Tribal Solid
Waste Program
Costing Tool ^
^    -!•*

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frribal Solid Waste Program
                 Costing Tool
                                  United States
                                  Environmental Protection
                                  Agency

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Tribal Solid Waste Program
Costing Tool
   Introduction
   Solid waste management issues and programs are diverse among tribes. Some tribes continue to struggle with
   closing open dumps and implementing basic waste collection, while others are developing programs with
   composting, recycling and household hazardous waste collection. For tribes just beginning to provide waste
   collection, the options for doing so can seem daunting. Should the tribe buy collection trucks to collect the waste
   or will it be more cost-effective to contract waste removal to a local hauler? Should the tribe build a transfer
   station or continue to haul directly to a landfill? Should the tribe build a landfill? How can the tribe finance the
   chosen option? To help answer these questions and more, this guide contains workbooks designed to help tribes
   choose from solid waste options. It also provides case studies from other tribes, tips on how to finance projects,
   and questions to guide the decision-making process.

   Use of this tool

   This tool is intended to help tribal  leaders make decisions about solid waste collection and disposal and to
   determine feasibility for implementing the following programs:

   • Tribally-operated collection service
   • Tribally-operated transfer station
   • Tribally-operated landfill

   Detailed information about basic waste collection and disposal options, including setting up curbside collection by
   an outside hauler, establishing drop-off sites, hauling waste to a transfer station, and hauling waste to a landfill, is
   available in the Tribal Decision-Maker's Guide to Solid Waste Management (http://www.epa.gov/tribalmsw/
   resource.htm).

   For more information on tribal solid waste programs or help setting up a collection and disposal program, please
   contact your regional EPA tribal solid waste coordinator: http://www.epa.gov/epaoswer/non-hw/tribal/about.htm

   What is a waste disposal program?

   Tribal solid waste programs typically consist of three main components-collection, hauling, and disposal.

   Collection is defined as the movement of solid waste from the waste generator (i.e., a household or business)
   to the next step in the solid waste  system such as a transfer station or a landfill. Collection programs typically
   involve regularly scheduled pick-up routes and include the need for curbside bags, curbside receptacles, and/or
   dumpsters. In a "self-collection" program, the generator takes his or her waste to the nearest dumpster, transfer
   station, or final disposal site. Collection may include separating wastes for recycling, composting and/or household
   hazardous waste collection.

   Hauling refers to the movement of solid waste from a place of consolidation, such as a transfer station or a
   baling facility, to another facility for final disposal. Asa general rule, if a tractor-trailer vehicle is required to move
   the waste to a transfer station, baling facility, or to final disposal, then this is called "hauling." A contractor used to
   pick up these volumes of waste is also categorized as hauling.  "Self hauling" refers to individual generators (i.e.,
   residents or businesses) moving waste from point of generation to point of disposal.

   Disposal of solid waste occurs in a municipal solid waste (MSW) landfill. The landfill may be owned or operated
   by a tribe, local government, or a private entity. Typically, landfills charge tipping fees that are based on the weight
   or volume of the waste disposed.

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                                                                            Tribal Solid Waste Program
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Before you begin...

Questions to help evaluate your current waste collection and disposal system

These questions are helpful to keep in mind when evaluating your options for waste collection
and disposal.

Current Practices

How is solid waste collected currently?
Do 100% of tribal members have access to waste collection?
	    Yes
	    No: (	% have access)
Do 100% of tribal members have access to recyclables collection?
	    Yes
	    No: (	% have access)

How is waste collection and disposal paid for?
	%  by individual generators (i.e., residents and businesses)
	%  by the tribe
	    Other:	
How is household hazardous waste (e.g., paint, solvents, batteries) disposed of?
How are bulky wastes (e.g, mattresses, furniture, electronics) disposed of?
Does the tribe have a solid waste management plan?
	    Yes
	    No

Does illegal dumping occur?
	    Yes
	    No

Does trash burning occur?
	    Yes
        No
NOTES:

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Tribal Solid Waste Program
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        Questions to help evaluate your current waste collection and disposal system

        These questions are helpful to keep in mind when evaluating your options for waste collection
        and disposal.

        Desired Situation

        What are the three biggest problems your tribe faces for solid waste management? (For example: only
        25% of tribal members have curbside trash collection; no members have access to recycling collection;
        75% of members burn trash.)
        1).
        2).
        3).
        What are three solid waste goals for your tribe?

        (For example: start a recycling program in the next 3 years; stop the practice of residential trash burning;
        provide waste collection services to 100% of residents.)

        1)	
        2)	
        3)	
        If the tribe has one, does the Solid Waste Management Plan include information about current and future
        plans for waste collection and disposal? Describe:

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                                                                                  Tribal Solid Waste Program
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Should my tribe start a tribally-operated collection service?

A "tribally-operated collection system" means the tribe owns and operates the collection vehicles and bins, and
that tribal staff are responsible for transporting the waste to the transfer station and/or the municipal solid waste
landfill. This is an alternative option to contracting waste collection to private operators. This option may be best
for tribes in areas where local existing waste haulers are unable or unwilling to collect, or for tribes that create a
sufficient volume of waste so that it is economically beneficial to provide tribally-run waste hauling.

Follow these steps, included in the following worksheets, to conduct an economic feasibility study for a
tribally-operated collection service:

Step 1: Determine what the tribe currently pays for waste collection
Step 2: Determine what a tribally-owned collection system would cost
Step 3: Include user fees
Step 4: Determine if and when the new collection system would breakeven with what the tribe pays currently
More resources on starting a tribally-owned collection service

Tribal Decision-Maker's Guide to Solid Waste Management (PDF)
(http://www.epa.gov/epaoswer/non-hw/tribal/pdftxt/trib-dmg.pdf)

• The Tribal Decision Maker's Guide provides an overview of solid waste management, which covers solid waste
planning, regulations, collection, disposal, recycling, education, and more. It includes over 40 case studies and
examples from tribes who are leaders in solid waste management, as well as a substantial list of resources at the
end of each chapter.

Training and Technical Assistance Directory for Tribal Solid Waste Managers (PDF)
(http://www.epa.gov/epaoswer/non-hw/tribal/pdftxt/training.pdf)

• To help meet tribal needs for training and technical assistance, EPA has compiled a listing of potential sources
of support for tribal municipal solid waste management efforts. It includes stand-alone programs and partnerships
between tribes, states, and local communities.

Partnerships in Solid Waste Management (PDF)
(http://www.epa.gov/epaoswer/non-hw/tribal/pdftxt/partner.pdf)

• This tip sheet discusses working in partnership with other tribes, states, or local governments to address solid
waste issues. The document provides a list of other partnership resources and a case study describing the
partnership of the Eastern Band of Cherokee Indians with Swain County, North Carolina.

Recycling Guide  for Native American Nations
(http://www.epa.gov/tribalmsw/ntverecy.htm)

• This EPA brochure provides useful information for tribes interested in developing recycling programs. Topics in-
clude setting up a  recycling program (collecting materials, staffing, educating the community, and reducing waste),
creating recycling jobs, and buying recycled  products.

