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HomeMy WebLinkAbout2002_ROSCANS_1995State of North Ca, olina Department of Environment, Health and Natural Resources • a Division of Solid Waste Management James B. Hunt, Governor p E H [*NJ F1 Jonathan B, Howes, Secretary William L. Meyer, Director October 13, 1995 Wendell Parker, PhD. GAI Consultants -NC, Inc. 3812-H Tarheel Drive Raleigh, N.C. 27609 RE: Addendum B To Revised Site Hydrogeologic Report For The Proposed Cherokee County Landfill Dear Dr. Parker, There are still a few items in the Addendum B Report that need further clarification. Please address the following comments: (13) (B) Although the response to this comment was generally adequate, it should be made clear that there are no critical receptors (drinking water wells) between the proposed MSWLF units and the discharge features (Valley River and its tributaries). Therefore it is unlikely that a release from the facility would have a significant adverse affect on.ground-water receptors. Discussion was provided regarding surface water receptors. (13) (C) The intent of this rule is to establish the suitability of the site for solid waste management activities based upon the hydrogeologic characteristics of the site. Also based upon the hydrogeological characteristics of the site, discussion should be provided as to which parts of the proposed facility are (most) suitable for fill activities. For example, overall a site may be suitable for landfilling, however fill activities would not be possible in areas of streams, wetlands, floodplains, unstable areas, or areas that could not be effectively monitored. This would eliminate certain portions of a proposed facility. Of the portions of a site where solid waste management activities could be permitted, some areas may be more suitable for landfilling than others due to depth to rock, depth to ground water, or other hydrogeologic factors. Therefore some parts of a facility may be more suitable than others for fill activities. This type of evaluation and discussion needs to be provided for the proposed Cherokee County facility. P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 1 50% recycled/ 10% post -consumer paper Cherokee Site Study Page 2 (13) (D) The intent of this rule is to establish that based upon the hydrogeologic characteristics of the site it is possible to effective monitor ground -water quality. For example, for sites having a saprolite aquifer where it is possible to define the direction and rate of flow and develop a fairly good understanding of the ground -water flow paths of the uppermost aquifer, then properly located and designed monitoring wells should be capable of providing an effective monitoring system. This may not be possible in other hydrogeologic regimes, such as karst terrain or a purely fractured bedrock aquifer. The hydrogeologic characteristics of each site are different. Some sites are more easily monitored than others. Some sites may require alternative monitoring systems other than monitoring wells. This type of evaluation and discussion needs to be provided for the Cherokee County site. Table 3-1 Default Values For Effective Porosity: There has been on prior reference indicating this table is endorsed by EPA. Nor has any documentation been provided indicating this table is endorsed by EPA. If it is, are the default values referenced in a context such that they are representative of glacial till soils only, or are they referenced in a wider context of being representative of soils having the various soil classifications regardless of geologic setting? Please show me this reference source so we can resolve this issue. Ground -water Velocity Data For Lithologic Units I And II: The intent of Rules .1623(a) and .1631(c)(2) is to develop a good understanding of the hydrogeologic characteristics of the uppermost aquifer so as to effectively design the landfill, design an effective water quality monitoring system, and in the event of a release to be able to predict the direction and rate of flow and how the contaminant plume will migrate. Both of these rule references require developing an understanding of the hydraulic characteristics of the various lithologic units. This includes the units of the unsaturated zone, since in the event of a contaminant release these zones could become saturated. Or in the case of the Cherokee County site, the seasonal high water table elevations indicate saturated conditions do occur in both Units I and II during certain seasons of the year. Gradients can be estimated based upon likely situations where conditions could become saturated, and ground -water velocities can then be calculated. Dr. Wendell Parker Cherokee Site Study Page 3 Please provide additional responses to these comments as soon as possible so the Solid Waste Section can complete the technical review of the Cherokee County Site Study. If you have any questions about this letter, you may contact me a (919) 733-0692, extension 258. Sincerely, 9417 V<+ Bobby Lutfy Hydrogeologist Solid Waste Section CC: Bill Sessoms, Solid Waste Section J`�n Pa_ttersari' SWS - Asheville Richard Honeycutt, Cherokee County Manager Jimmy Woodie, Municipal Engineering Services =ENT B`i': E3- 'L-'='5 04: 52F11 # MUCH TURMOIL jXISTS IN OUR COMMUNITY ABOUT THE FUTURE OF SOLID WASTE AND WHERE THE NEW LANDFILL, IF CONSTRUCTED, WILL BE LOCATED. WE SUBMIT TO YOU THAT IF CHEROKEE COUNTY BUILDS A LANDFILL ANYWHERE, IT SHOULD BE AT THE PROPOSED LOCATION ON THE WEST PROPERTY. OUR DECISIONS MUST BE MADE WITH THE INTERESTS OF THE WHOLE COUNTY IN MIND AND AT HEART. ANY LOCATION IN CHEROKEE COUNT' WILL GENERATE PUBLIC OUTCRY IF SELECTED AS A LANDFILL SITE! NO MATTERWHERE WE SAY A LANDFILL SHOULD BE BUILT SOMEONE WILL FIND FAULT WITH THE SITE SELECTED! WE HAVE SPENT MUCH TIME AND EFFORT LOOKING AT ALL POSSIBLE ALTERNATIVES TO THE CONSTRUCTION OF A LANDFILL FOR CHEROKEE COUNTY. WE SHALL EXAMINE EACH OF THESE ALTERNATIVES AND GIVE YOU A BRIEF DESCRIPTION OF THE CRITERIA AND COSTS THAT WE HAVE IDENTIFIED WITH EACH ALTERNATIVE. THESE ALTERNATIVES ARE PRESENTED IN NO PARTICULAR ORDER, SIMPLY THE ORDER THAT WE ARRANGED THE WORK PAPERS WHEN WRITING THIS REPORT. ALTERNATIVE NUMBER 1 CONTRACT HAULING OUT OF COUNTY THE PROPOSAL DF HAULING THE SOLID WASTE OUT OF THE COUNTY TO A PRIVATE LANDFILL HAS BEEN EXAMINED. THE BEST PRICE THAT WE HAVE COME UP WITH IS CURRENTLY $26.10 PER TON THROUGH THE GATE AT BALLGROUND, G ORGIA AT A LANDFILL RUN BY SANIFILL, INC., A SUB- TITLE D LAND ILL AS REPRESENTED BY THE OWNERS, HAS SPACE FOR ANOTHER TWENT (20) YEARS OF OPERATION ON THE PRESENTLY ENGINEERED SITE, WITH MO E LAND AVAILABLE FOR USE THAT IS ALREADY OWNED BY THE COMPANY BUT N T YET PERMITTED. SANIFILL HAS ESTIMATED THAT THEY WOULD HAUL TH WASTE FOR CHEROKEE COUNTY FOR APPROXIMATELY $15.00 PER TON BRING NG THE TOTAL COST TO $41.10 PER TON. CHEROKEE COUNTY PRESENTLY LES FIFTY (50) TONS PER DAY, SEVEN DAYS PER WEEK OR 18,250 TONS P R YEAR. THIS WOULD COST CHEROKEE COUNTY $750,075.00 PER YEAR. C EROKEE COUNTY WOULD CONTINUE TO HAVE TO HANDLE THE GREENBOXES AND COLLECTION DUTIES AT ADDITIONAL COSTS OF $600,000.00 PER YEAR. IN ORDER TO CONTRACT HAUL, WE WOULD HAVE TO CONSTRUCT A TRANSFER STATION THAT IS ESTIMATED TO COST ANOTHER $100,000.00 TO CONSTRUCT. CHEROKEE COUN Y WOULD ALSO HAVE TO CONSTRUCT A DEMOLITION LANDFILL WHERE BUILDING DEBRIS COULD BE PLACED. THIS TYPE OF DEBRIS IS THE WOOD, SHINGLES), CONCRETE, ASPHALT, ETC., THAT IS LEFT OVER DURING THE REMOVAL CF OLD BUILDINGS AND PARKING LOTS AND IN REMODELING PROJECTS. -EHT B', : n3- -9E n : 5^FY 1 � 14 WE ESTIMATE THAT WE WOULD NEED A TWENTY ACRE SITE FOR THIS TYPE OF OPERATION WITH NECESSARY EQUIPMENT. COVERING WOULD BE REQUIRED BUT NOT ON A DAILY BASIS AS IS NOW THE CASE. WE WOULD STILL HAVE TO TAKE CARE OF THE OLD TIRES AND THE OLD WHITE GOODS (APPLIANCES). ANOTHER POINT WITH TRANSFER STATIONS IS THAT THE "JUICE" THAT RUNS BY SOME MEANS TRUCK. 