SFUND RECORDS CTR 2095669 CLARK COUNTY HEALTH DISTRICT P.O. BOX 3902 • 625 SHADOW LANE • LAS VEGAS. NEVADA 89127 • 702-385-1291 • FAX 7O2-384-5342 March 20. 1998 Mr. Alan Gaddy, Vice President Republic Environmental Technologies of Nevada, Inc. 770 E Sahara Ave Las Vegas. NV 89104 Dear Mr. Gaddy: As requested, we are enclosing copies of the pages from the following case file: SUNRISE MOUNTAIN LANDFILL (SSD CO.) 04719-33A-01 CLOSURE ACTIVITIES As Custodian of Records and Documents, I hereby certify that these are true and accurate copies of original documents on file in our Environmental Health Division. Cost for production of records established by the District Board of Health and Nevada Revised Statues is $.60 per copied page. Enclosed are the 19 copied pages of the records you have requested. Please remit $11.40 to the Clark County Health District. Sincerely, C7f. David Rowles, Director Administrative Services DR/bf Enclosures cc: Environmental Health SUNRISE MOUNTAIN LANDFILL File CLARK COUNTY • LAS VEGAS • NORTH LAS VEGAS . BOULDER CITY • HENDERSON 003345
Transcript
SFUND RECORDS CTR
2095669CLARK COUNTY HEALTH DISTRICT
P.O. BOX 3902 • 625 SHADOW LANE • LAS VEGAS. NEVADA 89127 • 702-385-1291 • FAX 7O2-384-5342
March 20. 1998
Mr. Alan Gaddy, Vice PresidentRepublic Environmental Technologies
of Nevada, Inc.770 E Sahara AveLas Vegas. NV 89104
Dear Mr. Gaddy:
As requested, we are enclosing copies of the pages from the following case file:
As Custodian of Records and Documents, I hereby certify that these are true and accuratecopies of original documents on file in our Environmental Health Division.
Cost for production of records established by the District Board of Health and Nevada RevisedStatues is $.60 per copied page. Enclosed are the 19 copied pages of the records you haverequested. Please remit $11.40 to the Clark County Health District.
CLARK COUNTY • LAS VEGAS • NORTH LAS VEGAS . BOULDER CITY • HENDERSON
003345
Harding LJWIOPI Anoclatai
March 22.1995
23629.1
Mr. Tom Isola, Vice PresidentMr. George Rogers. ArchitectDisposal Urban MaintenanceProcessing Company. Inc.770 E. Sahara AvenueLas Vegas. Nevada 89104
VERIFICATION OF CLOSURE IN ACCORDANCEWTTH APPROVED CLOSURE PLANSUNRISE MOUNTAIN LANDFILL.CLARK COUNTY, NEVADA
Gentlemen:
At your request, this letter is submitted as verification of closure of the above referenced landfill in accord with the.approved landfill closure plan, dated April U. 1994 and titled. "Sunrise Mountain Landfill Closure Plan." This verificationis required by Section 7.1 of the approved closure plan and further required by Clark County and State of NevadaAdministrative Codes, Section 444.6892-5 and by the Code of Federal Regulations, Part 258.60. Section (h).
As part of the verification process, an engineer of Harding Lawson Associates (HLA) visited the site on seven separateoccasions during construction phase activities to review progress and assist in identifying construction deficiencies whichwere required to be addressed prior to finalizing closure. Verification of meeting closure plan requirements is also basedon information provided to HLA which included the following documents:
• Letter and reports by Vector Engineering. Inc., the engineering consulting firm providing the constructionquality assurance oversight for the installation of the infiltration layer and erosion layer. The letter, copyattached, provides certification regarding compliance with the approved plans and specifications for theinfiltration layer system.
• Record survey supplied by Silver State Disposal Company showing compliance with thickness requirements forthe installation of the infiltration layer and erosion layer system.
Based on the HLA site visits, and on the above referenced documents, designed structures and engineered materials appearto have been installed in substantial accord with the approved closure plan and appear to meet the design intent.This letter was prepared in accord with generally accepted practices applicable at the time it was issued. HLA makes noother warranties, either expressed or implied, as to the professional opinion provided under the terms of service asdescribed in this letter.
HLA sincerely appreciates the opportunity to provide continued service to DUMPCo in completion of this project. Shouldthere be questions regarding this letter or should you require idditional information, please contact the undersigned at (702)
Sincerely.HARDING LAWS ON ASSOCIATES
Edward H. Martinez. P.E.Associate EngineerCertified Environmental Manager EM-1013 (NVJ
Director'H'lvironmontaJHc-alUiDivfeior March 3, 1995Mr. Clare Schmutz, R. S.
