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Home My WebLink About910998.tiff RESOLUTION RE: ACTION OF BOARD CONCERNING SHOW CAUSE HEARING - TIRE MOUNTAIN, INCORPORATED, C/O JARRALD A. AND FAYE L. JAMISON WHEREAS, the Board of County Commissioners of Weld County, Colorado, pursuant to Colorado statute and the Weld County Home Rule Charter, is vested with the authority of administering the affairs of Weld County, Colorado, and WHEREAS, on August 14, 1991, a Show Cause Hearing was conducted to consider revocation of Special Use Permit 11842, issued to Tire Mountain, Incorporated, c/o Jarrald A. and Faye L. Jamison, and WHEREAS, Jarrald A. Jamison is owner and operator of said facility, located on property described as part of the SE,' of Section 32, Township 3 North, Range 65 West of the 6th P.M. , Weld County, Colorado, and WHEREAS, Ken Lind, Attorney representing the applicant, and Mr. Jamison were present, and WHEREAS, the Board heard all of the testimony offered concerning this matter and, having been fully informed, did Find that the burden of proof has not been met to show the existence of violations of Development Standards 113c, 116, and 117, regarding number of trenches open at one time, placement of tires, and covering of trenches, and WHEREAS, pursuant to said Findings, the Board deems it advisable that Special Use Permit 11842 not be revoked for the following reasons: 1. The operation does not show substantial deviation from Development Standard 113c, with said Development Standard to allow more than two trenches to be open at one time. 2. The operation is not in substantial variation with Development Standard 116, with said Development Standard to allow tires to be placed lengthwise rather than widthwise. 3. The operation had diligently tried to fulfill the requirement of Development Standard 117, which was not feasible, and the violation and requirement of said Development Standard be withdrawn. NOW, THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Weld County, Colorado, that the Board does hereby Find that Tire Mountain, Incorporated, c/o Jarrald A. and Faye L. Jamison, be, and hereby is, not in violation of Special Use Permit 11842. 910998 CC: per, Pea-M1 CA Ken Ljnd Page 2 RE: SHOW CAUSE - TIRE MOUNTAIN, INC. , C/0 JAMISON The above and foregoing Resolution was, on motion duly made and seconded, adopted by the following vote on the 14th day of August, A.D. , 1991. Iey� /f�/ //� BOARD OF COUNTY COMMISSIONERS ATTEST:�"'�/ /,('�J' r�(/// WELD COUNT , COLORADO Weld County Clerk to the Board AYE Gor a y iairman By: <��, f�[�i2 ��Yw NAY Deputy Clerk to the_BoaAi George Kennedy, Pro-Tem APPROV8D AS TO FORM: _ ,/ EXCUSED DATE OF SIGNING (AYE) Constance L. Harbert ' % i' �`' "`-�_� EXCUSED ' ounty Attbrney --eC. W. Kirby A '9 � / 1 1d�4k0 AYE W. H. Webster 910998 HEARING CERTIFICATION DOCKET N0. 91-34 RE: SHOW CAUSE HEARING TO CONSIDER REVOCATION OF SPECIAL USE PERMIT 11842 - TIRE MOUNTAIN, INC. , C/0 JARRALD A. AND FAYE L. JAMISON A public hearing was conducted on August 14, 1991, at 10:00 A.M. , with the following present: Commissioner Gordon E. Lacy, Chairman Commissioner George Kennedy, Pro-Tem Commissioner Constance L. Harbert Commissioner C. W. Kirby - Excused Commissioner W. H. Webster Also present: Acting Clerk to the Board, Shelly Miller Assistant County Attorney, Lee Morrison Planning Department representative, Keith Schuett Health Department representative, Wes Potter The following business was transacted: I hereby certify that pursuant to a notice dated June 5, 1991, and duly published August 1, 1991, in The New News, a public hearing was conducted to consider the revocation of Special Use Permit #842, issued to Tire Mountain, Inc. , c/o Jarrald A. and Faye L. Jamison. Lee Morrison, Assistant County Attorney, made this a matter of record. Keith Schuett, Planning Department representative, said he inspected the property on August 13, 1991, and the Permit holder is still in violation of the three Development Standards. He asked that the staff comments be entered into the record as written. The applicant was agreeable to this. Ken Lind, Attorney representing Tire Mountain, spoke in regards to Development Standard 63c concerning the difference between the cells and the trenches, and gave the status of each cell. He also stated that they had submitted a request on April 24, 1991, to the Department of Planning Services, for a minor change to allow four trenches to be open instead of only two. Concerning Development Standard #6, Mr. Lind said they also submitted a request for a minor change, again on April 24, concerning placing the tires lengthwise rather than widthwise. He said that approximately ten percent of the tires are reclaimed and sold; therefore, more room was required to sort. Mr. Lind said they also submitted a request, on April 24, for a minor change concerning the covering of the tires. He explained that the tires in Cell #1, for example, have settled ten feet in the past twelve to fifteen months. He also said the plastic and dirt covering was not feasible because of the dirt contamination to the tires and having to uncover and recover to add tires. (Change to Tape #91-23 during Mr. Lind's presentation. ) Mr. Lind proposed that no covering be put over the tires for ten years, and if the tires are not reclaimed or recycled by that time, they would then be covered. After further comments concerning the Development Standards, Mr. Lind submitted a series of pictures of the landfill. He said a performance guarantee proposal would be submitted to the Board next week concerning the existing surface tires. He submitted pictures showing the construction of the trenches. Mr. Lind stated that since they have requested a minor change for the abovementioned Development Standards, he is now requesting thirty days to close the facility, if so required by the Board. Mr. Lind answered questions of the Board and Wes Potter, representing the Health Department. Mr. Potter stated concerns about the adequacy of space for tires and the adequacy of dirt to cover the tires. Jarrald Jamison, representing Tire Mountain, spoke in respect to the adequacy of the dirt. Mr. Lind responded to questions of Mr. Morrison and further questions of the Board. Mr. Schuett and Mr. Potter responded to various other questions of the Board. Helen Moore and Norma Taylor, surrounding property owners, commented on their concerns about the facility. Mr. Lind and Mr. Jamison addressed the concerns of the public. Mr. Morrison explained the Board's 910998 Cc . Pkan Page 2 RE: HEARING CERTIFICATION - TIRE MOUNTAIN, INC. , C/O JAMISON options in taking action. Mr. Schuett suggested the Board determine whether the requested changes were minor or substantial. Mr. Schuett and Mr. Potter answered questions of the Board concerning State regulations. Commissioner Webster moved for Development Standard 113c to allow more than two trenches to be open at one time. Commissioner Harbert seconded the motion. Mr. Morrison suggested restating the motion as "the operation does not show substantial deviation from Development Standard 113c." Commissioners Webster and Harbert agreed with the restatement, and made statements concerning minor changes. Commissioner Kennedy stated he does not consider this a minor change. The motion carried three to one with Commissioner Kennedy voting nay. In regards to Development Standard 116, Commissioner Harbert moved to not find the operation in substantial variation. Commissioner Webster seconded the motion, which carried three to one with Commissioner Kennedy voting nay. Commissioner Webster stated that the operation had diligently tried to fulfill the requirement of Development Standard 117, which was not feasible, and moved that the violation and requirement of said Standard be withdrawn. Commissioner Harbert seconded the motion. Chairman Lacy suggested that the motion include the requirement of covering the tires with dirt after ten years. Mr. Morrison said that statement may be considered substantial change. Commissioner Harbert stated that her second stands. Commissioner Webster suggested including alternate methods of care in the motion. Commissioner Kennedy said he is not opposed to the position of the Board, only the process being taken. The motion carried three to one, with Commissioner Kennedy voting nay. Chairman Lacy, in response to a question from Ms. Taylor, clarified that the operation is not in violation and there was no substantial change determined. Mr. Morrison stated that if the State Health Department's requirements are not met, the matter will be further reviewed. This Certification was approved on the 19th day of August, 1991. LeMaah APPROVED: ATTEST: BOARD OF COUNTY COMMISSIONERS WELD COUN Y, OLORADO Weld County C erk to the Board By; ✓✓ 2ee2-teJJ Gordbgn . Lac 1rman Deputy Clerk to the,-Bylard G Kennedy, Pro-Tem TAPE 1191-22 & 91-23 EXCUSED DATE OF APPROVAL Constance L. Harbert DOCKET 1191-34 EXCUSED C. W./Kirby�//(/ 4 // PL0456 [/0,4 / 1 W. H. Webster 910998 ATTENDANCE RECORD HEARINGS ARE AS FOLLOWS oON THIS f '- DAY OF A i� �u S , 1990: DOCKET # � - �� " c97Lmt� Cau_ AA_ _ _ `T lnA rnoweL.e,sy_ -/o DOCKET # DOCKET A DOCKET # DOCKET / PLEASE write or print your name legibly, your address and the DOC A (as listed above) or the name of the applicant of the hearing you are attending. , NAME ADDRESS HEARING ATTENDING f �c ,tit N\to re Pit�w6g2 z �,ta- n1+11 ��3z,� �, L `� y J �3 /p c r'/u 4,4„ , /?217. 910999 CC: . . .... . -7 rt ,A -., STATE OF COLORADO ) CLut. COUNTY OF WELD ) The New News Page 11 NOTICE David S. Reynolds, being duly sworn, Pursuant to the zoning laws of the says that he is publisher of State of ColoradO�w the Weld The New News, a weekly newspaper g be held in the published in Keenesburg in said County Commissioners ohe f Weld County, CCou�nty, and State; that said newspaper has a Colorado, Weld County Ce, First Center, 813 10th Street, First general circulation in said Count Floor, Greeleyd., Colorado, at the and has been COnt1nOU51y and Y mannere interested All personsmany manner interested te the matter are requested to attend and may uninterruptedly . published therein, beheard.- during a period of at least Should any eofaeourE rtravorterW fifty—two consecutive weeks prior to inaaddaitio�aw�th will -be he en(tap the e4 tne Ord the first publication of the annexed hearing, the Clerk to ode a rds tmg notice; that said newspaper is a office shall be advised in e days sof such action ri least e c days newspaper within the meaning of the prior to he hearing. The cost o[ g engaging a court reporter shall be act of the General Assembly of the borne by the renuesUg otae teat Be d also yknown the the State of Colorado,, entitled "An Act and a Maybe xamine°Ban. 0 to regulate the WeldClerk printing n t i n o f legal a 1 County Commissioners• located m g P g g Center,Weld County Street, Tudal notices and advertisements, " and Flooer'GreeleylColorado. Turd DOCKET NO.91-34 amendments thereto; that the notice Tire Mountain Inc. - Jerrold A. and Faye L. Jamison - 1231 Weld Of which the annexed is a printed County Road 41 - Hudson, Colorado 80642 copy taken from said newspaper, was DATE: August 14,1891 ublished in said news a er and in TIME. P P P r 12E UEST: Hearing N SHOW the regular and entire issue of CAUSE for revocation of Special g Use Permit No.842,on or to Tire e. every number thereof , LEGA'LL DESCRIPTION: Part a i the SE1/4 of Section 32, Township 3 North Ridge 65 West of the 6th once a week for P.M. Weld CountY,Colorado ISSUES: 1. Whether or-not the successive weeks that said notice uses currently, conducted, an the 1 site are m violation of was so published in said newspaper Development Standard No. 3c which states: No more N 2 an ro er and not in an su lement trenches shall be excavated and P P Y P P exposed or filled at a time.' thereof , and that the first 2. Whether pond Ducted Don the sitte are in violation of Development publication of said notice as Standard No 6, which states: Tires shall-be placed ac�¢at h aforesaid, was on the width and to the t0P trench before Proceeding lengthwise along the trench. `"�''=d� 3. .Whether or not the uses day o f Y `, .9 , currently,conducted on the site 777 le re m vwlalion of Development Standard Na 7, wfri states: ` Within 30 days of filing a trench and he last on the I day Of with tires, ilia trench shag be covered sod ne less Nana . No CI 2 qy plastic and one foot of sod. ea md 19 ` �' more than 100, feel of uncovered / - tires shall exist c er . time. �....Q Materials other than soil may, be t I aced as a finalonCo6yr Pe Weld Ney are app to County Departinent of Planning Services, Weld County Health DDeepar Department, of Health.the Colorado BOARD OF COUNTY COMMISSIONERS Subscribed and s r to before WELD COUNTY, BY: DONALD D.WARDEN f WELD COUNTY CLERK BOARHED me this ar day of ,i4 ey1Lz.ti , BY: Carol A.Harding.Deputy 91 DATED: June 5 1991 in The LISHNew ND News August 1, 1991 4,,k/nn A 11 i 71II.4-1<H..-+ 1 Myco� l� �ch15:1�" �1 99 NOTICE Pursuant to the zoning laws of the State of Colorado and the Weld County Zoning Ordinance, a public hearing will be held in the Chambers of the Board of County Commissioners of Weld County, Colorado, Weld County Centennial Center, 915 10th Street, First Floor, Greeley, Colorado, at the time specified. All persons in any manner interested in the matter are requested to attend and may be heard. Should any interested party desire the presence of a court reporter to make a record of the proceedings, in addition to the taped record which will be kept during the hearing, the Clerk to the Board's Office shall be advised in writing of such action at least five days prior to the hearing. The cost of engaging a court reporter shall be borne by the requesting party. BE IT ALSO KNOWN that the text and maps may be examined in the office of the Clerk to the Board of County Commissioners, located in the Weld County Centennial Center, 915 10th Street, Third Floor, Greeley, Colorado. DOCKET N0. 91-34 Tire Mountain, Inc. Jarrald A. and Faye L. Jamison 12311 Weld County Road 41 Hudson, Colorado 80642 DATE: August 14, 1991 TIME: 10:00 A.M. REQUEST: Hearing to SHOW CAUSE for revocation of Special Use Permit 11842, issued to Tire Mountain, Inc. LEGAL DESCRIPTION: Part of the SE* of Section 32, Township 3 North, Range 65 West of the 6th P.M. , Weld County, Colorado ISSUES: 1. Whether or not the uses currently conducted on the site are in violation of Development Standard 113c, which states: "No more than 2 trenches shall be excavated and exposed or filled at a time." 2. Whether or not the uses currently conducted on the site are in violation of Development Standard #6, which states: "Tires shall be placed across the width and to the top of each trench before proceeding lengthwise along the trench. " 911;998 3. Whether or not the uses currently conducted on the site are in violation of Development Standard 117, which states: "Within 30 days of filling a trench with tires, the trench shall be covered with no less than a 20-mil plastic and one foot of soil. No :more than 100 feet of uncovered tires shall exist at any time. Materials other than soil may be used as a final cover provided they are approved by the Weld County Department of Planning Services, Weld County Health Department, and the Colorado Department of Health. " BOARD OF COUNTY COMMISSIONERS WELD COUNTY, COLORADO BY: DONALD D. WARDEN WELD COUNTY CLERK TO THE BOARD BY: Carol A. Harding, Deputy DATED: June 5, 1991 PUBLISHED: August 1, 1991, in The New News 91.C998 SHOW CAUSE DATE: August 14, 1991 CASE NUMBER: ZCH-73 USR NUMBER: Amended USR x/842 OPERATOR/OWNER Tire Mountain, Incorporated Jarrald A. and Faye L. Jamison 12311 Weld County Road 41 Hudson, CO 80642 LEGAL DESCRIPTION: Part of the SE4 of Section 32, T3N, R65W of the 6th P.M. , Weld County, Colorado. LOCATION: 12311 Weld County Road 41, Hudson, Colorado. It is the opinion of the Department of Planning Services' staff that the following Standards, as approved for Jarrald A. and Faye L. Jamison are not in compliance. Development Standard #3C states : A maximum of 25 storage trenches shall be constructed for tire storage as follows: C. No more than 2 trenches shall be excavated and exposed or filled at a time. A total of Five cells (three trenches) are exposed at this time. The required cover was not complete on any of the cells. Development Standard #6 states: Tires shall be placed across the width and to the top of each trench before proceeding lengthwise along the trench. Tires are not being placed in the trenches across the width and to the top of each trench before proceeding lengthwise along the trench. Development Standards #7 states: Within 30 days of filling a trench with tires, the trench shall be covered with no less than a 20-mil plastic and one foot of soil. No more than 100 feet of uncovered tires shall exist at any time. Materials other than soil may be used as a final cover provided they are approved by the Weld County Department of Planning Services, Weld County Health Department, and the Colorado Department of Health. Trenches are not properly covered and more than 100 feet of uncovered tires exist at this time . 