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HomeMy WebLinkAbout20120232.tiff 615/e -99/C 2400 West Union Avenue Englewood,CO 80110 RECEIVED 303-914-1427(Phone) WASTE MANAGEMENT 886-331-0444(Fax) JAN 1 2 ,n19 Weld County ,g Department January 9, 2012 GREELEY OFFICE Mr. Doug Ikenberry Colorado Department of Public Health and Environment Hazardous Materials and Waste Management Division 4300 Cherry Creek Drive South Denver, CO 80246-1530 Subject: Buffalo Ridge Landfill Leachate Management Plan Response to Comment Letter Dated November 1, 2011 Dear Mr. Ikenberry: Waste Management of Colorado, Inc. (WMC) received your letter dated November 1, 2011 providing comments and pertaining to the Buffalo Ridge Landfill (BRLF) Leachate Management Plan. The comments from the letter are provided with responses following each. July 6, 2010 Letter Comment#1 —Page 2, 3`d par., only sentence—The sentence indicates that Waste Management proposes to replace the last paragraph of Section 7.1.1 of the Engineering Design and Operations Plan (EDOP revised December 10, 1992) with a reference to the July 2010 leachate management plan. The leachate must be properly characterized to determine if it is a hazardous waste. As such, the Division is receptive to including, but not necessarily being limited to, the parameters and constituents listed in Appendix l A and 1B of the Regulations Pertaining to Solid Waste Sites and Facilities, 6 CCR 1007-2, as leachate monitoring parameters at BRLF. It is recommended that the leachate management plan be inserted as an appendix to the EDOP upon approval by Weld County and the Division. Provide the verbatim language that is proposed for replacement of the last paragraph of EDOP Section 7.1.1. Response #1 —The leachate management plan as approved by the Division and Weld County will be included in the revised EDOP as an appendix. Please note that the EDOP is currently being revised and the section numbers, appendix labeling and other details are not yet available. However, by attaching the leachate management plan as an appendix, the revised EDOP text will not provide any additional details but will merely reference the plan in the appendix. Discussion of the sampling parameters and characterization of the leachate is further discussed in the response to Comment#7. nzati a tan,o� 2012-0232 3 i� PL0821 Mr. Doug Ikenberry January 9, 2012 Page 2 Leachate Management Plan (dated July 2010) Comment#2 —Page 1, 15` par 2"d sentence—The sentence indicates that the leachate collection system consists of a 6-inch granular drainage blanket that overlies the base liner. The present configuration of the granular drainage blanket is currently under Division review in context of the proposed base grade revisions and is not considered essential to the leachate management plan. Omit the sentence. Response #2 —The sentence has been removed. Comment#3 — Page 1, I s` par, last sentence—The sentence indicates that one of thirteen planned permanent sumps have been constructed. Thirteen permanent sumps are not consistent with the number of sumps shown on Plate 10 of 16 included with the East Weld Sanitary Landfill (i.e., previous name of BRLF) Design and Operations Plan (revised December 10, 1992) and are not considered essential to the leachate management plan. Omit the sentence. Response #3—The sentence has been removed. Comment#4—Page 1, 2"d par. —The paragraph, which discusses the source and amount of leachate generation, is considered subjective and not essential to the leachate management plan. Omit the paragraph. Response #4— The paragraph has been removed. Comment#5 —Page 1, 3`d par.—Change the text to read, "The management method to be implemented at the Buffalo Ridge Landfill includes the following:" Response#5 —The sentence has been amended. Comment #6—Page 1, item 1 — Change the text to read, "Temporary and permanent sumps shall be monitored at least quarterly for the presence of leachate. Monitoring shall be conducted to verify that leachate levels remain below the lowest elevation of the top of the consolidated drainage layer located on the floor of the liner adjacent to the sump. Leachate shall be pumped as necessary to maintain leachate levels below the lowest elevation of the top of the consolidated drainage layer located above the floor of the liner adjacent to the sump." The above edit is made to preclude leachate from contacting the waste placed above the drainage layer (i.e., the drainage layer placed adjacent to the Phase 1C sump has a nominal thickness of 6 inches). Additionally, glass cullet has been shown to consolidate under pressure per Waste Management's September 2, 2009 correspondence. Mr. Doug Ikenberry January 9, 2012 Page 3 Response #6 —Per 6 CCR 1007-2 Part 1 Section 3.2.5(D), leachate levels are allowed to exist up to but not exceeding one foot over the liner and proposes to follow the existing regulations. Item 1 has been modified to state that leachate levels shall remain below"one foot(1 ft) above the floor of the liner adjacent to the sump". Comment#7—Page 1, item 2—Change the text to read, "Leachate shall be properly sampled and analyzed at least annually to determine if the leachate is a hazardous waste. The leachate parameters and constituents shall include but not be limited to all those listed in Appendix lA and 1B of the Regulations Pertaining to Solid Waste Sites and Facilities, 6 CCR 1007-2. The list of parameters/constituents is subject to revision pending the acceptance of future waste streams at the landfill (e.g., Technologically Enhanced Naturally Occurring Radioactive Material, etc.). In the event the leachate is determined to be a hazardous waste, it shall be disposed of in accordance with all applicable laws, regulations and ordinances." Response #7—Leachate sampling is not conducted for the sole purpose of characterization of the leachate itself. The data is used for comparison with groundwater data to determine if there has been a release from the landfill. As the management plan does not need to provide the reason(s), they have been omitted from the revised text. The leachate management plan must be specific in its guidance to the landfill personnel on which parameters to analyze for; therefore, the use of the phrase "shall include but not be limited to" is not appropriate for this document. Addition of the last sentence in the comment provides for expansion of the sampling list should the need arise. Comment#8 —Page 1, item 3 — Change the text to read, "In the event the leachate is determined to be non-hazardous, it may be used for dust control on the interior slopes that are without final cover and that are located within the lined limits of the landfill. Should there be more non- hazardous leachate than needed for dust control, it shall be properly transported and managed appropriately such as disposal at a publicly owned wastewater treatment facility. Alternative on- site leachate disposal methods shall be submitted to Weld County and the Colorado Department of Public Health and Environment (CDPHE)for review and approval." Response #8—The revised text continues to allow for on-site storage but requires a "leak-tight" above ground storage tank located over lined areas. The revised text also allows for the use of leachate on finished decks as well as interior slopes over lined areas. Comment #9 —Page 2, item 5 —Change the text to read, "The leachate shall be applied over lined areas with soil cover at rates to avoid runoff or any amounts of standing fluids." Response #9—WMC will change the sentence to read "The leachate shall be applied over lined areas with soil cover with application rates that will not contribute to runoff or ponding." Mr. Doug Ikenberry January 9, 2012 Page 4 Comment#10—Page 2, item 7, 1st sentence—Change the sentence to read, "The dates and results of the quarterly monitoring events as well as the leachate analytical results and the dates and volume of leachate applications shall be provided to Weld County and CDPHE with the First Half Groundwater Monitoring Report each year." Alternatively, change the sentence to read, "The dates and results of the quarterly monitoring events as well as the leachate analytical results and the dates and volume of leachate pumped and applied on site shall be provided to Weld County and CDPHE with the First Half Groundwater Monitoring Report each year." Response #10-Item 7 has been modified to include the requested information. If there are any questions about this request or the attached plan, please call me at 303-914-1427 or Mr. Tom Schweitzer, at 303-914-1445. Sincerely, <! - D.4 Jessica Walko, P.E. Facility Engineer Enclosure cc: Troy Swain, WCDPHE Kim Ogle, WCDPS Bill Hedberg, Buffalo Ridge Landfill Jack Epple, Buffalo Ridge Landfill LEACHATE MANAGEMENT PLAN BUFFALO RIDGE LANDFILL January 2012 The disposal cell design includes a leachate collection system that underlies the waste disposal area. The drainage blanket is designed and constructed to drain to sump areas located at the low point of each disposal area. The permanent sumps are designed with riser pipes that extend up the side-slope of the disposal cell to ground surface. The riser pipes are used for monitoring leachate levels, collecting samples for analysis, and removing leachate as required. The management method to be implemented at the Buffalo Ridge Landfill includes the following: 1. Temporary and permanent sump risers shall be monitored at least quarterly for the presence of leachate. Monitoring shall be conducted to verify that leachate levels remain below one foot(1 ft) above the floor of the liner adjacent to the sump. Leachate shall be removed as necessary to maintain leachate levels at or below one foot (1 ft) above the floor of the liner adjacent to the sump. 2. Leachate shall be sampled and analyzed at least annually. The leachate parameters and constituents shall include those listed in Appendix I and IB of the Regulations Pertaining to Solid Waste Sites and Facilities, 6 CCR 1007-2. The list of parameters/constituents is subject to revision pending the acceptance of future waste streams at the landfill (e.g., Technologically Enhanced Naturally Occurring Radioactive Material, etc.). In the event the leachate is determined to be a hazardous waste, it shall be disposed of in accordance with all applicable laws, regulations and ordinances. 