PUGET SOUND BASIN
Offi
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REPORT TO THE TULALIP INDIAN TRIBE
EVALUATION OF THE EBEY SLOUGH
LANDFILL OPERATION
ENVIRONMENTAL
PROTECTION
AGENCY
REGION X
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION X
r, 1200 SIXTH AVENUE
2 SEATTLE, WASHINGTON 98101
T
January 12, 1973 .
REPLY 10CSW - M/S 533
Mr. Wayne Williams
Tribal Manager
Tulalip Indian Tribe
3901 Totem Beach Road
Marysville, Washington 98270
Dear Mr. Williams:
We are glad to submit for your review three copies of the technical
assistance report prepared for the Tulalip Indian Tribe by this office.
Your guidance and overall assistance in the development of the report has
been appreciated.
The general purpose of the report is to disseminate information and
knowledge to the Tribe on the environmental aspects of solid waste
management as well as provide some technical assistance in the operation
of sanitary landfills. To complement the information contained in the
report, we have also enclosed copies of each publication referenced in it.
Special attention is directed to the conclusions and recommendations
discussed in the cover memorandum and the Recommendations section of the
report. Several significant deficiencies were apparent to EPA in the
operation of the Ebey Slough landfill at the time of our inspections.
The report correctly concludes that these conditions should be the subject
of immediate abatement action. In addition, it should be noted that the
report based its recommendations upon proposed federal Sanitary Landfill
Guidelines.
Careful consideration should be given to the report and steps
initiated to implement its recommendations. The Solid Waste Management
Branch will be glad to give additional technical assistance to you in
meeting these recommendations once the Tribe has had the opportunity to
consider the report.
To provide for a full discussion of the report contents, please call
either Mr. Rod Hansen or myself (telephone 442-1260) by January 26, 1973.
Sincerely,
ester E. Blaschke
Chief, Solid Waste Management Branch
Enclosures
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ENVIRONMENTAL PROTECTION AGENCY
LYTO
ITNOF: 1 OCSW - M/S 533 DATE: January 11, 1973
bjECT: Report to the Tulalip Indian Tribe
I Evaluation of the Ebey Slough Landfill Operation %
Lester E. Blaschke, Chief
Solid VJaste Management Branch
Enclosed is the technical assistance report prepared for the
Tulalip Indian Tribe.
The findings of the report are that serious water pollution problems
exist at the landfill site, and that decomposition gases present a poten-
tially serious fire and explosion hazard. In addition, the Federal Water
Pollution Control Act Amendments of 1972 may have an impact upon this
operation.
The report presents several important recommendations to the Tribe.
The most significant of these is that the disposal of decomposible solid
wastes at the site be terminated. In addition, the report contains specific
recommendations that include:
1. The elimination of solid waste-surface water contact that occurs
along a portion of the existing fill.
2. The containment, collection, and treatment of leachate from the
existing fill .
3. An assessment of decomposition gas control needs, as they relate
to the intended final site use.
4. The construction of gas vents through the final cover.
5. The monitoring of methane concentrations in the existing main-
tenance building, if it is to be retained, and the removal of welding and
cutting operations from the building.
Conditions at the site merit immediate abatement action. A meeting
with the Tulalip Tribe should be requested to provide for a full discussion
of the report. In addition, copies of the report should be circulated to
the other Divisions of EPA Region X for review with_ respect to their
activities.
Roc
Mission 5000 Project Officer
Solid Waste Management Branch
EPA Form 1320-6 (11-71)
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TABLE OF CONTENTS
Table of Contents i
List of Figures ii
Summary and Recommendations . , iii
Introduction 1
Background 1
Purpose of Report 1
I Operation Description 3
Site Description . 3
Operating Practices 3
II Sanitary Landfill Guidelines 11
III Operation Evaluation 13
Water Quality 13
Aesthetics 17
Gases 18
Other Guidelines Requi rements 21
Appendix 24
USEPA Sanitary Landfill Guidelines,
September 8, 1972 Draft
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List of Figures
1. Tulalip Landfill Location Map 4
r
2. Aerial Photo of Landfill Site 5
3. Barge Channel Side Wall 6
4. Leachate Discharge from Barge Channel Side Wall 6
5. Solid Waste Spillage in Barge Channel 8
6. Crane Construction Perimeter Dike Along Northern
Active Working Face - Looking West 9
7. Western Active Working Face - Looking South 9
8. Completed Fill Prior to Application of Final Cover 10
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SUMMARY AND RECOMMENDATIONS
By letter dated April 21, 1972, the Sol-id Waste Management Branch,
U.S. Environmental Protection Agency, Region X, requested from the
Bureau of Indian Affairs information concerning the operation of a
soli'd waste landfill on the Tulalip Indian Reservation. Correspondence
resulting from this inquiry led to two inspections of the operation,
and to meetings with the Tulalip Tribal Manager and officials of the
landfill operator, Seattle Disposal Company.
The Tulalip operation is a general-use landfill that receives
primarily non-residential solid wastes generated within the City of
Seattle. The Tulalip Tribe assumes responsiblity for the operation of
the landfill through a lease arrangement with Seattle Disposal Company.
Inspections conducted by Solid Waste Management Branch personnel
indicated a number of operating deficiencies that were brought to
the attention of the Tribe. This report was prepared to provide
more detailed assistance and recommendations directed towards elimin-
ating the operating deficiencies. The most serious deficiencies are
water pollution resulting from the operation, and decomposition gas
control at the site.
Water pollution is occurring from the deposition of decomposible
solid waste into ponded ground and surface waters, from direct solid
waste-surface water contact along the working face and in the barge
channel, and from leachate produced by water percolating through
the landfill. At a minimum, to be in compliance with federal standards,
this operation requires:
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IV
1. The elimination of solid waste-surface water contact in the
barge channel;
2. The containment, collection, and treatment of leachate along
the working face; and
3. An assessment of ground water movements and leachate collection
«
needs under and around the perimeter of the landfill. Additional collec-
tion facilities may be required to meet the federal guidelines.
These procedures will reduce, but may not eliminate, unnecessary
water pollution resulting from operations at the site. It may not be
possible to eliminate adverse impacts associated with past operations
without removing the completed fill. The natural topography and
hydrology of the site makes proper environmental controls extremely
difficult and potentially expensive. Proper control measures would
include the termination of general-use disposal activities at the
Tulalip site. That is, decomposible .materials should not be accepted
at the Tulalip site.