Clark County Health District625 Shadow LaneLas Vegas, Nevada 89127
re: Sunrise Mountain Landfill Closure
Dear Mr. Schmutz,
Please accept this letter as notification that the Sunrise Mountain Landfill is fully closed asof March 1,1995 according to the terms and conditions as noted in part 7.1 of the document titled"Sunrise Mountain Landfill Closure Plan" dated April 14,1994, agreed to by you and other agenciesparty thereto. Furthermore understand that no additional closure activities are required exceptmonitoring and maintenance. As of March 1, 1995 D.U.M.P.Co. will begin monitoring andmaintenance of the closure for a period of five years, until April 31/2000, as agreed to in part 8.1.1of the aforementioned plan.
Please acknowledge your understanding and agreement of this notification by signing anddating where required and returning one original copy to us for our files.
Thomas A. IsolaVice President
Clark County Health District Date
770 East Sahara Avenue • P. O. Box 98508 • Las Vegas, Nevada 89193-8508 • Telephone (702) 735-5151 • Fax (7no> -—
HAM WttN MCtCVIO
003348
CLARK COUNTY HEALTH DISTRICT
P.O. BOX 4426 • 623 SHADOW LANE • LAS VEGAS. NEVADA 89127 • 7O2-383-I291 • FAX 702-384.3342
September 19, 1994
Mr. Thomas A. IsolaVice PresidentDisposal Urban Maintenance Processing Co., Inc.770 East Sahara AvenueP. 0. Box 98508Las Vegas, NV 89193-8508
Dear Mr. Isola:
We have reviewed your request for an extension of time for finalclosure of the Sunrise Landfill and have discussed your requestwith personnel of the Clark County Public Works Department whohave reviewed the closure extension request with you and yourstaff.
We have determined that Silver State acted in good faith in thepreparation^jrf—the Sunrise Landfill closure plan and haseffectivelyx^reformed work on the closure since the plans wereapproved, anothat precautions have been taken to prevent threatsto the public health and safety and the environment of theLandfill.
The Clark County Health District, as the Solid Waste ManagementAuthority for Clark County, is in accordance with Section 70 of "the State Environmental Commission Regulation LCB File No. R-051-93, as amended by LCB File No. R-208-93, adopted by the DistrictBoard of Health by reference, granting Silver State DisposalUrban Maintenance Processing Company, Inc. a six-month extensionto April 9, 1995, for final closure of the Sunrise Landfill.This approval is with the understanding that the District willreceive reports on the progress of closure at 60 day intervals.
If you have any questions regarding this matter, contact thisoffice at your convenience.
Your continued cooperation is appreciated.
Sincerely,
ENVIRONMENTAL HEALTH
Clare A. Schmutz, R. S.Environmental Health Director
cc: Marty Manning, CCPWBureau of Land Management
CLARK COUNTY • LAS VEGAS • NORTH LAS VEGAS • BOULDER CITY • HENDERSON
003349
SOLID WASTEMEMORANDUM 1
TO: Clare A. Schmutz, R.S., Environmental Health Director
FROM: > ict6rxB.'~S^aar, MAN^ Environmental Health Supervisor
SUBJECT: Review of the Request of Final Closure Date, SunriseLandfill, D.U.M.P. Co. Letter August 3, 1994
DATE: August 8, 1994
My review of the subject request addresses these basicissues:
1. Does authority exist to grant an extension? Yes, inmy opinion. Section 70 {Amended by Sec. 20 ofLCB File #R-208-93) states that authority " ifthe owner or operation demonstrates that closurewill, of necessity, take longer than 180 days ".
I believe the question is of the authority'sacceptance of the owner/operator's(s) interpretationof " of necessity ". What criteria will beused to establish an acceptable reason for the failureto complete according to the initial plan? I believethat a company's financial posture should not byitself determine " of necessity ".
2. The landfill operator has a contractual obligation toperform as prescribed. That contract is betweenSilver State/D.U.M.P. Co., Clark County, and BLM.I recommend that any request for an extensionapproval should be initiated by the appropriatecontract's administrator, Public Works Director, orcounty agencies with responsibility arid authority toact. The Clark County authorities should make thedecision to honor the request for an extension (orany other contractual deviation) and recommendacceptance by the Solid Waste ManagementAuthority, Clark County Health District.
