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Home My WebLink About20110288.tiff r 1 Weld County Planning Department GREELEY OFFICE r_ .InI 14 •'nhi WASTE MANAGEMENT® RECEIVED WASTE MANAGEMENT 2400 W.Union Ave. Englewood,CO 80110 (303)794-2403 Fax January 10, 2011 Ms. Dana Podell Colorado Department of Public Health and Environment Air Pollution Control Division (APCD-S S-B1) 4300 Cherry Creek Drive South Denver, CO 80246-1530 CERTIFIED MAIL 7001 1940 0001 9919 7998 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, 2010. Should you have any questions regarding the updated information contained in this report, please contact me at 303-914-1427. Sal ly, Jessica Walko Facility Engineer Attachment cc: Troy Swain, WCDPHE Caren Johannes, CDPHE Kim Ogle, WCDPS Bill Hedberg, BRLF tow r' u>,q.) 2011-0288 /-av-aov/ pLogX From everyday collection to environmental protection, Think Green? Think Waste Management. ® p,,',r o,,!9J%psbmsu ,,'cveled pQPn. de 2010 TIER 1 NMOC EMISSION RATE REPORT BUFFALO RIDGE LANDFILL Because the site does not have scales, volume of waste accepted is 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(ekc-e kt)(CNMoc)(3.6 x 10-9) NMOC Emission Rate' 2010 MNMoc = Mass methane generation potential, ma/Mg Lo = Refuse methane generation potential, m3/Mg = 170.00 R = Average annual acceptance rate, Mg/yr = 37,490.87 k = Methane generation rate constant, 1/yr = 0.02 c = Years since closure, yrs = 0.00 (c= 0 for active and/or new landfills) t = Age of landfill, yrs = 8.50 CNMOC = Concentration of NMOC, ppm as hexane = 4,000.00 Conversion factor = 3.6 x 10-9 = 28.70 Mg/yr ' Information used to determine annual average acceptance rate The average annual acceptance rate (R) is based on projected waste in place as of 12/31/10 divided by 8.5 years (age of site at time of volume measurement) less inert material3. Waste in place is tracked monthly by adding monthly waste receipts and subtracting inert material volumes. Periodically these calculations are evaluated against actual airspace used (as measured by completing a flyover of the site and comparing the airspace consumed from the previous flyover to the airspace consumed at the time of the current flyover) and adjusted as necessary. Waste in place(Mg)through 12/31/10 740,066, Waste in place less inert material(Mg) through 12/31/10 318,672 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 for 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 only inert wastes that are disposed in the landfill. Because these figures are obtained from gate receipts, they do not include cover soil used in 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 specdically cautioned against improper and irresonsible uses of these calculations. C:\Documents end 5etnngs\jwalko\My Documents\Buffalo Ridge\Air Pemnt\NMOC Repons\2010\BRL NMOC Report 201O xls RECEIVED 2400 West Union Avenue En®: O 80110 303-914-1445 0 -914-1 4 (Phone) WASTE MANAGEMENT APR 12 Z011 303-914-9937(Fax) Weld County Planning Department GREELEY OFFICE April 7, 2011 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: Enclosed are updated closure/post-closure and financial assurance plans which have been revised to reflect current operations at BRLF and anticipated closure and post-closure activities. Section 1.8.3 (C) of the Colorado Regulations Pertaining to Solid Waste Disposal Sites and Facilities, 6CCR-1007-2, requires an annual adjustment to the closure and post-closure financial assurance cost estimate by using the implicit price deflator(IPD) for the gross domestic product. The IPD for 2011 is 1.009 as confirmed with the Colorado Department of Public Health and Environment. The closure and post-closure cost estimates respectively contained in Appendix A and Appendix B of the enclosed financial assurance plan were adjusted using this value. The insurance certificate contained in Appendix C