HomeMy WebLinkAbout2003-06-12 OPH PWD Email Re Demolition Disposal IssuesJa Johnson
From.- Ja Johnson
Sent: Thursda June 12, 2003 3:55 PM
To: Ja Johnson; 'Ken Hoo ( E-mail ) '; 'Mike Price ( E-rnail ) '; 'Todd Ercikson ( E-mail ) '
Cc: Eric A. Johnson; Jim Butler Julie Hultman; Mark J. Vierlin ( E-mail )
Sub RE: Demolition Disposal Site Is not just a hole in the g round that y ou can throw trash.
I spoke with Katie Koelf (651-297-8506) of the MPCA Solid Waste Division and M anal of the situation was 99%
correct. The onl thin that I did not know is that Washin Count as well as the Cit has to si off on the application
prior to sendin it to the MPCA.
- - - -- ori g inal Messa -----
From: Ja Johnson
Sent: Thursda June 12,, 2003 12:08 AM
To: Ken Hoo (E-mail) Mike Price (E-mail) Todd Ercikson (E-mail)
Cc: Eric A. Johnson Jim Butler Julie Hultman
Subject: Demolition Disposal Site Is not just a hole in the g round that y ou can throw trash.
At our staff meetin on Wednesda we discussed y our plan to establish a demolition disposal site at McKean S
Your g radin g and fill permit did not re such a facilit Prior to the Cit approval of such a site we will need to
review the site plans to ensure that y ou meet the applicable MPCA re for desi construction, operation and
closure of a solid waste disposal facilit Eric asked me to check into the rules and talk with the MPCA I will be callin
MPCA on Thursda afternoon unless y ou decide not to build a demolition debris landfill and y ou decide to truck the
debris offsite.
The site cannot be used for an other than demolition debris. Below are the definitions from the MPCA rules
for demolition debris. These definitions do not include car parts, appliances or old drums (man older
appliances were made of parts that are now considered hazardous waste).
Subp. 3 0. Demolition debris. "Demolition debris" means solid waste resultin from the demolition of
buildin roads, and other structures includin concrete, brick, bituminous concrete, untreated wood,
masonr g lass, trees, rock, and plastic buildin parts. Demolition debris does not include asbestos wastes.
Subp. 31. Demolition debris land disposalfacilit "Demolition debris land disposal facilit means a site
used to dispose of demolition debris.
Permit b Rule
It appears that y ou MAY q ualif y for a "Permit -b -Rule" since y our facilit will be less than 15,000 cubic y ards and open
for less than one y ear. The "Permit -b -Rule" applies to small sites which will onl be open for a limited amount of time
and that have been desi in accordance to the MPCA rules. You will have to notif the MPCA Commissioner
before y ou start operations. I have copied some of the rules into this email. Prior to desi the site y ou ma want to
review the MPCA rules. It is not as simple as di a hole, put it in and cover the hole. You will need to be able to certif
that the bottom of the facilit is more than 5 feet above g round water, have records of the waste g oin g in, know the
g eolo gy below the site, the cover desi is specific, the site has to be recorded a the propert deed, and there
are post closure re includin maintenance of the site.
MPCA Re Chapter 7001.3050 Subp. 3. Permits-b The owner or operator of the followin
facilities is deemed to have obtained a solid waste mana facilit permit without makin application
for it, unless the commissioner finds that the facilit is not in compliance with the listed part:
B. demolition debris land disposal facilities desi for less than 15, 000 cubic y ards total capacit and
operatin less than a total of 12 consecutive months, not located ad to another demolition debris
permit b rule facilit and in compliance with parts 7035.2525 to 7035. 7035.2825 and 7035.2855
The main rule seems to be 7035.2825 which I have included at the end of this email.
If you decide to bury the debris and you do not design, construct, operate and close the site in accordance to the rules
you will not qualify for a "Permit -by- Rule" and you will have constructed an demolition debris land disposal facility
without a permit. Since the City is aware of the plan we will review your plan in accordance with the applicable MPCA
Rules. To facilitate this review I am requesting the following:
Submit a building request for as Demolition Debris Land Disposal Facility on our standard building permit form with the
following attached.
1. A listing of the applicable MPCA Rules under which the facility will be constructed, operated, closed and post
closure maintenance.
2. Design drawing showing the design of the facility including cross - sections) and the applicable setbacks from
wetlands and site boundaries and any other setback requirements within the MPCA rules.
3. A certification for a certified geologist or geological engineer that the site does not meet the definition of Karst
geology. one of the definitions is that streams disappear. This entire area has landlocked wetlands which infiltrate into
the soils rather than flowing from one to the other. The Prairie du chen limestone is know to underlay this area and in
some areas of town it is at the surface. The video tapes of this limestone a mile and one half east of this location
shows it to have large dissolution channels.
