HomeMy WebLinkAbout941337.tiff c,,,SKATE OF COLORADO
COLORADO DEPARTMENT OF HEALTH
Dedicated to protecting and improving the fr231th anti
environment of the people of Co/orado 0 Al 10: 01 �
4300 Cherry Creek Dr.S. Laboratory Building CLER'r r r876
Denver,Colorado 80222-1530 4210 E.11th Avenue4,, CLERK
Phone(303)692-2000 Denver,Colorado 8(J2 1-17-18 r n F t- RoyRanier(303)691-4700 Governor
June 24, 1994 Certified # P 860 417 928 Patricia A.Nolan,MD,MPH
Executive Director
Mike Cervi
Northern Colorado Brine
P.O. Box 300397
Denver, Colorado 80203
RE: Liner Testing - Pond 1
Northern Colorado Brine
Weld County
Dear Mr. Cervi:
The Hazardous Materials and Waste Management Division of the Colorado Department
of Health (the Division) has reviewed Mr. LaVern Nelson's letter of May 16, 1994. Mr.
Nelson's letter is in responds to the Division's letter of February 24, 1994 regarding pond
1 liner tests at Northern Colorado Brine.
The Division has the following comments regarding Mr. Nelson's letter of May 16, 1994:
1. As Mr. Nelson pointed out in his letter, it was not necessary or required by the
state's solid waste regulations 6 CCR 1007-2 (the Regulations) to add bentonite to
the soil liner of pond 1. However, it only seems prudent that the bentonite/soil
mixture and application would be in accordance with the appropriate USEPA
Technical Manual to achieve the maximum benefit from this process.
2. The letter indicates section 9.4.1 of the Regulations does not apply, "Because this
project was one of enhancement as opposed to new construction..." Section 9.8.8 of
the Regulations states "Clay or other soil liner material which has been continuously
exposed to impounded wastes shall be sampled and tested for permeability as
specified in Section 9.4.1 at intervals of not more than five (5) years." Please provide
a plan which addresses how pond 1 and other pond liners which are tested at this
facility will comply with the requirements of section 9.8.8.
3. In regards to the failed compaction test #11, Mr. Nelson indicates it was not
necessary to complete a retest because adequate compaction was achieved in his
opinion. The facility's Design and Operations Plan (D&O Plan) specifies at least 95
percent compaction will be achieved for the soil liner. Because the failed area was
never retested, there is no documentation which demonstrates 95 percent compaction
was achieved. It has been and will remain the position of the this Division that
assumed values are not acceptable documentation for Quality Assurance/Quality
niTh Control (QA/QC) specifications. It is common industry practice to rework
����-� 1 �° 941337
0r7/ 1I )14 pi(<)
Mr. Cervi
Northern Colorado Brine
June 24, 1994
Page 2
areas that fail compaction test and retest those areas to document adequacy with the
QA/QC specifications. During future liner tests, all failed compaction tests shall be
retested.
4. In accordance with the D&O Plan, liner testing/repair documentation shall be
submitted and approved by this Division and the appropriate Weld County officials
prior to filling the pond. The Division's records show liner tests have been
completed for three ponds at this facility. After completion of the tests, the ponds
were filled without the approval of the Division or Weld County. The Division has
notified you (Division's letter of February 24, 1994) filling of ponds without the
appropriate agency approvals may result in those ponds being emptied and additional
testing preformed.
Based on the comments contained in items 2, 3 and 4 of this letter, the Division is
requesting that liquids in pond 1 be removed and the liner tested in accordance with the
Regulations and the facility's D&O Plan. Please respond, in writing, within 10 days of the
receipt of this letter. Your responds should include at a minimum; a schedule for removing
liquids from pond 1 and a detailed plan for testing the liner.
If you have any question, please contact me at 303-692-3437.
Sincerely,
Roger Doak
Geologist
Solid Waste Section
Hazardous Materials and Waste Management Division
cc: Weld County Commissioners
Weld County Planning Department
T. Jiricek, Weld County Health Department
L. Nelson, Nelson Engineering
T. Monahan, Attorney General
file: SW/WLD/NOR #4
Hello