3. In the event the leachate is determined to be non-hazardous, it may be used for dust control on finished decks and interior slopes that are without final cover and that are located within the lined limits of the landfill. Should there be more non-hazardous leachate than needed for dust control, it shall be properly transported and managed (such as disposal at a publicly owned wastewater treatment facility) or stored over lined portions of the landfill in a leak- tight above ground tank until needed for dust control. Alternative on-site leachate disposal methods shall be submitted to Weld County and the Colorado Department of Public Health and Environment(CDPHE) for review and approval. 4. When using leachate for dust control, leachate would be pumped from the sumps into a water truck for transport to the disposal area. A spray-bar attachment on the truck, or similar distribution device, will be used to apply the leachate. In-lieu-of a water truck, an alternative method for transporting and applying the leachate may be used provided conformance with items 5 and 6 below is maintained. 5. The leachate shall be applied over lined areas with soil cover with application rates that will not contribute to runoff or ponding. Page 1 6. The application areas will be located away from the active disposal area. 7. The following information shall be provided to Weld County and the CDPHE with the First Half Groundwater Monitoring Report each year: • The dates and results of the quarterly leachate level monitoring, • The leachate analytical results, and • The dates and volumes of leachate applications Page 2 2400 West Union Avenue Englewood,CO 80110 RECEIVED 303-914-1427(Phone) WASTE MANAGEMENT 877-331-0444(Fax) JAN 11 201? January 26, 2012 Weld County donning Department GREELEY OFFICE Ms. Dana Podell Colorado Department of Public Health and Environment Air Pollution Control Division (APCD-SS-B1) 4300 Cherry Creek Drive South Denver, CO 80246-1530 CERTIFIED MAIL 7001 1940 0001 9919 8148 RE: ANNUAL NMOC EMISSION RATE REPORT BUFFALO RIDGE LANDFILL Dear Mrs. Podell, As required under the State Emissions Guideline Program for Municipal Solid Waste Landfills, the Buffalo Ridge Landfill (BRLF) located at 11655 Weld County Road 59 in Keenesburg, Colorado completed an Annual NMOC Emission Rate Report for emissions through December 31, 2011. Should you have any questions regarding the updated information contained in this report, please contact me at 303-914-1427. Sincerely, aDA Jessica Walko Facility Engineer Attachment cc: Troy Swain, WCDPHE Doug Ikenberry, CDPHE Kim Ogle, WCDPS Bill Hedberg, BRLF ConvmU...ku. rk a-t5-ta Imo- LOnI 2011 TIER 1 NMOC EMISSION RATE REPORT BUFFALO RIDGE LANDFILL Prior to installation of a scale in December 2010, volume of waste accepted was estimated based on container size of incoming waste. Therefore,the equation found in 40 CFR 60.754(a)(ii)was used to determine NMOC emission rates for this Tier 1 NMOC Emission Rate Report. MNMoc=2LoR(e kc-e kt)(CNMoc)(3.6 x 109) NMOC Emission Rate1 2011 MNMOC = Mass methane generation potential, ma/Mg Lo = Refuse methane generation potential, m3/Mg = 170.00 Note2 R = Average annual acceptance rate, Mg/yr = 37,490.87 Note 1 k = Methane generation rate constant, 1/yr = 0.02 Note 2 c = Years since closure, yrs = 0.00 (c=0 for active and/or new landfills) t = Age of landfill, yrs = 9.50 CNMOC = Concentration of NMOC, ppm as hexane = 4,000.00 Note2 Conversion factor = 3.6 x 10-9 31.76 Mg/yr 1 Information used to determine annual average acceptance rate The average annual acceptance rate(R)is determined by taking the total waste received between the approximate opening date of July 1, 2002 and December 31, 2010 divided by the number of years for this period less inert material. Waste in place(Mg)through 12/31/10 740,066 Average Inert(from 7/1/02 to 12/31/10)= 36.9% Waste in place less inert material(Mg) Soil(daily and intermediate)(4:1 refuse to through 12/31/10 318,672 soil)= 20.0% Percent inert material 56.9% Age of site at volume measurement 8.50 Annual average acceptance rate(Mg/yr) 37 490.87 2 For regulatory purposes, the EPA default values fork, Lo and CNMoc must be used to calculate Tier 1 NMOC emission rates unless actual values have been obtained during Tier 2 sampling. 3 Inert material includes inert wastes that are disposed in the landfill as well as intermediate and final cover soil used as part of routine landfill cell development. NOTE. These calculations are made for NSPS purposes only. EPA has specifically stated as follows."It is recommended that these default values not be used for estimating landfill emissions for purposes other than NSPS and EG" (61 FR 9905.9912,March 12.1996) Consequently.these emission calculations grossly overestimate actual and potential emissions and reviewers of this document are specifically cautioned against Improper and irresonsible uses of these calculations Page 1 of 2 C.1Documenis and Seamgsljwalko\My Documents\Buffalo Ridga'ir Permit\NMOC Reportsi2011\BRL NMOC Report 2011 xis 2011 TIER 1 NMOC EMISSION RATE REPORT BUFFALO RIDGE LANDFILL 40 CFR 60.754(a)provides two equations for determining NMOC emission rates; one for sites with known solid waste acceptance rates and another for sites with unknown (i.e. estimated)waste acceptance rates. For sites that include time periods with both known and unknown acceptance rates, the Regulation indicates that both equations should be used. Buffalo Ridge Landfill is such a facility. NMOC Emission Rate Calculations for Years with Known Waste Acceptance Rates The site installed scales in Decmeber 2010. Therefore, the equation found in 40 CFR 60.754(a)(1)(I)for known waste acceptance was used to determine NMOC emission rates for this time period. The equation is provided below: NMOC Emission Rate' MNMoc=Summation of[2kLOMi(e""'i)(CNMOc)(3.6 x 10"9)]for each year with a known waste acceptance rate MNMoc = Mass emission rate of NMOC, Mg/yr k = Methane generation rate constant, 1/yr = 0.02 1 Lc, = Refuse methane generation potential, m6/Mg = 170.00 2 Mi = Mass of solid waste received for given year, Mg = Varies per year(see table below) t, = Age of the im section,Years = current year minus year of waste placement CNMOc = Concentration of NMOC, ppm as hexane = 4000.00 2 Conversion factor = 3.6 x 10.9 NMOC Emission Rate Calculation Summary(for years with known waste acceptance rates) Tons Tons Less II Year Received %Inert Inert Waste3 M;* t1 MNOOC 2011 67,947 59.8% 27,301 24,767 0 2.43 2012 2013 2014 Totals 67,947 27,301 24,767 2.43 Mg/yr `Conversion Used: tons to Mg-divide tons by 1.1023 1 For landfills in areas with a thirty year annual average precipitation of less than 25 inches, a k value of 0.02 is to be used. According to weather data, annual precipitation in the area of Buffalo Ridge Landfill is about 16 inches, therefore a k value of 0.02 has been used in the NMOC emission rate calculation. 2 For regulatory purposes, the EPA default values for Lo and CNMOc must be used to calculate Tier 1 NMOC emission rates unless actual values have been obtained during Tier 2 sampling. 