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Page 1: Monthly progress rpts (6/1999-12/1999) · 2016-12-20 · NOV/Order CWA-309-9-99-14 As required by the above referenced order, specifically VI number 3 (page 9 of 22) the following

SDMSDocID 2010532

Page 2: Monthly progress rpts (6/1999-12/1999) · 2016-12-20 · NOV/Order CWA-309-9-99-14 As required by the above referenced order, specifically VI number 3 (page 9 of 22) the following

POOR LEGIBILITY

ONE OR MORE PAGES IN THIS DOCUMENT ARE DIFFICULT TO READDUE TO THE QUALITY OF THE ORIGINAL

Page 3: Monthly progress rpts (6/1999-12/1999) · 2016-12-20 · NOV/Order CWA-309-9-99-14 As required by the above referenced order, specifically VI number 3 (page 9 of 22) the following

June 9,1999

Ms. Susanna Trujillo, Project CoordinatorU.S. EPA Region IX75 Hawthorne Street (WST-7)San Francisco, CA 94105-3901

Certified-Return ReceiptRequested

I If

Dear Ms. Jrujiilo:

RE: Monthly Progress Report - June, 1999Order RCRA 7003-09-99-0005NOV/Order CWA-309-9-99-14

As required by the above referenced order, specifically VI number 3 (page 9 of 22) the followingis the first monthly pi ogress report:

1. The parties a^e meeting with BLM on June 9 for finalization of access agreement for off-lease areas,

2. Item b. 1 .(a-h) "Landfill Assessment Work Plan," was completed and delivered to F,PAand BLM on June 7, 1999.

3. Republic DUMPCo is in the process of identifying qualified contractors to complete thework outlined in the Assessment Work Plan.

4. Submittals for CWA Order Task #19,20, and 21 are on schedule.

If you have any questions, please contact Alan Gaddy at (702) 734-5400.

Respectfully,

Vice Pres:

Steve Wall - Technical CoordinatorMike Moran - Bureau I and ManagementJohn Schlegel - CCCPClare Schmutz - CCHDDave Emme - NDEP

770 East Sahara Avenue • P.O. Box 98508 • Las Vegas, Nevada 89193-8508 • Telephone 735-5151 • Fax (702) 735-1986

j MADE WITH RECYCLED PAPER

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July 14, 1999

Ms. Susanna Trujillo, Project CoordinatorU.S. EPA Region IX75 Hawthorne Street (WST-7)San Francisco, CA 94105-3901

Dear Ms. Trujillo:

RE: Monthly Progress Report - July, 1999Order RCRA 7003-09-99-0005NOV/Order CWA-3 09-9-99-14

As required by the above referenced RCRA Order, specifically VI number 3 (page 9 of 22), thefollowing is the monthly progress report1

1. Tentative agreements have been reached on the access agreement for off-lease areas.2. RCRA Order Item b.l.(a-h) "Landfill Assessment Work Plan," wan completed and

delivered to EPA and BLM on June 7,1999.3. CWA Order Task #19, 20, and 21 were competed and delivered to EPA and BLM on

June 11, 1999.4. DUMPCo is in the progress cf selecting contractors for work at the Sunrise Landfill.5. On July 8, 1999, the Las Vegas Valley experienced a 100 year storm event. Immediately

following the storm event, DUMPCo inspected the impact. DUMPCo estimated thatapproximately 3 cubic yards of trash was released. DUMPCO notified the NevadaDivision of Environmental Protection of the release on July 9,1999, and was given arelease number of 990709-01.

6. A written report will be completed within 10 days of July 9,1999.7. DUMPCo is in the process of repairing the impact caused by the storm event.

If you have any questions, please contact Alan Gaddy at (702) 734-5400.

AlanVice

CC: Steve Wall - Technical CoordinatorMike Moran - Bureau Land ManagementJohn Schlegel - CCCP

770 East Sahara Avenue • P.O. Box 98508 • Las Vegas, Nevada 89193-8508 • Telephone 735-5151 • Fax (702) 735-1986

B MADE WITH RECYCLED PAPER

Page 5: Monthly progress rpts (6/1999-12/1999) · 2016-12-20 · NOV/Order CWA-309-9-99-14 As required by the above referenced order, specifically VI number 3 (page 9 of 22) the following

August 12, 1999

Ms. Susanna Trujillo, Project CoordinatorU.S. EPA Region IX75 Hawthorne Street (WST-7)San Francisco, CA 94105-3901

Dear Ms. Trujillo:

RE: Monthly Progress Report - August, 1999Order RCRA 7003-09-99-0005NOV/Order CWA-309-9-99-14

As required by the above referenced RCRA Order, specifically VI number 3 (page 9 of 22), the following isthe monthly progress report:

1. Agreement .has been reached on the access of off-lease areas.2. RCRA Order Item b. 1 .(a-h) "Landfill Assessment Work Plan," was completed and delivered to EPA

and BLM on June 7, 1999.3. EPA's August 2, 1999 comments on the "Work Plan" have been received and reviewed. Based on

these comments, Republic DUMPCo (DUMPCo) is requesting an extension for the submittal of therevised work plan from August 16, 1999 to August 25, 1999.

4. DUMPCo has completed the consultant selection process for the RCRA Work Plan assessmentwork.

5. CWA Order Task # 19, 20, and 21 were competed and delivered to EPA and BLM on June 11,1999.6. On July 16, 1999, DUMPCo submitted to EPA a Sunrise Landfill Release Report that described the

impacts associated with the July 8, 1999, storm event. This report also included a request toimplement immediate interim measures to prevent further impacts.

7. In a letter dated August 6, 1999, DUMPCo responded to EPA's comments regarding interimstormwater control measures. DUMPCo is implementing these measures as outlined in the letter.

