Monthly progress rpts (1/2000-12/2000) · Nov.6: Trimble's Geo-Explorer III is still not available. Trimble can not give our local distributer a time for delivery. Dec.l: Formal approval

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ONE OR MORE PAGES IN THIS DOCUMENT ARE DIFFICULT TO READDUE TO THE QUALITY OF THE ORIGINAL

January 13,2000

Ms. Susanna Tmjillo, Project CoordinatorU.S. EPA Region IX75 Hawthorne Street (WST-7)San Francisco, C A 94105-3901

Dear Ms. Trujillo:

RE: Monthly Progress Report - January, 2000Order RCRA 7003-09-99-0005NOV/Order CWA-3 09-9-99-14

As required by the above referenced RCRA Order, specifically VI number 3 (page 9 of 22), thefollowing is the monthly progress report: The report contains two sections, the Current MonthlyProgress Report section, followed by the Monthly Progress Report Summary section. Theprogress report items are numbered with the first three letters of the month of the report that theitem appeared. This months items are:

Section I: Current Monthly Progress Report

Jan. 1: On December 21,1999, Republic DUMPCo received comments back from EPAregarding waste relocation in the Northeast Canyon. As discussed, the January 7, 2000,submittal date for the additional information on the Northeast Canyon Relocation ofwaste has been extended to January 18,2000.

Jan.2: On December 22, 1999, SCS on the behalf of Republic DUMPCo, submitted the DesignReport for the Eastern By-Pass Channel Reconstruction.

Jan.3: Republic DUMPCo has received a Stormwater General Permit (GNV0022233-20553)from the Nevada Division of Environmental Protection. The Authorization date of thePermit is indicated as being December 16, 1999.

Jan.4: On December 16, 1999, EMCON conducted an evaluation of the existing stormwatercontrols at the Sunrise Landfill. All of their recommendations have been completed,except for placing rip-rap at the outfalls from the Southern Flats and at the sediment basinbelow the upper flats southwestern down drain. The rip-rap should be in place by the endofJanauary.

770 East Sahara Avenue • P.O. Box 98508 • Las Vegas, Nevada 89193-8508 • Telephone 735-5151 • Fax (702) 735-1986

MADE WITH RECYCLED PAPER

Page 2January 2000 Progress Report

Jan.5: On December 22, 1999, Republic DUMPCo received correspondence from EPAapproving the modified CSAMT lines. Since that time, Republic DUMPCo has decidedto add additional CSAMT lines. Please find enclosed with this correspondence adrawing with the additional CSAMT lines 10 and 11.

Jan.6: Republic DUMPCo has completed mapping of all Interim Actions, including theadditional fences in the Northeast Canyon. As soon as the as-built drawings for theheadwalls and construction debris cell are complete, an amended IA Report will beforwarded to EPA.

Jan.7: Workplan Progress: The field work for CSAMT is 60% complete. Surface EmissionMonitoring should be completed by January 14, 2000. EM started on January 3, 2000,and IP is scheduled to start in the Northeast Canyon on January 14, 2000.

Section 2: Monthly Progress Report Review Summary:

1. Tentative agreements have been reached on the access agreement for off-lease areas.2. RCRA Order Item b. 1 .(a-h) "Landfill Assessment Work Plan," was completed and

delivered to EPA and BLM on June 7, 1999.3. CWA Order Task #19, 20, and 21 were competed and delivered to EPA and BLM on

June 11,1999.4. On July 16, 1999, DUMPCo submitted to EPA a Sunrise Landfill Release Report that

described the impacts associated with the July 8,1999 storm event. This report alsoincluded a request to implement interim emergency measures to prevent further impacts.

5. EPA's August 2, 1999, comments on the "Work Plan" have been received and reviewed.Based on these comments, Republic DUMPCo (DUMPCo) requested an extensionfor the submittal of the revised work plan from August 16, 1999 to August 25, 1999.

6. DUMPCo completed the consultant selection process for the RCRA Work Planassessment work.

7. In a letter dated August 6, 1999, DUMPCo responded to EPA's comments regardinginterim stormwater control measures. DUMPCo is implementing these measures asoutlined in the letter

Sep.l: A hydrology and hydraulic study was submitted to EPA for approval on August 30, 1999,for the Eastern portion of the landfill as part of DUMPCo's August 8,1999, (E.5 & E.6)response to EPA's comments on the DUMPCo's Interim Stormwater Measures. Usingthe data obtained from the hydrology and hydraulic study, preliminary design conceptsare proposed for blasting the drop off channel and re-armoring the western slope of thelandfill. That area has been impacted in past storm events. After approval of thisapproach, DUMPCo will provide EPA with proposed construction drawings for thesecontrol measures.


Sep.2: As requested by Clark County Public Works (CCPW), final construction drawings for theprotection of the Construction Debris Cell were delivered to CCPW on September 8,1999, for their final approval and bonding.

Sep.3: DUMPCo expects to begin placing concrete around the down drains, as specified in theAugust 6, 1999, response to EPA's comments on the Interim Plan, by the end ofSeptember.

Sep.4: On August 25,1999, SCS Engineers submitted, on the behalf of DUMPCo, a revisedWork Plan as required by EPA's August 17, 1999 approval of DUMPCo's extensionrequest.

Sep.5: EPA provided DUMPCo with some general comments regarding the revised Work Plan.DUMPCo is in the process of clarifying some the text based on EPA's comments.However, two possible points of misunderstanding were identified: The InducedPolarization (IP) method includes resistivity (See page 9, 3.4.1.5), and DUMPCo does notfeel that it is appropriate to restate objectives in the Sampling and Analysis Plan (SAP).The SAP is designed to describe methods.

Sep.6: DUMPCo will be providing EPA with a list of contractors and summaries ofqualifications of the consultants and primary contractors for the Sunrise Landfill work.DUMPCo is in the process of selecting the geoprobe contractor and soils laboratory(s).The approval letter should be ready by the end of September.

Sep.7: After evaluating the Trimble Geo Explorer II and associated software, DUMPCo hasdecided to purchase the unit. The evaluation determined that while the unit does notprovide field personnel with accurate locations, once the data has been corrected with thesoftware, valuable location information can obtained.

Sep.8: DUMPCo has been proceeding with surficial stormwater control work, see the attachedsummary. A detailed report of these repairs will be provided, including pictures.

Sep.9: DUMPCo is in the process of evaluating the GC Wallace, Inc. "Conceptual DrainageAnalysis For The Sunrise Mountain Landfill East Channel," dated August 1999, preparedfor Clark County Department of Public Works. A copy of the report has been forwardedto EPA.

Oct. 1: EPA has verbally approved moving forward with providing EPA with constructiondrawings and specifications for blasting the south end of the Eastern Bypass channel, andarmoring of landfill cell below the drop off structure. However, EPA made it clear thatthis structural modification may not be the final solution to the drainage in this area. (SeeInterim Action Report).


Oct.2: DUMPCo has received final approval for armoring the Construction Demolition Cell andDUMPCo is proceeding to construct. See Interim Action Report.

Oct. 3: DUMPCo will place concrete around the down drains during the armoring of theConstruction demolition cell.

Oct.4: In a correspondence dated September 29,1999, DUMPCo submitted to EPA a list ofcontractors, consultants, and laboratories for review and approval. DUMPCo requests toadd an additional company to this list: Atlas Chemical Testing Laboratories. A companyprofile is enclosed with this monthly progress report.

Oct.5. As indicated in the October 7, 1999 teleconference, DUMPCo is evaluating the mostappropriate method(s) that should be used to determine soil loss from erosion. After aninitial review, it seems that there may be a problem with past reports that indicate that thecover at Sunrise contains high concentrations of gypsum. After a review of the EMCONexpansion report and Dynamac's report, there does not seem to be any formal analyticalresults to support comments made in those reports. DUMPCo has identified a localchemical testing laboratory that has the ability to test for these parameters. DUMPCowill provide EPA with the results of this evaluation.

Oct.6: DUMPCo has indicated to EPA that there may not be enough available cover material atthe Landfill site to respond to the corrective actions that will be identified in the RCRAWork Plan and CWA AO. DUMPCo has proposed to locate small crushing plant on sitein order to make cover dirt. EPA has responded by requesting specifications on thematerial and product that will be used as cover. DUMPCo is currently evaluating anumber of different specifications, and has obtained a sample of the source material. Thissample will be analyzed to determine it's chemical composition. However, until theappropriate models can be established, DUMPCo is unable to provide EPA with theproposed cover material specifications. DUMPCo is evaluating this, and in the interim,submits an Alternative Cover Evaluation that was completed in Glendale, Arizona forEPA review.

Oct.7: On August 31,1999, Harding Lawson Associates conducted perimeter landfill gasmonitoring at the Sunrise Landfill. No detectable levels of landfill gas was detected atthe perimeter of the Sunrise Landfill. (See the attached HLA report)

Oct 8: CWA Task #20 - Interim Plan now contains an Appendix A entitled: Interim ActionReport (IAR). Republic DUMPCo is requesting approval of these actions as InterimActions. This report will be updated to finalize the document once all actions arecomplete.

Oct 9: Republic DUMPCo has ordered a Geoexplorer II. However, Trimble has discontinuedmanufacturing this unit and has no more in stock. Republic DUMPCo is on the waitinglist for a Geoexplorer III. Republic DUMPCo will update these Interim Actions as soonas the unit is received, the software is installed and the unit is calibrated for the Sunrisesite.


Nov.l: On November 2, 1999, SCS Engineers, on the behalf of Republic DUMPCo, submitted toEPA the response to EPA's Draft Comments on the revised Work Plan.

Nov.2: All proposed down drain head wall modifications have been completed. RepublicDUMPCo will be providing EPA with a detailed report.

Nov. 3: Armoring of the Construction Debris Cell has begun. Republic DUMPCo will beproviding EPA with a detailed report once this Interim Action is complete.

Nov.4: The detailed drawing for the proposed blasting and armoring of the Eastern BypassChannel outlet is in the making. As soon as they are complete, they will be submitted toEPA for review.

Nov. 5: Four truck loads of proposed rock to be used as a cover source has been crushed.Samples of this material will be evaluated for potential use. Once the evaluation iscomplete, a report will be submitted to EPA for review.

Nov.6: Trimble's Geo-Explorer III is still not available. Trimble can not give our localdistributer a time for delivery.

Dec.l: Formal approval of portions of the November 2, 1999, revised Work Plan was obtainedon December 7, 1999.

Dec.2: Republic DUMPCo has purchased a GPS system, and is in the process of mapping all ofthe Interim Actions (IA).

Dec.3: BLM has placed boundary identification markers for the Instant Study Areas (ISA).Republic DUMPCo is in the process of mapping these areas.

Dec.4: All Interim Actions, except for the Design of the Eastern Drop off Channel and themapping of the lA's have been completed. Republic DUMPCo will be providing EPAwith a full report to update the lA's.

Dec.5: EMCON started Geologic Mapping on December 9, 1999, and the surface gas monitoringis scheduled to start on December 14, 1999. CSAMT should be starting within a week.

Dec.6: The initial review of the Design Drawings for the Eastern Bypass Channel revealedseveral technical errors. SCS is in the process of revising the design drawings.

"Page 6January 2000 Progress Report

If you have any questions, please contact me at (702) 734-5400.

Respectfully,"

CC: Mr. David Basinger (WTR - 7) Water DivisionU.S. Environmental Protection Agency75 Hawthorne StreetSan Francisco, CA 94105 - 3901

Mr. Dave Emme, ChiefBureau of Waste ManagementNevada Division of Environmental Protection333 W. Nye Lane, Room 138Carson City, NV 89706-0851

Mr. Clare SchmutzClark County Health District625 Shadow LaneLas Vegas, NV 89106

Mr. Mark Morse, Field Manager(Attention: Mike Moran)Bureau of Land Management4765 Vegas Valley DriveLas Vegas, NV 89108

Mr. John SchlegelClark County Comprehensive Plan.500 S. Grand Central PkyLas Vegas, NV 89155-1745

Ms. Sandy DotySAIC5303 W. Oberlin Dr.Denver, CO 80235

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February 14,2000

Ms. Susanna Trujillo, Project CoordinatorU.S. EPA Region IX75 Hawthorne Street (WST-7)San Francisco, CA 94105-3901

Dear Ms. Trujillo:

RE: Monthly Progress Report -- February, 2000Order RCRA 7003-09-99-0005NOV/Order CWA-309-9-99-14

As required by the above referenced RCRA Order, specifically VI number 3 (page 9 of 22), thefollowing is the monthly progress report: The report contains two sections, the Current MonthlyProgress Report section, followed by the Monthly Progress Report Summary section. Theprogress report items are numbered with the first three letters of the month of the report that theitem appeared. This months items are:

Section I: Current Monthly Progress Report

Feb. 1: In a January 19, 2000, correspondence from EPA, Republic DUMPCo receivedcomments on the Stormwater Inspection Report dated December 16, 1999. Along withproviding specific comments on the Stormwater Inspection Report, this correspondencerequires Republic DUMPCo to submit a monitoring plan no later than March 7, 2000.Republic DUMPCo is in the process of developing a Monitoring Plan.

