1. Removal Action Summary Report WAIMANALO GULCH SANITARY LANDFILLKAPOLEI, OAHU, HAWAII AUGUST 2011

2. CONTENTS ACRONYMS AND ABBREVIATIONS iii CERTIFICATION iv I. SUMMARY OF EVENTS 1 A. Site Conditions and Background 1 1. Initial Situation 1 2. Cause of Release or Discharge 1 B. Organization of the Response 8 C. Chronological Narrative of Response Actions 9 1. Threat Abatement Actions Taken 9 2. Treatment/Disposal/Alternative Technology Approaches Pursued 14 3. Public Information and Community Relations Activities 16 D. Resources Committed 18 II. EFFECTIVENESS OF REMOVAL ACTIONS 18 A. Actions Taken By Operator 18 B. Actions Taken by State and Local Forces 19 C. Actions Taken by Federal Agencies and Special Teams 19 D. Actions Taken by Contractors, Private Groups, and Volunteers 19 III. RECOMMENDATIONS 19 A. Means to Prevent a Recurrence of the Discharge or Release 19 APPENDIXES A Correspondence B Work Plans C Heath and Safety Plan D Letter Reports/CQA Reports E Invoices FIGURES 1 Site Location Map 3 2 Site Layout Map 4 3 Daily Sum of Precipitation Measured at On-Site Rain Gauge 5 4 Daily Sum of Precipitation Measured at Up-Canyon Rain Gauge 6 5 Daily Sum Comparison of Precipitation Measured at On-Site and Up-Canyon Rain Gauges 7 TABLES 1 Major Rain Event Summary 1 2 Monthly Precipitation Summary 1 3 Organization of Response 8 4 Response Action Activities 10 5 Materials/Quantities Pumped during Removal Action 14 6 Total Liquid Disposed of at WWTP 16 7 Costs Incurred to WMH during Response Activities 18 ii 3. ACRONYMS AND ABBREVIATIONS AECOM AECOM Technical Services, Inc. CERCLA Comprehensive Environmental Response, Compensation, and Liability Act City City and County of Honolulu CQA Construction Quality Assurance DOH Department of Health, State of Hawaii EPA Environmental Protection Agency, United States GBI Goodfellow Brothers, Inc. GCL geosynthetic clay liner GEI GEI Consultants, Inc. MSW municipal solid waste Order Administrative Order on Consent for Removal Action, CERCLA Docket No. 09-2011-0007 PCS Pacific Commercial Services, LLC RCRA Resource Conservation and Recovery Act WGSL Waimanalo Gulch Sanitary Landfill WMH Waste Management of Hawaii, Inc. WWTF wastewater treatment facility 3 ydcubic yards iii 4. Removal Action Summary Report August 2011 Waimanalo Gulch Sanitary Landfill, Kapolei, Oahu, HI Page 1 of 19 I. SUMMARY OF EVENTS A. SITE CONDITIONS AND BACKGROUND 1. Initial Situation The Waimanalo Gulch Sanitary Landfill (WGSL) is an active municipal solid waste (MSW) disposal facility located at 92-460 Farrington Highway in Kapolei, Oahu, Hawaii and is owned by the City and County of Honolulu (City). Waste Management of Hawaii, Inc. (WMH) is contracted by the City to manage and operate the landfill. WGSL is the only operating municipal solid waste landfill (MSW) on the island of Oahu and receives commercial and residential wastes generated within Oahu, as well as ash and residue from the H-Power power plant. See Figure 1 for a site location map and Figure 2 for a site layout map. A series of storm events occurring in late December 2010 through mid-January 2011 resulted in high surface stormwater run-on flows that flooded one of the MSW cells (Cell E6) and damaged portions of the liner system. The resultant runoff from the January 12th and 13th storm may have carried waste materials into the WGSL storm water conveyance system, which flows into the sedimentation basin prior to leaving the site at the permitted discharge point and onward to the Pacific Ocean. A removal action was required by the Administrative Order on Consent for Removal Action, Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Docket Number 09-2011-0007 (Order). While stormwater flowing from Cell E6 likely entrained some waste materials, waste materials from other areas of the landfill could also have been dislodged and entrained in stormwater that also flowed to the conveyance system. 2. Cause of Release or Discharge In late December 2010, a series of storms produced high stormwater run-on at the site resulting in damage to the northeastern edge of the MSW Cell E6 liner where it joins with Cell E4. An even larger storm arrived on the evening of January 12, 2011 that resulted in additional flooding of the landfill and damaged the exposed portion of the western sideslope area of the MSW Cell E6 liner system. Table 1 summarizes the daily precipitation of the major storm events prior to the release from the site. Rain data is provided for an on-site down gradient rain gauge located at the administration building and a rain gauge located up-canyon of the site. Monthly summaries for the December 2010 and January 2011 daily precipitation is presented in Table 2. Daily summaries of the rain precipitation for the period of December 1, 2010 to June 21, 2011 are presented in Figure 3 5. Table 1: Major Rain Event Summary Daily Precipitation (in) Date On-Site Gauge Daily Precipitation (in) Up-Canyon Gauge 12/19/2010 5.4 8.4 12/27/2010 2.2 4.3 1/12/2011 5.0 9.2 1/13/2011 2.0 10.3 Table 2: Monthly Precipitation Summary Daily Precipitation (in) Month On-Site Gauge Daily Precipitation (in) Up-Canyon Gauge December 11.9 27.4 January 7.3 20.9 5. Removal Action Summary Report August 2011 Waimanalo Gulch Sanitary Landfill, Kapolei, Oahu, HI Page 2 of 19 ththThe high water flows during the January 12 -13storm resulted in erosion of the Cell E6 termination bench and exposed the operations layer soils covering the sideslope liner, thereby exposing the liner to subsequent damage by falling rocks in addition to allowing sections of the liner to pull down from the termination bench creating wrinkles. Due to numerous holes in the exposed sideslope liner at the northern end of the cell caused by falling rocks, water and sediment were able to flow between the geotextile, 60-mil geomembrane, and geosynthetic clay liner (GCL) layers. Portions of the GCL in the middle area of the sideslope area were hydrated and covered with sediment due to the water and sediment flow. A Severe Storm Damage Report (included in Appendix D) documents the inspection that followed the January 12-13, 2011 storm event. The inspection found several damaged areas including flooding of the MSW Cell E6 and damage to the drainage structures, landfill liner, drainage swales, and access roads. 6. LEGENDPROJECT LOCATION 7. 654 Daily Precipitation (in) 3210Figure 3: Daily Sum of Precipitation Measured at On-Site Rain GaugeSource: WGSL on-site rain gauge located at the administration building. 8. 12 108Daily Precipitation (in)6420Figure 4: Daily Sum of Precipitation Measured at Up-Canyon Rain Gauge Source: Data from rain gauge MPLHHL located up-canyon of the WGSL.Weather Underground. 2011. http://www.wunderground.com/cgi-bin/findweather/getForecast?query=Kapolei, Hawaii. June (6/23/11). 9. 12 108Daily Precipitation (in) 64On-Site Up-Canyon20Figure 5: Daily Sum Comparison of Precipitation Measured at On-Site and Up- Canyon Rain Gauges 10. Removal Action Summary Report August 2011 Waimanalo Gulch Sanitary Landfill, Kapolei, Oahu, HI Page 8 of 19 B. ORGANIZATION OF THE RESPONSE Response actions were conducted in accordance with the timeline mandated by the Order. As specified in the Order, WMH retained several contractors to perform the work required by the EPA, and notified the EPA and DOH of the names and qualifications of the contractors within two days of the Effective Date. The Effective Date of the Order was January 25, 2011 and the submittal of the contractors was made on the same day, correspondence is presented in Appendix A. Contractors used during the removal action are identified in Table 3. WMH designated Joseph Whelan as Project Coordinator. As required by the Order, Mr. Whelan was present on site and/or readily available during site work. Correspondence between the Project Coordinator and the EPA is presented in Appendix A. Table 3: Organization of Response Agencies or Parties Involved Contact Description of Participation EPA Region 9 (SFD-9) Bret Moxley EPA On-Scene Coordinator (OSC) 75 Hawthorne Street San Francisco, CA 94105 EPA Region 9 (WST-5) Katherine Baylor RCRA Action Officer (RAO) 75 Hawthorne Street San Francisco, CA 94105 DOH, Environmental Management Division Stuart Yamada, P.E., Chief State Agency Oversight 919 Ala Moana Blvd., Room 300 Honolulu, HI 96814-4920 City and County of Honolulu, Department of Wilma Namumnart, P.E. Acting Landfill Owner Environmental Services, Refuse Division Chief 1000 Uluohia Street, Suite 212 Kapolei, HI 96707 WMH Joe Whelan, General Manager Project Coordinator/ 92-460 Farrington Highway Landfill Operator Kapolei, HI 96707 GEI William A. Rettberg, P.E. Western Drainage Project Design 180 Grand Ave, Ste 1410 Engineer Contractor Oakland, California 94612 Geosyntec Consultants, Inc. Hari D. Sharma, Ph.D., P.E. Liner System Design Engineer 180 Grand Ave, Ste 1410 Contractor Oakland, CA 94612 PCS Jingbo Chang, Ph.D. Storm Water/Leachate Disposal PO Box 235117 Contractor Honolulu, HI 96823 GBI Matt Heahlke Earthwork/Construction Contractor 93-061 Waipio Point Access Road Waipahu, HI 96797 AECOM Ron Boyle, P.E. Construction Quality Assurance 1001 Bishop St, Ste 1600 Contractor Honolulu, HI 96813 AECOM AECOM Technical Services, Inc. DOH Department of Health, State of Hawaii EPA Environmental Protection Agency, United States GBI Goodfellow Brothers, Inc. GEI GEI Consultants, Inc. PCS Pacific Commercial Services, LLC 11. Removal Action Summary Report August 2011 Waimanalo Gulch Sanitary Landfill, Kapolei, Oahu, HI Page 9 of 19 C. CHRONOLOGICAL NARRATIVE OF RESPONSE ACTIONS The follow sections detail the response actions taken. The response was performed in accordance with the Order, under the authority of CERCLA. 1. Threat Abatement Actions Taken Measures taken to prevent future storm damage at the site and to document efforts to further contain potential storm water and prevent waste material from exiting the facility in the event of additional storm events are described in the Stormwater Management Update and Contingency Plan. This document was updated several times throughout the response action; the three versions dated January 27, 2011, February 1, 2011 and February 18, 2011 are presented in Appendix B. Table 4 presents the response actions completed during the removal action, in chronological order, as outlined in Section VIII of the Order. 