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April 8, 2011 <br />Mr. Thomas Mountfort <br />Conditional Approval for One -Time Acceptance at Foothills Landfill <br />Water Treatment Plant Residuals from Denver Water's Ralston Residuals Management Facility <br />Page 2 <br />uranium activity, which is similar to levels of water treatment residuals approved for disposal at Foothills Landfill <br />in previous years, and is below the source material constrain of 350 pCi/g. Therefore, there is not a regulatory . <br />barrier with respect to the definition of source material to the disposal of this batch of material. <br />The Department approves the proposed disposal of approximately 1500 cubic yards of the Ralston Drying Bed #2 <br />water treatment plant residuals at Foothills Landfill with the following condition: Prior to receipt of these <br />materials at Foothills Landfill, Republic Services must submit a letter to the Department for its review and <br />approval confirming adherence to and implementation of enhanced facility controls in accordance with Chapter <br />4.4.1 of the Policy. In addition, the local goveming authority (in this case Jefferson County) may conduct an <br />independent evaluation and render its own determination regarding the receipt of this material. The Department's <br />one -time conditional approval does not automatically extend to disposal of future residuals. Transportation shall <br />comply with appropriate DOT regulations. <br />The Department's preference is that ongoing disposal of this waste not be handled on a case -by -case basis going <br />forward. If you desire to continue using Foothills Landfill in the future, the facility must undergo a modification <br />to its approved engineering design and operations plan. This would require significantly longer lead time in terms <br />of obtaining approval, and we are bringing it to Denver Water's attention at this point to give Denver Water <br />adequate time for long -term planning. The Department's position with respect to continued case -by -case approval <br />is the same if Denver Water chooses another solid waste facility where their design and operations plan is not <br />approved for this waste stream. <br />In closing, The Division is authorized to bill for its review of technical submittals at $125 per hour, pursuant to <br />Section 1.7 of the Solid Waste Regulations. An invoice for the Division's review of Denver Water's request will <br />be sent under separate cover. <br />If you have any additional questions, please contact either of us or James Grice of the Radiation Management <br />Unit at (303) 692 -3371, james.arice@state.co.us, or Curt Stovall of the olid Waste and Materials Management <br />Program at (303) 692 -2295, curtis.stovall @state.co.us. <br />7 <br />Jennifer • t ila, Unit Leader <br />Radiation Management Unit <br />Radiation Management Program <br />(303) 692-3403 <br />ec: Megan Brown, CDPHE <br />Darrell Dearborn, CDPHE <br />James Grice, CDPHE <br />Curt Stovall, CDPHE <br />File: SW /JFR/RAL 1.1 and 2.5 <br />cc: Patrick O'Connell, Jefferson County Planning Department <br />Roy Laws, P.E., Jefferson County Public Health <br />Elizabeth Stengl, Republic Services <br />Roger Doak, Unit Leader <br />Solid Waste Permitting Unit <br />Solid Waste and Materials Management Program <br />(303) 692 -3437 <br />