Montgomery County, Maryland
Feedstock System Assessment
1,800 TPD of manufacturing feedstock flows to a single facility under a contract expiring April 2031 — no in-county landfill fallback, and an active long-haul RFP pending award that will lock the interim disposal pathway.
What this document is
How Montgomery County’s residual stream is generated, routed and paid for today — volumes, the Dickerson RRF contract, transfer-station economics, and the share that qualifies as manufacturing feedstock.
- The County’s residual system runs through a Resource Recovery Facility whose contract expires in April 2031, and no replacement pathway is contracted.
- The collector-facing tipping fee understates what the system actually costs the County; the Fully-Weighted Disposal Cost is the correct basis for any comparison.
- The addressable stream is large enough to support deployment at every phase without competing with the County’s own diversion goals.
- Read the commercial structure ↗What the County would sign, and on what terms.
- See the economic model ↗State A against State B, with each flow reported separately.
- Back to the package hub ↗All six documents in one place.
What This Means
This assessment documents the structure, cost, and strategic condition of Montgomery County's manufacturing feedstock system. Five findings define the current posture:
- The RFP award — not April 2031 — is the operative near-term deadline. Award locks the bridge disposal contractor. Engaging before award preserves maximum pathway flexibility; engaging after award narrows the entry window to the bridge contract's expiry.
- At $90/ton FWDC, the current system costs approximately $59.1M per year for the MSW stream alone. Confirmation of FWDC — the largest outstanding unknown — is the gating step before any contract cost comparison is meaningful.
- The April 2031 RRF expiry is a structural discontinuity, not a rolling date. Any system not operational by that date leaves 657,000 TPY of manufacturing feedstock without a contracted disposal pathway.
- The County's own DEP documentation explicitly references exploration of advanced processing technologies concurrent with the RFP process — establishing a documented policy basis for ACM engagement.
Feedstock Profile
§ 1.1 — Feedstock Volume Table
| Stream | Annual (tpy) | Daily (TPD) | Current Disposition | Operator | Access Classification | ACM Phase | Status |
|---|---|---|---|---|---|---|---|
| MSW Residual | 657,000 | 1,800 | Shady Grove TS → CSX rail → Dickerson RRF | Reworld Montgomery / NMWDA | IMMEDIATE | Initial | VERIFIED |
| Dual-Stream Recyclables | 175,200 | 480 | Shady Grove MRF → commodities markets | Montgomery County RRMD | CONDITIONAL | Medium | ESTIMATED |
| Yard Trim | 116,800 | 320 | County composting facility | Montgomery County RRMD | CONDITIONAL | Medium | ESTIMATED |
| Organics / Food Scraps | 65,700 | 180 | Emerging diversion; majority to RRF | Multiple | CONDITIONAL | Medium | ESTIMATED |
| Biosolids — MC Share (wet) | 52,925 | 145 | WSSC Water WRRFs → Piscataway Bioenergy | WSSC Water | CONDITIONAL | Medium–Expanded | ESTIMATED |
| Construction & Demolition Debris | 80,300 | 220 | Private facilities, partial recycling | Private contractors | ACCESSIBLE | Expanded | ESTIMATED |
| Special Waste / HHW / Other | 27,375 | 75 | HHW programs, private contractors | Multiple | ACCESSIBLE | Expanded | ESTIMATED |
MSW Residual VERIFIED per NMWDA / Montgomery County DEP. Non-MSW streams estimated from county population benchmarks and Maryland DEP data.
§ 1.2 — Primary ACM Feedstocks
The MSW Residual stream (1,800 TPD / 657,000 TPY) is the Phase Initial target — IMMEDIATE classification, no additional contract negotiation required beyond the RRF expiry. This single stream fully supports a Phase Initial 400 TPD deployment. Dual-stream recyclables (480 TPD) and yard trim (320 TPD) are Phase Medium targets — CONDITIONAL pending MRF contract terms and composting program structure.
§ 1.3 — Full Feedstock Capability Statement
Per MASTER_RULES §16.1, ACM is confirmed capable of processing all seven stream categories identified in Montgomery County's feedstock system: MSW Residual · Recyclables · Yard Trim · Organics · Biosolids · Construction & Demolition · Special Waste / HHW. No stream is beyond ACM's technical capability. All classification barriers are access-based only.
Logistics & Infrastructure
§ 2.1 — Current Collection Infrastructure
Montgomery County operates a fully integrated collection-to-disposal system for residential and commercial MSW. The County provides weekly curbside collection to single-family homes and townhomes. All material routes to the Shady Grove Processing Facility and Transfer Station at 16101 Frederick Road, Derwood, MD — the single convergence point for the entire MSW stream.
