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V >O (o > 4— • 1. O O s Ual _ 92 >> N O D u l/1 +' N p 4._, vi E > U, i eL 4-- N C ♦.J (0 in O_ D p uu O v Ql � o cuI O ID t,_ C cc ■ O Ti __ Ep N N L. (13 Q 73 D n3 r 0 O1 C C i ' 4_ a--+ O O ?� ,2 v N .0 2 s a) Cro V > 0 > Ln Q U • • a c V Cl I I I I I • • organics Colorado's Leader in Organic Recycling PROPOSED PLAN TO CONTAIN AND REMOVE PLASTICS AND UPDATE ON CONTINUING CLOSURE ACTIVITIES AT PLATTEVILLE FACILITY April 26, 2011 I. BACKGROUND Al Organics ("Al"), is the owner and operator of the Platteville Highway 66 Composting Facility in Weld County Colorado (the"Facility"). Al began closure of the Facility on March 1, 2011. Al recognizes the need to utilize enhanced measures to timely close the Facility and diligently work to remove all materials on site and remove all sources of windblown plastics. Al takes seriously these issues and its efforts to address these issues. Al met with Weld County representatives and toured the Facility on April 18, 2011. On April 21, 2011, Al provided an initial draft of this proposed Plan to the County. Comments to the draft Plan were provided on April 25 and 26, 2011 respectfully. This revised proposed Plan was provided to the County on April 26, 2011. • This Plan contains Al's report on how Al is actively working to minimize and prevent migration of plastic debris from the Facility, Al's proposal to beneficially use the remaining compostable materials that remain at the Facility and the proposed milestones associated with meeting these deliverables A. Source of Plastics at the Facility The food wastes and other compostable and/or organic materials received by Al came from multiple local generators. While these generators screened the wastes to remove non- compostable materials prior to delivery at the Facility, not all non-compostable materials were always removed from the waste. As such, Al would screen again the received food waste piles and remove non-compostable materials. All compostable materials, which include compostable plastics, are left in the received food wastes. B. Materials at the Facility As of the date of this proposed Plan, there is one static processed pile, in which substantial composting (estimated to be greater than 50% of the processed) has already occurred, and composted overs piles located in three distinct sections at the Facility. The static processed pile is approximately 30,000 cubic yards and the composted overs piles are approximately 30,000 cubic yards. Within the static processed pile and the composted overs pile are compostable plastics. • Han" i • II. Al's PROGRESS TO DATE A. Removal and Containment of Plastics From the Facility Al brought to the Facility a Hurrikan air knife separator machine on March 21, 2011. The Hurrikan is a state of the art waste separator technology and involves a capital cost of several hundred thousand dollars.1 The Hurrikan is an extremely effective technology for removing all debris (including plastics) from compostable materials, isolating the debris in a high volume trailer for disposal at a permitted landfill rather than being placed in an overs pile. While the Hurrikan effectively removes and isolates debris, including plastics, from compostable materials it adds an additional but valuable step to the Facility operations—including closure. Since March 21s`, the Hurrikan has been used to screen all finished windrows at the Facility, and the composted overs piles. The Hurrikan is operated 6 days per week weather permitting. When high wind events (in excess of 15 mph) occur the Hurrikan cannot be safely or adequately operated and must be shut down. The material to be screened through the Hurrikan is fed through a hopper. When winds pick-up and material is blown from the feeder, use of the Hurrikan is discontinued. Al has found the Hurrikan to be an extremely effective technology. Since March 16, 2011, it has enabled Al to remove 56 tons of plastics from the Facility to a permitted landfill. Going forward under this proposed Plan, the Hurrikan will be an indispensible technology for prompt • and effective Facility remediation and closure. Additionally. Al has been covering the compostable overs piles with cleaned wood material, so as to help prevent plastics in those piles from being transported during high wind events. The placement of cleaned wood overs on top of these composted overs piles has been helpful in reducing plastics from leaving these piles, however,as detailed below Al is in the process of identifying and utilizing additional cover materials that it anticipates will be even more effective. B. Clean-up of Plastic Debris During high wind events some of the plastics located in the overs pile were subject to being blown off-site. Al understands the seriousness associated with plastics leaving the Facility and going on to neighboring properties. The situation is not acceptable to Al and it is actively addressing the issue. Al has previously employed debris pickers, usually a team of two to four people, to remove debris that blew from the Facility to neighboring properties. Since March 28, 2011, Al has substantially increased its efforts to address the debris problem that arose with the severe winds, and has deployed two teams of pickers to remove the plastics that have been blown during high wind events to neighboring properties. These teams of pickers are generally made up of as many as 12 people. Al retains day laborers and/or agricultural laborers to serve on the picking crews. Al currently leases the Hurrikan at use at the Facility but is in the process of purchasing it as an . addition to its operations. 2 • Due to the planting season underway it can be difficult to hire agricultural workers so Al must at times rely on day laborers. There may not always be enough day laborers available to fill a team of twelve people. With the increased utilization of picking crews and the addition of the Hurrikan, Al believes plastic debris will be much more effectively contained. However, and as detailed below, there does remain plastics debris in the composted overs piles and the static processed pile that need to be, and are being, addressed so that they are not susceptible to be blown off-site during high wind events. C. Windrows As of March 4`h there were 17 windrows at the Facility. As of the date of this proposed Plan no windrows remain on-site and no new windrows will be constructed. All compost which had been in windrows has been processed, and removed from the Facility. No waste materials are being accepted at the Facility. III. PROPOSED PLAN A. Plastic Containment and Clean-Up Al proposes the following steps to contain the plastics on-site. • 1. Encasing Composted Overs Piles Al is proposing to encase the composted overs piles with a heavy "tackifier" material, and/or clean wood materials. Al has identified (and recently field tested) a candidate tackifier material that would be sprayed on the composted overs piles, encasing the piles so that plastics are not removed during high wind events. The tackifier is organic and completely compostable. The main ingredient of the candidate material is potato starch, which provides a thick, strong weave that covers the composted overs pile. Once applied, Al has been advised the tackifier may hold for 2-4 months depending upon weather conditions. The benefit to using tackifier is it can be used on an on-going basis, allowing Al to process sections of the composted overs piles more efficiently than with wood cover. Based upon the testing completed to date, Al believes that the candidate tackifier will effectively work as a cover to prevent the migration of plastics from the composted overs pile. As such, Al proposes that it proceed immediately to cover all of the composted overs piles with the tackifier. 