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Mr. John Paul Ary <br />March 3, 2014 <br />Page 3 <br />and information for the final destination disposal or recycling facility; 3) disposal <br />receipts from the waste hauler and receipts from the destination disposal facility <br />receiving the debris and/or fill; and 4) any sampling and analysis results associated <br />with waste profiling purposes and confirmation soil sampling efforts. <br />Deficiency 2: Mr. Ary has failed to establish financial assurance for the closure and post - closure <br />care of the solid waste disposal site and facility, as required by the Act and the <br />Regulations. This is in violation of CRS 30 -20 -104 and Section 1.8 of the <br />Regulations. <br />Requested Action 2: No action is required at this time. <br />Deficiency 3: Mr. Ary has failed to conduct groundwater and explosive gas monitoring, as required <br />by the Act and the Regulations. This is in violation of Section 2.2 and 2.3 of the <br />Regulations. <br />Requested Action 3: No action is required at this time. <br />Deficiency 4: Mr. Ary has failed to provide stormwater controls at the solid waste disposal site and <br />facility. This is in violation of Section 2.1.6 of the Regulations. <br />Requested Action 4: No action is required at this time. <br />Recommendation 1: Regarding the waste tires being stored in the central region of the property within the <br />Division of Reclamation Mining and Safety (DRMS) permit boundary; it is <br />important to note that these waste tires cannot be used for backfill, rather it is <br />assumed they will be hauled offsite for appropriate recycling, reuse or disposal. The <br />large number of tires being stockpiled in their current configuration introduces the <br />potential for nuisance conditions by providing shelter and protection for vectors such <br />as mosquitoes, rodents and snakes. It is the Division's recommendation that the <br />facility proactively work to minimize the size of the waste tire stockpile during the <br />next few years. <br />Recommendation 2: Relative to the practice of rinsing and washing the rotating drums of concrete trucks <br />and then discharging the wash water into one of three unlined sedimentation basins <br />on the southwest perimeter of the property; this practice appears to be an unpermitted <br />discharge activity. The Department is researching standard industry practice and an <br />effort is underway to identify the best permitting option for this activity. The <br />Department will provide additional input regarding your options for this activity in <br />the future. <br />To facilitate resolution of the issues identified in this Compliance Advisory, we encourage you to contact <br />this office at the number listed below by March 21, 2014 to schedule a meeting: <br />A. To discuss the Compliance Advisory and answer any questions that you may have; <br />B. To develop a schedule for correcting the deficiencies noted above; or <br />C. To submit information necessary to show that the deficiencies are not a violation of Colorado's <br />solid waste laws. <br />