Miscellaneous0.
Florida Department of ,environmental. Regulation
South District. • 2269 Bay Strcct • Fort Myers, Florida 33901.2W 6 x��gli ; 5'
Snh Marilnez, GOVernnr bale Twxchtmann, Sucr<.tyry John Shearer, Assistant Secretary
Philip Wwods, pelway A$04m t Seveury
CERTXFXED MAIL # P 496.201 714
RETURN RECEIPT REQUESTED
Captain Thomas Brown
County Administrator
County of Monroe
Public Service Bldg./Stock island
Key West, Florida 33040
Dear Captain Brown:
December 18, 1990
D.E.R. Marathon, FL
Re: Monroe C unty - SWIDW
Cudjoe Key Landfill
SC44-139746
Let this letter serve as a follow-up to our November 8, 1990
inspection of the referenced landfill, copy enclosed. The
inspection revealed the following deficiencies.
1. On December 27, 1989 the County received alternative
procedure approval from the Department to use 12 inches of
screened ash 'aver the gee%. A.10-geonet-bottom liner, and
12 inches of chapped tires above the ash layer. As the
result of shortages of screened ash and chipped. tires, two
feet of filtered sand has now replaced the ash/chipped tire
layer in a portion of the landfill. Please Modify the
engineering drawings of the referenced permit accordingly
to show this change.
2. Two 20,000 gallon storage tanks have been installed at
the landfill site. There is no mention of the construction
of these tanks in the referenced permit application. One
sludge storage tank is represented in the revised
application plans (sheet 3 of 8, February 23, 1988).
However, the'tank in the drawing is represented as a
component of the on -site industrial wastewater treatment
plant (IWWTP). The application to construct the IWWTP was
withdrawn by the County, and the plant was.never built.
In May of 1989, modification plans to the solid waste
permit were submitted but did not indicate the existence of
the storage tanks at their current location. Copies of
pertinent portions of two of the engineering drawings are
enclosed for your perusal. In accordance with specific
Condition #6 of the permit, you are required to submit plans
Continued.....
L
R�tNCItI Iwper
Captain Thomas Brown
Aecember 18, 1990
Page 2
to us if leachate is to b
landfill. Please modify
conditions. Please also
taken to prevent leachate
including the area under'
the storage tank drum.
e stored outside of the lined
your permit to show existing
explain what•precautions have been
from discharging to unlined areas
the conveyance piping extending to
3. please note, if the storage tanks are intended to store
septage/sludge instead of leachate the tanks must be
approved and permitted by our domestic waste section.
Please clarify your intent.
4. As explained on page 3 of the inspection report; you
are requested to cease accepting solid waste at the unlined
section of the Cudjoe Key Landfill as soon •as an option
becomes available to you which is permittable by the
Department. This includes receiving an operation permit
for the completed lined section, or when the transfer
station becomes operational, which ever comes first.
Failure to comply with this request may result in
enforcement action. In addition, the current permit should
be modified as necessary to address the final cover on the
unlined section.
Please respond to items one, two and three by February•l, 1991.
Reply to item four as soon as it becomes applicable. If you
have any questions please contact Ghaus Minhaj concerning solid
waste •issues and Mel Reinhart concerning domestic waste issues.
Both may be reached at (813)332--6975. Your cooperation is
appreciated.
sincerely,
v
Philip R. Edwards
Deputy Assistant secretary
PRE/BK/jrh
cc., Ghaus Minhaj w/enclosures
Mel Reinhart w/enclosures
Lisa Gordon w/enclosures
Raymond 7. Dever, P.E. w/enclosures
DECgzol av
201990
D.E.R. Marathon, FL
C
UNTY joNROE
KEY WESTLORIDA 33040
(305)294-4641
•rz .,
M E M O R A N D U M
DATE: June 5, 1991
TO: Board of County Commissioners
FROM: Joe Kelinson ..,
Asst. County Attorney
BOARD OF COUNTY COMMISSIONERS
MAYOR, Wilhelmina Harvey, District 1
Mayor Pro Tem, Jack London, District 2
Douglas Jones, District 3
A. Earl Cheal, District 4
John Stormont, District 5
RE: Cudjoe Key Landfill; use of silica sand instead of tire
chips/ash as a cover/filtration medium for the
geotextile layer - update
I have been in contact with Mr. R. E. Kinghorn, Vice President of
Ground Improvement Techniques, Inc., (G.I.T.), the contractor
working under Post -Buckley, et al. (PBS&J) on this job. Mr.
