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Home My WebLink About20102380.tiff W x Wald County Planning Department GREELEY OFFICE WASTE MANAGEMENT WASTE MANAGEMENT OF COLORAI AUG 3 MT 5500 South Quebec Street Suite250 August 26, 2010RECEIVED" Greenwood Village,CO 30111 '303) 486-6000 1303) 797-3031 Fax Ms. Marley Shoaf Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Sent via FED EX SUBJECT: NORTH WELD LANDFILL (NWLF) TITLE V OPERATING PERMIT 2010 SEMI-ANNUAL MONITORING REPORTS Dear Ms. Shoat: In accordance with the NWLF Title V Operating Permit# 97OPWE181, attached are the Monitoring and Deviation Reports covering the period of October 1,2009—March 31,2010. This certification report was to be submitted on May 1, 2010. An assumption was made that the certifications provided in the NWLF Title V Operating Permit Renewal Application, which was submitted to the Colorado Department of Public Health and Environment on April 28, 2010, fulfilled the semi-annual reporting requirement. Although the Title V application addresses certain requirements of the semi-annual report, on further review, it does not cover all aspects of the semi-annual report. We apologize for this oversight. In addition,the responsible official has changed from Mr. Steve Derus, Director of Landfill Operations to Mr. Scott Bradley, Area Vice President. Should you have any questions regarding these reports, please contact Tom Schweitzer at (303) 914-1445, Bill Hedberg at (970) 686-2800 ext. 23, or myself at (303) 486-6034. Sincerely, ei Bruce Clabaugh, M.S., R.S. Environmental Protection /attachments cc: Dana Podell,CDPHE APCD, w/enc. Jim King, CDPHE APCD,w/enc. Douglas Ikenberry, CDPHE, w/enc. Troy Swain, WCDPHE, w/enc. Kim Ogle, WCDPS, w/o enc. /O_ aD -dD/d 0,90/0—0738( From everyday collection to environmental protection, Think Green.® Think Waste Managemm/en/t..X p '�a m.ao„00%�.,n-o.a,me„:oaea vae= / L.CJ"G� Weld County Planning Department a GREELEY OFFICE WASTE MANAGEMENT AUG 3 07mn WASTE MANAGEMENT OF COLORA 5500 South Quebec Street RECEIVED Suite250 August 26, 2010 Greenwood Village,CO 80111 (303) 486-6000 303) 797-3031 Fax Ms. Cindy Beeler, Environmental Engineer Office of Enforcement, Compliance and Environmental Justice Mail Code 8 ENF-T U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 Sent via FED EX SUBJECT: NORTH WELD LANDFILL(NWLF) TITLE V OPERATING PERMIT NUMBER 97OPWE181 2010 ANNUAL COMPLIANCE CERTIFICATION REPORT Dear Ms. Beeler: In accordance with the NWLF Title V Operating Permit# 97OPWE181,enclosed is the 2010 Annual Compliance Certification Report, which covers the period April 1, 2009 through March 31,2010. This certification report was to be submitted on May 1,2010. An assumption was made that the certifications provided in the NWLF Title V Operating Permit Renewal Application,which was submitted to the Colorado Department of Public Health and Environment on April 28, 2010, fulfilled the annual reporting requirement. Although the Title V application addresses certain requirements of the annual report, on further review, it does not cover all aspects of the annual report. We apologize for this oversight. In addition, the responsible official has changed from Mr. Steve Derus,Director of Landfill Operations to Mr. Scott Bradley,Area Vice President. Should you have any questions regarding this report, please contact Tom Schweitzer at(303)914-1445,Bill Hedberg at(970) 686-2800 ext. 23, or myself at(303) 486-6034. Sincerely, i Vk` fte- C Gi/LY?cc i Bruce Clabaugh, M.S., R.S. Manager, Environmental Protection /attachment cc: Douglas Ikenberry, CDPHE, w/enc. Troy Swain, WCDPHE, w/enc. Kim Ogle, WCDPS,w/o enc. Dana Podell, CDPHE, w/o enc. From everyday collection to environmental protection, Think Green.® Think Waste Management. vn:m o Boas vos-e,m., .a�.e vov=,. AquAeTer o1�tmizrirrnk 7430 E. Caley Avenue, Ste 310 . Centennial, CO 80111 . Phone (303) 771-9150 = Fax (303) 771-8776 August 25, 2010 103228 Ms. Caren Johannes Wald County Planning Department Colorado Department of Public Health and Environment GREELEY OFFICE Hazardous Materials and Waste Management Division AUG 3 07010 HMWMD-SWIM-B2 4300 Cherry Creek Drive South RECEIVED Denver,Colorado 80246-1530 Mr. Troy Swain Weld County Department of Public Health and Environment 1555 N. 17th Avenue Greeley, Colorado 80631 RE: Buffalo Ridge Landfill,Keenesburg, Colorado 2010 Updated Monitoring and Reporting Plan Dear Ms. Johannes and Mr. Swain: On behalf of Waste Management Disposal Services of Colorado, Inc., please find enclosed the 2010 Updated Monitoring and Reporting Plan (M&RP) for the Buffalo Ridge Landfill (BRLF), in Keenesburg, Colorado. The 1992 Ground Water Monitoring Plan (GWMP) for BRLF was approved by the Colorado Department of Public Health and Environment (CDPHE) and Weld County Department of Public Health and Environment (WCDPHE) as part of the approved Design and Operations Plan (D&O Plan) dated December 10, 1992. Waste Management of Colorado, Inc. (WMC) developed this 2010 M&RP to maintain monitoring program consistency with standard industry practices, while maintaining compliance with updated Colorado 6 CCR 1007-2, Regulations Pertaining to Solid and Industrial Waste Disposal Sites and Facilities [March, 2010]. This 2010 M&RP will be incorporated, by reference, into the D&O Plan and will be amended pending comments received from CDPHE or WCDPHE. The 2010 M&RP incorporates the following new or revised major elements. • Section 3.1.2.2, Procedure for Establishing a Site-Specific Detection Monitoring Parameter List - presents the method developed by WMC in conjunction with CDPHE that can be used to propose modification of the monitoring parameter list for the facility. • Section 3.2, Groundwater Monitoring Network - presents a modification to the existing 11-well monitor well network based on BRLF hydrogeologic conditions pLv f Caren Johannes,Colorado Department of Public Health and Environment 103288 August 25,2010 Page 2 and landfill development plans. Under the 2010 M&RP, groundwater level and flow monitoring will continue at all 11 wells, and detection monitoring will be performed at five wells. One well is up-gradient of the landfill (i.e., MW-03), and four are down-gradient Point of Compliance (POC) wells (i.e., MW-02, MW-04, MW-05, and MW-06). Two additional down-gradient POC wells will be added to the detection monitoring well network (i.e., MW-07 and MW-08) in the future. Therefore, the final detection monitoring well network for BRLF will consist of six down-gradient POC wells and one up-gradient well. No additional up- gradient monitoring wells are proposed at this time. Detection monitoring at MW-07 and MW-08 will begin at least one year in advance of landfilling up-gradient of each well. As such, data collected previously from these wells are considered background for purposes of future groundwater data quality evaluations. These two wells will recommence semi- annual monitoring at least one year prior to waste being placed in a new landfill phase in order to update and complete the pre-waste background dataset. Semi- annual monitoring after waste placement begins will start detection monitoring (and associated statistical analysis of data) to comply with groundwater detection monitoring requirements. • Section 3.3.1, Detection Verification Procedure - clarifies that the response to a Statistically Significant Increase above background (SSI) for one or more inorganic constituent(s) will be to perform verification re-sampling during the next regularly scheduled semi-annual groundwater detection monitoring event. The response to an SSI for one or more organic constituent(s) will be to complete verification re-sampling within 45 days of receipt of the final laboratory report, unless BRLF successfully petitions CDPHE to postpone re-sampling until the next regularly scheduled semi-annual detection monitoring event. • Section 3.3.2, VOC Detection Evaluation - describes that Volatile Organic Compounds (VOCs) will be compared to laboratory-specific Practical Quantification Limits (PQLs). Since VOCs are not anticipated to be naturally- occurring at any well location, the PQL will serve as the non-parametric prediction limit (NPPL) and be the basis of the statistical comparison. Therefore, a SSI for a VOC would be reported when an initial exceedance of a PQL is confirmed by verification re-sampling. • Section 3.3, Detection Monitoring Data Evaluation - describes the statistical program DUMPStat® as the tool that will be used to perform the statistical evaluations of inorganic detection monitoring parameters. If there is evidence that the source of a SSI is not landfill related for an inorganic or VOC parameter, this evidence will be presented in an Alternative Source Demonstration (ASD) that will be submitted for CDPHE approval requesting continuance of detection monitoring. The approach for conducting an ASD is presented in this Section. Caren Johannes,Colorado Department of Public Health and Environment 103288 August 25,2010 Page 3 • Section 3.4, Assessment Monitoring - describes the commencement of assessment monitoring within 90 days after a SSI is identified, unless an ASD was submitted and approved by CDPHE. • Section 3.6.4, Well Purging - includes an updated description of low-flow purging and sampling protocol to be performed. • Section 3.6.5, Sample Collection and Field Determinations - clarifies that future samples will not be field-filtered for any monitored parameters. The transition to unfiltered samples will occur upon approval of this M&RP, and is expected to consist of two sampling events where both filtered and unfiltered samples will be taken. The approach to statistically evaluating future unfiltered sample results, including how to incorporate these data into background, is described. If you have any questions pertaining to the 2010 Updated M&RP, please contact Ms. Jessica Walko at(303) 914-1427 or Mr. Bill Hedberg at(970) 686-2800. Sincerely, AquAeTer, Inc.1' 1 . (1111^3 Cathryn Stewart, P.G. Stephen W er, P.E. Project Manager Technical Di for cc: Ms. Kim Ogle, WCDPS, w/o enc. Mr. Louis Bull, Waste Management, w/o enc. Mr. Jack Epple, Waste Management, w/o enc. Mr. Bill Hedberg, Waste Management, w/enc. Ms. Jessica Walko, Waste Management, w/enc. Weld County Planning Department GREELEY OFFICE CCT 1 ?nsf� t ); WM ® RECEIVED WASTE MANAGEMENT WASTE MANAGEMENT 2400 W.Union Ave. October 4, 2010 Englewood,`CO 80110 q!