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Home My WebLink About931595.tiff Waste Services Corporation 6037 77th Avenue Greeley. Colorado 80634 C. ' A Waste Management Company 303/330-2641 41, ?5 C, r,- March 4, 1993 Trevor Jiricek Weld County Department of Health 1617-16 Avenue Court Greeley CO 80631 RE: RESPONSES TO WELD COUNTY DEPARTMENT OF HEALTH (WCDH) COMMENTS ON THE GROUNDWATER MONITORING PLAN FOR CEN 1'RAL WELD SANITARY LANDFILL (CWSL) Dear Mr. Jiricek: This letter is in response to the WCDH comments of October 30, 1992 concerning the groundwater monitoring plan for CWSL. During our meeting on October 6, 1992, it was mutually agreed that CWSL would provide responses to WCDH review comments once the Colorado Department of Health completed it's review of the groundwater monitoring plan. The CDH provided comments to CWSL regarding their review of several documents (including the groundwater plan) in a letter dated December 21, 1992. Subsequently, a meeting was held on January 20, 1993 between CDH, WCDH and CWSL to discuss CWSL's preliminary approach for responding to each issue and to discuss the time requirements necessary to provide an adequate response. After the January 20, meeting CWSL finalized its response to CDH and submitted it on February 5, 1993. This letter will address WCDH comments which are reiterated below, followed by CWSL's responses. The responses were prepared with the assistance of Golder Associates, Inc. WCDH Comment No 1: "All monitoring wells previously monitored on the facility must be monitored on a quarterly basis at a minimum. This includes monitoring wells GWMW-5, GWMW-5N and all seven (7) "deep" monitoring wells referred to in this document. The division feels it would be inappropriate to abandon GWMW-5 at this time. The deep monitoring wells must be monitored quarterly for a minimum of eight (8) quarters to establish background concentrations. After these concentrations have been established the facility may request that the sampling frequency be amended. " 931595 wp51\as\letter\02229311.wch , F: CWSL 3.2.93&4.1.6.93 91 1;,06 Ex11; &F M Letter Trevor Jiricek March 4, 1993 Page 2 CWSL Response: All monitoring wells including deep groundwater monitoring wells will be monitored for eight consecutive quarters for the parameters to be agreed upon by the CDH and CWSL. WCDH Comment No 2: "On page 9 the document refers to four (4)permitted wells downgradient of the facility which "warrant discussion". The division requests that the facility develop a monitoring protocol for these four (4) wells and that they are monitored quarterly for a minimum of eight (8) quarters. The facility may request an amendment to the Groundwater Monitoring Plan after eight (8) quarterly sampling events have been completed. " CWSL Response: During the January 20, 1993 meeting CDH and WCDH agreed with concerns raised by CWSL regarding the capability of samples collected from the private wells to identify impacts from the landfill. These four (4) wells are identified by permit #15091, #765, #11090 and #90580. As we discussed, sampling groundwater from these wells is unlikely to provide reliable information for comparison to groundwater quality at the landfill due to (1) the demonstrated limited extent of impacts to groundwater from the landfill, (2) different or unknown completion depths and geologic conditions of selected private wells, (3) unknown completion techniques for the private wells, and (4) other potential impacts to groundwater quality. 1. Limited Extent of Impacts to Groundwater from the Landfill Additional hydrogeologic characterization activities conducted at the site subsequent to submittal of the " Hydrogeologic and Geotechnical Characterization Report " revealed that volatile organic compound concentrations in the shallow groundwater are limited to less than 200 feet south of the landfill (see letter report entitled "Expanded Hydrogeologic Investigation at the Central Weld Sanitary Landfill," October 23, 1992). Of the four (4) private wells referenced by WCDH, well permit #'s 765, 11090 and 90580 are downgradient of the landfill. The closest well is approximately 2000 feet from the landfill and the farthest is approximately 4500 feet from the landfill. Based on these data, the downgradient wells are at least 10 times farther from the landfill than the extent of detectable volatile organic compounds. This indicates that analyses of groundwater from the private wells will not provide useful information for comparison to the groundwater quality at the landfill. wp51\as\letter\02229311.wc6 F: CWSL 3.2.93&4.1.6.93 931.06A M / Letter Trevor Jiricek March 4, 1993 Page 3 Since the remaining well (#159091) is located upgradient approximately 500 feet from the landfill, it would be inappropriate to use this well to determine impacts from the landfill. 2. Different or Unknown Completion Depths and Geologic Conditions of Selected Wells Table 1-2 of the "Hydrogeologic and Geotechnical Characterization Report" includes depths of the wells (permit #765, #11090 and #90580 ) as provided by the State Engineer's office. The depth of well (permit#159091) has not been reported to the State Engineer's office. However, as previously indicated, this well is upgradient of the - landfill. As shown on table 1-2, the well with permit #765 is completed to depth of 263 feet. Additional information subsequently obtained from the State Engineer's office indicates that the screened interval for the well with permit #765 is from 233 to 263 feet below ground surface. The screened interval is approximately 200 feet deeper than the shallow aquifer beneath the landfill. This well is located approximately 4500 feet from the landfill. Based on the distance of the well from the landfill, its deep completion interval and the absence of any detectable contamination in onsite deep wells, sampling of this offsite deep well is not necessary. The wells with permit#11090 and #90580 are completed at shallow depths (i.e. less than 40 feet) below ground surface. Of these two wells, geologic information is available for only the well with permit#11090. These wells are located approximately 3000 and 2000 feet east of the landfill respectively. The great distance from the landfill to these wells renders geologic and hydrogeologic interpretation unreliable due to the great intervening distance for which no data exists. Furthermore, as is typical, the geologic data collected during drilling of these wells is incomplete and inadequate for proper comparison to the data collected at the landfill. No geologic data exists for well #90580 and the geologic data collected for well #11090 included only three units: gravel, clay, and sandstone. Gravels were the predominant geologic unit identified for this well. No gravels were encountered at the landfill. Accordingly, it is not possible to reliably correlate the geology at the landfill to the geology at this shallow well. 3. Unknown Completion Techniques The drilling and completion techniques used on the downgradient wells are unknown but were likely much less stringent than the drilling and completion techniques used to complete the monitoring wells at the landfill. Incomplete decontamination procedures, inappropriate well completion materials (such as carbon steel, grease, oils, etc.) and inadequate well maintenance and security often render data collected from the monitoring of private wells unreliable. 4. Other Potential Impacts to Ground Water Quality N wp51\as\krtcr\02229311.wch 9 106 P: CWSL 3.2.93 8 4.1.6.93 Letter Trevor Jiricek March 4, 1993 Page 4 In addition to potential impacts from CWSL to surrounding ground water quality, land use impacts including agricultural practices can impact ground water quality. For instance, pesticide and fertilizer application, equipment maintenance and septic systems, all may have potential impacts not attributable to CWSL. WCDH Comment No 3: "Spomer Lakes and the "underdrain" must be included in the plan. Both must be sampled during each sampling event, and analyzed for the same parameters as the monitoring wells. " CWSL Response: Prior to 1992, WCDH sampled the underdrain parameters it deemed appropriate, which included only inorganic constituents. In 1992 CWSL initiated its own monitoring program for the outfall. Since July 1992, CWSL has monitored the outfall for parameters similar to those sampled as part of the hydrogeologic study. CWSL will continue to monitor the outfall during each groundwater sampling event and will analyze for the same parameters as the monitoring wells as agreed to in response to comments #4 and 6. As discussed during the January 20, 1993 meeting surface water sampling at the site including the underdrain, will be regulated by the Water Quality Control Division and will be coordinated with the Solid Waste Division of the CDH. Therefore it would be inappropriate for the Spomer Lakes and the underdrain (surface water sources), which will be subject to permit conditions when issued, to be included in the groundwater monitoring plan at this time. Accordingly, it is understood that this particular comment is no longer applicable. WCDH Comment No 4: "In addition to the proposed inorganic analytes listed in table 5-1, analysis must include Barium, Chromium and Nickel. Also radionuclides must be monitored in all monitoring wells for a minimum of eight (8) quarterly sampling events. The facility may request an amendment to the Groundwater Monitoring Plan after (8) sampling events have been completed. " CWSL Response: CWSL agrees to add barium, chromium and nickel to the parameter list in Table 5-1. CWSL also agrees to add radionuclides to Table 5-1 but, because radionuclide concentrations have been shown to represent natural conditions; we suggest the frequency be annually rather than quarterly. wp51\u\letter\02229311.wch F: CWSL 3.2.93&4.1.6.93 M 931.061 L Letter Trevor Jiricek March 4, 1993 Page 5 WCDH Comment No 5: "Quarterly monitoring of depth to groundwater in all piezometers must be conducted during each quarterly sampling event and submitted in each quarterly report. " CWSL Response: In response to the WCDH comment, water levels in the piezometers will be monitored on a quarterly basis and the data will be submitted to the WCDH and CDH. Although we agree to provide this information at this time, these piezometers may be required to be abandoned due to operational necessity. Consideration for replacing abandoned piezometers will be given on a case by case basis. WCDH Comment No 6: "The proposed volatile organic analytes (table.5-1)are inappropriate. At a minimum, the thirty- four volatile organic compounds (VOC's) included in the July 1992 characterization must be included in the proposed parameter list. In addition to these thirty-four (34), the parameters also must include Dichlorodifluoromethane, Trichlorofluoromethane, and carbon disulfide. " CWSL Response: The parameter list specified on Table 5-1 of the "Ground Water Monitoring Plan" complies with current regulations governing sampling and analysis of ground water at solid waste landfills (see Section 2.2.3 of the Solid Waste Regulations) and also includes additional volatile organic compounds not specified in the Solid Waste Regulations but which were detected in shallow ground water. Accordingly, we believe the parameter list specified in Table 5-1 is appropriate. The basis for requesting the additional parameters listed above is unclear. CWSL has demonstrated that only a select few volatile organic compounds are present in ground water at the site. These compounds are included in the monitoring plan. WCDH Comment No 7: "The Division requires that the facility apply for a discharge permit with the Water Quality Control Commission, Colorado Department of Health in regard to the "underdrain" and the associated discharge into a water of the State. In addition, the Division requires that the facility apply for this permit within fourteen (14) days of receipt of this letter. " wp51\as\letter\02229311.wch F. CWSL 3.2.93&4.1.6.93 (?, ,06 1 Letter Trevor Jiricek March 4, 1993 Page 6 CWSL Response: The discharge permit application for the underdrain was submitted to the Colorado Department of Health, Water Quality Control Division on November 25, 1992. The CDH is now requesting additional information which CWSL is expeditiously preparing. Please contact Bill Hedberg at 330-2641 or Alan Scheere at 770-3324 if you have any questions about these responses. We appreciate the opportunity to meet with WCDH on January 20, 1993 and believe future meetings will facilitate our working relationship. Sincerely, ee JJ C �� au'ig1 cietik Bill Hedberg Alan Scheere Division V.P. Landfill Operations Environmental Specialist cc: Roger Doak, CDH John Pickle, WCDH Chuck Cunliffe, WCPD Lee Morrison, Assistant County Attorney Weld County Commissoners: Constance Harbert, Chairman Bill Webster Dale Hall George Baxter Barbara Kirkmeyer wp5l\as\letter\02229311.wch (} (vi F: CWSL3.2.93&4.1.6.93 51'14y106 1 (� Waste Services Corporation 6037 77th Avenue �� A Waste Management Cotncany Greeley. Colorado 80634 303/330.2641 06 March 9, 1993 Barbara Taylor, Environmental Engineer Colorado Department of Health Water Quality Control Section WQCD-PE-B2 4300 Cherry Creek Drive South Denver CO 80222-1530 RE: RESPONSES TO CDH REVIEW COMMENTS ON WASTE SERVICES CORPORATION, CENTRAL WELD SANITARY LANDFILL DISCHARGE PERMIT NO: CO-0043419 Dear Ms. Taylor: This letter is in response to Colorado Department of Health (CDH) comments of December 22, 1992 concerning the discharge permit application submitted to CDH on November 25, 1992 for Central Weld Sanitary Landfill (CWSL). The CDH comments are reiterated below, followed by CWSL detailed responses. CDH Comment #1: Clarification is required on the following : Please provide a full description of the following sample points: 1) NDIS 6) RP- INLET 2) LF-UD 7) EB 3) GWMWSA 8) TB 4) GWMWSSA-DUP 9) LF-UD 5) N-Discharge CWSL Response: 1. NDIS - This symbol designates the North Discharge Sampling point. Its location is shown on Attachment 2 of the permit application. The corresponding NDIS analytical data represent samples taken at the outfall of a 36" corrugated metal pipe (CMP) which wp51 W\kticr\030593.cdb F: CWSL 1.10 931061 h dx-1- nl 0d, ft L,t.k Sues Letter Barbara Taylor March 9, 1993 Page 2 is part of the northern ditch segment constructed about 1981. The purpose of the CMP and the ditch is to divert surface water run-on from properties north and upgradient of the landfill. The water in the ditch flows to the west of the CWSL through another CMP at the northwest corner of the landfill before entering the uppermost of four manmade ponds referred to as Spomer Lakes. The surface water run-on diverted through the ditch consists of stormwater and tailwater from irrigation activities upgradient of the landfill. 2. LF-UD - This symbol designates the landfill underdrain which is further described in the discharge permit application. The corresponding LF-UD analytical data represents samples taken at the outfall of the underdrain prior to discharge into the lower Spomer Lake. 3. GWMW5A - This designation was originally used to identify a new groundwater monitoring well located in the southeast corner of the landfill, which was installed as part of a hydrogeologic investigation recently conducted at the site. The new monitoring well was intended to replace monitoring well GWMW5 which is located offsite approximately 15 feet south of GWMW5A. During the course of preparing the hydrogeologic report, it was decided to change the designation of GWMW5A to GWMW5N to more appropriately indicate a new well. The groundwater monitoring well designations are shown on Figure 4-la of the permit application. 4. GWMW5A-DUP -This laboratory designation identifies the sample from GWMW5A as analyzed in duplicate. This procedure is part of the laboratory quality control program to ensure quality data is generated. 5. N-Discharge - This symbol is equivalent to the NDIS designation described in response #1. 6. RP-Inlet - This symbol identifies the retention pond inlet from which the french drain water outfalls. The corresponding analytical data represents samples taken from the outfall of the french drain into the retention pond. The french drain is further described in the discharge permit application submitted to CDH on January 7, 1993. Briefly, the • french drain and perimeter ditch system were constructed in 1991 for the remainder of the northern segment and the eastern alignment of the property boundary. The purpose of the french drain is to maintain groundwater levels at elevations below the base of refuse. 7. EB - This symbol is part of the water quality data contained in the hydrogeologic and geotechnical characterization report prepared by Golder Associates Inc., and submitted to CDH in July 1992. Enseco, the laboratory which performed water quality analyses wp51 W\laser\030593.cdh F: CWSL 1.10 931.06 '.. Letter Barbara Taylor March 9, 1993 Page 3 used this designation to indicate "equipment blank". This is part of a field quality control program to identify whether samples have become contaminated by field sampling procedures and/or equipment. 8. TB - This designation was also used by Enseco to identify the sample as a "trip blank". This procedure is part of a laboratory quality assurance program to determine the potential of a field sample to absorb volatile chemicals during transit. The trip blank is prepared by the laboratory and taken to the field during sampling. The trip blank accompanies the field sample back to the laboratory for analyses. Both the trip blank and field sample are analyzed and data compared as part of the quality assurance program. 9. LF-UD - See response # 2 CDH Comment #1B: "Describe the uses of the water that flows from the french drain to the retention pond. " CWSL Response: The water from the french drain outfalls to a temporary retention pond east of the landfill. The water level in the pond is currently managed by using the water primarily for onsite dust control. The water may also be used for irrigation. CWSL is currently evaluating the feasibility of routing water from the french drain to the Big Thompson River south of the site via a borrow ditch along the CWSL frontage road (77th Avenue). The discharge permit application for the french drain was submitted to the CDH on January 7, 1993. CDH Comment #1C: "What is the ultimate use or destiny of the water that flows from the underdrain to Spomer Lake?" CWSL Response: The water from Spomer Lake is used primarily for irrigation purposes by downstream farmers. Irrigation tailwater flows through a series of irrigation channels ultimately toward the Big Thompson River. w p5l W\Weer\030593.c i F: CWSL 1.10 931061 3 Letter Barbara Taylor March 9, 1993 Page 4 CDH Comment #1D: "A drain flows in a westerly direction on the northern perimeter of the property. Please describe the discharge point and the nature of the drain. " CWSL Response: The drain refered to in this sentence is the run-on control ditch north of the landfill. CDH Comment # 2: Additional testing required: Testing is required on all point-discharges which ultimately flow to surface waters of the State. Additional current data ( 3 months or less old) or testing is required for: 1) additional metals 5) uranium 2) fecal coliforms 6) Organic Chemicals 3) Nitrates and Nitrites 7) Pesticides 4) Total Suspended solids See Table 1 attached. CWSL Response: Enclosed for your review as Attachment 1, is the analytical report for the additional testing required by CDH to further process the permit application. The final report is comprised of the data qualifier report, analytical data and chain of custody records. However, due to a laboratory error, fecal coliforms and sulfide were not analyzed. Additional sampling is scheduled for March 1993 and analytical results will be immediately forwarded upon receipt of the sampling report. CWSL apologizes if this causes you any inconvenience in your review of the permit application. Also enclosed for your review, are additional analytical data for sampling of the underdrain conducted in December 1992 (See Attachment 2). As you will note in your review, two volatile compounds (trichloroethene and trichlorofluoromethane) detected at near the reporting limit (3 ug/L)during July were not detected at a reportable concentration during the December sampling. wp51 W lkaer\030593.ca P: CWSL 1.10 331061 4 Letter Barbara Taylor March 9, 1993 Page 5 Please contact Bill Hedberg at 654-1133 or Alan Scheere at 770-3324 if you have questions Sincerely, cur /' n Bill Hedberg Alan Scheere Division V.P. Landfill Operations Environmental Specialist AS/mmp Enclosure cc: Roger Doak, CDH w/enc John Pickle, WCDH w/enc Lee Morrison, Assistant County Attorney w/o enc Chuck Cunliffe, Weld County Department of Planning w/o enc Weld County Commissioners: Constance Harbert, Chairman w/o enc Bill Webster, w/o enc Dale Hall, w/o enc George Baxter, w/o enc Barbara Kirkmeyer, w/o enc wp5l WMetter\030593.c lh F: CWSL 1.10 931061 5 ATTACHMENT 1 LFUD ADDITIONAL ANALYTICAL DATA 331061 WMI Environmental Monitoring /c;; Laboratories, Inc. e A Waste Management Co^oa-, 2100 Gen Cleanwater Geneva, Illinois 60134 708/208-3100 Enclosed are the analytical results for samples received from your facility. The results in the Client Report are for a single ENS (Event Notification System) number only. The sampling event at your facility may include multiple ENS numbers . A separate Client Report will be generated for each one. It is the goal of WMI Environmental Monitoring Laboratories , Inc . to provide analytical data in a timely fashion, formatted in a way that our clients will find most useful. If you have any questions concerning the form or content of this report, please contact the WMI EML Customer Operations Department: Main Number (708 ) 208-3100 FAX Number (708) 208-1175 Note: Two designations may appear in the results column of your Client Report: NA or ND. The designation NA ( for "Not Analyzed" ) is used to identify analytes which were requested in the monitoring program, but for which no suitable testing methodology exists. NA may also indicate a dry well, broken sample bottle, insufficient sample volume, or other condition which precludes analysis for a sample. The designation ND (for "Not Detected" ) is used to indicate that the analyte of interest was not found at or above the concentration listed under the EMLRL (EML Reporting Limit) heading. Unless otherwise indicated, all analytes meet the requirements of holding time as specified in the method. Mai c. 1� Ph.D . Deborah C. Hockman, Ph.D. President WMI Environmental Monitoring Laboratories, Inc. 921.061 rk •. DATA OUALIFIER COMMENT CODE DEFINITIONS AR: Acid surrogate recoveries did not meet the acceptance criteria of the method. Oxidative degradation due to sample matrix is suggested. BB: Broken bottle. BL: The method blank concentration associated with this analyte did not meet the acceptance criteria of the method. CX: The concentration of this compound exceeded the calibration used for this analysis. The concentration reported is estimated. CU: Co-elution with another compound interferes with the quantitation of this compound. The concentration reported is estimated. DL: The sample was diluted during analysis. Reporting limits have been adjusted where necessary. DP: This sample was analyzed in duplicate. The relative percent difference between the two results did not meet the acceptance criteria of the method. DW: Dry well. • HS: Headspace in sample exceeded laboratory control limit. The reported results of the analysis may be less than the actual value. IS: The internal standard recoveries associated with this analysis did not meet the acceptance criteria of the method. IV: The bottle did not contain enough sample to perform the analysis. MP: 3-methylphenol and 4-methylphenol co-elute under the analytical conditions of the method, and can not be differentiated solely on the basis of their mass spectra. The concentrations reported may be either or both isomers. MX: This sample was used as a matrix spike. The percent recovery did not meet the acceptance criteria of the method. The analysis of a quality control standard showed the analytical system was in control. The result reported may therfore be affected by matrix interferences. NN: N-nitrosodiphenylamine can not be distinguished from diphenylamine using gas chromatography. The concentrations reported may be either or both compounds. N 33 061 NQ: No standard qualifier code is in use for this qualification. See the associated comment. NS: There was not enough sample to repeat this analysis. PL: This result may be a product of contamination from phthalate plasticizers, which are a common lab contaminant. PX: This sample required preservation in the field to a pH of less than 2. The pH was checked before analysis and did not have a pH of less than 2. PY: This sample required preservation in the field to a pH of 4 to 5. The pH was checked before analysis and did not have a pH of 4 to 5. PZ: This sample required preservation in the field to a pH of 12 or greater. The pH was checked before analysis and did not have a pH of 12 or greater. QX: This sample was used as a matrix spike. The percent recovery did not meet the acceptance criteria of the method. The analysis of a quality control standard showed the analytical system was out-of-control. The analytical result for this parameter in the unspiked sample is suspect and may not be reported for regulatory compliance purposes. SB: The analysis of this sample was performed by an approved subcontract laboratory. ST: This compound is not stable in acidic water. SU: The analysis of the surrogate with this sample did not meet the acceptance criteria of the method. TX: The analysis for this parameter was conducted after the holding time specified in the method. UN: This compound is not stable under the conditions of the analysis. 931.061 `i III Page: 1 %C NMI ENVIRONMENTAL MONITORING LABORATORIES, INC CLIENT REPORT Site: 488 — CENTRAL WELD CO. L/F Sample Point: LFUD ENS: 93-10469 Sampled: 27-JAN-1993 Sample Type: OUTFALL MP: 488932 Received: 28-JAN-1993 6037 77TH AVE. Sample Number: AG5052 REV: 00 Reported: 8-MAR-1993 GREELY CO 80634 Analyte Result EMI RL Units Comments Method FIELD DATA: 7.21 PH UNITS FDPHQUADO1 PH FIELD 7.22 PH UNITS FDPHQUADO1 PH FIELD 7.22 PH UNITS FDPHQUADO1 PH FIELD 7.24 PH UNITS FDPHQUADO1 PH FIELD 419 UMHOS/CM FDSPCONDO4 SPECIFIC CONDUCTANCE FIELD 423 UMHOS/CM FDSPCONDO4 SPECIFIC CONDUCTANCE FIELD 425. UMH0S/CM FDSPCONDO4 4 SPECIFIC CONDUCTANCE FIELD 28UMHOS/CM FDSPCONDO4 SPECIFIC CONDUCTANCE FIELD 13.2 DEGREES C FDXTEMPC01 WATER TEMPERATURE IN DEGREES CELSIUS CHEMICAL METHODS 6 ROBOTICS: ND 0.020 MG/L CRCNTTLXOI CYANIDE, TOTAL 1.26 0.050 MG/L CRNO3HYD01 NITROGEN, NITRATE ND 0.050 MG/L BL CRNO2HYDO1 NITROGEN,NITRITE SU ND 3.000 MG/L CRTSSXXX01 SOLIDS, TOTAL SUSPENDED INORGANICS: ND 200.000 UG/L INICPTOTAL ALUMINUM-TOTAL ND 25.000 UG/L INICPTOTCU COPPER-TOTAL 40.000 UG/L INICPTOTNI ZINC--TOTALAL ZINC ND 20.000 UG/L INICPTOTZN TOTAL SUB-CONTRACT DATA: ND 0.086 NG/L SB SB2378TCDD ALDIC R-TCDD ND 0.500 UG/L SB SBAGPST002 CABBOFUR ARBOFURAN ND 0.900 UG/L SB SBAGPST002 OXAMYL ND 0.100 UG/L SB SBAGPST002 PICLORAM ND 0.100 UG/L SB SBAGPST003 SIMAZINE ND 0.070 UG/L SB SBAGPST001 URANIUM-TOTAL 76.5 7.600 UG/L SB SBXURANIUM SEMI-VOLATILE ORGANICS: ND 10.000 UG/L SU ' SVMS1BPP10 1,2-DICHLOROBENZENE NZENE ND 10.000 UG/L SU SVMS1BPP10 1,2-DICHENYLHYDPAZ1 ND 10.000 UG/L SU SVMS1BPP10 1,3-DIPHLOROBENZENE E ND 10.000 UG/L SU SVMS1BPP10 1,4-DICHLOROBENZENE ND 10.000 UG/L SU SVMS1BPP10 2,4,6ITRICHLOROPHEE ND 10.000 UG/L SU SVMS1BPP1O 2,4-DICHLOROPHENOL ND 10.000 UG/L SU SVMS1BPP10 2,4-DICHLOROPHENOL 1.000 UG/L SVGC2HRB01 2,4-DINITROPHENOL YACETIC ACID ND 2,4-DINITROPHENOL ND 50.000 UG/L SU SVMSIBPPIO 2-(2,4,5-TRICHLOROPHENOXY)PROPIONIC ACID ND 1.000 UG/L SVGC2HRB01 4,4'-DDE ND 0.100 UG/L SVGC1PTP14 4,4'-DDT ND 0.100 UG/L SVGC1PTP14 ALDRIN ND 0.100 UG/L SVGC1PTP14 0.100 UG/L SVGC1PTP14 AROCLOR 1016 ND A 1.000 UGIL SVGC1PTP14 ND AROCLOR 1221 ND 1.000 UG/L SVGC1PTP14 AROCLOR 1232 ND 1.000 UG/L SVGC1PTP14 AROCLOR 1242 ND 0.100 UG/L SVGC1PTP14 AROCLOR 1248 ND 1.000 UGIL SVGC1PTP14 AROCLOR 1254 ND 1.000 UG/L SVGC1PTP14 AROCLOR 1260 ND 1.000 UG/L SVGC1PTP14 BENZIDINE ND 50.000 UG/L SU SVMSIBPPIO NA - Not Analyzed ND - Not Detected TBK - Trip Blank Item Additional Comment Explanations (NQ/DL) SB2378TCDD CAL ENSECO SBAGPST001 ENV HEALTH LABS SBAGPST002 ENV HEALTH LABS SBAGPST003 ENV HEALTH LABS SBXURANIUM CLEMSON SVGC2HRB01 DUE TO FAILED ANALYTE RECOVERY IN RO SPIKES A & B, SAMPLE DATA IS SUSPECT AND CONCENTRATIONS ESTIMATED. N 9'21..061. /0 iPage: 2 %e/ 1*4I ENVIRONMENTAL MONITORING LABORATORIES, INC CLIENT REPORT Site: 488 — CENTRAL WELD CO. L/F Sample Point: LFUD ENS: 93-10469 Sampled: 27-JAN-1993 Sample Type: OUTFALL MP: 488932 Received: 28-JAN-1993 6037 77TH AVE. Sample Number: AG5052 REV: 00 Reported: 8-MAR-1993 GREELY CO 80634 Analyte Result EML RL Units Comments Method BIS(2-CHLOROETHYL)ETHER ND 10.000 UG/L SU SVMS1BPP10 ND 1.000 UG/L SVGC1PTPI4 CHLORDANE I ND 10.000 OG/L SU SVMS1BPP10 DIDIELDRN,H)ANTHRACENE ND 0.100 UG/L SVGC1PTP14 ENDRIN ND 0.100 UG/L SVGC1PTP14 0.100 UG/L SVGC1PTP14 ENDRIN ALDEHYDE NDSVGC1PTP14 HEPTACHLOR ND 0.050 UG/L SVGC1PTP14 HEPTACHLOR EPDXIDE ND 0.500 UG/L HEXACHLOROBENZENE ND 10.000 UG/L SU SVMS1BPP10 HEXACHND 10.000 UG/L SU SVMS1BPP10 ISOPHOLOROBUTADIENE ND 10.000 UG/L SU SVMSIBPP10 LISOPHORONE ND 0.100 OG/L SVGCIPTP14 HETHOXE (GAMMA-BHC) ND 0.500 UG/L SVGC1PTP14 NITROBENZENE ND 10.000 UG/L SU SVMS1BPP10 NITROBENZENE ND 10.000 UG/L SU SVMSIBPPIO PENTACHLOROBENZENE PENTACPHENOL ND 50.000 UG/L SU SVMS1BPP10 TOXAPHENE HLOROPHENOL ND 1.000 UG/L SVGCIPTP14 VOLATILE ORGANICS: ND 5.000 UG/L V0MSAAX118 1, 1-DICHLOROETHANE 6. 5.000 UG/L VOMSAAX118 1, 2-DICHLOROETHANE ND5.000 UG/L V0MSAAX118 1,2-DICHLOROETHANE ND 10.000 UG/L VOMSAAX118 -DICHLOROETHENE ND 5.000 UG/L VOMSAAX118 1,N-EICHLOROPROPANROPANE ND 5.000 UG/L VOMSAAX118 BENZENE ND 10.000 UG/L VOMSAAX118 BROMOCHLO METHANE ND 5.000 UG/L VOMSAAX118 CA ND 5.000 UG/L V0MSAAX118 CARBON ON TETRACHLORIDE ND 5.000 OG/L VOMSAAX118 CHLOROFOR ND 5.000 UG/L V0MSAAX118 CHLOROFORM ND 10.000 UG/L VOMSAAX118 ETHYLBENZENEICHLOROETHENE ND 5.000 UG/L VOMSAAX118 TETRACHLOROETHENE 5. 5.000 UG/L V0MSAAX118 U ND 5.000 UG/L VOMSAAX118 TOLUENE ND 10.000 UG/L VOMSAAX118 TRICHLOROETHENE TRICHLOROETHENE ND 5.000 UG/L VOMSAAX118 IN ND 10.000 UG/L VOMSAAX11B, VINYL CHLORIDE NA - Not Analyzed ND - Not Detected TEE - Trip Blank GPI 931.061 Ir /1� Page: 3 %C Sd4II ENVIRONMENTAL MONITORING LABORATORIES, INC CLIENT REPORT Site: 488 - CENTRAL WELD CO. L/F Sample Point: TBK-LFUD ENS: 93-10469 Sampled: 27-JAN-1993 Sample Type: OUTFALL MP: 488932 Received: 28-JAN-1993 6037 77TH AVE. Sample Number: AG5052 REV: 00 Reported: 8-MAR-1993 GREELY CO 80634 Analyte Result EML RL Units Comments Method VOLATILE ORGANICS: ND 5.000 UG/L VOMSAAX118 1,1-DICHLOROETHETHANE ND 5.000 UG/L VOMSAAX118 1, 2-DICHLOROETHANE ND 5.000 UG/L VOMSAAX118 1,2-DICHLOROETHANE ND 10.000 UG/L VOMSAAX118 1,2-DICHLOROPROPANE(TOTAL) ND 5.000 UG/L VOMSAAX118 B, -EICHLOROROPAN ND 5.000 UG/L VOMSAAX118 BENZENE ND 10.000 UG/L VOMSAAX118 BROMO METHANE ND 5.000 UG/L VOMSAAX118 CARBOFORM OTM ND 5.000 UG/L VOMSAAX118 CARBON TETRACHLORIDE ND 5.000 UG/L VOMSAAX118 CHLOROFOR ND 5.000 UG/L VOMSAAX118 CHLOROFORM ND 10.000 UG/L VOMSAAX118 ETHYLBENZICHLOROETHENE ND 5.000 UG/L VOMSAAX118 TETRACHLOROETHENEENE ND 5.000 UG/L VOMSAAX118 U ND 5.000 UG/L VOMSAAX118 TOLUENE ND 10.000 OG/L VOMSAAX118 TRICHLOROETHENE TRICHLOROETHENE ND 5.000 OG/L VOMSAAX118 IN ND 10.000 UG/L VOMSAAX118 VINYL CHLORIDE NA = Not Analyzed ND - Not Detected TBE - Trip Blank 33106a i.) N Page: 1 %S NMI ENVIRONMENTAL MONITORING LABORATORIES, INC CLIENT REPORT Site: 488 — CENTRAL WELD CO. L/F Sample Point: LFUD ENS: 93-10469 Sampled: 27-JAN-1993 Sample Type: OUTFALL MP: 488932 Received: 28-JAN-1993. 6037 77TH AVE. Sample Number: AG5052 REV: 00 Reported: 8-MAR-1993 GREELY CO 80634 Analyte Result EML RL Units Consents Method FIELD DATA: 7.21 PH UNITS FDPHQUADO1 PH FIELD 7.22 PH UNITS FDPHQUADO1 PH FIELD 7.22 PH UNITS FDPHQUAD01 PH FIELD 7.24 PH UNITS FDPHQUAD01 PH FIELD UMHOS/CM FDSPCOND04 SPECIFIC CONDUCTANCE FIELD 423.419. UMHOS/CM FDSPCONDO4 SPECIFIC CONDUCTANCE FIELD 425. UMHOS/CM FDSPCONDO4 SPECIFIC CONDUCTANCE FIELD 428UMHOS/CM FDSPCONDO4 SPECIFIC CONDUCTANCE FIELD 13 2 DEGREES C FDXTEMPCO1 WATER TEMPERATURE IN DEGREES CELSIUS CHEMICAL METHODS 6 ROBOTICS: ND 0.020 MG/L CRCNTTLXOI CYANIDE, TOTAL 1.26 0.050 MG/L CRNO3HYD01 NITROGEN, NITRATE ND 0.050 MG/L BL CRN02HYD01 NITROGEN,NITRITE ND 3.000 MG/L CRTSSXXXO1 SOLIDS, TOTAL SUSPENDED INORGANICS: ND 200.000 UG/L INICPTOTAL ALUMINUM-TOTAL 25.000 UG/L INICPTOTCU COPPER-TOTAL ND NICKEL-TOTAL ND 40.000 UG/L INICPTOTNI ZINC-TOTAL ND 20.000 UG/L INICPTOTZN SUB-CONTRACT DATA: ND 0.086 NG/L SB SB2378TCDD ALDIC 8-TCDD ARB ND 0.500 UG/L SB SBAGPST002 CABBOFUR ND 0.900 UG/L SB SBAGPST002 OXAMYLAN ND 0.100 UG/L SB SBAGPST002 PICLORAM ND 0.100 UG/L SB SBAGPST003 SIMAZINE AZINE ND 0.070 UG/L SB SBAGPST001 URANIUM-TOTAL 76.5 7.600 UG/L SB SBXURANIUM SEMI-VOLATILE ORGANICS: ND 10.000 UG/L SU SVMSIBPPI0 1,2, 4,5-TETRACHLOROBENZENE ND 10.000 UG/L SU SVMS1BPP10 1,2-DICHENYLHYDRAZILOROBENZENE ND 10.000 UG/L SU SVMS1BPP10 1,3-DICHLOROBENZENE E ND 10.000 UG/L SU SVMS1BPP10 1,4-DICHLOROBENZENE ND 10.000 UG/L SU SVMS1BPP10 2,4,6-TRICHLOROPHENICHLOROBENZENE ND 10.000 UG/L SU SVMS1BPP10 2,4-DICHLOROPHENOL ND 10.000 UG/L SU SVMS1BPP10 2,4-DICHLOROPHENOL 1.000 UG/L SVGC2HRB01 2,4-DINITROPHENOL YACETIC ACID ND 2,4-DINITROPHENOL ND 50.000 UG/L SU SVMSIBPPI0 2-(2, 4,5-TRICHLOROPHENOXY)PROPIONIC ACID ND 1.000 UG/L SVGC2HRB01 4,4'-DDT ND 0.100 UG/L SVGCIPTP14 0.100 UG/L SVGC1PTP14 ALDRIN ND 0.100 UG/L SVGC1PTP14 ALPHA- ND 0.100 UG/L SVGC1PTP14 AROCLOR 1016 ND SVGC1PTP14 AROCLOR ND 1.000 UG/L SVGC1PTP14 1.000 UG/L AROCLOR 1221 ND 1.000 UG/L SVGC1PTP14 AROCLOR 1232 ND SVGC1PTP14 AROCLOR 1242 ND 0.100 UG/L AROCLOR 1248 ND 1.000 UG/L SVGCIPTPI4 AROCLOR 1254 ND 1.000 UG/L SVGC1PTP14 AROCLOND 1.000 UG/L SVGC1PTP14 BENZIDINE R 1260. ND 50.000 UG/L SU SVMS1BPP10 NA - Not Analyzed ND - Not Detected TBK - Trip Blank Item Additional Consent Explanations (NQ/DL) SB2378TCDD CAL ENSECO SBAGPST001 ENV HEALTH LABS SBAGPST002 ENV HEALTH LABS SBAGPST003 ENV HEALTH LABS SBXURANIUM CLEMSON SVGC2HRB01 DUE TO FAILED ANALYTE RECOVERY IN RO SPIKES A & B, SAMPLE DATA IS SUSPECT AND CONCENTRATIONS ESTIMATED. nr /4 ;:;:,' Page: 2 ‘4525' NMI ENVIRONMENTAL MONITORING LABORATORIES, INC CLIENT REPORT Site: 488 - CENTRAL WELD CO. L/F Sample Point: LFUD ENS: 93-10469 Sampled: 27-JAN-1993 Sample Type: OUTFALL MP: 488932 Received: 28-JAN-1993 6037 77TH AVE. Sample Number: AG5052 REV: 00 Reported: 8-MAR-1993 GREELY CO 80634 Analyte Result EML RL Units Comments Method BIS(2-CHLOROETHYL)ETHER ND 10.000 UG/L SU SVMS1BPP10 CHLORDANE ND 1.000 UG/L SVGC1PTP14 DIBENZ[A,H]ANTHRACENE ND 10.000 UG/L SU SVMSIBPP10 DIELDRIN ND 0.100 UG/L SVGC1PTP14 ENDRIN ND 0.100 UG/L SVGC1PTP14 ENDRIN ALDEHYDE ND 0.100 UG/L SVGC1PTP14 HEPTACHLOR ND 0.050 UG/L SVGC1PTP14 HEPTACHLOR EPDXIDE ND 0.500 UG/L SVGC1PTP14 HEXACHLOROBENZENE ND 10.000 UG/L SU SVMS1BPP10 HEXACHLOROBUTADIENE ND 10.000 UG/L SU SVMS1BPP10 ISOPHORONE ND 10.000 UG/L SU SVMS1BPP10 LINDANE (GAMMA-BHC) ND 0.100 UG/L SVGCIPTP14 METHOXYCHLOR ND 0.500 UG/L SVGC1PTP14 NITROBENZENE ND 10.000 UG/L SU SVMSIBPP10 PENTACHLOROBENZENE ND 10.000 UG/L SU SVMS1BPP10 PENTACHLOROPHENOL ND 50.000 UG/L SU SVMSIBPP10 TOXAPHENE ND 1.000 UG/L SVGC1PTP14 VOLATILE ORGANICS: 1,1,2-TRICHL0R0ETHANE ND 5.000 UG/L VOMSAAX118 1,1-DICHLOROETHANE 6. 5.000 UG/L VOMSAAX118 1,2-DICHLOROETHANE ND 5.000 UG/L VOMSAAX118 1,2-DICHLOROETHENE(TOTAL) ND 10.000 UG/L VOMSAAX118 1,2-DICHLOROPROPANE ND 5.000 UG/L VOMSAAX118 BENZENE ND 5.000 UG/L VOMSAAX118 BROMOCHLOROMETHANE ND 10.000 UG/L VOMSAAX118 BROMOFORM ND 5.000 UG/L VOMSAAX118 CARBON TETRACHLORIDE ND 5.000 UG/L VOMSAAX118 CHLOROBENZENE ND 5.000 UG/L VOMSAAX118 CHLOROFORM ND 5.000 UG/L VOMSAAX118 CIS-1,2-DICHLOROETHENE ND 10.000 UG/L VOMSAAX118 ETHYLBENZENE ND 5.000 UG/L VOMSAAX118 TETRACHLOROETHENE 5. 5.000 UG/L VOMSAAX118 TOLUENE ND 5.000 UG/L VOMSAAX118 TRANS-1,2-DICHLOROETHENE ND 10.000 UG/L VOMSAAX118 TRICHLOROETHENE ND 5.000 UG/L VOMSAAX118 VINYL CHLORIDE ND 10.000 UG/L VOMSAAX118 NA - Not Analyzed ND - Not Detected TBE - Trip Blank N sl.Osx iv 14 ;:;:,1 Page: 3 %C Sd4Z ENVIRONMENTAL MONITORING LABORATORIES, INC CLIENT REPORT Site: 488 - CENTRAL WELD CO. L/F Sample Point: TBK-LFUD ENS: 93-10469 Sampled: 27-JAN-1993 Sample Type: OUTFALL MP: 488932 Received: 28-JAN-1993 6037 77TH AVE. Sample Number: AG5052 REV: 00 Reported: 8-MAR-1993 GREELY CO 80634 Analyte Result ENL RL Units Comments Method VOLATILE ORGANICS: ND 5.000 UG/L VOMSAAX118 1,1,2-TRICHLOROETHANE 5.000 UG/L VOMSAAX118 1,1-DICHLOROETHANE ND 1,2-DICHLOROETHANE ND 5.000 DG/L VOMSAAX118 1,2-DICHLOROETHENE(TOTAL) ND 10.000 UG/L VOMSAAX118 1,2-DICHLOROPROPANE ND 5.000 UG/L VOMSAAX118 BENZENE ND 5.000 UG/L VOMSAAX118 BROMOCHLOROMETHANE ND 10.000 UG/L VOMSAAX118 BROMOFORM ND 5.000 UG/L VOMSAAX118 CARBON TETRACHLORIDE ND 5.000 UG/L VOMSAAX118 CHLOROBENZENE ND 5.000 UG/L VOMSAAX118 CHLOROFORM ND 5.000 UG/L VOMSAAX118 CIS-1,2-DICHLOROETHENE ND 10.000 UG/L V0MSAAX118 ETHYLBENZENE ND 5.000 UG/L VOMSAAX118 TETRACHLOROETHENE ND 5.000 UG/L V0MSAAX118 TOLUENE ND 5.000 UG/L VOMSAAX118 TRANS-1,2-DICHLOROETHENE ND 10.000 UG/L VOMSAAX118 TRICHLOROETHENE ND 5.000 UG/L VOMSAAX118 VINYL CHLORIDE ND 10.000 DG/L VOMSAAX118 NA - Not Analyzed ND = Not Detected IRK - Trip Blank • N 331064 i5 �■ Subcontract To: " AgdePer PREP WMYI I Environmental Monitoring Laboratories, Inc. Date Staledl � l S 1 clO -1 YY .1MM DD FIELD CHAIN-OF-CUSTODY RECORD SUM yy4-, By: SITE/FACILITY #1 -We I I SITE NAME: CENTRAL WELD CO . L% F Sample Point: I jIFIUItI I I' • SAMPLE DATE: - 1!9 l:3 le I ) 1 L 11 1 MM DD SAMPLE TIME: I I 1 I I : 12 b 1 MATRIX CODE: 1 -J Water (W) LeacOthehate (C) 12400 NRI Source Codes . . . . . We,l • (W) Leacnate System . . ICI Pretreatment Facility. . • ,P1 RLaxeOlreaStream Brook' 'RI Bottom Sediment. . . . .. . . . e. Gererancn P. x O Durtace n na,er I m p ru omet Ol Gas Conaensate. . .tM) tntl„ent 7 Outten 0I Noise Ni Spec'Y Swtace water lmpounament . . . '.n Air dal Effluent IT) ENS # R:- 1045- AquaPek" CONTENT SAMPLE M OF BOTTLE PRESERVATIVE ANALVTES/LAB GROUPS FILTER FIELD E.M.L. I.D. BOTTLES TYPE TYPE Y-N COMMENTS I COMMENTS A3gO=-, • 'COOL 4 • - p � Y N An 104 G NONE/COOL 4 e Y Y N 04 G HCL/COOL 4 DEG C V Y A6 ' 505.2-C •y 5052-D 01 C NONE/COOL_ DE6.C_,,.__SB Y AG5052-E 02 G NONE/COOL 4 DEG C SB Yom, A35052-F 01_ ..__._G-..-2-I-NC.-ACELt E/.NAOH/4CSB Y AG5052-G 01 P NONE./COOL DEG C SB Y W A35052-H._..___. .at_ _ P_.. NAOH/COO L 4 DEG C CR Y AG505.2=-_I 01 G NONE/COOL 4 DEG CR Y �,` TDS AG5052-7__. .. -Q1 p .NONE DUL - 4 DEG 'C _ CR ACa5052-K _ ------- 91_ __ _..P. HNOa_. _____ IN Y AG5052-L 04 G NONE/COOL 4 DEG C SV Ya AG5052-M 01 G HCL/COOL 4 DEG C 9= Y - _ _ei -iAG502_N • 1 G HCL/C•I • _ _ r Au5Q52-P 02 A/ Y 01 G L_ COL 4 DEG_C • AG502^GL. — ___- v CHAIN OF CUSTODY CHRONICLE .Clc.t ,,'E...IJ AS6-4 Date: `321 C / / :1 Time: J, ' cry 1. AquaPak Opened By: (print 2400 HR. Signature: Seal #: 4/5045 Intact: Yai I have received thes aterials in d condition from the above person. 2. Name: Signature: / Time: Remarks: Date: 2400 HR. I have received these materials in good condition from the above person. 3. Name: Signature: Date: / Time: • Remarks: 2400 HR. / AquaPak'"/Sub Contr. # Sealed By: A.JENN -1 Date: 9 3 / d i 12" Time: / [ ' -%(/' / (Print) 2400 HR. 4' Seal #: 0 e`fo /95 Intact )E S Signature: n /� LL LAB USE ONLY / Q ,1��/ ( / .)6 / Time: I2 • 3 w Opened By: 15'9°""'e1 WC! 't T4 ry( Date: /D % { 2400 HR. N AquaPak^ Sub. Contf.'# Temp°C Seal # L U G J Intact. 931061 � , ' Site # kI! I?I WM I Environmental f lonitoring Laboratories, Inc. Bottle Set: IA IL;-I5 IG I-' I Z I FIELD INFORMATION FORM - Sample Point: IcIILIrIt4tI I I Source CUE. PURGINGII INFORMATION 7 310 I �1 It I 1x 1Iy�'IP ELAPSED HAS WATER VOL. UAL VOLUME PURGED i 1-LE PURGE DATE STTApT pugGE (Gellamj I IVY MM DD) (zoo Hr Clock) PUR G AND SAMPLING EQUIPMENT ' N Purging Equipment Dedicated I ; N I Sampling Equipment Dedicated mrd.on., wits one) Purging Device I / A-Submersible Pump D-Gas Lift Pump G-Bailer K. P RG,NG OTHER sPEaFn Sampling Device B-Peristaltic Pump E-Venturi Pump H-Scoop/Shovel X' SAMPLING OTHER(SPECIFY) C-Bladder Pump F-Dipper/Bottle I-Piston Pump Purging Material l y ATeflon C-Polypropylene E-Polyethylene X P RGINGrnNER(sPECIFYj X Sampling Material I B-Stainless Steel D-PVC SAMPLING OTHER{SPECIFY) Tubing-Purging I f ATeflon D-Polypropylene F-Silicon X- PURGING OTHER(SPECIFY) Tubing-Sampling /-1 BTygon E-Polyethylene G-Combination teflon/X- �MPLINGOTHER(SPECIFY) C-Rope X- Polypropylene (SPECIFY) Filtering Devices 0.45 y:I.,eJ A-In-line Disposable B-Pressure C-Vacuum Fl LD MEASUREMENTS Well Elevation (ft/msl) Land Surface Elevation (ft/msl) Depth to water Depth to water From top of well casing (ft) From land surface (ft) Wmsl Groundwater Elevation (ft/msl) Groundwater Elevation � � � y�� ( ) Well Depth L-,�L I (ft) Stickup (ft) I d pm/cm 1st I 142141 (STD) 1st I I I / I ZIRl at 25° C Sample Temp. 1 I i I3;Z'I(° C) Pe spec..ccond. /I I 2nd 1 17ltill (STD) 2nd I I (4'1'141 ate 5r"C I I I I I ( IJ spec.cond. Ices Psrunele) vel Pe pm/cm u 3rd I '712111 (STD) 3rd I I 1411-13I at 25° C Wine Mw ph spec.cond. 24th 1 I I�I /Ill am 5'r'C -I- 1 IIIIII LJ 4th I Ill I I (STD) Ices peeneen .Mw WIe spat cone. M FIELD COMMENTS Sample Appearance: ['0. ) Odor. _///"''' Color: --443.414. Turbidity: A✓' ld- (u appkaeM Weather Conditions: Viand Speed iA/o.AJE motion Precipitation v J outlook E fe Specific Comments: S4 row pi_E s TA tt Ear e 171SGNV.2G I e F I-0,00 F/LL U,AOEAc O/ZAIN �orrLe5 �G.ocI-O oh/licit?t4Cit//y l�f/U 44-4,00). / /J �` ,4,• h4 LTA? LAVAS i s dmALL Yon- ALL /ao >lie S-- n.., 7-Jinn, AO^^ S S r rte s Are la c..J4v T Sir/4 Fw. te.