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ENGINEERING DESIGN &
OPERATIONS PLAN
Pawnee Waste E&P Landfill
Weld County, Colorado
Submitted to: Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South
Denver, CO 80246
Submitted by: Golder Associates Inc.
44 Union Boulevard, Suite 300
Lakewood, CO 80228
On Behalf of: Pawnee Waste LLC
3003 E. Harmony, Suite 300
Fort Collins, CO 80528
Distribution:
2 Copies - Colorado Department of Public Health and Environment
2 Copies - Weld County
2 Copies - Pawnee Waste LLC
1 Copy - Tetra Tech
1 Copy - Golder Associates Inc.
July 23, 2015
Revision 1 — February 19, 2016
Revision 2 — April 22, 2016
Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation
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Table of Contents
1.0 INTRODUCTION 1
1.1 Purpose and Scope 1
1.2 Facility Location 2
2.0 GEOLOGIC AND HYDROGEOLOGIC CONDITIONS 3
2.1 Regional Conditions 3
2.1.1 Regional Geology 3
2.1.2 Regional Hydrogeology 3
2.1.3 Regional Groundwater Quality 4
2.2 Site Conditions 4
2.2.1 Soils and Geologic Units 4
2.2.2 Hydrogeology 4
2.2.3 Groundwater Chemistry 6
3.0 LOCATION RESTRICTIONS AND SITE STANDARDS 7
3.1 Airport Safety 7
3.2 Wetlands 7
3.3 Faults 7
3.4 Seismic Impact Zone 7
3.5 Unstable Areas 8
3.6 Topography 8
3.7 Flood plains 8
3.8 Isolation of Wastes 9
3.9 Surface and Groundwater Waste Placement 9
4.0 ENGINEERING DESIGN AND CONSTRUCTION 10
4.1 Engineered Containment Systems 10
4.1.1 Enhanced Composite Liner System 10
4.1.2 Leachate Collection Sump Secondary Liner 14
4.1.3 Leachate Storage Tank Area Liner System 14
4.2 Leachate Collection and Recovery System (LRCS) Design and Management 15
4.2.1 Leachate Collection and Recovery System Description 15
4.2.2 Leachate Collection and Recovery System Design Calculations 16
4.3 Final Cover 17
4.4 Landfill Capacity, Projected Site Life, and Soil Requirements 18
4.5 Surplus Soil Uses 18
5.0 STORMWATER MANAGEMENT SYSTEM 19
5.1.1 Temporary Surface Water Management 19
5.1.2 Final Stormwater Management System 20
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5.1.3 Erosion Potential Evaluation 21
6.0 CONSTRUCTION DOCUMENTATION 22
7.0 OPERATIONS 23
8.0 REFERENCES 24
List of Tables
Table 1 Summary of Permitted Wells within One Mile of the Facility
List of Figures
Figure 1 Facility Location
Figure 2 Airport Proximity Map
Figure 3 USFWS National Wetlands Inventory Map
Figure 4 USGS Quaternary Faults Map
Figure 5 Permitted Wells within One Mile of the Facility
List of Drawings
Drawing 1
Drawing 2
Drawing 3
Drawing 4
Drawing 5
Drawing 6
Drawing 7
Drawing 8
Drawing 9
Drawing 10
Drawing 11
Drawing 12
Drawing 13
Drawing 14
Drawing 15
Drawing 16
Cover Sheet
Existing Conditions
Subgrade Plan
Final Cover Plan
Stormwater Controls Plan
Cross -Sections Sheet 1 of 5
Cross -Sections Sheet 2 of 5
Cross -Sections Sheet 3 of 5
Cross -Sections Sheet 4 of 5
Cross -Sections Sheet 5 of 5
Landfill Details Sheet 1 of 3
Landfill Details Sheet 2 of 3
Landfill Details Sheet 3 of 3
Surface Water Details Sheet 1 of 3
Surface Water Details Sheet 2 of 3
Surface Water Details Sheet 2 of 3
List of Attachments
Attachment 1 USGS Seismic Design Maps Classification
List of Appendices
Appendix A Hydrogeologic and Geotechnical Characterization Report
Appendix B Engineering Calculations
Appendix B-1 Landfill Capacity, Projected Site Life, and Soil Requirements Calculations
Appendix B-2 Leachate Collection and Recovery System Calculations
Appendix B-2-1 Leachate Head on Liner Calculations
Appendix B-2-2 Leachate Travel Time Calculations
Appendix B-2-3 Leachate Collection Header Pipe Sizing Calculations
Appendix B-2-4 Leachate Collection Header Pipe Structural Integrity Calculations
Appendix B-2-5 Leachate Storage Tank Area Containment Sizing Calculations
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List of Appendices (Continued)
Appendix B-3 Drainage Report
Appendix B-4 Foundation Settlement Calculations
Appendix B-5 Slope Stability Analysis
Appendix B-5-1 Global Stability Analysis
Appendix B-5-2 Finite Slope Analysis
Appendix B-6 Anchor Trench Calculations
Appendix B-7 Soil Erosion Potential Calculations
Appendix B-8 Water Balance Cover Demonstration
Appendix C
Appendix D
Appendix E
Appendix F
Appendix G
Appendix H
Appendix I
Appendix J
Operations Plan
Waste Acceptance Plan
Environmental Monitoring Plan
Closure/Post-closure Plan
Construction Quality Assurance Plan
Solidification Unit Design and Operations Plan
Radiation Risk Assessment
Worker Health and Safety Plan Outline
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1.0 INTRODUCTION
This Engineering Design & Operations Plan (EDOP) has been prepared by Golder Associates Inc. (Golder)
for the proposed Pawnee Waste LLC (Pawnee) commercial exploration and production (E&P) waste landfill
(Landfill or Facility) located in Weld County, Colorado. The Facility proposes to accept both RCRA-exempt
E&P and non -hazardous E&P-related (non-exempt) wastes from the oil and gas industry. The proposed
Landfill will be regulated under 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), as further described herein. In accordance with Sections 1.3 and 1.6 of the Regulations, a
Certificate of Designation is being concurrently sought from the local governing body having jurisdiction,
Weld County, along with a Use by Special Review (USR) permit per Weld County Code.
1.1 Purpose and Scope
This EDOP contains the information necessary to demonstrate that the location restrictions/site
standards, engineering design, waste acceptance and operations procedures, environmental monitoring
program, and closure/post-closure activities for the proposed Landfill will be in accordance with current
applicable CDPHE Regulations.
Contained in this document are discussions of location standards, design, waste characterization/acceptance,
operations, radiation risk assessment, groundwater monitoring, recordkeeping, and closure/post-closure
requirements for the proposed Landfill. This report contains 16 engineering plan sheets (Drawings 1
through 16) including: an existing conditions plan, subgrade plan and leachate collection layout, final cover
grading plan and stormwater control system, cross -sections depicting the landfill and underlying geology, and
details of the Landfill and stormwater control features. The groundwater monitoring network is shown in
multiple plan sheets.
A summary of the hydrogeologic and geotechnical site characterization from the field investigation
conducted in 2014, including laboratory soil testing results, is presented in Appendix A. Engineering
calculations to support the design are provided in Appendix B. The Operations Plan is presented in
Appendix C. The wastes that may be accepted at the Landfill, as well as the characterization and
screening activities required, are described in the Waste Acceptance Plan, Appendix D. Appendix E
contains the Environmental Monitoring Plan. The Closure/Post-closure Plan, including a description of the
final cover system and an estimate of the largest area of the Landfill ever requiring a final cover during the
active life, is presented in Appendix F. Appendix G contains the Construction Quality Assurance Plan. A
Design and Operations Plan specific to the proposed Solidification Unit is provided in Appendix H.
Appendix I contains the risk assessment and RESRAD modeling associated with the receipt of E&P
wastes which may contain naturally occurring radioactive material (NORM)/technologically enhanced
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naturally occurring radioactive material (TENORM) waste. A general overview and proposed outline for
the Worker Health and Safety Plan (HASP) is provided in Appendix J.
Cost estimates for hiring a third party to close the Landfill and to conduct post -closure care will be
provided under separate cover upon approval of the EDOP by CDPHE and Weld County. The financial
assurance mechanism sufficient to ensure payment of such costs will be established within 60 days prior
to initial receipt of waste.
1.2 Facility Location
Pawnee is proposing to develop the Landfill on a 240 -acre contiguous property owned by Pawnee Waste
LLC (Site). The Pawnee Waste E&P Landfill will be located approximately four miles southeast of Grover,
Colorado, near the intersection of County Road 118 and County Road 95 in Weld County (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 6"' Principal Meridian.
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2.0 GEOLOGIC AND HYDROGEOLOGIC CONDITIONS
This section provides an overview of regional and site -specific geologic and hydrogeologic conditions of
the proposed Landfill facility area, based on the information and references included in Appendix A
(Hydrogeologic and Geologic Site Characterization). Appendix A-2 presents a detailed description of the
field investigation conducted for the Facility to characterize the site -specific geology, hydrogeology, and
soil conditions. and also includes tables, figures, and attachments documenting the field investigation
conducted in 2014. Cross -sections of the site -specific geologic and hydrogeologic conditions, based on
the results of the field investigation, are presented in Appendix A and Drawings 6 through 10.
2.1 Regional Conditions
This subsection summarizes geologic and hydrogeologic conditions in the region. A more detailed
discussion of the site -specific geology and hydrogeology, along with applicable figures and reference
citations, can be found in Appendix A.
2.1.1 Regional Geology
The Facility is located within the Denver-Julesburg (DJ) Basin in northeastern Colorado. The DJ Basin is
a north -south structural basin that covers 70,000 square miles of northeast Colorado, southeast
Wyoming, and northwest Nebraska. The basin formed during the Laramide Orogeny and is characterized
by its asymmetry with gentle east flank and faulted, steeply dipping west flank. The basin contains
sedimentary units dating from the Cambrian Period (oldest) to the Tertiary Period (youngest). The thickest
part of the DJ Basin occurs north of Denver, where it is approximately 13,000 feet thick. Approximately
70% of the sedimentary rock in the DJ Basin is composed of sandstone, shale, and limestone units of
Cretaceous age (Higley and Cox 2002).
2.1.2 Regional Hydrogeology
The proposed Facility is underlain by the Tertiary -aged White River Formation consisting primarily of
claystone, siltstone, and sandstones commonly containing volcanic ash (Tweto 1979). The primary
aquifer in the vicinity is the High Plains Aquifer system including the Ogallala, the Arikaree, and the Brule
formations. These formations of the High Plains Aquifer are not well defined in the vicinity of the Facility.
However the surficial aquifer along the South Platte River Valley directly overlies the High Plains Aquifer
system and is commonly used for irrigation, stock and domestic use in the immediate vicinity of the
Facility (Robson and Banta 1995).
The Tertiary -age Ogallala, Arikaree, and Brule formations are overlain by Quaternary -age alluvial
deposits where the South Platte River Valley surficial aquifer can be found. The surficial aquifer is often
present in confined or semi -confined conditions. Regionally, silt and clay deposits provide some level of
groundwater protection to the surficial aquifer. The local and regional groundwater flow is to the west and
southwest toward Jackson Draw and the South Platte River. The piezometric level is about 5,020 feet
above mean sea level (AMSL), or 50 feet below the existing ground surface at the Facility.
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2.1.3 Regional Groundwater Quality
A regional groundwater quality study (USGS 1985) of the High Plains Aquifer states that there are large
quantities of groundwater of quality suitable for irrigation, with concentrations of dissolved solids generally
less than 500 milligrams per liter. Groundwater in this area can contain more than 1,000 milligrams per
liter of dissolved sulfate. The study indicated that groundwater in this aquifer is predominantly a
calcium -magnesium -bicarbonate type.
2.2 Site Conditions
Site geologic and hydrogeologic conditions were evaluated during the hydrogeologic and geotechnical
site investigation performed by Golder between September 2 and October 27, 2014. A detailed
description of the site investigation is presented in Appendix A-2 - Hydrogeologic and Geotechnical Field
Investigation Report.
