Solid Waste Study Phase I
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CITY OF SALINA
SOLID WASTE STUDY
PHASE I
CAMP DRESSER & McKEE, INC.
155 North Market, Suite 910
Wichita, Kansas 67202
(316) 262-0046
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CDM
CAMP DRESSER & McKEE INC.
environmental engineers. scientists,
planners. & management consultants
155 North Mart<et. SuRe910
Wichita, Kansas 87202
316262-0049
March 30, 1992
Mr. Frank Weinhold
Director of General Services
City of Salina
412 East Ash
P.O. Box 706
Salina, KS 67402
RE: Solid Waste Study, Phase I: Final Report
Dear Mr. Weinhold:
Attached are five (5) copies of the Final Report for the Solid Waste Study, Phase I.
With this submittal, Camp Dresser & McKee Inc. satisfies the contractual responsibilities
for this project.
We appreciate the opportunity to work with you on this important project. Please do not
hesitate to con us should you have any questions.
Sincerely, /
JPC\sg
Attachment
8558.002
_on /8C)OIodpeper
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TABLE OF CONTENTS
Section
fw
1.0 INTRODUCTION...................................... 1-1
2.0 LANDFILL ANALYSIS .................................. 2-1
3.0 INDUSTRIAL GENERATORS .............................. 3-1
4.0 HAULERS........................................... 4-1
5.0 REGULATIONS....................................... 5-1
6.0 CONCLUSIONS....................................... 6-1
7.0 RECOMMENDATIONS.................................. 7-1
Appendix A - City Provided Data
Appendix B - Industrial Analysis
Appendix C - Wash Pit Analysis
Appendix D - Hauler Analysis
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1.0 INTRODUCTION
Camp Dresser & McKee Inc. (CDM) has been retained by the City of Salina to review and
analyze the disposal of non-hazardous industrial and wash pit waste. This analysis involves the
following tasks:
TASK 1 - Site Visit
CDM has visited Salina to ascertain the present solid waste situation regarding non-hazardous
industrial and wash pit waste in the City. Data was provided prior to this visit by City staff and
is outlined in Appendix A.
Utilizing this data, CDM made site visits to the landfill to inspect the present operations, closed
and open portions of the facility and overall characteristics of the site. Site visits to selected
area industries that dispose of wastes at the Salina landfill were made (See Appendix B). Visits
to area industries involved data collection and inspection of materials and storage facilities where
possible. Site visits were also made to selected wash pit sites (See Appendix C).
TASK 2 - Scoping Meeting
At the conclusion of Task I, CDM met with City staff to discuss the results of the site visits,
present preliminary conclusions and recommendations and develop a strategy for responding to
any further concerns of the City. From this meeting, an approach to the handling of non-
hazardous industrial and wash pit wastes was identified. This meeting also identified other City
concerns regarding solid waste and additional elements of the industrial and wash pit waste
question.
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2.0 LANDFILL ANALYSIS
The Salina landfill opened for operation in 1973, southwest of the City of Salina. The site
is permitted with the State of Kansas under Permit No. 144. The landfill averages a yearly
disposal rate of 231,300 cubic yards per year. The City owns a full section of land
at the current landfill location of which only 15-20% has been currently landfilled. Over the
past ten years, the City utilized a combination of trench and high-rise disposal methods at the
landfill.
Current operations include the following points:
· Compaction is achieved using a 32,000 lb. Caterpillar compactor with Caron
wheels;
· No spotter is currently being utilized at the working face;
· All record data is currently being hand written. Data is kept on vehicle load size,
type and owner;
· Spot inspections are conducted on waste composition;
· Compactor works from top to bottom on the working face;
· A Caterpillar 623E is used to transport daily cover;
· Daily cover is four to eight inches thick and rather inconsistent on the working
face;
· Special wastes are placed in a segregated area on the south side of the current fill
area;
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· Medical wastes, including sharps, are mixed in with mixed solid waste (MSW);
and
· Dead animals are accepted at the landfill.
