HomeMy WebLinkAbout20090875.tiffSTATE OF COLORADO
Bill Ritter, Jr., Governor
James B. Martin, Executive Director
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
TDD Line (303) 691-7700
Located in Glendale, Colorado
http://www.cdphe.state.co.us
April 2, 2009
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Ms.Jessica Walko, Facility Engineer
5500 S. Quebec Street, Ste. 250
Greenwood Village, CO 80111
Colorado Department
of Public Health
and Environment
Certified Mail # 7007 0220 0001 0610 3937
RE: Final Agency Action: Approval, With Modifications, of Asbestos Waste Acceptance Plan ("the
Plan")
Buffalo Ridge Landfill ("the Facility")
Weld County, Colorado
SW/WLD/BRL 2.2
Dear Ms. Walko:
The Hazardous Materials and Waste Management Department of the Colorado Department of Public
Health and Environment ("the Department") reviewed the above referenced document, received in this
office on January 27, 2009. The certificate of designation for the facility, issued on October 14, 1992,
conditionally approved the disposal of friable asbestos waste, with the condition that a document
detailing the waste handling and disposal procedures be developed and submitted for review and
approval to the Department and the Weld County Environmental Protection Services Division. The Plan
intends to satisfy the foregoing condition of the certificate of designation and Section 5.3.1(A) of the
Regulations Pertaining to Solid Waste Sites and Facilities, 6 CCR 1007-2 ("the Regulations"), which
states that no friable asbestos waste shall be received and disposed of at a solid waste facility unless
expressly authorized in an approved design and operations plan. The plan is a stand-alone addition to
the facility's approved engineering design and operation plan.
The Department approves the Plan, as final agency action, with the following modifications:
1. Financial assurance cost estimates for closure of the asbestos disposal area(s) shall be updated as
necessary within thirty (30) calendar days of your receipt of this letter to reflect this new disposal
activity occurring at the landfill. If forced to close the facility under adverse circumstances, the
Department would possibly incur incremental costs associated with the friable asbestos disposal
area, including, but not limited to, additional fencing and signage and additional surveying costs.
2. Section 3.8, Disposal Procedure: The entrance to the asbestos disposal area shall be equipped
with a gate that must remain shut when the area is not in use.
3. Section 3.8, Disposal Procedure: A trained WMC employee shall observe asbestos disposal area
operations during unloading and other activities to ensure all provisions of the Regulations and
131.1 cis"l 7s)
o -v1
(10; Pt, /Liz_
2009-0875
Ms. Jessica Walko
April 2, 2009
Page 2 of 3
the approved plan are being followed, including, but not limited to, setback distances and the
prohibition on visible emissions.
4. Section 3.8, Disposal Procedure: Customers using the area shall be instructed to unload in such a
way as to ensure the integrity of packages on unloading.
5. Asbestos Disposal Area: No limitation on the size or number of asbestos disposal areas size has
been specified. In effect, the plan requests approval to set up an unlimited number of asbestos
disposal areas within the permitted filling area of the MSW landfill. The Department's
preference would be to designate one discrete area according to anticipated current needs. If that
area as initially designated should prove inadequate, the opportunity exists for expanding that
area, or permitting a new one as disposal needs might dictate. If the facility elects to go forward
with the current approach of multiple, unlimited disposal cells in various parts of the landfill,
then the facility shall maintain a current, cumulative map showing surveyed locations of the
actual asbestos disposal areas used. Such map shall be included in the operating record and an
updated copy provided to the Department at the end of each year in which a new disposal area is
used (i.e. by March 1 of the year following). Because signage and fencing must remain in place
in areas where there has been disposal of friable asbestos, both during the active life of the
facility and during the post closure care period, the greater the number of such areas that arc
created, the greater the ongoing obligations to maintain the activity restrictions in these areas.
Should there come a time when operations require filling municipal solid waste in a lift(s) above
an inactive asbestos disposal area, the Division understands that you may request approval to
have the fencing and signage requirements be met through use of such features at the facility
perimeter.
6. Section 4.1.2, Fencing: In accordance with Section 5.3.4(A) of the Regulations, the fence
circumscribing the friable asbestos disposal area shall be sufficient to ensure the restriction of
activities in that area and to prevent the entry of unauthorized and unprotected personnel.
Having no specifications in the Plan for the fencing places the onus on WMC to ensure that the
fence used meets the performance based criteria in the Regulation.
7. Inspections by WMC Personnel: Trained site personnel shall inspect the disposal area at a
minimum frequency of daily, at the end of each operating day when the area is in use. For times
when the area is inactive, inspection frequency shall be weekly. The purpose of such inspections
shall be to ensure the requirements of the Regulations and the approved plan have been satisfied,
including, but not limited to, fence integrity, closing of the gate, adequacy of cover, signage,
visible emissions, etc.
8. Section 3.9, Cover Procedure: For asbestos -contaminated soil waste, where ovcrwetting at the
generator site may cause bags to split open on contact with the ground, the facility shall cover
such bags as soon as practical based on the volume of waste being received in the asbestos
disposal area, but no later than four hours after receipt. The cover will consist of nine inches of
soil or eighteen inches of non -asbestos cover material prior to compaction as required by Section
5.2.1 of the Regulations. All such bags will be covered at the end of each day, at a minimum,
which is sooner than the 24 hour period specified in the Regulations. The cover procedure in
3.9.1 will still apply to asbestos waste other than asbestos contaminated soil. If visible emissions
are observed at any time, the bags or containers will be covered immediately.
9. Section 3.10, Asbestos Storage Area: This shall be limited to rigid containers that will maintain
their integrity on during storage.
Ms. Jessica Walko
April 2, 2009
Page 3 of 3
10. Section 4.1, Asbestos Disposal Area: While the Plan states that at least six inches of soil will
separate the base of asbestos waste from the top of drainage layer material, nothing in the Plan or
this approval letter shall obviate the need for the site to implement its protective layer of select
trash over the liner and leachate collection system, in accordance with the approved engineering
design and operation plan. Some asbestos waste is inappropriate to be used as a first lift of select
waste placed upon the liner.
11. Section 6.0: The Contingency Plan shall specify under what conditions decontamination
procedures are necessary to prevent asbestos fibers from being inadvertently tracked outside of
the friable asbestos disposal area, and also describe in detail the decontamination procedures to
be implemented in that event.
12. Section 7.0, Records: Add the cumulative disposal areas map to the facility operating record.
13. Section 8.0, Closure and post closure care: Add the NESHAP closure and post -closure care
requirements to this section.
14. Approval of the Plan does not constitute approval of the Phase 1 landfill footprint depicted on the
figures associated with the Plan. The Plan may only be implemented in those discrete areas of
the landfill footprint for which the Department has approved a construction certification report in
accordance with Section 3.2.7 of the Regulations.
Please note that per Section 1.3.9 of the Regulations, the Department's approval does not preclude
separate review and approval by the local governing authority as well. Should you have any questions
regarding this correspondence, you may contact Jerry Ienderson at 303-692-3455, or Roger Doak at
303-692-3437.
Sincerely,
erYy Henderson
Solid Waste and Material Management Unit
Solid and Hazardous Waste Program
Roger Doak, Permitting Group Unit Leader
Solid Waste and Material Management Unit
Solid and Hazardous Waste Program
cc: Weld County Commissioners
Bill Hedberg, WMC
Doug Ikenberry, FIMWMDTrevor Jiricek, WCDPIIE
Laura Schumpert, APCD
Tom Schweizter, WMC
Cindy Smith, HMWMD
Troy Swain, WCDPHF
Hello