8. DUMPCo expects to complete the consultant selection for the stormwater portion by August 18,1999.

770 East Sahara Avenue • P.O. Box 98508 • Las Vegas, Nevada 89193-8508 • Telephone 735-5151 • Fax (702) 735-1986

MADE WITH RECYCLED PAPER

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Page 2August Monthly Progress ReportAugust 12,1999

DUMPCo continues to be committed to promptly responding and implementing those actions required byEPA. Without waiting for work plan approval, DUMPCo has nearly completed the consultant selectionprocess. Once these work plans are approved, DUMPCo will be ready to respond.

If you have any questions, please contact Alan Gaddy at (702) 734-5400.

Respe

Vice Pre:

CC: Mr. Mike Dweyer, Field Manager(Attention: Mike Moran)Bureau of Land Management4765 Vegas DriveLas Vegas, NV 89108

Mr. John SchlegelClark County Comprehensive Planning500 S. Grand Central Pky.Las Vegas, NV 89155-1741

Mr. Dave Emme, ChiefBureau of Waste ManagementNevada Division of Environmental Protection333 W. Nye Lane, Room 138Carson City, Nevada 89706-0851

Mr. Steve JohnsonPHB Hagler Bailly100 Hamilton Ave., Ste 200Palo Alto, CA 94301

Mr. Clare SchmutzClark County Health District625 Shadow LaneLas Vegas, NV 89106

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llrfem

September 14, 1999

Ms. Susanna Trujillo, Project CoordinatorU.S. EPA Region IX75 Hawthorne Street (WST-7)San Francisco, CA 94105-3901

Dear Ms. Trujillo:

RE: Monthly Progress Report - September 1999Order RCRA 7003-09-99-0005NOV/Order CWA-309-9-99-14

As required by the above referenced RCRA Order, specifically VI number 3 (page 9 of 22), thefollowing is the monthly progress report: It should be rioted that, at the request of EPA, themonthly progress report format has changed. There will now be two sections: The CurrentMonthly Progress Report section, followed by the Monthly Progress Report Summary section.In the future, the first three letters of the month will p^eeeed-the report item number to identifywhich progress report they were contained in, as identified below:

Section I: Current Monthly Progress Report

Sep.l: A hydrology and hydraulic study was submitted to EPA for approval on August 30, 1999,for the Eastern portion of the landfill as part of DUMPCo's August 8, 1999, (E.5 & E.6)response to EPA's comments on the DUMPCo's Interim Stormwater Measures. Usingthe data obtained from the hydrology and hydraulic study, preliminary design conceptsare proposed for blasting the drop off channel and re-armoring the western slope of thelandfill. That area has been impacted in past storm events. After approval of thisapproach, DUMPCo will provide EPA with proposed construction drawings for thesecontrol measures.

Sep.2: As requested by Clark County Public Works (CCPW), final construction drawings for theprotection of the Construction Debris Cell were delivered to CCPW on September 8,1999, for their final approval and bonding.

Sep.3: DUMPCo expects to begin placing concrete around the down drains, as specified in theAugust 6,1999, response to EPA's comments on the Interim Plan, by the end ofSeptember.

Sep.4: On August 25, 1999, SCS Engineers submitted, on the behalf of DUMPCo, a revisedWork Plan as required by EPA's August 17,1999 approval of DUMPCo's extensionrequest.

770 East Sahara Avenue • P.O. Box 98508 • Las Vegas, Nevada 89193-8508 • Telephone 735-5151 • Fax (702) 735-1986

1 MADE WITH RECYCLED PAPER

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Page 2September Progress Report

Sep.5: EPA provided DUMPCo with some general comments regarding the revised Work Plan.DUMPCo is in the process of clarifying some the text based on EPA's comments.However, two possible points of misunderstanding were identified: The InducedPolarization (IP) method includes resistivity (See page 9,3.4.1.5), and DUMPCo does notfeel that it is appropriate to restate objectives in the Sampling and Analysis Plan (SAP).The SAP is designed to describe methods.

Sep.6: DUMPCo will be providing EPA with a list of contractors and summaries ofqualifications of the consultants and primary contractors for the Sunrise Landfill work.DUMPCo is in the process of selecting the geoprobe contractor and soils laboratory(s).The approval letter should be ready by the end of September.

Sep.7: After evaluating the Trimble Geo Explorer II and associated software, DUMPCo hasdecided to purchase the unit. The evaluation determined that while the unit does notprovide field personnel with accurate locations, once the data has been corrected with thesoftware, valuable location information can obtained.

Sep.8: DUMPCo has been proceeding with surficial stormwater control work, see the attachedsummary. A detailed report of these repairs will be provided, including pictures.

Sep.9: DUMPCo is in the process of evaluating the GC Wallace, Inc. "Conceptual DrainageAnalysis For The Sunrise Mountain Landfill East Channel," dated August 1999, preparedfor Clark County Department of Public Works. A copy of the report has been forwardedto EPA.

Section 2: Monthly Progress Report Review Summary:

1. Tentative agreements have been reached on the access agreement for off-lease areas.2. RCRA Order Item b. 1 .(a-h) "Landfill Assessment Work Plan," was completed and

delivered to EPA and BLM on June 7, 1999.3. CWA Order Task #19, 20, and 21 were competed and delivered to EPA and BLM on

June 11, 1999.4. On July 16,1999, DUMPCo submitted to EPA a Sunrise Landfill Release Report that

described the impacts associated with the July 8,1999 storm event. This report alsoincluded a request to implement interim emergency measures to prevent further impacts.

5. EPA's August 2,1999, comments on the "Work Plan" have been received and reviewed.Based on these comments, Republic DUMPCo (DUMPCo) requested an extensionfor the submittal of the revised work plan from August 16,1999 to August 25,1999.

6. DUMPCo completed the consultant selection process for the RCRA Work Planassessment work.

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Page3September Progress Report

7. In a letter dated August 6, 1999, DUMPCo responded to EPA's comments regardinginterim stormwater control measures. DUMPCo is implementing these measures asoutlined in the letter.

If you have any questions, please contact me at (702) 734-5400.