91C998 LIND, LAWRENCE & OTTENHOFF ATTORNEYS AT LAW THE LAW BUILDING 1011 ELEVENTH AVENUE P O.BOX 326 GREEIPY.COLORADO 80632 ,- GEORGE H-OITENHOEF TELEPHONE KENNETH F LIND (303)3532323 KIM R.LAWRENCE (303)3569160 TELECOPIER (103)356-1111 June 5 , 1991 Board of County Commissioners Gordon E. Lacy, Commissioner 915 Tenth Street Greeley, CO 80631 Re: USR #842/ACH #73 Dear Commissioner Lacy: In preparation for the August 14 , 1991 Show Cause Hearing we are submitting to you the complete report and evaluation of Mr . Hoynoski . I am sure you will agree his credentials are impressive and we believe his conclusions as well as the written standards of the National Fire Protection Association clearly show why the cells should not be covered. Very truly yours, LIND, & OTTENHOFF Kent& th F. Lind KFL/cg Enclosure C�Cj=' tie) Ktifitc.?„Cris° • LIND, LAWRENCE & OTTENHOFF:7 ATTORNEYS AT LAW THE LAW BUILDING _ 1011 ELEVENTH AVENUE P O.BOX 326 GREELEY,COI.ORAIX)80632 GEORGE H.OTTENHOE1 TELEPHONE KENNETH E LIND (303)1532323 KIM R.LAWRENCE (303)156-9160 TELECOPIER June 5 , 1991 om1356-n11 Weld County Department of Planning Services 915 Tenth Street Greeley, CO 80631 Attention: Keith Schuett Re: USR #842/ACH #73 Dear Mr. Schuett: Enclosed please find a copy of the complete report and evaluation of Mr. Hoynoski regarding the above. Very truly yours , LIND, LA E CE & TENHOFF Kennet F Lind KFL/cg Enclosure 0 \"/ UN it ,, ism Weld C9. DIMISSia N OhL/h. (S ‘ m t NELSON ENGINEERS r GREELEV NATIONAL PLAZA 822 7TH STREET GREELEV, COLORADO 80631 (303)356-6362 May 17, 1990 Austin Buckingham, C.P.G. Hazardous Material and Waste Management Division Colorado Department of Health 4210 East 11th Avenue Denver, Colorado 80220 Re: Tire Mountain, Inc. - Certificate of Designation Dear Ms. Buckingham: In behalf of Tire Mountain, Inc. (owner) , I am requesting an amendment by deletion of inclusion number 1 on page three the Certificate of Designation recommendation as stated in the November 10, 1988 Department letter to Weld County Board of Commissioners . That inclusion, also a condition of the issuance of a Certificate of Designation by Weld County, Colorado to Tire Mountain, Inc. , is included as follows : "1 . All trenches shall be covered with 20 mil plastic and one foot of topsoil as the trench is progressively brought to final grade. No more than 100 feet of uncovered trench shall exist at any point in time. Other materials than topsoil can be used as final cover if they are non-flammable and if erosion control, wind protection , oxygen suppression the aesthetics suitability, etc. , of the alternative materials can be demonstrated. " By this letter, Tire Mountain, Inc. , is requesting that the requirement for cover by plastic and earth be deleted and that the tires in trenches be left uncovered . Included with this letter is supporting data for that request. Herewith I am transmitting one copy each 1 ) January, 1990 report prepared by High Country Engineering entitled Evaluation of Alternataive Covering Material; 2 ) the January 16 , 1990 letter from Nelson Engineers to Platteville Fire Protection District ; and 3 ) the February 6 , 1990 letter form Platteville Fire Protec- tion District to Nelson Engineers . The subject of that report and the letter is cover over the tires in trenches at Tire Mountain. Each document is self explan- atory with the report concluding that there is no compelling reason to cover the in-trench tires and that open uncovered cells of waste tires is the preferred practice. The Platteville Fire Protection District , upon review of all material, is no longer requiring cover over the tires since the District agrees with the report which recommends no cover over the tires . 911;398 Upon considering all alternatives, Nelson Engineers continues to support the position of leaving the tires uncovered for the rea- sons outlined in the report, for safety reasons, and because dirt cover on the tires over the long period will surely infiltrate the trenches as it dissipates into the tire mass. The tires should be maintained in a manner free of dirt contamination to have any value for reuse, recycling or other recovery. It is necessary that every effort be made to recycle any potentially recoverable resource, which includes scrap tires. In addition, the evidence supports leaving the tires uncovered as the most effective method of avoiding ignition of the trenched tires and enhances safety to fire fighters and others near the tire trenches . There is increasing justification that waste tires be kept as free of dirt as possible so that they can be recycled or other- wise reused. Placing of dirt over the tires does not necessarily prove to be a more environmentally sound method of disposal. On the contrary, such cover will find its way into the trenched tires to a degree that recycling is rendered impossible. Thus the waste tire storage problem will continue to grow. Even more viable solutions to that problem will be found in the future as the value increases for waste tires because of shortages of other energy sources . A copy of an article from the May, 1990 American City and County magazine, Tire Recycling Catches Fire is also enclosed. In addition, I am enclosing an April 10, 1990 letter with attachments from the Southwestern Portland Cement Company. Tire Mountain, Inc. , and the Cement Company are negotiating for the use or burning of the waste tires being collected at the Hudson facility. Such burning for fuel purposes would be accomplished under stringent conditions as described in the attached approved Special Use Site Specific Development Plan, and Certificate of Designation for Solid Waste Disposal Site, use of tires as fuel for cement manu- facture. The cement company letter points out the importance of the tires being free from dirt in order to be most usable. Upon review of the submitted material, please call me at the earliest possible date to define the next action. Tire Mountain, Inc. , is particularly anxious to obtain a resolution to the tire cover issue so that is can proceed to the next phase of tire storage. Respectfully, NEL ENGINEERS / ��ker� Vern 1C. �Nelson, P. E. LCN/gc Enclosures cc: Tire Mountain, Inc. Kenneth Lind , Esq. 911i998 EVALUATION OF ALTERNATIVE COVERING MATERIAL TIRE MOUNTAIN, INC. WELD COUNTY, COLORADO JANUARY 1990 PREPARED BY: GLENN T. HOYNOSKI , P.E. HIGH COUNTRY ENGINEERING BLACK HAWK, COLORADO %., ) I z1 90 - • TIRE MOUNTAIN EVALUATION OF THE NEED FOR ALTERNATIVE COVERING MATERIAL FOR THE STORAGE CELLS SCOPE The following report is pursuant to a request from Tire Mountain. This report is intended to evaluate the need for tire covering on the tire cells permitted by USR $842. This evaluation assumes that tire recycling will be used at the USR site. This report will evaluate various options and provide documentation as well as relevant background information. We will evaluate the various options , provide an analysis of the risk , develop recommendations and justifications for various alternative methods concerning covering of the tire storage cells. This evaluation is intended to cover only the fire safety aspects of covering the tires at the tire storage facility . According to information provided from Tire Mountain, the scenario involving tire recycling will be utilized . According to the recommendations from the State Department of Health, all trenches must be covered with 20 mil plastic and 1 foot of top soil as the Trench is brought to -grade with no more than 100 feet of uncovered tires existing at any point in time. The recommendation from the State includes the statement that other materials can be used as a final cover if they can be proven to be non—flammable and provide erosion control, wind protection, oxygen suppression and esthetic suitability . These recommendations were incorporated into the Certificate of Designation by Weld County. This evaluation will address the above items in the context of fire safety and will determine what alternatives are available and the most cost effective means to provide a safe facility in accordance with the intent of the applicable regulations . Based upon information previously submitted , it was recognized that a final solution to the tire covering issue had not been developed . The previous documentation indicates that research and development on the alternatives to tire covering would be researched with final recommendations in the form of a plan submitted for approval . The various alternatives that were to be explored were as follows : 1 . Cover the tire cells with fire retardant plastic , maintaining ballast with tire strips and the edges only covered with soil. 2. Cover the tire cells with fire retardant plastic and cover with 1 foot of soil as ballast. 91.0998 -1- TIRE MOUNTAIN EVALUATION OF THE NEED FOR ALTERNATIVE COVERING MATERIAL FOR THE STORAGE CELLS SCOPE (CONT' D) 3 . Cover the tire cells with fire retardant plastic and ballast with waste tires and the edges with the sidewall of tires. 4 . Investigate other practical ways to safely maintain the tires and storage . The above items were evaluated as to their application, suitability and level of safety provided . According to the recommendations from the Colorado Department of Health it was imperative that any materials used must be tested to determine that they exhibit fire retardant characteristics. The applicable test standard for flammability is NFPA #701 , "The Standard Method of Fire Test for Flammable Resistance." Various plastic materials were researched in order to evaluate which materials exhibit the necessary characteristics in order to satisfy the site objectives for use as a cover material. Previous research has indicated that only a fire retardant plastic would be considered acceptable in terms of satisfying the intent of the parameters established by the Colorado Department of Health. PLASTIC COVERING ALTERNATIVE Our firm evaluated various plastic materials which might be considered acceptable for this application. We found considerable difficulty in locating materials for utilization in this application. This was due to the fact that most large sheet plastic installations have not been tested to satisfy the building or fire code requirements. The only testing that we are aware of has been for fabric materials that may be used for tent applications . In general the low cost plastics that are typically available have not been specifically tested for flammability characteristics and would not satisfy the fire safety criteria imposed by the state. In this application, the plastic cover material must also be sunlight resistant. The plastic materials evaluated do not lend themselves well to characteristics such as sunlight resistance. In the event that the tire cells are covered with only fire retardant plastic without using top soil , the plastic material must then exhibit both fire retardant characteristics as well as resistance to sunlight and maintain a reasonable service life for the life of the facility . During the course of the evaluation of the fire retardant plastics which are commercially available , it was determined that the life expectancy of the acceptable plastic material would be in the range for 2 to 3 years due to the limitations of sunlight- resistance and ultraviolet penetration. 91.699 -2- TIRE MOUNTAIN EVALUATION OF THE NEED FOR ALTERNATIVE COVERING MATERIAL FOR THE STORAGE CELLS PLASTIC COVERING ALTERNATIVE (CONT'D) The alternatives. explored include covering the tire piles with plastic and other materials for ballasting. All concepts rely on the premise that a plastic covering material is readily available with necessary characteristics to perform all the requirements stated above. In addition the practicality of using a plastic cover should be considered in terms of the cost for implementation. Based upon the preliminary cost estimates of using materials which satisfy the fire retardant characteristics necessary , this represents a cost of $8 ,500 per cell for the plastic covering material only . The cost for the installation would be additional. The fire test used to demonstrate the flammability characteristics of fire retardant plastics includes exposure from a bunsen burner . The report ignition temperature of plastic sheet material is approximately 660 0F. The reported ignition temperature of rubber tires is 700 F. When comparing the susceptibility of ignition of fabric materials relative to that of rubber tires, it is obvious that the risk of ignition based on the documented ignition temperatures of plastic covering materials is greater than that of rubber tires. Consequently by providing a fire retardant plastic cover will provide no additional level of fire safety for the facility than if the tires are left exposed. PLASTIC AND EARTH COVER In the event that the plastic cover would be covered with dirt , there is no practical means to provide for the removal of such soil without damage to the plastic cover . Consequently , the tires that are to be recycled would be filled with soil and create a loss of recycling operation for which this storage facility is intended . This particular item has not been resolved by any of the individuals evaluating this. The tires stored in the cells will compact resulting in an uneven surface and the plastic liner will not be able to withstand this movement and be able to maintain the surface without tearing. In addition, if the plastic were to be covered with earth the plastic will tear easily when covered and again avoid the practical tire re-utilization that is anticipated with this recycling operation. 1.0998 -3- TIRE MOUNTAIN EVALUATION OF THE NEED FOR ALTERNATIVE COVERING MATERIAL FOR THE STORAGE CELLS PLASTIC AND EARTH COVER (CONT' D) The practicality of covering the tires with plastic and earth must also be considered in terms of cost and benefit. If the tires are covered in this fashion there is no possibility for reclamation. Although this alternative is plausible for the final disposition of the tires , this is not the case under the present operating scheme which contemplates recycling of the tires. The cost involved to provide a plastic cover and cover with dirt would be in excess of $5 ,000 excluding the cost of the plastic. In the process of accessing the tire piles to install the plastic cover, the likelihood of tearing the plastic is greater . In addition, the installation of the earth cover is going to be difficult. Although this approach provides slight benefit , it eliminates the primary basis for the tire recycling operation. FIRE RISK A previous report , conducted by High Country Engineering , dated November of 1988 (see attached) addressed the requirements for tire cell separation and need for berms within the storage cells in order to minimize fire spread from cell to cell assuming a fire were to be started in any single cell. In that analysis , it was anticipated that the spacing and placement of berms, access roads and the spacing of tire cells was predicated on the basis of a fully involved fire and the incident radiation on adjoining tire piles. That analysis provided the basis for the spacing of the tire cells . During that analysis it was assumed that the tire piles were not protected with any covering material(s) . The recommendations for the tire cell placement and utilization of berms and fire access roads have been agreed upon and incorporated by the Planning Commission and incorporated by the Weld County Commissioners for implementation into the approval as part of the Certificate of Designation. Consequently, that was the basis for the arrangement of the tire cells and subsequent approval. When considering both the issue of the plastic covers on the tires and the plastic covers with the earth, neither of the alternatives appear to serve a practical solution for the storage of these tires based upon the results of incident radiation on adjoining cells . The results of the fire protection analysis and recommendations provided in our report date November of 1988 would not change at all as a result of the need to cover or not to cover the tires . We have previously conducted a fire risk assessment associated with the tire storage cells that would potentially ignite the tires at this site. Our previous evaluation concerning the likelihood of ignition indicated that lightning was the only 91.