1995-95 1996-97 1997-98 1998-99 1999-2000 2000-2001 2001-2002 2002 -2 003 2003-2004 2004-2005 REPLACEMENTS: 1996 TRUC 1999 TRUC 2001 TRUC 2004 TRUC TRANSFER STATI DEMOLITION LA 20 ACRES * ASSUMPTION 0 3.2%; CPI AND TONNAGE FOR TO PAY FOR BOTE BOTH THE CURRE COMMERCIAL HAUI SOME $.14 PER FROM THE CURRET A SEWAGE TREATMENT PLANT EITHER BY PIPE LINE OR BY 3.2% PER YEAR CPI ILL $11,000 CONSTANT CONSTANT ISPOSAL DISPOSAL COSTS OPERATIONS TOTAL $750,075 $ 692,875 $1,442,950 774,077 734,450 1,508,527 798,847 778,500 1,577,347 824,410 825,200 1,649,610 850,791 874,700 1,725,491 878,016 927,200 1,805,216 906,112 982,850 1,888,962 935,107 1,041,820 1,976,927 965,030 1,104,300 2,069,330 995,910 1,170,500 2,166,410 150,000 175,000 200,000 225,000 100,000 220,000 13mimmumme OPERATIONS, CHEROKEE COUNTY WOULD HAVE TO DOUBLE T $35.00 LANDFILL FEE AND THE TIPPING FEES FOR ;RS FROM $36.00 PER TON TO $72.00 OR INCREASE TAXES UNDRED MAKING THE TAX RATE APPROXIMATELY $.61 UP $.47. SENT BY: 0 —95 04:54FFe1 a H 4 ALTERNATIVE NUMBER 2 CONSTRUCTION OF A LANDFILL IN LOOKING WE SHOULD AT THE LOOK L051'6 Ur nulLLlliVV ti l�L•• ��•.Ly---, _ AT A TEN (10) YEAR COST STUDY SO THAT THERE ARE NO SURPRISES. WE MUST FACTOR IN THE COST OF THE LAND, THE INTEREST COSTS FOR THE LAND PURCHASE, THE CONSTRUCTION COSTS OF THE LINED CELLS, THE DESIGN COSTS AS WELL AS THE OPERATION COSTS AND EQUIPMENT REPL CEMENT COSTS OVER THE ENTIRE TEN (10) YEAR PERIOD. THESE COSTS AR� AS FOLLOWS: 11 ACRES OF CELL @ $350,000 PER ACRE $3,850,000 DESIGN/Q /QC 175,000 LAND COST 850,000 INTEREST ON LAND 360,208 1995-96 CPERATIONS 692,875 1996-97 734,450 778,500 1997-98 „ 825,200 1998-99 " 874,700 1999-200C 927,200 2000-01 982,850 2001-02 1,041,820 2002-03 1,104,300 2003-04 " 1,170,500 2004-05 647,530 EQUIPMEN (DOZER, RACKED LOADER AND FINANCING) 1996 CO ACTOR TRUCK REPLACEMENT 150,000 175,000 1999 CO ACTOR TRUCK REPLACEMENT 2001 CO ACTOR TRUCK REPLACEMENT 200,000 2004 CO ACTOR TRUCK REPLACEMENT 225,000 $15,765,133 THIS ALTERNAT VE WOULD ALSO CAUSE THE LANDFILL CHARGES TO DOUBLE OR A TAX INCREAS OF SOME $.12 TO $.16 IF THE LANDFILL FEES WERE NOT INCREASED. EITHER ALTERNATIVE NUMBER 1 OR 2 WOULD CAUSE A SUBSTANTIAL INCREASE IN FEES OR TAXES OR BOTH. I PERSONALLY SUPPORT THE IDEA OF THE USERS OF THE YSTEM PAYING FOR THE COSTS. WE HAVE LAND OWNERS, WHO BECAUSE OF THEIR LAND HOLDINGS WOULD PAY A LARGE AMOUNT OF LANDFILL SEIIT BY: l]'- -95 04:55FI1 k# c FEES IF WE USED THE LANDFILL S CHEROKEE COUNTY LANDFILL SERVIC THE ARGUMENT CA SCHOOL SYSTEM W1 MAY WELL BE THE FUNCTION, SOLID STARR ENTERPRI; ESTABLISH MANNE AND ESTABLISH 1 LEASE THE CURRE GOODS AREA AS W1 FUNCTIONING. 'I AT LEAST ANOTHE BY STARR ENTERP PER POUND OF c STANDARDS THIS AVERAGE $144.5 ON THE 2.2 POL RECYCLABLE MAT CONVENIENCE CEN AND TAKEN AT r CAROLINA COLLEC AND DISTRIBUTES AGREED TO ACCE3 FURTHER CHARGE'S TO CONTINUE TH: SCRAP TIRE REMC COMMERCIAL USE FOR SOLID WASZ WHAT CHEROKEE I OR 2. THE PROPERTY TAX SYSTEM WHILE USING VERY LITTLE OF .'STEM. WE HAVE PEOPLE WHO DO NOT LIVE HERE IN BUT WHO OWN LARGE TRACTS OF LAND THAT WOULD PAY FOR 3S THEY WOULD NEVER USE. d BE MADE THAT THESJ; SAME ehVeii l-UlNlm-Lmuln ill "' ILE NOT HAVING A CHILD IN SCHOOL HERE EITHER. THIS CASE, BUT SCHOOLS HAVE ALWAYS BEEN A GOVERNMENTAL WASTE HAS NOT. ALTERNATIVE NUMBER 3 CONTRACTED SERVICES ;ES HAS MADE A PROPOSAL TO CHEROKEE COUNTY TO D CONVENIENCE CENTERS, CONSTRUCT A TRANSFER STATION, WHITE GOODS SYSTEM. THEY HAVE ALSO PROPOSED TO VT LANDFILL AREA FOR THE TRANSFER STATION AND WHITE sLL AS MONITORING AND KEEPING THE METHANE GAS SYSTEM HIS METHANE GAS SYSTEM WILL REQUIRE MONITORING FOR R TWENTY—FIVE (25) YEARS. THE PROPOSAL AS SET OUT RISES WOULD CHARGE THE PEOPLE USING THE SYSTEM $.09 OLID WASTE DISPOSED OF. USING CURRENT INDUSTRY WOULD MEAN THAT A FAMILY OF TWO ( 2 ) WOULD PAY ON 4 PER YEAR FOR SOLID WASTE DISPOSAL. THIS IS BASED NDS OF SOLID WASTE GENERATE PER PERSON PER DAY. ERIALS WOULD BE ACCEPTED AT NO CHARGE BY THE TERS. WHITE GOODS WOULD BE BROUGHT TO THE LANDFILL 0 CHARGE TO THE INDIVIDUAL. THE STATE OF NORTH TS A WHITE GOODS DISPOSAL TAX ON ALL NEW APPLIANCES THE PROCEEDS TO EACH COUNTY. STARR ENTERPRISES HAS IT THIS MONEY FOR WHITE GOODS DISPOSAL AND MAKE NO TO THE COUNTY. STARR ENTERPRISES HAS ALSO AGREED CONTRACT CHEROKEE COUNTY HAS WITH U.S. TIRE FOR ,VAL . WOULD PAY SOMEWHERE IN THE RANGE OF $41.00 PER TON SERVICES TO STARR ENTERPRISES, SOMEWHAT LESS THAN JNTY WOULD HAVE TO CHARGE UNDER EITHER ALTERNATIVE THE MANAGEMENT AT SANIFILL HAS WRITTEN THAT THEY WILL ACCEPT ANY TYPE OF SOLID vrASTR EXCEPT THE FOLLOWING: 1. REGUIATED HAZARDOUS WASTE 2. RED BAG MEDICAL WASTE 3. LIQUID WASTE THIS MEANS THAT BUILDING WASTE MATERIALS AND OTHER DEMOLITION MATERIALS COULD BE ACCEPTED BY STARR ENTERPRISES FOR DISPOSAL AT THE SANIFILL SITE. '=.EI 1T BY: 0�3-22-95 04:55PIl1 H F, RESIDENTIl COMMERCIA] COSTING STARR'S PROPOSAL - $.09 PER POUND - $41.00 PER TON 50 TONS PVR DAY GREENBOXE� ARE RESIDENTIAL BALANCE C MMERCIAL 31 DAYS 1,550 TONS GREENBOXES 759 TONS COMMERCIAL 791 TONS RESIDENTIAL - 759 X 2000 @ $-09 COMMERCIAL - 791 @ $41.00/TON YEARLY COST YEARLY RESIDE TIAL COSTS YEARLY COMMER IAL COSTS 1995-96 1996-97 1997-98 1998-99 1999-200 2000-200 2001-200 2002-200 2003-200 2004-200 3.2% CPI TOTAL 10 YEARS $136,620.00 32 431.00 $169,051.00 $2,028,612.00 $1,639,440.00 389 172.00 $2,028,612.00 $2,028,612.00 2,093,527.00 2,160,519.00 2,229,655.00 2,301,000.00 2,374,632.00 2,450,620.00 2,529,039.00 2,609,968.00 2,693,486.00 $23,471,058.00 THIS SYSTEM WOULD NOT COST CHEROKEE COUNTY ANY DIRECT CHARGES. THE CHARGES FOR WHITE GOODS AND SCRAP TIRES WOULD BE OFFSET BY STATE FUNDING FOR THESE TWO TYPES OF MATERIALS. THE USERS OF THE SYSTEM WOULD PAY ALL CHARGE ONCTHEEAMOUNTIOFSWASTE DOSPOSEDSO ENCOURAGE RECYCLING TO CUT DO THIS SYSTEM AND THE ESTA VIGOROUS ENI ILLEGAL DUMP BUT THE PROB] OF THE COURT IOULD FOR A TIME BE LIKELY TO CAUSE ROADSIDE DUMPING 3LISHMENT OF "LOCAL DUMPS". THIS CAN BE REVERSED BY ORCEMENT OF LITTERING LAWS AND PROSECUTION OF ALL > AND "DUMPERS". WILL EVENTUALLY REVERSE ITSMONTHS WITH THE COOPERATION EM SYSTEM. 