HomeMy WebLinkAbout20192029.tiffChloe Rempel
From:
Sent:
To:
Cc:
Subject:
Attachments:
Kim Ogle
Tuesday, June 25, 2019 12:17 PM
Selena Baltierra; Jessica Reid; Chloe Rempel; Isabella Juanicorena; Bethany Ford
Esther Gesick
20190621 Inspection Letter Pawnee Landfill.pdf
20190621 Inspection Letter Pawnee Landfill.pdf
Please add document to file, USR15-0048, Pawnee Waste LLC
Thank you.
Kim Ogle
Planner III
Weld County Planning Services
1555 North 17th Avenue
Greeley, Colorado 80634
970.353.6100 x 3540 Office
970.400.3549 Direct
kogle()weldgov.corn
Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for the person or entity to
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WELD COUNTY DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
1555 North 17th Avenue, Greeley, CO 80631 www.weldhealth.org
June 25, 2019
Mr. Jerry Hamel
General Manager
Pawnee Waste LLC
47368 County Road 118
Grover, CO 80729
Subject: Pawnee Landfill — 2019 First Semiannual Inspection
Dear Mr. Hamel:
On June 21, 2019, the Weld County Department of Public Health and Environment conducted a routine
inspection of the Pawnee Landfill, located at 47368 Weld County Road 118 east of Grover in Weld County,
Colorado. The purpose of the inspection was to assess the facility's compliance with conditions of the
Certificate of Designation (CD), including the Development Standards of Use by Special Review Permit
(USR15-0048), the Regulations Pertaining to Solid Waste Sites and Facilities (6 CCR 1007-2) (the
Regulations), C.R.S. 30-20-101 et seq. and other applicable statutes and provisions of the Weld County Code.
In accordance with Development Standards 9 and 16 of USR15-0048, "The facility shall operate in
accordance with the approved Engineering Design and Operations Plan (EDOP)," and "The facility shall
be operated in a manner which protects against surface and groundwater contamination." Based on the
2018 Annual Groundwater Monitoring Report, dated March 27, 2019, two potential exceedances were
identified; 27 mg/L sulfate in MW -2A and 4.3 mg/L total organic carbon (TOC) in MW -3. According to
the report, "Confirmatory re -sampling for the potential exceedances will be conducted during the first
semi-annual 2019 groundwater sampling event." If the analytical results of the first semi-annual 2019
groundwater sampling event, conducted during the second quarter of 2019 for MW -2A and MW -3,
confirm verified exceedances, further steps, as outlined in the facility's approved EDOP, will need to be
taken to maintain compliance.
Other than the issues outlined above, at the time of the inspection the facility was in compliance with USR15-
0048 and their CD. If you have any questions regarding this inspection, please contact me at 970-400-2227.
Sincerely,
(Abut
Lauren Kemper
Environmental Health Specialist
Weld County Department of Public Health and Environment
Environmental Health Services
ec: Doug Ikenberry, CDPHE
Andy Todd, CDPHE
Tom Parko, Weld County Planning Department
Ben Frissell, WCDPHE
Health Administration
Vital Records
Tele: 970-304-6410
Fax: 970-304-6412
Public Health 8
Clinical Services
Tele: 970-304-6420
Fax: 970-304-6416
Environmental Health
Services
Tele: 970-304-6415
Fax: 970-304-6411
Communication,
Education 8 Planning
Tele: 970-304-6470
Fax: 970-304-6452
Emergency Preparedness
I. Response
Tele: 970-304-6470
Fax: 970-304-6452
Public Health
Bethany Ford
From:
Sent:
To:
Cc:
Subject:
Attachments:
Kim Ogle
Tuesday, May 28, 2019 6:57 AM
Bethany Ford; Selena Baltierra; Jessica Reid; Chloe Rempel
Esther Gesict
Pawnee Waste Additions to File
K2-Attach-1_NRC-Tech-Evalaution-Report-Landfill-Disposal_Mar2016.pdf; Re: Pawnee
Waste E&P Tracers; 20162987.pdf; 20162988.pdf; K2 -Attach- 1_N RC-Tech-Evalaution-
Report-Landfill-Disposal_Mar2016.pdf
Hello
Please add to case file for Pawnee, USR15-0048. Previous email requested Bethany to
please process as a Communications — Addition to File PL2442.