(199T3 -4- TIRE MOUNTAIN EVALUATION OF THE NEED FOR ALTERNATIVE COVERING MATERIAL FOR THE STORAGE CELLS FIRE RISK (CONT' D) credible risk that existed . The evaluation utilized the risk assessment guide provided in NFPA #78 , "The Lightning Protection Code." This includes such factors as the type of construction, relative location, size and height , topography of site and surrounding areas , type of occupancy and the number of thunderstorms in the general area. In considering that some of the factors are not specifically a-pplicable , the analysis suggested that the risk of lightning in underground trenches is almost non—existent when compared to above ground storage . The net result is that the use of plastic covering on the tires will not provide any degree of added fire safety for the facility . In fact the fire retardant plastic poses a higher risk of ignition than the tires themselves . FIRE PROTECTION AND PREVENTION We had previously examined other fire causes and recommended that fire prevention and protection measures be incorporated in the site emergency plan. Based upon the incorporation of the on— site fire prevention practices and the implementations of our recommendations for cell separation , establishment of a fire water supply and fire fighting procedures, it would appear that the level of fire risks is minimal at the site. None the less if a fire would occur adequate provisions for fire fighting and active fire suppression were considered appropriate for the facility. In the unlikely event that a fire is ignited in any cell, the emergency fire operations need to know the nature of the fire and the best way to contain it. One means to suppress the fire is the application of water particularly in the early stages of the fire. However , the primary fire suppression efforts should rely upon the heavy earth moving equipment which will provide the fire control required . The available earth on the site adjoining the cells provides the most practical fire extinguishing medium. In order to employ fire suppression agents (water and earth) and to be effective there must be no cover over the tires . Any covering material may inhibit the fire suppression activities . The newly adopted NFPA standard for storage of scrap tires is more than satisfied with the arrangement proposed . This facility provides a safer arrangement than is proposed under the Appendix to NFPA #231D Standard. This is true since the NFPA code contemplates above ground tire storage of whole scrap tires . The code establishes fire protection based upon minimizing the size of storage piles and control of ignition sources. .910998 . -5- , _. r TIRE MOUNTAIN EVALUATION OF THE NEED FOR ALTERNATIVE COVERING MATERIAL FOR THE STORAGE CELLS FIRE PROTECTION AND PREVENTION (CONT'D) The tire storage arrangement in this specific application is in below grade cells and as such provides a higher level of safety from ignition risks and minimizes risk of exposure from fires from one tire cell to another . Additional safety factors, such as personnel and or equipment near the edge of the tire cells may create an unsafe condition. Considerations such as emergency personnel and equipment driving into the tire cells during non—daylight hours may create a safety hazard for both personnel and equipment. This condition would be less likely if the tires were exposed . SUMMARY Based upon the above review including the anticipated recycling program, the impracticality of covering the tires with plastic and/or earth, the cost necessary to provide the alternative covering, the lack of any increased level of fire safety , the level of safety to fire fighters and the effectiveness of fire extinguishing efforts all lead to the conclusion that there is no need based upon fire safety criteria which justifies any covering material on the tires under the recycling mode of operation. In conclusion, the open cell storage of tires will provide a safer storage arrangement due to safety of site personnel, safety of emergency response personnel and the application of fire fighting agents. 91.0998 -6- — _. - 231D-12 STORAGE OF RUDDER TIRES . Automatic sprinklers can be expected to operate within Appendix C Guidelines for Outdoor Storage • 2 to 5 minutes of ignition.At this point, the fire has goner. of Scrap Tires ally progressed beyond the stage where extinguishers are effective and within a few minutes, smoke will make the area untenable and vision will be completely obscured. C-1 General. The intent of these recommendations is Active Stage. At this point, the building is untenable to provide fire protection guidance to minimize the fire hazard in areas for outside scrap tiro storage. Each indi- and obscured vision makes the use of hose streams ques- tionable. It is best to allow the-sprinklers to take conirol vidual property will have its own soccial conditions of tire - of the fire. Most sprinklers will have operated within 15 handling, exposure, and topography. For this reason, only • to 20 minutes of ignition if control is to be effected. basic fire protection principles are being considered herein Sprinklers should be allowed to operate at least 60 and which are intended to be applied with due consideration preferably 90 minutes. During the period the building is of the local factors involved. The authority having jurisdic- best left unventilated.As control of the fire is gained,smoke icon should be consulted in all cases. will tend to change from black to gray and ditninish in in- Rubber has a heat combustion of about 15,000 BTU's tensity. During this period at least six charged 11/2-in. per pound,or roughly twice that of ordinary combustibles (38-mm)hose lines should be laid out preparatory to enter- (that is, paper and wood). Once ignited, fire development ing the building. Portable floodlights should be secured as is rapid and high temperatures can be expected,due to the well as raincoats,boots,helmets,breathing apparatus,etc., • large exposed surface area of tires.Burning is likely to per- for the overhaul crew. sist for hours. In cases.where the fire is controlled, re- kindling is a possibility. Critical Stage. After 60 to 90 minutes and when These recommendations are not intended to apply to smoke intensity has diminished, the building should be ven- storage of shredded tires (chips, granuals, etc.). tilatcd around the periphery of the suspected fire location. During this period close observation should be made of C-2 Definitions. Unless expressly stated elsewhere, the smoke conditions. If smoke generation increases,cease ven- following terms will for the purpose of these recommen- tilating and close up building if possible. , dations have the meanings indicated below: • Aisle. An accessible clear space between storage piles Overhaul. As soon as smoke dears to the extent that the building can be entered, entry should be made with groups ec piles suitable for housekeeping operations, vi small hose streams which should be directed into burning vi inspection of piling areas, and initial fire fighting tires. Sprinklers should remain in operation unless the fire operations. chief is certain that hose can control the fire. Clear Space. Any area free of combustible materials. Fork trucks and other means should be employed to This does not preclude the storage of noncombustible remove tires from the fire area. It will usually be necessary materials that will not transmit an exposure fire. to keep sprinklers and/or hose streams in operation dur- ing this procedure at least until all evidence of flame is Fire Lane. A clear space suitable for fire fighting ac- gone. Patrols should be made in affected area for 24 hours cess and operations by motorized fire apparatus. following the fire. . In the event that control of the fire is lost as evidenced Yard. The outdoor areas where scrap tires are stored. by increasing smoke generation,loss of pressure at fire - pump discharge(indicating massive sprinkler operation), Units (equivalent passenger). One average size collapsing roof,-etc., efforts should be directed towards passenger tire weighing approximately 25 lb (11 kg). preventing the spread of the fire beyond the area bounded ' - by the fire walls. At this point, consideration should be Scrap Tire. A tire that is no longer suitable for given to shutting off sprinklers in the fire area to provide vehicular use. water for protecting the exposures. , C-3 Fire Experience. - ' Use of High Expansion Foam. If a high expansion C-3.1 Fire experience in outdoor storage of scrap tires foam system is used in connection with automatic sprink- -reveals a number of concerns, including: the generation lers, sprinklers may be shut off 1 hour after ignition and of large amounts of black smoke; the fact that the storage an additional 1-hour soaking time for foam allowed before is often too close to buildings on the same or adjacent the building is opened up and overhaul begun. Limited premises, causing fires in these exposed buildings; the tests with high expansion foam indicate that fire extinguish- generation of oil during the fire where the oil contributes ment is largely complete after a period of soaking in foam. to the fire or where the run-off will contaminate the sur- As a precautionary measure, charged hose streams should rounding area; delay in reporting the fire; and the lack of be available when foam is drained away. fire fighting capabilities.The fire hazards inherent in scrap After the initial fill,foam generators should be operated rubber tiro storage are best controlled by a positive lire periodically during the soaking period to maintain the foam prevention program which would include the intent that level. This is necessary since sprinklers and products of a fire would be contained to the pile of origin and limiting combustion will cause partial foam breakdown. the exposures to other piles or associated structures. C-3.2 Fire Prevention. C-3.2.1 The fire hazard potential inherent in scrap Lkill;, 1069 Emiwn •.,'J5. !�' '"; • APPENDIX c 231D-13 ber tire storage operations can best be controlled by a C-4.2.2 Means of protecting the building exposed by \--tee/ positive fire prevention program.The method of stacking burning tiro storage may be selected from NFPA 80A, should be solid piles in an orderly manner and should Chapter 3, and separation adjustments may be based on include:. . . • building construction and protective measures as given in (a) Fire lanes to separate piles and provide access for NFPA 80A, Chapter 4, except that the separaton should effective fire fighting operations. • never be reduced below that necessary for fire fighting ac- (b) Separation of yard storage from buildings and other cess. (See Scotian C-9.3.) exposures. \- �' C-4.2.3 Table C-4.2.3 gives representative separations (c) An effective fire prevention maintenance program between exposed building and piles or between isolated including control of weeds, grass, and other combustible piles, materials within the storage area. (d) The topography should be considered since in fire conditions, oil accumulations or run-off can be expected. Table C-4.2.3 Representative Exposure Scrap tire storageshould preferably be on a level area. Separation Distance ,`,�' • Tire Storage Pile Height C-3.2,2 Appropriate steps should be taken to limit ac- s to 12 14 16 18 20 cess to the tire storage area. Acceptable access should be a ii 25 56 62 67 73". 77 02 05 provided for fire fighting equipment. c, 50 75 04 93 - 100`5.- 107 113 110 2 ii leo 100. 116 120 137. 146 155 164 G-4 Et aaure Protection. Vii 150 117 135 149 164 170 109 190 P ist Hh 200 130 119 167 - 103 190 212 226 C-4.1 For 500 units or less a minimum separation be- 250 140 162 I01 190' 216 231 245 NOTE: Separation distances are hisnl on NFPA 00A,Chapter 2,using tween scrap rubber tires and structures should be 25 ft (7.6 m) minimum or as reduced by Chapter 3, "Means a factor of 1.5 in accordance with C-4.2.1(a). of Protection," and Chapter 4, "Application of Means of Protection," of NFPA 80A,Recommended Practice for Praia- C-4.2.4 Because of the extensive fire expected in scrap lion of Buildings from Fire Exposures. tire storage some form of exposure protection for adjoin- • ing properties should be considered.:If the dear space as C-4.2 For More than 500 Units. recommended in Table C-4.2.3 cannot be provided, pro- vide a dirt berm 1'% times the height of the tire storage. C-4.2.1 The minimum distance between outside scrap • v rubber tire storage and buildings should be determined in C-4.2.5 The distance between storage and grass,weeds, accordance with the intent and provisions of NFPA 80A, and brush should be 50 ft (15 m).:!..': RuommendedReulicejorRokclionufDuiGlingrfiomExtenarFire ' Exposures..Since ie is based on exposure from a burning C-4.3 Fire Fighting Access ,. building,restrictions are needed for application to an out- C-4.3.1 Maximum pile height should be 20 ft(6 m). Pile side storage configuration. width and length should not exceed 250 ft(76.2 m)without (a) The height of exposing fire from burning trees should a separation according to.Table C-4,2.3. Dirt berms may be taken as 1.5 times the height of the tire pile since flames lie used in lieu of cross aisles in accordance with C-4,2.1(b). extending above the burning tires contribute to the size (See Figure C-9.3.1.) of the radiation surface area. The height of the exposing fire, per NITA BOA, is the building height. Height of com- C-4.9.2 The fire department should be consulted for ad- . bustibles stored within the building is not mentioned; it vice on provision of all-weather roadways to and within would be inherent in the selection of the severity of the ex- the storage area. Depending on storage area configuration posure fire:A comparative building height would have to and size, access obstruction(river,railroad yards), prevail- exceed height of piling by several feet at least, and could ing wind direction, alternative tactics, etc., fire fighting be substantially higher. Furthermore, the height (and strategy may require one or more aisles to be wider than width) of flames above.a fire-penetrated roof would be those described in C-4.3.1. �— substantially influenced by the debris of the fire-damaged or collapsed roof, whereas flame height above yard storage C-4.3.3 Pre-emergency planning should be made with would have no such restraint. the local fire protection agency so that fire emergencies can (b) The width of the exposing fire should be taken as be properly handled in the tire storage facility. the accumulative width of piles facing the exposed building, • • with disregard for the nominal separation between piles C-5 General Fire Protection. provided by narrow access aisles and roadways. In order C-5.1 General. ..—' for storage piles to be considered isolated piles, the mini- mum separation distance between piles should be in accor- C-5.1.1 Weeds, grass, and similar vegetation should be dance with Table C-4.2.3. This distance can be reduced eliminated throughout the entire yard. Combustibles to that necessary to provide a dirt berm at least 1'h times should be removed as they accumulate. the height of the pile. C-5.1.2 Smoking should be prohibited within the tire (c) Percent of opening in exposing wall area should be considered to be 100 percent, storage area. Othertypes of potential ignition sources such as cutting and welding, heating devices, open fires, etc., (d) Severity of exposing fire should considered as severe. should be prohibited. 4g�r7� � °1.V 998 19119 Fdilian • 231D-14 STORAGE OF RUDDER TIRES 250' Max. bi J Distance by Table C-4.2.3 250' Max, Tire Pile Distance by —_I Table C-4.2.3 1 Tire Pile s r t . Distance by Table C-4.2.3 Building (or Dirt Berm 1 1/2' limos Pile Height) Cross Aisle • • .. �i Tire Pile Main Tire Pile Aisle Figure C-4.3.1 'tire Pile Arrangement. • C-5.1.3 Suitable safeguards should be provided to mini- Appendix D Referenced Publications mize the hazard of sparks from such equipment as refuse burners, boiler stacks, vehicle exhaust, etc. D-1 The following documents or portions thereof are �„J C-5.2 Water Supplies. referenced within this standard for informational purposes only and thus should not be considered part of the require- C-5.2.1 Either a public or private fire main and hydrant system should be provided.A water system should be pro- menu of this document. The edition indicated for each vided to supplya minimum of 1000 gpm(3780 Lmin)for reference is the current edition as of the date of the NFPA less than 10,000 units storage, or 2000 gpm(7560 Umin) issuance of this document. for 10,000 units or greater for a duration of 3 hours.. • D-1.1 NFPA Publications. National Fire Protection C-5.2.2 If there is access to a lake,stream, pond,or other Association, Batterymarch Park, Quincy, MA 02269. body of water in the vicinity of the storage area a fire NFPA 10-1900, Standard for Portable Fire Extinguishers department suction connection should be provided. NFPA 13A-1907, Recommended Practice for the Inspection, C-5.2.3 If fire hoses arenot immediately available from Tilting and Maintenance of Sprinkler Systems responding public fire departments,on-site storage of 1000 f[ NFPA 600-19II6, Rccommrndatioru jot Organization; Train- (304.8 m) of 2'b-in. (63-mm) hose and sufficient nozzles ing and Equipment of Private Fire Brigades should be provided. In addition to water hose streams,high NFPA 80A-1987, Recommended Practice for Protection of expansion foam may be used to control or extinguish scrapBuildings from Exterior Fire Exposures. tire fires. • C-5.2.4 Bulldozers, front-end loaders and similarequip • - ment can be used to move tires not yet involved in the fire, to create breaks in the tire pile or to cover burning tires with soil. 916998 1989 Edthon Glenn T. Hoynoski , P.E. ACADEMIC Bachelor of Science degree in Fire Protection -- - - .. Engineering from the University of. Maryland , 1975 . At the _ present time , the University of Maryland is the only school with an accredited baccalaureate degree program in fire protection engineering recognized by the engineering profession . EMPLOYMENT 5/85 - present : President of High Country Engineering, Black Hawk , Colorado . Formed the company in May 1985 to serve business and industry with a wide variety of engineering services relative to the fire protection and building construction industry . 10/83 - 5/86 : Corporate Fire Protection Engineer for the Adolph Coors Company in Golden , Colorado . Responsible for the initial implementation of a multi-million dollar program to upgrade life safety features in the existing company facilities , including alarm systems , egress , emergency and exit lighting ; implementation of a multi- . million dollar process safety upgrade of grain handling systems for the brewery complex ; evaluation of new facilities , processes , and modifications to existing processes which introduce additional fire and explosion - risks to the plant , personnel , and its continuing operation ; i jimplementation of a program of fire protection equipment maintenance for all the existing fire protection and detection systems ; development of plant-wide emergency plans , personnel training programs and coordination of same with outside emergency response agencies; investigation of plant fires and emergencies with follow-up evaluations and critiques , to minimize future plant and personnel risks and coordination of new building plans and modifications with local fire officials . 