40 CFR 60.754(a)allows the mass of nondegradable solid waste to be subtracted from the total mass of solid waste when calculating the value of Mi if documentation of the nature and amounts of such wastes is maintained. NOTE. These calculations are made for NSPS purposes only. EPA has specifically stated as follows:"II is recommended that these default values not be used for estimating landfill emissions for purposes other than NSPS and EG" (61 FR 9905,9912,March 12,1996). Consequently,these emission calculations grossly overestimate actual and potential emissions and reviewers of this document are specifically cautioned against improper and irresponsible uses of these calculations. TOTAL NMOC EMISSION RATE: NMOC rate for years with known waste acceptance rates: 2.43 NMOC rate for years with estimated waste acceptance rates: 31.76 Combined NMOC Emission Rate: 34.19 Mg/yr Page 2 of 2 C\Oocumenls and settingsywalkmMy oocuments1Burtalo RidgeMir PermilMIMOC Reports120111BRL NMOC Repel 2011 xis RECEIVED. APR 1 1 201? Weld County Planning Department 2400 West Union Avenue GREELEY OFFICE Englewood,CO 80110 • 303-914-1445(Phone) WASTE MANAGEMENT 303.914-9937(Fax) April 6, 2012 Mr. Charles Johnson Colorado Department of Public Health and Environment Hazardous Materials and Waste Management Division 4300 Cherry Creek Drive South Denver, CO 80246-1530 Subject: Buffalo Ridge Landfill (BRLF) Updated Closure/Post-Closure Plan and Financial Assurance Plan Dear Mr. Johnson: Revised closure/post-closure and financial assurance plans are enclosed. The plans have been updated to reflect changes in certain closure/post-closure activities and quantities and miscellaneous text changes. The financial assurance plan includes new closure and post-closure cost estimates, which replace estimates prepared in 2007. Colorado regulations require that cost estimates be replaced with new estimates every five years or as otherwise required by the Colorado Department of Public Health and Environment. Accordingly, the new closure and post-closure cost estimates are in 2012 dollars. A certificate of insurance in the amount of the new estimates is also provided in the financial assurance plan. Copies of the enclosed plans have been placed in the facility operating record. Please call me at(303) 914-1445 if you have questions concerning the enclosures. Sincerely, Terri c weitzer, P.E. Engineering Manager Enclosures cc: Deborah Blandin, WCDPHE Kim Ogle, WCDPS Douglas Ikenberry, CDPHE Jack Epple/BRLF Operating Record Bill Hedberg, Waste Management of Colorado Julie Overmyer, Waste Management of Colorado, w/o enclosures Donna Meals, Waste Management, w/o enclosures CC ry �y y• ('b)'IO'o 4 C:\Documents and Settings\tschweit\My Documents\mydata\FinAssurancel2\BRLF FinAssur TransLtr 2012.doc D/`2— pc JM. CLOSURE/POST-CLOSURE PLAN BUFFALO RIDGE LANDFILL Weld County, Colorado Prepared by: Waste Management of Colorado, Inc. Buffalo Ridge Landfill 11655 WCR 59 Keenesburg, Colorado 80643 `t°$1lui 00 IREG/1/44�� 00 24176 Reviewed By: yam' y a�: U�.� Thomas S. Schweitzer, P �FS,•:. �;,:ec '- Registered Professional Engf* Nglt.' 0���``` State of Colorado License#24176 Updated March 2012 CLOSURE/POST-CLOSURE PLAN BUFFALO RIDGE LANDFILL TABLE OF CONTENTS Section Page 1.0 INTRODUCTION 1 1.1 PURPOSE 1 1.2 FACILITY INFORMATION 1 2.0 CLOSURE PLAN 2 2.1 INTRODUCTION 2 2.1.1 Description 2 2.1.2 Regulatory Requirements 2 2.2 CLOSURE ACTIVITIES 3 2.3 MAXIMUM EXTENT OF OPERATIONS 5 2.4 FINAL COVER 5 2.4.1 Final Grades 5 2.4.2 Final Cover Description 5 2.5 CONSTRUCTION 6 2.6 CONSTRUCTION QUALITY ASSURANCE(CQA) 6 2.7 CLOSURE SCHEDULE 7 3.0 POST-CLOSURE PLAN 8 3.1 INTRODUCTION 8 3.1.1 Description 8 3.1.2 End Use 8 3.1.3 Regulatory Requirements 8 3.2 POST-CLOSURE ACTIVITIES 9 3.2.1 Facility Management 9 3.2.2 Post-Closure Activities 9 LIST OF FIGURES Figure 1 Site Location Map 2 Closure Area Map 3 Closure Schedule Closure/Post Closure Plan Updated March 2012 Buffalo Ridge Landfill CLOSURE/POST-CLOSURE PLAN BUFFALO RIDGE LANDFILL REVISION LOG DATE DESCRIPTION OF REVISION BY April General Plan review and update TSS/ARS 2002 March Update Plan to increase estimate of largest area of the landfill ever TSS/ARS 2003 requiring final cover during the active life March Update Plan and modify text in Sections 2.4, 2.5 and 2.6 to reflect TSS/ARS 2005 approval of an alternative final cover design March Revised to update soil cover quantities,reflect quarterly inspections for TSS/ARS 2006 first 2 years of post-closure, and make miscellaneous text changes. March Updated Plan to reflect changes to the corresponding Financial Assurance TSS/ARS 2007 Plan dated March 2007 specifically replacing cost estimates prepared in 2002 with new cost estimates; updated soil backfill quantities. Miscellaneous text changes were also made to the Plan. March Revised plan to update soil cover quantities,update largest area requiring JW 2009 closure, and reflect annual vegetative surveys during post-closure. August Amended plan to include pumping and closure of the temporary JW 2009 dewatering trench and to reference inclusion of asbestos disposal area fencing in closure cost. March Amended plan to update pumping for the temporary dewatering trench JW 2010 and increase the fencing required for the asbestos disposal area in the closure cost. March Amended plan to update pumping for the temporary dewatering trench, JW 2011 add future landfill disposal cell Phase Id to be constructed in 2011, and fencing for the expanded asbestos disposal area. March Updated Plan to reflect changes to the corresponding Financial Assurance TSS 2012 Plan dated March 2012, specifically replacing cost estimates prepared in 2007 with new cost estimates. Miscellaneous text changes were also made to the Plan. Closure/Post Closure Plan ii Updated March 2012 Buffalo Ridge Landfill 1.0 INTRODUCTION 1.1 PURPOSE This Closure/Post-Closure Plan(Plan) for Buffalo Ridge Landfill (BRL)reflects the facility's present understanding of closure and post-closure care requirements for this solid waste disposal site. This Plan has been prepared to meet the following objectives: 1. Describe the steps necessary to close the site when the cost of closure would be the greatest. 2. Describe the activities to be conducted during the post-closure care period. This plan has been prepared in accordance with the provisions of the Colorado"Regulations Pertaining to Solid Waste Disposal Sites and Facilities", 6 CCR 1007-2 (Regulations). Sections 2.5 and 3.5 of the Regulations pertain to closure activities and Sections 2.6 and 3.6 pertain to post- closure activities. This Plan is to be used in conjunction with the Financial Assurance Plan for BRL revised March 2012. Cost estimates are calculated in the Financial Assurance Plan for the closure and post- closure care activities described in this Plan. 1.2 FACILITY INFORMATION BRL is located approximately 5 miles north of Interstate Highway 76, on Weld County Road 59, in the southeast quarter of Section 34,Township 3 North,Range 64 West as shown on Figure 1. The facility is owned and operated by Waste Management of Colorado, Inc. (WMC). The site consists of 1676 acres; 700 of which are permitted for municipal solid waste disposal with an approximate disposal capacity of 78 million bank cubic yards. The facility accepts non-hazardous municipal, commercial and industrial solid wastes. BRL will be developed in phases. The site will be closed and monitored as a single unit. Individual phases will not be closed or monitored separately. Therefore, this plan addresses the site as a whole. However, operational factors occurring during the life of the site may necessitate closure or monitoring of portions of the site individually. Closure/Post Closure Plan 1 Updated March 2012 Buffalo Ridge Landfill CLOSURE PLAN 2.1 INTRODUCTION 2.1.1 Description This closure plan describes the steps necessary to close the facility at any point during its active life. This plan will be reviewed and updated as needed for changing conditions. 2.1.2 Regulatory Requirements This closure plan is prepared in accordance with Section 2.5, "Closure of Solid Waste Disposal Sites and Facilities" and Section 3.5, "Closure" of the Regulations. This Plan will be maintained in the facility operating record. The closure requirements call for a closure plan, a description of the closure activities and the closure certification. The requirements are summarized below: Closure Plan 1. Prepare a closure plan for approval by the CDPHE after consultation with the local governing body having jurisdiction. The plan, at a minimum,must include the following: a. The steps necessary to close the landfill at any point during its active life. b. A description of the final cover system and the methods and procedures to be used to install the cover. c. An estimate of the largest area of the landfill ever requiring a final cover during the active life. d. A schedule for completing closure activities. 2. Maintain a copy of the closure plan in the operating record. Closure Requirements 1. Close the site in accordance with the Solid Waste Disposal Sites and Facilities Act and the Regulations. 2. Sixty(60) days prior to closure, notify the CDPHE and the local governing body in writing that the facility will be closing. 3. Sixty(60) days prior to closure, notify the general public of the facility closure by posting clearly visible signs of suitable size at the site entrance. Closure/Post Closure Plan 2 Updated March 2012 Buffalo Ridge Landfill 4. Enact precautions to prevent further use of the site for unauthorized disposal. 5. Prevent water pollution from occurring at or beyond the point of compliance. 6. Prevent nuisance conditions at or beyond the site boundary. 7. Initiate closure activities within thirty(30) days of reaching final design grades, unless an extension is obtained from CDPHE. 8. Complete closure within 180 days after closure initiation, or if necessary, obtain an extension from the CDPHE. Closure Certification 1. Following closure, submit a report certified by a Colorado professional engineer (P.E.)to the CDPHE documenting that closure has been completed in accordance with the closure plan. Place a copy of the report in the facility operating record. 2. Following closure,record a notation on the deed or other title instrument stating that the land was used as a landfill and its use is restricted. Notify the CDPHE and the local governing authority that the notation has been recorded and place a copy of the notation in the operating record. 2.2 CLOSURE ACTIVITIES The following closure activities will be performed when site closure is necessary: 1. Construction Documents - Construction plans will be prepared. 2. Regulatory Agency Notification - Sixty(60)days prior to closure of any landfill phase, a notification of the intent to close will be submitted to the CDPHE and the local governing authority and a copy of the notice will be placed in the operating record. 