INCIDENT MANAGEMENT PLAN (IMP)

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INCIDENT MANAGEMENTPLAN (IMP)withCONTINGENCY PLAN AND EMERGENCYPROCEDURESBRIDGETON LANDFILLPrepared for:BRIDGETON LANDFILL, LLC13570 ST. CHARLES ROCK ROADBRIDGETON, MO 63044Prepared by:CIVIL & ENVIRONMENTAL CONSULTANTS, INC.ST. LOUIS, MISSOURICEC Project No. 131-178June 10, 2015*30216116*30216116

TABLE OF CONTENTS1.02.03.04.05.06.07.0INTRODUCTION . 1DESCRIPTION OF BRIDGETON LANDFILL . 3DEFINITIONS. 4INCIDENT PREVENTION. 5RESPONSE AND INCIDENT STRATEGIES . 6RESUMPTION AND RESTORATION. 11AMENDMENT OF PLAN . 12TABLESTable 1 – Responsibilities and ContactsTable 2 – List of Available On-Site ResourcesFIGURESFigure 1 – Facility LocationFigure 2 – Facility MapFigure 3 – Site Access and OperationsFigure 3A – Emergency Locator MapFigure 4A, 4B – Chemical Storage AreasATTACHMENTSAttachment A – Facility Emergency Coordinator Checklist / Emergency Responder CommunicationAttachment B – Spill Prevention and Response for LeachateAttachment C – MSDS (provided separately)

1.0INTRODUCTIONLike many industrial activities, operation and maintenance of municipal waste landfills includesrisk. At the Bridgeton Landfill, these risks can result from the use of large mobile and stationaryequipment, handling of combustible materials, and the management of waste byproducts such asdecomposition gases and liquid leachate.A recognized heat-generating event is occurring within a portion of the solid waste disposal area.Such heat-generating events can increase the potential hazards and the likelihood of an incident.An Operation, Maintenance, and Monitoring (OM&M) Plan has been submitted to the MDNRseparately to describe special observations and preventative maintenance procedures, whichBridgeton Landfill personnel are implementing. The OM&M Plan requires that monitoring andwork activity reports be generated and submitted to the MDNR, allowing constant tracking of thestatus of the heat-generating event.In addition to the above document, the facility is required to have various spill prevention plans,leachate treatment and handling protocols, surface water management plans, and air qualityplans. All of these plans can be found at the facility office.This Incident Management Plan (IMP) describes plans to prevent incidents, required protocol forinitial incident emergency calls, coordination of responses, and resumption of normal activities(in case of interruption). The IMP has been prepared by Bridgeton Landfill with the cooperationof appropriate regulatory authorities and local emergency responders.Bridgeton Landfill creates, stores, and disposes of leachate as part of its operation.Constituents contained in the leachate have, at times, exceeded levels at which it be classifiedas a hazardous waste in accordance with the Code of Federal Regulations (CFR) Part 261.Specifically, some of the leachate has occasionally exceeded the hazardous threshold forbenzene which carries the waste code D018. Therefore, the facility needs to be operated incompliance with the requirements applicable to a hazardous waste generator (40 CFR part262) including certain provisions of 40 CFR Part 265. As such, this IMP has also beendeveloped to meet the requirements of CFR 265, Subpart D – Contingency Plan andEmergency Procedures, since those procedures are inclusive of contingency planning andemergency response procedures applicable to either a generator or a treatment, storage, ordisposal facility.-1-

The remainder of this IMP is comprised of the following sections:2.0Description of Bridgeton Landfill – Location, access, size, and facilities aredescribed.3.0Definitions – Defines significant terms used in the IMP.4.0Incident Prevention – Describes measures for incident prevention, assignment ofEmergency Coordinators, and communication and coordination with Regulatoryand Local Authorities.5.0Response and Incident Strategies – Presents response scenarios for a number ofidentified potential incidents.6.0Resumption and Restoration – In the case of service interruptions, this sectiondescribes the process for resuming operations including regulatory approvals.7.0Amendment of Plan – Describes the frequency and process for updating andamending the IMP.-2-