$A' r itkiAti r I certify that sampling procedure were in accordance with applicable EPA, State and WMI protocols. / Employer: SEC-496Nod&G maul ISIEneucj J e 1 N FML FF 2A dal Lcn,Au ATTACHMENT 2 LFUD FOURTH QUARTER ANALYTICAL DATA N 931061 /1' WMI Environmental Monitoring I4;;;:1 Laboratories, Inc.e A Waste Manage en: Correa-, 2100 Gen Cleanwoi 0134 Geneva, Illinois r 60134 708/208-3100 Enclosed are the analytical results for samples received from your facility. The results in the Client Report are for a single ENS (Event Notification System) number only. The sampling event at your facility may include multiple ENS numbers . A separate Client Report will be generated for each one . It is the goal of WMI Environmental Monitoring Laboratories, Inc . to provide analytical data in a timely fashion, formatted in a way that our clients will find most useful. If you have any questions concerning the form or content of this report, please contact the WMI EML Customer Operations Department : Main Number ( 708 ) 208-3100 FAX Number ( 708 ) 208-1175 Note: Two designations may appear in the results column of your Client Report: NA or ND. The .designation NA ( for "Not Analyzed" ) is used to identify analytes which were requested in the monitoring program, but for which no suitable testing methodology exists . NA may also indicate a dry well, broken sample bottle, insufficient sample volume, or other condition which precludes analysis for a sample . The designation ND ( for "Not Detected" ) is used to indicate that the analyte of interest was not found at or above the concentration listed under the EMLRL (EML Reporting Limit) heading. Unless otherwise indicated, all analytes meet the requirements of holding time as specified in the method. ueade deigeta e .O , Deborah C. Hockman, Ph.D. President WMI Environmental Monitoring Laboratories, Inc. 931061 / ) V11 Data Qualifier Comment Code Definitions AR: Acid surrogate recoveries did not meet the acceptance criteria of the method. Oxidation degradation due to sample matrix was confirmed. BB: Broken bottle. BL: The method blank concentration associated with this analyte did not meet the acceptance criteria of the method. CX: The concentration of this compound exceeded the calibration used for this analysis. The concentration reported is estimated. CU: Co-elution with another compound interferes with the quantitation of this compound. The concentration reported is estimated. DL: The sample was diluted during analysis. Reporting limits have been adjusted where necessary. DP: This sample was analyzed in duplicate. The relative percent difference between the two results did not meet the acceptance criteria of the method. DW: Dry well HS: The headspace in this sample bottle exceeded 6 millimeters. IS: The internal standard recoveries associated with this analysis did not meet the acceptance criteria of the method. IV: The bottle did not contain enough sample to perform the analysis. MP: 3-methylhphenol and 4-methylphenol co-elute under the analytical conditions of the method, and can not be differentiated solely on the basis of their mass spectra. The concentrations reported may be either or both isomers. MX: This sample was used as a matrix spike. The percent recovery did not meet the acceptance criteria of the method. The analysis of a quality control standard showed the analytical system was in control. The result reported may therefore be affected by matrix interferences. NN: N-nitrosodiphenylamine can not be distinguished from diphenylamine using gas chromatography. The concentrations reported may be either or both compounds. NQ: No standard qualifier code is in use for this qualification. See the associated comment. NS: There was not enough sample to repeat this analysis. 3'. 1.061 E. C, PL: This result may be a product of contamination from phthalate plasticizers, which are a common lab contaminant. PX: This sample required preservation in the field to a pH of less than 2. The pH was checked after receipt at the lab, and did not have a pH of less than 2. PY: This sample required preservation in the field to a pH of 4 to 5. The pH was checked after receipt at the lab, and did not have a pH of 4 to 5. PZ: This sample required preservation in the field to a pH of 12 or greater. The pH was checked after receipt at the lab, and did not have a pH of 12 or greater. QX: This sample was used as a matrix spike. The percent recovery did not meet the acceptance criteria of the method. The analysis of a quality control standard showed the analytical system was out-of-control. The analytical result for this parameter in the unspiked sample is suspect and may not be reported for regulatory compliance purposes. RA: Acid surrogate recoveries associated with this analysis did not meet the acceptance criteria pf the method. RB: Base/neutral surrogate recoveries associated with this analysis did not meet the acceptance criteria of the method. SB: The analysis of this sample was performed by an approved subcontract laboratory. ST: This compound is not stable in acidic water. SU: The analysis of the surrogate with this sample did not meet the acceptance criteria of the method. TX: The analysis for this parameter was conducted after the holding time specified in the method. UN: This compound is not stable under the conditions of the analysis. J 931061 2/ Page: 1 44:;:;: k ENVIRONMENTAL MONITORING LABORATORIES, INC 14:12 CLIENT REPORT Site: 488 — CENTRAL WELD CO. L/F Sample Point: LFUD ENS: 92-13531 Sampled: 17-DEC-.9'92 Sample Type: OUTFALL MP: 488921 Received: 19-DEC-1992 6037 77TH AVE. Sample Number: AG2132 REV: 02 Reported: 11-JAN-1993 GREELY CO 80634 Analyte Result EML RL Units Comments Method FIELD DATA: DTWTC01 DEPTH TO WATER FROM TOP OF CASING NA FT MSL NA FT FDWFDWDTWTCOT GROUNDWATER ELEV. 6.90 PH UNITS FDPHQUADO1 PH FIELD 6.91 PH UNITS FDPHQUADO1 PH FIELD 6.92 PH UNITS FDPHQUADO1 PH FIELD 6.94 PH UNITS FDPHQUADO1 PH FIELD 428. UMHOS/CM FDSPCONDO4 SPECIFIC CONDUCTANCE FIELD 426. UMHOS/CM FDSPCONDO4 SPECIFIC CONDUCTANCE FIELD 430. UMHOS/CM FDSPCONDO4 SPECIFIC CONDUCTANCE FIELD UMHOS/CM FDSPCONDO4 SPECIFIC CONDUCTANCE FIELD DEGREES C FDXTEMPC01 WATER TEMPERATURE IN DEGREES 432.13.2 CELSIUS WELL DEPTH TOTAL CHEMICAL METHODS S ROBOTICS: 533 20.000 MG/L DL CRALKMOTO1 ALKALINITY 19 10.000 MG/L CRCODXXXO1 CHEMICAL OXYGEN DEMAND 45.3 0.500 MG/L CRCHLORIO1 CHLORIDE ND 0.020 MG/L CRN2NH3X01 NITROGEN, AMMONIA 1.19 0.050 MG/L CRNO3HYD01 NITROGEN, NITRATE 0.050 0.050 MG/L CRNO2HYD01 NITROGEN,NITRITE 2200 250.000 MG/L DL CRSULFATO1 SULFATE 5.6 1.000 MG/L CRTOCDUPO1 TOTAL ORGANIC CARBON 5.5 1.000 MG/L CRTOCDUPO1 TOTAL ORGANIC CARBON INORGANICS: ND 200.000 UG/L INICPTOTCA BARIUM-TOTAL ND 5.000 UG/L INICPTOTCD CADMIUM-TOTAL 490000 5000.000 UG/L INICPTOTCA CALCIUM-TOTALINICPTOTCR CHROMIUM-TOTAL ND 10.000 UG/L INICPTOTFE IRON-T-TOTAL 243 100.000 UG/L LEAD-TOTAL ND 25.000 UG/L DL INGFAATOPB MAGNESIUM-TOTAL 290000 5000.000 UG/L INICPTOTMG 1750 15.000 UG/L INICPTOTNN MANGANESE-TOTAL ND 0.200 UG/L INCVAATOHG MERCURY-TOTAL ND 40.000 UG/L INICPTOTNI NICKEL-TOTAL ND 5000.000 UG/L INFAATOTXK POTASSIUM-TOTAL SODIUM-TOTAL 230000 5000.000 UG/L INICPTOTNA ND 20.000 UG/L INICPTOTNN ZINC-TOTAL SUB-CONTRACT DATA: 93.4 15.000 PCI/L +/- SB SBALPHBETA GRGROSS ALPHA ND 30.000 PCI/L +/- SB SBALPHBETA RADIUM DIU 822 ND 5.000 PCI/L +/- SB SBRA226228 2266 PCI/L +/- SB SBRA226228 RADIUM 226-STANDARD DEVIATION N/A RADIUM 228 ND 5.000 PCI/L +/- SB SBRA226228 RADIUM 228-STANDARD DEVIATION N/A PCI/L +/- SB SBRA226228 STANDARD DEVIATION-GROSS ALPHA 21.6 PCI/L +/- SB SBALPHBETA STANDARD DEVIATION-GROSS BETA N/A PCI/L +/- SB SBALPHBETA VOLATILE ORGANICS: ND 5.000 UG/L VOMSBAX322 1, 1,1-TRICHLOROETHANE ND 5.000 UG/L VOMSBAX322 1,1,2,2-TETRACHLOROETHANE ND 5.000 UG/L VOMSBAX322 1, 1-DICH OROETHANE 6. 5.000 UG/L VOMSBAX322 1,1-DICHLOROETHANE ND 5.000 UG/L VOMSBAX322 1, 1-DICHLOROETHENE ND 5.000 UG/L VOMSBAX322 1,2-DICHLOROETHANE NA = Not Analyzed ND - Not Detected TBK - Trip Blank Item Additional Consent Explanations (NQ/DL) ALKALINITY Dilution factor 2 applied. SULFATE Dilution factor 50 applied. LEAD-TOTAL Dilution factor 5 applied. SBALPHBETA CLEMSON SBRA226228 CLEMSON 931.064 o Page: 2 4' ;:;: i1 NMI ENVIRONMENTAL MONITORING LABORATORIES, INC ‘e CLIENT REPORT Site: 488 - CENTRAL WELD CO. L/F Sample Point: LFUD - ENS: 92-13531 Sampled: 17-DEC-'.32 Sample Type: OUTFALL MP: 488921 Received: 19-DEC-_))2 6037 77TH AVE. Sample Number: AG2132 REV: 02 Reported: 11-JAN-1993 GREELY CO 80634 Analyte Result EML RL Units Comments Method ND 10.000 UG/L VOMSBAX322 1,2-DICHLORO?ROPAN(TOTAL) ND 5.000 UG/L VOMSBAX322 2-BUTANONE 2HLOROPROPANE ND 10.000 UG/L VOMSBAX322 HEX ND 10.000 UG/L V0MSBAX322 2-METHYL-2 ND 10.000 UG/L VOMSBAX322 4CETONYL-2-PENTANONE ND 34.000 UG/L VOMSBAX322 ACETONE ND 5.000 UG/L VOMSBAX322 BENZENE ND 5.000 UG/L VOMSBAX322 BROMOFORM ROMETHANE ND 5.000 UG/L VOMSBAX322 BROMOMETHANE UL ND 10.000 UG/L VOMSBAX322 ND 5.000 UG/L VOMSBAX322 CARBON DISULFIDE ND 5.000 UG/L VOMSBAX322 CARBON TETRACHLORIDE ND 5.000 UG/L VOMSBAX322 CHLOROBENZENE 10.000 UG/L VOMSBAX322 CHLOROETHANE E ORMNE ND 5.000 UG/L VOMSBAX322 CHLOROFORM ND 10.000 UG/L VCMSBAX322 CCHLOROMEDICHL ND 5.000 UG/L VOMSBAX322 DIBROMOCHLOROMETHANE II E ND 5.000 UG/L VOMSBAX322 DICHLOROUOROETHAN 19. 10.000 UG/L VOMSBAX322 ETHYLBENZENE LOROMETHANE ND 5.000 UGIL VOMSBAX322 ND 5.000 UG/L VOMSBAX322 METHYLENE CHLORIDE ND 5.000 UG/L VOMSBAX322 STYRENE 5. 5.000 UG/L VOMSBAX322 TETRACHLOROETHENE ND 5.000 UG/L VOMSBAX322 TOLUENE ND 5.000 UG/L VOMSBAX322 TRICHLOROETICHLORDPROPENE ND 5.000 UG/L VOMSBAX322 TRICHLORO ND 10.000 UG/L VOMSBAX322 TRICHLOROFLUOROMETHANE IN ND 10.000 UG/L VOMSBAX322 VINYL ACETATE VOMSBAX322 VINYL CHLORIDE ND 10.000 UG/L V0MSBAX322 XYLENE(TOTAL) ND 10.000 UG/L NA = Not Analyzed ND = Not Detected TSR = Trip Blank Subcontract To: AquaRae PREP f �J - W M I Environmental Monitoring Laboratories, Inc. AquaPek" # Dab Sealed tg 1/ k7[10-31 I FIELD CHAIN-OF-CUSTODY RECORD OD Sail y // By: c_— SITE/FACILITY #1 Ar 48W*fl SITE NAME: CENTRAL WELD� '-`J. !_'/Sample Point: Lir1"t� II �eJ e 00-C SAMPLE DATE: - 1 I - l ` 1 ,-1 I-"-1 /" yy I M%1 I DD 6V SAMPLE TIME: I if I : l(-' l`' 1 MATRIX CODE: water (WI Leechete . ... ... . (C) (use„ill Soil (S) Other (X) Source Codes: Well (WI Leecnate System . .(C) Pretreatment Facility. . . (P1 Rrver/Stream/erook . (RI Soil (S) Generation Pt .;G Dewaterrng/Pressure Reirel... . i0) Gas Condensate. . .(M) Influent (U) Lake or Ocean IL) Boot em Sediment. . (B)ise ) °Vierfy J' Surface Water impoundment. . . (I) Air (A) Effluent (T) Outtall (0) ENS # -- �- . AquaPek" CONTENT SAMPLE M OF BOTTLE PRESERVATIVE FILTER FIELD E.M.L. I.o. Bonus TYPE TYPE ANALYTESILAB 3ROUPJ y_N COMMENTS COMMENTS AG2132-A 01 P HNO3 SR Y I i I Q . <_ . •, AG2132-8 02 P HNO3 SB Y 9' V AG2132-C r 01 G H2SC4/COOL` 4 DES .C CR. ,V N , s H2SO4/COOL 4 DE c .C CR Y N AG2132-D 01 6 / '.� •. AG2132-E 02 G H2604/COOL. 4 Of el CR •Y r� . r' A02132-F 01 G NONE/COOL /4 DEG C ' CR Y 1►}� ^t0.0: AG2132-G • 01 P NONE/COOL 4 DEG C CR Y n f A62132-H 01. P HNO3 , . __. .c IN Y• C � 'r' > i•:,4 AG 132-I 01 HNO3 N Y ...14.02132-3 04 G HCL/COOL 4 . Va. :.;i Y N AG2132-K 01, ØHCL/COOL 4 06 C4.` _.; .s..4. Y reor 407/245 • Y N I" Y N V-41 t YiSerti" dafv UM • I, ti. Y N it_ ` CHAIN OF CUSTODY CHRONICLE uaPak" Opened By: rint) l / "(- `-" ' r 1'16 r- Date: '91/ /1---/ /6 Time: O F ' 1. i.•f'' �',�';,i_ 'Of l/ Intact: 5/C) Signature: - Seal #: I have received these materi • in 1d Ion from the aboveplan. 2. Name: ' ' Signature: Date: / 4' - • Flonarks: 2400 H!! I have received these materials iti.8;ood condition keen thealbty ,per•• 3. Name: Silspatur* Date: / / TIM*: a,. • IRemarMlac' '' 2400 HR. AquaPak'"/Sub Contr. # 1 Sealed �,IW4�• J6_0r''j Date: (7L/ i 1/1 Time: 4 .—i---------152 ! (Preq n ! �40Q HR. Signature: i `-r/`./ !T/ 2 Seal #: " / Intact: fr�' LAB USE ONLY k/16 ..,:t: / j '� / Mme: I ( /''.4 q Opened By: 'g`°""""' �� Date:_ w /" •2r400 HR. AquaPak"/Sub. Contr. # /0573 Temp.°C 7 3 Seal # yZ G�V Intact.____931.061--... V .• • ' _ Site # • I Iylr - WM I Environmental Monitoring Laboratories, Inc. Bottle Set: I41 I / 1 Sample Point: I L I r Ii �I� I I FIELD INFOR ATION FORM Source G« PURGING INFORMATION `_ �' '= II - { t IIc7Il/�I�—r9 -' • l �_I I--_ '�PURGE DATE ART PURGE -ELAPSED MRS WATER IVOL IN CASING ACTUAL VOLUME(PURGED 2400 Hr Clock) mMVDDI ( PURGING AND SAMPLING EQUIPMENT DedicatedIVI INSampling Equipment Purging EquipmenF-, (circle ono) E ui ment Dedicated Y-I InsN Purging Device L{I� A-Submersible Pump D-Gas Lift Pump G-Bailer — PURGING PURGING OTHER(SPECIPn / Sampling Device I j I B-Peristaltic Pump E-Venturi Pump H-Scoop/Shovel X- SAMPLING OTHER(SPECIFY) C-Bladder Pump F-Dipper/Bottle I-Piston Pump Purging Material I__I A-Teflon C-Polypropylene E-Polyethylene X- �RGING OTHER(SPECIFY) Sampling Material Ir•xl B-Stainless Steel D-PVC X- SAMPLING OTHER(SPECIFY) Tubing-Purging LJ A-Teflon D-Polypropylene F-Silicon X• PURGING OTHER(SPECIFY) Tubing-Sampling I__.1 B-Tygon E-Polyethylene G-Combination teflon/X- SAMPLING OTHER(SPECIFY) X- Polypropylene II (SPECIFY) Filtering Devices 0.45 p:I____ A-In-line Disposable B-Pressure C-Vacuum FIELD MEASUREMENTS � 1� Well Elevation I I I I _1--I (ftlmsl) Land Surface.Elevation I I I I �I (ftmsl) Depth to water Depth to water �� I I lot) From top of well casing j �' II 1 I I (ft) From land surface / • Groundwater fFl•vatiOn IIIIIII (ftimsl) Groundwater Elev l) I I I I l I I (ft/ms Well Depth I I I I I I I (tt) _,StiekiP/ I I I I I I I (ft) pm/cm 1st I 41 PI (STD) 1st I I I913 IA at 25° C Sample Temp. I I" I Jai(° C) ph sp.c.cued. 2nd I Valf P I (STD) 2nd I I It/I;h• stet 25T°C I I I I I I I jCJ on sp.c.cond. (car warmer) vow. s 3rd I I�j I I i I (STD) 3rd I I If/L f--7j at 5m C I I II spec.CO 4. (other pe.ss i value units '/ph ,,yy 4th I li4T I CI (STD) 4th I I III 121*4 at 5T°C MIL II WOG cond. (odor prr.rr n ) vow onus M FIELD COMMENTS Sample Appearances Odor A/c r ILL, Color: Al.-,0,P Turbidity: , / 1 Weather Conditions: 0 _ almiten fl A _ Precipitation 0outlook 174,- -v 1k _ - /t3 - C.ie toff.c K\ ( ( I lo i, -7/c" _.'7� C. 'c-. , 'rc Specifk Comments:e . Vr u , I c r'i, -- -1 e --- 7; ©> j.-3roc .A '4 c 4s /2 -/3- 'eats . rI� t I, . . , Hic 2 - /, ra(.4eS . - -- `` <.t I certify that samplin proc resjwere in accordance with appliSbie EPA, State and WMI protocols. /_2 P/7/ V / -. Employer:,56C l)ar�) • c- m.* ewrM.l N 93a..H6 w EMI FFtA 1.m . REGION A 4"7,i March 10, 1993 Weld County Commissioners Centennial Center 915 10th Street Greeley, CO. 80631 Dear Commissioners: We are owners of the property directly south and west of the Central Weld Sanitary Landfill. We have recently received a notice from Chuck Cunliffe of the Weld County Planning Department that you intend to hold a public hearing on the landfill on April 5, 1993. Prior to this notice, we have not been contacted by anyone at the county or the media regarding our knowledge of the current situation or the activities at the landfill for the past 20 years. Our property is the only bordering property which is below the landfill. We were not in favor of placing this facility uphill of us in 1971 when the Board of Commissioners approved the location. Nevertheless, we have had to deal with it in the best manner possible throughout these past 21 years and must continue to do so... In July 1992, the current operators informed us they had recently expanded their testing of the groundwater and discovered some contamination along the common borders of our property. Naturally,we were very concerned about this discovery they had made. However, since that time, we have been pleased to see the progress and commitment Waste Services/Waste Management has demonstrated toward resolving this situation. Our family has owned this property next to the landfill for many, many years and would like to continue to own this property. We are trying to work with the landfill operators to allow them a reasonable amount of land around the facility to do the right thing. Even if they acquire this additional property, we will still be the only property owners directly in the path of groundwater contamination. We, and you, must not jeopardize the community's best option to clean up and eventually close this facility properly. If you force the premature closure of the landfill, you are placing our property at risk for greater long range environmental damage. Please don't jeopardize the community's best solution. • 931061 h it f�i I 0 . Pe.; (-Vadat_ S:ueo Weld County Commissioners Centennial Center March 10, 1993 Page Two Negative community opinion and pressure will not solve the only real issue; environmental impact to us in the future. We can't just wish or complain this situation away. This approach is not productive and only stands to hurt Weld County and our environment. Let's focus on taking advantage of their expertise to correct any past problems. We urge you to give Waste Services/Waste Management a chance to continue their professional approach to operating, clean-up and proper closure of the Central Weld Sanitary Landfill. Any other action will place our property in jeopardy. Very truly yours, �R2CG +ritn- /4r Ella Marie Spomer Hayes Susanne Spomer Stephens CC: John Pickle. Weld County Department of Health Lee Morrison, Weld County Assistant County Attorney Randolph L. Gordon, M.D., M.P.H., Director, Weld County Health Dept. Chuck Cunliffe, Weld County Planning Department Roger Doak, Colorado Department of Health Barbara Taylor, Water Quality Control Division Colorado Dept. of Health Joyce Williams, Department of Health Environmental Compliance Officer • 931061 -Ax__ .,- 7'); C: :\i' , 7-19 __-- ((// Attorneys At Law - 1775 Sherman Street • Suite 1300 Denver, Colorado 80203 `;`.�' . : (303) 861-1963 • Fax: (303) 832-4465 Extension 123 March 17, 1993 Ms. Connie Harbert, Chairperson Weld County Commission 915 Tenth Street Post Office Box 758 Greeley, Colorado 80632 Re: Hearing of April 5, 1993 Regarding Central Weld County Landfill Dear Ms. Harbert: On behalf of the Ashston-Daniels Neighborhood Association, we request that a public comment period be set aside from 1 p.m. to 2 p.m. on April 15 for presentation by four witnesses of the Association and me. We also request that the County obtain the services of a court reporter for the hearing and that I be allowed, on behalf of the citizens, to ask questions of witnesses at the hearing. We understand that the issue at the April 5 hearing is whether there is sufficient basis to proceed to a certificate of designation revocation hearing. We are prepared to proceed in an orderly and efficient manner to address those matters which justify and require a revocation and closure order. Sincerely, Gregory J. Hobbs, Jr. for HOBBS, TROUT & RALEY, P.C. GJH: lbc cc: Mr. Lee Morrison Ashton-Daniels Neighborhood Association r'- `,1- .-0 I �3 17 I—' Ce�: P4; WasaeSrc_ 9106 / WL ERN INTERNATIONAL MUSIC, IC. 3707 65th Avenue Greeley, Colorado 80634-9626 U.S.A. 303-330-6901 FAX: 303-330-7738 March 6, 1993 Dr. Patricia A. Nolan, Executive Director Colorado Department of Health 4300 Cherry Creek South Denver, CO 80222 Dear Dr. Nolan: As a member of the Ashton-Daniels Neighborhood Association I have a particular interest in recent activities relating to the Central Weld Sanitary Landfill. I understand you have kept an open line of communication with various individuals and officials wanting answers on this issue—a welcome attribute. There are three points I wish to make, and I would appreciate your response as soon as possible. First of all, I would like to know why the CWSL owners have been allowed to operate an unlined facility since 1971, dumping heavy metals, petroleum-contaminated soil, alleged radio-active material and pesticides, asbestos, sludge, and other toxins into 5 to 25 feet of standing water, draining into now-dead lakes, into an irrigation ditch and thence to the Big Thompson River, a source of irrigation water for the City of Evans? How can a site like this not be an insidious threat to the environs by creating tremendous health problems to the crops, animals and to humans? Would the Health Department personnel—or our legislating officials—savor living in such an environment? Secondly, the State Health Department will not allow any County officials to view a Special Waste Permit, stating that they have to protect the "trade secrets" of Waste Management. How can this be a reason for secrecy, and why is the Department concerned with protecting what is known as "the largest waste-hauling and disposal firm in the world"? Thirdly, the so-called Fact Sheet reads as though it were written directly by Waste Management itself; to the private citizen this looks like a direct conflict of interest . Two week-ends ago Waste Management was passing out this same Fact Sheet in their public relations booth at the Greeley Mall. Who, indeed, did compose this Sheet? Thank you for your attention: I look forward to your response to these issues. Yours truly, Saxon avis pc: Governor Roy Romer Senator Hank Brown Representative Wayne Allard State Representative Dave Owen Weld County Commissioners John Pickle, Weld County Dept. of Health Chuck Cunliffe, Weld County Department of Planning Services Richard Evans, City Manager kA LH- C� e PQ; I,vaoit-S feb 931061 March 1993 "NEW AND IMPROVED" FACT SHEET ✓ CENTRAL WELD SANITARY LANDFILL Questions and Answers Compiled by The Ashton-Daniels Neighborhood Association This question and answer FACT SHEET is in response to a "fact sheet" dealing with these same questions and answers distributed by the Colorado Department of Health (CDH) to the public concerned about the Central Weld Sanitary Landfill (CWSL), known locally as the Greeley- Milliken Landfill. That "public" comprises the citizens truly concerned about their environment— their rivers; soil and water near the Landfill. These are citizens who want questions answered frankly and truthfully. Q. Is the landfill regulated? A. CWSL has never filed a complete Design and Operation Plan in its 21 years of existence.* A discharge drain flows into Spomer Lakes from the landfill. The odor flowing from the landfill into Spomer Lakes and through the irrigation ditches violates 6 CCR 1007-2.1.1 of the Minimum Standard. CWSL has never, in its 21 years, had a discharge permit (NPDES)—a violation of 6 CCR 1007 2.1.2. The facility is trying to expand vertically. If allowed, the facility would not blend into the surrounding area when closed: violation of 6 CCR 1007-2.1.4 (Minimum Standards). A number one requirement of a landfill is that it "be dry and stay dry".2) However, this landfill, located in a major drainage area 1/4 mile from the Big Thompson River, is wet and it stays wet! Q. Has the Landfill contaminated the ground water? A. Yes. CWSL admitted to the contamination from its lab tests 3) And, according to Glenn Mallory and Roger Doak of CDH, in a letter to CWSL on Dec. 23, 1993, they have. Also, as late as Feb. 22, 1993, the Weld County Health Department (WCHD) confirmed the existence of contamination in a memorandum to Chuck Cunliffe, Weld County Department of Planning Services. Q. What about the milky color and the odor of Spomer Lakes? A. The lakes were full of fish, crystal clear and odor free until the landfill began operation. By the mid-seventies, according to witnesses, the lakes turned white and all of the fish died. If this were a natural occurrence the lakes would have been milky white and odoriferous before 1971. 1)Austin Buckingham,CDH,in a letter to Attorney Kent Hanson Sept. 18, 1992,and on her inspection of the landfill,Oct 12, 1992. 2)Paul Paulson,CDH,in an audiotape,siting the Ault Landfill. 3)"Hydrogeologic and Geotechnical Characterization Report"from Golder Associates,July 1992. 931061 A Q. Is the landfill responsible for the condition of Spomer Lakes? A. Yes it is, according to results of private lab testing and eye-witness accounts of the lakes' history. Q. Why would you give the landfill a permit to discharge water to Spomer Lakes when the lakes appear polluted? A. When private lab tests revealing heavy metals are available, and odor, visible pollution and VOC's (volatile organic compounds) are present, it would seem inconceivable that CDH could even think of allowing this pollution to go through private lands, irrigation systems and into the Big Thompson, Evans Ditch and ultimately the South Platte. Q. Isn't the ground and surface water contaminated by heavy metals? A. Yes, as confirmed by private lab tests submitted by citizens to CDH. CDH has relied on the landfill to do its own testing since the State claims to have no available funds for this purpose. Q. Will private wells in the area be tested? A. Good question! There has been talk of this since July or August of 1992, but as yet the neighboring landowners have not been contacted about any specific intentions. Q. Has the landfill submitted engineering and operation plans? A. No complete Design and Operations Plan has been submitted during its 21-year history, according to a memo to Chuck Cunliffe Feb. 22, 1993 from WCH, thus violating C.R.S. 30-20- 103. Q. Is the landfill in the water table, and isn't this illegal? A. Yes; in a letter dated Dec. 21, 1992 to CWSL, CDH states: "Solid wastes have been placed into the ground water at this facility." In a memo dated Feb. 22, 1993, WCHD states that this condition is due to a lack of cover and adequate surface drainage. It is a violation of Subsections 2.1.2 of Solid Waste Regulation, 3.11.5 of Water Quality Control Commission Rules, and 2.1.4 of the Solid Waste Regulation. It was a bad site from the start,4) as time has shown. Meanwhile, the landfill operation continues to further jeopardize the environment, affecting human health and safety. For further information call 339-0629, 330-8726 or 330-6901. A Probable Cause Public Hearing is scheduled before the Weld County Board of County Commissioners on Monday, April 5, 1993, at 9:00 am., in the County Commissioners' Hearing Room, First Floor, Weld County Centennial Center, 915 10th Street, Greeley, Colorado. 4)Testimony at the original hearing on the Greeley-Milliken Landfill,September 22,1971. Q 931061 March 18,' 1993' Ms. Constance Harbart, Chairwoman Weld County Commissioners Centennial Center 915 10th Street Greeley, CO 80631 Dear Ms. Harbart: I am in receipt of a letter dated March 10, 1993, to the Commissioners regarding CWSL from Ella Marie Hayes and Susanne Stephens. Last week, they asked to come and visit about CWSL. In our conversation we agreed the only real issue is the environmental impact. They said several times that they felt Waste Management Inc. had the funds to clean up the site. At each such statement, I agreed, but said Waste Management Inc. was obligated to the environment and to clean up whether they closed tomorrow or in a decade. I asked how could we as caretakers of this land support another decade of pollution? The missing link, I believe, is in paragraph four: "We are trying to work with the landfill operators to allow them a reasonable amount of land around the facility. " Money talks! Even Waste Management Inc. gives the Big Thompson as the recipient of their discharge. We own property on both sides of the road before the Big Thompson. How is the water to get there and not go through our property? What of landowners who take water out of the Evans ditch? In addition to the drainage to the Big Thompson, each year, a few weeks after irrigation starts above us to the north, a spring breaks out in our corn fields. This water comes from underground aquifers. The spring dries up each winter. Attached is a letter from a resident and geologist regarding the underground "piping" in our area. As ever, our biggest concern is the water, the Big Thompson, the South Platte, the Evans ditch and our own irrigation ditches and the surrounding soil. cc, : pc , t,,_ c k =—e ,ixcs u) 931.061 2 Will this be another Globeville? How do we know the impact of children playing, livestock drinking, crops absorbing, and wildlife feasting in the fields that have been irrigated? The Daniels have trusted our state and county since the 1860s; we know they would not allow any "premature closure" (paragraph 4) . We trust it will close very shortly, but we know they will do their job to make sure Waste Management Inc. adheres to proper environmental closure plans and accept their long-range responsibility for the environment. Sincerely, $'f'dJ Madeline Daniels 23732 WCR 271 Milliken, CO 80543 339-0629 cc: Governor Romer Ms. Gale Norton Mr. T. Monahan Ms. Laura E. Perrault Mr. Dan Miller Dr. Patricia Nolan Ms. Barbara Taylor Ms. Patricia Nelson Mr. Victor Sainz Mr. David Shelton Mr. John Pickle Mr. William Webster Mr. George Baxter Ms. Barbara Kirkmeyer Mr. Dale Hall Rye 061 ,2 November 10, 1992 Mr. Glen Mallory Program Manager Solid and Hazardous Waste Division Colorado Department of Health 4300 Cherry Creek Drive South Denver, CO 80222-1530 Dear Mr. Mallory: As a concerned citizen and landowner I am taking this opportunity to comment on your agency's proposed solid waste regulations scheduled to be taken before the Colorado State Board of Health in a hearing for adoption on November 18, 1992. After review of the draft regulations provided to me by Austin Buckingham of your office and comparing them to the Environmental Protection Agency's Solid Waste Disposal Facility Criteria; Final Rule (published in the October 9, 1991 edition of the Federal Register) and the solid waste regulations developed and adopted by the State of New Mexico (filed December 31, 1991) in compliance with EPA's ruling I am suggesting some additional language for inclusion in your proposed regulations. Under section 3 - Standards for Solid Waste Disposal Landfill Sites and Facilities of the proposed Regulations Pertaining To Solid Waste Disposal Sites And Facilities is subsection 3.1 - Location Restrictions And Site Standards. The State of New Mexico's Solid Waste Management Regulations contain the comparable section : Part III - Maximum Size Of Facility and subsection : 302 - Siting Criteria For Landfills (both attached) . I direct your attention to 302(A) (2) which states no landfill shall be located "where depth to seasonal high water table will be closer than 100 feet to the bottom of the fill". I suggest that the proposed Colorado regulations contain a similar depth to groundwater provision under subsection 3.1. Such a provision would serve to strengthen your 3.1.11 clause in the protection of groundwater from contamination. My property is located in Weld County less than a quarter of a mile from the Central Weld Sanitary Landfill. I am concerned about groundwater contamination resulting from solid waste burial in that landfill. I am a trained geologist and I can assure you that sink holes and the geologic phenomenon known as piping are prevalent in the clayey formations that exist in that area. Piping can tansport water subsurface both horizontally and vertically as rapidly as water can flow through a plastic pipe. As I grew up there I witnessed this phenomenon numerous times and am confident I could provide evidence of piping occuring on my property at any time of the year. It has been brought to my attention that solid waste has been buried at the landfill site in 6 feet of water at times. This does not surprise me as I have groundwater fed springs on my property that flow all year and serve as watering holes for my livestock and an abundance of natural wildlife. The groundwater table is quite shallow (close to the surface) and contamination of area groundwater through subsurface migration through buried waste at the landfill is 931061 an undeniable consequence that should not be allowed. Perhaps if my suggested language were included in your proposed regulation these types of undesirable effects on groundwater could be better precluded. I appreciate your consideration of my suggestions and concerns. Sincerely, /,47,6r.,1 Albion Carlson 7191 49th street Greeley, CO 80631 • • • fl 931061 I.. yfic '94.4 NEW MEXICO > _. SOLID WASTE MANAGEMENT -it- REGULATIONS ,,, .... 0 ar,:. • i:.�H -, \ \\ '41.t FJI; •.114• 1:', SOLID WASTE BUREAU New Mexico Environment Department 'i= �' C;;... 1.. . 931061 5 establishment of the priority list. D. The interim status of any solid waste facility granted by Subsection A.1 or B.3 of this section: 1. shall automatically terminate upon: a. final closure, if accomplished prior to the issuance of a permit; b. suspension of operation for more than one year; c. the failure of the owner or operator to withiSubsection results of ofpthismsectioniif assessment in d. the Secretary' s final order on a permit application; and 2. may be revoked or suspended for violation of an applicable provision of these regulations in accordance with the procedures set forth in the Department' s Rules Governing Appeals from Compliance Orders; provided that for purposes of the iinterimestatusushs alloberdeemedptoals be afrom permiitpliance Orders, E. The opperator of any solid waste facility operating der inte of these om rm tas shall rshalltcply with all applicable provisions of Part IV PART III MAXIMUM SIZE OF FACILITY; SITING CRITERIA 301. MAXIMUM SIZE. The Secretary shall not issue a permit for any active solid waste facility larger than five hundred acres. 302. SITING CRITERIA FOR LANDFILLS.-- A. Except as otherwise provided in Subsection B of this section, no landfill shall be located in the following areas: 1. floodplains, within 500 feet of wetlands, or 200 feet of watercourses; closer than 100 feet to thetbottomooflthegfillter table will be 3. where subsurface mines are considered to be a problem as defined by New Mexico Department of Energy, Minerals and Natural Resources, or in an area subject to sink holes; 4. within 200 feet of a fault that has had a displacement within Holocene time (i.e. , the past 11,000 years ) , unless all pollution control structures, including liners, • leachate collection systems, and surface water control systems, are designed to resist the maximum horizontal acceleration in lithified material for the site; gg 5. within historically or archaeologically p Act, Sectionsi18-6-1ntos unless compliance78,with Cultural Properties andAHistoric Sites Preservation Act, Sections 18-8-1 to 18-8-8 N6. within 1,000 feet of public water supply well or EIB/SWMR-3 37 921061 ' w8a, 8' o:gc .o°. 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WO 931064 Breeze, March 11, 1993 Spe._ Jal waste plan kit t from county by Matt Lubich John Pickle, head of the ges. With the variety of other Hearing set The Weld County Health county environmental protec- issues currently facing him and Department has not been given tion division, said that in the the county regarding the The : b County bore- course of his office's work it CWSL site, he said, he has not misstdners brie set a probable. the chance to review a copy of cause hearing for iApril 5 to a "special waste plan" that the became apparent that they had had time to pursue the issue. considetralr issues regarding the State Health Department never received a copy of the Waste Service Vice-President besting. Weld Landfill. The p Plan. Special wasteplans detail for Landfill Operations Bill hearing;:begins at v:a,m. in the: approved in December for P ' P' �' P commissioners' !Marini ro ar om, , Waste Services Corp. sites in how facilities intend to deal Hedberg said he wasn't aware the centennial Cster in the region, the with wastes such aspetroleum of an issues regarding the downtown Grbeley. $ including Y 8 $ Weld County Director of Central Weld Landfill. contaminated soil and other limited access question. The Planning Chun cannfre said to Glenn Mallory, materials that they are allowedplan, he said, is an attempt b county: officials will present According t�', P by testimony regarding a variety of state section chief for solid to accept, but which may the company to conform with violations the,' allege they've dis waste, the company asked the require specific and additional impending new state regula- covered at the . Among, those -'charges is is that waste ! CDE to limit access to the procedures. tions that will come in under disposal at the site has con- plan because it contains "pro- "The state has already review- what is known as Subtitle D. Laminated the groundwater and. . that the facility is lacking_several pnetary information." Simply ed it and approved it," Pickle The plan has only been dis- necessary _Permits. a res put, Mallory said, the company said, "but it seems to me that muses off the landfill,cc �aiso:. asked it be kept confidential we should have the right to tributed to the state, he said, have the chance to present their' because it details "trade se- review it too." Pickle said his pending final drafting and own testimony. Public comment acts." office did receive a co a implementation of those will also be solicited. copy of regulations. If probable cause is determined, But that confidentiality has draft of the plan, dated Febru- When that occurs, Hedberg ashoos cane hearing could beof the seemingly even extended to ary of 1992, but he believes the said, the plan will be dis- landtln's permit ofoperation. local environmental health document approved this winter tributed to all agencies. officials. may contain substantial chan- Mallory said 7liesday that he had just received a letter from e l's n N o.g ee m a ,� d N o . d-xo 77 nU Office tatrequesting y hatar he a o , sit, f ' ro r� r �r contact the company and ask m Rat/?a, Iry CO �' _ 2 g�- n 3 n ° m ° c' o a a ..�{EADER �PIAl1ON A, them to substantiate why the r ^ o as nrs n o = _ information should be con- o CD p m o Nw .ci, 7w o n ° Si POI Landfill issues sidered proprietary. N n no C C -tin G, &° n o r• m ° -n r o.0foo3 " goa " nGo-"', g- ? n O. To Tile Tribune: o n a. = o ,9 a --g 5' m 2 0 N 2. H. Our water supply is finite.We take it for s' 5 ;to a °p o w o -e — granted. Almost 70 percent of the planet is °c a 0a ^ w p ao n a w laca'e d r v psi covered by water with only 3 percent of it pi IA' a v o o a m `; a = Y �'. O being fresh water held in streams, rivers, ft} lakes, underground aquifers or frozen in c iv E E o c d o d 'a o ° 3. Zia glaciers and ice caps. "i aio n g 5 >< co 5 N °can g a N' a n � > g0. gm °'. y W E - a a a = -n, a• o or. a O,< o pson and ° n a x w g A South mega-giantte Rivers companyted called of Waste = w= o n a m '-3 d a 2 ,- , o n res Management owns and operates the Central Please protect our natural resources. It's °'F a e°.e g . CD o .-1 ° U w Weld Landfill only one-fourth mile away easy to be complacent with an out-of-sight, 0 0 °a O c- ro- - _ ' L •N �• a from the Big Thompson River.So far there o m m c 2 E N an d n c " out-of-mind attitude. But our waters won't = a 0-a n = a in 0 < y ? d ° 0 are 21 years of trash leaking its contaminants take care of themselves. We want the area ° down the hillside to the most susceptible 6 5 n Cr, c, n = n rn a _ o leaned up and the landfill closed. n _ = E - N r, N a N &a- S. St 0" = g N rb oCo. a c _ Illt source of fresh water. There is a hearing regarding the continued CD n ro CD oo Irrigauon water surges operation of this landfill on at 9 a.m.April 5 �d the landfill in summer at the Centennial Building. Please get c.„r r duo and it's located in the middle of a natural involved.I hope our county commissioners to " n n drainage area.Keeping this landfill in oper- have done their homework and are ethically rn n a ° ation only compounds the problem.Even the � n � r1 '.• ;, w - B bound to truly do what is right for the corn- - w o o fill dirt used as part of daily cover is petrole- munity,not what they may be enticed to do 0,2 ' .b 0 ° um-contaminated and they truck it in day b a large company with lots of money. 4 •!<- ' o m • C . after day.Just where do you think all of these y P y Ann Hayes 0 0. o co c volatile organic compounds are going? Greeley • g Eventually they end up in the water o n 0 to rN 3. o o5' m °.' = �ow � N s 931.0+6 . I 8 n Waste Services Corporation 6037 77th Avenue - - - Greeley, Colorado 80634 A Waste Management Company 303/330-2641 r_, March 18, 1993 • Barbara Taylor, Environmental Engineer Colorado Department of Health Water Quality Control Section WQCD-PE-B2 4300 Cherry Creek Drive South Denver CO 80222-1530 Re: FOURTH QUARTER FRENCH DRAIN MONITORING RESULTS AT CENTRAL WELD SANITARY LANDFILL (CWSL) Dear Ms. Taylor: Central Weld Sanitary Landfill, under its own initiative, is currently conducting quarterly monitoring for the flow of water from the french drain into the onsite retention pond. The intent of this program is to compile background water quality data that would reflect seasonal activities occurring around the landfill, such as pesticide and fertilizer use related to agricultural activities. Enclosed for your review is the fourth quarter 1992 analytical report for the french drain at CWSL. This data is intended to provide additional information on the quality of water from the french drain in consideration of CDH's review of the Colorado Discharge Permit Application. The sample was taken at the outfall of the french drain on December 17, 1992. The analysis was performed by the Waste Management, Inc. Environmental Monitoring Laboratory (EML). The enclosed monitoring data is in addition to previous sampling events conducted on March 28, 1992 as part of the site hydrogeologic investigation and additional sampling which was performed on July 16, 1992. The results of these first two sampling events are included in the Colorado Discharge Permit Application submitted to the Colorado Department of Health (CDH) on January 7, 1993 for the french drain at CWSL. The report is comprised of the Data Qualifier Report, Fourth Quarter Analytical Data and Chain of Custody and Field Information Forms. wp51W\leAer\03159312.cdb P: CWSL 3.1 d 4.11.2(new file) ale; ft 924..061 Letter Barbara Taylor March 18, 1993 Page 2 CWSL would greatly appreciate your expeditious review of the frenchdrain permit application. Please contact Bill Hedberg at 654-1133 or Alan Scheere at 770-3324 if we can be of any assistance. Sincerely , zcenicc Bill Hedberg Alan Scheere Division V.P. Landfill Operations Environmental Specialist cc: Roger Doak, CDH w/enc John Pickle, WCDH w/enc Lee Morrison, Assistant County Attorney w/o enc Chuck Cunliffe, Weld County Department of Planning w/o enc Weld County Commissioners: Constance Harbert, Chairman w/o enc Bill Webster, w/o enc Dale Hall, w/o enc George Baxter, w/o enc Barbara Kirkmeyer, w/o enc wp5l\as\letter\03159312.cd F: CWSL 3.1&4.11.2(new file) 93 061 S Letter Barbara Taylor March 18, 1993 Page 3 bcc: Len Butler Tom Schweitzer Tom Buchholz Bruce Clabaugh Marian King Bill Jeffry Bob Damico Brad Keirnes File wp51 W\farcA03159312.cdb P: CWSL 3.1&4.11.2(new file) 93 O61 zl 3 • cc tOt DEPARTME NT OF PLANNING SERVICES PHONE (303)353-3845, EXT. 3540 �• WELD COUNTY ADMINISTRATIVE OFFICES WI p1400 N. 17TH AVENUE GREELEY, COLORADO 80631 COLORADO March 2, 1993 Waste Services Corporation 40000 Weld County Road 25 Ault, CO 80610 Subject: ZCH-96 Dear Sirs: The Probable Cuase Public Hearing originally scheduled for March 24, 1993 , HAS BEEN RESCHEDULED by the Board of County Commissioners. Notice is hereby given that on Monday, April 5, 1993, at 9:00 a.m. , or as soon thereafter as the agenda of the Board of County Commissioners permits, the Board of County Commissioners of Weld County will hold a Probable Cause public hearing pursuant to Section 81 of the Weld County Zoning Ordinance and the policies and procedures of the Weld County Administrative Manual. This meeting will take place in the Commissioners' Hearing Room, Weld County Centennial Center, 915 Tenth Street, Greeley, Colorado. The purpose of this public hearing will be to review Case Number SUP-116 for compliance with conditions of approval as approved by the Board of County Commissioners on October 6, 1971, to determine if probable cause exists to hold a hearing on revocation of SUP- 116. Mr. John Pickle, in his memorandum dated February 22, 1993, has identified the items of non-compliance with conditions of approval for SUP-116. A copy of his memorandum is attached. If it is determined at the public hearing that there is probable cause that you are not in compliance with SUP-116 the Board of County Commissioners will schedule a Show Cause public hearing to consider revocation of the Special Review permit. If you have any questions regarding this matter, please call or write. Respectfully, C� � Chuck Cunliffe, AICP Director enclosure pc: William J. Hedberg Marian King Bill Jeffry Lee Morrison John Pickle L_x-GL.d bJ- r 931061 (ice DEPARTMENT OF PLANNING SERVIC ES ' PHONE (303) 3533845, EXT. 3540 C• WELD COUNTY ADMINISTRATIVE OFFICES 1400 N. 17TH AVENUE GREELEY, COLORADO 80631 COLORADO March 2, 1993 TO: SURROUNDING PROPERTY OWNERS Subject: ZCH-96 NAME: Waste Services Corporation, c/o Waste Management FOR: Central Weld Sanitary Landfill LEGAL DESCRIPTION: Part of the W2 SW4 and the SE4 SW4 of Section 32, T5N, R66W of the 6th P.M. , Weld County, Colorado. LOCATION: Approximately 1 1/2 miles northeast of the Town of Milliken. A Probable Cause Public Hearing originally scheduled before the Weld County Board of County Commissioners on Wednesday, March 24, 1993, HAS BEEN RESCHEDULED to Monday, April 5, 1993, at 9:00 a.m. , or as soon thereafter as the agenda of the Board of County Commissioners permits , in the County Commissioners' Hearing Room, First Floor, Weld County Centennial Center, 915 1Oth Street, Greeley, Colorado. The purpose of this public hearing will be to review Case Number SUP-116 for compliance with conditions of approval as approved by the Board of County Commissioners on October 6, 1971, to determine if probable cause exists to hold a hearing on revocation of SUP-116. You are receiving this notification because your property is within five-hundred (500) feet of the property being reviewed. All persons in any manner interested are requested to attend and may give testimony pertaining to the uses occurring on the approved site. For additional information write or telephone, Chuck Cunliffe. -1-- 9x1061 CERTIFICATE OF MAILING The undersigned hereby certifies that a true and correct copy of the foregoing Notice of Hearing, was placed in the United States mail, postage prepaid, addressed to the following property owners. DATED this 3 day ofQ/J , 1993. -d, a -3211-/ Deppty Clerk to the Board GREGORY J. HOBBS, JR. HOBBS, TROUT & RALEY, P.C. ATTORNEYS AT LAW 1775 SHERMAN STREET, SUITE 1300 DENVER, CO 80203 SENATOR HANK BROWN 1100 TENTH STREET, ROOM 201 GREELEY, CO 80631 SENATOR TOM NORTON SENATE CHAMBERS STATE CAPITOL BUILDING DENVER, CO 80203 931061. 