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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(B)(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 longer 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 $125 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 larry.bruskin@state.co.us. <br />Sinc ely, <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: sw/elp/csr/2.2, 2.5 and 4.3 <br />2