Under current conditions, no liner system is being used. Groundwater depth varies between ten
to fifteen feet below existing grades. In-situ soils consist of clay and thin sandstone lenses in
the Kiowa formation. The in-situ clays are silty by nature.
Pending regulations will impact strongly on Salina landfill operations. Some of the impacts are:
· Strict record keeping procedures will be required;
· Accurate tonnage records will be essential;
· Consistency of daily cover will be essential;
· Closure requirements will become much stricter;
· Groundwater monitoring requirements will become much stricter;
· Liner systems and leachate collection will be mandatory; and
· Landfill expansion will be restricted.
These impacts will each cost the city additional time, money and manpower. Costs will vary
depending on the extent of the needs of the City and how waste is disposed of and the type of
waste accepted.
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3.0 INDUSTRIAL GENERATORS
The City staff provided a listing of industrial generators in the initial data provided. From this
list and after subsequent discussions with City staff at the initial project kick-off meeting, CDM
selected a representative sample of generators to interview. The interviews involved visiting the
facility, interviewing responsible staff, inspecting (where possible) waste handling procedures, .
and reviewing waste testing results if available. The results of this investigation are as follows:
Green Lantern
MANAGER:
BUSINESS:
WASTES:
HAULER:
DESTINATION:
COMMENTS:
James Maes
Car Wash
Sand Trap Sludge
Hertl Tank Service (Hays, KS)
Unknown
Water from the car wash is disposed through the City sewer system. All
other wastes (commercial paper, etc.) are picked up locally and taken to
the Salina landfill. Mr. Maes provided copies of Total Column Level
Permitted (TCLP) testing results of the sludge.
Blue Beacon Truck Wash
MANAGER:
BUSINESS:
WASTES:
HAULER:
DESTINATION:
COMMENTS:
8558.001
James Maes
Truck Wash
Sand Trap Sludge
None
None - left on-site (lagoon)
Water from the truck wash is disposed through the City sewer system.
All other wastes (commercial paper, etc.) are picked up locally and taken
to the Salina landfill. The sludge is placed in an on-site lagoon to be air
dried. Mr. Maes provided copies of TCLP testing results of the sludge.
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City of Salina Central Garage
MANAGER:
BUSINESS:
WASTES:
HAULER:
DESTINATION:
COMMENTS:
Jim Hill
City Facility
Sand Trap Sludge
City of Salina
City of Salina brush pile yard
Water from the facility is disposed through the City sewer system. All
other wastes (commercial paper, etc.) are transported to the Salina
landfill. Used oil and solvents are picked up by Radium Reclaimers.
Batteries are sold to a reclaimer. Tires are hauled to a monofi11.
City of Salina Waste Water Treatment Facilities
MANAGER:
BUSINESS:
WASTES:
HAULER:
DESTINATION:
COMMENTS:
George Pauls
City Facility
Waste Water Treatment Sludge
City of Salina
None - currently left on-site
All dried sludge is currently being stored on-site until a determination is
made on a permanent disposal site. Liquid sludge is currently being land
applied locally on select agricultural lands.
Kansas Department of Transportation Maintenance Facility
MANAGER:
BUSINESS:
WASTES:
HAULER:
DESTINATION:
COMMENTS:
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State Facility
Sand Trap Sludge
State of Kansas D.O.T.
Kansas D.O.T. sand and dirt piles
Water from the facility is disposed through the City sewer system. All
other wastes (commercial paper, etc.) are transported to the Salina
landfill. Used oil and solvents are picked up by Radium Reclaimers.
Batteries are sold to a reclaimer.
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Great Plains Manufacturing, Inc.
MANAGER:
BUSINESS:
WASTES:
HAULER:
DESTINATION:
COMMENTS:
Exline Inc.
