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Farnsworth Paper Works, Inc.

20 Tituba Lake Road

Ossentuck, Washington 00000

Sol Weidman, Manager of Environmental Engineering

October 13, 2001

Vern Fenkel, Manager

Department of Natural Resources

Region No. 4

Fredonia, Washington 00000

Subject: Permits for Pelletization and Disposal of Fly Ash

Mr. Fenkel:

As you know, the operation of a paper plant results in the production of fly ash. Farnsworth Paper Works, Inc. produces this ash at a rate of 1000 tons a year. This waste product requires an environmentally sound and economically viable form of disposal. Our solution is to pelletize about half of the material. This will create a safe fertilizer and avoid the overuse of landfills. Additionally, we have identified a site to hold the remaining ash. This lot will satisfy all of our future demand without negatively impacting the environment. In order to carry out these plans, we will need one permit for pelletizing and another for disposing of the ash. This report will describe our proposed approach. It will then explain why our plan should be chosen over the alternatives when addressing this problem. Finally, it will detail how these ideas are to be implemented and will outline the costs involved.



Naturally, the problem of fly ash grows consistently larger as time passes. Our current method for storing the ash will be exhausted in the next couple months. The Farnsworth property is adjacent to a 40-acre plot that could hold all that we produce for many years to come. A prior misconception, however, has prevented us from employing this region for our waste disposal. In 1979, area residents requested an investigation of the land in response to the dumping of general garbage such as tires and metal. The resulting study showed that the groundwater could be effected due to the groundís permeability. This fear led the Department of Natural Resources to give it a Type III classification. Even though our dumping was not the source of the complaints, we were prevented from making any further use of the fill.

The restriction has remained due to new environmental data. The EPA has found that the leachate from fly ash is high in alkalies. These chemicals raise concerns about the potential pollution of Tituba Lake. These concerns, however, are unfounded. We recently commissioned a consulting firm, Terra Engineering, to study the land in question. Several test wells proved that there were not noticeable levels of the metals in the groundwater between the landfill and the lake. Furthermore, a hydrogeologic analysis showed that the groundwater flows away from the lake.

Since the landfill was reclassified, several alternatives have been presented. The first of these is to transport the ash to a more acceptable fill. However, the nearest Type II landfill is 35 miles from our factory. The transport of our ash over that distance could pose serious environmental hazards. The regular movement by trucks will increase the likelihood of accidental release of the ash. This could cause a serious dust problem. More importantly, the use of the landfill for our relatively harmless ash will decrease the space available for more toxic materials. The other suggested option is to convert our land into a Type II fill. The modifications would consume valuable resources and would not aid the environment. Also, the mounting ash supply demands a more immediate solution than lengthy construction work. We realize the tension caused by the environmental groupsí monitoring of your departmentís actions, but we can show that our solution involves the smallest ecological risk of all the possibilities. In light of the studies we conducted, you can see that our approach causes less damage to the environment and leads to fewer expenses for your department.



In order to dispose of our waste without unnecessarily harming the environment, we will need to begin pelletizing about half of our ash. We will convert 500 tons a year into low-grade fertilizer and will market it in small quantities to gardeners. This will eliminate ash that would otherwise need to be dumped. Also, the resulting substance is just as safe as the potash that is already widely used for this purpose. The process will pay for itself and, at the same time, benefit the environment.

The remainder of the ash cannot be applied in this way. It contains fused sand and must be dumped in a safe location. Since our current facilities are full, we will need to find another site for the 500 to 700 tons produced each year. The 40 acre Type III landfill next to our property satisfies this need. Our research shows that the fly ash will not endanger Lake Tituba or other parts of the local water table. Still, to insure that the groundwater remains free of alkalies, scattered monitoring stations will be established. These will consistently measure the levels of key elements. If evidence shows that a shift in groundwater flow connects the lake with our pile, we will take immediate action to alter the structure of the land. This will promote the continued isolation of the ash. Additionally, the ash presents no dust hazard and should not anger the nearby residents. They were initially concerned with other kinds of waste.

In addition to the theoretical success that are proposal promises, we have obtained testimonials from several plants in similar situations throughout the state. These companies have implemented the pelletizing plan and have reduced their waste considerably with no cost to them or the local ecosystems. For example, Richter Corporation is giving away part of its ash as fertilizer. It is able to maintain low limits on the amount that it must dump. Pittman Products, Inc. is under similar circumstances and is currently seeking approval to convert their ash. They have encountered no financial or ecological stumbling blocks. Also, a few corporations have used Type III landfills without disrupting the groundwater. Ashland Products in Region 2 has disposed of fly ash at a rate similar to our own and has not reported any rise in alkalies. These related scenarios prove that our plans are free from the consequences that the DNR is hoping to prevent.


The costs required to carry out these solutions will be minimal. After the DNR supplies the necessary permits, we will assume all further responsibilities. We are able to do this because the cost of pelletizing will be offset by the profits from the sale of the fertilizer. Outside of our corporation, growers will benefit from the cheap fertilizer that we will be able to provide. This will stimulate local agriculture. Ultimately, we may observe that the environment has benefited from an increase in small-scale gardens.

Our choice of landfills should also bring about as many rewards as costs. The landfill space that remains available will provide ample storage for toxic substances that might otherwise be deposited in less secure areas. The proximity of the proposed landfill will eliminate the transport of the ash over large distances and will therefore reduce the chance that accidents will occur. The only significant cost that remains is the monitoring equipment. Many new devices and personnel will have to be acquired to insure that the groundwater remains clean. We will gladly take care of these minor expenses in the interest of the environment.



Our proposals will solve our current storage crisis and will allow us to consume fewer of the natural resources for which the DNR is responsible. It is in the best interest of the local economy that we be permitted to reduce landfill usage by half and create a marketable product. The interests of the environment are satisfied when we save room in Type II regions for the toxic substances that require them. We request that you supply the necessary permits for pelletization and dumping fly ash in a Type III fill so that we can begin our move toward a cleaner, more cost-effective disposal of our waste.






Sol Weidman, Manager of Environmental Engineering.

Prepared by Jeff DePree.