of the financial assurance plan reflects this adjustment to the referenced cost estimates. The insurance certificate and updated plans have been placed in the facility operating record. Please call me at (303) 914-1445 or Jessica Walko at(303) 914-1427 if you have questions about the enclosures. Sincerely, Tom Schweitzer, P.E. Engineering Manager Enclosures cc: Deborah Blandin, WCDPHE Kim Ogle, WCDPS Douglas Ikenberry, CDPHE Jack Epple/BRLF Operating Record Jessica Walko, Waste Management of Colorado Bill Hedberg, Waste Management of Colorado Julie Overmyer, Waste Management of Colorado, w/o enclosures Donna Meals, Waste Management, w/o enclosures LaTMa/71(a)/CinS /'L d� 4/21)1261/ / C\Documents and Settings\tschweit\My Documents\mydata\FinAssurance1l\BRLF FinAssur TransLtr 201 Ldoc 'p/f_ 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 \\001lmmtio1/4 4O5 tor%f6 ,ta �J 76 Reviewed By: / ;o %°Sta`/ago Thomas S. Schweitzer, PE %FS •°°,.,,s3 / ��.� Registered Professional Engin ��s�0Ng' F ��o° State of Colorado License#24176 Updated March 2011 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 2011 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 ld to be constructed in 2011, and fencing for the expanded asbestos disposal area. Closure/Post Closure Plan ii Updated March 2011 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 2011. 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 2011 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 2011 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 2011 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 210,000 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 3`d party costs for similar fencing at the Denver Arapahoe Disposal Site approximately $10,000 is estimated for removing and replacing approximately 1,800 feet of fencing and gates. With the asbestos area used in 2009 added to the 2010 area and the future 2011 planned area,the total fenced perimeter equals approximately 3,200 linear feet. This equates to approximately$17,300 based on the costs provided. 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 I 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 is pumped approximately every 7 days. The financial assurance has been updated to include closure of the trench system following a total of 3.5 years of operation. Based on the data collected to date, the flow rate is decreasing linearly over time at a rate of 15-16 gallons a month on average with closure in mid-2013. At these estimated rates, pumping of the tank is expected to cost approximately $23,400 as included in the closure cost estimate. This estimate is based on pumping the tank once per week for the next year and every other week for the last year of operation. 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/Post Closure Plan 4 Updated March 2011 Buffalo Ridge Landfill 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 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 32.1 acres in Phase 1, which is 7.1 acres more than the previous estimate because of Phase Id disposal cell construction scheduled for 2011 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 210,000 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 Closure/Post Closure Plan 5 Updated March 2011 Buffalo Ridge Landfill 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 32.1-acre area. 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 Closure/Post Closure Plan 6 Updated March 2011 Buffalo Ridge Landfill 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. 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 2011 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 2011 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 2011 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 2011 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 2011 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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B !d IIOt� �a .n6 �� Raua6��s6p la 1^B\opp ao lo0�.0100� :0 �311l 9tJIMVaO 01 • 5 | al co \ I 2 § ( _ik 2a. � I— k § cokI ) Co 0 k WLUe. ® ; ) \ � k ( I co L _ % k � O \ 2 ] 2 \ 1. 