MANAGER:
BUSINESS:
WASTES:
HAULER:
DESTINATION:
COMMENTS:
Exide Corporation
MANAGER:
BUSINESS:
WASTES:
HAULER:
DESTINATION:
COMMENTS:
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Bob Trembly
Manufacturing Facility
Filter Press Sludge, Paint Filters, Dried Paint (drummed)
None - currently left on-site
All dried sludge and solidified paints are currently being stored on-site
until a determination is made on a permanent disposal site. Paint filters
are cleaned, bagged and placed in trash going to the Salina landfill. All
other wastes are transported to the Salina landf1ll. Used oil and solvents
are reused or hauled by a reclaimer.
Jerry Exline
Manufacturing Facility
Filter Press Sludge, Water Treatment Sludge, Caustic Filter Cake
None - currently left on-site
All dried sludge and caustic f1lter. cake are currently being stored on-site
until a determination is made on a permanent disposal site. All other
wastes are transported to the Salina landfill. Used oil and solvents are
reused.
Darryl Younger
Manufacturing Facility
Numerous
Exide and McPherson Recycling
Varied
All wastes of a hazardous nature are transported by Exide to an approved
disposal facility. All other wastes (only paper and plastic) are transported
to the McPherson Recycling Facility.
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Philips Lighting Inc.
MANAGER:
BUSINESS:
WASTES:
HAULER:
DESTINATION:
COMMENTS:
Holiday Mansion
MANAGER:
BUSINESS:
WASTES:
HAULER:
DESTINATION:
COMMENTS:
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Vernon Silvers
Manufacturing Facility
Mercury Tainted Powder, Crushed Glass
Empire Sanitation
Mercury tainted powder goes to USPCI hazardous waste landfill in
Oklahoma, Crushed glass goes to the Salina landfill
Mercury tainted powder used in the manufacture of florescent lights is the
only hazardous waste found. All other wastes are transported to the
Salina landfill.
Brad Byquist
Manufacturing Facility
Dried Polyester Resins (drummed), Dried paint
Holiday Mansion, McPherson Recycling
None - currently left on-site
Dried polyester resins and paints are found inside steel storage barrels.
These barrels are currently being stored on-site until a final disposal
option is determined. All other wastes are transported to the Salina
landfill.
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4.0 HAULERS
Local Salina solid waste haulers were interviewed as part of this study. Appendix D provides
a sample of the data obtained (McPherson Recycling was not interviewed). All haulers
interviewed were extremely cooperative and concerned about any future decisions made
regarding the Salina Landfill. The following is a list of concerns and observations from
interviews:
1. Private haulers are relatively unconcerned and unaware of the contents and makeup of
the wastes they haul. They feel that any violations are the concern of the generator
and/or the landfill.
2. Private haulers generally believe that the State and City are responsible to enforce solid
waste regulations. They believe it is the State's and City's responsibility to police solid
waste regulation violators.
3. The private haulers are concerned about mandatory recycling goals and mixed in their
opinions about the worth of recycling.
4. The private haulers do not generally favor the use of scales at the landfill. They
apparently expect to pay higher tipping fees and are concerned about their vehicle haul
weights.
5. When queried about potential hazardous waste violators among their customers, the
haulers discussed paint users and suppliers (paints, solvents and thinners), machine shops
(oil and solvents), service stations auto shops and lube shops (oil and solvents) and small
service and manufacturing shops (unknown waste).
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5.0 REGULA nONS
CDM conducted a review of the applicable solid and hazardous waste regulations and pending
legislation as part of this study. The applicable Federal Regulations include the Resource
Conservation and Recovery Act (RCRA) and the Environmental Protection Agency (EPA) 40
CFR 257 and 258. The applicable Kansas State regulations Kansas Statutes Chapter 65, Article
34 and Kansas Administrative Regulations Article 29, Part 1 and 2. The applicable local
regulations include Salina Solid Waste Disposal Regulations (May I, 1988). Pending State
legislation includes Kansas State House Bill No. 2801.
Federal Regulations
Federal regulations governing permissible solid wastes consider Maximum Containment Limits
(MCL) requirements based on the EPA Clean Water Act. Total Column Level Permitted
(TCLP) is the test currently required by EPA to determine acceptable solids limits. The E.P.