6/78 - 8/83 : Loss Prevention Engineer for Marathon Oil Company , Findlay , Ohio. The company utilized the loss prevention expertise to minimize company risk through comprehensive site inspections and evaluation reports identifying deficiencies in fire protection , process safety and controls , administrative procedures , as well as fire prevention and building code issues. Responsible for conducting site inspections for all domestic facilities loperated by the company , including petroleum refineries , gas plants , offshore oil and gas drilling and producing 1platforms , pipeline and storage facilities , and other miscellaneous support facilities . 1/76 - 7/58 : Fire Protection Engineer for Tennessee Valley Authority . Responsible for the development of design criteria and technical specifications for fire protection systems and related sub-systems , water supplies , fire pumps , water distribution systems , sprinkler systems , standpipe systems , carbon dioxide systems , fixed water spray systems , foam systems , Halon fire protection systems , and gas detection equipment ; also responsible for the coordination 910998 of architectural , electrical , and mechanical installations with respect to the overall facility fire protection design concept — this work primarily involved nuclear power plants , but also included development of retrofit programs for ' existing fossil—fueled and hydroelectric power plants . PROFESSIONAL ACTIVITIES Active in the development , as a charter member , of the I' Rocky Mountain Chapter of the Society of Fire Protection Engineers . Participated as a member of the Executive Committee of the Chapter since 1983 , and served as Chapter President during the years 1985-1986 and 1986-1987 . Active in the Colorado Sierra Fire Protection District in Gilpin County , Colorado . Chairman of the five—member fire district Board of Directors since June , 1984. Member of ICBO and the Colorado Fire Marshals' Association . Registered as a Professional Engineer in Colorado , Wyoming , California , New Mexico, Ohio, Utah, and South Dakota. 91.0998 i FIRE PROTECTION EVALUATION FOR SCRAP TIRE LANDFILL TIRE MOUNTAIN , INC. WELD COUNTY, COLORADO • DECEMBER 5 , 1988 PREPARED BY: GLENN T. HOYNOSKI , P.E. PRINCIPAL ENGINEER HIGH COUNTRY ENGINEERING BLACK HAWK , COLORADO 91099'8 I • i REPORT CONTENTS SECTIONS PAGE NUMBER I SCOPE 2 II REFERENCES 3 I III DEFINITIONS 4 IV INTRODUCTION 5 V ANALYSIS 6 VI RESULTS 12 VII RECOMMENDATIONS 14 VIII CONCLUSION 17 IX COMPANY QUALIFICATIONS 18 -1- 31099`3 I . SCOPE This report has been developed to provide Mr. Jerrold A . Jamison the owner of Tire Mountain , Inc . , an independent fire safety review of the proposed scrap tire landfill , located at 12311 Weld County Road 41 in Hudson, Colorado . The situation which prompted the concern about this facility was a fire involving a stockpile of used tires. In June , 1987 a fire involving approximately 2 million tires was started by a direct lightning strike at the facility . This report is intended to address the fire safety I concerns of the owner , the local fire jurisdiction and the community . This review and evaluation will address the proposed site layout to develop an acceptable storage arrangement with respect to fire safety . This fire safety review is in conjunction with the permitting and certification requirements from the Colorado { Department of Health. This evaluation does not address the existing conditions with respect to the above ground tire storage . The scope of this evaluation was primarily directed at three issues . 1 . The spacing of the cells used for tire storage with respect to adjoining storage cells and the minimum required distance between the cells to prevent ignition of adjoining cells assuming a fire . ` 2. The need for separation/fire breaks within the individual cells to minimize the likelihood of total involvement within a single cell and the spacing of these fire breaks. 3. The proposed distance between the storage cells as they relate to the requirements for fire department operations and access . The analysis and subsequent recommendations are primarily intended to address the above issues. Other issues with respect to fire prevention , security , control of ignition sources , fire fighting, water supply , etc. were only briefly considered during this evaluation. However , it is recognized that all of these features collectively establish the overall fire safety of the facility. -2- 91.C99t9 II . REFERENCES: i A. Factory Mutual , Loss Prevention Data for Tire Storage , June , 1975 B. Fire Protection Handbook , 15th Edition National Fire Protection Association (NFPA) C. CRC, Handbook of Chemistry and Physics, 61st Edition D. An Introduction to Fire Dynamics , Dougal Drysdal , 1985 E. NFPA 231D , Standard for Storage of Rubber Tires , 1980 F. NFPA 231 , Standard for Indoor General Storage , 1979 G. State of Colorado , Scrap Tire Recycling Regulation , March 16 , 1988 H. The SFPE Handbook of Fire Protection Engineering , First Edition -3- 9I.C('998Qq� i III . DEFINITIONS The following definitions explain some of the terminology used in this report . These terms are characteristic in the fire protection field and are provided here for clarification purposes . 1 . Scrap Tire — A tire that is no longer used for it' s original purpose . 2. Ignition Temperature — The temperature at which an object will begin to burn due to heat from an external source . 3. Heat of combustion — The amount of heat produced from the combustion o£ a particular object , assuming 100% combustion efficiency. 4. Heat Flux - The amount of heat being felt at a distance from the original heat source . 5. Area affected - This is the total area involved in fire at any one time . 6. Radiator - An object which is producing a heat j source . 7 . Exposure - The area which is affected by a heat source . 8. Fire retardant - A treatment which will reduce a materials ability to ignite and support combustion. l9. Fire lane - A road provided for fire department use during an emergency which is designed so as to support and provide enough operating room for the fire apparatus and personnel. 10. Fire separation distance - The distance required between structures or hazards to avoid fire spread from one location to another location. 11 . Radiation - The heat transfer mode from a fire through the air to an adjoining location. -4- 910998 . IV. INTRODUCTION it Facilities which store scrap tires outdoors are not directly addressed in any nationally recognized fire codes . There is very little technical data published with regard to the combustion or combustibility of tires in outdoor locations . Due to the lack of published information , standards and criteria , recommendations have been developed based upon expertise in fire protection engineering along with back—up references from the limited code information data available relative to the protection of hazards . The following evaluation will address the adequacy of I the fire lanes with regard to proper separation distance and fire lane access between the storage cells . The evaluation will also include recommendations to provide for safer operation and maintenance of the facility with respect to fire safety . These recommendations will address design, operations , maintenance and safety for the facility . Based upon the previously described scope this I evaluation 'is intended to : 1 . Determine if the proposed 50 foot separation between storage cells is adequate to limit the spread of fire. 2. Determine if it is necessary to reduce the size of the storage cells by providing fire breaks within each storage cell. 3. Assess the location and design of the proposed fire lanes with respect to providing for fire department access and sufficient area for the fire department to operate in. I V. ANALYSIS A. To determine whether or not the 50 foot separation distance proposed between storage cells is adequate , a set of calculations have been performed . These calculations will consider the surface of half of a storage cell being fully involved in fire and the effect it will have on the neighboring cells . The cells are considered to be divided in half by 50 foot wide earthen barriers. In order to mathematically describe the conditions which occur in a fire the characteristics of the fuel must- be considered . The technical data for the combustion of rubber tires was not available from the customary fire protection reference sources. Consequently the analysis was based on the observed estimated flame height of 100 feet. This is from discussions with the Platteville fire department personnel and actual experience . This analysis will calculate the amount of heat that will be felt on a storage cell adjacent to one fully involved in fire. The result of this calculation will determine whether or not the 50 feet distance between storage cells will be sufficient to prevent ignition of neighboring storage cells. Calculations such as these are used in United Kingdom and by the hydrocarbon processing industry to determine safe distances between buildings or storage tanks i❑ order to prevent the ignition of adjoining structures or processes from radiant heat. The calculations will determine how much heat energy is being radiated from a fire and the amount- of heat energy being received at the adjacent storage cells. These results will be used to determine if the separation distance is adequate. All mathematical equations used are from "An Introduction to Fire Dynamics" . These calculations do not consider the effects of weather. The calculations also assume very high combustion efficiency with an adequate air supply to support combustion. In actual practice the fuel supply will be limited . -6- V. ANALYSIS (CONT' D) STEP 1 : CALCULATE THE RATE OF NEAT RELEASE FOR THE FIRE. i ac_ [01+1 . n2Dl 2 . 5 0 . 23 JJ R=30. 48m ( 100 FT) Estimated flame height from observations D=7/4A =equivalent diameter for a l� 7y rectangle A=7G . 2m x 31 . 09m =2 , 3G9 . 1m2 = area of ell ( 25 , 491 . 1 FTC) D=54 . 9m ( 180. 2 ft) Qe= 1530 . 48 f 1 . 02 (54 . 9g2 . 5 LL 0 . 23 2 . 74 x 106 kW STEP 2 : CALCULATE THE RELEASE OF RADIANT ENERGY BY THE FIRE *NOTE: THE AMOUNT OF RADIANT NEAT OBSERVED ON A DISTANT OBJECT IS 30 PERCENT. . . • • QR=0 . 3 Qc Qc=2 . 74 x 106 kW (Prom Step 1 ) QR=8 . 22 x 105 kW —7- 2)1.699ct3' V. ANALYSIS (CONT' D) • STEP 3 : CALCULATE THE NEAT FLUX AT THE ADJACENT CELL 50 FEET AWAY AT I POINT "T" OF FIGURE 2 . cos m 4 = Q R r T or R2 QR=8 . 22 x 105 kW (Prom Step 2 ) 6) =arctan (1/2) 2 d j=30. 48m ( 100 ft ) Flame Height d=30 . 79m ( 101 ft ) Distance from center of flame to adjacent cell 0 = 82. 5 degrees R=y (X/2) 2 4- d2 R=34 . 4m 8 . 22 x 105 cos 82 . 5 4 T= rr 4 71' ( 34 . 4) 2 • Z qr ,T=7 . 22 kW/m it V. ANALYSIS (CONT' D) i FIGURE 1 ( 102 FT) (50 FT) (102 FT) 31 .9m 15.24m 31 .09m 1 . 22m f I I I (4 FT)r - - - - - - - -- - - - F7X / LENGTH = 167. 64m (550 ft) ,I 910998 �I V. ANALYSIS (CONT' D) i FIGURE 2 ESTIMATING THE RADIANT HEAT FLUX RECEIVED AT POINT T FROM A POOL FIRE, DIAMETER D. EQUIVALENT POINT SOURCE AT P. I . qt . ) I1 , . I ) I . , 1 , P`„`, i . 'f I . , • • 1 ``` e r • -ci D -----t _. I • • d "P" is the point source of the radiated heat. "R" is the distance from the point source of the radiated heat to the edge of the adjacent storage cell. "d" is the distance from the center of the burning storage cell to the edge of the adjacent storage cell . "D" is the width of the storage cells . "1" is the flame height of the burning storage cell . "T" is the point at the adjacent storage cell for which the radiated heat is calculated. —10- 21.6398 V. ANALYSIS (CONT' D) B. From discussion with and reviewing the fire fighting apparatus and equipment of the Platteville Fire Protection District , there must be 18 feet distance to set up a truck to pump water and 15 feet to set up the portable tank and that leaves a 1.7 foot driving lane for tankers to use to fill the portable tank. (See Figure 3) FIGURE 3 I I s �'t 5 FT. 50' WIDE TANKER DRIVING LANE FIRE LANE 8 FT. 4 FT. PORTABLE TANK f 15 FT. 15 ' X 15 ' - ( 5 FT. h PUMPER 8 FT. T 5 FT. S.._.. -- T NOT TO SCALE 916 998 _11_ i • VI . RESULTS i A. After reviewing the results of the calculations a heat flux of 7 . 22 KW/m1 is received at the edge of the adjoining storage cell . The radiant heat energy to ignite wood is 12. 5 KW/m2- after prolonged exposure. Since the energy required to ignite rubber tires is not available a comparison to the ignition of wood was used . The chart in Figure 4 will give a better understanding of what the results of radiant heat energy are. The ignition temperature of wood after a prolonged exposure is 662 F. (From Fire Dynamics) The ignition temperature of rubber tires is 700 ° F (from Factory Mutual) . Due to the ignition temperature of rubber tires being somewhat higher than that of wood provides a greater safety factor with respect to possible ignition. The density of the materials also has an effect on the ease of ignition. Generally those materials with a greater density are harder to ignite. Since rubber tires have a greater density than wood the tires are not as likely to ignite as wood with a similar exposure . In comparing the radiant energy required to ignite l combustibles , the ignition temperature and the density of the material indicate that the rubber tires will not ignite under the conditions fevaluated . Consideration must also be given to the fact that 979 of the stored tires in the cells will be separated from other cells by a physical barrier of soil , 50 feet wide . The majority of heat being produced from the fire is directed vertically, dissipated in the air above the fire. Only 30 percent of the energy is radiated to the adjoining storage cell . -lz- 916998 VI . RESULTS (CONT' D) I FIGURE 4 EFFECTS OF THERMAL RADIATION RADIANT }TEAT OBSERVED EFFECT flux (kW/m`) 0.67 SUMMER SUNSHINE IN UK . 1 MAXIMUM FOR INDEFINITE SKIN EXPOSURE. j 6 . 4 PAIN AFTER 8 s SKIN EXPOSURE 10.4 PAIN AFTER 3 s EXPOSURE 12.5 VOLATILES FROM WOOD MAY BE IGNITED BY PILOT AFTER PROLONGED EXPOSURE. 16 BLISTERING OF SKIN AFTER 5 s . 29 WOOD IGNITES SPONTANEOUSLY AFTER PROLONGED EXPOSURE. 52 FIBERBOARD IGNITES SPONTANEOUSLY IN 5 s . D. According to the calculation results , the size of the storage cells is required to be reduced in half from cell size proposed . This is due to fact that an entire cell being involved in fire will produce ' radiant heat energy greater than 14. 3 KW/le; With the cells divided in half, radiant heat energy is reduced to 7.22 KW/m1. C proposed width of the fire a i e w ill provide for reasonable and safe operations of the fire department during emergencies . —13- 9a.0998 VII. RECOMMENDATIONS i A. Storage Cell Separation Divide the storage cells in half with a 50 foot wide 1 earthen barrier to reduce the size of the potential fire . Reducing the sire of the individual storage cells , by providing an earthen separation at the middle , will be beneficial in several ways . It will provide for better access to the stored scrap tires for both , the facility operator and fire department. By reducing the amount of tires in each storage cell , will reduce the size of a fire which will reduce the probability of a fire spreading to adjoining storage cells. • The size and construction of these separations should be similiar to that of the barriers between the storage cells. B. Fire Lanes The construction of the fire lanes between cells shall be able to support a weight of 50,000 pounds . Consideration must be given to fire apparatus operating while in a parked mode , within two feet of the edge of the fire lane and water spilling onto j the roadway surface during fire fighting operations. I These fire lanes must be kept unobstructed and driveable at all times of the year . C. Water Supply The irrigation wells for water supply sources will flow a sufficient amount of water to provide for exposure protection and limited containment purposes . They are located within reasonable j proximity to the tire storage facility to provide application of water in a timely manner . -14- I i VII . RECOMMENDATIONS (CONT' D) t D. Fire Fighting Procedures 1 • The primary means to extinguish a fire in a storage cell will be to smother it by piling dirt on top with equipment available at the site. This equipment must be maintained and kept g order at all times.e , on site at all times There must personnel capable of operating this equipment. 2• The following equipment must be readily Tire availMountainable to on an on—call mobilize the event of a fire at call bads , 1 —8 Yard Terex Loader 1 —3 Yard Fiat Allis Loader 1 1 —1 1/2 Yard Drop 50 Backhoe —11 Yard John Deere Elevating Scraper 1 —D—B Caterpillar Dozer 1 —D-7 Caterpillar Dozer 3 —18 Yard Caterpillar Scrapers 3 . The secondary or back—up resources will be the local fire departments to assist with containment and exposure protection. 4. Hand held portable fire a minimum extinguishers of rating of 4A-40B—C should be kept on service equipment to provide for a means to put out a small fire quickly. All plant employees should be trained in the proper use of fire extinguishers. 