HomeMy WebLinkAbout931600.tiff Remedial Planning Activities
ARCS At Selected Uncontrolled
Hazardous Substance Disposal Sites
In The Zone of Regions VI, VII and VIII
` a Environmental Protection Agency
(/ ZKS. Contract No. 68-W9-0053
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SITE INSPECTION PRIORITIZATION
GREELEY-MILLIKEN LANDFILL
WELD COUNTY, COLORADO
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{ Work Assignment No. 21-8JZZ
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September 1, 1993
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{ U R S Brown and Caldwell
Harza Environmental Services, Inc.
CONSULTANTS,INC Shannon & Wilson, Inc. 931600
Western Research Institute
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Greeley-Mlmken6IP
ARC,RS EPA Regions Inc. Distribution List
ontr EPA No. VI,05 VII and VIII Revision: 1
Contract 6&W9-0053 Dan: 09/01/93
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DISTRIBUTION LIST
ENVIRONMENTAL PROTECTION AGENCY
Robert Heise Work Assignment Manager, ARCS, EPA Region VIII,
WA en-sjzz
Pat Smith (3 copies) Site Assessment Manager, ARCS, EPA Region VIII,
WA#21-8JZZ
URS CONSULTANTS, INC.
Michael V. Carr
Project Manager, ARCS, EPA Region VIII, WA#21-8JZZ
Philip Woodcock Site Investigator, ARCS, EPA Region VIII, WA#21-8J
ZZ
File (3 copies) ARCS File System, ARCS, EPA Regions VI, VII and VIII
•
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SITE INSPECTION PRIORITIZATION
Greeley-Milliken Landfill
Weld County, Colorado
U.S. EPA Contract No. 68-W9-0053
Work Assignment No. 21-8JZZ
CERCLIS ID OCOD097141923
Prepared By:
Jennifer Macalady
and
Philip Woodcock
URS Consultants, Inc.
1099 18th Street, Suite 700
Denver, CO 80202-1907
UPS DOCUMENT CONTROL NO. 41881.30.63.A6138
Approved: Date: /40 93
ohn L Coats, Program Manager, UPS
Approved: U. tdift< ceLm .. ti Date: 9-1-9 3
Michael V. Carr, Project Manager, URS
Approved 3e Date: 7//s
"tulip Woodcock Site Investigator, UPS
1V--an Date: ( t:27?5
Approved: Pat Smith, Site Assessment Manager, EPA
t _ This document has been rePared for the U.S. Environmental Protection Agency under Contract
o. 68• 9 in0053. The material contained h is not to be disclosed to, discusse3 w1fl�3i araar
available to on or for any reason without rior express approval mther
ency. e interest conserving natural resources
is
ocument is printed on recycled papa.
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1.0 INTRODUCTION
1 URS Consultants,Inc. (URS)has been tasked by the U.S.Environmental Protection Agency(EPA)under
the Alternative Remedial Contacts Strategy (ARCS) Contract Number 68-W9-0053 to conduct a Site
Inspection Prioritization(SIP) (Work Assignment Number 21-8JZZ), under Superfund, for the Greeley-
Milliken Landfill site(landfill)(CERCLIS 1D+t COD097141923)located at 6037 77th Avenue,Greeley, CO
80631. The site is also known as Central Weld Sanitary Landfill; Weld County Dump (CERCLIS IDit
COD980959605) and Colorado Landfill, Inc. An EPA Field Investigation Team (FIT)plan of study was
completed in 1980 on"Greeley-Milliken Landfill"(Fred C.Hart Associates,Inc. (Hart)1980). No further
EPA FIT documents are found in files under any of the above site names (EPA 1993; Colorado
Department of Health(OH)1993a). A letter report and EPA Preliminary Assessment(PA)forms were
completed by Colorado Department of Health (CDH) in 1987 on "Weld County Dump" (same site
location) (EPA 1993).
2.0 OBJECTIVES
The purpose of this SIP is to review existing data for the landfill and identify whether data gaps exist
with respect to the revised Hazard Ranking System (HRS)and to provide sufficient documentation for
the EPA to determine the potential environmental threats posed by site contaminants, thus determining
the appropriate future course of action under the Superfund Program. The results of this SIP will enable
1 the EPA to determine if the site is eligible for the National Priorities List(NPL) under Superfund.
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The specific objectives of this SIP are to :
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• Summarize the previous work at the landfill;
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• Quantify and characterize (if possible) wastes attributable to the landfill;
• Identify waste availability to the groundwater, surface water, air and soil exposure pathways;
• Identify whether there is a potential or actual impact of landfill wastes on human and
environmental targets; and
• Identify relevant data gaps in each HRS pathway.
3.0 $ACKGROUND
3.1 SITE LOCATION ti `
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The landfill encompasses approximately 110 acres in Weld County and is located at 6037 77th
Avenue, Greeley, Colorado 80631 (Figure 1). The legal description for the landfill is the
southwest quarter of Section 32, T. 5 N, R. 66 W. The approximate site coordinates are 40'21'
16" N latitude and 107° 48' 24" W longitude. The site can be reached from Denver by
proceeding north on Interstate 25(I-25)to Colorado Highway 34, east to 65th Avenue, south to
Weld County Road 50 and then west to 77th Avenue. The site is located approximately 1/4 mile
from the intersection of Weld County Road 50 and 77th Avenue.
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Land use in the area within 4 miles of the landfill is primarily agricultural (U.S. Geological
Survey (USGS) 1969; Weld County Health Department 1993). The city of Greeley is located
approximately 5 miles northeast of the site. The town of Milliken is located approximately 2.5
miles southwest of the site (USGS 1969).
3.2 SITE DESCRIPTION
The landfill is an active facility which currently accepts municipal, commercial and industrial
solid wastes (Golder Associates, Inc. (Golder) 1993). The landfill also accepts special wastes
including petroleum-contaminated soils, empty resin (inert) drums and non-friable asbestos
(CDH 1987; Golder 1993). Liquid sludges and hazardous wastes are not currently accepted
(Golder 1993). The landfill is unlined (Weld County Health Department 1993). Engineering
controls currently in place have not prevented migration of volatile organic compounds present
in the landfill from migrating to a shallow aquifer and into the landfill underdrain outfall to
Spomer Lakes (Figure 3) (Golder Associates, Inc. (Golder) 1993)..
Buildings located on the landfill consist of a former residence,a gate house and a shop building
(Figure 3). Access to the landfill is controlled by a chain link fence;however Spomer Lakes are
located outside of the fence line(CDH 1993). The landfill is located on a hill at an approximate
elevation of 4800 feet above mean sea level in a region of gently rolling topography. The landfill
is bordered by agricultural fields on all sides(Golder 1993). The Big Thompson River is located
approximately one-half mile south of the landfill (Figure 2).
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3.3 SITE HISTORY AND PREVIOUS WORK
Site history and ownership information included here is taken primarily from site reports
prepared by Golder, a consultant to Waste Services Corporation (Golder 1992; Golder 1993).
Landfill operations began as early as 1967. The original Certificate of Designation for the site
was issued by Weld County to Earl Moffat on October 6, 1971. Browning Ferris Industries(BEI)
took over operations on an undetermined date and operated the landfill until 1976. Ralph and
Barbara Roweder (Weld Landfill, Inc.) operated the site from 1976 until June 1979, when
ownership of the property was transferred to Mr.C.Lynn Keimes(Colorado Landfill,Inc.). The
landfill was subsequently owned and operated by Waste Services, Inc under Mr. C. Lynn
Keimes from December 1985 until 1989. In 1989, ownership changed to Waste Services
Corporation under Mr. Brad Keines. In 1991,Waste Services Corporation merged with Waste
Management of Colorado, Inc, an operating division of Waste Management of North America
(Golder 1993). Waste Services Corporation continues to operate the active landfill.
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Based on documents and correspondence present in EPA and CDH site files, industrial and
commercial contributors to the landfill include:
• Balcom Chemicals, Inc (pesticide manufacturing wastes);
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• IBM Corporation (unknown amounts of toner and carrier wastes high in cyanide);
• Kodak, Inc. in Windsor, Colorado (paper and boxing containers, possibly chemicals); 1
r
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• Fort St. Vrain Nuclear Generating Station (precipitates and contaminated soils from a
regeneration process pond and the liner from an evaporation pond); and
• Flynn Sanitation (liquid wastes, primarily water) (EPA 1979, CDH 1987).
Site file information indicates that the landfill routinely accepted and co-deposited liquid and
solid wastes as of 1980 (Hart 1980). No detailed records on historical waste deposition in the
landfill are available from previous landfill owners, the Weld County Health Department,
or CDH.
Golder,under contract to WSC,collected samples from groundwater monitoring wells on landfill
property, from the landfill underdrain and from Spomer Lake drain in March 1992. These
samples were analyzed for eight VOCs,four pesticides,two herbicides,nutrients,major anions,
cations and ten dissolved metals. In July 1992, Golder collected confirmatory samples from the
same locations. These samples were analyzed for the same paran eters except that 15 additional
VOCs were added to the list of parameters(Golder 1993). These two sample rounds confirmed
that contaminants attributable to the landfill are present in the shallow aquifer downgradient of
the landfill trash zone (Golder 1993).
Radionuclides and radioactivity have been detected in wells and surface water samples on and
near the landfill property. Samples collected from shallow and deep aquifers and drainages at
and near the landfill were analyzed for two radionuclides, gross alpha and gross beta radiation.
The analytical data were reviewed by personnel at the CDH Radiation Control Division in 1993.
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Maximum levels detected at and near the landfill are considered to be within the range of
expected values for this region of Colorado (CHD, Radiation Control Division 1993).
Sampling at the landfill has included the following groundwater and surface water sample
locations:
• Fourteen shallow and deep groundwater wells located on and to the south of the landfill L
property;
• The landfill underdrain outfall to Spomer Lakes(located at the southwest corner of the
landfill);
• Surface water at the lower drain for Spomer Lakes;
• Surface water in the unnamed creek below Spomer Lake;
• Surface water in the on-site retention pond; and
• Landfill gas monitoring(Figure 3)(Warzyn Engineering,Inc.1984;Industrial Compliance
1991; Golder 1992; Golder 1993).
1.
Analytical data used in this evaluation is primarily from Golder investigations conducted in 1992.
Additional data was made available from Dave Hayes, a local citizen, in 1992. !!
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3.4 SITE GEOLOGY
Detailed information about the geology of the landfill area can be found in"Geologic Map of the
Boulder, Fort Collins, Greeley area, Colorado" by E.S. Crosby and "Bedrock Aquifers in the
Denver Basin,Colorado-A quantitative water-resources appraisal"by S.G.Robson(Crosby 1978;
-- Robson 1987). Site-specific geological information is located in previous investigations
(Warzyn 1984; Industrial Compliance 1991; Golder 1993).
Three stratigraphic units have been delineated at the landfill, above the consolidated bedrock,
based on field investigations. These are the Surficial unit (0 to 30 feet thick), the Upper
Weathered Bedrock unit (40 to 70 feet thick) and the Lower Weathered Bedrock unit(thickness
unknown) (Golder 1993). The Surficial unit consists of unconsolidated, yellow, well-sorted
Quaternary eolian silty day to clayey silt. The bedrock units are of Upper Cretaceous age and
are thought to be either the Laramie Formation or the Fox-Hills Formation. The Upper and
Lower Weathered Bedrock units are delineated based on color and location with respect to an
apparent erosional horizon. Both bedrock units consist of weathered, poorly indurated,
interbedded to interlaminated silty fine sandstone or daystone, probably of deltaic origin.
Gypsum lenses are present in the Upper Weathered Bedrock unit. Two large paleochannels
filled with slightly coarser material (sands and silty sands) were also identified in the Upper
Weathered Bedrock unit at a trench at the northern landfill property boundary. The directional
trends of the paleochannels are unknown(Golder 1993).
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3.5 SITE HYDROGEOLOGY
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Site-specific hydrological information included here is taken primarily from"Hydrogeological and
Geotechnical Characterization for the Central Weld Sanitary Landfill" (Golder 1993). Three
saturated zones were encountered during field investigations at the landfill. The first zone is
an apparently perched aquifer located in the northeastern corner of the site. The second zone
(shallow aquifer) is located at the top of the Upper Weathered Bedrock unit. Depth to
groundwater in the shallow aquifer at the landfill ranges between 3 to 59 feet below ground
surface (Golder 1993). The third zone (deep aquifer) occurs within the upper portion of the
Lower Weathered Bedrock unit.
Based on regional data,the shallow aquifer is approximately equivalent to the Laramie-Fox Hills rr
Aquifer(Golder 1993). The Laramie-Fox Ells Aquifer extends north from the Denver Basin into
Wyoming. The portion of the Laramie-Fox Frills Aquifer which underlies the landfill lies outside
of the Denver Groundwater Basin as defined in 2CCR 402-6, Colorado Department of Natural
Resources, "The Denver Basin Rules".
Groundwater flow in the shallow aquifer is to the south at approximately 95 feet per year.
Groundwater flow in the deep aquifer is to the south-southeast at approximately 2 feet per year.
Groundwater flow between the shallow and deep aquifers at the landfill has been documented
in both upward and downward directions. However, vertical flow is expected to be minimal
based on the presence of unsaturated zones between the aquifers in test boreholes(Golder 1993).
1%e nearest shallow downgradient private wells permitted for domestic use are located
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approximately 2.000 feet to the south and southeast of the landfill (State of Colorado. Office of
the State Engineer Division of Water Resources (DWR) 1993).
3.6 SITE HYDROLOGY
The probable points of entry for landfill contaminants to surface water are� >landfill
discharge
point
outfall to Spomer Lakes (proposed Colorado Discharge Permit System
001) and the on-site retention pond (unlined) overflow (proposed CDPS discharge point 002)
(Figures 2 and 3). Surface water run-on from precipitation and irrigation north of the landfill is
collected in perimeter ditches which flow west and south to the Spomer Lakes or east and south
to the on-site retention pond(Figure 3). Water in the Spomer Lakes flows south into a wetland
area and small creek and then into a series of irrigation ditches. Water in the on-site retention
pond is discharged onto agricultural fields along the eastern landfill property boundary. Both
drainage pathways eventually join the Big Thompson River,located approximately 12 mile south
of the landfill. The Big Thompson River flows approximately 2 miles east into the South Platte
River. Flow in the Big Thompson River in the landfill area has not been gauged(USGS 1991).
Average annual flow in the South Platte River as measured near ICersey, Colorado
(approximately 20 miles downstream)is approximately 1133 cubic feet per second(USGS 1991).
3.7 SITE METEOROLOGY
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The landfill is located in a semiarid climate zone. The mean annual precipitation based on
monthly data from the University of Delaware database is 15 inches. The net annual
precipitation calculated using monthly precipitation and evapotranspiration data from the
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University of Delaware database is 2.6 inches (University of Delaware, Center for Climatic
Research 1986). The two-year, twenty-four hour rainfall event for the site area is approximately
1.7 inches (Dunne and Leopold 1978). Prevailing wind direction is to the east (Golder 1993).
1
4.0 PRELIMINARY PATHWAY ANALYSIS
The following analysis will consider potential site impacts on the air pathway, groundwater pathway,
surface water pathway and soil exposure pathway utilizing HRS guidelines.
1
4.1 SITE WASTE QUANTITY AND CHARACTERISTICS
The source area at the site consists of a 110-ace landfill. The total volume of landfill has not
been determined(Waste Services Corporation(WSC)1993). Based on a thorough review of EPA
and CDH site files and conversations with the Weld County Health Department personnel and
the current landfill operators, detailed information about quantities of specific wastes deposited
in the landfill is lacking. Available waste deposition information is summarized below:
• A Preliminary Assessment form completed in 1979 indicates that liquid and solid wastes
from municipal, industrial sources were routinely accepted at the landfill (EPA 1979).
The same document lists Kodak, Inc in Windsor, Colorado, as a known depositor. A
subsequent EPA Site Inspection Report Form states that wastes from Kodak, Inc.
included paper and boxing containers (EPA 1980).
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Contract No.68.w40053• pesticide wastes from Balton Chemicals,Inc.are likely to have been deposited betweer
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1973 and 1976. The quantity of material deposited in the landfill was estimated by
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Balcom Chemicals employee to be 5.0 to 10,000 pounds based on expected quantities c
floor sweepings during the relevant period. The wastes reportedly consisted of dus
� tildes, floc
from the formulation of disulfoton and other organic phosphate pesticides,
e,�s 1981; CDH 1987); and
sweepings and empty containers and bags (EPA
The landfill has accepted special wastes consisting of petroleum-contaminated soils,no:
friable asbestos and empty resin (inert) drums (CDH 1987).
Documentation for the alleged disposal of hazardous wastes from IBM,Flynn Sanitation and t'.
Fort St. Vrain Nuclear Generating Station in the landfill is lacking.
Data gaps for waste quantity and characteristics identified by UPS are as follows:
The landfill has not been sampled to date. Contaminants in the landfill have b.
•
inferred based on contaminants found in groundwater and surface water near
landfill.
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4.2 AIR PATHWAY i
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4.2.1 Target Populations
Based on 1990 census data for Weld County, approximately 3263 people live within four
miles of the landfill. There are no known residents within 114 mile of the landfill.
Approximately 104 people are estimated to live within 1 mile of the landfill (U.S.
Department of Commerce, Bureau of the Census 1990). Approximately 8 workers are t
routinely present on site (Waste Services Corporation 1993).
Numerous small emergent and forested wetlands are scattered throughout the area
within 4 miles of the landfill (U.S. Department of the Interior, Fish and Wildlife }
Service 1990). Il
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Webster State Wildlife Area (WSWA) is located approximately 2.75 miles east of the
landfill. WSWA provides winter nesting areas for Bald Eagles and stopping areas for I
migratory waterfowl (Colorado Division of Wildlife 1993). f
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4.2.2 Release Data/Containment
No air sampling data have been collected in the landfill area to date. EPA and CDH file1.
`\documents indicate that insufficient cover and blowing trash have been recurrent
\ Iproblems at the landfill throughout its history (EPA 1980).
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4.2.3 Air Pathway Specific Data Gaps
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URS was not able to identify any significant data gaps associated with the air pathway.
4.3 GROUNDWATER PATHWAY
4.3.1 Target Populations
The population potentially impacted by groundwater contamination consists of residents
with domestic wells located within four miles of the landfill. There are no known
municipal drinking water wells located within 4 miles of the landfill (DWR 1993).
Approximately 157 domestic and household use wells are listed within four miles of the
landfill (DWR 1993). The nearest domestic well is located approximately 2,000 feet to
the southeast (downgradient)of the landfill and upgradient of the Big Thompson River
(DWR 1993). There are five domestic wells completed in the shallow aquifer that are
located within one mile of the landfill (DWR 1993). CDH instructed WSC to sample
these five wells by January 1992. This sampling has not occurred as of August 1993
(CDH 1993).
4.3.2 Release Data/Containment
Contaminants in the landfill have migrated to the shallow (Laramie-Fox Hills) aquifer
to the south and southeast of the landfill property (Golder 1993). Sampling data
collected in March and July 1992, from monitoring wells located downgradient of the
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landfill trash zone indicate the following contaminants are present in the shallow aquifer
at levels greater than three times the background sample level (Golder 1993):
1 Contaminant Maximum Concentration(ppb) l
1,1-dichloroethane 5.9
1,2-dichloroethane 36
1,2-dichloroethene 26
1,2-dichloropropane 6.6
trichloroethene 190
_tetrachloroethene 580 t
dichlorodifluoromethane 18
chromium 28
manganese 1,020 I
IL ammonia 220
Several metals and nutrients potentially attributable to the landfill were also detected in I
wells completed in the deep aquifer on site (Golder 1993). Based on sampling data
t
collected in March and July 1992, the following contaminants are present in the deep
aquifer downgradient from the landfill trash zone at levels greater than three times the
background sample level (Golder 1993):
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Contaminant Maximum Concentration (ppb)
26
barium
5.3
cadmium
12
chromium
1,700
manganese
2,620
iron
1,400
ammonia
7,400
nitrate as N _ _ — —
Nutrient levels in the shallow and deep aquifers are likely to be heavily influenced by
agricultural practices upgradient from the landfill (Golder 1993).
4 The following radionuclides and levels of radioactivity were also detected downgradient
I
I of the landfill trash zone:
4 Contaminant Maximum Concentration 1
f (Picocuriesfliter) ±
1
8.4
radium 226 6.2
radium 228 180
gross alpha 76
gross beta
Deep Groundwater
t
2.9
radium 226 3.4
radium 228 49
gross alpha n
gross beta
—
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Shallow and deep groundwater samples were analyzed for 23 volatile organic
compounds, 10 dissolved metals, 4 pesticides and 2 herbicides, nutrients, major anions
I.
and cations and radionuclides and radioactivity(Golder 1993). Groundwater data have
not been validated(CM 1993). A trip blank and a laboratory blank analyzed as quality
control indicators for the March 1992 sampling round were found to be contaminated r
with methylene chloride. A rinsate blank was also submitted in March 1992,but it was
free of contamination (Golder 1993).
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4.3.3 Groundwater Pathway Specific Data Gans I
URS has identified the following unknown data elements for the groundwater pathway.
These are not critical to evaluating the site using the HRS: `
• Domestic wells located downgradient of the landfill and upgradient of the Big
Thompson River have not been sampled; and v t
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• All analytical data previously collected is limited to select analytes from the ;
following analyses: Dissolved metals, pesticides, herbicides, nutrients, major
anions and cations,radionuclides and radioactivity. All available analytical data
is unvalidated.
