POOR LEGIBILITY

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Originals to Sunrise

CITY OF HENDERSON L a n d f n i F i l e

CITY HALL 240 WATER STREET | 702/565-2323HENDERSON. NEVADA 89015-7200

Gaieway to Lake Mead Resorts

July 5, 1990 |.

Silver State Disposal Service, Inc./Environmental Technologies of Nevada, Inc.770 East Sahara Avenue.Las Vegas, Nevada 89104

Attention: Mr. Johnnie Isola '

Re: Disposal of Municipal Sludge at Sunrise Mountain Landfill

The purpose of this letter is to summarize our understanding of theacceptability of disposing municipal sludge from the proposed HendersonvastetMter treatment plant at the Sunrise Mountain Landfill.

A meeting was held with you at the City of Henderson (City) municipal officeson June 21,. 1990, to discuss the City's proposal for sludge disposal. Also inattendance were Wayne Robinson of the City of Henderson land Vicki Scharnhorstof James M. Montgomery, Consulting Engineers, Inc. (JMM).i '

It was proposed at this meeting that! the City be allowed to dispose ofapproximately 30 to 40 cubic yard* of dewatered secondarysludge fer day beginning in mid-1992 land increasing to

domestic wastewaterapproximately 60-80

cubic yards per day by the year 2000. The average estimated {solids content ofthis sludge is 16 to 18 percent. ! '''

You explained that, at a minimum, the sludge must pass the Paint FilterLiquids Test, Method 9095, as outlined in the EPA Manual ion Solid Wastes (copyattached). On June 21, 1990, JHM obtained a dewatered sludge samplecontaining 14.6 percent solids from ! the belt filter press dewateringfacilities at' the South Valley Water Reclamation Facility, Midvale, Utah.This JMM-designed facility utilizes an identical treatment method to theproposed treatment plant in the City. The plant disposes of their sludge at amonofill and is not required to produce;a minimum solids|content. JMM broughtthis sludge sample to your office on the following day and your chemist ran apaint filter liquids test on it. | ; ! ' !

At our June 25, 1990, meeting, you presented the results!of your investigationinto the acceptability of the proposed. sludge disposal methodology. KurtSegler, Utility Services Manager for the City, was in attendance as well asyourself, Wayne and Vicki. Your chemist reported that the sludge sample hadpassed the paint filter test -and your discussions with Tom Isola, Director ofHazardous Wastes for Silver State Disposal Service,! confirmed that thelandfill would be able to receive the City's municipal sludge.

Silver State Disposal Service, Inc./Environmental Technologies of NevadaPage 2July 5, 1990

In summary , Silver State Disposal will receive the City's dewatered domesticwastewater sludge from the City treatment plant expansion. The dewateredsludge will contain 16 to 18 percent solids, by weight, and will be deliveredin quantities of 30 to 40 cubic yards per day beginning in 1992 and increasingto 60 to 80 cubic yards per day by the year 2000. This equates to one to twotruckloads daily initially, and two to four per day in the future.

As you are aware, sludge treatment and disposal is one of the most criticaloperations of a wastewater facility. We would like to • express ourappreciation for your efforts and timeliness on this matter. As this isimportant to the design of our facility and, consequently, the growth of ourCity, we would appreciate your timely response to this matter as to yourconcurrence.

Sincerely,

Kurt R. Segler, PL-HE.Utility Services Manager

KS:VS:kmh

c: Wayne Robinson, City of HendersonVickl Scharnhorst, James M. Montgomery EngineersBob Mayers, James M. Montgomery Engineers

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~,, Jur.

July 9, 1990

Mr. Wayne RobinsonCity of Henderson240 Water StreetHenderson, Nevada 89015

Dear Wayne:

I have just completed reviewing the letter dated July 5, 1990, regarding the disposal of municipalsludge at our. Sunrise Sanitary .Landfill. I would like to reiterate our conditions for acceptance.As you are aware, the United States EPA regulates landfills and there are some forthcomingregulations referred to as "Subtitle D". It is our current understanding these regulations will noteffect our conditions to accept sludge, and any enforcement of these regulations should beaccompanied with a grace period for compliance. The EPA will also be instituting a new testto determine weather or not a material is considered a hazardous waste, the test is referred toas the T.C.L.P., Silver State Disposal will require all suspected waste streams to be analyzed.As you are aware, Silver State operates a sanitary landfill and will not accept any hazardousmaterials.

