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DEC 2.31919 j Wheat Ridge, Colo. 80033
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(303) 422-3452
GREELE."G COInt December 17 , 1979
Board of County Commissioners Colorado Landfill, Inc .
of Weld County, Colorado 4710 W. 12th Street
P. 0. Box 459 Greeley, Colorado 80631
Greeley, Colorado 80631
Attn: Charles Lynn Keirnes
Attn: Norman Carlson, Chairman
Charles Lynn Keirnes
State of Colorado 4710 W. 12th Street
Department of Health Greeley, Colorado 80631
4210 E. 11th Avenue
Denver, Colorado 80220 Administrator
Environmental Protection Agency
Attn: Albert J. Hazle, Director Washington, D. C. 20460
Radiation & Hazardous Wastes
Control Division REGISTERED MAIL
RETURN RECEIPT REQUESTED
Gentlemen: ADDRESSEE ONLY
Please take notice that after the expiration of sixty days from
the service of this notice upon you, I shall commence suit against
you in the United States District Court in Denver, Colorado, for
your violation of Environmental Protection Agency Regulations
published in the Federal Register, Vol. 44, No. 179, on Thurs-
day, September 13, 1979, as corrected in the Federal Register of
September 21, 1979, Regulations made pursuant to authority granted
to the EPA by 42 USC 0 6944.
The activity that violates the Regulations is the construction
and operation of the solid waste disposal site described in the
Certificate of Designation issued by the Weld County Commissioners
to Colorado Landfill, Inc . , and/or Charles Lynn Keirnes on De-
cember 10, 1979 .
The persons who are responsible for the violation are the Board
of County Commissioners of Weld County, Colorado, Colorado Land-
fill, Inc . , Charles Lynn Keirnes and the State of Colorado Depart-
PL0631
790414
// (7-
Board of County Commissioners
Department of Health
Colorado Landfill, Inc .
Charles Lynn Keirnes
Administrator, EPA
December 17 , 1979
page two
ment of Health.
The dates of the violation are: December 3, 1979 (Board of
County Commissioners approval of Certificate of Designation for
Colorado Landfill, Inc.--Erie site) ; December 10, 1979 (Board
of County Commissioners issuance of Certificate of Designation
to Charles Lynn Keirnes) ; and all times subsequent to those
dates when Colorado Landfill, Inc . , and/or Charels Lynn Keirnes
attempts to construct or operate a landfill site at the place
designated on the said Certificate of Designation.
The Environmental Protection Agency is included in the suit as
a person needed for a just adjudication of the matter since it
may claim an interest in the subject of the action, and it is
so situated that a disposition of the action in its absence may
leave some or all of the other parties to the suit subject to
substantial risk of incurring inconsistent obligations as a
result of that claimed interest.
The names, addresses and telephone numbers of the persons giving
notice are:
Board of Trustees Frederick S. Solheim
Town of Erie, Colorado dba Dakota Ridge Aircraft
Erie Town Hall 2850 S. Main
Erie, Colorado 80516 Erie, Colorado 80516
449-3085 665-9321
Skies Unlimited, Inc. , Ronald R. Keith
of Colorado 1694 30th Street
350 Baron Court Boulder, Colorado 80301
Erie, Colorado 80516 442-3713
665-9001
Paul B. Knight
Aero Systems, Inc. 1602 S. Parker Road
2850 S. Main Denver, Colorado 80231
Erie, Colorado 80516 751-1154
665-9321
Daniel R. Horst
2240 Weld County Rd. #5
Erie, Colorado 80516 -
469-5246
Board of County Commissioners
Department of Health
Colorado Landfill, Inc.
Charles Lynn Keirnes
Administrator, EPA
December 17 , 1979
page three
The name, address and telephone number o£ Plaintiffs ' counsel
are listed above on the letterhead.
Very truly,
--Cx),ALL
Frank H. Rob -ts, Jr.
FHR/jv
cc : Regional Administrator
Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80295
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