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4.4 SURFACE WATER PATHWAY
4.4.1 Release Data/Containment
Contaminants attributable to the landfill have migrated to the landfill underdrain
(Figure 3). Based on sampling data from March and July 1992, the following
contaminants are present in aqueous samples from the landfill underdrain outfall to
Spomer Lakes (Figure 3) at levels greater than three times the background sample level
(Golder 1993):
Contaminant Maximum Concentration (ppb)
1,1-dichloroethane 5,400
tetrachloroethene 5,000
dichlorodifluoromethane 9
tetrachloroethene , 3
trichlorotrifluoromethane 3
manganese 1,750
ammonia 1.500
The following radionuclides and levels of radioactivity have been detected in the landfill
underdrain:
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Contaminant Maximum Concentration
(picoCuriesAiter)
Surface Water
radium 226 0.3
radium 228 0.9
gross alpha 63.6
gross beta 52.4
In addition, barium is present in an aqueous sample from the drain below the lower
Spomer Lake at 1,500 ppb(Figure 3). Barium was not detected in the landfill underdrain
sample or in the background sample(Golder 1993). No contaminants attributable to the
landfill were detected in aqueous samples from the creek below the Spomer Lakes or in
the on-site retention pond. Surface water samples were analyzed for the same
parameters as groundwater samples (Golder 1993). Surface water data have not been
validated (Golder 1993).
An aqueous sample collected from Spomer Lakes in 1992,by a local citizen was analyzed
for total metals by Triple "S" Lab, Inc. on July 10, 1992. Data from this sample is
unvalidated and there is no quality assurance associated with the sampling or analysis.
This data indicates the following metals in Spomer Lakes:
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METAL CONCENTRATION
ppb
aluminum 1743
arsenic 173
cadmium 20
chromium 61
cobalt 14
copper 23
iron 303
had 75
manganese 448
mercury 9
molybdenum 76
nickel 722
phosphorous 3920
selenium 149
vanadium 7
zinc 249
(Hayes 1992).
4.4.2 Drinking Water Threat
There are no known drinking water intakes or diversions located within 15 downstream
miles from the landfill (State of Colorado,Office of the State Engineer 1993). The Evans
Town Ditch, diverted from the Big Thompson River between the landfill and the South
Platte River confluence(Figure 2), is used solely for irrigation(State of Colorado, Office
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of the State Engineer 1993). Surface water within 15 downstream miles of the landfill
is used for irrigation, stockwatering, industrial and commercial use.
4.4.3 JIuman Food Chain Threat
It was reported that Spomer Lakes were fished regularly before the landfill commenced r
operations (Long 1993). Currently the nearest fishery is located approximately 1/2 mile 11
downstream from the landfill in the Big Thompson River (USGS 1969). The Big F
Thompson River downstream from the landfill is expected to contain sport fishing
species including Perch, Sunfish, Black Bullhead, Carp and rare Rainbow and Brown
Trout (City of Loveland 1993). The South Platte River downstream from the Big
Thompson River confluence has not been surveyed,but is expected to contain a similar
range of warm-water river fish species as the Big Thompson River (Colorado Division
I
of Wildlife 1993). Production data is not available for either fishery(City of Loveland
1993; Colorado Division of Wildlife 1993). WSWA and Bromer State Wildlife Area
(BSWA) are open hunting grounds for rabbit, pheasant, (Love and waterfowl (Colorado
Division of Wildlife 1993). Sediment and surface water in the Big Thompson River and
the South Platte River downstream from the landfill have not been sampled. r
4.4.4 Environmental Threat
National Wetland Inventory Maps for the landfill area show abundant emergent and
forested wetland areas downstream from the landfill along the Spomer Lakes drainage,
the drainage on the eastern border of the landfill, the Big Thompson River and the South I
Platte River (U.S. Department of the Interior, Fish and Wildlife Service 1990). Total I
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( Page 21 of 32
wetland frontage downstream from the landfill along the Spomer Lakes drainage is
Iapproximately 1/2 mule. Wetland frontage along the eastern drainage is approximately
2/3 mile. Emergent and forested wetlands with a total frontage of approximately 28
miles are present continuously along the Big Thompson and South Platte Rivers
downstream from the landfill.
WSWA and BSWA both provide winter nesting areas for Bald Eagles and stopping areas
for migratory waterfowl (Colorado Division of Wildlife 1993).
Wetlands located downstream from the landfill have not been sampled.
( 4.4.5 Surface Water Pathway Specific Data Gaps
URS has identified the following surface water pathway data gaps:
N.
All analytical data previously collected is limited to select analytes from the
following analyses: Dissolved metals, pesticides, herbicides, nutrients, major
anions and cations,radionuclides and radioactivity. All available analytical data
is unvalidated. There has been no sediment sampling conducted to evaldate the
_
surface water pathway.
1.
r
I
• Flow rate in the Big Thompson River, and
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• Samples have not been collected to evaluate the site's impact on the Big
Thompson River. t
4.5 SOIL EXPOSURE PATHWAY f
4.5.1 Target Populations
I
There are no known residents living within 200 feet of the landfill (USGS 1969).
Approximately 8 workers are routinely present at the landfill and may be exposed to
contaminants via the soil exposure pathway(WSC 1993). Based on census data for Weld
County, approximately 104 people live within 1 mile of the landfill(U.S. Department of
Commerce, Bureau of the Census 1990).
4.5.2 Containment [
No surface soil, subsurface soil or waste sampling has been conducted at the landfill to
date. EPA and CDH file documents indicate that insufficient cover and blowing trash
have been recurrent problems at the landfill during many periods in its history
(EPA 1993; CDH 1993). {
The landfill is surrounded by a chain link fence(Weld County Health Department 1993).
t
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;,g,3 oiosath
Scecific Data Gays
URS has not been able to identify any significant data gaps associated with the soil
exposure pathway.
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5.0 SUMMARY
The landfill is an unlined landfill which currently accepts municipal, commercial and industrial solid
wastes. There are no detailed records on historical waste deposition in the landfill. The facility first
submitted a Design and Operations plan to CDH for approval in 1993. Volatile organic compounds and
<. other contaminants attributable to the landfill have migrated to the shallow aquifer downgradient from
the landfill. The deep aquifer downgradient from the landfill may also be impacted by landfill wastes.
Contaminants detected in the landfill underdrain outfall to Spomer Lakes have the potential to migrate
to nearby surface waters.
The following data gaps have been identified for the site(Starred items are critical to screening this site
( under the HRS):
• Domestic wells located downgradient of the landfill and upgradient of the Big Thompson River
have not been sampled (groundwater pathway);
• • All analytical data previously collected at the site are limited to select analytes from dissolved
metals, volatile organic, pesticide, herbicide, major anion and cation, radionuclide and
radioactivity. The available data is unvalidated;
• • Sediment samples have never been collected to evaluate the surface water pathway;
- • Samples have not been collected to evaluate the site's impact on the Big Thompson River,
• Flow rate in the Big Thompson River, and
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• Waste characteristics for the landfill have been inferred based on contaminants detected in
groundwater and surface water near the landfill (site waste quantity and characteristics, soil [
exposure pathway).
I
It
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1881.30
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Page 26 of 32
6.0 LIST OF REFERENCES
City of Loveland, Colorado. 1993. Personal communication with Don Carlson, Manager of
environmental Resources, on May 19, 1993.
Crosby,E.S. 1978. Landforms in the Boulder-Fort Collins,Greeley Area,Colorado,USGS Miscellaneous
Investigation Series MAP I-855-6.
Dunne,Thomas, and Luna B. Leopold. 1978. "Water in Environmental Planning."W.H.Freeman and
Company, San Francisco.
Fred C. Hart Associates, Inc. (Hart). 1980. Plan of Study, Greeley-Milliken Landfill, TDD 1F8-8004-6,
6a, July 19, 1980.
Golder Associates, Inc. (Golder). 1992. Application for Colorado Discbarge Permit System, Waste
Services Corporation, Central Weld Sanitary Landfill, Weld County, Colorado, November 1992.
Golder Associates, Inc. (Golder). 1993. Hydrogeological and Geotechnical Characterization for the
Central Weld Sanitary Landfill, Weld County, Colorado, March 1993.
Hayes, Dave. 1992. Unvalidated sample data from Spomer Lakes. Sample was analyzed on July 10,
1992.
Industrial Compliance,Inc. 1991. Groundwater Investigation,Waste Services Corporation,Central Weld
Sanitary Landfill.
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Darr. 09N7N3
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Con EPA Region 0• and
Contra No.68-�M4�3 7444 W.
communication with Otis Long, Common Sense Bait and Tackle,
Long, Otis. 1993. Personal co
Chatfield Ave., Littleton, Co. (303) 973-3571• on August 10, 1993. ll
Nature Conservancy' The. Colorado Natural Heritage Program.
1993. Threatened and endanger
species information.
r
i
Robson, S.G. 1987. Bedrock Aquifers in the Denver Basin,
Colorado-A Quantitative Water-Resources
Appraisal. USGS Professional Paper 1257.
State of Colorado,Department of Health(CDH)•
1975. Evaluation of Eitsting Sanitary Landfills in Weld
City as Hazardous Waste Disposal Sites. September 1975.
State of Colorado, Department of Health (CDH). 1987. Potential Hazardous Waste Site Preliminary
Assessment. Completed on October 20, 1987.
State of Colorado, Department of Health (CDH)•
1993. Personal communications with Glenn Mallory
and Roger Doak, April 29, May 11 and May 25, 1993.
State of Colorado, Department of Health (CH), Radiation Control Division. 1993. Radiological Data
Review.
State of Colorado, Division of Wildlife (CDW). 1993. Letter from Frances Pusateri, Wildlife Biologist,
May 10, 1993.
State of Colorado, Office of the State Engineer. Division of Water Resources (DWR). 1993. Well
permitting and surface water diversion information.
68.41881.30 Txtsni �1.SJ n\SIP.Sites\Greeley\Ttr .uhaA 921061
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ARC.EPA Regions VI,VU and VIII Revision: 1
Contract No.68-W9.0053 Date. 09/01/93
Page 28 of 32
State of Colorado, Radiation Control Division. 1993. Personal communication with Greg Brand,
Professional Engineer, May 26, 1993.
University of Delaware, Center for Climatic Research. 1986. Terrestrial Water Budget Data Archive:
Version 1.01, compiled by C.J.Willmott and C.M. Rowe.
U.S. Department of Commerce, Bureau of the Census. 1990. Census data for Weld County, Colorado.
U.S. Department of the Interior, Fish and Wildlife Service. 1990. National Wetlands Inventory Maps,
Greeley, Kersey, LaSalle and Milliken Quadrangles.
( U.S. Environmental Protection Agency(EPA). 1979. Potential Hazardous Waste Site Identification and
Preliminary Assessment. Completed on November 27, 1979.
U.S. Environmental Protection Agency(EPA). 1980. Potential HazardousyWaste Site Inspection Report.
Completed on May 27, 1980.
U.S. Environmental Protection Agency(EPA). 1981. Notification of Hazardous Waste Site. Completed
on May 10, 1981 by Dennis Burchett of Balcom Chemicals,Inc. identifying the Greeley-Milliken Landfill.
U.S. Geological Survey(USGS). 1969 (photo-revised). 7.5-Minute Topographic Quadrangle, Milliken,
Colorado.
U.S.Geological Survey(USGS). 1991. Water-Data Report CO-91-1,"Water Resources Data for Colorado,
Water Year 1991."
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ARCS,EPA Regions 05VI,VII and VlII Date:Contract No.68-W9-0053 Page 29 of 32
Warzyn Engineering,Inc. 1984. Hydrogeologic Assessment,Greeley Landfill,Weld County,Colorado.
I
Waste Services Corporation. 1993. Personal communication with Bill Hedberg, Landfill Manager, on
June 11, 1993. '
Weld County Health Department. 1993. Personal communication with Trevor Juicek, Environmental
Services Division, May 3 and 21, 1993.
I
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ARCS,EPA Regions VI VU and VIII Site Location Map Page 31 of 32
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1 I Figure 2
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Source: 1:100,000 USGS 7.5'Topographic Quadrangle, Milliken, CO CONSULTANTS
93106
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9:1061
APPENDIX A
EPA PA Worksheet
y
931061
Name Philip Woodcock Location Weld County. Colorado
Site Name Greelev-Milliken Landfill Date September 1, 1993
PA WORKSHEET
ti
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jvtATOR CONSIDERATIONS
A) DOES ANY QUALITATIVE OR QUANTITATIVE INFORMAllON EXIST THAT MAY INDICATE
AN OBSERVED RELEASE TO GROUNDWATER, SURFACE WATER, SOIL OR AIR? Yes
Describe: Shallow groundwater and the landfill underdrain are contaminated with volatile
manic compounds.
B) IF THE ANSWER TO A. ABOVE, IS YES, IS THERE EVIDENCE OF DRINKING WATER
SUPPLY CONTAMINATION OR ANY OTHER TARGET CONTAMINATION (i.e. food chain,
reaeation areas, or sensitive environments)?
Describe: Downgradient domestic wells and downstream surface waters have not been
sampled
C) ARE THERE SENSITIVE ENVIRONMENTS WITHIN A 4-MILE RADIUS OR 15 DOWNSTREAM
MILES OF THE SITE? Yes IF YES, DESCRIBE IF ANY OF THE FOLLOWING APPLY:
- Multiple sensitive environments?
-Federally-designated sensitive environment(s)?
-Sensitive environment(s) downstream on a small or slow flowing surface water body?
Wetland areas are located downstream along the creek below Spomer Lakes and along the Big
Thompson and South Platte Rivers.
D) IS THE SITE LOCATED IN AN AREA OF ICARST TERRAIN? No.
Describe:
E) DOES THE WASTE SOURCE LIE FULLY OR PARTIALLY WITHIN A WELLHEAD
PROTECTION AREA AS DESIGNATED ACCORDING TO SECTION 1428 OF THE SAFE
1 DRINKING WATER AC? No.
( Describe:
F) DOES ANY QUALITATIVE OR QUANTITATIVE INFORMATION EXIST THAT PEOPLE LIVE
OR ATTEND SCHOOL ON ON-SITE CONTAMINATED PROPERTY? Imo.
Describe: There are no residents or schools located within 200 feet of the landfill.
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SITE INFORMATION
SITE NAME: Greeley-Milliken Landfill
ADDRESS: 6037 77th Avenue
CITY: Greeley COUNTY: Weld STATE: CO ZIP: 80631
EPA ID: COD097141923
LATITUDE: 40' 21' 16" N. LONGITUDE: 107°48' 24" W.
2. DIRECTIONS TO SITE (From nearest public road):
,South on 65th Avenue from Colorado Highway 34 to County Road 50, then travel west on
county road 50 to 77th Avenue, then travel north on 77th Avenue for 1/4 mile to site.
3. SITE OWNERSHIP HISTORY (Use additional sheets, if necessary):
A. Name of current owner. Waste Services Corporation {I
Address: 5660 Greenwood Plaza Boulevard. Suite 400 t
City: Englewood County: Arapahoe State: CO Zip: 80111
Dates: Front 1989 To present Phone: (303) 770.3324 j
B. Name of previous owner. Waste Services, Inc. (C. Lynn Keirnes)
Address: Unknown
City: Greeley County: Weld State: CO Zip: Unknown
Dates: From 1985 To 1989 Phone: Unknown
Source of ownership data: CDH 1987: Golder 1993 1
See Section 3.3. Site History and Previous Work, in the SIP text for complete ownership
history. I
4. TYPE OF OWNERSHIP (Check all that apply):
X Private State Municipal
Federal County Other (describe): t
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5. NAME OF SITE OPERATOR: Waste Services Corp.
ADDRESS: 6037 77th Avenue
CITY: Greeley COUNTY: Weld STATE: CO ZIP: 80631
PHONE: (303) 330-2641
BACICGROUND/OPERATING HISTORY
6. DESCRIBE OPERATING HISTORY OF SITE:
Landfillinz operations began as early as 1967. As of 1980. the landfill accepted liquid and solid
wastes from municipal and industrial sources.
Source of information: CDH 1987; EPA 1979; EPA 1980
7. DESCRIBE SITE AND NATURE OF SITE OPERATIONS (property size, manufacturing, waste
disposal, storage, etc.): The landfill covers approximately 110 acres. No liners, leachate
collection or runoff management systems are present at the landfill. The Landfill accepts solid
waste from municipal and industrial sources, hydrocarbon contaminated soils. nonfriable
asbestos and empty drums (less than 1% residue).
Source of information: CDH 1987; EPA 1979; EPA 1980
8. DESCRIBE ANY EMERGENCY OR REMEDIAL ACTIONS THAT HAVE OCCURRED AT THE
SITE:
None known or reported.
Source of information: EPA 1979: EPA 1980; CDH 1987: CDH 1993
9. ARE THERE RECORDS OR KNOWLEDGE OF ACCIDENTS OR SPELLS INVOLVING SITE
WASTES?
Describe: None known or reported.
. Source of information: CDH 1993
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10. DISCUSS DUSTING SAMPLING DATA AND BRIEFLY SUMMARIZE DATA QUALITY (e.g.,
sample objective, age/comparability, analytical methods, detections limits and QA/QC):
Groundwater and surface water samples collected from the landfill in 1992 have undergone the
following analyses: Volatile organic analysis for vinyl chloride; LL-dichloroethene: 1.1-
dichloroethane;1,2-dichloroethane:1.2-dichloropropane:trichloroethene;4bromofluorobenzene.
acolein;acrvlonitrile;bromochloroethane;dibromomethane; dichlorodifluoromethane:ethanol;
ethyl methac elate: idomethane; trans-1,2-dichloroethene; trans-1,3-dichloropropanei l
trichlorofluoromethane; tetrachloroethene; 1.2.3-trichloropropane: 1.4-dichloro-2-butene: 2-
chlorovinyl ether, dissolved metal analysis for arsenic.barium; cadmium: chromium; iron;lead:
manganese; mercury; selenium; silver pesticide analysis for endrin: lindane; methoxvchlor; `
toxaphene; herbicide analysis for (2.4-dichlorophenoxy)-acetic add; (Z4.5-trichlorophenoxyI l4
;retie add: nutrient analysis for nitrate: amonia: anion analysis for nitrate: amonia; cation f
analysis for radium 228; gross alpha; gross beta. One trip blank and one rinsate blank were
submitted and analyzed for the same parameters. None of this analytical data has been
validated.
Source of information: Golder 1992; Golder 1993
Y
WASTE CONTAINMENT/HAZARDOUS SUBSTANCE IDENTIFICATION
11. FOR EACH SOURCE AT THE SITE, SUMMARIZE ON TABLE 1 (page 12): 1) Methods of
hazardous substance disposal,storage or handling;2)Size/volume/area of all features/structures
that might contain hazardous waste; 3) Condition/integrity of each storage disposal feature or
structure; and 4) Types of hazardous substances handled.
12. BRIEFLY EXPLAIN HOW WASTE UANITTY WAS ESTIMATED (e.g., historical records or
Q
manifests, permit applications, air photo measurements, etc.): t
Waste quantity is as the area of the landfill (110 aces)since the volume of wastes deposited in
the landfill has not been determined. [
Source of information: WSC 1993
I.
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13. DESCRIBE ANY RESTRICTIONS OR BARRIERS ON ACCESSIBILITY TO ON-SITE WASTE
MATERIALS:
f-- The site is surrounded by chain link and barbed wire fencing materials.
Source of information Weld County Health Department 1993
GROUNDWATER CHARACTERISTICS
14. ANY POSITIVE OR CIRCUMSTANTIAL EVIDENCE OF A RELEASE TO GROUNDWATER?
Describe: Shallow groundwater is contaminated with VOCs.
Source of information: Golder 1992; Golder 1993
15. ON TABLE 2 (page 13), GIVE NAMES, DESCRIPTIONS, AND CHARACTERISTICS OF
GEOLOGICIHYDROGEOLOGIC UNITS UNDERLYING THE SITE.
16. NET PRECIPITATION: 2.6 inches
SURFACE WATER CHARACTERISTICS
17. ARE THERE SURFACE WATER BODIES WITHIN 2 MILES OF THE SITE? Yes
/ Ditches I Lakes d Pond
Creeks / Rivers Other
O
18. DISCUSS THE PROBABLE SURFACE RUNOFF PATTERNS FROM THE SITE TO SURFACE
WATERS:
Surface water originating on site may collect in perimeter ditches or an on-site retention pond.
The retention pond overflows onto agricultural fields located east of the landfill. The western
perimeter ditch discharges into the Soomer Lakes. All surface waters migrate to the Big
Thompson River which in turn discharges to the South Platte River.
t 19. PROVIDE A SIMPLIFIED SKETCH OF SURFACE RUNOFF AND SURFACE WATER FLOW
SYSTEM FOR 15 DOWNSTREAM MILES (see item #35).
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20. ANY POSITIVE OR CRCUMSTANTIALEVIDEJ.Jr OP SURFACE WATER CONTAMrJqAflQq
Yes.
Describe: The landfill underdrain is contaminated with VOCs.
Source of information: Golder 1992: Golder 1993
21. ESTIMATE THE SIZE OF THE UPGRADIENT DRAINAGE AREA FROM THE SITE: M0Q acres
Source of information: USGS 1969
22. DETERMINE THE AVERAGE ANNUAL STREAM FLOW OF DOWNSTREAM SURFACE
WATERS
Water body: Creek below Spomer Lakes Flow: no data cfs
Water body: Big Thompson River Flow: no data cfs f
Water body: South Platte River Flow: 1133 cfs (16-year average)
Source of information USGS 1991
23. IS THE SITE OR PORTIONS THEREOF LOCATED IN SURFACE WATER? No. E
24. IS THE SITE LOCATED IN A FLOODPLAIN (indicate flood frequency)? No.
25. IDENTIFY AND LOCATE(see item#35)ANY SURFACE WATER kECREATION AREA WITHIN
15 DOWNSTREAM MILES OF THE SITE:
Webster State Wildlife Area (158 acres) and Brower State Wildlife Area (69 acres) are located
;long the South Platte River approximately 3.5 and 12 miles downstream from the landfill
respectively.
Source of information: CDW 1993 tL
26. TWO YEAR 24-HOUR RAINFALL: 1.7 inches •
TARGETS
27. DISCUSS GROUNDWATER USAGE WITHIN FOUR MILES OF THE SITE:
Groundwater within four miles of the landfill is used for domestic, household, irritation.
