Proposed Approval for Commercial Disposal of
Polychlorinated Biphenyls
Chemical Waste Management of the Northwest, Inc.
Arlington, Oregon
U.S. EPA ID: ORD089452353
Proposed by
U.S. Environmental Protection Agency, Region 10
Seattle, Washington
October 30, 2023
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 10
1200 Sixth Avenue
Seattle, WA 98101
PROPOSED APPROVAL
FOR A TOXIC SUBSTANCES CONTROL ACT
POLY CHLORINATED BIPHENYL (PCB) COMMERCIAL DISPOSAL FACILITY
FACILITY: Chemical Waste Management of the Northwest, Inc. Arlington Facility
U.S. EPA ID Number: ORD089452353
The United States Environmental Protection Agency (U.S. EPA) has approved Chemical Waste
Management of the Northwest's (CWMNW) Application, as owner and operator, to renew and modify
its Approval to operate the Arlington Facility, a commercial polychlorinated biphenyls (PCB) storage
facility and chemical waste landfill located southwest of Arlington in Gilliam County, Oregon (Figure
1). This Approval authorizes CWMNW to store for disposal, treat for disposal, and dispose of PCB
waste at the Arlington Facility (hereinafter Facility or Arlington Facility).
The terms and conditions of this Approval are based on the final Application from CWMNW titled,
"Final Application for Commercial Disposal of Polychlorinated Biphenyls (PCBs) under the Toxic
Substances Control Act (TSCA) Chemical Waste Management of the Northwest, Inc. (CWMNW)"
dated May 12, 2023, and signed by CWMNW on June 22, 2023; additional supporting information
submitted by CWMNW; and other information, as discussed in the draft Statement of Basis (October 30,
2023) for this Approval. Inaccuracies or omissions found in the written information provided by
CWMNW as part of its Application may be grounds for the termination or modification of this
Approval.
This Approval authorizes CWMNW to: (1) continue to dispose of non-liquid PCB waste in an existing
landfill (L-14 Cells 1-4); (2) dispose of non-liquid PCB waste in a landfill cell to be built (L-14 Cell 5);
(3) store for treatment and disposal containerized and bulk PCB waste and PCB Items in existing and to-
be-constructed waste storage areas; and (4) process and treat PCB-containing wastes prior to disposal.
The Approval also requires CWMNW to monitor and perform post-closure maintenance at the non-
operating landfills (L-l, L-3, L-5, L-6, L-7, L-8, L-9, L-10, L-12, and L-13) that previously accepted
PCB wastes.
The Approval authorizes CWMNW to store for disposal, treat for disposal, and dispose of PCB wastes
at the Arlington Facility as shown in Table 1. The locations of these units are shown on Figure 2. Please
note that Figure 2 also includes non-PCB units and units that are not yet constructed.
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Table 1
Approved PCB Units and Maximum Capacities
PCB Unit Name
Approved Activities at PCB Unita b
Maximum Total
Capacity d
gallons (gal) or
cubic yards (cy)
Location in
Approval
Storage Building S-2
Temporary and long-term indoor storage
Draining/flushing, repacking, bulking
Transfer of PCB Liquids
Treatment
1,720,000 gal
Section V
Storage Unit S-6
Temporary outdoor storage
Treatment
10,200,000 gal
Section V
Storage Unit S-10
Temporary outdoor storage
Treatment
8,090,000 gal
Section V
Storage Unit S-l 1
(located within S-2)
Temporary and long-term indoor storage
Transfer of PCB liquids
2,420 gal
Section V
Storage Unit S-l2
Temporary outdoor storage
Treatment
18,000,000 gal
Section V
Storage Building B-5
Temporary and long-term indoor storage
Draining/flushing, repacking, bulking
Transfer of PCB Liquids
Treatment
5,570,000 gal
Section V
Storage Building B-6
(TBC)C
Temporary and long-term indoor storage
Draining/flushing, repacking, bulking
Transfer of PCB Liquids
Treatment
16,710,000 gal
Section V
Storage Building B-7
(TBC)C
Temporary and long-term indoor storage
Draining/flushing, repacking, bulking
Transfer of PCB Liquids
Treatment
5,570,000 gal
Section V
Storage Building B-8
(TBC)C
Temporary and long-term indoor storage
Draining/flushing, repacking, bulking
Transfer of PCB Liquids
Treatment
5,570,000 gal
Section V
OSU-1
Treatment
139 cy/28,000 gal
Section V
OSU-2
Treatment
139 cy/28,000 gal
Section V
OSU-3
Treatment
139 cy/28,000 gal
Section V
OSU-4
Treatment
220 cy/ 44,000 gal
Section V
OSU-5
Treatment
220 cy/ 44,000 gal
Section V
OSU-6
Treatment
220 cy/ 44,000 gal
Section V
SU-B8 (TBC)C
Treatment
13,693 cy
Section V
Landfills L-l, L-3, L-
5, L-6, L-7, L-8, L-9,
L-10, L-12, and L-13
Post-closure care
Not applicable
Section VI
Landfill L-l4
Cells 1-4
Landfill disposal
6,300,000 cy
Section VI
Landfill L-l4
Cell 5 (TBC)C
Landfill disposal
a Temporary PCB storage not to exceed thirty (30) days from the date of removal from service
b Long-term storage not to exceed one (1) year from the date it was determined to be PCB waste unless
EPA approves an extension under 40 C.F.R. §§ 761.65(a)(2)-(3)
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c TBC - to be constructed
d Maximum Total Capacity specifies the total approved waste capacity for the Unit including PCB waste.
U.S. EPA has determined, based on agency review of the Application, that the operation of this Facility,
subject to the conditions in this Approval, does not pose an unreasonable risk of injury to human health
or the environment. U.S. EPA has determined that the applicant has satisfied the requirements of 40
C.F.R. Part 761. The rationale for U.S. EPA's determination is documented in the Statement of Basis
dated October 30, 2023.
CWMNW previously operated the Arlington Facility under an Approval issued by U.S. EPA in 2006.
This Approval supersedes all previous TSCA Approvals issued by U.S. EPA to CWMNW to store, treat,
and dispose of PCB waste at the Arlington Facility.
This Approval is being issued pursuant to Section 6(e)(1) of the Toxic Substances Control Act (TSCA)
of 1976, 15 U.S.C. § 2605(e)(1), and 40 C.F.R. Part 761 \ including any amendments or revisions
thereto.
This Approval is effective immediately upon signature and will remain in effect for ten (10) years from
the original date of issuance unless modified, renewed, suspended, or revoked in accordance with 40
C.F.R. Part 761 or the Approval conditions herein.
Timothy B. Hamlin Date
Director
Land, Chemicals, and Redevelopment Division
1 The U.S. EPA Administrator delegated authority to issue Approvals under TSCA to the Regional
Administrator of Region 10 by U.S. EPA Delegation Order 12-5 issued January 9, 2008. The Regional
Administrator further delegated authority to issue Approvals to the Director of the Land, Chemicals, and
Redevelopment Division by U.S. EPA Regional Order R10-12-5 issued April 15, 2019.
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RECORD OF APPROVAL MODIFICATIONS
Number
Effective
Sections
Description
Date
Modified
0
October 30, 2023
All
Renewal and Modification Approval
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This Page Intentionally Left Blank
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Contents
I. Introduction 1
II. Facility Description 1
III. Scope and Limitations of Approval 2
IV. General Approval Conditions 2
A. Approval Compliance 2
B. General Requirements 3
C. General Waste Management 4
D. Personnel Training 5
E. Health and Safety Requirements 5
F. Emergency Preparedness and Spill Cleanup 5
G. Entry and Agency Inspection 8
H. General Inspection Requirements 8
I. Security 8
J. Closure Cost Estimate 8
K. Post-Closure Cost Estimate 9
L. Financial Assurance for Closure and Post-Closure 9
M. Liability Insurance 10
N. Recordkeeping and Reporting 10
V. Conditions for Storage, Processing, and Treatment of PCBs 12
A. Operational and Regulatory Requirements for Storage 12
B. PCB Waste Storage in Containers 12
C. Approved PCB Treatment Units 13
D. Processing and Treatment for Disposal of PCB-Containing Waste 16
E. Operational and Regulatory Requirements for Processing and Treatment 17
F. PCB Sampling of Treatment Units 17
G. Inspection Requirements for PCB Storage, Processing, and Treatment Units 17
H. Closure of Storage and Treatment Units 18
VI. Conditions for Landfill Disposal of PCBs 19
A. Approved Landfill Units and Maximum Disposal Capacities 19
B. PCB Wastes Authorized for Disposal 19
C. Disposal Prohibitions 20
D. Landfill Operations and Management of Wastes 21
E. Groundwater Monitoring 22
F. Leachate Management, Monitoring, Sampling, Disposal, and Reporting 23
G. Inspection Requirements for Landfill Units 24
H. Closure of Landfill Units 25
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I. Post-Closure Care for Landfill Units 25
VII. Procedures to Modify, Transfer, Revoke, Suspend, Deny, Continue or Renew Approval
27
A. Modifications 27
B. Transfer of Ownership 28
C. Revocation or Suspension of Renewal 28
D. Continuation 29
E. Renewal or Closure 29
VIII. Definitions 29
Figures
Figure 1 - Site Location Map
Figure 2 - Facility Layout
Tables
Table 1 - Approved PCB Units and Maximum Capacities
Table 2 - Units and Descriptions for Processing and Treatment of PCB-Containing Wastes
Attachment 5 - Landfill Design, Operations and Response Action Plan (Application Appendix L)
Attachments
Attachment la - Closure/ Post-Closure Plan (Application Appendix H)
Attachment lb - PCB-Specific Closure/ Post-Closure Plan Information (Application excerpts)
Attachment 2 - PCB Operations Plan (Application Appendix A)
Attachment 3 - Contingency Plan (Application Appendix G)
Attachment 4 - Table 3-1 of the Inspection Plan (excerpt from Application Appendix F)
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I. Introduction
Chemical Waste Management of the Northwest, Inc. (CWMNW) has been operating under an
Approval issued by U.S. EPA Region 10 on January 31, 2006, to store, treat, and dispose of PCB
wastes. CWMNW submitted a final application titled, "Final Application for Commercial
Disposal of Poly chlorinated Biphenyls (PCBs) under the Toxic Substances Control Act (TSCA)
Chemical Waste Management of the Northwest, Inc. (CWMNW)" (Application) dated May 12,
2023, and signed June 22, 2023. U.S. EPA has evaluated this Application and determined that
operation of this storage and disposal facility for PCB wastes, subject to the conditions in this
Approval, does not pose an unreasonable risk of injury to health or the environment.
II. Facility Description
The Arlington Facility is in Gilliam County, Oregon, approximately 12 road miles
south/southwest of the town of Arlington (Figure 1). The nearest two highways are the east-west
Interstate 84 and north-south Highway 19. The Facility entrance is located approximately 5 miles
west of the intersection of Highway 19 and Cedar Springs Lane. Direct access to the Facility is
by Cedar Springs Lane, with an address of 17629 Cedar Springs Lane, Arlington, Oregon. From
Cedar Springs Lane, the haul road extends up the slope to the active area of the Facility.
Secondary unpaved access roads in the undeveloped portions of the Facility intersect the haul
road system. A haul road that parallels Cedar Springs Lane Road also connects the Facility with
the neighboring Columbia Ridge Landfill and Recycling Center.
The Facility consists of approximately 2,600 acres, of which approximately 942 acres are used
for hazardous waste management-related activities. The Facility is bounded on the south by the
east-west trending Alkali Canyon. The Facility extends from the bottom of Alkali Canyon (at an
elevation of approximately 750 feet above mean sea level [msl]) north approximately 5,300 feet,
climbing out of the canyon to the upland plateau (at a maximum elevation of approximately
1,150 feet msl). Hazardous waste storage, treatment, and disposal activities are limited to the
portion of the Facility, known as "the active area," located above 950 feet msl.
The Facility was opened in 1976 and currently accepts approximately 150,000 to 250,000 tons of
waste per year, with approximately 13,000 tons being PCB wastes. Wastes regulated as
hazardous under Resource Conservation and Recovery Act (RCRA) or by Oregon state
regulations are received for storage, treatment, or disposal. PCB wastes regulated under TSCA
are accepted at the Facility for storage, treatment, or disposal under an approval from U.S. EPA
Region 10, separate from the State RCRA Permit. The Facility does not accept explosive,
radioactive (as regulated by the Oregon and U.S. Departments of Energy), or infectious waste.
Wastes that cannot be treated or disposed of at the Facility, or that can be reused or recycled, are
temporarily stored at the Facility and then shipped off-site for treatment, disposal, or beneficial
use elsewhere.
The Facility is properly equipped to safely store, treat, or dispose of all wastes it is authorized to
receive under this Approval. Safe waste management is established through: (1) the
implementation of comprehensive plans; (2) the use of environmental monitoring systems; and
(3) self-audit practices. The Facility also operates under a State RCRA Permit issued by Oregon
Department of Environmental Quality (ODEQ). The Facility is designed and constructed to
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manage solid, semi-solid, and liquid hazardous wastes. Container and bulk storage areas,
containment storage buildings, surface impoundments, stabilization bins, organic recovery units,
wastewater treatment plants, and landfills comprise the major RCRA waste management units at
the Facility. Waste management procedures include storage, transfer, drain and flush, solar
evaporation, stabilization, solidification, macro-encapsulation, micro-encapsulation, wastewater
treatment, thermal desorption, oxidation treatment, and landfilling. All PCB regulated wastes
accepted by the Facility are managed in accordance with the procedures and protocols set forth
in this Approval.
III. Scope and Limitations of Approval
1. This Approval only applies to CWMNW as the Owner and Operator of the Arlington
Facility.
2. This Approval authorizes the following activities at the Facility, consistent with all
applicable conditions in this Approval:
a. The storage for disposal of PCB wastes at units S-2, S-6, S-10, S-ll, S-12, B-5, B-6,
B-7, and B-8;
b. Draining and flushing of PCB liquids from transformers, capacitors, electrical
equipment, and other PCB Articles;
c. Treatment for disposal of PCB wastes at units S-2, S-6, S-10, S-12, B-5, B-6, B-7,
and B-8, OSU-1 through OSU-6, and SU-B8; and
d. Disposal of PCB wastes at units Landfill L-14 Cells 1-5.
3. Compliance with these Approval conditions does not establish a defense to any claim
that the Facility presents a risk to human health and the environment, including such a
claim under the federal PCB regulations at 40 C.F.R. Part 761.
4. If information contained in the Application or other supporting documents differs from
the conditions specified in this Approval, the conditions of this Approval shall govern.
IV. General Approval Conditions
A. Approval Compliance
1. CWMNW must comply with and operate the Facility in accordance with: (1) all terms
and conditions of this Approval as stated herein; (2) portions of the Application
referenced in this Approval; and (3) the PCB regulations at 40 C.F.R. Part 761, including
any future modifications to those regulations.
2. Any plan and/or Application provision referenced in this Approval is fully incorporated
by reference into this Approval and is fully enforceable under the Approval.
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3. At least thirty (30) days prior to making a change to any document referenced in, or
incorporated into, this approval, CWMNW must notify U.S. EPA Region 10 in writing
and initiate an Approval modification consistent with Section VILA, Modifications, to
incorporate into this Approval the most current version of the referenced or incorporated
document.
4. Any action of a CWMNW employee, agent or contractor who is involved in the
operation of the Facility will be considered an action of CWMNW for purposes of
compliance with this Approval.
5. Failure to comply with any condition of this Approval is a prohibited act under TSCA
Section 15(1), 15 U.S.C. § 2614(1).
B. General Requirements
1. This Approval supersedes all previous Approvals issued by U.S. EPA that regulate PCBs
at the CWMNW Arlington Facility.
2. Notwithstanding the terms of this Approval, CWMNW must comply with all applicable
federal, state, and local laws and regulations including, but not limited to RCRA as
amended (42 U.S.C. 6901 et seq.) and the Occupational Safety and Health Act (OSHA).
3. CWMNW must design, construct, maintain, and operate the Facility to prevent fire,
explosion, or any unplanned sudden or non-sudden release of hazardous waste
constituents to air, soil, ground water, or surface water that could threaten human health
or the environment [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
4. A copy of this Approval, including any Application Appendices incorporated into the
Approval, must be maintained at the Facility [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §
761.75(c)(3)(ii)].
5. Any notification, report, or other submittal of information to U.S. EPA required under
this Approval must be submitted in writing via certified mail or electronically to the
following address:
Manager, RCRA Corrective Action, Permits and PCB Section
Land, Chemicals, and Redevelopment Division
U.S. EPA Region 10
1200 Sixth Avenue, Suite 155, MS 15-H04
Seattle, WA 98101
Direct: 206-553-0955
Main: 206-553-1200
epa-seattle@epa.gov
A Responsible Official for CWMNW must certify any written information submitted to
U.S. EPA required under this Approval by using the certification statement found at 40
C.F.R. § 761.3.
6. All terms and/or conditions of this Approval are severable. If any provision of this
Approval is determined to be invalid, CWMNW must comply with all remaining
conditions.
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7. CWMNW is required to comply with all relevant TSCA requirements, whether or not
they are included in this Approval.
8. CWMNW must provide upon request any information that U.S. EPA deems necessary to
determine if cause exists for modification, suspension, revocation, or termination of this
Approval. Failure to provide the above-mentioned information within five (5) working
days of the request will be deemed a violation of this Approval unless U.S. EPA
determines that additional time is warranted.
9. CWMNW must not avoid any otherwise applicable provision of this Approval or TSCA
by diluting PCBs, unless specifically allowed by the TSCA regulations [40 C.F.R. §
761.1(b)(5); 40 C.F.R. §761.20(c)(2)(iii)].
10. Attachment la, Application Appendix H, Closure/ Post-Closure Plan, dated December 1,
2022 (the "Closure/ Post-Closure Plan"), as supplemented by the additional information
included in Attachment lb, Application Section 3.36, is incorporated as a requirement of
this Approval. CWMNW must ensure the Closure/ Post-Closure Plan remains consistent
with current operations and maintain the Plan until closure commences. The Plan must
identify the steps necessary to close each unit in a manner that eliminates the potential
for post-closure release of PCBs that may present an unreasonable risk to human health
and the environment. The Closure/ Post-Closure Plan must, at a minimum, meet the
requirements of 40 C.F.R. § 761.65(e)(l)(i)-(vii) for each PCB Unit contained in this
Approval. The Closure/ Post-Closure Plan must also address post-closure care of all
PCB landfill cells, plus any other units that have PCB waste remaining in place after
closure, and must identify the steps necessary to eliminate the potential for releases of
PCBs into the environment during the post-closure care period [40 C.F.R. §761.65(e), 40
C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
11. Attachment 2, Application Appendix A, PCB Operations Plan, dated May 12, 2023, is
incorporated as a requirement of this Approval. CWMNW must operate and maintain the
Facility consistent with the PCB Operations Plan, except to the extent the PCB
Operations Plan requirements are inconsistent with the requirements in 40 C.F.R. Part
761 or conditions of this Approval, in which case the requirements in 40 C.F.R. Part 761
and this Approval apply [40 C.F.R. §761.75(b)(8)],
C. General Waste Management
1. CWMNW must not mix PCBs and any substances that may be incompatible with PCBs.
CWMNW must implement precautionary procedures for the management of ignitable,
reactive, and incompatible wastes [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §
761.75(b)(8)(i) and (iii); 40 C.F.R. §761.75(c)(3)(ii)].
2. CWMNW may not dilute or otherwise change the concentration of PCB waste to meet
any PCB concentration-based limit on storage, treatment, or disposal [40 C.F.R.
§761.20(c)(2)(iii)].
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D. Personnel Training
1. CWMNW must provide initial and annual training to all Facility personnel that teaches
PCB waste management, inspection, sampling, safety, and emergency response
procedures relevant to the positions in which they are employed [40 C.F.R.
§761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
2. CWMNW must maintain for at least three (3) years from the date the record was created,
and make available to U.S. EPA upon request, records documenting employee training
which includes at a minimum [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)]:
a. The job title for each position at the facility related to hazardous waste management,
and the name of the employee filling each job;
b. A written job description for each position employed at or regularly present at
CWMNW. This description must include the requisite skill, education, or other
qualifications, and duties of employees assigned to each position;
c. A written description of the type and amount of both introductory and continuing
training that will be given to each person filling a position; and
d. Records that document completion of required training or job experience by facility
personnel.
E. Health and Safety Requirements
1. CWMNW must conduct all PCB related work at the Facility in accordance with 29
C.F.R. § 1910.120, including any future amendments to that rule [40 C.F.R.
§761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
2. CWMNW must ensure that personnel handling PCB waste use appropriate personal
protective equipment [40 C.F.R. §761.60(b)(8); 40 C.F.R. §761.79(e)(2)],
F. Emergency Preparedness and Spill Cleanup
1. CWMNW must clean up and adequately address all spills of PCBs at the Facility in
accordance with 40 C.F.R. Part 761, Subpart G - PCB Spill Cleanup Policy [40 C.F.R.
§761.61; 40 C.F.R. §761.79],
2. CWMNW must conduct emergency response and spill prevention and cleanup activities
at the Facility in accordance with Attachment 3, Application Appendix G, Contingency
Plan [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
3. CWMNW must either verbally report to U.S. EPA or provide an email notice to U.S.
EPA of any incident involving PCBs that requires implementation of the Contingency
Plan, Attachment 3, Application Appendix G. The verbal or email notification must be
made/sent to the person identified in Condition IV.B.5 of this Approval as soon as
possible after CWMNW becomes aware of the incident, but no later than 24 hours after
the incident [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
4. CWMNW must submit a written report to U.S. EPA that provides details on any incident
involving PCBs that requires implementation of the Contingency Plan, Attachment 3,
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Application Appendix G. The written report must be submitted via certified mail or
electronically to the person identified in Condition IV.B.5 of this Approval.
The written report must be submitted to U.S. EPA within fifteen (15) days of the
incident and include, at a minimum, the following information [40 C.F.R.
§761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)]:
a. Date, time, and type of incident (e.g., fire, explosion, chemical release);
b. Name and quantity of material(s) involved;
c. The extent of injuries, if any;
d. Response actions taken;
e. An assessment of actual or potential hazards to human health or the environment,
where this is applicable;
f. Estimated quantity and disposition of recovered material that resulted from the
incident; and
g. Steps taken to prevent reoccurrence.
5. CWMNW must certify in writing to U.S. EPA compliance with the following
requirements before operations are resumed in the areas affected by any incident
involving PCBs that requires implementation of the Contingency Plan, Attachment 3,
Application Appendix G [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)]:
a. All emergency equipment listed in the Contingency Plan, Attachment 3, Application
Appendix G, is cleaned and fit for usage after the incident is addressed. CWMNW
may substitute equivalent emergency equipment in the affected area while repairing,
replacing, or recharging used emergency response equipment; and
b. Corrective measures have been implemented to prevent reoccurrence of the incident.
6. If CWMNW believes, or has reason to believe, that PCBs equal to or greater than one
pound have been released into the environment, CWMNW must immediately notify the
National Response Center by telephone at (800) 424-8802 within 24 hours after
discovery. A full investigation into the cause of the incident and a detailed report must
be included in the daily operation records. A copy of this report describing the incident
must be submitted to the U.S. EPA person identified in Condition IV.B.5 within fifteen
(15) days after the incident [40 C.F.R. Part 302, 40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R.
§761.75(c)(3)(ii)].
7. If CWMNW believes, or has reason to believe, that PCBs equal to or greater than 10
pounds have been released into the environment, CWMNW must either verbally notify
U.S. EPA or provide an email notice to U.S. EPA within 24 hours after discovery. The
notification must be made/sent to the person specified in Condition IV.B.5 of this
Approval. A full investigation into the cause of the incident and a detailed report must be
included in the Facility daily operation records. A copy of this report describing the
incident must be submitted to the person specified in Condition IV.B.5 of this Approval
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within fifteen (15) days after the incident [40 C.F.R. §761.125(a)(l)(iii); 40 C.F.R.
§761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
8. CWMNW must maintain a copy of Attachment 3, Application Appendix G,
Contingency Plan, at the Facility [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R.
§761.75(c)(3)(ii)].
9. CWMNW must post a dated list of emergency contacts, telephone numbers, and
designated emergency exits in prominent locations throughout the Facility. The list must
be updated annually no later than June 30th of every year or within thirty (30) days of
any change in emergency contacts or telephone numbers [40 C.F.R. §761.65(d)(4)(iv);
40 C.F.R. §761.75(c)(3)(ii)].
10. CWMNW must, at a minimum, monthly test and maintain the alarm system, facility
communications systems, fire extinguishing systems, spills kits, spill control equipment,
and personnel and equipment decontamination equipment as recommended by the
manufacturer to assure its proper operation in time of emergency. If any of the
equipment specified above was manufactured by CWMNW, CWMNW must establish
and follow a testing and maintenance plan for those manufactured items adequate to
ensure the efficacy of the equipment during an emergency [40 C.F.R. §761.65(d)(4)(iv);
40 C.F.R. §761.75(c)(3)(ii)].
11. Whenever PCBs are being poured, mixed, or otherwise handled, CWMNW must ensure
that all personnel involved in the operation will have immediate access to an internal
alarm or emergency communication device, either directly or through visual or voice
contact with another employee [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R.
§761.75(c)(3)(ii)].
12. At all times, there must be at least one employee either at the Facility or on call who has
[40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)]:
a. The responsibility for coordinating all emergency response measures;
b. The authority to commit the resources needed to carry out the Attachment 3,
Application Appendix G, Contingency Plan; and
c. Immediate access to the entire Facility and to a communication device such as a
telephone, cellular phone, or hand-held two-way radio immediately available at the
scene of operation capable of summoning external emergency assistance.
13. CWMNW must review and amend, as necessary, Attachment 3, Application Appendix
G, Contingency Plan, within thirty (30) days of the following events and shall submit the
revised Contingency Plan for approval to the person identified in Condition IV.B.5 of
this Approval [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)]:
a. Failure of the Plan in an emergency;
b. Changes in the Facility's design, construction, operation, maintenance, or other
circumstances that materially increase the potential for fires, explosions, or releases
of PCBs or hazardous constituents, or other response necessary in an emergency;
c. A change to the list of emergency coordinators;
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d. A change to the list of emergency equipment;
e. When information available to CWMNW otherwise indicates that revision is
warranted; or
f. When U.S. EPA determines that a revision of this Plan is necessary and notifies
CWMNW accordingly.
14. If at any time U.S. EPA determines that PCB operations at the Facility authorized by this
Approval are creating a situation of imminent hazard, U.S. EPA will notify CWMNW as
to the steps required to mitigate and/or prevent the hazard. Such steps must be taken by
the date provided in such notice [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R.
§761.75(c)(3)(ii)].
G. Entry and Agency Inspection
1. U.S. EPA officials and designated representatives of U.S. EPA, upon presentation of
credentials, must be permitted access to any area of the Facility at all reasonable times
during regular business hours: (1) to determine compliance with applicable statutes,
applicable regulations, and the conditions of this Approval; (2) for the purpose of
inspection, sampling, or monitoring; and (3) for any other purpose allowed by law [40
C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
2. CWMNW, upon request by U.S. EPA, must provide copies of any record maintained by
the Facility pursuant to this Approval within seven (7) days of such request [40 C.F.R.
§761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
H. General Inspection Requirements
1. CWMNW must conduct inspections of the Facility according to the procedures and
schedule contained in Attachment 4, Application Appendix F, Inspection Plan, Table 3-1
[40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
2. CWMNW must generate records documenting the equipment inspected, inspection
findings, any corrective action taken, and any general maintenance conducted on Facility
equipment. All such records must be maintained at the Facility and made available to
U.S. EPA upon request [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
3. CWMNW must evaluate and address all deficiencies identified during the inspections.
Any deficiency identified must be repaired, replaced, cleaned up, or otherwise corrected
within 48 hours after discovery [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R.
§761.75(c)(3)(ii)].
I. Security
1. CWMNW must operate and maintain the security systems at the Facility to prevent the
unauthorized entry of persons, livestock, or wildlife into the active areas of the Facility
[40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
J. Closure Cost Estimate
1. CWMNW comply with closure cost estimate requirements in 40 C.F.R.§ 761.65(f).
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K. Post-Closure Cost Estimate
1. CWMNW must maintain a detailed estimate, in current dollars, of the cost of post-
closure care for the operating and closed landfills in accordance with the Closure/ Post-
Closure Plan. Post-closure for each landfill unit begins after final closure is certified
complete and continues for thirty (30) years after the date of closure certification for
each landfill unit. The post-closure cost estimate must be in writing, be certified by the
person preparing it (using the certification defined in 40 C.F.R § 761.3) and comply with
the following criteria [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)]:
a. The post-closure cost estimate must be based on the costs to CWMNW of hiring a
third party to conduct post-closure care activities, and the third party must not be
either a corporate parent or subsidiary of the Owner or Operator, or member in joint
ownership of the Facility.
2. CWMNW must annually adjust the post-closure cost estimate for inflation within sixty
(60) days prior to October 15 of each calendar year. The adjustment may be made by
recalculating the maximum costs of post-closure in current dollars, or by using an
inflation factor derived from the most recent Implicit Price Deflator for Gross National
Product published by the U.S. Department of Commerce in its Survey of Current
Business. The Implicit Price Deflator for Gross National Product is included in a
monthly publication titled Economic Indicators, which is available from the
Superintendent of Documents, Government Printing Office, Washington, DC 20402.
The inflation factor used in the latter method is the result of dividing the latest published
annual Deflator by the Deflator for the previous year. The adjustment to the post-closure
cost estimate is then made by multiplying the most recent post-closure cost estimate by
the latest inflation factor [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75 (c)(3)(ii)].
3. CWMNW must revise and resubmit to U.S. EPA the post-closure cost estimate within
thirty (30) days of any U.S. EPA approval of a modification to the Closure/ Post-Closure
Plan that increases the cost of post-closure care. The revised cost estimate shall be
adjusted for inflation at that time [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R.
§761.75(c)(3)(ii)].
4. CWMNW must keep at the Facility during its operating life the most recent post-closure
cost estimate, including any adjustments resulting from inflation or from modifications
to the Closure/Post-Closure Plan [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R.
§761.75(c)(3)(ii)].
L. Financial Assurance for Closure and Post-Closure
1. CWMNW must always maintain adequate financial assurance for each PCB Unit at the
Facility. The level of financial assurance funding must always be greater than or equal to
the total cost estimate for closure and post-closure care of all PCB Units [40 C.F.R.
§761.65(g); 40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
2. CWMNW must annually submit written documentation to U.S. EPA of continued
financial assurance for the PCB Units at the Facility. The documentation must include,
but not be limited to, the current closure and post-closure cost estimates for the PCB
Units and the level of funding for closure and post-closure. The documentation must be
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submitted to the person identified in Condition IV.B.5 of this Approval by January 15 of
each calendar year [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
3. A modification to a unit storing PCB waste that increases the maximum storage capacity
indicated in the Approval requires that a new financial assurance mechanism be
established or an existing one be amended. When such a modification occurs, CWMNW
must notify U.S. EPA in writing no later than thirty (30) days from the completion of the
modification. The new or revised financial assurance mechanism must be established
and activated no later than thirty (30) days after U.S. EPA is notified of the completion
of the modification, but prior to the use of the modified portion of the Facility [40 C.F.R.
§761.65(g)(9)],
4. CWMNW must notify the person identified in Condition IV.B.5 of this Approval by
certified mail and electronically of the commencement of a voluntary or involuntary
proceeding under Title 11 (Bankruptcy), U.S. Code, naming CWMNW or its parent
company as debtor, within ten (10) days after commencement of the proceeding [40
C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)]
5. If at any time U.S. EPA determines that under the terms of this Approval the existing
financial assurance is inadequate, U.S. EPA will notify CWMNW in writing. CWMNW
must establish a new financial assurance mechanism or amend the existing mechanism
and provide U.S. EPA with documentation of the revised financial mechanism within
sixty (60) days of the written notification unless another timeframe is specified in the
notification [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)]
M. Liability Insurance
1. CWMNW must maintain liability coverage for sudden and non-sudden accidental
occurrences consistent with the requirements of 40 C.F.R. § 264.147 [40 C.F.R.
§761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
2. CWMNW must notify U.S. EPA in writing at least thirty (30) days prior to making any
changes to the liability insurance coverage. The notification must describe the nature of
the changes and rationale for making them. This term may not be construed to allow
liability coverage below the limits described in Condition IV.M. 1 of this Approval [40
C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
3. CWMNW must keep at the Facility during its operating life a copy of the current
liability coverage for sudden and non-sudden accidental occurrences [40 C.F.R.
§761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
N. Recordkeeping and Reporting
1. CWMNW must comply with all recordkeeping and reporting requirements specified in
the PCB regulations at 40 C.F.R. §§ 761.180(b); 180(d); 180(f); 761.205(f); 761.207;
761.208; 761.209; 761.210; 761.213; 761.214; 761.215; 761.216; 761.217; 761.218; and
761.219.
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2. All records required under this Approval must be maintained onsite either in paper form
written in ink or in an electronic reporting system for the duration the Facility is
operational, and for at least twenty (20) years following cessation of operations. Any
modification or correction of the records must be initialed and dated by the responsible
official [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761 75(c)(3)(ii); 40 C.F.R.
§§761.180(b) and (d)].
3. At the completion of any cleanup required by the Approval, CWMNW must develop and
maintain records of the cleanup including at a minimum [40 C.F.R. §761.65(d)(4)(iv);
40 C.F.R. §761.75(c)(3)(ii)]:
a. Identification of the source of the contamination;
b. Date and time contamination was discovered;
c. Date and time cleanup was completed;
d. A brief description of contaminated area;
e. Pre-cleanup and post-cleanup sampling data used to define boundaries of
contamination and a brief description of the sampling methodology used to establish
contaminated boundaries;
f. Amount of waste cleanup material generated;
g. Steps taken to prevent reoccurrence of the incident;
h. Date of notification and report to U.S. EPA; and
i. A certification statement signed by CWMNW personnel stating that the
decontamination levels referenced in Condition IV.F.l have been achieved and that
the information contained in the record is true to the best of his/her knowledge.
4. CWMNW must notify U.S. EPA in writing if any unusual occurrences should happen
that are not normal to the operation of the Facility as hereby authorized, such as
accidents, spills, leaks, uncontrolled discharges, earthquake damage, excessive rain
episodes (e.g., rainfall in excess of a 24-hour, 25-year storm event), fires and/or
explosions. The written notification must be submitted to U.S. EPA within three (3)
calendar days of the incident and include a description of what occurred and CWMNW's
response. The notification must be submitted via certified mail or electronically to the
person identified in Condition IV.B.5 of this Approval [40 C.F.R. §761.65(d)(4)(iv); 40
C.F.R. §761.75(c)(3)(ii)].
5. CWMNW must notify U.S. EPA in writing when 80, 90, and 95 percent of the disposal
capacity is reached for Landfill L-14, Cell 5. Each notification must be submitted via
certified mail or electronically to the person identified in Condition IV.B.5 of this
Approval [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
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V. Conditions for Storage, Processing, and Treatment of PCBs
This section sets forth applicable requirements for the storage for disposal of PCBs at
concentrations of 50 parts per million (ppm) or greater, PCB Items with PCB concentrations of
50 ppm or greater, and PCB Remediation Waste with an as-found concentration of 50 ppm or
greater. This section also applies to processing for disposal and treatment for disposal of PCB-
containing waste.
A. Operational and Regulatory Requirements for Storage
1. CWMNW must at all times comply with the PCB storage requirements contained in 40
C.F.R. § 761.65.
2. Any PCB waste must be disposed of as required by 40 C.F.R. Part 761 Subpart D within
one (1) year from the date of removal from service for disposal unless U.S. EPA has
approved an extension per 40 C.F.R. § 761.65(a)(2)-(3).
3. CWMNW may temporarily store PCB Items or PCB containers for up to thirty (30) days
in an area that does not comply with the requirements of 40 C.F.R. § 761.65(b) provided
that all requirements applicable to the temporary storage area are satisfied and spills of
PCBs are cleaned up in accordance with 40 C.F.R. Part 761, Subpart G [40 C.F.R.
§761.65(c)(1)],
4. CWMNW must implement a system to track how long PCB wastes have been in each
storage unit to ensure that the thirty (30)-day and one-year time limits are not exceeded.
Any exceedances of the time limits are a violation of this Approval and must be recorded
and reported to U.S. EPA as an unusual circumstance specified in Condition IV.N.4 of
this Approval unless U.S. EPA has approved an additional extension under 40 C.F.R. §
761.65(a)(2)-(3) [40 C.F.R. §761.65(c)(8)],
5. Storage of PCB liquids in tanks is not authorized by this Approval. CWMNW must not
store liquid PCB wastes in tanks or stationary containers at the facility.
B. PCB Waste Storage in Containers
1. CWMNW must operate and maintain a database and barcode system to track the
volumes and locations of containerized PCB wastes throughout the Facility [40 C.F.R.
§761.180(b)(l)-(5)].
2. CWMNW must maintain a 2.5-foot or greater aisle space between all containers and
items or rows of all containers and items stored in the PCB storage areas [40 C.F.R.
§761.65(d)(4)(iv)].
3. CWMNW must store containers to allow for unobstructed access by personnel, fire
protection equipment, and decontamination equipment [40 C.F.R. §761.65(d)(4)(iv)].
4. Containers holding PCB waste must be on a single tier and not be stacked to ensure
stability and safe handling. Bulk intermodal containers can be stored with a minimum of
2.5 feet between them and may be stacked up to 3 high if the stack is stable, there is no
apparent hazard of such containers tipping or falling and provided that inspection of such
containers is not inhibited [40 C.F.R. §761.65(d)(4)(iv)].
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5. CWMNW must store containers placed in storage areas on pallets or other types of
material handing platforms [40 C.F.R. §761.65(d)(4)(iv)].
6. CWMNW must not remove any item of movable equipment from an approved storage
area that is used for handling PCBs and PCB Items and that comes into direct contact
with PCBs (e.g., accidental PCB release from a container or item that contaminates a
forklift) unless it has been first decontaminated as specified in 40 C.F.R. § 761.79 [40
C.F.R. §761.65(c)(4)],
7. CWMNW must comply with the requirements for PCB containers specified in 40 C.F.R.
§ 761.65(c)(6).
8. CWMNW must comply with the marking requirements set forth in 40 C.F.R. §§ 761.40,
761.45, 761.65(c)(3), and 761.65(c)(8) for all PCB Containers, PCB Items and PCB
storage areas.
C. Approved PCB Treatment Units
1. CWMNW is authorized, subject to the conditions of this Approval, to process PCB-
containing wastes for disposal and treat PCB-containing wastes for disposal by the
methods in each unit shown in Table 2 below [40 C.F.R. §761.20(c)(2)(ii)].
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Table 2
Units and Descriptions for Processing and Treatment of PCB-Containing Wastes
Location of
PCB Unit
Processing and Treatment Unit
Description
Type of Processing and Treatment
Allowed
S-2
Containers in storage
Draining/flushing, repacking, bulking
Transfer of PCB Liquids
Solidification
S-6
Macro-encapsulation vault
Solidification
Macro-encapsulation
S-10
Macro-encapsulation vault
Solidification
Macro-encapsulation
S-ll
Indoor storage unit
Transfer of PCB liquids
S-12
Macro-encapsulation vault
Solidification
Macro-encapsulation
B-5
Macro-encapsulation vault
Draining/flushing, repacking, bulking
Transfer of PCB liquids
Solidification
Stabilization
Macro-encapsulation
B-6
Macro-encapsulation vault
Draining/flushing, repacking, bulking
Transfer of PCB liquids
Solidification
Stabilization
Macro-encapsulation
B-7
Macro-encapsulation vault
Draining/flushing, repacking, bulking
Solidification/ stabilization
Transfer of PCB liquids
Solidification
Stabilization
Macro-encapsulation
B-8
Macro-encapsulation vault
Draining/flushing, repacking, bulking
Transfer of PCB liquids
Solidification
Stabilization
Macro-encapsulation
OSU-1
2 open partially below ground
carbon steel bins;
Macro-encapsulation vault
Solidification
Stabilization
Micro-encapsulation
Macro-encapsulation
Oxidation
Precipitation
Deactivation
Neutralization
Chemical Oxidation
Adsorption
OSU-2
2 open outdoor partially below
ground carbon steel bins;
Macro-encapsulation vault
Solidification
Stabilization
Micro-encapsulation
Macro-encapsulation
Oxidation
Precipitation
Deactivation
Neutralization
Chemical Oxidation
Adsorption
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Location of
PCB Unit
Processing and Treatment Unit
Description
Type of Processing and Treatment
Allowed
OSU-3
2 open outdoor partially below
ground carbon steel bins;
Macro-encapsulation vault
Solidification
Stabilization
Micro-encapsulation
Macro-encapsulation
Oxidation
Precipitation
Deactivation
Neutralization
Chemical Oxidation
Adsorption
OSU-4
2 open outdoor partially below
ground carbon steel bins;
Macro-encapsulation vault
Solidification
Stabilization
Micro-encapsulation
Macro-encapsulation
Oxidation
Precipitation
Deactivation
Neutralization
Chemical Oxidation
Adsorption
OSU-5
2 open outdoor partially below
ground carbon steel bins;
Macro-encapsulation vault
Solidification
Stabilization
Micro-encapsulation
Macro-encapsulation
Oxidation
Precipitation
Deactivation
Neutralization
Chemical Oxidation
Adsorption
OSU-6
2 open outdoor partially below
ground carbon steel bins;
Macro-encapsulation vault
Solidification
Stabilization
Micro-encapsulation
Macro-encapsulation
Oxidation
Precipitation
Deactivation
Neutralization
Chemical Oxidation
Adsorption
SU-B8
Indoor tipping floor with 4
mixing/staging units;
Macro-encapsulation vault
Solidification
Stabilization
Micro-encapsulation
Macro-encapsulation
Oxidation
Precipitation
Neutralization
Chemical Oxidation
Adsorption
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D. Processing and Treatment for Disposal of PCB-Containing Waste
1. CWMNW must maintain documentation of drain and flush activities for transformer,
capacitors, electrical equipment, and other PCB articles, including the following
information [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)]:
a. Generator name;
b. Date of removal from service;
c. Date the PCB article was received;
d. Unique load number;
e. Amount of oil drained from the article;
f. Amount of diesel or alternate flushing solution in accordance with 40 C.F.R. §
761.60(b)(l)(i)(B) used to fill the article;
g. Length of time the article was filled with flushing solution (minimum 18 hours); and
h. Drum number where the drained oil will be stored.
2. CWMNW is authorized to stabilize and/or solidify PCB wastes for disposal except for
the following:
a. Liquids with concentrations of PCBs greater than 50 ppm except for liquids from
incidental sources as classified in 40 C.F.R. § 761.60(a)(3) [40 C.F.R. §761.60(a)];
b. Liquid ignitable wastes, which are wastes that have a flash point less than 60 °C (140
°F) as determined by the following method or an equivalent method: Flash point of
liquids shall be determined by a Pensky-Martens Closed Cup Tester, using the
protocol specified in ASTM D93-09, or the Setaflash Closed Tester using the
protocol specified in ASTM D3278-89 (all standards incorporated by reference in 40
C.F.R. § 761.19) [40 C.F.R. §761.60(a)(3)(ii); 40 C.F.R. §761.75(b)(8)(iii)];
c. Soils with concentrations of halogenated organic compounds, including PCBs, greater
than 1000 ppm that are also determined to be hazardous by toxicity characteristic for
metals under RCRA [40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii); 40
C.F.R. §268.32(b)(l)(i) and (2)(i); 65 FR 81373-81381]; and
d. Any other PCB waste with a total PCB concentration greater than 50 ppm except
PCB bulk product waste and PCB remediation waste [40 C.F.R. §761.65(d)(4)(iv); 40
C.F.R. §761.75(c)(3)(ii)].
3. CWMNW is authorized to drain and flush PCB-containing transformers and other PCB
Items. The liquid PCBs and solvent containing PCBs must be disposed in accordance
with 40 C.F.R. § 761.60(a) [40 C.F.R. §761.60(b)(l)(i)(B)].
4. CWMNW may store non-leaking and structurally undamaged PCB Large High Voltage
Capacitors and PCB-Contaminated Electrical Equipment that have not been drained of
free-flowing dielectric fluid, subject to the requirements of 40 C.F.R. § 761.65(c)(2) [40
C.F.R. §761.65(c)(2)],
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5. Thermal treatment of any PCB-containing waste is prohibited [40 C.F.R. §761.60(e)],
E. Operational and Regulatory Requirements for Processing and Treatment
1. CWMNW must prevent uncontrolled reactions during treatment operations [40 C.F.R.
§761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
2. CWMNW must take all appropriate measures to minimize dust emissions during outdoor
solidification activities, including but not limited to, using non-hazardous liquids for dust
suppression [40 C.F.R. §761.60(b)(8); 40 C.F.R. §761.79(e); 40 C.F.R.
§761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
3. CWMNW must operate at least one baghouse to control dust emissions anytime PCB
wastes are being processed within indoor PCB Units. CWMNW must test baghouse dust
for PCBs prior to land disposal and manage baghouse dust pursuant to any applicable
requirements under 40 C.F.R. Part 761 and this Approval [40 C.F.R. §761.60(b)(8); 40
C.F.R. §761.79(e); 40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
4. CWMNW must not remove any excavator or other equipment that comes into direct
contact with PCBs to outside of the Facility unless it has first been decontaminated as
specified in 40 C.F.R. §761.79 [40 C.F.R. §761.65(c)(4), 40 C.F.R. §761.65(d)(4)(iv); 40
C.F.R. §761.75(c)(3)(ii)].
5. CWMNW must decontaminate any equipment used to conduct treatment which contacts
PCBs in accordance with the self-implementing procedures of 40 C.F.R. § 761.79(c) and
must meet the decontamination standards of 40 C.F.R. § 761.79(b) before the equipment
is used on non-PCB containing wastes [40 C.F.R. §§761.79(b) and (c)].
F. PCB Sampling of Treatment Units
1. CWMNW must conduct quarterly sampling of units B-5, B-6, B-7, B-8, and SU-B8
using a standard wipe test as defined in 40 C.F.R. § 761.123. The sampling must include
taking a minimum of three wipe samples for PCB analysis from the floor areas in
proximity to the mixing/ staging units and tipping floor [40 C.F.R. §761.30(p); 40 C.F.R.
§761.30(u); 40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii); 40 C.F.R.
§§761.79(b)(3)(i)(A) and (b)(4)],
2. If wipe samples described in Condition V.F.I show PCB concentrations greater than 10
micrograms ([j,g)/100 square centimeters (cm2), CWMNW must fully delineate the
extent of PCB contamination and initiate the cleanup process in accordance with Section
IV.F, Emergency Preparedness and Spill Cleanup, of this Approval. The sampling
results and any follow-up cleanup must be reported to U.S. EPA as a circumstance
specified in Condition IV.N.4 of this Approval [40 C.F.R. §761.30(p); 40 C.F.R.
§761.30(u); 40 C.F.R. §761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii); 40 C.F.R.
