draft materials management plan - summitcountyco.gov

Draft Materials Management Plan

Summit County Resource Allocation Park 639 Landfill Road Dillon, CO 80435 970-468-9263

6161 S. Syracuse Way, Ste. 210 Greenwood Village, CO 80111

303-221-1719

27215011.04 Task 00017 | March 19, 2019

Materials Management Plan www.scsengineers.com Page i

Table of Contents

Introduction ........................................................................................................................................ 1

Site Information and Background ..................................................................................................... 3

2.1 LOCATION AND LEGAL DESCRIPTION ......................................................................................... 3

2.1 GENERAL DESCRIPTION OF SITE AND IMPROVEMENTS .......................................................... 3

2.1 GENERAL SITE HISTORY .............................................................................................................. 3

2.3 POTENTIAL CONTAMINANTS PRESENT AT THE SITE ................................................................. 7

2.3.1Asbestos Containing Materials ....................................................................................... 7

2.3.2Asbestos Contaminated Soil ........................................................................................... 7

2.3.3Fuels/Petroleum Contaminated Soil .............................................................................. 7

2.3.4Metals/Pesticides/Herbicides Contaminated Soil ........................................................ 8

2.3.5Solvent Contaminated Soil ............................................................................................. 8

2.3.6Waste Tires ...................................................................................................................... 8

Description of Planned Soil-Disturbing Activities ............................................................................. 9

3.1 SCOPE OF WORK ......................................................................................................................... 9

3.1 HEALTH AND SAFETY PLANS ...................................................................................................... 9

Training Requirements.................................................................................................................... 11

Waste Characterization and Disposal ............................................................................................ 12

5.1 EXCAVATION AND INITIAL FIELD SCREENING ......................................................................... 12

5.2 WASTE CHARACTERIZATION .................................................................................................... 13

5.3 SOIL CHARACTERIZATION ........................................................................................................ 13

5.4 WASTE DISPOSAL ..................................................................................................................... 14

5.4.1Solid Waste ................................................................................................................... 14

5.4.2Hazardous Wastes ....................................................................................................... 14

5.4.3Universal Wastes .......................................................................................................... 15

5.4.4Non-Hazardous/Solid Wastes ...................................................................................... 15

5.5 POST EXCAVATION CONFIRMATORY SOIL SAMPLING AND ANALYSIS .................................. 16

Reporting ......................................................................................................................................... 17

References ....................................................................................................................................... 18

Figures Figure 1 – Site Location Map Figure 2 – Site Plan Map Appendices Appendix A Set of Construction Drawings

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Materials Management Plan www.scsengineers.com Page ii

Table of Contents

Appendix B Waste Acceptance Protocol (update)


Materials Management Plan www.scsengineers.com Page 1

INTRODUCTION The Summit County Resource Allocation Park facility (SCRAP) is located approximately 6 miles east of Interstate 70 in Dillon, Colorado. Access to the site is located off of Landfill Road. The permitted Landfill comprises approximately 465.8 acres where municipal waste disposal has been conducted on 87 acres and is located in Section 15, 16, and 22 of Township 05S, Range 77W of the 6th Principal Meridian. The location of the solid waste disposal site is shown on Figure 1, and the layout of the landfill is shown on Figure 2.

This Materials Management Plan (MMP) document is provided as an addendum to the Engineering, Design, and Operation Plan (EDOP) update (SCS, October 26, 2018), approved by the Colorado Department of Public Health and Environment (CDPHE) on November 15, 2018. The EDOP specifies general construction plans and specifications. Detailed design and specifications (March 2019) provide details of the Fill Area (FA)-III sump rehabilitation (2 options) and FA IV Phases 4 and 5 construction to be conducted between May and December 2019 (Appendix A). The FA IV details will include three options for non-contact groundwater interception.

The construction of the FA III temporary sump will include interception of pre-1979 waste in lined FA- III cell (clay and GCL); FA VII pre-1979 waste (no liner); and FA IV intermediate Sump IV installation and one of the groundwater options is expected to intercept unlined pre-1979 waste located to the east of FA IV. Prior to 1979, waste was not screened for hazardous substances, thus hazardous or toxic substances may be encountered in the waste itself. The purpose of this document is to outline how to identify and manage this historical municipal solid waste and potentially contaminated materials encountered during field activities; in particular historical (pre-1979) municipal solid waste, construction and debris (C&D) waste, impacted soil, and other materials such as asbestos containing materials (ACM) that may be encountered. At this time, SCRAP assumes that the materials to be encountered will be generally municipal solid waste.

