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Home My WebLink About20100823.tiff W�® 2400 West Union Avenue Englewood,Co 80110 303-914-1445(Phone) WASTE MANAGEMENT 303-914-9937(Fax) April 7, 2010 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: North Weld Landfill (NWLF) Updated Closure and 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 NWLF 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 IDP for 2010 is 1.012 as confirmed with CDPHE. 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 if you have questions about the enclosures. Sincerely, TomSweitzer, P.E. Engineering Manager Enclosures cc: Troy Swain, WCDPHE Kim Ogle, WCDPS Douglas Ikenberry, CDPHE Bill Hedberg/NWLF Operating Record Julie Overmyer, Waste Management of Colorado, w/o enclosure 2010-0823 Cotitou.L\ieatcw 4—(O—,;'z''lo C:\Documents and Settings\tschweit\My Documents\mydata\FinAssurance10\NWLF FinAssur TransLtr 10 Finaidoc nLO77 7 CLOSURE/POST-CLOSURE PLAN NORTH WELD LANDFILL Weld County, Colorado Prepared by: Waste Management Disposal Services of Colorado, Inc. North Weld Landfill 40,000 Weld County Road 25 Ault, Colorado Cs •• TIMe>11, T1/403 24176 Reviewed By: c_v, , m Thomas S. Schweitzer, PE VII' °f�• •'4`"� Registered Professional Engin 79/0 State of Colorado rowa wu"'�` License#24176 Revised March 2010 CLOSURE/POST-CLOSURE PLAN NORTH WELD LANDFILL TABLE OF CONTENTS Section tam 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 4 2.4 FINAL COVER 4 2.4.1 Final Grades 4 2.4.2 Final Cover Description 4 2.5 CONSTRUCTION 5 2.6 CONSTRUCTION QUALITY ASSURANCE(CQA) 5 2.7 CLOSURE SCHEDULE 6 3.0 POST-CLOSURE PLAN 7 3.1 INTRODUCTION 7 3.1.1 Description 7 3.1.2 End Use 7 3.1.3 Regulatory Requirements 7 3.2 POST-CLOSURE ACTIVITIES 8 3.2.1 Facility Management 8 3.2.2 Post-Closure Activities 8 LIST OF FIGURES Figure 1 Site Location Map 2 Closure Area Map 3 Backfill Area Map 4 Post-Closure Drainage Channel 5 Closure Schedule Closure/Post Closure Plan March 2010 North Weld Landfill CLOSURE/POST-CLOSURE PLAN NORTH WELD LANDFILL REVISION LOG DATE DESCRIPTION OF REVISION BY 4/97 Update Plan originally submitted to CDPHE 10/93, to reflect operational TS/AS changes 3/01 Update Plan to increase estimate of largest area of the landfill ever TS/AS requiring final cover during the active life 4/03 Update Plan to increase estimate of largest area of the landfill ever TS/AS requiring final cover during the active life 3/05 Update Plan to increase estimate of largest area of the landfill ever TS/AS requiring final cover during the active life and modify text in Sections 2.4, 2.5 and 2.6 to reflect approval of an alternative final cover design 3/06 Updated Plan to decrease estimate of largest area of the landfill requiring TS/AS final cover during the active life. Miscellaneous text changes were also made to the Plan. 3/07 Updated Plan to reflect changes to the corresponding Financial Assurance TS/AS Plan dated March 2007 specifically replacing cost estimates prepared in 2002 with new cost estimates; updated Plan to adjust estimate of largest area of the landfill requiring final cover during the active life; update soil backfill quantities. Miscellaneous text changes were also made to the Plan. 3/09 Updated Plan to adjust estimate of largest area of the landfill requiring TS/AS final cover during the active life; update soil backfill quantities; included drawing illustrating surface water control structures that remain to be constructed and areas requiring backfill to achieve 5% slope. 3/10 Updated Plan to adjust estimate of largest area of the landfill requiring TS final cover during the active life; updated soil backfill quantities to achieve 5% slope; updated post-closure acreage. Closure/Post Closure Plan hi March 2010 North Weld Landfill 1.0 INTRODUCTION 1.1 PURPOSE This Closure/Post-Closure Plan (Plan) for the North Weld Landfill (NWLF)reflects the facility's present understanding of closure and post-closure care requirements for this solid waste disposal site. It 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 NWLF revised March 2010. 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 NWLF is located approximately six miles west of Highway 85, on Colorado Highway 14, in the southwest quarter of Section 7, Township 7 North, Range 66 West, as shown on Figure 1. The facility is owned and operated by Waste Management of Colorado (WMC). The site consists of 170 acres, 119 of which are permitted for municipal solid waste disposal, and an approximate disposal capacity of 15 million bank cubic yards. Current operations are in Phase 2, Module 4. The facility accepts non-hazardous municipal, commercial and industrial solid wastes. NWLF will be developed in four phases: 1, 2, 3A and 3B. 