A Debris Management Handbook for State and Local DOTs and Departments of Public Works (2014)

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85 C H A P T E R 1 1 Synopsis of Issues Disposing of disaster debris can pose a challenge to communities. Not only can it be costly, but landfill space is becoming increasingly limited, requiring communities to make alternate plans to dispose of their disaster debris. Certain types of debris are regulated and must be processed, transported, and disposed of in accordance with local, state, and federal requirements, which could require disposal in specially permitted facilities. To address the issue of limited landfill space as well as cost considerations, some communities employ reduction and recycling methods during debris operations. Volume reduction methods can substantially decrease the volume requirements for landfilling debris. Recycling limits the amount of landfill space required for debris disposal, is environmentally conscious, and can also return revenues to the jurisdiction that is doing the recycling. Target Audience • Debris managers, • Local officials, • Environmental officials, • Debris supervisors, • Landfill owners/operators, • Debris monitors, and • Solid waste officials. Why Are Debris Reduction and Disposal Important? Debris disposal involves the volumetric reduction and final disposition of disaster-generated debris. Disposal must be accomplished in accordance with all local, state, and federal environ- mental and health regulations, which can require special handling for different types of debris. Though historically disposal often occurred at landfills, the decreasing availability of space at these facilities is causing jurisdictions to evaluate other options. There are three methods of reduction to consider: chipping and grinding, incineration, and recycling—any of which can be used during operations. Disasters can generate thousands to millions CY of waste, and any debris in public areas that is not removed and properly disposed of may pose a public health and safety threat (see Figure 11.1 Reduction and Disposal

86 A Debris Management Handbook for State and Local DOTs and Departments of Public Works and 11.2). It is critical that local jurisdictions consider options for reduction and final disposal of disaster-generated debris during the planning phase. This ensures that sufficient space exists in landfills, opportunities are identified for recycling, and all applicable local, state, and federal environmental, health, and transport regulations are addressed. Reduction methods can greatly reduce the volume of landfill space required for disposal. As the amount of available landfill space decreases nationwide, recycling is becoming a prevalent part of disposal operations. In fact, some local and state governments have set ambitious policy goals and passed laws for solid waste diversion and recycling. Recycling can produce beneficial financial impacts for disaster recovery operations by reducing the amount of waste taken to a landfill, thus reducing the tipping fees paid to the landfill operator. Additionally, some types of debris have market value that can help offset removal costs. Appendix I provides some additional information on debris reduction. Figure 11.1. Vegetative debris can be a significant portion of the overall debris generated by many types of disasters. (Source: FEMA) Figure 11.2. This pile of mixed debris at a DMS will be sorted for additional processing. (Source: FEMA)

Reduction and Disposal 87 What Does Debris Reduction and Disposal Include? Debris disposal generally occurs after segregation and can involve the volumetric reduction of some materials. It is the final resting place for disaster-generated debris, and also the final step in the field operations for debris management. The amount of reduction may depend, in part, on the amount of available landfill space (versus the cost to reduce the waste volume prior to disposition). Reduction methods include: Chipping and Grinding Typically, chipping and grinding is the preferred method used to reduce the volume of vegetative debris (see Figures 11.3 and 11.4). However, these methods may also be applied to certain types of rubber, concrete, and metals before they are sent to a recycling plant. Chipping and grinding generally reduce the volume of vegetative debris material by 75 per- cent (FEMA 325) (25), and the residual material may be used for other purposes, such as Figure 11.3. Typical wood chipper. (Source: FEMA) Figure 11.4. Typical tub grinder. (Source: FEMA)