This Materials Management Plan has been developed following the guidelines provided in the Colorado Department of Public Health and Environment (CDPHE) Interim Final Policy and Guidance on Management of Investigation Derived Wastes (IDW) at RCRA Facilities. Additionally, the U.S. EPA guidance, including the Guide to Management of Investigation-Derived Wastes (January 1992) and the Science and Ecosystem Support Division (SESD) Operating Procedure for Management of Investigation Derived Waste (July 2014), the CDPHE Materials Management Plan template found in the following web site address: (https://www.colorado.gov/pacific/cdphe/swguidance), and to some extent the Corrective Action Guidance Document (May 2002), Appendix 3 Management of Remediation Waste were used to develop the Materials Management Plan.

This MMP will also be used to guide the response actions to be taken if known or unknown bulk chemical containers and other wastes are encountered during site cleanup.



A Soil Characterization Management Plan (SCMP) will be developed separately and is expected to apply to portions of the site with suspect asbestos, if encountered. If asbestos wastes and asbestos contaminated soils are encountered, they will sampled and identified by an Asbestos Building Inspector and will be managed in accordance with the SCMP.

This MMP describes safe work practices to be used to address waste materials found at the site, including chemical contaminants. A site-specific Health and Safety Plan has been developed for the site and the construction companies will be required to provide health and safety documents for their activities. This MMP applies only to the wastes encountered during the construction activities as identified in the Plan and is not intended for use elsewhere.



SITE INFORMATION AND BACKGROUND

2.1 LOCATION AND LEGAL DESCRIPTION

The Summit County Resource Allocation Park facility (SCRAP) is located approximately 6 miles east of Interstate 70 in Dillon, Colorado. Access to the site is located off of Landfill Road. The permitted Landfill comprises approximately 465.8 acres where municipal waste disposal has been conducted on 87 acres and is located in Section 15, 16, and 22 of Township 05S, Range 77W of the 6th Principal Meridian. The only access to the site operations is Landfill Road, which enters the facility at the southeast corner of the site from State Highway 6. The legal description for the site as documented in the USFS Land Patent 05-94-0039 (USFS, 1990) is as follows: Sixth Principal Meridian, Colorado Township 05 South, Range 77 West Section 15, S ½ SW ¼, S ½ SW ¼ SE ¼ and SW ¼ SE ¼ SE ¼; Section 16, SE ¼; Section 22, lots 2, 3, 11, 13, N ½ NW ¼, N ½ SE ¼ NW ¼, and SW ¼ NE ¼ Containing 465.80 acres.

A site location map is provided in Figure 1.

2.1 GENERAL DESCRIPTION OF SITE AND IMPROVEMENTS

The site is currently permitted by CDPHE as a solid waste disposal facility under the Resource Conservation Recovery Act (RCRA). Currently Fill Area (FA) IV Phase 3 and FA III are the active disposal cells, but new construction of the FA IV Phases 4 and 5 will be conducted in 2019. The facility is also a permitted composting facility and provides compost for sale. A Materials Resource Management Facility (MRF) for recycled materials is also located at the facility. The facility also accepts household hazardous waste and electronic wastes and recycles, re-uses, or disposes of this waste appropriately. The location of site features and improvements is provided on Figure 2.

This document is an addendum to the Engineering, Design, and Operation Plan (EDOP) (SCS, October 26, 2018). The purpose of this document is to outline how to identify and manage contaminated materials encountered during field activities, in particular waste, construction and debris (C&D) waste, impacted soil, and asbestos containing materials (ACM).

2.1 GENERAL SITE HISTORY

SCRAP is owned and operated by Summit County. SCRAP has approximately 56.7 acres where municipal solid waste disposal has been conducted, and 465.80 total acres of permitted operations. The facility provides waste services to the County and surrounding area. The site has been reportedly operating as a permitted solid waste disposal facility since 1982.