2.2.1 Soils and Geologic Units
A custom soil resource report was generated for the proposed Facility area using the United States
Department of Agriculture - Natural Resources Conservation Service (USDA-NRCS) Web Soil Survey
and can be found in Appendix A-1. The surface soils at the Facility include Kim -Mitchell Complex and
Stoneham fine sandy loam, composed primarily of silt and fine sandy loams. The parent materials for
soils within this soil association are calcareous loamy alluvial deposits.
Based on the October 2014 field investigation, the geology at the Site was divided into three simplified
and mappable strata. These strata were distinguished based on grain size and color differences. The
subsurface soil conditions found in the boreholes have been categorized into the following three strata:
• Stratum 1 - Eolian silt, overlying;
• Stratum 2 - Sandy silt, silty clay, and residuum weathered from siltstone/claystone: and
IN Stratum 3 - Localized lenses of sand and silty sand.
Descriptions and index properties of these strata are detailed in Appendix A. Four cross -sections
depicting the landfill overlaid with the underlying geology and one additional geology -only cross-section,
have been prepared and are presented in Drawings 6 through 10. No evidence of structural features (e.g.,
faults) was observed during the field investigation. Review of the United States Geological Survey
(USGS) Interactive Fault Map (USGS and Colorado Geological Survey 2014) (see Figure 4) also did not
identify any known faults having displacement in Holocene time at or within 200 feet of the Facility.
2.2.2 Hydrogeology
The hydrogeology beneath the proposed Landfill has been simplified into two hydrogeologic zones: the
vadose zone/confining unit and the uppermost saturated unit. The near -surface unsaturated deposits (i.e.,
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the vadose zone/confining unit) range from 49 to more than 70 feet thick. The vadose zone/confining unit
is composed of eolian silt overlying sandy silt, silty clay, discontinuous sand lenses, and residuum from
siltstone and claystone.
The uppermost saturated zone consists of the first saturated interval found below the vadose
zone/confining unit. The uppermost saturated zone is composed primarily of fissured silty clay with three
instances of saturated sand observed at BH-2014-01, BH-2014-03, and MW -2014-03. Groundwater
movement through the saturated zone is dominated by the fissured nature of the clayey material and thin
saturated sand lenses. This uppermost saturated zone is continuous across the Site with a potentiometric
surface at an elevation of approximately 5,020 feet AMSL.
The uppermost saturated zone is considered confined because water levels in each borehole stabilized at
an elevation above the first occurrence of water observed during the drilling program. Stabilized water
levels ranged from approximately 1 foot to approximately 14 feet above the first occurrence of water.
Water level contours have been prepared for the Site and are presented in Appendix A, Figure A-5.
2.2.2.1 Hydraulic Characteristics
Golder performed variable -head "slug" hydraulic testing in each of the four groundwater monitoring
wells initially installed at the Facility. Slug testing was performed to estimate the in situ saturated
horizontal hydraulic conductivity of the geologic materials isolated by the screened intervals and was
used for calculation of groundwater flow velocity, as discussed in the next section. The horizontal
hydraulic conductivity (K) estimated from the hydraulic (slug) testing ranged from 1.5 x 10.2 cm/sec (43
feet/day) to 6.0 x 10-5 cm/sec (0.17 feet/day) with a geometric mean of 1.8 x 10-3 cm/sec (5.1 feet/day). A
summary of the slug test results is presented in Table A-2-4 in Appendix A-2.
2.2.2.2 Direction and Rate of Groundwater Flow
Based on the groundwater levels measured in October 2014, groundwater generally flows to the west at a
gradient of 0.0004 ft/ft. Hydraulic conductivity of the upper portion of the saturated zone ranges from
0.17 to 43 feet/day. The effective porosity of the sediment was estimated at 20%. The following modified
Darcy equation was used to estimate groundwater velocity:
Ki
V= —
no
where: V = True velocity (ft/day)
K = Hydraulic conductivity (ft/day)
i = Hydraulic gradient (ft/ft)
ne = Porosity (% / 100)
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Based on the highest hydraulic conductivity obtained from the hydraulic testing, the maximum
groundwater velocity is estimated at 0.086 ft/day.
2.2.3 Groundwater Chemistry
Background groundwater quality data collection commenced in January 2015. A baseline groundwater
monitoring report will be prepared and submitted to CDPHE and Weld County upon completion of the
requisite number of background sampling and analysis events.
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3.0 LOCATION RESTRICTIONS AND SITE STANDARDS
This section describes the Landfill setting relative to the location restrictions and site standards found in
Section 3.1 of the Colorado Solid Waste Regulations, 6 CCR 1007-2, Part 1.
3.1 Airport Safety
The Landfill is not located within a five -mile radius of any airport runways; therefore, notification of the
Federal Aviation Administration (FAA) or providing evidence regarding mitigation of a potential bird
hazard is not required. The Pine Bluffs Municipal Airport is the nearest public airport to the proposed
Facility and is located approximately 21.4 miles to the north, as shown in Figure 2.
3.2 Wetlands
The Landfill is not located in a swamp, marsh, bog. or similar area that could be defined as a wetland
according to the United States Fish and Wildlife Service (USFWS) National Wetland Inventory Wetlands
Mapper (USFWS 2014), as shown in Figure 3. No wetlands or wet areas were identified within the
proposed Facility on the USGS 7.5 -minute quadrangle topographic map. Site reconnaissance by Golder
personnel also confirmed that there is no vegetation on site that would typically be adapted for life in
saturated soil conditions.
3.3 Faults
There are no known faults that have had a displacement in Holocene time present at or within 200 feet of
the Landfill, according to the USGS Interactive Fault Map (USGS and Colorado Geological Survey 2014),
as shown in Figure 4.
3.4 Seismic Impact Zone
The Landfill is marginally located in a "seismic impact zone," defined in the Colorado Solid Waste
Regulations as an area with a 10% or greater probability that the maximum horizontal acceleration in
lithified earth material (expressed as a percentage of the earth's gravitational pull) will exceed 0.10g in
250 years. Based on the USGS Seismic Design Maps tool (USGS 2014a), the peak horizontal
acceleration with a 2% probability of exceedance in 50 years (equivalent to 10% in 250 years) for the
location of the Landfill is 0.10g. Using the proposed Landfill location and a Seismic Class C under
International Building Code (IBC) classification, an SDd1 value of 0.053g was generated by the Design
Maps tool and is shown in Attachment 1. A peak acceleration of 0.053g indicates a low risk of seismic
activity. Slope stability calculations were performed to demonstrate that the Landfill is capable of resisting
the design seismic acceleration and are included in Appendix B-5.
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3.5 Unstable Areas
No geologic unstable areas, such as underground mines or landslide deposits, are located on or beneath
the Landfill. There are no on -site or local man-made features or events (surface or subsurface), such as
underground excavations or karst features, that would cause the Facility to be unstable, based on review
of the USGS Geologic Map of the Site location (USGS 2013), as shown in Figure 1. The gentle slopes
that characterize the Site property pose a negligible slope stability risk.
A previous soils study performed by GROUND Engineering (GROUND Engineering 2012) on an adjacent
property to the west of the proposed Landfill identified native windblown (eolian) silty soil to depths of
typically 11 to 13 feet below the ground surface (bgs), underlain by interbedded sandstones and siltstones
to the explored depths of 60 feet. The geotechnical investigation performed by Golder in 2014 found
conditions similar to those reported in the GROUND Engineering report. Eolian silts (loess) are prone to
settlement when submerged and a load is applied. The GROUND Engineering report indicated that
consolidations of up to 7% were measured in lab tests. A laboratory consolidation test performed by Golder
on an undisturbed sample collected between 15 to 17 feet bgs indicated consolidation up to 10%. This
potential settlement of the near -surface soils has been taken into account as part of the engineering design
of the Landfill and is not predicted to adversely impact the operation or integrity of the containment systems.
3.6 Topography
Based on the topographic survey for the proposed Facility, the topography is characterized by a relatively
uniform slope of approximately 0.5 to 1%. Drainage across the proposed Facility generally flows
southwestward from a topographic high in the northeastern corner of the Facility to a topographic low in
the southwestern corner of the Facility. Surface water generally flows toward an intermittent waterway,
Jackson Draw, roughly 4,000 feet southwest of the proposed Landfill boundary. The Site topography and
location of Jackson Draw are shown in Figure 1.
Due to the relatively minimal topographic relief, significant natural protection from prevailing winds is not
available. Windy conditions are not expected to cause a significant operational challenge for the waste
types and operational methods proposed for this Landfill. Operational requirements and nuisance controls
will be implemented to provide suitable protection from prevailing winds to the extent necessary.
3.7 Floodplains
The Landfill is within a "Zone D" undetermined area per the Federal Emergency Management Agency
(FEMA). which means a flood study has not been performed. Based on review of the topographic survey for
the proposed Facility, it does not lie within a floodplain. The nearest intermittent waterway from the Landfill.
Jackson Draw, is located hydraulically down -gradient approximately 4,000 feet to the southwest, as shown
in Figure 1. The elevation drop between the southwest corner of the proposed Landfill boundary and
Jackson Draw is approximately 20 feet, indicating that the flood risk is negligible.
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3.8 Isolation of Wastes
The Landfill will isolate wastes from the public and environment through the use of an enhanced
composite liner system, described in Section 4.0 and detailed in Drawing 11.
The Environmental Monitoring Plan for the proposed Facility is presented as Appendix E. Groundwater
quality analytical results for samples collected from monitoring wells around the Facility will be provided to
the CDPHE on an ongoing basis via annual reports, and are not included herein.
3.9 Surface and Groundwater Waste Placement
No waste will be placed below or into surface water or groundwater. The cross -sections presented in
Drawings 6 through 10 illustrate the groundwater potentiometric surface relative to the proposed base of
the landfill liner. The uppermost saturated zone was found to exist at a depth of approximately 50 feet below
natural ground surface, and, given the excavation grades proposed, the lowest points in the Landfill liner
(sumps) will be separated from the uppermost saturated zone by a minimum of 20 vertical feet. Surface water
run-on and runoff controls are described in Section 5.0 and Appendix B-3. Facility operations will be
performed as described in Appendix C.
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4.0 ENGINEERING DESIGN AND CONSTRUCTION
4.1 Engineered Containment Systems
This section describes the engineering design of the Landfill, per Sections 3.2 and 3.5 of the Colorado Solid
Waste Regulations. 6 CCR 1007-2. Part 1. The proposed Landfill will be designed, constructed, and
maintained with state -of -the -practice engineered containment systems designed to meet or exceed current
CDPHE regulations. Engineered containment systems will include an enhanced composite liner system, a
leachate collection and recovery system, double -lined leachate collection sumps, and a water balance final
cover. Each engineered containment system is discussed in detail in the following subsections.
4.1.1 Enhanced Composite Liner System
The proposed Landfill will be constructed with an enhanced composite liner system, which will act as the
primary barrier between the waste and the subsurface environment. A detail of the proposed enhanced
composite liner is shown in Drawing 11. The enhanced composite liner system will consist of the following
components, listed from top of liner down to existing foundation material:
■ A protective cover layer (3 -foot minimum thickness) composed of select E&P waste
material installed over the entire liner area as part of initial waste ("fluff") layer, except
where indicated and unless otherwise approved by CDPHE;
IN An 8 oz./sq. yd. non -woven geotextile;
• A 12 -inch -thick sand drainage layer installed over the entire liner area and composed of
soils exhibiting a hydraulic conductivity equal to or greater than 1 x 10-2 cm/sec;
• A 60 -mil HDPE textured (both sides) geomembrane liner;
■ A geosynthetic clay liner (GCL) liner;
• A 24 -inch -thick compacted low -permeability soil liner composed of on -site soils with a
minimum 3% bentonite admixture. exhibiting a hydraulic conductivity no greater than 1 x
10-7 cm/sec; and
■ Prepared subgrade material composed of conditioned and compacted existing
subsurface material.
The proposed bottom grades of the liner system (referred to as the subgrade) are shown in Drawing 3.