§§761.79(b)(3)(i)(A) and (b)(4)],
G. Inspection Requirements for PCB Storage, Processing, and Treatment Units
1. CWMNW must check all PCB Items in storage for leaks at least once every thirty (30)
days. Any leaking PCB Item and its contents must be transferred immediately to a
properly marked non-leaking container. Any spilled or leaked materials must be
immediately cleaned up and the materials and residues containing PCBs shall be
disposed of in accordance with 40 C.F.R. § 761.61. Records of inspections, maintenance,
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cleanup, and disposal must be maintained in accordance with 40 C.F.R. § 761.180(a) and
(b) [40 C.F.R. §761.65(c)(5)],
H. Closure of Storage and Treatment Units
1. CWMNW must notify U.S. EPA in writing at least sixty (60) days prior to the date on
which final closure of its PCB storage, processing, or treatment facility, or any section of
it, is expected to begin. If needed at the time of closure, CWMNW must also include in
the notification a request to modify the Closure/ Post-Closure Plan, pursuant to the
modification process under Section VILA of this Approval [40 C.F.R. §761.65(e)(6)(i)].
2. The date CWMNW expects to begin closure shall be no later than thirty (30) days after
the date on which the Facility, or any section of it, receives its final quantities of PCB
waste for storage. The notification must be submitted via certified mail or electronically
to the person identified in Condition IV.B.5 of this Approval [40 C.F.R.
§761.65(e)(6)(ii)].
3. After receiving the final quantity of PCB waste, CWMNW must remove all PCB waste
from the storage units within ninety (90) days and complete closure of storage units
within 180 days unless EPA approves an extension [40 C.F.R. §761.65(e)(6)(iii); 40
C.F.R. §761.65(e)(6)(iv)].
4. CWMNW must conduct final closure activities (including PCB analysis) for the PCB
storage, processing, and treatment units in accordance with Application Appendix H,
Closure/ Post-Closure Plan, and Application Sections 3.36-3.37, which are incorporated
into this Approval as Attachment la and Attachment lb, respectively.
5. As part of the closure, soils beneath the foundation and surrounding each of the PCB
storage, processing, and treatment units must be sampled for PCBs in accordance with
SubpartN of 40 C.F.R. Part 761; 40 C.F.R. § 761.65; and 40 C.F.R. § 761.286. If PCBs
are detected in the soil above 1 ppm (or as otherwise specified by U.S. EPA) total PCBs,
the nature and extent of PCB contamination in the area must be investigated and
determined, and any soils with PCB concentrations above 1 ppm (or as otherwise
specified by U.S. EPA) must be excavated and disposed of in a TSCA approved landfill
cell. The remaining soils must then be resampled to verify that they are no longer
contaminated above the 1 ppm (or as otherwise specified by U.S. EPA) total PCB limit.
CWMNW must use the most current version of U.S. EPA's SW-846 Method 8082 for
PCB analysis and Method 3540C for Soxhlet Extraction or an alternative method
approved under 40 C.F.R. § 761.61(c) or validated under Subpart Q of 40 C.F.R. Part
761 [40 C.F.R. §761.61(a)(4)(i)(A); 40 C.F.R. §761.61(c); C.F.R. §761.65(e); 40 C.F.R.
§761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
6. During the closure period, CWMNW must dispose all contaminated system component
equipment, structures, and soils in accordance with the disposal requirements of 40
C.F.R. Part 761 Subpart D, or, if applicable, decontaminate in accordance with the levels
specified in the PCB Spills Cleanup Policy under 40 C.F.R. Part 761 Subpart G. If PCB
waste is removed from the Facility during closure, CWMNW becomes a generator of
PCB waste subject to the generator requirements of 40 C.F.R. Part 761 Subparts J and K
[40 C.F.R. §761.65(e)(7)],
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7. Within sixty (60) days of completion of closure of the Facility for the storage of PCB
waste, CWMNW must submit to U.S. EPA, by certified mail, a certification that the
PCB Units for storage in the Facility have been closed in accordance with the approved
closure plan. The certification must be signed by CWMNW and by an independent
registered professional engineer [40 C.F.R. §761.65(e)(8)],
VI. Conditions for Landfill Disposal of PCBs
A. Approved Landfill Units and Maximum Disposal Capacities
1. CWMNW must at all times comply with the landfill and disposal requirements
contained in 40 C.F.R. §§ 761.60 and 761.75.
2. This Approval authorizes, subject to the conditions of this Approval, the Landfill L-14
Cells 1-5 at the CWMNW Arlington Facility to receive PCB wastes for disposal [40
C.F.R. §761.75],
3. The maximum disposal capacity of Landfill L-14 Cells 1-5 combined must not exceed
6.3 million cubic yards inclusive of waste and daily cover [40 C.F.R. §761.75(c)(3)(ii)].
4. CWMNW must include the amount of remaining disposal capacity for each of the
operating landfills in the annual report required by 40 C.F.R § 761.180(b) [40 C.F.R.
§761.75(c)(3)(ii)].
5. CWMNW must construct Landfill L-14, Cell 5 and maintain Landfill L-14 in
accordance with Application Section 2 and Attachment 5, Application Appendix L,
Landfill Design, Operations, and Response Plan [40 C.F.R. §§761.75(b)(1), (b)(2), and
(c)(3)(ii)].
B. PCB Wastes Authorized for Disposal
1. CWMNW is authorized, subject to the conditions of this Approval, to dispose of the
following non-liquid PCB wastes in the L-14 landfill, Cells 1-4, and to dispose of the
following non-liquid PCB wastes in the L-14 landfill, Cell 5 upon final construction
consistent with the requirements of Condition VI.A. 5:
a. PCB Transformers [as defined in 40 C.F.R. § 761.3 and as required in 40 C.F.R §
761.60(b)(l)(i)]. Disposal is limited to PCB Transformers that arrive at the Facility
drained and flushed and containing no free-flowing liquids. CWMNW must verify
certification from the generator that the PCB transformer has been drained/flushed in
accordance with 40 C.F.R. § 761.60(b)(l)(i)(B).
a. PCB-Contaminated Electrical Equipment [as defined in 40 C.F.R. § 761.3 and as
required in 40 C.F.R. § 761.60(b)], Disposal is limited to PCB-Contaminated
Electrical Equipment that contained PCBs liquids at concentrations >50 ppm and
<500 ppm. Such equipment except large capacitors must be drained of all free-
flowing liquids prior to landfill disposal. The removed liquid PCBs must be disposed
in accordance with the incineration or other disposal requirements under 40 C.F.R. §
761.60(a). PCB capacitors with a PCB concentration <500 ppm may be disposed in
the landfill without draining.
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b. PCB Articles [as defined in 40 C.F.R. § 761.3 and as required in 40 C.F.R. §
761.60(b)(6)], PCB Articles must be drained of all free-flowing liquids, and the
liquids must be disposed in accordance with 40 C.F.R. §761.60(a).
c. Non-liquid PCBs [as defined in 40 C.F.R. § 761.3], Disposal is limited to non-liquid
PCBs.
d. PCB Containers [as defined in 40 C.F.R. § 761.3 and as required in 40 C.F.R. §
761.60(c)(1)], Disposal is limited to:
(1) PCB containers that have been fully drained of any liquids. The removed PCB
liquids must be disposed in accordance with the incineration or other disposal
requirements under 40 C.F.R. §761.60(a).
(2) PCB Containers containing liquids with PCB concentrations <500 ppm from
incidental sources such as from precipitation, condensation, leachate, or load
separation, provided that each container is surrounded by an amount of inert
sorbent material capable of absorbing all the liquid contents of the container.
e. PCB Remediation Waste [as defined in 40 C.F.R. §761.3], Disposal is limited to
materials meeting the definition of non-liquid PCBs at 40 C.F.R. § 761.3.
f. PCB Bulk Product Waste [as defined in 40 C.F.R. § 761.3],
g. Solidified Liquids Associated with PCB Articles or Nonliquid PCB Waste [40
C.F.R. §761.60(a)(3)], Disposal is limited to liquids that are from incidental sources,
such as precipitation, condensation, leachate, or load separation, and are associated
with PCB Articles or non-liquid PCB waste provided that the liquids are <500 ppm
PCB, are not an ignitable waste, and that, as a result of treatment, meet the definition
of non-liquid PCBs at 40 C.F.R. § 761.3.
C. Disposal Prohibitions
1. The following items are prohibited from disposal:
a. Solid or liquid ignitable wastes including those that are characteristically ignitable
under RCRA as defined in 40 C.F.R. § 261.21(a), are spontaneously combustible, or
have a flash point less than 60 °C (140 °F). The following methods can be used to
determine ignitability: Pensky-Martens Closed-Cup Method for Determining
Ignitability (Method 101 OA), the Setaflash Closed-Cup Method for Determining
Ignitability (Method 1020B), the Ignitability of Solids (Method 1030), Test Method
for Oxidizing Solids (Method 1040), and the Test Method to Determine Substances
Likely to Spontaneously Combust (Method 1050). Any disposal of waste known to be
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ignitable at the time of acceptance, or later determined to be ignitable after disposal,
constitutes a violation of this condition [40 C.F.R. §761.75(b)(8)(iii)];
b. Liquid wastes, as defined by the paint filter liquid test, described in the most current
version of U.S. EPA Publication SW-846, "Test Methods for Evaluating Solid
Wastes," Method 9095 [40 C.F.R. §761.60(a)];
c. Large Capacitors that contain liquids with 500 ppm or greater of PCBs [40 C.F.R.
§761.60(b)(2)(iii)];
d. PCB small capacitors subject to the disposal requirements at 40 C.F.R. §
761.60(b)(2)(iv) [40 C.F.R. §761.60(b)(2)(iv)];
e. Any wastes including, but not limited to, mixed RCRA and TSCA regulated wastes,
that do not meet the land disposal restrictions at 40 C.F.R. Part 268 [40 C.F.R.
§761.75(c)(3)(ii)]; and
f. Any radiologically contaminated waste material, including such waste that is not
regulated under the Atomic Energy Act of 1954, as amended [40 C.F.R.
§761.75(c)(3)(ii)].
D. Landfill Operations and Management of Wastes
1. CWMNW must operate the L-14 landfill to prevent uncontrolled reactions, damage to
the structural integrity of a device holding waste, damage to the landfill, release of
hazardous wastes, or threats to human health and the environment [40 C.F.R.
§761.75(c)(3)(ii)].
2. CWMNW must maintain a permanent and accurate record in the Facility's computerized
systems identifying the specific three-dimensional location of each hazardous waste
type, based on grid coordinates, within each cell of the L-14 landfill [40 C.F.R.
§§761.75(b)(8)(ii) and (iv)].
3. CWMNW must control wind dispersal of particulate matter during landfill operations.
Control methods must include, but are not limited to [40 C.F.R. §761.75(b)(9)(ii)]:
a. Placing daily cover over deposited wastes to control wind dispersal of particulate
matter;
b. Use of non-hazardous, non-RCRA liquids and, as specified in this Approval, leachate
from the landfill to suppress dispersal of particulate matter;
c. Avoidance of unloading dusty materials in high wind conditions;
d. Covering dusty loads promptly; and
e. Other management controls as necessary to control particulate emissions.
4. CWMNW may use untreated leachate from the L-14 landfill for dust suppression only
on the active parts of the landfill in accordance the following conditions [40 C.F.R.
§761.75(c)(3)(ii)]:
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a. Leachate may not be applied to roads.
b. Sprinkler and drip systems must be operated to prevent landfill sideslope erosion.
c. Leachate must not be applied in quantities leading to puddles, saturated soil
conditions, excessive percolation, or runoff; and
d. CWMNW must inspect the leachate application area weekly for evidence of spray
leaving the footprint of the landfill, sideslope application, runoff, or puddling. If any
of these conditions are observed, CWMNW must reduce the amount of leachate
application accordingly.
5. All liquid PCB wastes that are transported off-site for disposal must be sent to a U.S.
EPA-approved PCB disposal facility in accordance with 40 C.F.R. § 761.60(a).
6. CWMNW must maintain surface water controls to prevent run-on onto the landfill, run-
off from the landfill, and surface water discharge from the Facility [40 C.F.R.
§§761.75(b)(3)-(4)].
7. CWMNW must implement, at a minimum, the following controls to assure that PCB-
contaminated material is not carried from the active disposal area [40 C.F.R.
§761.61(a)(4)(i)(B)]:
a. CWMNW must only use equipment designated specifically for use in the active PCB
waste handling area and use proper and efficient operating practices to minimize
exposure of equipment to PCBs;
b. Prior to leaving the landfill cell, equipment that contacts PCB waste must be tested
using wipe samples and decontaminated, if necessary, until analysis of wipe samples
demonstrate that PCB levels are below 10 jag/100 cm2; and
c. Soil from the landfill access ramp must be sampled quarterly. If PCB contamination
is detected, the ramp surface soil must be scraped and resampled until analysis shows
PCB contamination less than 25 ppm.
8. CWMNW must maintain the existing 6-foot-high chain link fencing surrounding the
current operations area. CWMNW will install 6-foot-high chain link fencing in phases
around future PCB Units as they are constructed to prevent unauthorized persons and
animals from entering [40 C.F.R. §761.75(c)(4)],
E. Groundwater Monitoring
1. CWMNW must comply with the groundwater monitoring requirements specified in 40
C.F.R. § 761.75(b)(6)(ii) and (iii).
2. CWMNW must annually analyze groundwater samples for the parameters specified in
40 C.F.R. § 761.75(b)(6)(iii) using methods from the most current version of U.S. EPA
Publication SW-846, "Test Methods for Evaluating Solid Wastes" and from American
Society for Testing and Materials (ASTM) as appropriate [40 C.F.R. §761.75(c)(4)],
3. CWMNW must notify U.S. EPA in writing within seven (7) calendar days of receiving
the analytical report showing, or otherwise becoming aware of, a detection of PCBs in
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any groundwater sample. The report must identify the levels of PCBs detected and the
affected groundwater monitoring well. The notification must be made in accordance
with Condition IV.B.5 of this Approval [40 C.F.R. §761.75(c)(3)(ii)].
4. CWMNW must maintain monitoring wells and not plug, abandon, or decommission any
monitoring wells without first receiving written approval from U.S. EPA [40 C.F.R.
§761.75(c)(3)(ii)].
5. CWMNW must submit to U.S. EPA an annual report that contains the analytical and
field data results from the groundwater monitoring required by this Approval. The
annual groundwater monitoring report must include: (1) the groundwater monitoring
data; (2) data analysis; (3) conclusions that discuss the significance of the current data in
comparison to historical data (trends); (4) identification and discussion of any anomalies
with the data; and (5) historical sampling data contained in the appendices. The data
must be reported in graphical, tabular, and electronic file format as approved by U.S.
EPA [40 C.F.R. §761.75(c)(3)(ii)].
. Leachate Management, Monitoring, Sampling, Disposal, and Reporting
1. CWMNW must comply with the leachate collection and monitoring requirements
specified at 40 C.F.R. § 761.75(b)(7).
2. Management and Monitoring of Leachate:
a. CWMNW must operate the leachate collection and detection systems for Landfill L-
14 to prevent a fluid head on either liner greater than one (1) foot [40 C.F.R.
§761.75(c)(3)(ii)].
b. CWMNW must, during the active life of the landfill, monitor at least on a weekly
basis, the depth of liquid in all of the leachate collection and detection sumps for
Landfill L-14 [40 C.F.R. §761.75(c)(3)(ii)].
c. CWMNW must, within 24 hours of detecting pumpable liquids with a depth of
greater than one (1) foot in any collection or detection sump on Landfill L-14, pump
all of the liquids from each sump [40 C.F.R. §761.75(c)(3)(ii)].
d. CWMNW must notify U.S. EPA in writing within seven (7) calendar days of the fluid
head on either liner exceeding one foot for Landfill L-14. Within thirty (30) days of
the initial notification, CWMNW must submit to U.S. EPA a report that includes the
following information and determinations: (1) an assessment of the possible source of
the liquids (including estimated volumes broken down by source area), (2) results of a
fingerprint, hazardous constituent, or other analysis to identify the sources of liquids
and possible locations of any leaks, and the hazard and mobility of the liquid, (3) an
assessment of the seriousness of the leak in terms of potential for escaping into the
environment, (4) the location, size, and cause of any leak, and (5) a determination
whether waste receipt should cease or be curtailed, whether any waste should be
removed from the unit for inspection, repairs, or for installation of controls, and
whether any other short-term and long-term actions need to be taken to mitigate or
stop any leaks. The written notifications must be submitted via certified mail or
electronically to the person identified in Condition IV.B.5 of this Approval [40 C.F.R.
§761.75(c)(3)(ii)].
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e. CWMNW must record and track, in an electronic database, the volumes of leachate
pumped from collection and detection sumps on the L-14 landfill. The data, tables,
graphs, and an assessment of the tracking data and trend analysis must be included in
the Leachate Status Report required in Condition VI.F.4 of this Approval [40 C.F.R.
§761.75(c)(3)(ii)].
3. Leachate Sampling and Analysis
a. On a quarterly basis CWMNW must collect leachate samples from all landfill L-14
collection and detection sumps which contain pumpable liquids. CWMNW must
analyze the samples for parameters specified in 40 C.F.R. § 761.75(b)(6)(iii) using
methods from the most current version of U.S. EPA Publication SW-846, "Test
Methods for Evaluating Solid Wastes" and from ASTM as appropriate. The leachate
samples taken for analysis must be unfiltered. Run-on accumulated precipitation can
be sampled using the same methodologies. The use of these analytical methods is a
waiver of the requirement to use specified sampling methods in 40 C.F.R. §
761.75(b)(6)(iii).
b. If PCBs are detected in any leachate sample, CWMNW must notify U.S. EPA in
writing within 24 hours of receiving the analytical report or otherwise becoming
aware of a detection of PCBs in a leachate sample. The report shall identify the
source of the leachate and PCB levels detected [40 C.F.R. §761.75(c)(3)(ii)].
4. Leachate Status Reporting
a. CWMNW must submit semi-annual Leachate Status Reports to U.S. EPA. One must
be submitted by March 30 of each year that covers the July to December period of the
previous year, and the second report submitted by September 30 that covers the
January to June period of the same year. The Leachate Status Reports must include, at
a minimum, sampling location, identification of the landfill, the sump name, date and
time of sump PCB sampling, date and time of sump pumping, the monthly volume of
leachate pumped, date and time of treated leachate sampling, PCB test results for
sump and treated leachate sampling, identification of any PCB detections, the
leachate collection period, database printouts in appendices, and a summary
discussion of what took place during the reporting period including an assessment of
the sampling results. CWMNW must put the information and data into tables and
graphs that show the leachate volume pumped versus time for each sump such that
trends can be identified. The written report must be submitted via certified mail and
electronically to the person identified in Condition IV.B.5 of this Approval [40 C.F.R.
§761.75(c)(3)(ii)].
G. Inspection Requirements for Landfill Units
1. CWMNW must conduct inspections of the L-14 landfill within 24 hours or on the next
business day after a storm event of 0.5 inches or greater and/or when sustained wind
speed conditions exceeding 25 miles per hour (mph) are confirmed to detect evidence of
any of the following [40 C.F.R. §761.75(c)(3)(ii)]:
a. Signs of instability or erosion in above grade dikes;
b. Erosion of daily cover applied for wind dispersal and areas of exposed waste;
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c. Deterioration, malfunction, or improper operation of the run-on and run-off system;
and
d. The presence of leachate in, and the proper functioning of, the leachate collection and
removal system.
2. CWMNW must evaluate and address all deficiencies identified during the inspections of
the L-14 landfill. Any deficiency identified must be repaired, replaced, cleaned up, or
otherwise corrected within 48 hours after discovery [40 C.F.R. §761.75(c)(3)(ii)].
3. CWMNW must document all inspections and follow-up responses of the L-14 landfill,
and maintain this documentation in the operating record [40 C.F.R. §761.75(c)(3)(ii); 40
C.F.R. §§761.180(b) and (d)].
H. Closure of Landfill Units
1. CWMNW must notify U.S. EPA in writing at least 180 days prior to the date it expects
to begin closure of any of the landfill units. If needed at the time of closure, CWMNW
must also include in the notification a request to modify the Closure/ Post-Closure Plan,
pursuant to the modification process under Section VILA of this Approval [40 C.F.R.
§761.75(c)(3)(ii)].
2. CWMNW must begin closure activities for an active landfill within sixty (60) days of
when the unit reaches its maximum disposal capacity [40 C.F.R. §761.75(c)(3)(ii)].
3. CWMNW must conduct final closure activities for Landfill L-14 Cells 1-5 in accordance
with Application Appendix H, Closure/ Post-Closure Plan, which is incorporated into
this Approval as Attachment la [40 C.F.R. §761.75(c)(3)(ii)].
4. CWMNW must submit a request to U.S. EPA to modify the Closure/ Post-Closure Plan
pursuant to Section VILA of this Approval within thirty (30) days of the following [40
C.F.R. §761.75(c)(3)(ii)]:
a. Changes in ownership;
b. Changes that affect the Closure/Post-Closure Plan including operating plans, Facility
design, or Facility operations;
c. A change in the expected date of closure, if applicable;
d. An unexpected event occurring during closure activities; or
e. Changes to U.S. EPA regulations that would affect the Closure/ Post-Closure Plan
requirements.
The corresponding post-closure plan for these units must also be modified as necessary to
be consistent with any changes made to the closure plan.
I. Post-Closure Care for Landfill Units
1. CWMNW must conduct post-closure care for non-operating landfills (L-l, L-3, L-5, L-
6, L-7, L-8, L-9, L-10, L-12, and L-13) and Landfill L-14 Cells 1-5. Post-closure care
must begin after final closure is certified complete for each unit and continue for thirty
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(30) years after the date of closure for each unit, which is hereinafter referred to as the
"post-closure care period" [40 C.F.R. §761.75(c)(3)(ii)].
2. CWMNW must comply with groundwater monitoring, sampling, and reporting
requirements throughout the post-closure care period in accordance with Section VI.E of
this Approval [40 C.F.R. §761.75(c)(3)(ii)].
3. CWMNW must comply with leachate monitoring, sampling, pumping and reporting
requirements throughout the post-closure care period in accordance with Section VI.F of
this Approval [40 C.F.R. §761.75(c)(3)(ii)].
4. CWMNW must inspect and maintain the groundwater monitoring system, final cover,
run-on and run-off structures, and leachate collection systems throughout the post-
closure care period [40 C.F.R. §761.75(c)(3)(ii)].
5. CWMNW must inspect landfills in post-closure care within 24 hours or on the next
business day after a storm event of 0.5 inches or greater and/or when sustained wind
speed conditions exceeding 25 mph are confirmed, to detect evidence of any of the
following [40 C.F.R. §761.75(c)(3)(ii)]:
a. Signs of instability or erosion in the final cover and above grade dikes;
b. Deterioration, malfunction, or improper operation of the run-on and run-off system;
and
c. The presence of leachate in, or the improper functioning of, the leachate collection
and removal system.
6. CWMNW must document all inspections of landfills in post-closure care. CWMNW
must also document actions taken to address any deficiencies identified during the
inspections [40 C.F.R. §761.75(c)(3)(ii)].
7. CWMNW must maintain the integrity and effectiveness of the final cover, including
making repairs to the cap, as necessary, to correct the effects of settling, subsidence,
erosion, or other events throughout the post-closure care period [40 C.F.R.
§761.75(c)(3)(ii)].
8. CWMNW must prevent run-on and run-off from eroding or otherwise damaging the
final cover and protect and maintain surveyed benchmarks such that they can be used to
determine landfill elevations throughout the post-closure care period [40 C.F.R.
§761.75(c)(3)(ii)].
9. CWMNW must annually survey the elevation of the closure caps to verify that the caps
are not eroding or are otherwise being compromised [40 C.F.R. §761.75(c)(3)(ii)].
10. CWMNW must submit an annual report to U.S. EPA by July 15 of each year throughout
the post-closure care period that includes the information specified in Conditions VI.E.5,
VI.F. 5, and VI.I.9 of this Approval [40 C.F.R. §761.75(c)(3)(ii)].
11. At least eighteen (18) months prior to the end of the most recent post-closure care
period, CWMNW must submit to U.S. EPA an Approval modification request, in
accordance with Section VILA of this Approval, that contains an updated post-closure
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care plan that renews the post-closure care period for an additional thirty (30) years. The
modification request must also include a revised post-closure care cost estimate and
corresponding financial assurance mechanism. CWMNW may submit, prior to the
eighteen-month time period, a demonstration to U.S. EPA showing why it believes that
an additional thirty (30)-year post-closure care period is not necessary. If U.S. EPA
approves the demonstration, CWMNW will not be required to submit a new Approval
modification request. CWMNW must continue to submit thirty (30)-year post-closure
renewal modification requests until such time that U.S. EPA determines that post-closure
care is no longer necessary. Unless U.S. EPA approves any Approval modification
request submitted pursuant to this Condition, CWMNW must continue post-closure care
activities consistent with its current post-closure care plan [40 C.F.R. §761.65(d)(4)(iv);
40 C.F.R. §761.75(c)(3)(ii)].
VII. Procedures to Modify, Transfer, Revoke, Suspend, Deny, Continue or Renew Approval
The filing of a request by CWMNW for an Approval modification, revocation or termination,
or the notification of planned changes or anticipated noncompliance on the part of CWMNW,
does not stay the applicability or enforceability of any Approval condition [40 C.F.R.
§761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)].
A. Modifications
1. EPA may unilaterally reopen or modify this Approval for the following reasons:
a. Alterations. There are material and substantial alterations or additions to the Facility
or activity which occurred after the Approval was issued.
b. Information. U.S. EPA has received new or different information that was not
available or not provided at the time of Approval issuance that EPA believes would
justify the application of different Approval conditions at the time of issuance.
c. New statutory requirements or regulations. The standards or regulations on which
the Approval was based have been impacted by statutory revisions, through
promulgation of new or amended regulations, or by judicial decision after the
Approval was issued.
d. Compliance and/or construction schedules. U.S. EPA determines good cause exists
for modification of a compliance and/or construction schedule, such as an act of God,
strike, flood, or materials shortage or other events over which CWMNW has little or
no control and for which there is no reasonably available remedy.
2. CWMNW may not make major modifications (e.g., changes to engineering design,
ancillary hardware, type of catalyst, process capacity, change in PCB storage or disposal
areas, changes to maximum PCB storage or disposal volume) prior to receiving written
approval from U.S. EPA. U.S. EPA may require CWMNW to conduct a demonstration
test or provide additional information to ensure operations at the Facility continue to
meet applicable performance standards and do not present an unreasonable risk of injury
to health or the environment.
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3. CWMNW may initiate a minor modification to this Approval, provided that the minor
modification will not go into effect without written concurrence from U.S. EPA. A
minor modification is defined as an administrative or informational change, correction or
typographical error or any other change that does not affect overall performance or
environmental impact. U.S. EPA may determine that a minor modification request
should be evaluated as a major modification.
B. Transfer of Ownership
1. At least thirty (30) days prior to the proposed transfer of ownership of the property or the
proposed transfer of the right to operate PCB management activities at the Facility,
CWMNW must:
a. Submit notice to U.S. EPA that includes a notarized affidavit signed by the transferee
which states that the transferee will abide by this Approval [40 C.F.R. §761.65(j); 40
C.F.R. §761.75(c)(7)]; and
b. Provide evidence of financial assurance for closure and post-closure that the
transferee will have in effect as of the date of proposed transfer.
2. Within thirty (30) days of receiving the notification and affidavit discussed in Condition
VII.B.l, U.S EPA will issue an amended approval substituting the transferee's name for
the transferor's name, or U.S. EPA may require the transferee to apply for a new PCB
storage and chemical waste landfill approval. In the latter case, the transferee must abide
by the conditions of this Approval until U.S. EPA issues the new approval to the
transferee [40 C.F.R. §761.75(c)(7)],
C. Revocation or Suspension of Renewal
1. U.S. EPA may issue a notice of deficiency; suspend or revoke this Approval; deny an
Application for Approval renewal; and/or take an enforcement action, if U.S. EPA
determines that one or more of the following conditions have occurred [40 C.F.R.
§761.65(d)(4)(iv); 40 C.F.R. §761.75(c)(3)(ii)]:
a. Noncompliance with the conditions of this Approval or with the PCB regulations at
40 C.F.R. Part 761;
b. Failure by CWMNW in the Approval application or Approval issuance process to
disclose fully all relevant facts, or CWMNW's misrepresentation of any relevant facts
at any time;
c. U.S. EPA's issuance of new regulations, standards or guidance for issuing PCB
approvals;
d. U.S. EPA determines the PCB waste management process is being operated in a
manner that may result in an unreasonable risk to human health and the environment;
or
e. U.S EPA has not received a complete or non-deficient Approval application prior to
expiration of this Approval, or by a date specified by U.S. EPA if U.S. EPA
determines that a new or revised application is necessary to prevent an unreasonable
risk of injury to health or the environment.
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D. Continuation
1. The conditions of this Approval extend beyond the expiration date if:
a. CWMNW has submitted a timely and complete Application for renewal to U.S. EPA
in accordance with Condition VII.E of this Approval; and
b. U.S. EPA does not deny the renewal application by the expiration date or issue a new
Approval with an effective date on or before the expiration date of this Approval.
E. Renewal or Closure
1. CWMNW must at least 180 days prior to expiration of this Approval, submit to U.S.
EPA either a written notice of its intent to seek renewal of the Approval or provide
notice of its intent to initiate closure. If CWMNW requests renewal of the Approval, the
written notice must consist of a written application that includes all documents necessary
to satisfy the requirements for a TSCA PCB Approval under 40 C.F.R. Part 761.
VIII. Definitions
Unless otherwise defined below, all the terms and acronyms used in this Approval must have the
same definitions as those set forth in Section 3 of TSCA, 15 U.S.C. § 2602, and 40 C.F.R. §
761.3.
I. "Approval" means this TSCA Approval to operate a facility that manages PCBs.
2 "C.F.R." means the Code of Federal Regulations.
3. "Closure/ Post-Closure Plan" means the Closure/ Post-Closure Plan for the Facility.
4. "cm2" means square centimeters.
5 "Day" means a calendar day unless otherwise stated as an operating day.
6 "DOT" means the U.S. Department of Transportation.
7. "Facility" means the CWMNW hazardous waste management facility located at 17629
Cedar Springs Lane, Arlington, Oregon.
8. "Hazardous" or "hazardous waste" means a waste meeting the criteria at 40 C.F.R. §
261.3(a).
9. "Long-Term Storage" means PCB storage not exceeding one (1) year from the date it
was determined to be PCB waste unless extended under 40 C.F.R. § 761.65(a)(2)-(3).
10. "jig" means micrograms.
II. "mph" means miles per hour.
12. "ODEQ" means Oregon Department of Environmental Quality.
13. "Operator" means Chemical Waste Management of the Northwest.
29
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14. "PCB Unit" means any storage, treatment, or disposal unit at the Facility at which PCB
wastes are managed for storage, disposal, and or treatment under 40 C.F.R. Part 761.
15. "ppm" means parts per million or milligrams per kilogram.
16. "RCRA" means the Resource Conservation and Recovery Act.
17. "Temporary Storage" means PCB storage of specific PCB Items per 40 C.F.R. §
761.65(c)(l)(i)-(iv) not exceeding thirty (30) days from the date of removal from
service.
18. "Treatment" has the meaning in 40 C.F.R. § 260.10, which is incorporated by 40
C.F.R. § 761.20(c)(2)(ii).
19. "TSCA" means the Toxic Substances Control Act, 15 USC 2601 et seq. and 40 C.F.R.
Part 761.
20. "U.S. EPA" means the United States Environmental Protection Agency, Region 10
Office.
30
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Figure 1
- Site Location Map
SCS ENGINEERS
PROJECT NO.
01200266.04
DCS BY
LEL
FACILITY LOCATION MAP
CHEMICAL WASTE MANAGEMENT OF THE NORTHWEST, INC
DATE
November 2019
Environmental Consultants and Contractors
2405 140th Avenue NE, Suite 107
Bellevue, Washington 88005
(425)746-4600 FAX: (425) 746-6747
SCALE
N.T.S.
OK BY
EMS
FIGURE
1
CAD FILE
FIGURE 1
APPBY
PSS
ACDP MODIFICATION APPLICATION
COLUMBIA RIVER
PROJECT SITE
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Figure 2 - Facility Layout
Property Boundary_
1000' Buffer Zone
TrockExIt/
Gata2T
Chemical Waste Management
Of the Northwest, Inc.
Arlington, Oregon
DmwfogNo.
i2022.dgn 11/9/2022 1:21:30 PM
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Approval Attachment la
Closure/ Post-Closure Plan
(Application Appendix H, Received by U.S EPA December 1, 2022)
Approval for Commercial Disposal of Poly chlorinated Biphenyls
Chemical Waste Management of the Northwest, Inc.
Arlington, Oregon
U.S. EPA ID: ORD089452353
U.S. Environmental Protection Agency, Region 10
Seattle, Washington
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APPENDIX H
Closure/ Post-Closure Plan
For
Chemical Waste Management of the Northwest, Inc.
Received by EPA Region 10 on December 1, 2022
Appendix to CWMNW's final TSCA PCB application
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Closure/Post-Closure Plan
For
Chemical Waste Management of the Northwest, Inc.
Arlington Facility • ORD 089 452 353
17629 Cedar Springs Lane
Arlington, Oregon
Attachment Document No. 5
This document issue Pending by the
Oregon Department of Environmental Quality
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Chemical Waste Management of the Northwest, Inc.
Attachment #5 - Closure/Post-Closure Plan
1 INTRODUCTION 3
1.1 Purpose 3
2 CLOSURE POLICIES AND PRACTICES 3
3 WASTE MANAGEMENT UNITS AND CLOSURE PROCEDURES 4
3.1 Regulatory Requirements 4
3.2 Amendment of Closure/Post Closure Plan 4
3.3 Closure Procedures 4
3.4 Remaining Structures 6
3.4.1 Remaining Structures Closure Process 6
3.5 Wastewater Treatment Units 6
3.6 Waste Impoundments 7
3.7 Closure Process - Landfills 8
3.8 Closure Process - RCRA Container Storage Areas 9
3.9 Closure Process - RCRA Containment Buildings 9
3.10 Stabilization Unit 9
3.11 Organic Recovery Units 10
3.12 Thermal Desorption Unit TDU-1 10
4 DECONTAMINATION PROCEDURES 11
4.1 Closure Equipment Decontamination 11
5 ESTIMATE OF CLOSURE AIRSPACE REQUIRED 13
Table 5-1 Estimate of Airspace Required 13
6 GENERAL FACILITY CLOSURE REQUIREMENTS 13
6.1 Estimate of Maximum Potential Waste Inventory 13
TABLE 5-2 MAXIMUM POTENTIAL WASTE INVENTORY 14
6.2 Inspection 15
6.3 Closure Certification 15
6.4 Documentation Regarding Deed Notification 15
6.5 Closure Cost Estimates 16
6.6 Financial Assurance 16
TABLE 5-3 - WASTE MANAGEMENT UNIT CLOSURE ALTERNATIVE TIMEFRAMES 17
7 POST-CLOSURE PLAN 18
7.1 Facility Identification 18
7.2 Regulatory Requirements 18
7.3 Inspection of Closed Units 19
7.4 Security Fencing 19
7.5 Erosion Control and Maintenance of Cover and Vegetation 20
7.6 Groundwater Monitoring 20
7.7 Leachate Collection 20
TABLE 5-4 POST CLOSURE MONITORING TIMEFRAMES 21
7.8 Benchmarks 21
7.9 Post Closure Cost Estimates 21
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7.10 Financial Assurance 21
APPENDIX A - SOILS SAMPLING AND ANALYSIS PLAN 22
A1 SOIL SAMPLING AND ANALYSIS PLAN 23
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Chemical Waste Management of the Northwest, Inc.
Attachment #5 - Closure/Post-Closure Plan
1 INTRODUCTION
The Chemical Waste Management of the Northwest, Inc. (CWMNW) Arlington Facility is a hazardous waste
treatment, storage, and disposal (TSD) facility located on an approximate 1,288-acre parcel of property. The
property is owned by CWMNW. The facility is located approximately 12 miles by road from the town of
Arlington, Oregon. This document is to ensure compliance with all requirements of 40 CFR 264.110.
1.1 Purpose
• To identify steps necessary to perform partial and/or final closure of the facility; and
• To provide a schedule of closure for each hazardous waste management unit.
2 CLOSURE POLICIES AND PRACTICES
The Closure/Post-Closure Plans are based on the following policies and practices:
• A copy of the approved Closure/Post-Closure Plans, as revised, will be maintained at the site until
closure is completed.
• CWMNW has been granted extensions of the 180-day closure timeframe required by 40 CFR
264.113(b), approved timeframes for each unit are contained in Table 5-3.
• As required by 40 CFR 264.111(b), CWMNW will take all necessary steps to prevent the occurrence
of threats to human health and the environment during and after closure of the facility.
• Sequential closure of the hazardous waste management units or operations will be followed for
closing the entire facility. The processing of the hazardous wastes within the facility and individual
waste management units will be performed using the same procedures that normally would be used if
the facility were not being closed. A discussion of the sequential steps in closing the various waste
management units and operations is provided in this plan.
• It is intended that closure will be performed by trained CWMNW technicians familiar with the
various processing units. However, facility closure cost estimates and associated financial assurance
mechanisms will be based on third party costs.
• Pursuant to 40 CFR 264.114, landfills will be operated to provide sufficient reserve capacity for
disposal of solid and stabilized materials during closure of the individual units and final closure of the
facility.
• All RCRA storage and treatment tanks and associated equipment, piping, and instrumentation will be
decontaminated and recycled as scrap, or sold as a commodity.
• All contaminated concrete will be removed and disposed of in an on-site RCRA landfill following
analytical to verify LDR per 40 CFR 268.40, or macro/micro encapsulated and disposed in the RCRA
landfill.
• Uncontaminated materials will be recycled as appropriate.
• All metals will be sold as scrap or sold as a commodity.
• Former hazardous waste management unit areas (except those sites where new units are to be located)
will be contoured and revegetated to prevent ponding and wind erosion, pursuant to 40 CFR 264.310.
• Soil sampling and analysis will be conducted in accordance with the soil sampling plan presented in
Appendix A.
• Based on maximum depths of liquid in the impoundments and the net evaporation rate for the facility,
it is estimated that approximately 36 months will be required before stabilization of residues and
closure of the waste impoundments can commence.
• The groundwater monitoring (GWM) program established for the operating facility will be
maintained during the closure period for all applicable waste management units.
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Chemical Waste Management of the Northwest, Inc.
Attachment #5 - Closure/Post-Closure Plan
• Pursuant to 40 CFR 264.115, when closure is completed, CWMNW will submit to the DEQ,
certification both by CWMNW and an independent professional engineer registered in Oregon that
closure of the facility has been conducted in accordance with the specifications contained in this
Closure Plan.
• The closed facility will be protected by perimeter fencing.
3 WASTE MANAGEMENT UNITS AND CLOSURE PROCEDURES
3.1 Regulatory Requirements
Owners or operators of hazardous waste management facilities are required to have a Closure Plan that
describes how and when the facility will be partially closed (if applicable) and finally closed. This plan must
identify the maximum extent of facility operations that will be unclosed during the life of the facility and
how the requirements of 40 CFR Part 264, Subpart G (general and unit specific closure requirements) will be
met. Also, a closure schedule for each waste management unit and final closure of the facility must be
provided. The closure performance standard established by 40 CFR 264. Ill requires that the owner or
operator close the facility in a manner that:
• Minimizes the need for further maintenance; and
• Controls, and minimizes or eliminates, to the extent necessary to protect human health and the
environment, the post closure escape of hazardous wastes, waste constituents, leachate, contaminated
rainfall, or waste decomposition products to the groundwater, surface waters, or the atmosphere.
This Closure Plan for CWMNW describes the steps that will be undertaken to close existing and planned
individual waste management units as well as the entire facility. Based on current facility development plans
and permitted units, Table 5-1 represents the estimate of airspace required for closure materials for all
permitted units during the lifetime of the facility.
Ground-water monitoring, leachate collection, and run-on and run-off control for each unit being closed will
remain in place until each unit has reached final closure and is moved into Post Closure status. Ground-water
monitoring, leachate collection, and run-on and run-off control during the post Clouse period will continue as
set forth in Attachment #7 - Groundwater Monitoring Plan
3.2 Amendment of Closure/Post Closure Plan
CWMNW will submit a written notification of or request for a permit modification to authorize a change in
the approved closure plan in accordance with the applicable procedures in parts 124 and 270. The written
notification or request will include a copy of the amended closure plan for review or approval by
the Regional Administrator.
CWMNW has included alternate closure time frames in Table 5-3 of this plan requests the Regional
Administrator to apply alternative requirements to a regulated unit under § 264.140(d)
3.3 Closure Procedures
Waste management units at CWMNW described in this Closure Plan are contained within the Part B Permit.
Closure of the various waste storage, process, and treatment units includes the following common
procedures:
• Discontinue receiving hazardous waste
• Treat and/or remove inventory via normal sequential steps
• If necessary, decontaminate non-waste handling structures, tanks, and equipment and
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Chemical Waste Management of the Northwest, Inc.
Attachment #5 - Closure/Post-Closure Plan
• Salvage all waste management equipment (e.g., tanks, wiring, piping, and valves) and physical
structures (e.g., buildings). These items will be sold as scrap or a commodity and removed from the
site. All contaminated concrete will be removed and disposed of in an on-site RCRA landfill
following analytical to verify LDR per 40 CFR 268.40, or macro/micro encapsulated prior to disposal
in the RCRA Landfill.
• Uncontaminated concrete structures and foundations will be sent off-site for recycling as appropriate
• Decontaminate closure equipment; and
• Dispose of decontamination fluids and contaminated soils meeting LDR standards into waste
impoundments and active landfill L-14 or L-15, respectively. Landfills based on compliance with
LDR for RCRA codes associated with the equipment.,. Wash water and rinsate will also be
evaporated or stabilized in-place for eventual placement in the active landfill following analytical to
confirm LDR compliance.
Container storage units will be decontaminated by sweeping, washing or abrasive cleaning to remove any
surface residues, if necessary. Any steel portions will be characterized and decontaminated or disposed of as
hazardous debris. Soils below and or surrounding the units will be inspected, sampled, analyzed and if
necessary, disposed of in the facilities final landfill unit. The disturbed area will be backfilled to final grade
level.
Stabilization process equipment will be decontaminated, if necessary and removed from the facility or for
reuse or dismantled and disposed of in an on-site landfill cell. Waste residue from the stabilization area will
be removed and treated/disposed as required.
All tanks and ancillary equipment will be emptied of residues, the internal surfaces of the wastewater tanks
will be scraped, and rinsed, the tanks will be cut up and or crushed and disposed in the facility's final landfill
unit or macro /micro encapsulated. Prior to landfill all residue from the cleaning process will be characterized
and managed per the requirements of 268.40. based on site knowledge of potential contamination.
Surface Impoundments
The closure steps for the evaporation ponds will include the following:
• Discontinue receiving waste
• Reduce inventory through evaporation
• Stabilize remaining liquid and sludges to meet LDR standards;/characterize the residue for
compliance with F039
• Remove and dispose stabilized waste residues after determining compliance with F039 LDR
• The liner system from the evaporation ponds will be removed and Macro encapsulated
• Underlying soils will be tested for conformance with LDR under the F039 code, following
verification of waste meeting treatment standards/LDR, soils will be disposed of in the active onsite
landfill L-14 or L-15
• Perform soil sampling program as appropriate; and
• Contour area.
Notification of partial closure and final closure.
CWMNW will notify the Regional Administrator in writing at least 60 days prior to the date on which the
closure of a surface impoundment waste pile, land treatment or landfill unit, or final closure of a facility will
begin.
The site will initiate closure once the remaining landfill capacity is consumed, and there are no plans for
further expansion. All wastes at the facility will be treated, removed from the site or disposed of on-site or
off -site within 90 days after receiving the final volume of waste. The facility will be closed in stages as each
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Chemical Waste Management of the Northwest, Inc.
Attachment #5 - Closure/Post-Closure Plan
unit approached capacity, closure activities for individual units and final site closure will be completed in
accordance with the timeframes outlined in Table 5-3 following receipt of the final volume of waste.
In the following sections, specific closure procedures, dimensions, and capacities are described for each of
the waste management units or operations at CWMNW. Included is the estimated time to close each unit.
3.4 Remaining Structures
At final closure, the following will remain on site:
• Scales,
• Laboratory,
• Receiving building, maintenance shops,
• Sampling station,
• Transportation maintenance building
• Employee locker and rest rooms.
• Truck Wash
• Storage Building S-2
• Storage Building B-l
• Storage Building B-3
3.4.1 Remaining Structures Closure Process
This section covers the steps that will be used to achieve decommissioning and or closure of the above
structures. All hazardous unloading areas, the building structures (i.e, walls, ceilings, and roofs) the air
pollution control (APC) equipment and the concrete slabs will be decommissioned through
decontamination. The structural building elements, APC equipment and concrete slabs, where possible
will be decontaminated by sweeping, washing or abrasive cleaning. These structures are only subject to
superficial contamination, verification of decontamination will be accomplished by visual inspection. All
uncontaminated and decontaminated scrap materials that will not remain on site will be sent off site for
recycling. Any accumulated water from the washing of the buildings or structures will be collected and
analyzed for constituents of concern. All contaminated concrete will be removed and disposed of in an
on-site RCRA landfill following analytical to verify LDR per 40 CFR 268.40, or macro/micro
encapsulated prior to disposal in the RCRA Landfill. All spent wash waters will be characterized through
analysis for proper disposal. All hazardous waste samples in the laboratory will be removed and properly
disposed of. The lab holding tank will be pumped and liquids will be managed appropriately per 40 CFR
268.40. The truck wash will be pumped, all wash water will be analyzed and disposed of appropriately
per 40 CFR 268.40.
3.5 Wastewater Treatment Units
Bulk storage tanks in the wastewater treatment units are used for storage of bulk aqueous wastes prior to and
following processing through the wastewater treatment units. Processing tanks are used for processing of
aqueous wastes.
Closure Procedures. The bulk liquid storage and wastewater treatment tanks will be closed per procedures
outlined above and liquids volumes will be evaporated in the on-site ponds. All contaminated concrete will
be removed and disposed of in an on-site RCRA landfill following analytical to verify LDR per 40 CFR
268.40, or macro/micro encapsulated prior to disposal in the RCRA Landfill, uncontaminated materials will
be recycled as appropriate. Tanks and associated piping and equipment will be decontaminated, dismantled,
and recycled as scrap or sold as a commodity.
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Chemical Waste Management of the Northwest, Inc.
Attachment #5 - Closure/Post-Closure Plan
Maximum Inventory. Maximum Inventory for Wastewater Treatment Units are as follows:
WWTP-1 109,890 gallons
WWTP-2 405,687 gallons
WWTP-3 398,214 gallons
WWTP-4 336,792 gallons
WWTP-5 350,587 gallons
OWS-1 101,634 gallons
Schedule. Closure of the bulk liquid waste storage and wastewater treatment tanks shall be in accordance 40
CFR 264.113 The unit's closure timeframe starts once the facility has completed final treatment of all onsite
liquid wastes in the unit.