The landfill property boundary encompasses approximately 465.80 acres, which is designated under the Certificate of Designation) under the CDPHE approved 2001 D&O Plan by KRW (KRW. 2001). Conceptual information was provided in the 2001 D&O Plan (KRW. 2001) and is included for long-term development of the entire site area (EDOP; SCS Engineers. October 26, 2018). Detailed design information is not provided, beyond Fill Area VII, because it is inevitable that significant technological and regulatory changes will occur (in the 20-plus years until these areas are developed) that could render the design obsolete. Although Summit County has been issued a Certificate of Designation for the entire approximately 465.8 -acre property, Summit County will not begin refuse filling operations in Fill Areas V, VI, or VIII through XIII without separate and satisfactory review and approval by CDPHE of specific engineering design and operations plans for these areas.

The active landfill is located north of Highway 6, in Section 15, 16, and 22 of T05S, R77W of the 6th Principal Meridian. A site location map is provided in Figure 1. The property boundary, operations areas, buildings, groundwater monitoring wells, water supply well, and roads are shown on Figure 2.

The EDOP update presents specific and detailed design and operational information for the revised design of already included Fill Area IV, Phases 4 through 9, and Fill Area VII (Phases 1 and 2).

Nearby surface water features include the Snake River located approximately 0.1 miles to the south, an ephemeral tributary that flows along the southern property boundary, and a mountainside ephemeral creek that sustains a marsh to the west of the active landfill. Located on the SCRAP property (site) are two stormwater impoundments and a Leachate Holding Pond.

The solid waste disposal site was previously owned by U.S. Forest Service (USFS) until June 29, 1994 at which time the land was granted to Summit County. Waste disposal at the site began in the 1960’s. The earliest landfill operations record recovered for this Plan is a 1966 Certificate of Designation (CD) by Summit County. Waste disposal “landfilling” began in natural depressions and shallow (generally less than 15 feet) excavations (Polhemus, 2000).

In 1979, White River National Forest prepared an environmental assessment report for the site (as reported in the DO&C Plan (Douglass, Heath, and others, 1984)). The first operations plan on record for the site was prepared by Downhill Pickup Company in 1982 (Liman and Schmidt, 1982). Downhill Pickup, Inc. operated the site under contract to Summit County from November 1, 1981 until the company was sold in 1984. Twin Landfill Corporation had operated the site under contract to Summit County from 1984 until 2004. SCRAP is currently owned and has been operated by Summit County since 2004.



Prior to 1984, liquid sludge was disposed of at the site in two unlined lagoons located in what is now identified as the closed Compost Area (Figure 2). The northern-most lagoon was filled with solid waste prior to 1984, but the southern lagoon was used for “emergency” disposal of liquid sewage sludge until at least 1983 (Douglass, Heath, and others, 1984). The southern lagoon was allegedly later filled with materials comprised primarily of shale fill to serve as a working area for compost operations (McElroy, 2000). Construction of a lined stormwater runoff pond for compost operations in the lagoon area confirmed that the southern sewage sludge lagoon was not filled with refuse. Test pits excavated during a site investigation confirmed that the northern-most lagoon was filled with solid waste. Sludge from the lagoon was reportedly spread on the surface of the pre-1979 landfill area (Liman, 2000).

In 1984, a landfill DO&C plan was prepared by Fox Consulting Engineers and Geologists (Douglass, Heath, and others, 1984). This landfill plan was based on subsurface exploration, sampling, and testing at the site conducted in 1983 and 1984. The landfill plan included provisions for waste placement in Fill Areas I through IV (Fill Area IV later becoming the Compost Area and Fill Area VII). All of the Fill Areas proposed in the Fox landfill DO&C Plan were to be unlined.

During excavation of Fill Area II in 1986, groundwater was encountered during the excavation. In order to facilitate ongoing solid waste disposal at the site while Fill Areas II and III were further investigated and redesigned, Amendment 1 to the 1984 landfill plan (White, 1986) was submitted to allow construction of two additional landfill areas (Fill Area V and Fill Area VI) in hard bedrock outcrops, south and west of the old Compost Area, respectively. Fill Area V and Fill Area VI were filled with solid waste from 1986 to 1992.

In 1986, an addendum to Amendment 1 was prepared and submitted in 1987 to CDPHE for approval (White, 1986). This addendum included operational information for compost operations at the site in the old Compost Area.