5. A means must be to provided for immediate notification to the local fire department of a fire at the facility. This can be accomplished using the existing phone system. This should always be the first- action prior to attempting fire control , —15- 01C998 4 VII. RECOMMENDATIONS (CONT'D) E. Facility Fire Prevention 1 . Maintain the storage area so other combustible materials do not accumulate to create a hazard . 2 . Vehicles should not be stored in the tire storage area so as not to create an exposure hazard . 3 . At the present time, continuous monitoring of the site is provided . This must be maintained . 4. The facility management should designate an employee to be a facility emergency coordinator. This person should be familiar with all the fire safety requirements and procedures . In case of an emergency this person will be in charge of facility employees and coordinate fire suppression efforts with the fire department. —16- 910398 I VIII . CONCLUSION This review of the layout of the proposed facility , indicates that the design and layout of the storage cells is sufficient to prevent the spread of fire from radiant heat and allow for reasonable fire department access in cases of a fire emergency providing that all of the recommendation included in this report are implemented . The single most important consideration is the capability to readily mobilize fire protection efforts with heavy equipment located on site . The other primary concern is fire prevention practices , which can be controlled through the operator of the facility . Although forces of nature cannot be completely prevented nor controlled , with the layout proposed a fire in one storage cell will not ignite an adjoining cell if immediate efforts are made towards I ' fire control with on-site personnel . With both the fire department and the resources available to the 1 facility operator , a fire in any of the storage cells can be contained and held under control until it is extinguished. The practice of reducing the size of the stockpiles and burying them below grade will provide for a more efficient and fire safe operation particularly when compared to the existing above ground storage . I -17- 21.098 I - IX. COMPANY QUALIFICATIONS BACKGROUND High Country Engineering was founded in 1985 to satisfy a need in the fire protection industry which has existed in the greater Rocky Mountain region. We have established a thoroughly qualified fire protection engineering firm providing specialized fire protection consulting service to business , government and industry. The services typically provided consist of a wide variety of fire protection, prevention, safety , risk analysis design and code-related activities intended primarily to limit loss of life and property due to fire and explosion risks ; secondarily to minimize costly business interruption. The services described below are provided by an experienced team of engineering professionals . GLENN T. HOYNOSKI , P.E. PRINCIPAL ENGINEER Bachelor of Science degree in Fire Protection Engineering, University of Maryland, 1975 . At the present time, the University of Maryland is the only school with an accredited baccalaureate degree program in fire protection engineering recognized by the Engineering profession. Active in the development, as a charter member , of the Rocky Mountain Chapter of the Society of Fire Protection Engineers . Participated as a member of the Executive Committee of the Chapter since 1983, and served as Chapter President during the years 1985-1987. i Active in the Colorado Sierra Fire Protection District in Gilpin County , Colorado . Chairman of the five—member fire district Board of Directors since June , 1984. Member of NFPA, SFPE, ICBO and the Colorado Fire Marshals ' Association. Registered as a Professional Engineer in Colorado , Wyoming , California , New Mexico, Ohio , Utah and South Dakota. -18- ©1Cs`9S -- YIN/ >>,:..; : NELSON ENGINEERS • i • ;r) • ' ' ' GREELEV NATIONAL PLAZA 822 7TH STREET. GREELEV.COLORADO 80637 (303)356-6362 January 16 , 1990 Platteville Fire Protection District Glenn Miller, Fire Marshall P. O. Box 122 Platteville, Colorado 80651 Re: Tire Mountain, Inc. Dear Mr. Miller: The January 1990 report prepared by Glen Hoynoski of High Country Engineering entitled Evaluation of Alternative Covering Material, has been reviewed by me. The report is comprehensive in its evaluation of in-trench scrap tire coverings. The re- search accomplished by Mr. Hoynoski does not reveal any signi- ficant data that provides enlightenment with respect to coverages for in-trench tires. The concepts used at the Tire Mountain facility for fire prevention, fire safety and suppression are apparently not incorporated in any known literature or available research information. Mr. Hoynoski has made evaluations in his report, based on his extensive knowledge and experience, that reflect reasonable and logical conclusions to assure beyond a reasonable doubt that uncovered in-trench tire storage is in fact the most practical method. His point regarding safety of personnel and equipment in the area where uncovered tire trenches exist that can be readily seen is particularly valid . He also points out that in the un- likely event of a fire in the trenched tires , the tire cells as designed can readily be covered by dirt taken from the adjacent fills constructed as access roadways. Mr. Hoynoski ' s research shows that the greatest fire suppres- sant for tires is earth. In this case, earth is readily available and the placement should not be inhibited by artificial cover. Further, the fact that the tested plastics are more flammable than the tires themselves indicates that a fire is more likely to occur and spread if plastics are used adjacent to or on the tires . Platteville Fire Protection District Glenn Miller, Fire Marshall January 17 , 1990 Page Two Mr. Hoynoski ' s report provides no compelling reason to cover the in-trench tires, but rather his conclusion supports the fact that open uncovered cells of waste tires is the preferred practice . I recommend that Tire Mountain, Inc. , be encouraged to follow the recommendations of High Country Engineering. Respectfully, NELSON ENGINEERS /Mg LaVern C. Nelson, P.E. LCN/gc Enclosure cc: Tire Mountain, Inc. Kenneth Lind C" _) Platteville Fire Protection District `g o l I P.O. Box 122 • Platteville, CO.80651 (303) 785.2232 RECEIVED FEB 0 8 mg • Nelson Engineers 2/6/90 822 7th St . Greeley, Co . • Dear Mr. Nelson : As per your reques.t •The ".Platteville Fire District has reviewed the proposal made.`ibt.T,ir'e'Mountain inc . concerning the covering of the tire ' dells, With''d`irt and plastic . After reviewing the report by Mr. Glenn Hoynoski and visiting the sitewe„agree 'wit:l“lietreport in that covering the cells may 'not be •-necesV.4Yi de however insist that all other requirements. o`f . .the permit'M2!41.;strictly adhered to . The Platteville Fire Dis'tric_t�willTbe visiting the site r on a monthly bases . At!',our° la ysi.$it we wer1e -ve(ry pleased with what we observed y' .iri r. t<yF{�0,; .•, 0 i e0J e t—i`t'+�fi,}� ci3E A{''hti C• e�yyp�ye 'r yr` � ;'i F 5S �J t N.'�++��r ic7 3 �N r r Sincerely ®�� ,��e!^i�� `�'3Hy i.7+ r n [Ar"raln i/t/// t /J��/ � av7a. >k,< '^l /� `.GU- L.5 b' -1f�^N`•jr f.��'' r'µ ��ti• t r : Glenn Miller r `(04t.. ,,..nrr4,0e �,E``," . a .4 ,e' ii• .� }: Fire Marshal �' ` 1. x '4 1,,+�'s 0.::"? ti a J S a *1 r�a7,1 4:401 w�'}"-1?+fe e Platteville Fire District � 9 'r(`:�A�JF r vbe yr, �e1° YJ• {Jrlv�+'? (r Cam.;f- vr) , i{v /na v. i.L a P y i≥ '�(A}44Oi -9.P p`y of �sv cc :Tire Mountain ,afi'c t r 1[ `vh f:. (1 ! (Y ) : v v A v i f47 • • 21C998 • RECEII _t9 MAY 0 1 1990 SOUTHWESTERN PORTLAND CEMENT COMPANY `,O0,4„ fret L `' SOUTHWEST DIVISION t7S d~RAno P.O.Wx 529 2104:41.4/ i,r 1. Lvons,COLORADO 80540 `4 4;tin11}TY (303)823-685 ( )! . April 10, 1990 Mr. Jerry Jamison Tire Mountain, Inc. 12311 Weld County Road Hudson, Colorado 80642 Dear Jerry: In the near future, I would like to discuss the possible use of the automobile tires that you presently have stockpiled at your Hudson facility. Our company, Southwestern Portland Cement, has received a Certifi- cate of Designation to receive whole or shredded tires for fuel in our rotary cement kiln. We are presently burning the tire chips and anticipate burning whole tires in the near future. We will need approximately seven hundred fifty thousand (750,000) tires per year if we are successful in burning the whole tires. We will need clean tires (no dirt or water) when we receive them, and also if the stockpile of tires were ever shredded, the tires need to be free of dirt and trash or the cost of shredding them may be much higher because of labor to clean the tires and also higher maintenance cost on the equipment. I will call you in a week to set up an appointment so we can review the storage area. Very truly yours, SOUTHWESTERN PORTLAND CEMENT M��1nlald° Vice President-Special Projects GLA:Iw �I.G998 IwI • OUC'.:.•TF}AS • vKTOIMI l£Vd u.O9rvP • r•Orryjry nor, • fin`. ,.,-.,uM . /WY• � us........+ „host.O6c/a Box 471 •Bouloot.Codorodo 00706 YV$ Y L IrA��,ty�pk J . litil'urlrlr tihc4��rl`4I lit;1 ClUbjeta �� Land Use Department Gdu� ry�h 2(140 tan Sne i•1xM 6 Spnxe Suem•AOMiniwcifre%mees eudong.2ntl ROOT• BODUH.COdorpao 60002•(107)u10v00 '''r.414, 1'e 1 1 J. "N 1 RECEIVED May 30, 1989 JU:J 1 L89 Mr. Gerald Anderson . Southwest Portland Cement Co. LY01 . PLANT Ute Highway Lyons, CO 80540 Dear Mr. Anderson: The purpose of this letter is to certify that at a hearing of the Board of County Commissioners of the County of Boulder, Slate of Colorado, duly called and held on May 30, 1989, in consideration of the request described as follows: Docket CU-88-21Lyons Rubber Recycling Facility the following action was taken: The Board of County Commissioners of Boulder County, State of Colorado, APPROVED the request for Special Use Site Specific Development Plan, and Certificate of Designation for Solid Waste Disposal Site, use of tires as fuel for cement manufacture subject to the following conditions: 1. That Southwestern Portland Cement Company obtain its revised Colorado Air Pollution Emission Permit before beginning to accept or burn shredded or whole tires. 2. That, starting on August 1, 1989 and on August 1st of each subsequent year, an annual report will be submitted to the Boulder County Land Use and Health Departments and the Colorado Department of Health. This report shall Indicate on a monthly basis and annual total, the weight of whole and shredded tires received, the weight of whole tires shredded, the weioht of whole and shredded tires utilized in the kiln, and the weight of whole and shredded tires in storage. 3. That RCRA EPA lo>ocity analyses, and analysis for toxio trace elements, of the kiln dust shall be performed for each 1,500 tons of fire material utilized during the first three months and for each 3,000 tons of material utilized In the following four months, A minimum of three separate such analyses shall be provided within the first seven months of operation. These results shall be reported to the Boulder County Land Use and Health Departments and to the State Health Department. 4. That mosquito and other vector control programs approved by the Boulder County Health Department be instituted-as necessary to ensure that the the storage areas do not Increase area vector populations. 5. That Southwestern develop and Implement a tire fire coordination program with the Lyons and Hygiene Fire Departments prior to bringing tires to the site. This program should 1.C99?!.3 Jowprltn♦W. Hnan1 Ponnkl K Siemon Homer Pogo CLwnN Comrnuyer Crwr\N COmmu:rer COLIny CZITIM:Yone, Anderson, May 30, 1989/page 2 identify the personnel, equipment, materials, and sequence of events that will be used to fight a tire fire. All Identified personnel should be trained in the program. A report detailing the program shall be submitted to the Boulder County Land Use and Health Departments and to the State Health Department. 6. That surface runoff will be diverted away from the shredded and whole tire storage areas. 7. That within three months of closure of the kiln, all remaining tires will be either recycled properly disposed of. e. That any required Floodplain Development Permit be approved by Boulder County Public Works DepartmenL 9. That a report be made to the Planning Commission and Board of County Commissioners of the results an Inspection of the operation made after one yeas of operation. 10. That the operation proceed as described In all commitments made of record as a part of this Special Review and-other required reviews and permits. The standard model form for the Site Specific Development Agreement is enclosed for your use in preparation of the final agreement implementing this approval. Please use this form and the conditions of approval listed to prepare this document for signature and recording. If you have any questions conceming this action, please feel free to contact me at the Planning Office at 441-3930. Sincerely, l g4<4 iv/ Ken Ziebarth Planner, Operational Division cc: file 91C99i8 RESOLUTION L/ RE: ACTION OF BOARD AT PROBABLE CAUSE HEARING CONCERNING SPECIAL USE PERMIT - TIRE MOUNTAIN, INC. WHEREAS, the Board of County Commissioners of Weld County, Colorado, pursuant to Colorado statute and the Weld County Home Rule Charter, is vested with the authority of administering the affairs of Weld County, Colorado, and WHEREAS, by Resolution dated August 30, 1989, the Board approved Special Review Permit 11842, and WHEREAS, by Resolution dated October 3, 1990, the Board amended said Special Review Permit for Tire Mountain, Inc. , c/o Jarrald A. and Faye L. Jaimson, subject to certain Development Standards, and WHEREAS, on June 5, 1991, a Probable Cause Hearing was held before the Board to consider setting a Show Cause Hearing to determine whether or not Tire Mountain, Inc. is in compliance with three Development Standards contained in said Special Use Permit, and WHEREAS, the alleged violations were said to be occurring on property described as part of the SE; of Section 32, Township 3 North. Range 65 West of the 6th P.M. , Weld County, Colorado, and WHEREAS, the Board, after hearing testimony from the Planning Department, finds that, pursuant to the Standard in the Administrative Manual, there is sufficient probable cause to schedule a Show Cause Hearing to consider whether or not the Special Use Permit issued to Tire Mountain, Inc. should be revoked for failure to comply with certain Development Standards, and WHEREAS, the Board shall hear evidence and testimony from all interested parties at said Show Cause Hearing. NOW, THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Weld County, Colorado, that a Show Cause Hearing be scheduled to determine whether or not the Special Use Permit issued to Tire Mountain, Inc. should be revoked. BE IT FURTHER RESOLVED by the Board that the issues to be considered by the Board at said Show Cause Hearing is whether or not the applicant is in compliance with the following: Development Standard 113c: "No more than 2 trenches shall be excavated and exposed or filled at a time. " Development Standard 06: "Tires shall be placed across the width and to the top of each trench before proceeding lengthwise along the trench." 910496 8q r� PROBABLE CAUSE DATE: June 5 , 1991 • CASE NUMBER: ZCH-73 USR NUMBER: 842 OPERATOR/OWNER Tire Mountain Incorporated Jarrald A. and Faye L. Jamison 12311 Weld County Road 41 Hudson, CO 80642 LEGAL DESCRIPTION: Part of the SE4 of Section 32, T3N, R65W of the 6th P.M. , Weld County, Colorado. LOCATION: 12311 Weld County Road 41, Hudson, Colorado. It is the opinion of the Department of Planning Services' staff that the following Standards, as approved for Jarrald A. and Faye L. Jamison are not in compliance: Development Standard #3C states: A maximum of 25 storage trenches shall be constructed for tire storage as follows: C. No more than 2 trenches shall be excavated and exposed or filled at a time. A total of Five cells (three trenches) are exposed at this time. The required cover was not complete on any of the cells. Development Standard #6 states: Tires shall be placed across the width and to the top of each trench before proceeding lengthwise along the trench. Tires are not being placed in the trenches across the width and to the top of each trench before proceeding lengthwise along the trench. • Development Standard #7 states: Within 30 days of filling a trench with tires, the trench shall be covered with no less than a 20-mil plastic and one foot of soil. No more than 100 feet of uncovered tires shall exist at any time. Materials other than soil may be used as a final cover provided they are approved by the Weld County Department of Planning Services , Weld County Health Department, and the Colorado Department of Health. Trenches are not properly covered and more than 100 feet of uncovered tires exist at this time. Based upon the above information, the Department of Planning Services ' staff recommends that the Board of County Commissioners schedule a "Show Cause" public hearing on July 3 , 1991 to consider revocation of USR x/842. 