Mid-Florida Materials (MFM) (Division of Hubbard Construction) - - PowerPoint PPT Presentation

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Mid-Florida Materials (MFM) (Division of Hubbard Construction) - - PowerPoint PPT Presentation

Mid-Florida Materials (MFM) (Division of Hubbard Construction) C& D Debris Disposal Facility Class III Landfill Modification Presentation Overview Business of Hubbard Construction and MFM History of MFM C&D Disposal Facility


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Mid-Florida Materials (MFM) (Division of Hubbard Construction) C& D Debris Disposal Facility Class III Landfill Modification

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SLIDE 2

Presentation Overview

  • Business of Hubbard Construction and MFM
  • History of MFM C&D Disposal Facility
  • Location and Existing Operations
  • Requested Class III Landfill Permit Modifications
  • Operational Controls
  • Community Benefits and Needs
  • Environmental Protections and Landfill Design
  • Code Waiver Support and Approvals
  • Wekiva Study Area and Parkway Interchange Plans
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SLIDE 3

Business of Hubbard Construction and Mid-Florida Materials

  • Hubbard started as a Central Florida business in 1920.
  • Main business is roadway construction.
  • Employs 470 people.
  • MFM is a division of Hubbard.
  • Main business of MFM is borrow pits, C&D debris disposal, and

recycling.

  • MFM accepts C&D debris: steel*, glass, brick, concrete*,

asphalt material, pipe, gypsum wallboard, lumber, yard trash*, rocks, soil, land clearing debris (trees)*, clean cardboard*, paper, plastic, wood, and metal scraps*.

* Materials that are recycled.

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SLIDE 4

History of MFM/Hubbard C&D Disposal Facility

  • 1960 – Borrow pit began
  • 1984 – Started filling in borrow pit with C&D Debris
  • Orange County Excavation/Fill Permit 1991 - 2012
  • 220 Acres – C&D Facility approved in 2000; permit renewals 2007

and 2013

  • For 29 years, has been compatible with surrounding land uses

(borrow pits/landfills/agricultural) and rural neighbors

  • Approved permits from FDEP and Orange County
  • Excellent compliance record – no odor or groundwater quality issues
  • Recycles 30% of debris: wood, yard trash, concrete, and metals
  • Estimated 41 years of life at 2012 intake rates
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SLIDE 5

MFM C&D Disposal Facility Location

3602 Golden Gem Rd. Zellwood, FL

MFM C&D

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SLIDE 6

Facility Location

APPROVED DRI AREA KELLY PARK CROSSINGS MID-FLORIDA MATERIALS (HUBBARD C&DLANDFILL) APOPKA CITY LIMITS WEKIVA PARKWAY

Landfill has been compatible with neighbors for 29 years.

GOLDEN GEM CLASS III LANDFILL (CLOSED) ORANGE COUNTY BORROW PIT NOCIA BORROW PIT ZELLWOOD STATION SANG GREENHOUSE ARM NURSERY QUALITY GARDENS NURSERY II

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Zoning Map

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MFM C&D Facility Site Plan

MONITOR WELL

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SLIDE 9

MFM C&D Disposal Facility

Working Face Borrow Pit Concrete Recycling Yard Trash Recycling

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Requested Class III Permit Modifications

  • Change from C&D Waste to Class III Waste (very similar

waste)

  • Allows for a larger market and more recyclables
  • No expansion of existing 220 acre landfill (173 acre landfill

area)

  • No traffic increase over C&D permitted trucks/day
  • Landfill hill gently slopes (11 degrees) – maximum height

50’ above pre-landfill grade vs. existing 43’ height waiver

  • Estimated 39 years of life as a Class III
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SLIDE 11

C&D Debris vs. Class III Wastes

C&D Debris Class III Wastes

  • Steel*, glass, and brick
  • Concrete* and asphalt material*
  • Pipe
  • Gypsum wallboard
  • Lumber*
  • Yard trash*
  • Rocks and soil
  • Land clearing debris (trees)*
  • Clean cardboard*
  • Paper and plastic
  • Wood* and metal scraps*
  • C&D Debris
  • Yard trash*
  • Processed tires
  • Asbestos
  • Carpet*
  • Cardboard* and paper
  • Glass and plastic
  • Furniture (other than appliances)