68-41881.30.06
\SIP\STTES\Greeley\Fn I\W rksheet.PA:srd
PA Worksheet
Page a
stockwatering
Source of information: DWR 1993
28. SUMMA R=THE POPULATION SERVED BY GROUNDWATER ON THE TABLE BELOW:
Distance Population
(miles)
)0 - 1/4 0
,1/4 - 1/2 11
)1/2-
1 3
.1 - 2 46
,2- 3 148
-4 215
Source of information: DWR 1993
29. IDENTIFY AND LOCATE (see item#35) POPULATION SERVED BY SURFACE WATER
INTAKES WITHIN 15 DOWNSTREAM MILES OF THE SITE:
There are no known drinking water diversions located within 15-downstream miles of the
landfill.
Source of information: DWR 1993
30. DESCRIBE AND LOCATE FISHERIES WITHIN 15 DOWNSTREAM MILES OF THE SITE
(provide standing crop and production and acreage, etc.):
Spomer Lakes were fished regularly until the landfill began operations. The Big Thompson River
is a recreational fishery which supports the following game fish species: Perch. Sunfish.
Bullhead Catfish. Carp and occasional Rainbow and Brown trout. The South Platte River is also
a recreational fishery and supports a similar range of warm water fish species as the Big
Thompson River.
Source of information: CDW 1993; City of Loveland 1993. Long 1993.
68-41881.30.06
\SIP\SITES\Greeley\Final\W rksheet.P A srd
9171061
PA Worksheet .
Page 9
31. DETERMINE THE DISTANCE FROM THE SITE TO THE NEAREST OF EACH OF THE
FOLLOWING LAND USES
Description Distance
(miles) C
Commercial/Industrial
Institutional 3
Single Family Residential 1/4 [
Multi-family Residential unknown
Park
Agricultural . 1/4
Source of information: USGS 1969; CDH 1987 _ t
32. SUMMARIZE THE POPULATION WITHIN A FOUR-MILE RADIUS OF THE SITE:
Distance Population
(miles)
.0- 1/4 7
>1/4 - 12 19
.1/2- 1 78
A - 2 311
>2-3 518
,3 -4 2330 i
Source of information: U.S. Department of Commerce. Bureau of the Census 1990
33. DISCUSS ANY PERMITS:
County:
State: Certificate of Designation (CD) 1971: Amended CD under review by CDH.
Federal: Two proposed NPDES discharge points under review by CDH.
Other.
Source of information: CDH 1993 l
6841881.30.06
\SIP\SUES\Greeley\Puu tal\Wrksheet.PA:srd
1
921061
PA Worksheet
Page 10
34. SKETCH OF SITE
Include all pertinent features,e.g.,wells,storage areas,underground storage tanks,waste areas,
buildings, access roads, areas of ponded water, etc. Attach additional sheets with sketches of
enlarged areas, if necessary.
See Figure 3, Site Sketch N
i
6841881.30.06
\SIP\SI TES\Greeley\Foul\Wrksheet.PA:srd
9_1961
PA Worksheet
Page 11
35. SURFACE WATER FEATURES
Provide a simplified sketch of surface runoff and surface water flow system for 15 downstream
miles. Include all pertinent features, e.g., intakes,recreation areas, fisheries, gauging stations,
etc.
See Figure 1, Radius of Influence Map and Figure 2, Site Location Map N
1
68-41881.30.06
\SIP\Srrf35\Greeley\Final\W rksheetPA:srd
97:1061
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R2±0SI
URS
A PROFESSIONAL SERVICES ORGANIZATION
URS CONSULTANTS, INC.
1099 18TH STREET SAN FRANCISCO NEW YORK
September 1, 1993 SURE 700 SEATTLE CLEVELAND
DENVER COLUMBUS
DENVER,COLORADO 80202.1907 COLORADO SPRINGS PARAMUS
TEL:(3031 2984700 SACRAMENTO AKRON
PORTLAND BUFFALO
ANCHORAGE NEW ORLEANS
SAN BERNARDINO ATLANTA
Ms. Pat G. Smith, Site Assessment Manager LONG BEACH BOSTON
LAS VEGAS VRUR INGEACH
U.S. Environmental Protection Agency PI
H
Region VIII, Waste Management Division, BHWM-SM
999 18th Street, Suite 500
Denver, CO 80202-2405
SUBJECT: ARCS VI, VII and VIII, Contract No. 68-W9-0053, WA x21-4JZZ
Site Inspection Prioritization: Sampling Plan
Greeley-Milliken Landfill, Greeley, Colorado
(EPA ID *COO097141923)
Dear Ms. Smith:
This letter is submitted, per your direction, to describe sampling activities proposed to fill data gaps
identified under the Site Inspection Prioritization(SIP)work assignment for the Greeley-Milliken Landfill
(GML).
The GML is an active landfill located at 6037 77th Avenue, Greeley, Colorado. Wastes identified at GML
during previous investigations by various consultants include volatile organic compounds, pesticides,
herbicides, metals and others. Additional information pertaining to GML's operations and history may
be found in the SIP report for GML dated September 1, 1993. Additional information can be found in
Weld County files, State of Colorado Department of Health files and EPA CERCLA files.
Sampling activities specified in this letter will take place during the fall of 1993. URS will keep you
informed as the dates of sampling are determined. Sample collection, preservation and handling will
strictly adhere to applicable procedures described in the URS Technical Standard Operating Procedures
(TSOPs) for field operations at Hazardous Waste Sites. Photographs will be taken at each sampling
location. Sample collection will consist of six surface water samples,five sediment samples, two source
(landfill) samples and three quality control samples. Samples will be analyzed through Routine
Analytical Services(RAS)for volatile and semivolatile organic compounds,total metals,organophosphate
pesticides and polychlorinated biphenyls (PCBs). The analytical work will be performed through the
EPA Contract Laboratory Program(CLP). URS will obtain access to sampling locations from appropriate
landowners including Waste Services Corporation and any private landowners whose land would have
to be traversed to access sample locations.
68-41881.30.00007
\ARCS\SIP\Sites\Greeley\Rev1\SmplPlaa*
ft-N11061
URS
A PROFESSIONAL SERVICES ORGANIZATION
Pat G. Smith
September 1, 1993
Page 2 of 3
Surface/Sediment Water Samples
URS will collect five surface water samples and five co-located sediment samples (see Sample Location
Map). Background samples GML-SW-1 and GML-SE-1 will be collected from the unnamed creek above
Spomer Lake and upgradient of GML. Samples GML-SW-2 and GML-SE-2 will be collected to
characterize landfill leachate from the underdrain outfall to Spomer Lake. Samples GML-SW-3,GML-SE-
3 will be collected from Spomer Lake located immediately downgradient of GML. Samples GML-SW-
4/GML-SE-4 and GML-SW-5/GML-SE-5 will be collected from the Big Thompson River(GML-SW-4/GML-
SE-4 will be the background sample from the Big Thompson River).
Aqueous samples will be collected directly into sample bottles or by using a decontaminated Teflon
scoop as per TSOP 4.18,"Surface Water Sampling." Field parameters will be measured during collection
of aqueous samples as per TSOP 4.15, "Water Sample Field Measurements." Sediment will be collected
with decontaminated stainless steel spoons, a decontaminated hand auger or a decontaminated Teflon
scoop as per TSOP 4.17, "Sediment Sampling."
Source (landfill) Samples
URS will collect two samples from the landfill. Sample GML-GW-1 will be taken from an existing well
on landfill property completed upgradient of the trash zone to characterize background groundwater
quality. A second sample, GML-GW-2, will be collected from an existing monitoring well completed
in saturated refuse on the southwest corner of the landfill and directly upgradient of Spomer Lake. Prior
to collecting sample GML-GW-1 and GML-GW-2, a minimum of three casing volumes will be purged
from the monitoring well and field parameters will be allowed to stabilize. Groundwater will be
collected with a disposable bailer as per TSOP 4.12, "Groundwater Sampling."
Ouality Control Samples and Health and Safety
Quality control samples will be collected in accordance with Superfund Site Assessment Quality Control
Guidance (see Table 2). Personnel will strictly adhere to all URS health and safety requirements and
applicable OSHA regulations.
Non-Sampling Data
Prior to commencing field work, URS will attempt to:
• Characterize and quantify wetlands downgradient of GML;
• Take flow measurments from the Big Thompson River; and
• Conduct a radiation survey at the landfill.
6841581.30.00007
\ARCS\SIP\Sites\Greeley\Rev l\SmplPlan:jb
97,1061
•
URS
A PROFESSIONAL SERVICES ORGANIZATION
Pat G. Smith
September 1, 1993
Page 3 of 3
Management of Investigation-Derived Wastes
Field investigators will attempt to minimize the generation of Investigation-Derived Wastes (113W) and
manage wastes in accordance with EPA OERR Directive #9345.2-02, "Guidance for Managing
Investigation-Derived Wastes During Site Inspections."
URS anticipates that the sampling budget and LOE will be consistent with those estimated in the Initial
Work Plan Volume II-Cost Proposal. Sampling activities will be documented in a Sampling Activities
Letter that will be submitted to the EPA following completion of field activities.
Yours truly,
URS CONSULTANTS, INC.
2tite U ( wt
Michael V. Carr p B. Woodcock
Project Manager Site Investigator
Attachments: Table 1 - Sample Rational Table
Table 2 - Sample Plan Checklist
Figure 1 - Sample Location Map •
cc John I. Coats/URS/Denver
T. F. Staible/URS/Denver
Site File/URS/Denver
ARCS File/URS/Denver
68-41881.30.00007
.\ARCS\SIP\Sites\Greeley\Rev1\Smpiplarejb •
971061
URS
A PROFESSIONAL SERVICES ORGANIZATON
[7R.5 Consultants.Inc. Greeley-MMOtervSIP/Table 1
ARCS EPA Regions VI, VII and VIIIRevision:1
Contract No. 68-W9-0053 Date: 09/01/93
Page 1 of 1
TABLE 1
Sample Rational Table
Sample Number Location Data Gap Addressed
GML-SW-1 Unnamed seek upgradient of Background for Spomer Lake
GML
GML-SW-2 Landfill underdrain outfall Sample Landfill Lechate
GML-SW-3 Spomer Lake Test for Contamination in
Fishery
GML-SW-4 Big Thompson River Background for Big
(upgradient) Thompson River
GML-SW-5 Big Thompson River Test for Contamination in
(downgradient) Fishery
GML-SE-1 Co-located with GML-SW-1 Background for Spomer Lake
GML-SE-2 Co-located with GML-SW-2 Sample Landfill Lechate
GML-SE-3 Co-located with GML-SW-3 Test for Contamination in
Fishery
GML-SE-4 Co-located with GML-SW-4 Background for Big
Thompson River
GML-SE-5 Co-located with GML-SW-5 Test for Contamination in
Fishery
GML-GW-1 Existing North Landfill Characterize background
monitoring well groundwater
GML-GW-2 Existing Southwest corner Characterize the Landfill
landfill monitoring well
GML-NIR-1 Rinsate Quality Control
GML-BT-1 Trip Blank (VOA) Quality Control
GML-SW-6 Duplicate sample of GML-SW-3 Quality Control
6&41881.30.00007
\Aga\gip\Sites\Greeley\Real\SmplPlangb
931061
Greeley-Mcllacen/SIP/Figure 1
_ URS Consultants,Inc. FIGURE 1 on 1
ARCS.EPA Regions VI.VII and V� Date: 09/01193
8- Sample Location Map e 1 of 1
Contract No. 68-W9-00.53Pa 8 GML-SW-1—'bso./
`;, �•�' GML-SE 1 ��
LI
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•
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r 4709
10
ll
s 4715 •
a 1 a Site Inspection Prioritization
?8 ti • uNtpN Q ,�/I URS Job No.41881.30
fL�
Greeley-Milliken Landfill
' //= ee� r
1 N Weld County, Colorado
1a7 8 Sample Location Map
• l Figure 1
LEGEND 0 1/2 Mile
IN.- Direction of Flow : 7,-44;
September 1993 URS
Source: 1:100,000 USGS 7.5' Topographic Quadrangle, Milliken, CO \ CONSULTANTS
68-41881.30.00007
3.2136
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931061
ggt� +. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
�.eyta
REGION VIII
\r\iif`/ 999 18th STREET - SUITE 500
DENVER. COLORADO 80202-2466
Ref: SHWM-SM
Mr. Mike Carr
DRS Consultants
1099 18th Street, Suite 700
Denver, Colorado 80202
re: Greeley Millikin LF SIP
Dear Mike:
Thank you for your speedy response to the last set of
continents . The SI Prioritization . (SIP) report dated September 1,
1993 for the Greeley Millikin Landfill site in Colorado is
approved.
I have also reviewed and conditionally approved the sample
plan for remaining work at the site. Please add to it NO2/NO3
analysis for all acueous samples. You are approved in advance
for up to two additional water samples for drinking water wells
between the landfill and the Big Thompson River.
As always, please notify the State of your field dates so
that they may join you if they are interested in doing so.
Sincerely, )
j+SstaL,
Pat G. Smith
Site Assessment Manager
Enclosures
cc: Bob Heise, WAM
Pu,ted on Recycled Paper
9:71061
sELs�E�!
Pursuant to the terms and conditions stated herein, waste •
Management Disposal Services of Colorado, in*. (f/k/a waste
Services Corporation) hereinafter referred to as "orantor• epeesi
to designated representatives of UPS Consultants, Inv. (Urns)
to have access during normal business hours to certain lands
located within the Central weld sanitary Landfill (a/k/a Greeley -
Milliken Landfill) specifically within section 33 in Township 3
North, Range 66 West hereinafter referred to the "Site".
1. The purpose of aovses hereunder shall be to permit
designated representatives of U RS to enter upon the site
for direct soloion of thrU.S. Env
of
!inspection of the Site at the
rcseental Proteotion Agency
("OSEPA") , under the "Comprehensive Environmental
Response, compensation end Liability Act of lose", as
amended (cmecLA), including the right to take esalpiea or
splits of samples et air, water, soil, wastes or other
substances.
2. To secure access hereunder, individuals must notify the
site Saginaw at the Sits, 1037 77th Avenue, Oresluy,
Colorado 00634, telephone number (303) 330-2641, or his
designated representative, at a reasonable time prior to
the desired looses and present satisfactory evidence to
the Site Engineer, or his designated reprsssntative, that •
they ars rspr tatives of ORS. Prior to entering the
Site, such individuals shall:
• execute a document in duplicate in the form
•
ettaohed to this Agreement, releasing Grantors from
all liabilities for injuries or other damages of
any kind realised during or as a result of the
access, and representing and warranting to Grantors
the individuals. representative capacities for Urns.
• advise Orentors at the time of notification of
desired access of the looation(s), it any, from
which UPS repraaentative(s) shall obtain samples or •
splits of samples. Grantors shall be provided with
splits of any such simple' as specified herein.
• check in et the Site officio at the entrance gate.
Grantor's representatives, at the sole discretion
of Grantor, say accompany .no individuals while on
the Site.
3. *cows hereunder shall not permit drilling, boring or
oaring or taking of samples by ooze drilling without the
empress r esssne tier er(authorisation of grantors. If the aas
) securing nooses hereunder obtain any
samples from air, water, soil, wastes or any other
• substances, they Shall, prior to leaving the Site advise
the Site Engineer, or hie designated representative of
the types of samples, locations of taking, volumes taken,
protocol for the sample analysis, and method of
E00 ' 39mid 1N3W3& NtlW 31SWM W0d4 90221 ES . 02 d3S
971061
•
•
acquisition, Prior to leaving the Site, URS
representative(s) shall tender to Grantors' personnel a •
portion of each such mole or split of sample,
approximatelyequal in volume, weight and homogeneity to
the sample portion retained. All analytical results
therefrom shall be treated es preliminary and
confidential. The analytical results shall not be
released until a satisfactory galge has been performed.
4. URs or its representative(s) shall furnish Grantors
without charge with a copy of any report and attachments
thereto pretend rs d by O , its representative(s) or •
consultant(ss1p,,in oonasquence of Site acoess at the time
such is submitted to VSRPA. •
• 5. MS or its representative say, under this Agreement, take
photographs of site-related activities performed during
site visits, Duplicates of prints from each negative
• shall be provided without charge to Grantors within ten •
(10) days after such photographs are taken.
a. All activities undertaken by URs representatives at the
Site shell be per formed in a good and workmanlike manner
and in compliance with all applicable governmental
authorities, law, regulations, ordinances and codes.
7. Ulfa's exercise of its rights hereunder shall not
interfere with the operations of the Grantor at the site
and shall be in a manner as to cause the least possible
. amount of inconvenience to Grantor.
S. URs shall maintain or restore the portion of Grantor's
property upon which it enters in and to as closely as
reasonable possible a condition as when first entered.
Without limiting the generality of the foregoing, URs •
shall not cause from its activities hereunder (a) any •
accumulation of debris or waste, (b) any health hazard,
(o) any open pit or (d) any other dangerous condition to
exist upon Grantor's property.
!• as covenants and agrees 'that it will defend, indemnify •
and bold Grantor, its employees, officers, .directors,
representatives, agents and assigns harmless from and
against any and all dame a, liability, less, deficiency
or expense (including attorneys' tees, court costs and
other of ri itisa expenses)
and wi to tho t extent
resulting from URS's
the full amount of any sum which VRS say bedor on demand
obligated to may become
,
q pay on account et, all obligations,
liabilities, claims, accounts, demands, liens or
encumbrances, whether direct, contingent or sntial
and no matter bow arising, in any way relat to or
arising from, acts, conduct, omissions, contracts,
agreements or oo>olitmects of DRS, its Contractors, agents •
• and employees, that aro in anyway related to or arising •
from the exercise by UR0 of the rights herein granted or
the use or occupancy by ORS of the Grantor's property.
•
•
b00 ' 9Dtld 1N3W3DINeW 315tlM WOad 40121 e6 , 02 435
93 061
•
•
•
Upon the Grantor's notification to ORS of any claim lade •
representatives,
it, ite employees, officers, directors,
to indemnity
agents or anigqnne which us is obligated
•
the extent thatth.tlosrtor claim isAgreement,aus 1ily by to
gross negligence or willful misconduct of Grantor or its •
enpleyees, offioan, directors, representatives, agents
or assigns, ORS shall thereupon undertake to defend and
hold Grantor and its employees, officers, directors,
representatives, agents or assigns free and harmless
therefrom. If .URS fails to discharge or undertake to
defend against Ouch liability, than Granter say upon
writttentyntioso Coto ORS,
settle t the sacs and URs's
directors, representatives agents employees, otfi b
conclusively established y or assigns shall bt
of such liability to include in both the' settlementamount
aattttorp ys lees and courideration and the t costs) Granter
effecting such settlement. by Granter in• • 10. ORS shall not permit or allow any industrial, hazardous
or chemical wapto er any other toxic materials or
substances of any kind to enter onto the Grantor's
agrees property the activities of URS hereunder. ORS
to take
agree materials measures to prevent any such
waste ma rissubstances from entering onto the
of its Grantor's property.
� shall not permit the conducting
ofoitsatests to read any soil into presently
uncontaaiants andof groundwater. tots
defend the tamer from andMagainst an and hold harmless and •
losses, damages, costs (including rresponse l
and clean-upcosts), penalties, tines, liens, suits, liabilities,
judgements and expenses (including attorneys'
consultants' or experts'fees and, expenses) of every kind
and nature suffered by or asserted against the Grantor as
a direct or indirect result of a release or threatened release of a hazardous substance to the extent resulting
trot the activities hereunder of URi, its employees,
agents or contractors.
• 11. ORS and its contractor, at their expense, shall maintain
during the term of this A]1gqrrossent (1) workmen's
compensation insurance in accordance with the applicable
requirements of law (and shall ensure that any person or
•
entiety
property it to perform any activity upon the
(ii.) 13,000,000
blic liability insurance i suab n on amed ount
and
than 3,000,000 combined single limit per occurrence,
not lees
with coverages, including , liabilit,
for bodily injury, dea ad without limitation, liability
• property damage.
12. 111 individuals securing axons hereunder shall strictly
G• ranntor with
all site safety and as may be communiicaatted from tirements ime eto time blished by the Site by any personnel of Grantor.
500 ' 30tld 1N3W39NNdw 31.10M WONd ee :z1 E6 , ea d39
971061
13. This authorisation may be revoked by Grantor without
clause upon giving et reasonable written notice to ORS.
sshaaess ll be previously li fo one week troy the date hereof.this Agreement
14. �Communications I► 1 be directed tot
with this Access Agreement
for Grantors
Waste Management Disposal ,
Services of Colorado, Inc.
6037 77th Avenue
Greeley, CO 60636
Attnt Alen schesre
for URst
.VU Consultants Incl.
1096 16th Street, suite 700
CO $0303-1907
Attns I . Phillip Woodcock
Dated this day of , 1993. -
WAITS SANAGSNSNT DISPOSAL MIMICS '
OP COLORADO, INC.
sin
US CONSULTANTS, INC.
Fat
500' 30tld 1N3W3VtINGI4 315dM WOad 60131 E6. ea d35
931061
Tuesday, September 21, 199s -
Colorado health-care
re proposals
C-
n-
he ]though the official announcement aboard. Then the some public-health experts are calling
e- won't come until this week, details speed limit will be this an epidemic.
of the Clinton health-reform plan raised to 90 miles "Recent studies indicate that the cause
to emerged last week, and a Republican per hour. is a hormonal imbalance in males," a
nd counter-proposal also oozed into circula- "If you're just Schroeder spokesperson explained, "spe-
of tion. And I suspect we will see more plans the slightest bit cifically, an elevated level of testoster-
of once Colorado's political leaders join the sick, you'll feel one. If we could reduce the male level to
id. action: woozy," explained that of the biologically superior gender,
Vs ✓The Romer Regime: He took an oath an anonymous 26,092 lives would be saved every
lit that "the laws be faithfully executed."- " source familiar year."
lot , Even so, there's a leaky toxic landfill in ED with the plan. Details of implementation of a nation-
Weld County, cyanide from Summitvill "And if your wide testosterone reduction program
ily ' and coal dust at Redstone. QUILLEN timing is off even have yet to be worked out, the spokesper-
in , These may appear to be dereliction of just a little, you'll son said, "but I can assure you that ru-
ed duty,but they're actually part of a plan to dump your bike at 85 and your skull will mors that we are considering mandatory
en minimize Colorado health-care costs, look like last year's jack o'lantern.Scrape surgery to remove the testosterone-pro-
rn since rural care is expensive to up your body, and that's the end of it — during glands are totally without founda-
ys provide. no treatment or rehabilitation costs. It'll tion."
a Poison the hinterland, so that people save billions because there will be no sick ✓ The Lamm Plan: The former gover-
move to the city to get treated for myste- people; you'll either be fully healthy or nor, famous for his statement about hav-
ir rious ailments, and even those who aren't dead meat." ing a "duty to die," is now a public policy
id sick get scared and move. Once you de- ✓ The Brown Blueprint: Few details analyst.
y populate the countryside, no more need were available, but this apparently calls However, he could not be reached for
e for the state to waste money on hospitals, on Americans to eat more red meat. details on his health plan, as his office
r ambulances, clinics, immunizations, pub- ✓The Schroeder System: She may be said the proposal would not be complete
i- lic-health nurses and other nuisances in the only public official to address a major until he returned next week from a meet-
e the boondocks. factor in the American health problem. ing in Michigan with Dr. Jack Kevorkian.