12. Removal Action Summary Report August 2011 Waimanalo Gulch Sanitary Landfill, Kapolei, Oahu, HI Page 10 of 19 Table 4: Response Action Activities Item Subject Administrative Order Action Requirement 19g. Operation of Cell E6 Respondent shall not operate cell #E6 without further approval from EPA. Action Taken: In an e-mail dated January 28, 2011 the EPA approved WMH to resume operations on the east side of Cell E6, correspondence is presented in Appendix A. 19c. Storm Water Discharge Respondent shall ensure the termination of discharges of liquid originated from cell #E6 to the Pacific Ocean, except as in compliance with any applicable permit. Action Taken: Storm water discharges were in compliance with the applicable permits, or were approved by the DOH. 20. Work Plans and Respondent shall submit to EPA for approval a draft Work Plan or individual Work Plans for performing the response Implementation actions generally described in Paragraph 19 of the Order. EPA may approve, disapprove, require revision to or modify any draft Work Plan in whole or in part. If EPA requires revisions, Respondents hall submit a revised draft Work Plan within fifteen (15) days of receipt of EPAs notification of the required revision. Respondent shall implement each respective Work Plan as approved in writing by EPA in accordance with its schedule approved by EPA. Once approve, or approved with modifications, each Work Plan, its schedule, and any subsequent modifications shall be incorporated into and become fully enforceable under this Order. Respondent shall not conduct any Work except in conformance with the terms of this Order, or as directed by EPA. Action Taken: All work plans were submitted to the EPA for approval and revised according to schedule. Correspondence for submittals and work plans are presented in Appendix A and Appendix B, respectively. 22. Quality Assurance and Although none is presently anticipated, all sampling and analyses performed pursuant to this Order shall conform to EPA Sampling direction, approval, and guidance regarding sampling, quality assurance/quality control ("QA/QC"), data validation, and chain of custody procedures. Action Taken: Sampling was not performed for EPA reporting purposes and as part of the removal action. 24. Reporting Beginning two (2) days after the Effective Date, Respondent shall submit by e-mail to EPA and DOH daily, until agreed otherwise by the Parties, progress reports (Monday through Friday only, unless otherwise requested by EPA) concerning actions undertaken pursuant to this Order, until receipt of the Notice of Completion pursuant to this Order, unless otherwise directed in writing by the OSC or RAO. These reports shall describe all significant developments during the preceding period, including the actions performed and any problems encountered, analytical data received during the reporting period, and the developments anticipated during the next reporting period, including a schedule of actions to be performed under any approved Work Plan, anticipated problems, and planned resolutions of past or anticipated problems. Respondent shall submit copies of all plans, reports (other than progress reports) or other submissions required by this Order, or any approved Work Plan, to both EPA and DOH in electronic form (Word or pdf - minimum 300 dpi). 13. Removal Action Summary Report August 2011 Waimanalo Gulch Sanitary Landfill, Kapolei, Oahu, HI Page 11 of 19 Item Subject Administrative Order Action Requirement Action Taken: WMH submitted Daily Progress Reports as required by the EPA. All e-mail correspondence is presented chronologically in Appendix A. Copies of all documents required by the Order were submitted electronically. The documents included: Stability analysis of temporary earthen berm by a Civil/Geotechnical Engineer (Appendix D) Work Plans (Appendix B): o Collection and Transport of Liquid Behind Temporary Berm o Slope Stability Analysis and Work Plan for Temporary Earthen Berm Integrity o Work Plan for Managing Potential Cell E6 Hydraulic Head o Work Plan for Liner Evaluation and Repair o Work Plan for Restoration of Sedimentation Basin o Work Plan For Beach Assessment and Material Recovery Effort Written description of collection/treatment activities of liquids (presented in the Daily Progress Reports in Appendix A) Health and Safety Plan (Appendix C) In an e-mail dated March 17, 2011, the EPA granted the WMH request to replace daily progress reports with a weekly report submitted by noon every Wednesday, documenting work completed during the period of the prior Monday thru Sunday. In an e-mail dated June 22, 2011, the EPA granted the WMH request to terminate the weekly progress reports. 19d. Storm water Removal Respondent shall continue to collect and transport to a local treatment facility the liquids at the site retained behind the temporary earthen berm in cell #E6. Within seven (7) days of the Effective Date, Respondent shall provide a written description of the collection and treatment activities, the current permitting and the chemical parameters of the liquids, and transportation methods to the local treatment facility. Action Taken: Storm water was pumped and transported to a WWTP in Kailua, HI. The first work plan was submitted on February 1, 2011. In an e-mail dated February 10, 2011, the EPA noted that the description of collection and treatment associated with liquid located behind the temporary berm were acceptable with incorporation of the provided comments; revisions and resubmission were required. The revised work plan was submitted on February 25, 2011 and is included in Appendix B. 21. Health and Safety Plan Within seven (7) days, Respondent shall submit for EPA review and comment a Site Health and Safety Plan that ensures the protection of the public health and safety during performance of on-Site Work. This plan shall be prepared in accordance with EPAs Standard Operating Safety Guide (PUB 9285.1-03, PB 92-963414, June 1992), if applicable. In addition, the plan shall comply with all currently applicable Occupational Safety and Health Administration ("OSHA") regulations found at 29 CRF Part 1910. Action Taken: A site Health and Safety Plan was submitted on February 1, 2011 and is presented in Appendix C. 19e. Work Plan for Hydraulic Within seven (7) days of the Effective Date, Respondent shall provide to EPA and DOH a Work Plan and schedule, Head subject to modification based on further field analysis, for managing the hydraulic head between cell #E6 and the fluids outside of cell #E6 in order to maintain the integrity of the cell liner as the fluids are drawn down and the leachate collection system is returned to normal functions. 14. Removal Action Summary Report August 2011 Waimanalo Gulch Sanitary Landfill, Kapolei, Oahu, HI Page 12 of 19 Item Subject Administrative Order Action Requirement Action Taken: The work plan was submitted on February 1, 2011 and is presented in Appendix B. In an e-mail dated February 10, 2011, the EPA approved the work plan. The Evaluation of Hydraulic Head Below Liner System Summary Report was submitted to the EPA on February 25. The e-mail submittal is included in Appendix A and a copy of the summary report is included in Appendix D. 19h. Work Plan and Within seven (7) days of the Effective Date, Respondent shall provide to EPA and DOH a Work Plan and schedule to Schedule for Sediment restore the sediment basin system to its intended capacity and function. This shall include removal of the sediment Basin Restoration collected in the basin(s) and the proposed disposal location for the collected sediments Action Taken: The work plan was submitted on February 1, 2011 and is presented in Appendix B. In an e-mail dated February 10, 2011, the EPA noted that the submitted work plan was acceptable with incorporation of provided comments; revision and resubmissions were required. In e-mail dated March 4, 2011, the work plan was approved, and suggested a completion date of March 14, 2011. However, due to continued rain events during the restoration of the basin, WMH requested a later deadline of May 15, 2011. After continued rain events, WMH requested an additional extension via e-mail on May 5, 2011. In an e-mail dated May 6, 2011, the EPA approved an extension to June 15, 2011. In an e-mail dated June 15, 2011 WMH submitted the Sedimentation Basin Restoration Observation Report. Following comments provided by the EPA, additional work was conducted on the sediment basin and an Addendum report was submitted on August 4, 2011. The submittal correspondence is presented in Appendix A and the reports are included in Appendix D. 19i. Work Plan and Within seven (7) days of the Effective Date, Respondent shall provide to EPA and DOH a Work Plan and schedule for Schedule for Beach ongoing daily beach assessment and recovery of Waste Material released from the WGSL. Assessment and Debris Recovery Action Taken: The work plan was submitted on February 1, 2011 and is presented in Appendix B. In an e-mail dated February 10, 2011, the EPA noted that the submitted work plan was acceptable with incorporation of provided comments; revision and resubmissions were required. In an e-mail dated March 4, 2011, the EPA approved the work plan. The work plan is presented in Appendix B. After a final beach assessment on January 24, 2011, WMH noted that the daily beach assessment phase was complete; no calls were received at the established beach waste hot line during the subsequent reporting periods. 19a. Temporary Earthen Within ten (10) days of the Effective Date, Respondent shall provide to EPA and DOH an analysis by a qualified Civil or Berm Geotechnical Engineer of the stability and suitability of the temporary earthen berm, which is currently retaining liquid in cell #E6, to retain liquid when full to within one (1) foot of the top for up to six (6) weeks, and a Work Plan to ensure the integrity of the temporary earthen berm so long as it is holding liquid Action Taken: A report entitled Slope Stability Analysis and Work Plan for Temporary Earthen Berm Integrity was submitted to the EPA on February 4, 2011 by e-mail and Certified Mail. The report found that the temporary berm met and/or exceeded minimum accepted factors of safety and no modifications were necessary. The e-mail and report can be found in Appendix A and Appendix B, respectively. 