3 CERTIFICATE OF MAILING The undersigned hereby certifies that a true and correct copy of the foregoing Notice of Hearing, was placed in the United States mail, postage prepaid, addressed to the following property owners. DATED this day of /0/2-CJ ! , 1993. he/ #ah Dep y Clerk to the Board CRAIG A. SMITH D.C. SMITH CHIROPRACTIC OFFICES, P.C. 801 ELEVENTH AVENUE GREELEY, CO 80631 931061 L/ CERTIFICATE OF MAILING The undersigned hereby certifies that a true and correct copy of the foregoing documents, was placed in the United States mail, postage prepaid, addressed to the following property owners. DATED this O31141 3 '4 day of 772Cj/J,[ , 1993. Depu Clerk to the Board DON HOFF ATTORNEY AT LAW 1025 9TH AVENUE, SUITE #309 GREELEY, CO 80631 WALKER MILLER ATTORNEY AT LAW 822 7TH STREET GREELEY, CO 80631 931061 rati;), DEPARTMENT OF PLANNING SERVICES r t4 PHONE(303) 353-3845, EXT. 3540 WELD COUNTY ADMINISTRATIVE OFFICES 140lungCi ;. , ON ORAAVENUEO631 1 GREELEY, COLORADO 80631 COLORADO March 2, 1993 Waste Services Corporation 40000 Weld County Road 25 Ault, CO 80610 Subject: ZCH-96 Dear Sirs: The Probable Cuase Public Hearing originally scheduled for March 24, 1993, HAS BEEN RESCHEDULED by the Board of County Commissioners. Notice is hereby given that on Monday, April 5, 1993, at 9:00 a.m. , or as soon thereafter as the agenda of the Board of County Commissioners permits, the Board of County Commissioners of Weld County will hold a Probable Cause public hearing pursuant to Section 81 of the Weld County Zoning Ordinance and the policies and procedures of the Weld County Administrative Manual. This meeting will take place in the Commissioners' Hearing Room, Weld County Centennial Center, 915 Tenth Street, Greeley, Colorado. The purpose of this public hearing will be to review Case Number SUP-116 for compliance with conditions of approval as approved by the Board of County Commissioners on October 6, 1971, to determine if probable cause exists to hold a hearing on revocation of SUP- 116. Mr. John Pickle, in his memorandum dated February 22, 1993, has identified the items of non-compliance with conditions of approval for SUP-116. A copy of his memorandum is attached. If it is determined at the public hearing that there is probable cause that you are not in compliance with SUP-116 the Board of County Commissioners will schedule a Show Cause public hearing to consider revocation of the Special Review permit. If you have any questions regarding this matter, please call or write. Respectfully, C ' Chuck AICP Director enclosure pc: William J. Hedberg Marian King Bill Jeffry Lee Morrison John Pickle -T— co . b,., A1% &)mfrC67 (it (t DEPARTMENT OF PLANNING SERVICES PHONE (303)353-3845, EXT. 3540 Willp WELD COUNTY ADMINISTRATIVE OFFICES 140 N• EY, O ORAAVENUEO631 GREELEY, COLORADO80631 COLORADO March 2, 1993 TO: SURROUNDING PROPERTY OWNERS Subject: ZCH-96 NAME: Waste Services Corporation, c/o Waste Management FOR: Central Weld Sanitary Landfill LEGAL DESCRIPTION: Part of the W2 SW4 and the SE4 SW4 of Section 32, T5N, R66W of the 6th P.M. , Weld County, Colorado. LOCATION: Approximately 1 1/2 miles northeast of the Town of Milliken. A Probable Cause Public Hearing originally scheduled before the Weld County Board of County Commissioners on Wednesday, March 24, 1993, HAS BEEN RESCHEDULED to Monday, April 5, 1993, at 9:00 a.m. , or as soon thereafter as the agenda of the Board of County Commissioners permits, in the County Commissioners' Hearing Room, First Floor, Weld County Centennial Center, 915 1Oth Street, Greeley, Colorado. The purpose of this public hearing will be to review Case Number SUP-116 for compliance with conditions of approval as approved by the Board of County Commissioners on October 6, 1971, to determine if probable cause exists to hold a hearing on revocation of SUP-116. You are receiving this notification because your property is within five-hundred (500) feet of the property being reviewed. All persons in any manner interested are requested to attend and may give testimony pertaining to the uses occurring on the approved site. For additional information write or telephone, Chuck Cunlif£e. T 931061 (<, CERTIFICATE OF MAILING I hereby certify that I have placed a true and correct copy of the surrounding property owners in accordance with the notification requirements of Weld County in Case Number ZCH-96 for Waste Services Corporation in the United States Mail, postage prepaid First Class Mail by letter as addressed on the attached list. this 2nd day of March, 1993. 931061 T SURROUNDING PROPERTY OWNERS Waste Services Corporation ZCH-96 Ella Marie Hayes and Susanne Stephens, et al. 095931000007 Box 773 095932000008 Saratoga, WY 82331 105705000034 G.D. Mossberg and Janet Lea Sherrod-Mossberg 018 4603 83rd Avenue Greeley, CO 80634 Arthur P. Garcia 095932000010 13998 Weld County Road 378 105705000043 Milliken, CO 80543 Heirs of Ann Spomer, et al 015 c/o Louis Reikert, 1st National Bank P.O. Box 1058 Greeley, CO 80632 Samuel S. and Myrtle Ann Telep 016 2315 54th Avenue 017 Greeley, CO 80634 Keith V. Melodie R. Steven D. and Douglas L. Kammerzell 12314 Highway 60 Milliken, CO 80543 105706000028 931061 �' DEPARTMENT OF PLANNING SERVICES PHONE (303)353.3845, EXT. 3540 WELD COUNTY ADMINISTRATIVE OFFICES 1400 ON ORAAVENUEO631 GREELEY, COLORADO 80631 COLORADO February 25 , 1993 Waste Services Corporation 40000 Weld County Road 25 Ault, CO 80610 Subject: ZCH-96 Dear Sirs: Notice is hereby given that on Wednesday, March 24, 1993, at 9:00 a.m. , or as soon thereafter as the agenda of the Board of County Commissioners permits, the Board of County Commissioners of Weld County will hold a Probable Cause public hearing pursuant to Section 81 of the Weld County Zoning Ordinance. This meeting will take place in the Commissioners' Hearing Room, Weld County Centennial Center, 915 Tenth Street, Greeley, Colorado. The purpose of this public hearing will be to review Case Number SUP-116 for compliance with conditions of approval as approved by the Board of County Commissioners on October 6, 1971, to determine if probable cause exists to hold a hearing on revocation of SUP- 116. Mr. John Pickle, in his memorandum dated February 22, 1993, has identified the items of non-compliance with conditions of approval for SUP-116. A copy of his memorandum is attached. If it is determined at the public hearing that there is probable cause that you are not in compliance with SUP-116 the Board of County Commissioners will schedule a Show Cause public hearing to consider revocation of the Special Review permit. If you have any questions regarding this matter, please call or write. Respectfully, Cr\la Chuck Cunliffe, AICP Director CC/sfr enclosure pc: William J. Hedberg Marian King Bill Jeffry Lee Morrison John Pickle 1' 931061 6 mEmoRAnDum WIDc Chuck Cunliffe, Planning February 22, 1993 To COLORADO John Pickle, Healt From Central Weld Sanitary Landfill Subject: This memorandum is a follow-up to our meeting with Waste Management and Waste Services on February 18, 1993. Since that time, I have also met with Glenn Mallory, and Roger Doak, Solid Waste Division, and Pat Nelson, Water Quality Division, Colorado Department of Health. In response to these meetings, it is the opinion of this Division that the Central Weld Sanitary Landfill continues in a state of non-compliance. We submit the following areas of concern as violations: 1. The operators of the Central Weld Sanitary Landfill have not submitted a complete Design and Operations Plan. (See attached letter of February 22, 1993) . This is a violation of C.R.S. 30-20-103. 2. The Central Weld Sanitary Landfill continues to operate without required Discharge Permits. This is a violation of Subsection 2.1.2. of the Solid Waste Regulations, and 25-8-501, C.R.S. In conference with Pat Nelson, Water Quality Division, their position is that the absence of the required permits constitutes technical violation of the Rules; however, they are holding further enforcement in abeyance so long as this facility continues to proceed in good faith with the Discharge Permit application process. Our Division agrees with this position. 3. The Central Weld Sanitary Landfill continues to contaminate the groundwater. A review of the Hydrogeologic and Geotechnical Characterization and supporting documents indicate that a portion of this contamination is due to a lack of adequate cover and adequate surface drainage. This is a violation of Subsections 2.1.2 of the Solid Waste Regulations, specifically, 3.11.5 of the Water Quality Control Commission Rules, and 2.1.4. of the Solid Waste Regulations. In conference with Glenn Mallory and Roger Doak, Solid Waste Division, Colorado Department of Health, their position is still as outlined in their letter of December 23, 1992. 4. The Central Weld Sanitary Landfill has allowed solid waste to come into contact with groundwater on this site. A review of the Hydrogeologic and Geotechnical Characterization and supporting documents indicate that this condition is due to a lack of adequate cover and adequate surface drainage. This is a violation of Subsections 2.1.2 of the Solid Waste Regulations, specifically, 3.11.5 of the Water Quality Control Commission Rules, and 2.1.4. of the Solid Waste Regulations. In addition, this will be a violation of Subsection 3.1.10 of t e y revised Solid Waste Regulations, which are schedule rfi effective in April, 1993. �I FEB 2 3 1993 ' •r,of n...._w.nlnnnina. 931061 -r /c This Division, and the Colorado Department of Health continue to feel that items 11 3 and lk 4 constitute a public nuisance. Consequently, we would request that these violations be brought to the attention of the Board of County Commissioners, in the form of a public hearing. Should you need additional information, please contact me. ENV\342 XC: Lee Morrison, Assistant County Attorney Randolph Gordon, M.D. , M.P.H. Glenn Mallory, Solid Waste Division David Holm, Water Quality Division IIFEB 2 3 1993 •L Lt n nlOnnlllr -- 931061 / 3 r ! m i U .,ff % ° DEPARTMENT OF HEALTH 1517- 18 AVENUE COURT DGREELEY. COLORADO 80831 ADMINISTRATION (303)353-0586 WI' pc HEALTH PROTECTION (303)353-0635 COMMUNITY HEALTH (303)3530639 COLORADO February 22, 1993 William J. Hedberg Waste Services Corporation 6037 77th Avenue Greeley, Colorado 80634 Dear Mr. Hedberg: The Environmental Protection Division of the Weld County Health Department has received the "Preliminary Design, Operations, and Closure Plan", Central Weld Sanitary Landfill, Weld County, Colorado. Initial review has revealed the document to be incomplete as submitted. Page 4- 1, Section 4.0, refers to a series of sheets (Nos. 1 through 20) which have not been provided as part of the document. The Division has ceased review of this document pending receipt of all necessary doucments. In addition, the Division requests that the term "preliminary" be defined as it occurs in the document title. If you have any question, you may contact me at (303) 353-0635. Sincerely, 45:taCia. ohn S. Pickle, M.S.E.H. Director, Environmental Protection Services TJ-359 cc: Alan Scheere, Waste Management of North America, Inc. Roger Doak, Colorado Department of Health Lee Morrison, Assistant Weld County Attorney Chuck Cunliffe, Weld County Planning Department IIFEBmireyi,r \v/) ,; 2 3 1993 ninnnir 931061 �� DEPARTMENT OF PLANNING SERVICES PHONE(303) 353.3845, EXT. 3540 WELD COUNTY ADMINISTRATIVE OFFICES C 140EY, ON ORAOAVENUE631 GREELEY, COLORADO80631 COLORADO February 25, 1993 TO: SURROUNDING PROPERTY OWNERS Subject: ZCH-96 NAME: Waste Services Corporation, c/o Waste Management FOR: Central Weld Sanitary Landfill LEGAL DESCRIPTION: Part of the W2 SW4 and the SE4 SW4 of Section 32, T5N, R66W of the 6th P.M. , Weld County, Colorado. LOCATION: Approximately 1 1/2 miles northeast of the Town of Milliken. A Probable Cause Public Hearing is scheduled before the Weld County Board of County Commissioners on Wednesday, March 24, 1993, at 9:00 a.m. , or as soon thereafter as the agenda of the Board of County Commissioners permits, in the County Commissioners' Hearing Room, First Floor, Weld County Centennial Center, 915 10th Street, Greeley, Colorado. The purpose of this public hearing will be to review Case Number SUP-116 for compliance with conditions of approval as approved by the Board of County Commissioners on October 6, 1971, to determine if probable cause exists to hold a hearing on revocation of SUP-116. You are receiving this notification because your property is within five-hundred (500) feet of the property being reviewed. All persons in any manner interested are requested to attend and may give testimony pertaining to the uses occurring on the approved site. For additional information write or telephone, Chuck Cunliffe. 931061 /� itett\C DEPARTMENT OF PLANNING SERVICES PHONE (303)353.3845, EXT. 3540 WELD COUNTY ADMINISTRATIVE OFFICES C. 1400 N. 17TH AVENUE GREELEY, COLORADO 80631631 COLORADO January 18, 1993 Waste Services, Inc. C/0 Waste Management P.O. Box 122283 Ft. Worth, Tx. 76121 Subject: Violation Notice - ZCH-96 on a parcel of land described as part of the W2 SW4 and the SE4 SW4 of Section 32, T5N, R66W of the 6th P.M. , Weld County, Colorado. Dear Sirs: A review of your property was conducted to determine if the Conditions of Approval placed on the property at the time SUP-116 was approved by the Board of County Commissioners are in compliance. The review revealed violations of Condition of Approval #1. John Pickle's memorandum dated January 8, 1993, and Trevor Jiricek' s certified letter Number P423 630 398 dated January 14, 1993, outlines the violations of Condition of Approval #1 on the Board of County Commissioners' Resolution dated October 6, 1971. The Department of Planning Services is still evaluating the possibility of violations of Condition of Approval #2 on the Board of County Commissioners' Resolution dated october 6, 1971. You will be notified if violations are identified during the Department' s evaluation. Copies of John Pickle' s memorandum dated January 8, 1993, Trevor Jiricek's certified letter dated January 14, 1993, and the Board of County Commissioners' Resolution dated October 6, 1971 are enclosed for your review. The Use by Special Review area must be brought into compliance with the Conditions of Approval within 30 days from the date of this letter. Noncompliance will result in our office scheduling a Probable Cause Hearing before the Board of County Commissioners. If the Board determines there is sufficient probable cause to warrant further action, a Show Cause Hearing will be scheduled to consider revocation of the Use by Special Review permit 116. If you have information that may clear up this matter, please call or write. Sincerely, l ^` nc Chuck Cunliffe, AICP Director enclosures pc: William J. Hedberg Bill Jeffry Lee Morrison, Assistant County Attorney John Pickle, Weld County Health Department 4 (11 mEmoRAnDum Willi o Chuck Cunliffe, Planning January 8, 1993 To Eye COLORADO John Pickle, Healtt_ �G. /.,t` From Central Weld Sanitary Landfill Subject: The Central Weld facility has been the subject of very close monitoring over the past six (6) months. Disclosure of offsite groundwater contamination by Waste Management in August 1992, along with growing community concern, prompted increased surveillance since July, 1992, and it continues to the present. During this time period, Environmental Protection staff have spent considerable time in field inspections of the site, meetings and correspondence with Waste Management, Waste Services, Colorado Department of Health, and other county offices, as well as review of reports and records from the facility. In the process of these activities we have determined the following areas of concern, which our Division submits as violations: 1. The operators of the Central Weld Sanitary Landfill did not file a Design and Operations plan, although a partial submission was made at the County's request on November 12, 1992. Additional information is still being submitted as it is developed by Waste Services. This failure to file would be a violation of C.R.S. 30-20-103 and Subsection 3.1.2 of the Solid Waste Regulations. There is some question as to whether or not this was a requirement at the time this facility was permitted. Such a report was required in the 1971 Amendments to the Solid Waste Act prior to the hearing by the Board of County Commissioners, but the Act requires such a report only "as may be required by the [State Health] Department by regulation." The State appears to have decided that no report was necessary as they treated the landfill as a grandfathered site. Regardless of the State's position, it appears that the Board of County Commissioners expected such a review and that one never occurred. A review of the files does not show that there ever has been an "approval" by the State Health Department, though there has been some correspondence in recent months. The only correspondence that could be construed as any kind of approval, was that of Dennis Hotovec, approving a change of operator, so long as the landfill continued to be operated in accordance with an operations plan, which apparently, has never existed. 2. The Central Weld Sanitary Landfill has operated without required Discharge Permits. This is a violation of Subsection 2.1.2. of the Solid Waste Regulations, and 25-8-501, Colorado Revised Statutes. 3. The Central Weld Sanitary Landfill contaminated the ground water. This is a violation of Subsection 2.1.4. of the Solid Waste Regulations. The facility has been notified of this violation by our Division on October 5, 1992, and also by the Colorado Department of Health on December 23, 1992. 4„ V 1� 'JAN 1 11 1993 _I Chuck Cunliffe, Planning Department Re: Central Weld Sanitary Landfill January 8, 1993 Page 2 4. The Central Weld Sanitary Landfill has allowed ponding of water onsite. This is a violation of Subsection 2.1.4. , and 2.2.2. of the Solid Waste Regulations. 5. The Central Weld Sanitary Landfill has placed solid waste into the groundwater on this site. This is a violation of Subsections 2.1.4 of the Solid Waste Regulations, and will be a violation of Subsection 3.1.10 of the revised Solid Waste Regulations. These regulations are scheduled to become effective in April, 1993. 6. In the absence of any design and operations plan, the only basis for establishment of the parameters for the 1971 permits, are the representations of the applicant at the time the permits were considered by the Board of County Commissioners. Those representations did not contemplate a regional landfill with a life of thirty-five (35) years, but rather one with an expected life of less than twenty (20) years. The representations did not contemplate placing fill above the existing grade as Waste Services currently plans. (Reference Design and Operations Plan, Sheet ak 7) The Colorado Department of Health has determined that violations outlined in #4 and #6 above constitute a public nuisance. Environmental Protection Services Division concurs with this determination. Consequently, we would request that these violations at the Central Weld Sanitary Landfill, be brought to the attention of the Board of County Commissioners, in the form of a public hearing for probable cause. Should you need any additional information, please contact me. /jp-011 xc: Randolph L. Gordon, M.D. , M.P.H. , Director, Weld County Health Department Lee Morrison, Weld County Assistant Attorney -r 931061 , tje- II', .� Iii 1 4 1993 DEPARTMENT OF HEALTH I�� 1577- 18 AVENUE COURT II.'n -- .L n1GREELEY, COLORADO 80631 OADMINISTRATION (303) 353-0635 HEALTH PROTECTION (303)353-0635 COMMUNITY HEALTH (303)353-0639 COLORADO January 14, 1993 Certified Letter No. : P 423 630 398 William J. Hedberg Waste Services Corporation 6037 77th Avenue Greeley, Colorado 80631 Dear Mr. Hedberg: On December 20, 1992, a representative of the Environmental Protection Division of the Weld County Health Department inspected the Central Weld Sanitary Landfill, located at 6037 77th Avenue, Greeley, in Weld County, Colorado. The purpose of the inspection was to inspect and assess the facilities compliance with the "Regulations Pertaining to Solid Waste Disposal Sites and Facilities" (The Regulations) as promulgated by the Solid Waste Disposal Sites and Facilities Act (The Act) , Title 30, Article 20, Part 1, C.R.S. , as amended. On the date of the December 20, 1992, field inspection, the following was observed, or has been observed previously: 1. This facility continues to discharge pollutants into state waters without an approved discharge permit. 2. This facility continues to allow water to pond on the eastern portion of the facility. 3. This facility continues to operate in the absence of an approved Design and Operations plan. 4. This facility has contaminated the groundwater beyond the facility property line. 5. Solid waste has been placed into groundwater at this site. 6. This facility is currently operating without an emissions permit. It has been documented that previously disposed solid waste is currently exposed to groundwater and that groundwater pollution has occurred at this location. As you are aware, subsection 2.1.4 of The Regulations states that "A site and facility operated as a sanitary landfill shall provide means of finally disposing of solid wastes on land in a manner to minimize nuisance conditions. . . ." and that 931%1 013 7klk row& RE�c�, IR C Attorneys At Law 1775 Sherman Street • Suite 1300 Denver. Colorado 80203 (303) 861-1963 • Fax: (303) 832-4465 Ext. 123 February 26, 1993 Ms. Connie Harbert, Chairperson VIA FAX: 1-352-0242 Weld County Commissioners 915 - 10th St., P.O. Box 758 Greeley, Colorado 80632 RE: Request for Rescheduling of March 24, 1993 Hearing Dear Chairperson Harbert: I have just learned that a public hearing has been set for March 24, 1993 on the Central Weld County Sanitary Landfill matter. The Ashton-Daniels Neighborhood Association has a vital interest in this matter and requested a hearing. Nevertheless, we were not contacted regarding the hearing date. I will be out of the United States traveling in Bolivia from March 20- 29, 1993, this being the spring break for my wife who is a teacher. The cost of the airline tickets was $2,000.00, and we purchased them in early January. - 4U V MAR 0 1 1993 y .. , ._ T 9101061 47 Ms. Connie Harbert February 26, 1993 Page Two In view of the circumstances, in order to allow the Ashton-Daniels Neighborhood Association to prepare for and participate in the hearing, we request that the hearing be rescheduled for an appropriate date in April. My secretary, Dee Trees, has my calendar and can coordinate the date with your staff and that of the County Attorney and the Landfill representatives. Sincerely, Greg r J. Ho(•s, Jr. for HOBBS, TROUT& RALEY, P.C. GJH/det c: • Weld County Commissioners • Mr. Tom David • Mr. Sam Telep • Mr. Lee Morrison • Mr. Chuck Cunliffe • Mr. John Pickle • Ashton-Daniels Neighborhood Citizens 931061 LS' MAR-11-93 THU :3 51 WELD CO rEA :H ' -rX NO. 3Cc.)OQ,, 21 hL MAR 1 1 1993 )I 5L L March 5, 1993 Tot Glenn Mallory • solid Waste Program `1 FROM: Laura E. Perraultkfici • u : r ;a9,Assistant Attorney General 1 1' THREIt Dan Miller First Assistant Attorney General • REt central Weld Landfill -- Regulatory Interpretation Request o₹ 6 CCR 1007-2, S 2.1.4 �ao1c_arognd On December 21, 1992, the Hazardous Materials and Waste MnotifiedWaste anagement Division of the Colorado Department of Health ("CDR") completed its eBview�ofs C several itechni arl documientson ("WasaSerVces") sthat 0011ubmitt dbbad y Waste Services regarding Studies and monitoring plans and results for the surface water, groundwater and landfill gas media at the Central Weld Landfill. As a result of this review, CDR determined, in part, that: Central Weld sanitary Landfill has contaminated the ground water. This is violation of subsection 2.1.4 of the Regulations [6 CCR 1007-2]. The Regulations clearly state a site and facility operated as a sanitary landfill shall prevent water pollution. Please provide a corrective action plan which addresses the contamination issues on and off site. Waste Services has contested the application of section 2.1.4 to its operation of the landfill. CDR has requested a written opinion of this issue. ArSRMC t•a Section 2.1.4 states: A site and facility operated as a sanitary landfill ,mAall provide means � P of finally $gealag of solid wastes nn is minimise nuisance co to ns, rich such as blown debris- att ,ta roda ni ` ZD'd 96:11 Mil SO-II-HUH MAR 11 '93 13:49 3033564966 PRGE.003 931061 L29 MAR-11-93 THU 13:51 WELD CO HEALTH OE? FAX Na 36335548'00 ', 34 shall provide compacted fill material; Beall eeme de adeta aua =,eve -w end surface drai.Atable material .oncsiateranfl air Hel1inn v st being filled, shall be lef— t l„in condition nd oforderliness and good aesthetic appearance and capable of blending with the :surrounding area. (emphasis added) . Waste Services, objection to the application of section 2.1,4 to the Central Weld Landfill is somewhat convoluted and seems to be basedwhich port nisu section 2 between CDM and ht m of nd i g 1 4 is at issueest. Services misinterpretation of this regulation by both Waste 'Services and oand CDR. In a February 2, 1993 memo, Waste Services focused on the "adequate cover" portion of section 2.1.4. To its disadvantage, Waste Services misread this portion as requiring that the operators of a landfill must "provide adequate cover with suitable material end surface drainage designated (sic] to urevent air pollution."(emphasis added).Perhaps Waste Services'reading was based, in part, on CDZ's December 21, 1992, incorrectly stated that section 2.1.4 re requires letter, which landfill u be operated to "prevent water pollution" Section 2.1.4, however, does not contain this mandate; rather it poveuti " and n. "surface drainage" prevent the "per or te that "adequate �a annd air Based on its incorrect reading of section 2.1.4, Waste SorVices' memo addressed a tangential and irrelevant issue -- whether an adequate cover and effective surface drainage alone can prevent groundwater contamination. Waste Services concluded that, because a number of other factors contribute to groundwater contamination, the existence of groundwater contamination beneath the site "is not ea eaete evidence that a landfill has been designed or operated in violation" of this portion of section 2.1.4. Although Want, Services' memo is correct in its assumption that the existence of groundwater contamination is not ee evidence that a landfill has a poor cover or bad surface drraainaag, its memo never addressed one of the real issues here -- whether the Central Weld landfill has an adequate cover and surface drainage which prevents the ponding of water. Thus, Waste Services may be in violation of this portion of section 2.1.4, . Moreover, Waste Services may be in violation of another portion of section 2.1.4. which the Waste Services' memo does not operated to "minimizs. Section e nuisance c nditi.1.4 also on that "a landfill must be is defined under 6 CCR 1007-2, s 1.2 as " Nuisance conditions" from - water pollution . ." moose which nt may result definition makes no distinction between groundDR has and insudact, this pollution. Thus, CDR may assume that if a measurablefamounttof groundwater contamination exists in the groundwater beneath the EO'd OV:11 Rill co-ii-V11 MAR 11 '93 13:50 3033564966 PAGE.004 -1- 931061 So MAR-11-93 T'HU «E_) CO H JL in NC. 3C33oodb;5a facility, the facility may not be operating in a manner to "minimise nuisance conditions." This may be due to the tact that the ayill does not be due to the ave an operator adequate failure to take frdrainage, measures. certain other n WasteIneresponseltoaCDR'saim, during a phone conversation with that "nuisance condition "representative, Waste Services acknowledged and that groundwater pollution d result from groundwater pollution, Waste Services claimed that no actual "exrut at the site.restated fro, this groundwater pollution because no one is presently using, from affected by, this contaminated groundwater. using, or is Although this interpretation has some scintilla of merit, it is too narrow. According to the legal definition of "nuisance" found in Black's Law Dictionary, a "nuisance" probably bas already occurred at this site. The dictionary defines public nuisance as "by act, or by failure to causing or permitting a condition to erform oleexigal duty,i intentionally gr B 'raB tx1A nuhlie health F or we_w ies" which injures SHw The dictionary dotines private nuisance as "an (emphasis added) . destroys orof an Bete e t individual y wrongful act a few persons or interferes with their la ul use r or of a few flowing em(emphasis addite ) . be Since this contaminatd groundwater enjoyment thereof . Yused by someone, undwatar is e public health and safety and, therefore, costitutes endangers the nuisance. The contamination constitutes a private nuisance,public as Well, because it has deteriorated offsite groundwater property. But even assuming per se occurred, Waste Services many still fails to e meet this has not oat requirement. Arguably, the term "nuisance conditions" regulatory than the term "nuisance." section 2.1.4 does not ma is that atdan actual "nuisance" be created before COB can find mandate in violation of this section; rather, it clearly states mtthat in operator must minimise "nuisance conditions." In other words, an an operator must take steps to prevent the possibility of the creation of a nuisance. As CDR has pointed out, Waste Services has failed to do this. Leachate from the landfill has contaminated the groundwater and this contaminated groundwater is flowing off site. SONCLT7Srn?; In short, although CDR incorrectly stated that section 2.1.4 legitimately alylandnill operator t "to prevent water pollution," CDR Central Weld Loncfill appears Waste Services' operation of the Services can either refute this l violate ys this section. taken every action necessary to minimize ground water g thatcontaminatio it has taken it can comply with CDH's request and draft a coective action plan n which documents what further actions it plans to take i meet section 2.1.4., h order to 60'd 9b:11 (1HJ. 88—tt-1M1 MAR 11 '93 13:51 3W:2564966 PRC£.005 T 931061 5/ CERTIFICATE OF MAILING The undersigned hereby certifies that a true and correct copy of the foregoing documents, was placed in the United States mail, postage prepaid, addressed to the following property owners. DATED this c;?u day of am , 1993. Deput Clerk to the Board DON HOFF ATTORNEY AT LAW 1025 9TH AVENUE, SUITE #309 GREELEY, CO 80631 WALKER MILLER ATTORNEY AT LAW 822 7TH STREET GREELEY, CO 80631 331061 45 7-10 Ids. 7?out& a%7?L. Attorneys At Law 1775 Sherman Street• Suite 1300 Denver, Colorado 80203 - - _ .._� (303) 861-1963 • Fax: (303) 832-4465 Ext. 123 March 22, 1993 Ms. Constance Harbert, Chairperson Weld County Commission 915 Tenth Street, P.O. Box 758 Greeley, Colorado 80632 RE: Hearing of April 5, 1993 Regarding Central Weld County Landfill Dear Ms. Harbert: It has been brought to my attention that my 3-17-93 letter to you contains an error in the first paragraph regarding the hearing date. It indeed should be April 5, 1993, not April 15. Thank you for your attention to this matter. Very truly yours, ALL CALL--/ Dee Trees for Greg Hobbs /DT c: • Weld County Commissioners • Mr.Tom David • Mr.Sam Telep ■ Mr. Lee Morrison • Mr.Chuck Cunliffe • Mr.John Pickle ■ Ashton-Daniels Neighborhood Citizens 931061 : / STATE Of COLORADO COLORADO DEPARTMENT OF HEALTH < • Dedicated to protecting and improving the health and environment of the people of Colorado n. p • �_� 4300 Cherry Creek Dr.S. Laboratory Building Denver,Colorado 80222-1530 4210 E.11th Avenue .. - Phone(303)692-2000 Denver,Colorado 80220-3716 (303)691-4700 . F Roy Romer Governor March 19, 1993 Patricia A.Nolan,MD,MPH Executive Director Bill Hedberg Waste Services Corporation 5660 Greenwood Plaza Blvd., Suite 400 Englewood, Colorado 80111 RE: Interim Disposal of Retention Pond Water Central Weld Landfill Weld County, Colorado Dear Mr. Hedberg: This letter is to inform you that the Hazardous Materials and Waste Management Division of the Colorado Department of Health(the Division) has reviewed an interoffice memo (enclosed), dated March 19, 1993, from Barbara Taylor of the Water Quality Control Division of the Colorado Department of Health (WQCD). The Division concurs with the contents of the memo from WQCD. The memo is intended as an interim measure only. Once conditions change such that the retention pond is not in jeopardy of overflowing discharge to the adjacent land will stop. Your application for a discharge permit is still under review by WQCD. If youhave any questions regarding this issue please contact myself or Barbara Taylor. Sincerely, Roger Doak Geologist Solid Waste Section Hazardous Materials and Waste Management Division enclosure cc: J. Pickle, Weld County Health Department A. Scheere, Waste Management of North America B. Taylor, CDH, WQCD Wintraintredidliteonost Weld County Planning File: SW/WLD/CEN/ 931061 Cu h t bt-f- V Date: March 19 , 1993 To: Glenn Mallory Roger Doak Solid Waste Management Division Colorado Department of Health Topic: Land Application of Retention Pond Water to approximately 40 Acres of Agricultural Land East of the Weld County Landfill The winter months of 1993 . have produced more than the average precipitation in Colorado. As a result of this activity, the retention pond on the eastern corner of the Weld County Landfill has approached overflow. The landfill operators have been attempting to handle the situation by spray-applying the water to the landfill . However, it has become apparent that another solution to the problem is required, especially since more precipitation is expected during the spring season. An alternative solution which has been proposed is to apply the water to approximately 40 acres of agricultural land to the east of the landfill . Colorado does not have established criteria and enforceable standards for waters used for irrigation. The water from the retention pond was tested as recently as November and December of 1992 . The water contained no volatile organics and otherwise is characteristic of the water found in the area, as shown by a groundwater study conducted by the Weld County Health Department during the summer of 1992 . To summarize: a) The water may be summarized as hard, that is, it is high in divalent cations such as calcium and magnesium and the associated anions, sulfate, carbonate, and bicarbonate. Water hardness, in itself, is not considered a health problem. Rather, it is an aesthetic problem and consequently is treated in large municipal systems. b) The water is high in nitrates, ranging from approximately 9 . 9 mg/1 to 15 . 9 mg/1 (as N) . c) The water is moderately high in sodium, ranging from 127 to 919 mg/l. 931061 Groundwater sampling in the area east of the landfill can be characterized similarly. The water has a total hardness ranging from 460 to 580 mg/1, sodium 140 to 180 mg/1, and sulfates as high as 380 mg/l. Studies done by the Civil Engineering Department at Colorado State University indicate that alfalfa is one of the more tolerant crops to nitrates, sulfates, and salt solutions. Current non- implementable standards for agriculture require nitrate levels less than 100mg/l. Salinity is a problem in Colorado, especially in the Arkansas River Basin; the levels which have caused problems, however, approach 3500 mg/l. In summary, after an extensive review of the agricultural waters presently being used in the Weld County area for agricultural application, the Division thinks that carefully-managed agricultural application of water from the retention pond to the alfalfa crops to the east of the landfill is appropriate in order to prevent overflow of the retention pond. A more complete review of the water is being done for discharge to the waters of the State. Barbara Taylor Environmental Engineer Page 2 931061 'I 3 cc: Trevor Juricek John Pickle Weld County Health 1517-16 Avenue Court Greeley, Colorado 80631 Ashton-Daniels Neighborhood Association Pat Nelson Bob Shukle 931061 V 4/ March 25. 1993 • -7 Mr. Dale Hall Weld County Commissioner Centennial Center 915 10th Street Greeley, Colorado 80631 Dear Mr. Webster, I read with great interest the March 22nd article in the Reporter-Herald concerning the Central Weld Landfill. In particular the comments of Sharon Schmidt about her well water. With some research, she would discover that the well water in that area has never been drinkable because of the hardness of the water. My father drilled our well in the late 1920's or early 1930's. The water was used for garden purposes and livestock. As a child growing up, you were in big trouble with Mother if you got the well water on the windows because it left spots on the window because of the hardness. Before water lines were run to the farmsteads, we had cisterns and we trucked our water to the farm. I remember Dan the Waterman who delivered to our farm. Before Dan the Waterman we had a water tank and would use the farm truck to haul water from Greeley. We never had the technical, chemical anaylsis of the water in those days but this we did know, we did not use it for household use. In modern times, we do not use the well water in automatic horse waterers because the mineral content clogs them. I think no taxpayer should be liable for homeowners use of distilled water as Sharon Schmidt states. I write to you because of my conern of so much information being given by the environmental groups that is unfounded. Yours truly, 4/1,2 02 7/7 931061 r. ca i. r ) w rtk, c-k), l c L 1 _ (jajeS ' (3% �j „cc • - LOUIS E. SPOMER OIL AND GAS PROPERTIES TELEPHONE 4055 SOUTH ONEIDA STREET AREA CODE (303) 757-1442 DENVER,COLORADO 80237 • March 24 , 1993 Weld County Commssioners Centennial Center 915 10th Street Greeley , Colorado 80631 Re: County Landfill Gentalmen, We shouldn ' t let a handful of people cause the County Commissioners to make another environmental mistake in the future of the Central Weld County Landfill , located east of Milliken . The first handful of people coused the Commissioners to allow the opening of the landfill in 1971 . The second handful of people are trying to force the Commissioners to prematurely close the Landfill . Itdoes not serve the community nor the enviroment by the radical actions proposed by these people . The damage caused by the first handful of people cannot be reversed by the second handfull of people ' s wishful thinking ! The fact is ; the landfill is there to stay ; active or inactive . The far sighted course, for the Commissioners to follow, to best serve the community and the enviroment , is to cooperate with the current operators of the landfill to insure an environmentally safe , normal closing of the landfill at the end of its useful cycle . Very Tru yours , ouis E. Spol� meY Concerned Landowner L k �b.C 4� X �� j. 9c7�61 5026 Redmond Road :• Cheyenne, Wyoming 82009 March 26, 1993 Greeley Tribune 501 8th Avenue Greeley, Colorado 80632 Dear Editor: I have been reading negative press releases about Central Weld Landfill . I don ' t like landfills either, but they are a necessary part of the American system. Our garbage-creating lifestyle is not going to go away overnight. The Central Weld Landfill has become a widely publicized issue. A well-organized opposition group has created sensational headlines , but there is more than one side to every story. My family objected to the landfill in 1971 when it was proposed, but their concerns were ignored and over-ridden. The damage was done long ago. Closing the landfill will not make it disappear. My family had plans to build on a site adjacent to the present land-fill boundary, but were forced to consider alternate home-building plans after 1971 . They regret their lack of foresight at that time, when they did not urge county officials to see that verbal pledges and agreements be put into a written contract to ensure future compliance with the "so-called-promises , " "mutually-agreed-upon-arrangements , " and Federal , state, and county regulations. Although my family did not want to see a landfill bordering their farm in 1971 , we cannot blame Waste Services-Waste Management for the negligence of others in the past. Waste Services/Waste Management is now working at solving many of the problems. Most of the less desirable aspects of the landfill , as with any landfill , really affect only the handful of neighboring land-owners. Thousands of other Weld County residents have not been heard from. Are they willing to pay higher garbage-collection fees to cover the added transportation costs to other sites , give up the convenience of quick Saturday trips to Central Weld Landfill, or pay the added taxes to repair increased miles of highway wear and tear? Fxh b, y ec: rive ste.sve, <7-0 931061 Page 2 March 26 , 1993 I think it is time to look at the overall picture and weigh both sides of the issue. If the Central Weld Landfill is closed, the hidden costs to all of Weld County's citizens will far outweigh any negative aspects that mainly involve the handful of adjacent landowners . Yours truly, 7"4.1,-1041(eiltatec Michael Hayes (307) 632-2908 cc: 4215nnie Harbert-Chairwoman, Weld County Commissioners John Pickle, Weld County Department of Health Randolph L. Gordon, M.D. , M. P.H. , Director, Weld County Health Department Lee Morrison, Weld County Assistant Attorney Chuck Cunliffe , Weld County Planning Department Roger Doak, Colorado Department of Health Patricia Nolan, M.D. , Executive Director, Colorado Department of Health Barbara Taylor, Water Quality Control Division, Colorado Department of Health Johnstown Breeze Loveland Daily Reporter-Herald / 931061 . March 26 , 1993 Greeley Tribune 501 8th Avenue Greeley, Colorado 80632 Dear Editor : Wouldn' t it be great if Weld County citizens could reuse all their garbage or if there were some magic button they could push to make it useful again over night? The fact is , Weld County cannot afford to sit around and wait for such dreams to come true . No one likes living with landfills , but we can' t do without them. The trash is here . ' The trash will not disappear. We must deal with it. We cannot become part of the NIMBY (Not- in-my-backyard) crowd. The Telep/Daniels group crusading to close the Central Weld Landfill has concentrated on environmental concerns . They have accumulated a file of information, but much is focused on sensational , isolated facts and figures. So many partial truths and rumors have been circulated, it has become a circus. The Action Group has accomplished their stated goals including: to be granted a public hearing to have an opportunity to be heard and to have testing of groundwater and wells surrounding the CWL. They also state "Frankly the types of remediation are fairly simple: The contaminants can be captured and then pumped to a treatment area and then released or the contaminants can be dug up and removed from the landfill . " Now isn' t it time to allow the professionals to do their part? Let us give Waste Services/Waste Management time to finish the job they have already started and have committed thousands of dollars more for continued remediation. If you are ill , do you listen to the opinions of family and friends and stop there, or do you seek the advice of your doctor and specialists? Is Weld County going to base such a wide reaching decision as the fate of Central Weld Landfill on what a group of homemakers , lawyers, pilots , and other novices say, or will the county listen to professionals and specialists in the business - Waste Services/Waste Management, Colorado Department of Health specialists, and Weld County Health Department personel? 