United States Department of the Interior

BUREAU OF LAND MANAGEMENTNevada Slate Office SFUND RECORDS CTR

P.O. Box 12000 (1340 Financial Blvd.) 2094969Reno, Nevada 89520-0006

http-J/www.nv.blm.gov

In Reply Refer To:

Nev-0462081703/2912

(NV-920/053)

JUL 07 1998

Honorable Harry ReidUnited States Senate300 Las Vegas Blvd. South, Suite 1610Las Vegas, Nevada 89101

Dear Senator Reid:

Thank you for facilitating the July 3, 1998, meeting regarding Sunrise Landfill. Manypositive statements were made by all parties. We are in agreement that a mutual objectiveshould be protection of human health and the environment In order to achieve that objective,we believe that compliance with applicable regulations is essential.

As we stated at the meeting, the Bureau of Land Management (BLM) contracted forpreparation of documents to assess the condition of the landfill cover and environmentalconditions relating to hazardous materials. These documents are referred to as the DynamacReport and the CCJM/TEG Report, respectively. At the meeting, representatives from SilverState Disposal Company indicated that these reports are not valid. BLM believes thesereports are valid. Moreover, this conclusion is supported by Environmental ProtectionAgency (EPA) reviews contained in the enclosed letters (Enclosures 1 and 2). Yoursuggestion of an independent third party evaluation is an excellent one. BLM believes theobjective of this effort should be towards ensuring corrective actions are taken to bring thelandfill into compliance with all applicable regulations and requirements.

As we stated at the meeting, we believe the closure of the landfill must comply with theregulatory requirements of 40 CFR 258. The EPA and Nevada Division of EnvironmentalProtection (NDEP) concur, as shown in the enclosed letters (Enclosures 1, 3, and 4). ClarkCounty Health District concurs that the site must comply with 40 CFR, Part 60, for non-methane emissions (Enclosures 5 and 6). EPA and BLM also believe that the landfill mustcomply with the Clean Air Act 40 CFR, Part 70.

At the meeting, Silver State Disposal Company indicated that, \.'hile under no legalobligation, they are willing to address grbundwater and gas collection issues. They statedthey will meet the federal deadline for gas collection. We appreciate their willingness toparticipate in these efforts; however, we~ believe that such issues are the ultimateresponsibility of Clark County because they are the landfill lessee. Any effort to addressthese issues should have concurrence of Clark County Public Works and close regulatoryoversight by BLM as the land management agency and lessor. BLM believes that cooperativeefforts by all regulatory interests to review and comment on both the groundwater and gascollection plans, as established in the technical oversight committees, can successfully addressall the issues at the Sunrise landfill. ~

As anyone can attest, hydrogen sulfide gas is easily detected by breathing the ambient air onthe site. At the meeting, representatives of the Clark County Health District stated they donot believe the landfill is the source of the smell detected by nearby residents. We supportyour position that the Clark County Health District should conduct further evaluations in thearea to address the concerns of those residents.

BLM would like to pursue transfer of ownership of the site to Clark County. We will initiatethis process as soon as officials of Clark County provide a written request for such a transfer.

Again, both your and Senator Bryan's involvement in ensuring a proper environmental closureof the Sunrise landfill is a very positive step towards making a properly closed landfill acommunity asset ™

Sincerely,

ROBERT V. ABBEY

Robert V. AbbeyState Director, Nevada

6 Enclosures:1. EPA letter dated March 11, 19982. EPA letter dated April 10, 19983. NDEP letter dated August 1, 19944. NDEP letter dated March 6, 19985. CCHD letter dated February 11, 19986. BLM letter dated February 17, 1998

cc: (w/enclosures)

Senator Richard BryanCongressman Jim GibbonsCongressman John EnsignU.S. Environmental Protection Agency, Felicia MarcusNevada Division of EnvkonmehtaTProtectionClark County Health District 7Clark County Department of Public WorksSilver State Disposal CompanyOffice of the Regional Solicitor

