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GRAND I S L.A V D P.O.Box 3395 <br /> PO4 Nederland,CO 80466 <br /> R E S O U R C E S November 2,2020 <br /> GIR believes pond 3A to be very close to the existing permit boundary. As was discussed with DRMS on 9/15/2020, <br /> the permit boundary will be amended twice in the coming months. First, GIR is to submit a 'Partial Release of <br /> Permit Area' which will reduce the overall permit boundary by 0.40 acres (DRMS Request for Partial Release of <br /> Permit Area Map2). Through the upcoming Amendment#2 process,the Disturbance area will then be increased <br /> to include additional land to the South West side of Pond 3A, ensuring all ponds are within the permitted area <br /> (Proposed Permit Boundary Modifications Map 3). <br /> 3) Please address the following items regarding the sludge present in Ponds 38 and 3C: <br /> a. On page 4, the operator states there is a small amount of sludge settled in the bottom of Ponds 38 <br /> and 3C that was left over from treatment 34 years ago. Please provide an estimated volume for the <br /> sludge present in these ponds. <br /> The sludge has been removed and is stored in"super sacks"on-site. There are 10"super sacks"that are <br /> approximately half full. Estimated volume is 20 cubic ft per sack for a total of 200 cubic feet. <br /> b. On page 4, the operator states that multiple samples (of the sludge) have been tested through <br /> Colorado Analytical for their metals concentration as well as toxicity. The laboratory results provided <br /> appear to be for a composite sample.However,the operator does not specify how many samples were <br /> collected from the sludge in each pond, and how the sampling plan was developed to sufficiently <br /> characterize this material. Please provide more details on the sampling process utilized and how this <br /> process produced representative samples for adequately characterizing the sludge. <br /> Composite samples taken on 7/6/2020 were sampled from a variety of locations and depths in ponds 3B and 3C. <br /> The Operator was directed by the Laboratory to run 503 Sludge Analysis on the samples. However,this was not <br /> the correct analysis.The 503 analysis is for residential or municipal biosolid waste and not applicable for the sludge <br /> in question. <br /> c. The laboratory results provided for the sludge show a total lead concentration of 253.8 mg/kg, which <br /> is more than 20 times the toxicity characteristic leaching procedure (TCLP) regulatory limit. To be <br /> exact the lead concentration in the sludge is 153.8%more than 20 times theTCLP limit for lead,which <br /> is 100 mg/kg. This means the sludge may be a hazardous waste and should be handled as such until <br /> further testing, using the TCLP analysis, confirms the waste's toxicity characteristic results. Please <br /> commit to collecting representative samples of the sludge, having a TCLP metals test run on these <br /> samples for arsenic, barium, cadmium, chromium, lead, mercury, selenium,and silver,and reporting <br /> the results of the TCLP test(s)to the Division prior to handling the sludge. <br /> At the direction of DRMS(after a conversation had on-site on 9/15/2020)GIR took samples from all 10 individual <br /> "super sacks"of material. The samples were taken from three different levels to get a representative, composite <br /> sample from each sack. See pictures for sampling techniques. Each sample was analyzed with the TCLP method <br /> and all of the results are well below EPA thresholds. (Colorado Analytical Lab reports attached)(Attachment 1). <br /> 2 <br />