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HomeMy WebLinkAbout931603.tiff ORkiii1AL HEARING BEFORE THE WELD COUNTY COMMISSIONERS REPORTER'S TRANSCRIPT April 5, 1993 IN RE: CENTRAL WELD/GREELEY-MILLIKEN LANDFILL - WASTE SERVICES CORPORATION. APPEARANCES: ARTHUR P. ROY, ESQ. 1011 - 11th Avenue Greeley, Colorado 80631 and SAUNDERS, SNYDER, ROSS & DICKSON, P.C. By Eugene F. Megyesy, Jr. , Esq. 707 - 17th Streeet, Suite 3500 Denver, Colorado 80202 Appearing on behalf of Waste Services Coporation. HOBBS, TROUT & RALEY, P.C. By Gregory J. Hobbs, Jr. , Esq. 1775 Sherman Street, Suite 1300 Denver, Colorado 80203 Appearing on behalf of Ashton-Daniels Neighborhood Association. LEE D. MORRISON, ESQ. Office of the Weld County Attorney 915 - 10th Street Greeley, Colorado 80631 Appearing on behalf of the Weld County Commissioners. fB R `S-1 BILLINGS REPORTING SERVICE EK � pd t Registered Profession' • 9316D3 r Z Greeley Fort Collins (303)356-3306 4,37 710- 11th Avenue.Suite 106 X800-546 3306 356.33 419 Canyon Avenue,Suite 220 Greeley. Colorado 80631 Fnx(wa>aw3�a2 Fort Collins, Colorado 80521 2 1 Weld County Commissioners: Constance Harbert, Chairman W. H. Webster 2 George E. Baxter Dale K. Hall 3 Barbara J. Kirkmeyer 4 Clerk to the Board: Carol Harding County Finance Office: Don Warden 5 Planning Services: Chuck Cunliffe Weld County Health Dept. : John S. Pickle 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BILLINGS REPORTING SERVICE " 084 3 1 PROCEEDINGS 9 : 17 a.m. 2 MS. HARBERT: We will now reconvene 3 the regular meeting of the Weld County Board of 4 Commissioners, and our next item is Planning, 5 Item 1, Consider Probable Cause Hearing for Central 6 Weld/Greeley-Milliken Landfill - Waste Services 7 Corporation. 8 Carol Harding, our clerk of the board, will 9 be passing out cards. If you care to speak for or 10 against, we would recommend that you fill out a card, 11 and your names will be called in the order they are 12 turned into me. Anybody that needs a card needs to 13 make sure that Carol gets one to you. 14 Would you please, on the card, in the upper 15 left-hand corner, would you write "for" or "against" so 16 that we may have an orderly testimony here. Just write 17 "for" or "against. " 18 UNIDENTIFIED SPEAKER: For or against what? 19 MS. HARBERT: The probable cause hearing. 20 Are you for or against having a show cause hearing? 21 That's what we're here today for, is to decide whether 22 we will be having a show cause hearing. 23 MR. HOBBS: Chairperson Harbert, I 'm Greg 24 Hobbs representing the Ashton-Daniels Neighborhood 25 Association. We did, prior to the hearing, submit a BILLINGS REPORTING SERVICE :3 1.06 4 1 suggestion that at least the members of our group be 2 considered in a presentation for about an hour. 3 And I would at least, would like to clarify 4 for those who are filling out cards in our group, that 5 if they would indicate that they are members of the 6 Ashton-Daniels Neighborhood Association, perhaps those 7 cards could be called as we present our matter. 8 Also, there is a matter of convenience with 9 respect to citizen attendance. This may be a long day, 10 unfortunately, for all of us. We had asked that 11 sometime early or mid-afternoon, that we be granted at 12 least an hour to present our material. 13 I do have a meeting in Northern Colorado -- 14 I represent the Northern Colorado Water Conservancy 15 District -- tomorrow morning in Loveland. If it's at 16 all possible to be able to present the neighborhood 17 association's presentation this afternoon, it would 18 certainly be appreciated. 19 MS. HARBERT: We certainly hope that you 20 will have that opportunity this afternoon, also. 21 MR. HOBBS: Thank you. 22 MS. HARBERT: Thank you. Anyone who would 23 like to be a part or is part of the Ashton-Daniels 24 group, if you will write that at the top of your card, 25 also. And, Carol, if you would divide those so they BILLINGS REPORTING SERVICE ^ 1.964 5 1 are all together, and we will discuss how we are going 2 to call those after a while. Thank you. 3 I would like to read a statement prior to 4 this which has been prepared by our legal staff. 5 This is a probable cause hearing to 6 determine if there is reasonable grounds for belief 7 that there are facts showing violations of Special Use 8 Permit No. 116 and Certificate of Designation No. 26 9 for the Greeley-Milliken Landfill, also known as the 10 Central Weld, which would warrant proceedings for the 11 show cause hearing. 12 The show cause could result in a revocation 13 or suspension of permits for the landfill . This 14 proceeding is to be conducted informally and not in 15 accordance with strict rules of procedure, as would be 16 the case in a court of law. 17 The Department of Health and Planning 18 Services will make the initial presentation, followed 19 by the permit holder. Members of the public will be 20 given an opportunity, and I understand the 21 Ashton-Daniels group has asked for a block of time to 22 give their presentation. The board cannot guarantee 23 the time for the presentation, but will try to 24 accommodate any group that has a spokesman or organized 25 presentation. BILLINGS REPORTING SERVICE :C1061 6 1 The permit holders will have the first 2 opportunity to present rebuttal evidence. Formal 3 cross-examination is not going to be used, but anyone 4 making a presentation is free to pose questions to 5 others giving evidence. The Board will see that the 6 questions are answered, preferably all together. 7 Please, everyone, including the permit 8 holders and the County departments, keep your 9 presentations as short and concise as possible. 10 Remember that this is a preliminary hearing and that 11 further proceedings are possible. Please do not repeat 12 the evidence that has been given before, and direct 13 your presentations toward the issues framed by the 14 staff. 15 We recognize that you are all intensely 16 interested in this matter, but outbursts from the 17 audience or interference with other parties ' testimony 18 will not be tolerated. Please direct your testimony to 19 the Board from the podium, so that all evidence can be 20 on record. We do have a court reporter here. The 21 microphone is at the podium here for anyone that 22 speaks. It is on tape; you will be recorded. 23 I will now turn it over to our staff for 24 their presentation. 25 MR. CUNLIFFE: Chuck Cunliffe, Weld County BILLINGS REPORTING SERVICE 7 1 Department of Planning Services. These comments are in 2 reference to Case No. ZCH-96 in the name of Waste 3 Services Corporation. The description is part of the 4 W2 SW4 and the SE4 SW4 of Section 32 , T5N, R66W of the 5 6th P.M. , Weld County, Colorado. The location is 6 approximately 1-1/2 miles northeast of the town of 7 Milliken. 8 "It is the opinion of the Department of 9 Planning Services ' staff that Condition of Approval #1, 10 as approved for Special Use Permit #116, is not in 11 compliance. 12 "Condition of Approval #1 states: That any 13 sanitary landfill facility to be installed shall be 14 approved by the State Health Department. 15 "Mr. John Pickle, in his memoranda dated 16 February 22 , 1993 and March 30, 1993 , to Chuck Cunliffe 17 and his memorandum dated April 1, 1993 , to the Board of 18 County Commissioners, has identified the items of 19 noncompliance with Condition of Approval #1 for Special 20 Use Permit #116. 21 "On April 1, 1993 , Waste Services 22 Corporation submitted applications for Amended Special 23 Use permit #116 and amended Certification of 24 Designation #26. Bill Hedberg' s letter of March 31, 25 1993, is attached. The Department of Planning Services BILLINGS REPORTING SERVICE 8 1 is proceeding with the processing of the applications. 2 "Based upon the above information, the 3 Department of Planning Services and the Weld County 4 Health Department recommends that the probable cause 5 hearing be continued to December 1, 1993, to allow 6 sufficient time for the amended Special Use permit and 7 amended Certificate of Designation applications to be 8 reviewed and considered by Weld County during the 9 standard land-use application review procedures. " 10 MS. HARBERT: Do you have anything else you 11 want to present? 12 MR. CUNLIFFE: Not at this time. 13 MS. HARBERT: John, do you? 14 MR. PICKLE: John Pickle. Do you wish to 15 proceed? 16 MS. HARBERT: Yes. 17 MR. CUNLIFFE: I guess we are -- we would 18 prefer not to give additional testimony at this time 19 unless the Board so chooses. We are prepared on 20 that -- at least, Mr. Pickle is prepared to present the 21 supporting documentation that we believe that Condition 22 No. 1 is still in violation. 23 But based upon our recommendation, we would 24 only give that testimony if the Board would ask us to, 25 or have additional questions based upon the BILLINGS REPORTING SERVICE 9:1,081 9 1 recommendation. 2 MS. HARBERT: Okay. Do you wish to hear 3 additional testimony or would you rather wait until it 4 comes up during the hearing? 5 MS. KIRKMEYER: Wait. 6 MS. HARBERT: We will go ahead and proceed 7 with the applicant. 8 MR. MORRISON: Technically, we have the 9 respondent next. They have replied but that' s not the 10 proceeding before you today. 11 MS. HARBERT: Sorry, I misspoke. The 12 respondent, then. We will go ahead, and you may make 13 your presentation. And, again, we ask you to keep it 14 as brief as possible. 15 MR. HOBBS: Excuse me, Madam Chairman. 16 MS. HARBERT: I 'm sorry, sir, you are out 17 of order. 18 MR. HOBBS: I have a point of clarification 19 on the procedure. 20 MS. HARBERT: Would you like to come to the 21 microphone and state your name, please. 22 MR. HOBBS: Of course. Greg Hobbs. I am 23 the attorney for the Ashton-Daniels Neighborhood 24 Association. I merely have a point of clarification 25 here. BILLINGS REPORTING SERVICE 9n41061 10 1 When the recommendation of the staff was 2 made, it wasn't clear to -- as to whether or not they 3 were going to present evidence today, in my opinion. 4 They left that to the discretion of the chair. 5 I believe that the chair should exercise 6 discretion to hear evidence, because I think it's going 7 to be necessary in order to go to the next stage, which 8 would be a probable -- would be a show cause hearing 9 for that evidence to be presented. 10 So I am asking the commissioners basically 11 to hear at least a summary of the evidence of 12 violation, particularly of Condition 1 of the original 13 resolution. Without a summary of that evidence, I 14 don't believe the commissioners can make the 15 determination that is the issue before this commission 16 this morning. 17 The issue is not whether to continue the 18 hearing. The issue is whether to grant a hearing on a 19 show cause. That ' s what was noticed to the public. 20 That's what we are prepared to address today. Thank 21 you. 22 MS. HARBERT: Thank you. 23 Legal counsel, would you advise us on that, 24 please. 25 MR. MORRISON: Well, I guess it would BILLINGS REPORTING SERVICE 9 "1.06 11 1 probably assist everyone if you directed Mr. Pickle to 2 go ahead and present his evidence at this point. 3 Unless you want to -- unless someone is prepared to 4 continue -- to move to continue this on the basis of 5 the application. 6 Otherwise, I would suggest Mr. Pickle go 7 ahead and present his -- at least a summary of his 8 evidence. I think that will assist everyone. 9 MS. HARBERT: Okay. Thank you. 10 John? 11 MR. PICKLE: John Pickle with Weld County 12 Health Department. 13 Madam Chairman, I 've prepared a packet with 14 my statements. I would like to place that into the 15 record, but should I read that at this point or 16 summarize it? 17 MS. HARBERT: I think that we've probably 18 all had copies of it, but I think because of the people 19 that are here today, perhaps -- do you have a summary 20 written there? 21 MR. PICKLE: Yes. 22 MR. MORRISON: Mr. Pickle, is that the 23 memo of April 1 -- 24 MR. PICKLE: That's right. 25 MR. MORRISON: -- directed to the Board of BILLINGS REPORTING SERVICE 12 1 County Commissioners? 2 MR. PICKLE: That's correct. 3 MR. MORRISON: That' s been marked as 4 Exhibit GG. 5 MR. PICKLE: "The Central Weld Sanitary 6 Landfill has been in operation at least since 1971. 7 Waste Services Corporation took over the operation in 8 1989 and merged with Waste Management of Colorado, 9 Inc. , in 1991. 10 "The site has been monitored over the years 11 by the Colorado Department of Health, as well as Weld 12 County Health Department. Our Department has tried to 13 maintain an inspection frequency of at least four 14 visits per year. In addition, our laboratory sampled 15 Central Weld' s monitoring wells until the discovery of 16 Volatile Organics indicated a more sophisticated 17 monitoring program was necessary. 18 "In July of 1992 , I met with Bill Hedberg 19 of Waste Services at this facility. At that meeting we 20 discussed the history of groundwater problems at this 21 site and Waste Management' s efforts to control them to 22 date. Mr. Hedberg also informed me at that meeting 23 that Waste Management' s Laboratory had discovered low 24 levels of contaminants in several downgradient 25 monitoring wells and that a full written report would BILLINGS REPORTING SERVICE 9:1.061 13 1 be forthcoming. He asked that in light of these 2 findings Central Weld be allowed to discontinue its 3 agreement with Weld County for monitoring, and contract 4 with a more sophisticated laboratory. I readily agreed 5 with this proposal since our lab could not test for 6 Volatile Organic Compounds. 7 "As clarification for the Board, Volatile 8 Organic Compounds are contaminants commonly from 9 landfill leachate, as well as underground storage 10 tanks, agricultural runoff, and other sources. VOCs 11 are common constituents in industrial and household 12 solvents pesticides, and other chemical products. 13 Toxicological studies have shown that some of these 14 organics have the potential for carcinogenesis in human 15 beings. Consequently, their presence in the 16 groundwater is a public health concern. 17 "In August, 1992 , we received 18 the Hydrogeologic and Geotechnical Characterization for 19 the Central Weld Sanitary Landfill, Weld County 20 Colorado. After review and discussion with Colorado 21 Department of Health personnel, we cited the Central 22 Weld facility in October, 1992 . " 23 There' s two letters in your packet I would 24 like to enter into the record. And this is a complete 25 copy of the Hydrogeological and Geotechnical Report BILLINGS REPORTING SERVICE 14 1 that I would like to also enter into the record. 2 "Waste Management performed confirmation 3 sampling at the Central Weld facility in September, 4 1992 . The results confirmed previous findings 5 submitted in the Hydrogeological Characterization of 6 July. " 7 This is a full copy of the Central Weld 8 Confirmation Groundwater Sampling, and I would like to 9 place that into the record. 10 "Golder Associates Inc. performed an 11 Expanded Hydrogeological Investigation at the Central 12 Weld Sanitary Landfill, Colorado in October, 1992 . The 13 purpose of this investigation was to determine the 14 extent of" the contamination -- or "extent of migration 15 of VOCs offsite. " 16 And here also is a copy of that report, 17 the Central Weld Sanitary Landfill Confirmation 18 Groundwater Samplings, which I would like to place into 19 the record. I have included portions of these in the 20 packet for brevity. 21 "Since October, subsequent inspections, 22 discussions with Colorado Department of Health 23 personnel, and meetings with Waste Management have 24 culminated in Weld County Health Department citing the 25 Central Weld facility for four (4) violations, and BILLINGS REPORTING SERVICE �' Z..Oa 15 1 requesting this Hearing. " 2 "The Department contends that Central Weld 3 Sanitary Landfill is in non-compliance with existing 4 rules in the following areas: 5 "1. The operators of the . . . Landfill 6 have not submitted a complete Design and Operations 7 Plan. There is some question as to whether or not this 8 was a requirement at the time this facility was 9 permitted. Such a report was required in the 1971 10 Amendments to the Solid Waste Act prior to the hearing 11 by the Board of County Commissioners, but the Act 12 requires such a report only, 'as may be required by the 13 (State Health) Department by regulation. ' The State 14 appears to have decided that no report was necessary as 15 they treated the landfill as a grandfathered site. 16 "Regardless of the State' s position, it 17 appears that the Board of County Commissioners expected 18 such a review and that one never occurred. A review of 19 the files does not show that there ever has been an 20 'approval ' by the State Health Department. 21 "The Board of County Commissioners 22 requested a Design and Operations Plan for this 23 facility by November 12 , 1992 . A partial submission 24 was made by Waste Management. After review, this 25 submission was considered incomplete. " BILLINGS REPORTING SERVICE t M_i-i ()WA. 16 1 A copy of a letter of February 22 , which I 2 would like to also place into the record. 3 "This is a violation of 30-20-103, Colorado 4 Revised Statutes. 5 "2 . The Central Weld Sanitary Landfill 6 continues to operate without required Discharge 7 Permits. This fact is documented in letters from Waste 8 Management, November 16, 1992 , and Colorado Department 9 of Health, November 17, 1992 , " which I would like to 10 also place into the record. 11 "Colorado Department of Health, Water 12 Quality Division personnel have indicated that despite 13 application for required permits, the facility is in 14 technical violation of the rules, but they are holding 15 further enforcement in abeyance so long as the facility 16 continues in good faith with the application process. " 17 We agree that "this is a violation of 18 Subsection 2 . 1. 2 of the Solid Waste Regulations and 19 25-8-501, Colorado Revised Statutes, " which are 20 attached, "but it appears this condition is near final 21 correction. " 22 "3 . The Central Weld Sanitary Landfill 23 continues to contaminate the groundwater, and this 24 contamination has migrated offsite. This fact is 25 evidenced by Waste Management in two documents: The BILLINGS REPORTING SERVICE 17 1 Hydrogeological and Geotechnical Characterization for 2 the Central Weld Sanitary Landfill, July 1992 , 3 pages 41, 42 , 55, and 57; and the Expanded 4 Hydrogeological Investigation at the Central Weld 5 Sanitary Landfill, Colorado, pages 5, and 6. The 6 Department feels that this is a violation of 7 Subsections 2 . 1. 2 of the Solid Waste Regulations, 8 specifically, 3 . 11.5 of the Water Quality Commission 9 Rules, and 2 . 1.4 of the Solid Waste Regulations. That 10 this is a violation of 2 . 1. 4 is also indicated in a 11 letter from Colorado Department of Health to Waste 12 Management dated December 21, 1992, specifically 13 page 4, paragraph C. 1. 