931061 Eht13N-- . uDa so-es (-1/40 March 26 , 1993 Page 2 I join my family in wanting to see an intelligent decision reached regarding the Central Weld Landfill adjoining our Spomer family farm. Please don' t let emotional frenzy and political pressure alone determine the outcome. Your try y. c Katherine S. Haig_ (307) 326-5873 CC : .4onnie Harbert-Chairwoman, Weld County Commissioners John Pickle , Weld County Department of Health Randolph L. Gordon, M.D. , M.P.H. , Director, Weld County Health Department Lee Morrison, Weld County Assistant Attorney Chuck Cunliffe, Weld County Planning Department Roger Doak , Colorado Department of Health Patricia Nolan, M.D. , Executive Director, Colorado Department of Health Barbara Taylor , Water Quality Control Division, Colorado Department of Health 931961 TARCO, INC. EARTHMOVING CONTRACTOR GENERAL CONTRACTOR 4781 'West 5$tfi'A&e'nue Arvada, Colorado 80002-7009 (303) 409-2221 • FAX (303) 429-0051 March 29, 1993 Board of Weld County Commissioners 915 Tenth St. P.O. Box 758 Greeley, CO 80632 RE: Central Weld Sanitary Landfill To Whom It May Concern: TARCO, Inc. , has projects from time to time, in the Weld/Larimer County areas, and we have a necessity to dispose of construction debris. The Central Weld Sanitary Landfill is centrally located and we would hope that the Board of County Commissioners would grant the right to Waste Services Corporation to continue to operate the Central Weld Sanitary Landfill. Sincerely, 4t its. Victor C. Thomas Chairman of the Board VT/ily 931061 P.O. BOX 1047 • ARVADA, COLORADO 80001-1047 An Equal Opportunity Employer 1 ( March 29, 1993 19 Mr. John Pickle Department of Health 1517 - 16 Avenue Court Greeley, Colorado 80631 Dear Mr. Pickle, We are directing this letter to you because we understand the hearing process will heavily rely on information provided by yourself, supported by State Health agencies. Your recommendations and those of the other health officials will probably decide the fate of the CWSL continued operation. We feel confident the health agencies' expert testimony will not fall victim to radical elements in their recommendations as to the future of the Central Weld County Sanitary Landfill. We went to see Mrs. Daniels recently to hear her views and to express our views and concerns. We found this to be an exercise in futility. With her mind set, everything we tried to discuss was impossible. As she will now say that our land sale has bought us off, she was saying then that the health officials, County and State have been bought off by Waste Services/Waste Management. Mrs. Daniels should open her prespective and realize we are fortunate to have Waste Services/Waste Management to run the landfill. Our position: 1. We consulted an independent environmental engineering company. They recommend Waste Services/Waste Management continued operation is the best for our property and the environment. They have written to the County Commissioners regarding their findings. 2. Having Waste Services/Waste Management there with a financial incentive to correct whatever pollution problems we might have will prove more expedient than shutting them down. 3. We also feel and have been advised that the question about the continued use of the landfill until the end of its useful cycle is the only 931061 Ey/AA.b� B" cc . �Jfil SL'C : tL, A/c_ y1/4 v.A JO` c. SKELTON & ASSOCIATES, " IC. ENvIRONMENTAL CONSULTING 861 Stove Prairie Road • Bellvue, CO 80512 • Pb.or FAX(303)42-0113n f March 29, 1993 Weld County Commissioners Centennial Center 915 10th Street Greeley, CO 80631 Re: Landfill in Weld County Operated by Waste Management Corporation Gentlemen: I have been requested by a group of concerned citizens and landowners to look at the current landfill operated by Waste Management in Weld County. There are a number of factors to be reviewed concerning the ongoing operation of any landfill including but not limited to the following: o Past operating practices. o Present operating practices. o Present Management technical, environmental and standards of practice knowledge. o Financial strengths of owner. o Present Management commitment to complying with environmental regulations, recognized standards of practice to minimize potential environmental contamination and working with local population to meet community standards. o Potential of future environmental contamination. It is my understanding that Waste Management took over the operations of this landfill some years after its opening. The original operators were generally underfinanced and may not have always operate the landfill in accordance with recognized standards of practice and environmental regulations. Having practiced environmental consulting engineering for the last 20 years, specializing in waste management, throughout the U.S. , I have a very good knowledge of the waste management industry. Waste Management operates facilities in many parts of the country. They are very well thought of in the industry. They have very knowledgeable personnel in both standards of operating landfills and in complying with environmental regulations. They have shown a commitment to operating their facilities in an environmentally sound manner. They have the financial stability to Weld County 931 96t h'i stCC; 0c: ,• t tY ccs, / , C yt,-,fr Commissioners March 29, 1993 Page 2 address operations as well as controlling potential contamination concerns. Waste Management has also shown a willingness to work with communities to address their concerns. It has been my experience that when a landfill that has environmental problems from past operations is taken over by an experienced, well financed company, the remediation of the site while still in operation is handled in a very professional manner. This is accomplished because the company accepted the condition of the site in its economic evaluation prior to taking over the site. Should the site be closed prior to reaching its design capacity, a number of problems will be present. The waste presently being sent to the site will have to be sent elsewhere, at a much higher cost. A new site will have to be developed that may very well develop the same problems as this facility is experiencing. A significant delay will occur in finding a suitable site, locating a qualified operator and permitting a site. A site should not be closed simply because of the "NIMBY" (not in my back yard) syndrome. A site should be required to be operated in compliance with the regulations and by a company with the resources to perform the work. Waste Management Corporation has the technical and financial resources to accomplish these requirements. I would encourage you to work with this firm to solve the problems at the site and not to just close the site. Very truly yours, Joe F. Skelton & ssoocciiates, Inc. /Joe F. elton, Ph.D. , P.E. fr'Presi t JOE F. SKELTON & ASSOCIATES, INC. CG 931061 ROCK. MOUNTAIN LAZY BAR S itANCH (303) 482-2719 March 26, 1993 € . 9 Weld County Commissioners Connie Harbert, Chairwoman Centennial Center 915 10th Street Greeley, Colorado 80631 Dear Commissioners: Ref: Who really wants to see the Central Weld Sanitary Landfill closed? The silent majority is unfortunately just that, SILENT, The trouble makers and radicals seem to always receive attention and press coverage. Within approximately 2 miles of the landfill, something like 27 people who live or have property interest are AGAINST CLOSING THE LANDFILL. The local community sentiments seem to be, it is better to have a properly operated landfill, run by financially and professionally qualified people than to have a half used landfill, forcing those who legally dump trash to travel much, much further to do so and having trash dumped along our county roads by others. Remember when listening to the small number of radical protesters, it is in vogue for people to sign petitions against landfills, and against big business regardless if it is in the best interest of the county or environment. Please cooperate with Waste Services/Waste Management to properly close the landfill at the end of the normal cycle. Very truly yours, i Jo . Stephens Rocky Mountain Lazy J-S Ranch ner Mailing Address: Scaffold Gulch Ranch Other Locations: QQCC 1406 Stove Prairie Road 23673 Weld County Road 27'/2 3756 West C6 661 Bellvue, Colorado 80512 Milliken, Colorado 80543 Loveland, Colorado 80537 �K h-L bti J D.D e, , 1 March 29, 1993 Weld County Commissioners Centennial Center 915 10th Street Greeley, Colorado 80631 Dear Commissioners: Again, as the landowners of the property directly south and west of the Central Weld Sanitary Landifll , we again write to you. After reading further newspaper releases by the Telep/Daniels Group and dealing with their activities on our property, we have done the following to become better informed of the true reality of the landfill situation. 1. We have contacted State Health Department individuals as to the state of the pollution especially concerning the Spomer lakes. 2. We have contacted a private environmental consultant. 3. We have held meetings with personnel of the Waste Services/Waste Management as to their plans for operating and properly closing the landfill. 4. We have received information on operations of Waste Services/Waste Management in other areas of the United States. Again our position is this, Waste Services/Waste Management did not create the problems addressed by the Telep/Daniels group nor those issues brought forward by the County and State. It is our position : 1. that Waste Services/Waste Management is the best answer to solve the above issues. We believe Waste Services/Waste Management is acting in good faith to correct these issues. 2. that the landfill has never been so well operated than under Waste Services/Waste Management and that they are the first operator to have both the financial and professional expertise to correct the areas of concern of the State and County. �2�1�cfEE « /-77 s-cs 931061 3. that as a national company, Waste Services/Waste Management has a reputation to maintain with its share holders and the general public and are striving to be on the cutting edge of latest advancements of landfill techniques. Having a mega-million dollar company operating the landfill to us is an asset not a detriment as the Telep/Daniels group implies. 4. that it is better to have the Central Weld Sanitary Landfill being actively operated than inactive with minimum attention being given to past problems. S. that it serves no purpose to close the landfill before it is filled. The damage has already been done and with new State and Federal regulations and new advancements in landfill methods further damage should not happen. With the County and State Agencies and Waste Services/Waste Management all cooperating together, the Central Weld Sanitary landfill can become a state-of-the-art landfill serving the citizens of Central Weld County and the environment. Yours truly, 45,7a.tj Ella Marie Spomer Hayes Susanne Spomer Stephens ( oy) 302C - S's?,/ cif2 - 7/7 EL 931061 ca,, 5 ADVOCATES FOR CONTINUED OPERATION OF CENTRAL WELD SANITARY LANDFILL APRIL 5 , 1993 PREPARED FOR WELD COUNTY BOARD OF COUNTY COMMISSIONERS 931061 r �'X: 4I RUT f1 i JOE F. SKELTON & ASSOCIAI ES, NC, EN RONMENTAL CONSULT G 861 Stove Prairie Road • Bellvue,CO 80512 • Ph, or FAX(303)482-0113 March 29, 1993 Weld County Commissioners Centennial Center 915 10th Street Greeley, CO 80631 Re: Landfill in Weld County Operated by Waste Management Corporation Gentlemen: I have been requested by a group of concerned citizens and landowners to look at the current landfill operated by Waste Management in Weld County. There are a number of factors to be reviewed concerning the ongoing operation of any landfill including but not limited to the following: o Past operating practices. o Present operating practices. o Present Management technical, environmental and standards of practice knowledge. o Financial strengths of owner. o Present Management commitment to complying with environmental regulations, recognized standards of practice to minimize potential environmental contamination and working with local population to meet community standards. o Potential of future environmental contamination. It is my understanding that Waste Management took over the operations of this landfill some years after its opening. The original operators were generally underfinanced and may not have always operate the landfill in accordance with recognized standards of practice and environmental regulations. Having practiced environmental consulting engineering for the last 20 years, specializing in waste management, throughout the U.S. , I have a very good knowledge of the waste management industry. Waste Management operates facilities in many parts of the country. They are very well thought of in the industry. They have very knowledgeable personnel in both standards of operating landfills and in complying with environmental regulations. They have shown a commitment to operating their facilities in an environmentally sound manner. They have the financial stability to Weld County 931[)61 Commissioners March 29, 1993 Page 2 address operations as well as controlling potential contamination concerns. Waste Management has also shown a willingness to work with communities to address their concerns. It has been my experience that when a landfill that has environmental problems from past operations is taken over by an experienced, well financed company, the remediation of the site while still in operation is handled in a very professional manner. This is accomplished because the company accepted the condition of the site in its economic evaluation prior to taking over the site. Should the site be closed prior to reaching its design capacity, a number of problems will be present. The waste presently being sent to the site will have to be sent elsewhere, at a much higher cost. A new site will have to be developed that may very well develop the same problems as this facility is experiencing. A significant delay will occur in finding a suitable site, locating a qualified operator and permitting a site. A site should not be closed simply because of the "NIMBY" (not in my back yard) syndrome. A site should be required to be operated in compliance with the regulations and by a company with the resources to perform the work. Waste Management Corporation has the technical and financial resources to accomplish these requirements. I would encourage you to work with this firm to solve the problems at the site and not to just close the site. Very truly yours, Joe Fy Skelton/& Associates, Inc. / /Joe . Skel on, Ph.D. , P.E. /President JOE F. SKELTON & ASSOCIATES, INC. 931061 Fp Subject: CENTRAL WELD COUNTY SANITARY LANDFILL. The following is a list of 35 residents and people with vested interest in land within approximately 2 1/2 miles of the CWSL. This list comprises those who do not oppose the continued operation of the CWSL until the end of a reasonable life cycle as long as the operation adheres to all pollution control measures. Louis Spomer Jan Spomer Steve Spomer Julie Spomer Larry Kammerzell Florence Kammerzell Steve Hayes Bev Hayes Mike Hayes Sherry Hayes David Hayes Sloane Stephens Kathy Hall Randy Hall Vern Kammerzell Carolyn Kammerzell Julie Kammerzell Doug Kammerzell Melodie Kammerzell Keith Kammerzell Steve Kammerzell Jennifer Kammerzell Ella Marie Hayes Van Hayes Art Garcia Alicia Garcia Susanne Stephens Jon Stephens Dee Belo Chris Dubbs Gene Kammerzell Jan Kammerzell Carol Prewitt Jeff Prewitt Lisa Bell NOTE: Because of people's work commitments very little time was available to tell the "other side of the story". What motivated us to prepare this package was the disinformation, disregard for other peoples property and sensationalism and radical actions by the Telep-Daniels group. You can see 35 residents and landowners within approximately 2 1/2 miles of CWSL favor the continued operation of the landfill. We urge you again not to be mislead by a small group of neighbors and possibly outsiders opposing the landfill. The list could be longer if time allowed. The above are the ones we had time to contact. 9;31061 1 / yo {` iII Ii r(1 �l t \ ` �\• J � I -,,s- x 0090 / / qo I � �_ INN II , I . i, \ AA�� / go J y '\) ? ..., 4.9; \C-\ -- :...‘ \:-\..‘ \0 I': \ \ 9-3 ; --- _ _ -' ; ,,\--\ i\_. - (-----i I r ,, , - - _, 1 \ ) \,,,,\)) (c-c-)k \ t r---- ' / >g,,, Y\ ---) I I% 1 �� -:55 ��I�( Vim, I •�-�� \V ' ,. i .. �� 1„y ) h\ ) 1 L ‘ h-,\ C il: Li - 1 I 2' - h rq 2 .. Q / -h C y C h ' ( -2) \K - i' h 1'06 h/ ' .d'i )) ,\t ° : : ,‘\')--(di \h r , i(t.\\2 s7ao 0 \ ,)22,2?:2\2,2.:/2,22,-2\22\-E 2 2 2 22 2_ im 2 71 )J K\ II` h, If( a , I\\ \1 I 1\✓ J \ ' f \I ( Nh,l�l 11► h * c Ng JP �\ a ` t` <`�'�( ` 11 l` 111�i Qs ‘,20 a% ; ic,4, i _ �v, �� \ a,., L ,�!I 1k 111. .. o (� .ti Ij �� .4,'. 4 \ScK \ll " 4so ' \ - �' // i 6s$ II cI / 4 Adh i�REA� �i �� f a o�. r -Pah//` >no �' ( I v i oo /9 i I r '� V e win �� G\- I 2- ! ��_ 426 o / -04 _ y � .�;. II I ,� �A A DITCH !, Se � 4n5 °/� f , ,-- i„Uam• s .eN6 4.-2 4728 .•' )1p10� 'Q i % .�l i ♦130 I J- ii o �� SONe. �I,• o � f/ \ n 41,, s fig 153 6 • 4161 u /)7( __ i a>]5 • 4J31 hr U r Ali Ni q� 9 ( 4)09 1 6� March 31, 1993 Weld County Commissioners Connie Harbert Centennial Center 915 10th Street Greeley, CO. 80631 Dear Mrs. Harbert, I would like to point out at least one totally inaccurate statement in C-COW's flyer distributed in the area last Sunday soliciting support to close the landfill near our farm. In the third paragraph, second sentence it states that local farmers agreed to the siting of the dump. C-COW knows this is an untruth! Local farmers never agreed nor had any say except to object to the landfill. C-COW knows this. Our concern is the degree of dis-information they are distributing to yourselves and the community. This does give rise to what appears to be a credibility gap on the part of C- COW's position in this matter. Yours truly, Susanne Spomer Stephens 931061 HAVE A C—L._.d! ! BE CONCERNED! ! GREEELEY—N.a..LIKEN LANDFILL 0 Coloradans - Concerned Over Water (C-W.4) is a gza.ip of croterrned H Colorado citizens who demand action by their elected representatives to a) rn protect public health and the environment. The Greeley-Milliken landfill is located in a )C,JOR DRAMA= AREA, 1/2 'b b'#' 0 mile from the Big Thompson River and 1 1/2 miles from the South Platte River .p where the two rivers meet at Dos Rios. g M 'H >10 *A M IN 1971, the Evans dump had reached capacity and the Greeley-Milliken 3 x p,•n landfill was proposed. Local farmers agreed to siting of the dump because they were promised it would be only an DIltUM DUMP, AND WM= CLOSE NOT LATER THAN 1986, when a new site would be in operation. TODAY, 21 YEARS LATER, the Greeley-Milliken dump is still in operation, CZtATJc IAIEZR EACH DAY! The landfill continues, and threatens to EXPAND, even though a large, lined and buffered facility in dry lands is located near Ault and another is planned near Keensburg. The Greeley-Milliken lardfil is UNREZULATED BY C!RIENT STANDAR • Be- cause it was established prior to the adoption of federal RCRA laws and prior to the adoption of current state regulations, the owners/operators have NEVER FILED AN ENGINEERING AND OPERATIONS DESIGN PLAN. The landfill has not been REQUIRED TO COMPLY WITH CURRENT SOLID WASTE DISPOSAL LAWS! When the landfill was begun, it was dug BELOW THE GRCUINDWA'I2.3i, was UNLINED, and TRASH WAS D MPC INTO STANDING WATER, all in a major drainage area 1/2 mile from the Big Thmpson River. RED, EVEN HWSD{OLD WASTES SUCH AS PAINT CANS, SOWESTS, CLEANERS AND GARD,N PWIICSD= CAN ENDANGER GROUND AND SURFACE WATTR IF PLACED IN UNLINED ramps! The Greeley. ,Milliken dump has holding ponds on site, which collect water. It also his deep, dangerous trenches to divert groundwater and surface 'run-off. — _ CONTAMINATION FRCM HEAVY )TTALS is being detected in neighboring irrigation-holding lakes. The hearrates of these lakes are opened, the water leaves the lakes, goes into the irrigation ditches, finds its way through gravel beds and sloughs and INFO T:i` BIG THCFSSON AND THEN INTO THE SOULS! ran. IF THIS DUMP COTIlNU= TO GO UNNOTICED, contamination of Colorado's surface and ground water will result. The state Dapartmnnt of Health, thzou3h its Solid and Hazardous Waste Division and the Division of Water Quality MUST' BE URGED TO INVESTIGATE THE SWRZE OF THIS C]NTAMTZRTION1 PUBLIC ATITNTION AND PUBLIC HEARLt7GS must foals on this facility so that it is closed and any resulting contamination is treated. f 931061 7 P . O. Box 773 Saratoga, Wyoming 82331 307-326-8874 Dear Editor, Over the past few weeks I have watched with interest as charges , counter charges , truths , half truths , innuendos , etc . have been presented through the news media by various individuals and groups regarding the present move to permanently close the Central Weld Sanitary Landfill operated by Waste Services Corporation. My wife and her sister are the owners of the Spomer farm which entirely borders the CWSL on the south and the west. Our family' s lands and waters are the ones most directly affected by any past, present or future pollution, erosion and other real or imagined environmental damage . In a letter to the editor, published in the Johnstown Breeze, Mr . Harold Daniels recently raised a question relative to this "garbage mountain" when completed and capped and continued on with a scenario of an inch of rain, three million gallons of runoff , wind and water erosion, garbage exposure and so on. Real scary, but a largely sensation- alized and extremely remote possibility. I think the cartoon of Mt. CWSL paid for by CCOW and accompanying this article bears out this sensationalism. Exaggeration seems to be the name of the game . The stories we heard as kids comes to mind -Chicken Little and The Sky is Falling and The Boy Who Cried Wolf . Yes , these things could happen, but the possibility with today ' s knowledge and technology reduces the incidence of these types of happenings to the minimum. Seedings can be successful on steep slopes and under arid conditions . The development of netting, slurry mix seeding and mulching, and residue incorporation are a few of the methods successfully used on steep slopes and dry areas where rainfall is in the 5-9" range and winds are extreme. Yes , Mother Nature needs to help, but the incidence of success has been good in harsh environmental areas and we are continually developing new techniques . Mixtures utilizing adaptable native seed from plants and grasses found and presently growing under like conditions are also available . As a retired professional conservationist of more than 30 years with the U. S . Soil Conservation Service , I have helped plan and apply these types of measures to the land. / /- 931061 cf) Early last week my wife and I made a tour of the landfill so we might be better informed as to the operation. We were impressed with the lack of visible refuse. The dump area being used on that particular day was smaller in over all size than I have seen exposed in my community's landfill , town size 3 , 000 plus or minus. Much of the area was relatively level but undulating. Some of the area has vegetative growth on it where it has been seeded. This in itself would tend to dispel the myth that "no vegetation could survive . " • Colorado law requires , at this time, only a two foot cover on closing a landfill . Waste Service 's standard practice is to cover with two feet of compacted clay with an additional six inches of topsoil , into which they seed a pasture mix. The soil is protected from wind and water erosion by a straw mulch until enough growth is obtained to protect and hold the soil in place . In addition, they build in a slope to reduce standing water infiltration to a minimum. In my professional opinion this is the way to go and is several steps beyond what the law requires . At the present time there are several areas within the landfill that are not at the target level as I understood it twenty plus years ago. To successfully complete and cap the landfill these would need to be filled and then an additional amount of fill would be needed to build a slope before final capping and seeding. We do not feel that allowing the Central Weld Sanitary Landfill to continue operation will cause any more harm to our land and water than has already occurred over the past twenty years . We also feel that by working with Waste Servicrs over the past several months , and by not taking an a!lversr_i.al position, we have a much greater chance of taking care of any existing or future problems that may develop. Waste Services is providing a needed and vital service to the community. Are we going to allow a small vocal group to make a decision for the rest of us that is based on what I said at the start of this letter, charges , counter charges , truths , half truths , innuendos , and now this last Sunday, outright scare tactics? Sincerely, 7 /141 Van Hayes �� / 931061 k7 LETTER TO THE EDITOR Not Needed, Not in Compliance, Not Safe , and Not Wanted! This is what a small number of people calling themselves the Ashton-Daniels Community Action Group have concluded about the Weld Central Landfill between Milliken and Greeley. Action Group spokesman Michael Hays claims, Waste Management the landfill owner and operator is nothing more than 'GREEDY. ' Harold Daniels , group member, predicts a seventy-five foot mountain of trash being eroded by the elements. They and their followers have gone on a crusade to close the landfill. . . TODAY! In doing so, this group has twisted facts out of proportion, sensationalised the situation, misrepresented the views of the entire community, and misled the public . From just below the landfill at the Spomer Stables come some real facts and another opinion. Fact #1 . Waste Management purchased the Weld Central Landfill in 1991, twenty years after the landfills inception. Fact #2. Waste Management has spent in the realm of $3/4 Million to analyze to what extent the landfill is effecting our environment. Fact #3. Waste Management has already committed $1/2 Million to the process of correcting problems at the landfill they inherited. 'WAKE UP' Ashton-Daniels Community Action Group! IS THAT GREED? Whose trash are we dealing with anyway? It's yours and mine. Now we have a 'Corporate Giant' with its checkbook out, willing to cleanup what was created twenty years ago and you're trying to run them off. I use the landfill as do most of you. So do many others in this area of Weld County. Our option if this landfill is closed and we choose not to dump our trash along fields and roads is at best twenty-five miles away. This landfill is 'convenient' and it is 'needed' ! 'Not Wanted' . . .I 'll give this one to the Ashton-Daniels Group. I prefer not living next to a landfill. Yellowstone Park would be much better. Fact is, twenty some years ago when this landfill site was chosen, our predecessors weren't able to thwart off the chosing of this site. .Our lawyer was all but ignored. Harold and Madoline Daniels weren' t even present. Guy Shable offered to trade this wet site for dryland and was shrugged off. Even our County Attorney, Sam Telep, Michael Hays ' Father-in-Law, whose family owns land north of the site chose to hide behind the old 'Conflict of Interest' cliche. Fact is, everyone complaining now should have / / 9431061 / cc complained then. Fact is, we have a landfill. As for 'Not Safe' and 'Not in Compliance ' , Waste Management has committed its manpower, equipment, and capital to achieve these goals. By October 1993, Waste Management has to be in compliance with the new, strict, Subtitle D Regulations and has to clean our environment and keep it clean if they plan to operate at this site. This landfill is one of the cleanest landfills I have seen and is professionally managed. This site if closed properly, will not be a seventy-five foot mountain of eroding trash, but rolling hills, thirty to fourty feet at the drest, seeded with dryland grasses and designed to shed water off the site and not soak into the ground water through the trash. My goal, as should be the entire community, is work with, not fight with Waste Management to insure the future . Awareness is only a stepping stone in the process. The Ashton-Daniels Group has accomplished awareness. Now its time to support Waste Management's efforts and accomplish the goal to clean our environment and eventually close the landfill properly and sensably after its useful lifespan. David Hayes Spomer Stables / 931061 f" /7 Letter to the Editor Now for a more logical look at the Central Weld Sanitary Landfill situation.The most logical solution is for Waste Management to guide the landfill in its completion. That company has the experience and the capability to manage the landfill in a professional manner that will realize the landfill's full potential and not curtail the effort begun in 1971. The landfill was supposed to close earlier but that would be a wasteful action as its filling is not yet complete. Another landfill would just have to be created somewhere as the alternative to the Alt and Keensburg's dumps as they fill up faster with Weld County's added trash. The pro-environment decision is to utilize one developed landfill before wasting more land on others in the future. An added incentive is that the landfill is now in more capable hands. Yes, writing as a neighbor of the landfill, its never having been begun would be the ideal situation but it is now a reality due to the previous decisions of the county commissioners and open knowledge of the public. An irrational treatment of the landfill would be its immediate closing. Superfund will not whisk in with a magic wand to clean up the landfill. Superfund only deals with toxic waste clean up. The landfill does not have this required element according to a member of Superfund which is probably much to the chagrin of the anti-landfill contingent since that makes their puerile muck. graveyard, that they have set up in protest of the landfill, null and void. Members of the anti-landfill group also lack a consistency in their beliefs. One of the most vocal of this anti-landfill group is a man who served as the county attorney when the original deal was approved. He gave his full support at that time as a county officer and as a neighbor to the dump. Now, apparently • because of some hidden agenda, he has had a change of heart. This rather radical contingent professes to be on the side of the environment and has gained some support by means of a petition against the landfill. This is a noble cause but not when the try masks the facts behind the situation. Anyone should be willing to sign a petition in support of their environment but those signers should make themselves aware of what effects the closing would have on other neighborhoods as they become potential landfill sites as well the premature filling of the Alt and Keansburg landfills. The only rational option in this situation is to allow Waste Management to guide the landfill in its completion and for the radical, irrational contingent to lay their vacant dead to rest. Sloane Stephens Concerned, Next Generation Land•Owner 1406 Stove Prairie Rd Belivue Co 80512 (303) 482-2719 931061 is fi „_i ri F.2/R March 29, 1993 200 Oakridge Trail Kennedale, TX 76060 Weld County/Board of County Commissioners Centennial Center 915 10th Street Greeley, CO 80631 Dear Commissioners: This letter is in reference to my position on the disposition of Central Weld County landfill. I feel justified in expressing my position for the landfill's continued operation due to my strong ties to the area, and the four generations of my family that have called the Spomer farm home. This property is immediately adjacent to the landfill. Unlike many of the activist campaigning to close the landfill whose experience with the facility spans weeks or even months, I and my family have lived in intimate contact with the landfill from its inception approximately 21 years ago. The recent change in the landfill management to Waste Management Inc. should be viewed as a very positive event for Weld County and the landfill by all parties. My personal experience with Waste Management at the local government level have shown the company to be extremely professional in dealing with the environmental,technical and public issues associated with the management and disposal of solid waste. Waste Management has recently been awarded the local garbage hauling contract, have, completed fabricating a recycling center for curbside programs and have provided a significant contribution towards public education in this area. The presence of a landfill in close proximity to one's home is never a positive thing. However, separating the emotional from the factual issues is essential when making decisions effecting the future of this and similar landfills. Rational, responsible citizens must acknowledge that • Landfills are a fact of life. • No one wants a landfill close to their home. • Properly managed landfills provide the most economical solution to our solid waste disposal needs. • Locating landfills as close to the waste source reduces cost (transportation, labor and road maintenance) • The Central Weld County landfill is currently in operation, continued operation will not create a new monetary hardship on area properties (property values will not be affected). • Ground water pollution associated with the landfill will not disappear if the landfill were closed. 931061 /. P.3/3 • Waste Management Inc. has the expertise and resources not only to control future pollution, but to improve the environmental damage leftover from previous landfill operators. I have confidence that sound judgement will prevail when you, the Commissioners of Weld County must differentiate between reality and fantasy, and facts and emotions and that the taxpayers of Weld County will be provided the opportunity to enjoy the advantages of a professionally operated, economical source for solid waste disposal. Respectfully, V;2 Steven V. Hayes 931061 March 29, 1993 Mr. John Pickle Department of Health 1517 - 16 Avenue Court Greeley, Colorado 80631 Dear Mr. Pickle, We are directing this letter to you because we understand the hearing process will heavily rely on information provided by yourself, supported by State Health agencies. Your recommendations and those of the other health officials will probably decide the fate of the CWSL continued operation. We feel confident the health agencies' expert testimony will not fall victim to radical elements in their recommendations as to the future of the Central Weld County Sanitary Landfill. We went to see Mrs. Daniels recently to hear her views and to express our views and concerns. We found this to be an exercise in futility. With her mind set, everything we tried to discuss was impossible. As she will now say that our land sale has bought us off, she was saying then that the health officials, County and State have been bought off by Waste Services/Waste Management. Mrs. Daniels should open her prespective and realize we are fortunate to have Waste Services/Waste Management to run the landfill. Our position: 1. We consulted an independent environmental engineering company. They recommend Waste Services/Waste Management continued operation is the best for our property and the environment. They have written to the County Commissioners regarding their findings. 2. Having Waste Services/Waste Management there with a financial incentive to correct whatever pollution problems we might have will prove more expedient than shutting them down. 3. We also feel and have been advised that the question about the continued use of the landfill until the end of its useful cycle is the only 931061 / /= i5" intelligent and rational use of an asset. The damage has already been done. Closing it now is not a practical answer to the problem. 4. Waste Services/Waste Management has the financial and technical capabilities to address the problems as they arise concerning pollution problems. 5. Yes, we have entered into a contract to sell Waste Services/Waste Management a ribbon buffer around the landfill. Contrary to Mrs. Daniels contention this is NOT the "missing link", money was not our major consideration. Past landfill operators dumped waste right up to their fence line which now does not allow room to correct current pollution and drainage problems. We already allow them to drill test holes on our property in the spirit of cooperation. It is important to us is to see an atmosphere of cooperation develop among all of us involved to insure everything is done to identify and clean up all contamination between now and when the landfill's capacity is reached and closed. 6. The fact remains that we will continue to be landowners with one mile of a common property line with the landfill. We will remain concerned neighbors. Mrs. Daniels fails to understand that we did not sell out, move out and give up ownership of a farm that remains the most impacted by the CWSL. We strongly urge you to not fall victim to this radical group. Within 2 to 3 miles of the landfill, the majority of the residents and landowners do not oppose the continued operation of the landfill until the end of its useful cycle. Yours truly, . 4,14 inevui 441" "larna' 1414n-`—i Ella Marie Spomer Hayes Susanne Spomer Stephens CC: Patrica Nolan, M.D. Executive Director, Colorado Department of Health Weld County Commissioners Lee Morrison, Weld County Assistant County Attorney Randolph L. Gordon, M.D., M.P.H., Director, Weld County Health Dept. Chuck Cunliffe, Weld County Planning Department Roger Doak, Colorado Department of Health Barbara Taylor, Water Quality Control Division, Colorado Dept. of Health Joyce Williams, Colorado Department of Health 931061 70 March 29, 1993 Weld County Commissioners Centennial Center 915 10th Street Greeley, Colorado 80631 Dear Commissioners: Again, as the landowners of the property directly south and west of the Central Weld Sanitary Landifil , we again write to you. After reading further newspaper releases by the Telep/Daniels Group and dealing with their activities on our property, we have done the following to become better informed of the true reality of the landfill situation. 1. We have contacted State Health Department individuals as to the state of the pollution especially concerning the Spomer lakes. 2. We have contacted a private environmental consultant. 3. We have held meetings with personnel of the Waste Services/Waste Management as to their plans for operating and properly closing the landfill. 4. We have received information on operations of Waste Services/Waste Management in other areas of the United States. Again our position is this, Waste Services/Waste Management did not create the problems addressed by the Telep/Daniels group nor those issues brought forward by the County and State. It is our position : 1. that Waste Services/Waste Management is the best answer to solve the above issues. We believe Waste Services/Waste Management is acting in good faith to correct these issues. 