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Tribal Solid Waste Program
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   Examples of tribally-run collection systems

   Example 1: Local waste hauler unwilling to pickup on tribal land

   The local waste hauler near the Pit River Tribe was unwilling to provide service to many of the Tribe's remote
   areas. Asa result, tribal members were left to haul their own waste to a far off transfer station and open dumping
   on the Tribe's land was common. To address these problems, the Tribe decided to take on the task of providing
   garbage and recycling service to their tribal members.  Funded with a grant from USDA and EPA (http://www.epa.
   gov/tribaImsw/finance.htm) the Pit River Tribe hired a solid waste coordinator and technician, purchased a
   collection vehicle and bins, and established the Pit River Solid Waste and Recycling service. The Tribe established a drop-off
   recycling center that accepts electronic waste, recyclables, and reusable materials, a car crushing operation, and a "pay-as-
   you-throw"collection program. In order to gain acceptance for the "pay-as-you-throw" program, the Tribe implemented
   the program incrementally, starting it as a free service then gradually introducing fees. After two years of operation, the
   program has successfully provided service to low-income rural tribal
   members who were previously without service. In order to bring the program closer to sustainability, the Tribe
   gained generous support from their Tribal Council, and found creative ways to generate additional program income
   by renting out their collection vehicle and roll-off bins for a fee. The program  provides tribal members with a
   consistent service, and open dumping and burning on the Tribe's land has been greatly reduced.

   For more information about the Pit River Tribe's program, contact:
   The Pit River Solid Waste and Recycling at (530) 335-4516

   Example 2: Volume of waste makes tribally-run program economically feasible

   TheTohonoO'odham Nation consists of 65 communities covering 2.84 million acres.  In 1997, to combat illegal
   dumping and burning on the Tribe's land, the Nation's Legislative Council adopted theTohono O'odham Solid
   Waste Management Plan and Solid Waste Code. The Solid Waste Management Plan called for the establishment
   of a tribally-operated waste collection system, funded by user fees, grant money, and gaming dollars.

   The program has expanded and improved each year and serves as a model program with weekly pickups, a
   comprehensive recycling and HHW collection program, and an active open dump cleanup and enforcement pro-
   gram. Weekly, three front loader compactor trucks drive nine collection routes covering the 65 communities of
   the Nation. The routes include pickup at 750 waste bins (a combination of 4-  and 6- cubic yard bins). The solid
   waste is taken to a tribally-owned transfer station and recycling yard in the Nation's capital of Sells, Arizona to be
   consolidated before transportation to the City of Tucson's landfill for disposal. Monthly, 600 tons of solid waste
   and 50 tons of recyclables are transported to Tucson by theTohono O'odham Nation's collection program.
   In addition to waste collection, the Tribe has an office paper and cardboard recycling  program, a household
   hazardous waste collection program, and a scrap metal and junk vehicle abatement program.

   For more information about theTohono O'odham Nation's program, contact theTohono O'odham Nation's Solid
   Waste Management Office at (520) 383-4767.

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                                                                                Tribal Solid Waste Program
                                                                                              Costing Tool
  Step 1: Determine what the tribe currently pays for waste collection
  These  calculations only include costs that the tribal government currently pays for rather than
  what residents, businesses, or other generators may be paying for.
                 Information needed
  A) Number of tribal households
     or residential units within the
     service area
   B) Current waste hauling/
     disposal cost to the tribal
     government per household
  C) Number of offices,
     businesses, and government
     facilities (such as schools and
     hospitals) within the service
     area
   D) Current waste hauling/
     disposal cost to the tribal
     government per business
  G) Total yearly cost of current
     system to the tribe
                                          Households
    $/Month
Offices/Businesses
    $/Month
                                            $/Year
                         If all residents and businesses
                         pay for their own waste
                         collection, this cost will be zero.
                                                                      12*
                                       BCD
                                                  OR
   E) Approximate number of tons
     per day disposed
   F) Hauling/disposal cost per ton
     to the tribal government
  G) Total yearly cost of current
     system to the tribe
                                             Tons
                                             $/Ton
                                            $/Year
                           Average solid waste generation
                           is 4.5 Ibs/capita/day.
                           1  ton = 2000 pounds)

                           (	*	) / 2000
                           # of residents * solid waste
                                         generation
                                   365
NOTES:

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 ;s  Tribal Solid Waste Program
'   Costing Too I
Step 2: Determine what a tribally-owned collection system would cost
These calculations only include the costs that the tribal government will pay for.
However, when considering who will use the new collection service, you may want to account
for residents who previously paid for their own collection services.
Information needed
Initial costs may include any or all of the following:
Mark NA for items not needed
H) Number of curbside bins
needed
1) Cost per curbside bin
J) Number of community
dumpsters or roll-off bins
needed
K) Cost per community
dumpster or roll-off bin
L) Number of additional
collection vehicles needed
M) Cost per collection vehicle
N) Other equipment or overhead
costs (include costs of
planning as well as hiring and
training staff)
O) Total initial cost
Bins
$/Bin
Dumpsters or Roll-Off
Bins
$/Dumpster or Roll-Off
Bin
Vehicles
$/Vehicle
$/Year
$

< Curbside bin

Roll-off bin to purchase:
40cy~ $4.2k

Other equipment and overhead
costs are:

(__*__) + (__*__) + (__*__) + __
HI J K L M N


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Step 2 continued: Determine what a tribally-owned collection system would cost
These calculations only include costs that the tribal government will pay for.  However, when
considering who will use the new collection service, you may want to account for residents
who previously paid for their own collection services.
Information needed: Calculating yearly
operating costs
P) Miles collection vehicle will
   travel per week
Q) Cost of gas per mile
   Miles/Week
                                         $/Mile
          Cost of gas per mile =
         Cost of gas per gallon /
    Gas mileage of vehicle (in miles per
                 gallon)

      Cost of maintenance per mile =
        Yearly maintenance costs /
      Number of miles traveled a year
                 (52*P)
R) Cost of maintenance, repairs
   and insurance per mile
S) Contingency cost per year
T) Administrative staff hours
   needed per week
U) Cost per hour administrative
   staff time
V) Solid waste technician/hauler
   hours needed per week
W) Cost per hour solid waste
    technician/hauler
X) Tipping fee per month
Y) Other costs per year (include
  any annual capital costs
  related to depreciation of
  vehicles and equipment, and
  any state taxes for road use)
Z) Total cost per year
                                         $/Mile
                                         $/Year
   Hours/Week
                                         $/Hour*
                                       Hours/Week
                                         $/Hour*
Contingency should be budgeted in to
the yearly operating costs to
prevent cost overrun from unexpected
changes or setbacks in the project.
Contingency costs should include at a
minimum:
• Replacement costs for equipment
• Contamination cleanup*
*Note that if you are disposing of
waste off reservation, the landfill or
final disposal site maintains records
of who hauled there and in what
quantities. If there is ever a need
for reclamation or clean up, the tribe
can be billed for a portion of waste
dumped there over the life of the
contract.
                      Remember to include the cost of both
                      salary and benefits when calculating
                      staff costs.
                     Tipping fee per month = tons of waste
                     collected per month* tipping fee per
                     ton at the transfer station or landfill.
                                        $/Month
     $/Year
                                         $/Year
Other costs per year might be:

Annual capital costs for items such
as curbside bins (5-year average life
expectancy), roll-off containers
(10-year life expectancy), and
collection trucks (150,000 miles life
expectancy
   Total costs per year:   52
                             P   Q
. +
 P
) + (__*__+.
T   U  V  W
     S   X
+ __*12 +
 Y

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Tribal Solid Waste Program
Costing Tool
     Step 3: Include user fees
     Use your calculations from the previous pages. You may want to charge users a monthly fee
     for collection service, or charge per bag of garbage ("pay-as-you-throw") in order to recoup
     costs. Setting fees will depend on both the cost of service and the willingness and ability for
     residents to pay
                   Information needed
     a) Fee charged to households for
        use (if any)
     b) Fee charged to tribal
        businesses for use (if any)
     G) Revenue, if any, from
        recyclables collection
     d) Total yearly revenue from
        collection program
                                             $/Month
                                             $/Month
                                             $/Month
                                              $/Year
 If you choose to start a "pay-
 as-you-throw" program, and
 charge per bag, the monthly fee
 would be =

 Price per bag * average number
 of bags used per month by
 residents/businesses
                                                                     12*(
          * __+ __* _
           A  b  C
+
c
A=# of residences from page 6
B=# tribal business from page 6
OR A&B can reflect  the number
of residences and businesses
expected to use the new program.
     Step 4: Determine if/when the new collection system wilTbreak even" with what the tribe
     pays currently
     Use your calculations from the previous pages.
     Payback period with no fee charged and no recycling revenue:
     o/(G-z;
     =  payback time in years

     If you get a negative number, it means that the new system will ultimately be more expensive than the current
     system, unless you are able to decrease costs or include fees for service.

     Payback period with fee charged and recycling revenue:

     O/(d+G-Z)
     =  payback time in years
   NOTES:

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Breaking even: funding your program and decreasing your costs

Funding Your Program

Most tribes pay for their solid waste programs with a mixture of grants, general funds, and direct fees charged to
generators/users. Grants can often be used for planning, development, and start-up costs, which can include capital
equipment costs, but can not often be used to pay for operation and maintenance of the program. Clearly defining
your expenses will make it possible to identify funding sources that are politically and financially sustainable.

Grants Federal grants can sometimes be used to fund certain capital costs associated with your solid waste
program. Operation and maintenance costs are typically not covered.
   Capital Costs Covered By Federal Grants
  Training, technical assistance, heavy equipment
  (Indian Health Service)

  Development of community solid waste activities
  (Housing and Urban Development Community
  Development Block Grants)

  Heavy equipment, technical assistance, training
  (USDA Rural Development)

  Personnel for a pilot collection program, small
  equipment and supplies, vehicles, technical
  assistance, public outreach (EPA)
Operation and Maintenance Costs Not
Covered By Federal Grants
Fuel

Tipping fees

Bin replacement (depends on situation)

Vehicle repair and replacement (depends on
situation)

Salaries for solid waste technicians and
administrative staff past the pilot phase of
the project
Fees The best way to make sure your solid waste program runs sustainably is direct fees charged to generators
for pickup, drop-off, hauling, or disposal services — whether with a tribally-run program or with  the use of
contractors. Fees for residents can be collected through utilities billing, pay-as-you-throw or housing rental
payments. Fees for businesses can be negotiated as part of the lease agreement and/or billed directly.
Universal participation by all generators can be an issue if participation is voluntary.

General Fund Participation can be increased if a tribe's general fund or gaming revenues are used to pay for
trash service. Although it is generally a large and readily available source of money, solid waste must compete with
other tribal needs and many tribes and  native villages find it difficult to fund this large operation and maintenance
budget item.
Sources of Equipment

General Services Administration (GSA) GSAXcess allows tribes seeking property to avoid the cost of new
procurements by acquiring the same or like items that have been reported as excess by another federal activity.
More information is available at: http://www.gsa.gov/gsaxcess

Materials exchange: You may be able to find free materials and equipment on materials exchange web sites such as
Freecycle. More information on Freecycle: http://www.freecycle.org/
Some states host their own materials exchange web sites.
Arkansas: E-match: http://www.1800arkansas.com/energy/index.cfm?page=industrial_ematch2
California: California Materials Exchange (CalMax): http://www.ciwmb.ca.gov/calmax
Florida: Southern Waste Information Exchange: http://wastexchange.org/

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Tribal Solid Waste Program
Costing Tool
  Georgia: Enviroshare Waste Information Exchange: http://www.enviroshare.org
  Indiana: Indiana Materials Exchange: http://www.in.gov/idem/
  Illinois: Industrial Material Exchange Service: http://www.epa.state.il.us/land/imes/
  Iowa: Iowa Waste Exchange/Recycle Iowa: http://www.recycleiowa.org/exchange.htm
  Kentucky: Kentucky Materials Exchange: http://www.kppc.org/KIME/
  Minnesota: Minnesota Materials Exchange Alliance: http://www.mnexchange.org/
  Montana: Montana Material Exchange: http://www.montana.edu/mme/
  New Hampshire: New Hampshire Materials Exchange: http://www.wastecapnh.org/nhme/
  New York: Wa$teMatch: http://www.wastematch.org
  Ohio: Ohio Materials Exchange: http://www.epa.state.oh.us/opp/omex/omex.html
  Oklahoma: Oklahoma Materials Exchange (OKMAX): http://www.deq.state.ok.us/csdnew/wasteex/OKmax.htm
  Tennessee: Tennessee Materials Exchange: http://www.cis.utk.edu/TME/
  Texas: Renew: http://www.renewtx.org
  Vermont: Vermont Business Materials Exchange: http://www.vbmex.net/
  Washington: 2Good2Toss: http://www.2good2toss.com/
  West Virginia: West Virginia Materials Exchange: http://www.state.wv.us/swmb/exchange/
  Wisconsin: Business Material Exchange of Wisconsin: http://www.bmex.org


  Tribal Example

  When the City of Folsom, California, mandated that their garbage service provide smaller bins, the city was left
  with hundreds of 90-gallon roll-off bins and no use for them. The Pit River Tribe saw the bins posted for free
  pickup on CalMaxand realized they could use them. The Tribe picked up about 100 of the bins, valued at about
  $100 each, set aside some of the bins for their senior complex and plans to sell the rest to Tribal members for $25
  each. The revenue will be used to supplement the Tribe's solid waste and recycling program.

  Share with other tribal programs: The tribe may already have some of the needed equipment within another
  tribal program.  Check with other tribal programs such as housing or public works to see what might be available.
   Decreasing Your Costs

   Outreach Decrease the cost of waste hauling and disposal by encouraging waste reduction to your
   community. Start by researching and understanding your community's values and identifying barriers which may
   trigger specific behaviors that contribute to increased waste generation. The tribe should invest the time, money,
   and effort to understand these barriers first in order to create incentives that embrace peoples'values and change
   these specific behaviors, to reduce waste generation  in the long run. Outreach may include distributing printed
   materials to each household and business, making radio orTV public service announcements, publishing articles in
   a tribal newsletter or paper, giving presentations to local schools, and hosting information booths at tribal events.