14 "That this is" -- which I would like to 15 also place that letter in the record. 16 "That this is a violation is also further 17 indicated in an Attorney General ' s Opinion dated 18 March 5, 1993 . 19 "4 . The Central Weld Sanitary Landfill has 20 allowed solid waste to come into contact with 21 groundwater on this site. This is documented in the 22 Hydrogeologic and Geotechnical Characterization for the 23 Central Weld Sanitary Landfill, July, 1992 , page 34 . 24 This condition results in the production of leachate, a 25 source of groundwater pollution and public nuisance. BILLINGS REPORTING SERVICE 18 1 "This is a violation of Subsection 2 . 1.4 of 2 the Solid Waste Regulations. In addition, this too is 3 indicated in the Attorney General ' s Opinion dated 4 March 5, 1993 . 5 "An inspection by our staff on March 2 , 6 1993, indicated that the Central Weld Sanitary Landfill 7 was still in non-compliance in the areas referenced 8 above. Further, the Weld County Health Department and 9 the Colorado Department of Health feel that items #3 10 and #4 constitute a public nuisance. We would ask that 11 the Board of County Commissioners find that, on 12 balance, there are sufficient facts shown to justify 13 proceeding with a Show Cause Hearing. " 14 MS. HARBERT: Thank you. Do you have 15 anything else? 16 MR. PICKLE: No. Thank you. 17 MS. HARBERT: All right. Now, the 18 respondents may give their presentation. 19 MR. HEDBERG: Good morning. My name is 20 Bill Hedberg. I 'm division vice president for Waste 21 Services Waste Management Company, and my 22 responsibilities include the direct management of the 23 Central Weld Sanitary Landfill . 24 We are pleased to be before you this 25 morning to address some of the allegations that have BILLINGS REPORTING SERVICE 19 1 been raised about the facility, and I would like to 2 take just a couple minutes of the Board' s time, take a 3 couple minutes to introduce a few of the team members 4 that have come up to either be part of the presentation 5 or be available for the County Commissioners for direct 6 questions that you may have. 7 MS. HARBERT: Excuse me just a moment. Can 8 everyone hear? 9 UNIDENTIFIED PERSONS: No. 10 MS. HARBERT: Is it this microphone that 11 you aren't hearing? All of them. 12 MR. TELEP: He might speak louder. 13 MS. HARBERT: Sometimes these mikes need to 14 be spoken into directly, so you might remember that as 15 you come forward to speak. Thank you. 16 MR. HEDBERG: Thank you. Do I need to 17 repeat any of the lead-in information? 18 MS. HARBERT: Is that okay now? Is that 19 better? 20 MR. HOBBS: Yes. 21 MS. HARBERT: All right. Thank you. 22 No, I think that's fine. Go ahead. 23 MR. HEDBERG: Again, to start with, a few 24 very brief introductions. I would like to introduce 25 Mr. Brad Keirnes, which is a previous shareholder of BILLINGS REPORTING SERVICE {� 1.'.7!'/71 20 1 the Waste Services Corporation; Mr. Bob Damico, which 2 is the mountain region vice-president, manager; Bill 3 Jeffry, which is mountain region general legal counsel; 4 Gene Megyesy, which is outside counsel from the firm of 5 Saunders, Snyder, Ross & Dickson, which has worked with 6 the company for this and other law issues. 7 Mr. Art Roy is our local legal counsel; Mr. Alan 8 Scheere is the environmental specialist for the 9 facility; Mr. Neal Schuessler is division 10 vice-president and comptroller for the facility. 11 I would like to introduce Mary King, which 12 is the legal counsel for the West Group for 13 Environmental Issues. Leonard Butler is the 14 vice-president and environmental manager for the 15 mountain region. Ward Herst is representing Golder 16 Associates, an independent consulting firm that we have 17 engaged. 18 And Mr. Tom Buchholz is the division 19 vice-president, or division president and general 20 manager for the Colorado Landfill Division. 21 MS. HARBERT: Thank you. 22 MR. HEDBERG: We have a little presentation 23 notebook that may summarize some of the things that 24 will be presented to you verbally today, and we would 25 like to pass it out. BILLINGS REPORTING SERVICE 21 1 In respect for the time this morning, I 2 would like to take just a few minutes to give a very 3 brief history of the facility. The facility was 4 properly permitted in 1971 and basically operated under 5 various ownership until 1979, at which time it became 6 under ownership of the Keirnes family. 7 And I would like to introduce again 8 Mr. Brad Keirnes to talk a little bit about its history 9 and some of the upgrades and operational interests of 10 the facility during the 19 -- late ' 70s, ' 80s, and 11 early ' 90s. 12 MR. KEIRNES: Good morning. This is a 13 little high now. 14 Madam Chairman, Commissioners, my name is 15 Brad Keirnes, for the record. I am a former 16 shareholder in Waste Services Corporation and formerly 17 did manage the Central Weld Sanitary Landfill. 18 If you' ll turn with me to Section 1 of the 19 overview you've just been handed, I would like to take 20 just about five minutes and give you a brief overview 21 of the history of the site from 1979 , when my family 22 became involved with it, to July of 1991, when we 23 merged our family-owned company with Waste Management 24 of Colorado. 25 To start off, contained in this section is BILLINGS REPORTING SERVICE ��++ r ,;,1.0 g 22 1 a copy of a service area map that came out of a 2 feasibility study we did for Weld County in 1979, that 3 took a look at all the solid waste management needs 4 throughout the county and established a county-wide 5 system that incorporated service areas. And at that 6 time the Central Weld Landfill was in existence and 7 became a facility to provide the solid waste disposal 8 capability for the central service area. 9 The same concept that has, in my opinion, 10 served the county very well during the last 12 to 13 11 years was also adopted into the Weld County 12 Comprehensive Plan, which currently projects a useful 13 capacity or remaining life for the facility of between 14 20 and 60 years. 15 When my family became involved with this 16 site, we set out to investigate its environmental 17 status, and we did start that effort by conducting a 18 geotechnical investigation in 1980, and that work was 19 done by Empire Laboratories. That study identified the 20 need to install an underdrain beneath the western 21 portion of the site to prevent the site and, 22 specifically, that area from impacts from artificial 23 groundwater conditions caused by upgradient land uses. 24 That study also identified the benefit of 25 beginning the staged installation of a surface and BILLINGS REPORTING SERVICE n �1•.1gt 23 1 groundwater diversion system and to further protect the 2 site from those unnatural groundwater conditions and 3 also provide for diversion of surface water run-on 4 around the facility. 5 Later, in 1984 , we engaged Warzyn 6 Engineering to conduct a hydrogeologic assessment of 7 the facility, which affirmed the benefit of the 8 continued staged installation of that diversion system, 9 and it also established the first-ever groundwater 10 monitoring program at the facility. And that program, 11 which was begun in 1984 , monitored both upgradient and 12 downgradient groundwater around the facility for base 13 parameters. 14 And shortly after installing that 15 monitoring system in 1984 , we then entered into a 16 contract with the Weld County Department of Health to 17 come out and actually perform the sampling and 18 analysis. 19 Moving on, some of the operational 20 considerations of the facility, we as a family made our 21 best effort to operate the site in compliance with 22 applicable regulations in a manner that would be 23 compatible with surrounding agricultural land uses, and 24 I think the record of compliance inspections that were 25 performed on the facility during the 12 years we were BILLINGS 1REPORTING SERVICE 931061 24 1 involved with it do show that there was a consistent 2 operational compliance history there. 3 And, in addition to being concerned with 4 compliance matters, we also made a sincere and best 5 effort to be a good neighbor to our neighbors in the 6 same manner that they try to be good neighbors to each 7 other. We tried to be sensitive to their concerns and 8 responsive, participated in some of the improvements 9 that were made to the area in terms of irrigation 10 systems and things of that nature. 11 So we were committed to being a good 12 neighbor, and I hope we succeeded to some degree. In 13 1990, 1991, we started looking forward to where the 14 industry was headed, and we saw Subtitle D on the 15 horizon, the new EPA regulations, and we felt a need to 16 assess the ability of that particular facility, the 17 Central Weld Landfill, to comply with those 18 regulations, and we had a preliminary assessment done 19 of the site, which found that it could be made to 20 comply with Subtitle D. 21 And at the same time, we internally 22 assessed our ability as a family to meet the various 23 demands associated with Subtitle D, financially and 24 otherwise, and recognized very definitely a need to 25 have greater environmental expertise, added financial BILLINGS REPORTING SERVICE 931061 25 1 strength to pay the costs associated with ongoing 2 compliance, and also the real need for longevity to 3 bear the perpetual responsibilities associated with the 4 facilities. 5 And we found, after honestly examining 6 where we were at as a family, that even though we knew 7 where we needed to get, we felt we couldn't get there 8 from here. So we felt the best thing we could do was 9 to merge our family-owned company with Waste 10 Management. 11 And I had known Waste Management, as I had 12 all of the other large waste companies. They have been 13 customers, competitors during the last 12 years, and I 14 felt that Waste Management was head and shoulders above 15 the rest in terms of their commitment to do it right, 16 to serve the County' s interest, to provide the service 17 that' s needed, to serve their customers and also to be 18 a good neighbor. 19 I felt also that they had the competence 20 necessary to meet the environmental, legal and 21 operational requirements associated with solid waste 22 facilities. And I also felt, in addition to having the 23 right commitments and the competence, they had the 24 ingredient that we probably lacked most, and that was 25 the capability to meet the financial demands and bear BILLINGS REPORTING SERVICE 931061 26 1 the long-term responsibilities. 2 So we did decide, as a family -- it was the 3 hardest decision that I have probably ever made in my 4 business life -- to sell our family business, but I 5 feel, looking back on it, that it was the right one. 6 Everything that I thought to be true of Waste 7 Management was proving to be true. 8 Immediately after the merger, they hit the 9 ground running and, in terms of investigating the 10 facility, going the next step in the process we had 11 begun during the '70s and ' 80s, in addition to doing 12 the investigation, they also started applying expertise 13 to interpret data that they had gathered, to start 14 properly planning for the continued operation of the 15 facility and its eventual proper closure. 16 With that, I will hand it back over to Bill 17 Hedberg. I will be happy to answer any questions. 18 MS. HARBERT: Are there any questions? 19 MR. KEIRNES: Thank you. 20 MS. HARBERT: Brad, I just have one 21 question. In 1980 it was determined that there was 22 a need for an underdrain. Did you install that 23 underdrain? 24 MR. KEIRNES: We did. We did install that. 25 MS. HARBERT: And then you also installed a BILLINGS REPORTING SERVICE 931061 27 1 diversion system? 2 MR. KEIRNES: We began installing the 3 diversion system around the upgradient portion of the 4 site. 5 MS. KIRKMEYER: In your history, you have 6 useful capacity for the facility is 20 to 60 years. 7 Does that take into account the recent approval of the 8 landfill near Keenesburg, or any other landfills in the 9 southern part of the county? 10 MR. KEIRNES: It probably did not. I 11 think that estimate contained in the Weld County 12 Comprehensive Plan was probably made before East Weld 13 was permitted, in which case, if you were to do the 14 same estimate today, it would probably be significantly 15 longer than 20 to 60 years. 16 MS. HARBERT: Thank you. 17 MR. KEIRNES: Thank you. 18 MS. HARBERT: Sir, you will be given a 19 chance after their presentation to ask any questions. 20 MR. HOBBS: I see. May I just clarify 21 that? Then we have to record our questions as each 22 witness is up, and then ask? 23 MS. HARBERT: Yes. That was explained in 24 our statement previously. 25 MR. HOBBS: And they will all be available BILLINGS REPORTING SERVICE 931061 28 1 to answer questions? 2 MS. HARBERT: Yes. 3 MR. HOBBS: Thank you very much. 4 MR. HEDBERG: Madam Chair, I would like to 5 take the opportunity to bring the history from the time 6 of the merger on up till basically the present time. 7 I joined Waste Services after spending 8 about 13 years in public accounting with 9 Anderson-Whitney in 1991 -- 1990, 1991, and at that 10 point in time was more planning and finance director, 11 moving on into the spring and summer of ' 91 as 12 vice-president and general manager, and then, through 13 the combination, have stayed on as the site manager, in 14 that role, just for a little history on my background. 15 Basically, the facility, as Brad indicated, 16 after the combination with Waste Management was looked 17 into, from an environmental standpoint, from an 18 operational standpoint, for any waste that we could 19 take, what had been done by the previous owners and 20 operators and either continue or looking for waste to 21 improve either the knowledge or the operations. 22 A lot of what was being done was in line 23 with the, basically, the environmental plans and 24 principles that Waste Management has, that 's exhibited 25 that. I won't take the time right now, because of the BILLINGS REPORTING SERVICE 931061 29 1 time constraints we have on today, but I 've included 2 that for the board members to be able to look into what 3 are the various principles and policies that Waste 4 Management has for environmental issues. 5 Nevertheless, as Brad mentioned, we hit the 6 ground running, completed the groundwater and service 7 water diversion structures that were on the upgradient 8 sides of the site. That was completed in the September 9 or October 1991 area. Got to about the end of the 10 year, contracts were in place to engage our selected 11 independent consultant, Golder Associates, to determine 12 a comprehensive evaluation of the hydrogeologic and 13 geotechnical aspects of the facility. 14 I would like to just run through some of 15 these things real quick. Getting into those areas, I 16 would like Mr. Leonard Butler, our environmental 17 director for the region, to be able to talk about the 18 particular engineering aspects of each. But basically 19 looking down the list, we engaged them for that. 20 We engaged SEC Donahue, which is now RUST, 21 for the preparation of the formal design and operations 22 plan, feeling that this was not a legal requirement; 23 nevertheless, it met with the principles and goals of 24 Waste Management to have the comprehensive document to 25 govern and discuss the various attributes of the BILLINGS REPORTING SERVICE 931061 30 1 operation and the development of the facility. 2 Basically, the -- in February, also, we 3 were advised the existing special waste acceptance and 4 screening plan, formalized that in a document and 5 submitted that for review and approval by the various 6 health agencies of both County and State. 7 The fieldwork during that springtime was 8 being conducted for both the screening plan and the 9 geotechnical investigation. In July, we received a 10 draft report of that initial Golder investigation, and 11 it was at this time that we had an indication that 12 there were some very light concentrations of volatile 13 organic compounds in three of the downgradient wells 14 and the -- 15 We felt this was not a legal issue, but it 16 was a concern to us because of things that could go 17 into potential health risks. We got together with the 18 health departments, both County and State, got together 19 with the impacted neighbors, to let them know that, 20 and basically set a course of action to further 21 characterize and get better understanding, really, of 22 what we were dealing with at the facility. 23 This additional testing was performed. We 24 first did operation sampling. Then we engaged Golder 25 again to perform a standard hydrologic and geotechnical BILLINGS REPORTING SERVICE 931061 31 1 investigation dealing specifically with VOC on the 2 downgradient side to found out not only further 3 investigation of concentrations, but also any 4 indications of migration. 5 Also in September, completed a new and 6 updated groundwater, a gas monitoring program. The -- 7 also, during that same fall, '92 now, there had been 8 some concerns raised on some of the surface water 9 conditions around the site, so we engaged Golder to 10 perform a surface water investigation, looking at 11 quality and changes of various surface waters around 12 the facility. 13 Then in November we submitted the 14 application for the discharge permit, for the 15 underdrain. Also in November submitted the conceptual 16 design plans for the facility at the request of the 17 Board of Commissioners at that time, basically talking 18 about what the contours and sequence filling of the 19 facility would be over the remainder of its normal 20 life. 21 December, we completed the rest of the 22 document dealing with the preliminary design operations 23 and closure plan. In January, we had gotten some 24 responses back from the State Health Department asking 25 for additional testing in regard to the discharge BILLINGS REPORTING SERVICE 931061 32 1 permit for the underdrain. That situation was 2 performed, or that sampling was performed, and 3 submitted in March to meet their requests and desires. 4 Again, in March, we also completely revised 5 all these various site documents that had been 6 prepared. I might throw this up so that the audience 7 will have a chance to see that, as well. 8 Basically, this (indicating) would be a 9 summary of the site documents that were basically 10 codified during March to -- in preparation of 11 voluntarily submitting an application to amend the 12 existing CD and special use permit. 13 Basically, what it includes is all of the 14 documents we've talked about up to this time, but 15 trying to codify those together to make that 16 comprehensive review that would be made available in 17 the amendment process a little easier for both the 18 commissioners and the various planning and health 19 agencies, as well as the other agencies that would be 20 included in that, in that referral process. 