ADEQ Denies Exemption, Old Campus Building Debris Must Be Cleaned Up

By Linda Kor
   In an effort to stem what could be a financial burden, a petition for exemption filed by Northland Pioneer College (NPC) with the Arizona Department of Environmental Quality (ADEQ) regarding the construction and demolition debris buried at the old NPC campus in Holbrook has been formally denied.
   The request submitted to ADEQ, dated Aug. 5, 2009, and signed by NPC President Dr. Jeanne Swarthout, stated that NPC officials feel that the debris buried at the site on Hermosa Drive is unlikely to cause or substantially contribute to a threat to the public health or environment.
   The letter also stated that the demolition debris is primarily composed of material that represents no environmental risk or hazard, with more than 90 percent of the material being earth, concrete, masonry and steel in concrete.
   “Steel is unlikely to cause a public health or environmental threat; carpet nylon fibers are unlikely to deteriorate; gypsum board is composed of naturally occurring inorganic mineral, and paper and acoustic ceiling panels are made of wood cellulose fibers,” Swarthout stated in the letter, adding that the possibility of air pollution and water pollution is zero.
   The exemption request stated that NPC is facing increased demand on its limited resources due to reduced availability of state and local tax-based support. In addition, college officials are concerned with the potential environmental cost associated with the removal of the debris from the site. “Pollution would be caused by equipment and vehicles required to remove the materials. Valuable landfill space would be taken up by large quantities of non-hazardous material and earth,” the letter stated.
   Despite the reasons cited, ADEQ did not agree with NPC’s findings. A reply dated Nov. 12 and signed by Amanda Stone, director of the Waste Programs Division, stated that the type of debris buried at the site could indeed present a hazard that needs to be addressed.
   “Construction and demolition debris often contains concrete, metal, bricks, glass and plastics, among other items. In addition, this debris may also contain high organic based items such as ceiling tiles, insulation treated cellulose, insulation sheathing, pressboard, chipboard, roofing materials such as roofing felt and asphalt shingles, plywood, particleboard, as well as composite materials such as, carpeting, carpet padding, gypsum wallboard, electrical fixtures, electrical switches, rubber hosing/conduits and pressure treated wood,” Stone wrote.
   According to Stone, several of these construction and demolition debris components pose human health threats when they break down and produce highly toxic hydrogen sulfide gas and highly flammable methane gas. “These gases pose the greatest potential health threat to on-site workers, visitors and residents in the areas surrounding the landfills,” stated Stone.
   Another concern by ADEQ is the potential presence of asbestos containing materials commonly found in insulation, floor tiles, siding, shingles and asphalt roofing products. “Because it can cause a variety of health issues, including scarring of the lung tissue and certain types of cancer, asbestos is strictly regulated by ADEQ and the Environmental Protection Agency,” explained Stone.
   NPC Vice President of Administrative Services Blaine Hatch stated during the Nov. 17 meeting of the Navajo County Community College District Governing Board that he believed a certificate stating that no asbestos was used in the construction of the building was available and would be presented to ADEQ.
   The original complaint stemmed from an investigation by ADEQ into the Hermosa Drive site on March 26, 2008. The site was being prepared for the Northern Arizona Regional Behavioral Health Authority (NARBHA) detoxification center site when it was alleged that more than concrete was buried on the property.
   According to information provided by ADEQ, the original building slabs and foundations were left in place and covered with at least 12 inches of earth. The remainder of the building components were placed in a 10 foot deep pit, mixed with earth, compacted and covered with at least two feet of earth. The pit runs parallel to and closely aligns with the ends of the detoxification facility.
   The pit in question is approximately 44’ wide and 252’ long, and the estimated quantity of material under the earth cap is approximately 3,285 cubic yards.
   Though ADEQ will not be able to exempt those materials Stone did present options for the college. “ADEQ could reach an agreement with NPC for disposal in place with monitoring for hydrogen sulfide and methane gas (or) NPC could excavate the solid waste with assistance from the contractors, the City of Holbrook and ADEQ,” she wrote.
   Although Stone noted that ADEQ has no recycling grant funds remaining, she stated that other grants may be available through the Environment Protection Agency.
   The letter from ADEQ also stated that due to the potential for explosion of methane and hydrogen sulfide gases generated from the wastes, if an agreement is not reached, the demolition waste must be excavated and disposed of at a facility that is permitted to accept such wastes. Any inert material, such as concrete, asphaltic pavement, brick, rock, gravel, sand, soil and metal (if used as reinforcement), may remain on site.
   The matter was elaborated on in a separate letter addressed to Senator Sylvia Allen, Representatives Jack Brown and Bill Konopniki, and Governing Board Chairman Bill Jeffers, who each wrote letters of support on behalf of the college’s petition.
   The letter, signed by ADEQ Director Benjamin H. Grumbles stated that ADEQ understands that NPC, like many other educational institutions in Arizona, is experiencing financial hardship in these difficult economic times. He added that ADEQ intends to work closely with NPC to develop a cost effective strategy to address the situation.
   It was also noted that ADEQ is committed to pursuing all parties responsible for the illegal burial of the material located at the former NPC location. To that end, ADEQ has issued a notice of violation for illegal disposal of solid waste to the contractor and subcontractor who executed the contract with NPC and illegally disposed of the waste. Pursuit of these parties may yield additional technical and financial resources to address the required cleanup, according to ADEQ.