   Include Recycling Adding recycling to your waste collection program may increase some hauling costs
   and staff time. However, you may find significant savings in tipping fees. To incorporate the costs from adding
   recycling as part of your collection program, fill out steps 2-4 on the worksheets on the previous pages and include
   costs and savings for collecting recyclables. Check with your local transfer station and/or recycling center to see
   what recyclables they accept and what they charge/pay for them. In states with bottle bills, such as California,
   Oregon, Iowa, and New York, beverage containers have value and can be redeemed for profit. Tribes in bottle bill
   states should consider this additional potential revenue stream when starting a tribally-operated collection service.

   Consider Partial Collection It may not be economically feasible to collect from all residents and
   businesses. Evaluate the costs of your program if you have a limited collection program. You may also want to
   evaluate what types of waste you will exclude from collection and how these wastes will be collected.
   For example, you may want to exclude large bulky items such as mattresses and refrigerators from your collection
   program but provide a drop-off location for residents to take these items.

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Accounting for money saved Your collection program may lead to a decrease in open dumping. You may
want to include potential cost savings from decreased open dump cleanups when evaluating your program. EPA
Region 5 has created the IDEA (Illegal Dumping Economic Assessment) Cost Estimating Model, a useful tool for
assessing and measuring the costs of illegal dumping activities. It has the ability to model the costs of cleanup
activities for a single illegal dump site, specific groups of sites, or all of the illegal dump sites on a reservation.
The IDEA model's other functions include the ability to:

• Conduct cost analyses for different cleanup methods, equipment investments, and other illegal dumping-
 related activities
• Assess indirect costs of surveillance and prevention activities
• Compile actual cleanup and enforcement costs

For more information on the IDEA Model visit: http://www.epa.gov/region5/illegaldumping

An example of including cost savings from decreased open dumping:

Open dumping cleanup costs to tribe each year: $100,000
Expected decrease in  open dumping due to the new collection program: 25% reduction
Total savings: $25,000

Total cost of the collection program = cost of program - amount saved from open dump cleanups
 NOTES AND CALCULATIONS:

 Current tribally-owned equipment:.
 Free equipment might be obtained from:_
 Types of waste my collection program will accept:_
 Types of waste my collection program will notaccept:_
 How wastes that my collection program will not accept will be collected:.
 Grants I should apply for: _
 Current personnel available:
 Training needed:.

 Notes:	


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Tribal Solid Waste Program
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   Should my tribe start a tribally-operated transfer station?

   A waste transfer station is a facility where waste is consolidated from multiple collection vehicles into larger
   volume transfer vehicles for more economical transportation to distant disposal sites. A transfer station can also
   be a place where residents come to drop off their household waste. A "tribally-operated transfer station" means
   that the tribe owns and operates a transfer station on tribal land. This option may work best for tribes facing long
   hauling distances to a final disposal site, for tribes handling large volumes of waste, or for tribes servicing multiple
   collectors.

   Is a transfer station right for my community?

   Whether a transfer station is right for your tribe depends on the transfer station's ability to coordinate with the
   rest of the community's solid waste system. Costs associated with planning, siting, designing, and operating the
   facility are also key considerations. Decision-makers need to weigh those costs against savings the station might
   generate from reduced hauling costs. Other factors to consider when deciding to build a transfer station include
   whether the project has the support of the tribal community, if a suitable site exists on which to build the transfer
   station, and what impacts the transfer station might have on the surrounding community and environment.

   Will building  a transfer station be economically feasible for my tribe?

   Tribal transfer stations range in size and cost from small sites with a roll-off bin or two costing less than $50,000 to
   construct, to large, multi-million dollar facilities that require heavy machinery, such as compactors, to operate.
   For more information about what size transfer station might be right for your tribe, as well as how to get cost
   estimates for construction, see Against All Odds: Transfer Station Triumphs (EPATribal Waste Journal) (available
   at: http://www.epa.gov/epaoswer/non-hw/tribal/pdftxt/twj-2.pdf).

   To conduct an economic feasibility study for a tribally-operated transfer station, follow these steps, included in the
   following worksheets:

   Step 1: Determine what the tribe currently pays for waste collection
   Step 2: Determine what a tribally-owned transfer station would cost to construct and operate
   Step 3: Include  user fees
   Step 4: Determine if/when building a transfer station will "break even" with what the tribe pays currently
   Step 5:  Determine if building a transfer station is cost effective based on the distances traveled.

   Regulations regarding transfer stations on tribal land

   No federal regulations exist that are specifically applicable to transfer stations.  State laws may apply to the waste
   transfer trucks once they leave the reservation. Check with your state to see what may apply. Your tribe may have
   zoning or other regulations that apply. There are many best management practices that should be incorporated
   into the planning, construction, and operation of a transfer station. A description of best management practices
   can be found in Waste Transfer Stations: A Manual for Decision-Making (available at: http://www.epa.gov/epao-
   swer/non-hw/muncpl/pubs/r02002.pdf).

   More resources on planning, designing and operating a transfer station

   Waste Transfer  Stations: A Manual for Decision-Making
   (http://www.epa.gov/epaoswer/non-hw/muncpl/pubs/r02002.pdf)

   • Defines what a transfer station is and how it relates to municipal solid waste management in the context of a
    community's total waste management plan. The manual identifies issues and factors to consider when deciding
    to build a transfer station, planning and designing it, selecting a site, and involving the community.

   Against All Odds: Transfer Station Triumphs (Tribal Waste Journal)
   (http://www.epa.gov/epaoswer/non-hw/tribal/pdftxt/twj-2.pdf)

   • Provides case studies on tribal transfer stations from across the US.

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                                                                                  Tribal Solid Waste Program
                                                                                                  Costing Tool
Waste Transfer Stations: Involved Citizens Make the Difference
(http://www.epa.gov/epaoswer/non-hw/muncpl/pubs/wtsguide.pdf)

• Contains information on what role transfer stations play in the community, how they might impact the
 community, and how concerned citizens can participate in the decisions concerning their location and operation.

Tribal Decision-Maker's Guide to Solid Waste Management: Chapter 4
(http://www.epa.gov/epaoswer/non-hw/tribal/pdftxt/trib-dmg.pdf)

• The Tribal Decision Maker's Guide provides an overview of solid waste management, covering solid waste
 planning, regulations, collection, disposal, recycling, education, and more. It includes over 40 case studies and
 examples from tribes who are leaders in solid waste management, as well as a substantial list of resources at the
 end  of each chapter.
Examples of tribally-run transfer stations

Tule River

When the Tule River Tribe closed its five open dumps in the early
1990s, the Tribe knew that another waste disposal option would have
to be provided to its more than 800 tribal members. The Tribe first
provided 30-cubicyard roll-off containers for trash disposal. These
containers, however, proved difficult to use for some community
members because they had to throw trash up and over the edges of
the 6-foot high containers. As a result, trash often ended up around
the bins instead of in them, giving dogs and other stray animals easy
access to the trash.

Based on the recommendations and cost analyses in their Solid
Waste Management Plan, the Tribe decided that a transfer station
offered the best solution. The transfer station was built by Indian
Health Services with funds through the Division of Sanitation Facilities Construction program ($45,000) and from
US Department of Housing and Urban Development ($96,000). Tule River Indian Tribal Public Works contributed by
preparing the site prior to construction.