88 A Debris Management Handbook for State and Local DOTs and Departments of Public Works agricultural mulch (but not landscaping mulch), industrial heating and processing, or as landfill cover material. Several factors should be considered when determining if the chipping and grinding method should be used for reduction. The operations itself can be noisy, with large tractors and tub grinders performing much of the work. Thus, the equipment must be located properly on the site. Additionally: • The minimum exclusion zone around the grinding equipment is 300 feet because of the potential for flying objects to be ejected from the machines during operation. • Plastics, soil, and other contaminants must be removed prior to processing to minimize dam- age and wear and tear on the grinder or chipper. • Chips or mulch should be stored in piles not exceeding 15 feet in height, unless local regula- tions or the debris management safety plan prescribe another allowable height. • Mulch should be ground to the following dimensions: a maximum of 4 inches in length and 0.5 inch in diameter. If chippers and grinders are used for reduction of vegetative debris, equipment should be operated and maintained in accordance with manufacturers’ instructions. Buffer zones around the area of operation should be established to protect public health and safety. Forklifts, cranes, backhoes and trackhoes, bulldozers, and other similar equipment will be required to place materials into chippers, grinders, and shredders, as well as incinerators, and to load dump trucks for transporting materials to final disposal sites. In the case of equipment fuel or hydraulic fluid spills or leakages, affected areas should be cleaned up quickly, and soils tested to be sure no contamination occurs. Some states require that the spill or leakage be reported and appropriate forms completed and submitted. Recycling Recycling is another option for reducing and disposing of debris. Recycling may be particularly applicable to C&D debris, which may include concrete and metals. Recycling plants and reusers of recycled materials often have specific requirements depending on the types of products being supplied (for example, regarding grinding, shredding, and size of material). If recycling is part of disposal operations, it is important to understand the market specifications for these materi- als. When handled properly and with forethought, recycling can not only reduce the amount of waste brought to landfills; but also provide an economic opportunity to recover a portion of the costs of debris operations. It also can help lower overall debris operations costs by lowering trans- portation fees and tipping fees and reducing the amount of tracking and monitoring needed for debris operations. Specialty contractors may bid on well-sorted C&D debris. In addition to C&D materials, relatively clean soil may also be recycled; it may be mixed with ash or mulch and reused for agricultural purposes. Other recycling processes include (but are not limited to): • Metals (including white goods)—separated by ferrous/non-ferrous using an electromagnet (see Figure 11.5). • Soil—agricultural, must analyze for contaminants before use. • Construction materials—use directly or reduce for use as aggregate. • Wood—clean vegetative debris—mulch, fuel, or landfill cover (as previously discussed). • Sand—Depending on the cleanliness of sand and any specifications, may be reused. Many states and cities have facilities in the area that recycle a wide range of materials. During development of the debris management plan, recycling possibilities should be carefully researched. Appendix J provides additional information on reuse and recycling methods.

Reduction and Disposal 89 Incineration A common method used to reduce the volume of vegetative debris is incineration. Burning can result in volumetric reduction of up to 95 percent, and the ash sometimes can be recycled as a soil additive. The incineration process requires a minimum of three steps: 1. Unloading the debris, 2. Moving the debris into an incinerator, and 3. Removing the ash from the incinerator to final disposition. Final disposition may be an appropriately constructed area at the DMS or a landfill. Prior to final disposition, ash should be tested in accordance with federal, state, or local requirements. Incineration methods available for vegetative volume reduction include: • Air Curtain Pit Incineration—Vegetative debris is burned in a pit constructed by digging below grade or building above grade and using a specific type of blower (see Figure 11.6). The Figure 11.5. Metal maulers can be used in the metals recycling process. (Source: FEMA) Figure 11.6. Cross-section of an above-the-ground air curtain pit burner. (Source: FEMA)

