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HomeMy WebLinkAbout20071000.tiff STATE OF COLORADO Bill Flitter,Jr.,Governor James B.Martin, Executive Director otco�o Dedicated to protecting and improving the health and environment of the people of Colorado t7- �o 4300 Cherry Creek Dr. S. Laboratory Services Division z t+ . . Denver,Colorado 80246-1530 8100 Lowry Blvd. 87 Phone(303)692-2000 Denver,Colorado 80230-6928 TDD Line(303)691-7700 (303)692-3090 Colorado Department Located in Glendale,Colorado of Public Health http://www.cdphe.state.co.us and Environment March 28, 2007 Mr. Dwain M. Immel Operator and Registered Agent for Tire Recycling, Inc. 7000 W. Princeton Avenue Denver, CO 80235 RE: COMPLIANCE ORDER NO. 07-03-28-02 {Tire Recycling, Inc.} Dear Mr. Immel: You are hereby served with the attached Compliance Order Number 07-03-28-02 by the Hazardous Materials and Waste Management Division of the Colorado Department of Public Health and Environment(the "Department") pursuant to section 30-20-113(2), C.R.S. This Order is based upon findings by the Department that Dwain Immel and Tire Recycling, Inc. have violated, or are in violation of, certain provisions of the Colorado Solid Waste Act, sections 30-20-100.5 through 119, C.R.S. (the "Act") and the Colorado Solid Waste Regulations at 6 CCR 1007-2 (the "Regulations") as more particularly described in the enclosed Compliance Order. You are also hereby notified that the enclosed Compliance Order shall become effective upon receipt. Should you desire to schedule an informal conference or wish to discuss the technical aspects of this matter, please contact Charles Johnson of the Colorado Department of Public Health and Environment at (303) 692-3348. If you have retained legal counsel, he or she may contact David Banas of the Colorado Attorney General's Office at (303) 866-5456 to discuss legal aspects of this case. Please be aware that in order to maintain an accurate record of factual and legal matters discussed, an audio record will be made of the informal conference. A copy of the record will be provided to you upon request. In accordance with Department policy, an audio record will not be made of settlement discussions. • OiN :—N/ /`fF0u,6g 61/4,./-C,79 U7 A ( 2007-1000 Mr. Dwain M. Immel Tire Recycling, Inc. Compliance Order No_ 07-03-28-02 March 28, 2007 Cover letter-page two I urge you to give this matter your immediate attention. Sincerely, n5e- 5-IAA-Atre- Joe Schieffelin Solid and Hazardous Waste Program Manager Hazardous Materials and Waste Management Division Enc. Compliance Order No. 07-03-28-02 cc: David Banas, Office of the Attorney General Charles Johnson, HMWMD Peter Moore, Krys Boyle, PC Weld County Commissioners S Co<—, COLORADO DEPARTMENT OF PUBLIC HEALTH AND Fe` ?90 ENVIRONMENT t.,' O, * 't '( n * HAZARDOUS MATERIALS AND WASTE MANAGEMENT * * ' DIVISION * *� 1876 COMPLIANCE ORDER Number: 07-03-28-02 IN THE MATTER OF TIRE RECYCLING, INC. This Compliance Order is issued to Dwain Immel and Tire Recycling, Inc. ("Tire Recycling") f/Ida Tire Mountain, Inc. by the Colorado Department of Public Health and Environment, the Hazardous Materials and Waste Management Division ("the Division"), pursuant to the Division's authority under section 30-20-113(2), C.R.S., of the Colorado Solid Wastes Disposal Sites and Facilities Act, and sections 30-20-100.5 to 120, C.R.S. (the "Act"). The Division, as set forth herein, has determined that Dwain Immel and Tire Recycling have violated, or are in violation of, certain provisions of the Act and the Colorado Solid Waste Regulations (the "Regulations"), 6 CCR 1007-2, and are hereby ordered to come into compliance with the Act and the Regulations. General Findings of Fact and Conclusions of Law I. At all times relevant to the violations cited herein, Tire Recycling, Inc. was a Colorado corporation in good standing and registered to conduct business in the State of Colorado. Colorado Secretary of State Business Center records list the formation date of the corporation as January 15, 1985. The corporation operated as Tire Mountain, Inc. prior to changing the name of the corporation to Tire Recycling, Inc. in May of 2004. 2. Dwain Immel is a "person" and an "operator" under the Act, the Regulations (section 30- 20-101(3), C.R.S.; 6 CCR 1007-2, section 1.2), and relevant caselaw. 3. Tire Recycling is a "person" under the Act and the Regulations (section 30-20-101(3), C.R.S.; 6 CCR 1007-2, section 1.2). 4. Dwain Immel is the majority shareholder and registered agent for Tire Recycling. 5. Dwain Immel and Tire Recycling operate a tire recycling and disposal facility located at 12311 Weld County Road 41 near Hudson. Colorado 80642 (the "Facility:1 Operations at the Facility commenced in 1985, and the Facility has operated continuously since that date. 6. Weld County, Colorado is the governing body having jurisdiction over the Facility. 