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Home My WebLink About20203534GOLDER APPENDIX C Operations Plan Pawnee Waste Landfill Weld County, Colorado Prepared for: Pawnee Waste LLC 3003 E. Harmony Road, Suite 300 Fort Collins. Colorado 80528 Prepared by: Golder Associates Inc. 7245 W Alaska Drive. Suite 200, Lakewood. Colorado USA 80226 +1 303 980-0540 1407882B Revision 5 July 20. 2020 July 20, 2020 1407882B Revision 5 Revision History This document has been revised as indicated below: Revision ii Number Revision Date Description of Revision 0 July 23, 2015 Initial Issuance 1 October 20, 2015 Revised leachate management/recirculation 2 February 19, 2016 Revised Revised Revised Revised leachate discussion stormwater daily cover management of inspection procedures initial waste requirements procedures placement 3 April 22, 2016 Revised Revised Revised waste temporary contact placement water offsets slopes options waste management 4 August 2, 2019 Revised to include tracer materials 5 July 20, 2020 Updated Revised leachate site address characterization and requirements management GOLDER July 20. 2020 1407882B Revision 5 Table of Contents 1.0 INTRODUCTION 1 1.1 Purpose and Scope 1 1.2 Definitions 1 1.3 Abbreviations and Acronyms 2 2.0 GENERAL OPERATIONS 3 2.1 Facility Location [Regulation 3.3.1(A)] 3 2.2 Regulatory Status [Regulation 3.3.2(C)] 3 2.3 Landfill Service Area [Regulation 3.3.1(D)] 3 2.4 Facility Access and Traffic Flow [Regulation 3.2.3(3)(g)] 3 2.5 Operating Hours [Regulation 3.3.2(B)] 4 2.6 Signage 4 2.7 Site Security and Access Control [Regulations 2.1.7, 2.1.8, and 3.3.2(H)] 4 2.8 Water/Sanitary Requirements [Regulations 3.3.2(M). 3.3.6] 5 3.0 INFRASTRUCTURE, PERSONNEL, AND EQUIPMENT 5 3.1 Landfill Operator [Regulation 3.3.2(A)] 5 3.2 Facility Infrastructure 5 3.3 Personnel [Regulations 3.3.2(A) and 3.3.2(D)] 6 3.3.1 Site Manager 6 3.3.2 Gate Attendant 7 3.3.3 Lead Operator 7 3.3.4 Additional Landfill Personnel 7 3.4 Operator Training [Regulations 2.1.2(B)(3) and 2.4.2] 7 3.5 Equipment [Regulation 3.3.2(E)] 8 4.0 LANDFILL DEVELOPMENT AND SEQUENCING 9 5.0 WASTE HANDLING AND PLACEMENT (REGULATION 2.1.10) 9 5.1 Initial Waste Placement 10 ' GOLDER ii July 20, 2020 1407882B Revision 5 5.2 Disposal Area Grading and Operational Stormwater Controls 11 5.3 Fill Progression 11 5.4 Solidification Operation 11 6.0 ENVIRONMENTAL MANAGEMENT 11 6.1 Leachate Management [Regulation 3.2.5(D)] 11 6.1.1 Leachate Minimization 11 6.1.2 Contact Water Management 12 6.1.3 Leachate Collection and Removal 12 6.1.4 Leachate Management and Storage 13 6.1.5 Leachate Characterization and Disposal 13 6.1.6 Leachate Recirculation (Application) (Regulation 3.3.7) 14 6.1.7 Leachate System Monitoring/Inspection 15 6.1.8 Leachate Management Documentation 15 6.2 Surface Water Management (Regulations 2.1.4, 2.1.6. 2.1.10. 2.1.17. 3.2.6) 15 6.2.1 Stormwater Controls 15 6.2.1.1 Permanent Stormwater Control Structures 16 6.2.1.2 Temporary Stormwater Controls 17 6.2.2 Stormwater Permit 17 6.2.3 Inspections and Maintenance 18 6.3 Groundwater Monitoring (Regulation 2.2) 19 6.4 Air Monitoring (Regulation 2.1.1) 19 6.5 Explosive Gas Monitoring (Regulation 2.3) 19 7.0 COVER MATERIAL [REGULATIONS 2.1.10, 3.3.2(G), 3.3.4, AND 3.3.5] 19 7.1 Daily Cover 19 7.2 Intermediate Cover 20 7.3 Final Cover 20 7.4 Stockpiling, Borrow Activities, and Topsoil Handling 20 8.0 NUISANCE CONTROL [REGULATIONS 2.1.3 AND 3.3.2(I)] 20 8.1 Odor, Noise, and Vector Control 20 GOLDER iii July 20. 2020 1407882B Revision 5 8.1.1 Odors 20 8.1.2 Noise 21 8.1.3 Vectors 21 8.2 Bird and Wildlife Control 21 8.3 Dust Control 21 8.4 Fire Prevention [Regulations 2.1.9 and 3.3.2(J)] 22 8.5 Litter Control [Regulations 2.1.7, 2.1.11, and 3.3.2(K)] 22 9.0 SAFETY STANDARDS AND TRAINING 22 10.0 EMERGENCY RESPONSE PLAN 23 10.1 General Emergency Response 24 10.2 Hot Load, Fire, or Explosion [Regulation 3.3.2(J)] 24 10.3 Leaks/Spills/Releases 25 10.4 Utility or Pipeline Contact/Breach 25 11.0 CONTINGENCY PLAN Z5 11.1 Substance Release (Regulation 2.1.18) 25 11.2 Contamination of Surface Water or Groundwater [Regulation 3.3.2(L)] 25 11.2.1 Groundwater Impacts 26 11.2.2 Surface Water Impacts 26 11.3 Nuisance Conditions beyond Site Boundary [Regulation 3.3.2(L)] 26 11.3.1 Mud & Vehicle Tracking 26 11.3.2 Dust 26 11.3.3 Debris 26 11.3.4 Run-on or Runoff Control Failure 27 12.0 FACILITY INSPECTIONS 27 13.0 RECORDKEEPING (REGULATIONS 2.4 AND 3.4) 28 GOLDER iv July 20. 2020 1407882B Revision 5 SAMENISselieSe•WilanftalILSIZIal TABLES Table C-1: Facility Equipment 8 Table C-2: Surface Water Management Controls Inspection Checklist 18 Table C-3: Facility Inspections 27 APPENDICES APPENDIX C-1 Example Forms Daily Operations Log Weekly Inspection Log Leachate Management Log Leachate Spray Log Spill Recordkeeping Form Quarterly/Post-Runoff Event Landfill Inspection Form 4 GOLDER July 20. 2020 1407882B Revision 5 1.0 INTRODUCTION 1.1 Purpose and Scope This Operations Plan is part of the Engineering Design and Operations Plan (EDOP) for the Pawnee Waste Landfill (Landfill or Facility) located in Weld County. Colorado. The Landfill, which will be owned and operated by Pawnee Waste LLC (Pawnee), will consist of an approximate 74 -acre disposal area within a 240 -acre contiguous property (Site). This Operations Plan describes the activities required to operate the Facility in accordance with the applicable operating criteria specified in Section 2 and Section 3.3 of the Colorado Department of Public Health and Environment (CDPHE) "Regulations Pertaining to Solid Waste Sites and Facilities" (6 CCR 1007-2, Part 1) (Regulations). Additional operating provisions required based on the CDPHE "Interim Policy and Guidance Pending Rulemaking for Control and Disposition of Technologically -Enhanced Naturally Occurring Radioactive Materials in Colorado (2007)" are also included. 1.2 Definitions Active Portion: That part of a facility or unit that has received or is receiving wastes and that has not been closed in accordance with the Regulations. Designated Facility: A disposal site or facility where radioactive materials or materials contaminated by radioactive substances is specifically designated for receipt of said materials as required by 30-20-110-1 (c), C.R.S. Exploration and Production (E&P) Waste: Exploration and production waste. as that term is defined in Section 34-60-103, C.R.S E&P waste is currently defined as wastes that are generated during the drilling of and production from oil and gas wells or during primary field operations, and that are exempt from regulation as hazardous wastes under Subtitle C of the federal "Resource Conservation and Recovery Act of 1976," 42 U.S.C. sec. 6901 to 6934, as amended. Hazardous Waste: Those substances and materials defined or classified as such by the Hazardous Waste Commission pursuant to 25-15-302, C.R.S., as amended. Liquid Waste: Any waste material that is determined to contain "free liquids." A material is deemed to contain "free liquids" if it fails the "Paint Filter Liquids Test," USEPA Method 9095B, as published in USEPA Publication SW -846 "Test Methods for Evaluating Solid Waste." Municipal Solid Waste (MSW): Solid waste from household, community, commercial, and industrial sources that does not contain hazardous wastes as defined in Section 25-15-101(9) of the Colorado Hazardous Waste Act unless otherwise regulated by the Department. NORM: Naturally -occurring radioactive material. Radioactive Material: Per 25-11-101(6), C.R.S., any material, whether solid, liquid, or gas, that emits radiation spontaneously. Radioactive Waste: Wastes governed by the Colorado Radiation Control Regulations (6 CCR 1007-1), Part 01 of which states "`Waste' means low-level radioactive waste that is acceptable for disposal in a land disposal facility and, for purposes of this definition, that is not classified as high level radioactive waste, spent nuclear fuel, or byproduct material meeting definition (2), (3) or (4)." Part 14 of 6 CCR 1007-1 establishes licensing requirements for land disposal of low-level radioactive waste. GOLDER 1 CD CDPHE DRO EAP EDOP E&P GRO HMWMD LCRS µR/hr MOLO MSW N ORM PCBs pCi/g PPE ppm RCRA Regulations SVOCs SWANA TENORM U SEPA U SR VOCs July 20. 2020 1407882B Revision 5 TENORM: Technologically -enhanced naturally -occurring radioactive material. Working Face: That portion of a facility for solid wastes disposal where solid wastes are actively unloaded, placed, compacted, and covered at any time of operation. Abbreviations and Acronyms Certificate of Designation Colorado Department of Public Health and Environment diesel range organics (as analyzed by TPH-DRO by USEPA Method 8015M) Emergency Action Plan Engineering Design and Operations Plan exploration and production gasoline range organics (as analyzed by TPH-GRO by USEPA Method 8015M) Hazardous Materials and Waste Management Division leachate collection and removal system microRoentgens per hour manager of landfill operations municipal solid waste naturally -occurring radioactive material polychlorinated biphenyls picoCuries per gram personal protective equipment parts per million Resource Conservation and Recovery Act CDPHE "Regulations Pertaining to Solid Waste Sites and Facilities" (6 CCR 1007-2, Part 1) semi -volatile organic compounds (as analyzed by USEPA Method 8270C) Solid Waste Association of North America technologically -enhanced naturally -occurring radioactive material U nited States Environmental Protection Agency U se by Special Review volatile organic compounds (as analyzed by USEPA Method 8260B) ,,, GOLDER 2 July 20. 2020 1407882B Revision 5 2.0 GENERAL OPERATIONS 2.1 Facility Location [Regulation 3.3.1(A)] The Facility will be located approximately four miles southeast of Grover, Colorado, on a 240 -acre property in Weld County encompassing the northeast quarter and the east half of the northwest quarter, Section 13, Township 10 North. Range 61 west of the 6th Principal Meridian. The Landfill Address is: Pawnee Waste Landfill 47368 Co Rd 118Grover, Colorado 80729 2.2 Regulatory Status [Regulation 3.3.2(C)] The Landfill will be permitted as a "solid waste disposal landfill facility" subject to Sections 2 and 3 of the Regulations. As a condition of Landfill operation, a Certificate of Designation (CD) will be obtained from the local governing body having jurisdiction. Weld County, in accordance with Sections 1.3 and 1.6 of the Regulations. The Facility will also operate under the provisions of a "Use by Special Review" (USR) permit issued by Weld County. The Landfill will be a Designated Facility and will accept only non -hazardous wastes as defined by the CDPHE Hazardous Materials and Waste Management Division (HMWMD). In no event will the Facility receive "radioactive wastes" as regulated under Part 14 of the Radiation Control Regulations (6 CCR 1007-1); such wastes will be deemed unacceptable and specifically prohibited. 2.3 Landfill Service Area [Regulation 3.3.1(D)] The Landfill will primarily serve generators in or serving the oil and gas E&P industry, without geographic limitation. Generators will exercise business judgment based on market conditions and local/regional disposal options in selecting the Landfill for disposal of their E&P, E&P-related, and industrial wastes. 2.4 Facility Access and Traffic Flow [Regulation 3.2.3(3)(g)] The Facility is located one half mile east of the intersection of Weld County Roads (WCR) 95 and 118. Both WCR 95 and WCR 118 are gravel roadways designated on the Weld County Road Classification Plan as local roads, as shown in Drawing 2. Currently WCR 118 ends at WCR 95. Therefore, Pawnee will construct a gravel access road within the right-of-way for WCR 118 from WCR 95, east to the Facility entrance. Pawnee will enter into a non-exclusive license agreement with Weld County for the proposed access road because it will be located within their right-of-way. The main Facility entrance road will be situated approximately 2,085 feet east of the WCR 118 and WCR 95 intersection, and from there will extend southeastward to the scale house/entrance area and continue to the Landfill area, as shown in Drawings 2 and 3. The entrance road will be a gravel -surfaced road with a minimum 25 -foot width, designed and properly maintained for all-weather traffic. The access road and turnaround areas are designed to provide access to over -the -road trucks. Additional internal roads for hauling of waste, leachate (for storage, off -site disposal, or application), equipment, and supplies will be established as needed prior to and during development of the Facility. Locations of these temporary internal access roads will change periodically as landfilling operations progress and will depend on the sequence of development within the sub -phases. These temporary roads will either be situated along designated routes within developed portions of the Landfill or may traverse through undeveloped (future cell) or excavated areas. A perimeter access road will ultimately extend ' GOLDER 3 July 20. 2020 1407882B Revision 5 Ft••'ea Cart •M- --1M— around the entire perimeter of the Landfill, as shown in Drawing 3, to provide access for maintenance and monitoring. and will be constructed in phases as the Landfill is developed. 2.5 Operating Hours [Regulation 3.3.2(B)] The Landfill will be open as follows: Typically daylight hours (adjusted as based on market demand up to 24 hours/day), 7 days/week, 365 days/year The Landfill will typically operate during daylight hours (dawn to dusk), seven days a week, year-round, but may be open up to 24 hours a day, as needed, to serve the needs of the oil and gas industry. Only generators and waste streams that have been screened/characterized and pre -approved will be allowed entry. Weather conditions may also necessitate the Landfill being operated under an alternate schedule. Because the Facility will be open up to 24 hours per day, the scale house area has permanent lighting installed to aid in screening loads. The active working face of the Landfill will use portable light plants during nighttime operations to aid in visually screening waste as they are deposited. 2.6 Signage Operating hours will be posted on permanent signage at the Facility entrance. Signage will be posted at the Landfill entrance and/or scale house to indicate: Facility name Name and telephone number of Landfill operator Days and hours the Facility is open for access That all incoming wastes must be pre-screened and pre -approved Lists of waste types accepted and prohibited Restrictions against smoking, trespassing, vandalism, littering, burning, or depositing of unacceptable or unauthorized wastes A statement that conveys: "Pawnee Waste reserves the right to reject any load." Other signage will be installed as appropriate to enhance safe operating procedures, including the identification of high -hazard areas (e.g., pipelines), traffic directions, soil stockpiles, borrow areas, and emergency muster points. Portable signs throughout the Facility will direct Landfill users to the active unloading areas, control traffic and vehicle speed, and state safety precautions and unloading rules as and where needed. Signs will be positioned and relocated as traffic patterns change due to changes in waste disposal (working face) locations. 2.7 Site Security and Access Control [Regulations 2.1.7, 2.1.8, and 3.3.2(H)1 A combination of physical barriers, signs, and staffed entrance facilities (scale house) will be used to secure the Facility and prevent unauthorized access and waste dumping. A gate installed at the entrance will be closed and locked at all times when the Facility is closed. Three -strand barbed wire fencing, or functionally -equivalent material, will be constructed around the Facility perimeter to deter off -road vehicles from entering the property. The remote ) GOLDER 4 July 20. 2020 1407882B Revision 5 location, rough terrain, and installed ditches and berms will further deter potential intruders. The Facility entrance (and key locations around the site perimeter, if necessary) will be clearly marked using "no trespassing" signs. Trained personnel will be stationed at the scale house during all operating hours to monitor, screen, and control access by all users and visitors. Scale house personnel will have radio contact with other Landfill personnel to report any unauthorized activities. Pawnee will coordinate with the Pawnee Fire Protection District to ensure they have access 24 hours a day to be able to respond to an after-hours emergency, if necessary. Additional fencing or other deterrents designed to limit access to wildlife and livestock will be installed as needed around the waste cells. leachate tank storage area, and/or stormwater pond. 2.8 Water/Sanitary Requirements [Regulations 3.3.2(M), 3.3.6] Potable water for Pawnee personnel and visitors will be either piped to the Facility or a well will be drilled on site. A septic system will be installed to serve the sanitary facilities at the scale house, which will include hand washing, toilet, and hygiene areas for employees and visitors. Water needed for construction, dust control, and fire suppression will be available in adequate amounts from either an on -site supply well or a commercial facility located within one mile of the Site. 3.0 INFRASTRUCTURE, PERSONNEL, AND EQUIPMENT 3.1 Landfill Operator [Regulation 3.3.2(A)] Pawnee Waste LLC will be the Landfill operator. An office will be maintained at the Site and will serve as the primary point of contact for the Landfill operation. Pawnee, through and in cooperation with the appointed site manager. will have the authority to take corrective action in the event that aspect(s) of the Landfill operation are noted to be non -compliant. Following is the address for the Pawnee corporate office: Pawnee Waste LLC 3003 E. Harmony, Suite 300 Fort Collins, CO 80528 Phone: (970) 818-7658 3.2 Facility Infrastructure Proposed Site improvements and structures at the Facility are shown in Drawing 4 and will include: Entrance road and permanent perimeter road — Facility entrance will be located on south side of the extension of WCR 118. The entrance road will extend southeast to the scale house and parking areas. A permanent perimeter road ranging from 15 to 30 feet wide will extend around the Landfill (to be constructed in stages). Scale house and employee/visitor parking — Trailer to serve as office/scale house, with a minimum of 10 parking spaces. Weigh scale(s) — Only one scale is envisioned at the outset of the Landfill operations. A second scale may be added, if needed. depending on waste traffic and volumes received. If the second scale is installed. it will be positioned so that one scale will typically handle incoming trucks and the other will handle outgoing trucks. A truck turnaround area will be provided to accommodate routing of rejected loads. and will also be used for temporary parking of loads requiring inspection before proceeding. ' GOLDER 5 July 20, 2020 1407882B Revision 5 Maintenance/employee facility - The maintenance building will be used by Pawnee employees performing maintenance on equipment used at the Facility and will also provide a change and washroom for the operators. Pumps, filters, power generator, and replacement parts will be stored in the maintenance building. Waste oils and fluids from routine maintenance will be contained in accordance with CDPHE and Weld County standards, and disposed of at an authorized facility. Equipment parking and staging area - Gravel parking and staging areas will be used to park equipment at night, and could potentially also be used by customer trucks awaiting inspection, waste acceptance confirmation, or unloading instructions. This area may also be used to store ancillary equipment such as heavy equipment attachments. Fueling area - Diesel fuel tank with proper secondary containment and spill controls, including a Spill Prevention, Control, and Countermeasure Plan in accordance with the requirements of 40 CFR §112. ■ Leachate storage area - See Section 6.1.4. 3.3 Personnel [Regulations 3.3.2(A) and 3.3.2(D)] Pawnee will employ qualified personnel to conduct all daily operations of the Facility, as described in the following sections. These personnel will be employed by, or report directly to. Pawnee. The Pawnee operations personnel will: Operate the scale; Inspect incoming waste; Unload, spread, compact, and cover waste; Operate, maintain, and monitor the leachate management system; Maintain the stormwater system; Maintain the Facility; and Pick up minor spills and trash and remove from the site. 3.3.1 Site Manager The site manager will be responsible for the day-to-day Landfill operations, including ensuring that proper operational practices are being followed and that the site operations maintain regulatory compliance. The site manager will make or supervise inspections of operations, and will be available by radio or phone at all reasonable times. The site manager will have the authority to ensure that the Facility is being operated in accordance with the EDOP (including this Operations Plan); the CD and USR conditions set forth by Weld County; and all other applicable federal. state, and local rules, regulations, permits, and conditions. The site manager will, in conjunction with Pawnee management, determine when modifications to the EDOP may be necessary or warranted, and seek CDPHE and Weld County (if applicable) approval of such modifications prior to implementation. The site manager shall be qualified to operate the Landfill, and will possess the following: 1) A thorough understanding of the Landfill construction, operation, and monitoring procedures. as specified in the governing permit documents. GOLDER 6 July 20, 2020 1407882B Revision 5 2) A working knowledge of the applicable rules, regulations, permits, and conditions. 3) A combination of appropriate work experience and/or documented completion of classroom or field training program(s). In the event of a personnel change for the site manager position, the new incoming site manager shall meet the qualifications above within six months of assuming that role. 3.3.2 Gate Attendant A gate attendant will be present at all times when the Landfill is open for receipt of waste and will be responsible for maintaining a log of all waste loads received, directing waste haulers to the working face for unloading, and for implementing and/or coordinating the waste receipt screening process prior to disposal. 3.3.3 Lead Operator The lead operator will be directly responsible for, or will supervise, other Pawnee employees in directing and spotting unloading activities at the working face.. performing and documenting routine random load inspections. and conducting waste screening observations of each load at the point of disposal. 3.3.4 Additional Landfill Personnel Pawnee intends to employ a total of up to six employees working at the site each day when the Landfill is operated at full capacity. One to two people will work at the scale house and another two to four people will work in the field managing disposal of the waste materials (i.e., heavy equipment operators) and other Landfill activities (e.g., inspections. leachate system operation, dust control, etc.). For safety purposes. at least two employees will be present during all operating hours. More employees may be required to accommodate market needs. 3.4 Operator Training [Regulations 2.1.2(B)(3) and 2.4.2] The site manager will undergo appropriate training that covers hazardous waste and PCB screening, which may include completing a Solid Waste Association of North America (SWANA) "Manager of Landfill Operations" (MOLO) course. The gate attendant and lead operator (and other Landfill personnel at Pawnee's discretion) will be required to complete a commercially -offered waste screening course (such as attending the SWANA "Waste Screening at MSW Management Facilities" training or comparable) and/or undergo internal training by qualified Pawnee representative(s). Depending on the individual employee's prior background and experience, additional training in landfill operation fundamentals may be provided (e.g., the SWANA training course `Landfill Operations Basics' or similar). The site manager will also receive recurring/recertification training and continuing education as necessary. undergo additional training as determined appropriate by Pawnee, and attend relevant training courses sponsored by CDPHE (e.g., regarding changes to state solid waste rules or guidelines). Landfill personnel shall be trained annually to identify prohibited waste and the response and notification procedures if suspected prohibited waste is discovered. Safety and emergency response training is discussed in Section 9.0 of this Operations Plan. Appropriate Facility personnel will also be trained in stormwater management in accordance with the EDOP and the site Stormwater Management Plan, as discussed in Section 6.2.2 of this Operations Plan. Personnel training shall be documented and the records maintained in the Operating Record at the Facility office (scale house) for regulatory agency review upon request. ' GOLDER 7 July 20. 2020 1407882B Revision 5 a _ 3.5 Equipment [Regulation 3.3.2(E)] The number, use, and type of equipment employed at the Landfill will vary based on the type and quantity of waste received. Landfill management will determine equipment requirements and schedule equipment to be available as needed to operate the Landfill in accordance with EDOP, CD, and USR requirements. All vehicles will be equipped with portable fire extinguishers. Following is a list of equipment likely to be used by Pawnee and or its contractors. Table C-1: Facility Equipment ;Equipment Function Scale & Software Weigh, document, and track waste received Bulldozer(s) Spread and compact waste and cover material; fire protection Excavator Excavate future cells and cover material Wheeled Front-end Loader Load cover material, site maintenance, fire protection, snow removal Motor Grader Road maintenance. drainage maintenance, grade unloading areas; snow removal Dump Truck Haul cover soil; site maintenance Farm (or equivalent) Tractor Revegetation and mowing Water Truck Dust suppression, fire protection, clean paved roads to control mud track -out Support Vehicles Equipment and site maintenance, leachate management, inspections, monitoring Leachate Pumps Leachate removal/transfer Tanker Wagon Truck or Water Portable "Frac" Tank(s) Liquid Holding Leachate storage (number of tanks will be based on peak storage needs) Portable Light Plants Illuminate work areas for safety during operations outside of daylight hours Radiation Detectors Portal radioactivity monitor and handheld gamma meter to survey incoming waste loads for Miscellaneous Power water washer, pump(s) air compressor, portable generator. camera surveillance system, Equipment deletions. substitutions. and/or replacements may be made at the discretion of the site manager and/or Pawnee management. If repair or replacement of any malfunctioning operations equipment is necessary to continue Landfill operations, then backup equipment will be rented, leased, or purchased from a local equipment supplier as soon as possible. ' GOLDER 8 July 20. 2020 1407882B Revision 5 4.0 LANDFILL DEVELOPMENT AND SEQUENCING The Landfill will be developed in a sequential manner as additional disposal areas are required. For construction and leachate management purposes, the Landfill has been subdivided into Phases 1 through 4. Drawing 3 shows the planned development by phase number. The Landfill is anticipated to be developed in four main phases (i.e., Phase 1k Phase 1 B, Phase 2A, and Phase 2B), generally corresponding with the areas shown in Drawing 3. Pawnee will further divide construction of the main phases into sub -phases (8 to 10 acres) and/or cells (approximately 5 acres). The sub -phase sizes will vary based on the estimated waste disposal capacity needs. Run-on and runoff controls will be established and maintained throughout the operation of each phase or sub -phase in accordance with the requirements given in Section 5.0 of the EDOP narrative. Disposal area operations will be managed through the use of a grid system (or equivalent) that will facilitate tracking of each waste load disposed, as well as other management activities such as cover placement or repairs. The grid will be established via stakes installed and maintained along the perimeter of the disposal area (e.g., letters along the north —south limit and numbers along the east —west limit). The initial sub -phase or cell of each phase will typically be constructed starting on the downgradient end of the phase. and thus will include construction of a leachate sump to allow for efficient leachate management in development of subsequent upgradient sub -phases or cells. Adjustments to this general progression may be made at Pawnee's discretion in order to minimize the amount of disturbed area, manage runoff more efficiently, and/or to maintain a continuous waste placement area (i.e., contiguous to previously constructed sections). Wherever a phase (or sub -phase) development area will terminate internal to the Landfill footprint (i.e., not along the final perimeter). a temporary termination berm will be constructed along the leading edge for containment of waste and contact water and to facilitate tie-in of future cells. Placement of waste will be limited to no closer than five feet from the termination berm to allow for contact water to report to the leachate collection system for collection and management. Where the leading edge is on the upgradient side of the constructed area, a temporary run-on diversion channel/berm will also typically be installed. as needed, on the undeveloped land immediately upgradient of the termination to collect and redirect the stormwater flow away from the active area. Phased construction will progress in this manner until the entire Landfill is developed. This method of phased development will limit the amount of active (open) cell area at any given point in the Landfill development, minimize leachate generation, and allow closure of one phase while waste placement is occurring in another phase, at the discretion of Pawnee. 5.0 WASTE HANDLING AND PLACEMENT (REGULATION 2.1.10) All loads accepted by the Landfill are expected to be properly contained and covered by the transporter to prevent spillage. leakage, or windblown debris from escaping the transport vehicle en route to the disposal area. When waste is delivered to the Facility, the driver will be directed onto a load scale so that the truck can be weighed and the content evaluated to ensure it matches the required paperwork. Upon acceptance of an authorized waste load and recordation of the daily grid's unique identifier, the driver will be directed to the active Landfill area. All loads of waste that have cleared the gate screening must proceed directly to the active disposal area. where drivers will be directed to off-load in the daily assigned grid by a Landfill operator. Site rules such as posted speed limits, no loitering. no littering. and safety procedures (e.g.. maintaining visibility/line of sight with heavy equipment GOLDER 9 July 20, 2020 1407882B Revision 5 operators while off-loading, staying with the vehicle, no smoking past the scale house, etc.) will be communicated to the drivers as needed. After unloading at the designated area, the truck will be directed to the Landfill exit via the appropriate route, and the driver will complete the required exit paperwork prior to leaving the Facility. When tare weights of vehicles are not current or recorded. the truck will be required to re -weigh prior to exit. Waste transporters will place waste directly in a designated active area of the Landfill. In the operation of the Landfill, the solid wastes shall be distributed in the smallest area consistent with handling traffic to be unloaded, assisted by signs and physical barriers, if necessary. The solid wastes shall be placed and/or compacted with a bulldozer into the most dense state (smallest volume) practicable in order to minimize long-term settlement and conserve Landfill airspace. Pawnee operators will direct and supervise the unloading activities. and then spread the waste across a selected area in generally horizontal layers at a thickness that will vary depending on the type and consistency of the specific waste stream, typically approximately 6 to 12 inches. Suitable heavy equipment will make several passes over the waste to minimize void spaces. This process may be adjusted based on site experience to improve compaction (e.g., reducing the thickness of layers and/or increasing the numbers of passes). A "lift" will consist of several individual layers of compacted waste and will generally range from four to six feet thick. 5.1 Initial Waste Placement An access ramp/pad will be created to provide initial access to each constructed phase as needed, typically from an adjacent unlined area. Upon CDPHE and Weld County approval of each new cell constructed, the initial layer of waste will be carefully unloaded, placed, and managed to prevent damage to the liner, drainage layer, and leachate collection system. The initial lift of waste will consist of a minimum three-foot protective cover "fluff" layer, unless otherwise approved by CDPHE. that will be carefully moved into place by a Landfill operator trained in the procedures required to ensure the environmental controls are not damaged by the heavy equipment. This protective cover "fluff' layer will be deposited from the access pad and then expanded laterally by traveling over previously -placed waste. to enable sufficient area for subsequent truck traffic. The lateral extent of the "fluff' layer will be limited in the vicinity of the crest of the perimeter berms and cell termination berms as follows to ensure unimpeded access for contact water to report to the leachate collection system: Placement of the initial "fluff' layer will be limited to no closer than 3 feet horizontally to the crest of the Landfill perimeter berm, creating a minimum 1 foot depth contact water management channel at the toe of the waste slope and leaving approximately 3.1 feet of leachate collection system drainage layer exposed along the sideslope of the berm. The outer sideslope of the `fluff' layer and subsequent lifts of waste material will initially be placed at 3H:1V slopes until they reach the tie in point with the permanent 4H:1V waste design slope, approximately 18 feet horizontally from the crest of the perimeter berm. Placement of the initial "fluff' layer will be limited to no closer than 5 feet from the cell termination berm, leaving 5 feet of leachate collection system drainage layer exposed. The temporary sideslopes of the "fluff' layer and subsequent lifts of waste material will be placed at no steeper than a 3H:1V slope. Initial waste placement will be performed using tracked equipment and avoiding tight turns to prevent rutting into the drainage layer sand or other damage. Truck or wheeled vehicle traffic will not be allowed access to any exposed area of the cell liner until at least the initial three-foot protective cover `fluff' layer of waste has been placed over the leachate drainage layer. Leachate lines within the drainage layer will be flagged and equipment operators will use extra caution when traversing them during initial "fluff' layer placement. The initial three-foot 4 GOLDER 10 July 20, 2020 1407882B Revision 5 protective cover "fluff' layer will not be subjected to compactive effort in addition to that imparted by depositing and spreading the material. Compaction will commence with the second lift of waste (i.e., the lift placed over the initial protective cover `fluff layer). In order to minimize the volume of leachate generated during the initial filling of a new phase or cell due to precipitation falling on exposed liner. one or more temporary stormwater control berms (stormwater partition berms) containing a geomembrane barrier (rainflap) will be installed during cell construction and successively removed as waste placement progresses upslope from the lower areas of the cell. 5.2 Disposal Area Grading and Operational Stormwater Controls As stated in Section 4.0 of the EDOP narrative. the liner floor will be graded at a typical 2% slope towards the leachate collection sumps to promote positive drainage and efficient leachate management. Operational practices, including waste placement, spreading, and compaction activities, will be conducted in a manner that facilitates stormwater drainage and avoids ponding. Incoming wastes will be incorporated into the Landfill active area on a daily basis to minimize the presence of piles or windrows that could block drainage of stormwater runoff. Appropriate measures will be taken to prevent and/or alleviate ponding of water over filled areas, including grading of filled surface to promote lateral surface water runoff. Runoff controls shall be maintained and operated such that surface water runoff and/or leachate from the active portion of the Landfill (i.e., uncovered or having less than intermediate or final cover) is not allowed to enter any surface water, either on site or off site, unless authorized by a National Pollutant Discharge Elimination System (NPDES) permit pursuant to the Clean Water Act. 5.3 Fill Progression After placing the initial "fluff layer. waste filling will generally progress by advancing the working face in four- to six -foot -thick lifts across each cell as an area fill. Waste lifts will typically be sloped towards the perimeter boundaries of each cell. Temporary waste slopes shall be no steeper than 3H:1 V to ensure the stability of the slope and minimize the potential for erosion of daily cover. As lifts are constructed above the elevation of the perimeter berm, ramps will be constructed and modified to permit truck access to the increased elevations of the active disposal area. The ramps will be constructed to permit truck maneuverability, and typically will not exceed grades steeper than 7.5%. The anticipated sequencing of waste filling activities is shown in Drawing 3 and will progress in such a manner as to optimize the constructed airspace and to minimize stormwater and leachate management requirements. A detail of initial waste placement in the vicinity of the crest of the perimeter berms is shown in Drawing 11 of the main text. Based on the Landfill phase planning and area filling plan, no more than 20 acres is anticipated to be open at any one time. 5.4 Solidification Operation Pawnee intends to install, operate, and maintain a Solidification Unit within the lined area of the Landfill to receive waste streams that require processing with a solidification agent (e.g., sludges, wet sediments, or drilling muds) to pass the paint filter test (USEPA Method 9095B) and thus allow these materials to be placed within the Landfill. A Solidification Unit Design and Operations Plan is presented in Appendix H of the EDOP. 6.0 ENVIRONMENTAL MANAGEMENT 6.1 Leachate Management [Regulation 3.2.5(D)] 6,1.1 Leachate Minimization Leachate generation is significantly influenced by waste type, precipitation, and the size of the active disposal area. Experience at other facilities accepting similar waste streams indicates that leachate generation tends to be relatively low at this type of landfill. Constructing cells or sub -phases of small, manageable size suitable for the GOLDER 11 July 20, 2020 1407882B Revision 5 rate/volumes of waste received, minimizing infiltration of precipitation, preventing stormwater run-on, and promoting runoff of stormwater that has not come into contact with waste are effective methods that will be employed at the Landfill to minimize leachate generation. As described elsewhere in this Operations Plan and shown in the EDOP and associated Drainage Report, the Landfill design, including perimeter berms, stormwater controls, operational practices, and final cover, are engineered to assist in accomplishing these objectives. Following are specific operational techniques that may be used to minimize leachate generation: Placement of intermediate cover over external finished slopes to prevent stormwater runoff from contacting the waste; Contouring of covered waste areas to provide positive slopes for stormwater drainage to avoid ponding within the Landfill footprint and direct runoff outside of the Landfill footprint; Installation of temporary and permanent ditches and berms along the perimeter of the waste placement area to prevent run-on from entering the Landfill footprint; and Implementing phased closure and final cover installation as significant areas of the Landfill reach final design elevations. 6.1.2 Contact Water Management Stormwater runoff that has contacted exposed waste or waste having only daily cover (i.e... contact water) will initially be treated as leachate and managed in accordance with the leachate management procedures discussed in Sections 6.1.3. 6.1.4. and 6.1.6 of this Operations Plan. Pawnee may elect to manage contact water as stormwater in the future, to the extent practical and provided the contact water runoff is only from areas covered with at least six inches of adequate daily cover. Cell termination berms will be constructed along the upgradient edge of the cell/phase for containment of waste to limit run-on into the cell from surrounding areas, and to prevent contact water from discharging to unlined areas. Additionally, stormwater partition berms containing a geomembrane barrier (rainflap) will typically be constructed in lined areas where waste is not being placed. These will limit the flow of clean rainwater through the leachate collection drainage layer, thus minimizing leachate generation. Contact water will be directed away from the active face by downstream filling patterns and allowed to percolate through the waste into the leachate collection system. As waste filling progresses vertically above the perimeter berm, the toe of the waste filling slope will remain a minimum of 1 foot (vertically) below the crest elevation of the perimeter berm (see detail 5/11), leaving a minimum of approximately 3.1 feet of leachate collection drainage layer exposed along at the waste toe/perimeter berm interface, thus containing any contact water runoff within the cell and allowing it to percolate through the drainage layer for management within the leachate collection system. Similarly, waste placement will be limited to no closer than 5 feet from the cell termination berms, leaving a minimum of 5 feet of exposed leachate collection drainage layer. 6.1.3 Leachate Collection and Removal Leachate generated in the Landfill. either from precipitation entering the active waste footprint or from liquids which may be generated as a result of long-term loading and consolidation of the waste mass, will drain to one of the four leachate collection sumps. All stormwater that contacts waste will be collected by the leachate collection system and managed as leachate. The leachate collection and removal system (LCRS) is designed to limit the maximum buildup of head on the liner system (outside of the sumps) to less than 12 inches and promote transport of leachate from the most distant point of the leachate collection system to the leachate removal system GOLDER 12 July 20, 2020 1407882B Revision 5 in less than 365 days. This will be accomplished through a combination of the sloped Landfill base grades, a one -foot -thick granular drainage layer, and leachate header drains (consisting of perforated HDPE pipes surrounded by gravel and geotextile) located along the centerline of each phase that will flow toward and discharge into the sumps located along the west and east Landfill perimeter. The sumps will be equipped with electronic level controls (transducers) and submersible pumps to facilitate leachate removal and maintenance of the leachate depth on the liner system to the prescribed level. The transducers will indicate to site personnel (either by visual means and/or automated notification) when the leachate level has reached the preset limit in any of the sumps. The pumps will be activated as needed (using a generator or other power source) to evacuate the accumulated liquid. As -built construction documents will provide specific details on the equipment, controls, and settings. Pumps and controls will be operated and maintained according to manufacturer's instructions. Maintenance, repair, and replacement of leachate removal system components will be documented in the Operating Record. 6.1.4 Leachate Management and Storage Leachate will be pumped from the sumps and transported to the leachate storage area for sampling and characterization prior to disposal. The leachate storage area, to be located immediately west of the Landfill as shown in Drawings 3 and 4, will consist of one or more 20,000 -gallon portable (e.g., frac) storage tanks inside a concrete -lined secondary containment area. The storage tank(s) will have combined capacity adequate to handle the anticipated volume of leachate storage needed, taking into account that leachate may be ultimately managed via application (dust control) onto the active Landfill area or through on -site solidification or off -site disposal. A sealed concrete basin will be installed beneath and around the tanks to maintain secondary containment capacity equal to at least 150% of the largest tank capacity, plus the precipitation volume resulting from a 25 -year, 24 -hour storm event. A dedicated loadout area will be constructed alongside the storage area to accommodate a tanker vehicle for leachate disposal. The loadout area will be graded to drain into the concrete containment area to prevent spillage or leakage of leachate onto adjacent unlined areas during leachate tank transfer activities. The leachate storage area will be inspected weekly and after significant precipitation events for visual observation of water level, concrete condition, and presence of hydrocarbon surface sheen or signs of contamination. These observations, along with any actions required, will be recorded on a field inspection log and placed in the Operating Record. All maintenance activities associated with the leachate storage area will also be documented in the Operating Record. The secondary containment area will have a gravity drainage pipe fitted with a valve to allow controlled discharge of accumulated stormwater. The valve will be normally closed. but will be opened to release the stormwater after inspection to verify that there are no signs of contamination (odor. discoloration. sheen). 6.1.5 Leachate Characterization and Disposal Leachate will require sampling and characterization prior to disposal. At a minimum, leachate will be characterized for the following parameters to determine an appropriate method for disposal: Hazardous characteristics Ra-226/Ra-228 Leachate may be disposed on -site through re -application within the lined areas of the Landfill (pending specific approval from CDPHE Air Pollution Control Division [APCD], see Section 6.1.6) provided that the leachate: ' GOLDER 13 July 20. 2020 1407882B Revision 5 Does not exhibit hazardous characteristics, as defined in the CDPHE Identification and Listing of Hazardous Waste Regulation, 6 CCR 1007-3, Part 261 [latest version]: Exhibits Ra-226/Ra-228 radiological concentrations less than 24 picocuries per liter (pCi/L); and Meets other applicable facility waste acceptance requirements (see Waste Acceptance Plan). Leachate volumes in excess of that which can be applied and/or stored in the on -site tanks, or for which the testing results for combined Ra-226/Ra-228 exceed 24 picocuries per liter (pCi/L), may be solidified on site and disposed of in the landfill or disposed of at an approved off -site disposal facility. In the event that Pawnee uses a third -party facility for off -site disposal of leachate, strict adherence to the third party's waste receipt requirements will be followed. 6.1.6 Leachate Recirculation (Application) (Regulation 3.3.7) As stated previously, the CDPHE APCD will require specific approval for applying leachate, and that such activity will not be permitted until sufficient analytical data are developed to enable APCD to make a determination on the suitability of this practice. Pending approval from APCD, leachate may be applied to the E&P wastes (within lined areas of the Landfill), primarily to manage fugitive dust, but also to enhance compaction depending on weather conditions and the moisture content/consistency of incoming wastes, as further detailed herein. Leachate will not be sprayed on the perimeter haul roads or on internal haul routes within the Landfill. Leachate application will be accomplished by transferring liquid from the storage tank(s) and spraying onto the waste via a tanker vehicle equipped with spray nozzles. Leachate applied to the E&P wastes within lined areas is subject to the following operational requirements (in addition to the characterization requirements outlined in Section 6.1.5): Application rate for dust control will remain below the average monthly evaporation rate. The monthly evaporation rate is estimated at approximately 1.25 inches per month based on HELP model 100 -year synthetic meteorological simulations. This evaporation rate corresponds to a leachate application rate or no greater than approximately 34,000 gallons per acre per month. Application will be practiced in lined areas of a cell where a second lift area has been placed. Application will be performed when temperatures are above freezing. Application will be monitored and recorded in a Leachate Spray Log, which will form part of the permanent Operating Record and will identify: Date, temperature, wind conditions, cloud cover, and dew point Volume of leachate applied Begin and end times Area of application Issues requiring mitigation, if any, including ponding, soil saturation, and odor Mitigation measures that have been deployed Confirmation that the mitigation measures have been successful 4.. GOLDER 14 July 20. 2020 1407882B Revision 5 Leachate will not be permitted on exterior slopes, areas where final cover has been applied, perimeter roadways, or any other areas outside of the lined footprint. All application activities will be conducted in a manner so as to prevent waste saturation or excessive runoff. and will be limited to days when weather conditions are favorable (i.e., light winds and lack of significant precipitation). Volumes of leachate application will be recorded on each day that application is performed, along with other pertinent information, such as weather conditions, area of application (sub -phase), and start/stop times. This information will be maintained in the Operating Record. The use or application of leachate on Pawnee property outside of the lined areas of the Landfill is prohibited. 6.1.7 Leachate System Monitoring/Inspection The accessible components of the leachate collection and removal system will be inspected weekly, and the inspections will be documented in the Weekly Landfill Inspection Form included in Appendix C-1. Items that will be inspected include: Sump risers and cleanout risers (for signs of mechanical/equipment or other damage); Pipe fittings/connections (for deteriorating gaskets, loose bolts, etc.); Pump and transducer operations: Leachate levels in the sumps; and Leachate storage area (tanks. concrete containment basin. and loadout area inspected for signs of leaks or spills). 6.1.8 Leachate Management Documentation Leachate management documentation that will be maintained in the Operating Record will include the: Leachate analytical test results; Volume removed from each of the sumps per pumping event, including date and head readings; Volume solidified and disposed on site in accordance with Section 2.4 of the Waste Acceptance Plan. The volume solidified and disposed will be recorded in the Leachate Management Log; Volume applied for dust control, including date, location applied, duration or application rate, and weather conditions; and it. Volume transported from the site for off -site disposal, including date and receiving facility. 6.2 6.2.1 Surface Water Management (Regulations 2.1.4, 2.1.6, 2.1.10, 2.1.17, 3.2.6) Stormwater Controls Temporary and permanent surface water (stormwater) control structures and erosion control measures will be constructed over the life of the Landfill to manage surface water runoff. Surface water controls proposed at the Facility are discussed in detail in Section 5.0 of the EDOP narrative and in the Drainage Report (Appendix B-3 to the EDOP). Proper installation and maintenance of appropriate surface water controls is essential to avoid the co -mingling of leachate with surface water runoff that has not been in contact with waste, and is required to GOLDER 15 July 20, 2020 1407882B Revision 5 -.11t ensure that stcrmwater leaving the Facility is controlled and complies with the EDOP and the conditions of the stormwater discharge permit (see Section 6.2.2). Proper surface water drainage and controls will be maintained at the Landfill to: Provide trafficable roads: Divert surface water run-on from areas upgradient of the Landfill around the site; Prevent rin-on to the active area of the Landfill; Prevent runoff that has contacted exposed waste from leaving the active areas of the Landfill; Prevent cischarge of impacted water from the site; and Minimize erosion and sedimentation of disturbed areas. 6.2.1.1 Permanent Storm water Control Structures Permanent stcrmwater control structures installed at the Landfill will include: Perimeter run-on diversion channels; Perimete- runoff collection/conveyance channel located within Landfill perimeter berm alignment; A terrace (bench) built into the Landfill final cover approximately midway vertically down the sideslope and sloped longitudinally to the downchute channels; Access road channel alongside the permanent access road, which extends from the northwest Landfill perimeter to the Landfill crest; Downchute channels to collect the flow from the terrace channels and access road channel and direct it downslope to the perimeter runoff collection channel; A stormwater detention pond located adjacent to the west side of the Landfill; and Armoring or reinforcement of areas where stormwater flows are predicted to have velocity and/or discharge rate exceeding design parameters for grass -lined structures. There will be one stormwater detention pond on site for attenuation of peak stormwater runoff flows and capture of sediment in runoff from disturbed areas of the Landfill. To ensure that the pond maintains capacity for coming storm events, it will have a low-level outlet to slowly discharge water following each storm event. The stage -storage data for the pond is presented in the Drainage Report (Appendix B-3). Provisions for management of stormwater collecting in the leachate tank storage area are discussed in Section 6.1.4. The stormwater pond is designed to maintain a minimum freeboard of 2.5 feet between the maximum water surface resulting from a 100 -year, 24 -hour storm event and the crest elevation of the pond. The perimeter run-on diversion channels, which will be aligned along the outer edge of the perimeter berm on the north and east sides of the Landfill. will be constructed prior to or concurrent with initial phase development. The permanent stcrmwater detention pond is necessary once the waste filling level in the constructed phases extends above the level of the perimeter berm; thus, the permanent stormwater pond may be installed either in conjunction with initial phase development or at a later date if Pawnee elects to use temporary (below -grade) stormwater ' GOLDER 16 July 20. 2020 1407882B Revision 5 detention features during early stages of landfilling. The perimeter runoff channel within the Landfill perimeter berm will be installed in segments as the adjacent Landfill phases are developed. Surface water runoff control features on the finished Landfill slopes (terrace channels, access road channel, and downchutes) will be established in conjunction with final cover construction at the time of either phased or final closure. The final cover stormwater control system is designed to limit long-term (i.e., after establishment of vegetative growth on the final cover) erosion loss due to precipitation to no more than two tons/acre-year. Armoring and reinforcement required for any of the permanent stormwater controls will be specified and installed along with the control feature being constructed. Calculations and details of the permanent stormwater management system are included in the Drainage Report (Appendix B-3). 6.2.1.2 Temporary Storm water Controls The network of permanent stormwater control structures will be supplemented by the installation of temporary stormwater controls and the implementation of best management practices (BMPs) to minimize sediment loading from construction zones, stockpiles, and other disturbed areas on the property, which may include, but are not limited to: Temporary berms and ditches Silt fences, straw bales, and/or straw wattles Rock check dams, sediment traps Temporary seeding and/or mulching Details for the temporary stormwater diversions and other controls will be prepared with the construction packages for each phase of construction. Temporary diversion berms will typically be constructed along the waste filling slopes and temporary excavation slopes to limit run-on into the cell from the surrounding areas. Runoff from precipitation falling directly over the waste footprint will be the only stormwater source with potential to contact exposed waste materials and will be directed away from the active face by downstream filling patterns and allowed to percolate into the leachate collection system. 6.2.2 Stormwater Permit Pawnee will apply for authorization to discharge under the Colorado Discharge Permit System (CDPS) General Permit COR900000, Stormwater Discharges Associated with Non -Extractive Industrial Activity" (general permit). To comply with the conditions of the general permit, Pawnee will develop and implement a Stormwater Management Plan (SWMP) prepared in accordance with the requirements listed in the terms of the general permit. Coverage under this General Permit will authorize the Facility to discharge stormwater, provided the Facility maintains compliance with the conditions of the General Permit, including sampling of discharge points (called outfalls) and sheet flow runoff, and reporting of the results to the CDPHE Water Quality Division. No defined stormwater discharge points (outfalls) currently exist within or along the boundary of the proposed USR, and none will be created as a result of Facility development. One outfall, at the stormwater pond outlet, will be created as a result of Facility development. The SWMP will focus management attention on sources of potential stormwater pollution, and aim to eliminate or minimize the risk of stormwater discharge associated with these sources. A copy of the CDPS Permit Application and SWMP will be maintained on site and includes water sampling to ensure conformance with discharge standards. Adherence to the monitoring requirements and provisions of the SWMP will be maintained through use GOLDER 17 July 20, 2020 1407882B Revision 5 of best management practices. employee training. inspections. and recordkeeping. As indicated in Section 3.4 of this Operations Plan, appropriate employees involved in the operation of the Facility will receive site -specific stormwater control training at the outset of operations and/or upon hiring, and with annual refreshers thereafter Stormwater management training will cover inspection and maintenance requirements, as well as sampling requirements associated with the General Permit. 6.2.3 Inspections and Maintenance The Facility will maintain stormwater controls in accordance with the Faciltiy EDOP. Routine maintenance requirements are found in the SWMP. The site manager will be responsible for ensuring that these controls are maintained in good repair in accordance with the BMPs identified in the SWMP in order to maximize their effectiveness. Irspections during the active life of the Landfill will be performed at least quarterly and after significant precipitation events, as per the checklist provided in the table below, and will be documented on the appropriate inspection form (see example form in Appendix C-1). Significant repairs (i.e.. beyond routine cleanout of sediment) from major storm damage will need to be certified in the form of a construction report prepared by a professional engineer (PE) licensed by the State of Colorado. Table C-2: Surface Water Management Controls Inspection Checklist Item/Reference valuation Criteria Corrective Action Inspections Following Storm Sicn Events Performed ficant Inspections within > 1.0 inch. 72 hours performed of the on end all of structures a rain event including Re needed. -address 3rd in party training refresher sessions, course if Stormwater Pond Detention Maintain sediment embankment of damage. g minimum accumulation. and freeboard. outlet Check structures Track pond for signs Clean accumulation deep, flow Evaluate out and/or from pond the and is is outlet correct if excessively sediment more standpipe. BMPs than 18 obstructing as inches needed. Ditches/Berms Ditches and of significant in are good relatively functioning erosion free order. on of berms litter No or evidence or ditches. debris Repair Provide energy ditches dissipation additional and stabilization where berms appropriate. as needed. or Silt Bales/Wattles Fence/Straw No straw beyond breaches wattles; these in silt no erosion sediment fence, controls. straw observed bales, or inches Repair Remove breaches deep. sediment in deposits erosion controls. if ≥ 6 Rock Dams/Baffles Sediment Check Traps and Maintain sediment performance downstream. (restore is observed and and/or if sediment to clean be out), hindering is found if inches Remove observed within sediment downstream. if accumulated structure or ≥ 6 control Vegetation Vegetation place applicable). (including and erosion stockpiles control where blankets in Re -vegetate as needed. GOLDEF 18 July 20, 2020 1407882B Revision 5 6.3 Groundwater Monitoring (Regulation 2.2) Groundwater monitoring will be performed at the Facility during the active life and will continue during the post -closure period. as described in the Environmental Monitoring Plan (Appendix E). Locations of the monitoring wells are shown in Drawings 2 through 5. 6.4 Air Monitoring (Regulation 2.1.1) Pawnee will submit an Air Pollutant Emission Notice (APEN) and comply with all air permitting requirements of the CDPHE Air Pollution Control Division. and Air Quality Control Commission regulations. Air permitting is addressed separately from this EDOP. 6.5 Explosive Gas Monitoring (Regulation 2.3) The waste accepted by the Landfill will not contain putrescible waste or organic material in quantities capable of generating explosive gases (methane) in concentrations requiring measurement and control. Therefore, explosive gas monitoring will not be required or performed at the Facility. COVER MATERIAL [REGULATIONS 2.1.10, 3.3.2(G), 3.3.4, AND 3.3.5] Sufficient amounts of adequate cover will be readily available for use throughout the Landfill operating life to minimize nuisance conditions, prevent ponding, and complete site closure. Cover soil will be obtained from the excavation of Landfill cells and either transported directly to the waste fill area or stockpiled on site as needed. Excavated soils will be segregated into separate stockpiles for unclassified soils (i.e., general fill) and topsoil; see Section 7.4 of this Operations Plan for additional description of stockpiling activities. All on -site soils are suitable for use as daily or intermediate cover. Daily Cover As allowed under the provisions of Section 3.3.4(C) of the Regulations, non-MSWLFs may propose alternate approaches to daily cover. Due to the nature of the waste, daily cover will not typically be needed to control disease vectors, fires. odors, blowing litter, and scavenging. Therefore, daily cover will be placed on all wastes at the Landfill to meet CDPHE requirements until Pawnee may apply for an alternate approach to the applicable regulatory agencies. Daily cover will be applied at a minimum thickness of six inches over each four- to six-foot lift of TENORM wastes. To the extent practical. exploration waste will be placed over production waste to help shield the operators (from TENORM) during daily operations and reduce the need for application of daily cover soil material. Any waste material accepted at the Landfill that contains significant petroleum constituents, is found to emit strong odors, or has other characteristics that make it unsuitable to remain exposed, will be covered the same day with additional waste material considered to be suitable as alternative daily cover (as demonstrated through a trial period of use and approved by CDPHE) or daily cover soil material. Certain wastes will require special handling, such as those identified in Section 2.5 of the WAP. Such wastes will be covered as soon as practical with daily cover soils or other suitable alternative daily cover materials as defined above (e.g., drill cuttings) to minimize their potential impact to human health and the environment. Alternative daily cover materials and/or cover soil may also be used to improve trafficability of haul routes and unloading areas over previously -placed wastes. Dust generation is expected to be minimal due to the consistency of the wastes received, and will be controlled by other means to the extent necessary (see Section 6.1.6): dust control is not expected to be improved by the application of daily cover soil. ' GOLDER 19 July 20. 2020 1407882B Revision 5 7.2 Intermediate Cover Twelve inches of intermediate cover soil will be placed over areas that will not receive additional waste for a period greater than 30 days. Intermediate cover will also be placed over disposal areas that have reached final waste grades. The intermediate cover shall consist of unclassified on -site soils. Intermediate cover will be graded to provide stormwater drainage away from the working face to avoid contact with waste. Intermediate -covered areas that are not anticipated to be receive additional wastes or final cover within 180 days will be seeded in the spring or fall order to establish vegetation. Areas that have been seeded will be routinely inspected to observe and document the effectiveness of revegetation activities. Prior to further waste disposal within intermediate -covered areas. the cover soils may be stripped and reclaimed (stockpiled) for future use. 7.3 Final Cover The final cover system will be constructed after the waste reaches the final design elevations as shown in the Final Cover Plan (Drawing 4). Final cover installation will be performed in accordance with the Closure and Post -closure Flan (Appendix F) and the Construction Quality Assurance (CQA) Plan (Appendix G). The Closure and Post -closure Plan describes the final cover system, the phased placement of final cover.. and the largest area (acres) allowed to be open (i.e., not certified closed) at any time during the active life of the Landfill as per the financial assurance criteria for closure. 