VBS:dt 00335°— L.\ e£ *Sc~ci)f
CLARK COUNTY HEALTH DISTRICT P.O.BOX4426 625 SHADOW LANE LAS VEGAS. NEVADA 89U7
Irfaan
Clare Schmutz.R.S.Environmental Health ManagerClark County Health District625 Shadow LaneLas Vegas, Nevada 89127
re: Sunrise Landfill Closure
Mr. Schmutz,
Auaust 3, 1994
AUG 3Oiraciot
Environmental Health Division
He have recently reviewed our schedule for completion ofclosure activities for the Sunrise Landfill and determined that wewill not finish in accordance with the intended schedule.
A schedule extension is necessary due to the extreme length oftime required by the agencies, including the Bureau of LandManagement, for the review and approval of the closure plan and theequipment mobilization and coordination time required toefficiently perform the work subsequent to the approval.
In accordance with Section 70 of the State EnvironmentalCommission Regulation LCB File No. R-051-93 as amended by LCB FileNo. R-208-93 we request an extension until April 9, 1995 tocomplete the closure tasks as agreed to. We anticipate substantialcompletion prior to this date. As always we have taken and willcontinue to take all actions to prevent threats to public healthand safety and the environment.
If you agree to our extension please indicate so by affixingthe appropriate signature and date in the space provided at thebottom of the page.
Very truly yours,
Thomas A. IsolaVice President
signature date
print name
770 East Sahara Avenue • P. O. Box 98508 • Las Vegas. Nevada 89193-8508 • Telephone (702) 735-5151 • Fax (702) 735-1986
V*OI WK MCtClU »»«• 00335A
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iej Any demonstration, certification, finding, monitoring, icsting or analy t ica l
data from the program for monitoring ground water required by sections 43 to
61. inclusive, [this regulation:) (he regulation adopted by the state
environmental commission that was filed with the secretary of state on
November S. 1993, and designated as LCD File No. R051-93:
(ft Plans tor closure and postclosure and any monitoring, testing or analytical data
required by sections 32. 34 and 69 to 72. inclusive, (this regulation:! the
regulation adopted by the state environmental commission that was filed with
the secretary of state on November 8. 1993, and designated as LCD Pile .\'o.R051-93; and
(g) Any documentation of-cost [estimate] estimates and financial assurance:
required by NAC 444.685.
2. The owner or operator shall notify the solid waste management authority when
the documentation has been placed in or added to the operating records. All
information contained in the operating records must be furnished upon request to
the solid waste management authority or be made available at 'all reasonable
times for inspection by the solid waste management authority.
3. The solid waste management authority may establish alternative schedules
for recordkeeping and notification, required by NAC 444.570 to 444.748.
inclusive, and sections 2 to [87.] 86.5, inclusive, [of this regulation.) the
regulation adopted by the state environmental commission'that was filed with
the secretary of state on November 8, 1993, and designated as LCB File ;Vo.
R051-93, except for the notification required by paragraph ic) of subsection I of
section 35 of [this] that regulation and by subsection 3 of section by subsection
3 of section 53 of [this] that regulation.
Sec. 20. Section 70 of the regulation adopted by the state environmental commission that
was filed with the secretary of state on November 8. 1993. and designated as LCB File No.
R051-93. is hereby amended to read as follows:
Sec. 70. I. At least 15 days before beginning the closure of a municipal solid
waste landfill unit at a Class I site pursuant to subsection 2. an owner or operatorshall provide notice to the solid waste management authority of the intent to close
the unit.
LPetition 'MlXlft a permanent refutation oJnpicJ by the Nevada Environmental Cummiiiiun un Januarr K>. I'I"U. Tint pciiimn tR-jnwnJeJ Knvinmmcnial CommiHion (xiuton'i «lji»W A 'MUM iLCO R4lj|.>l]i nt nU<J wi.h ilw Svcr.urv .1 SUM «n N..v«n.f«fOunyet mud* pr<vmutU in R-OJ!••*.'. 4« fil<J «n Nn»<mlxrS. I'NJ. have (wen rcmu»c\l l(vm inn pennon -WlXVi.
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2. The owner or operator shall begin activities tor the closure or' the municipal ,
solid waste landfill unit no later than 30 days after the date on which the unit
receives the final receipt or' wastes or. if the uni t has remaining capacity and
there is a reasonable likelihood that the unit will receive additional wastes, no
later than I year at'ter the most recent receipt or' wastes. Extensions heyond the
I-year deadline may be "ranted by the solid waste management authority \\ the
owner or operator demonstrates that the unit has the capacity to receive additional
wastes and the owner or operator has taken and will continue to take all actions
necessary to prevent threats to public health and sat'eiy and the environment
from the open unit.