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 March 2010 North Weld Landfill 2.0 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 Activities 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 March 2010 North Weld 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—Closure construction plans will be prepared as needed. 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 detail in Section 2.3 of this Plan. 5. Completion of Closure - Closure activities will be completed within 180 days following closure. A request for an extension may be submitted to CDPHE if climatic or operational factors dictate that additional time is required for proper closure. Closure/Post Closure Plan 3 March 2010 North Weld Landfill 6. 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 for approval after consultation with the local governing board. The approved report 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. 7. 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 currently requiring final cover is about 67 acres in Phases 1, 2 and 3A as shown in Figure 2. The estimated 67 acre closure area is based on the facility's current disposal activities, a 6.5 acre disposal cell in Phase 3A to be constructed in 2010, and less 16 acres of final cover completed in 2006. The estimated closure area is also based on the facility's projected disposal activities over a five year period. Section 1.8.3(D) of the Regulations requires the closure and post-closure cost estimates to be recalculated every five years unless otherwise required by CDPHE. The last recalculation was performed in 2007 and the associated cost estimates are included in the corresponding Financial Assurance Plan, inflation adjusted to 2010 dollars. The next replacement of cost estimates is scheduled for 2012. 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 250,000 cubic yards of on- site soils are estimated for achieving minimal slopes prior to placement of final cover. Figure 3 shows the area of backfill needed to achieve 5% slopes. 2.4.2 Final Cover Description NWLF received approval from CDPHE and Weld County Department of Public Health and Environment(WCDPHE) for an alternative final cover(AFC) design on March 30, 2004 Closure/Post Closure Plan 4 March 2010 North Weld Landfill and September 3, 2004 respectively. The AFC components are described below. 1. Alternative Final Cover Layer- The AFC layer will consist of a minimum of 18 inches of slightly compacted soil from on-site sources. AFC thickness on the side slope will be increased to 20 inches in accordance with the AFC design. The AFC components should have no less than 15% fines content and be compacted to between 80%to 90% of maximum density as determined by Standard Proctor (ASTM D 698). Approximately 171,500 cubic yards of soil will be necessary for the AFC layer. This assumes an average 19-inch AFC layer will be installed over the 67 - 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"North Weld Landfill Alternative Final Cover Demonstration"prepared by Golder Associates dated December 30, 2003. Approximately 54,500 cubic yards of soil will be required for the topsoil layer over the 67-acre area. 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 North Weld 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; Closure/Post Closure Plan 5 March 2010 North Weld Landfill • 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 approximately 100 feet on-center. A design drawing showing the area of AFC to be built and a detail of the cover cross- section will be supplied to the CDPHE and WCDPHE prior to construction. Also, an as- built construction drawing will be provided with the certification report that shows the survey points used to verify thickness on the approximately 100 feet on-center grid pattern. 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 5. 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 6 March 2010 North Weld 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 manage run-on and run-off from a 100 year, 24-hour storm event. Figure 4 Closure/Post Closure Plan 7 March 2010 North Weld Landfill • shows the general location of permanent stormwater channels anticipated to be constructed as part of closure activities. 