0 E \ | ° | | to § Z Ts o E of 15 2 < O22 7 ± ! ) : & ! tl2Gf : ! - ) t - \ ) ) 0 < W > 0 § \ fizz o ! • FINANCIAL ASSURANCE PLAN BUFFALO RIDGE LANDFILL Weld County, Colorado Prepared by: Waste Management of Colorado, Inc. Buffalo Ridge Landfill 11655 Weld County Road 59 Keenesburg, Colorado 80643 Updated March 2011 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 2011 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. Financial Assurance Plan ii Updated March 2011 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, closure and post- closure cost estimates which are updated from the 2010 estimates. Adjustments for 2011 reflect updates to the dewatering system in Phase lc, addition of future Phase ld to be constructed in 2011, additional fencing for an expanded asbestos area, as well as an inflation factor adjustment. This Plan also describes the financial assurance mechanism in place to ensure payment of all associated closure and post-closure costs. This Financial Assurance Plan is to be used in conjunction with the Closure/Post-Closure Plan as revised March 2011. 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). Cost estimates were last replaced in 2007; therefore, the next replacement of cost estimates is schedule for 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 2011 Buffalo Ridge Landfill • 4. Costs associated with closure, post-closure and corrective actions may be 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 as revised March 2011. The unit cost values for closure and post-closure activities were determined by WMC based on recent projects performed at WMC landfills in Colorado. The unit costs are based on 2007 dollars and inflation adjusted to 2011. The new closure costs are provided in Appendix A, and the new 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 2011 Buffalo Ridge Landfill APPENDIX A CLOSURE COSTS TABLE 1 -CLOSURE COST ESTIMATE Date: March-11 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 210,000 1.85 388,500 minimum 5% slope (on-site source) b Other Foundation Layer Closure Costs 0 Foundation Layer Total Cost 388,500 2 Final Cover Section Closure Area: 32.1 Acres a Compacted Clay Layer(on-site source) CY 0 b Alternative Final Cover(on-site source) CY 90,000 1.85 166,500 c Topsoil (on-site source) CY 26,000 1.85 48,100 d Fertilizer/Soil Amendements/material hauling Acre 32.1 582.00 18,682 e Seeding Acre 32.1 620.00 19,902 f Other Final Cover Closure-Related Costs Acre 0 Final Cover Total Cost 253,184 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 Mntg Wells w/dedicated pumps EA 0 b Gas Monitoring Probes EA 0 c Pumping of temporary trench system tank EA 1 23,400.00 23,400 Environmental Monitoring Total Cost 23,400 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 GasNapor Collection - Header Pipe 0 e GasNapor 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-11 Site: BUFFALO RIDGE LANDFILL Page: 2 Item Description Units Quantity Unit Cost Extended Category (Note 1) Cost Cost 6 Miscellaneous Closure Activities a Access Road Construction 0 b Fencing (asbestos disposal area) 1 17,300.00 17,300 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 42,700 7 CLOSURE COST ESTIMATE SUBTOTAL 707,784 8 Engineering & Project Management a Design & Bid Documents (% of Subtotal) 3% 21,234 b CQA, Surveys & Reports (°/c. of Subtotal) 10% 70,778 c Project Mgmt&Admin (% of Subtotal) 2% 14,156 d Engineering & Project Mgmt Total Cost 106,168 9 Contingency (%of Subtotal) 10% 70,778 10 CLOSURE COST ESTIMATE TOTAL (in 2007 dollars) $884,730 11 Inflation adjustment factor for 2008 1.027 12 Inflation adjustment factor for 2009 1.021 13 Inflation adjustment factor for 2010 1.012 14 Inflation adjustment factor for 2011 1.009 Total Closure Cost(adjusted to 2011 dollars - Line 10 x Lines 11 through 14 $947,281 Notes: 1 All costs include material and installation unless noted otherwise. 