2. that the landfill has never been so well operated than under Waste Services/Waste Management and that they are the first operator to have both the financial and professional expertise to correct the areas of concern of the State and County. / 931061 931061 /7 3. that as a national company, Waste Services/Waste Management has a reputation to maintain with its share holders and the general public and are striving to be on the cutting edge of latest advancements of landfill techniques. Having a mega-million dollar company operating the landfill to us is an asset not a detriment as the Telep/Daniels group implies. 4. that it is better to have the Central Weld Sanitary Landfill being actively operated than inactive with minimum attention being given to past problems. 5. that it serves no purpose to close the landfill before it is filled. The damage has already been done and with new State and Federal regulations and new advancements in landfill methods further damage should not happen. With the County and State Agencies and Waste Services/Waste Management all cooperating together, the Central Weld Sanitary landfill can become a state-of-the-art landfill serving the citizens of Central Weld County and the environment. Yours truly, Ella Marie Spomer Hayes Susanne Spomer Stephens (, 'v >) 326 - S' 7/ yr2 - .27/7 931061 / 7 ROC""MOUNTAIN LAZY '- BAR c 'ANCH (303) 482-2719 March 26, 1993 Weld County Commissioners Connie Harbert, Chairwoman Centennial Center 915 10th Street Greeley, Colorado 80631 Dear Commissioners: Ref: Who really wants to see the Central Weld Sanitary Landfill closed? The silent majority is unfortunately just that, SILENT, The trouble makers and radicals seem to always receive attention and press coverage. Within approximately 2 miles of the landfill, something like 27 people who live or have property interest are AGAINST CLOSING THE LANDFILL. The local community sentiments seem to be, it is better to have a properly operated landfill, run by financially and professionally qualified people than to have a half used landfill, forcing those who legally dump trash to travel much, much further to do so and having trash dumped along our county roads by others. Remember when listening to the small number of radical protesters, it is in vogue for people to sign petitions against landfills, and against big business regardless if it is in the best interest of the county or environment. Please cooperate with Waste Services/Waste Management to properly dose the landfill at the end of the normal cycle. Very truly yours, Jon T. Stephens Rocky Mountain Lazy J-S Ranch owner Mailing Address: Scaffold Gulch Ranch Other Locations: 1406 Stove Prairie Road 23673 Weld County Road 27% 3756 West County Road 16 Bellvue. Colorado 80512 Milliken, Colorado 80543 Loveland, Colorado 80537 931061 / 1 Box 1399 Saratoga, Wyoming 82331 March 26 , 1993 Greeley Tribune 501 8th Avenue Greeley, Colorado 80632 Dear Editor: Wouldn' t it be great if Weld County citizens could reuse all their garbage or if there were some magic button they could push to make it useful again over night, The fact is , Weld County cannot afford to sit around and wait for such dreams to come true. No one likes living with landfills , but we can' t do without them. The trash is here. The trash will not disappear. We must deal with it. We cannot become part of the NIMBY (Not- in-my-backyard) crowd. The Telep/Daniels group crusading to close the Central Weld Landfill has concentrated on environmental concerns. They have accumulated a file of information, but much is focused on sensational , isolated facts and figures . So many partial truths and rumors have been circulated, it has become a circus. The Action Group has accomplished their stated goals including: to be granted a public hearing to have an opportunity to be heard and to have testing of groundwater and wells surrounding the CWL. They also state "Frankly the types of remediation are fairly simple: The contaminants can be captured and then pumped to a treatment area and then released or the contaminants can be dug up and removed from the landfill . " Now isn' t it time to allow the professionals to do their part? Let us give Waste Services/Waste Management time to finish the job they have already started and have committed thousands of dollars more for continued remediation. If you are ill, do you listen to the opinions of family and friends and stop there, or do you seek the advice of your doctor and specialists? Is Weld County going to base such a wide reaching decision as the fate of Central Weld Landfill on what a group of homemakers , lawyers , pilots , and other novices say, or will the county listen to professionals and specialists in the business - Waste Services/Waste Management , Colorado Department of Health specialists, and Weld County Health Department personel? . 931061c7 March 26 , 1993 Page 2 I join my family in wanting to see an intelligent decision reached regarding the Central Weld Landfill adjoining our Spomer family farm. Please don' t let emotional frenzy and political pressure alone determine the outcome . Yours truly; c._,___77..71_2 .-- ,/ --------- 7 I( K therine S. Hall ' (307) 326-5873 CC: Connie Harbert-Chairwoman, Weld County Commissioners John Pickle, Weld County Department of Health Randolph L. Gordon, M.D. , M.P.H. , Director, Weld County Health Department Lee Morrison, Weld County Assistant Attorney Chuck Cunliffe , Weld County Planning Department Roger Doak, Colorado Department of Health Patricia Nolan, M.D. , Executive Director, M.D. ,, Colorado Department of Health Barbara Taylor, Water Quality Control Division, Colorado Department of Health Johnstown Breeze Loveland Daily Reporter-Herald 931061 . 5026 Redmond Road Cheyenne , Wyoming 82009 March 26 , 1993 Greeley Tribune 501 8th Avenue Greeley, Colorado 80632 Dear Editor: I have been reading negative press releases about Central Weld Landfill . I don' t like landfills either, but they are a necessary part of the American system. Our garbage-creating lifestyle is not going to go away overnight. The Central Weld Landfill has become a widely publicized issue. A well-organized opposition group has created sensational headlines , but there is more than one side to every story. My family objected to the landfill in 1971 when it was proposed, but their concerns were ignored and over-ridden. The damage was done long ago. Closing the landfill will not make it disappear. My family had plans to build on a site adjacent to the present land-fill boundary, but were forced to consider alternate home-building plans after 1971 . They regret their lack of foresight at that time, when they did not urge county officials to see that verbal pledges and agreements be put into a written contract to ensure future compliance with the "so-called-promises , " "mutually-agreed-upon-arrangements, " and Federal , state, and county regulations . Although my family did not want to see a landfill bordering their farm in 1971, we cannot blame Waste Services-Waste Management for the negligence of others in the past. Waste Services/Waste Management is now working at solving many of the problems . Most of the less desirable aspects of the landfill , as with any landfill , really affect only the handful of neighboring land-owners. Thousands of other Weld County residents have not been heard from. Are they willing to pay higher garbage-collection fees to cover the added transportation costs to other sites, give up the convenience of quick Saturday trips to Central Weld Landfill, or pay the added taxes to repair increased miles of highway wear and tear? -f 931061 y l Page 2 March 26, 1993 I think it is time to look at the overall picture and weigh both sides of the issue. If the Central Weld Landfill is closed, the hidden costs to all of Weld County' s citizens will far outweigh any negative aspects that mainly involve the handful of adjacent landowners . Yours truly, Michael Hayes (307) 632-2908 CC: Connie Harbert-Chairwoman, Weld County Commissioners John Pickle, Weld County Department of Health Lee Morrison, Weld County Assistant Attorney Randolph L. Gordon, M.D. , M.P.H. , Director, Weld County Health Department Chuck Cunliffe, Weld County Planning Department Roger Doak, Colorado Department of Health Patricia Nolan, M.D. , Executive Director, Colorado Department of Health Barbara Taylor, Water Quality Control Division, Colorado Department of Health Johnstown Breeze Loveland Daily Reporter-Herald /- 931061 ,) March 25, 1993 Mr. Dale Hall Weld County Commissioner Centennial Center 915 10th Street Greeley, Colorado 80631 Dear Mr. Webster, I read with great interest the March 22nd article in the Reporter-Herald concerning the Central Weld Landfill. In particular the comments of Sharon Schmidt about her well water. With some research, she would discover that the well water in that area has never been drinkable because of the hardness of the water. My father drilled our well in the late 1920's or early 1930's. The water was used for garden purposes and livestock. As a child growing up, you were in big trouble with Mother if you got the well water on the windows because it left spots on the window because of the hardness. Before water lines were run to the farmsteads, we had cisterns and we trucked our water to the farm. I remember Dan the Waterman who delivered to our farm. Before Dan the Waterman we had a water tank and would use.the farm truck to haul water from Greeley. We never had the technical, chemical anaylsis of the water in those days but this we did know. we did not use it for household use. In modern times, we do not use the well water in automatic horse waterers because the mineral content clogs them. I think no taxpayer should be liable for homeowners use of distilled water as Sharon Schmidt states. I write to you because of my conern of so much information being given by the environmental groups that is unfounded. Yours truly, 747-ecenc.A-c-, 931061 2 Landfill issues • To Having read the Spomer sister's March 16 letter and being the owner,of land adjacent to the budflll,I,too,have the same coact= • about the landfill. „, The problems we am now seeing am the same problems and concerns that the Oarcia and Spam*,families had when we opposed the opening of the landfill back in 1971. • Ahem have met with Waste Services/Wane Management to discuss my twrtcettts about • the water quality,and feel they we dedicated to canceling the problems which they wok upon themselves when they ptuthased the operation in 1991.They have been the best omit=since its conception. Living next to the landfill has been ayfng at best,but the fact remains that the garbage accumulation over the last 21 yea is not going away.We need a company with the will,ability and financial capability to man- - age and eventually close the landfill in the most environmentally amid manner. With the Weld County,the state,Waste Services/Waste Management and"the.com- munity cooperating together,continuing to operate and then closing the landfill through .. its planned life cycle appears to be the best° solution for our environment Arthur P.Osm t . Mnnkea Printed in Greeley Tribune March 24, 1993 edition Page 8 z= 931061 LOUIS E. SPOMER OIL AND GAS PROPERTIES TELEPHONE 4055 SOUTH ONEIDA STREET AREA CODE (303) 757.1442 DENVER,COLORADO 80237 March 24 , 1993 Weld County Commssioners Centennial Center 915 10th Street Greeley, Colorado 80631 Re: County Landfill Gen t,4men, We shouldn ' t let a handful of people cause the County Commissioners to make another environmental mistake in the future of the Central Weld County Landfill , located east of Milliken . The first handful of people coused the Commissioners to allow the opening of the landfill in 1971 . The second handful of people are trying to force the Commissioners to prematurely close the Landfill . Itdoes not serve the community nor the enviroment by the radical actions proposed by these people. The damage caused by the first handful of people cannot be reversed by the second handfull of people ' s wishful thinking ! The fact is; the landfill is there to stay; active or inactive . The far sighted course, for the Commissioners to follow, to best serve the community and the enviroment , is to cooperate with the current operators of the landfill to insure an environmentally safe, normal closing of the landfill at the end of its useful cycle. Very Tr yours , • ouis E. Spo mer Concerned Landowner Ft 931061 ._-7/.7 t- 931961 _�1 March 10. 1993 rte., O p- y Greeley Tribune 501 8th Avenue Greeley, Colorado 80632 Dear Editor, We have read the articles pertaining to the Central Weld Landfill with great interest. As the only landowners with bordering property below the landfill, we are quite concerned with future developments regarding the fate of the landfill. We would like to point out that Waste Services/Waste Management did not create the problem. They took over an existing dilemma that dates back to 1971. The problem has developed because of lack of monitoring by county officials. It appears that Waste Services/Waste Management is working to correct the situation. Their company has both the resources and the technical insight to carry out the solution. If Weld County officials close the landfill, will Weld County be responsible for cleaning up any pollution and contamination in perpetuity? We can't just wish or complain this situation away. In reviewing the history of events since 1971. the main impression that emerges is: "Where have Weld County officials been for all these years?" In 1971 they ignored the request and concern of neighboring landowners to not allow the landfill because of the water table, the seepage in the draw adjacent to the site and the proximity to the Big Thompson river. Not only did they override the request, but it appears those same officials were negligent from the very beginning in setting up proper guidelines and written agreements to protect Weld County citizens. Throughout the period of 1971 to 1992, it also appears the Weld County officials did little monitoring of the situation, until a public outcry in 1992 brought a sudden flurry of activity. / 931061 It does seem that the .dfill issue might be best served L the county officials cooperating with Waste Services/Waste Management, who has the expertise, resources and ability to eliminate existing and future problems. Very truly yours, r1astalAnntiiv ,s �a�xl,� y' Ella Marie Spomer Hayes Susanne Spomer Stephens CC:John Pickle, Weld County Department of Health Lee Morrison, Weld County Assistant County Attorney Randolph L. Gordon, M.D., M.P.H., Director, Weld County Health Dept. Chuck Cunliffe, Weld County Planning Department Roger Doak, Colorado Department of Health Barbara Taylor, Water Quality Control Division Colorado Dept. of Health Joyce Williams, Department of Health Environmental Compliance Officer 9 ";1061 / 931061 March 10, 1993 �! I Weld County Commissioners �•J Centennial Center 915 10th Street Greeley, CO. 80631 Dear Commissioners: We are owners of the property directly south and west of the Central Weld Sanitary Landfill. We have recently received a notice from Chuck Cunliffe of the Weld County Planning Department that you intend to hold a public hearing on the landfill on April 5, 1993. Prior to this notice, we have not been contacted by anyone at the county or the media regarding our knowledge of the current situation or the activities at the landfill for the past 20 years. Our property is the only bordering property which is below the landfill. We were not in favor of placing this facility uphill of us in 1971 when the Board of Commissioners approved the location. Nevertheless, we have had to deal with it in the best manner possible throughout these past 21 years and must continue to do so... In July 1992, the current operators informed us they had recently expanded their testing of the groundwater and discovered some contamination along the common borders of our property. Naturally,we were very concerned about this discovery they had made. However, since that time, we have been pleased to see the progress and commitment Waste Services/Waste Management has demonstrated toward resolving this situation. Our family has owned this property next to the landfill for many, many years and would like to continue to own this property. We are trying to work with the landfill operators to allow them a reasonable amount of land around the facility to do the right thing. Even if they acquire this additional property,we will still be the only property owners directly in the path of groundwater contamination. We, and you, must not jeopardize the community's best option to clean up and eventually close this facility properly. If you force the premature closure of the landfill, you are placing our property at risk for greater long range environmental damage. Please don't jeopardize the community's best solution. • 9.31061 "? Weld County Commissioners Centennial Center March 10, 1993 Page Two Negative community opinion and pressure will not solve the only real issue; environmental impact to us in the future. We can't just wish or complain this situation away. This approach is not productive and only stands to hurt Weld County and our environment. Let's focus on taking advantage of their expertise to correct any past problems. We urge you to give Waste Services/Waste Management a chance to continue their professional approach to operating, clean-up and proper closure of the Central Weld Sanitary Landfill. Any other action will place our property in jeopardy. Very truly yours, CC Via,44)..1,,„joembr_g(3071 3.16 - 187.7 _Add ( Ella Marie Spomer Hayes Susanne Spomer phens yTz-2/7/7 CC:John Pickle, Weld County Department of Health Lee Morrison, Weld County Assistant County Attorney Randolph L. Gordon, M.D., M.P.H., Director, Weld County Health Dept. Chuck Cunliffe, Weld County Planning Department Roger Doak, Colorado Department of Health Barbara Taylor, Water Quality Control Division Colorado Dept. of Health Joyce Williams, Department of Health Environmental Compliance Officer / / 931061 MEMORAnDUM WILDo To Board of County Commissioners April 1, 1993 COLORADO John Pickle, Healt 7<2 From � Hearing - Central Weld Sanitary Landfill Subject The Central Weld Sanitary Landfill has been in operation at least since 1971. Waste Services Corporation took over the operation in 1989 and merged with Waste Management of Colorado, Inc. , in 1991. The site has been monitored over the years by the Colorado Department of Health, as well as Weld County Health Department. Our Department has tried to maintain an inspection frequency of at least four visits per year. In addition, our laboratory sampled Central Weld's monitoring wells until the discovery of Volatile Organics indicated a more sophisticated monitoring program was necessary. In July of 1992, I met with Bill Hedberg of Waste Services at this facility. At that meeting we discussed the history of groundwater problems at this site and Waste Management's efforts to control them to date. Mr. Hedberg also informed me at that meeting that Waste Management's Laboratory had discovered low levels of contaminants in several downgradient monitoring wells and that a full written report would be forthcoming. He asked that in light of these findings Central Weld be allowed to discontinue its agreement with Weld County for monitoring, and contract with a more sophisticated laboratory. I readily agreed with this proposal since our lab could not test for Volatile Organic Compounds. As clarification for the Board, Volatile Organic Compounds are contaminants commonly from landfill leachate, as well as underground storage tanks, agricultural runoff, and other sources. VOCs are common constituents in industrial and household solvents pesticides, and other chemical products. Toxicological studies have shown that some of these organics have the potential for carcinogenesis in human beings. Consequently, their presence in the groundwater is of public health concern. In August, 1992, we received the Hydrogeologic and Geotechnical Characterization for the Central Weld Sanitary Landfill, Weld County Colorado. After review and discussion with Colorado Department of Health personnel, we cited the Central Weld facility in October, 1992. (See attached Report and letters of August 17, and October 5, 1992.) Waste Management performed confirmation sampling at the Central Weld facility in September, 1992. The results confirmed previous findings submitted in the Hydrogeological Characterization of July. (See attached Central Weld Sanitary Landfill Confirmation Groundwater Sampling, October, 1992. ) Golder Associates Inc. performed an Expanded Hydrogeological Investigation at the Central Weld Sanitary Landfill, Colorado in October, 1992. The purpose of this h/d/fGCT 931.96' investigation was to determine the extent of migration of the VOCs offsite. (See attached Expanded Hydrogeological Investigation. ) Since October, subsequent inspections, discussions with Colorado Department of Health personnel, and meetings with Waste Management have culminated in Weld County Health Department citing the Central Weld facility for four (4) violations, and requesting this Hearing. The Department contends that Central Weld Sanitary Landfill is in non-compliance with existing rules in the following areas: 1. The operators of the Central Weld Sanitary Landfill have not submitted a complete Design and Operations Plan. There is some question as to whether or not this was a requirement at the time this facility was permitted. Such a report was required in the 1971 Amendments to the Solid Waste Act prior to the hearing by the Board of County Commissioners, but the Act requires such a report only "as may be required by the [State Health] Department by regulation." The State appears to have decided that no report was necessary as they treated the landfill as a grandfathered site. Regardless of the State's position, it appears that the Board of County Commissioners expected such a review and that one never occurred. A review of the files does not show that there ever has been an "approval" by the State Health Department. The Board of County Commissioners requested a Design and Operations Plan for this facility by November 12, 1992. A partial submission was made by Waste Management. After review, this submission was considered incomplete. (See attached letter of February 22, 1993. ) To date, the additional documentation has not been submitted. This is a violation of 30-20-103, Colorado Revised Statutes. (Copy attached) 2. The Central Weld Sanitary Landfill continues to operate without required Discharge Permits. This fact is documented in letters from Waste Management, November 16, 1992, and Colorado Department of Health, November 17, 1992. (Attached) Colorado Department of Health, Water Quality Division personnel have indicated that despite application for the required permits, the facility is in technical violation of the rules, but they are holding further enforcement in abeyance so long as the facility continues in good faith with the application process. Weld County Health Department agrees that this is a violation of Subsection 2.1.2 of the Solid Waste Regulations and 25-8-501, Colorado Revised Statutes, (Attached) , but it appears this condition is near final correction. 3. The Central Weld Sanitary Landfill continues to contaminate the groundwater, and this contamination has migrated offsite. This fact is evidenced by Waste Management in two documents: The Hydrogeologic and Geotechnical Characterization for the Central Weld Sanitary 93106' 6-6- " Landfill, July 1992, pages 41, 42, 55, and 57; and the Expanded Hydrogeological Investigation at the Central Weld Sanitary Landfill, Colorado, pages 5, and 6. The Department feels that this is a violation of Subsections 2.1.2 of the Solid Waste Regulations, specifically, 3.11.5 of the Water Quality Commission Rules, and 2.1.4 of the Solid Waste Regulations. That this is a violation of 2.1.4 is also indicated in a letter from Colorado Department of Health to Waste Management dated December 21, 1992, specifically page 4, paragraph C.1. (Attached) That this is a violation is also further indicated in an Attorney General's Opinion dated March 5, 1993. (Attached) 4. The Central Weld Sanitary Landfill has allowed solid waste to come into contact with groundwater on this site. This is documented in the Hydrogeologic and Geotechnical Characterization for the Central Weld Sanitary Landfill, July, 1992, page 34. This condition results in the production of leachate, a source of groundwater pollution and public nuisance. This is a violation of Subsection 2.1.4 of the Solid Waste Regulations. In addition, this too is indicated in the Attorney General's Opinion dated March 5, 1993. An inspection by our staff on March 2, 1993, indicated that the Central Weld Sanitary Landfill is still in non-compliance in the areas referenced above. Further, the Weld County Health Department and the Colorado Department of Health feel that items #3 and #4 constitute a public nuisance. We would ask that the Board of County Commissioners find that, on balance, there are sufficient facts shown to justify proceeding with a Show Cause Hearing. 931.06' ( ( . July 1992 -34- 913-2403 4.4 Vertical Groundwater Flow Seven deep/shallow well pairs exist at the site. At the upgradient well pairs, downward vertical gradients exist (-0.40 to -0.80). Well pairs near Spomer Lakes exhibit slight downward to upward gradients (-0.11 to +0.01). At the downgradient well pair which is not near Spomer lakes (GWMW-12 and GWMW-5N) a slight downward gradient exists (-0.014). Table 4-2 is a summary of vertical gradients at the well pairs. The slight gradients at the well pairs adjacent to Spomer Lakes may indicate that the lakes are locally recharging groundwater. It should be noted that the vertical gradient may change seasonally. 4.5 Depth to Groundwater in Landfiiled Areas As mentioned in Section 1.4, seven trash piezometers (TP-1 through TP-7) were installed in 1991 under the supervision of Industrial Compliance Inc. (IC). The purpose of these piezometers was to delineate depths and thicknesses of refuse. IC reported that groundwater was above the base of trash in piezometers TP-1 and TP-6 at heights ranging of 1.92 feet and 0.42 feet, respectively. In addition, IC made recommendations concerning the conceptual design of the groundwater collection/diversion ditch located along the northern and eastern edges of the landfill. The purpose of this ditch was to control groundwater levels below the landfill. As part of the recent field investigation, water levels were measured in all of the trash piezometers in order to evaluate the effectiveness of the groundwater collection/diversion ditch. Table 4-3 summarizes the water levels measured in the trash piezometers with respect to base of solid waste as reported by IC in their 1991 report. Groundwater was present above the base of solid waste at only one location, piezometer TP-1, where groundwater was 6.34 feet above the base of solid waste. As shown on Figure 2-1, TP-1 is located near the northwest corner of the site. In this vicinity, the groundwater collection/diversion ditch is unlined, potentially resulting in local recharge in the area of TP-L 93196x'. 6-6-- Golder Associates (� July 1992 -38- 913-2403 A core sample containing both fine-grained and coarse-grained materials was tested in order to obtain a value for permeability of the two units acting together. The resultant value for this sample is 2x104 cm/sec. The relatively low permeability of this sample indicates that the fine- grained materials exert a pronounced influence on vertical permeabilities. Based on data provided by Industrial Compliance, 1991, the base of the landfill apparently rests on Upper Weathered Bedrock. Therefore, the permeability values for the Upper Weathered Bedrock unit have significant implications regarding potential contaminant migration. The • permeability of these materials ranged from 3x117' cm/sec to 4x104 cm/sec. These are relatively low permeabilities and suggest that the Upper Weathered Bedrock unit would likely act as a significant bather to downward migration of contaminants. 5.5 Geochemical Characteristics ( Geochemical characteristics of geologic materials at the site were evaluated by Analytica Laboratory of Golden, Colorado for Cation Exchange Capacity (CEC) and pH. The CEC evaluation was performed to assess the contaminant attenuation potential of the Upper Weathered Bedrock and the Surficial Unconsolidated material. The evaluation of pH was performed in order to assess the CEC values as they apply to the site, since CEC is strongly dependent upon pH. An additional motivation for pH testing is a cursory assessment of the ability of the soil to act as a buffer to acid leachate drainage. 5.5.1 Cation Exchange Capacity The CEC of geologic material is a measure of the ability of that material to adsorb exchangeable cations. It can therefore be used as a measure of the ability to attenuate the migration of some contaminants, primarily inorganic contaminants, by adsorption of exchangeable cations. Clay minerals have, to varying degrees depending on the particular mineralogy, a high capacity to adsorb specific inorganic solutes because of large surface areas and numerous exchange sites. 92106 q CrG Golder Associates ' <_ 1I ( July 1992 -39- 913-2403 In general certain metals including lead, cadmium, mercury and zinc are particularly susceptible to attenuation. Potassium, ammonia, magnesium, silicon and iron are moderately attenuated. Sodium is weakly attenuated. Divalent cations are generally more readily adsorbed than monovalent cations. Cations are more strongly adsorbed than anions. Conservative solutes such as chloride are not attenuated. CC is typically reported in terms of milliequivalent per 100 grams of dry mass (meq/100g). In order to evaluate CEC and pH at the site, 5 samples were submitted for testing. Four of the samples were of the Upper Weathered Bedrock and one sample was of the Surficial Unconsolidated silty clay. Upper Weathered Bedrock samples were favored since base of solid waste is estimated to be typically within the Upper Weathered Bedrock unit. Two of the samples were from upgradient soil gas wells (SG-I6,SG-20)and three of the samples were from downgradient soil gas wells (SG-3, SG-6 and SG-9). Table 5-3 presents the results of the CC and pH analyses. Values for CC range from 18.3 meq/I00g to 37.3 meq/100g. Based on these results, the materials at the site have the potential to attenuate the migration of inorganic contaminants. 5.5.2 Soil/Rock pH The same five samples submitted for ac analysis were also analyzed for pH. The pH of material underlying the site has a direct bearing upon the CEC of the material. The laboratory procedure for CC testing involves neutralizing the material (pH of 7.0). In a low pH environment a greater percentage of Hydrogen ions (Ii+) are present. These H+ ions limit the exchange sites available and therefore lower the ac. The pH values reported for the Central Weld site range from 7.5 to 7.9. Since the reported pH values are close to neutral the CC values reported by laboratory testing should closely mimic those relative to field conditions. The pH of a geologic material is an indicator of the alkalinity of the material which in turn governs the ability of that material to buffer acid leachate. The range of pH values reported (7.5 to 7.9) are just slightly basic. G- Golder Associates 9•v1!JV? ' JO 7uly 1992 -40- 913-2403 6.0 RESULTS OF WATER OUALITY ANALYSES Water quality samples were collected at the Central Weld site in March 1992 from eight shallow monitoring wells, seven deep monitoring wells, and three surface water sampling sites. Several quality assurance (QA) samples were also collected: a field duplicate, a field blank, a trip blank, and laboratory blanks. Procedures used to collect the field duplicate, field blank, and trip blank samples are described in Section 2.6. In addition, laboratory blanks were prepared and analyzed by the laboratory during sample analysis. Laboratory blanks were prepared by the laboratory and were analyzed without leaving the laboratory. Laboratory blank samples were analyzed concurrently with field samples to provide an indication of contamination introduced at the laboratory. Analysis of laboratory blanks was sporadic. Several laboratory blanks were analyzed for a particular type of analysis (e.g., volatile organics), while no laboratory blanks were analyzed for other types of analyses (e.g.,nutrients). This is typical for laboratory blanks and does not adversely impact the quality of the data. The samples were analyzed by Enseco/Rocky Mountain Analytical Laboratory in Arvada, Colorado. The following parameters were analyzed: ► Volatile Organic Compounds (VOCs); ► Pesticides and Herbicides; ► Trace Metals; ► Nutrients; ► Major Anions and Cations; and, ► Radionuclides and Radioactivity. .l1.f16.'. // 6-6- Golder Associates C C July 1992 41- 913-2403 A discussion of the laboratory results is provided below. Laboratory analytical results are included in Appendix I. 6.1 Volatile Orsanic Compounds A total of 34 volatile organic compounds (VOCs) were analyzed in the water quality samples (Table 6-1). Of these, eight VOCs were detected in one or more of the samples. These are: ► Acetone; ► 1,1-Dichloroethane; ► 1,2-Dichloroethane; ► 1,2-Dichloroethene; • 1,2-Dichloropropane; ► Methylene chloride; ▪ Trichloroethene; and, ► Tetrachloroethane. The volatile organic compounds that were detected and their concentrations are summarized in Table 6-2. VOCs were detected in five monitoring wells: GW 32,_GW1 iW� ONT/MW-5N, and GWMW-7. Al of these wells are completed in the shallow aquifer. With the exception of GWMW-2, each of these wells is located downgradient of the landfill. Monitoring well GWMW-2 is located upgradient of the landfill. Figures 4-IA and 4-1B show the location of the wells and the inferred direction of groundwater flow in the shallow aquifer. Vats were also detected in one of the stirface water samples, LF-UD,collected from the outlet. of the landfill underdrain. tNo VOCs were detected in the surface water samples collected from Golder Associates July 1992 -42- 913-2403 the steel culvert which drains the off-site area at the north property boundary (N-Discharge) and the inlet of the retention pond (RP-Inlet). VOCs were not detected in the field blank. Methylene chloride was detected in the trip blank and sample GWMW-7. Two VOCs were detected in the laboratory blanks: acetone, and methylene chloride. Both of these compounds are common laboratory contaminants. Acetone was detected in sample GWMW-2. Based on the laboratory and trip blank results, acetone and methylene chloride are present as a result of laboratory contamination and do not accurately reflect impacts from the landfill. Following is a list of detected volatile organic compounds, the range of concentrations at the site, and their corresponding drinking water standards: ( Range of State of Federal Compound Concentration Colorado Standard Standard (mg/1) (mg/1) (mg/I) 1,1-Dichloroethene <0.005 to 0.0059 N/A N/A 1,2-Dichloroethane <0.005 to 0.018 0.005`; 0.00042 0.005' 1,2-Dichloroethene <0.005 to 0.026 0.12 0.07` 1,2-Dichloropropane <0.005 to 0.0066 0.562 0.005' Trichloroethane <0.005 to 0.070 0.005'; 0.0052 0.005' Trichloroethene <0.005 to 0.210 0.0052 0.005' Standard shown for 1,2-dichloroethene is representative of cis-1,2-dichloroethene. State Standards 1: Colorado Drinking Water Standards, CCR Title 5 12: Colorado Ground Water Standards, CCR Tide 5 Federal Standards 3: Currently applicable standard promulgated under the Safe Drinking Water Act, 40 CFR 141 4: Safe Drinking Water Act Standard to become effective on July 30, 1992. /G' 92,106t. /3 July 1992 -43- 913-2403 Based on the information presented above, the maximum detected concentration of 1,2- dichloroethane, 1,2-dichloropropane,trichloroethene,and tetrachloroethene exceeds either a State of Colorado or federal standards. The maximum concentration of each of these compounds was exhibited by shallow groundwater on the downgradient site of the landfill in monitoring wells MW-4, MW-S, or MW-5N (Table 6-1). All detected concentrations of 1,2-dichloroethene are below State and federal standards_ No standards have been established for 1,1-dichloroethane. 6.2 Pesticides and Herbicides The water quality samples were analyzed for four pesticides (Endrin, Lindane, Methoxychlor, and Toxaphene) and two herbicides (2,4-D and 2,4,5-TP (Silvex)). No pesticides or herbicides were detected in any of the water quality samples analyzed. 6.3 Trace Metals Ten trace metals were analyzed in the water quality samples: arsenic, barium, cadmium, chromium, iron, lead, manganese, mercury, selenium and silver. Of these, five trace metals (barium, cadmium, chromium, iron and manganese) were detected in one or more of the samples. The detected concentrations for these trace metals are summarized in Table 6-3. The following paragraphs discuss the five detected trace metals. Banunr, iron, and/or manganese were detectedin seven of the nine shallow monitoring wells and in each of the deep monitoring wells and surface water sample Cadmium a d-chromtnm were only detected in one sample,which was collected from deep-monitoring we3L . This appears to be an isolated occurrence. No trace metals were detected in the field blank or in the laboratory blank analyzed for this set of samples. As is typical, the trip blank sample was not analyzed for metals. 66- Golder Associates 921.06! July 1992 -44- 913-2403 Barium concentrations ranged from <0.010 to 0.043 mg/1. There was no significant difference between the concentration of barium in the shallow and deep monitoring wells or between upgradient and downgradient sampling sites. This suggests that barium detected in the samples is originating from natural, geologic sources. The detected barium concentrations were all below the current primary drinking water standard of 1.0 mg/1 established by the EPA and the State of Colorado. Iron concentrations ranged from <0.10 to 0.87 mg/I. The secondary standard for iron established by the EPA and State of Colorado is 0.3 mg/I. Iron was only detected in the deep monitoring wells and the surface water samples. The presence of iron in the deep monitoring wells but not the shallow monitoring wells suggests that groundwater in the deeper aquifer is chemically under reducing (anaerobic) conditions whereas groundwater the shallow aquifer is under oxidizing (aerobic) conditions. Iron is nearly insoluble in waters that are oxygenated and not acidic but can be quite soluble in near neutral or basic waters that are void of oxygen. Field water quality measurements indicated that groundwater from both the shallow and deep aquifers at the site is, in fact, near neutral or basic. The presence of iron in site surface waters, expected to be well aerated and therefore insoluble to iron, is probably explained from particulates entrained in the samples during collection. Surface water samples for trace metals were not filtered when collected which could explain the source of particulate matter in the samples. Any iron in the particulates would have become dissolved into the water during sample preservation. Manganese concentrations ranged from <0.010 to 1.7 mg/1. The secondary standard for manganese established by the EPA and State of Colorado is 0.05 mg/I. Manganese was detected in the surface water samples, the shallow monitoring wells, and the deep monitoring wells. Concentrations of manganese were generally higher in the deep monitoring wells. In fact, the maximum detected concentration of manganese was exhibited by deep monitoring well GWMW- 8, located on the upgradient side of the landfill. Geochemically, manganese behaves very similar to iron. This probably explains the difference in manganese concentrations between the deep and shallow aquifers. GU Co yr •••••0 + 0 v C a ,. ..i .0% -1 QL r o w:,y - l`� U /{t w— Golder Associates 92i06/ 75 r ( July 1992 -45- 913-2403 6.4 Nutrients Two common nutrients, nitrate and ammonia, were analyzed in the water quality samples. Nutrient concentrations are summarized in Table 6-4. Ammonia was detected in six of the seven deep monitoring wells but in none of the shallow monitoring wells or surface water samples. Ammonia is a common groundwater constituent in areas of agricultural activity. Ammonia is chemically unstable in water under oxidizing conditions common in surface waters and shallow aquifers. This may explain why it was not detected either in the site surface waters or in the shallow aquifer. The presence of ammonia in groundwater from the deeper aquifer suggests that this aquifer is under reducing conditions and may be impacted by agricultural activities upgradient of the landfill. There is currently no EPA or State of Colorado standard for ammonia. Nitrate was detected in all but one of the samples and ranged in concentration from 0.11 to 18.5 mg/I as N. Two samples (GWMW-2 and N-Discharge) exceeded the EPA and Stare of Colorado drinking water standard for nitrate of 10 mg/I as N. Monitoring well GWMW-2 is completed upgradient of the landfill in the shallow aquifer and surface water sampling site N-discharge is located along the northern landfill boundary adjacent to agricultural land. Nitrate levels were consistently higher in the shallow monitoring wells and surface water samples than the deep monitoring wells, suggesting that nitrate is originating from agricultural activities near the landfill. This interpretation is consistent with the finding of Industrial Compliance, Inc. (1991). Neither nitrate nor ammonia were detected in the field blank. The trip blank was not analyzed for nitrate or ammonia. 6.5 Major Anions and Cations The following major anions and cations were analyzed in the water quality samples: calcium, l magnesium, potassium, sodium, alkalinity (bicarbonate and carbonate), chloride, and sulfate. (6T Golder Associates 92196_*, July 1992 -46- 913-2403 The results of these analyses are presented on a ttilinear diagram on Figure 6-1. Sample concentrations are designated on the diagram as a percentage of the total cation and anion concentrations measured in each sample. Note that the samples have been divided into three general groups based on their source: surface water, shallow monitoring wells and, deep monitoring wells. The position of the samples on the trilinear diagram indicates that all of the samples have a similar chemical signature and probably cannot be distinguished based on their major anion and cation data alone. Based on the predominant cation and anion measured, the samples classify as either calcium-sulfate or magnesium-sulfate waters. Most of the samples exceeded the secondary drinking water standard for sulfate of 250 mg/1. 