3EIAT BY: 0 -22-95 04:57PH a kt WE FEEL THAT ST. AT THE SITES. THE SITE. THI: THE AMOUNT OWE' MAKE SURE THAT WOULD BE SOMEWE LRR'S PROPOSAL WOULD BE CUMBERSOME WITH A BOTTLENECK FHE PROPOSAL WAS FOR ONE ATTENDANT TO BE PRESENT AT ATTENDANT WOULD HAVE TO WEIGH EACH BAG, CALCULATE i, MAKE CHANGE, AND CHECK THE RECYCLEABLES BAGS TO NO GARBAGE WAS PRESENT IN THE RECYCLING BAG. THIS r.nr_T_r_n_MvTTS_F_. RACKUP AND TRAFFIC JAMS AT THE M RE HEAVILY HELP THE SITU TION, BUT SYSTEM FOR THE "ROADSIDE 7ULY111Nk7 tuu." TS USED SITES. MULTIPLEOULD BYTTENDANPASS COULD IT IS FELT THAT MANY W DUMP" BECAUSE OF THE TIME INVOLVED. Y COST CHEROKEE WHILE HE CITIZENS OSAL OULD NOT AND BUSINESSES SOMEWHAT COUNTY, SOMEWHAT MORE THAN COST TEITHER WOULD COST ALTERNATIVE NUMBERS 1 OR 2. ALTERNATIVE NUMBER 4 REGIONAL INCINERATION SINCE JACKSON COUNTY HAS JOINED THE CAST OF COUNTIES LOOKING ABOUT FOR AN ANSWE TO THE SOLID WASTE DILEMMA SEVERAL INTERESTED INDIVIDUALS HAVE BEEN SEARCHING FOR ALTERNATIVES TO LANDFILL CONSTRUCTION. ONE IDEA THAT HAS SURFACED AND HAS MERIT IS THE ENCAPSULATED INCINERATOR. THIS SYTEM IS CURRENTLY BEING CONSTRUCTED IN NEW TECHNOLOGIESMEICO ON INDIAN AND NEW RESERVATION. ON HOW TO MAKE THE MIXTURE OF CURRENT INCINERATION OF SOLID WASTE SOMEWHAT LESS EXPENSIVE. THIS SYSTEM USES A SYSTEM WHICH MOST ANYTHING CAN BE SHREDDED AND PLACED IN MAGAZINES FOR LOADING INTO THE GAS ORINCINERATOUEL OIL R. THE THE INCINERATOR I STARTED BY NATURAL GAS, OPERATING TE ERATURE IS REACHED AND THEN THE SHREDDED MATERIAL IS LOADED INTO THE BURNING CHAMBER. COMBUSTION IS VERY COMPLETE WITH A RESIDUE OF OUT 8% TO 15%, DEPENDING ON MATERIALS BURNED. THE UNIQUE PART O THIS SYSTEM IS THAT THE "ASH" IS BENIGN AND IS USED IN MAKING BUILDING STONE, MUCH LIKE CINDER BLOCKS. COUPLED TO THIS INCINERATOR ES TZ,LEAST GENERATE (ELECTRICITY GENERATING FOR SALE PLANTS TO UBLIDC ELECTRIC TUR INE UTILITIES. THE SALE OF ELECTRIC POWER AND USE OF THE "ASH" IN BUILDING BLOCKS LEAVES ONLY OUBEFDISPOHS DROP EVERY EIGHTS(8) OTTENALIO)RDAYSHE SMOKE STACKS O NOW BEFORE E ERYONE GETS TOO EXCITED ABOUT THIS SYSTEM, LETS LOOK AT THE PRIC - $30,000,000.00. THAT'S RIGHT, THIRTY MILLION DOLLARS! THIS PROJECT 9OULD REQUIRE MULTI -COUNTY COOPERATION AND FUNDING AND COORDINATION OF WASTE STREAMS TO CONT NU INSURE THE ABILITY TO PROVIDE ELECTRIC POWER IS - EACH ALTERNA IVE HAS GOOD POINTS AND BAD POINTS. SOME ARE MORE EXPENSIVE T AN HEDCOOPERATION. SOME HAVE PROBLEMS E MAIN POINT HERE REQUIRING STOSHOW MUCH CONTRACT WOR -,EIIT BY': M-22-gE 04:58FN ? t# 8 WE HAVE EXAMI ED EACH AND EVERY ISSUE AND FEASIBLE ALTERNATIVE AVAILABLE TO U THAT IS ALLOWED BY LAW. COMPOSTING HAS NOT BEEN CONSIDERED HERE BECAUSE THE INDUSTRY AS WE KNOW IT TODAY fEQUIRES SOMEWHERE AROUND TWO HUNDRED ^(200)�TONS TOF MUNICIPAL SLUDGE TO START THE PROCESS. THERE DOES NOT EXIST AT THIS TIME A FE SIBLE MARKET FOR THE END MATERIAL. WITH ALTERNATIVE NUMBERS 1 AND 3 WE HAVE TO DECIDE IF WE HAVE ENOUGH ASSURAITCES THAT THE MANAGEMENT OF THE LANDFILLS WILL CONTINUE TO OPERATE THE SITES WITHIN THE BOUNDS OF THE LAW. WE HAVE SEEN THE EPA VOID HOLD HARMLESS AGREEMENTS AND PASS CLEANUP COSTS ALONG 10 THOSE THAT SENT MATERIALS TO THE LANDFILLS, REGARDLESS OF ANY CONTRACTS OR EVEN THE AMOUNTS OF MATERIALS SENT. WE MAY HAVE SE4T ONLY 3915 OF THE WASTE STREAM AND YET BE ASSESSED 20W OF THE CLEIMP COSTS. THESE ISSUES MUST BE CAREFULLY EXAMINED AND COURT CASE REVIEWED TO DETERMINE HOW TO SHIELD CHEROKEE COUNTY FROM EXTREME LIABILITY. IT MAY BE POSSIBLE TO PURCHASE SPECIAL INSURANCE OR RAVE THE LANDFILLS PURCHASE SPECIAL INSURANCE COVERAGE AVAILABLE TO LIMIT OUR EXPOSURE. ON FEBRUARY 2 1995, CHEROKEE COUNTY COMMISSIONERS AND STAFF REVIEWED A SYSTEM TO REDUCE AIR EMMISSIONS FROM SMOKE STACKS. THIS TECHNOLOGY HAS AN APPLICATION IF CHEROKEE COUNTY DECIDES TO UTILIZE AN INCINERATOR. INCINERATION AS WE NOW KNOW IT HAS A REDUCTION RATE OF ABOUT THREE TO ONE. THIS MEANS THAT THREE TONS OF WASTE WILL BE REDUCE TO ONE TON OF ASH. THE IMPORTANT THING TO REMEMBER NOW IS THAT IN JUNE OF 1994 THE UNITED STATES SUPREME COURT ISSUED A DECISION T T ASH FROM A MUNICIPAL WASTE INCINERATOR MUST BE CHEROKEE COUN Y AT THE PRESENT TIME PRODUCES FIFTY (50) TONS OF SOLID WASTE P DAY! THIS IS SEVEN DAYS PER WEEK OR 18,250 TONS PER YEAR! IF FORTY (40) ER CENT OF THIS WASTE STREAM IS OF THE TYPE THAT CAN BE INCINERATED, THEN WE MUST BUILD FOR TWENTY (20) TONS PER DAY OF INCINERATION WITH A CORRESPONDING ASH VOLUME OF 6.6 TONS PER DAY. CURRENT RATES AT THE BARNWELL, SOUTH CAROLINA SITE ARE $300.00 PER TON DELIVERED. THIS MEANS THAT WE WOULD INCUR DISPOSAL COSTS OF $1,980.00 PER DAY NOT INCLUDING TRANSPORTATION COSTS. THIS WOULD AMOUNT TO $722,700.00 PER YEAR IN ASH DISPOSAL COSTS WITHOUT CONSIDERING THE TRANSPORTATION COSTS. THERE ARE SEVERAL INCINERATORS IN USE THROUGHOUT THE UNITED STATES. THESE INSTALLATIONS ARE MOST ALWAYS SITED IN LOCALITIES THAT PRODUCE 250 To 300 TONS OF SOLID WASTE PER DAY. WE IN CHEROKEE COUNTY ARE NO AT THAT POINT. ANYTIME AN INCINERATOR IS BEING CONSIDERED, W MUST REMEMBER THAT ALL SYSTEMS THAT RELY ON COMBUSTION MU T HAVE A SMOKE STACK. INDUSTRIES HAVE INVESTED BILLIONS OF DO LARS IN CLEANING UP THE SMOKE STACK EMMISSIONS FROM EVERYTHING FR THE IRON AND STEEL INDUSTRY TO POWER PLANTS. THE SEIIT B`r': v13-22-95 05:00Pm # 'p SYSTEM THAT W DEMONSTRATED ON FEBRUARY 25, 1995 WOULD BE USEFUL AFTER THE CONSTRUCTION OF NORMAL STACK SCRUBBERS AND EMMIS I N CONTROLS. SUCH A SYSTEM AS WAS DEMONSTRATED CANNOT BE USED WITHOUT NORMAL CONTROLS AND SCRUBBERS. REDUCTION THAT THE UNIT IN AI COSTLIER TO COP HIGHER OPERATI] THE HIGH TEMPE. 1THE"UNIT DESCRIBED IN ALTERNATIVE NUMBER 4 DOES. rERNATIVE NUMBER 4 IS MUCH MORE ADVANCED AND MUCH STRUCT THAN A CONVENTIONAL INCINERATOR AND HAS MUCH IG COSTS THAN NORMAL DUE TO THE FUEL USED TO ATTAIN ATURES NEEDED BY THE SYSTEM, CONVENTIONAL INCINERATOR $38/TON 20 TONS DAY 7 DAYS / WEEK 30 TONS STILL HAVE TO DO SOMETHING WITH DISPOSAL 2,555 @ $300 BARNWELL, SC TRANSPORTATION $15/TON ESTIMATED OPERATI 30 TONS/DAY/36 1995-96 1996-97 1997-98 1998-99 1999-200( 2000-2001 2001-200,' 2002-200- 2003-200� 2004-200'_ WITH CONVENTI( BE REQUIRED. LINED LANDFIL OUTSIDE CHERC SOMEWHAT MORE 10,950 @ 41.10 $ 277,400 766,500 38,325 $ 1,038,225 692,875 $ 1,731,100 450,045 $ 2,181,145 $ 2,181,145 2,250,941 21322,971 2,397,306 2,474,019 2,553,187 2,634,889 2,719,205 2,806,219 2 896,018_ $25,235,900 )NAL INCINERATION, LANDFILLNG OF SOME MATERIALS WILL THIS MEANS THAT WE WOULD STILL HAVE TO CONSTRUCT A OR CONTRACT FOR HAULING TO A COMMERCIAL LANDFILL KEE COUNTY. THIS SYSTEM WOULD ALSO PROVE TO BE EXPENSIVE THAN ALTERNATIVES 1, 2 OR 3. State of North Cal ..,na Department of Environment, Health and Natural Resources • • Division of Solid Waste Management James B. Hunt, Jr., Governor y p E H N F1 Jonathan B. Howes, Secretor William L, Meyer, Director January 30, 1995 Paul Jordan Director Tri-County Solid Waste Management Authority 115 Peachtree Street Suite 103 Murphy, North Carolina 28906 Re: Proposed Tri-County MSWLF Site Study Review Mr. Jordan: The Division of Solid Waste Management, Solid Waste Section (Section) has completed the preliminary review of the above referenced project. The following items must be provided or addressed in order to continue the review process. Revisions to the application must be made in accordance with 15A NCAC 1313 .1603(b). 