2 All surface water control structures given the existing configuration on the landfill subject to final cover have been constructed APPENDIX B POST-CLOSURE CARE COSTS TABLE 2 -POST-CLOSURE COST ESTIMATE Date: March-11 Site: BUFFALO RIDGE LANDFILL Acres at Closure: 32.1 Item Description Units Unit Unit Cost Quantity Cost per Quantity per Year Year la Facility Inspections & Reporting -2 per year EA 1 1,000 2. 2,000 lb Facility Inspections & Reporting -2 addt'l Annual cost for 2 addt'l events= 2,000 events to allow for qtrly inspections first Total Item cost for 2-yr period= 4,000 2 yrs of post-closure. Total Item cost annualized over 30-yr PC period= 133 2 Qualitative Vegetative Assessement-annual EA 1 1,500 1 1,500 3a Cover Maintenance, Reseeding & Fertilizing - AC 5% 1,803 1.6 2,894 5% of site per year(Note 1) 3b Cover Maintenance, Reseeding & Fertilizing - Annual cost for addt'l 5%= 2,894 addt'l 5% per year to allow for 10% of the Total Item cost for 2-yr period= 5,788 site first 2 yrs of post-closure Total Item cost annualized over 30-yr PC period= 193 4 Surface Water Controls - Maintenance LS 1,000 1 1,000 5 Fence Repair LS 500 1 500 6 Mowing -Assume annual mowing for first 10 AC 1 20 32 years of post-closure Annual mowing cost= 642 Cost for 10 mowing events= 6,420 Total Item cost annualized over 30-yr PC period= 214 7 Groundwater Monitoring -Semi-annual events EA _ 11 996 2_ 21,918 8 Groundwater Well Pump Repair/Maintenance LS _ 300 1_ 300 9 Gas Probe Monitoring, Maintenance and EA 10 92 4 3,686 Reporting -4 Events per Year _ _ _ 10 Leachate Monitoring -Annual EA 1 526 1 526 11 Leachate Depth Measurement-Semi-annual _ EA 1 293 2 586 12 Leachate Management- First 5 years of post- Annual cost for leachate mgmt= 5,000 closure (managed on-site) (Note 2) Total Item cost for 5-yr period= 25,000 Total Item cost annualized over 30-yr PC period= 833 13 Gas Collection and Control Syst Maint LS 0 14 Gas Condensate Disposal GAL 0 15 Subtotal - Items 1 through 14 36,284 16 Administrative Costs (% of Subtotal) 5% 1,814 17 Contingency (°/0 of Subtotal) 10% 3,628 18 Total Cost per Year 41,726 19 Post-Closure Care Period: I 30 Years 20 Total Post-Closure Cost(in 2007 dollars) $1,251,783 21 Inflation Adjustment Factor for 2008 1.027 22 Inflation Adjustment Factor for 2009 1.021 23 Inflation Adjustment Factor for 2010 1.012 24 Inflation Adjustment Factor for 2011 1.009 Total Post-Closure Cost (adjusted to 2011 dollars - Line 20 x Lines 21 through 24) $1,340,284 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 a 2011 CLOSURE AND POST-CLOSURE COST ESTIMATES The BRL Financial Assuarance Plan as revised March 2011 includes a closure cost estimate of $947,281 (Appendix A) and a post-closure cost estimate of$1,340,284 (Appendix B) for a combined total estimate of$2,287,565 (2011 dollars). These estimates are based on the site Closure and Post-Closure Plan revised March 2011. The accompanying insurance certificate reflects this adjusted amount. , ACORDTM CERTIFICATE OF LIABILITY INSURANCE DATE (M04/01/2011DN ) 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 LIMITS LTR NSRD TYPE OF INSURANCE DATE IMMIDD/YY1 DATE IMM/DD/YYI GENERAL LIABILITY EACH OCCURRENCE $ DAMAGE TO RENTED COMMERCIAL GENERAL LIABILITY PREMISES(Ea occurence) $ CLAIMS MADE OCCUR MED EXP(Anyone person) $ PERSONAL BADV INJURY $ GENERAL AGGREGATE $ GENII AGGREGATE LIMIT APPLIES PER: PRODUCTS-COMP/OPAGG $ PRO- POLICY JECT LOC AUTOMOBILE LIABILITY COMBINED SINGLE LIMIT ANY AUTO (Ea accident) $ ALL OWNED AUTOS BODILY INJURY SCHEDULED AUTOS (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 $ OCCUR CLAIMS MADE AGGREGATE $ DEDUCTIBLE $ RETENTION $WORKER $ WCSTAN- OTH- EMPLOYSCOMPENSATIONAND TORYIIMITS ER EMPLOYERS'LIABILITY E.L.EACH ACCIDENT ANY PROPRIETOR/PARTNER/EXECUTIVE $ oFFiCER/MEMBER EXCLUDED? E.L.DISEASE-EA EMPLOYEE $ If yes,describe under SPECIAL PROVISIONS below E.L.DISEASE-POLICY LIMIT $ OTHER A Closure CPCS02-0004 4/09/11 4/09/12 $ 947,281.00 Post-Closure $1,340,284.00 DESCRIPTION OF OPERATIONS/LOCATIONS I VEHICLES I EXCLUSIONS ADDED BY ENDORSEMENT/SPECIAL PROVISIONS Buffalo Ridge Landfill, 11655 WCR 59, Keenesburg, CO 80643 This certificate certifies that the policy to which this certificate applies provides closure and/or post-closure care in connection with the Insured's obligation to demonstrate financial responsibility under Section 1.8.9 of the regulations pertaining to Solid Waste Disposal Sites and Facilities 6 CCR 1007-2, as amended. CERTIFICATE HOLDER CANCELLATION Director SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE THE EXPIRATION Colorado Department of Public Health and Environment DATE THEREOF,THE ISSUING INSURER WILL EINDEK/KFtXIA MAIL 120 DAYS WRITTEN Hazardous Materials/Waste Management Division NOTICE TO THE CERTIFICATE HOLDER NAMED TO THE LEFTkUT)ULHRX ib$ASIS➢&HXX 4300 Cherry Creek Drive South IMPflXar®L O xcONu7nm rIOCCURneee.ar uacaxswac Denver, Colorado 80246-1530 BEBBBBetwssi AUTHORIZED REPRESENTATIVE Donna L. Meals,Vice President and Secretary ACORD 25(2001/08) ©ACORD CORPORATION 1988 IMPORTANT If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must be endorsed. A statement on this certificate does not confer rights to the certificate holder in lieu of such endorsement(s). If SUBROGATION IS WAIVED, subject to the terms and conditions of the policy, certain policies may require an endorsement. A statement on this certificate does not confer rights to the certificate holder in lieu of such endorsement(s). DISCLAIMER The Certificate of Insurance on the reverse side of this form does not constitute a contract between the issuing insurer(s), authorized representative or producer, and the certificate holder, nor does it affirmatively or negatively amend, extend or alter the coverage afforded by the policies listed thereon. ACORD 25(2001/08) RECEIVED WASTE MANAGEMENT WASTE MANAGEMENT APR 1 n❑ 2011 2400 W Union Ave. Englewood,CO 80110 April11, 2011 Weld County Planning Department (303) 794-2403 Fax GREELEY OFFICE Ms. Dana Podell Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South CERTIFIED MAIL Denver, CO 80246-1530 7001 1940 0001 9919 8056 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: 04/01/10—03/31/11) • Semi-annual Monitoring and Deviation Report, Parts I, II, and III (Period: 10/01/10 — 03/31/11). 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 303-914-1427 or Tom Schweitzer at 303-914-1445. Sincerely, jig v,fC Jessica Walko Facility Engineer /attachments cc: Douglas Ikenberry, CDPHE, w/enc. Troy Swain, WCDPHE, w/enc. Kim Ogle, WCDPS, w/o enc. Bill Hedberg, WMC, w/enc. ao/,-0a2 0077/710/Cat7 n5 9/Zs/.Wi/ 12-06C2/ From everyday collection to environmental protection, Think Green? Think Waste Management. ®Pnnt¢d an 300%post-<o%umer recycled paper_ RECEIVED WASTE MANAGEMENTm APR 1 `) 2011 WASTE MANAGEMENT 4l@14i 4L Department 2400 W Union Ave. t,til�tt JFFICE Englewood,Co 80110 April 11, 2011 (303) 794-2403 Fax 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 CERTIFIED MAIL 7001 1940 0001 9919 8049 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, 2010 through March 31,2011. Should you have any questions regarding these reports,please contact me at 303-914-1427. Respectfully Yoours,�� LIN Jessica Walko Facility Engineer /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. From everyday collection to environmental protection, Think Green? Think Waste Management. ®Printed on]00%➢meran,umer rerytled paper. WI WASTE MANAGEMENT WASTE MANAGEMENT 1)310 South Valley Highwa Suite 200 April 7, 2006 Englewood,CO 80112.5806 (303)914-1400 03)914.993;Ea. 