Si 002

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION IX

75 Hawthorne Street

San Francisco, CA 94105-3901

March 11, 1998 •£• .* "^

Mr. Marty Manning, DirectorClark County Department of Public Works 'i-V^ *£500 Grand Central Parkway fU*"Las Vegas, NV 89101 ''V^ :

Mr. Stephen Kalis h. PresidentSilver State Disposal Service, Inc.770 E. Sahara Ave.Las Vegas, NV 89104

Dear Mr. Manning and Mr. Kalish:

We are writing to you regarding the status of the Sunrise Landfill facility. The Bureau ofLand Management recently submitted to us an evaluation of the facility by Dynamac Corporation- Sunrise Mountain Landfill Cover Evaluation: -"Based upon a preliminary review of thisinformation and some additional information provided to us by the Nevada Department ofEnvironmental Protection, we have a number of concerns regarding the facility. Our concernsarise under 40 CTR Part 258 regulations, adopted pursuant to the Resource Conservation andRecovery Act (RCK.A) and the requirements of the Clean Air Act. We believe it is important foryou to work clcsely and cooperatively with the appropriate State and local agencies to addressthese matters.

Municipal Solid Waste Landfill ("MSWLF') units that receive waste after October 9,199] , but stop receiving waste before October 9, 1993, are exempt from all the requirements of40 CFR Part 258, except the final cover requirement specified in §258.60(a). The final covermust be installed by October 9, 1994.

We understand your facility stopped receiving waste on October 8, 1993. However, itappears that the facility did not meet the October 9, 1994, deadline for facility capping andclosure under 40 CFR Part 258 Criteria for Municipal Solid Waste Landfills. Owners oroperators of MSWLF units that fail to complete cover installation by October 9, 1994, arc subjectto the post-closure requirements of 40 CFR 258.61 including:

40 CFR §258.61 (a): Post-clo.s,ure care must be conducted for 30 years, except asprovided under §258.6) (b); and consist of the following:

an Recielri I'

Clark County Public Works and Silver State Disposal - Page 2

40 CFR §258.61 (a)(l): Maintaining the integrity and effectiveness of any finalcover, including making repairs to the cover as necessary to correct the effects ofsettlement, subsidence, erosion, or other events, and preventing run-on and run-offfrom eroding or otherwise damaging the final cover;

40 CFR §258.61 (a)(3): Monitoring the ground water in accordance with therequirements of Pan 258 subpart E and maintaining the ground-water monitoringsystem, if applicable; and

40 CFR §258.61 (a)(4): Maintaining and operating the gas monitoring system inaccordance with the requirements of §253.23.

40 CFR §258.23(a): Owners or operators of all MSWLF units must ensure that: (1)the concentration of methane gas generated by the facility does not exceed 25 percentof the lower explosive limit for methane in facility structures and 100% of the lowerexplosive levels at the facility property boundary; owners/operators must implement aroutine methane monitoring program; if methane gas levels exceed the limit, theowner/operator must immediately take all necessary steps to ensure protection ofhuman health.

40 CFR §258.72(b)r the owner or operator of each MSWLF unit must establish, in amanner in accordance with §258.74, financial assurance for the costs .of post-closurecare as required under §258.61. The owner or operator must provide continuouscoverage for post-closure care until released from financial assurance requirementsfor post-closure care by demonstrating compliance with §258.61 (e).

Based upon our initial review it does not appear that the Sunrise Landfill has met anumber of the requirements specified in 40 CFR Pan 258.

Ir, addition tc the applicable 40 CFR Part 253 requirements, the facility iy also subjectto requirements under the .Clean Air Act, including the requirement to obtain a FederalOperating Permit (40 CFR Pan 70) for air pollutant emissions. Existing major Part 70sources were required to submit applications within six months of the effective date of theClark County Part 70 Program (APCR 19.3.1.1). Since the effective date of this program wasAugust 14, 1995. applications were due from all major Part 70 sources by February 14,1996.To our knowledge, the facility has failed to apply for the appropriate air permit As of thedate of this letter, an air permit application for the Sunrise landfill is over two years past due.