3. (The] Except as othenvise. provided in subsections 4 and 5. the owner or
operator of a Class I site shall complete activities for the closure of each
municipal solid waste landfill unit at the site in accordance with the plan for
closure within ISO days after the beginning the closure. Extensions of the period
for closure may be granted by the solid waste management authority if the owner
or operator demonstrates that closure will, of necessity, take longer than 180
days and thai the owner or operator has taken and will continue to take all actions
to prevent threats to public health and safety and the environment from the open
unit.
4. The owner or operator of a Class 1 site which stopped receiving waste before
'November 8, 1993, shall:,
(a) Comply with the requirements for a final cover set fonh in section 69 of the
• regulation adopted by the state environmental commission that was filed with
the secretary of state on November 8, 1993, and designated as LCB File No.
R051-93; and
(b) Complete activities for the closure of each municipal solid waste landfill unit
at the site by May 8, 1994.
5. The owner or operator of an existing municipal solid waste landfill unit or
. lateral expansion at a Class I site which accepts less than 100 tons of solid
waste per day shall, if the site stops receiving waste before April 9, 1994:
(a) Comply with the requirements fora final cover set fonh in section 69 of the
regulation adopted by the state environmental commission that was filed with
the secretary of state on November 8. 1993. and designated as LCB File No.
R051-93; and
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Pciiium 'UixVi a permanent refutation adopted hy ihe Nevada Environmental Cummioiun nn January il). I'1''-"anwndevl Environmental Cumrnitnon peniu<n'i ".:I»X A 'Ui»)| iLCU R-II51•''.•) jj tiled *iih Hie Secrcurt1 nr SiCli:inye» nude pre^icujlv in R-H5I •')}. .is llleJ nn Novembers. IV1)]. have been removed Inim lOu petitmn >Ht»U
nmental Cummioiun nn January il). I'i'M. Tl»% p<iiii»/i iR.J'i*-"Suie "» N«»emner .<. I•'•
petiimn 'WOJo I-
003353
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(b) Complete activities for the closure of each municipal solid waste landfill unitat the site within ISO days after (he last receipt of waste.
6. After the closure or' each municipal solid waste landfill unit , the owner oroperator of (he site shall notify the solid waste management authority that acertification, signed by an independent registered professional engineer andapproved by the solid waste management authority verifying that closure has beencompleted in accordance with the plan for closure, has been placed in theoperating record of the site.
Sec. 21. Section 32 of the regulation adopted by the state environmental commission thatwas filed with the secretary of state on November S. 1993. and designated as LCB File No.R051-93. is hereby amended to read as follows:
Sec. 32. // this state assumes legal responsibility for an owner's or operator's
compliance with the requirements for closure, postclosure or corrective action
set forth in
MAC 444.570 to 444.748, inclusive, and sections 2 to 86.5. inclusive, of theregulation by the state environmental commission that was filed with the
secretary of state on November 8, 1993, and designated as LCB File No. £057-
93, or assures that money will be available, from the state to cover the related
expenses, the owner or operator shall be deemed to be in compliance with the
requirements of MAC 444,685. Any assumption of responsibility by this state
must meet the criteria specified in section 84 of the regulation by the statei
environmental commission that was filed with the secretary of state onNovember 8, 1993. and designated as LCB File No. ROS1-93.
•Sec. 22. Section 85 of the regulation adopted by the state environmental commission thatwas filed with the secretary of state on November 8. 1993. and designated as LCB File No.
R051-93. is hereby amended to read as follows:
Sec. 85. I. The owner or operator of a Class II site shall provide suitable
shelter, drinking water and sanitary facilities for the employees who work at
the Class II site.
