Alaska Department of Environmental Conservation RESPONSE TO COMMENTS
Goodnews Bay Landfill Permit Application
December 22, 2016

 

Background

On May 5, 2016, the Alaska Department of Environmental Conservation (ADEC) received a permit application from the City of Goodnews Bay for the Class III Landfill in Goodnews Bay, Alaska. Goodnews Bay is located at the mouth of the Goodnews River and the Goodnews Bay Landfill is located approximately 0.2 miles north of the village within Section 21, Township 12 South, Range 73 West, Seward Meridian.

The Goodnews Bay Landfill serves the residents of Goodnews Bay and has been in operation the 1990s. The landfill has never been permitted. The general population served by the landfill is approximately 267 people based on the 2015 Department of Commerce, Community and Economic Development Commissioner Certified Population count.

ADEC Class III Landfill Permit Application Process

A permit application including site information, landowner documentation, operations plan, and closure costs must be submitted to ADEC for approval. ADEC reviews the application and, if it is determined to be complete and describes an activity that complies with applicable regulations, public notice of the intent to issue the permit is posted in a local newspaper for two consecutive issues. A complete application includes all requirements of the ADEC application form, although additional clarification may be requested of the applicant during and after the public comment period. In addition, conditions may be included in the permit to clarify regulatory requirements, address substantive public comment, and address any operational deficiencies. Prior to issuing or denying a permit, ADEC reviews all public comments, performs necessary research, and develops responses to address any comments. If any comments have been received, at the time the permit is issued or denied, ADEC will issue a response to comments and a permit decision document that summarizes the decision criteria.

Opportunities for Public Participation

Notice of the permit application was posted in the Delta Discovery on November 9, 2016 and November 16, 2015. The public comment period ended on December 19, 2016. ADEC received one comment by email.

Responsiveness Summary

The commenter voiced concerns over the landfill site plan and two sections of the operations plan submitted by the City of Goodnews Bay. These concerns are summarized and addressed in this document. The commenter also requested that the City of Goodnews Bay revise its operations plan to address the comments and have the permit go to public notice again. A summary of ADEC’s evaluation of the permit application is included in a separate Decision Document.

Response to Comments

Comment 1. Regarding the landfill site plan, the commenter states: “the Permit Application section 5 Landfill Site Plan shows an area for "drums". The contents of the drums should be identified. If there is concern that they contain hazardous waste, they should be tested and properly disposed as such.”

ADEC Response to Comment 1: Having a designated disposal area for empty drums is an acceptable practice. The City of Goodnews Bay will have to abide by the specific conditions listed below and ensure that only empty drums are accepted at the landfill. ADEC Specific Permit Conditions to Address Liquid Waste and Hazardous Waste 2. Prohibit disposal of medical waste, asbestos containing materials, used oil, oily waste, polluted soil, hazardous waste, lead-acid batteries, polychlorinated biphenyls (PCBs), and septage or sewage solids. 3. Prohibit the disposal of bulk liquids in the landfill. Only containers that hold a volume of one gallon or less of liquid waste generated from households may be disposed.

Comment 2. Regarding section 4 of the operations plan, the commenter states: “section 4 regarding leachate seeps, the response is inadequate; apparently a plan to address this issue is needed.”

ADEC Response to Comment 2: When submitting an operations plan with a Class III Community Landfill Permit application for an existing landfill, the ADEC Solid Waste Program asks the applicant to fill in the operations plan to reflect their current operations. Any deficient operations identified in the operations plan are
addressed through specific conditions in the permit, as provided for by 18 AAC 60.215(b). We assess compliance with stipulations through subsequent inspections, where we will provide assistance in making needed improvements. ADEC has included Specific Permit Conditions in the permit to address the issue of leachate. These conditions are meant to both require landfill operations practices that will minimize leachate production, and what to do if leachate is identified. These specific conditions are as follows: 8. Maintain a designated working face (dumping area) at the landfill. Consolidate and compact waste regularly to keep the working face manageable and reduce infiltration of water. 9. Cover waste with a minimum of 6 inches of soil at regular intervals as needed to control attraction of wild and domestic animals, windblown litter, fire, and odor. Cover any areas that do not receive waste for 90 days with at least 12 inches of soil material. Grade cover to prevent water from ponding. 11. Do not dispose of waste in water. Remove any waste that is disposed in water and place it at the working face, or an appropriate dry area. Work to grade the surfaces of the landfill so water does not create ponds. 12. If any leachate seeps are observed, the City of Scammon Bay must contact the ADEC Solid Waste Program for instructions on remediation. 13. All snow must be removed from the disposal area before the spring thaw. Snow removed from the disposal area must be stored in an area that will prevent the melting snow from coming in contact with waste. Litter that remains after the snow melts must be picked up and properly disposed.