It is our understanding that at a recent meeting on February 25,1998, withrepresentatives from your organizations, David Emme of NDEP reviewed the need for thefacility to meet the requirements outlined above under 40 CFR Part 258. \We believeimmediate action on your part is needed in order to comply with the appropriate regulatoryrequirements of both RCRA and the Clean Air Act. As stated earlier, it is important for youto work closely and cooperatively with the appropriate State and local agencies to addressthese matters.

Clark County Public Works and Silver State Disposal - Page 3

We have attached for your convenience a copy of both the 40 CFR Part 258 and 40CFR Part 70 regulations. If you have questions or need clarification on the RCRArequirements, please feel free to contact me at (415) 744-2120, or Srsanna Trujillo of mystaff at (415) 744-2099. For specific questions on the Clean Air Act, please contact SteveBranoff at (415) 744-1290.

Sincerely,

Deputy DirectorWaste Management Division

Enclosures

cc: Mark Chatterton, Bureau of Land ManagementDavid Emme, Nevada Division of Environmental ProtectionClare Schmutz, Clark County Health DistrictMike Naylor, Director Air Pollution Control Division

lu.u-i'Sliiii • • • ' " ' • _;, @] 005

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION ix

75 Hawthorne StreetSan Francisco, CA9410S-3901

April 10,1998

Mr. Mike Dwyer, District Manager j_Bureau of Land ManagementLas Vegas District Office4765 West Vegas DriveLas Vegas, NV 89108

Re: Review of "Reconnaissance Investigation of the Sunrise Landfill" report dated March 18,1998.

Dear Mr. Dwyer:

We arc writing to you regarding the Bureau of Land Management (BLM) report on theSunrise Landfill Titled "Reconnaissance Investigation of the Sunrise Landfill" dated March 18,1998. We have reviewed the report and find: 1) the report is technically sound and usedappropriate techniques for preliminary site screening and evaluation, 2) we concur with thereport's recommendation that additional investigation is warranted to determine the nature andextent of contamination at the site, 3) we believe additional investigation of the off-site lagoonsis necessary to determine the source and composition of the contaminants, and 4) a qualified fieldbiologist should conduct surveys to determine the presence/absence of the federally listed deserttortoise ( particularly near the off-site lagoons) and assess potential impacts to the tortoise and itshabitat pursuant to requirements of the Endangered Species Act (ES A) and the NationalEnvironmental Policy Act (NEPA).

"Report Validity

The field sampling and analytical techniques ware appropriate for a preliminary sitescreening evaluation. The combination of rapid site characterization tools and an on-sitc mobileanalytical laboratory allowed the investigators to quickly screen for a range of contaminants ofpotential concern- Additionally, field analysis was supplemented with laboratory analysis toconfirm the presence of contaminants of concern.

A well-designed and implemented field sampling and analysis program may be used to"screen-in" or "screen-out" a site from farther investigation. The purpose of a reconnaissanceinvestigation is simply to determine if there is a reasonable possibility that contaminants may bepresent at a site which could adversely affect human health or the environment. If thereconnaissance effort shows no contaminants of concern, or the contaminants are present at suchlow concentrarioTW that they would not be expected to have an adverse effect on human health orthe environment, a site may be screened out of further investigation. If, on the other hand, a

/Wn»erf on Ker*rlrJ I'tper

- oj i i . o a r.vi 7u2 647 5 U 1 U " _„ _ _ . ^ .^ El 006

recoonaissance investigation shows that contaminants arc present which may be human health orecologic concerns, a site is "screencd-in" for further investigation. In this case, the Sunrise •Landfill has been "scrcened-in" for fVrtbeHnvesugatioiL

Additional investigation is warranted from a risk based and lexicological perspective todetermine the nature and extent of contamination at the site because of:

• The presence of hazardous constituents, including a number of carcinogens,

• the presence of hydrogen stdfide at levels approaching and/or exceeding the IDLH(Immediately Dangerous to Life or Health) level

the limited nature of the reconnaissance investigation (metals and other inorganicswere not tested; neither groundwater nor ambient air were tested; and the samplingdid not fully characterize the lateral extent or depth of the landfilled material), and

• the nature of the constituents found suggests that industrial or large commercialactivities deposited significant amounts of hazardous waste in the Sunrise Landfill.