Kinghorn spoke from his office in Washington state, however, he
was personally involved here.
After a brief review of our prior discussions, the following is
an objective rendition of Mr. Kinghorn's thoughts and opinions
upon this issue:
1. Shortaae of available tire chips/ash suvvlied by the Countv:
This was Kinghorn's first experience using these recycled
materials and, to his knowledge, the first attempt to do so in
Florida. He commends this novel approach; however, the amount
needed was underestimated.
The most likely reason is the compaction factor. (When
physically placed on the geotextile, the material compacts,
accounting for less volume than originally calculated.) He
estimates the chips/ash compacted about 301, accounting for the
shortage (sand for example compacts 10%). Why was this not pre -
calculated? Because the novel material was an unknown factor
without a known compaction ratio, and the amount needed was only
an estimate.
-2-
2. options
a. Amend the existing contract. Feasible, albeit the existin�
contract had "time of the essence" and "liquidated damages'
clauses. More expensive than,
b. Cancel the balance of the contract with G.I.T. (Mr. Kinghorn
told me'iere was a cancellation clause in the contract, however,
I was unable to find same). Upon cancellation, the County could
proceed to cover the geotextile as the recyclable materials
became available, and do so in house.
3. Reasons to timely complete the -project:
The basic liner (underneath the geotextile) is 60 mils thick (1/8
inch). It is the only medium preventing leaching of effluents
into the soil.
Uniform industry policy suggests that once the liner is placed,
that it be covered by the protecting geotextile post haste.
There is great liability potential if the liner is not protected.
It is easily damaged, such as by animals, vandalism, accident,
etc. It is very flammable and might be ignited by a careless
cigarette. A major problem is that if the liner is breached, it
could go unnoticed. Even if suspected, it is extremely difficult
to located the tear, especially when the landfill is filled. If
leachingg occurs after the landfill is activated, cleanup costs
would be exorbitant, in addition to environmental concerns.
Additionally, many landfills have backup protection to the liner,
such as a layer of clay. Cudjoe is a single liner with no
backup.
PBS&J are obligated to provide the County with an operational
facility. It is prudent operating procedure to minimize its
potential liability by keeping G.I.T. on the job. (Argument
against cancelling G.I.T.'s contract). G.I.T., by contract, is
fully bonded.
Although the geotextile can be incrementally placed, it must be
covered with the filtration medium at once as it is susceptible
to sunlight damage in a short time.
If not totally and timely covered, the bottom liner is
susceptible to damage with expensive, pervasive results. To
totally protect the liner, via the geotextile, the geotextile
must be covered within days.
4. Why -silica sand?
Recyclable materials (tire chips/ash are currently experimental
materials in the industry. Although cheap, we ran out of them.
-3-
The County needed to cover the geotextile in short order. Silica
sand is the standard material used in Florida. Coverage/filtra-
tion material must have a designated level of permeability
(regular topsoil is not acceptable), but silica sand is widely
accepted, and D.E.R. approval is necessary.
Using 20-20 hindsight, it is easy to criticize the underprojec-
tion of the amount of tire chips/ash necessary to fully cover the
geotextile. It was a worthwhile experiment and we used all of
that material we had, and cost benefitted thereby. According to
Mr. Kinghorn, the exigency of protecting both the liner and the
overlying geotextile mandated quick acquisition of an approved
covering, and counter balanced the extra cost of the sand.
Mr. Ray Schauer of PBS&J contacted me yesterday. He is preparing
another letter which he hopes will fully answer my previous
inquiries.
JK/bpl