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February 22, 2013 <br />Mr. Eric B. Fenster, Esquire <br />Completeness Review Determination: Complete — Application for Certificate of Designation, Henderson Inert Landfill, <br />Adams County, Colorado <br />Page 4 <br />7. Section 6.5 (Record- Keeping) of the Plan (Tarry 2012) does not state that all records must be <br />maintained throughout the life of the facility, including the duration of the post - closure care period, <br />as required in Section 3.4 of the Solid Waste Regulations. Please revise Section 6.5 of the Plan <br />(Tarry 2012) to discuss the length of time that the records must be maintained. <br />8. Section 8 (Final Grades and Cover Materials) of the Plan (Tarry 2012) states that the proposed <br />final cover will consist of 18 inches of clean soil, overlain by 6 inches of topsoil capable of <br />sustaining vegetation, which would be the erosion layer. Please provide specifications for each <br />final cover layer <br />9. Section 8 of the Plan (Tarry 2012) also states that the Henderson Inert Landfill will institute a <br />Construction Quality Assurance /Quality Control Plan (CQA/QCP) for the assurance of final grade <br />construction and completion for the Henderson Inert Landfill for the soil cover following the <br />guidelines in the Division's guidance for preparing Quality Assurance /Quality Control Plans. <br />Prior to construction, the CQA/QCP must be prepared and submitted for review and approval by <br />the Division. In addition, the Division recently has prepared guidance for water balance covers <br />(also known as alternative final covers) in Colorado. This water balance cover guidance is not yet <br />available on the Division's web site, but can be provided electronically upon written request. <br />10. Section 9.1 (Ground Water Monitoring) of the Plan (Tarry 2012) includes the following statement: <br />"Current ground water conditions will be defined by the data from four separated sampling events <br />using the two existing up- gradient wells and two new proposed down - gradient wells. These <br />samples will form the initial background pool for statistical evaluation." Since inert material <br />backfilling of the Henderson Inert Landfill has been ongoing, one or more of the proposed down - <br />gradient wells may not be reflective of "background" conditions. Consequently, the down - gradient <br />data will be considered "current ground water quality" rather than "background" ground water <br />quality. In addition, Standard Operating Procedures for Well Installation and Ground Water <br />Sampling Activities can be found at this web site: <br />http: / /www. colorado. gov /cs /Satellite /CDPHE -HM/CB ON/ 125163 4796246 <br />11. Section 10.1 (Ground Water Monitoring) of the Plan (Tarry 2012) indicates that the Henderson <br />Inert Landfill proposes to initiate installation of the proposed new ground water monitoring wells <br />following issuance of the CD. Before the Division can evaluate the adequacy of the proposed <br />monitoring well network, the Division requires the Henderson Inert Landfill to provide <br />(1) a landfilling sequence plan (i.e., Where will landfilling re- commence? How will landfilling <br />progress ?), and (2) a schedule for any proposed changes to, or discontinuation of, on -going <br />de- watering activities. <br />12. For Section 10.6 (Reporting) of the Plan (Tarry 2012), ground water quality standards from the <br />Water Quality Control Commission's Basic Standards for Ground Water, 5 CCR 1002 -41, <br />Regulation Number 41, can be found at the following web site: <br />http: / /www.colorado.gov /cs /Satellite /CDPHE- Main/CBON/1251595703337 <br />