1618(c)(1) On the regional map indicate the following: names of subdivisions and commercial areas, local government incorporated limits, local government extra territorial jurisdiction limits, areas served by public water and sewer and known or potential sources of ground water contamination. In the report discuss the general regional characterization, including topography, water supplies, sewerage services, rivers and streams, land uses, and any other pertinent features. The report should also contain discussion with regards to the proposed site's relationship and impact or lack of impact to the Town of Andrews and surrounding communities. .1618(c)(2) Local area map must be of a scale and detail that shows the immediate region and features within the 2,000 foot perimeter of the proposed site. Include on the local map pertinent features described above and the following (also include on the aerial photograph): all water courses, both perennial and intermittent, zoning (if any) within the 2000 foot perimeter. It is strongly recommended that existing topography, at an appropriate contour interval, be shown on the local area map. P.O, Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer "recycled/ 10% post -consumer paper Tri-County Site Study Initial Review Page 2 Report should discuss all pertinent natural and man made features within the local study area. Public water systems and sewerage systems should be shown and discussed. Indicate on -site cemetery on map and include dis-e ussian of proposals for protectiDn and access in the report. Also show location of the cemetery on the proposed facility plan. Private wells should be cross-referenced with well records (also refer to hydrogeology review memorandum). No information was presented to document search for CERCLIS, State Superfund, National Priority List, RCRIS Notifiers, Registered Storage Tanks, and Leaking Registered Storage Tanks, sites. 1618(c)(3) For hydrogeologic comments, refer to Memorandum from Bobby Lutfy to Bill Sessoms, dated October 19, 1994 (copy enclosed). .1618(c)(4) Location Restriction comments - see following comments under .1622. 1618(c)(5) Local government approval with regards to site selection public hearing, zoning, and operational consistency is well documented. In accordance with North Carolina General Statute §130A-294(b1)(2), a copy of the Site Study was forwarded to Cherokee County. Provide documentation that the proposed site complies with subdivision or land use planning ordinances or that there are no applicable ordinances. 1618(c)(6) Include discussion of proposed leachate handling and treatment. Additional comments regarding the proposed facility plan are included under location restrictions. 16220) Request, and include in report, FAA comments or response regarding proposed siting with regards to the alignment and approach paths of the runway of the existing airport. Include information on proposed methods to control potential bird strikes. Recommend utilizing technical guidance found in EPA Technical Manual Solid Waste Disposal Facility Criteria (EPA530-R-93-017, PB94-100-450). Also enclosed for your use is a copy of Report On The Potential Hazards To Aircraft In Locating Waste Disposal Sites In the Vicinity Of Airports. Include North Carolina Aeronautical Chart or USGS quadrangle map indicating airport and showing distances from the landfill. .1622(3) Wetlands along the interior drainage feature, as well as other wetland features, should be buffered in accordance with recommendations Tri-County Site Study Initial Review Page 3 contained in the Wildlife Resources Commission memorandum dated January 14, 1994. In addition, all buffers should remain undisturbed except were necessitated for ingress and egress purposes. Reflect these changes in the proposed facility plans and report. No proposal was made i pFlication -toaa►ter; fil or in any way modify wetlands, therefore the Section assumes that all wetlands will remain undisturbed. 1622(5) Complete evaluation and recommendations should be presented in the report on proposed methods for demonstrating compliance with seismic impact design requirements. Recommended scope of evaluation is contained in the previously referenced EPA Manual. Also, refer to applicable comments in the hydrogeological review memorandum. 1622(6) Due to steep slopes found on the site, complete evaluation and recommendations should be presented in the report on proposed methods for evaluating stability in the design process. Recommended scope of evaluation is contained in the previously referenced EPA Manual. Also, refer to applicable comments in the hydrogeological review memorandum. 1622(7) Incorporate Department of Cultural Resources comments dated August 18, 1994 (enclosed) into report. Indicate, and note reference number, archeological sites on facility plan. Highlight the seven sites that may be potentially eligible for listing on the National Register. Demonstrate that these sites will not be affected by proposed construction and operation or outline proposals for further documentation of these sites. Include Department of Cultural Resources concurrence with any such proposals. 1622(8) Include documentation from the Division of Parks and Recreation (Natural Heritage Program and Natural Resources) that the proposed site will not have an adverse impact on lands included in the State Nature and Historic Preserve. .1622(9) Indicate in report (and on appropriate local and regional characterization maps if within the scope of the included maps) the classification of streams and watersheds. Include in report the location of the nearest watershed critical area and nearest public water supply intake. 162200) The report indicates that no threatened or endangered species or their critical habitats will be directly impacted by development of the proposed site. However, in order to protect wetlands, and in accordance with recommendations contained in the report, establish undisturbed buffers Tri-County Site Study Initial Review Page 4 as recommended by the Wildlife Resources Commission (referenced above). Revise proposed plans to include these buffers and adequately discuss proposals in the report. Dtriftg-the--conttn-tt ng-review-process, a-dd tiorval information or clarifiesion may be required. Should any additional information be required, you will be contacted by the Section. If you have any questions or require any other assistance, please do not hesitate to contact this office at (919) 733-0692. Thank you, William D. Sessoms, PE enclosures copy: Jim Patterson - DSWM Jan McHargue, PE - DSWM Jimmy Woody, PE - Municipal Engineering C:\SESSO MS\PROJECTS\CHEROKEE\LETTER.18 State of North Ca. 