19f. Work Plan and Within fourteen (14) days of the Effective Date, Respondent shall provide to EPA and DOH a Work Plan and schedule to Schedule for E6 Liner evaluate and demonstrate or restore the integrity of the liner system in cell #E6 Repair 15. Removal Action Summary Report August 2011 Waimanalo Gulch Sanitary Landfill, Kapolei, Oahu, HI Page 13 of 19 Item Subject Administrative Order Action Requirement Action Taken: The work plan was submitted to the EPA on February 4, 2011. In an e-mail dated February 10, 2011, the EPA noted that the submitted work plan was acceptable; revision and resubmissions were not required. Submittal correspondence is included in Appendix A and a copy of the work plan is presented in Appendix B. CQA reports documenting the liner repairs related to the storm damage was submitted under separate cover as specific areas were repaired. Copies of the CQA repair reports are included in Appendix D. 19b. Storm water Diversion Within twenty-one (21) days of the Effective Date, Respondent shall complete construction of a functional storm water Structure diversion structure on the west side above cell #E6. Action Taken: In an e-mail dated February 15, 2011, WMH confirmed that construction of a functional storm water diversion structure located on the west side above Cell E6 was functionally complete. In an e-mail dated February 16, 2011, the EPA concurred that WMH completed construction of a functional storm water diversion structure as required by paragraph 19b. In addition, in an e-mail dated March 11, 2011, WMH submitted a revised Surface Water Management Plan to the EPA and DOH. All correspondence is presented in Appendix A, and the Surface Water Management Plan is in Appendix D. 25. Final Report Within sixty (60) days after completion of all Work required by this Order, Respondent shall submit for EPA review and approval a final report summarizing the actions taken to comply with this Order. The final report shall conform, at a minimum, with the requirements set forth in Section 300.165 of the NCP entitled "OSC Reports." The final report shall include a good faith estimate of total costs or a statement of actual costs incurred in complying with the Order, a listing of quantities and types of materials removed off-Site or handled on-Site, a discussion of removal and disposal options considered for those materials, a listing of the ultimate destination(s) of those materials, a presentation of the analytical results of all sampling and analyses performed, and accompanying appendices containing all relevant documentation generated during the removal action (e.g., manifests, invoices, bills, contracts, and permits). The final report shall also include the following certification signed by a person who supervised or directed the preparation of that report: "Under penalty of law, I certify that to the best of my knowledge, after appropriate inquiries of all relevant persons involved in the preparation of the report, the information submitted is true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations." Action Taken: This report fulfills the requirements described in Paragraph 25. 26. Off-site Shipments Respondent shall, prior to any off-Site shipment of Waste Material from the Site to an out-of-state waste management facility, provide written notification of such shipment of Waste Material to the appropriate state environmental official in the receiving facilitys state and to the OSC and RAO. Action Taken: No Waste Material, as defined in Section III.r of the Order, was shipped off-site during the response activities. CQA Construction Quality Assurance WWTP wastewater treatment plant 16. Removal Action Summary Report August 2011 Waimanalo Gulch Sanitary Landfill, Kapolei, Oahu, HI Page 14 of 19 2. Treatment/Disposal/Alternative Technology Approaches Pursued WMH contracted Pacific Commercial Services, LLC (PCS) to pump and transfer storm water to the wastewater treatment plant (WWTP) in Kailua, HI. A summary of the materials pumped during the removal action is presented in Table 5. In addition to the material shown in Table 5, WMH removed 3approximately 806,500 gallons of storm water and 14,610 cubic yards (yd ) of sediment from the sedimentation basin during the restoration activities, as discussed in the Sedimentation Basin Restoration Observation Report dated June 15, 2011 (included in Appendix D). A summary of the liquid transported and disposed of at the WWTP is presented in Table 6. Note that quantities of liquid pumped and transported by the City during the removal action are not included in this report. Table 5: Materials/Quantities Pumped during Removal Action Reporting Date Location Amount Pumped (gallons) Material Disposal Area 1/27/11 Cell E6 Leachate Riser 12,000 mud On-site 1/27/11 Sedimentation Basin 60,000 Water WWTP 1/28/11 Cell E6 Leachate Riser 20,321 Silt On-site 1/28/11 Sedimentation Basin 60,000 Water WWTP 1/31/11 Cell E6 Leachate Riser 2 ft Silt On-site 1/31/11 Sedimentation Basin 274,000 Water WWTP 2/1/11 Cell E6 Leachate Riser 16,500 Water WWTP 2/1/11 Cell E6 Leachate Riser 16,000 Mud/Water Mixture Frac Tanks for Separation 2/1/11 Sedimentation Basin 56,000 Water WWTP 2/2/11 Cell E6 Leachate Riser 16,500 Water WWTP 2/2/11 Cell E6 Leachate Riser 10,000 Mud/Water Mixture Frac Tanks for Separation 2/2/11 Sedimentation Basin 105,800 Water WWTP 2/3/11 Cell E6 Leachate Riser 12,500 Mud/Water Mixture Frac Tanks for Separation 2/3/11 Sedimentation Basin 55,800 Water WWTP 2/4/11 Cell E6 Leachate Riser 10,000 Mud/Water Mixture Frac Tanks for Separation 2/4/11 Sedimentation Basin 61,500 Water WWTP 2/7/11 Cell E6 Leachate Riser 2,500 Mud/Water Mixture Frac Tanks for Separation 2/7/11 Sedimentation Basin 24,700 Water WWTP 2/8/11 Sedimentation Basin 44,800 Water WWTP 2/9/11 Sedimentation basin 52,277 Water WWTP 2/10/11 Cell E6 Leachate Riser 19,350 Mud/Water Mixture Frac Tanks for Separation 2/10/11 Frac Tanks 16,500 Water WWTP 2/10/11 Sedimentation Basin 41,249 Water WWTP 2/11/11 Cell E6 Leachate Riser 9,675 Mud/Water Mixture Frac Tanks for Separation 2/11/12 Sedimentation Basin 19,350 Water WWTP 2/14/11 Cell E6 32,818 Water WWTP 2/14/11 Cell E6 Leachate Riser 27,000 Mud/Water Mixture Frac Tanks for Separation 2/14/11 Sedimentation Basin 32,700 Water WWTP 2/15/11 Cell E6 47,759 Water WWTP 2/15/11 Cell E6 Leachate Riser 44,000 Mud/Water Mixture Frac Tanks for Separation 2/15/11 Sedimentation Basin 17,318 Water WWTP 2/16/11 Cell E6 18,100 Water WWTP 2/16/11 Cell E6 Leachate Riser 33,200 Water WWTP 2/16/11 Cell E6 Leachate Riser 27,700 Mud/Water Mixture Frac Tanks for Separation 2/17/11 Cell E6 Leachate Riser 55,000 Mud/Water Mixture Frac Tanks for Separation 17. Removal Action Summary Report August 2011 Waimanalo Gulch Sanitary Landfill, Kapolei, Oahu, HI Page 15 of 19 Reporting Date Location Amount Pumped (gallons) Material Disposal Area 2/17/11 Sedimentation Basin 31,675 Water WWTP 2/1711 Sedimentation Basin -- Silt/Rock Lined portion of Cell E6 2/18/11 Frac Tanks 56,700 Water WWTP 2/18/11 Sedimentation Basin 57,718 Water WWTP 2/18/11 Sedimentation Basin -- Silt/Rock Lined portion of Cell E6 2/21/11 Frac Tanks 108,000 Water WWTP 2/21/11 Sedimentation Basin -- Silt/Rock Lined portion of Cell E6 2/22/11 Frac Tanks 33,900 Water WWTP 2/22/11 Sedimentation Basin -- Silt/Rock Lined portion of Cell E6 2/23/11 Sedimentation Basin 41,700 Water WWTP 2/24/11 Sedimentation Basin 54,900 Water WWTP 2/25/11 Sedimentation Basin 56,800 Water WWTP 2/28/11 Frac Tanks 105,300 Water WWTP 2/28/11 Cell E6 Leachate Riser 33,200 Water WWTP South Pond Area 2/28/11 Cell E6 Leachate Riser 30,772 Mud/Water Mixture Frac Tanks for Separation South Pond Area 2/28/11 Sedimentation Basin 8,700 Water WWTP 3/1/11 Frac Tanks 30,700 Water WWTP 3/1/11 Cell E6 Leachate Riser 11,000 Water WWTP South Pond Area 3/1/11 Sedimentation Basin 15,500 Water WWTP 3/2/11 Frac Tanks 13,000 Water WWTP 3/2/11 Sedimentation Basin 40,000 Water WWTP 3/3/11 Frac Tanks 12,018 Water WWTP 3/3/11 Cell E6 Leachate Riser 25,000 Water WWTP South Pond Area 3/3/11 Sedimentation Basin 51,000 Water WWTP 3/4/11 Frac Tanks 14,949 Water WWTP 3/4/11 Sedimentation Basin 59,700 Water WWTP 3/7/11 Frac Tanks 36,200 Water WWTP 3/7/11 Sedimentation Basin 113,000 Water WWTP 3/8/11 Sedimentation Basin 76,200 Water WWTP 3/9/11 Frac Tanks 15,100 Water WWTP 3/9/11 Sedimentation Basin 75,300 Water WWTP 3/10/11 Frac Tanks 6,359 Water WWTP 3/10/11 Sedimentation Basin 84,000 Water WWTP 3/11/11 Frac Tanks 3,159 Water WWTP 3/11/11 Sedimentation Basin 26,500 Water WWTP 3/14/11 Frac Tanks 20,677 Water WWTP 3/14/11 Sedimentation Basin 126,000 Water WWTP 3/15/11 Frac Tanks 8,769 Water WWTP 3/15/11 Cell E6 Leachate Riser 1,518 Water WWTP South Pond Area 3/15/11 Sedimentation Basin 71,476 Water WWTP 3/16/11 Frac Tanks 6,318 Water WWTP 3/16/11 Cell E6 Leachate Riser 1,300 Water WWTP 18. Removal Action Summary Report August 2011 Waimanalo Gulch Sanitary Landfill, Kapolei, Oahu, HI Page 16 of 19 Reporting Date Location Amount Pumped (gallons) Material Disposal Area South Pond Area 3/16/11 Sedimentation Basin 91,400 Water WWTP Week Ending 3/20/11 Frac Tanks 31,698 Water WWTP Week Ending 3/20/11 Sedimentation Basin 221,300 Water WWTP Week Ending 3/27/11 Frac Tanks 52,434 Water WWTP Week Ending 3/27/11 Sedimentation Basin 105,900 Water WWTP Week Ending 4/3/11 Frac Tanks 51,663 Water WWTP Week Ending 4/10/11 Frac Tanks 35,586 Water WWTP Week Ending 4/10/11 Sedimentation Basin 15,000 Water On-Site (Dust Control)a Week Ending 4/17/11 Frac Tanks 26,006 Water WWTP Week Ending 4/24/11 Frac Tanks 4,159 Water WWTP Week Ending 5/1/11 Frac Tanks 1,000 Water WWTP Week Ending 5/8/11 Frac Tanks 63,611 Water WWTP Week Ending 5/15/11 Frac Tanks 9,477 Water WWTP Week Ending 5/22/11 Frac Tanks 56,914 Water WWTP Week Ending 5/29/11 Frac Tank 25,216 Water WWTP Week Ending 6/3/11 Frac Tank 34,075 Water WWTP Week Ending 6/12/11 Frac Tanks 33,343 Water WWTP Notes: a Approval via e-mail from DOH dated 3/23/11 to use sedimentation basin storm water for onsite dust control and irrigation. The quantity of water pumped was no longer recorded after this date. Table 6: Total Liquid Disposed of at WWTP Origin Total Liquid Disposed of between 1/28/2011 6/12/2011 (gallons) c Cell E6 98,677 aCell 6 Leachate Riser 138,218 Frac Tanks 853,540 Sedimentation Basin b 2,314,263 TOTAL 3,306,021 Notes: a Does not include mud/water mixture pumped into frac tanks on site. b Does not include storm water pumped to use for onsite dust control and irrigation. c Quantities of liquid do not include liquid pumped by the City from Cell E6 and the sedimentation basin. 