Respectfully,

Alail GaddVice President

Attachments: Stormwater Surficial Repair List and Map

CC: Mr. David B asinger (WTR - 7) Water DivisionU.S. Environmental Protection Agency75 Hawthorne StreetSan Francisco, CA 94105 - 3901

Mr. Mike Dwyer, Field Manager(Attention: Mike Moran)Bureau of Land Management4765 Vegas Valley DriveLas Vegas, NV 89108

Mr. Dave Emme, ChiefBureau of Waste ManagementNevada Division of Environmental Protection333 W. Nye Lane, Room 138Carson City, NV 89706-0851

Mr. Steve JohnsonPHBHaglerBailly100 Hamilton Ave., Ste 200Palo Alto, CA 94301

Mr. Clare SchmutzClark County Health District625 Shadow LaneLas Vegas, NV 89106

Page 10: Monthly progress rpts (6/1999-12/1999) · 2016-12-20 · NOV/Order CWA-309-9-99-14 As required by the above referenced order, specifically VI number 3 (page 9 of 22) the following

Repairs Sunrise Landfill As of September 9,19991. The main road on the west face leading to the top deck of the Landfill has been re-

graded and is pitched to allow stormwater to run within the roadway, as opposed toalong side of the road over cover of waste.

2. The culverts have been removed west of the medical disposal area that led to thesediment basin. The sediment basin now discharges smoothly through the smallchannels with no waste below the channel.

3. The headwall of both the top deck southeast and southwest corner down drains isready for concrete.

4. Two (2) additional culverts have been placed on the east face of the top deckdischarging into the east main drainage channel. The headwall of the two culverts isready for concrete.

5. The east main drainage channel has been recovered with 12 to 18 inches of dirt fromthe gabion structure north to the mouth of the channel.

6. The piles of dirt have been depleted from on the top deck of the landfill. That dirtwas removed during clean out of the east main drainage channel.

7. Only four (4) piles of riprap rock remain on the top deck area of the landfill.8. The main road on the south face of the upper deck has been re-graded and is pitched

to allow stormwater to run within the roadway, as opposed to along side of the roadover cover of waste.

9. The south face road and the southwest down drain now lead to a partially constructedsediment basin. The basin is not over waste and is shaped and ready for engineeringdetail.

10. The south flats have three (3) new wing berms leading to culverts that drainstormwater from the landfill at the southern boundary.

11. The headwall for each of the three new culverts on the southern flats is ready forconcrete.

12. The water pull road leading to the wastewater treatment facility is pitched andproperly graded to allow stormwater to run within the roadway, as opposed to alongside of the road over cover of waste.

13. The rills near the animal disposal area have been filled in and re-graded.14. A new wing berm has been installed on the east side of the medical waste deck that

drains water to the north and south into two new culverts.15. The headwall of the new medical waste drainage culvert is ready for concrete.16. The culverts on the west side of the medical waste deck have been removed. The

culvert grooves have been filled in and the deck has been re-graded.17. The drainage on the north side of the asbestos area has been improved using a new

road. The road is properly pitched to allow stormwater to run within the roadway, asopposed to within culverts that have been overtopped causing water to run into theasbestos disposal area.

18. The cover has been restored to the waste cell adjacent to the east main drainagechannel drop structure. This is the cell that released waste during the July stormevent. This portion of the drainage channel is been proposed to be blasted to correctthe angle of the channel. The blasted material will be used to armor the waste cell.

19. The construction debris cell armor is undergoing final County approval of designplans. Following approval, a bond will be secured with installation expected to beginby the end of September.

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Page 12: Monthly progress rpts (6/1999-12/1999) · 2016-12-20 · NOV/Order CWA-309-9-99-14 As required by the above referenced order, specifically VI number 3 (page 9 of 22) the following

October 14,1999

Ms. Susanna Trujillo, Project CoordinatorU.S. EPA Region IX75 Hawthorne Street (WST-7)San Francisco, CA 94105-3901

Dear Ms. Trujillo:

RE: Monthly Progress Report - October, 1999Order RCRA 7003-09-99-0005NOV/Order CWA-3 09-9-99-14

As required by the above referenced RCRA Order, specifically VI number 3 (page 9 of 22), thefollowing is the monthly progress report: The report contains two sections, the Current MonthlyProgress Report section, followed by the Monthly Progress Report Summary section. Theprogress report items are numbered with the first three letters of the month of the report that theitem appeared. October's Items are:

Section I: Current Monthly Progress Report

Oct. 1: EPA has verbally approved moving forward with providing EPA with constructiondrawings and specifications for blasting the south end of the Eastern Bypass channel, andarmoring of landfill cell below the drop off structure. However, EPA made it clear thatthis structural modification may not be the final solution to the drainage in this area. (SeeInterim Action Report).

Oct.2: DUMPCo has received final approval for armoring the Construction Demolition Cell andDUMPCo is proceeding to construct. See Interim Action Report.

Oct.3: DUMPCo will place concrete around the down drains during the armoring of theConstruction demolition cell.

Oct.4: In a correspondence dated September 29,1999, DUMPCo submitted to EPA a list ofcontractors, consultants, and laboratories for review and approval. DUMPCo requests toadd an additional company to this list: Atlas Chemical Testing Laboratories. A companyprofile is enclosed with this monthly progress report.

770 East Sahara Avenue • P.O. Box 98508 • Las Vegas, Nevada 89193-8508 • Telephone 735-5151 • Fax (702) 735-1986

§ MADE WITH RECYCLED FWPER

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Page 2October Progress Report

Oct.5. As indicated in the October 7,1999 teleconference, DUMPCo is evaluating the mostappropriate method(s) that should be used to determine soil loss from erosion. After aninitial review, it seems that there may be a problem with past reports that indicate that thecover at Sunrise contains high concentrations of gypsum. After a review of the EMCONexpansion report and Dynamac's report, there does not seem to be any formal analyticalresults to support comments made in those reports. DUMPCo has identified a localchemical testing laboratory that has the ability to test for these parameters. DUMPCowill provide EPA with the results of this evaluation.

