r/EPA
EPA/600/FM3/303 / October 2012 / www.epa.gov/researc
United States
Environmental Protection
Agency
Data Gap Analysis and Damage
Case Studies: Risk Analyses from
Construction and Demolition
Debris Landfills and Recycling
Facilities
Prepared for:
U.S. Environmental Protection Agency
Office of Research and Development
National Risk Management Research Laboratory
Land Remediation and Pollution Control Division
Waste Management Branch,
Cincinnati Ohio
Prepared by:
Innovative Waste Services
Gainesville, FL
Under subcontract to
RTI International
Research Triangle Park, NC
EPA Contract No. EP-W-09-004
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EPA/600/R-13/303 Data Gap Analysis and Damage Case Studies for C&D Debris Facilities
Notice
The US Environmental Protection Agency (US EPA) through the Office of Research and Development
funded and managed the research described here under contract order number: EP-W-09-004 to RTI
International in Research Triangle Park, North Carolina. It has been subject to the Agency's review and
has been approved for publication as a US EPA document. Use of the methods or data presented in this
manual does not constitute endorsement or recommendation for use. Mention of trade names or
commercial products does not constitute endorsement or recommendation.
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EPA/600/R-13/303 Data Gap Analysis and Damage Case Studies for C&D Debris Facilities
Foreword
The US Environmental Protection Agency (US EPA) is charged by Congress with protecting the Nation's
land, air, and water resources. Under a mandate of national environmental laws, the Agency strives to
formulate and implement actions leading to a compatible balance between human activities and the ability
of natural systems to support and nurture life. To meet this mandate, US EPA's research program is
providing data and technical support for solving environmental problems today and building a science
knowledge base necessary to manage our ecological resources wisely, understand how pollutants affect
our health, and prevent or reduce environmental risks in the future.
The National Risk Management Research Laboratory (NRMRL) is the Agency's center for investigation
of technological and management approaches for preventing and reducing risks from pollution that
threaten human health and the environment. The focus of the Laboratory's research program is on
methods and their cost-effectiveness for prevention and control of pollution to air, land, water, and
subsurface resources; protection of water quality in public water systems; remediation of contaminated
sites, sediments and ground water; prevention and control of indoor air pollution; and restoration of
ecosystems. NRMRL collaborates with both public and private sector partners to foster technologies that
reduce the cost of compliance and to anticipate emerging problems. NRMRL's research provides
solutions to environmental problems by: developing and promoting technologies that protect and improve
the environment; advancing scientific and engineering information to support regulatory and policy
decisions; and providing the technical support and information transfer to ensure implementation of
environmental regulations and strategies at the national, state, and community levels.
This publication has been produced as part of the Laboratory's strategic long-term research plan. It is
published and made available by US EPA's Office of Research and Development to assist the user
community and to link researchers with their clients.
Cynthia Sonich-Mullin, Director
National Risk Management Research Laboratory
in
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EPA/600/R-13/303 Data Gap Analysis and Damage Case Studies for C&D Debris Facilities
Table of Contents
Notice ii
Foreword iii
Abbreviations and Acronyms ix
Executive Summary ES-1
1. Introduction and Background 1
1.1 Background on C&D Debris Management 1
1.2 Summary of Previous US EPA Evaluation of C&D Debris Management 2
1.2.1 US EPA Damage Evaluation (1995) 2
1.2.2 US EPA C&D Leachate Quality Evaluation and State Regulatory Evaluation
(1995) 3
1.2.3 40FR257Rulemaking 4
1.3 Project Objectives and Report Outline 4
2. State-by-State Summary of C&D Management 6
2.1 Overview and Methodology 6
2.2 State Regulatory Evaluation of C&D Debris Management 7
2.2.1 Alabama 7
2.2.2 Alaska 8
2.2.3 Arizona 8
2.2.4 Arkansas 8
2.2.5 California 9
2.2.6 Colorado 10
2.2.7 Connecticut 10
2.2.8 Delaware 11
2.2.9 Florida 11
2.2.10 Georgia 12
2.2.11 Hawaii 13
2.2.12 Idaho 13
2.2.13 Illinois 13
2.2.14 Indiana 14
2.2.15 Iowa 14
2.2.16 Kansas 15
2.2.17 Kentucky 15
2.2.18 Louisiana 16
2.2.19 Maine 16
2.2.20 Maryland 17
2.2.21 Massachusetts 18
2.2.22 Michigan 18
2.2.23 Minnesota 19
2.2.24 Mississippi 19
2.2.25 Missouri 20
2.2.26 Montana 20
2.2.27 Nebraska 21
2.2.28 Nevada 21
2.2.29 New Hampshire 22
2.2.30 New Jersey 22
2.2.31 New Mexico 23
IV
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EPA/600/R-13/303 Data Gap Analysis and Damage Case Studies for C&D Debris Facilities
2.2.32 New York 23
2.2.33 North Carolina 24
2.2.34 North Dakota 24
2.2.35 Ohio 24
2.2.36 Oklahoma 25
2.2.37 Oregon 25
2.2.38 Pennsylvania 26
2.2.39 Rhode Island 26
2.2.40 South Carolina 27
2.2.41 South Dakota 27
2.2.42 Tennessee 27
2.2.43 Texas 28
2.2.44 Utah 28
2.2.45 Vermont 29
2.2.46 Virginia 29
2.2.47 Washington 30
2.2.48 West Virginia 30
2.2.49 Wisconsin 31
2.2.50 Wyoming 31
2.3 Inventory of Active C&D Landfills and C&D Recycling/Processing Facilities 32
2.4 Discussion of State Regulations Review 35
2.5 Discussion of Identified Damage Sites 40
3. Evaluation of Potential Damage from C&D Management and Statewide C&D Management
Damage-Related Data 42
3.1 Overview and Methodology 42
3.2 Technical Discussion of Damage from C&D Debris Management Based on Recent
Scientific Literature 42
3.2.1 Groundwater impacts 43
3.2.2 Gas Production and Migration 44
3.2.3 Fires 44
3.2.4 C&D Debris Recycling 45
3.3 Florida - Groundwater Monitoring Data at C&D Disposal Facilities 45
3.3.1 Data Analyzed 46
3.3.2 Data Analysis Summary 50
3.4 Maryland - Unauthorized Waste Acceptance and Leachate and Groundwater Quality
at Rubble Landfills 50
3.4.1 Prohibited Waste Evaluation Review 51
3.4.2 Groundwater and Leachate Data Review by MDE in the Mid-1990s 51
3.4.3 Review of Rubble Landfill Groundwater Evaluation Memos Written by
MDE Since the Late 1990s 52
3.5 Minnesota - Groundwater Quality at C&D and Demolition Landfills 53
3.6 Ohio - Leachate and Groundwater Quality at C&D Landfills 54
3.6.1 C&D Landfill Leachate Study (2009) 55
3.6.2 Hydrogeologic Study of C&D Landfill Groundwater Data (2011) 55
3.6.3 Summary 56
3.7 Virginia - Compliance and Enforcement at C&D Debris Landfills and Processing
Facilities 56
3.7.1 VDEQ Compliance and Enforcement Database 56
3.7.2 Summary 59
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3.8 Wisconsin- Groundwater and Leachate Quality at C&D Landfills 59
3.8.1 Groundwater Data Evaluation 59
3.8.2 Leachate Data from C&D Landfills Evaluation 60
3.8.3 Summary 64
4. Detailed Damage Case Evaluation 65
4.1 Overview and Methodology 65
4.2 Damage Case 1: Saufley Landfill (Escambia County, Florida) 66
4.2.1 Site Description 66
4.2.2 Regulatory and Compliance History 67
4.2.3 Discussion of Damage 71
4.3 Damage Case 2: Archie Crippen Excavation Site (Fresno County, California) 76
4.3.1 Site Description 77
4.3.2 Compliance History 77
4.3.3 Damage Assessment 78
4.4 Damage Case 3: Warren Landfill and Recycling Facility (Trumbull County, Ohio) 82
4.4.1 Site Description 83
4.4.2 Compliance History 84
4.4.3 Damage Assessment 87
4.4.4 Summary 92
4.5 Summary of Detailed Damage Cases 93
5. Summary and Recommendations 94
6. References 96
VI
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List of Figures
1-1. Previously Reported Annual Estimates of C&D Debris Generation in the US 1
2-1. US Map Showing Grouped Distribution of the Number of Active C&D Landfills Based on
State Solid Waste Databases as of 2012 33
2-2. Distribution of the Number of C&D Debris Landfills in the US as a Function of State
Population 33
2-3. US Map Showing Grouped Distribution of the Number of Active C&D Recycling
Facilities Based on State Databases, Direct Facility Contact, and WBJ (2012) as of 2012 34
2-4. Distribution of the Number of C&D Debris Recycling Facilities as a Function of State
Population 34
2-5. Summary of Minimum C&D Landfill Liner and Leachate Collection System
Requirements in the US as of 2012 36
2-6. Average Annual Precipitation in the US From 1971 to 2000 (NOAA 2012). Error! Bookmark not
defined.
2-7. Summary of Minimum C&D Landfill Groundwater Monitoring Requirements Including
Conditional Requirements in the US as of 2012 37
2-8. Comparison of States with Required Groundwater Monitoring at C&D Landfills and the
Number of Landfills in a State Error! Bookmark not defined.
2-9. Distribution of States Corresponding to Bottom Liner, LCS, and Groundwater Monitoring
Requirements in the US 38
2-10. Summary of Minimum Operational Soil Cover Application Frequency for C&D Landfills
in Individual States in the US as of 2012 39
3-1. Summary of Broad Statistical Results Comparing Measurements of Field Parameters,
Inorganic Compounds, and Organic Compounds to GCTLs from Groundwater Monitoring
Data from C&D Landfills in Florida 47
3-2. Comparison of Concentration Distribution of Selected Parameters for Upgradient and
Downgradient Wells for C&D Landfills in Florida 48
3-3. Summary of the Number of Facilities That Exhibited at Least One Exceedance of a GCTL
at a Downgradient Monitoring Well, Organized Based on Chemical Constituent 49
3-4. Temporal Variation of the Most Commonly Observed Leachate Parameters at One C&D
Landfill Site in Wisconsin Compared to Corresponding Constituent Target Levels 61
3 -5. Inorganic Parameters Measured in Leachate from Wisconsin C&D Landfills 62
3 -6. Summary of Inorganic Parameters Measured in Leachate from Wisconsin C&D Landfills 63
3 -7. Organic Parameters Measured in Leachate from Wisconsin C&D Landfills 64
4-1. Site Layout Showing Approximate Location of Groundwater Monitoring Wells (Aerial
Imagery from FDEP Bureau of Survey and Mapping, December 2009) 67
4-2. Timeline of Non-Compliance and Hurricane Events for the Saufley Landfill (Bars
Represent Recurring Non-Compliance Issues as Noted in FDEP Inspection Logs) 70
4-3. Odor Complaints from Residences Near the Site Between 2002 and 2008 Based on FDEP
and FDOH Inspection Logs 73
4-4. Aerial View of Archie Crippen Excavation Site as of August 2002 (Google Earth 2012) 78
4-5. Compliance and Event Timeline at the Archie Crippen Excavation Site 80
4-6. Aerial View of the Archie Crippen Excavation Site Fire as of January 2003 (US EPA
2003a) 81
4-7. Wormholes in Debris Pile Fire Indicating Subsurface Combustion (US EPA 2003a) 82
4-8. Site Layout of the Warren Recycling Landfill with Approximate Landfill Phase Extents
(April 2012 Aerial Imagery from Google Earth) 83
4-9. Timeline of Non-Compliance Events and US EPA Time-critical Clean Up (Bars Represent
Recurring non-Compliance Issues as Noted in OEPA and WHCD Inspection Logs) 85
vn
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4-10. Warren Recycling Landfill Community Odor Complaints Between 2002 and 2004 (April
2012 Aerial imagery from Google Earth) 88
List of Tables
2-1. Summary of C&D Facility Damage Inventory Based on Queries to State Solid Waste
Regulatory Personnel and Examination of Other Publicly Available Reports and Case
Studies 41
3 -1. Summary of the Median Concentration of Measured Parameters in Groundwater that
Exceeded the GCTL in Downgradient Wells 49
3-2. Summary of Groundwater and Leachate Data for Rubble Landfills Analyzed by MDE
(1997a) in the Mid-1990s 51
3-3. Demolition Landfill Classification System Developed as Part of MPCA Guidance (MPCA
2005) 54
3-4. Summary of Chemical Parameters Measured in Similar Concentrations in C&D Landfill
Leachate and MSW Landfill Leachate at Facilities in Ohio (OEPA 2009a) 55
3-5. Summary of VDEQ Compliance and Enforcement Database for Active and Closed C&DD
Landfills, and C&DD Processing Facilities: Classifications of Administrative Violations 58
3-6. Summary of VDEQ Compliance and Enforcement Database for Active and Closed C&DD
Landfills, and C&DD Processing Facilities: Issues Observed Upon Inspection...Error! Bookmark
not defined.
3-7. Frequency of Additional Violation Categories Identified in the VDEQ Compliance and
Enforcement Database for Active and Closed C&DD Landfills and C&DD Processing
Facilities 58
4-1. Summary of Detailed Damage Case Sites Selected and Corresponding Identifying
Information 65
4-2. Summary of Parameters Exceeding GCTLs at Groundwater Monitoring Wells at the
Saufley Landfill 71
4-3. Summary of H2S and Other Air Quality Parameter Monitoring Events at the Saufley
Landfill 74
4-4. Summary of Landfill Fire Observations Noted in Inspection Reports and Approximate
Duration Until Fire Was No Longer Observed at the Saufley Landfill 75
4-5. Summary of Site Environmental Damages and Potential Contributing Factors Related to
and Not Related to Facility Non-Compliance at the Saufley Landfill 76
4-6. Summary of Major FfcS Monitoring Events at the Warren Recycling Landfill 89
4-7. Summary of Groundwater Monitoring Parameters Exceeding MCLs at Warren Recycling
C&D Landfill (2007 - 2010 Monitoring Data) 92
4-8. Summary of Site Environmental Damages and Potential Contributing Factors Related to
and Not Related to Facility Non-Compliance at the Warren Recycling Landfill 93
Vlll
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Data Gap Analysis and Damage Case Studies for C&D Debris Facilities
ADEM
ADEQ
APP
ATSDR
C&D
C&DD
C&DLF
C/D
C/DLF
CalRecycle
CaSO4
CCA
CCDD
C&D
C&DD
CDD
GDI
CDIL
C/DLF or C&DLF
CESQG
CFR
CH4
CIWMB
cm
CO
COD
CUP
CZS
DMWM
FAC
FDEP
FDOH
FFD
Abbreviations and Acronyms
Alabama Department of Environmental Management
Arkansas Department of Environmental Quality
Aquifer Protection Permit
Agency for Toxic Substances and Disease Registry
Construction and Demolition
Construction and Demolition Debris
Construction and Demolition solid waste Landfill
Construction/Demolition
Construction/Demolition-Inert Landfill Unit
Department of Resources Recycling and Recovery (California)
Calcium Sulfate
Chromated Copper Arsenate
Clean Construction and Demolition Debris
Construction and Demolition
Construction and Demolition Debris
Construction/Demolition/Debris
Construction & Demolition Debris and Inert Debris
Construction, Demolition, and Industrial Landfill
Construction and Demolition Landfill
Conditionally Exempt Small Quantity Generator
Code of Federal Regulations
Methane
California Integrated Waste Management Board
Centimeter
Carbon Monoxide
Chemical Oxygen Demand
Conditional Use Permit
Continuous Zone of Saturation
Division of Materials and Waste Management
Florida Administrative Code
Florida Department of Environmental Protection
Florida Department Of Health
Fresno Fire Department
IX
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Data Gap Analysis and Damage Case Studies for C&D Debris Facilities
ft
GCL
GCTL
GEMS
H2O
H2S
HOPE
IL
ILF
in.
L
LAC
LEL
MCL
MDE
MDEQ
MFA
Mg
mg
MPCA
MRF
MSW
MSWLF
NDEQ
NGVD
NMAC
NOV
NRMRL
OAC
OEPA
ORD
PER
PCB
PM
ppb
Foot or Feet
Geosynthetic Clay Liner
Groundwater Cleanup Target Level
Groundwater Environmental Monitoring System
Water
Hydrogen Sulfide
High Density Polyethylene
Intervention Limit
Industrial Landfill Unit
Inch or Inches
Liter
Louisiana Administrative Code
Lower Explosive Limit
Maximum Contaminant Level
Maryland Department of the Environment
Montana Department of Environmental Quality
Materials Flow Analysis
Magnesium
Milligram
Minnesota Pollution Control Agency
Materials Recovery Facility
Municipal Solid Waste
Municipal Solid Waste Landfill
Nebraska Department of Environmental Quality
National Geodetic Vertical Datum
New Mexico Administrative Code
Notice Of Violation
National Risk Management Research Laboratory
Ohio Administrative Code
Ohio Environmental Protection Agency
Office of Research and Development
Permit-by-Rule
Polychlorinated Biphenyl
Particulate Matter
Parts Per Billion
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Data Gap Analysis and Damage Case Studies for C&D Debris Facilities
ppm
RCRA
RTI
sec
SMCL
SO4
TCEQ
TDS
tpd
TS/MRF
UFC
^g
US
US EPA
VDEQ
VOC
WAC
WBJ
WCHD
WDNR
yd3
Parts Per Million
Resource Conservation and Recovery Act
Research Triangle Institute
Second(s)
Secondary Maximum Contaminant Level
Sulfate
Texas Commission on Environmental Quality
Total Dissolved Solids
Tons per day
Transfer Stations and Material Recovery Facility
Uniform Fire Code
Microgram
United States
United States Environmental Protection Agency
Virginia Department of Environmental Quality
Volatile Organic Compound
Washington Administrative Code
Waste Business Journal
Warren City Health District
Wisconsin Department of Natural Resources
Cubic yard
XI
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Executive Summary
Construction and demolition (C&D) debris represents a major component of the non-hazardous solid
waste stream in the United States and includes materials generated from road construction and related
infrastructure projects as well as from the demolition, construction, or renovation of building structures.
Although federal rules do not have mandates specific to C&D debris, there are several federal rules that
indirectly address the management of C&D debris. The federal standards found in 40 CFR 257 include
basic requirements to provide environmental protection, and landfills that receive conditionally exempt
small quantity generator (CESQG) hazardous waste must meet certain requirements including location
restrictions, groundwater monitoring, and corrective action, but bottom liners and leachate collection
systems are not required. As part of rulemaking for 40 CFR 257 Subpart B in 1995, two reports were
prepared that examined impacts of C&D debris landfills on human health and the environment.
Generally, the reports suggested that risks are minimal, but the universe of information used to arrive at
this conclusion was limited (e.g., 11 damage case studies out of a total 1,889 landfills were examined in
one report).
Since 40 CFR 257 Subpart B rulemaking, substantially more information regarding operational practices,
potential human health and environmental impacts, and risk factors related to C&D debris management
has been documented. Additionally, research has been conducted examining the potential environmental
impacts from the leaching of common components of C&D debris, as well as air emissions from the
disposal of C&D components including gypsum drywall. Furthermore, the emergence of large processing
facilities to recycle C&D debris has occurred, thus affecting the composition of C&D debris that is
ultimately disposed of in landfills.
In light of the amount of additional information that has been documented related to potential or actual
environmental impacts from C&D debris management, the US EPA commissioned an evaluation of C&D
debris management in the US to update and expand upon previous analyses to include information on
more recent cases of damage and potential impacts and expand the breadth of damages beyond
groundwater and surface water impacts. The specific objectives of the evaluation were to
evaluate current state regulations and broad statistics pertaining to C&D debris management in
the US;
gather information from states regarding areas of concern, if any, with respect to C&D debris
management facilities and their impact on human health and the environment;
identify and analyze data gaps between information collected as part of the CESQG rulemaking
and current, readily available information regarding C&D debris management, including (but not
limited to) environmental monitoring data and compliance and enforcement information for C&D
debris disposal and recycling facilities; and
conduct detailed damage case assessments at three sites identified as causing damage in the last
10 years with an expanded set of damage pathways in the analysis (e.g., groundwater, air
emissions, and fires).
The state regulatory evaluation documented information regarding minimum requirements for liner
systems, groundwater monitoring, and routine soil cover application. The review found several examples
where flexibility in meeting the minimum requirements was provided based on the specific location of the
facility, the waste acceptance rate of the facility, or the ultimate size of the facility. Twenty-six states
require groundwater monitoring for all C&D landfills, while an additional 11 require groundwater
monitoring on a conditional basis (i.e., landfill size, location). The number of states requiring
groundwater monitoring increased by approximately 28% since the evaluation conducted by the US EPA
in the mid-1990s. Seventeen states require an engineered liner system with a leachate collection system,
and 26 states require the application of cover material on the landfill's active face at least weekly. Nine
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states have rules specific to waste processing facilities that include C&D debris, while 10 states had rules
specific to C&D recycling and processing facilities.
Publicly-available inventories of C&D debris management facilities and information from trade
organizations and other databases were examined to estimate the number of active C&D debris disposal
and recycling facilities in the US. An estimated 1,540 active C&D debris landfills and 512 active
recycling facilities that only process C&D materials were identified. The number of active C&D landfills
was approximately 18% less than the inventory developed by the US EPA in 1994. The decline may be
attributable to several factors, including increased stringency in C&D rules at the state level as well as
closure of facilities following the economic downturn that began in late 2008, which greatly impacted the
construction industry.
The C&D damage case inventory was developed based mostly on discussions with state solid waste
regulatory staff and other publicly-available information (e.g., public hearing notices). In this
examination, "damage" was defined as facilities with groundwater impacts, recurring odor problems,
recurring fire problems, or other issues at the facility that impacted human health and the environment.
A total of 44 damage sites were identified, including facilities located in 17 different states covering eight
of the 10 US EPA regions. The majority of the facilities identified as having caused damage were C&D
disposal facilities. The number of actual damage sites is likely more than 44 because the inventory relied
on opinions of state regulatory representatives at the headquarters level (i.e., site compliance and damage
issues is handled at a more local or district level). The universe of damage sites examined was limited to
active or recent issues, thus historical damage was not captured. Finally, the number of damage cases
identified may have been limited because of the subjective nature of the term "damage", which could lead
regulatory personnel to respond differently based on their individual experience and interpretation of the
term.
Large-scale environmental compliance and monitoring data sets were reviewed from six states to examine
a broader picture of information related to actual or potential damage from C&D management. The six
states evaluated were Florida, Maryland, Minnesota, Ohio, Virginia, and Wisconsin. Several key
observations were made as a result of the large data set review. First, data from several states showed
evidence of groundwater impacts. Notably, many impacts were observed in states that had been
identified has having few or no damage sites. Data compiled by the Ohio EPA showed that many
chemicals measured in MSW landfill leachate were found at similar levels in C&D debris leachate (and in
some cases greater). A comparison of information collected before and after promulgation of liner and
leachate collection system rules in Maryland indicates that these measures have reduced the frequency
and magnitude of groundwater impacts at C&D landfills in the state.
Three C&D debris management facilities were selected for a detailed damage case evaluation, with the
intent of evaluating historical permitting documentation, inspection records, and environmental
monitoring data to further understand the confluence of factors that led to damage, with particular focus
on issues caused by permit non-compliance and issues that would have occurred even if the facility
operated in compliance with its permit. The three facilities included the Saufley Landfill (C&D landfill in
Florida), the Archie Crippen Excavation Site (C&D recycling facility in California), and the Warren
Recycling Landfill (C&D landfill in Ohio). Ultimately, the examination found permit non-compliance
was not the only contributor to the damage issues observed at each site.
The results of the analysis show that a variety of issues can occur at C&D management facilities. The
inventory of damage sites in the US was limited by several factors, but the examination of large-scale
statewide data suggests that the universe of C&D sites impacting the environment is likely far greater than
the inventory developed through contacts with state regulatory representatives. The detailed assessment of
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three damage cases each showed that a combination of factors, both related and unrelated to permit non-
compliance, played a significant role in causing damage.
In light of these observations, it is recommended that the findings of this report be augmented by the
following actions: survey those directly involved with compliance and enforcement of facilities (i.e.,
regulatory staff at the district, regional, or local level) to create an enhanced damage site inventory in the
US, compile and examine additional large-scale data sets from other states in the US to provide a more
complete picture of the ranges of constituent concentrations in C&D leachate and in groundwater at C&D
management facilities, develop an improved inventory of C&D recycling facilities, and develop an
improved inventory of the quantity of C&D debris managed in the US (disposal and recycling) to allow
for improved management benchmarking similar to that which has been done for MSW for several years.
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1. Introduction and Background
1.1 Background on C&D Debris Management
Construction and demolition (C&D) debris is generated from the construction, renovation, repair, and
demolition of structures such as residential and commercial buildings, roads, and bridges. The
composition of C&D debris varies based on the activity type and structure. In general, C&D debris is
mainly comprised of concrete, wood products, metal, asphalt, drywall, and masonry products; other
components often present in significant quantities include paper, earthen materials, and vegetative debris.
Trace quantities of C&D debris may include paints, solvents, adhesives, and other related chemical
products. C&D debris can be disposed of in landfills (either dedicated C&D landfills or co-disposed with
other wastes such as MSW) or recovered for recycling.
Attempts have been made to estimate the amount of C&D debris generated annually in the United States
(US), and results vary depending on the assumptions built into the estimate methodology. Figure 1-1
presents a summary of three studies conducted to estimate C&D debris generation in the US. Earlier
estimates of C&D debris generation by the US Environmental Protection Agency (US EPA) (1998 and
2009) used an assumed waste weight per construction activity area to calculate C&D debris generation,
with estimates of 136 million and 170 million tons in 1996 and 2003, respectively. A limitation of these
estimates is that they do not account for the large volume of infrastructure-related C&D debris that is
generated in the US. A study conducted by Cochran and Townsend (2010) used a different approach to
estimate C&D debris generation that relied on a materials flow analysis (MFA) approach and included all
C&D debris (building-related and infrastructure-related). The MFA approach, which is similar to the
methodology used by the US EPA to estimate the annual generation rate of MSW in the US, accounted
for the consumption of construction materials in the US, assumed typical waste factors used for
construction materials purchasing, and estimated the material service life to calculate the mass of C&D
debris generated in the US. Based on the assumptions used, a range of 680 million to 860 million tons of
C&D debris generation was estimated for the year 2002. As a point of comparison, the estimate of the
MSW generation in the US in 2003 was approximately 236 million tons (US EPA 2005). More accurate
estimates (such as compiling data collected from disposal and recycling facilities in the US) is difficult
since many areas (states and local regulatory agencies) do not require tracking of waste amounts received
at landfills.
800
a
e
= 700
- 600
a
500
U o
£ 300
a
«8
(J
200
100
0
Includes all C&D. Estimated
through MFA method.
Includes only building-
related C&D'Estimated
through "waste weight
per construction activity"
method.
1
US EPA (1998)
US EPA (2009)
Cochran arj . ,
. ._ Cochran and
Townsend (2 /omm
Townsend (2010)
Figure 1-1. Previously Reported Annual Estimates of C&D Debris Generation in the US
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EPA/600/R-13/303 Data Gap Analysis and Damage Case Studies for C&D Debris Facilities
In many cases, design and construction requirements for dedicated C&D debris disposal facilities are less
stringent than federal requirements found in Title 40 Code of Federal Regulations (CFR) Part 258
(Subtitle D requirements) (e.g., no bottom liner or leachate collection and removal system), which often
allows this method of disposal to be less expensive for a waste generator compared to other types of
disposal facilities, which in turn can represent an economic disincentive to recycling. Furthermore, the
absence of certain environmental controls can lead to impacts to human health and the environment.
Given the large quantity of C&D debris generated in the US, the potential for the management and
disposal of certain components of C&D debris to impact human health and the environment, and the
varied environmental controls required at C&D management facilities, an examination of the potential
human health and environmental impacts that may occur is warranted.
1.2 Summary of Previous US EPA Evaluation of C&D Debris Management
The 1984 Hazardous and Solid Waste Amendments to the Resource Conservation and Recovery Act
(RCRA) required the US EPA to revise the existing land disposal criteria found in 40 CFR Part 257 for
facilities that accepted household hazardous waste and small quantity generator hazardous waste. The US
EPA revised criteria for MSW landfills in 1991 (40 CFR Part 258) because a majority of household
hazardous wastes and small quantity generator hazardous wastes were disposed of in MSW landfills.
Additional criteria for non-hazardous, non-MSW facilities that accepted a portion of these wastes were
developed in 1995. A new Subpart B was added to 40 CFR 257 to establish facility standards for non-
MSW disposal facilities that receive Conditionally Exempt Small Quantity Generator (CESQG) waste,
and C&D debris landfills were included as one of the facility types that may receive CESQG waste
(examples of possible CESQG waste included paints, roofing cements, and adhesives). The US EPA
commissioned two studies to examine the potential for human health and environmental impacts from
C&D debris landfills and gather information regarding the way that C&D debris landfills are regulated at
the state level as part of the 40 CFR 257 Subpart B rulemaking to assess whether further restrictions on
C&D debris landfills beyond those proposed in the rulemaking were justified.
1.2.1 US EPA Damage Evaluation (1995)
The US EPA commissioned an evaluation of "damage cases" at C&D debris disposal facilities in support
of rulemaking related to the CESQG rule (US EPA 1995a). Prior to this examination, C&D debris was a
portion of the waste stream that was not widely studied from an environmental impacts perspective and in
many cases was largely considered to be inert. The evaluation criteria used in the study included facilities
that accepted predominantly C&D debris (with or without CESQG waste), and the definition of damage
was limited to cases where the C&D landfill was the only potential or observed contamination source.
The study examined the technical literature, a database of Superfund sites, and information from the state
regulatory staffs institutional knowledge to identify damage cases. Two primary resources in the
technical literature and responses from 32 states served as the basis for the study's damage case database,
which identified 11 damage sites in three states: New York, Virginia, and Wisconsin. A facility was
considered to have damage if, based on a review of data and operating records, measured constituent
concentrations in groundwater detection wells were above background levels or exceeded corresponding
regulatory or health-based standards. The damage case search was inhibited largely by the following
factors:
Information from 32 of 50 states (64%) was evaluated. Some states not contacted were among
those with the largest number of C&D landfills (e.g., Louisiana, with 167 C&D landfills as of
1994 [US EPA 1994], was not surveyed).
Several states did not require groundwater or surface water monitoring, thus the understanding of
actual impacts could not be ascertained (e.g., Florida, which had 277 C&D landfills as of 1994
[US EPA 1994], did not require monitoring at the time, thus damage was not evaluated).
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The study also included ecological damage as a criterion, defining this type of damage as cases where
constituent concentrations measured in surface water exceeded the US EPA's Ambient Water Quality
Criteria, which were developed for the protection of aquatic communities. Additionally, the exclusionary
criteria used to isolate C&D landfills prohibited the evaluation of several sites that may have had co-
disposal of C&D with MSW or that had limited site historical use information available. Note that none
of the 11 damage cases had reported damage that fit the ecological damage criteria. Other instances of
impacts (e.g., odors) were occasionally noted in site history descriptions but were not examined as a
criterion for damage.
All of the 11 reported damage cases had groundwater contamination identified on-site. In nearly all cases,
the groundwater impacts were related to the presence of inorganic constituents above maximum
contaminant levels (MCLs), including
manganese (9 of 11 sites); four of the nine sites had measurements that exceeded secondary
MCLs (SMCLs) by more than a factor of 100;
iron (8 of 11 sites); five of the eight sites had measurements that exceeded SMCLs by more than a
factor of 100;
total dissolved solids (TDS, 6 of 11 sites);
lead (5 of 11 sites);
magnesium (4 of 11 sites);
sodium (4 of 11 sites); and
sulfate (3 of 11 sites).
In most cases, off-site groundwater monitoring data were not available. While a goal of the assessment
was to link environmental damages to the design, operation, or location of the landfill, such a connection
was not established because of a lack of available or reliable data.
As for surface water impacts, six sites had observed surface water contamination, which primarily
consisted of inorganic constituents (iron, zinc, lead, and copper). Two sites had measured sediment
contamination in the form of polynuclear aromatic hydrocarbons. None of the sites had reported fish kills
or other observable impacts on aquatic life.