3. Public Information and Community Relations Activities WMH and the City published several press releases summarizing the response activities. Press releases are included in Appendix A for the following dates: January 24, 2011, January 25, 2011, January 31, 2011, February 8, 2011, and February 15, 2011. As presented in the January 24, 2011 press release, a summary of the public notices, shoreline cleanup activities, and reporting hotline includes the following: Thursday, January 13 WMH evaluated storm water conditions throughout the day of the storm event and determined that a large body of storm water had collected in the area of the new cell construction. Working in collaboration with the DOH, WM, and the City installed warning signs in the shoreline area of the Ko Olina Resort, where the landfill outfall is located, and along the associated beach shoreline. Additionally, WMH and the City began a water quality sampling program that same day. Later on January 13, WMH began debris 19. Removal Action Summary Report August 2011 Waimanalo Gulch Sanitary Landfill, Kapolei, Oahu, HI Page 17 of 19 cleanup at the overflow and the storm water sedimentation basin once the flood waters had subsided enough to perform this operation safely. At that time, it was determined that the debris also contained sterilized medical waste. Friday, January 14 WMH dispatched an evaluation and cleanup team to the ocean side of the landfills permitted storm water outfall, located on the north end of the Ko Olina Resort property across Farrington Highway from the landfill. The crew spent several hours cleaning debris from this area. At the time, there was no apparent evidence of remaining medical waste material. WMH continued to clean up areas located between the sediment basin and the permitted outfall. Also on January 14, representatives of WMH, the City, and DOH held a press conference at the landfill to further inform the public of potential concerns associated with the storm events, and to provide an update on the cleanup efforts, warning sign postings, and water quality sampling being performed by WMH and the City. Numerous news interviews and media announcements were provided by all parties over the following several days in order to keep the public fully informed. Saturday, January 15 WMH personnel continued evaluation of the shoreline area. In the afternoon, additional medical waste material was reported in the WMH outfall area located near the Ko Olina Resort area. Sunday, January 16 At 7 a.m., WMH sent its cleanup crew back to the area and evaluated an approximate one-half to three-quarters of a mile section of the beach, including a return to the outfall area. No further medical waste was noted by WMH personnel at this time. Additionally, a hotline was also set up to provide the public with the opportunity to report any observations of medical waste material found on local beaches. The DOH announced the hotline to the public via news media, and WMH representatives continued to remind news media to include the hotline in any further media updates. WMH representatives used reports provided via the hotline to evaluate information and determine where to concentrate its ongoing daily cleanup efforts. Subsequently, in the afternoon of January 16, WMH was notified that some plastic syringes (absent needles) had been found at the White Plains beach located farther south on the shoreline. WMH dispatched cleanup crews to this beach, as well as the Kahe public beach located to the north of the WMH permitted outfall. Monday, January 17 By 8 a.m., WMH cleanup crews were sent to all three of the aforementioned areas and collected additional debris from the shoreline, including what appeared to be a lessening amount of medical waste. Tuesday, January 18 By 8 a.m., WMH dispatched cleanup crews, initially focusing attention at Nimitz beach, followed by White Plains, and then the storm water outfall. Wednesday, January 19 By 8 a.m., the cleanup team returned to Kahe beach, the storm water outfall, and then Nimitz and White Plains beaches, in order. Crews also continued to be responsive to reported findings from the public. Thursday, January 20 By 8 a.m., personnel split into two teams, with one team returning to Kahe beach and the storm water outfall, and the other team returning to Nimitz and White Plains beaches. Crews also continued to be responsive to reported findings from the public. Friday, January 21 Beginning at 8 a.m., the cleanup team returned to Kahe, Nimitz and White Plains beaches, as well as the storm water outfall. The WMH team found no medical waste. Monday, January 24 WMH performed a final beach assessment and observed no waste attributed to the WGSL. 20. Removal Action Summary Report August 2011 Waimanalo Gulch Sanitary Landfill, Kapolei, Oahu, HI Page 18 of 19 D. RESOURCES COMMITTED Table 7 summarizes WMHs good faith estimate of the costs incurred by WMH during the removal action. During the removal action, WMH spent approximately $2,252,501.64 on third party costs. This cost estimate does not include internal costs (e.g., labor) incurred by WMH or the City. Invoices and backup for the costs incurred area are presented in Appendix E. Table 7: Costs Incurred to WMH during Response Activities Invoice No. Date Contractor Description Amount 2248 2/11/11 PCS Vacuum truck and misc. storm clean up $11,580.12 2249 R 2/11/11 PCS E6 South Pond $168,604.33 (Revised 5/19/11) 2261 4/15/11 GBI Storm Water Response $103,322.45 2262 4/15/11 GBI Storm Water Response, Repair liner in E6, E6 Sump $220,761.00 work 2263 4/15/11 GBI Storm Water Response, Repair liner in E6, E6 Sump $353,526.73 work 2267 4/30/11 American Storm Related Liner Repairs $78,901.26 Environmental Group, LTD 2268 4/30/11 Watanabe Ing, LLP Storm Event Legal Fees $45,126.86 2269 4/30/11 AECOM Storm Event Sampling $17,935.67 2270 4/30/11 GEI Storm Event Work Plans $19,204.75 2274 5/19/11 GBI Storm Related Costs including Repair Liner, E6 $125,918.41 Leachate sump, repair damage to slope of West Berm Phase III 2277 5/23/11 AECOM CQA for Storm Event Costs $40,008.62 2278 5/26/11 Security Cost Increase $10,502.62 2279 5/24/11 PCS Leachate $242,562.88 2280 5/23/11 PCS Miscellaneous Storm Event Charges $4,867.67 2282 5/24/11 PCS Storm Water, Sediment Pond Pumping $226,465.28 2283 5/24/11 PCS Storm Water, Sediment Pond and Cell E6 Pumping $32,565.76 2286 5/24/11 GBI Storm Related Costs including Repair Liner, E6 $250,564.30 Leachate sump, repair damage to slope of West Berm Phase III 2291 6/13/11 GBI Storm Related Costs including Repair Liner, E6 $160,328.86 Leachate sump, repair damage to slope of West Berm Phase III 6705 7/31/11 GBI Sedimentation Basin Restoration $139,754.07 TOTAL $2,252,501.64 Note: Costs do not include WMH markup and Hawaii general excise tax (GET). II. EFFECTIVENESS OF REMOVAL ACTIONS A. ACTIONS TAKEN BY OPERATOR WMH executed all requirements of the Order in a timely manner. When unable to meet initial deadlines, extensions were requested and granted by the EPA. WMH hired subcontractors to perform the required activities on site and communicated regularly with the regulators. 21. Removal Action Summary Report August 2011 Waimanalo Gulch Sanitary Landfill, Kapolei, Oahu, HI Page 19 of 19 B. ACTIONS TAKEN BY STATE AND LOCAL FORCES The DOH Clean Water Branch performed storm water sampling at the site on January 13, 2011 in conjunction with samples collected for WMH by AECOM. Sampling included storm water from the site outfall location, the ocean outfall location, and an up-canyon location. The City provided storm water pumping and transportation to the WWTP, conducted various beach cleanup activities, posted warning signs surrounding beaches, and provided public notices via press releases of the activities going on at WGSL. C. ACTIONS TAKEN BY FEDERAL AGENCIES AND SPECIAL TEAMS The EPA Region 9 office provided oversight of all response action activities including the On-Scene Coordinator and the RCRA Action Officer including review of the daily and weekly progress reports, and review/approval of all work plans and reports that were initiated as a result of the Order. D. ACTIONS TAKEN BY CONTRACTORS, PRIVATE GROUPS, AND VOLUNTEERS GEI Consultants, Inc. and Geosyntec Consultants, Inc. provided work plans for the activities required by the Order. PCS provided pumping and transport services for the storm water. GBI performed general earthwork and construction services during the execution of the work plans. AECOM provided Construction Quality Assurance oversight of the activities including documentation of work performed. Volunteers were not present on site during the removal action; however, some volunteers in the surrounding community helped clear storm drains, sewer lines, and City beaches after the storm. However, these activities were not part of the response action. III. RECOMMENDATIONS A. MEANS TO PREVENT A RECURRENCE OF THE DISCHARGE OR RELEASE The amount of rain that fell in December 2010 and January 2011 was extremely unusual and not a typical rainfall pattern for the area. The storm event concluding on January 13th was described as a 100-year storm event. Based on rainfall data from the up-canyon Palehua rain gauge, the first major storm that occurred on December 19-20, 2010 generated a total recorded rainfall at the Palehua station of 10.44 inches. The second significant rain event occurred on December 26-27 and generated a total recorded rainfall at the nearby Palehua weather station of station of 5.68 inches. The storm was significant because it occurred less than one week after the December 19-20 storm. The third and largest storm occurred on January 12-13, 2011. The storm produced 12.21 inches of rain in total, with 10.68 inches of rain falling in a 24-hour period. Most significant was the short-term intensity of this storm, which generated 7.63 inches of rain during a 6-hour period, 6.23 inches of rain over a 3-hour period, and 3.65 inches of rain over a 1-hour period. Prior to completion of the western storm water diversion system, run-on to the WGSL was managed with on-site surface water conveyance systems which routed storm water through the site. The western storm water diversion system (also described as the offsite surface water conveyance) is designed bypass the 24-hour, 25-year storm flows and can handle flow from a 100-year, 24-hour storm with minimal or no damage occurring. When all portions of the system are completed, the system will bypass run-on around the landfill and discharge to a stilling basin to be constructed below the existing sedimentation basin. The upper portion of the western storm water diversion system was functionally complete on February 15, 2011 and constructed per the approved design specifications. A Surface Water Management Plan has been submitted to and approved by the EPA that describes the surface water management features present at WGSL. More information can be found in the Surface Water Management Plan, located in Appendix D. 22. 23. Appendix A Correspondence 24. 