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Waste Management uses a comprehensive Environmental Management Program at the Kettleman Hills Facility (KHF) to help ensure compliance with regulatory and corporate requirements, and to protect human health and the environment.

The Environmental Management Program at the Kettleman Hills Facility is implemented by a team of 12 environmental professionals in the following roles:

• Environmental Manager —responsible for overall program implementation and management of the KHF environmental management department.
• Environmental Compliance Specialists — responsible for implementation of one or more technical program areas.
• Environmental Technicians — responsible for performing inspections, environmental support operations, and field monitoring.
• Administrative Staff — responsible for performing data management, recordkeeping, and reporting activities.

The Environmental Management Program is comprised of many complementary elements, which include the following:

Policies and Procedures — Standard corporate environmental policies and procedures are supplemented by an additional 214 site‐specific practices covering many additional areas of landfill management, such as drum storage, emergency response, security, site maintenance and health and safety.

Task Management—Waste Management’s “CYCLE” system is used to verify completion of more than 2,000 compliance tasks each year.

Inspections —Inspections are conducted 365 days a year to ensure proper facility operations, and to prevent and detect situations that could potentially lead to a release into the environment and/or a potential human health hazard.

Air Monitoring — An Ambient Air Monitoring Program collects air measurements at three sampling stations around KHF to evaluate whether potential emissions from the facility measurably affect air quality and to evaluate the potential human health risks. Currently, the program collects samples for 24 hours every 12 days, and quarterly reports are submitted to regulatory authorities. An initial evaluation of the data shows that the ambient air around KHF is consistent with background regional air quality.

Landfill Gas Monitoring —A landfill gas collection system and a landfill gas flare are used to minimize potential emissions, prevent gas migration off‐site and destroy landfill gas compounds.

Groundwater Monitoring—Groundwater monitoring is performed quarterly across a network of more than 45 active wells to track both groundwater quality and groundwater flow conditions.

Storage Tank Monitoring —Storage tanks are monitored in accordance with the KHF Spill Prevention, Control, and Countermeasure Plan and Underground Storage Tank Monitoring Procedures.

Training —The KHF training program includes both initial and continuing training requirements for each site position.

Laboratory Analysis —An on‐site lab staffed with a full‐time chemist and lab technicians is used to test incoming wastes and for post‐treatment certification testing. The KHF lab is certified by the California Department of Public Health’s Environmental Laboratory Accreditation Program (ELAP) for specific types of analyses. This certificate is issued after completion of the State’s application process, an ELAP technical staff site visit and review, and successful analysis of performance evaluation samples.

Environmental Self‐Assessments —Environmental Self Assessments (ESAs) are performed to identify any potential deficiencies in meeting environmental requirements, and to define a schedule for corrective action plan implementation.

Compliance Audit Services Program — The Compliance Audit Services Program is performed according to nationally recommended practices approved by the American Society for Testing and Materials (ASTM). This program evaluates controls used to achieve environmental, safety and health compliance.

Dakota Tracer System — Dakota Tracer is a tracking system for all findings identified through the Environmental Self‐Assessments, the Compliance Audit Services Program or regulatory agency inspections. It provides a real‐time view of compliance status, and also identifies what has been accomplished and what corrective and preventive actions still need to be addressed.

Documentation — KHF maintains an extensive documentation system to track site activities including waste receipts, treatment, and disposal.

Waste Management Corporate Environmental Management

In addition to the KHF team, Waste Management’s Corporate Environmental Management Group plays a central role in the implementation of KHF’s Environmental Management Program. The Corporate group is composed of specialists in different areas including environmental protection, groundwater protection, environmental engineering air and gas management, and laboratory services. These specialists provide environmental tools, training, and advice to site personnel.