The US EPA concluded that impacts to groundwater and surface water had been documented based on the
cases that were reviewed. However, they believed that insufficient data existed to require more than the
statute required in the revised criteria for facilities that may receive CESQG waste (i.e., groundwater
monitoring, corrective action, and location restrictions). The US EPA also concluded that the evaluation
of 11 sites out of 1,889 precluded a meaningful, significant data set upon which further decisions could be
made.
1.2.2 US EPA C&D Leachate Quality Evaluation and State Regulatory Evaluation
(1995)
Data collected on leachate quality and state regulations related to C&D debris management were gathered
and evaluated in support of rulemaking related to the CESQG rule in 1995 (US EPA 1995a,b,c). Data for
305 chemical parameters that were sampled at one or more of 21 C&D landfills were compiled. A total of
93 chemical parameters were detected in leachate at least once, and of the 93 detections, 24 had at least
one exceedance of a federal drinking water standard or health-based standard. Overall, a total of seven
constituents were identified as potentially problematic based on their detection at any landfill where the
median value of the detected concentration exceeded the corresponding regulatory limit or health-based
standard.
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The most frequently detected constituents were iron, lead, manganese, and TDS - more than 70% of all
landfills for which data were available had median concentrations of these constituents greater than the
corresponding drinking water or health-based standard. The ratios of the median detected concentration of
iron and manganese to the corresponding standard were 37:1 and 59:1, respectively, while the ratio for
both lead and TDS was approximately 4:1. The report acknowledged that while the data from these
landfills indicated the potential for leachate produced at C&D debris landfills to exceed applicable
regulatory or health-based standards, the small number of sites (21) compared to the estimated number of
sites in the US (1,889) suggests that the data were not a statistically rigorous representation of the
population of C&D landfills.
The state regulatory review presented a variety of information regarding the extent of C&D debris facility
regulation. The major observations were as follows:
Groundwater monitoring was required in 29 states for some or all off-site C&D landfills, though
the stringency (e.g., frequency required) varied and was often less stringent than 40 CFR Part 258
(24 cases). Off-site C&D landfills are facilities that accept C&D debris from multiple locations
(as opposed to an on-site C&D landfill, where construction debris is disposed at the point of
generation).
Corrective action requirements existed for off-site C&D landfills in 22 states..
Permitting requirements existed in 45 states for off-site C&D landfills.
1.2.3 40 FR 257 Rulemaking
The US EPA acknowledged that requiring non-MSW disposal facilities that receive CESQG waste to
comply with all of the same requirements as MSW disposal facilities did not appear necessary because of
the apparent lower risk posed by non-MSW facilities (US EPA 1995a). Specifically, the US EPA relied
upon the damage case assessment (which reported information from 11 C&D sites that suggested C&D
landfills have negatively impacted groundwater quality), the leachate quality evaluation (which suggested
leachate from C&D debris can exceed applicable federal drinking water standards, but not at levels or
with constituents that were identified as sufficient to warrant additional rulemaking), and information
provided by the public during the commenting period of rulemaking to make this determination.
1.3 Project Objectives and Report Outline
The studies conducted as part of CESQG rulemaking in 1994 and 1995 provided US EPA with the state
of the practice of C&D debris management at the time, as well as limited data and information related to
actual or potential impacts that had occurred at C&D disposal facilities. Since the development of those
studies, changes have occurred with respect to C&D debris generation and management, regulation of
C&D facilities in the states, as well as the scientific community's understanding of actual or potential
risks associated with the management of C&D debris. Some of these changes include:
Development of more stringent regulations in states for C&D debris management facilities since
1995. This includes expanded requirements for groundwater monitoring, liners and leachate
collection systems, and waste prohibitions.
Expanded practices of C&D debris recycling. Though accurately accounting for specific C&D
recycling practices is complex, a US EPA (1998) estimate suggested approximately 20% to 30%
of building-related C&D debris was recovered for recycling in 1996, while an updated US EPA
(2009) report suggested that a 48% C&D debris recovery rate estimated for eight states may be
reasonably applied to the rest of the US. The expanded practice of C&D debris recycling results
in two major shifts compared to historical C&D debris management: greater presence of C&D
processing and recycling facilities, and a change in the composition of C&D debris delivered to
landfills for disposal. Though difficult to quantify, the separation and recycling of bulky C&D
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components (e.g., concrete) may result in the removal of C&D components that are not expected
to produce a leachate that is harmful to human health and the environment, thus increasing the
proportion of discarded C&D materials that could leach elevated concentrations of chemicals of
concern.
Enhanced scientific understanding of C&D debris impacts. Significant research efforts have
occurred since the mid-1990s with respect to the characterization of different components of
C&D debris, including leaching behavior (e.g., treated wood) and the potential to develop air
emissions including reduced sulfur compounds (e.g., from the reduction of sulfate (SC>42~)
contained in gypsum drywall). Additionally, a greater understanding of factors that can contribute
to problematic conditions such as fires, as well as approaches to prevent and address fires, has
been developed.
In light of the changes that have occurred in the approximately 17 years since the publication of the
previous nationwide studies on C&D debris, US EPA Office of Research and Development (ORD)
identified C&D debris disposal and management as a priority area for further examination to fill data gaps
and further explore C&D facility damage. The specific areas of focus were as follows:
Updated Evaluation of State Regulations, to include a state-by-state assessment of current
regulations. The primary focus of the regulatory examination was to assess rules related to the
requirements for bottom liner systems, operational conditions such as cover requirements and fire
prevention and control, and groundwater monitoring at landfills, and to identify states where
C&D debris recycling is a regulated activity.
Updated Inventory of Facilities That Primarily Handle C&D Debris, to include active C&D
disposal facilities and C&D processing/recycling facilities.
Expanded Criteria for Damage. The previous investigation by US EPA mainly focused on
groundwater impacts and limited data on leachate quality. These criteria were examined further in
this evaluation and the criteria were expanded to include air emissions and fires as additional
points of concern.
Expanded Evaluation of Damage. The previously conducted damage evaluation included
several data gaps. The damage evaluation in this project was expanded to use a three-tier
approach. First, developing an inventory of damage sites based solely on discussions with state
regulatory personnel. Second, examining large statewide data sets from several states to identify
and assess actual or potential environmental impacts. Third, identifying a select number of sites
(three) for detailed multi-media examination of damage at the facility level to understand the
factors that led to damage.
This report is organized into six sections. Section 1 presents the background on C&D debris management,
the project objectives, and the report organization. Section 2 provides a state-by-state regulatory summary
and database of active C&D landfills and processing facilities. Section 3 presents an evaluation of six
statewide studies related to C&D debris facility damage or compliance and enforcement records.
Section 4 presents detailed damage case evaluations for three specific C&D debris sites, two landfills, and
one recycling facility. Section 5 presents brief concluding remarks and recommendations for future
evaluations. Section 6 presents a listing of references and resources examined in the development of this
report.
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2. State-by-State Summary of C&D Management
2.1 Overview and Methodology
Currently, no federal rules specific to C&D debris management exist; however, several regulations exist
that indirectly impact C&D management facilities (e.g., hazardous waste rules in 40 CFR 261,
Subtitle C). A review of C&D debris management regulations in each of the 50 states was conducted to
provide appropriate context during the evaluation of data from statewide evaluations (Section 3) as well
as the detailed site-specific damage cases (Section 4). Last, the state regulation summary can help
facilitate an understanding of potential linkages between C&D debris management and observed human
health and environmental impacts.
The regulatory summary was conducted by searching each state environmental agency's websites. The
primary focus of the examination focused on rules pertaining to C&D debris disposal facilities, though in
some cases rules related to C&D debris recycling facilities were assessed. The regulations were reviewed
to gather specific information and understand key differences and similarities among states, including
whether regulations specific to C&D debris existed;
bottom liner requirements, with or without leachate collection;
groundwater monitoring requirements; and
operational requirements, which may include (but not be limited to) cover soil application
requirements and fire prevention and control.
If required, state regulatory agency solid waste personnel were contacted to get clarification on rule
interpretation related to one or more of the above-referenced factors. Since laws and regulations are
updated from time to time, the information presented for each state in this section should be considered as
a snapshot of existing regulations. In some cases, references to ongoing rulemaking are made.
In addition to developing state-by-state regulatory summaries, an inventory of the active C&D debris
disposal sites and processing/recycling facilities was developed. Data were sourced using a multi-step
process. The primary source of data for the inventory was publicly available databases listed on state
environmental regulatory agency websites or lists furnished directly by state regulatory agencies - the
database of active C&D landfills was sourced exclusively in this manner. The database of active C&D
processors was mostly obtained through state databases and data requests (36 states), while remaining
data gaps (9 additional states) were filled by making direct facility contact based on a C&D recycling
trade organization website (Construction Materials Recycling Association), and the remainder of the
database was populated using data from a trade industry database (Waste Business Journal [WBJ] 2012).
For comparison, the new list of sites was compared to the reported active C&D landfills in the US from
the 1994 US EPA report. Data regarding C&D processing facilities were mined from WBJ (2012) by
applying exclusionary criteria to eliminate recycling facilities that processed materials other than C&D
debris. Specifically, data points for sites that did not identify the waste type processed or that included
general recyclables, MSW, industrial waste, sludge, ash, white goods, or any other non-C&D type
materials within the description were excluded. Facilities that only processed the following waste types
were also excluded from analysis:
aluminum, copper, red metals, iron, stainless steel, or other metals;
contaminated soil;
yard waste; and
automobile tires.
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Finally, the state-by-state evaluation involved developing an inventory of C&D damage sites. The
collection and review of each state's regulations was conducted prior to researching potential damage in
each state so that appropriate C&D facility classifications and definitions were understood to ensure that
reported information on damage was specific to C&D debris facilities. The project team contacted the
state solid waste regulatory agency headquarters staff that was identified as most directly involved with
C&D debris and/or solid waste permitting or compliance. The regulatory staff were then asked about their
awareness of current or recent instances where a permitted C&D debris management facility had
impacted the environment or met the definition of damage, which was generally defined as a facility that
met one or more of the following criteria:
Had impacted groundwater, as evidenced through routine monitoring.
Had recurrent issues with leachate releases or observed leachate containment problems.
Had odor management or emissions issues, including those with recurring complaints from the
surrounding community.
Had reported fire events.
The evaluation was intended to obtain an inventory of the number of C&D sites in each state that
currently or recently had caused damage. Given that this was not a formal survey that was distributed to
all states, there are some notable limitations with the data gathered in this effort:
Several regulatory staff contacted indicated that compliance and enforcement is handled at the
regional or district level, so no direct knowledge of problem or damage sites was known at the
headquarters level.
Inquiries relied upon the direct knowledge of the regulatory staff to provide information on sites
that had caused damage.
Specific details or data regarding the sites in general were not gathered, so independent validation
or verification of the regulatory staffs assessment of damage was not made.
The nature of the question of damage (even in light of the clarifying remarks above) is somewhat
subjective, thus a response of "yes" to damage from one respondent could also be a response of
"no" from another respondent, and vice versa.
In a limited number of instances the project team utilized other publicly available resources to identify
damage sites in different states, which included public meeting notices, news media archives, and
environmental monitoring reports. Only facilities that met the criteria described previously were included
in the inventory.
2.2 State Regulatory Evaluation of C&D Debris Management
2.2.1 Alabama
The solid waste regulating authority is the Alabama Department of Environmental Management (ADEM).
The rules for the Land Division - Solid Waste Program are provided within ADEM Administrative Code
Division 13. Construction/demolition waste is defined to include non-putrescible and non-hazardous solid
waste, specifically: waste building materials, packaging, and rubble resulting from construction,
remodeling, repair, or demolition operations on houses, commercial buildings, and other structures. Such
wastes include, but are not limited to, masonry materials, sheet rock, roofing waste, insulation (not
including asbestos), scrap metal, and wood products.
Construction/demolition-inert landfill units (C/DLF) can receive construction/demolition waste, rubbish,
water treatment (alum) sludge, or foundry waste meeting Rule 335-13-4-.26(3). Industrial landfill units
(ILF) receive industrial solid waste and may also receive construction/demolition waste and or/rubbish.
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Materials such as asphalt, clean concrete, and green waste are excluded from the definition of C&D
waste.
Bottom liners are not required for C/DLFs or ILFs as long as liquid waste is not accepted. Groundwater
monitoring is not required for C/DLFs unless industrial waste or other prohibited materials have been
accepted. Weekly soil cover application is required for C/DLFs.
2.2.2 Alaska
The Alaska Department of Environmental Conservation regulates solid waste through the Alaska
Administrative Code; Title 18 Environmental Conservation, Chapter 60 Solid Waste Management. Many
C&D-type materials are exempt from the requirements of the solid waste rules unless they are mixed with
non-exempt waste or there is an identified threat to health or the environment. Such excluded materials
include: land clearing waste, including excavated dirt, rock, soil, butt ends, and stumps; tree limbs and
other foliage or woody debris, sometimes referred to as "slash" in a timber harvest area; bricks, mortar,
and Portland cement type concrete, including reinforcing steel that cannot be easily removed; crumb
rubber used in asphalt paving; and crushed glass.
For C&D material that must be landfilled, there are provisions for disposal within municipal landfills,
non-municipal landfills, or inert waste monofills. Inert waste monofills were the most relevant type of
facility to investigate regarding C&D waste management in Alaska because these facilities primarily
accept C&D and non-ash waste. Bottom liners are not required and groundwater monitoring is conditional
at inert monofills. Groundwater monitoring is not required for an inert monofill with a volume of less
than 1,000 cubic yards (yd3), or located within an area that receives 25 in. or less of total precipitation
each year. Unless there has been a non-inert load of waste placed, there is unexplained contamination in
nearby wells or there is evidence of a spill, groundwater monitoring is not required. Cover requirements
are determined on a case-by-case basis. The owner or operator of an inert waste monofill that accepts
combustible inert waste must maintain fire control equipment to extinguish any fires that may occur.
2.2.3 Arizona
The Arizona Department of Environmental Quality is the state solid waste regulatory authority. The state
has not established rules specific to C&D debris landfills. Construction debris and demolition debris are
defined within the state statutes. Construction debris means solid waste derived from the construction,
repair, or remodeling of buildings or other structures, and demolition debris means solid waste derived
from the demolition of buildings or other structures. Within the Arizona Administrative Code Title 18:
Environmental Quality, Chapter 13: Department of Environmental Quality- Solid Waste Management,
both C&D landfills as well as private landfills fall under the definition of non-municipal solid waste
landfills (non-MSWLFs). C&D landfills only accept solid waste derived from constructing, repairing, or
remodeling of buildings or other structures or demolishing buildings or other structures. Private landfills
accept only permitted wastes generated on-site. There are no specific bottom liner requirements, however,
non-MSWLFs are required to use best available demonstrated control technology and may be subject to
groundwater monitoring as a condition of an Aquifer Protection Permit (APP). Most APPs require 6 in. of
soil as daily cover. Some landfills are also permitted to use alternative daily cover.
2.2.4 Arkansas
The Arkansas Pollution Control and Ecology Commission created Regulation No. 22: Solid Waste
Management Rules, which are administered by the Arkansas Department of Environmental Quality
(ADEQ). C&D waste is defined as: any and all material and debris that might result from the construction
or demolition of any building or other manmade structure including but not limited to single and
multifamily dwellings, commercial buildings, road and highway construction and repair, remodeling and
additions to existing structures, and roofing. Materials may include (but are not limited to) dimensional
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lumber, roofing materials, bricks, concrete blocks, siding, gypsum (drywall), masonry, metal, cardboard,
concrete with and without rebar, fill materials (including earth, gravel, and stone), glass, and any other
material that may be used in any construction project or may be salvaged from any demolition project.
C&D waste falls under a Class 4 waste designation, which includes nonhazardous, bulky, inert, non-
putrescible solid wastes that do not degrade, or degrade very slowly. Class 4 wastes also include
appliances, furniture, stumps, limbs, and other bulky wastes that are not normally collected with other
household, commercial, or industrial waste. Liners for Class 4 landfills are conditionally required. When
landfills are sited in a location that provides permeability <1 x 10~5 cm/sec and all other standards are met,
a liner is not required. Otherwise, an 18 in. thick compacted clay liner (at a minimum) with a hydraulic
conductivity no greater than 1 * 10~5 cm/sec is required.
Class 4 landfills are exempt from groundwater monitoring unless the Director of ADEQ determines
monitoring is required to confirm groundwater standards are met. At a minimum, weekly cover with 6 in.
of earthen materials must be applied to control disease vectors, fires, odors, blowing litter, and scavenging
and to limit the generation of leachate. Daily spreading and compaction of the waste shall be performed to
minimize void space and reduce the potential for disease vectors and fires. Control of explosive gases
through a methane (CFLO monitoring program may be required if the Director determines that waste
quantities and characteristics of explosive gas standards are exceeded.
2.2.5 California
The California Environmental Protection Agency includes the Waste Permitting, Compliance and
Mitigation Division, which is within the Department of Resources Recycling and Recovery (CalRecycle),
the C&D waste regulatory oversight body. Compliance and enforcement of facilities is generally handled
at the local level by local enforcement agencies (LEAs). Within the California Code of Regulations Title
14 Natural Resources and Title 27 Environmental Protection, there is language that pertains to C&D
waste disposal and recycling. C&D waste could fit under both definitions of C&D Waste and Type A
inerts simultaneously (Type A inerts are effectively a subset of C&D waste). C&D Waste includes waste
building materials, packaging, and rubble resulting from construction, remodeling, repair and demolition
operations on pavements, houses, commercial buildings, and other structures. Type A inert debris
includes concrete (including fiberglass or steel reinforcing bar embedded in the concrete), fully cured
asphalt, glass, fiberglass, asphalt or fiberglass roofing shingles, brick, slag, ceramics, plaster, clay and
clay products. Type A inert debris is waste that does not contain soluble pollutants at concentrations in
excess of water quality objectives and has not been treated in order to reduce such pollutants.
C&D waste may be disposed of at C&D debris, inert debris (GDI), or MSW disposal facilities; inert waste
can also be disposed of in inert waste disposal landfills. Typically, GDI facilities are fully permitted solid
waste facilities and fall under Class III non-hazardous waste facility regulations; Type A inert debris
disposal facilities are required to obtain a registration permit (which is easier to obtain than fully
permitted status) prior to beginning operations. GDI and inert debris processing facilities are regulated
depending on the waste type being processed and at the daily waste throughput. For example, GDI
processors can be small (<25 tons per day [tpd]), medium (25 - 175 tpd) or large (>175 tpd) volume
facilities and thus respectively must submit or obtain the following paperwork: Local Enforcement
Agency notification, registration, or full solid waste facility permit. The state's Regional Water Boards
have final authority over the extent to which all facilities are permitted. There are also inert waste
engineered fill operations, which are different from GDI disposal sites because the material is used to
create a dense mass that can support structural loading and may be used for recreational, agriculture,
roads, buildings or other approved purposes.
In general, liners are conditional for Class III disposal facilities; if site characteristics do not ensure
protection of the quality of ground water or surface water, Class III landfills are required to have a single
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clay liner with hydraulic conductivity of 1 * 10~6 cm/sec or less. Leachate collection is required if a facility
has a liner or accepts sewage or water treatment sludge. Water quality monitoring is required and gas
monitoring and control are required to keep QrU and trace gases from migrating off site or causing any
adverse exposure. A minimum of 6 in. of compacted earthen material is to be applied at the end of each
operating day to control vectors, fires, odors, blowing litter, and scavenging. Earthen material may
include contaminated soil and soil with contaminants other than petroleum hydrocarbons that has been
approved for use as daily cover. As previously noted, the Regional Water Boards have final regulatory
jurisdiction and may require more stringent facility operational practices on a case-by-case basis.
2.2.6 Colorado
In Colorado, the Department of Public Health and Environment, Hazardous Materials and Waste
Management Division regulates solid waste facilities. The Regulations Pertaining to Solid Waste Sites
and Facilities are provided in 6 Code of Colorado Regulations 1007-2 Part 1. The definitions of both inert
waste and C&D debris describe common C&D wastes. Inert material is defined as non-water soluble and
non-putrescible solids. The term includes materials such as earth, sand, gravel rock, concrete, masonry,
asphalt paving fragments, and other inert solids. C&D debris is waste generated from construction,
remodeling, repairs, or demolition of buildings, pavements, and other structures which includes but is not
limited to, lumber, bricks, carpets, ceramics, sheetrock, metals, drywall, window glass, metal and plastic
piping, paint, and any other non-hazardous materials resulting from C&D operations. There are inert
waste landfills that accept only inert waste but there are currently no C&D waste-only landfills, as
standard practice in the state is for C&D waste to be disposed of at MSWLFs. Debris and ash from fires
within the state are classified as "special waste" and are disposed at MSWLFs after being wrapped in 6-
mil thick plastic sheeting. There is a section reserved within the rules to specifically address C&D
disposal facilities and there are ongoing discussions with the mining industry to develop an approach to
regulate C&D disposal facilities.
At present, independent C&D facilities would be regulated under the rule sections that generally address
disposal landfill sites and facilities. Design and operational requirements include a liner comprised of
natural lithology (compacted), a soil liner, a composite liner, or an alternative design; an accompanying
leachate collection system designed to maintain less than 1 ft of leachate head over the barrier layer,
promoting transport of leachate from the most distant point of the leachate collection system to the
leachate removal system in less than 12 months; and groundwater monitoring. The owners or operators of
all solid waste disposal sites and facilities that may generate explosive gases must also monitor for
explosive gases and implement a routine monitoring program. The type and frequency of monitoring will
vary depending on the site but if elevated levels are measured, a remediation plan must be created and
followed. Additionally, the owners or operators of all landfills must cover disposed solid waste with 6 in.
of earthen material at the end of each operating day, or at more frequent intervals if necessary to control
disease vectors, fires, odors, blowing litter, and scavenging.
2.2.7 Connecticut
The State of Connecticut Department of Environmental Protection is the regulating body for solid waste.
Title 22a Chapters 208 & 209 provide the rules for solid waste facilities. C&D waste is defined as waste
building materials or packaging resulting from construction, remodeling, repair, or demolition operations
on houses, commercial buildings, and other structures, excluding asbestos, clean fill, or solid waste
containing greater than de minimis quantities of radioactive, liquid, or hazardous waste. The definition of
bulky waste includes land clearing debris and waste resulting directly from demolition activities other
than clean fill.
Many of the landfills accepting C&D (bulky waste landfills) in Connecticut have limited capacity or are
closed, and therefore a majority of the C&D waste generated in Connecticut is first size-reduced and then
transported out of state for disposal. There are no liner or leachate collection requirements for bulky waste
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disposal sites in Connecticut, but groundwater monitoring and daily cover are required. There are also
provisions listing fire protection measures, including immediate notification of the Department when
there is smoldering, smoking, or burning on site; contacting the fire department; continuing firefighting
until all smoldering, smoking, and burning has ceased; closing the facility if required; not conducting
disposal activities in the immediate vicinity of smoldering, smoking, or burning; and fixing any structural
damage caused by fire.
2.2.8 Delaware
The Department of Natural Resources and Environmental Control is the regulatory authority for solid
waste. The regulations applicable to C&D waste are within the Delaware Administrative Code Title 7
Natural Resources and Environmental Control, 1301 Regulations Governing Solid Waste. C&D waste is
not explicitly defined within the Delaware solid waste rules but C&D materials can be classified as dry
and industrial wastes. Dry waste means wastes including, but not limited to, plastics, rubber, lumber,
trees, stumps, vegetative matter, asphalt pavement, asphaltic products incidental to construction/
demolition debris, or other materials that have reduced potential for environmental degradation and
leachate production. Industrial waste means any waterborne liquid, gaseous, solid, or other waste
substance or a combination thereof resulting from any process of industry, manufacturing, trade or
business, or from the development of any agricultural or natural resource.
Landfills classified as industrial can accept both industrial and dry wastes and thus C&D-type wastes.
There is one industrial landfill in Delaware that accepts mostly C&D waste. Delaware requires bottom
liners for industrial landfills; depending on site characteristics, the liner may be a composite, natural or
double liner. Unless otherwise approved, the bottom of the liner (second liner for a double liner) must be
at least 5 ft above the seasonal high groundwater table. A leachate collection system is required along
with a leachate treatment and disposal system, and a leachate monitoring system. The leachate collection
system must be designed to prevent the leachate head on the liner from exceeding 1 ft. Gas control
systems must be installed at industrial landfills where the materials landfilled would be expected to
produce gas, and a sufficient number of gas monitoring wells shall be installed to evaluate gas production
rates in the landfill. Groundwater monitoring is required. The Department specifies the thickness and
frequency of approved material for landfill cover; typically cover is applied at least once every 2 weeks.
2.2.9 Florida
The Florida Department of Environmental Protection (FDEP) is the regulatory authority for solid waste
management. C&D debris and C&D Disposal and Recycling regulations are located within the Florida
Administrative Code, Chapter 62-701.730. Florida defines C&D debris as follows: discarded materials
generally considered to be non-water soluble and non-hazardous in nature, including but not limited to
steel, glass, brick, concrete, asphalt material, pipe, gypsum wallboard, and lumber, from the construction
or destruction of a structure as part of a construction or demolition project or from the renovation of a
structure, including such debris from construction of structures at a site remote from the construction or
demolition project site. The term includes rocks, soils, tree remains, trees, and other vegetative matter that
normally results from land clearing or land development operations for a construction project; clean
cardboard, paper, plastic, wood, and metal scraps from a construction project; yard trash and unpainted,
non-treated wood scraps from sources other than construction or demolition projects; scrap from
manufacturing facilities that is the type of material generally used in construction projects and that would
meet the definition of construction and demolition debris if it were generated as part of a construction or
demolition project, including debris from the construction of manufactured homes and scrap shingles,
wallboard, siding concrete, and similar materials from industrial or commercial facilities and de minimis
amounts of other non-hazardous wastes that are generated at construction or demolition projects, provided
such amounts are consistent with best management practices of the construction and demolition
industries. Mixing of C&D debris with other types of solid waste will cause it to be classified as other
than C&D debris.
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C&D debris can also fall under the definition of Class III waste and therefore be disposed of in a Class III
landfill that also accepts yard trash, processed tires, asbestos, carpet, cardboard, paper, glass, plastic,
furniture other than appliances, or other materials approved by the FDEP that are not expected to produce
leachate that poses a threat to public health or the environment. Materials defined as Class III waste but
are not C&D debris cannot be disposed of in a C&D debris landfill. Liner and leachate collection systems
are not required for C&D debris disposal facilities unless the FDEP determines that based upon the types
of waste received, methods for controlling the types of waste disposed of, the proximity of ground water
and surface water, and the results of the hydrogeological and geotechnical investigations that operation of
the facility is reasonably expected to result in violations of ground water standards and criteria otherwise.
However, recently promulgated rules in Florida require Class III landfills to be constructed with a liner
and leachate collection system unless the permit applicant can demonstrate that a liner and leachate
collection system are not needed. Groundwater monitoring is required at C&D debris disposal facilities
on a semiannual basis. There are no minimum operational soil cover requirements. Unless a facility's
operational plan states otherwise, the working face and internal slopes of disposal units should be no
greater than 3 ft horizontal run to 1 ft vertical rise so that fires can be controlled.
2.2.10 Georgia
The Georgia Department of Natural Resources, Environmental Protection Division is the solid waste
authority for Georgia. The Solid Waste Management rules are provided within Chapter 391-3-4.
Construction/Demolition waste in Georgia is disposed of within C&D landfills. The specific definition of
C&D waste is: waste building materials and rubble resulting from construction, remodeling, repair, and
demolition operations on pavements, houses, commercial buildings, and other structures. Such wastes
include, but are not limited to asbestos containing waste, wood, bricks, metal, concrete, wall board, paper,
cardboard, inert waste landfill material, and other non-putrescible wastes that have a low potential for
groundwater contamination.
Unless a variance is granted by the Department, liner, leachate, and daily cover requirements, as set forth
for MSWLFs, apply to C&D landfills. These provisions include a liner with leachate collection that must
ensure that the concentration values of MCLs of listed chemicals are not exceeded in the uppermost
aquifer at the relevant point of compliance. Depending on the site location, liner requirements may be
more stringent if the site is located within an area of higher pollution susceptibility or a significant
groundwater recharge area. Disposed solid waste shall be covered with 6 in. of earthen material at the end
of each operating day at a minimum, to control disease vectors, fires, odors, blowing litter, and
scavenging.
Groundwater monitoring is required at C&D landfills and the monitoring system should provide sufficient
data on the background quality of the uppermost aquifer along with the quality of groundwater passing
the relevant point of compliance specified by the Director. There are also provisions for controlling
explosive gases, which include a CFL monitoring program with quarterly monitoring and the steps to take
when CHt concentration limits are exceeded. Facilities are also to be designed to prevent and minimize
the potential for fire or explosion, and a minimum supply of 1 day of cover material must be maintained
within 200 ft of the working face for firefighting purposes unless other acceptable means have been
approved.
Georgia's regulations also have provisions for inert waste landfills, defined as disposal facilities accepting
only wastes that will not or are not likely to cause production of leachate of environmental concern. Such
wastes are limited to earth and earth-like products, concrete, cured asphalt, rock, bricks, yard trimmings,
stumps, limbs, and leaves. This definition excludes industrial and demolition waste not specifically listed
above. Inert waste landfills, because they are more restrictive in the types of materials accepted, only
require a permit-by-rule (PER). Under the PER the facility is required to have 1 ft of cover placed over
exposed waste at least monthly, and soil should be stockpiled for use against fires. Liners, leachate
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collection, and groundwater monitoring are not discussed within the regulations relating to inert waste
landfills. The Environmental Protection Division is in the process of recommending updates to the inert
rules requiring permits; the proposal is currently being reviewed by the Board of Natural Resources.
2.2.11 Hawaii
The Department of Health is the regulatory body for solid waste management facilities in Hawaii.
Regulations on solid waste management facilities, including those that accept C&D waste, are provided in
the Hawaii Administrative Rules Title 11, Chapter 58.1. C&D waste is disposed of within C&D solid
waste landfills. C&D waste includes: solid waste resulting from the construction, repair, demolition, or
razing of buildings, of roads, and other structures and includes land clearing debris from the clearing of
land for construction. C&D wastes typically consist of concrete, hollow tile, bituminous concrete,
asphaltic pavement, wood, glass, masonry, roofing, siding, and plaster, alone or in combinations.
C&D solid waste landfills are required to have a liner system with a 2-ft thick soil layer (minimum) with
a maximum permeability of 1 * 10~5 cm/sec or an approved alternative design. Leachate collection is not
specifically noted in the rules; however a leachate management plan is required. Groundwater monitoring
is required and interim cover requirements are specified. More stringent facility design and operational
requirements may be determined on a case-by-case basis.
2.2.12 Idaho
The Department of Environmental Quality and the local health districts share responsibility for regulating
solid waste facilities. C&D wastes are not specifically defined within the Idaho Administrative Code
58.01.06 Solid Waste Management Rules. Inert waste is defined as noncombustible, nonhazardous, and
non-putrescible solid wastes that are likely to retain their physical and chemical structure and have a de
minimis potential to generate leachate under expected conditions of disposal, which includes resistance to
biological attack. Inert waste includes, but is not limited to, rock, concrete, cured asphaltic concrete,
masonry block, brick, gravel, dirt, inert coal combustion byproducts, inert precipitated calcium carbonate,
and inert component mixtures of wood or mill yard debris. Inert waste is exempt from the solid waste
rules. C&D type wastes that do not fit the description of an inert waste are regulated as solid waste and
can be placed within non-MSWLFs.
