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Using C&D Fines and Residuals Using C&D Fines and Residuals
to Close Landfills to Close Landfills –– Lessons Lessons LearnedLearned
James DoucettJames Doucett
Business Compliance DivisionBusiness Compliance Division
Bureau of Waste PreventionBureau of Waste Prevention
MassDEPMassDEP
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OverviewOverview
� Background – how did we arrive at
allowing use of C&D residuals in landfills
� Problems that developed
� Solutions
� Looking forward
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Key Issues for Massachusetts:Key Issues for Massachusetts:
� Lack of landfill capacity
� Goal to maximize diversion of C&D
waste from landfilling
� Number of old landfills never
properly capped and closed
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Since 2000 Master Plan:Since 2000 Master Plan:
�Banned disposal of specific C&D materials in 2006
�Conducted case studies to promote C&D source
reduction
�Provided over $700,000 in grants and loans to develop
C&D related recycling infrastructure
�Developing new end-use markets for processed C&D
and wood in particular
�Allowed C&D residuals to be used to close inactive
LFs
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Response by IndustryResponse by Industry
� In late 1990s, in response to the proposal to
ban disposal of C&D waste, the C&D
processing industry took off
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Response by IndustryResponse by Industry
� Before 2000 Master Plan:
– 6 C&D processing facilities
� Currently:
– 11 operating C&D processing facilities
– 2 in permitting
– 2 others located in NH on Mass border
� Over 3 million tpy of processing capacity, which
more than takes care of Mass C&D waste
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Snapshot of C&D ProcessingSnapshot of C&D Processing20042004
� 5,160,000 tons C&D generated
� 4,500,000 tons diverted/recycled– 3,470,000 tons - ABC materials
– 100,000 tons - Metal
– 30,000 tons - C&D wood recycled
– 50,000 tons - C&D wood for boiler fuel
– 50,000 tons - Woodwaste (clean wood)
– 20,000 tons - Other (ceiling tiles, carpet, gypsum wallboard, and
asphalt roofing shingles)
– 810,000 tons - C&D fines and residuals for closures
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Life is Good, Right?Life is Good, Right?
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Problems in Processor Problems in Processor
ParadiseParadise� C&D materials can be difficult to recover
and recycle
� Weak markets (C&D wood, for example)
– Wood biomass facilities located in Maine
– Controversy on burning C&D wood
� What do you do with residuals and fines?– Expensive to dispose of residuals and fines
($60-$100/ton)
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Industry ResponseIndustry Response
•Temporary closure of processors
- Nov. 1999
- no place to send residuals
•Proposed using residuals to close
old landfills!
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DEP ResponseDEP Response
� Unlined Landfill Closure Policy:– Allows use of materials for grading and shaping
old landfills prior to capping� C&D fines and residuals
� Coal ash
� Contaminated soils that meet MassDEP soils policy
� Dredge spoils, street sweepings, etc.
– Provides guidance on permitting process
– Establishes standards for materials and projects to promote consistency
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Why Use C&D Fines and Why Use C&D Fines and
Residuals to Close Residuals to Close LFsLFs??
� 700+ old MSW landfills in Massachusetts
– Lots of pre-1971 landfills never capped and
closed properly or only with minimal soil cover
– 1971 regulations had minimal closure standards
– 1990 regulations require up-to-date closures
� Have closed over 150 LFs since 1990
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Why Use Fines and Residuals?Why Use Fines and Residuals?
� Development pressures – land is valuable,
even old LFs
� Municipalities own most of those old
landfills
� Cost of closure is high
– no money set aside to close
– large burden on tax rate
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Why Use Fines and Residuals?Why Use Fines and Residuals?
� Fines and residuals can be used to grade the
landfill substituting for higher cost soils
� Town can charge a tipping fee for the
materials
� Set aside $$ for assessment, closure,
capping and post-closure monitoring and
maintenance
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Why Use Fines and Residuals?Why Use Fines and Residuals?