Thanks to all of you
Kim Ogle
Planner Ill
Weld County Planning Services
1555 North 17th Avenue
Greeley, Colorado 80634
970.353.6100 x 3540 Office
970.400.3549 Direct
kogle@weldgov.com
Confidentiality Notice: This electronic transmission and anyattached documents or other writings are intended only for the person or entity to
which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this
communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or
the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly
prohibited.
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2019-2029
}?L21 -p-{2
March 8, 2016
MEMORANDUM TO:
FROM:
SUBJECT:
Mark R. Shaffer, Director
Division of Nuclear Materials Safety
Region IV
John R. Tappert, Director /RA/
Division of Decommissioning, Uranium Recovery,
and Waste Programs
Office of Nuclear Material Safety
and Safeguards
RESPONSE TO TECHNICAL ASSISTANCE REQUEST, DATED
AUGUST 5, 2015, FOR THE REVIEW OF THE PROTECHNICS
DIVISION OF CORE LABORATORIES' REQUEST FOR
APPROVAL OF AN ALTERNATE WASTE DISPOSAL METHOD
UNDER 10 CFR 20.2002
Region IV submitted a Technical Assistance Request (Agencywide Documents Access and
Management System (ADAMS) Accession Number ML15218A608), dated August 5, 2015,
requesting a review of the ProTechnics Division of Core Laboratories' (ProTechnics) request for
an alternate waste disposal method under 10 CFR 20.2002. The U.S. Nuclear Regulatory
Commission (NRC) has previously approved ProTechnics use of two alternate waste disposal
methods: 1.) on -site earthen pit burial; and 2.) Class II wells for disposing of well returns
containing small concentrations of radioactive tracer material. ProTechnics is now requesting
NRC approval for a third option, disposal of the well returns at the Meadowfill Landfill in
Bridgeport, West Virginia.
The NRC staff evaluated ProTechnics' request for a third alternate waste disposal method that
considers the placement of well returns containing small concentrations of radioactive materials
at the Meadowfill landfill. Based on a review of the analyses provided by ProTechnics
(ML15211A594), the responses to the request for additional information (ML15292A061), and
the independent analyses discussed in the accompanying Technical Evaluation Report (TER),
the NRC staff find this disposal option to be acceptable and in compliance with the regulations
in 10 CFR 20.2002. The expected doses are a very small fraction of the public dose limit and
lower than calculated doses for other alternates already approved for the licensee. The
expected dose is less than 0.01 mSv/yr (1 mrem/yr) to the average member of the critical group
and doses are maintained as low as reasonably achievable.
Region IV will use the information provided in this TER to issue a license amendment to
ProTechnics and an exemption letter to Waste Management, owners of the Meadowfill Landfill,
CONTACT: Adam L. Schwartzman, NMSS/DUWP
(301) 415-8172
M. Shaffer - 2 -
granting them permission to dispose of the well returns without an NRC license. The NMSS
staff agreed to include an example exemption letter (ML15086A427), Enclosure 2, with this
response.
Enclosures: 1. Technical Evaluation Report
2. Example Exemption Letter
M. Shaffer - 2 -
granting them permission to dispose of the well returns without an NRC license. The NMSS
staff agreed to include an example exemption letter (ML15086A427), Enclosure 2, with this
response.
Enclosures: 1. Technical Evaluation Report
2. Example Exemption Letter
DISTRIBUTION:
D. Collins, MSTR
H. Gonzalez, MSTR
41A076 (Pkg.) ML16020A283 (Memo &TER) ML15086A427 (Ex.) *concurred via email
OFFICE
NMSS
NMSS:LA
NMSS:BC
NMSS:D
OGC
NMSS
NAME
A. Schwartzman
T. Moon
C. McKenney
(M. Norato for)
J. Tappert
S. Clark*
A. Schwartzman
DATE
1/21/16
2/1/16
1/28/16
2/2/16
2/25/16
3/8/16
OFFICIAL RECORD COPY
TECHNICAL EVALUATION REPORT
RESPONSE TO TECHNICAL ASSISTANCE REQUEST REGARDING THE PROTECHNICS
DIVISION OF CORE LABORATORIES' REQUEST FOR APPROVAL OF AN ALTERNATE
WASTE DISPOSAL METHOD UNDER 10 CFR 20.2002
DOCKET: 030-30429
LICENSEE: Core Laboratories, Inc. dba ProTechnics Division of Core Labs
LICENSE NUMBER: 42-26928-01
BACKGROUND
The ProTechnics Division of Core Laboratories (ProTechnics) is a well -logging licensee
(Materials License # 42-26928-01) authorized to use unsealed byproduct material during tracer
operations. ProTechnics is currently authorized under conditions of its license to use two
alternate waste disposal methods previously approved by the U.S. Nuclear Regulatory
Commission (NRC) under 10 CFR 20.2002. On -site earthen pit burial was approved on
December 18, 1995 (Agencywide Documents Access and Management System (ADAMS)
Accession Number ML12243A217). Disposal into Class II wells was approved as a result of the
issuance of license amendment 30 on November 4, 2003 (ML033080194).
