2012-09-06_REVISION - M2008070 (25)

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Design and Operations Plan October 24, 2011 Western Gravel E & P Waste Disposal Facility Page 35 of 51 3.8.6 Visual Impact Control The facility is located in a remote area; however, the landfill will be visible from the White River and Highway 64. Proposed waste will mainly be drill cuttings, drilling mud, and PCS that will be covered daily with soil and/or alternative daily cover. In the event that alternative daily cover is used, the material color is anticipated to be consistent with natural surroundings. In addition, cell elevations and finished slopes above natural grade are not significant; therefore, waste cells should blend with the natural hilly topography. 3.9 WASTE PLAN Exempt E &P waste to be disposed at the facility will mainly be drill cuttings and mud associated with energy exploration and production. Additionally, non -exempt E &P waste (e.g. PCS) will be accepted for disposal. PCS not associated with E &P operations (e.g. vehicle accidents, petroleum remedial activities) will also be accepted at the facility. Non - exempt wastes accepted for disposal shall not meet or exceed hazardous waste materials criteria. Acceptable and non - acceptable wastes are summarized below in Sections 3.9.5 and 3.9.6. Although exempt, E &P wastes and PCS will be characterized prior to acceptance for disposal at the facility. Waste shall be characterized based upon generator knowledge, laboratory analysis, and/or material safety data sheets (MSDS). The waste generator or appointed representative is ultimately responsible for waste characterization. Prior to conducting waste sample analysis, the generator should contact WGDF in order to determine the level of analysis required. WGDF shall determine the extent of appropriate characterization efforts and adequacy of waste characterization conducted. WGDF approval of waste characterization does not relieve the generator's responsibility to characterize the waste. WGDF reserves the right to refuse any wastes for any reason. In the event that the waste does not appear representative of characterization documentation, WGDF may reject the waste based upon random or unloading inspections at the working face. Waste evaluation and acceptance procedures are summarized below. 3.9.1 Waste Evaluation Each waste source shall be adequately characterized based upon the generator's knowledge, laboratory testing, and/or MSDS. A waste characterization form obtained from WGDF must be completed and returned for review. The waste characterization form will list exempt E &P waste accepted at the facility. The specific waste to be disposed, generator information, and signature w ill be included on the completed form. Following review, the generator or representative (disposer) shall be interviewed in order to help determine the level of required characterization. Required material analysis will be provided to the disposer. The disposer is responsible for providing required analytical reports for disposal evaluation purposes. Following receipt of analytical results, the disposer will provide the reports to WGDF. WGDF shall evaluate provided waste characterization information and reject or accept the disposal request. Subsequently, WGDF shall provide a disposal acceptance or rejection letter to the disposer. WGDF approval of waste shall not relieve the generator's responsibility to characterize the waste or making a hazardous waste determination. 3.9.2 Waste Analysis An analytical laboratory holding current National Environmental Laboratory Accreditation Program (NELAP) certification must be used to provide analytical services. Required analysis will be based upon waste characterization form review and disposer interview. General guidelines presented below may change based upon waste streams that require more or less analytical testing, at the discretion of WGDF. E &P waste and PCS analysis will generally include the following; however, actual required analytical suites are subject to known waste information. NWCC, Inc.