6.6 Radionuclides and Radioactivity Two radionuclides (Radium 226 and 228) and two measures of radioactivity (Gross Alpha and Gross Beta) were analyzed in each of the water quality samples. The results of these analyses are summarized in Table 6-5. Two samples exceeded the EPA and State of Colorado drinking water standard for combined Radium 226 and 228 of 5 pCi/1. Both samples were collected upgradient of the landfill, one from shallow monitoring well GWMW-3 and the other from deep monitoring well GWMW-10. Combined Radium 226/228 activities for the other samples ranged from 0.3 to 4.9 pCi/1 and averaged 2.0 pCi/1. There was no significant difference between the activities of groundwater samples upgradient and downgradient of the landfill, suggesting that the landfill does not act as a source of radioactivity. Fifteen of the eighteen groundwater and surface water samples exceeded the EPA and State of Colorado drinking water standard for Gross Alpha activity of 15 pCi/I. Gross Alpha activities ranged from 11 to 180 pCi/1 and avenged 49.3 pCi/1. The highest activities were measured in 9.2,106t. /7 Golder Associates July 1992 47- 913-2403 the shallow monitoring wells. It should be noted that there was no significant difference between the activities of groundwater samples upgradient and downgradient of the landfill, suggesting that the landfill does not act as a source of radioactivity. Gross Beta activities ranged from 0.0 to 71 pCi/I and averaged 33.8 pCi/1. Similar to the Gross Alpha results, Gross Beta activities were generally higher in the shallow monitoring wells than the deep monitoring wells with no significant difference between upgradient and downgradient wells. A standard for Gross Beta has not been established by the EPA or State of Colorado. The source of radionuclides and radioactivity in the samples appears to be natural and is probably related to native geologic materials occurring beneath the site. Overall, there was no significant difference between sample activities upgradient and downgradient of the landfill. Low activities of Gross Alpha (0.8 pCi/1) and Gross Beta (1.6 pCi/I) were detected in the field blank. The trip blank was not analyzed for radionuclides or radioactivity. No laboratory blanks were analyzed for radionuclides or radioactivity. Go— Golder Associates 921,n6.!• �a July 1992 -53- 913-2403 8.0 SUMMARY AND CONCLUSIONS This "Hydrogeologic and Geotechnical Characterihadon Report' was prepared to provide Waste Services Corporation(WSC)with a comprehensive evaluation of the geology,hydrogeology, and geochemical conditions at the Central Weld Sanitary Landfill. The information presented in this report will be the basis for developing environmental monitoring systems for groundwater, surface water, and landfill gas. The remainder of this section presents summaries and conclusions regarding site conditions. 8.1 Geology Thee geologic units have been identified at the site. They are herein referred to as the Surficial Unconsolidated Unit, the Upper Weathered Bedrock and the Lower Weathered Bedrock. The Surficial Unconsolidated Unit is an eolian silty day to clayey salt which ranges in thickness from a few feet to nearly 30 feet. The Surficial Unconsolidated Unit exhibits considerable lateral and vertical homogeneity. The Upper Weathered Bedrock is comprised of interlaminated and interbedded silty fine sandstone and claystone. The unit is typically yellowish brown, is poorly indurated and varies laterally across the site. The thickness of the unit ranges from approximately 40 to 70 feet. The Lower Weathered Bedrock is comprised of interlaminated and interbedded, medium to dark grey, silty fine sandstone and claystone. The unit is slightly less weathered than the Upper Weathered Bedrock. Thickness of the Lower Weathered Bedrock was not determined as part of this study. 92106 Iq Golder Associates r July 1992 -54- 913-2403 8.2 Hydroeeoloey Three saturated zones, a perched zone, a shallow groundwater zone, and a deep groundwater zone, were encountered in this study. Each is discussed below. Perched Zone A perched zone is inferred to exist east of the diversion trench along the northeastern perimeter of the site. The perched zone rests on top of a claystone unit and receives recharge from irrigation. The irrigation results in seasonal water level rises of a few feet in the perched water. Irrigation does not occur on the landfill. Therefore, perched waters are not evident within the landfilled areas. Shallow Saturated Zone The shallow saturated zone occurs near the top of the Upper Weathered Bedrock. Direction of flow in the shallow saturated zone is to the south-southwest. The average horizontal gradient across the site is approximately 0.03 ft./ft.. Average horizontal groundwater flow velocity is approximately 95 feet per year. In one localized area, the shallow saturated zone extends above the base of the landfill. This is evidently the result of infiltration through the diversion trench which extends along the northern boundary of the landfill. The saturated refuse may be an avenue for contaminant migration into the shallow groundwater system. Deep Saturated Zone The deep saturated zone occurs within the lower portion of the Upper Weathered Bedrock and the upper pardon of the Lower Weathered Bedrock. Direction of flow is to the south-southeast. 921064 10 Golder Associates 1 July 1992 -55- 913-2403 The average horizontal gradient across the site is approximately 0.02 ft./ft. Average horizontal groundwater flow velocity is approximately 11 feet per year_ During drilling, a relatively dry zone approximately 5 to 10 feet thick was generally noted between the shallow groundwater and the deep groundwater.' The presence of the dry zone suggests that the degree of communication between the shallow and deep groundwater systems is minimal. Vertical Groundwater Flow Downward vertical gradients exist at the shallow/deep well pairs across the site except near Spomer Lakes where weak downward to slightly upward gradients have been calculated. Apparently the lakes are locally contributing a constant head recharge to the groundwater. 8.3 Water Ouality F Water quality samples were collected from all of the groundwater monitoring wells and from three surface water sampling points. The following parameters were analyzed: ► Volatile Organic Compounds (VOC); ► Pesticides and Herbicides; ► Trace Metals; ► Nutrients; ► Major Anions and Cations;and, ► Radionuclides and Radioactivity. Volatile organic compounds were detected in four downgradient shallow groundwater monitoring wells (GWMW-4, GWMW-5, GWMW-5N and GWMW-7), upgradient monitoring well GWMW-2, and in the surface water sample from the landfill underdrain (I.F-UD). The only VOC detected in GWMW-2 was acetone, which is presented as a result of laboratory 9Ct o6. / Golder Associates July 1992 -56- 913-2403 contamination. The maximum concentration of volatile organic compounds in the downgradient monitoring wells generally exceed EPA or State of Colorado standards. VOCs were not detected in any deep wells. No pesticides or herbicides were detected in any of the water quality samples analyzed. Four trace metals (barium, cadmium, iron and manganese) were detected in one or more of the samples. In general, no trend was observed for occurrence of metals with respect to shallow versus deep wells or upgradient versus downgradient wells. The presence of iron in the deep monitoring wells but not the shallow monitoring wells suggests that water in the deeper saturated zone is chemically under reducing (anaerobic) conditions whereas water in the shallow saturated zone is under oxidizing (aerobic) conditions. Ammonia was detected in six of the seven deep wells but none of the shallow wells. The presence of ammonia in the deep wells is another indication of anaerobic conditions in the deep saturated zone and suggests that a source of ammonia exists upgradient of the landfill. Nitrate was detected in all but one of the water quality samples. The detection of nitrate in upgradient as well as downgradient wells suggests an agricultural source. The water quality samples classify as calcium-sulfate to magnesium-sulfate based on the analysis of major anions and cations. Fifteen of the eighteen groundwater samples exceed the EPA and State of Colorado drinking water standard for Gross Alpha activity. Two samples exceed the EPA and State of Colorado drinking water standard for combined Radium 226 and 228. The source of radionuclides and radioactivity appears to be natural and related to geologic materials occurring beneath the site. �+®- 69- Golder Associates �a July 1992 -57- 913-2403 The water quality results discussed above suggest that the landfill has contributed volatile organic compounds to the shallow saturated zone and the landfill underdrain. Concentrations exhibited by an off-site (approximately 15 feet from the landfill boundary), downgradient, shallow monitoring well (GWMW-5) suggest that volatile organic compounds have migrated off-site. Based on other analytical data collected as part of this study, the landfill does not appear to be a significant source of metals, pesticides, herbicides, nutrients, major anion and cations, or radionuclides. The deeper groundwater system has apparently not been adversely impacted by the landfill operations but has evidently been impacted by upgradient activities. Upgradient groundwater sample results for nitrate, sulfate, radionuclides, and radioactivity indicate that the shallow groundwater near the landfill does not meet drinking water standards due to naturally occurring conditions or upgradient impacts. However, two downgradient water wells are permitted by the State of Colorado to withdraw shallow groundwater for domestic or stock use. These two wells represent potential receptor points for volatile organic compound migration via shallow groundwater. The following section presents recommendations for upgrades to site operations and additional investigative activities based on the data presented in this report. 92.1.06.". Golder Associates 3 __ y July 1992 -58- 913-2403 9.0 RECOMMENDATIONS Baud on the information presented in this report, the following recommendations are made to upgrade the site operations and to further define the site hydrogeological and geochemical conditions: ► The design of the unlined portion of the diversion trench located along the northern boundary of the site should be revised to prevent continued recharge to the shallow aquifer system. ► The extent of off-site volatile organic compound migration south of the landfill should be delineated. ► The current use of the downgradient water wells south of the landfill should be determined through interviews with well owners. ► Surface water in Spomer Lakes should be sampled to determine if discharge from the landfill underdrain is measurably impacting the lakes. ► Shallow monitoring wells along the southern portion of the landfill should be =sampled to provide a larger database and to confirm the results of the Golder investigation. ► The potential impacts from upgradient irrigation activities should be defined through quarterly sampling of all monitoring wells. ► Seasonal water level changes should be determined through quarterly monitoring of water levels in all monitoring wells and soil gas probes. ► The extent of saturated refuse in the northern portion of the landfill should be determined through installation of additional piezometers. �T�y Golder Associates SL1O6t. • • ? ei EA Tilt. coca 8r 0000000 ; 88 . 0000008 O.. 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VVVV val VVVVVVV c; V V V p: V V V V V V V F-- mHL , —, 2,,- (- : - ? in v Z • . 888asp": lel Lf7 MI:x8888 - 8888888 :..888 18388888 � ti01 • 000 d' d o o 000000c. ;odd >a 000dddd < :,. V V V VV V V V ' V V V V V V V OV V V a : V V V V V V V o ^ vp�pN yp 3 WF N NON 'NN N py0000SS 8 ~ r4.a 88880 88 --.888888a f 8 ,,.,�.o .-�' 0 0 0 0 0.. 0 0 'O O 0 0 o o 0 D o t :O 0 0 0 0 0 0 n m. ,mow r. . V V V v V O.0s V v : V V V V V V V '9O V V V V V V V V V 0 `o > �> E _: o ). @ co ON0000 ': '.0000000 -000 '0 x'01 �" <cr in.8 0 .000000 : 0000000 y 000 :0ogg T':' YL Zx.`^.ar 00000000 7:0000000 :OOO y !.00«� Q I m — 'a V V V V V V V V , - V V V V V V V : V V V ` V V 0000'§' a `N /6'x 1: m m m C • m C C C pm N N N N N N N N N N N N N NNN N N N 'N N N N N N N as -.. ` t - O0 C1C ommmm ammmmmm . mmm e.g.! m V S V $ m ua -< N N N N N �a N A ]N a7 N N f N N 'NNN ' N N g a g f A C m m m Q aaaaaaaaaaaac3 : 'a as a a a ail c7 :aaa ; .iaa oo _N mcLi uz — r3 ' amj — NNN L E - • .. —N Off to N 1. Im 00..•N a7 f ` m0 0 1 I I 1 r a c • xp. oSsiiiiSii IZ33 ;3333333 R7= G mmmJNJJN $_ ° C'" m _ N • {-: 3 i i i i S ' ' ..g1=‘•''`cr m m m m m G O CC `m 1' 3 LL $ in LLI i �i i I l g m x m •188t y a C :� Z 0 - z - Eit i 911 ... ^5- (.,-6—' Golder Associates . (T 4. TABLE.6.3 . I TRACE METALS DETECTED IN WATER QUALITY SAMPLES »k r : ��a it r4m� ;CoIICe21tlano,,,, IDg/ a a. • ,r .::-:- ..-K;, •:"`&O•3>'' 4.9` L1C µ F :;. Nczt QI 0 Iron a.. r„ ;°°''�rirocattorl ₹ T Date. -4--• 8'_,.. it Fa;„C<2-IIIIIlIIN _ ntIb_'. ----- Manganese • Shallow Wells GWMW-1 3/27/92 <0.010 <0.0050 <0.010 <0.10 <0.010 GWMW-2 3/27/92 Gni <0.0050 <0.010 <0.10 <0.010 GWMW-3 3/25/92 <0.010 <0.0050 <0.010 <0.10 <0.010 GWMW-4 3/26/92 <0.010 <0.0050 <0.010 <0.10 owl GWMW-5 3/31/92 <0.010 <0.0050 <0.010 <0.10 n' 1 GWMW-5N 3/30/92 . 23 <0.0050 <0.010 <0.10 I-24, GWMW-5N (dup.) 3/30/92 D.M. <0.0050 <0.010 <0.10 0.24 GWMW-6 3/25/92 MT <0.0050 <0.010 <0.10 MOO GWMW-7 3/31/92 MI <0.0050 <0.010 <0.10 l}26 Deep Wells GWMW-8 3/27/92 0M11 <0.0050 <0.010 <0.10 GWMW-9 3/31/92 <0.010 <0.0050 <0.010 <0.10 offs GWMW-10 3/25/92 M <0.0050 <0.010Z GWMW-11 3/26/92 =1<4 <0.0050 <0.010 MT I88 GWMW-12 3/31/92 <0.10 �� GWMW-13 3/25/92 1,ckg <0.0050 <0.010 <0.10 GWMW-14 3/26/92 <0.010 <0.0050 <0.010 SST 00 Surface Water LF-UD 3/26/92 witfro <0.0050 <0.010 F 6 in N-Discharge 3/27/92 r6 <0.0050 <0.010 RP-Inlet 3/26/92 <0.0050 <0.010 FM 11044 QA Samples TB 3/27/92 NA NA NA NA NA FB 3/27/92 .<0.010 <0.0050 <0.010 <0.10 <0.010 MB-6D 3/30/92 <0.010 <0.0050 <0.010 <0.10 <0.010 NOTES: Detected concentrations azs shaded. NA = Not Analyzed TB = Trip Blank FB = Field Blank MB = Method Blank July 1992 913-2403 92106t. p_t 6-6-- Golder Associates i TABLE 6-4 NUTRIENTS DETECTED IN WATER QUALITY SAMPLES xx s a'c is wiiks]py'g�� ;n .w c rj.OnC.c.,54119FISZ:ID "x. giggi 100' .a Location~ ' £ Date- a inp oma:(as N r = Ntrate(as N} : Shallow Wells GWMW-1 3/27/92 <0.10 PEI GWMW-2 3/27/92 <0.10 SIS GWMW-3 3/25/92 <0.10 GWMW-4 3/26/92 <0.10 GWMW-5 3/31/92 <0.10 GWMW-5N 3/30/92 <0.10 .8::::f.4: :2 GWMW-SN (dup) 3/30/92 <0.10 Z GWMW-6 3/25/92 <0.10 GWMW-7 3/31/92 <0.10 Deep Wells GWMW-8 3/27/92 <0.10 M GWMW-9 3/31/92 1 * . <0.10 GWMW-10 3/25/92 l GWMW-11 3/26/92 GWMW-12 3/31/92 Wta GWMW-13 3/25/92 GWMW-14 3/26/92 Surface Water LF-UD 3/26/92 <0.10 ZS N-Discharge 3/27/92 <0.10 RP-Inlet 3/26/92 <0.10 If : QA Samples TB 3/27/92 NA NA FB 3/27/92 <0.10 <0.10 NOTE: Detected concentrations are shaded. NA = Not Analyzed TB = Trip Blank FB = Field Blank Laboratory blank samples were not analyzed for nutrients. - July 1992 913-2403 921964 7' - Golder Associates 7 t (- - r f' TABLE 6-5 RADIONUCLIDES AND RADIOACTIVITY DETECTED IN WATER QUALITY SAMPLES a ai` a,F .[ z ;::.Term �a. �` ' Cae*-sa anoir j' £ antic P.W. . a* �..,.._.�..,,,',j„�'„„,,.to ::,ae,� ,A e �.i� r , a a. ..R+__S ,, F C...: Y' 226 J4 �,;tenza . a.. Shallow Wells GWMW-1 3/27/92 67 50 2.0 1.9 GWMW-2 3/27/92 56 38 0.9 1.7 GWMW-3 3/25/92 180 47 7.0 6.2 GWMW-4 3/26/92 60 0.0 1.5 0.0 GWMW-5 3/31/92 19 36 0.0 1.4 GWMW-5N 3/30/92 . 90 55 1.4 0.9 GWMW-5N (dup.) 3/30/92 62 38 0.4 0.4 GWMW-6 3/25/92 64 57 1.2 0.9 GWMW-7 3/31/92 82 76 0.0 1.3 Deep Wells GWMW-8 3/27/92 38 71 ,0.4 1.0 GWMW-9 3/31/92 41 25 2.1 2.7 GWMW-10 3/25/92 49 28 2.9 3.4 GWMW-11 3/26/92 10 22 2.5 2.4 GWMW-12 3/31/92 5 1.4 1.0 0.0 GWMW-13 3/25/92 16 33 0.9 2.1 GWMW-14 3/26/92 11 17 1.1 0.2 Surface Water LF-UD 3/26/92 40 18 0.1 0.9 N-Discharge 3/27/92 15 14 0.0 0.3 RP-Inlet 3/26/92 _ 32 16 0.3 0.7 QA Samples TB j 3/27/92 NA NA NA NA FB 3/27/92 0.8 1.6 0.0 0.0 a NOTE: NA = Not Analyzed TB = Trip Blank FB = Field Blank Laboratory blank samples was not analyzed for radioactivity. July 1992 913-2403 921.06.". Golder Associates . , o \ x4 p6 � ! 30- _ tz9� r. v f A�h. �' �� :,, 1 .> ' r�I Cie��\�'q�� ,� � I 1 (� ,,1. Fe�er =3211ror1 J\C `,,11� �,�0;' t1 '— ��pK fr . & '�C �,_. \‘ . I\ 487= 5 1---- A. 1vvv r\!\ �- v \ cx�or ov �_ !1 11 Il ..-•t ��\ V ,` v' �v. , A APPROXIMATE SITE LOCATION j1 ( ( I y[Aw, \I ?, m,\ /cc, .r� � �3, It )NIyi ' \, ` �.�>� 2 `� `�4�ul�ll QpU)i t\ \i 1 ,-1 I I 41 v \\ :A147:::\ -dEE +_w1: ,i-,--._r----l-'-'7:2, -- i -T) I •, TT;O L r LA -= _... 921 _ . a e I N d `. I'N - ti 4 v �.n 1 1_ 1 ,41fl ! II*. ��\ F.% 'I gr 2 9 4y�1 `� i .� , .� rr 3 ' e Adna ; pR •E yA �l n cs _IN T .meson I! _ a , 4693 r vim, N26 p i T Y _---i----- .e-0 9 I e /rp P1'✓SY__ a / '—'�_� Daniels -,T • - • rcN - .:f Sch r• .4715 ...`9444- 4 C]*6' o 4732 • 4729 :i .�C.,. r' n V i __ - 1/ . I I \\ A 1 9 .a0 7 / 1 % o I 1TTLE >e`. GENERAL SITE LOCATION MAP Golder AI-07 Associates Denver, Colorado CLIENT/PROJECT DRAWN KAw DATE aM 1992 JOB NO. 923-2403 WASTE SERVICES CORPORATION CHECKED .1C SCALE r-2000• DWG NO./REV. NO. CENTRAL WELD SANITARY LANDFILL REVIEWED Wa-I FILE NO. FlGURE NO. 1-2 2 N 0 1 hI g I : x ‘,.. iiII Jil : 7 W eew g 1 N Q /-,// 4 r /7 ! �.),> //'-� I i'� * '`i"� 1 �I 15 11 d I� J ` 1�� + ��, ANN §' R ✓ 5 11it a •� _.0� , ill �,i ` ..h o� gill f • f ! ' " Ali t �')r6. V`n e LI NS II V - ) , ' J li t ° NR Q al O{yam---��g— , �I( EI II M ,',1/ ;= 11 - i _ _ _. ��: _` II iIB i t fI i, a I I. r 7 I I ! " 1 I h 1 r / i $. �f 7 UZ/ ! / f 7` I ( li n s 11 �', y , �/� f �� ..q i ,L, 1 !f %q b. - if; _/ r '3a } r .F, r / � �/ r. V �. • - 7 / / , fr q. / ti v' as '3'- 1 3-• 0 c. N 1 § ¢§ u § c z ; W w $ '-.;,:.!:'.41.{! i O7 ¢ ¢ NA W d rc W 3 g s € i �" —i 3 X ! I__ ;i 0 k y, t z— o . . o I y s 3v W`l __ ., i 3 a TO s$ tau,,; ::o M _ r � .s t. — —t 3 ¢ / �� s. . 1� °"° �� 3s ii 1 ri Lii y ^y za 3 43 1 �l 1 y6 .6s' ga i ) ‘-, 1 ...-1, t�.: '1 ;� Wiz! <4 405 _'��i. V= 'd I VX' i �'t, �V'Q� �'�7 1 t f,; UQN v 1 N. -- -_%1 IC, n3 ev 7 ) ../ 1 J in a � 12 � � - • 1:11 a°17 to cgi / • 7• / il, .4.1" L cif k �$ 3p y ' A A\ , z,-,0 3" ,,,, . IQ 3r'i- 3n u u Q. /) 4$06 ( I - 30 ) 29\ PS r_ 5\-' i r v . _� I ., v -JA' \ i 1 h 1% � CWSL it I 1t , , I 'Cs 1 1 V es° - ;\1 '1', I— 331v: 1\\ 1 m - ei ®, a l 0 n '\,....._ 1• I � I �o, '\ : y�r +^ #1590 u n----‘::::„._ �s �i i 1iy \V,,,��!� I II a � •c 1 �agoo • � ��i5 _ 1 v •1-4KFS�`'\\ _ -I ®#'11090 (. "� .� v 1 ,5 [ ;�, ; �' . - • 1 ' ' r u .ell '��_' 14 k r • .x4834 • \ tERS --L- '� 6s G R` rO F I a #90580® i \V 1 ', ,R 48s, R.IA. GREAT C\ 11 // : .� l.- I 4715, T nip / ' L _ — N I v Well . __- , ' I I c - se+ �os - %i / I Daniels 4ns LEGEND 1--,DITCH j;,Sch .. • \ 4732 • 4728 i sos Q �}-� J O NLN13ER OF PERIVITTED WELLS N QUARTER/QUARTER SECTION #785 WELL PERMIT NUNEER. ?cP / ® SEE TEXT FOR DISCUSSION .10 / i ( I.. ._ . TITLE PERMITTED WELLS WITH I A O Associates Denver, Colorado OPE MILE RADIUS OF THE SITE CtENT/PROJECT DRAWN KAW GATE ±111992 J°9 N0. 913-2403 L WASTE SERVICES CORPORATION r sac scfrtc rez000 bwc No./REV. NO. CENTRAL WELD SANITARY LANDFILL REVIEWED WF]I Flit NO. FIGURE NO. 2-7 6G— 4 ;i.e)6+ • 32 • • TABLE 2-4 PERMITTED WELLS DOWNGRADIENT OF THE CENTRAL WELD SANITARY LANDFILL >: tNifAtf OWNS .:> (fti . m. 77SE #765 Robert Race 263 NA D Parker, Colorado #11090 GA& MJ Shable 37 8 S Milliken, Colorado #90580 H Daniels 22 9 D Denver, Colorado Notes: NA= Data not available Usage Codes D = Domestic S =Stock Source: Colorado State Engineer, Division of Water Resources • August 1992 913-2403 92106' 33 ��T Golder Associates � 1 TABLE 6-2 REPORTING LIMITS FOR VOLATILE ORGANIC COMPOUNDS esanx' a \ UD ' a4Cccei4°ge�F�,xemuy'` 1, 2-Dichloroethane 3 ug/1 1,1-Dichloroethene 5 ug/1 1,2-Dichloropropane 5 ug/1 Methylene Chloride 5 ug/1 Tetrachloroethene 5 ug/1 Trans-1, 2-Dichloroethene (total) 3 ug/1 Trichloroethene 5 ug/1 Total Organic Carbon 1.0 mg/I NOTE: Reporting limits provided by contracted laboratory, Environmental Monitoring Laboratory, Inc. Total Organic Carbon is not strictly a volatile organic parameter. August 1992 913-2403 �7; 064 C-rLr Golder Associates ` 'J '- . �_,J"7 TABLE 6-1 REPORTING LIMITS FOR INORGANIC GROUNDWATER PARAMETERS'=It rttSriCtllltttetrta�1V10Itlf . arattniteporE�.a g 1�inu�,<< ,, 7 Alkalinity 10 mg/1 Ammonia . 0.02 mg/1 Cadmium 5 ug/1 Calcium 5 mg/1 Chemical Oxygen Demand 10 mg/1 Chloride 0.5 mg/1 Iron 100 ug/1 Lead 5 ug/1 Magnesium 0.2 ug/1 Manganese 15 ug/1 Mercury 0.2 ug/1 Nitrate/Nitrite 0.05 mg/1 Potassium 5 mg/1 Sodium 5 mg/1 Sulfate 5 mg/1 Zinc 20 ug/1 NOTE: 1) Reporting limits provided by contracted laboratory, Environmental. Monitoring Laboratory, Inc. I August 1992 913-2403 0S Golder Associates ' 6-9 ti; DEPARTMENT OF HEALTH \ 1517- 16 AVENUE COURT GREELEY,COLORADO 80631 O ADMINISTRATION (303)353-0586 HEALTH PROTECTION (303)353-0635 COMMUNITY HEALTH (303)353-0639 COLORADO . August 17, 1992 W C ion Waste Services Coo rporation W d Sanita 'LP) 60 77th Avenue Greeley, Colorado 80634 Mr. Hedberg: Our Division has received the "Hydrogeologic and Geotechnical Characterization for the Central Weld Sanitary Landfill, Weld County, Colorado", dated July 1992. We are very concerned with the results of your water quality analysis, particularly with regard to the presence of VOC's in five of the monitoring wells. We are in the process of reviewing your recommendations. We will be in contact with you upon completion of this review. Sincerely, n S. Pickle, M.S.E.H. irector, Environmental Health Division xc: Austin Buckingham, Colorado Department of Health Chuck Cunliffe, Weld County Planning Department Lee Morrison, Assistant County Attorney Brad Keirnes, Waste Services 931064 G-G- 36 DEPARTMENT OF HEALTH tt \' 1517• 18 AVENUE COURT w( It ! ' ilge GREELEY.COLORADO 80831 ADMINISTRATION(303)353-0586 HEALTH PROTECTION (303)353-0635 COMMUNITY HEALTH (303)353-0639 COLORADO October 5, 1992 Mr. Bill Hedberg Waste Services Corporation Central Weld Sanitary Landfill 6037 77th Avenue Greeley, Colorado 80634 Mr. Hedberg: This Division has reviewed your Hydrogeologic and Geotechnical Characterization for the Central Weld Sanitary Landfill, dated July, 1992. Trevor Jiricek and myself will be meeting with you on October 6, to discuss our concerns with regard to the report. At this time, we do wish to advise you that in the opinion of this Division, the findings in your report, specifically, the presence of volatile organic compounds in the offsite monitoring well, constitute a violation of section 2.1.4. of the State Solid Waste Regulations. You have been most cooperative up to the present in taking appropriate action toward mitigation and remediation of these problems. Consequently, we will suspend further legal action, pending our meeting on October 6, the results of further studies, and so long as you continue to cooperate as you have in the past. Very ly` yyoourLss,, /.. ohn S. Pickle Director, Environmental Protection Services Division xc: Lee Morrison, Assistant County Attorney Randy Gordon, M.D. , M.P.H. , Director -77 CT L� ,-ti,--t / ,,t r,4 Ifii Di b. Vlltl 6-01,ici+, e izstz i-ia:;ac ment of North America ;n::. Mountain n^gi.anIke 5 . -...O. P.-r:." ,.O,., olazo Blvd.•F..nr,i ,:oc,d . . ..dc 36111 Suite Cr:• .,^3/;?0-3324 /q October 5, 1992 Ms. Austin Buckingham Colorado Department of Health Hazardous Materials and Waste Management Division HMWMD-SWIM-B2 4300 Cherry Creek Drive South Denver CO 80222-1530 RE: CENTRAL WELD SANITARY LANDFILL CONFIRMATION GROUNDWATER SAMPLING Dear Ms. Buckingham: Enclosed for your review is the final report and summary letter from SEC/Donohue dated September 10, 1992, for the confirmation sampling event performed at Central Weld Sanitary Landfill (CWSL) . This sampling event included the Spomer pond that receives discharge from the landfill underdrain. This pond was not previously included in the sampling event performed as part of the CWSL Hydrogeologic investigation. Please contact Bill Hedberg at 1-330-2641 or Alan Scheere at 770- 3324 if you have any questions about the report. Sincerely, //YY/ Bill Hedberg Alan Scheere Division V.P. Landfill Operations Environmental Specialist • AS\mmp Enclosure cc: John Pickle, Weld County Health Department w/enc Sara Broadbent, Western Region wp51\nlbuckingham.924 F: CWSL9.1 pLo I r • _ SEC DONOHUE Environment& Infrastructure September 10, 1992 Lori Tagawa Waste Management of Colorado, Inc. 5660 Greenwood Plaza Blvd. Suite 400 Englewood, CO 80111 RE: CENTRAL WELD COUNTY SANITARY LANDFILL CONFORMATION GROUNDWATER SAMPLING Dear Lori, Enclosed for your review is the final report for the July, 1992 conformation sampling event performed at the Central Weld County Sanitary Landfill as part of the hydro-geo investigation. Sampling was conducted on July 15, 16, 17, 20 and 21, 1992 and the analysis was performed by the Waste Management, Inc. Environmental Monitoring Laboratory (EML). The results presented in the EML report confirm the original results reported by Enseco-Rocky Mountain Analytical in support of the hydro-geo investigation. Virtually all volatile compounds detected during the original sampling and Enseco analysis were confirmed and reported by the EML analysis. Compounds that were not confirmed by EML include acetone in GWMW02 which was detected just over the reporting by Enseco. EML reported no volatile compounds in GWMW02 indicating that the original value is most likely a laboratory or field contaminant. EML did not report methylene chloride in GWMW07, again indicating that the Enseco value may be from a laboratory source. The Enseco data reports the compound I,2-dichloroethene as "total" and reported a detection of this compound in wells GWMWO5 and GWMW5N: EML reports only the "trans' isomer and this was not detected in GWMW05 or GWMW5N indicating that the "total" values in the Enseco report are likely attributable to the "cis" isomer. In addition to confirming the compounds detected in the original analysis, the EML data, which generally had lower reporting limits for the volatile compounds reported additional compounds at a level that was below the Enseco reporting limit. These compounds include: 1,1 dichlorethane, tetrachloroethene and trichloroethene in GWMW04, 1,2-dichloropropane and 1,1 dichloroethane in GWMW05, 1,1-dichloroethane, (trans)1,2-dichloroethene,trichloroethene,and vinyl chloride in GWMW07, carbon sulfide in GWMW10 and trichioromethane in the Under Drain. e-c, 93106t. 37 Ms. Tagawa September 10, 1992 Page 2 Enseco did not analyze for the compound dichlorofluoromethane and EML reported this in wells GWMW04, GWMW05, GWMW5N and GWMW07 and the Under Drain. Enseco also did not analyze for the compound trichlorofluoromethane and EMI.,`reported this in well GWMW07 and / the Under Drain. A table comparing volatile compounds detected during the Enseco and EML analyses is included. During the EML analysis the compounds bromodichloromethane and chloroform were detected in field blank 01 and chloroform was detected in field blank 02. This was most likely present in the deionized water that was used as opposed to appearing from a field source. These compounds were not detected in any of the wells and the deionized water appears to have had no adverse affects on the data. Trihalomethanes (THMs) can be found in drinking water supplies as a byproduct of the treatment process. There appeared to be no significate changes in the metals or other inorganic results between the Enseco-RMAL and EML reports. Please feel free to contact me if you have any questions regarding this event. Sincerely, Randy ompson Environmental Scientist RT/rt cc: Bruce Clabaugh, WMC w/enc. CTG DETECTED VOLATILE COMPOUNDS (original RMA and confirming EML analyses) Well Compound Level-EML Level-RMA GWMW02 Acetone ND @25 ug/L 34 ug/L GWMW04 1,2-Dichloroethane OM 18 1,1-Dichloroehe ne 5 ND @5 Dichlorofluoromethane 481 NA Tetrachloroethene r -3-1 ND @5 Trichloroethene I - ND @5 GWMW05 Tetrachloroethene -2301 210 Trichloroethene '86' 70 1,2-Dichloroethene ND (trans) @6 26 (total) 1,1-Dichloroethane 201 ND @10 . 1,2-Dichloropropane -91 ND @10 Dichlorofluoromethane x6 NA I GWMW5N Tetrachloroethene 1580 140 Trichloroethene 190 7 50 1,2-Dichloroethene ND (trans) @12 17 (total) 1,1-Dichloroethane x;17 1 5.4 1,2-Dichloropropane 116--' 5.8 Dichlorofluoromethane 110 1 NA GWMW07 Tetrachloroethene '_381 9.5 Trichloroethene -5 i ND @5 1,2-Dichloroethene -9(trans) ND (total) @5 1,1-Dichloroethane 16 ND @5 1,2-Dichloroethane 16 6.1 Dichlorofluoromethane 18 NA Trichlorofluoromethane :S NA Vinyl Chloride 2 ND @10 Methylene chloride ND @3 10 GWMW10 Carbon disulfide 3 ND @5 LFUD Tetrachloroethene 5 I 5 Trichloroethene .3 , ND @5 1,1-Dichloroethane 7 7 5.4 Dichlorofluoromethane 9 NA Trichlorofluoromethane 3 NA (NA = Not analyzed, ND = Not detected) 921.06t.,* GG a n Z N i eJ < L i k cv cv rs i i2.".2, bn i o. 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'- ,r I r I ,•si •I. /W k y x1 •� /b • ^• "-• 1. ".. ¢ s \ 3 - „(. _� N. 1. OE = _ ._ y . 1 Golder Associates Inc. Golder 200 Union Boulevard,Suite 100 Golder TelLakewood.he CO USA 80228 Associates es Telephone(303)980-0540 � �.i[liC Fax(303)985-2080 - I October 23, 1992 Our Ref.: 913-2403 A RECEIVED Waste Services Corporation SANITATION DI`✓ISI0N 6037 77th Avenue Greeley, CO 80634 O C l 2 6 1992 V!Etll CHM NEU Ent 10 Attention: Mr. Bill Hedberg RE: EXPANDED HYDROGEOLOGICAL INVESTIGATION AT THE CENTRAL WELD SANITARY LANDFILL, COLORADO Dear Bill: Golder Associates Inc. (Golder) is pleased to present the results of the above-referenced project to Waste Services Corporation (WSC). Golder has completed the installation of temporary sampling points (TSPs) and collected groundwater samples for chemical analysis. The following sections provide background information, summarize field activities, and present results of the analysis. Ul 1.0 BACKGROUND Golder recently completed a hydrogeological and geotechnical investigation for the Central Weld Sanitary Landfill (CWSL) (see "Hydrogeologic and Geotechnical Characterization for the Central Weld Sanitary Landfill", Golder, 1992). Seven geotechnical borings, three shallow groundwater monitoring wells, seven deep groundwater monitoring wells, and twenty soil gas probes were installed during the field investigation portion of the investigation. The geotechnical borings, monitoring wells, and soil gas probes supplemented five shallow groundwater monitoring wells previously installed at the site. Water quality data were generated from samples collected from groundwater monitoring wells and surface water sampling points. Volatile organic compounds (VOCs) were detected in four shallow groundwater monitoring wells (GWMW-4, GWMW-5, GWMW-5N and GWMW-7) on the southern (downgradient) side of the landfill and at one surface water sampling point, the outlet of the landfill underdrain (LF-UD). Figure 1 shows the locations of sampling points where VOCs were detected and Table 1 321,4&L �� OFFICES IN AUSTRALIA.CANADA.GERMANY,HUNGARY,ITALY,SWEDEN,UNITED KINGDOM.UNITED STATES ✓ 0 M October 23, 1992 -2- 913-2403 M summarizes the results. It should be noted that VOCs were detected in GWMW-5, located A off-site approximately 20 feet south of the site boundary. WSC determined that additional investigative efforts were required to further characterize the quality of shallow groundwater downgradient of the landfill. 2.0 FIELD ACTIVITIES Field activities conducted at the CWSL as part of the expanded hydrogeologic investigation included drilling, installation of TSPs and collection of groundwater samples from the TSPs. The field program was initiated on September 21, 1992. The following sections provide a brief description of drilling operations, TSP construction, and groundwater sampling procedures. 1 2.1 Drilling Operations Drilling operations were conducted by GEO Environmental (GEO) of Golden, Colorado. GEO utilized a pickup-truck mounted Giddings drill rig for all boreholes except TSP-5. Due to difficult access to the TSP-5 location, this borehole was drilled with a small all terrain vehicle mounted hydraulic hammer rig, utilizing a 1-inch diameter drill rod. Other boreholes were drilled with 2-inch diameter solid stem flight augers. Golder field personnel supervised all drilling activities. Boreholes were drilled approximately five feet below the anticipated water table depth, based on previous site-characterization data. Auger refusal was encountered in TSP-7 and TSP-8 at depths approximately 10 feet below the anticipated water table depth. No water was encountered at these locations. A summary of final borehole depths, including water levels encountered, is provided in Table 2. All drilling and sampling equipment, including drill rods, samplers, and tools, was steam- cleaned prior to initiation of drilling activities and between boreholes. These cleaning procedures ensured that representative samples were obtained from each TSP. Nine TSPs were installed as part of this investigation (Figure 1) The TSPs were installed near the southern property line to further characterize shallow groundwater on the downgradient side of the landfill. TSP locations are summarized as follows: Temporary Sampling On-or Point. Off-Ste. Approximate Location Sting..Rationale TSP-I Ott 200'south of GWMW-5 Define extent of VOC migration detected in GWMW-5 TSP-? On 400'west of CWMW-5t4 Characterize groundwater in center of south property boundary Golder Associates 91:106!. October 23, 1992 -3- 913-2403 Ill PI — Temporary - Sampling On-or Point Off-Ste: Approximate I-manna Sting Radamle ! TSP-3 On 340'west of TSP-2 Characterize groundwater in center of south property boundary TSP-4 On 340'west of TSP-3 Characterize groundwater in center of south property boundary TSP-5 Off Center of Middle Characterize groundwater Spomer Late Dam downgradient of landfill underdrain TSP-6 On 300' southwest of GWMW-6 Characterize groundwater upgradient llof landfill underlain TSP-7 Off 22.5'south of property line,midway Characterize groundwater between TSP-2 and TSP-3 downgradient of the center of the Ilandfill TSP-8 Off 300'south of property line,midway Characterize groundwater between TSP-2 and TSP-4 downgradient of the center of the I landfill TSP-MW-5 Off 3' south of GWMW-5 Compare TSP sampling results with monitoring well sampling results I Approximate TSP locations are provided in Figure 2. IllDue to the extensive amount of data collected during Golder's 1992 hydrogeologic and geotechnical investigation, it was not necessary to collect soil samples. Accordingly, IIborehole logs were not prepared for the TSPs. i2.2 Sample Point Installation Procedures The TSPs were installed by GEO in all boreholes drilled as part of this investigation. The il GEO Expendable Aquifer Sampling Implant (EASI) was utilized for the TSPs. After the boreholes had been drilled to the desired depth, the EASI points were installed in completed boreholes. The end of the drill rod was fitted with an expendable tip and placed in the Illboreholes. One end of a 3/8-inch Teflon tube was perforated with 1/16-inch holes over a 1-foot interval. The tube was then inserted into the drill rod and attached to the Ill expendable tip. The drill rod was then removed from the borehole, exposing the perforated interval to the formation to allow groundwater to migrate into the tube. I The TSPs were completed by pouring 10-20 grit environmental grade silica sand into the borehole while agitating the 3/8-inch tube to prevent bridging. The sand was placed to a level approximately one foot below ground surface; granular bentonite was then placed from lithat point to ground surface and hydrated with deionized water. Final completion details differed between on-site and off-site TSPs. On-site TSPs were sealed with Parafilml'';Ill Golder Associates (> ay,--- 931.06'' 47 __..,m. October 23, 1992 -4- 913-2403 completed with 1-inch diameter, 5-inch long PVC tubes; and, threaded caps were placed to N protect the sampling point. Cement pads were constructed around the TSPs to prevent surface water infiltration. Locations were marked with survey stakes. Off-site TSPs were sealed with Parafilm°°° and attached to survey stakes. Figure 2 illustrates a typical "EASP" temporary sampling point. All TSP locations were surveyed by Stewart and Associates of Fort Collins, Colorado, on September 25, 1992. Ground surface and bottom of borehole elevations are provided in Table 2. 2.3 Sampling Procedures EASI TSPs are designed to be sampled without development. Groundwater samples were collected from EASI TSPs upon completion; or, in the case of low-yielding points, when sufficient groundwater was present for sample collection. As discussed in Section 2.1, Drilling Operations, auger refusal was encountered at TSP-7 and TSP-8 prior to encountering the water table; no samples were collected from these points. Groundwater samples were collected from the TSPs utilizing a peristaltic pump attached to the 3/8-inch diameter tube, or alternatively, to a 3/16-inch diameter tube threaded down the larger tube. The alternative methodology was utilized when water levels were deeper than 20 feet or the water contained a large percentage of silt. In those instances, the peristaltic pump was not capable of creating sufficient vacuum to extract a sample. The 3-16-inch tube, unperforated, could be inserted into the larger tube directly to the water level, allowing the pump to extract a sample. Groundwater samples were collected in 20-milliliter (ml) volatile organic analysis (VOA) vials. The vials were immediately labelled and placed on ice in coolers for preservation. Strict chain-of-custody procedures were followed, and the samples were delivered to Phoenix Analytical Laboratories (Phoenix) for chemical analysis. Copies of chain-of-custody forms are included in the attachments. The samples were analyzed using EPA Method 8240 for the following parameters: ► Vinyl Chloride; ► 1,1-Dichloroethene; ► 1,1-Dichloroethane; ► trans-1,2-Dichloroethene; ► cis-1,2-D ich loroethene; ► 1,2-Dichloroethane; ► 1,2-Dichioropropane; / Golder Associates `o 31.06-* AL [TL I October 23, 1992 -5- 913-2403 N ► Trichloroethene; and, ► Tetrachloroethane. The analytes include the six VOCs detected in the downgradient monitoring wells during the initial investigation, with the addition of vinyl chloride, a degradation product of the trichloroethene and tetrachloroethane series (see Table 1). It should be noted that trans-1,2- Dichloroethene and cis-1,2-Dichloroethene results provided by Phoenix have been presented in Table 3 in a combined format as 1,2-Dichloroethene. This presentation format is consistent with the manner in which the initial investigative results were presented (see Golder, 1992). 3.0 RESULTS Results of chemical analysis of the groundwater samples are presented in Table 3. Copies of the Phoenix reports are included in the attachments. No target compounds were detected in the TSPs, with the exception of the confirmatory TSP-MW-5. Results indicate that VOC impacts to shallow groundwater on the south side of the landfill are limited to the immediate area of the landfill. A comparison of TSP-MW-5 results with GWMW-5 results is provided in Table 4. It should be noted that GWMW-5 results presented in Table 4 are from the sampling round conducted as a part of the initial hydrogeologic study. The comparison shows that the same compounds were detected in both sample points, although at slightly different concentrations. The slight differences in concentrations between the two sampling rounds could be the result of using different analytical laboratories. Additionally, the TSP drilling and sampling methodology may enhance volatilization of targeted compounds. The comparison indicates that the TSPs are a useful means of obtaining qualitative groundwater quality information for the site. 4.0 CONCLUSIONS Results of the expanded hydrogeologic study, combined with results of the initial investigation, suggest that the occurrence of VOCs in the shallow groundwater is isolated to particular areas. Elevated concentrations of VOCs were detected during the initial investigation in the southeast and southwest corners of the landfill. VOCs were not detected in the center of the south side of the landfill VOCs were also not detected in off-site sampling points, with the exception of the GWMW-5 and TSP-MW-5 locations. The isolated occurrences of VOCs may be the result of different types of waste disposed in these areas. I Golder Associates P Pg October 23, 1992 -6- 913-2403 I The 1992 initial hydrogeologic investigation concluded that the nearest permitted PIdowngradient groundwater well is approximately 2,000 feet from the landfill. Detection of offsite VOC migration in the shallow groundwater was limited to very low levels in TSP-MW-5 which was located approximately 23 feet south of the site boundary and immediately downgradient of GWMW-5. TSP-1, which was located about 200 feet further south, showed no VOC contamination. Accordingly, no water well users are being impacted by volatile organic compounds originating from the landfill. Any questions concerning the content of this report should be directed to the undersigned. Sincerely, GOLDER ASSOCIATES INC. 4, Christopher E. Rife Engineer Technician e Ward E. Herst, PG, CEM I� Senior Hydrogeologist �1 CER/WEH/smp N I I I I I Golder Associates 9.31064 ...�. TABLE 1 SUMMARY OF VOLATILE ORGANIC COMPOUNDS DETECTED AT DOWNGRADIENT SAMPLING POINTS tSAMI? ING4 a : i ,S 1 'GOMPOCANIXCONCENTR.TtONSIN4ridi &' �'•q-kin " y "acx IN a r �F`.> :itt-I3Cira�'�P "wtz4.C�i `Sc .a.' —DFeE:`.n SDcp.gap1r lE'cstr:pC. ,".£5A' GWMW-4 <0.005 0.018 <0.005 <0.005 . <0.005 <0.005 GWMW-5 <0.01 <0.01 0.026 <0.01 0.070 0.210 GWMW-5N 0.0054 <0.005 0.017 0.0058 0.050 0.140 GWMW-7 <0.005 0.0061 <0.005 <0.005 <0.005 0.0095 LF-UD 0.005 <0.005 <0.005 <0.005 <0.005 0.005 NOTES: (1) Below Detection Limit = BDL (2) 1,1 — DCA = 1,1—Dichloroethane 1,2— DCA = 1,2—Dichloroethane 1,2 — DCE = 1,2—Oichloroethene 1,2 — DCP = 1,2—Dichioropropane TCE= Trichloroethene PCE = Tetrachloroethane I I I I I I October 1992 913-2403 Golder Associates 9'A LL oa+ + + oui0.02 wogs tt I S Nod x � ` t l J If // -�i C, TT Fn og v K +\ 1� ' \ -.'3\' \L\ •\\ I ii:,-;-...-„7---,e_ __,- -,-(.6,, c '7, \cc-- rc;7:: \ , 73fre ‘A-N\-\, f iA 1;1 0 t11( 4- min *I- V —2::-i I �. � fir' /}21/ \ �. ) � 1 III _ Nv r. \ \,Th„::,,,,k,\, \ N ...... , J ,„-= = _ ._ N --- -A: / r -ft't-crt .,- '- \I CC-!)) \II il ..< 1/4 , \17 I --„c,<_%.