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August 31, 2010 <br />Mr. Ben Frei <br />Certificate of Designation Application for Frei-Henderson Inert Landfill <br />Completeness Review Determination: Complete <br />Page 6 <br />15. Section 6.1- Groundwater Monitoring Program: Section 6.1 indicates that two up-gradient <br />and two down-gradient wells are proposed for the site. However, the DOP does not provide a <br />hydrogeologic evaluation of the site. Adequate hydrogeologic data must be added to the DOP <br />before the Division is able to evaluate the adequacy of the proposed groundwater monitoring <br />system. <br />16. Section 6.2 Groundwater Sampling and Analysis Requirements: Section 6.2 indicates that <br />the eight quarterly sampling events will be conducted to establish background conditions. This <br />stipulation implies that the eight quarters of groundwater sampling will take place prior to <br />commencement of waste placement. Please confirm. <br />17. Section 6.2.4 - Reporting: During the initial eight groundwater monitoring events, summary <br />reports shall be prepared and submitted to the Division for each event. The reports shall include <br />at a minimum: (1) groundwater elevation measurements, (2) well purging data, (3) field <br />parameter test data, (4) chain of custody documentation, (5) laboratory test data including <br />quality assurance and quality control information, and (6) a summary table that lists all detected <br />constituents and corresponding groundwater quality standards. Groundwater quality standards <br />can be found at the following web site in this Water Quality Control Commission's <br />("WQCC's") Basic Standards for Ground Water, 5 CCR 1002-41, Regulation No. 41: <br />http://www.cdphe.state.co.us/regulations/wgccregs/100241 wgccbasicstandardsforgroundwater. <br />pddf. Following the initial eight groundwater monitoring events, the summary reports may be <br />submitted annually and shall also include results of statistical analyses of groundwater data <br />conducted pursuant to the requirements set :forth in Appendix B of the Solid Waste <br />Regulations. <br />18. Section 8.1- Financial Assurance: Section 8.1 of the DOP suggests that closure and post- <br />closure financial assurance requirements will be covered by the financial assurance mechanism <br />in place for the Division of Reclamation Mining and Safety ("DRMS") permit. For the <br />Division to consider such a proposal, the DIMS cost estimates must be included with the DOP. <br />Typically, DRMS financial assurance cost estimates do not include post-closure groundwater <br />monitoring and final cover maintenance and care. Therefore, a separate financial assurance <br />mechanism may be required for certain post closure requirements. <br />19. Section 8.3.1- Post-Closure Financial Assurance Period: The Division requires the <br />initially-approved post-closure care period to be no less than 30 years. Pursuant to the <br />provisions in Section 3.6.3 of the Solid Waste Regulations, the post-closure period can either <br />be increased or decreased by the Division after consultation with the local governing <br />jurisdiction. A request for such a modification to the post-closure period typically would be <br />made during the post-closure period, and would be based on operating history, groundwater <br />monitoring data, and other pertinent site-specific information. Pursuant to the requirements of <br />Section 1.8.1 of the Solid Waste Regulations, closure and post-closure cost estimates shall <br />reflect the cost of hiring a third party to perform the closure and post-closure activities. The <br />post-closure cost estimate must reflect 30 years of post-closure monitoring.