✓The Campbell Cure: All Americans The leading causes of death among
over 16 will be issued Harley hogs, and young men aged 15.34 are violence and Ed oullle, of Saeda Is a former newspaper editor
' will be forbidden to wear helmets while accidents. They are so widespread that whoa,columns appear Tuesday and Sunday
• , 1 1 _ 1 re 1 •
,..+x,.41' .5 l,.. r• .0". -- - — �--
unwholesome and menacing dump,which of
Put the landfill necessity will drain toxic poisons into the Big
Thompson River,which joins the Platte tun-
ning through eastern Colorado and the many
somewhere else towns• �Colorado contains millions of
To The Tribune: acres of marginal lands far removed front
•
This letter supplements an earlier one,dat- rivers and streams and eminently suitable for
ed April 9,concerning the most urgent prob- large landfills. present
lems evolving from the gigantic Central Weld We,therefore,humbly suggest
that"Sanitary"Landfill. operators of Central Weld Sanitary Landfill
On Oct 13,Weld County commissioners take its vast tonnage of toxic waste to more
will hold a hearing at the Centennial Building 'suitable locations to cease and desist per-
in Greeley in Order to determine whether or manendy damaging rich central Weld Conn-
not this behemoth monstrosity will be ,ty countryside,farm lands and precious water
allowed to continue to grow. supply. Fred R.Rehrrter
As before stated, this writer owns an 80- Aurora
acre farm two miles downstream from this
9'19-4
*w tee . asus 101.01 **
Rtit7lSt •
This release is executed this day of
the purDes r i!
por ohs o — dintral weldSan ti a a o seauri_+s access
specifically Section 33 in Township S W i (■sltsry ,
Worth, Rangngee. s ii West.
I hereby certify that i ea an authorised representative of
DRS, Inc.
I, for myself and for ty heirs, successors and ass
•
forever, de hereby release, hold harmless and indeaaify Waste
te
Management Disposal Services, Inc, and their officers, agents,
any• independent
aer it o liabilities �oyess, suooessars and assigns, from
related to my entry onto the site or sight be eeeaelened by or
shall bhheaeby governed fe that fl conduct and activities at the site
by the terms of the Access Agreement dated
opera 103, grantee by Waste
• ws o ado r Inc. which I f rstand end
accept. ' ally understand and
•
•
•
•
•
•
•
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03 r. M mo M-rs a
EXPLANATION INTRODUCTION
The depth to the water table is a hydrologic factor that can be used
PTH TO WATER TABLE IN UNCONSOLIDATED ALLUVIAL and local officials to assist them in making decisions regarding I
DEPOSITS,'IN FEET BELOW LAND SURFACE conversion in the rapidly urbanizing Boulder—Fort Collins—tree
Less than 5 (index map)
5 to 10
10 to 20
Greater than 20
F--------------- AREA OF --
THIS REPORT
AREAS WHERE UNCONSOLIDATED ALLUVIAL DEPOSITS �` Fort Collins o Greeley
HI
ARE NOT PERENNIALLY SATURATED—Depth to seasonal
water table generally ranges from 5 to 20 feet.Where areas are Boulder
not irrigated,the deposits usually are drained by mid summer. DENVER
Where areas are irrigated, seasonal water table may remain l
41 through the growing season with drainage of deposits occur-
ring during the autumn Grand Junction
>' AREAS WHERE LOCALIZED WATER-TABLE AQUIFERS oColorado Springs
OCCUR IN COLLUVIAL, LANDSLIDE, AND WIND-
BLOWN DEPOSITS,AND IN CONSOLIDATED SEDIMEN-
TARY ROCKS WHERE ROCKS NEAR LAND SURFACE Pueblo
ARE FRACTURED AND WEATHERED-Aquifer materials COLORADO
may not be perennially saturated;depth to water table genet- l
ally ranges from 5 to 20 feet depth to seasonal water table I
generally less than 10 feet L------ -------------
AREA WHERE LOCALIZED WATER-TABLE AQUIFERS
OCCUR IN FRACTURED CRYSTALLINE ROCKS—Frac- MAP SHOWING AREA OF FRONT RANGE URBAN CORR
tures may not be perennially saturated; depth to water table
may be more than 100 feet
pth to water table generally less than 20 feet in localized areas of unconsolidated alluvial deposi6
wn on map)occurring in stream valleys traversing fractured aystdrme rocks.
CONTACT BETWEEN UNCONSOLIDATED ALLUVIAL DE-
POSITS AND OTHER DEPOSITS AND ROCKS.—Dashed This report presents the results of a 2-year investigation to determine th
where approximately located to the water table,water-table fluctuations and trends,and to relate thl
of the investigation to urban planning.The report is one of a series of r
EASTERN OUTCROP LIMIT OF FRACTURED CRYSTAL- and hydrologic reports prepared by the U.S. Geological Su•
LINE ROCKS demonstrate the usefulness of earth-science information in urban pl
e14.2 WELL WHERE DEPTH TO WATER TABLE WAS MEASURED In the Boulder—Fort Collins—Greeley area, the principal wantWHERE
aquifers consist of thick unconsolidated alluvial deposits that arc per
IN 1976 OR 1977—Number is depth to water table, in feet
below land surface. saturated.These deposits occur in present and ancestral stream valley
CS, Well completed in consolidated sedimentary rocks terraces both along present stream valleys and on slopes of the foothill
the Front Range (diagrammatic section).
F, Well completed in fractured-crystalline rocks
W, Well completed in windblown deposits
All other wells completed in unconsolidated alluvial deposits
03.6 WELL COMPLETED IN UNCONSOLIDATED ALLUVIAL
DEPOSITS WHERE DEPTH TO THE WATER TABLE WAS
MEASURED FOR AT LEAST 4 YEARS DURING
1971-75.—Number is average depth to the water table for the wlNoeLouaN wowsperiod, in feet below land surface (Data from Major, Kerbs, LULvawL OR LMosLDE DEPOSITS Lmlme w•Nnuae
Leeliad wor.ubN pail. quls
and Penley, 1975) U mmol nwra.e blapmiN drained
b,n Ma Pnof.Fd,Wr
o WELL COMPLETED IN UNCONSOLIDATED ALLUVIAL PRINCIPAL Wpen of RE AQUIFERS
DEPOSITS WHERE DEPTH TO THE WATER TABLE WAS 4 - ywa T al AQUIFE
p,wawlM FFnnuC
MEASURED BETWEEN 1955 AND 1975 TERRACES • PRESENT TERRACES
VALLEY
VA LE
(aAC'nll® IFbW elwnl
1mI d .-Nt60aOAI SEDIMENTARY Roots W91EH F She.'
wOralge F` '.laellllra wew -obs. j.a
_a mM ,• W—when,am UNCONSOLD- -
1 aaiFro t.esnd ela.Wr- W4L CCPOS
T.9lv.,R. W.,sea + - DIAGRAMMATIC SECTION SHOWING OCCURRENCI
Terrace
OF WATER-TABLE AQUIFERS
17.4
yi „ I , , l I , 931061
58 1960 1965 1970 1975 1977
a
- • RELEVANCE 10 maw RAPPING`
The depth to elk ester able a 1 Savant brae In planting for urban
devebprere as tamed by the folowag exempla .
A Depth to the ester table is Is than 5 Se either seasonal,or amualy.
1.The electivrnr of kdMbai data'wewe.disporl systems could
be reduced and'ntreatedaawncead andenteiheraidakeiet wean.Scene
brochette,
of the broc e,matrons aawiia3wah Individual w vidual w d+poed systems
ocar In the unattested sons below a adherent to the� system Brain the
wear,do not occur in wu ,de raw the daeh to the aster able,the
grazer the poadbil y that thee IMille floomptf-ma caveats'of
waste to an Mare that a na s haal&heat
2. ale tabilienif6rC ad."HalerotabInds
might
3.Sara ppblwnootdd eat lbs types of vegetation tateould be
grown In dust was would be dependent on la degree of the eWYy,but
even without any sanity problems,wry typos of wigwam could not grow
in them areas SELECTED REFERENCES
4. hM soljtme!'rtia tyhleh allot'1mb 1M us.d l red.mu d ewlw Colton. R.B., 1978, Geologic map of the Sadder—For Cans—Greeley5,a.enouedore w mu teal orhalftime.dadom amJd be hampered area,Colorado:U.S. Go I Su
by the low of ground aster into the coabtuaon excavations. I-855-G. �� rteY MkaBaneo'u Investigations Meg
6. Basements could be subject to coarse from water pressure and Jenkins,E.D., 1961,Records and logs of selected wells and tea hole,and
flooding. chemical and radfon attic analyses
The situations described in lens 4,5,and 6 also could occur in areas of ground cow- the Boulder area,
where the depth to the water table lra mote thin 10 feet either seasonally orColorado Curbs, L nda, and eyR.D.,1975,Selected
Report aster-level
el
untidy.
Major, T.J., Kerbs, Lynda Petty,, R D., 1975,Selected astw•le rd
B. Depth to the aster table related to depth of kaaladar records for Colorado. 1971-75( Colorado Water Consrwtlon Board
I. leesti _er a acid t atM"tictie l'wodtsosd Basic-Data Meese 37,356 p
/74 Yule nsa Schneider,P.A.Jr.,1962,Records and ktgs of selected was and test hole
rte! ,Sy•"'��� and chemical analyses of
_,l1 9r of late taaelagI dq.Arwn«pollution of tla ground Ys. ground aster in the South Rene basin n
wear.The praib ty of degradation a patabn would be dependent m the "'teem Adams and southwesternrBasic-Data
sc Weld Counties, Colorado Colorado
and amount ofwase,theWater Conservation and dome he s,L A, Report 9,84 p
NPedepth dbualdthe wen, the Schneider.P.A,Jr., tie , ,
annual depth of the water table in the ar of the landll«related type of wets and tat hole,and chemical analyses' Records and e ells *cud
may' _ Cache la Poudre River Colorado
d ground water o the lower
2. Ground aster could warinfriaaary saves. reel/, "'ail-Board basin, Colorade Colorado Water Conservation
a Board l a Poudre Report&fi0 p.
significant increase in the volume of waste totes pm«sad by waste-treatment Schneider,P.A,Jr.,and FWkr,D.E,1978,Hydrologic data for water-able
facilities. The volume of watts entering a laky sanitary sewer would be unities In the Boulder—Fort Collins—G area,
dependent on the depth ofburW ofawerad la second orannual depth to Corridor, Colorado U.S. 'wayenRle Reportnt Range Urban
-567,
the water table. 555 Geological Survey Open'Rle 78.567.
R
3.The placement of electric and telephone utility lints below ground and
the type of insulation and codats required for below-ground Installation
would be. in part, dependent on the depth to the aster table.
DEPTH TO TIE WATER TABLE
Measured depths to the aster table cluing 1976-77 in the unconsolidated
alluvial deposits ranged hr 0 to 45.6 feet Gwnenaly the depth to the water
table in the food plans of present streams was Is than 10 feet and,in many
bolas, it vas lea than 5 feet The depth to the aster table In ancestral
stream coleys,such a Beebe Drew,and In the tenaces ranged from 0.5 to
45.6 feet. Water levels windblown In wells completed in deposits, METRIC CONVERSIONS
consolidated sedimentary rocks, and fractured crystaline rocks w• e MULTIPLY BY I
measured only in Boulder County.Inthe corny,the depth to the water a z _ _ _ TO OBTAIN
rd es windblown deposits ranged from 3 to 12 let a the cwuoide.ad M Mile 0.6098 Meter
aedmmay rocks,it ranged horn 1 to 29 ant and In the fracturfracturedaywaitne 1.409 4047 He ectare
rocks,
a ngd hour 9 b 193 lestAene—_ —0.-
-NV"; Ql,tlare(,%
.
a r
r *
rte tar or ewm"at D,mawan U S Geoetrx Suer
Di,25/X6 nervy Can,., Deno CO 50725
9 '106'
-
STATE OF COLORADO REFER TO
Roy Romer, Governor
DEPARTMENT OF NATURAL RESOURCES 4.011. �4. O"iik
DIVISION OF WILDLIFE r`i` V r o
AN EOUAL OPPORTUNITY EMPLOYER Irbil /
Perry D. Olson, Director 4 2 6 1993 3 _, - 4
6060 Broadway —� O^, *
Denver, Colorado 60216 . , _ OF
Telephone: (303) 297-1192 • O'4mMi _ For Wildlife—
Larry Rogstad, District Wildlife Manager For People
Mr. Chuck Cunliffe, Director USR-1012
Weld County Planning Services
1400 North 17th avenue
Greeley, Colorado 80631
Dear Chuck,
Biologists from the Division have reviewed the material supplied by Waste
Services Corporation concerning the Milliken landfill. The facility has
been in operation for approximately 20 years. It is situated in an area
with natural seeps, a high water table, and agricultural runoff. Its close
proximity to the Big Thompson River and its confluence with the South Platte
River is of special concern.
Currently, Waste Services is operating the landfill in a manner that is consistent
with accepted practices and regulations for sanitary landfills. Unfortunately the
technology for designing an environmentally "safe" landfill probably did not exist
when this facility opened.. Under today's guidelines, a landfill may not have been
permitted on this site. The concerns of the community over movement of toxics
from the landfill onto adjacent land and waters is shared by the Division of Wild-
life. Waste Services Corp. finds itself saddled with finding solutions to problems
created by a lack of engineering in the past. Never the less, Waste Services has
an obligation to operate this landfill in a manner that will not have adverse im-
pacts on its neighbors or the environment. A special use permit allowing contin-
ued operation of the landfill should be based on this ideal.
Migration of organic cuipounds, heavy metals, leachate, and toxics in excess of
levels permitted by the E.P.A., Colorado and Weld County Health Departments onto
neighboring property should be considered unacceptable. Movement of such material
through runoff or groundwater could have serious negative impacts to the fishery
and wildlife resources in the South Platte Basin. Monitoring runoff and ground-
water on site and at the perimeter of the property should continue to ensure that
acceptable water quality is maintained.
Removal of volatile organics, metals, and other toxics fran waters and land should
be performed using approved methods for disposal of such compounds. Containment
of leachate and contaminated water until and during processing should occur in a
manner that would prevent exposure to wildlife. Preferably, the material could
be stored in closed tanks. If it is necessary to hold or process contaminated
liquids in open ponds, the ponds should be lined and screened or netted to pre-
vent access by birds and mammals
The plan calls for borrowing earth fran neighboring land for daily capping of
refuse. Large scale earth work often results in noxious weed problems. Waste
services should work with the Weld County Weed specialist to develop an aggres-
sive weed management plan. The plan should not rely solely on use of pesticides.
DEPARTMENT OF NATURAL RESOURCES, Hamlet J. Barry. Executive Director
WILDLIFE COMMISSION, William R Hogberg, Chairman . Dennis Luttrell, Vice Chairman • Eldon W. Cooper, Secretary
Felix Chavez. Member • Rebecca L Frank. Member • Louis F. Swift, Member • George VanDenBerg, Member • Larry M. Wright. Member
9:A06Z
•
The current status of the aquatic fauna in the Sparer Lakes seems to be in quest-
ion. The Division would request the opportunity to sample the Spomer Lakes using
nets and or electrofishing equiiment. Data collected from sampling would be a-
vailable to the Planning Department, Waste Services, or other interested parties.
We would also request the opportunity to resample the lakes on a yearly basis.
This would provide a long term data base on the lakes.
The Division would like to offer its services as needed to Weld County Planning
and Waste Services. If we can provide expertise or information that will assist
in creating an environmentally safe facility, please call on us.
Sincerely
Larry stad
cc Rick Moss, Habitat Biologist
Steve Puttmann, Aquatic Biologist
Katie Kinney, Area Manager
file
•
STATE OF COLORADO
COLORADO GEOLOGICAL SURVEY ot.c
Division of Minerals and Geology w_. °coy
• Department of Natural Resources J %VW
1313 Sherman Street, Rm. 715s lam*
Denver, Colorado 80203
Phone(3031866-2611 it FAX(303)866-2461 JUN 2 0 1993 Roy Romer
Governor
— Ken Salazar
Executive Direr
Planninn
Michael B.Long
Division Director
Vicki Cowart
•
State Geologist
and Director
June 24, 1993 WE-93-0011
•
•
Mr. Chuck Cunliffe
Department of Planning Services •
Weld County Administrative Offices
1400 North 17th Avenue
Greeley, CO 80631
Dear Mr. Cunliffe:
Re: Central Weld Sanitary Landfill- review of amendment application, special use permit -
No. 116
We have reviewed the materials submitted regarding the above reference application, the
general and engineering geology and hydrogeology of the site and vicinity.
We believe that this site and plan are problematical enough to raise serious questions as to
the advisability of placing significant additional quantities of municipal refuse at this
location.
Items of major concern include:
(1) Mapping by the USGS shows the bedrock immediately below the site to be the lower
Laramie formation and the Fox Hills (Colton, 1978) this means the principal regional
aquifer is close to the base of the land fill. The geologic and hydrogeologic characterization
of the site is inadequate to determine the risk of potential adverse impacts on the aquifer.
(2) The greatest portion of the proposed future trash volume is being placed on top of the
existing refuse, below which there is no liner or leachate collection system. This is clearly
not the intent of the soon-to-be-implemented subtitle D requirements. Also this situation
plus the existing contamination at the site will drastically complicate the future evaluation
of the various portions of the landfill if further contamination is documented in the future.
921.06*
Page 2,Weld unitary landfill,June 24,1993
(3) Flow path distance in the shallow aquifer is less than 2000 feet to the alluvial channel
of the Big Thompson River. Not withstanding the work of Robson as to the location of the
Denver Basin Boundary (and begging the issue of appropriate scale differences between a
regional study and a site specific study) the saturated alluvium overlying the Laramie - Fox
Hills aquifer is part of the recharge zone. given the highly variable, lenticular nature of the
bedrock below the site the number, location and relationship of the monitoring wells
proposed is inadequate without a great deal more detailed geologic and hydrologic
characterization of the site.
(4) Man made hydrologic intervention structures such as french drains and diversion
trenches are a justifiable means of avoiding or mitigating existing problems at an historic
landfill site. They do not constitute an acceptable method of site improvement for a
proposed facility in comparison to the availability of substantially superior terrain, geology
and hydrogeology to be found within the same general vicinity of this site.
(5) The pre-existing nature of this facility and the necessity to close it properly justifies
allowing several years of continued use of achieve acceptable slopes, grades and elevations
to improve the existing conditions and allow a properly functioning cap to be constructed.
Additionally, a two-to-three year phase out of this site will be advantageous with respect to
generation of revenues to defray the closure costs, allowing time to site, design and build
a replacement disposal facility and develop an environmental background data base using
the existing and any additional site monitoring to evaluate closure performance.
In summary we do not believe that the location and physical conditions at this site are
conducive to the operation of a sanitary landfill that can be demonstrated to be protective
of the public health and safety and the environment.
We recommend that a phase out period of no more than three years be established during
which time an acceptable closure plan can be implemented for this facility.
•
It is appreciated that the above comments are general in nature due to the constraints of
time and cost for this review. If additional needs or questions arise in this regard we will
try to accommodate the county to the best of our ability but additional costs will accrue.
Please feel free to contact us at your discretion.
Yours very truly,
Jeffrey L Hynes
Senior Engineering Geologist
JHB:\dln
cc: WSC B:\WE93011
Golder Associates
Amended Permit Application Review
Central Weld Sanitary Landfill
ATEC Project No. 41-07-93-00140
97,77—
I,v
JUL 0 81993
WELD Cu Nf4Ltn u•
_rl
n�
cl.
4tiaglgqo 478
4/44
Mr. Roger Doak, Project Officer
Colorado Department of Health
HMWMD-SWIM-B2
4300 Cherry Creek Drive South
Denver, Colorado 80222-1530
July 2, 1993
9"1061
Al EC Associates, Inc.
I V 8041 West I.70 Frontage Road North Una 11
Arvada Colorado 80002
(303)424-2832 FAX(303)424.4708
July 2, 1993
Mr. Roger Doak, Project Officer
Colorado Department of Health
■ HivfWMD-SWIM-B2
l 4300 Cherry Creek Drive South
Denver, Colorado 80222-1530
IRE: Amended Permit Application Review
Central Weld Sanitary Landfill
ATEC Project No. 41-07-93-00140
Dear Mr. Doak:
ATEC Associates, Inc. has completed the review of the above-referenced Amended Permit
Application. The purpose of this project was to review documents submitted by the
Applicant, Waste Management of Colorado, for compliance with the current existing
Colorado State Landfill Regulations. This review has been completed in accordance with
' our proposed scope of services, as outlined in the attached report.
Based on the data reviewed as part of this project, there appears to be substantial
information missing or issues that need further clarification. There are also several items
' which are not regulated under the current regulations; however, it may be prudent to have
the Applicant respond to those items listed in this report.
' We appreciate the opportunity to be of service to you on this project. Should you have any
questions regarding this report or desire any additional information, please do not hesitate
to contact us.