All current conditions have been met for the acceptance of the sludge material at our landfill.We will await further information on the system to put together a bid on the transportation of theof the sludge to our landfill. Thank you for your patience on this matter.' Should there be anyfurther information needed, please do not hesitate to call.

Johnnie Isola

Jl/tdl

770 East Sahara Avenue • P.O. Box 98508 • Las Vegas. Nevada 89193-8508

Se'vmg me Wo«a s '30'i272-'3QOl Neeas

J525 Soutn wasatch BoulevardSute 200 San Lake Cny.

OCT1 1990JMA James M MontgroWHEALTH OFFICER

HEALTH DIVISION1

September 27, 1990

Clark County Health Department Project No. 1644Environmental Health DivisionP.O. Box 4426Las Vegas, NV 89106

ATT N: Glair SchmutzSenior Supervisor

PROJECT: Henderson WWTP Expansion

SUBJECT: Sludge Disposal

Gentlemen:

Thanks for the recent opportunity to review with you the sludge disposal plan for the HendersonWastewater Treatment Plant Expansion Project. As discussed in our telephone conversationof September 26, 1990, the new Henderson treatment facility will utilize the oxidation ditchprocess which generates "secondary" sludge only (no primary clarifiers). This secondarysludge undergoes significant digestion (reduction of volatile solids) in the oxidation ditchprocess. Sludge subsequently removed in the secondary clarifiers will be dewatered to 15-20percent dry solids, by weight, using belt filter presses and polymer conditioning. Thedewatered sludge will be trucked for disposal to Sunrise Mountain Landfill, operated by SilverState Disposal Services, Inc.

The Clark County Sanitation District (CCSD) and the City of Las Vegas (CLV) wastewatertreatment facilities already utilize the landfill for disposal of their non-digested primary andsecondary sludges, which are conditioned with lime and dewatered before disposal. Thequantity of sludge discharged by both CCSD and CLV is much greater than for Henderson dueto the lime conditioning process and the larger size of the CCSD and CLV plants. Hendersonexpects to discharge up to 60-80 cubic yards per day of dewatered sludge by the year 2000, basedon a 10 mgd treatment plant capacity.

The only current standard for disposal of municipal wastewater sludge in a solid wastelandfill is the EPA Paint Filter Test for free liquids. The test essentially requires that asludge sample contain no liquids which can freely drain away from an undisturbed sample bygravity. Both JMM and Silver State have performed the paint filter test on a recent sludgesample from a JMM-designed municipal facility which uses a wastewater treatment processand a sludge dewatering system very similar to the ones proposed for Henderson. Thesamples, which contained 14.6 percent solids, passed the test and Silver State agreed to acceptHenderson's dewatered secondary sludge at Sunrise Mountain Landfill as long as the sludge

Clark County Health Dept. -2- September27,1990

is not toxic or hazardous and generally conforms to the characteristics of the sample tested.(See attached correspondence.)

It should be noted that, under current regulations, municipal wastewater sludge is classifiedas neither hazardous nor toxic by categoric determination. It is understood that futureregulations may require more stringent testing, monitoring or treatment of sludges disposedof in this manner.

There currently is no permitting or approval process on the federal, state or local level formunicipal wastewater sludges discharged to solid waste landfills, other than conformance toexisting regulations. Henderson intends to comply fully with all regulations and ispermitted, categorically, to practice the proposed sludge disposal method. As Silver StateDisposal Services has agreed to accept Henderson's municipal wastewater sludge under theconditions defined herein, design of the new wastewater facilities is proceeding under thiscritical assumption.

The Henderson Preliminary Engineering Report for Wastewater Treatment PlantExpansion Project has been submitted to and accepted by both the Nevada Department ofEnvironmental Protection and the Clark County Comprehensive Planning Department. Thisdocument contains a more detailed description of Henderson's proposed wastewater treatmentand sludge disposal methods, and may be referenced as necessary.

Please contact us immediately should you have any questions or comments regarding theissues addressed in this correspondence. We appreciate your helpful involvement in thisproject.