Decomposition gas problems may result from the lack of adequate
assessment and control measures both prior to and during the landfill
operation. Significant quantities of carbon dioxide and methane may be
expected, as may detectable quantities of the sulfides of hydrogen.
Carbon dioxide will dissolve calcium, magnesium, iron, and other
substances that are undesirable at high concentrations. Solutions of
these substances will also inhibit potential leachate treatment processes.
--' *"
Methane presents a fire and explosion hazard both during.and after
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disposal operations at the landfill. Hydrogen sulfide and associated
mercaptans present odor problems that may impact intended post-operative
>a
uses.
Even if general-use disposal operations are terminated, the following
recommendations should be adopted:
1. An assessment of gas control needs, as they relate to the
intended final use of the site, should be performed.
2. Steps should be taken to assure proper cover ventilation at
the site.
3. Buildings should be constructed on the site only with extreme
caution. If the existing maintenance building is to be retained, its
ventilation must be assured and monitored. Welding and cutting operations
should not be conducted within the building.
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INTRODUCTION
Background
Since the establishment of the EPA Regional office in July of 1971,
the Solid Waste Management Branch has been engaged in an effort to
identify and resolve the most significant solid waste problems within
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Region X. Emphasis has been placed upon identifying problems and
a course of action that will compliment and benefit the activities
of the affected state and local jurisdictions. In the process of this
research, interest became directed towards a landfill operation on
the-Tulalip Indian Reservation near Everett, Washington.
By letter dated April 21, 1972, the Solid Waste Management Branch
requested from the Bureau of Indian Affairs information concerning the
operation of this landfill. Correspondence resulting from this inquiry
led to two inspections of the operation, and to meetings with the Tulalip
Tribal Manager and officials of Seattle Disposal Company.
Purpose of Report
The Tulalip Indian Tribe is responsible for the operation of this
landfill through a lease with Seattle Disposal Company. The inspections
conducted by personnel from the Solid Waste Management Branch indicated
a number of operating deficiencies that were brought to the attention of
the Tribal Manager. The Tribal Manager expressed an interest in upgrading
the operation where practical, and in receiving reconomendations from
EPA directed towards this end.
-*". f*
The purpose of this report is to relay these recommendations to the
Tulalip Tribe. Its conclusions are based upon a water based inspection
that was conducted on June 9, 1972, and a site inspection that was
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conducted, in the presence of the Tribal Manager and officials of Seattle
Disposal Company, on July 13, 1972. The recomnendations are based upon
the proposed Federal Sanitary Landfill Guidelines, dated September 8,
1972. They are intended to indicate where deficiencies occur, and what
types of abatement actions are required to upgrade operations at the site.
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I OPERATION DESCRIPTION
Site Description
The landfill operation is being conducted on a portion of an island
in the Snohomish River estuary, as indicated in Figures 1 and 2. The
natural topography of the site is flat, characteristic of a brackish
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water marsh. Salt grasses dominate the natural flora, and the ground
water table was observed to be at the land surface. Fine grained soils
predominate.
Approximately one-quarter of the site has been covered with solid
waste. The portion of the site nearest to Interstate Highway 5 has
been completed, and the landfill operation is proceeding westward.
Currently, there is no vehicle land access to the site, but a road
is to be constructed in the near future.
Operating Practices
Seattle Disposal Company operates a barge transfer station at Pier
35, Seattle, that receives primarily non-residential solid wastes from
private collectors in the City of Seattle. Four or five barges per week,
carrying up to 1500 tons of solid wastes each, are delivered to the
Tulalip disposal site.
For barge unloading purposes, a channel has been dredged from Ebey
Slough into the interior of the island. The sides of the barge channel
have been constructed of a soil-solid waste mixture; the soils available
at the site are not suitable for this purpose, and suitable soils have
not been imported. As a result, there is direct contact betwe~en"solid
wastes and the waters flowing into and out of the barge channel. In
addition, leachate discharges into the channel have been observed.
These conditions are shown in Figures 3 and 4.
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j. j|C" WaterTank".
,-~^~ /^JjiMlJ.? Landfi
~^>-/ Site Vboeation
-O'" "><:-c<.* ^-iT^^;. / ^^^$W%IQ]HS&-^~-~-
, ''::^>~--^^^^^^-£^..'-*-~;3\ .« ~Hfcj?r::" .-rocK«-/
' ":.:,-;-;:^.. .. - -t-----::"-?:-^::' ---*- ^^^: i i ; ^
Smith ^ILs I a n
Snohomish, River
. Prestoh'Point."; ___--,
Tulalip Landfill
Location Map
-/ '. '" ' AMEI
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Figure 2
Aerial Photo of Landfill
Site
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Figure 3
Barge Channel Side Wall
Figure 4
Leachate Discharge From Barge
Channel Side Wall
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Solid waste is lifted from the barge to the landfill surface by a
crane equipped with a modified clamshell bucket. From there, a crawler
tractor equipped with a large landfill blade pushes the waste to the
active disposal area. During unloading operations, a significant quantity
of waste falls into the barge channel, as shown in Figure 5. Nets
*
are used to inhibit the passage of this solid waste into Ebey Slough,
and the barge channel is periodically skinned with a large screen
that is attached to a crane. During the July 13 investigation, the
unloading area was equipped with a tarp to catch spillage below the
clamshell bucket. This tarp was not observed during the June 9 investi-
gation.
The completed perimeter of the landfill is surrounded by a dike
constructed of soils dredged at the site. Cover and dike material is
excavated from the site, and solid waste is deposited into water that
collects in the fill areas. A long, active working face is exposed
to ground and surface waters. Cells are not constructed to provide
for the collection and treatment of the resulting leachate. Figures
6 and 7 illustrate these conditions.
The soils dredged from the site are not workable under all
conditions, so no daily cover is applied. Rather, soil is mixed with
solid waste for daily application, and a final cover is applied at
a later date. The soil-solid waste mixture is deposited and compacted
in horizontal lifts. Prior to the application of the final cover,
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solid waste is visible throughout the fill area, as illustrated in
Figure 8.