2. On-Going Plastic Clean-up Al will continue to deploy one to two crews daily, with each crew made up of between 4-12 people, to pick up debris from neighboring properties. As detailed above, because of Al s plan to entomb the overs pile with tackifier and with the successful deployment of the Hurrikan, it is expected that the plastics that are from the on-site piles will not be transported off-site during • 3 • • high wind events. All plastics that are picked up off-site, and in the course of the on-site clean- up process, will be hauled to a permitted landfill. B. Static Processed Pile When food waste was previously received at the Facility it was blended with bulking agents and covered with wood. The existing static processed pile, which is approximately 30,000 cubic yards, must now be ground and screened through the Hurrikan. A test of the material in the static processed pile conducted on April 20, 2011 showed that considerable composting activity has occurred, estimated to be up to 50% of the processed, in the pile. Al has determined that the static processed pile is ready to be ground and then screened in the Hurrikan so as to remove any remaining non-compostable materials. Once the grinding and screening processes are complete, Al could beneficially remove the high quality compostable material to its Rattler Ridge composting facility, also located in Weld County, to complete the composting process. The Rattler Ridge facility has available capacity to immediately accept the processed static processed piles currently at the Platteville Facility and incorporate (upon arrival) these processed static processed piles into windrows. Keeping 30,000 cubic yards of compostable material from the landfill will benefit the environment and preserves the static processed pile materials for its intended purpose—compost. This solution also would allow Al to avoid the potential of a huge loss of valuable product/revenue. Al understands that it may not transport the static processed pile to Rattler Ridge without the approval of the County and State. With this proposed Plan, Al respectfully requests that the County authorize Al to transport the compostable material from the static processed piles to the Rattler Ridge facility to complete the composting process. If the County, and the State, approves the transport of the compostable material from the static processed piles to the Rattler Ridge facility Al proposes to implement the following timetable to address the static processed pile: 1. Immediately begin the grinding and processing of the static processed pile in a series of controlled phases. a. Phase 1: Grind static processed pile. 1 — I '/z days worth of material would be ground at a time, and the grinder would be moved off-site until the next batch of material were ground. It is expected that the static processed pile can be ground over the course of 5-6 weeks. b. Phase 2: Immediately cover the ground static processed pile material with clean overs. c. Phase 3: Process the ground material through the Hurrikan to remove the plastics from the ground material. Removed plastics would be sent to the landfill and compostable materials would, with County and State approval, be moved to Rattler Ridge. • 4 • Only once the Phase 1 partial grinding operations are complete and the grinder is removed from the site, would the screening and separation process commence. The grinder would not return to the site until the previously ground pile was completely processed through the Hurrikan. To process the partially ground static processed pile will take approximately 4- 6 days. It is important to note that the Hurrikan cannot be operated during adverse weather conditions - which include winds in excess of 15 mph. Al would run the Hurrikan 6-days a week weather permitting, and endeavor to process the ground static processed pile as quickly as possible prior to grinding additional material. 2. As the static processed pile is processed through the Hurrikan it is proposed that it be transported to the Rattler Ridge facility. It is estimated that there will be approximately 150 semis full of material to haul to the Rattler Ridge facility. There will be significant cost to Al to transport the processed static processed pile to the Rattler Ridge facility, but not as great a cost as transporting it to the landfill. It is estimated that to transport the static processed pile to the landfill would cost approximately $250,000-$350,000 and only add to the landfill, not keep this commercially and environmentally valuable compostable material out of the landfill. 3. By request of the Weld County Department of Planning Services Al is investigating the following additional options for mitigating the potential release of plastic debris during the grinding of the static processed pile: • a. Installation of a litter control fence similar to that employed at Waste Management's Alt landfill facility. The cost and efficiency of this option is not yet known. Al began investigating this option on April 25th. As of April 27th it is not known whether this option is viable and cost effective. b. Portable fencing/netting/backstops. The cost and efficiency of this option is not yet known. Al began investigating this option on April 25th. As of April 27th it is not known whether this option is viable and cost effective. c. Prior to the grinding/screening process, run the static process pile through a trommel to separate the plastics from the pile. The efficiency of this option is not yet known. The material may not be able to be processed through the trommel. Al began investigating this option on April 25th. As of April 27th it is not known whether this option is viable and cost effective. Al appreciates the County's comments and is seriously considering each of these options. Al is evaluating the feasibility and cost of each of these options closely, and as quickly as possible. It is expected that Al will know whether all or any of these options are feasible and cost effective in the next two weeks, if not sooner. Al will likely need to conduct controlled testing of each of the options identified above, which would include limited grinding to see whether the potential control option is feasible. No other grinding or movement of the static processed pile would occur. Because Al does not know as of April 27th whether all or any of these options are • feasible and cost effective, Al respectfully requests that any decision on the static 5 • • processed pile be postponed for two weeks. However, Al will inform the County as soon as possible on its progress in identifying a feasible and cost effective control option. Al will work closely with the Department to keep them apprised of Al's evaluation of these options during this two week period. C. Processing of Composted Overs Pile If the tackifier performs as hoped, once the composted overs piles are encased,the migration of plastics debris from these piles will be substantially prevented or eliminated. As with the static processed pile, the composted overs pile must be processed through the Hurrikan before it can be sold. If authorized to transport the static processed piles material to the Rattler Ridge facility, Al would immediately proceed with the screening of the composted overs pile through the Hurrikan once it has completed processing the static processed pile. To process the composted overs pile will take approximately 28-days. It is important to note that the Hurrikan cannot be operated during adverse weather conditions, which includes winds in excess of 15 mph. Therefore it could take up to 6 weeks to process the entire composted overs pile through the Hurrikan. Al would run the Hurrikan 6-days a week (weather permitting), and endeavor to process the static processed pile as quickly as possible. The cleaned composted overs piles will be sold. If there remains at the Facility cleaned composted overs piles that have been processed and not sold, or not yet processed, by July ls`Al • proposes that those cleaned composted overs piles be transported to the Rattler Ridge facility. The cleaned composted overs piles transported to the Rattler Ridge facility would be sold from that facility. D. Enhanced Remediation of Open Areas at the Facility As the composted overs and static processed piles are addressed and ground is cleared, Al will mobilize scrapers and earth moving equipment to clean the cleared surface. These scrapers and earth movers scrape the surface layer of the ground, removing any remaining debris, and collecting the skimmed surface layer. This collected surface layer is contained, where it will remain until it is processed through the Hurrikan. The Hurrikan is anticipated to remove any remaining debris from the contained surface layer. The resulting cleaned surface layer will be evaluated, and if determined to be compostable material will be incorporated into the ground at the Facility to facilitate the seeding that will occur at the site. If the cleaned surface layer is not used at the Facility, Al proposes that it also be authorized to take that material to its Rattler Ridge facility. Beginning April 18`h, Al deployed a Caterpillar 623 belly scraper and other earth moving equipment to the site to begin work on the cleaned surface areas. The scrapers and earth moving equipment will be mobilized on-site until the surface layer of the site is cleaned. • 6 • IV.PROGRESS MADE TO CLOSE THE FACILITY In the Fall of 2010, Al met with representatives of Weld