Laserfiche WebLink
July 21, 2010 <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 3 <br />soil will leach hazardous substances to groundwater and potentially degrade the <br />groundwater quality in excess of the allowable standard. <br />c) In certain instances soil may not be adequately characterized by limiting the leach <br />testing to 8 RCRA metals. Each potential source of fill material shall be evaluated <br />based on site location, prior land use, quantity of material, etc., to determine necessary <br />testing parameters and frequency of testing to adequately characterize the potential fill <br />material. <br />2. AS-CI's Response---to the-Division's General Comment #2: -The Divisiows -General <br />Comment #2 from its April 27, 2010 letter requires the Plan to be reviewed, signed, and <br />stamped, as appropriate, by a Colorado-registered professional engineer or professional <br />geologist. ASCI's response document addresses the issue by providing a signed statement by <br />Robert Laird, the author of the Plan. Please note that when the Plan is revised and resubmitted <br />to the Division for review and approval, the cover page must be signed by Mr. Laird as the <br />Professional Geologist of record. <br />3. ASCI's Response to the Division's Comment #3: The Division's Comment #3 from its April <br />27, 2010 letter requires the landfilling of asphalt-containing material to be restricted to the <br />portion of airspace that is at least one (1) foot above the maximum seasonal ground water <br />elevation and beneath the final cover. ASCI's response to this issue includes the following: <br />"All data heretofore with this application has determined an average elevation of the water <br />table to`be 5009 ft. The maximum seasonal high elevation would then be 501 Oft. ASCI commits <br />to placing asphalt chunks, as part of the inert fill for this site, at an elevation no lower than <br />5011 ft., MSL. " The groundwater level data does not seem to support ASCI's conclusion <br />regarding the maximum seasonal high elevation level. The data indicates that the historic water <br />level elevation (prior to dewatering) was generally about 5020 feet MSL along the site's east <br />boundary. Even certain recent measurements that may be artificially low as a result of <br />dewatering seem to show water level elevations in the range of 5015 to 5018 feet MSL. ASCI <br />must clarify this issue. <br />4. ASCI's Response to the Division's Comment #4: The Division's Comment #4 from its April <br />27, 2010 letter requires ASCI to provide a schedule for construction of the perimeter drain to be <br />installed pursuant to requirements of the Division of Reclamation, Mining and Safety <br />("DRMS"). In response to Comment #4, ASCI provided copies of e-mail correspondence <br />between DRMS and ASCI. The DRMS e-mail correspondence includes the following <br />statement: "So long as the temporary drain is doing its job, and as long as the backfill is below <br />the level of the temporary drain outflow, then the situation is stable and we can cross the <br />bridge to the permanent drain at a later time. " The Division agrees with the DRMS statement. <br />However, ASCI has indicated that it plans to shut off and temporarily remove the de-watering <br />pump(s) and allow groundwater to fill the pit upon commencement of filling operations (see <br />ASCI's Response #9, May 28, 2010). Under such a plan, the temporary drain is unlikely to <br />function as required by DRMS. Therefore, ASCI must obtain written approval from DRMS <br />regarding ASCI's plan for ceasing to operate or removing the de-watering pump(s). ASCI