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GRAND ISLAND 13ox <br /> Nederland.CO SO4N) <br /> RESOURCES No„rn,ber, 2020 <br /> is <br /> a" "7-'%" <br /> r <br /> i u , <br /> Figure 3 Sampling Super Sacks from multiple layers <br /> d. Please provide a disposal plan for the sludge in the event the TCLP results indicate the material is a <br /> "toxicity characteristic"hazardous waste. The operator may wish to contact the Hazardous Materials <br /> and Waste Management Division of the Colorado Department of Public Health and Environment to <br /> determine proper disposal of this type of waste. <br /> TCLP lab analysis conducted on 9/24/2020 showed our sludge to be a non-hazardous material. CDPHE's Solid <br /> Waste Compliance Assurance Unit confirmed that our sludge is not a regulated hazardous waste and can be <br /> disposed of at any solid waste landfill. GIR has contacted Republic Services and identified the landfill in Golden, <br /> CO as the preferred landfill for disposal. Prior to acceptance, Republic has requested additional analysis on the <br /> sludge: <br /> a. VOC's and SVOC's(submitted 10/27/2020) <br /> b. TENORM(submitting 11/2/2020) <br /> i. Combined Radium Ra-226 and Ra-228 <br /> ii. Uranium U-nat <br /> iii. Thorium Th-232 <br /> Based on historical and current data,GIR believes the additional testing will meet the landfill requirements. At <br /> that time, Republic will provide an approved waste profile and manifest for transport. <br /> 4/ Please provide a maintenance plan for the sediment ponds, including inspection frequency, sludge removal <br /> and disposal, vegetation management, and monitoring the condition of inlet/outlet pipes and other <br /> associated infrastructure. <br /> GIR's maintenance plan is as follows: <br /> a. Clean sludge from liners as needed. Previous ponds only required cleaning once in 30+years. <br /> i. Procedure to clean sludge from ponds: <br /> 4 <br />