25. FOR IMMEDIATE RELEASEMedia Contact:Keith DeMelloMcNeil Wilson Communications(808) 542-5343keith.demello@mwc-anthology.comWASTE MANAGEMENT: UPDATE ON BEACH CLEANUP POST STORMPublic Hotline Remains Open for Reports of Any Further FindingsHONOLULU Jan. 24, 2011 Waste Management of Hawaii (WM) provided an update following the 100-yearstorm that hit Oahu on Jan. 13.The downpour made it necessary for the Waimanalo Gulch Sanitary Landfill, operated by WM for the City andCounty of Honolulu, to discharge storm water into the ocean. The extreme nature of the Jan. 13 floodwatersresulted in an unusual amount of debris.The following is a summary of WM shoreline cleanup activities. The WM cleanup team was also continuouslyresponsive to reported findings from the public. WM established a hotline for individuals to report waste onbeaches near the landfill.Thursday, Jan. 13 WM evaluated storm water conditions throughout the day of the storm event anddetermined that a large body of storm water had collected in the area of the new cell construction.Working in collaboration with the state Department of Health (DOH), WM and the city installed warningsigns in the shoreline area of the Ko Olina Resort, where the landfill outfall is located, and along theassociated beach shoreline. Additionally, WM and the city began a water-quality sampling program thatsame day. Later on Jan. 13, WM began debris cleanup at the overflow and the storm watersedimentation basin once the flood waters had subsided enough to perform this operation safely. Atthat time, it was determined that the debris also contained sterilized medical waste.Friday, Jan. 14 WM dispatched an evaluation and cleanup team to the ocean side of the landfillspermitted storm water outfall, located on the north end of the Ko Olina Resort property acrossFarrington Highway from the landfill. The crew spent several hours cleaning debris from this area. Atthe time, there was no apparent evidence of remaining medical waste material. WM continued to cleanup areas located between the sediment basin and the permitted outfall. Also on Jan. 14,representatives of WM, the city and DOH held a press conference at the landfill to further inform thepublic of potential concerns associated with the storm events, and to provide an update on the cleanupefforts, warning sign postings and water quality sampling being performed by WM and the city.Numerous news interviews and media announcements were provided by all parties over the followingseveral days in order to keep the public fully informed.Saturday, Jan. 15 WM personnel continued evaluation of the shoreline area. In the afternoon,additional medical waste material was reported in the WM outfall area located near the Ko Olina Resortarea.Sunday, Jan. 16 At 7 a.m., WM sent its cleanup crew back to the area and evaluated anapproximate one-half to three-quarters of a mile section of the beach, including a return to the outfallarea. No further medical waste was noted by WM personnel at this time. Additionally, a hotline was alsoset up to provide the public with the opportunity to report any observations of medical waste material(more) 26. Waste Management Provides Update on Beach Cleanup following Jan. 13 StormPage 2 of 2found on local beaches. The DOH announced the hotline to the public via news media, and WMrepresentatives continued to remind news media to include the hotline in any further media updates.WM representatives used reports provided via the hotline to evaluate information and determine whereto concentrate its ongoing daily cleanup efforts. Subsequently, in the afternoon of Jan. 16, WM wasnotified that some plastic syringes (absent needles) had been found at the White Plains beach locatedfarther south on the shoreline. WM dispatched cleanup crews to this beach, as well as the Kahe publicbeach located to the north of the WM permitted outfall.Monday, Jan. 17 By 8 a.m., WM cleanup crews were sent to all three of the aforementioned areasand collected additional debris from the shoreline, including what appeared to be a lessening amount ofmedical waste.Tuesday, Jan. 18 By 8 a.m., WM dispatched cleanup crews, initially focusing attention at Nimitzbeach, followed by White Plains and then the storm water outfall.Wednesday, Jan. 19 By 8 a.m., the cleanup team returned to Kahe beach, the storm water outfall,and then Nimitz and White Plains beaches, in order. Crews also continued to be responsive to reportedfindings from the public.Thursday, Jan. 20 By 8 a.m., personnel split into two teams, with one team returning to Kahe beachand the storm water outfall, and the other team returning to Nimitz and White Plains beaches. Crewsalso continued to be responsive to reported findings from the public.Friday, Jan. 21 Beginning at 8 a.m., the cleanup team returned to Kahe, Nimitz and White Plainsbeaches, as well as the storm water outfall. The WM team found no medical waste.WM is working closely with city and state officials to monitor the beaches until water testing in the area showsnormal levels and they are free of landfill debris. That determination will be made in cooperation with city andstate health officials. These officials, along with the U.S. Environmental Protection Agency, have approved WMprocesses and procedures to clean up these areas.In addition, a diversion channel that would have averted the debris discharge caused by the Jan. 13 storm ismere weeks from completion.WM will continue to maintain its hotline for the foreseeable future. WM encourages anyone who finds waste onbeaches near the landfill to report it by calling (808) 668-2985.Waste Management of Hawaii operates Waimanalo Gulch, West Hawaii and Kekaha Landfills as an integralpart of each countys solid waste management infrastructure. The facilities handle municipal solid waste, whichis heavily regulated, monitored and controlled by local, state and federal government agencies. For moreinformation, visit www.keepinghawaiiclean.com.### 27. FOR IMMEDIATE RELEASEMedia Contact:Keith DeMelloMcNeil Wilson Communications808-539-3482keith.demello@mwc-anthology.com WAIMANALO GULCH LANDFILL AGREES TO WORK PLANS WITH U.S. EPAHONOLULU, Jan. 25, 2011 Waste Management of Hawaii (WM) today announced it has enteredinto a formal agreement with the United States Environmental Protection Agency (EPS) regardingseveral work plans needed to alleviate damage to the Waimanalo Gulch Landfill caused by the 100-year storm of Jan. 13, 2011.The intense storm that hit Oahu made it necessary for the Waimanalo Gulch Landfill, operated byWM for the City and County of Honolulu, to discharge large volumes of storm water from the landfillinto the ocean. Some limited amounts of solid waste were swept along with the storm water anddischarged. WM is working with the EPA, the City and County of Honolulu and the state Departmentof Health to develop written plans that detail the steps that will be taken to clean up the landfill.In the interest of keeping all parties informed, we want to let everyone know that we are working withthe EPA on a consent agreement, which is a formal document dedicated to memorializing the workwe need to do to get the landfill back into pre-storm shape, said Joe Whelan, general manager of theWaimanalo Gulch Landfill. While much of the work identified in the agreement is already underway,the agreement will serve to memorialize those commitments.Whelan added that the WM clean-up team was out every day on the beaches picking up debris andthat WM established a hotline (668-2985) for people to report waste they found on the beaches nearthe landfill. As of Jan. 25, the beaches were reopened for swimming but the landfill remained closed.Waste Management of Hawaii has operated Waimanalo Gulch Landfill as an integral part of the Cityand County of Honolulus solid waste management infrastructure for more than 20 years. The facilityis permitted to handle municipal solid waste, which is heavily regulated, monitored and controlled bylocal, state and federal government agencies. The facilitys staff includes 31 full-time employees,many of whom are active in the local community. In addition to its community contributions andsignificant volunteer efforts, Waste Management provides a benefit to the local economy of more than$2.9 million annually. To learn more about Waste Managements commitment to the beautification ofthe islands, visit www.keepinghawaiiclean.com. ### 28. 29. From:Kenefick, Andrew M To:Helmlinger.Andrew@epamail.epa.gov Cc:dviola@honolulu.gov Subject: WGSL Contractors Date:Tuesday, January 25, 2011 11:36:00 AMAndrew,The following is a list of the contractors being used by WMH. After execution of the AOCwe will submit these names, as requried. If EPA thinks that it will not waive therequirements in paragraph 15 relating to the QMP, please let me know ASAP so that theWork will not be delayed. Thanks.AECOM: CQA firm for construction activitiesAEG: Liner installation/repair contractorGoodfellow Bros. Inc: General ContractorPacific Commercial Services: Pumping contractorGeoSyntec: Design Engineer for landfill constructionGEI: Design Engineer for drainage construction Andrew M. KenefickSenior Legal CounselWaste ManagementWestern Group Legal Department801 2nd Avenue, Suite 614Seattle, WA 98104206-264-3062 (direct)866-863-7961 (direct fax-toll free)206-264-8212 (main fax)akenefick@wm.comadmitted in Washington Our renewable energy projects create enough energy to power more than one million homes.The recovery of landfill gas, coupled with the power generated from the conversion of solid wasteat our waste-to-energy plants, saves the equivalent of more than 13 million barrels of oil. The information contained in this e-mail message may be privileged, confidential and protected from disclosure. If you are not the intended recipient, any dissemination, distribution or copying is strictly prohibited. If you think that you have received this e-mail message in error, please e-mail the sender at akenefick@wm.com 30. From:Helmlinger.Andrew@epamail.epa.govTo:Kenefick, Andrew MCc:Baylor.Katherine@epamail.epa.gov; Moxley.Bret@epamail.epa.govSubject: Confirmation of contractors at WGSLDate:Wednesday, January 26, 2011 7:23:18 AMAndrew;I write to confirm that both of EPAs project contacts have noted to me, at your request,that they are comfortable with the existing contractors at the WGSL site. The list ofcontractors that you provided satisfies the requirement for names and certifications of thecontractors in the Jan. 25, 2011 AOC. If concerns arise, EPA will notify WM per the AOC.____________________________________J. Andrew HelmlingerAttorney AdvisorU.S. Environmental Protection Agency75 Hawthorne Street (ORC-3)San Francisco, CA 94105Telephone: (415) 972-3904Facsimile: (415) 947-3570 31. From:Whelan, JosephSent:Thursday, January 27, 2011 12:30 PMTo:Kabei.Arlene@epamail.epa.gov; Armann.Steve@epamail.epa.gov; Vaille.Rich@epamail.epa.gov; Tyahla.Stephen@epamail.epa.gov; Moxley.Bret@epamail.epa.gov; Helmlinger.Andrew@epamail.epa.gov; Wall.Steve@epamail.epa.gov; baylor.katherine@epa.gov; stuart.yamada@doh.hawaii.gov; Steven.chang@doh.hawaii.govSubject: WGSL Cell 6 Operations ReportGreetings all.Please find attached a copy of the QC report documenting the evaluation and repairs made towaste disposal cell E6 located at WGSL. As noted, this cell has been cleared to resume waste placementper the terms of the report. Also attached is the requested contingency plan that addresses potentialfuture storm events. We would appreciate your earliest review of these documents and approval toresume operations in Cell E6. As you know, there is a significant buildup of solid waste that requireslandfill disposal at this time. Thank you for your quick response and your continued support during thisordeal. We appreciate your efforts.Best regards, Letter Report Cell Cell E6 MSW AreaWGSL SW E6 and E4 R... 1-26-11.pdfntingency Plan 1-26-JoeJoe WhelanGeneral ManagerWaste Management of Hawaii808-668-2985, ext. 15 Office808-668-1366 Fax808-479-4610 MobileWaste Managements landfills provide over 17,000 acres ofprotected land for wildlife habitats and 15 landfills are certifiedby the Wildlife Habitat Council. 