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Mr. John Paul Ary <br />March 3, 2014 <br />Page 2 <br />will take into consideration your response to the requested actions listed below for each cited deficiency in <br />its consideration of enforcement options. <br />Note that deficiencies 1 and 2 (below) remain as originally cited on the in -field Compliance Advisory that <br />was issued to you during the January 22, 2014 inspection. Deficiencies 3 and 4 and Recommendations 1 <br />and 2 have been added to this Compliance Advisory Addendum. It is also important to note that additional <br />requested actions and compliance timeframes have been identified (below) for your implementation. <br />Deficiency 1: The Facility is being operated as a solid waste disposal site and facility not having a <br />certificate of designation (CD). This is in violation of CRS 30 -20- 102(1) and 30 -20- <br />102(2), and Section 1.3.3 of the Regulations. <br />Requested Action 1: Immediately cease disposal of additional solid waste on the subject property. This <br />includes ceasing disposal of office waste, paper records, and binders in the eastern- <br />most concrete washout sedimentation basin. This also includes ceasing the <br />stockpiling and disposal of broken concrete, construction and demolition debris, <br />pallets, brush, broken containers, and miscellaneous gallon and quart-sized <br />containers on the north side of the fabrication building. <br />Within thirty (30) calendar days following your receipt of this compliance advisory, <br />develop a Closure Plan for the facility and submit the plan to the Department for <br />review and approval prior to implementation. For documentation purposes, the <br />Closure Plan should include a description of the material types disposed in the <br />eastern-most washout sedimentation basin and on the north side of the fabrication <br />building. The Closure Plan must relay what you propose to do with each material <br />type, and include a detailed compliance schedule outlining dates by which each <br />material type will be managed for final transportation and disposal, backfilling, <br />reclamation, recycling or reuse purposes. <br />Additionally, the Closure Plan shall include provisions for investigative potholing <br />efforts on the half acre of land situated immediately north of the fabrication shop. <br />CDPHE inspectors observed stockpiles of debris in this location, and there was <br />evidence of recent grading and earthmoving activities in this area. The purpose of <br />this potholing effort will be to confirm that inappropriate materials are not buried at <br />this location. If potholing efforts reveal that additional waste was buried in this area, <br />excavation and removal activities must be implemented to ensure that the subject <br />waste material is disposed at an appropriate treatment, storage or disposal facility. <br />The Closure Plan should address this contingency. <br />Implementation of the Closure Plan shall begin immediately following Department <br />approval. <br />Within thirty (30) calendar days of completion of site remediation and full <br />implementation of the approved Closure Plan, a Closure Report shall be submitted to <br />the Department which includes 1) photographs of debris removal activities, including <br />before and after photographs and removal -in- progress photos; 2) text describing <br />removal activities for different material types, including hauler contact information, <br />