§ 2.2 — Rail Infrastructure
The County's system is built around CSX rail, eliminating truck traffic on rural roads in the Dickerson corridor. Gantry cranes at Shady Grove TS load containers onto railcars for daily assembly by CSX. This creates a per-ton transport cost advantage under current volumes but introduces a structural dependency: any disruption to CSX service, the TS rail yard, or the Dickerson railyard creates an uncontracted disposal position with no immediate fallback. An ACM facility co-located at Shady Grove would eliminate this rail dependency entirely for converted feedstock volumes.
§ 2.3 — Transfer Station Capacity
The Shady Grove TS is confirmed at or near capacity per County DEP documentation. The RFP issued September 2025 includes TS operation as a core contractor deliverable — confirming the County anticipates operational changes under the incoming bridge contract. Any co-located ACM facility at the Shady Grove Industrial Corridor would need to account for TS throughput constraints or be positioned to receive feedstock directly ahead of the TS processing step.
§ 2.4 — Off-County Disposal Dependency
Ash residue (approximately 26% of input weight) is transported by sealed railcar to a private landfill in Brunswick, Virginia. The County's own environmental justice analysis identified the Brunswick, VA disposal community as majority low-income and Black — a documented EJ exposure in the current system. A transition to ACM eliminates this ash residue stream entirely within converted volumes, as ACM produces no landfill-destined ash residue by design.
Cost Structure
§ 3.1 — Current System Cost Table
| Cost Element | Unit Cost | Annual (657K tpy basis) | Source Type | Confidence |
|---|---|---|---|---|
| Collector-facing tipping fee — Shady Grove TS | $70/ton | $45.99M | VERIFIED | High — MC SWC FY2026 |
| FWDC — County TS+RRF combined operating estimate | ~$90/ton | ~$59.1M | ESTIMATED | Medium — DEP Council briefing Jan 2025 |
| Bridge long-haul alternative (for comparison) | ~$130/ton | ~$85.4M | ESTIMATED | Medium — DEP council estimate Jan 2025 |
| Per-household disposal charge (FY2026) | $87.17/yr | ~$33.9M (389K HH) | VERIFIED | High — MC SWC FY2026 |
| Implied per-ton household rate | $108.57/ton | — | MODELED | Medium — derived from HH charge and per-HH volume |
| NMWDA service agreement annual cost | Not disclosed | — | Data Gap | — |
| Ash residue disposal — Brunswick, VA | Not disclosed | — | Data Gap | — |
§ 3.2 — Verified Operator Names
RRF Operator: Reworld Montgomery, Inc. (formerly Covanta Montgomery, Inc.) — operating on behalf of the Northeast Maryland Waste Disposal Authority (NMWDA). Verified: nmwda.org, montgomerycountymd.gov/DEP, October 2025.
Transfer Station / MRF Operator: Montgomery County Department of Environmental Protection — Recycling and Resource Management Division (RRMD). Verified: montgomerycountymd.gov/DEP.
Biosolids Operator: WSSC Water (formerly Washington Suburban Sanitary Commission). Piscataway Bioenergy Facility opened October 30, 2024. Verified: wsscwater.com.
§ 3.3 — Cost Trajectory
- FWDC confirmation is the single most important analytical step before Proposal evaluation. A confirmed FWDC above $90/ton widens the gross cost displacement advantage; a FWDC below $90/ton narrows it. The gap between tipping fee ($70/ton) and FWDC ($90/ton estimated) is already $20/ton — $13.1M/year at current throughput.
- The bridge long-haul scenario at $130/ton represents a $40/ton cost increase over current FWDC — $26.3M/year in additional cost burden at MSW Residual volumes. This is the cost of transitional uncertainty if no alternative technology is operational by April 2031.
Regulatory Baseline
§ 4.1 — Hard External Deadlines
| Deadline | Date | Mechanism | Action Window |
|---|---|---|---|
| RFP #1184252 — Long-haul contract award | Pending Q1–Q2 2026 (estimated) | Award locks interim disposal contractor and pathway for bridge contract term | Now — active evaluation. Engage before award. |
| RRF Service Agreement expiry | April 2031 | Contract termination. No contracted fallback exists. New RRF contract = capex commitment + pathway foreclosure. | ACM Phase Initial COD must reach Q4 2028–Q1 2029 minimum to provide coverage at expiry |
| Montgomery County SWMP 2025–2034 | Adopted April 2025 | 10-year planning framework; governs permissible system types and goals | ACM classified as eligible "alternative technology" per DEP Zero Waste documentation |
§ 4.2 — Environmental Compliance Context
The Dickerson RRF holds a Title V air permit and operates under Maryland Department of the Environment oversight. The County's own council analysis documented the Brunswick, Virginia ash disposal as an environmental justice concern — the disposal community is majority low-income and Black. These factors are documented context for any alternative technology siting and EJ analysis.
