35. DEMOLITION AND CONSTRUCTION WASTE (D&C)
Demolition and construction (D&C) waste is a solid waste, largely inert waste resulting from the construction, demolition or razing of buildings, roads, and other man-made structures. D&C waste consists of, but is not limited to, concrete, brick, bituminous concrete, wood , masonry, composition roofing and roofing paper, steel, and minor amounts of other metals like copper. Plaster (i.e., sheet rock or plaster board) or any other material, other than wood, that is likely to produce gases or a leachate during the decomposition process and asbestos wastes are not considered to be D&C waste.
35.1 INTRODUCTION
This chapter of the Douglas County Comprehensive Solid Waste Management Plan (DCCSWMP) outlines the regulatory framework overseeing D&C wastes, discusses the existing conditions and programs within the Regional Planning Area (RPA), establishes objectives to meet the existing and projected needs, identifies alternatives, and recommends actions for achieving the established objectives.
35.2 REGULATORY FRAMEWORK
35.2.1 Federal Requirements
Federal regulations do not prohibit the disposal of D&C waste into permitted landfills. But, as with any non-hazardous solid waste, the Resource Conservation and Recovery Act (RCRA) emphasizes recycling, reclaiming or reuse whenever possible and when markets are available.
35.2.2 State Requirements
The State of Washington Department of Ecology (DOE) does not prohibit the disposal of D&C waste into a permitted municipal solid waste landfill. The DOE does allow D&C waste to be disposed of into less regulated limited purpose landfills as per WAC 173.304.460(5). All limited purpose landfills must meet the following requirements:
- performance standards;
- location standards;
- design standards;
- operating standards;
- ground water monitoring requirements;
- closure requirements;
- post closure requirements;
- financial assurance requirements;
- permit application requirement.
Under Chapter 173.200 WAC no waste material may be disposed of in a special protection area. Special protection areas shall include, but not be limited to, the following:
- ground waters that support a beneficial use or an ecological system requiring more stringent criteria than drinking water standards;
- ground waters, including, but not limited to, recharge areas and wellhead protection areas, that are vulnerable to pollution because of hydrogeologic characteristics;
- sole source aquifer status by federal designation.
D&C wastes that meet the criteria as a dangerous waste must be disposed of according to the requirements of Chapter 173.303 WAC.
35.2.3 Local Requirements
Douglas County
Any jurisdiction, agency, private corporation, individual or other entity wishing to import D&C waste into Douglas County must conform to the Douglas County Solid Waste Importation Ordinance (DCSWIO). As specified within the ordinance a formal Letter of Request to the Douglas County Board of Commissioners requesting that their application for solid waste importation be reviewed is required. Only after the Douglas County Board of Commissioners have received a Letter of Request, will the review and approval process begin. The Douglas County Board of Commissioners will review the information contained within the Letter of Request with county staff and others. If it is determined by the Douglas County Board of Commissioners that sufficient information has been provided and that all known potential adverse impacts have been identified, assessed and mitigated, the request may be approved.
Within Douglas County no person shall deposit, discard or otherwise dispose of any D&C waste upon any public place within the county or upon a private residence or other private property not owned by him/her, or in any waters within the county except:
- when such property is designated by the state or any of its agencies or the county for the disposal of solid waste, and such person is authorized by the appropriate permitting authority to so use such property;
- with the prior written consent of the landowner approving of such disposal upon their private property.
Additionally, within Douglas County all owners or persons in control of any private residence or other private property shall at all times maintain the premises free of any D&C wastes that pose a risk to the public health and safety, the environment or create a nuisance.
35.3 EXISTING CONDITIONS
Both D&C wastes are generated within the RPA at a rate which is proportional to construction activity at any given time and therefore, dependent on the economic climate as well as population growth.
Within the RPA there are only two permitted disposal sites. The two permitted disposal sites within the RPA are:
- the Greater Wenatchee Regional Landfill and Recycling Facility
- the T.R. Miller Orchard Demolition and Inert Waste Landfill (restricted to only demolition and inert wastes)
The Greater Wenatchee Regional Landfill and Recycling Facility (GWRLF) does not break out the volume of D&C wastes collected annually, but rather includes it in their annual total of municipal solid waste. The GWRLF charges a reduced commercial rate for contractors disposing of D&C wastes. For non-contractors, the normal residential disposal rate is charged.
The T.R. Miller Orchard Demolition and Inert Waste Landfill received 2,860 cubic yards of D&C waste in 1999, has a total capacity of approximately 26,000 cubic yards and a remaining site life of nine years. The T.R. Miller Orchard Demolition and Inert Waste Landfill is operated by Pipkin Construction, who restricts its use and charges a fee for those who are allowed to use it.
The traditional methods of handling D&C wastes in the RPA include recycling, burning, or burial. The disposal option is decided upon by the owner or contractor of the D&C project. A typical D&C project might involve piling debris on site or on other private land where fill is desired. The pile might then be "picked" for valuable material, such as bricks and structural timbers and the remaining waste burned or buried.
Map 35-1. Demolition and Construction Waste Landfills within the RPA
The D&C waste stream within the RPA has been expanding in the past few
years due to increased construction and demolition, primarily within the Greater
East Wenatchee Area. Accurate information on D&C wastes generated within
the RPA is complicated by:
- lack of oversight, reporting and record keeping;
- burning or burial of D&C wastes as described above;
- traditional disposal of D&C wastes at unpermitted and illegal dump sites.