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8
Figure 5
Solid Haste Spillage in Barge Channel
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Figure 6
Crane Constructing Perimeter Dike
Along Northern Active Working Face
Looking West
Figure 7
Western Active Working Face
Looking South
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Figure 8
Completed Fill Prior to Application
of Final Cover
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II SANITARY LANDFILL GUIDELINES
As charged by Section 209 of the Solid Waste Disposal Act, as amended,
the Office of Solid Waste Management Programs', U.S. Environmental Protection
Agency, is preparing guidelines for the operation of solid waste disposal
systems. A draft of the Sanitary Landfill Guidelines has been completed
t
and is in the review process. Although the latest draft available to the
Solid Waste Management Branch, U.S. EPA, Region X is not final and will be
changed, it is completed to a sufficient degree to justify its applica-
tion in an evaluation of the Tulalip Landfill operation. The Tribe is
also referred to References 1 through 3 for Sanitary Landfill information.
The purpose of the Guidelines is to provide for sanitary landfill
operations that will have minimum impact upon the environment and the
public health. The Guidelines do not establish new standards, but set
forth requirements and recommended operating procedures to insure that
the design, construction, and operation of sanitary landfills meet accept-
able health and environmental standards.
The Requirements sections of the Guidelines delineate minimum levels
of performance required at general-use sanitary landfills. The mix and
composition of the wastes accepted at the Tulalip site place it within
the general-use category, so the Requirements sections should be applied
to its operation.
Each Requirement is supported with recommended operating procedures
that are intended to emphasize specific items of concern. Owners and
operators of sanitary landfills should employ the most efficient engineer-
ing methods available to satisfy the Requirements. The Operating Procedures
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represent such methods and techniques, based on current knowledge, for
meeting the Requirements. If techniques other than those specified are
used, the operator should demonstrate to the Tribe that such techniques
will meet the Requirements.
The Guidelines also encompass considerations that relate to the safety
#
of the on-site personnel, and to the intended final use of the site. In-
all cases, the final site use should guide the landfill operating plans.
Important provisions include final grade, compaction, and decomposition
gas control.
When adopted, the Guidelines will apply to both existing and new
Federal Agency installations. Thus, the Requirements sections are written
to be applied as performance standards upon federal installations. The
Guidelines are also recommended to other agencies that are responsible
for solid waste disposal operations for use in their activities. The
Tulalip Tribe, which falls within this latter category, should evaluate
and consider the Guidelines for adoption and application to disposal
operations that are conducted on Reservation lands.
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III OPERATION EVALUATION
The various impacts addressed by the Guidelines include impacts upon
air and water quality, aesthetics, the public health and safety. The
purpose of this section is to assess the operation of the Tulalip Landfill
as compared to the Guidelines. A copy of the September 8, 1972 draft is
t
appended to this report for reference.
Since the Requirements are written as performance standards for
federal installations, all are not specifically applicable to the Tulalip
operation. Those specifying environmental and operating performance levels
are. applicable for assessment purposes, however. These Requirements and
their recommended Operating Procedures will form the basis of this
evaluation.
Water Quality
The Water Quality Requirement states that,
The location, design, and. operation of the sanitary
landfill shall minimize environmental hazards and
shall conform to applicable ground and surface water
quality standards. Applicable standards are existing
Federal, State, or local standards which are legally
enforceable.
The intent of this section is to eliminate discharges into ground and
surface waters from sanitary landfills. The recommended Operating
Procedures are written to eliminate direct contact with potential receiving
waters, and to minimize the percolation of water througji the landfill.
The alternative to these measures is the construction of potentially
expensive leachate collection and treatment systems.
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The first Operating Procedure outlines nine tasks that should be
performed in evaluations of proposed landfill sites. Proper performance
of these tasks will provide for the elimination of poor sites, and will
generate information that will permit effective water quality control
practices at sites that are chosen for use.
»
The nine tasks include an evaluation of the geology and hydrology
of the landfill area, an assessment of potential leachate-water quality
interrelationships, the specification of a proposed water quality sampling
program, and a delineation of potential leachate control systems. The
information generated from the performance of these tasks would not only
be useful in a water quality impact assessment, but would also contribute
information valuable for post-utilization purposes. If operations at the
Tulalip site are to continue, the operator should prepare such an assess-
ment for the Tribe.
The most common water quality hazard that results from solid waste
landfills is the production of leachates that arise from contact between
the solid waste and external waters passing through or adjacent to the
site. The second and fifth Operating Procedures recommend practices to
minimize this contact. In addition, the fourth Operating Procedure gives
implicit recognition to this leachate generation mechanism. Although it
is not necessary to elevate the bottom of a landfill to provide for flood
protection, it is often times necessary to elevate the landfill to provide
for ground water protection. Since flood plains are usually associated
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with high ground water tables, landfills located in flood plains present
greater environmental hazards than those located in non-flood plain areas.
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Leaching is a visible problem at the Tulalip site. Solid wastes
are deposited directly into the ground water, there is direct solid waste-
surface water contact along the working face and in the barge channel, and
the wide, flat landfill surface provides for the percolation of incident
precipitation into the landfill.
t-
The second Operating Procedure recommends the diversion of surface
waters around and over the landfill. At the Tulalip site, diversion
trenches are not necessary because the surface of the landfill is above
that of the surrounding land area. However, the landfill should be
graded to permit the runoff of incident precipitation. Even though the
final cover is constructed out of a tight soil, cracks will develop that
permit percolation into the landfill. Such cracks were observed during
the July 13 inspection. The final cover should be constructed with an
adequate slope and drainage facilities provided to permit the rapid
runoff of incident precipitation. .
The intent of the fifth Operating Procedure is to eliminate leachate
generation resulting from direct contact between solid waste and ponded
ground waters. This provision should be expanded to include direct
contact between solid waste and adjacent surface waters. These two
mechanisms present the most severe environmental hazards at the Tulalip
site.
In the barge channel, spillage, as well as direct contact, creates
water quality degradation. During both inspections, the barge channel
J r
waters were visibly polluted, being more colored, and containing more
floating scum and debris than the waters of Ebey Slough. Because of
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tidal action, the barge channel waters pass into Ebey Slough in a diluted
state.
These conditions merit irnnediate abatement. A water tight barrier
should be constructed between the landfill and Ebey Slough, and unloading
practices should be upgraded to eliminate spillage.
' Along the active working face, direct contact between ponded ground
and surface waters and solid waste was observed. Although the tight
soils at the site will inhibit the movement of the resulting leachate
through the ground, surface runoff of the leachate is not inhibited. It
can be seen, from Figure 2, that such surface runoff is a potentially
severe hazard.