7. On or about January 25, 1989, the Board of County Commissioners of Weld County, Colorado adopted a resolution for the approval of a "Use By Special Review Permit" (Permit No. 842) for a tire landfill, storage and recycling facility. The Facility is located within the southeast quarter of Section 32, Township 3 North, Range 65 West of the 6th P.M. in Weld County, Colorado. A resolution to approve an amended certificate of designation for the Facility was approved by the Board of County Commissioners of Weld County on October 3, 1990. 8. On September 12, 2006, the Division issued a letter to Mr. Immel to document a September 12, 2006 telephone conversation between Mr. Immel and the Division's Kathleen D. Wahlberg in which Mr. Immel requested that the Division issue a letter to approve Mr. Immel's choice of financial assurance instruments for his two tire facilities— Tire Recycling in Weld County and Midway Tire Disposal/Recycling in El Paso County, Colorado. 9. As indicated in the September 12, 2006 letter, the current closure cost estimate for the Tire Recycling Facility, after the costs were adjusted inflation in 2004, 2005, and 2006, was listed as $242,436.00, and the post-closure estimate for the Facility was listed as $128,861.00, for a total financial assurance obligation of$371,297.00. Tire Recycling's existing financial assurance mechanism as of September 12, 2006 was a Letter of Credit from Cache Bank & Trust in the amount of$362,000.00. 10. As documented in the September 12, 2006 letter, Mr. Immel indicated that he intended to obtain an insurance policy in the amount of$400,000.00 for Tire Recycling's 2006 financial assurance through Stailey Insurance Corporation, underwritten by Evanston Insurance Company, with evidence provided on the standard insurance industry certificate of insurance form (ACORD form), as prescribed by the Colorado Insurance Commission. The Division indicated that this financial assurance instrument is acceptable to the Department if written to include the requirements in Section 1.8.9 of the Regulations and the language in Appendix A—Financial Assurance Instrument Language. 11. On September 18, 2006, the Division received a copy of the Certificate of Liability Insurance policy binder for the closure/postclosure bond in the amount of$400,000.00 for Tire Recycling's 120-acre monofill/landfill Facility near Hudson, Colorado. The $400,000.00 insurance policy was produced by Stailey Insurance Corporation and underwritten by Evanston Insurance Company by and through Markel Underwriting Managers, Inc. The policy lists a policy effective date of September 18, 2006, and a policy expiration date of September 18, 2007. The September 18, 2006 cover letter with the Certificate of Liability Insurance policy indicated that the $400,000.00 policy from Evanston Insurance Company would he replacing the $362,000.00 letter of credit from Cache Bank & Trust that was currently being used to support closure/post-closure financial assurance for the Facility. Tire Recycling,Inc. Compliance Order k 07-03-28-02 Page 2 of/I 12. On September 25, 2006, the Division issued a letter to the Cache Bank & Trust to terminate and release all funds for Tire Recycling's Letter of Credit No. 038 for the Facility. The Letter of Credit was being relinquished pursuant to section 1.8.4(E)(1) of the Regulations, because alternate financial assurance had been provided for closure and post-closure care of the Facility. 13. On October 5, 2006, the Division issued a letter to Mr. Immel regarding the Division's review of Tire Recycling's 2006 financial assurance submittal for the Facility. As stated in the October 5, 2006 letter, the Division indicated that Tire Recycling's new insurance policy in the amount of$400,000.00 was adequate to cover the existing closure and post- closure plan as currently approved by the Department in the existing Certificate of Designation for the Facility. However, the current closure and post-closure plan and financial assurance did not include the tire shredding and crumb rubber manufacturing processes proposed for the Facility. Therefore, the Division informed Mr. Immel that the Division would need to review and approve a new closure and post-closure plan for the Facility, and new cost estimates would need to be re-calculated to include these processes. 14. On November 16, 2006, the Division received notification of future cancellation from Stailey Insurance Corporation because Tire Recycling failed to make its October and November 2006 payments for Policy#CL420905649 in accordance with its premium finance agreement. 15. On December 13. 