Non-MSWLFs are classified in tiers and can accept different quantities and characteristics of waste. With
respect to accepting C&D waste, Tier I facilities are typically reserved for use in small (less than
200 yd3), one-time building demolition projects. Tier I facilities have minimal design and operational
requirements. The majority of C&D waste disposed in Idaho is placed within Tier II facilities. These sites
are not required to install groundwater monitoring wells, liners, or leachate collection systems. Facilities
classified by the Department as a Tier II must not accept CESQG hazardous waste, waste with high
pathogenic potential, or waste in high volumes that may form toxic leachate or gas or harm the
environment. The total disposal capacity of Tier II facilities must be greater than 2,000 yd3. C&D waste
that cannot be placed within a Tier II landfill because of prohibitive quantities or material that may
contain CESQG hazardous waste can be accepted into Tier III facilities. Tier III facilities are regulated
similarly to MSWLFs and are required to have groundwater monitoring, liners, leachate collection
systems, and air contaminant control systems.
2.2.13 Illinois
The Pollution Control Board is the rule promulgating authority, and the Illinois EPA is the enforcing
authority for solid waste in Illinois. Title 35 of the Illinois Administrative Code, Subtitle G: Waste
Disposal, Chapter I: Pollution Control Board, Subchapter i: Solid Waste Part and Special Waste Hauling
Part, acknowledges that C&D landfills do not exist in Illinois. There are numerous clean construction and
demolition debris (CCDD) fill operations that accept uncontaminated broken concrete without protruding
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metal bars, bricks, rock, stone, reclaimed asphalt pavement, or soil generated from C&D activities. These
fill operations are not recognized as disposal sites because the fill materials are considered to be used
beneficially. Subtitle J: Clean Construction or Demolition Debris, Chapter I: Pollution Control Board,
Part 1100 details the requirements for CCDD Fill Operations, which does not require liners, leachate
collection, or groundwater monitoring. A fill operation cannot be located in a setback zone of a potable
water supply well, and there should be surface water controls. Fill cannot be applied above the highest
grade permitted at the facility, and 1 ft of uncontaminated soil is to be applied at closure.
The Illinois EPA has recognized that there is the potential for CCDD fill operations to have
environmental impacts. However, the update of the regulations for CCDD fill operations (which became
effective on 27 August 2012), promulgated by the Pollution Control Board, does not require groundwater
monitoring but does include new requirements to evaluate potential waste materials to assess the potential
for groundwater impacts.
Illinois defines inert waste as any solid waste that will not decompose biologically, burn, serve as food for
vectors, form a gas, cause an odor, or form a contaminated leachate. Inert waste may include, but is not
limited to, bricks, masonry, and concrete. Although inert waste landfills have provisions written into the
regulations that address several types of C&D waste, there have not been any facilities permitted under
the inert waste landfill classification. Therefore, C&D wastes that are not suitable for a CCDD fill
operation are regulated as solid waste and are disposed of at an MSW landfill.
2.2.14 Indiana
The Indiana Department of Environmental Management, Solid Waste Management Board is the solid
waste regulating authority. Indiana Administrative Code Title 329 Articles 10 & 11 addresses C&D
debris management. Construction/demolition waste is defined as solid waste resulting from the
construction, remodeling, repair, or demolition of structures. Wastes that may be included are scrap
lumber, bricks, concrete, stone, glass, wallboard, roofing, plumbing fixtures, wiring, and non-asbestos
insulation. The following uncontaminated C&D type materials are excluded from regulation: rocks,
bricks, concrete, road demolition waste, and dirt.
Construction/demolition sites require at minimum a soil barrier with a minimum thickness of 3 ft between
the solid waste and the aquifer, and a hydraulic conductivity <1 x 10~6 cm/sec. Leachate collection and
groundwater monitoring are not required and no less than 6 in. of cover must be applied weekly.
2.2.15 Iowa
The Iowa Department of Natural Resources is the solid waste regulatory authority. C&D management is
addressed within Iowa Administrative Rules, Chapter 567-100 & 114. Construction and demolition waste
is defined as waste building materials including wood, metals and rubble (stone, brick, or similar
inorganic material) that result from construction or demolition of structures. Tree waste is included in the
definition of C&D. Although the term rubbish includes several C&D type materials such as glass and
wood, construction and demolition waste is the terminology used consistently throughout Iowa's
regulations, and construction and demolition waste disposal sites are sanitary landfills that accept only
construction and demolition wastes.
The construction and demolition waste disposal sites require both liners and leachate collection systems.
The minimum liner requirement is a soil liner consisting of at least 4 ft of re-compacted soil with a
coefficient of permeability 1 * 10~7 cm/sec or less. A composite liner system consisting of an upper
component with a minimum 30 mil flexible membrane liner (60 mil if it is high density polyethylene
[HOPE]), and a lower component consisting of at least a 2 ft layer of compacted soil with a coefficient of
permeability of 1 x 10"7 cm/sec. The leachate collection, storage, and treatment and disposal system shall
be designed to protect the soils, surface water, and groundwater from leachate contamination. This system
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shall be designed to operate during the active life of the site and during the post-closure period.
Groundwater monitoring is required, and waste shall be covered with a minimum of 1 ft of earth at least
once every 7 days of operation.
2.2.16 Kansas
The Department of Health and Environment is the regulatory authority for solid waste in Kansas. The
Kansas Administrative Regulations, Article 29 - Solid Waste Management, define C&D waste as
including bricks, concrete and other masonry materials, roofing materials, soil, rock, wood, wood
products, wall or floor coverings, plaster, drywall, plumbing fixtures, electrical wiring, electrical
components containing no hazardous materials, non-asbestos insulation, and construction-related
packaging. C&D landfills are used exclusively for the disposal of C&D wastes and do not include sites
used exclusively for the disposal of clean rubble; clean rubble and uncontaminated soil are essentially
unregulated. If a city or county has established its own C&D facility standards that are more stringent
than the state requirements, enforcement authority may be given to the local agency by the Department.
C&D landfills are not required to have a liner or leachate collection; however there are specifications for
a minimal vertical distance of 5 ft from the bottom of waste to the highest predicted groundwater level
with the separation distance to be provided by either an in-situ, geologic, or alternative material.
Additionally, C&D contact water, liquid consisting primarily of precipitation that has been in contact with
the C&D waste, including all runoff from the active area of the C&D landfill and all liquid derived from
the C&D waste, must meet control and management requirements. The operator shall apply cover
material over every 2,000 tons of waste disposed, with a minimum of 1 ft of soil to limit air intrusion and
control the risk of fire, control litter and vectors. Cover shall be applied at least once every 120 days;
however no facility shall be required to apply cover more often than once a week.
Site owners and operators must make arrangements for fire protection services if a fire protection district
or other public fire protection service is available. If there is a fire at the site, the operator must initiate
and continue the use of appropriate firefighting methods until all smoldering, smoking, and burning cease;
notify the department within 1 business day and submit a written report to the department within 1 week;
and upon completion of firefighting activities, cover and regrade each disrupted finished grade, covered
surface, or completed surface.
2.2.17 Kentucky
The Energy and Environment Cabinet, Department for Environmental Protection is the regulating
authority for solid waste in Kentucky. C/D waste is defined in Kentucky Administrative Regulations,
Title 401 Chapters 47 Solid Waste Facilities & 48 Standards for Solid Waste Facilities as waste resulting
from the construction, remodeling, repair, and demolition of structures and roads, and for the disposal of
uncontaminated solid waste consisting of vegetation resulting from land clearing and grubbing, utility line
maintenance, and seasonal and storm related cleanup. Construction material is also defined and means
nonhazardous non-soluble material, including but not limited to steel, concrete, brick, asphalt roofing
material, or lumber from a construction or demolition project. Construction/demolition debris is disposed
of within construction/demolition debris landfills, and construction materials can be disposed of within
inert landfills which also accept inert, non-soluble and non-putrescible solid waste, certain industrial or
special waste, and other waste material with specific approval from the cabinet.
C/D landfill technical requirements vary depending on the size of the facility. Landfills with an area
greater than 1 acre must have a liner system. A bottom soil liner of a minimum thickness of 1 ft with a
maximum hydraulic conductivity of 1 * 10"7 cm/sec or its equivalent is required. The liner must cover the
bottom and sidewalls of the facility. If a facility restricts the waste to C/D debris, non-putrescible wastes,
and wastes that are not likely to leach, the liner design requirement may be modified to a minimum of 2 ft
of re-compacted soil. The leachate collection system shall be capable of removing leachate from the top
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surface of the low permeability soil component, and conveying it to a collection point and meet all
specified design requirements. Groundwater monitoring is required. The owner or operator shall apply a
1 ft soil cover such that the area of exposed waste does not exceed 10,000 ft2 and all exposed wastes are
to be covered at least once each week to reduce fire hazards, prevent an unsightly appearance, and
eliminate disease vectors. A fire safety and response plan must also be developed and maintained. The
plan shall identify measures that shall reduce the risk of fire at the facility, identify the equipment and
procedures to respond to a fire, and supplement the local fire department's capabilities.
C/D debris landfills of 1 acre or less can be registered as PER facilities. Liners and leachate collection are
conditionally required, and groundwater monitoring is not required. The rules pertaining to C/D landfills
less than 1 acre in size are in the process of being updated, and potential changes include a required liner
and leachate collection and a formal engineered site plan.
2.2.18 Louisiana
The Louisiana Department of Environmental Quality is the solid waste regulating authority. Within the
Environmental Regulatory Code (Louisiana Administrative Code (LAC) Title 33) Part VII Solid Waste,
C/D debris is defined as nonhazardous waste generally considered not water-soluble that is produced in
the process of construction, remodeling, repair, renovation, or demolition of structures, including
buildings of all types (both residential and nonresidential). Solid waste not included within this definition
includes regulated asbestos-containing material as defined in LAC 33:111.5151.B, white goods, and
creosote-treated lumber. C/D debris is accepted by Type III Facilities, which are facilities used for
disposing or processing of C/D debris or wood waste, composting organic waste to produce a usable
material, or separating recyclable wastes. The following solid wastes are not subject to the permitting
requirements or processing or disposal standards of the solid waste regulations: brick, stone, reinforced
and unreinforced concrete, and asphaltic roadbeds. C/D disposal facilities are not subject to permitting if
they receive only on-site generated debris.
A liner and leachate collection system and groundwater monitoring are not specified within the
regulations for Type III facilities. However, the facility must be located in an area with natural or
designed soils of low permeability to protect groundwater. Wastes shall be covered with silty clays
applied in a layer a minimum of 1 ft thick, and all wastes shall be covered within 30 days of disposal.
2.2.19 Maine
The Maine Department of Environmental Protection Bureau of Remediation and Waste Management is
the state regulating authority for solid waste. The Maine Solid Waste Management Rules Chapters 400,
401, 405, 409 are applicable to C&D waste management. C/D debris is defined as solid waste resulting
from construction, remodeling, repair, and demolition of structures. It includes but is not limited to:
building materials, discarded furniture, asphalt, wall board, pipes, and metal conduits. It excludes partially
filled containers of glues, tars, solvents, resins, paints, or caulking compounds; friable asbestos; and other
special wastes. Inert fill is also defined within the rules as clean soil material, rock, bricks, crushed clean
glass or porcelain, and cured concrete. Inert waste is exempt from the requirements set forth within the
Solid Waste Management rules.
C/D debris landfills less than 6 acres in size and qualifying under Section 7 of Chapter 401 are not
required to have a bottom liner system. A leachate management system may be required if site natural
soils do not allow adequate leachate infiltration. The active area within the solid waste boundary must be
covered with soil material or other approved cover so that no more than 0.5 acres remains uncovered at
any time. Groundwater monitoring is not required but surface water quality monitoring is required.
For other C/D debris landfills not qualifying for licensing under Section 7 of Chapter 401, a liner and
leachate collection system is required. The liner must be a composite consisting of a geomembrane and a
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barrier soil layer. The geomembrane must have a nominal thickness of 60 mil. The barrier soil layer must
consist of a minimum of 2 ft of re-compacted clay or well graded till containing a minimum of 35 %
fines. A geosynthetic clay liner (GCL) may substitute for up to 1 ft of the barrier soil layer component of
the liner system. Each liner system component must have a hydraulic conductivity <1 * 10~7 cm/sec. A
leachate collection system must be incorporated in the design above the liner system, and a leak detection
system and leachate storage system are required as well. Groundwater monitoring is required, and
facilities must also monitor gas collection or venting systems and have a quarterly CEU gas monitoring
program to verify the concentration of explosive gases generated by the landfill. The gas management
rules are in the process of being updated. Daily cover is not required, however, depending on the types of
materials accepted by a facility, application of cover material may be required or recommended in a
facility's permit.
Fire protection is described similarly for small (<6 acres) and larger C/D debris landfills. The
requirements are to arrange with a nearby fire department to provide emergency service, possess
sufficient on-site equipment for minor fires, to maintain a soil stockpile sufficient to suppress small fires,
and to observe the current applicable rules of the State of Maine Bureau of Forestry, Department of
Conservation.
2.2.20 Maryland
The Department of the Environment is the regulating authority for solid waste in Maryland. The Code of
Maryland Regulations Title 26 Department of Environment, Subtitle 04 Regulation of Waste Supply,
Sewage Disposal and Solid Waste, addresses C&D waste. Maryland has various types of sanitary landfills
that are regulated. Rubble landfills are one such type of sanitary landfill that accepts C&D wastes. In
general, the types of materials accepted at rubble landfills are land clearing debris, demolition debris,
construction debris, tires, asbestos, household appliances and white goods, processed debris, and other
materials. Acceptable demolition debris may include debris associated with the razing of buildings, roads,
bridges, and other structures includes structural steel, concrete, bricks (excluding refractory type), lumber,
plaster and plasterboard, insulation material, cement, shingles and roofing material, floor and wall tile,
asphalt, pipes and wires, and other items physically attached to the structure, including appliances if they
have been or will be compacted to their smallest practical volume. Acceptable construction debris may
include structural building materials including cement, concrete, bricks (excluding refractory type),
lumber, plaster and plasterboard, insulation, shingles, floor, wall and ceiling tile, pipes, glass, wires,
carpet, wallpaper, roofing, felt, or other structural fabrics. Paper or cardboard packaging, spacing, or
building materials, provided that they do not exceed 10% by volume of the waste, may be accepted at
rubble landfills. Paint containers, caulk containers, or glaze containers may be acceptable, provided that
they are empty and any residual material is dried before acceptance at the rubble fill, and further provided
that this waste category does not exceed 1% by volume of the waste accepted at the rubble landfill.
County governments can specify in their 10-year solid waste master plans what a rubble landfill within
their jurisdiction can accept. When permitting is developed by the state for a facility, the applicant's
requests, what the County allows, and the state's assessment of the facility's design ability and meeting
standards determines the specific waste materials that can be accepted into rubble landfills in Maryland.
A bottom liner, leachate system, and groundwater monitoring are required. The liner may be constructed
of natural earthen materials excavated from the site or imported from another location, or it may be
constructed of a synthetic or manufactured membrane material. The liner must be constructed with a
minimum thickness of 1 ft of clay or other natural material having an in-place permeability
<1 x 10"7 cm/sec, or one or more unreinforced synthetic membranes with a combined minimum thickness
of 50 mil or a single reinforced synthetic membrane with a minimum thickness of 30 mil which has a
permeability <1 * 10"10 cm/sec. The liner shall be installed over a subbase with a minimum thickness of
2 ft and having a permeability <1 x 10"5 cm/sec. Although clay liners may meet state requirements, in
practice all active rubble fills employ geomembranes as the bottom liner material. An engineered leachate
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collection and removal system must be designed, constructed, operated, and maintained to collect and
remove leachate from the landfill and operated to ensure that the depth of leachate over the liner does not
exceed 1 ft. At least every 3 days, 6 in. of clean earth shall be placed over all exposed rubble waste. There
are no specific provisions for fire prevention and control in the rules.
2.2.21 Massachusetts
Massachusetts Department of Environmental Protection is the regulating authority for solid waste. The
310 Code of Massachusetts Regulations 16.00 and 19.000 Solid Waste Management discusses solid waste
management rules. Within these rules, C&D waste is defined as the waste building materials and rubble
resulting from the construction, remodeling, repair or demolition of buildings, pavements, roads or other
structures. C&D waste includes, but is not limited to, concrete, bricks, lumber, masonry, road paving
materials, rebar and plaster. The state currently has a disposal ban for many materials that fall within the
definition of C&D debris (asphalt pavement, brick, concrete, metal, wood, and clean gypsum wallboard),
therefore these materials are first processed at a recycling facility before they can be disposed. At present
there are no active C&D only disposal sites. Closed facilities may have liners and leachate collection,
depending on when the facilities were constructed; groundwater monitoring is required.
There are regulations for C&D waste processing facilities including requiring handling to occur indoors,
appropriate materials to be stored and covered on an impervious surface, and any water that comes in
contact with the recyclable materials to be properly handled.
2.2.22 Michigan
The Resource Management Division of the Department of Environmental Quality is the solid waste
regulating authority in Michigan. The Waste and Hazardous Materials Division Part 115 regulations
define C&D waste as waste building materials, packaging, and rubble that results from construction,
remodeling, repair, and demolition operations on houses, commercial or industrial buildings, and other
structures. C&D waste includes trees and stumps that are more than 4 ft in length and 2 in. in diameter
and that are removed from property during construction, maintenance, or repair.
C&D waste landfills are classified as Type III Sanitary landfills. Type III Landfills require a liner
composed of either a natural soil barrier with a maximum hydraulic conductivity of 1.0 x 10"7 cm/sec, a
compacted soil liner with a minimum thickness of 3 ft, a composite liner, or a flexible membrane liner
which is not less than 30 mil thick if the liner is installed on stable soil that is not less than 4-ft thick and
has a hydraulic conductivity <1 .Ox 10"5 cm/sec. Other liner materials, modified soils, or technologically
advanced liner systems may be approved. Type III landfills that have a liner shall have a permanent
minimum clearance of 4 ft from the top of the liner to the groundwater table. Leachate collection systems
for Type III landfills shall be designed, constructed, and operated to limit the head at the lowest point in
the system to not more than 1 ft. Leachate that is removed shall either be reintroduced into the landfill or
shall be conveyed to a wastewater treatment facility that is capable of treating the leachate to meet
appropriate discharge standards.
Groundwater monitoring through a minimum of quarterly analyses of the monitoring wells is required
during the landfill's operation. Following the closure of the landfill, semiannual sampling and reporting
are required during the 30-year post-closure period. If groundwater cannot be monitored, then a site shall
have a leachate leak detection system. A suitable cover material shall be placed on all exposed solid waste
at a Type III landfill by the end of each working day to prevent fugitive dust, blowing litter, and other
nuisances.
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2.2.23 Minnesota
The Minnesota Pollution Control Agency (MCPA) is the solid waste regulating authority. Solid waste
rules are within the Minnesota Administrative Rules Chapter 7035 and specifically Demolition Land
Disposal Facilities are addressed within 7035.2825. Demolition debris is defined as solid waste resulting
from the demolition of buildings, roads, and other structures including concrete, brick, bituminous
concrete, untreated wood, masonry, glass, trees, rock, and plastic building parts. Demolition debris does
not include asbestos wastes.
Demolition debris is disposed of within demolition debris landfills, which can be granted PER status or
be required to obtain a permit. PER facilities cannot be located in an area where the bottom layer of waste
is less than 5 ft from the water table, they may be in operation for only one year, and they cannot accept
more than 15,000 yd3 (compacted) of waste. The cost of permitting a facility is often prohibitive for many
of the small county sites. The PER option allows the state to loosely observe these sites through a
notification process to deter negligence and illegal dumping without undue financial burden on smaller
counties. Plans to update PER provisions have been discussed.
Regulatory language states that both PER facilities and permitted facilities must provide monthly cover of
waste at a minimum, but do not require liners, leachate collection, or groundwater monitoring. In 2003 the
state conducted an evaluation of limited groundwater monitoring data from demolition landfills and
recognized that some facilities were impacting groundwater quality. As a result of this study, a
Demolition Landfill Guidance document was created to improve how demolition landfills are managed by
the solid waste management rules. The document more narrowly classifies demolition landfills and
identifies additional management and monitoring that should be required for each class. This document is
used in the permitting process for facilities, and therefore such requirements are written into a facility's
permit.
From the guidance document, Class I demolition landfills can only accept a specific list of C&D
materials. The need for groundwater monitoring is determined by using a matrix that compares depth to
groundwater and soil types underneath the waste. Class I facilities normally do not require liners. Class II
facilities accept a few additional waste items (incidental non-recyclable packaging consisting of paper,
cardboard and plastic, and limited demo-like industrial waste) in addition to Class I waste materials.
Groundwater monitoring is required for Class II demolition landfills; to determine if a liner is required, a
liner matrix, similar to the groundwater matrix, compares depth to groundwater and the soil type
underneath the waste. Class III demolition landfills may accept all C&D wastes and most industrial
wastes. Groundwater monitoring and a liner are both required for Class III sites. The state collects
demolition landfill groundwater data. Each demolition landfill facility submits an annual report in which
any detection above intervention limits (ILs) (1/4 of applicable MCL or SMCL) are noted and corrective
actions are proposed, as applicable.
2.2.24 Mississippi
The Mississippi Department of Environmental Quality is the solid waste regulating authority. The
Mississippi Commission on Environmental Quality Regulation SW-2: Nonhazardous Solid Waste
Management Regulations & Criteria describes C&D type waste materials as components within industrial
solid waste and rubbish waste. The final disposal destination of industrial waste is not described beyond
disposal within a municipal landfill; however, rubbish waste is disposed of at rubbish sites. Class I
rubbish sites can receive wastes including C&D debris, such as wood and metal, and also brick, mortar,
concrete, stone, and asphalt, cardboard boxes, natural vegetation, such as tree limbs, stumps, and leaves,
appliances (other than refrigerators and air conditioners) that have had the motor removed, furniture,
plastic, glass, crockery, and metal, except containers, sawdust, wood shavings, and wood chips, and other
similar wastes specifically approved by the Department. Class II rubbish sites receive mostly natural
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vegetation, such as tree limbs, stumps, and leaves. Materials such as brick, mortar, concrete, stone, and
asphalt and other similar rubbish materials can also be accepted.
Class I rubbish sites must have a liner which is comprised of naturally occurring geological materials (or
a constructed alternative) underneath the disposal area (5 ft thick) and on all sidewalls (extending 3 ft
laterally). The liner material should consist of clays, silty clays, clayey silts, or other soils that are of low
permeability. There must also be an additional 5 ft of material underneath the liner so that the minimum
distance from the bottom of the waste to the groundwater table is 10 ft. Leachate collection is not required
primarily because any runoff from the site should be controlled by stormwater drainage, and the rubbish
materials disposed are expected to have low solubility.
Class II rubbish sites do not require a liner or leachate collection system, although permit approval may
be contingent on installation of a liner. Groundwater monitoring is not required for either Class I or II
rubbish sites and at a minimum, 6 in of earthen cover material is required to be placed on waste at either
type of site, every 2 weeks. Both types of facilities have provisions addressing fire prevention and
protection including having an adequate supply of water under pressure at the site or an adequate
stockpile of earthen material reasonably close to the disposal area, or a nearby, organized fire department
providing service when called. When an accidental fire occurs, action is to be taken to extinguish the fire,
and the Department should be notified.
2.2.25 Missouri
The Department of Natural Resources is the solid waste regulating authority. Within the Code of State
Regulations, Division 80 Solid Waste Management, the disposal requirements for demolition waste are
described. The definition of C&D waste includes waste materials from the construction and demolition of
residential, industrial, or commercial structures. Clean fill that is not considered to be C&D waste is
defined as uncontaminated soil, rock, sand, gravel, concrete, asphaltic concrete, cinderblocks, brick,
minimal amounts of wood and metal, and approved inert solids. These materials are typically used for fill,
reclamation, or other beneficial uses. Demolition landfills are solid waste disposal areas used for the
controlled disposal of demolition wastes; construction waste; brush; wood wastes; cut, chipped, or
shredded tires as defined in 10 CSR 80-8; soil; rock; and concrete and inert solids insoluble in water. The
demolition wastes are not to contain more than a minor amount of metals.
Demolition landfills have regulatory provisions for a liner, leachate collection, gas control, groundwater
monitoring, daily cover, and fire prevention and control. For the liner system, the bottom liner is required
to be composed of at least 2 ft of compacted soil with a hydraulic conductivity of no more than
1 x 10"7 cm/sec and the upper liner a 30-mil thick geomembrane (60 mil if HOPE is used). Leachate
collection should maintain no more than 1 ft of leachate on the liner at one time and should have an
incorporated recirculation system. Groundwater monitoring wells, at least one upgradient and three
downgradient are required. Decomposition gases should be controlled by flaring or ventilation onsite to
prevent the endangerment of public health or the environment. A QrU control plan is required; if levels of
CH4 are detected above threshold levels, the facility must notify the Department and take actions to
protect public health and safety. At least 1 ft of cover must be placed on disposed waste once every
7 days. Fire prevention and control methods include maintaining fire extinguishers on all solid waste
handling equipment, extinguishing any fires occurring on the working face, and providing adequate
communication for emergency situations.
2.2.26 Montana
Solid waste in Montana is regulated by the Montana Department of Environmental Quality (MDEQ).
C&D waste is defined by MDEQ as the waste building materials, packaging, and rubble resulting from
construction, remodeling, repair, and demolition operations on pavements, houses, commercial buildings,
and other structures, once municipal, household, commercial, and industrial wastes have been removed. It
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is further defined as a Group IV waste, which includes C&D wastes and asphalt, and is disposed of in
Class IV landfills. The regulations regarding Class IV waste and landfills are found in Chapter 50, Solid
Waste Management of the Administrative Rules of the State of Montana Title 17.
Liners for Class IV landfills are conditionally required. Facility designs must ensure that specific MCL
concentrations of parameters in the groundwater will not be exceeded. Meeting this requirement is
determined by the location of the site, with MDEQ considering the hydrogeologic characteristics of the
site location and surrounding lands, climatic factors of the area, and volume and chemical characteristics
of the leachate by a point of compliance no more than 150m (492 ft) away from the waste management
boundary. If the MCLs are expected to be exceeded, a composite liner as well as a leachate collection and
removal system designed to maintain less than a 30-cm (-12 in) depth of leachate over the liner is
required. A liner is not required for a Class IV landfill located within the groundwater monitoring
network of a Class II (MSW) landfill. Groundwater monitoring is required for Class IV landfills. An
approved cover is required to be applied at a minimum of every 3 months to minimize litter, odor, and
leachate. Explosive gas controls required for Class II landfills regarding CH* shall also be implemented at
Class IV facilities.
2.2.27 Nebraska
Nebraska's Solid Waste Management program is regulated by the Nebraska Department of
Environmental Quality (NDEQ). C&D waste is defined by NDEQ as waste which results from
construction projects, land clearing, the demolition of buildings, roads or other structures, including, but
not limited to, fill materials, wood (including painted and treated wood), land clearing debris other than
yard waste, wall coverings (including wall paper, paneling, and tile), drywall, plaster, non-asbestos
insulation, roofing shingles and other roof coverings, plumbing fixtures, glass, plastic, carpeting,
electrical wiring, pipe, and metals. Excluded from the definition of C&D Waste are friable asbestos
waste, special waste, liquid waste, hazardous waste and waste that contains polychlorinated biphenyl
(PCB), putrescible waste, household waste, industrial solid waste, corrugated cardboard, appliances, tires,
drums, and fuel tanks. C&D waste can only be disposed of in C&D waste disposal areas, regulated under
Title 132 Integrated Solid Waste Management Rules, Chapter 5.
Nebraska has no requirements for bottom liners, leachate collection, or groundwater monitoring in C&D
waste disposal areas. However, a 10 ft vertical distance between the lowest point of the waste and the
maximum water table elevation must be maintained. Periodic cover is required in order to adequately
control litter, fires, and disease vectors. Permits for C&D landfills are issued by NDEQ for 5-year terms,
and can be renewed again after application for renewal.
2.2.28 Nevada
Nevada's solid waste is regulated by the Nevada Division of Environmental Protection. C&D waste falls
under the categories of "rubbish" and "industrial solid waste," which are disposed of in Class III landfills
as regulated in the Nevada Administrative Code Chapter 444 Sections 570-7499. Industrial waste defined
includes specifically construction, refurbishing or demolition waste from buildings or other structures.
Rubbish is defined as non-putrescible solid waste, consisting of both combustible and noncombustible
wastes such as paper, cardboard, abandoned automobiles, tin cans, wood, glass, bedding, crockery, and
similar materials.
Class III landfills do not require bottom liners or leachate collection systems; however, it is recognized
that waters of the state must be protected from degradation by pollutants or contaminants. Therefore,
groundwater monitoring is required, with the need for a system capable of monitoring the unsaturated
zone or groundwater depending on local conditions. However, due to the arid climate in Nevada, many
facilities can obtain an exemption from requirements to monitor groundwater. Daily inspection and cover
are required for litter control.
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2.2.29 New Hampshire
New Hampshire's solid waste is regulated by the Department of Environmental Services, Waste
Management Division. C&D debris and inert construction and demolition debris are defined and
regulated by the New Hampshire Code of Administrative Rules Chapter Env-Sw 800: Landfill
Requirements. C&D debris is defined as non-putrescible waste building materials and rubble that is solid
waste resulting from the construction, remodeling, repair, or demolition of structures or roads. The term
includes, but is not limited to, bricks, concrete and other masonry materials, wood, wall coverings,
plaster, dry wall, plumbing, fixtures, non-asbestos insulation or roofing shingles, asphaltic pavement, and
glass. Inert C&D debris means C&D debris that is comprised of materials that do not degrade, combust,
or generate leachate. C&D wastes are disposed of in construction/demolition debris (C&D) landfills.
C&D landfills are required to be single-lined (either a 60-mil geomembrane or a 3 ft thick compacted soil
liner) facilities, and can be required to be double-lined if the characteristics of the waste pose a threat to
groundwater quality. However, landfills that only receive inert C&D debris or stumps and brush can be
designed as unlined landfills. A leachate collection and removal system is also required for C&D
landfills, as well as groundwater monitoring at all landfills.
2.2.30 New Jersey
The New Jersey Department of Environmental Protection Solid and Hazardous Waste Program regulates
solid waste in New Jersey. C&D waste (Type 13C) is defined as waste building material and rubble
resulting from construction, remodeling, repair, and demolition operations on houses, commercial
buildings, pavements, and other structures. This includes wastes such as treated and untreated wood scrap,
tree parts, tree stumps and brush, concrete, asphalt, bricks, blocks and other masonry, plaster and
wallboard, roofing materials, corrugated cardboard and miscellaneous paper, ferrous and non-ferrous
metal, plastic scrap, dirt, carpets and padding; glass (window and door), non-asbestos building insulation,
and other miscellaneous materials. Bulky waste (Type 13) is also defined as including items such as tree
trunks, auto bodies, demolition or construction materials, appliances, furniture, and drums. These wastes
are to be disposed of in Class III sanitary landfills, which accept inert waste of types 13 and 23
(vegetative waste), as dictated by Title 7: Environmental Protection of the New Jersey Administrative
Code Chapter 26: Solid Waste, Subchapter2: Disposal.
A composite liner system consisting of a geomembrane liner with a 2 ft layer of compacted clay, or
equivalent, and hydraulic conductivity <1 x 10"7 cm/sec at a minimum is required at the landfills, as well as
a leachate collection system. Groundwater monitoring is also required at the landfills, as well as gas
venting systems. Adequate water supply and fire-fighting equipment are to be maintained at the facility or
be readily available. Areas where waste has been deposited shall be covered daily. Type 13 and 13C
wastes can also be disposed of at Class IMSWLF facilities.
Although landfills are identified for C&D material waste disposal, the majority of this waste type in New
Jersey is intended for recovery at transfer stations and material recovery facilities (TS/MRFs). At the
TS/MRFs, the waste is sorted manually or by mechanical systems to extract recyclables. The small
residuals from the sorting process can either be disposed of or applied as landfill cover, provided that it
satisfies chemical and physical performance criteria as cover materials and it is approved for use by the
Department of Environmental Protection. These transfer stations are common in the central and northern
part of the state, where landfills rarely receive C&D. In the southern part of New Jersey, most C&D Type
13 and 13C waste is disposed of in Class I MSWLFs that are equipped to receive these wastes in specific
cells. There is one Type II landfill that receives C&D and bulky waste, in addition to Type 27 dry
industrial waste.
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2.2.31 New Mexico
The New Mexico Environment Department Solid Waste Bureau regulates solid waste in New Mexico.