Oct.6: DUMPCo has indicated to EPA that there may not be enough available cover material atthe Landfill site to respond to the corrective actions that will be identified in the RCRAWork Plan and CWA AO. DUMPCo has proposed to locate small crushing plant on sitein order to make cover dirt. EPA has responded by requesting specifications on thematerial and product that will be used as cover. DUMPCo is currently evaluating anumber of different specifications, and has obtained a sample of the source material. Thissample will be analyzed to determine it's chemical composition. However, until theappropriate models can be established, DUMPCo is unable to provide EPA with theproposed cover material specifications. DUMPCo is evaluating this, and in the interim,submits an Alternative Cover Evaluation that was completed in Glendale, Arizona forEPA review.

Oct.7: On August 31, 1999, Harding Lawson Associates conducted perimeter landfill gasmonitoring at the Sunrise Landfill. No detectable levels of landfill gas was detected atthe perimeter of the Sunrise Landfill. (See the attached HLA report)

Oct 8: CWA Task #20 - Interim Plan now contains an Appendix A entitled: Interim ActionReport (IAR). Republic DUMPCo is requesting approval of these actions as InterimActions. This report will be updated to finalize the document once all actions arecomplete.

Oct 9: Republic DUMPCo has ordered a Geoexplorer II. However, Trimble has discontinuedmanufacturing this unit and has no more in stock. Republic DUMPCo is on the waitinglist for a Geoexplorer III. Republic DUMPCo will update these Interim Actions as soonas the unit is received, the software is installed and the unit is calibrated for the Sunrisesite.

Section 2: Monthly Progress Report Review Summary:

1. Tentative agreements have been reached on the access agreement for off-lease areas.2. RCRA Order Item b. 1 .(a-h) "Landfill Assessment Work Plan," was completed and

delivered to EPA and BLM on June 7,1999.3. CWA Order Task #19, 20, and 21 were competed and delivered to EPA and BLM on

June 11,1999.4. On July 16, 1999, DUMPCo submitted to EPA a Sunrise Landfill Release Report that

described the impacts associated with the July 8,1999 storm event. This report alsoincluded a request to implement interim emergency measures to prevent further impacts.

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Page 3October Progress Report

5. EPA's August 2,1999, comments on the "Work Plan" have been received and reviewed.Based on these comments, Republic DUMPCo (DUMPCo) requested an extensionfor the submittal of the revised work plan from August 16, 1999 to August 25, 1999.

6. DUMPCo completed the consultant selection process for the RCRA Work Planassessment work.

7. In a letter dated August 6, 1999, DUMPCo responded to EPA's comments regardinginterim stormwater control measures. DUMPCo is implementing these measures asoutlined in the letter

Sep.l: A hydrology and hydraulic study was submitted to EPA for approval on August 30, 1999,for the Eastern portion of the landfill as part of DUMPCo's August 8,1999, (E.5 & E.6)response to EPA's comments on the DUMPCo's Interim Stormwater Measures. Usingthe data obtained from the hydrology and hydraulic study, preliminary design conceptsare proposed for blasting the drop off channel and re-armoring the western slope of thelandfill. That area has been impacted in past storm events. After approval of thisapproach, DUMPCo will provide EPA with proposed construction drawings for thesecontrol measures.

Sep.2: As requested by Clark County Public Works (CCPW), final construction drawings for theprotection of the Construction Debris Cell were delivered to CCPW on September 8,1999, for their final approval and bonding.

Sep.3: DUMPCo expects to begin placing concrete around the down drains, as specified in theAugust 6,1999, response to EPA's comments on the Interim Plan, by the end ofSeptember.

Sep.4: On August 25,1999, SCS Engineers submitted, on the behalf of DUMPCo, a revisedWork Plan as required by EPA's August 17,1999 approval of DUMPCo's extensionrequest.

Sep.5: EPA provided DUMPCo with some general comments regarding the revised Work Plan.DUMPCo is in the process of clarifying some the text based on EPA's comments.However, two possible points of misunderstanding were identified: The InducedPolarization (IP) method includes resistivity (See page 9, 3.4.1.5), and DUMPCo does notfeel that it is appropriate to restate objectives in the Sampling and Analysis Plan (SAP).The SAP is designed to describe methods.

Sep.6: DUMPCo will be providing EPA with a list of contractors and summaries ofqualifications of the consultants and primary contractors for the Sunrise Landfill work.DUMPCo is in the process of selecting the geoprobe contractor and soils laboratory(s).The approval letter should be ready by the end of September.

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Page 4October Progress Report

Sep.7: After evaluating the Trimble Geo Explorer II and associated software, DUMPCo hasdecided to purchase the unit. The evaluation determined that while the unit does notprovide field personnel with accurate locations, once the data has been corrected with thesoftware, valuable location information can obtained.

Sep.8: DUMPCo has been proceeding with surficial stormwater control work, see the attachedsummary. A detailed report of these repairs will be provided, including pictures.

Sep.9: DUMPCo is in the process of evaluating the GC Wallace, Inc. "Conceptual DrainageAnalysis For The Sunrise Mountain Landfill East Channel," dated August 1999, preparedfor Clark County Department of Public Works. A copy of the report has been forwardedto EPA.

If you have any questions, please contact me at (702) 734-5400.