'na Department of Environment, Health and Natural Resources • • Division of Solid Waste Management James B. Hunt, Jr., Governor y ID C C N P1 Jonathan B. Howes, Secretor William L. Meyer, Director October 19, 1994 MEMORANDUM TO: Bill Sessoms FROM: Bobby Lutfy 9L RE: Hydrogeologic Review Of The Site Study For The Tri-County Solid Waste Management Facility In Cherokee County A preliminary hydrogeologic review has been done of the Site Study for the proposed Tri-County Solid Waste Management Facility in Cherokee County. The following issues need to be addressed before a full technical review can be completed: In Section II of the report, there is no local area study map on a scale of 1 inch equals 400 feet, as required by .1618(c)(2). The well records submitted are not legible. Information should be provided on the location of these wells. Section III - SITE HYDROGEOLOGIC REPORT - The report is not sealed by a licensed Professional Geologist. Two large areas of the site have not been investigated. One area is located on the eastern portion of the site. And the other area is located between the borings located in the central portion of the site and the borings located in the western portion of the site. The report indicates that the borings were not converted to piezometers or monitoring wells, as required by .1623(a)(3). "Temporary standpipes" do not meet this requirement. - In Table 2, no (total) porosity values are reported for each lithologic unit, as required by .1623 (a) (4) (E) . The values for effective porosity seem to be more representative of total porosity values. Further discussion is needed on how the effective porosity values were determined. P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper Page 2 - In Table 4, no 24 hour water table readings are reported, as required by .1623 (a) (7) (A) . -The —f-r--act-tire—tr-ace di-agram used to produce "he RoseDiagram is not included in the report, as required by .1623(a)(1). The scale of Plate 3 makes interpretation difficult. A map with a scale of 1 inch equals 100 feet would be helpful, even if this makes it necessary to split the site near the central stream tributary. Also the topographic lines and numbers are difficult to read. - Only two subsurface profiles were provided. An east -west profile further upgradient through the proposed fill areas would be useful. Also a couple of north -south profiles through the proposed fill areas would be helpful. The horizontal scale of the subsurface profiles should be adjusted to make the information more easily interpreted. - In Piedmont and Mountain settings, generally all borings should go to auger refusal or deeper if necessary to encounter ground water, unless a boring is terminated at a more shallow depth in order to characterize one of the distinct lithologic (hydrogeologic) units. Several of the borings at this site were not taken to auger refusal. Information should be provided on why borings 2,5,7, and 9 were terminated at such shallow depths. Under the location restrictions, the scale of the 100 year flood map makes interpretation difficult. It would be helpful to know the highest elevation reached by the 100 year flood. The facility plan does not indicate 300 foot buffers around the full perimeter of the site. Even though the old Cherokee County Landfill is across the Valley River from a portion of the new proposed Tri-County facility, the new facility is distinct from the old facility and the 300 foot buffer must be maintained around the full perimeter of the site. Page 3 Both the Wildlife Resources representative and the wetlands study representative recommended buffering the streams and wetlands at least 100 feet in order to protect these natural resources. It appears that the conceptual design for Proposed phase-s 4 & —doe ro-maint-ain the recommended-00 foot buffer - from the stream tributary in the central portion of the site. The additional information and clarifications on the issues addressed in this letter must be provided before a full technical hydrogeologic review of the Tri-County Site Study can be completed. The engineering and geologic consultants can call me if they have any questions regarding these comments. CC: Jim Patterson V`% North Carolina Department of Cultural Resources James B. Hunt, Jr., Governor Betty Ray McCain, Secretary MEMORANDUM TO: Bill Sessoms Solid Waste Section Division of Solid Waste Management DEHNR r, FROM: David Brook 9' %�1�6e'sje�-rvation & & De ut State iFl sfonc P Y �6)fficer SUBJECT: Cherokee County Landfill Site, ER 94-8010, ER 95-7230 Division of Archives and History William S. Price, Jr., Director We have received the archaeological report for the above project from Paul Webb of Garrow and Associates. Fourteen archaeological sites were recorded during this excellent Phase I survey. Seven of the sites are judged to be ineligible for the National Register and require no further investigation. However, seven sites (31 CE593, 31 CE599, 31 CE601- 602, 31 CE604-606) were judged to be potentially eligible for listing on the National Register. We concur with these recommendations. We recommend that you contact David Moore in our Western Office, 704/274-6789, for assistance in developing a scope -of -work for additional archaeological investigations. Any of the seven potentially eligible sites which may be affected by future construction will have to be fully evaluated for National Register eligibility. The above comments are made pursuant to Section 106 of the National Historic Preservation Act of 1966 and the Advisory, Council on Historic Preservation's Regulations for Compliance with Section 106, codified at 36 CFR Part 800. Thank you for your cooperation and consideration. If you have questions concerning the above comment, please contact Renee Gledhill -Earley, environmental review coordinator, at 919/733-4763. DB:slvv cc: Paul Webb 109 East Jones Street • Raleigh, North Carolina 27601-2807 2 � J UNITED S, -TES ENVIRONMENTAL PROTECTION. AGENCY � 2 REGION IV 345 COURTLAND STREET, N.E. ATLANTA. GEORGIA 30365 NOV 0 4 1994 4WD-OSW Mr. Dexter Matthews, Chief Solid Waste Section North Carolina Department of Envir_onment_, Health and Natural Resources P. 0. Box 27687 Raleigh, NC 27611-7687 Dear Mr. Matthews: The Federal Aviation Administration (FAA) has prepared a proposed report to Congress entitled, "Report on the Potential Hazards to Aircraft in Locating Waste Disposal Sites in the Vicinity of Airports." The FAA intends to publish the report in the Federal Register for comment in the near future. The "Recommendations" section of the report concludes with the following paragraph: "In an effort to enhance aviation safety, FAA recommends that no new or expanded municipal solid waste or putrescible landfill be located within the FAA specified 5,000 and 10,000 foot criteria or in the approach/departure area within five miles of an airport if deemed incompatible with safe aircraft operations." A complete copy of the information. We will keep becomes available. Please (404) 347-2091, if you have information. Enclosure report is enclosed for your use and you informed as additional information contact Kelly Ewing of my staff at questions or need additional Sincerely, Patricia c/8. Z�wg Manager, Office of Solid Waste Waste Management Division 1 REPORT ON THE POTENTIAL HAZARDS TO AIRCRAFT Im LOCATING WASTE DISPOSAL -SITES IN THE VICINITY OF AIRPORTS P POSE This report -is submitted to Congress in -response to Section 203(b)(2) of the irport an Aires S,&fety, Capacity, Noise improvement, and Intermodal Transportation Act of.1992 which directs the Secretary of Transportation to conduct a study to determine whether a municipal solid waste facility, located within a 5-mile radius of the emd of a runway,' has the potential for attracting or sustaining bird movements (from feeding, watering or roosting in the area).and poses ahazard to runways . or approach and departure patterns of aircraft. • SCOPE _OF REPOR Because most wildlife movements are seasonally influenced, a complete study.of the issues,_presented would require that researchers document all wildlife aeti-,,'.y.for'at least one full year. In order to produce more credible information, at least three