7.4 Stockpiling, Borrow Activities, and Topsoil Handling Stockpiling wil typically be focused in the southern portion of the USR permit area. Stockpile(s) may temporarily overlap with the ultimate footprint of the Landfill, but will be depleted for use in Landfill construction or cover material by the time those cells or areas are developed. Soil stockpiles that are not anticipated to be disturbed for more than one year will be seeded in order to establish vegetation. Stockpile slopes shall be no steeper than 3H:1V and shall be revegetated after construction if the stockpile will remain in place for more than one year. All stockpiles sha I utilize suitable erosion and sediment control measure(s) (BMPs) as per the SWMP. Borrow areas may also be developed in the southern portion of the USR permit area, depending on soil cover needs. Borrow areas will be excavated and maintained so as not to create nuisance conditions. Topsoil will be stripped and stockpiled on the Facility property inside the USR boundary prior to phase development. Excess topsoil will be stockpiled in a location that is outside of future cell limits. When placed for final closure/reclamation, topsoil will not be compacted. 8.0 NUISANCE CONTROL [REGULATIONS 2.1.3 AND 3.3.2(1)] Many potential nuisance conditions typically associated with facilities that accept putrescible solid waste will be precluded from the Pawnee Waste E&P Landfill due to the nature of the waste types to be accepted. Accepted E&P wastes will primarily be earthen materials. sediments. and sludges from drilling operations, and other wastes of similar textLre and composition. 8.1 Odor, Noise, and Vector Control 8.1.1 Odors Off -site odors are not expected to be significant given the concentrations of volatile organic compounds and other constituents typically present in the types of waste materials to be accepted and the prevailing wind direction. Any GOLDER 20 July 20. 2020 1407882B Revision 5 potential odors produced by incoming waste should dissipate to unnoticeable levels within a short distance from the active disposal area. The waste disposal footprint will be set back from the property line by at least 200 feet. Any leachate application (applied in accordance with the requirements of Section 6.1.6 of this Operations Plan) shall be closely monitored for nuisance conditions including odors. If needed. additional measures may be implemented to mitigate odors, such as the application of cover soil or mulch (e.g., wood chips). 8.1.2 Noise Equipment noise will be controlled by requiring that on -site equipment be properly maintained and operated in a manner consistent with manufacturers' recommendations. If necessary to prevent objectionable noise levels from reaching off -site receptors, heavy equipment may be equipped with discriminating backup alarms (also referred to as proximity alarms) that employ alternative techniques such as radar or white noise to limit nuisance noise. 8.1.3 Vectors Disease and nuisance vectors such as flies and mosquitoes are not anticipated to be a concern due to the nature of the waste streams accepted and the measures to be taken to avoid standing water within the Landfill, which will deter insect breeding. If vectors do become a significant problem, remedial measures will be implemented. The initial response may include leveling or grading of uneven areas of the active portion of the Landfill to mitigate shallow depressions that may develop. To limit potential mosquito breeding in the leachate storage tank area. stormwater will be removed from inside the secondary containment basin within three days of each precipitation event that results in significant stormwater accumulation. Pawnee may also contract with a professional mosquito control company to implement a mosquito management program. Any liquid that collects within the secondary containment basin due to spillage or leakage from the tank(s) would be pumped back into one of the storage tanks. Clean stormwater collecting within the secondary containment basin will be released following inspection, as described in Section 6.1.4 of this Operations Plan. 8.2 Bird and Wildlife Control Significant bird populations are not expected in the Landfill area due to the absence of food sources, but if birds do become a persistent nuisance, they will be discouraged by use of proven humane bird control measures, which may include, but are not limited to: noisemaker (pyrotechnic) deterrents ("poppers," "screamers," "bangers," or cannons); visual scare techniques (birdlines, reflective tape. balloons, kites, owl decoys, etc.); distress calls; or other non -lethal methods. Netting. fencing, or other physical deterrents may also be installed if necessary to prevent birds or other wildlife from entering active Landfill areas. 8.3 Dust Control Access roads and certain other operational areas (e.g., dry excavation areas, inactive areas of the Landfill. or stockpiles) will be wetted periodically with water to control fugitive dust resulting from wind, vehicular traffic, and/or operational equipment. Additional measures implemented to minimize dust will be gravel -surfacing of access roads and parking areas, and seeding of buffer zones and inactive areas inside the permitted Facility (e.g., long-term stockpiles and borrow areas, stormwater channels/berms, intermediate -covered areas of the Landfill). Leachate may be applied to provide dust control within the active portion of the lined Landfill area only. Dust control measures will be initiated whenever it is judged necessary by Facility personnel to ensure compliance with air permit requirements (addressed separately with the Air Pollution Control Division of CDPHE) GOLDER 21 July 20, 2020 1407882B Revision 5 8.4 Fire Prevention [Regulations 2.1.9 and 3.3.2(J)] Burning of wastes will not be allowed at the Facility. The perimeter of the Landfill will be unobstructed to provide an access lane for fire -fighting. Portable fire extinguishers will be located in each Facility building or structure, and o n each vehicle and piece of heavy equipment. Procedures to be followed in the event of a fire or explosion are provided in the Emergency Response Plan. Section 10.0 of this Operations Plan, and will also be detailed in the Emergency Action Plan (EAP) to be prepared and maintained in accordance with Weld County requirements. 8.5 Litter Control [Regulations 2.1.7, 21.11, and 3.3.2(K)] The waste types to be accepted at the Landfill will typically be soil or materials of similar consistency and should n ot create any windblown litter; therefore, no litter screens or litter fencing will be required. Nonetheless. Pawnee staff will routinely monitor the Facility and neighboring properties for windblown litter, and will collect litter and debris as needed to ensure the Facility is kept neat and free from unsightly accumulation of such materials. This will include all areas and fences within the USR permit boundary as well as areas and fence -lines off site if n ecessary (with permission from adjacent landowners). Litter collection and removal activities will be documented in the Daily Landfill Inspection Form provided in Appendix C-1 or a similar form. Collected litter and debris will be placed in an appropriate storage container for disposal at a permitted off -site facility. Municipal waste (including waste generated at the scale house/office, maintenance building, and employee break room and changing areas, excepting personal protective equipment [PPE] worn by operators) may not be disposed of on site. 9.0 SAFETY STANDARDS AND TRAINING Fencing the area and maintaining a single entrance with a locking gate, as described above. will control u nauthorized access to the Facility. Employees will be provided appropriate PPE, such as hard hats, goggles, and hearing protection, and will be instructed in their proper care and use. Fire extinguishers will be placed in easily accessible locations, and personnel will be trained in their appropriate use. All Facility personnel will receive training regarcing proper procedures in the event of a fire, explosion, tornado or other natural disaster, spill. serious injury, or other emergency. Landfill personnel will be equipped with radios or cell phones to provide communication across the facility. Standard safety precautions will be observed during equipment operation and maintenance. First aid kits will be maintained on site in the scale house and maintenance building. An EAP, listing e mergency contact numbers for the ambulance, hospital, fire department, police, and hazardous material response, along with evacuation or sheltering procedures, will be prepared in accordance with Weld County requirements. The EAP will be posted in the scale house and at the maintenance building. The EAP will be reviewed regularly and updated as necessary with current information. Pawnee is committed to operational competence by assuring that personnel responsible for the Facility have a basic level of training to operate the site safely and in compliance with applicable regulations. The Worker Health & Safety Plan Outline provided in Appendix J lists the site -specific health and safety topics to be addressed for the o perators at the Facility, including those for handling and inspecting various types of E&P wastes. All Pawnee e mployees will be trained in general safety procedures and oriented to company operating policies prior to beginning work. This will typically include OSHA 10 -hour Training, H2S Training, PPE requirements. and other specific training as appropriate for the job description. In addition, employees will be provided with ongoing and in- field safety training in accordance with Pawnee's Safety Program. Personnel training shall be documented and the records maintained in the Operating Record at the Facility office (scale house) for regulatory agency review u pon request. GOLDER 22 July 20. 2020 1407882B Revision 5 Operating personnel will not be allowed to operate or oversee the Landfill without the appropriate training. Prior to waste acceptance, managerial -level and lead operations personnel will be provided with a copy of the EDOP and Weld County USR permit (and any relevant correspondence, modifications, revisions, addenda. or conditions thereto) and will receive site -specific training in the following topics: Applicable state laws, rules, and guidance documents Facility engineering drawings Waste acceptance procedures Inspection procedures Safety procedures Stormwater Management Plan Leachate management Permit conditions Operations Plan Radioactive material, including radioactive tracer materials Emergency/contingency response and EAP Erosion controls Site maintenance expectations Other. as may be needed All new employees and contractors working in active waste areas, with responsibility for leachate handling, stormwater management, or waste review and acceptance, will also receive quarterly training on these topics for the first year, and refresher training a minimum of semi-annually thereafter. More frequent training will be provided as needed if warranted based on observed performance deficiencies, operational errors, or compliance issues. 10.0 EMERGENCY RESPONSE PLAN This section describes the procedures to be followed in the event of an emergency. As defined in the Regulations, "emergency" means an "unexpected situation or sudden occurrence of a serious and urgent nature that demands immediate action and that constitutes a threat to life or health, or that may cause major damage to property." Prompt response in the event of an emergency can mitigate potentially harmful effects to human health and the environment. Operators at the Facility will be required to maintain safe operating conditions as well as protect public health and the environment, and will receive appropriate education in order to effectively handle emergency situations. The following steps would be followed in response to an emergency situation: i GOLDER 23 July 20. 2020 1407882B Revision 5 10.1 General Emergency Response The site manager (or designee) will be the coordinator of all initial response activities, including, but not limited to, the following actions in accordance with Pawnee procedures: Assess the conditions/extent of the emergency, considering the actual or potential impacts to human life, public health, and facility operations Direct employees to take appropriate actions and/or report to assigned muster points Call appropriate responders listed on the EAP posted throughout the Facility Cordon off the area of emergency and limit access to all except trained Pawnee personnel and emergency response crews To the extent practical and safe, take measures to limit the scope of the emergency Administer first aid (if needed) Use on-si:e emergency equipment, including communications devices and other materials/means as appropriate Notify CDPHE and Weld County as required Coordinate on -site activities as needed to facilitate cooperation between site personnel and emergency responders Implement corrective actions/measures (as discussed with CDPHE and Weld County) to restore the Facility to normal operation Ensure the event is properly reported, evaluated, documented, and further action plans, if any, are properly implemented Modify the inspection requirements, maintenance procedures, and/or emergency response/contingency plan as appropriate 10.2 Hot Load, Fire, or Explosion [Regulation 3.3.2(J)] In the event a load of incoming waste appears hot or is smoldering, the transporter will be directed to an area of the cell that is inactive. The designated area shall have at least four feet of cover material and/or waste over the liner in order to prevent heat damage to the liner system. In the unlikely event of a fire occurring at the Facility, Pawnee will immediately suspend Landfill operations and enact appropriate emergency response procedures to ensure employee safety. Pawnee personnel will manage the fire using on -site materials and equipment if possible, and may use soil, water, and/or other suitable means (e.g., fire extinguishers, water truck, heavy equipment applying cover soil) to extinguish or control the fire if it is deemed safe and appropriate to do so based on the judgment of trained Facility personnel. For a potential fire in the maintenance building or scale house, all personnel will follow posted evacuation procedures; only properly trained employee(s) using the appropriately rated fire extinguisher will attempt to put out the fire, and only if it appears manageable by such tactics. The Pawnee Fire Protection District will be called in the event of a larger fire, or one that is difficult to control using resources available to Facility personnel. Landfill personnel will be provided with a communication system with which to alert the fire department. CDPHE will also be contacted in the event of a significant fire. ' GOLDER 24 July 20, 2020 1407882B Revision 5 10.3 Leaks/Spills/Releases In the event of a regulatory defined reportable leak, spill, or release, the following actions must be taken: Immediately contact the CDPHE Hazardous Materials and Waste Management Division (in accordance with Guidance Document "Reporting Environmental Releases in Colorado" [CDPHE, January 2009]) and Weld County as appropriate. Advise CDPHE and Weld County of the type. quantity and location of the release, and of the response, containment.. and cleanup actions that have been taken or are proposed to be taken Take immediate measures to stop the release and to contain the release or spill by repairing or building up any breach or by installing dikes or diversions. Develop a plan for CDPHE review and approval to sample nearby watercourses or drainages that may contain any contaminated water or oily materials. Implement clean-up activities in accordance with CDPHE requirements. As soon as practical following the incident, submit a complete written report to CDPHE and Weld County describing the reportable release and documenting all corrective measures taken and contingency procedures enacted to control off -site release or migration of impacted material, along with the steps taken to prevent a recurrence. Place a copy of the report in the Operating Record. Review and update the Emergency Response and/or Operations Plans as needed. 10.4 Utility or Pipeline Contact/Breach Two underground pipelines (one water line and one natural gas pipeline) and one communications cable cross the Facility property (see Drawing 2) via recorded easements. These lines are clearly identified in the field. The Facility layout is designed to avoid the need for mobile equipment or vehicles to cross these lines. It is the Site Manager's responsibility to ensure all personnel, contractors, and other site visitors are properly trained in safe practices in and around the utilities and pipeline. If a utility or pipeline is inadvertently contacted or breached, emergency response will be called and the utility or pipeline owner notified immediately for corrective action. The incident will be noted in the Incident Log (example form provided in Appendix D-1). 11.0 CONTINGENCY PLAN 11,1 Substance Release (Regulation 2.1.18) If Pawnee observes, or is made aware of, a condition or event that is likely to cause a release or has caused a release of a substance containing a parameter identified in the Facility's detection monitoring program (per the approved Environmental Monitoring Plan) and that such condition or event is likely to cause a statistically significant increase over background, Pawnee shall provide written notification to CDPHE and Weld County within 10 days. 11.2 Contamination of Surface Water or Groundwater [Regulation 3.3.2(L)] This section presents conceptual mitigation measures that would be implemented if impacts to local surface water or groundwater quality are identified and confirmed based on the environmental monitoring program. GOLDER 25 July 20. 2020 1407882B Revision 5 11.2.1 Groundwater Impacts The Facility wi I be operating under a groundwater monitoring program approved by the CDPHE. To evaluate groundwater impacts, a statistical analysis of groundwater monitoring results will be performed in accordance with the requirements of 6 CCR 1007-2, Section 2.2.1. If the results indicate that the Landfill is adversely impacting groundwater quality, the measures identified in the Environmental Monitoring Plan (Appendix E) will be implemented as appropriate, including possible assessment monitoring. 11.2.2 Surface Water Impacts Surface water monitoring results will be evaluated to assess whether the Facility is impacting surface water quality. The Stormwater Management Plan will provide specifics regarding the surface water monitoring program and the controls proposed to prevent and mitigate potential spills or releases. In general, responses to any surface water impact will depend on the impact parameters and the pathway by which the impacts are reaching surface water. The following measures will be implemented in the event of an unpermitted release, as appropriate: 1) The CDPHE Emergency Spill Line will be notified in the event of a release to surface waters. 2) The source pathway of the surface water impacts will be identified through visual inspection. 3) The source of the impacts will be isolated from the perimeter drainage system or the local surface water drainage through installation of earthen berms, diversion ditches, and/or catchment basins. 4) The diverted impacted surface water will be collected and treated or disposed in a manner approved by the CDPHE 5) An approved remediation plan describing the nature and extent of the problem and the proposed remedy will be placed in the Operating Record. CDPHE will be notified when the remediation plan has been implemented. 11.3 Nuisance Conditions beyond Site Boundary [Regulation 3.3.2(L)] 11.3.1 Mud & Vehicle Tracking Pawnee will implement a system to minimize mud from being visibly tracked onto paved County roads. When weather condi:ions warrant, inspections will be made twice daily. Excessive mud will be removed from the roads, and the mater al disposed in the active Landfill cell. Double cattle guards will be installed on WCR 118 at the intersection with WCR 95 as a means of preventing mud tracking onto public roadways. 11.3.2 Dust In the event of excessive dust within the Facility or crossing the Facility boundary, including entrance areas and haul roads, the water truck will be used to apply fresh water (from the on -site supply well) to mitigate the dust. Other approved dust suppressants may be applied. 11.3.3 Debris Site personne will pick up litter and debris regularly and place in an appropriate storage container for disposal off site. Municipa'h waste or litter may not be disposed of on site. 3 GOLDER 26 July 20. 2020 1407882B Revision 5 11.3.4 Run-on or Runoff Control Failure In the event of run-on diversion failure, the structure shall be immediately repaired and a record of the corrective action and/or construction report placed in the Operating Record pursuant to the requirements of Section 6.2.3 of this Operating Plan. 12.0 FACILITY INSPECTIONS Facility inspections will be performed at the frequencies listed below, and the results documented in the appropriate forms entitled Daily Landfill Inspection Form, Weekly Landfill Inspection Form, and Quarterly/ Post -runoff Event Landfill Inspection Form. The inspection forms will be kept on file in the Landfill Operating Record located in the scale house, which will be available for inspection upon request. Non -conforming inspection items shall be brought into conformance in a timely manner and the repairs documented. The following systems shall be routinely inspected: Table C-3: Facility Inspections Inspection Item Frequency Landfill equipment Daily Weigh scale Quarterly Mud and vehicle tracking Up warrant to 2x daily when weather conditions Litter/debris Weekly Waste disposal Continuous observation Random load inspections 1% or 1 per week Leachate fittings. collection level transducers, system sump pumps risers, cleanout risers, Weekly Leachate tanks/storage area Weekly storm and events within 3 days after significant Stormwater controls (temporary and permanent) Quarterly and after significant storm events Groundwater and change monitoring in casing elevation) wells (casing condition, cap, locks, Quarterly Revegetated/seeded areas Weekly and after significant storm events Samples of the Daily Landfill Inspection Form, Weekly Landfill Inspection Form, and Quarterly/Post-Runoff Event Landfill Inspection Form are provided in Appendix C-1. ' GOLDER 27 July 20. 2020 1407882B Revision 5 13.0 RECORDKEEPING (REGULATIONS 2.4 AND 3.4) The Operating Record will contain documentation associated with applicable portions of Sections 2.4 and 3.4 of the Regulations, including the following: Location -estriction demonstrations required by Section 3.1 of the Regulations Inspection records Employee training procedures and documentation Design documentation for controlling leachate Demonstrations, certifications, findings, data, or documents required by Subsection 2.2 of the Regulations relating to groundwater monitoring Closure and post -closure care plans and any associated monitoring, testing, or analytical data, including closure and post -closure documentation as per the Closure and Post -closure Plan presented in Appendix F of this EDOP Cost estimates and financial assurance documentation required by Subsection 1.8 of the Regulations Information demonstrating compliance with waivers as required by Section 1.5 of the Regulations Pawnee will notify CDPHE and Weld County when the documents from the above list have been placed or added to the Operating Record. Incoming waste records. including the volumes, type, date of disposal, disposal location, and source of waste Copy of tie approved EDOP, Weld County USR permit, and any associated or subsequent correspondence, modificat ons, revisions, addenda, or conditions thereto Record of any problems causing suspension of operations, including, but not limited to, fire or equipment failure Water quality monitoring results Annual reports Record of third party requests for disposal of prohibited wastes Documentation of any prohibited or unacceptable wastes received and the actions taken Log of waste cover placement activities, including dates the material applied and areas covered Log of litter collection activities specifying the dates and areas of litter collection Log of quantity of leachate pumped from each sump, date and location of application and/or disposal events Construction as -built details (i.e., CQA reports, specifications, and record drawings) Variations from approved operations procedures, if any All informatior contained in the Operating Record will be furnished upon request or be made available at all reasonable times for inspection CDPHE and Weld County. The Operating Record will either be maintained at the GOLDER 28 July 20. 2020 1407882B Revision 5 Landfill office (scale house) or an approved alternative location. Operations and maintenance manuals for pumps, equipment, scales, radiation detection devices, and any other site equipment will also be maintained at the either the scale house or maintenance building. Golder and the G logo are trademarks of Golder Associates Corporation https //golderassoc ates sharepoint com/sites/123380/project files/6 deliverables/1407882b/0400/0410 edop rev7/minor changes made 20jul20 - use for rev8/1407882b app c pawnee waste If ops plan rev5 20jul20 docx GOLDER 29 DAILY OPERATIONS LOG: PAWNEE WASTE E&P LANDFILL DATE TEMP BY WIND CHECKED PRECIP GENERAL SAFETY INFORMATION (Y/N) COMMENTS All activities & hours recorded Any safety incidents All monitors calibrated Safety equipment/matenals used Housekeeping in good order OPERATIONS & MAINTENANCE (Y/N) COMMENTS Pre -post heavy equipment checks Scale & camera system working Waste acceptance discrepancies Rejected loads , TOTAL LOADS RECEIVED RANDOM SAMPLING (Y/N) TODAY Bi-WEEKLY Exploration Waste Loads Production Waste Loads Mixed/Non-Exempt Loads INSPECTIONS (Y/N) COMMENTS Roadway conditions Fence/security Stormwater controls Cover in place Evidence of erosion Cell grid in place Leachate levels Spills/releases Other VISITORS/OTHER ISSUES WEEKLY INSPECTION LOG Pawnee Waste Exploration and Production Landfill Item Acceptable Y/N I I Attention Requires Y/N IComments A. General Site Conditions 1. CR 118 2. On -site roads 3. Access ,fence, gate) 4. Signs 5. Scales 6. Housekeeping 7. Heavy equipment/trucks 8. Other equipment (lights, generator) 9. Storage areas 10. Safety equipment/inventory 11. Fire lanes clear 12. Other B. Active Fill Area 1. Fill access 2. Working face 3. Waste compaction 4. Daily cover 5. Intermediate cover 6. Cell Liner 7. Fill elevations/grid 8. Surface water control(s) 9. Solidification area/unit 10. Other C. Closed Areas 1. Settlement 2. Erosion Control(s) _ 3. Vegetation 4. Stockpiles 5. Cover 6. Other D. Leachate Management Controls 1. Leachate level (sumps; 2. Leachate pumps 3. Leachate risers/fittings 4. Leachate tank storage 5. Other E. Stormwater Management Controls 1. Post -storm event inspection(s) 2. Landfill detention pond 3. Other catchment areas 4. Ditches & berms 5. Silt fence & straw bales 6. Culverts 7. Vegetation/Erosion Protection 8. Other 1 WEEKLY INSPECTION LOG Pawnee Waste Exploration and Production Landfill Item Acceptable Y/N I Requires Attention Y/N Comments F. Other Environmental Management & Controls 1. Monitoring wells 2. Spill release equipment 3. Recordkeeping 4. Weather station 5. Air monitors 6. Survey markers 7. Other G. Waste Acceptance Procedures 1. Pre -Screening 2. Waste Approval & Confirmation 3. Waste Grid on Docket 4. Gate Screening 5. Random Sampling 6. Waste Discrepancy;s; 7. Waste Rejection(s) 8. Equipment Calibration 9. Waste Records 10. Other H. Miscellaneous 1. 2. 3. 2 PAWNEE WASTE E&P LANDFILL LEACHATE LOG MONTH YR SUMP LEVELS (FT) GALS PUMPED GALS PUMPED TO TOTAL GALLONS ACCEPTABLE? 1 2 3 4 1 2 3 4 ON -SITE TANKS OFF -SITE WELL STORED ON- SITE SOLIDIFIED DISPOSED OFF -SITE YIN ACTION TAKEN 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 DAILY AVERAGE MONTHLY TOTALS i.,,.'•'",i'• .$°re'fkliAt1' 't a _ir' +W`� .1'rta 414 e 't. rAgii. k1 NOTE IF ALARM IS NOT TRIGGERED INDICATE LEVEL AS LESS THAN 'X IF LEVELS ARE GREATER THAN THE ALLOWABLE LEVELS ACTION MUST BE TAKEN' IF THERE ARE MULTIPLE OFF -SITE DISPOSAL WELLS ADD COLUMNS TO INDICATE WHERE LEACHATE DELIVERED SPILL,RECORDKEEPING FORM (Page 1 of 1) {r- h v -Yes No - Comments - _ 1 Were any spills reported or observed? 2 Did any of the spilled material reach surface water ponds, or leave the site? 3 Was the spilled material considered a hazardous substance? 4 Did the spill volume exceed the reportable quantity as per CDPHE Guidance Document "Reporting Environmental Releases in Colorado"? 5 Any unusual events, injuries, exposures? 6 Did any govemmental agencies, consultants, or non -landfill personnel participate, advise, or oversee the clean-up? Are there any agency notification numbers or report numbers issued for the release'? r Comments - 8 What was the estimated date, time, and duration of release? 9 What was the reported or observed source and volume of the release? 10 What notifications (whom, when) were made? 11 What were the cleanup procedures employed? 12 What employees observed the spill, reported the spill, and participated in the clean-up? 13 What equipment/subcontractor was used during the clean-up operations? 14 What was the final disposition of the spilled material? SPILL REPORTING The following actions shall be performed if there is a reportable spill • Immediately take appropriate action to stop and contain the release, • Immediately notify the CDPHE of the type, quantity and location of the release, and of the response, containment and cleanup actions which have been taken or are proposed to be taken Call the CDPHE Colorado Environmental Release and Incident Reporting Line at 1-877-518-5608 (available 24 hours a day, 7 days a week) This number should ONLY be used for spills and emergencies, • If the spill is regarding radioactive material, call the CDPHE Radiation Incident Reporting Line at (303) 877-9757 (available 24 hours a day, 7 days a week), Immediately proceed to correct the cause of the release, and Submit a complete written report to CDPHE (and USEPA if necessary) descnbing the reportable release and steps taken to prevent a recurrence within the time frame specified in the CDPHE Guidance Document "Reporting Environmental Releases in Colorado" (CDPHE, January 2009) Please note that non -reportable spill events are still required to be addressed immediately by containing, removing, and disposing of the released product according to CDPHE regulations - - - _ = QUARTERLY/POST-RUNOFF EVENT LANDFILL iNSPECTIOW FORM (Page 1 of 2) A Site Information B Inspection Information. , Facility Name. Pawnee Waste E&P Landfill Inspector Name Landfill Type E&P Waste Date - If post -runoff event inspection, size of storm event (rainfall depth)* inch(es) Weather " ANSPECTION'ITEMS - - , C Stormwater Management System °, Yes(E) , No - - Comments(E) `_ ; - C 1 Is there excessive erosion or signs of overtopping observed in the stormwater system or damage to flow dissipation structures? C 2 Are any excessive settlement or depressions observed in the stormwater system? C 3 Does the Stormwater Catchment Basin downgradient of the entrance facility show signs of contamination? C 4 Are any significant areas of sedimentation observed? C 5 Had stormwater accumulated in the leachate storage tank containment basin? If yes, was it inspected and documented prior to discharge to the environment? C 6 Were any pumps used to convey stormwater on or across the site? If yes, where was the stormwater transported to, where was it transported from, and how much was transported? C Is there evidence of any improper discharge (e g , non-stormwater such as contact water)? C 8 Were any on -site roads washed out? D Cover System - - ,,t Yew) No -- Comments(E) _ _ ID 1 Do the landfill or perimeter berm sideslopes show signs of vegetation damage or erosion? D 2 Is there excessive erosion of any cover systems? D 3 Is there excessive ponding or depressions observed on or around the cover systems? D 4 Are there any leachate seeps on the facility? D 5 Were any cover repairs made? If yes, state where (grid coord) and descnbe actions taken (if additional cover soil applied, list how much) List drainage features and cover areas evaluated during this inspection -QUARTERLY/POST-RUNOFF EVENT LANDFILL INSPECTION FORM,(Page 2 of 2), ; Comments - All blocks marked "Yes" ,r'eguire a mitten explanation -and a'corrective-action to be discussed below (attach additional sheets, d, necessary) AND any comments above, that`require additional explanation should be;discussed below = - APPENDIX D Waste Acceptance Plan k> GOLDER APPENDIX D Waste Acceptance Plan Pawnee Waste E&P Landfill Weld County, Colorado Prepared for: Pawnee Waste LLC 3003 E. Harmony Road. Suite 300 Fort Collins. Colorado 80528 Prepared by: Golder Associates Inc. 7245 W Alaska Drive, Suite 200, Lakewood. Colorado, USA 80226 +1 303 980-0540 1407882B Revision 6 October 30. 2019 October 30. 2019 1407882B Revision 6 Revision History This document has been revised as indicated below: Revision Number . Revision Date Description of Revision 0 July 23, 2015 Initial EDOP submittal 1 October 20, 2015 Clarification screening/response; of acceptable Clarification wastes; of Clarification random of waste radiation sampling 2 February 19, 2016 Revision E&P acceptance waste to hazardous acceptance criteria waste criteria; characteristics; Clarification of Clarification asbestos of and non-exempt PCB waste 3 April 22, 2016 Addition requirements: collected of from lead Additional accepted -210 and wastes polonium waste -210 acceptance testing requirements; and acceptance Data to be 4 July 3, 2017 Removal Clarification of restrictions on excluded on vehicle wastes types; Definition of bulk liquid; 5 August 2, 2019 Acceptance of tracer materials 6 October 30, 2019 Acceptance waste; Streamlining of industrial of waste wastes and profiling construction process/documentation and demolition (C&D) GOLDER 44> October 30, 2019 1407882B Revision 6 Table of Contents 1.0 INTRODUCTION 1 2.0 WASTE TYPES TO BE ACCEPTED 1 2.1 Exempt Exploration and Production Wastes 2 2.1.1 Exempt Exploration Waste 3 2.1.2 Exempt Production Waste 4 2.2 Non-exempt E&P Wastes and Other Oil and Gas Wastes 4 2.3 Publicly Owned Treatment Works (POTW) Water and Wastewater Residuals 5 2.4 Industrial Wastes 6 2.5 Construction and Demolition Waste 6 2.6 Wastes Requiring Solidification 6 2.7 Wastes Requiring Special Handling or Disposal Methods 6 2.7.1 Dusty Wastes ..7 2.7.2 Drummed Wastes 7 2.7.3 NORM/TENORM Wastes 7 2.7.4 Odorous Wastes 7 3.0 PROHIBITED WASTES 7 3.1 Liquid Wastes 7 3.2 Hazardous Waste 7 3.3 Municipal Solid Waste 7 3.4 Asbestos -containing Material 8 3.5 Polychlorinated Biphenyl Wastes 8 3.6 Radioactive Wastes 8 3.7 NORM/TENORM Waste Exceeding Established Thresholds 8 3.8 Unacceptable Wastes 9 4.0 WASTE SCREENING PROGRAM FOR PREVENTING DISPOSAL OF PROHIBITED OR UNACCEPTABLE WASTE (REGULATION 2.1.2) 9 4.1 Pre-screening and Generator Education 10 ' GOLDER ii October 30. 2019 1407882B Revision 6 4.2 Waste Profile Sheet 10 4.2.1 Waste Analyses and Information Required 11 4.2.2 Sampling Procedures 12 4.2.3 Asbestos and PCB Testing 12 4.3 Waste Stream Review and Approval 12 4.4 Waste Stream Retesting and Certification 13 4.5 Screening at the Landfill 13 4.5.1 Load Screening at Gate 13 4.5.1.1 Approved Waste Profile Number 13 4.5.1.2 Visual Screening 13 4.5.1.3 Gate Tests 14 4.5.1.4 Container Inspection 14 4.5.1.5 Weights 14 4.5.1.6 Radiation Detectors at Scale 14 4.5.1.7 Handheld Gamma Survey Meter 15 4.5.2 Random Load Inspections and Testing 16 4.5.2.1 Training and Equipment 16 4.5.2.2 Random Load Selection, Inspection, and Sampling Procedures 16 4.6 Waste Rejection 19 4.6.1 Management and Disposal of Unauthorized Wastes 20 4.6.2 Cause for Suspension from Use of Facility 20 4.7 Waste Acceptance Procedure Adjustments 21 5.0 CONTINGENCY PLAN FOR HANDLING UNAUTHORIZED WASTES [REGULATION 2.1.2(C)(4)] 21 5.1 Suspected Presence of Unauthorized Waste 21 5.2 Confirmed Discovery of Unauthorized Waste 22 5.3 Detection of Prohibited Wastes 23 5.4 Management and Disposal of Unacceptable Wastes 23 5.5 Documentation of Inspections and Incidents 23 GOLDER iii October 30. 2019 1407882B Revision 6 TABLES Table D-1: Exempt E&P Wastes 2 Table D-2: Random Load Inspection and Sampling Overview 17 Table D-3: Test Parameters and Allowable Levels for Non-exempt E&P Waste Attached Table D-4: Background Radioisotope Results Summary Attached APPENDICES APPENDIX D-1 Example Forms Waste Profile Sheet Load Inspection and Sampling Log and Waste Screening Checklist Incident Log APPENDIX D-2 Radiation Detection Response Procedures 4 GOLDER iv October 30, 2019 1407882B Revision 6 1.0 INTRODUCTION This Waste Acceptance Plan (WAP, also known as a waste characterization and disposal plan) has been developed for the Pawnee Waste E&P Landfill (Landfill or Facility) in Weld County, Colorado, to satisfy Section 2.1.2 of the CDPHE Regulations Pertaining to Solid Waste Sites and Facilities (6 CCR 1007-2. Part 1). The Landfill, which will be owned and operated by Pawnee Waste LLC (Pawnee), will consist of an approximate 74 - acre disposal area within a 240 -acre contiguous property (Site). The WAP outlines waste type restrictions, waste characterization and profiling procedures, waste evaluation personnel, waste exclusion procedures (including screening and random inspection methodologies). waste handling procedures, and associated documentation and reporting requirements to be implemented at the Facility. The handling and management of unacceptable wastes is described in the Contingency Plan for Handling Unauthorized Wastes, presented in Section 5.0 of this WAP. The WAP serves to inform state and local agencies regarding Pawnee's approach to waste characterization, acts as a vital tool to guide decision making on acceptable wastes and establishes a framework for waste exclusion and handling procedures to be followed by Facility personnel. The scope of the WAP encompasses requirements set forth in Section 2.1.2 of the Regulations, and, as such, addresses: The responsibility of the waste generator in the waste characterization process and in determining if the generator's waste is a hazardous waste pursuant to the Colorado Hazardous Waste Regulations, 6 CCR 1007-3, Part 261: The Facility's evaluation procedures, screening methods, and documentation practices regarding the generator's waste characterization determination; Random inspections of incoming loads and records of such inspections; Training of Facility personnel to recognize unacceptable wastes (see also Section 3.4 of the Operations Plan); Notifications required in the event that unacceptable wastes are discovered at the Facility (see Section 5.0 of this WAP); Identification of potential waste streams requiring specific waste handling and/or disposal methods (see Section 2.7 of this WAP); and A Contingency Plan outlining specific procedures to be followed in the event that unacceptable wastes are received at the Facility (see Section 5.0 of this WAP). Pawnee recognizes that this WAP, and the associated operational procedures based thereon, may require further refinement as generator information becomes more readily available and CDPHE regulations, policies, and guidelines are modified for management of naturally occurring radioactive material (NORM) and technologically enhanced naturally occurring radioactive material (TENORM). Thus, Pawnee proposes to perform periodic reviews and revisions of its waste receipt processes to be consistent with CDPHE policy, including the corresponding RESRAD model inputs as further defined in Section 4.7 — Waste Acceptance Procedure Adjustments. 2.0 WASTE TYPES TO BE ACCEPTED Pawnee Waste is a permitted solid waste disposal facility which is designated, designed, constructed and operated to accept non -hazardous solid waste with low levels of NORM and TENORM. These non -hazardous wastes can generally be categorized as oil and gas -related wastes (from exploration & production [E&P] and treatment > GOLDER 1 October 30. 2019 1407882B Revision 6 activities), municipal water and wastewater treatment residuals, other non-putrescible industrial waste streams, and construction and demolition (C&D) waste. 2.1 Exempt Exploration and Production Wastes RCRA-exempt oil and gas exploration and production (E&P) wastes are defined in 40 CFR 261.4 (b)(5) as "drilling fluids, produced waters, and other wastes associated with the exploration, development, or production of crude oil. natural gas or geothermal energy:' and published in the USEPA's Regulatory Determination for Oil and Gas and Geothermal Exploration. Development. and Production Wastes [FRL-3403-9], 53 FR 25447, Section II, Part D. These exempt wastes are also listed in the USEPAs publication entitled Exemption of Oil and Gas Exploration and Production Wastes from Federal Hazardous Waste Regulations dated October 2002 (USEPA Exemption Publication). Exempt exploration and production (E&P) wastes, as currently defined in 34-60-103(4.5) C.R.S., are "wastes that are generated during the drilling of and production from oil and gas wells or during primary field operations and that are exempt from regulation as hazardous wastes" under RCRA Subtitle C (40 CFR Parts 260 to 279). Exempt E&P waste streams (see below) from the oil and gas exploration and production industry are those that, based on the regulatory citations listed above. are exempt from requirements related to hazardous waste identification, sampling, handling, storage, and disposal. In order to be classified as RCRA-exempt, the E&P waste must have been generated from a material or process uniquely associated with the exploration, development, and production of crude oil or natural gas. An example of the modified list of waste streams is included below and is separated into exploration, production, and either — where -either" could be exploration or production depending upon the location and use of the equipment or material: Table D-1: Exempt E&P Wastes Exempt Exploration Wastes Exempt Production Wastes Production ither Exploration or Drill cuttings and muds Accumulated hydrocarbons, emulsion separators, and production from fluid materials solids, production impoundments treating sand, such vessels, as and Spent backwash filter the exempt itself residue filters, solids is waste not in filter it stream) media, (assuming hazardous is from and and an the Rigwash solids Solids including reclamation operations. from filter production cake and water from sites, oil Constituents flowback before disposed bottom it sediments) and is of removed injected (e.g., filters, or otherwise from water tank produced recycling Sediment bottoms activities, generated recycling and from including by exploration closed other tank wastes loop Gas and sweetening plant and dehydration backwash wastes: solids wastes filter Debris, stained crude oil soaked or media GOLDER 2 October 30, 2019 1407882B Revision 6 Exempt Exploration Wastes Exempt Production Wastes Exploration or . Either Production Pit generated and sludges drilling during and activities solids exploration Pipe gathering solids, deposits and to transportation scale, production hydrates, lines), removed pigging equipment hydrocarbon and from wastes other piping (from prior Mixtures and exempt of exempt production exploration wastes Proppant/sand (excluding flowback unused wastes product) and Hydrogen wastes production sulfide from geothermal abatement Crude generated drilling, (prior reclamation to oil and transportation contaminated during production facility) exploration, soils activities from a energy * The term "solidsas used in the above table refers to wastes that are not bulk liquids. and includes wastes that occur in a solid. semi -solid. or sludge form. and/or that may contain free liquids. Since the Landfill will not be permitted to dispose of wastes not passing the Paint Filter Test (USEPA Method 9095B), all wastes exhibiting apparent free liquids upon delivery to the Facility will either be rejected or will be processed at the on -site solidification unit, in accordance with all regulatory requirements. prior to being incorporated into the working face. The foregoing is a list of typical exempt E&P solid waste types/streams that may be accepted but is not all-inclusive. Variations or additions to the list will be evaluated on a case -by -case basis using the same criteria. If uncertainty exists regarding the acceptability of a particular waste. CDPHE will be contacted for guidance and/or approval, as appropriate. The mixture of an exempt waste with another exempt waste remains exempt. 2.1.1 Exempt Exploration Waste Exempt exploration waste will be accepted at the Landfill provided it meets all the following requirements: 1) The generator certifies that the material is RCRA-exempt (i.e., that it was generated from a material or a process `uniquely associated with the exploration. development, and production of crude oil and natural gas"); 2) The generator certifies that the RCRA-exempt waste is generated by activities associated with the exploration or development of an oil or gas well and does not include production wastes; 3) The material has successfully passed a Paint Filter Test (USEPA Method 9095B), either at the time of receipt at the Facility or upon treatment at the on -site solidification unit; and 4) The material does not emanate more than 50 microRoentgens per hour (pR/hr) when received at the Landfill (see Section 3.7, below). Exploration wastes typically don't contain large concentrations of NORM or TENORM; thus quantifying radionuclides will not be required. 9 GOLDER 3 October 30. 2019 1407882B Revision 6 Please see Waste Profile Sheet in Appendix D-1 for additional information regarding requirements for disposal at this Landfill, including Generator Information, Waste Characterization, Waste Analytical Requirements, Physical Description, Volume & Packaging, and Generator Certification, and Appendix I. 2.1.2 Exempt Production Waste Exempt production waste will be accepted at the Landfill provided it meets all of the following requirements: 1) The generator certifies that the material is RCRA-exempt (i.e., that it was generated from a material or a process "uniquely associated with the exploration. development. and production of crude oil and natural gas"); 2) The generator certifies that the RCRA-exempt waste is generated by activities associated with production wastes or contains a mixture of production, exploration, and development wastes; 3) The material has successfully passed a Paint Filter Test (USEPA Method 9095B), either at the time of receipt at the Facility or upon treatment at the on -site solidification unit; 4) The material does not contain radioactivity exceeding the threshold criteria established in this WAP based on the Radiation Risk Assessment (Appendix I) and CDPHE guidance: a. Combined radium 226 (Ra-226) and radium 228 (Ra-228): 50 picocuries per gram (pCi/g) above background; b. Natural uranium (U -Nat): 10 pCi/g above background; or c. Natural thorium (Th-232): 10 pCi/g above background. 5) The material does not emanate more than 50 pR/hr when received at the Landfill (see Section 3.7, below): 6) Natural gas wastes/residues that result from pipeline pigging operations associated with gathering lines will not contain radioactivity exceeding the threshold criteria of Lead -210 (Pb-210) at 10 pCi/g and Polonium -210 (Po -210) at 10 pCi/gm; and 7) The average concentrations of radioisotopes from E&P Waste are consistent with the RESRAD model assumptions (see Appendix I). Since production wastes can concentrate NORM or create TENORM, quantifying the radionuclide concentrations is necessary in addition to measuring emanation at the scale. as indicated above. Please see Waste Profile Sheet in Appendix D-1 for additional information regarding requirements for disposal at this Landfill, including Generator Information, Waste Characterization, Waste Analytical Requirements, Physical Description, Volume & Packaging, and Generator Certification, and Appendix I. 2.2 Non-exempt E&P Wastes and Other Oil and Gas Wastes Exempt E&P waste is defined as "waste materials intrinsically derived from primary field operations associated with the exploration. development, or production of crude oil. natural gas, or geothermal energy" that received an exemption from requirements related to hazardous waste identification, sampling. handling, and storage requirements. Oil and gas wastes are those that may result outside of the primary field operations, and include wastes generated as a result of spills during treatment and transport. Only non -hazardous non-exempt E&P wastes and other oil and gas wastes may be considered for acceptance by Pawnee. GOLDER 4 October 30. 2019 1407882B Revision 6 However, other waste streams generated by the oil and gas industry will only be accepted at the Landfill, provided the material satisfies the following requirements: 1) Is not a listed hazardous waste; 2) Is not a hazardous waste by characteristics for toxicity, ignitability, reactivity, or corrosivity (i.e., is not a waste generated from any process; source, or discarded products categorized under waste codes F, K, P or U per 6 CCR 1007-3 Part 261 (see Section 3.2 below); 3) Contains no free petroleum or other liquids and has successfully passed a Paint Filter Test (USEPA Method 9095B), either at the time of receipt at the Facility or upon treatment at the on -site solidification unit; The ignitability (flash point) is greater than 140°F and will not pose a chemical reaction hazard; 4) Is at or below the radioactivity threshold criteria established in this WAP based on the Radiation Risk Assessment (Appendix I) and CDPHE guidance: a. Combined Ra-226/Ra-228: 50 picocuries per gram (pCi/g) above background; b. U -Nat: 10 pCi/g above background; c. Th-232: 10 pCi/g above background; and d. Tracer material isotopes (Ir-192, Sc-46, and Sb-124): 1,000 pCi/g (total of all isotopes combined). 5) Does not emanate more than 50 pR/hr when received at the Landfill (see Section 3.7, below); 6) Does not contain greater than 1% asbestos by weight (see Section 3.4 below); and 7) Does not contain PCBs (see Section 3.5 below). 8) Is generated as a result of activities directly associated with exploration, development, production of crude oil or natural gas, and other oil and gas transport and treatment activities. For purposes of this WAP, personal protective equipment (PPE) generated in direct association with the acceptance and handling of NORM/TENORM waste and tracer material will be considered an exempt waste and may be disposed of in the Landfill without screening or testing. All wastes identified as non-exempt oil and gas wastes will be deemed acceptable only if they meet each and every criterion identified above. If uncertainty exists regarding the acceptability of a particular waste, the CDPHE will be contacted for guidance and/or approval, as appropriate. In no event will Pawnee accept any waste if they are listed hazardous wastes, more specifically if they are generated from any process, source, or discarded products categorized under waste codes F, K. P or U per 6 CCR 1007-3 Part 261, or if the waste exhibits hazardous waste characteristics. Please see Waste Profile Sheet in Appendix D-1 for additional information regarding requirements for disposal at the Landfill, including Generator Information, Waste Characterization, Analytical Requirements, Physical Description, Volume & Packaging, and Generator Certification, and Appendix I. 2.3 Publicly Owned Treatment Works (POTW) Water and Wastewater Residuals Non -hazardous solids from water and wastewater treatment will be considered acceptable for waste disposal at the facility provided they conform to state regulatory requirements for non -hazardous waste and established ,� GOLDER 5 October 30. 2019 1407882B Revision 6 NORM/TENORM standards. These waste streams include dissolved solids removal residues (sludges), suspended solids removal residues (sock or bag filters, captured solids), tank bottoms, and system scale. 2.4 Industrial Wastes The CDPHE defines industrial waste in 6 CCR 1007-2 Part 1 to mean all solid wastes, including mill tailings and mining wastes, resulting from the manufacture of products or goods by mechanical or chemical processes that are not a hazardous waste regulated under 6 CCR 1007- 3, the Colorado Hazardous Waste Regulations. Such waste may include, but is not limited to, construction and demolition debris, and waste resulting from the following manufacturing processes: electric power generation; fertilizer/agricultural chemicals; food and related products/by products: inorganic chemicals; iron and steel manufacturing; leather and leather products; nonferrous metals manufacturing/foundries; organic chemicals; plastics and resins manufacturing; pulp and paper industry; rubber and miscellaneous plastic products; stone, glass, clay, and concrete products; textile manufacturing; transportation equipment; and water treatment. This term does not include oil and gas wastes regulated by the Colorado Oil and Gas Conservation Commission." Although it is not explicitly stated. industrial waste includes remediation wastes (e.g., old fill, investigation derived wastes, and contaminated materials). Only non-putrescible and non -hazardous industrial wastes will be considered for acceptance by Pawnee Waste provided they meet the regulatory criteria as a non -hazardous waste and the standards for NORM and TENORM established herein 2.5 Construction and Demolition Waste The CDPHE defines construction and demolition (C&D) debris in 6 CCR 1007-2 Part 1 to mean "waste that is generated from construction, remodeling, repairs, or demolition of buildings, pavements, and other structures which includes but is not limited to, lumber, bricks, carpets, ceramics, sheetrock, metals, drywall, window glass, metal and plastic piping. paint and any other non -hazardous materials resulting from construction and demolition operations." C&D wastes may be accepted by Pawnee Waste provided they meet the regulatory criteria as a non -hazardous waste and the standards for NORM and TENORM established herein. 2.6 Wastes Requiring Solidification Waste materials that are otherwise acceptable but are not capable of passing the Paint Filter Test may, at Pawnee's discretion, be received and accepted at the Facility. With generator consent, such wastes will be processed at the on -site solidification unit prior to landfilling. These include wet sludges and other wastes exhibiting "free liquids," either as disclosed by the generator on the Waste Profile Sheet, or as presented at the gate (i.e., due to separation during transport, inadequate solidification by generator, or other reason). Pawnee does not currently plan to accept bulk or containerized liquids for solidification unless the Facility has been approved by the CDPHE and Weld County to receive such wastes, and the wastes have been treated (solidified) to pass the Paint Filter Test (USEPA Method 9095B) prior to deposition in the Landfill; Pawnee defines bulk liquids as wastes which are typically injected into Class II wells without prior treatment (beyond filtration for de minimis solids removal). The solidification operation, which is more fully described in the Solidification Unit Design and Operations Plan (Appendix H), will be operated and maintained by Pawnee within the lined Landfill area. • Wastes Requiring Special Handling or Disposal Methods Certain waste streams that may be accepted at the Landfill may require special handling and/or disposal methods. These include, but are not limited to: Dusty wastes ' GOLDER 6 October 30, 2019 1407882B Revision 6 Drummed wastes NORM/TENORM wastes and tracer materials Odorous wastes 2.7.1 Dusty Wastes Dusty wastes will be handled with care and wetted with water or leachate (using the on -site water truck or wagon), both at the point of unloading and during waste spreading and compaction, to minimize fugitive dust generation. The dusty wastes will then be covered with cover soil or other E&P wastes as soon as practicable. 2.7.2 Drummed Wastes Drummed wastes will be unloaded at the working face in a manner so as to ensure worker safety, which may entail emptying the drums at a location off to the side of the active working face. The contents of each drum will be emptied and visually inspected by Pawnee personnel. Once the drummed material is completely unloaded, it will be pushed to the working face and combined with other E&P wastes. 2.7.3 NORM/TENORM Wastes Additional cover material and worker safety provisions are required for handling of NORM/TENORM wastes (i.e., wastes having radioactivity levels below the acceptability thresholds defined in Section 3.7 of this WAP, but exceeding the criteria for the "exempt" category in CDPHE's Interim Policy and Guidance Pending Rulemaking for Control and Disposition of Technologically -Enhanced Naturally Occurring Radioactive Materials in Colorado (2007) [or latest version]). Please see the buffer cover requirements described in Section 7.1 of the Operations Plan. The Worker Health & Safety Plan Outline provided in Appendix J lists the site -specific health and safety topics to be addressed for the operators at the Facility, including those for handling and inspecting NORM/TENORM wastes and tracer materials. 2.7.4 Odorous Wastes Odorous wastes will be unloaded and covered with cover soil or other E&P wastes as expeditiously as possible to minimize the potential for nuisance odors. If warranted based on the amount of material received and the scope of the odor concern, odor suppressants may be applied. 3.0 PROHIBITED WASTES 3.1 Liquid Wastes Bulk (non -containerized) or containerized liquids will not be accepted unless Facility has been approved by CDPHE and Weld County to receive such wastes, and the wastes have been treated (solidified) to pass the Paint Filter Test (USEPA Method 9095B) prior to deposition in the Landfill. 3.2 Hazardous Waste The Landfill will not accept hazardous wastes as defined or classified as such by the Hazardous Waste Commission pursuant to 25-15-302, C.R.S., as amended (e.g., ignitables [solvents, paints, and fuels], corrosives [acids and alkalis], reactive[s], non-RCRA exempt E&P wastes that exhibit hazardous characteristic(s), and listed wastes). 3.3 Municipal Solid Waste The Landfill will not accept municipal solid waste (MSVV). 4 GOLDER 7 October 30, 2019 1407882B Revision 6 3.4 Asbestos -containing Material _AS.Prierf The Landfill will not accept solid wastes containing asbestos -containing material (ACM), which is defined as any material containing greater than 1°/0 by weight asbestos in any of the asbestiform varieties of serpentinite (chrysotile), riebeckite (crocidolite), amosite (cummingtonite-grunerite), anthophyllite, actinolite, and tremolite, or regulated asbestos -contaminated soils (RACS). Should an E&P facility generate ACM or RACS because of plant re -configuration or construction, Pawnee would accept such waste only after all approvals and permits from the appropriate CDPHE Divisions and Weld County have been granted. 3.5 Polychlorinated Biphenyl Wastes Some acceptable E&P waste has the potential to contain polychlorinated biphenyls (PCBs), such as natural gas pipelines and lubricating oils. Compressor stations in particular may be a source of PCBs, including scrubbers, filter, and condensate. The Landfill will not accept solid wastes, electric equipment, or oils containing PCBs in concentrations greater than 50 parts per million (ppm). 3.6 Radioactive Wastes The Landfill will not accept radioactive wastes as defined and governed by Part 14 of the Colorado Radiation Control Regulations (6 CCR 1007-1) with the exception of approved tracer materials containing Ir-192, Sc-46, or Sb-124 at concentrations less than 1,000 pCi/g (total of all isotopes combined): other such radioactive wastes will be deemed unacceptable and specifically prohibited. Unacceptable radioactive wastes include byproduct material as defined and governed in the Atomic Energy Act as revised, and surface contaminated materials that exceed the American National Standard, Surface and Volume Radioactivity Standards for Clearance (ANSI/HPS N13.12-2013). 3.7 NORM/TENORM Waste Exceeding Established Thresholds The Landfill will not accept NORM and TENORM waste with concentrations that exceed the limits established in this WAP, which are based on the results of the Radiation Risk Assessment and RESRAD modeling (see Appendix I) and the CDPHE Interim Policy and Guidance Pending Rulemaking for Control and Disposition of Technologically -Enhanced Naturally Occurring Radioactive Materials in Colorado (2007) (or latest version thereof). These limits include the following: Combined Ra-226 and Ra-228 concentration greater than 50 pCi/g above background, where background is taken as 1.7 pCi/g for Ra-226 and 1.7 pCi/g for Ra-228 (based on site test results); and/or U -Nat concentration greater than 10 pCi/g above background. where background is taken as 1.12 pCi/g; and/or Th-232 concentration greater than 10 pCi/g above background, where background is taken as 0.84 pCi/g; and/or Pigging wastes/residues from natural gas pipelines with maximum concentrations of Pb-210 or Po -210 in excess of 10 pCi/g. Background concentrations listed above are average values based on site -specific testing performed on samples collected from the upper 0.5 to 5 feet of existing native soils, as summarized in Table D-4. GOLDER 8 October 30. 2019 1407882B Revision 6 3.8 Unacceptable Wastes In addition to the prohibited wastes listed above, Pawnee shall not accept the following non-E&P wastes for disposal at the Landfill, unless approved through this WAP or via correspondence with CDPHE and Weld County expressly granting approval: Household garbage and putrescible waste Animal carcasses Waste grain, seed, and elevator screenings Wastes containing "free liquid" and/or that fail Paint Filter Test (unless accepted for solidification in approved on -site solidification unit) Bulk liquids Pesticides and pesticide containers Lead -acid batteries Scrap metal or appliances Waste electronic devices (as defined by the Regulations) Mercury -containing devices (e.g., fluorescent lighting, switches, thermometers, thermostats, etc.) Manure Septic tank pump waste Infectious wastes Regulated radioactive waste Tires id Pyrophoric wastes 4.0 WASTE SCREENING PROGRAM FOR PREVENTING DISPOSAL OF PROHIBITED OR UNACCEPTABLE WASTE (REGULATION 2.1.2) The detection and prevention of receiving prohibited or unacceptable waste is accomplished by the pre-screening and waste inspection program practices described in the following subsections. The goal of the program is to prevent waste generators from bringing regulated hazardous wastes, municipal solid wastes, PCBs, and/or other prohibited or unacceptable wastes to the Facility. To effectively accomplish this goal, Pawnee will follow a tiered approach to waste screening: 1) Pre-screening, generator education, and determination of acceptability prior to receipt 2) Random load inspections 3) Routine waste exclusion/screening procedures ' GOLDER g October 30. 2019 1407882B Revision 6 These waste screening methods are discussed in the following sections. 4.1 Pre-screening and Generator Education The purpose of this section is to provide procedures for Pawnee personnel to determine if a waste generator has materials acceptable for disposal at the Landfill. The procedures include the following steps: Pre-screening and generator education Determination of acceptability prior to receipt at the Landfill (pre -approval) Inspection and verification upon receipt at the Landfill Examples of all forms discussed in this section are included in Appendix D-1. The pre-screening and generator education program will ensure that solid waste generators and transporters are n otified of the Landfill operating requirements and restrictions. It is designed to educate customers of their o bligations to conform to the regulations and Pawnee policies and procedures. Generator education materials include forms and instructions that are required for a waste stream to be accepted for disposal at the Landfill. Pawnee will provide the following information to generators to ensure that they are notified of the Facility o perating requirements and restrictions: Waste acceptance criteria, including the requirement for the waste to be solid, non -hazardous RCRA exempt exploration and/or production waste, and other non -hazardous wastes including oil and gas waste, POTW- generated wastes, and select industrial wastes; Waste application forms, including the requirement for analytics and certification; Waste approval procedures and documentation requirements: Waste screening procedures, including random inspections and potential random testing/sampling provisions; and Basis for waste rejection. The pre-screening and education process informs generators and transporters of the requirements so that unnecessary paperwork, transportation of an unacceptable load, or delay at the Landfill can be avoided. For example, during this pre -approval process, Pawnee personnel will make clear to customers that only generators and transporters of solid, non -hazardous, acceptable waste types that do not contain NORM/TENORM above the prescribed threshold limits should take the next step of completing an application for waste acceptance at the Landfill. The instructions and forms may be delivered to generators or transporters in person, via a mail service, or through electronic means. Only personnel fully trained in Pawnee's specific waste acceptance procedures and applicable regulations will assist generators with questions they may have about the acceptability of their waste at the Facility. Consultation by Pawnee personnel with regulations, regulators, and/or consultants may be made, particularly if it is a waste material that has not previously been received. 4.2 Waste Profile Sheet Waste generators that proceed past the pre-screening stage will be required to complete and submit a Waste Profile Sheet for approval prior to delivery of each distinct waste stream to the Landfill. The Waste Profile Sheet must be certified by the generator for each waste stream or discrete waste type to be delivered, and/or from each GOLDER 10 October 30, 2019 1407882B Revision 6 "generation point" (e.g., well pad). Written confirmation of Pawnee's approval of the waste stream will be required as a means of authorizing the generator to deliver the waste to the Facility. An Example of the Waste Profile Sheet to be used for the Facility is provided in Appendix D-1 to illustrate the information, data, certifications, etc. to be required of the generator for each category of acceptable waste, and are subject to change to meet the needs of Pawnee. Substantive modification(s) of the Waste Profile Sheet will be provided to CDPHE and Weld County. The Waste Profile Sheet generally requires the following information: Generator's name, address, and contact information; Description of the waste stream, including name, type, source, method of shipment, estimated volume, physical characteristics, and special handling instructions; Generator's identification of the waste stream as one of the acceptable waste categories: as defined in Section 2.0 of this WAP; and Generator certifications that all samples tested are representative of the identified waste stream and that the waste is not regulated hazardous waste (either through RCRA exemption or by testing for hazardous characteristics). Following selection by the generator of one of the acceptable waste categories, the Waste Profile Sheet will require that appropriate testing results and certifications be attached in accordance with Section 4.2.1 of this WAP. Pawnee may, at its discretion, decline to accept a specific waste stream at the Facility based on physical characteristics, analytical results, or other means of evaluating chemical composition, waste type/source, project volume, and/or frequency of the waste to be delivered, and/or other factors. 