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April 27, 2010 <br />Mr. Dan Hunt, President <br />Certificate of Designation Application for Speer Inert Landfill <br />Completeness Review Determination: Complete <br />Adams County Planning and Development Department, Case No. EXG2009-0000 <br />Page 2 <br />for the purpose of expediting the review process. The following listed items (other than general <br />comments) refer to section numbers in Revision 1. <br />1. General Comment #1: Revision 1, including the Affidavit signed by Mr. Hunt, makes <br />numerous references to landfilling with "clean fill dirt." However, Revision 1 does not <br />adequately address a methodology for defining "clean fill dirt." Since much of the inert <br />material proposed for landfilling at the Speer Pit will be placed below the pre-mining <br />groundwater level proper characterization and screening of soil and inert material is very <br />important. _ <br />In Attachment 3 to Revision 1, ASCI compares test data from soil samples to the Colorado Soil <br />Evaluation Values ("CSEV") and, on that basis, concludes that the inert fill already placed by <br />ASCI in the Speer Pit is "clean." The Division believes that there is insufficient test data to <br />draw such a conclusion. Please note that the intent of the CSEV is to provide a tool to assist in <br />making efficient, cost-effective, and site-specific remedial action decisions at sites where <br />contaminants are present or suspected in the soil. While the intent of the CSEV is also to <br />protect groundwater, the CSEV are based on mathematical fate and transport modeling <br />simulating vertical movement of contaminants (including naturally occurring concentrations of <br />constituents) from unsaturated soils down to the groundwater table. Therefore, the CSEV alone <br />may not provide appropriate screening levels for the proposed inert landfill where soil and <br />other inert material will be placed below the groundwater table. The Division recommends that <br />ASCI review the companion draft technical policy document to the CSEV table, which can be <br />found at the following web site: li.ttp://www.edplie.state.co.u.s/hni/soiIplcvdi-aft.pdf. Section <br />6.5.4 of the draft policy document provides recommendations for test procedures to estimate <br />the concentration of inorganic constituents that are likely to leach from soil to groundwater. <br />Soil testing procedures similar to those described in Section 6.5.4 shall be incorporated, as <br />appropriate, into the application as a means of screening for potentially contaminated soil. <br />_G_eneral.Comment_#2: he, pplication must be reviewed signed, and stamped by <br />Colorado-registered professional engineer or professional geologist, as appropriate. <br />Section 4.1 Types of Materials: Section 4.1 indicates that asphalt will be placed only 1 foot <br />above the average water table elevation. The Division requires that asphalt only be placed at <br />least 1 foot above the maximum seasonal ground water elevation. <br />4. Section 5.6 Nearby Wells: Section 5.6 includes the following statement: "Locations, <br />completion depths, dates, static water levels and other information has been compiled by ASCI <br />as part of the DRMS approval and design of a "French Drain " required to be constructed on <br />the east side/up-gradient side of the permit area....... " This compilation of groundwater <br />information shall be included in the application. Additionally, the application shall include the <br />schedule for construction of the French Drain to be installed pursuant to requirements of the <br />DRMS approval.