2014 Apex Operations Plan-Web Site-3

10.
12
LITTER CONTROL PLAN

10.13
SULFUR ANALYTICAL DATA

10.14
OPERATIONS AND MAINTENANCE MANUAL FOR THE APEX BIOREMEDIATION FACILITY AND
LIQUID SOLIDIFICATION AREA
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REPUBLIC ENVIRONMENTAL TECHNOLOGIES, INC.
OPERATIONS AND MAINTENANCE MANUAL
APEX BIOREMEDIATION FACILITY
AND
LIQUID SOLIDIFICATION AREA
Apex Regional Waste Management Center
Apex, Nevada
************************************************************************
Prepared
August 1995
Revised March 17, 2000
Revised December 15, 2005
Revised July 29, 2011
Revised May 25, 2012
Revised July 25, 2012
By
Republic Environmental Technologies, Inc. (E.T.)
770 E. Sahara Avenue, Suite 100, Las Vegas, Nevada 89104
Republic Environmental Technologies, Inc.
Table of Contents
Facility Construction and Operating Plan
I.
II.
III.
IV.
INTRODUCTION
TREATMENT DESCRIPTION
2.1 Petroleum Contaminated Liquids
2.2 Non-Hazardous Liquids
2.3 Petroleum Contaminated Soils
2.4 Initiating Bioremediation Activities
2.5 Maintaining Bioremediation
2.6 Completion ofTreatment Cycle
2.7 Disposition of Treated Soils
FACILITY DESCRIPTION, OPERATIONS AND MAINTENANCE
3.1 Construction Specifications
3.2 Liner and Sump Inspections
3.3 Water Supply
TREATMENT OPERATIONS
4.1
4.2
4.3
4.4
4.5
Waste Pre-Acceptance
Waste Acceptance at the Facility
Testing and Screen Procedures
In-State Soils and Out-of-State other than California
California Out-of-State Soils Acceptance Procedures
Liquid Petroleum Contaminated Waste
2
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Republic Em:ironmental Technologies, inc.
Page
V. LIQUID SOLIDIFICATION AREA 21
VI. MAINTENANCE 22
VII. MONITORING 22
VIII. SAFETY 27
IX. EMERGENCY CONTACTS 27
FIGURES: Page
1. General Area Site Map 6
2. Bioremediation (ABF) Site Map 7
3. Block Diagram of the Bioremediation Facility 8
4. ABF Cell Sampling Locations 10
5. Certificate of Material for Recycling 13
6. Monitoring Probe Design 26
ATTACHMENTS:
1. NDEP Testing and Screening Procedures for all Soil Treatment Facilities in
Nevada
2. As-Built Drawing and Designs for the Geomembrane Liner System
3. Leachate Collection and Leak Detection Monitoring Procedures
4. In-State Application for Treatment of Petroleum Contaminated Soils
5. Out-of-State Application for Treatment of Petroleum Contaminated Soils
6. Liquid Waste Handling Procedures and Profile Application
7. Water Pollution Control Discharge Permit
3
Republic Environmentai Technoiogies, Inc.
I. INTRODUCTION
The purpose of this manual is to provide a description of the facilities, operating guidelines, and
acceptance criteria for Republic Environmental Technologies, Inc. (ET) bioremediation facilities
at the Apex Waste Management Center in Apex, Nevada (see Figures 1, 2 and 3- Site Maps).
This manual will cover ET's liquid solidification and bioremediation of soils contaminated with
petroleum hydrocarbons (such as gasoline, diesel, motor oil, etc.) through evaporation,
solidification or landfarming techniques. This 0 & M manual covers the management of
Petroleum Contaminated Soils and Non-Hazardous Liquid Waste (liquids for evaporation or
solidification), soils and liquids must be nonhazardous as defined by state and federal regulations
for acceptance into the facility.
This manual also contains application forms required for acceptance of the customer's waste.
The biological treatment employed is capable of reducing the hydrocarbon contaminates to levels
less than 100 ppm TPH. The treated soils are then primarily utilized as landfill cover material.
Soils treated to less than 50 ppm may be used for alternative purposes, such as fill material, a
component of road base materials, or as a component of sand and gravel processing materials,
where dirt is a component.
II. TREATMENT DESCRIPTION
Non Hazardous liquids, petroleum contaminated liquids and petroleum contaminated soils will
be considered for evaporation or treatment in the bioremediation facility. Both liquid petroleum
contaminated waste and petroleum contaminated soils are capable of biological treatment at the
ET's Bioremediation Facility. The Facility is designed to bioremediate 160,000 tons I yr. of soil.
2.1 Petroleum Contaminated Liquids are solidified within the double synthetically lined
Treatment cells using clean soils. The liquids are evaporated or tilled into the soils to
concentrate the petroleum sufficiently for economical biological treatment. Once sufficiently
concentrated, the solidified petroleum contaminated liquids may be disposed of by direct
landfilling into the Class I landfill sections, or used for cover as needed by landfill operations. If
the soils are to be bioremediated they are then profiled into the Soil Treatment Facility's
following Nevada Division of Environmental Protection (NDEP) guidelines (see Attachment 1)
established for all soil treatment facilities operating within Nevada.
2.2 Non-Hazardous liquids will be placed into separate cells from the petroleum contaminated
liquids, where they will be allowed to evaporate. Once the liquid has evaporated the soils may be
disposed of directly into in the Class I landfill.
2.3. Petroleum Contaminated Soils, which may include the solidification ofliquids described
above, are biologically treated using landfarming teclmiques.
770 E. Sahara Avenue, Suite I 00, Las Vegas, Nevada 89104
4
Republic Environmentol Technologies, li1.c.
2.4. Initiating Bioremediation Soil Activities
2.4.1 Upon accumulating approximately 3000 tons (approx. 2300 cu. yd.) of
Hydrocarbon contaminated soil in a treatment cell; the soil is spread with a front
loader (or equivalent). During cell accumulation, the soils are placed into small
piles in the cell to prevent settling. The soils will be tilled thoroughly to increase
soil uniformity and consistency within the treatment cell.
5
Republic Environmental Inc.
Figure 1
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DATE FEB. 2000
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FIGURE 1
REPUBLIC-DUMPCO
APEX MUNICIPAL WASTE DISPOSAL FACIU1Y
LAS VEGAS, NEVADA
BIOREMEDIATION FACILITY
LOCATION PLAN
Figure 2
770 E. Sahara Avenue .. Suite 100, Las Vegas, Nevada 89104
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Figure 3
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2.4.2 A representative "baseline" sample will be obtained from the soil within a cell when the
cell is ready to be biologically treated.
2.4.2.1 Sampling Protocol
( 1) The sampling procedure is to collect sixteen ( 16) discrete soil samples per
celL Representative composite samples for each cell will be obtained by dividing
the cell into sixteen (16) sections (see Figure 4) using sprinklers as common
reference points.
(2) A hand shovel will be used to collect a sample from the center of each section
at a depth from between 10 to 18 inches.
(3) The 16 discrete samples will be collected into a clean polypropylene bucket
and gently mixed with the hand shovel to form a homogenous composite sample.
( 4) Each treatment cell composite sample will then be tightly packed into a glass
jar and labeled with the date and cell number.
(5) The sample containers will then be placed in an ice chest for transport to the
laboratory for analysis.
2.4.3 The samples will be delivered to the laboratory with the appropriate "chain of
custody" documentation and analyzed for Total Petroleum Hydrocarbons
(modified EPA Method 8015). The analytical results will provide the baseline
soil concentration prior to implementing biological treatment activities.
2.4.4 Off-site laboratory testing is preferred for detennining the nitrogen (N) and
phosphorous (P) levels of the cell soiL On-site evaluation is possible using
common fanning testing methods. The testing will be conducted on samples from
numerous locations (approximately 8) within the celL The locations of these
samples are rotated among one-half of the 16 discrete sampling locations used to
determine the TPH of a cell shown in Figure 4. IfN or P are absent or less than
optimum concentrations in the soil, the desired concentrations can be achieved by
applying fertilizers. The desirable Nor P values are confidential to company
operations. The amount of nutrients applied will vary depending upon the
concentration levels and can be easily calculated on a case-by-case basis. The
nutrients can be applied to the soil via a water truck or more accurately with
common farm fertilizer application instruments. The concentrations of fertilizer
nutrients maintained in the soils are significantly less than 0.1 %. As such, no
potential ignitability or flammability hazard exists when working with fertilizers
and petroleum contaminated soils.
2.4.5 After application, the soil is thoroughly tilled and re-tested for nutrient
concentrations. The nutrient application/test procedure is repeated, as necessary,
throughout the treatment cycle to maintain the desired nutrient concentrations.
Upon soil tilling, and confirming the proper nutrient levels, the soils are ready for
inoculation.
770 E. Sahara Avenue, Suite 100, Las Vegas. Nevada 89104
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Bio-remediation Facility
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Cell Sampling Locations
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2.4.6 The bacteria can be applied to the soil with landfarming equipment or by water
truck. Caution should be exercised not to over-water the treatment cell. After
inoculation is completed, the soil is thoroughly tilled with a tractor/disc.
Maintaining Bioremediation
2.5.1 The bioremediation cycle consists of several days of biological treatment activity.
Time is required to load a treatment cell, perform biological treatment activities,
and unload the treated soil from the cell when treatment is complete. After which
time, the treatment cell is ready for new loads of contaminated soil and start of a
new treatment cycle.
2.5.2. The following maintenance activities must be performed to ensure optimal
environment for the bacteria, and hence, successful treatment of the hydrocarbon
coi1taminated soil:
(1) Water the soil treatment area daily as required to maintain moisture
content. Moisture content will be measured primarily using an off-site
laboratory testing soil moisture levels. Water can be applied with the
water truck or with a tank/sprinkler system. The depth of the soils is
maintained at between 15 to 18 inches, so tilling of soils easily
facilitates aeration of the biological media.
(2) The contaminated soils will be tilled thoroughly on a regular basis.
During the summer, tilling occurs daily.
(3) A representative sample of the soil being treated must be obtained
through completion of the treatment cycle, and analyzed for Total
Petroleum Hydrocarbons. Reference the sampling and handling
procedures identified in Section II-3.1.2.1 of this plan. The analytical
results will be evaluated to assess the progress and efficiency of the
treatment activities.
( 4) After approximately 14 days, a representative sample is collected and a
biological plate count of the bacteria population will be performed. If
the bacteria population is significantly low, then a second inoculation of
microorganisms should be applied to the treatment area. The method
used to collect bacteria samples is described in Section IL3.1.2.1. The
method of measurement of the bacteria content is confidential to the ET
process and lab.
(5) The biological plate counting is repeated after approximately 14 days
and a third inoculation is performed, if necessary.
11
Republic Environmental Technologies, inc.
2.6 Completion of the Treatment Cycle
2. 6 .1. After time, the contaminated soil shall be successfully treated to hydrocarbon
concentrations less than 1 00 ppm. A representative sample must be collected and
analyzed, as previously discusses, to confirm the success and subsequent
termination of the treatment cycle.
2.6.2 A copy of the final laboratory result is included in ET's reports to NDEP to
document the successful treatment of the materiaL Customers will be provided a
copy of the successful treatment results upon their request. Ordinarily, the
customer is mailed a Certificate of Materials for Recycling (Figure 5)
documenting the acceptance of the soils into the facility.
2. 7 Disposition of Treated Soils
2. 7.1 After the soils have been treated to less than 100 ppm total petroleum
hydrocarbon content, the soils may be placed into either a municipal or industrial
section ofthe solid waste landfill for use as cover material. Additional uses may
include fill material, a component of sand and gravel processing materials, where
di1i is a component. Concentrations of petroleum contamination must be below
50 ppm TPH, if the material is to be used for alternative purposes off-site.
2.7.2 Once the soils have been removed from the cell, a small layer of clean base soils
is also removed and immediately replaced before treatment begins on a new batch
of contaminated soils. The bottom of each cell is surveyed annually and restored
as needed to ensure approximately 5 feet of clean soil exists between the liner and
soils to be treated.
770 E. Sahara Avenue, Suite J 00, Las Vegas, Nevada 89104
12
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III.
Environmental Technologies, Inc.
FACILITY DESCRIPTION, OPERATIONS, J\1ANITENANCE
3.1 Construction Specifications
3 .1.1 The Soil Treatment Facility is designated as an approximately 20-acre area at
the Apex Waste Management Center located about 30 miles north of Las
Vegas. The Facility is designed to Bioremediate solidified liquids and soils
contaminated with petroleum hydrocarbons (gasoline, diesel, motor oil, etc.)
through the process ofbiological treatment and landfarming. The access road
will be capable of facilitating vehicle transport during inclement weather
conditions.
3.1.2 Current construction involves approximately eight (8) acres of active treatment
area designed to contain any free liquids that may be generated during soil
storage or bioremediation activities. This treatment area is designed to prevent
ground water contamination. After site grading/compaction, installation was
completed with 2 layers, one 60-mil and one 30-mil, of impem1eable high-
density polyethylene (HDPE). The design and construction of the treatment
facility was directed and certified by a qualified registered engineer.
3 .1.3 Selected excerpts form the engineer's report describing the as-built layout and
construction specifications of the bioremediation facility are presented in
Attachment 2. The entire engineer's report is too voluminous for inclusion in
this manual. It is mainly comp1ised of quality control/quality assurance
documentation.
3 .1.4 The containment area is designed for soil storage and bioremediation in any of
10 separate treatment cells (approximately 100' x 400'). Treatment cells
require a minimum dimension of 80 feet to allow efficient movement of the
tractor/disc. Each cell has the capability to biologically treat up to 2300 c.y.
(3000 tons) of contaminated soil. Cells not in use for treatment of petroleum
contaminated soils will be used for solidification of petroleum contaminated
liquids and non-hazardous liquids. The pe1imeter of the containment area is
"humped" soil berm, designed to facilitate vehicle access in/out of the
treatment cells. The treatment cells are segregated by a 14-foot wide zone to
permit vehicle accessibility and the establishment of a sprinkler system.
3 .1.5 Surrounding the containment area is approximately 285,550-sq. ft. of area
designated for vehicle access, equipment storage, sprinkler system, etc.
3 .1.6 Sprinklers are strategically situated around each cell to ensure complete water
coverage.
770 E. Saham Avenue, Suite 100, Las Vegas, Nevada 89104
14
Liner and Sump Inspections
3 .2.1 The liner system under the Facility cells was constructed to direct any liquids that may
percolate through the soils, toward a central leachate collection monitoring point (refer to
As-Built- Attachment 2) above the upper most liner. The leak detection and containment
areas will be inspected weekly. A summary ofthe weekly inspections shall be reported.
3.3. Water Supply
3.3. 1 The Treatment Facility is adjacent to a 7 million gallon synthetically lined reservoir of
1-vater supplied by three (3) on site groundwater wells. The water is distributed to each
cell by industrial sized sprinklers to ensure adequate moisture content within each cell.
IV. TREATMENT OPERATIONS
4.1 Waste Pre-Acceptance
4.1.1 The Soil Treatment Facility is a commercial facility designed for the management
and bioremediation of petroleum hydrocarbon contaminated liquids and soils, and
the disposal of non hazardous liquids. The facility manages only nonhazardous
waste capable of evaporation or complete biodegradation with especially designed
and commercially available microorganisms. Therefore, ET has established a
mandatory wastestream "pre-acceptance" procedure to ensure that all
contaminated material received at the facility is both nonhazardous and
biodegradable.
4.1.2 ET's wastestream "pre-acceptance" profiles are reviewed by Republic Services
Special Waste Approval Department before approval. Upon receiving a complete
Application for Waste Acceptance (Attachment 4- In-State Soil Treatment
Application Form; Attachment 5 -Out-of-State Soil Treatment Application
Fom1) representative samples of the stockpiled contaminated soil are fonvarded
under fmmal chain-of-custody to analytical laboratories for organic/inorganic
analysis and treatability testing. Iflaboratory analyses indicate that the
contaminated soil is a hazardous waste or incapable of complete biodegradation,
then ET notifies the customer that the wastestream is rejected for management at
the STF Facility. If, upon Republic's Special Waste Approval Dept. review of the
laboratory analyses and determines the waste soil is both nonhazardous and
treatable, the customer is notified of acceptability of the soils.
4.1.3 All "pre-approved" vehicle loads of contaminated soil must be scheduled into the
Facility and comply with the conditions of waste acceptance noted on the
Authorization of Waste Acceptance. ET inspects all contaminated soil transport
vehicles leaving the Facility for evidence of contamination and performs
decontamination, as necessary.
15
4.1.3 .1 Vehicle Decon Procedures
(1) Vehicles requiring decontamination will be directed to a Petroleum
Contaminated Liquids designated cell, or other approved areas.
(2) A facility water pressure washer will be used to remove
contaminated soils remaining within the vehicle.
. .
(3) The liquids generated from the decon of a truck will be a1lowed to drain
directly into the appropriate approved area for treatment.
( 4) The petroleum contaminated decon liquids will be presumed approved based
upon acceptance of the soils previously within the truck.
4.1.4 Liquid petroleum contaminated wastes will be profiled before acceptance into the
facility (see Attachment 6- Liquid Waste Profile Application Form). Each
profile will be evaluated and approved based upon either analytical results or a
self-classification of the generators waste. Generators may be contacted to
confirm proper self-classification of the waste.
4.2 \Vaste Acceptance at the Facility
4.2.1 Once waste has had profile or application submitted and approved, waste
transport vehicles will enter the Bioremediation facility after passing through
inspection points at the main entrance of the Apex Waste Management Center.
4.2.2 All waste contaminated shipments (liquids and solids) must have prior approval
through ET' s preacceptance procedures - Section 4.1 - Wastestream Pre-
acceptance.
4.2.3 Notification of the approved waste stream is communicated to the Apex
Inspection Station by either direct access to computer profiles, direct printer
printout, facsimile, or accompanying paperwork delivered with the load. An ET
manifest document or a bill oflading, and wastestream approval with the job
number must accompany each vehicle load of contaminated material. The
document will be reviewed for its accuracy and completeness with any
discrepancies resolved prior to accepting the waste load.
4.2.4 During inspection at the main gate, each load of contaminated waste will be
inspected for evidence of hazardous waste. The inspection will look for the
presence of unexpected colors, odors, or the presence of chlorinated compounds
using copper wire test on the waste, would cause the waste to be suspect. If
hazardous waste is detected in a vehicle waste load, the load will be rejected.
Solid wastes, or undesirable solid materials will be taken to an isolation area
pending evaluation of test results on the waste for proper disposal. Suspect liquid
waste will be directed to the liquid waste solidification area, where a holding tank
is positioned to contain waste, pending analytical results.
4.2.5 A representative sample will be collected from each suspect vehicle load (with a
hand auger or other appropriate sampling implement) received at the facility. The
16
sample will be placed into a container and labeled with the following infonnation:
generator name, document nwnber, waste approval number, load number, vehicle
license number and date, as well as a copy of the manifest
4.2.6 Samples must be stored in a refrigerated environment until received at the
laboratory. Samples will be anal_yzed, as necessary, to verify the receipt of
approved wastestreams and to confinn receipt of nonhazardous waste material.
Sample retention in most cases is 30 days after acceptance into the laboratory.
1. Rejected Loads
Testing will be performed of either liquid or solid waste for the eight RCRA
heavy metals, volatile organic components or PCB 's. Ifthe waste is rejected, the