2006, the Division issued a letter to Mr. Immel to inform him that the financial assurance mechanisms for the Midway Tire Landfill facility and the Tire Recycling facility were not in compliance with the Regulations. Based on further review of the Certificates of Liability Insurance, the Division found that Tire Recycling was out of compliance with the Regulations for the following reasons: a. Tire Recycling's policy allows the insurer to cancel the policy with only sixty (60) days notice of cancellation, and with only ten (10) days notice of cancellation for for non-payment of premium.Pursuant to Section 1.8.9(I) of the Regulations, the policy must provide that the insurer may not cancel, terminate, or fail to renew the policy except for failure to pay the premium. If there is a failure to pay the premium, the insurer may elect to cancel the policy by sending notice of cancellation by certified mail to the owner or operator and the Department or governing body having jurisdiction one hundred twenty (120) days in advance of cancellation. b. Tire Recycling's policy has a 525,000.00 deductible. Pursuant to Section I.8.9(C) of the Regulations. the closure and post-closure policy must he issued for a face amount at least equal to the current closure and post-closure cost estimate. The tern "face amount- means the total amount the insurer is obligated to pav under the policy. Tire RCCrci/n' in( ('omplrancr Urdu=lC-2<.',v{1' Pncr 301!! 16. On January 29, 2007, the Division received a facsimile from Stailey Insurance Corporation regarding Tire Recycling's Certificate of Liability Insurance. The facsimile indicated that Tire Recycling made their December payment to First Insurance Funding Corporation which produced a reinstatement notice from First Insurance Funding Corporation. Stailey Insurance Corporation was waiting to receive the reinstatement notice from First Insurance Funding so it could forward it on to Evanston Insurance Company to stop the January 12, 2007 cancellation of Tire Recycling's policy. The January 29, 2007 facsimile from Stailey Insurance Corporation also indicated that Tire Recycling had not made their January 18, 2007 payment, and that the payment needs to be received by February 10, 2007. 17. On February 5, 2007, the Division received a copy of the January 28, 2007 Notice of Intent to Cancel Insurance Coverage from the Stailey Insurance Corporation regarding Tire Recycling's Certificate of Liability Insurance. The Notice of Cancellation, issued by the First Insurance Funding Corporation, indicated that Tire Recycling's insurance policy (Policy#420905649) was scheduled for cancellation on February 10, 2007 if the past due amounts on Tire Recycling's insurance policy were not received by First Insurance Funding Corporation prior to the scheduled cancellation date. 18. On February 9, 2007, the Division filed a claim with Evanston Insurance Company c/o Markel Underwriting Managers for the full-face value ($400,000.00) of the closure and post-closure bond issued by Evanston Insurance Company for closure and/or post closure care for the Tire Recycling's Facility located at 12311 Weld County Road 41, Hudson, Colorado 80642. 19. On March 1, 2007, the Division received a copy of the February 28, 2007 Notice of Intent to Cancel Insurance Coverage from the Stailey Insurance Corporation regarding Tire Recycling's Certificate of Liability Insurance. The Notice of Intent to Cancel, issued by the First Insurance Funding Corporation, indicated that Tire Recycling's insurance policy (Policy#420905649)was scheduled for cancellation on March 13, 2007 if the past due amounts on Tire Recycling's insurance policy were not received by First Insurance Funding Corporation prior to the scheduled cancellation date. 20. On March 16, 2007, the Division conducted an account status check with the First Insurance Funding Corporation regarding Tire Recycling's Certificate of Liability Insurance, and learned that Tire Recycling's account had been cancelled as of March 15, 2007. 21. On March 19, 2007, the Division filed a new claim with Evanston Insurance Company c/o Markel Underwriting Managers for the full-face value ($400,000.00) of the closure and post-closure bond issued by Evanston Insurance Company for closure and/or post closure care for the Tire Recycling's Facility located at 12311 Weld County Road 41, Hudson, Colorado 80642. Tire Recycling.Inc Compliance Order#07-03-28-02 Page 4 of II 22. On March 22, 2007, the Division conducted an account status check with the First Insurance Funding Corporation regarding Tire Recycling's Certificate of Liability Insurance, and learned that a payment for the account had been received by First Insurance Funding Corporation on March 21, 2007, and that Tire Recycling's account was listed as having a"current" status. 