Respectfully,

Vice Pres

Attachments: HLA Perimeter Gas Monitoring ReportGlendale Alternative Cover StudyAtlas Chemical Testing Profile

CC: Mr. David Basinger (WTR - 7) Water DivisionU.S. Environmental Protection Agency75 Hawthorne StreetSan Francisco, CA 94105 - 3901

Mr. Dave Emme, ChiefBureau of Waste ManagementNevada Division of Environmental Protection333 W. Nye Lane, Room 138Carson City, NV 89706-0851

Mr. Clare SchmutzClark County Health District625 Shadow LaneLas Vegas, NV 89106John Schlegel

Mr. Mike Dwyer, Field Manager(Attention: Mike Moran)Bureau of Land Management4765 Vegas Valley DriveLas Vegas, NV 89108

Mr. Steve Johnson (WO/A)PHB Hagler Bailly100 Hamilton Ave. Ste. 200Palo Alto, CA 94301

Mr. John SchlegelClark County Comprehensive Plan.500 S. Grand Central Pky.Las Vegas, NV 89155-1744

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Ifp

Harding Lawson Associates HLA

September 8,1999

48248.1

Mr. Tom GardnerEnvironmental Technologies of Nevada, Inc.770 East Sahara Ave.Las Vegas, Nevada 89104

Perimeter Landfill Gas Monitoring forDisposal Urban Maintenance Processing Company (DUMPCO)Apex Landfill, Laughlin Landfill, Sunrise LandfillClark County, Nevada

Dear Mr. Gardner:

Harding Lawson Associates (HLA) is pleased to present results of perimeter landfill gas monitoring conductedat the Apex, Laughlin, and Sunrise landfills located in Clark County, Nevada. The purpose of the project is tomonitor for the presence of explosive gases, specifically methane, along the perimeters of the landfills.Authorization to perform this work was issued by Environmental Technologies of Nevada, Inc. (ET) in aservice agreement dated August 31,1999, pursuant to HLA's proposal for Landfill Gas Monitoring datedAugust 20, 1999. This report presents results of the gas monitoring performed during August 1999.

GAS MONITORING ACTIVITIES

HLA mobilized to the Apex, Laughlin, and Sunrise Landfills on August 31, 1999 to monitor the concentrationof methane gas around the perimeter of the landfill by measuring the percentage of the Lower Explosive Limit(LEL) using a GASTEC Model GT201 LEL and Oxygen Meter (GT201). As required, the instrument wascalibrated prior to gas monitoring using a canister of methane gas containing 50% of the LEL. A total of fourreadings were recorded during continuous monitoring around the perimeter of each landfill (north, south, east &west boundaries). Additional readings were collected at the Apex landfill at ET-designated locations within theindustrial, maintenance, and active dumping areas. At each location, HLA field personnel held the GT201approximately two feet above the ground surface and monitored the LEL for approximately five minutes. HLArecorded the highest LEL reading for each location during the five-minute monitoring period. The attachedLandfill Gas Perimeter Form summarizes the time and results of gas monitoring activities for each facility. Ascan be seen on this form, the LEL reading at all monitoring points was "0" percent.

CLOSURE

This document was prepared for the sole use of ET, the only intended beneficiary of HLA's services. No otherparty should rely on the information contained herein without prior written consent from HLA.

Engineering and 10265 Rockingham Drive. Suite 150. Sacramento, California 95827 916/364-0793 Fax 916/364-5633Environmental Services

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November 12, 1999 Ux

Ms. Susanna Trujillo, Project CoordinatorU.S. EPA Region IX75 Hawthorne Street (WST-7)San Francisco, CA 94105-3901

Dea- Ms. Trujillo:

RE: Monthly Progress Report - November, 1999Order RCRA 7003-09-99-0005NOV/Order CWA-309-9-99-14

As required by the above referenced RCRA Order, specifically VI number 3 (page 9 of 22.), thefollowing is the monthly progress report: The report contains two sections, the Current MonthlyProgress Report section, followed by the Monthly Progress Report Summary section. Theprogress report items are numbered with the first three letters of the month of the report that theitem appeared. November's Items are:

Section I: Current Monthly Progress Report

Nov.l: On November 2,1999, SCS Engineers, on the behalf of Republic DUMPCo, submitted toEPA the response to EPA's Draft Comments on the revised Work Plan.

Nov.2: All proposed down drain head wall modifications have been completed. RepublicDUMPCo will be providing EPA with a detailed report.

Nov.3: Armoring of the Construction Debris Cell has begun. Republic DUMPCo will beproviding EPA with a detailed report once this Interim Action is complete.

Nov.4: The detailed drawing for the proposed blasting and armoring of the Eastern BypassChannel outlet is in the making. As soon as they are complete, they will be submitted toEPA for review.

Nov. 5: Four truck loads of proposed rock to be used as a cover source has been crushed.Samples of this material will be evaluated for potential use. Once the evaluation iscomplete, a report will be submitted to EPA for review.

770 EadNSSH&JHrehite's £fep&)$iim Illis Mityaapt^^ (702) 735-1986distributer a time for delivery.

I MADE WITH RECYCLED PAPER

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Page 2November Progress Report

Section 2: Monthly Progress Report Review Summary:

1. Tentative agreements have been reached on the access agreement for off-lease areas.2. RCRA Order Item b. 1 .(a-h) "Landfill Assessment Work Plan," was completed and

delivered to EPA and BLM on June 7,1999.3. CWA Order Task #19, 20, and 21 were competed and delivered to EPA and BLM on

June 11, 1999.4. On July 16,1999, DUMPCo submitted to EPA a Sunrise Landfill Release Report that

described the impacts associated with the July 8, 1999 storm event. This report alsoincluded a request to implement interim emergency measures to prevent further impacts.

5. EPA's August 2,1999, comments on the "Work Plan" have been received and reviewed.Based on these comments, Republic DUMPCo (DUMPCo) requested an extensionfor the submittal of the revised work plan from August 16,1999 to August 25, 1999.

6. DUMPCo completed the consultant selection process for the RCRA Work Planassessment work.

7. In a letter dated August 6,1999, DUMPCo responded to EPA's comments regardinginterim stormwater control measures. DUMPCo is implementing these measures asoutlined in the letter

Sep.l: A hydrology and hydraulic study was submitted to EPA for approval on August 30, 1999,for the Eastern portion of the landfill as part of DUMPCo's August 8, 1999, (E.5 & E.6)response to EPA's comments on the DUMPCo's Interim Stormwater Measures. Usingthe data obtained from the hydrology and hydraulic study, preliminary design conceptsare proposed for blasting the drop off channel and re-armoring the western slope of thelandfill. That area has been impacted in past storm events. After approval of thisapproach, DUMPCo will provide EPA with proposed construction drawings for thesecontrol measures.