2.0DESCRIPTION OF BRIDGETON LANDFILLBridgeton Landfill is an inactive municipal solid waste landfill located at 13570 St. Charles RockRoad in Bridgeton, Missouri (see attached site location map, Figure 1). The site was formerlymined for limestone, resulting in large, open pits which were over 200 feet deep. Beginning inthe 1940’s or 1950’s, portions of the property were backfilled with municipal wastes, industrialwastes, and construction and demolition debris. Landfill operations ceased in 2005.The recent permitted disposal area (see Figure 2 for location) covers about 52 acres of the 214acre property and is the main focus of this IMP. In addition, a concrete mixing plant, a wastetransfer station, two legacy disposal areas and many appurtenant features are present on the siteproperty. See Figure 2 for the facility layout and access.Although the landfill is inactive, many activities are occurring at the facility including: Placement and maintenance of cover materials;Collection, management, and destruction of landfill decomposition gas;Generation, storage, and treatment of leachate;Collection and disposal of landfill leachate; andOperation of a waste transfer station, at which waste is transferred from small localcollection trucks into large long-haul trucks for transportation to a remote landfill.When waste material decomposes, a biological process increases its temperature and producescombustible gasses (primarily methane). Portions of the Bridgeton Landfill are experiencinghigher-than-typical temperatures resulting from a possible heat-generating (exothermic) eventtaking place within the waste. Many things can produce a heat-generating event, and heightenedmonitoring and maintenance of the facility is required to control the heat-generating event.-3-

3.0DEFINITIONSFacility Emergency Coordinator Bridgeton Landfill person identified with the responsibilityfor initial assessment and coordination of response activitieswith regulatory and local authorities.Incident CommanderRepresentative of governmental emergency response agencyto which all other responders report.Regulatory AuthoritiesGovernmental agencies responsible for permitting andregulation of activities associated with, or affected by, thelandfill.These include: the MDNR, the St. LouisMetropolitan Sewer District (MSD), the U.S. EPA, St. LouisCounty Department of Health (DoH), and the FederalAviation Authority (FAA).Local AuthoritiesParties that have a role or interest in emergency responseincluding: Local Fire Departments, St. Louis County LocalEmergency Planning Committee, Lambert-St. LouisInternational Airport, and the City of Bridgeton.Level 0 IncidentAn incident that can be handled entirely by on-site Bridgetonpersonnel and equipment. In some cases, notification toemergency responders and/or regulatory personnel may benecessary.Level 1 IncidentAn incident that requires assistance of local authorities toremedy. May include potential harm to life, safety, or healthof on-site personnel.Emergency Command CenterA location identified for use during a Level 1 Incident. Thelocation would serve as the control center for the EmergencyCoordinator, Incident Commander, Regulatory Authorities,Local Authorities, and media relations.-4-

4.0INCIDENT PREVENTIONBridgeton Landfill personnel work hard to prevent potential hazards from becoming incidents.Many voluntary and required programs and documents are used to minimize hazards and protectemployee and public health and safety. A partial list follows:Missouri Department of Natural Resources Solid Waste Disposal Operating Permit #118912This permit and referenced permit application documents govern the previous operation and thecurrent closure and post-closure activities at the site. Compliance with the applicable strict statesolid waste regulations ensures a high level of due care with respect to the landfill facility. Thesedocuments are available at the site office.Bridgeton Landfill Health and Safety Plan (HASP)This site-specific plan details safety protocols. The HASP focuses on the specific health andsafety hazards that are related to working in and around a landfill and requires landfill personnelbe OSHA trained if performing certain tasks.Bridgeton Landfill Operation, Maintenance, and Monitoring Plan (OM&M Plan)A recognized heat-generating event is occurring within a portion of the solid waste disposal area.Such heat-generating events can increase the potential hazards and the likelihood of an incident.The OM&M Plan describes special observations and preventative maintenance procedures, andBridgeton Landfill personnel are implementing these procedures. The OM&M Plan requires thatmonitoring and work activity reports be generated and submitted to the MDNR, allowingconstant tracking of the status of the heat-generating event.In addition to the above documents, the facility is required to have various spill prevention plans,leachate treatment and handling protocols, surface water management plans, and air qualityplans. All of these plans can be found at the facility office.-5-