Sincerely,
ATEC Associates, Inc.
Kieth B. Fiebig, P.E. ID' :Nyle L Hothem, P
Project Engineer Corporate Senior Geotechnical Consultant
41c-Yrice.-1/
Peter Mih alilc, „-r; Jo A Mundell, P`
Manager, Environmental Division Corporate Director, Technical Services
A Subsidiary of American Testing and Engineering Corporation Consulting Environmental. Georecnnical and
lOffices in Maio:-U.S. Cities/Since 1958 Materials Engineers
931061
I
TABLE OF CONTENTS
I
LETTER OF TRANSMITTAL
TABLE OF CONTENTS
1.0 INTRODUCTION 1
Ll Orientation Meeting 1
1.2 Site Visit 1
1.3 Amended Permit Application Review 2
L4 CDH Peer Review Meeting 3
2.0 SUMMARY OF SITE CHARACTERISTICS 3
3.0 FINDINGS OF TECHNICAL REVIEW 5
4.0 SUMMARY AND CONCLUSIONS 9
5.0 QUALIFICATIONS 10
APPENDIX
oil Landfill Application Checklist
ATEC Letter to CDH dated June 11, 1993
CDH Letter to WMC dated June 15,.1993
List of Peer Review Attendees, June 18, 1993
11
1.0 INTRODUCTION
ATEC Associates, Inc. (ATEC) was selected by the Solid Waste Section of the
Hazardous Materials and Waste Management Division of the Colorado Department
of Health (CDH), to perform a review of an Amended Permit Application for the
Central Weld Sanitary J andfiil
The scope of work included an orientation meeting with representatives of the CDH
and the Applicant,a site visit,a review of the Amended Permit Application including
the available supporting documentation,a CDH peer review meeting and preparation
of the final report.
Ll Orientation Meeting
On June 2, 1993 Mr. Kieth Fiebig, Project Engineer with ATEC, met with Mr. Glen
Mallory and Mr.Roger Doak of the CDH Solid Waste Section and Mr.Alan Scheere
and Mr. Bill Hedberg of Waste Management of Colorado, the current landfill
owner/operator. The purpose of this meeting was to finnli7- the scheduled
milestones as well as to discuss the proposed methodology and basis for this review.
Subsequent to this meeting, ATEC performed a site visit and conducted a peer
review meeting with regulatory agency personnel to discuss our findings and
conclusions.
- L2 Site Visit
As part of the review procrsc, a site visit was performed on June 10, 1993 with
representatives of ATEC,CDH,Weld County Health Department and the Applicant
attending. The purpose of the site visit was to perform a cursory review of the
fn1ity and to familiarize the reviewer with current site conditions/operations. The
Application review process had been partly completed at that time and follow-up
1
921061
questions were directed at the Applicant through the CDH representative during this
site visit A letter outlining the questions raised during the site visit was submitted
by ATEC to the CDH on June 11, 1993 and subsequently transmitted to Waste
Management of Colorado on June 15, 1993. The June 11, 1993 and June 15, 1993
letters are included in the Appendix of this report
A brief"site walk-through"was given by Mr. Hedberg. A video of the walk-through
was taped by ATEC and a copy was submitted to CDH at the Peer Review Meeting
on June 18, 1993 (see Section 1.4).
13 Amended Permit Application Review
The statement of work included in the original OH-Request for Proposal (RFP)
generally outlined the basis and guidelines for the permit review. The amended
permit review was performed using, as the regulatory basis, the CDH supplied
I anrifitl Application Checklist and the current"Regulations Pertaining to Solid Waste
Disposal Sites and Facilities", Revised November 199L During the June 2, 1993
project initiation meeting, it was decided that this particular application would be
reviewed acing Sections 2.0 and 4.0 of the current State Regulations as the basis for
the existing landfilled area and for the proposed module/cell development The
documents provided by the applicant for the amended permit review were as follows:
(1) Site Development Plan for Central Weld Sanitary Landfill, Weld County,
Colorado", Sheets 1 through 18, prepared by RUST Environment &
Infrastructure (RUST E&I), revised March 1993.
(2) "Hydrogeologic and Geotechnical Characterization for the Central Weld
Sanitary Landfill, Weld County, Colorado" prepared by Golder Associates
Inc., revised March 1993.
(3) "Ground Water Monitoring Plan for the Central Weld Sanitary Landfill, Weld
County, Colorado" prepared by Golder Associates Inc., revised March, 1993.
2
f1:1061
' (4) "Landfill Gas Monitoring. Plan for Cenral Weld Sanitary I andfill, Weld
County, Colorado"prepared by Golder Associates Inc., revised March, 1993.
' (5) "Access Control Plan for Special Waste Identification at Central Weld
Sanitary Landfill" prepared by Waste Management of Colorado, Inc., dated
March, 1993.
(6) "Interim Ground Water Measures Plan, Central Weld Sanitary I anrifill"
prepared by Golder Associates Inc., dated March, 1993.
(7) "Design, Operations, and Closure Plan, Waste Services Corporation, Central
Weld Sanitary Landfill' prepared by RUST E&I, dated March, 1993.
(8) 'Amendment Application of Special Use Permit No. 116 for the Central Weld
Sanitary J andfill" dated March 31, 1993.
L4 CDH Peer Review Meeting
A peer review meeting was held on June 18, 1993 at the CDH. ATEC presented
general site information, a list of noted application deficiencies and concerns based
upon the review of the amended application documents. The basic forum included
the presentation of ATEC's findings followed by questions and riter+,csion of
particular issues relating to the application. A list of attendees present at this
meeting is included in the Appendix of this report.
2.0 SUMMARY OF SITE CHARACTERISTICS
The following general site description is presented only as a brief summary of the
proposed facility. For more detailed information of the site conditions and proposed
plans for this facility, please refer to the documents outlined in Section 1.1 of this
report.
3
931061
1
The existing landfill farility is located in Weld County,Colorado,five miles southwest
of Greeley and three miles northeast of Milliken. The landfill coven approximately
110 aces with an additional 100 acres of buffer zone property, recently acquired, on
the east, south and west sides of the landfill limits.
The Central Weld Sanitary Landfill is owned and operated by Waste Services
Corporation, a subsidiary of Waste Management, Incorporated. Mr. William
Hedburg, Division Vice President of Landfill Operations for WSC, is the site
operator.
The proposed final contours of the landfill will range from 4,770 to 4,870 feet
elevation. The surrounding undisturbed areas of the site range from 4,750 to 4,840
feet elevation. The general landfill development wall occur in six sequences. The
first sequence begins at the north end of the existing fill area and proceeds to the
south and east. A bottom liner wall be developed in the proposed Module 1
(approximately 6 to 8 acres), located in the northeast corner of the east half portion
Iof the site. The apparent available refuse airspace is reported to be 4,015,000 cubic
yards with an estimated 12 or more years of landfill life based on the proposed plans.
I
A landfill underdrain exists beneath the site which is generally located on the west
Ihalf of the site trending in a southerly direction. The underdrain outlets to an
existing Spomer Lake located within the buffer zone property on the west side.
I
The reported geology beneath the site consists of three major components; a surficial
iunconsolidated soil (eolium - wind-deposited silts and sands), an upper weathered
bedrock and a lower weathered bedrock. The bedrock is an Upper Cretaceous
Formation with interbedded to interlaminatrd silty fine sandstone and claystone.
The reported aquifers at this site exist in each of these layers.
I
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I
Upgrades of the existing french drain,runon and runoff drainage,and detention pond
systems are proposed as part of this amended application. The existing French drain
system will be completed on the western two-thirds of the northern perimeter and
will outfall into one of the adjacent Sportier Lakes west of the site. The rusting
perimeter drainage ditch will be enhanced by constructing two separate channels
within the existing channeL The existing detention pond will also be reconfigured
as shown on the Site Development Plans.
The proposed Module 1 (Sequence 5) is designed to have a 3-foot thick compacted
soil bottom liner with a permeability of 1 x 104 cm/sec. A leachate collection system
is also proposed consisting of a 1-foot drainage layer on top of the liner draining to
a collection trench and sump at the base of the landfill.
1 The proposed final cover system is planned for construction over the entire landfill
upon closure, with the exception to the existing cover layer placed on previously
completed fill areas generally located on the western-most slopes of the site. The
proposed cover system will be 4.5 feet of soil materials including 2 feet of compacted
1 soil designed to achieve a permeability of less than 1 x log cm/sec.
l 3.0 FINDINGS OF TECHNICAL REVIEW
This landfill amended permit application review included an initial coordination
meeting, review of documents submitted by the applicant, site visit, and a peer review
meeting with regulatory agency personneL The information obtained during this
process_was used to evaluate whether the amended permit application rom;+'ir with
Ithe existing landfill regulations in the State of Colorado. Due to this facility having
! been open for approximately 20 years and due to the proposed construction of a new
module/cell, the basis for regulatory compliance evaluation was limited to Section
2.0 - "Minimum Standards" and Section 4.0 - "Standards for New Facilities" of the
I
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1
f "Colorado Regulations Pertaining to Solid Waste Disposal Sites and Facilities",
' revised November 1991.
' The findings of this review indicate that there are several items which need to be
addressed or simply clarified by the Applicant, in order for this Amended Permit
Application to be in compliance with the existing State Regulations.
' Below is a list of items for which information could not be found within the
Application documents, or where insufficient information was presented to meet the
' apparent requirements of the regulations. Some of the items listed below may not
be explicitly required by the regulations, but have been included to help establish the
adequacy of the submittal. We recommend that the CDH review each item in
accordance with customary principles and practices acceptable to CDH policy. When
applicable, we have included the reference section of the State Regulations for each
of the issues listed.
IList of Deficiencies
I (1) Section 4.7.1 - The application should include a discussion of the facility
operator's qualifications, Mr. William J. Hedberg.
I (2, Section 4.7.1 - The person responsible for facility non-compliance issues and
the authority to take corrective action should be named within the application.
I (3) Section 4.73 - Waste types and their respective volumes in yards per day for
the expected landfill life should be included.
(4) A discussion should be included as to how different wastes are treated and/or
managed, once they are accepted at the gate (eg. sludge waste disposal
1 practices).
(5) Section 4.4 -The geology and hydrogeology at the site as well as the regional
geology and hydrogeology should be discussed in more detail. The regional
bedrock strike and dip, actual geological formations at the site, description of
confining characteristics,fracture patterns,typical hydraulic properties and the
vertical limits of the lower weathered bedrock are some of the items which
6
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•
could be included within the application. Additional information could be
( cited from published geological and hydrogeological literature.
(6) Section 4.1.4 - The applicant needs to present groundwater flow calculations
with respect to the distance of the closest down-gradient uppermost aquifer
water source.
(7) Section 45.1 - Surface water features within a 1-mile radius of the site was
provided; however, a 2-mile radius is required per the regulations.
(8) Section 4.5.6 - A more detailed diwssion of groundwater potential impact
from the site should be included, i.e., bedrock weathered or fracture zones,
confining layers, potential of c0nraminanr migration pathways.
(9) It is suggested that a leachate monitoring and management plan be prepared
and issued as part of this application.
(10) Section 43.4 - Detailed discussion regarding the shallow perched aquifer
observed at the site is insufficient. What effect will it have on the site, how
will the design control it, and what are the potential concerns?
(11) Section 4.6.2-The application states that the soil liner and cover systems will
achieve a specified permeability; however,supporting physical and hydraulic
testing data and the proposed compaction density and moisture content
specifications should be provided at a minimum
(12) Section 427 - The source of water for construction and nuisance control
purposes is the on-site detention pond and off-site nearby irrigation ditches.
The applicant should discuss the availability of these sources to confirm that
there is an adequate supply.
(13) Sheet 12 of 18 of the Site Development Plan shows the plan for upgrading the
western two-thirds of the north perimeter runon/runoff surface water
structure. It appears that there is no separate structure for runon/runoff
water, unlike the remaining perimeter diversion structure upgrades. The
applicant should clarify the difference between the two diversion systems.
(14) Section 4.7.13 -A conceptual plan for addressing potential surface or ground-
water contamination occurrence was not specifically outlined within the
application.
7
9 ;14>1
I
(15) Section 4.2.2 - The diversion runon/runoff structures were apparently
designed for a 24 hour 100 year flood event for predevelopment site
conditions. These structures should be designed for post-closure site
conditions. The applicant should clarify this apparent discrepancy.
(16) Sections 423 and 4.6.2-Data should be presented and discussed detailing the
type and quantity of cover and liner soil materials required and available, and
the proposed location of the borrow source should be indicated.
(17) Section 4.7S -Site fencing plan locations are shown on the Site Development
Plan and are generally dicntcca-d within the application;however,the type and
height of fencing to be provided should be included as well.
(18) The ground-water monitoring plan did not appear to address the following
issues and,although these may not specifically be required in accordance with
the regulations, they can be important and should be addressed by the
applicant.
}
- - Specific test methods of each analysis should be outlined as part of the
plan.
▪ Is well sampling equipment dedicated?
- Is field parameter stabilization required prior to sampling?
- What are the analytical detection limits and what if SW846 detection
limits cannot be achieved?
- A basis for monitoring well placement and well construction should be
given for the previously installed ground-water monitoring wells as well
as for those proposed. A discussion should also be given regarding the
adequacy of the well network for detection of potential contaminant
releases from the facility.
- The Plan could outline a specific statistical monitoring program to be
used for analysis after 8 sampling events.
- Published geochemical data from the region could also be compiled
and discussed for evaluation of long-term groundwater quality
monitoring and statistical approach considerations.
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9:1061
(19) Section 213 - Table 5-1 of the Groundwater Monitoring Plan outlines the
proposed analytes for each groundwater sample. The list of analytes appears
to be incomplete when compared to the listed analytes within the regulations.
(20) Section 2.2.8 - High wind closure criteria for the site should be addressed at
a minimum.
(21) Section 4.7.14 - The applicant should submit an estimated volume of water
needed for dust control, fire protection and construction purposes.
(22) Section 4.2.6 - The proposed Site Development Plan does not include the
previously completed areas along the western north edge to be covered
with the new cover system. At a minimum,the following should be submitted:
confirmation testing data for this portion and a dicrnnion that the required
2-foot thick minimum cover layer is present and is adequate for vegetative
protection against erosion, and is able to maintain waste isolation after
closure.
(23) Section 4.63(0-The applicant could present a graphical cross-section through
the proposed Module 1,showing the design, geologic and hydrologic features
and their relationship to the proposed cell.
(24) Section 4.8 - The Closure Plan could include more informational detail such
as frequency of inspections, monitoring, and duration of post-closure care.
(25) The issue of the shallow ground water observed within the landfill limits, in
most cases being less than 15 feet beneath the waste, should be discussed in
more detail. Module 1 also appears to be constructed with only 7 feet of
separation. These issues need to be clarified and discussed giving a basis for
compliance by the applicant.
(26) It is not clear when the proposed Module 1 will be constructed. The Site
Development Plan appears to indicate Module 1 on each of the phases or
sequences.
4.0 SUMMARY AND CONCLUSIONS
In conclusion, most of the deficiencies listed could be addressed by the Applicant
with a simple clarification or explanation and possible presentation of additional
information that may already exist We have summarized the primary areas of
apparent Application deficiencies as follows:
9
921061
1 •
• The shallow ground water is within the waste limits and the potential impact
of this situation could be detrimental to the site and surrounding areas.
Module 1 is proposed to be constructed only 7 feet above the apparent
ground-water surface. In accordance with State Health Department
guidelines, this waste isolation above the ground water should be 15 feet
' minimum
• The geology and hydrogeology at the site is not specifically defined. The
vertical extent of the lower weathered bedrock has not been defined. It could
not be determined which, if any, aquifer recharge basin could be effected by
the landfill
• The actual source, required quantity, available quantity and suitability of
adequate cover and liner soil materials was not discussed in the application.
Although, the volume of soil required for liner material is significantly less
than the required volume of cover material, it is unknown if an available
source of suitable material capable of meeting the permeability requirements
is on-site.
• The ground-water monitoring plan could be enhanced by including an
explanation and basis for the well network placement spatially, and possibly
by a dismission of the known or unknown integrity of the existing previously
installed monitoring points. The discussion of the potential impact from the
site to surface waters and groundwaters could be enhanced. Based on
detectable levels of VOC contamination previously observed, a discussion
could be presented to include potential contaminant pathways and how the
existing or proposed monitoring system would detect these potentials.
• ; Insufficient data and discussion was presented for the existing cover system on
the completed western portion of the landfill Apparently this area is final
covered and will not receive the "new engineered" cover system. Since it will
be part of the overall final cover system, the existing cover needs to be
evaluated for its adequacy in accordance with the State Regulations.
5.0 QUALIFICATIONS
Our professional services have been performed, our findings obtained, and our
recommendations prepared in accordance with customary principles and practices in the
fields of environmental science and engineering. This statement is in lieu of other
statements either expressed or implied. This company is not responsible for the
10
_ _ 9:1081
•
Iindependent cnnriusions, opinions or recommendations made by others based on this
Amended Permit Application review or the information used during the process of this
review.
This report is intended for the sole use of the Colorado Department of Health. This report
Imay not be used or relied upon by any other party without the written consent of ATEC.
The scope of services performed in execution of this evaluation may not be appropriate to
satisfy the needs of other users, and use or re-use of this document or the findings,
conclusions, or recommendations is at the risk of said user.
1
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f
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931061
I
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I
I
• APPENDIX
4 - - CDH I-anent Application Checklist
I - ATEC Letter to CDH dated June 11, 1993
- CDH Letter to WMC dated June 15, 1993
- List of Peer Review Meeting Attendees, June 18, 1993
931061.
I
SOLID WASTE DISPOSAL SITES AND FACILITIES
APPLICATION CHR.CKLIST
LANDFILL
FACIL7TY NAME (en 1 rit / CU i �An, to rri/ h y n.= tde id
IUnincorporated X incorporated City
GTht3AL DATA (4 .3) ) I�
:Se I/kitd ►�,,,,,r As' ,0o5d) _Caro ce5 c COin^aIO,.LaC.
OPERATOR (4. 7 i) y}/i2„ � ,�qq��
Name A/ ' 11/4 s7e• •r✓i ces GOP,00ra f,o u
Attention: W,!/id.„ C. MO djbefe •
Address : 4,o37. = a th Aiuer,u)s
City : Greeley State C 3 Zip /PC&J1
Phone : (.>b3 ) 336 - ;64/ /
QLal ' `' -ations Nol A/od/a'ed (5.°C-C- nc7<e1)
I Person responsible for c^r- ^tine nor-com.p ance
Name Not tow!' /sera note s1,
Address. . . .
I City - State Zip
Phone ( ) -
SITE DESCRIPTION (4 . 3 . 1)
IMailing Address �1,d( •
j/
Name • Cen�f')/ Weld 7t ,1 ) -ra ` y
I Attention //;aw, s sea/ kept) /
Address : e,O3 9. f-;-1, tQr! ue
City : es,ree 'r % State ! J • Zi= 2,7 :, J4
Phone : (10j) -_; - C4--11
Location • T-,m 5zr),1 Rng 6e, W Section 3,?
Area (4 . 3 .2) Total site ,2/f1 ac. Disposal area /JO ac.
:ours of opera-Ain (4 .7. 2)
lne (ay *Frmu�A sa#afaay Ybaim a 4'3OPm
fzr5onne( / ,/
__-'--d._- title classifica: on (4 . 7. 4) . •. . . . Yes
S ,ee Ser an.7.41/e fr Ocs y ti , pie ra h'c..t s
Closure _/a.-- e S�prcon s
Attended - capabie of coliect_ng a DDC Q ` . . CS/No)
I Er_ipment (4 . 7 5) ) Yes
See Secl o.., F. C of PAe DOC 'Yam-
Capable of placing in most dense volume (2 . 1. 4) it/No)
Lwater and sanitary facilities C/No)
Waste streams (4 3 3) /1k-f Co..29/6.4..
j
I n 4ceni ce c/secf 4.7/ of sit
fe3c. s,
•
Pao ! 1 01 i
931061
.i /� �
See 1•-1-e,•c _T oT ogle e ncfls i,ui/di it re cr7t;
' Commercial (1.2. 18) - Yes/No
Community (1.2. 18) Yes/No
! Industrial (1.2. 35) Yes/No
Asbestos (1.2.10) Yes/No
Inert Material (1. 2.36) Yes/No
Corstrution Demolition Yes/No
Special (1. 2 .71) Yes/No
Sludge (2 .2. 11) Yes/No
Quality determination
I
Other
' Volume (4 . 7 . 31
I
Total 300,000 CY/YEAR Sew} j,2 dos(
' Ve-Oat ^anion of waste
�s N� )
Hazardous Waste Exclusion Plan (2t ,g) _e No)
Service areas (4 .3 . 4) r-�'30 stuate knits/ /,(/44 Cog+ �1 t Access to site FI'orn s0ufh 4 '° z 6)C, af F�L ( 7-7•In /_ .l
See Sect 1.1 1)OC • J
' GEOLOGICAL DATA ( 4)
14f co•tsaidate .�t
3.
Surface r•-+- 1asad (allu ium) Data (4.4 .1) . . . . See .Sec7, ,1
' Name (Foil4n. e-AoY/ uarterna rho/rare
Type Wind-3 fD Sit c/Lbs E SOOrds yiro-
Thickness tp (M
' Consolidated Formation Data (4 4.2) / Sec 22.2..,-5.23Name . . t . owes-Jed- Wea efea/ _fecir ocA_ ad rAsni e. or el-Qoe cn it For Ion_ ) Upper <:t-eDac cces See l/3,
h
}..-iess UmB=o �L?=. „Dept, t0 Bedrock awe.fG10 =
t.
1.4;_ See /' 4 */ LwB = erAt(See /Vole /J Geological
hat ,s )
' re ho �cr ed /r n e rokr rrr% »m,'rtes/ aft %fs if -C-7
Structure (4 . 4 . 2 ) 1 /
Regional strike Nord tDip .ei,Te (/ im / // )
Geological structures Mea(r- Denver- r0►^ntct/ ion ` <5 a /yep re *f)
I Confining geological layers /tide 44-1
SITE STANDARDS (4 . 1)
Topography (4 . 1. 1)
MAXIMUM MINIMUM 1
Elevation air-70 Inc 374 Dec'e%/o,. al
Grades/slopes y'/ S Pr ' er5 rSec):
Precipitation /2. 6 rVYear 41.5. 1, P tech?) 4.5 Doc
-C9
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- . 9:1061
1 .
