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July 21, 20 10 <br />Mr. Dan Hunt, President <br />Comments from Comprehensive Technical Review <br />Certificate of Designation Application for Speer Inert Landfill <br />Adams County Planning and Development Department, Case No. EXG2009-0000 <br />Page 2 <br />A comprehensive technical review of the CD application is required by statute to be completed within <br />150 calendar days following the end of the 30-day completeness review period (April 27, 2010). The <br />Division conducted and completed its comprehensive technical review of Revision 1 and ASCI's May <br />28, 2010 response document in accordance with procedures outlined in state statute and corresponding <br />Solid Waste Regulations. The Division's comprehensive technical review of Revision 1 resulted in no <br />new comments beyond the preliminary comments presented via the Division's April 27, 2010 letter. <br />However, the Division requires ASCI to modify certain provisions from its response document. The <br />information from the ASCI response document with the modifications described herein shall be <br />incorporated into an updated Plan. The updated Plan: shall be submitted to the Division for its review <br />and approval. <br />ASCI's Response to the Division's General Comment #1: The Division's General Comment <br />#1 from its April 27, 2010 letter requires ASCI to provide greater detail regarding its planned <br />screening procedures to prevent receipt of contaminated soil, contaminated debris, and other <br />unacceptable materials at the proposed Speer Inert Landfill. ASCI's response document dated <br />May 28, 2010 addressed the issue in part by proposing the following procedure: "ASCI <br />commits to perform the Toxicity Characteristic Leaching Procedure ("TCLP') as defined by <br />EPA method 1311 and as described under Section 6.5.4 of the DRAFT Soil Remediation <br />Objectives Policy Document developed by the CDPHE in 1997. ASCI will perform this test for <br />the 8 RCRA metals on sample(s) collected from soils that have been brought to the Speer site <br />and that have been screened both by visual and olfactory methods and have been found to be <br />questionable as to suitability from a potential contamination issue for fill within the pit. These <br />soils will be set aside and will be tested by the TCLP method. " <br />The updated Plan must incorporate the following additional considerations/requirements <br />regarding waste and soil screening procedures: <br />a) Because inorganic compounds such as the 8 RCRA metals can be naturally occurring in <br />-some geologic- environments-in-Color-ado--at fair-ly=high=comentrations, °it-will be- - - - <br />necessary to evaluate and test, as appropriate, potential source material before it is <br />delivered to the site. This is especially essential for large-volume projects. The <br />screening procedures described in ASCI's response document are more appropriate for <br />small-quantities received from the general public. <br />b) The updated Plan must describe how ASCI will use the TCLP results to determine <br />whether soil is suitable for acceptance. The Division's 1997 Soil Remediation <br />Objectives Policy Document and corresponding Colorado Soil Evaluation Values <br />("CSEV") Table 1 (December 2007) provide useful guidance. Using fate and transport <br />modeling the Division established Leachate Reference Concentration values for a <br />number of inorganic constituents. Leachate Reference Concentration values are <br />presented in CSEV Table 1. If leach test results are equal to or below the Leachate <br />Reference Concentration values, it is assumed, based on fate and transport modeling, <br />that the soil will pose little to no threat to local groundwater quality. Conversely, if the <br />leach test results exceed the Leachate Reference Concentration, it is assumed that the