3. Public Notification- Sixty(60) days in advance of closure date, signs will be placed at entrance to the site notifying the general public of the closure date. 4. Final Cover-Final cover will be placed in accordance with the Regulations. The final cover design is discussed in Section 2.3 of this Plan. 5. Asbestos Disposal Area—On April 2, 2009 CDPHE approved the facility's Asbestos Waste Acceptance Plan for disposing friable asbestos waste at the site. The asbestos disposal area is located within the lined limits of the Phase 1 disposal cell in a fenced area Closure/Post Closure Plan 3 Updated March 2012 Buffalo Ridge Landfill with signage in accordance with the approved Waste Acceptance Plan. In the event of premature closure, Phase 1 (including the asbestos disposal area)will be covered with approximately 86,111 cubic yards of soil in order to achieve minimum final slopes of 5% per Section 2.4.1. Final cover will then be placed in accordance with Section 2.4.2. Facility closure will include the removal,replacement and surveying of the fencing of areas used for disposal of asbestos. Based on 3rd party cost estimates obtained for similar fencing at the Colorado Springs Landfill approximately$48,800 is estimated for removing and replacing approximately 3,200 feet of fencing. The post-closure cost estimate includes costs for facility inspections,maintenance and fence repair which allows for post-closure care for the asbestos disposal area. 6. Temporary Trench Collection System- During construction of the BRL Phase 1 c cell, an area of perched water was encountered in the vicinity of the permanent Phase 1 leachate sump. In order to continue construction and maintain compaction of the clay liner in the sump area, a temporary trench system was constructed. In a letter dated November 12, 2008, the CDPHE conditionally approved the design of the temporary trench system. Following construction, the trench system documentation report was sent to CDPHE and approved on March 6, 2009. The trench system collects artificially perched water and transports it away from the leachate sump area to a collection tank located outside the lined limits of Phase lc. This tank is monitored and pumped as necessary to allow for free flow of water from the saturated formation. Currently the tank capacity is reached approximately every 60 days based on current flow rates. The financial assurance has been updated to include closure of the trench system following a one year of remaining operation. Based on the data collected to date, closure is anticipated to occur mid-2013. Pumping of the tank is expected to cost approximately$3,600 as included in the closure cost estimate. This estimate is based on pumping the tank once a month for the next year until closure. Each pumping event is estimated to cost $300, allowing a technician to drive to and from the site, pump the tank and document the activity. At completion of pumping, the trench system was designed to be abandoned in place, as could be the tank. However, based on abandoning the trench system in place and removing/backfilling the tank, the estimated closure cost is $25,100, which is included in the closure cost estimate. 7. Completion of Closure -Closure activities will be completed within 180 days following closure. A request for an extension may be submitted to CDPHE if climatic or operational factors dictate that additional time is required for proper closure. 8. Certification/Documentation - Upon completion of construction, a report will be prepared Closure/Post Closure Plan 4 Updated March 2012 Buffalo Ridge Landfill by a Colorado P.E. certifying that closure was conducted in accordance with the provisions of this plan. The report will be submitted to CDPHE and the local governing body for approval and will be placed in the operating record. To complete closure a notation will be made on the title or deed to the land,which notifies prospective buyers that the land was used as a landfill, and that certain land use restrictions apply. Copies of the notation will be submitted to CDPHE and the local governing body and a copy will also be placed in the operating record. 9. Security- During closure activities and after closure,public disposal will be prohibited. Signs will be posted warning of unauthorized entry or waste disposal. The existing fence will be maintained and the front gate will be kept locked when not in use. 2.3 MAXIMUM EXTENT OF OPERATIONS An estimate of the largest area of the landfill requiring final cover is about 31.1 acres in Phase 1 as shown in Figure 2. Should the maximum area requiring final cover change, this plan and associated cover costs accordingly will be updated. 2.4 FINAL COVER 2.4.1 Final Grades Final grades have been designed to promote surface water runoff and minimize erosion. Final grade slopes are designed to be a minimum of 5 percent(20 to 1) and a maximum of 25 percent(4 to 1), unless alternative grades have been approved by CDPHE. Prior to placement of final cover, areas of the site that have not been filled to final grades may require placement of backfill to achieve 5% slopes. About 86,111 cubic yards of on- site soils are estimated for achieving minimum slopes prior to placement of final cover. 2.4.2 Final Cover Description BRLF received approval from CDPHE and WCDPHE for an alternative final cover(AFC) design on August 26, 2004 and September 3, 2004 respectively. Accordingly, the AFC components are described below. 1. Alternative Final Cover Layer - The AFC layer will consist of a minimum of 18 inches of slightly compacted soil from on-site sources. AFC thickness on the side slope will be increased to 20 inches in accordance with the AFC design. The AFC components should have no less than 26% fines content and be compacted to between 80%to 90% of maximum density as determined by Standard Proctor (ASTM D 698). Approximately 90,000 cubic yards of soil will be necessary for the AFC layer. This conservatively assumes a 20-inch AFC layer will be installed over the 31.1-acre area. Closure/Post Closure Plan 5 Updated March 2012 Buffalo Ridge Landfill 2. Alternative Final Cover Topsoil Layer—The 6-inch topsoil layer of the AFC will have no less than 30% fines content and be compacted to between 80%and 90%of maximum density as determined by Standard Proctor(ASTM D698). The 6-inch topsoil layer of the AFC will be material suitable for sustaining vegetation. AFC seedbed preparation, seed mix and fertilizer requirements are specified in the approved "Buffalo Ridge Landfill Alternative Final Cover Demonstration"prepared by Golder Associates dated July 12, 2004. Approximately 26,000 cubic yards of soil will be required for the topsoil layer. 2.5 CONSTRUCTION Construction of the final cover system will be performed by using equipment such as scrapers to excavate, haul and place loose soil lifts for the AFC layer. A motor grader, low ground pressure dozer, or other suitable equipment will be used to spread/shape the cover. The topsoil layer will be placed loosely over the AFC layer with scrapers and then shaped with a motor grader, low ground pressure dozer, or other suitable equipment. The topsoil layer will then be prepared in accordance with specifications provided in the above referenced Buffalo Ridge Landfill Alternative Final Cover Demonstration. 2.6 CONSTRUCTION QUALITY ASSURANCE (CQA) To ensure proper implementation of the AFC design the following CQA requirements apply: • Performance of grain-size distribution tests every 5,000 cubic yards will be conducted for the AFC layer and the 0.5 foot topsoil layer; • Performance of Standard Proctor tests every 10,000 cubic yards; • In-situ density testing using a nuclear gauge at a frequency of one test per 1,000 cubic yards; • Oven-dry moisture contents at a frequency of one test every 1,000 cubic yards; • Verification of proper thickness of cover at a grid spacing of about 100 feet on-center. A design drawing showing the area of AFC to be built and a detail of the cover cross-section will be supplied to the CDPHE and WCDPHE prior to construction. Also, an as-built construction drawing will be provided with the certification report that shows the survey points used to verify thickness on the approximately 100 feet on-center grid pattern. Closure/Post Closure Plan 6 Updated March 2012 Buffalo Ridge Landfill Upon completion of construction activities, a Colorado P.E. will sign a certification document indicating that the final cover was constructed in substantial conformance with the project specifications and approved closure plan. 2.7 CLOSURE SCHEDULE The schedule for closure is weather dependent. Excessive cold or rainy weather can affect placement of cover materials. The typical available construction window for placing cover materials in this climate is from late April through late September. A typical closure schedule is provided in Figure 3. If necessary, a request for an extension will be submitted to CDPHE to ensure that sufficient time is available to complete closure in accordance with the provisions of this closure plan. Closure/Post Closure Plan 7 Updated March 2012 Buffalo Ridge Landfill 3.0 POST-CLOSURE PLAN 3.1 INTRODUCTION 3.1.1 Description This post-closure plan describes all actions to be taken following closure of the site. Post- closure care begins after the site is closed in accordance with the closure plan. Post-closure care continues for a period of 30 years,unless during the life of the facility or the post- closure period, a demonstration is made to the CDPHE and the local governing body, which shows that a reduced time period is sufficient to protect human health and the environment. If the post-closure period is reduced,this plan will be updated accordingly. 