The third Operating Procedure recommends the construction of leachate
collection and treatment systems where necessary to protect ground and
surface waters. Such abatement measures are definitely required for sur-
face waters at the Tulalip site, and may be required for ground water.
Conditions at the site make the construction and operation of proper control
measures very difficult, however. At a minimum, cells should be constructed
around the active working face, and treatment should be provided for water
that accumulates in a cell during deposition.
If the assessment recommended as the first Operating Procedure had
been performed prior to the initiation of operations at the Tulalip site,
the difficulties associated with operating the site as a general-use
landfill would have been more apparent. Given the water quality considera-
tions presented above, the Tulalip Tribe should seriously consider the
termination of general-use disposal activities at this site. If implemented,
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the recommended abatement measures would reduce, but would not eliminate,
adverse water quality impacts resulting from the landfill operation.
More effective water pollution abatement would result from moving the
disposal of decomposable solid wastes to an alternative site. Even if
operations are terminated, there will be a long term environmental impact
because of past operating procedures.
Aesthetics
The Guidelines require a sanitary landfill to be operated in an
aesthetically acceptable manner. The purpose of this provision, and the
supporting Operating Procedures, is to minimize adverse visual impacts
upon adjacent land and water resource uses. Since recreation is an
important use of the navigable waters adjacent to the Tulalip Landfill,
aesthetic considerations should be incorporated into its operation.
Although aesthetic conditions at the Tulalip site are poor, the fact
that there is no public access to the site reduces aesthetic impacts. In
addition, the surface operations are not readily visible from the adjacent
waterways.
The first two Operating Procedures are directed at the containment
of blowing litter to the inmediate vicinity of the working face. No
blowing litter controls are practiced at the Tulalip site. The operator
did indicate that blowing litter was a problem on windy days. Tarps and
portable litter fences should be used to control litter around the barge
unloading operation, and in the area of active deposition. _.- ,.
v
The third Operating Procedure recommends immediate cover for certain
wastes, and cover at the end of each operating day. Wastes that require
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immediate cover include dead animal carcasses, dewatered sludges, and dry
incinerator and air pollution control residues. None of these wastes are
delivered to the Tulalip site. Aesthetic problems do result from the
absence of daily cover operations, however. The soil-solid waste mixture
contains large amounts of visible solid waste prior to the application of
*
final cover.
In addition to presenting a major water quality problem, operations
in the barge unloading channel also present a major aesthetics problem.
Floating refuse and the walls constructed of refuse are visible to the
public from Ebey Slough. The installation of litter control fences,
and the construction of a water tight barrier, as discussed above,
would alleviate these adverse aesthetic conditions.
Gases
The Guidelines require that,
Decomposition gases generated within the sanitary
landfill shall be controlled on-site.
The monitoring and control of decomposition gases is important in part
because of the water quality problems that can result from the generation
of soluble gases, and because methane production can present serious
fire and explosion hazards. Since post-operative uses are intended
for the Tulalip Landfill, the latter item is of extreme importance.
Methane accumulations should also be of concern in buildings constructed
for operation and maintenance purposes during the life of the landfill.
.-" r
Data that have been developed with respect to gas production in
sanitary landfills have not been related to solid waste composition.
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Since the composition of the solid waste at the Tulalip Landfill varies
somewhat from that found in most general-use landfills, available data
t
are not necessarily applicable to the Tulalip" operation. However, the
paper and restaurant wastes accepted are subject to anaerobic decomposition,
so gas production may be expected.
»
Based upon the limited amount of data available in the literature,
and upon the fact that brackish water infiltration does occur at the
Tulalip site, the ultimate gas composition is expected to be characterized
by the presence of carbon dioxide (COz), methane (CH4), and hydrogen
sulfide (H2S) and associated mercaptans (organic sulfide compounds).
The carbon dioxide produced passes into solution, and can create
water quality problems by dissolving calcium, magnesium, iron, and other
substances which are undesirable at high concentrations. Iron oxide is
visible along the walls of the barge channel. Leachate containing these
materials will also migrate through the fill to the working face. High
concentrations of these materials will also have an adverse impact upon
potential leachate treatment mechanisms.
Even though the sulfide compounds will comprise a very small
portion of the decomposition gas volume (less than one percent), they
may present continuing odor problems. Hydrogen sulfide exhibits a
"rotten-egg" smell that is detectable at concentrations of less than
one percent. The mercaptans present odor problems at concentrations
of less than one part per billion (10,000,000 parts per billion equal
_r* *
one percent). Usually, problem concentrations of the su-lfide gases
are not expected at solid waste landfills. In this case, however,
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brackish water infiltration will supply sulfates that will be utilized
in the production of sulfide gases.
The methane gas may present explosion and fire hazards both during
and after the operation of the landfill. The landfill surface is broad,
and ,the final cover and perimeter dikes are impermeable except for
cracks that may develop as the final cover dries. Thus, gas pockets
may form within the fill, resulting in explosion and fire hazards. In
a similar situation, fire problems have been experienced at the University
of Washington's Montlake Landfill. Small gas bubbles were observed in
puddles on the completed portions of the Tulalip Landfill during the
July 13 inspection.
If buildings are constructed for post-operative uses, or for operation
and maintenance purposes during the landfill operation, gas collection
and venting become very important. In the past, methane gas explosions
have caused injury and death at completed landfills. Enclosed structures
also present explosion hazards at operating landfills. If proper
gas control is not practiced during the operation of the landfill,
possible post-operative uses may be restricted.
The Operating Procedures recommend an assessment of decomposition
gas control needs, and the prevention of lateral gas migration. The
assessment is needed to relate required control measures to operating
safety needs, and to intended post-operative uses. Since an assessment
has not been performed for the Tulalip Landfill, gas generationrrates,
composition, and potential migration paths have not been defined.
The operator should be required to perform such an assessment for
the Tulalip Tribe.
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Other Guidelines Requirements
The site inspections performed by the Solid Waste Management Branch
were directed at the adverse, environmental impacts resulting from the
Tulalip Landfill operation. EPA's immediate concern in this matter
relates to the elimination of these impacts. Several other Guidelines
Requirements should also be of interest to the Tribe. Since the purpose
of this report is to inform the Tribe of the environmental aspects of
solid waste management as well as to provide some technical assistance
to the Tribe in the operation of sanitary landfills, these requirements
will be noted below.