Soil and soil gas samples were collected at very shallow depths, generally between 2-7feet below ground surface (bgs). As such, these samples represent only a minor fraction of thecontaminants which may be present in the landfill. A comprehensive investigation shouldinclude the entire thickness of the fill, which appears to be greater than 200 feet in some places.

The reconnaissance investigation assumes a phased approach, which is appropriate for aninitial site assessment. Now that contaminants have been identified in the soil, a more thoroughinvestigation is warranted to fully characterize the nature of the constituents present at thelandfill and in surrounding areas, and to determine the extent to which they are migrating withinthe environment Further site investigation would include assessment of subsurface soils,groundwater, and ambient air.

Off'Site Lagcxyns:

The existence of the off-site lagoons containing black tarry organic material and evidenceof collapsed drams indicates the potential for hazardous waste disposal in violation of RCRAhazardous waste disposal requirements. This warrants additional investigation to determine thesource, composition, and extent of contamination. The results of such investigation would alsohelp determine any enforcement and/or corrective actions.

Desert Tortnjqe;

The presence of numerous apparent desert tortoise burrows near the off-site lagoonsindicates a high likelihood that the area is actively used as tortoise habitat A qualified fieldbiologist should conduct surveys to deterraine the presence/absence of the desert tortoise andassess potential impacts to the tortoise and its habitat pursuant to requirements of the EndangeredSpecies Act (ESA) and the National Environmental Policy Act (NEPA). If tortoise are present,any actions in die area must comply with ESA and NEPA requirements for the protection of thetortoise.

- . u o o t , J . O . O B i-AA T O * b 4 7 o U i u - - - -4/16/84 THU n:ju r/i-x j. -.j." •-.-. - . - • - .^ _

Complg^f Analysis nfS\u' 1 . T ^ V

A complete and detailed analysis should be performed on the entire landfill site to assessthe current situation and identify the full envelope of issues to be addressed at the site. Thefindings of the "Reconnaissance Investigation of die Sunrise LandfUT ate significant-and are inaddition to significant findings in the. November 13,1997 "Sunrise Mountain Landfill FinalCover Evaluation". Such findings warrant further comptebcnsivc analysis of the overallconditions of the landfill and die surrounding environment.

If you have questions or need clarification, please feel free to contact Susanna Tmjillo ofmy staff at (415) 744-2099. 3

Sincerely,

JcDeputy DirectorWaste Management Division

Enclosures

cc: David Emine, Nevada Division of Environmental ProtectionClare SchmuTZ, Clark County Health DistrictMike Naylor, Director Air Pollution Control DivisionMarty Manning, Clark County Department of Public WorksStephen Kalish. Silver State Disposal Service, Inc.

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STATE OF NEVADABOB MILLER

Couemor

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DEPARTMENT OF CONSERVATION AND NATURAL RESOURCES

DIVISION OP ENVIRONMENTAL PROTECTIONCapitol Complex

333 W. Nye Une

Carton City. Nevada 89710

August I. 1994

Clare SchmutzClark County Health DepartmentP.O. Box 4426Las Vegas, NV 89127

RE: Extension of closure period for Sunrise Landfill

Dear Clare:

The Nevada Division of Environmental Protection (NDEP) has reviewed the regulationsas they pertain to the deadline for completion of closure activities at Sunrise Landfill as yourequested. It seems to be another collision of common sense and regulation. The bottom lineis we recommend every effort to comply with the October 9, 1994 deadline.