3.1.2 End Use Upon completion of closure, current plans indicate that the site will be zoned for agricultural use. This end use should have minimal impact on the final cover, and the use will not interfere with post-closure monitoring. 3.1.3 Regulatory Requirements This post-closure plan is prepared in accordance with Section 2.6 "Post-Closure Care and Maintenance Standards"and Section 3.6, "Post-Closure Care and Maintenance"of the Regulations. This plan will be maintained in the facility operating record. The regulatory requirements are summarized below: Post-Closure Plan 1. Prepare a post-closure plan for approval by CDPHE in consultation with the local governing body, which includes the provisions to prevent or minimize nuisance conditions, maintain the final cover,monitor groundwater,maintain and monitor the leachate collection system, and monitor landfill gas. 2. Describe the planned end use for the site and identify the name and address of a contact person who is responsible for the facility. 3. Maintain a copy of the post-closure plan in the site's operating record. Post-Closure Activities 1. The post-closure period shall be at least 30 years unless a demonstration is made to CDPHE and the local governing body that a shorter time period is sufficient to protect human health and the environment. 2. Permanent surface water structures remaining after closure shall be designed to Closure/Post Closure Plan 8 Updated March 2012 Buffalo Ridge Landfill manage run-on and run-off from a 100-year, 24-hour storm event as required. 3. Enact precautions to prevent water pollution at the point of compliance after closure. 4. Enact precautions to prevent nuisance conditions at or beyond the site boundary after closure. 5. Post-closure monitoring shall be conducted in accordance with the approved post-closure monitoring plan. 6. At the completion of the post-closure care period, a certification signed by a Colorado P.E. or an approval from CDPHE must be placed in the operating record verifying that post-closure has been completed in accordance with the post-closure plan. 3.2 POST-CLOSURE ACTIVITIES 3.2.1 Facility Management During the post-closure period, a facility manager will be named and a phone number and address for the manager will be incorporated into this plan. The manager currently responsible for the facility is: Mr. Jack Epple Buffalo Ridge Landfill 11655 WCR 59 Keenesburg, Colorado 80643 303-732-0218 3.2.2 Post-Closure Activities The following post-closure activities provide for inspection, maintenance, and monitoring of the design features of the facility during the post-closure period: 1. Inspections - Inspections of the entire site will typically be conducted quarterly for the first two years after closure and semi-annually thereafter. The inspector will assess the conditions of the site and recommend corrective actions for any items needing attention. Items to be inspected are further described in the following line items and include nuisance conditions,the final cover system, groundwater monitoring points, leachate monitoring system, gas monitoring system, surface water management system, and security. 2. Prevent Nuisance Conditions - The placement of final cover provides a barrier between the refuse and the environment. Construction of the final cover in Closure/Post Closure Plan 9 Updated March 2012 Buffalo Ridge Landfill substantial conformance with the project specifications should prevent disease vectors, deter birds, minimize odors, reduce blowing litter, and minimize air and water pollution as direct contact with refuse is prevented. Inspections and continued maintenance of the final cover system will ensure the integrity of the final cover so nuisance conditions are prevented throughout the post-closure period. The potential for on-site litter, traffic congestion, and noise pollution will be eliminated once the closure of the facility is complete since refuse will no longer be accepted for disposal and heavy equipment will no longer be operating. 3. Final Cover System- The maintenance of the final cover may involve repair of the AFC layer the erosion layer and vegetation. It is estimated that 5%of the site per year will require cover maintenance, reseeding and fertilizer. An additional 5%is estimated, which will allow for 10%of the site for the first 2 years of post-closure for cover maintenance, reseeding and fertilizer. Additionally, a qualitative vegetation assessment is estimated to be performed annually during post-closure to ensure the vegetative cover is established and assist in identifying any areas that may require attention. 4. Groundwater Monitoring- Groundwater monitoring wells at BRL will be phased in with development of the landfill. A total of 20 groundwater-monitoring wells will be installed upon construction of the 6 landfill phases at BRL. The site currently has 11 groundwater monitoring wells, which make up the Phase 1 environmental monitoring system. The facility will be monitored in accordance with the Design and Operations Plan. The post-closure estimate assumes that 11 groundwater monitoring wells, which make up the Phase 1 environmental monitoring system, will be monitored during post-closure. Depending on the analytical data obtained during the site operating period, the number of wells and the monitoring frequency may be reduced during the post-closure care period with concurrence by CDPHE and the local governing authority. For this plan it is estimated that groundwater monitoring will be performed semi-annually. Samples will be analyzed for the constituents as listed in the approved Design and Operations Plan. The results of all analyses will be placed in the site's operating record. Monitoring results will be reviewed and a statistical evaluation performed comparing each event's results to background levels. Detection monitoring will continue as long as results remain below specified levels for each constituent. If the statistical evaluation shows that background levels are exceeded, confirmation sampling, and if necessary, corrective action will be performed in accordance with the GWMP and this plan will be updated as necessary. In addition to sampling, it is estimated that one well will require repair each year and a new pump will be required every five years. The integrity of the monitoring well Closure/Post Closure Plan 10 Updated March 2012 Buffalo Ridge Landfill system will be inspected during the monitoring events or during the annual site inspections. Any required repairs will be corrected. 5. Leachate Monitoring - The liquid elevation/level in the leachate collection sump will be monitored semi-annually to verify the levels are 1 ft. or less above the liner. The measurements will be taken concurrent with semi-annual groundwater monitoring or site inspection activities. Leachate samples from the sumps will be taken annually for analysis, if leachate is present. Although leachate is not expected during post-closure, in the event that leachate is removed from a sump, it will be managed in accordance with the analytical data and approved leachate management procedures. Information related to the number of gallons removed, date, time, and location of leachate removal, and the disposal method will be maintained in the facility operating record. During the post-closure period, a demonstration may be made to the CDPHE showing that leachate no longer poses a threat to human health and the environment and that monitoring can cease. 6. Gas Monitoring- The facility will monitor gas at the site quarterly in accordance with the Design and Operations Plan. Landfill gas probes will be phased with development of the landfill. A total of 35 gas probes will be installed upon construction of the landfill. Currently, 10 gas probes are installed which make up the Phase 1 environmental monitoring system. The post-closure cost estimate assumes the 10 gas probes which make up the Phase 1 environmental monitoring system will be monitored during post-closure. Based on the monitoring data obtained during the site operating period, the number of probes and the frequency of monitoring may be reduced during the post-closure care period with concurrence by CDPHE and the local governing authority. Results from each gas monitoring event will be placed in the site's operating record. If monitoring results indicate that methane gas is present above the permissible regulatory limits, measures will be taken in accordance with Section 2.3.3 of the Regulations. 7. Surface Water Management System - Maintenance of the surface water management system is expected to be required during the post-closure period. This maintenance consists of regrading or desilting channels and ponds. In addition, semi-annual inspections will be conducted to ensure the stormwater system is functioning satisfactorily. Inspections of the permanent stormwater management structures will be conducted semi-annually and following storms exceeding the 100 year, 24 hour storm event. 