The intent of the Safety Requirement is self explanatory. The Tribe
should examine the Operating Procedures to insure that the operating
personnel are protected. Special attention should be directed towards
Procedure 2.6.I.G. The potential explosion and fire hazards have been
discussed above. Ventilation of the maintenance shed must be assured,
and ventilation trenches should be provided in the final cover.
Proper cover application is important for a number of reasons.
The Cover Application Requirement is supported by recommended Operating
Procedures that will satisfy most cover needs. The type of soil used
for cover, grading practices, and the soil's ability to support vegeta-
tive cover will all impact post-operative uses of the site.
The marshy nature of the Tulalip site makes the exclusion of
hazardous and special wastes vitally important. In addition to^those
^
wastes listed in the Hazardous and Special Wastes Requirement, all dead
animals, sludges, ashes, animal wastes, and pesticide containers should
be excluded.
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The Inspections Requirement is written for agencies that are subject
to the legal authority of the Environmental Protection Agency. The Tribe
should examine the Operating Procedures, and provide for a formal
inspection program to ensure that proper operating practices are followed.
This is necessary for environmental, public health, and safety reasons,
as well as to ensure that the intended final site use can be attained.
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REFERENCES
1. Brunner, Dirk R. and D. J. Keller, Sanitary Landfill Design and
Operation, U.S. Government Printing Office, Washington, D.C., 1972.
2. Sorg, T. J. and H. L. Hickman, Jr., Sanitary Landfill Facts,
Public Health Service Publication No. 1792, U. S. Government
Printing Office, Washington, D.C., 2nd. ed., 1970.
3. Recommended Standards for Sanitary Landfill Design, Construction
and Evaluation and Model Sanitary Landfill Operation Agreement,
prepared by National Solid Waste Management Association and the
Federal Solid Waste Management Program, U. S. Government Printing
Office, Washington, D.C., 1971.
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APPENDIX
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DRAFT
SANITARY LANDFILL GUIDELINES
Prepared By
Office of Solid Waste Management Programs
U. S» ENVIRONMENTAL PROTECTION AGENCY
Cincinnati, Ohio
September 8, 1972
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CONTESTS
1. INTRODUCTION ....... 1
1.1.0. General 1
1.2.0. Definitions 2
2. REQUIREMENTS '. 6
2.0.0. General 6
2.1.0. Water Quality 6
' 2.2.0. Air Quality. . * 8
2.3..0. Aesthetics .'. 8
2.4.0. Gases 9
2.5.0. Vectors 9
2.6.0. Safety ....;.... *. . 10
2.7.0. Site Selection 11
2.f>.0. Cover Application 13
2.9.0. Solid Wastes Accepted 14
2.10.0. Hazardous and Special Wastes 14
2,11.0. Equipment 1?
2.12.0. Inspections ' 17
3. RECOMMENDED BIBLIOGRAPHY ...'....'.... 20
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1. INTRODUCTION
1.1.0. GENERAL
Sanitary landfilling is the most widely applied and only
environmentally acceptable land solid waste disposal method available
/.
today. A sanitary landfill is an engineered land disposal facility
at wfyich solid waste is spread in thin layers, compacted to the
smallest practical volume, and covered with soil each operating day
in a manner which minimizes'environmental hazards.
The prescribed guidelines are intended to provide for operations
that will have minimum impact on the environment, and they apply to
both existing and new Federal agency installations (Sec. 209 and Sec. 211,
PL 91-512). The guidelines do not establish new standards, but set
forth requirements to insure that the design, construction, and operation
of sanitary landfills meet the health and environmental standards for
the area in which they are located.
The Requirements section of the guidelines delineate minimum
levels of performance required of general-use sanitary landfills.
It is possible to construct a sanitary landfill on nearly all topographies ,
although some land formations present unique problems. While it is
impossible to delineate all the techniques required at every potential
site, the Operating Procedures are intended to emphasize specific items
of concern. Owners and operators of sanitary landfills are expected
to employ the best technology available to satisfy the Requirements.
-," f~
The Operating Procedures represent techniques based on..current knowledge
for meeting the Requirements. If techniques other than those specified
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2
are used, it is the obligation of the proposed facility's owner and
operator to demonstrate to the responsible agency in advance that such
techniques will ensure meeting the Requirements. /« .
These guidelines are also recommended to State, interstate,
regional, and local government agencies for use in their activites.
1.2.0. DEFINITIONS (as used in these guidelines)
Cell: Compacted solid wastes that are enclosed by undisturbed
soil and/or cover material.
Cover Material; Soil that is used to cover compacted solid
waste in a sanitary landfill.
Daily Cover; Cover material that is spread and compacted on
the top and side slopes of compacted solid waste at least at
the end of each operating day in order to control vectors,
aesthetics, fire and moisture.
Final Cover; Cover material vjhich serves the same functions
as daily cover, but in addition is permanently exposed on the
surface, must support vegetation, and must resist weathering
for a longer period of time.
Free Moisture; Liquid which will drain freely from solid waste.
Croundwater; That water below ground whose pressure is equal
to or greater than atmqspheric pressure.
Hazardous Wastes; Materials or combinations of materials
-i. f
vhich require special management techniques because of their
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3.
acute and/or chronic effects on the health and welfare of the
public (or those individuals who handle them).
/«
Health Care Facilities: Institutions and offices including
hospitals, nursing homes, clinics, etc., where medical services
are regularly rendered.
Infectious Waste; Laboratory wastes including pathological
specimens (i.e., all tissues, specimens of blood elements,
excreta, and secretions obtained from patients or laboratory
animals) and disposable fomites (any substance which may
, #
harbor or transmit pathogenic organisms) attendant the'reto.
Also, surgical operating room pathologic specimens and
disposable foraites attendant thereto and similar disposable
< materials from out-patient areas and emergency rooms. Also,
equipment, instruments, utensils, and fomites of a disposable
nature from the rooms of patients who are suspected to have
or have been diagnosed as having a communicable disease and
must, therefore, be isolated, as required by public health
agencies.
Leachate; Liquid that has percolated through solid waste or
other medium and contains dissolved or suspended materials
from it.
Open Burning; Uncontrolled burning of wastes in the .open or
in an open dump.
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A
Open Dump; A land site at which solid waste is disposed of
in a manner which does not protect the environment and is
exposed to the elements, vectors, and scavengers.
v-
Plans; Reports and drawings prepared to describe the sanitary
landfill site and proposed operation which must be submitted
to regulatory authorities for their consideration. Preliminary
and final plans may be prepared; the final plans expanding on
items contained within the preliminary plans.