Sincerely,

JAMES M. MONTGOMERYConsulting Engineers, Inc.

Robert J. Mayers, P.E.Project Engineer

/dt

cc: Kurt Segler, HendersonLarry Bowen, JMMVicki Schamhorst, JMM

REPORT AND NOTICE OF INSPECTION

CLARK COUNTY HEALTH DISTRICT825 SHADOW LANE • LAS VEGAS. NEVADA

•fefcphon* 383-1251 (Dirtci) • 385-1251 (24 houra)

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CLARK COUNTY HEALTH DISTRICT

C.O. I3OX 142G • 62S SHADOW L.ANC • LAS VEGAS, NEVADA 89127 • 7O2-30S-I29I . FAX 7O2-3Q4-5342

July 5, 1S90

Calvin D. Staraan, P.E.Project EngineerClark County Sanitation District5857 East Flamingo RoadLas Vegas, Nevada 89122

Subject: Request for Approval To Dispose of WastewaterSludge from the Overton and Mesquite Sewage Lagoonsat the Sunrise Mountain Landfill

Dear Mr. Starman:

Approval is granted based on the laboratory data submitted inyour letter to this Department dated June 29, 1990. Review ofthe data indicates several components of the sludge are border-line and are slightly elevated that technically are above thelimit for landfill disposal, i.e., acetone, arsenic, chromium,and lead. However, based on the projected method of prepara-tion for disposal that includes windrowing which allows forvolatizing and dilution, we believe these elements do notrepresent a significant threat to the environment, due to thegeographical location of the Sunrise Mountain Landfill inrelation to ground water.

As noted in your letter, Mr. Julian Bielawski of the NevadaDivision of Environmental Protection also received the identi-cal data. A copy.of this letter is being forwarded to him forhis review and/or comments.

Unless the Nevada Division of Environmental Protection has anyadverse comments regarding this approval, proceed as plannedfor disposal of the sludge at the Sunrise Mountain Landfill.

Should you have any questions, please call me at 383-1263.

Sincerely,

CLARK COUNTY HEALTH DISTRICT

Felix Havis, Sanitarian SupervisorEnvironmental Health Division

FH/bc

>:c: Julian Bielawski, Nevada Div. of Environmental ProtectionDon Cadwell, Environmental Technologies

Cl.*PK COUNTV . LAS VEGAS . NORTH LAS VEGAS • BOULDER CITY • HENDERSON

bxc: Dr. Ravenhojt, C l a r e Schmutz, C l i f f Judkins, Rea3ing F i l e s , £Sunrise M o u n t a i n L a n d f i l l F i l e w/Attachments

ClarkCounty

Sanitation DistrictE. JAMEB OANB

DIRECTOR

EB57 E. FLAMINGO ROADLAS VEGAS. NEVADA 89122

[7O2) 4SB-11BO

Telef oceimite [7O2] 435-5435

June 29, 1990

Clark County Health DistrictAttention: Felix Havis625 Shadow LaneLas Vegas, Nevada 89102

3 ]SSO

. REQUEST FOR APPROVAL TO DISPOSE OF WASTEWATER SLUDGE FROMOVERTON AND MESQUITE LAGOONS AT THE SUNRISE MOUNTAINLANDFILL (CCSD PROJECTS #195 AND #255)

We are transmitting to you the lab results of sludge samplestaken in three lagoons in Mesguite and three lagoons inOverton. The District's contractor will truck the sludge tothe Sunrise Mountain Landfill, operated by Silver StateDisposal, in Las Vegas. We request a written response fromthe Health District on whether this landfill is acceptableto the Health District as the disposal site for thisdomestic wastewater lagoon sludge.

We have enclosed a copy of our letter to Don Cadwell ofEnvironmental Technologies which gives background infor-mation for your review.