Construction and demolition waste is disposed of in a Construction and Demolition Landfill, which is a
landfill that receives only C&D debris in quantities equal to or less than 50 tpd on a monthly average.
Any landfill that receives more than 50 tpd monthly average of C&D debris waste in any month is defined
as a municipal landfill, as defined by 20.9 New Mexico Administrative Code (NMAC). C&D debris is
also disposed with MSW in municipal landfills.
Bottom liners are not required for C&D landfills. Groundwater monitoring for C&D landfills is not
required unless there is the potential for constituents to migrate to the uppermost aquifer. In an effort to
control vectors and reduce the risk of fire, soil cover should be applied and compacted at the end of each
operating day. The generation and migration of CFL must be prevented so that the concentration of CFL
generated by the facility does not exceed 25% of the lower explosive limit (LEL) for CFL in facility
structures or 100% of the LEL at the property boundary. As a matter of reviewing and proposing permit
applications for approval, it is likely that the Solid Waste Bureau would require CFL monitoring at C&D
landfills in the future to ensure that they are compliant with the requirements of 20.9.5.10.C NMAC.
2.2.32 New York
The New York State Department of Environmental Conservation regulates solid waste and specifically
C&D debris landfills in the State of New York, as specified in 360-7 of Chapter 4: Quality Services,
except for C&D debris landfills located on Long Island (Nassau and Suffolk Counties), which are
regulated under 360-8. C&D debris is defined as uncontaminated solid waste resulting from the
construction, remodeling, repair, and demolition of utilities, structures and roads; and uncontaminated
solid waste resulting from land clearing. Such waste includes, but is not limited to bricks, concrete and
other masonry materials, soil, rock, wood (including painted, treated and coated wood and wood
products), land clearing debris, wall coverings, plaster, drywall, plumbing fixtures, non-asbestos
insulation, roofing shingles and other roof coverings, asphaltic pavement, glass, plastics that are not
sealed in a manner that conceals other wastes, empty buckets 10 gal or less in size and having no more
than 1 in. of residue remaining on the bottom, electrical wiring and components containing no hazardous
liquids, pipe, and metals that are incidental to any of the above. Land clearing debris is vegetative matter,
soil, and rock resulting from activities such as land clearing and grubbing, utility line maintenance or
seasonal or storm-related cleanup such as trees, stumps, brush and leaves and including wood chips
generated from these materials.
C&D debris can be disposed of in exempt, registered, or permitted C&D debris landfills. Exempt C&D
debris landfills may accept only asphalt pavement, brick, glass, soil, and rock, and are exempt from
permitting. Registered C&D debris landfills are land clearing debris landfills of 3 acres or less, which
may also accept recognizable, uncontaminated concrete, concrete products, asphalt pavement, brick,
glass, soil, and rock. Exempt and registered C&D debris landfills do not require liners, leachate collection
systems, or groundwater monitoring.
The remaining C&D debris is disposed of in permitted C&D debris landfills, which are further divided
into landfills 3 acres or less and landfills larger than 3 acres. Liners are required for both types of
permitted facilities; landfills 3 acres or less require a base liner of 2 ft of soil with a hydraulic
conductivity of IxlO"5 cm/sec. C&D debris landfills greater than 3 acres require a single composite liner,
comprised of a 60 mil geomembrane over a 24 in compacted soil layer, with a hydraulic conductivity
<1*10~7 cm/sec.
All permitted C&D debris landfills require a 5 ft buffer between the base of the liner and the seasonal
high groundwater table, as well as a 10 ft buffer between the base of the liner and bedrock. For C&D
debris landfills 3 acres or less in size that accept no more than 200 tons per week and no pulverized C&D
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debris, leachate collection is not required, and groundwater monitoring is conditional, based on the size
and expected life of the facility, as well as its distance to potential groundwater users. For C&D debris
landfills greater than 3 acres in size, leachate collection is required, with a maximum of 1 ft of head on the
liner, as well as groundwater monitoring. Cover must be applied to control odors, fire hazards, vectors,
and litter. Gas venting systems are necessary for all C&D debris landfills greater than 3 acres upon
closure and may be required for those less than or equal to 3 acres in size.
2.2.33 North Carolina
The North Carolina Department of Environment and Natural Resources, Division of Waste Management
regulates solid waste, specifically C&D waste, under 15A North Carolina Administrative Code
13B .0532-.0547. C&D solid waste is defined as solid waste generated solely from the construction,
remodeling, repair, or demolition operations on pavement and buildings or structures. C&D waste does
not include municipal or industrial wastes that may be generated by the ongoing operations at buildings or
structures. This waste is disposed of in C&D solid waste landfills (C&DLF). Following the passing of the
Solid Waste Management Act of 2007, new C&D landfills are required to have a liner and leachate
collection system per the statute. Landfills in existence prior to August 1, 2006, are not subject to the liner
requirement. This condition has not yet been reflected in the rules. A groundwater monitoring system is
required, and must consist of wells to represent the quality of background groundwater as well as
groundwater passing relevant points of compliance and downgradient wells. Open burning at a C&DLF is
prohibited, and equipment must be provided at the facility to control accidental fires as well as
arrangements made with the local fire protection agency to immediately provide services when needed.
Cover requirements of 6 in. of earthen material applied at least weekly or when the waste disposal area
exceeds one half acre are in place to control disease vectors, fires, odors, blowing litter, and scavenging.
2.2.34 North Dakota
In North Dakota, solid waste is regulated by the North Dakota Department of Health, Division of Waste
Management. Inert waste is also regulated, which is defined as non-putrescible solid waste that will not
generally contaminate water or form a contaminated leachate, and includes but is not limited to: C&D
material such as metal, wood, bricks, masonry and cement concrete; asphalt concrete; metal; tree
branches; bottom ash from coal fired boilers; and waste coal fines from air pollution control equipment.
Because C&D waste falls under this definition, it is disposed of in inert waste landfills as regulated by the
North Dakota Administrative Code 33-20-05.
There are no liner or leachate collection requirements for inert waste landfills due to the clayey nature of
soils in North Dakota; however, there are location restrictions based on other geophysical conditions of
the site. Groundwater monitoring is also not required for inert waste landfills in North Dakota. Cover of
6 in. of earthen material is required at a minimum of two times per year. Final cover requirements are at
least 2 ft of final soil cover, including 6 in. of topsoil.
2.2.35 Ohio
The Ohio Environmental Protection Agency (OEPA) Division of Materials and Waste Management
(DMWM) regulates construction and demolition debris (C&DD) in Ohio, under Ohio Administrative
Code (OAC) Chapter 3745-400. C&DD refers to those materials resulting from the alteration,
construction, destruction, rehabilitation, or repair of any manmade physical structure, including, without
limitation, houses, buildings, industrial or commercial facilities, or roadways. This includes materials
such as brick, concrete and other masonry materials, stone, glass, wall coverings, plaster, drywall,
framing and finishing lumber, roofing materials, plumbing fixtures, heating equipment, electrical wiring
and components containing no hazardous fluids or refrigerants, insulation, wall-to-wall carpeting,
asphaltic substances, metals incidental to any of the above, and weathered railroad ties and utility poles.
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This waste is disposed of in C&DD landfills or may go to MSWLFs, especially in areas that do not have
access to a C&DD facility.
Areas of C&DD landfills constructed after 1996 are required to have liners, whether in the form of in-situ
materials that have a minimum thickness of 5 ft and maximum permeability of 1 x 10~5 cm/sec or a
maximum permeability equivalent to two feet of soil of 1 x 10~6 cm/sec, or the required re-compacted soil
liner of thickness 24 in. built in 8 in. lifts and a maximum permeability of 1 x 10~6 cm/sec for each lift.
Leachate collection systems are required for both in-situ and constructed liner systems, and shall be
designed to maintain less than 1 ft of head on the liner. Liners and groundwater monitoring are required at
C&DD landfills in Ohio, unless it meets all the requirements in paragraph (A) of rule 3745-400-10 of the
Administrative Code, based on the location of the C&DD landfill to the nearest aquifer and water supply
system and the permeability of the materials in between. Fire protection for C&DD landfills is taken into
account by applying cover to all disposed debris on a weekly basis with soil, clean hard fill, or any other
noncombustible material. Fire control equipment is also necessary at or near the facility.
OEPA has had a focus on C&DD landfill properties as a result of growing concerns about impacts from
C&DD landfills. Further discussion of the examinations conducted by OEPA on leachate quality and
groundwater impacts from C&DD landfills is presented in Section 3 of this report. Recent regulation
changes that were promulgated on August 1, 2012, established new rules for C&DD landfills, including a
5-year post-closure care period, financial assurance for post-closure and closure care, and leachate
sampling requirements.
2.2.36 Oklahoma
The Oklahoma Department of Environmental Quality regulates solid waste through the Oklahoma
Administrative Code Title 252 Chapter 515 Management of Solid Waste. C/D waste is defined as waste
composed of asbestos-free waste from construction and/or demolition projects that may include such
materials as metal, concrete, brick, asphalt, glass, roofing materials, limited amounts of packing materials,
sheetrock, or lumber; wood waste that may include such materials as yard waste, lumber, wood chips,
wood shavings, sawdust, plywood, tree limbs, or tree stumps; yard waste that may include such materials
as grass clippings, tree limbs, tree stumps, shrubbery, flowers, or other vegetative matter resulting from
land clearing or landscaping operations; or residential lead-based paint waste. This waste is disposed of in
C&D landfills.
C&D landfills are required to have an in-situ liner or a reconstructed clay liner. The in-situ liner must
have a minimum separation of 15 ft from waste to the highest groundwater elevation, and be 5-ft thick
with a maximum hydraulic conductivity of 1 x 10~5 cm/sec. Otherwise, a reconstructed clay liner of at least
3 ft in thickness is required with a hydraulic conductivity of maximum 1 x 10"5 cm/sec. C&D Landfills are
not subject to leachate collection requirements. Groundwater monitoring is required for all C&D
Landfills, for the parameters of pH, chemical oxygen demand (COD), and conductivity. Cover shall be
applied weekly for the control of disease vectors, fires, odors, litter, and scavenging. Gas monitoring by
use of probes is required at C&D landfills.
2.2.37 Oregon
In Oregon, solid waste is regulated by the Oregon Department of Environmental Quality. C&D waste is
defined in Oregon rules as solid waste resulting from the construction, repair, or demolition of buildings,
roads and other structures, and debris from the clearing of land, but does not include clean fill when
separated from other C&D wastes and used as fill materials or otherwise land disposed. Such waste
typically consists of materials including concrete, bricks, bituminous concrete, asphalt paving, untreated
or chemically treated wood, glass, masonry, roofing, siding, plaster; and soils, rock, stumps, boulders,
brush and other similar material. This term does not include industrial solid waste and MSW generated in
residential or commercial activities associated with construction and demolition activities.
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C&D landfills are landfills that receive only C&D waste. There are relatively few C&D landfills in
Oregon, and most of the C&D waste disposed goes to MSW landfills. C&D landfills are regulated under
Oregon Administrative Rules Chapter 340 Division 95: Land Disposal other than MSWLFs. Inert waste is
defined as waste containing only constituents that are biologically and chemically inactive and that, when
exposed to biodegradation and/or leaching, will not adversely impact the waters of the state or public
health.
Liner and leachate collection systems at C&D landfills are conditionally required - determining factors
include the site's size, incoming waste amount, or geophysical conditions. Groundwater monitoring is
also conditional and can be dependent on whether a landfill's location and geophysical condition indicate
that there is a reasonable probability of potential adverse effects on public health or the environment. If
so, the Department may require the permittee to provide monitoring wells at Department-approved
locations and depths to determine the effects of the non-municipal land disposal site on groundwater. Gas
controls must be in place so that CH* at the landfill does not exceed 25% of its LEL in facility structures,
or at the property boundary and that malodorous decomposition gases do not become a public nuisance.
Cover must be placed in layers of at least 6 in. at intervals specified in a site's permit, and arrangements
with the local fire protection agency and on-site fire-fighting methods must also be demonstrated.
2.2.38 Pennsylvania
Solid waste in Pennsylvania is regulated by the Pennsylvania Department of Environmental Protection.
As described by the Pennsylvania Code Title 25, Chapter 277, C/D waste is defined as solid waste
resulting from the construction or demolition of buildings and other structures, including, but not limited
to, wood, plaster, metals, asphaltic substances, bricks, block and unsegregated concrete. The term C/D
waste does not apply to uncontaminated soil, rock, stone, gravel, brick and block, concrete and used
asphalt, and waste from land clearing if they are separate from other waste and are used as clean fill.
C/D waste is disposed of in C/D landfills.
C/D landfills are required to have a liner system with a subbase, leachate detection zone, a liner that is a
continuous layer of remolded clay or synthetic material liner, a protective cover and leachate collection
zone that is a prepared layer placed over the liner in which a leachate collection system is located. The
leachate collection system, among other requirements, shall ensure that there is a maximum of 1 ft of
head on the liner. Groundwater monitoring is also a requirement for C/D Landfills, which entails
measuring groundwater quality upgradient, beneath, and downgradient of the C/D waste disposal area.
Cover is to be placed on lifts of 50 ft horizontally or on a weekly basis, whichever occurs first. The cover
material should be capable of controlling fires and stabilizing the area. If the cover is soil-like, a
minimum of 12 in. shall be applied, and a 2 week supply shall be maintained on site. If the waste disposed
of generates or is likely to generate gas, the operator shall then implement gas control and monitoring.
2.2.39 Rhode Island
Solid waste in Rhode Island is regulated by the Department of Environmental Management, Office of
Waste Management. C&D debris is defined as non-hazardous solid waste resulting from the construction,
remodeling, repair, and demolition of utilities and structures; and uncontaminated solid waste resulting
from land clearing. Such waste includes, but is not limited to, wood (including painted, treated and coated
wood and wood products), land clearing debris, wall coverings, plaster, drywall, plumbing fixtures, non-
asbestos insulation, roofing shingles and other roofing coverings, glass, plastics that are not sealed in a
manner that conceals other wastes, empty buckets ten gallons or less in size and having no more than 1 in.
of residue remaining on the bottom, electrical wiring and components containing no hazardous liquids,
and pipe and metals that are incidental to any of the above. Solid waste that is not C&D debris (even if
resulting from the construction, remodeling, repair, and demolition of utilities, structures, and roads and
land clearing) includes, but is not limited to, asbestos waste, garbage, corrugated container board,
electrical fixtures containing hazardous liquids such as fluorescent light ballasts or transformers,
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fluorescent lights, carpeting, furniture, appliances, tires, drums, containers greater than ten gallons in size,
any containers having more than 1 in. of residue remaining on the bottom, and fuel tanks. Also excluded
from the definition of C&D debris is solid waste resulting from any processing technique that renders
individual waste components unrecognizable, such as pulverizing or shredding, at a facility that processes
C&D debris.
C&D debris that is disposed of in Rhode Island is placed in MSWLFs, otherwise the C&D debris is
handled by C&D debris processing facilities, which are regulated by Solid Waste Regulation No. 7:
Facilities that Process Construction and Demolition Debris. Facilities that receive less than 50 tpd of
C&D debris are exempt from the requirement to obtain a solid waste management facility license; instead,
they must go through a registration process and comply with all other applicable requirements and
regulations. Groundwater monitoring is conditional at C&D debris processing facilities, and may be
required by the Department based on size, type, and location of the facility, length of time materials will
be stored, and proximity to drinking water wells and surface water bodies. A fire protection plan that has
been approved by the local fire chief is necessary for all facilities and an adequate supply of water under
pressure or cover material designated for firefighting is required.
2.2.40 South Carolina
Solid waste in South Carolina is regulated by the South Carolina Department of Health and
Environmental Control. C&D debris is defined as discarded solid wastes resulting from construction,
remodeling, repair and demolition of structures, road building, and land clearing. These wastes include,
but are not limited to, bricks, concrete, and other masonry materials, soil, rock, lumber, road spoils,
paving material, and tree and brush stumps, but do not include solid waste from agricultural or silviculture
operations. C&D debris is disposed of in Class Two landfills, as regulated by 61-107.19 Part IV of the
South Carolina Code of Regulations. Class Two landfills accept C&D debris in addition to land clearing
debris and vegetation, tires, and asbestos containing material. There are no liner or leachate collection
requirements for Class Two landfills; however, groundwater monitoring is required. A minimum of one
upgradient well and three wells downgradient of the landfill are required to monitor groundwater quality.
Clean earth cover of no less than 6 in. shall be applied onto exposed waste every 30 days.
2.2.41 South Dakota
In South Dakota, solid waste is regulated by the Department of Environment and Natural Resources.
C&D debris is defined in South Dakota as waste building materials resulting from construction,
remodeling, repair, and demolition operations on pavements, houses, commercial buildings, and other
structures, excluding regulated asbestos-containing waste material or ash. This waste is disposed of in
inert waste disposal facilities, or restricted use sites which are regulated under both general permits and
individual permits, and follow certain portions of the Administrative Rules of South Dakota, Article
74:27. There are no liner or leachate collection system requirements for these inert waste and restricted
use facilities. Groundwater monitoring is also not required for these sites, as location is taken into
consideration when permitting a site to avoid the need for groundwater monitoring. A fire lane at least
25 ft wide around the active disposal area and within the perimeter fence is required for fire control.
2.2.42 Tennessee
Solid waste in Tennessee is regulated by the Department of Environment and Conservation, Division of
Solid Waste Management. C/D waste is defined to mean wastes, other than special wastes, resulting from
construction, remodeling, repair and demolition of structures and from road building. Such wastes include
but are not limited to bricks, concrete and other masonry materials, soil, rock and lumber, road spoils,
rebar, paving material. Prior to 2008, C/D wastes were disposed of in Class IV landfills. As of July 1,
2008 C/D wastes have been required to be disposed of in Class III landfills, which also allow the disposal
of shredded tires, and certain wastes with similar characteristics as approved by the Department. Class III
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and IV landfills are regulated by Chapter 1200-01-07-.04 of the Rules of Tennessee Department of
Environment and Conservation.
Although no composite liner system is required at Class III or IV landfills, there is a requirement for
either a 10-ft thick geologic buffer having a maximum hydraulic conductivity of 1 x 10~5 cm/sec, and
located such that its uppermost surface is at least 10 ft above the seasonal high water table, or for a 5 ft
thick geologic buffer having a maximum hydraulic conductivity of 1 * 10"6 cm/sec and located such that its
uppermost surface is at least 5 ft above the seasonal high water table. No leachate collection system is
required at Class III landfills. A groundwater monitoring system is required, and groundwater protection
standards must be met. At a minimum, Class III disposal facilities shall cover waste every 14 days, and
Class IV every 30 days, with at least 6 in. of compacted soil or adequate equivalent in order to prevent
fire hazards, harmful releases, and control disease vectors. In Class III landfills, quarterly gas monitoring
shall take place at the landfill facility.
2.2.43 Texas
Solid waste in Texas is regulated by the Texas Commission on Environmental Quality (TCEQ) by Title
30, Texas Administrative Code, Chapter 330. Texas defines C&D waste as "waste resulting from
construction or demolition projects; includes all materials that are directly or indirectly the by-products of
construction work or that result from demolition of buildings and other structures, including, but not
limited to, paper, cartons, gypsum board, wood, excelsior, rubber, and plastics." C&D waste may be
disposed at both Type I landfills, which may accept all forms of MSW, and Type IV landfills, which are
limited to non-putrescible wastes which include brush, C&D waste, and rubbish. C&D wastes can also be
disposed of at landfills classified as Type IAE and Type IVAE, which accept the same waste types, but
are regulated based on waste acceptance rates and location. Arid exempt landfills are exempt from
requiring a liner and groundwater monitoring.
Type IV landfills must have a liner, which can be a 4 ft thick layer of in-situ soil between the waste and
groundwater that has a hydraulic conductivity of 1 * 10~7 cm/sec or a re-compacted clay liner with a 3-ft
thick buffer between the waste and the groundwater, a hydraulic conductivity of 1 x 10"7 cm/sec, and a 1-ft
thick protective soil layer over the re-compacted clay layer. Leachate collection is not required.
Groundwater monitoring in Type IV landfills is conditional, as it may be required by the TCEQ executive
director with wells sampled annually. All Type IV facilities must apply 6 in. of earthen material cover on
a weekly basis at a minimum to control disease vectors, fires, odors, and litter.
2.2.44 Utah
The Utah Department of Environmental Quality, Division of Solid & Hazardous Waste regulates solid
waste. C/D waste is defined as solid waste from building materials, packaging, and rubble resulting from
construction, remodeling, repair, abatement, rehabilitation, renovation, and demolition operations on
pavements, houses, commercial buildings, and other structures, including waste from a conditionally
exempt small quantity generator of hazardous waste, as defined by Section R315-2-5, that may be
generated by these operations. These types of wastes include concrete, bricks, and other masonry
materials, soil and rock, waste asphalt, rebar contained in concrete, untreated wood, and tree stumps. As
defined in Rule 305 of Utah Administrative Code Title 315, C/D Waste is disposed of in Class IV
landfills, which are non-commercial landfills that can also accept yard waste, inert waste, dead animals,
waste tires, and petroleum contaminated soils if they meet certain requirements.
Class IV landfills are further classified as Class FVa landfills, which receive over 20 tons of waste per day
and as a component, CESQG waste, and Class FVb landfills, which receive less than 20 tpd or that receive
over 20 tpd and that do not accept CESQG waste. C/D aste can also be disposed of in Class VI landfills,
which are commercial nonhazardous landfills and accept the same waste types as Class IV landfills
except for CESQG hazardous waste which they are not allowed to accept. There are no liner or leachate
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collection system requirements for Class IV or VI landfills. Groundwater monitoring is considered
conditional, as only Class IVa landfills require monitoring, as well as landfills located in Salt Lake
County. To avoid fires, cover of 6 in. of soil is required over timbers, wood, and other combustible waste
on a monthly basis.
2.2.45 Vermont
Solid waste in Vermont is regulated by the Agency of Natural Resources, Department of Environmental
Conservation, Waste Management Division. C&D waste is defined as waste derived from the
construction or demolition of buildings, roadways or structures including but not limited to clean wood,
treated or painted wood, plaster, sheetrock, roofing paper and shingles, insulation, glass, stone, soil,
flooring materials, brick, masonry, mortar, incidental metal, furniture and mattresses. The definition of
C&D waste excludes CESQG waste. C&D waste is disposed of in discrete disposal facilities, which refers
to facilities other than diffuse disposal facilities used for solid waste disposal.
These discrete disposal facilities are regulated under the Solid Waste Management Rules, Rule Number
11P-03, and are required to have a liner and leachate collection system. For these facilities, the liners are
required to be double liners, with each of the liner components being of a synthetic material or a
composite of synthetic and natural materials, with a hydraulic conductivity 1 x 10~3 cm/sec. A leachate collection system is required
to maintain <30 cm of leachate on the liner. Groundwater monitoring is required unless a CDD landfill
opts to install a double liner system with a monitoring zone. Compacted soil cover 1 ft thick must be
applied weekly for safety and aesthetic purposes, and a fire break line of 50 ft shall be designated between
the waste limits and tree lines in order to prevent fires. For CDD Landfills, sites must include a
decomposition gas venting system or gas management unless the owner can demonstrate that gas
formation is not a concern. At closure, CDD Landfills must install a final cover system of soil only, 18 in.
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thick infiltration layer with a hydraulic conductivity < bottom liner hydraulic conductivity or natural
subsoils or <1 x 10"5 cm/sec, whichever is less, and a 6 n. thick erosion layer to support native plant
growth, or an alternate system consisting of a GCL or a 40 mil thick geosynthetic membrane, 18 in. thick
soil protective cover layer, and 6 in. thick earthen vegetative support layer. After closure, CDD landfills
are subject to a minimum 10-year post closure care period.
2.2.47 Washington
The State of Washington Department of Ecology develops regulations for solid waste facilities. Local
jurisdictional health departments permit and enforce the state regulations at solid waste facilities in the
state. C&D debris is not defined; however, demolition waste is defined under Chapter 173-351
Washington Administrative Code (WAC) as largely inert waste resulting from the demolition of
buildings, roads, and other manmade structures. This waste is disposed of in limited purpose landfills. As
defined in Chapter 173-350 WAC, a limited purpose landfill is defined as a landfill which is not regulated
or permitted by other state or federal environmental regulations that receives solid wastes limited by type
or source. Limited purpose landfills include, but are not limited to, landfills that receive segregated
industrial solid waste, construction, demolition and land clearing debris, wood waste, ash (other than
MSW incinerator ash), and dredged material.
WAC 173-350 establishes several performance standards for limited purpose landfills. A composite liner
system consisting of a lower component of minimum 2-ft layer of compacted soil with a hydraulic
conductivity of 1 x 10"7 cm/sec, and an upper component of HOPE 60-mil geomembrane installed with
direct contact with the lower component is presumed to meet the liner performance standard. A leachate
collection system is also required, maintaining less than 1 ft of head over the liner system and 2 ft in
leachate sump areas. Groundwater monitoring is required at limited purpose landfills. Cover is required
on a daily basis at the end of operation in order to control disease vectors, fires, odors, litter, and
scavenging. Components of C&D waste debris such as concrete, brick and masonry, clean soils, rock, and
asphalt can be disposed of in inert waste landfills, which do not have liner, leachate collection, or
groundwater monitoring requirements.
2.2.48 West Virginia
Solid waste in West Virginia is regulated by the West Virginia Department of Environmental Protection.
C/D waste is defined as waste building materials, packaging, and grubbing waste resulting from
construction, remodeling, repair, and demolition operations on houses, commercial, and industrial
buildings, including, but not limited to, wood, plaster, bricks, blocks and concrete, and other masonry
materials. This waste does not include asbestos-containing materials, household furnishings, burnt debris,
material containing lead-based paint, pressure-treated wood, contaminated solid waste, yard waste, or
waste tires. C/D Wastes are disposed of in Class D and Class D-l solid waste facilities, regulated by
Subdivision 3.16.e., et seq., and Subsection 5.4., et seq., of the Solid Waste Management Rule, Title 33
Series 1 (33CSR1). Class D-l solid waste facilities are commercial or noncommercial solid waste
facilities for the disposal of only C/D waste. Class D solid waste facilities are noncommercial facilities for
the disposal of waste materials such as asphalt, masonry products, brush, engineered wood, hardened
concrete, packaging materials, and trees, but in an area no greater than 2 acres in size and not exceeding
the height of the adjoining ground elevation.
Liner requirements are necessary depending on if the facility is Class D-l or Class D. A Class D-l landfill
requires a liner with a subbase of cleared natural ground and a 2-ft thick soil liner, compacted in 6 in. lifts
with a hydraulic conductivity less than 1 x 10"6 cm/sec. A leachate collection system is also required, as
well as groundwater monitoring. For Class D facilities, a liner and a leachate collection system are not
required. Groundwater monitoring is not required for a Class D facility; however, a groundwater
protection plan must be approved prior to operation. Intermediate cover a minimum of 4 in. thick earthen
material, or an alternate material approved by the Department, must be placed once per week over the
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disposed waste material, or it must be placed on top of each 6 ft vertical lift of waste material disposed,
whichever comes first.
2.2.49 Wisconsin
Solid waste in Wisconsin is regulated by the Department of Natural Resources (WDNR). C&D waste is
defined as solid waste resulting from the construction, demolition, or razing of buildings, roads, and other
structures. This waste typically consists of concrete, bricks, wood, glass, masonry, roofing, siding and
plaster. These wastes are disposed of in small and intermediate size C&D landfills, which are regulated by
Chapter NR 503 Wisconsin Administrative Code. Small Size C&D landfills are permitted to accept less
than 50,000 yd3 of material. For small size C&D landfills, a distance of 10 ft separation is required from
the base of the landfill to the water table, unless it is located in a clayey soil environment.
Groundwater monitoring is required for small size C&D landfills, with a minimum one well upgradient,
and two wells downgradient of the landfill. Intermediate size C&D landfills accept C&D Waste and are
permitted for more than 50,000 yd3 but no more than 250,000 yd3. Intermediate C&D landfills require a
clay liner of thickness of 3 ft, a hydraulic conductivity of 1 * 10~7 cm/sec, and a distance between the
bottom of the clay liner and the groundwater table of 10 ft. Intermediate C&D landfills must also have a
leachate collection system, as well as leachate monitoring. More extensive groundwater monitoring is
required for intermediate size C&D landfills than for small size sites. Cover is required at the end of each
operating day with 6 in of soil or alternative material. Additionally, the landfill must be designed with a
system allowing gas venting from the landfill surface, unless it has an active gas recovery system. C&D
landfills greater than 250,000 yd3 are regulated as industrial solid waste landfills under Chapter NR 504.
2.2.50 Wyoming
Solid waste is regulated by the Wyoming Department of Environmental Quality. It defines C/D waste as
waste that includes but is not limited to stone, wood, concrete, asphaltic concrete, cinder blocks, brick,
plaster, and metal. This waste is disposed of in C/D waste landfills, meaning a solid waste management
facility that accepts only inert construction waste, demolition waste, street sweepings, and brush, which
are regulated by Chapter 4 of the Wyoming Solid Waste Rules. Bottom liner and leachate collection
systems at C/D landfills are conditional based on the wastes accepted and site conditions of where the
C/D landfill is located. Groundwater monitoring may be required at these facilities. Cover is required for
all facilities, with 6 in. of compacted soil at least monthly, though landfills that receive <20 yd3 of waste
per month must cover with 6 in. of compacted soil once the working face depth reaches 3 ft. Fire
protection is required by maintaining a minimum 10 ft unobstructed fire lane within the area of the
perimeter fence, and personnel having access to portable fire extinguishers as well as a communication
system to alert the local fire department.
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2.3 Inventory of Active C&D Landfills and C&D Recycling/Processing Facilities
A total of 1,540 active C&D debris landfills and 512 active C&D recycling facilities were identified in the
facility inventory using the methodology described previously. The number of active C&D landfills was
less than that reported by US EPA (1994), which identified 1,889 C&D landfills, a decrease of
approximately 18%. As a point of comparison, the number of MSWLFs in 1994 was 3,558 (US EPA
2008), while the reported number of MSWLFs in 2008 was 1,908 (van Haaren et al. 2010) - a decline of
approximately 47%. Figure 2-1 presents a map depicting the distribution of active C&D debris landfills
in the US. The data were further examined on a population basis - using US census data from 2010, the
distribution of landfills was assessed by grouping each state based on population size as shown in
Figure 2-2. The data do not appear to suggest a strong correlation between a state's population size and
the number of active C&D debris landfills. For example, states with a population ranging from 1 to
5 million have nearly 45% of all active C&D debris landfills, whereas the number of C&D landfills in the
largest states (population greater than 10 million) is slightly less than the number of landfills in the states
with the smallest populations.
The relative disparity in the decline of the number of C&D landfills compared to MSWLFs is likely a
function of a combination of factors, primarily that no major federal rules in the last 18 years were
promulgated impacting C&D debris management, whereas the decline in the number of MSWLFs is
largely a function of the federal Subtitle D design and construction requirements for these facilities, which
mandates a liner and leachate collection system among other elements. Thus, the trend for MSW to be
disposed of in fewer, larger facilities has emerged in recent years. As will be discussed in Section 2.4,
several states have increased the stringency of rules related to C&D debris management, which may have
contributed somewhat to the decline in the number of C&D landfills compared to the 1994 figure. Note
that most states (66%) do not require bottom liners and leachate collection systems, which may explain
why the decline in the number of C&D landfills was not as dramatic when compared to MSWLFs.
Another factor that likely contributed to the decline in C&D landfills compared to 1994 was the economic
downturn that occurred in the US in late 2008, which greatly impacted the construction industry.
Figure 2-3 presents a summary of C&D recycling and processing facilities in the US. Note that the data
represent facilities that nearly exclusively process C&D debris, which was determined by obtaining lists
of C&D-only processing facilities from the states or by filtering data in the WBJ (2012) database to
include only those facilities that listed C&D as the only materials processed. In general, the figure shows
that the number of facilities in a given state tends to be greater on the east and west coast. The count of
facilities presented in Figure 2-3 contains some gaps and thus likely underestimates the total number of
C&D processing facilities in the US. As described further in Section 2.4, several states exempt certain
recycling activities from regulation under solid waste rules, and as a result, these activities may not be
documented at the state level.