Closure Process - WWTP tanks will remain in place and operated to treat leachate form the landfill/landfills
as the remaining liquids within the landfills are captured during the post-closure period. Under this scenario,
the RCRA rands would be closed once the amount of liquid entering the leachate collections systems no
longer justifies the maintenance of the tanks.
3.6 Waste Impoundments
Facility waste impoundments are used for the storage and solar evaporation of selected liquid wastes. Table
5-2 provides maximum waste inventories and Table 5-1 provides estimate of airspace required for the
existing waste impoundments.
Inventory Reduction. After the final on-site liquid waste inventory has been processed, liquid wastes will
cease to be accepted at the waste impoundment being closed. The quantity of liquid in the unit will be
reduced through solar evaporation. Evaporation of remaining liquids is expected to take approximately 4
years. Remaining free liquids and sludges will be stabilized by the application of a stabilization agent (to
meet all LDR requirements, e.g., fly ash, cement kiln dust, etc.).
For purposes of closure cost estimating, it has been assumed impoundment solids holding capacity has been
reached and any residual liquids will be evaporated.
Closure Procedures. Individual waste impoundment units/subunits will be closed in accordance with the
requirements of 40 CFR 264.228 and OAR 340-104-228. All wastes, waste residues, contaminated subsoils,
will be tested for conformance with LDR per 268.40, liners, structures, and equipment will be removed and
macro/micro encapsulated or direct disposed of in the active on-site Subtitle C landfill. The Evaporation
Ponds will be closed during substantial facility closure activities.
During the period when the Evaporation Pond is inactive but not closed, CWMNW will implement all
necessary measures to prevent threats to human health and the environment from the Evaporation Pond. At a
minimum, these will include the following:
• Run-on will be prevented from entering the Evaporation Pond.
• There will be no run-off from the Evaporation Pond.
• Site security control measures will be maintained to prevent unauthorized access to the property by
persons or livestock.
• The Evaporation Pond and its associated leak detection sumps will be monitored in accordance
with the inspection schedule.
Schedule. The time required to initiate closure of a waste impoundment will depend on the size of the
individual impoundment, volume of residual wastes, weather conditions, time of year and method of closure.
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Chemical Waste Management of the Northwest, Inc.
Attachment #5 - Closure/Post-Closure Plan
Closure of the individual waste impoundments shall be in accordance 40 CFR 264.113. The unit's closure
timeframe starts once the liquids have evaporated from the unit.
3.7 Closure Process - Landfills
Facility landfills will be used for the permanent disposal of bulk solid hazardous wastes, containerized
wastes free of liquids, and stabilized wastes. Attachment #14 - Landfill Design, Operations, and Response
Plan contains landfill capacities.
Reserve landfill capacity is maintained to accept waste inventory that may exist at the time of facility closure.
This capacity will be used for the disposal of solid or stabilized waste such as:
• Residues from the closure of the processing units
• Discarded tools, fixtures, wiring, etc.
• Stabilized residues from the closure of processing units
• Soils generated from the closure of processing units
• Demolished decontaminated and uncontaminated concrete structures and foundations
• Stabilized residues and liner materials from impoundments undergoing closure by removal.
Remaining permitted capacity for Landfill L-14 is approximately 8,195,000 yd3. Remaining permitted
capacity for landfill L-15 is approximately 80,400,000 yd3
Closure Procedures. Closure cover designs for the landfill L-14 and L-15 is included in the facility's
Attachment # 14 Landfill Design, Operations and Response Plan document. The remaining landfills (L-l,
L-3, L-5, L-6, L-7, L-8, L-9, L-10, L-12 and L-13) have been closed previously in accordance with an
approved closure plan.
Attachment #17 - Landfill Final Cover Design document addresses landfill cover information related to
materials, topsoil and vegetation, erosion and drainage control, side slope stability, cover grades, settlement,
frost penetration. Final cover designs and contours for each landfill are also included.
Leachate monitoring and collection procedures for synthetically lined landfills will continue as specified in
the permit throughout the closure period and until closure has been certified as complete. Thereafter, landfills
and any impoundments closed in-place will be inspected and monitored in accordance with Attachment #5-
Post-Closure Plan.
Closure will include the following procedures:
Upon placement of the final wastes the materials will be covered in accordance with normal operating
practices. Any area that previously has not been covered will be covered with native soils to establish grade
and to serve as the base for the final cover. The detailed closure cover design can be found in Attachment
#17 - Final Cover Design.
The point at which the maximum unclosed portion is expected to occur will be when Landfill L-15 ad L-14
have been filled to capacity and the cells are waiting for placement of the final cap. The maximum area
requiring closure for L-14 will be approximately 35.5 planar acres. The maximum area requiring closure for
the specialty landfill L-15 will be approximately 202 planar acres.
Schedule. Closure of Landfill L-14 shall be in accordance 40 CFR 264.113 and within the approved
alternate regulatory time frame outlined in Table 5-3. The unit's closure timeframe starts once all available
airspace has been consumed. Closure of landfill L-15 shall be in accordance with 40 CFR 264.113 and
within the approved alternate regulatory time frame outlined in Table 5-3. The landfill unit closure timeframe
starts once all available airspace has been consumed.
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Chemical Waste Management of the Northwest, Inc.
Attachment #5 - Closure/Post-Closure Plan
3.8 Closure Process - RCRA Container Storage Areas
All RCRA regulated hazardous wastes accepted at the Arlington Facility, with the exception of containerized
solids and bulk liquids and solids, are processed through the container storage areas. The pertinent physical
information for all the existing container storage units is shown in Attachment #9 - Container Storage
Design and Operations Plan
Inventory Reduction. Liquid wastes will be treated and landfilled on-site or shipped to off-site treatment as
appropriate Wastes will be treated and landfilled or shipped off-site for treatment.
Closure Procedures. Containers remaining in the existing storage units will be removed and processed
through the existing waste management operations as described above. All liner material will be removed
and disposed of via direct landfill or Micro/Macro encapsulation based on analytical and site knowledge of
potential contamination. Foundation soils from each area (S-6, S-10 and S-12) will be sampled in accordance
with Appendix A and analyzed for contamination. Any contaminated soil will be removed and disposed of
in an on-site RCRA landfill following testing for verification of LDR compliance per 40 CFR 268.40
requirements. For the purpose of estimating closure costs, it is assumed that a maximum depth of 1 foot of
soil from 100 percent of the surface area will be removed from these units.
Schedule. Container Storage Areas will be closed pursuant to 40 CFR 264.113 and within the approved
alternate regulatory time frame outlined in Table 5-3.
3.9 Closure Process - RCRA Containment Buildings
The pertinent physical information for all containment buildings units is shown in Attachment #9 - Waste
Storage Unit Design and Operations Plan
Inventory Reduction. Solid wastes will be treated and landfilled on-site or shipped to off-site treatment as
appropriate.
Closure Procedures. Bulk solids remaining in the containment units will be removed and processed
through the existing waste management operations as described above. Building Structures and equipment
will be decontaminated, by sweeping, washing or abrasive cleaning, and shipped offsite as scrap or sold as a
commodity. Foundations and 1 foot of underlying soils from each containment building (B-2, B-4, B-5, B-6
[units 1-3], B-7 and B-8) will be sampled in accordance with Appendix A and analyzed for contamination.
All contaminated concrete will be removed and disposed of in an on-site RCRA landfill following analytical
to verify LDR per 40 CFR 268.40, or macro /micro encapsulated prior to disposal in the RCRA Landfill,
uncontaminated materials will be recycled as appropriate. For the purpose of estimating closure costs, it is
assumed that a maximum depth of 1 foot of soil from 100 percent of the surface area will be removed from
these units.
Schedule. Containment Buildings will be closed pursuant to 40 CFR 264.113 and within the approved
alternate regulatory time frame outlined in Table 5-3.
3.10 Stabilization Unit
CWMNW operates a Stabilization Unit for the treatment of solids, sludges, semi-solids, and aqueous wastes
from direct deliveries, containers, truck wash sumps, waste impoundments, leachate, and waste management
units undergoing closure.
Inventory Reduction. After stabilized wastes have been tested to ensure that the treatment process is
adequate, and LDR has been met per 40 CFR 288.40, they will be removed from the treatment tanks and
disposed of in an on-site compatible landfill.
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Chemical Waste Management of the Northwest, Inc.
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Closure Procedures. Structures and equipment will be decontaminated, by sweeping, washing or abrasive
cleaning, shipped offsite as scrap or sold as a commodity. Verification of all visible signs of waste will be
removed from these structures to the extent practicable. Foundations and 1 foot of underlying soils from the
unit will be sampled in accordance with Appendix A and analyzed for contamination. Any contaminated soil
and concrete will be removed and disposed of in an on-site RCRA landfill based on analytical to verify
compliance with 40 CFR 268.40, Contaminated concrete may be micro/macro encapsulated as appropriate
and disposed in the RCRA landfill, uncontaminated materials will be recycled or reused as appropriate. For
the purpose of estimating closure costs, it is assumed that a maximum depth of 1 foot of soil from 100
percent of the surface area will be removed from these units.
Schedule. Stabilization units will be closed pursuant to 40 CFR 264.113 and within the approved alternate
regulatory time frame outlined in Table 5-3.
Decontamination of Auxiliary Equipment and Tanks
A current list of the type and number of facility equipment that are available for closure activities is
maintained at the facility. The equipment used during the closure period will be decontaminated by either
high-pressure water or steam washing of the tires and undercarriage. Appropriate chemical additives will be
added to the cleaning solution, as specified by the chemical manufacturer. The adequacy of cleaning will be
verified through visual inspection, and when the equipment is found to be clean (i.e., no visible evidence of
contaminated soil or liquid), cleaning with water or steam will be repeated one more time.
Decontamination of the facility equipment used in the size reduction of solid waste (crushing operations) can
be accomplished with compressed air inside the enclosed structure housing the operation. The compressed
air will be effective at removing any dust residue on the equipment and any airborne dust particles will be
collected and removed by the air handling and filtration system. Solid waste residue which cannot be blown
from the equipment will be cleaned using conventional decontamination procedures.
The facility maintenance program requires regular equipment inspections and provides for periodic servicing
and replacement of equipment.
3.11 Organic Recovery Units
The pertinent physical information for the Organic Recovery Units (ORU) is shown in Attachment #22
ORU-2 and ORU-3 Design and Operations Plan
Closure Procedures. The ORUs will be closed per procedures outlined in this plan. The equipment used in
the operation will be decontaminated as described in this plan via sweeping, washing and abrasive cleaning.
Since the referenced equipment is only subject to surficial contamination, verification of decontamination
will be accomplished by visual inspection. The equipment is considered scrap and will be recycled or resold
once de-contaminated and removed from the site. All contaminated concrete will be removed and disposed of
in an on-site RCRA landfill following analytical to verify LDR per 40 CFR 268.40, or macro/micro
encapsulated prior to disposal in the RCRA Landfill., uncontaminated materials will be recycled as
appropriate. Foundation soils from the building and processing area will be removed and disposed of in an
on-site RCRA landfill following analytical verification of LDR compliance.
Closure Schedule. ORU-2 and ORU-3 will be closed pursuant to 40 CFR 264.113 and within the approved
alternate regulatory time frame outlined in Table 5-3.
3.12 Thermal Desorption Unit TDU-1
The pertinent physical information for the TDU-1 is shown in Attachment #25 TDU-1 Design and
Operations Plan Operations Plan
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Closure Procedures. The TDU-1 will be closed per procedures outlined in this plan. The equipment used in
the operation will be decontaminated as described in this plan. The equipment is considered scrap and will be
recycled or resold once de-contaminated and removed from the site. The structural steel and interior support
structures shall be decontaminated by sweeping, washing, or abrasive cleaning. Since the referenced
equipment is only subject to surficial contamination, verification of decontamination will be accomplished
by visual inspection. All contaminated concrete will be removed and disposed of in an on-site RCRA landfill
following analytical to verify LDR per 40 CFR 268.40, or macro/micro encapsulated prior to disposal in the
RCRA Landfill, uncontaminated materials will be recycled as appropriate. Foundation soils from the area
will be sampled pursuant to Appendix A and removed and disposed of in an on-site RCRA landfill following
verification sampling and analytical to conform with 40 CFR 268.40.
Closure Schedule. TDU-1 will be closed pursuant to 40 CFR 264.113 and within the approved alternate
regulatory time frame outlined in Table 5-3
4 DECONTAMINATION PROCEDURES
In addition to removal of concrete structures, tanks, piping, and liner systems, decontamination may
consist of sweeping & vacuuming residues, incidental liquids, wash waters, sandblasting residues, spent
PPE and/or other cleaning residues. To facilitate cost- effective residues management, incidental
liquids, sludges, sediments, or solids will be segregated in separate containers, as necessary. These
containers may consist of roll-off containers, box trailers, frac tanks, vacuum trucks, portable plastic
storage tanks, WWTP tanks, totes, drums or other appropriate containers.
Representative samples of the accumulated solids, debris, equipment (via Swab), and liquids will be
collected and analyzed for Universal Treatment Standards (UTS) constituents to determine if treatment
is required. Sample collection and analysis methods are discussed in Appendix A and in Attachment #1,
Waste Analysis Plan. Based on the results of these analyses and comparison to the UTS, the materials
will be disposed per the requirements of the WAP.
Stabilization of liquids and/or solids may be performed in the Mixing Tanks in the Stabilization Units,
in containers (including roll-offs), or other temporary units utilized for this purpose. Such units will be
decontaminated, dismantled and/or direct disposed as hazardous waste upon completion of treatment
activity. A final sample of the stabilized residues will be collected and analyzed for metals to verify the
stabilized residues are no longer hazardous (or meet appropriate LDRs) and may be disposed in the
facility's final landfill unit. During final closure activities for the Evaporation Pond, all residues will be
characterized and properly treated and disposed at an off-site facility.
4.1 Closure Equipment Decontamination
All construction equipment used in closure activities and hazardous waste processing equipment (that is not
disposed in a landfill unit) will be decontaminated. All rinsate will be collected and pumped to a temporary
holding tank for analysis. The wash water will be transferred to one of the open Evaporation Ponds in
accordance with the procedures described in the WAP. For purposes of this Closure/Post-Closure Plan, it is
assumed that the wash waters will not exceed LDRs and can be placed into the Evaporation Ponds.
The decontamination zone will be located along the edge of the "working" or contaminated area and will
include a liquid collection area. This zone will be bermed and double lined with synthetic sheeting to
facilitate collection of wash water and to prevent a release of liquid outside the zone.
All earthwork equipment will be cleaned in the decontamination zone or truck / equipment wash pad, if it is
still active, prior to final removal from the site and before any "clean" (e.g., backfilling) operations are
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Chemical Waste Management of the Northwest, Inc.
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commenced in the area. All trucks hauling material to facility landfills will also be cleaned, as necessary, at
the completion of disposal activities. Equipment decontamination will be verified visually (i.e., no visible
evidence of contaminated soil or liquid).
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Attachment #5 - Closure/Post-Closure Plan
5 ESTIMATE OF CLOSURE AIRSPACE REQUIRED
Table 5-1 Estimate of Airspace Required
Waste Management Unit
Actual/E s timate d
Construction
Date(s)
Maximum Total
Yards Airspace
Required
Container Storage Area S-62
1998
1,127
Container Storage Area S-122
TBC
2,050
Container Storage Area S-102
1997
580
Waste Water Treatment Unit 1- Equipment3
2006/2007
1
Waste Water Treatment Unit 2- Equipment3
2017
1
Waste Water Treatment Unit 3- Equipment3
TBC
1
Waste Water Tertment Unit 4 - Equipment3
TBC
1
Stabilization Unit1
1988-1990
5,077
Containment Building B-42
1997-1999
1,802
Containment Building B-22
1998
1,494
Containment Building B-52
2004
3,339
Containment Building B-62
TBC
10,018
Containment Building B-72
TBC
3,339
Containment Building B-82
TBC
3,339
Waste Crushing Equipment - B-3 to remain
1998-1999
2,693
Organic Recovery Unit ORU-21 - Containment
2009
13,055
Organic Recovery Unit ORU-31 - Containment
TBC
4,039
TDU-1 Organic Treatment Unit1 - Containment
TBC
3,302
Impoundments P-A2, P-B2
1987-2000
15,456
Impoundments P-C2, P-D2, P-E2
TBC
47,160
Impoundment P-F2
TBC
15,720
Landfill L-14 (Cell No.'s 1 - 4)2
2003-2021
-
Landfill L-14 (Cell No.'s 5 - 8)2
TBC
-
LandfillL-15 (CellNo.'s 1 - 4)
TBC
-
Note 1 - Equipment will be scrapped or sold as capital goods 1
133,597
Note 2 - No equipment associated with this unit
Note 3 - WWT 2/3/4 are located within the ORU/TDU Contanment Strucutre
6 GENERAL FACILITY CLOSURE REQUIREMENTS
The Arlington Facility will be closed in a manner that protects human health and the environment and
minimizes the need for post-closure maintenance, in accordance with the standards found in 40 CFR 264,
Subpart G.
6.1 Estimate of Maximum Potential Waste Inventory
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As required by 40 CFR 264.112(b)(3), the Closure Plan must provide an estimate of the maximum extent of
operations and maximum inventory of hazardous wastes on-site over the active life of the facility. This
estimate is then used to determine the maximum cost of closure, as required by 40 CFR 264.142(a)(1).
The maximum inventory of hazardous waste on-site over the active life of the facility is shown in Table 5-2.
TABLE 5-2 MAXIMUM POTENTIAL WASTE INVENTORY
Actual/Estimate d
Maximum Total
Maximum
Maximum
Waste Management Unit
Construction
Yards Airspace
Potential
Potential
Date(s)
Required
Inventory Gallons
Inventory yd3
Non-RCRA Product Tank Storage
2009
-
135,900
-
Container Storage S-2
1998
-
1,720,000
-
Container Storage Area S-62
1998
1,127
10,200,000
See Note 4
Container Storage Area S-122
TBC
r
18,000,000
See Note 4
Container Storage Area S-102
1997
580
8,090,000
See Note 4
Waste Water Treatment Unit 1- Equipment3
2006/2007
1
109,890
-
Waste Water Treatment Unit 2- Equipment3
2017
1
345,687
-
Waste Water Treatment Unit 3- Equipment3
TBC
1
338,214
-
Waste Water Tertment Unit 4 - Equipment3
TBC
1
336,792
-
Stabilization Unit1
1988-1990
5,077
180,000
24,064
Containment Building B-42
1997-1999
2,691
-
30,000
Containment Building B-22
1998
1,494
-
5,950
Containment Building B-52
2004
3,339
5,570,000
58,833
Containment Building B-62
TBC
-
16,710,000
176,500
Containment Building B-72
TBC
-
5,570,000
30,000
Containment Building B-82
TBC
-
5,570,000
13,693
Waste Crushing Equipment - B-3 to remain
1998-1999
2,693
NA
NA
Organic Recovery Unit ORU-21 - Containment
2009
13,055
See WWTP-2
See Build B-4/B-5
Organic Recovery Unit ORU-31 - Containment
TBC
-
See WWTP-3
See Build B-4/B-5
TDU-1 Organic Treatment Unit1 - Containment
TBC
-
See WWTP-4
See Build B-6/B-7
OWS-1 Oil Water SeperatorUnit
2006
85,734
-
Impoundments P-A2, P-B2
1987-2000
11,607
8,500,000
NA
Impoundments P-C2, P-D2, P-E2, P-F2
TBC
r
190,760,000
NA
Landfill L-14 (Cell No.'s 1 - 4)2
2003-2021
-
-
3,100,000
Landfill L-14 (Cell No.'s 5 - 8)2
TBC
-
-
8,195,945
Landfill L-15 (Cell No.'s 1-4)
TBC
-
80,400,000
Note 1 - Equipment will be scrapped or sold as capital goods 1
41,668
272,222,217
92,034,986
Note 2 - No equipment associated with this unit
Note 3 - WWT 2/3/4 are located within the ORU/TDU Contanment Strucutre
Note 4 - Contaner Storage area capacity based on containment capacity for each unit
Pursuant to this plan CWMNW will evaporate prior to closure. Maximum land fill airspace for waste
disposal (41,668 yd3) is based on the maximum solids holding capacity of the containment buildings and
stabilization tanks. This amount of reserve air space will be maintained in in Landfill L-14 and/or L-15.
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CWMNW will notify the DEQ of the closure of any waste impoundment, landfill, storage building,
containment building, or waste treatment unit at least 60 days prior to the start of closure.
Schedule. The General Facility will be closed pursuant to 40 CFR 264.113 and within the approved
alternate regulatory time frame outlined in Table 5-3 after termination of all waste treatment and disposal
activities and after all hazardous waste units have been closed.
CWMNW will notify the DEQ in writing at least 60 days prior to the initiation of final closure of the facility.
Once closure is complete, CWMNW will submit to the ODEQ, a certification by both CWMNW and by an
independent registered professional engineer that the site has been closed in accordance with the
specifications in the approved Closure Plan.
6.2 Inspection
Until final certification closure, inspections will be made according to the facility's Attachment #3 Inspection
Plan. Construction monitoring and engineering certification of disposal areas will continue throughout the
placement of soil cover during closure.
6.3 Closure Certification
As required by 40 CFR 264.115, CWMNW will certify that the activities performed to close the facility are
in accordance with the procedures described in the approved Closure Plan. The certification will be signed
by CWMNW and an independent registered professional engineer and will be submitted to the DEQ within
60 days of the completion of final closure. Documentation supporting certification will be provided to the
DEQ on request.
CWMNW will also obtain certification of closure by an independent registered professional engineer for any
waste impoundment or landfill that is closed prior to final facility closure, as required by 40 CFR 264.115.
6.4 Documentation Regarding Deed Notification
The only portions of the Arlington Facility upon which hazardous wastes will be disposed of permanently are
the landfills including impoundments closed as "landfills". In order to satisfy the requirements of 40 CFR
264.119, within 60 days of certification of closure of the first hazardous waste disposal unit and within 60
days of certification of closure of the last hazardous waste disposal unit, CWMNW will be required to:
• Record in accordance with state law, a notation on the deed to the facility Property - or on some other
instrument which is normally examined during title search - that will in perpetuity notify any
potential purchaser of the Property that:
o The land has been used to manage hazardous wastes
o Its use is restricted under 40 CFR Subpart G regulations; and
o The survey plat and record of the type, location, and quantity of hazardous wastes disposed of
within each cell or other hazardous waste disposal unit of the facility required by 40 CFR 264.116
and 264.119(a) have been filed with the local zoning authority or the authority with jurisdiction
over local land use and with the DEQ; and
• Submit a certification, signed by CWMNW, that CWMNW has recorded the notation specified
above, including a copy of the document in which the notation has been placed, to the DEQ.
On completion of official closure, a legal description will be prepared to precisely reflect the as-built location
of all RCRA disposal units at the facility. This description will be submitted to the state along with the
certification that final closure has been completed as specified in the approved Closure Plan.
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At the time that the closure certification for each disposal unit (existing and future) or final closure of the
facility is presented to the state, CWMNW also will submit a survey plat prepared by a registered land
surveyor which shows the location and dimensions of landfill cells as required under 40 CFR 264.116.
No later than 60 days after completion of the established post-closure care period for each hazardous
waste disposal unit, CWMNW will submit to the Regional Administrator, by registered mail,
a certification that the post-closure care period for the hazardous waste disposal unit was performed in
accordance with the specifications in the approved post-closure plan. The certification will be signed by
the owner or operator and a qualified Professional Engineer. Documentation supporting the Professional
Engineer's certification must be furnished to the Regional Administrator upon request until he releases the
owner or operator from the financial assurance requirements for post-closure care under § 264.145(i).
6.5 Closure Cost Estimates
A copy of the most recent closure cost estimates prepared in compliance with 264.142 is maintained in the
operating record at CWMNW and available for review. These cost estimates are updated annually by a third
party, per the requirements of 264.140 and submitted to the Agency for review.
6.6 Financial Assurance
Financial Assurance in compliance with 264.143 is provided to the Agency annually for review and a copy is
maintained electronically and/or by hard copy in the operating record at CWMNW.
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Attachment #5 - Closure/Post-Closure Plan
TABLE 5-3 - Waste Management Unit Closure Alternative Timeframes
iBiaan
2
Container Storage Units
30
180
180
390
"i
Coataubmeot Buildings'
30
180
365
575
¦->
Organic Recovery Units*
30
180
365
575
Thermal Desorption Units"
30
180
365
5~5
-i
Wastewater 'Treatment Units"
30
180
ISO
390
Stabilization. Solidification Units"
30
180
365
575
Waste Impoundments"
30
180
365
575
Final Landfill L-14 or L-15""
180
180
1697
2057
*?
Bask UtMes (Inclntfiiig Laboratcwy)*
30
180
180
390
Final Inspection and Professional Engineer
Certification
60
90
150
Note 1- Closure plan submittal timeframe starts after decision to close unit is made
Note 2 - Closure activities for each unit begin with once inventory reduction removal has been completed .and closure construction
plans for each unit have been approved
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7 POST-CLOSURE PLAN
7.1 Facility Identification
EPA Facility Identification Number: ORD 089 452 353
Owner's or Operator's Name: Chemical Waste
Management of the Northwest, Inc.
Address and Telephone Number: 17629 Cedar Springs Lane
Arlington, OR 97812
(541)454-2030
7.2 Regulatory Requirements
Facilities that have disposal operations are required by 40 CFR 264.118 to have a Post-Closure
Plan that identifies the activities that must be carried on after the facility is closed. The
regulations require that post-closure care of the facility be continued for 30 years after the date of
closure of each hazardous waste management unit, unless the Oregon Department of
Environmental Quality Director (ODEQ) determines that a reduced period is sufficient to protect
human health and the environment.
All post-closure care activities must be in accordance with the provisions of this approved post-
closure plan as specified in § 264.118
This Post-Closure Plan for the Chemical Waste Management of the Northwest, Inc. (CWMNW)
Arlington Facility identifies post-closure care activities that will be carried out either after
closure and certification of any disposal unit has occurred or following final facility closure and
certification. The Post-Closure Plan presents the requirements for post-closure care activities,
including periodic groundwater and leachate monitoring, site inspections and maintenance
activities, and measures to assure restricted site access. Monitoring and reporting will be
conducted in accordance with the requirements of subparts F, K, N, and X of 40CFR 264.
Maintenance and monitoring of waste containment systems will be conducted in accordance with
the requirements of subparts F, K, N, and X of 40CFR 264.
Post-closure uses which disturb the integrity of the final cover, liner(s), or any other components
of the containment system, or the function of the facility's monitoring systems, are prohibited
unless the Regional Administrator finds that the disturbance is necessary pursuant to 40 CFR
264.117(c)(1) or (2).
A copy of the current approved Post-Closure Plan will be kept electronically and/or by hard
copy at the facility located at 17629 Cedar Springs Lane, Arlington, Oregon. After that time, an
updated copy of the approved plan will be kept electronically and/or by hard copy at CWM
Portland offices located at 7227 NE 55th Ave. Portland, Oregon. The contact person will be
Pacific Northwest Environmental Protection Manager, phone number is 800-808-5901.
The Post-Closure Plan will be amended whenever changes in operating plans, facility design, or
other factors (including a change in the expected year of final site closure) affect the plan.
CWMNW will submit a written notification of or request for a permit modification at least 60
days prior to the proposed change to authorize the change in the approved post-closure plan in
accordance with the applicable requirements in parts 124 and 270. The written notification or
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Chemical Waste Management of the Northwest, Inc.
Attachment #5 - Closure/Post-Closure Plan
request will include a copy of the amended post-closure plan for review or approval by
the Regional Administrator.
The Regional Administrator may request modifications to the plan under the conditions
described in § 264.118(d)(2). CWMNW will submit the modified plan no later than 60 days after
the Regional Administrator's request.
A certification of completion of post-closure care will be provided by CWMNW to the
appropriate agencies no later than 60 days after the established post-closure care period for each
hazardous waste management unit. The certification will be signed by CWMNW and an
independent registered professional engineer and will certify that all post-closure activities were
performed in accordance with the specifications of the approved Post-Closure Plan.
Documentation to support the certification will be provided to the agencies on request.
7.3 Inspection of Closed Units
The post-closure procedures and technical activities for periodic inspections will commence
immediately following certification in accordance with timeframes in Table 5-4 that the entire
Arlington Facility has been closed in accordance with the requirements of the approved Closure
Plan and will continue for the period specified by 40 CFR 264.117(a) or, alternately, for the
period specified by the EPA Regional Administrator. For the purpose of this Post-Closure Plan,
this period has been assumed to be 30 years. Throughout the post-closure period, the facility will
be inspected, per 40 CFR 264.113 requirements. Please see Attachment #3 - Inspection Plan,
Inspection Schedule for detailed inspection elements.
Following the occurrence of a recorded linch, 24 hour storm, an out of period inspection will be
scheduled for the cover, embankments, roads, dikes, surface run-off containments, and drainage
ways.
The frequency of inspection has been selected on the basis of CWMNW's experience with its
presently closed landfills. These landfills have not required maintenance since closure. The
landfills will be the only units containing hazardous waste that will remain at the site after
closure and consequently are the only units that will require maintenance. This, coupled with the
remote location of the facility, makes it unnecessary to inspect landfills more frequently.
Inspection frequency is outlined in Table 5-4
The date, time, results of the inspection, and the maintenance activities performed will be
documented electronically or by hard copy and filed in the facility operating record along with
dates of repair of identified repairs. The results of the initial semi-annual inspections will
provide a data base from which CWMNW will be able to better define the nature and extent of
necessary post-closure care activities and costs that will occur after the facility is finally closed.
Any necessary repairs or maintenance of the disposal unit covers, leachate detection and removal
systems, groundwater monitoring wells, or fencing will be accomplished during the scheduled
inspection or shortly thereafter.
7.4 Security Fencing
During each inspection, CWMNW personnel will check the fence for holes, damaged posts,
broken or missing wire, gate damage, broken locks, and erosion under the fence and around the
posts. Please see Attachment #3 - Inspection Plan for detailed inspection procedures.
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7.5 Erosion Control and Maintenance of Cover and Vegetation
During each inspection, CWMNW personnel will check the cap of landfills for holes, burrows,
severe surface cracks, subsidence, and erosion. Please see Attachment #3 - Inspection Plan for
detailed inspection procedures. The cover vegetation also will be checked to determine whether
revegetation is required. The drainage control system will be checked for damaged sections,
debris and/or excessive vegetation, or other conditions detrimental to the system's operation.
The dry climate and slow growth of vegetation will make mowing unnecessary. However,
clearing will take place if weeds or grass threaten to interrupt the flow of surface water in the
ditches or threaten the integrity of the closure cap. It is estimated that approximately 1,000 feet
of ditch will require major maintenance and 20 feet of culvert will need replacement each year
during the post-closure period. Ditches will be inspected for high or low spots and erosion.
The design features of the closure cap slopes and facility drainage system minimize the potential
for deterioration. An average annual soil loss of 0.7 tons per acre per year is anticipated from
closed areas containing waste. On-site soil will be used for redressing in areas eroded or areas
where settlement has occurred that may cause ponding. Other conditions which may necessitate
replacement of disturbed soil and/or revegetation include the burrowing activities of rodents or
other small animals and the occurrence of a major storm. The soil will be replaced from a
borrow area as necessary and vegetated.
7.6 Groundwater Monitoring
Groundwater monitoring (GWM) will continue at the Arlington Facility for 30 years following
final closure. Waste Management Area (WMA) monitoring wells will be sampled semi-annually
throughout this 30-year period. Wells monitoring past practice units will be monitored annually.
The post-closure groundwater monitoring program for the facility will be the same program as
implemented for active site operations. This program is described in Attachment #7 -
Groundwater Monitoring Program. All groundwater monitoring wells and devices will be
maintained in good repair and kept operational. The wellhead units will be inspected during the
groundwater monitoring events and repaired or replaced if necessary.
If damage be found during inspections, wells will be repaired or replaced as necessary. Well
integrity issues during the 30 year post closure period are not expected to occur as the facilities
groundwater monitoring plan has well decommissioning and replacement of wells using the new
monitoring strategy. Monitoring, including reporting requirements, will be conducted in
accordance with 40 CFR Subpart F and 264.117. Please see Attachment #3 - Inspection Plan for
specific inspection procedures. Purge water generated during post-closure groundwater
monitoring events will be sent off-site for disposal.
7.7 Leachate Collection
Monitoring and maintenance of the leachate collection systems of individual closed landfills will
be performed on a monthly basis while the facility is still active. After final facility closure, the
leachate collection and removal system will be inspected in accordance with 40 CFR 264.113.
The leachate collection sump system will be checked for liquid accumulation. If there is any
liquid accumulation, the liquid will be removed using a portable pump and sent to a RCRA
hazardous waste facility. Please see Attachment #3 - Inspection Plan for specific inspection
procedures.
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Attachment #5 - Closure/Post-Closure Plan
TABLE 5-4 POST CLOSURE MONITORING TIMEFRAMES
Inspection Frequency
0 to 10 years
After Closure
11 to 30 years
After Closure
Groundwater Monitoring
Semi- Annually
Semi-Annually
Site Inspection
Semi- Annually
Annually
Final Cover Monitoring
Semi- Annually
Annually
Leachate Sumps
Monthly
Semi-Annually
Aerial Flyovers
Every 2 years
Every 5 years
7.8 Benchmarks
Benchmarks are not used at CWMNW, the facility employs aerial flyovers to identify areas of
subsidence to demonstrate compliance with 40 CFR 264.116 and 264.310(b)(6). Flyover
7.9 Post Closure Cost Estimates
A copy of the most recent post closure cost estimates prepared in compliance with 264.144 is
maintained in the operating record at CWMNW
7.10 Financial Assurance
Financial Assurance in compliance with 264.143 is provided annually and a copy is maintained
in the operating record at CWMNW.
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Attachment #5 - Closure/Post-Closure Plan
APPENDIX A - SOILS SAMPLING AND ANALYSIS PLAN
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A1 SOIL SAMPLING AND ANALYSIS PLAN
Soils will be sampled and analyzed to determine the existence or extent of contamination at the
Arlington Facility according to the following procedures. Prior to background and closure
sampling, CWMNW will consult with Oregon Department of Environmental Quality, to identify
the required extent of soil sampling for contamination removal at the Arlington Facility.
Additionally, CWMNW will submit the proposed background and closure sampling locations to
the department for approval at a minimum of number of days for the applicable type of unit as
indicated in 40 CFR 264.112(d) prior to the anticipated final or partial closure.
• Surrounding soils will be sampled and analyzed for the presence of contamination for all
hazardous waste storage and treatment units, except those which will be constructed with
impervious concrete foundations and containments.
• For landfills underlying soil sampling will not be performed, 100 x 100-foot grids will be
established around the perimeter of the landfill. Five samples will be collected from each
grid area. One (1) sample will be collected at the center of the grid the other four (4)
samples will be collected at the 47-foot interval along the diagonals of the grid. Please
see Figure 5-1 for more information
• For other treatment and storage units underlying soil sampling will be performed on a 50
x 100-foot grid with samples taken at the 47-foot interval along the diagonals of the grid.
25 x 200-foot grids will be established around the perimeter of each unit with samples
taken at the 50-foot interval along the diagonals of the grid. 5 samples will be collected
from each grid area. One (1) sample will be collected at the center of the grid the other
four (4) samples will be collected along the diagonals of the grid. The 5 samples from
each grid will be mixed to form a single composite sample. All sampling locations will
be measured and marked with flags for future reference. Please see Figure 5-1 for more
information
• In addition to the random sampling grid, at least one sample shall be obtained from each
area of known contamination or obvious visual contamination. Samples from such areas
shall not be composited with any other samples for analyses.
• Final confirmation of the absence of contamination of hazardous constituents in soil shall
be demonstrated by analysis for hazardous constituents as contained in 40 CFR Part 261
Appendix VIII (for which analytical procedures are available), rather than the
constituents contained in the priority pollutant list.
• Background samples will be collected from areas where no waste activity has been
conducted. At least 5 background samples will be taken with each sampling consisting of
5 samples composited into a single sample. Each background soil location will consist of
a single 200 ft. by 200 ft. square. Within each grid, five (5) samples will be collected: one
(1) sample will be collected from the midpoint of the grid and four (4) samples will be
collected along the grid diagonals at a distance of approximately 97 ft. from the center of
the grid. The five (5) individual soil samples from each background grid location will be
composited.
• The analytical results from these background samples will serve as the standard against
which contaminated area results are compared for detecting the presence of residual
contamination. Criteria used for the selection of background sample locations are as
follows:
DEQ Pending Rev. 0
Appendix C-Page 23
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Chemical Waste Management of the Northwest, Inc.
Attachment #5 - Closure/Post-Closure Plan
o Samples must be taken from areas within a nominal 1,200-foot horizontal distance
from the contaminated area, but not so close that they could be affected by past
operation of the area or by other activity at the facility
o Samples must be taken from similar geologic strata at similar depths as those samples
taken from the contaminated area to which they will be compared,
o If analysis of any background sample indicates that it is an outlier using the method
provided in ASTM E-17880, Section 4.3 as calculated at a one percent significance
level, then the Permittee may delete that sample from the background set and may
replace it with a new background sample or the Permittee may demonstrate that the
outlier sample is a valid background sample, representative of natural background
concentrations for the constituent(s) in question. All background values for each
parameter shall be subject to review and acceptance or rejection by the DEQ before
such values are used to determine the cleanup standard at each unit.
• Soil samples will be taken with a standard sampling shovel at a depth of approximately 2-
6 inches below the ground surface. All field sampling equipment will be rinsed between
locations to eliminate cross contamination. Soil samples for inorganic analyses will be
placed into either polyethylene containers or glass containers and sealed to prevent
desiccation during transport to the laboratory. Soil samples for organic analyses will be
placed into Teflon sealed glass containers with septum tops (or equivalent). The choice
of container size and preservative method will depend on the analytical parameters in
accordance with the procedures outlined in the most currently approved version of EPA
Publication SW-846 ("Test Methods for Evaluation Solid Waste, Physical/Chemical
Methods,") at the time each unit undergoes closure.
• Preliminary sampling and analytical testing will be performed by on-site personnel to
assure that all contaminated material has been removed. If such tests show that
contamination persists, additional material will be removed until test results are
satisfactory. (These tests are discretionary in nature and are not used for closure
certification.) Once this has been accomplished, an independent engineer will perform
final certification sampling and analysis.
Successful closure is defined as test results showing concentrations of test parameters in the soil
below the unit that are at (or below) the measured maximum concentration of these parameters in
background samples. On a case-by-case basis, test parameters which are at de minimis levels
over the maximum background concentration of that parameter may be approved by the DEQ.
DEQ Pending Rev. 0
Page 24
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Chemical Waste Management of the Northwest, Inc.
Attachment #5 - Closure/Post-Closure Plan
Figure 5-1 Sampling Grids
100 feet
Sample Point
Sample Point
Sample Point
50 feet
Sample Point
100 X 50 foot Grid
Sample Point
E
Sample Point
Sample Point
25 X 200 foot grid
Sample Point
Sample Point 25feet
J
Sample Point
Sample Point
47 feet from center
Sample Point
100feet
Sample Point
100 x 100 foot grid
47 feet from center
Sample Point
DEQ Pending Rev. 0
Page 25
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Approval Attachment lb
Approval for Commercial Disposal of Poly chlorinated Biphenyls
Chemical Waste Management of the Northwest, Inc.
Arlington, Oregon
U.S. EPA ID: ORD089452353
U.S. Environmental Protection Agency, Region 10
Seattle, Washington
In addition to the information provided in Application Appendix H, Closure/ Post-
Closure Plan, the following pages contain PCB-specific Closure/Post-Closure Plan
information excerpted from the Final Application for Commercial Disposal of
Polychlorinated Biphenyls (PCBs) under the Toxic Substances Control Act
(TSCA), Chemical Waste Management of the Northwest, Inc. (CWMNW), received
by U.S. Environmental Protection Agency, Region 10 on May 12, 2023
-------
3.31.
[40 C.F.R. §761.65(d)(3)(viii)] Written Closure Plan
CWMNW has included the TSCA. required closure elements in the sections below of this
application. CWMNW has included the RCRA Part B Permit Attachment #5 - Closure Post
Closure Plan for information on RCRA closure activities that will be occurring in parallel with
the RSCA. Closure Plan.
3.36. [40 C.F.R. §761.65(d)(6)] RCRA Closure Plan
This document is to ensure compliance with all requirements of 40 CFR 761.65 as described
below
(e) Closure
(1) A commercial storer ofPCB waste shall have a written closure plan that identifies the
steps that the owner or operator of the facility shall take to close the PCB waste storage
facility in a manner that eliminates the potential for post-closure releases of PCBs which
may present an unreasonable risk to human health or the environment. An acceptable
closure plan must include, at a minimum, all of the following:
(i) A description of how the PCB storage areas of the facility will be closed in a manner that
eliminates the potential for post-closure releases of PCBs into the environment.
Long term storage on PCB Items and containers are stored in units S-2, S-l 1, B-5, B-6.
B-7 and B-8. Storage building S-2 will remain after closure. Units S-l 1, B-5, B-6. B-7
and B-8 will be closed in compliance with the provisions outlined in the facilities
Attachment #5 - Closure Post Closure Plan. Samples of materials from these units will
also be analyzed for PCB contamination prior to disposal in the on-site landfill to
ensure the potential for post-closure releases of PCBs do not present an unreasonable
risk to human health or the environment.
(ii) An identification of the maximum extent of storage operations that will be open during
the active life of the facility, including an identification of the extent ofPCB storage
operations at the facility relative to other wastes that will be handled at the facility.
The maximum amounts stored at the facility are as follows:
• 44 - 55 gallon drums of PCB items with concentrations >500 ppm
• 5,000 tons of PCB containing remediation soils and dredge may be stored prior to
processing in Building B-6 or B-8 with concentrations >50ppm but <500ppm.
Amounts of these wastes such will likely have PCB contamination in addition to
other contaminants, many of these projects may exceed 100,000 tons annually.
These remediation wastes are primarily from remediation projects where PCB
contamination is identified as one of the many constituents in matrixes with other
RCRA contaminants. Some of these materials may require stabilization or
solidification prior to disposal in the on-site landfill. Stabilization and/or
Solidification of these wastes will occur in Buildings B-6 and B-8, please refer to
RCRA Part B Attachment #10 - Stabilization and Debris Treatment Plan for
-------
specific information. Costs for these operations are included in the RCRA Permit
Financial Assurance calculations. Increases to these storage volumes do not affect
the supplemental TSCA. financial assurance requirements
(Hi) An estimate of the maximum inventory of PCB wastes that could be handled at one time
at the facility over its active life, and a detailed description of the methods or arrangements
to be used during closure for removing, transporting, storing, or disposing of the facility's
inventory of PCB waste, including an identification of any off-site facilities that will be used.
CWMNW estimates it will accept 12,000,000.00 Kilograms ( -13,227 tons) of PCB
wastes from manufactured PCB items and dielectric fluids annually for storage and/or
disposal during the life of the facility. Amounts of other wastes such as materials from
remediation projects will likely have PCB contamination in addition to other
contaminants, many of these projects exceed 100,000 tons annually. These remediation
wastes are primarily from remediation projects where PCB contamination is identified
as one of the many constituents in matrixes with other RCRA contaminants. Some of
these materials may require stabilization or solidification prior to disposal in the on-site
landfill. Stabilization and/or Solidification of these wastes will occur in Buildings B-6
and B-8, please refer to RCRA Part B Attachment #10 - Stabilization and Debris
Treatment Plan for specific information. Closure costs for the stabilization and/or
solidification of these materials are covered in the RCRA financial assurance
mechanism.
(iv) A detailed description of the steps needed to remove or decontaminate PCB waste
residues and contaminated containment system components, equipment, structures, and soils
during closure in accordance with the levels specified in the PCB Spills Cleanup Policy in
subpart G of this part, including a description of the methods for sampling and testing of
surrounding soils, and the criteria for determining the extent of removal or decontamination.
CWMNW will follow the facilities removal and decontamination plan described in
Attachment #5 - Closure Post Closure Plan. Buildings B-6 and B-8 may store, treat,
and process wastes with PCB concentrations >50ppm but <500ppm generally from
large remediation projects. Remediation type wastes containing PCB contamination
stored in Buildings will be treated in accordance with RCRA Part B Attachment #10 -
Stabilization and Debris Treatment Plan prior to disposal in the on-site landfill. All
building demolition closure materials will be tested for PCBs as part of the sampling
program described in RCRA Attachment #5- Closure Post Closure Plan. PCBs items
with concentrations <500ppm will be disposed in the on-site landfill. Wastes with PCBs
>500ppm are not expected from these remediation projects.
CWMNW will process three 250 ton batches of materials containing <50 ppm PCBs
through building B-6 and B-8 treatment unit processing equipment prior to closure.
These piles will be sampled and analyzed in compliance with RCRA Attachment #1 -
Waste Analysis Plan for the appropriate LDR constituents along with PCBs, if PBCs
are found to be <50ppm in these batches the equipment will be considered
decontaminated and will be disposed in compliance with RCRA Attachment #1 -
Waste Analysis Plan in the on-site landfills. Should confirmatory testing identify PCB
-------
concentrations >50 ppm additional 250 ton batches of materials containing <50 ppm
PCBs will be processed through the equipment and analyzed as previously discussed.
(v)A detailed description of other activities necessary during the closure period to ensure
that any post- closure releases of PCBs will not present unreasonable risks to human
health or the environment. This includes activities such as ground-water monitoring, run-
on and run-off control, and facility security.
CMWNW will follow the procedures contained in RCRA Attachment #5- Closure
Post Closure Plan to ensure that any post-closure releases of PCBs will not present
unreasonable risks to human health or the environment.
(vi) A schedule for closure of each area of the facility where PCB waste is stored or handled,
including the total time required to close each area of PCB waste storage or handling, and
the time requiredfor any intervening closure activities.
CMWNW will adhere to closure timeframes identified in RCRA Attachment #5 -
Closure Post Closure Plan. CWMNW has been granted extensions of the 180 day
closure timeframes for treatment and disposal units, please refer to RCRA Attachment
#5 - Closure Post Closure Plan.
(vii) An estimate of the expected year of closure of the PCB waste storage areas, if a trust fund
is opted for as the financial mechanism.
CWMNW estimates complete closure of the facility in the year 2123. Many factors may affect
this estimate including but not limited to inbound volumes of wastes into the facility and
regional storage and transfer requirements.
(3) A separate and new closure plan need not be submitted in cases where a facility is
currently covered by a TSCA approval or a RCRA permit, upon a showing to the satisfaction
of the Regional Administrator (or the appropriate official at EPA Headquarters, if the
commercial storage area is ancillary to a disposal facility for which an official at EPA
Headquarters has approval authority) that the existing closure plan is substantially equivalent
to closure plans required under paragraphs (d) through (g) of this section, and that the plan
adequately accounts for PCB waste inventories.
CWMNW is submitting this supplemental TSCA Closure Post Closure plan as a
supplement to the facilities RCRA Closure Post Closure plan and identifies all
necessary TSCA related Closure Post Closure related requirements
(4)(i) Changes in ownership, operating plans, or facility design affect the existing closure plan,
(ii) There is a change in the expected date of closure, if applicable.