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003354
Petition >UUV> a ptrmancnt regulation adopted by ilw N«raJ» Cnvimnmcnol Cummttiton on Jamurv 10. I'I'M. TUi\ p<tmon til-Ill* ••'.••,m«nJ<J eiivinmnwnial Cummiuion [xntion'! 'IJUM A 'Wmi (LCD R-<)«l-'».tl :»* liloJ %.nh iKc Secretary m Sate i.n N..«mh<r v I'"'1
Clun;<i nuU< prcviiHiilv in R-1)51-03. jt fil<J nn Ni«»<inNrr X. I'>">). luvc teen rcmuxvl Irum ilxti ptitinm 'UIKIA I
CLARK COUNTY HEALTH DISTRICT
P.O. BOX 4426 • 823 SHADOW LANE • LAS VEGAS. NEVADA 89127 • 702-383-1291 . PAX 702-384.534;
Aprils. 1994
Clark County Department of Public WorksAttention: M. J. Manning, Director6655 W. Sahara Avenue, Building C-204Las Vegas, NV 89102
Ref: Closure Date Extension for County Landfills, letter dated March 28, 1994
Dear Mr. Manning:
We received your request for the final closure date extension for the nine dumps/landfills on April 5,1994.
Your request for a six-month extension of the April 9, 1994, mandated closure date for eight county-operated dumps and the Sunrise Class I landfill is granted under authority of the Nevada regulationadopted by the State Environmental Commission that was filed with the Secretary of State onNovember 8, 1993, and designated as LCB File No. R051-93, and the U.S. EPA granting a six-monthextension to the original published date, e.g., October 9, 1994:
The closure process for each of the above sites is expected to be completed not later than October 9,1994. Please submit your certification of final closure within thirty days after the actual completiondate.
Sincerely, - • . .
CLARK COUNTY HEALTH DISTRICT
d.^:sQboC. A. Schmutz, R.S.,Environmental Health Director
CAS/VBS:dtcc: Marvin Morgan, BLM/Las Vegas
Tom Isola. Vice President. D.U.M.P. Co., Inc. 003355David Emme, NDEP/Carson City
CLARK COUNTY . LAS VEGAS . NORTH LAS VEGAS . BOULDER CITY - HENDERSON
Urban ilawtettanr*rnraBHttuj QIa, Jnr.
April 5. 1994
Clare SchmutzClark County Health District625 Shadow Lane Clark County Health DistrictLas Vegas, Nevada 89106 iiSTProsrcn
REQUEST FOR EXTENSION INSTALLATION OF FINAL COVERSUNRISE MOUNTAIN LANDFILL CLOSURE CLARK COUNTY. NEVADA
Dear Mr. Schmutz:
Per a discussion between our consultants, Harding Lawson Associates (HLA) and Dave Emme,regarding completion deadlines for closure of the Sunrise Mountain Landfill. Disposal UrbanMaintenance Processing Company. Inc. (D.U.M.P.Co.) understands, upon approval of the State'sSolid Waste Program, an extension to the deadline for installation of the final cover will berequired and granted upon submission of a formal request
At the present time, it is understood the federal deadline for. installation of this cover is October• 9, 1994. The State deadline is currently 180 days after receipt of final waste. D.U.M.P.Co. hasscheduled installation of the b'ner to adhere to the federal deadline to allow time for closuredesign and for review and approval by applicable regulatory agencies involved. Also, at the timethe closure process for this facility began, the State's program had not been approved. Therefore,the federal deadlines were referenced as those applicable to this site.
For these reasons. D.U.M.P.Co. formally requests an administrative extension to the State's 180day deadline for the Sunrise Mountain Landfill to match the federal closure deadline (October9, 1994).
If this is acceptable, a written response is requested. D.U.M.P.Co. appreciates your considerationand assistance in this matter. If there are any questions, please contact the undersigned.
Sincerely,
'a.Thomas A. IsolaVice President
pc: Dave Emme: NDEPCliff Yeckes; HLA
770 East Sahara Avenue • P. O. Box 98508 • Las Vegas. Nevada 89193-8508 • Telephone (702) 735-5151 • Fax (702) 735-1986
003356« «,TW nerou nut
(NV-053)
Mr. Marty ManningClark County Dept. of Public Works MAO <, - w<6655 West Sahara Avenue, Bldg. C-204 *Las Vegas, Nevada 89102
Dear Mr. Manning:
On March 17, 1994, representatives of this office went to the
Sunrise Landfill. They found that a channel for conveyance of
surface runoff was being excavated through landfill cells. They
also found a monitor well west of the site was being closed. The
BLM has not approved a closure plan for the site or any activity
associated with a closure plan. Neither Clark County nor any of
its contractors currently has authority to implement landfill
closure. You are directed to immediately cease closure activities.
Please contact me at 647-5000 so we may discuss actions required to
satisfactorily implement a closure plan.