Feb.2: In a January 27, 2000, correspondence Republic DUMPCo provided comments regardingEPA's Janauary 19, 2000, comments on the Stormwater Inspection Report datedDecember 16, 1999.

Feb.3: In a February 2, 2000, correspondence EPA provided Republic DUMPCo with approvalof Design Report for the Eastern Bypass Channel Reconstruction. Republic DUMPCo isin the progress of putting together the appropriate approval package for Clark CountyPublic Works approval. This package will contain the additional information andclarifications requested by EPA. A copy of this package will be forward to EPA.

Feb.4: The addendum to the Design Storm Event was submitted to EPA in a February 4, 2000,correspondence from EMCON.


i MADE WITH RECYCLED PAPER

Page 2February Monthly Progress Report

Feb.5: In a February 8, 2000, correspondence Republic DUMPCo provided EPA with anUpdated Interim Action Report.

Feb.6: On February 14, 2000, EPA provided Republic DUMPCo with a limited approval of theGeneral Waste Removal Plan with Exhibit 1, Northeast Off-Lease Interim Action. Thelocation of the waste to be removed has been staked off. BLM has been on site to reviewthe area of waste removal. Republic DUMPCo will be sampling the waste on February14, 2000, and will begin removal process as soon as the analytical results have beenreviewed.

Feb.7: In the early part of February, Republic DUMPCo received electronic copies of commentson the non-approved sections of the Work Plan. Through verbal arrangements, RepublicDUMPCo has transmitted to EPA a revised Sampling and Analysis Plan (SAP) based onEPA's comments (Final Revised SAP, February 13, 2000).

Feb.8: Based on EPA comments and the revised SAP, Republic DUMPCo is planning onstarting hydrogeologic borings on Wednesday, February 16, 2000.

Feb.9: IP in the Northeast Canyon is 95% complete. The schedule in the Work Plan indicatesthat all of the IP should be completed within 28 days. The IP was started on January 11,2000. The IP in the Northeast Canyon may take a little longer than the 28 days tocomplete.

Feb. 10: The EM is taking longer than anticipated. The EM started on January 4, 2000, and is50% complete.

Feb.l 1: Field geologic mapping and historic review is complete. All the data is being assessed,and locations electronically mapped. This information is being compared with existinginformation and CSAMT data. The ground truthing and calibration of computermodeling is currently under way.

Feb. 12: The rain gauges were installed on February 4, 2000, and February 9, 2000. The data isto become available through the Flood Control website at www.CCRFCD.org.

Section 2: Monthly Progress Report Review Summary:



June 11, 1999.4. On July 16, 1999, DUMPCo submitted to EPA a Sunrise Landfill Release Report that

described the impacts associated with the July 8, 1999 storm event. This report alsoincluded a request to implement interim emergency measures to prevent further impacts.

5. EPA's August 2, 1999, comments on the "Work Plan" have been received and reviewed.Based on these comments, Republic DUMPCo (DUMPCo) requested an extensionfor the submittal of the revised work plan from August 16, 1999 to August 25,1999.



7. In a letter dated August 6,1999, DUMPCo responded to EPA's comments regardinginterim stormwater control measures. DUMPCo is implementing these measures asoutlined in the letter

Sep.l: A hydrology and hydraulic study was submitted to EPA for approval on August 30, 1999,for the Eastern portion of the landfill as part of DUMPCo's August 8, 1999, (E.5 & E.6)response to EPA's comments on the DUMPCo's Interim Stormwater Measures. Usingthe data obtained from the hydrology and hydraulic study, preliminary design conceptsare proposed for blasting the drop off channel and re-armoring the western slope of thelandfill. That area has been impacted in past storm events. After approval of thisapproach, DUMPCo will provide EPA with proposed construction drawings for thesecontrol measures.



Sep.4: On August 25,1999, SCS Engineers submitted, on the behalf of DUMPCo, a revisedWork Plan as required by EPA's August 17, 1999 approval of DUMPCo's extensionrequest.







Oct.l: EPA has verbally approved moving forward with providing EPA with constructiondrawings and specifications for blasting the south end of the Eastern Bypass channel, andarmoring of landfill cell below the drop off structure. However, EPA made it clear thatthis structural modification may not be the final solution to the drainage in this area. (SeeInterim Action Report).


Oct.3: DUMPCo will place concrete around the down drains during the armoring of theConstruction demolition cell.


Oct.5. As indicated in the October 7,1999 teleconference, DUMPCo is evaluating the mostappropriate method(s) that should be used to determine soil loss from erosion. After aninitial review, it seems that there may be a problem with past reports that indicate that thecover at Sunrise contains high concentrations of gypsum. After a review of the EMCONexpansion report and Dynamac's report, there does not seem to be any formal analyticalresults to support comments made in those reports. DUMPCo has identified a localchemical testing laboratory that has the ability to test for these parameters. DUMPCowill provide EPA with the results of this evaluation.


Oct.7: On August 31, 1999, Harding Lawson Associates conducted perimeter landfill gasmonitoring at the Sunrise Landfill. No detectable levels of landfill gas was detected atthe perimeter of the Sunrise Landfill. (See the attached HLA report)

PageSFebruary Monthly Progress Report





Nov.3: Armoring of the Construction Debris Cell has begun. Republic DUMPCo will beproviding EPA with a detailed report once this Interim Action is complete.


Nov.5: Four truck loads of proposed rock to be used as a cover source has been crushed.Samples of this material will be evaluated for potential use. Once the evaluation iscomplete, a report will be submitted to EPA for review.






Dec.5: EMCON started Geologic Mapping on December 9,1999, and the surface gas monitoringis scheduled to start on December 14, 1999. CSAMT should be starting within a week.



Jan.l: On December 21, 1999, Republic DUMPCo received comments back from EPAregarding waste relocation in the Northeast Canyon. As discussed, the January 7, 2000,submittal date for the additional information on the Northeast Canyon Relocation ofwaste has been extended to January 18, 2000.




Jan.5: On December 22, 1999, Republic DUMPCo received correspondence from EPAapproving the modified CSAMT lines. Since that time, Republic DUMPCo has decidedto add additional CSAMT lines. Please find enclosed with this correspondence adrawing with the additional CSAMT lines 10 and 11.




Respectfully,

Alan GadVice President








Mrbati

March 13, 2000


Dear Ms. Trujillo:

RE: Monthly Progress Report - March, 2000Order RCRA 7003-09-99-0005NOV/Order CWA-3 09-9-99-14

As required by the above referenced RCRA Order, specifically VI number 3 (page 9 of 22), thefollowing is the monthly progress report. Attachment I to the monthly progress report containspast monthly progress items. The progress report items are numbered with the first three lettersof the month of the report that the item appeared. This months items are:

Current Monthly Progress Report

Mai". 1: In a February 14, 2000, correspondence, EPA approved the Northeast Canyon InterimAction plan.

Mar.2: The General Waste Removal Work Plan was modified to address EPA March 14, 2000,comments (Revised Version Dated: February 24, 2000).

Mar.3: In a February 28, 2000, correspondence, EPA approved the modified General WasteRemoval Plan and the statistical analysis results from the seven (7) samples.

Mar.4: On February 29, Republic DUMPCo began removing waste from the Northeast Canyon.

Mar. 5: In a March 1, 2000, correspondence, the EPA notified Republic DUMPCo that theapproached used for the Design Storm Event submitted on October 13, 1999, with theadditional information contained in the February 4, 2000, correspondence, wasappropriate. However, EPA did not feel that the 100-year storm event provided anacceptable level of confidence, and, therefore, approved only the use of the 200-yearstorm event.

1


I MADE WITH RECYCLED PAPER

Mar.6: On March 1, 2000, EPA received a revised Work Plan.

Mar.7: On March 3, 2000, after verbal discussions and minor modifications, Republic DUMPCoreceived approval of the final sections of the Work Plan from EPA. The March 3, 2000,correspondence also required that the schedule for the Work Plan be updated once thefirst exploratory bore hole is completed, and after the completion of test pit/trenches andinitial shallow borings for cover material soil assessment.

Mar.8: In a March 3, 2000, correspondence, SCS on the behalf of Republic DUMPCo, providedEPA with an addendum to the Eastern By-Pass Channel Reconstruction Interim Action toaddress EPA's comments. As indicated in the correspondence, Republic DUMPCo iswaiting on approval and/or comments from Clark County Public Works and EPA toinitiate this Interim Action. Clark County Public Works received a copy of these planson February 23, 2000.

Mar.9: In a March 6, 2000, correspondence, as requested by EPA, Republic DUMPCo providedEPA with a Stormwater Monitoring Plan.


Resr/fitfully

Vice Preswent

AG/tg

File#: 999901-062/Order 7484

Attachments: Attachment I - Past Monthly Progress Report Items



Mr. Dave Emme, Chief Mr. John SchlegelBureau of Waste Management Clark County Comprehensive Plan.Nevada Division of Environmental Protection 500 S. Grand Central Pky333 W. Nye Lane, Room 138 Las Vegas, NV 89155-1745Carson City, NV 89706-0851

Mr. Clare Schmutz Ms. Sandy DotyClark County Health District SAIC625 Shadow Lane 5303 W. Oberlin Dr.Las Vegas, NV 89106 Denver, CO 80235

Attachment IPaste Monthly Progress Report Items:



June 11, 1999.4. On July 16,1999, DUMPCo submitted to EPA a Sunrise Landfill Release Report that


5. EPA's August 2, 1999, comments on the "Work Plan" have been received and reviewed.Based on these comments, Republic DUMPCo (DUMPCo) requested an extensionfor the submittal of the revised work plan from August 16, 1999 to August 25,1999.






Sep.4: On August 25, 1999, SCS Engineers submitted, on the behalf of DUMPCo, a revisedWork Plan as required by EPA's August 17, 1999 approval of DUMPCo's extensionrequest.

Sep.5: EPA provided DUMPCo with some general comments regarding the revised Work Plan.DUMPCo is in the process of clarifying some the text based on EPA's comments.However, two possible points of misunderstanding were identified: The Induced

4

Polarization (IP) method includes resistivity (See page 9, 3.4.1.5), and DUMPCo does notfeel that it is appropriate to restate objectives in the Sampling and Analysis Plan (SAP).The SAP is designed to describe methods.








Oct.4: In a correspondence dated September 29, 1999, DUMPCo submitted to EPA a list ofcontractors, consultants, and laboratories for review and approval. DUMPCo requests toadd an additional company to this list: Atlas Chemical Testing Laboratories. A companyprofile is enclosed with this monthly progress report.

Oct.5. As indicated in the October 7, 1999 teleconference, DUMPCo is evaluating the mostappropriate method(s) that should be used to determine soil loss from erosion. After aninitial review, it seems that there may be a problem with past reports that indicate that thecover at Sunrise contains high concentrations of gypsum. After a review of the EMCONexpansion report and Dynamac's report, there does not seem to be any formal analyticalresults to support comments made in those reports. DUMPCo has identified a local

5

chemical testing laboratory that has the ability to test for these parameters. DUMPCowill provide EPA with the results of this evaluation.









Nov.5: Four truck loads of proposed rock to be used as a cover source has been crushed.Samples of this material will be evaluated for potential use.

6

Once the evaluation is complete, a report will be submitted to EPA for review.








Jan. 1: On December 21, 1999, Republic DUMPCo received comments back from EPAregarding waste relocation in the Northeast Canyon. As discussed, the January 7, 2000,submittal date for the additional information on the Northeast Canyon Relocation ofwaste has been extended to January 18, 2000.



Jan.4: On December 16, 1999, EMCON conducted an evaluation of the existing stormwatercontrols at the Sunrise Landfill. All of their recommendations have been completed,except for placing rip-rap at the outfalls from the Southern Flats and at the sediment basinbelow the upper flats southwestern down drain. The rip-rap should be in place by the endof Janauary.

Jan.5: On December 22, 1999, Republic DUMPCo received correspondence from EPAapproving the modified CSAMT lines.

7

Since that time, Republic DUMPCo has decided to add additional CSAMT lines. Pleasefind enclosed with this correspondence a drawing with the additional CSAMT lines 10and 11.









Feb.7: In the early part of February, Republic DUMPCo received electronic copies of commentson the non-approved sections of the Work Plan.