Runoff; The portion of precipitation which drains from an
area as surface flow.
Sanitary Landfill; A disposal facility employing an engineered
method of disposing of solid wastes on land in a manner which
minimizes environmental hazards by spreading the solid wastes
in thin layers, compacting the solid wastes to the smallest
practical volume, and applying cover material at the end of
each working day.
Scavenging: Uncontrolled removal of so'.id waste materials.
j>ludge; A semiliquid sediment resulting from industrial,
institutional, or commercial processes.
Solid Waste; Garbage, refuse, and other discarded solid
materials, resulting from industrial, commercial, and agri-
cultural operations, and from community activities, excluding
solids or dissolved material in domestic sewage or other
~'. **
significant pollutants in water resources, such as silt,
dissolved or suspended solids in industrial waste water
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effluents, dissolved materials in irrigation return flows or
other common water pollutants.
Vector: A living insect or other arthropod.or animal (not
human) which can carry infectious diseases from one person or
animal to another.
Water Table: The upper water level of a body of groundwater.
Working Face; That portion of the sanitary landfill where
waste is discharged and is spread and compacted prior to the
placement of cover material.
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2. REQUIREMENTS
2.0.0. GENERAL
2.0.1. Federal executive agencies shall conform to applicable Federal,
State, interstate, regional, and local standards where they are more'
.stringent than these Requirements.
2.0.2". Federal agencies shall comply with the applicable sections of
the National Environmental Policy Act of 1969.
2.0.3. Solid waste generated at Federal facilities and solid waste
disposed of at Federal facilities shall not be disposed of by open
burning or open dumping. .. :
*
2.0.4. A plan.for the design and operation of the sanitary landfill
N
shall be developed by a professional engineer who has demonstrated his
qualifications in previous similar design. The plan shall be submitted
to the responsible agency for review and approval.
2.1.0. WATER QUALITY: The location, design, and operation of the
sanitary landfill shall minimize environmental hazards and shall
conform to applicable ground and surface water quality standards.
Applicable standards are existing Federal, State, or local standards
which are legally enforceable.
1 2.1.1. Operating Procedures:
A. The plans shall include:
1. Current and projected use of water resources in the
potential zone of influence of the sanitary landfill;
_/ r-
2. Groundwater elevation and movement;
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3. Potential interrelationship of the sanitary landfill,
local aquifers, and surface waters based on historical
/»
records or other sources of information;
4. Initial quality of water resources in the potential
zone of influence of the sanitary landfill;
5. Proposed location of observation wells, sampling
stations, and testing program planned, when appropriate;
6. Description of soil and geologic material to a depth
of at least 50 feet below the bottom of the proposed fill;
7. Provision for surface water runoff control;
8. Proposed separation between the lowest portion of
the sanitary landfill and the historical high water
table elevation;
9. Potential of leachate generation and proposed control
systems for the protection of ground and surface waters,
B. Surface water courses and runoff shall be diverted from
the sanitary landfill by trenches and proper grading. The
sanitary landfill shall be constructed and cover material
graded so as to promote rapid surface water runoff without
excessive erosion. Regrading shall be done as required during
construction and after completion to avoid ponding of precip-
\
itation and to maintain cover integrity. -: t-
v
C. Leachate collection and treatment systems shall be used
where necessary to protect ground and surface waters.
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D. If a sanitary landfill is located in a flood plain, the
bottom of the sanitary landfill shall not be lower than the
r,
high water mark of the 50-year design flood.
E. In no case shall solid waste be allowed to contact ground
«-
water.
2.2.0. AIR QUALITY: The design and operation of the sanitary landfill
shall minimize environmental hazards and shall conform to applicable
ambient air quality standards and source control regulations.
2.2.1. Operating Procedures:
A. Open burning of solid wastes shall be prohibited.-
.B. Plans shall include an effective dust control program.
2.3.0. AESTHETICS:' The sanitary landfill s'.iall at all times be
operated in an aesthetically acceptable manner.
2.3.1. Operating Procedures: . .
A. Plans shall include an effective litter control program.
B. Portable litter fences or other devices shall be used in
the immediate vicinity, of the workir.g face and other locations,
as appropriate, to control blowing litter.
C. Certain wastes shall be .covered immediately and the
remainder by the end of each operating day. Refer to
Requirements 2.8.O., Z.8.I., and 2.10.1. E, G, and H.
D. Vegetation shall be cleared only as necessary. Natural
windbreaks, such as green belts, shall be maintained where
they will improve the appearance and operation of the
sanitary landfill.
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2.4.0. GASES: Decomposition gases generated within the sanitary
landfill shall be controlled on-sitc. _ * ..
2.4.1. Operating Procedures: ,...
A. Plans shall assess the need for gas control and indicate
the location and design of any vents, barriers, or other
control measures to be provided.
B. Decomposition gases shall not be allowed to migrate
laterally from the sanitary landfill. They shall be vented
into the atmosphere directly through the cover material,
cut-off trenches, or forced ventilation systems in such a
way that they do not become concentrated in explosive
quantities. Information on the limits of inflammability
of gase.s is available in such references as the Handbook of
Chemistry and Physics (44th.ed. Cleveland, Chemical Rubber
Publishing Co., 1962, 3604 p.).
2.5.0. VECTORS: Conditions shall be maintained that are unfavor-
able for the harboring, feeding, and breeding of insects, birds,
and rodents.
.f2.5.1. Operating Procedures:
A. Plans shall include contingency programs for vector control,
and the operating authority shall remain prepared at all times
to implement these procedures.
_-" r
B. All solid waste shall be covered by. the end of each
operating day. Refer to Requirements 2.8.0. and 2.8.1.
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' 2.6.0. SAFETY: The sanitary landfill shall be designed, operated,
and maintained in such a manner as to protect the Health and safety
of personnel associated with the operation. "The Occupational Safety
*\
and Health Act of 1970 (PL 91-596) shall apply, and the design and
operation shall comply with applicable provisions of the Act.
r
2.6.1. Operating Procedures:
A. An operating manual describing the various tasks that
must be performed during a typical shift, as well as safety
precautions and procedures, shall be available to employees
for reference. Employees shall be instructed as to these
t
tasks and safety precautions and procedures.
B. Safety devices, including but not limited to, roll bars
and automatic fire extinguishers shall be provided on all
rolling equipment to protect the health and safety of
' operators.