Fox Consultants prepared and submitted an expansion plan for the landfill in 1989 to CDPHE to include approximately 15.3 acres located approximately 1,500 feet northwest of Fill Area I. In 1989, the plan was revised to address CDPHE comments (White, 1989), but the revised plan was not resubmitted to CDPHE for review.

In 1990, a second amendment to the landfill plan (Amendment 2) was completed (White, 1990). This plan documented additional site exploration, primarily in Fill Areas II and III, and redesign of these fill areas to include liner and leachate collection systems. The designed liner system for these areas was a 2-foot clay liner. The leachate collection sump design called for a 2-foot clay liner overlain with a 60-mil HDPE liner. The leachate sump liner design was



changed in 1991 to replace the 60-mil HDPE with 36-mil Hypalon (White, 1991 and Buckingham, 1991). Fill Area II was filled with solid waste from 1992 to 1995.

In 1994, Summit County was granted a Land Patent from USFS for the current 465.80-acre site subject to the terms and conditions of Patent Number 05-94-0039 (USFS, 1990). The Patent prohibits landfill operations in wetland areas identified on the property, except for minimal disturbance for monitoring activities, and retains certain right-of-way rights access by the Department of Transportation and the Denver Water Board. The Patent specifies that the land will, “be used for solid waste disposal, expansion of the Summit County Landfill, or other authorized purposes of Summit County Government”. As recently reported, the location of the right-of-way for the Colorado Department of Transportation and the Denver Water Board was to be further investigated during the performance of a site boundary survey and illustrated on appropriate as-built construction drawings.

Between 1995 and 1997, and during construction of the liner for the first three phases of Fill Area III, it was necessary to add bentonite to the soil material to achieve the design permeability of the liner. Due to the high construction cost of the bentonite-amended soil liner, a design modification for use of a geosynthetic clay liner (GCL) was submitted to CDPHE and approved in 1998 (White, 1998 and Lujan, 1998). This design called for the placement of a single layer of GCL over a minimum 1-foot thick compacted clayey soil layer.

In 1996, a preliminary site assessment was performed by KRW, under contract to Twin Landfill Corporation the operator of the facility at the time, to identify future lateral expansion areas and landfill boundaries.

In 1999 and 2000, additional site assessment for landfill expansion was initiated by KRW under contract to Summit County. Along with historical data, this site assessment work forms the basis for the existing SCRAP landfill D&O Plan. Phase 1 and 2 were constructed with the compacted clay and CGL liner and solid waste was disposed of in these two phase areas. Phase 3 of Fill Area IV was similarly constructed in 2010 and is the current disposal area of solid waste at the landfill.

In 2018, an updated EDOP (SCS. October 26, 2018) was provided to CDPHE and approved on November 15, 2018 that included the design of FA IV Phases 4 and 5, and other upgrades. The construction drawings and specifications (Appendix A) provide the detail of the new cell construction and other upgrades.



2.3 POTENTIAL CONTAMINANTS PRESENT AT THE SITE

Based on previous inspections, potential wastes include, but are not limited to: municipal solid waste, drums of unknown origin, petroleum contaminated waste, animal carcasses, C&D waste, and friable and/or non-friable asbestos containing materials.

All potentially hazardous wastes or wastes of unknown origin will be assessed and segregated in the field in accordance with the Waste Acceptance Protocol (Protocol) (SCS. October 26, 2018). Acceptable wastes under the Protocol will be disposed of properly in the active landfill cells, either in FA III or FA IV, depending on where the wastes were encountered. These wastes can include municipal solid waste, C&D, non-friable ACM, and other acceptable solid waste. Wastes that don’t meet the waste acceptance criteria specified in the Protocol or unknown wastes will be labeled and easily-recognizable wastes will be segregated based on waste disposal requirements (for example, tires will be staged in two areas, while batteries will be staged in another). Unlabeled or unknown wastes will be staged in a separate area on a tarp and covered as appropriate for further assessment and characterization. When potentially regulated hazardous wastes are identified, they will be assessed in-place, as possible, for evidence of releases and their locations marked both in the field and on a scaled drawing. The surrounding/underlying media (soils as well as other wastes) will be assessed for impacts from releases of potentially regulated hazardous wastes.

If potentially contaminated soil is identified in an area with no nearby source containers, the potentially contaminated soil will be staged in a separate location for additional assessment described in Section 5.0.