`,794.; „ _.?1_ Mrs. Dana Podell z� -st,. Colorado Department of Public Health and Environment 0 C T 1 8 2010 Air Pollution Control Division APCD-SS-B1 ' ,, 4300 Cherry Creek Drive South Denver, CO 80246-1530 Hand Delivered SUBJECT: BUFFALO RIDGE LANDFILL (BRLF) TITLE V OPERATING PERMIT 2010 SEMI-ANNUAL MONITORING REPORTS Dear Mrs. Podell: The BRLF Title V Operating Permit# 03OPWE260 expired on April 1, 2010. An application for permit renewal was submitted to the Colorado Department of Public Heath and Environment (CDPHE) Air Permitting Unit on April 2, 2009. Although the permit renewal has not yet been issued, Waste Management of Colorado, Inc. (WMC) is continuing to follow the terms and conditions of Permit 03OPWE260 until such a time as the permit renewal is issued. As such, attached are the following reports covering the monitoring period of April I, 2010— September 30, 2010. • Monitoring and Permit Deviation Reports, Part I • Monitoring and Permit Deviation Reports, Part III. Part II of the Monitoring and Permit Deviation Reports 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 Bill Hedberg at (970) 686- 2800 ext. 23. Sincere Si 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. wnvnc�n i r>� L-5 w,o -=232O //-/- 2O/o f Ld f8/ From everyday collection to environmental protection, Think Green? Think Waste Management. Pnneea 20 200%Vw(-mmumn,nYdmP2DeL- Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report — Part I 1. Following is the required format for the Monitoring and Permit Deviation report to be submitted to the Division on a semi-annual basis unless otherwise noted in the permit. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. 2. Part II of the Appendix B shows the format and information the Division will require for describing periods of monitoring and permit deviations, or upset or emergency conditions as indicated in the Table below. One Part II Form must be completed for each Deviation. Previously submitted reports (e.g. EERs or Upsets) may be referenced and the form need not be filled out in its entirety. FACILITY NAME: Waste Management of Colorado, Inc. —Buffalo Ridge Landfill OPERATING PERMIT NO: 03OPWE261 REPORTING PERIOD: 4/01/10-9/30/10 (see first page of the permit for specific reporting period and dates) Upset/Emergency Operating Permit Unit Unit Description Deviations noted Deviation Code2 Condition Reported ID During Period?' During Period? YES NO YES NO E001 Landfill Gas Emissions X ;;- X E002 Fugitive Particulate X X Matter Emissions General Conditions X X Insignificant Activities X X See previous discussion regarding what is considered to be a deviation. Determination of whether or not a deviation has occurred shall be based on a reasonable inquiry using readily available information. 2 Use the following entries, as appropriate 1 = Standard: When the requirement is an emission limit or standard 2 = Process: When the requirement is a production/process limit 3 = Monitor: When the requirement is monitoring 4= Test: When the requirement is testing 5= Maintenance: When required maintenance is not performed 6= Record: When the requirement is recordkeeping 7= Report: When the requirement is reporting 8= CAM: A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring(CAM)Rule)has occurred. 9= Other: When the deviation is not covered by any of the above categories C:\Air\BRLF\BRLF MPDR 0909.doc l Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report — Part II FACILITY NAME: Waste Management of Colorado, Inc.—Buffalo Ridge Landfill OPERATING PERMIT NO: 03OPWE261 REPORTING PERIOD: 4/01/10-9/30/10 (see first page of the permit for specific reporting period and dates) Is the deviation being claimed as an: Emergency Upset N/A (For NSPS/MACT)Did the deviation occur during: Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Operating Permit Condition Number Citation Explanation of Period of Deviation Duration(start/stop date&time) Action Taken to Correct the Problem Measures Taken to Prevent a Reoccurrence of the Problem Dates of Upsets/Emergencies Reported(if applicable) Deviation Code Division Code QA: C:\Air\BRLFIBRLF MPDR 0909.doc Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report — Part III SOURCE NAME: Waste Management of Colorado, Inc.