C. Provision shall be made to extinguish any fires in
wastes being delivered to the site or which occur at the
working face or within equipment or personnel facilities.
Communications equipment shall be available for emergency
situations.
D. Scavenging shall be prohibited to avoid injury and to
j-revent interference with operations.
K. Access to the site shall be controlled and shall ,be- by
»
established roadways only. The sanitary landfill shall be
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accessible only when operating personnel are on duty. Large
containers may be placed outside the site entrance so that
users can deposit waste after hours; they and areas around
them shall be maintained in a sanitary and litter-free
condition.
F. Traffic signs shall.be provided to promote an orderly
traffic pattern to and from the discharge area, and if
necessary, to restrict access to hazardous areas or to
maintain efficient operating conditions. Drivers of
manually discharged vehicles shall not hinder operation of
mechanically discharged vehicles. No vehicle shall be left
unattended at the working face or'along traffic routes.
G. Decomposition gases shall not be allowed to concentrate
in a manner that will present an explosion hazard.
2,7.0. SITE SELECTION: Site selection and utilization shall comply
with local land-use planning and zoning regulations, as well as with
Requirement 2.0.1.
2.7.1. Operating Procedures:
A. Site development plans shall be prepared by a professional
engineer and shall include:
1. Initial and final topographies at contour intervals
of two feet or less;
-' *
2. Land use and zoning within I/A mile of>the site,
including location of all residences, buildings, wells,
water courses, arroyos, rock outcroppings, roads, and
soil or rock borings. All airports within five miles of
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12
the site shall be identified to aid in assessment of
the potential hazard of birds to aircraft.
B. Plans shall describe the projected use.-of the completed
sanitary landfill site. In addition to maintenance programs
, and provisions for monitoring and controlling decomposition
gas and leachate, the project plans shall include the following
specific ultimate use criteria; . ,
1. Cultivated Area. The major concern if the completed
site is to be cultivated is that the integrity of the
final cover not be disturbed by agricultural cultivation
r
activities. In this regard, a sufficient depth of cover
material to allow cultivation and to support vegetation
shall be applied in addition.to the minimum specified
in Requirement 2.8.1.
2. Structures: If major structures are to built on
or near a completed sanitary landfill, a professional
engineer shall design and construct then. The use of
battered pilings or preplanned islands of well-compacted
or undisturbed soil is strongly recommended. Any
materials to be imbedded in the landfill shall be
corrosion resistant. Pavements and utility lines shall
be able to withstand differential settlement conditions.
* ./* r-
Decoinposition gas controls shall be included in the
project plans and specifications.
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C.- The site shall comply with appropriate Federal, State,
or local health, environmental, planning, and solid waste
management Agency requirements.
D. Site development shall conform to any existing State,
regional, or local solid waste management plans.
E. The hydrogeology of the site shall be evaluated
in order to design the site in a manner to protect
ground water resources. Unacceptable hydrogeologic
conditions may be altered to render the site acceptable,
but all alterations must be detailed in the plans.
Precipitation, evapotrans'piration, and other
climatological conditions shall be considered in \he
site selection.
F. The site shall be accessible by permanent roads
leading from the public road system; temporary roads may
be provided as needed to deliver wastes to the working
face. All roads to the working .face shall be passable
regardless of weather.
G. The site shall be so located and operated that it
does not attract birds, which could be a hazard to low-
flying aircraft.
2.8.0. COVER APPLICATION: A cover of soil shall be applied and compacted
over all exposed solid waste by the end of each operating day. A final
- f-
cover of soil shall be applied and compacted as each ar,ea is "completed.
2.8.1. Operating Procedures:
A. Plans shall specify:
1. Cover material sources and soil classifications
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14
(Unified Soil Classification System or U. S. Department of
Agriculture classification system); .
2. Surface grades and side slopes needed to promote
maximum runoff, without excessive erosion, to minimize
infiltration;
3. Procedures to promote vegetative growth to combat
erosion and improve appearance, of areas as they are
completed or are to remain unusued for over nine months;
4. Procedures to maintain cover integrity; e.g.,
regrading and recovering.
B. Daily cover shall be applied regardless to weather;
therefore, sources of cover material shall be accessible
regardless of weather.
C. The thickness of the compacted daily cover shall not
be less than six inches.
D. The thickness of the compacted final cover shall not '
be less than two feet.
2.9.0. SOLID WASTES ACCEPTED: Except for the materials mentioned
in Requirement 2.10.0., all other solid wastes are acceptable
without special handling.
2.9.1. Operating Procedures: Routine sanitary landfill techniques of
spreading, compacting,' and covering with appropriate material by the
end of each working day shall be utilized to dispose of such wastes.
-'" *
2.10.0. HAZARDOUS AND SPECIAL WASTES: Under.no circumstances shall
any of the following be accepted for disposal: infectious institu-
tional wastes, bulk liquids, semiliquids, sludges containing free
moisture, highly flammable or volatile substances, unexpended
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15
pesticide containers, pesticides, raw animal manure, septic tank
pumpings, raw sewage sludge, radioactive materials, and explosives.
Certain industrial process wastes may also be prohibited. Some of
/.
the wastes that are acceptable may require special handling.
2.10.1. Operating Procedures:
* A. In consultation with appropriate environmental protection
agencies, the designer and operator shall determine what
specific wastes fall under the unacceptable categories listed
above and shall name them in the operating plan. They shall
also decide what, if any, industrial process wastes must be
*
prohibited.
3. Regular users of the facility shall be given a list of
the prohibited materials, and it shall also be displayed
prominently at the site entrance. If a regular user persists
in making unacceptable deliveries, he shall be barred from
the installation.
C. The operating plan shall specify the procedures and
precautions to be taken if unacceptable wastes are delivered
to the facility or are improperly left there.
D. Certain bulky wastes, such as automobile bodies, furniture,
and appliances shall be crushed on solid ground and then pushed
onto the working face near the bottom of the cell or into a
. separate disposal area. Other bulky items, such as demo-
^\ r-
lition and construction debris, tree stumps, and large timbers,
shall be pushed onto the working face near the bottom of the
cell or into a separate disposal area; they need not be
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compacted. The special areas used only for bulky wastes
shall be identified on the final plan .of the completed site.