8

Through verbal arrangements, Republic DUMPCo has transmitted to EPA a revisedSampling and Analysis Plan (SAP) based on EPA's comments (Final Revised SAP,February 13, 2000).




Feb. 11: Field geologic mapping and historic review is complete. All the data is being assessed,and locations electronically mapped. This information is being compared with existinginformation and CSAMT data. The ground truthing and calibration of computermodeling is currently under way.


JHabtfemmce

April 14,2000


Dear Ms. Trujillo:

RE: Monthly Progress Report - April, 2000Order RCRA 7003-09-99-0005NOV/Order CWA-309-9-99-14


Current Monthly Progress Report

Apr. 1 : The exploratory borings were started on March 13, 2000. The following is the status ofthese exploratory borings:GUI -A: Stopped at 102 feet below Ground Surface (bgs); bed rock contact.GH2-A: Stopped at 75 feet bgs; confining unit.GH3-A: Stopped at 43 feet bgs; confining unit.GH4-A: Stopped at 50 feet bgs; confining unit.GH5-A: Stopped at 64 feet bgs; confining unit.GH6-B: Stopped at 203 feet bgs; confining unit.

Apr.2: Additional IP lines have been run along the CSAMT lines over exploratory borings GH2-through GH6 to determine the extent of the confining unit. An additional boring atlocation 5 has been identified. A new exploratory boring was started at this location onApril 11, 2000. This recommendation along with the supporting data has been forwardedto EPA.


i MADE WITH RECYCLED PAPER

Apr.3: The data from the other IP lines is currently being evaluated to determine the nextappropriate borings for the other borings. This information along with RepublicDUMPCo's recommendations will be forwarded to EPA for their evaluation andapproval.

Apr.4: As required by the Work Plan, since bed rock was encountered at GH1-A, all CSAMTand geological mapping information is being evaluated. This information along RepublicDUMPCo's recommendations will be forward to EPA as soon additional information isobtained from the other exploratory borings in order to "ground truth" some of theCSAMT assumptions.

Apr.5: The borings in the lagoons have been completed. Two borings were completed in each ofthe four lagoons, except for lagoon number 3, the most eastern of the western burn pits.The initial boring in this lagoon was advanced to 76 feet bgs. If required, an additionalboring will be completed in this lagoon once the analytical results have been obtained andreviewed. The following is the depth that each of the borings were advanced to:LB1-A: (Northeast Tresspass); 6.5 feet bgs; bed rock contact.LB1-B: 6.5 feet bgs; bed rock contactLB2-A: (Northeast Canyon Lagoon); 8 feet bgs, trash found, and stopped at bedrock.LB2-B: 20 feet bgs, trash found, bed rock contact.LB3-A: (Eastern most western burn pit); 76 feet bgs, bed rock contact.LB4-A: (Western most western burn pit); 26 feet bgs, visual clean.LB4-B: 20 feet bgs, visual clean.

Apr.6: The cover material evaluation is scheduled to start on April 17, 2000.

Apr.7: The Northeast Canyon Waste Relocation project is 90% complete.

Apr.8: In the March 30, 2000, correspondence, Republic DUMPCo responded to Clark CountyPublic Works comments on the Eastern Bypass Channel Reconstruction Plan.


Respectfully,

File#: 999901-062/Order 7484




















Sep.5: EPA provided DUMPCo with some general comments regarding the revised Work Plan.DUMPCo is in the process of clarifying some the text based on EPA's comments.However, two possible points of misunderstanding were identified: The InducedPolarization (IP) method includes resistivity (See page 9, 3.4.1.5), and DUMPCo does not

4

feel that it is appropriate to restate objectives in the Sampling and Analysis Plan (SAP).The SAP is designed to describe methods.







Oct. 3: DUMPCo will place concrete around the down drains during the armoring of theConstruction demolition cell.


Oct.5. As indicated in the October 7,1999 teleconference, DUMPCo is evaluating the mostappropriate method(s) that should be used to determine soil loss from erosion. After aninitial review, it seems that there may be a problem with past reports that indicate that thecover at Sunrise contains high concentrations of gypsum. After a review of the EMCONexpansion report and Dynamac's report, there does not seem to be any formal analyticalresults to support comments made in those reports. DUMPCo has identified a localchemical testing laboratory that has the ability to test for these parameters. DUMPCo

5

will provide EPA with the results of this evaluation.









Nov.5: Four truck loads of proposed rock to be used as a cover source has been crushed.Samples of this material will be evaluated for potential use.Once the evaluation is complete, a report will be submitted to EPA for review.

6








Jan. 1: On December 21, 1999, Republic DUMPCo received comments back from EPAregarding waste relocation in the Northeast Canyon. As discussed, the January 7, 2000,submittal date for the additional information on the Northeast Canyon Relocation ofwaste has been extended to January 18, 2000.




Jan.5: On December 22, 1999, Republic DUMPCo received correspondence from EPAapproving the modified CSAMT lines.Since that time, Republic DUMPCo has decided to add additional CSAMT lines. Please

7

find enclosed with this correspondence a drawing with the additional CSAMT lines 10and 11.



Feb.l: In a January 19, 2000, correspondence from EPA, Republic DUMPCo receivedcomments on the Stormwater Inspection Report dated December 16, 1999. Along withproviding specific comments on the Stormwater Inspection Report, this correspondencerequires Republic DUMPCo to submit a monitoring plan no later than March 7, 2000.Republic DUMPCo is in the process of developing a Monitoring Plan.







Through verbal arrangements, Republic DUMPCo has transmitted to EPA a revised8

Sampling and Analysis Plan (SAP) based on EPA's comments (Final Revised SAP,February 13,2000).









Mar.5: In a March 1, 2000, correspondence, the EPA notified Republic DUMPCo that theapproached used for the Design Storm Event submitted on October 13, 1999, with theadditional information contained in the February 4, 2000, correspondence, wasappropriate. However, EPA did not feel that the 100-year storm event provided anacceptable level of confidence, and, therefore, approved only the use of the 200-yearstorm event.



9

Mar.8: In a March 3, 2000, correspondence, SCS on the behalf of Republic DUMPCo, providedEPA with an addendum to the Eastern By-Pass Channel Reconstruction Interim Action toaddress EPA's comments. As indicated in the correspondence, Republic DUMPCo iswaiting on approval and/or comments from Clark County Public Works and EPA toinitiate this Interim Action, Clark County Public Works received a copy of these planson February 23, 2000.


10

May 12, 2000


Dear Ms. Trujillo:

RE: Monthly Progress Report - May, 2000Order RCRA 7003-09-99-0005NOV/Order CWA-309-9-99-14


Current Monthly Progress ReportRepublic DUMPCo continues to make progress in completing the tasks outlined in the WorkPlan even though site conditions have proven to be very difficult. The methods required toobtain representative samples in order to appropriately characterize the site, have caused anumber of problems including breaking samplers and distroying drill bits.

May.l: The exploratory borings were started on March 13, 2000. The following is the status ofthese exploratory borings:

GH-1 A: Stopped at 102 feet below ground surface (bgs) at bed rock contact, and amonitoring well was installed. In the process of evaluating geological and geophysicaldata in order to propose the next boring at this location.

GH-2A: Encountered water at 185 bgs, and stopped drilling at 215 feet bgs at a confiningunit. However, after evaluating the geophysical log, and the boring log, we think that theboring was advanced through a confining unit around 190 feet bgs. Two nested wells arebeing installed to verify this as discussed with EPA.



GH-3 A: A Confining unit was encountered and drilling was stopped at 213 feet bgs, atemporary casing was installed, and the bore hole was geophysically logged. No waterhas been found in this boring. Unless this bore hole yields more than 2-3 gallons perhour, this boring will be sealed off, and advanced further.

GH-4A: Drilling resumed at 52 feet bgs on May 11, 2000.

GH-5 A: This exploratory bore hole is in the process of being sealed off at the 64 feet bgs.The seal should be completed by Monday, May 15, 2000.

GH-6B:This exploratory bore hole was stopped at 203 bgs due to a confining unit. A drilland drive rig is needed to set a 14 inch casing to this depth in order to seal off thisconfining unit. This is expected to be started on Tuesday, May 16, 2000.

GH-7A:This exploratory boring was advanced to 165 feet bgs, and was stopped becauseit was too unconsolidated to air core, and too deep to auger/sample. Once the drill anddrive is done at GH-6B, drilling will continue atGH-7A

May.2: The lagoon borings have been completed, and the analytical results were included in aMay 10, 2000, correspondence to EPA. Republic DUMPCo has proposed not to drill theother boring in LB3 because of the depth.

May.3: The Northeast Canyon Waste Relocation project is 95% complete.

May.4: The cover material evaluation is under way. At least 14 test pit/trenches have beencompleted, a total of 140 shallow borings, and 106 shallow boring locations have beencompleted. (Note: because of the unique site conditions, where the probe met refusal,more than one shallow boring has been needed in order to advance the sample probethrough the entire cover) A number of samplers have been broken. Based on EPArequest to find a faster method for obtaining geotechnical samples of the cover,geotechincial samples are no longer being obtained until EPA approves Republic'sproposed method of trenching.

May.5: Republic DUMPCo is obtaining a final bond estimate in order to comply with ClarkCounty Public Work's request for bonding this project.


Respectfully

Vice Presi

AG/tg

File#: 999901-062/Order 7484





















4










Oct.5. As indicated in the October 7,1999 teleconference, DUMPCo is evaluating the mostappropriate method(s) that should be used to determine soil loss from erosion. After aninitial review, it seems that there may be a problem with past reports that indicate that thecover at Sunrise contains high concentrations of gypsum. After a review of the EMCONexpansion report and Dynamac's report, there does not seem to be any formal analyticalresults to support comments made in those reports. DUMPCo has identified a localchemical testing laboratory that has the ability to test for these parameters. DUMPCo

5











6


Dec. 1: Formal approval of portions of the November 2, 1999, revised Work Plan was obtainedon December 7, 1999.











7




Feb.l: In a January 19, 2000, correspondence from EPA, Republic DUMPCo receivedcomments on the Stormwater Inspection Report dated December 16,1999. Along withproviding specific comments on the Stormwater Inspection Report, this correspondencerequires Republic DUMPCo to submit a monitoring plan no later than March 7, 2000.Republic DUMPCo is in the process of developing a Monitoring Plan.







Through verbal arrangements, Republic DUMPCo has transmitted to EPA a revised8

Sampling and Analysis Plan (SAP) based on EPA's comments (Final Revised SAP,February 13, 2000).












9



Apr. 1: The exploratory borings were started on March 13, 2000. The following is the status ofthese exploratory borings:GH1-A: Stopped at 102 feet below Ground Surface (bgs); bed rock contact.GH2-A: Stopped at 75 feet bgs; confining unit.GH3-A: Stopped at 43 feet bgs; confining unit.GH4-A: Stopped at 50 feet bgs; confining unit.GH5-A: Stopped at 64 feet bgs; confining unit.GH6-B: Stopped at 203 feet bgs; confining unit.


Apr. 3: The data from the other IP lines is currently being evaluated to determine the nextappropriate borings for the other borings. This information along with RepublicDUMPCo's recommendations will be forwarded to EPA for their evaluation andapproval.


Apr.5: The borings in the lagoons have been completed. Two borings were completed in each ofthe four lagoons, except for lagoon number 3, the most eastern of the western burn pits.The initial boring in this lagoon was advanced to 76 feet bgs. If required, an additionalboring will be completed in this lagoon once the analytical results have been obtained andreviewed. The following is the depth that each of the borings were advanced to:LB1-A: (Northeast Tresspass); 6.5 feet bgs; bed rock contact.

10

LB1-B: 6.5 feet bgs; bed rock contactLB2-A: (Northeast Canyon Lagoon); 8 feet bgs, trash found, and stopped at bedrock.LB2-B: 20 feet bgs, trash found, bed rock contact.LB3-A: (Eastern most western burn pit); 76 feet bgs, bed rock contact.LB4-A: (Western most western burn pit); 26 feet bgs, visual clean.LB4-B: 20 feet bgs, visual clean.

Apr,6: The cover material evaluation is scheduled to start on April 17, 2000.


Apr. 8: In the March 30, 2000, correspondence, Republic DUMPCo responded to Clark CountyPublic Works comments on the Eastern Bypass Channel Reconstruction Plan.

11

llrfem

June 13,2000


Dear Ms. Trujillo:

RE: Monthly Progress Report - June, 2000Order RCRA 7003-09-99-0005NOV/Order CWA-309-9-99-14

As required by the above referenced RCRA Order, specifically VI number 3 (page 9 of 22), thefollowing is the monthly progress report. Attachment: I to the monthly progress report containspast monthly progress items. The progress report items are numbered with the first three lettersof the month of the report that the item appeared. This months items are:

Current Monthly Progress ReportRepublic DUMPCo continues to make progress in completing the tasks outlined in the WorkPlan. Currently, the only drilling methods approved in unconsolidated alluvial materials arepercussion hammer advancement and Sonic drilling. A Sonic drill rig is has been schedule toarrive around July 1, 2000.