'Lt-

CALVIN D.1 STARMAN, P.E.Project Engineer

CDS:ab

Enclosures

BOARD OF TRUSTEESKoren Hayes. Chairman • Manuel J. Cortez. Vice-Cnairmen

Joy Bingnem. Paul J. Chnwceneen. Thalia M. Oondero. William U. Pear-eon, Bruce 1_ Woodbury~ ' Donald l_ "Pot" Shalmy. Councy Manager

CIr\rI<. Sanitation District

CountyE. JAMES OANB

DIRECTOR

5857 E. FLAMINGO ROADLAS VEGAS. NEVADA B9122

f7OS] 45B-11SO

Telef aCBimile [7O2] 435-5435

June 28, 1990

Environmental TechnologiesAttentionn: Don Cadwell, Field Operations Manager770 East Sahara AvenueLas Vegas, Nevada 89104

REQUEST FOR APPROVAL TO DISPOSE OF WASTEWATER SLUDGE FROM OVERTONAND MESQUITE LAGOONS AT THE SUNRISE MOUNTAIN LANDFILL (CCSDPROJECTS *195 AND 1255)

We understand that Sunrise Mountain Landfill, operated by silverState Disposal, will accept disposal of domestic wastewater lagoonsludge at its landfill if it is shown not to be hazardous, it isalso our understanding that Environmental Technologies handles allspecial dumping requests at Sunrise Mountain for Silver StateDisposal. Accordingly, we are hereby transmitting to you the labresults of sludge samples taken in three lagoons in Mesquite andthree lagoons in Overton and request a written response on whetherthe landfill will accept sludge from these lagoons.

The lab analysis was done for the parameters listed below by EnsecoIncorporated, Rocky Mountain Analytical Laboratory in Colorado andtheir attached report is entitled: "Analytical Results for ClarkCounty Sanitation District, ENSECO-RMAL NO. 008912, April 24,1990".

In your previous contact with Ms. Debra Bolding of the District,you indicated that you would require the following data beforedeciding to accept Mesquite and Overton sludge:

Metals:seleniumleadmercuryarsenicchromium (trivalent and hexavalent)cadmium

BOARD OF TRUSTEESKaren Hayes. Cneirman • Manual J. Cortaz. Vce-Cnarmen

Joy BinQnom, PeiJf J. Constenaen. Thalia M. Donflera. William U. Pearson. Bruca L. WbodOuryDonald L. "Pat" Snaimy. County Manager

Environmental TechnologiesPage 2June 28, 1990

Organics:series 8020 (aromatics)series 8240 (purgeable organics)series 8270 (bases, acids and neutrals)series 8080 except PCB!s (organochlorides)

pH and moisture at time of dumping (does not want toowet, using a garlic crusher, if more than afew drops squeeze out, the sludge is too wet.')

Quantity to be dumped

The series numbers refer to methods described in the Solid Waste846 Manual; Test Methods for Evaluating Solid Wastes z Physicaand* Chemical Methods; 6000 Series Methods of Analysis.

Also, it is our understanding that you require the following:

The analyses must be performed within nine to twelvemonths before dumping. Then just prior to dumping, youwill require that some of the tests be repeated to besure the quality of the sludge has not significantlychanged. After twelve months, the entire sampling andanalysis must be repeated. For future analytical work,you had requested that the Sanitation District be sureand contact you to check that Environmental Laboratorieswill'accept the results of the laboratory performing therepeat tests.

According to Mr. Felix Havis at Clark County Health District, theonly Health District authorized landfill for disposal ofwastewater lagoon sludge in Clark County is Sunrise Mountain.

By carbon copy of this letter with the lab report, we are alsorequesting approval from Mr. Felix Havis of the Clark CountyHealth District for a written response on whether the landfill atSunrise Mountain is acceptable to his District for disposal ofsludge from these lagoons, in Mr. Havis1 previous contact withMs. Debra Holding of the District, he indicated that he wouldrequire the following data:

Metals:seleniumleadmercuryarsenic

Environmental TechnologiesPage 3June 28, 1990

By carbon copy of this letter with the lab report, we are alsorequesting that Mr. Julian Bielawski of the Nevada Division ofEnvironmental Protection provide a written response on whether thelandfill at Sunrise Mountain is acceptable to the Division fordisposal of sludge from these lagoons.

On June 27, 1990, we had a bid opening for our Overton lagoon pro-ject. The construction firm of Hall Brothers with office inHurricane, Utah, was the apparent low bidder. If our Board ofTrustees awards the contract to them on or about July 17, 1990,construction operations will commence about August 1, 1990, withsludge hauling operations commencing some time on or afterSeptember 1, 1990. The contractor's procedure for sludge removaland disposal operations is yet to be received for approval, butcould follow those given in the contract specifications asindicated on the yellow page attached to this letter.

