SOP-ExemptSolidWasteLandfill-28Oct2010.pdf

Last Updated 10/28/2010 Standard Operating Procedure Exempt Solid Waste Landfill

SCOPE:

This standard operating procedure identifies the appropriate way to handle the disposal of solid wastes that are exempt from regulation by the U.S. environmental Protection Agency (EPA) and Alaska Department of Environmental Conservation (ADEC). At Base Support Unit Kodiak we operate an exempt solid waste landfill on Nyman’s Peninsula in the contractor’s lay down area.

DEFINITIONS:

Exempt Solid Wastes -- Alaska Administrative Code, Title 18, Chapter 60, Section 005 (18 AAC 60.005) defines exempt solid wastes. ADEC also developed an Exempt Solid Wastes fact sheet in April 2009 (Figure 1) that clearly describes exempt wastes and the restrictions placed on disposal of said waste stream.

High Value Wetland – Marine, Estruarine, Lakes, Large Ponds, Riverine Systems, and Riparian habitats are high value ecological wetland units.

BACKGROUND:

The exempt waste disposal has been going on at Base Kodiak for years. In fact much of the Contractor’s lay down area is a result of exempt waste landfilling. Although exempt waste disposal is generally not regulated, concerns have arisen regarding disposal of non-exempt wastes and encroachment on the wetland area.

The entire South and East shoreline of Nyman’s Peninsula is a high value wetland where dredging and filling is strictly regulated. The May 14, 1999 Final Wetland Delineation Study of U.S. Coast Guard Integrated Support Command (ISC) Kodiak, AK, prepared by Dames & Moore Group, identifies wetland planning zones. The study delineates and maps (Figure 2) the different wetland types on BSU Kodiak property so we can integrate environmental concerns into the USCG Master Planning process. It is important to note that many of the wetland zones include buffer areas next to water that may not appear to be wetland because they are high and dry.

However, these buffer zones are used by aquatic wildlife as refuge and nesting areas. The current fill is right on the border of a high value wetland zone and must not be allowed to expand.

Instances of non-exempt waste being mixed with exempt waste were documented in May and again in October of 2010. The non-exempt wastes included wood boards, bottles, metal sign posts, metal pipe, a metal tire rim, and asphalt.

DISCUSSION:

The current exempt waste landfill, commonly referred to as “the grass dump”, is encroaching on the wetland ecosystem. Expansion of the landfill must stop.

Non-exempt solid wastes must be delivered to the Kodiak Island Borough Landfill for disposal, recycled, or in the case of asphalt – accumulated for re-use at a later date.

RESPONSIBILITIES:

All employees of the Coast Guard or contractors working on the Coast Guard base are responsible for reporting non-compliance with these instructions to the BSU Environmental Branch (907-487-5320 ext 246) or to their appropriate chain of command to pass on to Environmental Branch.

BOSS Contractor – The BOSS contractor maintains general control of the lay down area by use of a locked gate. They add waste to the landfill and are responsible for ensuring that only exempt wastes are added.

Facilities Maintenance Branch – The BSU FMB oversees contractor operations to ensure they are in compliance. FMB is also responsible for maintaining the appropriate signage.

Environmental Branch – The BSU Environmental Branch is responsible for ensuring the Base’s operations are complying with environmental laws and regulations. This includes providing guidance, training, and completing environmental permitting submissions where applicable. The Environmental Branch Chief is responsible for reporting violations to state and federal regulatory agencies when required.

PROCEDURES:

Two signs will be maintained at the exempt waste landfill to identify what wastes are allowed and who to call with questions or concerns.

The following exempt wastes are ALLOWED to be landfilled in the Nyman’s Peninsula lay down area without a permit as long as they do not encroach on the wetland:

Dirt, rocks, and soil Tree limbs, stumps, foliage, branches, sod, and grass/weed clippings Bricks, mortar, and concrete (including reinforcing steel that cannot be easily removed) Crushed Glass

The person disposing of exempt solid waste must ensure compliance with the following:

The exempt waste must not be mixed with non-exempt waste The waste may not cause a safety problem, public nuisance, or environmental problem The waste may not be placed in surface water (creeks, ponds, etc)

The following non-exempt wastes are NOT allowed to be landfilled in the Nyman’s Peninsula lay down area or anywhere outside of a permitted landfill:

Metal (except metal that cannot be easily removed from concrete) Asphalt Garbage (bottles, cans, plastic, etc) Tires Boards, plywood, drywall Any other waste that is not specifically identified as exempt by Alaska Department of

Environmental Conservation

Direct any questions regarding environmental compliance to the BSU Environmental Branch Chief at 907-487-5320 ext 249.

Alaska Department of Environmental Conservation

Division of

Environmental Health

Solid Waste Management

Program Offices www.dec.state.ak.us/eh/sw

Juneau Office:

410 Willoughby Ave Suite 303 Juneau, AK 99801

(907) 465-5160

FAX (907) 465-5362

Anchorage Office:

555 Cordova Street Anchorage, AK 99501

(907) 269-7802

FAX (907) 269-7600

Fairbanks Office:

610 University Ave Fairbanks, AK 99709

(907) 451-2108

FAX (907) 451-2188

Soldotna Office:

43335 Kalifornsky Beach Road, Suite 11 Soldotna, AK 99669

(907) 262-5210

FAX (907) 262-2294

Exempt Solid Wastes

April 2009

Some types of solid waste do not pose a threat to human health or the environment. Therefore, the disposal of these wastes is not regulated by the Solid Waste regulations. These exempted materials include:

• Dirt, rocks, and soil;

• Tree limbs, stumps, foliage, and other woody debris;

• Bricks, mortar, Portland cement type concrete (including reinforcing easily removed); steel that cannot be building pad, road b

• Waste rock from mining operations (as long as it does not generate environment);

• Some other types o

• Wood waste from tim n 10 cubic yards is areas and will not ca

The person disposing o with the following requirements:

a public nuisance, environmental problem or

• The waste may not ner.

• Crushed glass;

• Crushed asphalt, but only if the product is used as fill material in a ase, parking pad, or containment berm;

acid rock drainage, leach metals, or otherwise pose a risk to the f mining waste and tailings (contact DEC for more information); and ber operations if less tha disposed per year or it is used for roads, building pads, or parking use a violation of the water quality standards.

f exempt solid waste must ensure compliance

• The exempt waste may not be mixed with non-exempt waste.

• The waste may not cause a threat to public health, safety, or welfare.

• The waste may not be placed in surface water (creeks, ponds, etc.).

be placed without prior approval by the landow

Regulations Alaska Administrative Code, Title 18, Chapter 60, Section 005 (18 AAC 60.005) http://www.dec.state.ak.us/eh/sw