June. 1: The exploratory borings were started on March 13, 2000. The following is the status ofthese exploratory borings:

GH-1 A: Stopped at 102 feet below ground surface (bgs) at bed rock contact, and amonitoring well was installed.

GH-1B: This borehole \\as stopped at 425 feet bgs and will be abandoned. A sonic drillrig will advance another boring next to this location.

GH-2A: A 2-inch and a 4-inch monitoring well were installed in this borehole which wasadvanced to a total depth of 215 feet bgs. Water has been measured at 197 feet bgs in the2-inch, and 194 feet bgs in the 4-inch.

1


1 MADE WITH RECYCLED F%PER

GH-3A: This boring was advanced to 213 feet bgs and will be abandoned.

GH-3B: This new boring was advanced next to 3A, and it has been advanced to 207 feetbgs to a confining zone. A permanent casing needs to be installed.

GH-4A: This boring was advanced to 295 feet bgs. Water has been measure at 189 feetbgs.

GH-4B: This new boring was advanced next to GH-4A to determine the water bearingzone. This boring has been advanced to 190 feet bgs. Will wait to determine if water isfound in this boring before advancing further.

GH-5A: A monitoring well has been installed at this location at 192.5 feet bgs. Thismonitoring well has been developed, and the water level has been measured at 171 feetbgs.

GH-6B: This exploratory bore hole was stopped at 203 bgs due to a confining unit. A14-inch casing needs to be set in order to seal off this confining unit.

GH-7A: This exploratory boring was advanced to 185 feet bgs, and will be abandoned.The percussion hammer drilling method could not advance for fear of notbeing able to remove casing from formation. A Sonic drill rig will advancea new boring next to this boring.

June.2: The Northeast Canyon Waste Relocation project is 95% complete.

June.3: The cover material evaluation is almost complete. A total of 568 locations have beencompleted requiring a total of 657 shallow borings. Landfill gas probes are currentlybeing installed.

June.4: Waste Limit Determination - Further field verifications and data interpretations are beingcompleted to finalize the waste boundary line.


Respectfully,

Alan GaddyVice Presidei

AG/tg

File#: 999901-062/Order 7484





















4






Oct.l: EPA has verbally approved moving forward with providing EPA with constructiondrawings and specifications for blasting the south end of the Eastern Bypass channel, andarmoring of landfill cell below the drop off structure. However, EPA made it clear thatthis structural modification may not be the final solution to the drainage in this area. (SeeInterim Action Report).




Oct.5. As indicated in the October 7, 1999 teleconference, DUMPCo is evaluating the mostappropriate method(s) that should be used to determine soil loss from erosion. After aninitial review, it seems that there may be a problem with past reports that indicate that thecover at Sunrise contains high concentrations of gypsum. After a review of the EMCONexpansion report and Dynamac's report, there does not seem to be any formal analyticalresults to support comments made in those reports. DUMPCo has identified a localchemical testing laboratory that has the ability to test for these parameters. DUMPCo

5











6


Dec. 1: Formal approval of portions of the November 2, 1999, revised Work Plan was obtainedon December 7, 1999.











7











Through verbal arrangements, Republic DUMPCo has transmitted to EPA a revised

Sampling and Analysis Plan (SAP) based on EPA's comments (Final Revised SAP,February 13,2000).












9

Mar. 8: In a March 3, 2000, correspondence, SCS on the behalf of Republic DUMPCo, providedEPA with an addendum to the Eastern By-Pass Channel Reconstruction Interim Action toaddress EPA's comments. As indicated in the correspondence, Republic DUMPCo iswaiting on approval and/or comments from Clark County Public Works and EPA toinitiate this Interim Action. Clark County Public Works received a copy of these planson February 23, 2000.






Apr.5: The borings in the lagoons have been completed. Two borings were completed in each ofthe four lagoons, except for lagoon number 3, the most eastern of the western burn pits.The initial boring in this lagoon was advanced to 76 feet bgs. If required, an additionalboring will be completed in this lagoon once the analytical results have been obtained andreviewed. The following is the depth that each of the borings were advanced to:LB1-A: (Northeast Tresspass); 6.5 feet bgs; bed rock contact.

10

LB1-B: 6.5 feet bgs; bed rock contactLB2-A: (Northeast Canyon Lagoon); 8 feet bgs, trash found, and stopped at bedrock.LB2-B: 20 feet bgs, trash found, bed rock contact.LB3-A: (Eastern most western burn pit); 76 feet bgs, bed rock contact.LB4-A: (Western most western bum pit); 26 feet bgs, visual clean.LB4-B: 20 feet bgs, visual clean.







GH-3A: A Confining unit was encountered and drilling was stopped at 213 feet bgs, atemporary casing was installed, and the bore hole was geophysically logged. No waterhas been found in this boring. Unless this bore hole yields more than 2-3 gallons perhour, this boring will be sealed off, and advanced further.


GH-5A: This exploratory bore hole is in the process of being sealed off at the 64 feet bgs.The seal should be completed by Monday, May 15, 2000.



11




May. 5: Republic DUMPCo is obtaining a final bond estimate in order to comply with ClarkCounty Public Work's request for bonding this project.

12

July 13,2000


Dear Ms. Trujillo:

RE: Monthly Progress Report - July, 2000Order RCRA 7003-09-99-0005NOV/Order CWA-3 09-9-99-14


Current Monthly Progress ReportRepublic DUMPCo continues to make progress in completing the tasks outlined in the WorkPlan. Currently, the only drilling methods approved for borehole advancement in unconsolidatedalluvial materials are percussion hammer advancement and Sonic drilling. The Sonic Rig(GP300 SR) arrived on site on July 5, 2000. Five drill rigs are on site advancing borholes,setting casings, and/or installing wells. These include the following: 2 Percussion Hammer(API00), 1 drill and drive (T3W), 1 air rotary (B90), and a sonic (GP300 SR) drill rigs.

July.l: The exploratory borings were started on March 13, 2000. The following is the status ofthese exploratory borings:


GH-1B: This borehole was stopped at 425 feet bgs and will be abandoned. A sonic drillrig will advance another boring next to this location.

GH-1C: The sonic drill rig has advanced this boring to 117' bgs where the sonic's drillstring broke. The drill string has been removed from the boring. This boring needs to be

1


1 MADE WITH RECYCLED PAPER

reamed out to 117' bgs before advancing further.


GH-2B: A 4-inch monitoring well has been installed in this boring which was advancedto a total depth of 209.5' bgs. Water has been measured at 204' bgs.

GH-2C: A 4-inch monitoring well has been installed in the borehole which was advancedto a total depth of 230' bgs. Water has been measured at 220' bgs.

GH-3A: This boring has been advanced to 213' bgs. Water was found, but after reamingout this boring, the boring caved in. An appropriate method needs to be approved tokeep the boring open in order to set a monitoring well.

GH-3B: This boring has been advanced to 247' bgs. Water has was found, but afterreaming out this boring, the boring caved in. An appropriate method needs to beapproved to keep this boring open in order to properly set a casing seal to advance thisboring further.

GH-4A: This boring was advanced to 295 feet bgs. Water has been measure at 189 feetbgs. A neutron log needs to be completed in this boring in order to propose the mostappropriate action for this boring.

GH-4B: This boring has been advanced to 205 feet bgs. Water has been measured at 188'bgs. A neutron log needs to be completed in this boring in order to propose the mostappropriate action for this boring.


GH-5B3: This boring has been advanced to 412' bgs. A seal casing was set to 412' bgs,but there are concerns regarding the setting of this seal. The condition of the seal needsto be evaluated. Based on out come of this evaluation, this boring could either beadvanced further, the seal casing reset, or the boring may be abanoned.

GH-5C: This boring has been advanced to 154' bgs. Water has been measured at146.2" bgs. A monitoring well needs to be installed in this boring.

GH-6B: This boring has been advanced to 227' bgs. Water has been measured at 208'bgs. A monitoring well needs to be installed in this boring.

GH-7A: This boring was advanced to 185 feet bgs, and will be abandoned. The2

percussion hammer drilling method could not advance for fear of notbeing able to remove casing from formation. A Sonic drill rig will advancea new boring next to this boring.

GH-7B: This boring has been advanced to 97' bgs.

GH-11 A: This boring has been advanced to 226' bgs, where water was encountered.Based on the recharge rate being less than 2 gallons per hour, this boring was sealed andcased off, and is being advanced further.

GH-12A: This boring has been advanced to 252.5' bgs. Water has been measured at207.5' bgs. A monitoring well needs to be installed.

GH-12B: This boring is currently at 143' bgs.

GH-13 A: This boring was advanced to 184.5' bgs. The recharge rate in this boring wasless than 2 gallons per hour. This boring will be sealed and cased off in order to advancefurther.

July.3: The Northeast Canyon Waste Relocation project is 100% complete. Some additionalwork is being completed in this area to ensure that there is adequate cover until a finalmanagement plan has been approved.

July.3: The field work for the cover material evaluation is complete. The geotechnical samples,landfill gas samples, and waste samples are being processed. As the analytical iscompleted, copies are being provided to EPA.

July.4: Waste Limit Determination: A waste boundary delineation map was provided to EPA onJune 30, 2000. This waste limit map included the waste limits for all areas except for thecenter of the landfill area around the main stockpile. The IP lines that were completedover this area are being interpreted to help identify the waste boundary in this area.

July.5: Stormwater Pollution Prevention Plan (SWPPP): A draft SWPPP was provided to EPAon June 23, 2000. Republic is moving ahead with obtaining the additional information inorder to update the draft SWPPP as outline in the draft SWPPP.

July.6: Eastern Drop Off Channel Reconstruction: The plans have all been approved, and thefinal application has been provided to the Clark County Flood Control District. Republicis in the process of selecting a contractor to do the work.


Respectfi

AlanVice Preside:

AG/tg

File#: 999901-062/Order 7484











June 11, 1999.4. On July 16,1999, DUMPCo submitted to EPA a Sunrise Landfill Release Report that


5. EPA's August 2,1999, comments on the "Work Plan" have been received and reviewed.Based on these comments, Republic DUMPCo (DUMPCo) requested an extensionfor the submittal of the revised work plan from August 16, 1999 to August 25, 1999.








5










Oct. 5. As indicated in the October 7, 1999 teleconference, DUMPCo is evaluating the mostappropriate method(s) that should be used to determine soil loss from erosion. After aninitial review, it seems that there may be a problem with past reports that indicate that thecover at Sunrise contains high concentrations of gypsum. After a review of the EMCONexpansion report and Dynamac's report, there does not seem to be any formal analyticalresults to support comments made in those reports. DUMPCo has identified a localchemical testing laboratory that has the ability to test for these parameters. DUMPCo

6











7








Jan. 1: On December 21,1999, Republic DUMPCo received comments back from EPAregarding waste relocation in the Northeast Canyon. As discussed, the January 7, 2000,submittal date for the additional information on the Northeast Canyon Relocation ofwaste has been extended to January 18,2000.


Jan.3: Republic DUMPCo has received a Stormwater General Permit (GNV0022233-20553)from the Nevada Division of Environmental Protection. The Authorization date of thePermit is indicated as being December 16,1999.


Jan.5: On December 22, 1999, Republic DUMPCo received correspondence from EPAapproving the modified CSAMT lines.Since that time, Republic DUMPCo has decided to add additional CSAMT lines. Pleasefind enclosed with this correspondence a drawing with the additional CSAMT lines 10

8

and 11.



Feb. 1: In a January 19, 2000, correspondence from EPA, Republic DUMPCo receivedcomments on the Stormwater Inspection Report dated December 16,1999. Along withproviding specific comments on the Stormwater Inspection Report, this correspondencerequires Republic DUMPCo to submit a monitoring plan no later than March 7, 2000.Republic DUMPCo is in the process of developing a Monitoring Plan.







Through verbal arrangements, Republic DUMPCo has transmitted to EPA a revisedSampling and Analysis Plan (SAP) based on EPA's comments (Final Revised SAP,

9

February 13,2000).






Mar. 2: The General Waste Removal Work Plan was modified to address EPA March 14, 2000,comments (Revised Version Dated: February 24, 2000).






10


Mar. 9: In a March 6, 2000, correspondence, as requested by EPA, Republic DUMPCo providedEPA with a Stormwater Monitoring Plan.