� The Big Issues:– What volume of grading and shaping material
is really needed?� To simply close the LF it is X
� To set aside enough money to also pay for the capping and closure it is X+Y
� To maximize profits it is X+Y+Z
– How much time is needed to grade then cap the landfill?
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Major Goals of PolicyMajor Goals of Policy
• Promote a permanent, permitted C&D
recycling/processing infrastructure
• Maximize recycling of C&D materials
• Ensure there is a home for C&D residuals
• Level Playing Field
• all landfill closures play by same rules
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The ProcessThe Process
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Stage 1 Stage 1 –– Consolidation and PreConsolidation and Pre--shreddingshredding
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Stage 2 Stage 2 –– Mechanical Separation/ScreeningMechanical Separation/Screening
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Stage 4 Stage 4 –– DuelDuel--line Picking Stationsline Picking Stations
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Stage 5 Stage 5 –– Float Tank/Density SeparationFloat Tank/Density Separation
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Stage 6 Stage 6 –– Residual & Fuel ProductionResidual & Fuel Production
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C&D Residuals in UseC&D Residuals in Use
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C&D Residuals in UseC&D Residuals in Use
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C&D Residuals in UseC&D Residuals in Use
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C&D Residuals in UseC&D Residuals in Use
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ProblemsProblems
� H2S gas generated that resulted in odor
problems
� Why? – theories
� Concentrations
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What Caused Odor Problem?What Caused Odor Problem?
� H2S issue much worse than expected
� Possible Causes:– Grinding wallboard increases surface area for
reaction
– Large amount of material going into LF over short period of time
– Conditions were ripe:� Anaerobic conditions
� Moisture
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How Bad Can it Be?How Bad Can it Be?
� Raw LF gas from gas probes:
– MSW landfill not using residuals or fines – H2S
<100 ppm
– Landfill using residuals and fines – H2S>20,000
– 30,000 ppm
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Where Did We Get into Where Did We Get into
Trouble?Trouble?
� Happened quickly – anaerobic conditions,
moisture and short period of time (9 months
to 1 year)
� No financial assurance to cover H2S
pretreatment and flaring LF gas
– Pretreatment is expensive
– Pretreatment technology not fool-proof
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SolutionsSolutions
� Source separation of wallboard at job sites
� Front-end removal of wallboard by C&D
processors
� Mix soils with residuals
� Install gas collection, pre-treatment and
flaring systems as closure progresses
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What Has MassDEP Done?What Has MassDEP Done?
� Require operator to address site-specific
problems when they arose
– Cover what’s there
– Stop taking more residuals until under control
– Install gas collection and pre-treatment
� New or revised policies
� Demonstration project
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C&D Residuals in UseC&D Residuals in Use
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C&D Residuals in UseC&D Residuals in Use
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What Has MassDEP Done?What Has MassDEP Done?
� Site specific solutions
– Gas pre-treatment to knock down H2S
– Gas treatment – flares
– Reduce or eliminate use of fines and residuals
– Require higher ratio of soil to fines and
residuals, at least 3:1 recommended
– Apply final cap as soon as possible in phases if
necessary
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What Has MassDEP Done?What Has MassDEP Done?
� Pre-treatment Issues:– 2 basic systems:
� Sulfa-treat – low capital cost, high operating cost
� Scrubbing – high capital cost, low operating cost
– Systems not designed for high concentrations of H2S - must change out media often - $$$$
– If concentration of H2S at inlet to flare is too high, flare will exceed permitted SO2 conc.
– Supplemental fuel needed, not enough methane
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What Has MassDEP Done?What Has MassDEP Done?
� Policies
– Modify Unlined Landfill Closure Policy to
include Addendum with BMPs
– Developed H2S Policy to address odors
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Best Management PracticesBest Management Practices
� Addendum to Closure Policy
– Setbacks to residences for future projects
– Wallboard separation program required
– Monitor sulfate content in residuals and fines
– Require minimum 3:1 ratio of soil to residuals
– Develop odor control plan (H2S Policy)
– Financial assurance for gas treatment
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HH22S PolicyS Policy
� Requires Odor Control Plan be developed by
landfills using C&D residuals and fines
� Establishes Action Levels:
– Odor Action Level
– H2S Action Level
� 15 ppb over 8 hr; or
� 30 ppb over 1 hr.