Nevada Division ofEnviromnental Protection and the Southern Nevada Health
District will be notified.
2. Acceptable Loads
(a) Non Hazardous liquids, Petroleum contaminated liquids or solid waste
successfully profiled and approved, and not considered suspect, will be accepted
into the appropriate liquid or solid cell by direct transfer from the transport
container. Soils are directed to the staging area where the waste is emptied from
the end dump trailers or bins into piles in preparation for screening and loading
into the treatment cells by front end loader.
(b) Liquid waste will be placed directly into treatment cells by opening the
back valve of the transport vehicles and dumping the waste. Once a treatment cell
has reached approximately 10% contamination, depending on the absorbent used,
the cell contents will stockpiled and sampled for the same pre-acceptance criteria
as other soils to be bio-treated (as described below). If no treatment cells are
available, and the solidified petroleum contaminated liquids require treatment as a
production priority, the soils will be profiled and treated in place. Absorbent
materials that have been found amenable to biotreatment include dirt,
diatomaceous earth and solid-a-sorb.
If, for operational reasons, the solidified soils of petroleum contaminated liquids
are found not amenable to bio-treatment (for example, due to the presence of
bactericides commonly used in maintaining sanitary systems), the material will be
profiled for acceptance into the Landfill. The analytical data required for
profiling the waste into biological treatment cells will then be used for
characterization of the soils into the Industrial Waste section ofthe Landfill. The
soils would be transferred by scraper or common loader equipment to the
Landfill.
3. Non-amenable Loads
If the soil waste is non-hazardous, but found not amenable for bio-treatment due
to pH, matrix or porosity effects, the analytical used in the pre-acceptance testing
17
Republic Environmenlal Technologies, Inc.
(TPH, volatile organics, heavy metals, or bioinhibition testing) will be used to
develop a profile of the waste for disposal into the Landfill.
4.2.7 Upon inspection clearance, necessary instructions for unloading the contaminated
soil will be provided to the transporter. Soils are unloaded within the lined area
and are stockpiled within the staging area ofthe STF. Liquid wastes are directed
to the Bioremediation facility into lined treatment cells. The treatment cells that
are accepting liquid waste will be clearly labeled.
4.3 Testing and Screening Procedures-
In-State Soils and Out-of-State Soils Other California
4.3.1 Prior to approval for treatment of soils, all generators shall complete a waste
profile form and submit it to Enviromnental Teclmologies for review and
approval by Republic's Special Waste Department. As stated above, it is the
responsibility of the generator to determine if the waste is hazardous. The role of
ET is to verify the generator has followed the proper steps in classifying the
NON-HAZARDOUS waste status and to determine compatibility of the waste
with the treatment system. All customers shall at a minimum provide the
following infonnation:
(1) Representative sampling and analysis for Total Petroleum Hydrocarbons
(TPH) via EPA method 8015 Modified
(2a) Representative sampling and analysis for total halogenated organic via
EPA Method 8260C for volatile organics; or
(2b) Documentation by the generator; that based upon knowledge of the waste,
no listed waste is present which would classify the material as hazardous
waste.
4.3.2 Based upon the findings of the TPH, additional information may be required to
confirm that the waste is NON-HAZARDOUS. This additional analysis may
include the following:
(1) Representative sampling and analysis for Toxicity Characte1istic via EPA
Method 1311;
(2) Representative sampling and analysis to determine for presence of free
liquids via EPA Method 9095.
(3) Representative sampling and analysis to determine for presence of
regulated heavy metals via EPA Method 1311 and/or Method 6010.
4.3.3 Environmental Technologies may waive certain tests if it can be conclusively
detennined what the source of the waste is, the lack of potential for waste mixing
or contamination with other regulated material, or documentation that the waste is
not hazardous under 40 CFR Part 261 or regulations in the State of Origin.
4.4 California Out-of-State Soils Acceptance Procedures
770 E. Sahara Avenue, Suite 100. Las Vegas. Nevada 89104
18
Republic Environmenwl Technologies, inc.
4.4.1 Out-of-state hydrocarbon contaminated soil from the State of California will be
accepted at the Facility only if the following information is provided to
Environmental Technologies by the generator, reviewed and approved by
Republic's Special Waste Dept. and send a copy of the approved profile to
SNHD:
(1) A letter from the regulatory entity governing hazardous waste
management within the state of origin attesting to the non-hazardous
nature of that waste,
or;
(2) Self-classification of the waste via procedures outlined in Article 11, Title
22 of the California Administrative Code. This self classification will be
recognized only upon a review of the information pertaining to the waste
acceptance application which must include a brief report containing the
following:
a. Site Description
(1) Location: description with site plan, including location of soil
samples, excavation, and stockpile.
(2) Site usage: both past and present (brief)
(3) Source of contaminate(s) (Surface spill or UST)
( 4) Description of contaminate product type
b. Laboratory Analysis
(1) Based on generator knowledge of site and contaminates, the
appropriate analyses should be selected.
(2) Generators will elect to do the following if sufficient information
or site history exists:
(a) Acute Aquatic 96 Hr. LC50: Aquatic Toxicity Assay is
required when generator knowledge is not sufficient to
waive this test. This test is required to be perfonned either
by the customer, prior to acceptance, or by ET as part of the
evaluation process.
(b) TTLC Metals Test
(c) TCLP Benzene (Needed if spill in not associated with a
regulated UST)
(d) Volatile Organics - 8240
(e) Total Petroleum Hydrocarbons (TPH) (note: TPH analyses
are not required by Title 22 CCR; however, it is needed to
establish petroleum contamination type and concentration).
(3) Analyses may include: (optional)
(a) Pesticides and Polychlorinated Bipenyls, EPA 8080
19
(b) Bases/Neutrals/Acid Extractables EPA 8270
(c) Ignitability
(d) Corrosivity
(e) Reactivity
c. Sample Protocol
(1) Description of sampling method
(2) All chain-of-custody records and analyses reports
(3) California Health Services Certification number for all laboratories
used
( 4) All information must be signed and stamped by a California
Professional Geologist or Professional Engineer
4.5 Liquid Petroleum Contaminated Waste
Petroleum contaminated liquids most often are the result of pollution control devices leading to
Publicly Owned Treatment Works (POTW) such as oil/water separators, and water I sand
separators. Additional sources of petroleum contaminated liquids come from triple rinsing of
UST's, well development water, petroleum grease traps and petroleum contaminated septic
tanks. Under the ET profile system, the generator must describe the system, the source of the
contamination and provide either analytical test results, MSDS data, or demonstrate sufficient
knowledge and control over their process as justification of a proper non-hazardous waste
determination, and sign a declaration the waste is non-hazardous waste. The Transporter then
signs all related documents indicating the material is properly described and contains no
hazardous waste.
Liquid petroleum contaminated wastes will be profiled before acceptance into the
Bioremediation Facility (see Attachment 6). Each profile will be evaluated and approved based
upon either analytical results or a self-classification of the generator's waste as allowed under
guidelines found in 40 CFR 261.1 0. Generators may be contacted in order to confirm proper
self-classification of the waste, and will be required to provide appropriate test documents or
Material Safety Data Sheets.
20
LIQUID SOLIDIFCATION AREA
Non-Hazardous liquids that found to be acceptable maybe solidified in the Liquid Solidification
area. These liquids are typically grease trap, porta potties type liquids, but may include other
liquid waste that is non-hazardous. Liquids with presence of petroleum will not be accepted at
the Liquid Solidification Area, but will be sent to the Bioremediation Facility
The waste acceptance procedure will follow the same profiling procedure as any waste going to
the Bioremediation Facility. The generator will fill out and complete a Republic Waste Profile
Form. Any analyst that is required wiJJ accompany the profile fmm. Once the profile has been
review and approved, it will receive a unique profile number. Any waste going into the Liquid
Solidification Area must have an approved profile number.
The liquid waste will be placed in a cleared slightly inclined borrow area. The borrow area will
be used for the solidification purpose of non-hazardous liquids. The soils in the borrow areas will
be prepared by allowing the liquids to be absorbed and blended into the surface soils. Additional
soils will be added as needed to solidify all liquids. Additional, materials such as saw dust, wood
chips, auto fluff maybe used to aid in the solidification process.
This waste category is identified as mainly, Grease Trap Wastes from food establishments, septic
waste from residential and porta potties businesses and other light industrial facilities.
No petroleum based liquid will be accepted for solidification. Liquids with incidental TPH
concentrations will be sent to the bioremediation facility solidification.
Liquid waste is discharged in a designated solidification area. There are typically two receiving
areas constructed in the borrow area for solidification purposes of grease trap, septic tank
pumping's wastes and industrial liquids that do not contain TPH constituents. The soils in the
borrow area are prepared by ripping the surface and stockpiling soils, allowing the liquids to be
absorbed and blended into the surface soils. Blending activities are conducted until free liquids
are no longer present in the resulting mixture.
A Paint test (Method 9095B) may be administered to verify that the soils have been blended with
the liquids and are solid and do not contain free liquids. All waste material will remain in the
designated area until the conditioned soils being analyzed meet the required solidification. The
solidified material is used as cover material over the landfill area as needed, or comingled for
disposal
21
VL MAINTENANCE
The Apex Bioremediation Facility is designed with little or no maintenance requirements. The
Facility is equipped with an industrial sized automatic sprinkler system, which is supplied by a 7
million-gallon fresh water reservoir. Simple water trucks, as back up to the sprinklers, are
capable of adequately watering the facility treatment cells, if needed.
VII. MONITORING
The facility is required to monitor and report certain activities. A copy of the Water Pollution
Control Permit and reporting form is included as Attachment 7.
7.1 Biological Treatment within Cells
Biological treatment of petroleum contaminated soils is monitored following the procedures
found in Section 3 .1-Initiating Bioremediation Activities
7.2 Rain Fall at the Facility
The facility also monitors rainfall events by utilizing a US Weather Service Standard Rain
Gauge. As more sophisticated technologies become available, this manual task is expected to be
replaced by computerized monitoring devices. The facility has been designed to contain the 25
year, 24 hour, rainfall event; and withstand, with no discharge, the run-off from the 24 hour,
once-in-1 00 year storm event. Monitoring of the rain gauge is perfonned daily simply by
observing and documenting the level ofliquid within a calibrated, graduated-type cylinder.
Once the liquid level is recorded, the water is discarded, and the gauge is placed back into its
holder.
7.3 Leak Detection and Leachate Systems
The entire Bioremediation Facility, cells and staging area, is lined with two layers of synthetic
liner. Monitoring the performance of the liner system of the double synthetically lined facility is
accomplished by checks for accumulations of liquids at specific monitoring locations. The
facility has a sloped and contoured design so any liquids present will migrate to one location.
The monitoring location is designed to inspect the interstitial space just above the upper most
liner (Leachate Collection Monitoring) and between the two liners (Leak Detection Monitoring).
Procedures and fonns for documenting the monitoring are included as Attachment 3. In the
event a leak should develop below any one individual cell, all soils would be required to be
removed to facilitate repairs. If the general location of a leak were not known, the leak could not
easily be located. Soils would be removed and liner inspections be made systematically, from
one end of the facility toward the other, in order to locate and repair the liner.
22
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7.4 Tons of\Vaste Accepted
Daily per load recording of the tons of waste accepted into the facility is accomplished by
certified scales positioned at the entrance to the facility. Each vehicle entering the facility will
be weighed, and a unique transaction number will be printed documenting the vehicle license
number, customer account number, and gross weight. The customer/transporter will then be
directed to the appropriate unloading area, i.e. the soils staging area or the petroleum
contaminated treatment cells. The vehicles will then cross over the scales again in order to
generate computer calculated net weight of waste received. All the information is documented
on a Dumping Ticket provided to the driver.
7.4.1 Weigh in Procedures
(1) Vehicle and waste will be inspected and all paperwork will be reviewed
(2) Customer account number and vehicle ID will be entered into the computer along
with initial gross weight
(3) Vehicle will be directed, or escorted, to the appropriate unloading area
( 4) Vehicle will again cross over the scales for tare weight and automatic calculation
of net weight*.
(5) Copies of manifests, bills oflading or dumping receipts will be acknowledged and
provided to the vehicle drivers
* "Gallons" received of non-hazardous liquids and petroleum contaminated liquids are
calculated by conversion of net weight, in pounds, divided by a conversion factor of 8. 8
pounds per gallon.
7.5 Tons of Soils Removed from the Containment Pad
The daily per load of tons of soil removed from the containment pad are only those tons received
into the containment pad. The phrase "containment pad" used for reporting, are the treatment
cells. Each customer's soils are assigned a particular cell for treatment. The cell number is
documented and cross-referenced to a specific account number established for that customer.
The total tons of soils within any individual cell is linked via the computer system to the net
weight calculated for each customer as the waste arrived. Once a cell contains approximately
3000 tons of soils, the cell is prepared for Initiation of Biological Treatment (see Section II-2.1).
Once the treatment is completed, the tons of soils placed into a cell are removed from the cell.
That tonnage is used to report "Tons of Soil Removed fonn the Containment Pad".
7.5 .1 Procedures for Calculation of Tons Removed from the Containment Pad
(1) Net weight of customers soils are automatically calculated and cross referenced to
the customers account number when the vehicle crosses the facility scales
(2) Each customers soils are assigned a specific cell for treatment
(3) Total tonnage of soils within a cell is calculated, and treatment begins when
tonnage approached 3000 tons
( 4) After treatment is complete, all soils placed into the cell (total tons) are removed
23
Republic Environmenlal Technologies, Inc.
7.6 Daily Maximum of Tons of Soils being Treated on the Containment Pad
The reporting of daily tons being treated with in the treatment cells is documented as those soils
received into a specific cell as described in Section VI- 6.4, above. The net tons within any cell
can be cross-referenced to a customer account number. A computer printout can be generated,
for any particular day, indicating the tons of soils received at the facility.
7.7 TPH in Treated Soils Prior to Removal from Containment Pad
Once again, the phrase "containment pad" used for reporting, are the treatment cells. The
procedure for determining the TPH concentration for treatment cells are provided in Section II.
7.8 Daily Maximum Gallons Contaminated Liquids in BioceUs
The volume of petroleum contaminated liquid waste accepted into the Bioremediation facility is
facilitated by using the facility scales; and converting the net weight of waste received into
gallons via a conversion factor. The procedure for tracking gallons received into the facility is
described in Section IV- 4.2
7.9 Tons of Solidified Media Removed from the Liquid Cells
Once the solidified petroleum contaminated liquids are prepared for biological treatment, the
soils are profiled (tested) as any other petroleum soils being profiled into the Bioremediation
Facility (see Section IV- 4.5). The soils will be moved from dedicated solidification cells,
estimates of cubic yards will be made, and tonnage will be calculated based upon volume using
approximately 1.3 tons per cubic yard. If production priorities require the solidified petroleum
contaminated liquids to be treated within their solidification cell or moved directly to the Landfill
operations without biological treatment. "Tons of Solidified Media ... " will be calculated, based
upon volume removed when the cell is cleaned out.
7.10 Liquid in the Leachate Collection Sump
The entire facility is lined with two layers of synthetic liner. The base grade of the facility has
been sloped (see diagrams in Attachment 2- Report of Design) so any liquids, that may collect
within the Leachate Collection System, drain to a central low spot that can be monitored for
moisture. The actual sump is not a man-way type structure, but rather a 6-inch diameter pipe
leading to the liner low spot. The procedures for detecting, and forms for documenting, liquids
in the sump are found in Attachment 3. The monitoring is perfonned weekly, or as directed in
the permit.
770 E. Sahara Avenue, Suite I 00. Las Vegas, Nevada 89104
24
7.11 Liquid in the Leak Detection System
Liquid in the leak detection system is monitored using the leak detection pipe designed the same
as the Leachate Collection Sump. The 3-inch diameter Leak detection pipe is located adjacent to
the Leachate Collection pipe, but is positioned to measure liquids that may be present at the same
low spot, except under both liners. The procedures for detecting, and forms for documenting,
liquids in the sump are found in Attachment 3. The monitoring is perfom1ed weekly, or as
directed in the permit.
7.12 Groundwater Monitoring 'Vell #5
Well #5 is located immediately north of the Bioremediation Facility and the 7 million-gallon
reservoir (see Figures 1). This well provides water to the reservoir. A..lmual monitoring and
reporting of Well #5 for TPH, by Method 8015B, and VOC's by Method 8260B (including
MTBE), is accomplished by collection of water exiting the active pumping well. Water will be
collected at the well head sample port. A water sample will be collected into two (2) full 1-quart
glass jars, and three (3) VOA vials, with zero headspace. The samples will be immediately
placed into an ice chest and transported to an off-site laboratory certified for testing for TPH and
VOC's.
25
Environmental Technologies ofNevada, Inc.
Wire
Monitoring Probe Design
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Republic Environmenza! Technologies, Inc.
V1II. SAFETY
Standard level of personal protection required at the site is Level D. Level D Personnel
Protective Equipment includes:
o Coveralls
o Gloves
o Boots/shoes, leather or chemical-resistant
o Safety glasses as needed (Optional)
o Hard hat (Optional)
Beside the chemicals present in the contaminated soils, the only chemicals used at the facility are
water and fertilizers containing nitrogen and phosphorus based supplements.
IX. EMERGENCY CONTACTS
The following list provides names and telephone numbers for emergency contact personnel. In
the event of a medical emergency, personnel will take direction form the appropriate emergency
organization. In the event of a fire or spill, the site supervisor will notify the appropriate local,
state, and federal agencies.
Organization Contact
Ambulance MERCY
Police METRO
Fire: CLARK COUNTY FIRE DEPT.
Regional IX EPA
State Authority (NDEP)
Local Authmity (CCHD)
National Response Center
Center for Disease Control
Chemtrec
Management
Mark Clinker - Landfill GM
Tim Hipps- Landfill Operations Manager
Dave McCafferty- Landfill Operations Manager
Rob Tidwell- Regulatory Compliance
Dave Fink- Medical Waste Manager
Emergency Response Coordinator
Elaina Turner- Safety
Telephone
911
911, (702) 799-3403
911, (702) 455-8579
415-947-8000
(702) 486-2850
(702) 759-1000
800-424-8802
1-800-232-4636
1-800-262-8200
Telephone
(702) 599-5901
(702) 599-5902
(702) 599-5902
(702) 599-5907
(702) 599-5632
Cell: (702) 280-0057
(702) 599-5917
27
Environmental Inc.
770 E. Sahara Avenue .. Suite 100, Las Vegas, Nevada 89104
28
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STATE OF NE:V!.DA
6.. H. !'ilifl ,"\!U1\