Apr.l: The exploratory borings were started on March 13, 2000. The following is the status ofthese exploratory borings:GH1-A: Stopped at 102 feet below Ground Surface (bgs); bed rock contact.GH2-A: Stopped at 75 feet bgs; confining unit.GH3-A: Stopped at 43 feet bgs; confining unit.GH4-A: Stopped at 50 feet bgs; confining unit.GH5-A: Stopped at 64 feet bgs; confining unit.GH6-B: Stopped at 203 feet bgs; confining unit.


Apr,3: The data from the other IP lines is currently being evaluated to determine the nextappropriate borings for the other borings. This information along with RepublicDUMPCo's recommendations will be forwarded to EPA for their evaluation andapproval.


Apr.5: The borings in the lagoons have been completed. Two borings were completed in each ofthe four lagoons, except for lagoon number 3, the most eastern of the western burn pits.The initial boring in this lagoon was advanced to 76 feet bgs. If required, an additionalboring will be completed in this lagoon once the analytical results have been obtained andreviewed. The following is the depth that each of the borings were advanced to:LB1-A: (Northeast Tresspass); 6.5 feet bgs; bed rock contact.LB1-B: 6.5 feet bgs; bed rock contactLB2-A: (Northeast Canyon Lagoon); 8 feet bgs, trash found, and stopped at bedrock.LB2-B: 20 feet bgs, trash found, bed rock contact.

11

LB3-A: (Eastern most western burn pit); 76 feet bgs, bed rock contact.LB4-A: (Western most western burn pit); 26 feet bgs, visual clean.LB4-B: 20 feet bgs, visual clean.












May.2: The lagoon borings have been completed, and the analytical results were included in aMay 10, 2000, correspondence to EPA. Republic DUMPCo has proposed not to drill the

12

other boring in LB3 because of the depth.




June.l: The exploratory borings were started on March 13, 2000. The following is the status ofthese exploratory borings:





GH-3B: This new boring was advanced next to 3 A, and it has been advanced to 207 feetbgs to a confining zone. A permanent casing needs to be installed.




13






14

BtJrtem

August 15,2000


Dear Ms. Trujillo:

RE: Monthly Progress Report - August, 2000Order RCRA 7003-09-99-0005NOV/Order CWA-309-9-99-14

As requin-d by the above referenced RCRA Order, specifically VI number 3 (page 9 of 22), thefollowing is the monthly progress report. Attachment I to the monthly progress report containspast trxmthly progress items. The progress report items are numbered with the first three lettersof tilt month of the report that the item appeared. This months items are:

Current Monthly Progress ReportRepublic DUMPCo continues to make progress in completing the tasks outlined in the WorkPlan. Currently, the only two drilling methods approved for borehole advancement inunconsolidated alluvial materials are percussion hammer advancement and Sonic drilling. TheSonic Rig (GP300 SR) arrived on site on July 5, 2000. Both drilling methods have experiencedproblems. Four drill rigs are on site advancing borholes, setting casings, and/or installing wells.These include the following: 2 Percussion Hammer (API000), 1 drill and drive (T3W), and asonic (GP300 SR) drill rigs. A third drilling method for borehole advancement (Barber RigDR40) is currently being proposed, and is also on site.

Obtaining the sample quality prescribed by EPA deeper than 400' bgs is proving to be verydifficult and slow with the above two approved methods. Both the API000 and the Sonic areexperiencing problems at these depths. The attached correspondence from GES outlines some ofthese problems and provides for another drilling and sampling method at these depths. Republicbelieves that this additional method will speed up the hydrogeological investigation withoutcompromising sample quality.

Aug.l: The exploratory borings were started on March 13, 2000. The following is the status ofthese exploratory borings:

1


I MADE WITH RECYCLED WPEfl

GH-1 A: Stopped at 102 feet below ground surface (bgs) at bed rock contact, and amonitoring permanent well has been installed.

GH-1B: This borehole was stopped at 425 feet bgs. A sonic drill rig will advance anotherboring next to this location.

GH-1C: The sonic drill rig has advanced this boring to 117' bgs where the sonic's drillstring broke. The drill string has been removed from the boring. This boring has beenreamed out to 117' bgs.


GH-2B: A 4-inch monitoring well has been installed in this boring which was advancedto a total depth of 209.5' bgs. Water has been measured at 204' bgs. A monitoring wellhas been installed.

GH-2C: This boring was advanced to 230' bgs, and water was encountered measured at220' bgs. Since the recharge rate was less than 2 gallons per hour, this boring was sealedand cased off at 230' bgs. However, it was determined that the casing was not sealedproperly, and this boring will be abandoned.

GH-2C2: This boring was advanced to 262' bgs, and a monitoring well has beeninstalled. Water has been measured at 216' bgs.

GH-3A: This boring has been advanced to 213' bgs. Water was found, but after reamingout this boring, the boring caved in. This boring will be abandoned.

GH-3B: This boring was advanced to 247' bgs. Water has was found, but after reamingout this boring, the boring caved in. This boring will be abandoned.

GH-4A: This boring was advanced to 295 feet bgs. Water has been measure at 189 feetbgs. A neutron log has been completed in this boring. The data for this boring is beingevaluated.

GH-4B: This boring has been advanced to 205 feet bgs. Water has been measured at 188'bgs. A neutron has been completed in this boring. The data for this boring is beingevaluated.


GH-5B3: This boring has been advanced to 412' bgs. A seal casing was set to 412' bgs,but there are concerns regarding the setting of this seal. The condition of the sealwas evaluated and determined to be defective.

GH-5C: This boring has been advanced to 154' bgs. Water has been measured at146.2" bgs. After reaming out this boring in order to install a monitoring well, the boringcaved in to 80' bgs.

GH-6B: This boring has been advanced to 227' bgs. Water has been measured at 208'bgs. A monitoring has been installed in this boring.

GH-7A: This boring was advanced to 185 feet bgs, and will be abandoned. Thepercussion hammer drilling method could not advance for fear of notbeing able to remove casing from formation.

GH-7B: This boring has been advanced to 452' bgs with the Sonic Rig. Water has beenencountered, but no confining unit has been identified.

GH-11 A: This boring has been advanced to 407' bgs, where water was encountered.Based on the recharge rate being greater than 3 gallons per hour, a monitoring well willbe installed.


GH-12B2: This boring is currently at 452' bgs, with a 14" conductor casing to 252' bgs,and needs a 10" casing set to 452' bgs before further advancement can take place.


Aug.2: The Northeast Canyon Waste Relocation project is 100% complete. Some additionalwork is being completed in this area to ensure that there is adequate cover until a finalmanagement plan has been approved.

Aug.3: The field work for the cover material evaluation is complete. The geotechnical samples,landfill gas samples, and waste samples are being processed. As the analytical iscompleted, copies will be provided to EPA. After comparing the boring locations withthe new waste limit delineation, the need for additional cover material samples wasidentified. These are currently being obtained.

Aug.4: Waste Limit Determination: A waste boundary delineation map was provided to EPA onJune 30, 2000. This waste limit map included the waste limits for all areas except for the

3

center of the landfill area around the main stockpile. The IP lines that were completedover this area are being interpreted to help identify the waste boundary in this area.

Aug.5: Stormwater Pollution Prevention Plan (SWPPP): A draft SWPPP was provided to EPAon June 23, 2000. Republic is moving ahead with obtaining the additional information inorder to update the draft SWPPP as outline in the draft SWPPP.

Aug.6: Eastern Drop Off Channel Reconstruction: The plans have all been approved, and thefinal application has been provided to the Clark County Flood Control District. Republicis in the process of selecting a contractor to do the work.


Respectfully,

(laflGaddVice Pres\

AG/tg

File#: 999901-062/Order 7484

Attachments: August 15, 2000, Correspondence From GESAttachment I - Past Monthly Progress Report Items





Mr. Clare Schmutz Ms. Sandy DotyClark County Health District S AIC625 Shadow Lane 5303 W. Oberlin Dr.Las Vegas, NV 89106 Denver, CO 80235














6










Oct. 5. As indicated in the October 7,1999 teleconference, DUMPCo is evaluating the mostappropriate method(s) that should be used to determine soil loss from erosion. After aninitial review, it seems that there may be a problem with past reports that indicate that thecover at Sunrise contains high concentrations of gypsum. After a review of the EMCONexpansion report and Dynamac's report, there does not seem to be any formal analyticalresults to support comments made in those reports. DUMPCo has identified a localchemical testing laboratory that has the ability to test for these parameters. DUMPCo

7



Oct.7: On August 31,1999, Harding Lawson Associates conducted perimeter landfill gasmonitoring at the Sunrise Landfill. No detectable levels of landfill gas was detected atthe perimeter of the Sunrise Landfill. (See the attached HLA report)







Nov. 5: Four truck loads of proposed rock to be used as a cover source has been crushed.Samples of this material will be evaluated for potential use.Once the evaluation is complete, a report will be submitted to EPA for review.

8


Dec.l: Formal approval of portions of the November 2,1999, revised Work Plan was obtainedon December 7, 1999.




Dec.5: EMCON started Geologic Mapping on December 9,1999, and the surface gas monitoringis scheduled to start on December 14,1999. CSAMT should be starting within a week.

Dec. 6: The initial review of the Design Drawings for the Eastern Bypass Channel revealedseveral technical errors. SCS is in the process of revising the design drawings.

Jan. 1: On December 21,1999, Republic DUMPCo received comments back from EPAregarding waste relocation in the Northeast Canyon. As discussed, the January 7, 2000,submittal date for the additional information on the Northeast Canyon Relocation ofwaste has been extended to January 18, 2000.





9

and 11.











10

February 13, 2000).









Mar. 5: In a March 1, 2000, correspondence, the EPA notified Republic DUMPCo that theapproached used for the Design Storm Event submitted on October 13,1999, with theadditional information contained in the February 4, 2000, correspondence, wasappropriate. However, EPA did not feel that the 100-year storm event provided anacceptable level of confidence, and, therefore, approved only the use of the 200-yearstorm event.


Mar. 7: On March 3, 2000, after verbal discussions and minor modifications, Republic DUMPCoreceived approval of the final sections of the Work Plan from EPA. The March 3, 2000,correspondence also required that the schedule for the Work Plan be updated once thefirst exploratory bore hole is completed, and after the completion of test pit/trenches andinitial shallow borings for cover material soil assessment.

11




Apr. 2: Additional IP lines have been run along the CSAMT lines over exploratory borings GH2-through GH6 to determine the extent of the confining unit. An additional boring atlocation 5 has been identified. A new exploratory boring was started at this location onApril 11, 2000. This recommendation along with the supporting data has been forwardedto EPA.




12













May .2: The lagoon borings have been completed, and the analytical results were included in aMay 10, 2000, correspondence to EPA. Republic DUMPCo has proposed not to drill the

13














14









GH-1C: The sonic drill rig has advanced this boring to 117' bgs where the sonic's drillstring broke. The drill string has been removed from the boring. This boring needs to bereamed out to 117' bgs before advancing further.




GH-3A: This boring has been advanced to 213' bgs. Water was found, but after reaming15

out this boring, the boring caved in. An appropriate method needs to be approved tokeep the boring open in order to set a monitoring well.








GH-7A: This boring was advanced to 185 feet bgs, and will be abandoned. Thepercussion hammer drilling method could not advance for fear of notbeing able to remove casing from formation. A Sonic drill rig will advancea new boring next to this boring.




16


GH-13A: This boring was advanced to 184.5' bgs. The recharge rate in this boring wasless than 2 gallons per hour. This boring will be sealed and cased off in order to advancefurther.






17

'Rug 15 00 01:2Dp p.2

GEOTECHNICAL &ENVIRONMENTALSERVICES, INC. Re:

PROVIDING• Geotechnical

Engineering• Construction

MaterialsTesting

• EnvironmentalSiteAssessments

• DrillingServices

August 15, 2000Project No. 98744D1

Mr. Alan GaddyRepublic Services of Southern Nevada770 East Sahara AvenueLas Vegas, Nevada 89104

Additional method for drilling and sampling, Sunrise Landfill HydrogeologicEvaluation, Clark County, Nevada

Dear Mr. Gaddy:

In a letter dated May 5, 2000, GES proposed an additional sampling method for useduring air core system drilling and sampling for recovering samples in softerunconsolidated material. In general, this sampling method consisted of utilizing a 1-3/4 inch diameter, 2-foot long Standard Penetration Split Spoon Sampler drivesampling methodology through the center of the core barrel on a wireline systemusing AW rod with 140 pound drive hammer.

This methodology has not yet been utilized. Current depth advancement is up to450-feet beneath ground surface (bgs). This 450-foot depth is beginning to exceedthe mechanical capabiiities of the AP-1000 percussion hammer drill rigs. Therefore,the purpose of this letter is to recommend using the above sampling technique inconjunction with the T3W air rotary drive casing drill rig that is currently on-siteperforming drill rig required support activities (reaming, conductor installation).