5.0RESPONSE AND INCIDENT STRATEGIESAn “incident” is a situation that is non-routine or is anomalous and which poses a threat to thehealth and safety of facility personnel or the public, or which may develop into such. BridgetonLandfill has designated a Facility Emergency Coordinator who is responsible for determining if asituation rises to the level of an incident (see Table 1 for Facility Emergency Coordinatordesignation as well as other responsible parties).When an incident occurs, the Facility Emergency Coordinator will make an initial assessment ofthe severity of the incident and classify it as Level 0 or Level 1 (see definitions in Section 3.0 ofthis Plan) based on the nature of the incident. Depending on the severity of the incident,regulatory and local authorities become involved. A checklist of some of the important incidentmanagement steps to be taken by the Facility Emergency Coordinator is presented in AttachmentA. At this time, identified potential incidents at the Bridgeton Landfill fall into one of thefollowing categories: Surface Fire;Personal Injury – Man Down /Personnel Contamination;Sudden Waste Movement; andLeachate ReleaseSite entrances are shown on the attached Figure 2; evacuations, if necessary may be made at anyof these entrances. Internal communications are provided to appropriate facility personnelthrough two-way radio or cell phones. In the event of an emergency or required response orevacuation, the radio-equipped personnel will circulate the facility to provide appropriatenotifications.The following pages contain the response and incident strategies for each of these potentialincidents.-6-

INCIDENT – SURFACE FIREINITIAL ASSESSMENT(by Facility Emergency Coordinator) Level 0Small affected area, orMinor smoke plume, andEquipment and personnel on-sitesufficient to resolve incidentRESPONSE1. Notify on-site personnel2. Call Pattonville FD On-Duty BattalionChief 314-393-48023. Call Robertson FD Assistant FireChief 314-575-50114. Notify MDNR 573-751-5401 & St.Louis Co. DoH5. Coordinate extinguishment (use heavyequipment to smother with dirt orextinguish with water truck spray)6. Monitor continuously for one hour toensure extinguished7. Assess potential damage to systemsand make repairsLandfill fires may be extinguished bysmothering with dirt, water, or water/foamapplication. See Figure 2 for locations ofdirt stock piles, water sources, and foamstorage locations. Level 1After normal business hours, orInsufficient on-site resources, orFlame/smoke visible off-site, orLarge affected areaRESPONSEProvide clear, precisedescription of the emergency1. Notify on-site personnel2. Call 9113. Call Pattonville FD On-Duty BattalionChief 314-393-48024. Call Robertson FD Assistant Fire Chief314-575-50115. Notify MDNR 573-751-5401 (after hours573-634-2436) & St. Louis Co. DoH6. Suspend impacted, non-critical operations(unless such operation minimizesincident)7. Coordinate extinguishment with IncidentCommander8. Monitor continuously for 48 hours toassure extinguishment9. Assess potential damage to systems andmake repairs10. Resume regular operations with consentof Incident Commander

INCIDENT – PERSONAL INJURYMAN DOWN / PERSONNEL CONTAMINATIONINITIAL ASSESSMENT(by Facility Emergency Coordinator) Level 0Injury handled with on-site firstaid Level 1Any injury requiring firstresponder or paramedicassistanceRESPONSE1. Call 9112. Follow 911 operatorinstructions until firstresponders arrive3. Brief first responders and/orIncident Commander uponarrival—follow instructions4. Bridgeton personnel maytransport injured person toCommand Center for transportif off-site treatment is required

