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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
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Remediation Plan

Remediation is the process of clean up. As used in this document, a site which has undergone remediation has had wastes removed, but has not necessarily been returned to its original condition or prepared for specific future uses. Remediation readies the site for reclamation (see below).

The Remediation Plan describes clean up and removal methods in detail. It lists personnel and equipment requirements for each activity, as well as the cost of each phase.

Essential equipment includes the following:

  • front loader
  • dozer
  • dump truck
  • sanitation facilities including hand washing facilities
  • first aid supplies
  • emergency eye wash facilities
  • personal safety equipment
  • decontamination supplies if site contains (or is suspected of containing) biological or hazardous waste

Essential personnel include the following:

  • site supervisor
  • qualified Health and Safety Officer
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  • qualified, licensed equipment operators
  • workers/laborers (specify number)

Additional equipment and/or personnel may be required depending on the condition found at specific sites. For example, field air monitoring equipment for detection of flammable or toxic gases may be needed if buried waste is being excavated, because pockets of such gases might lead to worker injuries if they are not detected and mitigated. Developing accurate cost estimates for clean up and removal may require an individual experienced in road construction and/or construction site development. The following is a list of remediation activities that should be addressed in the Remediation Plan.

  • Identify facilities which could recycle or reuse certain wastes. Discarded items such as glass, metals, aluminum, white goods, plastics, and construction/demolition debris are easily and best recycled if a facility is within a reasonable distance
  • .
  • To avoid costly surprises, obtain written confirmation regarding the types of waste that are accepted at the intended disposal facility. Nonhazardous solid waste not recycled or transported for reuse should go to a RCRA Subtitle D municipal solid waste facility.
  • Estimate the volume and weight per cubic yard of materials to be removed. (Uncompacted municipal waste weighs about 160 lbs. per cubic yard.)
  • Consider equipment operation and maintenance, and any necessary decontamination of equipment. Include storage for fuel, water, and other necessary supplies.
  • Determine accessibility of the site. For example, if the site is in an arroyo or a wash, a temporary access road may need to be constructed.
  • Consider what, if any, special mitigation/control measures might be required, i.e., dust, storm water, or odor control.
  • Determine the time to load at the clean up site, unload at disposal site, and the distance to the disposal site.
  • Determine disposal and recycling costs at the disposal site and recycling center where waste will be taken.
  • Consider segregation and removal of special wastes such as automobile bodies, white goods, asbestos, and medical waste.
  • Plan for testing of unknown materials for the presence of hazardous wastes. Include information on waste reduction and recycling in public materials and meetings.
  • Plan for public information campaigns, public meetings, and notices.
  • Plan for control of the site to limit public access.
  • Consider health and safety training and equipment.
  • Consider rodent trapping and disposal.
  • Consider any on-site waste processing before final removal, such as shredding tires on-site to reduce volume.
  • Determine workers wages and insurance. Be sure to include the Site Supervisor and Health and Safety Officer(s).
  • Consider the need for temporary office space.

NOTE: Asbestos, lead, and other listed hazardous materials require special handling and reporting. It will be necessary to seek technical advice for disposal of these materials from the state or federal EPA.

Automobile bodies and white goods also require separate removal techniques. We recommend that a local metals salvager be contacted for assistance in removing these wastes. Since these are some of the items that can be recycled, skillful negotiation may result in diminished or eliminated removal costs.

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The bulk of a clean up can be accomplished mechanically. Often, however, there is wind-blown litter and scattered waste that must be consolidated into the main body of waste. Unfortunately, most of this pick-up work must be done by hand. (See the Health and Safety Plan for specific requirements regarding personnel safety equipment and procedures. For safety, the number of workers at a site being cleaned up should be kept to the minimum number actually needed to accomplish given tasks in a day.)

Remediation Plan

To reduce the potential exposure to infectious agents and products, the Native American Tribe's Environmental Health crew will trap rodents for 32 days, beginning three days prior to the arrival of the remediation crew. The partially decayed animal carcasses identified in disposal site #1 will be burned on the spot using gasoline. Recycling centers for glass, metals, and white goods have been identified. When feasible, segregation and transportation of these materials to recycling centers has been arranged.

Written confirmation that XYZ Landfill will accept wastes from Backforty Dumping Area is on file at the Site Supervisor’s office and will become part of the permanent record of this remediation project. It is not necessary to do any on-site processing of wastes before final removal from these disposal areas. Hazardous wastes, tires, white goods, and automobile bodies will be disposed of separately. See below for details.

Temporary modular buildings will be used for the Site Supervisor’s office, equipment maintenance area, and storage areas for equipment and supplies. The contractor, Arid Environments Engineering, Inc., shall provide these temporary structures and be responsible for them during the project. Arid Environments Engineering, Inc. shall also remove these structures when work has been completed.

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Because of the danger of flash flooding in the area remediation work will be conducted only during dry months of the year. If thunderstorms occur while work is in progress work will be stopped immediately and the workers evacuated. See the Health and Safety Plan for details.

Waste in trenches or mounds will be picked up with a front-end loader and placed into 40-cubic-yard bins. It may be necessary for workers to use lines to descend to the bottom of the wash in order to retrieve certain wastes. For those areas which have surface-scattered waste manual pickup will be necessary. Workers outfitted with long tongs or pointed stakes shall collect such scattered waste in large plastic bags. These bags will be collected as necessary and also removed to the waste bins. Suggested bin locations during the clean up are on the north side of disposal area # 2 and on the north side of disposal area # 5. These bins will be taken to a staging area near disposal area # 5 and the waste transferred to dump trucks. A dragline and pulleys will be used to remove waste from the wash and it will also be placed in dump trucks at the rim. These trucks will then be covered and proceed to XYZ landfill for waste disposal. The firm of J.C. Dumping will be responsible for transport of the waste from the site to the landfill. A temporary access road into the wash may be necessary at disposal areas # 2 and # 4.

The following items will be separated and properly disposed of by Southwest Hazard Removal Company:

  • Hazardous or potentially hazardous waste
  • Tires

The suggested workforce includes at least one Field Supervisor, one Health and Safety Officer, one heavy equipment operator, and one laborer for each of the areas being worked. Local workers will be hired to make up the labor force.

The local metal salvaging company, AFH, Inc. has been hired to remove all automobile bodies and white goods from the site. Necessary equipment for this project includes one front-end loader, one backhoe, one 200 horsepower dozer, and 193 40-cubic-yard bins.

Costs to clean up and remove wastes from this site are based on material amount and sources, labor, and equipment. Estimated cost: $151,047.90. The project is expected to last 29 working days. Estimated total volume of solid waste (all disposal areas): 8336 cubic yards. See Table I-1 for tasks, equipment and costs.

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