County to discuss the plan for closure of the Facility. At that time, Al and the County agreed that the Facility would begin the closure process on March I, 2011 and complete the process by June I, 2011.2 Al is currently in the midst of the applicable regulatory period for Facility closure. As Al has developed a process of screening and processing the on-site materials that most effectively minimizes off-property transport of plastics from the Facility, Al has identified several process enhancements that Al believes justify a reasonable extension of the timeframes for completing Facility closure activities. As detailed above,the addition of the Hurrikan machine has been a highly effective means to screen and process the materials so that plastics are immediately isolated and taken to a permitted landfill for disposal. However, the Hurrikan adds time to the screening process. As effective and costly as the Hurrikan device is, it operates under a maximum physical capacity to process materials, which affect processing timeframes. The Hurrikan cannot be operated when winds exceed 15mph or when it rains, which also adds time to the processing of materials. Because Al is committed to processing the materials on-site in the manner that best removes and contains the plastics, it believes that use of the Hurrikan is necessary. In order to process the remaining materials on-site through the Hurrikan, Al will need until August 22nd to complete all of the necessary closure activities. If the County authorizes the proposed Plan detailed here, Al will promptly initiate a formal written request to the State and the County to extend the closure date of the Facility to August 22, 2011. In addition to the processing of the remaining on-site materials, Al is also working diligently to accomplish these following tasks before it can close the Facility. 1. Remove tanks and footings. There are three empty storage tanks on-site that have never been plumbed for use. These three tanks are expected to be removed sometime during the week of April 25th. The concrete footings associated with the tanks will also be removed from the site. 2. Fill and grade retention areas. The rain water retention areas on-site will be filled and graded. The earth scrapers will be used to accomplish this task. 3. Till and reseed. Once surface layer has been scraped and open areas have been graded and leveled the soil will be tilled and reseeded. It is likely that the tilling and reseeding process will occur over time as the open areas are remediated so as to take advantage of spring and early summer rains. 4. Removal of debris fencing. Once all composted overs piles and static processed piles are removed, and the surface layer has been scraped and all open areas have been graded and 2 Pursuant to 6 CCR 1007-2, PART 1, 14.8.2 of the Colorado Department of Public Health and • Environment's Solid Waste Rules, closure activities may not exceed 90-days, unless extended. 7 leveled the debris fencing will be removed. This task will likely be one of the last IDcompleted in the closure process. V. REQUESTED ACTION As detailed in Section III(B), the control options identified by the Department to reduce the risk of plastic shreds migrating during the grinding process are still being investigated and evaluated by Al. However, the feasibility of the other elements of the Plan, such as application of the tackifier to the composted piles, are known. As such, Al respectfully requests that the County approve at this time all elements of the Plan except for how the static processed pile is to be addressed. 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L , . r. -11,..: • • 1`, ', I.jjet,.4: ,: ,...:....: P...,;.1.:c.:,,.1.•:1:47:,.:0):‘ ;_ , „1/4 , J. fll ID .4 LU .1 #• `4} . < may_ 4,-- • . .- . 14 - -.47 ..10 , < .i , . . • , _ - —4 — s . N , . •, ..- ikl I-- i r ill W 't.'.4-t_.,He' .r.: '... ;ill ''s 110117 4'7,-S.A. •741 I..'•:;:.ret• 7,11111L1 0 Z J : 4 a 0 ` . < ., . . -p , .. Let -; $ U (4119 , ys '� = ; r • ll+ I, P• , •f I H Z V) o Q � • E < Christie Peters 'om: Paul Seby [Paul.Seby@moyewhite.com] nt: Tuesday, May 03, 2011 12:16 PM To: Christie Peters; Trevor Jiricek; Bruce Barker Cc: Troy Swain; Kim Ogle; Mimi Larsen; Esther Gesick Subject: RE: Draft Hearing Cert for A-1 Organics Thanks. Al Organics understands that the Weld County BOCC hearing on this matter is continued until May 18, 2011. Regards- Paul M. Seby Partner 303 292 7934 Moye White Moye White LLP Attorneys at Law Market Square 6th Floor 1400 16th Street Denver CO 80202-1486 03 292 2900 fax 303 292 4510 www.movewhite.com \I , I'i.s r t Profile Download v and From: Christie Peters fmailto:cmpeters©©co.weld.co.us1 Sent: Monday, May 02, 2011 3:56 PM To: Trevor Jiricek Cc: Troy Swain; Kim Ogle; Paul Seby Subject: Draft Hearing Cert for A-1 Organics See the attached draft Hearing Cert for the Lambland, Inc., dba A-1 Organics Show Cause Hearing. NOTE: This is only the portion of the meeting after the Board reconvened at 2:00 p.m. Thanks, Christie Peters Deputy Clerk to the Board .5 10th Street, Greeley, CO 80631 WO-356-4000, ext: 4228 EXHIBIT cmpeters@co.weld.co.us ■■> 1 V • 861 20 Memorandum TO: BarbaraKirkmeyer, Chair o Board of County Commissioners W E L DEC O U N T Y FROM: Trevor Jiricek, Departments of PI ' g and Public Health and Environme DATE: May 18, 2011 SUBJECT: Al Organics, Show Cause Hearing Recommendation On Tuesday, May 17. 2011, Al Organics submitted an "Update to Proposed Plan to Contain and Remove Plastics and Update on Continuing Closure Activities at Platteville Facility, May 17. 201 1" (the Plan). The Plan outlines measures control measures evaluated and commenced to date, those planned in the near, and a schedule to close down the facility. The Departments of Planning and Public Health believe that implementation of the Plan will significantly reduce the potential for large amounts of plastic to be released from the facility during the closure period. Therefore, we are recommending that this Show Cause Hearing he continued until August 22, 2011. Our recommendation for continuance is conditional on the following: 1. A 1 demonstrate the effectiveness of the litter control fence, described on page 4 of the Plan, to County staff no later than May 25, 2011. (assuming the weather cooperates). 2. The collected surface layer pile (described on page 8) shall be tackified to prevent plastics from being liberated from it. 3. The facility shall minimize dust during all operations. In no case shall dust he allowed to migrate from the facility. 4. The "composted overs pile", which will be transferred to the Rattler Ridge facility, shall be processed with similar controls (including litter control fence) as described in the Plan. 5. Al submit a letter requesting formal vacation of the USR and Certificate of Designation (CD) no later than June 1, 2011. 6. Al submits an updated and comprehensive closure plan to Weld County and the Colorado Department of Public Health and Environment no later than June 1. 2011. No re-grading. filling, etc. shall occur on the site until the closure has been reviewed and accepted by Weld County and the Colorado Department of Public Health and Environment. 7. The Departments of Planning and Health will monitor progress of the operation and may bring hack the case to the BOCC should any violation he observed or should Al deviate from the Plan. 8. The Show Cause hearing will he dismissed and the USR and CD will he vacated at the August 22, 2011, hearing. EXHIBIT w, _ - Enclosure r h1cn . i L , L • organics Colorado's Leader in Organic Recycling UPDATE TO PROPOSED PLAN TO CONTAIN AND REMOVE PLASTICS AND UPDATE ON CONTINUING CLOSURE ACTIVITIES AT PLATTEVILLE FACILITY MAY 17, 2011 I. BACKGROUND Al Organics (-A1-). is the owner and operator of the Platteville Highway 66 Composting Facility in Weld County Colorado (the "Facility"). Al began closure of the Facility on March 1, 2011. Al recognizes the need to utilize enhanced measures to timely close the Facility and diligently work to remove all materials on site and remove all sources of windblown plastics. Al takes seriously these issues and its efforts to address these issues. Al met with Weld County representatives and toured the Facility on April 18, 2011. On April 21, 2011, Al provided an initial draft of this proposed Plan to the County. Comments to the draft Plan were provided on April 25 and 26, 201 1 respectfully. A revised proposed Plan was provided to the County on April 26. 