9,11993 910496 DATE: June 5 , 1991 VIOLATION NUMBER: ZCH-73 NAME: Jarrald A. and Faye L. Jamison ADDRESS: 12311 Weld County Road 41 Hudson, CO 80642 LEGAL DESCRIPTION: Part of the SE4 of Section 32, T3N, R65W of the 6th P.M. , Weld County, Colorado. CASE SUMMARY April 2, 1991 The property was inspected to determine compliance. April 5 , 1991 Violation letter issued. April 25, 1991 Received two letters from Ken Lind, dated April 24, 1991. May 8 , 1991 Reinspected the property. The property is still not in compliance. May 14, 1991 Letter sent to Mr. Jamison and his Attorney, Ken Lind, indicating that the Probable Cause Hearing was scheduled for June 5, 1991. 91.0998 titc([ DEPARTMENT OF PLANNING SERVICES PHONE(303)356-4000,EXT.4400 91510th STREET GREELEY,COLORADO 80631 C. • COLORADO May 14, 1991 • Jarrald A. and Faye L. Jamison 12311 Weld County Road 41 Hudson, CO 80642 Subject: ZCH x/73, To determine if probable cause exists to hold a hearing on revocation of USR #842. Dear Mr. and Mrs. Jamison: Notice is hereby given that on Wednesday, June 5, 1991, 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 USR-842 for compliance with the Development Standards as approved by the Board of County Commissioners on August 30, 1989 to determine if probable cause exists to hold a hearing on revocation of USR-842. Inspection by representatives of this office have identified that you are not in compliance with Development Standards 3C, 6 and 7. If it is determined at the public hearing that there is probable cause that you are not in compliance with Development Standards 3C, 6 and 7 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 telephone. Respectfully, enr e Current Planner pc: Ken Lind Lind, Lawrence and Ottenhoff P.O. Box 326 Greeley, CO 80632 91.0999 INSPECTION REPORT NAME: Tire Mtn. Incorporated Jerrald A. and Faye L. Jamison LEGAL DESCRIPTION OF PROPERTY: Part of the SE4 Section 32, Township 3 North, Range 65 West of the 6th P.M. , Weld County, Colorado. DATE: May 8 ,1991 CASE NUMBER: USR#842 / ZCH#73 The property was inspected to determine if the Special Review permit that was approved August 30, 1989 is in compliance. Development Standards 3C, 6, and 7 are not in compliance at this time. Development standard #3C states: A maximum of 25 storage trenches shall be constructed for tire storage as follows: C. No more than 2 trenches shall be excavated and exposed or filled at a time. A total of Five cells (three trenches) are exposed at this time. The required cover was not complete on any of the cells. Development standard #6 states: Tires shall be placed across the width and to the top of each trench before proceeding lengthwise along the trench. Tires are not being placed in the trenches across the width and to the top of each trench before proceeding lengthwise along the trench. Development standard #7 states: Within 30 days of filling a trench with tires , the trench shall be covered with no less than a 20-mil plastic and one foot of soil. No more than 100 feet of uncovered tires shall exist at any time. Materials other than soil may be used as a final cover provided they are approved by the Weld County Department of Planning Services, Weld County Health Department, and the Colorado Department of Health. Trenches are not properly covered and more than 100 feet of uncovered tires exist at this time. L A. ch tt Current Planner LIND, LAWRENCE & OTTENHOFF AT RDRNEYS AT LAW THE LAW BUILDING 1011 ELEVENTH AVENUE P.O.BOX 326 GREELEY.COLORADO 80632 GEORGE H.OTTENHOFF TELEPHONE KENNETH F.UND 0031 3333323 KRA R.LAWRENCE 003)3569160 Ap r i l 24 , 1991 LT�COPIER1 Department of Planning Services 915 Tenth Street �" _ - Greeley, CO 80631 � ) fIr Attention: Keith Schuett 111 APP. 25 1991 r�L� •r — Re: ZCH-73 (Tire Mountain) fins CD. Know.* ww"sm. Dear Mr. Schuett: Our office has been requested by Mr . and Mrs . Jamison to respond to your letter dated April 5 , 1991. As to Development Standard 3C , it is the opinion of this office , Mr . and Mrs . Jamison and we believe the intent of the Development Standards , that the 2 trench opening does not apply to the necessary trenches for disposal of the existing surface stored tires . The intent of Development Standard 3C was to have 2 open trenches for disposal of "new" tires coming onto the site . The purpose of the 2 trench opening was to allow sorting of tires . Obviously, if you now desire to interpret Development 3C as also applying to the disposal of existing surface tires , then you have placed Tire Mountain in an impossible situation . Tire Mountain will have to cease disposing of existing surface stored tires , or, Tire Mountain will have to start piling sorted tires on site rather than placing them into trenches . Based upon the intent of Development Standard 3C 3 trenches will frequently be used. One of the trenches is being used for disposal of existing surface stored tires and the other 2 trenches are being used for storage and sorting of "new" tires brought onto the site . Specifically, the 3 trenches presently consist of 5 cells . Trench #1 has 2 cells , trench #2 has 2 cells and trench # 3 exists presently of only 1 cell. This trench #3 is the one being used for disposal of existing surface stored tires . Trench #1 , consisting of cells 1 and 2 , is filled with both cells now covered. Trench #2 , consisting of cells 3 and 4 , is being used for disposal of " new" tires . Cell 3 is being used for disposal of large ( truck ) tires and cell 4 is being used for disposal of small ( car) tires . 91_44)999 Weld County Department of Planning Services April 24 , 1991 Page 2 Based upon the intent of Development Standard 3C, Tire Mountain is in compliance with 3C. Concerning Development Standard No . 5 , please be advised that all existing stockpiles are separated by a minimum width of 70 feet. As to Developments Standards No . 6 and 7 , enclosed please find a separate letter concerning a request for a minor change . The request for a minor change concerns Development Standards No. 6 and 7 . If you have any additional questions or have additional concerns , please contact the undersigned. Very truly yours, LIND, W CE TTENHOFF Kenneth F. Lind; KFL/cg pc: Tire Mountain, Inc. Weld County Health Department (311C7- 9,19 r-- - _77) LIND, LAWRENCE & OTTENHOFF „r. r "/� ATTORNEYS AT LAW I pn THE LAW BUILDING f" 5 1991 I 1011 ELEVENTH AVENUE U� ..J P.O.BOX 326 GREELEY.COLORADO 80632 .�. 280,0.4 ..,yµlyyb:yµ GEORGE H.OTIENHOFF OGW TELEPHONE KENNETH F.LIND (303)353.2323 KIM R.LAWRENCE (303)3569(60 TELEOOPIER (303)35611❑ April 24, 1991 Department of Planning Services 915 Tenth Street Greeley, CO 80631 Attention: Keith Schuett Dear Mr . Schuett: Pursuant to your letter dated April 5 , 1991 concerning Development Standards 6 and 7 of the above referenced property, the purpose of this letter is to address both Development Standards and to request a minor change concerning said Development Standards . First , as to Development Standard No . 6 it is the experience of Tire Mountain that disposal of tires and the use of the trenches in a length-wise rather than width-wise filling manner is much more practical, allows for better use of equipment and manpower and allows the trenches to be filled in a better procedure . The length-wise filling allows more tires to be placed into each trench . As all tires are inspected and sorted for potential reuse ( recapping ) before being permanently disposed , it is much more feasible to have the tires disposed of in a length-wise manner for inspection purposes rather than doing the width-wise procedure . Tire Mountain has a 150 ' apron on which incoming tires are unloaded for buyer inspection , and this apron needs to be length-wise . Additionally, the length-wise filling allows for better compacting for final fill and cover . Next , concerning Development Standard No . 7 , two changes for this Standard are requested . The first change is to modify the requirement that no more than 100 feet of uncovered tires shall exist at one time and the second change is to modify the soil cover requirement. As experience has shown that length-wise filling rather than width-wise filling is far more practical , it is impossible to keep only 100 feet of tires exposed at any time . Additionally, through experience it has been determined that to 91.639"3 Weld County Department of Planning Services April 24 , 1991 Page 2 properly fill, allow for settlement and then packing of the tires in each cell it .is necessary that an entire cell be open and not covered with plastic on a piecemeal basis . Experience has shown that as tires are placed into the cell a significant amount of settling does take place . To properly allow for drainage of water from the center of the plastic covered cells it is necessary to slope the tire cells with more tires placed in the center and gradually dropping off at the sides . When tires are placed into the cells it has been discovered that they settle by as much as 4 feet over a period of several weeks and after the settling has taken place additional tires are then placed on top of the "settled" tires , they are compacted . It is impossible to allow for proper settling and compaction when piecemeal covering takes place. Thus , it is requested that covering of a cell not ' be required until the entire cell has been filled, settled and then compacted. The next item of concern of Development Standard No . 7 concerns the 1 foot of soil cover . Numerous inspections of the cells and property have been made by the Weld County Health Department , Department of Planning Services , County Commissioners , engineers and officials of the Platteville Fire Protection District . On cell 1 of trench 1 various methods of covering the plastic have been experimented with over the past year. Those methods included soil cover, strap cover , rope cover and one layer of tire cover. The strap and rope cover proved to be ineffective as settling and shifting of the tires caused the plastic to tear . Soil cover has even been a worse situation as due to settling and shifting, holes in the plastic have occurred allowing dirt to enter the tire storage cells and spoil potential reuse or recycling. Additionally, with rain, snow and wind there has been a tendency for the soil to erode or blow off of the plastic covering. Additionally, when repairs must be made to the plastic covered by soil it is virtually impossible to effect any repairs without entirely removing the soil . The only way that soil can be removed is by a hand operation which necessarily results in further tearing of the plastic and additional contamination of the tires . Most importantly , the Platteville Fire Protection District , while being very impressed with the facilities has also had the opportunity to inspect and watch the operations for many months . The Platteville Fire Protection District is adamantly opposed to the soil covered plastic . Of all the methods tried to date , the most practical has been covering the plastic with one layer of tires . The one layer of tires allows for easy removal and repair of any torn plastic Weld County Department of Planning Services April 24 , 1991 Page 3 and prohibits any contamination of the stored tires . It is the request of Tire Mountain that the final cover of one layer of tires be approved as an alternative to the soil cover. It should be noted that Tire Mountain intends to continue to cooperate with the Weld County Department of Health to utilize alternative methods of final cover as ideas are received and experience dictates . To date , however, every engineer and fire expert or interested party that has inspected the site has determined that the one layer of tires over the plastic is by far the best alternative final cover at this time. Tire Mountain continues to watch trade journals and have its engineering staff review engineering periodicals for other material covers or final cover ideas and as alternative covers or ideas are determined Tire Mountain agrees to cooperate with all officials in reviewing alternative cover ideas and methods . Very truly Jyours LIND, A ENCE/& • TENHOFF Kenne h F Lind KFL/cg Enclosure pc: Tire Mountain, Inc. Weld County Health Department • SAle999 ' �G�` \It � DEPARTMENT OF PLANNING SERVICES T PHONE(303)358-4OOO,EXT.4400 91510th STREET upe GREELEY,COLORADO 00631 COLORADO April 5 , 1991 Jarrald A. Jamison and Fayle L. Jamison 12311 Weld County Road 41 Hudson, CO 80642 Subject: ZCH-73 Dear Mr. and Mrs. Jamison: An on-site inspection of your property was conducted on April 2, 1991, to determine if the Conditions of Approval and the Development Standards placed on your property ac the time USR-842 was approved by the Board of County Commissioners are in compliance. The inspection revealed violations of Development Standards #3C, 5, 6 and 7. A copy of these items from the approved resolution are enclosed. The Use by Special Review area must be brought into compliance with the Conditions of Approval and the Development Standards 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. If you have information that may clear up this matter, please call or write. Sincerely, eit .+ . Sc u t Current Planner pc Lind, Lawrence & Ottenhof, Attorneys at Law Attention: Ken Lind 1011 Eleventh Avenue Greeley, CO 80631 enclosures 0.1.C998 INSPECTION REPORT NAME: Tire Mtn, . Incorporated Jerrald A. and Faye L. Jamison LEGAL DESCRIPTION OF PROPERTY: Part of the SE4 of Section 32, Township 3 North, Range 65 West of the 6th P.M. , Weld County, Colorado. DATE: April 2,1991 CASE NUMBER: USR#842 / ZCH#73 The property was inspected to determine if the Special Review permit that was approved August 30, 1990, is in incompliance. Development Standards 3C, 5,6 , and 7 are not in compliance at this time. Development standard #3C states: A maximum of 25 storage trenches shall be constructed for tire storage as follows: C. No more than 2 trenches shall be excavated and exposed or filled at a time. A total of five cells (three trenches) are exposed at this time. The required cover was not complete on any of the cells. Development standard #5 states : Existing tire stockpiles shall be separated by a minimum width of 70 feet. The existing stock piles are not separated by 70 feet. Development standard #6 states: Tires shall be placed across the width and to the top of each trench before proceeding lengthwise along the trench. Tires are not being placed in the trenches across the width and to the top of each trench before proceeding lengthwise along the trench. 91(3 n9 a9 INSPECTION REPORT, TIRE MTN, INC. Page 2 Development standard #7 states: Within 30 days of filling a trench with tires, the trench shall be covered with no less than a 20-mil plastic and one foot of soil. No more than 100 feet of uncovered tires shall exist at any time. Materials other than soil may be used as a final cover provided they are approved by the Weld County Department o£ Planning Services, Weld County Health Department, and the Colorado Department of Health. Trenches are not properly covered and more than 100 feet of uncovered tires exist at this time- _ X�el eith A. Schuett Current Planner • °+ -C99 ;.t mEMORAnDum wigle. To wes Pnttnr off Dace April 2, 1991 COLORADO From Patty naplavas A' Sublect: Ti ra Mountain J/ The quarterly inspection conducted at Tire Mountain on March 14, 1991, revealed the following specific deviations from the development standards as established under amended USR-842: Development Standard: 3. c. Four pits on the south side of the site are exposed or partially exposed at this time. Pits 1 & 2 south are filled. Pit 1 is partially covered. Pits 3 & 4 are partially filled. Pits 2, 3, & 4 are not covered. Pit 1 north for surface stored tires is currently being filled. 6. Trenches are not being filled in a progressive manner, from end to end. Rather trenches are being filled haphazardly. 7. Only a portion of cell 1 south has been covered as required. All other cells were uncovered at the time of inspection. PD/lam-07 mEmoRAnDum Keith Schuett To ____W e1d_.S.ounty_Planning.._ Date —P1a3t_29-- 991 VffilCOLORADO From � Wes Potter_ Director. ervice�— — -- Subject:Tlre_Mountain_Attorney Letters __ _— ---- ---._ In response to the letter from Fen Lind with regard to Tire Mountain and the disposal of tires, I provide the following comments: 1. The staff has reviewed the disposal facilities practice of filling the trenches in a length wise, haphazard manner as opposed to the progressive manner as described in the Certificate of Designation. While it doesn't look very good, and may not be the most efficient way of filling the trenches, I don't see any technical reason why it could not continue as requested. There does seem to be a certain amount of logic in the explanation provided by Mr. Lind and his explanation of why the filling practice was occurring as it does. The staff agrees allowing the tires to settle is a prudent action, because it facilitates more tires going in to a given cell and obviously the more tires going into a given cell the more efficient the operation. 