� Progressive series of steps if problems develop
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HH22S PolicyS Policy
� Steps:
– Log complaints
– Determine nature, extent and severity of odor
problem
– Implement corrective actions (stop using
residuals, apply soil daily cover, etc.)
– Implement 24 hr. monitoring if not a specific
source using soil probes/wells and near-surface
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HH22S PolicyS Policy
� Steps (continued):
– Implement off-site gas monitoring if necessary
– Install gas collection, pre-treatment and flare
– Implement community communication plan
– Conduct additional off-site monitoring at
receptor locations
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Demonstration ProjectDemonstration Project
� Marion LF Demonstration Project
– Project Requirements
� Gypsum removal
– Concentrations of sulfate measured before and after
gypsum removal program
� Mix ratio of soils with fines and residuals
� Limited to residuals from only one C&D processor
� Monitored H2S generation
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Gypsum Wallboard Removal PlanGypsum Wallboard Removal Plan
� To create a low gypsum/sulfate product at
New Bedford Waste Services, they…
� Educated customers that gypsum wallboard is a problem
� Surcharged clients who delivered co-mingled gypsum
wallboard
� Bypassed all visual wallboard from the C&D processing line
� Hand sorted clean gypsum wallboard for recycling
� Created fines and residuals with a lower sulfate content
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Clean Gypsum Wallboard Clean Gypsum Wallboard
Recycling (covered container)Recycling (covered container)
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NBWS InNBWS In--house Sulfate house Sulfate
Levels Data Levels Data (pre(pre--gypsum removal)gypsum removal)
41,000 mg/Kg11/10/2005Fines/Residuals
38,000 mg/Kg11/11/2005Fines/Residuals
34,000 mg/Kg11/9/2005Fines/Residuals
57,000 mg/Kg11/8/2005Fines/Residuals
ConcentrationDateMaterial
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NBWS InNBWS In--house Sulfate house Sulfate
Levels Data Levels Data (post(post--gypsum removal)gypsum removal)
7,200 mg/Kg1/18/2006Fines/Residuals
4,800 mg/Kg1/19/2006Fines/Residuals
6,600 mg/Kg1/17/2006Fines/Residuals
4,900 mg/Kg1/16/2006Fines/Residuals
ConcentrationDateMaterial
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Marion LF Results to DateMarion LF Results to Date
� Odors have not developed
� No need for LF gas pre-treatment or flaring so far
� Monitoring Data:
– 15 soil gas probes inserted 12 feet into the LF
– H2S measured in the LF soil ranged from 0.0 ppm to
48.0 ppm (1 sample)
– H2S measured at the LF surface at 0.001 ppm or 1 ppb
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Looking ForwardLooking Forward
� Managing C&D has been interesting:– Processors stepped up to the plate and built
facilities
– Markets for reuse/recycling/diversion still an issue
– Still believe residuals and fines can be successfully used, but must apply BMPs
– Management of residuals key if processors are to remain a part of our C&D management infrastructure
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Looking ForwardLooking Forward
� Work To Do:
– Reduce the amount of residuals and fines generated� Firm up markets for C&D wood
� Expand wallboard recycling
� Recycle ceiling tiles and carpets
– Ensure use of residuals and fines will not cause problems in future
– Continually push for source separation to achieve better products
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Looking ForwardLooking Forward
� Ze-Gen Pilot Project – gasification of C&D wood
� Clean Wood BUD
� Biomass Projects
– Will facilities burning C&D wood get Renewable
Energy Credits (RECs)?
� Wallboard recycling
– Clean wallboard scraps currently recycled
– Old wallboard
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Need More Information?Need More Information?
� James Doucett – 617-292-5868
email – [email protected]
� MassDEP website
www.mass.gov/dep/recycle