The transfer station is free to all tribal and community members and tribal businesses. Residential waste collection
service is not currently available on the reservation, so residents must self-haul their waste to the transfer station.
The station is a paved, open-air, multi-level facility and is totally enclosed with a chain linkfence and three locking
gates. The waste tipping area consists of two 30-cubicyard roll-off bins situated in an  excavated area, which allows
tribal members to back up their vehicles and dump their waste directly into the bins. A ramp gives transfer vehicles
access to the bins, and allows the bins to be removed and replaced when full.

The station also has three recycling bins for glass, plastic, and cardboard and three overflow/storage bins for storing
recyclables when the receiving bins are full. In addition to household waste and recyclables, the transfer station
accepts refrigerators, used tires, and office paper from the tribe's administrative offices. Used tires are stacked
neatly and taken to a recycling facility at least every six weeks. The tribe also pays a licensed contractor to remove
hazardous fluids, such as Freon and oils, from old refrigerators and appliances brought to the transfer station.

For more information on Tule River's Transfer Station, contact the Tule River Environmental Office at (559) 781-
4271.

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        Tribal Solid Waste Program
        Costing Tool
,i.:::saaas
La Jolla Transfer Station

The 480-member La Jolla Tribe in Southern California
secured funding from the United States Department of
Agriculture Rural Development (USDA RD) to build a solid
waste transfer station on the reservation. Before the
transfer station existed, residents had to travel over 25
miles to a nearby town to haul their recyclables and trash.
The long distance gave residents little economic incentive
to recycle or to properly dispose of their waste.
To address the problem, the Tribe constructed a transfer
station near the tribal offices and opens it on weekends
for tribal residents.The transfer station collects trash,
white goods, electronics, and recyclables. Residents
transport their trash to the transfer station where waste
is collected and transported by the local disposal
company to the Ramona Transfer Station and ultimately
to the Ramona landfill.
          Source reduction and recycling play an integral role in the Tribe's integrated waste management program.
          By practicing environmental preferable purchasing and implementing a recycling program for their tribal offices,
          the Tribe has minimized the recyclable material that has gone into the waste stream and ultimately decreased
          what materials end up in landfills. Future plans include expanding the recycling program and piloting a household
          hazardous waste collection program.

          For more information on La Jolla's Transfer Station, contact:
          The La Jolla Tribal Environmental Office at (760) 742-3790.
               NOTES:

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                                                                             Tribal Solid Waste Program
                                                                                            Costing Tool
Step 1: Determine what the tribe currently pays for waste collection
These calculations only include costs that the tribal government currently pays for rather than
what residents, businesses, or other generators may be paying for. This information is the
same as on Page 6.
               Information  needed
A) Number of tribal households
or residential units within the
service area
B) Current waste hauling/
disposal cost to the tribal
government per household
C)  Number of offices,
businesses, and government
facilities (such as schools and
hospitals) within the service area
D) Current waste hauling/
disposal cost to the tribal
government per business
G) Total yearly cost of current
system to the tribe
                                        Households
$/Month
                                     Offices/Businesses
$/Month
                                          $/Year
                     If all residents and businesses
                     pay for their own waste
                     collection this cost will be zero.
                           12*(
                                   BCD
                                                OR
E) Approximate number tons per
day disposed
F) Hauling/disposal cost per ton
to the tribal government
G) Total yearly cost of current
system to the tribe
                                          Tons
                                          $/Ton
                                          $/Year
                       Average solid waste generation
                       is 4.5 Ibs/capita/day.
                       1 ton = 2000 pounds)

                       (            *           ) /2000
                       # of residents * solid waste
                                   generation
                               365

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Tribal Solid Waste Program
Costing Tool
Step 2: Determine what a tribally-owned transfer station would cost
These calculations only include costs that the tribal government will pay for. However, when
considering who will use the new collection service, you may want to account for residents
who previously paid for their own collection and disposal services.
Option 1: Tribal hauling — tribe owns roll-off bins and self hauls to final disposal site
Information needed
H) Initial Costs: Cost to plan,
design, and construct the transfer
station and hire and train staff to
run it
1) Landfill tipping fee per ton
J) Miles collection vehicle will
travel per week
K) Cost of gas per mile
L) Cost of maintenance, repairs
and insurance per mile
M) Contingency cost per year
N) Administrative staff hours
needed per week
O) Cost per hour administrative
staff time
P) Solid waste technician/hauler
hours needed per week
Q)Cost per hour solid waste
technician/hauler
R) Other costs per year (include
any annual capital costs related to
depreciation of vehicles and
equipment, and any state taxes
for road use)
Z) Total yearly operating costs
$
$/Ton
Miles/Week
$/Mile ""
$/Mile
-<-
$
Hours/Week
$/Hour*
Hours/Week
$/Hour*
<+
$/Year
$/Year
—
Cost of c
Cost of c
Gas mile
Cost of r
Yearly m
Number

Transfer station construction
costs can range from a few
thousand dollars to more than
$1,000,000. See Chapter 4 of
the Tribal Decision Makers Guide
to Solid Waste Management for
more details on how to estimate
design and construction costs.


as per gallon /
age of vehicle (in miles per gallon)
naintenance per mile =
aintenance costs /
of miles traveled a year (52*J)

Co
to
ve
ch
	 Co
a r
• R
• C
iru
• E
• C
* |V
wa
fin
of
qu
fo
™i ca
du
CO
ntingency should be budgeted in
the yearly operating costs to pre-
nt cost overrun from unexpected
anges or setbacks in the project.
ntingency costs should include at
ninimum:
eplacement costs for equipment
losure and post-closure monitor-
3
xpansion of facilities
ontamination cleanup*
lote that if you are disposing of
ste off reservation, the landfill or
al disposal site maintains records
who hauled there and in what
antities. If there is ever a need
reclamation or clean up, the tribe
n be billed for a portion of waste
mped there over the life of the
ntract.

*Remember to include the cost
1 of both salary and benefits when
calculating staff costs.

— Other
Annu<
as cur
expec
life ex
(150.C
costs per year might be:
al capital costs for items such
bside bins (5-year average life
tancy), roll-off containers (10-year
pectancy), and collection trucks
00 miles life expectancy)

Total yearly = ( * * 365 ) + ( 52 * *( + ) )+ +52*
(*+*)+
operating costs IE JKLM NOPQR

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                                                                               Tribal Solid Waste Program
                                                                                              Costing Tool
Step 2 continued: Determine what a tribally-owned transfer station would cost
These calculations only include costs that the tribal government will pay for.  However, when
considering who will use the new collection service, you may want to account for residents
who previously paid for their own collection services.