Excavation sideslopes were designed not to exceed 3H:1V, and liner floor grades were designed to slope
toward the centerline (header) of each phase in a herringbone pattern at approximately 2%. The proposed
liner grades were designed to maintain a minimum vertical separation distance of 20 feet from the
interpreted potentiometric surface contours within the Landfill footprint to the top of subgrade, as illustrated
in the cross -sections presented in Drawings 6 through 10. These cross -sections also depict the existing
ground surface elevation, borehole information, geologic strata, the maximum surface of the proposed
waste and final cover system, the proposed excavation sideslopes and floor of the subgrade, and the
potentiometric surface contours, generated from the water level measurements collected in October 2014.
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The enhanced composite liner system will be installed under a comprehensive construction quality
assurance (CQA) program, including electrical liner integrity surveys, to verify that both the soil materials
and the geosynthetic components of the liner system are procured and installed as intended in the design.
Electrical liner integrity survey methods are an effective and proven quality assurance measure to locate
defects in HDPE geomembranes and have been used successfully in the waste and mining industries.
Electrical liner integrity testing will be performed as part of the construction process for the Landfill on
both the exposed geomembrane (immediately after liner installation and completion of traditional
geomembrane CQA), and after the geomembrane is covered with the leachate collection (sand) drainage
layer material. Using this approach, both installation -related defects (e.g., due to improper seaming,
penetration from rocks in the subgrade, cuts, or worker -caused damage) and defects caused by heavy
equipment damage during drainage material placement can be detected and repaired prior to placing the
liner into service. The methods used for exposed geomembrane liner integrity surveys can detect defects
down to pinhole size; the sensitivity of surveys performed on soil -covered geomembrane is approximately
1/4 inch. The addition of electrical liner integrity surveys to a CQA program has been demonstrated
through extensive industry research to dramatically reduce the potential for measurable leakage through
the geomembrane. Pawnee is voluntarily incorporating the use of electrical liner integrity surveys into the
CQA program for the Landfill liner system as a means of providing the "best -available technology" to
ensure a superior level of environmental protection at the Facility.
4.1.1.1 Foundation Settlement Calculations
Potential settlement of the foundation soils beneath the proposed Landfill was estimated using
consolidation properties of the on -site material. Consolidation properties (i.e., the compression index [Cc]
and recompression index [Cr]) were determined by a consolidation test of one undisturbed soil sample
collected during the field program. The test was conducted on soil that will remain below the Landfill after
excavation to reach subgrade grades.
Results of the consolidation test, along with the estimated loading from the maximum waste and cover
soil profile, were used as input in the liner foundation settlement calculations. It was assumed that
consolidation will take place throughout the upper 25 feet below existing ground surface based on field
investigation data (i.e., standard penetration test results) correlated with visual observations from the
continuous split barrel samples.
Total predicted settlement under the maximum waste and soil cover was conservatively estimated to be
1.3 feet, with the maximum predicted differential settlement resulting in a calculated decrease in the slope
of the leachate collection header drain from the designed 1.2% to a minimum of 1% and the subgrade
floor grades from the designed 2% to 1.5%. The foundation settlement calculations are provided in
Appendix B-4.
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The leachate head on liner calculations (Appendix B-2-1). leachate travel time calculations (Appendix B-2-2),
and leachate collection system header pipe sizing calculations (Appendix B-2-3) were performed using a
conservative minimum header pipe post -settlement slope of 1.0% and floor post -settlement slope of 1.5% to
allow for maximum potential future settlement while maintaining the necessary drainage characteristics.
4.1.1.2 Slope Stability Analyses
Slope stability analyses were performed based on the proposed liner and final cover grades for the
Landfill. A detailed discussion of the slope stability analyses is included in Appendix B-5-1.
4.1.1.2.1 Global Stability
Several critical intermediate/operational conditions were analyzed at various geometries throughout the
development of the Landfill, including initial excavation of the Landfill. intermediate waste filling. and final
cover conditions, under both static and pseudo -static (seismic) loading conditions. The global stability
analyses were performed to evaluate the minimum factor of safety (FOS) for global and translational
veneer failure.
Three critical cross -sections were identified for the slope stability analyses, as presented in Figure B-5-1-1
and summarized below:
• Section A -A': Final Conditions - Cross-section through the lowest perimeter berm height
(i.e., minimum resisting force) and the highest depth of waste (i.e., maximum driving
force);
• Section B -B': Final Conditions - Cross-section through the Landfill and proposed
stormwater detention pond; and
• Section C -C': Intermediate Excavation and Waste Filling Conditions and Final Conditions
- Cross-section through the maximum excavated slope constructed for the subgrade
(i.e., interim conditions during the construction of Phases 1A, 1B, 2A and 2B).
Limit -equilibrium global slope stability analyses (2-D) were performed using Spencer's method in
SLIDE 6.0 (RocScience 2012) slope stability modeling software. Seismic stability was evaluated using a
pseudo -static analysis procedure generally following the Hynes -Griffin and Franklin method. A horizontal
seismic load coefficient of 0.05 was used for the pseudo -static analyses, corresponding to Y2 of the
maximum considered peak ground acceleration for the 2,475 -year event (0.10g).
The minimum targeted factors of safety for static and pseudo -static analyses were 1.6 and 1.2,
respectively. Factors of safety for the Landfill were calculated to be acceptable for all cross -sections
evaluated (i.e., equal to or greater than the minimum targeted factors of safety values); therefore, the
proposed liner system is predicted to be stable under both static and seismic loading conditions.
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4.1.1.2.2 Liner Translational Veneer Stability
Relatively thin layers of soils and/or geosynthetics, such as the proposed Landfill liner system, can
translate gravitationally or in response to external loading, such as vertical surcharges from Landfill
operational equipment. The veneer stability of the liner was evaluated along Section C -C', which was cut
perpendicular to the maximum -depth 3H:1V liner excavation slope.
The interface between the compacted low -permeability soil liner and the GCL was determined to be the
most critical interface (i.e., exhibiting the minimum interface friction angle among the proposed Landfill
liner system components), based on a review of several peak interface friction angles between various
geosynthetic and natural earth materials as published in the literature (Koerner and Narejo 2005).
The internal (veneer) stability of the Landfill liner system was evaluated assuming short-term static
loading conditions. seismic loading conditions. and short-term construction conditions assuming a
bulldozer load on the liner. Veneer stability was evaluated using the finite -slope analysis methods
established by Koerner and Soong (2005). Given the short-term durations of these anticipated loading
conditions (i.e., only during initial cell construction and placement of protective cover), the minimum
targeted factors of safety against a veneer failure in the Landfill liner are 1.2 and 1.0 for static and seismic
loading, respectively. The factors of safety calculated against translational veneer failure were found to be
above these minimum targeted factors of safety; therefore, the proposed liner is considered stable during
the short-term construction conditions evaluated.
The translational veneer stability calculations are presented in Appendix B-5-2.
4.1.1.3 Anchor Trench Analysis
Anchor trench calculations were performed to verify the capacity of the proposed anchor trench
dimensions to resist the maximum anticipated loads that will be applied to the geosynthetic liners on the
sideslopes during construction of the liner system and to identify the mode of failure (pull out or tear) in
the geomembrane and GCL liner system in the event of a failure.
Using a run -out length of two feet and an anchor trench depth of two feet, the geomembrane and GCL
liner system is predicted to withstand the maximum expected stresses from the weight of the
operations/protective cover layer and the live construction loads during liner placement. The resisting
forces acting on the geomembrane and GCL within the anchor trench are less than the tensile yield
strength of the geomembrane and GCL. indicating that, in the event of a failure. the geomembrane and
GCL would pull out of the anchor trench rather than tear. Anchor trench calculations are provided in
Appendix B-6.
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4.1.2 Leachate Collection Sump Secondary Liner
A secondary geomembrane and GCL will be installed within the leachate collection sump areas to create
a redundant liner system where leachate head may accumulate, and will be extended up the leachate
collection riser pipe corridor on the sideslope for added protection. Details and cross -sections of the
double liner system proposed for the sump areas are shown in Drawing 13. The double liner system.
including the sump profile, will consist of the following components, listed from top of the liner system
down to existing foundation material:
• Protective cover layer (12 -inch minimum thickness) installed over the entire liner area
and composed of either on -site soils or select E&P waste material;
• A 16 oz./sq. yd. non -woven geotextile;
■ A leachate collection sump backfilled with two feet (minimum) of drainage gravel, housing
the leachate collection header and riser pipes;
IN A protective 16 oz./sq. yd. non -woven geotextile;
IN A primary 60 -mil HDPE textured (both sides) geomembrane liner;
• A primary GCL liner;
IN A secondary 60 -mil HDPE textured (both sides) geomembrane liner;
• A secondary GCL liner;
■ A 24 -inch -thick compacted low -permeability soil liner composed of on -site soils with a
minimum 3% bentonite admixture, exhibiting a hydraulic conductivity no greater than
1 x 10-7 cm/sec; and
• Prepared subgrade material composed of conditioned and compacted existing
subsurface material.
The secondary geomembrane and GCL will be installed over the top of and will be welded to the liner that
lines the remainder of the Landfill to ensure continuity in the bottom -most liner material. In this way, the
liner that underlies the remainder of the Landfill will serve as the secondary liner within the sumps and
riser pipe corridors, and the upper geomembrane and GCL will serve as the primary liner in the sump
areas and riser pipe corridors.
4.1.3 Leachate Storage Tank Area Liner System
The proposed leachate storage tank area will be composed of a concrete basin to hold up to eighf<frac_
tanks for temporary storage of leachate. The concrete basin will have construction joints sealed with PVC
waterstops and silicone caulking (or engineer -approved alternative). The concrete basin will be sloped to
a sump area where stormwater will collect. An outlet pipe will allow stormwater to be drained from the
containment area, as needed.
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The design of the secondary containment for the leachate storage tank storage area is discussed in
Appendix B-2-5. Additional information on the sizing and operation of the leachate storage tank area is
included in Section 6.1 of the Operations Plan (Appendix C).
4.2 Leachate Collection and Recovery System (LRCS) Design and Management
4.2.1 Leachate Collection and Recovery System Description
The leachate collection and recovery system (LRCS) is designed to collect leachate and contact surface
water runoff from the waste mass and provide for an efficient means of removal. The LRCS will consist of
a 12 -inch sand drainage layer with hydraulic conductivity equal to or greater than 1 x 10-2 cm/sec overlain
by an 8 oz./sq. yd. non -woven geotextile. Waste placement will be limited near the crest of the Landfill
perimeter berms and along the cell termination berms as shown in Drawings 11 and 12 to provide contact
water runoff unimpeded access to the leachate collection drainage layer. Drainage from the sand
drainage layer will flow down the Landfill sideslopes and across the sloping floor of the Landfill into
leachate collection header drains installed along the lowest point (centerline) of each phase. Each header
drain will be installed at a design 1.2% slope towards one of four leachate collection sumps constructed at
the east and west ends of the Landfill and will consist of an 8 -inch -diameter SDR 11 HDPE perforated
header pipe surrounded with gravel and encapsulated by a non -woven geotextile. Solid -wall cleanout
riser pipes will be connected to the ends of the perforated header pipes in the leachate collection sumps
and will extend up the east and west sides lopes (see detail in Drawing 13) of the Landfill to allow for
cleaning of the leachate collection header pipes, if needed. The layout of the leachate collection header
drains and sumps is illustrated in Drawing 3, with details provided in Drawings 11 through 13.
As indicated above, the leachate collection header drains will be placed on the lowest points of the liner
floor, along the centerline of each of the four designed phases. The gravel material around the header
pipe will provide for proper bedding and structural support of the leachate collection header pipes and will
also convey leachate towards the leachate removal sumps. The gravel will be used as pipe bedding and
will also be mounded over the header pipes to provide adequate structural support and protection. The
gravel will be encapsulated by a 16 oz/sq. yd non -woven geotextile to limit the potential for clogging of the
leachate collection pipe/gravel by migration of fines. The leachate collection gravel will have a minimum
specified hydraulic conductivity of 1 cm/sec, which will provide system redundancy as the header pipes
were designed to convey the maximum anticipated leachate generation rate.