Sep.2: As requested by Clark County Public Works (CCPW), final construction drawings for theprotection of the Construction Debris Cell were delivered to CCPW on September 8,1999, for their final approval and bonding.

Sep.3: DUMPCo expects to begin placing concrete around the down drains, as specified in theAugust 6, 1999, response to EPA's comments on the Interim Plan, by the end ofSeptember.

Sep.4: On August 25, 1999, SCS Engineers submitted, on the behalf of DUMPCo, a revisedWork Plan as required by EPA's August 17, 1999 approval of DUMPCo's extensionrequest.

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Page 3November Progress Report

Sep.5: EPA provided DUMPCo with some general comments regarding the revised Work Plan.DUMPCo is in the process of clarifying some the text based on EPA's comments.However, two possible points of misunderstanding were identified: The InducedPolarization (IP) method includes resistivity (See page 9, 3.4.1.5), and DUMPCo does notfeel that it is appropriate to restate objectives in the Sampling and Analysis Plan (SAP).The SAP is designed to describe methods.

Sep.6: DUMPCo will be providing EPA with a list of contractors and summaries ofqualifications of the consultants and primary contractors for the Sunrise Landfill work.DUMPCo is in the process of selecting the geoprobe contractor and soils laboratory(s).The approval letter should be ready by the end of September.

Sep.7: After evaluating the Trimble Geo Explorer II and associated software, DUMPCo hasdecided to purchase the unit. The evaluation determined that while the unit does notprovide field personnel with accurate locations, once the data has been corrected with thesoftware, valuable location information can obtained.

Sep.8: DUMPCo has been proceeding with surficial stormwater control work, see the attachedsummary. A detailed report of these repairs will be provided, including pictures.

Sep.9: DUMPCo is in the process of evaluating the GC Wallace, Inc. "Conceptual DrainageAnalysis For The Sunrise Mountain Landfill East Channel," dated August 1999, preparedfor Clark County Department of Public Works. A copy of the report has been forwardedto EPA.

Oct.l: EPA has verbally approved moving forward with providing EPA with constructiondrawings and specifications for blasting the south end of the Eastern Bypass channel, andarmoring of landfill cell below the drop off structure. However, EPA made it clear thatthis structural modification may not be the final solution to the drainage in this area. (SeeInterim Action Report).

Oct.2: DUMPCo has received final approval for armoring the Construction Demolition Cell andDUMPCo is proceeding to construct. See Interim Action Report.

Oct.3: DUMPCo will place concrete around the down drains during the armoring of theConstruction demolition cell.

Oct.4: In a correspondence dated September 29, 1999, DUMPCo submitted to EPA a list ofcontractors, consultants, and laboratories for review and approval. DUMPCo requests toadd an additional company to this list: Atlas Chemical Testing Laboratories. A companyprofile is enclosed with this monthly progress report.

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Page 4November Progress Report

Oct.5. As indicated in the October 7,1999 teleconference, DUMPCo is evaluating the mostappropriate method(s) that should be used to determine soil loss from erosion. After aninitial review, it seems that there may be a problem with past reports that indicate that thecover at Sunrise contains high concentrations of gypsum. After a review of the EMCONexpansion report and Dynamac's report, there does not seem to be any formal analyticalresults to support comments made in those reports. DUMPCo has identified a localchemical testing laboratory that has the ability to test for these parameters. DUMPCowill provide EPA with the results of this evaluation.

Oct.6: DUMPCo has indicated to EPA that there may not be enough available cover material atthe Landfill site to respond to the corrective actions that will be identified in the RCRAWork Plan and CWA AO. DUMPCo has proposed to locate small crushing plant on sitein order to make cover dirt. EPA has responded by requesting specifications on thematerial and product that will be used as cover. DUMPCo is currently evaluating anumber of different specifications, and has obtained a sample of the source material. Thissample will be analyzed to determine it's chemical composition. However, until theappropriate models can be established, DUMPCo is unable to provide EPA with theproposed cover material specifications. DUMPCo is evaluating this, and in the interim,submits an Alternative Cover Evaluation that was completed in Glendale, Arizona forEPA review.

Oct.7: On August 31, 1999, Harding Lawson Associates conducted perimeter landfill gasmonitoring at the Sunrise Landfill. No detectable levels of landfill gas was detected atthe perimeter of the Sunrise Landfill. (See the attached HLA report)

Oct 8: CWA Task #20 - Interim Plan now contains an Appendix A entitled: Interim ActionReport (IAR). Republic DUMPCo is requesting approval of these actions as InterimActions. This report will be updated to finalize the document once all actions arecomplete.

Oct 9: Republic DUMPCo has ordered a Geoexplorer II. However, Trimble has discontinuedmanufacturing this unit and has no more in stock. Republic DUMPCo is on the waitinglist for a Geoexplorer III. Republic DUMPCo will update these Interim Actions as soonas the unit is received, the software is installed and the unit is calibrated for the Sunrisesite.

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PageSNovember Progress Report

If you have any questions, please contact me at (702) 734-5400.

Respectfully,

AlanVice P ident

CC: Mr. David Basinger (WTR - 7) Water DivisionU.S. Environmental Protection Agency75 Hawthorne StreetSan Francisco, CA 94105 - 3901

Mr. Dave Emme, ChiefBureau of Waste ManagementNevada Division of Environmental Protection333 W. Nye Lane, Room 138Carson City, NV 89706-0851

Mr. Clare SchmutzClark County Health District625 Shadow LaneLas Vegas, NV 89106John Schlegel

Mr. Mike Dwyer, Field Manager(Attention: Mike Moran)Bureau of Land Management4765 Vegas Valley DriveLas Vegas, NV 89108

Mr. John SchlegelClark County Comprehensive Plan.500 S. Grand Central PkyLas Vegas, NV 89155-1744

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NOV-1?-99 09:22 FROM- T.850 p.01/03 F_253

November 12, 1999

Ms. Susanna Trujillo, Project CoordinatorU.S. EPA Region IX75 Hawthorne Street (WST-7)San Francisco, CA 94105-3901

Dear Ms. Tnijillo:

11 November. 1999 /RE: Monthly Progress Report | November. 1999Order RCRA 7003~09-99-TmWNOV/Order CWA-309-9-99-14

As required by the above referenced RCRA Order, specifically VI number 3 (page 9 of 22), the followingis the monthly progress report: The report contains two sections, rhe Current Monthly Progress Reportsection, followed by the Monthly Progress Report Summary section. The progress report items arenumbered with me first three letters of the month of the report thai the item appeared. November's Itemsare:

Section I: Current Monthly Progress Report

Nov.l: On November 2,1999, SCS Engineers, on the^ehalf of Republic DUMPCo, submitted to EPAthe response to EPA's Draft Comments on the revised Work Plan.

