FFPA Solid Waste Study: Sound Science and Regulatory Collaboration, 1996 Environmental Conference Proceedings

In November 1992, the Florida Department of Environmental Protection (FDEP) adopted a rule that set new standards for the construction, operation, and closure of industrial solid waste disposal sites. Because comprehensive data on such sites were lacking, the rule required compliance with the most stringent municipal landfill standards (Class I) effective January 1995. Early involvement by the Florida Pulp and Paper Association (FPPA) and other industry groups, however, led to a provision in the rule allowing a specific industrial facility or a representative organization (such as FPPA) to request alternate and less stringent requirements. This provision required the timely submittal of a study addressing the specific factors listed in the rule that would demonstrate the inappropriateness of Class I municipal landfill standards for a particular kind of industrial solid waste disposal activity. The FPPA retained CH2M HILL to complete such a study of wastes being disposed of onsite at each of the Florida mills. The study, which was developed in collaboration with FDEP, was comprehensive and spanned 2 years. It was designed to satisfy the rule and included a solid waste characterization component and an assessment of operational practices, leachate quality, and groundwater quality. The findings of the study demonstrate that, unlike municipal solid wastes, wastes from the pulp and paper industry in Florida are generated by highly controlled manufacturing processes, have known and predictable properties, and are being appropriately managed to prevent adverse environmental impacts. As a result of this study, FDEP exempted the pulp and paper industry from Class I municipal landfill standards pending the development of appropriate standards.