Floodplain (4 . 1.2, 4.5.5)
Located in 100 year flood plain (Yes 41, . . . SEcL. /`1 ? D0C
Aquifer recharge area (4 , 1.3) (Yes/No)
If yes source /Vote. '4
1 Groundwater travel calculation (4.1.4) #1
Distance between fill and ground water
1 (Upper most aquifer, perched water, water table)
(min 15 ft. ) (4.7.7) —6 to /2) Medic/e1=F ft.
Closest downgradient well (Discharge) 2000 ft.
I
04/4-": t5X/0 -s
Aquifer permeability Lw8 . 9.2wo-T cm. /sec.
1 Travel time ski years
Facility life • /o2 f' years
' Method of groundwater proa-=r- -4or} (4.z
lower- shat/cw Su), «Pgrades of of✓ei'siom o/i'1-ch 1 l
fr`Pne.la r&vt , hedroek , /noel,ele 1 -/t'ne.-//eac4tre r sle..t
I waste isolation (4 . 1. 5)
Main factors proposes/ moist e 2 Is 6endeet;,
set Nis tone/c/Arstona , a egua#r. cover-//i iei-
tnh±erl als.
Putresci=le wastes (2 .2.7)
Airport restriction Turbojet 10, 000 ' (Yes ':)
IPiston type 5, 000 ' (Yes'4
r:DR0L0G=0=._ DATA (4 . 5)
I •
Surface water features within 2 miles (4. 5. 1) . . . .
(Include 1 sprrJ'4ng`�) f /
Oid veer ,nG TcJe TeJures w,_tA;.n -Ike reiLflv'e
n. , rhdicic B_„ly 1k.v rlia!t'rc5 a , t/P A,
Surface water potential site impact evaluation (4 . 5. 6) (Y_s/Nc) 4/ 7
Domestic Wells within, miles CD No)
Groundutt_r tpui.e:;:Ylal sits impact SQ ivat:cr, (les/No) /licit *A
Ground water data (4 . 1. 6, 4 .5. 2)
Acu4 'er Aame 9epth (ft. ) Thic3ss (ft. ) Use Pace
jha7r 1n
ow rercded Note. '
I. ltwd 3 to 30 40 too 01 Domestic! WA NotP *4 Note
Hydrological data (4 . 5. 2)
I.
T /`
OG J 0 9210s,
1
Aquifer
Name 11gM LWD Pd?�d
Unconfined/confined 44 y 'E4 �'le
Hydraulic conductivity (cm./sec) mean `.eleVt0 2 5A/0 ' � �
3X/C_`
Hydraulic gradient (ft./ft. ) C.03 O.c.it Note 4ki
ISeepage velocity (ft/day) Arse 4/ No{•e t/ ,c4•
Specific yield (Percent %) / / #1
ISpecific retention (Percent %) r #/ sfr/
' Porosity, (Percent %) ASsumeK 30 30 */
Flow direction Soul"& Souf'h t . w./Aead
I
Permeability, (darcys) / ' / 1
Water table depth (feet) _3 la 23 60 O
ITransmissibility (c`2/sec) */ / -I,
t t
Storativity, S / / N v
I �, �,4
Water balance j m�
h0
l • 'r = Model �•GT3+E No)
ENGINE -TNG DSS=GN STAN: RDS (4 .2 , 4 . 6)
? =N=? (4 . 6 . 2) /ncdicie I 0n (• . . . . Sec) 6.0 D0C
Type Co rig pdcfre So i•i •
I Thickness -7
Constituents a rol a /eri a d cr'9»t hi.J-4^ g.o n e
Compaction Density (min 9 %) 4s/
I Atteberg Limits /
Design permeability (min 1. Ox 10- ' cen. /sec. ) Yes
7.eerhpi-e. ' 1 r ; ,C.-77- N-
I Propose th L/r 1 only Secf C.:2 'Oda -d- s�P
Construction QA/QC Plan / Nofe '�`/ Yes/C7
r L Test pad N° re #1 Yes •o
Amount / Source AY07Le 1*1
Construction quality assurance, PF rt ficat Yes tap
tom,/( aePrc ✓,c�ec� 7�
Construction water (4 . 2 . 7) Ail/st E 0C11 Pao P =1 CI /
9:71961
1I
Source mK 5/ to /'e/r-il io+.� 54t1c/ure Fr rn�.
iI Location / Cut Map (4. 6.3 a) sDP
P
1 Location / Fill Map (4. 6. 3 b) SD/
Cell minimum slope (4 7 7)
Type cut, Cut and fill--- es No, Trench--- Yes Nc ,
Cell specifications (4.7.7 eque.,<ce /thou S,"Shei..s file d
Number of cells or phases S Sseque-ncps
1 Size of cell or phase SD
Location of each phase or cell (4 . 6.3 , j) SUP
Runon/runoff Control (2.1.4, 4.2.2)
I Structure type 5,0/9
two C A,a rt /s d lam: na rf k 4 ea s 7 )0er/
Diversion design per, .ete,^ a /c -3 no.-f4 Er e&s-
Location map (4 . 6. 3 ,c) ear-
..-- SD / .S14, iott-! /3
IMaximum storm event design ( es/No) See /iliOiLe *S fecal. 4. 3..2 ACC
Diagrams (4 . 6 . 3 c,d) SDP
I Conceptual plan for surface water /
contamination (Yes , o (4.7.13) /fDre o''9
Agencies notified (Yes 'o / le ell
■ Within 5 working d.vs (Yes '�. °
[I Remediation plan (Yes -o
Within 30 days (Ye )
Remediation schedule (Yese I Cover material (2 . 1. 1, 4 . 2.5, 4 . 6. 1, 4 .7. 3) . . . . .
Daily Intermediate
!Thickness 6 ln, (min 6in") /,2 in min 12"
= ply
Amountnneeded 44 / CI "`Q"tl, w CY days
.Uote *rl Cc'
I • Location Al,-1-0 *--ti /./o fa + 4
Fencing (4 . . . 5) and access ----_-1 (2 .2 . 1 )
I 1/
e Ai !'P
Height dot AV
Materials N i-e sAj
Gates & signs --- Yes
Public assess control (2 . 1. 5) CS/No)
Unauthorized vehicle control (2 . s.3) .(CD No)
Other types of barriers
Location map (4 . 6. 3 , i) -50P
Monitoring well design (wet/dry wells) (4 . 2.4)
Accordance w/ Water Well and Pump Installation i�
Contractors Act (2 . 2 .4) _es No) /' - (_
Diagram of well layout _es No) (4 . 6 . 4) . . . . 1-,i -C..
Screened interval, material used (4 . 6 . 4) . . . . hi—(:-,
P e stf ?
91719S1
i , Tubing size waiver (Yes/No)
Modifications
4 1
ti
Location map (4. 6. 3 ,h) . . . . . . . . . je5 . . -G
1 Ground-water monitoring (2.2.3, 4.5.7)
•
Frequency (2.2.5) relarTeriV
i Parameters (2.2.3 a, 4 .5.7) See r+eim tM
Minimum groundwater parameters (Yes/No) Or clefjcieitcie Sl
1 Testing according to SW-846 0/No) • Eu, f'1, ,n relln`T
Statistical procedure
Cochran's approximation to the benrens-f' her student 's
t-test method (2 .2. 3, c) (Yes/No) Ate 47,1
Other method
•
Pre land1filling groundwater quality (4 .5.7) . .A/4 t 1
y.. Conc.Bpi4A( //i. #i
1i Gonoopt_onal plan for negative incident (Yes ' No (4 .7. 13) °
Agencies notification / •
1 Within 5 working days (Yes/No) ,(/p le
Remediation plan (Yes/Nc) if
I Within 30 days (Yes/No) u
Remediation schedule (Yes/No) y
Explosive gas monitoring (2x2. 6/ 2 .2.5, 2.4 . 4)
I 4—eauency V./drtelt
Conceptional plan for negative incident Yes No) (4 . % 13 )
Site boundary - 5 % by volume (L EL) - . _ . 6) (s/Nc)
Structures 1 % by volume (2.2. 6) _e /No)
Agencies notified /No)
Within 5 working days (Yes/No)
No Remediation plan (Yes /'o*e (
1 Within 30 days (Yes/No) e
Remediation schedule (Yes/ o7
IOPERATIONAL DATA (4 .7) n
Records (2 . 2 . 13 , 4 7 6) Sec". 7. Pt
Waste volumes ( ,�)
[L Water monitoring ( ,,,.--5
Gas monitoring ( ,-1
IApproved operational plan , ( c---
1 pe,ce D r
977 061
Construction as-built (
Operation variances ( ,.4 /
I Training program ( ) i(/o� mad
Special waste program ( ) ,,
Site safety plan ( ) 1
1 Emergency telephone number�ssli
Police /Vise '±I NS rer d
Hospital a Ci
IFire department (4. 7.11) n
Control plan n
Water source Mote aL a
I f43/oil stockpile r
recap
e-..z-ysiona Plans (4 .7.13 , 4.7.10)
IWindblown debris plan (4.7.12) es No) . . . . Sec/. 725-00C
Wind characteristics SE 57/6 ,,,,p It sec/. J. Dec
IWind Monitoring Method /4vrPntowe le t-
On-site 5P_.5
1 Off-site
National Weather Service Office Location
Pick-up frequency WAAn nece554y7 .1 ?S A 6,S Doc
On-site tic, No) /
IOff-site .0/No)
Highc:ind plan (Yes/No) L
I S - Temporaryr Sa. A / S DOG
enc:ng No) 6.
Working face size .reduction 41r no
IClosing criteria Sustained 40 **?= yes-/No A/olLe. #/
Gusts fr 55 MPH L 1 . Yes/Nc
I Pricing policy (Yes/No) A0 r re vd huts coot pollee(
Nuisance Conditions (4.7. 10) , df 9 A
Dust control plan ye5 n5eC b.. 7‘.,2 Doc
Water source (4 . 7. 14) 109./141 /Inland. AJD,D.
Volume needed (4 .7 . 14) Noho 44/
Odor control plan (2. 1. 1) SST F. 6,/ Doc
Vector control plan (2 . 1.4) _cj, 7. 4. 6 DOC
Burning control plan (2 _ 4) T: 7 6, F
Fkee 7 or.. 1
` :1.06'
I .
1
CLOSURE/POST CLOSURE_ DATA (2.4, 4.8)
IFinal surface contour�map (4 .8.3)
Finial grades No) ,SD? ski.
7
I Final cover (4 2 6) _ A
Will 2 feet be adequate (Yes/No) No te. # /
Cap design ≤xcJt for prey'ious/y co,«�lefect %/ dress
Thickness 4. S f,oet
ICompacted clay /, Sf�PT
Permeability /X/0'6 •
cm/sec
Other materials /1
iUncompacted unspecified soil 2-460/ ,IroT �Zt/ertf D.SF'f 1/ers.
Revege'tation plan 11 I/ Layer
JSCS approved (Yes/No) ^pp• S7LGSes /J44 ii w�// be ��cvccd .
e f se 4•/0
Drainage sec/. 4,3 Doc
1 Side slope (max 4: 1) M AX 4.7
IErosion control 411a/No) /Uofe tea
■ Isolation of waste C/No) .42i? 44,?
■
■ Construction QA/QC plan Ale It/
Notification
IDivision and county commissioners in writing 60 days prior to
closure (2 . 4 . 1) No) cat /O DQC,
:General public by placing a sign of satiable size at the entrance
60 days p_' or to closing Dec
(2.4 .2) e G'No) tD
IPrevention of further and unauthorized site usage plan, Fencing Gate
(2 . 4 . 3) iiiip No) Sect.
. /0 Dec
' Maintenance and Monitoring plan (4.8. 1, 4 . 8 .2) . . . . A/ote '�Q S c . . 40
/ Dcc
Insaectiena frecuency (4. 8 .2) . 440 Y.
I Ponding (2 . 1. 4) (Y2,1 go)
Erosion `taw/No) ,[/O'fe ,2
Runon / Runoff control (2 . 4.5, 4 . 8 . 1) •r:^/No) (4/ofe jr
Diversion structures (4 . 8 . 1) Ye /No)
Agencies notified (Yes/No)
Within 5
working days
•
(Yes/No)
) /70: ., ,7(4,
o 321061
I
Remediation plan (Yes 41, 'vie /
Within 30 days
(Yes/No)
Nuisance conditions (4.8. 1) e/No) 'Se &W
J Odors,-windblown debris, insects rodents smoke
Explosive gas monitoring (2.4.4, 4. 8.2) a/No)
1 Ground-water monitoring (2.4.5, 4 .8.2) Cr/No)
Blends in with surrounding (2.1.4) (Yes/No) "de 49
I Good esthetics appearance upon being filled Wet,
(2.1.4) (Yes/No)
IMaintenance period 10 years (Yes IV ,4,71e $/
NNotes : IJ l / l / ,J/
Cpu (P ne� be. TouH_ & iI- !,,'4t cioca sit N•S /c.,1'�v'lef R/
iay Al ,QllC� ; •
I /rot/del is implied or ;n-(et-
red A ..•'
1nc`orrta4-ton_ /rods
;m ono''of Inc_ ed o, A, A d pp 1,CGS /v"1.. /
�c �cI`r1citiD4tt iHcl�tc� ;k terbedhe fro
Li &ea�hered 6�1�/� /fry nine 54 I a, clays/o•ie;
1
refer- /aK+Ietared ss/•! Kd5TonE `a�
I4. SuccicceAT „icormed.on W 5 not Oro✓; or isu se
wA5 ,C4 o(iscasseel *lion"ash eat o its it to .sz7115251
I 51-afe re, + AI"isK /s.
/At
for Fredevelo,0,."e�•„f /0A4se,
". Des19 m. orwt /AJ ,
1 5!003,1 be ,e54- evelop AAA5edesc3A. 5frt ;•\--'5
I
I
I
I
.�
740e ,,
9730 st
ATEC Associates, Inc.
I V aoarw tt 1.70 Fronage Roadam.d N unit 11
Mvai Ca craao 80002
(3031 424.2832 FAX x3031 424-4708
I
June 11, 1993
Colorado Department of Health
HVi IWMD-SWIM-B2
4300 Cherry Creek Drive South
Denver, CO 8022=-1530
Attu Mr. Roger Doak
Subject Solid Waste Application Review
Central Weld Sanitary Landfill
1 ATEC Project No. 41-07-93-00140
Dear Mr. Doak:
■ As you have requested, this letter is to outline the questions raised during the site visit
yesterday with you and the landfill operator. Below is a summary of the items discussed
with you during the site visit
1) The application describes the proposed french drain and diversion structure for the
north perimeter and where they will be discharged; however, more detail should be
provided for the outlet system and the planned routes.
2) The application generally describes where the cover and liner soil materials will be
borrowed; however, the State Regulations Section 4.6 require an explanation of the
type, quantity, and planned borrow-area for cover (including daily, intermediate, and
final cover) and liner materials. A statement could probably be made regarding the
quantity of materials available versus the quantity of materials needed(Section 4.2_5).
3) All of the surface water diversion structures should be designed using a 100 year 24-
hour flood event. Based on verbage outlined in the Application, this was performed
only for some of the structures.
4) The type and height of facility fencing should be described in more detail in
accnrdaore with stet.- Peglilaranc Srctior ^. 7.".
5) High wind closure criteria should be included in the Application to provide for State
Regulations Section 22.8.
6) The State Regulations Section 4.7.14 requires explanation of the amounts and sources
of water to be used on site for dust control, fire protection, construction purposes,
and personnel use.
A Subsrarary of American Testing aria Engmeenng Corporation Consulting Environmental. Georecnnrcal aria
Offices in Major U.S. Cities/Since 1958 Materials Engineers
•
IColorado Department of Health
June 11, 1993
Page Two
' 7) The Application provides information on who the operator is;however,qualifications
of this person should be provided in accordance with State Regulations Section 4.7.1.
8) A spatial distribution of the engineering, geologic and hydrologic data and their
relationship to the proposed module 1 is requested in accordance with State
Regulations Section 4.63(f).
9) The proposed cover system of the landfill has been presented in the Application Site
Development Plan; however, there is a certain portion of the landfill in which filling
is complete and apparently covered. An explanation or documentation of the cover
' system in this area should be provided to insure an adequate cover system is or will
be provided (i.e. erosion potential, permeability, depth, etc.)
If you have any questions regarding this letter, please do not hesitate to contact us.
Sincerely,
ATEC Associates, Inc.
Kieth B.'Fiebig, P.E. %
Project Engineer
KBF/brn
71 e4
irA t
RESOLUTION OF THE BOARD
OF COUNTY COMMISSIONERS OF WELD COUNTY
WHEREAS, Waste Management Disposal Services of Colorado, Inc. ,
hereinafter "Services" owns and operates Central Weld Sanitary
Landfill, hereinafter referred to as "Landfill, " on property
described in Exhibit "A" attached hereto, hereinafter "Parcel A, "
pursuant to a Special Use Permit and Certificate of Designation
issued by the County Commissioners of the County of Weld, State of
Colorado, on or about October 6 , 1971; and
WHEREAS, Services owns certain other property fully-described
in Exhibit "B" attached hereto, hereinafter "Parcel B, " which is
adjacent to, and abuts, Parcel A; hereinafter Parcel A and Parcel
B are collectively referred to as the "Site" ; and
WHEREAS, the Weld County Department of Planning Services has
alleged that the Landfill operations violate the terms of the
Special Use Permit; and
WHEREAS, a hearing was held before the County Commissioners of
Weld County, hereinafter "Commissioners, " on or about April 5,
1993, at which the Commissioners adopted a Resolution finding
probable cause to believe that the Landfill was being operated in
violation of the Special Use Permit and scheduled a Show Cause
Hearing for October 13, 1993, to hear the matter on its merits and
determine what action, if any, should be taken based on the
evidence and the findings made thereon; and
WHEREAS, Services denies that the operation of the Landfill
violates the terms and conditions of the Special Use Permit or
applicable state and federal statutes and regulations; and
WHEREAS, Services has filed with the Commissioners an
"Amendment Application of Special Use Permit No. 116 for the
Central Weld Sanitary Landfill" dated March 31, 1993, and filed
931061
April 1, 1993, hereinafter referred to as "Amendment Application, "
which includes requests for approval of excavation of surface
material from Parcel B and the construction of wetlands on Parcel
B; which application contemplates continued operation of the
Landfill for an additional twelve to fourteen years and is being
reviewed by a number of agencies including the Colorado Department
of Health; and
WHEREAS, Services, on or about November 25, 1992 and January
7, 1993, applied to the Colorado Water Quality Control Commission
for a Colorado Discharge Permit for the
operation of the Landfill, which applications have been
consolidated and were the subject of public comment on September
21, 1993 in Greeley, Colorado; and
WHEREAS, Services filed an "Interim Measure Plan" on April 1,
1993 and a "Supplemental Interim Measure Plan "on or about May 27,
1993, which are pending with the Commissioners and the Colorado
Department of Health, and has filed an application for construction
of a French Drain which has been approved by the Colorado
Department of Health, Weld County Department of Health, and the
Army Corps of Engineers, and is pending approval by the Weld County
Department of Planning Services; and
WHEREAS, Services has filed with the Colorado Department of
Health and the Commissioners a Closure and Post-Closure Plan
intended to comply with all state and federal regulations
applicable to landfills operating after October 9, 1993; and
WHEREAS, An Agreement between Waste Management Disposal
Services of Colorado, Inc. and the individual members of the
"Ashton-Daniels Neighborhood Association" has been submitted to
this Board dated October 1, 1993 .
NOW, THEREFORE, the Board of County Commissioners of Weld
2
9?1061
County hereby resolve as follows :
1 . Closure Criteria. The Landfill will not exceed the
elevations, grades, and contours shown on Exhibit C attached
hereto. The maximum elevation will not exceed 4855 feet above mean
sea level . Landfilling and closure activities will proceed north
to south so that the maximum allowable height is reached soonest
along the northern part of the Landfill . Exhibit D-1, attached
hereto, is a computer generated digital photograph of the
anticipated appearance of the Landfill from the viewpoint on the
Telep property specified on Exhibit D-2, attached hereto. Exhibit
D-1 is intended to reflect the anticipated appearance of a Landfill
constructed to the elevations and grades specified in Exhibit C.
Even though Exhibit D-1 also depicts vegetation, the actual
vegetation to be installed during final closure will be as proposed
by Services, commented on by the parties to an agreement between
Waste Services and neighbors, and approved by the Commissioners and
the Colorado Department of Health, as part of the Closure Plan.
Any conflict between Exhibits C and D-1, shall be resolved by
giving effect to both as reasonably and completely as possible,
except that, to the extent any conflict exists between Exhibits C
and D-1, Exhibit C shall control .
2 . Closure Schedule. The target date for cessation of
waste disposal activities shall be December 31, 1996 , as depicted
in the schedule attached hereto as Exhibit E. In no event shall
waste disposal activities continue beyond December 31, 1997 .
Services will make good faith efforts to maintain the flow of
acceptable solid wastes to the Landfill at or above the current
rate to the extent within its ability. If, due to circumstances
beyond the reasonable control of Services, waste contours and
elevations sufficient to reach the final contours and elevations
depicted in Exhibit C are not reached throughout the Site on or
before December 31, 1996, waste disposal activities shall continue
only until waste contours and elevations sufficient to reach final
3
931061
contours and elevations are reached. If waste disposal activities
extend beyond December 31, 1996 , Services will complete the
installation of final cover and drainage controls within six months
of final receipt of waste. In no event shall activities necessary
for the installation of the final cover, cap and drainage controls
and initiation of vegetation extend beyond June 30, 1998 . Services
shall submit monthly reports to the Weld County Health Department
and to the parties to an agreement between Waste Services and
neighbors which shall include, in addition to any other information
regularly required by the Weld County Department of Health, a
report on the volume of solid wastes received at the Landfill,
including a breakout of the volume and type of special wastes
received at the Landfill .