23. On March 23, 2007, the Division received a copy of the March 22, 2007 Request for Reinstatement of Insurance Coverage issued by First Insurance Funding Corporation to Evanston Insurance Company regarding Tire Recycling's Certificate of Liability Insurance. The Request for Reinstatement indicated that Tire Recycling had brought their account to a current status, and First Insurance Funding Corporation was requesting that Tire Recycling's policy be reinstated by Evanston Insurance Company. Violation (Failure to Maintain Financial Assurance) 24. The General Findings of Fact and Conclusions of Law in paragraphs 1 through 23 of this Compliance Order are hereby incorporated by reference as though fully set forth herein. Findings of Fact 25. "Scrap tire" means a tire that is no longer used for its original purpose. (6 CCR 1007-2, section 1.2) 26. "Solid waste" means any garbage, refuse, sludge from a waste treatment plan. water supply treatment plant, or air pollution control facility, and other discarded material, including solid, liquid, semisolid, or contained gaseous material resulting from industrial or commercial operations or from community activities. (section 30-20-101(6)(a), C.R.S. and 6 CCR 1007-2, section 1.2) 27. Scrap tires disposed of, processed, and recycled at the Tire Recycling Facility are "solid wastes" as that term is defined by the Act and the Regulations. 28. "Solid wastes disposal" means the storage. treatment, utilization. processing, or final disposal of solid wastes. (section 30-20-101(7), C.R.S.; 6 CCR 1007-2. section 1.2) 29. Tire Recycling has disposed of solid wastes at the Facility. 30. --Solid wastes disposal site and facility" means the location and facility at which the deposit and final treatment of solid wastes occur. (section 30-20-101(8). C.R.S. and 6 CCR 1007-2, section 1.2) tr Rtz kr. , ('ongdicrur c Ohdr. _u- qr-,-p' Agvo-of l l 31. Tire Recycling owns and operates a"solid wastes disposal site and facility"as that term is defined by the Act and the Regulations. 32. No person shall operate or maintain a solid wastes disposal site and facility in a manner that violates any provisions of part 1 of the Act, any rule or regulation adopted pursuant thereto, or any certificate of designation. (section 30-20-113(1)(a), C.R.S.) 33. The owner or operator of any solid wastes disposal site and facility shall comply with the financial assurance requirements mandated by the regulations of the department. (section 30-20-104.5(1)(e), C.R.S.) 34. No solid wastes disposal site and facility shall operate without being in compliance with the financial assurance requirements of the department contained in such regulations. (section 30-20-104.5(3)(a), C.R.S.) 35. The owner or operator of any solid waste disposal site/facility shall maintain in written documented form current cost estimates for hiring a third party to close such site and facility and to conduct post-closure care of such site/facility. The owner or operator of any solid wastes disposal site and facility shall establish financial assurance sufficient to ensure payment of such costs. No solid waste disposal site and facility shall operate without being in compliance with the financial assurance requirements of section 1.8 of the Regulations. (6 CCR 1007-2, section 1.8.1(A)). 36. The owner or operator must maintain the closure and post-closure care insurance policy in full force and effect until the Department in consultation with the governing body having jurisdiction consents to termination of the policy by the owner or operator as specified in section 1.8 of the Regulations. Failure to pay the premium, without substitution of alternate financial assurance as specified in section 1.8 of the Regulations, will constitute a violation of the Regulations, warranting such remedy as the Department in consultation with the local governing body having jurisdiction deems necessary. Such violation will be deemed to begin upon receipt by the Department and the local governing body having jurisdiction of a notice of future cancellation, termination, or failure to renew due to nonpayment of the premium, rather than upon the date of expiration. (6 CCR 1007-2, section 1.8.9(G)). 37. Review of information provided by Stailey Insurance has established that Tire Recycling has failed to make timely payments on its insurance policy(Policy#CL420905649) for the months of October 2006, November 2006, December 2006, January 2007, February 2007, and March 2007. 38. Review of financial assurance documents for the Facility has established that Tire Recycling failed to make timely payments in October 2006 through March 2007 on its premium for maintaining its Certificate of Liability Insurance for the Facility, and that the insurance policy(Policy#CL420905649) was cancelled effective March 15, 2007 due to Tire Recvcllog,Lm. Compliance Order X 07-03-28-02 Page 6 of// Tire Recycling's default in payment of its premium finance agreement. As of March 22, 2007, Tire Recycling's policy was recommended for reinstatement by Stailey Insurance Corporation and First Insurance Funding Corporation after receipt of payment on March 21, 2007. Conclusions of Law 39. Tire Recycling failed to make timely payments on its insurance premium for Tire Recycling's closure and post-closure care insurance policy for the Facility without substitution of alternate financial assurance, in violation of 6 CCR 1007-2, section 1.8.9(G). 