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DEPARTMENT OF CONSERVATION AND NATURAL RESOURCES
DIVISION OF ENV ONMENTAL PROTECTION
C.lp!to! Compb
J:!J W. Nyi! Lane
Cu-wn City, Nenda 8.9il 0
.June 20, 1994
TOt All permitted Hydrocarbon Contaminated Soil Treatment
Facilities in Nevada
SUOM: Allen Biaggi, Chief, Bureau of Corrective
StmJ5CT: Testing and Scre'ening Procedures for Waste .Acceptance and
Receipt of out of state waste.
This a to and policry of
January 25, 1991 and subsequent issued by the
Division.
Due to inconsistencies in acceptance . procedures between
_permitted soils treatment facilities in Nevada and new regulatory
requirements, the Division has determined that a need exists to
standardize waste testing and analytical procedures. Commencing
July 1, 1994 the following minimum testing requirements shall be in
place for all permitted soil treatment facilities in Nevada:
* Representative sampling and analysis for Total Petroleum.
Hydrocarbons (TPH) via EPA Method 8015 (modified}i
Representative sampling and analysis by EPA Method 8240 for
volatile organics;
Preaeceptance field screening (prior to facility acceptance)
for halogens using the copper wire test or equivalent;
Screening for other contaminants which :may be expected to be
present in the waste stream (i.e. dielectric fluids or mineral
oil-PCB's, waste oil-heavy metalsr etc.);
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June 20, 1994
Pagl3 2
NOTE: These are mi:aim1..11n screening criteria only. The
may require additional tests as necessary.
The Division is willing to consider waiving certain tests if
it can be determined what the source of the waste is,
the lack of potential for waste mixing or contamination with other
regulated material and documentation that the waste is not a
hazardous waste under 40 CFR Part 261.
The Toxic Characteristic Leachate Procedure (TCLP) in 40 CFR
261 requires the evaluation of waste for toxicity. A major
component of this rule is the evaluation of certain organic
compounds most notable of which is benzene.
o:f TCLP require:ments is in place for UST related contaminated
debris and media, contaminated debris and media from other
sources (i.e. trucking accidents, above ground tank releases,
releases from unregulated tanks) must be evaluated for hazard via
. TCLP prior to acceptance unless other knowledge can be applied
which documents the non-hazardous nature of the waste.
caution should be taken when accepting waste material from sources
other than those related to USTs.
Out of state hydrocarbon contaminated soil may be accepted
only if the following information in 1 r 2 or 3 is provided!
revie.,led and approved by the Division:
1. A letter from the regulatory entity governing hazardous
waste management within the state of origin attesting to
the non-hazardous nature ofthat waste, or
2.
3.
Evidence that the waste is not hazardous using
the regulatory provisions of the state of origin.
Self declassification (California derived waste only) of
the waste via procedures outlined in Article llr
Title 22 of the California .Administrative code. This
self-declassification will be recognized only under the
following
A.
B.
Sample protocols must be certified as
representative by a California Registered
Professional Engineer or Geologist. .A wet
stamped letter of certification is requlred;
All tests required under Title 22 for
self-declassification must be conducted and
results be at or below the specified critical
levels unless other generator
can be applied which documents t.-he
non-hazardous nature of the waste.
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June 20, 1994
Page J
C. All sample protocols, test methods
f
cert1f1cat1ons and results must be reviewed by
a Nevada Registered Professional Engineer or
Certified Environmental Manager knowledgeable
of California and Nevada wasta regulations.
The Nevada portion of the review must include
a recommendation to the Division on whether or
not the material meets the Title 22
requirements for self declassification.
D. All data is then provided to the Division
along with the results of all tests and
associated recommendations for acceptance. A
review will then be conducted by NDEP and a
de:termination made as to the hazardous
status of the soils and applicability for
importation into Nevada;
E" All testing and screening procedures placed
upon the treatment facility still apply to the
waste materiali -
Individual facilities may post a bond or other financial
assurance instrument acceptable to NDEP, the amount of which shall
be determined by calculating the average importation project waste
load processed at the facility per calendar year. For facilities
with an average imported project waste load in excess of 500 cubic
yards,. the bond amount shall be $100 r 000. For facilities importing
an average project waste load below 500 cubic yards the bond amount
be $50, 000. After the proper posting of this bond or other
financial assurance instrument, soils may be imported without the
specific written approval of the Division prior to acceptance at
the facility. However, .. all the above referenced relevant tests by
California and Nevada environmental professionals including
recol!Uilendations for acceptance by the Nevada CEM shall be provided
to the Division for review on a monthly basis.
Each project subject to these requirements shall be tracked
and segregated in the treatment unit in case removal is required at
a later time.
The Nevada CEI-1 may include employees of the treatment
facility.
If the improper acceptance of a hazardous waste is determined
through the monthly reports or other means, the Division shall
immediately notify the facility and require actions be undertaken
for the :material r s timely removal .
from the facility and proper disposal at a permitted TSD at tne
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1994
4
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facility or If the lity cannot or will not
commance removal of (i.e. contact a TSD, begin
additional amplinq or analytical etc.) in a timely manner
(within 5 days) may call for the bond and use these
funds to pay for th!!lil proper disposition of the materiaL
These procedures are the only way pt\ttroleum conta:m.inated
materials and granulated activated carbon (GAC) if the
facility permit allows) can be legally imported into Nevada for
disposal or treatmant other than as waste to a permitted
'l'SD facility. It you have any information on the improper
importation into Nivada, plca!Ol1 notify the Division.
I hop!!ii will clarify the Divisions oosition on this
If que$tions .or feel free to
contact :me.
EnvironmenirJ Technologies, Inc.
Selected excerpts from the engineer's Report of Design originally sent to NDEP
under separate cover from Vector Engineering, Inc. dated February 2, 1994
entitled; As-Built Report for the Apex Regional Waste Managenzent Center Soil
Treatment Facility Double Liner System.
770 E Sahara Avenue. Suite I 00. Las l'egas. Nevada 89104
29
AS-BUILT REPORT
for the
APEX P.EGIONAL W4SIE
l'r!ANAGEMENT CENTER
SO JL TREA_._TMENT FACILIT""r
DOUBLE liNER SYSTEM
Prepared for.
Environmental Techn-ologies of Neva.rla, Inc.
77() East Salwm Avenue
Las Vegas
1
Nevada 89104
(702) 734-5400
Prepared by:
Vector Engineering, lite.
1601 Fairview Avenue, Suite H
Carson City, Nevadil 89701
(702) 883-7065
Jab No. 935015.00
7
Phase 5S
February 2, 1994
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-NG INEERING, INC.
February 2, 1994
Job No. 93.5015.00
Mr. James Smitherman
Errvironmental Management Specialist ill
Bureau of Water Pollution Control
Nevada Division of Environmental Protection
333 W. Nye Lane
Carson City, Nevada 89710
Re: Apex Regional Waste 11anagement Center Soil
Treatment Facility Double Liner System As-Built Report
Dear }Af. Smitherman:
This letter is intended to provide as-built docmnentation for the double llirer installed
at the Apex Regional Waite Management Center, soil treatment facility (STF). The design
of the STF was based on meetings between your department and Vector Engineering, Inc.
(Veetor) in early November of last year. The purpose of the double liner system is to
provide a means of detecting leaks through the primary geomembrane liner; The design and
installation of the STF was conducted according to the Vector letter dated November 4,
1993. This letter has been included with this report in Appendix A.
L11 order for contaminated soil to be placed on the STF, the liner system must be installed
and observed to verify compliance with the project plans and specifications. As part of the
CQA inspection services at the site, Vector observed the installation of the minus 3/4 inch
subgrade soil, seconcia_ry 30 mil BDPE flexible membrane liner, one foot thick granular
drainage layer vrith collection piping, 60 mil HDPE primary geomembrane liner,
geocomposite drain layer, leachate collection pipeline, leachate collection \leak detection
sumps, and operations layer protective soil cover. During installation, Vector provided
continuous observation of ill liner phases. with a field staff of one quality assurance monitor,
a CQA project engineer who routinely visited the site throughout the construction, and
lffil fairview Ave., Suitt: H Carson Cicy, t-IV 89701
5
(702) 883-7065 Fax: (702) 883-7161
GR.AS:S VALLEY, CA UTil..ITON, CO ' SA.l:'<'Tl!-DD. CHILE
----

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sri MIL SMOOlH HDPE .PRJMARY LJNER
'
' DRAJNAGE LAYE."'R MATERlAL
30 MIL SMOQTI-1 HDPE SECONDARY UNER
3 FT.
(min.)
COMPACTED
BACICF1LL
3 FT.
(min.)
------""'! I FT. I