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 notification will be submitted to CDPHE with a certification signed by an independent Colorado Registered Professional Engineer or approved by the CDPHE and the local governing body having jurisdiction verifying that post-closure care has been completed in accordance with the post-closure plan. The notification will be placed in the operating record. 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. William Hedberg North Weld Sanitary Landfill 40,000 WCR 25 Ault, Colorado (970) 686-2800 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 site will 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 Closure/Post Closure Plan 8 March 2010 North Weld Landfill 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 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,NWLF will conduct a qualitative vegetation assessment annually during post-closure to ensure the vegetative cover is established and assist in identifying any areas that may require attention. 4. Groundwater Monitoring - The current groundwater monitoring program consists of 5 wells, which will be monitored in accordance with the Site Specific Groundwater Monitoring Plan (GWMP). Depending on the monitoring 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 listed in the Groundwater Management Plan. The results of all analysis 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 9 March 2010 North Weld 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 in the leachate collection sumps will be monitored semi-annually to verify the levels are 1 ft or less above the base 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. Due to the arid climate leachate generation is not expected at closure. Nevertheless, during the post-closure period, an allowance for leachate management is provided for the first 5 years of post-closure in the event of premature closure. A demonstration may be made to the CDPHE showing that the leachate no longer poses a threat to human health and the environment and that monitoring can cease. 6. Gas Monitoring- The facility will continue to monitor gas at the site quarterly in accordance with the Landfill Gas Migration Monitoring Plan(LGMMP). The post- closure cost estimate assumes the 15 gas monitoring probes (currently in the program) 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 of the stormwater system will be performed. Inspections of permanent stormwater management structures will be performed following storm events exceeding the 100 year, 24 hour storm event. 8. Waste Disposal - Off-site refuse will not be accepted during the post-closure period. However, if during post-closure repairs,previously placed refuse is Closure/Post Closure Plan 10 March 2010 North Weld Landfill 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 locked when not in use. Signs will be posted warning of unauthorized entry. The integrity of the fence will be monitored and maintenance performed as necessary. 10. Certification - At the completion of the post-closure care period, a notification will be submitted to CDPHE with a certification signed by an independent Colorado Registered Professional Engineer or approved by the CDPHE and the local governing body having jurisdiction verifying that post-closure care has been completed in accordance with the post-closure plan. The notification will be placed in the operating record. Closure/Post Closure Plan 11 March 2010 North Weld Landfill FIGURES i C a ■■��'' - I ' ti iiik It 14 ILI wz,14.... llimml w=ii 4 .0, . _„„.„, Att... .4. 1 ion V ra., ,, _ ‘ . 0 ___,_0 . t i , ‘ , ■■�_��■ ;�:v A _ ‘11■■ 2 ramma... ■r am. 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' ti e Dann. 3o to yea =,nau ia .e� .=v=i a .5°. .50i 010tz P5.5°11,555°5 w 1 0i43:. a.5. eu_,oii. x..a, 1 e i. I =�=er�f uMX� l - n ]'3w 9x.MVMo fa C 2 e in co co \ I ) ) % ) I ot k ) iix _ ® -I � ': 1 gf /; kI Ca t ; CI\ wkra 5 ( Elf \ � S ) � 2 2 27 \ ' ' ` O 0 li2 0 Lv ) Er 0 ( f to iii : E f § °to o k ) ) ) ; k \ /o ! { # \ ! / $ k ) ) \ - { # \ kk / > o ° \ \ \ z ! \ 3 FINANCIAL ASSURANCE PLAN NORTH WELD LANDFILL Weld County, Colorado Prepared by: Waste Management Disposal Services of Colorado, Inc. North Weld Landfill 40,000 Weld County Road 25 Ault, Colorado Revised March 2010 FINANCIAL ASSURANCE PLAN NORTH WELD 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 i March 2010 North Weld Landfill FINANCIAL ASSURANCE PLAN NORTH WELD LANDFILL REVISION LOG DATE DESCRIPTION OF REVISION BY 4/99 Replaced letter of credit with insurance certificate. TS 3/01 Revise financial assurance costs based on the revised closure and post- TS/AS closure plan dated March 2001. 