40. At the time the Division received the Notices of Future Cancellation from the Stailey Insurance Corporation regarding the Tire Recycling facility, Tire Recycling was operating a solid wastes disposal site and facility without having met the requirements for owners and operators of such facilities, in violation of section 30-20-113(1)(a), C.R.S., section 30-20-104.5(1)(e), C.R.S., section 30-20-104.5(3)(a), C.R.S. and 6 CCR 1007-2, section 1.8. COMPLIANCE ORDER Based on the foregoing factual and legal determinations and pursuant to section 30-20-113(2). C.R.S. and 6 CCR 1007-2, Section 1.9.2(B), the Division hereby orders Tire Recycling to comply with the following compliance requirements: Financial Assurance Requirements 41. Within fourteen (14) calendar days of the effective date of this Compliance Order. Tire Recycling shall ensure that the existing financial assurance mechanism for the Facility is sufficiently funded for the period of coverage of the financial assurance mechanism. or shall obtain an alternate financial assurance mechanism that is approved by the Division and is sufficiently funded to cover all closure and post-closure costs for the Facility in accordance with section 30-20-104.5(1)(e), C.R.S., section 30-20-104.5(3)(a), C.R.S. and 6 CCR 1007-2, section 1.8. Tire Recycling shall submit a copy of the sufficient financial assurance mechanism to the Division within fourteen (14) calendar days of the effective date of this Compliance Order. Closure and Post-Closure Care Plan Requirements 42. Within thirty (30) calendar days of the effective date of this Compliance Order, Tire Recycling shall submit an updated Closure and Post-Closure Plan for the Facility to the Division for review and approval, that meets the requirements of 6 CCR 1007-2, sections 25. 2.6, 3.5 and 3.6. l yr Rarr(inr. Inr Compliance Ord', -tl'.p_-_n-p_ Pati c 'of/l 43. The Division will notify Tire Recycling in writing of its approval, approval with modifications, or disapproval of the Closure and Post-Closure Plan. 44. Upon commencement of voluntary or involuntary closure, Tire Recycling shall begin to implement the Closure and Post-Closure Plan in accordance with the procedures and schedules contained in the approved plan. 45. In the event that Tire Recycling is unable to obtain adequate financial assurance coverage for providing closure and post-closure care for the Facility within fourteen (14) calendar days of the effective date of this Compliance Order: a. Tire Recycling shall cease accepting used tires or any other solid waste, and b. Tire Recycling shall commence closure of the Facility in compliance with all requirements of the Act and the Regulations and in accordance with a Division- approved closure plan identified in paragraph 42 of this Compliance Order for the Facility immediately upon its approval. Additional Requirements 46. The Division reserves the right to impose any additional conditions or requirements necessary for compliance with the Act or the Regulations or to protect human health and the environment. IMPLEMENTATION OF WORK TO BE PERFORMED 47. All documents submitted under this Compliance Order shall use the same titles as stated in this Compliance Order, and shall reference both the number of this Compliance Order and the number of the paragraph pursuant to which the document is required. No plan submitted under this Compliance Order may be implemented unless and until written approval is received from the Division. Any approval by the Division of a plan submitted under this Compliance Order is effective upon receipt by Tire Recycling. All approved plans, including all procedures and schedules contained in the plans, are hereby incorporated into this Compliance Order, and shall constitute an enforceable requirement under Part I of the Act. 48. If the Division disapproves or approves with modifications any original or revised plan submitted by Tire Recycling pursuant to this Compliance Order, the Division shall provide a written explanation of the disapproval or approval with modifications. Within fifteen (15) days of receipt of the Division's approval with modifications or disapproval of the plan, Tire Recycling shall: 1) in the case of an approval with modifications only, submit a revised document that fully addresses the issues specified in the Division's written explanation; or 2) in the case of a disapproval only, submit a revised document Tire Rending, Inc. Compliance Order#07-03-28-02 Page 8 of 11 that fully addresses the issues specified in the Division's written explanation of disapproval for Division review and approval (Tire Recycling may not select this option if the Division has included in its disapproval an alternate plan that shall be implemented by Tire Recycling). If Tire Recycling fails to do any of the above within the specified time, Tire Recycling shall be deemed to have failed to comply with the Compliance Order, and the Division may bring an enforcement action, including an assessment of penalties. 