As you are aware, 40 CFR Part 258 originally required owners/operators that cease wasteacceptance prior to October 9, 1993 to complete closure within six months of the last receipt ofwaste. US EPA extended this six month deadline to a full year primarily to respond tocomments from northern tier states expressing concern over the practicality of closure duringthe fall and winter months. Obviously, this concern over harsh weather conditions is not afactor in Las Vegas. Therefore, I read the Federal regulations as intending that 1 year is a morethan adequate timeframe for closure, particularly in a mild climate. While approved States aregranted authority to extend the closure period for sites that cease waste acceptance past theeffective date, there does not appear to be authority to extend the deadline for sites like Sunrisethat ceased waste disposal priorto Qctober 9, 1993.

Establishing a closure deadline for facilities that cease to accept waste is simply intendedas a regulatory control to ensure closure is completed in a reasonable timeframe. The timeperiod is arbitrary and the practical consequence of slipping past the deadline, particularly whena contractor is actively engagedjn closure, is insignificant. The regulatory consequence is,however, serious. Failure to close within the 1 year deadline would trigger all the ground water

. /9 .81FR!) 1 6 : 0 5 NV DIV ' PROT

/ * •/ Clare Schmutz

Clark County Health DepartmentAugust 1, 1994Page 2

TEL: 701 *868

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P. 002

monitoring requirements. A demonstration thai monitoring'is unnecessary may be possible inthat circumstance. Though the disposal company would need to weigh the costs of timelyclosure with the costs and likelihood of a successful demonstration prior to October 9.

If there are questions, please contact me at 687-4670 x3001.

Sine

Emme, SupervisorSolid Waste BranchBureau of Waste Management

DE:jm

cc: Jolaine Johnson, NDEP

It-ITKK »'. MDKHnS. IMiiVhir

Ull. IXIIV.ION. Adminlflruler

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STATE OF NEVADA

BOB MILLERCorvnwr

Wjalc MaiuerntnlCorrective .VIMUWF«dunl Fxilhio

Furiimilc •VT-SsSil

Wjltr Quality Planning

6S7.63W

DEPARTMENT OF CONSERVATION AND NATURAL RESOURCES

DIVISION OF ENVIRONMENTAL PROTECTION333 W. Nye Unc. Room 138

Carson City. Nevada S970W8S1

March 6, 1998

Clare SchmutzEnvironmental Health DivisionClark County Health District .P.O. Box 4426Las Vegas, NV 89127 . I

Dear Clare:

As we discussed last week. I have asked our Solid Waste Branch permitting engineer, Dennis LaPrairie, toreview the DYNAMAC report, prepared for BLM coDcernirjg the Sunrise Landfill. His comments on thereport are attached. Based on our review of this report and apparent non-compliance with the federaldeadline for closure established in 40 CFR Pan 258.1, the Division recommends the following course ofaction:

1. Gas monitoring wells should be installed along the landfill perimeter and monitored quarterly formethane in accordance with NAC 444.667 . the 1986 EMCON report prepared for Silver State Disposalincludes an acceptable design for the methane monitoring weDs.

2. A ground water monitoring system should be designed and Installed to monitor for any contaminantmigration from the landfill. After establishing a baseline data set with four independent samples, themonitoring wells should be sampled semi-annually in accordance with NAC 444.7481 through 444.7488.

3. The stormwater drainage system should be reevaluated and if necessary redesigned to ensure it willfunction properly without continuous maintenance. It appears the CMP half culvert diversion channelsmay not be adequate to capture and divert run-off. Stormwater appears to have eroded' around adverts inpast storm events and sedimentation within the culverts has also apparently been a problem.