2011. On April 27, 2011. Al appeared before the Weld County Board of County Commissioners ("Board") at which time a Proposed Plan was reviewed. At the conclusion of the hearing, the Board directed Al to encase the composted overs piles and continue picking up plastic debris on and off-site, along with continued closure activities. The Board also directed Al to pursue the investigation and testing of three potential control measures to contain the release of plastic debris during the proposed processing of the static pile. These potential control measures are outlined in Section III of this Plan. At the April 27th hearing, the Board scheduled Al to reappear before it on May 18. 2011, at which time Al and the Weld County Department of Public Health and Environment ("Department") will brief the Board on the success of the three potential control measures. Al will also provide to the Board at the May 18th hearing an update of its continuing efforts to mitigate and correct the release of plastic debris from the Facility and its efforts to close the Facility. Contained within this Plan is an update to the County on the testing of the three potential control measures; an update on Al's continued efforts to mitigate and contain plastic debris at the Facility; and its efforts to close the Facility. A. Source of Plastics at the Facility The food wastes and other compostable and/or organic materials received by Al came from multiple local generators. While these generators screened the wastes to remove non- ecompostable materials prior to delivery at the Facility, not all non-compostable materials were EXHIBIT ll�� 01065771.DOC5 always removed from the waste. As such,Al would screen again the received food waste piles and remove non-compostable materials. All compostable materials, which include compostable plastics, are left in the received food wastes. B. Materials at the Facility As of the date of this proposed Plan, there is one static processed pile, in which substantial composting(estimated to be greater than 50% of the processed)has already occurred, and composted overs piles located in three distinct sections at the Facility. The static processed pile is approximately 30,000 cubic yards and the composted overs piles are approximately 30,000 cubic yards. Within the static processed pile and the composted overs pile are compostable plastics. II. Al's PROGRESS TO DATE A. Communications With Neighbors and Governing Agencies 1. Outreach to Pete Salazar and the Sekich Family. Since the April 27'h hearing,Al has had repeated conversations and meetings with Pete Salazar and the Sekich family. Al understands that Mr. Salazar is satisfied with Al's efforts to date to clean-up the plastics and to move towards closure of the Facility. Al will continue to work with Mr. Salazar on the details of the Facility's closure plan. On May 9th, Mr. Chuck Wilson met with Randy Sekich to review Al's Plan and its efforts to clean-up off-site plastic debris. Mr. Wilson spoke again with Mr. Sekich on May 17th. During the May 17th conversation Mr. Wilson and Mr. Sekich discussed that after Mr. Sekich cuts his hay, which should occur around Memorial Day, Mr. Wilson and he will visit to assess what additional actions may need to be taken. Al continues to maintain an open dialogue with the Sekich family regarding Al's efforts and is working with the family to address any concern they may have regarding the progress of the plastic debris clean-up. 2. Conference With the CDPHE and the Department On May 5, 2011, representatives of Al and the Department participated in a conference call to discuss the status of the Compliance Advisory issued by the CDPHE on April 27, 2011. Al provided the CDPHE with an update on its efforts to mitigate and resolve the plastic debris issue and its proposal to move forward with the closure of the Facility. The CDPHE agreed that because the original closure date for the Facility,June l's. will need to be extended by Al depending in part upon the action taken by the Board on May 18th,that the remaining Compliance Advisory compliance dates are postponed pending determination of a closure date for the Facility. 2 01065771.DOC:5 B. Removal and Containment of Plastics From the Facility Al brought to the Facility a Hurrikan air knife separator machine on March 21, 2011. The Hurrikan is a state of the art waste separator technology and involves a capital cost of several hundred thousand dollars.' The Hurrikan is an extremely effective technology for removing all debris (including plastics)from compostable materials, isolating the debris in a high volume trailer for disposal at a permitted landfill rather than being placed in an overs pile. While the Hurrikan effectively removes and isolates debris, including plastics, from compostable materials it adds an additional but valuable step to the Facility operations—including closure. Since March 2O, the Hurrikan has been used to screen all finished windrows at the Facility, and the composted overs piles. The Hurrikan is operated 6 days per week weather permitting. When high wind events (in excess of 15 mph)occur the Hunikan cannot be safely or adequately operated and must be shut down. The material to be screened through the Hurrikan is fed through a hopper. When winds pick-up and material is blown from the feeder, use of the Hurrikan is discontinued. Al has found the Hurrikan to be an extremely effective technology. Since March 16, 2011, it has enabled Al to remove 56 tons of plastics from the Facility to a permitted landfill. Going forward under this proposed Plan, the Hurrikan will be an indispensible technology for prompt and effective Facility remediation and closure. C. Clean-up of Plastic Debris During high wind events some of the plastics located in the overs pile were subject to being blown off-site. Al understands the seriousness associated with plastics leaving the Facility and going on to neighboring properties. The situation is not acceptable to Al and it has been addressing the issue. Al has previously employed debris pickers, usually a team of two to four people, to remove debris that blew from the Facility to neighboring properties. Since March 28, 2011, Al has substantially increased its efforts to address the debris problem that arose with the severe winds, and has deployed two teams of pickers to remove the plastics that have been blown during high wind events to neighboring properties. These teams of pickers are generally made up of as many as 12 people. Al retains day laborers and/or agricultural laborers to serve on the picking crews. Due to the planting season underway it can be difficult to hire agricultural workers so A 1 must at times rely on day laborers. There may not always be enough day laborers available to fill a team of twelve people. With the increased utilization of picking crews and the addition of the Hurrikan, Al believes plastic debris has been much more effectively contained. However, and as detailed below, there does remain plastics debris in the composted oven piles and the static processed pile that need to A I currently leases the Hurrikan at use at the Facility but is in the process of purchasing it as an addition to its operations. 3 01065771 AOC:5 be, and are being,addressed so that they are not susceptible to be blown off-site during high wind events. D. Windrows As of March 4th there were 17 windrows at the Facility. As of April 27, 2011 there were no windrows remaining on-site and no new windrows will be constructed. All compost which had been in windrows has been processed, and removed from the Facility. No waste materials are being accepted at the Facility. III. Progress on Testing of Additional Control Measures As detailed below,two sources of materials remain on site at the Facility: the static processed pile and composted overs piles. Within this Plan Al proposes a process by which these materials may be further processed and beneficially used. Prior to the Board and the Department's approval of processing these materials,the Department requested that Al investigate the following additional options for mitigating the potential release of plastic debris during the processing of the static processed pile: a. Prior to processing,hand sort the static process pile to remove non-compostable materials from it. b. Prior to processing,run the static process pile through a trommel to separate the plastics from the pile. Al began investigating this option on April 25th. c. Portable fencing/netting/backstops. Installation of a litter control fence similar to that employed at Waste Management's Ault landfill facility. Al began investigating this option on April 25th . At the time of the April 27th Board hearing, Al was not certain whether all or any of these proposed plastic debris control measures to be employed prior to and/or during the processing of the static processed pile was feasible and cost effective. Al therefore respectfully requested that any Board decision on the static processed pile be deferred until testing of these options could be completed. The Board agreed, and deferred any action on the static processed pile until the May 18th hearing so as to allow Al time to investigate and test these and other potential control measures. On May 9,2011,Al conducted testing of two potential plastic debris control measures at the Facility. The control measures tested were: 1)hand picking/cleaning of the static processed pile; and 2) trommel screening of the static processed pile. The Department and the Colorado Department of Public Health and Environment("CDPHE") were invited to the testing. Mr. Troy Swain and Mr. Kim Ogle of the Department attended the testing. Representatives from the CDPHE were unable to attend the testing. 