*currently recycled/to be recycled at MFM landfill

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SLIDE 12

Landfill Operational Controls

  • Noise Control
  • Odor Control
  • Vibration Control
  • Dust Control and Visual Emissions
  • Litter Control
  • Waste Screening – Prohibit

non-C&D/Class III wastes

  • Truck Traffic Controls
  • Emergency Plans – Fire, Hurricane
  • Setbacks and Visual Buffering

Orange County Code Enforcement

  • Monthly Inspections
  • Noise
  • Odor
  • Dust
  • Litter
  • Truck Traffic
  • Annual Reporting

FDEP Oversight

  • Quarterly on-Site Inspections
  • Annual Reporting
  • Complaint Response
  • Odor and Groundwater Quality Rules
  • Quarterly and Semiannual Reports

MFM has an excellent compliance record

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Prohibited Wastes

Certified and Trained Spotters/Operators Check Each Load

  • Oils
  • Whole Tires
  • Paints
  • Batteries
  • Chemicals
  • Chromated Copper Arsenate

(CCA)-treated wood

  • Food Wastes
  • White Goods (appliances)
  • Toxic and Hazardous Waste
  • Automobiles and Parts
  • Florescent Lamps and Ballasts
  • Thermostats
  • Gas Cans
  • Drums
  • Household Garbage
  • Septic Tanks and Grease Traps
  • Liquids and Sludges
  • Class I Waste
  • Any Other Wastes Not Specifically

Classified as Class III Wastes

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SLIDE 14

Odor Control Plan

  • Weekly soil cover
  • Weekly odor monitoring by operator

with hydrogen sulfide (H2S) meter

  • Quarterly odor monitoring at

property line

  • Quarterly report to FDEP and

OCEPD – “no odors detected”

  • Final cover with gas controls
  • All yard waste recycled
  • Facility never cited for odor problem
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Truck Traffic Controls

  • Speed limit enforcement by off-duty

sheriffs on Golden Gem Road

  • Most truck traffic driving off-peak

weekday times

  • No truck parking allowed on

Golden Gem Road

  • No trucks/customer traffic from north of

landfill on Golden Gem Road

  • Permit condition to build turn lane at

Ponkan and Golden Gem, if needed

  • Closed Golden Gem Class III Landfill

traffic removed (+200 trucks/day)

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Projected Traffic Class III Landfill

20 40 60 80 100 120 140 160 180 2003 2007 2010 2011 2012 2014

Trucks per Day Years

Average of 175 Trucks per day is stated in current permits C&D Class III

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Community Benefits

  • Creates 6 direct and an estimated 20 indirect jobs
  • Adding a liner and cap on landfill to protect Wekiva Basin

water quality

  • Increased recycling – towards 75% state/county goal by

2020 (may add 10 jobs at future recycling center)

  • $21,000,000 in construction expenditures over 40 years
  • To provide 120-220 acre park at closure – increased

recreation area and open space (current donation agreement for 120 acres)

  • Hurricane waste staging area
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Proposed Class III Landfill Will Provide a Needed Service

  • Orange County EPD approved Project Need Assessment
  • Adjacent Golden Gem Class III Landfill closed in May 2012
  • Only 3 remaining Class III landfills in Orange County

– Orange County Class III – East Orange – Vista Class III – South Apopka – Proposed MFM Class III – Northwest Orange

  • Provides needed Class III disposal cost competition to keep

disposal fees lower for local businesses and the County

  • Increase in Class III recyclables to help meet County goals
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County Wide Class III and C&D Generation

1,000,000 1,200,000 1,400,000 1,600,000 1,800,000 2,000,000 2010 2020 2030 2040 2050

Tons per Year Years

+56,650,400 tons (113,300,800 cubic yards) +1.8% per year

Source: Orange County Solid Waste Integrated Resources Plan, HDR, 2011

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Class III Landfills in Orange County

Class III Landfill Mid-Florida Materials (proposed) Vista Landfill Bay Lake Landfill (private) Orange County Landfill Golden Gem (closed)

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Added Environmental Protections

Low Recharge Area

Site specific Geologic studies found 70 to 100 feet of clayey confining layer under the site to protect the Floridan Aquifer and Wekiva area

Stormwater Management System

Exceeds Wekiva Pollution Abatement Standards; contains 100 year storm

Impermeable Cap

Over entire 173 acres

Impermeable Liner/ Clayey Soil Barrier Layer Replaces approved unlined C&D landfill Groundwater Monitoring Wells