32. 33. From: Whelan, JosephTo: "Kabei.Arlene@epamail.epa.gov"; "Armann.Steve@epamail.epa.gov"; "Vaille.Rich@epamail.epa.gov";"Tyahla.Stephen@epamail.epa.gov"; "Moxley.Bret@epamail.epa.gov"; "Helmlinger.Andrew@epamail.epa.gov";"Wall.Steve@epamail.epa.gov"; "baylor.katherine@epa.gov"; "stuart.yamada@doh.hawaii.gov";"Steven.chang@doh.hawaii.gov"; alec.wong@doh.hawaii.govSubject:WGSL Daily Progress Report - AOCDate: Thursday, January 27, 2011 7:27:00 PMGreetings all.Please find below the initial daily progress report on work items contained within therecently approved AOC. ACTIONS PERFORMED AND DEVELOPMENTS ANTICIPATEDCell 6 assessment:1)East side assessment and repair report submitted to all parties on 1-27-11.2)South portion of west side assessment to commence 1-28-11Western Storm water Diversion Project (to render functional):1) Diversion Structure: Poured half of walls 1-26-11, curing today, strip walls & cleanstorm mud tomorrow (Friday)2) Box Culvert: Continue forming and placing steel for invert. Friday pour 250 lf of invert& place steel for invert.3) Pipe: Remove over burden for final trench blast 1-26-11, today, final blast for pipetrench & excavated previous blast material, Friday, excavate pipe trenchCell 6 Leachate Riser Restoration:1)The controls for the cell 6 leachate riser were re-established today at thegenerator and storage area.2)Contractors investigated options for removal of the silt deposits in theleachate riser area on 1-26-11 In order to connect the riser pumps. Removed approximately 4 feet of mud (12,000 gallons) today, Fridaycontinue to pump down mudSediment Basin: 34. 1)pumped 60,000 gallons today and sent to the WWTP for treatment anddisposal, Friday, continue pumpingANALYTICAL DATA RECEIVED DURING REPORTING PERIOD - NoneANTICIPATED PROBLEMS AND PLANNED RESOLUTIONS NonePlease let me know if you have any questions.Best regards, JoeJoe WhelanGeneral ManagerWaste Management of Hawaii808-668-2985, ext. 15 Office808-668-1366 Fax808-479-4610 Mobile Waste Managements landfills provide over 17,000 acres ofprotected land for wildlife habitats and 15 landfills are certifiedby the Wildlife Habitat Council. 35. From: Whelan, JosephTo: "Kabei.Arlene@epamail.epa.gov"; "Armann.Steve@epamail.epa.gov"; "Vaille.Rich@epamail.epa.gov";"Tyahla.Stephen@epamail.epa.gov"; "Moxley.Bret@epamail.epa.gov"; "Helmlinger.Andrew@epamail.epa.gov";"Wall.Steve@epamail.epa.gov"; "baylor.katherine@epa.gov"; "stuart.yamada@doh.hawaii.gov";"Steven.chang@doh.hawaii.gov"; "alec.wong@doh.hawaii.gov"Subject:WGSL Daily Progress Report - AOCDate: Friday, January 28, 2011 6:49:00 PMGreetings all.Please find below the daily progress report on work items contained within therecently approved AOC. ACTIONS PERFORMED AND DEVELOPMENTS ANTICIPATEDCell 6 assessment:1) EPA approval was received today allowing WM to resume operations in theeast side of cell E6.2) The south portion of the west side assessment of cell E6 is ongoing.Western Storm water Diversion Project (to render functional): 1) Diversion Structure:The contractor stripped forms from Wednesdays concrete pour and began cleaning storm mud and debris from the rebar supports. From Saturday thru Monday the forms will be reset for the next pour. 2) Box Culvert: The contractor p oured 200 lf of invertconcrete in the open box channel, and continued placing structural steel forms. From Saturday thru Monday additional forming and placement of structural steel will continue in preparation for invert pours on Tuesday and Friday. 3) Pipe: The contractor continued excavatingthe Hobas pipe trench and placing bedding (aggregate below pipe). These same operations will continue through early next week when pipe can be placed.Cell 6 Leachate Riser Restoration: 1 ) Electricians arepreparing the controls and generator for the leachate pump at the storage tank. The pumping contractor continues removing water from pond surface. 36. 2) The contractor pumped 20,321 gallons of silt from the south pond area. FromSaturday thru Monday the contractor will continue to pump silt from south pond. Sediment Basin:1)The contractor pumped 60,000 gallons of storm water againtoday which was sent to the WWTP for treatment and disposal. From Saturday thru Monday the contractor will continue thispumping.ANALYTICAL DATA RECEIVED DURING REPORTING PERIOD - NoneANTICIPATED PROBLEMS AND PLANNED RESOLUTIONS NonePlease let me know if you have any questions. Best regards,Joe WhelanGeneral ManagerWaste Management of Hawaii808-668-2985, ext. 15 Office808-668-1366 Fax808-479-4610 Mobile Waste Managements landfills provide over 17,000 acres ofprotected land for wildlife habitats and 15 landfills are certifiedby the Wildlife Habitat Council. 37. From: Kabei.Arlene@epamail.epa.govSent: Friday, January 28, 2011 10:56 AMTo: Whelan, JosephCc: gary.gill@doh.hawaii.gov; stuart.yamada@doh.hawaii.com;Takata.Keith@epamail.epa.gov; Diamond.Jane@epamail.epa.gov;Scott.Jeff@epamail.epa.gov; Baylor.Katherine@epamail.epa.gov;Moxley.Bret@epamail.epa.gov; Helmlinger.Andrew@epamail.epa.gov;Wampler.David@epamail.epa.gov; Barroll.Hugh@epamail.epa.gov;armann.steve@epa.gov; Vaille.Rich@epamail.epa.gov;Wall.Steve@epamail.epa.gov; Sheehan.Eileen@epamail.epa.gov;Huetteman.Tom@epamail.epa.gov; Higuchi.Dean@epamail.epa.gov;Ryerson.Teddy@epamail.epa.gov;Johnson.Kathleen@epamail.epa.gov; Glenn.William@epamail.epa.gov;Arlene_Kabei/Janice.Okubo@doh.hawaii.gov;tsteinberger@honolulu.govSubject:Notice of EPA Approval to Operate Cell E6 at Waimanalo Gulch Landfill,Oahu HIDear Mr. Whelan:We have reviewed and accept the Construction Quality Assurance Report submitted for the linerinstallation at Cell #E6. We have also reviewed your "Stormwater Management Update and ContingencyPlan," Version 4, dated 1/27/2011, which supports your belief that the measures described in thedocument "will prevent waste material and stormwater that may come into contact with waste from exitingthe facility in the event of a major storm."While WM has not yet completed the tasks yet due in the Administrative Order on Consent, datedJanuary 25, 2011, USEPA recognizes that WM has made progress in improving the situation at thelandfill and that the continued closure of the landfill may create a risk to public health from accumulatingwastes, in particular sewer sludge, throughout Oahu. We encourage WM to continue to forge aheadquickly on completing the upper valley stormwater diversion system ("Western Drainage System") andcontinue enhancements to the temporary stormwater systems. It is our expectation that the WesternDrainage System will be functional in 15 days. Until the system is functional, please continue to enhancethe capabilities of the temporary stormwater control systems to manage the quantity of water experiencedon January 13, 2011.Therefore, pursuant to Section VIII (g) of the Administrative Order on Consent, USEPA hereby approves,with conditions noted below, the operation of Cell #E6 to accept wastes at the Waimanalo Gulch SanitaryLandfill (WGSL). We understand that the Hawaii Department of Health has also notified you that they donot object to reopening of landfill Cell #E6.The reopening of WGSL is the best alternative to minimize the risks to human health and the environmentassociated with the handling of solid wastes on Oahu. This approval is not a determination WMsoperation of WGSL has been or is currently in compliance with applicable laws governing themanagement of solid waste including, but not limited to, the Clean Water Act and the ResourceConservation and Recovery Act. Nor is it a determination that reopening the landfill is consistent withthese laws.We approve reopening with the following conditions:With regard to Cell E6: 38. 1) Waste is disposed only within the footprint designated on your hand-annotated drawingsubmitted with your Petition for Re-Opening;2) As recommended by AECOM, waste placement operations should be kept a minimum of 50feet away from the damaged western edge of E6; and 3) The western edge of Cell E6 should be repaired as expeditiously as practicable, with planand schedule for repair provided to EPA within one week. With regard to the facility: 4) Waste Management must submit a revised stormwater contingency plan by February 1, 2011 thatdescribes how WM will manage stormwater on the site in response to storm events to prevent thedischarge to waters of the United State of solid wastes, leachate, and/or stormwater contaminated bypollutants generated at WGSL pending completion of the stormwater diversion system ("WesternDrainage System") currently under construction. The contingency plan must list and/or describe, atminimum, the following: - type and quantity of on-site mobile heavy equipment WM employees can use to maintainstormwater systems in response to storm events, including, pumps, tractors, back-hoes; - names of the Waste Management point of contact, or points of contact, available at any time,and the number of WM employees who can be deployed if storm water management systems or equipment fail or are not properly operating; - how WM will monitor storm events and the process WM will follow to deploy employees on-site in response to storm events; - name and location of storm water management equipment or systems (e.g., retention basins,pipes, drains, etc.) that will be monitored and/or maintained by on-site employees in response to storm events; - types of corrective actions or maintenance activities that on-site employees should take inresponse to storm events to ensure storm water conveyance systems remain operational; - beach monitoring activities (including posting signs, and performing clean-up) that will occur ifun-permitted storm water discharge from the landfill occurs.5) No later than fifteen (15 days) after the completion of a functional storm water division structure(Western Drainage System) as required in 19.b. of EPAs Order, WM must revise and submit to EPA itsSWPCP to incorporate the functional Western Drainage System and all ancillary storm waterconnections into its revised SWPCP consistent with the requirements of its storm water general permit.EPA sincerely appreciates your responsiveness to the information we requested for making this Approvaldetermination. We recognize that much work and improvements at the site have been accomplished inshort order since January 13th, 2011.Arlene KabeiAssociate DirectorWaste Management DivisionUSEPA, Region 9 39. From: Whelan, JosephTo: "Kabei.Arlene@epamail.epa.gov"; "Armann.Steve@epamail.epa.gov"; "Vaille.Rich@epamail.epa.gov";"Tyahla.Stephen@epamail.epa.gov"; "Moxley.Bret@epamail.epa.gov"; "Helmlinger.Andrew@epamail.epa.gov";"Wall.Steve@epamail.epa.gov"; "baylor.katherine@epa.gov"; "stuart.yamada@doh.hawaii.gov";"Steven.chang@doh.hawaii.gov"; "alec.wong@doh.hawaii.gov"Subject:WGSL AOC Daily Progress ReportDate: Monday, January 31, 2011 5:30:00 PMGreetings all.Please find below the daily progress report on work items contained within therecently approved AOC. ACTIONS PERFORMED AND DEVELOPMENTS ANTICIPATEDCell 6 assessment:1) The south portion of the west sideassessment of cell E6 is ongoing. Theoperations layer of protective stonelocated above the anchor trench will beremoved to allow the liner material to befurther investigated. The assessmentshould be completed by this Saturday.Western Storm water Diversion Project (to render functional):1) Diversion Structure: The contractor isresetting the wall forms and continues installingreinforcing steel rebar, in anticipation of pouringadditional concrete wall material on Wednesday.2) Box Culvert:The contractor hascontinued placing structural steel formsin the bottom and walls of the open boxculvert in preparation for invert pourson Tuesday and Friday.3) Pipe: The contractor completedexcavating the Hobas pipe trench andcontinues placing bedding (aggregatebelow pipe). Pipe placement willcommence on Tuesday.Cell 6 Leachate Riser Restoration: 40. 