2.3.1Asbestos Containing Materials

Any material found to contain more than 1% asbestos by weight or volume through polarized-light microscopy (PLM) analysis by a NVLAP-accredited (National Voluntary Lab Accreditation Program) laboratory is considered asbestos-containing material (ACM). ACM will be managed in accordance with the SCMP.

2.3.2Asbestos Contaminated Soil

Soil containing any visible asbestos-containing materials or detectable amounts of asbestos through PLM analysis by a NVLAP-accredited laboratory is considered asbestos-contaminated soil. Asbestos-contaminated soils will be managed in accordance with the SCMP.

2.3.3Fuels/Petroleum Contaminated Soil

Labeled and unlabeled containers of various fuels (gasoline, diesel, kerosene, etc.) and oils may be present. Petroleum contaminated soil (PCS) is defined in this plan as soil in contact with or otherwise impacted by wastes confirmed to be fuels. PCS determination may also be made based on laboratory analysis and field observations if fuel containers are not identified near the location of the petroleum contamination. Used oil may be contaminated with



solvents, PCBs, and metals. Petroleum contamination will be screened for in the field with a photoionization detector (PID) and a 4-gas meter (particularly for explosivity), and by evidence of staining and odors. Characterization for disposal will be performed as described in Section 5.0.

2.3.4Metals/Pesticides/Herbicides Contaminated Soil

Metals-contaminated soils may be encountered near leaking batteries, fluorescent lighting, appliances and electronics, or other sources. Pesticides and herbicides may be present in labeled or unlabeled containers. Field screening methods for pesticides, herbicides, and metals are more limited than for fuels or solvents, in part because the PID is not effective for most of these compounds. Field screening will still include visual and olfactory observations for evidence of releases. Characterization for disposal will be performed as described in Section 5.0.

2.3.5Solvent Contaminated Soil

Chlorinated and non-chlorinated solvents are possible wastes. Broad categories of solvent products include paint thinner, mineral spirits, degreaser, etc. Labeled solvents often list individual chemical components on the container. Solvents may also be mixed in with used oil. In general, solvent contamination can be screened for in the field with a PID and by evidence of staining and odors. Characterization for disposal will be performed as described in Sections 5.2 and 5.3.

2.3.6Waste Tires

Waste tires will be moved to the on-site Waste Tire Accumulation Area, inventoried, and transported off-site by a registered waste tire hauler.



DESCRIPTION OF PLANNED SOIL-DISTURBING ACTIVITIES

3.1 SCOPE OF WORK

The project’s goals are to:

- Remove all identified wastes - Properly dispose of these wastes at a permitted disposal site - Perform post-cleanup soil sampling and analysis

Potential soil-disturbing activities are generally limited to excavating soil and wastes from the disposal areas. After these wastes have been removed, additional excavation may be required to remove impacted soils. The site is managed in the following manner (Appendix A and Figure 2). Access is controlled with fencing and a gate that is locked after hours of operation. Access roads are graded and watered to reduce dust emissions. All patrons must pass by the scale house that is manned during operating hours and check in to the facility. Prior to starting cleanup, barriers and engineering controls such as temporary fencing will be installed surrounding the work area to control access and manage storm water runoff. Per State regulations, the contractor will obtain a CDPHE storm water permit if the project will impact more than one acre of land. Site dewatering during construction is not anticipated at this time. If site dewatering is necessary, SCRAP or SCS Engineers will obtain permits through the Water Quality Control Division. SCS Engineers will file air pollution emissions notices (APENs) with the Air Pollution Control Division if work at the site is expected to produce regulated air emissions.

3.1 HEALTH AND SAFETY PLANS

SCRAP has developed a site-specific Health and Safety Plan (HASP) for the site.

It is recommended that the contractor performing excavation have a site specific HASP for asbestos-contaminated soil and potential contaminants discussed in Section 2.3.

The HASP should also address applicable chemical contaminants, health effects, personal protective equipment (PPE), exposure monitoring, and any other specific issues that may require engineering controls.

Based on prior assessments, the work will start in Level D PPE, including hard hat, hard-toed shoes, and safety glasses (if deemed appropriate). If unexpected chemical containers are encountered, work will be stopped and work practices will be upgraded as appropriate.



Additional monitoring methods, engineering controls, and equipment (PPE) may be required prior to resuming work.