The T3W would utilize it's air rotary capabilities to advance an open center triconebit through which a Standard Penetration Split Spoon Sampler would be driven tocollect continues samples. This would continue until either split spoon refusal orsample recovery is less than 50 percent over a 5-foot interval. If you have anyquestions please feel free to call us at 365-1001.

Sincerely,Geotechnical & Environmental Services, Inc.

Daniel C. Burns, C.E.M.Project Managing Geologist

kmhDist: 1 faxed to addressee @ (702) 735-4523

1 original delivered to addressee1 cc faxed to Tom Gardner @ (702) 735-45231 cc faxed to David Faircloth @ (702) 431-31271 cc project file

756C W. Sahara Ave., Suite 101 Las Vegas, NV 89117(702)365-1001 • Fax (702) 341-7120

www.gesnevada.com

/•\jobs\98Jobs\93744\opent;ente

September 15.2000


Dear Ms. Trujillo:

RE: Monthly Progress Report - September, 2000Order RCRA 7003-09-99-0005NOV/Order CWA-309-9-99-14

As required by the above referenced RCRA Order, specifically VI number 3 (page 9 of 22), thefollowing is the morilhly progress report. Attachment I to the monthly progress report containspast monthly progress items. The progress report items are numbered with the first three lettersof the month of the report that the item appeared. This months items are:

Current Monthly Progress ReportRepublic DUMPCo continues to make progress in completing the tasks outlined in the WorkPlan. Currently, the oniy two drilling methods approved for borehole advancement inunconsolidated alluvial materials are percussion hammer advancement and Sonic drilling. TheSonic Rig (GP300 RS) arrived on site on July 5, 2000. Both drilling methods have experiencedproblems. Five drill rigs are on site advancing borholes, setting casings, and/or installing wells.These include the following: 1 Percussion Hammer (AP1000), 1 drill and drive (T3W), a sonic(GP300 RS), T4 W, and a DR40 Barber Rig.

Obtaining, the sanple quality prescribed by EPA deeper than 400' bgs has been difficult,however, the T4W reverse air drill rig with a quad drill bit seems to be obtaining good samples'below 400' bgs. No formal approval of this drilling and sampling method has been received.The T3W has been able to continuously core at GH-5B4.

Sep.]: The exploratory borings were started on March 13, 2000. The following is the status ofthese exploratory borings. It should be noted that when a monitoring well has beeninstalled and developed, the prefix for the location designation changes from GH to MW.This is reflected below. Furthermore, when a boring has been classified as being"abandoned," this means the boring as been plugged with bentonite and sealed. Once aboring as been classified in this progress report as being "abandoned," the boring will not

1



be included in the next months progress report.

MW-1 A: Stopped at 102 feet below ground surface (bgs) at bed rock contact, and amonitoring permanent well has been installed.


GH-1C: The sonic drill rig has advanced this boring to 252' bgs.

MW-2A: A 2-inch and a 4-inch monitoring well were installed in this borehole whichwas advanced to a total depth of 215 feet bgs. Water has been measured at 197 feet bgsin the 2-inch, and 195 feet bgs in the 4-inch on May 5, 2000. Current water levelmeasurements indicate that this boring is dry.

MW-2B: A 4-inch monitoring well has been installed in this boring which was advancedto a total depth of 209.5' bgs. Water has been measured at 204' bgs on June 7, 2000.Current water level measurements indicate that this boring is dry.

GH-2C: This boring was advanced to 230' bgs, and water was encountered and measuredat 220' bgs. Since the recharge rate was less than 2 gallons per hour, this boring wassealed and cased off at 230' bgs. However, it was determined that the casing was notsealed properly, and this boring has been abandoned.

MW-2C2: This boring was advanced to 262' bgs, and a monitoring well has beeninstalled. Water has been measured at 218' bgs.

GH-3A: This boring has been advanced to 213' bgs. Water was found, but after reamingout this boring, the boring caved in. This boring has been abandoned.

GH-3B: This boring was advanced to 247' bgs. Water was found, but after reaming outthis boring, the boring caved in. This boring has been abandoned.

GH-3C: Barber Rig has currently advanced to 195' bgs.

GH-4A: This boring was advanced to 295 feet bgs. Water has been measure at 189 feetbgs. A neutron log has been completed in this boring. A monitoring well has beeninstalled, and it needs to be developed.

GH-4B: This boring has been advanced to 606 feet bgs. The API000 can no longeradvance beyond this depth. Further advancement with a different drill rig is beingevaluated.

MW-5A: A monitoring well has been installed at this location at 192.5 feet bgs. Thismonitoring well has been developed, and the water level has been measured at 164 feet

2

bgs.

GH-5B3: This boring has been advanced to 412' bgs. A seal casing was set to 412' bgs,but there are concerns regarding the setting of this seal. The bond logging data indicatedthat the seal was defective. This boring will be abandoned.

GH-5B4: This boring has been advanced to 563' bgs. The T3W is currently continuouslycoring with air rotary.

MW-5C: This boring has been advanced to 154' bgs. Water has been measured at146.2" bgs. A monitoring well has been installed.

MW-6B: This boring has been advanced to 227' bgs. Water has been measured at 208'bgs. A monitoring has been installed in this boring.

GH-7A: This boring was advanced to 185 feet bgs, and has been abandoned.

GH-7B: This boring has been advanced to 597' bgs with the Sonic Rig. Sonic hasreached a maximum depth with the 5" casing. Water has been encountered, but noconfining unit has been identified. Waiting on response from BLM regarding locationapproval for this boring for further advancement.

GH-11 A: This boring has been advanced to 407' bgs, where water was encountered.Based on the recharge rate being greater than 3 gallons per hour, a monitoring well hasbeen installed.



GH-12C: This boring has been advanced to 1020 bgs as an exploratory boring using theT4W. No apprecable water zones have been encountered.

GH-13A: This boring was advanced to 477' bgs by the AP1000. The AP1000 could notadvance this boring beyone this depth. Need to evaluate a different drilling and samplingmethod in order to advance this boring further.

Sep.2: The Northeast Canyon Waste Relocation project is 100% complete. Some additionalwork is being completed in this area to ensure that there is adequate cover until a finalmanagement plan has been approved.

Sep.3: The field work for the cover material evaluation is complete. The geotechnical samples,3

landfill gas samples, and waste samples are being processed. As the analytical theanalytical data is produced and checked, copies will be provided to EPA.

Sep.4: Waste Limit Determination: A waste boundary delineation map was provided to EPA onJune 30, 2000. This waste limit map included the waste limits for all areas except for thecenter of the landfill area around the main stockpile. The IP lines that were completedover this area have been interpreted. A draft final waste limit map will be provided toEPA once the boundary in this area is ploted.

Sep.5: Stormwater Pollution Prevention Plan (SWPPP): A draft SWPPP was provided to EPAon June 23, 2000. Republic is moving ahead with obtaining the additional information inorder to update the draft SWPPP as outlined in the draft SWPPP.

Sep.6: An erosion and stability analysis was provided to EPA on August 31, 2000.

Sep.7: Eastern Drop Off Channel Reconstruction: The plans have all been approved, and the finalapplication has been provided to the Clark County Flood Control District. Republic is inthe process of selecting a contractor to do the work.


Respect

AVice President

AG/tg

File#: 999901-062/Order 7484

Attachments: August 15, 2000, Correspondence From GESAttachment I - Past Monthly Progress Report Items

CC: Mr. David Basinger (WTR - 7) Water Division Mr. Mark Morse, Field ManagerU.S. Environmental Protection Agency (Attention: Mike Moran)75 Hawthorne Street Bureau of Land ManagementSan Francisco, CA 94105 - 3901 4765 Vegas Valley Drive

Las Vegas, NV 89108

Mr. Dave Emme, Chief Mr. John SchlegelBureau of Waste Management Clark County Comprehensive Plan.Nevada Division of Environmental Protection 500 S. Grand Central Pky333 W. Nye Lane, Room 138 Las Vegas, NV 89155-1745Carson City, NV 89706-0851

Mr. Clare Schmutz Ms. Sandy DotyClark County Health District SAIC625 Shadow Lane 5303 W. Oberlin Dr.Las Vegas, NV 89106 Denver, CO 80235


1. Tentative agreements have been reached on the access agreement for off-lease areas.2. RCRA Order Item b.l.(a-h) "Landfill Assessment Work Plan," was completed and

















Oct. 2: DUMPCo has received final approval for armoring the Construction Demolition Cell andDUMPCo is proceeding to construct. See Interim Action Report.



7

Oct.5. As indicated in the October 7, 1999 teleconference, DUMPCo is evaluating the mostappropriate method(s) that should be used to determine soil loss from erosion. After aninitial review, it seems that there may be a problem with past reports that indicate that thecover at Sunrise contains high concentrations of gypsum. After a review of the EMCONexpansion report and Dynamac's report, there does not seem to be any formal analyticalresults to support comments made in those reports. DUMPCo has identified a localchemical testing laboratory that has the ability to test for these parameters. DUMPCowill provide EPA with the results of this evaluation.





Nov. 1: On November 2, 1999, SCS Engineers, on the behalf of Republic DUMPCo, submitted toEPA the response to EPA's Draft Comments on the revised Work Plan.






Dec.l: Formal approval of portions of the November 2, 1999, revised Work Plan was obtainedon December 7,1999.








Jan.3: Republic DUMPCo has received a Stormwater General Permit (GNV0022233-20553)from the Nevada Division of Environmental Protection. The Authorization date of thePermit is indicated as being December 16,1999.

Jan.4: On December 16, 1999, EMCON conducted an evaluation of the existing stormwatercontrols at the Sunrise Landfill. All of their recommendations have been completed,

9

except for placing rip-rap at the outfalls from the Southern Flats and at the sediment basinbelow the upper flats southwestern down drain. The rip-rap should be in place by the endofJanauary.

Jan.5: On December 22,1999, Republic DUMPCo received correspondence from EPAapproving the modified CSAMT lines.Since that time, Republic DUMPCo has decided to add additional CSAMT lines. Pleasefind enclosed with this correspondence a drawing with the additional CSAMT lines 10and 11.








Feb.6: On February 14, 2000, EPA provided Republic DUMPCo with a limited approval of theGeneral Waste Removal Plan with Exhibit 1, Northeast Off-Lease Interim Action. Thelocation of the waste to be removed has been staked off. BLM has been on site to reviewthe area of waste removal. Republic DUMPCo will be sampling the waste on February

10

14, 2000, and will begin removal process as soon as the analytical results have beenreviewed.


Through verbal arrangements, Republic DUMPCo has transmitted to EPA a revisedSampling and Analysis Plan (SAP) based on EPA's comments (Final Revised SAP,February 13,2000).










11









Apr.5: The borings in the lagoons have been completed. Two borings were completed in each of12

the four lagoons, except for lagoon number 3, the most eastern of the western burn pits.The initial boring in this lagoon was advanced to 76 feet bgs. If required, an additionalboring will be completed in this lagoon once the analytical results have been obtained andreviewed. The following is the depth that each of the borings were advanced to:LB1-A: (Northeast Tresspass); 6.5 feet bgs; bed rock contact.LB1-B: 6.5 feet bgs; bed rock contactLB2-A: (Northeast Canyon Lagoon); 8 feet bgs, trash found, and stopped at bedrock.LB2-B: 20 feet bgs, trash found, bed rock contact.LB3-A: (Eastern most western burn pit); 76 feet bgs, bed rock contact.LB4-A: (Western most western burn pit); 26 feet bgs, visual clean.LB4-B: 20 feet bgs, visual clean.




May. 1: The exploratory borings were started on March 13, 2000. The following is the status ofthese exploratory borings:







13






June.l: The exploratory borings were started on March 13, 2000. The following is the status ofthese exploratory borings:





GH-3B: This new boring was advanced next to 3A, and it has been advanced to 207 feetbgs to a confining zone. A permanent casing needs to be installed.


14







June.4: Waste Limit Determination - Further field verifications and data interpretations arecompleted to finalize the waste boundary line.






15



GH-3A: This boring has been advanced to 213' bgs. Water was found, but after reamingout this boring, the boring caved in. An appropriate method needs to be approved tokeep the boring open in order to set a monitoring well.








GH-7A: This boring was advanced to 185 feet bgs, and will be abandoned. Thepercussion hammer drilling method could not advance for fear of notbeing able to remove casing from formation. A Sonic drill rig will advancea new boring next to this boring.

GH-7B: This boring has been advanced to 97' bgs.16













17













18










Aug.4: Waste Limit Determination: A waste boundary delineation map was provided to EPA onJune 30, 2000. This waste limit map included the waste limits for all areas except for thecenter of the landfill area around the main stockpile. The IP lines that were completedover this area are being interpreted to help identify the waste boundary in this area.