4.2.1 Waste Analyses and Information Required Depending on the type of waste being considered for disposal, a generator and/or transporter will be required to provide to Pawnee the physical characteristics of the waste, either through their own observations, by evaluation of the chemical characteristics via analytical testing procedures, and/or through other sources of information (i.e. generator knowledge). The types of information and various tests that may be included with the waste profile sheet are: Material safety data sheets (MSDSs) Chemical composition analysis TCLP test results Reactivity, corrosivity, and ignitability test results Radionuclides (e.g., Ra-226, Ra-228, U -Nat, Th-Nat, Pb-210, Po -210) Tracer material isotopes (Ir-192, Sc-46, Sb-124, using in situ gamma spectroscopy HPGe detection equipment) TPH, BTEX, PCB, and other analyses as appropriate for the specific waste stream Depending on the waste stream, the chemical composition of a waste may be determined by using standard analytical procedures to identify the concentration of chemicals of concern that could be in the waste. The results 4GOLDER 11 October 30. 2019 1407882B Revision 6 from a chemical composition analysis must be in units of ppm, milligrams per kilogram (mg/kg) (which corresponds to ppm), parts per billion (ppb), pCi/g, or micrograms per kilogram (µg/kg) (which corresponds to ppb). 4.2.2 Sampling Procedures Sampling procedures and sample handling are key components in accurately determining the chemical makeup of a waste. The generator and/or transporter will be required to verify that the sample collected for waste characterization is a true representation of the waste. A representative sample must be obtained by following approved sampling methods or by an equivalent method selected by the generator and/or transporter or authorized designee. The amount of sample required, bottle size and type, shipping requirements, and holding times are dependent on the waste analysis to be conducted. Generators and/or transporters will be instructed to consult with the analytical laboratory conducting the sample analysis for complete information concerning these requirements. Chain -of -custody forms should be used with each sample collected. The chain -of -custody includes information about the sample size, container, required testing, date and time of sample collection, name of sampling personnel, name of waste generator and/or transporter, identification of waste type/source (e.g., drill cuttings, tank sludge, etc.), and signature of the person sampling and the person accepting custody of the sample for analysis. 4.2.3 Asbestos and PCB Testing The Waste Profile Sheets will require that the generator certify that PCB concentrations in the waste are less than 50 ppm and that the waste contains no more than 1% asbestos by weight. In the event that Pawnee obtains specific authorization from CDPHE and Weld County to accept ACM, the Waste Profile Sheet included in Appendix D-1 will be modified. 4.3 Waste Stream Review and Approval Qualified Pawnee representative(s) will review the Waste Profile Sheet, including the analytical results or equivalent information (i.e., 40 CFR 262.11 allows generator and/or transporter knowledge of the waste and process generating the waste) to screen each prospective waste stream submitted by the generator. Pawnee reserves the right to require (re -)sampling and analysis of any waste submitted for consideration. Waste Profile Sheets, with any accompanying characterization information or test results, will be maintained in the Facility's permanent Operating Record. Wastes that are shown through the pre-screening and review process to contain unacceptable characteristics will be rejected, and a notation of the cause for rejection put in the generator's file: which forms part of the Operating Record. Waste rejection procedures are detailed in Section 4.6. Upon determination that the Waste Profile Sheet is complete and accurate and the waste is deemed acceptable, the generator will be notified by Pawnee in writing confirming the waste is approved for receipt at the Landfill. As part of the approval process, Pawnee will assign a unique approval number (e.g., Waste Profile ID number) for the waste stream represented by the Waste Profile Sheet, which will be recorded on the Waste Profile Sheet. 4 GOLDER 12 October 30, 2019 1407882B Revision 6 4.4 Waste Stream Retesting and Certification Periodic follow-up waste characterization for an approved waste stream may be required, based on the type of material in question, the process generating the waste, and the constituents of concern in the waste. Generators and/or transporters will be required at least annually to: Certify that the waste, or process generating the waste, will not change or has not changed since the original waste characterization; or Submit updated waste characterization data if changes to the process or the waste stream have occurred. Waste materials that are consistent in physical and chemical makeup may not require retesting. For these wastes, an annual or one-time waste characterization certification will be required stating that the waste remains the same as the initial characterization. Waste streams that can vary significantly over a short time span will be required to conduct periodic retesting at a frequency to be determined by Pawnee on a case -by -case basis. Pawnee also reserves the right to request analytical test results on a specific waste stream any time the waste appears to vary from the approved waste characterization. Observed variations can include a color change. physical change (e.g., granular to powder), different odor, or change in composition mixture. Visual observations will be used to assist in evaluating changes in waste characterization. A written request for the updated analytical testing results will be sent to the generator and/or transporter identifying the chemical compounds they should test for and the date by which they should forward the results. No additional wastes will be accepted from the generator and/or transporter until the required testing is completed. 4.5 4.5.1 Screening at the Landfill Load Screening at Gate Load screening performed at the gate consists of Waste Profile Sheet review, visual screening, weighing, and container inspection as described below. All shipments of waste shall remain on the transport vehicle in the receiving/entrance area during the gate screening process until operating personnel have completed the review of the waste documentation and accepted the load. 4.5.1.1 Approved Waste Profile Number Each delivery to the landfill shall be associated with a completed manifest and approved Waste Profile Number that documents the delivery has been pre-screened and approved. Deliveries without an approved Waste Profile Sheet accompanying the load will be rejected. The Gate Attendant and/or other trained Pawnee personnel will review the Waste Profile Number accompanying each load to verify that the profile has been approved. If approved documentation is not provided with the load, authorized Landfill management will be contacted to determine acceptability. If necessary. Landfill management will contact the waste generator to determine if a Waste Profile Sheet has been completed and approved for the waste, and if so. request that it be delivered immediately via facsimile or electronic means. If the waste profile has not been approved for acceptance, the load will be rejected. 4.5.1.2 Visual Screening In addition to the paperwork review. the Gate Attendant and/or other trained Pawnee personnel will visually verify that the load is representative of the waste description on the approved Waste Profile Sheet. All waste loads accepted for disposal will be visually inspected to determine if the load of waste has essentially the same characteristics as those documented by the generator on the approved Waste Profile Sheet. A remote camera GOLDER 13 October 30. 2019 1407882B Revision 6 positioned to see into trailer loads will assist Landfill personnel in determining whether or not the load appears consistent with the description on the corresponding Waste Profile Sheet, and whether or not the waste exhibits any of the following characteristics: Hazardous labels (including radioactivity) or shapes (visual inspection) An unusual or unexpected appearance The presence of free liquids Bulk liquids or liquid containers Unusually strong or irritating odors not associated with typical acceptable waste types Apparent chemical reactions or noticeable fumes Is finely divided or granular material (e.g., powders. dusty solids) If the load contents are questionable or are clearly inconsistent with the waste description documentation provided in the waste profile, authorized Landfill management will be contacted to determine acceptability. If necessary. Landfill management will contact the waste generator to determine if the waste load is covered under a different approved Waste Profile Sheet. If a matching approved waste profile cannot be provided, the load will be rejected using the process described in Section 4.6 below. 4.5.1.3 Gate Tests No physical testing at the gate is anticipated at this time; however. Pawnee may implement gate screening testing in the future if it is determined that gate screening tests will provide additional safety benefits or improve regulatory compliance. In that case, a standard operating procedure for gate screening will be developed. and this WAP would be revised accordingly. 4.5.1.4 Container Inspection Waste in containers will be opened to verify data reported on the Waste Profile Sheet. If this procedure reveals that the physical description of the waste differs significantly from the appearance of the waste, then all containers will be rejected. Indicators of potentially unacceptable waste for which operating personnel should exercise special care are listed above. 4.5.1.5 Weights All waste loads must be weighed using the certified scale. A record will be made of all the required information including generator details, weights. and date of acceptance. Tare weights will be established in accordance with Pawnee policy to enable accurate recordkeeping on the loads received for disposal. In the event the scale is not working, volumes will be recorded. To avoid downtime at the scale house, Pawnee will make routine inspections, remove debris, and provide maintenance as recommended by the scale manufacturer, including re -certification by the State. 4.5.1.6 Radiation Detectors at Scale Stationary gamma radiation monitor(s) (Ludlum Model 375P, or similar) will be installed at the scale (hereinafter referred to as aportal monitor") to survey each incoming load. The sensitivity of the portal monitor will be sufficient to detect concentrations of NORM/TENORM above the levels listed in Section 3.7. The setpoint on the ' GOLDER 14 October 30. 2019 1407882B Revision 6 alarm will be set to maximize sensitivity while minimizing false positive readings. The design objective of the setpoint is to have less than one false positive in 1,000 vehicles passing. The alarm setpoint may be adjusted based upon manufacturer recommendations and site -specific data collected after installation. Once data is gathered over the first 6 months of landfill operation to correlate gamma survey meter readings to laboratory radionuclide concentrations, the portal monitor readings will be compared against a two -tiered system for response actions: Tier 1 action: If the portal monitor detects radiological activity at greater than 40 µR/hr (or adjusted level based on correlation data) above background. the following procedures will be initiated: The load will be redirected to pass the detector a second time for confirmation of the reading; The response procedures listed in Appendix D-2 will be implemented; and A Radiation Alarm Monitor Record will be completed (sample copy is in Appendix D-2) for each radiation detector alarm activation. Tier 2 action: If the portal monitor detects radiological activity at greater than 50 µR/hr (or adjusted level based on correlation data) above background. triggering the alarm, the following procedures will be initiated: The load will be redirected to pass the detector a second time for confirmation that the alarm continues to be triggered; The response procedures listed in Appendix D-2 will be implemented; If the reading is confirmed and it is concluded that the truck driver is not the source of the radiation, the load will either be rejected, or, Pawnee may conditionally reject the load, pending laboratory testing of the waste (by the generator) for radionuclides (the contents of the load will be sent back with the generator awaiting acceptable results); and A Radiation Alarm Monitor Record will be completed (sample copy is in Appendix D-2) for each activation of the radiation detector alarm. Due to the potential variability of the waste streams, this two-tier system may be modified to better identify waste load outliers as is further addressed in Section 4.7 and Appendix D-2 of this WAP. 4.5.1.7 Handheld Gamma Survey Meter A Ludlum Model 3 with a Ludlum Model 44-2 probe, or similar make with a sodium iodide gamma scintillation detector, will be used to survey the exterior of loads that activate the radiation detectors at the scale. Personnel would then follow the radiation detection response procedures detailed in Appendix D-2, including scanning the driver to determine whether the driver is the possible source triggering the meter (cancer treatments can create sufficient radioactivity concentrations to trigger a detector), and surveying the exterior of the vehicle to determine whether there is a possible source in a specific area of the load. The radiation detection response procedures are also summarized on the Radiation Monitor Alarm Record form. A Radiation Alarm Monitor Record (sample copy is provided in Appendix D-2) will be completed for each radiation detector alarm activation. Personnel will be trained in the proper use of the radiation monitoring equipment. The meter will be calibrated based on manufacturer recommendations. > GOLDER 15 October 30. 2019 1407882B Revision 6 4.5.2 Random Load Inspections and Testing Pawnee will implement a random load inspection and testing program as described in detail in this section. Pawnee will inform all waste generators and transporters of the random load inspection and testing program. Pawnee personnel (or a contractor) will perform random inspections of loads accepted at the Landfill. All types of waste received will be subject to random load inspections. Landfill personnel will visually inspect random waste loads as they are dumped and spread to look for evidence of prohibited waste. Additional targeted inspections may be conducted if the Facility personnel have reason to suspect all or part of the contents of a load to be unauthorized. Such inspections will follow the same procedures as for random inspections. Large volume waste streams (> 10,000 tons) containing small amounts of NORM/TENORM will be sampled on a pre -established schedule to ensure the waste being shipped continues to comply with the profiled waste description. 4.5.2.1 Training and Equipment All pertinent staff will receive appropriate training to enable them to identify and safely respond to the presence or receipt of any hazardous or other unauthorized waste. Employees will be required to complete a commercially - offered waste screening course and/or undergo internal training by qualified Pawnee representative(s) prior to being allowed to perform random load inspections. Current documentation of this training will be maintained in the Operating Record. Complete employee training requirements are presented in Section 3.4 of the Operations Plan. Equipment necessary to perform the random load inspections will include: Appropriate PPE (i.e., eye protection, hard -toed boots, hard hat, gloves, disposable coveralls as necessary) Heavy equipment (e.g., bulldozer) for moving and separating waste Basic field equipment, such as shovels, rakes. pry bars, and/or hoes Sampling equipment such as trowels, jars. cans, and Ziploca bags 4.5.2.2 Random Load Selection, Inspection, and Sampling Procedures Loads will be selected for inspection using an appropriate random method. The frequency of random load inspections will vary by waste category as indicated in the table below, but will be a minimum of at least one load per month for each category. Loads designated for random inspection will be directed to unload in the active landfill cell in an area separate from the daily designated working face. Loads from which samples are collected for laboratory testing will be clearly marked by the Site Manager (or designee), and the operators will be trained to ensure that the waste remains untouched until results have been obtained and the waste deemed acceptable. Portable light plants or other portable illumination devices, as necessary will be used during hours of darkness to visually inspect the random waste loads as they are dumped and spread. Prior to unloading the vehicle, Pawnee personnel will complete the top part of the -Load Inspection and Sampling Log" (example form provided in Appendix D-1; may be modified or updated by Pawnee as needed). At that time, the vehicle contents will be unloaded, spread out, and inspected by trained Facility personnel. The driver will typically be required to remain on site during the inspection. In the event that this creates a conflict with the driver's schedule, they will be released from the Site with the understanding that they will be contacted and expected to cooperate in the event that any type of prohibited wastes are found. Once the load has been spread out using the heavy equipment, Pawnee staff will conduct the physical screening process using basic field equipment to shift and expose the waste materials and examine the wastes for visual 44> GOLDER 16 October 30. 2019 1407882B Revision 6 signs or unusual odors that may indicate unauthorized or unacceptable waste(s). Pawnee employees that may come into contact with the waste will use appropriate PPE at all times. The frequency of random load inspections and the parameters evaluated as part of the inspections will be specific to the category of E&P wastes being accepted and inspected, as detailed in the summary table below. All waste categories will undergo visual examination and measurement of gamma radiation using the handheld radiation survey meter (see Section 4.5.1.7). Representative samples will also be collected from all randomly selected loads, in accordance with schedule listed in the table below, for laboratory testing of radionuclides; the results will be used to: 1) obtain (in the case of exempt exploration waste) or confirm (for all other wastes, which will require radionuclide testing as part of the waste profile) the level of radiological activity of the load contents; and 2) build a database to allow correlation between gamma survey meter readings and laboratory measurements of radioisotopes and thus facilitate potential adjustments to the random inspection and sampling program in the future. This database will be developed over the initial six-month period of facility operation to obtain a sufficient number of correlations to define a useable dataset. Thereafter, data will be added to the database as it is collected, and a comprehensive re-evaluation will be performed approximately every six months for the remainder of the first two years, and then annually until no additional benefit is derived, to refine the correlations and increase statistical confidence. If the load randomly selected contains non-RCRA-exempt waste, a composite representative sample of the waste will be collected and tested to verify that the material is non -hazardous. Table D-2: Random Load Inspection and Sampling Overview Waste Category Frequency Load On -Site Inspection Sampling of Random an - Parameters Load Inspection to be and Evaluated/Tested Sampling during Random Exempt Waste Exploration 1 month, more per 500 whichever frequent loads or is 1 per Visual Gamma Radionuclides examination radiation (Ra-226 survey with and Ra-228, handheld U -Nat, meter Th-Nat) Exempt Waste Production 1 month, more per 500 whichever frequent loads or is 1 per Visual Gamma Radionuclides and 210 for and examination gas radiation Po plant -210) (Ra-226 survey gathering with and lines Ra-228, handheld wastes/residues U -Nat, meter Th-Nat, Pb- 4 GOLDER 17 October 30. 2019 1407882B Revision 6 Waste Category Frequency Load On -Site Inspection Sampling of Random and Parameters Load Inspection to be Evaluated/Tested and Sampling during Random Other Wastes Oil and Gas 1 month, more per frequent 500 whichever loads or is 1 per Visual Gamma Radionuclides Toxicity lgnitability methods) Corrosivity Reactivity RCRA Benzene examination radiation 8 (flash (total (pH) metals (TCLP) (Ra-226 cyanide survey point; (TCLP) or multiple and BTEX with and Ra-228, sulfide) handheld as accepted appropriate U -Nat, meter test Th-Nat) Tracer Material 1 per 500 loads Tracer material isotopes (Ir-192, Sc-46, Sb-124) Other Known to NORM/TENORM have Wastes or suspected 1 per 500 loads Visual Gamma Radionuclides examination radiation (Ra-226 survey with and Ra-228, handheld U -Nat, meter Th-Nat) Other NORM/TENORM Wastes Non- 1 per 500 loads Visual Waste Safety examination stream Data Sheet specific (if applicable) RCRA characteristic testing The results of the radionuclide testing performed in conjunction with the random load inspections will be used to further refine the WAP as may be appropriate based on a wider universe of information that will become available after the Landfill is operational. Based on review of the additional data compiled, the frequency and/or methodology of random sampling and analysis of exploration and/or production loads may warrant adjustment. Please refer to Section 4.7. The contents of any load selected for sampling and testing will be clearly marked by the trained Facility personnel to ensure the waste will remain untouched until results have been obtained and the waste deemed acceptable. The results of the above -listed tests will be compared to Table D-3 for hazardous waste characteristics. In accordance with the protocol for sampling, all tools and equipment used for collecting a sample shall be cleaned with water, appropriate cleaning solution, and rinsed with water. Solids and liquids generated from this process ' GOLDER 18 October 30. 2019 1407882B Revision 6 shall be collected and handled as on -site generated waste. Samples of waste are to be handled and managed in the same manner as the original waste (i.e., samples of unacceptable waste are to be returned to the generator or shipped to an approved disposal facility as per the generator's instructions). The sampling protocol will be designed to ensure that a representative sample is obtained. All waste load inspection events will be recorded on the appropriate forms, which will, at a minimum, include documenting the inspections on the "Load Inspection and Sampling Log" form (Appendix D-1 or most recent version). Load inspections shall be documented and maintained in the Operating Record located at the scale house, for review upon request. The load inspection process will involve identification of: Hazardous labels (including radioactivity) or shapes (visual inspection) Unusually strong or irritating odors not associated with typical acceptable waste types Apparent chemical reactions or noticeable fumes Grindings or shavings of undiscernible or suspect origin Bulk liquids and liquid containers If it is concluded that the waste is acceptable (i.e., that it is consistent with the Waste Profile Sheet characteristics and does not exhibit any of the identifiers listed above) it will be transported or pushed (e.g., via bulldozer) into the active disposal area and combined with existing wastes, and the Load Inspection and Sampling Log form will be appropriately completed. If, based on the results of the random inspection observations or sample test results, that waste(s) received does not meet the acceptance criteria, and/or any suspected or confirmed prohibited or unacceptable waste is found, the load will be rejected as per Section 4.6 below. The load will remain segregated and the procedures listed in the Contingency Plan for Handling Unauthorized Wastes (Section 5.0 of this WAP) will be implemented. 4.6 Waste Rejection Loads may be rejected for any of the following reasons: 1) Deliveries without an approved Waste Profile Number accompanying the load: All such loads will be rejected. 2) Discrepancy with approved Waste Profile Number: The discrepancy may involve: a. Documentation: If a transporter presents documentation for a load of incoming waste that contains a discrepancy with the Waste Profile Number or other applicable information, the discrepancy may be corrected through contact with the generator, transporter, and/or other qualified employee or contractor of Pawnee. The load will remain in the load inspection parking area until the discrepancies have been resolved. If the discrepancy is not resolved, the generator will be notified and the load will be rejected. b. Physical attributes of waste: Wastes for which the physical description of the waste on the Waste Profile Sheet differs significantly from the appearance of the waste. This may be observed through examination by the gate attendant or by landfill operators (either during routine operations or random inspection). If the load contents are questionable or are clearly inconsistent with the waste description documentation provided in the Waste Profile Sheet, or if an approved Waste Profile Sheet matching the waste load cannot be located, the load will be rejected. ,� GOLDER 19 October 30. 2019 1407882B Revision 6 3) Presence of free liquids: Any waste that appears to have free liquids present, upon examination by the gate attendant or by landfill operators, will be rejected unless the generator agrees to have the material processed at Pawnee's on -site solidification unit. 4) Unacceptable or prohibited wastes: Wastes that are identified, either through screening by the gate attendant or from the results of random inspection observations and/or sample test results, to contain materials that are suspected or confirmed to be prohibited or unacceptable wastes per the lists provided in Section 3.0 of this WAP, or which otherwise do not conform to the Landfills established acceptance criteria, will be rejected. 5) Unacceptable radioactivity levels: Should it be discovered that a waste load containing NORM/TENORM concentrations exceeding the allowable levels for the required radionuclides has been delivered or accepted, the waste will be rejected and the actions described in the Radiation Detection Response Procedures will be followed (see Appendix D-2). Short-term storage of wastes may be required while awaiting analytical results, resolving documentation discrepancies, or, in certain circumstances, awaiting CDPHE or Weld County approval. As such, this storage area shall be inspected daily. Notification of CDPHE and Weld County will be made for all loads rejected due to the confirmed presence of hazardous waste or PCBs. The Colorado Department of Transportation will be notified in event of a gamma radioactivity reading above regulated transport limits, or other actionable radioactivity levels as set forth by the CDPHE. Records of rejected loads will be maintained in the Operating Record. 4.6.1 Management and Disposal of Unauthorized Wastes In the event that unauthorized waste, whether prohibited by regulation or otherwise unacceptable at the Landfill, is detected, either through random inspection or other circumstances, the responsibility for transportation and disposal rests with the generator. Whether the generator or transporter is ultimately held responsible, Pawnee will ensure that the material is properly managed in the manner described in Sections 5.1 or 5.2 of this WAP (whichever is applicable). 4.6.2 Cause for Suspension from Use of Facility Pawnee may require additional tests of the generator and reserves the right to refuse acceptance of waste. Should sampling and analysis reveal a waste stream routinely reflects unauthorized waste; the generator's waste will be refused until such a time as the generator can demonstrate the waste will meet the approved waste acceptance standards. Testing of the failed parameters will be required prior to Pawnee's acceptance of that waste stream (including all applicable radioisotopes) and such requirement will continue until such a time as the generator can demonstrate that its waste will routinely meet the standards of acceptance. Should the parameters of concern be attributable to a specific geographic area or waste process technology (rather than a specific generator), Pawnee will review its waste acceptance protocol and revise it as needed to ensure the acceptance procedures for like wastes will follow the amended protocol. In the event that a regulated hazardous waste, PCB waste, or radioactive waste is deliberately transported to the Facility despite the generator having been clearly informed that the material is unacceptable, the transporter and/or generator may be suspended from further use of the Facility. ' GOLDER 20 October 30. 2019 1407882B Revision 6 4.7 Waste Acceptance Procedure Adjustments Whereas significant data is available from formations in the Marcellus and Bakken shale plays, very limited data is available on radioisotope concentrations from E&P waste generated in northeastern Colorado. Pawnee recognizes that this WAP, and the associated operational procedures based thereon, may require further refinement as generator information becomes more readily available. Thus, Pawnee proposes to perform a review of its waste receipt processes and the corresponding RESRAD model inputs semi-annually during the first year of operation, and annually for an additional two years. This review will cover: Correlation and deviation between data on the Waste Profile Sheets, portal monitors, and handheld screening device; Evaluation of set point used on the portal monitors and adjustment as appropriate; Adequacy of the frequency of random sampling of various waste streams; RESRAD model revisions using compiled data on actual wastes received. Actual wastes received include all wastes that will have been received and disposed of in the landfill. Data to be compiled include the following: The category of waste (e.g., exploration, production, mixed wastes); Weights on all loads; Analyses of a representative sample of all waste streams received (except exploration wastes) for Ra-226 and Ra-228; Portal monitor results for all waste streams; Hand-held monitor results for wastes that trigger the portal monitor; Analyses of all random samples for Ra-226, Ra-228, natural uranium (U-nat), and thorium -232 (Th-232), wastes from gathering lines from natural gas activities for Pb-210 and Po -210, and tracer material wastes for Ir-192, Sc-46, and Sb-124; Recommendations for modifications to the WAP, Radiation Safety Plan (to be prepared prior to facility operation), and or other operating procedures; and Recommendations for future reviews of the waste streams. 5.0 CONTINGENCY PLAN FOR HANDLING UNAUTHORIZED WASTES [REGULATION 2.1.2(C)(4)] 5.1 Suspected Presence of Unauthorized Waste In the event that Pawnee staff inspecting the waste suspects the presence of unauthorized waste (i.e., non-E&P waste, listed hazardous waste, non-exempt E&P waste with hazardous waste characteristics, PCBs, radioactive materials in excess of 50 pCi/g combined Ra-226 and Ra-228, or other material listed in Section 3.0 of this WAP), the following will be performed: 1) Notify supervisor and/or Site manager 4 COLDER 21 October 30. 2019 1407882B Revision 6 2) Segregate and flag the suspect material and protect with secured tarp (cover with soil if waste is suspected radioactive) 3) Close off the area to all personnel except trained Pawnee employees and emergency response crews 4) Contact the transporter and/or generator immediately 5) Notify the local Fire Department or Colorado State Patrol Hazardous Materials Team and CDPHE Hazardous Materials and Waste Management Division as appropriate depending on the circumstances 6) Engage a licensed contractor to perform testing of a representative sample of the suspect material 7) Suspend work in the area until the substance has been identified and it is determined to be safe to resume work If the transporter or generator is able to provide timely, reliable, additional information or evidence to substantiate that the suspect material is indeed acceptable waste. Steps 5 and 6 above may not be necessary and the subject waste material, if deemed to be acceptable at the Landfill, will be released for routine disposal. If not, notifications and laboratory testing will proceed as indicated above. Depending on the results of the testing. the material will either be: 1) determined as acceptable waste, in which case it will be taken to the active landfill area and the appropriate forms completed; or 2) confirmed as regulated hazardous waste, PCB, or radioactive waste and handled as described below. 5.2 Confirmed Discovery of Unauthorized Waste In the event that the presence of unacceptable waste is confirmed through obvious labeling, field or laboratory testing, or other means, the following actions will be taken immediately: 1) Notify supervisor and/or Site manager immediately 2) Segregate and flag the material and protect with secured tarp (cover with soil if waste is radioactive) 3) Close off the area to all personnel except trained Pawnee employees and emergency response crews 4) Contact the transporter and/or generator immediately 5) Notify the CDPHE Hazardous Materials and Waste Management Division 6) Complete Load Inspection and Sampling Log form to reflect the detection of regulated waste 7) Complete an Incident Log (example form provided in Appendix D-1) and place in Operating Record 8) Ensure that the waste is transported off site by a licensed hauler and taken to a facility authorized to manage the waste, as further described below To ensure proper management of the material, Pawnee will either: 1) require the transporter or generator to retrieve the wastes and provide documentation of proper disposal at an approved off -site facility; or 2) arrange for the proper transportation and disposal of the material. In the case of the latter, Pawnee will contract with an entity licensed to handle the regulated hazardous waste. PCBs, or radioactive waste to assume responsibility for proper transportation and disposal of the waste, and decontamination of the site if necessary. Pawnee will require the contracted entity to provide all necessary documentation for the Facility Operating Record and submit a copy to the CDPHE. GOLDER 22 October 30. 2019 1407882B Revision 6 5.3 Detection of Prohibited Wastes The screening process is also intended to detect prohibited waste other than regulated hazardous waste or PCBs, such as tires, bulk liquids, paint products, lead -acid batteries, used motor oil, or anti -freeze. Pawnee will reject such wastes when discovered, and will require that the generator provide a transporter to remove the waste from the Facility. If the transporter has already left the Facility, Pawnee will contact the transporter and/or generator to retrieve the waste. Pawnee may elect to retain the waste at the Facility for proper management along with other similar waste materials generated at the Facility (e.g., automotive batteries or used motor oil) or will otherwise ensure that the waste material is properly managed (recycled or disposed) off site at an approved facility. In either event, the Load Inspection and Sampling Log and Incident Log will reflect the detection of the prohibited waste, and Pawnee will notify the generator. 5.4 Management and Disposal of Unacceptable Wastes In the event that unacceptable waste, whether regulated or prohibited, is detected, either through random inspection or other circumstances, the responsibility for transportation and disposal rests with the generator. Whether the generator or transporter is ultimately held responsible. Pawnee will ensure that the material is properly managed in the manner described in Sections 5.1 or 5.2 of this WAP (whichever is applicable). 5.5 Documentation of Inspections and Incidents A Load Inspection Log will be filed and placed in the Operating Record for every waste inspection performed (random or otherwise). In the event that an unauthorized waste incident occurs, an Incident Log will also be completed and placed in the Operating Record. Golder and the G logo are trademarks of Golder Associates Corporation I \14\1407882b\0400\0410 edop rev7\1407882b app d wap_rev6 30oct19 docx 4 GOLDER 23 October 2019 1407882B Rev. 6 Table D-3: Test Parameters and Allowable Levels for Non-exempt E&P Waste TCLP (Test Parameter Method - -- --- .. _ — .... _ _ --T-- .- �— 1311) ► (mg/I) Maximum Allowable Concentration Metals Arsenic 5.0 Barium 100.0 Cadmium 1.0 Chromium 5.0 Lead 5.0 Mercury 0.2 Selenium 1.0 Silver 5.0 Volatile Organic Compounds Benzene 0.5 Ignitability Characteristic Minimum Allowable Flash Point Test Method 1010A, 1020B, 1030. 1040, or 1050 140°F Corrosivity Characteristic Allowable Parameters pH (Test Method 9040C) ≥ 2 or ≤ 12.5 Reactivity Characteristic (mg/I) Maximum Allowable Concentration Total Cyanide (Test Method 9012) 10.0 Total Sulfide (Test Method 9034) 10.0 -(‘ GOLDER October 2019 Table D-4: Background Radioisotope Results Summary 1407882B Rev. 6 SS1 SS2 Averages Isotope Unit BH01 BH02 BH03 BH04 BH08 BH10 BH10 DUP BH01 BH02/03 BH04 Isotope Average Thorium -232 mg/kg 8.49 7.94 7.98 7.31 7.91 7.53 7.97 6.23 8.09 6.81 Thorium 7.63 -232 Uranium -238 mg/kg 1.34 1.43 1.49 1.55 1.59 1.47 1.51 2.02 1.57 2.45 Uranium -238 1.64 Radium -226 pCi/g 1.66 1.43 1.73 1.93 1.33 1.69 1.84 1.82 1.94 Radium -226 1.71 Radium -228 pCi/g 1.97 1.54 1.99 1.24 1.85 2.24 1.24 1.87 1.75 Radium -228 1.74 Notes: 1). Samples BH01-SS1 through BH10-SS1 collected between October 24, 2014. and October 27. 2014, adjacent to boring locations within the Facility boundary at a depth of 0 to 6 inches below ground surface. 2). Samples BH01-SS2 through BH04-SS2 collected on October 28, 2014, from borings located within the Facility boundary, and were composited over a sample interval from 0 to 5 feet below ground surface. Sample BH02/BH03-SS2 was composited from borings BH02 and BH03 in the same manner. 3). Laboratory test results provided by TestAmerica Laboratories, Inc. GOLDER PAWNEE WASTE VF 10252019 Remittance Address Phone Fax Waste Profile Sheet Pawnee Waste Facility Site Location WPS # (Office Use Only) Email Important: The waste generator or authorized representative must complete this form and email a scanned copy or fax to Pawnee Waste. Please ensure the WPS is signed and dated and includes all supporting and signed analytical documents. 1. Generator Information a) Name b) Address c) Location Company Street Address City State Zip Code Site Name / Physical Address City State Zip Code d) Contact Information Name Company Phone Fax Email 2. Invoicing Information n Same as Generator information a) Company / Contractor Company b) Address c) Contact Street Address City State Zip Code Name Email Phone Fax e) Job Identification PO# 3. Material Name / Generating Process Describe: 4. Attachments ❑ Analytical n MSDS � Memo / Letter Other (specify): 5. Physical Properties a) Physical Description ❑ Dry solid ❑ Sludge ❑ Particulate ❑ Free -liquids c Debris b) Odor ❑ Strong Slight None Describe: Note: Waste with free liquids must be pre -approved for on -site solidification Page 1 of 2 6. Waste Stream Information (check all that apply) a) Exempt E&P Waste b) Oil and Gas Wastes c) POTW Wastes d) Other Industrial Wastes n Exploration Analysis of cuttings not required. Known or suspected exploration waste with Ra 226+228 >10 pCi/g to be analyzed. ❑ Petroleum Contaminated Soils If exempt per 261.4 (b) (10), no testing required. Otheriwse, specific RCRA and/or TENORM tests may be required ❑ Drinking Water Ra 226, Ra-228, U (NAT) Production Analysis of: Ra-226, Ra-228, U (Nat), Th (Nat) required for all solids. Natural gas waste analysis to include Pb-210, Po -210. Other: RCRA characteristic, TCLP, TENORM and/or other waste stream specific tests may be required (e.g., tracer wastes) Wastewater RCRA characteristic, TCLP ❑ Describe: Ra 226, Ra-228, U (NAT), Th (NAT), Pb-210, Po -210 (specific to NORM/TENORM wastes) RCRA characteristic, TCLP, BTEX and/or other tests may be required specific to the process 7. Waste Stream Characterization If any of the following is answered "No", additional analytic data are required. a) Does the waste (i) contain NORM/TENORM with combined Radium-226/Radium-228 < 50 pCi/gram; (ii) emanate < 50 uR/hr: (iii) contain < 10 pCi/g of each U -NAT, Th-232, Po -210, Pb-210? b) Is the waste non -hazardous as defined under Colorado regulations (6 CCR 1007-3 Part 261)? JYes No Yes No c) Does the waste pass the paint filter test (EPA 9095B)? If not, has Pawnee determined the waste suitable for solidification? d) Does the waste contain PCBs at a concentration < 50 ppm? e) Does the waste contain Asbestos at a concentration < 1%? f) Are all of the analytic requirements identified in 6 (above) attached? Yes No Yes No Yes No Yes No All waste analytic procedures to conform with CDPHE standarts; radioactive limits are above background. Should any Waste load trigger Pawnee's portal radiation detectors upon delivery, further screening will be required. I understand it is the sole responsibility of the Generator to determine the characteristics of the waste and its proper classification. I certify that all information contained in this waste profile is true and correct, and the waste material described is accurately identified and characterized. I certify that this waste is classified as non -hazardous waste and it does not contain combined Radium-226/Radium-228 greater than 50 pCi/gram, does not emanate radiological activity greater than 50 pR/hr, does not contain more than 1% asbestos. and does not contain more than 50 ppm PCBs. I certify that the material passes the Paint Filter Test (EPA Method 9095B), unless approved for solidification at the Pawnee Waste Landfill. I certify that all known or suspected hazards have been disclosed. and that the waste is not a regulated hazardous waste by U.S EPA or the State of Colorado. I certify that all samples used for this analysis are representative of the materials to be shipped. I understand that all wastes may undergo inspection upon arrival at the Pawnee Waste Landfill and may be refused if the delivered material does not conform to the description herein. I understand that it is the Generator's sole responsibility to characterize. retrieve. package. load. store. remove. and transport off site any unacceptable waste. including any other waste contaminated by the Generator's unacceptable waste. The Generator will immediately notify Pawnee if there is a change in the source, composition of. or process generating this waste stream. prior to delivering the waste to the Pawnee Waste disposal facility. Generator or Generator's Authorized Representative Printed name Signature Title Company Date 1. Waste Screening Pre -Screening by: 2. Waste Profile Sheet Approved by: 3. Contract Signed by Customer and: Date: Date: Date: Page 2 of 2 LOAD INSPECTION AND SAMPLING LOG PAWNEE WASTE E&P LANDFILL SECTION I WASTE HAULER ADDRESS TELEPHONE CONTACT PERSON/TITLE DRIVER'S NAME DRIVER'S LICENSE # VEHICLE LICENSE PLATE # SOURCE OF WASTE GENERATOR WASTE PROFILE SHEET ID NUMBER SECTION II SUSPECTED UNAUTHORIZED WASTE? YES CONFIRMED? YES IF CONFIRMED, COMPLETE INCIDENT LOG IF NO UNACCEPTABLE WASTE PRESENT, DO NOT FILL IN SECTION IV NO NO SECTION III • Is the material Exempt Exploration or Production Waste (or a mixture thereof)? YES _NO _ If yes 1) Perform radiation survey using handheld meter and record average reading NR/hr 2) Collect representative sample for laboratory radionuclide testing (Ra-226 and Ra-228, U -Nat, Th-Nat) Sample collected and prepared for shipment to laboratory? YES _NO • Is the material Non-exempt Waste? YES NO If yes, collect representative samples for laboratory testing o RCRA metals (TCLP) o Benzene o Ignitability o Radionuclides (Ra-226 and Ra-228, U -Nat, Th-Nat, and for gathering line wastes Pb-210 and Pb-210) Samples collected and prepared for shipment to laboratory? YES NO SECTION IV (complete only if unauthorized waste confirmed) NOTIFICATIONS (as applicable) WASTE SOURCE/GENERATOR [ ] HAULER [ ] SITE MANAGEMENT [ ] STATE [ ] FED [ ] WELD COUNTY [ ] SECTION V EMPLOYEE NAME WITNESS (IF ANY) DATE TIME AM PM (circle one) DRIVER SIGNATURE PAWNEE WASTE REPRESENTATIVE SIGNATURE WASTE SCREENING CHECKLIST PAWNEE WASTE E&P LANDFILL CONTAINERS FULL PARTIALLY FULL EMPTY CRUSHED PUNCTURED POWDERS/DUST IDENTIFIED UNKNOWN SATURATION LABEUHAZARDOUS ODOR/FUMES STRONG FAINT HEAT BATTERY OIL BIOMEDICAL RADIOACTIVITY ASHES/RESIDUE SOD/SOIL CHECK ALL THAT APPLY YES ATTACH ADDITIONAL SHEETS FOR DETAILED INFORMATION NO INCIDENT LOG PAWNEE WASTE E&P LANDFILL DATE TIME NAME OF HAULER OR VEHICLE OWNERS) ADDRESS TELEPHONE NAME OF DRIVER DRIVER'S LICENSE # CONTACT PERSON/TITLE _ VEHICLE LICENSE PLATE # GENERATOR WASTE PROFILE SHEET ID NUMBER TYPE OF INCIDENT ( ) UNACCEPTABLE WASTE ( ) SPILL ( ) FIRE ( ) EXPLOSION ( ) OTHER (explain) DESCRIPTION OF INCIDENT ACTION TAKEN DRIVER SIGNATURE PAWNEE WASTE REPRESENTATIVE SIGNATURE APPENDIC D-2 Radiation Detection Response Procedures October 2019 1407882B Rev. 6 APPENDIX D-2 RADIATION DETECTION RESPONSE PROCEDURES a. Alarm Trigger Procedures Waste deliveries that trigger the alarm on the stationary radioactivity detector at the gate (portal monitor) will be redirected past the detector in order to confirm the actual measurement of the waste. The alarm will initially be set to trigger at a gamma reading of 50 µR/hr. This level may be adjusted after the initial period of facility operation as data becomes available (detailed further in Section (d) below). a. Reading Verification The gate attendant or other Pawnee personnel trained in the detector operations will observe the portal monitor to check for any obvious malfunctions, reset the monitor, and require the vehicle to pass through the detector a second time. If the vehicle triggers the alarm again, the vehicle will be directed to the load inspection parking area (north of the scale house). Driver Assessment Ensure the alarm has ceased and the monitor is reading normal background level. Once parked at the load inspection area, the driver of the vehicle will be directed to walk through the stationary detector and/or submit to a scan using the handheld survey meter. Scanning the driver will determine whether the driver is the possible source triggering the meter; treatments for cancer and other diseases utilize radiation sources sufficient in concentration to trigger a detector. If the driver is the apparent source, the truck alone will be re -measured by using an alternate driver or having the original driver park on the scale and walk away from the truck and detectors. If the truck alone does not set off the alarm, the load is acceptable. There is no restriction on a driver who has had a medical procedure. c. Truck Scan with Handheld Gamma Meter If the driver is eliminated as the source of the detection (i.e., the truck is determined to be source), and the gate attendant will contact the Site Manager or other Pawnee management. The exterior of the vehicle will be surveyed at a distance of no more than two to three inches (or based on manufacturer recommendations) from the vehicle surfaces using the on -site portable gamma survey meter. A minimum of four readings will be taken (two on each side) and this number will be averaged. The handheld meter readings will be GOLDER 1 October 2019 1407882B Rev. 6 used to confirm the portal monitor reading and to determine whether the source of the elevated reading may be isolated in a specific area of the load. d. Correlation Database Development and Response Procedures During Initial Period of Facility Operation The portal monitor and handheld meter readings will be used to develop and refine a database to allow correlation between gamma meter readings and laboratory measurements of radioisotopes (as described in Section 4.5.2.2 of the WAP), and thus assess the need for potential adjustments to the portal monitor alarm/trigger levels in the future. Prior to collecting enough data to define a useable correlation dataset, all loads having readings greater than 50 µR/hr using both the portal monitor and handheld gamma meter will be rejected, and Weld County will be notified. The generator may elect to perform additional laboratory testing of the subject waste for radionuclides (the contents of the load will be sent back with the generator awaiting acceptable results) and re -submit the Waste Profile Sheet. e. Two -Tier Response System Once the database of correlations between gamma survey meter readings and laboratory analytical radioisotope concentrations has been developed, a two-tier response system will be implemented. [Note, the trigger levels for each tier indicated below are subject to change based on the results compiled in the correlation database]: Tier 1: • For portal monitor readings of > 40 to ≤ 50 µR/hr: 1. Perform Reading Verification, Driver Assessment, and Truck Scan with the handheld gamma meter as described in Sections (a) through (c) above. 2. If the gamma readings from both the portal monitor and handheld meter correlate to a combined Ra-226/228 concentration predicted to be less than or equal to 50 pCi/g above background, the load can be accepted. 3. If the gamma readings from both the portal monitor and handheld meter correlate to a combined Ra-226/228 concentration predicted to be greater than 50 pCi/g above background, the generator will be notified. The load will either be returned with the generator or may be conditionally accepted. 4. If conditionally accepted, it will be off-loaded in an inactive area of the cell, isolated, marked, and covered with a secured tarp. A sample of the waste will be taken and subjected to laboratory testing to determine if it meets the criteria set forth in this WAP, and in no event may it exceed the limit of 50 pCi/g combined Ra-226 and Ra-228 above background. li‘› COLDER 2 October 2019 1407882B Rev. 6 Tier 2: • For triggering of the alarm, i.e., readings of > 50 µR/hr: 1. Perform Reading Verification, Driver Assessment, and Truck Scan with the handheld gamma meter as described in Sections (a) through (c) above. 2. If the readings from both the portal monitor and handheld meter correlate to a combined Ra-226/228 concentration predicted to be greater than 50 pCi/g above background, the load will be rejected. 3. The generator may elect to perform additional laboratory testing of the waste for radionuclides and re -submit the Waste Profile Sheet (e.g., if the gamma reading correlation is believed to be unreliable). In this case, the contents of the load will be sent back with the generator awaiting acceptable results. b. Waste Disposition and Notifications If a load is rejected due to elevated radioactivity levels detected using the protocols delineated above, Weld County will be notified. If the vehicle leaves before the situation is sufficiently evaluated, and the readings are suspected to be in excess of Colorado Department of Transportation (CDOT) radioactivity limits (270 pCi/g or 200 millirem/hr), the attendant will contact Colorado DOT and provide them with a vehicle description and any additional information concerning the time the vehicle left the site and where it may be headed. The gate attendant will also contact CDPHE concerning the incident as appropriate. The purpose of these notifications is to attempt to prevent the driver from possibly disposing of the waste illegally or taking it to another facility that is not authorized to receive the waste. The generator of the load of non -conforming material will be contacted and instructed to immediately discontinue delivery of the waste stream. If the waste load has already been delivered to the disposal area and unloaded, the material will be isolated from other wastes until arrangements for proper disposal can be made. Whether rejected at the gate or at the disposal area, the waste material will be transported off -site and delivered to a facility approved for acceptance of such waste (either by the generator or by Pawnee). Pawnee will suspend additional acceptance of the subject waste stream until sufficient data is provided to confirm that additional similar materials will conform to acceptability requirements. Pawnee may further recommend to the generator that they investigate the circumstances of the incident to determine how the material was identified to be acceptable at the Landfill and ensure that such incidents can be avoided in the future. I‘) GOLDER 3 October 2019 1407882B Rev. 6 c. Record keeping and Detector Calibration The results of the handheld survey and the load disposition will be documented on the Radiation Monitor Alarm Record, with copies maintained in the Facility Operating Record. False triggers of the stationary detector alarm are expected at a frequency of approximately one false alarm per 1,000 vehicles surveyed. Precipitation events and other atmospheric conditions can contribute to false positives. Manufacturer representatives of the survey equipment will assist with setting the alarm to minimize false positives while maximizing sensitivity. ' GOLDER 4 r� rsr a"c rF s� ti �y...r�, r ' t : `� �, ,RADIATION =MONITOR ALARM 'RECORD �;r fy t = "b Generator Waste Profile No Waste Origin Waste Type Lab Concentration in Profile Hauler Truck No Trailer No pCl/g License Plate Driver Radiation Measurements: '," ,' �, P ;�'''- Scale„Detector'- �' r � , �, .� � � �� . 3 = ,� • '.' - < -`,' _ Handheld Survey , Monitor/Meter Detector Background Reading Monitor/Meter Reading Date Time Monitored By Initial Alarm I Re -Monitor Initial Alarm I Re -Monitor Ludlum Model 375P or (other, please specify here) Ludlum Model 3 or (other please specify here) Ludlum Model 44-2 of (other please specify here) pR/hr pR/hr pR/hr pR/hr per pR/hr pR/hr pR/hr Scale Radiation ,DetectorAlarm Activation Procedures:,--, �' ,� , _ , , f; , , 1 2 3 4 5 Alert landfill management that alarm has been triggered Record the radiation reading and the other information shown above Instruct the driver to pull off the scale and park the truck away from the detectors Ensure the alarm has ceased and the monitor is reading normal background Determine if the driver activated the alarm Have the driver walk near a detector to determine if he has received a recent nuclear medicine procedure If the driver is the apparent source, re -measure the truck alone by using an alternate driver or have the original driver park on the scale and walk away from the truck and detectors If the truck alone does not set off the alarm, the load is acceptable There is no restriction on a driver who has had a medical procedure If the truck is determined to be the source, notify landfill management Landfill management will perform the following actions a Survey the external surface of the load using a handheld gamma survey meter (Ludlum Model 3 with a Ludlum Model 44-2 probe, or similar) • Compare the meter readings to the database developed by Pawnee to correlate between gamma meter readings and laboratory radionuclide concentrations If the gamma meter readings correlate to a combined Ra-226/228 concentration ≤ 50 pCi/g, the load can be accepted If the gamma meter readings correlate to a combined Ra-226/228 concentration > 50 pCi/g, reject the load and notify the waste generator Document the results of the handheld survey and the load disposition Comments Load Disposition Accepted or Rejected By Date GOLDER golder.com APPENDIX E Environmental Monitoring Plan 1.. A world of capabilities delivered locally APPENDIX E ENVIRONMENTAL MONITORING PLAN Pawnee Waste E&P Landfill Weld County, Colorado Prepared for: Pawnee Waste LLC 3003 E. Harmony 80528 Suite 300 Ft. Collins, CO 80528 Prepared by: Golder Associates Inc. 44 Union Boulevard, Suite 300 Lakewood, CO 80228 July 23, 2015 Revision 1 — February 19, 2016 Revision 2 — November 16, 2017 1407882B Golder Associates November 2017 Appendix E 1407882B Rev. 2 PAWNEE WASTE E&P LANDFILL ENVIRONMENTAL MONITORING PLAN RECORD OF REVISIONS Revision No. Date Description of Revision Section(s) Prepared By 0 07/23/2015 Initial Issuance All SAH 1 02/19/2016 Addition Revision of to MW detection -2016-05 and monitoring MW -2016-06, program 4.2.2 4.0 JAR 2 11/16/2017 Revision to Appendix E-1 -- JAR i \14\1407882b\0400\0408 edop rev5\1407882b app e environmental monitonng plan rev2 16nov17 docx -•- Golder Associates February 2016 Appendix E ii 1407882B Rev. 1 Table of Contents 1.0 INTRODUCTION 1 2.0 BACKGROUND 2 2.1 Site Information and Monitoring History 2 2.2 Monitoring Well Completion Details 2 3.0 GROUNDWATER MONITORING PROGRAM 4 3.1 General Procedures 4 3.1.1 Well Inspection 4 3.1.2 Decontamination 4 3.1.3 Equipment 5 3.2 Quality Assurance and Quality Control 5 3.3 Groundwater Sampling Procedures 6 3.3.1 Purging 7 3.3.2 Sample Withdrawal 7 3.3.3 Sample Preservation and Shipment 8 3.4 Leachate Sampling Procedures 9 3.4.1 Sample Withdrawal 9 3.4.2 Sample Preservation and Shipment 10 3.5 Chain -of -Custody Control 10 3.6 Documentation 10 4.0 DETECTION MONITORING PROGRAM 12 4.1 Detection Monitoring Constituents 12 4.2 Analytical Data Review 12 4.3 Statistical Analysis 13 4.4 Notification 13 5.0 REPORTING 14 6.0 ASSESSMENT MONITORING 15 7.0 ASSESSMENT OF CORRECTIVE MEASURES 16 8.0 REFERENCES 17 i \14\1407882b\0400\0403 edop revl\appendix e\1407882b app e environmental monitoring plan rev1 19feb16.docx Golder Associates 0- S February 2016 Appendix E 1407882B Rev. 1 List of Tables Table E-1 Table E-2 Monitoring Well Details Analyte List List of Figures Figure E-1 Site Layout and Sampling Locations List of Appendices Appendix E-1 Statistical Analysis Plan Appendix E-2 Lithologic and Well Logs i \14\1407882b\0400\0403 edop rev1\appendix e\1407882b app e environmental monitoring plan revs 19feb16 docx Golder Associates February 2016 Appendix E 1 1407882B Rev. 1 1.0 INTRODUCTION This Environmental Monitoring Plan (EMP) has been prepared by Golder Associates Inc. (Golder) for the proposed Pawnee Waste LLC (Pawnee) E&P Landfill (Landfill or Facility). This EMP includes the following: • Brief history of the Facility (Section 2); • The groundwater monitoring program (Section 3); ■ The detection monitoring program (Section 4); • Reporting procedures (Section 5); • Assessment monitoring description (Section 6); • The assessment of corrective measures procedure (Section 7); • List of references (Section 8); and • Statistical Analysis Plan (Appendix E-1). This EMP is intended as a working document that will be adapted as needed to reflect regulatory, technological, or operational changes. The Facility will initially be in detection monitoring for the groundwater; if in the future the Facility enters into assessment monitoring, this plan will be modified accordingly. The sampling and analysis procedures described herein are designed to: • Be in accordance with current CDPHE Regulations Pertaining to Solid Waste Disposal Sites and Facilities 6 CCR 1007-2, Part 1 (the Regulations); • Be consistent with EPA -accepted procedures; • Be consistent with the Standard Guide for Purging Methods for Wells Used for Groundwater Quality Investigations (ASTM D6452-99) • Be consistent with the Standard Guide for Field Quality Assurance in a Groundwater Sampling Event (ASTM D7069-04) • Be consistent with Colorado Oil and Gas Conservation Commission (COGCC) standards; and • Ensure that monitoring results provide an accurate representation of site conditions. i \14\1407882b10400\0403 edop rev1\appendix e\1407882b app e environmental monitoring plan rev1 19feb16 docx Golder Associates February 2016 Appendix E 2 1407882B Rev. 1 2.0 BACKGROUND 2.1 Site Information and Monitoring History The proposed Facility is located approximately four miles southeast of Grover, Colorado, near the intersection of County Road 118 and County Road 95 in Weld County, specifically in the northeast quarter and east half of the northwest quarter of Section 13, Township 10 North, Range 61 West of the 6th Principal Meridian. This will be a new ("greenfield") landfill. 2.2 Monitoring Well Completion Details The groundwater monitoring system at the Facility will consist of six groundwater monitoring wells at the locations shown in Figure E-1. Monitoring wells MW -2014-01, MW -2014-02A, MW -2014-03, and MW -2014-04 were installed in October 2014. Monitoring wells MW -2014-05 and MW -2015-06 will be installed in 2016. The wells are installed in 8 -inch -diameter boreholes and are constructed with 2 -inch - diameter polyvinyl chloride (PVC) riser pipes and screen, with a surface completion consisting of a protective steel casing extending to below ground surface. Screen lengths are approximately 5 to 10 feet, with a slot size of 0.010 inches (i.e., 10 slot). The sand pack encasing the screen is #10-20 silica sand. Construction details are presented in Table E-1 and Appendix E-2. A summary of each monitoring well or boring is as follows: ■ MW -2014-01: • Northeast of the Landfill • Ground elevation of 5,091.3 feet above mean sea level (ft AMSL) • Screened from 75.2 to 84.6 feet below ground surface (bgs) • Total depth of 85.2 feet bgs • Upgradient well • MW -2014-02A: • West of the Landfill • Ground elevation of 5,070.9 ft AMSL • Screened from 48.7 to 58.3 feet bgs • Total depth of 58.8 feet bgs • Downgradient well • MW -2014-03: • Southwest of the Landfill • Ground elevation of 5,065.0 ft AMSL • Screened from 45.3 to 50.0 feet bgs • Total depth of 50.5 feet bgs • Downgradient well i \14\1407882b\0400\0403 edop revl\appendix e\1407882b app e environmental monitoring plan revs 19feb16 docx Golder Associates February 2016 Appendix E 3 1407882B Rev. 1 • MW -2014-04: • West of the Landfill • Ground elevation of 5,066.8 ft AMSL • Screened from 47.3 to 57.0 feet bgs • Total Depth of 57.4 feet bgs • Downgradient well • MW -2016-05: • To be installed west of the Landfill • Downgradient well • As -built well data to be added to EMP in the future • MW -2016-06: • To be located north of the Landfill • Cross -gradient well • As -built well data to be added to EMP in the future The monitoring wells will be operated and maintained to perform as designed throughout the life of the groundwater monitoring program for the Landfill. Each of the monitoring wells is located on the Facility property. The wells have been constructed and located according to Colorado Regulations 6 CCR 1007-2, Part 1, Appendix B requirements. \14\1407882b\0400\0403 edop revl\appendix e11407882b app e environmental monitoring plan rev1 19feb16 docx Golder Associates February 2016 Appendix E 4 1407882B Rev. 1 3.0 GROUNDWATER MONITORING PROGRAM 3.1 General Procedures Prior to each sampling event, sample bottles will be ordered from the contracted analytical laboratory certified in Colorado. Sampling personnel will coordinate with the contracted lab so that sample bottles can be ordered in sufficient time for shipping, bottle inspection, and corrections. Appropriate sample bottles for each well will be verified upon receipt. Additional bottles for quality assurance/quality control (QA/QC) samples (e.g., duplicates and field blanks) will also be arranged with the laboratory prior to shipment. The laboratory or sampling crew will provide sample labels, chain -of -custody forms, and chain -of -custody seals with delivery of the sample bottles. The containers, preservation techniques, and holding times for each constituent or group of constituents will be determined in advance of the bottle shipment. All necessary field equipment will be inspected and tested before the sampling event (e.g., check batteries and calibrate field meter). A checklist can be developed for the Landfill and modified as necessary to expedite this task. Proper preparations will reduce the time required in the field by minimizing the number of trips to obtain additional supplies 3.1.1 Well Inspection At the beginning of each sampling event, the monitoring wells will be visually inspected for the items listed in the following table QUARTERLY WELL INSPECTION ITEMS Groundwater Monitoring Well Observations Yes No Comments 1. Are the protective monuments damaged? 2. Are the protective caps damaged or missing? 3. Are the locks rusted, damaged, or missing? i 4. Are the surface seals cracking or settling? 5. Are the casings cracked or damaged? 6. Are there any changes to top of casing elevations? i 3.1.2 Decontamination Any reusable, non -dedicated sampling equipment will be decontaminated between each sampling location to provide representative samples. Decontamination will be performed by scrubbing all equipment with an Alconox® or comparable solution, rinsing with tap water, followed by a final rinse with deionized or distilled water. All clean or unused sampling equipment will be handled by personnel wearing clean, new, disposable gloves constructed of appropriate material. i \14\1407882b\0400\0403 edop revl\appendix e\1407882b app e environmental monitoring plan revs 19feb16.docx GA\ Golder Associates February 2016 Appendix E 5 1407882B Rev. 1 3.1.3 Equipment All sampling equipment will be constructed of materials that will not alter the quality of the groundwater samples. Monitoring and sampling equipment will include some or all of the following: • Electronic water level indicator; • Field water quality meter capable of measuring pH, temperature, and specific conductance (i.e., conductivity); • Powder -free disposable gloves (nitrile or latex); ■ Deionized or distilled water; • Phosphate -free environmental detergent such as Alconox®; • Plastic sheeting to prevent possible contamination of sampling equipment; ■ Paper towels; • 5 -gallon plastic buckets for decontamination and purge volume measurement; • Low -flow sampling equipment, bladder pump, controlling unit, compressed gas, and discharge tubing; • Disposable bailers and rope; • Sample bottles and sample preservatives; • Field forms and/or field book, including piezometer purge/sampling forms, Chain -of -Custody forms, and sample labels; and • Coolers with ice. All of the monitoring and sampling equipment will be maintained in a clean and working condition. 