21 At this time I would like to field any 22 questions you might have, and then turn the 23 presentation over to Leonard Butler to get more details 24 into some of the environmental issues. 25 MR. ROY: Could I rise to a point of BILLINGS REPORTING SERVICE 931061 33 1 clarification? 2 MS. HARBERT: State your name. 3 MR. ROY: Yes. My name is Arthur Roy, 4 attorney, counsel to Waste Management and Waste 5 Services. 6 Mr. Hobbs raised a procedural point and I 7 raise one. The initial comments indicated that there 8 wasn't going to be formal cross-examination, that we 9 would answer questions. 10 I gathered from Mr. Hobbs' request at the 11 end of the first presenter that they wish to ask 12 something in the nature of cross-examination. If 13 that's going to occur, we' ll be here all day. If they 14 have generic questions for us at the end of the 15 presentation, we may be able to prepare answers and 16 present them. But to go through some sort of direct 17 questioning is going to take a long time. 18 MS. HARBERT: I will refer to Lee, but 19 usually our procedure is for the presenter to present 20 their presentation and for those that object to the 21 cause will come back and present theirs, and present 22 any questions to you. And then you have the last 23 rebuttal, to answer those questions, not -- it won't be 24 a back and forth type of thing. 25 I think you are familiar with our BILLINGS REPORTING SERVICE 931061 34 1 procedure. 2 MR. ROY: Normally, a probable cause 3 hearing is between the County and the operator, and is 4 a bi-parte proceeding, not a tri-parte proceeding. 5 MS. HARBERT: I realize that. 6 MR. ROY: And I understand there is a need 7 to have public input, and we don't object to the public 8 input, but it can become a circus if it gets out of 9 hand. 10 MS. HARBERT: We understand that, also. 11 Lee, would you like to comment? 12 MR. MORRISON: We haven't seen the nature 13 of Mr. Hobbs ' questions. It is not -- although it's 14 principally brought by the departments and heard by the 15 commissioners, it doesn't preclude public testimony in 16 this kind of proceeding. 17 So I think we' ll deal with the nature of 18 the questions when they are posed. 19 MS. HARBERT: I agree with that. 20 MR. HEDBERG: Thank you. I would like to 21 present Mr. Leonard Butler for the engineering side of 22 this. 23 MS. HARBERT: Thank you. 24 MR. BUTLER: Good morning. Chairperson 25 Harbert, Weld County Commissioners, my name is Leonard BILLINGS REPORTING SERVICE 931061 35 1 Butler, and as Bill Hedberg introduced me, I am the 2 environmental manager with Waste Management of 3 Colorado. 4 I might first tell you a little bit about 5 what specially qualifies me for my job. I have a BS 6 and MS in environmental engineering, I am a 7 professional engineer in the state of Colorado, and a 8 diplomats with the American Academy of Environmental 9 Engineers. 10 Along with my presentation, to assist in 11 any questions that you have this morning, I 've asked 12 the facility engineer, Alan Scheere, who is here. 13 Alan's background is 13 years as an environmental 14 health professional . He formerly was with Tri-County 15 Health Department and has a bachelor of arts in 16 environmental sciences from the University of Colorado. 17 In addition, I 've asked Warren Herst. 18 Warren is with Golder and Associates. Warren has 19 almost 10 years of experience as a professional 20 hydrogeologist and as a certified geologist. This is 21 my technical team, and I 'd like to go ahead. 22 In your presentation notebook, you' ll note 23 I 've put together an outline. And in that outline I 've 24 attached the overall summary of my presentation this 25 morning. What I would like to do is highlight for you, BILLINGS REPORTING SERVICE 931061 36 1 given the nature and time of this hearing, to a very 2 brief but very important overview, and I ' ll use some 3 posters and some overheads. 4 As you' ll note in this presentation, I ' ll 5 be speaking about three different areas. The first is 6 with regard to our environmental assessments at the 7 site. The second pertains to the design or 8 development, operations and closure plans, and finally, 9 I would like to talk about our environmental 10 commitments. 11 You might ask, as you look over at this 12 table, what are all these notebooks? As I think you 13 saw from Bill Hedberg' s presentation, many of them are 14 part of the amended application. In fact, all of these 15 are part of the amended application, but they are built 16 from all of these documents and all of these plans. 17 So over the last year and a half, we've 18 been very busy. You might ask, why are we doing this? 19 Well, first, as a company, Waste Management of Colorado 20 has 14 environmental principles, of which two of them I 21 would like to highlight. The first is to protect the 22 environment and the second is compliance. 23 And we feel that, to meet our own high 24 standards, we needed to initiate an assessment and 25 prepare for the upcoming Subtitle D regulations. That BILLINGS REPORTING SERVICE 931061. 37 1 preparation, which has gone over the last year and a 2 half, we've spent close to three-quarters of a million 3 dollars doing this effort, and we're prepared today, 4 with today's engineering, to resolve any of the issues 5 at the site through an amended application process. 6 I believe that in our working relationships 7 with the Weld County Health Department, the Planning 8 Department, and the Colorado Department of Health, we 9 have exhibited a high spirit of cooperation in working 10 to protect the environment. 11 Moving first to the first of three topics, 12 environmental assessments, as Brad Keirnes indicated, 13 prior to the merger between Waste Services Corporation 14 and Waste Management of Colorado there were various 15 investigations conducted. After 1991 a number of 16 investigations were conducted, which are exhibited on 17 this table. 18 Well, what did we do out at the site? In a 19 nutshell, what we did is we tripled the number of 20 groundwater monitoring wells, we installed over 35 21 investigatory borings to assess the character of water 22 quality, and also to implement a gas -- landfill gas 23 monitoring program. 24 Can you excuse me a moment? I 'm finding 25 I 'm getting dry just standing up here. BILLINGS REPORTING SERVICE 931061 38 1 (Pause. ) 2 MR. BUTLER: Getting over the infamous 3 sinus infection of northern Colorado. 4 Based on the information collected from 5 this investigation, I would like to summarize nine of 6 our findings. First, we looked at landfill gas, and we 7 found that landfill gas concentrations are generally 8 nondetectable. 9 We also looked at the surface water 10 drainage works, which consisted of diversion ditches 11 and then associated French drains, and found those to 12 be functioning properly, as designed. 13 We also, through this investigation, looked 14 at shallow groundwater and deep groundwater. Shallow 15 groundwater generally flows from north to south. I 16 have a figure here which further illustrates -- I ' ll 17 use this one just for a moment -- which illustrates 18 with a number of colored dots all of the investigatory 19 borings, landfill gas monitoring wells. 20 MS. HARBERT: Sir, you need to take the 21 microphone. 22 MR. BUTLER: Do I need to do that? I ' ll 23 try and speak louder. I will stay here, rather than do 24 that. 25 The poster shows a series of investigatory BILLINGS REPORTING SERVICE 931061 39 1 borings, which are established groundwater monitoring 2 wells, landfill gas probes, geotechnical property, 3 boring holes, and all of this was used to summarize 4 these findings. And we found -- I wanted to get into 5 shallow groundwater. It moves generally from north to 6 south. Deep groundwater also mirrors that pattern and 7 flows from the northwest to southeast. 8 We also found that the potential for 9 contamination -- or excuse me -- communication between 10 the shallow and the deep groundwater system is low, 11 based on this information. We sampled the deep 12 groundwater. We found no impacts from the landfill to 13 the deep groundwater. 14 We did an assessment of all the groundwater 15 and all the registered and unregistered used wells in 16 the vicinity, and I would like to move to the next one 17 that shows the location and the vicinity of wells. 18 And the nearest wells were approximately 2, 000 feet 19 downgradient of the site. 20 As I mentioned, we found no impacts to deep 21 groundwater. What we found was that there was a 22 shallow groundwater table which had low levels of 23 volatile organic compounds. As Mr. Pickle indicated, 24 these can be from a variety of different sources, but 25 regardless, we've taken them and have been addressing BILLINGS REPORTING SERVICE 931061. 40 1 them in an environmentally responsible manner. 2 We believe that the cause of these is 3 because of an isolated area located up in the northwest 4 portion of the site where, because of off-site 5 irrigation practices of our neighbor to the north, that 6 has caused -- and which we believe has been impacted 7 from over the last few years -- land tiling and 8 artificially high groundwater, which we will talk about 9 in a moment, with how we intend to minimize future 10 contact of that water in that very isolated northwest 11 corner of the site. 12 But as a result of that contact, what we 13 believe has occurred is limited volatile organic 14 compound impacts in the shallow groundwater, as 15 delineated in this overhead. As you can see, the area 16 is very small, it' s very limited. It' s shown in a 17 light brown color on the south side of the facility. 18 MR. MORRISON: Before you go further, are 19 these figures contained in the Golder and Associates 20 report? And are these something that have previously 21 been put into evidence? 22 MR. BUTLER: This is the only exhibit that 23 is not contained. It' s in the presentation notebooks, 24 which we believe would be a record of this 25 presentation. BILLINGS REPORTING SERVICE 931061 41 1 MR. MORRISON: So the overhead is in the 2 presentation? 3 MR. BUTLER: It' s in the presentation 4 notebook as an exhibit, and should be kept as a part of 5 the record. 6 MR. MORRISON: Okay. 7 MR. BUTLER: Those were our findings. 8 Where do we go from here, you might ask. Well, we 9 retained Golder and Associates, as mentioned, and 10 prepared a hydrogeologic model of the site. 11 And what we found was that the primary 12 aquifer underlying the facility is the Laramie-Fox 13 Hills aquifer, although this area of the aquifer is 14 outside the Denver Basin, and we further delineated for 15 the hydrogeologic model three geologic units, of which 16 the surficial or uppermost unit was deemed to be a 17 silty clay to clay silt material. 18 Based on engineering property of soil tests 19 done on that, we found that the horizontal groundwater 20 flow could be estimated at approximately 95 feet per 21 year. Now, when we look at this figure again, as we 22 all know, this landfill has been open for approximately 23 22 years. 24 I think that, again, we enforced that, 25 although groundwater moves at 95 feet per year, we are BILLINGS REPORTING SERVICE 9J1061 42 1 seeing a volatile organic compound concentration, which 2 is moving slow and is no more than 30 feet to 200 feet 3 maximum, based on our investigation, off of the 4 landfill boundary. 5 I would like to move to further discussion 6 of what else we found in the groundwater in our 7 determination of existing environmental conditions. 8 What we found after extensive testing -- and we are not 9 dealing with fiction here, we are dealing with fact -- 10 the fact we spent a tremendous amount of money going 11 above and beyond the State regulations, the County 12 regulations, but to our own company high standards in a 13 spirit of cooperation, we have done a tremendous amount 14 of testing. 15 And what we found are basically four 16 volatile organic compounds which exist in the shallow 17 groundwater. This might make some sense to some folks, 18 but I will mention them, because I think it's important 19 that there are only four. And these are called 20 1, 1-dichloroethane, 1, 2-dichloroethane, trichloroethene 21 and tetrachlorethene. These are common volatile 22 organic compounds which can be easily treated, and we 23 will get into that a little bit later in my 24 presentation. 25 However, the important thing to note, the BILLINGS REPORTING SERVICE 931061 43 1 concentrations that we found are only slightly above, 2 only slightly exceeding the State of Colorado and 3 Federal drinking water standards. VOCs were not 4 detected in the deep groundwater. Further, no 5 pesticides or herbicides were detected in the 6 groundwater. 7 I think this is an important point to draw 8 out, because this site was listed on what' s called 9 CERCLIS. CERCLIS is a Federal inventory of all of the 10 disposal sites in our country, and there was an 11 assessment done many years ago to determine if the 12 disposal of pesticides may have caused a problem at 13 this site. 14 We believe that the testing we have done 15 shows that there is no leakage from the landfill that 16 would cause or that we could detect a problem from. 17 Further, we analyzed metals. We found no detectable 18 concentrations. We looked for radionuclides, 19 radioactivity. Those all appear to be natural . 20 The only surface water sample which 21 exhibited a detectable concentration of VOCs was the 22 landfill underdrain outlet, and there were only two 23 volatile organic compounds in the underdrain. 24 So we went further downstream to see if in 25 Spomer Lakes we could detect it. We went farther BILLINGS REPORTING SERVICE 931061 44 1 downstream in the discharge from Spomer Lakes. And in 2 both instances we found no organic compounds. 3 We found no pesticides or herbicides 4 detected in any of the water samples. Through this 5 focus sampling of the creek water downstream of the 6 landfill, it was determined -- and the State has 7 reviewed our findings -- that the milky white color in 8 the creek is probably caused by natural conditions. 9 The odors are also probably caused by natural 10 conditions which result in the decomposition of 11 sulfites. 12 I would like to move to the second part of 13 my presentation, the second of three, regarding the 14 development, operation and closure plans. These plans, 15 which are included in a number of large sheets which 16 were filed on March 31 with Weld County, go over the 17 design, operation and closure methods to be used by the 18 Central Weld Sanitary Landfill. 19 I think it's important to note, again, in a 20 spirit of cooperation, even though in 1971 plans 21 were -- of this nature were not required, we went 22 ahead, even before Chairman Kennedy' s letter in 23 October, and initiated the preparation of these plans. 24 And we've had an ongoing dialogue since 25 October with the Weld County Health Department and with BILLINGS REPORTING SERVICE 9:x`1061 45 1 the Colorado Department of Health regarding the 2 development and evolution. 3 The development plans include some basic 4 features which I 'd like to go over. The first one is 5 with regard to surface water management. Alan is going 6 to be putting up a poster here which goes over and 7 shows in blue some of the diversion works, French drain 8 that's been installed at the site. 9 These are necessary because of irrigation 10 activities upgradient, which have required more 11 extensive management of water levels within the 12 landfill, and by the construction of a landfill 13 underdrain, interceptor trench, and French drain. 14 As part of the amended permit application 15 submitted in March, 1993 , we're proposing to do three 16 key components. The first is to enhance and further 17 develop a system brought on/brought off perimeter 18 ditches. 19 These are shown in key design details. The 20 key design details first point out in the upper left 21 column two different ditches. One ditch will be used 22 for handling site runoff from the landfill . The second 23 will be used for handling site run-on, principally from 24 the practices of the property owner to the north of our 25 landfill. BILLINGS REPORTING SERVICE 91061 46 1 Secondly, I 'd like to go over the surface 2 water and irrigation water control system, which 3 enhances the existing French drain system and helps by 4 improving the French drain to further draw down the 5 shallow water that we've seen in a very isolated and 6 very small portion of the northwest corner of the site. 7 And, finally, what you see on the bottom of 8 the poster is a large schematic of a 54-inch CNP that 9 will be used to divert these irrigation waters around 10 our north perimeter and to the west of the facility. 11 In the evolution of the development plans, 12 we've worked very hard on determining how best to meet 13 Subtitle D for future service to Greeley and Weld 14 County. And what we have recently done is sign an 15 agreement to purchase an additional hundred acres of 16 land east, south and west of the existing site. 17 We believe this is important because it 18 provides us the elbow room in which to install interim 19 measures needed for future operation of the site, 20 including establishing true points of compliance for 21 the facility. 22 The landfill will not expand into the 23 buffer zone. Rather, the buffer zone will be used for, 24 one, elbow room to do interim measures and, number two, 25 as a source of soils to be used in the operation and BILLINGS REPORTING SERVICE 931061 47 1 closure of the Central Weld Sanitary Landfill . 2 I would like to talk about the next part of 3 the development operations and closure plan, which is 4 the operations plan. The operations plan addresses how 5 the facility will be operated. One of the major 6 components of the facility is with regard to how we 7 inspect incoming waste loads. These waste loads are 8 inspected at the gate and again at the time of 9 disposal. 10 We've implemented a hazardous waste 11 exclusion program and an access control plan, which is 12 included within the amended application process. What 13 is this about? Well, this program basically provides a 14 plan to identify and screen, both visually and through 15 extensive analytical testing, that no regulated 16 hazardous wastes, liquid wastes, or PCB wastes are 17 received at the site. 18 The plans also show with regard to 19 operations fill sequencing. A fill sequence plan is 20 broken basically into series of sequences to engineer 21 the proper development of the final gradient plan. 22 Another key component of the operations 23 plan is environmental monitoring, and the environmental 24 monitoring plan will include monitoring of groundwater, 25 landfill gas, and surface water. As I mentioned BILLINGS REPORTING SERVICE 931961 48 1 earlier, we have already tripled the number of 2 groundwater monitoring wells. 