§ 4.3 — Policy Alignment
Montgomery County DEP's Aiming for Zero Waste program documentation states: "Concurrent with this RFP process, we will continue to explore potential advanced waste processing technologies and enhanced programs to further reduce the MSW stream requiring disposal." This language, published on the official County DEP site, establishes an explicit documented policy basis for advanced processing technology engagement parallel to the bridge contract process.
Feedstock Opportunity
| Category | Volume (tpy) | TPD | Access Classification |
|---|---|---|---|
| IMMEDIATE — no contract barrier at RRF expiry | 657,000 | 1,800 | IMMEDIATE |
| CONDITIONAL — negotiation or contract modification | 409,825 | 1,125 | CONDITIONAL |
| ACCESSIBLE — third-party engagement required | 107,675 | 295 | ACCESSIBLE |
| Total Addressable System | 1,174,500 | 3,220 | — |
§ 5.2 — Addressability Table
| Stream | Annual (tpy) | TPD | Access Classification | Phase | Primary Access Constraint |
|---|---|---|---|---|---|
| MSW Residual | 657,000 | 1,800 | IMMEDIATE | Initial | RRF contract expiry April 2031 — or bridge contract window |
| Dual-Stream Recyclables | 175,200 | 480 | CONDITIONAL | Medium | MRF contract terms; commodities market exit conditions |
| Yard Trim | 116,800 | 320 | CONDITIONAL | Medium | County composting contract and capacity |
| Organics / Food Scraps | 65,700 | 180 | CONDITIONAL | Medium | Emerging diversion program; majority currently co-mingled with MSW Residual |
| Biosolids — MC Share | 52,925 | 145 | CONDITIONAL | Medium–Expanded | WSSC Water bilateral engagement; MC/PG County apportionment |
| C&D Debris | 80,300 | 220 | ACCESSIBLE | Expanded | Private facility relationships; RRMD permit conditions |
| Special Waste / HHW | 27,375 | 75 | ACCESSIBLE | Expanded | HHW collection program structure; contractor relationships |
§ 5.3 — Phase Configuration
Phase Initial (400 TPD / 4 modules): MSW Residual only. No additional negotiations required. Minimum viable deployment. Covers 22% of the MSW stream; 12% of total addressable system.
Phase Expanded (2,000 TPD / 20 modules): All seven streams. Full bilateral engagement required. Maximum addressable ceiling. Lifetime Circular Royalty™ projected at approximately $735M (ESTIMATED — Carbotura standard parameters).
Infrastructure Map
Active and closed facilities — Montgomery County, Maryland and immediate region. Closed/historical landfills shown as grey dashed squares per MDE Solid Waste Program and Montgomery County DEP post-closure records.