NOTE: EXTEND WELDS FOR UNER SEAMS
MINIMUM 1 FT. INTO ANCHOR TRENCH
TYPICAL ANCHOR TRENCH EBB
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administrative support staff. Vector's CQA monitor prep3.1-ed daily field construction reports
during the errtire liner system installation.. Appendix B coo.tains these daily reports.
Vector's CQA monitor observed subgrade (foundation) preparation prior to liner deployment.
Areas were cut and filled to render a fum foumi?-tion. The relative compaction of the
sub grade was tested and found to meet the requirements of 90% of the maximum dry density
as determined by ASTM D-1557. A summary of these tests is provided in Appendix C.
The subgrade was then rolled 1vith a smooth drum roller and insped:ed for suitability of
geomembrane placement. A record of these tests and observations is provided in
Appendix D. Following completion of the prepared sub grade, the instillation of the smooth
30 mil HDPE geomembrane begaiL Prior to deployment of any geosynthetic material, the
manufacturer's quality control documentation was reviewed by Vector's CQA monitor and
the CQA project engineer. According to that documentation, all material utilized in the
construction of the STF met the required values as stated within the speciiications.
As each geomembrane panel was placed, Vector's CQA monitor recorded the temperature,
wind conditions, panel number, roll number, and location. Prior to any seauling activities at
the beginning of each day and on.ce during the middle of the shift, a test seam (start-up trial
weld test) was prepared for each extrusion and! or double wedge welder used for that shift.
The Contractor's seaming technicians prepared a test specimen and marked the sample with
the machine number, machine temperature, date, time, and therr name. Vector performed
shear and peel te..sts in the field in accordance with ASTM D-4437. If the start-up weld
sample -failed to meet the project specifications, the welding technician and the liner
installation supervisor were notified and recommended to take corrective action or place the
machine out of service. No weldi.tl.g machine or technician began work until a start-up weld
was tested and shown to conform t ~ the requirements.
The geomembrane panels were seamed in the field using double-wedge fusion and extrusion
welding techniques by the Gundle Lining Systems crews. Vector's CQA monitor observed
the seaming activities and observed for proper panel overlap, cleanliness of the seams,
grinding where required, and the preheat and weld temp....=ratures of the equipment used.
Seam continuity was tested by Gundle using the air pressure and vacuum boX. methods.
Vector's monitor observed the seam contiuuity testing performed by Gundle's QC technicians
and maintained documerrtation. of this procedure. This documentation included recording the
seam number, QC technician, test type, number of repairs and their loca.tions, dates of
repairs and retests, and the CQA monitor observing the testing.
!eDe!:
Feb mary 2, 1994
Pogo 3
-----------------------------
In addition to nondestructive quality control, destructive samples were obtained at random
intervals of approximately one sample per 500 linear feet of seam as determined and located
by the Vector CQA monitor. Each sample was at least 12 inches wide by 40 inches 1orrg and
was cut by Gundle and provided to Vector for determination of bonded seam strength in
shear and peel according to AS'.Thi D-4437. All destructive sear:u evaluations were
accomplished on-site by Vector's CQA monitor using a field tensiometer. All finished field
seams from the STF liner system met the requirements of the specu'lcations for shear and
peel strength. The results of the destructive testing on the 30 mil HDPE secondary liner are
provided in Appendix E ..
After the 30 mil geomembrane was installed, a final w.alkdown was conducted by Vector and
Gundle. The final starus of each panel was recorded on a '
1
panel acceptance form" which are
included as Appendix F. 1ne leak detection and removal system layer was then placed.
According to our testing and observations, all material components met the requirements of
the specifications and the letter to NDEP dated November 4, 1993 (included in Appendix A).
As previously mentioned, Vector's CQA monitor carefully observe<:! the placement of the
drainage layer and collection piping to verify that the underlying 30 mil geomembrane was
not damaged.
After the leak detection layer was placed, the primary 60 mil BDPE liner was installed. The
manufacturer's certification, CQA testing, observations; and documentation conducted orr the
30 mil secondary rul.er were also conducted on the 60 wil primary liner. Documentation of
the acceptance of the completed 60 mil HDPE panels is provided in Appendix G.
Documentation on the shear and peel (destructive) testing conducteD on the 60 mil
geomembrane seams is provided in Appendix H. After primary liner placement,
geocomposite leachate collection sb:;ips and a.s.sociated collection piping were plac.ed. The
operations protective layer was then placed over the STF primary liner and the area was
opened for placement of the soil treatment cells and subsequent contarflinated soil.
As of the submittal of this letter, and based on our observations and testing, it is our opinion
that all components of the STF liner system were installed in general accordance with the
project plarts and specifications. Drawings showing the as-built configuration of the STF are
included with this letter. This letter was prepared in accordance with generally accepted
soils and geosynthetic engineering practices applicable at the time the letter was prepared.
Vector Engineering, Inc., makes no other warranties, either expressed or implied, as to the
professional advice provided under the terms of this agreement, and as described in t:his
letter.
Mr. hm<t5 S roltho..;,w
F<ob-nUtry i, 19-!4
hge4
If you require any additional infurrnation
1
please do not hesitate to call Scott Purdy or Mark
Smith at (916) 272-2448. Your timely review and approval of this letter is greatly
a._vpreciated. Environmental Technologies of Nevada, Inc. will begin operation of the STF
L'TIIDediately following your approval.
Regards,
VECTOR ENGI},('EffiliNG, illC.

Scott Purdy, CQA Project Engineer
Vice President
Mark Smith, P .E. 6546
President
cc: Johnnie Isola - Ef
Thomas DUMPCo
Doug 1:'1'l:artin - Y ector
enclosu.L--es: Appendices
As-built Drawings
N: \9350 15\WP\STFCERT .LTR
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l'"GiliEERINLi INC.
November 4, 1993
Job No. 925010.0
MI. James Smitherman
Environmental Management Specialist III
Bureau ofWater Pollution Control
Nevada DiVision of Envirornnental Protection
Capitol Complex
333 W. Nye Lane
Carson City, Nevada g9710
Re: Liner System. Soil Treatment Facility- Apex Regio:nal Waste
Il'fanagement Center
Dear Tlm,
Following a meeting and subsequent phone calls between NDEP and Vector
Engineelliig on Novembcr.-2and 3, 1993, a double liner system was p.wposed for the soil
treatment faciliiy .(STF) at, the Apex Regiorral Waste Management Cerrter. The prn:pose of
the double liner system is tD provide a means of detecting any leaks through the primary
liner. A detailed cross seciion of the proposed design has been enclosed this letter.
From top to bottom the system consists of the following components:
L Operations layer (material next to liner will b-e Screened to 3/4 inch minus).
2. _Geocomposite (geotex:.tile/geonet) strips placed below the operations layer that
will act as a leachate collection system and convey any liquids to a collection
sump.
3. Primary cbmposed of 60 mil HDPE geomembrarre.
4.
5.
6.
_ One foot tbick leak detection layer composed of proces-<::e:d 3/4 inch minus
compacted on-site materials with an internal piping system to increase the flow
capacity. This layer will drain to a central collection point that will be
monitored for any potential leakage.
Secondary liner composed of 30 mil HOPE geomembrane.
Smooth, fum subgrade layer that is suitable for the placement of liner. The
subgrade material Mll consist of on-site material screened to 3!4 inch minus
3lld compacted to 90% of the maximum density as determined by ASTM: D-
1557.
l6'Jl hb:vicw Ave .. Suite: H City, NY 8970i s (702) 88.3-7065 Fa:c: (102) 883-7161
GRASS VALLEY, C.'-. UTRETON, CD S.AJmf-.GO, CHILE
Complete as-built drawing! of the STF will be prepared and submitted to NDEP
following ronstructicm of the facility. The 2.3-built drav.dngs will be :mcnn.irtfd within 15 days
following installation of the STF which is scheduled for completion in Jate December of this
ye:a:r. In addition, a certification letter (smmped by a civil engineer registered in Nevarla)
will be provided stating that the .liner system was installed according to the requirements of
the pernrit and the design plans and specifications.
We hope this letter satisfies your requirements for is:suance of a permit for the STF at
the Apex Regional Waste Management Center. If you have any questions concerning this
matter, plea....e do not hesitate to call the undersigned at (916) 272-2448.
Regards,
VECI'OR INC.
Scott Purdy
Vice President
endosure
cc: Johrurie Isola- ET
Tom Isola- Silver Stare Disposal
Doug 1Yfart:in- Vector
\!ECTOR
y ENGfNEEPJNG, flv'C.
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APPENDIX A.
LINER SYSTEM DESIGN LETIER
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GEOCOMPOSITE DRAIN LAYER STRIP
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: . ;,;,_ , , ' LEAK DETECTION LAYEi'l
30 mil HOPE
PREPARED SUBGRADE
Soi[ Treatment Facility
Liner System Cross-Section
I T ;-ECTOR
I v NC-TNEERINC, iNC
APEX REGIONAL WASTE CENTER
ENVIRONMENTAL TECHNOLOGiES
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APPENDIX B
DAILY FIELD CONSTRUCTION REPORTS
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APPErtDIX C
FIEID DENSITY TEST SUMi"\iARY
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APPENDIXD
SUBGRADE ACCEPTANCE FORMS
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DESTRUCTIVE SEAM TESTS ~ 30 1\fiL HDPE
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APPEJ\1}) IX F
P ANTI ACCEP1A.NCE FORMS 30 MlL HDPE
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APPENDIX G
P .. I\NEL ACCEPTP..NCE 60 :mL HDPE
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APPENDIX ff
DESTRUCTIVE SEAM TESTS - 60 :MIL HDPE
KE'pub/ic Emnrnnmemal Technologies. Inc.
770 E. Sahara Avenue. Suite I 00. Las I 'egas. Nevada 89104
30
Leachate and Leak Detection JVlollitoring Procedure
Originally Issued: JUI\:'E 26, 1994 ET 1904
Revised: August 31,2011
Approval: ____ _
1. Purpose and Scope
The Apex Waste Management center is required to monitor for the presence of liquids in the
collection system of the Soil Treatment Facility (STF). The Soil Treatment Facility is a double lined
system with both leak detection wei leachate collection systems.
2. Monitoring Schedule
2.1 The Leachate Collection System of the S TF will be checked Weekly per permit
2.2 The Leak Detection System of the STF will be checked Weekly
3. Leachate Collection Mon:itoring Equipment and Interpretation of Data
3.1. Equipment
The Leak detection and Leachate Collection System monitoring utilize one of two methods to
check the sumps. One method is the dip stick method, using a pole placed dovm_ the sump and
the other method involves probes which are essentially simple wires to act as an extension of
a Volt/ohm meter terminals. The dip stick method will measure the wetness on the pole
placed inside of the sumps. The follo-vving procedures would be followed if using an electric
probe. The probes test for an "Open" or "Closed" electrical circuit in the absence or presence
of water, respectively. The Meter is connected to the wires at the top of a probe. The wires
lead to exposed terminals at the bottom of the probe which are placed into the low spot of the
STF (See Figure 6). \Vhen the system is tested using the meter in the Ohms Mode, the
presence of water completes an electrical circuit, and registers as an "Closed Circuit" with no
resistance or having continuity of a circuit
The monitoring of both the Leachate Collection and Leak Detection Systems utilize any
electronic meter capable of measuring Continuity, such as a Fluke Electronic Tester or a
WaterMark Model30KTC Meter. The Fluke Meters are standard electronic meters and are
the preferred meter. The backup meter is the W aierMark. The WaterMark meter is actually a
soil moisture meter. This meter can be obtained from Irrometer Company, Inc., P.O. Box
2424, 8835 Philbin, Riverside, California, 909-599-4424.
Leachate and Leak Detection Monitoring Procedure Page 2 of3
3.2. Leachate System- Interpretation of Data from the Meter
The Leachate System test is also designed to check for an "open circuit" versus a "closed
circuit" The presumption is liquids present in a sump will contact the probe completing an
electric circuit Measurement of cominuity \Vith a Fluke Meter is a measurement of the
presence of liquid. The WaterMark meter operates on a more sensitive principal. This
meter is actually designed for measurement of moisture in soil. Consequently, when
following the manufacturer's instructions, a "beep" by the meter indicates a moist soil
condition and not the presence ofliquids.
In order to compensate for the sensitivity of the Watermark meter, the following procedures
v-rili allow for interpretation of the meter.
3 .2.1. Set the meter to the following Initial Settings:
- Scale+ 0
- 6 on the Dryness Scale
- Soil Temperature at 75
3 .2.2. Touch the nvo leads of the meter together and press the Red Button to check the
operations of the Meter. A "beep" should be heard. If not, replace the batteries and
repeat step 2.
3 .2.3. Connect the leads to the Detection Probes and press the Red Button. No "Beep"
should be heard. Record results and sign the Inspection Log.
3.2.4. If a "beep" is heard, turn the Dryness Scale Knob to "0" and retest If no
"beep" is heard, slowly increase Dryness Scale setting until the "beep" is heard.
Record reading and sign the Inspection Log.
3.2.5. If a "beep"continues to be heard at the "0" Setting, with the Meter still
connected slowly raise the Detection Probe out of the Detection Pipe in order to
determine the depth of any liquid that may be present If raising and lowering the
Detection Probe indicates more than 1 foot of liquid in the Collection System, notify
your supervisor in order to collect a sample of the liquid.
3.2.6. If raising and lowering the probe indicates less than 1 foot of liquid exists in the
Collection y s t e ~ record the observation and sign the Inspection Log. Notify your
supervisor of the observation and re-inspect the Collection System the ne:xi day.
Leachate and Leak Detection Monitoring Procedure Page 3 of3
3.3 Leak Detection System- Interpretation of Data from the Meter
Just as in the Leachate System, the Leak Detection uses the Fluke meter as the preferred meter sinGe it
involves no interpretation of the test, except for the "open" or "closed" circuit test based upon the
absence or presence of liquid. The WaterMark meter requires much more interpretation. Moisture
content of soil under the liner of the System is expected to vary greatly depending on the time of the
season, rainfall for the area, and condensation produced by the liner. Generally, baseline data -will be
generated over time which -will provide guidance on what to expect for the moisture content of soil at
various times of the year.
The way the liner system is instilled, situated under the entire facility, locating the precise location of
a small leak under one cell is difficult If sufficient data is generated indicating a liner has failed to
perform as expected, and leachate may be entering t ~ e environment, soils v,ill be removed
systematically from the Facility in order to inspect the liner and make repairs.
4. Handling and Disposal of Leachate Liquids
Excess rain waters not taken up by the soils within the STF are expected to be collected within the
Leachate Coliection Systems. If Liquids reach approximately l/2 gallon in volume, capturing a
sample for analyses would be possible. No liquid has yet been detected in either system. The
leachate will be analyzed for the presence of:
1. Total Petroleum Hydrocarbons (TPH) by EPA Method 8015 Modified
2. Total Volatile Organics by Method 8240 and
3. The 8 RCRA Total Metals by Method 6010
Based upon the results of the analyses, a non-hazardous, petroleum contaminated leachate would be
disposed of into the Bioremediation facility liquid solidification cells. If the liquids were not
petroleum contaminated, they will be disposed of as septic mixed waste for solidification and
disposal into the municipal landfill. As an alternative to municipal disposal, the liquids would be
handled as if they were petroleum contaminated. If the liquids were deteiJJJined to be a hazardous
waste, the liquids would be disposed of at a permitted hazardous waste treatment facility.
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Environmental Technologies. Inc.
770 E Sahara Avenue, Suile 100. Las 1 'egas. i\'evada 89104
31
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AND OF WASTE ACCEPTANCE
APEX SOIL TREATMENT FACILITY
April!, 1995

Own<lr.

Qw:n:lty Soil: YMh
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NDtify IT Eq'<=n!AliYo. twonty-foor (24) hour>< prior !r.<ru;po.-tlng soil to tho Sci.! Tr=mcrn F&cili:ty
. " H= o[It'*f'L>= !!l tl:i<:> Soil Troalrnern. PMiiity ue 7:00 lUll to 3;{1() pm (M..na thru Fri.).
" All ""J to th-o Soil F.!tlity must bo propcdy liccru;cd ,00 in corop\1;mce '\li'of.b pp!i:c.&bk l=U and st!.\b
ROO dump vchlcfe! mrut h.I!?D !1illpw.
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SMrnwnt by Wm Generntor r Slte Owr!a Qr fu.cir Aufuortzed
'1 hereby ll:uthorize Envi.roruocnW. Teclmoiogie;; of Nw;;da, Inc.. (ET) to the ;;ubject in support of this Applica
my I05pDflbibility to ensure thAt ET is reimbursed for ill prof=ioo.al seivl= rendered in the processing of
application 8Ild H:Cknowlcdge the conditiom- ;md cost estimates associated Mth ET' s acccpl:lmco, trea:f:rnellt and of thb wl
waste soiL Furthef]'1}Dre., I he:roby certify that on.ly 1:00 waste soil identified in our Application for W!L'<te Acccpbmco wil
tnmsported to the Soil Tre.a!:rnent F!Cility md certify that no Mzardous defined by \]lo Code ofFcdenll Regulati()J)S (4D <
261), will be t=spmted. to the Soil Treatment Focility.
(Slgna.tiJre)
(Date)
Republic Environmfl7tal Inc.
770 E Sahara Avenue. Suite I 00. Las f
32
.Nevada 89 I 04
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.. Es!im.3.ted Quantity of Contaminated Cubic Yards; ____;,_ ___ Tons
Nature of Soil Contunj.rumts (i.e. gas, diesel, motor oil, etc ..
- .
Sampling Methodology
(ag. Arl:o:r, HMd oc Ooo (XX J?&
Volume Sample Taken: of Taken:

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Regulations. I
ET facility at my
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roils are to