90 A Debris Management Handbook for State and Local DOTs and Departments of Public Works pit and blower constitute an engineered system that must work together precisely. As there are no industry standards for design, knowledgeable personnel who are experienced with air curtain pit design and operations should oversee this process. This is extremely important, as the design and construction must be properly completed to ensure efficient operations. When constructed and operated properly, air curtain pit burners can effectively reduce the volume of vegetative debris by as much as 90 percent (FEMA 325) (25) without having an adverse impact on the environment. However, there are some things to consider: – The pit is typically 8 feet to 9 feet wide and 9 feet to 14 feet deep: length varies based on site size, environmental permitting, and labor and equipment limitations. – An impervious clay layer at the bottom of the pit should be at least 1 foot thick. – The ends of the pit are sealed to a height of 4 feet. – Nozzle ends should be sealed with 1 foot of soil. – Warning stops are at least 1 foot high. – Nozzles should be placed on one side of the pit, aimed so the primary air flow hits the opposite side of the pit two feet below the top. This causes the air to circulate down into the pit, causing more complete and efficient burning of the vegetative debris. The air curtain at the top of the pit forms a barrier to keep particulate matter in the pit for additional burn- ing, finally forming ash. – The blower nozzle should run the complete length of the pit (see Figure 11.7). – There should be a minimum 100-foot setback between debris piles and the incineration area. – There should be a minimum safety distance of at least 1,000 feet between an incineration area and the nearest building. – To prevent explosions, hazardous or contaminated flammable materials should not be placed in the pit. – All fires should be extinguished 2 hours before ash is removed. – The ash should be removed before it reaches 2 feet below the lip of the incineration pit. – Air monitoring devices may be required to ensure particulate matter is adequately contained. Figure 11.7. Open-air incineration pit. Note nozzles on left side. (Source: FEMA)

Reduction and Disposal 91 • Portable Air Curtain Incineration—This uses the same methods as the air curtain pit incinera- tion, but portable incinerators use a pre-manufactured pit rather than one that is dug or built on site (see Figure 11.8). They are usually more limited in size than the open pit. The primary advantage of a portable unit is that unlike an air curtain pit burner, it is not subject to erosion. This is a good option for sites with high-water tables (where digging a pit is not feasible or desirable). • Controlled Open-Air Incineration—Vegetative debris is carefully burned in a contained, fixed area. This method generally has little adverse environmental impact and is cost-effective. • Uncontrolled Open-Air Incineration—Debris is burned without controlling the amount or speed at which the incineration takes place. This method allows debris volume to be reduced quickly. However, this method may not meet environmental regulations and therefore is gen- erally regarded as the least desirable method of burning. If open-air incineration must be used, it is recommended that air quality be monitored to ensure that there are not adverse impacts to the surrounding community and environment. Conversion Technologies In some locales burn permits are increasingly difficult to obtain, landfill space is extremely limited, and recycling by itself is not sufficient to meet solid waste management goals set by governing authori- ties. Under these circumstances, some jurisdictions are exploring conversion technologies. “Conver- sion technologies” refer to a wide variety of technologies that can convert post-recyclable or residual solid waste into useful products, green fuels, and renewable energy through noncombustion thermal, chemical, or biological processes (31). The use of these technologies in addition to recycling has the potential to significantly reduce the amount of solid waste sent to landfills. Final Disposal When determining the location and method of the final disposition of the debris, it is impor- tant to determine the “final” state of the debris: will it be left whole, reduced, or recycled? Debris left whole may be better suited for the jurisdiction’s landfill, or sold for sale to private buyers. Reduced debris could also be disposed of at the landfill, or perhaps used as landfill cover. Reduced debris may also be of interest to private buyers as well. If the jurisdiction’s landfill is overburdened, an agreement with a neighboring jurisdiction may be appropriate for final debris disposition. If an agreement with a neighboring jurisdiction is the option of choice, it is vitally important to understand the landfill rules and regulations, such as tipping fee cost structure. This cost structure may include operating and maintenance costs, permitting fees, capital improvement Figure 11.8. Portable air curtain incinerator. (Source: FEMA)

