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HomeMy WebLinkAbout20103483 STATE OF COLORADO Bill Ritter,Jr.,Governor Martha E.Rudolph,Executive Director oFCot\ $ Dedicated to protecting and improving the health and environment of the people of Colowdo Nei �'r X90 4300 Cherry Creek Dr.S. Laboratory Services Division eid County Planning Depart •; „ Denver,Colorado 80246-1530 8100 Lowry Blvd. GREELEY OFFICE r�87b s x Phone(303)692-2000 Denver,Colorado 80230-6928 TDD Line(303)691-7700 (303)692-3090 FEB 1 02010 Colorado Department Located in Glendale,Colorado of Public Health http://www.cdphe.state.co.us R EC E 9 VEud$nvironment February 3, 2010 1 Mr. Alan Scheere Mr. Bill Hedberg Conservation Services, Inc. North Weld Landfill 41800 East 88' A-venue — - - - -- -40;000 Weld County-Road-25` - -- _— Bennett,Bennett, CO 80102 Ault, CO 80610-9748 RE: Comments regarding North Weld Landfill (NWLF) 2009 Groundwater Monitoring Plan Update (document revised May 2009) Dear Mr. Scheere and Mr. Hedberg, The Hazardous Materials and Waste Management Division (Division)reviewed the NWLF 2009 Groundwater Monitoring Plan Update(document revised May 2009)that was attached to your letter dated June 8,2009. Based on the Division's review, we offer the following comments,for appropriate incorporation into a revised plan update: General Comment: 1) Provide documentation that the plan updates are reviewed and sealed by a Colorado licensed professional engineer or reviewed by a professional geologist, as appropriate. 2) Incorporate modifications so as to maintain consistency throughout the plan. 3) The modifications addressed in comments 8 and 12 below are based on a continued implementation of past land filling practices at NWLF in which land filling in a Phase begins atthe cell module located farthest from the permanent sump. The Division's intent is to facilitate attainment of up to date pertinent background groundwater monitoring parameters in the perched groundwater monitored by MW-9, which are not impacted by land filling operations. Additional modifications to the plan may be warranted if such is not the case. Specific Comments: 4) Page i—The letter that addresses the May 2009 plan revisions is actually dated June 8, 2009 (i.e., instead of June 5, 2009). 5) Page iv—Table 5-2 (Monitoring Sample Collection, Preservation, and Holding Times)was omitted from the List of Tables and from the plan. Include such information and modify the plan text, etc. accordingly. 6) Page vi—Appendix 8 (STL Denver Laboratory Quality Manual)was omitted from the List of Appendices and from the plan. Replace the STL Denver Laboratory Quality Manual with the Test America 2010 -- 3483 FLorrl Mr. Scheere and Mr. Hedberg - February 3,2010 Page 2 of 2 Laboratories (TAL) Laboratory Quality Manual in an appendix and modify the plan List of Appendices and text, etc. accordingly. 7) Page 19, 1'`par., l' sentence—The text indicates that upon receipt of the [groundwater] samples at the laboratory,the Chain-of-Custody form will be signed,etc. by the person taking the samples. Add that the person relinquishing the samples will also sign and date the Chain-of-Custody form. 8) Page 20,2"d par., 8th and 9'h sentences—The text indicates that semiannual monitoring of MW-9 will resume following the sampling period after filling encroaches on the PZ-1 survey coordinates and that MW-9 will not be sampled until waste disposal begins in areas that overlie the perched water zone. Modify the text to indicate that quarterly monitoring of MW-9 will commence when waste is initially placed in either Phase 3A or Phase 3B, whichever occurs first. Add that quarterly monitoring will be eonducted afMW-9 for a minimum of two years in order to establish background ground water quality data. 9) Page 20, last par., only sentence—Modify the text to indicate the appendix where the TAL Laboratory Quality Manual can be found in the plan. 10) Page 21, 5th par., 3`d sentence—Change the sentence to state, "Analytical methods listed in this Plan may be substituted provided that the alternate methods are approved for use by CDPHE in consultation with WCDPHE." 11) Page 21, 5th par.,,last sentence—Omit the sentence. 12) Table 1-1 —Change the footnote to state, "Monitoring suspended 2/97; quarterly monitoring will be resumed when land filling commences in either Phase 3A or Phase 3B,whichever occurs first." The Division looks forward to receiving a comprehensive revised version of the Groundwater Monitoring Plan Update. In closing the Division is authorized to bill for its review of technical submittals pursuant to Section 1.7 of the Regulations, 6 CCR 1007-2. An invoice for the Division's review of the above referenced documentation will be sent under separate cover. Please contact me at 303-692-3389 if you have any questions. Sincerely, $6 *.-S Douglas M. Ikenberry Solid Waste and Material Management Unit Solid and Hazardous Waste Program • Cc: Troy Swain, WCDPHE t�niogle-lkWer.?_4S1t FILE: SW WLD NWC 4.3 Hello