3.2 Quality Assurance and Quality Control Proper quality control (QC) procedures will be followed so that laboratory preparation, sampling, and transport activities do not bias the results of the chemical analysis. QC samples provide a quantitative basis for validating the analytical data and consist of the following: Blind Duplicate Sample: Duplicate samples will be collected by the sampling personnel in a manner identical to the primary sample. The duplicate sample will be analyzed by the laboratory just as the primary sample is analyzed. The duplicate is intended to assess that the results from the primary sample are accurate and reproducible by the analytical laboratory. Field Blank: A field blank consists of empty sample bottles filled with deionized or distilled water by the field personnel at the sampling site. The field blank will also be analyzed by the laboratory as if it was a "real" sample. The primary purpose of the field blank is to evaluate possible cross -contamination of samples from the field (ambient) conditions that are present at the sampling location. Equipment Blank: An equipment field blank consists of empty sample bottles filled with deionized or distilled water that has been subjected to contact with decontaminated sampling equipment water at the 1114\1407882b\0400\0403 edop revl\appendix e\1407882b app e environmental monitoring plan revl 19feb16 docx f Golder Associates February 2016 Appendix E 6 1407882B Rev. 1 sample site. The equipment blank will also be analyzed by the laboratory as if it was a "real" sample and is intended to assess the effectiveness of field equipment decontamination procedures applied to reusable sampling equipment. Trip Blank for Volatile Organic Compounds (VOCs): A trip blank consists of empty sample bottles filled with deionized or distilled water prepared by the analytical laboratory. The trip blank will accompany the sample container shipment from the laboratory to the field and then back to the lab. At no time will the trip blank container be opened in the field. The trip blank will also be analyzed by the laboratory as if it was a "real" sample. The trip blank is intended to assess the cleanliness of laboratory analytical method and track any influences on VOC concentrations over the course of a sampling event. Based on the monitoring program, QC samples will consist of the following: • One trip blank per sampling cooler should be analyzed for each sampling event. • One equipment blank will be analyzed per event if non -disposable or non -dedicated equipment is used for sampling. An equipment blank is not necessary if dedicated or new sampling equipment is used at each location. ■ One other QC sample should be collected and analyzed per event. It is recommended the QC sample that is collected rotate between a blind duplicate and a field blank. 3.3 Groundwater Sampling Procedures At the start of every monitoring event, each well will be inspected prior to sampling. The condition of the casing, well pad, reference mark for water level measurements, protective casing, well identification markings, and security locks will be recorded. In the event the protective casing or locks show evidence of tampering, a description will be logged in the Operating Record and noted in the annual report submitted to CDPHE. Static water levels will be measured in all the groundwater monitoring network wells prior to the purging and sampling of any well. The water levels for all of the wells in the groundwater monitoring network will be measured on the same day. The water level measurements will be made from the reference mark on the top of the PVC or protective steel casing to the nearest 0.01 foot using a portable electronic water level indicator. These measurements will be compared in the field to previous measurements to check for consistency. A new pair of disposable gloves, of appropriate material, will be worn to minimize the potential of sample contamination. The water level indicator probe will be rinsed between wells using deionized water. If additional decontamination is deemed necessary, the probe will first be washed with an Alconox' '' or comparable solution, and then rinsed with deionized water. The volume of water standing in each well will be calculated using the static water level measurement, the total depth of the well, and the casing diameter. Well depths for the purpose of well volume determination r\14\1407882b10400\0403 edop revllappendix e\1407882b app e environmental monitonng plan revl 19feb16.docx Golder Associates February 2016 Appendix E 7 1407882B Rev. 1 will be obtained from well completion records or measured in the field. The equation for calculation of one casing volume is: V = [u x (rcasing)2 x h] x 7.48 where: V = volume of water in well casing (gallons) rcasing = radius of well casing (feet) h = height of water column (total well depth - depth to water) (feet) Casing volume information may be necessary for determining purge volumes when certain types of equipment are used as described in Section 3.3.1, below. 3.3.1 Purging If sampling is being conducted with bladder pumps, "low -flow" methodology will be used. "Low -flow" refers to the rate at which water is drawn into the pump, typically 0.1 to 0.5 liters per minute or approximately 0.025 to 0.125 gallons per minute (Puls and Barcelona 1995) and involves purging and sampling only across a small portion of the screened interval. During low -flow sampling, the static water level will be monitored with an electronic water level indicator. Pumping rates will need to be adjusted to limit drawdown when purging. The purged groundwater will be monitored for field parameters (temperature, pH, and specific conductance) using a portable field meter no fewer than three times before sample collection. The field parameters will be recorded during purging. Samples will be collected once field parameters have stabilized. Stabilization is considered to have occurred when there is less than ±10% change in consecutive measurements of temperature and specific conductance, and ±0.2 units change in consecutive measurements of pH. If low -flow bladder pumps are not being used, prior to sample collection, each well will be purged of stagnant water using disposable or dedicated bailers. Sample collection will begin when the field parameters have stabilized and at least three casing volumes have been purged. Alternatively for wells with slow recovery, purging will continue until the well is dry. Field parameters will be measured at a minimum frequency of once per casing volume when using the three -casing -volume method. All field parameter values will be recorded on a field data sheet or in a dedicated field book, along with a description of the sample appearance at the time of field parameter measurement. Meters used to measure field parameters will be calibrated according to manufacturer's recommendations. Purge water generated during the purging will be discharged on the ground near the well site. 3.3.2 Sample Withdrawal After well purging is completed, field personnel will don a new pair of disposable gloves in preparation for sample collection. Groundwater samples will be collected directly from either the discharge end of the \14\1407882b\040010403 edop revl\appendix e\1407882b app e environmental monitoring plan revl 19feb16 docx Golder Associates February 2016 Appendix E 8 1407882B Rev. 1 pump tubing or from the bottom valve of the bailer. If the well is purged dry, sample collection will begin when a sufficient amount of groundwater has entered the well, which may be several days after purging. To avoid agitation and loss of VOCs, the maximum pumping rate for sample collection using pumps will be less than or equal to 100 milliliters per minute (mL/min). The order of sample collection will be based on parameter sensitivity to volatilization and pH change, as follows: ■ VOCs ■ Oil and grease • Total organic carbon (TOC) • Total metals • Other inorganics • Radionuclides Field parameters will be measured again after sample collection is complete, if possible. Some low -yield wells may produce insufficient volume of water to fill all of the sample containers. Sample containers for these wells will be filled in the order listed above until the sample volume is depleted. Filled bottles will be submitted to the laboratory for limited analysis. VOC samples will be collected in 40-m1 glass vials, while metals, TOC, and other inorganic samples will be collected in either plastic or glass containers of appropriate capacity. Sample containers will be provided by the analytical laboratory and will be pre -cleaned so they will not require rinsing before filling. Every effort will be made to reduce contact between the bottles and sampling equipment. As an added precaution, contact time of the sample with ambient air will be minimized by replacing caps immediately after the bottles are filled. VOC samples will be collected without air bubbles. This will be achieved by adding sample slowly until a positive meniscus forms at the mouth of the vial (i.e., the vial is slightly overfilled) before replacing the cap. Once the cap is firmly attached, the vial will be inverted and examined for air bubbles. Following completion of groundwater sampling at each monitoring well, all non -dedicated sampling equipment will be decontaminated in accordance with the procedures specified above in Section 3.1.1. 3.3.3 Sample Preservation and Shipment Preservatives will either be attached to the sample containers in small vials or will be pre -added to the containers in the laboratory. If they are attached to the sample containers, sampling personnel will add the specified volume of preservative to the container immediately before sampling. VOC samples will be unpreserved, in accordance with the CDPHE Groundwater VOC Sample Preservation Policy (CDPHE 1998). Sample filtration, where required, will be conducted in the field with a new disposable 0.45 micrometer filter for each sample. i \14\1407882b\0400\0403 edop revl\appendix e\1407882b app e environmental monitoring plan revl 19feb16 docx Golder Associates February 2016 Appendix E 9 1407882B Rev. 1 Filled and capped containers will be wiped clean with paper towels, appropriately labeled, and stored with frozen ice packs or bagged ice in insulated coolers. Sufficient ice will be added to the coolers to maintain sample temperatures at or below 4°C. Packing material will be added to the coolers as necessary to prevent breakage of glass containers. Samples will be submitted to the analytical laboratory either by an overnight courier (such as FedEx) or delivered by the sampling personnel, depending on the lab location, no later than the day following sample collection in order to expedite the analysis and meet EPA - recommended sample hold times. 3.4 Leachate Sampling Procedures Leachate will be sampled from each constructed leachate sump at least annually. Samples will be collected using either the dedicated leachate pump or a bailer. 3.4.1 Sample Withdrawal Field personnel will don a new pair of disposable gloves in preparation for sample collection. If a particular sump is dry and a sample cannot be collected, the sump will checked for the presence of liquid during the next monitoring event. The order of sample collection will be based on parameter sensitivity to volatilization and pH change, as follows: • VOCs • Oil and grease • Total organic carbon (TOC) • Total metals • Other inorganics • Radionuclides Filled bottles will be submitted to the laboratory for limited analysis. VOC samples will be collected in 40-m1 glass vials, while metals, TOC, and other inorganic samples will be collected in either plastic or glass containers of appropriate capacity. Sample containers will be provided by the analytical laboratory and will be pre -cleaned so they will not require rinsing before filling. Every effort will be made to reduce contact between the bottles and sampling equipment. As an added precaution, contact time of the sample with ambient air will be minimized by replacing caps immediately after the bottles are filled. VOC samples will be collected without air bubbles. This will be achieved by adding sample slowly until a positive meniscus forms at the mouth of the vial (i.e., the vial is slightly overfilled) before replacing the cap. Once the cap is firmly attached, the vial will be inverted and examined for air bubbles. Following completion of leachate sampling, all non -dedicated sampling equipment will be decontaminated in accordance with the procedures specified above in Section 3.1.1. \14\1407882b\0400\0403 edop revl\appendix e\1407882b app e environmental monitoring plan rev1 19feb16 docx Golder Associates February 2016 Appendix E 10 1407882B Rev. 1 3.4.2 Sample Preservation and Shipment Preservatives will either be attached to the sample containers in small vials or will be pre -added to the containers in the laboratory. If they are attached to the sample containers, sampling personnel will add the specified volume of preservative to the container immediately before sampling. VOC samples will be unpreserved, in accordance with the CDPHE Groundwater VOC Sample Preservation Policy (CDPHE 1998). Sample filtration, where required, will be conducted in the field with a new disposable 0.45 -micrometer filter for each sample. Filled and capped containers will be wiped clean with paper towels, appropriately labeled, and stored with frozen ice packs or bagged ice in insulated coolers. Sufficient ice will be added to the coolers to maintain sample temperatures at or below 4°C. Packing material will be added to the coolers as necessary to prevent breakage of glass containers. Samples will be submitted to the analytical laboratory either by an overnight courier (such as FedEx®) or delivered by the sampling personnel, depending on the lab location, no later than the day following sample collection in order to expedite the analysis and meet USEPA-recommended sample hold times. 3.5 Chain -of -Custody Control EPA -accepted chain -of -custody (COC) procedures will be followed to maintain the integrity of the samples. From the time the sample containers leave the laboratory until the issuing of final laboratory results, the samples and/or sample containers will be: • In sight of the assigned custodian; or • Locked in a tamper -proof location; or • Sealed with a tamper -proof seal. A written record of sample container possession and transference of samples will be documented on appropriate COC forms. The COC will include the name of the person or persons performing the sample collection and will indicate the method of delivery to the laboratory (e.g., FedEx®, driven by sampling personnel, etc.). A copy of the COC will be sealed in a Ziplac' bag, placed in the cooler containing the containers listed on the COC, and shipped/delivered with the samples to the laboratory. 3.6 Documentation Where applicable, the following information will be recorded on a sampling or monitoring data sheet or in a field notebook for each groundwater sampling location: • Observations made during the visual inspection of the monitoring well; • Weather conditions at the time of purging and sampling; • Static water level and total well depth; • Purge method, volume, purge rate, and stabilization chemical parameters; \14\1407882b\0400\0403 edop rev1\appendix e\1407882b app e environmental monitoring plan rev1 19feb16 docx Golder Associates February 2016 Appendix E 11 1407882B Rev. 1 • Field parameters associated with the sample and sample appearance; • Date and time of purging and sampling; and • Other observations such as sample equipment malfunctions or conditions that could affect sample chemistry. i \14\1407882b\0400\0403 edop rev1\appendix e\1407882b app e environmental monitoring plan revs 19feb16 docx Golder Associates rloil. Iiift- February 2016 Appendix E 12 1407882B Rev. 1 4.0 Detection Monitoring Program Initially the detection monitoring will be conducted on a quarterly basis to establish baseline (i.e., background). In accordance with the proposed statistical analysis program (Section 4.3), baseline will be established after the completion of 8 to 10 quarterly monitoring events. Following the initial baseline statistical analysis and the commencement of waste placement, the frequency of detection monitoring will be reduced to a semi-annual basis. Should the decision to allow semi-annual groundwater monitoring change for any reason in the future, the Division will notify the facility in writing of that decision. Semi-annual detection monitoring will only be required in those monitoring wells that are considered proximate (i.e.. downgradient/cross-gradient and within 150 meters) to areas of waste placement. The detection monitoring program is described in additional detail below. 4.1 Detection Monitoring Constituents The water samples collected will be analyzed for the constituents listed in Table E-2. The analyte list consists of constituents listed in Appendix 1A and 1B of the Regulations, as well as groundwater constituents from Table 910-1 of the COGCC 900 Series rules for exploration and production (E&P) waste management, and relevant radionuclides. In the future, the analyte list may be revised to account for site -specific conditions based on monitoring results for the leachate (i.e., parameters are not detected or below maximum contaminant levels [MCLs]), if approved by the CDPHE. Constituents will be measured in accordance with EPA Report SW -846 "Test Methods for Evaluating Solid Waste," which includes Method 8260 for organics and Method 6010 or a method from the 7000 Series for inorganics (EPA 2007). Practical quantitation limits (PQLs) for the parameters analyzed will be the lowest concentrations that can be reliably achieved within the specified limits of precision and accuracy during routine laboratory operating conditions. Instrument detection limits will be required to be kept at or below the PQLs. 4.2 Analytical Data Review Upon receipt of the analytical results, general analytical data evaluation (i.e., data validation) will be performed. At a minimum, this evaluation will address the following: • Overall data completeness; • A review of laboratory qualified data; • Comparison of field duplicate results to original sample results; • Comparison of method and equipment blank results to sample results; • Confirmation that reporting limits are below MCLs; • Review of data accuracy based on cation -anion balances, etc.; and • Review of laboratory QA/QC sample results including comparison of spike recoveries to control limits. Results of the data review will be documented, and, if necessary, used to initiate additional review by the laboratory or possible addition of qualifiers of the analytical data by the reviewer. i \14\1407882b10400\0404 edop rev2\appendix e\1407882b app e environmental monitoring plan rev1 19feb16 docx Golder Associates February 2016 Appendix E 13 1407882B Rev. 1 4.3 Statistical Analysis The purpose of groundwater monitoring at the Landfill is to determine if on -site wastes are impacting the groundwater. In order to determine if an impact has occurred, baseline and more recent groundwater data from each well will undergo a statistical analysis. The statistical plan for the Facility's groundwater analytical data is described in more detail in Appendix E-1. The proposed statistical analysis program will begin by establishing baseline statistical limits as outlined in Appendix E-1. The initial baseline statistical analysis will be conducted after 8 to 10 sampling events have been completed at the Facility. Future semi-annual groundwater monitoring results will be compared to these statistical limits. The comparative statistical analysis program will consist of reviewing/recalculating the statistical limits annually, but for the interim monitoring events, a simple comparison of the new data to the statistical limits will identify whether any concentrations are potentially statistically significant. Additionally, the baseline data will be reviewed periodically (approximately every three years) to determine if recent results, that are not statistically significant, can be incorporated into an updated baseline period. 4.4 Notification After each monitoring event. a comparative statistical analysis will be conducted. For this comparison, the new data will be compared to the current statistical limit to identify whether a concentration is statistically significant. The CDPHE will be notified of any statistically significant increases (SSIs) within 14 days after the completion of the comparison and data review, including any data quality review necessary to address questions concerning the validity of sampling or laboratory analyses. An SSI will not be considered a verified exceedance until confirmatory re -sampling is performed during the next scheduled sampling event and an annual comparative statistical analysis is conducted. \14\1407882b\0400\0403 edop revl\appendix e\1407882b app e environmental monitoring plan rev1 19feb16 docx Golder Associates February 2016 Appendix E 14 1407882B Rev. 1 5.0 REPORTING An annual monitoring report will be prepared and submitted to the CDPHE by April 1 of the following year. The annual report will include the following information: • Facility map with monitor well locations; • Evaluation of groundwater elevation and flow direction, including whether there have been any significant changes observed; • Field information notes or forms; • Summary of groundwater monitoring activities; • Finalized analytical laboratory reports, including COC forms and laboratory QA/QC data; • Groundwater analytical data in a tabulated format; and • Stiff diagrams. After the initial baseline period, the annual report will also include: • Comparative statistical analysis of the semi-annual data; and • If conducted, a description of the new or revised baseline statistical analysis. i \14\1407882b\0400\0403 edop rev1\appendix e\1407882b app e environmental monitoring plan revl 19feb16 docx Golder Associates February 2016 Appendix E 15 1407882B Rev. 1 6.0 ASSESSMENT MONITORING An assessment monitoring program will be required in the event of a verified SSI over established background levels for one or more of the constituents listed in Table E-2, unless Pawnee makes a successful demonstration of an alternate source for the groundwater contamination or that the statistically significant increase resulted from error in sampling, analysis, statistical evaluation, or natural variation in groundwater quality. The assessment monitoring program would be implemented consistent with the requirements of Appendix B Section B5 of 6 CCR 1007-2, Part 1. i.\14\1407882b\0400\0403 edop revl\appendix e\1407882b app e environmental monitoring plan rev1 19feb16 docx Golder Associates February 2016 Appendix E 16 1407882B Rev. 1 7.0 ASSESSMENT OF CORRECTIVE MEASURES If, within 90 days of detecting one or more Appendix II constituents (or the list approved in accordance with 40 CFR 258.55(C)) at statistically significant levels above the background concentrations, a successful demonstration has not been made to indicate that a source other than the Landfill caused the contamination, or that the SSI resulted from error in sampling, analysis, statistical evaluation, or natural variation in groundwater quality, an assessment of corrective measures will be initiated, as described in Appendix B6 of the Regulations, and completed within a reasonable amount of time as determined by the CDPHE. i \14\1407882b\0400\0403 edop revl\appendix e\1407882b app e environmental monitoring plan revl 19feb16 docx Golder Associates February 2016 Appendix E 17 1407882B Rev. 1 8,0 References ASTM International. 2005. Standard Guide for Developing Appropriate Statistical Approaches for Ground - Water Detection Monitoring Programs (D6312-98(2005)). Conshohocken, PA: ASTM International. Colorado Department of Public Health and Environment (CDPHE). 1998. Groundwater VOC Sample Preservation Policy. June 22, 1998. Puls, R.W. and M.J. Barcelona. 1995. Low -Flow (Minimal Drawdown) Ground -water Sampling Procedures. USEPA Ground Water Issues Report, EPA/540/5-95/504. Ada, Oklahoma : United States Environmental Protection Agency (USEPA). 2007. Test Methods for Evaluating Solid Waste, Physical/Chemical Methods (SW -846) Revision 6. February 2007. Available online: http://www.epa.gov/epawaste/hazard/testmethods/sw846/online/index. htm#table (accessed December 11, 2014) USEPA. 2009. Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities Unified Guidance. Available online: http://www.epa.gov/osw/hazard/correctiveaction/resources/guidance/sitechar/qwstats/unified-guid.pdf (accessed November 24, 2014). i \14\1407882b\0400\0403 edop revl\appendix e\1407882b app e environmental monitonng plan revl 19feb16 docx Golder Associates February 2016 TABLE E-1 MONITORING WELL CONSTRUCTION SUMMARY 1407882B Rev. 1 Monitoring Well ID Date Completed Easting (ft)(" Northing (ft)(') Total Depth of Borehole (ft bgs) Borehole Diameter (inches) Bottom of Casing (ft bgs) Top of Screen (ft bgs) Bottom of Screen (ft bgs) Top of Sand Pack (ft bgs) Bottom of Sand Pack (ft bgs) Ground Elevation (ft AMSL) Top of Casing Elevation (ft AMSL) Casing Stick-up Height (ft)(2) Water Level(3) (ft BTOC) (ft Water Level Elevation AMSL) MW -2014-01 10/18/2014 3375508.68 1552334.34 85.2 8 85.2 75.2 84.6 72.1 85.2 5091.29 5094.02 2.73 73.02 5021.00 MW -2014-02A 10/23/2011 3372060.75 1551800.20 58.8 8 58.8 • 48.7 58.3 46.5 58.8 5070.90 5073.66 2.76 53,53 5020.16 MW -2014-03 I 10/17/2014 a 3373494.23 1550228.01 50.5 e 8 50.5 45.3 50.0 42.2 50.5 5065.04 5067.73 2.69 47.31 5020.42 MW -2014-04 r 10/16/2014 i 3372813.54 1551042.63 59.0 8 ,,57.4 - 47.3 57.0 44.9 58.8 5066.83 5069.55 2.72 49.21 5020.34 MW -2016-05 TBD 2016 I MW -2016-06 TBD 2016 Notes: 1) Each datum is from Colorado State Plane NAVD 88. 2) Stick-up height refers to the height of the PVC well casing above ground surface. 3) Water levels measured by Golder Associates Inc. on October 27, 2014. ft bgs: feet below ground surface ft AMSL: feet above mean sea -level ft BTOC: feet below top of casing I \14\1407882B\0400\0403 EDOP REV1Wppendix E\Tables182 19FEB16 xlsxTablel Colder Associates July 2015 TABLE E-2 ANALYTE LIST Group Analyte CAS Recommended Laboratory Analytic Method(') COGCC(1)Oil and Grease 1664 Total dissolved solids SM 2040 APPENDIX IA GENERAL GROUND WATER QUALITY INDICATOR PARAMETERS v, o iii U Magnesium 7439-95-4 6010/6020 Sodium 7440-23-5 6010/6020 Potassium 7440-09-7 6010/6020 Calcium 7440-70-2 6010/6020 o E Carbonate SM 2320 Bicarbonate SM 2320 Chlonde(2) 16887-00-6 9056A Sulfate(?) 14808-79-8 9056A Nitrite 14797-65-0 9056A Nitrate 14797-55-8 9056A l a ap °' E n pH NA Specific conductivity NA Temperature NA Additional Laboratory Parameters Total organic carbon 9060 pH 9040 Specific conductivity SM 2510 Ion Balance NA APPENDIX IB INORGANIC CONSTITUENTS Total Metals Antimony 7440-36-0 6010/6020 Arsenic 7440-38-2 6010/6020 Banum 7440-39-3 6010/6020 Beryllium 7440-41-7 6010/6020 Cadmium '7440-43-9 6010/6020 Chromium 7440-47-3 6010/6020 Cobalt 7440-48-4 6010/6020 Copper 7440-50-8 6010/6020 Lead 7439-92-1 6010/6020 Nickel 7440-02-0 6010/6020 Selenium 7782-49-2 6010/6020 Silver 7440-22-4 6010/6020 Thallium 7440-28-0 6010/6020 Vanadium 7440-62-2 6010/6020 Zinc 7440-66-6 6010/6020 ORGANIC CONSTITUENTS Acetone 67-64-1 8260 Acrylonitrile 107-13-1 8260 Benzene(2) 71-43-2 8260 Bromochloromethane 74-97-5 8260 Bromodichloromethane 75-27-4 8260 Bromoform, tribromomethane 75-25-2 8260 Carbon disulfide 75-15-0 8260 Carbon tetrachloride 56-23-5 8260 Chlorobenzene 108-90-7 8260 Chloroethane; ethyl chloride 75-00-3 8260 Chloroform; trichloromethane 67-66-3 8260 Dibromochloromethane, chlorodibromomethane 124-48-1 8260 1,2-dibromo-3-chloropropane, dbcp 96-12-8 8260 1,2-dibromoethane; ethylene dibromide, edb '106-93-4 8260 O-dichlorobenzene; 1,2-dichlorobenzene 95-50-1 8260 P-dichlorobenzene; 1,4-dichlorobenzene 106-46-7 8260 Trans-1,4-dichloro-2-butene 110-57-6 8260 1,1-dichloroethane; ethylidene chloride 75-34-3 8260 1,2-dichloroethane; ethylene dichloride 107-06-2 8260 1,1-dichloroethylene, 1,1-dichloroethene; vinyliden chloride 75-35-4 8260 Cis-1.2-dichloroethylene, cis-1,2-dichloroethene 156-59-2 8260 Trans-1,2-dichloroethylene; trans-1,2-dichloroethene 156-60-5 8260 1,2-dichloropropane; propylene dichloride 78-87-5 8260 Cis-1,3-dichloropropene 10061-01-5 8260 Trans-1,3-dichloropropene 10061-02-6 8260 Ethylbenzene(2) 100-41-4 8260 2-hexanone; methyl butyl ketone 591-78-6 8260 Methyl bromide; bromomethane 74-83-9 8260 Methyl chloride; chloromethane 74-87-3 8260 Methylene bromide; dibromomethane 74-95-3 8260 Methylene chloride; dichloromethane 75-09-2 8260 Methyl ethyl ketone; mek, 2-butanone 78-93-3 8260 Methyl iodide; iodomethane 74-88-4 8260 -methyl-2-pentanone; methyl isobutyl ketone 108-10-1 8260 Styrene 100-42-5 8260 1.1.1,2-tetrachloroethane 630-20-6 8260 1.1,2.2-tetrachloroethane 79-34-5 8260 Tetrachloroethylene; tetrachloroethene perchloroethylene 127-18-4 8260 Toluene(2) 108-88-3 8260 1,1,1-trichloroethane; methylchloroform 71-55-6 8260 1,1,2-tnchloroethane 79-00-5 8260 Tnchloroethylene; tnchloroethene 79-01-6 8260 Tnchlorofluoromethane. cfc-11 75-69-4 8260 1.2.3-tnchloropropane 96-18-4 8260 Vinyl acetate 108-05-4 8260 Vinyl chloride 75-01-4 8260 Xylenest21 1330-20-7 8260 v7 w o J o Z O cc Radium -226 13982-63-3 EPA 901 1 Radium -228 15262-20-1 EPA 901 1 Natural Thorium 14274-82-9 14269-63-7 7440- 29-1 HSL-300 Natural Uranium 13966-29-5 15117-96-1 HSL-300 Notes: 1) COGCC. Colorado Oil and Gas Conservation Commission Table 910-1 2) Parameter on both COGCC Table 910-1 and CDPHE Solid Waste Regulations Appendix 1A or Appendix 1B 3) Altemate method from SW -846 may be substituted NA Not applicable 14178828 !!4V 40711828504005002 EDOP FNl MpoO+m E\ noes%T *bet! 62 .ut5 nix teole Golder Associates I N 1 552 000 I • N1551500• • • • 1 I • • I N 1 551 000 j I I I 1 N 1 550 500 • i1 • • • • • • I N 1 550 000 I I N 1 549 500 I I I I I f - as. air ea•-aa• W W m 8W O m W 'a REV B ..--e-.. =e -a-.----. e----.--..-eea..-.--.e-.- N MW -2014-02A) REV B MW -2014-04 rn QS) (5 MW-2014-03---/ h I(a I"' W W VW Wvv NQN iJ v V a rn W Np' m u? .ti r. CD m 53 PROPOSED E&P LANDFILL AREA —' //1 -- (APPROXIMATELY 74 ACRES) / Irn W W a B 2016-02.19 ADDRESS CDPHE TECHNICAL EDOP COMMENTS DATED JANUARY 28. 2016 A 2015.07.16 ISSUED FOR CDPHE EDOP SUBMITTAL kr/ YYY l MM DC) DE SCRIP TION CAI CE TB JAR CKB CETB SH JMP MAY PREPARED DESIGN REVIEW APPROVED Cr PZ-2014-01A rn W W a O • • • • • • MW -2014-01 • • 1 u5 • • I I I I I N 1 552 000 N 1 551 503 IN 1 551 000 • • • I I I I . I N 1 550. 500 • I I I IN 1 550 000 N 1 549 500 LEGEND ,:r t.; EXISTING TOPOGRAPHY (SEE NOTE 1) 5090 0- GROUNDWATER CONTOUR/ELEVATION (SEE NOTE 2) asap amase, Os MW -2014-03 PROPOSED USE BY SPECIAL REVIEW (USR) BOUNDARY PROPOSED ESP LANDFILL AREA BOUNDARY GROUNDWATER MONITORING WELL PZ-2014-01A PIEZOMETER (GROUNDWATER ELEVATION MEASUREMENT ONLY) PROPOSED -MW-06 PROPOSED GROUNDWATER MONITORING WELL NOTES 1 EXISTING GROUND TOPOGRAPHY PROVIDED BY CLARK LAND SURVEYING, INC. FROM FIELD SURVEY PERFORMED IN OCTOBER 2014 2 GROUNDWATER CONTOURS INTERPOLATED BASED ON WATER LEVEL DATA COLLECTED IN OCTOBER 2014 ClItN1 PAWNEE WASTE LLC CONSUL TANT ass DENVER OFFICE 44 UNION BLVD. STE. 300 LAKE WOOO, COLORADO USA 14.11(303) 980 0540 www.golder corn 0 200 400 SCALE FEET PROJECT PAWNEE WASTE E&P LANDFILL WELD COUNTY, COLORADO 111.E SITE LAYOUT AND SAMPLING LOCATIONS PROJEL. r CONTROL 1407882B R001 1 1 B F I UUHt E-1 J v CO A world of capabilities delivered locally APPENDIX E-1 STATISTICAL ANALYSIS PLAN Pawnee Waste E&P Landfill Weld County, Colorado Prepared for: Pawnee Waste LLC 3003 E. Harmony Suite 300 Fort Collins, CO 80528 Prepared by: Golder Associates Inc. 44 Union Boulevard, Suite 300 Lakewood, CO 80228 July 23, 2015 1407882B Revision 1 - November 16, 2017 Golder Associates Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation November 2017 Appendix E-1 1407882B Rev. 1 Table of Contents 1.0 INTRODUCTION 1 1.1 Approach 1 2.0 BASELINE STATISTICAL ANALYSIS 2 3.0 COMPARATIVE STATISTICAL ANALYSIS 5 4.0 REFERENCES 6 I \14\1407882b\0400\0408 edop rev5\app e-1 sap revl 16nov17 docx Golder Associates November 2017 Appendix E-1 1 1407882B Rev. 1 1.0 INTRODUCTION This plan has been prepared by Golder Associates Inc. (Golder) and details the statistical analysis program for the proposed Pawnee Waste LLC (Pawnee) E&P Landfill (Landfill or Facility) in Weld County, Colorado. This statistical analysis plan has been developed for the detection monitoring program at the Facility. The statistical methodology outlined below was selected in accordance with the Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities, Unified Guidance (USEPA 2009), with additional guidance from the American Society for Testing and Materials (ASTM) Standard Guide for Developing Appropriate Statistical Approaches for Ground -Water Detection Monitoring Programs (ASTM D6312 1998). For the statistical analysis, WQStat Plus (Sanitas Technologies 2009) or similar statistical analysis software will be used. This plan has been organized into four sections, including this introduction. Section 2 outlines the procedures for the initial baseline (i.e., background) statistical analysis and periodically updating the baseline period. Section 3 discusses the protocol for the comparative statistical analysis and reporting. Section 4 includes a list of references for this document. 1.1 Approach Statistical analysis for this Facility will not include upgradient—downgradient comparisons (i.e., inter -well comparisons). Instead, data from each well will be considered individually and more recent analytical results will be statistically compared to the previous results from the well. This is referred to as the intra-well method. The initial baseline statistical analysis will be conducted after 8 to 10 sampling events have occurred at the Facility. Statistical analysis will not be conducted on any field parameters. There is a high potential for false positive results with field measurements because of the sample collection inconsistency (e.g., changes in field conditions and sampling personnel), equipment calibration variability, and other causes of measurement variation. Additionally, baseline statistics will not be conducted on volatile organic compounds (VOCs) or oil and grease. A statistically significant increase (SSI) for a VOC or oil and grease is therefore regarded as any detection that is above the practical quantitation limit (PQL). r\14\1407882b\0400\0408 edop rev5\app e-1 sap rev1 16nov17.docx Golder Associates November 2017 Appendix E-1 2 1407882B Rev. 1 2.0 BASELINE STATISTICAL ANALYSIS Baseline statistical limits for each inorganic analyte using the intra-well method will be determined by the step -based approach detailed below. Step 1: Step 2: Step 3: Step 4: Step 5: ■ All data will be compiled in a database and graphed in time -series and/or box plots to visualize any temporal variability of the data, and to screen for outliers in the dataset. Occasionally, analytical values for a specific parameter at a specific well are not consistent with the remainder of the data. These inconsistent values, or outliers, may be excluded from the dataset used for statistical analysis, as outlined in Step 7. ■ The detection frequency will be determined for each parameter. Estimated values between the method detection limit (MDL) and the PQLs that are reported by the laboratory will be used in the analysis. ■ When the detection frequency is greater than 25%, non -detected values will either be treated with a Cohen's adjustment or substituted with appropriate values consistent with statistical guidelines. When the detection frequency is less than 25%, adjustments or substitutions for the non -detected values will not be conducted. ■ If the detection frequency of the analyte is greater than 25%, further steps (described below) will be conducted. ■ If the detection frequency is less than 25%, this will be the final step and a statistical limit will be set by: • Inspection of the time -series and/or box plots for outliers, which will be removed as outlined in Step 6. • A non -parametric prediction limit of the highest detected value or the highest practical PQL, whichever is greater, will be set. ■ Prediction limits, which are the main statistical methodology proposed below, assume that concentration distributions are stationary over time and are therefore not appropriate when temporal trends are present. Tests for seasonal and directional trends (at a 95% confidence level) will be conducted on each constituent. If trends are present in the dataset, the data will be adjusted to account for the trends (e.g., removal of seasonal trends), the time period used for the baseline will be reassessed, or an alternative statistical method will be used. Occasionally, it may be possible that no adjustments or alternative methods are appropriate and it may not be appropriate to consider a particular analyte for statistical analysis. i \14\1407882b\0400\0408 edop rev5\app e-1 sap revl 16nov17 docx Golder Associates Step 6: November 2017 Appendix E-1 3 1407882B Rev. 1 Step 7: Step 8: ■ A Rosner's test (when there are greater than 25 samples) or Dixon's Q test for outliers will be conducted to check for any abnormally high or low concentrations in the dataset. These statistical outlier tests assume that all data values, except the suspect observation, are normally distributed or can be transformed to fit a normal distribution. Therefore, visual inspection of concentrations over time is also important in screening for outliers. The results of the statistical test will be considered when removing any outlier from the dataset in conjunction with time -series and/or box plots to visualize any temporal variability of the data. Any suspected outlier identified by the statistical tests or visual methods will be reviewed before removal from the dataset and the rationale for the removal of any outliers will be documented. Golder anticipates that the majority of the outliers will be isolated values that can be attributed to: 1. inconsistent sampling or analytical chemistry methodology resulting in laboratory contamination or other anomalies; and 2. errors in the transcription of data values or decimal points. The effect of removing outliers from the baseline data will usually be to lower the statistical limits, thus improving the odds of detecting upward changes in concentration levels. ■ A Shapiro-Wilk's test for normality or similar, will be conducted on the data (using a 95% confidence level) to check the data distribution. Most parametric statistical tests are based on the assumption that the data are normally distributed or can be transformed to a normal distribution. If necessary and where possible, transformations of the data (log -normal or ladder of powers) will be performed. If the data is normal or can be transformed to be normal, further steps will be conducted. ■ If the data does not fit a normal distribution or cannot be transformed to fit a normal distribution, this will be the final step and a statistical limit will be set by: • Inspection of the time -series and/or box plots for outliers, which will be removed as outlined in Step 6. • A non -parametric prediction limit of the highest detected value or the highest PQL, whichever is greater, will be set. For pH, a two -tailed non -parametric limit will be set at the highest and lowest detected value. ■ A parametric prediction methodology will be used to establish a statistical limit. For pH, a two -tailed parametric test will be used to set the baseline values. Parametric prediction limits will be calculated using a 95% confidence level and are related to the number of recent (non -baseline or compliance) data. Therefore, parametric prediction limits may change slightly from one monitoring event to the next. The baseline statistical period should be periodically re-evaluated and potentially updated. To reduce the number of false positive and false negative results and increase statistical power in future comparative statistical analyses, the dataset (number of samples) used to represent the baseline period should reflect changes in conditions at the site. Updating is recommended when enough new measurements have been \14\1407882b\040010408 edop rev5\app e-1 sap rev1 16nov17.docx Golder Associates November 2017 Appendix E-1 4 1407882B Rev. 1 collected to allow for statistical comparison between the existing baseline data and a potential set of newer data. Therefore, updating should be performed after every four to eight sampling events, or approximately every three years with semi-annual sampling. The Unified Guidance (USEPA 2009) cautions against updating more frequently since adding new sampling points to the dataset more frequently does not allow a statistical evaluation of whether the baseline is stationary over time. Additionally, adding data to the baseline every one or two sampling events, and without conducting a comparison of means (or medians), can introduce subtle trends and reduce the statistical power of the comparative statistical analysis. The Wilcoxon Rank -Sum test, also known as the Mann -Whitney test, determines if measurements from one population are significantly higher or lower than another population. This test is non -parametric, meaning that it does not assume that the data fit a specific distribution, such as a normal distribution. When the baseline period is updated in the future, the Wilcoxon Rank -Sum test will be used to compare data from the current baseline period with the more recent data that are intended to be reclassified and included in the updated baseline period. The test will be conducted at the 95% confidence level. If these two data populations are drawn from the same median, then the results of the test support updating the previous baseline dataset with the recent data. After the new data is incorporated into the dataset, the baseline statistical analysis outlined above will be conducted. If the Wilcoxon Rank -Sum test detects a significant difference between the two sample populations, additional data review will be necessary. The data will be reviewed to determine whether a gradual trend or other change has occurred that was missed by the comparative statistical analysis. It may be necessary to delete some of the earlier baseline data from the updated baseline period to ensure that future statistical analysis is based on current groundwater conditions at the site and not on outdated measures of groundwater chemistry. I \14\1407882b\0400\0408 edop rev5\app e-1 sap rev1 16nov17 docx Golder Associates November 2017 Appendix E-1 5 1407882B Rev. 1 3.0 COMPARATIVE STATISTICAL ANALYSIS After the baseline statistical analysis has been completed, comparative statistical analysis will be conducted after each semi-annual monitoring event. The following definitions will be used in discussion of the comparative statistical analysis: ■ SSI — is a statistically significant increase and is defined as an analytical result that exceeds the prediction limit established by the baseline statistical analysis. For volatile organic compounds, any detection above the PQL is regarded as an SSI. ■ False -positive SSI — is defined as an analytical result exceeding the Prediction Limit that can clearly be attributed to laboratory error, changes in analytical precision, or is invalidated through confirmatory re -sampling. ■ Confirmatory re -sampling — is designated as the next scheduled semi-annual event. ■ Verified exceedance — is interpreted as two consecutive SSIs for the same constituent for the same well. Both the original sample and the confirmatory sample are considered verified exceedances. For this analysis, the new data will be compared to the current statistical limit. When the statistical limit is exceeded, the data value will be identified as statistically significant. The CDPHE will be notified of any SSTs within 14 days after the completion of the comparison and sample analyses, including any data quality review necessary to address questions concerning the validity of sampling or laboratory analyses. An SSI will not be considered a verified exceedance until confirmatory re -sampling is performed during the next scheduled sampling event and an annual comparative statistical analysis is conducted. If a parametric prediction limit was set in the baseline period, the parametric test will be re -run annually with the most recent values set as "future" results. A discussion of the comparative statistical analysis will be included in the annual monitoring report. I \14\1407882b\0400\0408 edop rev5\app e-1 sap rev1 16nov17 docx Golder Associates November 2017 Appendix E-1 6 1407882B Rev. 1 4.0 REFERENCES American Public Health Association (APHA). 2005. Standard Methods of Water and Wastewater. 21st ed. American Public Health Association, American Water Works Association, Water Environment Federation publication. APHA, Washington D.C. ASTM International. 2005. Standard Guide for Developing Appropriate Statistical Approaches for Ground - Water Detection Monitoring Programs (D6312-98(2005)). Conshohocken, PA: ASTM International. Sanitas Technologies. 2009. WQStat Plus User's Guide, Version 9. United States Environmental Protection Agency (USEPA). 2009. Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities —Unified Guidance, Available online: http://www.epa.gov/epawaste/hazard/correctiveaction/resources/guidance/sitechar/gwstats/index. htm (accessed November 4, 2010). I \14\1407882b\0400\0408 edop rev5\app e-1 sap rev1 16nov17 docx Golder Associates Depth (ft) Elevation (ft) MONITORING WELL CONSTRUCTION SUMMARY Site Location Pawnee Waste Well No MW -1 I + 2 73 5094 0 Project Number 140-7882A Boring No X -Ref MW -2014-01 5091 3 Survey Coordinates E 3374729 63 Elevation Ground Level 5091 3 ft CO State Plane N 1551976 06 Top of Casing 5094 0 ft 3 20 I._. r,o if "' 5088 1 Drilling Summary Total Depth 85 21 ft Construction Time Start Log Finish Borehole Diameter 8 in Task Date Time Date Time Casing Stickup Height 2 73 ft Install PVC 10/18 1627 10/18 1629 Driller Site Services - Josh Anderson Pour Sand 10/18 1635 10/18 1710 Bentonite Seal 10/18 1713 10/18 1820 Hydrate Seal 10/18 1820 10/19 816 Rig CME 55 Bentonite Seal 10/19 816 10/19 849 Bits(s) 8 inch 4 -tooth carbide cutterhead Surface Comp 10/19 1009 10/19 1025 Drilling Fluid none Protective Casing 4 inch locking square steel Well Design and Specifications Casing String(s) C = Casing, S = Screen Depth String(s) Elevation + 2 73 - 75 2 C-1 5094 0 - 5016 1 Well Development 72 08 - Lie `; _ _ 5019 2 75 2 — 84 6 S 5016 1 - 5006 7 Depth to water initial N/A final N/A 0 0 - 85 2 C-2 5091 3 5006 1 See separate well development sheet - - - - ClStabilization Casing- Onoflex 2 -inch Sch 40 flush - threaded PVC Test Data Time pH Spec Cond I Temp ( C) 1 C2 N/A See separate well development sheet 75 16— 5016 Screen S1 Onoflex 2 -inch Sch 40 0 010 Slot flush -threaded PVC S2 N/A Q= N/A gpm Filter Pack CO Washed Silica Recovery Data S= N/A ft 10-20 sand on Recovery D c Grout Seal CETCO PUREGOLD 84 59- 5006 7 medium (3/8 inch) bentonite chips 85 21- 5006 1 Bentonite Seal CETCO PUREGOLD 85 21 5006 1 NOT TO SCALE medium bentonite chips 00 00 10 00 20 00 30 00 40 00 Time (mm sec) Comments The bentonite seal was hydrated with a minimum of 3 gals potable water per 2 bags of bentonite chips Supervised by Matt Somogyi Date 10/18/2014 Golder Associates Depth (ft) Elevation (ft) MONITORING WELL CONSTRUCTION SUMMARY Site Location Pawnee Waste Well No MW -2A + 2 76 5073 7 Project Number 140-7882A Boring No X -Ref BH-2014-06 (PZ-1) 5070 9 Survey Coordinates E 3372060 75 Elevation Ground Level 5070 9 ft CO State Plane N 1551800 20 Top of Casing 5073 7 ft 3 00 = ms'µ 5067 9 Drilling Summary Total Depth 58 83 ft Construction Time Start Log Finish Borehole Diameter 8 in Task Date Time Date Time Casing Stickup Height 2 76 ft Install PVC 10/10 905 10/10 911 Driller Site Services - Josh Anderson Pour Sand 10/10 925 10/10 1016 Bentonite Seal 10/10 1027 10/10 1037 Hydrate Seal 10/10 1037 10/10 1100 Rig CME 55 Bentonite Seal 10/10 1100 10/10 1158 Bits(s) 8 inch 4 -tooth carbide cutterhead Surface Comp 10/14 1254 10/14 1357 Drilling Fluid none Protective Casing 4 inch locking square steel Well Design and Specifications Casing String(s) C = Casing, S = Screen Depth String(s) Elevation + 2 76 - 48 7 C-1 5073 7 - 5022 2 Well Development 46 50- 5024 4 48 7 - 58 3 S 5022 2 - 5012 6 Depth to water initial N/A final N/A 58 3 - 58 8 C-2 5012 6 - 50121 See separate well development sheet - - Casing ClStabilization Onoflex 2 -inch Sch 40 flush - threaded PVC Test Data Time pH Spec Cond Temp ( C) 48 69- - C2 N/A See separate well development sheet 5022 2 Screen Si Onoflex 2 -inch Sch 40 0 010 Slot flush -threaded PVC S2 N/A Recovery Data O= N/A gpm Filter Pack CO Washed Silica S= N/A ft 10-20 sand on % Recovery n D C Grout Seal CETCO PUREGOLD 58 29- 5012 6 medium (3/8 inch) bentonite chips 58 83- 5012 1 Bentonite Seal CETCO PUREGOLD 58 83 5012 1 NOT TO SCALE medium bentonite chips 00 00 10 00 20 00 30 00 40 00 Time (min sec) Comments The bentonite seal was hydrated with a minimum of 3 gals potable water per 2 bags of bentonite chips Supervised by Matt Somogyi Date 10/10/2014 Golder Associates Depth (ft) Elevation (ft) MONITORING WELL CONSTRUCTION SUMMARY Site Location Pawnee Waste Well No MW -3 + 2 69 J 5067 7 Project Number 140-7882A Boring No X -Ref MW -2014-03 +5065 0 Survey Coordinates E 3372715 18 Elevation Ground Level 5065 0 ft CO State Plane N 1549869 74 Top of Casing 5067 7 ft 2 90 -._J J. _ 5062 1 Summary Total Depth 50 45 ft Construction Time Start Log Finish Borehole Diameter 8 in Task Date Time Date Time Casing Stickup Height 2 69 ft Install PVC 10/17 1143 10/17 1147 Driller Site Services - Josh Anderson Pour Sand 10/17 1147 10/17 1215 Bentonite Seal 10/17 1215 10/17 1218 Hydrate Seal 10/17 1306 10/17 1320 Rig CME 55 Bentonite Seal 10/17 1320 10/17 1330 Bits(s) 8 inch 4 -tooth carbide cutterhead Surface Comp 10/19 941 10/19 953 Drilling Fluid none Protective Casing 4 inch locking square steel Well Design and Specifications Casing String(s) C = Casing, S = Screen Depth String(s) Elevation + 2 69 - 45 3 C-1 5067 7 - 5019 7 Well Development 42 17 r t- 5022 9 45 3 - 50 0 S 5019 7 - 5015 1 Depth to water initial N/A final N/A 0 0 - 50 5 C-2 5065 0 - 5014 6 See separate well development sheet - - Casing ClStabilization Onoflex 2 -inch Sch 40 flush - threaded PVC Test Data Time pH I Spec Cond Temp ( C) 45 29 -5019 7 C2 N/A See separate well development sheet Screen Si Onoflex 2 -inch Sch 40 0 010 Slot flush -threaded PVC S2 N/A Q= N/A gpm Filter Pack CO Washed Silica Recovery Data S= N/A ft 10-20 sand 01-1 Recovery r D c Grout Seal CETCO PUREGOLD 49 95 -5015 1 -5014 medium (3/8 inch) bentonite chips 50 45 6 Bentonite Seal CETCO PUREGOLD 50 45 5014 6 NOT TO SCALE medium bentonite chips u 00 00 10 00 20 00 30 00 40 00 Time (min sec) Comments The bentonite seal was hydrated with a minimum of 3 gals potable water per 2 bags of bentonite chips Supervised by Matt Somogyi Date 10/17/2014 Golder Associates Depth (ft) Elevation (ft) MONITORING WELL CONSTRUCTION SUMMARY Site Location Pawnee Waste Well No MW -4 + 2 72 5069 5 Project Number 140-7882A Boring No X -Ref MW -2014-04 5066 8 Survey Coordinates E 3372034 48 Elevation Ground Level 5066 8 ft CO State Plane N 1550684 35 Top of Casing 5069 5 ft 3 20 v .'_y° -= -'' : 5063 6 Drilling Summary Total Depth 59 00 ft Construction Time Start Log Finish Borehole Diameter 8 in Task Date Time Date Time Casing Stickup Height 2 72 ft Install PVC 10/16 1355 10/16 1358 Driller Site Services - Josh Anderson Pour Sand 10/16 1359 10/16 1505 Bentonite Seal 10/16 1506 10/16 1507 Hydrate Seal 10/16 1508 10/16 1520 Rig CME 55 Bentonite Seal 10/16 1520 10/16 1619 Bits(s) 8 inch 4 -tooth carbide cutterhead Surface Comp 10/19 910 10/19 930 Drilling Fluid none Protective Casing 4 inch locking square steel Well Design and Specifications Casing String(s) C = Casing, S = Screen Depth Strng(s) Elevation + 2 72 - 47 3 C-1 5069 5 - 5019 6 Well Development 44 92— rs R _{FA T 5021 9 47 3 - 57 0 S 5019 6 - 5009 8 Depth to water initial N/A final N/A 0 0 - 57 4 C-2 5066 8 - 5009 4 See separate well development sheet - - - - - Casing ClStabilization Onoflex 2 -inch Sch 40 flush - threaded PVC Test Data Time pH Spec Cond Temp ( C) 47 26- - 5019 6 C2 N/A See separate well development sheet Screen S1 Onoflex 2 -inch Sch 40 0 010 Slot flush -threaded PVC S2 N/A Recovery Data Q= N/A gpm Filter Pack CO Washed Silica S= N/A ft 10-20 sand % Recovery n D C Grout Seal CETCO PUREGOLD r 57 03- 5009 8 medium (3/8 inch) bentonite chips 57 42- 5009 4 Bentonite Seal CETCO PUREGOLD 58 75 5007 8 NOT TO SCALE medium bentonite chips L, 00 00 10 00 20 00 30 00 40 00 Time (mm sec) Comments The bentonite seal was hydrated with a minimum of 3 gals potable water per 2 bags of bentonite chips Supervised by Matt Somogyi Date 10/16/2014 Golder Associates APPENDIX F Closure/Post-closure Plan LOSURE / POST -CLOSURE PLQ A world of capabilities delivered locally APPENDIX F CLOSURE / POST -CLOSURE PLAN Pawnee Waste E&P Landfill Weld County, Colorado Prepared for: Pawnee Waste LLC 3003 E. Harmony, Suite 300 Fort Collins, CO 80528 Prepared by: Golder Associates Inc. 44 Union Boulevard, Suite 300 Lakewood, CO 80228 July 23, 2015 Revision 1 - February 19, 2016 1407882B Golder Associates February 2016 Appendix F 1407882B Rev. 1 PAWNEE WASTE E&P LANDFILL CLOSURE/POST-CLOSURE PLAN RECORD OF REVISIONS Revision No. Date Description of Revision Section(s) Prepared By 0 07/23/2015 Initial Issuance All MAY 1 2/19/2016 Revision rolling financial to maximum closure assurance approach area and 2 8 2.9 JAR \14\1407882b\0400\0403 edop rev1\appendix f 1407882b app f cpc plan rev1 19feb16 docx Golder Associates 2.7 2.8 2.9 3.0 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 3.10 Closure Certification and Recordkeeping 3.11 Post -closure Cost Estimate and Financial Assurance February 2016 Appendix F ii 1407882B Rev. 1 Table of Contents 1.0 2.0 2.1 2.2 2.3 2.4 2.5 2.6 2.6.1 Phased Closure 2.6.2 Final Closure 2.6.2.1 Closure Notifications 2.6.2.2 Final Closure Activities 2.6.2.3 Closure of Fuel Tank and Leachate Storage Tank Areas 2.6.2.4 Closure Certification Deed Notation INTRODUCTION 1 CLOSURE ACTIVITIES (REGULATIONS 2.5, 3.5) 2 Description of Final Cover System 2 Final Cover Design and Construction 2 Revegetation Plan 2 Survey 3 Surface Water Controls 3 Phased and Final Closure 4 4 4 4 4 5 5 6 Largest Landfill Area Ever Requiring Final Cover 6 Closure Cost Estimate and Financial Assurance 6 POST -CLOSURE CARE (REGULATIONS 2.6 AND 3.6) 7 Post -closure Period 7 Post -closure Activities 7 Inspections and Maintenance 7 Access Control 8 Final Cover and Surface Water Controls Monitoring 8 Revegetation Monitoring 8 Groundwater Monitoring 10 Leachate System Maintenance and Operation 11 Post -closure Land Uses 11 11 12 i \14\1407882b\0400\0403 edop rev1\appencitx f\1407882b app f cpc plan rev1 19feb16 docx Golder Associates February 2016 Appendix F 1 1407882B Rev. 1 1.0 INTRODUCTION This Closure/Post-closure Plan (CPC Plan) has been prepared for the Pawnee Waste E&P Landfill (Landfill or Facility) located in Weld County, Colorado, owned by Pawnee Waste LLC (Pawnee, Owner). More specifically. the Landfill is located approximately four miles southeast of the Town of Grover, Colorado, near the intersection of County Road 118 and County Road 95 (see Figure 1 and Drawing 1), specifically in the northeast quarter and east half of the northwest quarter of Section 13, Township 10 North, Range 61 West of the 6th Principal Meridian. This CPC Plan, which is part of the document entitled 'Engineering Design & Operations Plan, Pawnee Waste E&P Landfill" (EDOP), describes the steps required to properly close the Landfill and to perform the necessary maintenance and monitoring during the post -closure care period. Closure and post -closure activities will be performed in accordance with applicable portions of Sections 2 and 3 of the Colorado Department of Public Health and Environment (CDPHE) "Regulations Pertaining to Solid Waste Sites and Facilities" (6 CCR 1007-2, Part 1) (Regulations). I \14\1407882b\0400\0403 edop revl\appendix f\1407882b app f cpc plan revs 19feb16 docx 4 fit\ Associates February 2016 Appendix F 2 1407882B Rev. 1 2.0 CLOSURE ACTIVITIES (Regulations 2.5, 3.5) This section, which constitutes the Closure Plan portion of the CPC Plan for the Landfill, provides a general description of the closure activities proposed to satisfy current applicable CDPHE closure requirements. as set forth in Section 2.5 and 3.5 of the Regulations. Specifically, this Closure Plan describes the phased and final closure plans and schedules, final cover requirements, revegetation, surface water controls, reporting and documentation of closure -related activities, and closure cost estimates for financial assurance. 2.1 Description of Final Cover System As indicated in Section 4.3 of the EDOP narrative, a "water balance" final cover system for the Landfill has been designed in accordance with the "Final Guidance Document: Water Balance Covers in Colorado" (WBC Guidance) (CDPHE, January 2013) using a water storage layer meeting the requirements for Ecozone 3. Based on the WBC Guidance and test results for existing on -site soils, the final cover profile will consist of, from bottom to top: • Foundation layer (12 -inch minimum thickness; may be composed of intermediate cover) • Water storage layer (2.5 feet thick) • Topsoil layer (6 inches thick) 2.2 Final Cover Design and Construction During phased construction of final cover and at final closure, final cover will be constructed over the portions of the Landfill that have not previously received final cover. Drawing 4 shows the final cover grading plan. Maximum final slopes will be 4H:1V (25%), and the minimum slope will be 5%. As illustrated on Drawing 4, the final cover grading will incorporate geomorphic features such as irregular slopes ranging from 5 to 10% on the top deck (crown), and a multi -peak design for a more natural appearance. Drawings 11 through 16 provide the associated details for the cover and related surface water control features. The Construction Quality Assurance (CQA) Plan, Appendix G of the EDOP, summarizes the tests and procedures to be followed in constructing the final cover system. 2.3 Revegetation Plan Successful revegetation is critical to the success of a water balance cover (WBC). Seeding and mulching requirements are presented in Section 9 of the CQA Plan and will be followed during phased and final closure of the Landfill. Development of an understanding of the soil characteristics at the time of initial seeding will help establish parameters for comparison in later stages of vegetation development. As detailed in the CQA Plan, the soil will be tested prior to seeding to assess physical properties and constituent concentrations affecting vegetative health. The proposed seed mixture included in the CQA Plan may be modified based on the results of site -specific soil conditions, previous site experience, and upon consultation with the Natural Resources Conservation Services (NRCS) and/or other revegetation '114\1407882010400\0403 edop rev1\appendix f\1407882b app f cpc plan revl 19feb16 docx Golder Associates February 2016 Appendix F 3 1407882B Rev. 1 specialists. An appropriate seed mixture will be applied according to the soil test parameters as well as recommendations of seed suppliers and/or a revegetation specialist. Tree species will not be used. Native shrubs may be included in the seed mix, but tap -rooted species will be avoided. Seeding will be performed at appropriate planting times for the area; this approach will increase the rate of success as it will be timed to coincide with optimal soil moisture conditions for germination. Supplemental irrigation is not proposed. Soil amendments such as compost or composted manure or other organic matter may be added if deemed appropriate based on soil test results and field soil conditions. The soil surface will be prepared to provide a firm but not overly compacted seed bed. Seeding methods, rates, and depths will be appropriate for the species specified, as per the CQA Plan. Weed -free mulch will be applied as specified in the CQA Plan. Vegetation success monitoring of seeded areas of the WBC is discussed in Section 3.6 of this CPC Plan. 2.4 Survey Final cover survey requirements include performing a record survey of the area of the final cover installed and performing manual measurements of final cover thickness. The thickness of the AFC will be measured on a 100 -foot grid pattern and at the edge of the cover on 100 -foot centers. The measurements, which may be performed either by survey or by using grade stakes, will document that the thickness of the water storage and topsoil layers meet the minimum required thicknesses. The tolerance for AFC cover component thicknesses will be 0.0 feet to +0.2 feet. The measurements will be included in the final certification report. Also included in the final cover documentation will be a topographic map of the surface of the final cover at the time of construction. It must be noted that this surface will change with time due to settlement of the underlying waste. This topographic map, prepared by a Colorado Registered Professional Land Surveyor, will be included in the final certification report. 2.5 Surface Water Controls Drawing 5 shows the stormwater control features that will be in place upon completion of final closure. All perimeter channels will be installed during the progression of Landfill development and thus will not be constructed during closure. Surface water controls (terrace channels, downchute channels, etc.) on the final cover will be constructed in phases as portions of the final cover are completed. At the time of final closure and along with the final phase of cover construction, any remaining unconstructed surface water control structures will be completed, in accordance with the approved design and CQA Plan. All permanent surface water structures that will remain after closure have been designed to control run-on and runoff from the 100 -year. 24 -hour storm event. Surface water control construction will be monitored by CQA personnel as per the most recent approved CQA Plan for the Facility. \14\1407882b\0400\0403 edop rev11appendix f\1407882b app f cpc plan revl 19feb16.docx Golder Associates February 2016 Appendix F 4 1407882B Rev. 1 2.6 Phased and Final Closure 2.6.1 Phased Closure Pawnee intends to close the Landfill in phases as sizeable areas reach final design waste grades. The phased closure area(s) will be defined based on the rate of waste intake and thus the frequency of completion of phase areas of practical size for final cover construction. The phased closure approach will require only those areas where final design grades have been reached to receive final cover. Final cover will not be applied to the interim sideslope of a fill area that has reached final design grade until the adjacent fill area is filled. Intermediate cover will be temporarily applied to those slopes of the fill areas that are adjacent to future fill areas and have not reached final elevation. The sequence of closure activities, particularly final cover construction, will be determined by Pawnee as filling operations progress. Prior to beginning closure of a Landfill phase, Pawnee will notify CDPHE and the Weld County Department of Public Health and Environment (WCDPHE) and also place notice of the intent to close the phase in the Operating Record. Closure activities for each Landfill phase will commence no later than 30 days after final waste grades are reached in the respective area, and will be completed no later than 180 days following the beginning of phase closure activities. Extension to either of these time frames may be sought by Pawnee, dependent upon successful demonstration to CDPHE that all steps necessary to prevent threats to human health and the environment from the unclosed Landfill phase have and will continue to be taken. Following each phase of closure, a CQA report will be prepared to document that the final cover and any associated surface water control structures were constructed in accordance with the approved CPC Plan, the CQA Plan, and all CDPHE and WCDPHE requirements. The final cover certification report will be signed and sealed by a Colorado registered professional engineer and submitted to CDPHE and WCDPHE, with a copy placed into the Operating Record as per Section 13 of the Operations Plan (Appendix C of the EDOP). 2.6.2 Final Closure 2.6.2.1 Closure Notifications When all waste disposal activities at the Facility are completed, the Landfill will be closed in accordance with applicable CDPHE Regulations. Pawnee will notify the CDPHE and WCDPHE in writing at least 60 days in advance of the final closure date, and post signs of suitable size at the entrance to the Facility to notify customers and the general public of the Landfill closure. 2.6.2.2 Final Closure Activities Final closure activities will include (but are not limited to): closure of the solidification unit and removal of residual solidification agents; installation of final cover over any remaining uncapped area(s) of the i \14\1407882b\0400\0403 edop revl\appendix f\1407882b app f cpc plan revl 19feb16 docx Golder Associates February 2016 Appendix F 5 1407882B Rev. 1 Landfill; removal of site buildings/infrastructure (including fuel tanks and leachate storage tanks); grading the entrance facility area to restore pre -development drainage patterns (where practical); and revegetation of all disturbed areas. Features such as the stormwater control channels, detention pond, and/or roads that are necessary during the post -closure period will remain in place. Final grading will promote positive drainage of surface water runoff and eliminate depressions to prevent surface water ponding. Soils for the final cover and grading are anticipated to be obtained primarily from on -site materials excavated from the Landfill footprint and stockpiled for this purpose. Revegetation will be accomplished using the seed mixture and mulching recommendations provided in the CQA Plan. In accordance with Section 2.1.16 of the Regulations, the Landfill and environs shall, upon completion of final Facility closure, be in a condition of orderliness and good aesthetic appearance. The geomorphic grading design and vegetative cover will render it capable of blending with the surrounding area. 2.6.2.3 Closure of Fuel Tank and Leachate Storage Tank Areas The fuel tank and leachate storage tank areas will be decommissioned in accordance with the following steps and procedures: • All stored fuel and leachate will be removed and transferred to/disposed of at an appropriately -permitted off -site facility. • The concrete containment areas will be demolished. The concrete rubble, as well as accumulated sediments and pipes, will be transported to an approved disposal facility. • Collect soil samples from beneath the former storage tank locations and analyze for: • RCRA/CERCLA volatile organic compounds using USEPA SW -846, Method 8260B; and • Toxicity Characteristic Leaching Procedure (USEPA SW -846, Method 1311) for RCRA metals. ■ Compare analytical results to the "Groundwater Protection Values Soil Cleanup Table" (CDPHE, Hazardous Materials and Waste Management Division [HMWMD] March 2014 or most recent version), using the Groundwater Protection Level values, except where USEPA Regional Screening Levels (RSLs) (for residential soil) differ, in which case the USEPA RSLs will govern. • If the applicable CSEV or USEPA RSL standards are exceeded, follow the guidelines presented in CDPHE's "Voluntary Cleanup Roadmap — A How -To Guide" (HMWMD May 2008 or most recent version). • Properly dispose of excavated soil at an approved disposal facility. • Backfill with clean on -site borrow soil and grade to achieve positive drainage (minimum 2% slope to surrounding grades). ■ Revegetate disturbed areas as per CQA Plan. 2.6.2.4 Closure Certification At the conclusion of all final closure activities, a certification report will be prepared to document that closure has been completed in accordance with the approved CPC Plan, the CQA Plan, and all CDPHE I \14\1407882b\0400\0403 edop revl\appendix f\1407882b app f cpc plan revs 19feb16 docx Golder Associates February 2016 Appendix F 6 1407882B Rev. 1 and WCDPHE requirements. The certification report will be signed and sealed by a Colorado registered professional engineer and submitted to CDPHE and WCDPHE, with a copy placed into the Operating Record as per Section 13 of the Operations Plan (Appendix C of the EDOP). 