5/02 Replace original engineering cost estimates of closure and post-closure TS/AS based on 2002 CDPHE guidance or determined by NWSL 4/03 Revise financial assurance costs based on the revised closure and post- TS/AS closure plan dated April 2003. 3/05 Revise financial assurance costs based on the revised closure and post- TS/AS closure plan dated March 2005 3/06 Revised financial assurance costs based on the revised closure and post- TS/AS closure plan dated March 2006. 3/07 Replace cost estimates of closure and post-closure prepared in 2002 with TS/AS 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 Revised financial assurance costs based on the revised closure and post- TS/AS closure plan dated March 2009. 3/10 Revised financial assurance costs based on the revised closure and post- TS closure plan dated March 2010. Financial Assurance Plan ii March 2010 North Weld 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 North Weld Landfill (NWLF) in Ault, Colorado. This Plan includes, in Appendices A and B, closure and post-closure cost estimates which are updated from 2009. The Regulations require that cost estimates be replaced every five (5) years or as otherwise required by the Colorado Department of Public Health and Environment (CDPHE) and 2007 marks the most recent year that costs were replaced. The next replacement of cost estimates is scheduled for 2012. Adjustments for 2010 reflect changes in the closure area subsequent to the 2009 Plan. This Plan also describes the financial assurance mechanism in place to ensure payment of all associated closure and post-closure costs. This Plan is to be used in conjunction with the NWLF Closure/Post Closure Plan dated March 2010. 2.0 REGULATORY REQUIREMENTS 2.1 Cost Estimates Sections 1.8 of the Regulations list 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 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 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 March 2010 North Weld 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. The unit cost values for closure and post-closure activities were determined by WMC. Costs for items including earthwork, excavation and soil placement, were taken from recent bids for similar work completed at Waste Management construction projects. The updated closure costs are provided in Appendix A, and the new post-closure costs are provided in Appendix B. The costs are based on 2007 dollars and inflation adjusted to 2009. 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 March 2010 North Weld Landfill APPENDIX A CLOSURE COSTS TABLE 1 -CLOSURE COST ESTIMATE Date: March-10 Site: NORTH WELD LANDFILL Page: 1 Unit Cost Extended category Item Description Units Quantity (Note t) Cost Cost 1 Foundation Layer a Backfill of intermediate grades to achieve CY 250,000 1.85 462,500 minimum 5% slope (on-site source) b Other Foundation Layer Closure Costs 0 Foundation Layer Total Cost 462,500 2 Final Cover Section Closure Area: 67.0 Acres a Compacted Clay Layer(on-site source) CY 0 b Alternative Final Cover (on-site source) CY 171,500 1.85 317,275 c Topsoil (on-site source) CY 54,500 1.85 100,825 d Fertilizer/Soil Amendements/material hauling Acre 67.0 834.00 55,878 e Seeding Acre 67.0 620.00 41,540 f Other Final Cover Closure-Related Costs Acre 0 Final Cover Total Cost 515,518 3 Surface Water Controls a Drainage Swales/Berms/Channels LF 3,400 7.45 25,330 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 25,330 4 Environmental Monitoring Installations a Grndwtr Mntg Wells w/dedicated pumps EA 0 b Gas Monitoring Probes EA 0 c Other Env. Monitoring Closure Costs 0 Environmental Monitoring Total Cost 0 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-10 Site: NORTH WELD LANDFILL Page: 2 Unit Cost Extended Category Item Description Units Quantity (Note ) Cost Cost 6 Miscellaneous Closure Activities a Access Road Construction 0 b Fencing 0 c Signs EA 2 150.00 300 d Other Miscellaneous Closure-Related Items 0 Miscellaneous Total Cost 300 7 CLOSURE COST ESTIMATE SUBTOTAL 1,003,648 8 Engineering & Project Management a Design & Bid Documents (% of Subtotal) 3% 30,109 b CQA, Surveys& Reports (% of Subtotal) 10% 100,365 c Project Mgmt&Admin (% of Subtotal) 2% 20,073 Engineering & Project Mgmt Total Cost 150,547 9 Contingency (% of Subtotal) 10% 100,365 10 CLOSURE COST ESTIMATE TOTAL (in 2007 dollars) $1,254,560 11 Inflation