21204 Martinsburg Rd, Dickerson, MD 20842
16101 Frederick Rd, Derwood, MD 20855
Accokeek, MD (Prince George's County)
6001 Olney-Laytonsville Rd, Gaithersburg, MD
600 East Gude Dr, Rockville, MD 20850
| Figure | Value | Public Source | Source Type | Confidence |
|---|---|---|---|---|
| RRF daily throughput | ~1,800 TPD | Montgomery County DEP "Aiming for Zero Waste"; NMWDA facility description | VERIFIED | High |
| RRF annual throughput | 657,000 TPY | Derived: 1,800 TPD × 365 days | MODELED | High |
| RRF operator — current name | Reworld Montgomery, Inc. | nmwda.org · montgomerycountymd.gov/DEP (Oct 2025) | VERIFIED | High |
| Tipping fee — Shady Grove TS (FY2026) | $70/ton | Montgomery County SWC FY2026 residential fee schedule | VERIFIED | High |
| FWDC — combined TS+RRF operating estimate | ~$90/ton | Montgomery County DEP — Council briefing, January 28, 2025 | ESTIMATED | Medium |
| Bridge long-haul cost estimate | ~$130/ton | Montgomery County DEP — Council briefing January 28, 2025 | ESTIMATED | Medium |
| Per-household disposal charge (FY2026) | $87.17/yr | Montgomery County SWC page (FY2026 rates) | VERIFIED | High |
| RRF contract expiry | April 2031 | montgomerycountymd.gov/DEP — Aiming for Zero Waste | VERIFIED | High |
| RFP #1184252 issuance | September 19, 2025 | Montgomery County DEP Zero Waste page; BidNet Maryland Purchasing Group | VERIFIED | High |
| RFP #1184252 close date | November 11, 2025 | BidNet solicitation record #1184252 | VERIFIED | High |
| Ash residue weight fraction | ~26% | Montgomery County Council — DEP long-haul analysis | ESTIMATED | Medium |
| Biosolids operator — WSSC Water | Confirmed | wsscwater.com — Piscataway Bioenergy (opened Oct 30, 2024) | VERIFIED | High |
| Oaks Landfill closure date | 1997 | montgomerycountymd.gov/DEP/trash-recycling/facilities/oaks-landfill | VERIFIED | High |
| Gude Landfill closure date | 1982 | montgomerycountymd.gov/DEP/trash-recycling/facilities/gude-landfill | VERIFIED | High |
| County population | 1,082,273 | US Census Bureau 2024 estimate | VERIFIED | High |
| Factor | Direction | Mechanism |
|---|---|---|
| FWDC confirmed above $90/ton | Increases ACM cost advantage | Widens gross cost displacement per ton at Phase Initial — every $1/ton of confirmed FWDC above $90 = $146K/year additional annual advantage at 146K tpy |
| RFP #1184252 awarded before ACM engagement | Reduces entry flexibility | Bridge contract locks interim disposal pathway; ACM entry window narrows to bridge contract expiry date — potentially 3–5 years later than April 2031 |
| RRF contract renewed instead of bridge transition | Forecloses ACM pathway through mid-2030s+ | Long-term RRF renewal commits County to major capital reinvestment and fixed-cost structure for the renewal term; alternative technology entry requires contract renegotiation |
| Organics diversion increases materially | Reduces IMMEDIATE stream volume | Zero Waste goals target increased organics capture; if achieved, reduces MSW Residual co-mingled volume available to RRF or ACM |
| Maryland state policy — alternative processing mandate | Increases ACM policy basis | Maryland's evolving solid waste policy could mandate alternative technology evaluation, strengthening ACM engagement framework |
| WSSC Water bilateral engagement | Expands CONDITIONAL stream to earlier phase | If WSSC Water confirms Piscataway capacity allocation, biosolids stream (145 TPD) moves to Phase Medium IMMEDIATE |
| Shady Grove Industrial Corridor land availability confirmed | Accelerates Phase Initial timeline and reduces site risk | P1 site is unconfirmed. Confirmation is the single largest site risk item in the deployment timeline; resolution is a Waste Study deliverable |
- Montgomery County DEP — Aiming for Zero Waste Program · montgomerycountymd.gov/DEP/trash-recycling/programs/zero-waste
- Montgomery County DEP — Shady Grove Processing Facility and Transfer Station · montgomerycountymd.gov/dep/trash-recycling/facilities/transfer-station
- Montgomery County DEP — Oaks Landfill post-closure documentation · montgomerycountymd.gov/DEP/trash-recycling/facilities/oaks-landfill
- Montgomery County DEP — Gude Landfill post-closure documentation · montgomerycountymd.gov/DEP/trash-recycling/facilities/gude-landfill
- Northeast Maryland Waste Disposal Authority — Montgomery County RRF · nmwda.org/montgomery-county · October 2025
- WSSC Water — Piscataway Bioenergy Facility · wsscwater.com · October 2024
- Montgomery County Government — Council Briefing, Long-Haul MSW Management (DEP + Arcadis analysis), January 28, 2025 · montgomerycountymd.granicus.com
- RFP #1184252 — Shady Grove Transfer Station Operation, MSW Long Haul Transportation & Disposal · BidNet Maryland Purchasing Group · Issued September 19, 2025 · Closed November 11, 2025
- Montgomery County Solid Waste Advisory Committee Meeting Minutes, January 22, 2025
- Maryland Department of the Environment — Solid Waste Management and Diversion Report 2024 · mde.maryland.gov
- Montgomery County Comprehensive Solid Waste Management Plan 2025–2034 · Adopted April 2025
- US Census Bureau — Montgomery County Population Estimates 2024
- Arcadis — MSW Management Systems Analysis for Montgomery County · Referenced in DEP council materials, 2025 (independent analysis)