(Hi) In conducting closure activities, unexpected events require a modification of the approved
closure plan.
-------
CWMNW will submit all required modifications to the TSCA. closure supplement to
EPA headquarters.
(5) The Regional Administrator or the Director, appropriate official at EPA Headquarters, if
an official at EPA Headquarters approved the closure plan, may modify the existing closure
plan under the conditions described in paragraph (e)(4) of this section.
CWMNW Understands this requirement
(6) Commercial storers ofPCB waste shall comply with the following closure schedule:
(i) The commercial storer shall notify in writing the Regional Administrator or the
Director, Office of Resource Conservation and Recovery, if an official at EPA
Headquarters approved the closure plan, at least 60 days prior to the date on which final
closure of its PCB storage facility is expected to begin.
CWMNW will notify in writing the Regional Administrator at least 60 days prior to the
date on which final closure of its PCB storage facility is expected to begin
(ii) The date when a commercial storer ofPCB waste "expects to begin closure " shall be no
later than 30 days after the date on which the storage facility received its final quantities of
PCB waste. For good cause shown, EPA may extend the date for commencement of closure
for an additional 30-day period.
CWMNW will make notification of unit closure at least 30 days after last waste receipt
(Hi) Within 90 days after receiving the final quantity ofPCB waste for storage, a commercial
storer of PCB waste shall remove all PCB waste in storage at the facility from the facility in
accordance with the approved closure plan. For good cause shown, EPA may approve a
reasonable extension to the period for removal of the PCB waste.
During initial closure period after last waste has been received CWMNW will remove
or dispose PCB waste from the facility.
(iv) A commercial storer ofPCB waste shall complete closure activities in accordance with
the approved closure plan and within 180 days after receiving the final quantity ofPCB
waste for storage at the facility. For good cause shown, EPA may approve a reasonable
extension to the closure period.
CMWNW will adhere to closure timeframes identified in RCRA Attachment #5 -
Closure Post Closure Plan. CWMNW has been granted extensions of the 180 day
closure timeframes for treatment and disposal units, please refer to RCRA Part B
Attachment #5 - Closure Post Closure Plan.
(7) During the closure period, all contaminated system component equipment, structures, and
soils shall be disposed of in accordance with the disposal requirements of subpart D of this
part, or, if applicable, decontaminated in accordance with the levels specified in the PCB
Spills Cleanup Policy at subpart G of this part. When PCB waste is removed from the storage
-------
facility during closure, the owner or operator becomes a generator of PCB waste subject to
the generator requirements of subpart J of this part.
CWMNW will follow the facilities removal and decontamination plan described in
Attachment #5 - Closure Post Closure Plan. Buildings B-6 and B-8 may store, treat,
and process wastes with PCB concentrations >50ppm but <500ppm generally from
large remediation projects. Remediation type wastes containing PCB contamination
stored in Buildings will be treated in accordance with RCRA Part B Attachment #10 -
Stabilization and Debris Treatment Plan prior to disposal in the on-site landfill, please
refer to RCRA Part B Permit attachment #10. All building demolition closure materials
will be tested for PCBs as part of the sampling program described in RCRA
Attachment #5- Closure Post Closure Plan. PCBs items with concentrations <500ppm
will be disposed in the on-site landfill. Wastes with PCBs >500ppm are not expected
from these remediation projects.
CWMNW will process three 250 ton batches of materials containing <50 ppm PCBs
through building B-6 and B-8 treatment unit processing equipment prior to closure.
These piles will be sampled and analyzed in compliance with RCRA Attachment #1 -
Waste Analysis Plan for the appropriate LDR constituents along with PCBs, if PBCs
are found to be <50ppm in these batches the equipment will be considered
decontaminated and will be disposed in compliance with RCRA Attachment #1 -
Waste Analysis Plan in the on-site landfills. Should confirmatory testing identify PCB
concentrations >50 ppm additional 250 ton batches of materials containing <50 ppm
PCBs will be processed through the equipment and analyzed as previously discussed.
(8) Within 60 days of completion of closure of each facility for the storage of PCB waste, the
commercial storer of PCB waste shall submit to the Regional Administrator (or the Director,
Office of Resource Conservation and Recovery, if an official at EPA Headquarters approved
the closure plan), by registered mail, a certification that the PCB storage facility has been
closed in accordance with the approved closure plan. The certification shall be signed by the
owner or operator and by an independent registered professional engineer.
CWMNW will submit by registered mail within 60 days of closure of each unit, a
certification that the PCB storage facility has been closed in accordance with the approved
closure plan. The certification will be signed by the owner or operator and by an independent
registered professional engineer
3.37. [40 C.F.R. §761.65(e)| Closure
CWMNW understand the requirements of this section, long term storage on PCB Items and
containers are stored in units S-2, S-l 1, B-5, B-6. B-7 and B-8. Storage building S-2 will
remain after closure. Units S-l 1, B-5, B-6. B-7 and B-8 will be closed in compliance with the
provisions outlined in the facilities Attachment #5 - Closure Post Closure Plan. Samples of
materials from these units will also be analyzed for PCB contamination prior to disposal in the
on-site landfill to ensure the potential for post-closure releases of PCBs do not present an
unreasonable risk to human health or the environment.
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Approval Attachment 2
PCB Operations Plan
(Application Appendix A, received by U.S EPA May 12, 2023,
updated August 11, 2023)
Approval for Commercial Disposal of Poly chlorinated Biphenyls
Chemical Waste Management of the Northwest, Inc.
Arlington, Oregon
U.S. EPA ID: ORD089452353
U.S. Environmental Protection Agency, Region 10
Seattle, Washington
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APPENDIX A
PCB Operations Plan
For
Chemical Waste Management of the Northwest, Inc.
Received by EPA Region 10 on May 12, 2023
updated August 11, 2023
Appendix to CWMNW's final TSCA PCB application
Arlington Facility • ORD 089 452 353
17629 Cedar Springs Lane
Arlington, Oregon
1-1
Final CWMNW PCB Ops Plan, Appendix A to application; received by EPA 05/12/2023
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CWMNW PCB Operations Plan 1-4
1 General Facility Description 1-4
1.1 Expected Waste Volumes 1-5
1.2 Maximum Amounts Stored 1-5
1.3 TSCA Waste Storage Considerations 1-5
Figure 1-0 Site Location Map 1-7
Figure 1 -2 CWM Site Plan 1 -8
Figure 1-3 CWM Building S-2 Layout 1-9
2 Waste Acceptance Procedures 2-1
2.1 Introduction 2-1
2.2 Waste Identification Procedures 2-1
2.3 Waste Acceptance Procedures 2-1
2.4 PCB Manifests 2-2
2.4.1 Manifest Discrepancies 2-2
3 Records and Reports 3-2
3.1 Introduction 3-2
3.2 PCB Identification Records 3-2
3.2.1 PCB Acceptance Records 3-3
3.2.2 PCB Transfer/Rejection Records 3-3
3.2.3 PCB Storage Records 3-3
3.2.4 PCB Treatment Records 3-3
3.2.4.1 Drain and Flush Records 3-3
3.2.4.2 Stabilization Records - 3-4
3.2.4.3 Immobilization (Micro and Macro-encapsulation) 3-4
3.2.5 PCB Disposal Records 3-4
3.2.6 Monitoring Records 3-5
3.2.7 Long-Term Record Maintenance [761.180.(d)] 3-5
3.2.8 Other Records 3-5
3.3 Reports 3-5
3.3.1 Annual Document Log 3-5
3.3.2 Annual Report 3-6
3.3.3 Exception Report 3-7
3.3.4 One-Year Exception Report 3-7
3.3.5 Un-manifested Waste Report 3-8
3.3.6 Other Reporting 3-8
4 Landfill Operations 4-8
4.1 Introduction 4-8
4.2 Liner Design of Landfill Units 4-8
4.3 Deposition of Waste and Backfilling 4-8
4.4 Burial Coordinates 4-9
4.5 Landfill Leachate and Run-on Media Testing 4-9
4.6 Sampling and Monitoring Equipment and Facilities Available 4-9
5 Disposal and Treatment 5-1
1-2
Final CWMNW PCB Ops Plan, Appendix A to application; received by EPA 05/12/2023
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5.1 Landfill Disposal 5-1
5.2 Drain and Flush 5-2
5.3 Stabilization 5-2
5.4 PCB Storage/Transfer Operations 5-3
5.5 Storage Limitations 5-3
5.6 Containers 5-4
5.7 Container Marking Formats 5-4
5.8 PCB Decontamination 5-5
5.9 PCB Item Inspection 5-5
6 Groundwater Management 1
7 Preventive Contingency and Security Measures 1
7.1 Contingency Plan 1
7.2 Security Measures 1
8 Roadway Use and Vehicle Movement 1
8.1 Contamination Control 1
APPENDIX A - EPA Approval Letters 3
1-3
Final CWMNW PCB Ops Plan, Appendix A to application; received by EPA 05/12/2023
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CWMNW PCB Operations Plan
Preface
Chemical Waste Management of the Northwest, Inc. (CWMNW), has prepared this PCB
Operation Plan as required by the Code of Federal Regulation (CFR); Title 40, Part 761.
This PCB Operation Plan includes detailed procedures which demonstrate the methods used at
the Chemical Waste Management of the Northwest, Inc. (CWMNW) Arlington Facility to
comply with applicable regulatory requirements from the Toxic Substances Control Act (TSCA),
40 CFR 761 and Oregon Administrative Rule (OAR) Chapter 340 Division 110. Historically the
facility's TSCA permit has been included in the facility's RCRA Part B Permit, with the PCB
Operations Plan also being part of the RCRA Part B Permit. CWMNW has been approved to
manage polychlorinated biphenyls (PCBs) for treatment, storage, and disposal since 1996.
At the request of EPA Region X (EPA-X) and Oregon Department of Environmental Quality
Hazardous Waste Division (ODEQ) has separated the existing TSCA permit documents from the
current RCRA Permit. Having been determined that a new application is required, CWMNW has
submitted an application to renew the approval for CWMNW facility to manage PCB wastes in
accordance with 40 CFR, §§761.60, 761.65 and 761.75.
1 General Facility Description
CWMNW manages PCB wastes using one or more of the following procedures:
• Storage
• Storage and Transfer
• Drain and Flush
• Immobilization
• Stabilization (PCB wastes contaminated with RCRA constituents)
• Landfilling
PCB wastes are received in bulk form or in containers.
CWMNW is approved to process TSCA regulated (40 CFR Part 761) PCB articles and wastes at
the following waste management units:
\V\ll
Process
A|")|")i"o\ ill Request
1 .andfill L-14
Cells 1-4(A-Cy
Landfill Disposal
Renewal of existing
TSCA permit.
Landfill L-14
Cells 5 - 8
Landfill Disposal
New Approval
Landfill L-15
Cells 1 - 4
Landfill Disposal
New Approval
PCB Flushing/Storage
Unit S-2, S-ll
Draining/flushing, repacking,
bulking, and storage.
Renewal of existing
TSCA permit.
PCB Flushing/Storage
Unit B-5, B-6, B-7, B-8
Draining/flushing, repacking,
bulking, solidification/stabilization
and storage.
New Approval
Waste management units are confined to the active area of the site. Container and
bulk storage areas, containment storage buildings, surface impoundments, stabilization bins, the
organic recovery units, wastewater treatment plants, and landfills comprise the major RCRA
waste management units at the site.
1-4
Final CWMNW PCB Ops Plan, Appendix A to application; received by EPA 05/12/2023
-------
Figures 1-0, 1-2 and 1-3 showing the facility location, layout and building S-2 plans are provided
below. PCBs are stored in storage Units S-2, S-l 1, B-5, B-6, B-7, and B-8.
1.1 Expected Waste Volumes
CWMNW stores and disposes of PCB wastes from manufactured PCB items and dielectric
fluids, in addition CWMNW primarily stores, treats, and disposes of wastes as a result of one-
time remediation projects. The amounts of wastes from manufactured PCB items and dielectric
fluids for the last 5 years are shown below:
5 year PCB Waste Acceptance Volumes
Year
PCB Kilograms
2016
5,346,240
2017
9,447,354
2018
7,052,914
2019
2,040,005
2020
1,104,629
PCB activity from wastes originating from manufactured PCB items and dielectric fluids is
based on the life of the permitted landfills (approx. 50 to 100 years). Landfill L-14 has an
approximate remaining capacity of 6.5 million yards. Landfill L-15 has an approximate
permitted capacity of 80 million cubic yards. Kilogram volume is dependent on each wastes
density per cubic yard and cannot be approximated, however CWMNW has used 1.6 tons per yd3
as an average density. To estimate the annual volume expected of these wastes, CWMNW
estimates that 1% of its permitted landfill volume will be used by PCB wastes. Taking the 86
million yd3 of available airspace divided by the midpoint in the facility life of 75 years results in
approx. 13,000 tons of annual PCB volumes. Therefore:
CWMNW estimates it will accept 12,000,000.00 Kilograms (-13,227 tons) of PCB wastes from
manufactured PCB items and dielectric fluids annually for storage and/or disposal during the life
of the facility.
1.2 Maximum Amounts Stored
The maximum amounts stored at the facility are as follows:
RCRA Solids
TSCA Capacity
TSCA Solids
Total Waste Unit Storage Capacity
Capacity Yd3
Containers Gal
Capacity Yd3
Building S-2
NA
2420
NA
Container S-l 1 (Inside S-2)
NA
NA
Building B-5 Solids Storage
58,833
Building B-6 Solids Storage
16,710,000
5,000
Building B-7 Solids Storage
5,570,000
Building B-8 Solids Storage
5,570,000
5,000
Total Waste Inventory
27,908,833
2,420
10,000
1.3 TSCA Waste Storage Considerations
Building S-2 include Container S-l 1 Maximum storage in S-l 1 is 44 - 55 gallon drums of PCB
items with concentrations >500 ppm
Buildings B-6 and B-8 manage remediation soils and dredge, maximum storage prior to
treatment of these materials with PCB concentrations >50ppm and <500ppm is 5,000 tons.
1-5
Final CWMNW PCB Ops Plan, Appendix A to application; received by EPA 05/12/2023
-------
Remediation wastes with PCB concentrations >500ppm are not expected. Many of these
projects are projected to exceed 100,000 tons annually. These remediation wastes are primarily
from remediation projects where PCB contamination is identified as one of the many
constituents in matrixes with other RCRA contaminants. Some of these materials may require
stabilization or solidification prior to disposal in the on-site landfill. Stabilization and/or
Solidification of these wastes will occur in Buildings B-6 and B-8, please refer to RCRA Part B
Attachment #10 - Stabilization and Debris Treatment Plan for specific information.
1-6
Final CWMNW PCB Ops Plan, Appendix A to application; received by EPA 05/12/2023
-------
Figure 1-0 Site Location Map
S C 5 ENGINEERS
PROJECT MO
01200266.04
D6SBY
UEL
FACILITY LOCATION MAP
CHEMICAL WASTE MANAGEMENT OF THE NORTHWEST, INC
ACDP MODIFICATION APPLICATION
DATE
January 2021
Environmental Consultants and Contractors
2405140th Avenue NE, Suite 107
Bellevue, Washington 93005
{425)746-4600 FAX: (425) 746-6747
SCALE
N.T.S.
CH< BY
EMS
FIGURE
1-0
CAD FIE
FIGURE t
AFP BY
PSS
Pointer 4S,40 29 2S'N 120J11'56.42'W
COLUMBIA RIVER
PROJECT SITE
1-7
Final CWMNW PCB Ops Plan, Appendix A to application; received by EPA 05/12/2023
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Figure 1-2 CWM Site Plan
LEGEND:
Evapora:icn
Pond P-C4
B-6 Module'
B-6Mocule2
D-6 Module 3
Evaporation
Pord P-E1
WWT-2
WWT-31
Stormwster
> Pond
SW Pond I S-2 '
———S-11
Cell4C
Evaoorstion
Pord P-C3
ypSile Wells.
TranspotationYa'di
Fuel Stafon
-ci ipfie-i:
Maint Facility"
OffmpyMainl
Facility'
Stormweler
Pond
Statloi/
Compound
Trarispurlatiuii
w
CHEMICAL WASTE MANAGEMENT
OF THE NORTHWEST, INC.
ARLINGTON, OREGON
TSCA Permit Figure 1-2
OR02 - 2236
Figure 1-2
Evapo'aiicn
Porcl P-E3
Evaporation
Pond P-D2
1-8
Final CWMNW PCB Ops Plan, Appendix A to application; received by EPA 05/12/2023
REFERENCE (3;
; 1. TOPOGRAPHIC MAP PERFORMED BY MILLER CREEK ON APRIL 24, 2019.
Horizontal Datum: NAD 83 '2011 OR N (3601)
-Vertical Datum: NAVD 88
Lint of Measure: International Foot
Da:um SNft from Site Historical Vertical Datum: +3.37' (CWMNWj
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Figure 1-3 CWM Building S-2 Layout
1A1WI
Protect Location:
CHEMICAL WASTE MANAGEMENT
OF THE NORTHWEST, INC,
ARLINGTON, OREGON
i p
OR02 - 2238
TSCA Permit Figure 1-3
Stieet Number
Figure 1-3
im
Rejected Container Staging Area
4 - Intermodal Containers
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2 Waste Acceptance Procedures
2.1 Introduction
Types of PCB wastes accepted at the Arlington Facility include PCB solids, Sludges, and liquids
delivered to the site in bulk or containers. Articles, equipment, and clothing containing or
contaminated with PCBs (e.g., PCB capacitors and transformers, gloves or aprons from draining
operations, or empty drums that formerly held PCBs) are also accepted at the site.
Waste acceptance procedures for PCB wastes are, in general, similar to procedures for
acceptance and analysis of other wastes received at the site. These procedures are described in
the facility's RCRA Part B Permit Attachment #1 - Waste Analysis Plan (WAP) and are
referenced where applicable in the following discussion. Specific waste acceptance procedures
applicable to PCB wastes are described in detail below.
Liquid PCBs are not disposed in any landfill at the facility. PCB containing wastes with PCB
concentrations of 50 ppm or less are solidified to meet free liquid requirements and disposed in
the on-site landfills. Liquid PCB containing wastes with concentrations between 5 lppm and
500ppm that are from incidental sources and non-ignitable may be solidified to meet free liquid
requirements and disposed in the on-site landfills. PCB fluids with concentrations above 500ppm
that are not from an incidental source are shipped offsite for incineration
2.2 Waste Identification Procedures
CWMNW has developed a series of control procedures to determine the acceptability of specific
wastes for receipt at the facility. The pre-acceptance control procedures dictate what information
a potential customer must provide to enable CWMNW to determine the acceptability of the
waste for storage, treatment, or disposal. Pre-acceptance control is the mechanism for deciding
to reject or accept a particular type of waste prior to its shipment to the facility based on the
conditions or limitations of existing permits, and its compatibility with other wastes being stored,
treated, or disposed of at the facility.
2.3 Waste Acceptance Procedures
Upon arrival at the facility, each load of waste will be inspected, sampled, and analyzed as
detailed by CWMNW's WAP before initiation of any further activity. This serves two purposes:
• compares the actual waste characteristics supplied by the generator and the information
determined in the pre-acceptance phase, with the information listed on the manifest, and
• further ensures the proper disposition of the waste to treatment, storage, or disposal.
Un-manifested PCB waste are not accepted for treatment, storage, or disposal by CWMNW.
If an un-manifested shipment of PCB waste arrives at the facility, receiving personnel will
attempt to contact the generator, using information supplied by the transporter, to obtain a
manifest, or to return the PCB waste.
CWMNW personnel ensure that all PCB transformers, capacitors, electrical equipment, and
other PCB articles are destined for disposal at the facility's landfill are free of liquids or empty as
required by 40 CFR 761.60. PCB articles that are not empty are either drained and flushed in
accordance with Section 5.2 and procedures specified in 40 CFR 761.60(b) or stored at the
facility until off-site shipment to an incinerator or appropriate treatment facility is arranged.
After waste acceptance procedures are completed, CWMNW personnel direct the vehicle to the
appropriate facility's on-site treatment, storage, or disposal area.
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2.4 PCB Manifests
CWMNW will only accept Generator manifests that are from approved printing source approved
under 40 CFR 262.21 (c) and (e).
Upon receipt of PCB waste shipped on a manifest under 40 CFR Part 761.207, CWMNW will
manage the manifest in accordance with 40 CFR Part 761.213.
When acting as the generator of a PCB waste CWMNW will obtain, prepare, and utilize the
manifest, EPA Form 8700-22, in accordance with 40 CFR Parts 761.207 through 210 and
761.180(b)(4). Records of each signed manifest will be maintained in accordance with 40 CFR
Part 761.214(a)(1) and 761.180(b)((l)(i). Periods of retention are extended automatically during
unresolved enforcement action regarding the regulated activity or as requested by the
Administrator in accordance with 40 CFR Part 761.214(e).
2.4.1 Manifest Discrepancies
If possible, manifest discrepancies are resolved by contacting the generator to properly complete
the needed information on the waste shipment. Significant manifest discrepancies will
necessitate the completion of a Manifest Discrepancy Report if they are not resolved within 15
days in accordance with 40 CFR Part 761.215(c).
Significant manifest discrepancies are differences in the quantity or type of waste received.
Significant discrepancies in quantities are:
• Greater or less than 10 percent difference in manifested weight for bulk shipments
• Incorrect piece count for smaller size multiple container shipments
Significant discrepancies in waste type are obvious differences that can be discovered by
inspection or waste analysis as conducted using fingerprint procedures, such as a waste
flammable solvent substituted for a PCB-contaminated liquid. These are resolved with the
generator, if possible, by correctly identifying the waste. If the waste is identified as another
approved waste stream, it is tested and may be accepted if it matches the Waste Profile
characterization. Significant discrepancies that cannot be resolved with the generator will result
in rejection of the shipment and its return to the generator. CWMNW returns rejected shipments
of PCB waste to the generator and does not send rejected wastes to an alternate facility.
3 Records and Reports
3.1 Introduction
PCB liquids, PCB contaminated liquids, and PCB solids are routinely received for treatment,
storage and disposal. Depending on the concentration of PCBs contained in the PCB liquids and
PCB contaminated liquids, they may be transferred to another permitted facility for required
treatment (e.g, incineration). Procedures for maintaining auditable records for receipt,
identification, transfer, storage, treatment, drain and flush, and disposal of PCBs are described in
this section. Records corresponding to groundwater and leachate monitoring are also generally
described in this section. Records will be managed electronically and/or by hard copy in the
Operating Record.
3.2 PCB Identification Records
PCB identification documents specify the physical state of the PCB waste, the name of the
waste, the process generating the waste, and indicate if the PCB content of the waste is greater
than 500 parts per million (ppm). Determination of PCB concentration is based upon
1) laboratory analysis performed by an EPA-qualified laboratory, or
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2) A written statement from the generator, signed by a responsible individual,
providing technical justification for the determination that the liquid contains less
than 500 ppm PCBs.
Alternately, PCB liquids may be shipped off site for incineration without verification of PCB
content.
3.2.1 PCB Acceptance Records
All PCB waste arriving on site is documented and inspected. A Load Inspection Sheet is
completed for each PCB shipment to facilitate inspection and acceptance procedures. After the
PCB waste is received, CWMNW personnel sign the manifest and provide copies of the manifest
to the transporter and generator in accordance with 40 CFR 761.213(a).
3.2.2 PCB Transfer/Rejection Records
As PCB wastes are transferred from storage to treatment to disposal or off-site shipment,
documentation of these transfers are recorded on waste transfer logs. The date of transfer, the
specific type of waste, unique load number, and weight or quantity of PCB Items transferred are
recorded on the log.
For rejected loads CWMNW is required to prepare a manifest (EPA Form 8700-22) to transport
a rejected load of PCB waste or transport PCB waste offsite. Each manifest is required to contain
the information in 761.207(a)(l-3) as applicable. The information on the manifest must also meet
the requirements in 761.207(b-f), such as name of the facilities approved to handle the waste.
CWMNW returns rejected shipments of PCB waste to the generator and does not send rejected
wastes to an alternate facility.
3.2.3 PCB Storage Records
A PCB storage form is maintained for all PCB waste placed in storage at the facility. The
information recorded on this form includes the date the material is placed into and removed from
storage, the unique load number of the waste, the number and type of containers, and other
information as needed. This information is also recorded in the facility's computer tracking
system.
3.2.4 PCB Treatment Records
3.2.4.1 Drain and Flush Records
Documentation of drain and flush activities for transformer, capacitors, and other electrical
equipment is maintained on a transformer processing form.
Information recorded on the form includes the following:
• generator name (from manifest)
• removed from service date
• date the PCB article was received at the Arlington Facility
• unique load number
• amount of oil drained from the article
• amount of diesel or alternate flushing solution in accordance, with 40 CFR
761.60(b)(l)(i)(B) used to fill the article
• length of time that the article was filled with the flushing, solution (a minimum of 18
hours) and
• location where the drained oil and flushed solution will be, stored (tank number or
drum number).
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3.2.4.2 Stabilization Records -
Waste identification records for materials requiring stabilization specify a Stabilization
Evaluation Test (SET). The SET is recorded on a stabilization form and represents the amount
of reagents required to stabilize that particular waste stream. Information recorded on the
stabilization form includes the following:
• date
• EPA codes
• generator
• mix ratio
• stabilization unit bin number, and
• certification and signature.
See Section 5.3 for more information on operational procedures
3.2.4.3 Immobilization (Micro and Macro-encapsulation)
Micro-encapsulation: Waste identification records for materials requiring microencapsulation
specify a mix ratio dependent on the type of RCRA codes present in the waste. Information
recorded on the Micro-encapsulation form includes the following:
• date
• EPA codes
• generator
• mix ratio
• stabilization unit bin number, and
• certification and signature
See Section 5.3 for more information on operational procedures
Macro-encapsulation: Waste identification records for materials requiring macro-encapsulation
are maintained on a Macro-encapsulation Processing Form. The form contains the following
information:
• start date
• end date
• part number
• load number
• profile number
• EPA codes; and
• certification statement and signature
See Section 5.3 for more information on operational procedures
3.2.5 PCB Disposal Records
A Certificate of Disposal (CD) is prepared and submitted to the generator of all PCBs disposed
of in the facility's landfill. The certificate is submitted within 30 days of the disposal date and
includes the following information:
• the Name, Address, and EPA Identification Number of the disposal facility
• the identity of the PCB waste disposed of, including reference to the manifest number
of the shipment
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• a statement certifying that the waste was disposed on site, including the date of
disposal and the process used, and
• a certification statement as defined in 40 CFR 761.3.
In accordance with 40 CFR 761.75(b)(8)(iv), records of the disposal location of PCBs buried in
the landfill are maintained on a three-dimensional grid. Information maintained on the grid
regarding the location of all PCBs disposed in the landfill is incorporated into CWMNW's
computer tracking system. The grid map includes the unique load number of the disposed PCB
waste and can be tracked back to the manifest that accompanied the PCB shipment, as well as the
chemical and physical makeup of the incoming PCBs. Liquid PCBs are not disposed of in the
landfill.
3.2.6 Monitoring Records
As required by 40 CFR 761.75(b)(6), records of groundwater and leachate sampling and analysis
are maintained at the facility electronically or by hard copy in the facilities operating record.
3.2.7 Long-Term Record Maintenance [761.180.(d)]
Records, documents, and reports pertaining to PCB landfill disposal at the facility will be
maintained electronically or by hard copy in the facilities operating record at least 20 years after
the landfill is no longer used to dispose of PCB wastes (or for the length of time necessary to
satisfy the regulatory requirements), after the landfill is closed.
3.2.8 Other Records
CWMNW will maintain the following Records in compliance with 761.180 electronically or by
hard copy in the facilities operating record
• Inspections and cleanups per 761.180(b)(l)(iii)
• Special records as required by 761.180(f), such as documents, correspondence, and data
by or to any State or local government agency, and applications and related
correspondence to any local, State, or Federal authorities
3.3 Reports
3.3.1 Annual Document Log
The written annual document log will be prepared by July 1, for the previous calendar year. The
log includes information on the Arlington Facility in addition to PCB waste received, stored,
generated, and disposed at the facility in accordance with 40 CFR 761.180(b)(2). Information
required on the log is as follows:
• Name, Address, and EPA Identification Number of the storage or disposal facility
covered by the annual document log for the calendar year
• Manifest numbers generated or received by the facility during the calendar year, the
unique manifest number and the name and address of the facility that generated the
manifest, and the following information:
• Bulk PCB Waste:
• weight (kg)
• date removed from service
• date received at the facility
• date put into transport for off-site storage/disposal (SD)
• date of disposal
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• PCB Article:
• serial number or equivalent of each PCB article
• weight of PCB s in transformer/capacitor (kg)
• date removed from service
• date received at the facility
• date put into transport for off-site storage/disposal
• date of disposal
• PCB Container:
• unique number to identify container
• description of contents
• weight of material in container(kg)
• date that material in container was first removed from service for disposal
• date received at the facility
• date put into transport for off-site storage/disposal
• date of disposal
• PCB Article Container:
• unique number to identify container
• description of contents
• weight of contents (kg)
• date when the first PCB article put in the PCB Article Container was removed
from service for disposal
• date received at the facility
• date placed in transport for off-site storage/disposal
• date of disposal.
3.3.2 Annual Report
The annual report summarizes information retained by the annual document log and additional
operating records. The annual report will be prepared by July 1 for the previous year and
submitted to the EPA by July 15 of each year. The submitted annual report will be signed by the
facility's General Manager or responsible designee, and includes the following information
required by 40 CFR 761.180(b)(3):
• Name, Address, and EPA Identification Number of the facility covered by the annual
report for the calendar year, a list of the numbers of all signed manifests of PCB
waste initiated or received by the facility during that year.
• Total weight in kilograms of bulk PCB waste, PCB waste in transformers, PCB waste
in large capacitors, PCB waste in article containers, and PCB waste in containers, in
storage at the facility at the beginning of the year, received or generated at the
facility, transferred to another facility, or disposed of at the facility during the
calendar year, and
• Total number of PCB transformers, PCB large capacitors, PCB article containers, and
PCB containers, in storage at the facility at the beginning of the year, received or
generated at the facility, transferred to another facility, or disposed of at the facility
during the calendar year.
The information must be provided for each category. Any requirements for weights in kilograms
of PCBs may be calculated values if the internal volume of containers and transformers is known
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and included in the reports together with any assumptions on the density of PCBs in the
containers or transformers.
3.3.3 Exception Report
In accordance with 40 CFR 761.217(a), if CWMNW as a PCB generator does not receive a
signed copy of the manifest from the storage/disposal facility within 35 days from the date that
the waste was accepted from the first transporter, CWMNW will contact the facility to determine
the status of the PCB waste.
An exception report will be submitted to the EPA no later than 45 days from the date on which
the generator should have received the manifest after noting that the following has occurred:
If CWMNW generates a PCB waste, sends if off site for storage or disposal, and does not receive
a copy of a signed manifest within 45 days from the date that the waste was accepted by the first
transporter.
The exception report must include:
• A legible copy of the manifest for which the generator (CWMNW) does not have
confirmation of delivery, and
• A cover letter signed by the generator (or authorized designee) explaining the efforts
taken to locate the PCB waste and the results of those efforts.
3.3.4 One-Year Exception Report
A one-year exception report must be submitted to the EPA as within 45 days after the 1-year
storage for disposal date, per 761.219(a), or 45 days after from the date of the occurrences in
761.219(b)(l-2) after identifying that either of the following has occurred:
• If PCBs are received at CWMNW with a manifest indicating more than nine months
from the removed from service date, and CWMNW could not dispose of the waste
within 1 year after the removed from service date indicated on the manifest or
continuation sheet; or
• If CWMNW, acting as a generator and/or commercial storer, ships PCBs off site less
than nine months from the removed from service date, and CWMNW received a
Certificate of Disposal which indicates that the waste was actually disposed of more
than one year after the removed from service date, or the off-site destination facility
did not send CWMNW a Certificate of Disposal within 13 months from the removed
from service date.
The one-year exception report must include:
• A legible copy of the manifest relevant to the transfer and disposal of the affected
PCB waste,
• A cover letter signed by the General Manager or his designee stating:
• date(s) the PCB waste were removed from service,
• date the PCB waste was received for on-site disposal,
• date the PCB waste was shipped off site,
• name of transporter and designated storage/disposal facility, and
• reason for the delay in bringing about the disposal of the affected PCB waste within
one year from the removed from service date.
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3.3.5 Un-manifested Waste Report
Un-manifested PCB wastes are not accepted for disposal at the Arlington Facility. If an un-
manifested PCB waste arrives at the facility, and attempts to obtain a manifest have failed, then
the waste will be returned to the generator. Within 15 days after receiving the un-manifested
PCB waste, the facility will prepare and submit an un-manifested waste report to the EPA
Regional Administrator for the region in which the facility is located, and to the EPA Regional
Administrator for the region in which the PCB waste originated, if known. EPA Form 8700-13B
may be used, or the report may be submitted by a letter designated "Un-manifested Waste
Report". The report will include the following information:
• EPA Identification Number, Name and Address of the facility,
• Date the facility received the un-manifested PCB waste,
• EPA Identification Number, Name and Address of the generator and transporter, if
available,
• Description of the type and quantity of the unmanifested PCB waste received at the
facility,
• The method of storage or disposal for each PCB waste;
• Signature of the owner or operator of the facility or his authorized representative
• A brief explanation of why the waste was un-manifested, if known, and
• Disposition made of the un-manifested waste by the facility, including:
• if the waste was stored or disposed by the facility, was the generator identified
and was a manifest subsequently supplied,
• if the waste was sent back to the generator, why and when.
3.3.6 Other Reporting
CWMNW understands that should its PCB waste handling practices change, the facility must
resubmit EPA Form 7710-53 to reflect those changes no later than 30 days from when a change
is made, as 761.205(f) states.
4 Landfill Operations
4.1 Introduction
Currently, disposal operations are taking place in Landfills L-14 and in the future landfill L-15.
Landfill design drawings, cross sections, and design details for all non-closed landfill units are
maintained in the facility's RCRA Part B Permit Attachment #18 - Landfill Design Drawings.
Personal Protective Equipment for employees handling PCB items is contained in the facility's
required PPE Personal Protective Equipment and Clothing Chart Matrix, documented in the
facility's OSHA Safety Plans. The PPE Matrix contains requirements for employees handling
PCB items that protect against dermal contact or inhalation of PCBs or materials containing
PCBs.
4.2 Liner Design of Landfill Units
Engineering Design Reports for Landfill L-14 and L-15 are contained in the facility's RCRA Part
B Permit Attachment #18 - Landfill Design Drawings.
4.3 Deposition of Waste and Backfilling
Disposal procedures shall be conducted to prevent the occurrence of:
• Generation of extreme heat or pressure, fire or explosion, or violent reaction,
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• Production of uncontrolled toxic mists, fumes, dust, gases in sufficient quantities to
threaten human health or the environment,
• Production of uncontrolled flammable fumes or gases in sufficient quantities to pose a
risk of fire or explosions, ignitable wastes are not disposed in the landfill in
accordance with the CWMNWs
• Disposal of ignitable wastes in the landfill are specifically restricted by the ODEQ
RCRA Part B permit
• Damage to the structural integrity of the device or facility containing the waste, and
• Threat to human health or the environment.
Procedures for the operation of Landfills L-14 and L-15 are detailed in the facility's RCRA Part
B Permit Attachment #14 - Landfill Design, Operations, and Response Plan.
4.4 Burial Coordinates
PCB waste shall be disposed of in the landfill at CWM following 761.75 requirements. Waste
placement is recorded on a three-dimensional map and in the facilities computerized systems
identifying the specific location of the waste.
4.5 Landfill Leachate and Run-on Media Testing
CWMNW will perform sampling analysis, for run-on accumulated precipitation, and leachate
using SW-846 Methods, 8082a, and other methods as required to properly characterize the
media.
4.6 Sampling and Monitoring Equipment and Facilities Available
CWMNW maintains stocks of manual sampling equipment on-site and employs this equipment
in compliance with the Sampling and equipment methods outlined in Attachment #1 - WAP.
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5 Disposal and Treatment
CWMNW accepts and manages the following types of PCB wastes for the processes below:
• PCB Transformers >500 ppm PCB - received for landfill disposal of the
drained/flushed carcass. The generator must certify that the PCB transformer has been
drained/flushed in accordance with 40 CFR 761.60(b)(1)(B). Waste must contain no free
liquids prior to disposal in the active landfill. Any PCB transformer with free liquids
present will be drained and flushed in accordance with 761.75(b)(8)(ii). Residual liquids
will be sent offsite for incineration.
• PCB Contaminated Transformers >50 ppm but <500 ppm - received for landfilling or
recycling of the carcass (e.g., shipment to a metal smelter subject to 40 CFR 761.72). The
PCB contaminated transformer must arrive drained with no free liquids present prior to
landfilling in the active landfill. Any PCB transformer with free liquids present will be
drained and flushed in accordance with 761.75(b)(8)(ii).
• PCB Contaminated Solids Containing No Free Liquids - received for landfill disposal;
or mixed RCRA/TSCA for stabilization, or encapsulation. These include but are not
limited to contaminated clothing, rags, environmental media, debris, and equipment.
Waste must contain no free liquids prior to landfill disposal in the active landfill.
• PCB Containers - received for disposal in the landfill. The contents of each container
are managed based on the type of PCB material present (solids, transformer, capacitor,
etc.). Waste must contain no free liquids prior to landfill disposal in the active landfill.
Any PCB container received with free liquids will be stabilized in accordance with
Stabilization section below and 761.75(b)(8)(ii).
• PCB Articles and Electrical Equipment - articles/electrical equipment are received for
direct landfill. PCB articles and equipment that would require draining must arrive
drained of free liquids Any PCB articles/electrical equipment with free liquids present
will be stabilized in accordance with Stabilization section below and 761.75(b)(8)(ii).
• PCB Contaminated Articles and Electrical Equipment - articles/electrical equipment
are received for direct landfill. PCB contaminated articles and equipment that would
require draining must arrive drained of free liquids. Any PCB articles/electrical
equipment with free liquids present will be stabilized in accordance with Stabilization
section below and 761.75(b)(8)(ii).
• PCB Remediation Waste - remediation wastes such as soil, concrete, asphalt, etc. are
received for landfill disposal. Waste must contain no free liquids. Any PCB remediation
waste received with free liquids present will be stabilized in accordance with
Stabilization section below and 761.75(b)(8)(ii).
• PCB Bulk Product Waste - PCB bulk product wastes including paint, caulk, mastics,
sealants, and building surfaces that have been coated with these products are received for
landfill disposal. Waste must contain no free liquids. Any PCB bulk product waste
received with free liquids present will be stabilized in accordance with Stabilization
section below.
Personal Protective Equipment for employees handling PCB items is contained in the facility's
required PPE Personal Protective Equipment and Clothing Chart Matrix, documented in the
facility's OSHA Safety Plans. The PPE Matrix contains requirements for employees handling
PCB items that protect against dermal contact or inhalation of PCBs or materials containing
PCBs.
5.1 Landfill Disposal
PCB wastes not passing the paint filter test are not disposed of in the landfill units. All PCB
containing liquids are stabilized prior to disposal in accordance with 761.75(b)(8)(ii).
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Placement of PCB items in the landfills will be in a manner that will prevent damage to
containers or articles, and segregate from items not chemically compatible in accordance with 40
CFR 761.75(b)(8)(i).
Expected volumes of PCBs over the life of landfills L-14 and L-15 is estimated as follows:
PCB Activity is based on the life of the permitted landfills (approx. 50 to 100 years). Landfill L-
14 has an approximate remaining capacity of 6.5 million yards. Landfill L-15 has an approximate
permitted capacity of 80 million cubic yards. Kilogram volume is dependent on each wastes
density per cubic yard and cannot be approximated, however CWMNW has used 1.6 tons per
yd3 as an average density. To estimate the annual volume expected, CWMNW estimates that 1%
of its permitted landfill volume will be used by PCB wastes. Taking the 86 million yd3 of
available airspace divided by the midpoint in the facility life of 75 years results in approx. 13,000
tons of annual PCB volumes. Therefore:
CWMNW expects to accept up to 12,000,000.00 Kilograms (-13,227 tons) of waste annually for
treatment or disposal during the life of the facility.
5.2 Drain and Flush
PCB transformers, capacitors, and other PCB articles containing PCB liquids that are accepted at
the Arlington Facility for disposal that contain PCB liquids will first be drained of free flowing
liquid, filled with solvent, allowed to stand for at least 18 hours, and drained thoroughly. The
flushed PCB liquid will be managed in accordance with 40 CFR 761.60(a). The empty PCB
article may be disposed of in the facility's landfill.
Non-leaking and structurally undamaged PCB Large High Voltage Capacitors and PCB-
Contaminated Electrical Equipment that have not been drained of free flowing dielectric fluid
may be stored on pallets next to a storage Unit. PCB-Contaminated Electrical Equipment that has
been drained of free flowing dielectric fluid is not subject to the storage provisions of § 761.65.
Storage will be permitted only when the facility has immediately available unfilled storage space
equal to 10 percent of the volume of capacitors and equipment stored outside the facility. The
capacitors and equipment temporarily stored outside the facility shall be checked for leaks
weekly.
Containerized PCBs accepted at the facility may be stored in Building S-2, S-l 1, B-5, B-6, B-7,
and B-8 prior to disposal or transferred off-site for management at another permitted facility.
PCBs will be stored in the PCB storage buildings S-2, S-l 1, B-5, B-6, B-7, and B-8 that meets
the criteria listed in 761.65(b)(1), or in accordance with the temporary storage requirements
listed in 761.65(c).
5.3 Stabilization
PCB waste contaminated with both TSCA and RCRA-regulated constituents received at the
facility may be treated by stabilization. These wastes must meet the disposal requirements found
at 40 CFR 761.60. This includes any non-liquid PCBs at concentrations of <500 ppm in the
form of contaminated soil,, sludges, rags, or other debris. In addition, any non-liquid PCB waste
(including sludges) that contain a PCB concentration less than 50 ppm may also be present and
treated in the stabilization unit. PCB debris contaminated with RCRA constituents will be
treated using immobilization processes described in the facility's RCRA Part B Permit
Attachment #10 - Stabilization and Debris Treatment Plan. Dust suppression for soils that could
release particulate emissions during stabilization and handling will be moisture conditioned.
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Free liquids which may accompany a PCB waste contaminated with RCRA-regulated
constituents may be stabilized with the waste on a case-by-case basis. CWMNW will contact the
generator regarding any associated free liquids and attempt to identify the source of the liquid. If
the generator can adequately demonstrate that the liquids are environmental media (e.g.,
rainwater or groundwater) that are incidental to the PCB waste, the free liquids may be stabilized
with the PCB wastes.
5.4 PCB Storage/Transfer Operations
The Design for each storage unit is in accordance with Attachment #9 - Container Storage
Design and Operations Plan, of the RCRA permit.
PCB Storage/Transfer operations of non-leaking PCB Items are conducted in the following units:
• Temporary outdoor storage (<30 days) in units S-6, S-10 and S-12 of containers holding up
to 85 gallons of PCB liquids with a concentration between 50 and 500 ppm (each container is
labeled to indicate the PCB concentration of container contents does not exceed 500 ppm)
• Temporary outdoor storage (<30 days) in units S-6, S-10 and S-12 of leaking PCB
Articles and PCB Equipment if the PCB Items are placed in a non-leaking PCB
Container that contains sufficient sorbent materials to absorb any liquid PCBs remaining in
the PCB Items;
• Temporary outdoor storage (<30 days) in units S-6, S-10 and S-12 of PCB
containers containing non-liquid PCBs such as contaminated soil, rags, and debris
• Temporary and long term (>30 days) storage of containerized PCB liquids and solids, in
Units S-2, S-ll, B-5, B-6, B-7, and B-8.
• Temporary outdoor storage (<30 days) in units S-6, S-10 and S-12 of PCB containers
containing liquid PCBs at concentrations of >50 ppm, provided the liquid PCB waste is in
packaging authorized in the DOT Hazardous Materials Regulations at 49 CFR parts 171
through 180 or stationary bulk storage tanks (including rolling stock such as, but not limited
to, tanker trucks, as specified by DOT).
• Transfer of PCB liquids in Units S-2, S-ll, B-5, B-6, B-7, and B-8.
• Storage in preparation for Stabilization/Solidification of PCB containing clean-up and
remediation soils and sludges with a concentration >50 and <500 ppm in Building B-6 and
B-8
• Storage in preparation for thermal treatment of PCB containing clean-up and remediation
soils and sludges with a concentration >50 and <500 ppm in Building B-6.
PCB Wastes are stored within the above units based on its compatibility with other wastes being
stored.
CWMNW has prepared a Spill Prevention, Control and countermeasure plan for the facility/
Any mobile equipment, such as a forklift, which enters a PCB storage area or building and
comes in contact with PCBs, must be properly decontaminated or verified to be free of PCB
contamination before moving from that structure.
5.5 Storage Limitations
Any PCB wastes received shall be disposed of within 1-year from the date it was determined to
be PCB waste and the decision was made to dispose of it with the exception of wastes stored for
wastes generated from the Portland Harbor Superfund remediation projects have been exempted
per 40 CFR 268.50(b). The waste will be accumulated in the building until they can undergo
5-3
Final CWMNW PCB Ops Plan, Appendix A to application; received by EPA 05/12/2023
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treatment processing by TDU-1. The facility is allowed to store waste pending treatment for
longer than one year, not to exceed the life of the permit.. The 1-year disposal due date starts
from the date of removal from service for disposal begins.
PCB items including organic solvents shall be segregated throughout the waste handling, storage
and disposal activities in accordance with 40 CFR 761.75(b)(8)(i).
5.6 Containers
All PCB waste containers used for the storage of liquid or non-liquid PCB are managed in
accordance with the requirements set forth in the DOT Hazardous Materials Regulations (HMR)
at 49 CFR parts 171 through 180. PCB waste not subject to the HMR (i.e., PCB wastes at
concentrations of <20 ppm or <1 pound of PCBs regardless of concentration) must be packaged
in accordance with Packaging Group III, unless other hazards associated with the PCB waste
cause it to require packaging in accordance with Packaging Groups I or II. For purposes of
describing PCB waste not subject to DOT's HMR on a manifest, one may use the term "Non-
DOT Regulated PCBs."
5.7 Container Marking Formats
Large PCB Mark - Ml . Mark Ml shall be as shown in Figure 1, letters and striping on a white
or yellow background and shall be sufficiently durable to equal or exceed the life (including
storage for disposal) of the PCB Article, PCB Equipment, or PCB Container. The size of the
mark shall be at least 15.25 cm (6 inches) on each side. If the PCB Article or PCB Equipment is
too small to accommodate this size, the mark may be reduced in size proportionately down to a
minimum of 5 cm (2 inches) on each side.