8. Waste Disposal - Off-site refuse will not be accepted during the post-closure Closure/Post Closure Plan 11 Updated March 2012 Buffalo Ridge Landfill period. However, if during post-closure repairs, previously placed refuse is excavated for construction activities, the refuse will be placed within the permitted fill area and final cover will be applied. 9. Security- During post-closure,the perimeter fence will remain in place and the front gate kept locked when the site is not attended. Signs will be posted warning of unauthorized entry. The integrity of the fence will be monitored and maintenance performed as necessary. 10. Certification - Upon completion of the post-closure care period, notification will be given to the CDPHE certified by a registered Colorado P.E. or approved by CDPHE, verifying that post-closure care has been completed in accordance with this post- closure plan. This notification will be placed in the operating record. 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Buffalo Ridge Landfill 11655 Weld County Road 59 Keenesburg, Colorado 80643 Updated March 2012 FINANCIAL ASSURANCE PLAN BUFFALO RIDGE LANDFILL TABLE OF CONTENTS Section Page 1.0 INTRODUCTION 1 2.0 REGULATORY REQUIREMENTS 1 2.1 COST ESTIMATES 1 2.2 FINANCIAL ASSURANCE ACTIVITIES 1 2.3 FINANCIAL ASSURANCE MECHANISMS 2 3.0 CLOSURE AND POST-CLOSURE COSTS 2 4.0 FINANCIAL ASSURANCE MECHANISM 2 LIST OF APPENDICES Appendix A Closure Costs B Post-Closure Care Costs C Insurance Certificate for Closure and Post-Closure Care Costs Financial Assurance Plan Updated March 2012 Buffalo Ridge Landfill FINANCIAL ASSURANCE PLAN BUFFALO RIDGE LANDFILL REVISION LOG DATE DESCRIPTION OF REVISION BY 04/02 General plan review and update. Replaced original cost estimates based TSS/ARS on 2002 CDPHE guidance or as determined by BRL. Changed financial assurance mechanism from letter of credit to insurance certificate. 03/03 Revise financial assurance costs based on the revised closure and post- TSS/ARS closure plan dated March 2003 03/05 Revise financial assurance costs based on the revised closure and post- TSS/ARS closure plan dated March 2005 3/06 Revised financial assurance costs in response to the Colorado Department TSS/ARS of Public Health and Environment(CDPHE) letters dated January 11 and February 13, 2006. 3/07 Replaced cost estimates of closure and post-closure prepared in 2002 with TSS/ARS new cost estimates in accordance with Section 1.8.3 of the Solid Waste Regulations. Miscellaneous text changes were also made to the Plan. 3/09 Updated to reflect changes to closure and post-closure plan updated JW March 2009. 8/09 Updated to reflect changes to closure and post-closure plan updated JW August 2009. 03/10 Updated to reflect changes to closure and post-closure plan updated JW March 2010. 03/11 Updated to reflect changes to closure and post-closure plan updated JW March 2011. 03/12 Replaced cost estimates of closure and post-closure prepared in 2007 with TSS new cost estimates in accordance with Section 1.8.3 of the Solid Waste Regulations. Miscellaneous text changes were also made to the Plan. Financial Assurance Plan it Updated March 2012 Buffalo Ridge Landfill 1.0 INTRODUCTION This revised Financial Assurance Plan (Plan) has been prepared in accordance with Section 1.8 of the Regulations Pertaining to Solid Waste Disposal Sites and Facilities, 6 CCR 1007-2, (Regulations) and sets forth the closure and post-closure care costs for Buffalo Ridge Landfill (BRL) in Keenesburg, Colorado. This Plan includes, in Appendices A and B, new closure and post-closure cost estimates which replace all previous estimates. The Regulations require that cost estimates be replaced every five (5) years or as otherwise required by the Colorado Department of Public Health and Environment (CDPHE) and 2012 marks the fifth year since costs were replaced. The next replacement of cost estimates is scheduled for 2017. This Plan also describes the financial assurance mechanism in place to ensure payment of all associated closure and post-closure costs. This Plan is to be used in conjunction with the BRLF Closure/Post Closure Plan dated March 2012. 2.0 REGULATORY REQUIREMENTS 2.1 COST ESTIMATES Section 1.8 of the Regulations lists the specific financial assurance requirements for solid waste disposal sites. These requirements are described below: 1. Maintain cost estimates, in current dollars, for hiring a third party to close the largest area of the facility requiring closure during the active life of the site. The cost estimate must also include costs associated with conducting post-closure care. 2. The facility must establish financial assurance sufficient to ensure payment of the third-party closure and post-closure care costs. 2.2 FINANCIAL ASSURANCE ACTIVITIES The following are the requirements for financial assurance activities as described in Section 1.8 of the Regulations: 1. Notify the CDPHE when the required cost estimates have been placed in the operating record; 2. Annually adjust cost estimates to account for inflation using the method prescribed by CDPHE; 3. Replace original cost estimates with new cost estimates every five(5)years, unless otherwise required by CDPHE; Financial Assurance Plan 1 Updated March 2012 Buffalo Ridge Landfill 4. Costs associated with closure, post-closure and corrective actions maybe adjusted after approval by CDPHE and the local governing authority; 5. Financial assurance must be provided continuously unless a release is granted by CDPHE. 2.3 FINANCIAL ASSURANCE MECHANISMS Several financial assurance mechanisms are available, and more than one mechanism may be used. For corporate entities, these mechanisms include a trust fund, letter of credit, surety bond and insurance. Waste Management of Colorado Inc. (WMC) has chosen to use insurance to meet the financial assurance requirements. The insurance certificate was prepared in accordance with the requirements set forth in Section 1.8.9 of the Regulations. 3.0 CLOSURE AND POST-CLOSURE COSTS Closure and post-closure costs are those costs associated with closing the facility and conducting post-closure care activities. These costs are determined by calculating the cost to complete all of the actions in the Closure/Post Closure Plan. The unit cost values for closure and post-closure activities were determined by WMC. Costs for items including earthwork, excavation and soil placement, were taken from recent bids for similar work completed at Waste Management construction projects. The new closure costs are provided in Appendix A, and the post-closure costs are provided in Appendix B. 4.0 FINANCIAL ASSURANCE MECHANISM WMC has established insurance coverage to assure adequate funds are available for all closure and post closure care costs determined in the Closure/Post-Closure Plan. The insurance meets all requirements set forth in Section 1.8.9 of the Regulations,"Insurance for Closure and Post- Closure". The insurance certificate is provided in Appendix C. Financial Assurance Plan 2 Updated March 2012 Buffalo Ridge Landfill APPENDIX A CLOSURE COSTS • TABLE 1 -CLOSURE COST ESTIMATE Date: March-12 Site: BUFFALO RIDGE LANDFILL Page: 1 Item Description Units Quantity Unit Cost Extended Category (Note 1) COSt COSt 1 Foundation Layer a Backfill of intermediate grades to achieve CY 86,111 1.85 159,306 minimum 5% slope (on-site source) b Other Foundation Layer Closure Costs CY 1.85 0 Foundation Layer Total Cost 159,306 2 Final Cover Section Closure Area: 31.1 Acres a Compacted Clay Layer(on-site source) CY 0 b Alternative Final Cover(on-site source) CY 90,000 1.60 144,000 c Topsoil (on-site source) CY 26,000 2.35 61,100 d Fertilizer/Soil Amendements/material hauling Acre 31.1 1,215.00 37,787 e Seeding Acre 31.1 145.00 4,510 f Other Final Cover Closure-Related Costs Acre 0 Final Cover Total Cost 247,396 3 Surface Water Controls (Note 2) a Drainage Swales/Berms/Channels 0 b Culverts 0 c Sedimentation/Surface Wtr Control Ponds 0 d Erosion Control 0 e Other Surface Water Closure-Related Costs 0 Surface Water Total Cost 0 4 Environmental Monitoring Installations a Grndwtr Mntq Wells w/dedicated pumps EA 0 b Gas Monitoring Probes EA 0 c Pumping of temporary trench system tank EA 1 3,600.00 3,600 Environmental Monitoring Total Cost 3,600 5 Gas Collection and Control System (GCCS) a Extraction Well Installation 0 b Extraction Well -Well Head Assembly 0 c Extraction Well - Lateral Pipe 0 d Gas/Vapor Collection - Header Pipe 0 e Gas/Vapor Collection - Header Drain 0 f Blower 0 q Blower Enclosure/Building 0 h Flare 0 i Other GCCS Closure-Related Items 0 GCCS Total Cost 0 TABLE 1 -CLOSURE COST ESTIMATE (Continued) Date: March-12 Site: BUFFALO RIDGE LANDFILL Page: 2 Unit Cost Extended Category Item Description Units Quantity (Jots i) Cost Cost 6 Miscellaneous Closure Activities a Access Road Construction 0 b Fencing(asbestos disposal area) 1 48,800.00 48,800 c Signs EA 2 150.00 300 Removal/backfill of temporary trench system EA 1 25,100.00 25,100 d tank Miscellaneous Total Cost 74,200 7 CLOSURE COST ESTIMATE SUBTOTAL 484,502 8 Engineering& Project Management a Design &Bid Documents (% of Subtotal) 3% 14,535 b CQA, Surveys & Reports (%of Subtotal) 10% 48,450 c Project Mgmt&Admin (% of Subtotal) 2% 9,690 d Engineering& Project Mgmt Total Cost 72,675 9 Contingency(% of Subtotal) 10% 48,450 10 CLOSURE COST ESTIMATE TOTAL (in 2012 dollars) $605,627 11 Inflation adjustment factor for 2013 12 Inflation adjustment factor for 2014 13 Inflation adjustment factor for 2015 14 Inflation adjustment factor for 2016 Total Closure Cost (adjusted to 2012 dollars) $605,627 Notes: 1 All costs include material and installation unless noted otherwise. 