4. In the near term, the final cover should be assessed to ensure that the thickness is adequate, particularlyin the areas of DYNAMAC's trenches 3 and 4 where only a thin cover layer was found. While you andyour staff presented a plausible explanation as to how the cover in this area may have been disturbed afterclosure, the extent of the disturbance would need to be assessed.

ilOll

Qare SchmutzEnvironmental Health DivisionClark County Health DistrictMarch 6, 1998Page 2

5. Over the longer term, the final cover should be reevaluated irra manner consistent with the intendedland use and with the objective of minimizing the need for continuous maintenance. As the last few yearsexperience has demonstrated, a cap constructed to comply with the prescriptive standards may beinappropriate in our arid environment since tbe compacted day barrier layer tends to crack and the soilerosion layer is unlikely to support plant growth sufficient to c^^Lcl rrcrion, particularly on side-slopes.An alternative cover design or a modification to the existing cover design may be more appropriate thanthe current prescriptive cover. As you know, the Desert Research Institute, USEPA and others areactively studying alternative final cover systems in arid environments. Ideally, an alternative cover designor cover modification would benefit from this research.

We will discuss the details of the work mat needs to be done and timefranies when we meet next week andagain at the end of the month. We expect to gain compliance by the responsible parries for installation ofnecessary monitoring systems in the very near future. Further evaluation of the final cover design shouldbe conducted over time, though any needed maintenance issues should continue to be addressed as theyarise. If there are questions, I can be reached at 687-4670 x3001.

David Emme, ChiefBureau of Waste Management

DErjm

enclosure

cc w/encl: L.H. Dodgion, Administrator, NDEP

Verne Rosse, Deputy Administrator, NDEP

Ed Wojcik, CCHD

CLARK COUNTY HEALTH DISTRICT

P.O. BOX 39O2 • 625 SHADOW LANE -LAS VEGAS. NEVADA B9J27 • 7Oa~f̂ ~̂(%f4 VF*6 702-383-

Trail 7 30ft]February 11, 1998

U.S.Q.I.BUREAU G r L A H .LAS VEGAS FiSiO OFF.

Mark Chatterton, Assistant DistnciManager £Enc</C" /-<£Bureau of Land Management Las Vegas Field Office •**4765 Vegas Drive, :Las Vegas Nevada 891 08 ^^

Mr. Martin Manning, Director of Public Works, Clark County2nd Floor Government Center 500 S. Grand Central ParkwayLas Vegas, Nevada 89155-4000

Mr. Steve KalishRepublic DUMPCo Inc. (A394)770 E. Sahara AvenueLas Vegas, Nevada 89104

Gentlemen:

This letter is to clarify the Health District's interpretation of how the requirements inEPA, state and local regulations for managing off-gas from Sunrise Landfill may besatisfied. We seek to facilitate a resolution as to how these requirements will be metamong the Bureau of Land Management, Clark County and/or DUMPCo.

1) The Sunrise Mountain Landfill (A394), generally located on the central easterlyslope of Las Vegas Valley, ClafR County is a Municipal Solid Waste (MSW)Landfill as defined in the Environmental Protection Agency regulations for NewSource Performance standards. See Subparts Cc and WWW, Part 60, Chapter 1 ,Title 40, Code of Federal Regulations (40 CFR60). The property is owned by theUS Government and managed by the Bureau of Land Management (BLM).

2) This Landfill served as the primary permitted disposal facility for most of the solidwaste originating from within the Las Vegas Valley during its operation beginningin 1962 until it stopped receivingTwiste in 1993.

3) The site was leased .to Clark County in 1962. For its entire period of operations,the landfill was operated for Clark' County through an agreement between theCounty and Silver State Disposal Services, Inc. (SSDS) and later theirincorporated subsidiary, Disposal Urban Maintenance Processing Co., Inc.,(D.U.M.P. Co).

:LARK COUNTY . LAs VEGAS . NORTH LAS VEGAS • BOULDER CITY . HENDERSON

1^009

4) In October, 1993, the landfill ceased receiving waste and in April 1994, an agreedupon closure plan was signed by BLM, Clark County, Clark County Health Districtand D.U.M.P. Co.

5) On March 3, 1995, D.U.M.P. Co executed an "all-parties agreement", i.e., BLM,Clark County, Health District, and DUMPCo signed on various dates betweenMarch 29 and April 12, 1995, which recognized the completed final closure inaccordance to the Plan. The Vipe president of DUMPCo stated in a letter to theDirector of Environmental Health of the Health District, that "(As of) March 1, 1995,D.U.M.P. Co will begin monitoring and maintenance of the closure for a period offive years, until April 31, 2000...."