Small PCB Mark - Ms . Mark Ms shall be as shown in Figure 2, letters and striping on a white
or yellow background, and shall be sufficiently durable to equal or exceed the life (including
storage for disposal) of the PCB Article, PCB Equipment, or PCB Container. The mark shall be a
rectangle 2.5 by 5 cm (1 inch by 2 inches). If the PCB Article or PCB Equipment is too small to
CONTAINS f
5 pcbs ;
(Arfychtorinatftd Biphmtytx) !
k A roxic environmental contomfnont requiring ¦
J special handling ond disposal in occordance with j
¦ U.S. Environmental Protection Agency Regulations J|
k 40 CFR 761—For Disposal Information conroa ¦
S ihe nearest U.S. E.P.A. Office. J
S In case of Occident or spill, call toll free the U.S. C
Coast Guard Notionol Response Center r ]
! 500:424-6602 |
5 Abo Contocr
| WNo.
Figure 1
! CAUTION CONTMNS PCBsj
I (ftlychltrinitcd BiplwuyUt |
I FOR WEA DISPOSAL INFORMATION |
k CONTACT U S ENVIRONMENTAL
PROTECTION AGENCY I
Figure 2
accommodate this size, the mark may be reduced in size proportionately down to a minimum of
1 by 2 cm (.4 by .8 inches).
5-4
Final CWMNW PCB Ops Plan, Appendix A to application; received by EPA 05/12/2023
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CWMNW does not accept or store PCB/Radioactive wastes at the facility
CWMNW does not store liquid PCB wastes in stationary containers (tanks) at the facility.
5.8 PCB Decontamination
In accordance with 761.79, CWMNW will follow decontamination standards and procedures for
removing PCBs, which are regulated for disposal, from water, organic liquids, non-porous
surfaces (including scrap metal from disassembled electrical equipment), concrete, and non-
porous surfaces covered with a porous surface, such as paint or coating on metal except for the
following:
Buildings B-6 and B-8 may store and process wastes with PCB concentrations >50ppm but
<500ppm generally from large Superfund remediation projects. All building demolition materials
will be tested for PCBs as part of the sampling program contained in RCRA Attachment #5-
Closure Post Closure Plan. PCBs items with concentrations <500ppm will be disposed in the on-
site landfill. Wastes with PCBs >500ppm are not expected from these remediation projects.
CWMNW will process three 250 ton batches of materials containing <50 ppm PCBs through
building B-6 and B-8 treatment unit processing equipment prior to closure. These piles will be
analyzed for the appropriate LDR constituents along with PCBs, if PBCs are found to be
>50ppm in these batches the equipment will be considered decontaminated and will be managed
in compliance with RCRA Attachment #5 final dispositions. Should confirmatory testing identify
PCB concentrations >50 ppm additional 250 ton batches of materials containing <50 ppm PCBs
will be processed through the equipment and analyzed as previously discussed.
5.9 PCB Item Inspection
All PCB Items in storage shall be checked for leaks at least once every 30 days. Any leaking
PCB Items and their contents shall be transferred immediately to properly marked non-leaking
containers. Any spilled or leaked materials shall be immediately cleaned up and the materials
and residues containing PCBs shall be disposed of in accordance with § 761.61. Records of
inspections, maintenance, cleanup and disposal are maintained in accordance with § 761.180(a)
and (b).
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Final CWMNW PCB Ops Plan, Appendix A to application; received by EPA 05/12/2023
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6 Groundwater Management
The environmental monitoring program at the Arlington Facility is designed to detect a potential
release from the PCB land disposal units to the groundwater in the uppermost aquifer underlying
the facility.
The monitoring system consists of groundwater monitoring wells and leachate monitoring. The
groundwater monitoring program is conducted in accordance with the procedures detailed in the
facility's RCRA Part B Permit Attachment #7 - Groundwater Monitoring Plan.
In accordance with 40 CFR 761.75(b)(7), if there is sufficient liquid to perform the analysis, a
representative sample of the liquid removed from at least one of the primary standpipes in the
PCB portion of closed landfills L-5, L-7, L-9, L-12, L-13, and active landfills L-14 and L-15 will
be analyzed monthly for the following parameters: PCBs, pH, specific conductance, chlorinated
organics (TOX), and total chlorides in addition to the volume recorded. The sample of the liquid
from L-12, L-13, L-14, and L-15 may be taken after the liquid is transferred to an on-site storage
tank. Leachate from the primary and secondary collection sumps of closed landfills L-12, L-13,
and active landfills L-14 and L-15 (including the tertiary monitoring sump) will be analyzed for
PCBs before it is discharged to any on-site impoundments. Leachate discharged to the active on-
site evaporation ponds must meet LDR standards prior to discharge to the ponds. Prior to
treatment or disposal, leachate and run-off from the active PCB areas (L-12, L-13, L-14, and L-
15) may be accumulated in on-site storage tanks prior to testing, pursuant to CWMNWs RCRA
Part B Permit Attachment #23 - Bulk Liquids Storage Plan
7 Preventive Contingency and Security Measures
7.1 Contingency Plan
Spills, leaks, and other uncontrolled discharges of PCBs are managed are reported in accordance
with OAR Chapter 340 Division 108. The facility's Attachment #4 - Contingency Plan provides
an explicit description of response procedures to be used to protect the public, facility personnel,
and the environment in the event of an emergency. Such emergencies may include fires,
explosions, or unplanned sudden or non-sudden release of PCBs to air, soil, or surface water.
If an emergency occurs, an Emergency Coordinator immediately assesses the situation and
directs appropriate response activities including implementing procedures contained in
Attachment #4 - Contingency Plan, if necessary
7.2 Security Measures
Security of the site shall be maintained in accordance with Attachment #2 - Security, Hazard
Prevention and Training Plan
8 Roadway Use and Vehicle Movement
The CWMNW site is located off Cedar Springs Road. Cedar Springs Road is constructed of
bituminous concrete pavement (blacktop). Roads on the site are constructed of compacted
gravel-bearing soil, flexible pavement, or asphalt. The compacted soil roads are graded as
necessary and maintained throughout the year in a condition to allow transport vehicles and
disposal machinery to operate safely and efficiently.
8.1 Contamination Control
Wastes are handled and emplaced with front-end loaders, dump trucks and small and medium
duty forklifts (fitted with drum-grabbers when necessary). This equipment has been found to be
1
Final CWMNW PCB Ops Plan, Appendix A to application; received by EPA 05/12/2023
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most effective since it minimizes physical contact of operations personnel with the waste
containers.
Several steps are taken to assure that PCB-contaminated material is not carried from the active
disposal area. First, only designated equipment is used in handling PCB wastes.
Second, whenever equipment surfaces have contacted PCBs or whenever PCB contamination is
suspected to be present, such surfaces are swabbed with a solvent and then dried with suitable
absorbent material. The solubility of PCBs in the solvent is 5 percent or more by weight. The
solvent may be reused for decontamination until it contains 50 ppm PCBs. It is then disposed of
as a PCB liquid in accordance with 40 CFR 761.60(a). Non-liquid PCBs resulting from the
decontamination are disposed of in the PCB landfill.
Third, the exposure of the vehicles which haul wastes and machinery which places wastes into
the disposal cell is minimized by proper operating practice. In so doing, contaminants are not
carried out of the landfill on the tires or treads of the vehicles and machinery which operate in
the PCB cell. As an added precaution, any heavy equipment which places waste into the
disposal cell that requires maintenance will be inspected and have a standard wipe test for PCBs
performed prior to going to the shop for maintenance. As an alternative, maintenance of
equipment may be performed in the active area at a safe location. CWMNW implements written
procedures which specify decontamination procedures be conducted on clean fill adjacent to a
haul road.
Finally, a statistical sampling program is used to ensure that PCB contamination is not carried
from the PCB landfills by the disposal machinery. This program consists of two regimes. The
first outlines procedures for the sampling equipment surfaces which have contacted PCBs. The
second outlines procedures for the sampling of soil from the landfill access ramp.
Equipment sampling is designed to identify PCB contaminants on equipment surfaces that have
come into contact with PCB wastes. Before the machinery leaves the PCB disposal cell, the
PCB storage areas or buildings, the equipment is sampled and analyzed to show the equipment is
decontaminated. Three random samples are taken from tires and the appropriate equipment
surface(s), e.g., forklifts and/or tracks of the machinery. These samples are segregated and
labeled by location. Samples may be composited by vehicle location to form a 3 to 1 composite.
All composite samples are analyzed for PCB contamination. Should contamination be identified,
individual samples can be tested to identify the specific source of contamination. Any PCB
contaminants are then removed, and the surface resampled until PCB contamination is below 10
micrograms (|LXg)/100 square centimeters. As a general rule, equipment that has come into direct
contact with PCBs does not leave the PCB disposal cell, the PCB storage areas or buildings.
The system for sampling the landfill access ramp is based upon a clustered transect approach
suitable for linear surfaces. These transects are plotted across the ramp surface perpendicular to
the direction of traffic. The access ramps are divided into approximately 100-foot equal sections.
A cluster of three transects placed 3 feet apart is then randomly located in each of these sections.
Three samples taken at randomly selected locations across each transect are segregated and
labeled individually. For testing, all samples from a transect cluster will be composited to form a
9 to 1 composite sample. Portions of the segregated samples are archived until certification
analyses are complete. In the unlikely event that PCB contamination is detected, the applicable
section of the access road or ramp will be scraped until repeat sampling and analysis shows PCB
contamination is below 25 ppm. Routine sampling of the access ramps will be repeated every
quarter. TSCA PCB Storage
2
Final CWMNW PCB Ops Plan, Appendix A to application; received by EPA 05/12/2023
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APPENDIX A - EPA Approval Letters
3
Final CWMNW PCB Ops Plan, Appendix A to application; received by EPA 05/12/2023
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 10
1200 Sixth Avenue
Seattle, WA98101
3 1 JAN 2D06
Reply to
Attn Of: OCE-084
Mr. Samir M. Jiries
Senior Environmental Manager
Chemical Waste Management of the Northwest
17639 Cedar Springs Lane
Arlington, OR 97812
Re: Request for Amendment of PCB Disposal Approval to Include Landfill Unit L-14
EPA I.D. Number ORD089452353
tag!
P ROl^
Dear Mr. Jiries:
This is in response to Chemical Waste Management of the Northwest's (CWMNW)
April 14, 2004, letter requesting an amendment to its U.S. Environmental Protection Agency,
Region 10 (EPA) issued PCB Disposal Approval to include landfill unit L-14.
In conjunction with this request CWMNW has provided EPA an update to the language in
the PCB Disposal Approval, the PCB Operation Plan, and the Closure/Post Closure Plan to include
cells 1 through 4 of landfill unit L-14.
EPA has completed its review of the information in CWMNW's submittals of
April 14, 2004, and June 30, 2004, in support of this request and the Oregon Department of
Environmental Quality's (ODEQ) September 23, 2005, approval of a permit modification to
incoiporate a groundwater detection monitoring program for landfill L-14 into CWMNW's RCRA
Permit No. ORD089452353. Based on this review EPA has decided to modify CWMNW's PCB
Disposal Approval to include landfill unit L-14, effective immediately, with the additional clarifying
revisions specified in Enclosure A to this letter.
The PCB Disposal Approval and the PCB Operating Plan, as updated by CWMNW are
enclosed with this letter as Enclosures B and C (dated December 2005). This updated PCB Disposal
Approval does not constitute a reissuance of the PCB Disposal Approval which was originally issued
on March 25, 1982, nor does it serve as a final action on the draft PCB Disposal Approval issued on
September 18, 1987.
If you have any questions, please feel free to contact Linda Meyer at (206) 553-6636, oi
Daniel Duncan at (206) 553-6693.
Sincei
Michael A. Bussell, Director
Office of Compliance and Enforcement
Enclosures
Brett McKnight, ODEQ
Fredrick Moore, ODEQ
f punted on flesyeta* Paper
1
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CWMNW PCB Ops Plan, Appendix A to application; received by EPA 05/12/2023
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2
Final CWMNW PCB Ops Plan, Appendix A to application; received by EPA 05/12/2023
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Agancy i>oanie v\Aya
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2
Appendixes A and E, respectively. This revised PCB Disposal
Approval does not constitute a reissuance of the PCB Disposal
Approval, which was originally issued on March 25, 1982, nor does
it serve as final action on the draft PCB Disposal Approval issued
on September 18, 1987:
1. Revision of the PCB Landfills' groundwater monitoring program
fox- consistency with CWMNW* S RCRA Part B, No. ORD089452353,
including using the same monitoring well network specified for
landfills L-5, L-7 and L-9.
2 Other miscellaneous updates, including correcting 40 CFR Part
265 citations to Part 264 citations and corrections of
typographical errors„
All correspondence or inquiries on this matter should be
directed to Catherine Massimino of my staff, at (206) 553-4153..
Sincerel vf/ a
Michael A, Bussell, Director
Office of Waste and
Chemicals Management
Enclosures ...— ...
4
Final CWMNW PCB Ops Plan, Appendix A to application; received by EPA 05/12/2023
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Approval Attachment 3
Contingency Plan
(Application Appendix G, Received by U.S EPA December 1, 2022)
Approval for Commercial Disposal of Poly chlorinated Biphenyls
Chemical Waste Management of the Northwest, Inc.
Arlington, Oregon
U.S. EPA ID: ORD089452353
U.S. Environmental Protection Agency, Region 10
Seattle, Washington
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APPENDIX G
Contingency Plan
For
Chemical Waste Management of the Northwest, Inc.
Received by EPA Region 10 on December 1, 2022
Appendix to CWMNW's final TSCA PCB application
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Contingency Plan
For
Chemical Waste Management of the Northwest, Inc.
Arlington Facility- ORD 089 452 353
17629 Cedar Springs Lane
Arlington, Oregon
Attachment #4
This Document is issued by the
Oregon Department of Environmental Quality
Arlington Facility • ORD 089 452 353
DEQ Issue TBD- Rev: 0
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17629 Cedar Springs Lane
Arlington, Oregon
DEQ Issue TBD- Rev: 0
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Table of Contents
RCRA Requirements Table Error! Bookmark not defined.
Preface Contingency Plan 3
1 General Information 3
Table 4-1 Waste Contained in Active Areas 4
Figure 4-1 Delegated Authority 5
2 Emergency Coordinators 5
Table 4-2 Emergency Coordinators and Warning System 6
Table 4-3 Agency Emergency Contacts 7
3 Initiation of the Contingency Plan 8
Figure 4-2 Initial Response Activities 8
4 Emergency Response Procedures 10
4.1 Notification 10
4.2 Identification of Hazardous Materials 11
4.3 Assessment 12
4.4 Control Procedures 13
4.4.1 Fire and/or Explosion 13
2.2.1 4.4.2 Spill or Material Release 14
4.4.3 Power Outages/Equipment Failures 16
2.2.2 4.4.4 Prevention of Recurrence or Spread of Fires, Explosions, or Releases 17
4.5 Storage and Treatment of Released Material 17
4.6 Incompatible Waste 17
4.7 Post-Emergency Equipment Maintenance 17
5 Emergency Equipment 17
Table 4-4 Emergency Equipment 18
6 Coordination Agreements 21
Table 4-6 Response and Coordination Agreements 21
7 Evacuation Plan 23
Figure 4-3 Evacuation Plan 21
8 Required Reports 11
Table 4-7 Emergency Event Reporting Form 11
9 Amendments to the Contingency Plan 12
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Preface Contingency Plan
The information contained herein is submitted in accordance with the requirements of [40
CFR 264.50 through 264.56 and 270.14(b)(7)], These regulations require facilities that treat,
store, or dispose of hazardous wastes to have contingency procedures to minimize hazards to
human health or the environment from fires, explosions, or any unplanned sudden or non-
sudden release of hazardous waste or hazardous waste constituents to air, soil, groundwater,
or surface water at the facility. The provisions of this Contingency Plan are implemented
when it is determined that an event could threaten human health or the environment. A copy
of the Contingency Plan is maintained at the facility and has been submitted to all agencies
which may be called upon to provide emergency services.
During the period of the permit, changes may be made to the facility that necessitates changes
in drawings of physical layouts/plans in the Contingency Plan. These changes in drawings of
physical layouts/plans will be submitted to ODEQ and all Contingency Plan holders.
1 General Information
This Contingency Plan is for Chemical Waste management of the Northwest Inc. (CWMNW)
treatment, storage, and disposal facility located at 17629 Cedar Springs Lane, Arlington,
Oregon. Access to this facility is by way of Interstate I 84 to Arlington: south on Highway
19: west on Cedar Springs Lane approximately 5 miles. The site entrance is clearly marked
on the right-hand side of Cedar Springs Lane. The facility primarily treats, stores and
disposes of RCRA Hazardous waste as defined in [40 CFR Part 261], TSCA wastes as
defined in 40 CFR 761 and other types of solid, non-hazardous and non-regulated wastes. The
facility location is shown on Figure 4-3 (at the end of the document). The Arlington Facility
is located in a remote upland area of northeastern Oregon. Approximately 7.5 miles by air
from the Columbia River.
The facility manages hazardous wastes in a variety of ways:
• Hazardous wastes, including debris, are treated in a variety of units.
• Hazardous wastes are stored in a variety of units.
• Hazardous wastes are disposed of in landfill cells and surface impoundments.
• Storm water run-off is collected in surface impoundments.
• Hazardous wastes are transferred off-site to other treatment, storage, and disposal
facilities.
The active waste handling operations at the facility are described in detail in Table 4-1 below
DEQ Issue TBD- Rev: 0
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Table 4-1 Waste Contained in Active Areas
Waste Present Surface Impoundments
The waste impoundments receive pumpable wastes and
sludges.
Aqueous waste with pH greater than two, TCLP wastes and
metals less than 268.40 LDR limits
Aqueous waste with pH less than 12.5, TCLP wastes and
metals less than 268.40 LDR Limits
Waste Present Container Storage Areas
Various containerized liquids and solids are stored in segregated sections of this area. Site records must be consulted for
specifics as inventory turnover is high. Waste profile, analytical and SDS information are contained in site records that are
readily available
Waste Present Landfills
Stabilized pond residues, contaminated soil, stabilized liquids and sludges, bulk solids, and containerized solids are disposed
of in the landfills. The following is a list of waste types deposited in active landfill cells.
Solid waste that mav be anv of the following:
Corrosive
Primary and secondary metals waste
Spent halogenated solvents
Pesticide wastes
Spent non-halogenated solvents
commercial chemical products
Electroplating wastes
Off-specification species
Wood products wastes
Spill residues
Petroleum refining wastes
Liquids present in "lab packs."
Waste Present Stabilization Units
Electroplating sludges
Liquids with pH greater than 2 with characteristic regulated
constituents
Liquids with pH greater than 2 and metals greater than
the 268.40 LDR limits
Liquids with pH 12.5 or greater
Electric arc furnace dust
Soils and solids with characteristic regulated constituents
Inorganic liquids or solids
Potliner (K088) and various reagents
Off-spec materials requiring stabilization
Non-regulated liquids
Waste Present Waste Water Treatment Units
Landfill Leachate - F039
Various Reaaents
Acid and Alkaline wastewaters
Sodium Hydroxide
Wastewaters contaminated with heavy, medium, and/or
light petroleum distillate
Acids (HCL, H2S04)
Heavy metal contaminated wastewater
Ferric Sulfate
Cyanide contaminated wastewater
Ferric Chloride
Organic solvent contaminated wastewater
Sodium Hypochlorite/Calcium Hyperchlorite
ORU wastewaters and process waters
Calcium Carbonate
Hydrogen Peroxide
Waste Present 90 Day/Sattellite Acumulation Areas
Flammable Liquids
Corrosive Liquids
Various containerized liquids and solids from well
drilling operations
Various containerized liquids and solids from lab analysis
Various containerized liquids and solids from
maintenance buildings
Waste Present Containment Buildings
IPotliner Soils or other waste materials contaminated with: 1
Petroleum hydrocarbons
Chlorinated pesticides
Residuals from explosives
Organic compounds
Waste Present Crushing Facility
| K088 Aluminum Potliner | All Debris types
Waste Present Organic Recovery Units
Organic Contaminated Wastes
Petroleum refinery waste
Other organic wastes
Pesticide contaminated waste
DEQ Issue TBD- Rev: 0
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This Contingency Plan is implemented if there is a fire, explosion, or any unplanned release
of hazardous waste or hazardous waste constituents which could threaten human health or the
environment.
Delegated Corporate authority for emergency coordinators is included as Figure 4-1 below;
Figure 4-1
CORPORATE AUTHORITY
FOR EMERGENCY COORDINATOR
CHEMICAL WASTE MANAGEMENT OF THE NORTHWEST, INC.
CERTIFICATE
I, Jason Rose, the duly qualified and Area Vice President of the Pacific .Northwest Market
Area of Waste Management, Inc., a Delaware Corporation, hereby certify thai I am
authorized by the corporation to grant the authorization below,
RF.SOI VKD: That the Corporation hereby grants to the individual(s) designated as
"Lmergeney Coordinator' in the approved Contingency Plan for Chemical Waste
Management of the Northwest, Inc. - Arlington to commit such of the Corporation's
resources as are needed to carry out such Contingency Plan; and
BE IT FURTHER RESOLVED: That such individual(s) designated as "Emergency
Coordinator" in such approv ed Contingency Plan be and hereby are authorized, directed,
and empowered to execute and deliver for and on behalf of the Corporation any and all
such contracts, agreements, documents and memoranda to be necessary and appropriate
to execute the herein authorized resolution.
Dated: _ \\ j L%( X - -/l
Figure 4-1 Delegated Authority
2 Emergency Coordinators
In accordance with [40 CFR 264.52(d) and 264.55], the facility maintains a list of Emergency
Coordinators (ECs). The list of ECs designates a primary contact as well as alternates in the
order in which they assume responsibility in the absence of the primary contact. This list of
ECs is provided as Table 4-2 below.
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Table 4-2 Emergency Coordinators and Warning System
Table 4 2 (40 CFR 264.52(a);264.56) Report all emergencies to the Emergency Coordinator or
Alternate.
Emergency Coordinators
Emergency Coordinator
Phone #
Address
Robert Mulholland
Cell (541)-371-0646
1310 Childers Road Arlington, OR
(Primary)
Office 541-454-3265
97812
Jeff Bufton (Alternate 1)
Cell (541)980-1716
Office 541-454-3251
1225 W. 2nd ST. Arlington, OR 97812
Jerry Gabbey (Alternate 2)
Cell (541)-965-3038
Office 541-454-3228
901 Airport Way Arlington, OR 97812
Russ Hayter (Alternate 3)
Cell (541)-656-9084
850 Main, Arlington, OR
On Site Warning System
Phone #/Channel #
Alt Phone #
Site Paging System
HF Radio Emergency
Channel 10
HF Radio Operations
Channel 5
Base Station; Base 1
541-454-3227
541-454-3215
Alt Base Station; Base 1
541-454-3313
At all times there is an EC on the facility premises or on call (i.e. available to respond to an
emergency by reaching the facility within a short period of time) who has the responsibility
for coordinating all emergency response measures. The EC is thoroughly familiar with all
aspects of the facility's contingency plan, all operations and activities at the facility, the
location and characteristics of wastes handled, the location of all records within the facility,
and the facility layout. In addition, the EC has the authority to commit any resources needed
to carry out the contingency plan. Each EC is provided a copy of the Contingency Plan that
may be kept at their residence. The EC has complete authority to commit all the resources of
CWMNW to implement the Contingency Plan in the event of an emergency. Table 4-3 lists
Agency emergency contacts, that may be contacted by the EC in the event of an emergency.
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Table 4-3 Agency Emergency Contacts
Table 4 3 Agency Emergency Contacts
Emergency Organization/Agency2
Phone Number
Good Shepherd Medical Center
541-567-6483
Mid Columbia Medical Center
541-296-1111
Any Emergency
Gilliam County Sheriff Non-emergency
541-351-9530
Oregon State Police
866-442-0776
North Gilliam Ambulance Service
911
Fire/Explosion
Oregon Emergency Management Division
800-452-0311
North Gilliam Fire Department
911
Poison Information,
National Poison Control Center
800-222-1222
Hazardous Material Spill
Chemtrec
800-424-9300
or Release
National Response Center
800-424-8802
National Disaster
Oregon Emergency Communication Center
800-452-0311
American Red Cross
541-296-3210
This table, as well as any other emergency contacts and telephone numbers in the
Contingency Plan, is reviewed annually and revised as necessary.
In accordance with 40 CFR 264.55, ECs are selected based on their familiarity with:
The Facility Layout
The Contingency Plan
Operations and activities at the facility
Location and characteristics of the wastes handled
Location of records within the facility
ECs have completed site training requirements, exhibit leadership qualities, and have
completedCWMNW probationary employment period. Training records and job descriptions
of the EC and Alternate ECs are maintained at the facility for review.
This plan describes the actions ECs must or may carry out during any particular incident. The
EC may delegate certain activities to other qualified facility personnel (e.g.; outside
notifications may be delegated to the Environmental Manager or other qualified facility
personnel). The Emergency Coordinator (or Alternate) will be on call 24 hours a day, 365
days per year. A "On-Call" duty roster will be maintained in all offices and lunchrooms.
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3 Initiation of the Contingency Plan
In accordance with 40 CFR §§264.52(a) and 264.56(d), the decision to implement the
Contingency Plan depends on whether or not an imminent or actual incident could threaten
human health or the environment (e.g., release, fire or explosion). This paragraph provides
guidance for making these determinations by specifying decision-making criteria to be used
during the implementation of the Contingency Plan. The general response and
implementation procedures to be used when an incident occurs and the potential notification
requirements are outlined in Figure 4-2 below.
Figure 4-2 Initial Response Activities
1 \lTIA1. RESPONSE ACTIVITIES
Figure No.
4-2
Chemical Waste Management
MMLAJU. aft he Northwest, Inc.
"~M *** Arlington Facility
Date
Rev. 0: Feb. 2022
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The EC can implement the Contingency Plan in full or in part to meet the needs of the
particular incident. A full implementation is appropriate if outside assistance is needed from
any emergency agency or if complete facility evacuation is warranted. The following
situations require either partial or full implementation of the Contingency Plan:
Fire and/or explosion:
• A fire involving hazardous waste or hazardous materials that could threaten human
health or the environment (does not include small fires incidental to hot work permits
or oxidation of gasses from hydrolysis during treatment).
• The fire spreads and could possibly ignite materials at other locations on-site or could
cause heat-induced explosions.
• The fire could spread to areas outside the facility.
• A danger exists that an explosion could occur.
• A danger exists that an explosion could ignite other hazardous wastes at the facility.
• A danger exists that an explosion could result in the release of toxic material.
• An explosion has occurred.
• Any fire or explosion requiring an off-site agency for emergency response.
Spills or Material Release:
• A spill that results in release of flammable liquids or vapors that could cause a fire or
gas explosion hazard.
• The spill causes the release of toxic liquids or fumes that could threaten human health
or the environment.
• The spill cannot be contained inside the facility.
• Any spill or material release that requires an off-site agency for emergency response.
A partial implementation is appropriate when the facility has the resources to address the
situation without outside emergency resources in a timely fashion.
The EC implements the Contingency Plan and coordinates the activities of available
personnel. All facility employees have received training in implementing the Contingency
Plan. It is the responsibility of the individual who detects an incident at the facility to
promptly contact a supervisor, the EC, or their designee. When contacted, the supervisor will
make a preliminary assessment of the situation and, if warranted, will promptly contact the
EC. If the primary EC is unavailable, an alternate EC will be contacted (See Table 4-2).
When work is being conducted without an EC present at the site, the Primary EC will appoint
a trained designee to carry out EC duties, including notifications, in case of an emergency. In
the event an emergency situation should arise, the EC is responsible for assessing the severity
of the incident and implementing the Contingency Plan as required.
Should an incident occur after the normal working hours, the designated EC can implement
the Contingency Plan, as appropriate, without being at the facility. To do this, the designated
EC uses the observations of personnel and security officers who are at the facility to make
preliminary determinations of the appropriate course of action.
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4 Emergency Response Procedures
4.1 Notification
In accordance with 40 CFR 264.56(a), upon the discovery of any imminent or actual
emergency, the discoverer will promptly notify their supervisor. All employees actively
mixing or managing hazardous waste will either have handheld radios, vehicle radios or
landline telephones (scale house, lab, shop and transportation) available. The Supervisor
will, as necessary, notify the primary EC (or his alternate when the primary EC is unavailable
and/or the alternate is a more appropriate contact for the particular situation) of the situation.
For after hours incidents, the primary EC or his alternate is generally contacted by phone.
Specific notification procedures and requirements for the various types of incidents that
would require implementation of this Contingency Plan are provided in the other portions of
this plan. A facility map is available to assist personnel in providing necessary details to the
EC available. If not immediately available at the facility, the ECs have the authority to issue
preliminary decisions prior to arriving at the facility. The EC is responsible for contacting the
necessary personnel (response team, cleanup crew, etc.) and instructing them how to proceed.
Supervisors of unaffected areas will generally stay with their personnel and be ready to
evacuate and account for the personnel under their supervision.
The siren or other communication systems may be activated to notify facility personnel at the
ECs discretion. In the event of a power outage, the radio transponder/repeater is equipped
with a battery backup that can last up to 48 hours, depending on usage, so that radios may still
be used for communication. Evacuation may be initiated using radios and/or the siren. All
employees working in the active treatment area will be equipped with handheld radios, and
all site vehicles are equipped with Motorola radios, so that the siren can be activated if
needed. Radios are issued in sufficient numbers so that each employee either has a radio or is
with an employee who has a radio, including heavy equipment operators. The sites paging
system activated thru the phone system is used to notify office personnel at CWM and
CRLRC of the contingency. The radios are battery operated and not dependent on electrical
power. The sirens are located on top of the water tank at Well 5 near the Lab and the top of
the S-2 building in the active area.
The EC will contact available supervisors to inform them of the incident. Site radio channel
10, emergency channel will be used for initial announcement of the emergency, this also
alerts neighboring Columbia Ridge Landfill of the incident. During active emergencies,
administrative personnel are instructed to curtail routine business calls so the phone lines will
remain open to handle emergency calls. Personnel are assigned to the access gates by the EC
to control the access of persons during emergencies. The EC is responsible for contacting the
appropriate federal, state, or local authorities if their assistance is required. The EC is also
responsible for recording those incidents requiring activation of the Contingency Plan in the
operating record (recording incidents in the operating record may be delegated to the
Environmental Manager or other qualified facility personnel).
Notification of the appropriate agencies is the responsibility of the EC. Pertinent phone
numbers are listed in Table 4-2 and Table 4-3.
If a release, fire, or explosion that could threaten human health or the environment outside the
facility or that is beyond the facility's emergency response capabilities to control occurs, the
EC is responsible for ensuring the appropriate persons/agencies are notified. The following
information is typically given to the appropriate persons/agencies:
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• Name and telephone number of the reporting individual
• Name and address of facility
• Time and type of incident (e.g., release, fire)
• Name and quantity of material(s) involved, to the extent known
• Extent of injuries, if any
• Possible hazards to human health or the environment outside the facility
Based on the type and severity of the reported injury, the EC will contact the appropriate
emergency service and medical facilities. The responding medical unit will direct medical
emergency responses once they arrive at the scene. These responsibilities include assessment
of the emergency and communication with medical facilities to ascertain which facility the
injured person(s) will be sent to for treatment. The EC and medical personnel will evaluate
chemical exposures and the need for personnel decontamination prior to leaving the facility.
Place the injured person in the care of qualified medical personnel. The facility will notify
the appropriate hospital of any information on toxicity and decontamination and any other
pertinent information. North Gilliam County Fire Department will be notified in the event of
a fire if their participation is needed to contain the fire to the facility. They will protect areas
outside the facility and outside the active areas.
4.2 Identification of Hazardous Materials
In accordance with 40 CFR 264.56(b) and in the event of a release, the EC will attempt to
identify the character, exact source, amount, and areal extent of any release. The initial
identification method will include visual inspection, if possible. Paperwork documentation,
such as shipping Manifests, Internal Load Inspection Sheets (LIS), Waste Profile Forms
(WPF) and other available sources of information will also be reviewed.
Certain wastes that come into the facility are bulk liquids or solids. Should a problem occur
during the unloading, storage, treatment, stabilization, or disposal of these wastes, the
material can be identified by the WPF numbers and LISs associated with these wastes. Bulk
wastes unloaded and disposed of within a landfill can be identified using waste disposal
records.
Wastes in containers can be identified at the time of their unloading by WPF numbers, during
storage by the LISs and, finally, by their position in the landfill area as indicated in the waste
location records.
Wastes being treated in surface impoundments can be identified by manifests and WPF
numbers at the time of their deposition and, subsequently, by LISs.
Wastes being treated or stabilized can be identified by WPF numbers, waste characterization
review information, and manifests. Inventory records are maintained for all wastes stored at
the facility.
Samples will be taken in accordance with the Attachment #1 - Waste Analysis Plan (WAP),
for chemical analysis if there is a release of materials from containers, tanks, stabilization
areas, disposal areas, or surface impoundments that cannot be identified from existing
records. Personnel who may have knowledge of the materials involved will be interviewed as
necessary.
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4.3 Assessment
In accordance with CFR 264.56(c) and 264.56(d), the EC will assess possible hazards, both
direct and indirect, to human health or the environment. This assessment will be based on:
• The character of the released material(s)
• The exact source of the released material(s)
• The amount of the released material(s)
• A determination of the areal extent of the released material(s)
• An assessment of the possible hazards to human health and the environment
The information used in making assessments may include:
• EC observations
• Reports from facility personnel
• Manifests
• Operating logs
• Operation records
• Waste characterization data
• Miscellaneous sources of information and response assistance maintained at the
facility
Once the area of involvement is identified, the EC will acquire and review the appropriate
facility records of the wastes stored, treated, or disposed at the site location, including waste
analyses, manifests, and other pertinent data, as needed.
Based on this information, the EC will assess possible hazards to human health or the
environment that may result from the release, fire, or explosion. This assessment will
consider both direct and indirect effects of the release, fire, or explosion (including the effects
of any toxic, irritating, or asphyxiating gases that are generated), of any hazardous surface
water run-off from water or chemical agents used to control fire and heat-induced explosions,
of the possibility of heat-induced explosions and spreading fire, and of the potential
exposures of personnel to hazardous materials while attempting to control a fire.
If the EC determines that the facility has had a release, fire, or explosion which could threaten
human health, or the environment, outside the facility, the EC must report their findings
where applicable as follows:
• If the ECs assessment indicates that evacuation of local areas may be advisable, he must
immediately notify appropriate local authorities. The EC must be available to help
appropriate officials decide whether local areas should be evacuated; and
• The EC must immediately notify Oregon State Police, North Gilliam Fire Department,
Gilliam County Sheriffs Department and the National Response Center (using their 24-
hour toll free number 800-424-8802). The report must include:
o Name and telephone number of the reporter;
o Name and address of the facility;
o Time and type of incident (e.g. release, fire);
o Name and quantity of material(s) involved, to the extent known;
o The extent of injuries, if any; and
o The possible hazards to human health, or the environment, outside the facility.
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All spills and leaks of hazardous waste greater than the minimum reportable quantity of
releases (as defined in 40 CFR 302.4), which do not threaten human health or the
environment outside the facility will be reported to the Oregon Emergency management
Division (800/452-0311) (ODEQ) and NRC within 24 hours.
If the EC determines the facility has had a release or explosion which could threaten human
health or the environment and deems that an evacuation is necessary, the EC will contact the
appropriate local authorities (see Table 4-3) and proceed with evacuation procedures as
further addressed in the Evacuation Plan section of this document
4.4 Control Procedures
In accordance with [40 CFR 264.52(a)], potential releases fall under two general
classifications: fire/explosions and spills/releases of materials. Natural disasters such as
earthquakes or tornadoes could also result in implementation of the Contingency Plan by
causing an event that would fall into one of these two classifications. Because of the facility's
location and elevation, inundation by flood is not a probable threat. Run-on and run-off from
precipitation events are controlled by a system of dikes, ditches, swales, and collection ponds.
The subsections that follow discuss specific control procedures utilized in the event of a fire,
explosion, or material spill/release. In all emergency procedures, the initial response is to first
protect human health and safety, then protect the environment. Identification, containment,
treatment, and disposal assessment are subsequent phases to the contingency implementation
process.
4.4.1 Fire and/or Explosion
Response personnel will be on standby during all facility emergencies. If a response to a fire
has occurred, remote firefighting efforts will concentrate on preventing the fire from
spreading to nearby areas. During nonworking hours (evenings, holidays, weekends), the
Response Team will be contacted at home. The Organic Recovery Units (ORU) at the facility
operate 24/7, these are 3-4 man crews, contact can be made to the ORU crew in the event of
an emergency, the ORU crew will then contact the on call EC in the event of a fire,
CWMNW will only utilize minimal remote fire suppression techniques as appropriate in
order to protect the health and safety of the response crew.
All areas for loading, off-loading, treatment, storage, and disposal are readily accessible by
fire-fighting and other emergency vehicles and equipment. The roads leading to the storage,
treatment and landfill areas are kept clear of obstructions.
The following general procedures are used for rapid and safe response and control of
fire/explosion situations. When an employee discovers a fire or explosion or a situation that
could lead to either of these events (spill of flammable material, etc.), they will report it to
their supervisor or the EC via the Motorola radio on the Emergency Channel. When
contacted, the EC is responsible for obtaining the following information where appropriate:
• The area of the fire and/or explosion or the unsafe condition
• The materials involved and the intensity of the fire or explosion if they have occurred
• Any personnel injuries
The following actions will be taken where applicable in the areas affected by the fire or
explosion:
• Work in all potentially impacted areas will be immediately terminated.
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• Complete evacuation of the affected area will be initiated if a threat to human health is
possible.
• Medical attention will be obtained for any injured person(s) through notification of
911.
• The emergency alarm warning system as necessary, will be used to notify site
personnel of an emergency condition if it requires site evacuation. This signal also
indicates to employees that 2-way radios will be used only for emergency
communication and that all facility personnel who are involved with emergency
response should turn on their radios at this time. Also, "EMERGENCY" will be called
three (3) times over the 2-way radios to provide an open communication line for
emergency use.
• If safe to do so, operating equipment will be shut down, feed lines and additional
equipment will be shut down, and nearby containers will be removed or isolated.
• If necessary, the area will be cleared of personnel not actively involved in fire
suppression. For site evacuation, these persons will report to the designated rally
points for accountability. Rally points are designated in Figure 4-3. The figure shows
that several rally points are established around the site so an area upwind of the fire is
available. Additional personnel safety equipment will be distributed if needed.
• If safe to do so, injured persons will be removed from the area and medical treatment
will be administered by qualified personnel.
• As appropriate, facilities will be inspected for leaks, pressure buildup, gas generation,
or ruptures in valves, pipes, or other equipment where appropriate and safe to do so.
• Fires may be suppressed with water, soil, or dry chemicals. Heat-exposed containers
will be cooled with water spray and removed from the fire, if appropriate and
possible. Warning/Caution: If a rising sound comes from a venting device or a tank
begins to discolor, withdraw from the area immediately. (Possible Boiling
Liquid/Expanding Vapor Explosion).
• North Gilliam Fire Services will be called if a fire cannot be controlled or is too
dangerous for facility personnel (as determined by EC). North Gilliam Fire Services
will assist in perimeter control of the fire
Based on the severity of the fire/explosion, the potential for injury to personnel, and the
materials involved, the EC will determine if fire suppression activities/explosion response
activities can be safely accomplished by CWMNWpersonnel. The EC is responsible for
assessing all fire-fighting/explosion response efforts.
The EC will determine when the fire emergency has passed and will consult with other
facility personnel, as appropriate, before the "all clear" message is sent. The "all clear"
message will be communicated to facility personnel via two-way radios phones or verbally
when the fire has been extinguished and the personnel are no longer endangered. All required
dedicated equipment used in the emergency will be cleaned and prepared for use prior to
being placed back in service as required by [40 CFR 264.56(h)(2)],
2.2.1 4.4.2 Spill or Material Release
CWM is responsible for all spill and material releases in the active areas, the following
general procedures outline rapid and safe response for the control of spills or material release
situations. Figure 4-2 outlines the determination process. When an employee discovers a
hazardous chemical spill or process upset resulting in a release, he will immediately report it
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to his supervisor or the EC. When contacted, the designated EC will attempt to obtain the
following information where applicable:
• Location of the release or spill of hazardous material
• The identity, properties, and characteristics of the material spilled or released
• The direction in which the spill, vapor, or smoke release is heading
• An estimate of the quantity released and/or the rate at which it is being released.
• Any injuries involved
This information is used to assess the magnitude and potential seriousness of the spill or
release. If the spill or release is within the facility's emergency response capabilities, the EC
will contact and deploy the necessary facility personnel. The EC will contact the appropriate
agencies for assistance and reporting.
Because fire is always a potential hazard in spills of flammable materials, possible sources of
ignition near the fire will be eliminated, whenever possible. Vehicular traffic will be directed
away from the area to avoid ignition of the vapor. Routine work in the area will cease until
the spill is contained and safety is restored. If spilled materials are flammable and pose a
threat of fire, response personnel may respond with water and hoses for vapor suppression. If
advised by the EC, the spill may be flushed with large quantities of water. Materials will be
contained and collected for proper treatment and disposal.
If the chances of an impending explosion are high, an appropriate area will be evacuated as
determined by the EC. The closest local residence is approximately 1.6 miles from the site.
Therefore, a release of even highly flammable material should not threaten local residences
with any danger of fire.
Isolation distances and evacuation requirements are dependent on the nature and magnitude
of the spill. Small and large spills are defined using the 2016 edition of the North American
Emergency Response Guidebook. A small spill is one which involves quantities less than 55
gallons for liquids and less than 660 pounds for solids. A large spill is one which involves
quantities that are greater than 55 gallons for liquids or greater than 660 pounds for solids.
The Contingency Plan will be activated for all spills that could directly threaten human health
or the environment. The Contingency Plan may not be activated for small spills that do not
exceed reportable quantities (as defined in 40 CFR 302.4) and do not pose a threat to human
health or the environment. De minimis losses include those from normal material
handling/processing operations (e.g., loading and unloading, or leaks from pipes) or other
facility operations; these small losses are handled as part of the normal site operations and do
not require implementation of the Contingency Plan. Spills and releases into secondary
containment are generally not considered to pose a threat to human health and the
environment and do not generally require implementation of the Contingency Plan.
The following actions will be immediately taken where applicable in the areas affected by a
spill or release:
• Initiate complete evacuation of the affected area if a threat to human health is
possible
• Clear radio by calling "EMERGENCY" three (3) times over the radio.
• Obtain medical attention for any injured person(s) through notification 1o911.
• Dispatch emergency personnel to the site to take the appropriate action as needed.
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• Contact the proper authorities if the uncontained spill or release directly threatens
human health or the environment outside of the facility.
• Contact the Oregon State police and the Gilliam County Sheriffs Office first so
that, if necessary, persons downwind or downgradient of the spill or release can be
notified and, if necessary, evacuated. If a large spill occurs, the initial evacuation
area downwind will depend on the nature and volume of the material spilled.
Evacuation distances established by the latest edition of the North American
Emergency Response Guidebook will be referenced where applicable. A copy of
this guidebook is kept at the facility for use in the event of an emergency. The EC
will use this guidebook or other appropriate guidebooks as a reference for
determining safe evacuation distances for spills or releases.
Emergency response personnel will address spills and releases where applicable as follows:
• Put on protective clothing and equipment.
• Once the area can be safely accessed, remove all injured and unnecessary persons from
the hazard area.
• Use 2-way radios for emergency-related communication only.
• If a flammable waste is involved, remove all ignition sources, and use spark and
explosion-proof equipment and clothing in containment and cleanup.
• If applicable and can be safely attempted, stop the leak and/or eliminate the feed source
via valves, fittings, pumps, barriers, dikes, engineering controls, and/ or other
appropriate methods.
• In the event of an uncontrolled leak or spill in the tank or treatment areas, close all
feedlines to the affected unit.
• As soon as practical after the spill is detected, initiate removal of standing liquids.
Treat and dispose of cleanup materials in an appropriate fashion, in accordance with
the WAP.
• Remove surrounding materials that could be dangerously reactive with materials in the
spill or release. Determine the major and hazardous components in the spilled or
released material.
• Contain, divert, and/or absorb spills not contained by dikes or sumps. Spills contained
within the dike or sump can be pumped into an appropriate storage tank, drum, or tank
truck.
• Where applicable, neutralize spilled material with the appropriate reagent.
4.4.3 Power Outages/Equipment Failures
Response to power outages are area specific. If the power outage is facility wide, the first
consideration is the communications systems. The phone system will be checked. If the
phone system is not active, then the radio-phone or cellular phones systems will be checked
to determine if they are working.
The internal radio and alarm systems will also be checked. For internal areas where lighting is
critical to operations, emergency lighting will be provided or operations will be suspended. If
additional lighting is needed for safe operations, then portable, self-powered light facilities
will be used.
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Power outages occur periodically at the facility and do not present an emergency condition
unless they create or exacerbate other incidents. Back-up power in the form of portable
generators are available for certain uses during a power outage.
2.2.2 4.4.4 Prevention of Recurrence or Spread of Fires, Explosions, or Releases
Actions to be taken to prevent the recurrence or spread of fires, explosions, or releases
include shutting down processes and operations, collecting and containing released waste,
and/or recovering or isolating containers. If the facility stops operations in response to an
emergency, site personnel will monitor valves, pipes, and other equipment for leaks, pressure
buildup, gas generation, or ruptures, as necessary, practical, and safe. General inspection
requirements are used as guidelines for these activities. Any areas that appear to have the
potential for ignition of a fire or explosion will be isolated (if possible) and contingency
procedures will be considered.
4.5 Storage and Treatment of Released Material
The EC will make proper arrangements for treatment, storage, or disposal of recovered waste,
contaminated soil, water, or any other contaminated material as soon as practical after a
release or spill. Waste management activities conducted at the facility will be in accordance
with the WAP.
4.6 Incompatible Waste
Wastes that are incompatible with the released material will not be treated, stored, or disposed
in the affected area until decontamination procedures are complete, to the extent necessary.
This will be accomplished by checking the existing WPFs, laboratory data, and/or manifest
data to determine the type of material and its compatibility category. Data and procedures
described in the WAP will be utilized in making compatibility determinations.
4.7 Post-Emergency Equipment Maintenance
All emergency equipment utilized will be cleaned, utilizing on site pressure washers and the
truck wash if applicable. Damaged equipment will be repaired by on-site maintenance
personnel and emergency response equipment such as fire extinguishers and first aid
equipment will replaced after an emergency event. Inspection of all utilized emergency
equipment required by this Contingency Plan will be conducted before normal operations are
resumed in the affected areas. When there has been full implementation of this Contingency
Plan, ODEQ will be notified that cleanup and post-emergency equipment maintenance have
been performed in accordance with [40 CFR 264.56 (h) and (i)] before operations are
resumed in the affected area(s) of the facility.
5 Emergency Equipment
In accordance with 40 CFR 264.52(e)], the facility maintains equipment necessary for
emergency situations. A list of the minimum emergency equipment maintained at the facility
is located in Table 4-4.
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Table 4-4 Emergency Equipment
Table 4 4 CWMNW Emergency Equipment
Emergency Category Equipment Description
Quantity Equipment Location
Equipment Capability
Reference Materials
2016 or current edition North
American Emergency
Response Guidebook
1 Copy
Scale Flouse Offices
Provide information on evacuation
distances, PPE, etc. in case of chemical
emergency.