35.4 OBJECTIVES
35.4.1 Ensure that Demolition and Construction Wastes are Properly Managed
With owners and contractors being responsible for the proper management of their D&C wastes it is very important that the owners and contractors properly dispose of the D&C wastes. Failure of an owner or contractor to properly manage their D&C waste can pose a threat to the public health and safety and the environment.
35.4.2 Ensure that all Demolition and Construction Waste Limited Purpose Landfills Meet all Federal, State, and Local Regulations
With state regulations specifying how D&C waste limited purpose landfills are to be operated it is very important that the owner or operator of these facilities be properly educated. Failure of a facility owner or operator to comply with the state regulations can result in substantial penalties, fines and corrective actions.
35.4.3 Ensure that Programs Reflect Local Conditions
With the tendency of regulatory agencies to have a one-size fits all approach, it is imperative that all programs be locally supported and accepted. Because of the rural character of Douglas County and its cities and towns, all programs should reflect conditions that exist locally and not be driven by what the DOE deems as efficient or cost effective.
35.4.4 Ensure that Owners and Contractors have an Opportunity to Recycle
With restrictions placed upon how and where D&C waste can be disposed of, it is imperative that owners and contractors have convenient and economical recycling opportunities available. Failure to provide such opportunities may lead to improper disposal and possible enforcement action against the owner or contractor.
35.4.5 Establish a Demolition and Construction Waste Diversion Goal
It is the goal of the DCCSWMP to divert ten percent of all D&C waste from the municipal solid waste stream within the RPA.
35.5 ALTERNATIVES
35.5.1 Ban Demolition and Construction Wastes from the GWRLF
Another way to increase source-separated recycling is to prohibit the disposal of D&C waste into the GWRLF. One problem associated with disposal bans is illegal dumping of the banned material. Therefore, an important component of a disposal ban is the development of alternative handling and disposal methods. For example, if construction and demolition waste disposal is banned from the solid waste stream, a D&C waste collection and recycling facility must be available, convenient and reasonably priced to accommodate the diverted material.
35.5.2 Restrict Disposal to only Permitted and Approved Facilities
By restricting D&C waste disposal to only permitted and approved facilities, proper disposal, diversion and recycling opportunities will be available within the RPA. This will ensure that the facilities are operated in a manner that protects the public health and safety and the environment. However, there are currently many non-permitted collection and disposal sites within the RPA. As required by Chapter 173.304 WAC, all solid waste facilities are to be permitted by the Chelan-Douglas Health District (CDHD) and inspected at least annually. Facilities failing to obtain or apply for a solid waste facility permit are considered to be illegal dumpsites, and are in violation of state law and local regulations.
35.5.3 Site and Permit a Number of Demolition and Construction Waste Limited Purpose Landfills within the RPA
With only two permitted limited purpose landfills within the RPA currently, and with their use restricted, additional D&C waste limited purpose landfills, should be sited and permitted within the RPA. The actual number of D&C waste limited purpose landfills would depend upon the volume of material available, the geographical location of the facility in proximity to the source of material, convenience to the public and/or generator and federal, state and local siting and permit requirements. If the D&C limited purpose landfills were to be sited in close proximity to the source of material and were convenient to the public and/or generator, then disposal, diversion and recycling of the collected material would most likely take place. However, if too many D&C waste limited purpose landfills are sited and permitted within the RPA the overall available volume is dispersed to the point that the facilities may not be able to receive enough materials to sustain their operation.
35.5.4 Develop a Demolition and Construction Waste Technical Assistance Program
The DCSWPO could offer assistance to D&C waste generators by conducting workshops, providing regulatory guidance and on-site consultation. These services could offer the generator valuable assistance in gaining experience and knowledge that could take months or years to develop without outside assistance. For example, by utilizing the DCSWPO Resource Center the generator would have access to federal, state and local regulations, requirements and guidance as it pertains to the proper management of D&C waste.
35.5.5 Develop a Demolition and Construction Waste Education Program
The DCSWPO should develop a D&C waste education program. This program would specifically provide generators with the requirements, methods and options available to them to properly manage their D&C waste. The program could provide information on what constitutes D&C waste, how it is regulated, where it can be disposed of, and other similar information. The DCSWPO should develop brochures and information sheets to educate the public, generators and regulatory authorities about how D&C waste is to be managed properly. The reuse of D&C waste should be stressed over landfilling.
35.5.6 Monitor and Track Demolition and Construction Waste
The DCSWPO needs to monitor and track all D&C waste to determine who is generating the D&C waste, the volume of D&C waste being generated, where it originated from, where it is being disposed of, and how it is being disposed of. Without knowing these basic facts, it is impossible to properly manage the solid waste stream within the RPA. Therefore, the DCSWPO should establish a data tracking program which monitors and tracks all D&C waste disposed of within the RPA annually.
35.6 RECOMMENDATIONS
35.6.1 Restrict Disposal to only Permitted and Approved Facilities
35.6.2 Site and Permit a Number of Demolition and Construction Limited Purpose Landfills within the RPA
35.6.3 Implement a Demolition and Construction Waste Technical Assistance Program
35.6.4 Implement a Demolition and Construction Waste Education Program
35.6.5 Monitor and Track Demolition and Construction Wastes