19


20

iKmtttarartce

October 16,2000


Dear Ms. Trujillo:

RE: Monthly Progress Report - October, 2000Order RCRA 7003-09-99-0005NOV/Order CWA-309-9-99-14


Current Monthly Progress ReportRepublic DUMPCo continues to make progress in completing the tasks outlined in the WorkPlan. Five drill rigs are on site advancing borholes, setting casings, and/or installing wells. Theseinclude the following: 1 Percussion Hammer (AP1000), 1 drill and drive (T3W), a sonic (GP300RS), T4W, and a DR40 Barber Rig.

Oct. 1: The exploratory borings were started on March 13, 2000. The following is the status ofthese exploratory borings. It should be noted that when a monitoring well has beeninstalled and developed, the prefix for the location designation changes from GH to MW.This is reflected below. Furthermore, when a boring has been classified as being"abandoned," this means the boring as been plugged with bentonite and sealed. Once aboring as been classified in this progress report as being "abandoned," the boring will notbe included in the next months progress report.



1







GH-3C: Barber Rig has currently advanced to 281' bgs at this location.


GH-4B: This boring has been advanced to 806' bgs. Geophysics is being completed inthis boring. Installation of a monitoring well is being evaluated.

MW-5A: A monitoring well has been installed at this location at 192.5 feet bgs. Thismonitoring well has been developed, and the water level has been measured at 164 feetbgs.

GH-5B3: This boring has been advanced to 412' bgs. A seal casing was set to 412' bgs,but there are concerns regarding the setting of this seal. The bond logging data indicatedthat the seal was defective. The bottom 200' of this boring has been abandoned using leftover concrete. This boring will be completely abandoned as more concrete is available.

GH-5B4: This boring has been advanced to 733' bgs. This boring may be advancedwhen another appropriate drill rig is available.

MW-5C: This boring has been advanced to 154' bgs. Water has been measured at146,2" bgs. A monitoring well has been installed.


GH-6C: This boring has been readmed out to 227' bgs for placement of 10 inchconductor casing. Will advance to 400' bgs for installation of monitoring well.

GH-7B: This boring has been advanced to 645' bgs with the Sonic Rig. Sonic hasreached a maximum depth with the 5" casing. Water has been encountered, but noconfining unit has been identified. When the appropriate drilling rig is available, thisboring will be advanced further in order to identify the confining unit.

GH-11 A: This boring has been advanced to 407' bgs, where water was encountered.Based on the recharge rate being greater than 3 gallons per hour, a monitoring well hasbeen installed. The monitoring well was installed with the new sand pack and slotscreens. This has eliminated 90% of the development problems.



GH-12C: This boring has been advanced to 1217' bgs as an exploratory boring using theT4W. Water zones were encountered, and geophysics has been completed.

GH-13A: This boring was advanced to 477' bgs by the AP1000. The AP1000 could notadvance this boring beyond this depth. Need to evaluate a different drilling and samplingmethod in order to advance this boring further.

GH-15 A: This boring has been advanced to 31' bgs with conductor casing. The T4Wwill advance this boring further.

Oct.2: The Northeast Canyon Waste Relocation project is 100% complete. Some additionalwork is being completed in this area to ensure that there is adequate cover until a finalmanagement plan has been approved. Waiting on final analytical results from AlphaAnalytical for stockpiled drill cuttings so that cuttings can be used to fill one area in theNortheast Canyon.

Oct.3: The field work for the cover material evaluation is complete. The geotechnical samples,landfill gas samples, and waste samples are being processed. EPA will receive a coverevaluation report on October 17, 2000.

Oct.4: Waste Limit Determination: A waste boundary delineation map was provided to EPA onJune 30, 2000. This waste limit map included the waste limits for all areas except for thecenter of the landfill area around the main stockpile. The IP lines that were completedover this area have been interpreted. After this evaluation of the IP lines, additionalconfirmation borings have been scheduled to be completed in this area.

Oct.5: Stormwater Pollution Prevention Plan (SWPPP): A draft SWPPP was provided to EPAon June 23, 2000. Republic is moving ahead with obtaining the additional information in

3

order to update the draft SWPPP as outlined in the draft SWPPP.

Oct.6: An erosion and stability analysis was provided to EPA on August 31, 2000.

Oct.7: Eastern Drop Off Channel Reconstruction: The plans have all been approved, and the finalapplication has been provided to the Clark County Flood Control District. Based on fieldcomments from EPA, this Interim Action has been put on hold.


Respectfully,

Alan GiddyVice President

AG/tg

File#: 999901-062/Order 7484










delivered to EPA and BLM on June 7,1999.3. CWA Order Task #19, 20, and 21 were competed and delivered to EPA and BLM on

June 11,1999.4. On July 16, 1999, DUMPCo submitted to EPA a Sunrise Landfill Release Report that


5. EPA's August 2, 1999, comments on the "Work Plan" have been received and reviewed.Based on these comments, Republic DUMPCo (DUMPCo) requested an extensionfor the submittal of the revised work plan from August 16,1999 to August 25, 1999.


7. In a letter dated August 6,1999, DUMPCo responded to EPA's comments regardinginterim stormwater control measures. DUMPCo is implementing these measures asoutlined in the letter






5










Oct.5. As indicated in the October 7, 1999 teleconference, DUMPCo is evaluating the mostappropriate method(s) that should be used to determine soil loss from erosion. After aninitial review, it seems that there may be a problem with past reports that indicate that thecover at Sunrise contains high concentrations of gypsum. After a review of the EMCONexpansion report and Dynamac's report, there does not seem to be any formal analyticalresults to support comments made in those reports. DUMPCo has identified a localchemical testing laboratory that has the ability to test for these parameters. DUMPCo

6










Nov. 5: Four truck loads of proposed rock to be used as a cover source has been crushed.Samples of this material will be evaluated for potential use.Once the evaluation is complete, a report will be submitted to EPA for review.

7


Dec.l: Formal approval of portions of the November 2,1999, revised Work Plan was obtainedon December 7, 1999.

Dec. 2: Republic DUMPCo has purchased a GPS system, and is in the process of mapping all ofthe Interim Actions (IA).










8

and 11.











9

February 13, 2000).












10








11




Apr. 8: In the March 30, 2000, correspondence, Republic DUMPCo responded to Clark CountyPublic Works comments on the Eastern Bypass Channel Reconstruction Plan.









May .2: The lagoon borings have been completed, and the analytical results were included in aMay 10, 2000, correspondence to EPA. Republic DUMPCo has proposed not to drill the

12














13













GH-3A: This boring has been advanced to 213' bgs. Water was found, but after reaming14

out this boring, the boring caved in. An appropriate method needs to be approved tokeep the boring open in order to set a monitoring well.








GH-7A: This boring was advanced to 185 feet bgs, and will be abandoned. Thepercussion hammer drilling method could not advance for fear of notbeing able to remove casing from formation. A Sonic drill rig will advancea new boring next to this boring,




15













16













17








Aug.4: Waste Limit Determination: A waste boundary delineation map was provided to EPA onJune 30, 2000. This waste limit map included the waste limits for all areas except for thecenter of the landfill area around the main stockpile. The IP lines that were completedover this area are being interpreted to help identify the waste boundary in this area.



Sep.l: The exploratory borings were started on March 13, 2000. The following is the status ofthese exploratory borings. It should be noted that when a monitoring well has been

18

installed and developed, the prefix for the location designation changes from GH to MW.This is reflected below. Furthermore, when a boring has been classified as being"abandoned," this means the boring as been plugged with bentonite and sealed. Once aboring as been classified in this progress report as being "abandoned," the boring will notbe included in the next months progress report.






GH-2C: This boring was advanced to 230' bgs, and water was encountered and measuredat 220' bgs. Since the recharge rate was less than 2 gallons per hour, this boring wassealed and cased off at 230' bgs. However, it was determined that the casing was notsealed properly, and this boring has been abandoned.


GH-3A: This boring has been advanced to 213' bgs. Water was found, but after reamingout this boring, the boring caved in. This boring has been abandoned.

GH-3B: This boring was advanced to 247' bgs. Water was found, but after reaming outthis boring, the boring caved in. This boring has been abandoned.

GH-3C: Barber Rig has currently advanced to 195' bgs.


GH-4B: This boring has been advanced to 606 feet bgs. The API000 can no longeradvance beyond this depth. Further advancement with a different drill rig is being

19

evaluated.


GH-5B3: This boring has been advanced to 412' bgs. A seal casing was set to 412' bgs,but there are concerns regarding the setting of this seal. The bond logging data indicatedthat the seal was defective. This boring will be abandoned.

GH-5B4: This boring has been advanced to 563' bgs. The T3W is currently continuouslycoring with air rotary.

MW-5C: This boring has been advanced to 154' bgs. Water has been measured at146.2" bgs. A monitoring well has been installed.


GH-7A: This boring was advanced to 185 feet bgs, and has been abandoned.

GH-7B: This boring has been advanced to 597' bgs with the Sonic Rig. Sonic hasreached a maximum depth with the 5" casing. Water has been encountered, but noconfining unit has been identified. Waiting on response from BLM regarding locationapproval for this boring for further advancement.

GH-11 A: This boring has been advanced to 407' bgs, where water was encountered.Based on the recharge rate being greater than 3 gallons per hour, a monitoring well hasbeen installed.



GH-12C: This boring has been advanced to 1020 bgs as an exploratory boring using theT4W. No apprecable water zones have been encountered.

GH-13A: This boring was advanced to 477' bgs by the AP1000. The AP1000 could notadvance this boring beyone this depth. Need to evaluate a different drilling and samplingmethod in order to advance this boring further.

Sep.2: The Northeast Canyon Waste Relocation project is 100% complete. Some additional20

work is being completed in this area to ensure that there is adequate cover until a finalmanagement plan has been approved.

Sep.3: The field work for the cover material evaluation is complete. The geotechnical samples,landfill gas samples, and waste samples are being processed. As the analytical theanalytical data is produced and checked, copies will be provided to EPA.

Sep.4: Waste Limit Determination: A waste boundary delineation map was provided to EPA onJune 30, 2000. This waste limit map included the waste limits for all areas except for thecenter of the landfill area around the main stockpile. The IP lines that were completedover this area have been interpreted. A draft final waste limit map will be provided toEPA once the boundary in this area is ploted.

Sep.5: Stormwater Pollution Prevention Plan (SWPPP): A draft SWPPP was provided to EPAon June 23, 2000. Republic is moving ahead with obtaining the additional information inorder to update the draft SWPPP as outlined in the draft SWPPP.

Sep.6: An erosion and stability analysis was provided to EPA on August 31, 2000.

Sep.7: Eastern Drop Off Channel Reconstruction: The plans have all been approved, and the finalapplication has been provided to the Clark County Flood Control District. Republic is inthe process of selecting a contractor to do the work.

21

22

REPUBLIC DUMPCO13550 N U. S. HIGHWAY 93

LAS VEGAS, NEVADA 89124(702) 644-4210

Fax: (702) 644-3028

FAX TRANSMISSION COVER SHEET

To:

Re: v

Sender:

YOU SHOULD RECEIVE 5 PAGE (S), INCLUDING THIS COVER SHEET. IF YOU DONOT RECEIVE ALL THE PAGES, PLEASE CALL (702) 644-42 10.

REPUBLIC DUMPCO13550 N U.S. HIGHWAY 93

LAS VEGAS, NEVADA 89124(702) 644-4210

Fax: (702) 644-3028

FAX TRANSMISSION COVER SHEET

Date: OcA ^ W ,>(

To;

Fax:

Re: V-re porSender:

YOU SHOULD RECEIVE 5"pAGE(S), INCLUDING THIS COVER SHEET. IF YOU DONOT RECEIVE ALL THE PAGES, PLEASE CALL (702) 644-4210.

llrfem

November 15,2000

Ms. Susanna Trujillo, Project CoordinatorU.S. EPA Region IX75 Hawihorne Street (WST-7)San Francisco, CA 94105-3901

DeorMs Tnijil lo

RE: Monthly Progress Report - November, 2000Order RCRA 7003-09-99-0005NOV/Order CWA-309-9-99-14

As required by the above referenced RCRA Order, specifically VI number 3 (page 9 of 22), thefollowing is the monthly progress report. Attachment I containing past monthly activites hasbesn deleted as a step in .conservation of natural resources. If you should require a copy of pastmonthly activities, please contact rne. The progress report items are numbered with the first threeletters of the month. This month's items are as follows:

Current Monthly Progress ReportRepublic DUMPCo continues to make progress in completing the tasks outlined in the WorkPlan Five drill rigs are on site advancing boreholes, setting casings, and/or installing wells.These include the following: 1 Percussion Hammer (API000), 2 drill and drives (T3W & T4W),a sonic (GP300 RS), and a DR40 Barber Rig.