*--,---)\_„---Ii \ f \L -,‘ ‘, ,, 4 ��:. ; \� \ , % E.1 ,--.4/117 ,, pe\ \ \ Iv, >'1`\off\�c,\) /j �I \\‘ t it // if- ek - 9 , J li -\\ --A :: , I m.. n i Cr} aJr U DEPARTMENT OF HEALTH \ \ 1517•18 AVENUE COURT lung GREELEY,COLORADO 80631 e ADMINISTRATION(303)353-0586 HEALTH PROTECTION(303)45'L0R95 COMMUNITY HEALTH(303)3530639 COLORADO February 22, 1993 William J. Hedberg Waste Services Corporation 6037 77th Avenue Greeley, Colorado 80634 Dear Mr. Hedberg: The Environmental Protection Division of the Weld County Health Department has received the "Preliminary Design, Operations, and Closure Plan", Central Weld Sanitary Landfill, Weld County, Colorado. Initial review has revealed the document to be incomplete as submitted. Page 4- 1, Section 4.0, refers to a series of sheets (Nos. 1 through 20) which have not been provided as part of the document. The Division has ceased review of this document pending receipt of all necessary doucments. In addition, the Division requests that the term "preliminary" be defined as it occurs in the document title. If you have any question, you may contact me at (303) 353-0635. Sincerely, i ohn S. Pickle, M.S.E.H. Director, Environmental Protection Services TJ-359 cc: Alan Scheere, Waste Management of North America, Inc. Roger Doak, Colorado Department of Health Lee Morrison, Assistant Weld County Attorney Chuck Cunliffe, Weld County Planning Department GCS— i P 30-20-102 Government-County 30-20-102. Unlawful to operate site and facility without certificate of des{g 4 nation. (I) Except as provided in subsection (2) of this section, it is unlawful i for any person to operate a solid wastes disposal site and facility in the unin. corporated portion of any county without first having obtained therefor a certificate of designation from the board of county commissioners of the county in which such site and facility is located. (2) Any site and facility for the disposal of mill tailings, metallurgical slag, d. mining wastes, junk automobiles or parts thereof, or suspended solids coo lected, treated, or disposed of within a sanitary sewer system in operatioq i immediately prior to July 1, 1971, shall have until July I, 1972, to comply with the provisions of this part 1 and the rules and regulations adopted by +G 5 ik the department. ;, I: (3) The final use for beneficial purposes, including fertilizer, Spar,„;; conditioner, fuel, and livestock feed, of sludge which has been processed . and certified or designated as meeting all applicable regulations of the department and the department of agriculture shall not require a certificate of designation for such final use. Source: L. 67, p. 759, § 2; CRS 1963, § 36-23-2; L. 71, p. 341, § 3; L. 76, p. 694, § 1. 4 30-20-103. Application for certificate. Any person desiring to operate a solid wastes disposal site and facility within the unincorporated portion of -.,. any county shall make application to the board of county commissioners of , the county in which such site and facility is or is proposed to be located Ay?, for a certificate of designation. Such application shall be accompanied by V a fee of twenty-five dollars which shall not be refundable, and it shall set ,. forth the location of the site and facility; the type of site and facility; the type of processing to be used, such as sanitary landfill, composting. or incineration; the hours of operation; the method of supervision; the rates to be charged, if any; and such other information as may be required by the ,,:/.. board of county commissioners. The application shall also contain such ergi,,ff4 veering, geological, hydrological, and operational data as may be required by the department by regulation. The application shall be referred to the y, « department for review and for recommendation as to approval or disapproval. 1 which shall be based upon criteria established by the state board of health, the water quality control commission, and the air pollution control commis 't,,„--4. sion. Source: L. 67, p. 759, §.3; C.R.S. 1963, § 36-23-3;L. 71, p. 341,§A.,,,, 30-20-104. Factors to be considered. (I) In considering an application sae -, a certificate of designation, the board of county commissioners shall tale ,k s . into account: (a) The effect that the solid wastes disposal site and facility wall Aare °, - on the surrounding property, taking into consideration the types of prooesl to be used, surrounding property uses and values, and wind andcro t; conditions; *�''` r (b) The convenience and accessibility of the solid wastes disposal r. facility to potential users; it e. ,. Wa r w5+x',' y - Ct'4 ;w, ' . I, t Y i� h ! 1,^ pR .p~ �` F eF 1 �. B' A : ., tY + £ it , . I. ,,. . � ;14:41/31,1:1P ye ° P IIY w 1.M11 n a•. .t to-�U-102 ,.,. , ',WI 1. µfie . C t id,,7@ ts r.441,:;',, � , tty_0-10: I ni:rs.iai urcau '',it, and taudl, without ctrtiti, u, of ,des. s;r t' nation. (I) I.s , t ,i, rite+ iii I ,.::uun ) t this cut :[ .� anlaaiW t 41... :a r VI°•. for any per,on t ,,p.22 II r a ,.,ridwastes di,pos:., site and t redo,, in the un- m,, ,t ,' _orporated pOrtiOil CI . us c Quote rithout h'st havit obtained therefor a . . �.iiti Opt,. :ertifieate „f fes _nau° n rum the board Of ounty commissioners of the s"Li tt" t. 11 f r ,�. ,` county in which such site and t urhR is lucatc.d u �` t :- :-Eli�., t2) An} site and fag Iity for the disposal of nil tailin , metallurgical slag _ s ,3,. f. mining waste, junk automobile', or parts thereof, or suspended solids col. 1844-•.-;3•:491y•-.9 y_ `5: art','! . Iected, treated, or disposed of within a sanitary sewer system in uperatiop ;! p ' �'- immediately prior to July I, 1971, shall hake until July I. 1972, to comply ,, ,Ti j t ' with the.provisions of this part I and the rules and regulations adopted by t ki, ci ' t1` ' the department a a� i.4 f.) The final use for henel col purposes, including fertilizer, sod r • r conditioner. fue and uvestock t e of sludge which has been processed +to$;:Eig k r and certified or designated as meeting all applicable regulations of the I,w , _ department and the department r f Agriculture shall not require a certificaL ',ar•1 Tel,:€' i of designation for such final use- '§'i.ia> .` eyv Jes, Source t.. 67. p. 759, § 2: C.R.S. 196;, § 36-23-2: I.. 71, p. 341. 53_ 1^ <',w, , I.. 76, p. n94. § i. T r .1 YtY 4 B , ItiE, _ w. .. °,;:! ..,..1,6:74,':;,:,..? 3(h20-103. Application for certificate. Any person desiring to operate a "- .s Y n v , a'f E, solid wastes disposal site and futility within the unincorporated portion .l n p�`. �'a4 §', any county shall make application to the board of county commissioners of vxi . �{ the count), in which such site and facility is or is proposed to be located O1,-•;1;-•; , 't for a certificate of designation. Such application shall he accompanied hs • k a fee of twent ' five dollars which shall not be refundable. and it ,hail .c: 5 r,rt forth the location of the site and facility: the type of site and taealrty: the 'trip'� - type of processing to he used. such as sanitary landfill, composting. or rt f.. incineration: the hours of operation: the method of supervtsru❑ the rise, to .� t'Sk 'Y- `! be charged, if any: and such other information as may he required by the ax. .t); board of county commissioners. The application shall also contain such enip m ; �, neering, geological. hydrological. and operational data as may be required t# F ,„....c.....11-1/,14 :200.4.i*" i�, ; by the department by regulation. The application shall he referred to the department for resiew and for recommendation as to approval or disapprosal which shall he based upon criteria established by the state board of health. tha• ' t. the water quality control commission, and the air pollution control commis- ;.. iv h sion. .,. . t "!';'4-i'?.L i � Source: L. 67, p. 759, §.i, C.R.S. 1963. § 36-23-3: L. 7I, p. 341. § 4. r; 30-20-104. Factors to be considered. (1) In considering an application foe .- _ q t. 1— a certificate of designation. the board of county commissioners shall take y. F into account: ;, a t t '.. (a) The effect that the solid wastes disposal site and facility will bast s , rocessttt� t` on the surrounding property, taking into consideration the types of p a ; 4];...•-:;;-..,, '' to be used. surrounding property uses and values, and wind and climax 1s tl1 , ,, conditions; < «ai��r k' "`ri* (b) The convenience and accessibility of the solid wastes disposal site rail ., ; ;Th . ls. '.,`('. facility to potential users: ::::1:1,k: .r 1z. — t Z yt a a5 '0.:.:17...l i - s t Waste Management of North America,Inc. NCIMountain Region V 5660 Greenwood Plaza Blvd.•Englewood,Colorado 80111 - S `: , Suite 424•303/770-3324 C5Cf1:;2. - . . November 16, 1992 `\� iO % ti; •:\ '\jam Mr. Trevor Jiricek ..t4 u Weld County Department of Health 1517-16 Avenue Court Greeley CO 80631 RE: CENTRAL WELD SANITARY LANDFILL DISCHARGE PERMIT APPLICATION. Dear Mr. Jiricek; . Per your request, this letter will confirm our phone conversation on November 13, 1992, concerning the discharge permit application for the Central Weld Sanitary Landfill (CWSL). As discussed CWSL intends to submit the application to the appropriate agency no later than November 30, 1992. Please call me at 770-3324 or Bill Hedberg at 332-2641 if you have any questions. Sincerely, l/fJ`� "_\ (CC-kt Alan Scheere Environmental Specialist AS/mmp • • vp511u\jiricctl 1.16 F:CWSL Ll /r-0vote )• /t Ca " ( w • -a r• . STATE OF COLORADO COLORADO DEPARTMENT OF HEALTH Dedicated to protecting and improving the health and ✓ environment of the people of Colorado : V4 ; 4300 Cheny Creek Dr.S. Laboratory Building Denver,Colorado 80222-1530 4210 E.11th Avenue Phone(303)692-2000 Denver,Colorado 80220-3716 (303)691.4700 Roy ROMS' November 17, 1992 Pat,ta&Ndar.MO.mm Executive&hector Alan Scheere, Environmental Specialist Waste Management of North America, Inc. Rocky Mnt. Satellite Office, Western Region 5660 Greenwood Plaza Blvd. , Suite 400 Englewood, Colorado 80111 CERTIFIED MAIL P 440 450 128 RE: Central Weld Sanitary Landfill (CWSL) , Surface Discharge. Dear Alan: . The Weld County Health Personnel brought to my attention that there is a surface discharge from the Central Weld Landfill into a Spomer Lake. This lake eventually discharges into the Big Thompson River. During my site inspection on November 6, 1992 I verified that un under drain perforated pipe, that runs under the landfill, discharges into Spomer Lake. Also, there is a surface drain ditch and under drain french pipe beneath the drainage ditch that eventually discharge into the Big Thompson River. These discharges constitute point sources and both needed to be permitted. However, it is my understanding that your company is in the process of finalizing an engineering study and that an application for a discharge permit (which will include both sources) will be submitted in the next 10 days. If you anticipate any change from your schedule, please contact Patricia Nelson at (303) 692-3608 or me at (303) 692-3564 If you have any other questions, please call me. Sincerely, FOR DIRECTOR, WATER QUALITY CONTROL DIVISION tor' . Sain P.E. District Engier Field Support Section cc: Weld County Health Department Permits and Enforcement Environmental Protection Agency, Region VIII :i i05'-14- 7 r SECTION 2 MINIMUM STANDARDS 2.1 Minimum standards All facilities for solid waste disposal shall comply with the following minimum standards of the act: 2.1.1 Such sites and facilities shall be located, operated, and maintained in a manner so as co control obnoxious odors and prevent rodent and insect breeding and infestation, and they shall be kept adequately covered during their use. 2.1.2 Such sites and facilities shall comply with the health laws, standards, rules, and regulations of the department, the Water Quality Control Commission, the Air Quality Control Commission, and all applicable zoning laws and ordinances. 2.1.3 No radioactive materials or materials contaminated Sy radioactive substances shall be disposed of in sites or facilities not specifically designated for that purpose. 2.1.4 A site and facility operated as a sanitary landfill shall provide means of finally disposing of solid wastes on land in a manner to minimize nuisance conditions such as odors, windblown debris, insects, rodents, and smoke; shall provide compacted fill material; shall provide adequate cover with suitable material and surface drainage designated to prevent ponding of water and wind erosion and prevent water and air pollution; and, upon being filled, shall be left in a condition of:orderliness and good esthetic appearance and capable of blending with the surrounding area. In the operation of such a site and facility, the solid wastes shall be distributed in • the smallest area consistent with handling traffic to be unloaded; shall be placed in the most dense volume practicable using moisture and compaction or other method approved by the department; shall be fire, insect, and rodent resistant through the application of an adequate layer or inert material at regular intervals; and shall have a minimum of windblown debris which shall be collected regularly and placed into the fill. 2.1.5 Sites and facilities shall be adequately fenced so as co prevent waste material and debris from escaping therefrom, and material and debris shall not be allowed to accumulate along the fence line. 2.1.6 Solid wastes deposited at any site/or facility shall not be burned, other than by incineration in accordance with a certificate of designation issued pursuant co section 30-20-105; except that, in extreme emergencies resulting in the generation of large quantities of combustible materials, authorization for burning under controlled conditions may be given by the department. 2.1.7 Any provision of the 'Air Pollution Control Act' , Title 25, Article 7, section 108, CRS 1973 as amended, to the contrary notwithstanding, the board of county commissioners in any county with less than twenty-five thousand (25,000) population, according co the latest federal census, is authorized co develop regulations, by resolution, permitting the noncommercial burning • (10) Revised 8/90 • 4 106 6-6" dl4 r .;*, `� Pr't:r °is"m:`..'ti�dL%-`n1 a h''tit S. rt".$� ' `� ? f8241:40,S�ta -°4 .., ., J'"'- ?',ir`.' 4=4r ++ 'sPin.. an ₹ 304 30` Nl:iterQuaiii'/ Control n5-B-3U i i der, or determination by a temporary restraining order or injunction at the request of the commission Tined to classification of or division. 2 management plans, water egulations, enforcement Source: ;2 & RE, L. 81, p. 1325. § '. 1 shall be subject to Judi- s article and article 4 of Formal party status is not prerequisite to Frederick v. Colorado Water Quaiit Control t terminations of the corn- right of judicial review under section 224-1-IO, Comm n, Colo. App. _ , h28 P 2d 129 i or issued in accordance (4), and by analogy. under subsections(l) and '1980). (2) of this ection. so long as the concerned Applied in Colorado Water P pp Quality Coruna . plaintiff can shew that It is adversely affected Comm'n v. Town of Frederick. Colo. I al order or determination or aggrieved by ar,v agency action. Town of _,641 P.2d 958(1982) trier court for the district 25-8-405. Samples, secret processes. (1) If samples of water or water rule, order, or deferral- pollutants are taken for analysis and a violation of any permit or control rein).- within thirty days after lation is suspected, a representative portion of the sample shall be furnished s Rulemaking determina- upon request to the person who is believed to be responsible for such sus- co_ Administrative Price- petted violation. A representative portion of such sample shall be furnished ;wile final upon issuance - i to any suspected violator whenever any remedial action is taken with respect eedings. The period for thereto by the division. A duplicate of every analytical report pertaining to hue any application for such sample shall also be furnished as soon as practicable to such person. • tie pursuant to section (2) Any information relating to any secret process, method of manufac- j >hcation is pending shall hire or production, or sales or marketing data which may be acquired, ascer review an equal length tamed, or discovered, whether in any sampling investigation, emergency I li 1 investigation, or otherwise, shall not be publicly disclosed by any member. lets issued pursuant to officer, or employee of the commission or the division, but shall be kept d desist order, clean-up i confidential. Any person seeking to invoke the protection of this subsection sion or commission, or (2) shall bear the burden of proving its applicability. This section shall never be interpreted as preventing full disclosure of effluent data. _ie, may petition the dis- order or determination. rich the pollution source ' Source: R &RE, L. 81, p. 1326, § 1. i order or determination I i order or determination PART 5 1 w ;re is probable cause to ,, PERMIT SYSTEM a harm to the affected y 25-8-501. Permits required for discharge of pollutants - administration. (1) i; No person shall discharge any pollutant into any state water from a point the order or determina- '"e ue, any harmful effects ''xI source without first having obtained a permit from the division for such dis- charge, and no person shall discharge into a ditch or man-made conveyance essation of the violation =_,y for the purpose of evading the requirement to obtain a permit under this arti- cle. Each application for a permit duly filed under the federal act shall be vithout sufficient corre- deemed to be a permit application filed under this article, and each permit .447.:. issued pursuant to the federal act shall be deemed to be a temporary permit he case to the division issued under this article which shall expire upon expiration of the federal F tie purpose of adducing ;. r- permit. iings thereon; but such (2) The division shall examine applications for and may issue, suspend, o adduce such evidence revoke, modify, deny, and otherwise administer permits for the discharge : of pollutants into state waters. Such administration shall be in accordance an order of the commis- with the provisions of this article and regulations promulgated by the commis- l ith that order by issuing Sion. a line eras_ r 304 305 Water Quality Control 25-8-501 tie, order, or determination by a temporary restraining order or injunction at the request of the commission not limited to classification of or division. ment management plans, water ntrol regulations, enforcement Source: R&RE, L. 81, p. 1325, § 1. lyders, shall be subject to judi- of this article and article 4 of Found party status is not prerequisite to Frederick v. Colorado Water Quality Control and determinations of the com- right of judicial review under section 21-4106 Conun'n, _Colo. App._,628 P.2d 129 ;aced, or issued in accordance (4),and by analogy,under subsections(1)and (1980). y (2) of this section, so long as the concerned Applied in Colorado Water Quality Control t plaintiff can show that it is adversely affected Comm'n v. Town of Frederick, _ Colo. ny final order or determination or aggrieved by any agency action. Town of _,641 P.2d 958(1982). he district court for the district I, 25-8-405. Samples, secret processes. (1) If samples of water or water 1 ny final rule, order, or determi- pollutants are taken for analysis and a violation of any permit or control regu- i filed within thirty days after lation is suspected, a representative portion of the sample shall be furnished final. Rulemaking determina- • upon request to the person who is believed to be responsible for such sus- e "State Administrative Proce- petted violation. A representative portion of such sample shall be furnished II become final upon issuance to any suspected violator whenever any remedial action is taken with respect e proceedings. The period for thereto by the division. A duplicate of every analytical report pertaining to ayed while any application for such sample shall also be furnished as soon as practicable to such person. pending pursuant to section (2) Any information relating to any secret process, method of manufac- ch application is pending shall ture or production, or sales or marketing data which may be acquired, ascer- ndicial review an equal length tained, or discovered, whether in any sampling investigation, emergency investigation, or otherwise, shall not be publicly disclosed by any member, :y orders issued pursuant to officer, or employee of the commission or the division, but shall be kept se and desist order, clean-up confidential. Any person seeking to invoke the protection of this subsection e division or commission, or (2) shall bear the burden of proving its applicability. This section shall never ' en made, may petition the dis- be interpreted as preventing full disclosure of effluent data. such order or determination. t in which the pollution source Source:R&RE, L. 81, p. 1326, § 1. y such order or determination PART 5 1 such order or determination t if there is probable cause to PERMIT SYSTEM serious harm to the affected I 25.8.501. Permits required for discharge of pollutants - administration. (1) which the order or determina- 4 No person shall discharge any pollutant into any state water from a point source without first having obtained a permit from the division for such dis- continue, any harmful effects r the cessation of the violation charge, and no person shall discharge into a ditch or man-made conveyance for the purpose of evading the requirement to obtain a permit under this arti- cle. Each application for a permit duly filed under the federal act shall be I be without sufficient cone- • deemed to be a permit application filed under this article, and each permit issued pursuant to the federal act shall be deemed to be a temporary permit i land the case to the division issued under this article which shall expire upon expiration of the federal for the purpose of adducing permit. ' 4 findings thereon; but such (2) The division shall examine applications for and may issue, suspend, ilure to adduce such evidence revoke. modify, deny, and otherwise administer permits for the discharge n, of pollutants into state waters. Such administration shall be in accordance ess of an order of the commis- with the provisions of this article and regulations promulgated by the commis- nice with that order by issuing sion. L.3.2 Sites for new sanitary landfills shall comply with standards of sections 4.1 and 4.2 unless compliance with the standards is waived by the department in accordance with section 1. 3.8 of these regulations. 1.3.3 The construction, operation and closure of all new facilities Eor solid waste disposal shall comply with designs, specifications and procedures outlined in the certificate of designation application, as amended by department review and local requirements; and with the standards in sections 2.1 through 2.4 and 3.1 through 4.8 of these department regulations. 1.3.4 The construction, operation and closure of all approved facilities for solid waste disposal that were granted a certificate of designation before there were requirements for an engineering design and operations report or that are in operation on the effective dace of these department regulations, shall comply with standards in section 2.1 through 2.4 of these department regulations. 1.3.5 Approved facilities for solid wastes disposal chat are exempted from certificate of designation requirements under provisions of section 1.4 of these department regulations shall comply with standards in section 2.1 through 2.4 of these regulations, unless permitted or operated in compliance with regulations pursuant co the "Colorado Mined Land Reclamation Act", Title 34, Article 32, Section 101, ec sea. , CRS 1973, as amended; or the "Hazardous Waste Act", Title 25 , Article 15, Parts 1, 2, and 3, CRS 1973, as amended. 1.3.6 Technical guidelines, including specific technical factors, may be developed and issued by the department to assist applicants, local • governments, and the public. 1.3.7 An amended application shall be made for a substantial change in operations as defined in section 1.2 of these regulations, and shall be referred to the county board of commissioners and the department for review and approval before such change shall become effective. 1.3.8 In its consideration of an application, and in the exercise of its regulatory authority to assure compliance with these regulations, the department and county of jurisdiction may waive compliance with any standard in section 2.2, 2.4, 4.1, 4.2, 6, 8. 9, 10. 11 and 12 provided that: (a) The benefits derived from meeting a standard do not bear a reasonable relationship to the economic, environmental, and energy impacts or other factors which are particular to the facility; or (b) Such waiver is consistent with the purposes of the act and these regulations; and (c) Such waiver is not deemed to constitute a material variation from the requirements of these regulations; and (d) The waiver will not cause or allow the violation of any air or water quality standard. 1.3.9 A concise general statement of the basis and purpose for these regulations has been prepared and adopted by the board of health, and hereby incorporated into these department regulations by reference, • pursuant to the "Colorado Administrative Procedures Act" , Title 24, Article 4, section 103, C.R.S 1971, as amended. (8) (1"7,4 CU! Revised 8/90 ? SECTION 2 MINIMUM STANDARDS -. 1 Minimum standards All facilities for solid waste disposal shall comply with � the following minimum standards of the act: :�, 2.1.1 Such sites and facilities shall be located, operated, and maintained in a manner so as co control obnoxious odors and prevent rodent and insect breeding and infestation, and they shall be kept adequately covered during their use. 2.1.2 Such sites and facilities shall comply with the health laws, standards, rules, and regulations of the department, the Water • Quality Control Commission, the Air Quality Control Commission, and all applicable zoning laws and ordinances. 2.1.3 No radioactive materials or materials contaminated by radioactive substances shall be disposed of in sites or facilities not specifically designated for that purpose. 2.1.4 A site and facility operated as a sanitary landfill shall provide means of finally disposing of solid wastes on land in a manner co minimize nuisance conditions such as odors, windblown debris, insects, rodents, and smoke; shall provide compacted fill material; shall provide adequate cover with suitable material and surface drainage designated to prevent ponding of water and wind erosion and prevent water and air pollution; and, upon being filled, shall be left in a condition oftorderliness and good esthetic appearance and capable of blending with the surrounding area. In the operation of such a site and facility, the solid wastes shall be distributed in • the smallest area consistent with handling traffic to be unloaded; shall be placed in the most dense volume practicable using moisture and compaction or other method approved by the department; shall be fire, insect, and rodent resistant through the application of an adequate layer or inert material at regular intervals; and shall have a minimum of windblown debris which shall be collected regularly and placed into the fill. 2. 1.5 Sites and facilities shall be adequately fenced so as co prevent waste material and debris from escaping therefrom, and material and debris shall not be allowed to accumulate along the fence line. 2.1.6 Solid wastes deposited at any site/or facility shall not be burned, other than by incineration in accordance with a certificate of designation issued pursuant co section 30-20-105; except that, in extreme emergencies resulting in the generation of large quantities of combustible materials, authorization for burning under controlled conditions may be given by the department. 2.1.7 Any provision of the "Air Pollution Control Act", Title 25, Article 7, section 108, CRS 1973 as amended, to the contrary notwithstanding. the board of county commissioners in any county with less than twenty-five thousand (25,000) population, according co the latest federal census, is authorized to develop regulations, by resolution, permitting the noncommercial burning • #(10) Revised 8/90 rs'candardsarawaived • f trash in the unincorporated area of said county; except chat no ermit shall be issued which shall allow the county co exceed primary nd secondary ambient air quality standards as prescribed by federal aws and regulations adopted pursuant thereto. s used in subsection 2.1.7 of this section, "noncommercial burning of trash" includes the burning of wood waste in wigwam wood waste urners. standards All facilities for solid waste disposal shall be operated nce with the following standards, where applicable, unless said are waived in accordance with section 1.3.8 of these department s:Facilities for solid waste disposal shall be kept adequately fenced to prevent unauthorized public access without operator supervision. 2.2.2 Surface waters shall be diverted from, or around, the disposal site and facility and its working face. 2.2.3 Groundwater quality shall be monitored upgradient and downgradient of facilities for solid waste disposal when final disposal or liquid evaporative treatment is performed. Depth and locations of monitoring wells co be determined after considering the hydrogeology of the site. (a) Quarterly groundwater sampling and analysis must be performed for the following parameters unless additional or fewer constituents or frequency of testing have been specified by the Department for the facility operating plan or if the Department specifies based on leachate analysis, waste composition or other information. ( • (1) temperature (2) conductivity (3) pH (4) chloride (5) nitrate, nitrite, and ammonia as nitrogen (6) sulfate (7) dissolved iron, cadmium, lead and mercury (8) dissolved zinc and manganese (9) total alkalinity (10) chemical oxygen demand (11) total organic carbon (12) calcium, sodium, potassium and magnesium (b) Test methods used for groundwater analysis shall be according to— EPA Publication SW-846 "Test Methods for Evaluating Solid Waste ysical/Chemical Methods" or an EPA approved method. (c) The owner or operator shall use the Cochran's Appro 0 the Benrens-Fisher Student's T-test as described in Appendix IV of part 264 of the RCRA Hazardous Waste Regulations or a statistical procedure approved by the Department in the groundwater monitoring plan for determining whether a significant change over background has occurred. 2.2.4 All groundwater and explosive gas monitoring points shall be installed in accordance with applicable rules and regulations of the "Water Well and Pump Installation Contractor's Act", Title 37, Article 91, Part 1, CRS 1973 as amended, and the water quality and gas concentrations of samples taken from the wells shall be determined by the facility operator. /61;7,- (11) ,� e. Lo Revised 8/90 �3 I- SECTION 3 APPLICATION FOR CERTIFICATE OF DESIGNATION • . 1 Application for a certificate of designation for new facilities for solid waste disposal 3. 1.1 Any person proposing co operate a facility for solid wastes disposal within the unincorporated portion of any county shall apply to the commissioners of the county in which the site is to be located for a certificate of designation. 3.1.2 The application shall include a nonrefundable three hundred dollar ($300) fee and at least five (5) copies or as many additional copies as specified by local requirements, of an engineering design and operations report prepared in accordance with sections 3.1 through 4.8 of these regulations, unless the proposed solid waste disposal facility is a privately operated solid waste-co-energy incineration facility not under contract to a county and/or municipality or is a solid waste incineration facility, in which case sections 3.1 and 10.2 through 10.5 shall apply. The application shall also include all other documents specified by local requirements. 3.1.3 After receipt of an application, the commissioners shall forward copies of the application and at least four copies of the engineering design and operations report to the department for review and a recommendation for approval or disapproval. 3.1.4 Recommendations on certificate of designation applications, including the engineering design and operations report, shall be based upon compliance with the act and these department regulations. • Revised 8/90 (14) 6161- r SECTION 2 MINIMUM STANDARDS /Minimum standards All facilities for solid waste disposal shall comply with the following minimum standards of the act: . 2.1. 1 Such sites and facilities shall be located, operated, and maintained in a manner so as to control obnoxious odors and prevent rodent and insect breeding and infestation, and they shall be kept adequately covered during their use. 2.1.2 Such sites and facilities shall comply with the health laws, standards, rules, and regulations of the department, the Uacer Quality Control Commission, the Air Quality Control Commission, and all applicable zoning laws and ordinances. 2.1.3 No radioactive materials or materials contaminated 5y radioactive substances shall be disposed of in sites or facilities not specifically designated for that purpose. 2.1.4 A site and facility operated as a sanitary landfill shall provide means of finally disposing of solid wastes on land in a manner co minimize nuisance conditions such as odors, windblown debris, insects, rodents, and smoke; shall provide compacted fill material; shall provide adequate cover with suitable material and surface drainage designated to prevent ponding of water and wind erosion and prevent water and air pollution; and, upon being filled, shall be left in a condition ofcorderliness and good esthetic appearance and capable of blending with the surrounding area. In the operation of such a site and facility, the solid wastes shall be distributed in . the smallest area consistent with handling traffic co be unloaded; shall be placed in the most dense volume practicable using moisture and compaction or other method approved by the department; shall be fire, insect, and rodent resistant through the application of an adequate layer or inert material at regular intervals; and shall have a minimum of windblown debris which shall be collected regularly and placed into the fill. 2.1.5 Sites and facilities shall be adequately fenced so as to prevent waste material and debris from escaping therefrom, and material and debris shall not be allowed to accumulate along the fence line. 2.1.6 Solid wastes deposited at any site/or facility shall not be burned, other than by incineration in accordance with a certificate of designation issued pursuant to section 30-20-105; except chat, in extreme emergencies resulting in the generation of large quantities of combustible materials, authorization for burning under controlled conditions may be given by the department. 2.1.7 Amy provision of the "Air Pollution Control Act', Title 25, Article 7, section 108, CRS 1973 as amended, to the contrary notwithstanding. the board of county commissioners in any county with less than twenty-five thousand (25,000) population, according co the latest federal census, is authorized to develop regulations, by resolution, permitting the noncommercial burning • k(10) Revised 8/90 931.06,4_ C .; r .i 304 305 W,tter Quality Control 25-8-501 i ier, or determination by a temporary restraining order or injunction at the request of the commission I tiled to classification of or division. lanagement plans. water egulations, enforcement Source: R & RE, L. 81 p. 1325. § I shall be subject to Judi- t s article and article 4 of Formal party status is not prerequisite to Frederick v. Colorado Water Quality Control erminations of the corn- right of judicial review under section 24-1-Iti m Coma. _ Colo. App. , 628 P-2d 129 (4), cad by analogy, under subset:ions(I)and (1980). Jr issued in accordance - (2) of this section, so long as the concerned Applied in Colorado Water Quality Control 1 plaintiff can show that it is adversely affected Comm'n v. Town of Frederick, Cob. d order or determination or aggrieved by any agency action. Town of ,641 P.2d 958(1982). 1 rict court for the district 25-8-405. Samples, secret processes. (1) If samples of water or water I' I rule, order, or detertni- pollutants are taken for analysis and a violation of any permit or control regu- F l within thirty days after lation is suspected, a representative portion of the sample shall be furnished I Rulemaking determine- upon request to the person who is believed to be responsible for such sus- e Administrative Proce- .; petted violation. A representative portion of such sample shall be furnished me final upon issuance �'t' to any suspected violator whenever any remedial action is taken with respect thereto by the division. A duplicate of every analytical report pertaining to f„ eedmgs. The period for P Y P chile any application for such sample shall also be furnished as soon as practicable to such person. ig pursuant to section ' ,5 (2) Any information relating to any secret process, method of manufac- lication is pending shall '.1-z. . ture or production, or sales or marketing data which may be acquired, ascer- j ; review an equal length tamed, or discovered, whether in any sampling investigation, emergency investigation, or otherwise, shall not be publicly disclosed by any member. • ers issued pursuant to _ officer, or employee of the commission or the division, but shall be kept confidential. Any person seeking to invoke the protection of this subsection I desist order, clean-up p sion or commission, or (2) shall bear the burden of proving its applicability. This section shall never de, may petition the di s- ': be interpreted as preventing full disclosure of effluent data. order or determination. Source: R & RE, L. 81, p. 1326, § 1. N rich the pollution source ! r order or determination „4-4;:i. 1 order or determination PART 5 t :re is probable cause to v, c PERMIT SYSTEM is harm to the affected I 25-8-501. Permits required for discharge of pollutants - administration. (I) No person shall discharge any pollutant into any state water from a point the order or determine s! source without first having obtained a permit from the division for such dis- le, any harmful effects y charge, and no person shall discharge into a ditch or man-made conveyance essation of the violation 1', for the purpose of evading the requirement to obtain a permit under this arti- U cle. Each application for a permit duly filed under the federal act shall be jithout sufficient corre- 2,s;'/` deemed to be a permit application filed under this article, and each permit issued pursuant to the federal act shall be deemed to be a temporary , �_ P Y permit le case to the division issued under this article which shall expire upon expiration of the federal ie purpose of adducing „.;= ; permit. rings thereon: but such t„::::,,„4 (2) The division shall examine applications for and may issue, suspend, o adduce such evidence ,E, ` revoke, modify, deny, and otherwise administer permits for the discharge , of pollutants into state waters. Such administration shall be in accordance an order of the commis- with the provisions of this article and regulations promulgated by the commis- ith that order by issuing commis- sion. 4, , b. the nature and location of the activity and of its discharge; and c. existing ground water quality that may be affected by the activity; and d. relevant geologic and hydrogeologic conditions, including but not limited to the presence of ground water hydrologically connected to surface waters and recharge areas. 2. In the absence of an existing or proposed activity, the shape, depth, boundaries, and extent of a specified area may be determined by considering: a. the presence, extent, and nature of existing uses of ground water and the nature of reasonably expected future uses of ground water; and b. existing ground water quality; and c. relevant geologic and hydrogeologic conditions, including but not limited to the presence of ground water hydrologically connected to surface waters and recharge areas. 3.11.5 GROUND WATER QUALITY STANDARDS The water quality standards specified in Subsections A and B below are deemed necessary and appropriate to protect ground water uses as specified in Section 3.11.4, and shall be adopted to protect such classified uses. The standards specified in Subsection C apply to all State ground waters, unless alternative site-specific standards have been adopted for a specified area pursuant to Subsection D below. A. Narrative Standards 1. Ground Water shall be free from pollutants not listed in the Tables referred to in Section 3.11.5(B) , which alone or in combination with other substances, are in concentrations shown to be: a. Carcinogenic, mutagenic, teratogenic, or toxic to human beings, and/or, - 6 - 9310€., X07 b. Ground water is not used for domestic or agricultural uses within the specified area; and c. Background levels are generally not adequate to assure compliance with the Human Health and Agricultural Standards listed in Tables 1 and 3, or the information is insufficient to make such a determination; and d. Domestic or agricultural use of the ground water can be reasonably expected in the future, considering: background levels of water quality; geologic and hydrologic conditions; the degree to which any particular types of pollutants present are subject to treatment; the economic reasonableness of such treatment; the impact of treatment requirements on water quantity; whether or not pollution arises from natural sources; and other relevant factors. 5. Ground water within a specified area shall be classified "Limited Use and Quality" when: a. TDS levels are equal to or in excess of 10,000 mg/1; or b. The ground water has been exempted under Rule 324(2) of the "Rules and Regulations, Rules of Practice and Procedure" (2CCR 404-1) of the Oil and Gas Conservation Commission, pursuant to the Colorado Oil and Gas Conservation Act, Title 60, Article 34, CRS (1982); or c. The criteria specified in Sections 3.11.4(2)1, 2, 3, or 4 are not met. C. Specified Area 1. When an activity exists or is proposed, the shape, depth, boundaries, and extent of a specified area shall be determined by considering: a. the presence, extent, and nature of existing uses of ground water that may be affected by the activity, and the nature of reasonably expected future uses of ground water that may be affected by the activity; and !A b. A danger to the public health, safety, or welfare. 2. Determinations made pursuant to Section 3.11.7 of specific numerical limitations under this subsection shall be based upon the best scientific information currently available. B. Numeric Standards 1. The numeric standards shall be measured as total concentrations unless otherwise specified in Tables 1 through 4. 2. When a ground water has a multi-use classification, the most restrictive standard for a parameter shall apply. 3. The following numeric standards shall apply: a. "Domestic Use - Quality" - The Human Health and Secondary Drinking Water Standards listed in Tables 1 and 2, respectively, except as specified in Section 3.11.5(B)5. b. "Agricultural Use - Quality" - The Agricultural Standards listed in Table 3, except as specified in Section 3.11.5(B)5. c. "Surface Water Quality Protection" - The standards necessary to prevent the exceedance of surface waters standards. d. "Potentially Usable Quality" - appropriate standards considering those factors listed in Section 3.11.4(B) (4) (d) . 