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) 662-0278Mr. 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