TRAINING REQUIREMENTS The Colorado Solid Waste Regulation 6 Code of Colorado Regulations (CCR) 1007-2 and OSHA Standard 29 Code of Federal Regulations (CFR) 1926.1101 outline training requirements and worker protection standards for activities that involve waste materials and asbestos. If hazardous wastes are encountered, an exclusion zone will be established and will include the excavation area and a 20-foot buffer around the excavation area. All personnel entering the exclusion zone must have current initial or refresher training per OSHA’s HAZWOPER standard (29 CFR 1910.120). Truck loading will occur within the decontamination zone, and truck drivers will not be required to have HAZWOPER training if they stay inside their cabs with windows up inside the decontamination zone. All personnel entering the exclusion zone will be adequately trained in the use of PPE, including the use of respirators. Any person using a respirator on site must have a current annual physical with a pulmonary function test, accompanied by a qualitative and/or quantitative fit test for their respirator. Asbestos training requirements are described in the SCMP.



WASTE CHARACTERIZATION AND DISPOSAL

5.1 EXCAVATION AND INITIAL FIELD SCREENING

For asbestos and regulated asbestos-contaminated soils, refer to the SCMP for asbestos management procedures.

Prior to beginning excavation, the property owner will designate an area near each site for short-term stockpiling of soils and wastes excavated from that site. The stockpile areas will be lined with 10-mil polyethylene sheeting, or equivalent. Each stockpile will be covered with 10-mil plastic sheeting, or equivalent, at the end of each workday.

An engineer or scientist from SCS Engineers will observe the excavation of each area and will direct the excavator to place waste materials into stockpiles or dumpsters for characterization. In addition, SCS Engineers will monitor the excavator bucket and ambient air for combustible gases using a combustible gas indicator (CGI). If greater than 10 percent of the lower explosive limit (LEL) is measured at any time, the work area will be evacuated and work practices will be re-evaluated. Work will not resume until the ambient air contains less than 10% of the LEL.

If labeled chemical containers or unlabeled suspect chemical containers are identified within the excavation, and/or if potentially contaminated soil is observed based on field screening, a multiple step assessment will be performed:

• SCS will assess containers, in-situ, the likely chemical content based on labeling, container type/shape, etc. Potentially contaminated soils will be assessed based on nearby chemical containers, if present, or based on field screening observations (see Section 2.0).

• SCS will use a PID and CGI to measure ambient air at (or as close as safely possible) the location for volatiles and combustible gases.

• The container or soil will be observed for crystallization or other evidence of reactively unstable materials. Reactively unstable materials are considered unlikely, but if present, they will not be moved until they can be chemically or physically stabilized.

• If the condition of a container can be assessed in place, will note the condition of the container, evidence of releases, etc. If a container appears to be actively leaking, it will not be removed until a suitable overpack container is available for containment.

• Will observe and document whether releases, if any, appear likely to have impacted soils or other wastes around or below the container. If a suspected release has occurred, the extent of the release will be assessed by excavating around and below the point of the release. Where contaminated soils are observed, it will be assumed that the soils have been impacted by containers located physically above or adjacent to the location of the observed contamination, regardless of the presence of visible leakage from each container.

• The location will be measured from a fixed reference point and plotted on a scaled drawing; if it is practical, the location will be marked in the field with flagging or stakes.



• SCS will take photograph(s) documenting the container location and general condition. • SCS will direct the excavator to place the waste material into a stockpile.

Stockpiles will be segregated based on general waste types, media, and waste disposal requirements (for example, PCS would be placed into a separate stockpile from soils excavated below a leaking drum of chlorinated solvent). The stockpile areas will be lined with 10-mil polyethylene sheeting, or equivalent. Each stockpile will be covered with 10-mil plastic sheeting or tarps (or equivalent) at the end of each workday that has been weighted to limit or prevent wastes from being blown away from the stockpile.

5.2 WASTE CHARACTERIZATION

Asbestos wastes and regulated asbestos-contaminated soils will be managed per the SCMP.