42 additional wells; tested every 6 months (7 Floridan Aquifer, voluntary)

Waste Coverage

Weekly cover with clayey soils

Post-Closure Care

30 years of care after site closure

Open Space or Park

220 acre open space or park at closure

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Existing C&D Landfill with Dirt Cover

Of the 50” of Annual Rainfall:

  • 42.77” Runoff and

Evaporation

  • 7.23” Infiltration
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OPAQUE BUFFER

Proposed Class III Landfill with Liner and Cap

+99% reduction in infiltration through landfill Of the 50” of Annual Rainfall:

  • 49.993” Runoff and

Evaporation

  • 0.007” Infiltration

Wells

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OPAQUE BUFFER

Construction

  • f Class III

Landfill with Liner and Cap

Wells

  • Full Class III Liner

– Leachate controls and impermeable cap – 100 acre Borrow Pit

  • FDEP & OCEPD Approved

Liner Exemption – 120 acre C&D filled area closed with 12” clayey soil barrier with phased Class III ±15 acre cells (±15 thick) closed as-you-go (3-5 years each)

“Demonstrated no significant

threat to the environment per Rule 62-701.340(b)”

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Landfill Visual Buffer

North Site Boundary (Trussel Trail and Golden Gem Road)

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Code Waivers Supported by BZA and EPD

Height

Section 32-216(a)(30): A waiver is requested to have a final elevation at closure up to 50 feet above the original elevation of the site, prior to any field activities. The current C&D landfill permit has an approval waiver to 43 feet above grade. Specifically, Class III waste is requested to be landfilled up to a maximum elevation

  • f about 168 feet NGVD.

– Provides Needed additional Class III landfill capacity, in the Public Interest. – Majority of height increase is over 100 acre lined area to fund +$10,000,000 liner cost. – Additional elevation assists impermeable cap runoff to ponds in setback. – 168’ is only 25’ over the 143’ natural high point on the site. – 168’ height is 900’ from Golden Gem Road, gentle 11% (5:1) slope on sides – not visible. – 168’ height blends in with regional hills (150’ to 190’). – Compatible with surrounding properties and land uses.

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Landfill Height: Keene Road vs MFM

Keene Rd. 80’ above road MFM 30’ above road

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Perspective View

Keene Rd. 80’ above road MFM 30’ above road

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Side Slope

Keene Rd. 3:1 MFM 5:1

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Topographic Map of Area Showing Elevation of Surrounding Areas

Site Final landfill height is comparable to surrounding topography

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Code Waivers Supported by BZA and EPD

Wekiva Study Area

Section 32-216(c)(4): A waiver to the restrictions and additional requirements of the Wekiva Study Area, “presumptive prohibition” for Class III landfills in a Primary and Secondary Floridan Aquifer Vulnerability Zones. – Existing C&D landfill is “grandfathered in” and does not have to meet Wekiva Area protections. – Extensive site-specific geological study supports the site is a less vulnerable zone – low recharge. – The proposed Class III liner and cap design is more protective of the environment and the Floridan Aquifer/Wekiva basin than the existing permitted facility. The OCEPD Manager supports the waiver. – Project meets the recommended Best Management Practices of Pollution Abatement for Existing Land Uses in the Wekiva Study Area. – Wekiva vulnerability maps were not intended to be applied to site/project specific decisions under 480 acres, i.e. data not accurate below that level.

Class III landfill water quality protection improvements will be a long-term benefit to Wekiva study area quality

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  • n

Wekiva Study Area

Primary (“more vulnerable”) Secondary (“vulnerable”) Tertiary (‘less vulnerable”)

Florida Geological Survey Disclaimer – RI #104: “Application of the vulnerability map on the

  • rder of greater than 0.75

square miles (480 acres) is more appropriate. The WAVA Vulnerability map is no substitute for a site-specific hydrogeologic investigation.”