6) In August 1997, Republic Industries, Inc., acquired the assets and liabilities ofSilver State Disposal Service, Inc., and D.U.M.P. Co. By January 1998, thetransfer was accepted by Clark County, BLM and the Health District.

7) BLM continues as the owner of the closed landfill. Clark County may continue tohold a lease to the property since'BLM indicates that it has not yet accepted returnof the property and released the County from the terms of the lease agreement.The Health District cannot judge this issue. The issue must, however, be resolvedby BLM and Clark County such that the gas collection and managementrequirements can be met within Mf time permitted under terms of both the localregulations and 40 CFR 60.

8) The Sunrise Landfill is subject to the provisions of Section 14 of the Air PollutionControl Regulations of Clark County; specifically 40 CFR 60 Subparts Cc andWWW. These federal regulations were adopted Jan 23, 1997 by the Clark CountyDistrict Board of Health. The District Regulations incorporate the federalregulations by reference. Subpart Cc of the regulations generally applies toexisting MSW landfills for which,jjpnstruction commenced before May, 1991.Subpart VWVW generally applies to MSW that commenced construction,reconstruction or modification ...after May 30.1991. Subpart Cc applies to theSunrise Mountain Landfill because its construction commenced in approximately1962. Subpart VWVW may apply to certain portions of Sunrise because ofchanges made there after 1991, but before closure activities commenced.

9) According to Subpart 60.33, the State Implementation Plan shall include control ofMSW landfill emissions at each MSW landfill meeting the conditions in 60.33c,a(1), a(2). anda(3).

a1) The Sunrise Landfill accepted municipal waste after November 8, 1987, theapplicable date in 60.33.c(a) (1).

/ a2) The Sunrise Landfill has a final capacity of approximately 61 million cubic:: yards or 46 million cubic meters. Based on daily waste rate for the two

years prior to closure, perhaps 20 to 25 million cubic meters were disposedof at the site. These volumes are substantially greater than 2.5 millioncubic meters threshold in CFR 60.33c (a)(2)

a3) Using the landfill gas generation formula at Section 60.754 (Methane is50%, non methane organic gases as hexane are 4000ppm) with a multiplierof 30% for the assumed amount of degradable waste, the estimatedVolatile Organic Emissions are 859 metric tons per year or 945 (English)tons per year. This amount exceeds the 50 metric ton threshold for VOCemissions in CFR 60.33c (a)(3)

10) Since the qualifying criteria of Section 60.33c have been met, the addressees areagain advised (as in the earlier notice) of the requirement to submit or achievesubmission of a plan to control Municipal Solid Waste landfill emissions at theSunrise Mountain Landfill.

ACTION NEEDED FOR PROSPECTIVE COMPLIANCE WITH DEADLINES INREGULATIONS INCLUDE:

a) Establish better estimates of the landfill gas emissions.There is limited information from which to reasonably characterize the actualestimate of emissions. Section 60.754 contains several options that can beused to improve the estimates.

b) Design acceptable system to collect and limit the released MSW emissions.

The control technology must meet one of the following threerequirements:

1} An open flare designed and operated according to the parametersestablished in Section 60.18 of the federal regulationsor,

2) A control system designed and operated to reduce nonmethaneorganic compound emissions by 98 weight percentor,

3) An enclosed combustor designed and operated to reduce the outlet •NMOC concentration to 20 parts per million as hexane by volume,dry basis at 3 percent oxygen, or less.

c) Build an acceptable system to collect and limit the release of MSW Landfillemissions. ~y

•

The following tasks and schedules are proposed to assure compliance with/ Section 14 of the Regulations and specifically, 40CFR 60, Subpart Cc.

„•

Bv June 1. 1998 Submit improved estimates of landfill gas emissions using Section60.754

Bv July 15. 1998 Submit site specific design plans for gas collection and controlsystem.

