2012-09-06_REVISION - M2008070 (24)

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Design and Operations Plan Western Gravel E & P Waste Disposal Facility Waiver Request — Regulations Section 2.2 Groundwater Monitoring October 24, 2011 Page 1 of 1 A waiver from CDPHE solid waste Regulations Section 2.2 - Ground Water Monitoring is requested in accordance with Section 1.5 of the Regulations. Information requested under Section 1.5.1 (A -E) of the Regulations is provided in D &O Plan Section 1 and for Regulations Section F in D &O Plan Section 2. The hydrogeologic setting of the facility is considered excellent with shallowest groundwater estimated at approximately 45 feet below facility grade in White River alluvium (See Section 2.3.3.7). The cell liner engineering design is considered very robust, consisting of not only a double synthetic HDPE liner but leak detection and leachate collection systems (See Sections 3.4.4, 3.4.5, and 3.4.6). In addition, wet/dry well monitoring will be conducted down dip from the facility based upon geologic structure (i.e., bedrock bedding). In accordance with Regulation Section 1.5.2, the following information is provided. The robust engineering design and wet/dry well monitoring is considered more protective of human health and the environment than monitoring water quality in the White River alluvium where any potential facility leakage would likely be masked. Therefore, WG proposes that benefits derived from meeting the standard do not bear a reasonable relationship to economic, environmental, or other factors particular to the facility. In addition, the requested waiver is consistent with purposes of the Act and Regulations, is not deemed to constitute a major variation from regulation requirements, and will not cause or allow violation of any air or water quality standard or federal or local restriction. In accordance with Appendix B of the Regulations, the waiver will be re- proposed every 5 years. NWCC, Inc.