SUMMARY OF PREVIOUS EVALUATIONS
The NRC and several Agreement States have already evaluated the impacts associated with
the disposal of these well returns containing radioactive materials and have included license
conditions authorizing the on -site burial of the material in both shallow pits and Class II disposal
wells. In December 1995, the NRC staff concluded a "Finding of No Significant Impact
(FONSI)" for the generic disposal of this material in on -site burial pits provided specific
restrictions are met. A licensing amendment was added to ProTechnics' license for this generic
disposal option. Prior to this point, the NRC staff reviewed and approved these disposals on a
case -by -case basis.
In November 2003, the NRC amended ProTechnics' license to allow the disposal of radioactive
material associated with well returns in Class II disposal wells that had been previously
approved to accept non -hazardous oil and gas waste by State agencies. As discussed in the
NRC's response to "Core Laboratories' Request to Inject Well -Logging Waste in Class II
Disposal Wells" (ML041200730), acceptance of this second disposal option by the NRC staff
was based on a combination of NRC policies and stringent construction, operating, and
monitoring requirements for Class II disposal wells. Use of the Class II disposal wells allows for
greater control over the waste once it is disposed and limits possible access to the material
compared to the previously accepted disposal process of using disposal pits with a soil cover.
Additional details related to the use of Class II disposal wells are provided in NUREG/CR-3467,
"Environmental Assessment of the Use of Radionuclides as Tracers in the Enhanced Recovery
of Oil and Gas."
ENCLOSURE 1
2 -
PROPOSED ACTION
By letter dated June 19, 2015 (ML15211A594), ProTechnics requested approval for a third
alternate disposal method, allowing for the disposal of well returns containing small
concentrations of radioactive tracer material (less than 120 -day half-life) at the Meadowfill
Landfill in Bridgeport, West Virginia. Contingent on NRC approval and acceptance by the West
Virginia Department of Environmental Protection and the West Virginia Department of Health
and Human Resources, Waste Management, Inc., the owner and operator of the Meadowfill
Landfill, has already agreed to accept the material in cases when on -site earthen pit burial and
injection into Class II disposal wells are determined not to be viable options. The need for a
third disposal option is due to the fact that some locations where tracer operations are
conducted do not allow shallow disposal pits to be used to hold well returns and costs
associated with the construction and maintenance of Class II disposal wells, as well as the
transport of the well returns to the well sites can be high. As indicated above and emphasized
in the submittal, the NRC staff has already acknowledged the low risks associated with the
tracer materials through its review and acceptance of on -site burial in shallow burial pits. The
NRC staff agrees that disposal in a landfill, which would occur at greater depths and include a
deeper cover, would provide additional shielding as well as greater assurances that the tracers
would not be prematurely uncovered or handled. As discussed in the submittal, risk and
exposure during the transport of tracer material to the Class II disposal wells, which has already .
been authorized by the NRC, is minimal. Transporting the tracer material to the Meadowfill
Landfill, which is closer in proximity, would further minimize risk and exposure to the public.
NRC STAFF'S REVIEW AND EVALUATION
As part of its tracer operations, ProTechnics injects three radionuclides (Iridium [Ir]-192,
Scandium [Sc]-46, and Antimony [Sb]-124) into the wells during hydraulic fracturing activities.
The small increase in radioactivity above background assists well operators in optimizing well
operations. According to the submittal, no more than 37 Bq/g (1000 pCi/g) of radioactive
material is injected into a well at any one time. The submittal does not clearly indicate if this
37 Bq/g (1000 pCi/g) concentration is for a single radionuclide or for a combination of all three
radionuclides. As part of its independent analysis the NRC staff considered a combination of all
three radionuclides with input concentrations of 37 Bq/g (1000 pCi/g) for each, three times the
highest concentration of radioactive material that would be associated with the well returns
assuming all of the radionuclides were removed from the well.
