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 updated 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 has 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 exempt 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 facilities. 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 minimize 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 Management 

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 hazardous 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 administrative 

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 Program. 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 Corrective 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/SI 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 Group, 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 administer the RCRA Program 

in the State.
Regulatory/Guidance Revisions

As of December 2011, 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 

its current procedures and has determined that these procedures are sufficient to administer the 

Federal Program. 

Resources

As of December 2011, Colorado has 38.8 full-time equivalent employees (FTE) budgeted in the 

hazardous waste programs. This includes 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 laboratory 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 has 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 2011)

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 updated 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 Form
II (E) State Compliance 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 Changes:

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.