2. The problem of covering the cells after they are completed continues to be a dilemma faced by this department. The intent of the soil cover is to retard the potential of a fire in a given cell. Without putting the soil over the tires, the potential for the entire cell to become engulfed in flames exists. The staff is aware the flimsy single sheet of plastic that is being attempted by the facility operators' to hold the soil is not sufficient. There is no doubt a suitable product is available on the market that would support the soil cover, if the facility was willing to spend the funds to purchase that plastic. The Division continues to be concerned about the potential for tumbleweeds to accumulate in the top of the piles and to facilitate the tire becoming involved in a fire which could have been established by a prairie fire whipping across the general area. To state that tumbleweeds never accumulated in the top of the pile, is ludicrous. The staff continues to be concerned with the unwillingness of the operator of the facility to comply with the methods he suggested at the proposal of the operation of the facility. The staff has made arrangements for the facility to continue to experiment and look for other methods of coverage of the completed cells. It is the position of the staff, the operator of the facility is not seriously looking for alternative methods, but has decided to rely upon a tactic of attempting to force the County to approved of not covering the cells. The Platteville Fire Protection District does not in effect seem to be adamantly opposed to the soil covered plastic. The Division therefore, is willing to allow the cells to remain uncovered until sufficient covering material can be proposed by the facility. Eventually, however, the Division feels the cells do need to be covered and protected from being a potential fire source. 91Cry S Keith Schuett May 20, 1991 Page 2 3. The staff encourages Mr. Jamison to dispose of all of the tires into trenches. The two (2) trenches that are presently being used to {_spose of the old tires need to be continued. The staff sees no reason why there should be a problem with allowing additional trenches to be open during this filling process and nothing should interfere with the operation of placing the existing six and one-half (6 1/2) million tires into trenches as soon as possible. WP/dgc-67 910998 d ft V DEPARTMENT OF HEALTH ••• • 1517 - 16 AVENUE COURT 1 GREELEY, COLORADO 80631 ADMINISTRATION (30.+1 3a3-0586 CoO HEALTH PROTECTION (303) 353-0635 COMMUNITY HEALTH (303) 353-0639 COLORADO April 12, 1991 Certified Letter No. : P 058 577 369 Jerry Jamison Tire Mountain 12311 Weld County Road 41 Hudson, Colorado 80642 Dear Mr. Jamison: A recent inspection of the Tire Mountain Facility on March 14, 1991, by Patty Deplazes - Environmental Protection Specialist, revealed the following problems: 1. Storage cells; are not being filled and covered as required in Amended USR- 842. 2. Evidence of recent open burning. A burning permit is required. Please be advised that the operation of this site is in violation of the Development Standards established under Amended USR No. 842, which states in part. . . . 3. A maximum of 25 storage trenches shall be constructed for tire storage as follows: C. No more than 2 trenches shall be excavated and exposed or filled at a time. 6. Tires shall be placed across the width and to the top of each trench before proceeding lengthwise along the trench. 7. Within 30 days of filling a trench with tires, the trench shall be covered with no less than a 20 mil plastic and one foot of soil. No more than 100 feet of uncovered tires shall exist at any time. Materials other than soil may be used as a final cover provided they are approved by the Weld County Department, and the Colorado Department of Health. Please be advised that you have thirty (30) days from receipt of this letter to bring the operation into compliance with the Regulations pertaining to "Solid Waste Disposal Sites and Facilities". Please be advised that the Regulations provide in Section 2.3.4 that: .j Jerry Jamison Certified Letter No. : P 058 577 369 Page 2 2.3.4 If the facility operator fails to respond to the Department violation notice within thirty (30) days, said operator may become subject to statutory and other remedies as appropriate including: (a) Fines, imprisonment, or both, under Section 114 of the Act. (b) Temporary suspension or revocation of the certificate of designation under Section 112 of the Act or, (c) If a facility is deemed a public nuisance for violation of the Act or these Department"regulations, the violation may be enjoined by a District Court under Section 113 of the Act. Failure to respond and comply will result in appropriate legal action by this Department. If you have any questions concerning this matter, please contact this office at 353-0635. Sincerely, I V � , Pattyazes Wes Potter, Director Environmental Protection Specialist Environmental Protection Services PD/WP/lam-88 cc: Randy Gordon, M.D. , Director Lee Morrison, Assistant County Attorney SOLID WASTE FACILITY INSPECTION Compliance Non-compliance - Open Dump County —�j-_�rE E !r k! II 4 Date II '4"( ! 4 - Located in ' Facility x:r r . Incorporated Area /_/ Location ) 's 1 vJ r, tZ yl 4±A d Stn a.O(o/1;- Current Operator �,- r f ,e 7" -rn, Mailing Address of -OperatoY Current Owner (If different) (All items checked must be explained in supplemental report) I. - Public Health-and/or-Environmental-Hazards (Department-enforcement- against violations) A. Evidence of Industrial Waste Disposal B. Evidence of Potential for Serious Surface or Ground Water Pollution _ C. Surface Diversion/Containment Facilities-Inadequate-or not Maintained D. Landfill Gas Migration Concerns E. Sludge or Septic Pumpings Disposal on Site (Unauthorized) F. Safety Hazards —x G. Non-Compliance with Approved Design and Operation H. Other * REMEDIAL ACTION REQUIRED . II. Minimum Standards, CRS_30,. 20-110„(Locally .enforced;,standards)_.•_,_ . A. Odors and/or Vectors Present B. Inadequate and/or Irregular Cover • . ` : ` C. Inadequate Fencing (to control access and windblown debris) --X D. Burning apparent E. .Not Designated;1nd/or,Improperly Zoned, INSPECTING ENGINEERS RECOMMENDATIONS:FOR`:SITE'IMPROVEMENT ._ -- Lilac/- 1 C> ,h e F� -- -*°ter Fi ' (91 1-1e-A to "AI 641- - _• (r '•/ __taut i �'-C. - 2 G -?.<_!.. 1 , 61-1 "} III. Complaints Received (Attach copiesh' ction`Taken r o _ IV. Remarks (Name) . PRESENT AT:INSPECTION :`" (Representing) X1,1 ::).0!`1let_i _ lr)e ' . Inspecting Engineer T7 ` 469Y1 -;1 ; . MEMORAnDum Keith Schuett To Weld County Planning Date October 16, 1990 COLORADO From Environmental Protection Services ,' ° !d Tire Mountain sunj«t: Environmental Protection Services staff has evaluated the tire covering and perimeter fencing of Cell 1 at T}se Mountain. It is the position of this department that the 20 mil fabric secured with ropes is not an adequate covering method for the tire cells. Further, it is the position of this department that the loader tire perimeter fence will cause increased piling of tumbleweeds on the tire cells. At this time, the department approves for Cell 1 to be experimentally covered with 20 mil fabric held down by a single layer of car tires, so long as the coverage of the cell with plastic is continuous and the car tires are placed flat and in an even layer across the cell. This approval is given for a period of one year on an experimental basis, and for comparison with the 20 mil plastic and 12 inches of dirt covering originally approved. The department does not approve the construction of a loader tire perimeter fence. The covering of Cell 2 will be evaluated when that cell has settled sufficiently to be covered. PD744/dgc • RECE= IVED SANITATION DIVISION MAY 23 1991 • • WELD COUNTY REALM DEFT. QCT 1 7 19;9 tau, pbitoK ,loon tia• emneacl TIRE MOUNTAIN EVALUATION OF THE NEED FOR ALTERNATIVE COVERING MATERIAL FOR THE STORAGE CELLS SCOPE The following report is pursuant to a request from Tire Mountain. This report is intended to evaluate the need for tire covering on the tire cells permitted by USR #842. This evaluation assumes that tire recycling will be used at the USR site. This report will evaluate various options and provide documentation as well as relevant background information. We will evaluate the various options , provide an analysis of the risk , develop recommendations and justifications for various alternative methods concerning covering of the tire storage cells. This evaluation is intended to cover only the fire safety aspects of covering the tires at the tire storage facility . According to information provided from Tire Mountain, the scenario involving tire recycling will be utilized. According to the recommendations from the State Department of Health, all trenches must be covered with 20 mil plastic and 1 foot of top soil as the •trench is brought to grade with no more than 100 feet of uncovered tires existing at any point in time. The recommendation from the State includes the statement that other materials can be used as a final cover if they can be proven to be non-flammable and provide erosion control , wind protection , oxygen suppression and esthetic suitability . These recommendations were incorporated into the Certificate of Designation by Weld County. This evaluation will address the above items in the context of fire safety and will determine what alternatives are available and the most cost effective means to provide a safe facility in accordance with the intent of the applicable regulations. Based upon information previously submitted , it was recognized that a final solution to the tire covering issue had not been developed . The previous documentation indicates that research and development on the alternatives to tire covering would be researched with final recommendations in the form of a plan submitted for approval. The various alternatives that were to be explored were as follows : 1 . Cover the tire cells with fire retardant plastic , maintaining ballast with tire strips and the edges only covered with soil. 2. Cover the tire cells with fire retardant plastic and cover with 1 foot of soil as ballast . fal i et nil 9 -1- TIRE MOUNTAIN EVALUATION OF THE NEED FOR ALTERNATIVE COVERING MATERIAL FOR THE STORAGE CELLS SCOPE (CONT' D) 3. Cover the tire cells with fire retardant plastic and ballast with waste tires and the edges with the sidewall of tires. 4. Investigate other practical ways to safely maintain the tires and storage . The above items were evaluated as to their application, suitability and level of safety provided . According to the recommendations from the Colorado Department of Health it was imperative that any materials used must be tested to determine that they exhibit fire retardant characteristics. The applicable test standard for flammability is NFPA #701 , "The Standard Method of Fire Test for Flammable Resistance." Various plastic materials were researched in order to evaluate which materials exhibit the necessary characteristics in order to satisfy the site objectives for use as a cover material . Previous research has indicated that only a fire retardant plastic would be considered acceptable in terms of satisfying the intent of the parameters established by the Colorado Department of Health. PLASTIC COVERING ALTERNATIVE Our firm evaluated various plastic materials which might be considered acceptable for this application. We found considerable difficulty in locating materials for utilization in this application. This was due to the fact that most large sheet plastic installations have not been tested to satisfy the building or fire code requirements. The only testing that we are aware of has been for fabric materials that may be used for tent applications . In general the low cost plastics that are typically available have not been specifically tested for flammability characteristics and would not satisfy the fire safety criteria imposed by the state. In this application, the plastic cover material must also be sunlight resistant . The plastic materials evaluated do not lend themselves well to characteristics such as sunlight resistance . In the event that the tire cells are covered with only fire retardant plastic without using top soil , the plastic material must then exhibit both fire retardant characteristics as well as resistance to sunlight and maintain a reasonable service life for the life of the facility . During the course of the evaluation of the fire retardant plastics which are commercially available , it was determined that the life expectancy of the acceptable plastic material would be in the range for 2 to 3 years due to the limitations of sunlight resistance and ultraviolet penetration. 5.31.C999 —2— TIRE MOUNTAIN EVALUATION OF THE NEED FOR ALTERNATIVE COVERING MATERIAL FOR THE STORAGE CELLS PLASTIC COVERING ALTERNATIVE (CONT'D) The alternatives explored include covering the tire piles with plastic and other materials for ballasting. All concepts rely on the premise that a plastic covering material is readily available with necessary characteristics to perform all the requirements stated above. In addition the practicality of using a plastic cover should be considered in terms of the cost for implementation. Based upon the preliminary cost estimates of using materials which satisfy the fire retardant characteristics necessary , this represents a cost of $8 ,500 per cell for the plastic covering material only . The cost for the installation would be additional. The fire test used to demonstrate the flammability characteristics of fire retardant plastics includes exposure from a bunsen burner . The report ignition temperature of plastic sheet material is approximately 660 0 F. The reported ignition temperature of rubber tires is 700 F. When comparing the susceptibility of ignition of fabric materials relative to that of rubber tires , it is obvious that the risk of ignition based on the documented ignition temperatures of plastic covering materials is greater than that of rubber tires. Consequently by providing a fire retardant plastic cover will provide no additional level of fire safety for the facility than if the tires are left exposed . PLASTIC AND EARTH COVER In the event that the plastic cover would be covered with dirt , there is no practical means to provide for the removal of such soil without damage to the plastic cover . Consequently , the tires that are to be recycled would be filled with soil and create a loss of recycling operation for which this storage facility is intended . This particular item has not been resolved by any of the individuals evaluating this . The tires stored in the cells will compact resulting in an uneven surface and the plastic liner will not be able to withstand this movement and be able to maintain the surface without tearing. In addition, if the plastic were to be covered with earth the plastic will tear easily when covered and again avoid the practical tire re-utilization that is anticipated with this recycling operation. e _C998 -3- TIRE MOUNTAIN EVALUATION OF THE NEED FOR ALTERNATIVE COVERING MATERIAL FOR THE STORAGE CELLS PLASTIC AND EARTH COVER (CONT'D) The practicality of covering the tires with plastic and earth must also be considered in terms of cost and benefit. If the tires are covered in this fashion there is no possibility for reclamation. Although this alternative is plausible for the final disposition of the tires, this is not the case under the present operating scheme which contemplates recycling of the tires. The cost involved to provide a plastic cover and cover with dirt would be in excess of $5 ,000 excluding .the cost of the plastic. In the process of accessing the tire piles to install the plastic cover , the likelihood of tearing the plastic is greater . In addition, the installation of the earth cover is going to be difficult. Although this approach provides slight benefit , it eliminates the primary basis for the tire recycling operation. FIRE RISK A previous report , conducted by High Country Engineering, dated November of 1988 (see attached) addressed the requirements for tire cell separation and need for berms within the storage cells in order to minimize fire spread from cell to cell assuming a fire were to be started in any single cell. In that analysis , it was anticipated that the spacing and placement of berms., access roads and the spacing of tire cells was predicated on the basis of a fully involved fire and the incident radiation on adjoining tire piles. That analysis provided the basis for the spacing of the tire cells. During that analysis it was assumed that the tire piles were not protected with any covering material(s) . The recommendations for the tire cell placement and utilization of berms and fire access roads have been agreed upon and incorporated by the Planning Commission and incorporated by the Weld County Commissioners for implementation into the approval as part of the Certificate of Designation. Consequently , that was the basis for the arrangement of the tire cells and subsequent approval. When considering both the issue of the plastic covers on the tires and the plastic covers with the earth, neither of the alternatives appear to serve a practical solution for the storage of these tires based upon the results of incident radiation on adjoining cells. The results of the fire protection analysis and recommendations provided in our report date November of 1988 would not change at all as a result of the need to cover or not to cover the tires. We have previously conducted a fire risk assessment associated with the tire storage cells that would potentially ignite the tires at this site. Our previous evaluation concerning the likelihood of ignition indicated that lightning was the only PAG°11499 -4- TIRE MOUNTAIN EVALUATION OF THE NEED FOR ALTERNATIVE COVERING MATERIAL FOR THE STORAGE CELLS FIRE RISK (CONT' D) credible risk that existed . The evaluation utilized the risk assessment guide provided in NFPA #78 , "The Lightning Protection Code. " This includes such factors as the type of construction, relative location, size and height , topography