years of study data would be -necessary to calculate valid statistical averages. Given the limited time frame specified in the Act for completing'this study, it was'not considered feasible to formulate and carryout a fully scientific research project to address the issue of siting landfills. near airports. Instead, this report was developed from historical data,` past studies and research on the incidents and accidents..' involving birdstrikes and aircraft, and. on the potential of solid waste disposal sites to attract and sustain bird movements.. AIRCRAFT BIBMSTRIKE -HISTO CAL PA C�*JIJD It is - generally agreed that birds and aircraft are -not c=patible even though they share the common thread of flight. Birdstrikes with aircraft were recorded-as.early as 1912,..when a Wright Flyer crashed after striking a. bird off the Pacific coast... Calbraith Rodgers, the pilot who drowned in the crash,.. berme the first aviation fatality attributed to a birdstrike. Developments over the last 80 years,. .have brought aviation to unprecedented levels of sophistication: Howover, this increased level of.sophistication has not provided aircraft with an immunity to damages resulting from strikes with wildlife. Modern aircraft carry more passengers at greater.speeds than ever before, thus increasing the potential for catastrophe. At high speed, even small animals become damaging projectiles to large aircraft:. According to V-t.E. Soloman,.a noted Canadian bird hazard specialist, a four pound bird struck at 260 knots exerts a force of 14 tons; at 520 knots, the force becomes 57.tons. Birdstrikes have been responsible for more. than 100 deaths in the 2 United States. some of the more notable accidents that were attributed to bird strikes included: On. March 10, 1960 a Lockheed Electra departing Boston®s Kogan Airport struck starlings and crashed, resulting in 62 deaths. In 1973, a I.,--arjet depart ing.Dekalb®Peachtree Airport in Georgia, struck a flock of cowbirds (small blackbirds) and ingested them' into the engines. Both engines sustained compressor stalls, causing the aircraf-t to crash, k �T�? 1 sev.- arc -17 19751 a DO-10 departing John F.-Kennedy Airport'ingested gulls on takeoff roll, aborted, the takeoff, 'caught fire and eras completely destroyed. Fortunately, the"139 •pass'engers .who. were airline employees were able to quickly evacuate the b=fting craft suffering injuries, but no deaths. Although it has been argued that these accidents are no longer . current and that modern a; ---:raft have become more resistant to damage. and disaster from bikd strikes.; this is not the case. In 1988, in Bahar Dad°, Ethiopia, a Boeing-737 on takeoff struck a flock of speckled pigeons and crashed,-killi.ng 3 5. passengers and injuring 21 others. The reports that followed the incidents mentioned above noted that birds had been attracted by eiher waste disposal operations or by trash on or -about the vicinity of the air' 'rt. Following the 1973 Learjet crash, the National Transportation Safety Board recommended that the FAA "implement a procedure 'for more stringent and continued surveillance of all facilities subject to the provisions of the Airport. -and -Ai ay Development Act and impose timely sanctions against operators of fa, 6ilities, which receive federal aid and do not fully comply �iit:h'the requirements imposed upon thew by the provisions of *this. act." A .provision in the Act specifies that grant recipients, to the extent reasonable, maintain compatible land -uses around.'an airport. Whether or not a catastrophe results, bird hazards can be responsible for unnecessary .risk .ana,expense.. The FAA receives an average of 2,000 bird strike reports each year. This reporting system is voluntary and...does not reflect the total number of strikes or .cost estimates of damage to 4ircraft or the aviation industry. it is.generally accepted that more than half of all strikes go unreported. Far less information•is received on cost estimates. Information regarding the amount of damag4 is seldom reported because.pilots normally fill out the strike report before the. actual extent of damage is determined. However, damage to aircraft from birds can be severe and costly. According to a recent, Envirormental Impact Statement (EIS) for John. F. Kennedy International Airport, after ingesting one bird, a Boeing-747 aborted its takeoff, blear 10 tires and damaged the brakes while stopping. The resulting damage from this one incident cost the airline $200,000. Additionally, the EIS reported that between 1979 and 1993, birdstrikes caused 3 46 instances of engine damage, 22 instances of non -engine damage, and 51 aborted takeoffs (USDA 1994)1.. r ANDFL1. S AS AT%R=IONS TO OEM A number'of scientific papers.have been pub-lished regarding the association o ir�r s and waste --disposal opeze� . 1-�$ generally accepted that large numbers of birds commonly frequent landfills in search of food. In a recent study conducted by the United States Department of Agriculture's Denver Wildlife Research Center (DWRC) for the FAA,. 69;9;477 individual birds of 42 species were recorded at 3.landfills' in 95S observation periods (Belant et al. 1994)Z. Although gulls may be found at inland landfills, they are one of the more common bird species associated with coastal landfills. Additionaiiy,`crows,' starlings, blackbirds, pigeons, sparrows,: and -vultures have been documented as common3visitors to most landfills regardless of the location. (Lake 1984) Bird populations -that impact human health and sa'fety have been less understood and documented. However, in 1971 the Environmental Protection Agency (EPA) released a report that surveyed land. disposal sites reporting bird aircraft hazards. In the discussion section on page 26 it -stated "there is little doubt that improper solid waste disposal sites in many areas of the country contribute to the bird/aircraft strike hazard at airports". Furthermore, it was stated in. the summary and conclusions that, "analysis of. judgments.folloWing two lawsuits resulting from aircraft/bird strike accidents.* indicated a strong .possibility that both government and -a diL-�osai sate owner could be liable for an accident attributed to birds if the disposal site was knowingly attracting bird- and contributing to the risk of bird/aircraft collisions" (Davideon et a1.:1971) • considering the reports referenced above.,.FAA believes there is enough information available to support the conclusion that }Final -Environmental Impact Statement, Gull Hazard Reduction Program, John F. Kennedy International Airport, United States Department of. Agriculture, May 1994, pp. 1-70, 1-10. ZJerrold L. Bellant et a1., "Gull and Other Bird Abundance at Three Mixed Solid,Waste Landfills in Northern Ohio," DOT Interim Report, DTFA01-91-Z-02004, (1992); p. 23. 3David W. Lake, "Airport Bird hazards Associated With Solid Waste Disposal Facilities," Proceedings:Wildlife Hazards to Aircraft Conte rence a Traigi g Workshop, (1984), p. 221. '.George R. Davidson, Jr. et al., "Land Disposal Sites Near Airports Reporting Bird/Aircraft Hazards,".open-File Report, (TSR 1.6.004/0), U.S. Environmental Protection Agency, 1971, p. 2. 