NDEP's approval for construction of the Mesquite facilities wasjust received on June 28, 1990 and we are expecting to go out for a30-day bid period shortly.

SLUDGE QUANTITIES

The bottom dimensions of the Overton lagoons are given below. Thesludge depth as measured on March 28, 1990 are as indicated on theblue sheets attached. Roughly, the average in-place wet depthappears to be about six inches, implying a total in-place wetsludge volume of 5,020 cubic yards for all three ponds. We do notknow what the final total "truck haul volume will be, but weroughly estimate it at half the above, or 2,510 cubic yards as apreliminary estimate for you.

OVERTON POND BOTTOM DIMENSIONS:

Primary Pond A 317' x 285'Primary Pond B 317' x 285'Primary Pond C 317' x 285'

The bottom dimensions of the Mesguite lagoons are given below. Thesludge depth as measured on March 27, 1990 are as indicated on thegreen sheets attached. Roughly, the average in-place wet depthappears to be about 0.5 inches for Pond B, 7.0 inches for Pond D,

Environmental TechnologiesPage 4June 28, 1990

and 6.0 inches for Pond E, implying a total in-place wet sludgevolume of 1,840 cubic yards for all three ponds. We do not knowwhat the final total truck haul volume will be, -but we roughlyestimate it at half the above, or 920 cubic yards as a preliminaryestimate for you.

MESQUTTE POND BOTTOM DIMENSIONS:

Pond B 205' x 365'Pond D 175' x 245'Pond E 175' X 245'

If I can be of further assistance in your review of this matter,please call. We await the written approval of Silver StateDisposal, Clark County Health District, and the Nevada Division ofEnvironmental Protection.

CALVIN D. STARMAN, P.E.Project Engineer

CDS:ab

Attachments

cc: Paul LaBruzzo, Silver State DisposalFelix Havis, Clark County Health District-Julian Bielawski, Nevada Division of Environmental Protection

SECTION 2

SLUDGE RQCWXL AND DISPOSAL

2-1 SLUDGE BQEWAL AND DISPOSAL

The accmaolati.cn of sludge depositing on the lagoon bottcot xakes its removalnecessary. Sludge removal fron the primary lagoons shall be armrplished inthe following fashion:

1. Isolate tbe lagoon by not letting any vastewater in or -out.

2. Punp the liquid contents to an adjacent lagoon by using a trash punp witha floating intake hose. No sludge shall be punped.

3. punping \iben. the sludge level is reached.

4. Allow sludge to dry into' semi-wet solids. It is acceptable to add sawdustor other drying agents to speed up the drying of the sludge.

5. Wind row semi-wet sludge by using a mail grader.

6. Ifcve wind rows periodically until it dries to a level acceptable for

7. Bring a mall front end loader and place dried sludge into a dmrp truck./i

\7a7ta;;~n :"^-'"^n Landfill located near Las Vegas at 7900 VegasValley Drive in Clark County owned by Silver State Disposal.' /\

186 Detailed Specifications

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CLARK COUNTY HEALTH DISTRICT

P.O. BOX 4426 • 625 SHADOW LANE • LAS VEGAS. NEVADA 89127 • 7O2-385-1291 . FAX 7O2-384-534:

May 4, 1990F A X

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FRQM:/>/C. faiHr/Mttr PHONE:

CO: FAX #:Pott-It "brand la> trinsminal memo 7671

Mr. Tom IsolaSilver State Disposal770 E. SaharaLas Vegas, Nevada 89104

Dear Mr. Isola:

In reference to Dr. Ueckert's telephone call on April10, 1990, regarding the disposal of bioraedical waste atthe Sunrise Sanitary Landfill, please refer to Section10, Items 6 and 7, Page 9, of the current DistrictRegulations Governing Solid Waste Disposal Sites andFacilities:

• "6. Spreading and Compacting of Refuse

As rapidly as refuse is admitted to the site,' it shall be spread and compacted in shallowlayers of approximately two or three feet indepth depending upon the type of material andthe compaction equipment. The completed cellshall consist of the refuse admitted andcompacted during the working day regardless ofoverall height and area covered.

