Contact Pacific Southwest Waste Program
Pacific Southwest, Region 9
Serving: Arizona, California, Hawaii, Nevada, Pacific Islands, Tribal Nations
Solid Waste Management on Tribal Lands
Technical Advice for Cleanup of Accumulated Waste Sites on Tribal Lands
| Tech Advice Contents | |
| Cleanup Plan | » Sample |
| Remediation Plan | » Sample |
| Health & Safety Plan | » Sample |
| Public Participation Plan | » Sample |
| Record Keeping Plan | » Sample |
| Site Cleanup | |
| Sample Jurisdiction | |
Hantavirus Illness in the United States (20 pp, 166K, About PDF)  |
|
Cleanup Plan
Sample Cleanup Plan
This section addresses activities that help ensure that a clean up is conducted in a cost-effective and environmentally sound manner. Gathering adequate information and formulating contingency plans prior to actually starting the project will decrease the number of unforeseen incidents which lead to lost time, cost overruns, accidents, or inadequate site clean up. It is therefore strongly recommended that a comprehensive Cleanup Plan be developed for each waste site. The following sections and information should be included in your Cleanup Plan. Information on possible funding sources for solid waste cleanup activities may be found at the EPA Region Funding web page.
Introduction
Begin the introduction with a general description of the site location, especially in relation to the nearest populated area. A description of the regulatory status of the site should be included. A description and explanation of the jurisdiction for the site is necessary to establish legal responsibilities. Information upon which the plan is based should be briefly described in the event a reviewer wants to look at the data used to develop the Cleanup Plan.
Environmental and Site Description
Location
Provide specific directions to the site. Ensure that enough information is included so that someone unfamiliar with the area could find the site. Geologic survey maps often provide valuable site location information.
Population
How many people live within two miles of the site? Are there are any immediate neighbors? A complete description of the local population, including their concerns and any issues unique to the site will help interested parties assess potential impacts on the community. For example, nuisance factors such as the smell of excavating rotting waste or disposal routes through neighborhoods should be identified here.
Site Use
Estimate how many people currently use the site, and note others who may potentially use the site. Describe the current activity of the site, i.e., abandoned, active, heavy, light, etc.
Site Size and Features
Specific information about the site should include the following:
- Area of the site, in yards (Multiply the length of the site by its width).
- Volume of waste in cubic yards (multiply area by the average depth of the waste). If the main body of waste is in a trench or other depression, estimate and include the volume of waste outside of the depression.
- Waste distribution at the site. Is it in a trench, scattered on the surface, mounded?
- Type of waste present, i.e., household, industrial, yard, dead animals, hazardous, white goods, automobiles, tires, batteries, barrels and drums, etc.
- White goods - Note whether motors, transmissions, or compressors are present.
- Automobiles - Note whether engines, transmissions, differentials, radiators, brake master cylinders, batteries, and air conditioners are present and whether these items still contain their fluids. Proper disposal of tires involves special procedures such as proper burning, chipping or shredding.
- Buried tires - tend to float in landfills and may eventually work their way back to the surface. Improper disposal of tires also creates rodent, snake, and/or insect habitat. Since these animals are frequently disease vectors, there is the potential for public health concerns.
- Barrels and drums - If the original contents of barrels and drums cannot be determined, then these containers should be treated as if they contain hazardous materials. It may be best to conduct preliminary reconnaissance at distance with binoculars and assess potential hazardous conditions. Take particular note of any bulging containers. Bulging may indicate that contents are under pressure and should be handled accordingly.
- Demolition Debris - Demolition debris may contain lead or asbestos. If lead or asbestos is suspected, contact the state or federal EPA for assistance with the special handling and reporting requirements for these wastes. Construction and demolition waste can also be reclaimed, reused, and recycles. Look for facilities where these wastes may be reused if they don’t require special handling.
- Sewage sludge - Pathogens and heavy metals are often present and may pose disposal problems. Compressed gas cylinders - These have the potential to become projectiles or explode when disturbed. Known industrial wastes such as plastics, resins, pulp, rubber, stone, etc. may be hazardous.