The number of C&D processing facilities as a function of state population was examined as shown in
Figure 2-4. In contrast to the C&D disposal facility and population relationship shown in Figure 2-2,
there appears to be a strong correlation between a state's population size and the number of C&D
processing facilities.
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Figure 2-1. US Map Showing Grouped Distribution of the Number of Active C&D Landfills Based
on State Solid Waste Databases as of 2012
<1,000,000 1,000,000 - 5,000,000 5,000,000-10,000,000
State Population Range
> 10,000,000
Figure 2-2. Distribution of the Number of C&D Debris Landfills in the US as a Function
of State Population
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Number of C&D
Recycling Facilities
0
1-2
3-10
11-50
>50
Figure 2-3. US Map Showing Grouped Distribution of the Number of Active C&D Recycling
Facilities Based on State Databases, Direct Facility Contact, and WBJ (2012) as of 2012
< 1,000,000 1,000,000-9,000,000 5,000,000-10,000,000
State Population Range
>io,ooo,ooo
Figure 2-4. Distribution of the Number of C&D Debris Recycling Facilities as a Function
of State Population
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2.4 Discussion of State Regulations Review
The review of state regulations presented in Section 2.2 provided a range of information regarding the
state of C&D debris management in the US, both in terms of how disposal facilities are regulated as well
as how recycling and processing facilities are regulated. This section provides a series of figures and data
summarizing the review of regulations. First, broad observations regarding the regulatory review are
provided as follows:
Definitions. Nearly all states had a specific definition for C&D debris. The definition of C&D
debris varied, sometimes substantially, between states (e.g., some states excluded CESQG waste
from the definition of C&D debris). A common approach to defining C&D debris included listing
specific materials that are considered to be C&D debris. Another approach several states used
included listing materials (which could originate from a construction or demolition site) as "clean
rubble" or "clean debris," which was often coupled with regulatory language exempting these
materials from management as a solid waste.
C&D Debris Regulations. Most states have specific regulations pertaining to C&D debris
disposal facilities, many of which include exclusively C&D debris, and in some cases there are
broader waste classifications that include C&D debris. In contrast, many states (31) do not have
regulations pertaining to the recycling and processing of C&D debris. In some cases, certain
recycling activities like C&D processing fell outside of the definition of solid waste, thus
recycling activities were exempted from solid waste regulations. In this case, recycled amounts
are frequently not tracked, and these facilities are also often not subject to routine compliance
inspections by the state. In other cases, states (10 total) had rules for waste processing and in
these cases, a listing of wastes subject to the rule (which often included C&D debris) was given.
In other cases, states (9 total) had specific C&D debris processing facility regulations.
Regulatory Flexibility. In nearly all cases, states had regulations that provided flexibility in
terms of stringency. For example, many states have provisions to allow requirements such as
bottom liners and leachate collection systems to be conditional, which gives a site owner the
opportunity to demonstrate that these systems are not needed based on site-specific factors. On
the other hand, many states had language that provided the regulatory agency the ability to apply
conditions that were more stringent if site-specific conditions warranted.
Specific aspects of state rules regarding construction and operational requirements were evaluated to
assess broad trends. Figure 2-5 depicts a classification of each state based on the regulatory minimum
bottom liner and leachate collection system requirements. The data showed that 17 states require some
form of liner and leachate collection system, while five states require a liner but no leachate collection
system, 12 have explicit conditional requirements for liners (e.g., liners and leachate collection systems
may be required for landfills that are a certain design size but not required for smaller sites), and 16 states
have no minimum liner and leachate collection system requirements. Note that for many states, it was
common for the regulations to include language giving the regulatory agency the authority to require
more strict engineering controls if site conditions warrant.
The data in Figure 2-5 were compared to the average annual precipitation in each state, which is depicted
in Figure 2-6. A broad comparison of these two figures appears to suggest that, in general, states that
have higher levels of precipitation tend to have more stringent liner and leachate collection system
requirements.
Figure 2-7 presents a map depicting the minimum groundwater monitoring requirements at C&D
landfills in each state. Overall, 13 states have no minimum groundwater monitoring requirement, 11 have
conditional requirements, and 26 have monitoring requirements. US EPA (1995c) indicated that as of the
mid-1990s, 29 states require "some or all construction and demolition facilities" to monitor groundwater.
Thus, using the same criteria that were used in US EPA (1995c), the number of states that currently
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require some or all C&D debris landfills to monitor groundwater is 37, an increase of approximately 28%.
The 26 states that require groundwater monitoring were further examined to assess the relationship to the
number of C&D landfills in the state. Figure 2-8 shows that the number of states that require
groundwater monitoring is fairly evenly distributed across the different "landfill number" bin sizes. This
suggests that the requirement to monitor groundwater is not heavily influenced by the number of facilities
that would be required to comply with such a regulation.
The data in Figure 2-5 was compared with the data in Figure 2-7to examine the overlap between states
that require liners and leachate collection systems at C&D landfills and states that require groundwater
monitoring at C&D landfills. Figure 2-9 summarizes the results of this comparison. The data indicate that
the greatest number of states (18) have a requirement for groundwater monitoring and a liner and/or a
leachate collection system, whereas it was least common for a state to require a liner and/or a leachate
collection system but no groundwater monitoring. A total of nine states were identified that had no
minimum requirement for liners, leachate collection systems, and groundwater monitoring.
Figure 2-10 summarizes an assessment of the operational cover soil requirements in each state. The data
shows a wide range of cover soil application frequency, ranging from no minimum requirement to daily.
This finding is in contrast to the RCRA Subtitle D requirements for MSW landfills, which require the
application of 6 in. of cover soil (or an approved alternative) daily. The application of cover soil at C&D
landfills can have substantial implications with respect to several of the damage pathways examined in
this report, including groundwater quality, the emission of H2S, and occurrence and persistence of fires.
These issues are described in more detail in Section 3 and Section 4.
Liner Requirements
No Requirements
Conditional
Liner/No Leachate Collection
Liner/Leachate Collection
Figure 2-5. Summary of Minimum C&D Landfill Liner and Leachate Collection System
Requirements in the US as of 2012
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<< Q20-24 Q40-5Q
4-« D?«-J8 ISO-GO
9-12 QZ9-32 &Q-7Q Q140-160
I: n. DC !' ''!' i^f E ]HM-
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Figure 2-6. Average Annual Precipitation in the US Ecam 1971 to 2000 (NOAA 2012)
Groundwater Monitoring
Requirements
[H I No Requirements
I I Conditional
Figure 2-7. Summary of Minimum C&D Landfill Groundwater Monitoring Requirements Including
Conditional Requirements in the US as of 2012
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1 ft
a
- G
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51 6-
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!_ 1 4 -
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1
<3 3-10 11-50 50-100
Xumber of C&D Debris Landfills in A Given State
Figure 2-8. Comparison of States with Required Groundwater Monitoring at C&D Landfills
and the Number of Landfills in a State
::
f- 12
<*-
Q
-S s -
H
^^m
\
n i i i i
No Minimum Liner. No Minimum Liner or Liner or Liner -r Liner or Liner -
Leachate Collection, or Liner + Leachate Leachate Collection Leachate Collection
Groundwater Monitoring Collection Required, but Required but No Required and
R e quirem ent G roundwater Monitoring G round\vater Monitoring G round'-vater Monitoring
Required Required Required
C&D Landfill Construction and Monitoring Criteria Combination
Figure 2-9. Distribution of States Corresponding to Bottom Liner, LCS, and Groundwater
Monitoring Requirements in the US
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Cover Soil Requirements
No Minimum Requirements
Variable
> Monthly
> Weekly, < Monthly
> Daily, < Weekly
Daily
Figure 2-10. Summary of Minimum Operational Soil Cover Application Frequency for C&D
Landfills in Individual States in the US as of 2012
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2.5 Discussion of Identified Damage Sites
The project team took a multi-step approach to identify potential damage sites in each state. First,
representatives from each of the 10 US EPA regions were queried regarding their knowledge of C&D
debris damage sites. None of the US EPA regions identified knowledge of damage sites for facilities that
only handle C&D debris, but the regional representatives all indicated that individual states would have
more direct knowledge of site issues. Research regarding damage was then conducted by evaluating
publicly available information from state solid waste databases as well as contacts with solid waste
regulatory program personnel in each state. In all cases, state regulatory representatives located in the
state's headquarters office were contacted.
In some cases, the regulatory representatives had knowledge of C&D damage sites and were able to
furnish a list of facilities. In many cases, the state regulatory representatives contacted indicated that
compliance and enforcement issues related to damage are handled at a district or regional level, and that
district or regional representatives would have to be contacted to obtain additional information. In the
queries to each state, the timeline under consideration for damage sites was limited to sites that currently
or recently were identified as having damage, though no strict boundary was necessarily provided. In this
analysis, the contact with states did not go beyond the headquarters level because of project time
constraints.
A total of 44 damage sites were identified in 17 states located in eight of the 10 US EPA regions. Table
2-1 summarizes the inventory of sites obtained using the methods described previously. The number of
sites identified is expected to be less than the universe of actual damage sites for the following reasons:
Several states (24) do not have minimum requirements for monitoring groundwater for all C&D
debris landfills, so in those cases impacts to groundwater would be difficult to quantify due to the
absence of monitoring data.
Several states indicated that compliance and enforcement are handled at the regional or district
level, thus a response of "no known damage" was indicated for several states. The response is
more of a function of the way a given state structures its enforcement group, though, and not
necessarily indicative that a state has no sites that would fit the profile of a damage site.
Many states do not have rules specific to C&D debris processing facilities, and in other cases,
recycling of C&D debris is an activity that is excluded from regulation under solid waste rules.
Thus, in many cases, these facilities are often not permitted or inspected by state regulatory
agencies.
While a fairly narrow definition of "damage" was provided to the state representatives when
developing the inventory, the subjectivity of the question could cause a varied response from a
given representative based on their experience level and interpretation of terms like "recurrent" or
"problematic."
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Table 2-1. Summary of C&D Facility Damage Inventory Based on
Queries to State Solid Waste Regulatory Personnel and
Examination of Other Publicly Available Reports and Case Studies
State
Arizona
California
Delaware
Florida
Georgia
Hawaii
Idaho
Kansas
Kentucky
Mississippi
Missouri
New Jersey
Ohio
Oregon
Rhode Island
Virginia
Wisconsin
Number of Damage
Sites Identified
3
1
1
3
6
1
1
1
3
4
2
1
8
1
1
1
6
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3. Evaluation of Potential Damage from C&D Management and
Statewide C&D Management Damage-Related Data
3.1 Overview and Methodology
This section discusses potential damage from C&D debris management facilities and an assessment of
large-scale data sets collected at the state level. In contrast to the damage site inventory presented in
Section 2, which reported damage sites based mostly on inquiries to solid waste regulatory staff (who in
many cases were not directly involved with facility enforcement or compliance issues), the analysis in this
section provides a more in-depth assessment of a handful of large data sets to identify broad trends and
specific factors that may indicate environmental damage. The information analyzed in this section
originated from the scientific literature (particularly that which has been conducted since the mid-1990s),
statewide studies on C&D debris management conducted as part of rulemaking or guidance development
(e.g., Maryland, Minnesota, and Ohio), and other readily available state-wide data sets (e.g., Wisconsin,
Virginia, and Florida).
The information provided in this section does not necessarily represent an exhaustive list of all states that
have conducted large-scale environmental impact or extensive compliance evaluations related to C&D
debris, nor does it represent an exhaustive examination of all publicly available data sets for C&D debris
facilities. The methodology of data set selection and collection was based on several factors, including the
following (in decreasing order of importance):
data set availability;
data sets that included information on multiple facilities in a given state;
data sets that included information on a variety of issues, including groundwater, odors/air
emissions, and other operational issues; and
varied geographic representation in the US.
The information that was gathered and analyzed for each state varied in terms of depth and breadth of
information. In some cases, large data sets regarding permits, permit applications, compliance,
enforcement, and monitoring data were available. In other cases, only raw data sets were available and
follow-up with the regulatory agency occurred to check data completeness and provide context to the
data. In all cases, the data that were examined in this section are from secondary sources (i.e., data
collected and, in some cases, reported by others).
The summary of scientific literature regarding groundwater impacts, gas production, fires, and issues
related to C&D debris recycling and recycled C&D debris components is provided in Section 3.2, while
the examination of statewide data is presented in the remaining subsections.
3.2 Technical Discussion of Damage from C&D Debris Management Based on
Recent Scientific Literature
The studies conducted by the US EPA in the mid-1990s related to damage at C&D disposal facilities
focused mostly on groundwater impacts, with some acknowledgement of surface water impacts. As
discussed, damage at C&D debris management facilities may be manifested in other ways, particularly
with regard to air emissions as well as other issues such as fires. Even in the case of groundwater, a
tremendous amount of research has been conducted since the mid-1990s that discusses issues with
leaching of chemicals from major components of C&D debris (which is a concern, along with leaching of
hazardous chemicals from other products that may be in C&D debris in trace amounts, such as paints,
glues, and solvents). Furthermore, increased observation of odorous emissions, as well as increased
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understanding of the mechanisms that cause odorous emissions, has occurred in recent years. Thus, prior
to the more detailed discussion of damage related to the statewide studies (as well as the detailed damage
cases presented in Section 4), it is important to discuss the different damage pathways as well as the
potential human health and environmental impacts.
3.2.1 Groundwater impacts
Groundwater monitoring is conducted at C&D debris management facilities on a routine basis to evaluate
groundwater quality. Upgradient and downgradient wells are used to compare data and draw conclusions
regarding the data, in addition to site hydrogeologic conditions. The leaching of components into the
groundwater may occur if no earthen or synthetic liner is present (or if the liner system does not function
properly), and in some cases may depend on the constructed location of the site (e.g., proximity of the
landfill bottom to the water table). Most newer facilities have detailed hydrogeological characterizations
conducted prior to waste placement to provide groundwater quality baseline data and meet siting criteria.
In some cases, groundwater quality has been shown to be impacted at facilities just because of the
presence of the landfill itself and not as a result of direct leaching from the waste.
When no liner is present, leachate resulting from the contact of rainfall and C&D debris components has
the potential to degrade water quality. While surface water can be impacted from leachate seeps from the
side slopes or the base of the landfill, the more common concern is leachate migration through the landfill
to the underlying aquifer. Bulk building materials such as concrete, wood, and drywall have been
demonstrated to create leachate elevated in minerals content with a potential for causing groundwater
concentrations at monitoring wells to exceed secondary water quality standards (Townsend et al. 1999,
Weber et al. 2002, Jang and Townsend 2003). Other building debris components contain chemicals with
known human health hazards, including lead (e.g., paint, metal sheeting), mercury (lighting, electrical
switches), and PCBs (light ballasts, paints). Research has found that some elements in C&D debris (e.g.,
lead) may be largely contained within C&D debris landfill environments because of the tendency of the
SO42"-reducing environment to bind metals (Wadanambi et al. 2008).
Leaching from preservative-treated wood and the possible impact on groundwater quality at C&D debris
landfills has been evaluated at length in the past 10 years (Weber et al. 2002, Townsend et al. 2004a).
Chromated copper arsenate (CCA), which until recently was the predominant wood preservative used in
the US, released arsenic in leaching tests and simulated landfills at concentrations that could result in
water quality maximum contaminant level (MCL) exceedances in groundwater wells if sufficient dilution
does not occur (Jambeck et al. 2008). Research on the predominant preservative replacements for CCA, a
series of chemicals based primarily on copper, found that copper was largely contained within the C&D
landfill environment, though other preservative chemicals, such as boron, continued to leach (Dubey et al.
2009).
Recent research has focused on the release of naturally occurring substances from soils and the aquifer
matrix as a result of conditions induced by C&D debris landfill leachate (Wang et al. 2012). The
phenomenon is known as reductive dissolution; iron and manganese oxide minerals are dissolved as
bacteria consume organics in leachate, leading to elevated concentrations of these dissolved metals (in
their reduced redox state) in groundwater (Lovley 1991; Heron and Christensen 1995). Additionally, the
presence of a landfill itself (with or without a liner) may cut off surficial aquifer atmospheric oxygen
exchange, thus leading to reducing conditions beneath landfills and thus causing reductive dissolution
(Sarasota County 2010). Given that arsenic is often naturally bound to iron minerals, this phenomenon
can lead to elevated groundwater concentrations of arsenic as well (deLemos et al. 2006).
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3.2.2 Gas Production and Migration
Since the previous US EPA investigation of damage cases from C&D debris, several cases involving gas
emissions from C&D debris landfills have been documented, which resulted in several studies on the
issue. Hydrogen sulfide (H2S) and other reduced sulfur gases have been documented to occur in large
concentrations at C&D debris landfills (Eun et al. 2006, Lee et al. 2006), causing problems of both odor
and nuisance to local residents, as well as potential health concerns to on-site workers and the
surrounding community. Disposed gypsum drywall can cause the formation of H2S in a landfill through
the presence of a combination of factors including moisture, anaerobic conditions, and a carbon source. In
the moist, anaerobic environment of a landfill, SCV'-reducing bacteria utilize dissolved SCV" from
gypsum (hydrated calcium sulfate, CaSO4»2H2O) drywall as an electron acceptor in the consumption of
organic matter, producing H2S. The kinetics of H2S formation (Tolaymat et al. 2012) and the
measurement of H2S concentrations at operating landfill sites have been evaluated and reported (Xu et al.
2010a, Xu et al. 2010b). The emission of H2S depends on weather conditions (e.g., atmospheric pressure,
wind velocity, temperature) and the presence or absence of a cover soil and cap and associated
characteristics, and the presence and/or performance of gas controls.
Laboratory experiments to replicate the formation of large concentrations of H2S in simulated C&D
debris landfill environments containing gypsum drywall have been conducted (Yang et al. 2006, Plaza et
al. 2007). Recent research has focused on methods to control H2S formation and to remove H2S once it is
produced (Xu et al. 2010a, Xu et al. 201 Ob). Removal of H2S from C&D was evaluated by Xu et al.
(2010a,b), who found that physical removal of H2S from the gas phase can be accomplished with a
variety of materials (e.g., concrete fines, mulch, native soil, and steel) with varying results. Other
researchers have studied H2S removal or mitigation using other cover amendments, such as metal oxides
(Bergersen and Haarstad 2008) and waste biocover soil (He et al. 2011).
One facility in Ohio (as detailed in Section 4) was remediated under the US EPA Superfund program
because of large emissions of odorous gases resulting from the disposal of pulverized gypsum drywall. As
a follow-up to the remediation of this site, the US EPA (2006b) developed a guide to manage H2S from
landfills that accept pulverized gypsum drywall. Continued issues with H2S emissions at C&D and MSW
landfills elsewhere in the US have occurred since that time, and the US EPA recently commissioned an
evaluation to develop a more comprehensive best management practices guide for preventing and
controlling H2S emissions from landfills that accept gypsum drywall (US EPA 2012).
3.2.3 Fires
Landfill fires can result from deposition of smoldering waste loads or by spontaneous combustion. Fires
can cause hazards for on-site workers as well as emit multiple types of air pollutants. The physical nature
of C&D debris differs from MSW in that many materials are bulky and rigid, thus while standard
procedures at C&D disposal facilities involve the use of bulldozers and compactors to compress the
waste, size reduction tends to be the primary mechanism for consolidation. Given the bulky nature of
C&D debris, coupled with the fact that many C&D debris landfills have minimal or infrequent cover soil
application requirements, conditions can occur where air voids form within the waste mass. Additionally,
the formation of above-grade side slopes that are steep (e.g., greater than standard 3 horizontal to
1 vertical rise configuration) can result in air from prevailing winds entering the landfill, introducing
oxygen and creating a chimney effect, which can contribute to or exacerbate fire issues. Formation of
steep slopes also reduces the ability to compact the waste mass because of decreased normal forces
exerted on the waste during compaction, which can further encourage the formation of air voids in the
waste. The Federal Emergency Management Agency (2002) suggested that C&D landfills are more
susceptible to a major landfill fire compared to other types of landfills.
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EPA/600/R-13/303 Data Gap Analysis and Damage Case Studies for C&D Debris Facilities
Aside from the health and safety issues associated with a fire at a landfill, the occurrence of landfill fires
at C&D debris facilities, as well as the steps to remediate them, can magnify other potential
environmental concerns. For example, a common firefighting measure is the addition of water to the
impacted area, but this can increase the quantity of leachate produced, and can also increase the moisture
content of the waste, which can promote the production of H2S (this issue was observed in the Florida
damage case highlighted in Section 4). Also, the release of some chemicals may be enhanced from burned
waste, such as arsenic leaching from the ashes of burned CCA-treated wood. Furthermore, the
combination of fire and added water can create voids within the waste, thus creating paths for gases and
leachate to short circuit through the landfill, which could result in uncontrolled releases to the
environment.
3.2.4 C&D Debris Recycling
Limited research has focused on environmental issues associated with C&D recycling operations,
particularly when compared to research on health and environmental concerns at C&D debris landfills. As
described in Section 2, many states exempt certain C&D recycling activities from solid waste regulations,
thus close examination of C&D recycling practices may not always be documented through compliance
and enforcement activities.
Issues that may occur at C&D recycling facilities may include problems with the storage of certain
materials. Several states with rules specific to C&D recycling place limits on the amount of time and/or
the volume of recyclable material that can be stored prior to shipment off-site for ultimate use or further
processing. An example where large amounts of debris were stockpiled and significant issues occurred
(e.g., fires) is highlighted in the California damage case presented in Section 4. Other operational
concerns that have been investigated involve the physical processing of debris at C&D recycling
facilities. For example, concerns about the potential presence of asbestos (and therefore subsequent
release following grinding or size reduction) in discarded asphalt shingles has been the subject of a
substantial amount of research, but large-scale examination of operational data (e.g., as summarized by
the Construction Materials Recycling Association [2007]) suggests that this concern is minimal, given
appropriate sampling and material sourcing procedures.
The possible environmental concerns associated with the reuse of some products generated from C&D
recycling operations have been evaluated. For example, the chemical content of recovered fines produced
during the screening operation at C&D debris recycling facilities has been evaluated for organic
chemicals (Jang and Townsend 200la), heavy metals (Townsend et al. 2004b), and SO42" (Jang and
Townsend 200Ib). Screened C&D fines, which are frequently utilized as cover soil and material for
grading and shaping of slopes at C&D and MSW landfills, may also contain concentrations of SO42" that
can lead to the formation of JrhS, and some states (e.g., New Hampshire) have developed specifications
for cover materials that limit the SCV content of screened fines (New Hampshire Department of
Environmental Services 2004). Arsenic contamination of C&D debris wood mulch from recycling
operations has also been evaluated (Tolaymat et al. 2000, Townsend et al. 2003).
3.3 Florida - Groundwater Monitoring Data at C&D Disposal Facilities
The Florida Administrative Code (62-701, FAC and 62-520, FAC) requires routine groundwater
monitoring at C&D landfills in Florida. Bottom liners and leachate collection systems by rule are not
required unless site-specific conditions, as determined by the FDEP, warrant the need for a liner and
leachate collection system to be installed. C&D landfills are required to have at least one monitoring well
hydraulically upgradient (background well) and at least two detection wells located downgradient within
50 ft from the edge of the landfill. Semiannual monitoring for a suite of parameters is required as
specified in 62-701 and 62-520, FAC, and the number of wells and the associated monitoring parameters
for each landfill are specified as part of the facility's permit conditions. The FDEP maintains a database
45
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EPA/600/R-13/303 Data Gap Analysis and Damage Case Studies for C&D Debris Facilities
of water quality monitoring data submitted by operating facilities at a frequency specified by the facility's
permit. The data for 91 C&D debris landfills were downloaded and analyzed to examine trends related to
measured chemical constituents to assess on a broad basis if or how groundwater at C&D landfills is
being impacted in Florida.
The project team downloaded groundwater data for all of the facilities classified as C&D landfills and
compiled the data in an MS Access database; 121 facilities were classified as C&D landfills, of which
91 were found to exclusively accept C&D debris (30 facilities also allowed the acceptance of MSW
and/or Class III waste, which includes other non-putrescible, non-C&D debris). Only the 91 facilities that
accepted only C&D debris were analyzed further.
3.3.1 Data Analyzed
The database included more than 450,000 measurements of more than 400 chemical constituents,
including field parameters and inorganic and organic compounds, for the 91 sites. Data for each site
represent monitoring events as early as the mid-1990s and as recently as 2011. The number of years of
data available for each site varied based on availability in the database.
As part of routine landfill compliance, groundwater monitoring events are conducted in accordance with a
site's permit, and the resulting measured concentrations are compared to appropriate target levels, which
are based on federal MCLs (primary and secondary) or risk-based target levels. Figure 3-1 presents the
total number of measurements and the number of measurements (includes all measurements, upgradient
and downgradient) below the respective laboratory detection limit and above the Florida Groundwater
Cleanup Target Level (GCTL) either in mg/L or ug/L.
More than 95% of the measurements of organic compounds were below the corresponding laboratory
detection limit. Approximately 28%, 13%, and 1% of field parameters and inorganic and organic
compound measurements were detected at concentrations greater than the respective GCTL.
A total of 60 organic compounds exceeded the GCTL at least once. The organic compounds measured at
more than 10 sites that exceeded their GCTL in more than 1% of measurements were: acrylonitrile,
aldrin, benzene, bis (2-cloroisopropyl) ether, bis (2-ethyhexyl) phthalate, bromodichloromethane,
cyanide, dibromochloromethane, methylene chloride, phenols, 1,1,2,2-tetrachloroethane, and vinyl
chloride. Approximately 8.6%, 3.6%, 19%, and 5.3% samples exceeded the GCTL for benzene,
bromodichloromethane, phenols, and vinyl chloride, respectively.
Of the 78 inorganic parameters that were detected, 43 exceeded the GCTL at least once. Iron, aluminum,
arsenic, sodium, chloride, sulfate, thallium, and TDS most frequently exceeded the GCTL; these
parameters were measured at concentrations greater than the GCTL at approximately 55 sites. Figure 3-2
presents a comparison of the distribution of parameters (those that most frequently exceeded the GCTL)
measured in upgradient and downgradient wells. In the box plot in Figure 3-2, the line in the center
represents the median concentration, the edges of the box represent the 25th and 75th percentiles of the
data, and the edges of the whiskers represent the 10th and 90th percentiles of the data, with the remaining
individual points representing outliers. As can be seen in Figure 3-2 the median of concentrations
measured at downgradient wells is approximately 2 to 4 times greater than that of upgradient wells for
these parameters. The data also show multiple data points that fall outside of the 10th and 90th percentile
of the data, suggesting a degree of scatter including low and high measured concentrations.
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EPA/600/R-13/303
Data Gap Analysis and Damage Case Studies for C&D Debris Facilities
3.5
3.0 -
2.5 -
2.0 -
en
8
o
o"
o
t/5
-Ii
CO
CD
o 1-0
i
CD
1
0.5 -
0.0 -1-
Measurements Below Lab Detection Limit
Measurements Above Lab Detection Limit and Below GCTL
Measurements Above GCTL
Field Parameters
Inorganics
Organics
Figure 3-1. Summary of Broad Statistical Results Comparing Measurements of Field Parameters,
Inorganic Compounds, and Organic Compounds to GCTLs from Groundwater Monitoring Data
from C&D Landfills in Florida
47
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EPA/600/R-13/303
Data Gap Analysis and Damage Case Studies for C&D Debris Facilities
1 nfi
105 -
104 -
1 n3
_j 1U
"DJ
11 10=-
101 -
10° -
i n-1
Ammonia
i GOT
t
Upgradient
107 -
106 -
10-
"^
^ 104
103 -
102 -
mi
Sodium
I GC~
f
Upgradient
m"
107 -
106 -
10 -
D)
* 10'-
103 -
102 -
1 ni
Sulfate
1 GC
!
Upgradient
IT
L
t
105 -
104 -
_l
7^ m2
101 -
10° -
1C'1 -
^ n-2
Iron
GC"
t
Downgradient Upgradient
I
j
107 -
106 -
105-
o> 104-
103 -
102-
101 -
Chloride
1 GC"
T
1 ' w II
Downgradient Upgradient
inn
" I
j
107-
106 -
10° -
_l
^ 1 n4
O) IU
103 -
102 -
101 -
IDS
1 GCl
1
Downgradient Upgradient
±
TL
Downgradient
1
t
Downgradient
1
j
Downgradient
Figure 3-2. Comparison of Concentration Distribution of Selected Parameters for Upgradient
and Downgradient Wells for C&D Landfills in Florida
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Data Gap Analysis and Damage Case Studies for C&D Debris Facilities
Figure 3-3 presents a summary of detected constituents in groundwater at Florida C&D landfills that
exhibited an exceedance of a GCTL at least once in a downgradient well. The data indicate that iron,
aluminum, phenols, TDS, arsenic, and ammonia showed at least one exceedance at a downgradient
monitoring well at more than half of the 91 landfills analyzed.
100
Total Number of Sites Analyzed
Illinium
i
Parameter
-o
Figure 3-3. Summary of the Number of Facilities That Exhibited at Least One Exceedance of a
GCTL at a Downgradient Monitoring Well, Organized Based on Chemical Constituent
Table 3-1 provides summary statistics regarding measured parameters in groundwater that exceeded the
GCTL in downgradient wells. The data shows that aluminum, ammonia, dibromochloromethane, iron,
phenols, and TDS exhibited elevated concentrations (when comparing the median concentration to the
GCTL in downgradient wells) at several sites (>10).
Table 3-1. Summary of the Median Concentration of Measured Parameters in Groundwater that
Exceeded the GCTL in Downgradient Wells
Parameter
Aluminum
Ammonia (Total as N)
Arsenic
Benzene
Bromodichloromethane
Cadmium
Chromium
Dibromochloromethane
Number of Sites
with Downgradient
Well Measurements
87
88
87
88
88
87
88
88
# of Sites with Median
Concentration of
Downgradient Wells >
Upgrad lent Wells
32
55
23
13
11
9
24
8
#of Sites with
Downgradient Median
Concentration
Exceeding GCTL
30
17
0
1
8
0
0
27
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EPA/600/R-13/303
Data Gap Analysis and Damage Case Studies for C&D Debris Facilities
(continued)
Table 3-1. Summary of the Median Concentration of Measured Parameters in Groundwater that
Exceeded the GCTL in Downgradient Wells (continued)
Parameter
Dissolved Iron
Iron
Lead
Mercury
Methylene Chloride
Nitrate (As N)
Phenols
Sodium
Sulfate
Total Dissolved Solids
Vinyl Chloride
Number of Sites
with Downgradient
Well Measurements
28
89
89
87
88
88
86
89
88
89
88
# of Sites with Median
Concentration of
Downgradient Wells >
Upgrad lent Wells
12
51
11
12
16
32
18
62
58
62
16
#of Sites with
Downgradient Median
Concentration
Exceeding GCTL
15
47
0
0
0
0
42
1
3
24
0
3.3.2 Data Analysis Summary
The data gathered and analyzed as presented in Figure 3-2, Figure 3-3, and Table 3-1 suggest that
groundwater impacts have occurred at several C&D landfills in Florida based on the broad comparison of
upgradient and downgradient well measurements as well as comparison of downgradient measurements to
applicable risk target levels. Note that a large amount of data was compiled and aggregated to provide
broad summary statistics - the intent was not to conduct a rigorous risk analysis at the facility level. The
data also indicate (based on the frequency analysis presented in Figure 3-3) several organic and inorganic
parameters, some of which are consistent with constituents of concern identified in the previous US EPA
(1995b) damage case evaluation, and several others that were not.
The direct interpretation of the aggregated data in this analysis is subject to certain limitations. For
example, grouping measured concentrations of several wells at a given site could overrepresent or under-
represent potential impacts, depending on the magnitude of constituent concentrations measured and the
number of wells in a given category (upgradient or downgradient), among other factors. The specific
magnitude of impacts, though, and confirmation of whether a C&D landfill site is impacting the
surrounding environment to the degree that it is acknowledged as a damage case, is an exercise that must
be conducted at the facility level. A more detailed analysis of factors such as site-specific hydrogeology,
operating practices, and other factors would need to be accounted for in such an assessment.
