2013-05-30_REVISION - M2001085 - Laserfiche WebLink

Home Browse Search

May 21, 2013 Mr. Eric Fenster, Esquire Technical Review Comments: Application for Certificate of Designation, Proposed Henderson Inert Landfill, Adams County, Colorado Page 4 needed to provide that fortification. If this indeed is the case, please revise this section as appropriate to state same. 2. The Division understands that a portion of the 100,000 cubic yards of material already has been placed. Since it can be more difficult to determine whether or not soil has been contaminated, please provide documentation of that the existing fill contains soil that is not contaminated. This documentation could include any, some, or all of the following: (1) Test results of samples collected (before, during, or after placemen) from the placed soil, with the test results indicating that the soil is uncontaminated; (2) Written documentation, from the generator(s), that the soil is uncontaminated; and (3) Written determination, from DRMS, that the soil is uncontaminated. Attachment 8 contains proposed affidavits addressing previously placed fill and future fill. By themselves, the proposed affidavits are not sufficient to address this Division comment. The proposed affidavits, in conjunction with the documentation requested above, might be sufficient to address this Division comment. 3. Sections 6.6 through 7.3 (Landfill Material Acceptance and Placement through Screening for Suspected Contaminants) of the Revised Plan (Tarry 2013) contain the basics of the Waste Characterization and Disposal Plan required by Section 2.1.2 (C) of the Solid Waste Regulations. Pursuant to Section 2.1.2 M of the Solid Waste Regulations, please revise the discussion of prohibited materials (Section 6.6.2 of the Revised Plan [Tarry 2013]) to address the prevention of the disposal of polychlorinated biphenyl (PCB) wastes. Pursuant to CRS 25 -15 -101 (6), friable asbestos is a hazardous waste. Since some inert material might contain asbestos, asbestos - containing material, asbestos - contaminated soil, or asbestos waste as defined in Section 1.2 of the Solid Waste Regulations, please revise the discussion of prohibited materials (Section 6.6.2 of the Revised Plan [Tarry 2013]) to address material that is or is suspected of being asbestos, asbestos - containing material, asbestos - contaminated soil, and asbestos waste. 4. Section 10.1 (Ground Water Monitoring) of the Revised Plan (Tarry 2013) indicates that the Henderson Inert Landfill proposes to initiate installation of the proposed new ground water monitoring wells following issuance of the CD. Prior to resumption of inert landfilling the Division will require (1) the approved ground water monitoring well network to be in- place, (2) the initial ground water sampling to be completed, and (3) approval of the facility's ground water monitoring plan. Section 10.1 (Ground Water Monitoring) of the Revised Plan (Tarry 2013) indicates that the ASCI Resource Manager (or his designee), who is properly trained in ground water sampling techniques, can conduct sampling of the ground water monitoring wells. Is ASCI a reference to Asphalt Specialties Company, Inc.? If so, is this correct or a typographical error? If correct, please clarify the relationship between the Henderson Inert Landfill and Asphalt Specialties Company, Inc. If a typographical error, please revise this section to provide the correct information. 6. Section 12.1 (Period) of the Revised Plan (Tarry 2013) states that the post - closure care period will be five (5) years for nuisance control and for maintenance and repair of the final cover and the erosion control system, and the post - closure care period for maintenance of the ground water