INCIDENT – SUDDEN WASTE MOVEMENTINITIAL ASSESSMENT(by Facility Emergency Coordinator) Level 0Movement within limits of temporarycap orLittle or no exposed waste, andMinor odor release Level 1Massive movement orLarge exposure of waste material orHot (steaming) or burning wasteexposed RESPONSE1. Stabilize toe with soil2. Turn off gas extraction wells within200’3. Lightly cover tension cracks withclean, clayey soil4. Notify MDNR 573-751-5401& St.Louis Co. DoH5. Call Pattonville FD On-duty BattalionChief 314-393-48026. Call Robertson FD Assistant FireChief 314-575-50117. Monitor for one week, if no furthermovement, implement relocation ofwaste material and restorationRESPONSE1. Turn off gas extraction wells within 500’2. Call Pattonville FD On-Duty BattalionChief 314-393-48023. Call Robertson FD Assistant Fire Chief314-575-50114. Notify MDNR 573-751-5401 (after hours573-634-2436) & St. Louis Co. DoH5. Stabilize toe with soil6. Lightly cover exposed waste with clean,clayey soil while buttressing toe atdirection of professional engineer7. Monitor for one month, if no furthermovement, implement relocation andrestoration

INCIDENT – LEACHATE RELEASEINITIAL ASSESSMENT(by Facility Emergency Coordinator) Level 0Event duration less than one hour andno visible off-site emissions andLeachate is contained to surface oflandfillRESPONSE1. Create berm on landfill to captureliquid2. Arrest release with temporary wellcap or new wellhead3. Note event in site records Level 1Event duration greater than one hourorEmissions visible off-site orLeachate reaches beyond on-sitesurface water management featuresRESPONSE1. Verify stormwater knife gates are shutand contain liquids in retention basin toextent possible2. Arrest release3. Notify MDNR 573-751-5401 (afterhours 573-634-2436) & St. Louis Co.DoH4. Call MDNR Spill Line 573-634-24365. Call Pattonville FD On-duty BattalionChief 314-393-48026. Call Robertson FD Assistant Fire Chief314-575-50117. Notify LEPC 314-615-9500/314-6155360 (after hours)*A leachate release may be assumed to be hot (scalding) hazard and may also be accompanied by odors and release of substances into surfacewater – see appropriate Incident Responses in this IMP.

6.0RESUMPTION AND RESTORATIONSevere incidents could result in damage to facility infrastructure or an interruption inmaintenance activities or operation of the transfer station. Bridgeton Landfill has ongoingretention agreements with a number of third-party contractors. These contractors can assist withrestoration of critical site operation and maintenance functions.In cases of Level 1 incidents, the Incident Commander will be involved in the decision andtiming of resumption of activities. Restoration will be coordinated with the MDNR so that thelandfill facility meets requirements.In case of damage to equipment, follow all provisions of 40 CFR 265.196 regarding inspection,return-to-service, and certification of major repairs to any damaged equipment that has resultedin a release of a regulated substance. All emergency equipment listed in this plan must bereplaced or cleaned and fit for its intended use before operations are resumed. Properly disposeof contaminated materials and personnel protective equipment.-11-

7.0AMENDMENT OF PLANThis plan will be reviewed, and amended, if necessary, whenever: Applicable regulations are revised;The plan fails in an emergency;The facility changes its design, construction, operation, maintenance, or othercircumstances in a way that materially increases the potential for fires, explosions, orreleases of hazardous waste or hazardous waste constituents, or changes the responsenecessary in an emergency;Upon request/input of regulatory authorities;The list of emergency coordinators changes; and/orThe list of emergency equipment changes.-12-

TABLES

BRIDGETON LANDFILLIncident Management PlanTABLE 1RESPONSIBILITIES AND CONTACTS* (updated May 20, 2015)Primary Emergency Contact – Dial 911Site Personnel – 13570 St. Charles Rock Road, Bridgeton, MO 63044Facility Emergency CoordinatorAlternate Emergency Facility CoordinatorAlternate Emergency Facility CoordinatorDerek BouchardOffice: (314) 744-8172Cell: (314) 302-3634Brian PowerOffice: (314) 744-8165Cell: (618) 410-0157Tim JohnsonOffice: (314) 744-8190Cell: (818) 434-8494Regulatory AuthoritiesMDNR–Solid Waste Management Program-- OperationsMDNR–Solid Waste Management Program-- DirectorBrenda ArdreyOffice: (573) 526-9940Cell: (573) 353-3543Chris NagelOffice: (573) 751-5401Blackberry: (573) 680-5146Cell: (573) 690-5371MDNR–Environmental Emergency Response (Spill Line) Hot Line:(573) 634-2436MDNR–Environmental Emergency Response –Skip RicketsSt. Louis Region -- Route 66Cell: (314) 608-5656St. Louis County Department of HealthLaura YatesOffice: (314) 615-4035Cell: (314) 609-2576Local AuthoritiesRobertson Fire Dept.Maynard Howell – Asst. Fire ChiefCell: (314) 575-5011Pattonville Fire Dept.Battalion Chief (Primary Contact) Cell:(314) 393-4802Matt Lavanchy (Secondary Contact) Cell:(314) 393-4807Office: (314) 739-3118St. Louis County Local Emergency PlanningCommittee (LEPC)Mark Diedrich – LEPC CoordinatorOffice: (314) 615-9500Bureau of Communications24/7 Emergency: (314) 615-5360Other ContactsSSM DePaul Health Center(314) 344-6000St. Joseph Health Center(636) 947-5000National Response Center(800) 424-8802EPA Region VII(913) 236-3778