of site and surrounding areas , type of occupancy and the number of thunderstorms in the general area. In considering that some of the factors are not specifically applicable , the analysis suggested that the risk of lightning in underground trenches is almost non-existent when compared to above ground storage . The net result is that the use of plastic covering on the tires will not provide any degree of added fire safety for the facility. In fact the fire retardant plastic poses a higher risk of ignition than the tires themselves . FIRE PROTECTION AND PREVENTION We had previously examined other fire causes and recommended that fire prevention and protection measures be incorporated in the site emergency plan. Based upon the incorporation of the on— site fire prevention practices and the implementations of our recommendations for cell separation , establishment of a fire water supply and fire fighting procedures , it would appear that the level of fire risks is minimal at the site. None the less if a fire would occur adequate provisions for fire fighting and active fire suppression were considered appropriate for the facility. In the unlikely event that a fire is ignited in any cell, the emergency fire operations need to know the nature of the fire and the best way to contain it. One means to suppress the fire is the application of water particularly in the early stages of the fire. However , the primary fire suppression efforts should rely upon the heavy earth moving equipment which will provide the fire control required . The available earth on the site adjoining the cells provides the most practical fire extinguishing medium. In order to employ fire suppression agents (water and earth) and to be effective there must be no cover over the tires . Any covering material may inhibit the fire suppression activities . The newly adopted NFPA standard for storage of scrap tires is more than satisfied with the arrangement proposed . This facility provides a safer arrangement than is proposed under the Appendix to NFPA #231D Standard. This is true since the NFPA code contemplates above ground tire storage of whole scrap tires . The code establishes fire protection based upon minimizing the size of storage piles and control of ignition sources . S i.C.9973 -5- TIRE MOUNTAIN EVALUATION OF THE NEED FOR ALTERNATIVE COVERING MATERIAL FOR THE STORAGE CELLS FIRE PROTECTION AND PREVENTION (CONT' D) The tire storage arrangement in this specific application is in below grade cells and as such provides a higher level of safety from ignition risks and minimizes risk of exposure from fires from one tire cell to another . Additional safety factors , such as personnel and or equipment near the edge of the tire cells may create an unsafe condition. Considerations such as emergency personnel and equipment driving into the tire cells during non—daylight hours may create a safety hazard for both personnel and equipment . This condition would be less likely if the tires were exposed . SUMMARY Based upon the above review including the anticipated recycling program, the impracticality of covering the tires with plastic and/or earth, the cost necessary to provide the alternative covering, the lack of any increased level of fire safety , the level of safety to fire fighters and the effectiveness of fire extinguishing efforts all lead to the conclusion that there is no need based upon fire safety criteria which justifies any covering material on the tires under the recycling mode of operation. In conclusion, the open cell storage of tires will provide a safer storage arrangement due to safety of site personnel, safety of emergency response personnel and the application of fire fighting agents. S� 9�� —6— 231D-12 STORAGE Or RUBBER TIRES . Automatic sprinklers can be expected to operate within Appendix C Guidelines for Outdoor Storage 2 to 5 minutes of ignition. At this point, the fire has genet-, of Scrap Tires • �- / ally progressed beyond the stage where extinguishers are • , effective and within a few minutes, smoke will make the area untenable and visionwill be completely obscured. C-1 General. The intent of these recommendations is Active.Sta Stage. At this point, the building is untenable to provide fire protection guidance to minimize the fire g P g hazard in areas for outside scrap tire storage. Each indi- and obscured vision makes the use of hose streams ques- .vidual property will have its own special conditions of tire tionable. It is best to allow the sprinklers to take control ltautdling, exposure, and topography. For this reason,.only � of the fire. Most sprinklers will have operated within 15 basic fire protection principles are being considered herein to 20 minutes of ignition if control is to be effected. which are intended to be applied with due consideration Sprinklers should be allowed to operate at least 60 and of the local factors involved.The authority having jurisdic- preferably 90 minutes. During the period the building is Lion should be consulted in all cases. best left unventilated.As control of the fire is gained,smoke Rubber has a heat combustion of about 15,000 BTU's will tend to change from black to gray and diminish in in- tensity.. During this period at least six charged 1'f.-in. per pound,or roughly twice that of ordinary combustibles (38-mm)hose lines should be laid out preparatory to enter- (that is, paper and wood). Once ignited, fire development �. tng the building.,Portable floodlights should be secured as is rapid and high temperatures can be expected,due to the w large exposed surface area of tires.Burning is likely to per- ell as raincoats,boots,helmets,breathing apparatus,etc., for the overhaul crew. silt for hours. In cases where the fire is controlled, re- kindling is a,possibility. Critical Stage. After 60 to 90 minutes and when These recommendations are not intended to apply to smoke intensity has diminished,the building should be yen- storage of shredded tires (chips, granuals, etc.). tilated around the periphery of the suspected fire location. - During this period close observation should be made of C-2 Definitions. Unless expressly stated elsewhere, the smoke conditions. If smoke generation increases,cease yen- following terms will for the purpose of these reconunen- tilating and close up building if possible. dations have the meanings indicated below: • Aisle. An accessible clear space between storage piles Overhaul. As soon as smoke dears to the extent that or groups of piles suitable for housekeeping operations, the building can be entered, entry should be made with visual inspection of piling areas, and initial fire fighting small hose screams which should be directed into burning operations. tires. Sprinklers should remain in operation unless the fire chief is certain that hose can control the fire. . Clear Space. Any area free of combustible materials. Fork trucks and other means should be employed to This does not preclude the storage of noncombustible remove tires from the fire area.It will usually be necessary materials that will not transmit an exposure fire. to keep sprinklers and/or hose streams in operation dur- ing this procedure at least until all evidence of flame is Fire Lane. A clear space suitable for fire fighting ac- gone. Patrols should be made in affected arca for 24 hours cess and operations by motorized fire apparatus. following the fire. In the event that control of the fire is lost as evidenced Yard. The outdoor areas where scrap tires are stored. by increasing smoke generation,-loss of pressure at fire Units (equivalent passenger). One average size pump discharge(indicating massive sprinkler operation), passenger lire(equivalent � approximately l 25 lb (i 1 e s collapsing roof, etc., efforts should be directed towards p 6 weighing pp y, preventing the spread of the fire beyond the area bounded gcra Tire. A tine that is no longer suitable for by the fire walls. At this point, consideration should be p given to shutting off sprinklers in the fire area to provide vehicular use. water for protecting the exposures. C-3 Fire Experience. Use of High Expansion Foam. If a high expansion C-3.1 Fire experience in outdoor storage of scrap tires foam system is used in connection with automatic sprink- reveals a number of concerns, including: the generation lers, sprinklers may be shut off 1 hour after ignition and of large amounts of black smoke; the fact that the storage an additional 1-hour soaking time for foam allowed before is often too close to buildings on the same or adjacent the building is opened up and overhaul begun. Limited premises, causing fires in these exposed buildings; the :csts with high expansion foam indicate that fire extinguish- generation of oil during the fire where the oil contributes ment is largely complete after a period of soaking in foam. to the fire or where the run-off will contaminate the sur- As a precautionary measure,charged hose streams should rounding area; delay in reporting the fire; and the lack of __ be available when foam is drained away. fire fighting capabilities.The fire hazards inherent in scrap After the initial fill, foam generators should be operated rubber tite storage arc best controlled by a positive fire periodically during the soaking period to maintain the foam prevention program which would include the intent that level. This is necessary since sprinklers and products of a fire would be contained to the pile of origin and limiting combustion will cause partial foam breakdown. the exposures to other piles or associated structures. C-3.2 Fire Prevention. ` C-3.2.1 The fire hazard potential inherent in scrap rub- e µr' x99 41�.4J . 9 UM Ednion • --_,.,=..z. • APPENDIX c • 231D-13 ber lire storage operations can best be controlled by a C-4.2.2 Means of protecting the building exposed by `....) positive fire prevention program. The method of stacking burning [ire storage may be selected from NFPA BOA, should be solid piles in an orderly manner and should Chapter 3, and separation adjustments may be based on include:'. . . . building construction and protective measures as given in (a) Fire lanes to separate piles and provide access for NFPA BOA, Chapter 4, except that the separaton should effective fire fighting operations. • never be reduced below that necessary for fire fighting ac- (b) Separation of yard storage from buildings and other cess. (See Section C-4.3.) exposures. C-4.2.3 Table C-4.2.3 gives representative separations \—./ (c) An effective fire prevention maintenance program between exposed building and piles or between isolated including control of weeds, grass, and other combustible piles, materials within the storage area. ., . (d) The topography should be considered since in lire Table C 4.2.3 Representative Exposureconditions, oil accumulations or run-off can be expected. Separation Distances Scrap tire storage should preferably be on a level area. Tire Storage Pile Height �-/• C-3.2.2 Appropriate steps should be taken to limit ac- v 8 10 12 14 16 to 20 cess to the tire storage area. Acceptable access should be w a 25 56 62 67 73 77 82 85 provided for fire fighting equipment. v° 50 75 04 93 - 100 5." 107 113 lt0 v as 100 100. -..116 128 137: 146 155 164 �.g 150 117 135 149 164 170 189 198 C-4 Exposure Protection. w"• fa 200 130 149 167 , 183 198 212 226 250 140 162 181 198 , - 216 231 245 C-4.1 For 500 units or ICS5 a minimum separation be- NOTE: Separation distances are based on NFPA 80A,Chapter 2,using tween scrap rubber tires and structures should be 25 ft a factor of 1.5 in accordance with C•4.2.t(a). (7.6 m) minimum or as reduced by Chapter 3, "Means of Protection," and Chapter 4, "Application of Means of Protection," of NFPA 80A,Recommended Practice for Proles- C-4.2.4 Because of die extensive fire expected in scrap lion of Buildings from Fire Exposures. tire storage some form of exposure protection for adjoin- ing properties should be considered.,If the clear space as C-4.2 For More than 500 Units. recommended in Table C-4.2.3 cannot be provided, pro- vide a dirt berm 1'b times the height of the tire storage. C-4.2.1 The minimum distance between outside scrap rubber tire storage and buildings should be determined in C-4.2.5 The distance between storage and grass,weeds, ^ accordance with the intent and provisions of NFPA BOA, and brush should be 50 ft (15 m).':?: _ Recommended Practice for Protection of Buildings from Exterior Fire - ' Exposures. Since it%is based on exposure from a burning C-4.3 Fire Fighting Access building,restrictions are needed for application to an out- C-4.3.1 Maximum pile height should be 20 ft(6 m).Pile side storage configuration. width and length should not exceed 250 ft(76.2 m)without (a) The height of exposing fire from burning trees should a separation according to.Table C-4,2.3. Dirt berms may be taken as 1.5 times the height of the tire pile since flames lie used in lieu of cross aisles in accordance widt C-4.2.1(b). extending abovethe burning tires contribute to the size (See Figure C-4.3.1.) of the radiation surface area. The height of the exposing r - fire, per NFPA 80A, is the building height. Height ofcom- C-4.3.2 • The fire department should be consulted for ad- . bustibles stored within the building is not mentioned;,it vice on provision of all-weather roadways to and within would be inherent in the selection of the severity of the ex- the storage area. Depending on storage area configuration posure fire.A comparative building height would have to and size, access obstruction(river, railroad yards), prevail- exceed height of piling by several feet at least, and could ing wind direction, alternative tactics, etc., fire fighting be substantially higher. Furthermore, the height (and strategy may require one or more aisles to be wider than width) of flames above.a fire-penetrated roof would be those described in C-4.3.1. �--- substantially influenced by the debris of the fire-damaged • or collapsed roof,whereas flame height above yard storage C-4.3.3 Pre-emergency planning should be made with would have no such restraint. the local fire protection agency so that fire emergencies can (b) The width of the exposing fire should be taken as be properly handled in the tire storage facility. the accumulative width of piles facing the exposed building, • • with disregard for the nominal separation between piles C-5 General Fire Protection. provided by narrow access aisles and roadways. In order C-5.1 General. N—' for storage piles to be considered isolated piles, the mini- mum separation distance between piles should be in actor- C-5.1.1 Weeds, ass,and similar vegetation should be dance with Table C-4.2.3. This distance can be reduced eliminated throughout the entire yard. Combustibles to that necessary to provide a dirt berm at least 1'h times should be removed as they accumulate. the height of the pile. C-5.1.2 Smoking should be prohibited within the tire (c) Percent of opening in exposing wall area should be considered to be percent. storage area. Other types of potential ignition sources such �. as cutting and wilding, heating devices, open fires, etc., (d) Severity of exposing fire should considered as severe. should be prohibited. CT1 q-.�e� �e .V pair I ORn rdlliett • 231D-14 STORACE OF ROHRER TIRES 250' Max. I I'� ►� Distance by Table C-4.2.3 , 250' Max. Tire Pile Distance by ,1If Tire Pile L Table C-4.2.3 I' A Distance by Table C-4.2.3 Building (or Did Berm 1 1/2- times Pile Height) Cross Aisle Tire Pile Main Tire Pile Aisle Figure C-4.3.1 "fire Pile Arrangement. • C-5.1.3 Suitable safeguards should be provided to mini- Appendix D Referenced Publications mize the hazard of sparks from such equipment as refuse • burners, boiler stacks, vehicle exhaust, etc. D-1 The following documents or portions thereof are C-5.2 Water Supplies. referenced within this standard for informational purposes only and thus should not be considered part of the require- C-5.2.1 Either a public or private fire main and hydrant system should be provided. A water system should be pro- ments of this document. The edition indicated for each vided to supply a minimum of 1000 gpm(3780 Umin)for reference is the current edition as of the date of the NFPA less than 10,000 units storage, or 2000 gpm(7560 Lmin) issuance of this document. for 10,000 units or greater for a duration of 3 hours.. • D-1.1 NFPA Publications. National Fire Protection C-5.2.2 If there is access to a lake, stream, pond,or other Association, Batterymarch Park, Quincy, MA 02269. body of water in the vicinity of the storage area a fire NFPA 10-1988, Standard for Portable Fire Extinguishers department suctionconnection should be provided. NFPA 13A-1987, Recommended Practice for the Inspection, Testing and Maintenance of Sprinkler Systems C-5.2.3 If fire hoses are not immediately available from NFPA 600-1986, Rda(ioru or Organization, Train- responding public fine departments,on-site storage of 1000 ft ecommen (304.8 m) of 2'h-in. (63-mm) hose and sufficient nozzles ing and Equipment aJPnoate Fire Bngader should be provided. In addition to water hose streams,high NFPA 80A-1987, Recommended Practice for Protection of expansion foam may be used to control or extinguish scrap Buildings from Extenor Fire.Exposures. tire fires. C-5.2.4 Bulldozers, front-end loaders and similar equip- ment can be used to move tires not yet involved in the fire, to create breaks in the lire pile or to cover burning tires with soil. �ilc; 1989 t:ehion PL0456 910998 CONTAINS PICTURES PLEASE SEE ORIGINAL FILE Hello