3 This was not required by the State. It was 4 not required by the County. And yet, we chose to do it 5 in a spirit of cooperation, voluntarily, to make sure 6 that we protected the environment, again which you will 7 recall is our first environmental principle. 8 In addition, in the amended application we 9 are proposing three points of compliance to address the 10 quality of groundwater downgradient of the site. 11 Finally, in operations must come closure, 12 and in the closure plan is a grading and drainage 13 configuration. The final elevation will be 14 approximately 40 feet higher than existing ground. 15 This contour will be necessary to achieve proper 16 drainage and blend with the surrounding area, to ease 17 the concerns of height and view restrictions. 18 This contouring, which will be necessary in 19 order to protect the environment, since, as you will 20 recall, a few minutes ago I mentioned that the 21 groundwater impacts are not coming from waste being put 22 on top, but they're coming from groundwater, shallow, 23 coming into contact with existing refuse placed at the 24 site in a very small and isolated portion, will provide 25 this central part of Weld County with approximately 12 BILLINGS REPORTING SERVICE 9310611 49 1 to 15 years, depending upon ours and your success in 2 waste reduction, recycling and minimization. 3 The post-closure, under the new Subtitle D 4 regulations, which we plan to meet if we're allowed to 5 continue to operate, will provide for post-closure care 6 for a 30-year period. 7 If the site is forced to close through 8 probable cause and show cause proceedings, this site 9 will not be governed by the same standards. We will 10 not all have the same high level of monitoring that is 11 now not required by current regulation. 12 Finally, the third part of my presentation 13 goes over environmental commitments. We believe that, 14 through our extensive work, we will demonstrate to the 15 satisfaction of Weld County and the State of Colorado 16 that our facility will meet all of the anticipated 17 Subtitle D regulations which will upgrade Colorado' s 18 solid waste program. 19 We acknowledge that shallow groundwater 20 immediately downgradient of the landfill contains VOCs 21 and that these VOCs are slightly above recognized 22 standards. 23 What we propose is to do two things: One 24 is to redesign the diversion trench and French drain, 25 and two is to evaluate the effectiveness of treating BILLINGS REPORTING SERVICE 331061 50 1 the groundwater via some new technology that has had 2 remarkable success over the last five years. 3 This technique is known as air sparging, 4 which specifically uses a series of wells to inject air 5 into the shallow groundwater. The bubbling effect 6 basically volatilizes the volatile organic compounds. 7 The effectiveness of the system can be measured in the 8 monitoring probe shown in the overhead, and we can 9 extract the vapors through a vapor extraction well. 10 What we propose to do, as contained in our 11 amended application, is to proceed on a pilot test 12 program the implementation of this air sparging 13 technique. 14 We believe a pilot scale test is 15 appropriate and should be done for a short time, until 16 it's expanded to treat that very small area in the 17 buffer area, which we plan to acquire. And then, once 18 the testing and the monitoring is concluded, we would 19 propose then to expand air sparging or choose another 20 suitable technique. 21 In summary, I think I 've gone over the high 22 degree of work that' s gone on over the last year and a 23 half with regard to environmental assessments and 24 preparation of design, development, operation and 25 closure plans. BILLINGS REPORTING SERVICE 9431061 51 1 The site is there. We've identified some 2 issues. As a good neighbor, we are prepared to deal 3 with them. So far, much of our work has all been 4 voluntary, and we will meet all the regulations that 5 are applicable to the site to comply with the future 6 Subtitle D regulations. 7 But with regard to the four points 8 addressed in Mr. Pickle's letter, I would like to point 9 out that, one, with regard to the lack of plans, I 10 believe the tape of the 1971 hearing will show that 11 Mr. Stoddard, as representing the Colorado Department 12 of Health, reviewed the application, concurred with the 13 application, and that even before Chairman Kennedy's 14 letter, we were in the midst of preparing development, 15 operation and closure plans, that these plans had been 16 coordinated closely with the Weld County Department of 17 Health. 18 With the same dialogue that we had had with 19 the hydrogeologic assessments, we had hoped to have 20 with the development plans, so for whatever reasons we 21 didn't have it, what I had proposed to do in our 22 submittal is present conceptual plans which would 23 establish a dialogue. This dialogue would be used for 24 the preparation of preliminary plans, and finally, we 25 would use this dialogue and comments received to BILLINGS REPORTING SERVICE 931061 52 1 incorporate any additional Subtitle D regulations into 2 final plans. 3 But after submitting the conceptual plans 4 in November and our written text accompanying those 5 plans in December, although we did hear from Mr. Pickle 6 in February that the plans were incomplete, we never 7 heard what the details of the incompleteness were, 8 other than there were four sheets regarding drainage, 9 which we had discussed with the Weld County Health 10 Department prior to looking at acquisitions of the 11 buffer area. 12 And so, other than having now submitted 13 those additional four sheets, we have not heard 14 anything extra that may be incomplete or lacking with 15 regard to these plans. But, nevertheless, we will work 16 closely with the Weld County Health Department, in our 17 continued spirit of cooperation, to address any issues 18 that come up in our amended application. 19 The second point of Mr. Pickle' s letter was 20 a lack of discharge permits. We filed for those. As 21 stated, those discharge permits are imminent, and we 22 should be receiving those shortly. 23 Finally, with regard to violation of 24 Section 2 . 1. 4 , we take exception to this, based on the 25 fact that inspections for the last 20 years, up until BILLINGS REPORTING SERVICE 331061 53 1 September of '92 , these inspections have continually 2 noted that the facility was in compliance. 3 The details of this compliance were that 4 there was adequate cover being applied, surface 5 drainage was adequate, and that, as an operator, the 6 facility continued to minimize nuisance conditions. 7 Therefore, we believe that we are not in violation of 8 Section 2 . 1.4 . 9 In summary, I believe that the historical 10 practices by Mr. Brad Keirnes, and current practices 11 over the last year and a half, illustrate a commitment 12 to compliance and protection of the environment, and 13 that we are here today to address in our amended 14 application any corrective issues that need to be done 15 to assure long-term compliance of this facility over 16 its useful life. 17 Thank you very much. 18 MS. HARBERT: Are there any questions for 19 Mr. Butler? 20 MS. KIRKMEYER: I have a question. You 21 said you submitted additional sheets regarding drainage 22 to Mr. John Pickle. When did you submit those? 23 MR. BUTLER: We submitted those in 24 conjunction with our amended application March 31. 25 And the reason, again, those were delayed was because BILLINGS REPORTING SERVICE 3j1961 54 1 we had worked closely with the project manager from the 2 Weld County Health Department and the State Health 3 Department, and we were trying to incorporate some 4 additional drainage improvements which could be 5 facilitated with the buffer area that was acquired 6 early in March. 7 MS. KIRKMEYER: And you made a statement 8 about, if the landfill were to close or were closed 9 today, or whatever, that the same standards wouldn't 10 apply. 11 MR. BUTLER: That 's correct. 12 MS. KIRKMEYER: What standards apply to the 13 landfill now? 14 MR. BUTLER: The existing State of Colorado 15 standards that have not incorporated Subtitle D. 16 MS. KIRKMEYER: And so what standards would 17 apply if the landfill closed now? 18 MR. BUTLER: The existing standards that do 19 not incorporate Subtitle D. The State of Colorado, in 20 May, will consider incorporation of the Subtitle D 21 standards into the state regulations. Currently, the 22 State of Colorado doesn't have a post-closure period 23 required. 24 MS. HARBERT: Any other questions? 25 MR. BAXTER: Madam Chairman, I would like BILLINGS REPORTING SERVICE .1.,;1961 55 1 to clarify something with Mr. Pickle. On this, the 2 sheets, then, that were sent to you, do they complete 3 the report? You said it was incomplete. 4 MR. PICKLE: At the time that I received 5 those sheets -- and they came in with the amended CD, 6 and I did not have time to review those -- no. 7 MS. HARBERT: Any other questions? We will 8 declare a 10-minute recess. We will come back at 20 9 minutes until 11: 00. 10 There is a canteen on the second floor and 11 there are restrooms on all floors. 12 (Recess from 10: 30 to 10: 42 a.m. ) 13 MS. HARBERT: Before we begin again, I 14 think it's quite obvious that there 's major 15 construction going on within the building, and we just 16 ask that you be extremely careful, that you don't trip 17 and fall over some of the plywood and rugs that have 18 been put out to save the flooring from the construction 19 process, and that you -- that we sincerely apologize 20 for noise that might go on. 21 We try to minimize that, especially during 22 times like this, but progress is in motion. 23 Mr. Butler, did you have something 24 additional to your presentation? 25 MR. BUTLER: I just wanted to make one BILLINGS REPORTING SERVICE 931061 56 1 comment and introduce Bill Hedberg, who will introduce 2 the next speaker. 3 MS. HARBERT: Okay. 4 MR. BUTLER: And my final comment, which I 5 think is important after our break and we returned, is 6 that, in our close working relationships since our 7 presence and historically, is that in those working 8 meetings and all the characterization activities we've 9 performed, that we agree with the Colorado Department 10 of Health, and that, by their actions, there is not an 11 immediate threat to the public health, and would agree 12 with their desire to proceed with corrective action. 13 With that, I would like to introduce 14 Mr. Bill Hedberg again. 15 MR. HEDBERG: Thank you, Leonard. I would 16 like to maybe help draw this back together. Also, 17 there is one thing that, I wanted to make sure we 18 didn't have a misunderstanding with the members of the 19 Board of Commissioners. 20 We had talked with the Weld County 21 comprehensive plan has included a 20- to 60-year life. 22 I believe that was back in 1987 when the plan was 23 drafted, and then updated through last year. 24 The contours that Mr. Butler talked about 25 of the highest point about 40 feet are not the same as BILLINGS REPORTING SERVICE 931061 57 1 what was included in the comprehensive plan. These 2 contours that we proposed in our amended application, 3 filed on April 1, would give an expected life of 4 probably 10 to 12 years, and so this -- 5 MS. HARBERT: Additional? 6 MR. HEDBERG: This is significantly less 7 than what the County was assuming in the comprehensive 8 plan and, basically, that was reduced to those levels, 9 basically in response to some of the comments we had 10 gotten from some of our neighbors, that the contours 11 needed to maybe blend in a little closer to the road 12 terrain, and not try to maximize the available capacity 13 of the facility, although it does reduce the ability of 14 the facility to meet the needs of the service area for 15 those later years. 16 I just wanted to make sure there was not a 17 misunderstanding. 18 MS. HARBERT: So you' re saying 10 to 12 19 additional years? 20 MR. HEDBERG: Yes, ma 'am. That' s basically 21 what's included in the amendment process that we're 22 proposing. 23 We've talked a lot about the engineering, a 24 lot about the types of things that the facility 25 management and environmental engineering staff has BILLINGS REPORTING SERVICE 931961 58 1 done. A lot of these things have been voluntary. 2 They've been above and beyond what the legal 3 requirements are. 4 That's consistent with what the commitment 5 of the company is. Basically, what we' re trying to 6 focus on is not only what is legally required, but 7 above that, what' s in the best interest of the 8 facility, the needs of the service area, the 9 environment of that neighborhood, and the needs of the 10 neighbors that we live next to out there. 11 However, there are some legal issues that 12 have been brought in through the allegations, and so I 13 would like to introduce our local counsel, Mr. Arthur 14 Roy, to address some of those issues. 15 MR. ROY: Good morning. My name is Arthur 16 Roy. You have, I believe, in your notebooks a sort of 17 an outline of what I want to address. You will be 18 happy to know I am, one, not going to read it to you, 19 and two, it's a basis for the discussion. And you can 20 read it, as well as listen to my comments. 21 The first alleged violation that has been 22 discussed is a failure to have an engineering design 23 and operations plan filed. This is alleged to be a 24 violation of CRS 30-20-103 by the Public -- Weld County 25 Health Department and Weld County Planning Department. BILLINGS REPORTING SERVICE 931961 59 1 The Colorado State Health Department disagrees and says 2 that that was not and is not a requirement for this 3 landfill. And this landfill was certified and 4 permitted to open in 1971. 5 Prior to that, the law was the Landfill Act 6 of 1967, which did not speak at all to an engineering 7 and design and operation plan, and the regulations 8 issued by the Colorado Department of Health in 1967 9 dealt solely with operational matters, not with the 10 application process. 11 If you read 30-20-103 and its predecessors, 12 it is an application statute. It is not an operational 13 statute. It deals with what an applicant must do, what 14 an applicant must submit before his application can be 15 reviewed and approved. 16 In 1971, effective April of that year, the 17 legislature adopted an act which added language to the 18 application section. That language is set out in the 19 outline, but the language was the first time there was 20 mention of doing geologic and hydrologic work, as a 21 part of the application required that that information 22 be submitted to the Department of Health in accordance 23 with regulations the Department of Health was to adopt. 24 The hearing on this matter before the Weld 25 County Commissioners occurred September 21 of 1971. BILLINGS REPORTING SERVICE 931%j 60 1 The regulations of the Health Department implementing 2 the statute were not adopted until February of 1972, 3 and were not effective until April of 1972 . And so the 4 regulations that called for this information and set 5 forth how it was to be presented were not in existence 6 at the time this landfill was certificated. 7 The State Department of Health, which has 8 the primary responsibility for the enforcement of these 9 regulations and drafted them and approved and enacted 10 them, has taken the position that existing landfills as 11 of the effective date of those regulations are 12 grandfathered. And this landfill meets that criteria. 13 And so there is not now and there never has 14 been a requirement that there be such a plan. If you 15 don't take the Department of Health's word for the fact 16 that this plan was not required and is not required, I 17 would address your attention to the 1991 amendments to 18 the Solid Waste Disposal statute. 19 And that statute says -- and I will take 20 the time to quote that -- No existing solid waste 21 disposal site facility which is operated pursuant to a 22 valid certificate of designation shall be deemed to be 23 in violation of any provision of this Part 1 because of 24 any failure to comply with application procedures which 25 are enacted subsequent to the issuance of such BILLINGS REPORTING SERVICE 931061 61 1 certificate of designation. 2 And so I would submit, not only has the 3 Department of Health grandfathered this facility; so 4 has the State Legislature, as recently as 1991. 5 Now, the regulations were originally 6 proposed to the State Department of Health for 7 enactment in October, shortly after this hearing, 8 shortly after the hearing at which this facility was 9 certificated. 10 Mr. Stoddard, who was the representative of 11 the State Department of Health, was present at the 12 hearing in September. His testimony is in the record. 13 His testimony is also quoted in my notes before you. 14 Basically, what he says is that 15 Mr. Moffat had submitted to the State Department of 16 Health in August of 1971 essentially what the State 17 Department of Health was going to require in their 18 regulations, and that that had been gone over by the 19 State Health Department, and they felt this was a good 20 site. 21 Now, that's not going through the formal 22 process, because the formal process didn't exist. But 23 a colorable effort to meet the process was, in fact, 24 undertaken, and the approval, be it informal, was in 25 fact given. BILLINGS REPORTING SERVICE 9.1961 62 1 Now, the one last remaining possibility, I 2 suppose, under this first violation, and that is, that 3 we have now, in fact, submitted that. There may be 4 those who say, Well, yeah, you submitted them two or 5 three days before the hearing. Big deal. 6 These documents take a long time to 7 prepare. They take lots of engineering work to 8 prepare, and according to the testimony, almost 9 three-quarters of a million dollars in expense. 10 These documents did not appear in the last 11 two weeks, the last month, the last six weeks, or the 12 last two months. These documents have been in the 13 course of being prepared for months. We've only known 14 the problem for a little over six months. 15 So I don't think it can be argued that 16 Waste Management or Waste Services has been dilatory in 17 meeting its obligations and coming forward with a 18 comprehensive plan, which I submit to this date it is 19 not required to do. 20 Now, with respect to alleged Violation 2 , 21 alleged Violation 2 alleges that the landfill is 22 discharging into the surface water. Waters are divided 23 into at least two categories, surface water and 24 groundwater. 25 The surface water allocation relates to the BILLINGS REPORTING SERVICE 931061 63 1 underdrain, which I think Chairman Harbert asked if 2 that had, in fact, been installed. It was, in fact, 3 installed in the 1980s, and it comes out adjacent to 4 Spomer Lake 2 . 