4 0106577 I.DOC:5 A. Results of the Testing. 1. Hand Picking/Cleaning the Static Pile: Two 5 cubic yard buckets of material(10cys total)from the static processed pile were placed on the ground,covering an 8' wide x 40' long and 6"-18" deep area. A crew of 10 pickers were deployed to remove plastic and other non-compostable materials from the pile. All non-compostable materials removed from the pile were placed into roll off trash cans. This process took 20 minutes from start to finish. At the time of the testing, winds were in excess of 14 mph with 30 mph gusts,but little to no blowing of debris or material occurred,and very little debris left the immediate work area. During the testing, Mr. Swain confirmed the wind speed. 2. Trommel Screening of the Static Pile: Approximately 50 cubic yards of material from the static processed pile were run through the McCloskey Trommel. The trommel has one set of Y" screens in the separation drum. 80% of the loaded material came out on the"overs"belt(all product greater than''h" including partially composted overs as well as debris consisting of plastic and compostable cardboard/paper). The material that came out on the"overs" belt largely consisted of partially composted wood that could be cleaned and sold as clean overs or reintroduced into the composting process as a bulking agent at Al's Rattler Ridge facility. Under this scenario,the 80% of the materials that came out on the"overs"belt would be transported to the landfill to be disposed of along with the separated debris. In the testing, 20% of the material came out on the fines belt. The material that came out of the fines belt could be utilized in further composting processes at our Rattler Ridge facility and could ultimately be sold as finished goods. At the time that the trommel testing was conducted the winds were blowing at 14 mph with 30mph gusts. Al advised Mr. Swain and Mr. Ogle that it would not normally operate the trommel under these high wind conditions,however, since the testing had been scheduled Al elected to continue with the testing. There was no objection from Mr. Swain or Mr. Ogle to continue with the testing. There was significant blowing and separation of material from the immediate work area during the testing. Picking crews were present to collect all blown debris. 3. Portable Fencing: Al has invested thousands of dollars in netting material,and to design a portable netting system. The portable netting system is being designed so as to capture plastics that migrate out during the processing of the static pile and the screening and cleaning of the composted overs piles. The portable netting system will 5 01065771.DOC:5 consist of seven 16'x40' panels. Al retained an engineer to design a system for deployment of the portable netting system. The construction of the frames and bases for the netting system is in process. Al had set a target date of May 16th to have the portable netting system completed. However, the heavy rains last week caused a transformer to blow at the plant that produces the concrete blocks Al will use as part of its netting system. The plant has just come back on-line but because of the shut-down Al will not have the concrete blocks it needs to install the netting system until later this week. It is expected at this time that the netting system will be completed by May 20`h and the system would be operational by May 23't. IV.PROPOSED PLAN A. Plastic Containment and Clean-Up 1. Encasing Composted Oven Piles At the April 27th hearing, Al briefed the Board and the Department on the use of a heavy tackifier on the composted oven piles. The tackifier is organic and completely compostable. The main ingredient of the candidate material is potato starch, which provides a thick, strong weave that covers the composted oven pile. Once applied, Al has been advised the tackifier may hold for 2-4 months depending upon weather conditions. The benefit to using tackifier is it can be used on an on-going basis, allowing Al to process sections of the composted overs piles more efficiently than with wood cover. At the time of the April 27th hearing,Al had just deployed the tackifier on a composted overs pile and was optimistic that it would prove to be an effective means to prevent the migration of debris from the composted oven piles. Al sought the Board's consent to use the tackifier on all composted overs piles, which consent was granted. As of the date of this Plan,all composted overs piles have been encased with a heavy"tackifier" material so that plastics in the piles are not removed during high wind events. To date,Al has found the tackifier to work effectively as a cover to prevent the migration of plastics from the composted overs pile. 2. On-Going Plastic Clean-up As labor is available,Al continues to deploy one to two crews daily, with each crew made up of between 4-12 people, to pick up debris from neighboring properties. The picking crews are going back to the fields and properties that they had already cleaned to do a second,third, or even fourth check of the property to gather any debris that may have been previously missed. All plastics that are picked up off-site,and in the course of the on-site clean-up process, will be hauled to a permitted landfill. B. Static Processed Pile 6 0106577 I.DOC:5 When food waste was previously received at the Facility it was blended with bulking agents and covered with wood. The existing static processed pile,which is approximately 30,000 cubic yards, must now be processed to remove noncompostable materials from the organic material . The static processed pile has been tackified. A test of the material in the static processed pile conducted on April 20, 2011 showed that considerable composting activity has occurred, estimated to be up to 50% of the processed, in the pile. Al has determined that the static processed pile is ready to be processed so as to remove any remaining non-compostable materials. Al proposes the following plan to address the static processed pile. 1. Run the Static Processed Pile Through the Trommel. The results of the trommel testing found that using a 1/2 inch screen produced only 20% organic material. Al believes that if it uses a 2 inch screen that it will be able to capture 50% - 60% of the organic material, with the remaining debris to be isolated and transported to the landfill. The netting system would surround the trommel work area,thereby preventing the migration of plastics that could come off the conveyor as the trommel is operating. It is expected that the static processed�ile can be run through the trommel screen and processed no later than August 15` . 