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Orange County Comprehensive Plan Objective FLU6.6.7 – Wekiva

“Initial identification would be through Geographic Information System (GIS) analysis of high and moderate recharge areas, karst sensitive areas, and the Wekiva Aquifer Vulnerability Assessment (WAVA) map. Final determination shall be through on-site soil analysis and hydrological and geotechnical investigations, as needed. (Added Ord. 07-20, Policy 4.5.4)”

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MFM C&D

Study Area Protection Area

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The site is not located in the Wekiva Protection Area

Wekiva Protection Area

Orange County

46 441

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Class III Wastes vs. Wekiva River Pollution Sources

Class III Wastes

Recycled Materials Steel Concrete Asphalt material Lumber Yard trash Land clearing debris (trees) Clean cardboard Other Inert Materials Glass Brick Pipe Gypsum wallboard Rocks and soil Paper Plastic Furniture Asbestos Carpet Processed tires

Nitrates, nitrogen, and phosphorus ARE polluting the Wekiva.

Wekiva River Nutrient Pollution Sources

Source: MACTEC’s Final Report Wekiva River Basin Nitrate Sourcing Study for FDEP and SJRWMD, March 2010

MFM Class III Facility would not be a pollution source to the Wekiva

(septic tanks)

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City of Apopka Wekiva Parkway Interchange Vision Plan

Kelly Park Crossings Development must transition to be compatible with existing rural land uses

Source: City of Apopka Comprehensive Plan 2030 Future Land Use Element

MFM Landfill

Proposed Districts Village Center Employment Interchange Transition Neighborhood (existing low-density rural) Recreation

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City of Apopka Comprehensive Plan 2030:

Future Land Use Element

Wekiva Parkway Interchange Plan Objective 20 - Policy 20.10:

  • “Development at the outer edges of the mixed-use area

shall maintain compatibility with the lands adjacent to the Wekiva Interchange Plan Area by reducing density and intensity or by providing substantial buffers, landscaping, height, and lighting controls.”

  • “. . .maintain 20% open space in the overall Study Area.”
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City of Apopka Comprehensive Plan 2030:

Future Land Use Element

Wekiva Parkway Interchange Plan Objective 20 - Policy 20.24:

  • “Where feasible, developments within the Wekiva Parkway

Interchange Plan Area shall maximize the preservation of

  • pen space and promote the clustering of uses to both

preserve and enhance the natural environment and to maintain the rural character of areas outside of the Wekiva Parkway Interchange Plan Area.” Interchange Development (Kelly Park Crossings) needs to be compatible with the existing rural character (MFM Landfill).

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Orange County Comprehensive Plan 2010-2030 Future Land Use Element Objective 6.7 – Wekiva Interchange Land Use Plan Overlay: “. . .measures need to be taken to ensure that development (Kelly Park Crossing) does not degrade the existing rural nature of the unincorporated (Orange County) areas. . .” Orange County Wekiva Interchange Report – May 2010: “County must minimize urban expansion into rural

  • areas. Therefore, it is important to ensure to the

degree possible, that the City of Apopka’s urbanization of the area is compatible.”

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Notices and Meetings with the City of Apopka

  • From Orange County EPD’s Final Kelly Park Crossing DRI Review

Comments, August 2011: “There are two active landfills south and southwest of the proposed development . . . The Mid-Florida Materials facility is currently pursuing a permit modification to change from accepting only construction and demolition (C&D) debris to a permitted Class III landfill that will also allow disposal of yard trash and other non- leachate producing waste.”

  • Mid-Florida Material met with the City of Apopka three times from May to

October 2012 to offer project information and additional buffers (opaque buffer was added along Golden Gem Road).

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Class III Landfill Approvals to Date

  • Orange County Development Review Committee –

August 2012

  • Florida Department of Environmental Protection –

October 2012

– Solid Waste – Class III – Stormwater (ERP)

  • Orange County Board of Zoning Adjustment – April 2013 –

Project Meets Special Exception Criteria – Compatible

  • Orange County Environmental Protection Division – Staff

Report Recommendation for Approval

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Voluntary Conditions

Based on Community concerns, MFM offers these Class III Landfill EPD Permit Conditions:

– Will not take asbestos – Will never become a Class I Landfill – 6’ landscaped berm along Golden Gem Road property line

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SLIDE 44

Respectively request that the Board of County Commissioners accept the recommendation of both the BZA and your EPD staff to approve the MFM Class III Landfill Permit Modifications.

Questions?

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Hydrogeologic Cross Section

On-site Studies Prove Low Recharge

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Approved C&D Landfill

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Proposed Class III Landfill Liner Exemption over C&D

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FDEP Definition:

Class III Wastes

“Class III waste” means yard trash, construction and demolition debris, processed tires, asbestos, carpet, cardboard, paper, glass, plastic furniture other than appliances, or other materials approved by the Department (FDEP), that are not expected to produce leachate (landfill tea) that poses a threat to public health or the environment.