::ertllkatltm. by or in the state of Srunple
protocols are, herein, certified as repr_esentative;.
Wet Stamp:
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Sample Locailon by Sample l. D,
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770 E. Sahara Avenue. Suite 100. Las Vegas, l\
1
evada 89104
33
Republic Errvironmental Technologies of Nevada, Inc.
Liquids and Petroleum Contaminated Liquids
Handling Procedures
Originally Issued: October 14, 1993
Revised: September 2, 2011
1. DEFINITIONS
ET1902
1.1 Septic Waste: Septic waste is liquid waste, or sewage waste, originating from households,
businesses, portable toilets, and/or industrial sources. This liquid waste may contain human
y,raste, kitchen cooking waste, animal fats, and vegetable greases. Septic waste can not
contain petroleum hydrocarbons.
1.2 Contaminated Liquid Waste: This liquid waste may contains petroleum hydrocarbons and
can originate from a number of sources. For example: Oil water or sand separators, sumps,
car washes, and automotive shops. Gasoline, motor oil, petroleum greases, and diesel are
common contaminates.
1.3 Non-hazardous waste: A waste that is not regulated by the Resource Conservation a11d
Recovery Act (RCRA), and is not regulated as a hazardous waste by tbe state where the
waste \Vas generated.
L 4 Profile: A description of the generating process, generator, and transporter of said waste.
This includes a declaration that the waste is not a hazardous waste.
1.5 Non-hazardous Waste Manifest: This is a tracking document used to identify and transport
septic and contaminated waste to the Apex Waste Management Center.
1.6 Septic Hauler: A person or company that is registered with t ~ Southern Nevada Health
District to transport and handle septic waste.
Z:\E1\EVERYOJ.,TE\Heal1h and Safety Programs\ET_H&S\ETl902 Liquid Waste Procedmes_doc
2.1 All septic and cont:a:rJ::ilnated liquid waste must an approved profile prior to acceptance.
22 Profiles will be established for all Equid waste whether they are septic, non-hazardous and
petroleum contaminated liquids:
3 Non-hazardous Waste Manifest:
3.1 All shipments of liquid waste must be accompanied with a non-hazardous waste
manifest. (Figure 2)
3.2 The manifest must be legible and in English.
3.3 Gate personnel will utilize the Septic and Contaminated Liquid Waste Check List
(Figure 3)
3.4 If there is a discrepancy or some type of problem, this must be noted in section 13.
3 _5 One copy of the manifest will be kept at the landfill, one copy given to the driver or
transporter after it is signed, and one copy sent to RET.
3.6 Tbe load checker will inspect all loads and ensure the manifest is properly filled out
before signing manifest.
4 Load Verification:
4.1 All trucks will be checked to ensure that vehicle is properly registered with the Southern
Nevada Health District (SNHD). Note: only Septic Liquid Waste Haulers are regulated
by the 8]\Jl-JD.
5 Non-conforming Shipments Liquid Waste:
5.1 RET will be notified immediately of any nonconforming shipment of liquid waste.
5.2 The transporter or generator will be notified that the load was rejected. A load rejection
form will be sent to the SNHD.
Z:\ET\EVER YOf,TE\_B:ealfu and Safety Programs\ET __H&S\ETlc:KJ2 Liquid Waste Pmced.ures.doc
--------------- - ------------ ---- -
.. ---- . .. . _. --. -- . .:..: ____.:..:..c -- .. - ....:..:.:._,
.. .-.--------- -- . .. .. .-
6.1 Transporters \vill be instructed into wbich cell they are to discharge their load.
62 Septic and Non-Hazardous liquids will not be mixed \vith petroleum contaminated
liquids.
7 TREATl\1ENT CELLS:
7.1 Soils from solidification of Septic cells will be used as cover material for the landfill.
7.2 For Petroleum Contaminated Soil cells, a representative sample will be obtained at the
time the cell is full.
7 .2.1 The Republic profile number for the sample \Vill be included on the Ceil
Treatment form.
7 .2.2 The sample will be taken to a laboratory for analysis by EPA method 8015
modified and toxicity.
7 .2.3 Disposition of the solidified cell \\rill be specified by RET.
7.2.4 Once the cell has been cleaned out, one verification sample vml be obtained
from each end of the cell. These will be analyzed for TPH by 8015 modified
and RCRA 8 metals by EPA method 6010.
8 CELL CONTENTS AND DISPOSITION:
8.1 All septic cells will be used as cover material for the landfill. Two discrete samples will
be obtained, one from each ancL These samples will be analyzed by EPA Method 8015
modified_
8.2 Non-septic cells will either be sent to STF or used as cover material for the industrial
landfill. Two discrete samples will be obtained
7
one form each end. These samples will
be analyzed by EPA Method 8015 modified.
and Safety Programs\ET_H&S\ET1902 Liguid Waste Procec\u;"es.doc
9.1 All liquids going to the solidification area vrill have gone tbru the waste characterization
profiling process. All liquids Virill have an approved profile number.
9.2 Liquids discharge into the solidificaiion area will be blended -with soils until no free
liquids are visible. Other materials maybe use to assist in the solidification process,
such as wood chips, saw dust, and auto fluff are few examples.
9.3 A paint filter test will be performed to verify that the material is acceptable for disposal
into the landfill. Once the material has been approved it i ~ l l be sent to the landfill for
disposaL
Z:\ETIEVERYOl'-<'E\Healfu wd Safety ?rograms\ET_H&S\ET1902 Liquid Waste Procedures.doc
Z:\ETIEVERYONE1Heal1h and Saiety Prugrarns\ET _R&S\ETJ902 Liquid Waste Procedures. doc
,-.-,--.-.--.-.-----;-c;--.--- -.-.-.
0 Generator's name, address, and telephone number complete.
D Approved profile number.
0 Transporter's name and phone number is legible.
[] Appropriate box checked for type of liquid waste identified by
profile.
D Total volume and units correspond with truck and paper work.
D Additional profile numbers listed in section 11 for bulk profile.
Number of gallons for each additional profile add up to what is
listed in section 9.
D Transporter has printed or typed name, signed, and dated section 12.
0 Vehicle has been inspected by Southern Nevada Health District.
0 If other (section 8 line e) is checked, is additional description of
material in section 11 explained satisfactorily
0 White copy to Landfill, pink copy to RET, and Yell ow copy is
given to driver.
0 If load is suspected then contact RET. If load is rejected, then a load
rejection form will be completed.
0 If uncertain or nonconforming load is found contact RET dispatch.
Z:\ETIEv'ERYONE\I-Iealtb and SafetyPrograms\ET_H&S\ETl902 Liquid Wme Procedures. doc
Republic Environmental Technofogies, Inc.
770 E Sahara Avenue, Suite I 00, Las VE'gas, Nevada 89104
34
Permit
DIVISION OF ENVIRONIVIENTAL PROTECTION
AUTHORIZATION TO DISCHARGE
In compliance with Chapter 445A of the Nevada Revised Statutes,
Republic Environmental Technologies
770 E. Sahara A venue
"Las Vegas, Nevada 89104
is, according to the requirements of this permit, authorized to discharge 1) hydrocarbon-
contaminated soils; 2) non-hazardous hydrocarbon contaminated liquids; and 3) non-hazardous
non-petroleum based liquid waste, to lined and unlined ponds, for management and treatment
with on-site soils and materials for approved disposal into the Apex Landfill.
Apex Bioremediation Facility and Liquids Solidification Area
Apex Landfill
13550 US Highway 93
Approximately 19 miles northeast of the City of Las Vegas
Las Vegas, Clark County, Nevada 89124
Township 18 South, Range 64 East, Sections 18
Latitude: 36 23' 15"
Longitude: 114 52' 14"
1
in accordance with the effluent limitations, monitoring requirements, and other conditions set
forth in Parts I, II, and III hereof.
This permit became effective on: December 16, 2010.
Major modification to this permit effective on: March 27, 2012
This permit and the authorization to discharge shall expire at 12:01 AM December 15, 2015.
Signed this DD day of MMM, 2012
Reid,
Bureau of Water PollutiOn Control
P:\BWPC\BWPC Penn;os\NV and N\I\NEV930i 1 REPUBUC ENVI TECH\2011 Mod 2011 Liguids Solidific.,tion\">EV9301 J Republic Emiro. Tech PERMIT lvbjMod FINAL [mrj.doc
I
EFFLUENT
CONDITIONS
Permit NEV93011
Page 2 oflS
I.A.l. Dming the period beginning on the effective date of this permit, and lasting until the
permit expires, the Permittee is authmized to accept and treat non-hazardous
petroleum contaminated soil/water along with non-hazardous petroleum and non-
petroleum based liquids at the Apex Bioremediation Facility (ABF) in accordance
with the conditions of this permit. Treated material shall be disposed in the Apex
Landfill, in accordance with governing county, state, and federal requirements. The
pennittee is also authorized to treat non-hazardous non-petroleum liquids with on-site
soils and landfill approved materials (i.e. wood chips, sawdust and auto fluff) at the
Liquid Solidification Area (LSA), for disposal in the Apex Landfill in accordance
with governing county, state, and federal requirements.
Table I.A. 1.1 a Bioremediation Facility: Petroleum Contaminated Soils
Discharge
Monitoring Requirements
Parameter
Limitations
Sample Measurement Sample
Locations Frequency Type
Maximum TPH concentration
Treatment
in treated soil and soil-water 100
Cell
Each Batch Composite
mixtures (mg/ kg)
Maximum volume of material
Treatment
within each treatment cell 2300
Cell
Each Batch Estimate
(cubic yards)
Maximum weight of material
45,000
.
Each Load Scale
within containment area (tons)
Total weight of in-state waste
M8:R " Each Load Scale
accepted per month (tons)
Total weight of out-of-state
waste accepted per month M8:R
.
Each Load Scale
(tons)
Presence of liquid in leak
Leak
M8:R Detection Weekly Inspection
detection system (Yes/No)
Pipe
Volume fluid removed from Leak Leak
Detection System M8:R Detection Weekly Discrete
(gallons/ acre/ day) Pipe
Containment area inspections M8:R
Containment
Weekly Inspection
Area
Permit NEV930ll
Page 3 ofl5
Tab [e I.A. 1. 1 b Bioremediation Hty: Non-Hazardous Liquids and Petroteum
Contaminated Liquids
'
Discharge
Parameter
Limitations
Sample Measurement Sample
Locations Frequency Type
Maximum TPH concentration
M&R
Treatment Each Load or
Analysis Record
in liquid waste (mg/L) Celt Profile Record
GRO Concentration in Liquid
M&R
Treatment Each Load or
Analysis Record
Waste (mg/L) Celt Profile Record
Daily Max (gallons)
Acceptance Calculate Est
(Bioremediation Facility and Soil 499,000
Area
Each Load
Load measure
Solidification Area combined)
Month Total (gallons) M&R Each Load Est measure
Total gallons of in-state liquid
M&R Each Load
Calculate Est
waste accepted per month
-
Load measure
Total gallons of out-of-state
Calculate Est
Liquid waste accepted per M&R Each Load
Load measure
month
Presence of liquid in leak
Leak
M&R Detection Weekly Inspection
detection system (Yes/ No)
Pipe
Volume fluid removed from Leak Leak
Detection System M&R Detection Weekly Discrete
(gallons/ acre I day) Pipe
Containment area inspections M&R
Containment
Weekly Inspection
I
Area
1.2
Pennit N-:EV93011
Page 4 oflS
Petroleum Liquids
Accept
Liquid
Waste
Process
Area
Remove
Conditioned
Soil
Parameter Discharge
I
Limitations
Daity Sample Measurement Sample Type
Locations Frequency
TPH Concentration 0.0 MEtR
Liquid Each load or
Analysis Record
Acceptance profile record
pH MEtR
Liquid Each load or
Analysis Record
Acceptance profile record
Liquid
Month Total (gallons) MEtR
Acceptance
Each load Est measure
Daily Max(gallons)
Liquid
(Bioremediation Facility
499, 000 Daily Calc Est Load measure
and Soil Solidification Acceptance
Area combined)
Containment Area
MEtR
Containment
Weekly Inspection
Inspections Area
Free Liquids MEtR
Conditioned Each Removal
Paint Filter Test
Soil Event
a. Hazardous Waste: Screen and accept only non-hazardous loads (rejection
I.A.18). Only non-hazardous and non-petroleum based liquids may be
accepted at the LSA. Liquids having incidental TPH shall be sent to the ABF
for treatment. All waste shall be screened for hazardous characteristics per
applicable state and federal requirements. Identify the source of all liquids
accepted and maintain a records management program for tracking per the
Division approved Operations and Maintenance (O&M) manual. No out of
state waste shall be accepted without prior notification to the Southern Nevada
Health Authority. Out of state waste shall be tracked through the process to
final disposition.
1. For the purpose of liquid solidification and conditioned soils placement
management, TPH concentrations known by the Permittee or generator to
be originating from non-petroleum sources such as fat, grease, and
cooking oils are waived from TPH analysis and TPH limitations of this
permit, since such liquids are known to produce false positive petrolemn
based TPH values. Such TPH waived liquids being accepted by the
Permittee are tallied as a portion of the total daily ma,""imum volume of
liquids allowed to be received by the Permittee.
b. Waste Load Information: The Permittee shall collect and maintain the
following information for each waste load accepted: receiving date, weight
and/or volume, truck identification, transporter, source of waste pre-
l.A.2.
Permit NEV93011
Page 5 ufl5
acceptance and pre-treatment analytical data, manifests, out of state letters of
non-hazard, and generator declarations of non-hazard.
c. Leak Detection System: The leak detection system must be inspected
weekly. Any liquid found in the leak detection system shall be removed.
Incidence of leakage, volumes removed, and final disposition, shall be
reported to show that the system is maintained and managed as described in
the Division approved O&M manual.
d. Paint Filter Test: (EPA method 9095B) shall be conducted, in accordance
with the Division approved O&M, to verify that the solidification treatment of
soils and liquids has resulted in a solid waste and does not contain any free
liquids.
e. Containment Areas
1. The contaim11ent areas shall be inspected weekly, at a minimum, for
erosion, deterioration, or malfunction of containment structures. If the
containment is breached, acceptance of material shall cease, the
Division shall be notified by 5:00pm of the following business day,
and a repair plan shall be submitted to the Division for approval.
n. A summary of the weekly inspections shall be reported.
iii. 'lhe containment areas shall contain the 25-yr 24-hr storm and
withstand the 100-yr 24-hr flood at their respective operating
locations.
f. Spills: Any spills resulting from transfer operations and truck and container
wash water shall be retained within the containment areas.
Groundwater Monitoring
Table LA.2. Monitoring Requirements for Well MW5
Parameter
Depth to Groundwater
(feet)
Groundwater Elevation
(Feet AMSL)
Sample
Maximum
Monitor &
Report
Monitor Et
Report
Frequency
Annual
(collected 4th Qtr.
each year)
Annual
(collected 4th Qtr.
each year)
I
Annual
TPH
1
, mg/l Monitor & . (collected 4th Qtr.
Report
each year)
Sample Type
field measurement
Calculate
Discrete
2 Monitor & Annual (collected Dl'screte
__ Q_tr_._e_ac_h_y_e_a_0 __ ____________ __j
l. EPA Method 8015B, full range. C6-C40. 2. EPA Method 8260B, lo mclude MTBE.
Perwit I\'EV93011
6 of15
I.A.3. of Compliance: The Permittee shall implement and comply with the
I.A.4.
I.A.5.
I.A.6.
I.A.7.
I.A.8.
I.A.9.
provisions of the schedule of compliance after approval by the Division, including in
said implementation and compliance, any additions or modifications which the
Division may make in approving the schedule of compliance.
a. The Permittee shall achieve compliance with the effluent limitations upon
issuance of the permit.
b. On or prior to May 7 ~ 2012 (60 days), the Permittee shall submit 2 copies of
the current updated O&M manual for the bioremediation and liquid waste
solidification activities for review and approval by the Division. The
submitted O&M sections shall include any change made to the O&M manual
needed to comply with this permit since the last Division approved edition.
Two (2) copies of the O&M manual shall be submitted for review and
approval to the following address:
Department of Conservation and Natural Resources
Division of Environmental Protection
901 S. Stewart Street, Suite 4001
c. Prior to initiating any change to an approved O&M manual or approved
system plan, in accordance with permit Part I.A.9 or Part I.A.10, a revision
requesting such change must be prepared and submitted to the Division for
approval. The Permittee, or designated representative, shall adequately
address all comments and concerns relating to the Division's review of a
revised O&M manual or system plan.
The Permittee shall remit an annual review and services fee in accordance with NAC
445A.232 starting July 1, 2012 and every year thereafter until the permit is
terminated.
There shall be no objectionable odors from the ABF or LSA.
There shall be no discharge of substances that would cause the groundwater to violate
drinking water standards.
There shall be no discharge from the ABF or LSA except as authorized by this
pe1mit.
The ABF and LSA shall be restricted from public access.
The ABF and LSA shall be constructed in conformance with plans approved by the
Division. The plans must be approved by the Division prior to the start of
construction and must by stamped by a Professional Engineer registered in the state
of Nevada. All changes to any approved plans must be stamped by a Professional
Permit NEV930 11
Page 7 of 15
Engineer registered in the state of Nevada and re-approved by the Division prior to
implementation.
I.A.lO. The facility shall be operated in accordance with a Division approved Operations and
Maintenance (O&M) manual. The Permittee shall maintain and revise, as necessary,
the O&M manual, keeping all information required by I. A and I.B of the permit
cunent. No operation or maintenance change outside the scope of the approved
O&M manual shall be initiated by the Permittee until the pertinent section or sections
of the O&M manual have been revised, submitted to and approved by the Division.
I.A.ll. The Permittee shall develop and implement Best Management Practices (BMPs) for
the facilities to include, at a minimum, "good housekeeping" measures. Best
Management Practices shall be incorporated into a specific section of the O&M
Manual.
I.A.l2. The containment structures shall contain any spills or loss of liquids within the
process facility and/or receiving pad during transfer operations. Any wash down
waters shall be contained in accordance with procedures in the O&M Manual.