Option 2: Contract hauling — tribe contracts for hauling to and disposal at the landfill.
               Information needed
H) Initial Costs: Cost to plan,
  design, and construct the
  transfer station and hire and
  train staff to run it
S) Cost of contract hauling and
   disposal per month
T) Administrative staff hours
   needed per week
U) Cost per hour administrative
   staff time
V) Solid waste technician hours
   needed per week
W) Cost per hour solid waste
    technician
X) Contingency costs
Y) Other costs per year
Z) Total yearly operating costs
Z) Total cost per year
                   $/Month
                  Hours/Week
                                           $/Hour
                  Hours/Week
                                           $/Hour
                                           $/Year
                                           $/Year
                                           $/Year
                                          Transfer station construction
                                          costs can  range from a few
                                          thousand dollars to more than
                                          $1,000,000. See Chapter 4 of
                                          the Tribal Decision Makers Guide
                                          to Solid Waste Management for
                                          more details.
                                                                   *Remember to include the cost
                                                                   of both salary and benefits when
                                                                   calculating staff costs.
                           Contingency should be budgeted in
                           to the yearly operating costs to pre-
                           vent cost overrun from unexpected
                           changes or setbacks in the project.
                           Contingency costs should include at
                           a minimum:
                           • Replacement costs for equipment
                           • Closure and post-closure monitor-
                           ing
                           • Expansion of facilities
                           • Contamination cleanup*
                           * Note that if you are disposing of
                           waste off reservation, the landfill or
                           final disposal site maintains records
                           of who hauled there and in what
                           quantities. If there is ever a need
                           for reclamation or clean up, the tribe
                           can be billed for a portion of waste
                           dumped there over the life of the
                           contract.
                                                                    Other costs per year might be:
  Total yearly   =
operating costs
12*	+ 52
  S
	*	+	*	) +	+_
 T  U   V  W    X   Y

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Tribal Solid Waste Program
Costing Tool
      Step 3: Include user fees and recycling revenue
      You may want to charge users a monthly fee for collection service, charge per bag of garbage,
      charge per ton of waste, or charge by type of waste, in order to recoup your costs. Setting
      fees will  depend on both the cost of service and the willingness and ability for residents to
      pay-
                    Information needed
      a) Fee charged to users of the
        transfer station (if any)
      b) Yearly revenue from selling
        recyclable material
      G) Total yearly revenue from
         collection program
                                             $/Month
                                              $/Year
                                              $/Year
 If you choose to charge per bag
 or per ton, the monthly fee would
 be =
 Price per bag or ton * average
 number of bags or tons used per
 month by residents/businesses
  12*
          A  C
+
b
A=# of residences from page 6
B=# tribal business from  page 6
OR A&B can reflect  the number of
residences and businesses
expected to use the new program.
      Step 4: Determine if/when building a transfer station will "break even" with what the tribe
      pays currently
      Use your calculations from the previous pages.
      Payback period, not including any revenue:
      H/(G-Z)
      = payback time in years


      If you get a negative number, it means that the system will ultimately be more expensive than the current
      system, unless you are able to decrease costs, market recyclables, or charge fees for service.

      Payback period including revenue:

      H / (c+ G - Z)
      = payback time in years

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                                                                                 Tribal Solid Waste Program
                                                                                                 Costing Tool
Step 5:  Determine if building a transfer station will be cost effective based on the distances
traveled.
(Note, this example assumes hauling by the tribe and not hauling by a contract)
               Information needed
A) Cost to build, own, and
  operate transfer station
B) Average payload* of collection
truck hauling directly to the landfill
C)  Average payload* of transfer
   truck hauling from transfer
   station to landfill
D) Average trucking cost per
   mile driven (direct or transfer
   hauling) (This includes the
   costs of hauler salary, gas and
   vehicle maintenance)
"Break-even" hauling distance
                                           $/Ton
                                           Tons
                                             Tons
                                          $/Mile
                                            Miles
*Payload is the amount of
waste in tons a collection truck
brings to the landfill
                                                                        ABC
                                                                                   D    C B
SAMPLE
       Sample Comparison of Hauling Costs With and
                Without a Transfer Station
                                           1 Haul cost without
                                            transfer station
                                            Haul cost with
                                            transfer station
      0              35              60
        Distance from Waste Source to
               Disposal, miles
                                                           The following assumptions were used to
                                                           create this sample comparison.

                                                           A) Cost to build, own, and operate transfer
                                                             station: $10/ton
                                                           B) Average payload of collection truck hauling
                                                             directly to the landfill: 7 tons
                                                           C) Average payload of transfer truck hauling
                                                             from transfer station to landfill: 21 tons
                                                           D) Average trucking cost (direct or transfer
                                                             hauling: $3/mile
                                                           The comparison shows a break-even
                                                           distance of about 35 miles (round trip).
                                                           Using a transfer station in this case is less
costly with distances greater than 35 miles round trip. Not using a transfer station is less costly with
distances of less than 35 miles round trip. Although the same economic principles apply, different break
even distances result when different input assumptions are used.
                                                                                                               *-.yjJ?'. -'t

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Tribal Solid Waste Program
Costing Tool
   Breaking even: Funding your program and decreasing your costs

   Funding Your Program

   Most tribes pay for the construction and operation of their transfer stations with a mixture of grants, general
   funds, and direct fees. Grants can sometimes be used for construction and capital equipment costs.
   Clearly defining your expenses will make it possible to identify funding sources that are politically and financially
   sustainable.

   Grants Federal grants can sometimes be used to fund certain components of your solid waste program.
   Operation and maintenance costs are typically not covered.
     Capital Costs Covered By Federal Grants
     Design and construction of transfer station, training,
     technical assistance (Indian Health Service)

     Development of community solid waste activities,
     construction of transfer station (Housing and Urban
     Development Community Development Block
     Grants)

     Construction of transfer station technical assistance,
     training (USDA Rural Development)

     Personnel for a pilot transfer station program, equip-
     ment, technical assistance (EPA)
Operation and Maintenance Costs Not
Covered By Federal Grants
Fuel

Tipping fees

Bin replacement (depends on situation)

Vehicle repair and replacement (depends on
situation)

Salaries for solid waste technicians and
administrative staff past the pilot phase of
the project

Cost of contract hauling
   Fees The best way to make sure your transfer station runs sustainably is direct fees charged to generators for
   pickup, drop-off, hauling, or disposal services — whether with a tribally-run program or with the use of
   contractors. Fees can be collected through utilities, pay-as-you-throw, tipping fees, or housing rental payments.
   Universal participation by all generators can be an issue if participation is voluntary.

   General Fund  Use of the transfer station can be increased if a tribe's general fund or gaming revenues are
   used to pay for the operation of the facility and no fees are charged for use by tribal members. Although it is
   generally a large and readily available source of money, the need for a transfer station must compete with other
   tribal needs and  many tribes and native villages find it difficult to fund this large operation and maintenance budget
   item.

   Decreasing Your Costs

   Outreach Decrease the cost of waste hauling and disposal by encouraging waste reduction to your community.
   Start by researching and understanding your community's values and identifying barriers which may trigger
   specific behaviors that contribute to increased waste generation. The tribe should invest the time, money, and
   effort to understand these barriers first in order to create incentives that embrace peoples'values and change
   these specific behaviors, to reduce waste generation in the long run. Outreach may include distributing printed
   materials to each household and business, making radio orTV public service announcements, publishing articles
   in a tribal newsletter or paper, giving presentations to local schools, and hosting information booths at tribal
   events.