49. In the event that Tire Recycling initiates closure activities, then Tire Recycling shall submit brief progress reports in writing to the Division, on the fifteenth day of each month, which include the following information: a. the progress of all closure and post-closure activities; b. a summary description of all closure and post-closure activities performed during the previous month; and, c. a summary description of activities to be performed in the upcoming month. NOTICES AND SUBMITTALS 50. For all documents, plans, records and reports required to be submitted by this Compliance Order, Tire Recycling shall submit an original and one copy to the Hazardous Materials and Waste Management Division of the Colorado Department of Public Health and Environment as follows: Mira Neumiller, Environmental Protection Specialist Solid Waste Unit Hazardous Materials and Waste Management Division Colorado Department of Public Health and Environment Mail Code: HMWMD-CP-B2 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 NOTICE OF LIABILITY FOR CIVIL PENALTIES AND INJUNCTIVE RELIEF 51. Section 30-20-113(5), C.R.S. provides that any person who violates section 30-20-113(1), C.R.S., which includes the Colorado Solid Wastes Disposal Sites and Facilities Act. sections 30-20-100.5 to 119, C.R.S., and the Colorado Solid Waste Regulations 6 CCR 1007-2. or any Compliance Order of the Department of Public Health and Environment, shall be subject to a civil penalty of not more than 52,000 per violation per day during which such violation occurs. The Colorado Department of Public Health and Environment is continuing its investigation into this matter and may issue additional Compliance Orders or may request that the Attorney General bring suit for injunctive lug'Recycling Inc. (-omplronce Order=0--2rJ•_U' Higr 1 0/ ll relief or civil penalties, or both, for failure to comply with section 30-20-113, C.R.S. and this Compliance Order. NOTICE OF EFFECTIVE DATE OF ORDER 52. This Compliance Order shall become effective upon receipt. RESERVATION OF RIGHTS 53. The Division reserves the right to bring any action or to seek civil or administrative penalties for any past, present or future violations of the Act or the Regulations not specifically addressed herein. Further, the Division has the right to bring any action to enforce this Compliance Order, and to seek penalties for any violation of the Compliance Order. COMPLETION OF REQUIRED ACTIONS 54. Tire Recycling shall submit a Notice of Completion to the Division upon satisfactory completion of all requirements of this Compliance Order. The Department shall either accept or reject Tire Recycling's Notice of Completion in writing within thirty(30) days of receipt. If the Department rejects Tire Recycling's Notice of Completion, it shall include in its notice a statement identifying the requirements that the Division considers incomplete or not satisfactorily performed and a schedule for completion. Tire Recycling shall, within fifteen (15) days of receipt of the Division's rejection, either I) submit a • notice of acceptance of the determination; or 2) submit a notice of dispute to the determination. If Tire Recycling fails to submit either of the above notices within the specified time, it will be deemed to have accepted the Division's determination. 55. If Tire Recycling files any notice of dispute pursuant to paragraph 54, the notice shall specify the particular matters in the Division's determination that Tire Recycling seeks to dispute, and the basis for the dispute. Matters not identified in the notice of dispute shall be deemed accepted by Tire Recycling. The Division and Tire Recycling shall have thirty (30) calendar days from the receipt by the Division of the notification of dispute to reach an agreement. If agreement cannot be reached on all issues within this thirty(30) day period, the Division shall confirm or modify its decision within an additional fourteen (14) days, and the confirmed or modified decision shall be deemed effective and subject to appeal in accordance with the Act. Tire Recycling,Inc Compliance Order#07-03-28-02 Page 10 of l l FOR THE COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT: n� Ar 3( 11 Charles Johnson Date Solid Waste Unit Leader Hazardous Materials and Waste Management Division Approved as to Form: David Banas #36664* Date Assistant Attorney General Natural Resources and Environment Section Attorneys for the Department 1525 Sherman Street, 5th Floor Denver, Colorado 80203 Telephone: (303) 866-5456 *Counsel of Record [be Rec (itiof Inc Conip/zncr Order (IS 2(4)2 Pngc 11 of 11 Hello