1 ) The pumping contractorcontinuesremoving water from the water surface. 2) The contractor has lowered thesilt from the south pond areaby an additional 2 feet. Sediment Basin:1)The contractor pumped 274,000 gallonsof storm water from the sedimentationbasin from Saturday thru Monday, whichwas sent to the WWTP for treatment anddisposal. ANALYTICAL DATA RECEIVED DURING REPORTING PERIOD - NoneANTICIPATED PROBLEMS AND PLANNED RESOLUTIONS NonePlease let me know if you have any questions. Best regards,Joe WhelanGeneral ManagerWaste Management of Hawaii808-668-2985, ext. 15 Office808-668-1366 Fax808-479-4610 Mobile Waste Managements landfills provide over 17,000 acres ofprotected land for wildlife habitats and 15 landfills are certifiedby the Wildlife Habitat Council. 41. FOR IMMEDIATE RELEASEMedia Contact:Keith DeMelloMcNeil Wilson Communications(808) 542-5343keith.demello@mwc-anthology.comWASTE MANAGEMENT OF HAWAII PROVIDES UPDATE Recaps EPA Milestones Achieved for Waimanalo Gulch Sanitary LandfillHONOLULU Jan. 31, 2011 Waste Management of Hawaii (WM) today provided an update onthe progress of work to alleviate damage to the Waimanalo Gulch Sanitary Landfill resulting fromrecent severe rainstorms and the companys ongoing efforts with the City and County of Honolulu tofully restore landfill services to Oahu.The U.S. Environmental Protection Agency (EPA) approved WM resuming operations in the easternportion of cell E6, which was damaged in the Jan. 13 storm. While the landfill remains closed to thepublic, on Friday the landfill began accepting limited city deliveries of critical waste items, such as H-POWER residue and wastewater sludge.The storm water that collected in the area of cell E6 has been removed. On Thursday alone,contractors removed approximately 4 feet of mud (12,000 gallons) and pumped 60,000 gallons fromthe sediment basin, sending it to the wastewater treatment plant for proper treatment and disposal.Furthermore, half of the walls for the new storm water diversion channel have been poured and set tocure.As of today, WM has met all milestone deadlines for the Waimanalo Gulch Sanitary Landfill outlinedin our Jan. 25 consent agreement with the EPA, said Joe Whelan, general manager of the landfill.We are making progress in meeting those that remain according to the agreed upon calendar. Thisincludes the completion of the new storm water diversion channel, already in progress.WM began filing regular progress reports every weekday to EPA and state Department of Health, asoutlined in the companys agreement with the EPA. While much of the work identified in theagreement was already underway, the agreement served to memorialize commitments.Although beaches were declared on Jan. 25 to be safe for swimming, WM continues to encouragethose who find debris appearing to be from the landfill to report it by calling (808) 668-2985.Waste Management of Hawaii has operated Waimanalo Gulch Landfill as an integral part of the Cityand County of Honolulus solid waste management infrastructure for more than 20 years. The facility(more) 42. Waste Management of Hawaii Provides UpdatePage 2 of 2is permitted to handle municipal solid waste, which is heavily regulated, monitored and controlled bylocal, state and federal government agencies. The facilitys staff includes 31 full-time employees, manyof whom are active in the local community. In addition to its community contributions and significantvolunteer efforts, Waste Management provides a benefit to the local economy of more than $2.9million annually. To learn more about Waste Managements commitment to the beautification of theislands, visit www.keepinghawaiiclean.com ### 43. From:Whelan, JosephSent:Tuesday, February 01, 2011 4:52 PMTo:Moxley.Bret@epamail.epa.gov; baylor.katherine@epa.gov; stuart.yamada@doh.hawaii.govSubject: EPA AOC Work Plan SubmittalsGreetings all.Please find attached an electronic version of the various work plans and reports that are duetoday as a result of the terms of the Administrative Order on Consent (AOC). Hard copies of eachsubmittal were sent to you by certified mail dated February 1, 2011. Please let me know if you have anyquestions. We look forward to receiving your approval.Best regards,Joe WhelanGeneral ManagerWaste Management of Hawaii808-668-2985, ext. 15 Office808-668-1366 Fax808-479-4610 MobileWaste Managements landfills provide over 17,000 acres ofprotected land for wildlife habitats and 15 landfills are certifiedby the Wildlife Habitat Council.DOC admin orderconsent.pdf 44. 45. From: Whelan, JosephTo: "Kabei.Arlene@epamail.epa.gov"; "Armann.Steve@epamail.epa.gov"; "Vaille.Rich@epamail.epa.gov";"Tyahla.Stephen@epamail.epa.gov"; "Moxley.Bret@epamail.epa.gov"; "Helmlinger.Andrew@epamail.epa.gov";"Wall.Steve@epamail.epa.gov"; "baylor.katherine@epa.gov"; "stuart.yamada@doh.hawaii.gov";"Steven.chang@doh.hawaii.gov"; "alec.wong@doh.hawaii.gov"Subject:WGSL AOC Daily Progress ReportDate: Tuesday, February 01, 2011 5:26:00 PMGreetings all.Please find below the daily progress report on work items contained within therecently approved AOC. ACTIONS PERFORMED AND DEVELOPMENTS ANTICIPATEDCell 6 assessment:1) The south portion of the west sideassessment of cell E6 is ongoing. Theoperations layer of protective stonelocated above the anchor trench is beingremoved to allow the liner material to befurther investigated. The assessmentshould be completed by this Saturday.Western Storm water Diversion Project (to render functional):1) Diversion Structure: The contractorcontinues to place the wall forms and reinforcingsteel rebar, in anticipation of pouring additionalconcrete wall material on Wednesday.2) Box Culvert: The contractor pouredconcrete today to place the invert boxculvert, Tomorrow he will resumeplacing structural steel forms in thebottom and walls of the open box culvertin preparation for invert pours onFriday.3) Pipe: Placement of the large diameterHobas pipe resumed today. The contractorcontinues placing bedding (aggregatebelow pipe).Cell 6 Leachate Riser Restoration: 46. 1 ) The pumping contractor continues skimming water from the surface of the area south of Cell E6, and transported 16,500 gallons today to the waste water treatment plant. These activities are ongoing. 2) The contractor removed 16,000 gallons of mud and water mixture from the area south of Cell E6 and placed into frac tanks in order to allow them to separate. These activities are ongoing. Sediment Basin: 1)The contractor pumped 56,000 gallons of storm water from the sedimentation basin today, which was sent to the WWTP for treatment and disposal. These activities are ongoing.ANALYTICAL DATA RECEIVED DURING REPORTING PERIOD - NoneANTICIPATED PROBLEMS AND PLANNED RESOLUTIONS NonePlease let me know if you have any questions. Best regards,Joe WhelanGeneral ManagerWaste Management of Hawaii808-668-2985, ext. 15 Office808-668-1366 Fax808-479-4610 Mobile Waste Managements landfills provide over 17,000 acres ofprotected land for wildlife habitats and 15 landfills are certifiedby the Wildlife Habitat Council. 47. From: Whelan, JosephTo: Tyahla.Stephen@epamail.epa.govSubject:FW: AGSL Additional Submittal under AOC - H&S PlanDate: Tuesday, February 01, 2011 6:00:00 PMAttachments:WGSL IIPP JAN 2009.pdfBloodborne Pathogen Plan.pdf020_Confined_Space_Program.pdfPART E_ Emer_Action_Plan_Jan2011.pdf035_Hazard_Communication.pdf025_Lock-Out_Tag-Out.pdf015_Personal_Protective_Equipment.pdf055_Respiratory_Protection.pdf021_Substance_Abuse_Program_for_Employees_and_Candidates.pdf065_Forklift_Training.pdf050_Welding,_Burning,_and_Hot_Works.pdf030_Hearing_Conservation.pdfRound two_____________________________________________From: Whelan, JosephSent: Tuesday, February 01, 2011 4:59 PMTo: Moxley.Bret@epamail.epa.gov; baylor.katherine@epa.gov; stuart.yamada@doh.hawaii.govSubject: AGSL Additional Submittal under AOC - H&S PlanGreetings all.Please find an electronic version of the facility Health & Safety Plan, per the terms of theAOC. A hard copy of this plan is being sent to you under separate cover, as the file sizewas too large to send with the other submittal. Best regards, Joe WhelanGeneral ManagerWaste Management of Hawaii808-668-2985, ext. 15 Office808-668-1366 Fax808-479-4610 Mobile Waste Managements landfills provide over 17,000 acres ofprotected land for wildlife habitats and 15 landfills are certifiedby the Wildlife Habitat Council. 48. 49. From: Whelan, JosephTo: Tyahla.Stephen@epamail.epa.govSubject:FW: EPA AOC Work Plan SubmittalsDate: Tuesday, February 01, 2011 5:59:00 PMAttachments:DOC admin order consent.pdfHi Steve. Welcome back!!_____________________________________________From: Whelan, JosephSent: Tuesday, February 01, 2011 4:52 PMTo: Moxley.Bret@epamail.epa.gov; baylor.katherine@epa.gov; stuart.yamada@doh.hawaii.govSubject: EPA AOC Work Plan SubmittalsGreetings all. Please find attached an electronic version of the various work plans and reports thatare due today as a result of the terms of the Administrative Order on Consent (AOC). Hardcopies of each submittal were sent to you by certified mail dated February 1, 2011. Pleaselet me know if you have any questions. We look forward to receiving your approval. Best regards,Joe WhelanGeneral ManagerWaste Management of Hawaii808-668-2985, ext. 15 Office808-668-1366 Fax808-479-4610 Mobile Waste Managements landfills provide over 17,000 acres ofprotected land for wildlife habitats and 15 landfills are certifiedby the Wildlife Habitat Council. 50. 