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FDEP Definition:

Construction & Demolition Debris

“Construction and Demolition Debris” means discarded materials generally considered to be not water soluble and non-hazardous in nature, including but not limited to steel, glass, brick concrete, asphalt material, pipe, gypsum wallboard, and lumber, from the construction or destruction of a structure as part of a construction or demolition project or from the renovation of a structure, including such debris from construction of structures at a site remote from the construction or demolition project site. The term includes rocks, soils, tree remains, trees, and other vegetative matter that normally results from land clearing or land development

  • perations for a construction project; clean cardboard, paper,

plastic, wood, and metal scraps from a construction project; except as provided in Section 403.707(9)(j), F.S., yard trash and unpainted, non-treated wood scraps.

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Proposed Project Meets Special Exception Criteria

  • 1. The use shall be similar in noise, vibration, dust, odor, glare, and

heat-producing characteristics that are associated with the majority of uses currently permitted in the zoning district.

Use will be similar in noise, vibration, dust, odor, glare, and heat-producing characteristics that are associated with the current use, adjacent land uses, and the majority of the uses currently permitted in agricultural zoning districts.

  • 2. The use shall meet the performance standards of the district in

which the use is permitted.

The use will meet the performance standards of the agricultural district.

  • 3. Landscape buffer yards shall be in accordance with Section 25-4
  • f the Orange County Code. Buffer yards shall track the district

in which the use is permitted.

Landscaping will be in accordance with Section 25-4 of the Orange County Code. Waiver approved along adjacent landfill property line. Added opaque buffer along Golden Gem Road.

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Proposed Project Meets Special Exception Criteria

  • 4. The use shall be similar and compatible with the surrounding area.

The use is similar and compatible to the adjacent land uses. The proposed use is a modification of an existing landfill with a special exception.

  • 5. The use shall be consistent with the pattern of existing

development.

The use is consistent with the pattern of existing development (rural residential, agricultural, industrial). The proposed modification does not expand the existing 220-acre MFM C&D landfill facility.

  • 6. The use shall not act as a detrimental intrusion into an existing

residential area.

The use will not act as a detrimental intrusion to an existing residential area. The use is existing and not expanding. Has been a good neighbor to surrounding rural residential. All surrounding areas are agriculturally zoned, or have special exceptions for industrial type uses.

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Proposed Project Meets Special Exception Criteria

  • 7. The granting of the Special Exception shall not adversely affect

the public interest (for instance: the request will not adversely impact neighboring properties; the proposed use will serve or benefit the neighborhood/community within which it will be located).

  • Granting the Special Exception will be in the public interest.
  • Avoids the need to construct additional Class III landfills in Orange County.
  • Proposed modification will allow reuse of many Class III wastes and assist the

County in meeting the State’s 75% recycling goal by 2020.

  • Provides more stringent environmental controls than the existing C&D landfill

(further protection for Wekiva River Basin).

  • Will become a 220 acre open space/park at closure.
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Extensive Onsite Geological Study, 1999-2000 and 2011-2012

  • Stable soils
  • 70’-100’ thick clay layer

above Floridan aquifer at 200’ below land surface

  • No karst features onsite
  • Low recharge to Floridan

Aquifer onsite

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Code Waivers Supported by BZA and EPD

Seasonal High Water Table Section 32-216(a)(4): A waiver to the five (5) feet minimum separation between the bottom of the lined landfill portion and the seasonal high water table (SHWT).

– Requested to allow steeper slope of liner floor to promote drainage. Current borrow pit floor is too flat. – The alternate 60 mil HDPE liner, with a permeability less than 1 x 10-7 cm/sec, will provide in excess (1,000x) of “equivalent” performance to the impedance of leachate as would have the 5-feet of soil, with an estimated permeability of 1 x 10-4 cm/sec. – Our design concept is to have the liner in the north 100 acres be above the estimated SHWT. – MFM agrees to monitor water levels across the north 100 acres prior to the final liner design.

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Landfill Liners are Protective of the Groundwater in Florida

  • Of the 40 active, lined Class I

Landfills in Florida, NONE of them currently have cleanup activities

  • ngoing that are associated with

groundwater contamination caused by a breach in the landfill liner system.