5 There are now four Spomer Lakes. We number 6 them from the bottom, north -- one, two, three, four. 7 The underdrain comes out adjacent to or into Spomer 8 Lake 2 . It was not until mid-1992 that there was any 9 awareness that a discharge permit was required. Tests 10 had been done pursuant to a contract with the County, 11 and all the reports have been favorable up to that 12 point. 13 When Waste Management of Colorado became 14 involved in the ownership of the operator, it 15 voluntarily undertook a much more aggressive, much 16 broader evaluation of this site, and using its own 17 laboratories and using laboratories of its consultants, 18 began to test for a wide range of compounds, including 19 volatile organic compounds. They found these to exist, 20 and that was not confirmed until confirmatory tests 21 were done in the fall of 1992 . 22 The application for a discharge permit was 23 made in the fall of 1992, October -- November of 24 1992 -- I 'm sorry. That's pretty speedy work for a 25 company that has just taken over a site and just made BILLINGS REPORTING SERVICE 3i1961 64 1 the determination for the first time that a discharge 2 permit is required. 3 Application is pending on that; Waste 4 Services is diligently pursuing it. Things take time 5 in the Colorado Department of Health. We believed we 6 would have it by now. We have no reason to believe it 7 won't ultimately be granted. 8 What ' s coming out of that underdrain are 9 the VOCs that have been discussed, have been described 10 to you. Those are ethenes and ethanes. Ethenes and 11 ethanes are very light organic compounds. They are 12 very volatile. The result is they come out of the 13 water almost as soon as the water is exposed to the 14 air. 15 The best evidence of that has been pointed 16 out to you, that there is no trace of them in Spomer 17 Lake No. 2 . There is no trace of them in Spomer Lake 18 No. 1. There is no trace of them in the discharge 19 point at Spomer Lake No. 1, nor is there any trace of 20 them downstream. 21 That doesn't make the discharge of them 22 legal, but I would submit to you that the discharge is 23 a minor one. It is being corrected. The discharge 24 permit will be granted, or in all likelihood will be 25 granted. BILLINGS REPORTING SERVICE (31061 65 1 The third violation -- and I might add, 2 both the Weld County Health Department and the Colorado 3 State Health Department have indicated that they would 4 not take action with respect to this as long as an 5 application is pending. And I would suggest that you 6 take their advice and take the same course of action. 7 With respect to the alleged Violation 3 , 8 alleged Violation 3 deals with the groundwater, to be 9 distinguished from the surface water, along the south 10 edge of the landfill . Most particularly, at the very 11 southeast corner of the landfill, volatile organic 12 compounds have been detected in the shallow 13 groundwater. 14 This is believed to be the product of 15 trash, waste coming into contact with subsurface water 16 in the northwest quadrant of the landfill, where it's 17 been subjected to groundwater encroachment, and perhaps 18 has been for some time. This was determined by wells 19 drilled subsequent to the acquisition of the site, 20 subsequent to the acquisition of Waste Services by 21 Waste Management. 22 There are three holes up in that northwest 23 corner. One of the holes is wet in the bottom. Two of 24 them within a few hundred feet of those holes are dry, 25 which indicates that the area of encroachment is BILLINGS REPORTING SERVICE 931061 66 1 relatively minor. That area of encroachment is minor, 2 also, measured by another scale. There is very little 3 methane production in this landfill. 4 MS. HARBERT: Do you have an overhead of 5 that? 6 MR. HERST: I can point. These are the 7 holes that he' s referring to up here (indicating) . 8 MS. HARBERT: Which one is wet and which 9 one is dry? 10 MR. HERST: This is the only one that' s 11 shown direct continual groundwater (indicating) . 12 MR. WEBSTER: What is the depth of that? 13 MR. HERST: The depth of the wells is 14 approximately 30 to 35 feet. They were drilled through 15 the base of the solid waste. I could be off a little 16 bit on the actual depth. The important thing is they 17 were drilled through the baseline, though. 18 MS. HARBERT: Thank you. 19 MR. WEBSTER: Thank you. 20 MR. ROY: The three I am referring to, the 21 upper one is wet; the two immediately to the south and 22 flanking it are dry. 23 The question becomes, is this a violation 24 of -- is the presentation of these volatile organic 25 compounds in the groundwater a violation of 2 . 1.2 or BILLINGS REPORTING SERVICE 931061 67 1 2 . 1.4? And I 'm not going to read all of those to you, 2 but I 've set them out verbatim in a note. 3 Suffice it to say that 2 . 1.4 is really the 4 governing regulation. It uses two terms: It uses 5 "minimize" and it uses "prevent. " It uses minimize 6 with respect to nuisance conditions, which can include 7 water within the definition. I would add that nuisance 8 condition is a defined term in the regulation. 9 The use of the word minimize assumes that 10 there' s going to be some impact from the operation of 11 any human activity, including a landfill. The 12 obligation of the operator is to minimize these 13 nuisance conditions, there being a recognition by the 14 State Department of Health by the use of the word 15 minimize, to be distinguished from the word prevent, 16 which is also used in the same section of the same 17 regulation, which gives you some indication that the 18 State Health Department knows the difference between 19 the two and intended a different meaning when it used 20 the different terms. 21 Minimize is what we are doing, and minimize 22 is what is planned. The groundwater encroachment is 23 caused, according to the hydrologists and geologists 24 who studied the matter, by the upgradient irrigation. 25 I read in the paper just last night BILLINGS REPORTING SERVICE 931061 68 1 statements from Mr. Telep to the effect that he had 2 installed underdrains on his land, and he had also 3 installed ponds, both of which would affect our 4 groundwater. We have already taken remedial action 5 across the north side of the public facility and 6 historically along the north edge of the facility. 7 The plan calls for even more. The 8 hydrologists and hydroengineers say that remedial 9 action in all likelihood will cure the problem, will 10 cure the encroachment of the groundwater, which is the 11 cause that is believed the problem. 12 The second aspect of dealing with the 13 problem is the air sparging on the south edge where we 14 have, in fact, had some movement of the volatile 15 organic compounds in the groundwater. 16 The second word used in 2 . 1. 4 is 17 "prevent. " Prevent is used in the language dealing 18 with cover and drainage on-site. It says we will cover 19 and we will compact and we will use suitable material 20 to prevent ponding of water, to prevent -- with 21 adequate design for drainage, and prevent water 22 pollution. That's what the regs say. 23 There are 20 years of reports on this site 24 dealing with a cover. They've been alluded to already. 25 The cover has always been approved. BILLINGS REPORTING SERVICE 931061 69 1 Now, you say, Well, that isn't quite 2 enough, Mr. Roy. Just the fact it has been approved 3 isn't quite enough. 4 I would point out to you that this 5 landfill, with the exception of one low area, is dry. 6 Now, if there were encroachment through the cover, it 7 would not be dry. It would be wet at the top. It 8 would be wet all the way through. 9 That is not what the test borings show. 10 The test borings show water only in one isolated area, 11 and that is at the bottom of the landfill . 12 So the water that you' re seeing in there 13 that's causing the possible generation of volatile 14 organic compounds is not water that' s come through the 15 roof. It' s water that's come into the basement. 16 We have prevented the ponding. We have 17 used adequate cover. And we have, by that, prevented 18 the encroachment of water in a landfill, and that' s 19 what the regulation requires. 20 Everybody has concluded that this is a 21 nuisance condition. "Nuisance condition" is a defined 22 term in the regulation. The mere existence of volatile 23 organic compounds in the groundwater is not a nuisance 24 under the department's regulations, in and of itself. 25 More must be shown. BILLINGS REPORTING SERVICE 931061 70 1 Nuisance conditions are defined as those 2 which may result from water pollution. There must be 3 something more than the mere existence of contaminants 4 to have a nuisance condition under the wording of the 5 State Department of Health's regulation. 6 The position of the operator is that it has 7 minimized groundwater contamination. It has done that 8 by aggressively testing for it, but promptly and 9 honestly reporting it to the regulatory agencies 10 responsible and interested, by proposing and taking 11 remedial action, and by being prepared to take 12 additional remedial action. 13 The alleged Violation 4 is basically a 14 repeat of alleged Violation 3 for all intents and 15 purposes. The difference is, in Violation 4 it 16 focuses on the fact that some of the trash is in the 17 groundwater, or has encroached upon by groundwater. 18 It speculates that that might be a violation of a 19 future proposed regulation of the State Water Quality 20 Commission. 21 That proposed regulation and the proposing 22 process has changed since the allegation was made, and 23 under the one being currently considered by the Water 24 Quality Control Commission, this would not, in fact, be 25 a violation. For the reasons I 've already discussed BILLINGS REPORTING SERVICE 931061 71 1 with respect to the construction of 2 . 1. 4 and 2 . 1. 2, we 2 submit no violation exists. 3 The two issues you need to address are, Has 4 there been a violation? The second issue you have to 5 address is, What are you going to do about it if there 6 has been? 7 This proceeding that you are now engaged 8 in, if taken to fruition, could result in a termination 9 of the zoning and require the closure of the facility. 10 This is a result which is contrary to the 11 recommendation that you have received from your 12 Department of Health, it's contrary to the 13 recommendation you have received from your Department 14 of Planning, contrary to the recommendations of 15 engineering and environmental specialists retained by 16 Waste Services, contrary to the recommendation of Waste 17 Services, contrary to the more comprehensive and modern 18 regulatory scheme envisioned by Subtitle D, which talks 19 not about termination and closure, but talks about 20 remedial and corrective action, and it's contrary, 21 though they may not believe it, to the long-term best 22 interests of the adjacent property owners. 23 Waste Services has before you a series of 24 items, which are corrective action plan, a future 25 operations plan, a closure plan and a post-closure BILLINGS REPORTING SERVICE 931061 72 1 plan. Those plans are designed to close this facility 2 in an orderly fashion, in accordance with current 3 engineering practice, in accordance with future 4 comprehensive -- a future comprehensive regulatory 5 environment, and if those plans are adopted, your 6 operator has agreed to be involved in the post-closure 7 period, an obligation he does not now have. 8 I would submit to you that you take the 9 advice of your own advisers and, one, find no probable 10 cause, but, two, if you cannot be so persuaded, 11 continue this matter until you've had an obligation to 12 look at what is going to happen in the future with 13 respect to this site. 14 If you look at the diagrams that are in 15 your materials and you look at the chart that' s behind 16 me, you will see that this facility is flat on top, 17 large areas of very little gradient, basically flat. 18 I think your engineer will tell you, I 19 think the people familiar with regulation of landfills 20 will tell you, you don't close a landfill in that 21 configuration. You close a landfill with a dome on it. 22 That permits drainage. That seals the top of that 23 landfill in a way that it will remain safe, not only 24 immediately, but for the entire post-closure period, 25 for some 30 years. BILLINGS REPORTING SERVICE 931961 73 1 I would submit to you that there is no 2 violation, and that if there is a violation, that needs 3 to be addressed by means other than a show cause 4 hearing and a possible termination of the site. 5 Thank you. 6 MR. WEBSTER: I have a question for 7 Mr. Roy. 8 MS. HARBERT: Is there anyone that has 9 questions of Mr. Roy? 10 MR. WEBSTER: Mr. Roy -- 11 MS. KIRKMEYER: Tried to get away, didn't 12 you? 13 MR. WEBSTER: Violation No. 2 , I would like 14 to read one thing, and I don't quite understand. It 15 says VOCs were detected at the underdrain discharge 16 point which discharges into or near Spomer Lake No. 2 . 17 The next sentence says no VOCs have been 18 detected in Spomer Lake No. 2 or at any downstream 19 location. 20 Which is it? 21 MR. ROY: Both. There is -- tests have 22 been made at this location, Spomer Lake No. 2 , Spomer 23 Lake No. 2 water. The tests have been made at the 24 discharge point at Spomer Lake 1, and tests were made 25 downstream. No volatile organic compounds have been BILLINGS REPORTING SERVICE 9:1961 74 1 found in those waters. 2 They do, in fact -- they have, in 3 fact, been found at the very outlet of that drain. 4 Someone facetiously said to me -- and I 5 take it to be somewhat true -- if you took a glass of 6 water with these volatile organic compounds in it, they 7 would evaporate from the water before you drink it. 8 They are that light and that volatile. They do not 9 stay in the water. 10 Department of Health, I understand, says 11 that anything that' s in this underdrain will be treated 12 ultravioletly while in these two lakes, if it's in 13 those two lakes. So it's naturally treated in those 14 two lakes, to the extent that it gets there. 15 The milky -- there was some laughter at the 16 time we talked about the milky water, the milky water 17 in the streams -- 18 (Brief interruption. ) 19 MR. ROY: -- that is caused by the 20 background compounds in the water observed in almost 21 equal quantity above and below the landfill . 22 MR. WEBSTER: Thank you. 23 MS. HARBERT: Are there any other questions 24 for Mr. Roy? 25 Thank you. BILLINGS REPORTING SERVICE 931061 75 1 MR. ROY: Thank you. 2 MS. HARBERT: I would like to say that we 3 will be adjourning for lunch at 11: 30, due to the fact 4 that the commissioners are all speaking at an 5 engagement this afternoon, and we will reconvene at 6 1: 15. So you can judge your presentation by those 7 hours. 8 MR. HEDBERG: Thank you very much. My 9 closing comments will be very brief. 10 Basically, we 've heard a lot. We've heard 11 a lot about the history of this facility, we've heard 12 it's being properly permitted in the beginning, that it 13 was run through the years with a focus on compliance. 14 It was operated -- it still is operated with an 15 extremely high focus on compliance. 16 We have also heard that it was through our 17 focus on that compliance and investigating a site for 18 anything that might exist, that we ourselves did find 19 the issues that we are talking about today. 20 We found those ourselves, we further 21 investigated those ourselves, we proposed remediation 22 of those ourselves, and we plan to follow through with 23 those ourselves. We feel this has all been able to be 24 accomplished. 25 We feel we have a good relationship with BILLINGS REPORTING SERVICE 3_1961 76 1 the Departments of Health, both State and County, and 2 we anticipate to continue that good working 3 relationship with both agencies, as well as anything 4 that would come under the special use permit of the 5 planning and zoning area. 6 One thing that we probably need to close up 7 with here is just one last focus, and that is that the 8 facility is permitted. It's functioning as a service 9 to that central service area. We are addressing issues 10 that we raised and, again, are of concern to the 11 County. 12 And the other thing I guess we need to 13 focus on here is, What ' s the best course of action for 14 all people involved? That would be the company, of 15 course, it would be the citizens that live around the 16 facility, it would be the citizens of the service area 17 of Central Weld County, and it would also be the 18 environment that we all love, live and grow up in. 19 I guess I would submit to you that the 20 proposal that we have taken, that is, the amended 21 application process that we submitted, is the best 22 route to take. In that application process, we have 23 addressed any of the concerns, whether they are legal, 24 or just -- just that they make sense. We've addressed 25 each of those concerns in the application process. BILLINGS REPORTING SERVICE 931961 77 1 I guess we would concur again with staff 2 that the best route to take at this point in time would 3 be to let that process travel its natural route, and 4 that would be that it would go out for basic review and 5 comment. 6 It would be submitted to various government 7 and quasi-governmental agencies for their reviews, 8 comments, that we would provide, I guess, a positive 9 process to be able to continue to upgrade the facility, 10 as necessary, to meet the ever-changing needs, both the 11 environmental needs and the surface area needs. 12 And I guess I would like to close in 13 bringing to your attention two letters that we've 14 received that illustrate, I guess, what we are out 15 there in business for. One is dated March 31, signed 16 by Karen Sekich, the chairman of the Weld Economic 17 Development Action Partnership, EDAP. 18 And if I can just briefly read it into the 19 record -- they're both very brief -- it says: 20 "Dear Ms. Harbert: The availability of a 21 regional state-of-the-art solid waste management 22 facility is important to the retention and attraction 23 of industry to Weld County. At a recent meeting of the 24 Executive Committee of the Greeley/Weld Economic 25 Development Action Partnership (EDAP) , we reaffirmed BILLINGS REPORTING SERVICE 931061 78 1 the above statement and endorsed the process of 2 re-permitting the Central Weld Sanitary Landfill. 3 "We encourage the Weld County Commissioners 4 to favorably consider the re-permitting of the subject 5 facility. " 6 The other letter of a similar nature. 7 This is a letter dated April 2 , addressed to the 8 commissioners, signed by Mr. Paul Grattet, the City 9 Manager of the City of Greeley, and it says: 10 "Dear Commissioners: It is my 11 understanding that the Board will be discussing the 12 Central Weld Sanitary Landfill on Monday, April 5, 13 1993 . 