E. Procedures for disposing of dead animals have been
established by law in most States, and the-'operating plan
shall comply accordingly. In most cases, small carcasses
shall be placed with residential and commercial wastes and
covered immediately. Very large carcasses are usually
dismembered for easier transport. In the absence of appli-
cable State laws, they shall be placed in a pit and covered
with two feet of compacted soil. The soil shall be regraded
periodically to keep water frcm ponding as a result of -
settlem2nt, which could be appreciable. N
F. The criteria used for determining whether an industrial
process waste is acceptable include the hydrogeology of the
site, the chemical and biological stability of 'the waste,
and the safety of personnel.
D. Dewatered sludges from water treatment plants and
digested and dewatered sludges from waste water treatment
facilities shall be placed on the working face with other
' wastes and shall be covered iromediately with soil or other
solid wastes. The quantities accepted shall be determined
by operational problems encountered at the working face.
H. Incinerator and air pollution control residues shall
. ~~. f~
be incorporated into the working face and shall" be covered
immediately if they are very dry.
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I, Expended pesticide containers shall be crushed and
disposed of with other solid wastes. i
2.11.0. EQUIPMENT: At a minimum, the equipment available shall
be capable of spreading and compacting the solid waste and the
cover' material required for the most severe combination of waste
delivery and weather conditions expected during any one operating
day.
2.11.1. Operating Procedures:
A. Equipment shall spread the solid waste accepted in
layers.no more than two feet thick, compact the waste, and
place, spread, and compact the cover material. These
operations shall be on a working face slope maintained
at 3:1 or steeper.
B. Equipment manuals, catalogs, and spare parts lists
shall be available at the equipment maintenance facility.
C. Arrangements shall be made and indicated in the plans
whereby substitute equipment will be available to provide
uninterrupted service during routine maintenance periods
or equipment breakdowns.
2.12.0. INSPECTIONS: Responsible environmental protection agencies
/ .
shall establish and maintain inspection and correction programs for
sanitary landfills for which they are responsible.
~~. *~
2.12.1. Operating Procedures: . . -*
A* During the first year of operation inspections shall
«
be conducted at least every 30 days; after a year, they
* shall generally be conducted semiannually.
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*
B. The inspecting agency shall define sample collection
and analysis requirements appropriate to the site.
C. The agency's internal inspection reports shall contain
at least the following information: "*
1. Date of inspection, site identification and
location, name of inspector and title, types of
industries and an estimate of population served.
2. An identification and brief discussion of any
i
operational problems, complaints, or difficulties.
3. Adequacy of operation and performance with regard
to applicable requirements and recommendations for
corrective actions. ' N
A. Qualitative and/or quantitative evaluation of
the aesthetic and environmental impact of the sanitary
landfill with regard to the effectiveness of:
(a) waste disposal in the areas served;
(b) gas and leachate control including;
- results of leachate sampling conducted on
the site perimeter,
- results of gas sampling and analyses,
- results of ground and surface water quality
analyses upstream and downstream of the site;
(c) efforts to control vectors, birds, or other
pests;
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19
(d) air quality control and elimination of open
burning practices;
(e) noise control; ^
(f) cover placement; '**
(g) dust and litter control.
D. Following each inspection an evaluation of the operation's
suitability with respect to these Requirements and applicable
standards shall be prepared by the agency's inspecting
authority.
E. The completed sanitary landfill shall be inspected by
the governmental agency responsible, for regulating its
proper operation. Following final acceptance, a detailed
description, including a plat, shall be recorded with the
county's-land recording authority. The description shall
include general types and location of wastes, depth of
fill, and other information of interest to potential
land owners.
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3. RECOMMENDED BIBLIOGRAPHY
(1) Banta, J., et al. Sanitary Landfill. American Society
of Civil Engineers, Manual of Engineering Practices, No. 39.
1959.
'(2) Black, C. A., D. D. Evans, J. L. White, L. E. Ensminger,
F. E. Clark, and R. C. Dinauer, eds. Methods of soil analysis.
Part 1Physical and mineralogical properties, including
statistics of measurement and sampling. Madison, Wise., American
Society of Agronomy, Inc., 1965. 77.0 p.
(3) Black, R. J. Sanitary'landfill... an answer to a community
problem; a route to a community asset. Public Health Service
Publication No. 1012. Washington, U. S. Government Printing
Office, 1971. 8 p.
(4) Bjornson, B. F., H. D. Pratt, and K. S. Littig. Control
of domestic rats and mice. Public Healt.h Service Publication
No. 563. Washington, U. S. Government Printing Office, 1956.
Revised 1960, 1968. Reprinted, Bureau of Solid Waste Management,
1970. Al p.
(5) Brashares, W. C., and R. M. Golden. Occupational Safety
and Health Act. Special Bulletin. Washington, National Solid
Wastes Management Association, 1972. 17 p.
(6) Brunner, D. R., S. J. Hubbard, D. J. Keller, and J. L. Newton,
. -"! *
Closing open dumps. Washington, U. S. Government Printing Office,
1971. 19 p.
20
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(7) fcrunner, D. R. and D. J. Keller. Sanitary landfill design
and operation. Washington, U.S. Government Printing Office, 1972.
59 p. . ,
/. *
(8) Sorg, T. J., and H. L. Hickman, Jr. Sanitary landfill facts.
2nd ed. Public Health Service Publication No. 1792. Washington,
U.S. Government Printing Office, 1970. 30 p.
(9) Occupational Safety and Health Act of 1970; Public Law 91-596,
91st Cong., S2193, Dec. 29, 1970. Washington, U.S. Government
Printing Office, 1970. . '
(10) National Solid Wastes Management Association and Federal Solid
*
Waste Management Program. Recommended standards for sanitary land-
's.
fill design, construction, and evaluation and model sanitary
landfill operation agreement.
(11) Federal Solid Waste Management Program. Solid waste management
glossary. Washington, U.S. Government Printing Office, 1972. 20 p.
(12) The Solid Waste Disposal Act as amended; Title II of Public
Law 89-272, 89th Cong., S306, Oct. 20, 1965; Public Law 91-512,
91st Cong., H.R.11833, October 26, 1970. Washington, U.S. Govern-
ment Printing Office, 1971. 14 p.
(13) Zausner, E. R. An accounting system for sanitary landfill
operations. Public Health Service Publication No. 2007. Washington,
U.S. Goverament Printing Office, 3969. 18 p.
(14) Handbook of Chemistry and Physics. 44th ed., Cleveland,
Chemical Rubber Publishing Co., 1S62. 3604. p.
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