The manufacturing process for the radioactive tracer, known as ZeroWash®, embeds the non -
water soluble radioactive tracer material inside the matrix of a ceramic particle. As a result,
there is minimal to no deleterious effects on the environment from the use of ZeroWash®.
According to ProTechnics, internal and external exposure to ZeroWash® will be negligible to the
public because the material cannot be absorbed through the skin, will not be inhaled, and
ingestion of hundreds of pounds of material would be needed in order to reach an Annual Limit
of Intake (ALI). The analysis provided with the submittal consisted of a series of mathematical
calculations that considered an individual standing directly over a 7.3 m2 (78.54 ft2) shallow pit
containing well return waste to a depth of 0.88 m (2.29 ft) with a 0.61 m (2 ft) cover consisting of
clean soil on top. The dose, assuming that an individual stood on top of the disposal pit for 24
hours a day for 365 days, was calculated to be 0.056 mSv/yr (5.56 mrem/yr). A similar analysis
performed by the NRC staff using RESRAD, Version 6.5, and the same assumptions resulted in
-3-
a dose of 0.011 mSv/yr (1.1 mrem/yr). Ultimately the use of realistic parameter values
associated with disposal in a landfill, including disposal over larger areas, at greater depths, and
with a larger cover, would yield doses that are even less significant.
Considering the characteristics of the ZeroWash® and the short half-lives of the associated
radionuclides, the NRC staff performed a second analysis to evaluate the impacts to the dose
associated with the disposal of the well returns in a landfill. In this scenario, the waste is
assumed to be spread over a larger area and a deeper cover would be installed. The NRC staff
assumed that the same volume of well return material considered in the submittal, 6.4 m3
(227ft3), was distributed over a larger area within the landfill (10 m2 or 33 ft2) to a depth of
0.64 m (2.1 ft) and covered with a 2 meter (6.6 feet) deep cover. The same exposure pathways
were considered for the landfill worker. This scenario resulted in a peak dose of 6E-10 mSv/yr
(6E-8 mrem/yr). Table 1 compares the RESRAD input parameter values and resulting doses for
the two scenarios evaluated by the NRC staff.
Table 1. Comparison of RESRAD parameter values and resulting doses calculated by the
NRC staff using RESRAD, Version 6.5a
Burial Pit Analysis
External Gamma
Ingestion
Inhalation
Parameter
Exposure Pathways
Radionuclides
Ir-192
Sc-46
Sb-124
Contaminant area (m2)
Contaminant depth (m)
Length parallel to aquifer flow (m)
Cover depth (m)
1000 pCi/g
1000 pCi/g
1000 pCi/g
7.3 m2
0.9 m
2.7 m
0.61 m
Dose') 1.1E-02 mSv/yr
Landfill Analysis
External Gamma
Ingestion
Inhalation
1000 pCi/g
1000 pCi/g
1000 pCi/g
10 m2
0.64 m
3.64 m
2m
6E-10 mSv/yr
a Default values were used for the remaining RESRAD parameters
b Multiply mSv/yr by 100 to get mrem/yr
FINDINGS
The NRC staff evaluated ProTechnics' request for a third alternate waste disposal method that
considers the placement of well returns containing small concentrations of radioactive materials
at the Meadowfill Landfill, Based on a review of the analyses provided by ProTechnics and the
independent analyses discussed above, the NRC staff finds this disposal option to be
acceptable and in compliance with the regulations in 10 CFR 20.2002. The expected doses are
a very small fraction of the public dose limit and lower than calculated doses for other alternates
already approved for the licensee. The expected dose is less than 0.01 mSv/yr (1 mrem/yr) to
-4 -
the average member of the critical group and the proposed disposal method would keep doses
as low as reasonably achievable.
Bethany Ford
From:
Sent:
To:
Cc:
Subject:
Follow Up Flag:
Flag Status:
Todd - CDPHE, Andrew <andrew.todd@state.co.us>
Thursday, April 11, 2019 12:01 PM
Jerry Hamel
Grice - CDPHE, James; Ben Frissell; Jerry Henderson - CDPHE; Derek Bailey - CDPHE;
Ramon Li - CDPHE; Phillip Peterson; Chris Dietzler; koskokd@aol.com; Hunter Hoshiko;
Jane Witheridge; Tamara Such
Re: Pawnee Waste E&P Tracers
Follow up
Flagged
Caution: This email originated from outside of Weld County Government. Do not click links or open attachments unless you recognize the
sender and know the content is safe.
