2007-11-20_REVISION - M1982015 ‎(19)‎

• Permit No: M1982015
• IBM Index Class Name: REVISION
• Doc Date: 11/20/2007
• Doc Name: Appendix 1, Email Correspondence
• From: E-21 Engineering, Inc.
• To: DRMS
• Type & Sequence: TR3
• Media Type: D
• Archive: No

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BRIAN WOODY
From: "WALTER Avramenko" <[e-mail]>
To: "'Sergius Hanson"' <serge@e-21 engineering.com>
Cc: <[e-mail]>; <[e-mail]>; <[e-mail]>;
<[e-mail]>; "Norm Higley" <[e-mail]>; "Teresa J Bennett"
<[e-mail]>; <[e-mail]>;
<[e-mail]>; <[e-mail]>
Sent: Friday, February 16, 2007 3:48 PM
Subject: Re: Revision 1 Bayshore Waste Mgmnt Plan - Free ProductRecovery
Dear Mr. Hanson:
I have reviewed your February 16, 2007 "Revision 1 to the Waste
Management Plan" for the Bayshore Ponds gasoline remediation project.
My comments with regard to this proposal are as follows:
1. I have no objection to using duel-phase extraction to recover
gasoline and impacted water.
2. Although it was not covered in the letter, it is my understanding
that you've had conversations with Teresa Bennett regarding the
management, classification and disposal of the recovered 2 phase liquid.
To reiterate what she may have told you, the two options are:
* Manage the entire mixture (gasoline and water) as a hazardous waste
for disposal at the Arvada Treatment Center, or some other facility
licenced/permitted to treat, store or dispose of hazardous waste
(ignitable, and/or characteristic for benzene).
* Allow the gasoline/water mixture to separate and decant the gasoline
off the water. Recovered gasoline may be managed as a product for
recycling (e.g., to a refinery as an off-spec commercial product for
reclamation). When handled in this fashion, the gasoline is not a solid
waste and therefore not a hazardous waste (6 CCR 1007-3, Section
261.2(e)). The water that was in contact with the gasoline probably
contains significant quantities of dissolved phase constituents. It can
be 1) tested to prove it is non hazardous (for the toxicity
characteristic, for benzene), allowing for disposal as a solid waste at
the Arvada Treatment Center, 2) it is assumed to be a hazardous waste
for disposal at the Arvada Treatment Center or 3) can be treated in
accordance with Section 100.21(d) of the Colorado Hazardous Waste
Regulations to render it non-hazardous for subsequent management.
' If a hazardous waste is generated during this remediation that requires
off-site disposal, E-21 must get an EPA ID no. as a generator. To do
this, contact Amy Williams at 303-692-3461.
' 3. I have no objection to stabilizing the impacted soils and slurry
using cement in the trench to absorb liquids and make the mixture more
easy to excavate and manage in preparation for transportation and
' 6/9/2007