DSHW-2025-001838

To Whom It May Concern,
Div of Waste Management
and Radiation Control
APR O ~ 2025
During our most recent inspection, we were informed that we need to
re-evaluate how we determine the weight of items being disposed of
at our landfill. Since opening in 1993, we have followed the guidance
of our permit writers, who encouraged us to measure and calculate
waste based on cubic yards. However, our most recent inspection
revealed that our permit does not explicitly support this method,
despite it being the practice encouraged by inspectors over the years.
Until now, we were unaware that this approach was not aligned with
the state's expectations.
After discussing this matter with our assigned inspector, we
understand that we must either change our methodology or rely on
estimates. However, we have found that estimating load weights can
be highly inaccurate due to the significant variability in material
density. For example, wet grass is significantly heavier than dry
grass-sometimes nearly four times as much. Similarly, demolition
materials can vary greatly in weight, with sheetrock being much
denser than pallets.
To ensure greater accuracy, we have obtained a weight-to-volume
conversion factor document from the U.S. Environmental Protection
Agency's Office of Resource Conservation and Recovery (April
2016).This document provides standardized weight estimates for
various waste materials by cubic yard. At our landfill, we have
designated starting and ending points where we can measure
compacted materials, allowing us to apply these conversion factors
effectively.
Given that we are a small landfill with limited waste intake, we believe
that using the EPA's volume-to-weight conversion method would
provide the most reliable and consistent measurement approach.
Therefore we formally request approval to use the EPA's conversion
factors to determine the weight and volume of waste at our facility.
We appreciate your time and consideration and look forward to your
response. Please let us know if any further information is needed.
Sincerely,
Christopher Weicks
Landfill Operator
Plain City Landfill