3.4 Maryland - Unauthorized Waste Acceptance and Leachate and
Groundwater Quality at Rubble Landfills
Maryland Department of the Environment (MDE) is the regulatory body for Maryland's C&D landfills
(defined in Maryland rules as rubble landfills). In the 1990s, research regarding operation and monitoring
data at rubble landfills in Maryland was conducted as part of justification for modifications to the state's
minimum design and operating requirements at rubble landfills. The proposed rules included a
requirement to design and construct a low-permeability bottom liner system and leachate collection and
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removal system. The state regulations prior to the proposed liner regulations were based on two
assumptions: that debris that is allowed in rubble landfills is not expected to negatively impact the
environment, and that debris that is prohibited from disposal in rubble landfills is not received in practice
at rubble landfills. The information presented in this section was taken from a series of memoranda
written by MDE (1997a).
3.4.1 Prohibited Waste Evaluation Review
MDE initiated a study to examine the procedures followed by permitted rubble landfills in the state
related to compliance with promulgated waste prohibitions at the facility level. Several years of
inspection records were reviewed and the results were as follows:
Incidences of prohibited waste acceptance were present, even with in-place operational
procedures to screen such wastes out.
Between 1990 and 1997, approximately 44% (8 of 18 rubble landfills in the state) had at least one
instance where unauthorized or prohibited waste was accepted.
At least 32 instances of prohibited waste acceptance occurred between 1990 and 1997. Examples
of prohibited wastes accepted included contained petroleum products and MSW.
Another limited study at one rubble landfill in 1992 showed that three out of 20 loads (15%)
contained greater than a de minimis quantity of MSW.
The instances described only represent cases where an MDE inspector was on site and observed
the prohibited waste acceptance.
3.4.2 Groundwater and Leachate Data Review by MDE in the Mid-1990s
In addition to operational history, MDE compiled leachate and groundwater quality data from several
rubble landfill sites in 1997. Analytical data were summarized from eight rubble landfills; results included
analytical data for collected leachate, leachate seeps (collected from side slopes or near active filling
areas), and site groundwater. Major observations reported by MDE (1997a) are presented in Table 3-2.
Table 3-2. Summary of Groundwater and Leachate Data for Rubble Landfills Analyzed
by MDE (1997a) in the Mid-1990s
Site
Number
1
2
3
4
Media
GW
GW,
Leachate
Leachate
Leachate
VOCs Detected
Freon 12, Chloroethane, Methylene
chloride, 1,1,1,-Trichloroethane (TCA),
Toluene, Tetrahydrofuran, Acetone,
and various alcohols
GW: Trichloroethene (TCE); cis-1,2-
Dichloroethane above MCL
Leachate: Freon 12, Freon 11, and
Tetrahydrofuran
Below MCL: Toluene, Freon 11,
Xylenes, Benzene, Ethyl benzene and
Methylene chloride
Above MCL: Vinyl chloride
Freon 12, Freon 11, Methylene
chloride, Chloroethane, 1,2-
Dichloroethene, 1,2 Dichlorethene,
1,1,1-Trichloroethane (TCA),
Trichloroethene (TCE),
Tetrahydrofuran, and Acetone
Non-VOCs
Detected
Details/Discussion
Attributed to historical
acceptance of auto parts
Leachate observed in a
side seep
Measured in a leachate
seep (1987)
Measured in leachate
seeps (1986- 1989)
(continued)
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Table 3-2. Summary of Groundwater and Leachate Data for Rubble Landfills Analyzed by MDE
(1997a) in the Mid-1990s (continued)
Site
Number
5
6
7
8
9
Media
GW
GW
GW
GW
Leachate
VOCs Detected
Freon 11, Freon 12, Methylene
chloride, 1,1-Dichloroethane,
Trichloroethene (TCE) and Toluene
Below MCL: 1,2-Dichloroethene,
Xylene
Above MCL: TCE, vinyl chloride
Tetrachloroethene, Trichloroethene,
Freon 12, Chloroethane, and cis 1,2-
dichloroethene
VOCs detected, but no specific
chemicals listed
Vinyl chloride (45 parts per billion
(ppb))andTCE(14ppb)
Non-VOCs
Detected
"
"
Lead
Iron,
manganese,
sulfate, total
dissolved
solids
Details/Discussion
"
Data from 1992 and 1993
Data from 1990 and 1991;
trace levels detected
Data from lined C&D cell
with leachate collection;
data from 4 sampling
events from 1996- 1997
The results of the analysis conducted by MDE in the mid-1990s provided the justification for requiring
rubble landfills to be lined in the state. Recommendations that were made during hearings as part of the
rulemaking included proceeding with the requirement for liners and leachate collection systems, which
was based on the following (MDE 1997b):
Evidence from other studies conducted in the US (US EPA 1995a, US EPA 1995b) that suggested
elevated chemical constituents in groundwater can occur at unlined construction debris landfills.
The presumption that rubble waste (as defined in the Maryland solid waste rules) was inert was
identified as false, a conclusion based on data collected by MDE personnel and operating
facilities.
Data collected in groundwater samples at operating facilities showed that groundwater impacts
had occurred.
3.4.3 Review of Rubble Landfill Groundwater Evaluation Memos Written by MDE Since
the Late 1990s
MDE furnished copies of internal memoranda that are developed by MDE staff upon review of routine
groundwater monitoring data at C&D landfills. Memoranda for 11 active C&D landfills sites were
provided with summaries that spanned approximately 10 years from 1999 to 2011. These documents
generally described MDE staff interpretation of groundwater data and indicated parameters that were
elevated (when comparing a downgradient well concentration with an upgradient well concentration) and
above an applicable standard. Detailed statistical analysis was not conducted on the information in each
memorandum because of limitations of source data, but in general the information for each of the 11
landfills did not suggest that significant impacts to groundwater were occurring, and that cases where
recurring exceedances of applicable standards were either unresolved, attributed to poor regional
groundwater quality, or identified as caused by the landfill but remedial actions were taken to address the
issue. Evaluation of the information in these memoranda, when compared to information gathered by
MDE in the mid-1990s as part of rulemaking requiring liners and leachate collection systems at rubble
landfills, suggests that groundwater quality impacts at rubble landfills has declined since the
promulgation of the liner and leachate collection system rules.
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3.5 Minnesota - Groundwater Quality at C&D and Demolition Landfills
The Minnesota Pollution Control Agency (MPCA) produced a study on groundwater monitoring data
collected at 43 demolition landfills in Minnesota, eight of which only accepted demolition debris (MPCA
2003). The MPCA (2003) document provided summary statistics for 43 demolition landfills, which
included landfills that accept demolition waste only, accept demolition and industrial waste, and accept
demolition, industrial waste, and MSW. The report did not allow for the differentiation between those
sites that accepted only demolition debris and the other two types of facilities, but it is noted that the
43 landfills analyzed appeared to consist of unique cells (i.e., the site was either only demolition debris, or
had a demolition debris cell in addition to MSW cells).
The purpose of the study was to conduct a statistical analysis on historical groundwater monitoring data
and to evaluate whether groundwater was being impacted by the landfill. The study used a null hypothesis
that stated upgradient and downgradient groundwater concentration should be equal - in cases where the
null hypothesis was rejected (i.e., the data suggested, based on the Kruskal-Wallis one-way analysis of
variance test with a p < 0.05, that there was a statistical difference in upgradient and downgradient wells),
the data were further analyzed by site hydrogeologists to interpret the data and results. Measured
concentrations were further examined through comparisons to state ILs and water quality standards.
A total of seven demolition-only landfills had data sets that could be used in the statistical analysis, and of
these, five of the demolition landfills indicated groundwater impacts as measured at downgradient wells.
Additional summary statistics from the analysis are as follows:
Two of the seven demolition landfills had statistically significantly greater VOC concentrations in
downgradient wells compared to upgradient wells.
Four of the seven demolition landfills had statistically significantly greater inorganic constituents
that exceeded health-based standard, and three had constituent concentrations that exceeded non-
health-based standards.
The most commonly detected VOCs were chlorofluorocarbons.
The most commonly detected metals and metalloids were calcium, magnesium, sodium,
potassium, iron, and manganese.
The most commonly detected non-metal or metalloid inorganic constituents were sulfate, nitrate,
chloride, andTDS.
Ultimately, the MPCA concluded that demolition landfills have the ability to impact groundwater. This
led to the development of a state guidance document that provided a series of considerations and
measures intended to provide more consistency during the siting and overall operations and management
process for demolition landfill sites (MPCA 2005). Included in the MPCA guidance was the development
of a three-tier demolition landfill classification system, which allows for varying construction and
operation requirements depending on the quantity and nature of waste accepted at the site. Table 3-3
provides a summary of the three-tier classification system.
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Table 3-3. Demolition Landfill Classification System Developed as Part of MPCA Guidance
(MPCA 2005)
uemoinion Lancmn uassiricanon
Site Evaluation
Acceptable Wastes
Waste Screening
Groundwater
Monitoring
Liner
Reclassification
Class 1
Class II
Class III
All sites will need to conduct a site evaluation to verify that location standards are met,
soils are evaluated, depth to the water table is identified, and groundwaler flow direction
is defined.
From an "Acceptable
C&D Waste List'
Stringent screening
required.
Determined based
on depth to water
table and underlying
soil type.
No
N/A
From an "Acceptable C&D
Waste List" plus non-
recyclable packaging and
demolition-like wastes {e.g.,
wood, concrete, porcelain)
Screening required.
Yes
Determined based on depth to
water table, underlying soil
type, and possibly modeling
results.
All C&D Wastes plus most
Industrial Wastes
Screening required.
Yes
Yes
If the facility accepts >50% industrial waste based on annual
gate receipts, it should be reclassified as an industrial landfill.
In 2008, the Minnesota Legislature passed a bill that required a work group to advise the Legislature on
the management of C&D debris and industrial wastes, largely as a result of several factors including the
MPCA's rules and guidance regarding the management of C&D and industrial waste landfills, and
historical groundwater impacts in some areas of Minnesota (Construction, Demolition, and Industrial
Landfill [CDIL] Work Group [2009]). The Legislature also imposed a moratorium on the siting of new
landfills, pending the adoption of new rules from the MPCA regarding groundwater sensitivity and
financial guarantees at landfills.
The CDIL Work Group developed a report in 2009 that had several recommendations, including the
continued use of the demolition classification system (as shown in Table 3-3) before being incorporated
into eventual rulemaking. The CDIL (2009) document also pointed out that PER demolition landfills in
Minnesota (as described previously in Section 2) are not required to be monitored and recommended a
groundwater evaluation study to assess the impact that PER demolition landfills have had on groundwater
quality.
3.6 Ohio - Leachate and Groundwater Quality at C&D Landfills
Two large-scale studies were conducted by the Ohio Environmental Protection Agency (OEPA) regarding
environmental monitoring data collected at C&D landfills in the state. In 2005, the Ohio General
Assembly required the OEPA to revise C&D debris disposal regulations, and in response to extensive
comments received after draft rules were developed, the OEPA conducted a study to evaluate leachate
quality data from C&D landfills where data were available and compared the data to that measured from
MSW landfills in the state. A second study was conducted by OEPA (201 la) involving the examination
of groundwater monitoring data at C&D debris landfills in Ohio to understand potential impacts in
support of both previously promulgated rules related to liners and leachate collection systems at C&D
debris landfills (OAC chapter 3745-400) and draft rules OAC chapter 3745-520.
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3.6.1 C&D Landfill Leachate Study (2009)
Available leachate monitoring data from 30 landfills in Ohio were examined and compared to MSW
landfill leachate data to evaluate the potential effects of the release of C&D debris leachate into the
environment.
A total of 10 organic and 15 metals and other inorganic parameters were observed in both MSW and
C&D leachate in similar quantities. Eleven parameters were not detected, and 14 parameters were
detected with no difference in prevalence between the C&D and MSW landfill leachate. The leachate
from all 30 C&DD landfills had three to 29 parameters with measured concentrations of water quality
parameters that exceeded health based standards, surface water quality standards, or both. Health-based
standards were exceeded for 18 organic and 15 inorganic parameters in C&D debris leachate, compared
to 19 (organic) and 14 (inorganic) exceedances in MSW leachate. Table 3-4 summarizes the parameters
that were detected in similar quantities in C&D and MSW landfill leachate.
Table 3-4. Summary of Chemical Parameters Measured in Similar Concentrations in C&D Landfill
Leachate and MSW Landfill Leachate at Facilities in Ohio (OEPA 2009a)
Leachate Monitoring Parameters Measured in Similar
Concentrations in C&D and MSW Landfills
Antimony
Chromium
Iron
PH
Vanadium
2-Butanone
1,4-dichlorobenzene
Arsenic
Cobalt
Nitrate-Nitrite
Selenium
Zinc
4-Methyl-2-Pentanone
methylene chloride
Leachate Monitoring Parameters
Measured at Higher Concentrations in
C&D Landfills Than MSW Landfills
Calcium
Copper
Magnesium
Manganese
Sulfate
Four of the five parameters that were measured in higher concentrations in C&D landfill leachate were
also parameters of interest in the hydrogeologic study described below. The study concluded that both
types of leachate (C&D and MSW) are of concern to public health and the environment if released to
groundwater and surface water, and that one was not necessarily less harmful or cleaner than the other.
3.6.2 Hydrogeologic Study of C&D Landfill Groundwater Data (2011)
The hydrogeologic study examined groundwater monitoring data from a total of 99 C&D landfill sites. Of
the 99 sites evaluated, a total of 47 were considered to have substantially complete data sets that were
used for additional analysis - the OEPA considered the following when assessing whether a site had a
complete data set (OEPA 201 la):
documented groundwater monitoring information/data;
groundwater monitoring data including an analysis of key constituents over multiple sampling
events;
information related to C&D debris placement in the facility;
identified or estimated separation distance from the debris liner to the first continuous zone of
saturation (CZS)/uppermost aquifer system; and
characterization of geologic/hydrogeologic conditions at or near the facility.
In the 2011 hydrogeologic evaluation report, indications of groundwater contaminant release were
marked by evaluating background and downgradient groundwater quality, cases of increasing trends in a
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constituent's concentration, and/or the presence of VOCs in downgradient wells(s). Reported indications
of contaminant release were not regarded as confirmed releases. Of the 47 facilities with substantially
complete data sets, 60% of facilities displayed indications of groundwater quality impacts. Commonly
observed parameters included sulfate (20 sites), chloride (15 sites), ammonia (15 sites), potassium
(15 sites), sodium (13 sites), magnesium (11 sites), and calcium (11 sites). Groundwater impacts were
more likely to be observed at sites with lesser distances between the landfill bottom and the first CZS;
86% of sites with a separation distance of 5 ft or less had indications of groundwater impacts. No
indications of impact were observed at any site with a complete data set where there was a distance of
greater than 10 ft to the CZS.
Sensitive hydrogeologic settings (100 gal/min aquifer systems as designated by OAC), noted as areas
with thick glacial sand and gravel deposits, karst areas, shallow fractured bedrock, and location within an
old quarry (sand and gravel, limestone, sandstone), were also found to play a role in indication of
contaminant release. Of sites with complete data sets, 81% located in sensitive hydrogeologic settings
(25 sites, all with distances of between the water table and landfilled waste of <15 ft) showed indications
of groundwater impacts; alternatively, only 35% of sites with no indication of groundwater impact are
located in sensitive hydrogeologic areas. The presence of a bottom liner or leachate collection system
(engineering protection) appeared to mitigate groundwater impacts; of sites with complete data sets
showing impacts to groundwater (30 cases), 77% had no engineering protection, while of sites with
complete data set cases showing no impacts to groundwater (17 cases), 65% had engineering protection.
Of facilities located within 5 ft of the CZS, in a sensitive hydrogeologic setting, and employing no
engineering protection, 95% (18 total sites) had an indication of impacts to groundwater.
3.6.3 Summary
The information gathered and analyzed in the leachate study indicated that the quality of leachate at C&D
landfills in Ohio can be comparable to that of MSW landfill leachate, and for some parameters the
measured concentration may be greater. The hydrogeologic study concluded that hydrogeologic setting,
siting, and engineering controls all play a meaningful role when evaluating the potential for a C&D
landfill to impact groundwater. The OEPA further concluded that the results support the rules that are in
place requiring liners and leachate collection systems at C&D debris landfills (OEPA 201 la).
3.7 Virginia - Compliance and Enforcement at C&D Debris Landfills and
Processing Facilities
3.7.1 VDEQ Compliance and Enforcement Database
An electronic database of compliance and enforcement activities at C&D debris landfills and processing
facilities was provided by Virginia Department of Environmental Quality (VDEQ). The database included
information from active C&D landfills from 2000 to 2012 (16 sites), closed or inactive C&D landfills
from 2001 to 2006 (3 sites), and C&D processing facilities from 2001 to 2012 (18 sites). The database
included an inventory of non-compliance issues, the category or type of non-compliance, and a brief
comment section that generally included a short narrative to accompany instances of non-compliance.
The database presented all identified issues of non-compliance as "violations," though some of the
comments recognized the issue as an "alleged violation" (e.g., odor complaints related to IrkS that were
not necessarily observed by VDEQ inspectors). The number of non-compliance issues coded as
"violations" represented more than 80% of all non-compliance issues listed in the database. In some
cases, more than one violation was noted in the database related to one activity or event (e.g., a case
where acceptance of unauthorized waste was categorized as such and listed under a more general heading
of "permit non-compliance"). Efforts were made in this analysis to place a violation in the category that
appeared to best fit the violation based on the VDEQ's reference comments.
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The most frequent violations cited at active C&D landfills involved compaction and cover and permit
compliance. Compaction and cover violations were based on physical observation of a lack of appropriate
cover on waste. Multiple instances noted a "fire break" violation - of the 10 reported fire break violations,
one instance involved the observance of a fire while the majority (five of the remaining nine instances)
involved non-compliance based on related issues such as not maintaining appropriate buffers around
disposal piles and maintaining a debris pile greater than 20 ft high without compaction. Permit
compliance-related violations included exceeding permitted landfill elevations, accepting waste prior to or
after normal operating hours, and placing waste outside the permitted disposal area, among others.
At the closed C&D landfills, closure maintenance-related violations were most commonly observed and
included a variety of specific violations (e.g., implementation, inspection, post-closure). Compaction and
cover violations were based mainly on lack of a final acceptable cover system. Additionally, violations
related to groundwater monitoring were common, but mostly involved a lack of monitoring, reporting,
and access to monitoring wells. In a similar fashion, several sites had violations related to "decomposition
gas," which corresponded to a lack of monitoring rather than exceedance of a measured parameter.
Common violations identified at C&D processing facilities related to insufficiencies in written operating
plans and financial responsibility or assurance. Dust and litter were observed during multiple inspections
at facilities as well.
Table 3-5 provides summary statistics of the database and categorizes violations by type. Table 3-5
includes violations of a permitting and reporting nature of a limited number of selected categories; for
example, in the leachate category a failure to submit records of leachate removal would constitute a
leachate violation. Unauthorized waste acceptance violations of this nature at active C&D landfills
include, for example, failing to have a plan that adequately describes procedures for removal and disposal
of unauthorized waste, failure to provide training records on unauthorized waste management for new
employees, and failure to provide written records regarding a rejected waste load which contained
excessive MSW.
Table 3-6 involves counts of facilities where violations referred directly to observations by inspectors.
For example, in the leachate category, actual leachate outbreaks from side slopes were observed.
Regarding active facilities, compaction and cover violations were observed at seven active sites (ranging
from 1 to 6 violations per site), unauthorized waste acceptance occurred primarily at one site (13 of the
20 total violations) and the majority of odor, dust, and nuisance-related violations centered around one
site (18 of 25 violations).
Decomposition gas-related violations involved excessive QrU levels detected during monitoring. For
example, one gas monitoring probe indicated a reading of 12% CH4 at one site, and another site indicated
a reading of 7. 1% CH4, which exceed the VDEQ compliance level of 5% CH4 (i.e., 100% of the LEL of
CH4 in air). Compaction and cover violations often related to the observance of exposed waste with
insufficient cover, oversized working face, and insufficiently covered areas which appeared to have
reached final elevation, necessitating intermediate cover and grading to promote surface water run-off.
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Table 3-5. Summary of VDEQ Compliance and Enforcement Database for Active and Closed C&DD
Landfills, and C&DD Processing Facilities: Classifications of Administrative Violations
facility Type.'
Violation
Issue
Active LF
Closed LF
MRF/CftD
Processing
Compaction/
Cover
0
2
N/A
Unauthorized
Waste
24
2
5
Leachate
5
0
2
pecornjgo-
sition Gas
4
12
0
Designed
to Reduce
Dust, odor,
vector
1
0
6
Other
Hazard/
Nuisanse!
3
0
0
; Facility controlling nuisances v/ith methods not previously approved by VDEQ
Table 3-6, Summary of VDEQ Compliance and Enforcement Database for Active and Closed C&DD
Landfills, and C&DD Processing Facilities: Issues Observed Upon Inspection
=',
Facility
Type/
Violation
Issue
Active LF
Cfosed LF
MRF/C&D
Processing
Compaction i1
Cover
67
2
N/A
Unauthorized
Waste
20
0
1
Ftre
Prevention
g
0
Q
Observed
Fire
1
0
0
Leachate
7
0
0
Decpmppr
sitonGas
7
0
0
egos
8
0
0
4 facility may have been issued a violation based on citizen complaints and observations not necessarily observed
by VDEQ inspectors
Additional categories that made up a substantial portion of observed violations included groundwater,
financial assurance and responsibility, operator training, and site closure issues as detailed in Table 3-7.
Groundwater violations observed at active facilities included failures to assess corrective measures or
submit a proposal for presumptive remedies for statistically significant findings of regulated constituents
during groundwater monitoring, regulatory authorities being unable to assess the conditions of monitoring
wells due to lack of access roads and steep terrain, and failure to submit annual groundwater reports on
time. An instance of a statistically significant finding of a constituent above background does not
necessarily indicate a violation.
Table 3-7. Frequency of Additional Violation Categories Identified in the VDEQ Compliance and
Enforcement Database for Active and Closed C&DD Landfills and C&DD Processing Facilities
Facility
Type/
Violation
Issue
Active LF
Closed LF
MRF/C&D
Processing
Permit
Compliance
60
0
5
Financial
Responsibility/
Assurance
35
5
20
Facility
Closure
24
24
1
Record-
keeping/
Reporting/
Written
Plans or
Manuals
34
9
38
Facility
Design/
Construction
74
0
21
Operator/
Employee
Training
13
2
11
Ground-
water
9
17
0
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3.7.2 Summary
Data on active C&D landfill violations revealed a total of 424 violations at 18 facilities over an
approximate 5 year period. Closed C&D landfills were reported as having 72 violations over three
facilities. C&D processing facilities had 123 reported violations at 18 facilities. The results underscore the
challenges related to operating C&D facilities and the important role that compliance inspections have on
site operations. The results also show isolated instances where elevated levels of decomposition gas was
measured near C&D landfills, which was identified as a result of VDES's requirement to monitor such
gases at C&D landfills. The compliance and enforcement information analyzed also provides an
indication of issues that are most commonly encountered at different facility types in Virginia, some of
which relate to the broad mechanisms of damage discussed in Section 2, notably impacts that can occur
related to improper compaction and insufficient cover soil use.
3.8 Wisconsin - Groundwater and Leachate Quality at C&D Landfills
Two sources of data were examined for the state of Wisconsin: one consisted of a study conducted by
staff at the Wisconsin Department of Natural Resources (WDNR) related to groundwater quality at small
C&D landfills in Wisconsin, and the other consisted of a review of leachate quality monitoring data from
intermediate and large C&D landfills obtained through the WDNR's Groundwater Environmental
Monitoring System (GEMS). The groundwater quality study (conducted in 2007) included a very limited
amount of data and mostly presented broad summary observations and statistics. The leachate monitoring
data were downloaded, organized by site, and summarized to examine temporal trends at one site and
overall summary statistics for all sites where data were available.
3.8.1 Groundwater Data Evaluation
The state of Wisconsin regulates and classifies C&D landfills based on the accepted waste volume. Small
C&D landfills are those with a capacity <50,000 yd3. Small, unlined sites are the most common type of
C&D landfill in the state. Currently there are four intermediate (50,000 to 250,000 yd3) size facilities and
one large (>250,000 yd3) facility. In 2007, the WDNR conducted an assessment of groundwater
monitoring data collected at 52 small C&D landfills in the state. The age of the landfills examined varied,
with the oldest landfills contributing approximately 15 to 20 years of monitoring data. The study was
conducted because previous groundwater data evaluation efforts by the WDNR in 1991 and 1994
indicated that there was insufficient history of monitoring data at the small C&D landfills to observe
temporal trends in groundwater quality. However, the previous studies conducted in 1991 and 1994
showed that large C&D landfills had impacted groundwater (Kalvelage 2007).
The Kalvelage (2007) study noted that 60% of small C&D landfills in the state exhibited impacts to
groundwater (note that the term "impacts" was not clearly defined). Older landfills tended to make up a
disproportionate amount of the adverse effect cases; 71% of unlined C&D sites older than 10 years
showed adverse impacts to groundwater. Impacts were observed in 50% of cases of C&D landfills older
than 5 years. Sulfate was noted as a chemical that had elevated concentrations in the 1991 and 1994
studies, while manganese was noted as an additional chemical of concern based on the 1994 study.
The WDNR evaluated the impact of soil type, distance to the water table, and landfill age on the observed
groundwater impacts at the small C&D landfills. Twenty-six out of 39 sites situated in sandy soil showed
impacts to groundwater, while four of eight sites located in clay or silty clay soils showed impacts.
Approximately 83% (10 of 12) landfills with a separation distance of at least 50 ft to the groundwater
table showed elevated concentrations of groundwater constituents. Also, 25%, 50%, and 71% of sites less
than 5 years old, 5 to 10 years old, and greater than 10 years old were found to have impacted
groundwater, respectively.
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3.8.2 Leachate Data from C&D Landfills Evaluation
The publicly available WDNR GEMS database was used to gather data related to leachate quality from
C&D landfills. Data were available for five sites (intermediate and large sites that require leachate
collection) spanning a total of 45 unique sampling events between 2006 and 2012. The database included
3,063 measurements of 114 water quality parameters including field parameters (e.g., pH and specific
conductivity), inorganic, and organic compounds. Sixty-five parameters were detected in at least one
sample (11 parameters were detected below the limit of quantitation). The average number of years of
data available for each site was approximately 4 years, with a range of 1 year to 6 years. The database
included information on the location(s) at which leachate samples were collected - four sites listed
leachate collection system and one site listed a leachate head well as the point of collection.
Approximately 13.5% of samples (5 instances) had a field pH outside the range of 6.5-8.5 (all were less
than 6.5); the minimum pH observed was 5.71. Of the 23 inorganic constituents detected, nine do not
have current MCLs, SMCLs, US EPA aquatic life guidelines, or Wisconsin public health or public
welfare groundwater standards. Eight of 14 inorganic parameters with a regulatory standard exhibited an
exceedance of the standard at least once. Manganese (42 measurements), iron (40 measurements), and
sulfate (25 measurements) were the constituents that most frequently exceeded the corresponding
standard. Figure 3-4 presents an example series of time plots for one of the facilities that had 6 years of
leachate data. The results in Figure 3-4 show that sulfate, iron, and manganese were frequently measured
at concentrations above applicable corresponding standards. Figures 3-5 and 3-6 present plots of the
aggregated data for the detected inorganic parameters in leachate from intermediate and large C&D
landfills in Wisconsin. The aggregated data show that manganese, iron, arsenic, and sulfate exhibited a
median concentration greater than the applicable groundwater standard. These data, along with the data
shown in Figure 3-4, appear to be consistent with the conclusion of the groundwater evaluation
conducted for small C&D landfills in Wisconsin, which identified manganese and sulfate as two primary
constituents of concern.
The average median to standard ratio (from the results shown in Figure 3-5 and 3-6) was 14.3 in
instances where a parameter showed at least one exceedance of a corresponding groundwater standard.
Approximately 54% of inorganic parameter measurements with regulatory standards were detected at a
concentration greater than the Wisconsin standard. Five inorganic parameters (chromium, copper,
molybdenum, carbon disulfide, and mercury) were detected infrequently and never observed at
concentrations greater than the respective standard.
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SOOM
10000
5000
1000
500
Manganese
* *
* *
50 ng/L
1
c -,
Iron
0.3 mg/L
10
2006 2007 200S 2009 2010 2011 2012 2013 2S06 2007 2sas ^^ ^^ S011 2012 2°
Time Time
50M-
1000
500-
::.
f:
:.
Sulfate
250 mg/L
2 non-ddect readings
2006 2007 200S 2009 2010 2011 2012 2015
Time
Figure 3-4. Temporal Variation of the Most Commonly Observed Leachate Parameters at One C&D
Landfill Site in Wisconsin Compared to Corresponding Constituent Target Levels
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EPA/600/R-13/303
Data Gap Analysis and Damage Case Studies for C&D Debris Facilities
-54-5
1et4
=+;
e+-
Manganese
T
1
Leach ate
>»:
5»
a 100
10
Sulfate
Leachate
50 ug/L
250mg/L
10 -
0.1 -
1. -I- -
Ammonia
1
T
1
t
*
1000-
100-
J
? 10-
0.1 -
Iron
.
*
T
i. 0.3 mg/L
*
Leach ate
-::
Chloride
i"r
Leach ate
100-
n i -
Arsenic
*
t
10 ug/L
*
*
Leachate Leachate
Figure 3-5. Inorganic Parameters Measured in Leachate from Wisconsin C&D Landfills
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100
32 10 -
1 .
10000
1000-
_, 100.
E
10 -
1 .
0.1 -
10000
1000
100
11
Lead
*
t
J.
1 5 LL'3/L
Leachate
BOD- S Cay
i
I
*
Leadote
Tola K*-:a
1
*
Lea,hate
10-
1
a
0 1 -
IQttX
1QH
1
DO
IOC
1C
CaAnkm
I
COD- U-f ts's-: t
T
1
4
Leachate
1000 -
01 100-
10-
1 .
Sod On
4
*
*
LeadBte
Figure 3-6. Summary of Inorganic Parameters Measured in Leachate
from Wisconsin C&D Landfills
Figure 3-6. Summary of Inorganic Parameters Measured in Leachate
from Wisconsin C&D Landfills
Figure ^-/presents a summary of detected VOCs in leachate. Approximately 87 % of the organic
compound measurements were below the laboratory detection limit (1,983 below detection limit). Of the
detected organic compounds, toluene (32 measurements), fluorotrichloromethane (30 measurements),
naphthalene (20 measurements), and tetrahydrofuran (17 measurements) were the constituents most
commonly detected. Only the median concentration of tetrahydrofuran however, exceeded the regulatory
standard (approximately 4 times greater).
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, _-__
Figure 3-7. Organic Parameters Measured in Leachate from Wisconsin C&D Landfills
Figure 3-7. Organic Parameters Measured in Leachate from Wisconsin C&D Landfills
3.8.3 Summary
The ground-water monitoring data collected at small C&D sites in Wisconsin suggest that impacts have
occurred at several sites. The observed impacts have been seen in cases where the natural soils include
clays and silty clays and where the travel distance to the groundwater table is fairly large. Fairly limited
information was available regarding the magnitude of impacts to groundwater as well as the specific
constituents of concern, though sulfate and manganese were two parameters mentioned. Several years of
monitoring data of collected leachate at five C&D sites suggested leachate quality showed the median
concentrations of iron, manganese, sulfate, arsenic, and tetrahydrofuran exceeded the corresponding
regulatory limit in instances of detection for the entire data set. The detections of sulfate and manganese
are consistent with the results of the small C&D landfill groundwater evaluation.
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4. Detailed Damage Case Evaluation
4.1 Overview and Methodology
The previous two sections (Sections 2 and 3) presented information regarding damage at C&D facilities
in a progressively more detailed manner. Section 2 presented an inventory of damage sites based largely
on feedback and information gathered from state solid waste regulatory personnel, and Section 3
presented an analysis of large-scale summary statistics on actual or potential environmental impacts or
damages based on reports prepared by state regulatory agencies or available environmental monitoring
data. In this section, damage is evaluated in a more acute manner by evaluating three specific instances of
damage at the facility level. The examination of specific facilities allows for a more complete picture of
environmental damage and provide context regarding the causes of damage (e.g., whether damage was
the result of permit non-compliance).