Chemical containers and other wastes found at the site will be characterized based on labeling, if present, observations of contents, and sampling and laboratory analysis. All necessary field-based characterization and laboratory analyses will be performed by the clean-up contractor and a qualified environmental laboratory. Containers will be assessed for content labeling. For labeled containers, the contents will be visually examined to verify that the content appears to match the labeling. If uncertain, the contents will be sampled with a drum thief or equivalent sampling device. Container samples will be submitted to a qualified environmental laboratory to be analyzed for hazardous waste characteristics such as toxicity characteristic leaching procedure (TCLP) analyses. The specific types of analyses will be selected based on the materials released, if known, or will include the full range of hazardous waste characteristics for unknown wastes. In general, likely analyses could include:

• Paint Filter • Ignitability • Corrosivity • Reactivity • TCLP Metals (8) • TCLP VOCs • TCLP SVOCs • TCLP Pesticides • TCLP Herbicides • Petroleum fingerprint analysis • Polychlorinated Biphenyls (PCBs) • Total Petroleum Hydrocarbons (TPH) – extended (gasoline and diesel) range; and/or • Oil and Grease

5.3 SOIL CHARACTERIZATION

Regulated asbestos-contaminated soils will be managed per the SCMP.



Potentially contaminated soils will be characterized for disposal based on field observations and the type of material released, and sampling and laboratory analysis. Excavated soils with staining or other visible impacts will be stockpiled separately on a layer of 10-mil poly sheet for additional characterization and disposal.

Composite soil samples will be collected at a rate of one 6-point composite sample per approximately 300 cubic yards of stockpiled soil or some other volume as required. Composite samples will be submitted to a qualified environmental laboratory to be analyzed for total contaminants and/or hazardous waste characteristics such as toxicity characteristic leaching procedure (TCLP) analyses. The specific types of analyses will be selected based on the materials released, if known, or will include the full range of hazardous waste characteristics for unknown wastes. In general, likely analyses could include:

• Paint Filter • Ignitability • Corrosivity • Reactivity • TCLP Metals (8) • TCLP Volatile Organic Compounds (VOCs) • TCLP Semivolatile Organic Compounds (SVOCs) • TCLP Pesticides • TCLP Herbicides • Polychlorinated Biphenyls (PCBs) • Total Petroleum Hydrocarbons (TPH) – extended (gasoline and diesel) range; and/or • Oil and Grease. • Or as specified in the SCRAP Waste Acceptance Protocol

SCS Engineers will evaluate soils contamination laboratory analyses results against the Colorado Department of Public Health and Environment’s current soils screening guidelines (CDPHE at www. https://www.colorado.gov/cdphe. Accessed March 22, 2019). Soils deemed to have contamination levels greater than the soil screening guidelines will be segregated for further profiling as necessary and disposal as solid waste or hazardous waste. Soils with analytical values less than the soil screening guidelines will be stockpiled for reuse.

5.4 WASTE DISPOSAL

5.4.1 Solid Waste

Municipal solid waste and other similar wastes accepted by SCRAP will be disposed of on-site in FA III or FA IV depending on the original location of the waste; or transported off-site to a licensed and approved solid waste disposal facility.

5.4.2 Hazardous Wastes

If hazardous wastes are identified at the disposal site, the contractor will obtain an EPA hazardous waste generator identification number from the Colorado Department of Public



Health and Environment on behalf of the property owner. Each waste stream will be profiled based on field observations and laboratory analyses. Upon approval of each waste stream profile, the cleanup-contractor will load each waste stream into an appropriate transport vehicle and haul to the approved offsite hazardous waste disposal facility for disposal. The clean-up contractor will comply with all applicable state and Federal regulations applying to transport and disposal.

Waste transporters include:

Household Hazardous Waste transporters and recyclers/disposal:

Veolia

Green Sheen

Hazardous Waste Transport and Disposal will be completed in consultation with the CDPHE.

5.4.3 Universal Wastes

The following hazardous wastes will be handled as universal wastes:

- Batteries - Electronic wastes - Lighting wastes

These will be profiled and transported to an approved recycler for the waste or to a permitted hazardous waste disposal site. Wastes will be transported by approved haulers for each waste type. Household Hazardous Waste transporters and recyclers/disposal:

Veolia

Green Sheen

Electronic Waste transporters and recyclers/disposal:

Electronic Recycling Incorporated (ERI)

5.4.4 E-Waste

Electronic waste encountered that is intact will be transported to the e-waste trailer for recycling.