2.7 Deed Notation In accordance with Section 3.4.1 of the Regulations, Pawnee will, following the completion of final Landfill closure, record a notation on the deed for the Landfill property (or some other instrument that is normally examined during title search) to in perpetuity notify any potential purchaser of the property that the land has been used as a landfill facility, and that its use is restricted under Section 3.6.1(A)(7) of the CDPHE Regulations (6 CCR 1007-2, Part 1). The CDPHE and WCDPHE will be notified that the deed notation has been made, and a copy will be placed in the Operating Record. 2.8 Largest Landfill Area Ever Requiring Final Cover In accordance with Section 3.5.1(A)(2) of the Regulations, an estimate has been made of the largest area of the Landfill ever requiring a final cover during the active life. Based on the phased closure approach described in Section 2.2 above, the typical 5 -acre minimum cell size, and incorporating the interim landfill slope areas surrounding the Landfill's final constructed cell prior to final closure (which would represent the point in the Landfill life when the potential unclosed area would be the largest), the estimated maximum area ever requiring final cover is approximately 20 acres. As discussed in the Facility Operating Plan and in Section 2.6 of this CPC Plan, the Landfill will be developed in sub -phases (8 to 10 acres) and/or cells (approximately 5 acres) based on market conditions. The largest area currently constructed, open, and thus requiring final cover will be evaluated on an annual basis by the Owner and will serve as a basis for the development of the closure cost estimate for Landfill financial assurance (submitted separately, see Section 2.9). 2.9 Closure Cost Estimate and Financial Assurance Closure cost estimates will be updated and submitted to CDPHE annually, identifying the largest constructed and open area that would require closure, should premature closure be necessary, and tabulating the costs of hiring a third party to perform all associated closure activities. Initial financial assurance will be based on the size of the first phase constructed. Subsequent financial assurance estimates will vary over time and will be increased based on the timing of future phase/cell expansions, the extent of developed and open areas, and the impacts of filling progression on anticipated final closure phases. In accordance with Section 1.8 of the Regulations, a financial assurance mechanism will be established and maintained until final closure is completed, and associated documentation provided to CDPHE. The financial assurance mechanism will be provided to CDPHE and WCDPHE under separate cover after the approval of the EDOP. i \14\1407882b\0400\0404 edop rev2\appendix f\1407882b app f cpc plan rev1 19feb16 docx Golder Associates February 2016 Appendix F 7 1407882B Rev. 1 3.0 POST -CLOSURE CARE (Regulations 2.6 and 3.6) This section, which constitutes the Post -closure Plan portion of the CPC Plan for the Landfill, provides a general description of the post -closure care activities proposed to satisfy current applicable CDPHE post -closure requirements, as set forth in Section 2.6 and 3.6 of the Regulations. Specifically, this Post -closure Plan describes the inspection and maintenance program, access control, monitoring of final cover and surface water controls, revegetation performance evaluations (vegetative success monitoring), leachate disposal and leachate system monitoring, documentation of post -closure activities, and post -closure cost estimates for financial assurance. 3.1 Post -closure Period The current Regulations require post -closure care of the Facility to be conducted for a minimum of 30 years. However, the length of the post -closure period may be decreased by CDPHE, after consultation with the local governing body (in this case WCDPHE), if the Owner demonstrates that the reduced period is sufficient to protect human health and the environment. 3.2 Post -closure Activities Per the Regulations, Pawnee will perform the following during the post -closure period: • Prevent nuisance conditions; • Maintain the integrity and effectiveness of the final cover, including making repairs to the cover as necessary to correct effects of settlement, subsidence, erosion, or other events, and preventing run-on and runoff from eroding or otherwise damaging the final cover (further discussed in Section 3.3); • Monitoring groundwater and maintaining the groundwater monitoring system; and • Maintaining and operating the leachate collection system. Documentation of all required monitoring and maintenance activities will be placed into the Operating Record for the Facility. These monitoring and maintenance activities are further described below. The Owner will address any problems, issues, or concerns identified during the post -closure period. The following is the current location, mailing address, and telephone for the Owner: Pawnee Waste LLC 3003 E. Harmony, Suite 300 Fort Collins, CO 80528 3.3 Inspections and Maintenance Visual monitoring of the final cover integrity (erosion, burrowing animals, ponding, etc.) will be performed quarterly; inspection of the surface water controls will be conducted at a minimum semi-annually and within 14 days after major precipitation events (i.e., 25 -year, 24 -hour storm). Repair or maintenance of any impaired areas will be performed as soon as practicable following the inspection. \14\1407882b\0400\0403 edop revl\appendix f\1407882b app f cpc plan revs 19feb16 docx Golder Associates February 2016 Appendix F 8 1407882B Rev. 1 3.4 Access Control Access to the Facility will be controlled during the post -closure period using a lockable gate and perimeter fencing to prevent unauthorized entrance or unauthorized waste deposition. The Facility gates and perimeter fencing will be checked during routine site inspections for signs of damage or unlawful waste dumping, and any necessary repairs and corrective actions will be made in a timely manner. 3.5 Final Cover and Surface Water Controls Monitoring The final cover will be monitored during post -closure for signs of settlement, subsidence, erosion, or other potential damage or deficiency. Surface water controls, including the terrace channels, downslope channels, perimeter channels, access road channel, run-on diversion channels, culverts, and the stormwater detention pond will be monitored to verify that the run-on and runoff controls are adequately preventing erosion or other damage to the cover. The surface water control structures will be inspected for erosion damage and clogging by sediment, weeds, and other debris. Pawnee will periodically mow the perimeter of the Landfill area (buffer zones), as needed, to prevent noxious weeds or unwanted trees from becoming established, and thus limiting the potential for their seeds to be spread onto the completed cap. Any trees, noxious weeds, or undesirable shrubs that do become established on the final cover will be manually removed. Leachate volume tabulations and trend evaluation will also be performed as a component of WBC performance monitoring; see Section 3.8 of this CPC Plan. 3.6 Revegetation Monitoring In addition to physical assessment of the final cover integrity and effectiveness, annual vegetative success monitoring will be conducted in order to track progress and resolve any issues associated with the establishment of vegetation, as per the WBC Guidance. The annual vegetative success monitoring will be performed on all capped and revegetated phases, including those closed while the Landfill remains in operation. Each closed phase will therefore be on a separate timetable for vegetative success monitoring. The annual revegetation assessment activities are summarized below: • Year One: The revegetated final cover will be assessed based on a count of seedlings of desirable species per unit area after the end of the first year (first growing season). Several different areas of the revegetated cover will be assessed to achieve a broad evaluation and address observed variability. The number of seedlings counted per square foot will be recorded and categorized as follows: • Satisfactory — Four seedlings per square foot will be deemed "satisfactory" for establishment of a revegetated stand. • Sufficient — Two to three seedlings per square foot will be considered "sufficient," but any areas having this count will be identified for further inspection and progress evaluation at the conclusion of the next growing season. • Inferior — One to two seedlings per square foot will be considered as possible cause for re -seeding. Weather conditions (e.g., lack of precipitation or very heavy rains) or other site -specific factors will be considered in determining the need for re -seeding and whether seeding practices require adjustment. r\14\1407882b10400\0403 edop revl\appendix f11407882b app f cpc plan rev1 19feb16 docx Golder Associates February 2016 Appendix F 9 1407882B Rev. 1 • Unsatisfactory — Areas with less than one seedling per square foot will be evaluated to determine what factors inhibited the success of the area, and re -seeding (with practices adjusted as appropriate) will be performed during the next planting season (spring or fall). Starting in Year Two for each revegetated final cover area, annual assessments of plant cover will be performed in order to monitor the development of the vegetation stand. One or more of the approved methods described below, adapted from the WBC Guidance, will be implemented by Pawnee for the annual assessments conducted in Years Two through 10. Adjustments to the proposed timelines for each method of vegetative success monitoring may be made depending on the actual progress of vegetation establishment. • Year Two through Year Five: The Transect Line Intercept Method will be used in Years Two through Five after seeding, or until a satisfactory stand of vegetation has been established (i.e., if the vegetation remains insufficient in Year Five, annual Transect Line Intercept surveys will be continued until acceptable results are achieved). If the vegetative cover standards are not achieved at five calendar years after initial seeding, the revegetation methods will be reviewed and remedial procedures submitted to CDPHE and Weld County for review and approval within 90 days of following such a determination. • Transect Line Intercept Method — Measurement of live vegetative cover (by species), litter cover, and other forms of cover at 1 -foot intervals along randomly selected 100 -foot transects, with enough transects performed to obtain statistical adequacy. Vegetative cover measurements made using the Transect Line Intercept Method will be compared either against transect results from corresponding reference area(s), or against the following performance standards, per the WBC Guidance: Total live vegetation cover of perennial species in the seed mix or other appropriate live perennial vegetative species (excluding noxious weeds/undesirable vegetation) in any given year > 25%; Two-year running average for percent cover > 50%; and Three-year running average for percent cover > 67%. With "percent cover" defined as: Percent cover = 100 — percent bare ground = Percent live vegetation of perennial species in seed mix + percent appropriate live perennial vegetation by species not in seed mix + percent inappropriate live vegetation by species (e.g., noxious weeds/vegetation) + percent standing dead vegetation + percent rock + percent litter + percent cryptogams. • Year Six through Year 10: From Year Six through Year 10, annual vegetation monitoring will be continued in order to confirm the stability, diversity, and maturity of the vegetative stand. One or more of the four assessment methods listed below will typically be used during this stage: • Stand Height Measurement Method — Comparison of stand height of revegetated final cover against stand height of natural growth in reference area; • Biomass Measurement Method — Measurement of dry weight of biomass from a given size area of revegetated final cover (e.g., 1 foot by 1 foot) and comparison to dry weight of biomass from same -sized plot in reference area; I \14\1407882b\0400\0403 edop revl\appendix f\1407882b app f cpc plan revs 19feb16.docx Golder Associates -L - February 2016 Appendix F 10 1407882B Rev. 1 • Soil Moisture Measurement Method — Measurement of the soil moisture content of the upper 12 inches of the revegetated final cover and comparison to the soil moisture content of natural soils in the reference area(s); • Small Area Evaluation Method — Comparison of plant density (species type and coverage) in two identical size areas (e.g., 3 -foot square) on the revegetated final cover and the reference area(s) (plant density may be assessed visually or by counting "clumps" of grass). • Year 11 through End of Post -closure: Vegetation success monitoring will be continued until a diverse and stable plant community has become fully established. Pawnee may request approval from CDPHE for a reduction or elimination of vegetation monitoring and reporting once sufficient data is available to demonstrate acceptable WBC performance. In the interim (assumed beginning in Year 11), a simple visual assessment may be performed in lieu of any of the formal methods listed above. Additionally, for the vegetative stand to be considered satisfactory, no more than 60 percent of the vegetative growth of live perennial species (whether in the seed mix or otherwise) may consist of a single live perennial species; this standard is necessary to ensure that the vegetative stand does not develop into a "monoculture," which could be more susceptible to disease, pests, or adverse seasonal weather influences, may lead to reduced soil fertility and microorganism activity, and could lack the range of root depths and density necessary for proper WBC performance. Most of the prescribed assessment methods entail the identification of a reference area (i.e., an undisturbed nearby area) that has similar physical characteristics for comparison to determine success of the revegetation over time. Large areas of relatively undisturbed grasslands are available on the Owner's property for use in delineating reference area plots. Vegetative success monitoring results will be summarized in annual monitoring reports and submitted to CDPHE and Weld County. Areas identified as having insufficient vegetation or as having a dominant single species will be re -seeded as necessary, in accordance with procedures that would be outlined in the annual vegetation success monitoring report(s). 3.7 Groundwater Monitoring Per the Environmental Monitoring Plan (Appendix E of the EDOP), groundwater monitoring is to be performed on a semi-annual basis during the operating life of the Landfill, and will continue to be performed semi-annually during the post -closure period, unless an alternate frequency is sought by the Owner and approved by CDPHE and WCDPHE. All of the wells included in the monitoring network, as shown on Figure E-1 in Appendix E (as well as any potential monitoring wells installed in the future), will be checked for the presence of water and sampled if water is present during each semi-annual sampling event. Well integrity will also be examined during each groundwater monitoring event. The analytical methods and statistical evaluation of groundwater monitoring data will comply with applicable CDPHE Regulations and the site -specific requirements I \14\1407882b\0400\0403 edop rev1\appendix f\1407882b app f cpc plan revl 19feb16 docx Golder Associates Ar February 2016 Appendix F 11 1407882B Rev. 1 defined in the most recent approved version of the Environmental Monitoring Plan. Consistent with the requirements of Appendix B of 6 CCR 1007-2, Part 1, the CDPHE will be notified of any confirmed groundwater impacts that occur during the post -closure care period. Any actions taken as a result of groundwater impact will also be documented in the Operating Record. 3.8 Leachate System Maintenance and Operation The leachate collection system sumps, shown on Drawing 3, will be monitored at least monthly for liquid depth during the first three years of the post -closure period and thereafter quarterly during the post -closure period, unless otherwise approved by CDPHE and Weld County. Liquid will be removed from the sumps as needed to maintain less than 12 inches of head on the bottom liner. Leachate volumes will be tabulated quarterly to evaluate system performance (i.e., to look for potential trends or signs of malfunction). Liquid removed from the sumps during the post -closure period will be properly disposed of at a licensed wastewater treatment facility, permitted injection well, or any other approved facility. If liquid levels are consistently low and no liquid removal is required for at least 3 years, Pawnee may reduce the monitoring frequency for liquid depth in the sumps to annual. Liquid in the leachate sumps will also be sampled annually and tested for pH and the constituents listed in Appendix IA and IB of the Regulations. The liquid in the sumps will also be tested biennially (in odd -numbered years) using the Toxicity Characteristic Leaching Procedure (TCLP) (EPA SW -846, Method 1311). 3.9 Post -closure Land Uses No active land use is currently planned for the Landfill during the post -closure care period. The Landfill footprint will be restricted from grazing; however, the surrounding property owned by Pawnee may be returned to agricultural use. If future plans call for final cover disturbance, a plan for such activities will be submitted to CDPHE and WCDPHE for approval prior to implementation. Any potential post -closure use of the site that may be planned or proposed will be such that the integrity and function of the final cover, liner, leachate collection and removal system, or groundwater monitoring network will not be compromised. Any proposed disturbance of the Landfill containment systems will be subject to review and approval by CDPHE and will require demonstration that such activities will not increase the potential threat to human health or the environment. 3.10 Closure Certification and Recordkeeping Following completion of the post -closure period, CDPHE and WCDPHE will be notified that a certification verifying the post -closure care has been completed in accordance with this Post -closure Plan has been placed in the Operating Record. This certification will be either signed by an independent Colorado registered professional engineer or approved by CDPHE and WCDPHE. All monitoring, inspections, repairs, maintenance, and other activities conducted by the Owner or on the Owner's behalf during the post -closure period will be documented and the documentation placed in the Operating Record. \14\1407882b\0400\0403 edop rev1\appendix f\1407882b app f cpc plan rev1 19feb16.docx Golder Associates February 2016 Appendix F 12 1407882B Rev. 1 3.11 Post -closure Cost Estimate and Financial Assurance Post -closure cost estimates will be updated and submitted to CDPHE annually to tabulate the cost of hiring a third party to perform all necessary post -closure care activities. In accordance with Section 1.8 of the Regulations, a financial assurance mechanism will be established and maintained until the post -closure period has been completed to the satisfaction of CDPHE, including submittal of documentation to certify that post -closure care has been completed in accordance with this CPC Plan. The financial assurance mechanism will be provided under separate after the approval of the EDOP. \14\1407882b\0400\0403 edop revllappendix f11407882b app f cpc plan revs 19feb16 docx Golder Associates APPENDIX G Construction Quality Assurance Plan a444r z c�asi LLI 0 Labs las co co do °Z acr 0 U t: world of capabilities delivered locally APPENDIX G CONSTRUCTION QUALITY ASSURANCE PLAN Pawnee Waste E&P Landfill Weld County, Colorado Prepared for: Pawnee Waste LLC 3003 E. Harmony, Suite 300 Fort Collins, CO 80528 Prepared by: Golder Associates Inc. 44 Union Boulevard, Suite 300 Lakewood, CO 80228 July 23, 2015 Revision 1 — February 19, 2016 Revision 2 — June 1, 2017 1407882B Golder Associates June 2017 Appendix G 1407882B Rev. 2 Table of Contents 1.0 INTRODUCTION 1 1.1 Purpose 1 1.2 Document Format 2 1.3 Definitions 2 2.0 PERSONNEL AND ORGANIZATION RESPONSIBILITIES 6 2.1 Resident Project Representative (RPR) 6 2.2 Owner's Project Manager 6 2.3 CQA Manager 6 2.4 Design Engineer of Record 6 2.5 CQA Officer 7 2.6 CQA Monitor 7 2.7 Contractor and Geosynthetics Installer 7 2.8 Project Surveyor 8 2.9 Geosynthetics Manufacturer 8 3.0 PROJECT MEETINGS 9 3.1 Pre -construction Meeting 9 3.2 Daily Progress Meetings 10 3.3 Weekly Progress Meeting 10 3.4 Other Meetings 11 4.0 GENERAL CQA PROCEDURES 12 4.1 Preparing a Daily Record of Construction Progress 12 4.2 Verifying Material Quality 13 4.2.1 Samples 13 4.2.2 Material Submittals 13 4.2.3 Certificates of Compliance 13 4.3 Preparing CQA Test Reports 14 4.4 Summarizing CQA Test Data 14 4.5 Reviewing MQC and CQC Test Reports 14 4.6 Documenting the Correction of Non -Conforming Work 15 4.6.1 Observation and Documentation of Non -Conforming Work 15 4.6.2 Determining the Extent of Non-conformance 15 4.6.3 Documenting Non-conformance 15 4.6.4 Corrective Measures 15 4.6.5 Verification of Corrective Measures 16 4.7 Using a CQA Checklist 16 4.8 Documenting Design Modifications 16 4.9 Documenting CQA Plan Modifications 16 is\14\1407882b\040010406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G ii 1407882B Rev. 2 4.10 Documenting As -built Conditions 16 4.11 Preparing Other Project Records 17 4.12 Obtaining Photographic Documentation 17 4.13 Filing Project Documentation 17 4.14 Preparing the Construction Report 17 4.15 Calibrating Testing Equipment 18 4.16 Complying with Test Standards 18 5.0 EARTHWORK CQA 19 5.1 Purpose 19 5.2 Soil Sampling 19 5.2.1 Sample Processing 19 5.2.2 Sample Numbering 19 5.2.3 Sample Tagging 20 5.3 Conformance and Construction Phase Testing 20 5.4 Field Moisture and Density Test Numbering 21 5.5 Earthwork Observation and Testing Requirements 21 5.5.1 Excavation 21 5.5.2 Soil Stockpiling 21 5.5.3 Structural Fill Placement 21 5.5.4 Perimeter and Access Road Aggregate Placement 22 5.5.5 Subgrade Preparation 22 5.5.6 Compacted Low Permeability Soil Liner Placement 23 5.5.6.1 Mixing Methods 23 5.5.6.2 Test Pad Construction 24 5.5.6.3 Pre -construction Testing 26 5.5.6.4 Liner Construction 26 5.5.7 Sand and Gravel Placement 27 5.5.8 Final Cover System Placement 28 5.5.8.1 Vegetative Properties 29 5.5.9 Riprap Placement 29 6.0 GEOSYNTHETICS CQA 37 6.1 GCL Quality Assurance 37 6.1.1 Pre -Construction Submittal Review 37 6.1.2 Conformance Testing 38 6.1.3 Delivery 38 6.1.4 Subsurface Preparation 39 6.1.5 Subgrade Acceptance 39 6.1.6 Deployment and Seaming 39 i \14\1407882b10400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Associates _„4_ 11, 1T� - -76 June 2017 Appendix G 1407882B Rev. 2 6.1.7 Repairs 40 6.2 Geomembrane Quality Assurance 40 6.2.1 Pre -Construction Submittal Review 40 6.2.2 Conformance Testing 41 6.2.3 Delivery 41 6.2.4 Review of Geomembrane Panel Drawings 41 6.2.5 Subsurface Preparation 42 6.2.6 Subgrade Acceptance 42 6.2.7 Panel Layout As -built 42 6.2.8 Panel Placement Documentation 43 6.2.9 Trial Welding and Production Welding Documentation 44 6.2.10 Non-destructive Seam Testing 45 6.2.11 CQC Destructive Seam Sampling and Field Testing 46 6.2.12 CQA Destructive Seam Testing 48 6.2.13 Repairs 48 6.2.14 Wrinkles 49 6.2.15 Anchor Trench 49 6.2.16 Electrical Liner Integrity Testing 49 6.2.16.1 Work Plan 50 6.2.16.2 Bare Geomembrane 50 6.2.16.3 Covered Geomembrane 52 6.2.17 Acceptance 53 6.3 Geotextile Quality Assurance 54 6.3.1 Pre -Construction Submittal Review 54 6.3.2 Conformance Testing 54 6.3.3 Delivery 54 6.3.4 Subsurface Preparation 55 6.3.5 Placement and Seaming 55 6.3.6 Repairs 56 7.0 MECHANICAL CQA 65 7.1 HDPE Header and Riser Pipe Conformance and Construction Testing 65 7.1.1 Pre -Construction Submittal Review 65 7.1.2 Delivery 65 7.1.3 Construction Monitoring 66 8.0 SITE SURVEY REQUIREMENTS 67 9.0 SEEDING AND MULCHING 68 9.1 Topsoil Surface Acceptance 68 9.2 Seeding 68 I \14\1407882b\0400\0406 edop rev311407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G iv 1407882B Rev. 2 9.3 Mulching 69 List of Tables Table G-1 Table G-2 Table G-3 Table G-4 Table G -5A Table G -5B Table G-6 Table G-7 Table G-8 Table G-9 Table G-10 Table G-11 Table G-12 Table G-13 Table G-14 Construction Quality Assurance Testing of Structural Fill Construction Quality Assurance Testing of Prepared Subgrade Construction Quality Assurance Testing of Compacted Low Permeability Soil Liner Construction Quality Assurance Testing of Sand and Gravel Construction Quality Assurance Testing of Final Cover System Construction Quality Assurance Recommended Testing of Final Cover System Vegetative Properties Prior to Seeding Manufacturer Quality Control and Conformance Testing of Geosynthetic Clay Liner Manufacturer Quality Control Testing of 60 -mil Textured HDPE Geomembrane Manufacturer Quality Control Testing of High -Density Polyethylene Resin Conformance Testing of 60 -mil Textured HDPE Geomembrane 60 -mil Textured HDPE Geomembrane Seam Testing Manufacturer Quality Control of Extrudate or Bead Geosynthetics Field CQA/QC Testing Requirements Conformance Testing for Geotextile Typical Seed Mix List of Figures Figure 1 Water Storage Cover Material and Topsoil Thicknesses Acceptable Zone i \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 1 1407882B Rev. 2 1.0 INTRODUCTION 1.1 Purpose The purpose of this Construction Quality Assurance Plan (CQA Plan) is to describe procedures for the monitoring, testing, and documentation required during the installation of the geosynthetic clay liner (GCL), geomembrane liner, and soil components used for the construction of the landfill liner, leachate collection system, and final cover system at the Pawnee Waste E&P Landfill (Landfill) in Weld County, Colorado. CQA personnel will use this CQA Plan as the guidance document to implement the CQA program. This CQA Plan has been developed to ensure that the construction of the Landfill is in compliance with applicable local, state and federal regulations, and to substantiate that the construction meets or exceeds design criteria requirements. This CQA Plan also allows identification of issues that may occur during construction and provides the means for resolution of these problems. This document has been prepared by following the regulations and guidelines set forth by the Colorado Department of Public Health and Environment (CDPHE) below: • 6 CCR 1007-2, Part 1 "Regulations Pertaining to Solid Waste Sites and Facilities" (CDPHE, as amended from time to time) ■ "Solid Waste Guidance Document Concerning Solid Waste Site and Facility Engineering Design Quality Assurance/Quality Control Plans for Disposal Cell Subgrade, Liner, Leachate Collection System (including Sumps) and Protective Layer Components" (CDPHE, January 2010) • "Final Guidance Document: Water Balance Covers in Colorado" (CDPHE, January 2013) Geosynthetic components used in the Landfill construction will include high -density polyethylene (HDPE) geomembrane and geosynthetic clay liner (GCL). The GCL component proposed is a manufactured geosynthetic that utilizes sodium bentonite encapsulated between two layers of geotextile. However, as new products are developed and approved, this component may be changed with approval of the CDPHE. Soil components used in the Landfill construction will include structural fill, a low permeability soil liner, leachate collection header drain gravel, and a sand drainage layer. The tests to establish the adequacy of soil materials will be performed for each source as described in this CQA Plan. Construction material will be accepted or rejected based on the results of these tests. This program addresses quality assurance, not quality control. This CQA Plan is independent of the construction quality control (CQC) programs conducted by the manufacturers and contractors, and provides the plan for independent third -party verification and testing. Quality control is provided by the manufacturers and contractors, and refers only to those actions taken by them to ensure that materials and workmanship meet the requirements of the design. I \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 2 1407882B Rev. 2 1.2 Document Format This CQA Plan is organized as follows: ■ Section 1 provides this introduction, defines the format of the document, and provides definitions specific to terms used in the document. ■ Section 2 defines personnel and organizations that will be involved with CQA and their roles. ■ Section 3 provides information regarding various CQA-related meetings. ■ Section 4 defines general CQA procedures, including items such as project reporting, data collection, record keeping, and project filing. ■ Section 5 defines CQA procedures for earthwork construction. ■ Section 6 defines CQA procedures for geosynthetics manufacturing and installation. ■ Section 7 defines CQA procedures for mechanical construction, such as high -density polyethylene (HDPE) pipe installation ■ Section 8 defines site surveying requirements. ■ Section 9 defines procedure for seeding and mulching. 1.3 Definitions Whenever the terms in this section are used, the intent and meaning will be as indicated: ASTM: ASTM International, Inc. Construction Quality Assurance (CQA): A planned and systematic pattern of procedures and documentation designed to provide confidence that items of work or services meet the requirements of the contract documents, including construction drawings and technical specifications. Construction quality assurance includes verifying that the Contractor is meeting CQC requirements and that MQC requirements are met as defined in the technical specifications. CQA Consultant: The entity, independent from the Owner and the Contractor, that is responsible for observing and documenting activities related to the quality of material manufacturing, material installation, and other construction activities related to the project. This entity is also responsible for issuing a Construction Report sealed by a Professional Engineer registered in the state of Colorado documenting the CQA observations and conclusions. CQA Laboratory: A laboratory capable of conducting the materials testing required by this CQA Plan. CQA Manager: An authorized representative of the CQA Consultant who is responsible for managing the CQA program \1411407882b\0400\0406 edop rev311407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 3 1407882B Rev. 2 CQA Monitors: The authorized representatives of the CQA Consultant who also represent the Owner and are responsible for on -site implementation of CQA procedures and for observing and documenting CQA and CQC activities during construction. CQA Officer: An authorized representative of the CQA Consultant and a Professional Engineer registered in the state of Colorado who is responsible for certifying that construction was performed in accordance with the intent of the construction drawings and technical specifications. The CQA Officer and CQA Manager may be the same individual within the CQA Consultant's organization. Construction Quality Control (CQC): Those actions that provide a means to measure and regulate the characteristics of an item or service to comply with the requirements of the contract documents. This function is performed by the Contractor. Construction Drawings: The official plans, profiles, typical cross -sections, elevations, and details, as well as their amendments and supplemental drawings, that show the locations, character, dimensions, and details of the work to be performed. Construction drawings may also be referred to as the "plans." Contract Documents: The official set of documents issued by the Owner that includes bidding requirements, contract forms, contract conditions, technical specifications, construction drawings, addenda, and contract modifications. Contractor: The person or persons, firm, partnership, corporation, or any combination thereof, who, as an independent contractor, has entered into a contract with the Owner to perform the construction operations defined in the contract documents. Design Engineer of Record: The individual or firm responsible for the design and preparation of the construction drawings and technical specifications. This entity is also referred to as "Designer" or "Design Engineer." Earthwork: A construction activity involving the use of soil materials as defined in the technical specifications and Section 5 of this CQA Plan. Geosynthetic Clay Liner (GCL): A product consisting of a layer of sodium bentonite encapsulated between two layers of geotextile. The types of geotextile vary based on site -specific design criteria, and reinforcing is provided as needed to increase the internal shear strength of the product. Geosynthetics Installer: The person or firm responsible for geosynthetic installation. This definition applies to any entity installing geomembrane, geotextile, GCL, or other geosynthetic material and is also referred to as the "Liner Installer." I \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 4 1407882B Rev. 2 Geosynthetics Manufacturer: The firm responsible for supplying geosynthetics. This definition applies to any party supplying geomembrane, geotextile, GCL, or other geosynthetic material and is also referred to as the "Geosynthetics Supplier" or "Liner Supplier." High -density Polyethylene (HDPE) Geomembrane: A flexible product manufactured from specially formulated high -density polyethylene resin. The manufactured product generally contains approximately 97.5% polyethylene, 2.5% carbon black, and trace amounts of antioxidants and heat stabilizers. Manufacturer Quality Control (MQC): Actions that provide a means to measure and regulate the manufactured characteristics of a material or product to comply with the requirements of the technical specifications. This function is performed by the Geosynthetics Manufacturer. N on-conformance: A deficiency relative to the technical specifications and construction drawings that renders the quality of an item or activity unacceptable. Examples of non-conformance include, but are not limited to, physical defects, test failures, and inadequate documentation. N on -woven Geotextile: A product manufactured from continuous or staple filament polyester or polypropylene oriented into a staple network that maintains its structure during handling, placement, and long-term service, commonly for the purpose of filtration, drainage, or material separation. Owner: Pawnee Waste LLC Owner's Project Manager: An authorized representative of the Owner having overall responsibility for design and construction activities. The responsibilities include scheduling, cost control, engineering, procurement, and contracting functions with the support of the Resident Project Representative. This representative is also referred to as "Project Manager" in this CQA Plan. Panel: A unit area of a geosynthetic material that will be seamed in the field or in the Geosynthetics Manufacturer's facility. P rocedure: A written instruction that specifies or describes how an activity is to be performed. P roject Documents: The project documentation that includes, but is not limited to, Contractor submittals, construction drawings, record drawings, technical specifications, contract documents, the CQA Plan, health and safety plans, and project schedules. P roject Communication Records: The documents created and maintained throughout the project that include telephone memoranda, e-mail or facsimile communications, or other ancillary contact between participants of the project. i \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 5 1407882B Rev. 2 Project Surveyor: The independent surveying firm the Owner appoints or the Contractor retains to provide layout work, perform surveys for measurement of installed quantities, perform surveys for documentation of as -built conditions, and verify that the constructed work conforms to the lines and grades on the construction drawings. Record Drawings: The drawings documenting the constructed dimensions, details, and coordinates of the project. These drawings are also referred to as "as-builts." Resident Project Representative (RPR): The owner's representative responsible for day-to-day administration of the contract documents and coordination between parties in support of the Project Manager. Technical Specifications: The requirements for products, materials, and workmanship upon which the contract documents are based. Testing: Verification that an item meets specified requirements by subjecting that item to a set of physical, visual, chemical, environmental, or performance assessments. i \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 6 1407882B Rev. 2 2.0 PERSONNEL AND ORGANIZATION RESPONSIBILITIES This section of the CQA Plan describes personnel and organizations that will be assigned to this project and their roles. Individual roles may be consolidated; however, an independent third -party will perform CQA oversight. 2.1 Resident Project Representative (RPR) The RPR is the Owner's representative responsible for administration of the contract documents and coordination between parties. The RPR provides overall support to the Project Manager. The RPR and the Project Manager may be the same individual acting on behalf of the Owner. The RPR will request assistance from the CQA Manager, Design Engineer of Record, CQA Monitors, Contractor, and Geosynthetics Installer to resolve construction, technical, or regulatory issues. The RPR will control construction documents, including technical specifications, construction drawings. and change orders. The RPR will maintain one or more copies of the current set of contract documents for use by the Contractor, Geosynthetics Installer, and CQA Consultant. Upon issuance of new copies or revisions to any of the construction documents, it is the responsibility of the RPR to notify all parties involved in construction, provide revised contract documents, and recall all copies of the contract documents that do not include the latest revisions. 2.2 Owner's Project Manager The Project Manager is the Owner's representative with primary responsibility for communicating with the RPR and the CDPHE. The RPR and the Project Manager may be the same individual acting on behalf of the Owner. The Project Manager will request assistance from the RPR, CQA Manager, and Design Engineer of Record to resolve technical or regulatory issues during construction. 2.3 CQA Manager The CQA Manager is responsible for working directly with the RPR to manage CQA activities. The CQA Manager is responsible for managing the CQA program, supervising the CQA Monitors, conducting progress meetings, and preparing the Construction Report. The CQA Manager will obtain the approval of the Design Engineer of Record when an interpretation of the design is needed or a design change is being considered during construction. The CQA Manager will maintain one master copy of the CQA Plan for reproduction and distribution. 2.4 Design Engineer of Record The Design Engineer of Record is responsible for the design as it exists at the time construction begins. The Design Engineer of Record will approve all design changes and changes to the CQA Plan and provide i \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Assodates June 2017 Appendix G 7 1407882B Rev. 2 clarifications to design questions raised during construction. The Design Engineer of Record and the CQA Officer can be the same individual. 2.5 CQA Officer The CQA Officer is responsible for certifying that construction was performed in accordance with the design intent, construction drawings, technical specifications, and any design changes or CQA procedure changes made during construction are approved by the Design Engineer of Record. 2.6 CQA Monitor The CQA Monitor represents the CQA Consultant and the Owner by monitoring and testing the Contractor's work and the Geosynthetics Installer's work in accordance with the CQA Plan. The CQA Monitor reports to the CQA Manager. The CQA Monitor observes and documents the activities of the Contractor and the Geosynthetics Installer in sufficient detail, and with sufficient continuity, to provide a high level of confidence that the work product complies with the intent of the construction drawings and technical specifications. The CQA Monitor also performs tests, when appropriate, to provide a high level of confidence that the characteristics of the work meet the requirements of the construction drawings and technical specifications. Whenever the CQA Monitor conducts observations or performs tests, they are responsible for timely preparation and processing of the required documentation and reports. Accurate and concise documentation shall be prepared for all monitoring activities and for each test performed on the day that the CQA activity occurs. 2.7 Contractor and Geosynthetics Installer The Contractor and the Geosynthetics Installer are responsible for coordinating amongst themselves, scheduling and performing the work within the timeframe and budget agreed to in the contract documents, and performing the work in accordance with the construction drawings and technical specifications. The Contractor and the Geosynthetics Installer are also responsible for implementing or verifying MQC procedures and implementing CQC procedures to document that materials are manufactured and installed in accordance with the construction drawings and technical specifications. The Contractor and the Geosynthetics Installer are also expected to cooperate with the CQA Monitors to achieve a quality product. The Geosynthetics Installer is responsible for installation of geosynthetics within the timeframe and budget agreed to in the contract documents and in accordance with the construction drawings and technical specifications. The Geosynthetics Installer must provide a master seamer to supervise geomembrane installation. All installation technicians must be qualified by experience or by passing seaming tests. The experience record of each installation technician must be given to the CQA Manager prior to the start of geomembrane installation. i \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 8 1407882B Rev. 2 2.8 Project Surveyor The Project Surveyor will work at the direction of the Contractor or the Owner to set construction control stakes, perform surveys to document as -built conditions and conformance with design lines and grades, and perform surveys to measure the installed quantities of materials. 2.9 Geosynthetics Manufacturer The Geosynthetics Manufacturer is responsible for manufacturing geosynthetic products. The Geosynthetics Manufacturer must provide MQC certification forms with the results of the MQC testing on the geosynthetics being supplied for the project. f \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates -fir June 2017 Appendix G 9 1407882B Rev. 2 3.0 PROJECT MEETINGS In order to administer the contract documents, and to coordinate the Contractor's and Geosynthetics Installer's activities with those of the CQA Consultant, regular meetings will be held. They are discussed in this section of the CQA Plan. 3.1 Pre -construction Meeting A pre -construction meeting will be held at the site and will be attended, in person or by teleconference, by the RPR, Design Engineer of Record, Project Manager, CQA Manager, Contractor, Geosynthetics Installer, CQA Monitor, and others designated by the Owner. The meeting will be facilitated by the RPR and assisted by the CQA Manager. A meeting report will be prepared to document the meeting and its attendees. The purpose of this meeting will be to: ■ Present a proposed construction progress schedule and submittal log as required by the contract documents ■ Discuss procedures for handling submittals ■ Discuss the rules for project correspondence and roles and responsibilities of the Contractor, Design Engineer of Record, RPR, CQA Manager, and Owner ■ Establish reporting and documentation procedures for each party ■ Schedule weekly progress meetings ■ Present a summary of the laboratory materials testing and field testing that will be required to meet CQC, MQC, and CQA requirements ■ Discuss procedures for field orders, work change directives, and change orders ■ Discuss the Owner's site regulations ■ Review the construction drawings and technical specifications ■ Review the CQA Plan ■ Review work area security, safety procedures, and related issues ■ Provide all parties with relevant contract documents ■ Review testing equipment and procedures ■ Establish testing protocols and procedures for correcting and documenting non -conforming work or materials ■ Conduct a site inspection to discuss the work area, stockpile areas, lay -down areas, material storage areas, access roads, haul roads, and related items The RPR or CQA Manager will record minutes of the meeting and provide copies to all parties present at the meeting. \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 10 1407882B Rev. 2 3.2 Daily Progress Meetings An informal progress meeting is recommended daily before the start of work. At a minimum, the CQA Monitor and the Contractor's and Geosynthetics Installer's superintendents shall attend the meetings. A suggested typical agenda for the meetings may include the following: • Discussion of health and safety issues relevant to scheduled work • Discussion of the previous day's construction -related issues and resolutions • Review of relevant test data • Discussion of the Contractor's and Geosynthetics Installer's personnel and equipment assignments for the day • Identification of expected material or equipment deliveries and determination of staging and storage areas and inventory requirements ■ Resolution of outstanding issues or disputes 3.3 Weekly Progress Meeting Weekly progress meetings will be held. Typically, the RPR, Project Manager, CQA Manager, Contractor, Geosynthetics Installer, and CQA Monitors will be present. The RPR or CQA Manager will prepare the agenda for each meeting, facilitate the meeting, and prepare meeting minutes for distribution to all parties. An attendance sheet will be used to document the participants. At a minimum, the topics to be discussed during the weekly progress meetings will include the following: • Health and safety issues for the project • Meeting minutes from the previous weekly progress meeting • Work in progress and key activities scheduled for the upcoming week ■ Outstanding issues or disputes that may or may not interfere with progress of the work • Submittal Log, with identification of outstanding submittal issues ■ MQC, CQC, and CQA test results and testing scheduled to take place during the upcoming week • Updated schedule and quantities provided by the Contractor At the beginning of each weekly progress meeting, all parties in attendance at the previous meeting will be asked to agree to the contents of the minutes from the previous weekly progress meeting. Any changes to the minutes must be marked on the file copy. The RPR will keep a copy of all minutes at the project site in a project file that can be accessed at any point during or after the project. Official submittal of quantities to the CQA Manager and Project Manager will occur monthly. I \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 11 1407882B Rev. 2 3.4 Other Meetings As required, special meetings will be held to discuss issues or non -conforming work. At a minimum, the RPR, CQA Manager, CQA Monitor, and Contractor or Geosynthetics Installer will attend these meetings. If the issue requires a design modification and subsequent change order, the Design Engineer of Record will also be present or participate in the meeting via telephone. The RPR will document the meeting. I \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 12 1407882B Rev. 2 4.0 GENERAL CQA PROCEDURES The success of the CQA program requires thorough performance of the specified monitoring and testing activities, documentation of completed monitoring and testing activities, and frequent senior review of CQA documentation. Therefore, the CQA Monitor and CQA Manager must help assure that all CQA procedures have been implemented, results of the program are reviewed frequently, and corrections are implemented as needed. Procedures for completing, documenting, and reviewing CQA activities are summarized in this section and described in subsequent sections. They include the following: • Completing a daily record of construction progress (Daily Progress Report) • Verifying material quality • Preparing CQA test reports • Summarizing CQA test data • Reviewing and documenting CQC and MQC test reports provided by the Contractor, Geosynthetics Installer, and Geosynthetics Manufacturer • Documenting the correction of non -conforming work • Using a CQA checklist to help verify that procedures and documentation have been completed properly • Preparing CQA progress reports • Documenting design modifications • Documenting CQA Plan modifications • Documenting as -built conditions ■ Preparing other project records ■ Obtaining photographic documentation of the project • Filing project documentation • Preparing the Construction Report • Calibrating testing equipment and documenting calibration • Complying with test standards 4.1 Preparing a Daily Record of Construction Progress A daily record of construction progress (Daily Progress Report) will summarize each day's construction: CQA. CQC. and MQC activities; and relevant discussions with the Contractor and Geosynthetics Installer. A report will be prepared by the CQA Monitor on a daily basis. Each completed report will be submitted to the CQA Manager no later than the following day. A review will be conducted by the CQA Manager to check for clarity, legibility, traceability, and completeness. At a minimum, the report will include the following: • The date, project name, project number, and project location I \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 13 1407882B Rev. 2 ■ A unique number for cross-referencing and document filing ■ A description of the day's weather ■ A description of ongoing construction activities in the area of the CQA Monitor's responsibility ■ A summary of CQA, CQC, and MQC activities for the day ■ An inventory of equipment and personnel used by the Contractor and Geosynthetics Installer ■ A summary of pertinent project -related discussions and the names of parties involved in those discussions ■ A brief description of tests performed, identification of pass or fail status, and, in the event of fail status, a description of the re -test with pass or fail status ■ A description of non -conforming work and related corrective actions, if any (if used, a non- conformance and corrective action form must be attached) ■ A summary of materials received and documentation of their quality, such as MQC data ■ Follow-up information about previously reported problems or deficiencies ■ The signature of the CQA Monitor A copy of the Daily Progress Report that was sent to the CQA Manager and a copy of the Daily Progress Report that was signed by the CQA Manager will be kept on site. 4.2 Verifying Material Quality 4.2.1 Samples The Contractor, Geosynthetics Manufacturer, and Geosynthetics Installer will identify sources and provide samples of various materials as appropriate. Samples must be tested by the CQA Consultant to determine whether each material meets the quality requirements defined in the technical specifications. A record of soil samples obtained throughout the project will be maintained. 4.2.2 Material Submittals Material submittals may be used by the CQA Consultant to establish the acceptability of materials. When submittals are required, they will be submitted to the RPR and CQA Manager. Acceptance and proper review of submittals are the responsibility of the Design Engineer of Record or the CQA Officer. 4.2.3 Certificates of Compliance Where allowed in the technical specifications, certificates of compliance may be used by the CQA Consultant to establish the acceptability of materials in lieu of testing. These certificates generally state that the material is in compliance with a particular code, standard, or specification. The certificates of compliance must directly reference the project and include the name of the product or source of the material. Submission of a certificate of compliance does not relieve the Contractor of the responsibility to supply and install materials that meet the design requirements. I \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 14 1407882B Rev. 2 4.3 Preparing CQA Test Reports The CQA laboratory will complete a test report whenever testing is performed. Laboratory test reports will be reviewed by the laboratory performing the tests, and all field test reports will be reviewed by the CQA Manager. Laboratory and field test reports will be reviewed within 24 hours of completing the test. The review will include a determination regarding pass or fail status relative to specified quality or installation requirements, a check for mathematical accuracy, a check for conformance to test standards and the CQA Plan, and a check for clarity, legibility, traceability, and completeness. Laboratory and field test reports must include the following information as appropriate for the form being used: ■ The date, project name, and project location ■ A unique number for cross-referencing and document control ■ Weather data ■ A reduced -scale site plan showing sample and test locations ■ Information about test equipment calibrations, if applicable ■ A summary of test results with pass or fail status ■ Completed calculations, as applicable ■ The signature of the CQA Monitor or laboratory technician ■ The signature of the laboratory reviewer 4.4 Summarizing CQA Test Data CQA test data will be summarized in a form similar to that in which they will be presented in the Construction Report. Test data will be entered on a summary form no later than five working days after the CQA Manager's review of the individual test reports. Sections 5 and 6 of this CQA Plan include tables summarizing the required CQA testing. 4.5 Reviewing MQC and CQC Test Reports The Contractor and Geosynthetics Installer have contractual responsibilities for performing MQC and CQC testing to determine the quality of materials manufactured for the project and the quality of their installation. These requirements are presented in the technical specifications. The CQA Consultant will review MQC and CQC data to help ensure that manufactured materials and their installation meet the project requirements. The CQA Manager will review MQC data for conformance with specified material quality requirements within three working days of receiving the data. The CQA Manager will then file this information in the project files as described in Section 4.13 of this CQA Plan. Summarization of the data is not required. If the MQC data do not confirm the quality of the material, the CQA Manager will immediately notify the Contractor or the Geosynthetics Manufacturer, as appropriate. i \14\1407882b10400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 15 1407882B Rev. 2 The CQA Monitor will review CQC data for conformance with the installation requirements on the day that the installation is completed. The CQA Monitor will then file this information in the form it was received in the project files. Summarization of the data is not required. If the CQC data do not confirm that material installation was completed in accordance with project requirements, the CQA Monitor will immediately notify the Contractor or the Geosynthetics Installer, as appropriate. 4.6 Documenting the Correction of Non -Conforming Work 4.6.1 Observation and Documentation of Non -Conforming Work Whenever non -conforming work is found, the CQA Monitor will notify the Contractor's foreman or superintendent supervising the work in question. The CQA Monitor will then document in the Daily Progress Report that the Contractor or Geosynthetics Installer was notified. When the non -conforming work is corrected, the CQA Monitor will document that the corrective work has taken place in that day's Daily Progress Report or a subsequent Daily Progress Report. 4.6.2 Determining the Extent of Non-conformance Whenever non-conformance requires technical input from the Design Engineer of Record, the CQA Monitor or CQA Manager will first determine the extent of the non -conforming work. This can be accomplished by performing additional sampling, testing, and observations or by taking photographic records. 4.6.3 Documenting Non-conformance All non -conforming work must be documented in writing on Daily Progress Reports, test reports, or e lsewhere, as appropriate. The documentation must occur immediately upon determining the extent of the n on-conformance. For non-conformance that is considered serious or complex in nature or requires an e ngineering evaluation, a non-conformance report will be initiated and issued to the Design Engineer of Record, RPR, CQA Manager, and Contractor or Geosynthetics Installer. 4.6.4 Corrective Measures When routine non-conformance is found as a result of testing, such as a failed field moisture and density test, corrective measures will be determined by adherence to procedures provided in the technical specifications. If the routine non-conformance is determined by observation, such as a non -conforming grade tolerance, the CQA Monitor, RPR, and Contractor or Geosynthetics Installer will discuss standard construction methods to correct the deficiency. For more significant non-conformance, such as accidental damage to an installed material, the Design Engineer of Record will determine the corrective measures to be used. A copy of the non-conformance report, with the Design Engineer of Record's corrective measure determination, must be forwarded to the \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 16 1407882B Rev. 2 CQA Monitor and Contractor or Geosynthetics Installer for implementation of the corrective measure. The Owner will be notified of all significant non-conformance issues before corrective action is taken. 4.6.5 Verification of Corrective Measures Upon notification to the CQA Monitor by the Contractor or Geosynthetics Installer that corrective measures are complete, the CQA Monitor will verify completion. The verification must be documented by observations or re -testing and with photographs. The CQA Monitor will prepare written documentation of the corrective measures on Daily Progress Reports, logs and forms, and the non-conformance report. The report will then become part of the project documentation and be filed as indicated in Section 4.13 of this CQA Plan. 4.7 Using a CQA Checklist The CQA Monitor is responsible for completing a checklist of CQA testing requirements. The purpose of the checklist is to list all required CQA testing. The CQA Monitor will periodically review the checklist to help ensure that CQA testing and reporting are being completed as the pace of the project requires and to help verify that all required testing is being completed in a timely manner. 4.8 Documenting Design Modifications Design changes may be required during construction. Design changes can only be made by written agreement of the Design Engineer of Record. A copy of the design changes will be provided to the CQA Consultant for distribution to the appropriate personnel. 4.9 Documenting CQA Plan Modifications Changes to CQA procedures may be required during construction. CQA procedural changes can only be made by written agreement of the Design Engineer of Record. These changes must be made in writing by the Design Engineer of Record and must identify each CQA procedural change and its justification. When CQA procedural changes are made, the Design Engineer of Record will provide an updated CQA Plan to the CQA Consultant for distribution to the appropriate personnel. The Design Engineer of Record will be responsible for notifying the Owner of major changes and notifying the CDPHE of any change that may require regulatory approval. 4.10 Documenting As -built Conditions The CQA Monitor, Contractor, Geosynthetics Installer, and Project Surveyor will collect as -built information throughout the project as required by their contractual obligations. The CQA Manager will compile as -built information provided by the CQA Monitors, Contractor, Geosynthetics Installer, and Project Surveyor into one set of "as -built" drawings and technical specifications, which will be maintained at the project site and included in the Construction Report. These "as -built" drawings and technical specifications must be clearly marked as "project as -built drawings" and "project as -built technical specifications." \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Colder er t ssocIates June 2017 Appendix G 17 1407882B Rev. 2 4.11 Preparing Other Project Records Other project records will be completed as needed. These may include telephone records and meeting minutes that document issues related to CQA aspects of the project. 4.12 Obtaining Photographic Documentation Construction activities will be photographed by the CQA Monitor. Photographs will be taken to document project progress. Photographs will also be taken to show significant issues encountered during the work and actions taken to correct the issues. The photographs will be identified by number, location and/or direction, time, date, subject, and photographer. Selected photographs may be used in the Construction Report. 4.13 Filing Project Documentation The CQA Manager will implement a project filing system that results in a complete and retrievable record of the project. A file will be kept on site, and a duplicate file will be kept in the CQA Consultant's office. 4.14 Preparing the Construction Report At the completion of the project, the CQA Consultant will prepare and submit a Construction Report. This report will document the construction and compliance with the construction drawings and technical specifications. At a minimum, the report will contain the following: ■ An introduction ■ A list of all parties responsible for completing the project ■ A summary of all major construction activities ■ A summary of all MQC, CQC, and CQA tests ■ A description of significant construction issues and their resolutions ■ A discussion of design changes and CQA procedural changes and the justification for these changes, including references to any correspondence with the Design Engineer of Record and/or the CDPHE regarding the changes ■ Full-size record drawings (11 -inch by 17 -inch copies of the record drawings will be kept in the Landfill Operating Record) ■ A statement that the work was completed in accordance with the construction drawings, technical specifications, and design intent, accompanied by the stamp and signature of a Professional Engineer registered in the state of Colorado. The record drawings will accurately show the as -constructed locations of Landfill components including enhanced composite liner system, the leachate collection and recovery system, the final cover system, and anchor trenches. All surveying required to develop the record drawings will be performed by the Project Surveyor. The CQA Officer will review and verify that the record drawings are correct before they are included in the Construction Report. Electronic copies of the record drawings will be provided to the 114\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 18 1407882B Rev. 2 CDPHE. Daily and weekly summaries of CQA work will be kept in the Operating Record for a period of no less than five years. 4.15 Calibrating Testing Equipment Before on -site testing equipment is placed into service, the accuracy of each piece of equipment will be verified by calibration. Types of on -site equipment requiring calibration include nuclear gauges, tensiometers, and scales. The calibration procedures and frequencies will be completed per the equipment manufacturer's instructions. Copies of current calibration certificates for equipment will be maintained by the CQA Manager in the project file. Whenever a piece of equipment is suspected of producing questionable results, it will be removed from service and re -calibrated. 4.16 Complying with Test Standards The CQA Laboratory and CQA Monitor must perform various field and laboratory tests in accordance with applicable standards as specified in the contract documents or this CQA Plan. In most instances, the applicable test procedure is an ASTM standard. The most recent version of each test standard shall be used. i \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx tip Associates L-fr June 2017 Appendix G 19 1407882B Rev. 2 5.0 EARTHWORK CQA This section defines the earthwork CQA program for the liner, leachate collection and recovery, and final cover systems and any associated infrastructure being constructed. 