The leachate collection sumps were designed to be recessed approximately two feet below the
surrounding liner grades to allow for accumulation of leachate and efficiency of pumping. The leachate
removal system will be contained completely within the Landfill liner system to eliminate the need for liner
penetrations. Sumps will be double -lined with secondary HDPE geomembrane and GCL liners
(as described in Section 4.1.2 above and shown in Drawing 13). After construction of the primary liner
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system, a geotextile cushion will be placed in the sump excavation. and the sump will be backfilled with
clean gravel to allow leachate to be easily conveyed to the sump riser pipes. Leachate will be removed
from the sump via 18 -inch -diameter SDR 11 HDPE sump riser pipes. Two sump riser pipes will be
installed in each sump for system redundancy in the event of riser pipe blockage or the need for
additional pumping capacity. A perforated section of sump pipe will extend horizontally onto the floor of
the sump area to allow leachate to enter the riser pipe. Solid sections of sump riser pipe will extend from
the floor of the sumps to approximately two feet above the crest of the perimeter berm. The top of the
solid riser sections will be fitted with blind flanges. The riser pipes will be used to remove leachate and to
measure leachate levels. Submersible pumps will be installed within the riser pipes to pump accumulated
leachate from the sumps up the Landfill sideslope to a dedicated water truck for management by one of
the methods detailed in Section 6.1 of the Operations Plan (Appendix C).
4.2.2 Leachate Collection and Recovery System Design Calculations
4.2.2.1 Leachate Head on Liner
An analysis was performed to conservatively predict leachate head on the liner throughout the life of the
Landfill, assuming various waste depths and cover configurations. This analysis is described in detail in
Appendix B-2-1. The Hydrologic Evaluation of Landfill Performance (HELP) model, version 3.07,
developed by the US Army Corps of Engineers was used for this analysis. The HELP model analysis was
performed for the following scenarios, assumed to represent the most critical operational scenarios from a
leachate-generation standpoint:
• Scenario 1: 6 feet of waste with 6 -inch daily cover (assumed to consist of native clean fill
ML material);
• Scenario 2: 80 feet of waste with 6 -inch daily cover (assumed to consist of native clean
fill ML material);
• Scenario 3: 80 feet of waste with 12 -inch intermediate cover (assumed to consist of
native clean fill ML material); and
• Scenario 4: 160 feet of waste with 3 -foot water balance final cover (assumed to consist of
native clean fill ML material)
Stormwater runoff that has contacted exposed waste or waste having only daily cover (contact water) will
be treated as leachate and managed as described in Section 6.1 of the Operations Plan (Appendix C).
Under intermediate and final cover conditions, runoff will be considered stormwater and will be conveyed
to the stormwater detention pond.
Under all open daily. intermediate, and closed conditions for leachate generation, the HELP model
simulation predicts that the peak head on the liner with the designed leachate collection system to be less
than 12 inches (considering potential reductions in the slope of the Landfill floor and header pipes due to
foundation settlement). as required by USEPA Subtitle D regulations.
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4.2.2.2 Leachate Collection Header Pipe Flow Capacity
The required flow capacity of the leachate collection header pipe was calculated using Manning's equation,
assuming uniform flow conditions. The peak daily flow generated from the HELP model (applying Scenario 3
waste and cover configurations over the largest sump area to model active waste placement over the entire
constructed area) were used as the maximum estimated flow to be conveyed within the leachate collection
header pipe. This calculation is described in detail in Appendix B-2-3. The proposed 8 -inch -diameter
SDR 11 pipe can adequately convey the maximum anticipated leachate generation rate and without reliance
on the additional flow capacity of the surrounding drainage gravel.
4.2.2.3 Leachate Collection Header Pipe Strength
Pipe strength calculations were completed to verify the structural integrity of the proposed leachate
collection header pipes (8 -inch -diameter SDR 11 HDPE) under the overburden pressure of the maximum
height of waste and cover soils. The calculations obtained factors of safety for wall crushing, wall buckling,
and ring deflection. The ability of the leachate collection pipes to withstand the loads anticipated to be
imposed by the overlying waste is discussed further in Appendix B-2-4. All factors of safety exceeded the
minimums recommended by the Plastic Pipes Institute (PPI) for thermoplastic pipe applications.
In addition, to provide protection against damage from overlying waste and waste placement equipment,
the leachate collection pipes will be flagged during construction and caution will be used during placement
of the initial 3 -foot protective cover "fluff' layer of select waste. Truck or wheeled vehicle traffic will not be
allowed access to any area of the cell until the 3 -foot "fluff" layer has been placed over the liner and
leachate collection pipes.
4.3 Final Cover
The final cover design includes 4H:1V side slopes on all sides of the Landfill with a top deck (crown) slope
of 5 to 10%. The final cover system will be constructed in phases after the waste reaches final design
grades. Drawings 4 and 5 show the proposed top of final cover contours and stormwater controls. A water
balance final cover system has been designed in accordance with the CDPHE's Final Guidance
Document: Water Balance Covers in Colorado" (2013) (WBC Guidance). A detail of the proposed final
cover system is shown in Drawing 11. The final cover system will consist of the following components
listed, from top to bottom:
• 6 -inch -thick topsoil layer; and
■ 30 -inch -thick water storage layer.
Water balance covers in Colorado are based on the Ecozone location of the Site and the predominant
USDA soil type of on -site soils to be used in the final cover. A demonstration that on -site soils meet the
requirements for a water balance cover per the WBC Guidance is provided in Appendix B-8. Final cover
soils will be obtained from select areas of the landfill excavation that are demonstrated through borrow
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source characterization testing to yield soils falling within the acceptable zone for use as a water storage
layer in Ecozone 3 (per "Final Guidance Document: Water Balance Covers in Colorado" [CDPHE 2013]).
Final cover stormwater controls will be constructed on the completed final cover, as discussed in
Section 5.0 and Appendix B-3. Final cover will not be applied to the interim sideslope of a closed fill area
that has not been filled to final grade until the adjacent fill area is filled. Intermediate cover will be applied
to those slopes of the fill areas that are adjacent to future fill areas and have not reached final elevation in
accordance with CDPHE regulations.
Final cover installation will be performed in accordance with the Closure/Post-closure Plan (Appendix F)
and the Construction Quality Assurance Plan (Appendix G). The Closure/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.
4.4 Landfill Capacity, Projected Site Life, and Soil Requirements
Based on the liner and final cover grading plans and an estimated waste intake rate of 1,000 tons/day, the
estimated life of the 74 -acre lined disposal area is approximately 42-45 years (assuming 5% and
10% daily/intermediate cover, respectively). The actual life of the landfill will depend on a number of
factors, including tonnage of waste actually received, compaction factors, cover usage, etc. The effective
airspace capacity for the landfill as proposed is approximately 11,478.000 million cubic yards. This
effective airspace capacity includes the volume consumed by waste and daily/intermediate cover, as
detailed in Appendix B-1. Calculations of the landfill airspace volume and soil requirements, including
components of the liner and final cover system, are presented in Appendix B-1. Soil needed for cell
construction and cover will be obtained from the landfill excavation. The sand for the leachate drainage
layer, and all drainage gravel material, will be obtained from off -site sources.
4.5 Surplus Soil Uses
Surplus soil resulting from Landfill excavation and that is not projected to be needed for intermediate or
final cover may be utilized for a number of purposes, as listed below, but will remain inside the boundaries
of the USR obtained from Weld County, unless otherwise approved by CDPHE. Such uses may include,
but are not limited to:
• Access road grade fill
• Earthen berms, including but not limited to:
• Temporary stormwater control berms or sediment traps
• Screening berms (aesthetic enhancement, wind protection, or other)
• Stockpile for future cover and/or road repairs
• Soil additive to limit and/or restore the loss of soil through wind and water erosion.
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5.0 STORMWATER MANAGEMENT SYSTEM
This section describes the Landfill stormwater management system, in accordance with Sections 2.1.6
and 3.2.6 of the Colorado Solid Waste Regulations, 6 CCR 1007-2, Part 1. An overview of the design of
the proposed surface water control components at the Facility is presented, including a description of
each component, summary of the design parameters, and a discussion of the analyses performed.
Temporary and permanent surface water structures and erosion control measures will be constructed
over the life of the Landfill to manage surface water and contact water runoff. Design objectives for the
surface water controls include:
• Provide trafficable roads;
• Prevent contact water runoff from leaving the active areas of the Landfill;
• Divert surface water run-on from areas upgradient of the Landfill around the site;
• Prevent run-on to the active area of the Landfill; and
• Prevent discharge of contaminated stormwater from the Site.
The basis of stormwater control design for the Facility is to replicate historic drainage patterns as closely as
possible. Components of the surface water control system include:
• Run-on diversion channels;
■ A culvert crossing under the entrance road with a dissipation basin;
• Landfill perimeter and access road channels;
IN A culvert crossing under the Landfill perimeter road discharging to the detention pond;
• Terrace channels;
• Downchute channels with stilling basins; and
• A detention pond with an outlet pipe.
In addition, there will be a small stormwater catchment basin southwest of the scalehouse to capture and
release runoff from the entrance/infrastructure area. Drawing 5 shows the locations of the proposed
permanent surface water control structures. Drawings 14 and 16 provide the details for these structures.
5.1.1 Temporary Surface Water Management
Surface water will be managed through a series of temporary berms and/or channels that will divert run-on
away from the active area and direct runoff toward temporary surface water ponds or the permanent
stormwater detention pond. Surface water runoff that is not contact water will be managed via gravity
drainage or pumping to the stormwater detention pond prior to release from the Site. Details for the
temporary stormwater control structures will be provided to the CDPHE for informational purposes with the
construction packages for each cell prior to construction. Any temporary surface water controls will be
designed to handle a 25 -year, 24 -hour storm event.
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5.1.2 Final Stormwater Management System
Permanent drainage improvements for the Facility were designed in conformance with the Weld County
Storm Drainage Criteria Addendum and the Urban Storm Drainage Criteria Manuals, Volumes 1, 2, and 3.
5.1.2.1 Run-on Diversion
Run-on diversion channels were evaluated for the Facility and include five trapezoidal open channels
(Channels 0 through 4) along the north and east perimeter of the Landfill. The diversion channels will flow
to the west and south to route stormwater run-on around the Landfill. These channels are designed to
control the 100 -year frequency, 24 -hour duration storm event and include a minimum 1 foot freeboard. A
culvert crossing consisting of either four concrete box culverts or an equivalent single -span box culvert
structure will be installed northwest of the scalehouse to convey stormwater from the north diversion
channel (Channels 0, 1, and 2) beneath the entrance road and into a dissipation basin. The dissipation
basin, which will be lined with riprap, will be placed directly downstream of the culverts to spread and
dissipate the flow prior to discharge as sheet flow onto natural topography. The dissipation basin has
been designed to control the runoff from a 100 -year, 24 -hour storm event and reduce the discharge flow
velocity to no greater than 4 feet per second. An equivalent dissipation basin will also be placed at the
discharge point of the east run-on diversion channel. The run-on channels, entrance road culvert
crossing, and dissipation basin will be constructed as shown in Drawing 16. Detailed design information is
presented in Appendix B-3.
5.1.2.2 Runoff Control
Perimeter channels adjacent to the waste footprint (embedded within the perimeter berm), as well as
downchute channels, terrace channels, and an access road channel, will be used to control runoff from
intermediate- and final -covered areas of the Landfill. The locations of these features are shown in
Drawing 5 and details are provided in Drawings 14 through 16. All runoff control channels with design flow
velocity greater than five feet per second will be lined with either turf reinforcement mat (TRM) or riprap.
All surface water runoff from disturbed areas is designed to be collected and report to the stormwater
detention pond located directly west of the Landfill.