Thanks for the update Jerry. Please let us know how that progresses so that CDPHE Radiation Control Program (Jim
Grice's group) and Solid Waste permitting (Jerry Henderson's and my group) can best anticipate our re -involvement.
Best regards,
Andy Todd
On Thu, Apr 11, 2019 at 10:31 AM Jerry Hamel <jhamel@pawneewaste.com> wrote:
Good Morning Andy,
Pawnee Waste has a meeting setup with Kim Ogle with Weld county Thursday April 18th, 2019 at 1:30 pm. The
following is the subject of the meeting:
Project Description: Amendment to Accept additional waste streams
First Amendment to USR15-0048
Following the technical review from Mr. Grice and utilizing the expertise of Kevin Kosko from Protechnics, Pawnee
Waste will be presenting the application for the Amendment to USR15-0048. Pawnee Waste will take further steps to
formalize the amendments to the USR based upon this meeting.
We thank you and everyone involved in working on this amendment!
Regards,
1
PAWNEE
Jerry Hamel, Jr.
General Manager
47368 County Rd 118
Grover, CO 80729
(c) 970-889-0006
WASTt,
http://www.pawneewaste.com/
From: Todd - CDPHE, Andrew <andrew.todd@state.co.us>
Sent: Wednesday, April 10, 2019 1:41 PM
To: Grice - CDPHE, James <james.grice@state.co.us>
Cc: Jerry Hamel <ihamel@pawneewaste.com>; Ben Frissell <bfrissell-durlev@weldgov.com>; Jerry Henderson - CDPHE
<jerrv.henderson@state.co.us>; Derek Bailey - CDPHE <derek.bailey@state.co.us>; Ramon Li - CDPHE
<ramon.li@state.co.us>; Phillip Peterson <phillip.peterson@state.co.us>
Subject: Re: Pawnee Waste E&P Tracers
Hello Jerry Hamel,
to add to what Jim Grice has written, specifically:
"As a result the next steps as I understand it are for you to obtain or verify designation to receive these materials at
your facility.
The process for designation is outside of the scope of our program and I would have to refer you to our Solid Waste
permitting staff for more details on that."
The CDPHE Solid Waste permitting unit is waiting on news that you've reacted to Kim Ogle's 2/28/2019 e-mail inviting
you to schedule a pre -application meeting that may ultimately lead to amendment of Pawnee's CD and USR. That is
2
between Pawnee and Weld County. CDPHE (Solid Waste permitting) will also require some amendment to the EDOP,
but it is assumed that Pawnee wouldn't spend time and $ on an EDOP amendment before clearing the CD/USR hurdle
with Weld County. It sounds like Jim Grice is also saying get to, if not through, that CD/USR hurdle and we'll get through
the following step(s) with Pawnee. That's what Solid Waste permitting is waiting on also.
Are we all on the same page?
Best Regards,
Andy Todd
On Wed, Apr 10, 2019 at 12:40 PM Grice - CDPHE, James <james.grice@state.co.us>wrote:
Jerry,
As we discussed on the phone the radioactive materials unit does not make recommendations on these matters but
we do grant exemptions from radioactive materials licensing and authorizations to perform these activities.
As you correctly included in your e-mail, these questions are a result of a request for alternate disposal in Colorado
under section 4.34.
The process of approving such a request includes, primarily, a technical review of a radiological dose assessment for
the potential radiation dose to a landfill worker as well as members of the public as a result of the proposed activities.
The radioactive materials unit has conducted that review and has determined that the activities specifically as
proposed by Protechnics would not exceed a 25 mrem per year dose to any potential receptor. Additionally, as you
provided in your attachment, the Nuclear Regulatory Commission has reviewed and approved an analogous request
by Protechnics within their jurisdiction.
You have also correctly pointed out that once we have reviewed the dose assessment and deem the activity to be
appropriate and to meet public dose standards the licensee would have to identify a specific landfill and the landfill
would have to obtain designation to receive these materials in order for us to grant an exemption from the
requirements for a radioactive materials license to the solid waste landfill to accept these materials.
3
Protechnics has identified your facility as the facility in which they would like to use for disposal of these materials. As
a result the next steps as I understand it are for you to obtain or verify designation to receive these materials at your
facility.
The process for designation is outside of the scope of our program and I would have to refer you to our Solid Waste
permitting staff for more details on that.