Toxicity Test, which is more sensitive in measuring metals levels, may be considered as an
alternative testing requirement.
The intent of the new Federal Regulations as they relate to solid waste, is to ensure proper
record keeping and disposal techniques are followed. For the Salina Landfill, this will mean an
extensive expansion of present record keeping procedures and potential leachate collection and
liner requirements.
Also included in the new regulations is an attempt to further define responsible parties. The
regulations have been interpreted to indicate that the final disposal operator is responsible for
all waste disposed of at its facility in addition to the generator of the waste. This interpretation
reinforces the need for complete and accurate record keeping and greater vigilance regarding
what is deposited at the landfill.
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State Regulations
The State of Kansas regulations presently require an operator of a landfill to accept all waste that
is non-hazardous or acceptable to the operator or owner of the facility. This requirement has
caused considerable confusion among both generators and disposers of solid waste. This
situation has also caused the present conflict between industrial waste generators and the Salina
Landfill.
The responsibility for protection of groundwater and prevention of contamination from the
landfill is borne by the operator and owner of the landfill. The basis of this present
interpretation is that sufficient record keeping capabilities do not exist to identify responsible
parties beyond operators and owners. With this lack of information, the only party that can be
held directly responsible is the operator and owner of the landfill.
Local Rel!ulations
The City of Salina has developed regulations governing solid waste handling and disposal.
These local regulations list prohibited materials which include:
· Industrial Liquids;
· Dead Livestock and Animals;
· Hazardous Wastes; and
· Item 18 - Items prohibited at the discretion of the Director of General Services.
Pending Legislation
There is legislation presently under consideration that will impact solid waste management in the
City of Salina. This legislation includes several changes which will affect local municipalities:
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· All counties will be required to submit current solid waste management plans for
State approval. Regionalization of planning is encouraged;
· Planning requirements will be in accordance with stricter federal regulations;
· The State has provided a closure and post-closure funding mechanism based on
a per ton surcharge; and
· Recycling goals have been introduced in an effort to force waste reduction
throughout the state.
There is also an intent by state regulators to modify the present solid waste regulations. These
changes would be implemented to bring state regulations in line with federal regulations.
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6.0 CONCLUSIONS
By comparing the results of the data collection, interviews and inspections accomplished for this
study to the regulations and pending legislation that affect the disposal of solid waste by the City
of Salina, a number of conclusions can be made. These conclusions are not considered all
inclusive and are based on the information available or obtained for this study.
Sand trap sludges are not presently tested in all cases. There is a potential for possible
contamination due to hydrocarbons, pesticides or other materials that may be deposited by a
vehicle.
The larger industrial waste generators are likely not hazardous waste violators. Smaller
operators have a greater potential to send hazardous materials to the landfil1. This is because
smaller haulers can dispose of materials easily and with minimal inspection.
The private haulers are not motivated to check loads. This lack of concern has the potential of
introducing unacceptable materials into the waste stream.
The Federal, State and Loca1 regulations do not allow disposal of materials that do not meet
TCLP standards. This test has a high acidic level which leaches out metals. The E.P. Toxicity
test is less acidic, resulting in higher metal concentrations.
New solid waste regulations place responsibility for waste on disposal facilities. Records must
be accurate and up-to-date. Generator, quantity, type and location of waste, must be accurate.
Inspection of loads needs to be consistent and at the working face. Suspicious materials can be
disposed of easily without adequate inspection.
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7.0 RECOMMENDATIONS
Based on the results of the data collection and analysis, eleven recommendations have been
identified to address the concerns of the City of Salina regarding the impact of non-hazardous
waste on the solid waste system. These recommendations can each stand alone but would be
most beneficial to the city if all eleven were implemented.
1. To better identify potential contaminants and stop their introduction into the landfill a full
time spotter should be utilized at the working face. This individual can check materials
discharged from trucks prior to final disposal. Due to the nature of collection of
commercial and industrial accounts (private haulers) control of the waste must be the
responsibility of the city.