- Describe the site location in relation to the surface and subsurface geology and natural features of the land. For example: Is the site located in or adjacent to an arroyo, wash, canyon, intermittent stream or riverbed, pond, or lake? Is it or on a hillside or hilltop? What is the distance from the site to these nearby features? Is the site in a seasonal flood zone? What is the distance from the site to the highest seasonal high water mark?
Estimate the site surface gradient and determine site surface water runoff patterns. Does surface water drain from the site to any nearby watercourse? Plot these features on a map of the site. Take pictures from each of the four sides of the site showing the surrounding topography. Do any of the surrounding surface features show signs of wastes being wind blown or washed down from the disposal site?
Identify and take pictures of any stressed vegetation near or down gradient from the site, since this may be a sign of contamination. Identify and take pictures of any areas of stained soils (e.g., soils stained by used oil dumping, etc.). Plot the location of any stressed vegetation and/or stained soil on a map of the site.
Describe the climatology of the area. What are the annual precipitation and evaporation rates? What are the yearly rainfall patterns. Does all of the rainfall occur during a few months of the year. Are there seasonal variations that could affect on-site work?
Give the depth to groundwater (the uppermost aquifer) at the disposal site. If known, describe the water quality of the underlying aquifer (e.g., is the aquifer suitable for drinking water purposes?) Describe the soil geology beneath the site. This information may be obtained from well drilling records, from current United States Geological Survey (USGS) maps, or by drilling geophysical test borings if data is not readily available. Based on the geophysical characteristics of the underlying soils, assess whether, and to what extent, the existing geology affords any protection to the aquifer. - Note the presence of any industries, businesses, hospitals, and schools within close proximity of the site (e.g., one mile).
- Characterize and describe any potential hazards or problems relating to clean up/removal in the vicinity of the site. Look for such things as water lines, gas lines, power lines, and accesses to the site. Will temporary roads need to be constructed to allow access for necessary equipment? What is the destination of excavated wastes and will they need to be hauled out through, or near residential areas?
- Describe the distance to active wells and other water sources, such as lakes, ponds, rivers, streams, springs, and windmill tanks. Are these up gradient or down gradient from the site and what, if any, use is made of them. For example, is a stream the source of potable water for local residents?
- Describe the distance to sewage lagoons or septic systems and whether these systems are up gradient or down gradient from the site.
- Include any other general information relevant to the clean up of the site. If any of the elements described in (a) though (i) of this section are not present, this should be stated.
Site History
Describe the history of the waste site. Information may often be obtained from a historical records search and should include the following:
- Is it known who may have contributed waste at the site?
- Are there any records or other documentation, i.e., pictures, aerial photographs, etc. about the site?
- Have wastes been burned at the site? Is it possible that explosives may be present? How has hazardous waste been disposed of in the surrounding area? If there is no local arrangement for disposal of hazardous waste, caution should be exercised in that hazardous wastes may be present at the site. See https://www3.epa.gov/epawaste/hazard/wastetypes/index.htm for a description of some of the hazardous materials which may be encountered during a clean up and a listing of common household hazardous wastes.
Sample Cleanup and Removal Plan - Backforty Dumping Area Cleanup and Removal Plan Introduction
General Location
This Cleanup and Removal Plan has been developed for the site known as Backforty Dumping Area. It is located in and around a natural watercourse known as Water Wash. Appaloosa, Arizona is the nearest town, approximately 1.5 miles west of the site. The site is located entirely within the reservation boundaries of the Native American Tribe. The natural course of the wash runs in the direction of northeast to southwest.
Regulatory Status
A Cleanup and Removal Plan is the best and most practical way to assure that all necessary activities and their costs are included in planning for the clean up process. A Cleanup and Removal Plan will also keep to a minimum unforeseen incidents which result in lost time, cost overruns, accidents, or inadequate site clean up. The Backforty Dumping Area is located in and immediately adjacent to a natural watercourse, thereby violating the Clean Water Act (40 CFR Part 230). In addition, there is an airport serving piston-type aircraft within 5,000 feet of the Backforty Dumping Area creating a potential bird hazard for aircraft. Businesses and residences are also located within a mile of the site. Businesses are responsible for contracting for removal of their own solid waste off the Native American Tribe Reservation.