2 Costs to enlarge existing surface water control structures to meet closure requirements. APPENDIX B POST-CLOSURE CARE COSTS TABLE 2-POST-CLOSURE COST ESTIMATE Date: March-12 Site: BUFFALO RIDGE LANDFILL Acres at Closure: 31.1 Item Description Units Unit Unit Cost Quantity Cost per Quantity per Year Year 1 a Facility Inspections & Reporting- 2 per year EA 1 1,150 2 2,300 1 b Facility Inspections& Reporting -2 addt'l Annual cost for 2 addt'l events= 2,300 events to allow for qtrly inspections first Total Item cost for 2-yr period= 4,600 2 yrs of post-closure. Total Item cost annualized over 30-yr PC period= 153 2 Qualitative Vegetative Assessement-annual EA 1 2,737 1 2,737 3a Cover Maintenance, Reseeding & Fertilizing - AC 5% 2,040 1.6 3,172 5%of site per year(Note 1) 3b Cover Maintenance, Reseeding & Fertilizing- Annual cost for addt'l 5%= 3,172 addt'l 5% per year to allow for 10% of the Total Item cost for 2-yr period= 6,344 site first 2 yrs of post-closure Total Item cost annualized over 30-yr PC period= 211 4 Surface Water Controls- Maintenance LS 2,300 1 2,300 5 Fence Repair LS 15 100 1,525 6 Mowing-Assume annual mowing for first 10 AC 1 40 31 years of post-closure Annual mowing cost= 1,244 Cost for 10 mowing events= 12,440 Total Item cost annualized over 30-yr PC period= 415 7 Groundwater Monitoring -Semi-annual events EA 11 1,336 2 29,384 8 Groundwater Well Pump Repair/Maintenance LS 300 1 300 9 Gas Probe Monitoring, Maintenance and EA 10 118 4 4,720 Reporting-4 Events per Year 10 Leachate Monitoring -Annual EA 1 526 1 526 11 Leachate Depth Measurement-Semi-annual EA 1 1,472 2 2,944 12 Leachate Management- First 5 years of post- Annual cost for leachate mgmt= 20,000 closure(managed on-site) (Note 2) Total Item cost for 5-yr period= 100,000 Total Item cost annualized over 30-yr PC period= 3,333 13 Gas Collection and Control Syst Maint LS 0 14 Gas Condensate Disposal GAL 0 15 Subtotal - Items 1 through 14 54,021 16 Administrative Costs (% of Subtotal) 5% 2,701 17 Contingency(% of Subtotal) 10% 5,402 18 Total Cost per Year 62,124 19 Post-Closure Care Period: I 30 Years 20 Total Post-Closure Cost (in 2012 dollars) $1,863,724 21 Inflation adjustment factor for 2013 22 Inflation adjustment factor for 2014 23 Inflation adjustment factor for 2015 24 Inflation adjustment factor for 2016 Total Post-Closure Cost (adjusted to 2012 dollars) $1,863,724 Notes: 1 Unit cost for Item 3 is based on the Fertilizer,Soil Amendment and Seeding costs of the Closure Cost Estimate(Table 1)increased by a factor of 1.5 to provide an allowance for cover maintenace in addition to seeding,fertilizer and amendments. 2 Due to arid climate,leachate generation is not expected at closure. However,an annual allowance for leachate management is provided for the first 5 years of post-closure in the event of premature closure. APPENDIX C INSURANCE CERTIFICATE FOR CLOSURE AND POST-CLOSURE CARE COSTS 2012 CLOSURE AND POST-CLOSURE COST ESTIMATES The BRL Financial Assuarance Plan as revised March 2012 includes a closure cost estimate of $605,627 (Appendix A) and a post-closure cost estimate of$1,863,724 (Appendix B) for a combined total estimate of$2,469,351 (2012 dollars). These estimates are based on the site Closure and Post-Closure Plan revised March 2012. The accompanying insurance certificate reflects this adjusted amount. ACORDTM CERTIFICATE OF LIABILITY INSURANCE D03/19/2012 MM/DOY) PRODUCER THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION National Guaranty Insurance Company of Vermont ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS CERTIFICATE DOES NOT AMEND, EXTEND OR 100 Bank Street, Suite 610 ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW. Burlington, Vermont 05401 (802)864-1715 INSURERS AFFORDING COVERAGE NAIC# INSURED INSURER A: National Guaranty Insurance Company Waste Management of Colorado, Inc. INSURER B: of Vermont 5500 South Quebec Street, Suite 250 INSURER C: Greenwood Village, Colorado 80111 INSURER D: INSURER E: COVERAGES THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIOD INDICATED.NOTWITHSTANDING ANY REQUIREMENT,TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS CERTIFICATE MAY BE ISSUED OR MAY PERTAIN,THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS,EXCLUSIONS AND CONDITIONS OF SUCH POLICIES.AGGREGATE LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS. INSR ADD'L POLICY NUMBER POLICY EFFECTIVE POLICY EXPIRATION D/ LIMITS LTR INSRD TYPE OF INSURANCE DATEIMM/DYY1 DATE IMMIDDIYYI GENERAL UABILITY EACH OCCURRENCE $ COMMERCIAL GENERAL LIABILITY PR ( PREMISES ES RENTED (Eaxcurence) $ CLAIMS MADE OCCUR MED EXP(Any one person) $ PERSONAL BADVINJURY $ GENERAL AGGREGATE $ GEN'LAGGREGATELIMITAPPLIESPER: PRODUCTS-COMP/OP AGG $ POLK;Y n JECT PRO- LOC AUTOMOBILE LIABILITY COMBINED SINGLE LIMIT $ ANY AUTO (Ea accident) ALL OWNED AUTOS BODILY INJURY SCHEDULED AUTOS I (Per person) HIRED AUTOS BODILY INJURY NON-OWNED AUTOS (Per accident) PROPERTY DAMAGE $ (Per accident) GARAGE LIABILITY AUTO ONLY-EA ACCIDENT $ ANY AUTO OTHER THAN EA ACC $ AUTO ONLY: AGG $ EXCESS/UMBRELLA LIABILITY EACH OCCURRENCE $ 1 OCCUR CLAIMS MADE AGGREGATE $ _ $ DEDUCTIBLE $ RETENTION $ ?$ RY WORKERS COMPENSATION AND I OLIMITS I I 1 ER- ___ EMPLOYERS'LIABILITY ANY PROPRIETOR/PARTNERJEXECUTIVE E.L.EACH ACCIDENT $ OFFICER/MEMBEREXCLUDED? E.L.DISEASE-EA EMPLOYEE S If yes.describe under SPECIAL PROVISIONS below E.L.DISEASE-POLICY LIMIT $ OTHER A Closure CPCS02-0004 5/1/2002 4/09/13 $ 605,627.00 Post-Closure $1,863,724.00 DESCRIPTION OF OPERATIONS!LOCATIONS/VEHICLES/EXCLUSIONS ADDED BY ENDORSEMENT/SPECIAL PROVISIONS Buffalo Ridge Landfill, 11655 WCR 59, Keenesburg, CO 80643 This certificate certifies that the policy to which this certificate applies provides closure and/or post-closure care in connection with the Insured's obligation to demonstrate financial responsibility under Section 1.8.9 of the regulations pertaining to Solid Waste Disposal Sites and Facilities 6 CCR 1007-2, as amended. CERTIFICATE HOLDER CANCELLATION Director SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE THE EXPIRATION Colorado Department of Public Health and Environment DATE THEREOF,THE ISSUING INSURER WILL IgilOgLINIQR TO MAIL 120 DAYS WRITTEN Hazardous Materials/Waste Management Division NOTICE TO THE CERTIFICATE HOLDER NAMED TO THE LEFT,ENID-{Ip{I( t$U75$OnoAKL 4300 Cherry Creek Drive South gozcintst0109I.INA=49LM A PKTNEGIltIlrR ifsAd'Ei TI[dRx Denver, Colorado 80246-1530 xttrIw Tx,es r� c� AUTHORIZED REPRESENTATIVE Donna L. Meals, Vice President and Secretary ACORD 25(2001/08) ©ACORD CORPORATION 1988 2400 West Union Avenue Englewood,CO 80110 303-914-1445(Phone) WASTE MANAGEMENT 303-914-9937(Fax) RECEIVED April 23, 2012 APR 2 s InnMs. Cindy Beeler, Environmental Engineer Weld Co =[q g A®plftRlBnt Office of Enforcement, Compliance, and Environmental Justice t /UM Mail Code 8ENF-T U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 CERTIFIED MAIL 7003 3.110 0005 2391 8670 RE: BUFFALO RIDGE LANDFILL (BRLF) TITLE V OPERATING PERMIT NUMBER 03OPWE260 ANNUAL COMPLIANCE CERTIFICATION REPORT Dear Ms. Beeler, In accordance with the BRLF Title V Operating Permit #03OPWE260, attached is the Annual Compliance Certification Report covering the period April 1,2011 through March 31, 2012. Should you have any questions regarding these reports,please contact me at 303-914-1445. Sincerely, T Schweitzer Engineering Manager Attachments cc: Dana Podell, CDPHE, w/o enc. Douglas Ikenberry, CDPHE, w/o enc. Troy Swain, WCDPHE,w/o enc. Kim Ogle, WCDPS, w/o enc. Bill Hedberg, WMC, w/enc. U.)\--wn Ov, aDlca.- u59, 2400 West Union Avenue Englewood,CO 80110 303-914-1445(Phone) 303-914-9937(Fax) WASTE MANAGEMENT RECEIVED April 23, 2012 APR 2 6 7n17 Weld Coun , g Depar g0 Ms. Dana Podell GREE:.7 r ,)EFIGE Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-Bl 4300 Cherry Creek Drive South CERTIFIED MAIL Denver, CO 80246-1530 7003 3110 0005 2391 8687 SUBJECT: BUFFALO RIDGE LANDFILL (BRLF) TITLE V OPERATING PERMIT NUMBER 03OPWE260 ANNUAL COMPLIANCE CERTIFICATION REPORT SEMI-ANNUAL MONITORING REPORTS Dear Ms. Podell: In accordance with the BRLF Title V Operating Permit#03OPWE260, attached are the following reports: • Annual Compliance Certification Report(Period: 04/01/11 -03/31/12) • Semi-annual Monitoring and Deviation Report, Parts I, II, and III (Period: 10/01/11 - 03/31/12). Part II of the Monitoring and Deviation Report shows there were no permit deviations, upsets, or emergency conditions that occurred during this reporting period and appears blank. Should you have any questions regarding these reports, please contact me at(303) 914-1445 or Mr. Bill Hedberg at(970)686-2800 ext. 23. Sincerely, Tom Schweitzer Engineering Manager Attachments cc: Douglas Ikenberry, CDPHE, w/enc. Troy Swain, WCDPHE,w/enc. Kim Ogle, WCDPS, w/o enc. Bill Hedberg, WMC, w/enc. Bruce Clabaugh, WMC,w/enc. STATE OF COLORADO John W.Hickenlooper,Governor Christopher E.Urbina,MD,MPH ti p_F co<o� Executive Director and Chief Medical Officer yam, o`I Dedicated to protecting and improving the health and environment of the people of Colorado * *; 4300 Cherry Creek Dr.S. Laboratory Services Division �.w 1876 ; Denver,Colorado 80246-1530 8100 Lowry Blvd. " Phone(303)692-2000 Denver,Colorado 80230-6928 