51. From: Whelan, JosephTo: "Kabei.Arlene@epamail.epa.gov"; "Armann.Steve@epamail.epa.gov"; "Vaille.Rich@epamail.epa.gov";"Tyahla.Stephen@epamail.epa.gov"; "Moxley.Bret@epamail.epa.gov"; "Helmlinger.Andrew@epamail.epa.gov";"Wall.Steve@epamail.epa.gov"; "baylor.katherine@epa.gov"; "stuart.yamada@doh.hawaii.gov";"Steven.chang@doh.hawaii.gov"; "alec.wong@doh.hawaii.gov"Subject:Daily Progress Report for 2-2-11Date: Wednesday, February 02, 2011 7:06:00 PMGreetings all.Please find below the daily progress report on work items contained within therecently approved AOC. ACTIONS PERFORMED AND DEVELOPMENTS ANTICIPATEDCell 6 assessment:1) The south portion of the west sideassessment of cell E6 is ongoing. Theoperations layer of protective stonelocated above the anchor trench is beingremoved to allow the liner material to befurther investigated. A temporary fillroad was placed today to allow theexcavator to access the side wall liner.The assessment should be completed bythis Saturday.Western Storm water Diversion Project (to render functional):1) Diversion Structure: The contractorcontinues to place the wall forms andreinforcing steel rebar, in anticipation ofpouring additional concrete wall materialon Thursday. 2) Box Culvert: Placement of reinforcingsteel continued.The final invert pour isscheduled for Friday. 3) Pipe: Placement of the large diameterHobas pipe continued today. Thecontractor continues placing bedding(aggregate below and around the pipe), 52. and began pressure testing the joints of placed pipe. Cell 6 Leachate Riser Restoration: 1 ) The pumping contractorcontinues skimming water from the surface of the area south of Cell E6, and transported 16,500 gallons again today to the waste water treatment plant. These activities are ongoing. 2) The contractor removed 10,000 gallons of mud and water mixture from the area south of Cell E6 today, and placed into frac tanks in order to allow them to separate. These activities are ongoing. Sediment Basin:1) The contractor pumped 105,800 gallons of storm water from the sedimentationbasin today, which was sent to the WWTP for treatment and disposal. These activitiesare ongoing.ANALYTICAL DATA RECEIVED DURING REPORTING PERIOD - NoneANTICIPATED PROBLEMS AND PLANNED RESOLUTIONS NonePlease let me know if you have any questions. Best regards,Joe WhelanGeneral ManagerWaste Management of Hawaii808-668-2985, ext. 15 Office808-668-1366 Fax808-479-4610 Mobile Waste Managements landfills provide over 17,000 acres ofprotected land for wildlife habitats and 15 landfills are certified 53. From: Whelan, JosephTo: "Kabei.Arlene@epamail.epa.gov"; "Armann.Steve@epamail.epa.gov"; "Vaille.Rich@epamail.epa.gov";"Tyahla.Stephen@epamail.epa.gov"; "Moxley.Bret@epamail.epa.gov"; "Helmlinger.Andrew@epamail.epa.gov";"Wall.Steve@epamail.epa.gov"; "baylor.katherine@epa.gov"; "stuart.yamada@doh.hawaii.gov";"Steven.chang@doh.hawaii.gov"; "alec.wong@doh.hawaii.gov"Subject:Daily Progress Report for 2-3-11Date: Thursday, February 03, 2011 8:00:00 PMGreetings all.Please find below the daily progress report on work items contained within therecently approved AOC. ACTIONS PERFORMED AND DEVELOPMENTS ANTICIPATEDCell 6 assessment:1) The south portion of the west sideassessment of cell E6 is ongoing. Theoperations layer of protective stonelocated above the anchor trench is beingremoved to allow the liner material to befurther investigated. A temporary fillroad was placed to allow the excavatorto access the side wall liner. Theassessment should be completed by thisSaturday.Western Storm water Diversion Project (to render functional):1) Diversion Structure: Concrete wallmaterial was poured today, and thecontractor continues to place the final wallforms and reinforcing steel rebar.2) Box Culvert: The contractor completedplacement of the invert reinforcing steel. The final invert pour is scheduled forFriday. 3) Pipe: Placement of the large diameterHobas pipe and backfilling continuedtoday. The contractor continues pressure 54. testing the joints of placed pipe. Pipe work will be complete Friday. Cell 6 Leachate Riser Restoration: 1 ) The pumping contractor continues skimming water from the surface of the area south of Cell E6. These activities are ongoing. 2) The contractor removed 12,500 gallons of mud and water mixture from the area south of Cell E6 today, and placed into frac tanks in order to allow them to separate. These activities are ongoing. Sediment Basin:1) The contractor pumped 55,800 gallons of storm water from the sedimentation basintoday, which was sent to the WWTP for treatment and disposal. These activities areongoing.ANALYTICAL DATA RECEIVED DURING REPORTING PERIOD - NoneANTICIPATED PROBLEMS AND PLANNED RESOLUTIONS NonePlease let me know if you have any questions. Best regards,Joe WhelanGeneral ManagerWaste Management of Hawaii808-668-2985, ext. 15 Office808-668-1366 Fax808-479-4610 Mobile Waste Managements landfills provide over 17,000 acres ofprotected land for wildlife habitats and 15 landfills are certifiedby the Wildlife Habitat Council. 55. From: Whelan, JosephTo: "Kabei.Arlene@epamail.epa.gov"; "Armann.Steve@epamail.epa.gov"; "Vaille.Rich@epamail.epa.gov";"Tyahla.Stephen@epamail.epa.gov"; "Moxley.Bret@epamail.epa.gov"; "Helmlinger.Andrew@epamail.epa.gov";"Wall.Steve@epamail.epa.gov"; "baylor.katherine@epa.gov"; "stuart.yamada@doh.hawaii.gov";"Steven.chang@doh.hawaii.gov"; "alec.wong@doh.hawaii.gov"Subject:Daily Progress Report for 2-4-11Date: Friday, February 04, 2011 5:20:00 PMGreetings all.Please find below the daily progress report on work items contained within therecently approved AOC. ACTIONS PERFORMED AND DEVELOPMENTS ANTICIPATEDCell 6 assessment:1) The south portion of the west sideassessment of cell E6 is ongoing. Theoperations layer of protective stonelocated above the anchor trench is beingremoved to allow the liner material to befurther investigated. A temporary fillroad was placed to allow an excavatorto remove over burden from the stormin order to access the side wall liner,which was exposed today. Operationslayer sand will be placed on Saturday.Liner crews have begun their evaluationof this area.Western Storm water Diversion Project (to render functional):1) Diversion Structure: The contractorclosed all remaining forms today inanticipation of the final wall pour onFebruary 8 th .2) Box Culvert: The contractor completedpouring the channel invert today. Nextweeks efforts will concentrate on formingthe transition structure from box culvertinvert to pipe invert. 3) Pipe: The contractor completed layingthe Hobas Pipe today, and continues 56. pressure testing the joints of placed pipe. Backfilling of the pipe trench will continue thru next week. Cell 6 Leachate Riser Restoration: 1 ) The pumping contractorcontinues skimming water from the surface of the area south of Cell E6. We anticipate Cell E6 riser connections to commence on Monday or Tuesday. 2) The contractor removed 10,000 gallons of mud and water mixture from the area south of Cell E6 today, and placed into frac tanks in order to allow them to separate. These activities are ongoing. Sediment Basin:1) The contractor pumped 61,500 gallons of storm water from the sedimentation basintoday, which was sent to the WWTP for treatment and disposal. These activities areongoing.ANALYTICAL DATA RECEIVED DURING REPORTING PERIOD - NoneANTICIPATED PROBLEMS AND PLANNED RESOLUTIONS NonePlease let me know if you have any questions. Best regards,Joe WhelanGeneral ManagerWaste Management of Hawaii808-668-2985, ext. 15 Office808-668-1366 Fax808-479-4610 Mobile Waste Managements landfills provide over 17,000 acres ofprotected land for wildlife habitats and 15 landfills are certifiedby the Wildlife Habitat Council. 57. From:Whelan, JosephSent:Friday, February 04, 2011 11:06 AMTo:Moxley.Bret@epamail.epa.gov; Tyahla.Stephen@epamail.epa.gov; stuart.yamada@doh.hawaii.govSubject: EPA AOC Submission No. 2Greetings all. Please find attached an electronic version of the work plans and reports that are due today as aresult of the terms of the Administrative Order on Consent (AOC). Hard copies of each submittal weresent to you by certified mail dated February 4, 2011. Please let me know if you have any questions. Welook forward to receiving your approval. DOCWGSL EPADOCWGSL EPA OC SUBMISSION 2.pOC SUBMISSION 2 sBest regards,Joe WhelanGeneral ManagerWaste Management of Hawaii808-668-2985, ext. 15 Office808-668-1366 Fax808-479-4610 MobileWaste Managements landfills provide over 17,000 acres ofprotected land for wildlife habitats and 15 landfills are certifiedby the Wildlife Habitat Council. 58. 59. From:Whelan, JosephTo:Tyahla.Stephen@epamail.epa.govSubject: RE: Near-term storm preparation at WGSLDate:Friday, February 04, 2011 2:51:00 PMGreetings Steve. Please find our responses to your referenced request. Best regards, Joe From: Tyahla.Stephen@epamail.epa.gov [mailto:Tyahla.Stephen@epamail.epa.gov]Sent: Friday, February 04, 2011 9:41 AMTo: Whelan, JosephCc: Moxley.Bret@epamail.epa.gov; lene.ichinotsubo@doh.hawaii.gov; Armann.Steve@epamail.epa.gov;steven.chang@doh.hawaii.gov; stuart.yamada@doh.hawaii.gov; Wampler.David@epamail.epa.gov;Blake.Ellen@epamail.epa.gov; Kabei.Arlene@epamail.epa.govSubject: Near-term storm preparation at WGSLJoe,We are reviewing the submittals you provided on 1 February 2011 in response to our AdministrativeOrder on Consent ("AOC") and our 28 January 2011 e-mail that conditionally approved re-opening ofcell E6 at the Waimanalo Gulch Sanitary Landfill ("WGSL"). I anticipate sending you our detailedfeedback on those work plans and schedules by the latter part of next week.However, in light of "heavy rain" being forecasted by NOAA for the vicinity of the WGSL this comingweekend, we are providing the below interim comments on your "Revised Storm Water ManagementUpdate & Contingency Plan," ("contingency plan") and would like your written response to these today.These particular comments generally concern near-term preparation for storm events and are eitheritems that lack detail or are absent in the contingency plan Waste Management of Hawaii ("WMH")submitted on 1 February.(1) Please provide details on WMHs process for deciding when Cell E6 operations are to be shut-down due to rain storm events and how such a shut-down would be executed. [Whelan, Joe] Thefacility is currently closed to the public, which means our daily volumes are fairly small. Ournormal procedures call for us to stop operations if rainfall amounts create either a safety,environmental or operations concern. If unloading or processing operations are severelyaffected, we would suspend operations, and begin covering the waste material placed thatday. As you know, we only create a working face disposal area large enough to accept thepredicted days waste receipts. Therefore, this area is very small now until we reopen to thepublic. Once operations are ceased, we will place daily cover over all exposed waste. Thiscover would meet interim cover requirements, which is one foot of soil, which is compactedafter placement.(2) Please provide a description of how WMH would secure waste within Cell E6 in anticipation of asignificant rain event. [Whelan, Joe] We have already evaluated and reinforced the existing DI-1 interceptor manhole by placing a mound of large boulders in front of this manhole toprevent