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i <br />August 27, 2010 <br />Adams County Board of Commissioners <br />Final Agency Action: Recommendation for Approval with Conditions <br />Certificate of Designation Application for Speer Inert Landfill - Asphalt Specialties Company <br />Page 2 <br />The Division conducted and completed its comprehensive technical review of Revision 1 and ASCI's <br />May 28, 2010 response document in accordance with procedures outlined in State statute and <br />corresponding Solid Waste Regulations. The comments from the Division's comprehensive technical <br />review of Revision 1 were provided to ASCI in a letter dated July 21, 2010. The Division's July 21St <br />letter required ASCI to modify certain provisions from Revision 1 and its response document and <br />submit an updated Plan. <br />In response to the Division's July 21, 2010 letter, the Division received two documents: (1) a <br />memorandum from ASCI titled "Alluvial Groundwater Levels at Speer Inert Fill Site" dated August 9, <br />2010, and (2) a revised Operations and Closure Plan dated August 2010 ("Revision 2") received on <br />August 11, 2010..For ease of review, ASCI presented all proposed modificationsTor Revision 2 in <br />bold font. The Division has reviewed Revision 2 for technical merit. It is the determination of the <br />Division that the proposed facility can comply with the technical, environmental, and public health <br />standards in the Act and corresponding Solid Waste Regulations if the facility is constructed, operated, <br />and monitored as detailed in Revision 2, and with the conditions of the Division as stated in this letter. <br />Based on this assessment, the Division recommends, as final agency action, that this facility may be <br />approved by Adams County, with the conditions set forth herein and with any additional local <br />restrictions Adams County may choose to impose. The required conditions are as follows: <br />I . Section 4.1 of Revision 2 stipulates that asphalt materials must be placed at least I foot above <br />the seasonal high alluvial groundwater table elevation. Section 4.1 also includes the following <br />statement: "ASCI has determined that the elevation of one foot above the seasonal-high <br />groundwater elevation is 5008 ft. above MSL. " The groundwater elevation data provided by <br />ASCI shows that the groundwater table elevations prior to dewatering varied significantly <br />across the site. For example, a topographic map of the site from a 1999 aerial survey shows an <br />elevation of 5011.6 feet for surface water in a former pond near the southern end of the site. <br />Given the characteristics of the alluvial soil (i.e., sand and gravel) that existed in 1999, the <br />water elevation in the pond is likely to be a surface expression of the groundwater elevation <br />that existed in that area of the site in 1999 prior to dewatering activities. Consequently, the <br />Division believes that the groundwater table could return to elevations that are higher than 5008 <br />Feet above YASL at somelocattons at the site foil"-Wing ce`ssa -on ofgroundwater dewatering -- <br />activities. Therefore, prior to placement of any asphalt materials, and following cessation of <br />dewatering activities, the Division requires ASCI to assess and document stabilized <br />groundwater elevations at the site. The groundwater level documentation and assessment must <br />be provided to the Division for its review and approval prior to placement of any asphalt <br />materials at the site. <br />2. Section 8 of Revision 2 includes the following statement: "Approximately 18 inches (1.5 ft.) of <br />topsoil or clean fill dirt will be placed on top of all filled materials as final cover. " Pursuant to <br />the requirements in Section 3.5.3 of the Solid Waste Regulations, the Division requires the final <br />cover to consist of at least 24 inches of clean soil. The upper 6 inches of final cover shall <br />consist of topsoil capable of supporting vegetation. The Division does not require a <br />compaction specification or permeability specification since the site is being proposed as an <br />inert material landfill.