—Buffalo Ridge Landfill FACILITY IDENTIFICATION NUMBER: 1230448 PERMIT NUMBER: 03OPWE260 REPORTING PERIOD: 4/01/10-09/30/10 (see first page of permit for specific reporting period and dates) All information for the Title V Semi-Annual Deviation Reports must be certified by a responsible official. The responsible official signing this certification must be pre-approved by the Division in accordance with Colorado Regulation No. 3, Part A, Section I.B.38. This signed certification document must be packaged with the documents being submitted. STATEMENT OF COMPLETENESS I have reviewed the information being submitted in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this submittal are true, accurate and complete. Please note that the Colorado Statues state that any person who knowingly, as defined in Sub- Section 18-1-501(6), C.R.S., makes false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of Sub-Section 25-7 122.1, C.R.S. Scott Bradley Area Vice President Printed or Typed Name Title 6 - ( - `D Signature of Responsible fficial Date Signed Note: Deviation reports shall be submitted to the Division at the address given in Appendix D of this permit. No copies need be sent to the U.S. EPA. C:\Air\BRLF\BRLF MPDR 0909.doc Weld County Planning Department WASTE MANAGEMENT GREELEY OFFICE WASTE MANAGEMENT I I I (IQ 111 I 2400 W Union Ave. Englewood,CO 80110 July 6, 2010 RECEIVE® 303)794-2403 Fax Mr. Doug Ikenberry Colorado Department of Public Health and Environment Hazardous Materials and Waste Management Division 4300 Cherry Creek Drive South Denver, CO 80246-1530 Mr. Troy Swain Weld County Department of Public Health and Environment Environmental Health Specialist 1555 North 17thAvenue Greeley, CO 80631 SUBJECT: BUFFALO RIDGE LANDFILL LEACHATE MANAGEMENT Dear Mr. Ikenberry and Mr. Swain: The Buffalo Ridge Landfill (BRLF) is owned and operated by Waste Management of Colorado, Inc. (WMC). The site is regulated under the permit conditions provided in the Weld County Certificate of Designation (CD) and accompanying Site Specific Development Plan and Special Review Permit Development Standards (USR-966), as well as the Engineering Design and Operations Plan (EDOP). The CD and USR-966 were signed and put into effect on October 14, 1992 by Weld County. The EDOP is dated December 10, 1992 and was approved by the Colorado Department of Public Health and Environment (CDPHE) and Weld County. WMC is requesting a minor modification to the leachate management requirements in both USR-966 and the EDOP to bring the site in line with currently accepted practices at other landfills in Colorado. Development Standard #8 of USR-966 states: "The facility shall be operated in a manner which protects against surface and groundwater contamination. The facility operator shall implement the groundwater monitoring plan, approved by the Colorado Department of Health and the Weld County Environmental Protection Services Division. The analytical method and statistical evaluation of groundwater monitoring data shall comply with applicable Colorado Revised Statutes, as amended, for Solid and Hazardous Waste Disposal Sites and Facilities, and Subtitle D of the Resource Conservation and Recovery Act. Carbonate and cation-anion balance shall be included as part of the groundwater monitoring program. The applicant shall also analyze leachate for the following parameters, at a minimum: total organic halides, biochemical oxygen demand, total petroleum hydrocarbons, total phenols, Ph, and specific conductivity. The operator may choose to do a more detailed analysis." aromiruu eztt w to- l3-O t o ao to-- From everyday collection to environmental protection, Think Green? Think Waste Management. ® Pnnted on 100%post-consumer recycled pope, PLC 221 Mr. Doug Ikenberry and Mr. Troy Swain July 6, 2010 Page 2 WMC is proposing to replace the leachate monitoring portion of Development Standard #8 in USR-966 (last two sentences) with a reference to the attached July 2010 leachate management plan. This change would replace the current list of sampling parameters. The constituents listed in the proposed leachate management plan allow WMC to compare leachate chemistry with that of the surrounding groundwater monitoring network. Leachate management is discussed in Section 7.1.1 of the EDOP. The last paragraph of the section states: "The landfill liquid collection system will be monitored on a quarterly basis at the collection sump. Any liquids encountered will be sampled and analyzed to determine proper methods of discharge, disposal or treatment. Leachate will be monitored for the following parameters at a minimum: • Total Organic Halides (TOX) • Total Phenols • Biochemical Oxygen Demand (BOD) • Specific Conductivity • Total Petroleum Hydrocarbons (TPH) • pH All analyses required by any discharge permits will be completed as part of the monitoring program." WMC proposes to replace this last paragraph with a reference