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STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832 -8106 <br />January 6, 1997 <br />Mr. Walter Avramenko <br />Colorado Dept. Public Health and Environment <br />Hazardous Materials and Waste Management Division <br />4300 Cherry Creek Drive South <br />Denver, Colorado 80222 -1530 <br />Mr. David Holm <br />Colorado Dept. Public Health and Environment <br />Water Quality Control Division <br />4300 Cherry Creek Drive South <br />Denver, Colorado 80222 -1530 <br />RE: Coal Basin Environmental Site Assessment <br />Dear Messrs. Avramenko and Holm: <br />P 7,W', <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br />Roy Romer <br />Governor <br />James S. Lochhead <br />Executive Director <br />Michael B. Long <br />Division Director <br />As you know, the Division of Minerals and Geology is in the <br />process of accomplishing reclamation of the Coal Basin Mine in <br />Pitkin County. Some of the reclamation to be accomplished during <br />the next two construction seasons will occur in the facilities <br />area. This area was the primary focus of the environmental audit <br />conducted by Harlan and Associates (Harlan) this past summer. The <br />Division of Minerals and Geology is interested in your comments <br />regarding the findings and recommendations contained in the final <br />report issued by Harlan and Associates on August 2, 1996. <br />Given your Divisions' expertise in the area of hazardous waste, we <br />request your assessment of the existing condition at Coal Basin <br />before proceeding with the required reclamation projects in the <br />facilities area. <br />Our specific questions are as follows: <br />In the August 2, 1996 memorandum, Harlan states that the soils <br />proposed for disposal at the Conservation Services, Inc. (CSI) <br />facility must be tested for RCRA characteristics to confirm that <br />the material is not hazardous. What additional constituents should <br />be sampled for the RCRA characterization, and, if any of the <br />sampled constituents are found to be elevated, how and where would <br />this material be disposed? <br />In the August 2, 1996 memorandum, Harlan states that the material <br />has not been fully characterized. What is your interpretation of <br />this comment? Is this a reference to the RCRA characterization <br />