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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 3 <br />Section 6.2, Personnel and Equipment Requirements: Section 6.2 indicates that ASCI will <br />normally have a minimum of two employees at the site. The Division requires that at least one <br />employee be present at the site at all times when the facility is receiving soil or other inert <br />material, and when the facility's entrance gate is open. <br />6. Section 6.5 Recordkeeping: All records shall be maintained throughout the life of the facility, <br />including the duration of the post-closure care period. <br />7. Section 8 Final Grades and Cover Materials: The proposed final cover (both grades and <br />configuration) does not satisfy the requirements set forth in Sections 3.5.2 and 3.5.3 of the <br />Solid Waste Regulations. Variations from these standards may be approved by the Division if <br />the adequacy of the proposed variance can be satisfactorily demonstrated. Additionally, <br />pursuant to the requirements in Section 3.3.3 of the Solid Waste Regulations a Construction <br />Quality Assurance/Quality Control Plan ("CQA/QCP") for all engineered features, which <br />would include final cover, must be prepared and approved by the Division prior to construction. <br />In preparing the CQA/QCP, the Division recommends using the testing frequencies and <br />methodologies outlined in the Division's recently finalized guidance document for preparing <br />Quality Assurance/Quality Control Plans. While the guidance document does not specifically <br />address barrier layers in final covers, the testing frequencies and recommendations provided for <br />soil liners are appropriate for use in construction of a barrier layer in final cover. The guidance <br />document can be found at the following web site: b.ttp://wNA--"-,.cdphe.state.co.i.is-hrn/ <br />engdesigngagc.pol <br />8. Section 9.1 Groundwater Monitoring: Section 9.1 includes the following statement: <br />"Current ground water conditions will be defined by the data from four separated sampling <br />events using the two existing up-gradient wells and two new proposed down-gradient wells. <br />These samples will form the initial background pool for statistical evaluation. " The Division <br />requires the initial groundwater monitoring program to consist of at least eight sampling events <br />with an initial sampling frequency of no greater than quarterly. Also, because backer (ling of the <br />Speer Pit with soil and other inert fill commenced starting in January 2008, one or more of the <br />proposed down-gradient wells may not be reflective of "background" conditions. <br />Consequently, the down-gradient data will be considered "current groundwater quality" rather <br />than "background" water quality. <br />9. Section 10.1 Groundwater Monitoring: Section 10.1 indicates that ASCI proposes to initiate <br />installation of proposed new groundwater monitoring wells within three months following <br />issuance of the Certificate of Designation. Prior to resumption of inert landfilling the Division <br />will require: (1) the approved groundwater monitoring well network to be 'in-place, and (2) the <br />initial groundwater sampling event to be completed. Before the Division can evaluate the <br />adequacy of the proposed monitoring well network, the Division requires ASCI to provide: (1) <br />a landfilling sequence plan (i.e., Where will filling commence? How will filling progress?), <br />and (2) a schedule for any proposed changes to, or discontinuation of, ongoing dewatering <br />activities.