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March 11, 2010 <br />Mr. Dan Hunt, President <br />Certificate of Designation Application for Speer Inert Landfill <br />Completeness Review Determination: Incomplete <br />Adams County Planning and Development Department, Case No. EXG2009-0000 <br />Page 3 <br />13. Subsections 3.2.2(A),(C)&(G): The Plan does not provide the hydrologic data requirements <br />specified in Subsections 3.2.2(A),(C)&(G). Additionally, the Plan must address potential <br />impacts that the proposed filling may have on the groundwater flow patterns near the site, and <br />include engineering solutions to mitigate those potential impacts. <br />14. Sections 3.2.3 and 3.2.6: The Plan does not adequately address the engineering design details <br />for surface water control features, clay liner associated with the water storage reservoir, and <br />final cover. Additionally, in order to evaluate proposed surface water controls, the Division <br />requires the applicant to include a site map that shows existing topography at 2-foot contour <br />intervals. <br />15. Section 3.2.4: Construction specifications for proposed groundwater monitoring wells must be <br />included in the Plan. <br />16. Section 3.3: Some of the requirements in set forth in Section 3.3 are not necessarily applicable <br />to landfilling of inert material. However, the Plan must include greater detail pertaining to <br />requirements of Section 3.3 including, but not limited to: the site's legal description, employee <br />qualifications, job descriptions, fencing, conceptual plans to be implemented if contamination <br />of surface water or groundwater occurs, and quality assurance and quality control procedures <br />for construction of such features as compacted clay reservoir embankments and final cover. <br />The Plan shall clearly define and distinguish between the property boundary, the fill area, and <br />setback/buffer areas. <br />17. Sections 3.5 and 3.6: Closure and post-closure requirements have not been adequately <br />addressed in the Plan. <br />In addition to complying with the Division's Regulations, the applicant must comply with all relevant <br />federal, state, and local regulations including but not limited to the requirements of the Division of <br />Reclamation Mining and Safety, the Division of Water Resources, the Water Quality Control Division, <br />and the Air Pollution Control Division. The Division requires that a copy of the revised application be <br />forwarded to representatives from each of these Divisions (see cc list for respective contacts). <br />The Division is authorized to bill for its review of technical submittals pursuant to the provisions set <br />forth in Section 1.7 of the Regulations. Division staff charges its time at $125.00 per hour. For review <br />of a Certificate of Designation application, including the completeness review, the fee ceiling is <br />$35,000. An invoice for the Division's completeness review will be transmitted to Asphalt Specialties <br />under separate cover. <br />Should you have questions, or if you would like to schedule a meeting to discuss our comments, please <br />call Curt Stovall at (303) 692-2295 or Roger Doak at (303) 692-3437.