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                                                                                 Tribal Solid Waste Program
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Soliciting Multiple Bids Make sure you solicit multiple bids from contractors (both for design and
construction of your transfer station, as well as for any contract hauling you will need) to insure the lowest rate.

Negotiate With Waste Disposal Companies Some waste disposal companies may be willing to
negotiate to construct a transfer station in exchange for a long-term hauling and disposal contract. This has the
benefit of amortizing the high capital costs of building the transfer station in the disposal fees over the life of
the contract.

Recyclable Materials Buy-Back A buy-back center can be part of your transfer station. In states with bottle
deposit rules such as California, the consumer pays extra (usually 5-10 cents) for each can and bottle when
purchased. This deposit is returned at a buy-back center which can be built on tribal lands. Buy-back centers, in
addition to encouraging recycling in your community and decreasing your tipping fee at the landfill, can help to
decrease costs by bringing in revenue from sales of recyclable material.  Several tribes in California, including
Robinson Rancheria and the Hopland Tribe, have partnered with the State of California and host California Refund
Value (CRV) buy-back centers. For more information about starting a buy-back center, check with your state.
States that have bottle bills include California, Connecticut, Delaware, Hawaii, Iowa, Maine, Massachusetts,
Michigan, New York, Oregon, and Vermont.

Sale of Recyclable  Material Some materials, especially scrap metal, may have high re-sale values.  Check with local
dealers and haulers to see what materials you may be able to sell. You can check scrap metal prices at the following web
sites: http://www.recycleinme.com/ or http://www.metalprices.com/.

Accounting for money saved Your transfer station may lead to a decrease in open dumping. You may want
to include potential cost savings from  decreased open dump cleanups when evaluating the costs of your transfer
station.  EPA Region 5  has created the IDEA (Illegal Dumping Economic Assessment) Cost Estimating Model, a
useful tool for assessing and measuring the costs of illegal dumping activities. It has the ability to model the costs
of cleanup activities for a single illegal dump site, specific groups of sites, or all of the illegal dump sites on a
reservation. The IDEA model's other functions include the ability to:

• Conduct cost analyses for different cleanup methods, equipment investments, and other illegal dumping-
  related activities
• Assess indirect costs of surveillance and prevention activities
• Compile actual cleanup and enforcement costs

For more information on the IDEA Model visit: http://www.epa.gov/region5/illegaldumping

An example of including cost savings from decreased open dumping:

Open dumping cleanup costs to tribe each year: $100,000
Expected decrease in open dumping due to the new collection program: 25% reduction
Total savings: $25,000

Total cost of the collection program = cost of program - amount saved from open dump cleanups
   NOTES:

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,,, Tribal Solid Waste Program
  Costing Tool
         Notes and Calculations

         Planning and Building the Transfer Station

         Reasons to build a transfer station:

         1)	
         2)	

         3)	

         Reasons not to build a transfer station:

         1)	
         2)	

         3)	

         Agencies representatives I should contact for technical advice for planning and construction:
         IMS: (name)	
         EPA: (name)	
         USDA: (name),
         HUD: (name)_
. (phone number)	
_ (phone number)	
	(phone number),
_ (phone number)_
.(e-mail)
         Local waste management company:.

         Grants I should apply for:	
         Where to site the transfer station:
         Possible impacts from the transfer station on the community and environment:

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                                                                                 Tribal Solid Waste Program
                                                                                                Costing Tool
Notes and Calculations

Operating the Transfer Station

My transfer station will collect:
	Household trash
	Recyclable material including:.
   _ Household hazardous waste including:	
   _ Tires
   _ Scrap metal
   _ White goods (such as refrigerators, washing machines)
    Used oil
Other:
My transfer station will not collect:_
How will I keep items my transfer station will not collect out of the transfer station:.
My transfer station will:
   _ Collect a fee of $_
   _ Collect a fee of $_
   _ Charge a fee of $_
   _ Charge a fee of $_
   _ Be free to the public
_from tribal members per month
_from non-tribal members per month
_per ton
_per bag
Charge separate fees for:

	Recyclable material $_
   _ Household hazardous waste $_
   _Tires $	per tire
   _ White goods $	per item
   _ Other $	(for	
           .including.
Hours and days my transfer station will be open from: _

Expected number of users per day:	
How many people do I need to run the transfer station: _
Current personnel available:
Training needed:_
Notes:

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Tribal Solid Waste Program
Costing Tool
   Modern landfills are engineered facilities that are located, designed, operated, and monitored to ensure
   compliance with federal regulations. Municipal solid waste landfills (MSWLFs) receive municipal waste for
   disposal. MSWLFs can also receive non-hazardous sludge, industrial solid waste, and construction and demolition
   debris. MSWLFs must be designed to protect the environment from contaminants which may be present in the
   solid waste stream.
                                                                                                 o
   Laws

   Federal laws and regulations governing solid waste management apply directly to owners and operations of
   MSWLFs. The following federal laws govern MSWLFs. In addition, tribal laws may apply in Indian Country.
   In state jurisdictions, state laws may apply.

   Resource Conservation and Recovery Act (RCRA)
   (40 CFR Part 258)

   The primary federal solid waste law is the Resource Conservation and Recovery Act (RCRA) as amended.
   In addition, there are state laws, and sometimes county laws, that regulate solid waste. While state and county
   laws don't apply to solid waste facilities sited in Indian Country, they may be taken into consideration to enhance
   protection of human health or the environment or to promote good stewardship and relationships with the
   surrounding, non-tribal lands and communities.

   Federal MSWLF standards under RCRA are found in regulations promulgated by EPA (40 C.F.R Part 258). All
   MSWLFs must comply with these regulations, regardless of where they are located, and regardless of whether a
   state or tribal authority is regulating the MSWLF. However, some of these regulations allow for alternatives,
   or "flexibility," if the owner or operator can demonstrate that the alternative meets criteria listed in the

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                                                                                 Tribal Solid Waste Program
                                                                                                Costing Tool
regulation. For example, alternative liners may be considered if those liners can be shown to be as protective as
the liner required by the regulations (sometimes called the prescriptive liner). In Indian Country, this demonstration
(called a Site-Specific Flexibility Request) must be made to EPA.

The standards in the regulations include:

Location restrictions: Landfills must be built in suitable geological areas away from faults, wetlands, flood
plains, or other restricted areas.

Composite liners requirements: Landfills must include a flexible membrane (geomembrane) liner overlaying two
feet of compacted clay soil lining the bottom and sides of the landfill and protect groundwater and  the
underlying soil from leachate releases.

Leachate collection and removal systems: Landfills must include a leachate collection system which sits on
top of the composite liner and removes leachate from the landfill for proper treatment and disposal.

Operating practices: Landfills must compact and cover waste daily with several inches of soil to help reduce
odor, control litter, insects, and rodents, and to protect public health.

Groundwater monitoring requirements: Landfills must test groundwater wells to determine whether waste
materials have escaped from the landfill.

Closure and post-closure care requirements: Landfills must properly close the facility when the end of the
operating life has been reached. Proper closure includes a final cover and  long-term care of the facility.

Corrective action provisions: Landfills must control and clean up releases and meet all groundwater protection
standards.

Financial assurance: Landfills must guarantee that funding for environmental protection will be available during
and after landfill closure (i.e., closure and post-closure care).