Sincerely,. .. • v
\ GARV RYAN ['(JSrV "Ryan* ~"Acting District Manager
cc: •" Mr. Victor SkaarClark County Health District625 Shadow LaneP.O. Box 4426Las Vegas, Nevada 89127
003357
SOLID WASTEMEMORANDUM
TO: C. A. Schmutz. R.S., Environmental Health Director
FROM: ^victor B. Skaar, MAM, Environmental Health Supervisor, RCRA
SUBJECT: Landfill Status and Solid Waste Issues
DATE: March 22, 1994
The following represents my understanding of the several open issues. Landfill Closures:
I. County Sites
Mr. Jenner's letter to you dated March 15, 1994, is confusing in that I perceive that Mr. Jenner andstaff believe that provisions exist for the approval of an alternative final cover. One must refer to 40CFR Subpan F - Closure and Post Closure S258.60 (a) and (b) to establish that the Federal law doe*permit alternative materials for use as final cover as long as the permeability standards/1 X 10~5cm/sec (52.9 days) is achieved. It is obvious that Mr. Jenner and staff either don't understand thator are trying to convince the authorities that the County need not spend money unnecessarily. Isuggest that perhaps they best consider proceeding with the closure process or they might run out oftime. From my perspective, I believe that it would be illogical and risky for any "authority" to permitclosure with less than the verifiable minimum requirements because, (a) the contents of those ruraldumps are unknown, and (b) the County does not intend to fence or otherwise restrict access. Yourletter to Mr. Jenner of March 22, 1994 should define our position.
II. Commercial/Municipal Sites
1. Two landfills have been closed and accepted: James Hardie Gypsum and Nevada Power - ReidGardner Sanitary Landfill.
2. Nellis Air Force Base closure process continues on schedule for their sites at Indian Springs andthe #3 landfill near the golf course. No problems are expected. (Telecon March 22, 1994).
3. Sunrise Landfill: BLM's stance in halting closure activities until they formally accept theclosure plan is understandable from their perspective. I personally believe that the landfilloperator could have informed them of their intent to perform certain defined activities inpreparation for closure provided that they had not received final plan approval not later thana given date. BLM is suspicious and cautious - shades of Henderson perhaps. I believe thata meeting must occur soon with all interested parties to move this project!
4. Henderson: I have.requested that we be invited to each meeting on this subject. You havea copy of the recent letter.
5. Mesouite; Jack and I will visit the landfill to document the "footprint" as of April 9, 1994. Itappears that their request of March 11,1994, is not unrealistic. This activity will require someextra effort to help them achieve their goal for a new landfill.
6. Boulder Citv; We have submitted all available supporting information received from theconsultants to Mr. Allen Biaggi, NDEP for his review. I support the City's request to use "auto-fluff" as an alternative cover. If NDEP refuses to raise the TPH level for this particular wasteproduct for the specified use, we must then revisit the issue of the waste itself • where canit be disposed of? I believe that it is improper to permit the continued stockpiling on site at theNevada Recycling location.
I trust that this has covered everything of concern.
003358
CLARK COUNTY HEALTH DISTRICT
P.O. BOX 4426 • 023 SHADOW LANE • LAS VEGAS. NEVADA 88127 • 7O2-385-I291 . FAX 702-384-3342
February 17, 1994
Mr. W. Cliff Yeckes, P.G., Managing PrincipalNevada Environmental Manager EM-1025Harding Lawson Associates4170 S. Decatur Boulevard, Suite A-1Las Vegas, Nevada 89103
Subject: Review of Sunrise Mountain Landfill Draft Closure Plan, HLA Project No. 26073and your letter dated February 9, 1994
Dear Mr. Yeckes:
Thank you for the revised response to our comments. Mr. Schmutz and I have reviewed eachitem and are comfortable with all aspects of the closure plan.
Please be advised that we are prepared to review and approve the final plan as it representsthe subject revision dated February 10, 1994, and look forward to witnessing the projectcompletion.
Thank you for your cooperation.
Sincerely,
CLARK COUNTY HEALTH DISTRICT
Environmental Health Supervisor
VBS:dt
cc: Mr. Tom Isola' Silver State Disposal, Inc.
00?359
CLARK COUNTY • LAS VEGAS • NORTH LAS VEGAS . BOULDER CITY . HENDERSON
CLARK COUNTY HEALTH DISTRICT
P.O. BOX 4426 • 823 SHADOW LANE • LAS VEGAS. NEVADA 89127 • 7O2-38S-I29I . FAX 7O2-384-3342
February 2, 1994
W. Cliff Yeckes. P.G.Managing PrincipalHarding Lawson Associates4170 South Decatur BoulevardSuite A-1Las Vegas, Nevada 89103
Subject: Review of Sunrise Mountain Landfill Draft Closure Plan, HLA Project No. 26073dated January 20, 1994
Dear Mr. Yeckes:
Thank you for meeting with us on January 21. 1994, and presenting copies of the subjectplan and the corresponding Construction Quality Assurance Plan with engineering drawings.
