Research of other County OrdinancesHennepin Co. HW Ordinance - provisions alreadyIncoming hazardous building materials at C&D transfer stations (in Ramsey Co.)Magnitude in number of vacant buildingsLandfill Operators – hazardous building materials require upstream regulation as wellRegional/State Policy – Reduce toxicity of C&D
Driving Force - Outcome Ramsey Co. Hazardous Waste Ordinance
amended and approved in February ’08 to include section 3.06 (Standards for Demolition Sites and Wastes from Demolition Sites)
Ramsey County Solid Waste Ordinance Amended and approved in November ‘09 (closely follows MPCA Pre-Demo Rule) and effective December 3, ‘09.
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Initial work drafting section 3.06 of the Ramsey County Hazardous Waste Ordinance and the Pre-Demo piece began in Fall ‘07 and was adopted Feb 2/08. Pre-demo piece currently being written into the Ramsey County Solid Waste Ordinance with adoption projected for Summer ‘09.
KEY DATESRamsey County published an article in the Minnesota Building Permit Technicians Association(MBPTA) May 2008 newsletterAttended related trade association meetings in June - July 2008 and will continueLetter sent to all Municipalities June 30th , 2008Letter sent to Demo Contractors mid August 2008Follow-up & update letters to both were sent December 2008, March & August 2009 Updates to Stakeholders as necessary
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Discuss the journey thus far 5/08 – RC published article in professional association newsletter Attended trade association meetings beginning 7/08 1st Ramsey County Pre-demo inspection conducted early 8/08. Continued municipality and demo contractor communication and correspondence to date. Overall demo contractor responsiveness – generally positive (no license fees…) Overall municipalities (City of Saint Paul projects…) responsiveness – very good.
What Is the Goal?
Protect Health and EnvironmentRight Waste to the Right Place/LiabilityEven Playing FieldOffer Upstream Check on Hazardous Building Materials, HHW, HW, etc. being released and/or delivered to transfer stations/landfillsEncourage additional recovery of building materials
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Health & Env – Protect Community & Workers; surface and groundwater contamination, asbestos, lead paint, refrigerants, mercury, HHW Right waste to the right place. Reduction in liability if resulting building materials and building contents are properly managed Ensure that low bidder plays by the rules Keep inappropriate/banned wastes OUT of C&D in the first place – transfer stations and landfills cannot be the first line of defense. Talk with any transfer station or landfill operator about what people try to sneak into loads… Deconstruction (will talk about that a little later)
Program Poster Child Realtor Hires Demo Contractor on a Budget
Realtor hired their own Demo Contractor to save $$•No demolition permit•No MPCA/MDH Notification•No asbestos survey/abatement•No dust suppression
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Program Poster Child …Demo Contractor on a Budget (cont.)
•Stop Work Order Issued•MPCA, RC & City Involved•City Cost: Original Bid for
City Contractor $8K Now City pays $22K
•Entire house = ACM•Neighbors lawns, roofs vacuumed to recover ACM•100% preventable
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What Does Ramsey Co. Require?
Pre-Demolition Walk Through InspectionProperly removed and managed: (overlapping definitions)
Hazardous Building ComponentsHazardous or Household Hazardous WasteUniversal/Special WastesMSWOther
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Hazardous Building Components: items containing cadmium, lead, mercury, oil, PCBs, refrigerants, asbestos containing materials, and other items posing risk to humans or the environment including, but not limited to, fluorescent and high intensity discharge (HID) lamps, neon lighting, lighting ballasts (both PCB and non-PCB containing ballasts), electrical capacitors, batteries, circuit boards, appliances, components of heating, ventilation, and air conditioning (HVAC) systems that contain the above referenced materials, and thermometers, gauges, switches, and relays containing mercury. Hazardous or Household Hazardous Waste RCRA definition Universal Wastes: Hg containing Lamps Pesticides Batteries Mercury Special Hazardous Waste shall include the following hazardous wastes. 1. photographic and X Ray negatives and paper which exhibit the toxicity characteristic for silver under Minnesota Rule part 7045.0131. 2. electronics except for "appliances" as defined by this ordinance.