l.A.13. All wastes shall remain within the containment areas until analyses, as per the
procedures in the O&M Manual, have shown that treated materials meet the permit
approved requirements.
I.A.l4. The Permittee shall provide safety training to appropriate facility personnel
describing the possible hazards and proper hygiene of working with and around liquid
waste. The Permittee shall provide the Safety Training manual to the Division upon
Division request.
l.A.15. Liquid waste is prohibited from running off the Permittee's property and from
running or being discharged into any surface drainage. Solidification shall be
conducted in accordance with management practices which prevent fluid from
running off the facility property. On-site processing of liquids being solidified with
native soil and approved materials shall be conducted in a manner such that liquids
and conditioned soils remain fully contained on site.
I.A.l6. Liquid waste shall be solidified and removed in a timely manner to minimize possible
migration of fluid from the designated solidification areas. All final liquid processed
soils/materials must be used as cover material placement over Apex Landfill, or
comingled for disposal at Apex Landfill. The Permittee shall manage materials
generated by solidification of liquids having an incidental TPH concentration in
accordance with the solidification process described in the Division approved O&M
Manual.
I.A.17. The designated LSA on the property may be changed during this permit cycle to other
approved areas on the property by notification to the Division in accordance with
permit Part I.A.9. The designated areas shall be adequately described in the O&M
Manual by latitude and longitude coordinates. The perimeter of these areas shall be
field identified for operational control and to aid site inspection by the Division.
LA.18.
Permit NEV93011
Page 8 ofl5
Waste loads determined to be hazardous waste shall be prohibited from off-loading at
the facility. Waste loads screened at the facility that are determined to be hazardous
waste shall be rejected, and the Division and appropriate local agencies will be
notified within 24 hours of the occurrence. The notification shall include information
surrounding the rejection, and the waste characterization of the load.
MONITORING AND REPORTING
I.B.l. Samples and measurements taken as required herein shall be representative of the
volume and nature of the monitored discharge. Analyses shall be performed by a
State of Nevada certified laboratory. Results from this lab must accompany the
Discharge Monitoring Report.
I.B .2. Reporting
a. Annual Report: The fourth quarter report shall contain plots of monitoring
parameter (y-axis) versus date (x-axis) for each monitored parameter. The
plots shall include data from the preceding five years, if available. Any data
point from the current year that is greater L1an the limits in Part I.A.l must be
explained by a narrative. The Permittee shall also submit to this office labeled
and dated photograph(s) of the ABF and LSA, annually, as part of the 4th
quarter D MR.
b. Quarterly Reporting: Monitoring results obtained during the previous tbree
(3) months shall be summarized for each month and reported on a Discharge
Monitoring Report (DMR) Form received in this office no later than the 28th
day of the month followi..'1g the completed reporting period. The first report is
due on July 28, 2012. An original signed copy of these, and all other reports
required herein, shall be submitted to the State at the following address:
LB.3. Definitions
Department of Conservation and Natural Resources
Division of Environmental Protection
901 S. Stewart Street, Suite 4001
a. The "30-day average discharge" means the total discharge during a month
divided by the number of samples in the period that the facility was
discharging. Where less than daily sampling is required by this permit, the
30-day average discharge shall be determined by the summation of all the
measured discharges divided by the number of samples during the period
when the measurements were made.
I.B.4.
I.B.5.
I.B.6.
PenrJt NEV93011
Page 9 of 15
b. The "daily maximum" IS the highest measurement during the monitoring
period.
c. The "30-day average concentTation", other than for fecal coliform bacteria,
means the mithmetic mean of measurements made during a month. The "30-
day average concentration" for fecal colifom1 bacteria means the geometric
mean of measurements made during a month. The geometric mean is the "nthn
root of the product of "n" numbers. Geometric mean calculations where there
are non-detect results for fecal coliform shall use one-half the detection limit
as the value for the non-detect results.
d. A "discrete" sample means any individual sample collected in less than 15
minutes.
e. A "composite" sample, in regards to this permit, means a sample comprising
two or more increments selected to represent the material being analyzed.
f. TPH: Total Petroleum hydrocarbons
g. GRO: Gasoline Hydrocarbon range
h. mg!L: Milligrams per liter
l. jlg/L: Micrograms per liter
]. M&R: Monitor and Report
Test Procedures. Analyses shall be conducted by a "certified laboratory" using an
"approved method of testing", as defined in NAC 445A.0564 and NAC 445A.0562,
respectively.
Recording the Results: For each measurement or sample taken pursuant to the
requirements of this permit, the Permittee shall record the following information:
a. The exact place, date, and time of sampling;
b. The dates the analyses were pe1iormed;
c. The person(s) who performed the analyses;
d. The analytical techniques or methods used; and
e. The results of all required analyses, including the reporting limits.
Reporting Limits. Unless otherwise allowed by the Division, the approved method
of testing selected for analyses shall have a reporting limit which is:
a. Half or less of the discharge limit; or, if there is no limit,
Permit NEV93011
Page 10 of15
b. Half or less of the applicable water quality criteria; or, if there is no limit or
criteria,
c. The lowest reasonably obtainable using an approved test method.
I.B.7. Additional Monitoring by Permittee: If the Permittee monitors any pollutant at the
location(s) designated herein more frequently than required by this permit, using
approved analytical methods as specified above, the results of such monitoring shall
be included in the calculation and reporting of the values required in the Discharge
Monitoring Report Form. Such increased frequency shall also be indicated.
I.B.8. Records Retention: All records and information resulting from tbe monitoring
activities required by this permit, including all records of analyses performed and
calibration and maintenance of instrumentation and recordings from continuous
monitoring instrumentation, shall be retained for a minimum of three (3) years, or
longer if required by tbe Administrator.
I.B.9. Modification of Monitoring Frequency and Sample Type: After considering
monitoring data, stream flow, discharge flow and receiving water conditions, the
Division may, for just cause, modify the monitoring frequency and/or sample type by
issuing an order to the Permittee.
PART II
TI.A.
Il.A.l.
II.A.2.
ll.A.3.
J\tlANAGEMENT REQUIREJVIENTS
Change in Discharge: All.discharges authorized herein shall be consistent with the
terms and conditions of this permit. The discharge of any pollutant identified in this
permit more frequently than or at a level in excess of that authorized shall constitute a
violation of the pe1mit. Any anticipated facility expansions, or treatment
modifications which will result in new, different, or increased discharges of pollutants
must be reported by submission of a new application or, if such changes will not
violate the effluent limitations specified in this permit, by notice to the permit issuing
authority of such changes. Any changes to the permitted treatment facility must
comply with Nevada Administrative Code NAC 445A.283 to 445A.285. Pursuant to
NAC 445A.263, the permit may be modified to specify and limit any pollutants not
previously limited.
Facilities Operation: The Permittee shall at all times maintain in good working
order and operate as efficiently as possible all treatment or control facilities,
collection systems or pump stations installed or used by the Permittee to achieve
compliance with the terms and conditions of this permit.
Adverse Impact: The Permittee shall take all reasonable steps to minimize any
adverse impact to receiving waters resu1ting from noncompliance with any effluent
limitations specified in this permit, including such accelerated br additional
monitoring as necessary to determine the nature and impact of the noncomplying
discharge.
II.A.4.
a.
b.
Unauthorized Discharge, Bypassing and
Permit N""EV93011
11 of15
Any diversion, bypass, spill, overflow or discharge of treated or untreated
wastewater from wastewater treatment or conveyance facilities under the
control of the Permittee is prohibited except as authorized by this permit. In
the event the Permittee has knowledge that a diversion, bypass, spill, ovedlow
or discharge not authorized by this permit is probable, the Permittee shall
notify the Division immediately.
The Permittee shall notify the Division within twenty four (24) hours of any
diversion, bypass, spill, upset, overflow or release of treated or untreated
discharge other than that which is authorized by the permit. A written report
shall be submitted to the Divisiori within five (5) days of diversion, bypass,
spill, overflow, upset or discharge, detailing the entire incident including:
1. Time and date of discharge;
ii. Exact location and estimated amount of discharge;
iii. Flow path and any bodies of water which the discharge reached;
lV. The specific cause of the discharge; and
v. The preventive and cotTective actions taken.
c. The following shall be included as information which must be reported within
24 hours: any unanticipated bypass which exceeds any effluent limitation in
the permit; any upset which exceeds any effluent limitation in the permit; and
violation of a limitation for any toxic pollutant or any pollutant identified as
the method to control a toxic pollutant.
d. The Permittee shall report all instances of noncompliance not reported under
Part II.A.4.b. at the time monitoring reports are submitted. The reports shall
contain the information listed in Part Il.A.4.b.
e. An "upset" means an incident in whiCh there is unintentional and temporary
noncompliance with the permit effluent limitations because of factors beyond
the reasonable control of the Permittee. An upset does not include
noncompliance to the extent caused by operational enor, improperly designed
treatment facilities, inadequate treatment facilities, lack of preventive
maintenance, or careless or improper operation.
f. In selecting the appropriate enforcement option, the Division shall consider
whether or not the noncomp1iance was the result of an upset.
g. The burden of proof is on the Permittee to establish that an upset occuned. In
order to establish that an upset Dccurred, the Permittee must provide, in
addition to the information required under paragraph Il.A.4.b. above, properly
signed contemporaneous logs or other documentary evidence that:
II.A.5.
II.A.6.
II. B.
II.B.L
II.B.2.
II.B.3.
Permit NEV93G11
Page 12 of15
1. The facility was at the time being properly operated as required in
paragraph II.A.2. above, and
ii. All reasonable steps were taken to minimize adverse impacts as
required by paTagraph ll.A.3. above.
Removed Substances: Solids, sludges, filter backwash, or other pollutants removed
in the course of treatment or control of waste waters shall be disposed of in a manner
that will prevent any pollution from such materials from entering any navigable
waters.
Safeguards to Electric Power Failure
a. Provide at the time of discharge an alternative power source sufficient to
operate the wastewater control facilities, or
b. Halt or reduce all discharges upon the reduction, loss, or failure of the primary
source of power to the wastewater control facilities.
RESPONSIBILITIES
Right of Entry: The Permittee shall allow authorized representatives of the Division,
upon the presentation of credentials, to:
a. Enter upon the Permittee's premises where an effluent source is located or in
which any records are kept under the terms and conditions of this permit;
b. Have access to and to copy any records kept under the terms and conditions of
this permit;
c. Inspect any facilities, equipment, or operations related to compliance with this
permit; and
b. Perform any necessary sampling or monitoring to determine compliance with
this permit.
Transfer of Ownership or Control: In the event of any change in control or
ownership of facilities from which the authorized discharge emanates, the Permittee
shall notify the succeeding owner or controller of the existence of this permit, by
letter, a copy of which shall be forwarded to the Division. All transfer of permits
shall be approved by the Division. '
Availability of Reports: Except for data determined to be confidential under NRS
445A.665, all reports prepared in accordance with the terms of this permit shall be
available for public inspection at the office of the Division. Effluent data shall not be
considered confidential. Knowingly making any false statement on any such report
may result in the imposition of criminal penalties as provided for in NRS 445A.710.
ILB.4.
II.B.5.
II.B.6.
Permit J'\TEV93011
Page 13 of15
u..:lHili.<J;; False Information Tampering Monitoring Devices: A.ny
person who knowingly makes any false statement, representation, or certification in
any application, record, report, plan or other document filed or required to be
maintained by the provisions of NRS 445A.300 to 445A.730, inclusive, or by any
permit, rule, regulation or order issued pursuant thereto, or who falsifies, tampers
with or knowingly renders inaccurate any monitoring device or method required to be
maintained under the provisions of NRS 445A.300 to 445A.730, inclusive, or by any
permit, rule, regulation or order issued pursuant thereto, is guilty of a gross
misdemeanor and shall be punished by a fine of not more than $10,000 or by
imprisonment. This penalty is in addition to any other penalties, civil or criminal,
provided pursuant to NRS 445A.300 to 445A.730, inclusive.
Penalty for Violation of Permit Conditions: Nevada Revised Statutes l\TRS
445A.675 provides that any person who violates a permit condition is subject to
administrative and judicial sanctions as outlined in NRS 445A.690 through
445A.705.
Permit Modification, Suspension or Revocation: P.Jter notice and opportunity for a
hearing, this permit may be modified, suspended, or revoked in whole or in part
during its term for cause including, but not limited to, the following:
a. Violation of any terms or conditions of this permit;
b. Obtaining this permit by misrepresentation or failure to disclose fully all
relevant facts; or
c. A change in any condition that requires either a temporary or permanent
reduction or elimination of the authorized discharge.
II.B.7. Toxic Pollutants: Notwithstanding Pa1t II.B.6. above, if a toxic effluent standa1d or
prohibition (including any schedule of compliance specified in such effluent standard
or prohibition) is established under NAC 445A for a toxic pollutant which is present
in the discharge and such standard or prohibition is more stringent than any limitation
for such pollutant in this permit, this permit shall be revised or modified in
accordance with the toxic effluent standard or prohibition and the Permittee so
notified.
II.B.8. Liability: Nothing in t.his permit shall be construed to preclude the institution of any
legal action or relieve the Pem1ittee from any responsibilities, liabilities, or penalties
established pursuant to any applicable Federal, State or local laws, regulations, or
ordinances.
ILB.9. Property Rights: The issuance of this permit does not convey any property lights, in
either real or personal property, or any exclusive privileges, nor does it authorize any
injury to private property or any invasion of personal rights, nor any infringement of
Federal, State or Ioca1laws or regulations.
II.B.lO. Severability: The provisions of this permit are severable, and if any provision of this
permit, or the application of any provisions of this permit to any circumstance, is held
Permit NEV93011
Page 14 of15
invalid, the application of such provision to other circumstances, and the remainder of
this pem1it, shall not be affected thereby.
OTHER REQUIREMENTS
III.A.l. Reapplication: If the Permittee desires to continue to discharge, he shall reapply not
later than 180 days before this permit expires on the application forms then in use.
The application shall be accompanied by the renewal application fee required by
NAC 445A.232.
III.A.2. Signatures, Certification Required on Application and Reporting Forms:
a. All applications, reports, or information submitted to the Division shall be
signed and certified by making the following certification.
"I certify under penalty of law, that this document and all attachments were
prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated
the information submitted. Based on my inquiry of the person or persons who
manage the system, or those persons directly responsible for gathering
information, the information submitted is, to the best of my knowledge and
belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fine and
imprisonment for knowing violations."
b. All applications, reports or other information submitted to the Division shall
be signed by one of the following:
1. A principal executive officer of the corporation (of at least the level of
vice president) or his authorized representative who is responsible for
the overall operation of the facility from which the discharge described
in the application or reporting form originates; or
u. A general partner of the partnership; or
111. The proprietor of the sole proprietorship; or
iv. A principal executive officer, ranking elected official or other
authorized employee of the municipal, state or other public facility.
c. Duly Authorized Representative: All Discharge Monitoring Reports and
any other information required by this permit or requested by the Division
shall be signed by a person described in paragraph (b) of this section, or by a
duly authorized representative of that person. A person is a duly autholized
representative only if:

10.15
GREENHOUSE GAS MONITORING PLAN

Gr eenhous e Gas ( GHG) Moni t or i ng Pl an

USEPA Mandat or y GHG Repor t i ng Rul e
40 CFR Par t 98 Subpar t s A, C and HH

Mar c h 2010

Ver s i o n 1. 0

Facility Information:

Site Name:
Address:
City, State:

Table of Contents

1.0 INTRODUCTION
1.1 Background
1.2 Recordkeeping
1.3 Applicability
2.0 POSITIONS OF RESPONSIBILITY
3.0 PROCESSES AND METHODS
3.1 Municipal Solid Waste Landfills Subpart HH
3.1.1 Data Collection Processes, Methods & Assumptions
a. Modeled Landfill Gas Generation Emissions
b. Measured Landfill Gas Collection Recovery
3.2 General Stationary Fuel Combustion Sources Subpart C
3.2.1 Data Collection Processes, Methods & Assumptions
4.0 PROCEDURES & METHODS
4.1 Quality Assurance, Maintenance & Repair

Appendix A - EPA Frequently Asked Questions
Appendix B - Stationary Fuel Combustion Excluded Sources

R e publ i c S e r vi c e s G r e e nho us e G a s Mo ni t o r i ng P l a n

March 2010 (version 1.0) Page 1

1.0 INTRODUCTION
1.1 BACKGROUND
EPA has issued the Mandatory Reporting of Greenhouse Gases Rule. The rule requires
reporting of greenhouse gas (GHG) emissions from large sources and suppliers in the
United States, and is intended to collect accurate and timely emissions data. The final
rule was published in the Federal Register on October 30, 2009 and became effective
December 29, 2009.
This Greenhouse Gas Monitoring Plan (GHG Plan) serves as a centralized record
prepared pursuant to USEPA Code of Federal Regulations (CFR), Title 40, Part
98.3(g)(5) for Republic Services facilities (referenced herein as facility).
The GHG Plan is considered a living document that will be revised as necessary. In an
effort to reduce the frequency of monitoring equipment downtime, revisions may include
but will not be limited to the following changes:
Production processes
Monitoring instrumentation
Quality assurance procedures
Procedures for maintenance or repair of the monitoring systems

1.2 RECORDKEEPING
Any relevant records from which GHG emission have been calculated, will be retained
for at least three (3) years and will be made available to regulatory personnel upon
request. Data collected to comply with the GHG Reporting Rule will be collected and/or
maintained in hard-copy or electronic storage provided that electronic records can be
inspected, reviewed or made available in hardcopy format. Records may be retained
off-site as long as they are readily available. References to on-site files or
hardcopy/electronic files may include remotely stored information.
Changes and modifications to the process, procedures, and methods as outlined within
the GHG Plan shall be documented and maintained on-site. The plan may reference
on-site, electronic or remotely maintained files and/or company, government, or other
documents. The referenced files and documents may be revised and updated without
revising this plan.
1.3 APPLICABILITY
The GHG Plan described herein provides guidance for sources required to report
pursuant to 40 CFR Part 98, Subpart HH - Municipal Solid Waste (MSW) Landfills and
Subpart C General Stationary Fuel Combustion Sources.



The GHG Plan contains the required key elements as set forth in 40 CFR 98.3(g)(5),
which include the following:
Positions of Responsibility - Identification of positions of responsibility for data
collection
Process & Methods - Explanation of the processes and methods used for data
collection
Procedures & Methods - Description of procedures and methods used for quality
assurance (QA) along with maintenance and repair of instrumentation used to
report GHG emissions
Sections or procedures presented herein may not apply based on current equipment
being used or the operating status of the facility. Therefore, sections of this monitoring
plan may be considered independently.
2.0 POSITIONS OF RESPONSIBILITY
In accordance with the requirements of 40 CFR 98.3(g)(5)(1)(A), the written GHG Plan
must identify positions of responsibility (i.e., job titles) for collection of the facility
emissions data.

Facility personnel with responsibilities for collecting emissions data include, but are not
limited to the following: Division Manager, General Manager, Operations Manager,
Maintenance Manager, LFG Technician, Environmental Specialist, Environmental
Manager and Corporate Engineering. The responsible personnel may rely on other
companies or contractors as necessary.

The personnel listed above will be responsible for various GHG data collection tasks
including, but not limited to:
Updating the GHG Plan
Collecting and compiling data
Periodically reviewing data to ensure data is complete
Preparation of annual report
Calibrating, maintaining and repairing GHG measurement devices
Ensuring GHG Plan is implemented

3.0 PROCESSES AND METHODS
In accordance with 40 CFR 98.3(g)(5)(i)(B) of the GHG Reporting Rule, each facility is
required to provide an explanation of the processes and methods used to collect the



data for GHG calculations. The processes and methods for each facility will vary
depending on the specific measuring and recording devices installed.
Only processes and methods for equipment owned and operated by Republic or its
subsidiaries are included in this GHG Plan and will be reported annually. Landfill gas
routed off-site for destruction or use at a third party is considered a separate facility
regardless of the physical location. As described in Section 3.1, the facility will only be
responsible for collecting data flow and monitoring gas composition. The facility will not
be responsible for calculating, recordkeeping or reporting GHG emissions associated
with the third party LFG destruction and operating hours.
The following section presents the data collection processes and methods for Municipal
Solid Waste Landfills Subpart HH and Stationary Fuel Combustion Sources Subpart
C.
3.1 MUNICIPAL SOLID WASTE LANDFILLS SUBPART HH
The facility is required to report modeled methane generation in accordance with 40
CFR 98.343(a), Subpart HH. If a facility has an operational active gas collection
system, then the quantity of methane destroyed and calculated methane generation is
required to be calculated pursuant to 40 CFR 98.343(b) and 98.343(c) respectively.
The following section outlines the process and methods for a) Modeled Landfill Gas
Generation Emission and b) Measured Landfill Gas Collection Recovery.
3.1.1 Data Collection Processes, Methods and Assumptions
a. Modeled Landfill Gas Generation Emissions
i. For each reporting year, landfills accepting waste will determine the
quantity of waste landfilled. The waste disposal quantity will be
determined by tipping fee receipts or other company records which are
stored electronically. The data collected will be based upon, but not
limited to the following assumptions:
Historical waste acceptance method and the reason for choosing
such method will be documented in the annual report.
A closed landfill or landfill which ceases accepting waste will not be
required to record annual waste disposal. Until such time as the
facility is no longer required to report its GHG emissions per
Subpart A and HH requirements, applicable records will be
maintained in order to complete required annual calculations.
The waste acceptance quantity in the years 2010 and after will be
determined in a manner consistent with the requirements for
commercial weighing equipment as described in Specification,



Tolerances, and Other Technical Requirements for Weighing and
Measuring Devices NIST Handbook 44 (2009).
Waste disposal data collection will be for the time period of J anuary
1 December 31.
ii. The waste disposal data will be reviewed periodically to ensure there are
no data gaps or problems. Missing daily waste disposal quantity data will
be substituted in accordance with 40 CFR 98.345(c). Missing data
documentation will contain a description identifying the cause, duration
and any actions or steps taken to prevent future occurrence.
iii. Annual waste disposal data will be totalled to determine GHG emissions.
The annual report may include, but will not be limited to the following
assumptions:
Waste composition, if available, may be estimated based on
engineering judgments, visual inspection, supplier information or
applicable scientific method.
A facility that uses the waste composition option may use more
refined categories such as those where k rates are available in 40
CFR 98, Subpart HH, Table HH-1, and any future updates to
these sections. The method or basis used for calculating GHG
emissions will be documented on-site.
Annual modeling inputs may use site specific data, default values
or a combination of site specific and default values to determine
generated methane emissions.
Quantity of waste disposed in the landfill will be determined as
prescribed in 40 CFR 98.343(a) in Equation HH-1.

b. Measured Landfill Gas Collection & Recovery Emissions
(b)1 Landfill Gas Flow Rate

i. The gas flow measurement devices used for complying with the GHG
Reporting Rule will record continuously. Records of the continuous flow
will be documented and maintained on-site per Section 1.2 above in
hardcopy/electronic format. The data will be collected, but not limited to
the following assumptions:
Flow measurement devices will include units that measure the
mass or volumetric gas flow through an open or closed conduit.
These devices are not limited to those contained in 40 CFR
98.344(c) as specified in EPAs Frequently Asked Questions
(FAQs) attached in Appendix A.



The flow meter data will only be calculated if the destruction device
is operating.
Flow meters which do not automatically correct for temperature,
pressure and, if applicable, moisture content will require
measurement at the same location as the weekly gas concentration
measurement. The moisture correction is only required if the flow
meter and gas concentration are measured on a different moisture
basis. The requirement to make correction readings will be
determined by manufacturer specifications of the meter and/or site
specific conditions. The measurement(s) will be recorded using a
portable gas analyzer or other appropriate measuring device.
Flow meters installed at the facility for measurement of landfill gas
meet the provisions under 40 CFR 98.3(i)(6) Subpart A which
allows for postponement of the April 1, 2010 deadline for initial
calibration and for subsequent recalibrations until the next
scheduled shutdown. The flow meters are required to continuously
operate and need to be removed from service for calibration.
Calibration postponements will be documented and records
maintained onsite as required.
ii. The flow data will be reviewed periodically to ensure there are no data
gaps or problems. Missing flow data will be substituted in accordance with
40 CFR 98.345(b). Missing data documentation will contain a description
identifying the cause, duration and any actions or steps taken to prevent
future occurrence.
iii. The flow data will be totalled annually and compiled to determine GHG
emissions. A facility may use a single flow meter which collectively
combines flow being sent to multiple destruction devices as long as the
flow meter is located before treatment or use. Landfill gas routed to a
destruction device will determine the cumulative volume of landfill gas
each week and will be totalized annually. Treatment shall mean thermal
destruction such as a flare, engine or turbine. Treatment does not include
any components prior to the flare, engine or turbine such as but not limited
to knock-out, separator drums and/or a compressor.

(b)2 Methane Concentration
i. In order to be considered a compliant weekly reading, methane
concentration will be measured and recorded once each calendar week
with at least 3 full calendar days between readings. The data will be
documented and maintained on-site in accordance with Section 1.2 above



in hardcopy/electronic format. The data collected will be based upon, but
not limited to the following assumptions:
Monitoring may be performed as a stand-alone monitoring event or
as a part of routine operation and maintenance.
Methane measurements collected on a weekly basis which means
during the calendar period from Sunday to Saturday.
Methane concentration can be collected by portable infrared
methane analyzers (i.e. GEM 500, 2000 or equivalent), continuous
methane concentration analyzers (i.e. gas chromatographs) or total
organic concentration analyzers for determining quantity of
methane recovered for destruction. Future technology and the
associated procedures for collecting methane concentration will
automatically be incorporated into the GHG Plan once approved by
EPA.
A facility may use one methane concentration sampling point which
collectively combines flow sent to multiple destruction devices as
long as the sampling point is located before treatment or use.
Treatment shall mean thermal destruction such as a flare, engine or
turbine. Treatment does not include any components prior to the
flare, engine or turbine such as but not limited to knock-out,
separator drums and/or a compressor.
Methane concentration will only be collected if the destruction
device is operating. If the destruction device has been operational
for less than one week in duration and there are multiple sample
points used for GHG emission calculations, the gas concentration
can be determined by other measured events during the week
provided the sample location is representative.
Moisture correction for methane concentration is only required if the
flow meter and gas concentration are measured on a different
moisture basis. This will be determined by manufacturer
specifications of the meter and/or site specific conditions.
The portable infrared measuring devices such as the GEM-500,
GEM-2000, Envision Analyzer or equivalent devices are not
required to correct for non-methane organic compound (NMOC)
because these meters are designed and calibrated to directly
measure methane. Measurement devices which do not directly
measure methane are required to annually sample for NMOC and
apply a correction factor.
ii. Methane content data will be reviewed periodically to ensure there are no
data gaps or problems. Missing methane content data will be substituted



in accordance with 40 CFR 98.345(a). Missing data documentation will
contain a description identifying the cause, duration and any actions or
steps taken to prevent future occurrence.
iii. Methane concentration data will be annually compiled to determine GHG
emissions. When more than one reading is collected at the sample point
or when multiple sampling points exist during a valid weekly monitoring
frequency, the readings will be averaged to produce a weekly average
methane reading.

(b)3 Control Device Destruction Efficiency
i. The facility will use the lesser of the flare or engine manufacturer's
specified destruction efficiency or 99%. Where no manufacturer's data are
available, a default value of 99% will be used for methane destruction, in
accordance with the rule. The records are maintained on-site in
hardcopy/electronic format.
ii. Destruction efficiency data will be reviewed periodically to ensure the
information is up to date.
iii. Destruction efficiency information will be annually compiled to determine
GHG emissions. If gas is transported off-site for destruction, an efficiency
value of 100% will be used for methane destruction.

(b)4 Landfill Collection & Destruction Operating Hours
i. The annual operating hours during the reporting year in which collection
and destruction device(s) operate will be determined using flow data.
Records will be maintained on-site in accordance with Section 1.2 above
in hardcopy/electronic format.
ii. Flow data will be reviewed periodically to ensure there are no data gaps or
problems. The control device downtime will be monitored by reviewing
flow records, field activity logs and startup, shutdown, and maintenance
(SSMs) records as applicable. Missing flow data will be evaluated as
described in b.2(ii) above.
iii. Data will be compiled annually to determine GHG emissions. The annual
operating hours will default to 100% if landfill gas is destructed in a back-
up flare (or similar device) or if the gas is transported off-site.

(b)5 Landfill Gas Collection Efficiency
i. The landfill gas collection efficiency (CE) will be estimated in accordance
with Subpart HH of 40 CFR Part 98 Landfill Gas Collection Efficiencies
Table HH-3. If the area by soil cover type information is not available, a



default CE value of 75% will be used for areas under the influence of a
gas collection system. A default oxidation fraction value of 10% will be
used for the entire facility. Future technology or acceptable estimates
used for determining oxidation fraction will automatically be incorporated
in the GHG Plan, once approved by EPA. The records will be maintained
on-site in accordance with Section 1.2 above in hardcopy/electronic
format.
ii. Data will be reviewed periodically to ensure there are no data gaps or
problems.
iii. Data will be compiled annually to determine GHG emissions.

b(6) Passive Flares
Passive flares (ie. vent flares, tiki torches, etc.) are not required to measure
landfill gas collection and recovery at this time. Therefore, facilities with a
passive flare system are not required to determine flow or methane content.
The EPA has posted documentation regarding the exclusion of passive flares.
Additional information is contained in EPAs FAQs document included herein
as Attachment A. Absent flow data, the facility will assume no destruction of
methane occurred for purposes of emissions calculations until such time the
information is required or available.
3.2 GENERAL STATIONARY FUEL COMBUSTION SOURCES SUBPART C
A facility that has stationary fuel combustion sources is required to report and document
the procedures used to ensure the accuracy of the estimates as applicable for fuel
usage, sorbent usage, steam production, and boiler efficiency.
There are specific source categories that are not required to report. A summary of the
excluded source categories is included in Attachment B. The facility is not required to
report on these categories.
3.2.1 Data Collection, Monitoring, Procedures & Assumptions
i. Stationary fuel emission sources will be inventoried at each facility. The
inventory will be maintained and stored on-site in hardcopy/electronic
format. The data will be collected based on, but not limited to, the
following assumptions:
Fuel usage will be obtained from company records.
Emissions may be estimated based on total annual expenditures,
estimated running hours along with known fuel consumption rates



or best institutional knowledge (ie. approximations made by
Maintenance Manager or other knowledgeable individual).
Utility bills or annual consumption summaries obtained from the
provider may be used for determining emissions.
Monitoring will be conducted for the necessary parameters to
complete Tier 1 or Tier 2 method of calculations as applicable
under 40 CFR Part 98, Subpart C.
High heating value (HHV) for a fuel sample may be collected for
biogas or the default value will be used when no data is available.
The fuel sample will be collected in a representative location where
the fuel is combusted. The fuel samples collected for biogas can
be sampled once per quarter but shall be taken at least 30 days
apart.
The facility only uses stationary emission sources derived from fuel
billing meters which are exempted from calibration requirements.
ii. The inventory and fuel usage data collected to calculate GHG emissions
will be reviewed periodically to ensure there are no data gaps or problems.
Missing HHV data will be substituted in accordance with 40 CFR
98.35(b)(1). Other missing data (ie. operating hours) will be estimated
using the best available estimate method incorporating all relevant data
in accordance with 40 CFR 98.35(b)(2). Missing data will be
documented and records will be retained and include the procedures for
such estimates.
iii. The inventory and fuel usage data will be updated and totalled annually to
determine GHG emissions. The results of any HHV analyses will be used
to develop a site-specific higher heating value for use in calculating
combustion emissions per Subpart C. Stationary combustion units that
combust the same type of fuel from the same common supply line or pipe
can be reported as combined emissions without separating the individual
units (i.e. natural gas metered units such as a water heater and furnaces).