Jurisdiction – See Sample Jurisdiction
Information Used
There are no maintenance and/or operational records available for this site. Information contained in this plan was obtained by visits to and visual observation of the site on July 31, 1998 and August 11, 1998 and represents the existing conditions of the site at that time. These visits and observations were made jointly by Jane Jones, representative for the Native American Tribe, and John Franks, site supervisor for Arid Environments Engineering, Inc., contractor for the clean up of this site.
Environmental and Site Description
Location
The seven discrete waste disposal areas that constitute the Backforty Dumping Area are all located along the approximately 1.5 mile length of Water Wash. Water Wash begins less than a quarter mile south of the fairgrounds, which are in turn located on the eastern edge of the town of Appaloosa.
Population
The town of Appaloosa has a population of 4,513 (1990 Census). Population in the surrounding area is about 5,225 persons. This is the highest population density on the Reservation. There are residences in the area immediately around the site, the closest being 0.6 miles from the northeastern end of the Wash. The community is concerned that hazardous wastes will be hauled through town to a disposal facility. These concerns will be addressed in the Public Participation Plan.
Site Use
The Backforty Dumping Area received periodic waste deposits from the Appaloosa community for approximately 10 years prior to January 1995. The Backforty Dump is no longer used since an open top bin was made available in the town of Appaloosa in January of 1995. Household solid waste is accepted there for a fee. Because of the fee and the fact that there is no convenient alternative disposal for special wastes such as tires and white goods, it is reasonable to assume that casual disposal at Backforty Dumping Area still occurs from time to time. This site has never been maintained in any way. It was simply the convenient and accepted place to dispose of waste as people settled in the area as the town grew.
Site Size and Features
- Area: There are seven discrete waste disposal areas within the Backforty Dumping Area. They extend for approximately 1.5 miles along the length of Water Wash. The average width of the disposal areas is 50 feet and the average depth is 20 feet. There is no sewage sludge or industrial waste at any of the disposal areas. It is possible that compressed gas cylinders are present since propane gas was used for heating and cooking prior to 1987 when electricity became available in Appaloosa. See below for the area, volume of waste, distribution, and type of waste present for each disposal area.
- Geology and natural features: See individual descriptions for location and gradient. The following geological information applies to all waste disposal areas.
- Depth to groundwater – 20 feet
- Soil geology/soil type: silty clay geological strata to groundwater: silty clay
- Annual precipitation – 18 inches per year, annual evaporation 140 inches per year. This area is subject to heavy cloudbursts resulting in immediate heavy run-off and/or flash flooding
- Aquifer information – confined
- Soil permeability – permeable
- Drainage – located in a watercourse
- Industries, businesses, hospitals, or schools. There is one business, a restaurant, located within one mile of the site. There are no industries, hospitals, or schools.
- Potential hazards- See individual descriptions. Except as noted for disposal areas # 2 and # 4, no temporary access roads will be required for this remediation project. Wastes will be hauled approximately 63 miles to the XYZ Landfill. The waste must be trucked trough the town of Appaloosa. Citizen concerns over this process will be addressed in the Public Participation Plan and will include hours of operation, proper cover for loaded trucks, etc.
- Proximity to wells and other water sources - There are no wells or other water sources within one mile. As noted 3 above, however, this area has the potential to become a watercourse after heavy rains.
- Proximity to sewage lagoons - There are no sewage lagoons within one mile of the site.
- Other information- There are residences and one small airport (serving piston-type aircraft) within one mile of the site. There are no buildings on the site. Two major access dirt roads have been blocked off by fencing and currently only one unimproved dirt road provides access. There are no electrical or natural gas lines within one mile of the site. A gray water drain from the rodeo grounds passes under disposal area # 7 and opens into the wash.
Site History
See above under Site Use. There are no records about the site. There are indications that this area was used by local residents for disposal of the usual household wastes and there were no restrictions on what was placed there. There are no indications that any company or individual was responsible for the operation of the Backforty Dumping Area at any time. This is a small agrarian community with no industry or sewage treatment facilities.
With the exception of household hazardous waste and special wastes such as automobile bodies and white goods, it is unlikely that hazardous wastes in appreciable quantities will be found at this site. Anecdotal evidence indicates that the site occasionally caught on fire but there was no deliberate or routine burning. There is no evidence to suggest unexploded ordnance may be present at the site.
