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Design and Operations Plan October 24, 2011 <br />Westem Gravel E & P Waste Disposal Facility Page 43 of 51 <br />the landfill terrace, active cell stormwater run -off into a stormwater retention pond, and methane and VOC <br />gas concentrations above threshold levels. Contingency plan response activities follow below. <br />4.8.1 Illegal Dumping, Suspicious Materials, and Spills <br />Illegal dumping includes any and all unsolicited disposal (e.g. disposing wastes along the facility access <br />road, outside of landfill cells without facility personnel knowledge, and/or knowingly disposing unapproved <br />wastes [e.g. suspicious waste, hazardous, general trash, drums]) Unapproved wastes may be considered <br />suspicious in nature. Waste spills outside a cell are not likely but may occur through spillage off a transport <br />truck and/or truck roll -over. All loads entering the facility access must be covered (e.g. tarped) in order to <br />minimize the spill potential along the access road. CDPHE must immediately be notified in the event of <br />illegally dumped, suspicious, and/or spilled wastes. <br />Since the origin of illegally dumped waste is unknown, the material must be considered suspicious and <br />handled accordingly. Suspicious waste includes but is not limited to containerized (e.g. drummed) material, <br />unusual physical appearance (e.g. color, saturated), unusual or offensive odor (e.g. pungent, sweet), and <br />vapors that are irritating to eyes, nasal system, and lungs. Following CDPHE notification, the waste will be <br />bermed using soil and/or other material in order to contain and inhibit migration of the waste. CDPHE w ill <br />be consulted in order to determine corrective actions that may include hazardous waste response team <br />activation and/or material sampling and analytical analysis. <br />Spills of waste approved for disposal at the facility will be contained in order to inh ibit material migration. <br />The spill will immediately be cleaned using landfill equipment (e.g. loaders, skid - steer, and dump truck). <br />Material will be transported and disposed in an active landfill cell. In the event that saturated material is <br />spilled, the spill location will be evaluated by an environmental professional in order to determine if <br />excavation and/or additional characterization activities are warranted. CDPHE will be consulted in order to <br />determine appropriate corrective actions. <br />4.8.2 Wet/Dry Wells <br />In the event that liquid is discovered in a wet/dry well, samples will be collected in order to help determine if <br />the liquid is a result of leachate migration, surface water entering the well, condensate in the well, or <br />groundwater. If liquid is discovered, CDPHE must be notified and analytical samples collected within 7 <br />days of discovery. Analytical results must be reported to CDPHE within 7 days of sample analytical results <br />receipt. At a minimum, sample analysis shall include chlorid e, sodium, and BTEX. BTEX detection above <br />the laboratory method detection limits (MDLs) will be considered potential impacts from waste. BTEX <br />MDLs used are unknown and may be elevated because of sample interference and/or laboratory dilution <br />required in order to analyze the samples. However, MDLs should be less than groundwater standards. <br />Additionally, potential laboratory and/or field cross contamination will be evaluated and a trip blank will be <br />used in order to help evaluate potential sample cross co ntamination. Sodium and chloride results will be <br />used to help assess if a release has occurred. <br />In the event that analytical results suggest that sampled liquid could be cell leakage (e.g. E &P waste or PCS <br />waste), CDPHE shall be notified in order to determine appropriate corrective action. Based upon analytical <br />data evaluation, additional confirmation samples may be collected in order to help assess if the liquid source <br />is potentially from the waste. CDPHE will be consulted in order to determine appro priate corrective actions. <br />4.8.3 Terrace Face Seeps <br />If suspect liquid and/or soils are observed during seep monitoring activities, analytical samples will be <br />collected. Because petroleum constituents are the best parameters to use for monitori ng the landfill, <br />NWCC, Inc. <br />