Comment 3. Regarding section 5 of the operations plan, the commenter states: “section 5 Special Waste Management - sections which appear to be in need of development of plans and procedures include: household hazardous waste, liquid waste, and used oil.” Commenter also states “section 5 identifies the use of used oil in "steams" appears to refer to a potentially inappropriate practice of using used oil in boilers for heating. If used oil is planned for burning it should be tested to ensure it is not hazardous waste; it should not be burned if it is hazardous waste. This appears to identify an appropriate practice; the community should be notified that burning used oil may be inappropriate.”

ADEC Response to Comment 3: ADEC has addressed the issues posed in Comment 3 through specific conditions in the permit as necessary for these waste streams. Overall, Section 5 of the operations plan asks the applicant to “Please describe the procedures you use for handling and disposing of the following wastes. If you do not accept a type of waste, explain how you keep it out of the landfill.” In many cases, the responses provided by the applicant in the permit application were insufficiently vague, and as such, ADEC has addressed these issues through specific conditions.The following include the various waste streams, how they are addressed in the Operations Plan portion of the permit application, and the specific permit conditions. a. Household Hazardous Waste (HHW) Management Operations Plan - Section 5 (Special Waste Management): Household Hazardous Waste (HHW) Applicant Answer: “Only lead acid batteries are segregated.” ADEC Specific Permit Conditions to address HHW: 4. Separate special wastes such as electronics, lead-acid batteries, and fluorescent bulbs from normal household waste and store them in an enclosed area so that they will not be damaged. When possible, transport these wastes out of the community to proper recycling/disposal facilities. 7. Remove household hazardous waste, ammunition, gas canisters, large metals, large plastic or rubber items, and any other materials that might cause a hazard or black smoke, prior to lighting the burn box. b. Liquid Waste Management Operations Plan - Section 5 (Special Waste Management): Liquid Waste (greater than 1 gallon) Applicant Answer: “Liquid waste are not restricted. No signs letting residents know of policy.” ADEC Specific Permit Condition to Address Liquid Waste 3. Prohibit the disposal of bulk liquids in the landfill. Only containers that hold a volume of one gallon or less of liquid waste generated from households may be disposed. Additional Information: The ADEC Solid Waste Program provides technical assistance to all solid waste facilities. This includes options for reusing, storing, and alternative disposal options for liquid wastes. c. Used Oil Management Operations Plan - Section 5 (Special Waste Management): Used Oil Applicant Answer: “Used oil is used by community for steams.” ADEC Specific Permit Condition to Address Used Oil 2. Prohibit disposal of medical waste, asbestos containing materials, used oil, oily waste, polluted soil, hazardous waste, lead-acid batteries, and polychlorinated biphenyls (PCBs). Additional Information: The ADEC Solid Waste Program does not regulate households’ reuse of used oil.

Comment 4. The commenter asked “Please request the City of Goodnews Bay to address these comments in a revised application/operations packet and make available for public comments again.”

ADEC Response to Comment 4: The operations plan submitted with a Class III Community Landfill Permit application for an existing facility need only reflect current operations. Since any deficiencies identified in the operations plan are addressed through specific permit conditions, the ADEC Solid Waste Program will not request the City of Goodnews Bay to revise and resubmit its application for public comment.

 

From: Thomas Price <This email address is being protected from spambots. You need JavaScript enabled to view it.>
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