NIOSH Pocket Guide to
Chemical Flazards
1 Copy
Scale Flouse Offices
Provides general industrial hygiene informat
Alarm System
Siren
1 Copy
Well 5 Water tanks
S-2 Drum Building
Capable of activating emergency response
teams, alerting employees that an
emergency has occurred and initiating site
evacuation.
Facility Communications
Radio System
Multiple
All on site vehicles, scalehouse,
lab, Sample Rack, Maintenance
Build, WWTP-1 and ORU-2
Radios are capable of communication
between employees, management and
Columbia Ridge
Comercial Phone System
Multiple
Scalehouse, lab, Sample Rack,
Maintenance Build, WWTP-1
and ORU-2
Phone lines are capable of communicating
with outside emergency response agencies
(e.g., County Sheriff).
Fire Extingushing Systems
Portable Fire Extinguishers
ABC
Multiple
In all buildings and heavy
equipment
Capable of extinguishing Class A, B, and C
fires
Fire Floses
2
Stored at Outdoor Stabilization
Facility
Capable of spraying water onto fire.
Water tank truck (3,500
gallon) Fire Truck 400
gallons
1
Parked on site when not in use
elsewhere
Capable of moving fire- fighting water and
spraying water onto fire.
Additionally, the following safety and emergency items and equipment are also available at
the facility:
• Two-way radios, installed in all vehicles and heavy equipment, handhelds for
individual personnel
• Off-site telephone communications
• Additional off-site communications devices include cellular phones
• First aid kits are located in the Lab, Scale house and Maintenance building
• Eye washes are located at all processing areas, SU, Evaporation ponds, WWTPs,
ORU, S-2, and the Sample Rack
• oxygen units for supplied air are available at the site
• Showers are available at the site in the following locations: Laboratory, maintenance
Shop, SU, WWTPs, S-2, ORU, Sample Rack and evaporation ponds.
• Spill kits are located in all buildings and at all processing areas,
• heavy equipment is such as track hoe, dozers, front end loaders and ADTs are used
for mitigating and cleaning up large spills
• Equipment decontamination will occur in areas with impermeable surfaces and liquid
containment
• Personnel decontamination will occur in safety showers
Table 4-5 provides information on the type, location and intended use of decontamination
materials for personnel and equipment.
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Table 4-5: Equipment and Personnel Decontamination
Material
Type
Equipment
Description
Quantity
Equipment
Location
Equipment
Capability
Equipment
Decontaminati
on Equipment
Miscellaneou
s cleaning
supplies,
brooms
Multiple
ORU/TDU, Truck
Wash,
Maintenance Shop
Pressure
washers, broom,
and air
compressors are
capable of
cleaning dry and
wet material
from heavy
equipment and
containment
areas
Pressure
washer,
ORU/TDU, Truck
Wash, Site
Management
Vehicles
air
compressors
Maintenance Shop,
ORU/TDU, B-5,
B-4, S-2, B-2, SU
Personnel
Decontaminati
on Equipment
Eye washes,
showers,
garbage bags,
brushes,
disposable
wipes
Multiple
Maintenance Shop,
Laboratory,
Impoundment A
and B
Truck sampling
rack
WWTP1 and 2,
ORU, TDU, S-2
Capable of
decontaminating
persnonel in a
safe manner
Spill Kits
Booms, floor
dry, brooms
and shovels
Multiple
Maintenance Shop,
WWTP1 and 2, S-
2,
Capable of
containing and
holding spills
prior to final
clean up and
aiding in final
cleanup of small
spills
Spill Control
Equipment
Dozers,
Graders,
Front end
loaders,
Track Hoes
Multiple
Landfill, SU,
Capable of
excavating and
cleaning up large
spills
Emergency eyewash fountains and showers are located in varies areas and buildings and in
the laboratory.
Fire extinguishers are available in all buildings, on-site vehicles, and heavy equipment
throughout the facility. These portable fire extinguishers are primarily dry chemical types A,
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B, and C. Type A is capable of extinguishing fires involving ordinary combustible materials
such as wood, cloth, paper, rubber, and many plastics. Type B is capable of extinguishing
fires involving flammable liquids, oils, greases, tars, oil-base paints, lacquers, and flammable
gases. Type C is capable of extinguishing fires involving energized electrical equipment. All
extinguishers comply with National Fire Code standards for portable fire extinguishers. They
are inspected after each use (or at least monthly) and recharged as necessary. Records of these
inspections are kept in the operating record for a period of 1 year.
PPE maintained at the facility includes protective suits, gloves, boots, goggles, hard hats, face
shields and half-face and full-face air purifying respirators. Airline respirators and self-
contained breathing apparatus (SCBA) are also available at the facility. The personal
protective equipment (PPE) is readily available for implementation of contingency response
procedures. Fire specific PPE is maintained in the Fire Truck.
Fire fighting water with adequate volume and pressure to supply water hose stream is
available at the facility from supplied on site wells, water trucks, and storage tanks to supply
the fire truck in case of emergencies. Onsite Well SW1-5 is 620 ft deep and provides 300
GPM, Well SW1-3 is 1325 ft deep and provides 838 gpm. The fire truck is located on site
and contains proper fire fighting PPE for fire response. Soil is also available for emergency
fire control and for use as an absorbent material for containment of spills or leaks.
DEQ Issue TBD- Rev: 0
Page 20 of 28
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6 Coordination Agreements
In accordance with 40 CFR 264.52(c), 264.37, written working agreements are already in
existence between CWMNW and the organizations shown in Table 4-6. These agreements
are maintained electronically and hard copy in the facility's lower office.
Table 4-6 Response and Coordination Agreements
Table 4 6 Response and Coordination Agreements
North Gilliam County Fire Department 911
Local Fire Fighting Services |Fire Services Coordinator
Department has copy of approved Contingency Plan/Permit Attachment #4 and will Receive any Revised Plan
Oregon State Police 866-442-0776
Local Law Enforcement |Sgt./Lt. On-Duty
Department has copy of approved Contingency Plan/Permit Attachment #4 and will Receive any Revised Plan
North Gilliam County Ambulance 911
EMS Services [Operations Officer
Department has copy of approved Contingency Plan/Permit Attachment #4 and will Receive any Revised Plan
Good Shepherd Medical Center (541) 567-6483
Hospital/Medical Services [Emergency Depart Director
Department has copy of approved Contingency Plan/Permit Attachment #4 and will Receive any Revised Plan
EC will provide applicable MSDS's to the medical center for exposed personnel or upon request
Mid Columbia Medical Center (541) 296-1111
Hospital/Medical Services [Emergency Services Coordinator Safety Officer
Facility has copy of approved Contingency Plan/Permit Attachment #4 and will Receive any Revised Plan
Arlington Medical Center (541) 454-2888
Hospital/Medical Services | Administrator
Facility has copy of approved Contingency Plan/Permit Attachment #4 and will Receive any Revised Plan
Gilliam County Emergency Management (541) 351-9530
Emergency Services/Law Enforcement | Sheriff - Emergency Management Coordinator
County has copy of approved Contingency Plan/Permit Attachment #4 and will Receive any Revised Plan
Life Flight (800) 452-7434
Emergency Services | Flight Desk
County has copy of approved Contingency Plan/Permit Attachment #4 and will Receive any Revised Plan
In accordance with 40 CFR 264.53(b)] copies of the Contingency Plan are provided to all of
the organizations listed in Table 4-6 to alert them to the fact that the facility treats, stores, and
disposes of hazardous wastes and that the potential exists for injuries relating to chemical
exposures, burns, respiratory distress, etc. This information alerts the local responders and
hospitals of the potential for injuries at the facility. Notification of the need for services is
provided thru the local Fontier 911 center located in Condon Oregon (Gilliam County).
In compliance with 40 CFR 264.37(b) and 264.52(e), it is CWMNW's understanding that the
local authorities (i.e., Gilliam Sheriffs Department) will respond and provide services to
emergency incidents involving hazardous materials as the incident dictates. It is also expected
that emergency response services will be available from U.S. EPA and the Oregon
Department of Environmental Quality in accordance with [40 CFR 264.37(a)(3)], Since these
agencies must be notified of emergency situations or have teams and individuals that
DEQ Issue TBD- Rev: 0
Page 21 of 28
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routinely respond to hazardous materials spills, no special agreement is needed for these
services. CWMNW has sent notification letters to various emergency response agencies
Coordination/contact with emergency response agencies and services may be handled through
contact with the Oregon Emergency Management Division at 1-800-452-0311. Because of
the rural and isolated setting of CWMNW, site staff and personnel are trained and equipped
to provide the necessary response to on site spills and events. The facility will maintain all
necessary spill response and fire suppression equipment and supplies on site. If assistance is
required, local 911 is contacted, assistance from local fire will be provided at the fence line to
the facility property to protect and keep the fire from leaving the facility. This negates the
need for an Emergency Response Contractor or on-call Equipment Supplier as described in
40 cfr 264.37(a)(3).
DEQ Issue TBD- Rev: 0
Page 22 of 28
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7 Evacuation Plan
In accordance with 40 CFR 264.52(f)], in the event of an emergency that could threaten
human health or the environment as described herein, it will be necessary to follow an
established set of procedures. These procedures will be followed as closely as possible;
however, in specific emergency situations, the EC may deviate from the procedures to
provide a more effective plan for bringing the situation under control. The EC is responsible
for determining which emergency situations require facility evacuation.
The facility employs a warning system with a specific alarm to initiate evacuation of facility
areas. The warning is a long blast on the civil defense siren, and a verbal evacuation order on
the radio. The radios are issued to personnel throughout the facility and are not dependent on
alternating current electrical power. The radio transponder is dependent upon a power source
but has a battery back-up with sufficient power to last for 48-hours. Locations are listed in
Table 4-4.
In addition to the siren, two-way radios, cellular telephones, and the internal telephone system
may be used to notify key facility personnel of the nature of the emergency and the
recommended plan of action. Telephones can also be used to summon aid in emergency
situations. Employees are trained to respond to the evacuation signals. Total facility
evacuation can only be initiated by the EC or their designee.
Evacuation routes and rally points for the facility are shown in Figure 4-3 below. These
routes are as follows:
• Route No. 1 - Main Entrance to Cedar Springs Lane
• Persons evacuating by this route will proceed south and east to the main gate. They
will rally outside the main gate
• Route No. 2 - Gate 9
• Persons evacuating by this route will proceed east through Gate 9 and then to the rally
point at the lower entrance to CWMNW
• Route 3 - Gate 23
• Persons evacuating by this route will proceed west through Gate 23 to the rally point
indicated in Figure 4-3 at evacuation route 3.
If the needed evacuation route is blocked due to the incident, an alternate route to the rally
point may be used. The EC or their designee will determine the safest route to the rally point
and will relay the information to site personnel.
DEQ Issue TBD- Rev: 0
Page 23 of 28
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PAVED RCMB
INDEX CONTOUR
! AND FLOW DIRECTION
Reference:
Topographic Mapping provided by Miller Creek on February 9,2022
Horizontal Datum: NAD 83 / 2011 OR N (3601)
Vertical Datum: NAVD 88
Unit of Measure: International Foot
Datum Shift from Site Historical Vertical Datum: +3.37" (CWMNW)
fcIOO)T Flood Ran
Revisions
Project Location.
Approved By: Dave R&ttell
Chemical Waste Management
Of The Northwest, Inc.
Arlington, Oregon
Evacuation Plan - Figure 4-3
Cheeked By: Ben Arata
Evepof&licn
Port! P-C4
' l«
P
Is"
ag
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~ s?. ¦'
ae"
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.
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Figure 4-3 Evacuation Plan
DEQ Issue TBD- Rev: 0
Page 21 of 28
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In the event facility evacuation is called for by the EC, the following actions where applicable
will typically be taken:
• The siren signal for facility evacuation will be activated, and a verbal evacuation order
will be given over the two-way radios.
• No further entry of unnecessary visitors, contractors, or trucks will be permitted.
Vehicular traffic within the facility will cease.
• Site personnel, visitors, and contractors will leave through the exit gates (see Figure 4-
3) for general evacuation routes), except for properly equipped employees who may
be assigned to control access through the gates.
• No persons will be allowed to remain in or re-enter the area unless specifically
authorized by the EC. Those within the fenced area will normally include only the
rescue team/emergency response and authorized emergency response personnel.
• Site personnel will be accounted for by area. Supervisors may designate certain gates
as the safest exits for employees and may identify an alternate exit if the first choice is
inaccessible. To assist in the endeavor, the EC will use the internal telephone/radio
system to contact the area supervisors and update them of the nature of the emergency.
• Rally points for specific routes are shown on Figure 4-3. Immediately upon exiting
through a gate, the first person from each work area will begin preparing a list to
determine if all personnel by area have been evacuated. Master lists of employees are
kept on file at the scale house building.
• Upon completion of the employee list, the list will be conveyed to the EC. Personnel
will remain at their assigned rally points until the "all clear" signal is given to re-enter
the facility. In the case of a more severe emergency situation, employees, once
accounted for may rally at a position further from the facility.
• Contract personnel and visitors shall be listed with the name of their company.
• The names of emergency team members involved in emergency response will be
determined by the EC.
• A final accounting of personnel will be made by the EC.
• An updated list of all personnel will be maintained to aid in the accountability
procedure. Employees will prevent entry of any unauthorized persons into the facility.
• Re-entry will be made only after the "All clear" signal is given by the EC. At the EC's
direction, a signal or other notification will be given for re-entry into the facility.
• In all questions of accountability, immediate supervisors will be held responsible for
those persons reporting to them. Visitors will be the responsibility of those employees
admitting the visitor to the facility. Contractors are the responsibility of those persons
administering the individual contracts. Truck drivers are the responsibility of the area
supervisor where the truck is loading/unloading. Employees will be assigned to aid in
accounting for visitors, contractors, and truckers by reference to the sign-in sheets.
• Drills will be held annually, at a minimum, to practice emergency evacuation.
If the EC's assessment of the situation indicates that evacuation of local areas may be
advisable, he will immediately notify the Gilliam County Sheriff. The EC will be available to
help appropriate officials decide whether local areas should be evacuated. The Gilliam
County Sheriff will notify the local population in accordance with the Gilliam County
Emergency Plan.
DEQ ISSUE TBD-Rev: 0
10
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8 Required Reports
There are various reporting requirements applicable to the Contingency Plan and periods of
non-compliance contained in 40 CFR 264.56(d) (Emergency Procedures), 40 CFR
270.30(1)(6) (Permit Conditions: 24 hour reporting), OAR 340-104-0056 (Emergency
Conditions). The conditions located in the Part B permit, include all the applicable verbal
and written requirements.
A report format for emergency events is shown in Table 4-7
Table 4-7 Emergency Event Reporting Form
Emergency Event Report Form
Name, address, and phone number of owner or operator
Name, address, and phone number of facility
Date, time and type of incident (e.g. fire, explosion, etc.)
Name and quantity of material(s) involved
Extent of injuries (if any)
Assessment of actual or potential hazards to human health or the environment
Estimated quantities and disposition of material recovered
DEQ ISSUE TBD-Rev: 0
11
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9 Amendments to the Contingency Plan
The Contingency Plan will be reviewed and updated and/or amended, as necessary, whenever
the following occurs:
• The facility permit is revised.
• The Contingency Plan fails in an emergency.
• The facility changes in its design, construction, operation, maintenance, or other
circumstances in a way that materially increases the potential for fires, explosions, or
releases of hazardous wastes or hazardous waste constituents, or where there are
changes in the responses necessary in any emergency.
• The list of ECs changes.
• The list of emergency equipment changes.
• There are relevant changes in the requirements of Oregon Rule or 40 CFR Part 264.
At a minimum, the Contingency Plan will be reviewed annually and amended and/or updated
(as needed). Plan revisions are recorded, and copies of the revisions are sent by the EC to the
organizations listed in Table 4-6.
DEQ ISSUE TBD-Rev: 0
12
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Approval Attachment 4
Table 3-1 of Inspection Plan
(excerpt from Application Appendix F, received by U.S EPA
December 1, 2022)
Approval for Commercial Disposal of Poly chlorinated Biphenyls
Chemical Waste Management of the Northwest, Inc.
Arlington, Oregon
U.S. EPA ID: ORD089452353
U.S. Environmental Protection Agency, Region 10
Seattle, Washington
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Chemical Waste Management of the Northwest, Inc.
Attachment #3 - Inspection Plan
Table 3-1 Daily Inspections - Each Operational Day
Daily Inspections Each Operational Day
Non-Treatment Areas Subject to Spills
Inspection Element
Potential Problems
Frequency
Truck Scale
Inspect for Spills and removal of previously identified spills
Daily
Sam pi i ng Area At Entrance
Inspect for Spills and sampling being conducted in approved areas
Daily
Sampling Area inside Building S-2
Inspect for Spills and sampling being conducted in approved areas
Daily
Roads
Inspect for Drivability, Spills and removal of previously identified spills
Daily
1 1 1
Active Waste Water Treatment Units Each Operational Day
Potential Problems
Frequency
Active Bulk Storage Tanks WWTP-1, WWTP-2, WWTP-3, WWTP-4, WWTP-5
Inspect for Spills, Debris and removal of previously identified spills
Dai
iy
Active System Components WWTP-1, WWTP-2, WWTP-3, WWTP-4, WWTP-5
Inspect for structural integrity of system components, cracks in coating, floors
Dai
iy
Equipment Storage Active WWTP-1, WWTP-2, WWTP-3, WWTP-4, WWTP-5
Inspect for improperly stored equipment, used spill cleanup absorbant, debris and housekeeping
Dai
iy
Overflow Controls Active WWTP-1, WWTP-2, WWTP-3, WWTP-4, WWTP-5
Operate High Level Alarms, inspect overflow controls
Dai
iy
Active Tanks and Containers WWTP-1, WWTP-2, WWTP-3, WWTP-4, WWTP-5
Inspect tanks and containers deformation, corrosion, leaks, Compatable storage, and proper labeling
Dai
iy
Sumps in Active WWTP-1, WWTP-2, WWTP-3, WWTP-4, WWTP-5
Inspect sumps for presence of liquids (pump daily by End of Day)
Dai
iy
Hoses, Piping, Valves in Active WWTP-1, WWTP-2, WWTP-3, WWTP-4, WWTP-5
Inspect Pi ping and Hoses for leaks including WWTP to Pond discharge piping
Dai
iy
Discharge Piping in Active WWTP-1, WWTP-2, WWTP-3, WWTP-4, WWTP-5
Inspect WWTP to Pond discharge piping and secondary containment (>1 gal report)
Dai
iy
Containers in Active WWTP-1, WWTP-2, WWTP-3, WWTP-4, WWTP-5
Inspect container isle space (2.5 ft Min), compatibility, not stored in standing liquids
Dai
iy
Containment in Active WWTP-1, WWTP-2, WWTP-3, WWTP-4, WWTP-5
Inspect for Floor and Sump damage, cracks or deterioration
Dai
iy
Containers in Active WWTP-1, WWTP-2, WWTP-3, WWTP-4, WWTP-5
Inspect 90day containers and tanks foracculumation dates and compliance
Dai
iy
Emergency Spill Kits in Active WWTP-1, WWTP-2, WWTP-3, WWTP-4, WWTP-5
Inspect for proper location and if seal is removed
Dai
iy
1 1
Active Stabilization Units OSU 1 through OSU 6 Each Operational Day
Potential Problems
Frequency
OSU-1, OSU-2, OSU-3, OSU-4, OSU-5, OSU-6
Inspect tanks, sumps, and lined area for damage, corrosion and integrity
Daily
OSU-1, OSU-2, OSU-3, OSU-4, OSU-5, OSU-6
Inspect tanks for spills and leaks
Daily
OSU-1, OSU-2, OSU-3, OSU-4, OSU-5, OSU-6
Inspect for sufficient freeboard in tanks (2 feet)
Daily
OSU-1, OSU-2, OSU-3, OSU-4, OSU-5, OSU-6
Inspect stand pipe for damage and integrity
Daily
OSU-1, OSU-2, OSU-3, OSU-4, OSU-5, OSU-6
Inspect for evidence of liquis in primary sumps
Daily
1 1
Active Stabilization Units B 8 Each Operational Day
Potential Problems
Frequency
Active Stabilization UnitSU-B8- Spills and Leaks
Inspect for Spills, Debris and removal of previously identified spills
Dai
iy
Active Stabilization UnitSU-B8- Structural integrity
Inspect for structural integrity of system components, cracks in coating, floors
Dai
iy
Active Stabilization UnitSU-B8- Equipment and cleanup materials
Inspect for improperly stored equipment, used spill cleanup absorbant, debris and housekeeping
Dai
iy
Active Stabilization Unit SU-B8- overflow alarms and controls
Operate High Level Alarms, inspect overflow controls
Dai
iy
Active Stabilization UnitSU-B8-Tanks and Containers
Inspect tanks and containers deformation, corrosion, leaks, Compatable storage, and proper labeling
Dai
iy
Active Stabilization UnitSU-B8- Sumps
Inspect sumps for presence of liquids (pump daily by End of Day)
Dai
iy
Active Stabilization UnitSU-B8- Piping and Hoses
Inspect Pi ping and Hoses for leaks
Dai
iy
Active Stabilization UnitSU-B8- Discharge pipe
Inspect WWTP to Pond discharge piping and secondary containment (>1 gal report)
Dai
iy
Active Stabilization UnitSU-B8- Containers
Inspect container isle space (2.5 ft Min), compatibility, not stored in standing liquids, lids closed
Dai
iy
Active Stabilization UnitSU-B8- Floor and Sump
Inspect for Floor and Sump damage, cracks or deterioration
Dai
iy
Active Stabilization UnitSU-B8- 90 day containers
Inspect 90day containers and tanks foracculumation dates and compliance
Dai
iy
Active Stabilization UnitSU-B8-Spill Kits
Inspect for proper location and if seal is removed
Dai
iy
1 1
1 Active PCB Storage and Transfer Units S 2, S 11, B 5, B 6, B 7, and B 8
Potential Problems
Frequency 1
| Active Drip Pans
| Inspect for any liquids in pans, Absorb and containerize spilled or leaked liquids
| Daily |
2-1
DEQ To Be Issued Rev: 0
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Chemical Waste Management of the Northwest, Inc.
Attachment #3 - Inspection Plan
Table 3-1 Daily Inspections Continued - Each Operational Day
Daily Inspections Each Operational Day
Inspection Element
Frequency
Active TDU 1 Unit Each Operational Day
Potential Problems
Frequency
Active TDU-1 Unit - Spills and Leaks
Inspect for Spills, Debris and removal of previously identified spills
Dai
iy
Active TDU-1 Unit - Structural integrity
Inspect for structural integrity of system components, cracks in coating, floors
Dai
iy
Active TDU-1 Unit - Equipment and cleanup materials
Inspect for improperly stored equipment, used spill cleanup absorbant, debris and housekeeping
Dai
iy
Active TDU-1 Unit - overflow alarms and controls
Operate High Level Alarms, inspect overflow controls
Dai
iy
Active TDU-1 Unit - Tanks and Containers
Inspect tanks and containers deformation, corrosion, leaks, Compatable storage, and proper labeling
Dai
iy
Active TDU-1 Unit - Sumps
Inspect sumps for presence of liquids (pump daily by End of Day)
Dai
iy
Active TDU-1 Unit - Piping and Hoses
Inspect Pi ping and Hoses for leaks including WWTP to Pond discharge piping
Dai
iy
Active TDU-1 Unit - Discharge pipe
Inspect WWTP to Pond discharge piping and secondary containment (>1 gal report)
Dai
iy
Active TDU-1 Unit - Containers
Inspect container isle space (2.5 ft Min), compatibility, not stored in standing liquids, lids closed
Dai
iy
Active TDU-1 Unit - Floorand Sump
Inspect for Floorand Sump damage, cracks or deterioration
Dai
iy
Active TDU-1 Unit - 90 day containers
Inspect 90day containers and tanks foracculumation dates and compliance
Dai
iy
Active TDU-1 Unit - Spill Kits
Inspect for proper location and if seal is removed
Dai
iy
1 1 1
Active Organic Recovery Units ORU 2 and ORU 3 Each Operational Day
Potential Problems
Frequency
Active Organic Recovery Units ORU_2 and ORU-3 - Spills and Leaks
Inspect for Spills, Debris and removal of previously identified spills
Dai
iy
Active Organic Recovery Units ORU_2 and ORU-3 - Structural integrity
Inspect for structural integrity of system components, cracks in coating, floors
Dai
iy
Active Organic Recovery Units ORU_2and ORU-3 - Equipment and cleanup materials
Inspectfor improperly stored equipment, used spill cleanup absorbant, debris and housekeeping
Dai
iy
Active Organic Recovery Units ORU_2 and ORU-3 - overflow alarms and controls
Operate High Level Alarms, inspect overflow controls
Dai
iy
Active Organic Recovery Units ORU_2 and ORU-3 - Tanks and Containers
Inspect tanks and containers deformation, corrosion, leaks, Compatable storage, and proper labeling
Dai
iy
Active Organic Recovery Units ORU_2 and ORU-3 - Sumps
Inspect sumps for presence of liquids (pump daily by End of Day)
Dai
iy
Active Organic Recovery Units ORU_2and ORU-3 - Piping and Hoses
Inspect Pi ping and Hoses for leaks including WWTP to Pond discharge piping
Dai
iy
Active Organic Recovery Units ORU_2and ORU-3 - Discharge pipe
Inspect WWTP to Pond discharge piping and secondary containment (>1 gal report)
Dai
iy
Active Organic Recovery Units ORU_2 and ORU-3 - Containers
Inspect container isle space (2.5 ft Min), compatibility, not stored in standing liquids, lids closed
Dai
iy
Active Organic Recovery Units ORU_2and ORU-3 - Floorand Sump
Inspectfor Floorand Sump damage, cracks or deterioration
Dai
iy
Active Organic Recovery Units ORU_2 and ORU-3 - 90 day containers
Inspect90day containers and tanks foracculumation dates and compliance
Dai
iy
Active Organic Recovery Units ORU_2 and ORU-3 - Spill Kits
Inspect for proper location and if seal is removed
Dai
iy
1 1 II
Security and Measuring Devices Each Operational Day
Potential Problems
Frequency
| Rain Gage
Record Rainfall, inspectfor damage
Daily |
2-2
DEQ To Be Issued Rev: 0
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Chemical Waste Management of the Northwest, Inc.
Attachment #3 - Inspection Plan
Table 3-1 Weekly Inspections
Weekly Inspections
Inspection Element
Frequency
Emergency, Security and Measuring Devices
Potential Problems
Fence
Inspect Entire Perimeter for Breaches and Damage
Weekly
Employee Entrance
Inspect access controls are functioning, employees are checking in/out
Weekly
Primary Gates
Inspect for Controlled Entry, Damage, and in Working Order
Weekly
Secondary Gates
Inspect for Controlled Entry, Damage, Closed and Locked
Weekly
Emergency Plan - General Inspection
visual inspection for leaks, pressure buildup, gas generation, or ruptures in valves, pipes, or other equipment
Weekly
1 1 1
Active Container Storage Structures
Potential Problems
Frequency
Active Container Storage Areas S-2, S-6, S-10, S-12, B-l, B-2, B-4, B-5, B-6, B-7, and/or B-8
Inspect for damage to floors, sumps, berms and/or curbing
Weekly
Active Container Storage Areas S-2, S-6, S-10, S-12, B-l, B-2, B-4, B-5, B-6, B-7, and/or B-8
Inspect for gaps, cracks or other damage
Weekly
Active Container Storage Areas S-2, S-6, S-10, S-12, B-l, B-2, B-4, B-5, B-6, B-7, and/or B-8
Inspect for presence of liquids in sumps, and physical integrity of sumps and standpipes if equipped
Weekly
Active Container Storage Areas S-2, S-6, S-10, S-12, B-l, B-2, B-4, B-5, B-6, B-7, and/or B-8
Inspect storage areas for signs of deterioration of structures
Weekly
Active Container Storage Areas S-2, S-6, S-10, S-12, B-l, B-2, B-4, B-5, B-6, B-7, and/or B-8
Inspect for Spills and removal of spill cleanup materials
Weekly
Active Container Storage Areas S-2, S-6, S-10, S-12, B-l, B-2, B-4, B-5, B-6, B-7, and/or B-8
Inspect waste storage piles to ensure retaining walls are not being overtopped
Weekly
Fugitive Emission Controls all active units
Inspect to ensure no visible emissions in each active area, including doors, vents, and louvers using Method 22
Weekly
Emissions Control Equipment all active units
Inspect stacks for visible emissions using Method 22
Weekly
Contamination Control - Decontamination Areas all active units
Inspect for adequate housekeeping, presence of wastes, trackout
Weekly
Storage Area Capacity all active units
Check to ensure capacity is not exceeded
Weekly
1 1 1
Containers in Storage
Potential Problems
Frequency
Containers General 264.174
Check for Deterioration, Leaks, Swelling, Lids are attached,
Weekly
Containers Labeling
Inspect all containers (incl 90day) to ensure load sheet number and compatability label are visable and readable
Weekly
Containers Compatability
Visual Check to ensure containers in segrigated storage are compatable
Weekly
Containers Drums, Totes, Pails
Adequate Isle Space (2.5 ft) between rows of containers
Weekly
Subpart CC and FF Container Compliance
Inspect affected containers covers for Visiable cracks, holes, gaps
Weekly
Subpart CC and FF Container Compliance - Biotreatment Containers
Inspect affected Biotreatment containers covers for Viable Cracks, holes, gaps
Weekly
1 1 1
Active Landfill
Potential Problems
Frequency
L-14 and/or L-15- General
Inspect for wind dispersal of wastes and dust control effectiveness on access roads
Weekly
L-14 and/or L-15 Run-On/Run-Off Controls
Inspect for removal of rainfall volumes
Weekly
L-14 and/or L-15 Run-On/Run-Off Controls
Inspect berms and ditches for silting, debris, erosion, and ponded water
Weekly
L-14 and/or L-15 Leachate Application
Inspect for ponding, runoff, seepage
Weekly
Active Landf
II L-14 and L-15
Inspect for Ponding, Run-on, and Runoff
Weekly
Active Landf
II L-14 and L-15 - Primary Leachate Sumps
Inspect/Re cord Liquids removed in Primary sumps (Report if >4S")
Weekly
Active Landf
II L-14 and L-15-Secondary Leachate Sumps
Inspect/Re cord Liquid for Levels in Secondary sumps (Report any), risercoverand lock
Weekly
Active Landf
II L-14 and L-15-Tertiary Leachate Sumps
Inspect/Re cord Liquid for Levels in Tertiary sumps (Report any), risercoverand lock
Weekly
Active Landf
II L-14 and L-15-All Risers
Inspect to ensure riser cover and lock are in place
Weekly
Active Landf
II L-14 and L-15-Wind Dispersal
Properfunctioningof Wind Dispersal control systems where present
Weekly
1 1
2-3
DEQ To Be Issued Rev: 0
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Chemical Waste Management of the Northwest, Inc.
Attachment #3 - Inspection Plan
Table 3-1 Weekly Inspections Continued
Pond P-A/P-B General
Inspect for Freeboard, must be >1.4 ft
Active Pond P-A, P-B, P-C, P-D, P-E and/or P-F Sump Accumulated Liquids
Inspect/Record Liquid Levels and volume if pumpable from Primary Leak Detection riser(s) (report any)
Active Pond P-A, P-B, P-C, P-D, P-E and/or P-F
Inspect for indications of sudden decrease/increase in levels
Active Pond P-A, P-B, P-C, P-D, P-E and/or P-F General and Unloading Areas
Inspect for proper Housekeeping and condition of, Hoses, Pumps, Spills, Piping
Active Ponds P-C, P-D, P-E and/or P-F
Inspect for Freeboard, must be <2.0 ft
Active Ponds P-C, P-D, P-E and/or P-F Sumps
Inspect/Record Liquid Levels and volume if pumpable from Secondary sumps (Report any)
Active Ponds P-C, P-D, P-E and/or P-F Sumps
Inspect/Record Liquid Levels and volume if pumpable from Tertiary sumps (Report any)
Active Ponds P-A, P-B, P-C, P-D, P-E and/or P-F Level Indicator
Inspect for indications of sudden decrease/increase in levels
Active Ponds P-A, P-B, P-C, P-D, P-E and/or P-F Runon/Runoff
Inspect berms and ditches for silting, debris, erosion, and ponded water
Active Ponds P-A, P-B, P-C, P-D, P-E and/or P-F Structural integrity
Inspect for containment berm failure if pond is above ground
Active Pond P-A, P-B, P-C, P-D, P-E and/or P-F
Inspect risercoverand lockare in place
Active Pond P-A, P-B, P-C, P-D, P-E and/or P-F
Inspect for hose damage or leaks
Pumps 61.242.2(a)(2)
Visually Inspect Pumps for Leaks from the pump seal
Weekly
Active unit leak assesment
visual inspections for visible, audible, or olfactory indications of leaks
Weekly
OWS-1 Carbon Adsorption Vent
The exhaust vent stream from the carbon adsorption system is monitored using Method 21 in compliance with 61.355(h) on a
regular schedule. Readings exceeding 500ppm VOCs, the existing carbon will be replaced with fresh carbon immediately.
Weekly
Active Storage Areas S-2, S-ll, B-5, B-6, B-7, and B-8
Inspect for unused pans, berm integrity
Weekly
Active Drip Pans
Inspect for any liquids in pans, Absorb and containerize spilled or leaked liquids
Weekly
Vehicles and Equipment
Visually inspect mobile equipment for presence of contamination, and for unauthorized vehicles
Weekly
Active Storage Area floors S-2, S-ll, B-5, B-6, B-7, and B-8
Inspect floors, berms and curbing for cracks, deterioration and area allows safe transfer
Weekly
PCB Containers in storage 761.65(c)(5)
Visually inspect PCB Items for out of service dates, spilled or leaked materials
Weekly
Active Storage Units S-2, S-6, S-12, B-l, B-2, B-4, B-5, B-6, B-7, B-8
Inspect active Outdoor/Building units for Spills and removal of previously identified spills
Weekly
Containers in Active Storage S-2, S-6, S-12, B-l, B-2, B-4, B-5, B-6, B-7, B-9
Inspect for container closure devices being inplace and intact (lids, tarps and
Weekly
Active Storage Units S-2, S-6, S-12, B-l, B-2, B-4, B-5, B-6, B-7, B-8
Inspect for container compatibility
Weekly
Presence of Liquids in Sumps
|inspect for presence of pumpable liquids in sumps Record volumes pumped
2-4
DEQ To Be Issued Rev: 0
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Chemical Waste Management of the Northwest, Inc.
Attachment #3 - Inspection Plan
Table 3-1 Semi-Annual, Quarterly, and Monthly Inspections
Semi Annual Inspections
Inspection Element
Frequency
Closed Landfills L 5, L 7, L 9, and L 10
Potential Problems
Final Cap Condition
Visually Inspect for Ponding, Settling, Cracking, Fractures, Erosion and signs of burrowing animals
Semi-Annual
Final Cap Condition - Vegetation
Inspect for areas without vegetation
Semi-Annual
Run-On/Run-Off Structures
Inspect for damage, and erosion
Semi-Annual
1 1 1
Groundwater Monitoring Wells
Potential Problems
Groundwater Monitoring Wells
Inspect for wells being visable and accessable
Semi-Annual
Groundwater Monitoring Wells
Inspect for area around wells for good housekeeping, Clean
Semi-Annual
Groundwater Monitoring Wells
Inspect for casing and cap for damage and cap is locked
Semi-Annual
Quarterly Inspections
Inspection Element
Frequency
Security and Measuring Devices
Potential Problems
Internal Radio Communications 254.33 | Inspect accessibility and operations |Q.uarterly
Stabilization Units OSU 1 through OSU 6
Potential Problems
Frequency
OSU-1, OSU-2, OSU-3, OSU-4, OSU-5, OSU-10 | Inspect Secondary Sumps for presence of liquids |Quarterly
Active Organic Recovery Units ORU 2 and/or ORU 3
Potential Problems
Frequency
Subpart FF inspection
Inspect for visible defects that could result in air pollutant emissions
Quarterly
OWS-1 Carbon Adsorption System
Inspect carbon tanks, piping, connection, and covers for evidence of defects and/or deterioration
Quarterly
1 1
Active Containment Buildings
Potential Problems
Frequency
Emission unit preventive maintenance
Confirm that preventive maintenance is being completed frequency recommended by manufacturer
Quarterly
Standby Generators and other engine driven equipment
Confirm that preventive maintenance is being completed frequency recommended by manufacturer
Quarterly
Monthly Inspections
Inspection Element
Frequency
Safety and Emergency Devices
Potential Problems
Fire Water Line 264.33
Check for Adequate Pressure (60 psi)
Monthly
Emergency Plan - Alarm Systems (Sirens and Flashing Beacon) 264.33
Check Accessability, Activate Siren, Activate Flashing Beacon
Monthly
Closed Landfills L 12. L 13
Potential Problems
Frequency
Final Cap Condition
Inspect for Ponding, Settling, Cracking, Fractures, Erosion and signs of burrowing animals
Monthly
Final Cap Condition - Vegetation
Inspect for areas without vegetation
Monthly
Run-On/Run-Off Structures
Inspect for damage, and erosion
Monthly
Leachate Collection System
Inspect for damaged risers and instrumentation, presence of liquids in the sumps
Monthly
1 1 II
OWS 1 inside Building B 5
Potential Problems
Frequency
OWS-1 Tanks, Equipment and Piping
Inspect for visible leaks and general condition. .
Monthly
OWS-1 Overfill Alarms and systems
The overfill alarm systems shall be tested to insure they are in working order.
Monthly
OWS-1 Containment, Sumps
Inspected forevidence of any liquid collection and evidence of any leakage
Monthly
2-5
DEQ To Be Issued Rev: 0
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Chemical Waste Management of the Northwest, Inc.
Attachment #3 - Inspection Plan
Table 3-1 Initial, Annual, and Event Inspections
Event Based Inspections
Inspection Element
Frequency
Rain Event greater than 0.1
Surface water diversion and retention structures
Visually inspect landfill cover, sumps, ponds, embankments, roads, dikes, surface run-off structures, and drainage ways
Rain Event
Power Outage Greater than 8 Hours
Visual inspections of various areas onsite that would normally be monitored using electronic mechanisms
Active Organic Recovery Units ORU 2 and ORU 3
Potential Problems
Frequency
Closed Vent Air Pollution Control Equipment
Inspect for visible defects that could result in air pollutantemissions
Initial
Subpart FF inspection
Inspect for visible defects that could result in air pollutantemissions
Initial
Annual Inspections
Inspection Element
Frequency
Security and Measuring Devices
Potential Problems
Warning Signs
Visually Inspect for presence of signage around active areas and for legibility of printing
Annual
Active Organic Recovery Units
Potential Problems
Closed Vent Air Pollution Control Equipment
Visually Inspect Active Organic Recovery Units for defects that could result in air pollutant emissions
Annual
Semi Annual Inspections
Inspection Element
Frequency
Closed Landfills L 5, L 7, L 9, and L 10
Potential Problems
Final Cap Condition
Visually Inspect for Ponding, Settling, Cracking, Fractures, Erosion and signs of burrowing animals
Semi-Annual
Final Cap Condition - Vegetation
Inspect for areas without vegetation
Semi-Annual
Run-On/Run-Off Structures
Inspect for damage, and erosion
Semi-Annual
1 1 II
Groundwater Monitoring Wells
Potential Problems
1
Groundwater Monitoring Wells
Inspect for wells being visable and accessable
Semi-Annual
Groundwater Monitoring Wells
Inspect for area around wells for good housekeeping, Clean
Semi-Annual
Groundwater Monitoring Wells
Inspect for casing and cap for damage and cap is locked
Semi-Annual
2-6
DEQ To Be Issued Rev: 0
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Approval Attachment 5
Landfill Design, Operations and Response Action Plan
(Application Appendix L, received by U.S EPA December 1, 2022)
Approval for Commercial Disposal of Poly chlorinated Biphenyls
Chemical Waste Management of the Northwest, Inc.
Arlington, Oregon
U.S. EPA ID: ORD089452353
U.S. Environmental Protection Agency, Region 10
Seattle, Washington
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APPENDIX L
Landfill Design, Operations and Response Action Plan
For
Chemical Waste Management of the Northwest, Inc.
Received by EPA Region 10 on December 1, 2022
Appendix to CWMNW's final TSCA PCB application
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Chemical Waste Management of the Northwest, Inc.
Attachment No. 14 - Landfill Design, Operations Plan and Response Action Plan
Landfill Design, Operations and
Response Action Plan
For
Chemical Waste Management of the Northwest,
Inc.
Arlington Facility • ORD 089 452 353
17629 Cedar Springs Lane
Arlington, Oregon
Attachment No. 14
This document is to be issued by the
Oregon Department of Environmental Quality
i Revision 0: Jan 2022
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Chemical Waste Management of the Northwest, Inc.
Attachment No. 14 - Landfill Design, Operations Plan and Response Action Plan
Contents
RCRA Landfill Checklist Error! Bookmark not defined.
1 INTRODUCTION 1-5
1.1 Active Landfills 1-6
1.2 Closed Landfills 1-6
Table 14-1 SUMMARY OF SIZE AND CAPACITY OF CLOSED LANDFILL UNITS 1-7
2 ACTIVE LANDFILL DESIGN Error! Bookmark not defined.
3 Landfill L-14 Design 3-1
3.1 General Configuration 3-1
3.2 Landfill L-14 Foundation 3-1
3.3 Foundation Settlement and Bearing Capacity3-2
3.4 Landfill L-14 Liner and Leachate Collection System Design 3-2
3.5 Base Grade Configuration 3-3
3.6 LCRS Geocomposite Flow Capacity 3-4
3.7 Sump Riser Pipe Structural Integrity 3-4
3.8 Slope Stability3-4
3.9 Slope Stability Evaluation Methods 3-4
3.10 Interface Friction Angles and Shear Strength3-5
3.11 Static and Seismic Analysis Parameters 3-5
3.12 Stability of Intermediate Grade Slopes 3-5
3.13 Stability of Final Waste Mass and Cover 3-5
3.14 Landfill L-14 Liner Specifications and Installation 3-6
3.15 Landfill L-14 Final Cover 3-6
3.16 Landfill L-14 Final Cover Soil Erosion 3-6
Table 14-2 SUMMARY OF LANDFILL L-14 DESIGN CELLS 1-3 3-1
4 Landfill L-15 Design 4-1
4.1 Landfill Configuration 4-1
4.2 Foundation Settlement and Bearing Capacity4-1
4.3 Description of Landfill Lining System 4-1
4.4 Landfill L-15 Liner and Leachate Collection System Design 4-2
4.5 Geosynthetic Clay Liner 4-2
4.6 Base Grade Configuration 4-3
4.7 LCRS Geocomposite Flow Capacity 4-3
4.8 Sump Riser Pipe Structural Integrity 4-3
4.9 Slope Stability - Intermediate Slopes 4-3
4.10 Interface Friction Angles and Shear Strength4-3
4.11 Static and Seismic Analysis Parameters 4-4
4.12 Landfill L-15 Liner Specifications and Installation 4-4
Table 14-3 SUMMARY OF LANDFILL L-15 DESIGN 4-5
5 LANDFILL OPERATIONS 5-1
5.1 Waste Acceptance Procedures 5-1
5.2 Fill Sequencing 5-2
5.3 Control of Run-on and Run-off 5-3
5.4 Construction Inspection of Landfills 5-4
5.5 Final Cover 5-4
5.6 Ignitable and Reactive Wastes 5-5
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Attachment No. 14 - Landfill Design, Operations Plan and Response Action Plan
5.6.1 Incinerable Ignitable or Reactive Labpack Packaging 5-5
5.7 Incompatible Wastes 5-5
5.8 Control of Wind Dispersal of Wastes 5-5
5.9 Disposal of Dioxin-Containing Wastes 5-7
5.9.1 Exposure Control Practices 5-7
5.9.2 Waste Characteristics 5-7
5.9.3 Disposal Procedures 5-7
5.10 Special Requirements for Containers 5-8
6 ALR Engineering Calculations Specific to Landfill 14 6-9
6.1 Introduction 6-9
6.2 Purpose 6-9
6.3 Project Location 6-9
6.4 Landfill Development 6-9
6.5 Description of Landfill Lining System 6-9
6.6 Base Liner System 6-10
6.7 Leachate Leak Detection Systems 6-10
6.8 Tertiary Sump Monitoring System 6-10
6.9 Description of the LDS 6-10
6.10 Leachate Management 6-10
6.11 Potential Sources of Liquid in LDS 6-11
6.12 Construction-Related Liquids 6-11
6.13 Internal Sources 6-11
6.14 External Sources 6-11
6.15 Liquid Removal Capacity of the LDS 6-11
6.16 LDS Design Considerations 6-12
TABLE 14-4 Drainage Geocomposite Partial Reduction Factors 6-12
6.17 Leak Detection Time 6-12
6.18 Action Leakage Rate 6-13
TABLE 14-5 Cell Specific Action Leakage Rates (ALRs) 6-14
6.19 Verification of LDS Sump Capacity 6-14
7 ALR Engineering Calculations Specific to Landfill 15 7-15
7.1 Introduction 7-15
7.2 Purpose 7-15
7.3 Project Location 7-15
7.4 Landfill Development 7-15
7.5 Description of Landfill Lining System 7-16
7.6 Base Liner System 7-16
7.7 Leachate Leak Detection Systems 7-16
7.8 Tertiary Sump Monitoring System 7-16
7.9 Description of the LDS 7-16
7.10 Leachate Management 7-16
7.11 Potential Sources of Liquid in LDS 7-17
7.12 Construction-Related Liquids 7-17
7.13 External Sources 7-17
7.14 Liquid Removal Capacity of the LDS 7-17
7.15 LDS Design Considerations 7-17
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Chemical Waste Management of the Northwest, Inc.
Attachment No. 14 - Landfill Design, Operations Plan and Response Action Plan
TABLE 14-6 Drainage Geocomposite Partial Reduction Factors 7-18
7.16 Leak Detection Time 7-18
7.17 Action Leakage Rate 7-18
TABLE 14-7 Cell Specific Action Leakage Rates (ALRs) 7-19
7.18 Verification of LDS Sump Capacity 7-20
8 Landfill L-14 / L-15 Response Action Plan 8-20
8.1 Monitoring of the Primary Leachate Collection Sumps 8-20
8.2 LDS Monitoring 8-20
8.3 Response Action Plan 8-20
8.4 EPA and DEQ Requirements 8-21
8.5 TERTIARY SUMP MONITORING PROGRAM 8-21
8.6 Tertiary Sump Monitoring Frequency 8-22
8.7 Tertiary Sump Volume and Chemical Measurements 8-22
TABLE 14-8 Tertiary Sump Monitoring Parameters 8-22
8.8 Sump Sampling, Laboratory Analysis Procedures, and Reporting 8-23
TABLES
14-1 Summary of Size and Capacity of Closed Landfill Units
14-3 Summary of Landfill L-14 Design Cells 1-3
14-4 Summary of Landfill L-14 Design Cells 4-8
14-5 Summary of Landfill L-15 Design
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Chemical Waste Management of the Northwest, Inc.