Nov.2: All proposed down drain head wall modifications have been completed. Republic DUMPCo will/ be providing EPA with a detailed report.I r i

Nov.3: Armoring of the Construction Debris Cell has begun. /Republic DUMPCo will be providing EPAwith a detailed report. *• '

Nov.4:The datailed drawing for the proposed blasting and armoring of the Eastern Bypass Channel outlet^TTsln the making. Ks soon as they are complete, they will be submitted to EPA for review.

Nov.5: Four truck loads of proposed rocktobe used as a cover source has been crushed Samples of thismaterial will be evaluated for potential use. Once the evaluation is complete, a report will besubmitted to EPA for review.

Nov.6: Trimble's Geo-Explorer HI is still not available- Trimble can not give our local distributer a Timefor delivery-

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December 13, 1999

Ms. Susanna Trujillo, Project CoordinatorU.S. EPA Region IX75 Hawthorne Street (WST-7)San Francisco, CA 94105-3901

Dear Ms. Trujillo:

RE: Monthly Progress Report - December, 1999Order RCRA 7003-09-99-0005NOV/Order CWA-309-9-99-14

As required by the above referenced RCRA Order, specifically VI number 3 (page 9 of 22), thefollowing is the monthly progress report: The report contains two sections, the Current MonthlyProgress Report section, followed by the Monthly Progress Report Summary section. Theprogress report items are numbered with the first three letters of the month of the report that theitem appeared. November's Items are:

Section I: Current Monthly Progress Report

Dec.l : Formal approval of portions of the November 2, 1999, revised Work Plan was obtainedon December 7, 1999.

Dec.2: Rq-abb'c DUMPCo has purchased a GPS system, and is in the process of mapping all ofthe Interim Actions (IA).

*

Dec.3: BLM has placed boundary identification markers for the Instant Study Areas (ISA).Republic DUMPCo is in the process of mapping these areas.

Dec.4: All Interim Actions, except for the Design of the Eastern Drop off Channel and themapping of the lA's have been completed. Republic DUMPCo will be providing EPAwith a full report to update the lA's.

Dec.5: EMCON started Geologic Mapping on December 9, 1999, and the surface gas monitoringis scheduled to start on December 14, 1999. CSAMT should be starting within a week.

Dec.6: The initial review of the Design Drawings for the Eastern Bypass Channel revealedseveral technical errors. SCS is in the process of revising the design drawings.

770 East Sahara Avenue • P.O. Box 98508 • Las Vegas, Nevada 89193-8508 • Telephone 735-5151 • Fax (702) 735-1986

I MADE WITH RECYCLED PAPER

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Page 2December Progress Report

Section 2: Monthly Progress Report Review Summary:

1. Tentative agreements have been reached on the access agreement for off-lease areas.2. RCRA Order Item b. 1 .(a-h) "Landfill Assessment Work Plan," was completed and

delivered to EPA and BLM on June 7,1999.3. CWA Order Task #19, 20, and 21 were competed and delivered to EPA and BLM on

June 11,1999.4. On July 16, 1999, DUMPCo submitted to EPA a Sunrise Landfill Release Report that

described the impacts associated with the July 8, 1999 storm event. This report alsoincluded a request to implement interim emergency measures to prevent further impacts.

5. EPA's August 2, 1999, comments on the "Work Plan" have been received and reviewed.Based on these comments, Republic DUMPCo (DUMPCo) requested an extensionfor the submittal of the revised work plan from August 16, 1999 to August 25,1999.

6. DUMPCo completed the consultant selection process for the RCRA Work Planassessment work.

7. In a letter dated August 6, 1999, DUMPCo responded to EPA's comments regardinginterim stormwater control measures. DUMPCo is implementing these measures asoutlined in the letter

Sep.l: A hydrology and hydraulic study was submitted to EPA for approval on August 30, 1999,for the Eastern portion of the landfill as part of DUMPCo's August 8,1999, (E.5 & E.6)response to EPA's comments on the DUMPCo's Interim Stormwater Measures. Usingthe data obtained from the hydrology and hydraulic study, preliminary design conceptsare proposed for blasting the drop off channel and re-armoring the western slope of thelandfill. That area has been impacted in past storm events. After approval of thisapproach, DUMPCo will provide EPA with proposed construction drawings for thesecontrol measures.

Sep.2: As requested by Clark County Public Works (CCPW), final construction drawings for theprotection of the Construction Debris Cell were delivered to CCPW on September 8,1999, for their final approval and bonding.

Sep.3: DUMPCo expects to begin placing concrete around the down drains, as specified in theAugust 6,1999, response to EPA's comments on the Interim Plan, by the end ofSeptember.

Sep.4: On August 25, 1999, SCS Engineers submitted, on the behalf of DUMPCo, a revisedWork Plan as required by EPA's August 17,1999 approval of DUMPCo's extensionrequest.

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Page3December Progress Report

Sep.5: EPA provided DUMPCo with some general comments regarding the revised Work Plan.DUMPCo is in the process of clarifying some the text based on EPA's comments.However, two possible points of misunderstanding were identified: The InducedPolarization (IP) method includes resistivity (See page 9, 3.4.1.5), and DUMPCo does notfeel that it is appropriate to restate objectives in the Sampling and Analysis Plan (SAP).The SAP is designed to describe methods.