Numbers to date
Over 270 demo permits received from Municipalities throughout Ramsey CountyOver 220 on-site pre-demo inspections conducted by County Staff~90% residential/~10% commercial2 inspectors combine this with their other solid & hazardous waste compliance work.
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Also discuss standouts both good and bad. Greg LaMere & Michael Reed
Typical Residential Demo Project
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Typical residential structure slated for demolition. What we drive up to. Loss or Opportunity for Neighborhood? (Mixed) Discuss neighbor, police interest and appreciation Overall process already taken place and leading up top the pre-demo site visit. Role of the bank or city. Foreclosure process (Police Action)
Multi Unit Demo
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Example of a multi-unit demo project. Discuss what goes into securing the area to be demo’d. Dust suppression, what is not required for winter demo vs. summer demo for dust suppression? Overall method by which the heavy equipment operator takes as he systematically brings a structure down.
Commercial/Institutional Project
Industrial Site Demo
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Example of a Commercial Demo Walk through, all HVAC components decommissioned on-site, asbestos abated, lighting/ballasts removed, asbestos concerns as project continues. 3M Tartan Floor in Field House (Hg containing) Was removed and disposed of as industrial waste. Concrete below it also had to be disposed of as industrial waste.
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Discuss containment of the debris field Site Security
Site Considerations
•Multiple contractors, schedules and pieces of equipment•Asbestos•Utilities•Dust suppression•Site runoff•Site security•Site contamination
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Multiple contractors, schedules and pieces of equipment Asbestos Overhead/underground utilities Dust suppression (city hydrant w/ meter, neighbor, truck) Site runoff Site security Site Contamination
Site Considerations (cont.)•Proximity to other buildings•Access to site•Sidewalk/Alley/Street Permits
•Hazardous Materials•Salvage/Deconstruction
Potential•Staging area for debris
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Proximity to other buildings Access to building – hill in front - from street/alley/neighbor? Sidewalk/Alley Permit Staging areas for debris
Total Fire Loss –MSW vs. Demo?
•Furniture, household goods, appliances, mattresses, garbage, area rugs all = MSW
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Discuss different demo site conditions What is safely recoverable? It may all have to go as MSW or ACM How practical is it to remove “MSW” during & after building is brought down?
•“Alligator cracking” = lead paint.•Is it flaking?
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A typical find at a residential pre-demo site. Discuss the process of HHW removal at this time.
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RC HHW Pre-Demolition Acceptance Form Deliveries to RC Permanent/Year Around HHW Site ONLY Residential Demo Projects ONLY One form per address/Signed by Demo Contractor Unique Form ID# Distributed to and tracked by contractor HHW Contractor provides completed copy to RC. All but one contractor applauded this offer
C&D or MSW?
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More typical junk found at residential demo sites. Sometimes walls and ceilings are opened for asbestos inspection/abatement Smoke Detectors = MSW – may trip radiation detectors at landfills MSW vs. C&D disposal – must be separated. Discuss conditions we often walk into. Trade the cold of winter for the smells of summer Discuss what we will do in this case
Fluorescent Lamps & Ballasts
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Typical find at a commercial demo Are ballasts PCB? Are commercial HVAC refrigerants being properly evacuated at the site with documentation from certified technician? Are HVAC systems being processed to remove capacitors, ballasts, mercury switches, etc. prior to recycling? Back up batteries and lights in Exit Lights/Emergency lighting? Are ballasts and bulbs being properly managed?
Major Appliances
Examples: Refrigerator, Freezer, Microwave, Stove/Range, Dish Washer, Clothes Washer/Dryer, Hot Water Heater, Furnace, Garbage Disposal, dehumidifier, A/C, refrigerated drinking fountain
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Are major appliances present? Fridge/stove/microwave/dish washer/clothes washer/dryer/hot water heater/furnace/garbage disposal/ A-C/dehumidifer Are they properly processed as required by MN Statute? They may not be delivered directly to a scrap yard unless “processed”. Hg flame sensors, Hg tilt switches, PCB capacitors/ballasts, refrigerants, refrigerants being evacuated by a certified technician ON-SITE for central A/C units/HVAC units.