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) Revised Closure/Post-Closure Plan and Financial Assurance Plan Dear Mr. Johnson: Revised closure/post-closure and financial assurance plans for BRLF are enclosed. These plans were revised to include an increase in the area requiring backfill and in consideration of letters prepared by Mr. Ikenberry dated January 11 and February 13, 2006 regarding North Weld Landfill and a February 8, 2006 meeting between representatives of Colorado Department of Public Health and Environment (CDPHE) and Waste Management. These plans dated March 2006, replace the previous plans that were prepared for the facility. As provided in Appendices A and B of the enclosed financial assurance plan, the 2006 closure and post-closure estimate is $1,326,722 (2002 dollars). Section 1.8.3 (C) of the Colorado Regulations Pertaining to Solid Waste Disposal Sites and Facilities, 6CCR-1007-2, requires an annual adjustment to the closure and post-closure financial assurance cost estimate by using the implicit price deflator(IPD) for the gross domestic product. The IPD for 2006 is 1.028 as confirmed with the Colorado Department of Public Health and Environment. Because the costs in Appendices A and B are based on 2002 dollars, the inflation adjustment must include, in addition to the 2006 adjustment factor,the adjustment factors for 2003, 2004 and 2005, which are 1.011, 1.016, 1.021 respectively. Accordingly, the cost estimate for 2006 is calculated as follows: $1,326,722 x 1.011 x 1.016 x 1.021 x 1.028 =$1,430,355 The enclosed insurance certificate reflects this adjustment to the BRLF financial assurance cost estimate. The updated plans and certificate have been placed in the facility operating record. C.\Documents and Settings\tschweit\My Documents\mydata\FinAssurance06\l3RL Transmtl Ltr 06.doc /7/ (1fc/ • • Letter Charles Johnson April 7, 2006 Page 2 Please call Alan Scheere at (720) 977-2107 or me at (303) 914-1445 if you have questions concerning the adjustment to the NWLF financial assurance. Sincerely, Tom Schweitzer, P.E. Environmental Engineer Enclosure cc: Douglas Ikenberry, CDPHE Troy Swain, WCDPHE Kim Ogle, WCDPS (w/o end) Bill Hedberg, Waste Management Jack Epple/BRLF Operating Record(2 copies) Alan Scheere, Waste Management Robert Sheehan, Waste Management (w/o end) US2.- °i& p 2400 West Union Avenue P. "�" VED Englewood,CO 80110 �' '&I. 303-914-1427(Phone) WASTE MANAGEMENT 877-331-0444(Fax) OCT 1 R 2011 Weld County ramrng Department GREELEY OFFICE October 11, 2011 Mrs. Dana Podell Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Hand Delivered SUBJECT: BUFFALO RIDGE LANDFILL (BRLF) TITLE V OPERATING PERMIT 2011 SEMI-ANNUAL MONITORING REPORTS Dear Mrs. Podell: In accordance with the BRLF Title V Operating Permit # 03OPWE260, attached are the following reports covering the monitoring period of April 1, 2011 —September 30, 2011. • Monitoring and Permit Deviation Reports, Part I • Monitoring and Permit Deviation Reports, Part III. Part II of the Monitoring and Permit Deviation Report was not completed because there were no permit deviations, upset or emergency conditions that occurred during this reporting period. Should you have any questions regarding these reports, please contact me at 303-914-1427 or Tom Schweitzer at 303-914- 1445. Sincerely,3J Jessica Walko Facility Engineer /attachments cc: Jim King, CDPHE APCD, w/enc. Douglas Ikenberry, CDPHE, w/enc. Troy Swain, WCDPHE, w/enc. Kim Ogle, WCDPS, w/o enc. Bill Hedberg, WMC,w/enc. 0 cswuvuA,c5/Cot/Unto) 2o//-Ocz Io-ay-c2O ( 1 pLoV C Aqu ktri er opt ,m z ng 7430 E. Caley Avenue, Ste 310 . Centennial, CO 80111 . Phone (303) 771-9150 - Fax (303) 771-8776 October 25,2011 113314 Mr.Doug Ikenberry RECEIVED Colorado Department of Public Health and Environment