14 "The continued availability of this 15 conveniently located landfill for the disposal of solid 16 waste generated within the City of Greeley is vital to 17 our residents and businesses. 18 "I respectfully request you proceed with 19 the process for considering an amended permit as 20 quickly as possible. 21 "Concerns of area residents should be heard 22 and considered, however sudden closure or prolonged 23 delay in issuing an amended permit would be harmful to 24 the economic future of Greeley. 25 "If there is any assistance I can provide BILLINGS REPORTING SERVICE _ 9:_11061 79 1 in this matter, please let me know. " 2 This illustrates what we are in business 3 for. We are in business to take care of the solid 4 waste that's generated in the service area. We try to 5 take care of that in an environmentally sound manner, 6 and if things do come up, we take care of those. We 7 try to take care of them in an economically sound 8 manner, to make it a cost-effective facility for the 9 benefits of the economic base of the region here. 10 And I guess we would propose that the 11 highest and best track to take at this point in time 12 would be to either find that there is not probable 13 cause or, at a minimum, suspend the probable cause 14 hearing in preference of the higher and better route to 15 take through the application process. 16 Thank you very much. 17 MS. HARBERT: Thank you. 18 MR. HEDBERG: Any questions? 19 MS. HARBERT: Are there any questions? 20 MR. HALL: I have one question. As far 21 as Mr. Roy's presentation on the alleged Violation 22 No. 4 -- he may be the one to ask, but may not be -- I 23 guess I 'm curious as to the second paragraph, or third 24 paragraph on the second page, where it says the 25 remedial action has been proposed and implementation of BILLINGS REPORTING SERVICE 931061 80 1 some has already occurred. 2 Can you just briefly explain what that 3 means? 4 MR. HEDBERG: Yes. This is on the 5 identified infiltration of groundwater into the basic 6 refuse? Is that it? 7 MR. HALL: It's essentially, the trash is 8 in contact with groundwater. 9 MR. HEDBERG: That goes back, just as a 10 point of clarification -- and if I need further 11 consultation, I ' ll lean on my engineering staff for 12 sure. But, basically, when we were talking about the 13 54-inch corrugated metal culvert, and they were talking 14 about how that would be, I guess, blended into the 15 existing surface diversion ditch that' s on the -- in 16 the northwest side of the property, presently that's a 17 service water diversion ditch only, it ' s presently not 18 lined, and what's believed is that, as that carries the 19 surface water around the site to the west, that there 20 may be some infiltration just from seepage into that 21 very upper northern portion of the site. 22 What' s being proposed in the amendment 23 process is to basically enclose that in a metal pipe so 24 it will shut off the seepage tendency and, therefore, 25 if you shut off the source, then that area will join BILLINGS REPORTING SERVICE 931061 81 1 the other areas in being a dry facility. 2 MS. HARBERT: Otherwise, that' s why the one 3 hole up there is wet. 4 MR. HEDBERG: Yes, ma'am. That's what 5 we believe, is that that one, what they call 6 piezometer -- it' s a boring that tests the water 7 levels in conjunction with the base of trash. And it's 8 believed that in that area -- Leonard can probably 9 explain this better than I can -- it' s believed that 10 that's what' s causing the moisture in that area. 11 MR. BUTLER: It' s -- 12 MS. HARBERT: State your name, please. 13 MR. BUTLER: I 'm sorry. Leonard Butler 14 with Waste Services. 15 To respond succinctly to your question, in 16 the fall of ' 91, we proceeded to enhance the diversion 17 ditch on along the north side by construction of a 18 French drain. That's some of the activity, as well as 19 the planning work that was referenced by Mr. Hedberg. 20 MS. HARBERT: Does that answer your 21 question? 22 MR. WEBSTER: Where is the outlet of that 23 drain then to occur? Where are you going to take that 24 water, once you collect it? 25 MR. BUTLER: Mr. Herst is pointing out on BILLINGS REPORTING SERVICE 931061 82 1 the poster that this runoff will be diverted around the 2 west and will be discharged along the western boundary 3 through the Spomer Lakes. 4 MR. WEBSTER: And all the water is not a 5 problem at that collection point? 6 UNIDENTIFIED PERSON: It' s upgrading the 7 quality. 8 MR. BUTLER: It's of acceptable quality. 9 It' s above the landfill . 10 MR. BAXTER: In other words, it's foreign 11 water? 12 MR. BUTLER: You can use that term, foreign 13 or on-site or off-site. 14 MS. HARBERT: That would be water that came 15 to that field from the north? It could be agricultural 16 runoff or something like, similar to that? 17 MR. BUTLER: Yes, ma'am. 18 MS. HARBERT: So it wouldn't have any 19 connection with the landfill at all , actually. 20 MR. BUTLER: That' s correct. 21 MS. HARBERT: Okay. Are there any other 22 questions for Waste Management? 23 MS. KIRKMEYER: I have a question for Art 24 Roy. 25 MR. ROY: Yes, ma'am. I was going to get BILLINGS REPORTING SERVICE 931061 83 1 my notes, but I put them away. 2 MS. KIRKMEYER: You said the act, the 1967 3 Act, that you quoted earlier, is there anything in that 4 act that required the applicant to submit any reports, 5 engineering or operational data to the Department of 6 Health, Colorado Department of Health, for review, and 7 the Department of Health is supposed to write any kind 8 of recommendation of approval? 9 MR. ROY: Neither was true under the 1967 10 Act. It' s interesting that the 1967 Act -- and it may 11 be true also of the 1971 Act -- is not under the 12 article dealing with Health. It's under the article 13 dealing with County Powers. Okay? And it allowed the 14 County to certificate these things and left it with the 15 County to make that determination. 16 The 1971 Act, which became effective April 17 of that year, was the first act that talked about the 18 State Department of Health being involved in the 19 permitting process. And it did that two ways, 20 basically. 21 One, it said in the Application section 22 that's now 30-20-102 or 103 , that engineering -- or not 23 -- but hydrological or geological information would be 24 submitted to the Department of Health in accordance 25 with its regulations. BILLINGS REPORTING SERVICE 931061 84 1 Later, in the 1971 amendment, it also says 2 that the County will not permit, without the approval 3 the Department of Health -- or I shouldn't say this -- 4 I think the exact language is something to the effect 5 that you will not permit over the disapproval of the 6 Department of Health. If the Department of Health 7 disapproves it, you cannot permit it. 8 The -- that regulation was not in 9 existence, and apparently was only in a preliminary 10 draft form at the time of the hearing in September of 11 1971. 12 MR. WEBSTER: In either one of those acts 13 of ' 67 or '71, were there any recognizing written 14 factors as to the -- what goes into the landfills, 15 hazardous waste or anything like that, recognized -- in 16 the '71, in particular? 17 MR. ROY: I would have to look at the 18 regulations that were in existence in 196- -- under the 19 1967 act, to answer that question. 20 My belief is that, without looking at them, 21 and subject to correction from looking at them, is that 22 the distinction that we now have between hazardous 23 waste, nonhazardous waste and household waste, those 24 distinctions are relatively new, as is the total 25 regulatory environment in which this landfill is now BILLINGS REPORTING SERVICE 931061 85 1 being required to operate. 2 Most of what we're talking about, in terms 3 of all of these plans and so forth, are creations of 4 legislatures and regulatory bodies after this landfill 5 started operation and, for the most part, after the 6 early waste was placed in the landfill, including the 7 waste up in the northwest corner. 8 The current operator is addressing those 9 issues, even though, quite frankly, it is not the 10 present operator' s fault. 11 MR. WEBSTER: Because you are not under the 12 subtitle. 13 MR. ROY: Not under Subtitle D. 14 MR. WEBSTER: I just wondered if they 15 picked up anything in '71. 16 MR. ROY: I don't believe -- I ' ll check 17 over the noon hour and ascertain that. The ' 67 18 regulations dealt entirely with operation, and were 19 very brief, called them dumps. I mean, all this -- you 20 know, it was crude by today's standards. 21 MS. HARBERT: Are there any additional 22 questions for Waste Management? 23 MR. ROY: Thank you. 24 MS. HARBERT: Thank you. Since it's 25 25 after 11: 00 and I said we would adjourn at, or we would BILLINGS REPORTING SERVICE 931961 86 1 recess -- excuse me -- at 11: 30, I think this is an 2 appropriate time to break. 3 MR. BAXTER: I believe John had something 4 he wanted to say. 5 MR. PICKLE: I just want to say, we do have 6 representatives from the State Department of Health, if 7 you wish to talk with them. I 'm not sure they' ll be 8 able to stay all afternoon. So I just mention that. 9 MS. HARBERT: All right. Are there any 10 five-minute questions for the Department of Health? 11 (No response. ) 12 MS. HARBERT: All right. We will recess, 13 and we will reconvene at 1: 15. 14 (The hearing recessed at 11: 25 a.m. , to be 15 reconvened at 1: 15 p.m. ) 16 17 18 19 20 21 22 23 24 25 BILLINGS REPORTING SERVICE 931061 87 1 AFTERNOON SESSION 1: 18 p.m. 2 MS. HARBERT: We will proceed with the 3 probable cause hearing for Waste Management for the 4 Central Landfill. Let the record show it is 5 approximately 18 after 1: 00 and all five commissioners 6 are present. 7 THE CLERK: Do you want to remind them of 8 the cards? 9 MS. HARBERT: If anyone has come in since 10 this morning, we do have cards on the Clerk to the 11 Board's desk up here, if you will please fill those 12 cards out if you wish to speak for or against the 13 probable cause. 14 There was a question asked before we 15 dismissed this morning of Mr. Roy, and he has asked if 16 he can answer that question. 17 MR. ROY: Commissioner Webster asked about 18 the rules and regulations of the Department of Health 19 in 1967 . I have a copy of those rules. They are 6 20 pages in length -- 5-1/2 , actually -- double-spaced, 21 wide margins. 22 They do distinguish -- to be compared, I 23 might add with the current regulations which are this 24 thick, 58 pages, single-spaced, narrow margins. The 25 1967 regulations did refer to hazardous waste. I BILLINGS REPORTING SERVICE 931961 88 1 indicated I didn't think they did. I wanted to correct 2 that. 3 It defined hazardous wastes. Hazardous 4 materials and toxic substances are liquids and/or 5 solids which can be dangerous to human, animal and 6 plant life. I have not read the regulations word for 7 word, but the only reference I could see in them to 8 hazardous wastes and toxic substances appears in the 9 last subsection. 10 And it says, Hazardous and toxic substances 11 received at a solid waste disposal site shall be 12 denatured to a form which is harmless to human life to 13 final disposal and . . . hazardous and toxic 14 substances, stocks of merchandise, including foods, 15 drugs and vegetables, is prohibited. 16 That's all it says, to my knowledge, about 17 hazardous waste. But the regulations are demonstrably 18 shorter and simpler than they were. 19 MS. HARBERT: Thank you. 20 MR. WEBSTER: Okay. 21 MS. HARBERT: I assume that Waste 22 Management has completed their presentation; is that 23 correct? 24 MR. HEDBERG: Yes, ma'am, we have. 25 MS. HARBERT: Thank you. BILLINGS REPORTING SERVICE 931061 89 1 We will now call for the opposition' s 2 testimony. Mr. Hobbs, I believe you are representing 3 that group; is that correct? 4 MR. HOBBS: That' s correct. 5 MS. HARBERT: All right. Would you come to 6 the microphone, please. 7 MR. HOBBS: Thank you. My name is Greg 8 Hobbs. I represent a group of Weld County citizens 9 today, some of whom you will hear from, many of whom 10 will not testify because we felt that the testimony 11 might be duplicative. 12 However, Mr. Hayes, the primary spokesman 13 for the group, will reflect the views of the citizens 14 who are not speaking today. 15 I would like to hand my long-time 16 colleague, Mr. Megyesy, who represents Waste Management 17 Inc. , a copy of our materials. And, Mr. Roy, I 'm 18 sorry, I don't have an extra copy. Maybe you can share 19 it. 20 MR. MEGYESY: We will . 21 MR. HOBBS: I would like the record to 22 reflect that we will distribute right now to each of 23 the commissioners our exhibits and summary of our 24 presentation. So if I may have a moment to have those 25 distributed before I refer to them. BILLINGS REPORTING SERVICE 931961 90 1 For the record, I would also like to state 2 that the original exhibits and summary of the 3 Ashton-Daniels Neighborhood Association has been handed 4 to Mr. Morrison to be included in the record of today' s 5 proceedings. 6 MR. MORRISON: I might also note that those 7 have been marked by Mr. Hobbs as AD, beginning with 8 No. 1, and I believe he has also included a summary of 9 all those, so there won't be a separate record of 10 those. 11 MR. HOBBS: That is correct. We have 47 12 exhibits before you that we would like to be included 13 in this proceeding. You will also find a summary of 14 our presentation, which I hope you will find useful, 15 of the pertinent facts and some of the law. 16 I do want to emphasize that this procedure 17 is a little bit unfamiliar to me, and any of my 18 questions this morning, please, I was just trying to 19 figure out the nature of the proceeding. I believe I 20 understand now that what this is, is an informational 21 hearing. It is not a hearing on the merits of whether 22 or not violations have occurred. 23 The regs that the County was kind enough to 24 provide me last week regarding probable cause hearings 25 state pretty clearly that your duty today is to see if BILLINGS REPORTING SERVICE 931061 91 1 there is a reasonable ground for belief in the 2 existence of facts warranting the proceedings 3 complained of. 4 It is not to find facts, it' s not to make 5 conclusions of law, it's not to take -- and the 6 chairperson pointed this out to me very directly and I 7 believe I understand it now -- this is not the 8 opportunity for cross-examination. That would be 9 reserved, as I understand it, for a full-scale hearing 10 in which evidence would be taken, the findings of fact 11 might be made, conclusions of law might be made, and 12 interested persons, including the public, would have 13 the opportunity to fully participate. 14 So, therefore, we do come before you this 15 afternoon in the spirit of your own rules, and it's not 16 to prove facts. It' s to prove the reasonable ground 17 for belief that facts may exist that you should explore 18 fully in the context of a proceeding. 19 So, therefore, we are asking you today, as 20 a result of the information we will present, to go to a 21 full-scale hearing as soon as possible on the 22 revocation of the land use approval and the certificate 23 of designation for this landfill. 24 We believe that it is necessary for the 25 commissioners to do this in the public interest, and BILLINGS REPORTING SERVICE 9:1061 92 1 also because, as we will set forth today, there has 2 been a constant improper disposal of material at this 3 landfill since 1971. It' s gone on much too long and, 4 basically, we need to get on to the full-scale 5 hearing. 6 Now, of course, we did not know until this 7 morning that the staff might recommend a continuance. 8 We, of course, understand you sit as members, elected 9 officials of the County, and can take or reject staff 10 recommendations, also that the staff may itself, after 11 it hears our evidence, want to rescind their suggestion 12 for a continuance. 13 We believe that for the first time this 14 afternoon, it will be clear from the record, both to 15 the County Land Use Department, to yourselves, and to 16 the environmental folks, why we believe that this 17 landfill has operated illegally and must be closed. 18 Now, let me address what you've heard this 19 morning. Waste Services and Waste Management, Inc. -- 20 and I have no doubt about it, that Waste Management, 21 Inc. knows what the state-of-the-art is and technology 22 for remediation and for landfills. 23 It is clear to us sitting in the audience, 24 however, that Waste Management and Waste Services are 25 trying to blend two issues here that cannot be BILLINGS REPORTING SERVICE 931061 93 1 blended. They would like to expand the operations of 2 the landfill. They would like to file an operations 3 plan allowing for expansion. They would like, in 4 effect, a permit that this facility has never had to 5 operate at this location in Weld County. 6 We have no objection to Waste Services 7 seeking a permit to operate this facility if and when a 8 proper plan for design, operation, construction and 9 remediation is presented to Weld County and the Health 10 Department for approval . But, please, under the 11 statute, it is clear that this hearing has to do with 12 whether or not the land use conditions that attach to 13 approval of this landfill in the first place, have or 14 have not been violated, is a reasonable belief to 15 proceed to a hearing on that basis, not that you have 16 to determine it today, but you have to determine 17 whether there is reasonable belief. 18 Now, let me read from the statute what this 19 proceeding and what the full-scale hearing would be 20 about. I read from the State Solid Waste Disposal Act, 21 30-20-112 , states as follows: 22 The governing body, which is you, the Weld 23 County Commissioners, having jurisdiction, after 24 reasonable notice of public hearing, shall temporarily 25 suspend or revoke a certificate of designation that has BILLINGS REPORTING SERVICE 8:31061. 94 1 been granted by it for failure of a site and facility 2 to comply with all applicable laws, resolutions -- I 3 want to underscore resolutions. We' ll come back to 4 that -- and ordinances, or to comply with the provision 5 of this Part 1 or any rule or regulation adopted 6 pursuant thereto. 7 It says shall. It doesn't say may. It 8 says you shall suspend or revoke the certificate for 9 the violation of a resolution. Now, the resolution 10 that I want to refer you to now -- and you will hear 11 our citizens speak to the matter -- is the resolution 12 adopted by the County when it issued the certificate of 13 designation. 14 That resolution is the resolution that we 15 ask you to enforce. The resolution is in your packet 16 at AD-8. Now, because the first half of this packet 17 has the transcript of the 1971 hearing, it will take a 18 while perhaps for you to find that. But I do ask that, 19 while the hammering proceeds, that you look at AD-8 in 20 your packet. 