The perimeter channels will be constructed in segments as the phased development of the Landfill
advances and the perimeter berm is constructed. Perimeter channels will be grass -lined trapezoidal
channels with 3H:1V side slopes, 10 -foot bottom widths. and 3.0 -foot depths. Perimeter channel reaches
immediately adjacent to the west culvert crossing are designed to be lined with riprap due to larger peak
flow velocities and base -shear stresses.
The terrace channels will be grass -lined "V" channels formed by the construction of a 15 -foot wide terrace
situated at the approximate mid -point of the landfill sideslopes (approximately 50 feet vertically from the
top and bottom of the approximately 100 -foot -high Landfill sideslope). Across its width, the terrace will
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slope at 10H:1V inward toward the landfill, resulting in a channel depth of 1.5 feet; the opposite side of
each terrace channel will slope at 4H:1V coincident with the final Landfill sideslope. The terrace channels
will slope longitudinally at 1% across the final cover surface and converge at selected points on the final
cover, where they will discharge into one of three reinforced downchute channels to carry the flow down
the Landfill sideslopes. The access road channel will parallel the permanent access road that extends
from the northwest corner of the Landfill to the top deck, and will consist of TRM-lined "V" -notch channels
with sideslopes of 3H:1 V and a depth of 1 foot.
The downchute channels will be trapezoidal with 3H:1V sideslopes, 10- to 25 -foot bottom widths, and
1.5 -foot depths. At the base of the downchute channels, where the flow enters the perimeter channel,
hydraulic stilling (jump) basins will be installed to dissipate hydraulic energy. The downchute channels
and hydraulic stilling basins were designed to be constructed with riprap; however, articulated concrete
block (or alternative material as approved by the Engineer) may be substituted at the time of construction
to reduce future maintenance requirements. The perimeter channels will convey the stormwater around
the perimeter of the Landfill to the stormwater detention pond.
Supporting calculations, which demonstrate that the access road channels, terrace channels, perimeter
channels, and downchutes have been designed to control runoff from the Landfill from a 100 -year.
24 -hour storm event. are presented in Appendix B-3.
Stormwater will ultimately report to the stormwater detention pond via three 42 -inch diameter culverts, or
equivalent box culvert structure, to be installed beneath the perimeter road on the west side of the
Landfill, as detailed in Drawing 15. There will be approximately three feet of cover over the culverts to
provide load -bearing capacity for the vehicular loads on the perimeter road.
Perimeter channels and run-on diversion controls will be constructed as described in the Operations Plan
(Appendix C). Stormwater will be managed in accordance with the Colorado Discharge Permit System
(CDPS) Stormwater Management Plan (SWMP) General Permit for "Stormwater Discharges Associated
With Non -Extractive Industrial Activities" (COR900000) (application for permit coverage to be submitted
prior to commencing Landfill operations).
5.1.3 Erosion Potential Evaluation
An evaluation of the effects of erosion due to rainfall on the proposed final cover was performed. The
analysis involved using the Revised Universal Soil Loss Equation, Version 2 (RUSLE2) erosion modeling
software (USDA 2010) to estimate the amount of soil loss caused by sheet and rill erosion of the final
cover immediately after closure construction and after a five-year period of vegetative growth on the final
cover. RUSLE2 calculations are presented in Appendix B-7 of this report. Annual soil loss due to erosion
in the first year of closure and long-term (i.e., after vegetative growth on the final cover) was predicted to
be 2.8 tons/acre/year and 1.8 tons/acre/year, respectively, and less than the regulatory soil loss tolerance
of 5 tons/acre/year for Landfill final cover slopes in surrounding states.
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6.0 CONSTRUCTION DOCUMENTATION
This section introduces the requirements for construction documentation of the various engineered
components of the Landfill, per Section 3.2.7 and 3.3.3 of the Colorado Solid Waste Regulations, 6 CCR
1007-2, Part 1. A comprehensive Construction Quality Assurance (CQA) Plan has been prepared for the
Landfill, and is included in Appendix G. The CQA Plan contains details on sampling, testing, observation,
documentation. reporting and certification of applicable portions of the subgrade, structural fill, liner and
leachate collection and recovery system components, as well as the final cover and seeding activities.
Pawnee will prepare and submit a CQA report to CDPHE and Weld County for each phase of liner and
final cover construction at the Landfill, documenting that the designed construction was completed in
accordance with this EDOP, including the CQA Plan. CQA reports will be signed by a Colorado registered
professional engineer. For each new constructed cell or phase, approval of the CQA report will be
obtained from CDPHE prior to acceptance of waste in that area.
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7.0 OPERATIONS
The Operations Plan presented in Appendix C provides operational information specific to the proposed
Landfill to satisfy Section 2 and Section 3.3 of the Regulations. The Waste Acceptance Plan, contained in
Appendix D, includes details regarding waste type restrictions, waste evaluation and profiling procedures,
screening and random inspections, management of unacceptable wastes, employee training, and
associated documentation and reporting requirements.
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8.0 REFERENCES
Colorado Oil and Gas Conservation Commission. 2014. 900 -Series Rules.
Golder Associates Inc. 2014. Pawnee Waste Project: Borehole Data.
GROUND Engineering. 2012. Subsurface Exploration Program & Geotechnical Recommendations,
Pawnee Project Improvements. Grover, CO.
Koerner, G.R. and D. Narejo. 2005. "Direct Shear Database of Geosynthetic-to-Geosynthetic and
Geosynthetic-to-Soil Interfaces," GRI Report #30, Geosynthetic Research Institute, Folsom, PA.
Koerner. R.M. and T -Y. Soong. 2005. "Analysis and Design of Veneer Cover Soils," Geosynthetics
International, Vol. 12, No. 1, pp. 28-49.
Higley, D.K., R.R. Charpentier, T.A. Cook, T.R. Klett, R.M. Pollastro, and J.W. Schmoker. 2002.
Petroleum Systems and Assessment of Undiscovered Oil and Gas in the Denver Basin Province,
Colorado, Kansas, Nebraska, South Dakota, and Wyoming-USGS Province 29: US Geological
Survey Digital Data Series DDS -69-P. Chapter 2, 1 p.
Hynes -Griffin, M.E. and A.G. Franklin. 1984. "Rationalizing the Seismic Coefficient Method,"
Miscellaneous Paper GL -84-13, U.S. Army Engineer Waterways Experiment Station, Vicksburg, MS.
Robson, S.G. and E.R. Banta. 1995. Groundwater Atlas of the United States. Arizona, Colorado, New Mexico,
Utah, HA730-C. Available online: http://pubs.usgs.gov/halha730/ch c/ Accessed July 23, 2015.
RocScience. 2012. SLIDE - Version 6.017. Software for 2D Limiting Equilibrium Slope Stability Analysis.
Available online: http://www.rocscience.com Accessed July 23, 2015.
Spencer, E. 1967. A Method of Analysis of the Stability of Embankments Assuming Parallel Inter -Slice
Forces. Geotechnique, Vol. XVII, No. 1, pp. 11-26.
United States Fish and Wildlife Service (USFWS). 2014. National Wetlands Inventory: Wetlands Mapper.
United States Geological Survey (USGS). 1985. National Water Summary 1984 - Hydrologic Events.
Selected Water -Quality Trends, and Ground -water Resources: USGS Water -Supply Paper 2275, 467 p.
United States Geological Survey (USGS). 2013. Grover South Quadrangle, Colorado -Weld Co.
7.5 -Minute Series.
USGS. 2014a. Earthquake Hazards Program: US Seismic Design Maps.
USGS. 2014b. The National Geologic Map Database: MapView.
USGS and Colorado Geological Survey. 2014. Earthquake Hazards Program: Interactive Fault Map.
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APPENDIX C
OPERATIONS PLAN
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APPENDIX C
OPERATIONS 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 — October 20, 2015
Revision 2 - February 19, 2016
Revision 3 - April 22, 2016
Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation
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PAWNEE WASTE E&P LANDFILL
OPERATIONS PLAN
RECORD OF REVISIONS
Revision No.
Date
Description of Revision
Section(s)
Prepared By
0
07/23/2015
Initial Issuance
All
MAY
1
10/20/2015
Revised leachate management/recirculation
6.1
MAY
2
02/19/2016
Revised discussion of initial waste
placement
Revised leachate management
procedures
Revised stormwater inspection
requirements
Revised daily cover procedures
5.1
6.1, 8.1, 8.3
6.2.3, 11.2.2,
11.3.4
7.1
JAR
3
04/22/2016
Revised waste placement offsets
4.0, 5.1, 5.3,
JAR
Revised temporary waste slopes
6.1.2
5.3
Revised contact water management
6.1.2
options
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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 4
2.1 Facility Location [Regulation 3.3.1(A)] 4
2.2 Regulatory Status [Regulation 3.3.2(C)] 4
2.3 Landfill Service Area [Regulation 3.3.1(D)] 4
2.4 Facility Access and Traffic Flow [Regulation 3.2.3(3)(g)] 4
2.5 Operating Hours [Regulation 3.3.2(B)] 5
2.6 Signage 5
2.7 Site Security and Access Control [Regulations 2.1.7, 2.1.8 and 3.3.2(H)] 6
2.8 Water/Sanitary Requirements [Regulations 3.3.2(M), 3.3.6] 6
3.0 INFRASTRUCTURE, PERSONNEL, AND EQUIPMENT 7
3.1 Landfill Operator [Regulation 3.3.2(A)] 7
3.2 Facility Infrastructure 7
3.3 Personnel [Regulations 3.3.2(A) and 3.3.2(D)] 8
3.3.1 Site Manager 8
3.3.2 Gate Attendant 8
3.3.3 Lead Operator 9
3.3.4 Additional Landfill Personnel 9
3.4 Operator Training [Regulations 2.1.2(B)(3) and 2.4.2] 9
3.5 Equipment [Regulation 3.3.2(E)] 9
4.0 LANDFILL DEVELOPMENT AND SEQUENCING 11
5.0 WASTE HANDLING AND PLACEMENT (REGULATION 2.1.10) 12
5.1 Initial Waste Placement 12
5.2 Disposal Area Grading and Operational Stormwater Controls 13
5.3 Fill Progression 14
5.4 Solidification Operation 14
6.0 ENVIRONMENTAL MANAGEMENT 15
6.1 Leachate Management [Regulation 3.2.5(D)] 15
6.1.1 Leachate Minimization 15
6.1.2 Contact Water Management 15
6.1.3 Leachate Collection and Removal 16
6.1.4 Leachate Management and Storage 16
6.1.5 Leachate Recirculation (Application) (Regulation 3.3.7) 18
6.1.6 Leachate System Monitoring/Inspection 19
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6.2 Surface Water Management (Regulations 2.1.4, 2.1.6, 2.1.10, 2.1.17, 3.2.6) 19
6.2.1 Stormwater Controls 19
6.2.2 Stormwater Permit 21
6.2.3 Inspections and Maintenance 22
6.3 Groundwater Monitoring (Regulation 2.2) 22
6.4 Air Monitoring (Regulation 2.1.1) 23
6.5 Explosive Gas Monitoring (Regulation 2.3) 23
7.0 COVER MATERIAL [REGULATIONS 2.1.10, 3.3.2(G), 3.3.4, AND 3.3.5] 24
7.1 Daily Cover 24
7.2 Intermediate Cover 24
7.3 Final Cover 25
7.4 Stockpiling; Borrow Activities, and Topsoil Handling 25
8.0 NUISANCE CONTROL [REGULATIONS 2.1.3 AND 3.3.2(1)] 26
8.1 Odor, Noise, and Vector Control 26
8.1.1 Odors 26
8.1.2 Noise 26
8.1.3 Vectors 26
8.2 Bird and Wildlife Control 27
8.3 Dust Control 27
8.4 Fire Prevention [Regulations 2.1.9 and 3.3.2(J)] 27
8.5 Litter Control [Regulations 2.1.7, 2.1.11, and 3.3.2(K)] 27
9.0 SAFETY STANDARDS AND TRAINING 29
10.0 EMERGENCY RESPONSE PLAN 31
10.1 General Emergency Response 31
10.2 Hot Load, Fire, or Explosion [Regulation 3.3.2(J)] 31
10.3 Leaks/Spills/Releases 32
10.4 Utility or Pipeline Contact/Breach 32
11.0 CONTINGENCY PLAN 33
11.1 Substance Release (Regulation 2.1.18) 33
11.2 Contamination of Surface Water or Groundwater [Regulation 3.3.2(L)] 33
11.2.1 Groundwater Impacts 33
11.2.2 Surface Water Impacts 33
11.3 Nuisance Conditions Beyond Site Boundary [Regulation 3.3.2(L)] 34
11.3.1 Mud & Vehicle Tracking 34
11.3.2 Dust 34
11.3.3 Debris 34
11.3.4 Run-on or Runoff Control Failure 34
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12.0 FACILITY INSPECTIONS 35
13.0 RECORDKEEPING (REGULATIONS 2.4 AND 3.4) 36
List of 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
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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 E&P 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). The 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.