  • The MFM Class III landfill design

follows the same regulatory (Rule 62-701) and USEPA (Chapter 264) approved design and construction quality control as these other lined landfills that have proven to not impact groundwater quality.

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Closest House to Property Line

100’ to property line 250’ to landfill House built in 2003

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Height Waiver Factors to Consider

1. Location of real property

  • Existing C&D landfill in agricultural/rural district

2. Distance of facility from adjacent improvements

  • Existing facility since 2000
  • Closest adjacent residence (built in 2003) is 100’ from property line;

250’ from landfill

  • 150’ set backs, vegetative buffer, and gentle slope mitigate visual

impacts

3. Effect of the proposed waiver on adjoining property

  • Existing C&D landfill approved to be 43’ above grade
  • Additional 7’ is not a significant increase
  • Existing and proposed buffers and gentle slopes mitigate any effects
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SLIDE 59

Height Waiver Factors to Consider

  • 4. Current physical conditions on property whereon landfill is

proposed

  • Existing C&D landfill, Class III landfill on same property – similar

wastes

  • Height waiver previously approved
  • Height similar to regional topography ranging from 150’ to 190’ above

sea level

  • 5. Whether waiver is contrary to the public health, safety, and welfare

and/or adopted plans, policies or ordinances of the County

  • Solid waste code allows for a 50’ height waiver
  • Previous waiver approved
  • Will not effect public health, safety, or welfare
  • Buffers act to visually buffer
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SLIDE 60

Height Waiver Factors to Consider

  • 6. Any special conditions applicable to the real property wherever the

landfill is proposed

  • Existing C&D landfill with 43’ height waiver
  • Additional Class III landfill capacity needed in County
  • Additional height provides landfill capacity to support funding of liner

and capping system

  • 7. Would waiver diminish the level of environmental protection

provided by this article or nullify its intent

  • Height waiver of 43’ existing
  • Additional height will not effect the environment
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SLIDE 61

Wekiva Code Waiver

1. Location of real property

  • Existing C&D landfill exempt from Wekiva provisions
  • Class III landfill very similar waste types – inert
  • Site suitable for a Class III landfill

2. Distance of facility from adjacent improvements

  • Existing facility since 2000
  • Closest adjacent residence (built in 2003) is 100’ from property line;

250’ from landfill

  • Improved environmental controls such as liner, cap, and monitoring

wells

  • Existing and improved buffers are in place
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SLIDE 62

Wekiva Code Waiver

3. Effect of the proposed waiver on adjoining property

  • Improvement to environmental controls over existing C&D landfill
  • Improved buffers and monitoring plans
  • 30 years post-closure care
  • Donation as a park and open space at closure

4. Current physical conditions on property whereon landfill is proposed

  • Existing C&D landfill exempt from Wekiva code provisions
  • Proposed Class III environmental controls and buffers improve the

condition of the property

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SLIDE 63

Wekiva Code Waiver

  • 5. Whether waiver is contrary to the public health, safety, and welfare

and/or adopted plans, policies or ordinances of the County

  • Waiver is not contrary to the public health, safety, and welfare, or
  • ther County codes
  • Class III landfill environmental controls meet or exceed Wekiva code

provisions for best management practices

  • Additional controls envisioned by the Wekiva code are provided
  • Code provides for a site-specific study of property, which proved site

to be low recharge to the Floridan Aquifer and the Wekiva Basin

  • Existing C&D landfill is not lined and closed with 2’ soil, a potential

threat to Wekiva basin water quality – Class III design removes this risk

  • Class III landfill further protects public health, safety, and welfare
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SLIDE 64

Wekiva Code Waiver

  • 6. Any special conditions applicable to the real property wherever the

landfill is proposed

  • Site is an existing C&D landfill with minimum environmental controls
  • Wekiva code was intended to apply to new facilities
  • A prohibition would prevent the extensive environmental

improvements provided by the Class III landfill design and operations

  • 7. Would waiver diminish the level of environmental protection

provided by this article or nullify its intent

  • The waiver will not diminish the level of environmental protection by

the article or nullify intent of the code

  • To the contrary, the waiver will allow a much greater level of

environmental and water quality protection over the existing approved C&D landfill that is exempt from the code

  • Class III landfill improvements meet all best management practices to

protect Wekiva area water quality