2. A public awareness campaign must be implemented to decrease the potential
contamination from private citizens and small manufacturers. This campaign must
motivate the constituents and also inform them of the impact of contaminants on the
disposal system. Public service messages, newsletters, public hearings and presentations
at civic groups would be some of the methods to consider.
3. To support the public awareness program the city must implement a household hazardous
waste program. This program should be available to citizens, and commercial and small
industrial generators at least once per month. Given the cost of the program it is
recommended that the city prepare this program on a regional basis.
4. Given the amount and extent of the record keeping that will be required by the new
regulations it is recommended that the present record keeping program be updated.
Installation of a PC computer at the scale house and at the main office will afford for the
more efficient and effective record keeping system. By adding a mqdem, the computers
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5.
6.
7.
8.
8558.001
can be linked for a continual data transfer. The computers will be utilized for not just
record keeping but also for maintaining up to date information on haulers and special
wastes.
One of the most demanding elements of the new regulations is the requirement for
accurate disposal quantities. The best quantities tracking is a scale system. A scale will
afford the city the most accurate quantities tracking and also assists in the monitoring of
loads. The scale can also be tied directly to a computer for automatic tracking.
The tracking of the final disposal location for any solid waste is required by the
regulations. The most efficient approach to this requirement is by utilization of the
spotter and the computer system. Installing a grid system at the landfill and tying this
system to a digitized drawing of the landfill allows for continual updating and tracking
of the disposal of solid waste. The spotter would track the location of the solid waste
on a daily basis and in particular any special waste. At the end of the day the spotter
would call up the level that the landfill is at on the computer and indicate the location
and extent of the fill on that day. Special waste location would be highlighted for ease
of identification.
To improve on the control of the flow of potential hazardous materials into the landfill
each hauler should be required to manifest his loads. This manifesting would identify
generators that have contributed to a load. This manifesting would be accomplished
based on route and day of week. This manifest would be utilized to quickly identify
suspected generators. This would accelerate the identification of responsible parties.
In conjunction with manifesting loads spot inspections of the generators facilities is
recommended. A number of hazardous materials are generated daily at a number of
facilities throughout the city. The potential for contamination always exists. A spot
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9.
10.
11.
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inspection program would reinforce to the generator that the city is serious about
protecting the landfill and also adds to the ability of the city to control the introduction
of contaminants into the landfill.
At present the test required by the regulations for determination of hazardous or
nonhazardous is the TCLP test. Although this test gives a good indication of the content
of a substance it does not indicate the potential impact the introduction of other materials
may have upon this substance. Introduction of water or other liquids to a dewatered
material must be considered. Other materials that may be in the waste stream could have
an adverse affect on the substance and should be considered.
Through the use of the spotter, manifesting, spot checks, additional testing and tracking
of materials it will not be a problem to mix wastes at the working face. By mixing waste
the special disposal area is eliminated, which can be perceived by the public and future
regulators as a problem. The mixing of waste will also allow for a more efficient
operation and better use of the entire facility.
Any non-hazardous material accepted at the landfill must be dewatered. Wash pit sludge
should only be accepted if dewatered prior to arrival at the site. This material should
also be tested prior to delivery.
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8558.001
APPENDIX A
City of Salina Provided Data
Site Sketch
Site Drawings
Topographic Drawings
Landfill Operation Procedures
Landfill Disposal and Usage Records
Landfill Disposal Survey
1974 Management Plan
Subsurface Documents (Fent)
Monitoring Wells - Sample Data
Industrial Clients
Medical Waste Clients
Licensed Private Haulers
Population of Salina/County
Wash Pit Owners/Haulers
City/State Rules and Regulations
City Organizational Structure
Landfill Equipment/Personnel
Landfill Fees
Daily Gate Entries
Solid Waste Logs
Industrial Waste Disposal (A)
Industrial Waste Disposal (B)
Medical Waste
Special Entry Requests
Metal Waste Recycled
Tire Logs
Special Landfill Work
Random Inspections
Work Diary
Permits
County Map
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