Attachment No. 14 - Landfill Design, Operations Plan and Response Action Plan
LANDFILL DESIGN AND OPERATIONS PLAN
1 INTRODUCTION
This Landfill Design and Operations Plan addresses existing landfill units included in the Part B permit
at the Chemical Waste Management of the Northwest, Inc. (CWMNW) Arlington Facility. Locations of
the landfills are shown on Permit Figure 1-1 Facility Layout Map (as contained in the Part B Permit). As
shown on the figure, there are two not closed landfills in the Part B permit; L-14, and L-15 and eight
landfills, which have been completely filled and closed in accordance with an approved closure plan (L-
1, L-3, L-5, L-6, L-7, L-8, L-9, L-10, L-12, and L-13). Permit Figure 1-1 Facility Layout Map (as
contained in the Part B Permit) also shows the location of all landfills described above.
Landfill units at the Arlington Facility are used for the permanent disposal of solid hazardous and
industrial wastes. On reaching final design grades, the active landfills L14 and L-15 are covered by a
final cover designed to minimize soil erosion and infiltration of rainwater through the final cover. Final
cover design details for the currently active and future proposed landfills are presented in the following
documents:
• Alternative Final Cover Design Report, Landfills L-12, L-13 and L-14, Chemical Waste
Management Arlington Facility, Gilliam County, Oregon, Applied Soil Water Technologies,
August 2014.
• Alternative Final Cover Design Modification Report, Landfills L-13 and L-14, Chemical Waste
Management Arlington Facility, Gilliam County, Oregon, Geo-Logic Associates, Inc., July 2020.
All types of commercial, industrial, and agricultural wastes, including those identified or listed as
hazardous wastes in 40 CFR Part 261, are potential candidates for landfill disposal at the Arlington
Facility. Wastes that are not accepted at the facility are listed in Attachment #1 - Waste Analysis Plan. In
addition, bulk and containerized liquid wastes are not accepted for landfilling, unless:
• The waste has been stabilized so that free liquids no longer are present.
• The container is very small (such as an ampule) or is a lab pack, or
• The container is designed to hold free liquids for use other than storage, such as a battery.
• Waste analysis procedures, which dictate what wastes will be accepted for landfilling, are
presented in the facility's Attachment #1 - Waste Analysis Plan.
Landfill L-14 was originally permitted with a disposal capacity of 3.1x106. In 2013 CWMNW received
approval of the addition of Cell 5 which increased the disposal capacity of Landfill L-14 from 3.1xl06
cubic yards to 6.2xl06 cubic yards. In 2022 as part of the Part B Renewal CWMNW increased the
capacity of L-14 by adding Cells 6 through 8 which increased the capacity by 3.9xl06 cubic yards giving
a total of lO.lxlO6 cubic yards. All landfill units are located well above the saturated zone (i.e., the
uppermost aquifer). A comprehensive description of the site geology/hydrogeology can be found in the
following documents previously submitted to the Oregon Department of Environmental Quality (DEQ):
Geologic andHydrogeologic Site Characterization Report, Part B Permit Application, prepared for
Chem-Security Systems, Inc., by Dames and Moore, dated April 1987.
RCRA Facility Investigation Report for Landfill Units L-9 and L-10, prepared for Waste
Management, Inc. (Arlington, Oregon), by CFhMHill and Rust Environment and Infrastructure, Inc.,
dated May 20, 1996; and
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Attachment No. 14 - Landfill Design, Operations Plan and Response Action Plan
Hydrogeologic Investigation and Engineering Design Report for Landfill L-14, Arlington, Oregon,
prepared for Chemical Waste Management of the Northwest, Inc., by Rust Environment and
Infrastructure Inc., dated February 1998.
The uppermost aquifer which may potentially be impacted as a result of the landfill activities is
monitored in accordance with the facility's Attachment #7 - Groundwater Monitoring Plan.
1.1 Active Landfills
This Landfill Design and Operations Plan focuses on design features and landfill operational procedures
for currently active and future landfill cells. Supporting geotechnical studies and engineering analyses
performed as part of the landfill siting/design have been previously submitted to the DEQ prior to each
landfill unit construction. Active landfill L-14 has been constructed in accordance with approved
construction drawings and technical specifications prepared specifically for each phase of construction.
Phases approved for waste placement in landfill L-14 include Cells 1, 2, 3 and 4 (modules A, B and C).
Waste placement in Landfill L-14 (cells 5 through 8) will be initiated once all construction CQA
documents are approved. Waste Placement in landfill L-15 (Cells 1-4) will be initiated once all
documents in accordance with 40 CFR 264.301 through 264.304 (i.e., engineering design report,
construction CQA) are submitted and approved by the Department. Construction quality assurance for
all landfill cell construction will be in accordance with Attachment #16 - Construction Quality Assurance
Plans.
Applicable key design components for the currently active landfills and the remaining unconstructed cells
within Landfill L-14 and L-15 are summarized in Table 14-2, and Table 14-3.
Active landfills are inspected at least weekly in compliance with Attachment #3 Inspection Plan
1.2 Closed Landfills
Ten landfill units (L-l, L-3, L-5, L-6, L-7, L-8, L-9, L-10, L-12, and L-13) have been closed, via
placement of a final cover, in accordance with approved closure plan specifications at the time of closure.
Table 14-1 summarizes the size and capacity of the closed landfill units. Copies of the closure
certifications for all closed landfills are on file at the facility. Closed landfills are regularly inspected in
compliance with Attachment #3 - Inspection Plan
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Chemical Waste Management of the Northwest, Inc.
Attachment No. 14 - Landfill Design, Operations Plan and Response Action Plan
Table 14-1 SUMMARY OF SIZE AND CAPACITY OF CLOSED LANDFILL UNITS
Landfill Unit
Size/Capacity
Operating Status
L-l
60'x 500'x 25' (deep)
Completely filled: July 15, 1981
Final closure cover: completed
L-3
65' x500' x 32.5' (av. depth)
Completely filled: December 1,1981
Final closure cover: completed
L-5
160' x 350' x 34.5' (av.depth) (RCRA wastes)
160' x 150' x 31.75' (av. depth) (non-RCRA wastes)
Completely filled: May 20,1981
Final closure cover: completed
L-6
175'x 700'x 30' (av. depth)
Completely filled: May 20,1981
Final closure cover: completed
L-7
255' x 525' x 48' (deep) (RCRA wastes)
187' (av.) X 135' x 42' (deep) (non-RCRA wastes)
Capacity 167 acre-feet ®
Completely filled: 1990
Final closure cover: completed
L-8
120' x 600' x 30' (deep) (accepted potlining wastes)
Capacity 65 acre-feet ®
Completely filled: 1989
Final closure cover: completed
L-9
200' x 400' x 50' (deep) (RCRA wastes)
200' x 200' x 40' (deep) (non-RCRA wastes)
Capacity 101 acre-feet®
Completely filled: 1990
Final closure cover: completed
L-10
400' x 600 x 66' (deep)
Capacity 362 acre-feet
Completely filled: 2002
Final closure cover: completed
L-12
900' X 440' X 52' 493 acre feet
Final closure March 2018
L-13
850' X 900' X 78' 1487 acre feet
Final closure December 2020
Notes:
W This is the total capacity of the landfill during its active life and included mounding of waste above grade.
The capacity for non-RCRA waste is not included in this amount.
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Attachment No. 14 - Landfill Design, Operations Plan and Response Action Plan
2 Active Landfill L-14 and L-15 Design
There are two landfill units in the Part B Permit at the Arlington Facility, L-14 and L-15. These active
landfills all received hazardous wastes after November 19, 1980 (the date when hazardous wastes were
first regulated under RCRA). Detailed engineering design documents, plans, and specifications for
construction of the active landfills are maintained in Attachment #18 - Landfill Design Drawings.
Pertinent design details are summarized in Tables 14-2, and 14-3.
All landfill cells are surveyed once constructed as part of the CQA process contained in Attachment #16
- Construction Quality Assurance Plan in compliance with 40 CFR 264.309.
The following sections discuss the design specifics relating to the active landfills.
3 Landfill L-14 Design
3.1 General Configuration
Landfill L-14 is designed in compliance with 40 CFR 264.301 and is designed as a multi-phase unit
divided into eight hydraulically separated cells. The 2013 expansion of Landfill L-14 added Cell 5 which
increased landfill L-14 acreage to 67.9 acres. As part of the Part B Renewal in 2022, Cell 5 was rotated
and Cells 6 through 8 were added which added 16.4 acres. Therefore L-14 Cells 1 through 8 now have a
planar area 84.3 acres and a total design capacity of approximately lO.lxlO6 cubic yards. Supporting
engineering analyses performed in support of the currently permitted landfill siting/design have been
previously submitted to the DEQ in the following documents:
Hydrogeologic Investigation and Engineering Design Report for Landfill L-14, Arlington,
Oregon, prepared for Chemical Waste Management of the Northwest, Inc., by Rust Environment
and Infrastructure Inc., dated February 1998 - Section 8.0 and Appendix G.
Engineering Design Report for Landfill L-14 Expansion, by Civil & Environmental Consultants,
dated March 30, 2020
The overall design for L-14 Cells 5-8 remains similar to previously constructed landfill unit Cell 4 which
meets or exceeds the minimum technology requirements for landfill units. General design details for the
currently permitted Landfill L-14 are summarized in Table 14-2 and 14-4.
Cells 1 through 4(Phases A-C) of Landfill L-14 were constructed as originally designed in 2003, 2005,
2010,2011, 2017, 2018 and 2021.
The 2013 and 2022 expansions of Landfill L-14 resulted in the need to revise the site's surface water
management system, because the expanded footprint encroaches into existing or designed surface water
management impoundments located directly north of L-14, and some of the surface water conveyance
systems, such as surface water conveyance ditches around the new footprint of L-14. Details of the
revised surface water management system are provided in the facility Surface Water Management Plan,
previously Standalone Document #6, which has been removed from the Part B permit.
3.2 Landfill L-14 Foundation
Detailed geotechnical analyses were conducted as part of the original L-14 siting/design to evaluate
settlement/heave, bearing capacity, and cut slope stability under static and dynamic loading conditions.
The results of these evaluations and other analyses presented in this section have been previously
submitted to the DEQ in the following document as part of the design/siting documents required for
landfill construction approval:
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Chemical Waste Management of the Northwest, Inc.
Attachment No. 14 - Landfill Design, Operations Plan and Response Action Plan
Hydrogeologic Investigation and Engineering Design Report for Landfill L-14, Arlington,
Oregon, prepared for Chemical Waste Management of the Northwest, Inc., by Rust Environment
and Infrastructure Inc., dated February 1998.
Bearing Capacity, Settlement and Slope Stability Analysis, L-14 Cells 5-8, by Geosyntec, dated
May 20, 2020. The overall geotechnical results for L-14 Cells 5-8 remains similar to previously
analysis with the design meets or exceeds the requirements for landfill units.
3.3 Foundation Settlement and Bearing Capacity
Soils beneath L-14 have relatively high strength and low compressibility characteristics. Since the
landfill's foundation grades are well above (>100 feet) the groundwater table, most of the anticipated
settlement is elastic and will occur as the loads are applied.
Settlement of the soils underlying the landfill (and of the soil/bentonite component of the base liner
system, for Cells 4-8 was evaluated along a select leachate flowline within each of the eight cells.
Loads for each cell were calculated based on the proposed final grades of the expanded landfill.
For the eight sections analyzed, the base grade slopes on the floor of L-14 meet the requirement of 40
CFR § 264.301(c)(3)(i) to be constructed at a minimum slope of 1.5%. Conservative estimates of post-
settlement slopes show that all sections will maintain positive drainage.
Bearing capacity of the landfill was evaluated in 2013 for Cells 1-5 and also re-evaluated for the
expansion of Cell 6-8 to ensure that the base of the landfill would remain stable under the increased load
resulting from the landfill expansion. The bearing capacity of the soils underlying the landfill was
evaluated assuming that general shear failure will control since the landfill is a relatively non-rigid
foundation on the subgrade soils.
For Cells 1-5, two scenarios were evaluated that cover the range of possible failure conditions. Both
scenarios used long term or drained soil strength and assume the landfill is at the maximum height. A
third scenario that used undrained or short-term soil strength was considered but not evaluated because
rapid soil loading conditions that induce undrained conditions in the soil have not occurred as the existing
landfill has been filled, nor are they anticipated as part of the landfill development from expansion.
Results of the calculations show the soils underlying Landfill L-14 has sufficient bearing capacity to
support the Cells 1-5 expanded landfill under the design conditions.
For the expansion of Cells 6-8, L-14 bearing capacity was rechecked using the maximum height and
thickness of the landfill. The 2022 L-14 expansion did not increase the overall height of the landfill.
Results confirmed past bearing capacity results of sufficient bearing capacity to support the expanded
landfill.
3.4 Landfill L-14 Liner and Leachate Collection System Design
The liner system for Landfill L-14 was designed in accordance with applicable regulations and EPA
guidance. The liner system in certain cells is similar to those of Landfills L-12 and L-13; however,
several key enhancements have been made in cells going forward:
Tertiary Sump - Each cell within L-14 has a tertiary sump constructed beneath the primary and
secondary leachate collection sump system. The tertiary sump acts as an "engineered vadose zone" in an
area of the landfill with the highest likelihood of a potential release (i.e., leachate collection sumps). The
tertiary sumps are designed to provide the landfill unit with the earliest possible indication of a release
that can be effectively monitored.
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Attachment No. 14 - Landfill Design, Operations Plan and Response Action Plan
Incorporation of Geosynthetic Clay Liner - The liner system in all cells of L-14 utilizes a geosynthetic
clay liner (GCL) in the upper composite (primary) liner, instead of the soil/bentonite liner used in
Landfills L-12 and L-13. For Cells 4 through 8, GCL will also be used in the construction of the lower
composite (secondary) liner as a replacement for the compacted soil/bentonite layer because of the lower
permeability of the GCL.
An equivalency evaluation was conducted as part of the original Landfill L-14 permitting in 1998. It was
not revised as part of this update because the design conditions have not changed. The original evaluation
determined that the flux of water through the soil/bentonite liner was approximately 2.7 times greater
than that for a GCL. This, along with other factors (scarcity of soil materials for soil liner, favorable
weather conditions, production quality, cost, installation, repairs etc.), makes the GCL a suitable
replacement to the soil/bentonite layer and will further reduce the possibility of a release from Landfill L-
14. The liner system (base and sideslope) for Landfill L-14 is summarized in Table 14-2.
Within each cell, leachate from the primary and secondary collection systems is channeled toward
primary and secondary leachate collection sumps, respectively, located on the landfill bottom. Each
primary sump in Cells 1 - 3 is equipped with a sideslope riser to permit sampling and removal of leachate
during the operational and post closure periods. Cells 4 through 8 have two primary sideslope risers to
provide additional access for pumps and other equipment. In addition, Cells 5 through 8 include a smaller
diameter monitoring conduit. This pipe is located along the spine of the herringbone pattern of the base
grades, runs through the primary leachate collection sump, and up the sideslope (adjacent to the primary
sump risers) to daylight at the landfill perimeter. The pipe is perforated along the floor of each cell, and
solid on the sideslope. 40 CFR 264.301 (c)(3)(ii) a geosynthetic drainage composite within the LDS with
a transmissivity equal to or greater than 3 X 10"5 meters squared per second (m2/sec). The secondary
leachate collection layer was also designed using a geonet/geotextile drainage composite meeting this
requirement. Per 40 CFR 264.301(c)(3)(iii) the liner material is chemically resistant to the waste
managed in the landfill and leachate expected to be generated and of sufficient strength and thickness to
prevent collapse under the pressures exerted by overlying wases, waste cover materials and equipment
used at the landfill.
The secondary leachate collection sumps are also equipped with a single riser for each cell located on the
sideslopes. The secondary risers are sandwiched between the upper and lower liners to eliminate
penetration of the geomembrane liners.
Sampling equipment used for the sampling of the leachate sumps is in accordance with appropriate
section of Attachment #1 - WAP.
Leachate is removed from the primary leachate removal sump when leachate levels are near or above the
action level. The leachate is pumped through a conveyance system over the lined area or into a vacuum
truck and used for dust control within the landfill. Leachate may be transported to WWTP-1 or WWTP-5
on-site wastewater treatment plant for treatment prior to placement in any of the on-site surface
impoundments for solar evaporation.
Responses required to address liquids which accumulate in the secondary and tertiary leachate collection
sumps are presented in the Landfill Response Action Plans (RAP) included in this document.
3.5 Base Grade Configuration
The floors of Cells 1 through 3 are planar and slope between 1 and 1.5 percent, from north to south
toward a collection sump located along the southern edge of each cell. The base of Cell 4 also slopes
from north to south but in a herringbone configuration with a sump at the toe of the southern sideslope.
The floor of Cells 5 through 8 is also configured in a herringbone pattern, but slopes at 1.5 percent
toward the spine of the herringbone. Cells 1 through 3 each have a shallow trench at the toe of the
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sideslope that directs liquids to that cell's sump. Due to the shape of and the herringbone configuration of
Cell 4-8, a toe trench is not necessary. The lined sideslopes of the landfill are at a 3:1 (H:V) slope.
Each cell is hydraulically separated from adjacent cells by an intercell berm. Each berm is three feet high
(minimum) and is incorporated into the liner and leachate collection system.
3.6 LCRS Geocomposite Flow Capacity
The geocomposite layer of the primary leachate collection system is designed to remain free draining
under the maximum expected impingement rate. A design method was utilized that has been developed
and refined over a number of years by several organizations within the geosynthetics industry and is the
industry standard for evaluating flow performance of geonets and geocomposites. The method accounts
for various mechanisms that can impact the transmissivity of a drainage layer over time. These include
clogging due to biological and chemical activity, clogging due to sediment, and creep of the HDPE ribs
of the geonet material. Conservative safety factors were used to account for all these mechanisms in the
analysis.
Calculations were performed for several scenarios using the maximum impingement rates from the HELP
modeling performed as part of the 1998 permitting. Critical flow lines were analyzed for each cell to
ensure that the geocomposite had sufficient flow capacity under the design impingement rate. The
calculations document that a geocomposite in Cells 1 through 4 will perform satisfactorily under the
loading imposed by the design waste thickness. A minimum required transmissivity was calculated for
Cells 5 through 8 which will be used when specifying material for the construction of those cells.
3.7 Sump Riser Pipe Structural Integrity
The structural integrity of the sump riser pipes were evaluated based on the design waste thickness. These
calculations were prepared for the original L-14 and 2022 design. The expansion of the landfill did not
increase the design waste thickness above the sump riser pipes, so no design modifications were required
for Cells 1-3. For Cells 4 through 8, the diameter of the sump riser pipes was increased from 18 to 24
inches. The updated calculations for Cells 4 through 8 demonstrate that the 24-inch diameter riser pipes
satisfy the established factor of safety for structural integrity.
3.8 Slope Stability
Slope stability a were performed in the original design and in the 2022 expansion to document that the
design grades of Landfill L-14 meet the regulatory requirements. Analyses were performed to model
conditions during construction and operation of the landfill as well as after closure of the landfill. The
analyses demonstrate that landfill slopes will be stable within the target factor of safety under the design
conditions over the life of the landfill and throughout the post-closure period.
3.9 Slope Stability Evaluation Methods
The stability of the landfill slopes was evaluated using the limit equilibrium method. In general terms,
this method is based on balancing translational and rotational forces of a waste mass sliding along a slip
surface. Forces (moments or stresses) resisting instability (resisting forces) of the mass are balanced
against those that cause instability (disturbing or driving forces).
Based on industry experience and an analysis of the shear strength of the various materials, it can safely
be assumed that the weakest and therefore critical material in the landfill stability is one of the interfaces
within the base liner system. The soils beneath the liner system and the waste are stronger than either
liner system interface with those materials. Therefore, the calculations were performed to determine the
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lowest allowable interface strength of the liner system that meets the established minimum factors of
safety.
3.10 Interface Friction Angles and Shear Strength
Shear strength data for the base liner system of Cells 1 through 3 was taken from testing performed as
part of the detailed design of Cell 3 in 2010. Since the liner system of Cells 1 through 4 are identical and
similar materials were used throughout, this is representative.
For Cells 5 through 8, shear strength data from testing performed on the lining system in 2013 was used
in the stability analyses. The lining system included the incorporation of GCL as a replacement for the
soil/bentonite layer. Representative geosynthetic and soil materials were used in the testing. Cell-specific
testing can be performed prior to the construction of Cells 4 through 8 to confirm that the strength
envelope of the proposed materials meets the requirements established by this analysis.
3.11 Static and Seismic Analysis Parameters
Analyses were performed for static and seismic conditions. Seismic conditions were assessed using a
pseudo-static approach where a horizontal force equal to the peak design earthquake acceleration is
applied to the waste mass.
Target factor of safety for static interim conditions was a minimum of 1.25, static final waste mass of 1.5
and seismic interim and final waste mass of 1.0.
A peak ground acceleration of 0.22g was chosen for the 2022 Expansion seismic analysis. For the site
location, this is the value that has a 2 percent chance of being exceeded in 50 years or a 10% chance of
being exceeded in 250 years. The value was obtained from USGS Uniform Hazard Response Spectrum.
Conservatively, the peak ground acceleration was increased by a coefficient of 1.2 to a value of 0.22 to
take in account the stiffness of soil overlying bedrock.
3.12 Stability of Intermediate Grade Slopes
Conservative configurations of intermediate waste slopes were analyzed for the current landfill
configuration as well as anticipated future filling patterns. The most critical section for the intermediate
filling conditions was assessed to be a north-south section through Cells 4 through 8. It represents the
point at which Cells 1 through 4 are filled to their interim capacity and Cell 5 is excavated but has no
waste in place. Note that the section analyzed is the most critical, therefore, it is used in the analysis.
The section was analyzed under both static and seismic conditions using conservative assumptions for
waste strength, liner and final cover system strength, and earthquake forces. The analyses indicate that
the stability of the proposed intermediate filling plans meet or exceed the target minimum factors of
safety.
3.13 Stability of Final Waste Mass and Cover
The stability of the landfill at final grade was also reevaluated for the 2022 expansion. The critical section
is a north-south line that passes through the thickest parts of the landfill and has the longest and steepest
slopes with the smallest buttresses. The east and west section was also analyzed. Both sections were
analyzed under both static and seismic conditions using conservative assumptions for waste strength,
liner and final cover system strength, and earthquake forces. The analyses indicate that the stability of the
proposed final grading plan meet or exceed the target minimum factors of safety.
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3.14 Landfill L-14 Liner Specifications and Installation
The landfill liner systems for the existing Landfill L-14 Cells 1 through 4 have been installed in
accordance with approved construction drawings and technical specifications prepared for each cell prior
to construction. Quality assurance is conducted during construction as described in Attachment #16 -
Construction Quality Assurance Plan. Construction Quality Assurance (CQ A) reports have been
previously submitted to the DEQ certifying that the currently active landfills were constructed in
accordance with the approved technical specifications at the time of construction.
Construction of Landfill L-14 cells 5 through 8 will be completed in accordance with construction plans
in Attachment #18 - Landfill Design Drawings, and construction drawings and technical specifications
submitted to the Department. Construction inspection of L14 Cells 5 through 8 will be completed in
accordance with approved facility Construction Quality Assurance Plan Attachment #16 - Construction
Quality Assurance Plan.
3.15 Landfill L-14 Final Cover
Final cover systems that will be constructed in Landfill L-14 at closure are presented in the following
facility documents:
• Construction Quality Assurance (CQA) Manual For Landfill Closure Construction, Chemical Waste
Management Arlington Facility, Gilliam County, Oregon, Geo-Logic Associates Inc., January, 2022
• Alternative Final Cover Design Report, Landfills L-12, L-13 and L-14, Chemical Waste Management
Arlington Facility, Gilliam County, Oregon, Applied Soil Water Technologies, August 2014.
• Alternative Final Cover Design Modification Report, Landfills L-13 and L-14, Chemical Waste
Management Arlington Facility, Gilliam County, Oregon, Geo-Logic Associates, Inc., July 2020. The
final cover report specific for Landfill L-15 will be completed and submitted for approval prior to
constructing the final cover on the landfill.
2022 Expansion includes the Alternate Final Cover design. Landfill closure procedures and post-closure
maintenance of the landfill cover are described in Attachment #5 - Closure/Post-Closure Plans.
3.16 Landfill L-14 Final Cover Soil Erosion
The potential erosion of the upper soil layers of the final cover was evaluated to ensure that the cover will
continue to perform as intended over the design period. Software developed by the U.S Department of
Agriculture, Natural Resources Conservation Service was used to calculate a rate of soil erosion based on
factors such as slope length, steepness, soil types, vegetative coverage, and type of vegetation.
Two scenarios were evaluated: (1) unvegetated slopes, which represents a short-term condition just after
final cover construction is completed but before vegetation is established; and (2) vegetated slopes which
represent the long-term scenario once vegetation has become established. The predicted soil loss rates
calculated by the software for the short-term condition indicate that some form of erosion protection may
be required on the sideslopes (diversion berms, erosion blankets, etc.) until vegetation is established. For
the long-term scenario with established vegetation, predicted soil loss rates are substantially less than the
established maximum allowable rate, indicating that minimal erosion is expected and permanent erosion
control features such as diversion berms are not required.
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Attachment No. 14 - Landfill Design, Operations Plan and Response Action Plan
Table 14-2A SUMMARY OF LANDFILL L-14 DESIGN CELLS 1-3
Landfill
Units
Liner System Design
(top to bottom)
Sideslope Design
(top to bottom)
Leachate Collection Sumps
Final Cover Design
Approximate Landfill Design
Size/Capacity
L-14
(Cells 1-3)
Upper (Primary) Leachate
Collection System
Primary Protective Soil 18-
inches(min.)
Primary Geocomposite LCRS
Layer
Primary Liner 60-mil HDPE
Primary GCL
Lower (Secondary) Leachate
Collection System
• Secondary Geocomposite LCRS
Layer
• Secondary Liner 60-mil HPDE
• Secondary Clay Liner
• Subgrade
Upper (Primary) Leachate
Collection System
• Primary Protective Soil 12-inches
(min.)
• Primary Geocomposite LCRS
Layer
• Primary Liner 60-mil HPDE
Lower (Secondary) Liner System
Secondary Geocomposite LCRS
Layer
Secondary Liner 60-mil HPDE
Secondary Clay Liner Minimum
3-ft (mill.)
Subgrade
Primary Sump
• Primary Protective Soil 18-inches
(min.)
• One Primary Leachate Collection
Sump Riser 18" HDPE, SDR-
11. 3-ft Sump Aggregate with
Non-Woven Geotextile wrap.
• Primary Geocomposite LCRS
Layer
• Primary Liner 60-mil HDPE
• Primary GCL Two Layers in
Sump
Secondary Sump
• One Secondary Leachate
Collection Sump Riser 18"
HDPE, SDR-11. 2-ft Sump
Aggregate with Non-Woven
Geotextile wrap.
• Secondary Geocomposite
LCRS Layer
• Secondary Liner 60-mil HPDE
• Secondary GCL (sump only)
• Secondary Clay Liner (sump
only)
Tertiary Sump
• One Tertiary Leachate Collection
Sump Riser 18" HDPE, SDR-
11. 2-ft mill. Sump Aggregate
or General Soil with Non-
Woven Geotextile wrap.
• Tertiary Geocomposite LCRS
Layer
• Tertiary Liner 60-mil HPDE
• Tertiary GCL (sump only).
• Subgrade
Approved alternative final
cover design; 3 feet of onsite
soils over daily cover, see
Attachment #17 Landfill
Final Cover Design Plans
2013 expansion with Cells 1-5
Size: 1,260'x 1,280'x 104
Cells 1-5 Capacity: Approx. 6.3 x
10° cubic yards
2022 Expansion with Cells 1
through 8; Capacity approx. 10.5
x 10° Cubic Yards
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Table 14-2B SUMMARY OF LANDFILL L-14 DESIGN CELLS 4-8
Landfill
Units
Liner System Design
(top to bottom)
Sideslope Design
(top to bottom)
Leachate Collection Sumps
Final Cover Design
Approximate Design
Size/Capacity
L-14
Cells 4-8
Upper (Primary) Leachate
Collection System
Primary Protective Soil 18-
inches(min.)
Primary Geocomposite LCRS
Layer
Primary Liner 60-mil HDPE
Primary GCL (floor only)
Lower (Secondary) Leachate
Collection System
• Secondary Geocomposite LCRS
Layer
• Secondary Liner 60-mil HPDE
• Secondary GCL
• Subgrade
Upper (Primary) Leachate
Collection System
• Primary Protective Soil 12-inches
(min.)
• Primary Geocomposite LCRS
Layer
• Primary Liner 60-mil HPDE
Lower (Secondary) Liner System
Secondary Geocomposite LCRS
Layer
Secondary Liner 60-mil HPDE
Secondary GCL
Subgrade
Primary Sump
• Primary Protective Soil 18-inches
(mill.)
• Two Primary Leachate Collection
Sump Riser 24" HDPE, SDR-11.
One 8" HDPE, SDR-11 monitoring
conduit Cells 5-8. 3-ft (min.) Sump
Aggregate with Non-Woven
Geotextile wrap.
• Primary Geocomposite LCRS Layer
• Primary Liner 60-mil HDPE
• Primary GCL Two Layers in Sump
Secondary Sump
• Secondary Leachate Collection
Sump Riser 24" HDPE, SDR-11. 3-
ft Sump Aggregate with Non-
Woven Geotextile wrap.
• Secondary Geocomposite LCRS
Layer
• Secondary Liner 60-mil HPDE
• Secondary GCL Two Layers in
Sump
Tertiary Sump
• One Tertiary Leachate Collection
Sump Riser 24" HDPE, SDR-11. 3-
ft mill. Sump Aggregate or General
Soil with Non-Woven Geotextile
wrap.
• Tertiary Geocomposite LCRS
Layer
• Tertiary Liner 60-mil HPDE
• Tertiary GCL (sump only)
• Subgrade
Approved alternative final
cover design; 3 feet of
onsite soils over daily cover,
see Attachment #17 Landfill
Final Cover Design Plans
2013 expansion with Cells 1-5 Size:
1,260'x 1,280'x 104
Cells 1-5 Capacity: Approx. 6.3 x
10° cubic yards
2022 Expansion with Cells 1
through 8; Capacity approx. 10.1 x
10° Cubic Yards
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4 Landfill L-15 Design
Landfill L-15 is designed in compliance with 40 CFR 264.301 and is a multi-phase unit divided into 4
hydraulically separated cells which may be constructed in phases based on operational need. The
permitted planar area of L-15 is 202 acres. The design of Landfill L-15 has a total design capacity of
approximately (80.4 xlO6 cubic yards).
The overall design concept for L-15 is consistent with currently approved Landfill L-14 Cells 4 through 8
at the Arlington Facility, this design meets or exceeds the minimum technology requirements for landfill
units. General design details for the currently permitted Landfill L-15 are summarized in Table 14-3.
Landfill L-15 is designed to meet or exceed 40 CFR 264.301 standards and will accept all hazardous and
non-hazardous wastes not restricted by Attachment #1 - WAP. These waste are typically generated from
but not limited to clean-up, remediation, and industrial waste sources contaminated with PFAS,
Pesticides, PCB's. Solvents, PAH's, Dioxins and Furans, heavy metals, and other constituents.
4.1 Landfill Configuration
Landfill L-15 is divided into four cells which are further divided into modules for development and
disposal purposes. Three inter-cell berms in the north-south direction divide the base area into the four
cells, modules are developed based on operational need. The primary and secondary leachate collection
and detection systems have been designed to be hydraulically independent.
The landfill base grades (i.e., top of protective layer) vary between 950 feet MSL and 986 feet MSL
which vary from approximately 70 feet to 150 feet below the existing grade. The maximum top of
landfill elevation is approximately 1,452 feet. The maximum depth of waste in the landfill is
approximately 490 feet.
4.2 Foundation Settlement and Bearing Capacity
CWMNW has reviewed the subsurface geology of the facility and the soils underlying landfill L-14 and
the Columbia Ridge landfill along with the limited well boring logs in the area and has found that soils
beneath L-15 are reasonably believed to be consistent across the area and generally have relatively high
strength and low compressibility characteristics. Since the landfill's foundation grades are well above
(>100 feet) the groundwater table, most of the anticipated settlement is elastic and will occur as the loads
are applied. Foundation soil characteristics will be provided in the Engineering Design Report package
along with the construction documents prior to construction and waste placement. Additional
geotechnical soil borings will be part of the groundwater site characterization development work prior to
construction and waste placement
4.3 Description of Landfill Lining System
The lining system components of Landfill L-15 have been designed in accordance with 40 CFR Part 264
Subpart N 264.301. Landfill L-15 has been designed with four cells which have a total capacity of
approximately 80.4 xlO6 cubic yards. The design of L-15 meets or exceeds the requirements detailed in
40 CFR Part 264.301, OAR 340-104, and guidelines for landfill construction as described in Minimum
Technology Guidance on Double Liner Systems for Landfill and Surface Impoundment Design,
Construction and Operation - EPA 530SW85015, and is based on the currently approved liner and final
cover system designs for Landfill L-14 cells 4 through 8.
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4.4 Landfill L-15 Liner and Leachate Collection System Design
The liner system for Landfill L-15 was designed in accordance with applicable regulations (e.g., 40 CFR
264 Subpart N) and EPA guidance for hazardous waste landfills. Each cell within L-15 is designed with a
primary liner system draining to a leachate collection sump. The primary liner system is underlain by a
secondary leachate collection and removal system draining to a secondary sump. Both the primary and
secondary leachate collection sump system are underlain by a tertiary sump. The tertiary sump acts as an
"engineered vadose zone" in the area of the landfill with the highest likelihood of a potential release (i.e.,
leachate collection sumps). The tertiary sumps are designed to provide the landfill unit with the earliest
possible indication of a release that can be effectively monitored.
Within each cell, leachate from the primary and secondary collection systems is channeled toward
primary and secondary leachate collection sumps, respectively, located on the landfill bottom. Each
primary sump has two primary sideslope risers to provide redundant access for pumps and other
equipment and a smaller diameter monitoring conduit. The leachate riser pipes, and the monitoring
conduit is located along the spine of the herringbone pattern of the base grades, runs through the primary
leachate collection sump, and up the sideslope (adjacent to the primary sump risers) to daylight at the
landfill perimeter. The riser pipes are perforated along the floor of each cell and in the sump, and non-
perforated on the sideslope. 40 CFR 264.301 (c)(3)(ii) a geosynthetic drainage composite within the LDS
with a transmissivity equal to or greater than 3 X lOto the minus 5 meters squared per second (m2/sec).
The secondary leachate collection layer was designed using a geonet/geotextile drainage composite
meeting this requirement. Per 40 CFR 264.301 (c)(3)(iii) the liner material is chemically resistant to the
waste managed in the landfill and leachate expected to be generated and of sufficient strength and
thickness to prevent collapse under the pressures exerted by overlying wases, waste cover materials and
equipment used at the landfill.
The secondary leachate collection sumps are also equipped with a single riser for each cell located on the
sideslopes. The secondary risers are sandwiched between the upper and lower liners to eliminate
penetration of the geomembrane liners.
Leachate is removed from the primary leachate removal sump by a dedicated pump when leachate levels
are near or above the action level. The leachate is either pumped to the on-site evaporation ponds or
delivered to the on-site wastewater treatment plant for treatment depending on the concentrations of the
contaminants in the leachate.
Responses required to address liquids which accumulate in the secondary leachate collection sumps are
presented in the leachate detection discussion below. Responses required to address liquids which
accumulate in the tertiary sump are also presented in the RAP.
The geocomposite layer of the primary leachate collection system is designed to remain free draining
under the maximum expected impingement rate. The design method for evaluating flow performance of
geonets and geocomposites, equivalent to industry standard that have been developed and refined over a
number of years by several organizations within the geosynthetics industry and is the industry standard.
This standard method accounts for various mechanisms that can impact the transmissivity of a drainage
layer over time. These include clogging due to biological and chemical activity, clogging due to
sediment, and creep of the HDPE ribs of the geonet material. Conservative safety factors were used to
account for all these mechanisms in the analysis. Calculations are provided in the Engineering Design
Report package along with the construction documents prior to construction and waste placement.
4.5 Geosynthetic Clay Liner
The geosynthetic clay liner system in cells 1- 4 of L-15 meets the design requirements of 40 CFR 264
Subpart N including the requirements of 264.301(c) and utilize a geosynthetic clay liner (GCL)
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specifically Resistex® or equivalent, in both the upper composite (primary) and lower (secondary) layers
as a replacement for the compacted soil/bentonite layer due to the better performance and the lower
permeability of the GCL versus clay/bentonite liner systems.
4.6 Base Grade Configuration
The floors of Cells 1 through 4 are planar and slope between 1 and 1.5 percent, from north to south
toward a collection sump located along the southern edge of each cell. The lined sideslopes of the landfill
are at a 3:1 (H: V) slope.
4.7 LCRS Geocomposite Flow Capacity
The geocomposite layer of the primary leachate collection system was designed to remain free draining
under the maximum expected impingement rate. A design method was utilized that has been developed
and refined over a number of years by several organizations within the geosynthetics industry and is the
industry standard for evaluating flow performance of geonets and geocomposites. The method accounts
for various mechanisms that can impact the transmissivity of a drainage layer over time. These include
clogging due to biological and chemical activity, clogging due to sediment, and creep of the HDPE ribs
of the geonet material. Conservative safety factors were used to account for all these mechanisms in the
analysis.
Calculations are performed on several scenarios using the maximum impingement rates from HELP
modeling. Critical flow lines are analyzed for each cell to ensure that the geocomposite has sufficient
flow capacity under the design impingement rate. A minimum required transmissivity is also calculated
that is used when specifying material for the construction of those cells. Calculations will be provided in
the Engineering Design Report package along with the construction documents prior to construction and
waste placement.
4.8 Sump Riser Pipe Structural Integrity
The structural integrity of the sump riser pipes is evaluated based on the design waste thickness, similar
to the calculations prepared for the original L-14 design. Calculations will be provided in the Engineering
Design Report package along with the construction documents prior to construction and waste placement.
4.9 Slope Stability - Intermediate Slopes
Slope stability and foundation analyses is performed to document that the design grades of Landfill L-15
meet the regulatory requirements. Analyses is performed to model conditions during construction and
operation of the landfill as well as after closure of the landfill. The analyses will demonstrate that landfill
slopes are stable within the target factor of safety under the design conditions over the life of the landfill
and throughout the post-closure period. Calculations will be provided in the Engineering Design Report
package along with the construction documents prior to construction and waste placement.
4.10 Interface Friction Angles and Shear Strength
The lining system will include the incorporation of GCL as approved in cells 4 through 8 in L-14.
Interface friction angles and shear strength calculations are provided in the Engineering Design Report
package along with the construction documents prior to construction and waste placement.
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4.11 Static and Seismic Analysis Parameters
Analyses is performed for static and seismic conditions. Seismic conditions are assessed using a pseudo-
static approach where a horizontal force equal to the peak design earthquake acceleration is applied to the
waste mass.
A peak ground acceleration of 0.22g is utilized consistent with Landfill L-14 calculations for the seismic
analysis. For the site location, this is the value that has a 2 percent chance of being exceeded in 50 years
or a 10% chance of being exceeded in 250 years. The value was obtained from USGS Uniform Hazard
Response Spectrum. Conservatively, the peak ground acceleration was increased by a coefficient of 1.2
to a value of 0.22 to take in account the stiffness of soil overlying bedrock.
4.12 Landfill L-15 Liner Specifications and Installation
Cells 1 through 4 are constructed and inspected during construction in accordance with construction
drawings, technical specifications, and quality assurance manuals prepared and approved for each cell.
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Table 14-3 SUMMARY OF LANDFILL L-15 DESIGN
Landfill
Units
Liner System Design
(top to bottom)
Sideslope Design
(top to bottom)
Leachate Collection Sumps 1 5
Final Cover Design
Approximate Landfill
Design Capacity/Size
L-15
Upper (Primary) Leachate
Upper (Primary) Leachate
Primary Sump
Approved alternative
Size: 202 Planar Acers
Cells 1-4
Collection System
Collection System
• Primary Protective Soil
final cover design; 3 feet
Approx. 80.4 x 10°
• Primary Protective Soil 18-
• Primary Protective Soil 12-
• Two Primary Leachate Collection
of onsite soils over daily
cubic yards)
inches(min.)
inches (min.)
Sump Aggregate with Non-Woven
cover, see Attachment
• Primary Geocomposite
• Primary Geocomposite LCRS
Geotextile wrap.
#17 Landfill Final Cover
LCRS Layer
Layer
• Primary Geocomposite LCRS Layer
Design Plans
• Primary Liner 60-mil
• Primary Liner 60-mil HPDE
• Primary Liner 60-mil HDPE
hdpe'
• Primary GCL Two Layers in
• Primary GCL (floor only)
Lower (Secondary) Liner System
Sump.
• Secondary Geocomposite
Lower (Secondary) Leachate
LCRS Layer
Secondary Sump
Collection System
• Secondary Liner 60-mil
• Secondary Leachate Collection
• Secondary Geocomposite
HPDE
Sump Riser 24" HDPE, SDR-11.
LCRS Layer
• Secondary GCL
3-ft Sump Aggregate with Non-
• Secondary Liner 60-mil
• Subgrade
Woven Geotextile wrap.
HPDE
• Secondary Geocomposite LCRS
• Secondary GCL
Layer
• Subgrade
• Secondary Liner 60-mil HPDE
• Secondary GCL Two Layers in
Sump
Tertiary Sump
• One Tertiary Leachate Collection
Sump Riser 24" HDPE, SDR-11.
3-ft min. Sump Aggregate or
General Soil with Non-Woven
Geotextile wrap.
• Tertiary Geocomposite LCRS
Layer
• Tertiary Liner 60-mil HPDE
• Tertiary GCL (sump only).
• Subgrade
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5 LANDFILL OPERATIONS
5.1 Waste Acceptance Procedures
Containerized waste received at the Arlington Facility is screened in accordance with the
facility's Attachment #1 - Waste Analysis Plan including Appendix A of the WAP. If the waste is
found to be acceptable the load is sent directly to the landfill, unless weather or operating
conditions dictate otherwise (in which case the load is delivered to an appropriate storage area,
provided the wastes are compatible). Containers are delivered to the landfill for disposal via both
offsite and onsite trucks and placed in rows immediately adjacent to each other.
Containers of bulk solid waste material (i.e., wastes having no free liquids) must be at least 90
percent full prior to placement in the landfill. CWMNW personnel have the option of rejecting
the load (see Attachment #1- Waste Analysis Plan) or filling the containers to the maximum
extent possible prior to disposal in the landfill.
The only containers with free liquids that are landfilled are very small containers (i.e., ampules),
containers of hazardous waste in overpacked drums (i.e., lab packs), and containers designed to
hold free liquids for use other than storage (i.e., batteries). Each lab pack (as defined by U.S.
Department of Transportation [DOT] hazardous materials regulations [40 CFR Parts 173, 178,
and 179]) must be certified by the generator or packer (through the manifest system and prior
approval and instructions from CWMNW) that:
• Hazardous wastes are packaged in non-leaking inside containers.
• Inside containers are of a sufficient design and constructed of a material that will not
dangerously react, decompose, or ignite with the contained waste.
• Inside containers are sealed tightly and securely.
• The solidification material within the lab pack is compatible with the contained wastes
and will not react, ignite, or decompose on contact with the wastes.
• Incompatible wastes are not placed in the same lab pack; and
• Containers of reactive wastes other than cyanide or sulfide bearing wastes are not placed
in the lab packs unless they have been previously treated or rendered non-reactive.
Liquids that are contained in lab packs, small containers, ampules, or batteries may be disposed
without stabilization and related testing and verification procedures, provided other restrictions
specified in the RCRA Permit or by other laws or regulations, do not prohibit the land disposal of
such wastes.
Hazardous Wastes with free liquids are solidified with the following non-biodegradable sorbents:
(i) Inorganic minerals, other inorganic materials, and elemental carbon (e.g.,
aluminosilicates, clays, smectites, Fuller's earth, bentonite, calcium bentonite,
montmorillonite, calcined montmorillonite, kaolinite, micas (illite), vermiculites,
zeolites; calcium carbonate (organic free limestone); oxides/hydroxides, alumina, lime,
silica (sand), diatomaceous earth; perlite (volcanic glass); expanded volcanic rock;
volcanic ash; cement kiln dust; fly ash; rice hull ash; activated charcoal/activated carbon);
or
(ii) High molecular weight synthetic polymers (e.g., polyethylene, high density
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polyethylene (HDPE), polypropylene, polystyrene, polyurethane, polyacrylate,
polynorborene, polyisobutylene, ground synthetic rubber, cross-linked allylstyrene and
tertiary butyl co polymers). This does not include polymers derived from biological
material or polymers specifically designed to be degradable; or
(iii) Mixtures of these nonbiodegradable materials.
The Arlington Facility does not dispose of any waste which is generated as a liquid and
subsequently stabilized by the generator (or another off-site treatment facility) unless CWMNW
has conducted testing (in accordance with Attachment #1- Waste Analysis Plan) to ensure that
the waste has been properly stabilized.
The Arlington Facility does not dispose of any waste which is restricted from land disposal under
40 CFR Part 268 unless the applicable treatment standards as specified in 40 CFR Part 268 have
been achieved or an approved treatment variance has been received. In addition, as new wastes
are specified for land disposal restriction under 40 CFR Part 268, CWMNW immediately
discontinue disposing of such wastes upon the effective date of the 40 CFR Part 268 regulation,
unless the treatment standard as specified in 40 CFR Part 268 has been achieved or an approved
treatment variance has been received. CWMNW will accept any Corrective Action Management
Units (CAMU)-eligible waste which is in compliance with the requirements contained in 40 CFR
264.555. Prior to placement of CAMU-eligible wastes by the Arlington Facility, the Oregon
Department of Environmental Quality must not object to its placement.
CWMNW maintains the following items in the operating record required under § 264.73:
(a) On a map, the exact location and dimensions, including depth, of each cell with
respect to permanently surveyed benchmarks in compliance with Attachment #16 -
Construction Quality Assurance Plan; and
(b) The contents of each cell and the approximate location of each hazardous waste type
within each cell.
5.2 Fill Sequencing
Wastes are placed in the landfill in a series of lifts, with each lift consisting of either a single or
double layer of waste material. If containers are part of the disposal material, they are placed in
the lower layer; the upper layer consists of bulk waste materials.
The filling sequence for the landfill units starts at the bottom of one cell of the landfill and moves
through a series of lifts toward the landfill top. The depth of the lifts will vary, depending on the
material being landfilled.
Access to the working face within each landfill is over temporary haul roads constructed on
covered, filled waste material. As filling progresses, a terraced embankment is developed, with
the highest point near the outer edges (sides) of the landfill. As each lift is completed, the
temporary haul road is extended to the next lift. When the capacity of this stage of the landfill is
reached, a new series of lifts are placed beginning with the lowest lift and filling upwards and
back against the previously filled lifts. The former haul road is filled as each new lift begins.