3 . Special Wastes . Commencing with the adoption of
this Resolution by County, only those special wastes identified in
the three page portion of Exhibit F, attached hereto, shall be
received at the Landfill . Exhibit F consists of that list of
wastes, handling procedures and other specifications acceptable to
the Weld County Health Department. The handling and deposit of
such wastes shall comply with all laws, rules and regulations
applicable to such wastes at the time they are deposited in the
landfill, and any additional procedures or techniques specified in
Exhibit F.
4 . Groundwater and Surface Water. Services shall install
three additional monitoring wells on the southern boundary of
Services ' property to monitor the shallow groundwater flow, said
wells to be constructed and spaced as approved by the Colorado
Department of Health, in consultation with the Weld County Health
Department, as necessary, to intercept, sample, and test the
shallow groundwater.
These three wells shall be monitored, sampled and the samples
analyzed, to establish initially a baseline and, thereafter, to
4
931061
measure changes in water quality, if any, from the time the wells
are installed to expiration of the post-closure monitoring period
as established for the Site by the Colorado Department of Health
under laws and regulations applicable at the time the monitoring
period is established or modified. The protocol, including
sampling frequency and the parameters to be sampled are as follows :
the wells will be sampled initially for analysis of volatile
organic compounds (EPA Method 8240 or 8260) ; conditional on the
results therefrom, the frequency of monitoring and the parameters
to be sampled and tested shall be as determined by the Colorado
Department of Health in consultation with the Weld County Health
Department. Services shall provide test results of all samples
taken from the wells, promptly upon receipt of confirmatory results
to the Weld County Health Department.
Services shall undertake whatever remedial activities,
including the installation of additional monitoring wells, are
required by the Colorado Department of Health or other
jurisdictions having authority to require such remedial activities .
Any offsite monitoring and remedial activities are conditional upon
county or state officials being able to obtain access therefor.
5 . Future Use of Property. Services shall not pursue
any request for approval of waste handling, storage, transfer or
disposal activities on the Site beyond December 31, 1997 . The
Commissioners will act only on that part of the Amendment
application applicable to excavation and closure/post-closure and
remedial activities proposed for Parcel B. Services shall withdraw
its application for an amendment to the Certificate of Designation,
which application was filed on April 1, 1993, and, if approved,
would authorize waste disposal activities beyond December 31, 1997 .
Between the date of execution of this Resolution and final
cessation of waste disposal activities specified in Paragraph 3 of
this Resolution, no operation other than the landfill operation
historically conducted at the Landfill, closure and remedial
5
931061
activities and any other activities required by federal, state or
local agencies shall be allowed on the Site. Such activities will
be conducted in compliance with law and legal requirements
applicable to landfills operating after October 9, 1993 . Following
final closure of the Landfill, no portion of the Site shall be used
for handling, storage, transfer or disposal of waste whatsoever.
Closure/post closure activities and remedial activities, and any
other activities required by federal, state or local agencies may
be conducted on the Site. The present zoning is agricultural . Any
other future use of the Site will be subject to the physical
constraints of the Site, such as soil and slope stability, and
shall also be subject to all applicable land use, zoning and
permitting requirements, including public review and comment if
required by law. Services shall provide notices to the Association
at the same time as submittal to the County of applications for any
use other than that allowed as of right or under applicable zoning
at the time of application. Services agrees not to petition any
city or town for annexation of the Site, unless the terms of such
annexation include assumption by the city or town of the County' s
resolutions regarding the Site.
6 . Buildings . All buildings and other structures on
the Site shall be removed within six months of final closure of the
Landfill, and, in no event, later than June 30, 1998, except that
the residence, one additional existing building and temporary sheds
necessary for closure/post-closure or remediation activities may
remain. The one additional existing building and temporary sheds
shall be removed when they are no longer reasonably needed for
closure/post-closure or remedial activities . Services will not
construct any buildings on that portion of Parcel A visible from
Knister Farm as depicted in Exhibit D-1 that would further restrict
the view from Knister Farm as depicted in Exhibit D-1, except any
temporary buildings necessary for closure/post closure or remedial
activities . In no event shall any building on the Site be utilized
for the conduct of truck or equipment storage, maintenance or
parking, except as required to complete closure/post-closure or
remedial activities . Any future construction of buildings on the
6
931061
Site, other than those allowed, as of right, under applicable
zoning at the time of application, will be subject to the physical
constraints of the Site, such as soil and slope stability, and
shall also be subject to all applicable land use, zoning and
permitting requirements, including public review and comment if
required by law. Services shall provide notices to the Association
at the same time as submittal to the County of applications for any
use other than that allowed as of right or under applicable zoning
at the time of application. Telep, Hayes and Carlson reserve the
right to contest any use or structure which would alter the view
from the Telep (Knister Farms) property as shown on Exhibits D-1
and D-2 .
7 . Closure/Post Closure Plans . On or before October
9, 1993, Services shall submit to the Colorado Department of Health
and the Commissioners, for review and approval, a Closure/Post-
Closure Plan ( "Closure Plan" ) in accordance with rules and
regulations, including, without limitation, 40 C.F.R. Part 258
( "Federal Subtitle D" ) and 6 C.C.R. 100-7-2 ( "State Subtitle D" ) ,
applicable to landfills operating after October 9, 1993, and
requirements of Weld County and as provided under the terms and
conditions of this Resolution. The Closure Plan shall be subject
to review and approval by the Colorado Department of Health and the
Commissioners, and subject to review and comment by the parties to
an agreement between Waste Services and neighbors, the Weld County
Health Department and any other agencies to which the Colorado
Department of Health and the Commissioners are required to
circulate the Plan for such review and comment.
8 . Drainage from Telep Property (Known as Knister Farms) . If
existing or future conditions on the Site are shown to restrict
drainage from the Telep property associated with storm events or
historic agricultural activities on the Telep property so as to
interfere with such activities, Services and Telep shall consult
and cooperate in good faith in determining what steps are
reasonably necessary to mitigate such an impact on drainage and
Services shall take whatever steps are jointly agreed to by Telep
7
931061
and Services . Telep and Services reserve any and all rights at law
or equity to remedy any such occurrence.
9 . Compliance. All activities conducted on the Site shall
comply with all local, state and federal statutes, regulations and
ordinances including, without limitation, State and Federal
Subtitle D Regulations applicable to landfills operating after
October 9, 1993 . Those conditions that the County Department of
Planning Services have alleged as violations and that were
subsequently the subject of the April 5th Probable Cause hearing
will be addressed through Services ' implementation of their Interim
Measures Plan as it is approved by the Colorado Department of
Health and the Weld County Health Department and consistent with
the terms of the Agreement of October 1, 1993 . The terms of this
Resolution shall be enforceable by the Board as follows :
a) A Special Use Permit or Certificate of Designation may be
suspended or revoked for a failure to comply with the
terms of this Resolution, the approved closure plan and
the approved interim measure plan.
b) Mandatory or prohibitory injunctive relief to compel
compliance with this Resolution.
c) Withholding of building permits the issuance of which
would be inconsistent with the terms of this Resolution.
d) Any other available remedies under the Weld County Zoning
Ordinance and the Solid Waste Sites and Facilities Act.
Nothing in this Resolution shall be construed to infringe upon
the ability of the parties to an agreement between Waste Services
and neighbors to exercise the remedies available to them under said
laws . Time is of the essence in performance of this Resolution, it
being specifically understood that the purpose of this Resolution
is to provide for completion of all landfillinq, closure, capping
and landscaping activities within the timeframes provided in this
Resolution.
8
92011061
10 . Term of Resolution. The obligations of Services hereunder
are subject to the occurrence of all of the following conditions :
1) the issuance by the Commissioners to Services of a land use
permit allowing excavation of fill dirt from, and proposed remedial
activities on, Parcel B; 2) the issuance by the Colorado Department
of Health of a CPDES permit pursuant to the current application
filed by Services and acceptance of that permit by Services; and 3)
the adoption by the Commissioners of a Resolution approving the
Closure Plan submitted pursuant to Paragraph 7 . In the event any
of the conditions listed in the immediately preceding sentence does
not occur within 180 days from the date of adoption of this
Resolution, then this Resolution shall be null and void and shall
be of no further force and effect whatsoever and the Commissioners
will proceed to reconvene the Show Cause Hearing on revocation of
the Special Use Permit without the need for a Probable Cause
Proceeding. Upon occurrence of all three conditions, the
Commissioners shall dismiss the Show Cause Hearing with prejudice.
11 . Dismissal . The Show Cause Hearing scheduled for
October 13, 1993 is hereby dismissed without prejudice.
a:\resoluti
9 931061
ADDITIONAL PROVISIONS FOR 'ME
RESOLUTION OF THE BOARD
OF COUNTY COMMISSIONERS OF WELD COUNTY
A. Paragraph 5 of the Resolution is amended to add the
following language:
Services agrees not to petition any city or town for
annexation of the Site, unless the terms of such
annexation include assumption by the city or town of the
County' s resolutions regarding the Site.
B. Paragraph 6 of the Resolution is amended by the addition
of the following language:
Telep, Hayes and Carlson reserve the right to contest any
use or structure which would alter the view from the
Telep (Knister Farms) property as shown on Exhibits D-1
and D-2 .
C. The second sentence of paragraph 7 of the Resolution
shall be amended to read as follows:
The Closure Plan shall be subject to review and approval
by the Colorado Department of Health and the
Commissioners, and subject to review and comment by the
parties to an agreement between Services and neighbors,
the Weld County Health Department and other agencies to
which the Colorado Department of Health and the
Commissioners are required to circulate the Plan for such
review and comment.
D. Paragraph 9 of the Resolution shall be amended to read as
follows:
Nothing in this Resolution shall be construed to infringe
upon the ability of the parties to an agreement between
Waste Services and neighbors to exercise the remedies
available to them under said laws. Time is of the
essence in performance of this Resolution, it being
specifically understood that the purpose of this
Resolution is to provide for completion of all
landfilling, closure, capping and landscaping activities
within the timeframes provided in this Resolution.
931061
DRAFT 10/12/93
RESOLUTION OF THE BOARD
OF COUNTY COMMISSIONERS OF WELD COUNTY
WHEREAS, Waste Management Disposal Services of Colorado, Inc., hereinafter
"Services" owns and operates Central Weld Sanitary Landfill, hereinafter referred to as
"Landfill," on property described in Exhibit "A" attached hereto, hereinafter "Parcel A,"
pursuant to a Special Use Permit and Certificate of Designation issued by the County
Commissioners of the County of Weld, State of Colorado, on or about October 6, 1971; and
WHEREAS, Services owns certain other property fully-described in Exhibit "B" attached
hereto, hereinafter "Parcel B," which is adjacent to, and abuts, Parcel A; hereinafter Parcel A
and Parcel B are collectively referred to as the "Site"; and
WHEREAS, the Weld County Department of Planning Services has alleged that the
Landfill operations violate the terms of the Special Use Permit; and
WHEREAS, a hearing was held before the County Commissioners of Weld County,
hereinafter "Commissioners," on or about April 5, 1993, at which the Commissioners adopted
a Resolution finding probable cause to believe that the Landfill was being operated in violation
of the Special Use Permit and scheduled a Show Cause Hearing for October 13, 1993, to hear
the matter on its merits and determine what action, if any, should be taken based on the evidence
and the findings made thereon; and
WHEREAS, Services denies that the operation of the Landfill violates the terms and
conditions of the Special Use Permit or applicable state and federal statutes and regulations; and
WHEREAS, Services has filed with the Commissioners an "Amendment Application of
Special Use Permit No. 116 for the Central Weld Sanitary Landfill" dated March 31, 1993, and
9.31061
DRAFT 1C/12/93
filed April 1, 1993, hereinafter referred to as "Amendment Application," which includes
requests for approval of excavation of surface material from Parcel B and the construction of
wetlands on Parcel B; which application contemplates continued operation of the Landfill for an
additional twelve to fourteen years and is being reviewed by a number of agencies including the
Colorado Department of Health; and
WHEREAS, Services, on or about November 25, 1992 and January 7, 1993, applied to
the Colorado Water Quality Control Commission for a Colorado Discharge Permit for the
operation of the Landfill, which applications have been consolidated and were the subject of
public comment on September 21, 1993 in Greeley, Colorado; and
WHEREAS, Services filed an "Interim Measure Plan" on April 1, 1993 and a
"Supplemental Interim Measure Plan "on or about May 27, 1993, which are pending with the
Commissioners and the Colorado Department of Health, and has filed an application for
construction of a French Drain which has been approved by the Colorado Department of Health,
Weld County Department of Health, and the Army Corps of Engineers, and is pending approval
by the Weld County Department of Planning Services; and
WHEREAS, Services has filed with the Colorado Department of Health and the
Commissioners a Closure and Post-Closure Plan intended to comply with all state and federal
regulations applicable to landfills operating after October 9, 1993; and
WHEREAS, An Agreement between Waste Management Disposal Services of Colorado,
Inc. and the individual members of the "Ashton-Daniels Neighborhood Association" has been
submitted to this Board dated October 1, 1993.
NOW, THEREFORE, the Board of County Commissioners of Weld County hereby
resolve as follows:
2
921061
DRAFT 10/12/93
1. Closure Criteria. The Landfill will not exceed the elevations, grades,
and contours shown on Exhibit C attached hereto. The maximum elevation will not exceed 4855
feet above mean sea level. Landfilling and closure activities will proceed north to south so that
the maximum allowable height is reached soonest along the northern part of the Landfill.
Exhibit D-1, attached hereto, is a computer generated digital photograph of the anticipated
appearance of the landfill from the viewpoint on the Telep property specified on Exhibit D-2,
attached hereto. Exhibit D-1 is intended to reflect the anticipated appearance of a Landfill
constructed to the elevations and grades specified in Exhibit C. Even though Exhibit D-1 also
depicts vegetation, the actual vegetation to be installed during final closure will be as proposed
by Services and approved by the Commissioners and the Colorado Department of Health, as part
of the Closure Plan. Any conflict between Exhibits C and D-1, shall be resolved by giving
effect to both as reasonably and completely as possible, except that, to the extent any conflict
exists between Exhibits C and D-1, Exhibit C shall control.
2. Closure Schedule. The target date for cessation of waste disposal
activities shall be December 31, 1996, as depicted in the schedule attached hereto as Exhibit E.
In no event shall waste disposal activities continue beyond December 31, 1997. Services will
make good faith efforts to maintain the flow of acceptable solid wastes to the Landfill at or
above the current rate to the extent within its ability. If, due to circumstances beyond the
reasonable control of Services, waste contours and elevations sufficient to reach the final
contours and elevations depicted in Exhibit C are not reached throughout the Site on or before
December 31, 1996, waste disposal activities shall continue only until waste contours and
elevations sufficient to reach final contours and elevations are reached. If waste disposal
activities extend beyond December 31, 1996, Services will complete the installation of final
cover and drainage controls within six months of final receipt of waste. In no event shall
activities necessary for the installation of the final cover, cap and drainage controls and initiation
of vegetation extend beyond June 30, 1998. Services shall submit monthly reports to the Weld
County Health Department which shall include, in addition to any other information regularly
3
931061
DRAFT IC/b2/33
required by the Weld County Department of Health, a report on the volume of solid wastes
received at the Landfill, including a breakout of the volume and type of special wastes received
at the Landfill.
3. Special Wastes. Commencing with the adoption of this Resolution by
County, only those special wastes identified in the three page portion of Exhibit F, attached
hereto, shall be received at the Landfill. Exhibit F consists of that list of wastes, handling
procedures and other specifications acceptable to the Weld County Health Department. The
handling and deposit of such wastes shall comply with all laws, rules and regulations applicable
to such wastes at the time they are deposited in the landfill, and any additional procedures or
techniques specified in Exhibit F.
4. Groundwater and Surface Water. Services shall install three additional
monitoring wells on the southern boundary of Services' property to monitor the shallow
groundwater flow, said wells to be constructed and spaced as approved by the Colorado
Department of Health, in consultation with the Weld County Health Department, as necessary,
to intercept, sample, and test the shallow groundwater.
These three wells shall be monitored, sampled and the samples analyzed, to establish
initially a baseline and, thereafter, to measure changes in water quality, if any, from the time
the wells are installed to expiration of the post-closure monitoring period as established for the
Site by the Colorado Department of Health under laws and regulations applicable at the time the
monitoring period is established or modified. The protocol, including sampling frequency and
the parameters to be sampled are as follows: the wells will be sampled initially for analysis of
volatile organic compounds (EPA Method 8240 or 8260); conditional on the results therefrom,
the frequency of monitoring and the parameters to be sampled and tested shall be as determined
by the Colorado Department of Health in consultation with the Weld County Health Department.
4
931061
DRAFT LC/ .2/93
Services shall provide test results of all samples taken from the wells, promptly upon
receipt of confirmatory results to the Weld County Health Department.
Services shall undertake whatever remedial activities, including the installation of
additional monitoring wells, are required by the Colorado Department of Health or other
jurisdictions having authority to require such remedial activities. Any offsite monitoring and
remedial activities are conditional upon county or state officials being able to obtain access
therefor.
5. Future Use of Property. Services shall not pursue any request for
approval of waste handling, storage, transfer or disposal activities on the Site beyond December
31, 1997. The Commissioners will act only on that part of the Amendment application
applicable to excavation and closure/post-closure and remedial activities proposed for Parcel B.
Services shall withdraw its application for an amendment to the Certificate of Designation, which
application was filed on April 1, 1993, and, if approved, would authorize waste disposal
activities beyond December 31, 1997. Between the date of execution of this Resolution and final
cessation of waste disposal activities specified in Paragraph 3 of this Resolution, no operation
other than the landfill operation historically conducted at the Landfill, closure and remedial
activities and any other activities required by federal, state or local agencies shall be allowed on
the Site. Such activities will be conducted in compliance with law and legal requirements
applicable to landfills operating after October 9, 1993. Following final closure of the Landfill,
no portion of the Site shall be used for handling, storage, transfer or disposal of waste
whatsoever. Closure/post closure activities and remedial activities, and any other activities
required by federal, state or local agencies may be conducted on the Site. The present zoning
is agricultural. Any other future use of the Site will be subject to the physical constraints of the
Site, such as soil and slope stability, and shall also be subject to all applicable land use, zoning
and permitting requirements, including public review and comment if required by law. Services
shall provide notices to the Association at the same time as submittal to the County of
5
931061
DRAFT 1012/93
applications for any use other than that allowed as of right or under applicable zoning at the time
of application.
6. Buildings. All buildings and other structures on the Site shall be
removed within six months of final closure of the Landfill, and, in no event, later than June 30,
1998, except that the residence, one additional existing building and temporary sheds necessary
for closure/post-closure or remediation activities may remain. The one additional existing
building and temporary sheds shall be removed when they.are no longer reasonably needed for
closure/post-closure or remedial activities. Services will not construct any buildings on that
portion of Parcel A visible from Knister Farm as depicted in Exhibit D-1 that would further
restrict the view from Knister Farm as depicted in Exhibit D-1, except any temporary buildings
necessary for closure/post closure or remedial activities. In no event shall any building on the
Site be utilized for the conduct of truck or equipment storage, maintenance or parking, except
as required to complete closure/post-closure or remedial activities. Any future construction of
buildings on the Site, other than those allowed, as of right, under applicable zoning at the time
of application, will be subject to the physical constraints of the Site, such as soil and slope
stability, and shall also be subject to all applicable land use, zoning and permitting requirements,
including public review and comment if required by law. Services shall provide notices to the
Association at the same time as submittal to the County of applications for any use other than
that allowed as of right or under applicable zoning at the time of application.
7. Closure/Post Closure Plans. On or before October 9, 1993, Services shall
submit to the Colorado Department of Health and the Commissioners, for review and approval,
a Closure/Post-Closure Plan ("Closure Plan") in accordance with rules and regulations,
including, without limitation, 40 C.F.R. Part 258 ("Federal Subtitle D") and 6 C.C.R. 100-7-2
("State Subtitle D"), applicable to landfills operating after October 9, 1993, and requirements
of Weld County and as provided under the terms and conditions of this Resolution. The Closure
Plan shall be subject to review and approval by the Colorado Department of Health and the
Commissioners, and subject to review and comment by the Weld County Health Department and
any other agencies to which the Colorado Department of Health and the Commissioners are
6 921061
DRAFT 10/12/93
required to circulate the Plan for such review and comment.
8. Drainage from Teleo Property (Known as Knister Farmsl. If existing or
future conditions on the Site are shown to restrict drainage from the Telep property associated
with storm events or historic agricultural activities on the Telep property so as to interfere with
such activities, Services and Telep shall consult and cooperate in good faith in determining what
steps are reasonably necessary to mitigate such an impact on drainage and Services shall take
whatever steps are jointly agreed to by Telep and Services. Telep and Services reserve any and
all rights at law or equity to remedy any such occurrence.
9. Compliance . All activities conducted on the Site shall comply with all
local, state and federal statutes, regulations and ordinances including, without limitation, State
and Federal Subtitle D Regulations applicable to landfills operating after October 9, 1993.
Those conditions that the County Department of Planning Services have alleged as violations and
that were subsequently the subject of the April 5th Probable Cause hearing will be addressed
through Services' implementation of their Interim Measures Plan as it is approved by the
Colorado Department of Health and the Weld County Health Department and consistent with the
terms of the Agreement of October 1, 1993. The terms of this Resolution shall be enforceable
by the Board as follows:
a) A Special Use Permit or Certificate of Designation may be suspended or revoked
for a failure to comply with the terms of this Resolution, the approved closure
plan and the approved interim measure plan.
b) Mandatory or prohibitory injunctive relief to compel compliance with this
Resolution.
c) Withholding of building permits the issuance of which would be inconsistent with
the terms of this Resolution.