to the attached leachate management plan for management of any leachate collected from the leachate collection system and sump. The proposed leachate management plan is attached to this letter for review. The plan includes operational practices for minimizing leachate generation, use of leachate following removal, analytical testing requirements, and testing and monitoring frequencies. The primary method of leachate disposal is through use as a dust control over lined portions of the landfill. This method is consistent with previous approvals at BRLF and other WMC landfill sites. Using this method, most of the applied leachate will only infiltrate the upper few inches of soil cover from where it will evaporate. Because of the arid climate and the low moisture content of the in-place waste, it is improbable that any of the applied leachate would ever return to the leachate collection system. Any leachate that may travel through the soil cover to the waste will be absorbed within, and confined to, the upper-most layers. We request your review and concurrence with the proposed changes to the EDOP including review and approval of the attached leachate management plan. Upon receipt of your concurrence, we will file this as a minor change to USR-966 with the Weld County Department of Planning Services. Mr. Doug Ikenberry and Mr. Troy Swain July 6,2010 Page 3 If there are any questions about this request or the attached plan, please call me at 303-914-1427 or Mr. Tom Schweitzer, at 303-914-1445. Sincerely, Jessica Walko, P.E. Facility Engineer Enclosure cc: Kim Ogle, WCDPS Bill Hedberg, Buffalo Ridge Landfill Jack Epple, Buffalo Ridge Landfill LEACHATE MANAGEMENT PLAN BUFFALO RIDGE LANDFILL July 2010 The disposal cell design includes a leachate collection system that underlies the waste disposal area. The collection system consists of a 6-inch granular drainage blanket that overlies the base liner. The drainage blanket is designed and constructed to drain to sump areas located at the low point of each disposal area. The permanent sumps are designed with riser pipes that extend up the side-slope of the disposal cell to ground surface. The riser pipes are used for monitoring leachate levels, collecting samples for analysis, and removing leachate as required. Currently, one of the thirteen planned permanent sumps have been constructed. The predominant source of leachate is from the introduction of surface water into the leachate collection system as a result of precipitation over newly opened disposal cells with exposed granular drainage layers. Once a lift of waste is placed over the leachate collection system, and surface water management systems are in place, the likelihood for additional leachate generation is greatly diminished due to the arid climate and the absorptive capacity of the waste. The management method proposed for Buffalo Ridge Landfill (BRLF), which is patterned after WMC's other approved Colorado landfills, includes the following: 1. Sump risers will be monitored at least quarterly for the presence of leachate. Monitoring will be conducted to verify that leachate levels remain below one foot (1 ft) above the floor liner elevation. 2. Leachate will be sampled and analyzed at least annually for all Appendix IA and IB constituents of the Colorado Solid Waste Regulations and Table 3 constituents (Agricultural Standards) from the Colorado Basic Standards for Groundwater. In the event the concentration limits in Table 3 are exceeded, the facility will limit leachate application, as described below, to areas that are without final cover and away from exterior side slopes. 3. Leachate will be used for dust control on the lined limits of the landfill. Should there be more leachate than needed for dust control, an alternative disposal method will be evaluated. This method may include storage on-site in an above ground tank until needed for dust control, permitted transport and disposal to a publicly owned wastewater treatment facility, or other similar method. 4. When using leachate for dust control, leachate would be pumped from the sumps into a water truck for transport to the disposal area. A spray-bar attachment on the truck, or similar distribution device, will be used to apply the leachate. In-lieu-of a water truck, an alternative method for transporting and applying the leachate may be used provided conformance with items 5 and 6 below is maintained. Page 1 5. The leachate would be applied over lined areas with soil cover at rates to avoid runoff or significant amounts of standing water. 6. The application areas will be located away from the active disposal area. 7. The volume of leachate applied and the analytical results will be provided to the Department with the First Half Groundwater Monitoring Report. Leachate data and pumping logs will be available at the facility for review by CDPHE and Weld County upon request. Page 2 Hello