Individual Waste Disposal Site Descriptions
Disposal Area # 1 Estimated measurements are 35 yards long X 20 yards wide X 2 yards deep. Area #1 contains approximately 1400 cubic yards of solid waste. Waste is located in a trench, there is no appreciable amount of material scattered out side of the trench. Potential hazardous waste items are used car batteries, labeled/unlabeled 5-gallon steel containers, labeled and unlabeled 1-gallon paint cans, water heaters and washing machines. The washing machines still contain their motors. Waste types are household, car body (without motor, transmission, etc.), oil waste, automobile parts, construction debris, yard waste, textiles, white goods and partially decayed animal carcasses. Exercise caution with construction debris as it may contain asbestos or lead. See https://www.epa.gov/msw/hhw.htm Hazardous Materials for mandatory reporting and disposal information. Waste is located in the wash along the northwest wall. The walls of the wash are near vertical with a slope approaching 90 degrees.
Disposal Area # 2 Estimated measurements are 150 yards long X 50 yards wide X 0.5 yards deep. Area contains approximately 3750 cubic yards of solid waste. Waste is located in a trench; there is also mounded waste and considerable surface scatter. Potential hazardous waste items are car batteries, unlabeled 1-gallon paint container, five-gallon asphalt petroleum container and three empty 55-gallon drums. Construction debris, textiles, yard waste, household waste, furniture, car parts and oil waste are also present. Solid waste is located in the wash, on the slope and on top of the northwest wall. The south wall of the wash is near vertical. The north wall of the wash has a slope averaging about 80 degrees.
Disposal Area # 3 Estimated measurements are 30 yards long X 20 yards wide X 1 yard deep. Area contains approximately 600 cubic yards of solid waste. Waste is located in a trench with little surface scatter. There do not appear to be any potentially hazardous waste items in this area. Waste types are household, textiles, furniture, oil waste and automobile parts. Solid waste is located in the wash along the northwest wall. The walls of the wash are near a vertical slope approaching 90 degrees.
Disposal Area # 4 Estimated measurements are 118 yards long X 12 yards wide X 1 yard deep. Area contains approximately 1416 cubic yards of solid waste. Waste is surface scatter that will require manual clean up. Potential hazardous waste items are refrigerators, water heaters, washing machines. All of these items contain their motors/compressors. Waste types are household, construction debris, household hazardous waste, white goods, auto parts, oil waste, furniture, and textiles. Waste is located along the unimproved dirt road and in the wash. The northwest wall of the wash has a slope averaging about 80 degrees. The southeast wall is vertical.
Disposal Area # 5 Estimated measurements are 125 yards long X 5 yards wide X 0.5 yards deep along the unimproved dirt road. Estimated measurements for solid waste buried along the north wall of the wash are approximately 20 yards long X 10 yards wide X 3 yards deep. Area contains approximately 920 cubic yards of solid waste, approximately 320 cubic yards located along the unimproved dirt road and approximately 600 cubic yards buried along the north wall of the wash. Waste is surface scatter along the road with some in a shallow trench along the wall. There do not appear to be any potentially hazardous waste items in this area. Waste types are household, construction debris, white goods (with motors/compressors), furniture, oil waste and automobile parts. The northwest wall is vertical and the southeast wall has a slope approaching 80 degrees.
Disposal Area # 6 Estimated measurements are 10 yards long X 20 yards wide X 1 yard deep. Area contains approximately 200 cubic yards of solid waste. Waste is mounded. There do not appear to be any potentially hazardous waste items in this area. Waste types are household, construction debris and asphalt debris. Solid waste is located along the north wall of the wash. The walls of the wash are near vertical with a slope approaching 90 degrees.
Disposal Area # 7 The wash at this point is estimated to be approximately 10 yards long X 10 yards wide X 0.5 yards deep. Area contains approximately 50 cubic yards of solid waste. Waste is mounded and does not appear to contain any potentially hazardous waste items. Waste types are household and construction debris. Waste is located along the slope of the northwest wall of the wash. The north wall has a slope approaching 80 degrees and the south wall is near vertical.