4. operation plans. These should be simple set which specify who you will receive waste from (McKean Square,
McKean west, Boutwell's Landing), what type of waste will be accepted (see definition above of Demolition Debris),
How the waste will be placed in the site, the method of compaction that will be used to compact the waste and
minimize post closure settling, the time of operation (both daily and how many weeks).
5. Closure plan including depth of final cover, how many lifts to achieve the 2 foot minimum cover and type of material
used in the base of the cover and the material that will be used for the top one foot of soil that supports vegetation.
(this can be on the same plan as 2. above.) Type of seeding.
6. Post Closure maintenance plan. Who will inspect it, how many years will it be inspected, what will be inspected for
and generally what will be done if there is a problem discovered.
7. Draft of material that is to be recorded against the deed. (probably 2, 3 4 5 and 6 above)
8. A copy of your notification to the MPCA Commissioner that you are going to operate a Permit by Rule Demolition
Debris Land Disposal Facility.
For those of you who do not know my background. I was an environmental engineer for 20 years prior to agreeing to
help a friend out for 5 months as his Public Works Director. I have worked for the US Army, the State of Iowa,
Consulting firms, Honeywell and been a self employed consultant. I have been involved in solid and hazardous waste
faculties at many levels including design, permitting, operation, investigating and as the neighbor of one that was not
properly constructed.
7035.2825 DEMOLITION DEBRIS LAND DISPOSAL FACILITIES.
Subpart 1. Scope. The requirements of subparts 2 to d apply to owners and operators of demolition debris
land disposal facilities granted permit -by -rule status under part 7001.3050 , subpart 3. The requirements of
subparts 7 to 14 apply to owners and operators of demolition debris land disposal facilities required to
obtain a permit under part 7001.3 05 0 .
Subp, 2. Location standards for permit -by -rule facilities. Demolition debris land disposal facilities
permitted -by -rule must not be located:
A. on a site with karst features including sinkholes, disappearing streams, and caves;
B. within wetland areas;
C. within a floodplain area;
D. within a shoreland area; and
E. with a water table within five feet of the lowest fill elevation.
Subp. 3. Design requirements for permit -by -rule facilities. Demolition debris land disposal facilities
permitted -by -rule must be designed in the following manner:
A. Site preparation must allow for orderly development of the site. Initial site preparations must include
clearing and grubbing, topsoil.!, gripping and stockpiling, fill excavation, it* appropriate, drainage control
structures, and other design features necessary to construct and operate the facility.
B. The site must be developed in phases to achieve final fill elevations as rapidly as possible. The design of
each phase must take into account weather conditions, site drainage, and the waste flow pattern into the site.
C. Surface water drainage must be diverted around and away from the fill areas.
D. Slopes and drainageways must be designed to prevent erosion. Slopes longer than 200 feet must be
interrupted with drainageways.
E. Final slopes for the fill area must be a minimum two percent and a maximum 20 percent.
F. Final cover must consist of at least two feet of soil with the top 12 inches capable of sustaining vegetative
growth.
G. Final contours must be consistent with the planned ultimate use for the site.
Subp. 4. operation and maintenance requirements for permit -by -rule facilities. A demolition debris
land disposal facility must be operated by a certified operator in accordance with parts 7048.0100 to
7048.13 00 . The certified operator must be present during the time the facility is open to accept waste. The
facility operations must meet the following requirements:
A. The waste must be spread and compacted to the extent possible.
B. The waste must be covered at least monthly.
C. Suitable cover material must be maintained at the site.
D. Each phase must be staked for proper grading and filling.
E. A minimum separation distance of 50 feet must be maintained between the fill boundaries and the site
property line.
F. Only demolition debris may be placed in the fill area.
G. waste at the site must be stored in accordance with part 703 5.285 5 .
Subp. 5. Closure and postclosure care for permit -by -rule facilities. The owner or operator must close
each phase as it reaches final waste elevations. The cover must consist of at least two feet of soil capable of
sustaining vegetative growth and minimizing erosion. After closure, the site must be inspected at least once
each year between June and September for settlement and erosion problems. All problems at the site must be
corrected within 30 days of the inspection. A site closure record must be completed after closure and
submitted to the commissioner. A notation must also be placed on the property deed indicating the site use
and location of the waste.
Subp. 6. Notification of permit -by -rule facilities. The owner or operator of an existing demolition debris
land disposal facility shall submit a letter notifying the commissioner of the facility's existence within 30
days after November 15, 1988. The owner or operator of a new facility shall submit such a letter before
operations begin. The notification must include the initial date of operation, the type of waste accepted, the
capacity of the site, the location of the site, the users of the facility, and the expected date of closure.