7
931061
.7a•ivo1
October 13, 1993
We are handing in at least the following exhibits:
ATEC Report July 2, 1993
Colorado Geological Survey letter June 24, 1993
Division of Wildlife stamped May 26, 1993
USGS map for Landfill area with legend
David C. Shelton publication edited 1977 "Governor's 3rd Conference on
Environmental Geology"
Access Agreement for EPA
ARCS
Water tests taken l David Hayes on Spomer Lakes (pond)
Signed Petitions cj"'ttcc 'kS C ) --aata/cfi4
Harold L. Daniels
V
Bzy�/e/�t
TO
S
931061
E,J lu+ L0
200 ' 39dd S9tP2C8E0E PC :9I E6 , SI 100
ctzblkrwut& 7447? c.
Attorneys At Law
1775 Sherman Street•Suite 1300
Denver, Colorado 90209
(303)861-1963•Fax: (303)832-4465
Ext. 123
October 15, 1993
MEMORANDUM
TO: LEE MORRISON AND MARIAN KING
FROM: GREG HOBBS
RE: COMMISSIONER'S RESOLUTION, CENTRAL WELD COUNTY
LANDFILL
•
Enclosed please find my suggested editorial revisions to the
resolution. I understand that Marian has sent Lee a diskette,
and I ask that these revisions be made to accord with the
agreement. I am uncomfortable with some of the paraphrasing
and I was not prepared to make an issue of this in front of the
Commissioners.
In any event, the gist of Commissioner Webster's motion was to
adopt a resolution which reflects the agreement. Since the
agreement requires incorporation of its terms into the
resolution, I have changed the paraphrasing to more accurately
state the agreement.
Also, I agreed with Marian today that the signatory parties to
the agreement would withdraw the Clean Water Act and RCRA citizen
suit notices, which I will accomplish forthwith, without the
necessity of reciting this in the resolution.
Accordingly, I request that the written resolution presented to
the Commissioners be revised for the record as enclosed.
I greatly enjoy working with the two of you and look forward
to continuing this relationship as the facility is being closed.
Best regards .
9:1061
ZO' d Si0' oN S2: 91 26, 91 130 S9blZ£8£0£: QI b81H
b00 ' 39dd SSPP2E8C06 98 :91 E6 , GI 130
OCT t4 '90 13 ' 20 FROM WASTE MGMT RCKY MTM TO 8324465 PAGE.0021009
4\ t S c EJkst.o ,4O.--C
DRAFT 10/14/93
RESOLUTION OP TID3 BOARD
OF COUNTY COMMISSIONERS OF WELD COUNTY
WHEREAS, Waste Management Disposal Services of Colorado, Inc., hereinafter
"Services" owns and operates Central Weld' Sanitary Landfill, hereinafter referred to as
"Landfill," on property described in Exhibit "A" attached hereto, hereinafter "Parcel A,"
pursuant to a Special Use Penult and Ccrdfivatc of Drdignation issued by the County
Commissioners of the County of Weld, State of Colorado, on or about October 6, 19'71; and
WHEREAS,Services owns certain other property fully-described in Exhibit "B" attached
hereto, hereinafter "Parcel B," which is adjacent to, and abuts,Parcel A; hereinafter Parcel A
and Parcel B are collectively referred to as the "Site"; and
WHEREAS, the Weld County Department of Planning Services has alleged that the
Landfill operations violate the terms of the Special Use Permit; and
WHEREAS, a hearing was held before the County Commissioners of Weld County,
hereinafter "Commissioners," on or about April 5, 1993, at which the Commissioners adopted
a Resolution finding probable cause to believe that the landfill was being operated in violation
of the Special Use Permit and scheduled a Show Cause Heating for October 13, 1993, to hear
the matter on its merits and determine what action,if any, should be taken based on the evidence
and the findings made thereon; and
•
WHEREAS, Services denies that the operation of the Landfill violaters the terms and
conditions of the Special Use Permit or applicable state and federal statutes and regulations; and
WHEREAS, Services has tiled with the Commissioners an "Amendment Application of
Special Use Permit No. 116 for the Central Weld Sanitary landfill" dated March 31, 1993, and
tiled April 1, 1993, hereinafter referred to as "Amendment Application,' which includes
9.3.461
V0' d S10' 0N 92: 91 £6. SI 130 S9VVZ£8£0£: QI ?J81H
900 ' 39Ud 994428880E 98 :91 86 , SI 100
OCT 1A '90 13 :29 FROM UMSTE MGMT RCKY MTN TO 9324465 PAGE.003•%009
DRAFT 10/14/93
requests for approval of excavation of surface material from Parcel B and the construction of
wetlands on Parcel B; which application contemplates continued operation of the Landfill for an
additional twelve to fourteen years and is being reviewed by a number of agencies including the
Colorado Department of Health; and
WHEREAS, Services, on or about November 25, 1992 and Jana sy 7, 1993, applied to
the Colorado Water Quality Control Commission for a Colorado Discharge Permit for the
operation of the Landfill, which applications have been consolidated and were the subject of
public comment on September 21, 1993 in Greeley, Colorado; and
WHEREAS, Services filed at "Interim Measure Plan" on April 1, 1993 and a
"Supplemental Interim Measure Plait "on or about May 27, 1993, which are pending with the
Commissioners and the Colorado Department of Health, and has filed an application for
construction of a Preach Drain which has Lazo approved by the Colorado Department of Health,
Weld County Department of Health,and the Army Corps of Engineers, and is pending approval
by the Weld County Department of Planning Services; and
WHEREAS, Services has filed with the Colorado Department of Health and the
Commissioners a Closure and Post-Closure Plan intended to comply with all state and federal
regulations applicable to landfills operating after October 9, 1993; and
WHEREAS,An Agreement between waste Management Disposal Services of CO made,
artJLf2
Inc. and the individual membess of the "Ashton-Daniels Neighborhood Association" has REfefw
tee A S
submitted to this Board dated October 1, 1993. "
N>Erbtl�s
w�cuDES
NOW, THEREFORE, the Board of County Commissioners of Weld County hereby sow(
resolve as follows: rlYE1 R
�tcl4 f" lava
A-NO (-1AyES,
2 A-00
&- sieso
CIKt.�Soh)
efWasitA)ecsese4t
931061
S0' d ST0' oN 92: 9T 26. ST 130 S9VVZ£8£0£: QI 2I21H
900 ' 39Nd S844Z£8E0£ LE : 9i £6 . _SI 100 t
OCT 14 '99 13:30 FROM WASTE MGMT RCKY NTN TO 8324465
PAGE.00.1/008
DRAFT 10/14/93
1. Closure Criteria. The Landfill will not exceed the elevations, grades,
and contours shown on Exhibit C attached hereto. The maximum elevation will not exceed 4855
feet above mean sea level. Landfilling and closure activities will proceed north to south so that
the maximum allowable height is reached soonest along the northern part of the Landfill.
cE.RTtFteC /
Exhibit D-1, attached hereto, Is a computer genera digital photograph of the anticipated
appearance of the landfill from the viewpoint on the Tdep props ty apccifusl on Exhibit O-2,
attached herein. Rxhibit D-1 is intended to reflect the anticipated appearance of a landfill
constructed to the elevations and grades specified in Exhibit C. Even though Exhibit D-1 also
depicts vegetation, the actual vegetation to be installed during final closure will be as proposed
by Services mmented on_by�he partites to an�gd�ment between Waste Services and
neigybtr and approved by the Commissioners and the Colorado Department of Health, as part
of the Closure Plan. Any conflict between Exhibits C and D-1, shall be resolved by giving
effect to both as reasonably and completely as possible, except that, to the extent any conflict
exists between Exldt its C and 1)-1, Exhibit C shall control.
2. Closure Schedule. The target date for cessation of waste disposal
activities shall be December 31, 1996, as depicted in the schedule attached hereto as Exhibit E.
In no event shall waste disposal activities continue beyond December 31, 1997. Services will
make good faith efforts to maintain the flow of acceptable solid wastes to the Landfill at or
above the current rate to the extent within its ability. If, due to circumstances beyond the
reasonable control of Services, waste contours and elevations sufficient to reach the final
contours and elevations depicted in Exhibit C are not reached throughout the Site on or before
December 31, 1996, waste disposal activities shall wallow only until waste contours and
elevations sufficient to reach final contours and elevations are reached. If waste disposal
activities extend beyond December 31, 1996, Services will complete the installation of final
cover and drainage controls within six months of final receipt of waste. In no event shall
activities necessary for the installation of the final cover, cap and drainage controls and initiation
of vegetation extend beyond June 30, 1998. Services shall submit monthly reports to the Weld
3
91061
90' d ST0' °N d2: 9T £6. ST 130 S967Z£8£0£:QI b81H
L00 ' 39td G91 71,20860C LE :9I E6 , GI 130
OCT 14 ' 93 13 :30 FROM WASTE MGMT PCKY MTN TO 8324465 PAGE.005/009
DRAFT 10/14/93
County Health Department and to the parties to an4meriatilietweert Waste services and
npjehbora which shall include, in addition to any other information regularly required by the
Weld County Department of Health, a report on the volume of solid wastes received at the
Landfill, including a breakout of the volume and type of special wastes received at the Landfill.
3. S,prd t_�tests. Commencing with the adoption of this Resolution by
County, only those special wanes identified in the three page portion of Exhibit P, attaehod
hereto, shall be received at the Landfill. Exhibit P consists of that list of wastes, handling
procedures and other specifications acceptable to the Weld County Health Department, The
handling and deposit of such wastes shall comply with all laws, nuts and regulations applicable
to such wastes at the time they are deposited in the landfill, and any additional procedures or
techniques specified in Exhibit P.
4. Groundwater and Surface Wulrt. Service shalt lnstalt three additional
monitoring wells on the southern boundary of Service' property to monitor the shallow
groundwater flow, said wells to be constnlcted and spacer] as approved by the Colorado
Department of Health, in consultation with the Weld County Health Department, as nrrnwry,
to intercept, sample, and test the shallow groundwater.
These three wells shall be monitored, sampled and the samples analyzed, to establish
initially a baseline and, thereafter, to measure changes in water quality, if any, from die time
the wells are installed to expiration of the post-closure monitoring period as established for the
site by the Colorado Department of Health wales laws and regulations applicable at the time the
monitoring period is established or modified. The protocol, including sampling &cgpnncy and
the parameters to be sampled are as follows: the wells will he sampled initially for analysis of
volatile organic compounds (EPA Method 8240 or 8260); conditional on the results therefrom,
the frequency of monitoring and the parameters to be sampled and tested shall be as determined
by the Colorado Department of Health in consultation with the Weld County Health Department.
4
931061
LO' d ST0' °N L£: 9T £6, ST 130 S9bfZ£8£02: 01 2181H
800 ' 3911d 59tfra8860E 8E : 9I E6 , SI 130
OCT IA ' 83 13:31 FROM WASTE MGMT RCKY MTN TO 032AA65 PAGE. 00S!009
•
DRAFT 10/14/93
Services shall provide test results of all samples taken from the wells, promptly upon
receipt of confirmatory results to the Weld County Health Department.
Services shall undertake whatever remedial activities, including the installation of
additional monitoring was, are required by the Colorado Department of Health or other
jurisdictions having authority to require ouch rcmodisl activities. Any offsite aluniloring and
remedial activities are conditional upon county or stale officials being able to obtain access
therofot.
5. Future Use gJ J?ropprty. Services Shall not pursue any request for
approval of waste handling, storage,transfer or disposal activities on the Site beyond December
31, 1997. The Commissioners will act only on that pan of the Amendment application
epplicab1e to excavation and closureipost•elOsure and remedial activities proposed for Parcel B.
Services shall withdraw its application for an amendment to this Certificate of Designation,which
application was filed on April 1, 1993, and, if approved, would authorize waste disposal
activities beyond December 31, 1997. Between the date of execution of this Resolution and final
cessation of waste disposal activities specified in Paragraph 3 of this Resolution, no operation
other than the landfill operation historically conducted at the landfill, closure and remedial
activities and any other activities required by federal, state or local agencies shall be allowed on
the Site. Such activities will be conducted in compliance with law and legal requirements
applicable to landfills operating after October 9, 1993. Following final closure of the Landfill,
nu portion of the Site shall be used for handling, storage, transfer or disposal of waste
whatsoever. Ciosure/post closure activities and renuxlial activities, and any other activities
required by federal, state or local agencies may be conducted on the Site. The present zoning
is agricultural. Any other future use of the Site will be subject to the physicel constraints of the
Site, such as soil and slope stability, and shall also be subject to all applicable land use, zoning
and permitting requirements,including public review and CommcommegiVestaptievtliw, Services ✓
shall provide notices to the Association at the same time as submittal to the County of
Et614 : Q
5
921061
80' d ST0' °N 82: 9T 26, ST 130 S9VPZ£8£0£:CI ?AIH
600 ' 39eld S9176268606 66 :91 66 , SI 130
pqGjr,a071009
OCT 14 '93 13:31 FROM WASTE MGMT RCV.Y hITN TO 8324n65
DRAFT 10/14/93 /
applications for any use other than that allowed/as of rlghtf under applicable zoning at the time ✓
of application. Services aarces not to petition aiiy city or town for a+nex?flop of Che Site sinless
y�terms o� "nexation include ass+≥+rnytion by y 0_T town of he ounty's rest ludons
regarding the Sim
6. Bum, All buildings and other suucituw on the Site shall be
removed within six months of final closure of the Landfill, and, in no avant, later than June 30,
1998, except that the residence, one additional existing building and temporary sheds necessary
for closure/post-closure or remediation activities may remain. The one additional existing
building and temporary sheds shall be removed when they are no longer reasonably neetded for
closure/post-closure or remedial activities. Services will not construct any buildings on that
portion of Parcel A visible from Knitter Farm as depicted in Exhibit O-1 that would further
restrict the view from Knister Farm as depicted in Exhibit 1)-1, except any temporary buildings
necessary for cloture/punt closure or remedial activities. In no event shall any building on the
Site be utilized for the conduct of truck or equipment storage, maintenance or parking, eactyt
as required to complete closure/post-closure or remedial activities. Any future construction of
buildings on the Site, other than those allowed. as of right, under applicable zoning at the time
of application, will be subject to the physical constraints of the Site, such as soil and slope
stability,and shall also be sub' t spy a ll is v drtta*,szo in shag emitting r Wrenn:11U t wisi
including ubbib�revview and comment ME° s rice s provide notice$to e R-
Association a e same me as submittal to the County o ap do��.odlatbd PP2 L
0vA
Teleu,Hayes and Goacoee.t'nS
n e et ,fight to conic t dpi the itL;Ii scuff " wh ch would ter a view from the crivi
et
'rely Waster Farms) property as shown on'Exhibits t)-1 mule, Tit
A-Douse()/
ASeF
7. ClosurttPost Closure Plaits. On or before October 9. 1993, Services shall R Up err
submit to the Colorado Department of Health and the Commissioners, for review and approval, u NOfi2-
hPPGeABiE
a Closure/Post-Closure Plan ("Closure Plan") in accordance with rules and regulations,
2oNi&6
including, without limitation, 40 C.F.R. Part 258("Federal Subtitle D") and 6 C.C.R. 100-7-2 ,v- -
('State Subtitle D"), applicable to landfills operating after October 9. 1993, and requirements t
cF
6 kPPL.tes-r a
971
60' d ST0' °N 6£:9T £6. ST 130 S9bbl£8£0£: 01 b811-1
0I0 ' 39Ud S9PPEESE0£ 6E :91 E6 , SI 1D0
, OCT l-1 '93 13:32 FROM WASTE MGMT RCKY MTN TO 902449S PAGE.008i008
DRAFT 10/14/93
of Weld County and as provided under the terms and conditions of this Resolution. The Closure
Plan shall be subject to review and approval by the Colorado Department of Health and the
Commissioners, and subject to review and comment by the eartieueurtAgreernent betwegp
Waste Service ana negahhors. the Weld County Health Department and any other agencies to
which the Coloxadu Department of Health and ttte Commissioners are required to circulate the
Plan for such review and comment.
i. Drainafe from Telex Property flCnown as j{nWer Faunal, if existing or
future conditions or. the Site are shown to restrict drainage }tom the Telep property associated
with storm events or historic agricultural activities on the Telep property so as to interfere with
such activities, Services and Telep shall consult and cooperate in good faith in determining what
steps are reasonably necessary to mitigate such an impact on drainage and Services shall take
whatever steps are jointly agreed to by Telep and Services. Telep and Services reserve any and
all sights at law or equity to remedy any such<xcturence.
9. Compjiatlga. All activities conducted on rho she shall comply with all local, stare
and federal statutes, regulations and ordinances including, without limitation,State and Federal
Subdile D Regulations applicable to landfills operating after October 9, 1993. Those conditions
that the County Department of Planning Services have alleged as violations and that were
subsequently the subject of the April Sth Probable Cause hearing will be addressed through
Services' implementation of their Interim Measures Plan as it is approved by the Colorado
Department of Health and the Weld County Health Department and consistent with the terms
of the Agreement of October 1, 1993. The tutus of Qua Resolutlo'n shall be enforceable by the
Board as follows:
a) A Special Use Permit or Certificate of Designation may be suspended or revoked
for a failure to comply with the terms of this Resolution, the approved closure
plan and the approved interim measure plan.
b) Mandatory or prohibitory injunctive relief to compel compliance with this
Resolution.
931061
OT ' d STO' °N 6£: 91 26, 91 130 S9VPZ£8£0£: UI 2181H
II0 ' 39bd S9VV2E86@E 041SI ES , SI 100
OCT 14 'Si 13132 FROM WASTE MGMT RCKY MTN TO 9324465 PAGE.009/009
DRAM' 10/14/93
c) Withholding of building permits the issuance of which would be inconsistent with
the terms of this Resolution.
d) Any other available remedies under the Weld County Zoning Ordinance and the
Solid Waste Sites and Facilities Act.
th; Yin this esolyid{fal a �,coast red to infri�fe upon the ability of the nartics
I an$eeme•t tlytween Wastg,Services and neighbors to exercise the remedies available le
them under said laws_ 'lime it alit essence in,.y4atformance of thisJtesolution. it being
cifi ity 1nderst ' ghat the n1 r� �f 11 Resol�tIon a to provide for cotnpiCtI0n Of a)≤
'wining cloture. capping snd,Jand&r pyng activities within tbgttmcftamcs eroxldod in this
Resolution.
•
10. Tenn of Resulu:i4et. The obligations of Services hereunder are subject to the
occurrence of all of the following conditions: 1)the issuance by the Comtniadoners to Services
of a land use permit allowing excavation of fill dirt from, and proposed remedial activities on,
Parcel B; 2) the issuance by the Colorado Department of Health of a CPDES permit pursuant
to the currant application filed by Services and acceptance of that permit by Services;and 3)the
u. Ntf adoption by the Commissioner of a Resolution approving the Closure Plan submitted pursuant
•
ce' to Paragraph). In the event any of the conditions listed in the immediately preceding sentence
,' �o,f does not occur within 180 days fawn the date of adoption of this Resolution,then this Resolution
Vm""' shad be null and void and shall be of no further force and effect whatsoever and the
/a'[` Commissioners will proceed to reconvene the Show Cause Hearing on revocation of the Special
R06u
Me Permit without the need for a Probable Cause Proceeding. Upon oecarre ace of all data
L.mJ.bf� Us
S conditions, the Commissioner shall dismiss the Show Cause Hearing with prejudice.
2
O Cti9t'. � 11. Dismissal. The Show cause Hearing scheduled for October 13, 1993 is hereby
`t t dismissed without prejudice.
t3 • QRj, T1 e_ CouQTY S'thFF 1 s O ( fiE.cT'F—!0 '('p
.gem Mr- r w %Tb4 Nt� tic Ft1302S !iarok2AiN0 -sine-tc .
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Waste Management of North America,Inc.
Ns/J�/Western Region
18500 Von Kaman Avenue•Suite 900
v Irvine, California 92715
714/474-2311
October 21, 1993
Mr. Lee Morrison
Assistant County Attorney
P. O. Box 1948
915 Tenth Street
Greeley, Colorado 80632
Re: Central Weld Sanitary Landfill
Greg Hobbs' October 15 Memo
Dear Lee:
As we discussed yesterday, I am forwarding Waste Services' response to Greg Hobbs'
requested changes to the Resolution adopted by the Commissioners on October 13.
It is my understanding from our conversation that there is no clear procedure for
malting changes such as those requested after a Resolution has been adopted and signed
by the Commissioners. I understand al o t, however, that
Commissioners an t you d ask them
how they
to present
Greg's
request and Waste Services' response
wish to handle the request.
Most of Greg's suggested changes are editorial in nature, and we would not oppose
making such changes. The changes included within this category include those in
Paragraphs 1, 2, 5 (the last line on page 5 and the first line on page 6), 7, 9, and 10.
Greg has proposed other changes that would impact language you had suggested for
inclusion in the Resolution. These changes would include his proposed deletion of the
words "if required by law" in the references to public review and comment in
Paragraphs 5 and 6. Waste Services will defer to you on these proposed changes.
There are two proposed changes that we do not believe are appropriate. Greg's
proposed language in the recitations on Page 2 of the Resolution does not parallel
language in the Agreement. Even though the Agreement does address the obligations
of successors in interest, the Agreement was not entered into by such successors.
Therefore, we recommend that this change not be made. The proposed addition of
Paragraph 12 on road paving is not consistent with the Resolution adopted by the
Commissioners. It i.s my understanding that this matter was acted on separately by the
G
OCT 21 ' 93 14: 08 74 757 2508 PAGE . 002
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Mr. Lee Morrison - 2 - October 21, 1993
Commissioners on the 13th and that this matter has been addressed in a separate
resolution. We recommend, therefore, that this change also not be made.
As I indicated in our conversation, except for those two items in the immediately
preceding paragraph, we are not opposed to changes in the Resolution as specified in
Greg's letter as long as a procedure is followed that will not jeopardize the validity of
the Resolution. Please call me if you have questions or need additional information.
Very truly yours,
Marian King
Sr. Environmental Counsel
/bam
cc: Greg Hobbs - Hobbs, Trout & Raley
cws4mk9
OCT 21 ' 93 14 : 08 74 757 2508 PAGE . 003
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