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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 5 <br />be employed by ASCI are effective. Following the initial eight (8) sampling events, ASCI may <br />request approval from the Division and Adams County to reduce the monitoring frequency <br />and/or modify the list of constituents (See Comment #9). <br />9. ASCI's Response to the Division's Comment #9: The Division requires that the two new <br />down-gradient wells be installed, and that the first quarterly sampling event for all wells be <br />completed prior to resumption of inert material landfilling. The Division approves the fill <br />sequencing plan shown on Exhibit 2 in Attachment 4. However, a schedule for installation of <br />.the..perimeter-drain-must be-established,_and-roust-be app -o-ved-b3-DRM-S,-in-conjunefion with- - <br />ASCI's plan for removing or ceasing to operate the de-watering pump(s) (See Comment #4). A <br />copy of the DRMS approval letter must be provided to the Division prior to discontinuing <br />operation of or removal of the de-watering pump(s). <br />ASCI response #9 indicates that the pond liner will be constructed and leak tested in <br />accordance with State Engineer Office guidelines. ASCI must include the details of the <br />referenced guidelines in the CQA/QCP. <br />10. ASCI's Response to the Division's Comment #10: ASCI's Response #10 includes the <br />following statement: "The new sheet for Attachment]] is supplied herein as Attachment 5. " <br />The May 28, 2010 correspondence does not include an Attachment 5. The updated Plan must <br />include a drawing that shows the surveyed locations of the two existing wells, and approximate <br />locations of the two new down-gradient wells. Well designations for existing wells shall be <br />consistent with historic designations and shall be referenced consistently throughout the <br />updated Plan. <br />11. ASCI's Response to the Division's Comment #11: The Division approves ASCI's response <br />to Division's Comments #11. <br />12. ASCI's Response to the Division's Comment #12: The Division approves ASCI's response <br />to Division's Comment #12 with the following modification. The updated Plan shall <br />incorporate the following information into the quarterly groundwater monitoring summary <br />reports: (1) groundwater elevation measurements, (2) well purging data, (3) field parameter <br />test data, (4) chain of custody documentation, (5) laboratory test data including quality <br />assurance and quality control information, (6) a summary table that lists all detected <br />constituents and corresponding groundwater quality standards, and (7) a summary and <br />conclusions section that includes an explanation of anomalous data. Following the initial eight <br />groundwater monitoring events, the summary reports may be submitted annually and shall also <br />include conclusions and results of statistical analyses of groundwater data conducted pursuant <br />to the requirements set forth in Appendix B of the Solid Waste Regulations. <br />13. ASCI's Response to the Division's Comment #13: The Division approves ASCI's response <br />to Division's Comments #13.