21 It' s right after, if it will help, the 22 transcript that has 66 pages and is signed by Estelle 23 Kenley, a transcriber, which is AD-7 , and there is 24 AD-8. 25 Has everybody got that? BILLINGS REPORTING SERVICE 931061 95 1 MS. HARBERT: Is it the resolution? 2 MR. HOBBS: It is the Resolution of Weld 3 County Commissioners dated October 6, 1971. AD-8 at 4 the bottom of the page. 5 Okay? It's right after the big transcript. 6 The date is October 6, 1971. 7 Do the commissioners have that in front of 8 them? 9 MS. HARBERT: Yes. 10 MR. HOBBS: Now, this is what I would call 11 your land use approval, zoning resolution. Recall that 12 the nature of the proceeding under state law is that 13 the County Commissioners have to determine land use 14 questions. 15 And as you recall, Governor Lamm found this 16 out, didn't he, in the mid- ' 70s. The local government 17 has always been jealous to protect its land use zoning 18 or disapproval process. 19 So it's very important to understand that 20 our laws in this state have always placed with the 21 County Commissioners the responsibility to determine 22 whether the land use shall be authorized. 23 Now, this was a land use by special 24 review. It required a specific hearing and a 25 determination as to whether the land use should be BILLINGS REPORTING SERVICE 931061 96 1 allowed, and you were empowered to place conditions on 2 the land use. 3 In this case, the applicant asked for a 4 landfill in what was predominantly an agricultural 5 area. There are surrounding farms. In fact, Weld 6 County, the third largest producer of agricultural 7 products in the United States, has always been known 8 for its water and its land and its abundant crop. 9 This land use was surrounded by gorgeous 10 farmland with a view of the mountains, and the 11 applicant wanted to place a landfill in the midst of 12 the surrounding agricultural land. It had to be done 13 by a special review. 14 Now, what did the condition of the County 15 Commissioners following the hearing in '71 say? Number 16 one, that any sanitary landfill activity to be 17 installed -- underline, to be installed -- shall be 18 approved -- shall be approved by the State Department 19 of Health. 20 Now, what were they talking about? A 21 landfill installation to be installed prior to its 22 installation to deposit of any waste material under 23 that land to be approved by the State Department of 24 Health. October 1971, the land use resolution of the 25 Weld County Commissioners. BILLINGS REPORTING SERVICE 931061 97 1 Now, as I read you from the State statute, 2 it is clear that upon a certificate of revocation 3 hearing, your own resolution can be enforced. 4 Now, one of the essential inquiries into 5 this matter is the fact that we allege, and we believe 6 the documents will show incontestably at a full-scale 7 hearing that the applicant promised an engineering, 8 design and operation plan back in '71, induced the 9 County Commissioners to approve the land use, and never 10 followed through, and that for 22 years material has 11 been deposited in that landfill illegally, improperly, 12 contrary to your resolution, and to the detriment of 13 the public interest. 14 Now, let me summarize what preceded that 15 hearing to show you that this is so. Exhibit AD-1 of 16 your packet is -- and you've heard the name before -- 17 Mr. Orville Stoddard. Mr. Stoddard, on July 15 of ' 71 18 -- remember, the hearing was in September -- asked for 19 an engineering report to be supplied before the 20 hearing, to determine whether this site was suitable 21 for disposal. 22 Look at the second paragraph on Page 1. 23 The purpose of the meeting was to review, in general, 24 the suitability of the site and the submittal of an 25 engineering report required by the State Solid Waste BILLINGS REPORTING SERVICE 901961 98 1 Disposal Act as amended in 1971. Look at the 2 enumerated items. Look at the next paragraph. 3 The requirements for an engineering report 4 describing design and operation of this site, public 5 hearings, recommended approval by the Weld County 6 Commissioners prior to operation was discussed. 7 okay. Well, now, what happened? What 8 happened to the engineering report and the design and 9 operations plan? Please turn to AD-3 in your exhibits 10 for a moment. AD-3 . This is William Garr, director, 11 Division of Engineering and Sanitation. 12 Now, look at the second sentence. 13 Mr. Earl Moffat -- he's the one who applied for the 14 landfill -- made a valid point in his letter concerning 15 the preparation of the required engineering report 16 prior to assurance the site would be designated by the 17 County Commissioners. The information presented and a 18 site visit by members of the department, Mr. Moffat 19 indicated this to be a suitable site. It is 20 recommended the site location be approved and the 21 designation be made contingent upon the submittal of an 22 engineering report concerning the design and operation 23 of the site, as described in Regulations 3 and 4 of the 24 attached proposed regulation. Some of this was 25 included in the information submitted. BILLINGS REPORTING SERVICE 931061 99 1 All right. What do we have here? An 2 applicant who had an option on this property. That's 3 clear from the transcript. The option had to close 4 soon. He was begging the County Commissioners not to 5 make him file, and get an engineering firm and file a 6 plan design and operation, until he was assured that he 7 got a land use approval. 8 What happened? He induced the 9 commissioners to issue the land use approval contingent 10 upon a design and operation plan described in 11 Regulations 3 and 4 . 12 Now, what were these regulations? The 13 regulations were then in draft, as Mr. Roy has very 14 correctly pointed out to you. They were then in draft 15 and they were finalized in February. Please look -- of 16 '72 . 17 Please look at AD-4 . These are the 18 regulations that Mr. Garr was referring to and that the 19 application was warranting would be complied with 20 before any facility would be installed for operation of 21 a landfill at this site. Section 3 ; what is Section 3 , 22 Page 4? 23 Of these standards, we heard a lot of talk 24 about voluntary this morning. This applicant, to get 25 this land use, volunteered, regardless of State law, BILLINGS REPORTING SERVICE 931061 100 1 regardless of when these regulations were going to be 2 put into effect, to submit a design and operations plan 3 and an engineering report that incorporated Sections 3 4 and 4 of the then-proposed regulations. 5 Why? The act had just passed. The act was 6 passed in the ' 71 General Assembly, became effective on 7 July 1. What is an agency such as yours, with a Health 8 Department, have to do when a new act is put into 9 place? They propose regulations. That doesn't mean 10 that the regulations should not be binding on 11 facilities. 12 A choice of the Weld County Commissioners 13 could have been to wait before it gave the certificate 14 of designation to Mr. Moffat until the regs had become 15 final. 16 Why didn't they wait? Because Mr. Moffat 17 said, Give me the approval and I ' ll agree that my 18 engineering report and design and operations plan, 19 before I deposit anything in that landfill, will comply 20 with those proposed rules when they become final. 21 Page 4 of the Rules, Minimum Standards. 22 Please turn on Page 5, to E of the Minimum Standards. 23 A site and facility operated as a sanitary landfill 24 shall provide means of finally disposing of solid 25 wastes on land in a manner to minimize nuisance BILLINGS REPORTING SERVICE 92,1961 101 1 conditions such as odors, windblown debris, insects, 2 rodents, and smoke; and shall provide compacted fill 3 material; adequate cover with suitable material and 4 surface drainage designed to prevent ponding of water 5 and wind erosion and -- underscore the next clause -- 6 prevent water and air pollution. Not minimize, not 7 hope to avoid, not hope to design. Prevent water and 8 air pollution. 9 Next page, Section 4 , Engineering Report 10 Design Criteria. The design of a solid waste disposal 11 facility hereinafter designated shall be such as to 12 protect surface and subsurface waters from 13 contamination. Shall be designed. 14 Now, what is -- what is this plan? This 15 design and operations plan? Recall that your 16 resolution, your predecessor' s resolution just didn't 17 take Mr. Moffat at his word that he would submit this. 18 They required it as a condition of the land use 19 approval. 20 Smart thing for a county commission to do, 21 you know, because people forget, time goes on. You do 22 things in hopes you might not be caught up with it 23 until maybe many years later. The County Commissioners 24 surrounded this in October of 1971 by saying that any 25 sanitary landfill facility to be installed shall be BILLINGS REPORTING SERVICE 931061 102 1 approved by the State Health Department. 2 Now, there was an allusion this morning 3 that the State Health Department rules were not 4 retroactive before February. That is correct for 5 landfills that did not have this kind of condition in 6 their land use approval. 7 The State Health Department has not seen 8 the evidence that you have in front of you today of 9 what was behind the County Commissioners acting to 10 approve the landfill site, not that they didn't get the 11 engineering report, design and operations plan. They 12 said and thought they were protecting the public 13 interest by being sure that nothing would be deposited 14 until it was forthcoming. 15 Now, I heard a lot this morning that 16 indicates to me that what the operator and owner would 17 like to do would be to shift to the public and to the 18 County and the State the burden of having never caught 19 up with this thing. 20 What is this thing? The fact that they, 21 the ones who made the representation that they would be 22 governed by a design and operations plan, never 23 obtained one. 24 Now, at the back of your exhibits -- and we 25 marked this today based on this morning's testimony -- BILLINGS REPORTING SERVICE -31061 103 1 please look at the back of your folder to Exhibit 2 AD-47. If I can take a moment and let you find that, 3 AD-47. It' s inserted right in the back of the 4 material. 5 MS. KIRKMEYER: Here it is, in this book. 6 MR. HOBBS: Sorry. AD-47? Lee, is there 7 an extra copy? 8 MR. MORRISON: I 've got it here. 9 (Discussions off the record about finding 10 document. ) 11 MR. HOBBS: AD-47 , you heard Mr. Keirnes 12 this morning, whose family owned this, and they sold 13 out for good and adequate reason to a much larger 14 company. But let's take a look at what the assumptions 15 of the transfer were. 16 Now, this is Colorado Department of 17 Health. Colorado Department of Health has reviewed 18 your request to change the name of the Certificate of 19 Designation for the Greeley-Milliken Sanitary Landfill 20 from Colorado Landfill, Inc. to Waste Services, Inc. 21 The Department approves your request, 22 provided -- now, here are the conditions -- one, you 23 receive approval from the Weld County Commissioners; 24 two, you commit to operating the landfill in accordance 25 with the approved operational plan, engineering design, BILLINGS REPORTING SERVICE 0:1161 104 1 and certificate of designation. 2 Ladies and gentlemen, there was no 3 engineering design operational plan. The Health 4 Department in 1986 believed there was one. Why was 5 there not one? The operator never submitted it. 6 Did Mr. Keirnes or his family call upon the 7 State Health Department or the Weld County 8 Commissioners and say, You know, you all assumed there 9 was an approved operational plan, engineering design 10 that we have to comply with. We need to tell you there 11 isn't one. 12 Was there one submitted? Was Waste 13 Services on notice by this AD-47 that there was a plan 14 in existence? Did they find out if there was a plan in 15 existence? I heard this morning that this plan was 16 Mr. Orville Stoddard' s statement on the transcript that 17 this site was okay. 18 You remember, however, what the deal was. 19 The deal was a full-scale engineering report and design 20 and operations plan to be submitted to the Health 21 Department for their approval. Mr. Stoddard wasn't 22 saying, Everything is hunky-dory. In fact, in the 23 transcript he says our first duty is, if there is going 24 to be water contamination, we are going to shut it 25 down. BILLINGS REPORTING SERVICE 931061 105 1 Okay? The whole statute passed in 1971 by 2 the General Assembly was for the purpose, before trash 3 is put in the ground and starts to migrate, is to have 4 a plan that will prevent it. 5 It is uncontestable that the only plan that 6 has ever been submitted by this facility is the belated 7 attempt by the Waste Services, Inc. and Waste 8 Management, Inc. to provide you with a plan for 9 expansion of this landfill that has never been properly 10 operated. 11 Now, we believe that the law requires you 12 to revoke for violation of Condition 1 of your land use 13 zoning resolution, the certificate to operate this 14 landfill. 15 Then, if you and the State Department of 16 Health wish to entertain the operation of a landfill on 17 this site, it should meet all applicable requirements, 18 including Subpart D, including all the regulations that 19 are applicable to design, operation, closure of this 20 facility. 21 Now, that is the overview of our 22 presentation. Our presentation is -- ladies and 23 gentlemen, it's a sad fact you' re called upon to do 24 public duty that should have been done years ago, but 25 it' s just like robbing a bank or turning in an IRS BILLINGS REPORTING SERVICE 931061 106 1 form, you know, finally, after 10 years of not paying 2 your taxes. The government and the public can't be 3 estopped because you got away with something you were 4 supposed to do. 5 The representations that this landfill 6 would never receive material until a design and 7 operations plan was approved by the Health Department 8 as made by the applicant, the public deserves to have 9 that condition enforced and the public deserves a full 10 public hearing on this issue. 11 This is only an informational session here 12 today. And with that overview, I would like to call on 13 my case. Thank you. 14 MS. HARBERT: Are there any questions for 15 Mr. Hobbs? 16 I just have one question. You read from, I 17 think it was 30-20-121; is that correct? Or 112? 18 MR. HOBBS: It may have been 112 . 19 MS. HARBERT: All right. Was that 20 regarding probable cause, or was that regarding show 21 cause? 22 MR. HOBBS: That is the show cause. What 23 you call the show cause, that' s a revocation hearing. 24 MS. HARBERT: Right. That' s -- 25 MR. HOBBS: And I want to be clear, all we BILLINGS REPORTING SERVICE 931061 107 1 are asking you to do today is, based on what you heard, 2 is that you believe, you have a reasonable belief that 3 there may be facts proven at this hearing that's 4 mentioned in the books that would lead you to revoke 5 it. 6 So -- but the standards in there, I wanted 7 to draw your attention to, and it included your land 8 use zoning resolution. It' s not just dependent upon 9 the State Health Department whether or not it wants to 10 enforce or what its standards are. 11 MS. HARBERT: Thank you. Any other 12 questions from Mr. Hobbs? 13 Mr. Hayes, is that correct? Please come to 14 the podium and state your name and address. 15 MR. HAYES: Ladies and gentlemen -- 16 MS. HARBERT: Will you state your name and 17 address. 18 MR. HAYES: Yes, I will. My name is 19 Michael Hayes. I live in Weld County. My family 20 resides on the farm immediately north of the landfill. 21 At this time I want to show you, present to you, ma 'am, 22 1152 names. 23 MS. HARBERT: Would you give them to Lee. 24 MR. HAYES: Sure. 1152 names of citizens 25 in Weld County who wanted this hearing. I 'd like to BILLINGS REPORTING SERVICE D A16s. 108 1 speak to you about two items, the 1971 County hearing 2 on the Greeley-Milliken dump and our family experiences 3 with living next to the dump. 4 In September of 1971 the County held a 5 public meeting regarding the granting of approval for 6 Earl Moffat to site a dump near Milliken at the present 7 location of the Central Weld Sanitary Landfill. 8 Chairman of the Board of the Weld County Commissioners 9 was Marsh Anderson, and Glenn Billings and Harry Ashley 10 were the other commissioners. 11 Earl Moffat was in the process of closing 12 a landfill in Evans and was searching for a location 13 for a new dump. He envisioned digging down 45 feet and 14 filling up the hole. 15 He stated, and I quote, We intend to make a 16 good piece of farm ground out of it, and we intend to 17 cover more -- cover more than is required by law, about 18 3 to 4 feet of cover when we are through with it, and 19 it will be on an even grade that will be practical to 20 irrigate. We expect a depth of 45 feet, and I think we 21 will have a 15-year goal. End quote. 22 Twenty people attended that meeting, other 23 than some of the officials from the State and County 24 Health Departments. It was pretty evident in the tapes 25 that the chairman of the Commissioners, Marsh Anderson, BILLINGS REPORTING SERVICE 9C1')61 109 1 wanted to hustle this landfill site through. At one 2 point in the tape, Marsh Anderson asked the other 3 commissioners for a vote, and Glenn Billings, county 4 commissioner, says he hasn't had a chance to walk the 5 property and wants to do so over the weekend. 6 Marsh Anderson says, muttering, His option 7 runs out on that property, I think, next Monday. 8 Commissioner Glenn Billings says, and I 9 quote, I haven't even had the time to think about it 10 and I haven't even seen it, either. End quote. 11 Marsh Anderson insisted on an immediate 12 vote, or -- and I quote -- he' ll lose his option. End 13 quote. 14 At this time, I note that Commissioner 15 Glenn Billings was the only commissioner to vote no, 16 and I reference his letter, our Exhibit AD-41, stating 17 his reasons for voting no. He states that the same 18 reasons he voted no in 1971 are the same reasons we are 19 here today. 20 I also reference Mr. Albion Carlson' s 21 statement, Exhibit AD-42 , which references the 22 hydrogeology and regulatory matters. It was clear from 23 the decision the commissioners made that they wanted to 24 get the landfill passed through, and it was my 25 understanding that they would wouldn't receive waste BILLINGS REPORTING SERVICE J:Y.r�'A � 1'1(�V1 110 1 until the State approved. 2 Please reference Exhibit AD-8 where the 3 commissioners approved the landfill based on, quote, on 4 the approval of the State Health Department. End 5 quote. 