SCOTT A. THOMPSON
Executive Director

January 24, 2018

Jungho Ahn, Project Manager
ENVIRONMENTAL REVIEW, INC.
P.O. Box 2756
Berkeley, CA 94702

RE:      Clean Harbors Lone Mountain, LLC – Lone Mountain Facility
             Waynoka, Oklahoma, EPA ID NO. OKD065438376

             Post-Closure Renewal Draft Permit – Public Comment

Dear Jungho:

On December 24, 2017, the Land Protection Division of the Department of Environmental Quality (DEQ) received via email your comments on the Clean Harbors Lone Mountain (CHLM) above referenced draft Permit DEQ has reviewed your comments, and provides the following responses:

1.      In regards to Part III – Post-Closure Care of the draft Permit, you requested information on other monitoring requirements to be considered in addition to groundwater monitoring. Additional monitoring requirements reflected in Part III of the post-closure draft Permit include: leak detection monitoring systems, leachate monitoring and collection, run-on and run-off management systems, and periodic monitoring of any damage to landfill cell closure caps, embankments or associated components. There are also air and water monitoring requirements outlined in CHLM’s Air Quality Permit and Stormwater General Permit.

2.      In regards to Part I, Section I.E.8 – Duty to Provide information, you mentioned that a particular time frame should be specified for submitting information that DEQ requests related to modifying, revoking and reissuing, or terminating the Permit. When DEQ requests any such information from the Permittee, a specific time frame is always outlined in the request letters. Specific time frames for submitting reports are also outlined in Section IV.E – Recordkeeping And Reporting.
Regarding Section V.C – Notification Requirements for Newly-Discovered Releases at WMA(s) and AOC(s), you mentioned a more specific time frame for notifying DEQ of a release. The wording of this section is in accordance with Title 252 of the Oklahoma Administrative Code (OAC 252) chapter 205-13-1, which states in part that the owner or operator shall immediately notify the DEQ and take all necessary action to contain, remediate, and mitigate hazards from the release. Section V.C also mentions a specific time frame of fifteen (15) days for submitting a written notification of discovery of a release.

DEQ appreciates your comments on the CHLM Post-Closure Draft Permit, and does not find that changes to theses sections are necessary. If you should have any questions regarding this correspondence, please contact Brigette Haley of my staff at 405-702-5104 or This email address is being protected from spambots. You need JavaScript enabled to view it..

Sincerely,
Hillary Young, P.E.
Chief Engineer
Land Protection Division

Subject: _Clean Harbors Lone Mountain, LLC Lone Mountain Facility Major County, Oklahoma Post-Closure Permit, Hazardous Waste Treatment, Storage and Disposal Facility, Waynoka, OK due 12/24/2017

Hillary Young
Chief Engineer
Land Protection Division
Oklahoma Department of Environmental Quality
707 North Robinson
P.O. Box 1677
Oklahoma City, Oklahoma 73101-1677

Dear Ms. Young:

Environmental Review, Inc. has reviewed the document and has the following comments:

1. Page III-1 (Part III Post-Closure Care) The document refers the duty of Clean Harbors Environmental Services, LLC Lone Mountain Facility (the Permittee) to provide analysis for groundwater monitoring; are there other monitoring requirements which should be considered (e.g. air monitoring, ecological monitoring, noise monitoring)? 

2. Page I-6 and Page V-3 Section I.E.8 first sentence and Section V.C) The document should indicate specific deadlines for submittal of reports. For instance, at page I-6, the document indicates when Oklahoma Department of Environmental Quality (DEQ) requires any relevant information, the Permittee should furnish the data to DEQ within a reasonable time, that should be specified (usually 45 days from the date of fieldwork for submittal of a report is considered reasonable). Also, the document specifies that the Permittee should notify DEQ after an occurrence of hazardous contaminant release in their Waste Management Areas; the time frame should be defined here (e.g. 24-hour notice, in that case, may be considered reasonable).  

Sincerely yours, 

Jungho Ahn - Project Manager,

Environmental Review, Inc., 

P.O. Box 2756, Berkeley, CA 94702

www.envreview.org