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compliant material by the equipment operators during placement activities, there is no discussion <br /> as to the required training that the operators will receive in order to identify non-compliant <br /> material, as required in Section 2.1.2(B)(3) of the Colorado solid waste regulations, 6 CCR 1007- <br /> 2 (the Regulations). The EDOP must be modified to include the required training the equipment <br /> operator, or anyone else tasked with the material screening responsibility, will receive. In <br /> addition, the frequency of spot-checks should also be identified in the EDOP. <br /> Pursuant to Section 1.5 of the Regulations, a waiver request was submitted because CSU <br /> believes that the inert nature of the fill material along with the characteristics of the site provide <br /> adequate environmental protection, thus negating the need for a liner and groundwater <br /> monitoring. Specifically, CSU points to the inert, non-putrescible nature of the fill material, the <br /> limited quantity of shallow, horizontally non-continuous groundwater beneath the Gravel Pit #2 <br /> area, the low hydraulic conductivity of the Pierre shale underlying the site, and the large ratio of <br /> evaporation (over 40-inches per year)to precipitation (— 15-inches per year). <br /> Based on the above, and pursuant to the Regulations Pertaining to Solid Waste Sites and <br /> Facilities, 6 CCR 1007-2, the Division hereby approves, as final agency action, with the <br /> modifications discussed above, the Fill Request. The Division also approves, as final agency <br /> action, the submitted Waiver Request, thereby eliminating the requirements to construct a liner <br /> beneath Gravel Pit #2 as well as eliminate groundwater monitoring requirements specific to <br /> Gravel Pit #2. Both the revised Fill Request, including Appendix C-1 of the EDOP, as well as <br /> the Waiver Request, must be placed within the facility's operating record. Please provide a copy <br /> of the revised EDOP to the Division within 30 calendar days from the date of this letter <br /> incorporating the waiver requests and language for site personnel training pursuant to Section <br /> 2.1.2(13)(3) of the Regulations. <br /> Please note that a waiver is granted based upon data, information and operational criteria <br /> submitted at a given point in time. Anytime a facility that has been granted a waiver by the <br /> Division can no Ionger meet the waiver criteria,the waiver is void and ceases to exist. <br /> In closing, the Division is authorized to bill for its review of technical submittals at 5125 per <br /> hour, pursuant to CRS 30-20-109(2)(b). An invoice for the Division's review of the above <br /> referenced documents will be sent under separate cover. <br /> Should you have any questions regarding this letter, I may be reached at 303-692-3384 or by <br /> email at larrti.h usl�an(�r statc_c�7.us. <br /> Sin <br /> Larry Bruskin <br /> Solid Waste and 'Material Management Unit <br /> Hazardous Materials and Waste ;Management Division <br /> cc: Mike Hrebenar, El Paso County <br /> Colorado Division of Reclamation Mining and Safety <br /> file: s•,\-ielp%csri2.2, 2.5 and 4.3 <br /> 2 <br />