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CD Application Technical Comments #1 September 9, 2011 <br />Western Gravel Disposal Facility Page 3 <br />post- mining and post -land filling) may affect the permanent stormwater control designs. The permanent <br />ditch design can be provided now or at the time of closure. <br />15. Stormwater Controls — According to our discussions the content of the stormwater management plan for the <br />mining operation is known. The stormwater management for the solid waste facility should be consistent <br />with the mining operation and reclamation plan. <br />16. 3.5.3 — Discuss the run -off stormwater calculations in more detail including drainage area assumptions and <br />provide the design flow for the run -off ditches similar to 3.5.2. It is unclear what land is included in the 3.4 <br />acre drainage area for each channel given Cell A is 4.1 acres. Also clarify if the future cell located to the <br />west of Pond 1 was included in the Pond 1 design calculations. (see Appendix I comments below) <br />17. 3.6.3 — Discuss the potential for accumulation of toxic/hazardous gases within the cell and consider a <br />contingency plan for health and safety of employees and disposers. <br />18. 3.6.4 — The facility must cease operation and stop visible emissions off -site (dust) beyond the CD boundary. <br />Use of water within the cell for dust control may be acceptable under certain weather conditions given the <br />proposed LCRS will manage any excessive liquids. <br />19. 3.7.2 — Describe what the signage will say including "will not accept hazardous waste ", identify the wastes <br />not acceptable at the facility and provide operator contact information. <br />20. 3.8.1 — For each random load screening consider collecting a composite sample. Conduct analytical testing <br />on the sample at a specified testing rate (say 'A of the samples collected) for comparison with the waste <br />characterization data (for that Generator). <br />21. 3.8.5 — Describe the details of the security fencing surrounding each cell. <br />22. 3.9.1 or 3.9.4 — The waste characterization form used for exempt E &P waste must include a list of exempt <br />E &P waste accepted at the facility and the Generator must identify the specific waste disposed and provide <br />signature. Each load of waste from a project should be transported under manifest control (or a copy of the <br />disposal request letter) that again identifies the waste as an exempt E &P waste. <br />23. 3.9.2 — testing for Gross Alpha/Beta is an unreliable measurement with solids. Consider radium 226/228 <br />from a composite sample taken from the cell on some schedule. <br />24. 3.9.3 — Assuming the facility will accept various sources of petroleum contaminated soil (PCS), as well as <br />E &P drill cuttings, provide a listing of the analytical testing to be conducted for waste characterization for <br />each major waste stream. The testing rates proposed in the Application may be utilized for non - exempt PCS <br />waste. Consider less frequent testing for E &P drill cuttings such as one composited sample per 2000 cy with <br />a minimum of 2 samples per project. <br />25. 3.9.5 — Drill cuttings may contain naturally occurring radioactive material (NORM). Revise accordingly. <br />26. 3.10 Groundwater Monitoring — In lieu of a groundwater monitoring well located outside of CD boundary <br />consider wet/dry wells along the down dip southern edge of the CD. Given the robust liner system design <br />proposed and the dilution factor of the White River aquifer, groundwater monitoring near the river will likely <br />not identify a release from this facility. (also revise 2.3.3.7 accordingly). With this approach please request a <br />waiver from Section 2.2 of the Regulations for groundwater monitoring. <br />27. 3.10.2 — 3.10.6 — If groundwater monitoring is proposed, the monitoring plan should be consistent with <br />Appendix B of the Regulations: sampling quarterly to establish baseline; testing initially for the Appendix 1A <br />and 1B parameters to establish baseline conditions; and provide a statistical analysis plan. <br />28. 3.11 — An annual seepage survey is proposed for the steep slope to the north. It would be important to <br />develop "baseline" existing conditions by completing a well documented and complete survey of the area <br />prior to or soon after facility construction possibly in the wetter springtime. Consider that the unlined <br />stormwater ponds may provide a new source of water infiltrating into joints and fractures and then potentially <br />emanating from the steep slope. <br />29. 3.10 and 3.12 — For retention pond monitoring and wet/dry well monitoring, consider adding chloride to the <br />analytical testing. <br />30. 3.13 — Drill cuttings may be amended (solidified) by the oil/gas companies prior to disposal at this facility <br />and therefore the carbon will biodegrade possibly producing methane. Some alternative daily covers may <br />also consist of biodegradable materials. In addition volatile organic compounds are expected in the <br />acceptable waste. Consider monitoring not only for methane but for a broader range of explosive gases. <br />Provide action levels. Monitoring in all structures located inside CD boundary is required. A scale house is <br />