FIGURES

NORTHAdmin. Bldg.3BRIDGETON LANDFILL, LLC13570 ST. CHARLES ROCK ROADBRIDGETON, MISSOURIFACILITY LOCATIONwww.cecinc.comDRAWN BY:DATE:JMMAPR. 2014CHECKED BY:DWG SCALE:MRBNONEAPPROVED BY:PROJECT NO:MRB121-337FIGURE NO.:1

NORTHWEST LAKE OU-1(2)LEGACY DISPOSAL AREA(RESTRICTED ACCESS)ESRLHA.CSTROCKLANDFILL OFFICE(OCCUPIED M-F, 8AM-5PM)RD.ENTRANCE #1 /COMMAND CENTERGATEEMERGENCY MEETING &COORDINATION AREACEANRNTESCALE HOUSE (OCCUPIED24 HRS PER DAY, EXCEPTSAT. 11PM TO SUN.MIDNIGHT)ADWEST LAKE OU-1(1)LEGACY DISPOSAL AREA(RESTRICTED OTENTRANCE #4GATEBRIDGETONHAULINGCOMPANYFENCE /APPROXIMATEPROPERTY LINELEACHATEPRETREATMENTAREALANDFILLGAS FLARECOMPOUNDLEACHATELOADOUTOPENWATERRECENT PERMITTEDDISPOSAL AREA(MAIN SUBJECT OF IMP)SOILSTOCKPILELEACHATETANKENTRANCE #2GATEOLDSTEASTERNFLAREYARD.CHARLESROCKSECOND ALTERNATECOMMAND CENTER(IF REQUIRED)RDENTRANCE #3GATE.NOTEREFERENCESOURCE: Google Earth Pro2012 GoogleBRIDGETON LANDFILL, LLC13570 ST. CHARLES ROCK ROADBRIDGETON, MISSOURIFACILITY MAPwww.cecinc.comDRAWN BY:DATE:JMMAPR. 2014CHECKED BY:DWG SCALE:MRBNONEAPPROVED BY:PROJECT NO:MRB121-337FIGURE NO.:2

"QUADRANT" DESIGNATIONSABCDENORTHNOTE1213LEGENDBULK STORAGE CONTAINERS (ALL OUTDOORS)12345678910111213INCIDENT MANAGEMENT PLAN (IMP)PBRIDGETON LANDFILLSITE ACCESS AND OPERATIONSJUNE 20151" 300'FIGURE 3

NORTH"QUADRANT" DESIGNATIONSABCDELEGENDNOTEINCIDENT MANAGEMENT PLAN (IMP)BRIDGETON LANDFILLEMERGENCY LOCATOR MAPJUNE 20151" 300'FIGURE 3A

LEACHATE TREATMENT AREALEGENDBULK STORAGE CONTAINERSNORTH2230 3231 341235133614371538163917401841193834 35GENERAL LEGEND281516KEY5172116192018GAS FLARECOMPOUNDNOTESEASTERNFLARE IDENT MANAGEMENT PLAN (IMP)BRIDGETON LANDFILLCHEMICAL STORAGE AREASJUNE 20151" 100'FIGURE 4A