4 landfills are attractive to birdsand that � potential hazard will exist whenever numbers of birds are drawn into or across air traffic corridors. The FAA has initiated research to. better understand, identify and manage potentially hazardous wildlife populations on or near airports. Actual research is being completed under a contract organizations in the t1eia or nuisance walaiirs Zana9t=eLI%.. Although wildlife hazard research is currently underway, it remains in preliminary stages. This preliminary axch will establish asolid database that will used for dater comparisons. More research is also needed tc assess :the effectiveness of wildlife control. techniques. -it is common for -'operators of waste disposal facilities" to include wildlife control techniques in proposals to locate .or expand 'operations in the. vicinity of airports, These techniques include the use of pyr'oteclmic devices, broadcast bird.distress calls,. and as a last resort, lethal control. Although these controls are often presented as being sufficient to offset any wildlife attraction caused by the landfill activity, there is little -.documentat on that these controls will significantly mitigate the attractiveness of a landfill to birds over an extended period. Thus, there is no assurance that such efforts would actually alleviate a bird hazard near an airport should one arise after the landfill is constructed. And, once constructed; landfills are.very difficult to relocate. There exists ample information regarding bird dependence on landfills. Conversely, there is little information documenting successful long -terra mitigation of the problem. L&NEFILL TING R AIRMETS Locating a waste disposal .site, particularly in and around urban areas, has become a very serious.prvblem for most'communities, from both physical and political viewpoints.- As a result, there has beer an increasing need td expand existing sites and establish new waste disposal facilities and landfills. A proposal to establish such a facility close to a -populated or recreational area will,. in most cases,:result in considerable controversy and public opposition. Landfill.proppnents often consider or select sites located at the end of.runways or in tt.e vicinity of airports as solution to these .issues. These locations are often near, but outside, populatien centers; are noise impacted or otherwise unattractive for buildirg- ftvelopment; provide readily available and inexpensive land; %-nd generally provide a location with good road access. As a result, these sites stand a much greater chance of beiiig accepted by er.e public for landfill use. Because of its concern that the attractiveness cf these landfills to bird populations has a potential to impact the safety of aircraft operating to and airports,. the FAA has taken a number of actions and establ i :r-i OCT 19 '94 14:07 FROM FAA-HRP-12 PAGE.006 • policies and procedures to evaluate the impact of potential landfill sites adjacent to airports. FEpEgAL UGUIA, tIONS,POLICIES,A= PROCXJgRES 5 A. Federal -Aviation Reaulati!;n part' 139_._ Airports which serve any scheduled or unscheduled passenger operation of an air carrier that is conducted with an aircraft having .a seating capacity of more than 30 passengers is required by Federal Aviatiorf Regulation Part 139 tohave an airport' operating certificate from the FAA. This certificate is only granted after the airport is'.inspected'by an FAA airport special-ist to assure that all minimum safety standards of part 139 have been met. Under 139..337, all operators of. certificated -airports shall establish a wildlife hazard management plan and provide for, "the conduct of an ecological survey, acceptable to the. Administrator, when any of the following events occur on or near the airport: (1) An air carrier aircraft experiences a multiple bird strike or engine ingestion. (2) An air carrier experiences a•damaging collision with wildlife other than birds.- (3) Wildlife of a size or in numbers capable of causing an event previously described in or (2) is observed to have access to any airport flight pattern or movement area." B. Order 5200 5A. waste Disnos *sites on Or Mean Airyo _g. FAA issued order-5200.5 on October 16, .197.4 to provide int-rnal guidance regarding FAA's official position on siting landfills .near airports in an effort to reduce potential airport/wildlife hazards. The current order 52010.ZA, TMWaste Disposal Sites On Or Near Airports", and as did the original order 5200.5, contain criteria concerning the establishment, elimination or monitoring of landfills, open dumps, waste disposal sites or -other similar facilities on or in the vicinity of airports.- orders, such as 5200.5A, are internal directives that provide guidance to FAA employees. Advisory circulars are public information and may be instructive to those who receive grants from the.7AA.. These orders and advisory circulars have: no author ty.over facilities located off airport property. Also, FAA has no authority to approve or redirect land use outside of,the airport perimeter. For airports that receive Federal funds, the :owner, operator, or grant recipient miust comply with terms of the grant obligation to the extent reasonable to restrict the use of ..land adjacent to or in the immediate vicinity of.the-airport to activities and purposes compatible with normal airport operations. However, in most cases landfills are located outside the airport property and are often beyond the owner's jurisdictional owner'jurisdictional control. Order 5200.5A sets forth the policy that waste disposal sites are incompatible with aircraft operations when located within those areas adjacent to an, airport that are defined through the application of the following three criteria: (1).when located within 10,000 feet of any runway end used or planned to be used 10 by turbine -powered aircraft; (2) within 5,000 feet of any runway end used by piston -powered aircraft; and•(3) when located within a 5-mile radius of a runway -end, such that it attracts or sustains hazardous bird movements from feeding, watering or roosting areas into, or across the runways and/or approach and birds across aircraft approach kd� rture pa- s could a safety concern beyond the 5-mile radius, this distance was considered a reasonable limit for application of the 'FAA criteria. The earlier version of.dhe. FAA Order had no such limit. C. F ® cat' on Reguireme i;s o ..To assist '-VAA. in . its ability to monitor the siting. of landfills near airports, the Co s in .1992 enacted Legislation to amend the Fede 1.Aviation Act to allow the Secretary of Transportation to require that persons proposing to establish sanitary -landfills notify the Secretary when such notice -will promote safety,and the efficient use or preservation of navigable airspace,'. A L,.oposed FAA regulatory amendment will establish a 5-mile radius from an airport for requiring such a .notification. D. EPA Notification__Raalaients. Because of safety, concerns and a lack of jurisdiction, FAA actively sought the assistance of the.EpA to consider airport safety concerns when processing landf'ill'. siting permits. FAA suggested that the'crite'ria in Order 520'®.SA.be incorporated into EPA's revision of their solid waste -disposal regulations. As a result of FAA comments, the EPA adopted'a regulatory requirement