5.1 Purpose Construction of each earthwork component shall be performed in accordance with the project design, design drawings, and this CQA Plan. Testing requirements and frequencies described in this section are for CQA and not for the Contractor's CQC program. The scope of earthwork construction for this project will generally include the following: • Excavation • Soil stockpiling • Structural fill placement • Perimeter and access road aggregate placement ■ Subgrade preparation • Compacted low permeability soil liner placement • Sand and gravel placement • Final cover system placement 5.2 Soil Sampling 5.2.1 Sample Processing The CQA Monitors are responsible for the timely processing and testing of soil samples. The CQA Manager will determine which samples will be tested on site and which will be tested off site. This determination will be made based on available manpower, available equipment, complexity of test procedures, and time available to obtain results. Samples tested off site will be shipped as soon as practical. As test data are obtained from the CQA Laboratory, they will be summarized in tables in a format suitable for inclusion in the Construction Report. 5.2.2 Sample Numbering The CQA Monitors must maintain a sample numbering system for all soil samples obtained for the project. These samples include those obtained prior to construction for conformance testing, and samples obtained during construction, such as samples obtained for determination of engineering properties (Atterberg limits, grain -size distribution) and moisture -density relationship (standard Proctor compaction) testing. \14\1407882b\040010406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx ' Golder Associates June 2017 Appendix G 20 1407882B Rev. 2 Documentation of soil sampling will be recorded on a soil sample log and maintained throughout the project. The soil sample log will include soil sample numbers that are unique to the type of sample being collected and will proceed sequentially. No sample number will be repeated, and re -tests of samples that do not meet the specified requirements will be given the original number with a letter suffix. Information contained in the soil sample log must include the following: • Sample number • Test(s) being performed ■ Date the sample was obtained • Name of the CQA Monitor who obtained the sample • Location where the sample was obtained, such as a stockpile, a fill, or a borrow area • Location where the testing will take place (on site or off site) • Date when the sample was sent off site, if applicable 5.2.3 Sample Tagging The CQA Monitors will maintain the identification of all samples obtained throughout the project from the time the sample is obtained to the time soil testing is completed. The CQA Monitor will place an identifying tag on the sample or mark the sample container with the sample number immediately upon sampling. The tag or identifying container will remain with the sample throughout processing, testing, and storage. The tag or container must have the following information: • Sample number • Project number • Name of the CQA Monitor who obtained the sample • Date when the sample was obtained 5.3 Conformance and Construction Phase Testing Table G-1 establishes testing methods and frequencies for earthwork CQA testing of structural fill. Table G-2 establishes testing methods and frequencies for earthwork CQA testing of prepared subgrade. Table G-3 establishes testing methods and frequencies for earthwork CQA testing of compacted low permeability soil liner. Table G-4 establishes testing methods and frequencies for earthwork CQA testing of sand and gravel. Table G-5 establishes testing methods and frequencies for earthwork CQA testing of final cover. Tables G-1 to G-5 include classification and conformance testing that will be performed both prior to soil installation to help ensure that soil materials meet quality standards established in the technical specifications, as well as construction testing that will be performed to help ensure that installed materials meet specified installation requirements. 114\1407882b10400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 21 1407882B Rev. 2 The listed testing frequencies establish a minimum number of required tests. Additional testing will be conducted whenever work or materials are suspect, marginal, or potentially of poor quality. Extra testing may also be performed to provide additional data for engineering evaluation. Any re -tests performed as a result of a failing test cannot contribute to the total number of tests performed in satisfying a minimum testing frequency. 5.4 Field Moisture and Density Test Numbering Each soil component that requires field moisture and density testing will have a unique set of test numbers. No test number will be repeated for a given soil component, and re -tests of failing tests must be given a letter suffix to the original test number. Test data will be recorded on a field moisture and density test form in a format suitable for inclusion in the Construction Report. 5.5 Earthwork Observation and Testing Requirements Each earthwork component for the project has specific material quality and installation requirements that will be monitored and tested. Sections 5.5.1 to 5.5.8 list monitoring and testing requirements for earthwork components. 5.5.1 Excavation Construction quality assurance for excavation includes the following activities: • Verify that construction staking is performed prior to excavation work • Periodically verify that slope requirements and grading tolerances are being met ■ Verify that stormwater channel excavations meet slope and cross-sectional requirements • Verify that lumped subsoil (clods), boulders, and rock of the dimensions identified in the technical specifications are removed from the excavation if it is also a completed surface of the Landfill cell subgrade ■ Verify that excavated materials that will not be used for earthwork components are stockpiled in designated areas 5.5.2 Soil Stockpiling Construction quality assurance for stockpiling includes the following activities: • Verify that soil is placed in the appropriate designated stockpile • Verify that soil placed in stockpiles remains within the designated stockpile footprint • Verify that maximum and minimum slope requirements are met 5.5.3 Structural Fill Placement On -site soils will be used for structural fill. This material shall be relatively free of deleterious matter and shall contain no particles larger than 6 inches. Large, oversize material shall be sorted out of the material using graders or other earthmoving equipment. Any sharp or deleterious objects in the upper four inches I \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 22 1407882B Rev. 2 of the final grade surface upon which geosynthetic materials will be placed shall be removed. The final surface will be proof -rolled, with a minimum 10 static ton, smooth drum drive, vibratory compactor, or other approved method. until it is smooth and there are no deflections greater than 1 inch. Construction quality assurance for structural fill placement also includes the following activities: ■ Verify that the proposed material is suitable for use as structural fill by sampling the proposed material and performing classification testing at the required frequencies ■ Summarize the classification test results ■ Verify maximum lift thickness of eight inches ■ Test for density and moisture content at the required frequencies and record the test data ■ Summarize the nuclear density and moisture content test data ■ Verify that the CQA data are reviewed, summarized. and filed as indicated in this CQA Plan ■ Verify that the completed grades meet finished grade and tolerance requirements 5.5.4 Perimeter and Access Road Aggregate Placement Construction quality assurance for the perimeter and access roads includes the following activities: ■ Verify that the source of material is suitable for use as aggregate base course by obtaining material submittals from the Contractor, logging the samples, and performing classification testing at the required frequencies ■ Summarize classification test results ■ Verify lift thicknesses ■ Verify that placement meets the specified installation requirements and record the relevant data ■ Summarize the test data ■ Verify that the CQA data are reviewed, summarized, and filed as indicated in this CQA Plan ■ Verify that the completed grades meet finished grade and tolerance requirements 5.5.5 Subgrade Preparation The Landfill subgrade upon which geosynthetic materials will be placed shall be prepared in accordance with the project requirements. Any sharp or deleterious objects in the upper four inches of the final grade surface upon which geosynthetic materials will be placed shall be removed. The final surface will be proof -rolled, with a minimum 10 static ton, smooth drum drive, vibratory compactor, or other approved method, until it is smooth and there are no deflections greater than 1 inch. Construction quality assurance for subgrade preparation includes the following activities: ■ Verify that the subgrade consists of suitable material by obtaining representative soil samples, logging the samples, and performing classification testing at the required frequencies \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 23 1407882B Rev. 2 ■ Summarize the classification test results ■ Test for density and moisture content at the required frequencies and record the test data ■ Summarize the nuclear density and moisture content test data ■ Verify that the completed grades meet finished grade and tolerance requirements ■ Verify that no soil particles greater than the size specified in the technical specifications are exposed on the finished surface and that there are no surface protrusions greater than 1/2 -inch in height ■ Verify that grade control stakes are removed at the completion of subgrade preparation ■ Verify that an as -built survey of the completed subgrade is performed and within the required tolerances ■ Verify that the subgrade as -built survey establishes the horizontal and vertical coordinates of the subgrade surface in accordance with the tolerances listed in Section 8.0 5.5.6 Compacted Low Permeability Soil Liner Placement On -site soils may not be suitable for use as a soil liner material without amendment. These on -site soils will be amended with bentonite to achieve a suitable soil-bentonite admixture with a hydraulic conductivity no greater than 1 x 10-7 cm/sec. On -site soils used for the low permeability soil liner shall have a minimum 50 percent passing the #200 sieve, and a minimum plasticity index (PI) of 10. The bentonite used for the admixture shall be supplied in powder or pulverized form. The following information about the bentonite will be recorded: ■ The type and origin of the bentonite component (natural sodium, sodium enriched bentonite, or calcium bentonite) ■ The montmorillonite content ■ The content of materials other than montmorillonite ■ The presence or absence of polymers or additives Acceptable off -site soils may be used for low permeability soil liner material if they have a hydraulic conductivity no greater than 1 x 10-' cm/sec. a minimum of 50 percent passing the #200 sieve, and a minimum plasticity index (PI) of 15. 5.5.6.1 Mixing Methods On -site soils will be spread out in a controlled manner to achieve a uniform thickness. The bentonite will be spread on top of a 12 -inch thick uncompacted lift of on -site soils at a rate equivalent to at least 3% bentonite (by dry weight), or at a rate determined by project -specific testing prior to liner construction. The bentonite spreader shall be fitted with an electronically variable mechanical or weight -controlled batcher allowing a spreading accuracy of 0.01 pounds per square foot. The CQA monitoring will measure the bentonite deposited over a known area to verify the bentonite application rate. A road reclaimer (CAT RM300 or Engineer -approved equivalent) will be used to mix the bentonite with the soil using the number of passes determined from the test pad (see next section). The first three passes will be made without adding water (i.e., dry passes). Water may be added to the mixture between passes after the initial \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx 411 Golder Associates June 2017 Appendix G 24 1407882B Rev. 2 three passes. Control measures shall be put in place so that the mixing depth by the road reclaimer does not exceed the lift thickness to prevent mixing the underlying layers. Once on -site soils are mixed with the bentonite. the soil-bentonite admixture will be hydrated to within 2% of the optimum moisture content in the mixing pad area. The material will be hydrated for a minimum of 24 hours prior to placement as liner. The remaining water to reach the appropriate water content may be added to the soil in -place during liner placement and compaction. Mixing methods do not apply to off -site soils. 5.5.6.2 Test Pad Construction Prior to constructing the compacted low permeability soil liner, a test pad will be constructed using the intended mixing. placement,. and compaction machinery. The test pad will be designed to provide the following information: • The suitability of the mixing method and mixture ingredients (does not apply to off -site soils). • The ability of the specified soil-bentonite admixture to achieve the permeability requirement (does not apply to off -site soils). • The suitability of the method of placement and compaction methods to achieve the permeability requirement. • Recommendations for the operation and management of the chosen mixing and water addition techniques. • Recommendations for the compaction of the liner, including the thickness of each lift, the weight and type of compaction equipment and minimum number of passes required to achieve the compaction specification. The test pad will be approximately 50 feet by 200 feet, which will allow the mixing equipment to reach full operational speed and to provide adequate space for full-scale construction practices to be used. The lift thickness and total thickness requirements will be the same as for the actual low permeability soil liner requirements (i.e., 6 -inch lifts and a total 2 -foot liner thickness). The test pad may be within a designated area of the Landfill and may be used as a portion of the actual low permeability soil liner being constructed. Moisture content (ASTM D3017) and density (ASTM D2922) testing on the test pad will be performed at a minimum frequency of three tests per lift. If more than 80% of the moisture -density test results fall below the "line of optimums." the area will be reworked and retested until 80% of tests in the area yield results above the "line of optimums." All moisture tests shall achieve a minimum moisture content corresponding to 75% saturation. The "line of optimums" will be defined as the line or curve connecting the maximum dry density/optimum moisture content points from 3 Proctor curves created at different compactive energies. Permeability testing on each test pad will consist of a minimum three hydraulic conductivity tests (ASTM D5084) on undisturbed samples (i.e., Shelby tube samples) to verify the compacted low \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates a June 2017 Appendix G 25 1407882B Rev. 2 permeability soil liner as constructed has a maximum vertical hydraulic conductivity less than or equal to 1 x 10-7 cm/sec. These tests will be distributed over the thickness of the layer so that the hydraulic conductivity is estimated for the upper 6 inches, middle 1 foot, and lower 6 inches. Test pad construction and testing activities shall be observed and certified by the CQA Monitor. At the discretion of the CQA Monitor, Pawnee may proceed with liner installation in advance of receiving final permeability testing laboratory data; however, should the permeability tests indicate that the test pad construction procedures resulted in an insufficient liner system (i.e., doesn't meet the project performance requirements), all liner installed to date will require full removal until a new test pad can be constructed using modified procedures and/or materials and its performance demonstrated through laboratory data. A new test pad will be required if there is a significant change (from approved test pad methods) in the equipment or methods proposed to construct the liner or if a significant change is observed in the source and/or type of low -permeability borrow soil. A significant change would consist of any one or more of the following: 1. Any change in the weight or type of equipment proposed, including the soil mixer, grader/spreader, and compactor; 2. Any change in the proposed liner mixing method and/or mixture ingredients; 3. Any change in the geologic unit from which the borrow materials are obtained; 4. Any change in the USCS classification of the borrow materials, to be demonstrated through laboratory soil testing at the frequencies required for pre -construction testing as outlined in Table G-3; 5. A 15% or greater change in the liquid limit, to be demonstrated through laboratory soil testing at the frequencies required for pre -construction testing as outlined in Table G-3; 6. A 15% or greater change in the gradation as defined by the #4, #10, #40, #100, and #200 sieves, to be demonstrated through laboratory soil testing at the frequencies required for pre -construction testing as outlined in Table G-3; 7. A ±5 pcf and/or ±3% change in moisture —density characteristics (i.e., maximum dry density and optimum water content), to be demonstrated through laboratory soil testing at the frequencies required for pre -construction testing as outlined in Table G-3; or 8. Any failed construction quality assurance hydraulic conductivity performance test, when relying on the performance of a prior test pad. Such determination will require supporting means/methods information from the Contractor, laboratory data, and professional certification by a professional engineer (PE) licensed by the State of Colorado. \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 26 1407882B Rev. 2 5.5.6.3 Pre -construction Testing Characterization of the borrow materials to be used to construct the low permeability soil layer (on -site soils with bentonite admixture or off -site soils) provides a basis for the CQA Monitor to verify during construction that the material being used for the low permeability soil layer is similar to the tested borrow materials. In addition, preconstruction permeability testing will enable the development of a "line of optimums," establishing moisture -density controls to help ensure that hydraulic conductivity requirements will be met. Prior to construction, bulk samples of proposed low permeability soil liner material will be collected and tested based on testing requirements in Table G-3. 5.5.6.4 Liner Construction Low permeability soil liner (on -site soils with bentonite admix or off -site soils) shall be compacted to a minimum of 95 percent of the maximum dry density as per ASTM International (ASTM) Method D 698 (Standard Proctor). Low permeability soil liner material requiring moisture addition will be hydrated prior to and/or during placement. Once on -site soils are mixed with the bentonite, the soil-bentonite admixture will be hydrated to within 2% of the optimum moisture content in the mixing pad area. This material will be hydrated for a minimum of 24 hours prior to placement. The low permeability soil liner materials shall be moisture -conditioned so that at least 80 percent of the moisture tests indicate yield results above the "line of optimums.' All moisture tests will achieve a minimum moisture content corresponding to 75% saturation. The optimum moisture content for the different clay liner materials will be determined by performing ASTM D 698 and the "line of optimums" will be defined as the line or curve connecting the maximum dry density/optimum moisture content points from 3 Proctor curves created at different compactive energies ("3 -Proctor technique"). Low permeability soil liner will be compacted using compaction equipment as determined during test pad construction or CQA Monitor -approved comparable equipment. The maximum loose lift of the clay liner will be no greater than the depth of the tamping feet on the compactor. After the low permeability soil layer is compacted, it will be smooth -drum rolled and protected from desiccation cracking (cracks greater than 1/4 inch or more than 1.5 inches deep) and frost damage. Protrusions of stones, clods, rocks, or debris that may cause damage to overlying geosynthetic components shall be removed to the satisfaction of the CQA Monitor. Construction quality assurance for low permeability soil liner placement includes the following activities: ■ Perform density and as -placed moisture content tests on a maximum 100 -foot grid pattern on every lift, offsetting the grid for alternating lifts (nuclear gauge testing will be used as the primary test method, but sand cone or drive cylinder testing must be used to verify nuclear gauge test results at a frequency of 1 sand cone or drive cylinder test per day) with a minimum 4 tests per acre per lift \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 27 1407882B Rev. 2 • Perform oven moisture content testing at a minimum frequency of one test per day to verify nuclear gauge testing results • Perform a standard Proctor compaction test with a minimum 5 -point curve for every 5,000 cubic yards of in -place compacted low permeability soil liner, with a minimum of one test per lift and one test per material type • Perform laboratory testing for Atterberg limits at a minimum frequency of one test per 5,000 cubic yards of in -place compacted low permeability soil liner, with a minimum of one test per acre and one test per material type • Perform specific gravity testing at a minimum frequency of one test per material type of in - place compacted low permeability soil liner • Perform grain -size distribution testing at a minimum frequency of one test per 1,000 cubic yards of in -place compacted low permeability soil liner, with a minimum of one test per acre and one test per material type • Perform "line of optimums" evaluation using "3 -Proctor technique" at a minimum frequency of one test per 10,000 cubic yards or change in material type • Perform hydraulic conductivity testing of compacted low permeability soil liner at a frequency of one test per 20,000 cubic yards • Verify that lifts have a compacted thickness of approximately 6 inches and are compacted to a minimum of 95 percent of the standard Proctor maximum dry unit weight with 80 percent of tests greater than the standard Proctor optimum moisture content. All moisture tests will achieve a minimum moisture content corresponding to 75% saturation. • Verify that no frozen soil is used to construct compacted low permeability soil liner components and that precautions such as soil cover or insulation are used to prevent freezing, as necessary based on weather conditions • Verify that the tamping foot or sheepsfoot compactor weighs, at minimum, 30.000 pounds and that it makes adequate passes per lift to ensure structural improvement of the soil • Verify that compacted low permeability soil liner has a minimum thickness of 2.0 feet in accordance with the tolerances listed in Section 8.0 5.5.7 Sand and Gravel Placement The leachate collection drainage layer (sand drainage layer) will consist of a minimum of 12 inches of sand. Material for the sand drainage layer will have a permeability of at least 1 x 10 2 cm/sec and shall have less than 5% fines (particles passing the No. 200 sieve). The supplier of the material for the sand drainage layer will be required to provide a certificate from an independent testing laboratory that the sand meets required specifications to satisfy pre -construction testing requirements for gradation and permeability. The leachate collection header drains will consist of 8 -inch diameter (dia.) SDR 11 HDPE pipe surrounded by gravel and encapsulated by 16 ounce per square yard (oz./sy) non -woven geotextile. The gravel will have a permeability of at least 1 cm/sec and shall have less than 5% fines (particles passing the No. 200 sieve). The supplier of the material for the gravel will be required to provide a certificate from an independent testing laboratory that the sand meets required specifications to satisfy pre -construction testing requirements for gradation and permeability. \14\1407882b\0400\0406 edop rev311407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 28 1407882B Rev. 2 Construction quality assurance for sand and gravel placement includes the following activities: • Verify that sources of sand and gravel are suitable by obtaining material submittals from the Contractor, logging the samples, and performing classification testing at the required frequencies • Perform gradation and permeability testing of sand and gravel prior to installation at the frequencies established in this CQA Plan to verify material quality and record the test data • Verify that the CQA data are reviewed, summarized, and filed as indicated in this CQA Plan • Establish the stockpile location, if required • Verify that sand and gravel placed in sumps and header drains is being fully encapsulated in geotextile • Verify that underlying geosynthetics and piping installations are complete prior to sand and gravel placement • Verify that grade control has been established to control the thickness of sand and gravel layers • During placement of sand and gravel over geosynthetics, verify that the required minimum material thickness is maintained below equipment that is spreading the material • Verify that the equipment being used to spread sand and gravel has a ground pressure equal to or less than the maximum ground pressure indicated in the specifications • Monitor the equipment speed and traffic patterns during sand and gravel placement to help ensure that damage is not occurring to underlying materials 5.5.8 Final Cover System Placement As outlined in Section 4.3 of the main EDOP narrative, the final cover system for the landfill will consist of, from bottom to top: • Foundation layer (6 -inch minimum thickness) • Water storage layer (2.5 feet thick) • Topsoil layer (6 inches thick) The foundation layer may consist of intermediate cover soil already in place. Per the "Final Guidance Document: Water Balance Covers in Colorado" (WBC Guidance), the location of the Landfill is in Ecozone 3. Soils analyzed from the on -site borrow sources meet the United States Department of Agriculture (USDA) definition of silt/loam on the USDA Soil Textural Triangle. According to the Acceptable Zones (AZ) laid out in the WBC Guidance, a water storage layer thickness of 2.5 feet is needed for water balance covers in Ecozone 3 for sites with this type of soil, as detailed in Appendix B-8. CQA for final cover placement includes the following activities: • Verify that the proposal material does not have boulders, stumps, or large roots '114\14078821010400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Assoriates June 2017 Appendix G 29 1407882B Rev. 2 ■ Verify that the maximum particle size is ≤2 inches in longest dimension, and maximum clod size is ≤4 inches in longest dimension, with a clod defined as a soil aggregation that does not break down by hand ■ Verify that proposed material has a suitable pH and CaCO3 to promote the capacity of vegetative growth for the final cover system ■ Verify that the proposed material is suitable for use as water storage layer material or topsoil by sampling the proposed material and performing classification testing and analytical testing at the required frequencies for the various zones (lower 30 inches of water storage layer material and upper 6 inches of topsoil) ■ Summarize the classification test results ■ Verify lift thicknesses (18 -inch minimum for water storage layer) ■ Perform as -placed density and moisture content tests on a maximum 100 -foot grid pattern and verify these values are suitable for the final cover ■ Perform as -placed density and moisture content tests on underlying water storage layer following topsoil placement and verify these values are suitable for the final cover ■ Implement corrective action for over -compaction and/or excessive moisture of each lift, including previously placed lifts, which will consist of ripping material that is too dense and drying material that exceeds the optimum moisture content until field testing confirms that the specifications are met. ■ Verify that the CQA data are reviewed, summarized, and filed as indicated in this CQA Plan ■ Verify that the completed grades meet finished grade and tolerance requirements in accordance with the requirements listed in Section 8.0 5.5.8.1 Vegetative Properties A key component to the effectiveness of the water balance cover is the capacity for vegetation growth throughout the entirety of the cap. This will be ensured by pre-screening the soils in the borrow area at a set frequency for pH and CaCO3. Table G -5A includes the methods and parameters that borrow source soils must meet for proper vegetative development. This includes the water storage layer and the topsoil layer. After construction and prior to seeding, the soil may also be analyzed for one, a subset of, or all of following characteristics, as deemed appropriate by the Design Engineer: salinity, nitrogen, potassium, phosphorous, organic matter, and conductivity. The WBC Guidance for these tests is summarized in Table G -5B. 5.5.9 Riprap Placement Riprap will be used for lining the downchute channels, the dissipation basin, stilling basins, and select reaches of perimeter channels. CQA for riprap placement includes the following activities: ■ Verify that the subgrade consists of suitable material ■ Verify riprap material consists of hard, dense. durable stone, angular to sub -rounded in shape and resistant to weathering. ■ Verify the stone has a specific gravity of at least 2.5. i \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 30 1407882B Rev. 2 ■ Verify that sources of riprap are suitable by obtaining a quarry certification showing the gradation of the material, the specific gravity, and the D5o from the Contractor. ■ Verify that the completed grades and cross -sections meet finished grade and tolerance requirements i \14\1407882b\040010406 edop rev3\1407882b app g cqa plan rev2 o1jun17 docx Golder Associates June 2017 Appendix G 31 1407882B Rev. 2 Table G-1: Construction Quality Assurance Testing of Structural Fill Testing I Test Method I Minimum Frequencym' 2' 3) I Requirements Pre -Construction Testing Standard Proctor Compaction ASTM D698 One per material type I None Construction Testing Standard Proctor Compaction ASTM D698 One one per 5,000 per material cubic type yards or None Density and Moisture Content - Nuclear ASTM D6938 One per 5,000 cubic yards 95% to +3% content relative relative (ASTM compaction to D698) optimum or higher moisture at -3% Nuclear Gauge Calibration Block Once per day None Grain -Size Distribution ASTM D422 One one per 10,000 per material cubic type yards or None Oven Moisture Content ASTM D2216 tests One Moisture per 20 Content Density - Nuclear and None Notes 1 Test frequencies are based on cubic yards of placed and compacted material. 2. At a minimum. Density and Moisture Content - Nuclear testing shall be performed once per day on each day that structural fill is placed. 3. When options are allowed in the testing frequency, the option that will result in the greatest frequency will apply. \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 32 1407882B Rev. 2 Table G-2: Construction Quality Assurance Testing of Prepared Subgrade Testing 1 Test Method IMinimum Frequency', 2) l Requirements Pre -Construction Testing Standard Proctor Compaction IASTM D698 l One per material type I None i Construction Testing Standard Proctor Compaction ASTM D698 One per material type None Density and Moisture Content - Nuclear ASTM D6938 Top 6 inches on 100 -foot grid 95% 3% content relative to +3% (ASTM relative compaction D698) to optimum or higher at moisture -- Nuclear Gauge Calibration Block N/A Once per day None Atterberg Limits ASTM D4318 One 6 inches per 1,000 cubic or one per yards material of the type top None Grain -Size Distribution ASTM D422 One 6 inches per 1,000 cubic or one per yards of the type top None material Oven Moisture Content ASTM D2216 One Content per 20 Nuclear Density and tests Moisture None Notes: 1. At a minimum, Density and Moisture Content - Nuclear testing shall be performed once per day on each day that subgrade preparation is performed. 2. When options are allowed in the testing frequency, the option that will result in the greatest frequency will apply. \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates r June 2017 Appendix G 33 1407882B Rev. 2 Table G-3: Construction Quality Assurance Testing of Compacted Low Permeability Soil Liner Testing I Minimum Frequency(1, 2, 3, 4) I Requirements Pre -Construction Testing Standard (ASTM Proctor D698) Compaction One per 6,540 cubic yards None Atterberg (ASTM D4318) Limits One per 6,540 cubic yards None Grain (ASTM -Size D422) Distribution One per 6,540 cubic yards None Water (ASTM Content D2216) One per 2,620 cubic yards None Hydraulic (ASTM Conductivity D5084) - Flexible Wall One per 13,080 cubic yards 1 or x 10-7 lower centimeters per second Construction Testing Standard 5 -point (ASTM Proctor Curve D698) Compaction — One one material per per 5,000 lift, type cubic or one yards, per None Density Nuclear(5) (ASTM and D6938) Moisture Content - On 100 6 -inch minimum per lift -foot (maximum) of grid 4 tests on lift per each with a acre 95% higher above (ASTM relative the and D698)(5) "line compaction 80% of yield optimums" or results Nuclear Gauge Calibration Block Once per day None Atterberg (ASTM D4318) Limits One one or one per per 5,000 acre or per material cubic one type yards, per lift, I Plasticity index of 15 or higher Grain (ASTM -Size D422) Distribution One one material per per 1,000 acre, type cubic or one yards, per More sieve than 50% passing No. 200 Specific (ASTM Gravity D854) One per material type None Oven (ASTM Moisture D2216) Content One per day None Density Cylinder (ASTM D1556 Sand Cone or ASTM or Drive D2937) One per day None "Line Using of 3 -Proctor Optimums" technique Evaluation One or one per 10,000 per material cubic type yards None (ASTM Hydraulic Conductivity D5084) - Flexible Wall One per 20,000 cubic yards 1 x or lower 10-7 centimeters per second Notes: 1. Test frequencies are based on cubic yards of placed and compacted material. 2. At a minimum. Density and Moisture Content - Nuclear testing shall be performed once per day on each day that compacted clay is placed. 3. When options are allowed in the testing frequency, the option that will result in the greatest frequency will apply. 4. For Density and Moisture Content Nuclear testing. the grid shall be offset on alternating lifts_ 5. The degree of saturation for each moisture/density test shall be greater than or equal to 75%. I \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 34 1407882B Rev. 2 Table G-4: Construction Quality Assurance Testing of Sand and Gravel Testing fFrequency13 Requirements(2) Sand Pre -Construction Testing Grain (ASTM -Size C136) Distribution One per source 100% Less sieve than passing 5% 3/8 -inch passing No. sieve 200 Hydraulic (ASTM Conductivity D2434) - Rigid Wall One per source 1 or x higher 10-2 centimeters per second Sand Construction Testing Grain (ASTM -Size C136) Distribution One one per 1.000 per source cubic yards or 100% Less sieve than passing 5% 3/8 -inch passing No. sieve 200 Hydraulic (ASTM Conductivity D2434) - Rigid Wall One four or one per per 2,000 construction per source cubic yards, phase, 1 or x higher 10-2 centimeters per second Gravel Pre -Construction Testing Grain (ASTM -Size C136) Distribution One per source 100% 70% sieve Less sieve to than passing 100% 5% 1.5 passing passing -inch 1 No. sieve -inch 200 Hydraulic (ASTM Conductivity D2434) - Rigid Wall One per source 1 centimeter per second or higher Gravel Construction Testing Grain (ASTM -Size C136) Distribution One per source 100% 70% to sieve Less sieve than passing 100% 5% 1.5 passing passing -inch 1 sieve -inch No. 200 (ASTM Hydraulic Conductivity D2434) - Rigid Wall One per source 1 centimeter per second or higher Notes 1. Test frequencies are per cubic yard of placed and compacted material. 2. Gradation requirements for sand and/or gravel may be modified if the hydraulic conductivity requirements are met, if the gradation is sufficient to limit entry of soil into pipe perforations (applicable to gravel only), and if approved by the Design Engineer of Record. 3 When options are allowed in the testing frequency, the option that will result in the greatest frequency will apply. \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 35 1407882B Rev. 2 Table G -5A: Construction Quality Assurance Testing of Final Cover System (Water Storage Layer and Topsoil) Parameter I Test Method I Requirement QA Test Frequency(2) Pre -construction Grain -Size Distribution ASTM D 422 (with full hydrometer) Inside < 15% AZ(1) and gravel 1 per 6,500 CY, or change in soil type Standard Proctor Compaction I ASTM D 698 None 1 per 6,500 CY, or change in soil type Nuclear Block Gauge Calibration Once per day None Nuclear Gauge Calibration Block Construction Grain -Size Distribution ASTM D 422 (with full hydrometer) Inside < 15% AZ(1) and gravel 1 per 1,500 CY Standard Proctor Compaction ASTM D 698 None 1 per 3,000 CY, or change in soil type Completed Thickness Per Design topsoil) 3.0 storage feet layer (total water and 3 per acre per 18 -inch (minimum) lift Density Nuclear and Moisture Content - ASTM D6938 80-90% compaction -5% optimum content relative relative moisture at to +0 . to 3 1 per acre per acre per 18 per successive -inch (minimum) 6 -inch lift topsoil lift Nuclear Block Gauge Calibration Once per day None Nuclear Gauge Calibration Block pH EPA Methods SW -846, SW 9045C 6.0-8.4 1 per 6,500 CY CaCO3 USDA Handbook Number 60 <15%, by weight 1 per 6,500 CY Notes 1. Acceptable Zone (AZ) is provided as Figure G-1. 2. When options are allowed in the testing frequency, the option that will result in the greatest frequency will apply. \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 36 1407882B Rev. 2 Table G -5B: Recommended Construction Quality Assurance Testing of Final Cover System - Vegetative Properties Prior to Seeding (Optional per Design Engineer) Parameter Test Method Recommendations Salt content < 2% Salinity USDA Handbook Number 60 Nitrogen EPA 351.2 5 to 30 parts per million Potassium i ICP 200.7 H20 parts per million Phosphorous EPA M365.1 3 to 7 parts per million Organic Matter USDA Handbook Number 60 1.5 to 2.0% when accompanied by proper nitrogen/phosphorous levels Conductivity Soil Survey Standard Test Method i < 4 millisiemens per centimeter \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 37 1407882B Rev. 2 6.0 GEOSYNTHETICS CQA This section describes the geosynthetics CQA program. The objectives of the geosynthetics CQA program are to: • Verify that geosynthetic materials manufactured for the project meet quality standards defined in the technical specifications • Verify that construction techniques and procedures used during installation of geosynthetic materials are in compliance with the construction documents and the Geosynthetics Manufacturer's and/or Geosynthetics Installer's installation manual(s) • Identify and define issues that may occur during construction and then verify that these issues are prevented or corrected before construction is complete To help ensure compliance, the CQA program will include a review of the MQC testing, performance of material conformance testing. documentation of CQC testing, and visual observation of geosynthetic materials installation. Geosynthetics MQC and conformance testing will take place before installation of geosynthetics to verify material quality. Construction testing includes activities that are performed during installation of geosynthetics to verify installation quality. Table G-12 presents geosynthetics field CQA/CQC testing requirements. The following types of geosynthetics are proposed be installed in the Landfill: • GCL, as a component of the enhanced composite liner • HDPE geomembrane, as a component of the enhanced composite liner • Non -woven geotextile, as a separation layer above the leachate collection and recovery system and around granular soil in sumps, header drains, and related components 6.1 GCL Quality Assurance 6.1.1 Pre -Construction Submittal Review Prior to scheduled delivery of the product, the Geosynthetics Manufacturer will provide the CQA Consultant with the following items for review: • The Geosynthetics Manufacturer's description (cut sheet) for the proposed GCL documenting that it will meet or exceed the specified requirements • Written instructions for storage, handling, installation, seaming. and repair of the proposed GCL If the properties outlined in the technical specifications differ from those listed on the Geosynthetics Manufacturer's standard cut sheet, the Geosynthetics Manufacturer must provide a written statement certifying that the properties in the specifications will be met or provide an alternative material. Prior to shipment of the GCL. the CQA Consultant must review the submittals for conformance with the technical specifications. 114\1407882b10400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 38 1407882B Rev. 2 Prior to scheduled installation, the Geosynthetics Manufacturer or the Geosynthetics Installer must provide the following items to the CQA Consultant for review: ■ MQC data for GCL produced for the project ■ The Geosynthetics Installer's CQC plan and installation procedures describing the Geosynthetics Installer's needle detection plan • A copy of the Geosynthetics Manufacturer's needle detection and removal certification Prior to installation, the CQA Consultant must review the above information and verify conformance with Table G-6 of this CQA Plan and record the sampled roll numbers. All submittals received by the CQA Consultant must be recorded on the submittal log and placed in the project files for review by the CQA Monitors. 6.1.2 Conformance Testing The CQA Consultant will obtain one GCL sample for every 100,000 square feet of material supplied, and at least one for each type of GCL. Each sample will be sent to the CQA Laboratory for conformance testing. The CQA Monitor will review all conformance test results and report any non-conformance to the CQA Manager. The conformance testing summarized in Table G-6 will be completed and accepted prior to shipment of GCL to the site. 6.1.3 Delivery During delivery of GCL, the CQA Monitor must: • Verify that the equipment used to unload the materials does not damage the GCL • Verify that rolls are wrapped in impermeable and opaque protective covers • Verify that care is used to unload the rolls ■ Verify that all MQC and submittal documentation required by the technical specifications has been received, reviewed. and filed • Verify that each roll is marked or tagged with the Geosynthetics Manufacturer's name, project identification, lot number, roll number. and roll dimensions and that this information is documented in a GCL Inventory Log • Verify that materials are stored in a location that will protect the rolls from exposure to precipitation, mud, dirt, dust, puncture, cutting. and any other damaging or deleterious conditions Damaged material will be rejected. The CQA Monitor will verify that rejected material is removed from the site or stored at a separate location away from accepted material. GCL rolls that are not accompanied by the proper documentation from the Geosynthetics Manufacturer will also be stored at a separate location until all such documentation has been received and approved. \14\1407882b10400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 39 1407882B Rev. 2 6.1.4 Subsurface Preparation Before GCL installation, the CQA Monitor will: ■ Verify that all lines and grades have been met by the Contractor ■ Verify that the subsurface has been prepared in accordance with the technical specifications in Section 5.4. 6.1.5 Subgrade Acceptance Prior to GCL deployment. the surface on which the GCL will be installed will be prepared in accordance with the technical specifications in Section 5.4. Before GCL installation, the CQA Monitor and the Geosynthetics Installer will inspect the surface. The CQA Monitor will verify the following: ■ No sharp objects or other materials that could puncture the GCL are present on the subgrade surface ■ The anchor trench dimensions have been checked, and the trenches are free of sharp objects and stones ■ There are no excessively soft areas ■ All construction stakes have been removed ■ The Geosynthetics Installer has certified, in writing on a subgrade acceptance form acceptable to the CQA Manager, that the surface on which the GCL will be installed is acceptable ■ The Contractor has signed the subgrade acceptance form ■ The subgrade acceptance form is prepared on a daily basis whenever GCL is being deployed 6.1.6 Deployment and Seaming During GCL deployment and seaming operations, the CQA Monitor will: ■ Observe the GCL as it is deployed and identify defects and corrective actions, such as panel rejection or patch installation ■ Verify that corrective actions are performed in accordance with the technical specifications and record these corrective actions in the daily progress report ■ Verify that equipment used to install GCL does not damage it during handling or deployment by leakage of hydrocarbons or any other means ■ Verify that crews working on the GCL do not smoke, wear shoes that could damage the GCL, or engage in activities that could damage the GCL ■ Verify that GCL is anchored and ballast is placed by the Geosynthetics Installer to limit movement by the wind ■ Verify that adjacent panels are overlapped and seamed in accordance with the technical specifications and that the proper amount of bentonite is applied to the seam overlap, if required ■ Verify that the GCL is not exposed to precipitation or damaged due to premature hydration r\14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Colder Associates June 2017 Appendix G 40 1407882B Rev. 2 ■ Verify that no more panels are deployed than can be covered with geomembrane on the same day ■ Examine the GCL after installation to verify that no objects that could damage the overlying geomembrane are present The CQA Monitor must inform the CQA Manager and the Geosynthetics Installer in a timely manner if the requirements are not being met. 6.1.7 Repairs Where repairs are necessary, the CQA Monitor will verify that the following methods are used: ■ Patching — used to repair large holes. tears, and small defective areas ■ Removal — used to replace large defective areas where the preceding method is not appropriate or to replace GCL that has been exposed to excessive moisture 6.2 Geomembrane Quality Assurance 6.2.1 Pre -Construction Submittal Review Prior to scheduled delivery of the product, the Geosynthetics Manufacturer will submit the following items to the CQA Consultant for review: ■ The Geosynthetics Manufacturer's description (cut sheet) for the proposed resin and geomembrane documenting that it will meet or exceed the requirements summarized in Tables G-7 and Table G-8 ■ Written instructions for storage, handling, installation, seaming, and repair of the proposed geomembrane If the properties outlined in Tables G-7 and G-8 differ from those listed in the Geosynthetics Manufacturer's standard cut sheet, the Geosynthetics Manufacturer must provide a written statement certifying that the properties in the specifications will be met or provide an alternative material. Prior to shipment of the geomembrane, the CQA Consultant or Design Engineer of Record must review the geomembrane submittals for conformance with the technical specifications. Prior to installation of the geomembrane, the CQA Consultant will review personnel qualification submittals and shop drawings for conformance with the technical specifications. The CQA Monitor must also complete geomembrane conformance testing in accordance with this CQA Plan and record the sampled roll numbers prior to installation of the geomembrane All submittals received by the CQA Consultant must be recorded in the Submittal Log and placed in the project files for review by the CQA Monitors. i \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates **fa tin . June 2017 Appendix G 41 1407882B Rev. 2 6.2.2 Conformance Testing One geomembrane sample will be obtained for every 100,000 square feet of material supplied, and at least one for each resin batch or lot represented by the Geosynthetics Manufacturer. The material will be sampled at the site by the CQA Monitor or at the manufacturing plant by the Geosynthetics Manufacturer. Samples will be forwarded to an independent testing laboratory for conformance testing. The CQA Monitor will review all conformance test results and report any non-conformance to the CQA Manager. The conformance tests presented in Table G-9 will be completed and accepted by the CQA Manager prior to shipment to the site. 6.2.3 Delivery Upon delivery of geomembrane, the CQA Monitor will: ■ Inspect geomembrane rolls for damage that potentially occurred during shipping and/or handling, then document the damaged materials and verify that damaged materials are set aside and not installed ■ Verify that geomembrane is stored in accordance with the technical specifications and the Geosynthetics Manufacturer's recommendations and is protected from puncture, dirt, grease, water, moisture, mud, mechanical abrasions, excessive heat, direct sunlight, and other potential causes of damage ■ Verify that each roll is marked or tagged with the Geosynthetics Manufacturer's name. project identification, lot number. roll number, and roll dimensions and that this information is documented in a Geomembrane Inventory Log ■ Verify that all MQC and submittal documentation required by the technical specifications has been received, reviewed, and filed ■ Verify that a Geomembrane Inventory Log has been completed for all geomembrane materials received Damaged geomembrane will be rejected. The CQA Monitor will verify that rejected material is removed from the site or stored at a separate location away from accepted geomembrane. Geomembrane that is not accompanied by the proper documentation from the Geosynthetics Manufacturer will also be stored at a separate location until all such documentation has been received and approved. 6.2.4 Review of Geomembrane Panel Drawings Before installing any geomembrane. the Geosynthetics Installer will submit shop drawings in accordance with the technical specifications. The shop drawings will show the proposed layout of the panels, field seams, and any other details that are needed to describe the proposed installation. The CQA Monitor will review these shop drawings prior to geomembrane installation and record the submittal in the Submittal Log. i \14\1407882b\0400\0406 edop rev311407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 42 1407882B Rev. 2 6.2.5 Subsurface Preparation Before geomembrane installation, the CQA Monitor will: ■ Verify that all lines and grades have been met by the Contractor ■ Verify that the subsurface has been prepared in accordance with the technical specifications 6.2.6 Subgrade Acceptance Prior to geomembrane deployment, the soil and GCL on which the geomembrane will be installed must be prepared in accordance with the technical specifications in Sections 5.4 and 6.1. Before geomembrane installation, the CQA Monitor and the Geosynthetics Installer must inspect the surface. The CQA Monitor will verify the following: ■ If the geomembrane is to be placed on soil subgrade, the soil has been prepared in accordance with the technical specifications ■ No sharp objects or other materials that could puncture the geomembrane are present on the surface ■ The anchor trench dimensions have been checked, and the trenches are free of sharp objects and stones ■ There are no excessively soft areas ■ The Geosynthetics Installer has certified, in writing on a subgrade acceptance form acceptable to the CQA Manager. that the surface on which the geomembrane will be installed is acceptable ■ The Contractor has signed the subgrade acceptance form ■ The subgrade acceptance form is prepared on a daily basis whenever geomembrane is being installed 6.2.7 Panel Layout As -built During installation, the CQA Monitor will maintain an up-to-date panel layout drawing that shows the following as -built information: ■ Orientation and size of each geomembrane panel ■ Roll numbers associated with each panel ■ Assigned panel numbers ■ Assigned seam numbers ■ Destructive test locations ■ Repair locations Before the geomembrane is covered, the Project Surveyor will survey the installed perimeter of geomembrane. The Project Surveyor will prepare an as -built drawing showing the location of installed geomembrane. i \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates a June 2017 Appendix G 43 1407882B Rev. 2 6.2.8 Panel Placement Documentation During panel placement operations, the CQA Monitor will: ■ Record panel numbers and dimensions in a Geomembrane Panel Deployment Log ■ Observe the panel surface as it is deployed and record all panel defects and defect corrective actions (e.g., panel rejection and patch installation) in the Geomembrane Repair Log ■ Verify that corrective actions and repairs are made in accordance with the technical specifications ■ Verify that equipment used during deployment operations does not damage the geomembrane ■ Verify that equipment used on the geomembrane does not leak hydrocarbons (i.e., fuels or oils) onto the geomembrane and that preventive measures are taken to avoid leakage ■ Verify that the surface beneath the geomembrane has not deteriorated since previous acceptance ■ Verify that stones, construction debris, and other items that could damage the geomembrane have been removed ■ Verify that a slip sheet is used to deploy geomembrane over GCL to prevent damage to the GCL ■ Verify that the geomembrane is not dragged across a potentially damaging surface ■ If the geomembrane is dragged across a surface that could damage the geomembrane, verify that the geomembrane is inspected for scratches and repaired or rejected if necessary ■ Verify that the geomembrane is not deployed in the presence of excessive moisture (e.g., fog. dew, or mist) ■ Verify that the geomembrane is not placed when the ambient air temperature is less than 40 degrees Fahrenheit or when standing water or frost is on the underlying material ■ Verify that crews working on the geomembrane do not smoke, wear shoes that could damage the geomembrane, or engage in activities that could damage the geomembrane ■ Verify that methods used to deploy the geomembrane minimize wrinkles and that panels are anchored and ballast is placed by the Geosynthetics Installer to limit movement by the wind ■ Verify that the Geosynthetics Installer corrects any damage to geomembrane resulting from movement by wind ■ Verify that no more panels are deployed than can be seamed on the same day The CQA Monitor will inform the Geosynthetics Installer and the CQA Manager if the panel placement requirements are not being met. The CQA Monitor will mark the location of observed damage to geomembrane and determine whether the material can be repaired. If it can be repaired, the repair must be performed in accordance with this CQA Plan and the technical specifications. All repairs will be documented. Material that cannot be repaired will be rejected, removed from the installation area, and moved away from the construction area so that it is not reinstalled. I 114\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 44 1407882B Rev. 2 6.2.9 Trial Welding and Production Welding Documentation Before the start of geomembrane production welding and during welding operations, each welder and welding apparatus will be tested in accordance with the technical specifications to verify that they are functioning properly. One trial weld will be performed before the start of work and one at mid -shift each day. Additional trial welds will be required if a machine is not in operation for a period longer than one hour. The trial weld sample will be at least 48 inches long and 12 inches wide.. with the seam centered lengthwise on the geomembrane sample. The CQA Monitor will observe all trial welding operations and verify that the Geosynthetics Installer quantitatively tests each trial weld for peel adhesion and bonded seam strength per ASTM D6392. Each required seam test will consist of five peel adhesion and five shear strength tests. The required seam tests and specifications are presented in Table G-10. Peel adhesion tests will be referred to as "peel" and bonded seam strength tests will be referred to as "shear" in this CQA Plan. The purpose of peel and shear tests is to evaluate seam strength. Shear strength measures the continuity of tensile strength through the seam and into the parent material. Peel adhesion measures the strength of the bond created by the welding process. The results of trial weld peel and shear tests will be recorded in a geomembrane trial welds form. Trial welds must be completed under conditions similar to those under which production seams will be welded. Trial welds must meet the specified requirements for peel and shear, and the failure must be ductile or a film tearing bond (FTB). If at any time the CQA Monitor believes that a welding apparatus is not functioning properly, a trial weld must be performed. If there are wide changes in temperature (±30 degrees Fahrenheit), humidity, or wind speed.. another trial weld must be performed. The trial weld must be allowed to cool to ambient temperature before it is tested. During geomembrane welding operations, the CQA Monitor must: • Verify that the Geosynthetics Installer has the number of welding apparatuses and spare parts necessary to continuously perform the work • Verify that the equipment used for welding will not damage the geomembrane ■ Verify that extrusion welders are purged before beginning a weld so that heat -degraded extrudate is removed from the nozzle of the welder • Verify that seam grinding is completed less than 30 minutes before seam welding and that the upper sheet is beveled (extrusion welding only) • Verify and document that the ambient temperature measured 6 inches above the geomembrane surface is between 40 and 104 degrees Fahrenheit • Verify that the ends of extrusion welds that are more than five minutes old are ground to expose new material before restarting a weld • Verify that contact surfaces of the panels are clean and free of dust. grease, dirt, debris, and moisture before welding • Verify that welds are free of dust. rocks, and other debris • Verify that cross seams are ground to a smooth incline before welding (fusion welding only) i \14\1407882b\0400\0406 edop rev311407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 45 1407882B Rev. 2 • Verify that all seams are overlapped a minimum of 3 inches or in accordance with the Geosynthetics Manufacturer's recommendations, whichever is more stringent • Verify that solvents or adhesives are not present in the seam area • Verify that the procedures used to temporarily hold the panels together do not result in damage to the panels and do not preclude CQA testing • Verify that panels are being welded in accordance with the construction drawings and technical specifications • Verify that there is not free moisture in the weld area • Document seaming operations and weather conditions in a Geomembrane Seam Welding Log • For extrusion welded seams, verify that the extrudate or bead conforms to the requirements presented in Table G-10 6.2.10 Non-destructive Seam Testing The purpose of non-destructive geomembrane seam testing is to detect discontinuities or holes in the seams. Non-destructive geomembrane tests include vacuum and air pressure testing. Non-destructive testing must be performed over the entire length of the welded seam. It is the Geosynthetics Installers responsibility to perform all non-destructive testing as part of the CQC program, then record and report the results to the CQA Monitor. The CQA Monitor's responsibility is to observe and independently document in a Geomembrane Non-destructive Test Summary Form that the Geosynthetics Installer's CQC testing is in compliance with the technical specifications and independently document seam defects and panel defects that the Geosynthetics Installer detects on a Geomembrane Repair Log. The non-destructive testing procedures are described in this section. For welds tested by vacuum method, the weld is placed under suction using a vacuum box constructed with rigid sides, a transparent top for viewing the seams, a neoprene rubber gasket attached to the bottom of the rigid sides, a vacuum gauge on the inside, and a valve assembly attached to a vacuum hose connection. Procedures outlined in ASTM D5641 will be used to perform the testing. The vacuum box is placed over a seam section that has been thoroughly wetted with a soapy water solution. The rubber gasket on the bottom of the box must fit snugly against the soaped seam section of the panel to ensure a leak -tight seal. A vacuum pump is energized and a vacuum of approximately five psi is applied to the segment of the geomembrane seam that is covered by the vacuum box. Pinholes or seam defects are indicated by the appearance of soap bubbles in the vicinity of the defect. Dwell time for the applied vacuum will not be less than 10 seconds. Air pressure testing is used to test the double wedge -welded seams that have an enclosed air space (channel) between the wedge welds. Procedures outlined in ASTM D5820 will be used for this test procedure. Both ends of the air channel are sealed. A pressure feed device, usually a needle equipped i \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 46 1407882B Rev. 2 with a pressure gauge, is inserted into one end of the channel. Air pressure is then increased in the channel to a minimum specified pressure according to the technical specifications. A five-minute relaxation period is allowed for the pressure to stabilize. The air chamber must sustain the pressure as specified in the technical specifications. Following a passed pressure test, and while the air pressure is sustained, the end of the air channel opposite the needle and gauge is punctured to release air in the channel. The pressure gauge should return to zero. If it does not, a blockage is likely present in the seam channel. When a blockage is detected, it will be located and the seam retested on both sides of the blockage. The penetration holes must be repaired after testing. During non-destructive testing, the CQA Monitor must: ■ Review the technical specifications and associated standards regarding test procedures and verify that all testing is completed in accordance with the technical specifications and standards ■ Verify that the equipment operators are fully trained and qualified to perform their work ■ Verify that the test equipment meets the requirements indicted in the technical specifications and test standards ■ Verify that the entire length of each seam is tested ■ Observe all testing and independently record the test results in a Geomembrane Non-destructive Test Summary Form and the Geomembrane Seam Welding Log ■ Identify failed areas detected by the Geosynthetics Installer by marking the area with a waterproof marker, verify that the Geosynthetics Installer is aware of the required repair. and document the completion of the repair in the Geomembrane Repair Log 6.2.11 CQC Destructive Seam Sampling and Field Testing The purpose of destructive seam sampling and testing is to demonstrate seam quality during construction. Destructive seam testing will be conducted at the required interval along the completed seam length for each welding apparatus. Samples will be removed from the completed seam by the Geosynthetics Installer at locations selected by the CQA Monitor. Samples measuring 48 inches by 12 inches will be cut into thirds. One piece will be used for CQC testing by the Geomembrane Installer, one piece will be used for CQA testing by the CQA Consultant. and one sample will be archived for additional testing if required. CQC samples will be cut into 10 one -inch -wide specimens. Five specimens will be tested for peel and five specimens will be tested for shear. The results must meet the requirements of Table G-10 and the technical specifications. Four of the five tests for peel are required to pass and four of the five tests for shear are required to pass. If one of the five tests for peel or shear fail, the strength must meet or exceed 80% of the requirements in Table G-10. \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 47 1407882B Rev. 2 Destructive seam testing will be conducted at 750 -foot intervals. Additional specimens may be taken at any time if the CQA Monitor suspects that a seam does not meet the requirements. Reasons for taking additional samples may include, but are not limited to: ■ Wrinkling in the seam area ■ Crystallinity in the seam area ■ Suspect seaming equipment or techniques ■ Weld contamination ■ Insufficient overlap ■ Adverse weather conditions ■ Failing tests The Geosynthetics Installer must remove specimens at the locations identified by the CQA Monitor and then test the specimens for peel and shear using the same procedures used for trial welds as presented in Table G-10. During sampling, the CQA Monitor will: ■ Observe sample cutting ■ Mark each specimen with an identifying number and record the seam number, welder, weld date, and weld time corresponding to the specimen number ■ Record the specimen locations in the panel layout drawing ■ Record the specimen locations in the Geomembrane Repair Log ■ Record the Geosynthetics Installer's test results in the Summary of Destructive Tests Form The Geosynthetics Installer must test seam specimens at the project site using a calibrated tensiometer capable of quantitatively measuring shear and peel strengths in accordance with ASTM D6392. For double wedge welding, both sides of the air channel will be tested for peel strength. The CQA Monitor will observe the tests. A specimen will be considered to have passed when the break is a ductile FTB. An FTB is indicated when the test specimen breaks at the edge or the outside of the seam, but not in the seam. In addition, the seam strength must meet the minimum values specified in Table G-10. If any of the specimens fail to meet the specified seam quality, the Geosynthetics Installer can, at his discretion, reconstruct the entire seam or take two additional test samples at least 10 feet in each direction from the point of the failed specimen. At that point, the Geosynthetics Installer can repeat the peel and shear tests. If subsequent specimens fail to meet the specified seam quality, this procedure will be repeated until the length of poor -quality seaming is established. Repeated failures indicate that the seaming equipment or operator is not performing adequately, and appropriate corrective action will be taken immediately. \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 48 1407882B Rev. 2 6.2.12 CQA Destructive Seam Testing The purpose of CQA destructive seam testing is to verify the findings of CQC destructive seam sampling and field testing. Additional CQA tests may be taken if the CQA Monitor suspects that a seam does not meet the requirements of the technical specifications. CQA testing will be performed on 100% of all CQC destructive test samples. CQA samples will be cut into 10 one -inch -wide specimens. CQA destructive seam test specimens will be tested for peel and shear by the CQA Consultant using the procedures in ASTM D6392 and outlined (above) for CQC testing. This testing can be performed on site in an environment that complies with ASTM D6392 and using equipment that complies with ASTM D6392 or off site in a qualified laboratory. During sampling and testing, the CQA Monitor will: • Observe sample cutting • Mark each specimen with an identifying number and record the seam number, welder, weld date. and weld time corresponding to the specimen number • Record the specimen locations in the panel layout drawing • Record the specimen locations in the Geomembrane Repair Log • Record the CQA laboratory test results in the Summary of Destructive Tests Form Four of the five tests for peel are required to pass and four of the five tests for shear are required to pass. If one of the five tests for peel or shear fail, the strength must meet or exceed 80% of the requirements in Table G-10. If any of the CQA test specimens fail to meet the specified seam quality, the Geosynthetics Installer can. at his discretion, reconstruct the entire seam or take two additional test samples at least 10 feet in each direction from the point of the failed specimen. At that point, the CQA Consultant can repeat the testing. If subsequent specimens fail to meet the specified seam quality, this procedure will be repeated until the length of poor -quality seaming is established. Repeated failures indicate that the seaming equipment or operator is not performing adequately, and appropriate corrective action will be taken immediately. 