GAS FLARE COMPOUNDEASTERN FLARE YARDNORTHNORTH25242326PLEGENDLEGENDBULK STORAGE CONTAINERSNO BULK STORAGE CONTAINERSKEY2324GAS FLARECOMPOUND2526GENERAL LEGENDEASTERNFLARE YARDLEACHATETREATMENTAREANOTESINCIDENT MANAGEMENT PLAN (IMP)1516BRIDGETON LANDFILLCHEMICAL STORAGE AREASJUNE 2015SCALE VARIESFIGURE 4B

ATTACHMENT AFACILITY EMERGENCY COORDINATOR CHECKLIST / EMERGENCYRESPONDER COMMUNICATION

BRIDGETON LANDFILLIncident Management PlanFACILITY EMERGENCY COORDINATOR CHECKLIST / EMERGENCYRESPONDER COMMUNICATIONa. Make initial classification and categorize incidentb. Initiate proper response strategy (Section 5). For notifications, collect thefollowing information and communicate it to notified parties: Location of the incident (by Quadrant) Gate location closest to the incident Incident Type and Level (0 or 1)c. Account for facility personneld. Assure appropriate access gates are opene. Determine if environmental release is occurring and containf. Restore and resume normal operationINCIDENT DETAILDate and Time of Incident:Facility Coordinator:Description of Incident:Date and Time Resume Normal Activity:

ATTACHMENT BSPILL PREVENTION AND RESPONSE FOR LEACHATE

Spill Prevention and Response for LeachateSpill PreventionLeachate is collected from wells and collection sumps throughout the landfill. The leachate is piped tocollection tanks either directly or via internal lift station. There are currently two internal lift stations.Under normal operations, leachate is collected in Tank 1 (one of four 1-million gallon tanks), treated in inthe 316K tank and then stored in Tank 2 for load out. Tanks 3 and 4 and the 96 tank are available foradditional storage capacity of leachate either before or after treatment. Treated leachate is transferred tohauling trucks at the Leachate Loadout station. Table 1 lists of the devices and practices in place toprevent spills of leachate.Table 1 Spill Prevention Devices and PracticesSpill Prevention Devices and Practices96K Tank316K and1M Tanks******Pumps turned off during maintenance*******Dry disconnect couplingsNANADrip pansNANAVac Truck available to cleancontainment****SCADA level sensorMinimum freeboardHigh level alarm lightFrac TanksSecondary tank containmentDual containment pipingDaily NANA****Overfill prevention feed shutoffsBypass valvesPumps andLiftStations*1**********Truck LoadOut StationNA**21Buffer tank farm has clay berm. Sparge units have no secondary containment but have been deactivated.Loading is monitored continuously by driver2Leachate Piping All leachate conveyance piping is dual containment with the exception of the pressurized wellmanifolds. This piping lies entirely on top of flexible membrane line and is connected to dualcontainment sumps. Single walled piping may be used in temporary applications whennecessary. There are no hose flanges or connections in piping. The only connections are at pumps, valvesand the tanks, all of which have containment systems.

During maintenance involving pipe disconnection, pipes are vacuumed with a vac truck as neededto avoid spillage; there are two vac trucks on site.Drip pans are used as needed during pipe disconnection during maintenance.Leachate Pumps and Lift Station Each lift station is equipped with a high level alarm that activates a second pump to reducevolume quickly. If necessary, a second high-high level alarm triggers an automatic by-pass of thelift station and sends leachate directly to Tank 1. The lift stations and LCSs are equipped with SCADA monitoring and controls. Pumps and valve connections are within dual containment vaults. During maintenance, affected pumps are shut off and/or squeeze-off tools/valves are used toredirect leachate. After maintenance, leachate is removed from vaults and containments with a vacuum truck.316K and 1M Tanks Tanks are in secondary containment systems capable of holding 110% of the capacity of the tank. Tank filling is conducted manually by on/off switch at the control panel and is monitored by staffon site 24 hours, 7 days per week. Tanks are monitored via SCADA equipment. Additional analogue gauges are being installed. There is a 22’ maximum fill height; when freeboard is exceeded, the SCADA displays a highlevel on-screen alarm. The SCADA system is designed to generate a phone or email message to designated users whenhigh level is reached. This feature is under development and not yet implemented. There is a high–level alarm light on the SCADA panel at the tank. Tank and containment are inspected daily; staff are on site 24 hours, 7 days per week.96K Tank The tank has a secondary containment system capable of holding 110% of the capacity of thetank. There is an overfill bypass system to the secondary containment with a sump to the MSD liftstation (currently incapacitated). Tank filling is conducted manually by on/off switch at the control panel and is monitored by staffon site 24 hours, 7 days per week. Tanks are monitored via SCADA equipment. There is a 29’1” feet maximum fill height; when freeboard is exceeded, the SCADA displays ahigh level on-screen alarm. The SCADA system is designed to generate a phone or email message to designated users whenhigh level is reached. This feature is under development and not yet implemented. The Tank has a high level light on the control panel. The Tank and containment are inspected daily and staff are on site 24 hours, 7 days per week.