MAJOR Appliance Violations•Minn Stat. 115A.9561 Major Appliances – must be recycled or reused.
•…recycling includes removal of PCB ballasts & capacitors, CFCs, Mercury•Practical Solutions?
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When exactly are the appliances coming out of the building? How are the appliances coming out? Refrigerant release (Fines $$) Very difficult and expensive to properly decommission damaged appliances. Vendors charging you the same rate as an undamaged appliance may not be doing it right. Minn Stat. 115A.9561 Major appliances must be recycled or reused. Each county shall ensure that its households have the opportunity to recycle used major appliances. For the purposes of this section, recycling includes: (1) the removal of capacitors that may contain PCB's; (2) the removal of ballasts that may contain PCB's; (3) the removal of chlorofluorocarbon refrigerant gas; and (4) the recycling or reuse of the metals, including mercury.
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Why was asbestos used in building products? Doesn’t burn, rust, mold and strong as steel. Asbestos still exists in new building products today Discuss clarification if asbestos survey and remediation have been performed and completed Do NESHAP rules apply? Does the project require a 10-Day notification to MPCA/5-Day to MDH? If asbestos was abated, was on-site testing performed to confirm the air inside the house was cleared? discuss asbestos contractor requirements – does the contractor know the project must stop if additional asbestos is found?
Rooms Available?•Typical vacant building posting•Posting discloses name and phone number of City Contact•Are you at the right address?•The whole world knows this house is vacant…
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A typical vacant building posting. Great caution is exercised in making sure that the correct structure and the right address is being inspected. This posting will also disclose the name and phone number of the City contact.
Security often breachedOpen 2nd Floor Windows Good!Open 1st Floor Windows Bad…
• Inspections NEVER done alone• Hard hat, head lamp & safety glasses• Boots: steel toes & steel shank• Knock loudly, announce yourself• Rodents/insects/feral animals• Slip/trip/fall/nails• Asbestos• Syringes• Squatters• Vandalism to utilities
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An element of danger exists when conducting pre-demolition inspections. These boarded up homes are often safe havens for not only the desperate & downtrodden but also populations of rodents and feral animals. Pre-demolition inspections are never done without two people present – 2 inspectors or an inspector and contractor. Knock loudly, announce yourself, listen and proceed with caution.
Flooring in good condition – up to $4.00/square foot used retail market
Deconstruction (cont.)
•Hot water radiators•Major Appliances: < 5 years old & working•Unique plumbing & lighting fixtures•Unique hardware
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Hot water radiators - $15 – 25/fin on used TC retail market
Deconstruction (cont.)Making cents…
•Expand your network of materials outlets•Cash for salvage - for-profit salvage vendors•Charitable donation - for non-profit •Tax benefit –charitable donation•On-site auction?•Tipping fee and SWMT reductions•Marketing Opportunity (i.e. LEED)
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Revisit your existing network and look for gaps For profit vs. cash Tax benefit – talk with your tax advisor On-site auction (to include bidder providing removal labor) Tip fee/SWMT reductions – calculate How can you market this approach
Deconstruction Demonstration Project – City of White Bear Lake
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Commercial redevelopment project Bought out current homeowners Incorporated deconstruction/soft stripping into demolition project
Deconstruction ResultsHomeowners + Deconstruction Services : Used
building materials recovered =2 kitchens 40+ windowsInterior/exterior doorsMajor appliancesWood: oak flooring, trim, misc. lumber Garage door/openerBlock retaining wallLighting fixtures Landscaping
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Demonstration Results300 tons of concrete recycled111 tons of demo debris created*C&D Waste Processing (Atomic)
Total Recycled: 46ADC: 34 tonsTotal landfilled: 31 tons
*aggregate monthly facility data
Overall recovery 90%+ by weightEstimated $18 – $20,000 salvage value recovered
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Deconstruction (cont.)
•Hot water radiators•Major Appliances: < 5 years old & working•Unique plumbing & lighting fixtures•Unique hardware
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Hot water radiators - $15 – 25/fin on used TC retail market
Questions?Michael Reed
Environmental Health Specialist IIRamsey County Environmental Health