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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.
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.
1.3 Abbreviations and Acronyms
CD Certificate of Designation
CDPHE Colorado Department of Public Health & Environment
DRO diesel range organics (as analyzed by TPH-DRO by USEPA Method 8015M)
EAP Emergency Action Plan
EDOP Engineering Design and Operations Plan
E&P exploration and production
GRO gasoline range organics (as analyzed by TPH-GRO by USEPA Method 8015M)
HMWMD Hazardous Materials and Waste Management Division
LCRS leachate collection and removal system
µR/hr microRoentgens per hour
MOLO Manager of Landfill Operations
MSW municipal solid waste
NORM naturally -occurring radioactive material
PCBs polychlorinated biphenyls
pCi/g picoCuries per gram
PPE personal protective equipment
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ppm parts per million
RCRA Resource Conservation and Recovery Act
Regulations CDPHE "Regulations Pertaining to Solid Waste Sites and Facilities" (6 CCR 1007-2, Part 1)
SVOCs semi -volatile organic compounds (as analyzed by USEPA Method 8270C)
SWANA Solid Waste Association of North America
TENORM technologically -enhanced naturally -occurring radioactive material
USEPA United States Environmental Protection Agency
USR Use by Special Review
VOCs volatile organic compounds (as analyzed by USEPA Method 82608)
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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 E&P Landfill
57996 WCR 95
Grover, Colorado 80729
Until the Facility is operational, all correspondence should be delivered to the following mailing address:
Pawnee Waste LLC
3003 E. Harmony, Suite 300
Fort Collins, CO 80528
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 exploration and production
wastes as defined by CDPHE 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 serve generators in or serving the oil and gas exploration & production 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 and E&P-related waste.
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
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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 CR 118 and CR 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 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:
IN 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.
Since 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 utilize 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
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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.
Site Security and Access Control [Regulations 2.1.7, 2.1.8 and 3.3.2(H)]
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 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 dearly 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.
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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.
• 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.
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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;
IN 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.
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 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.
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3.3.3 Lead Operator
The lead operator will be direcfiy 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 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.
Equipment [Regulation 3.3.2(E)]
The number; use, and type of equipment employed at the Landfill will vary based upon the type and
quantity of waste received. Landfill management will determine equipment requirements and schedule
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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.
Equipment
Function
Scale & Software
Weigh, document, and track waste received
Bulldozers)
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 Tractor (or
equivalent)
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 Truck or Water
Wagon
Portable Liquid Holding
Frac Tank(s)
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 monitor and handheld gamma meter to survey incoming waste loads for
radioactivity
Miscellaneous
Power washer, air compressor, portable generator, camera surveillance system,
water pump(s)
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.
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Cu 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 1A, Phase 1B, 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 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.
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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 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 dozer 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
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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:1 V 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 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
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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 aH:1V 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.
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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 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 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 6.1.5 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 berrns 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 rain water 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)
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below the crest elevation of the perimeter berm (see detail 5/11), leaving a minimum of approximately 3.1
feet of Jeachate 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 in less than 365 days. This will be accomplished
through a combination of the sloped Landfill base grades, a 1 -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 using direct pipe conveyance or via a
dedicated tanker truck or "water wagon" either directly to the active Landfill area for dust control and/or
moisture conditioning of waste (pending specific approval from CDPHE Air Pollution Control Division
[APCD], see Section 6.1.5), or to the leachate storage area or off -site for disposal. Leachate intended for
on -site application will be tested in accordance with procedures identified in Section 6.1.5 of this
Operations Plan prior to application. In the event that Pawnee uses a third -party facility for disposal of
leachate, strict adherence to the third party's waste receipt requirements will be followed.
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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 off -site disposal. 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), will be disposed of at an
approved off -site disposal facility. Pawnee will obtain an agreement with the owner/operator of a
permitted off -site disposal facility to dispose of the maximum anticipated volume of excess leachate
generated by the Landfill. 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. All leachate removed from the Landfill
will be transported and disposed of in conformance with all applicable rules and regulations. 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 applied for dust control, including date, location applied, duration or application
rate, and weather conditions; and
• Volume transported from the site for off -site disposal, including date and receiving facility.
A dedicated "loadout area" will be constructed alongside the storage area to accommodate a tanker
vehicle for leachate application or off -site 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).
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6.1.5 Leachate Recirculation (Application) (Regulation 3.3.7)
As stated previously, 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 sumps
and/or storage tank(s) and spraying onto the waste via a tanker vehicle equipped with spray nozzles.
Leachate applied to lined areas of the Landfill will require prior laboratory analysis, whereby each sump
will be individually sampled and analyzed, and/or a composite sample will be taken of leachate stored in
the tanks. Should sufficient historical data be available which indicates that a reduced sampling frequency
may be warranted, Pawnee will make a request to the CDPHE for its approval prior to modifying this
procedure.
Leachate may be applied to the E&P wastes within lined areas under the following conditions:
M Prior laboratory analysis of leachate samples from each sump and/or storage tank to
confirm that Ra-226/Ra-228 levels do not exceed 24 pCi/L.
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
• 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
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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.
6.1.6 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).
6.2 Surface Water Management (Regulations 2.1.4, 2.1.6, 2.1.10, 2.1.17, 3.2.6)
6.2.1 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 ensure that stormwater 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;
IN Divert surface water run-on from areas upgradient of the Landfill around the site;
• Prevent run-on to the active area of the Landfill;
• Prevent runoff that has contacted exposed waste from leaving the active areas of the Landfill;
• Prevent discharge of impacted water from the site; and
• Minimize erosion and sedimentation of disturbed areas.
6.2.1.1 Permanent Stormwater Control Structures
Permanent stormwater control structures installed at the Landfill will include:
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• Perimeter run-on diversion channels;
• Perimeter 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 stormwater 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 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 Stormwater 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
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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 SVVMP 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 of best management practices, employee training, inspections,
and recordkeeping. As indicated in Section 3.4 above, 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.
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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. Inspections 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.
Surface Water Management Controls Inspection Checklist
Item/Reference
Evaluation Criteria
Corrective Action
Inspections Performed
Following Significant
Storm Events
Inspections performed on all
structures within 72 hours of the end
of a rain event > 1.0 inch.
Re -address in training sessions,
including 3rd party refresher
course if needed.
Stormwater Detention
Pond
Maintain minimum freeboard. Track
sediment accumulation. Check pond
embankment and outlet structures
for signs of damage.
Clean out pond if sediment
accumulation is more than
18 inches deep, and/or is
excessively obstructing flow from
the outlet standpipe. Evaluate and
correct BMPs as needed.
Ditches/Berms
Ditches are relatively free of lifter or
debris and in good functioning order.
No evidence of significant erosion
on berms or ditches.
Repair ditches and berms as
needed. Provide additional
stabilization or energy dissipation
where appropriate.
Silt Fence/Straw
Bales/Wattles
No breaches in silt fence, straw
bales, or straw wattles; no sediment
observed beyond these erosion
controls.
Repair breaches in erosion
controls. Remove sediment
deposits if ? 6 inches deep.
Rock Check
Dams/Baffles and
Sediment Traps
Maintain (restore and/or dean out),
if sediment is observed to be
hindering performance and if
sediment is found downstream.
Remove sediment if accumulated
? 6 inches within control structure
or observed downstream.
Vegetation
Vegetation and erosion control
blankets in place (including
stockpiles where applicable).
Re -vegetate as needed.
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.
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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.
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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 for additional description of stockpiling activities. All on -site soils
are suitable for use as daily or intermediate cover.
7.1 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 6.1.5); dust control is not expected to be improved by the application of daily cover soil.
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.
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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 Plan (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 will 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 shall 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.
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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 texture 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 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 6.1.5 of this Operations Plan), hall 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.
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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.
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).
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 on 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 of this 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, 2.1.11, 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 not create any windblown litter; therefore, no lifter 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
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well as areas and fence -lines off site if necessary (with permission from adjacent landowners). Lifter
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.
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9.0 SAFETY STANDARDS AND TRAINING
Fencing the area and maintaining a single entrance with a locking gate, as described above, will control
unauthorized 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 regarding 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 emergency 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 operators at the Facility, including those for handling and inspecting various types
of E&P wastes. All Pawnee employees 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 upon request.
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
in Inspection procedures
• Safety procedures
■ Stormwater Management Plan
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• Leachate management
IN Permit conditions
• Operations Plan
• Radioactive material
• Emergency/contingency response and EAP
• Erosion controls
■ Site maintenance expectations
• Other, as may be needed
All new employees and contractors working in active
handling, stormwater management, or waste review and
on these topics for the first year, and refresher training
frequent training will be provided as needed if warranted
operational errors, or compliance issues.
waste areas, with responsibility for leachate
acceptance, will also receive quarterly training
a minimum of semi-annually thereafter. More
based on observed performance deficiencies,
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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:
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 -site 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
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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.
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 20091) 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).
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Appendix C
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1407882B Rev._?_
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.
11.2.1 Groundwater Impacts
The Facility will be operating under a groundwater monitoring program approved by 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 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.
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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 conditions warrant, inspections will be made twice daily. Excessive mud will be removed
from the roads, and the material 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 personnel will pick up litter and debris regularly and place in an appropriate storage container for
disposal off site. Municipal waste or litter may not be disposed of on site.
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.
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1407882B Rev._
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:
Inspection Item
Frequency
Landfill equipment
Daily
Weigh scale
Quarterly
Mud and vehicle tracking
Up to 2x daily when weather
conditions warrant
Litter/debris
Weekly
Waste disposal
Continuous observation
Random load inspections
1% or 1 per week
Leachate collection system sump risers, cleanout risers, fittings,
level transducers, pumps
Weekly
Leachate tanks/storage area
Weekly and within 3 days after
significant storm events
Stormwater controls (temporary and permanent)
Quarterly and after significant
storm events
Groundwater monitoring wells (casing condition, cap, locks, and
change in casing elevation)
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.
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1407882B Rev._
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 restriction demonstrations required by Section 3.1 of the Regulations
IN Inspection records
IN 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 the approved EDOP, Weld County USR permit, and any associated or
subsequent correspondence, modifications, 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
IN 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., COA reports, specifications, and record drawings)
• Variations from approved operations procedures, if any
All information 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
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1407882B Rev. _ -( Deleted: February
maintained at the 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.
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APPENDIX D
WASTE ACCEPTANCE PLAN
DAL
i r 1 TM 1 1 WO- 1.1f I 1 N 1 4 1 I r 1 1 - A
1
A world of
capabilities
delivered locally
APPENDIX D
WASTE ACCEPTANCE 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 - October 20, 2015
Revision 2 - February 19, 2016
Revision 3 — April 22, 2016
1407882B
Golder
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Appendix D
1407882B Rev_,
PAWNEE WASTE E&P LANDFILL
WASTE ACCEPTANCE PLAN
RECORD OF REVISIONS
Revision No.