7. Cover

Cover material shall consist of soil of suchcharacter that it can be compacted to providea tight seal, does not crack excessively whendry and is relatively free of putresciblematerials and large objects. Cover shall beapplied as follows:

a) Daily cover. A layer of at least six(6) inches of material shall be used to coverall exposed refuse at the end of each workingday; except that on surfaces that will notreceive an additional depth of refuse or thefinal cover within 60 days, a layer of coverat least one (1) foot shall be applied.

b) Final oover. A layer of at leasttwo (2) feet of material in addition to thedaily cover shall be placed over the entiresurface of all completed portions of the fill

CLARK COUNTY LAS VEGAS NORTH LAS VEGAS BOULDER CITY HENDERSON

CL.ARK COUNTY HEALTH DISTRICT

Mr. Tom IsolaPage 2May 4, 1990

within one (1) week following the final place-ment of refuse. Final cover shall be gradedas provided on the approved plan to preventponding. The surface of the final cover shallbe maintained at the plan elevation at alltimes by the placement of additional covermaterial where necessary."

Medical waste should be covered and compacted whenplaced in the landfill to comply with present Regula-tions outlined above. Without proper compaction, thereis potential harborage for rodents and potential subsi-dence in the surface of the landfill that can lead toinadequate cover in the completed portion of the fill.

This failure to comply with the Regulations (that com-paction is required) was brought to our attention by anengineering firm retained by BLM to evaluate this andother landfills.

As you know, there has never been a prohibition onbiomedical waste .being included with other refuse in theSunrise covered landfill.

Therefore, to comply with the Regulations, daily coverand compaction must be made of waste deposited in thelandfill.

If you have questions regarding this matter, please donot hesitate to contact this office.

Sincerely,

CLARK COUNTY HEALTH DISTRICT

olt, M.D.h Officer

OR: 1mxc: State Division of Environmental Protection

Clark County Department of Comprehensive PlanningClark County Public Works Department

bxc: Dr. UeckertSupervisors /Landfill File *Reading Files

Copies to Subjeat/Landfill

United States Department of the InteriorBUREAU OF LAND MANAGEMENT

STATELINE RESOURCE AREA • '4765 VEGAS DRIVE ,„«,., V.^M,

P.O.BOX 26569 4212-4LAS VEGAS . NEVADA 89126 (NV-053

Mr. Cliff Judkins, SanitarianClark County Health District MAY 0 i J950625 Shadow LaneLas Vegas, NV-89127

Dear Mr. Judkins:

Recently, representatives of Advanced Sciences, Inc., a BLM contractor, havevisited your office seeking information with regard to solid waste disposalsites at Las Vegas, Moapa, Indian Springs, Overton and Blue Diamond. Inaddition, they will be visiting the Mesquite and Henderson land fills whichare no longer administered by Clark County public works. Advanced Sciences,Inc., is contracted by BLM to audit land fills authorized under the Recreationand Public Purposes Act for compliance with Federal regulations (SWMA 4 RCRA)and state regulations. I have included a brochure which explains theprocess. As soon as we receive the contractor reports, we will discuss themwith Clark County.

Clark County public works personnel have accompanied Advanced Sciences and BLMon a field visit to each of the sites. We appreciate your cooperation insupplying additional background information to what BLM case files andDepartment of Public Works files contained.

I understand the contractors have requested and have been furnished copies ofsome materials. We appreciate the counties cooperation in providing theseinasmuch as both BLM and the county have responsibilities under the laws andBLM is.bearing the costs of the contract audit.

You should also be aware that under a separate BLM contract, CCJM P.C., hasevaluated the following sites in Clark County for compliance with CERCLA.These are Sandy Valley, Henderson, and Searchlight. Representative of CCJMmay also have sought your assistance in their evaluation of these sites.Again, we appreciate county assistance in this evaluation.

Jerry, Wickstrom, Environmental Coordinator for the Las Vegas District is theproject inspector for the Advanced Sciences contract and with regard tooverall coordination of these audits. His telephone number is 647-5054. BobWilson of the BLM Nevada State Office is the project inspector for the CCJMcontract. His telephone number is 785-6573.

/*yRunore Wycoff\y Area Manager

1 Enclosure1. Brochure