Truck Leachate Loadout Station Leachate loading station has a concrete containment.The containment drains to a sump pump that pumps liquid back to the 316K tank.Truck leachate loading is monitored continuously be driver in overhead safety cage; engineeringcontrols prevent the driver from leaving the area during filling.Frac Tanks Regular use of frac tanks has been discontinued. All frac tanks on site are in the process of beingemptied and decommissioned. Each frac tank has an isolation/shut off valve. The buffer tank farm has a clay containment berm and on-site vac trucks to enable quick responseto remove any spills. During piping changes or maintenance, pipes are vacuumed with a vac truck to avoid spillage.

Spill ResponsePrevent Additional ReleaseIf there is a release of leachate from a tank, container, piping, secondary containment or otherequipment, or if any equipment that is used for managing leachate which becomes unfit for use,the equipment must be removed from service as soon as safely practicable.In the event of a failure of equipment, landfill technicians or contract leachate workers under thesupervision of a landfill Environmental Specialist/Manager will immediately take steps to shutoff pumps and valves as necessary to relieve pressure from the affected tank or line and isolate itfrom the rest of the system.If the landfill stops operations in response to a fire, explosion, or release, the Facility EmergencyCoordinator or his designee must monitor for leaks, pressure buildup, gas generation, or rupturesin valves, pipes or other equipment, wherever this is appropriate.If the release is from a tank or container, waste must be removed to prevent further release to theenvironment and to allow inspection and repair of the vessel.Immediately or as soon as safely possible, take steps to prevent further migration of the release.If a release is contained within a secondary containment system, all released leachate must beremoved within 24 hours or in as timely a manner as is practicable to prevent harm to humanhealth and the environment. All recovered leachate must be treated, stored, and disposed toprevent further release or exposure and insure compliance with applicable regulations.NotificationIn addition to the notifications described in the flow diagram titled “Incident Leachate Release”the Facility Emergency Coordinator will submit a written report within 15 days after any Level 1incident to the Missouri DNR. The report must contain the following: Name, address, and telephone number of the facility,Date, time, and type of incident (e.g. surface fire, explosion),Quantity of leachate involved,Extent of injuries, if any,An assessment of actual or potential hazards to human health or the environment, wherethis is applicable,Disposition of leachate,Likely route of migration of the release,Description of response actions taken or planned,Characteristics of the surrounding soil (soil composition, geology, hydrogeology, (ifavailable). If sampling or monitoring data relating to the release are not available within30 days, these data must be submitted to the Missouri DNR as soon as they becomeavailable; andProximity to downgradient drinking water, surface water, and population areas.

Assessment, Containment and Immediate CleanupFor any release of leachate to the ground, regardless of whether it is contained in the stormwatercollection system, the Facility Emergency Coordinator (or designee when the FacilityEmergency Coordinator is on call) must immediately: Id

Chief 314-393-4802 3. Call Robertson FD Assistant Fire Chief 314-575-5011 4. Notify MDNR 573-751-5401 & St. Louis Co. DoH 5. Coordinate extinguishment (use heavy equipment to smother with dirt or extinguish with water truck spray) 6. Monitor continuously for one hour to ensure extinguished

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