Landfill L-14 and L-15 are designed as a multi-phase landfill consisting of hydraulically
separated cells. This multi-phase design allows CWMNW flexibility with respect to operational
considerations, predicted landfill disposal capacity requirements and closure. Based on current
operational and infrastructure needs, CWMNW intends to construct the L-14 Cell 5 next. This
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likely will be followed by development of Cells 6 through 8. Landfill L-15 cell modules will be
constructed in phases beginning with Cell 1A on the South end of the landfill. For all landfill fill
progressions, if operational and infrastructure needs change, other fill sequences may be
implemented at CWMNW's discretion.
5.3 Control of Run-on and Run-off
The run-on prevention system at the CWMNW is typical for an arid climate, where the annual
average rainfall is less than 10 inches and a high intensity rainfall event such as the 25-year, 24-
hour storm would produce only 1.8 inches of rain. Details of the run-on and run-off control
features are presented in the facility's Surface Water Management Plan which has been removed
from the Part B permit. The surface water plan is updated prior to additional features and units
being constructed
A series of ditches constructed around the perimeter of the landfills route run-on to one of six
onsite surface water basins (see Figure 1-1 Facility Layout Map contained in the Part B Permit),
where the water will be evaporated. The ditches are typically triangular, unlined earthen channels
with 3H:1V sideslopes. The ditches are sized to convey the 25year, 24hour storm event and are
designed with freeboard that will allow them to carry at least two times the design flow.
Calculations performed as part of the surface water analysis indicate that the freeboard will allow
the ditches to handle the lOOyear, 24-hour storm event without overtopping.
• Surface Water Management Plan, Chemical Waste Management of the Northwest, Inc,
Arlington, Oregon, Golder Associates, Inc., October 2019
Surface water management plan was designed to achieve zero off-site discharge of run-off
Ditching is either 3:1 or 2:1 Storm water ponds are designed to contain the 100-year, 7-Day Event
plus an additional 10%. Southern Peripheral Conveyance Ditches are designed to convey the
100-year, 24-hour Event. Interior conveyance ditches are designed to convey 25-year, 24-hour
event.
The berms and run-on ditches are inspected regularly, and after significant rainfall events in
accordance with the facility's Attachment #3 - Inspection Plan. Signs of deterioration, clogging,
or failure are reported and appropriate repair actions, involving standard soil placement and
compaction techniques, are taken to affect the necessary repairs.
In order to prevent discharge of run-off from the landfills surface onto the adjacent ground
during each phase of operation, the following plan is implemented. For the period of time during
which waste elevations are below surrounding grade, precipitation is contained within each
landfill by the lined sideslopes. During this phase of operation, no run-off can discharge onto the
adjacent ground. Any precipitation falling inside the perimeter of the active cells of the landfill is
directed to temporary, geomembrane-lined surface water basins within each landfill footprint.
The temporary detention basins are located in each cell between the toe of the waste slope and
the cell divider berms, or immediately adjacent to each cell. Each area is lined with a
geomembrane to prevent infiltration into the waste. The basins are sized to contain run-off from
a 25-year, 24-hour storm.
Liquid collected in the temporary basins is removed by vacuum trucks or portable pumps
maintained and operated by site personnel and routed to the facility's surface waste
impoundments. Precipitation run-off is tested for toxicity in accordance with the procedures
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established in the facility's Attachment #1- Waste Analysis Plan and the exclusion in 40 CFR §
261.3(c)(2)(i), and then treated or discharged directly as appropriate.
Once waste elevations within the landfill are above the adjacent perimeter grade, and prior to
constructing final cover, precipitation falling on the outer slopes of the landfill is directed to a
channel formed by the toe of the slope and the liner, which directs flow to a basin. A berm is
maintained around the perimeter of the landfill to prevent overflow.
Precipitation that falls on the landfill areas with final cover in place or into cells that do not
contain waste is considered uncontaminated and is discharged without testing. After final cover
is in place, no contaminated run-off is allowed to flow onto the adjacent covered areas. No
contaminated vehicles are allowed to operate on the final cover, and incident precipitation is
directed away from these areas.
Run-off from active slope areas could flow downslope over previously covered areas during
placement of subsequent lifts of waste. To prevent this from occurring, a channel is maintained
along the toe of the exposed waste slope, adjacent to the cover of the previous lift. All run-off
from the active slope areas is collected in the channel, which has the capacity to contain a 25-
year, 24-hour storm. To minimize this occurrence, cover is placed over the active areas of the
slope as soon as practical.
5.4 Construction Inspection of Landfills
During construction of new landfills, an independent Construction Quality Assurance firm is
onsite to monitor and inspect material quality and installation of the materials for compliance
with approved construction drawings and technical specifications.
Detailed construction quality assurance procedures are contained in the facility's Attachment #16
- Construction Quality Assurance Plan and project specific construction quality assurance
manuals. Upon completion of landfill construction activities, a CQA report is prepared by the
independent engineering firm certifying that the landfill was constructed in accordance with the
approved construction drawings and technical specifications.
Inspections are conducted during installation of all components of the landfill liners, leachate
collection and removal systems, and protective soil and geosynthetic layers. Geomembrane liners
and covers are inspected during construction and/or installation for uniformity, damage, proper
seaming, and imperfections. Upon completion of installation, the geomembranes are inspected
and tested to verify seam integrity, and to verify there are no tears, punctures, or blisters. Other
routine landfill inspection procedures are described in the facility's Attachment #3 - Inspection
Plan.
5.5 Final Cover
Final cover systems that will be constructed after waste reaches final design grades in Landfill L-
14 and Landfill L-15 are presented in the following facility documents contained in Attachment
#17 -Landfill Final Cover Design Plan and Alternative Final Cover Design Report, Landfills I-
12, L-13, andL-14. Landfill closure procedures and post-closure maintenance of the landfill
cover are described in Attachment #5 - Closure/Post-Closure Plan. Final cover analysis of the
Alternative Final Cover design will be confirmed prior to constructing the final cover section on
Landfill L-15
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5.6 Ignitable and Reactive Wastes
Per the requirements of 264.312(a) Reactive wastes, as defined by RCRA, are not to be landfilled
prior to undergoing approved treatment. All bulk reactive wastes accepted by the facility for
storage, treatment, and/or disposal are processed to a level such that the resulting material(s) no
longer meet(s) the definition of a reactive waste under 40 CFR § 261.21 or 261.23. The resulting
material(s) are analyzed per the facility's Attachment #1- Waste Analysis Plan to verify that they
are not ignitable or reactive wastes prior to final disposal in the landfill. Per the requirements of
264.17 the waste is segregated and protected from sources of ignition or reaction and from heat
producing chemical reactions. Containerized solid ignitable wastes are landfilled in compliance
with 40 CFR § 264.312(b) including the application of a daily cover of non-combustible wastes
or inert soils. Ignitable liquids are shipped off site for disposal.
5.6.1 Incinerable Ignitable or Reactive Labpack Packaging
Incinerable lab packs according to the requirements in 40 CFR 268.42(c)(1) may be packaged in
fiber drums in place of metal outer containers. Such fiber drums must meet the DOT
specifications in 49 CFR 173.12 and be overpacked according to the requirements in paragraph
(b) of this section.
5.7 Incompatible Wastes
Wastes placed in the landfills are assigned to one of three categories (combustibles, TSCA PCBs,
and toxics) as a result of data gathered in accordance with the facility's Attachment #1- Waste
Analysis Plan. Wastes classified and are placed in the landfill using the compatibility provisions
of Attachment #1 - WAP to ensure that no incompatible wastes are grouped in the same
category.
The wastes are assigned to a specific area or cell of the landfill based on the classification. The
location of each waste load is recorded according to a three-dimensional grid system. Site
landfill disposal procedures specify that inert material or neutral wastes are used to segregate
cells and prevent the mixing of potentially incompatible wastes.
5.8 Control of Wind Dispersal of Wastes
Potential sources of fugitive dust emissions are: 1) earthmoving activities, such as excavation
and transport of material for daily cover, 2) unvegetated active areas of the landfill, such as
partially completed final covers or partially excavated trenches, 3) truck traffic on haul roads and
ramps, 4) waste unloading operations in the landfills, and 5) exposed waste surface in the
landfills.
Fugitive dust can be a problem at the Arlington Facility because of the semi-arid climate and
persistent winds. The wind is usually from the west at about 5 to 10 miles per hour (mph);
however, there are occasional gusts of 20 to 40 mph. Control of fugitive dust at the landfill is
accomplished by surface application of leachate within the lined areas of the landfill. Leachate is
pumped from the leachate detection sumps in an individual landfill unit either to a container
located within the lined footprint of the respective landfill or directly to the leachate distribution
system (sprinklers or drip hoses) for the respective landfill. No leachate leaves the landfill from
which it was pumped and the leachate, at all times, remains over the lined area that collected the
leachate. If not applied directly, the leachate is collected in a portable container that serves as a
reservoir for times dust control is required. The leachate is piped to drip systems and sprinkler
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systems for dust control as required. The drip and sprinkler systems are activated during periods
before and during dust generation weather. Leachate is not sprinkled on roadways to prevent
potential tracking from the landfill. Sprinkler systems are configured and operated so that no
leachate is allowed to drift out of the footprint of the respective landfill. Both sprinkler and drip
systems are operated to prevent landfill sideslope erosion. Leachate application rates are
controlled to prevent puddles, saturated soil conditions, excessive percolation, and runoff.
Leachate may also be pumped into a vacuum or tanker truck and sent to onsite wastewater
treatment units WWTP-1 orWWTP-5
The wastewater treatment unit operator oversees the application of leachate to the landfill
surface. The operator monitors and adjusts the system for appropriate leachate application rates,
appropriate spray sizing for wind drift conditions, piping and equipment leaks and ground
conditions.
Inspections of the landfill sprinkler and drip systems are conducted regularly. The inspector
visually checks the leachate application area for evidence of spray leaving the footprint of the
landfill, sideslope application, runoff, and puddling. Other dust control measures include:
• Application of clean water from a water truck onto the exposed surface within the
landfill, and
• Spraying of clean water from a fire truck hose onto dry bulk wastes during unloading
operations.
The water truck spray rate is equivalent to 0.012 inches of rain per year per application. Since the
average daily evaporation rate is 0.10 inches per day, it is apparent that clean water applied in
this manner will evaporate before it can percolate into the subsoils. Therefore, no groundwater
contamination is possible with this method of dust control.
The procedure of spraying water via a water hose is only used when unloading dry bulk wastes
such as baghouse dust. Assuming the waste has a moisture content of 5 percent, the amount of
water sprayed is not sufficient to even achieve the normal moisture content (10 percent) of the
soil used as clean cover in the landfills. Therefore, the additional water poses no threat to
groundwater.
Dust emissions from earthmoving activities and truck haul roads and ramps are minimized on
dry, windy days by periodic watering of areas being traveled and maintenance of a prepared
roadbed of aggregate material. Dust emissions from the active areas of the landfills are reduced
with the compaction of surface materials by heavy equipment traffic.
The offloading of container wastes in the landfills presents no dust emission problem. Most bulk
solid wastes, which are end dumped from trucks, are typically not dust generating wastes
because of their moisture content, large particles, and/or other physical properties. Stabilized
wastes are non-dust generating. However, the unloading of fine particle bulk solids, such as fly
ash or baghouse dust, is a potential dust emission problem. The current practice is to unload
these wastes in an area of the landfill protected from wind and as close to the final disposal area
as possible.
Once final cover is placed on each landfill, vegetation is established to control wind erosion of
final cover soils.
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5.9 Disposal of Dioxin-Containing Wastes
This management plan contains procedures for disposal of dioxin-containing wastes, (i.e., F020,
F021, F022, F023, F026, F027, and F028) which satisfy the unique requirements for managing
these wastes identified in 40 CFR § 264.317. The following items are addressed in this
management plan:
• Exposure control practices.
• Volumes, concentrations of dioxin-containing wastes, and potential to migrate; and
• Disposal procedures for land disposal.
5.9.1 Exposure Control Practices
Existing management standards under 40 CFR § 264 Subpart N are adequate to prevent the
dispersion of dioxin-contaminated wastes by wind dispersal. However, as an added precaution
these wastes are disposed in sealed impermeable enclosures to eliminate any potential for
dispersal of waste.
In instances where waste is transferred and/or stabilized into these enclosures for disposal,
personnel are provided adequate personnel protective equipment as is detailed in the facility's
exposure monitoring and prevention procedures.
5.9.2 Waste Characteristics
The volumes of dioxin-containing wastes to be managed for landfill varies depending upon the
process generating the waste. For example, dioxin-containing waste may be generated at large
cleanup sites and transported in lined bulk containers and then landfilled in sealed bulk
enclosures. In addition, these wastes may be generated and transported in small containers, such
as well investigation samples to be stabilized and landfilled in one or more impermeable
enclosures. The estimated volumes to be received for landfill are identified during the profile
approval process for each waste stream.
The concentration of dioxin or furans in the wastes designated as F020, F021, F022, F023, F026,
F027, intended to be managed for disposal at the Arlington Facility, are below the regulated
levels identified in 40 CFR § 268.40 for wastewaters or non-wastewaters except for debris and
wastes intended to be managed for disposal as corrective action management unit (CAMU)-
eligible wastes.
Debris contaminated waste can be treated in accordance with the alternative treatment standard
in 40 CFR § 268.45 as discussed in Attachment #10 - Stabilization and Debris Treatment Plan.
All of these wastes accepted at the Arlington Facility for landfilling are disposed of in
impermeable enclosures that are capped and sealed to reduce the possibility of migration of these
wastes to groundwater, surface water, or air to protect human health and the environment.
5.9.3 Disposal Procedures
As identified above, all dioxin-containing wastes that are disposed of in a landfill will be
confined within an impermeable enclosure that is later capped and sealed. These enclosures may
be drums, prefabricated HDPE macroencapsulation boxes, super sacks (non-rigid containers
consisting of an inner layer of impermeable material (such as polyethylene) and an outer layer of
woven fabric capable of withstanding waste loading, transport, and disposal without tearing), or
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may be constructed of flexible membrane liner (FML) within the landfill. FMLs may be
polyethylene (HDPE, LLDPE) or other materials as appropriate. Macroencapsulation enclosures
constructed within the landfill will have FML above and below the waste to be encapsulated with
the overlying FML seamed to the underlying FML at the edges. All macroencapsulation FML
panels will be seamed using either fusion or extrusion methods.
CQA of macroencapsulation enclosures within the landfill will consist of non-destructive testing
of the seams in accordance with the Attachment #16 - Construction Quality Assurance Plan.
Other requirements of the Construction Quality Assurance Plan may be implemented at the CQA
Engineer's discretion.
Liquids accepted for disposal in a landfill are solidified prior to being landfilled. All containers,
in which these wastes have been removed and where the waste has contacted the container, are
triple rinsed to remove any hazardous residue. This rinsate is also stabilized and landfilled in
similar enclosures discussed above.
5.10 Special Requirements for Containers
Containers holding wastes subject to LDR requirements to be disposed in the landfill must be
either:
315(a); At least 90 percent full when placed in the landfill, or
315(b); Crushed, shredded, or similarly reduced in volume to the maximum practical
extent before burial in the landfill.
Small containers of hazardous waste in overpacked drums (lab packs) may be placed in
a landfill if the following requirements are met:
316(a); Hazardous waste must be packaged in non-leaking inside containers. The
inside containers must be of a design and constructed of a material that will not react
dangerously with, be decomposed by, or be ignited by the contained waste.
Inside containers must be tightly and securely sealed. The inside containers must be of
the size and type specified in the Department of Transportation (DOT) hazardous
materials regulations (49 CFR parts 173, 178, and 179), if those regulations specify a
particular inside container for the waste.
316(b); The inside containers must be overpacked in an open head DOT-specification
metal shipping container (49 CFR parts 178 and 179) of no more than 416-liter (110
gallon) capacity and surrounded by, at a minimum, a sufficient quantity of sorbent
material, determined to be nonbiodegradable in accordance with § 264.314(d), to
completely sorb all of the liquid contents of the inside containers. The metal
outer container must be full after it has been packed withinside containers and sorbent
material.
316(c;) The sorbent material used must not be capable of reacting dangerously with,
being decomposed by, or being ignited by the contents of the inside containers, in
accordance with § 264.17(b)
316(d); Incompatible wastes, as defined in § 260.10 of this chapter, must not be placed in
the same outside container
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Attachment No. 14 - Landfill Design, Operations Plan and Response Action Plan
6 ALR Engineering Calculations Specific to Landfill 14
6.1 Introduction
This Response Action Plan for Landfill L-14 (RAP) has been prepared for the Chemical Waste
Management of the Northwest, Inc. (CWMNW) Arlington Facility in accordance with Title 40,
Code of Federal Regulations (40 CFR) Part 264 Subpart N, Oregon Administrative Rule (OAR)
340-104, and United States Environmental Protection Agency (EPA) guidelines as outlined in
the double liner and leak detection rules for hazardous waste and disposal units (FR 57, January
29, 1992).
6.2 Purpose
The owners or operators of landfill units subject to RCRA Subtitle C (Title 40, Code of Federal
Regulations [40 CFR] Part 264.3018 or (d)) regulations must have an approved RAP before
receipt of waste at the landfill facility. 40 CFR Part 264.301, also adopted by the Oregon
Administrative Code (OAR 340-100-002), requires that the leachate collection system between
the liners and immediately above the bottom composite liner functions as a leachate collection
and removal system as well as a leak detection system (LDS).
A RAP describes the criteria used to address liquids which accumulate in the LDS. Details of
the definition of the "Action Leakage Rate" (ALR) which trigger a response on the part of the
owner/operator to address such accumulations are given in 40 CFR Part 264.302
6.3 Project Location
The CWMNW Arlington Facility is located in Gilliam County, Oregon.
Landfill L-14 has been designed with eight cells and will have a total capacity of approximately
10.1 xlO6 cubic yards. The design of L-14 meets or exceeds the requirements detailed in 40 CFR
Part 264.301, OAR 340-104, and guidelines for landfill construction as described in Minimum
Technology Guidance on Double Liner Systems for Landfill and Surface Impoundment Design,
Construction and Operation - EPA 530SW85014
6.4 Landfill Development
Landfill L-14 is divided into eight cells for development and operational purposes. Four inter-
cell berms in the north-south direction and three intercell berm in the east west direction divide
the base area into eight cells. The primary and secondary leachate collection and detection
systems have been designed to be hydraulically independent.
The landfill base grades (i.e., top of protective layer) vary between 934 feet MSL and 954 feet
MSL which vary from 35 feet above to 80 feet below the existing grade. The maximum top of
landfill elevation is approximately 1,150 feet. The maximum depth of waste in the landfill remains
and is approximately 205 feet.
6.5 Description of Landfill Lining System
The lining system components of Landfill L-14 have been designed in accordance with 40 CFR
Part 264 Subpart N 264.301.
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6.6 Base Liner System
The base liner system incorporates separate primary and secondary composite lining systems as
described in the L-14 liner and leachate collection system section above covering the liner
system in this document.
6.7 Leachate Leak Detection Systems
Each of the eight cells of Landfill L-14 are constructed with a primary leachate collection system
(LCS) and a secondary LDS and a Tertiary LDS as described in the L-14 liner and leachate
collection system section above.
Leachate flow between cells will be prevented by means of separation/ intercell berms built into
the base liner and leachate collection system. Separation of the cells will also be ensured in the
design of primary and secondary leachate collection systems. Both the primary and the
secondary leachate collection systems will have separate sumps where leachate collection,
pumping, and leak detection functions will be performed by means of sideslope risers. Complete
design analyses for Cells 1-4 LCS and the LDS are provided in the following document
previously submitted to the DEQ:
• Hydrogeologic Investigation and Engineering Design Report for Landfill L-14,
Arlington, Oregon, prepared for Chemical Waste Management of the Northwest, Inc., by
Rust Environment and Infrastructure Inc., dated February 1998.
The design analyses for Cell 5-8 LCS and LDS are provided in the following document recently
submitted to the DEQ.
• Engineering Design Report, LI4 Expansion Application, Chemical Waste Management of
the Northwest, Arlington, By Civil & Environmental Consultants Oregon, dated March
30, 2020.
6.8 Tertiary Sump Monitoring System
In addition to the primary and secondary lining systems, a tertiary detection monitoring system
has been designed directly beneath the LDS sump to monitor any releases into the environment.
Inside the LCS and LDS sumps, the leachate heads will reach measurable levels during landfill
operations, increasing the probability of liner leakage at these locations. The tertiary sump
monitoring system will be capable of detecting releases through the LDS sump as well as enable
sampling of the liquids collected for purposes of chemical analyses.
6.9 Description of the LDS
Subtitle C Part 264.301 (c)(3)(ii) allows the use of a geosynthetic drainage composite within the
LDS with a transmissivity equal to or greater than 3xl0"5 meters squared per second (m2/sec).
The secondary leachate collection layer was designed using a geonet/geotextile drainage
composite meeting this requirement.
6.10 Leachate Management
Fluids from landfill operations (leachate) are intercepted by the primary leachate collection and
removal system (LCRS) and collected in the sumps. The LDS is designed to effectively intercept
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liquids which may have migrated through the primary lining system. Fluids intercepted by the
LDS are also channeled to discrete sumps from which they are removed.
Fluids in the leachate systems are measured and recorded in compliance with Attachment #3 -
Inspection Plan
6.11 Potential Sources of Liquid in LDS
The potential sources of liquids that may be collected within the secondary leachate
detection/collection system can be broadly categorized as:
• construction-related,
• internal; and
• external sources.
The following sections addresses the potential sources of liquids inside the secondary leachate
detection/collection system; and (2) quantification of the liquids due to each potential source.
6.12 Construction-Related Liquids
Liquids generated during installation of the lining system components and before placement of the
waste inside each cell will be classified as construction-related liquids.
6.13 Internal Sources
Internal sources of liquids in the secondary detection/collection system sump typically consist of:
(1) compression of the soil component of the primary lining system; and (2) compression of the
secondary drainage layer material. Compression water from the primary lining system drains into
the secondary detection/collection system.
6.14 External Sources
External liquid sources inside the secondary detection/collection system consist of: (1) leakage
of leachate and initial water within the primary drainage layer through the primary
geomembrane/GCL system; (2) compression water from the secondary soil/bentonite liner
leaking into the secondary collection system through pinholes or larger-size construction related
flaws through the secondary geomembrane; and (3) seepage of groundwater and/or other liquids
through the secondary lining system if an inward gradient condition exist
6.15 Liquid Removal Capacity of the LDS
The minimum transmissivity of the geocomposite drainage layers for the LDS has been specified
as 3xl0"5 m2/sec in the final leak detection rule. This is interpreted as the long-term value which
is obtained after the application of several safety factors to account for potential long-term
performance degradation. Some of these factors are related to the long-term filtration
performance of the geotextile component and some to the long-term structural performance of
the geonet. As discussed in the Section below, these factors have been included in the analysis
of the long-term performance of the LDS.
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6.16 LDS Design Considerations
Table 14-4 summarizes the safety factors used in the evaluation of the long-term performance of
the geonet/geotextile drainage composite.
TABLE 14-4 Drainage Geocomposite Partial Reduction Factors
DRAINAGE GEOCOMPOSITE PARTIAL REDUCTION FACTORS
Performance Factor
Assigned Safety Factor
Out-of-plane creep (geonet)
2.0
Void intrusion (geonet)
1.2
Soil clogging (geotextile)
1.0
Chemical clogging (geotextile)
1.5
Biological clogging (geotextile)
1.2
Overall Reduction Factor (Product of all above factors)
4.32
The geotextile-related factors listed in Table 14-4 do not necessarily affect the long-term
transmissivity of the geonet. However, they force a decrease in the flow rate of liquid into the
geonet, and therefore, indirectly affect the flow capacity of the drainage geocomposite.
The initial transmissivity value for the drainage geocomposite selected for the LDS was obtained
from a transmissivity vs. normal stress chart published by the manufacturer. The maximum
design waste thickness was used to calculate the design normal stress. This published
transmissivity value, in part, includes the effect of the creep of the HDPE due to sustained
loading. An additional creep factor of safety of 2.0 was applied to the transmissivity value
obtained from the chart as shown in Table 14-4.
By combining the partial safety factors listed above, the long-term transmissivity of the drainage
geocomposite was obtained as 7.8xl0"4 m2/sec.
The flow capacity of the drainage layer is calculated as approximately 11,410 gpd. This accounts
for the configuration of the secondary collection trench along the southern edge of the Cells 1
through 4, and along the eastern edge of Cell 5 through 8, and northern edge of Cell 8 which
intercepts flow from portions of each cell. This value is nearly three orders of magnitude larger
than the estimated total flow of liquids into the LDS.
6.17 Leak Detection Time
Based on the capability of the composite secondary leachate detection/collection systems to
detect extremely small flows regardless of the time scale involved in the arrival of such flows to
the LDS sumps, the final leak detection rule requires that the LDS "be capable of detecting ...
leaks ... at the earliest practicable time."
In Landfill L-14, the slowest calculated leachate flow path is along the base of Cell 1. This path
consists of approximately 180 feet along the sideslope (3H:1V west-east direction), 480 feet along
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the base (1.0 & 1.5 percent slope in the north-south direction), and 90 feet along the south toe
collection trench (0.7 percent slope), for a total of 750 feet. The leak detection time for this path
is estimated to be approximately one day.
6.18 Action Leakage Rate
In its final leak detection rule, the EPA has adopted a single level of leak detection (ALR), which
is defined similarly to the Rapid and Large Leak (RLL) in the proposed rule (EPA, 1992). By its
definition, the ALR is the maximum design flow rate that the LDS can remove without the fluid
head on the bottom liner exceeding 1-foot. This description applies largely to the LDS's that
have a 12-inch thick granular drainage layer. For the geocomposite drainage layers, an
equivalent condition would be the full flow within the drainage layer that has the same
transmissivity as a 12-inch thick granular layer with a hydraulic conductivity not less than
1 x 10"2cm/sec.
Although based on the definition in the final leak detection rule (also 40 CFR Part 264.302), an
ALR value based on the flow rate of 11,410 gallons/day (see Section 6.16 of this RAP) is
considered to be unreasonably high as this flow rate greatly exceeds the average daily
precipitation at the facility. The primary motive behind the selection of the LDS drainage
geocomposite was to provide a drainage system that would have satisfactory structural
performance under the calculated overburden pressures. The drainage capacity of the selected
LDS drainage geocomposite exceeds, by a large margin, the calculated potential leakage rate into
the LDS.
Therefore, if the maximum drainage capacity of the LDS is adopted as the ALR, then during the
active life of a cell a leak condition that requires an action will likely never be triggered
regardless of the severity of the leakage. Also, the use of the flow capacity of the LDS drainage
geocomposite would result in a significant overdesign of the LDS collection sump and the
leachate pumping system.
Considering the large disparity between the cell-specific liquid leakage rates into the LDS (as
estimated in Section 3.3.6 of this RAP) and the flow capacity of the LDS drainage geocomposite,
a more reasonable flow rate is proposed for the ALR. The ALR flow rate is based on the
minimum required transmissivity of 3xl0"5 m2/sec in the drainage geocomposite of the LDS per
40 CFR Part 264.301.
Based on this transmissivity and the cell floor width and slope, the maximum drainage capacities
of the LDS and thus ALRs are as follows.
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TABLE 14-5 Cell Specific Action Leakage Rates (ALRs)
Cell
Cell Moor
Width (I'd
Minimum Cell
I'loor Slope
Co)
Max Drainage
Capacity (upd)
1
210
1.0
438
2
214
1.0
447
3
214
1.5
670
4
120*
1.5
376
5
120*
1.5
419
6
120
1.5
419
7
120
1.5
419
8
120
1.5
419
*Due to the herringbone configurations of Cells 4 through 8
the perimeter length of the sump was used instead of the cell
width.
It should be noted that, the ALR values in the table above include a safety factor which greatly
exceeds the recommended minimum value of two that is published in the final leak detection
rule. This safety factor was calculated by multiplying the partial safety factors listed in Table
14-4.
The use of these action leakage rates enables CWMNW to take action before large releases into
the LDS begin to occur.
6.19 Verification of LDS Sump Capacity
The LDS sump in each cell was designed to be approximately 3 feet deep. The depth of the toe
trench on both sides of the sump (in cells that include a toe trench) will be approximately 1-foot
at the point of connection to the sump. In order to prevent liquid accumulation inside the toe
trench, the liquid head within the LDS sump will not be allowed to exceed 2 feet. The liquid
capacity of the LDS sump has been calculated assuming that the hydraulic head will be limited to
a minimum of 1-foot and a maximum of 2 feet.
The existing LDS sumps for cells 1 to 3 have a capacity of approximately 474 gallons and 1,600
gallons for Cell 4. Based on the LDS sump design for Cells 5-8, the liquid capacity of the LDS
sumps increases to approximately 2,676 gallons. In this analysis, a porosity of 40 percent was
used for the granular material within the sump and the storage volume of the sump riser was
ignored. The LDS sump dimensions can be found in the facility's Landfill Design Drawings
maintained in the operating record.
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The ALR's of 419 to 670 gallons/day/sump are relatively small flow rates. A wide range of
commonly available pumps have the capacity to handle these flow rates. Based on the available
LDS sump volume, a pump will need to operate approximately once per day for a period of only
about 1.5 to 2.5 hours to stay ahead of the proposed ALR.
7 ALR Engineering Calculations Specific to Landfill 15
7.1 Introduction
This Response Action Plan for Landfill L-15 (RAP) has been prepared for the Chemical Waste
Management of the Northwest, Inc. (CWMNW) Arlington Facility in accordance with Title 40,
Code of Federal Regulations (40 CFR) Part 264 Subpart N, Oregon Administrative Rule (OAR)
340-104, and United States Environmental Protection Agency (EPA) guidelines as outlined in
the double liner and leak detection rules for hazardous waste and disposal units (FR 57, January
29, 1992).
7.2 Purpose
The owners or operators of landfill units subject to RCRA Subtitle C (Title 40, Code of Federal
Regulations 40 CFR Part 264.3018 or (d)) regulations must have an approved RAP before
receipt of waste at the landfill facility. 40 CFR Part 264.301, also adopted by the Oregon
Administrative Code (OAR 340-100-002), requires that the leachate collection system between
the liners and immediately above the bottom composite liner functions as a leachate collection
and removal system as well as a leak detection system (LDS).
A RAP describes the criteria used to address liquids which accumulate in the LDS. Details of
the definition of the "Action Leakage Rate" (ALR) which trigger a response on the part of the
owner/operator to address such accumulations are given in 40 CFR Part 264.302
7.3 Project Location
The CWMNW Arlington Facility is located in Gilliam County, Oregon.
Landfill L-15 has been designed with four cells and will have a total capacity of approximately
80.4 xlO6 cubic yards. The design of L-15 meets or exceeds the requirements detailed in 40 CFR
Part 264.301, OAR 340-104, and guidelines for landfill construction as described in Minimum
Technology Guidance on Double Liner Systems for Landfill and Surface Impoundment Design,
Construction and Operation - EPA 530SW85014
7.4 Landfill Development
Landfill L-15 is divided into four cells each with phased modules that are developed based on
operational need. Four inter-cell berms in the north-south direction divide the base area into four
cells. The primary and secondary leachate collection and detection systems have been designed
to be hydraulically independent.
The landfill base grades (i.e., top of protective layer) vary between 950 feet MSL and 986 feet
MSL which vary from approximately70 feet to 150 feet below the existing grade. The maximum
top of landfill elevation is approximately 1,452 feet. The maximum depth of waste in the landfill
is approximately 490 feet.
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7.5 Description of Landfill Lining System
The lining system components of Landfill L-15 have been designed in accordance with 40 CFR
Part 264 Subpart N 264.301.
7.6 Base Liner System
The base liner system incorporates separate primary and secondary composite lining systems as
described in the L-15 liner and leachate collection system section above covering the liner system
in this document.
7.7 Leachate Leak Detection Systems
Each of the four cells of Landfill L-15 are constructed with a primary leachate collection system
(LCS) and a secondary LDS as described in the L-15 liner and leachate collection system section
above covering the liner system in this document.
Leachate flow between cells will be prevented by means of separation/ intercell berms built into
the base liner and leachate collection system. Separation of the cells will also be ensured in the
design of primary and secondary leachate collection systems. Both the primary and the
secondary leachate collection systems will have separate sumps where leachate collection,
pumping, and leak detection functions will be performed by means of sideslope risers. Complete
design analyses for Cells 1-4 LCS and the LDS will be provided in the Engineering Design
Report package along with the construction documents.
7.8 Tertiary Sump Monitoring System
In addition to the primary and secondary lining systems, a tertiary detection monitoring system
has been designed directly beneath the LDS sump to monitor any releases into the environment.
Inside the LCS and LDS sumps, the leachate heads will reach measurable levels during landfill
operations, increasing the probability of liner leakage at these locations. The tertiary sump
monitoring system will be capable of detecting releases through the LDS sump as well as enable
sampling of the liquids collected for purposes of chemical analyses.
7.9 Description of the LDS
Subtitle C Part 264.301 (c)(3)(ii) allows the use of a geosynthetic drainage composite within the
LDS with a transmissivity equal to or greater than 3xl0"5 meters squared per second (m2/sec).
The secondary leachate collection layer was designed using a geonet/geotextile drainage
composite meeting this requirement.
7.10 Leachate Management
Fluids from landfill operations (leachate) are intercepted by the primary leachate collection and
removal system (LCRS) and collected in the sumps. The LDS is designed to effectively intercept
liquids which may have migrated through the primary lining system. Fluids intercepted by the
LDS are also channeled to discrete sumps from which they are removed.
Fluids in the leachate systems are measured and recorded in compliance with Attachment #3 -
Inspection Plan
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7.11 Potential Sources of Liquid in LDS
The potential sources of liquids that may be collected within the secondary leachate
detection/collection system can be broadly categorized as:
• construction-related,
• internal; and
• external sources.
The following sections addresses:
• the potential sources of liquids inside the secondary leachate detection/collection system;
and (2) quantification of the liquids due to each potential source.
7.12 Construction-Related Liquids
Liquids generated during installation of the lining system components and before placement of the
waste inside each cell will be classified as construction-related liquids.
7.13 External Sources
External liquid sources inside the secondary detection/collection system consist of: (1) leakage
of leachate and initial water within the primary drainage layer through the primary
geomembrane/GCL system; (2) compression water from the secondary soil/bentonite liner
leaking into the secondary collection system through pinholes or larger-size construction related
flaws through the secondary geomembrane; and (3) seepage of groundwater and/or other liquids
through the secondary lining system if an inward gradient condition exist
7.14 Liquid Removal Capacity of the LDS
The minimum transmissivity of the geocomposite drainage layers for the LDS has been specified
as 3xl0"5 m2/sec in the final leak detection rule. This is interpreted as the long-term value which
is obtained after the application of several safety factors to account for potential long-term
performance degradation. Some of these factors are related to the long-term filtration
performance of the geotextile component and some to the long-term structural performance of
the geonet. As discussed in the Section below, these factors have been included in the analysis
of the long-term performance of the LDS.
7.15 LDS Design Considerations
Table 14-6 summarizes the safety factors used in the evaluation of the long-term performance of
the geonet/geotextile drainage composite.
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TABLE 14-6 Drainage Geocomposite Partial Reduction Factors
DRAINAGE GEOCOMPOSITE PARTIAL REDUCTION FACTORS
Performance Factor
Assigned Safety Factor
Out-of-plane creep (geonet)
2.0
Void intrusion (geonet)
1.2
Soil clogging (geotextile)
1.0
Chemical clogging (geotextile)
1.5
Biological clogging (geotextile)
1.2
Overall Reduction Factor (Product of all above factors)
4.32
The geotextile-related factors listed in Table 14-6 do not necessarily affect the long-term
transmissivity of the geonet. However, they force a decrease in the flow rate of liquid into the
geonet, and therefore, indirectly affect the flow capacity of the drainage geocomposite.
The initial transmissivity value for the drainage geocomposite selected for the LDS was obtained
from a transmissivity vs. normal stress chart published by the manufacturer. The maximum
design waste thickness is used to calculate the design normal stress. This published
transmissivity value, in part, includes the effect of the creep of the HDPE due to sustained
loading. An additional creep factor of safety of 2.0 is applied to the transmissivity value
obtained from the chart as shown in Table 14-6. Transmissivity and flow capacity calculations
will be provided in the Engineering Design Report package along with the construction
documents prior to construction and waste placement.
7.16 Leak Detection Time
Based on the capability of the composite secondary leachate detection/collection systems to
detect extremely small flows regardless of the time scale involved in the arrival of such flows to
the LDS sumps, the final leak detection rule requires that the LDS "be capable of detecting ...
leaks ... at the earliest practicable time." Flow path and leak detection time calculations will be
provided in the Engineering Design Report package along with the construction documents prior
to construction and waste placement
7.17 Action Leakage Rate
In its final leak detection rule, the EPA has adopted a single level of leak detection (ALR), which
is defined similarly to the Rapid and Large Leak (RLL) in the proposed rule (EPA, 1992). By its
definition, the ALR is the maximum design flow rate that the LDS can remove without the fluid
head on the bottom liner exceeding 1-foot. This description applies largely to the LDS's that
have a 12-inch thick granular drainage layer. For the geocomposite drainage layers, an
equivalent condition would be the full flow within the drainage layer that has the same
transmissivity as a 12-inch thick granular layer with a hydraulic conductivity not less than
1 x 10"2cm/sec.
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Although based on the definition in the final leak detection rule (also 40 CFR Part 264.302), an
ALR value based on the flow rate of 11,410 gallons/day (see Section 6.16 of this RAP) is
considered to be unreasonably high as this flow rate greatly exceeds the average daily
precipitation at the facility. The primary motive behind the selection of the LDS drainage
geocomposite was to provide a drainage system that would have satisfactory structural
performance under the calculated overburden pressures. The drainage capacity of the selected
LDS drainage geocomposite exceeds, by a large margin, the calculated potential leakage rate into
the LDS.
Therefore, if the maximum drainage capacity of the LDS is adopted as the ALR, then during the
active life of a cell a leak condition that requires an action will likely never be triggered
regardless of the severity of the leakage. Also, the use of the flow capacity of the LDS drainage
geocomposite would result in a significant overdesign of the LDS collection sump and the
leachate pumping system.
Considering the large disparity between the cell-specific liquid leakage rates into the LDS (as
estimated in this RAP) and the flow capacity of the LDS drainage geocomposite, a more
reasonable flow rate is proposed for the ALR. The ALR flow rate is based on the minimum
required transmissivity of 3xl0"5 m2/sec in the drainage geocomposite of the LDS per 40 CFR
Part 264.301.
Based on this transmissivity and the cell floor width and slope, the maximum drainage capacities
of the LDS and thus ALRs are as follows.
TABLE 14-7 Cell Specific Action Leakage Rates (ALRs)
Cell
Cell Floor
Width (ft)
Minimum Cell
Floor Slope (%)
Max Drainage Capacity (gpd)
1
210
1%
To be supplied with the Construction Set
2
214
1%
To be supplied with the Construction Set
3
214
1%
To be supplied with the Construction Set
4
120
1%
To be supplied with the Construction Set
It should be noted that, the ALR values in the table above include a safety factor which greatly
exceeds the recommended minimum value of two that is published in the final leak detection
rule. This safety factor was calculated by multiplying the partial safety factors listed in Table
14-6.
The use of these action leakage rates enables the owner/operator to take action before large releases
into the LDS begin to occur.
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7.18 Verification of LDS Sump Capacity
The liquid capacity of the LDS sump will be provided in the Engineering Design Report package
along with the construction documents.
8 Landfill L-14 / L-15 Response Action Plan
This section details response actions for possible excursions from the cell-specific ALR's for
Landfill L-14 Cells 1 through 8 and Landfill L-15 Cells lthrough 4. A summary of the monitoring
to be performed is also included.
8.1 Monitoring of the Primary Leachate Collection Sumps
During the active life of Landfill L-14/L15, all primary leachate collection system sumps will be
inspected in accordance with the facility's Attachment #3 - Inspection Plan. Landfill L-14/L-15
sumps are monitored electronically by a SCADA system. Accumulated leachate in these sumps
will be pumped once the individual sump SCADA setpoint is reached or at a frequency
determined by the liquid accumulation rate, sump size, and the characteristics of the leachate
pumps installed in each sump. Frequent removal of the leachate from the primary leachate
collection system will minimize the hydraulic gradients that increase the potential for leakage
into the LDS.
8.2 LDS Monitoring
During the active life of Landfill L-14/L-15, all L-14/L-15 LDS sumps will be inspected for
liquid accumulation in accordance with the facility's Attachment #3 - Inspection Plan. Landfill
L-14/L-15 LDS sumps are monitored electronically by a SCADA system. Liquids accumulating
within the LDS sumps will be removed to the extent possible by the leachate removal system.
This will minimize the hydraulic head on the secondary containment system, also minimizing the
potential for leakage through the secondary geomembrane and the soil liner or GCL. The
maximum liquid level within the sumps will be 3 feet. This will prevent the liquids from
backing into portions of the leachate collection trench.
The SCADA system or manual measurements methods monitors leachate accumulation in the
primary and LDS sumps during the active life of the landfills. After final closure, the amount of
liquid removed from each LDS sump will be recorded at least monthly. The monitoring
frequency may be decreased to quarterly or semi-annually after closure in accordance with the
requirements outlined in 40 CFR Part 264.303(c)(2). The volume of liquid removed over the
time since last evacuation (end of pumping to end of pumping) will be averaged to determine if
the ALR has been exceeded.
If it is determined that the ALR's have been exceeded, the following responses will be initiated
until such time as the accumulations are determined to be within the cell's/sump's acceptable
operating limits. The agencies have authority, upon determining the existence of a significant
threat to human health and the environment, to require additional response actions.
8.3 Response Action Plan
For flow rates below the ALR, routine monitoring will continue.
Flow rates that equal or exceed the proposed ALR will require the implementation of a set of
actions as described below. Pumping rates out of the LDS sumps greater than the ALR are
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indicative of flows into the LDS greater than expected due to one or more of the mechanisms
described earlier.
8.4 EPA and DEQ Requirements
In the event of exceedance of the cell specific ALR value in a cell, CWMNW will, per the
minimum specifications detailed in 40 CFR Part 264.304(b)(c), and 340 OAR 104, take the
following actions:
• Notify the Department in writing of exceedance within 7 days of the determination and
indicate that the response action plan will be implemented.
• Submit a preliminary written assessment to the Department within 14 days of the
determination, describing the amount and likely sources of liquids, possible location, size,
and cause of any leaks and short-term actions taken and planned.
• Determine to the extent practicable, the location, size, and cause of any leak.
• Determine whether waste receipt should cease or be curtailed, whether any waste should be
removed from the unit for inspection, repairs, or controls, and whether or not the unit should
be closed.
• Determine other short-term and long-term actions to mitigate or stop any leaks.
• Within 30 days after the notification that the ALR has been exceeded, submit to the
Department the results of the analysis specified in Steps 3, 4, and 5 (above) and the results of
actions taken and planned.
• Monthly thereafter, as long as the flow rate in the LDS exceeds the ALR, submit to the
Department a report summarizing the results of remedial actions taken and actions planned.
• To make the leak and/or remediation determinations in Steps above, the owner/operator
must:
• Assess the source(s) of liquids and amounts of liquids by source
• Conduct a fingerprint, hazardous constituent, or other analysis of liquids in the LDS to
identify the source of liquids and possible location of any leaks, and the hazard and the
mobility of the liquid; and
• Assess the seriousness of any leaks in terms of potential for escaping into the environment;
or document why such assessments are not necessary.
8.5 TERTIARY SUMP MONITORING PROGRAM
A tertiary sump is constructed beneath each primary and secondary sump. The tertiary sump
system effectively represents an "engineered vadose zone", protected from the true in-situ
vadose zone materials by a tertiary liner system. Objective of Tertiary Sump Monitoring
Program
The primary purpose of the tertiary sump is to detect leaks in the LDS sump. Additionally, the
tertiary sump monitoring program is intended to provide data to help identify the nature of the
Landfill L-14 long-term detection monitoring program that will eventually replace the interim
monitoring program. The tertiary sump monitoring program is designed to provide the following
information: (1) whether any liquid is present in the tertiary sumps; (2) the rate of liquid
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accumulation in the tertiary sump; and (3) the chemistry of liquid that might accumulate in the
sump.
8.6 Tertiary Sump Monitoring Frequency
Monitoring will be implemented at a given tertiary sump once waste placement begins in the cell
that is monitored by the sump. The tertiary sump is monitored by the SCADA system and
monitors the presence of liquid. In the event that liquid is detected in the tertiary sump, liquid
removal will occur, and subsequent monitoring and liquid removal will be performed weekly as
long as liquids continue to be detected in the sump. Pumping will be performed with a dedicated
pump, such as a bladder pump (or equivalent). Pumping will occur only if the liquid head is
sufficient to operate the pump. The volume of liquid removed will be recorded. If liquid is
detected but the volume is insufficient to activate the pump, this will be noted.
8.7 Tertiary Sump Volume and Chemical Measurements
Monthly inspections look for evidence of surface contamination or discoloration, the condition
of the riser, and the integrity of the locking cap will be recorded and maintained as part of the
permanent monitoring record at the site. If no liquid is present in the tertiary sumps, this will be
noted along with the date and time of the observation.
Liquid samples will be collected quarterly, if a pumpable quantity of liquid is present to allow
for sampling, from the tertiary sump and analyzed for the chemical indicator parameters listed in
the Table 14.8 below. In addition, field indicator parameters (pH, SC, and temperature) will also
be measured in the secondary and tertiary sumps. If a sufficient quantity of liquid is present to
allow for sampling, one sample will be collected from both the secondary and tertiary sumps in
order to evaluate whether there has been a potential release. Based on the analytical results,
additional tertiary sump samples may be collected. If volatile organic compounds are detected in
the tertiary sump samples, the secondary sump will be immediately sampled and analyzed for the
constituents listed in Table 14.8. Weekly measurements of volume and field indicator
parameters will continue as long as liquid is observed in the tertiary sumps.
TABLE 14-8 Tertiary Sump Monitoring Parameters
Volatile Organic Compounds [Method 8260B]
General Inorganics: Common Anions/Cations
Calcium
Magnesium
Sodium
Potassium
Nitrate
Bicarbonate
Carbonate (when pH greater than 8.0)
Sulfate
Chloride
Indicator Parameters:
Dissolved Iron
Dissolved Manganese
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Chemical Waste Management of the Northwest, Inc.
Attachment No. 14 - Landfill Design, Operations Plan and Response Action Plan
8.8 Sump Sampling, Laboratory Analysis Procedures, and Reporting
Samples will be collected from the secondary and tertiary sump using the dedicated pumps
installed in the sumps for liquid removal. .
Samples for chemical analysis will be collected according to the general procedures specified in
Attachment #7 - Groundwater Monitoring Plan, with the exception that no purging of the sumps
will be performed prior to sample collection. Samples will be handled and sent to the laboratory
using strict chain-of-custody procedures, as described in Attachment #7 - Groundwater
Monitoring Plan.
An annual data report and summary will be submitted to the Department each year for the
tertiary sump monitoring program.
Revision X:
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Chemical Waste Management of the Northwest, Inc.
Attachment No. 14 - Landfill Design, Operations Plan and Response Action Plan
Revision X:
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