6.2.13 Repairs Repairs are required where geomembrane panels or seams contain a flaw, where a destructive test sample has been taken, and where a "T" intersection exists at corners of welded panels. All of these repairs must be made in accordance with the technical specifications. The CQA Monitor will locate the required repairs and document the completion of repair work in a Geomembrane Repair Log. Acceptable repair techniques include the following: ■ Patching — used to repair large holes, tears, panel defects. undispersed raw materials, welds, contamination by foreign matter. destructive sample locations, and "T" locations in panel welds \14\1407882b\0400\0406 edop rev311407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 49 1407882B Rev. 2 ■ Extrusion — used to repair small defects, generally those measuring less than 1/2 inch in the largest dimension, in panels and seams ■ Capping — used to repair failed welds or to cover seams where welds cannot be non-destructively tested ■ Removal (followed by patching or capping) — used to replace areas with large defects when the preceding methods are not appropriate or to remove excess material (e.g., wrinkles, fishmouths, and intersections) from the installed geomembrane 6.2.14 Wrinkles During placement of soil materials over geomembrane, temperature changes may cause wrinkles to develop in the geomembrane. Wrinkles that can fold over will be repaired either by cutting out excess material or, if possible, by allowing the geomembrane to contract by temperature reduction. In no event will material be placed over the geomembrane where the weight could result in the geomembrane folding. The CQA Monitor will observe geomembrane surfaces for wrinkles and notify the Geosynthetics Installer if wrinkles are being covered by soil. The CQA Monitor is then responsible for documenting the corrective action to remove the wrinkles on the Daily Progress Report. 6.2.15 Anchor Trench The anchor trench will be excavated to the lines, grades, and widths shown on the construction drawings prior to geosynthetic materials placement and left open until seaming is completed. The CQA Monitor will verify that the anchor trench has been constructed according to the construction drawings. Expansion and contraction of the geomembrane will be accounted for in its placement. Geosynthetic materials will be extended into the anchor trench as shown on the construction drawings. The geosynthetic materials will be seamed, bonded, or attached along the entire length of the anchor trench. The anchor trench will be backfilled in 9- to 12 -inch -thick loose lifts and compacted by wheel rolling with light, rubber -tired compaction equipment or other compaction equipment approved by the CQA Consultant. Anchor trench backfill material will be moisture -conditioned and compacted in accordance with the requirements for structural fill and to the satisfaction of the CQA Monitor. Backfilling will take place in cooler parts of the day to reduce potential bridging of the geomembrane. Care shall be taken when backfilling the anchor trench to prevent damage to the geosynthetic materials. At no time will construction equipment come into direct contact with the geosynthetic materials. Any damage that occurs will be repaired by the Contractor prior to the completion of backfilling. 6.2.16 Electrical Liner Integrity Testing The best available technology for directly locating defects (i.e., holes, leaks) in the constructed geomembrane is the use of geoelectric leak location methods, known as "liner integrity surveys" when performed at the time of liner construction. The geomembrane will be tested both bare and after covering with the sand drainage layer material. Electrical liner integrity testing may be performed on either standard \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 50 1407882B Rev. 2 or conductive -backed HDPE geomembrane, in accordance with applicable ASTM standards. Test methods and apparatus may vary depending on the type of geomembrane used. Electrical liner integrity testing will only be performed on the continuous (primary) geomembrane liner and not on the additional layer of geomembrane placed within the sump areas. 6.2.16.1 Work Plan Prior to commencement of the electrical liner integrity survey (ELIS), the liner integrity consultant shall submit a Work Plan to the CQA Manager. The Liner Integrity Survey Work Plan shall include: ■ Qualifications of the proposed liner integrity consultant including the square footage and number of projects of successful method application the liner integrity consultant has performed of the proposed survey method. ■ Description of the proposed survey method, procedures, site preparations, estimated duration of survey, and quality control and field sensitivity testing procedures. ■ A Statement of Qualifications meeting the following requirements: • The ELIS consultant shall be qualified and have experience in conducting liner integrity surveys of the proposed method(s). • The ELIS shall be supervised by an experienced, certified, and qualified professional or technician. ■ A list of number and types of defects located for the three qualifying projects of the supervising ELIS technician or documentation of the ELIS operator certification for said technician. 6.2.16.2 Bare Geomembrane 6.2.16.2.1 Test Preparation The ELIS consultant shall be provided with drawings showing: ■ All layers constituting the lining system and details of all liner penetrations. ■ Plan of the survey area. ■ Peripheral details, including welds to adjacent lining systems. ■ Structures and obstructions above the liner, if any. ■ Electrical equipment above the geomembrane. The Geosynthetics Installer shall be responsible for preparing the survey area for the ELIS activities. The preparation consists of, but is not limited to, the following: ■ Install any necessary electrodes. ■ Provide the ELIS consultant the liner installation schedule and underliner wires (as needed) to perform ELIS. ■ Provide a water truck and driver with water as a continuous water source for the ELIS testing, if required by ELIS consultant. i 114\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx (;older s4Otiate:s June 2017 Appendix G 51 1407882B Rev. 2 ■ Provide one laborer per ELIS equipment operator to assist with the ELIS testing, if required by ELIS consultant. ■ Remove and dispose of residual water, as needed. ■ Render the geomembrane clean and uncluttered. Remove all standing water from the surface of the geomembrane and provide electrical isolation at the perimeter of the survey area. The survey area must have a low point where water is allowed to collect if the water -based survey methods are used. As the survey progresses. water is sprayed onto the liner. If the water exits the survey area and touches the surrounding ground, the survey cannot be performed. Often features such as rain flaps and berms are required to keep the water restrained to the survey area. In addition, the subgrade must contain sufficient moisture to conduct the survey unless conductive -backed geomembrane is being tested. One percent moisture by weight is usually adequate. It may be necessary to wet the subgrade if it has desiccated before deployment of the geomembrane; however, the surface tends to rehydrate after several days by wicking up moisture from the underlying soil. The installed geomembrane may also be wetted with approximately 0.1 inches of water (2,700 gallons per acre) several days before the performance of the ELIS. An equivalent recent rainfall would also suffice. The Geosynthetics Installer must be prepared to repair any holes in the geomembrane drilled for calibration. 6.2.16.2.2 Testing The ELIS testing shall be performed directly after the installation of the geomembrane. The ELIS consultant is responsible for calibrating equipment utilized to achieve optimum data quality and sensitivity for the site conditions. This usually involves drilling some holes in the geomembrane. which will be required to be repaired by the Geosynthetics Installer. The ELIS testing is optimally performed when the geomembrane is in intimate contact with the GCL, unless conductive geomembrane is being tested. Wrinkles are an impediment to conducting a good survey. Defects on wrinkles may not be detected. Therefore, whenever possible depending on weather conditions and other project considerations, the ELIS will conducted when the liner system is cool and flat, such as in the morning or during the night. The ELIS consultant will: ■ Identify any defect locations and will log, visibly mark, and report the location for repair. ■ Report the results of the ELIS testing to the CQA Monitor and Geosynthetics Installer daily. ■ Submit a list of locations of the defects detected to the CQA Monitor and Geosynthetics Installer prior to the demobilization from the site ■ Submit a letter report documenting the field work and results of the surveys to the Geosynthetics Installer within 14 days after completion of the field work. \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx ;older Associates June 2017 Appendix G 52 1407882B Rev. 2 6.2.16.3 Covered Geomembrane 6.2.16.3.1 Test Preparation The ELIS consultant shall be provided with drawings showing: ■ All layers constituting the lining system and details of all liner penetrations. • Plan of the survey area. • Peripheral details, including welds to adjacent lining systems. • Structures and obstructions above the liner, if any • Electrical equipment above the geomembrane. The Geosynthetics Installer shall be responsible for preparing the survey area for the ELIS activities. The preparation consists of, but is not limited to, the following: • Install any necessary electrodes. • Coordinate with the ELIS consultant to provide a survey area within the lined area that is electrically isolated from the surrounding ground (i.e., the sand drainage layer soil is not tied into the ground surface outside of the survey area). Isolation can be accomplished by open trenching or installation of a non-conductive insulator such as the liner materials. • Provide the ELIS consultant the liner installation schedule. • Provide water, water truck and driver, and wet the survey area prior to and during the dipole survey to ensure that there is adequate moisture in the material(s) covering the geomembrane for the dipole ELIS testing. To detect a defect, moisture must exist in the defect and be in contact with moisture in the materials above and below the liner. Therefore, the material(s) covering the geomembrane must be moistened with water prior to conducting the ELIS survey. In order to achieve uniform moisture distribution, the Geosynthetics Installer shall add water as the construction progresses on and within cover layer(s). A water truck must be available at all times as it may be necessary to wet the surface just in advance of the survey, as deemed necessary by the ELIS consultant. • The calibration process requires digging a hole down to the surface of the geomembrane to place the artificial leaks. The Contractor is to provide a backhoe and/or hand labor, as appropriate, to excavate the cover soils down to the geomembrane. A water source must also be provided to rehydrate the soil as it is backfilled over the artificial leaks, preferably a water truck. The Geosynthetics Installer is also responsible for backfilling the calibration hole, and uncovering and retrieving the artificial leak apparatus, and backfilling the hole appropriately, including patching any intervening geotextiles. • Render the geomembrane clean and uncluttered. Remove all standing water from the surface of the geomembrane and provide electrical isolation at the perimeter of the survey area. The Geosynthetics Installer must be prepared to repair any holes in the geomembrane drilled for calibration. 6.2.16.3.2 Testing The dipole ELIS survey shall be performed after the placement of the sand drainage layer. The ELIS consultant is responsible for calibrating all equipment utilized to achieve optimum data quality and sensitivity i \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 53 1407882B Rev. 2 for the site conditions. Data acquisition shall be GPS-based and a voltage map of the recorded dipole measurements shall be generated in three dimensions with appropriate contour intervals and colored voltage ranges. The sensitivity test shall include a voltage map of the area including the artificial leak location. Manual measurements shall be made to verify defect signals after data analysis and to pinpoint the defect positions on top of the sand drainage layer for excavation while the survey personnel are on site. Within one foot of the liner. the Geosynthetics Installer's laborers shall hand -excavate possible defect locations to expose the liner. Additional manual measurements should be made to guide the Geosynthetics Installer's personnel while they excavate the defect, if required. The ELIS consultant will: ■ Identify any defects and will log, visibly mark, and report the location for repair. ■ After the identification and excavation of a defect, the geomembrane liner around the defect location shall be visually inspected while the defect is uncovered and cleaned to check for adjacent defects. ■ Report the results of the integrity testing to the CQA Monitor and Geosynthetics Installer daily ■ Submit a list of locations of the defects detected to the CQA Monitor and Geosynthetics Installer prior to the demobilization from the site ■ Submit a letter report documenting the field work and results of the surveys to the Geosynthetics Installer within 14 days after completion of the field work. 6.2.17 Acceptance Geomembrane installation is accepted when the following conditions are met: ■ The installation is finished in accordance with the construction drawings and technical specifications, as determined by the CQA Manager ■ All seams have been inspected and tested, all required tests have been completed, the tests have passed, the test data have been reviewed, and approval has been given by the CQA Manager ■ The ELIS testing on the geomembrane (before and after sand drainage layer placement) has been completed and the tests have passed. the test data have been reviewed, and approval has been given by the CQA Manager ■ All required documentation has been received. reviewed, and filed ■ All record drawings have been completed and verified by the CQA Manager to show the true panel dimensions and locations of all seams, trenches. pipes, appurtenances, and repairs \14\1407882b\0400\0406 edop rev311407882b app g cqa plan rev2 01jun17 docx II Golder Associates June 2017 Appendix G 54 1407882B Rev. 2 6.3 Geotextile Quality Assurance 6.3.1 Pre -Construction Submittal Review Prior to scheduled delivery of geotextile materials, the Geosynthetics Manufacturer will provide the following items to the CQA Consultant for review: • The Geosynthetics Manufacturer's description (cut sheet) of the proposed geotextile materials documenting that they will meet or exceed the specified requirements • Written instructions for storage. handling. installation, seaming. and repair of the proposed geotextile materials If the properties outlined in the technical specifications differ from those listed on the Geosynthetics Manufacturer's cut sheet, the Geosynthetics Manufacturer will provide an alternate product. Prior to shipment of geotextile materials, the CQA Consultant will review the submittals for conformance with the technical specifications. Prior to scheduled installation, the CQA Monitor will complete geotextile conformance testing in accordance with this CQA Plan and record the sampled roll numbers. All submittals received by the CQA Consultant will be recorded on the Submittal Log and then placed in the project files for review by the CQA Monitors. 6.3.2 Conformance Testing The CQA Consultant will obtain a set of conformance test samples for every 100,000 square feet of each type of geotextile material manufactured for the project. Each sample will be sent to the CQA Laboratory for conformance testing. The CQA Monitor will review all test results and report any non-conformance to the CQA Manager. The conformance tests listed in Table G-13 will be completed at least seven days prior to scheduled installation of geotextile materials, and the sampled roll numbers will be recorded on a Geotextile Inventory Log. 6.3.3 Delivery During delivery of geotextile materials, the CQA Monitor will: • Verify that the equipment used to unload the rolls will not damage the geotextile ■ Verify that the rolls are wrapped in impermeable and opaque protective covers ■ Verify that care is used in unloading the rolls • Verify that all MQC and submittal documentation required by the technical specifications has been received, reviewed, and filed • Verify that each roll is marked or tagged with the Geosynthetics Manufacturer's name. project identification. lot number. roll number, and roll dimensions and that this information is documented on a Geotextile Inventory Log 11411407882b1040010406 edop rev311407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 55 1407882B Rev. 2 ■ Verify that materials are stored in a location that is protected from ultraviolet light exposure, precipitation, mud, dirt, dust, puncture, and any other damaging or deleterious conditions Damaged material will be rejected. If a roll is rejected, the CQA Monitor will verify that the rejected material is removed from the site or stored at a location separate from accepted material. Geotextile rolls that are not accompanied by the proper documentation from the Geosynthetics Manufacturer will also be stored at a separate location until all such documentation has been received and approved. 6.3.4 Subsurface Preparation Before geotextile installation, the CQA Monitor will: ■ Verify that installation of the underlying layer is complete and that its thickness requirement has been met, if the geotextile is to be placed on earthen materials ■ Verify that geomembrane installation is complete and CQC and CQA documentation establishes that the specified requirements have been met, if the geotextile is to be placed on geomembrane ■ Verify that stones or other protruding objects that could damage the geotextile have been removed from the surface of the underlying layer ■ Verify that all construction stakes have been removed 6.3.5 Placement and Seaming During geotextile placement and seaming operations, the CQA Monitor will: ■ Observe the geotextile materials as they are deployed and identify defects ■ Verify that corrective actions are performed in accordance with the technical specifications and record these corrective actions in the Daily Progress Report ■ Verify that the equipment used to install geotextile materials does not damage them during deployment ■ Verify that crews working on the geotextile do not smoke, wear shoes that could damage the geotextile, or engage in activities that could damage the geotextile ■ Verify that the geotextile is anchored and ballast is placed by the Geosynthetics Installer to limit movement by the wind ■ Verify that adjacent panels are overlapped and seamed in accordance with the technical specifications ■ Verify that geotextile materials were not exposed to direct sunlight for longer than the time recommended by the manufacturer ■ Examine the geotextile after installation to confirm that potentially harmful objects have been removed The CQA Monitor will inform the CQA Manager and the Geosynthetics Installer if the placement and seaming requirements are not being met. \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 56 1407882B Rev. 2 6.3.6 Repairs Where repairs are necessary, the CQA Monitor will verify that the following methods are used: ■ Patching — Used to repair large holes, tears, and small defective areas ■ Removal and replacement — Used to replace large defective areas where the preceding method is not appropriate \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 57 1407882B Rev. 2 Table G-6: Manufacturer Quality Control and Conformance Testing of Geosynthetic Clay Liner Testing Qualifier Units I Specification I MQC Test Frequency Conformance Test Frequency GCL Properties Bentonite Area (ASTM D5993) Mass per Unit minimum pounds square per foot 0.75 One square per 5,000 yards One 100,000 feet per square Grab (ASTM Tensile D6768) Strength(') minimum inch pounds per 23 One square per 25,000 feet None Hydraulic (ASTM Conductivity D5887) maximum centimeters per second 5 x 10.9 One square per 30,000 yards One 100,000 feet per square Peel (ASTM Strength D6496) minimum inch pounds per 2.1 One square per 5,000 yards One 100,000 feet per square Bentonite Properties(2) Swell (ASTM Index D5890) minimum milliliters 2 grams per 24 1 per 50 tons None Fluid (ASTM Loss D5891) _ maximum 18 1 per 50 tons None milliliters Notes: 1 Tensile testing shall be performed in the machine direction on a 4 -inch -wide specimen. 2 Bentonite must be granular and greater than 90% montmorillonite clay. I \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 58 1407882B Rev. 2 Table G-7: Manufacturer Quality Control Testing of 60 -mil Textured HDPE Geomembrane Testing Qualifier Units Specification MQC Frequency Test (ASTM Thickness D5994) I minimum minimum mils mils 57 51 (average) (lowest) Each Each roll roll (ASTM D7466; Height minimum mils I 10 IAsperity (average) Every roll(') second Density (ASTM D792 or ASTM D1505) minimum grams centimeter per cubic I 0.940 (average) One 200,000 per pounds Tensile (ASTM Yield Break Yield Break Properties(2) D6693, Stress Elongation Stress Elongation Type IV) i minimum minimum minimum pounds pounds % % per inch per inch 126 90 12 100 (average) (average) (average) (average) One pounds per 20,000 minimum Tear (ASTM Strength D1004) minimum pounds 42 (average) One pounds per 45,000 Puncture (ASTM D4833) Resistance minimum pounds 90 (average) One pounds per 45,000 Stress (ASTM Crack D5397 Resistance) Appendix) hours 300 Per GRI GM10 Carbon (ASTM Black D4218) Content(4) minimum maximum c)/0 % 2.0 3.0 One pounds per 20,000 Carbon (ASTM Black D5596) Dispersion None None 9 1 Category Category 1 i or 2 3(5) One pounds per 45,000 Oxidative Standard High Pressure Induction (ASTM (ASTM Times) D3895) or D5885) minimum minimum minutes minutes 100 400 (average) (average) One 200.000 per pounds Oven (ASTM Standard High Aging(6' Pressure D5721) (ASTM 7) (ASTM D3895) or D5885) I minimum minimum % after ,°/0 after 90 days 90 days 55 (average) 80 (average) Each formulation Ultraviolet (ASTM High Pressure(9) D7238) Resistances) (ASTM D5885) _minimum _°/o after 1,600 hours 50 (average) formulation Each Notes 1) Asperity height testing applies to textured geomembrane only. Ten readings are required for each test. The side being measured shall be alternated The lowest individual reading must be at least 5 mils, and eight of ten readings must be at least 7 mils. 2) Machine direction and cross -machine direction average values shall be on the basis of five test specimens in each direction. Yield elongation is calculated using a gage length of 1.3 inches. Break elongation is calculated using a gage length of 2.0 inches. 3) The test shall be conducted on smooth edges of textured geomembrane rolls or on smooth sheets made from the same formulation used for the textured geomembrane. The yield stress used to calculate the applied load for the test should be the Geosynthetics Manufacturer's mean value from MQC testing 4) Other means such as ASTM D1603 or ASTM D6370 are acceptable if an appropriate correlation to ASTM D4218 can be established. 5) For only near spherical agglomerates. out of 10 different views 6) The Geosynthetics Manufacturer has the option to select either of the oxidative induction time methods listed to evaluate the antioxidant content in the geomembrane. 7) It is also recommended to evaluate samples at 30 and 60 days for comparison with the 90 -day response. 8) The condition of the test should involve a 20 -hour ultraviolet cycle at 75 degrees Celsius followed by a 4 -hour condensation period at 60 degrees Celsius. 9) Ultraviolet resistance is based on the percent retained regardless of the original high-pressure oxidative induction time. 111411407882b1040010406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 59 1407882B Rev. 2 Table G-8: Manufacturer Quality Control Testing of High -Density Polyethylene Resin Testing(') Qualifier Units Specification MQC FIrequency Test Density (ASTM D792 or ASTM D1505) grams centimeter per cubic 0.932 (average) Each batch resin minimum Melt (ASTM Index D1238) grams i minutes per 10 1.0 I Each batch resin maximum Oxidative Standard High Induction Pressure (ASTM (ASTM Time(293) D3895) or D5885) _minimum minutes minutes 100 400 (average) (average) Each formulation minimum - Notes: 1) Resin without carbon black. 2) The Geosynthetics Manufacturer has the option to select either of the oxidative induction time methods listed to evaluate the antioxidant content in the geomembrane. 3) It is also recommended to evaluate samples at 30 and 60 days for comparison with the 90 -day response. \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 60 1407882B Rev. 2 Table G-9: Conformance Testing of 60 -mil Textured HDPE Geomembrane Testing Qualifier I Units Specification Test Frequency Thickness (ASTM D5994) minimum minimum mils mils I i 57 51 (average) (lowest) One per lot or per 100,000 sf Asperity (ASTM D7466) Height(') minimum mils 10 (average) One per lot or per 100,000 sf Density (ASTM D792 or ASTM D1505) minimum grams centimeter per cubic 0.940 (average) One per lot or per 100,000 sf Tensile (ASTM Yield Break Yield Break Properties(2) D638) Stress Stress Elongation Elongation pounds pounds % `)/0 per inch per inch 126 90 12 100 (average) (average) (average) (average) One per lot or per 100,000 sf minimum minimum minimum minimum Carbon (ASTM Black D1603)(3) Content minimum maximum `)/0 yo 2.0 3.0 One per lot or per 100,000 sf Carbon (ASTM Black D5596) Dispersion None None 9 2 Category Category 1 3(4) or One per lot or per 100,000 sf Tear (ASTM Strength D1004) minimum pounds al 42 (average) One per lot or 100,000 sf Puncture (ASTM D4833) Resistance minimum pounds _ 90 (average) One per lot or per 100,000 sf Notes. 1) Asperity height testing applies to textured geomembrane only. Ten readings are required for each test. The side being measured shall be alternated. The lowest individual reading must be at least 5 mils, and 8 of 10 readings must be at least 7 mils. 2) Machine direction and cross -machine direction average values shall be on the basis of five test specimens in each direction. Yield elongation is calculated using a gage length of 1.3 inches. Break elongation is calculated using a gage length of 2.0 inches. 3) Other means such as ASTM D1603 or ASTM D6370 are acceptable if an appropriate correlation to ASTM D4218 can be established. 4) For only near spherical agglomerates, out of 10 different views. \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 61 1407882B Rev. 2 Table G-10: 60 -mil Textured HDPE Geomembrane Seam Testing Testing Qualifier Units Specification MQC Frequency Test Shear (ASTM Strength D6392) minimum pounds per inch 120 Every weld 750 machine feet weld length per Shear (ASTM Elongation D6392) at Break minimum % 50 Every weld 750 machine feet weld length per Peel (ASTM Strength D6392) Every weld 750 machine feet weld length per Fusion minimum pounds per inch 91 Extrusion minimum pounds per inch 78 Peel Separation Every 750 feet weld length per (ASTM D6392) _°/0 25 weld machine maximum Table G-11: Manufacturer Quality Control of Extrudate or Bead Testing Qualifier Units Specification MQC Frequency Test Density (ASTM D792 Method B or minimum grams centimeter per cubic 0.932 One per resin lot or batch ASTM D1505) Carbon Black Content % 2.0 One per resin lot or batch minimum (ASTM D1603) maximum _°/O 3.0 Melt (ASTM Index D1238) maximum grams minutes per 10 1.0 One per resin lot or batch \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17.docx Golder Associates June 2017 Appendix G 62 1407882B Rev. 2 Table G-12: Geosynthetics Field CQA/CQC Testing Requirements Item Parameter Test Method QC Frequency Test QA Frequency Test Verification GCL Liner Overlap Observation Continuous Continuous Bentonite in overlap Observation Continuous Continuous HDPE Geomembrane All A Observation Continuous 20% Nondestructive Seam Testing: Fusion Weld Continuity Air ASTM Pressure Testing D5820 Each Seam Each Seam Extrusion Continuity Weld Vacuum ASTM D5641 Box Testing Each Seam Each seam Destructive Seam Testing: Fusion Extrusion Weld Weld / Testing Shear: Peel: ASTM ASTM D6392 4 D6392 Every weld weld length 750 machine feet per Observation destruct sample. of each Pre Extrusion/Fusion -weld Testing: _ Shear: Peel: ASTM ASTM D6392 D6392 Beginning shift machine of per weld each Observation pre -weld test of seam. each Notes: 1. Additional pre -weld testing will be required every four hours, or if a power interruption or breakdown of welding equipment occurs, a trial seam will be produced prior to resumption of seaming operations. i \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 63 1407882B Rev. 2 Table G-13: Conformance Testing for Geotextile Testing Qualifier Units 'Specification Test Frequency 8 oz/sy Non -woven Geotextile Mass (ASTM Per D5261) Unit Area ounces yard per square 8 (average) One 100,000 feet per square minimum Grab (ASTM Strength D4632) pounds 220 (average) One 100,000 feet per square minimum Trapezoidal (ASTM D4533) Tear Strength pounds 90 (average) One 100,000 feet per square minimum Puncture (ASTM D6241) Resistance minimum pounds 575 (average) One 100,000 feet per square Permittivity (ASTM D4491) minimum per second 1.3 (average) One 100,000 feet per square Apparent (ASTM D4751) Opening Size maximum inches 0.007 (average) One 100,000 feet per square 12 oz/sy Non -woven Geotextile Mass (ASTM Per D5261) Unit Area minimum ounces yard per square 12 (average) One 100,000 feet per square Grab (ASTM Strength D4632) minimum pounds 320 (average) One 100,000 feet per square Trapezoidal (ASTM D4533) Tear Strength minimum pounds 125 (average) feet One 100,000 per square Puncture (ASTM D6241) Resistance minimum pounds 925 (average) feet One 100,000 per square Permittivity (ASTM D4491) minimum per second 0.8 (average) feet One 100,000 per square Apparent (ASTM D4751) Opening Size maximum inches 0.006 (average) feet One 100,000 per square \14\1407882b\040010406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 64 1407882B Rev. 2 Testing Qualifier Units Specification p 'Test Frequency 16 oz/sy Non -woven Geotexti le Mass (ASTM Per D5261) Unit Area minimum ounces yard per square 16 (average) One 100,000 feet per square Grab (ASTM Strength D4632) minimum pounds 390 (average) One 100,000 feet per square Trapezoidal (ASTM D4533) Tear Strength minimum pounds 150 (average) One 100,000 feet per square Puncture (ASTM D6241) Resistance minimum pounds 1,125 (average) One 100,000 feet per square Permittivity (ASTM D4491) minimum per second i 0.6 (average) One 100,000 feet per square Apparent (ASTM D4751) Opening Size inches 0.006 (average) One 100,000 feet per square maximum \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx ct Golder Associates June 2017 Appendix G 65 1407882B Rev. 2 7.0 MECHANICAL CQA 7.1 HDPE Header and Riser Pipe Conformance and Construction Testing This section describes CQA procedures for HDPE header and riser pipe installations. Perforated and solid - wall HDPE pipe will be utilized to construct components of the leachate collection and recovery system. Installation requirements are provided in the technical specifications. 7.1.1 Pre -Construction Submittal Review Prior to shipment of HDPE pipe, the Geosynthetics Installer or the Contractor will provide the following information to the CQA Consultant for review: ■ A list of individuals certified for HDPE pipe fusion welding, including a copy of their current certificates ■ The manufacturer's product data for pipe and fittings demonstrating that the materials will comply with the technical specifications ■ A copy of MQC data for the materials ■ Information about the proposed welding system for the project ■ Written instructions from the manufacturer for storage and handling All submittals received by the CQA Consultant will be recorded on the Submittal Log and then placed in the project files for review by the CQA Monitors. 7.1.2 Delivery During delivery of HDPE pipe the CQA Monitor will: ■ Verify that the equipment used to unload the pipe does not damage the material ■ Verify that care is used in unloading the pipe ■ Verify that all documentation required by the technical specifications has been received, reviewed, and filed ■ Verify that materials are stored in a location that will protect the pipe from puncture, cutting, and any other damaging or deleterious conditions ■ Verify that materials are not stacked higher than the maximum height listed in the technical specifications or recommended by the manufacturer ■ Verify that the materials have the required markings as described in the technical specifications Damaged pipe will be rejected. If pipe is rejected, rejected material will be removed from the site or stored at a location separate from accepted materials. Pipe that is not accompanied by the proper documentation from the manufacturer will also be stored at a separate location until all such documentation has been received and approved. r\14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 66 1407882B Rev. 2 7.1.3 Construction Monitoring Before pipe fusion welding and installation operations begin, the CQA Monitor will verify that qualified fusion welding technicians are performing the work. During pipe fusion welding operations, the CQA Monitor will verify the following: • Qualifications and certifications of HDPE pipe fusion welder operators are acceptable • Hot plate temperatures are maintained with a minimum temperature of 400 degrees Fahrenheit but no more than 450 degrees Fahrenheit, and the temperature difference between any two points on the hot plate does not exceed 20 degrees Fahrenheit • Pipe ends are squarely faced and cuttings are removed before fusion welding occurs ■ Approximately 30 to 90 seconds per inch of pipe diameter is allowed for joining, holding, and cooling, and the welding bead is cool to the touch • Pressure testing, pulling, or installation of pipe does not take place for a minimum of 30 minutes after fusing ■ Cooling time of the fusion -welded pipe is approximately five minutes before release from the weld machine • Fusion weld roll -back (melted HDPE) distance is approximately 3/8 inch after the pipe ends are jointed • Pipes are properly aligned and are at the design grade • Backfilling operations are conducted in accordance with the technical specifications • Documentation of the installation work is provided in the Daily Progress Report During placement of pipe, the CQA Monitor will verify the following: • Piping is properly supported to limit movement and concentration of loads • Granular soil used as pipe bedding and cover has been tested for gradation and approved for use as pipe bedding and cover i \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx -ar �r Golder Associates June 2017 Appendix G 67 1407882B Rev. 2 8.0 SITE SURVEY REQUIREMENTS Site survey requirements include performing "as -built" record surveys. At a minimum, the "as -built" record survey will be performed on the final cover, subgrade and low permeability soil liner. The record survey will confirm that the Landfill is constructed in accordance with the approved design grades. The record survey will typically include: • Top of subgrade • 50 -ft by 50 -ft grid • All breaklines on 50 -ft centers • Edge of the subgrade on 50 -ft centers • Top of low permeability soil liner • 50 -ft by 50 -ft grid • All breaklines on 50 -ft centers • Edge of the subgrade on 50 -ft centers • Points shall be surveyed at coincident horizontal coordinate points (i.e., vertically "stacked" above the corresponding top of subgrade points) • Top of access road, terrace channels, perimeter channels, and downchutes perimeter channels • Channel flow lines or road on 100 -ft centers • Cross -sections (i.e., including channel bottom widths) at 200 -ft intervals • Top of final cover • 100 -ft by 100 -ft (max.) grid • Edge of the cover on 100 -ft centers The certifying CQA engineer will reference all test and sample points and reconstructed areas by measuring from reference points established for the on -site coordinate system. Tolerances will be as follows: • Top of Subgrade: Line: ±0.2 feet Grade: -0.2 to +0.0 feet IN Top of Low Permeability Soil Liner: Line: ±0.2 feet Grade: +0.0 to +0.2 feet • Top of Final Cover: Line: ±0.2 feet Grade: +0.0 to +0.2 feet • Top of Access Road, Terrace Channels, Perimeter Channels, and Downchutes: Line: ±0.5 feet Grade: +0.0 to +0.4 feet • Culvert Inlets and Outlets: Line: ±0.2 feet Grade: +0.0 to +0.2 feet \14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates June 2017 Appendix G 68 1407882B Rev. 2 9.0 SEEDING AND MULCHING The CQA personnel will monitor revegetation activities (topsoil preparation, seeding, fertilizer [if any] and mulching) and verify that each completed phase of final cover is seeded in accordance with this CQA Plan. Certificates for the seed, fertilizer, and mulch will be included in an appendix to the final cover certification report. Refer also to the Revegetation Plan provided in Section 2.3 of the Closure/Post-closure Plan (Appendix F) for additional information on seeding and mulching practices. Revegetation performance after initial seeding will be evaluated in accordance with criteria detailed in Section 3.6 of the Closure/Post-closure Plan as per the WBC Guidance. 9.1 Topsoil Surface Acceptance Prior to seeding, the topsoil surface that will be seeded the CQA Monitor will verify the following: ■ No sharp objects or other deleterious materials are present on the topsoil surface ■ The topsoil surface is firm but not overly compacted ■ All construction stakes have been removed 9.2 Seeding The seed mix presented in Table G-14 will be used when the Landfill will be closed. All seed will be furnished in bags or containers clearly labeled with the following information: ■ Name and address of the supplier ■ Seed name ■ The lot number ■ Net weight ■ Origin ■ Percent of weed seed content ■ Guaranteed percentage of purity and germination ■ Total pounds of pure live seed (PLS) in the container. Seed that has become wet, moldy, or damaged in transit or in storage will not be acceptable. If the seed available on the market does not meet the minimum purity and germination percentages specified, the Contractor must compensate for a lesser percentage of purity or germination by furnishing sufficient additional seed to equal the specified PLS product. Drill seeding is the preferred method for seeding. Drill seeding must be performed with a drill capable of distributing "fluffy" seed. Where drill seeding is impractical due to the access or slope limitations, broadcast seeding may be performed, using twice the seeding rate listed for drill seeding, and shall be followed by careful raking or harrowing to incorporate the seed to the proper depth. Hydraulic application of seed (hydroseeding) will not be acceptable without approval of the CQA engineer, CDPHE, and Weld County. i 11411407882b1040010406 edop rev311407882b app g cqa plan rev2 01jun17 docx 'Golder Associates June 2017 Appendix G 69 1407882B Rev. 2 Organic soil amendments may be added, as needed, to enhance the establishment of vegetation based on soil test results and/or site soil conditions. Inorganic fertilizer shall not be applied unless approved by the CQA engineer. 9.3 Mulching All mulch will consist of materials approved by the CQA engineer. Mulch will meet the specifications described below. Straw mulch will consist of one or more of the following types or approved equivalents: • Cereal grain straw • Oat straw • Soybean straw All mulch will be certified weed -free (CWF) by the Colorado Department of Agriculture or the North American Weed Free Forage Program. Mulch will be applied at a rate of two tons/acre and crimped in furrows (using a crimper run) perpendicular to the slope. A disc will not be acceptable for crimping. At least 70 percent (by weight) of the mulch shall be greater than or equal to 10 inches in length. Hydraulic application of wood fiber mulch at the rate of 2,500 to 3.000 pounds per acre, in conjunction with a water -stable tackifier, will also be acceptable with approval of the CQA engineer. Table G-14: Pawnee Waste E&P Landfill Typical Seed Mixo° 2) PLS lbs per Acre Common Name Blue Grama — Hachita, Bad River, Lovington 2.5 Sideoats Grama — Butte. Pierre 5.0 Western Wheatgrass — Flintlock, Arriba, Barton, Rodan, Rosana 5.5 4.0 I Little Bluestem — Cimarron, Pastura, Camper Annual Ryegrass 6.0 Notes: 1) Seed mix provided by the US Department of Agriculture — Natural Resources Conservation Service (NRCS) 2) An alternative seed mix may be used depending on site -specific soil conditions and upon consultation with NRCS and/or other revegetation specialist and will be approved by the Colorado Department of Agriculture. r\14\1407882b\0400\0406 edop rev3\1407882b app g cqa plan rev2 01jun17 docx Golder Associates Figure G-1 Water Storage Cover Material and Topsoil Thicknesses Acceptable Zone 3.0 ft 3.5 ft i oo7oA clay 4 44 st .% 50 - randy Cla go 80 90eo TAY SAW c�ay loam clay loam tf? J4 �4f:: II 2.5 ft 30 dy CerSir 1r V clay i Ailatrntrat7WIlivaisTAIK 4.0 ft I AVA vAvar v silt _;„, vrAsisprAsandyA%WAVAY-- 1 Iggitraves VAL4 PAIL a Pri I NOM IF /Mai A so A IU sand acts ,r)G �O 'O O O O t 4— Sand Separate, LEGEND Acceptable Zone (AZ) APPENDIX H Solidification Unit Design and Operations Plan ) GOLDER APPENDIX H Solidification Unit Design and Operations Plan Pawnee Waste E&P Landfill, Weld County, Colorado Submitted to: Pawnee Waste LLC 3003 East Harmony. Suite 300, Fort Collins. Colorado 80528 Submitted by: Golder Associates Inc. 7245 West Alaska Drive. Suite 200. Lakewood, Colorado 80226 +1 303 980-0540 1407882B. Revision 3 October 30. 2019 October 30. 2019 1407882B. Revision 3 Record of Revision Revision Date Description of Revision . L 0 July 23, 2015 Initial Issuance 1 February 19, 2016 Revision Revision Revision Clarification to GCL to solidification to inspection of relocation liner requirements requirements process and closure schedule procedures 2 June 27 2017 Definition Revision to of accepted bulk liquid waste transport vehicles 3 October 30, 2019 Revision to relocation construction documentation requirements GOLDER October 30. 2019 1407882B. Revision 3 Table of Contents 1.0 INTRODUCTION 1 1.1 Purpose and Scope 1 1.2 Solidification Unit Design 1 1.2.1 Mixing Container Design and Layout 1 1.2.2 Solidification Unit Grading and Stormwater Management 2 1.2.2.1 Diversion and Containment Berms 2 1.2.2.2 Solidification Unit Grading 2 1.3 Construction Documentation 2 2.0 CHARACTERIZATION AND ACCEPTANCE OF WASTES DESIGNATED FOR SOLIDIFICATION 2 3.0 SOLIDIFICATION OPERATIONS 3 3.1 Waste Receipt 3 3.2 Solidification Process Description 3 3.3 Processing Method 3 3.4 Solidification (Bulking) Agents 4 3.4.1 Lime 4 3.4.2 Fly Ash 4 3.4.3 Kiln Dust 4 3.4.4 On -site Soil 4 3.4.5 Sawdust 4 3.4.6 Other Potential Bulking Agents 5 4.0 WASTE STORAGE AND PROCESSING OPERATIONS 5 4.1.1 Bulking Agent Storage and Use 5 4.1.2 Waste Receipt and Mixing 5 4.2 Training of Operational Personnel 5 4.3 Inspections, Testing and Recordkeeping 6 .' GOLDER ii October 30, 2019 1407882B, Revision 3 5.0 CONTINGENCY PLAN 6 6.0 SOLIDIFICATION UNIT RELOCATION AND/OR CLOSURE 7 FIGURES Figure H-1: Solidification Unit General Layout Figure H-2: Solidification Unit Design Cross -Sections APPENDICES APPENDIX H-1 Example Forms ' GOLDER iii October 30, 2019 1407882B. Revision 3 1.0 INTRODUCTION 1.1 Purpose and Scope This Solidification Unit Design and Operations Plan (Plan) presents the design and operation procedures for a proposed container -type solidification unit at the Pawnee Waste E&P Landfill (Landfill or Facility), owned and operated by Pawnee Waste LLC (Pawnee). Solidification is a process in which a solidification ("bulking") agent or absorbent is added to wastes containing free liquids (i.e., sludges, wet sediments, drilling muds, etc.) to soak up the excess liquid in order for the material to pass the Paint Filter Liquids Test (US Environmental Protection Agency [EPA] SW -846 Method 9095B), thereby allowing Pawnee to accept these materials and then place them within the Landfill. The inclusion of a solidification unit at the Facility will provide an important service for the oil and gas exploration and production (E&P) industry in Weld County and the surrounding area. The solidification operation will be an adjunct to the primary Landfill operations, which are fully described in the Facility Operations Plan (Appendix C of the EDOP). Pawnee does not propose accepting bulk liquids for solidification; Pawnee defines bulk liquids as wastes which are typically injected into Class II wells without prior treatment (beyond filtration for de minimis solids removal). The solidification unit will be located within the permitted disposal area footprint and will be surrounded by (embedded in) previously deposited waste. This setting for the solidification unit will take advantage of the enhanced liner system designed for the Landfill. utilize the Landfill's leachate collection/removal and groundwater monitoring systems. and provide for convenient operations that may be relocated to an area close to the active working face as operations progress. If a significant change in operation or design to the solidification unit is required, Pawnee will submit engineering design plans and modified operational procedures to the Colorado Department of Public Health and Environment (CDPHE) prior to the change in design or operation. Note: For purposes of this Plan, a "significant change" is defined as "a change that will affect, alter, or impact the integrity, intent, capacity. capability, or regulatory requirements of a design." This Plan describes the activities required to operate the solidification unit in accordance with the applicable operating criteria specified in Sections 2 and 3 of the Colorado Department of Public Health and Environment "Regulations Pertaining to Solid Waste Sites and Facilities" (6 CCR 1007-2, Part 1) (Regulations). 1.2 Solidification Unit Design 1 ,2e1 Mixing Container Design and Layout The proposed general layout of the solidification unit is shown on Figure H-1. Typical cross -sections illustrating the solidification unit design are presented on Figure H-2. The central element of the solidification unit will be one or two metal mixing container(s) situated below top of waste grades within the waste mass. The bottom of the excavation into which the mixing containers are placed will initially be lined with a geosynthetic clay liner (GCL) and will be separated from the Landfill liner system by a minimum of 6 feet. The effectiveness and/or need for the GCL liner in future units will be evaluated based on the performance and operation of the initial unit and/or visual observations of the liner. Each mixing container will be constructed of a water -tight welded steel vessel (such as a roll -off container sealed with rubber gaskets). A minimum 12 -inch thickness of soil backfill will be placed between the GCL and the mixing container to prevent damage to the GCL. The solidification unit will be confined within an earthen containment berm, as discussed in more detail in the next section. Absorbents/bulking agents used for solidification will be delivered to the site in bulk material containers or bags (i.e., -totes" or -Super Sacks®"), which will be stored in a covered shed located at the entrance facility. If two mixing containers are used. they will either be placed side -by -side within a single lined excavation or will be set approximately 5 feet apart within separate ,, GOLDER 1 October 30. 2019 WIMIL .��Z.._ _2f�< 'r r_srrvri.�.z�,r►-' _ .0 1407882B. Revision 3 lined excavations, at Pawnee's discretion. The unloading area will consist of an enhanced -surface ramp or apron (e.g., reclaimed asphalt millings or gravel on compacted soil base) extending approximately 8 feet from the end of the mixing container(s). Safety curbs or concrete highway barriers will be positioned at the end of the container where truck unloading will take place. The remaining sides of the container(s) will be surrounded by construction or similar fencing. The container(s) will be covered with a flexible removable cover or tarp(s) when not in operation to prevent precipitation, wildlife, or debris from entering. 1.2.2 Solidification Unit Grading and Stormwater Management 1.2.2.1 Diversion and Containment Berms A containment berm constructed of on -site silty soils will encompass the perimeter of the solidification unit to prevent the escape of contact water (stormwater runoff that has contacted waste) or potential spilled waste. Diversion berms or channels will also be constructed upgradient of the solidification unit at strategic locations to prevent surface water run-on from entering the area (see Figure H-1). The perimeter containment berm will be constructed along an alignment appropriate for the grading and slopes of the immediate area. Containment berm height may vary depending on the topography but will typically be approximately 12 to 18 inches. The containment berm may be omitted on the upgradient (uphill) side of the solidification unit, given that escape of waste or contact water would be precluded by the natural topographic slope. 1.2.2.2 Solidification Unit Grading All components of the solidification unit, including the unloading ramp, will be constructed on a compacted soil pad to limit infiltration. Potential spills and/or contact water will be controlled by the perimeter containment berm and by grading of the area (within the confines of the containment berm) with an inward slope toward the mixing containers (see Figure H-1). Liquids entering the mixing containers in this manner will be processed along with wastes accepted for bulking. Access lanes on the sides of the mixing containers will facilitate access by mixing equipment and dump/haul trucks (i.e., those used for off-loading of bulking agents or load -out of the processed material). These lanes will slope gently toward the mixing containers to capture potential minor spillage that may occur during material transfer activities. Disposal areas around the solidification unit that are disturbed during mixing container installation will be re -compacted and covered with additional soil as needed. 1.3 Construction Documentation The construction of the initial solidification unit and all subsequent solidification relocations within the active Landfill will be documented by the Facility in writing and placed in the Operating Record. Once the initial solidification unit is constructed and ready for waste acceptance, a letter report will be prepared documenting the construction (including photographs) and will be submitted to CDPHE prior to commencing operation of the solidification unit. 2.0 CHARACTERIZATION AND ACCEPTANCE OF WASTES DESIGNATED FOR SOLIDIFICATION Incoming waste streams requiring solidification (hereinafter referred to as "wet wastes") will be pre -characterized, documented, and accepted in accordance with the Landfill's Waste Acceptance Plan. The pre -characterization will include analytical analysis and/or process information as necessary to make the determination that the waste is either exempt E&P waste or non -hazardous, non-exempt E&P waste. The physical and chemical characteristics GOLDER 2 October 30. 2019 1407882B. Revision 3 of each potential waste stream will be evaluated by a trained Pawnee staff member who is qualified and experienced in the area of materials management Although certain E&P wastes are exempt from regulation as hazardous waste under Subtitle C of the Resource Conservation and Recovery Act (RCRA) and 6 CCR 1007-3, Part 261.4(b)(5), all E&P wastes, (whether defined as exempt, or mixed exempt and non-exempt waste) will be pre -characterized in accordance with the site's approved Waste Acceptance Plan (see Appendix D of the EDOP). 3.0 SOLIDIFICATION OPERATIONS 3.1 Waste Receipt The wastes received for solidification will be oil and gas E&P wastes that do not pass the Paint Filter Test (e.g., semi -solid material containing "free liquids"). These materials will be transported to the Facility by private or commercial haulers in roll -offs, end dumps, tankers, or other sealed containers. Waste materials received for solidification will be processed with an absorbent material until the material passes the Paint Filter Test, and then disposed of in the Landfill. 3.2 Solidification Process Description Unless otherwise approved by CDPHE, acceptable wastes containing free liquids will be processed on site within 24 hours of receipt, and, to the extent practical, upon receipt. Pawnee will impose scheduling upon the generators who knowingly deliver acceptable wastes with free liquids in order to facilitate adherence within the 24 -hour period. Storage of wastes with free liquids outside the mixing basins will not be permitted. The on -site solidification process will be conducted in the mixing container(s) using a backhoe, excavator, or similar equipment to add and mix the bulking agent with the wet wastes. Mixing will be performed such that the wet waste is thoroughly blending with the bulking agent. The proportion of bulking agent, and the total mixing time, will be dependent upon the initial water content of the waste to be solidified and the rate of moisture absorption. The operator will visually observe the progress during mixing to determine if additional bulking agent is needed. Access for the mixing equipment will generally be from the equipment pad located on the end of the mixing container opposite the unloading ramp. Bulking agents will be hauled by truck or other equipment to the solidification unit as -needed and off-loaded from the bulk material storage bags into the mixing container either by the mixing equipment or by direct end -dumping. Bulking agents are listed in Section 3.4 of this Plan. Once the solidification process has been completed and the batch of processed material has passed the Paint Filter Test, the mixing equipment will be used to transfer the bulked waste into receiving truck(s) parked on the load -out access lanes (adjacent to the sides of the mixing containers). From there, the processed material will be delivered to the designated disposal working face. 3.3 Processing Method The solidification process involves the addition of a solid material (`bulking agent") that will absorb excess moisture and free liquid to form a sludge that can be disposed of in the landfill. More specifically, the solidification process will be as follows: Step 1- Site personnel will verify that incoming wet waste has been pre -characterized. documented, and accepted in accordance with the site's Waste Acceptance Plan. If the waste stream has been approved, Pawnee personnel will direct the hauler to the solidification unit. If the waste stream has not been approved, the waste will be rejected. GOLDER 3 October 30. 2019 1407882B. Revision 3 Step 2 — The wet waste will be discharged from the hauling truck directly into the mixing container. Step 3 — The mixing container will be filled with wet waste to a level that will allow enough remaining volume for the bulking agent to be added. Step 4 — Bulking agent will be added to the mixing container. Bulking agent may also be added to the container prior to the addition of the wet waste. Step 5 — The wet waste and bulking material will be mixed using a backhoe, excavator. or other suitable equipment. Additional bulking agent will be added to the mixing container as needed based on visual observation. Step 6 — A sample of the solidified material will be collected from the mixing container. A Paint Filter Test, as described in EPA publication SW -846 Method 9095B, will be performed on the sample by qualified Pawnee or contract personnel. The solidified waste must pass the Paint Filter Test before it is transferred to the working face for disposal. In the event a batch of processed waste does not pass the Paint Filter Test, additional bulking agent will be added and mixed until the appropriate solidification is achieved. Step 7 — Solidified material will be removed from the mixing container by the backhoe or excavator and placed in end -dump truck or similar vehicle and hauled to the working face. Step 8 - Solidified material will be disposed of at the working face along with other E&P wastes, in accordance with the Site Operations Plan. 3.4 Solidification (Bulking) Agents The absorbent materials (bulking agents) proposed for use in the waste solidification process may consist of lime, fly ash, kiln dust, on -site soil, sawdust. or other suitable materials approved for use by CDPHE. The following is a brief description of selected bulking agents. 3.4.1 Lime Lime is a grayish -white powder, often called quicklime. It is obtained by heating (calcimining) limestone and releasing carbon dioxide from the calcium carbonate. Lime has been used in similar processes for many years and is very effective in solidifying many types of sludges. 3.4.2 Fly Ash Fly ash is the particulate matter collected in air pollution control equipment used for cleaning flue gas from burning pulverized coal. It has been used in similar processes almost as long as lime and is very effective in solidifying many types of sludges. 3.4.3 Kiln Dust Kiln dust is the particulate matter collected in air pollution control equipment used for cleaning exhaust gases from kilns in the manufacture of cement. It is very effective in solidifying many types of sludges. 3.4.4 On -site Soil Clean on -site soil, typically silty material, may be used as a bulking agent. 3.4.5 Sawdust Woodworking machines at sawmills produce large quantities of sawdust. The particulate matter that is removed from the air exhaust systems for these machines can also be used to solidify waste. 4 GOLDER 4 October 30, 2019 1407882B. Revision 3 3.4.6 Other Potential Bulking Agents Pawnee may wish to utilize other appropriate bulking agents as additional sources or types of potential suitable materials are identified, subject to initial on -site trials to assess absorbent properties and overall effectiveness, in accordance with this Plan. For new potential bulking agents not listed in this Plan, a demonstration plan will be prepared and submitted to CDPHE for review and approval, followed by a one -month demonstration period. At the conclusion of the demonstration period, a demonstration report will be prepared and submitted to CDPHE summarizing the results of the bulking agent demonstration, including photographs of the associated bulking activities. After completing the demonstration period, the tested bulking agent will not be further utilized until Pawnee has received final approval from CDPHE. 4.0 WASTE STORAGE AND PROCESSING OPERATIONS 4.1.1 Bulking Agent Storage and Use Bulking agents will remain in the bulk material containers/bags inside the storage shed at the entrance facility until needed for solidification operations. At the beginning of each operating day. Pawnee will transport the anticipated number of totes to be used that day to the solidification unit. If the weather forecast is favorable (i.e., minimal chance of rain or high wind), any unused totes may remain within the bermed area of the solidification unit until needed. If inclement weather is predicted or the agent will not be needed for several days, the totes will be returned to the storage shed. Bulking agent totes to remain overnight or longer will be covered with a tarp if necessary. 4.1.2 Waste Receipt and Mixing Accepted loads of wet E&P waste will be directed to the solidification unit for discharge into one of the mixing containers. The wet wastes will undergo the solidification process as described above, and then be transported to the working face and disposed of in the Landfill. Any wet wastes discharged into the mixing containers will be solidified and disposed of before the end of the work day. No untreated waste loads will be left in the mixing containers overnight. Solidified wastes must pass the Paint Filter Test before they are transported for disposal to the Landfill working face. Solidified wastes that have passed the Paint Filter Test may be held in the mixing containers overnight or over a weekend or holiday but will be placed in the working face in a timely manner. Solidification unit operations will include the following: Control of dust by wetting the adjacent roads as needed and managing the bulking agent storage bags when not in use (as described in Section 4.1.1). Protection of public health and the environment (including Pawnee employees) by conducting the solidification operation in accordance with CDPHE, USEPA, Occupational Safety and Health Administration, and other applicable regulations. Training of personnel involved in the solidification operation (see Section 4.2 of this Plan). Liquid that enters the mixing container(s) from the surface (either due to runoff from precipitation, or from spills during unloading or transfer), would be solidified along with other waste materials. 4.2 Training of Operational Personnel Personnel involved in the operation of the solidification unit shall receive adequate training regarding the contents of this Plan, solidification procedures, the Paint Filter Test, daily operations, recordkeeping and reporting, implementation of emergency procedures, and pertinent regulations and/or conditions pertaining to waste solidification and disposal as set forth by the CDPHE. Training topics related to daily operations will include, but 4 GOLDER 5 October 30, 2019 1407882B, Revision 3 will not be limited to, minimizing damage to the steel mixing containers by the mixing equipment, inspecting and maintaining the containment berm, and continuing awareness to signs of damage or other problems. Example training and testing forms are included in Appendix H-1. 4.3 Inspections, Testing and Recordkeeping Inspection, testing, and recordkeeping requirements are listed below. Example training and testing forms are included in Appendix H-1. The Paint Filter Liquids Test (EPA SW -846 Method 9095B) is required immediately prior to disposal of the processed waste in the Landfill. Representative grab samples shall be obtained at a rate of one per batch of processed material. Test results will be documented and maintained in the Operating Record. Records of the completed Waste Profile Sheets, waste receipts, analytical test results for each of the waste streams accepted for solidification, as well as personnel training, shall be maintained in the Operating Record. Pawnee personnel will perform visual inspections of the solidification unit mixing containers at the beginning and end of each day that solidification is performed. Pawnee personnel will perform a monthly visual inspection of the interior of the mixing containers (while empty) to check for signs of possible structural defects or damage. The access lanes, unloading area, and mixing equipment pad will also be visually inspected. The inspections will be documented, and records maintained in the Operating Record. The containment berm and grading of interior areas of the solidification unit will be inspected monthly for signs of subsidence, breach, ponding, and/or erosion. Repairs will be made using compacted on -site soils as necessary to maintain the intent of the design as described in Section 1.2.2 above. If damage or defect to any of these components is found during an inspection, repairs will be initiated and completed as soon as possible. The observations and repairs will also be recorded in the Operating Record. Initial and annual hydrostatic testing of the steel mixing container will also be performed to confirm the integrity of each installed and operational mixing container (see Appendix H-1). Records of hydrostatic test results shall be maintained in the Landfill Operating Record. 5.0 CONTINGENCY PLAN This Contingency Plan outlines the actions to be taken by Pawnee if conditions of non-compliance with this Plan (once approved) occur. It is important to note that the design of the solidification unit will offer a high level of protection against a potential release to the environment due to the solidification unit's location overlying at least 6 feet of in -place waste and the composite Landfill liner system consisting of 2 feet of low -permeability compacted soil, a GCL, and a 60 -mil high -density polyethylene geomembrane. This Contingency Plan, therefore, serves as an added precautionary measure to mitigate the potential for a surface release or prolonged subsurface release of liquid. In the event that a mixing container is discovered to be damaged or defective, either through monthly inspections or during routine operations, the affected container shall be repaired and then undergo a hydrostatic test to ensure that its integrity is not compromised prior to resuming waste solidification operations. The affected mixing container will be taken out of use until the final determination of its integrity via hydrostatic test. If the hydrostatic test fails, then a plan to address the failure must be submitted to the CDPHE for review and approval prior to resuming use of the mixing container. 