What I can verify for you is that the radioactive materials unit is, at this time, prepared to both grant the request from
Protechnics for authorization of alternate disposal and an exemption from the requirements for a radioactive
materials license to your facility to accept these specific materials from Protechnics once the proper designation which
satisfies Colorado Revised Statutes C.R.S. 30-20-110 (1) (c) is in place. This would be a very specific authorization for
Protechnics to dispose of only the materials in the volumes and concentrations as requested at only your facility and a
very specific exemption for your facility to accept only the materials in the volumes and concentrations as
requested by Protechnics and only those materials from Protechnics.
I hope that helps clarify the process.
Sincerely,
Jim Grice
Radiation Program Manager
Hazardous Materials and Waste Management Division
P 303.692.3371 I F 303.691.7841
4300 Cherry Creek Drive South, Denver, CO 80246-1530
James.Grice@state.co.us I www. colorado. govt pacific/cdphef categories/services-and-
information/environment! radiation- management
4
On Fri, Mar 1, 2019 at 12:19 PM Jerry Hamel <jhamel@pawneewaste.com> wrote:
Hello Jim,
This note is to request your recommendation for an exemption regarding Pawnee's acceptance of a non-RCRA
exempt exploration and production waste stream, specifically radioactive tracer wastes. It is well known that tracers
used in exploration and production have low levels of radioactivity which are neither NORM or TENORM. Pawnee's
Profile Sheet for Non-RCRA exempt E&P waste, however, requires RCRA testing as appropriate, and for radioactivity,
analysis of Ra 226+228 radioisotopes only.
Pawnee is considering the receipt of in -state E&P non-RCRA exempt tracer wastes, and proposes testing for their
radioisotopes prior to receipt. Specifically, we propose the following radioisotopes would be analyzed: Ir-192, Sc-46,
and Sb-124, or in the case that other radioisotopes are used in the product, to test for those. Based on the attached
risk assessment for concentrations up to 1,000 pCi/g for each of these isotopes (i.e., three times the expected
concentration), the public dose increase is less than lmrem/year.
I am including an excerpt from an email you sent to K2 Environmental dated July 18th, 2018;
"As discussed, we have been working with Jim Grice and his team for some time now. In an email dated July, 18th Mr.
Grice states:
"The March 8, 2016 NRC Memorandum you provided correctly categorizes the request that you have made as
a request for an Alternate Waste Disposal Method under the federal provisions of 10CFR20.2002. This would
be a request for alternate disposal in Colorado under section 4.34.
As a result there are two things that need to be accomplished in order for us to provide you with an
authorization to do this. One is that we would have to approve your request based on the potential dose to a
landfill worker. The demonstration previously provided regarding dose is acceptable for this purpose. The
second is that we have to provide an exemption to the facility that will be receiving the waste. (Please see the
attached NRC Agreement State Letter dated March 13, 2012 as well as the October 2017 NRC draft guidance
regarding alternate disposal.)
Lastly, in order for us to grant an exemption to a solid waste landfill to accept these materials you the licensee
have to identify a specific landfill and the landfill would have to obtain designation to receive these
materials. The designation requirement is a result of the Colorado Solid Waste Rules. The Colorado Revised
Statutes C.R.S. 30-20-110 (1) (c) states that, "No radioactive materials or materials contaminated by
radioactive substances shall be disposed of in sites or facilities not specifically designated for that purpose."
5
We intend to further discuss this issue with the County, however, we believe it in everyone's best interest to obtain
your recommendation prior to proceeding.
Please advise what next steps may be necessary to obtain your approval.
Many thanks,
PAWNEE
Jerry Hamel, Jr.
General Manager
47368 County Rd 118
Grover, CO 80729
(c) 970-889-0006
WASTE
http://www.pawneewaste.com/
6
Andy Todd, P.E.
Environmental Protection Specialist
Solid Waste Permitting Unit
x
P 303.691.4049 I F 303.759.5355
4300 Cherry Creek Drive South, Denver, Colorado 80246-1530
Andrew.Todd@state.co.us I www.colorado.gov/cdphe
Andy Todd, P.E.
Environmental Protection Specialist
Solid Waste Permitting Unit
P 303.691.4049 I F 303.759.5355
4300 Cherry Creek Drive South, Denver, Colorado 80246-1530
Andrew.Todd@state.co.us I www.colorado.gov/cdphe
Hello