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Design and Operations Plan October 24, 2011 <br />Western Gravel E & P Waste Disposal Facility Page 34 of 51 <br />through waste characterization forms and waste characterization analytical results. Based upon total number <br />of random inspections that include sample collection (1 %), at a minimum, 1 /2 of the collected samples shall <br />be submitted to a laboratory for analysis. Each composite sample will consist of a minimum of five sub - <br />samples. Sample collection will be conducted in accordance with industry standards. Sub - samples will be <br />collected into a pre - cleaned mixing vessel. Composited samples will be directly transferred into pre - cleaned <br />laboratory supplied sample containers and immediately placed on ice in a cooler. Samples will be handled, <br />stored, and transported using chain -of- custody protocol. <br />Analysis of collected samples will be based upon waste profile analytes and the specific waste stream <br />characteristics. However, samples will periodically be analyzed for analytes (e.g. pesticides, herbicides, <br />polychlorinated biphenols [PCBs]) not anticipated being present in the waste. In the event that suspect <br />analytes are reported, CDPHE will be notified and based upon agreement, random load screening will likely <br />be increased. <br />3.8.2 Training <br />Personnel conducting random inspections and operating in the landfill cell will be trained to recognize and <br />work with hazardous waste. Personnel should attend a SWANA and or equivalent training course. Because <br />of the nature of materials to be disposed at the facility, Occupational Safety and Health Administration <br />(OSHA) 40 -hour HAZWOPER safety training may be required. In addition, a site safety plan associated <br />with suspect hazardous waste may be warranted. Training records shall be placed in the Operating Record. <br />3.8.3 CDPHE Notification <br />In the event that suspect hazardous waste is identified, CDPHE shall be notified in writing within 24 hours of <br />the event. The notification will describe events leading to detection of the suspect material and provide <br />information including waste generator, waste transporter, and current status of the waste. <br />Suspect waste identified during unloading will be loaded into the transport truck and returned to the <br />generator. Suspect waste identified in a loaded truck shall not be off - loaded at the landfill. Waste that is <br />refused and reloaded into a transport truck following inspection and waste that is refused and not unloaded <br />are both considered unaccepted waste. <br />3.8.4 Record Keeping <br />Records regarding random and routine inspections shall be maintained at the facility including but not <br />limited to modifications to the random inspection program, identified suspect materials and handling, and <br />inspection results. Typical records include inspection date and time, type of inspected vehicle, name of <br />driver and transport company, license plate number, notes recorded during driver interview, inspector <br />observations of waste, any actions resulting from the inspection. Inspection records must be maintained in <br />the Operating Record. <br />3.8.5 Access Control <br />Site access road control is maintained using a gated entrance and signage. In addition, landfill security <br />personnel may be used, as necessary. Following business hours and in the event that those security personnel <br />are not present; the entrance gate shall be locked. Actual landfill cells are located approximately 1 1/2 miles <br />from the access entrance and scale house. Therefore, security chain link fencing approximately six feet in <br />height will be installed around active cells and include a locked access gate. The gate will be locked <br />following business hours. Following closure of each cell, security fencing will be removed. <br />NWCC, Inc. <br />