The three sites were selected following discussions with and feedback from the US EPA regions and the
US EPA Office of Resource Conservation and Recovery on routine conference calls during the project.
Criteria for selection included (1) whether a given site had substantially available information regarding
operations, monitoring, and permits; (2) geographic distribution; and (3) prevailing or primary damage
type. The selected sites and basic information regarding their location and identifying information is
provided in Table 4-1. Available information about each site was gathered and evaluated with respect to
several potential "damage" indicators. The information evaluated for each site included the following:
overview of the site/history,
operations information and permit-related information,
documentation of environmental damage, and
applicable regulatory and/or remedial actions.
In contrast to the US EPA (1995b) damage case evaluation (which primarily evaluated groundwater and
surface water impacts at C&D debris landfills), the damage assessment in this project was conducted
using a multimedia approach, which included evaluating impacts to water and air, as well as examining
more local impacts such as fires. The sites selected for analysis meet the criteria that were used to define a
facility as a "damage" site as described in Section 2.1.
Table 4-1. Summary of Detailed Damage Case Sites Selected and Corresponding
Identifying Information
Site Name
Saufley Landfill
Archie Crippen
Excavation Site
Warren Landfill
and Recycling
Facility
Primary Site
Type
C&D Landfill
C&D
Recycling
Facility
C&D Landfill
Site Location
Pensacola,
Escambia
County, Florida
Fresno, Fresno
County,
California
Warren, Trumbull
County, Ohio
Identifying Information
Primary damages include hhS emissions, groundwater
impacts, and fires
Primary damage includes fires
Primary damages include hhS emissions and groundwater
impacts
The information presented in this section was gathered from a variety of sources, including
scientific literature,
regulatory guidance documents,
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health consultations,
site permits and regulatory submittals,
regulatory inspections, and
auditor reports.
4.2 Damage Case 1: Saufley Landfill (Escambia County, Florida)
The Saufley C&D Landfill (site) accepted debris between 1990 and 2006. The primary issues associated
with the site include emission of FfcS from disposed drywall in the landfill and particulates from fires that
occurred at the site. Approximately 2,000 residents lived within a 1-mile radius of the site, and several
dozen reported inhalation-related health effects to the local health department. There has also been
observation of groundwater impacts based on several years of monitoring data as well as historical off-
site stormwater and sediment transport. An order to close the site was issued by FDEP in 2008, but the
site owner did not complete the necessary actions and abandoned the site. Escambia County took
responsibility to close the site, and closure activities at the site are ongoing as of 2012.
4.2.1 Site Description
The site is an approximately 23-acre unlined C&D debris disposal facility located in Pensacola, Florida. It
is bordered on three sides by varying-density residential areas, and is bounded on the west by Saufley
Field Naval Air Base. The grades surrounding the landfill are at approximately 85 ft National Geodetic
Vertical Datum (NGVD) while the highest site elevation (top of landfill) is approximately 130 ftNGVD.
Previous documentation (Condor Earth Technologies 1998, Gallet and Associates 2003) indicates the site
was previously used as a sand borrow pit which was about 30 ft deep, suggesting waste at the site may be
up to 75 ft thick. Figure 4-1 presents the layout of the site showing the approximate location of the
groundwater monitoring network.
The soil underlying the site consists of the Florida Gravel-and-Sand Aquifer of the western panhandle,
which is comprised of three layers (or zones) including a surficial zone (Wilkins et al. 1985, Roaza et al.
1993, Condor Earth Technologies 1998). A total of nine groundwater monitoring wells were installed
within the surficial zone; groundwater sampling has occurred semiannually since 1999.
The site was operated as a sand mine for some time prior to 1968 until about 1981 (Gallet and Associates
2003). The site first started accepting C&D waste in 1990. Records from 1999 to 2003 show an annual
waste acceptance rate of approximately 40,000 tons per year, but Hurricane Ivan in 2004 and other
tropical storms resulted in a significant increase in waste acceptance at 400,000 tons in 2004 and
250,000 tons in 2005. Approximately 120,000 tons of waste were accepted in 2006 prior to the site
closing on August 8, 2006. On March 4, 2008, due to failure to close the site in accordance with various
court orders and deadline extensions, the Florida Department of Environmental Protection (FDEP) issued
a Final Order of Abandonment.
Escambia County assumed responsibility for the site August 24, 2009, through a Prospective Purchaser
Agreement to implement closure and post-closure construction and monitoring activities after
abandonment by the previous owner. Part of these closure activities will include the relocation of
approximately 200,000 yd3 of waste to reduce the height of the fill, and site closure according to Florida
Administrative Code (FAC) 62-701.730(9)(b), which includes bringing the side slopes to maximum 3:1
(horizontal to vertical) grades, installing an artificial turf-covered geomembrane, and completing a
stormwater management system to prevent runoff and provide erosion control. Final closure activities
were initiated mid-2012.
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SAUFLEY
LANDFILL
£
Figure 4-1. Site Layout Showing Approximate Location of Groundwater Monitoring Wells (Aerial
Imagery from FDEP Bureau of Survey and Mapping, December 2009)
4.2.2 Regulatory and Compliance History
Florida C&D debris landfills are regulated according to 62-701.730, FAC, which includes semiannual
groundwater monitoring, waste compaction and grading, final cover installation, waste screening,
stormwater management, and odor control. As discussed in Chapter 2, Florida solid waste regulations do
not require the installation of bottom liners and leachate collection systems unless the FDEP demonstrates
that site-specific conditions require these systems. Florida solid waste rules for C&D landfills do not
specify a minimum operational cover soil requirement, but the site had a specific condition in its 2002
operations permit that required application of soil cover on a weekly basis.
The following sections provide a discussion of major milestones and relevant compliance-related issues at
the site based on a review of site records, permits, inspection documents, and related information.
7988-7995
C&D debris placement into the excavated sand pit began in approximately August 1990 when the Florida
Department of Environmental Regulation issued a General Permit to Operate a Construction and
Demolition Debris Disposal Facility, which followed an Escambia County October 1988 issuance of a
Permit to Operate a Solid Waste Management Activity. From 1990 to 1995, the most common non-
compliance citations recorded during regulatory inspections were the acceptance, disposal, and/or storage
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of unauthorized, non-C&D debris waste (e.g., white goods, clothing, residential garbage, and vegetative
debris), the deposition of "unclean" (non-inert) C&D waste in standing water at the site, and inadequate
site access control. Based on a review of inspection report narratives, it appears that standing water
located on the bottom of the site's pit floor occasionally represented the groundwater table.
7995-7999
Non-compliance issues involving the acceptance and disposal of unauthorized waste, as well as non-
"clean" waste deposition in standing water continued, though additional efforts to address these instances
of non-compliance were noted on inspection report logs. The first discovered instance of an off-site odor
complaint was documented in July 1998, but after the application of cover soil and lime, FDEP inspectors
recorded that odors were no longer detectable in August 1998.
2000-2004
Instances of operating with steep operating slopes were first indicated during this time period. In February
2000, FDEP inspectors noted that side slopes were steeper than 3:1 (note that while current FDEP rules
require operating slopes at C&D landfills to be less than 3:1, the rules at the time only required side
slopes at 3:1 at the time of closure).
A landfill fire was documented in an FDEP inspection on 18 June 2000, but was brought "under control"
by June 20, 2000, and "no evidence of smoke or fire" was found in follow-up inspections on June 27 and
29, 2000. An FDEP inspection noted that "a lot" of water was used in initial efforts to extinguish the fire.
Prohibited waste acceptance continued to be the primary non-compliance issue noted in FDEP inspection
reports until May 2002. FDEP inspection logs mention that on November 17, 2002, another subsurface
fire started that did not appear to be extinguished until January 6, 2003. Following this landfill fire event,
frequent odor complaints from nearby residences occurred through April 2003. In October 2003, FDEP
recorded two additional complaints regarding odor, noise, and dust emissions from the site.
Numerous instances of failure to apply weekly cover and control the size of the working face were
documented starting in 2003, which is likely attributable to the large increase in waste acceptance
resulting from Hurricane Ivan and tropical storms during this time.
2005-Present
A Notice of Violation (NOV) was issued by FDEP in February 2005 requiring a small working face to
minimize waste and stormwater interaction, apply weekly cover, and implement corrective actions
concerning groundwater contaminants that were discovered beyond the property line (constituents
included iron, aluminum, manganese, and TDS). The NOV was followed by a Final Order which required
the site to conduct a contamination assessment. The site owner/operator at the time agreed to submit a
Site Assessment Report following a consent order issued in May 2005.
In June 2005, the site had exceeded the permitted design elevation of 120 ft NGVD and side slopes were
steeper than 3:1. On 21 November 2005, a fire was reported by a site operator. On 5 January 2006, the
Escambia County Health Department issued a Health Advisory as a result of smoke emissions from the
fire. On January 23, 2006, a consent order was signed requiring fire extinguishment prior to 16 February
2006 and grading of side slopes to less than or equal to 3:1. From January 23 to 25, 2006, the US EPA
performed ambient air tests to measure concentrations of multiple air pollutants - a health consultation
that used these sampling results indicated H2S concentrations were not low enough to ensure the
protection of human health (US EPA 2006a). The November 2005 fire was documented as extinguished
on February 20, 2006.
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A court order was issued that required the site to lower the elevation of the waste to below the permitted
120 ft NGVD, close the landfill, and provide topographic surveys to demonstrate that the required waste
elevations had been achieved. A fire broke out on August 28, 2006, during waste leveling and onsite
relocation activities and reportedly smoldered for about a month.
The Florida Department of Health (FDOH), in cooperation with the Agency for Toxic Substances and
Disease Registry (ATSDR), executed an ambient air monitoring program to measure H2S and particulate
matter (PM) concentrations using a combination of stationary and personal badge monitoring devices in
October 2006 (more details on the results of this study are presented in Section 4.2.3).
Strong odors were reported by FDEP inspectors following the fire that occurred from November 2006
through March 2007. From April 2007 to February 2008, the site operator attempted to close the site by
attempting to lower the waste elevation to 120 ft NGVD, installing a final cover, and constructing a
stormwater management system. During this time period, there were several reports and inspections that
documented stormwater runoff and cover soil washing onto adjacent properties and roads. Odor
complaints continued throughout this period.
In February 2008, the FDEP issued a Final Closure Order requiring the facility to be closed within
21 days. When the operator failed to initiate closure activities or request a time extension within the
21-day deadline, the FDEP issued a Final Order of Abandonment. Subsequent to the Final Order of
Abandonment, Escambia County acquired the property and took responsibility to address the issues at the
site.
Figure 4-2 presents a timeline of key events at the site, including non-compliance events, major storm
events, and related site activities.
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Figure 4-2. Timeline of Non-Compliance and Hurricane Events for the Saufley Landfill (Bars Represent Recurring Non-Compliance
Issues as Noted in FDEP Inspection Logs)
Halltr nt VWWlw H*ut4 (
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4.2.3 Discussion of Damage
This section presents a discussion of damage based on review of information from the site, with particular
focus on groundwater impacts as demonstrated by routine monitoring data, odors caused by IrkS
emissions, and issues associated with landfill fires.
Groundwater Impacts
Groundwater has historically flowed from north to south across the site, though several contour plots
included in semiannual groundwater monitoring reports (e.g., fall 2004, spring 2006) have suggested
occasional flow towards the southeast or southwest.
Table 4-2 presents a summary of groundwater monitoring data for the parameters that exceeded the
GCTL at least once between spring 1999 and spring 2012. During the sampling period, a total of
17 constituents were measured at concentrations that exceeded the respective GCTL; however, five of the
17 constituents measured above the GCTL were observed only at off-site wells, thus Table 4-2 only
presents the remaining 12 parameters that exhibited an exceedance at on-site compliance wells. There are
two background wells for most of the historical sampling period, MW-3 and MW-6. Well MW-3 is
located in the northwest portion of the site and has been identified as potentially impacted by historical
waste disposal activities at the parcel to the north.
Table 4-2. Summary of Parameters Exceeding GCTLs at Groundwater Monitoring Wells
at the Saufley Landfill
Monitored Parameter
Ammonia - N
Sulfate
Sodium
Total Dissolved Solids
Aluminum
Arsenic
Barium
Cadmium
Iron
Lead
Manganese
Phenols, Total
Units
mg/L
mg/L
mg/L
mg/L
mg/L
ug/L
ug/L
Mg/L
mg/L
Mg/L
mg/L
Mg/L
GCTL1
2.8
250 (S)
160
500 (S)
0.2 (S)
10
2,000
5
0.3 (S)
15
0.05 (S)
10
Number of Measurements
(Exceedances of GCTLs)
Background
34(9)
37(1)
34
37(13)
36(6)
36(7)
6
34
37(17)
33(1)
8(4)
25(2)
Compliance
58 (52)
62(8)
58(4)
62(45)
61(12)
61(10)
10(1)
58(1)
62(62)
58(1)
12(12)
39(3)
Off -site
4(2)
20
4
20(9)
11(5)
8(1)
0
4
20(19)
4
7(6)
-
Note: 1. (S) Denotes a secondary drinking water standard.
A comparison of data presented in Table 4-2 indicates that impacts from landfilling on groundwater
quality occurred. Ammonia, iron, and manganese exceeded the GCTL in 90%, 100%, and 100%,
respectively, of all measurements in downgradient wells.
A variety of factors not necessarily related to compliance likely contributed to the groundwater impacts
observed at the site. First, the landfill was not constructed with a bottom liner or leachate collection
system, thus no substantial barrier between the bottom of the waste and the surficial aquifer was present.
Second, the site was originally built on a sand and gravel pit in a hydrogeologic setting that would not be
expected to slow down percolation of chemicals that may leach from the waste mass. These two factors
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are consistent with the factors identified in Section 3 as having a substantial impact on groundwater
quality observed at C&D debris landfills.
The review of historical operating and inspection records for the site also indicates that several non-
compliance issues may have contributed to groundwater impacts at the site, including:
Unauthorized waste acceptance. FDEP inspection logs frequently indicated prohibited waste
acceptance between 1990 and 2002. Examples of prohibited wastes accepted included white
goods (i.e., appliances) and residential garbage.
Placement of waste within standing water. Non-"clean" debris was frequently cited in historical
inspections between 1990 and 1996 as being placed in standing water.
Recurrent fires at the site which necessitated the use of a large amount of water to extinguish the
fire. The addition of large volumes of water, coupled with the frequently cited cover soil
application deficiencies, likely contributed to a greater amount of liquids percolation through the
landfill than would have occurred had recurrent fires not been an issue. The presence of a greater
amount of liquid percolating through the waste mass would be expected to generate larger
volumes of leachate, thus exposing the underlying aquifer to a greater amount of leached
chemicals from the waste mass.
While the factors described above demonstrate factors related to non-compliance that may have
contributed to the impacts to groundwater that were observed, it is noted that several of the constituents
that were measured in concentrations exceeding the GCTL (e.g., sulfate, iron, manganese, and arsenic)
are consistent with those identified in C&D landfill leachate (e.g., in the Ohio study) and in groundwater
near C&D debris landfills as detailed in Section 3. Thus, the groundwater impacts observed at the Saufley
landfill may have occurred regardless of whether the facility had the non-compliance issues described
above.
Odors and Particulate Emissions
Numerous odor complaints as a result of IrkS emissions as well as the presence of fires occurred at the
site during its operational life. The first recorded odor complaint was in July 1998, but after the
application of dirt and lime to the area, no odor was detected during a follow-up inspection 2 weeks later.
The next period of recurrent odors began in late 2002 at the time of an extended fire event. Odors were
also reported multiple times between September and October 2003. The most recent and prolonged
instance of odor complaints followed a 3-month fire event that began in November 2005. Odor
complaints were received intermittently following this fire until September 2008. Figure 4-3 presents an
aerial image of the site showing the locations of residents that filed odor complaints recorded by FDEP
between 2002 and 2008. Complaints were submitted by residents as far as a half mile away from the site.
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Saufley
Landfill
Figure 4-3. Odor Complaints from Residences Near the Site Between 2002 and 2008 Based on
FDEP and FDOH Inspection Logs
During a February 2, 2007, complaint-related inspection event, FDEP and FDOH officials met at the site
to investigate reports that landfill operators fell ill with nausea and headaches due to H2S exposure
(FDOH 2007). The H2S meter brought to the site was non-functional and could not accurately measure
ambient concentrations; however, 10 minutes following the site visits, it was noted that FDEP inspectors
felt nausea and experienced headaches.
Table 4-3 presents a summary of five H2S monitoring events or periods that occurred between January
2006 and May 2012. The data show varied results based on the type of instrument used, the location of
sampling, and time period when monitoring took place. The maximum measured concentrations were
observed in early 2007, with concentrations as high as 140 parts per million (ppm) at the landfill surface
and 10 ppm at the site perimeter. The World Health Organization (2003) indicates that concentrations of
H2S greater than 100 ppm can cause olfactory paralysis, which is particularly problematic in that levels
exceeding the point of olfactory paralysis can inhibit a human's ability to detect even more harmful
concentrations (e.g., H2S concentrations greater than 500 ppm can cause death [World Health
Organization 2003]).
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Table 4-3. Summary of
and Other Air Quality Parameter Monitoring Events
at the Saufley Landfill
Dat6 or
Date
Range
23-27
Jan. 2006
22 Oct.
2006 - 8
Feb. 2007
5 Feb.
and 21
March
2007
8, 9, 26
Feb. 2007
Sampler and
Data Source
US EPA On-
Scene
Coordinator
Readiness
Task Force
(US EPA
2006a)
FDOH (2007)
ATL, Inc.
(Escambia
County Circuit
Court (2007a,
b))
Escambia
County
Department of
Health
Location
Site boundary,
surrounding
communities
Surrounding
residential
areas
Inside onsite
excavator,
outside onsite
excavator,
landfill surface,
landfill
perimeter
Areas
surrounding
landfill (Metzler
(2007); Pearce
(2007); Rivers
(2007)
H2S
Monitoring
Equipment
Hand-held
meter
(MultiRae)
Fixed
position
monitors,
personal
badges
Hand-held
meter
Hand-held
meter
Max. H2S
Concentration (ppb)
No Detections
224 (fixed
monitors)
123 (personal
badaes)
UUUX.J T-t^J J
20,000 (inside
excavator)
120,000 (outside
excavator)
140,000 (landfill
surface)
10,000 (landfill
perimeter)
120 (east of landfill)
Discussion
Testing occurred after
fire event, included
measurements of
carbon monoxide
(CO), sulfur dioxide,
volatile organic
compounds, PM, and
asbestos - results
were generally below
detection limit, but the
study concluded H2S
concentrations were
not low enough to
ensure protection of
human health.
ATSDR concluded the
site presented a
"public health hazard",
defined as "sites that
have certain physical
features or evidence
of chronic, site-related
chemical exposure
that could result in
adverse health
effects" (ATSDR
2006).
From a review of
reference
documentation, it
appears that the two
highest readings listed
during this monitoring
event were taken from
within 1 ft of the
landfill surface.
It is unknown the
exact locations where
sampling took place.
The occurrence of fires and the emission of Irk
below.
were likely caused by a variety of factors, as discussed
Cover Soil Application. The site was required to apply cover soil at least weekly for the bulk of
the operating period examined. Using cover soil reduces rainwater infiltration into the waste and
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acts as a barrier to trap or remove H2S (as discussed by Townsend et al. 2004c, Plaza 2007, Xu et
al. 2010a, Xu et al. 2010b), and routine use of cover soil can help prevent fires by creating a
barrier that limits air infiltration into the waste mass. One of the most frequently cited non-
compliance issues at the site was the failure to adequately apply cover soil.
Large Working Face. The site was required to maintain a small working face to avoid large areas
of exposed waste. However, a frequently cited compliance issue related to maintaining a large
working face. A large working face allows a larger area to be exposed to rainfall (thus
introduction of moisture into the waste, which can contribute to H2S emissions as described
previously). Also, a large working face can allow the waste to be exposed to oxygen, which can
be problematic if a surface or subsurface fire is occurring.
Steep side slopes. The presence of steep side slopes, coupled with a lack of cover soil, creates a
condition where prevailing winds can infiltrate side slopes and create a chimney effect, thus
potentially exacerbating fire issues. Steep operating side slopes at the site were noted in FDEP
inspection logs as far back as 2000. The use of steep operating side slopes, however, was not in
violation of FDEP rules or the site's permit.
Inspection and monitoring records related to PM measurement are limited. As Table 4-3 shows, PM
testing was conducted in early 2006 at the site, but the results did not indicate high PM levels (the highest
reading was 567 (ig/m3 in a 5-minute time-weighted average [TWA] reading, less than the ATSDR action
level of 3,500 (ig/m3 for black smoke). The US EPA (2006) evaluation indicated that the short duration of
sampling suggested the results were not likely representative of the conditions experienced in the
atmosphere near the landfill during the previous fire events, some of which had lasted months. A
summary of documented observations of fire at the site are summarized in Table 4-4.
Table 4-4. Summary of Landfill Fire Observations Noted in Inspection
Reports and Approximate Duration Until Fire Was No Longer Observed
at the Saufley Landfill
Approximate Time Fire First Observed
June 2000
November 2002
November 2005
June 2006
August 2008
Approximate Duration Until
No Longer Observed
Fire
< 1 Month
3 Months
3 Months
< 1 Month
1 Month
Based on the odor and fire issues observed at the site, these problems were caused by a combination of
factors, some of which did and some of which did not relate to facility non-compliance. The presence of
drywall (which is a common component of C&D debris), the percolation of moisture into the waste, and
other conditions typical of C&D landfills would likely have caused the formation and emission of H2S at
the site. However, the recurring cover soil application non-compliance as well as noted events where
large amounts of moisture were introduced into the landfill as part of fire-fighting caused conditions
conductive to the formation and emission of H2S to be exacerbated.
As for fires, the exact cause of fires in the waste was not clearly identified in inspection reports (though
previous operations plans for the sites suggested the receipt of "hot loads" may have contributed to the
fires), so it cannot be said with certainty whether the landfill fires that occurred were a direct result of
non-compliance or would have occurred anyway. The routine presence of steep slopes, which were
allowable at the site per the facility's permit, coupled with the large amount of waste accepted in the 2004
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to 2005 timeframe, which appeared to preclude appropriate compaction of the waste, likely were strong
contributing factors to the site's prolonged fire issues.
Site Damage Summary
Table 4-5 depicts a summary of the environmental damages noted at the Saufley Landfill and some
potential non-compliance issues that may have contributed to their development. The information in
Table 4-5, which is based on the discussion provided previously, indicates that the damage observed at
the site resulted from normal operations (i.e., operations that were in compliance with the facility's
permit) and from the site failing to comply with some conditions of its permit. The magnitude of impacts
observed was likely augmented by the facility's non-compliance. Although the costs related to addressing
odors and other damages from the site are not known, Escambia County contracted to close the landfill in
accordance with FDEP rules. Closure activities are ongoing, but the estimated cost to close the site, which
includes debris removal, stormwater management area construction, and final cover installation, is
expected to be $6 million (Page 2011).
Table 4-5. Summary of Site Environmental Damages and Potential
and Not Related to Facility Non-Compliance at the
Contributing Factors Related to
Saufley Landfill
Damage
Contributing Factors Not Related to
Facility Non-Compliance
Contributing Factors Related to
Facility Non-Compliance
Groundwater Impacts
Lack of bottom liner and leachate
collection system
Hydrogeology of the site (permeable
surficial aquifer)
Chemical nature of C&D waste
(observed at other sites in other states
as detailed in Chapters)
Prohibited waste acceptance
Fires (water used to fight fires)
Waste placed in standing water
Improper cover soil application
Large working face
Odors/Particulate
Emissions/Fires
Steep side slopes
Bulky, rigid nature of C&D debris
Presence of gypsum drywall in waste
stream, which is typical of C&D debris
Improper cover soil application
Large working face
Possible acceptance of "hot loads"
4.3 Damage Case 2: Archie Crippen Excavation Site (Fresno County,
California)
The Archie Crippen Excavation site was a 27-acre C&D debris processing and recycling facility located
in Fresno, California, that primarily processed wood, concrete, and asphalt for recycling. The site began
operating in 1980 as a processing, recycling, and storage facility for concrete and asphalt under a
conditional use permit (CUP) issued by Fresno County (CIWMB 2003a). In January 2003, a fire broke
out on a 5-acre, 20-ft high woody debris pile. Initial firefighter response appeared to extinguish the fire
within a day, but significant subsurface combustion was apparently ongoing prior to discovery of the
surface fire - ultimately, the surface fire re-emerged later, on the evening it was first discovered, and its
intensity escalated quickly. Despite significant fire-fighting efforts, the pile burned for approximately
another month, requiring a unified command response team that included fire fighters, the California
Integrated Waste Management Board (CIWMB), US EPA, and others. The City of Fresno declared a local
state of emergency and the Fresno Unified School District curtailed sports, recess, and outdoor physical
activities during the period while the fire burned. After several additional months of site monitoring and
remediation, all debris was removed from the site and the site was closed.
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4.3.1 Site Description
The former Archie Crippen Excavation Site (site) is located in southwest Fresno, California, and is
bordered by two roads to the east and south and by various businesses and households to the west and
north. There are 471 households and one school located within a mile of the site (US EPA EJView 2012).
In 1980, the site received a conditional use pemit (CUP) from Fresno County to operate a 12 acre site as a
concrete and asphalt processing facility and accept concrete, asphalt, and Group 3 wastes. Group 3 wastes
are defined in the original CUP as:
nonwater soluble, nondecomposable inert solids, examples include but are not limited to:
Construction and demolition wastes such as earth, rock, asphalt paving
fragments, inert plastics, plasterboard, and demolition material
containing minor amounts of wood and metals.
The phrase "minor amounts of wood and metals" was further defined as:
... approximately ten percent (by volume) of the total. Earth and rock from construction
activities is considered waste if there is a potential for transport from the site to waters of
the State.
The operation plan for the facility shows that broken concrete and blacktop were crushed for resale to
contractors. The original CUP was amended in 1982 to expand the working area and in 1983 the property
was annexed into the City of Fresno. When the city annexed the property, the City of Fresno accepted the
CUP without modification (CalRecycle 2004). At the time, there was no thorough review of business
CUPs that were annexed into the City of Fresno (City of Fresno 2003). In 1994, the site was expanded
onto an adjacent 15-acre parcel and the CUP was modified accordingly, with a total facility area of
27 acres. The site remained under the regulatory oversight of the Local Enforcement Agency of the City
of Fresno, with minimal regulatory or enforcement action and inspections occurring on a "complaint
only" basis for recyclable material operators, as per the City's Planning and Development Director (City
of Fresno 2003).
The 27-acre parcel was divided up into distinct waste handling areas including wood processing, inert and
metal processing, and mixed C&D processing (CIWMB 2003a). See Figure 4-4 for an aerial view of the
site as of August 2002. During operations, the processing areas contained different amounts of materials
that were either processed or waiting to be processed.
4.3.2 Compliance History
As previously noted, the site generally operated for several years with minimal regulatory oversight,
owing primarily to the lack of statewide C&D processing and recycling rules as well as local issues. A
timeline of major events at the site including compliance is provided in Figure 4-5.
A July 2001 inspection indicated no operational issues, but a fire at the site was noted in February 2002.
Inspection records indicated concerns with the acceptance of unauthorized waste in August 2002, and in
January 2003, the major fire broke out that encompassed a woody debris pile that encompassed
approximately 5 acres. In May of 2003, the City of Fresno revoked the site's CUP for failure to comply
with CUP conditions, specifically the provision that required operations to be "... limited to processing of
concrete, asphalt and other Group III materials." The site had accepted materials such as auto wrecking
junk, scrap iron, and excessive quantities of wood - the amount of wood at the site was estimated to
comprise approximately 40% to 90% of the waste on site, far more than the 10% specified in the original
CUP's definition of Group III materials. Furthermore, the CUP had a condition that allowed for a
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maximum of 180 days of debris storage, but findings at the site indicated some debris had been present
for at least 7 years. Another CUP violation included the violation of the uniform fire code (UFC). The
UFC was adopted by the Fresno Municipal Code and includes requirements for access and water supply.
and requirements for storage and processing of wood chips and debris (UFC 902.1, 903.1, 3008.1, 10
3.4.3.2, 103.4.3.3).
Figure 4-4. Aerial View of Archie Crippen Excavation Site as of August 2002 (Google Earth 2012)
4.3.3 Damage Assessment
On January 11, 2003, a fire was discovered in the main pile at the site in the 5-acre C&D debris storage
pile on the west side of the property. The Fresno Fire Department (FFD) responded to the fire and after
nearly 14 hours of firefighting, the fire was considered contained and firefighters left the site. Shortly
after leaving the site, FFD received multiple phone calls indicating that the debris pile was on fire again,
with reported large flames and heavy smoke. FFD was dispatched back to the site later that evening.
On January 13, the Air District issued an advisory due to high PM (2.5) levels, as well as an NOV due to
numerous smoke complaints (US EPA 2003a, California State Auditor 2003). On January 14, the
assistance of the CIWMB was requested as the fire intensified. CIWMB subsequently requested aid from
the US EPA for air monitoring support. FFD did not have experience combating a fire of that size and
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magnitude, thus the Office of Emergency Services was called in (CIWMB 2003a). A Unified Command
was established to combat the fire and monitor the site, which involved the City of Fresno, Fresno
County, CIWMB, US EPA, and the San Joaquin Valley Air Pollution Control District. During the main
firefighting efforts, CIWMB funded the heavy equipment operations; the City of Fresno provided
firefighters, and the US EPA provided air monitoring and health and safety support. A Joint Information
Center was established to better communicate information to the media, and develop fact sheets and
appropriate news releases. On January 23, both the city and county declared a local emergency
(California State Auditor 2003).
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r Conditional Use Permit Approved
11/1/80
1^- Owner receives license to
^ operate
1/1/82
r Annexed by City of Fresno
7/1/83
an
1980 1983 1986 1988
rC ty Code Enforcement Inspection
of Site (Zoning)- No Action
7/1/01
r Expansion of Operations
7/1/94
^flre
~ 2/20/02
- . Concerns Over Unauthorized
Waste Acceptance
8/1/02
i si*
1991 1993 1996 1998 2001
City of Fresno Addresses Wood Storage Sites Through Zoning/Conditional Use Permits
Development of State-Wide Regulations for C&D Processing Facilities
1995 - 2000
' 1997 - 2003
Fire | 1/11/03 - 2/11/03
Cleanup and Removal of Debris from the Site | I 7/25/03 - 9/19/03
Figure 4-5. Compliance and Event Timeline at the Archie Crippen Excavation Site
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Figure 4-6. Aerial View of the Archie Crippen Excavation Site Fire as of
January 2003 (US EPA 2003a)
An aerial view of the fire at the site is provided in Figure 4-6. Throughout the firefighting efforts, US
EPA periodically conducted sampling of pile and perimeter emissions (US EPA 2003a). Air monitoring
was also conducted throughout the entirety of the event. Fixed equipment and personal badges were used
for carbon monoxide (CO), H2S, and PM sampling. Volatile organic compounds (VOCs) were sampled
from vents, on site, and off site at nearby schools. Metals were also sampled on site and off site at
schools, while asbestos was monitored on site only. The air sample results showed that there were no
toxic fume dangers, however PM and smoke irritants were present. The smoke and soot from the fire
exacerbated Fresno's air quality, as the fire produced a cloud of smoke over the metropolitan area of
Fresno, which impacted the most proximate neighborhood. Soot was found to be deposited on cars and
homes within 1 mile of the site (California State Auditor 2003). During the first week of the fire, the
Fresno Unified School District canceled all outdoor activities due to the health advisory from the San
Joaquin Valley Air Pollution District from January 14 through January 16 (California State Auditor
2003). On January 25, a health screening was held at a nearby school, where volunteer medical experts
interviewed residents, many of whom were found to have irritation and respiratory tract inflammation of
because of the high levels of PM emitted (City of Fresno 2003).