Bv August 15 1998: Apply for Authority To Construct Certificate pursuant to Section 12of the Air Pollution Control Regulations.

The Clark County Health District will, in consultation with other local and state agencies,review such submittal for approval in August and September 1998.

Purina OCTOBER 1998 through JANUARY 1999: Planning and award of contracts forinstallation of the MSW LandfiHGas Collection and Control Equipment.

Bv MAY or JUNE 1999: Start-up of collection and control system for land fill gases.(This will satisfy the requirement of helng operational within 30 months of adoption ofthese regulations by the District Board of Health on January 27, 1997).

By DECEMBER 1999: Complete performance testing to meet the 40 CFR 60December 31 deadline.

Michael H. Naylor, DirectorAir Pollution Control Division

Otto RaviChief Health Officer

CLARK COUNTY HEALTH DISTRICT

P.O. BOX 4426 • 625 SHADOW LANE • LAS VEGAS. NEVADA 89127 . 702-383-1276 . FAX 7O2-383-1443

Distribution List: T

- fc*-^cAllen Bell - Mequite Public Works_ (ifQ&u ot L' :^0James Carlson - Nevada Power Company °u *" ,--,Mark Chatterton - Bureau of Land Management 'C^^^Joe Cyphers - Nevada State Parks ° c v"'^Conrad Dziewulski - Nellis AFB ^ .^Davd Emme - Nevada Division of Environmental Protection PllvwCol. Michael F. Fukey - Nellis AFB ^Karl Gieszi - So. Cal. Edison Co.Elizabeth Gilmartin - Clark County Health DistrictAlan Gove - Boulder City Public WorksMatt Haber - U. S. Environmental Protection AgencyTom isola - Silver State Disposal ServiceDonald Kwalick - Clark County Healtli DistrictTeresa Mann - Boulder City DisposalMarty Manning - Clark County Public WorksMichael Moran - Bureau of Land ManagementMichael Naylor - Clark County HealthjDistrictRoy E. Orr - Nevada State ParksDr. Otto Ravenholt - Clark County Health DistrictGreg Sanks - Nevada Power CompanyVictor Skaar - Clark County Health DistrictClare Schmutz - Clark County HealthlDTstrictDick Serdoz - Nevada Divsion of Environmental ProtectionDave Sorg - James Hardie GypsumSusan Stewart - Titanium Metals CompanyMike Sword - Clark County Health DistrictJoe Titus - Henderson Public WorksGuy Wells - Wells Cargo, Inc.Edmund Wojcik - Clark County Health District

CLARK COUNTY . LAS VEGAS . NORTH LAS VEGAS • BOULDER CITY • HENDERSON

ijOOS

United States Department of the Interior

BUREAU OF LAND MANAGEMENTLas Vegas Field Office

4765 Vegas Drive c / /Las Vegas, Nevada 89108 &hUoSC(r* <e

In Reply Refer To:NEV-046208

2912(NV-053)

Certified Mail 2 5 2 6 5 9 5Return Receipt Requested

Mr. Martin Manning FEB J 7 15'3£Director of Public Works, Clark County500 South Grand Central ParkwayP. O. Box 554000Las Vegas, NV 89155-4000

Dear Mr. Manning:

We are in receipt of a letter from Clark County Health District dated February 11, 1998,regarding management of gas at Sunrise Landfill. That letter indicates it was also sent toyou. As we indicated in at our December 16, 1997, meeting and in our February 6, 1998,letter to you, as the lessee of the Sunrise Landfill, Clark County Public Works Department isresponsible for insuring compliance with requirements for management of gas at SunriseLandfill.

Sincerely,

/S/ MICHAEL T. MORAW

.1^1 INQ FQfcMark R. ChattertonAssistant District ManagerNon-Renewable Resources

cc: Michael H. NaylorClark County Health District625 Shadow LaneLas Vegas, NV 89106

Steve KalishRepublic DUMPCo Inc. (A394)770 E. Sahara AvenueLas Vegas, NV 89104