Adjustment Factor for 2008 (1.027) 1.027 12 Inflation Adjustment Factor for 2009 (1.021) 1.021 13 Inflation Adjustment Factor for 2010 (1.012) 1.012 Total Closure Cost(adjusted to 2010 dollars - Line 10 x Lines 11 through 13) $1,331,276 Notes: 1 All costs include material and installation unless noted otherwise. APPENDIX B POST-CLOSURE CARE COSTS TABLE 2-POST-CLOSURE COST ESTIMATE Date: March-10 Site: NORTH WELD LANDFILL Acres at Closure: 83 Unit Quantity Cost per Item Description Units Unit Cost Quantity per Year Year 1a Facility Inspections&Reporting-2 per year EA 1 1,000 2 2,000 1 b 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% 2,181 4.2 9,051 5%of site per year(Note 1) 3b Cover Maintenance, Reseeding&Fertilizing- Annual cost for addtl 5%= 9,051 addt'l 5%per year to allow for 10%of the Total Item cost for 2-yr period= 18,102 site first 2 yrs of post-closure Total Item cost annualized over 30-yr Pc period= 603 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 83 years of post-closure Annual mowing cost= 1,660 Cost for 10 mowing events= 16,600 Total Item cost annualized over 30-yr PC period= 553 7 Groundwater Monitoring-Semi-annual events EA 5 1,111 2 11,110 8 Groundwater Well Pump Repair/Maintenance LS 300 1 300 9 Gas Probe Monitoring, Maintenance and EA 15 92 4 5,520 Reporting-4 Events per Year 10 Leachate Monitoring-Annual EA 3 461 1 1,383 11 Leachate Depth Measurement-Semi-annual EA 3 237 2 1,422 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 35,910 16 Administrative Costs(°/0 of Subtotal) 5% 1,795 17 Contingency(%of Subtotal) 10% 3,591 18 Total Cost per Year 41,296 19 Post-Closure Care Period: 30 Years 20 Total Post-Closure Cost(in 2007 dollars) $1,238,880 21 Inflation Adjustment Factor for 2008(1.027) 1.027 22 Inflation Adjustment Factor for 2009(1.021) 1.021 23 Inflation Adjustment Factor for 2010(1.012) 1.012 Total Post-Closure Cost(adjusted to 2010 dollars-Line 20 x Lines 21 through 23) $1,314,637 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. Basis for Costs Line 1 a $1,000 based on 9 hrs for site inspector @$70/hr and 3 hrs for report preparation @$120/hr 2 $1.500 vegetation assessement based on actual 2007 3rd party costs for this service 3a $1.803 based on Table 1,Line 2d and 2e values increased by a factor of 1.5 4&5 Estimated values 6 $20/acre mowing cost based on 3rd party bid submitted to DADS 7 Based on actual 3rd party sampling and lab costs 8 Estimated value 9 Based on representative 3rd party costs from other Colorado WM landfills 10 Based on actual 3rd party sampling costs 11 Based on actual 3rd party costs APPENDIX C INSURANCE CERTIFICATE FOR CLOSURE AND POST-CLOSURE CARE COSTS ANNUAL ADJUSTMENT TO CLOSURE AND POST-CLOSURE COST ESTIMATES The NWSL Financial Assuarance Plan as revised March 2010 includes a closure cost estimate of $1,331,276 (Appendix A) and a post-closure cost estimate of$1,314,637 (Appendix B) for a combined total estimate of$2,645,913. These estimates are based on the site Closure and Post- Closure Plan revised March 2010. These estimates are based on 2007 dollars, inflation adjusted to 2010 dollars. The accompanying insurance certificate reflects this adjusted amount. ACORD„ CERTIFICATE OF LIABILITY INSURANCE °04/01/2o 0' 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 Disposal Services 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 IMM/DD/TYI DATE IMM/ODM"1 GENERAL LIABILITY EACH OCCURRENCE $ DAMAGE TO RENTED COMMERCIAL GENERAL LIABILITY PREMISES(Ea occurence) $ CLAIMS MADE OCCUR MEDEXP(Any one person) $ PERSONAL&ADV INJURY $ GENERAL AGGREGATE $ GEN'L AGGREGATE LIMIT APPLIES PER: PRODUCTS-COMP/OP AGG $ PRO- POLICY n LOC ECT 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 $ $ WC STATU- 0R- EMPLOYERS'LIABILITY ON AND TORY LIMITS 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 I$ OTHER A Closure CPCS99-0013 4/09/10 4/09/11 $1,331,276.00 Post-Closure $1,314,637.00 DESCRIPTION OF OPERATIONS/LOCATIONS/VEHICLES/EXCLUSIONS ADDED BY ENDORSEMENT I SPECIAL PROVISIONS North Weld Sanitary Landfill,40000 Weld County Road 25, Ault, CO 80610 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 KBEEICYNSXM MAIL 120 DAYS WRITTEN Hazardous Materials/Waste Management Division NOTICE TO THE CERTIFICATE HOLDER NAMED TO THE LEFT,goaxesantamormacao 4300 Cherry Creek Drive South @B��MtSBgffiC4L�0@1E46@9R Denver, Colorado 80246-1530 XIIIERINNUMWDMIX AUTHORIZED REPRESENTATIVE Donna L. Meals, Vice President and Secretary ACORD 25(2001108) ©ACORD CORPORATION 1981 Hello