Nov.l: The exploratory borings were started on March 13, 2000. The following is the status ofthese exploratory borings. It should be noted that when a monitoring well has beeninstalled, the prefix for the location designation changes from GH to MW, and when themonitoring well has been developed, the prefix will be changed to MWC. This isreflected below. Furthermore, when a boring has been classified as being "abandoned,"this means the boring as been plugged with bentonite and sealed. Once a boring as beenclassified in this progress report as being "abandoned," the boring will not be included inthe next months progress report.

MW-1 A: Stopped at 102 feet below ground surface (bgs) at bed rock contact, and amonitoring well has been installed. (No water has been detected in this monitoring wellsince installation).

I


1 MADE WITH RECYCLED PAPER

GH-1B: This borehole was stopped at 425 feet bgs. This boring will be abandoned.

GH-1C: The sonic drill rig has advanced this boring to 682' bgs. This boring will bereamed out and a well installed with the T3W when it is available.

MW-2A: A 2-inch and a 4-inch monitoring well were installed in this borehole whichwas advanced to a total depth of 215 feet bgs. Water has been measured at 197 feet bgsin the 2-inch, and 195 feet bgs in the 4-inch on May 5, 2000. Current water levelmeasurements indicate that the 4-inch is dry.


MW-2C2: This boring was advanced to 263' bgs, and a 2-inch and 4-inch monitoringwell were installed. Water has been measured at 221' and 220' bgs respectively.

GH-2D: Installed temporary surface casing with the AP1000 to 20' bgs. Will advancethis boring as an exploratory boring with the T4W when it is available.

GH-3C: Barber Rig has currently advanced to 482' bgs at this location. Will install a sealto protect this zone and advance boring further.

GH-3D: This boring has been advanced to 813 feet bgs as an exploratory boring with theT4W. Water zones were encountered, and geophysics has been completed. This boringwill be abandoned with bentonite.

MW-4A: This boring was advanced to 295 feet bgs. Water has been measure at 185 feetbgs. A neutron log has been completed in this boring. A monitoring well has beeninstalled, and it needs to be developed.

GH-4B: This boring has been advanced to 806' bgs. Geophysics has been completed,and a monitoring well will be installed.



GH-5B4: This boring has been advanced to 733' bgs. This boring will be advanced when2

another appropriate drill rig is available.

MW-5C: This boring has been advanced to 154' bgs. Water has been measured at146.2' bgs. A monitoring well has been installed.

MW-6B: This boring has been advanced to 227' bgs. Water has been measured at 208'bgs. A monitoring well has been installed in this boring.

GH-6C: This boring has been reamed out to 227' bgs for placement of 10 inch conductorcasing. Will advance further for installation of a monitoring well.


GH-9A: This boring has been advanced to 329 feet bgs. This boring is currently beingadvanced with the Sonic drill rig.

MW-11 A: This boring has been advanced to 407' bgs, where water was encountered.Based on the recharge rate being greater than 3 gallons per hour, a monitoring well hasbeen installed. The monitoring well was installed with new sand pack and slottedscreens. This has eliminated 90% of the development problems.

MW-1 IB: This boring has been advanced to 259' bgs, and a monitoring well wasinstalled. Surface completion and development still need to be completed.

GH-11C: This boring has been advanced to 831' bgs, and geophysics was completed.This boring is on hold.

MW-12A: This boring has been advanced to 252.5' bgs. Water has been measured at236.5' bgs. A monitoring has been installed. Surface completion and development needto be completed.

GH-12B2: This boring is currently at 452' bgs, with a 14" conductor casing to 252' bgs.Appropriate well installation is being evaluated.

GH-12C: This boring has been advanced to 1217' bgs as an exploratory boring using theT4W. Water zones were encountered, geophysics was completed, and the boring hasbeen abandoned.

GH-13A: This boring was advanced to 477' bgs by the API000. The API000 could notadvance this boring beyond this depth. Need to evaluate a different drilling and samplingmethod in order to advance this boring further.

GH-14A: This boring has been advanced to 20 feet bgs with the API000

GH-15A: This boring has been advanced to 601' bgs with conductor casing. This boringwill be sealed off, and advanced further.

Nov.2: The Northeast Canyon Waste Relocation project is 100% complete.

Nov.3: The field work for the cover material evaluation is complete. A draft UNSAT-H reportwas submitted to EPA on October 17, 2000, and the backup laboratory testing resultswere submitted to EPA on November 11, 2000.

Nov.4: Waste Limit Determination: A waste boundary delineation map was provided to EPA onJune 30, 2000. This waste limit map included the waste limits for all areas, except for thecenter of the landfill area around the main aggregate stockpile. The IP lines that werecompleted over this area have been interpreted. After this evaluation of the IP lines,additional confirmation borings were done, and a new waste limit map is in the process ofbeing completed based on this information.

Nov.5: Stormwater Pollution Prevention Plan (SWPPP): A draft SWPPP was provided to EPAon June 23, 2000. Republic is moving ahead with obtaining the additional information inorder to update the draft SWPPP as outlined in the draft SWPPP. As approved by EPAverbally on October 31, 2000, additional soils are being placed in the Eastern BypassChannel for protection.

Nov.6: Eastern Drop Off Channel Reconstruction: The plans have all been approved. However,based on field comments from EPA, this Interim Action has been put on hold. In theinterim, Republic is evaluating alternative protection scenarios for the area in the drop offchannel where stormwater has historically impacted waste.


Resp£

4MAVice President

AG/tg

File#: 999901-062/Order 7484







December 15,2000

Ms. Susanna Tmjillo, Project CoordinatorU.S. EPA Region IX75 Hawthorne Street (WST-7)San Francisco, CA 94105-3901

DearV*. Truji;1^:

RE: Monthly Progress Report - December, 2000Order RCRA 7003-09-99-0005NOV/Order CWA-309-9-99-14

As required by the above referenced RCRA Order, specifically VI number 3 (page 9 of 22), thefollowing is the monthly progress report. Attachment I containing past monthly activites hasbeen deleted as a step in conservation of natural resources. If you should require a copy of pastmonthly activities, please contact me. The progress report items are numbered with the first threeletters of the month. This month's items are as follows:

Current Monthly Progress ReportRepublic DUMPCo continues to make progress in completing the tasks outlined in the WorkPlan. Three drill rigs are on site advancing boreholes, setting casings, and/or installing wells.These include the following: 1 Percussion Hammer (API000), 1 drill and drive (T4W), and aSonic (GP300 RS).

Dec. 1: i he exploratory borings were started on March 13, 2000. The following is the status ofthese exploratory borings. It should be noted that when a monitoring well has beeninstalled, the prefix for the location designation changes from GH to MW, and when themonitoring well has been developed, the prefix will be changed to PW. This is reflectedbelow. Furthermore, when a boring has been classified as being "abandoned," this meansthe boring as been plugged with bentonite and sealed. Once a boring as been classified inthis progress report as being "abandoned," the boring will not be included in the nextmonths progress report.

MW-1 A: Stopped at 102 feet below ground surface (bgs) at bed rock contact, and amonitoring wel) has been installed. (No water has been detected in this monitoring wellsince installation).

1



GH-1B: This borehole was stopped at 425 feet bgs. This boring will be abandoned.

GH-1C: The sonic drill rig has advanced this boring to 682' bgs. This boring will bereamed out and a well installed with the T4W when it is available.

MW-2A: A 2-inch and a 4-inch monitoring well were installed in this borehole whichwas advanced to a total depth of 215 feet bgs. Water has been measured at 197 feet bgsin the 2-inch, and 195 feet bgs in the 4-inch on May 5,2000. Current water levelmeasurements indicate that the 4-inch and the 2-inch are dry.


PW-2C2: This boring was advanced to 263' bgs, and a 2-inch and 4-inch monitoringwell were installed. Water has been measured at 221' and 220' bgs respectively. Onlythe 4-inch (PW-2C2-4) well has been developed. It was developed on December 4, 2000.

GH-2D: This boring has been advanced to 808' bgs with a temporary surface casing at260' bgs. Numerous water layers were encountered.

GH-3C: Barber Rig has advanced this boring to 500' bgs at this location. A seal wasinstalled at this zone.

GH-3D: This boring has been advanced to 813 feet bgs as an exploratory boring with theT4W. Water zones were encountered, and geophysics has been completed. This boringhas been abandoned.

MW-4A: This boring was advanced to 295 feet bgs. Water has been measure at 185 feetbgs. A neutron log has been completed in this boring. A monitoring well has beeninstalled, and it needs to be developed.

GH-4B: This boring has been advanced to 806' bgs. Geophysics has been completed,and a monitoring well will be installed.

MW-5A: A monitoring well has been installed at this location at 192.5 feet bgs. Thismonitoring well has been developed, and the water level has been measured at 164 feetbgs. Based on video and geophysics, it was determined that this well calapsed. Thisboring was abandoned with a bentonite and cement slurry.


2

GH-5B4: This boring has been advanced to 733' bgs. This boring will be advanced whenanother appropriate drill rig is available.

PW-5C: This boring has been advanced to 154' bgs. Water has been measured at146.2' bgs. A monitoring well has been installed, and the well was developed onDecember 6, 2000.

MW-6B: This boring has been advanced to 227' bgs. Water has been measured at 208'bgs. A monitoring well has been installed in this boring.

GH-6C: This boring has been advanced to 417' bgs with a 10' conductor casing seal at227' bgs.


GH-9A: This boring has been advanced to 572' feet bgs. A monitoring well will beinstalled at this location.

GH-10A: This boring is located in the North East Canyon, and has been advanced to 67'bgs.

MW-11 A: This boring has been advanced to 407' bgs, where water was encountered.Based on the recharge rate being greater than 3 gallons per hour, a monitoring well hasbeen installed. The monitoring well was installed with new sand pack and slottedscreens. This has eliminated 90% of the development problems. Development of thiswell is in progress.

PW-1 IB: This boring was advanced to 260' bgs, a monitoring well was installed, and itwas developed on November 29, 2000.

GH-11C: This boring has been advanced to 831' bgs, and geophysics was completed.This boring has been Abandoned.

PW-12A: This boring has been advanced to 252.5' bgs. Water has been measured at236.5' bgs. A monitoring has been installed. This monitoring well was developed onDecember 7, 2000.

GH-12B2: This boring is currently at 452' bgs, with a 14" conductor casing to 252' bgs.Appropriate well installation is being evaluated.

GH-13A: This boring was advanced to 477' bgs by the AP1000. The AP1000 could notadvance this boring beyond this depth. Need to evaluate a different drilling and samplingmethod in order to advance this boring further.

MW-14A: This boring has been advanced to 236' bgs, and a monitoring well has beeninstalled.

GH-15 A: This boring has been advanced to 601' bgs with drill casing. This boring willbe sealed off, and advanced further.

Dec.2: The Northeast Canyon Waste Relocation project is 100% complete.

Dec. 3: The field work for the cover material evaluation is complete. A draft UNSAT-H reportwas submitted to EPA on October 17, 2000, and the backup laboratory testing resultswere submitted to EPA on November 11, 2000.

Dec.4: Waste Limit Determination: A waste boundary delineation map was provided to EPA onJune 30, 2000. This waste limit map included the waste limits for all areas, except for thecenter of the landfill area around the main aggregate stockpile. The IP lines that werecompleted over this area have been interpreted. After this evaluation of the IP lines,additional confirmation borings were done. A proposed final waste limit map will beprovided to EPA by the end of December. This waste limit map may be require updatingin the future, if other workplan activities indicate changes.

Dec.5: Stormwater Pollution Prevention Plan (SWPPP): A draft SWPPP was provided to EPAon June 23, 2000, and then a Technical Memorandum regarding SWPPP evaluations wasprovided to EPA on November 30, 2000. In addition, on December 1, 2000, an updatedStormwater Monitoring Plan and Annual Stormwater Evaluation was provided to EPA.

Dec.6: Eastern Drop Off Channel Reconstruction: The plans have all been approved. However,based on field comments from EPA, this Interim Action has been put on hold. In theinterim, Republic is evaluating alternative protection scenarios for the area in the drop offchannel where stormwater has historically impacted waste. Republic is waiting onestimates from contractors in order to provide EPA with a complete proposal.


Respec

Vice President

AG/tg

File#: 999901-062/Order 7484







Documents

Monthly progress rpts (1/2000-12/2000) · Nov.6: Trimble's Geo-Explorer III is still not available. Trimble can not give our local distributer a time for delivery. Dec.l: Formal approval