4.0 PROCEDURES AND METHODS
In accordance with 40 CFR 98.3(g)(5)(i)(C) of the GHG Reporting Rule, the facility is
required to provide a description of the procedures and methods used to collect the data
for GHG calculations. The processes and methods for each facility will vary depending
on the specific measuring and recording devices installed.



The following section covers the procedures and methods to ensure quality assurance
along with maintenance and repair for the following measurement devices: 1) Waste
Disposal Scale, 2) LFG Flow Meter and 3) Gas Composition Monitor.
4.1 Quality Assurance, Maintenance & Repair
1. Waste Disposal Scale
The waste disposal scale measures the incoming waste for disposal at the
landfill. The waste acceptance quantity will be determined in a manner
consistent with the requirements for commercial weighing equipment as
described in Specification, Tolerances, and Other Technical Requirements for
Weighing and Measuring Devices NIST Handbook 44 (2009).

The waste disposal scale will be calibrated, maintained and repaired in
accordance with manufacturer procedures, regulatory specifications, state or
local weights and measures requirements, appropriate industry consensus
standards and/or internal operating procedures.

2. LFG Flow Meter
The flow meter measures the landfill gas flow at the landfill. The flow meter will
be calibrated, maintained and repaired in accordance with manufacturer
procedures, regulatory specifications, appropriate industry consensus standards
and/or internal operating procedures.

Flow monitoring equipment operated to comply with Subpart HH will be
recalibrated either every two years or at the minimum frequency specified by the
manufacturer. The flow meters will be calibrated within +/-5% accuracy and will
be recalibrated if any calibration check results in a calibration error exceeding +/-
5% in accordance with 40 CFR Part 98 Subpart A.

3. Methane Composition Monitor

The methane composition monitor measures the methane concentration of
landfill gas at the landfill. The methane composition monitor will be calibrated,
maintained and repaired in accordance with manufacturer procedures, regulatory
specifications, appropriate industry consensus standards and/or internal
operating procedures.

Gas composition monitors will be calibrated prior to the first reporting year.
Thereafter, calibration will be performed either annually or at a minimum



frequency specified by the instruments manufacturer, whichever is more
frequent. The gas composition monitor must be recalibrated if there is an error
that exceeds +/-10% in the midrange calibration check.


March 2010 (version 1.0)

APPENDIX A
EPA Frequently Asked Questions
Subpart HH, Municipal Solid Waste Landfills



Mandatory Reporting of Greenhouse Gases Rule
New Frequently Asked Questions: Subpart HH, Landfills
Posted January 21, 2010

Subpart HH

When does moisture content need to be corrected for in Equation HH-4?

If CH4 concentration and flow are both measured on a wet basis or both
measured on a dry basis, then no moisture correction is needed. If one is
measured on a wet basis and the other on a dry
basis,then correction is needed.

Are scales required?

Yes. Starting January 1, 2010, scales are required. Alternative methods to
measure waste quantities are not allowed after that date except in the case
of use of best available methods for a limited time. During January 1, 2010
through March 31, 2010, owners and operators of landfills subject to the
reporting rule may use best available monitoring methods for determining the
quantity of waste landfilled if it is not reasonably feasible to acquire,
install and operate monitoring equipment according to the requirements of
subpart HH. If a landfill owner or operator will not be able to install the
required weighing equipment by April 1, 2010, then they can submit a request
to EPA to allow use of best available monitoring methods (e.g., available
records or measurements methods) for a longer period of time. See 40 CFR
98.3(d) for details on use of best available monitoring methods and extension
requests. Extension requests must be submitted by January 28, 2010 to the
address in 40 CFR 98.9. For more information, please see the Special
Provisions for 2010 Fact Sheet, available at
http://www.epa.gov/climatechange/emissions/downloads/2010SpecialProvisionsInf
oSheet.pdf

What models are acceptable for performing the calculations in subpart HH?

Either the IPCC waste model or LandGem may be used for calculating modeled
methane generation under subpart HH. Note that although LandGem may be used
directly for bulk MSW, it is not available by waste type. LandGem may still
be used, but separate runs would need to be done to model different types of
waste.

How should inert wastes be accounted for in Equation HH-1.

If an MSW landfill has inert waste (glass, plastics, metal, etc) co-mingled
with degradable waste streams, and the facility is using the waste-specific
values in Table HH-1, then the value of zero should be assigned for the DOC
and k values for this volume of waste. If the facility is using the
bulk waste values for their calculations, then the inert waste quantities
must be included in the quantity of waste landfilled used in the calculation.



The DOC and k values for bulk waste in Table HH-1 account for some volume of
inert wastes. That is, you cannot use 'material-specific' defaults
only to exclude waste for the calculation.

The methods listed in section 98.344 are not applicable to my monitor, how
should I calibrate?

If none of the methods listed in 98.344(c) apply, calibrate as specified by
the manufacturer.

What is the definition of facility as it relates to landfills and landfill
gas to electric (LFGTE) plants?

The rule defines facility as any physical property, plant, building,
structure, source, or stationary equipment located on one or more contiguous
or adjacent properties in actual physical contact or separated solely by a
public roadway or other public right-of-way and under common ownership or
common control, that emits or may emit any greenhouse gas. In the case of a
landfill, if one entity owns and operates the landfill and a completely
separate entity owns and operates the landfill gas energy equipment, they
would be two separate facilities.

We do not have any records or receipts for the waste quantities that were
placed in our landfill before 2000, how do we estimate historic waste
quantities before that year?

If records or receipts for waste disposal quantities are unavailable, the
reporter must use one of the three estimation methods listed in 98.343(a)(3).

If an MSW landfill has a dedicated area which receives waste other than MSW,
may this area be excluded from the rule requirements?

"MSW landfill means an entire disposal facility in a contiguous geographical
space where household waste is placed in or on land. An MSW landfill may also
receive other types of RCRA Subtitle D wastes (40 CFR 257.2) such as
commercial solid waste, nonhazardous sludge, conditionally exempt small
quantity generator waste, and industrial solid waste. Portions of an
MSW landfill may be separated by access roads, public roadways, or other
public right-of-ways. An MSW landfill may be publicly or privately owned.
Unless this dedicated area is considered a completely separate landfill
facility then this area cannot be excluded from the various requirements of
the rule.

If an MSW landfill is later remediated as a hazardous waste landfill, does it
need to comply with the rule?

Only RCRA Title C or TSCA hazardous waste landfills are exempt. MSW landfills
that were later remediated are not exempt. Even after remediation, these
landfills are still expected to have potentially significant CH4 emissions
and are therefore required to report.



If I use a flame ionization detector (FID) or an infrared (IR) monitor, am I
required to determine an annual non-methane organic correction factor?

If the FID or IR monitor measures total hydrocarbons, an annual non-methane
organic carbon correction factor must be established, per section
98.344(b)(6)(ii). Some infrared monitors operate in such a manner as to
detect only methane; these methane-specific analyzer systems do
not need to establish or use a correction factor.

If two entities share a Title V permit would that preclude them from
reporting separately even if there is no common ownership or control?

EPA has determined that the Title V definition of facility is not appropriate
for this GHG reporting rule. The GHG rule serves a different purpose than
Title V programs and therefore defines a facility in a way that is more
inclusive of all large emitters. Under the facility definition in the GHG
rule, if there is no common ownership or common control, then the facilities
would be separate and their emissions would be reported separately.

Do landfills have to report the biogenic CO2 that is included in LFG
emissions and the CO2 that is emitted from flares?

No. Biogenic CO2 emissions contained in landfill gas are not reported. While
the rule requires reporting, under subpart C, of biogenic CO2 emitted from
stationary combustion units, flares are excluded from Subpart C.

How does EPA define "at least weekly" in the monitoring requirements?

Under Subpart HH of the mandatory GHG reporting rule, at least weekly means
that measurements must be taken once each calendar week with at least three
days between measurements.

If all of our landfill gas gets piped offsite to another facility, what do we
need to report?

If the landfill and the other facility are separate facilities under the
facility definition in 40 CFR 98.6 and the landfill generates 25,000 metric
tons or more of CO2 equivalent per year , then the landfill must (1)
calculate and report methane generation according to both equations HH-5 and
HH-7, and (2) calculate and report methane emissions according to both
equations HH-6 and HH-8. If the gas is transported off-site for destruction,
then the landfill should use a destruction efficiency (DE) of 1.0 in
equations HH-6 and HH-8. Note that if the landfill owns and operates
any stationary combustion devices at the landfill, the landfill would report
emissions from these combustion devices under Subpart C. However, the
landfill would not report emissions from stationary combustion devices
located at a separate off-site facility that combusts gas from the
landfill.



My site has a gas collection system, which equations do I need to calculate
to determine my methane generation and GHG emissions?

For landfills that have gas collection systems, you must calculate methane
generation using both equations HH-5 and HH-7. If either equation shows that
the landfill has methane generation 25,000 metric tons CO2e, then the
landfill is required to report under the rule. If the landfill is
required to report, than emissions must be calculated and reported using both
equations HH-6 and HH-8.

Can an alternate oxidation factor, other than 10% be used in the
calculations?

No, the 10% oxidation fraction must be used in the rule equations.

Does EPA accept thermal flow meters for measuring volumetric flow rate of
LFGs?

Thermal mass flow meters may be used to comply with the monitoring
requirements of the rule provided they meet the accuracy requirements under
section 98.3(i). Calibration should be done as specified by the manufacturers
if none of the methods listed in section 98.344(b) or (c) are applicable.

Do passive flares count as "gas collection systems" under the provision
below? Do the landfills with these systems have to collect data weekly?

Passive vents/flares (those that are not connected to a system of pipes used
to collect landfill gas from different locations in the landfill to a single
location for treatment or use) are not covered by the definition of "Gas
collection system or landfill gas collection system" in Section 98.6 of the
rule. Landfills that do not have gas collection systems are not required to
collect gas flow and methane concentration data.

Does EPA's definition of treatment equipment include moisture knockout and
blower systems? Is it acceptable to EPA for the flow meter to be placed after
the moisture knockout and blower or is it is required to be placed before
these items?

The term treatment equipment under the rule refers to destruction devices.
Knock out pots, blowers, compressors, condensate traps, etc. are not
considered treatment under the rule. However, all measurements need to occur
at the same relative location, i.e, all measurement
should be made after the knock-out pot, blower, etc. or all before the knock-
out pot, blower, etc. It is actually preferred that the measurements be made
after the knock-out pot, blower, etc.

Are portable meters that determine methane concentration acceptable for
compliance with the rule requirements?

Yes, a portable infrared monitor may be used to comply with the requirements
of the final rule.



Are annubars or v-cone flowmeters acceptable for compliance with the rule
requirements?

Annubar and/or v-cone flow meters (and any other type of flow meters) are
allowed under the rule provided they meet the accuracy requirements for flow
meters in Section 98.3(i). Calibration would be done as specified by the
manufacturer if none of the methods listed in Section 98.344(c) are
applicable.

Is weekly monitoring of both gas flow and methane concentration allowed?

No, gas flow must be monitored continuously. Methane concentration can be
monitored weekly if continuous monitoring is not already in place.

The applicability tool refers to a 350,000 waste-in-place threshold. Is
reporting required if the total waste-in-place is less than 350,000 tons?

The purpose of the applicability tool found on the EPA website is to give
potential reporters guidance as to whether they meet the threshold of
generating 25,000 tons CO2 equivalent and are therefore required to report
under the rule. There is no 350,000 metric ton capacity limit or
waste-in-place exclusion in the rule. The 30 year waste-in-place of less than
350,000 metric tons was estimated as the quantity below which a typical
landfill, using the bulk waste model, would not exceed the 25,000 ton CO2
equivalent reporting threshold. Some facilities may have much higher methane
generation. Please refer to the disclaimer for the use of the applicability
tool. Facilities are encouraged to perform generation and emission
calculations based on the methods specified in 40 CFR 98, Subpart HH to
determine if reporting is required. According to the rule, if a landfill
generated more that 25,000 metric tons of CO2 equivalent calculated
according to subpart HH, it is required to report emissions.

Can a landfill ever stop reporting under the rule?

A landfill can stop reporting under the rule is it emits less than 25,000
metric tons of CO2 equivalent for 5 years or less than 15,000 metric tons of
CO2 equivalent for 3 years. A landfill cannot stop reporting under the rule
simply because it ceases operations (i.e. no longer accepts waste) since
methane will continue to generate due to the waste in place even though new
waste is not being added.



APPENDIX B
Excluded Sources
Subpart C - Stationary Fuel Combustion Sources



STATIONARY FUEL COMBUSTION EXCLUSIONS
The specific source categories with applicable definitions as defined by 40 CFR 98.6
and clarifications as needed include:
Portable equipment has the meaning derived from the definition of portable
which is defined as a device "designed and capable of being carried or moved
from one location to another. Indications of portability include but are not
limited to wheels, skids, carrying handles, dolly, trailer or platform. Equipment
is not portable if any of one of the following conditions exist:
1) The equipment is attached to a foundation.
2) The equipment or a replacement resides at the same location for more
than 12 consecutive months.
3) The equipment is located at a seasonal facility and operates during the full
annual operating period of the seasonal facility, remains at the facility for
at least two years, and operates at that facility and operates at that facility
for at least three months each year.
4) The equipment is moved from one location to another in an attempt to
circumvent the portable residence time requirements of this definition."
The term same location as referenced above means the equipment resides
in the same exact location within the same facility for more than 12
consecutive months because of the intended use.
Emergency generator means a stationary combustion device, such as a
reciprocating internal combustion engine or turbine that serves solely as a
secondary source of mechanical or electrical power whenever the primary
energy supply is disrupted or discontinued during power outages or natural
disasters that are beyond the control of the owner or operator of a facility. An
emergency generator operates only during emergency situations, for training
of personnel under simulated emergency conditions, as part of emergency
demand response procedures, or for standard performance testing
procedures as required by law or by the generator manufacturer. A generator
that serves as a back-up power source under conditions of load shedding,
peak shaving, power interruptions pursuant to an interruptible power service
agreement, or scheduled facility maintenance shall not be considered an
emergency generator.



Emergency equipment means any auxiliary fossil fuel-powered equipment,
such as a fire pump, that is used only in emergency situations.
Flares, are covered under Subpart HH Municipal Solid Waste Landfills and
therefore are exempt from Subpart C Stationary Fuel Combustion sources
data collection, monitoring, recordkeeping and reporting requirements.
Mobile sources, such as all onsite vehicles and operating equipment

10.16
QUALITY ASSURANCE PROJECT PLAN FOR CONTINUOUS H2S MONITORING

10.17
SLOPE VARIANCE
top deck Variance Worksheet.doc, Revised 9/19/2013

SOLID WASTE MANAGEMENT FACILITY

VARIANCE CANDIDATE WORKSHEET
Section A: Facility name
Apex Regional Landfill
Section B: Regulation reference(s)
444.680
Section C: Standard specified in the regulations
Landfill refuse grading not less than 3%
Section D: Proposed alternative to standard specified in the regulations
Utilize a temporary 1% grade over the active waste disposal area to facilitate safe operations of large-scale tipping
equipment. All final slopes of the landfill surface will continue to have a 3% minimum grade.
Section E: How proposed alternative will comply with the intent of the specified standard and
will protect public health and the environment
A 1% grade will continue to provide positive drainage control while significantly increasing the stability of large
scale tipping equipment by allowing it to be operated on a flatter surface.

11
WASTE CHARACTERIZATION

12
INITIAL VOLUMETRIC SURVEY

13
LAST VOLUMETRIC SURVEY

14
PLANS FOR LANDFILL COVERS

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