92 A Debris Management Handbook for State and Local DOTs and Departments of Public Works costs, and taxes. The capital improvement costs may be directly related to the landfill itself or may be for projects within the county, and may not be eligible for reimbursement. Sometimes fees may be waived for neighboring jurisdictions. Where and When Does Debris Reduction/Disposal Take Place? Where debris disposal takes place in relation to other debris operations components can depend on the steps identified in the debris management plan. If the amount of debris is caused by a rela- tively small disaster, the plan may require segregation at the curbside rather than hauling to a DMS. Disposal (e.g., grinding and chipping) can then take place curbside as segregated debris would be picked up and then hauled to a landfill. If the plan calls for debris to be taken to a DMS, then disposal typically occurs after segregation. Materials that can be reduced or recycled are treated as they arrive on site. Materials that are not going to be reused, whether they have been reduced or not, are taken to a landfill when there is sufficient volume on-site to warrant trucking them off-site. • Various Disposal Options and Considerations: – Landfills: 77 C&D materials include concrete; asphalt from roads and roofing shingles; metals; bricks; glass; plastics; wood from buildings, salvaged building components (e.g., doors, win- dows, and plumbing fixtures); gypsum; and trees, stumps, earth, and rock from clearing sites. C&D landfills are regulated by state and local governments and are devoted exclu- sively to C&D materials. 77 RCRA Subtitle C Landfill—This category of landfill can accept hazardous waste. 77 RCRA Subtitle D Landfill—These municipal and non-hazardous solid waste landfills can accept household hazardous waste exempted from Subtitle C regulations. This cat- egory also includes garbage; non-recycled household appliances, residue from incin- erated automobile tires, scrap metal, wall board, empty containers, and sludge from industrial and municipal wastewater and water treatment plants and pollution control facilities. – Recycling: 77 Recycling centers. 77 Consider any additives to the materials that may make them illegal to recycle. 77 Mulch for agricultural purposes. – Fuel for energy recovery plants. – Composting—yard waste used as soil conditioner product or used in landfills in place of soil as alternative daily cover. Who Is Involved in Debris Disposal? There are potentially many parties involved in debris disposal operations: Jurisdiction The jurisdiction that “owns” the debris has overall responsibility for determining the debris management plan, which includes planning for disposal operations. This entity identifies target recycling and reuse rates, methods of reduction to be used (if any), and final disposal sites (land- fills). They are responsible for obtaining the proper permits, overseeing contractor performance, and ensuring that proper documentation of operations is maintained. The particular agency having responsibility will vary with each jurisdiction, but typically the department of public works or solid waste is designated as having primary responsibility.

Reduction and Disposal 93 Department of Environmental Quality (DEQ) The state environmental agency is responsible for issuing permits for reduction activities, particularly incineration. A DEQ also issues approval to use ash from burning operations as a soil or other additive, and oversees handling and disposal of hazardous materials and household hazardous waste. Department of Transportation The involvement of the DOT varies with the type of disaster and the needs. If FHWA is provid- ing funding for eligible work, the DOT usually will be the agency that coordinates that work. If FHWA is not involved, the DOT still may be involved. In some disasters, DOT resources may be temporarily reassigned to the disaster area to provide immediate assistance. The agency ensures that trucks used to transport debris meet state requirements, and that debris is transported according to regulations. In many instances, the ability of transportation routes to support the weight of the loaded trucks may also be available from DOT. Other State Agencies • Agriculture—May be involved in disposing of agricultural wastes and pesticides. May also assist with disposal of animal carcasses. • Forestry—May be involved in disposing of wastes such as termite-infested materials. • Health—May be involved in evaluating disposal methods for animal carcasses, radiological wastes. • Natural Resources—May assist with identifying recycling opportunities. • Environmental Protection—May assist in permitting and monitoring plans. Local Fire Department Should be notified prior to commencing incineration operations. Contractors • Hauling contractors—May assist with expediting reduction by dumping segregated wastes at the appropriate locations within a DMS. Must comply with transportation and environmen- tal regulations when hauling debris to a final disposal site. Working in accordance with the disaster management plan will expedite the operation. • Debris monitors—Ensure that debris loads are deposited at the appropriate locations within a DMS. Oversee and assist with removing contaminants from debris to be chipped, ground, recycled, and reused. Ensure that debris being hauled to a landfill, either directly from curbside pickup or from a DMS, is disposed of properly. • Specialty contractors—Bid on and haul recyclable materials to appropriate locations. Landfill Operators Identify available space, charge tipping fees, ensure final disposal is completed properly (in accordance with applicable regulations). Other Jurisdictions May enter into an agreement to provide facilities or technologies to assist with disposal opera- tions. Identify what level of compensation and taxes, if any, will be paid by the entity being assisted. Trucks hauling materials to disposal and recycling sites should comply with all local, state, and federal transportation regulations for transporting such wastes (e.g., bed liners, covers, permits, etc.).