Mr. Ed Wojcik, our consulting engineer, met with Mr. Eddie Martinez of Harding LawsonAssociates (HLA) on Tuesday, January 25, 1994. Mr. Martinez' letter of January 26identified the course of their discussion of technical issues. There appears to be no significantdifferences of opinion regarding the technical issues defined in Sections 4 and 5 of the draftClosure Plan and the related technical drawings.
Our review, offers these considerations:
Item 2.1, page 5, final sentence: Please clarify to whom the responsibility for the site willtransfer after the first five years of the post-closure period.
Item 2.2, page 5, third line: "10 x '* cm/sec* should read, "1 x 10'* cm/sec.
Item 2.2, final paragraph: Final cover was applied in accordance with Clark County' HealthDistrict Regulations Governing Solid Waste Sites & Facilities dated September 1990,paragraph 7.b, page 10, which defines final cover as "a layer of at least two feet of materialin addition to the daily~cover. . .." It is therefore expected that all areas closed prior toOctober 9, 1991, will be left with at least the requisite two feet of earthen material cover.
Item 3.1, page 7, second sentence: We recommend that the final slope be a minimum of 10percent grade. During the stripping process one must ensure that the necessary materials arenot removed from those "old cells.' (See previous comment regarding final cover.)
Item 3.2, page 7', first subparagraph, first sentence: It is agreed that the infiltration layermust consist of a minimum of 18" rather than 12" of acceptable permeable soils. Secondsentence: Delete the comma after "be" and after "material." Second subparagraph, first
CLARK COUNTY LAS VEGAS NORTH LAS VEGAS BOULDER CITY HENDERSON
sentence: Suggest adding "... that is capable of sustaining native plant growth" (a directquote from 40 CFR 258.60(a)(3).
Item 3.2, top of page 8, final paragraph, final sentence: Delete the remainder of the sentenceafter,". . . placed. . ." and substitute, ". . .in accordance with Clark County Health DistrictRegulations Governing Solid Waste Sites &. Facilities, September 1990, in effect prior toSubtitle D of 40 CFR 258." (See previous remarks.)
Item 3.3, page 8: We understand that a "Permit For Construction Activity" must be obtainedfrom the CCHD Air Pollution Control Division to include the time period necessary to begin andcomplete the closure process.
Item 8.1.1, page 15, first paragraph: 'We suggest that all parties might consider jointinspections with the BLM representative and CCHD Solid Waste Management representative.
Item 8.1.2, page 15: We request that copies of the analyses from indicated monitoring besubmitted to CCHD Waste Management as a matter of permanent record.
Item 8.2, page 16, final sentence: "After the five year period, BLM will be the site contact."Please identify the BLM office of primary interest and their telephone number.
Item, "Distribution," final page: Request the copy of the final closure plan be distributed toMr. Clare Schmutz, Environmental Health Director.
Sincerely,
CLARK COUNTY HEALTH DISTRICT
"Victor BTSkaaFTF/IAMEnvironmental Health Supervisor
VBS:mlm
cc: Mr. Tom IsolaSilver State Disposal, Inc.
003361
E. J. WOJCIK ENGINEERINGCIVIL ENGINEERING CONSULTANT
Edmund J. Wojerk, P.E. 62O South 11tti Street(7O2) 598-123* Sort* 6(702) «H>«-ni79 {PAX} Las V«s*9
"/ 31. 1994
Mr. Oare A Schmutz. R.S. JAM 3
Clark County Health District ENVIRONMENTAL HEALTH625 Shadow LaneLas Vegas. NV 89127
Re: Sunrise Mountain Landfill Final Closure
This letter is submitted to .affirm that the draft documents and preliminary plans dated January 20. 1994 and January19, 1994 respectively submitted by Harding Lawson Associates for the referenced closure are ready for acceptance.This affirmation Is based on my independent review of all of the Closure Plan and Construction Quality AssurancePlan documents and the 15 sheets of preliminary plans forflnal landfffl closure, my meetlnq on January 25.1994 withMr. Edward H. Martlnes. P.E to answer specific questions and a visit to the landfill site with Mr. Victor B. Skaar. R.S.on January 28.1994 for additional orientation and clarification bv Mr. Martinez.