2. Transport the Cleaned Processed Static Pile to Rattler Ridge. Processing the static pile through the trommel will result in high quality compostable material. Al could beneficially remove that high quality compostable material to its Rattler Ridge composting facility, also located in Weld County, to complete the composting process. The Rattler Ridge facility has available capacity to begin immediately accepting the processed static piles currently at the Facility and incorporate (upon arrival)these processed static piles into windrows. As the static processed pile is run through the trommel,the cleaned materials would be taken to Rattler Ridge and the debris would be taken to a landfill. Keeping this compostable material from the landfill will benefit the environment and preserves the static processed pile materials for its intended purpose—compost. This solution also would allow Al to avoid the potential of a huge loss of valuable product/revenue. Al understands that it may not transport the static processed pile to Rattler Ridge without the approval of the County and State. With this proposed Plan,Al respectfully requests that the County authorize Al to transport the cleaned compostable material from the static processed piles to the Rattler Ridge facility to complete the composting process. C. Processing of Composted Oven Pile The tackifier has to date performed as hoped, effectively stopping the migration of plastics debris from these piles. Al has found that the most effective means by which to address the composted overs is to process it through the Hurrikan before it can be sold. To process the composted overs pile will take approximately 28-days. It is important to note that the Hurrikan cannot be operated during adverse weather conditions, which includes winds in excess of 15 mph. Therefore it could take up to 6 weeks to process the entire composted overs 7 01065771.DOC:5 pile through the Hurrikan. Al would run the Hurrikan 6-days a week(weather permitting), and endeavor to process the static processed pile as quickly as possible. Because of the time that it will take to process the composted overs pile, Al proposes that it transport the composted oven piles to its Rattler Ridge facility. The composted overs would be tackified at Rattler Ridge and then processed at that site. Al would remove all of the composted overs piles to Rattler Ridge no later than July 31". Allowing Al to transport the composted overs piles to Rattler Ridge allows it to dedicate the equipment and personnel necessary to address the static processed pile and continue to proceed with the Facility's closure operations. Al proposes that it close the Facility by August 22m. In order for Al to achieve this August 2rd deadline it will need to move the composted oven piles to Rattler Ridge for processing at that site. D. Enhanced Remediation of Open Areas at the Facility As the composted overs and static processed piles are addressed and ground is cleared, Al will mobilize scrapers and earth moving equipment to clean the cleared surface. These scrapers and earth movers scrape the surface layer of the ground,removing any remaining debris, and collecting the skimmed surface layer. This collected surface layer is comprised of soil and compost. This collected surface layer is contained on-site, and has been compacted so as to prevent the migration of plastics from the pile. The collected surface layer will remain compacted until it is processed through the Hurrikan. The Hurrikan is anticipated to remove any remaining debris from the contained surface layer. The resulting cleaned surface layer will be evaluated, including any soil testing that may be required by the CDPHE and the Department. If it is determined that the collected surface layer is suitable for site remediation, it will be incorporated into the ground at the Facility to facilitate the seeding that will occur at the site. If the cleaned surface layer is not used at the Facility,Al proposes that it also be authorized to take that material to its Rattler Ridge facility. Beginning April 18th, Al deployed a Caterpillar 623 belly scraper and other earth moving equipment to the site to begin work on the cleaned surface areas. The scrapers and earth moving equipment will be mobilized on-site until the surface layer of the site is cleaned. V. PROGRESS MADE TO CLOSE THE FACILITY In the Fall of 2010, Al met with representatives of Weld County to discuss the plan for closure of the Facility. At that time, Al and the County agreed that the Facility would begin the closure process on March 1, 2011 and complete the process by June 1, 2011.2 Al is currently in the midst of the applicable regulatory period for Facility closure. As Al has developed a process of screening and processing the on-site materials that most effectively minimizes off-property transport of plastics from the Facility, Al has identified several process enhancements that Al believes justify a reasonable extension of the timeframes for completing Facility closure activities. 2 Pursuant to 6 CCR 1007-2,PART 1, 14.8.2 of the Colorado Department of Public Health and Environment's Solid Waste Rules,closure activities may not exceed 90-days,unless extended. 8 0106577 I.DOC:5 • In addition to the processing of the remaining on-site materials,Al is also working diligently to accomplish these following tasks before it can close the Facility. A. Remove tanks and footings. There are three empty storage tanks on-site that have never been plumbed for use. These three tanks have been removed. The concrete footings associated with the tanks will also be removed from the site. B. Fill and grade retention areas. The rain water retention areas on-site will be filled and graded. The earth scrapers will be used to accomplish this task. C. Till and reseed. Once surface layer has been scraped and open areas have been graded and leveled the soil will be tilled and reseeded. It is likely that the tilling and reseeding process will occur over time as the open areas are remediated so as to take advantage of spring and early summer rains. D. Removal of debris fencing. Once all composted overs piles and static processed piles are removed, and the surface layer has been scraped and all open areas have been graded and leveled the debris fencing will be removed. This task will likely be one of the last completed in the closure process. VI.REQUESTED ACTIONS A. Al requests the following: 1. Authorize Al to schedule a testing with Weld County Health officials in which the static processed pile would be run through the trommel with a 2 inch screen in an area surrounded by the netting system. 2. Upon determination that the processing of the static pile through the trommel is feasible,Al shall process the entire static processed pile through the trommel. The processed organic material will be transported to Rattler Ridge for further processing. All non-compostable materials will be taken to the landfill. 3. Permit Al to transport the composted overs piles to Rattler Ridge for further processing. B. Time Line For Requested Actives and Closure: 1. Testing of processing static pile through trammel: No later than June le 2. Processing static pile through tronunel: No later than August 15th 3. Transport processed organic material from static pile to Rattler Ridge: Ongoing,to be completed no later than August 20th 9 01065771.DOC:5 4. Transport of composted oven to Rattler Ridge: Ongoing,to be completed no later than July 31g 5. Estimated closure date for Facility August 22"d a. Remove footings No later than June 15th b. Fill and grade retention areas No later than August 22" c. Remediation of Site Scrapings: No later than August 22"d d. Till and reseed No later than August 22"d e. Removal of debris fencing No later than August 22" f. Soil Testing Once the protocol is approved,testing will be conducted once all materials have been removed from the Facility. 10 0I06577I.DOC:5 organics • Colorado's Leader in Organic Recycling BRIEFING TO WELD COUNTY BOARD OF COMMISSIONERS ON PROGRESS AT PLATTEVILLE FACILITY MAY 18, 2011 At the April 27, 2011 hearing ("Hearing") before the Board. the Commissioners determined that Al must take certain steps and continue with certain activities as it continues to mitigate the plastic debris issue at the Platteville Facility ("Facility") and proceed to close the Facility. Below is a summary of how Al has addressed and implemented the Board's directions since the April 27th hearing and a summary of its proposal to address the remaining materials on site at the Facility. A. IMPLEMENTATION OF THE BOARD'S DIRECTIVES 1. No other waste shall be brought into the Facility. No waste products have been brought into the Facility and no waste materials are being accepted at the Facility. • 2. A-I shall meet with the neighbors and find a solution to mitigate the damage they have already caused. Since the Hearing. Al has had repeated conversations and meetings with Pete Salazar and the Sekich family. Al understands that Mr. Salazar is satisfied with Al's efforts to date to clean-up the plastics and to move towards closure of the Facility. Al will continue to work with Mr. Salazar on the details of the Facility's closure plan. On May 9`h. Mr. Chuck Wilson met with Randy Sekich to review Al's Plan and its efforts to clean-up off-site plastic debris. Mr. Wilson spoke again with Mr. Sekich on May 17'x. During the May 17th conversation Mr. Wilson and Mr. Sekich discussed that after Mr. Sekich cuts his hay, which should occur around Memorial Day. Mr. Wilson and he will visit to assess what additional actions may need to be taken. Al continues to maintain an open dialogue with the Sekich family regarding Al's efforts and is working with the family to