Date
Description of Revision
Section(s)
Prepared By
0
07/23/2015
Initial Issuance
All
MAY
1
10/20/15
Clarification of acceptable wastes, radiation
screening/response: random waste
sampling
1.0; 2.1;
4.5.1,6,
4.5.1.7,
4.5.2.2,
Appx D-1,
Appx D-2
JGW/MAY
2
2/19/16
Revision to hazardous waste
characteristics
Clarification of non-exempt E&P waste
acceptance criteria
Clarification of asbestos and PCB waste
acceptance criteria
Table D-1
2.2
3.4 and 3.5
JAR
3
4/14/2016
Addition of lead -210 and polonium -210
2.1.2. 3.7,
JAR
testing and acceptance requirements
4.5.2.2, 4.7
Additional waste acceptance
4.6.2
requirements
4.7
Data to be collected from accepted
wastes
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Appendix D
II
1407882B Rev. 3
Table of Contents
1.0 INTRODUCTION 1
2.0 WASTE TYPES TO BE ACCEPTED 2
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 5
2.3 Mixtures of Exempt and Non-exempt E&P Waste 6
2.4 Wastes Requiring Solidification 6
2.5 Wastes Requiring Special Handling or Disposal Methods 7
2.5.1 Dusty Wastes 7
2.5.2 Drummed Wastes 7
2.5.3 NORM/TENORM Wastes 7
2.5.4 Odorous Wastes 7
3.0 PROHIBITED WASTES 8
3.1 Liquid Wastes 8
3.2 Hazardous Waste 8
3.3 Municipal Solid Waste 8
3.4 Asbestos -containing Material 8
3.5 Polychlorinated Biphenyl (PCB) 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) 11
4.1 Pre-screening and Generator Education 11
4.2 Waste Profile Sheets 12
4.2.1 Waste Analyses and Information Required 13
4.2.2 Sampling Procedures 13
4.2.3 Asbestos and PCB Testing 14
4.3 Waste Stream Review and Approval 14
4.4 Waste Stream Re -testing and Certification 14
4.5 Screening at the Landfill 15
4.5.1 Load Screening at Gate 15
4.5.1.1 Approved Waste Profile Sheet 15
4.5.1.2 Visual Screening 15
4.5.1.3 Gate Tests 16
4.5.1.4 Container Inspection 16
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4.5.1.5 Weights 16
4.5.1.6 Radiation Detectors at Scale 17
4.5.1.7 Handheld Gamma Survey Meter 17
4.5.2 Random Load Inspections and Testing 18
4.5.2.1 Training and Equipment 18
4.5.2.2 Random Load Selection, Inspection, and Sampling Procedures 18
4.6 Waste Rejection 21
4.6.1 Management and Disposal of Unauthorized Wastes 22
4.6.2 Cause for Suspension from Use of Facility 22
4.7 Waste Acceptance Procedure Adjustments 23
5.0 CONTINGENCY PLAN FOR HANDLING UNAUTHORIZED WASTES
REGULATION 2.1.2(C)(4)1 24
5.1 Suspected Presence of Unauthorized Waste 24
5.2 Confirmed Discovery of Unauthorized Waste 24
5.3 Detection of Prohibited Wastes 25
5.4 Management and Disposal of Unacceptable Wastes 25
5.5 Documentation of Inspections and Incidents 25
List of Tables
Table D-1
Table D-2
Test Parameters And Allowable Levels For Non-exempt E&P Waste
Background Radioisotope Results Summary
List of Appendices
Appendix D-1 Example Forms
Waste Profile Sheet - Exempt Exploration and Production Waste
Waste Profile Sheet - Non-exempt E&P Waste
Load Inspection and Sampling Log and Waste Screening Checklist
Incident Log
Appendix D-2 Radiation Detection Response Procedures and Radiation Monitor Alarm Record Form
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1.0 INTRODUCTION
This Waste Acceptance and Characterization Plan (WAR, 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 Regulations. 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 WAR):
• Identification of potential waste streams requiring specific waste handling and/or disposal
methods (see Section 2.4 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. Thus, Pawnee
proposes to perform periodic reviews of its waste receipt processes and the corresponding RESRAD
model inputs as further defined in Section 4.7 - Waste Acceptance Procedure Adjustments.
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2.0 WASTE TYPES TO BE ACCEPTED
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 USEPA's 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.
For the purposes of exempt E&P wastes that will be accepted at the Facility, the list of exempt E&P wastes
contained in the documents above will exclude those materials that are likely to be generated in bulk liquid
form, as the Facility will not accept such wastes (e.g.. liquids delivered in tanker trucks). 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:
Exempt E&P Wastes
Exempt Exploration Wastes
Exempt Production Wastes
Either Exploration or Production
Drill cuttings and muds
Accumulated materials such as
hydrocarbons, solids, sand, and
emulsion from production
separators, fluid treating vessels,
and production impoundments
Spent filters, filter media, and
backwash solids (assuming the
filter itself is not hazardous and
the residue in it is from an
exempt waste stream)
Rigwash solids
Solids from production sites,
including filter cake from oil
reclamation and water recycling
operations.
Constituents removed from
flowback and produced water
before it is injected or otherwise
disposed of (e.g., filters, tank
bottom sediments)
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Exempt Exploration Wastes
Exempt Production Wastes
Either Exploration or Production
Sediment and other tank bottoms
from exploration activities,
including wastes generated by
closed loop recycling
•
Pit sludges and solids generated
during exploration and drilling
activities
Proppant/sand wastes (excluding
unused product) and flowback
Gas plant dehydration wastes and
sweetening wastes; filter media
and backwash solids
Pipe scale, pigging wastes (from
gathering lines), hydrocarbon
solids, hydrates, and other
deposits removed from piping and
production equipment prior to
transportation
Debris, crude oil soaked or stained
4
Mixtures of exempt exploration and
exempt production wastes
Hydrogen sulfide abatement
wastes from geothermal energy
production
Crude oil contaminated soils
generated during exploration,
drilling, and production activities
(prior to transportation from a
reclamation facility)
* The term "solids'. as 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 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 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 (µR/hr) when
received at the Landfill (see Section 3.7, below).
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Exploration wastes typically don't contain large concentrations of NORM or TENORM: thus quantifying
radionuclides will not be required.
Please see Waste Profile Sheet - Exempt Exploration and Production Waste 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 µR/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 l).
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 - Exempt Exploration and Production Waste 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.
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2.2 Non-exempt E&P 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.
However, other waste streams generated by the oil and gas exploration and production industry are still
considered E&P wastes and 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 40 CFR Part 261, Subpart D) (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; or
C. Th-232: 10 pCi/g above background.
5. Does not emanate more than 50 µR/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, or
production of crude oil or natural gas.
For purposes of this WAP, personal protective equipment (PPE) generated in direct association with the
acceptance and handling of NORM/TENORM waste will be considered an exempt E&P waste and may be
disposed of in the Landfill without screening or testing.
All wastes identified as non-exempt E&P wastes provided in the USEPA Exemption Publication will be
assumed to be non -acceptable unless they meet each and every criterion identified above. If uncertainty
exists regarding the acceptability of a particular waste, CDPHE will 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 40 CFR Part 261, Subpart D, or if the waste exhibits hazardous waste characteristics.
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Please see Waste Profile Sheet - Non-exempt E&P Waste 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 Mixtures of Exempt and Non-exempt E&P Waste
Only E&P wastes. exempt and non-exempt, will be accepted at the Facility; thus. mixtures of E&P and non-
E&P waste will not be accepted. Mixtures of exempt and non-exempt E&P wastes may be acceptable, but
create additional characterization considerations. Should any of the non-exempt E&P wastes in a mixture
of exempt and non-exempt E&P wastes be categorized as a RCRA-listed hazardous waste, it will be
considered a prohibited waste. If the non-exempt E&P waste is not a listed waste but is hazardous based
on its characteristics; the resulting mixture of exempt and non-exempt waste may: 1) become a non-exempt
hazardous waste and require management under RCRA Subtitle C regulations; or 2) be received by
Pawnee under certain circumstances, but only after a chemical analysis to determine whether the mixture
is acceptable as per the specific criteria (based on the USEPA Exemption Publication) summarized below.
• Mixing a non -hazardous non-exempt E&P waste with an exempt waste results in a mixture
that is also exempt; however, the non-exempt fraction of the waste must be tested to
confirm it is non -hazardous prior to making this determination.
• If, after mixing a non-exempt characteristic hazardous waste with an exempt waste, the
resulting mixture exhibits any of the same hazardous characteristics as the hazardous
waste (ignitability. corrosivity, reactivity, or toxicity), or if it exhibits a characteristic that
would not have been exhibited by the exempt waste alone, the mixture becomes a
non-exempt hazardous waste and cannot be disposed of at the Landfill, regardless of the
relative volumes or concentrations of the wastes.
• If, after mixing a non-exempt characteristic hazardous waste with an exempt waste, the
resulting mixture does not exhibit any of the same hazardous characteristics as the
hazardous waste (even if the mixture exhibits some other characteristic of a hazardous
waste), the mixture is exempt.
■ If a listed hazardous waste is mixed with an exempt E&P waste, regardless of the
proportions, the mixture is considered a non-exempt hazardous waste and cannot be
disposed of at the Landfill.
2.4 Wastes Requiring Solidification
Exploration and/or production 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. 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.
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2.5 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
• Drummed wastes
■ NORM/TENORM wastes
• Odorous wastes
2.5.1 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.
2.5.2 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.
2.5.3 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.
2.5.4 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.
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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 (MSW).
3.4 Asbestos -containing Material
The Landfill will not accept solid wastes containing asbestos -containing material (ACM), which is defined as
any material containing greater than 1% 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 (PCB) 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.
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): such wastes will be deemed unacceptable and specifically
prohibited.
3.7 NORMITENORM Waste Exceeding Established Thresholds
The Landfill will not accept NORM and TENORM waste with concentrations that exceed the limits
established in this WAR 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
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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/q.
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-2.
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 Waste Acceptance Plan or via correspondence
with CDPHE and Weld County expressly granting approval:
• Household garbage and putrescible waste
IN Industrial waste not classified as E&P waste
• Animal carcasses
IN Waste grain, seed, and elevator screenings
IN 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
IN Petroleum storage tanks
IN Petroleum -contaminated soil not categorized as E&P waste
IN Lead -acid batteries
• Used motor oil
• Antifreeze
• 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 pumpings
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IN Infectious wastes
■ Regulated radioactive waste
• Tires
IN Paint products
IN Inert waste
■ Pyrophoric wastes
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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
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 notified of the Landfill operating requirements and restrictions. It is designed to educate
customers of their obligations 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 operating requirements and restrictions:
• Waste acceptance criteria, including the requirement for the waste to be solid,
non -hazardous exploration and/or production waste;
• 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.
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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, and do not have free liquids, 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 Sheets
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 "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. Examples of the Waste Profile Sheets to be used for the Facility are 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(s) will be provided to CDPHE and Weld County. The Waste Profile Sheets
generally will require 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:
exempt exploration waste, exempt production waste, or non-exempt E&P waste; and
• Generator certifications that all samples tested are representative of the identified waste
stream and that the waste in 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 corresponding Waste
Profile Sheet will require that appropriate testing results and certifications be attached. Specifically, the
following tests are REQUIRED:
• Paint Filter Test results (all wastes);
IN Radionuclide testing (exempt production waste, non-exempt E&P waste);
■ Hazardous waste characteristic testing (non-exempt E&P waste); and
• TCLP test results (non-exempt E&P waste).
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Example waste profile sheets for each acceptable waste category are provided in Appendix D-1. 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. The types of information and various tests that may be included with the
waste profile sheet are:
• Material safety data sheets (MSDSs)
IN 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)
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 from a chemical composition analysis must be in units of: parts per million (ppm); milligrams per
kilogram (mg/kg) (which corresponds to ppm); parts per billion (ppb); picocuries per gram (pCi/g) or
micrograms/kilogram (pg/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
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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(s) included in Appendix D-1 will be modified, or a separate waste profile sheet for this waste type will
be developed.
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.
4.4 Waste Stream Re -testing 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.
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Waste materials that are consistent in physical and chemical makeup may not require re -testing. 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 re -testing 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 Screening at the Landfill
4.5.1 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 Sheet
Each delivery to the landfill shall be associated with a complete approved Waste Profile Sheet 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 Sheet 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
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remote camera 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
IN Bulk liquids or liquid containers
• Unusually strong or irritating odors not associated with typical acceptable waste types
IN 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 free liquids are present or if 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.