4. The TDS limitation listed in Table 4 shall apply to the following classes: "Agricultural Use - Quality" "Surface Water Quality Protection" "Potentially Usable Quality" 931.064 67 - 7 - 5. For ground water classified "Domestic Use - Quality" or "Agricultural Use - Quality," where a Table value is exceeded by the background level, the applicable standard for that parameter shall be either 1) the Table value or 2) the background level for that parameter. This determination shall be made considering the increased risk to public health, crops, or livestock associated with the background levels, the extent of the exceedence above the Table value, the degree to which the pollution is deemed correctable and subject to treatment; and the economic reasonableness of such treatment requirements. C. Statewide Standards 1. Radioactive materials and organic pollutants in ground waters shall not exceed the following levels, unless alternative, site-specific standards for these substances have been adopted by the Commission: a. For radioactive materials and organic pollutants listed in Subsections 2 and 3 below, levels shall not exceed those specified in those subsections; b. For all other radioactive materials and organic pollutants, they shall be maintained at the lowest practical level. c. Where site-specific standards have been adopted, they shall apply in lieu of the standards set forth in this subsection. 2. Radioactive Materials Standards: parameter Picocuries Per Liter Cesium 134 80 Plutonium 238, 239, and 240 15 Radium 226 and 228 5 Strontium 90 8 Thorium 230 and 232 60 Tritium 20,000 - 8 912nga 7D Section 3.11.5C 3. Interim Organic Pollutants Standards: Note that all standards in Table A are being adopted as "interim standards." These interim standards will remain in effect until alternative permanent standards are adopted by the Commission in revisions to this regulation or site-specific standards determinations. Although fully effective with respect to current regulatory applications, these interim standards shall not be considered final or permanent standards subject to restrictions such as antibacksliding or downgrading. 4. Whenever the current detection level (PQL) for a pollutant is higher (less stringent) than a standard listed in Subsection 2 or 3 above, the detection level shall be used as the performance standard in regulating specific activities. The detection levels (PQL's) identified in Table A shall apply, unless and until they are modified as the result of a subsequent rulemaking hearing. 5. Nothing in this regulation shall be interpreted to preclude: a. An agency responsible for implementation of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), 42 U.S.C. 9601, et seq. , as amended, from selecting a remedial action and a point of compliance that are more or less stringent than would be achieved by compliance with the statewide numerical standards established in this subsection, or alternative site-specific standards adopted by the Commission, where a determination is made that such a variation is authorized pursuant to the applicable provisions of CERCLA; or - 9 - 931061. TABLE A GROUND WATER ORGANIC CHEMICAL STANDARDS (in micrograms per liter) Parameter CAS No. STANDARD( 20Z Aldicarb 10 10** 116-06-3 Aldrinc 0.002 0.1* 309-00-2 BenzeneC 1.0 1.0* 71-43-2 BenzidineC 0.0002 10 92-87-5 Bromodichloromethane (H14) 0.3 1.0 75-27-4 Bromoform (HM)C 4 1.0 75-25-2 Carbofuran 36 1563-66-2 Carbon tetrachlorides 0.3 1.0* f. 56-23-5 ChlordaneC 0.03 1.0 57-74-9 Chlorethyl ether (BIS-2)C 0.03 10 111-44-4 Chlorobenzene 100 1.0 108-90-7 Chloroform (HM)C 6 1.0 67-66-3 DDEC 0.1 0.1* 72-55-9 DDTc 0.1 0.1* 50-29-3 Dibromochloromethane (1114) 14 1.0 124-48-1 - 10 - .r 6-6-- 931931.061. TABLE A GROUND WATER ORGANIC CHEMICAL STANDARDS (in micrograms per liter) Parameter CAS No. STANDARD 24L2 Dichlorobenzene 1,2 620 1.0 95-50-1 Dichlorobenzene 1,3 620 1.0 541-73-1 Dichlorobenzene 1,4 75M 1.0 106-37-6 Dichloroethane 1,2C 0.4 1.0 107-06-2 Dichloroethylene 1,1 7 1.0* 75-35-4 Dichloroethylene 1,2-cis 70 1.0 156-59-2 Dichloroethylene 1,2-trans 100 1.0 156-60-5 Dichlorophenol 2,4 21 50 120-83-2 ( Dichlorophenoxyacetic acid 70 1.0 (2,4-D) 94-75-7 Dichloropropane 1,2C 0.56 1.0 78-87-5 DieldrinC 0.002 0.1* 60-57-1 Dinitrophenol 2,4 14 50 51-28-5 Dioxin (2,3,7,8 TCDD)C 2.2x10'7 1746-01-6 Diphenylhydrazine 1,2c 0.05 122-66-7 Endrin 0.2 0.1* 72-20-8 Endrin aldehyde 0.2m 0.1 7421-93-4 - 11 - 3106 73 TABLE A GROUND WATER ORGANIC CHEMICAL STANDARDS (in micrograms per liter) Parameter (- CAS No. STANDARD1 POk2 Ethylbenzene 680 1.0 100-41-4 HeptachlorC 0.008 0.05* 76-44-8 Heptachlor epoxideC 0.09 0.05* 1024-57-3 HexachlorobenzeneC 6 10 118-74-1 Hexachlorobutadiene 1.0 10 87-68-3 Hexachlorocyclohexane,AlphaC 0.006 0.05* 319-84-6 Hexachlorocyclohexane, 0.2 0.05* Gamma (Lindane) 58-89-9 Isophorone 1,050 10 78-59-1 Methoxychlor 40 0.5* 72-43-5 Nitrobenzene 3.5 10 98-95-3 PCBsC 0.005 1.0 1336-36-3 Pentachlorobenzene 6 10 608-93-5 PentachiorophenoIC 200 50 87-86-5 Tetrachlorobenzene 1,2,4-5 2 10 95-94-3 Tetrachloroethylene 5 1.0* 127-18-4 - 12 - 9:106 - TABLE A GROUND WATER ORGANIC CHEMICAL STANDARDS (in micrograms per liter) Parameter CAS No. STANDARD' EQ;e Toluene 1,000 1.0 108-88-3 ToxapheneC 0.03 5.0 8001-35-2 Trichloroethane 1,1,1 200 1.0 71-55-6 Trichloroethane 1,1,2 3 1.0 79-00-5 TrichloroethyleneC 5 1.0 79-01-6 Trichlorophenol 2,4,6c 2 50 88-06-2 Trichlorophenoxyproprionic 50 0.5* acid (2,4,5-tp) 93-72-1 Vinyl Chlorides 2M 2 75-01-4 1 All standards are chronic or 30-day standards. They are based on information contained in EPA's Integrated Risk Information System (IRIS) and/or EPA lifetime health advisories for drinking water using a 10.6 incremental risk factor unless otherwise noted. 2 PQL's are detection levels based on the Colorado Department of Health's labor- atories best judgement for Gas Chromotography/Mass Spectrophotometry (GC/MS) unless otherwise noted. C Carcinogens classified by the EPA as A, 81, or B2. M Drinking water MCL. * Gas Chromatography (GC) PQL **High Pressure Liquid Chromatography (HPLC) PQL. CAS No. - Chemical Abstracts Service Registry Number (HM) - Halomethanes 4127m/0183m/dg - 13 - 9.106" 616- 7-5 b. An agency responsible for implementation of Subtitle C of the Resource Conservation and Recovery Act (RCRA) , 42 U.S.C. 6901, et seg., as amended, or the Colorado Hazardous Waste Act, C.R.S. 25-15-101, et sea., as amended, from applying background levels or establishing "alternate concentration limits" and a point of compliance that differ from the statewide numerical standards established in this subsection, or alternative site-specific standards adopted by the Commission, for purposes of establishing hazardous waste management or corrective action requirements, where a determination is made that such background levels or alternate concentration limits are authorized by the regulations adopted pursuant to these statutory authorities; or c. An agency responsible for implementation of an underground storage tank (UST) program, pursuant to Subtitle I of the Resource Conservation and Recovery Act (RCRA), 42 U.S.C. 6901, et sea., as amended, from issuing a regulatory determination, including a point of compliance, that is more or less stringent than would be achieved by compliance with the statewide numerical standards established in this subsection, or alternative site-specific standards adopted by the Commission, where a determination is made that the ground water quality protection criteria identified in applicable UST regulations are satisfied. D. Site-specific radioactive materials and organic pollutant standards 1. In determining whether to adopt site-specific standards to apply in lieu of the statewide standards established in Subsection C above, the Commission shall first determine the appropriate ground water classifications within a specified area, in accordance with Section 3.11.4. (- - 14 92106 STATE OF COLORADO COLORADO DEPARTMENT OF HEALTH Dedicated to protecting and improving the health and environment of the people of Colorado • : GV i • 4300 Cherry Creek Dr.S. laboratory Building «• 7 • Denver,Colorado 80222-1530 4210 E.11th Avenue Phone 1303)692.2000 Denver,Colorado 80220-3716 (303)691-4700 Roy Romer Governor December 21, 1992 CERTIFIED # P 895 190 471 Paulda&Nolan,MIX MPH RECE ; vt>«e SAN.TATI.214 C 1^1 Bill Hedberg Waste Services Corporation DECtj` 1992 5660 Greenwood Plaza Blvd., Suite 400 Englewood, Colorado 80111 L f( CAS: sil RE: Additional Hydrogeological and Geotechnical Characterization and Site Operations Central Weld Sanitary Landfill Weld County, Colorado Dear Mr. Hedberg: The Hazardous Materials and Waste Management Division of the Colorado Department of Health (the Division) has completed the review of the following documents submitted by Waste Services Corporation: Hydrogeological and Geotechnical Characterization for the Central Weld Sanitary Landfill, Volume I and II; Groundwater Monitoring Plan for the Central Weld Sanitary Landfill; Landfill Gas Monitoring Plan for Central Weld Sanitary Landfill; Confirmation Groundwater Sampling Results for Central Weld Sanitary Landfill; Expanded Hydrogeological Investigation at the Central Weld Sanitary Landfill; Central Weld Sanitary Landfill Third Quarter 1992 Landfill Gas Monitoring Results; Central Weld Sanitary Landfill Third Quarter 1992 Groundwater Sampling Results; and Additional Surface Water Sampling and Analysis at the Central Weld Sanitary Landfill. These reviews have been made under the authority of the Solid Waste Disposal Site and Facilities Act, Title 30, Article 20, Part 1, C.R.S. as amended and with the Regulations promulgated thereunder, 6 CCR 1007-2 (the Regulations). The proposed revised Solid Waste Regulations were also given consideration. The operation of this facility will be governed by these regulations as soon as they become effective. Based on the information presented in these documents the Division has identified three areas of concern: A. Issues which are incomplete or needing clarification. B. Operational improvements. C. Areas of non-compliance. 91'106!. _ 77.e Bill Hedberg Central Weld Sanitary Landfill December 21, 1992 page 2/5 A. ISSUES WHICH ARE INCOMPLETE OR NEEDING CLARIFICATION 1. Point #2 from the October 27, 1992 letter sent by the Division requested a cross-section relating the on-site geology and hydrology to all ground water wells within a 1/4 mile of the facility. Please provide this information. 2. Please provide documentation which would identify if the retention pond is in direct communication with ground water, and provide clarification between the relationship of the retention pond and ground water. 3. There seems to be some confusion over Point #8 from the October 27, 1992 letter. The Division requests cross-sections along (intercepting monitoring points TP-1,TP-6 and GWMW-7)and perpendicular(intercepting monitoring points GWMW-6, TP-6, TP-7 SG-14 and SG-11) to the underdrain. The Division apologizes for any misunderstanding. 4. Please provide as-built drawings for the perimeter french drain. If as-built drawings are not available, provide an illustration which shows the extent of lined portions, thicknesses and types of construction materials, and relationship of geologic and saturated geologic units to the french drain. 5. The Division requests that additional hydrogeologic evaluations be performed to the west of the facility. This investigation shall determine whether the Spomer Lakes are influencing ground water characteristics along the western boundary of the facility. 6. To understand the relationship between the quality of ground water from the private wells in the vicinity of the site and those at the facility, the Division requests that the following wells be sampled, (permit # 159091, #765, • #11090, and #90580). These wells shall be analyzed for the identical parameters as the monitoring wells at the facility. Please provide cross- sections through the private wells to show the relationship of the landfill geologic and saturated geologic units to those of the private wells. 7. Figure 1 from "Responses to Colorado Department of Health Comments on the Hydrogeologic and Geotechnical Characterization Report for the Central Weld Sanitary Landfill" indicates an historical maximum water leveL What is the date of this water level? Please illustrate the top of the ground water surface between monitoring points. Ground water is shown below the . completion depth of trash piezometer TP-4. Please provide an explanation/data which verifies the depth of ground water at this location. 9Z106a Bill Hedberg Central Weld Sanitary Landfill December 21, 1992 page 3/5 8. Please explain why the detection limits were increased(Central Weld Sanitary Landfill Third Quarter 1992 Groundwater Sampling Results) for volatile organic analyses for monitoring well GWMW-5N. It appears that these limits were raised exclusively on GWMW-5N. In addition, VOC samples from monitoring wells GWMW-5N and GWMW-10,when checked by the lab(PX), did not have the required preservation of a pH less than 2. In the Division's judgement these samples are invalid and these wells must be resampled. B. OPERATIONAL IMPROVEMENTS 1. In the judgement of the Division, the number of ground water monitoring points are not adequate for the southern and southeastern boundaries of the facility to delineate contaminant migration. To improve the ground water monitoring situation the Division request that additional nested wells be installed along the south and southeastern property boundaries. Please provide all information to the Division for review. 2. Please provide documentation which demonstrates that the french drain is adequate to transport water and prevent continued recharge to the shallow aquifer. If the construction of the perimeter french drain is not appropriate, please provide design improvements. 3. Surface water sample locations (landfill underdrain, north discharge pipe, discharge from the french drain into the retention pond, and Spomer Lakes) shall be sampled for eight (8) consecutive quarters. 4. All deep ground water monitoring wells shall be monitored for eight (8) consecutive quarters and include all parameters as requested by the Division. Monitoring frequency and parameters may be modified, at the request of the applicant and approval by the Division, after completion of required background sampling. 5. The proposed revised Solid Waste Regulations do not allow for field filtering of water samples. Please make this change in all texts and implement this plan during the next sampling event. �� lr 921.06? 7/ Bill Hedberg Central Weld Sanitary Landfill December 21, 1992 page 4/5 6. Table 5-1 in the "Groundwater Monitoring Plan for Central Weld Sanitary Landfill, Weld County, Colorado" is inadequate. The following parameters shall be added to Table 5-1: all 34 volatile organic compounds (VOCs) included in the "Hydrogeological and Geotechnical Characterization for the Central Weld Sanitary Landfill;" carbon disulfide; dichlorodifluoromethane and trichlorofluoromethane; radionuclides; chromium; barium and nickel. Table 5-1 shall be changed to read "Groundwater and Surface Water Parameter List Central Weld Sanitary Landfill." 7. All piezometers shall be monitored for depth to ground water. Monitoring shall be conducted during each quarterly sampling event and data submitted to the Division. 8. The Division requests that those constituents identified from monitoring well GWMW-5N (target parameter list)be analyzed on a monthly basis. Sampling shall commence during January 1993 and continue for twelve(12) consecutive months. Routine quarterly sampling of this well shall continue for the established suite of parameters. If additional constituents are identified during quarterly sampling they will be added to the target list. The Division will evaluate sample frequency and parameters after completion of this sampling schedule. C. AREAS OF NON-COMPLIANCE 1. Central Weld Sanitary Landfill has contaminated the ground water. This is a violation of subsection 2.1.4 of the Regulations. The Regulations clearly state a site and facility operated as a sanitary landfill shall prevent water pollution. Please provide a corrective action plan which addresses the contamination issues on and off site. 2. Solid wastes have been placed into ground water at this facility. The Purpose, Scope and Applicability as defined in Section 3 of the proposed revised State's Solid Waste Regulations, defines standards for new landfills, existing landfills and lateral expansions. Subsection 3.1.11 (draft of November 5, 1992) states "landfills shall not place wastes below or into surface water or groundwater._" Bill Hedberg Central Weld Sanitary Landfill December 21, 1992 page 5/5 Please be aware, the Division fully expects the proposed revised Solid Waste Regulations will become effective in the very near future. At that time Central Weld Sanitary Landfill will be in violation of area 'C', point #2 as detailed above. As the owner and operator of this facility, Waste Services Corporation, is notified that the areas of non-compliance described above are a public nuisance. Please be advised that the Division will take whatever action is deemed appropriate and necessary to obtain correction of these violations and protect the public health and environment. These conclude the Division's comments concerning issues raised about Central Weld Sanitary Landfill. Please respond to the issues detailed above in a comprehensive document within two weeks of the receipt of this letter. If you have any questions please feel free to contact me at 303-692-3437. Sincerely, Roger Doak Glenn F. Mallory Geologist Section Leader Solid Waste Section Solid Waste Section Hazardous Materials and Hazardous Materials and Waste Management Division Waste Management Division cc: EfPitkbe, Weld County Health Department L. Morrison, Weld County Assistant Attorney A. Scheere, Waste Management of North America B. Taylor, CDH, WQCD L. Perrault, Attorney General's Office Weld County Department of Planning Weld County Commissioners File: SW/WLD/CEN/Correspondence 931,064. March 5, 1993 To: Glenn Mallory Solid Waste Program • FROM: Laura E. Perraultkfit MAR °93 Assistant Attorney General THRU: Dan Miller - •. . First Assistant Attorney General RE: Central Weld Landfill -- Regulatory Request of 6 CCR 1007-2, S 2.1.4 Interpretation _a_ssrsiunsiBc) On December 21, 1992, the Hazardous Materials and Waste Management Division of the Colorado Department of Health ("CDH") notified Waste Services Corporation ("Waste Services") that CDH had completed its review of several technical documents submitted by Waste Services regarding studies and monitoring plans and results for the surface water, groundwater and landfill gas media at the Central Weld Landfill. As a result of this review, CDH determined, in part, that: Central Weld sanitary Landfill has contaminated the ground water. This is a violation of subsection 2.1.4 of the Regulations [6 CCR 1007-2] . The Regulations clearly state a site and facility operated as a sanitary landfill shall prevent water pollution. Please provide a corrective action plan which addresses the contamination issues on and off site. to its Waste operation Services has the landfill.contested the application has treq of section 2.1.4 opinion of this issue, quested a written Arguments Section 2 . 1.4 states; A site and facility operated as a sanitary landfill Mhall provide eana disposing of solid waarea .. _djaajuningx j---Hnna11v to minimize nuisance conditions such as moors windblown debris, ins c oden e 931.061. 20 'd 56 II 1111 E6-[i-8d6! shall provide compacted fill material; shell o with m,it and sur*>nn drainage d ei able mA1'oqt oondina of Ovate and ,aped ear; on being filled, shall be left in a condition oforderliness and good aesthetic appearance and capable of blending with the surrounding area. (emphasis added) . Waste services' objection to the application of section 2.1.4 to the Central Weld Landfill is somewhat convoluted and seems to be based on a slight misunderstanding between CDH and Waste Services of which portion of section 2.1.4 is at issue, and on a misinterpretation of this regulation by both Waste Services and CDH. In a February 2, 1993 memo, Waste Services focused on the "adequate cover" portion of section 2.1.4. To its disadvantage, Waste services misread this portion as requiring that the operators of a landfill must "provide adequate cover with suitable material and surface drainage designated [sic] air pollution. " (emphasis to n o.,0- - war and was based added) . Perhaps Waste Services' reading incorrectly statedhat se on ction December rer 21, 1992, letter, which be operated to "prevent water pollution. " Section 2.1.4, ho ever, does not contain this mandate; rather, cover" and "surface drainage" prevent that"rno requires that "adequate nd pollution. " g of w� and air Based on its incorrect reading of section 2.1.4, Waste Services' memo addressed a tangential and irrelevant issue -- whether an adequate cover and effective surface drainage alone can prevent groundwater contamination. Waste Services concluded that, because a number of other factors contribute to groundwater contamination, the existence of groundwater contamination beneath the site "is not gg facto evidence that a landfill has been designed or operated in violation" of this portion of section 2.1.4. Although Waste Services' memo is correct in its assumption that the existence of groundwater contamination is not A facto evidence that a landfill has a poor cover or bad surface drainage, its memo never addressed one of the real issues here -- whether the Central Weld landfill has an adequate cover and surface drainage which prevents the ponding of water. Thus, Waste Services may be in violation of this portion of section 2.1.4. . • Moreover, Waste Services may be in violation of another portion of section 2.1.4. which the Waste Services' memo does not address. Section 2.1.4 also states that a landfill must be operated to "minimize nuisance conditions." "Nuisance conditions" is defined under 6 CCR 1007-2, $ 1.2 as "those which may result from . . . water pollution . . ." As CDR has definition makes no distinction between ground aoin this nd surface ted �Water pollution. Thus, CDR may assume that if a measurable amount of groundwater contamination exists in the groundwater beneath the 93106e. 60 'd 9: 1i f1NJ £6-I I-dEi41 `3 facility, the facility may not be operating in a manner to "minimize nuisance conditions. " This may be due to the fact that the landfill does not have an adequate cover or surface drainage, or it may be due to the operator's failure to take certain other measures. In response to CDR's claim, during a phone conversation with Waste Service's legal representative, Waste Services acknowledged that "nuisance conditions" may result from groundwater pollution, and that groundwater pollution does exist at the site. However, Waste Services claimed that no actual "nuisance" has resulted from this groundwater pollution because no one is presently using, or is affected by, this contaminated groundwater. Although this interpretation has some scintilla of merit, it is too innarrow. According rilingDicti to the legal definition of "nuisance" occoccurred Black's site, y, a nuisance" probably is already act, at this by failure The dictionary defines public nuisance as causing or permitting a condition tperforM olee il duty,i intentionally njures gc ang rs li health s tilt xis. which injures o. - - - _tie Dub c el a. a." The dictionary defines private nuisance as (emphasis added) . destroys or deteriorates t+e o �* ., "iny wrongful act which persons or interferes with their lawfulof an e individual a or of e a few " (emphasis added) . Since this contaminated enjoyment fis flowing off site and may be used b public health and safety and, therefre,someone, it endangers public c nuisance. The contamination constitutes 'a constitutes a , well, because it has deteriorated offsite private nuisance, as groundwater property. But even assuming arauendo a nuisance occurred, Waste Services may still fail to per this has not yet requirement. Arguably, the term "nuisancemeet on regulatory than the term "nuisance." section 2.1.4 does conditions" is broader a actual "nuisance" not mandate that an violation of be created before CDH can find a company in operator this section; rather, it clearly states that an must minimize "nuisance conditions. " In other words, an operator must take steps to prevent the possibility of the creation of a nuisance. As CDR has pointed out, Waste Services has failed to do this. Leachate from the landfill has contaminated the groundwater and this contaminated groundwater is flowing off site. C0NC, ru In short, although CDR incorrectly stated that section 2.1.4 requires a landfill operator "to prevent water pollution," CDR legitimately concluded that Waste Services' operation of the Central Weld Landfill appears to violate this section. Waste Services can either refute this claim by showing that it has taken it v can semion p o necessary to minimize ground water contamination, or whic do y with CDR's request and draft a corrective action plan cuments what further actions it plans to take in order to meet section 2.1.4. . 931064. 60 'd WEf}{J. £6-II-88U • 7 A 3 . 1.5 OWNERS OR OPERATORS OF NEW LANDFILLS, EXISTING LANDFILLS AND EXPANSIONS OF EXISTING LANDFILLS LOCATED 3 IN AN UNSTABLE AREA MUST DEMONSTRATE THAT ENGINEERING kC MEASURES HAVE -BEEN INCORPORATED INTO THE FACILITY'S 5 DESIGN TO ENSURE THAT THE INTEGRITY OF THE STRUCTURAL 6 COMPONENTS OF THE FACILITY WILL NOT BE DISRUPTED. THE 7 OWNER OR OPERATOR SHALL PLACE THE DEMONSTRATION IN THE 8 OPERATING RECORD OF THE FACILITY AND IN THE FACILITY 9 FILE OF THE DEPARTMENT. THE OWNER OR OPERATOR SHALL F 10 CONSIDER THE FOLLOWING FACTORS, AT A MINIMUM, WHEN 11 DETERMINING WHETHER AN AREA IS UNSTABLE: 12 1) ON-SITE OR LOCAL SOIL CONDITIONS THAT MAY 13 RESULT IN SIGNIFICANT DIFFERENTIAL SETTLING; 14 2) ON-SITE OR LOCAL GEOLOGIC OR GEOMORPHOLOGIC 15 FEATURES; AND 16 3) ON-SITE OR LOCAL HUMAN-MADE FEATURES OR EVENTS 17 (BOTH SURFACE AND SUBSURFACE) . 18 19 3 . 1. 6 THE TOPOGRAPHY OF THE SITE SHALL MAXIMIZE PROTECTION 20 AGAINST PREVAILING WINDS ON-SITE AND MINIMIZE THE 21 AMOUNT OF PRECIPITATION CATCHMENT AREA UPGRADIENT OF 22 THE SITE. 23 24 3 . 1.7 LANDFILLS SHALL NOT BE LOCATED IN A FLOODPLAIN. 25 26 3 . 1. 8 LANDFILLS SHALL BE SITED NO CLOSER TO DOMESTIC WELLS OR 27 SPRINGS SHOWN TO TAP THE UPPERMOST AQUIFER DOWNGRADIENT 28 OF THE SITE, THAN THAT DISTANCE GROUND WATER BENEATH 29 THE SITE WOULD FLOW DURING THE FACILITY'S OPERATING 30 LIFE AND POST-CLOSURE CARE PERIOD, UNLESS ADEQUATE 31 GROUND WATER PROTECTION IS PROVIDED. 32 33 3 . 1.9 LANDFILLS SHALL ISOLATE WASTES FROM THE PUBLIC AND 34 ENVIRONMENT BY EMPHASIZING FAVORABLE GEOLOGIC 35 CONDITIONS OVER ENGINEERED IMPROVEMENTS OF MARGINAL 36 GEOLOGIC CONDITIONS. 37 38 3 . 1.10 LANDFILLS SHALL NOT PLACE WASTES BELOW OR INTO SURFACE 39 WATER OR GROUND WATER. CONTINUED OPERATION OF SITES 40 AND FACILITIES THAT HAVE PLACED WASTE INTO GROUND WATER 41 IS PROHIBITED. 42 SECTION 3.2 DESIGN REOUIREMENTS 43 44 3 . 2 .1 GEOLOGIC DATA 45 THE ENGINEERING DESIGN AND OPERATIONS REPORT SHALL 46 INCLUDE, AS A MINIMUM, THE FOLLOWING GEOLOGIC DATA: 47 (1) TYPES AND REGIONAL THICKNESS OF UNCONSOLIDATED 48 SOILS MATERIALS; 49 (2) TYPES AND REGIONAL THICKNESS OF CONSOLIDATED 50 BEDROCK MATERIALS; 51 (3) REGIONAL AND LOCAL GEOLOGIC STRUCTURE, INCLUDING 52 BEDROCK STRIKE AND DIP, AND FRACTURE PATTERNS; AND 53 (4) GEOLOGIC HAZARDS, INCLUDING BUT NOT LIMITED TO 54 SLOPE STABILITY, FAULTING, FOLDING, ROCKFALL, 55 LANDSLIDES, SUBSIDENCE OR EROSION POTENTIAL, THAT MAY 56 AFFECT THE DESIGN AND OPERATION OF THE FACILITY FOR 57 SOLID WASTES DISPOSAL. DRAFT STATE SOLID WASTE + SUBTITLE D REGULATIONS 9:111€9 _ CTC-- December 24 , 1992 53 O DEPARTMENT OF HEALTH 1517- 16 AVENUE COURT GREELEY,COLORADO 80631 C ADMINISTRATION(303)353-0586 O HEALTH PROTECTION(303)353-0635 COMMUNITY HEALTH(303)353-0639 COLORADO March 19, 1993 William J. Hedberg Waste Services Corporation 6037 77th Avenue Greeley, Colorado 80634 Dear Mr. Hedberg: On March 2, 1993, a representative of the Environmental Protection Division of the Weld County Health Department inspected the Central Weld Sanitary Landfill, located at 6037 77th Avenue, Greeley, in Weld County, Colorado. The purpose of the inspection was to inspect and assess the facility's compliance with the "Regulations Pertaining to Solid Waste Disposal Sites and Facilities" (The Regulations) as promulgated by the Solid Waste Disposal Sites and Facilities Act (the Act) , Title 30, Article 20, Part 1, C.R.S. On the date March 2, 1993, field inspection, and subsequent record review, the following observations were made: 1. The facility does not possess an approved Design and Operations plan. 2. As previously documented, the facility has contaminated groundwater at this location. 3. As documented, the facility has allowed trash to come into contact with groundwater. 4. The facility continues to operate without the required discharge permits. This facility is currently operating without an approved Design and Operations plan as required by Section 30-20-103 of the Act. It is acknowledged, that the facility is currently in the process of preparing all necessary documents. It has been documented, that previously disposed solid waste materials is currently exposed to groundwater and that groundwater pollution has occurred at this location. Section 2.1.4 of The Regulations states "A site and facility operated as a sanitary landfill shall provide means of finally disposing of solid wastes on land in a manner to minimized nuisance conditions. . . ." and that '931.064. (>v William J. Hedberg Waste Services Corporation March 19, 1993 Page 2 ^nuisance conditions are those which may result from explosive gas, bird hazards,. disease vectors, odors, windblown solid wastes or cover materials, open burning, water pollution. .. ." Further, the pollution of groundwater at the facility's property line is in violation of Section 3.11.5 of the Water Quality Control Commission Rules, which constitutes a violation of Section 2.1.2 of the Regulations. The facility continues to discharge pollutants into State Waters without an approved Discharge Permit. Operating without a Discharge Permit is a noncompliant activity according to Title 25, Article 8, Part 5, C.R.S. , as amended. It is acknowledged that the facility has submitted the required permit application. The Division is assuming that all of the above matters will be addressed in the upcoming hearing, etc. If you have any questions, please contact Trevor Jiricek at (303) 353-0635. Sincerely, Trevor Jiricek Solid and Hazardous Waste Specialist - tj/527 cc: Roger Doak, Colorado Department of Health Keith Schuett, Weld County Planning • /tt a 14t. ' r , ... ( cis L DEPARTMENT OF PLANNING SERVICES WI ' PHONE(303)353-3845, EXT.3540 COUNTY ADMINISTRATIVE OFFICES CWELD GREELEY, N ORA AVENUE COLORADO 80631 COLORADO March 2, 1993 Waste Services Corporation 40000 Weld County Road 25 Ault, CO 80610 Subject: ZCH-96 Dear Sirs : The Probable Cuase Public Hearing originally scheduled for March 24, 1993, HAS BEEN RESCHEDULED by the Board of County Commissioners. Notice is hereby given that on Monday, April 5, 1993 , at 9 :00 a.m. , or as soon thereafter as the agenda of the Board of County Commissioners permits, the Board of County Commissioners of Weld County will hold a Probable Cause public hearing pursuant to Section 81 of the Weld County Zoning Ordinance and the policies and procedures of the Weld County Administrative Manual. This meeting will take place in the Commissioners' Hearing Room, Weld County Centennial Center, 915 Tenth Street, Greeley, Colorado. The purpose of this public hearing will be to review Case Number SUP-116 for compliance with conditions of approval as approved by the Board of County Commissioners on October 6, 1971, to determine if probable cause exists to hold a hearing on revocation of SUP- 116. Mr. John Pickle, in his memorandum dated February 22, 1993, has identified the items of non-compliance with conditions of approval for SUP-116. A copy of his memorandum is attached. If it is determined at the public hearing that there is probable cause that you are not in compliance with SUP-116 the Board of County Commissioners will schedule a Show Cause public hearing to consider revocation of the Special Review permit. If you have any questions regarding this matter, please call or write. Respectfully, C � LIArks Chuck Cunliffe, AICP Director enclosure pc: William J. Hedberg Marian King Bill Jeffry Lee Morrison 4ohn Pickle j�� : ?, MEMORAfDUfn 1119c. Chuck Cunliffe, Planning February 22, 1993 To COLORADO John Pickle, Healtb_`�` From Central Weld Sanitary Landfill Subject: This memorandum is a follow-up to our meeting with Waste Management and Waste Services on February 18, 1993. Since that time, I have also met with Glenn Mallory, and Roger Doak, Solid Waste Division, and Pat Nelson, Water Quality Division, Colorado Department of Health. In response to these meetings, it is the opinion of this Division that the Central Weld Sanitary Landfill continues in a state of non-compliance. We submit the following areas of concern as violations: 1. The operators of the Central Weld Sanitary Landfill have not submitted a complete Design and Operations Plan. (See attached letter of February 22, 1993) . This is a violation of C.R.S. 30-20-103. 2. The Central Weld Sanitary Landfill continues to operate without required Discharge Permits. This is a violation of Subsection 2.1.2. of the Solid Waste Regulations, and 25-8-501, C.R.S. In conference with Pat Nelson, Water Quality Division, their position is that the absence of the required permits constitutes technical violation of the Rules; however, they are holding further enforcement in abeyance so long as this facility continues to proceed in good faith with the Discharge Permit application process. Our Division agrees with this position. 3. The Central Weld Sanitary Landfill continues to contaminate the groundwater. A review of the Hydrogeologic and Geotechnical Characterization and supporting documents indicate that a portion of this contamination is due to a lack of adequate cover and adequate surface drainage. This is a violation of Subsections 2.1.2 of the Solid Waste Regulations, specifically, 3.11.5 of the Water Quality Control Commission Rules, and 2.1.4. of the Solid Waste Regulations. In conference with Glenn Mallory and Roger Doak, Solid Waste Division, Colorado Department of Health, their position is still as outlined in their letter of December 23, 1992. 4. The Central Weld Sanitary Landfill has allowed solid waste to come into contact with groundwater on this site. A review of the Hydrogeologic and Geotechnical Characterization and supporting documents indicate that this condition is due to a lack of adequate cover and adequate surface drainage. This is a violation of Subsections 2.1.2 of the Solid Waste Regulations, specifically, 3.11.5 of the Water Quality Control Commission Rules, and 2.1.4. of the Solid Waste Regulations. In addition, this will be a violation of Subsection 3.1.10 of t e revised Solid Waste Regulations, which are schedule CAI effective in April, 1993. 1 FEB 2 3 1993 •L f J n_..�..glq^gpr 0 "9 rigs. .$ x. . CST- This Division, and the Colorado Department of Health continue to feel that items II 3 and Ik 4 constitute a public nuisance. Consequently, we would request that these violations be brought to the attention of the Board of County Commissioners, in the form of a public hearing. Should you need additional information, please contact me. ENV\342 XC: Lee Morrison, Assistant County Attorney Randolph Gordon, M.D. , M.P.H. Glenn Mallory, Solid Waste Division David Holm, Water Quality Division i5I FEB 2 3 1993 I -r..pa a—on+i�ann�n� to.d._fig.. 4'2 (r(r mEmoRAnDum Chuck Cunliffe, Planning March 30, 1993 To e COLORADO John Pickle, Hea From Central Weld Sanitary Landfill Subject: On March 2, 1993, Trevor Jiricek of our staff inspected the Central Weld Sanitary Landfill. The purpose of the inspection was to assess the facility's compliance with the "Regulations Pertaining to Solid Waste Disposal Site's and Facilities", as promulgated by the Solid Waste Disposal Sites and Facilities Act, Title 30, Article 20, Part 1, C.R.S. The facility continues in a state of non-compliance as previously cited in my memo to you of 2-21-92: 1. The operators have not submitted a complete Design and Operations Plan. 2. The Central Weld Sanitary Landfill continues to operate without required Discharge Permits. 3. The Central Weld Sanitary Landfill continues to contaminate the groundwater. 4. The Central Weld Sanitary Landfill has allowed solid waste to come into contact with groundwater on this site. I met with Bill Hedberg, Site Manager on March 23, 1993. Although we primarily discussed other matters, no mention was made of any change in these areas of non- compliance. In addition, I have received nothing to date with regard to same. If you have further questions, please contact Trevor Jiricek or me. March 29, 1993 ^ 2 ,7 Ms . Connie Harbert , Chairperson Weld County Commissioners Centennial Center 915 10th Street Greeley, CO 80632 Dear Ms . Harbert , I am troubled by a situation involving Waste Management/ Waste Services . I live on the property adjacent to the Central Weld Landfill on the north side and I am in constant awareness of their presence . The loud large machinery operates non-stop from 7 : 00 a .m. - 5 : 00 p.m. Flocks of seagulls swarm the trash and are warded off by the sounds of loud flares throughout the day. That only sends them flying over our home which is very annoying. The landfill also is in an area that receives high wind gusts causing the trash to blow out of the landfill to adjoining properties . The machinery is constantly kicking up great amounts of dirt/particulates and spewing it into the air during their daily operations . In fact, truck load after truck load of petroleum contaminated soils are dumped here and by evening it is spread over the days trash. What about spewing the particulates from these contaminated soils into the air? What happened to the aeration process of accepting these soils? This landfill should have quit operations by 1986 but it seems to still be going strong. How can that be since they have never submitted all of the paperwork for their plan and design and procedures of operation? The only way to expand is if they go up using air space and build a mountain of trash. The original guidelines promised all surrounding landowners that nothing like that would happen - the landfill would blend nicely into the surrounding area . Some points are already 100 feet higher than the original historical elevation of the land and there is a very dangerous trench around the North and East sides of the landfill . They are going about operations as though everything is o.k. and approved . They have accelerated operations in the last couple of months and have been adding to the height of this thing with- out any approval from anyone : How can that be? : Who is monitering who? It is extemely unjust that a large mega company with a lot of money can get ahead simply because they have the monies . W@ the little guys , landowners that want to protect what we have get stomped on because of our lack of funds to fight back. The state and county are in charge to keep these businesses in check. This whole situation would be similar to applying for a permit for a small convenience store and over time building a strip mall 1 A hill without any approved permits ! The location of this dump is WRONG! Irrigation water surges through and around the landfill in summer and it ' s located in the middle of a natural drainage area . Keeping this landfill in operation only compounds the problem already at hand . It is contaminating the surrounding waters , the most susceptible source is the nearby Big Thompson River only 4 mile away. Why in the world would we jeopardize our local sources of water? As my husband and I have been saying lately - this landfill is not needed, not in compliance , not safe and not wanted ! Please listen to the citizens of this community - especially the ones who care about the future of our children and our environment . We want this landfill cleaned up and closed . It is ridiculous to believe that Waste Management should have another 14 plus years to keep operating an unsafe dump while at the same time cleaning up the contamination. Common sense says that a clean up is needed without adding more trash to an already bad situation . There are more than enough landfills', to accomodate the trash being generated by Weld County residents . Just to name two that are close in proximity are the Ault and Keenesburg landfills . Ms . Harbert , you are our representative in this matter as we are in your district . With all of the recent articles in the local papers regarding this landfill I am surprised you have not contacted us nor visited the landfill with a repre- sentative of our group. Our neighborhood action group has addressed inquiries from all of the other Weld County Commissioners and we certainly would welcome the opportunity to show you the other side of the story. The Ashton-Daniels Neighborhood Association has been working hard at discovering the facts and uncovering the facts . We deserve a fair chance to be heard . Thank you. Sincerely, Ann Hayes 8200 W. 49th Street Greeley, CO 80634 ( 303 ) 330-8726 Copies : Governor Romer Senator Hank Brown Weld County Health Dept . Congressman Wayne Allard Senator Tom Norton Dr . Patricia Nolan, CDH Barbara Taylor , WQCD Roger Doak CDH FI let 9x106.1 2 f PipM A'{f it rJ Many of WMI's "state-of-the-art"landfill designs employ a double-layer Emelle, high-density polyethylene(HDPE)liner with leachate collection piping be- tween. In 1990 WMI purchased a minority interest in National Smeal, a privately held landfill liner manufacturer. (670) According to the Phillips Petroleum Company, a leading maker of polyethylene, there are a number of chemicals that can weaken polyethylene landfill liners. (628) Liners made out of clay also leak due to the ability of organic chemicals to permeate clay and shrinkage and ex- pansion from varying weather conditions. (632) CWM has also sought to weaken regulations governing hazardous waste landfills. On April 24, 1989, CWM won a decision from the U.S. Ap- pellate Court to drop a provision in regulations issued under the Resource Conservation and Recovery Act's "first-third" land-ban rule, a decision that effectively weakened leachate treatment standards. (633) CWM currently operates seven hazardous waste landfills in the U.S., including the nation's largest in Emelle, Alabama. What follows is a chronology of problems at CWM's hazardous waste landfills, s �•il a h f f �:,' CO CWM's eroding CID landfill in Chicago's Southeast Side. sLo -a<4)%4144. a<4)% 61t. d- -)-}c & ,LJ'ant— 4 - fine- 3�1.A � 9"1.06_4. Hello