Sep.6: DUMPCo will be providing EPA with a list of contractors and summaries ofqualifications of the consultants and primary contractors for the Sunrise Landfill work.DUMPCo is in the process of selecting the geoprobe contractor and soils laboratory(s).The approval letter should be ready by the end of September.

Sep.7: After evaluating the Trimble Geo Explorer II and associated software, DUMPCo hasdecided to purchase the unit. The evaluation determined that while the unit does notprovide field personnel with accurate locations, once the data has been corrected with thesoftware, valuable location information can obtained.

Sep.8: DUMPCo has been proceeding with surficial stormwater control work, see the attachedsummary. A detailed report of these repairs will be provided, including pictures.

Sep.9: DUMPCo is in the process of evaluating the GC Wallace, Inc. "Conceptual DrainageAnalysis For The Sunrise Mountain Landfill East Channel," dated August 1999, preparedfor Clark County Department of Public Works. A copy of the report has been forwardedto EPA.

Oct. 1: EPA has verbally approved moving forward with providing EPA with constructiondrawings and specifications for blasting the south end of the Eastern Bypass channel, andarmoring of landfill cell below the drop off structure. However, EPA made it clear thatthis structural modification may not be the final solution to the drainage in this area. (SeeInterim Action Report).

Oct.2: DUMPCo has received final approval for armoring the Construction Demolition Cell andDUMPCo is proceeding to construct. See Interim Action Report.

Oct. 3: DUMPCo will place concrete around the down drains during the armoring of theConstruction demolition cell.

Oct.4: In a correspondence dated September 29, 1999, DUMPCo submitted to EPA a list ofcontractors, consultants, and laboratories for review and approval. DUMPCo requests toadd an additional company to this list: Atlas Chemical Testing Laboratories. A companyprofile is enclosed with this monthly progress report.

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Page 4December Progress Report

Oct.5. As indicated in the October 7, 1999 teleconference, DUMPCo is evaluating the mostappropriate method(s) that should be used to determine soil loss from erosion. After aninitial review, it seems that there may be a problem with past reports that indicate that thecover at Sunrise contains high concentrations of gypsum. After a review of the EMC ONexpansion report and Dynamac's report, there does not seem to be any formal analyticalresults to support comments made in those reports. DUMPCo has identified a localchemical testing laboratory that has the ability to test for these parameters. DUMPCowill provide EPA with the results of this evaluation.

Oct.6: DUMPCo has indicated to EPA that there may not be enough available cover material atthe Landfill site to respond to the corrective actions that will be identified in the RCRAWork Plan and CWA AO. DUMPCo has proposed to locate small crushing plant on sitein order to make cover dirt. EPA has responded by requesting specifications on thematerial and product that will be used as cover. DUMPCo is currently evaluating anumber of different specifications, and has obtained a sample of the source material. Thissample will be analyzed to determine it's chemical composition. However, until theappropriate models can be established, DUMPCo is unable to provide EPA with theproposed cover material specifications. DUMPCo is evaluating this, and in the interim,submits an Alternative Cover Evaluation that was completed in Glendale, Arizona forEPA review.

Oct.7: On August 31, 1999, Harding Lawson Associates conducted perimeter landfill gasmonitoring at the Sunrise Landfill. No detectable levels of landfill gas was detected atthe perimeter of the Sunrise Landfill. (See the attached HLA report)

Oct 8: CWA Task #20 - Interim Plan now contains an Appendix A entitled: Interim ActionReport (IAR). Republic DUMPCo is requesting approval of these actions as InterimActions. This report will be updated to finalize the document once all actions arecomplete.

Oct 9: Republic DUMPCo has ordered a Geoexplorer II. However, Trimble has discontinuedmanufacturing this unit and has no more in stock. Republic DUMPCo is on the waitinglist for a Geoexplorer III. Republic DUMPCo will update these Interim Actions as soonas the unit is received, the software is installed and the unit is calibrated for the Sunrisesite.

Nov.l: On November 2, 1999, SCS Engineers, on the behalf of Republic DUMPCo, submitted toEPA the response to EPA's Draft Comments on the revised Work Plan.

Nov.2: All proposed down drain head wall modifications have been completed. RepublicDUMPCo will be providing EPA with a detailed report.

Nov.3: Armoring of the Construction Debris Cell has begun. Republic DUMPCo will beproviding EPA with a detailed report once this Interim Action is complete.

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Page 5December Progress Report

Nov.4: The detailed drawing for the proposed blasting and armoring of the Eastern BypassChannel outlet is in the making. As soon as they are complete, they will be submitted toEPA for review.

Nov.5: Four truck loads of proposed rock to be used as a cover source has been crushed.Samples of this material will be evaluated for potential use. Once the evaluation iscomplete, a report will be submitted to EPA for review.

Nov.6: Trimble's Geo-Explorer III is still not available. Trimble can not give our localdistributer a time for delivery.

If you have any questions, please contact me at (702) 734-5400.

Respectfully,

Alan GiddyVice President

CC: Mr. David Basinger (WTR - 7) Water DivisionU.S. Environmental Protection Agency75 Hawthorne StreetSan Francisco, CA 94105 - 3901

Mr. Dave Emme, ChiefBureau of Waste ManagementNevada Division of Environmental Protection333 W. Nye Lane, Room 138Carson City, NV 89706-0851

Mr. Clare SchmutzClark County Health District625 Shadow LaneLas Vegas, NV 89106

Mr. Mike Dwyer, Field Manager(Attention: Mike Moran)Bureau of Land Management4765 Vegas Valley DriveLas Vegas, NV 89108

Mr. John SchlegelClark County Comprehensive Plan.500 S. Grand Central PkyLas Vegas, NV 89155-1745

Ms. Sandy DotySAIC5303 W. Oberlin Dr.Denver, CO 80235