REC IVED Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health http://www.cdphe.state.co.us SEP 0 7 9m9 and Environment August 30, 2012 Weld County rianning Department GREET EY OFFICE Mr. Tom Schweitzer, P.E. Waste Management 2400 W. Union Avenue Englewood, CO 80110 Re: Comments regarding Buffalo Ridge Landfill (BRLF) Leachate Management Plan(Revised January 2012) and associated Waste Management cover letter dated January 9, 2012 Dear Mr. Schweitzer, The Hazardous Materials and Waste Management Division (Division) of the Colorado Department of Public Health and Environment reviewed the above referenced plan that was attached to a Waste Management cover letter dated January 9, 2012. Based on our review the Division offers the following comments regarding the content of the January 9, 2012 letter and for incorporation into a revised leachate management plan, as applicable: January 9, 2012 letter: 1) Response#1 indicates that Waste Management intends to include the approved Leachate Management Plan as an appendix to a revised Engineering Design and Operations Plan (EDOP). In this instance, the Division will consider the above referenced Leachate Management Plan as a proposed supplemental amendment to the currently approved EDOP. It is the Division's position that the last paragraph of Section 7.1.1 of the Engineering Design and Operations Plan(EDOP revised December 10, 1992)be replaced with a proper reference to the leachate management plan that is approved (or approved with conditions) by Weld County and the Division, as the case may be. The Division views the page replacement as a minor modification to the EDOP and therefore would not require a public comment period. Leachate Management Plan (revised January 2012) General Comments 2) Based on the Division's August 3, 2012 teleconference with Waste Management representatives, we acknowledge that references to storage of leachate in above ground tanks located over lined portions of the landfill will be removed from the plan. Specific Comments 3) Item 3, l' sentence—Change the sentence to state, "In the event the leachate is determined to be non- hazardous, it may be used for dust control within the lined limits of the landfill on finished decks and interior slopes that are without final cover. 0 etc a00— 0a3a q-14-2012 Rut? l Mr. Tom Schweitzer August 30, 2012 Page 2 of 2 4) Item 4, 15'sentence—Change"would"to"shall." 5) Item 4, last sentence—Change the sentence to state, "In lieu of a water truck, an alternative method for transporting and applying the leachate shall be submitted to Weld County and CDPI-IE for review and approval." 6) Item 5, only sentence—Change the sentence to state, "The leachate shall be applied on adequate cover composed of soils using application rates that will not cause runoff or standing liquid. 7) Item 6, only sentence—Insert"leachate" between"The"and"application." 8) Item 7, 2nd bullet—Change the text to state, "The leachate analytical results along with the supporting laboratory reports, and." 9) Item 7, 3`d bullet—Change the text to state, "The dates and volumes of leachate pumped and applied on site." 10) Item 7—Add a fourth bullet that states, "The general location(s)where leachate was applied the previous calendar year." The Division is receptive to meeting with Waste Management and Weld County representatives to discuss the content of this letter. In closing, the Division is authorized to bill for its review of technical submittals per Section 1.7 of the Regulations Pertaining to Solid Waste Sites and Facilities, 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, gr4.:31/1( Douglas M. Ikenberry Permitting Unit Solid Waste and Materials Management Program Cc: Troy Swain, Weld County Department of Public Health and Environment Kim Ogle, Weld County Department of Planning Services Doc Nyiro, Waste Management FILE: SW WLD BRL 2.2 AquAe�r °Ram Ou lzing 7430 E. Coley Avenue,Ste 310<Centennial,CO 80111 o Phone (303) 771.9150 ' Fax(303) 771-8776 September 17,2012 123324 Mr.Doug Ikenberry RECEIVED Colorado Department of Public Health and Environment Hazardous Materials and Waste Management Division �'Ef 0 2012 HMWMD-SWIM-B2 4300 Cherry Creek Drive South Weld County ;zn Wing 9s®artmwi* Denver,Colorado 80246-1530 GREELEY 0€€ICE Mr.Troy Swain Weld County Department of Public Health and Environment 1555 N. 17th Avenue Greeley,Colorado 80631 RE: Buffalo Ridge Landfill,Keenesburg,Colorado First Half 2012 Groundwater Monitoring Report Dear Mr. Ikenberry and Mr.Swain: On behalf of Waste Management of Colorado,Inc.(WMC),AquAeTer,Inc submits the first half 2012 groundwater detection monitoring results for the Buffalo Ridge Landfill (BRLF), in Keenesburg, Colorado. Regular semi-annual detection groundwater monitoring was completed in May 2012 at 11 monitoring wells. Enclosed is one copy of the report for CDPHE, one copy of the report for WCDPHE,and an electronic file containing laboratory analytical data for CDPHE. There were no volatile organic compound detections and no statistical exceedances in any of the down-gradient monitoring wells during the first half 2012 event, and the BRLF remains in detection monitoring in accordance with 6 CCR 1007-2, Part 1 - Regulations Pertaining to Solid Waste Sites and Facilities (effective December 30, 2011). Furthermore, there are no outstanding Alternative Source Demonstrations(ASDs)for BRLF. If you have any questions pertaining to the groundwater detection monitoring program at BRLF,please contact Mr. Doc Nyiro at(720) 876-2621 or Mr.Bill Hedberg at(970)686-2800. Sincerely, AquAeTer,Inc. f pt...te/* Terra Plute,E.I. Cathryn Stewart,P.G. Project Engineer Project Manager cc: Mr.Kim Ogle,WCDPS,w/o enc. Mr. Louis Bull,Waste Management,w/enc. Mr.Jack Epple,Waste Management,w/enc. Mr.Bill Hedberg,Waste Management,wt enc. Mr. Doc Nyiro, Waste Management,w/enc. Mr.Tom Schweitzer, Waste Management,w/enc. 010/2 —aa C0/1)fv/urt/<a//aro /°�1 PLogg RECEIVED OCT 0 4 ?nt7 Weld County !-Hug Department GREELI_Y OFFICE WASTE MANAGEMENT September 27, 2012 Mr. Matt Burgett Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 RE: Buffalo Ridge Landfill (BRLF) Title V Operating Permit Number 03OPWE260 Annual Compliance Certification Report and Semi-Annual Monitoring Report Dear Mr. Burgett: In accordance with the BRL ' Title V Operating Permit#03OPWE260, attached are the following reports: • Annual Compliance Certification Report(Period: 4/01/12—7/31/12) • Semi-annual Monitoring and Deviation Report, Parts I, II, and III (Period: 4/1/12 —7/31/12). Part II of the Monitoring and Deviation Report shows there were no permit deviations, upsets, or emergency conditions that occurred during this reporting period, and therefore is blank. Should you have any questions regarding these reports, please contact me at (720) 876-2621 or Mr. Bill Hedberg at(970) 686-2800 ext. 23. Sincerely, Doc Nyiro Environmental Engineer Attachment cc: Douglas Ikenberry, CDPHE, w/attachment Troy Swain, WCDPHE, w/attachment Kim Ogle, WCDPS, w/o attachment Bill Hedberg, WMC, w/attachment Bruce Clabaugh, WMC, w/attachment Tom Schweitzer, WMC, w/attachment L` te_ t<elta, a0/c2—O 3O._ 10-15-cap/ a_ PGon1 W WASTE MANAGEMENT September 27, 2012 Ms. Cindy Beeler, Environmental Engineer Office of Enforcement, Compliance, and Environmental Justice Mail Code 8ENF-T U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 RE: Buffalo Ridge Landfill (BRLF) Title V Operating Permit Number 03OPWE260 Annual Compliance Certification Report Dear Ms. Beeler, In accordance with the BRLF Title V Operating Permit #03OPWE260, attached is the Annual Compliance Certification Report covering the period April 1, 2012 through July 31, 2012. Should you have any questions regarding this report, please contact me at 720-876-2621. Sincerely, r/9 Doc Nyiro Environmental Engineer Attachment cc: Matt Burgett, CDPHE, w/o attachment Douglas Ikenberry, CDPHE, w/o attachment Troy Swain, WCDPHE, w/o attachment Kim Ogle, WCDPS, w/o attachment Bill Hedberg, WMC, w/attachment Tom Schweitzer, WMC, w/attachment ni �. W WASTE MANAGEMENT RECEIVED DENVER ARAPAHOE DISPOSAL SITE(DAD �'�K ED 1'O Box 460397 3500 South Gun Club Road r Awum,(O80046-0397 N V a 5 �M9 (720)676-2620 Weld Lu,. (303)690.8138 his October 31, 2012 Departmenf 1SRFt 1 r IFFICE Mr. Matt Burgett Colorado Department of Public I lealth and Environment Air Pollution Control Division A PC D-S S-131 4300 Cherry Creek Drive South Denver, CO 80246-1530 RE: Buffalo Ridge Landfill (BRIT') Title V Operating Permit Number 03OPWE260 Semi-Annual Monitoring Report Dear Mr. Burgett: In accordance with the 13811' Title V Operating Permit#03O1'W 111260, attached is the following report: • Semi-annual Monitoring and Deviation Report, Parts I, II, and Ill (Period: 8/1/12 --9/31/12). Part II of the Monitoring and Deviation Report shows there were no permit deviations, upsets, or emergency conditions that occurred during this reporting period, and therefore is blank. If you have any questions regarding this report, please contact me at (720) 876-2621. Sincerely, jDcti I,-,0±-cc-----_,___. _ Doc Nyiro • Environmental Engineer Attachment cc: Douglas Ikenberry, CDPHI1 "Troy Swain, WCDPHE Kim Ogle, WCDPS, w/o attachment Bill Hedberg, WMC Bruce Clabaugh, WMC Bill Meyer, Waste Management Dana Podell,CDPI 113, w/o attachment 'Font Schweitzer, WMC Rodney Walter, Waste Management (In In-ILL/1( Ci ! LsvL.J (720-/;J-- L'. 73, i I- l�-aci,,,�. PLL88( Hello