5.4.5 Non-Hazardous/Solid Wastes

Based on field observations and/or laboratory analyses, waste materials that are not regulated as hazardous waste, such as tires, petroleum-contaminated soils, asbestos-contaminated wastes, or other municipal, agricultural, or industrial wastes, will be managed as solid waste. These solid wastes will be profiled, if required (as specified in the SCRAP



updated Waste Acceptance Protocol; SCS Engineers. October 26, 2019) as provided in Appendix B; and appropriately containerized or packaged and labeled if required, and disposed of on-site in the FA III or IV areas, or will be transported to an appropriate offsite permitted solid waste landfill for disposal. The contractor will follow all applicable state and federal regulations during transport, if required.

5.5 POST EXCAVATION CONFIRMATORY SOIL SAMPLING AND ANALYSIS

Construction activities will be conducted in former waste disposal areas and in native soils. When waste is removed from a former waste disposal area confirmation sampling is not necessary as long as the activity takes place within the footprint of the former waste disposal fill area. When all materials and impacted soils, if any, have been excavated from the site from areas outside of the former waste disposal fill areas, soil samples will be collected from the bottom and sidewalls of each excavation if the wastes extracted do not meet the definition of a solid waste (as provided in the updated SCRAP Waste Acceptance Protocol; Appendix B). Bottom samples will be collected along the length of the centerline of the excavation, at representative intervals. For sidewall samples, at least one soil sample will collected from each sidewall (north, south, east, and west); additional sidewall samples. Confirmatory soil samples will be analyzed, at a minimum, for the following total (not TCLP) constituents:

- Analytes specified in the Waste Acceptance Protocol (Appendix B) - Other parameters depending on the waste profile removed

If additional contaminants of concern are identified during field activities described previously, corresponding laboratory analyses will be added.



REPORTING A final report describing the actions taken to remove and dispose of wastes from the site will be provided to, as appropriate, to the Colorado Department of Public Health and Environment for review and approval, if warranted. The report may include, at a minimum:

- A written narrative of the actions taken to dispose of wastes encountered during construction at the site - Maps to scale of the site documenting areas of disturbance - Copies of photographs taken to document site cleanup - Copies of all laboratory sample analyses, including quality assurance/quality control samples.



REFERENCES

CDPHE. Undated. Materials Management Plan template. Accessed March 17 and 18, 2019. ( https://www.colorado.gov/pacific/cdphe/swguidance),

CDPHE. https://www.colorado.gov/cdphe. Accessed March 22, 2019.

Douglass, D.A., Heath, R.A., Gwilym, R.D., Reardon, M.W., and White, K.R., 1984. Summit County Landfill Design and Operation Plan: Fox Consulting Engineers and Geologists 21184.0.

Liman, L., 2000. KRW Personal Communication with Les Liman.

Liman, L.A., and Schmidt, W., 1982. Operating Plan for Summit County Landfill: Downhill Pickup Company.

Lujan, B., 1998. Summit County Landfill Liner Design Request, dated March 11, 1998: Colorado Department of Public Health and Environment, Hazardous Materials and Waste Management Division.

Polhemus, J., 2000. KRW personal communication.

SCS Engineers. October 26, 2018. EDOP Update. Approved by CDPHE November 15, 2018.

SCS Engineers. October 26, 2018.Waste Acceptance Protocol (update). Approved by CDPHE November 15, 2018.

USFS, 1990. Land Patent Transfer 05-94-0039: U.S. Forest Service.

White, K.R., 1986. Summit County Landfill Design and Operation Plan Amendment 1: Fox Consultants, Inc.

White, K.R., 1989. Revisions to the Expansion Plan, Summit County.

White, K.R., 1990. Amendment 2 Revisions to the Expansion Plan, Summit County.

White, K.R., 1998. Summit County Landfill Liner Design Change Request: KRW Consulting, Inc.

White, K.R. and Douglass, D.A., 2001. Landfill Design, Operations, and Closure Plan for Summit County Landfill, KRW Consulting, Inc. 9905-02, October 6, 2000, Revised April 20, 2001.


https://www.colorado.gov/cdphe


White, K.R., 2003. Summit County Landfill Groundwater Statistics Report for Samples Collected November 2002: KRW Consulting, Inc. 9905-02, January 30, 2003.


Figures

Figure 1 – Site Location Map

Figure 2 – Site Plan Map

Appendix A

Construction Drawing Set

Appendix B Waste Analysis protocol (updated)

draft materials management plan - summitcountyco.gov

Documents