Nearly 1 million gallons of water were used daily in firefighting efforts (CIWMB 2003a). Berms were
built around the pile fire area to contain the large amounts of water applied to the pile (US EPA 2003b).
CIWMB also had a mitigation plan in case issues with water retention arose; a pumping plan was in place
to prevent off-site migration of the waters. The Fresno Regional Quality board conducted a preliminary
assessment on the water runoff from the firefighting efforts and reported that there was little impact to
ground or surface water (California State Auditor 2003). After approximately a month of continuous
burning, the fire was extinguished in February 2003.
There were several factors that allowed the fire at Archie Crippen to become a massive fire event. One
major factor was the fact that the debris pile consisted of one continuous mound without spaces in
between (referred to as fire breaks). In addition to the surface fire that was initially present, investigators
concluded that subsurface fires had been burning since at least before the January 2003 surface fire (see
Figure 4-7). Other factors that complicated the firefighting efforts were mainly the lack of adequate fire
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breaks for proper access to the pile (California State Auditor 2003). As the firefighting went on, the pile
was broken down into three 1-2 acre piles of nearly 20,000 to 25,000 yd3 and a maximum height of 15 ft
(CIWMB 2003a).
Figure 4-7. Wormholes in Debris Pile Fire Indicating Subsurface Combustion (US EPA 2003a)
Following the extinguishing of the Archie Crippen pile fire, efforts were conducted to stabilize the pile.
Fire breaks were added and temporary access roads were added between the piles. Sampling occurred to
evaluate the nature of the remaining materials in the pile. It was jointly decided by the City of Fresno,
Fresno County, CIWMB, and US EPA that the most cost effective cleanup option for the fire debris was
removal, transport, and disposal at a Class III nonhazardous MSWLF with a composite liner and leachate
collection system. Mobilization began on July 28, 2003, and removal actions continued through
September 2003. Temperature, CO, and CH4 measurements were taken every morning in hot spot areas as
part of working condition monitoring. In total, 4,111 truckloads transported 102,650 tons of material from
the site. The cost of firefighting, stabilization, and clean-up efforts totaled nearly $6.5 million between the
US EPA, CIWMB, State of California, and the City of Fresno (US EPA 2003c).
Overall the damage incurred at the site included emissions of particulate matter into the surrounding
neighborhood, as well as the hazard of a large, uncontrolled fire. The site operated in a manner that was
not consistent with the conditions of its previous conditional use permit, namely the storage of a large
volume of wood-based products. The large debris pile was formed without fire breaks, and the site lacked
an adequate water supply - although not a regulation, one of the lessons learned (as identified by
Thalhamer, n.d.) was that storage of stockpiled woody C&D debris should follow procedures consistent
with the National Fire Protection Association code for outside storage of forest products, which reads in
part that wood piles should have
a maximum pile turnover time of 1 year,
a limitation to pile size, with a preference of numerous smaller piles,
a means of measuring temperatures within the pile on a regular (e.g., weekly) basis,
regular wetting to maintain moisture content and keep debris fines from drying out,
constructed access roadways to the top of the pile and access to reach any part of the pile, and
adequate water supply and fire hydrants so any part of pile can be reached by hose equipment.
4.4 Damage Case 3: Warren Landfill and Recycling Facility (Trumbull County,
Ohio)
The Warren Recycling/Warren Hills C&D Landfill (site) accepted debris between 1994 and 2004. The
site was the subject of a US EPA Superfund clean-up action from mid-2005 to mid-2006 to abate
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emissions of IrkS into surrounding residential communities. Due to the presence of IrkS at elevated
concentrations (one reading found a concentration of 95 ppm in residential ambient air), the ATSDR
categorized conditions in the neighborhoods surrounding the site as presenting an urgent public health
threat. More than 800 odor complaints were logged from more than 100 individuals (OEPA 2004a). In
addition to fugitive emissions of H2S, there have also been groundwater and surface water impacts
resulting from site operations that have been measured following cessation of site operations and at least
one documented instance of a prolonged (5-month) onsite subsurface fire.
4.4.1 Site Description
The site is an inactive landfill situated within approximately 240 acres located in Warren, Ohio. The site
is co-located with a municipal solid waste transfer station in a mixed commercial and residential area and
was originally constructed in a low-lying area adjacent to a wooded marsh or swamp (Tetra Tech 2004,
ATSDR 2006). The site was permitted to accept up to 1,500 tpd of C&D (OEPA 1994), and accepted
waste by truck and by rail. Two schools (Labrae High School and Leavitt Elementary School) were
located within 1 mile of the site. Labrae High School was demolished in March 2006 and Leavitt
Elementary School was abandoned. Figure 4-8 shows an aerial view of the site with the approximate
extents of the different fill areas.
GRANDFATHERED
AREA
Figure 4-8. Site Layout of the Warren Recycling Landfill with Approximate Landfill Phase Extents
(April 2012 Aerial Imagery from Google Earth)
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The footprint of the disposal area occupies approximately 62 acres and is divided into three separate
sections known as the "Grandfathered" area, Phase I, and Phase II. The Grandfathered area has a disposal
footprint of approximately 17 acres and is unlined. The Phase I section started receiving waste in 1999
and has a disposal footprint of nearly 15 acres and has an in-situ soil liner with a leachate collection
system (Civil and Environmental Consultants, Inc. [CECI] 2003). Phase I is piggybacked over a portion
of the Grandfathered area. Phase II has a disposal footprint of approximately 30 acres and includes a tire
drainage layer, a bottom liner and a leachate collection system (Durno 2005). Based on historic drawings
and an OEPA inspection, there appear to be at least three leachate riser pipes that have been used to
remove leachate from low points in the saw-tooth bottom liner system across the site; the bottom liner for
Phase II is located a maximum of approximately 15 ft below existing grades while the bottom liner for
Phase I is a maximum of nearly 20 ft below existing grades (PCR 2001, PCR 2003).
The elevation of existing grades surrounding the site ranges from approximately 900 to 910 ft above mean
sea level. The Mahoning River runs west to east approximately 1,500 ft north of the site, and there are
two tributaries that border both the eastern and western portions of the site that empty into the river: Duck
Creek, located approximately 1,700 ft west of the site, and an unnamed tributary directly east of the site.
According to a hydrogeologic site investigation report (CECI 2003), the underlying geologic profile is
divided into three general layers. The uppermost (shallow) layer consists of silt/sand unconsolidated
overburden, and ranges in thickness from 20 to 50 ft. The intermediate layer is comprised of Sanbury
Shale bedrock, which has two noted fracture zones and ranges from about 60 to 95 ft thick. The deepest
layer is made up of Berea Sandstone, with its uppermost boundary located approximately 95 to 140 ft
below ground surface. This layer represents the uppermost aquifer system, and is the major water-bearing
unit for approximately 25 groundwater supply wells within a mile of the site (CECI 2003). An OEPA
groundwater monitoring report from May 2010 sampling indicates at that time there were 17 total
operable (not dry) groundwater monitoring wells that comprised the entire groundwater monitoring
network; 11 installed in the uppermost shallow zone, 3 in the intermediate zone, and 3 in the deep zone.
Historically, the site has been used for various industrial purposes as far back as the 1920s, when a
brickyard operation existed. This was followed by a steel-stamping operation and then a trucking
company. The site was purchased by Warren Recycling, Inc. (WRI) in 1994, when it began operation as a
C&D landfill (ATSDR2002).
4.4.2 Compliance History
C&D disposal facilities in Ohio are regulated through OAC 3745-400. C&D sites are also regulated
through permits-to-install (which provide operational and air pollutant discharge standards) and permits
associated with stormwater and leachate discharge (e.g., National Pollutant Discharge Elimination System
and wastewater treatment plant discharge permits), as applicable. Current OAC requirements for C&D
disposal facilities include construction of a bottom liner with a leachate collection system, maintaining
less than 1 ft of leachate depth (head) on the bottom liner, constructing and maintaining a groundwater
monitoring well system for sites where waste was placed post-September 1996 with at least annual
groundwater sampling, and placing a weekly non-combustible material cover over deposited C&D.
Compliance and enforcement information dating back to 1994 was reviewed and is summarized below. A
timeline of major non-compliance events and related activities is presented in Figure 4-9.
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Sit* B*£inx Q Reran a n with
P*rmit-tH
. -
ExcMiivt 4>1 ft] L*ich*t* Depth
«nUn«r
-01
Oni*t* Nu««flc* Oder*
- .. Oni»t»Nu«i*rK* Odor*
ILeacnate into Tributary to M»twmin£ River
Srt* Operation r ran if or red from
W "*: 1 r> WHL
chat*, alonf Haul Road to Rail Car Ar«
ncM
into
^-, Sutp*r>d
^ Sehdi =n
Ar«< to
End of Wist* Aecflpti
Sep
Oct
i99S
Nov
1996
Det
1997
Jan
1999
Feb
2000
Mar
2O01
Apr
2002
May
2003
Jun
2004
Jul
2OO5
Aug
2006
0?
16/17/99
'6/26/00
Prohibhtd Wast*Acc*pt«nc* |
Exc*ij.!v» [>1 ftjf L**chat* O*pthon Liner
firm
6/11/02 - 4/12/05
2/20/03 -
7/23/03
2/20/03 - 7/23/03
S/4/O4 - a/14/07
Odor Complaint* [Doeum*nt*d} j| 10/18/02- 11/24/04
USEPATlm«-«ritie*(CI»»nUp |B^B 4/1/OS - 9/22/O6
Figure 4-9. Timeline of Non-Compliance Events and US EPA Time-critical Clean Up (Bars Represent Recurring non-Compliance Issues
as Noted in OEPA and WHCD Inspection Logs)
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1994-2002
Several Warren City Health District (WCHD) inspections noted the acceptance of prohibited (non-C&D)
waste, including industrial waste between August 1999 and June 2000. Some examples of non-C&D
materials accepted over this period included rubber manufacturing parts, car parts, drum containers, and
paper products. A November 2002 inspection report recorded that the industrial waste deposited during
this time was never removed, and Tetra Tech (2004) noted that a 1999 criminal investigation resulted
from its acceptance.
In fall 2001, the OEPA received numerous odor and health-related complaints from residents living in
neighborhoods in the vicinity of the site including reports of nausea, headache, vomiting, eye irritation,
fatigue, dizziness, and memory loss (Colledge 2005). These complaints and a subsequent petition
submitted to ATSDR prompted an investigation to evaluate exposure levels to area students, residents,
and workers from May to June 2002. The resulting Health Consultation, published 12 September 2002,
categorized the site as a "public health hazard."
Other compliance issues noted included the first instance of an odor issue (December 2001), which was
identified as "similar to rotting eggs." Additional nuisance odors were noted during an April 2002
inspection. Surface water impacts from leachate outbreaks from the eastern portion of the closed landfill
were noted during a July 1, 2002, OEPA inspection.
2002-2007
Starting in June 2002, at least 23 inspection reports documented the acceptance of prohibited waste,
primarily involving MSW. During this period, unidentifiable pulverized material was accepted at the site
as documented during February and March 2003 inspections; sometimes this material was directly
applied to the working face from rail cars without pre-screening. OEPA estimated that approximately
630,000 to 705,000 tons of pulverized C&D including powdered gypsum drywall were accepted from
early 2003 to mid-2004 (US EPA 2006b).
Two more instances of surface water impacts occurred in 2003. The first involved the seepage and runoff
of leachate along the site's haul road to the rail car unloading area. The second occurred as a result of the
uncontrolled discharge of stormwater to a wetland area to the south of the site. The inspection report
noted that suspended sediments/solids had not settled out of the stormwater prior to discharge.
From February to July 2003, a subsurface fire reportedly smoldered at the site. Four separate OEPA
inspections recorded smoke emissions from various landfill surfaces and areas of localized subsidence
during this time period. One inspection near the start of this fire event found that deposited waste was
placed without appropriate compaction, and two 2004 inspections also noted improper compaction.
According to OEPA inspections in 2003 and 2004, cover was not used regularly and stormwater was not
diverted from the working face, allowing leachate to collect in permanent leachate ponds at the toe of
landfill side slopes. OEPA stated odor problems became more serious during this period; residents north
and west of the landfill complained of "rotten egg" odors and negative health effects. Leachate head on
the liner greater than 1 ft was reported from February through July 2003.
An Exposure Investigation published by ATSDR concluded H2S gas presented an "urgent public health
threat" to the neighboring community (ATSDR 2003). This was based on an ambient air monitoring
event, summarized in Section 4.4.3. Federal, state and local agencies required the site owner to develop a
closure and remedial plan, but the owner did not comply with the order (US EPA 2006b).
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On 1 July 2003, a Consent Order and Permanent Injunction were signed which required the site to comply
with numerous provisions, including those relating to recurring non-compliance issues including:
Not accept material other than C&D for disposal at the site.
Only unload and screen waste in a designated unloading zone.
Submit and implement a final closure plan for existent and the future Phase II area in the
appropriate timeframes.
Operate the site in a manner to prevent fires.
Manage and control leachate (e.g., maintain and monitor the leachate collection systems in
Phase I and II).
Complete a hydrogeological investigation and implement a groundwater monitoring program.
On August 20, 2004, an OEPA inspection noted cracks in the cover soil at the toe of the southeastern
slope of Phase II revealed stained black soil suspected as a result of FfcS emissions. Nuisance FfcS odors
were detected during WCHD inspections in November and December 2004 through the end of site C&D
filling operations.
Even though a time-critical clean up action was executed by US EPA from mid-2005 to fall 2006, part of
which involved pumping out more than 13.4 million gallons of leachate (Durno 2006), head-on-liner
exceedances were recorded in OEPA inspection reports from August 2004 until August 2007. Following
the completion of site clean-up activities, US EPA turned over operation and maintenance of the leachate
management system to the site owner (Durno 2006).
On March 28, 2007, a Stipulation of Finding of Contempt and Joint Motion to Suspend Entry of
Contempt Penalties was signed, which brought five charges of contempt against the site owner regarding
failure to meet conditions listed in the Consent Order issued in July 2003. These charges included failure
to properly manage and control leachate, submit closure and post-closure plans, implement groundwater
monitoring, and pay the previous stipulated penalty fee.
A Consent Order that replaced the 2003 Consent Order was signed March 17, 2008; the terms of the order
that applied to site operation include the following:
Apply at least 12 in. of cover soil to all exposed waste areas and all areas with greater than 2 in.
of erosion. The site owner was required to submit a cover and seeding/vegetation plan prior to
initiating supplementary cover activities.
Maintain less than 1 ft of leachate depth on the bottom liners of the Phase I and Phase II portions
of the site, and maintain a pumping log for each day leachate was pumped.
Continue perimeter FfcS monitoring at least once per week and monitor FfcS concentrations across
the entire site at least once per month.
Inspect the entire facility for cover integrity and odors/gases once per month.
Maintain all leachate collection system and pumping equipment.
4.4.3 Damage Assessment
This section presents a discussion of damage based on review of historical reports, site inspection
documents, and related information on the site, with particular focus on odors caused by H2S emissions
and groundwater impacts as demonstrated by monitoring conducted at the site.
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Emissions
Figure 4-10 shows a plot of the various locations around the landfill where H2S odors were identified (or
recorded as a "rotten egg" smell) based on WCHD odor monitoring reports and investigation logs from
October 2002 through November 2004. There are 35 unique addresses represented in this plot, with the
farthest odor complaint originating from nearly two-thirds of a mile away from the site.
Figure 4-10. Warren Recycling Landfill Community Odor Complaints Between 2002 and 2004 (April
2012 Aerial imagery from Google Earth)
There were at least six different area residential and on-site H2S monitoring events between 2002 and
2006. Table 4-6 provides a summary of the different H2S and sulfur compound monitoring events
including the date taken, organization performing the monitoring, the location(s) of H2S monitoring, the
equipment used, the maximum H2S concentration detected, and a discussion of results.
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Table 4-6. Summary of Major hhS Monitoring Events at the Warren Recycling Landfill
Date
7 May-
3 June
2002
14 Nov.
2002 - 8
March
2003
15 Dec.
2003-
21 July
2004
Sampler and
Data Source
MS
Consultants,
Inc. (ATSDR
2002)
ATSDR
(2003)
Area Resident
(ATSDR
2006)
Location
5 Monitoring
Points in
Surrounding
Area (including
LaBrae High
and Leavitt
Elementary
Schools)
6 Residential
Locations -
Indoor and
Outdoor
Area
Residence
H2S Monitoring
Equipment
City Technology
Triple Plus
Monitors (UK)
Zellweger
Analytics Single
Point Monitors
(with ChemKey
and
Chemcassette
Detection
Systems)
SUMMA
Canisters (6),
Tedlar Bags (2)
Max. H2S
Concentration(s)
13.1 ppm
6.1 ppm outdoor
(> 6 ppm for 15
minutes)
38 ppb indoor
(> 30 ppb for 2
hours)
Indoor:
Dimethyl Disulfide
Oft nnh
^U |J|JU
Methyl Mercaptan
12 ppb
Outdoor:
Dimethyl Disulfide
180 ppb
Methyl Mercaptan
750 ppb
Dimethyl Sulfide
COr\ ririK
oou ppu
n-Butyl Mercaptan
83 ppb
H2S 60 ppb
Discussion
The Health Consultation
reviewing the results of this
monitoring noted a lack of
adequate QA/QC measures,
potential interference with
carbon monoxide and
nitrous oxide
concentrations, instances of
tampering or malfunctions
with the monitors, and times
where negative
concentrations were
recorded. However, ATSDR
concluded site area
conditions represented a
"public health hazard."
The manufacturer of the
equipment claimed that
readings are accurate within
20% - 25% of the true value
and have a precision of 10%
or greater. As a result of this
monitoring, ATSDR
classified area conditions as
an "urgent public health
hazard."
A resident at a single
location historically
impacted by H2S odors took
indoor and outdoor grab
samples during odor events
for laboratory analysis. Of
six SUMMA canister
samples taken, only one
had detectable
concentrations of sulfur
compounds. The
concentrations from the two
Tedlar bags were
determined using a
calibration curve based on
laboratory control samples
at concentrations up to 1000
times greater than those
reported.
(continued)
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Table 4-6. Summary of Major hhS Monitoring Events at the Warren Recycling Landfill (continued)
Date
June-
Aug.
2004
1 Sept. -
6 Oct.
2004
17-18
May
2005 and
25-27
July
2006
Sampler and
Data Source
Area
Residents
(Colledge
2005)
Tetra Tech
EM, Inc.
(2004)
US EPA
(2006)
Location
Area Residents
and Workers
(Personal
Badges). Five
Residences
(Ambient Air
Monitors),
Odor Events
3 Area
Residences
Landfill Surface
H2S Monitoring
Equipment
Personal
Badges,
Ambient Air
Monitors, hand-
held monitor
Zellweger
Analytics Single
Point Monitors
Low-level
hhSMonitor
Max. H2S
Concentration(s)
95 ppm (near sewer
manhole cover on
Lover's Lane just
south of Mahoning
River)
539 ppb
> 120 ppb for 24
minutes
> 100 ppb for 101
minutes
(All max. readings
from residence
immediately NW of
site)
165 ppm (before
clean up)
0.043 ppm (following
clean up)
Discussion
This reading is close to the
National Institute for
Occupational Safety and
Health immediately
dangerous to life or health
exposure level of 100 ppm.
The reading prompted US
EPA to notify the site owner
to stop pumping leachate
into the sewer. Leachate
was transferred to the
wastewater treatment plant
by truck.
Because these readings
exceeded the American
Industrial Hygiene
Association recommended
Emergency Planning
Guideline of 100 ppb for up
to a maximum of one hour, it
was concluded that a US
EPA time-critical removal
action was warranted for the
site.
H2S monitoring results
indicate that cleanup work
performed by US EPA
Emergency Rapid
Response Services and the
Superfund Technical
Assessment and Response
Team was effective in
reducing H2S emissions
from the site.
US EPA began an interim cleanup 25 April 2005 to reduce the immediate threat posed by H2S emissions.
This work involved cleanup of the southwest section of the landfill, which, as determined in May 2005,
was the only portion (of Phase II) of the site at the time which was producing H2S gas at concentrations
considered an immediate public health risk (US EPA 2006b). This cleanup involved the following:
Collecting all loose C&D and place on the open face, and then covering the exposed waste with a
temporary clay cap. US EPA estimated that approximately 20,000 tons of material were
relocated.
Draining and filling in (with clay) portions of the southwest section of the site which had standing
water
Grading the surrounding land and constructing a large ditch in order to divert stormwater away
from the landfill in the future.
Providing a compacted clay cap on southwest portion of the landfill.
Removing a large amount of leachate "trapped" inside the landfill using system of pipes and
pumps to draw from both the landfill and surrounding ponds.
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By May 2006, more than 13 million gallons of leachate had been collected, treated, and discharged.
Leachate levels over the leachate collection pad dropped from 13 to 6 ft. A final survey of H2S emission
concentrations was performed in July 2006, where a low-level H2S monitor was used to collect surface
data on the landfill on a 50-ft interval grid. Sampling during similar weather conditions revealed
maximum H2S concentrations were reduced from 165 ppm in May 2005 to 0.043 ppm in July 2006.
The factors related to the H2S emissions included non-compliance issues as well as other factors unrelated
to compliance. As described earlier in Section 4.2 and in Section 3, the acceptance of drywall and C&D
landfill conditions can lead to the formation of H2S. However, a unique factor at the site that contributed
to the high emission levels observed include the build-up of leachate at the bottom of the lined cells and
the acceptance of pulverized C&D debris. The build-up of liquid was observed to result in the saturation
of waste near the bottom of the landfill, which created even more favorable conditions for H2S production
(compared to a landfill that does not have built-up liquids). Furthermore, the disposal of size-reduced
C&D debris (which included gypsum drywall) created a larger specific surface area which can promote
the formation of H2S compared to larger pieces of debris.
Groundwater
Potentiometric contour plots from OEPA groundwater sampling reports show that groundwater in the
shallow zone has a relatively complex flow path (OEPA 2008, 2009b, 201 Ib). Shallow groundwater in
the Phase I and Grandfathered sections of the landfill generally flows east or northeast across the site
while the groundwater below the Phase II area flows west or northwest. A groundwater monitoring plan
and system was required in the July 2003 consent order and a total of 22 piezometers were installed from
August to October 2003, however, the operator never implemented groundwater monitoring. OEPA
voluntarily initiated quarterly groundwater sampling in November 2005.
The majority of groundwater monitoring events involved sampling from monitoring wells installed in the
surficial zone, typically including 11 wells - three upgradient (MW-3SA, MW-3SB, and MW-5S) and
eight downgradient. Samples were taken from both the intermediate and deep zones as well.
Quarterly sampling was concluded in August 2006, when OEPA transitioned to a semiannual sampling
schedule, the first of which took place in November 2006. OEPA performed a statistical analysis of the
November 2006 results and found that several downgradient wells showed statistically significant
elevated parameter concentrations above those measured in upgradient wells - the elevated parameters
included potassium, ammonia, COD, chloride, and sulfate.
Table ^-/presents a summary of the parameters with noted exceedances of Ohio MCLs measured in
groundwater monitoring wells installed in the surficial aquifer. Each parameter (with the exception of
filtered thallium and filtered arsenic) exhibited an exceedance of the Ohio MCL at least once for all
parameters listed in the table in both upgradient and downgradient wells. An assessment of the
monitoring data suggests that chloride, sulfate, iron, manganese, and thallium were greater in
downgradient wells compared to upgradient wells, though detailed statistical comparisons are difficult
because of the small number of sampling events for each well. Measured concentrations for other
parameters (e.g., aluminum, arsenic) are variable and a distinct difference in upgradient and downgradient
concentrations was not discernible. Evaluations conducted by OEPA (2011) found statistically significant
differences in alkalinity, ammonia, chloride, COD, magnesium, potassium, sodium, and sulfate between
background wells and at least one downgradient well, generally consistent with observations from 2006
groundwater monitoring event analysis.
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Data Gap Analysis and Damage Case Studies for C&D Debris Facilities
Monitored Parameter
Chloride
Sufltfe
Aluminum
Arsenic
Filtered Arsenic
Iran
Filtered Ircn
Lead
MangarKse
Filtered Manuantss
Thallium
Filtered Thallium
Unlla
mgJL
mg.'L
mg.'L
l-v-
l-v -
'I'-^1'-
mg.'L
>-; -
<:; .
;:; .
\IQX-
MtJ.'L
MCL
2H |Si
2SO |S)
.05(5)
10
10
a 3 (Si
a 3 (S)
15
HvSi
K (S)
2
2
Mumdtr or Maaeurementa
F'-f- i:\-r '-.-- r MCLai
tUiBHfliMtf
16 111
13(11)
1fl<14)
- :i::
tivii
16(15)
6(3)
1'. I"
111(11]
.-. ;i i
16(2)
£.
Downgradlent
56(12)
Sa (46)
48(41)
«(12)
1S
4.3 (46)
fill
-!: ,.
j.:: -^
11(10]
« :i;:
1SI7J
Nate: 1. i]Sj derates a secondary drinking water s'.andard.
Table 4-7. Summary of Groundwater Monitoring Parameters Exceeding MCLs at Warren Recycling
C&D Landfill (2007 - 2010 Monitoring Data)
As discussed, the landfill consists of a combination of unlined and lined cells. Furthermore, the site has a
documented history of leachate build-up on the lined areas. Given the mix of lined and unlined disposal
areas at the site, it is difficult to assess the efficacy of the liner and leachate collection system. However,
the data reviewed suggest that some impacts to groundwater from historical landfill operations occurred.
4.4.4 Summary
Table 4-8 presents a summary of the damages observed at the site and the potential contributing factors,
including those that may be related to permit non-compliance and those that are not related to permit non-
compliance. Ultimately, a combination of factors related and unrelated to permit compliance appear to
have resulted in the conditions observed at the site. In the case of F^S emissions, the nature of the
materials disposed and the anaerobic, moist conditions that can form within C&D landfills likely would
have led to the production and emission of FtS regardless of whether the facility complied with
applicable rules. However, the acceptance of large amounts of pulverized debris, which results in an
increased specific surface area of the debris and thus makes the gypsum drywall more susceptible to
conversion into H2S, coupled with the improperly functioning leachate collection system that allowed a
significant quantity of leachate to build up within the lined cells, appears to have greatly enhanced
conditions that cause the production and emission of H2S.
As for groundwater impacts, directly tying the elevated constituent levels observed to one specific activity
is difficult. The facility had an unlined cell as well as cells with improperly functioning leachate
collection systems, thus, it is expected that both conditions likely contributed to the groundwater impacts
observed at the site. So ultimately, a combination of permit non-compliance as well as the presence of the
unlined cell (which was built before C&D landfills required liners and leachate collection systems in
Ohio) contributed to the groundwater impacts observed at the facility.
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Data Gap Analysis and Damage Case Studies for C&D Debris Facilities
Table 4-8. Summary of Site Environmental Damages and Potential Contributing Factors Related to
and Not Related to Facility Non-Compliance at the Warren Recycling Landfill
Damage
Potential Contributing Factors Not
Related to Facility Non-
Compliance
Potential Contributing Factors Related to
Facility Non-Compliance
hhS Emissions
Acceptance of gypsum drywall
Requirement to apply cover
weekly (more frequent application
may have been required to reduce
H2S emissions to acceptable
levels)
Acceptance of unidentifiable (pulverized)
waste
Failure to apply weekly cover
Failure to install and maintain final cover
Improper operation of leachate collection
system
Improper surface water management
Groundwater Impacts
Presence of an unlined cell (built
before liner and leachate
collection requirements)
Nature of C&D debris causing
elevated constituents identified at
unlined C&D debris landfills
Improper operation of leachate collection
system (allowing build-up of leachate on
liner)
Prohibited and unidentifiable waste
acceptance
Failure to install and maintain final cover
Improper surface water management
The problems that were observed at the site were remediated as part of a Superfund cleanup action by the
US EPA. The clean-up effort, which cost approximately $4 million (US EPA 2006c), primarily focused
on the control of F^S emissions, which was largely addressed through the removal of significant
quantities of leachate that were built up at the landfill.
4.5 Summary of Detailed Damage Cases
Three damage cases located in different regions of the US comprising different types of operations
(disposal and recycling) were examined. In each of the three damage cases, a combination of permit non-
compliance issues as well as issues that occurred which were consistent with the facility's permit led to
damage that was manifested as groundwater, surface water, odor emission, and/or fire-related impacts.
The evaluation specifically suggested that damages that occurred at these facilities may have been
prevented with the inclusion or implementation of best management practices. Furthermore, the
dissemination of the lessons learned from these damage cases (as well as damage cases from other
facilities in other states) would provide a valuable resource for regulators and the regulated community.
The development of a best practice guide for C&D management at landfills and recycling facilities could
promote sustainable practices that reduce the likelihood of the formation of conditions that could result in
negative environmental impacts.
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5. Summary and Recommendations
The results of the analysis conducted in this study show that the rules for the management of C&D debris
vary, sometimes substantially, from one state to another, both in terms of operational requirements and
design, construction, and siting requirements. The inventory of C&D landfills is expected to be a fairly
accurate representation of the universe of active C&D landfills in the US as of the time of this writing, but
the inventory of C&D recycling facilities (which is, to the knowledge of the project team, the most
extensive inventory of C&D recycling facilities in the US compiled to date) contains several data gaps,
which is mostly a function of the exemption from solid waste regulation that is afforded to recyclers of
certain C&D debris materials and the fact that many states do not have rules specific to C&D recycling.
The inventory of damage sites in the US was limited by several factors, but the examination of large-scale
statewide data suggests that the universe of C&D sites impacting the environment is likely far greater than
the inventory that was developed through contacts with state regulatory representatives. The detailed
assessment of three damage cases each shows that a combination of factors, both related and unrelated to
permit non-compliance, plays a significant role with regard to the cause of damage. These damage cases
highlight the fact that damage may occur in several forms (e.g., groundwater impacts, fires and associated
emissions, and odorous emissions related to FfcS) and the impacts can be significant. In addition to the
human health and environmental impacts caused by these damage sites, the economic burden was
significant as well - the closure or remediation of each of these sites exceeded $3 million.
In light of these observations, several recommendations are made that would help to augment the results
identified in this report and provide states and communities with improved information regarding C&D
debris management in the US:
Enhance the site damage inventory developed in this analysis by conducting a formal survey of
states to include regional and district representatives who are responsible for compliance and
enforcement.
Compile and examine additional large-scale data sets from other states in the US to provide a
more complete picture of the range of constituent concentrations observed at sites in other states
in the US. The data set would ideally include groundwater, leachate, and gas-related data (e.g.,
CH4 measured at landfills and in monitoring probes and F^S measured at landfills within the
waste or in ambient air). Although the US EPA (2012) will be publishing an updated best
management practices guide for preventing and controlling H2S emissions from landfills,
additional operational data from sites would inform states and communities of concentrations that
may be measured at C&D landfills and enhance overall technical body of knowledge.
Further examine the extent of issues and experiences with fires at C&D landfills. This may
include causes but also an exploration and potential development of best practices to prevent and
control landfill fire events.
Develop a best management practices tool for C&D disposal and recycling facilities. As this
report demonstrated, damage at the three facilities examined was caused by a combination of
permit non-compliance issues and conditions unrelated to permit non-compliance. Compiling best
practices based on discussions with facilities throughout the US would serve as a valuable tool for
regulators and the regulated community to understand common practices that may lead to damage
and methods to mitigate or avoid these practices. A best management practices tool could also be
used as an opportunity to convey some of the lessons learned in this report and in other studies
and convey the potential environmental damage that may occur at C&D disposal and recycling
facilities.
Develop improved databases related to the number of C&D recycling facilities as well as C&D
debris management in the US. Previously published information estimating C&D debris
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generation and management in the US have shown significant spread (a difference of a factor of
five, depending on the methodology used and the materials included in the estimate), and the
compilation of generation and management data on a more frequent basis using a consistent
methodology would help US EPA benchmark improvements (similar to what is currently done in
the MSW facts and figures published by US EPA) and identify additional opportunities for the
US EPA to provide tools to help states manage materials more sustainably.
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