address any concern they may have regarding the progress of the plastic debris clean-up. 3. A-1 shall agree to vacate the USR upon closure of the facility. Al desires to and agrees to vacate the USR upon closure of the Facility. • EXHIBIT • • 4. A-1 shall work with the County Departments of Planning Services and Public Health and Environment, as well as the Colorado Department of Public Health and Environment, to work out key dates in regard to the closure. On May 5, 2011, representatives of Al and the Weld County Department of Public Health and Environment participated in a conference call to discuss the status of the Compliance Advisory issued by the CDPHE on April 27, 2011. Al provided the CDPHE with an update on its efforts to mitigate and resolve the plastic debris issue and its proposal to move forward with the closure of the Facility. The CDPHE agreed that because the original closure date for the Facility, June 1s`, will need to be extended by Al depending in part upon the action taken by the Board on May 18`1, that the remaining Compliance Advisory compliance dates are postponed pending determination of a closure date for the Facility. A copy of the CDPHE's letter is attached to this briefing. Al continues to work with the Weld County Department of Health to determine the most effective means by which to allow Al to process the materials remaining on-site at the Facility. Once a compliance measure is selected for mitigating the plastic debris that can result during the grinding process Al will be able to identify a closure date for the Facility. 5. There will be no grinding or movement of the static pile without the approval from the • County Department of Public Health and Environment for a test. and to the best extent possible. keep the plastic debris from being liberated from the site. No grinding of the static pile has occurred. A very small portion of the static pile has been moved so that Al may conduct testing on two potential control measures: hand sorting of the static pile and running the static pile through the trommel screen. The testing of these two control measures occurred on May 9th with Mr. Swain and Mr. Ogle present at the testing. Plastic debris pickers were on-site during the testing and captured any plastic that migrated out during the testing. 6. The composted overs piles shall be encased with tackifier instead of the clean wood materials. All composted overs piles have been encased with tackifier. 7. A-1 shall continue to provide ongoing plastic clean-up and deploy one to two crews consisting of approximately four (4) to twelve (12) people. daily to pick up debris from the neighbor's properties. As labor is available. Al continues to deploy one to two crews daily. with each crew made up of between 4-12 people, to pick up debris from neighboring properties. The picking crews are going back to the fields and properties that they had already cleaned to do a second, third, or even fourth check of the property to gather any debris that may have been previously missed. • 2 All plastics that are picked up off-site, and in the course of the on-site clean-up process, will be hauled to a permitted landfill. B. Al's PROPOSAL AND REQUEST 1. Authorize Al to schedule a testing with Weld County Health officials in which the static processed pile would be run through the trommel with a 2 inch screen in an area surrounded by the netting system. 2. Upon determination that the processing of the static pile through the trommel is feasible. Al shall process the entire static processed pile through the trommel. The processed organic material will be transported to Rattler Ridge for further processing. All non- compostable materials will taken to the landfill. 3. Authorize Al to transport the composted overs piles to Rattler Ridge for further processing. 4. Close the Facility by August 22"d • • 3 /t 7 C7vne LJ Supplemental Closure Plan, Odor, and Fly Control Information • A-i Organics Highway 66 Composting Facility March 24, 1995 jlnsure: In the event that receipt, processing or sales of materials ceases for a period of more than one year, a notice of closure shall be submitted in writing to Weld County. All materials, structures and berm's shall be removed within 180 days of the notice of closure, or as provided for in an approved closure plan submitted and agreed to by weld County. The closure plan shall demonstrate the following: 1. All finished or unfinished compost materials shall be removed from the site. • 2. Unfinished compost containing regulated materials such as sewage biosolids, will be disposed of at an approved land fill site, or properly applied to permitted farm ground. 3. Finished compost materials (including those having met requirements for unrestricted use) Can be used on the site as soil amendments in amounts deemed necessary by Weld County for reclamation of the site. The intent is to use finished compost to aid in reclamation of the facility, but not use the facility for - permanent storage of finished compost. A 4. All fencing, structures (other than those originally at the • site) , and berm's shall be removed from the site. • 5 . All disturbed areas shall be seeded and mulched in accordance with recommendations of the Soil Conservation Service within an additional 30 day period. 6. The facility will be reclaimed to its original condition and use, including re-vegetation of ground if required. Odors: Immediate blending of the materials and repeated aeration shall be conducted to mitigate. odor problems. Odors which . . originate at the composting facility and are measured at the nearest neighboring populated area will not exceed current or future limits as defined by Colorado Air Quality Control Commission, Regulation No. 2, ODOR EMISSION REGULATIONS. If an odor violation occurs that can be shown to have originated at the compost facility, the Weld County Department of Health shall direct the operator to correct the problem. The operator may use any acceptable method or combination of methods to mitigate an odor problem including, but not limited to bio-filtration. application • of organic odor control agents, additional aeration, and or changes • in operat.onal. parameters. such as the- time of day when mixing or aeration is accomplished. - -. :q • I Weld County Planning Services March 25, 1994 that cannot be composted will be properly contained and disposed of at an approved disposal site such as a certified land fill. A containment pit will be used to inventory the non-compostable wastes until they are disposed of. I Waste disposal will be done every quarter or when amounts accumulated warrant it. Estimated quantities will generally run less than 20 cubic yards per month. I Wastes or debris that cannot be composted will be disposed of on a quarterly basis via truck to approved disposal sites. 2.16 EXPLAIN PROPOSED LANDSCAPING PLANS AND EROSION CONTROL I MEASURES ASSOCIATED WITH THE PROPOSED USE. A berm will encompass the site, with shrubs or trees on the west and north west side of the site to provide a I windbreak and also improve visual esthetics as viewed by neighbors to the west and northwest. I The site was previously used for dry land farming. The composting operation increases the organic matter content of the soil, thus reducing wind erosion potential. The nature of the operation require windrows of product continually in process, which also reduce erosion potential. The site will be bermed where necessary to contain surface water. It is located on top of a hill with drainage sloping away from the center of the 'site. The area around the site is farm land. The surface soil has low permeability as stated in soil survey information. 2.17 RECLAMATION PROCEDURES TO BE EMPLOYED UPON CESSATION OF THE USE BY SPECIAL REVIEW ACTIVITY. All raw materials will be finished to soil amendment grade, then marketed or marketed to existing landscape or agricultural needs. Berm's will be leveled and site returned to its original condition and use. HWY 66 Composting Site 8 Esther Gesick 000m: Troy Swain nt: Friday, October 28, 2011 2:52 PM : Esther Gesick Subject: FW: Final Update -Closure Activities at Platteville Facility Attachments: Platteville Site Grading Pictures 070.jpg; Platteville Site Grading Pictures 073.jpg; Platteville Site Grading Pictures 075.jpg; Financial Assurance Bond.jpg; Final Update 10-27-11.docx Esther, if it's not too late, I would like to add this material provided by A-1 Organics. Thanks, Troy E. Swain Waste Program Coordinator Weld County Dept. of Public Health & Environment 1555 N. 17th Avenue Greeley, CO 80631 (970) 304-6415,ext. 2219 (970) 673-2218 (cell) (970) 304-6411 (fax) Al i 201F COi u 0r nfidentiality Notice:This electronic transmission and any attached documents or other writings are intended only for the person 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. From: Bob Yost fmailto:bobyost@alomanics.comi Sent: Friday, October 28, 2011 2:13 PM To: Trevor Jiricek Cc: Troy Swain; 'Paul Seby'; 'Mimi Larsen'; Kent Pendley; Chuck Wilson Subject: FW: Final Update - Closure Activities at Platteville Facility Hi Trevor, Chuck asked me to send you the attached documents so you can include them as necessary for Monday's hearing. • Final Update document dated 10-27-11 • Copy of financial assurance bond that is referenced in the update document • 3 pictures of the site taken earlier this week. Please let me know if anything else is needed. 