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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 a "portal 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 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
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(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.
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)
IN 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 Ziploe 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
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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 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.
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Random Load Inspection and Sampling Overview
Waste Category*
Frequency of
Random Load
Inspection and On-
Site Sampling
Parameters to be Evaluated/Tested during
Random Load Inspection and Sampling
1 per 500 loads or
• Visual examination
Exempt Exploration
Waste
1 per month,
whichever is more
frequent
■ Gamma radiation survey with handheld meter
• Radionuclides (Ra-226 and Ra-228, U -Nat,
Th-Nat)
• Visual examination
Exempt Production
1 per 500 loads or
1 per month,
■ Gamma radiation survey with handheld meter
Waste
whichever is more
frequent
• Radionuclides (Ra-226 and Ra-228, U -Nat,
Th-Nat. and for gas plant gathering lines
wastes/residues Pb-210 and Po -210)
.
• Visual examination
• Gamma radiation survey with handheld meter
1 per 100 loads or
• Radionuclides (Ra-226 and Ra-228, U -Nat,
Th-Nat)
Non-RCRA-Exempt
1 per month,
• Toxicity
Exploration and/or
whichever is more
• RCRA metals (TCLP)
Production Waste
frequent
• Benzene (TCLP)
• Ignitability (flash point; multiple accepted
test methods)
• Corrosivity (pH) and
• Reactivity (total cyanide and sulfide;
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-1 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 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
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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)
IN 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
IN 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 below) will be implemented.
4.6 Waste Rejection
Loads may be rejected for any of the following reasons:
1. Deliveries without an approved Waste Profile Sheet accompanying the load: All such
loads will be rejected.
2. Discrepancy with approved Waste Profile Sheet: 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 Sheet 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
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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.
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 Landfill's 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 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 below (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.
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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.
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), and for wastes from gathering lines from natural gas activities
Pb-210 and Po -210) ;
• 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.
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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
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
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
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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 CDPHE.
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 above (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.
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APPENDIX D-1
EXAMPLE FORMS
Waste Profile Sheet - Exempt Exploration & Production (E&P) Wastes
Pawnee Waste E&P Landfill
(Defined by 40 CFR 261.4(b)(5))
Office
Profile ID 4:
Use Only:
Approved fl Rejected 1
Location: WCR 118
Grover, Colorado 80729
Date:
Mailing Address: 3003 E. Harmony; Suite 300
Fort Collins, CO 80528
Completed
By:
Phone:
Fax:
Email:
A. GENERATOR INFORMATION
Generator Name:
Contact Name:
Generator Address:
Phone: I
Fax:
Email:
City: I
State: I
Zip:
Waste Source Location (Address/Well Name/Coordinates/Rig #):
County:
Generator Mailing Address (if different):
Township: I
Range:
Section (1/4):
City: I
State: I
Zip:
City: I
State:
Zip:
B. WASTE CHARACTERIZATION (See USEPA's "Exemption of Oil and Gas Exploration 8 Production Wastes from Federal Hazardous Waste Regulations")
B.1a
Exploration Waste: YES ❑ NO ❑
B.1b
Production Waste: YES ❑ NO
•
•
•
•
•
•
•
Drill Cuttings O Pit Sediments
Drilling Mud O Produced Sand
Rigwash Solids O Spent Filters
Filter Cake O Hydrocarbon Contaminated Soil
Tank Bottoms/Sediment O Closed Loop Wastes
Backwash Solids O Other/Special Handling
• Gathering Line Waste
■ Tank Bottoms
O Spent Filters
El Trtmnt Vessel Waste
O Separator Waste
• Gas Plant Sweetening
O
O
•
O
•
Wastes
Impoundment
Equipment Hydrocarbon
Hydrocarbon
Equipment Pipe
Gas Plant Dehydration
Waste
Contaminated
•
Waste
Soils
Scale
Waste
Other/Special Handling
•
•
•
•
Oil Reclamation Solids
Pre -injection Solids
Workover Wastes
Blowdown Wastes
O Other/Special Handling (Describe):
B.2a
Waste Analytical Requirements - Exploration Wastes
B.2b
Waste Analytical Requirements - Production Wastes
Exempt Exploration Waste:
• Analytical testing for combined Radium -226/228 is NOT
_Exempt Production Waste:
• Waste MUST be analyzed for NORM/TENORM by a state -certified lab.
required for drill cuttings and muds generated by
exploration activities.
• For other exploration wastes that are suspected or known
to contain a concentration of radioisotopes greater than 10
pCi/gm (Ra-226 + Ra-228), analytical work is required.
• Max. concentration of TENORM shall be identified below.
• Analysis must demonstrate that the combined Radium -226/228 concentration
is 5 50 pCi/gram.
• Gathering line wastes from natural gas must be tested for Pb-210 and Po -210
to demonstrate the individual concentrations are each < 10 pCi/gram
• Analytical results shall be documented in pCi../gm and attached hereto_
• Maximum concentration of TENORM shall be identified below.
Analytical Data Included: YES O NO
•
Max. Concentration TENORM In pCi/g:,ta226+Ra22ik jb-210: Po -210:
Should Pawnee's portal radiation detectors be activated upon delivery of generator's exploration waste, further screening will be performed.
B.3 Physical Description
❑ Solid ❑Sludge ❑Fine Particulate ❑Odorous BULK LIQUID WASTE IS NOT ALLOWED
❑ Other/Debris (describe): All material must pass the Paint Filter Test (USEPA 9095B) or undergo
Wastes for Solidification (fails Paint Filter Test (USEPA Method 9095B)) solidification at Pawnee Waste E&P Landfill
C. WASTE VOLUME/PACICAGING
Description
Delivery Frequency
Quantity (circle one)
ITons
/ Cubic Yards / Barrels / Other:
Tons I Cubic: Yards / Barrels r Other:
D. GENERATOR CERTIFICATION
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 exempt exploration and/or production waste as defined in 40 CFR 261.4(b)(5). Unless analytical results are provided herein, I certify that this waste
expressly meets the Waste Analytical Requirements identified above. I certify that the material passes the Paint Filter Test (EPA Method 9095B), unless
approved for solidification at the Pawnee Waste E&P Landfill. I certify that all known or suspected hazards have been disclosed, and that the waste is not
a regulated hazardous waste by USEPA 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 E&P 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 of a change in waste, including the source, composition, or process prior to delivery to Pawnee Waste E&P Landfill.
Generator or Generator's Authorized Representative:
Printed Name:
Signature:
Title:
Company:
Date:
_ . - - I Deleted: this Waste Profile Sheet.
l Deleted:
{ Deleted: )
j Deleted:
Deleted: pCi'gm
Exempt Production Waste Profile Sheet
Page 1 of 1
Waste Profile Sheet— Non-exempt Exploration & Production
(Use This Form also for Mixed Exempt and Non-exempt E&P
Pawnee Waste E&P Landfill
E&P Waste
Office Use Only:
Waste)
Profile ID #:
Approved l Rejected fl
Location: WCR 118
Grover. CO 80729
Date:
Completed By:
Mailing Address: 3003 E. Harmony, Suite 300
Fort Collins, CO 80528
Phone: I
Fax:
Email:
A. GENERATOR INFORMATION
Generator Name:
Generator Address:
Contact Name:
Phone:
Fax:
Email:
City:
State:
Zip:
Waste Source LocationNVell Name:
County:
Generator Mailing Address (if different):
Waste Source Location Address/Coordinates/Rig #:
Township:
Range:
Section (1/4-1/4):
City:
State:
Zip:
City:
State:
Zip:
B. WASTECHARACTERIZATION FOR MIXED EXEMPT AND NON-EXEMPT E&P WASTE
6.1 Please attach all analytical results, if appropriate to this sheet.
a) Does the waste contain NORM?TENORM with combined Radium-226/Radium-228 n 50 pCiigram?
(not
■Yes
acceptable
DNo
iatlach analytic* laboratory resuls)
bl Is the waste hazardous as defined under Colorado regulations (see 6 CCR 1007-3 Part 261)?
❑Yes
(not acceptab'e)
(attach analytkai
No
laboratory results)
cl Does the waste contain "free liquids" (fail the Paint Filter Test)?
(must
■Yes
be
solidified)
❑No
d) Does the waste contain PCBs at a concentration greater than 50 ppm?
❑Yes
(not acceptable)
❑No
(attach analytical laboratory resuls)
e) Does the waste contain Asbestos at a concentration greater than 1%?
DYes
(not acceptable)
(attach analyuca:
No
laboratory results)
B.2 Please attach all analytical results, if appropriate to this sheet.
Non-exempt E&P Waste must be analyzed for NORM/TEN0RM by a state -certified
lab and procedure to demonstrate that the waste does not contain combined
Radium -226/228 concentration is s 50 pCi/gram. The analytical results shall be
documented in pCi/gram and submitted with the waste profile.
Sample No.
Analytical Results for Combined
Radium -226/228 (pCi/g)
B.3 Physical Description (check all that apply)
)Solid
)Wastes
•Sludge
for
OFine Particulate ❑Odorous ❑Debris (describe):
Solidification (material fails Paint Filter Test (USEPA Method 9095B)
BULK LIQUID WASTE IS NOT ALLOWED
All material must pass the Paint Filter Test (USEPA 9095B) or
undergo solidification at Pawnee Waste E&P Landfill
C. WASTE VOLUME/PACKAGING
Description
Delivery Frequency
Quantity
Circle One
Tors 1 Cubic Yards 1 Banes / Other.
Tons ( Cub.e Yards I Da:ras / ether.
D. GENERATOR CERTIFICATION
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-exempt E&P Waste and it does not contain combined Ra-226 + Ra-228 greater than 50 pCi/gram, 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 E&P Landfill. I certify that all known or suspected hazards have been disclosed, and that the waste is not a regulated
hazardous waste by USEPA 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 E&P 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 Generators 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 E&P Landfill.
Generator or Generator's Authorized Representative:
Printed Name:
Signature:
Title
Company
Date
I Non -Exempt Production Waste Profile Sheet
Page 1 of 1
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?
CONFIRMED?
IF CONFIRMED. COMPLETE INCIDENT LOG
YES
YES
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: pR/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:
❑ RCRA metals (TCLP)
❑ Benzene
❑ Ignitability
❑ 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 [ ]
SITE MANAGEMENT [ ] STATE [ ]
HAULER [ ]
FED [ ]
WELD COUNTY [ ]
SECTION V
EMPLOYEE NAME:
WITNESS (IF ANY):
DATE: TIME: AM PM (circle one)
DRIVER SIGNATURE:
PAWNEE WASTE REPRESENTATIVE SIGNATURE:
_f Deleted:11
APPENDIX E
ENVIRONMENTAL MONITORING PLAN
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.
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Golder
Associates
APPENDIX F
CLOSURE/POST-CLOSURE PLAN
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).
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).
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.
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Golder
Associates
APPENDIX I
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
1
October 19, 2015
Revised April 22, 2016
Risk Assessment Report Rev 1— Pawnee Waste LLC October 19, 2015
CONFIDENTIAL BUSINESS INFORMATION Revised April 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 7
Figure 2: Annual Radiation Dose to a Landfill Worker by Pathway 11
Figure 3. Annual Dose to a Resident Farmer by Pathway 13
LIST OF TABLES
Table 1: Laboratory Analysis of Representative Production Wastes 2
Table 2: Radionuclide Concentrations in Waste to be Received at the Landfill 3
Table 3: RESRAD Site -Specific Input Parameters 7
Table 4: Occupancy Factors 9
Table 5: Soil Radionuclide Concentrations (for both post -closure resident farmer and worker dose
assessment) 9
Table 6: Exposure Pathways 10
Table 7: RESRAD Annual Doses to Workers by Pathway 10
Table 8: Annual Radiation Dose to a Resident Farmer 1,000 Years Post Closure 12
ADDENDUM 1
(APRIL 22, 2016)
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