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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 4 <br />must provide a copy of the DRMS approval letter to the Division prior to ceasing operations of <br />the de-watering pump(s) (See Comment #9). <br />5. ASCI's Response to the Division's Comment #5: The Division approves ASCI's response to <br />Division's Comments #5. <br />6. ASCI's Response to the Division's Comment #6: The Division approves ASCI's response to <br />Division's Comments #6. <br />7. ASCI's Response to the Division's Comment #7: The Division approves ASCI's waiver <br />request for alternative final cover and alternative final grades with the following modification. <br />The Division requires the final cover to consist of at least 24 inches of clean soil. The upper 6 <br />inches of final cover shall consist of topsoil capable of supporting vegetation. The Division <br />does not require a compaction specification or a soil-type specification since the site is being <br />proposed as an inert material landfill. <br />ASCI's response indicates that the updated Plan.will include a Construction Quality <br />Assurance/Quality Control Plan ("CQA/QCP") that provides the surveying and reporting (as- <br />built certification report) requirements for final cover placement. In preparing the CQA/QCP, <br />the Division recommends using the surveying requirements and methodologies as described in <br />the Division's guidance document for preparing Quality Assurance/Quality Control Plans. The <br />guidance document can be found at the following web site: littp://www.cd phe.state.co.us/ <br />hm/engdesigngagc.pdf. In addition to the reporting requirements presented in the guidance <br />document the Division requires ASCI to incorporate photographic documentation into the as- <br />built certification report requirements (See Comment #9). <br />8. ASCI's Response to the Division's Comment #8: Section 9.1 of Revision 1 and ASCI's <br />response to the Division's Comment #8 requests a variance from the requirement in Appendix <br />-.--B4($) of the Solid Waste Regulations which-st;pu-lates-thafi ?`to establish background <br />concentrations, a minimum of eight quarterly samples from each well must be collected and <br />analyzed for the Appendix IA and IB constituents.... " The ASCI response document proposes <br />the initial groundwater sampling to consist of four (4) quarterly sampling events followed by <br />semi-annual monitoring. The Division does not approve ASCI's variance request. The <br />Division requires the initial groundwater program to consist of at least eight (8) sampling <br />events performed at a frequency of no greater than quarterly. The Division will consider <br />approving a more frequent sampling program (e.g., monthly) for the initial eight (8) sampling <br />events if requested by ASCI. <br />The Division recognizes that because backfilling of the Speer Pit with soil and other inert fill <br />material commenced in January 2008, one or more of the proposed down-gradient wells may <br />not be reflective of "background" conditions. Nonetheless, the initial eight (8) sampling events <br />will be useful in detecting trends and differences in water quality between up-gradient and <br />down-gradient wells, and will also be useful in confirming that the soil screening procedures to