'ob Yost ,, aCrgriVice President, . `t . ter„ Chief Technical Officer dO//_/co$ 1 Al Organics - US Composting Council "Composter of the Year" Ph: 970-454-3492 ext 1014 Cell: 303-710-9121 970-454-3232 ebsite: www.alorganics.com Please consider the environment and only print this e-mail if you must. Think Green and Reduce, Reuse, Recycle • • 2 • organics Colorado's Leader in Organic Recycling FINAL UPDATE CLOSURE ACTIVITIES AT THE PLATTEVILLE FACILITY FOR THE THE WELD COUNTY DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT October 27, 2011 On May 18, 2011, the Weld County Board of Commissioners directed Al to take certain activities as Al continues its work to close the Platteville Facility ("Facility"). Al provided an interim update of closure related activities to the County on July 2151 and a Second Interim update dated August 18, 2011. This Final Update provides information on activities associated with the closure of the Facility subsequent to the August 18, 2011 Interim Update. As noted in the August 18 Interim Update, Al submitted a letter (dated August 15, 2011) to the County and the Colorado Department of Public Health and Environment (CDPHE) requesting an extension of the closure date for the Facility to October 31, 2011. At the August 22 County Commissioner Meeting, the Board approved a closure date of October 31 for the Facility. With the approval of the October 31 closure date, the Board also required Al to maintain a Financial Assurance on the site. Al's Financial Assurance, which is Travelers Insurance Bond • #103198325 in the amount of$187,158.00, remains in place and is attached here for reference. Al has worked diligently with the County and CDPHE to coordinate closure efforts at the Facility. For instance, Al has had several discussions with County and CDPHE officials regarding the final grading plan for the Facility. Input from the County and CDPHE on the final grading plan were considered and addressed by Al. On September 20 Al submitted to CDPHE and the County its final grading plan, which incorporated suggestions and requests received from CDPHE, the County and Mr. Pete Salazar, owner of the land that the Facility operates on. One such suggestion was to retain an agronomist to confirm the final seeding plan for the site. Al has retained an agronomist for this purpose. By email received on September 23 from Roger Doak of the CDPHE, Al was notified that its September 20 proposal was acceptable to the CDPHE. On September 13, Al met with Mr. Salazar at the Facility to walk the entire site perimeter and confirm the final configuration to return the land to its pre-use configuration and use of the land for dry land farming, as required under the terms of Al's lease with Mr. Salazar. Comments received from Mr. Salazar at the September 13 site review were incorporated into the final grading plan. Rough grading of the site was completed on September 29. Al met with the Salazars repeatedly during the rough grading activity to confirm that it was being completed to their satisfaction. On September 30 Al met with Pete Salazar to view and approve the final pR • & 0 Corporate Headquarters: 16350 WCR 76 • Eaton,Colorado 80615 US Composting OO Al Organics Tel 970-454-3492 • 800-776-1644 • Fax 970-454-3232 ® ,Council tit t ,, Facilities: Eaton•Golden•Greeley•Keenesburg•Stapleton Seal al Assurance xtng etiefLas Vegas,Nevada 47rnente www.alorganics.com r776//— /007 grading configuration and ripping of the site prior to disking and seeding. Mr. Salazar confirmed that Al's final grading efforts were acceptable. On October 3, Al began disking of the site to break up clods and prepare the site for seeding while still maintaining the coarseness necessary to control wind erosion. Removal of remaining materials, final ripping of surface areas, disking of the site, and sampling of the site soil by the agronomist was concluded by October 7. Al received the agronomy sample results on October 11 and a re-seeding plan to create a cover crop for erosion control and surface stabilization at the site was created. The agronomist plan is also to be provided to the Salazars as guidance for future cropping plans at the site that can be implemented after Al has closed the Facility. Subsequent to final disking and mulching of the site, drilling of an aggressive dry land pasture seed mix as recommended by the agronomist report was completed on October 23rd. Final drilling activities were monitored and approved by Mr. Pete Salazar. Between October 12 and October 24, Al personnel inspected the site for incidental plastics, rock, etc., and conducted final site cleaning activities. All final grading and clean-up activities at the Facility have been completed. As of October 31 the Facility will be officially closed. Per 6 CCR 1007-2, section 14.8.4 of the CDPHE's rules, Al is required to provide written notification to the CDPHE and the County documenting "that all requirements and conditions of • the closure plan have been achieved" 30 days after closure of the Facility. Within 30 days of closure of the Facility (November 30, 2011) Al will provide the CDPHE and the County with it's final closure evaluation. If the final closure report indicates there are additional remediation measures that are necessary to meet applicable standards, a plan for addressing those needs will be created by Al's engineering/environmental technical services consultant and provided for review and approval by Weld County and CDPHE. However, at this time it is not expected that any additional remediation or closure measures are or will be required at the Facility. Accordingly, Al expects to make by November 30 a final request to the County and CDPHE 1) that no further post closure activities be required at the Facility; 2) a notice of satisfactory completion of closure of the Facility be issued by the CDPHE and Weld County; 3) and that USR 1059 and the related Certificate of Designation for the Facility be vacated. • UDgC. Al Organics Corporate Headquarters: 16350 WCR 76 • Eaton,Colorado 80815 1 Composting V Tel 970-454-3492 • 800-776-1644 • Fax 970-454-3232 ® US Council M Du` Facilities: Eaton•Golden•Greeley•Keenesburg•Stapleton uti Toting ncSeal al �� '• Las Vegas,Nevada -tent.- www.atorganics.com TRAVELERS? • CONTINUATION CERTIFICATE FIDELITY OR SURETY BONDS/POLICIES License No. In consideration of $1,872.00 dollars renewal premium,the term of Bond/Policy No. 103198325 in thi amount of $187,158.00 , issued on behalf of A-1 Organics whose address is 6569 Hwy 93, Golden, CO 80403 in favor of Colorado Department of Public Health and Environment whose address is 4300 Cherry Creek Drive, #5, Denver, CO 80246 Performance Bond for Lost Antlers and in connection with Highway 66 Composting is hereby extended to August 27, 2012 subject to all covenants and conditions of said bond/policy. Tlertificate is designed to extend only the term of the bond/policy. It does not increase the amount which may be payable thereunder. The aggregate liability of the Company under the said bond/policy together with this certificate shall be exactly the same as,and no greater than it would have been, if the said bond/policy had originally been written to expire on the date to which it is now being extended. Signed, sealed and dated August 17, 2011 Travelers Casualty and Surety Company of America By: _ Diane F. Clementson, Attorney-in-Fact • F-58-M(2/95) am,tl� t r ritiets . . 0 c akH.P I ^�1 i .'w� 7, ...r! • 1 . • I I • y r. • •.. • 5 _• t r• s:.-•..• � w_.}�' s �f •IR+i'it '�'[ IRti c. 5-s Yla. t • - • _i �: — •'.IYL0r^.--. y 14....."_•.,"•,•••4:44••• .�.�I•J.•, "`. !, • a -.: J ^ . ^ it 1`I ♦,•,. ��•. 12 •^�Yt. 4,4:Ai, r y 1 ,t-.r' . • ,.•.. • i1� YI{fietr J: w°•t'q,...--.:;.( /. .• ••••••t ,,• a c'4, •t fa•Ve a �•. �r{.'Fi ,' r.i ' ter•., •1 • ' r rt r� re\rte •! 7.' • . i . . 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