Some materials may be banned from disposal in MSWLFs, including common household items such as paints,
cleaners/chemicals, motor oil, batteries, and pesticides. Leftover portions of these products are called household
hazardous waste. These products, if mishandled, can be dangerous to human health and the environment. Many
municipal landfills have a household hazardous waste drop-off station for  these materials. MSWLFs can also
receive household appliances (also known as white goods) that are no longer needed. Many of these appliances,
such as refrigerators and window air conditioners, contain ozone-depleting  refrigerants and their substitutes.
MSWLFs have to follow federal disposal procedures for household appliances that use refrigerants. Those proce-
dures can be found  at: http://www.epa.gov/ozone/snap/emissions/downloads/SafeDisposalBrochure.pdf

Exemptions: Small  Community Exemption
(40 CFR Part 258.1)

In rare cases, it is possible to qualify for exemptions from specific parts of the federal MSWLF regulations,
including Subparts D (Design Criteria) and E (Ground-Water Monitoring and Corrective Action) of the Resource
Conservation and Recovery Act, 40 CFR Part 258. If the proposed facility meets the following criteria, it may
qualify for an exemption:

• Owners or operators of new MSWLFs that dispose of less than twenty (20) tons of municipal solid waste daily,
 based on an annual average; and

• A community that  experiences  an annual interruption of at least three consecutive months of surface
 transportation that prevents access to a regional waste management facility, or

• A community that  has no practicable waste management alternative and the landfill unit is located in an area that
 annually receives less than or equal to 25 inches of precipitation.

National Environmental Policy  Act (NEPA)
The lead federal agency for a proposed landfill project will need to demonstrate compliance with NEPA. The lead
will need to determine if an Environmental Assessment (EA) or an Environmental Impact Statement (EIS) is
needed. If an EIS is needed, several steps need to occur which include publishing a Notice of Intent (NOI) to
prepare an Environmental Impact Statement in the Federal Register with the option of conducting public

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Tribal Solid Waste Program
Costing Tool
   scoping meetings to receive input on the proposed project. In addition, the lead agency may consider including
   other federal agencies as cooperating agencies in preparation of theEIS. When the Draft EIS is ready for public
   release, a Notice of Availability is published in the Federal Register and a minimum 45 day public comment period
   is provided, usually with public hearings.

   For additional information on NEPA compliance, please visit the following web site:
   http://www.epa.gov/compliance/basics/nepa.html

   Note that compliance with the National Historic Preservation Act and the Endangered Species Act occurs
   concurrently with the NEPA process. The results of these consultations with the State/Tribal Historic Preservation
   Officer (Section 106 consultation) and the U.S. Fish and Wildlife Service (Section 7 consultation), respectively, is
   included in the NEPA document. Early consultation with the U.S. Army Corps of Engineers for CWA Section 404
   compliance is encouraged.

   Clean Water Act (CWA)
   If the landfill is approved, the project developer must apply for a storm water National Pollutant Discharge Elimination Sys-
   tem (NPDES) permit  before construction can begin. For additional information, please visit the following web site:  http://
   cfpub.epa.gov/npdes/

   Clean Air Act (CAA)
   Within one year of commencing operation, the project developer must submit an application to determine if a Title
   V air permit is necessary (http://www.epa.gov/region09/air/permit/title-v-permits.html). Prior to submitting the
   Title V application, the developer will need to address other air issues (e.g., gas collection system) in the planning
   process, and through the NEPA document.

   More resources on planning, constructing, and operating a municipal solid waste landfill

   Solid Waste Association of North America  (http://www.swana.org)

   • Professional organization for the solid waste management field. SWANA provides training on managing
    and operating MSWLFs.

   EPA's Solid Waste Landfill Web page (http://www.epa.gov/epaoswer/non-hw/muncpl/landfill/swjandfill.htm)

   • More information on federal regulations regarding landfills.

   Municipal Solid Waste Landfill Criteria:Technical Manual
   (http://www.epa.gov/epaoswer/non-hw/muncpl/landfill/techman/index.html)

   • The manual focuses on providing owners/operators with guidance for complying with the Municipal Solid Waste
    Landfill Criteria.

   Site-Specific Flexibility Requests for MSW Landfills in Indian Country; Draft Guidance
   (http://www.epa.gov/epaoswer/non-hw/muncpl/landfill/indian/siteflex.htm)

   • This draft guidance document describes a process by which MSWLF owners and operators in Indian Country
    may apply for the same flexibility that is available to landfill owners and operators in states with EPA-approved
    MSWLF permitting programs.

   Criteria for Solid Waste Disposal Facilities: A Guide for Owner's/Operators
   (http://www.epa.gov/epaoswer/non-hw/muncpl/criteria.htm)

   • The document discusses the major requirements of these regulations, who is required to comply and when,
    how the rule will be implemented and enforced, and where to obtain  more information.

   Safer Disposal for Solid Waste: The Federal Regulations for Landfills
   (http://www.epa.gov/epaoswer/non-hw/muncpl/safedis.htm)

   • This handbook summarizes the federal regulations covering landfill location, operations, design, groundwater
    monitoring and corrective action, closure and post-closure care, and financial assurance.

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                                                                                 Tribal Solid Waste Program
                                                                                                 Costing Tool
Should my tribe build a municipal solid waste landfill?

Costs associated with permitting, constructing and operating a landfill

Actual costs of permitting, constructing and operating a landfill vary widely. Total costs are greatly affected by the
capacity of the site, the level of compaction of solid waste, and the average daily volume of waste received.

In general, constructing a landfill will likely cost $150,000-$250,000 per acre at least, not including operation and
closure costs (from the Tribal Decision-Makers Guide to Solid Waste Management, Chapter 4). Based on these
costs, tribes generating less than 100 tons of waste per day will find  building and operating a Subtitle D compliant
landfill to be economically infeasible. The following are elements of cost:

Development

• Site assessment
• Legal consultation
• Design
• Environmental assessment or environmental impact statement
• Permits
Construction

• Land clearing and grading, including surface water control
• Excavation
• Liner and leachate collection system construction
• Landfill gas management
• Groundwater monitoring system
• Structures related to landfill operation

Operation

• Equipment  such as dozers, loaders, balers, compactors,
 scrapers, water trucks, graders, and dump trucks
• Personnel costs
• Leachate and landfill gas systems management
• Monitoring
• Outreach
• Financial assurance fund
• Annual inspections

Closure

• Final cover construction
• Vegetation planting
• Storm water runoff control
• Long-term site inspections, monitoring, and leachate and gas
 management; assume at least 30 years of post-closure activity
  According to the Tribal
Decision-Makers Guide to
Solid Waste Management,
 typical construction cost
per acre of landfill  space is
  between $150,000 and
       $250,000.
      Landfill baler:
       ~ $225,000

Landfill dozer/compactor:
    ~ $500,000 each
  Landfill closure costs:
At least $1,000,000, likely
   significantly higher

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   Tribal Solid Waste Program
   Costing Tool
„!
          Notes and Calculations

          Reasons to build a landfill:
          Reasons not to build a landfill:
          Expertise needed:_
          Current personnel available:
          Training needed:.
          Notes:

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