ie ‘STATE OF MICHIGAN ey s DEPARTMENT OF ENVIRONMENTAL QUALITY LANSING RICK SNYDER DAN WYANT ‘coveRNOR DiRECTOR. August 20, 2014 Mr. David Manardo, Director Detroit Building Authority City of Detroit 1301 3" Street Detroit, Michigan 48226 Dear Mr. Manardo: itis my understanding that the City of Detroit is considering amending Ordinance 290-H to allow for the reuse of concrete, brick, and block (hard fill) on the site of generation as. backfill. Our staff have evaluates this proposal and other opportunities for recycling Construction and demolition (C&D) waste related to the large number of structures being demolished. It appears that hard fill has the highest potential for recycling at this time. Due to a number of factors (i.e. relatively cheap landfill disposal costs in Southeast Michigan, the lack of landfill bans for C&D waste, and the lack of local ordinances mandating recycling of C&D materials) it does not appear that many of the other materials contained in C&D waste (wood, shingles, vinyl, etc.) have a viable market for recycling under current conditions in Michigan. {tis estimated that a typical house demolition produces approximately ten tons of hard fil. Much of this material is already recycled in some way once hauled away from the site, but amending City Ordinance 280-H to allow for the reuse of hard fill on site as basement backfill would have many environmental, economic, and practical benefits. The benefit in terms of greenhouse gas reductions can be estimated using the U.S. Environmental Protection Agency's Waste Reduction Model (WARM). If the hard fill from 1,000 homes was reused on site, rather than being hauled to a landfill, the greenhouse gas reduction would be equivalent to removing 92 passenger vehicles from the road or to the annual energy use of 56 households. This estimate does not include the greenhouse gas reductions realized from reducing the loads of backfill soil being hauled to the sites. Additional benefits include less truck traffic in neighborhoods, less wear and tear on local roads, and potential reduction in demolition costs. Reusing the hard fill reduces the need for clean backfill o be located and hauled from off-site, which is a significant challenge at the volumes necessary for this project. The reuse of clean concrete, brick, and block as backfill is compliant with Part 115, Solid Waste Management, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. The recently amended statute defines these materials as ~inert” if they are not covered in whole or part with lead-based paint (324.115(2)(e)). Therefore, it would be necessary to establish a process to identify which homes would or would not be candidates for hard fill reuse based on the presence or absence of ‘CONSTITUTION HALL + 825 WEST ALLEGAN STREET “P.O, BOX 30473 « LANSING, MICHIGAN 48008-7072 ‘wiv michigan govides + (800) 662-0278Mr. David Manardo 2 August 20, 2014 lead-based paint on the concrete or brick. Additionally, it would be necessary to ensure ‘that controls were in place to address fugitive dust, asbestos floor tile, drainage, and the potential for other waste materials to be inappropriately used as backfill. | understand the enormous challenge the City is facing with removal of blighted structures. | appreciate your commitment to environmental protection and your consideration of sustainable demolition practices and recycling opportunities. Please contact Ms. Tracy Kecskemeti at kecskemetit@michigan.gov or 586-753-3840 with any questions on these issues. ir rely, S fienecl. 2. Bryce Feighner, P.E., Chief Office of Waste Management and Radiological Protection 517-241-6551 ce: Mr. Raymond A. Scott, City of Detroit Mr. Steven Sliver, DEQ Ms, Tracy Kecskemeti, DEQ Ms. Rhonda Oyer, DEQ Ms. Ann Vogen, DEQ Mr. Duane Roskoskey, DEQ