in the Solid Waste Disposal Facility. criteria ' h0, Code of Federal Regulations, Part 258.10, .that landfill, owners .or. operators notify the. affected airport and appropriate FAA .office whenever they intend to expand or propose a. new landfill within. five miles of an airport. However, EPA chose not to prohibit or restrict landfill operations within the 5,0O0-and 10,O00 foot distance criteria identified by'F'AA. Instead it required operators within these areas to* demonstrate to the. state agency having the authority to issue the permit that the operation doe's not pose a .bird hazard to aircraft. BASIS OF FAA CRI E'RTA FOR SITIX9 o? LAND.VIr,T FAA believes that any open household or putrescible waste disposal.activity within 5,000 feet.of-a runway serving piston - powered aircraft and 10,000 feet from.,' runway serving turbine - powered aircraft is incompatible with safe aircraft operations. Outside of this criteria but within five miles of the runway edge, FAA will review proposed landfill locations,on a case -by - case basis. Under these circumstances, if the site falls directly under the approach or departure path or has the potential.to increase birds in'the active a•ikspace, FAA will generally consider the site as beiiig iricompa-tA, le with the OCT 19 194 14:08 FRG FAA-ARP-12 PAGE.00e 7 airport. If.the site were located.between the 10,000-foot limit and the 5-mile limit.away from the approach or departure path and would not likely attract birds -across the active airspace, FAA t consider s-ite—incompa-tfble-. During- this case -by - case evaluation, factors such.as the native bird populations, local geography, and the airport traffic patterns are considered. The distance used in FAA's.guidance is..based on several factors. Birdstrikes are voluntarily reported to FAA from'ground level to several thousand feet above ground level-(AGL).' Most birdstrikes occur below 500 . feet with numbers ' diminishirig to ' insignificant levels above 3,000 feet. Based,on normal performance characteristics, .departing aircraft should be at approximately 500 feet AGL after traveling 10-1000 feet from.tbe runway end and approaching 3000 feet AGL at five luiles. These distances and altitudes -form the basis for,the minimum criteria designated for a turbine -powered aircraft. criteria for.piston-powered aircraft,specifies a lesser distance of 5,000 feet due -to different performance characteristics. These aircraft are slower and make more.noise relative to a bit''s ability to respond. The engine noise and slower airspeed allow the operator and bird more time'to react. and avoid striking each other. Additionally, -piston -powered aircraft do not have engine intakes that can ingest birds. The 5-mile area is specified in Order•5200.5A to.allow FAA the opportunity to review the traffic patterns, geography anu juxtaposition of the proposed landfill site and airport. As birds do not respect minimum distances, this review pro -.ides FAA an early opportunity to cmmment.on proposed disposal sites in critical air traffic areas immediately outside.of.the 5,000 and 10,000 foot zones. The review also takes into account existing numbers of birds in the area.and other natural, :man-made or geographical features such' -as refuges., water reservoirs or coastlines that may be located across air traffic.paths from the proposed disposal site. Aa a note of -reference., the 5-mile radius is also used in other countries, such as Canada, which restricts landfill development within.8 kilometers,'or 4.8 miles of an airport reference point. FUTURE CONCERNS There are indications that future resolutions to wildlife hazards will become more complex. Certain species that frequent landfills, such as ring -billed -gulls, are increasing in unprecedented numbers. At the same time, the public is becoming more involved in wildlife laanagement.issues. The National Environmental Policy Act may require public involvement in the solution of a wildlife related problem. .The public's involvement .may be costly and time consuming, resulting in a trade-off of potential hazards. The likelihood of birdstrikeo may be. further exacerbated by design changes to modern'aireraft, which incorporate larger inlet engines to achieve reduced noise levels. These larger, quieter . engines give birds less warning and require theba to avoid a larger surface area a F'II�S 1. FAA believes 'that current Egtate of the art science is not capable of accurately and consistently quantifying'the risk created by locating landfills. within five miles of an airport. Although a civantified risk 'assessment is not.available, the potential hazard of bird, strikes has been establi.shed.in repofts following aircraft accidents. 2'. FAA believes that 'landfills aviation if located within five following reasons: constitute a potential hazard to miles from a runway end for the a. waste disposal activities in the vicinity of the airport.. have lead to air'craft'catastrophes by attracting birds. b. Bird activity 'is generally recognized. to occur at altitudes that brings it into the.path of aircraft during approach and departure operations, the most critical .'time• for aircraft performance. c.. Mo.,ern aircraft, with quieter' -engines and .larger engine.. inlets, increase the potential for birdstrikes du.e,to the reduced warningrom less noise .and. a greater frontal..area for the bird to escape. d.. Bird mitigation techniques, although offered.as a solution, have not been proven -effective over.,extertded, periods of time. In addition, future mitigation programs.will become more complicated and require more time to implement, resulting in a trade-off of potential hazards. e. Landfills areintense attractions to birds and if birds are attracted into areas used by aircraft, .a potential hazard will result. 3. As total bird control is not possible, the best solution is to restrict actions on or in the vicinity of an active airport to reduce bird attractions. 4. The distance criteria contained in FAA Order 5200.5A serve as a reasonable basis for determining the. incompatibility of a landfill site with airport operations. OCT 19 '94 14:10 FROM FHH-HRH-12 PAGE. 010 COMIENDATIONS 9 Although not a solution to all airport -related bird hazards, locating intense attractions to wildlife, such as landfills, outside of the areas specified by the FAA reduces the risk of a potentially ardous-collision between-airCr--t and '11-4Fds progress has been made toward this.goal by the EPA. Although EPA stops short of restricting landfills within the 5,000 and 10,000 foot areas designated by the FAA, it does require that operators of existing municipal solid .waste Zandfills. within those areas to demonstrate to the State Director of,the ERA.that such units do not.pose a bird hazard to.aircraift... .Additionally,.proponents of new or expanded landfill sites must nctify the affected airport and the FAA of their intentions vithin five miles on any airport. in an effort to enhance aviation safety, FP -A recom3nends that no new or expanded municipal solid waste or p-.�rescible landfill be located within the FAA specified,.5,000 and 10,000 foot criteria or in the approach/departure area within five.miles of an airport if deemed incompatible with safe aircraft operations.. o•'