The submitted copies of all reviewed documents and plans are attached for your file. Also attached is a copy of aletter dated January 26.1994 from Mr. Martinez documenting the specific points of my discussion with him at HardingLawson Associates' office on January 25. 1994. This letter dearer outlines some of the most important parts of theirplan for final closure to meet federal and state regulations.
In summary these plans do propose to install an engineered cover as described in item (a), numbers (1). (2) and(3) of 40 C.F.R., Part 258. Subpart F. The actual limits of closure must be verified through examination of past landfillrecords and future construction quality assurance documents.
Sincerely.
EJ. WOJCIK ENGINEERING
Edmund J. WoiciK. P.E
EJW:gec
003362
Harding l_Jw»on AJIOCIJIOS
January 26, 1994
22068.1
Mr. Victor B. Skaar, R.S., SupervisorUnderground Storage TanksHazardous MaterialsClark County Health District625 Shadow LaneLas Vegas, Nevada 89127
SUNRISE MOUNTAIN LANDFILL CLOSURECLARK COUNTY HEALTH DISTRICT REVIEWRESPONSE TO COMMENTS
Dear Mr. Skaar:
As agreed, Harding Lawson Associates (HLA) met with Mr. Ed Wojcik, technical consultant for theClark County Health District (CCHD), on Tuesday, January 25, 1994. At this meeting, thepreliminary plans and specifications for the above referenced project were reviewed. Listed belowis a summary of items discussed and the technical responses provided during this discussion.
• Use of the Rational Formula method instead of the HEC I method for on-sitestormwater runoff analysis was discussed. All on-site and off-site hydrologic analyseswere conducted according to procedures outlined in the Clark County Regional FloodControl District (RDCD), "Hydrologic Criteria and Drainage Design Manual",(October 1990). This document allows for use of the Rational Method of runoffanalysis "for drainage basins that are not complex and have small drainage areas".The on-site drainage areas identified as basin areas were kept small and basincharacteristics were generally uniform, therefore .use of the rational method wasappropriate. With these considerations and since there are no plans for developmentof the site in the future, thus altering potential basin characteristics, the RationalMethod provided sufficient accuracy for the intended use.
• Minimum cover slopes and maximum allowable side slopes were discussed. Currentcriteria within Nevada's solid waste regulations require a minimum slope for finalcover material of 2 percent for drainage purposes. As designed, all areas receivingRCRA cover meet (^exceed this requirement. Maximum side slope within waste
Engineering andEnvironmental Services
4170 Soutn Oeeaiur Boulevard. Suite A-1. Lai Vegas. NV 69103 702/25 t-J449A Suiueitry tf Harding .-Uioctam < 0/KfCJ .V«fto*mrf«
003363
Harding Lawion Associate*
6January 2>>. 1994Mr. Victor B. SkaarClark County Health DistrictPage 2
areas was set at 3:1 to address potential side slope stability issues regarding siteclosure activities.
• Per RCRA Subtitle D, permeability of the infiltration layer shall be 1 x 10'J or thepermeability of the underlying soil layer, whichever is less. Based on investigationconducted to-date on inplace materials in areas where RCRA cover is to be placed,underlying soils consist of silty sands and gavels with sand being the majorcomponent. Soil analyses of samples taken from these areas indicate these soils,unprocessed, will not meet the permeability requirements and therefore, the 1 x 10**requirement will govern.
• The Closure Plan stipulates monitoring of the existing well. To quantify thismonitoring, the existing well will be visited bi-annually. If water is present in thewell, a sample will be taken. This sample will be sent to an NDEP approved lab foranalysis of potential contaminants listed in Appendix I of RCRA, Subtitle D.
• Use of undisturbed samples versus in-situ analyses for demonstration of compliancewith permeability standards was unclear. The CQA Plan identifies the use ofundisturbed samples for this analysis. This will remain the preferred method unless,during construction, a more effective approach is found.
$• While not currently part of the CQA Plan, there will be a testffrip developed for theinstallation of the RCRA cover. This test strip will assist the Contractor and the CQAconsultant to standardize lift thickness and rolling patterns for installation of the covermaterial. CCHD requested a copy of the results (which will be supplied) from thistest strip analysis to assist them in determining future construction compliance.
To further assist the CCHD in review of these documents, a site visit will be conducted on Friday,1
January 28,1994. The purpose of this site visit will be to orient CCHD personnel in the site featuresand to further discuss additional items which may have risen in the last four days.