Hazardous Materials and Waste Management Division OCT 31 7011 HMWMD-SWIM-B2 4300 Cherry Creek Drive South Weld eau',., ut:pariagoit Denver,Colorado 80246-1530 C,13k.t Cr_,1 oi-r 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 2011 Groundwater Monitoring Report Dear Mr. Ikenberry and Mr. Swain: - On behalf of Waste Management Disposal Services of Colorado, Inc., AquAeTer, Inc submits the first half 2011 groundwater detection monitoring results for the Buffalo Ridge Landfill (BRLF), in Keenesburg, Colorado. Regular semi-annual detection groundwater monitoring was completed in May 2011 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 2011 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 (revised December 30, 2008). 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 Ms.Jessica Walko at(303)914-1427 or Mr. Bill Hedberg at(970)686-2800. Sincerely, AquAeTer,Inc. n Terra Plute,E.I. Gtt5 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,w/enc. Ms.Jessica Walko, Waste Management,w/enc. &VI I — (); .512 U omm.ux)i 94.1-t.,- �v.,, II -7- 2O( i Pi-03E 4 4. NOV 0 i 1011 Pict, ',7, ii Di) Lment STATE OF COLORADO John W. Hickenlooper,Governor oe-co� Christopher E. Urbina,MD,MPH .of °R Executive Director and Chief Medical Officer 0 Dedicated to protecting and improving the health and environment of the people of Colorado * * « 'P 4300 Cherry Creek Dr.S. Laboratory Services Division .1876 Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health http://www.cdphe.state.co.us and Environment November 1, 2011 Ms. Jessica Walko, P.E. Waste Management 2400 W. Union Ave. Englewood, CO 80110 RE: Comments regarding Buffalo Ridge Landfill (BRLF) Leachate Management Plan (dated July 2010) and accompanying Waste Management cover letter dated July 6, 2010 Dear Ms. Walko, 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 your cover letter dated July 6, 2010. Based on our review the Division offers the following comments regarding the content of the July 6, 2010 letter and for incorporation into a revised leachate management plan, as applicable: July 6, 2010 letter: 1) Page 2, 3rd 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 IA 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. LdflAdvultllter'lLflU/ ,)b11—wag i� zr- I/ 1L028( Ms. Jessica Walko November 1, 2011 Page 2 of 3 Leachate Management Plan (dated July 2010) 2) Page 1, 1s' 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. 3) Page 1, 1st 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 Operation Plan (revised December 10, 1992) and are not considered essential to the leachate management plan. Omit the sentence. 4) Page I, 2nd 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. However, the Division recommends that the Leachate Management Plan include monitoring and reporting requirements regarding the amount of leachate pumped from the sump(s). Please incorporate this concept into comment number 10 below, as appropriate. 5) Page 1, 3r° par. — Change the text to read, "The management method to be implemented at the Buffalo Ridge Landfill includes the following:" 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. 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 1A 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." Ms. Jessica Walko November 1, 2011 Page 3 of 3 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 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." 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." 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." The Division's comments regarding the above referenced documentation do not necessarily reflect the position of Weld County, which must approve amendments to the certificate of designation, USR and EDOP. 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, (51A414)142\-2(Ley'lleAmr 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 FILE: SW WLD BRL 2.2 Hello