SUMMARY OF CHANGES TO THE PROGRAM DESCRIPTION

December 2011

Colorado Program Description Amendments II(A)

- Colorado Hazardous Waste Profile This section has been updated from the

December 2006 application. II(B)

- Organization and Structure of the Colorado Program This section has been updated from the

December 2006 application.
II(C)

- State Procedures This section has been updated from the

December 2006 application. II(D)

- State Forms This section has been updat ed from the

December 2006 application. II(E)

- State Compliance Tracking and Enforcement Program This section has been updated from the

December 2006 application.II (A) Colorado Hazardous Waste Profile

As of October 2011 , Colorado ha s a total of 3,826 generators of hazardous waste. Approximately 115 facilities are listed as large quantity generators of hazardous waste. A total

of 538 facilities are listed as small quantity generators and 3,173 facilities notified as conditionally ex empt small generators of hazardous waste. There are 70 companies listed as transporters. A total of 22 companies are regulated as treatment, storage, and/ or disposal facilities. Of these, 18 are treatment and storage facilities and 14 are land disposal facilit ies . A

decrease in the numbers of RCRA Subtitle C Handlers has occurred since the December 2006 application because a) we have made an effort to cleanup the data through inspections, and b) the generator fee has incentivized generators to either mi nimize their waste generation and move to a

lower classification or make their classification accurate at a lower level.

Biennially, all treatment, storage and disposal facilities and all large quantity generators of hazardous waste are required to submit a hazardous waste report on their activities. These reports contain information on the types and amounts of waste the company generated, transported, treated, and/or disposed. For the purposes of this package, we are reporting waste generation data from the 2009 National Biennial RCRA Hazardous Waste Report.

The 2009 National Biennial RCRA Hazardous Waste Report indicates that 41,532 tons of hazardous waste was generated in 2009 . The 2009 National Biennial RCRA Hazardous Waste Report shows the amount of waste managed to be 88,573 tons. Colorado received 38,822 tons of waste and shipped 31,567 tons of waste.II (B) Organization and Structure of the Colorado Program

The current organizational structure of the Hazardous Materials and Waste Managem ent
Division is as follows:

Division Director’s Office

– The Division Director’s Office is responsible for the overall management of the division and is instrumental in the implementation of the Division’s strategic plans for improving the management of h azardous and solid waste in Colorado. The Division Director’s Office includes the Division Director, the Division Compliance Advisor and the Community Involvement Manager.

Administrative Program

– The Administrative Program consists of fiscal and administ rative services, financial services, human resource and training services, and information management.

Solid and Hazardous Waste Program

– The Solid and Hazardous Program includes the Hazardous Waste Program and the Solid Waste and Materials Management P rogram. The Hazardous Waste Program includes the Financial Assurance & Data Management Unit, the Hazardous Waste Compliance Assurance Unit, the Hazardous Waste Permitting Unit, the Compliance Coordination & Assistance Unit, and the Hazardous Waste Correcti ve Action Unit

. The Solid Waste and Materials Management Program includes the Solid Waste Permitting unit, the Solid Waste Compliance Assurance Unit, and the Material Management Group.

Remediation Program

– This program has four units, the Superfund/PA/S I Unit, the Superfund/Voluntary Cleanup Unit, the Federal Facility Remediation and Restoration Unit, and

the Uranium Mill Tailings Remedial Action ( UMTRA ) Unit.

Radiation Program

- This program includes the Radiation Management Unit, Radon Grants

Work Gro up, a Special Projects group, an X

- ray Certification Unit, and a Uranium Projects work

group.

See the attached organizational chart of the Division and the Programs. The Solid and Hazardous Waste Program has sufficient staffing and expertise to admini ster the RCRA Program

in the State.Regulatory/Guidance Revisions

As of December 20 11 , the Department has not made any regulatory or guidance revisions that affect the ability of the State to administer the Federal Program. The Department has reviewed

i ts current procedures and has determined that these procedures are sufficient to administer the Federal Program.

Resources

As of December 20 11 , Colorado has 38.8 full

- time equivalent employees (FTE) budgeted in the hazardous waste programs. This incl udes 35.8 FTE in the Hazardous Materials and Waste Management Division and 3.0 at the Colorado Attorney General’s Office. This will be sufficient to handle the current workload and new provisions.

The Division has established an outside contract for labo ratory services and has determined that it will have sufficient laboratory resources to administer the new provisions. No FTE are assigned for laboratory services.

Colorado has several facilities that each ha s a significant level of the State’s resources devoted to

them. These include the Denver Federal Center, Clean Harbors (Deer Trail) Inc., Ft. Carson, and the Pueblo Army Depot.

An itemization of current and estimated program resources for the next two years is shown in

Tables 1 and 2.II (C) State Procedures

The Department has reviewed its procedures and has determined that these procedures are sufficient to administer the regulatory changes in the Federal Program.

New policies or procedures implemented since the 2006 Authorization Packet was submitted

include: Agency

- wide Supplemental Environmental Projects Policy (May 2008) Agency

- wide Policy on Settling Administrative and/or Civil Penalties Against Counties and Municipalities (May 2008) Air Screening Concentrations Table (December 201 1) Arsenic Concentrations in Soil, Risk Management Guidance for Evaluating (June 2011) Colorado Soil Evaluation Values (CSEV) (July 2011)

End of Post

- Closure Care Policy (August 2008) Enforcement Response Policy (August 2008)

Environmental Release and Incident Reporting (January 2009) Penalty Policy (June 2008)II (D) State Forms

The Department has determined that all of the current forms are sufficient to administer the regulatory changes in the Federal Program.

The following forms have been u pdated since the last Authorization Package submittal: Notice of Inspection Forms

– General, GAP, and PCAPP Environmental Covenant Routing Form CAR (Corrective Action Review) Tracking Form Compliance Advisory Form SNC Routing FormII (E) State Co mpliance Tracking and Enforcement Program

The Department has reviewed its compliance tracking and enforcement program and has determined that the program is adequate to administer the regulatory changes in the Federal Program.

State Data Management Chan ges:

The State CRIS, and CASE systems continue to be maintained. Timetrak was replaced with Trax (a timekeeping application) and a SharePoint HW_Program site for tracking HW Projects and Documents The Department continues to use the RCRAInfo Version 5.3 system implemented by EPA Headquarters on or about March 15, 2010

.