4 GOLDER 6 October 30, 2019 1407882B, Revision 3 For other potential events not in compliance with the Plan (e.g., significant spill occurring during unloading, known or suspected release from the mixing container structure [either or both], or failure or overtopping of the containment berm), appropriate actions will be taken based on the specific circumstances of the situation. This may include but would not necessarily be limited to: performing waste containment and/or clean-up activities as needed; inspecting and repairing damage to, or defect of, the integrity of berms; and/or, inspecting, cleaning up, and re -surfacing the unloading ramp, load -out areas, or mixing equipment pad with additional compacted soil material. In the event of a spill or release that is unable to be contained by the solidification unit containment berm and/or other control systems at the landfill (e.g., bottom liner, stormwater berms, perimeter berm), additional contingency actions will be implemented as necessary, and will be coordinated with and subject to the approval of, CDPHE and WCDPHE. In any situation necessitating implementation of the Contingency Plan, CDPHE and WCDPHE will be notified in writing within 7 calendar days. In addition, any situation separate from routine maintenance and housekeeping will be inspected and documented in a written report. All notifications and documentation of repairs made will be placed in the Operating Record. 6.0 SOLIDIFICATION UNIT RELOCATION AND/OR CLOSURE Relocation of the solidification unit within the lined Landfill will take place periodically at Pawnee's discretion. The need for the GCL liner at future solidification units will be evaluated based on the performance and operations of the initial unit; any change to the proposed solidification unit design (i.e., elimination of the GCL liner requirement) will be submitted to CDPHE for approval prior to implementation. The construction of relocated solidification units will be monitored and documented in accordance with Section 1.3 of this Plan. Mixing containers considered to be in good working order may be relocated to the new solidification unit only upon cleaning of waste residue and the performance of a hydrostatic test to confirm integrity and completion and approval of the new unit. Only one solidification unit will be active within the Landfill at any given time. At such future time when all solidification operations at the Facility are to be closed to further use, this Closure Plan will be implemented. Final closure will commence if the solidification unit is not used for a period of at least 18 months, unless the CDPHE provides written approval to extend this closure date initiation requirement. If Pawnee determines that final closure of the solidification unit is to be initiated prior to final Landfill closure, CDPHE and WCDPHE will be notified a minimum of 30 days prior to the closure date. All closure activities associated with the solidification unit will be completed within 180 days of the closure date. The residual materials will be properly disposed of in the Landfill. Closure and decommissioning activities will include: Removing any remaining bulking agent material and any appurtenances (berms, aprons. etc.) Filling the mixing container(s) with clean soil or compacted E&P waste Re -grading the area (including access roads) to achieve positive drainage Golder and the G logo are trademarks of Golder Associates Corporation 1407882B App H Rev3 PawneeWasteLF_SolidificationPlan 30OCT19 4 GOLDER 7 APPENDIX H-1 Example Forms Daily Operations and Inspection Log Personnel Training and Briefing Record Testing Log — Paint Filter Test Testing Log — Hydrostatic Test of Mixing Container Integrity PAWNEE WASTE E&P LANDFILL SOLIDIFICATION UNIT DAILY LOG OF OPERATIONS This daily log should be completed at the end of every operating day Attach additional documentation to this form, as necessary DATE OPERATOR WEATHER CONDITIONS Temperature Dew Point Precipitation Wind Cloud Cover SOLIDIFICATION UNIT UNIT LOCATION WASTE SOURCE WASTE GENERATOR DURATION OF SOLIDIFICATION Start Time Stop Time TOTAL MINUTES PAINT FILTER TEST Sample Time Sample ID Passing YES _NO DURATION OF SOLIDIFICATION Start Time Stop Time TOTAL MINUTES PAINT FILTER TEST Sample Time Sample ID Passing NO _YES DURATION OF SOLIDIFICATION Start Time Stop Time TOTAL MINUTES PAINT FILTER TEST Sample Time Sample ID Passing _YES _NO FINAL PLACEMENT AREA PHASE/CELL COORDINATES N E BASIN INSPECTION - GOOD OPERATING If No, explain condition EVIDENCE OF BASIN DAMAGE/CORROSION? If Yes, explain mitigation CONDITION _YES _NO YES _NO EQUIPMENT INSPECTION - DID ANY LEAKS OCCUR? If Yes, explain mitigation YES _NO PERSONNEL TRAINING AND BRIEFING RECORD' SOLIDIFICATION UNIT DESIGN AND OPERATIONS PLAN PAWNEE WASTE E&P LANDFILL Instructor Date The following topics were discussed at the meeting (check all that apply) o The Solidification Unit Design and Operations Plan o Recognition of waste streams o Acceptable bulking agents o Bulking procedures o Testing (Paint Filter Test) o Recordkeeping o Removal and disposal of bulked material o Safe equipment practices o Inspections o Hydrostatic Testing o Other EMPLOYEES' NAMES Printed Name Signature 1 — This form or a similar form may be used for personnel training and briefing record TESTING LOG -PAINT FILTER TESTI SOLIDIFICATION UNIT DESIGN AND OPERATIONS PLAN PAWNEE WASTE E&P LANDFILL Note The Paint Filter Liquids Test (EPA Method SW -846/9095B) is required immediately prior to disposal of the solidified waste in the landfill Representative grab samples shall be obtained at a rate of one per batch of treated material In the event the bulked liquid does not pass the Paint Filter Test, additional bulking agents will be added and mixed until acceptable solidification is achieved Date Approved Waste Profile ID # Time Bulking Agent Materials Passing Paint Filter Test (Y/N) Superintendent/ Operator Name Notes —This form or a similar form may be used for testing log record TESTING LOG -HYDROSTATIC TEST OF MIXING CONTAINER INTEGRITY1 SOLIDIFICATION UNIT DESIGN AND OPERATIONS PLAN PAWNEE WASTE E&P LANDFILL Note If no significant damage or defects are detected via routine visual observation of the mixing container, an annual hydrostatic test is required to confirm the integrity of the mixing container A hydrostatic test will also be required each time the solidification unit is relocated (installed at a new location within the lined landfill) In the event a leak is detected in the mixing container based on the hydrostatic test, the mixing container shall be repaired and undergo a confirmatory hydrostatic test to ensure that its integrity is not compromised prior to subsequent solidification operations Records of hydrostatic test results and/or leaks shall be maintained in the Site Operating Record Date Time Leak Detected in Container2 (YIN) Superintendent) Operator Name Notes 1 — This form or a similar form may be used for testing log record 2 — Criteria for concluding that a leak has occurred in the mixing container shall be water level drop 1 inch in 8 hours (after accounting for evaporation) GOLDER golder.com APPENDIX I-1 Radiation Risk Assessment Risk Assessment Report Pawnee Waste Facility 57748 Weld County Road 95 Grover, Colorado 80729 Revision 1.0 Prepared for: Pawnee Waste LLC 3003 East Harmony Road, Suite 300 Fort Collins, Colorado 80528 Prepared by: Tetra Tech, Inc. Engineering and Environmental Services 350 Indiana Street, Suite 500 Golden, CO 80401 October 19, 2015 Revised April 22, 2016 Risk Assessment Report Rev 1— Pawnee Waste LLC October 19, 2015 CONFIDENTIAL BUSINESS INFORMATION Revised Aprd 22, 2016 TABLE OF CONTENTS 1.0 INTRODUCTION 1 1 1 TYPES OF WASTE TO BE ACCEPTED 1 1 2 RADIONUCLIDE CONCENTRATIONS IN EXPLORATION AND PRODUCTION WASTES 2 1 3 WASTE DISPOSAL PROCEDURE 4 1 4 RADIATION DOSE ASSESSMENT METHOD 5 2.0 RADIATION DOSE ASSESSMENT ... ...... 6 2 1 RESRAD CODE (VERSION 6) 6 2 2 RESRAD INPUT PARAMETERS 7 2 3 CALCULATION OF DOSE TO A LANDFILL WORKER 10 2 4 CALCULATION OF DOSE TO A RESIDENT FARMER AFTER SITE CLOSURE 11 2 5 INCREMENTAL RA -226 CONCENTRATION FROM USE OF LEACHATE FOR DUST CONTROL 13 3.0 CONCLUSIONS ....15 4.0 REFERENCES ........ .... ............... .... .... 16 LIST OF FIGURES Figure 1 RESRAD Exposure Pathways from DOE, 1989 Figure 2 Annual Radiation Dose to a Landfill Worker by Pathway Figure 3 Annual Dose to a Resident Farmer by Pathway LIST OF TABLES Table 1 Laboratory Analysis of Representative Production Wastes Table 2 Radionuclide Concentrations in Waste to be Received at the Landfill Table 3 RESRAD Site -Specific Input Parameters Table 4 Occupancy Factors Table 5 Soil Radionuclide Concentrations (for both post -closure resident farmer and worker dose assessment) Table 6 Exposure Pathways Table 7 RESRAD Annual Doses to Workers by Pathway Table 8 Annual Radiation Dose to a Resident Farmer 1,000 Years Post Closure ADDENDUM 1 (APRIL 22, 2016) 7 11 13 2 3 7 9 9 10 10 12 Risk Assessment Report Rev 1— Pawnee Waste LLC October 19, 2015 CONFIDENTIAL BUSINESS INFORMATION 1.0 INTRODUCTION Pawnee Waste LLC (Pawnee) is proposing to permit, construct, and operate a landfill in Weld County, Colorado to accept RCRA exempt and non -hazardous Exploration and Production (E&P) wastes from oil and gas facilities The wastes may contain low levels of naturally occurring radioactive materials that have been designated as Technologically Enhanced Naturally Occurring Radioactive Materials (TENORM) Colorado Department of Public Health and Environment (CDPHE) requirements for industrial landfill acceptance of such materials include dose limits for members of the public and landfill workers that do not exceed 25 mrem per year [Landfill workers are considered members of the public rather than radiation workers for this type of facility] In accordance with CDPHE requirements, the maximum TENORM concentration that an industrial landfill may receive is 50 picocuries per gram (pCi/g) combined radium-226/radium-228 (Ra-226/228), 50 pCi/g natural thorium (Th-nat), and up to 300 pCi/g natural uranium (U-nat) The potential annual radiation doses to a landfill worker and to a member of the public post landfill closure were estimated using the RESRAD code (Yu, 2000) RESRAD is also useful for estimating dose from radionuclides in soil at operating facilities The RESRAD code and the Pawnee Waste LLC analyses are described in detail in Section 2 0 Several studies regarding the potential radiological hazards related to the oil and gas industry have been published in the past year Argonne National Laboratory published a report on TENORM for the North Dakota Department of Health (NDDoH) (ANL, 2014) The report concluded that a concentration of 51 6 pCi/g of Ra-226 could result in an annual dose to a worker of 100 mrem Based on this report, NNDOH proposed a disposal limit of 50 pCi/g for industrial landfills The Pennsylvania Department of Environmental Protection also produced a report on TENORM (PA, 2015) The report based estimates of worker doses on measured data The maximum average measured exposure rate at any of the nine landfills studied was 8 5 microroentgen per hour (µR/hr) above background resulting in a dose of 17 mrem per year to a full-time worker The Conference of Radiation Control Program Directors (CRCPD) published a Task Force Report on TENORM in the oil and gas industry (CRCPD, 2015) providing guidance to states with regard to management of TENORM 1 1 TYPES OF WASTE TO BE ACCEPTED The Pawnee facility will receive only E&P wastes with maximum total radium (Ra-226 and Ra-228) concentrations less than 50 pCi/g The average concentrations are not to exceed 24 pCi/g for Ra-226 and Ra-228 combined Based on laboratory analysis of representative wastes anticipated to be received at the facility, the concentrations of other naturally occurring radionuclides will be in the range of background Waste will include drilling mud, tank bottoms, drill cuttings, and water treatment residues The facility will not accept filter socks or filter cartridges 1 Risk Assessment Report Rev 1— Pawnee Waste LLC October 19, 2015 CONFIDENTIAL BUSINESS INFORMATION 1 2 RADIONUCLIDE CONCENTRATIONS IN EXPLORATION AND PRODUCTION WASTES Pawnee obtained laboratory data from E&P waste generator(s) in the DJ -Basin of Colorado to characterize the types of production wastes that might be accepted at Pawnee's landfill The samples were collected by the generator and analyzed by Pace Analytical Services Inc with the following results Table 1 Laboratory Analysis of Representative Production Wastes* Sample �t types `� Sam le #1 p' r J _Sam le #2 P- - ' Sample #3, tµ P , Sample #4 P .. :Sample #5 P_ „ Sample #6 - P Sample #7 P ' , Units "',', • :PCi/g, ° ,Z 'pC►/L - - 's -' pCi/L` , '', a pCi/,g , ; , pCi/g. '„ y - pCi/g' ; ;-_ pCi/g Collection r _ date ' 5/22/15! t 12/03/14 �' - � ; °r - 12/3/14= '',11/20/14 ,'. _ `11/20/14 ;z� ,'5/27/15, ,� > _ "5/27/15' Ra-226 4 97 20 1 19 2 11 94 10 23 148 25 87 Ra-228 2 42 3 01 4 05 3 11 2 19 143 6 69_ Th-228 1 03 0 007 0 018 0 51 1 32 1 70 1 59 Th-230 0 65 -0 058 0 197 0 16 0 37 1 25 0 79 Th-232 0 99 0 038 -0 029 0 11 0 43 103 0 54 U-234 0 88 0 288 1 55 0 91 0 88 0 87 1 08 U-235 0 08 0 00 0 077 -0 005 0 17 0 11 0 12 U-238 1 18 0 138 129 0 55 1 03 0 61 0 96 *All data reported on a 'dry weight' basis **Sample Descriptions Sample #1 — Sump Pit Grit from E&P treatment facility off load area Sample #2 — TCLP results from E&P water recycling filter press solids Sample #3 — TCLP results from oil reclamation filter press solids Sample #4 - Filter cake from E&P water recycling filter press Sample #5 — Filter cake from E&P oil reclamation filter press Sample #6 — Sump pit grit from E&P treatment facility off load area Sample #7 — Filter cake from E&P waste processing facility These laboratory data indicate that the radionuclide concentrations in production wastes are generally less than the average values assumed for this dose assessment Data provided in the table are not intended 'to represent any specific waste to be accepted by the Pawnee facility Radionuclide concentrations in all wastes to be received will be characterized in the Waste Profile provided by the generator The above data present typical concentrations for representative types of production wastes that may be received at the landfill An analysis of naturally occurring radioactive materials in drill cuttings and muds from Weld County, Colorado prepared by the Colorado Oil and Gas Conservation Commission (COGCC) observed no radioactivity concentrations in excess of background (COGCC, 2014) These results are consistent with analytical work of exploration wastes conducted by third parties from the Bakken and Marcellus oil and gas fields 2 Risk Assessment Report Rev 1— Pawnee Waste LLC October 19, 2015 CONFIDENTIAL BUSINESS INFORMATION The amount of waste received from exploration activities versus production activities will vary over time and, because of the lack of historical data for wastes produced in the DJ Basin, it is difficult to predict how much of each waste type the proposed Pawnee landfill may expect to receive In 2014, Pawnee conducted an evaluation of six dedicated E&P disposal facilities located in the heart of the active Bakken Oil Field in North Dakota to evaluate how much of each waste type was generated in this highly active field Based on monthly data from the North Dakota Department of Public Health, Pawnee calculated that between January and September, 2014, 85% of the waste received by these Bakken landfills was generated by exploration activities, and 15% from production activities In order to be conservative (protective), Pawnee has selected a 1 1 ratio of exploration to production wastes to form the basis of average expected concentration for the wastes that may be received The maximum and average concentrations of wastes that are proposed to be accepted at the Pawnee landfill are summarized in Table 2 While Ra-228 may be present in some of the wastes to be accepted at the landfill, the dose assessment described in Sections 2 0 through 2 4 is based on Ra-226 at the maximum combined Ra-226 and Ra-228 concentration of 24 pCi/g This is conservative because the dose per unit activity for Ra-226 in soil is greater than the dose per unit activity of Ra-228 Table 2 Radionuclide Concentrations in Waste to be Received at the Landfill _ _ _ Nuclide - - Average Concentration in , Waste (above background) L (pCi/g) Maximum Concentration in any ` Waste Shipment (above •„ background) (pCi/g) , Ra-226 + Ra-228 24 50 U-nat (U-238, U-234, U-235) 5 10 Th-232 5 10 The radionuclides listed in Table 2 include all of the nuclides present in the representative waste samples at concentrations distinguishable from regional background levels The proposed average concentrations were used in the RESRAD dose assessment The running inventory that will be maintained at the Pawnee facility based on shipment records, generator waste profiles, and random sampling is discussed in detail in the Pawnee Waste Acceptance Plan (WAP) The inventory will be reviewed quarterly to ensure that the average concentrations of the individual nuclides in the waste do not exceed the values listed in Table 2 If the Table 2 values are exceeded, the following corrective measures will be taken • Identify the generator(s) that are the principal contributors of elevated TENORM • Notify the generator(s) of the requirements to reduce the volume of elevated TENORM Wastes that will be accepted • Reduce quantities of received elevated TENORM wastes • Continue monitoring to assure compliance As is also discussed in the WAP, all incoming wastes will be screened via a radiation detection system that will be installed at the scale to monitor exposure rates from incoming trucks As noted, an alarm will be set to a level that would detect a Ra-226 concentration in the waste exceeding 50 pCi/g As proposed, Pawnee will operate a two-tier alarm system A manual radiation survey to verify the exposure rate will be conducted on any shipment that triggers the alarm The instruments will be 3 Risk Assessment Report Rev 1— Pawnee Waste LLC October 19, 2015 CONFIDENTIAL BUSINESS INFORMATION calibrated annually by the manufacturer or other licensed calibration facility Instrument precision (measurement reproducibility) will be evaluated at least weekly according to a Standard Operating Procedure to be developed by Pawnee The instruments to be used and the general procedures are described in the Waste Acceptance Plan Pawnee recognizes that this Risk Assessment, together with the WAP and associated operational procedures based thereon, may require further refinement as generator information becomes more readily available Thus, Pawnee proposes to conduct a review of its waste receipt processes and the corresponding RESRAD model inputs semi-annually during the first year of operation, and annually for an additional two years This review will cover • Correlation and deviation between data on the Waste Profile from facility measurements for the actual waste received, • RESRAD model revisions using compiled data for actual wastes received, field forms, portal monitors, and handheld screening device, • Evaluation of the set point used on the portal monitors and adjustment as appropriate, • Adequacy of the frequency of random sampling of various waste streams, • Recommendations for modifications to the WAP, Radiation Safety Plan, and or other operating procedures, and • Recommendations for future reviews of the waste streams 1 3 WASTE DISPOSAL PROCEDURE E&P wastes will be received at the Pawnee facility in bulk form and managed in accordance with the Operations Plan which forms part of this Permit Application As noted, a worker will spread the waste which has been deposited into a lined cell using a bulldozer or equivalent type of heavy equipment The waste will be covered sequentially with 6 inches of clean buffer material as it is spread, with no more than 900 square meters (m2) of bare waste exposed at any one time' To the extent practical, industry production waste will be covered with industry exploration waste throughout the day to minimize exposure to the operator Leachate may be applied for dust control over the bare waste and the covered waste as needed The calculated potential increase in residual radionuclide concentrations in surface materials due to the use of leachate in this manner is negligible, as described in Section 2 5 One foot of intermediate cover consisting of clean soil will be placed in areas where additional waste will not be received for 30 days The landfill facility site will be closed in increments Final cover will consist of,an engineered three foot soil layer placed on top of one foot of intermediate cover The total thickness of non-TENORM material and final cover will be a minimum of four feet (1 2 m) at site closure ' This area represents 3,000 tons per day, which is three times greater than what Pawnee expects to handle on a daily basis 4 Risk Assessment Report Rev 1— Pawnee Waste LLC October 19, 2015 CONFIDENTIAL BUSINESS INFORMATION 1 4 RADIATION DOSE ASSESSMENT METHOD The RESRAD dose assessment code was used for the purpose of estimating the potential doses to workers during landfill operations and doses to a member of the public after landfill site closure The RESRAD Code was developed by the United States Department of Energy (DOE) to evaluate the radiation doses and risks to members of the public from residual radioactive materials (Residual Radioactive) It was first issued in 1989 The version used in this analysis, RESRAD v 6 5, was issued in October 2009 RESRAD is part of a family of codes designed to evaluate doses to individuals and ecological receptors RESRAD v 6 5 addresses soil contamination and is used to calculate doses to individuals prior to and after remediation Further information on the RESRAD codes can be obtained from the User's Manual for RESRAD, Version 6 (Yu, 2001) 5 Risk Assessment Report Rev 1— Pawnee Waste LLC October 19, 2015 CONFIDENTIAL BUSINESS INFORMATION 2.0 RADIATION DOSE ASSESSMENT As noted above, the radiation doses to the two critical receptors, landfill worker and post -closure resident farmer, were calculated using the RESRAD Code The input parameters used in the RESRAD analysis are given in Section 2 2 The results of the risk assessment are given in Sections 2 3 and 2 4 2 1 RESRAD CODE (VERSION 6) RESRAD can be used to calculate the dose from a particular radionuclide at a specified soil concentration or, conversely, calculates a soil concentration that would result in a specified dose to a member of the public RESRAD can also calculate a total dose from a mixture of radionuclides in soil The RESRAD summary output provides the doses from each individual radionuclide and pathway and the total dose at user -specified time intervals RESRAD also calculates the peak total dose from the radionuclide mixture RESRAD calculates doses for water -independent and water -dependent pathways for the following exposure pathways (See Figure 1) • External gamma radiation • Inhalation of radionuclides in airborne particulate matter (re -suspended dust) • Ingestion of plants grown on the site • Ingestion of meat from animals raised on the site • Ingestion of milk from cows grazing on the site • Aquatic foods • Drinking water • Soil ingestion • Inhalation of radon decay products The RESRAD user specifies which exposures represent a complete pathway, that is, a source and a receptor, depending on the land use scenario RESRAD allows the user to specify time periods for dose assessment but also calculates the maximum annual dose over a 1,000 -year period 6 Risk Assessment Report Rev 1— Pawnee Waste LLC CONFIDENTIAL BUSINESS INFORMATION October 19, 2015 - Plant + Foods . © Milk T 4 feat 4 Soil' Riiiion ingestio 1 �uJ Alonds Forming-, A , I I 1 J Evaporiition 1 + 1 rinking er Tnfiltnntion External: ≥J .Rndivaclocb Gunlam�nakd MntcrmT m Soil -� Leaching fGrouud�tiater Figure 1: RESRAD Exposure Pathways from DOE, 1989 2 2 RESRAD INPUT PARAMETERS RESRAD allows the model user to designate site -specific input parameters but also provides default values The RESRAD input parameter values used in the dose assessments are given in Table 3 The input data were provided by Golder Associates Inc , the engineer/geotechnical firm of record Table 3: RESRAD Site -Specific Input Parameters Contaminated Zone = Waste material (drill cuttings, drilling muds, injection well filter cake, tank bottoms), assumed mixture of sand/silt/clay (equivalent to sandy clay classification) Unsaturated Zone 1= compacted soil liner (silt + bentonite admix) Unsaturated Zone 2 = Silty vadose zone Saturated Zone = Uppermost Saturated Zone (fissured silty clay with isolated sand lenses) _ ` Parameter , ' ,Y Value Area of the contaminated zone Worker 40468 m2 (10 ac total, 900 m2 uncovered, 40,000 m2 covered with 0 3 m soil or 0 15 m sod) Farmer 323746 m2 (80 ac) Thickness of the contaminated zone Worker 13 m avg (42 ft) 23 m max (76 ft) Farmer 29 m avg (96 ft) 49 m max (160 ft) Note Max height of landfill above natural grade 44 m 44 m Length parallel to the aquifer flow Worker 180 m (590 ft for 10 -ac area E -W) Farmer 730 m (2385 ft for 80 -ac footprint E -W) Density of the contaminated zone 1 76 g/cm3 (110 pcf) Cover erosion rate 3 3 x 104 m/yr (0 33 mm/yr) Contaminated zone erosion rate 0 001 m/y (RESRAD default value) 7 Risk Assessment Report Rev 1— Pawnee Waste LLC CONFIDENTIAL BUSINESS INFORMATION October 19, 2015 Parameter Value Contaminated zone total porosity 0.398 w/ (HELP Model k =2.7 x 10-6 cm/s User's and Guide, 3.3 x avg of defaults 10 5 cm/s) for 2 sandy clay (SC) materials Contaminated zone field capacity 0.313 w/ (HELP Model k =2.7 x 10-6 cm/s User's and Guide, 3.3x105cm/s) avg of defaults for 2 sandy clay (SC) materials Contaminated zone hydraulic conductivity 5.63 sandy m/yr clay (1.79 x 10 5 cm/s) (SC) materials w/ (HELP Model User's Guide, k =2.7 x 10-6 cm/s and avg of defaults 3.3 x 10-5 cm/s) for 2 Contaminated zone b parameter 8, RESRAD where be based 0.998 mixture on the 6.0 and of is sand/silt/clay) range RESRAD-Build for sand provided soil and in Table 3.0 Computer 14.2 is 3.1 for clayey of "Development Codes" soil of Probabilistic (Argonne/NRC, (waste material 2000) will likely Average annual wind speed 6 of m/s (13 monthly mi/hr) averages (NREL map from "Annual www.myforecast.com Average Wind for Speed Grover, at 30m; also CO) average Evapotranspiration coefficient 0.5 (model default) Precipitation 0.344 m/yr (13.54 in/yr) (Western Regional 1970) Climate Center, Grover data 1893- Runoff coefficient 0.43 (based on CN of 74 used in storm water runoff calculations) Density of the saturated zone 1.176 g/cm3 Inc. samples) (73.4 pcf) (avg initial dry density of 5 undisturbed Golder Associates, Saturated zone total porosity 0.464 (HELP Model User's Guide default for CL material w/ k = 6.4 x 10 5 cm/s) Saturated zone effective porosity 0.06 clay) (RESRAD "Data Collection Handbook" [Argonne/USDOE 1993] value for Saturated zone field capacity 0.310 (HELP Model User's Guide default for CL material w/ k = 6.4 x 10 5 cm/s) Saturated zone hydraulic conductivity 75.74 m/yr (2.4 x 104 as representative of the cm/sec) (geomean of MW -1 and unit) MW -4 aquifer test values Saturated zone hydraulic gradient 0.0004 (from Hydrogeo report) Saturated zone b parameter 12, RESRAD where clay) based 6.0 0.998 on the and is range provided RESRAD-Build for sand soil and 3.0 in Table Computer 14.2 is 3.1 for clayey of "Development Codes" soil (Argonne/NRC, (the of Probabilistic saturated zone 2000) is silty Thickness of unsaturated zone 1 0.61 m (2 ft = compacted soil liner thickness) Density of unsaturated zone 1 1.421 g/cm3 (89 pcf) (avg dry compaction) density of 4 recompacted perm samples at 96% Unsaturated zone 1 total porosity 0.427 (HELP Model User's Guide default for "Barrier Soil") Unsaturated zone 1 effective porosity 0.06 clay) (RESRAD "Data Collection Handbook" [Argonne/USDOE 1993] value for Unsaturated zone 1 field capacity 0.418 (HELP Model User's Guide default for "Barrier Soil") Unsaturated zone 1 hydraulic conductivity 0.03156 soil m/yr (1 x 10 / cm/sec) (specification for bentonite-admix liner) compacted Unsaturated zone 1 b parameter 10, RESRAD where based 6.0 0.998 on the and is range RESRAD-Build for sand provided soil and 3.0 in Table Computer 14.2 is 3.1 for clayey of Codes" "Development soil (Argonne/NRC, (liner of will be Probabilistic silt/silty 2000) clay) Thickness of unsaturated zone 2 6.1 m (20 ft = minimum at sumps) Density of unsaturated zone 2 1.176 g/cm3 Inc. samples) (73.4 pcf) (avg initial dry density of 5 undisturbed Golder Associates, Unsaturated zone 2 total porosity 0.46 (HELP Model User's Guide, avg of defaults for 3 ML soil types) Unsaturated zone 2 effective porosity 0.20 (RESRAD "Data Collection Handbook" [Argonne/USDOE 1993] value for silt) Unsaturated zone 2 field capacity 0.27 (HELP Model User's Guide, avg of defaults for 3 ML soil types) Risk Assessment Report Rev 1— Pawnee Waste LLC CONFIDENTIAL BUSINESS INFORMATION October 19, 2015 Parameter Value Unsaturated zone 2 hydraulic conductivity 1 17 x 10 3 m/yr (Estimated unsaturated K for native silt loam, calculated using M van Genuchten equation (1978, 1980) and Mualem, Y (1976) approximation based on saturated K and in situ moisture content test data ) Unsaturated zone 2 b parameter 10, based on the range provided in Table 3 1 of "Development of Probabilistic RESRAD 6 0 and RESRAD-Build 3 0 Computer Codes" (Argonne/NRC, 2000) where 0 998 is for sand soil and 14 2 is for clayey soil (this zone is silt/silty clay) The occupancy factors used in the RESRAD analysis for the post -closure resident farmer and the landfill worker during operations are summarized in Table 4 The site worker was assumed to be on -site a total of forty hours per week and exposed to uncovered waste for an average of 20 hours per week Pawnee has identified the activities necessary to maintain the site and estimates that the spreading and covering of waste can be conducted within a four hour period each work day The RESRAD default occupancy factors were used for the resident farmer post -closure Table 4 Occupancy Factors (Post -closure Resident Farmer) ,, Parameter Resident Farmer On -site worker , ,'� Fraction of time outdoors 0 25 (RESRAD default) 0 228 (1,000 hours per year on spreading bare waste and 1,000 hours per year on covered waste) Fraction of time indoors 0 50 (RESRAD default) 0 Fraction of diet from on -site sources 0 5 plants 10 meat 1 0 milk (RESRAD default values) 0 Soil ingestion 0 1 g/d (RESRAD Default) 0 1 g/d (RESRAD default) The average radionuclide concentrations used as input in the RESRAD assessment are given in Table 5 The long-lived decay products of uranium -235 (U-235) were included in the assessment even though they constitute a very small amount of activity U-235 represents approximately 2 2% of the total radioactivity of natural uranium Its decay products, actinium -227 (Ac -227) and protactinium -231 (Pa - 231), were assumed to be present in equilibrium (at the same concentration) as the U-235 There are no laboratory data to support including or excluding U-235 decay products Thorium -232 (Th-232) was also included as an input radionuclide Table 5 Soil Radionuclide Concentrations (for both post -closure resident farmer and worker dose assessment) Nuclide -Concentration ``_ - - (PCB/g) ' - - Ra-226 24 Th-230 0 U-nat 5 Ac -227 (U-235 decay product) 0 11 Pa -231 (U-235 decay product) 0 11 Th-232 5 9 Risk Assessment Report Rev 1— Pawnee Waste LLC October 19, 2015 CONFIDENTIAL BUSINESS INFORMATION RESRAD allows the user to specify the potential exposure pathways Pawnee's E&P Waste Landfill will be under institutional controls (deed restricted) post closure so the potential for the "resident farmer land use" scenario is very small, however it was used in the RESRAD analysis to evaluate model outputs All exposure pathways were active for the dose analysis except aquatic foods and radon Ingestion of aquatic foods is an unlikely complete exposure pathway because there are no water bodies or fisheries near the proposed facility location Radon was suppressed as a potential pathway because property deed restrictions make it unlikely that a residence would be constructed on the site If that were to be the case, radon mitigation would be required (Grice, 2015) The only complete exposure pathways for the site worker during operations are direct gamma radiation, inhalation of airborne particulates, inhalation of radon decay products and incidental soil ingestion There will be no site surface water or ground water pathways and no food ingestion pathways The exposure pathways used in the model are listed in Table 6 Table 6 Exposure Pathways - " ". ,Pathway '- - 5,-, '' Resident Farmer Post Closure K„Worker,During Operations External Gamma Active Active Inhalation (without radon) Active Active Plant ingestion Active Suppressed Meat ingestion Active Suppressed Milk ingestion Active Suppressed Aquatic foods Suppressed Suppressed Drinking water Active Suppressed Soil ingestion Active Active Radon Suppressed Active 2 3 CALCULATION OF DOSE TO A LANDFILL WORKER The RESRAD code was used to calculate the potential annual dose to a worker on the Pawnee Waste Landfill site during normal operations, and the potential dose to a member of the public after operations cease and the site is closed The RESRAD-calculated annual doses to a landfill worker, by pathway, are given in Table 7 The doses at time = 0 were used since the bare waste will be routinely covered with 6 inches of soil after TENORM placement/disposal and the only significant exposure pathway is direct gamma radiation The RESRAD landfill worker analysis assumed a 15 m thickness of the contaminated zone A sensitivity analysis demonstrated that increasing the thickness of the contaminated zone does not increase the calculated dose Table 7. RESRAD Annual Doses to Workers by Pathway b� ;= f " _ -Pathway _ _ _,; - "-Dose from Bare Waste'- y yNT (mrem/y) =r, r .,Dose from Covered �� ,= Waste (mrem/Y) ' i s Total Annual Dose ; `- '(mrem/Y)>Y- r Direct Gamma Radiation (ground) 27 61 4 88 3149 Inhalation of Particulates 0 05 Less than 0 01 0 05 Incidental Ingestion of Sod 0 20 Less than 0 01 0 20 Inhalation of Radon Less than 0 01 0 01 0 01 10 Risk Assessment Report Rev 1— Pawnee Waste LLC October 19, 2015 CONFIDENTIAL BUSINESS INFORMATION The worker will conduct waste placement and moving operations from the insides of a cab of heavy earth moving equipment that will provide shielding from direct radiation. The shielding factor for heavy equipment is at least 0.75 (Schneider, 2001). Therefore, the potential direct gamma radiation dose to the worker would be as follows: • Dose (mrem/y) = Direct Gamma Dose x 0.75 • Dose = 31.49mrem/y x 0.75 = 23.62 mrem/y The total annual dose to the worker would be the dose from shielded gamma radiation plus the dose from inhalation and ingestion. Total annual dose to the worker = 23.62 mrem/y + 0.05 mrem/y + 0.20 mrem/y + 0.01 mrem/y = 23.88 mrem/y = 24 mrem/y The annual doses by pathway are shown in Figure 2. Estimated Dose to Landfill Worker (mrem/y) 25 Direct radiation Inh. Dust Intl. Radar Soil Ingestion ■ Bare waste • Covered waste ■ Total Figure 2: Annual Radiation Dose to a Landfill Worker by Pathway The estimated total annual dose to a Pawnee Waste landfill worker, above background levels and excluding medical exposures, would be less than 25 mrem per year. Inhalation of dust and radon contribute essentially nothing to the dose. Direct radiation is the determining factor in the dose. 2.4 CALCULATION OF DOSE TO A RESIDENT FARMER AFTER SITE CLOSURE The potential annual doses to a member of the public were calculated using the RESRAD code. A very conservative land -use scenario "resident farmer" was used in the analysis with the default occupancy Risk Assessment Report Rev 1— Pawnee Waste LLC October 19, 2015 CONFIDENTIAL BUSINESS INFORMATION factors listed in Table 4 The pathways turned on in the analysis are described in Section 21 and summarized in Table 6 The results of this analysis showed that the annual dose at the year of maximum exposure for 1,000 years post closure (the required period of concern) would be less than the 25 mrem per year dose limit set by the CDPHE for TENORM landfills The waste will be covered by a minimum of 4 feet (1 2 m) of clean soil which will comprise the final cover and the erosion rate for the site is relatively low at 0 00033 m per year Therefore, direct gamma radiation is shielded At 1,000 years, the cover is expected to be about 0 6 m thick based on the erosion rate The principal exposure pathway is ingestion of drinking water with plant ingestion as a second contributing pathway Radon dose was not included in this analysis based on the deed restriction that would preclude construction of a residence on the site The doses are,summarized by pathway in Table 8 Table 8 Annual Radiation Dose to a Resident Farmer 1,000 Years Post Closure P �'� -� Pathway a 'n,F � '� ,i.: ' „,, _ -, Annual Dose (m'rem/Y) - t' - �` - Water Independent - f - - Pathways *aterdependent ',- Pathways ,,.. w{p' Total �r 04` > v` Direct Gamma (ground) 0 01 NA 0 01 Plant Ingestion 6 52 1 17 7 69 Meat Ingestion 0 29 0 27 0 56 Milk Ingestion 0 24 0 08 0 32 Water NA 15 27 15 27 Total Dose I 7 06 16 79 23 85 NA — not applicable The calculated annual doses by pathway are shown in Figure 3 The only significant pathways are ingestion of groundwater and plants grown on site The total annual dose for these pathways is less that the CDPHE dose limit of 25 mrem per year 12 Risk Assessment Report Rev 1— Pawnee Waste LLC October 19, 2015 CONFIDENTIAL BUSINESS INFORMATION Annual Dose to a Farmer by Pathway Post Closure 30 25 20 15 10 5 0 Direct Plant Meat Water Milk Gamma ingestion ingestion ingestion ingestion Figure 3. Annual Dose to a Resident Farmer by Pathway Total 2.5 INCREMENTAL RA -226 CONCENTRATION FROM USE OF LEACHATE FOR DUST CONTROL The incremental Ra-226 concentration in surface materials, including waste and cover, attributable to the application of leachate for dust control is negligible compared to background Ra-226 concentrations. Assuming an application rate of 5,000 gallons of leachate over a 2 acre (8,094 m2) surface area, a two- inch penetration depth and an average leachate concentration of 24 pCi/L, the average incremental Ra- 226 concentration can be calculated as follows: CS = [(Ci)(Volume)]/[(penetration depth)(surface material density)(area)] Where: CS = Incremental Ra-226 concentration in surface material C, = Ra-226 concentration in leachate = 24 pCi/L (based on measured values in Table 1) Density of surface material = 1.5 g/cm3 Volume = 5,000 gallons x 3.79 L/gallon = 1.90 x 104 L CS = [(24 pCi/L)(1.90 x 104 L)/[(8.08 x 103 m2)(1x104 cm2/m2)(2.0 in)(2.54 cm/in)((1.5 g/cm3) = 0.00074 pCi/g The actual Ra-226 concentration in leachate will vary over time. As can be seen from the calculation, even if the leachate concentration is several orders of magnitude greater than the concentration used in the example, the resulting incremental Ra-226 concentration in soil or other surface material would be a small fraction of the background Ra-226 concentration. Risk Assessment Report Rev 1— Pawnee Waste LLC October 19, 2015 CONFIDENTIAL BUSINESS INFORMATION The frequency of application of leachate to surface materials for dust control would not significantly affect the incremental Ra-226 concentration as the waste material will be covered with clean soil on a routine basis, as noted in the Operations Plan, so the residual Ra-226 concentration in surface material attributable to the leachate would ,not build up Given the negligible calculated incremental concentration from a single application, multiple applications would not significantly affect the total Ra- 226 concentration in surface materials The incremental Ra-226 concentration will be a function of the concentration in the leachate and the volume of water applied to a particular surface The use of leachate for dust control will be re-evaluated as site operations continue and more information in obtained 14 Risk Assessment Report Rev 1— Pawnee Waste LLC - October 19, 2015 CONFIDENTIAL BUSINESS INFORMATION 3.0 CONCLUSIONS The CDPHE has established a dose limit of 25 mrem per year for industrial landfills accepting TENORM waste for both the Pawnee landfill worker and any member of the public after closure of the facility The RESRAD-calculated doses demonstrate compliance with that dose limit The doses calculated for this risk assessment are consistent with the results of the Pennsylvania and Argonne (North Dakota) TENORM disposal evaluations (PA, 2015, ANL, 2014) Radiation doses to members of the public during operation will be negligible because the waste streams are expected to have small TENORM concentrations and the facility will be operated using radiation safety work practices The site will be secured and access limited to facility workers, precluding any public activities at the site There are no residences in close proximity to the proposed Pawnee Waste landfill site The type of wastes planned for delivery are typically damp, preventing significant dust emissions from the waste itself In addition, the TENORM waste will be covered as described in the Operations Plan Radiation safety work practices, described in the Radiation Safety Manual and Standard Operating Procedures, will prevent significant radiation doses to members of the public under routine operating conditions Emergency procedures will be developed and implemented to minimize the potential for radiation dose to a member of the public under non -routine or accident conditions 15 Risk Assessment Report Rev 1— Pawnee Waste LLC October 19, 2015 CONFIDENTIAL BUSINESS INFORMATION 4.0 REFERENCES (ANL, 2014) (CDPHE, 2007) (COGCC, 2014) (CRCPD) (CSI, 2006) (Grace, 2015) (PA, 2015) Argonne National Laboratory 2014 Radiological Dose and Risk Assessment of Landfill Disposal of Technologically Enhanced Naturally Occurring Radioactive Materials (TENORM) in North Dakota ANL/EVS-14/13 November Colorado Department of Public Health and Environment 2007 Interim Policy and Guidance Pending Rulemaking for Control and Disposition of Technologically -Enhanced Naturally Occurring Radioactive Materials in Colorado Rev 21 Final Draft for Comment February Colorado Oil and Gas Conservation Commission 2014 Analysis of Naturally Occurring Radioactive Materials in Drill Cuttings, Greater Wattenberg Field, Weld County, Colorado COGCC Special Project 2136 November Conference of Radiation Control Program Directors 2015 E-42 Task Force Report, Review of TENORM in the Oil & Gas Industry (CRCPD E-15-2) June Waste Management of Colorado, Inc Conservation Services, Inc 2006 Updated Risk Assessment Report May Personal communication with James Gnce, CDPHE June 2015 Pennsylvania Department of Environmental Protection 2015 Technologically Enhanced Naturally Occurring Radioactive Materials (TENORM) Study Report Rev 0 January 2015 (Schneider, 2001) Schneider, S, D C Kocher, G D Kerr, P A Scofield, F R O'Donnell, C R Mattsen, S J Cotter, J S Bogard, J S Bland, and C Wiblin, 2001 Systematic Radiological Assessment of Exemptions for source and Byproduct Materials NUREG-1717 Division of Risk Analysis and Applications U S Nuclear Regulatory Commission June (Yu, 2001) Yu, C, A J Zielen, J -J Cheng, D J LePoire, E Gnanapragasam, S Kamboj, J Amish, A Wallo, Ill, W A Williams, and H Peterson 2001 User's Manual for RESRAD Version 6 ANL/EAD-4 July 16 ADDENDUM 1 (APRIL 22, 2016) TO RISK ASSESSMENT REPORT, REVISION 1 0 (OCTOBER 19, 2015) Risk Assessment Report Rev 1— Pawnee Waste LLC CONFIDENTIAL BUSINESS INFORMATION Addendum 1 April 22, 2016 ADDENDUM TO RADIATION DOSE ASSESSMENT The radiation doses to the two critical receptors, landfill worker and post -closure resident farmer, were calculated using the RESRAD Code as described in Section 2 of the Radiation Dose Assessment The input parameters used in the RESRAD analysis are given in Section 2 2 of the Radiation Dose Assessment The results of the risk assessment are given in Sections 2 3 and 2 4 This addendum addresses the addition of Pb-210 and Po -210 to the waste acceptance criteria at average concentrations no greater than 10 pCi/g for each nuclide The Radiation Dose Assessment describes in detail the RESRAD code and the input parameter values used in the initial dose calculations The revised radionuclide soil concentrations used in this addendum are shown in Table 1 Table 1 Soil Radionuclide Concentrations (for both post -closure resident farmer and worker dose assessment) Nuclide r 4 1 -- t Concentration } ,. 4' (pCi/g)' ' ' r Ra-226 24 Th-230 0 U-nat 5 Ac -227 (U-235 decay product) 0 11 Pa -231 (U-235 decay product) 0 11 Th-232 5 Pb-210 10 Po -210 10 As noted in the Radiation Dose Assessment RESRAD allows the user to specify the potential exposure pathways Pawnee's E&P Waste Landfill will be under institutional controls (deed restricted) post closure so the potential for the "resident farmer land use" scenario is very small, however it was used in the RESRAD analysis to evaluate model outputs All exposure pathways were active for the dose analysis except aquatic foods and radon Ingestion of aquatic foods is an unlikely complete exposure pathway because there are no water bodies or fisheries near the proposed facility location Radon was suppressed as a potential pathway because property deed restrictions make it unlikely that a residence would be constructed on the site If that were to be the case, radon mitigation would be required (Grice, 2015) The only complete exposure pathways for the site worker during operations are direct gamma radiation, inhalation of airborne particulates, inhalation of radon decay products and incidental soil ingestion There will be no site surface water or ground water pathways and no food ingestion pathways The exposure pathways used in the revised model are listed in Table 2 and are the same as used in the initial RESRAD analyses No additional pathways are reasonable based on the addition of Po -210 and Pb-210 to the waste acceptance criteria Table 2: Exposure Pathways c _ , Pathway . Resident Farmer Post Closure _ -, Worker During Operations External Gamma Active Active Inhalation (without radon) Active Active Plant ingestion Active Suppressed Meat ingestion Active Suppressed Risk Assessment Report Rev 1— Pawnee Waste LLC CONFIDENTIAL BUSINESS INFORMATION Addenduml1 April 22, 2016 Milk ingestion Active Suppressed Aquatic foods Suppressed Suppressed Drinking water Active Suppressed Soil ingestion Active Active Radon Suppressed Active CALCULATION OF DOSE TO A LANDFILL WORKER As with the original analysis, the RESRAD code was used to calculate the potential annual dose to a worker on the Pawnee Waste Landfill site during normal operations, and the potential dose to a member of the public after operations cease and the site is closed The RESRAD-calculated annual doses to a landfill worker, by pathway, are given in Table 7 The doses at time = 0 were used since the bare waste will ble routinely covered with 6 inches of soil after TENORM placement/disposal and the only significant exposure pathway is direct gamma radiation Neither Pb-210 nor Po -210 contribute to the direct gammla radiation dose (Note the direct gamma dose to the landfill worker increased by approximately 018 mrem/yr probably due bremsstrahlung from the short-lived Bi-210 decay product of Pb-210 ) The RESRAD landfill worker analysis assumed a 15 m thickness of the contaminated zone Table 3 RESRAD Annual Doses to Workers by Pathway Pathway _ . _ Dose from Bare Waste (mrem/y) ' Dose from Covered - Waste'(mrem%y) -_ Total Annual Dose (mrem/y) ' Direct Gamma Radiation (ground) 27 62 4 88 32 50 I Inhalation of Particulates 0 05 Less than 0 01 0 05 Incidental Ingestion of Soil 0 47 Less than 0 01 0 47 Inhalation of Radon Less than 0 01 0 02 0 02 I The worker will conduct waste placement and moving operations from the insides of a cab of heavy ea th moving equipment that will provide shielding from direct radiation The shielding factor for heavy equipment is at least 0 75 (Schneider, 2001) Therefore, the potential direct gamma radiation dose to the worker would be as follows Dose (mrem/y) = Direct Gamma Dose x 0 75 Dose = 32 50 mrem/y x 0 75 = 24 38 mrem/y The total annual dose to the worker would be the dose from shielded gamma radiation plus the dose from inhalation and ingestion Total annual dose to the worker = 24 38 mrem/y + 0 05 mrem/y + 0 47 mrem/y + 0 02 mrem/y = 24 mrem/y 92 Po -210 is not included in the dose assessment as it is not included in the RESRAD list of nuclides Assuming Po -210 is present at the same concentration as Pb-210, the additional Po -210 dose can be estimated by multiplying the ratio of the ingestion dose conversion factors from Federal Guidance Report No 11 (EPA, 1988) by the calculated Pb-210 dose Estimated Po -210 dose = (0 47 mrem/y)(5 14E-7 Sv/Bq/1 45E-6 Sv/Bq) = 0 16 mrem/yr I Risk Assessment Report Rev 1— Pawnee Waste LLC CONFIDENTIAL BUSINESS INFORMATION Addendum 1 April 22, 2016 The total dose would be 25 08 mrem/yr The previously calculated dose without the addition of Pb-210 and Po -210 to the waste acceptance criteria was 24 mrem/yr CALCULATION OF DOSE TO A RESIDENT FARMER AFTER SITE CLOSURE The dose to the resident farmer would be unaffected by the addition of Pb-210 and Po -210 to the waste acceptance criteria since the maximum dose occurs at 1,000 years after site closure The Pb-210 and Po - 210 originally accepted into the facility would have decayed out within the first two hundred years As expected, the re -calculated dose to the resident farmer at 1,000 years post -closure was no different than the dose previously calculated The potential annual doses to a member of the public were calculated using the RESRAD code A very conservative land -use scenario "resident farmer" was used in the analysis with the default occupancy factors listed in Table 4 The pathways turned on in the analysis are described in Section 2 1 and summarized in Table 6 The results of this analysis showed that the annual dose at the year of maximum exposure for 1,000 years post closure (the required period of concern) would be less than the 25 mrem per year dose limit set by the CDPHE for TENORM landfills The waste will be covered by a minimum of 4 feet (1 2 m) of clean soil which will comprise the final cover and the erosion rate for the site is relatively low at 0 00033 m per year Therefore, direct gamma radiation is shielded At 1,000 years, the cover is expected to be about 0 6 m thick based on the erosion rate The principal exposure pathway is ingestion of drinking water with plant ingestion as a second contributing pathway Radon dose was not included in this analysis based on the deed restriction that would preclude construction of a residence on the site The doses are summarized by pathway in Table 8 Risk Assessment Report Rev 1— Pawnee Waste LLC CONFIDENTIAL BUSINESS INFORMATION Addendum 1 April 22, 2016 Table 4: Annual Radiation Dose to a Resident Farmer 1,000 Years Post Closure Pathway Annual Dose (mrem/y) Water Independent Pathways Water Dependent Pathways Total Direct Gamma (ground) 0.01 NA 0.01 Plant Ingestion 6.52 1.17 7.69 Meat Ingestion 0.29 0.27 0.56 Milk Ingestion 0.24 0.08 0.32 Water NA 15.27 15.27 Total Dose 7.06 16.79 23.85 NA — not applicable The calculated annual doses by pathway are shown in Figure 3. The only significant pathways are ingestion of groundwater and plants grown on site. The total annual dose for these pathways is less that the CDPHE dose limit of 25 mrem per year. 15 10 5 0 Annual Dose to a Farmer by Pathway Post Closure Direct Plant Meat Water Milk Total Gamma ingestion ingestion ingestion ingestion Figure 3. Annual Dose to a Resident Farmer by Pathway APPENDIX 1-2 NRC Technical Evaluation of Protechnics Tracer Material Alternate Waste Disposal Method March 8, 2016 MEMORANDUM TO: FROM: SUBJECT: Mark R. Shaffer, Director Division of Nuclear Materials Safety Region IV John R. Tappert, Director /RA/ Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards RESPONSE TO TECHNICAL ASSISTANCE REQUEST, DATED AUGUST 5, 2015, FOR THE REVIEW OF THE PROTECHNICS DIVISION OF CORE LABORATORIES' REQUEST FOR APPROVAL OF AN ALTERNATE WASTE DISPOSAL METHOD UNDER 10 CFR 20.2002 Region IV submitted a Technical Assistance Request (Agencywide Documents Access and Management System (ADAMS) Accession Number ML15218A608), dated August 5, 2015, requesting a review of the ProTechnics Division of Core Laboratories' (ProTechnics) request for an alternate waste disposal method under 10 CFR 20.2002. The U.S. Nuclear Regulatory Commission (NRC) has previously approved ProTechnics use of two alternate waste disposal methods: 1.) on -site earthen pit burial; and 2.) Class II wells for disposing of well returns containing small concentrations of radioactive tracer material. ProTechnics is now requesting NRC approval for a third option, disposal of the well returns at the Meadowfill Landfill in Bridgeport, West Virginia. The NRC staff evaluated ProTechnics' request for a third alternate waste disposal method that considers the placement of well returns containing small concentrations of radioactive materials at the Meadowfill landfill. Based on a review of the analyses provided by ProTechnics (ML15211A594), the responses to the request for additional information (ML15292A061), and the independent analyses discussed in the accompanying Technical Evaluation Report (TER), the NRC staff find this disposal option to be acceptable and in compliance with the regulations in 10 CFR 20.2002. The expected doses are a very small fraction of the public dose limit and lower than calculated doses for other alternates already approved for the licensee. The expected dose is less than 0.01 mSv/yr (1 mrem/yr) to the average member of the critical group and doses are maintained as low as reasonably achievable. Region IV will use the information provided in this TER to issue a license amendment to ProTechnics and an exemption letter to Waste Management, owners of the Meadowfill Landfill, CONTACT: Adam L. Schwartzman, NMSS/DUWP (301) 415-8172 1.1 4, S F g I I { I I I M. Shaffer -2- granting them permission to dispose of the well returns without an NRC license. The NMSS staff agreed to include an example exemption letter (ML15086A427), Enclosure 2, with this response. Enclosures: 1 Technical Evaluation Report 2. Example Exemption Letter M Shaffer - 2 - granting them permission to dispose of the well returns without an NRC license The NMSS staff agreed to include an example exemption letter (ML15086A427), Enclosure 2, with this response Enclosures 1 Technical Evaluation Report 2 Example Exemption Letter DISTRIBUTION D Collins, MSTR H Gonzalez, MSTR ADAMS Accession No ML16041A076 (Pkg ) ML16020A283 (Memo & TER) ML15086A427 (Ex ) *concurred via email OFFICE NMSS NMSS LA NMSS BC NMSS D OGC NMSS NAME A Schwartzman T Moon C McKenney (M Norato for) J Tappert S Clark* A Schwartzman DATE 1/21/16 2/1/16 1/28/16 2/2/16 2/25/16 3/8/16 OFFICIAL RECORD COPY TECHNICAL EVALUATION REPORT RESPONSE TO TECHNICAL ASSISTANCE REQUEST REGARDING THE PROTECHNICS DIVISION OF CORE LABORATORIES' REQUEST FOR APPROVAL OF AN ALTERNATE WASTE DISPOSAL METHOD UNDER 10 CFR 20 2002 DOCKET 030-30429 LICENSEE Core Laboratories, Inc dba ProTechnics Division of Core Labs LICENSE NUMBER 42-26928-01 BACKGROUND The ProTechnics Division of Core Laboratories (ProTechnics) is a well -logging licensee (Materials License # 42-26928-01) authorized to use unsealed byproduct material during tracer operations ProTechnics is currently authorized under conditions of its license to use two alternate waste disposal methods previously approved by the U S Nuclear Regulatory Commission (NRC) under 10 CFR 20 2002 On -site earthen pit burial was approved on December 18, 1995 (Agencywide Documents Access and Management System (ADAMS) Accession,Number ML12243A217) Disposal into Class II wells was approved as a result of the issuance of license amendment 30 on November 4, 2003 (ML033080194) SUMMARY OF PREVIOUS EVALUATIONS The NRC and several Agreement States have already evaluated the impacts associated with the disposal of these well returns containing radioactive materials and have included license conditions authorizing the on -site burial of the material in both shallow pits and Class II disposal wells In December 1995, the NRC staff concluded a "Finding of No Significant Impact (FONSI)" for the generic disposal of this material in on -site burial pits provided specific restrictions are met A licensing amendment was added to ProTechnics' license for this generic disposal option Prior to this point, the NRC staff reviewed and approved these disposals on a case -by -case basis In November 2003, the NRC amended ProTechnics' license to allow the disposal of radioactive material associated with well returns in Class II disposal wells' that had been previously approved to accept non -hazardous oil and gas waste by State agencies As discussed in the NRC's response to "Core Laboratories' Request to Inject Well -Logging Waste in Class II Disposal Wells" (ML041200730), acceptance of this second disposal option by the NRC staff was based on a combination of NRC policies and stringent construction, operating, and monitoring requirements for Class II disposal wells Use of the Class II disposal wells allows for greater control over the waste once it is disposed and limits possible access to the material compared to the previously accepted disposal process of using disposal pits with a soil cover Additional details related to the use of Class II disposal wells are provided in NUREG/CR-3467, "Environmental Assessment of the Use of Radionuclides as Tracers in the Enhanced Recovery of Oil and Gas " ENCLOSURE 1 2 PROPOSED ACTION By letter dated June 19, 2015 (ML15211A594), ProTechnics requested approval for a third alternate disposal method, allowing for the disposal of well returns containing small concentrations of radioactive tracer material (less than 120 -day half-life) at the Meadowfill Landfill in Bridgeport, West Virginia. Contingent on NRC approval and acceptance by the West Virginia Department of Environmental Protection and the West Virginia Department of Health and Human Resources, Waste Management, Inc., the owner and operator of the Meadowfill Landfill, has already agreed to accept the material in cases when on -site earthen pit burial and injection into Class II disposal wells are determined not to be viable options. The need for a third disposal option is due to the fact that some locations where tracer operations are conducted do not allow shallow disposal pits to be used to hold well returns and costs associated with the construction and maintenance of Class II disposal wells, as well as the transport of the well returns to the well sites can be high. As indicated above and emphasized in the submittal, the NRC staff has already acknowledged the low risks associated with the tracer materials through its review and acceptance of on -site burial in shallow burial pits. The NRC staff agrees that disposal in a landfill, which would occur at greater depths and include a deeper cover, would provide additional shielding as well as greater assurances that the tracers would not be prematurely uncovered or handled. As discussed in the submittal, risk and exposure during the transport of tracer material to the Class II disposal wells, which has already been authorized by the NRC, is minimal. Transporting the tracer material to the Meadowfill Landfill, which is closer in proximity, would further minimize risk and exposure to the public. NRC STAFF'S REVIEW AND EVALUATION As part of its tracer operations, ProTechnics injects three radionuclides (Iridium [Ir]-192, Scandium [Sc]-46, and Antimony [Sb]-124) into the wells during hydraulic fracturing activities. The small increase in radioactivity above background assists well operators in optimizing well operations. According to the submittal, no more than 37 Bq/g (1000 pCi/g) of radioactive material is injected into a well at any one time. The submittal does not clearly indicate if this 37 Bq/g (1000 pCi/g) concentration is for a single radionuclide or for a combination of all three radionuclides. As part of its independent analysis the NRC staff considered a combination of all three radionuclides with input concentrations of 37 Bq/g (1000 pCi/g) for each, three times the highest concentration of radioactive material that would be associated with the well returns assuming all of the radionuclides were removed from the well. The manufacturing process for the radioactive tracer, known as ZeroWash®, embeds the non - water soluble radioactive tracer material inside the matrix of a ceramic particle. As a result. there is minimal to no deleterious effects on the environment from the use of ZeroWash®. According to ProTechnics, internal and external exposure to ZeroWash® will be negligible to the public because the material cannot be absorbed through the skin, will not be inhaled, and ingestion of hundreds of pounds of material would be needed in order to reach an Annual Limit of Intake (ALI). The analysis provided with the submittal consisted of a series of mathematical calculations that considered an individual standing directly over a 7.3 m2 (78.54 ft2) shallow pit containing well return waste to a depth of 0.88 m (2.29 ft) with a 0.61 m (2 ft) cover consisting of clean soil on top. The dose, assuming that an individual stood on top of the disposal pit for 24 hours a day for 365 days, was calculated to be 0.056 mSv/yr (5.56 mrem/yr). A similar analysis performed by the NRC staff using RESRAD, Version 6.5, and the same assumptions resulted in a dose of 0.011 mSv/yr (1.1 mrem/yr). Ultimately the use of realistic parameter values associated with disposal in a landfill, including disposal over larger areas, at greater depths, and with a larger cover. would yield doses that are even less significant. Considering the characteristics of the ZeroWash® and the short half-lives of the associated radionuclides, the NRC staff performed a second analysis to evaluate the impacts to the dose associated with the disposal of the well returns in a landfill. In this scenario, the waste is assumed to be spread over a larger area and a deeper cover would be installed. The NRC staff assumed that the same volume of well return material considered in the submittal, 6.4 m3 (227ft3), was distributed over a larger area within the landfill (10 m2 or 33 ft2) to a depth of 0.64 m (2.1 ft) and covered with a 2 meter (6.6 feet) deep cover. The same exposure pathways were considered for the landfill worker. This scenario resulted in a peak dose of 6E-10 mSv/yr (6E-8 mrem/yr). Table 1 compares the RESRAD input parameter values and resulting doses for the two scenarios evaluated by the NRC staff. Table 1. Comparison of RESRAD parameter values and resulting doses calculated by the NRC staff using RESRAD, Version 6.5a Parameter Exposure Pathways Radionuclides Burial Pit Analysis Landfill Analysis Ir-192 Sc-46 Sb-124 Contaminant area (m2) Contaminant depth (m) Length parallel to aquifer flow (m) Cover depth (m) External Gamma Ingestion Inhalation 1000 pCi/g 1000 pCi/g 1000 pCi/g 7.3 m2 0.9 m 2.7 m 0.61 m Doseb 1.1E-02 mSv/yr External Gamma Ingestion Inhalation 1000 pCi/g 1000 pCi/g 1000 pCi/g 10 m2 0.64 m 3.64 m 2m 6E-10 mSv/yr a Default values were used for the remaining RESRAD parameters b Multiply mSv/yr by 100 to get mrem/yr FINDINGS The NRC staff evaluated ProTechnics' request for a third alternate waste disposal method that considers the placement of well returns containing small concentrations of radioactive materials at the Meadowfill Landfill. Based on a review of the analyses provided by ProTechnics and the independent analyses discussed above, the NRC staff finds this disposal option to be acceptable and in compliance with the regulations in 10 CFR 20.2002. The expected doses are a very small fraction of the public dose limit and lower than calculated doses for other alternates already approved for the licensee. The expected dose is less than 0.01 mSv/yr (1 mrem/yr) to 4 the average member of the critical group and the proposed disposal method would keep doses as low as reasonably achievable. APPENDIX J Worker Health and Safety Plan Outline APPENDIX J WORKER HEALTH AND SAFETY PLAN OUTLINE A site -specific Worker Health and Safety Plan (HASP) will be developed prior to the opening of the Pawnee Waste E&P Landfill This site -specific HASP will address a variety of topics, which will be further developed into standard operating procedures (SOP) The SOP will be developed for site personnel to ensure they are fully knowledgeable about each aspect of the operation, and how to maintain a safe environment at all times The purpose of the HASP is to identify areas of concern, mitigation measures, safety training, personal protective equipment (PPE) as well as general procedures required to keep the Pawnee work environment safe for the public, its employees, contractors and customers The HASP, together with the Safety Standards and Training, Emergency Response Plan, and Contingency Plan provided as Sections 9 0, 10 0 and 11 0 of the Operations Plan (Appendix C of the EDOP) (Safety Plans) will be provided to Pawnee's designated responders prior to operation These responders may include agents contracted by Pawnee or public, pnvate and/or volunteers who are responsible for managing emergencies should they arise The HASP will be developed by professionals with specific expertise in construction, waste handling, specific health and safety issues regarding Exploration and Production (E&P) waste, the effects and mitigation practices required when handling NORM/TENORM, and instrumentation Professionals with specific expertise in the subject matter of the Safety Plans will develop the plans as well as address the training required for the safe operation of the landfill Elements of the HASP include the following 1 Facility Description a Regulatory authorities b Property boundaries, ingress, egress and muster points c Safety equipment location d Restricted and non -restricted areas e Infrastructure introduction (e g , scale house, maintenance facility, active work area, leachate tanks, etc ) 2 Description of Construction & Operations a Liner system b Leachate system c Waste handling & spreading d Site cover e Excavation & stockpile areas f Potential hazards 1 I \14\1407882b\0400\0409 edop rev6\1407882h app j worker hasp rev2 doa 3 Waste Types a Review of the Waste Acceptance Plan (Appendix D of the EDOP) b Waste limits c TENORM concentrations and radioactive tracer materials d Potential hazards 4 TENORM a Basic science b Biological effects c Exposure pathways d Time, distance, and shielding e ALARA 5 Personnel Safety Equipment & Practices a Eating, smoking, drinking b Monitors, badges, dosimeters 6 Operating Practices a Operating procedures b Heavy equipment use & maintenance c Waste covering d Leachate handling e Dust control f Other 7 Monitors, Equipment & Screening Devices a Camera system b Portal monitors c Hand held monitors d Personnel safety equipment e Calibration f Other 8 Recordkeeping a Pre -employment training b Routine/weekly training c Annual training reviews 2 I \14\14078826\0400\0409 edop rev6\1407882b app j worker hasp rev2 doa GOLDER golder.com Hello