6 The landfill would either be all right or 7 they wouldn't dump. 8 Mr. Orville Stoddard, of the Engineering 9 Section of the Colorado Department of Health testified, 10 and I quote, There is an amended act that pertains to 11 the regulation of land disposal sites and facilities 12 that are often mentioned. This required the applicant 13 to submit a report of engineering, geological, 14 hydrogeological and operational data, to the Department 15 for review and recommended approval prior to the 16 issuance of a certificate of designation. End quote. 17 It is important to note at this point that 18 no engineering design operations plan or report has 19 ever been filed with the County or State from 1971 to 20 present. 21 During this hearing, several neighbors and 22 residents questioned location of the proposed dump 23 because, as you can see here -- and this is from the 24 1971, you got this in your packets -- sits on six 25 drainages, six major drainages. And when you look at BILLINGS REPORTING SERVICE 93106 . 111 1 the original topography, there is no doubt in your mind 2 why it' s wet. 3 This was a spring in here. These are the 4 major drainages. It sits on five, six major drainages 5 if you include the spring, and a lot of seep and wet 6 ground. They were very concerned about the high 7 groundwater, the development to the draw next to the 8 Spomer Lakes. That' s that Big Western draw, the draw 9 that we have all the problems. 10 As I said, they were very concerned about 11 that high groundwater development next to the Spomer 12 Lakes, and Mr. Moffat said and I quote, We don't intend 13 to get into that draw and work into the draw. End 14 quote. 15 Several farmers expressed concern on how 16 the operators were going to prevent the groundwater 17 from coming into contact with the trash. Mr. Guy 18 Shable, a long-time resident and successful farmer -- 19 who farmed the Knister Farms, I might add -- said, and 20 I quote, I think you're going to find out you have 21 water problems everywhere. Even on top of the hills 22 you are going to have water problems, end quote. 23 Mr. Ralph Waldo, who was representing Ella 24 Spomer, asked Mr. Stoddard of the State Health 25 Department, and I quote, Mr. Stoddard, if they can't BILLINGS REPORTING SERVICE 931061 112 1 cut that water off, then it will be your job to stop 2 the landfill ; is that right? End quote. 3 Mr. Stoddard replied, and I 'm quoting, 4 Yeah, I have to agree. The important -- I can't get 5 that out -- the important thing that we' ll be looking 6 at, of course, is to make sure that water pollution 7 does not occur from this operation in any way, shape or 8 form. End quote. 9 Mr. Waldo asked if Earl Moffat knew about 10 the spring in the center east half of the property. 11 Mr. Moffat said, and I quote, I didn't know about that. 12 End quote. 13 Mr. Waldo further asked, quote, Would you 14 take dead bodies, dead animals? End quote. 15 Mr. Moffat replied, and I 'm quoting, Most 16 people bury their pets. The larger animals go to a 17 dead animal place. End quote. 18 In over two years he could only remember 19 burying one horse. It should be noted that thousands 20 of animals carcasses are dumped at the landfill every 21 year. 22 And I 've included some photographs to 23 substantiate that number. That's Exhibit AD-46, 24 Page 19. 25 Mr. Shable asked, and I quote, You say this BILLINGS REPORTING SERVICE 9L1061 113 1 place will last 15 years; is that right? 2 Mr. Moffat replied, quoting, I think so. 3 Mrs. Carlson asked about the roads leading 4 into and out of the proposed landfill and the potential 5 problems with dust, litter and heavy traffic on the 6 dirt roadways. 7 The chairman of the commissioners, 8 Marsh Anderson, stated, and I 'm quoting, The law 9 says the County shall provide a road to the dump. 10 End quote. 11 Mrs. Carlson inquired about the shortcut, 12 which is 1 mile west of the Ashton School and south 13 1-3/4 miles of the landfill . That' s currently known as 14 County Road 27-1/2 . 15 Marsh Anderson replied, and I quote, The 16 road will have to be oiled, ma 'am. I don't think we' ll 17 be driving your roads when they can be driving both 18 ways on oiled roads. End quote. 19 It should be noted that County Road 27-1/2 20 is still a gravel road and currently has several ruts 21 that exceed 18 inches in depth. 22 Mrs. Myrtle Telep, my mother-in-law, asked 23 what the final design would like look. She actually 24 asked, and I quote, Well, I just think you' ll have a 25 table land, won't you? End quote. BILLINGS REPORTING SERVICE 9.31061 114 1 Mr. Earl Moffat replied, Yes -- well, no. 2 It won't just go out like this and then drop straight 3 over. End quote. 4 We've included some photographs that 5 look just like what has exactly occurred. That's 6 AD-46, Page 10. 7 Marsh Anderson at that time asked for a 8 vote, and the votes were: For the landfill, 8 people; 9 against the landfill, 12 people. 10 I would just like to spend a few moments 11 now relating the problems we've had in living next to 12 the dump. Knister Farms has been home to three 13 generations of our family. I was very proud to move to 14 Greeley and be a part of this tradition. 15 Before we moved in, I was aware of several 16 fires which had occurred, and in your packet is a 17 newspaper clipping from the Greeley Tribune dated 18 October 24, 1985. That' s Exhibit AD-46, Page 4 . The 19 clipping is of a story done on a fire that destroyed 10 20 acres of Knister Farm corn. The fire started at the 21 landfill and blew north to our fields. 22 MS. HARBERT: Would you point out, sir, 23 where you live, or where your property is? 24 MR. HAYES: Yes, ma 'am. Our property runs 25 from this corner of the landfill north. It actually BILLINGS REPORTING SERVICE 931061 115 1 goes just up on the upper north side of the map, comes 2 over here, up to here, over to here -- excuse me -- and 3 then up to here (indicating) . 4 That's not my property. That's my in-law' s 5 property, ma 'am. 6 The fire started at the landfill and blew 7 north into our fields. The Milliken Fire Department 8 Chief, Lowell Tarrant, states at the end of the article 9 that the dump has a history of fires in the fall and 10 requested a hearing between the County and the fire 11 districts. I never found any record in the county 12 files regarding this meeting. 13 Since we've lived near the dump, my wife 14 Ann has had to call Brad Keirnes on two separate 15 occasions about fires that broke out after the 16 operating hours of the landfill, and the operators were 17 unaware of it. 18 The noise at the landfill is very loud. It 19 starts around 7 : 00 a.m. every morning and runs for six 20 days a week. We really look forward to Sundays because 21 it is so quiet out there. Not only do you hear all the 22 landfill equipment, but all the trash trucks go 23 barreling down our road. 24 We have asked the County several times to 25 monitor Road 27-1/2 and 49th Street, because the trucks BILLINGS REPORTING SERVICE 931061 116 1 run the stop signs and travel much too fast along the 2 roads. 3 We 've had several near misses with these 4 trucks and I 've witnessed several close calls amongst 5 other travelers. Only nine days ago we had an 6 accident; a 31-year-old Johnstown woman was killed on 7 Road 27-1/2 by a 10-wheel truck going to the landfill. 8 Four children were luckily -- were lucky that they were 9 unhurt, because that car was pushed 300 feet along the 10 road. 11 That's just one of our problems. The ruts 12 on road 27-1/2 are incredible. I measured them last 13 week one day -- one day after the grader service went 14 through and graded the roads level, and I measured the 15 ruts at 18 inches deep. The trash trucks really damage 16 the road along the north-south route. 17 In listening to the County's public hearing 18 tapes on the Ault landfill, I noticed that Waste 19 Services insisted that no more than 25 trucks a day 20 would be traveling to the Central Weld Landfill . I 21 would speculate you have closer to three to five times 22 that amount today. 23 MR. MORRISON: Madam Chairman, I don't want 24 to interject here. But I think, Mr. Hayes, you might 25 be diverting a little bit from the issues today. BILLINGS REPORTING SERVICE 931061 117 1 MR. HAYES: Well, I was asked to speak as a 2 neighbor of the nuisances and the life next to it. 3 MR. MORRISON: Well, but the central issue 4 is whether there should be further hearings on whether 5 to revoke the permit, based -- and not all the issues 6 that may trouble you. 7 MR. HAYES: Are you saying nuisance factors 8 and nuisance issues -- 9 (Mr. Hobbs conferred with the witness off 10 the record. ) 11 MR. HAYES: Okay, I will . I ' ll wrap this 12 right on up. 13 As you can see from my chart, where the 14 hazardous traffic, the speeding traffic, the dust, the 15 road damage, it's ugly. I want you to note from the 16 previous slides, there is no landscape or visual 17 barriers. 18 The landfill generates an incredible amount 19 of the dust and it blows all across our fields. If you 20 look on the Exhibit AD-46, Page 14, you will see 21 several pictures that represent that. 22 I would like to speak just a few minutes 23 about some of the disease factors and some of the 24 problems that we see at the landfill. They spoke 25 earlier this morning on what good neighbors they were BILLINGS REPORTING SERVICE 931061 118 1 and how well they stay in compliance with the law. 2 This picture was taken on a Sunday. The 3 landfill closed on Saturday. You can see the trash 4 heaps, the trucks coming in during off-duty hours. 5 This black tarp is called an alternate daily cover. 6 You can see it did not fill and cover the face. 7 This was taken a little bit closer. I want 8 you to notice the trash heaps, the orange cones, and 9 notice in this foreground. Moving a little bit closer 10 on that shot, you can see the cones. 11 It' s difficult to picture what this is. 12 All those pink things are ears of sheep carcasses left 13 open. The landfill closed on Saturday. This was taken 14 on Sunday afternoon. 15 Okay. I ' ll take just one moment and I ' ll 16 summarize and I ' ll finish. 17 In listening this morning, this landfill 18 hearing reminded me of a story I heard about Abraham 19 Lincoln. He was faced with a very similar situation as 20 yours. 21 MS. HARBERT: Does this have something to 22 do with the regulations? 23 MR. HAYES: I think it does. I think 24 you' ll find it interesting. 25 He had to make a very difficult decision BILLINGS REPORTING SERVICE 931061 119 1 and, like you, he was hearing a lot of conflicting 2 information from his cabinet. Finally, he sat back in 3 his chair and he asked the group, How many legs does a 4 dog have? 5 Now, suppose that someone comes in with 6 pretty drawings and papers and certifies a tail is a 7 leg. Now, how many legs does a dog have? 8 Thank you. 9 MS. HARBERT: Is there anyone else that 10 would like to speak for or against this issue? 11 Mr. Hobbs, you are not completed; is that 12 right? 13 MR. HOBBS: We tried to put our group 14 together and tried to move it through, and I think you 15 will find the next statements are a lot briefer. 16 Mr. Hayes was called upon by the group to 17 give the overview of what this does in the way of the 18 life. 19 I would like to ask Myrtle Telep to come up 20 here, and I would like to ask the group to be as brief 21 as possible. We can hand out the written statements. 22 MS. HARBERT: I would like to add to that, 23 that if you agree with things that have been said 24 previously, that you just say that you agree with what 25 somebody else said, and not reiterate everything that 's BILLINGS REPORTING SERVICE 921061 120 1 been said so far. 2 MS. TELEP: I 've never talked on one of 3 these, and I don't know how this is going to come out. 4 MS. HARBERT: I think you're doing fine. 5 MS. TELEP: My name is Myrtle Knister 6 Telep. 7 MS. HARBERT: Get closer to the mike. 8 MS. TELEP: Excuse me. My name is Myrtle 9 Knister Telep, and I am one of the few remaining people 10 who attended that 1971 hearing. I went there to 11 represent my parents who lived on the farm, as Mike 12 showed you, north of the dump. They were ill at the 13 time and quite elderly, so they wanted someone to 14 represent them, because they were very concerned about 15 just what a dump was going to mean to their property, 16 because it might spoil a view or it might be -- you 17 know, all the things. I won't go over that. You've 18 seen them. 19 And I 'm just going to touch on two issues 20 that I remember hearing very well . The first one was 21 by Guy Shable, when he was trying to tell Earl Moffat 22 how bad the water problems were out there. He did 23 everything in his power to say, I farmed that place, 24 that site. I farmed part of the Knister Farm, I farmed 25 our places with my brother, and I know what this soil BILLINGS REPORTING SERVICE b31061 121 1 is. I know what you're going to have. There is seep 2 everywhere, there is water, and you are going to have 3 problems, Earl. You're going to have problems. 4 And all Earl could say was his old song and 5 dance, Well, I don't think there' s anything that we 6 can't get controlled. And that we heard several 7 times -- I heard several times. 8 And then I -- he was asked, Just what is 9 going to happen to this site, once the dump is closed, 10 as you say, in 15 years? And Earl said, I am going to 11 turn it back into very nice tillable land, agricultural 12 land. It will be a nice, gentle slope going right with 13 the topography that' s already there. 14 Ha, ha, ho. If anyone has gone out there, 15 they know what it looks like now. Please go out there. 16 MS. HARBERT: Will you address your 17 comments to the board, please. 18 MS. TELEP: Well, I think everybody here 19 has an interest. May I say that? 20 Okay. As I was walking out of the hearing 21 room that afternoon, I met Earl at the door. He saw my 22 face was rather long at the decision that was made just 23 like that (indicating) , and he said, Now, don't you 24 worry about a thing. In 12 years it will be beautiful 25 farmland. Those are quotes. BILLINGS REPORTING SERVICE 931061 122 1 I just want to say that just recently -- 2 may I say this to the crowd, Madam Chairman? This is 3 just a little quip I have, that I just wanted to have 4 today, if it's all right with you. 5 I 've been noticing in a few papers of late 6 that I 've been classified as a radical. Now, I am not 7 quite sure just what a radical means, but I -- if a 8 radical is a person who really cares for the good of 9 future generations, cares for his home, his community, 10 his country, and one who would like to leave this 11 planet in better condition than he found it, then I 'm a 12 radical. That' s all I can say. 13 MR. HOBBS: I would like to ask the 14 citizens, I know you feel stirred by that, but please, 15 let's just go ahead with the presentation. And I would 16 like to have Sharon Davis come up. 17 Let' s remember the public officials have a 18 decision to make, and that' s whether to grant a full 19 hearing. 20 MS. DAVIS: Hello. My name is Sharon 21 Davis. Do you need the address? 22 MS. HARBERT: We would prefer that, yes. 23 MS. DAVIS: Excuse me? 24 MS. HARBERT: We would prefer that, 25 yes. BILLINGS REPORTING SERVICE 901Q6. 123 1 MS. DAVIS: Okay. 3707 - 65th Avenue. I 2 am a resident of Weld County and have been a member of 3 the local emergency planning committee at the sheriff's 4 office since 1988. 5 Can you hear me all right? 6 MS. HARBERT: Are you picking her up? 7 MR. WEBSTER: You might tip the mike up. 8 MS. DAVIS: My husband and I have had 9 careers of music nearly all of our lives and run a 10 small music publishing business. 5-1/2 years ago we 11 moved to a property southwest of Greeley. One of our 12 plans was to build a small recording studio there as 13 part of our business activity. However, those plans 14 were immediately foiled after hearing all the trucks 15 enroute to and from the Milliken landfill -- loud, 16 rumbling and noisily downshifting as they approached 17 the intersection at our corner, which is a 18 four-way stop. 19 This activity did not manifest itself 20 during the times we looked at the house before 21 purchasing the property. Since moving there, we have 22 been aghast at the number of near misses at the 23 intersection. Not only cars and pickups, but trash 24 trucks zoom past the stop signs without stopping, 25 even with other vehicles at the intersection. BILLINGS REPORTING SERVICE 21061 124 1 We dread the time when just such a 2 foolhardy driver rushes through the intersection, 3 unexpectedly meeting a propane or gas truck coming 4 around the corner. That could certainly be the end 5 of this Ashton schoolhouse and everything in its 6 proximity. 7 We have the litter on the ground from 8 all the trucks and cars traveling with their fragrant 9 loads for dumping. We have to regularly clean up 10 branches, old lumber, auto parts, trash bags, and other 11 debris left on the roads, for safety sake as much as 12 for appearance. 13 The region around the landfill has a 14 special beauty -- broad views of the horizon, soft 15 rolling hills at the beginning of the prairies, slow, 16 winding creeks and rivers, calm bucolic scenes of 17 livestock winding its way through the pastures and by 18 aging old trees, and the freedom of birds and other 19 wildlife reminding us we are part of the earth. 20 These are features that drew us to the 21 area, features now being endangered by the shattering 22 effects of the landfill . The groundwater adjacent to 23 the landfill has been found to be polluted with 24 contaminants and is spreading out to other areas via 25 irrigation ditches, the Big Thompson and the South BILLINGS REPORTING SERVICE 924061 125 1 Platte Rivers, to say nothing of underground aquifers. 2 This contamination touches all of us 3 eventually, regardless of our proximity to the 4 offending source. 5 I have been alarmed at the apathy of so 6 many people in our county at the invasion into our 7 lives of various forms of pollutants which end up 8 affecting each of us in some way. 9 The ideal of everyone being affected by one 10 another was eloquently stated in 1627 by the English 11 poet in Divine, John Donne. And I quote: 12 "No man is an island, entire of itself; 13 every man is a piece of the continent, a part of the 14 main; if a clod be washed away by the sea, Europe is 15 the less, as well as if a promontory were, as well as 16 if a manor of thy friends or of thine own were; any 17 man's death diminishes me, because I am involved in 18 mankind; and therefore never send to know for whom the 19 bell tolls; it tolls for thee. " 20 I therefore ask the commissioners -- the 21 end of the quote, by the way. 22 I therefore ask the commissioners to hold a 23 final hearing immediately, so the people of this county 24 can learn the real facts pertaining to the Milliken 25 Landfill operation. BILLINGS REPORTING SERVICE 9 1064 126 1 We need to resolve this matter, not for the 2 aggrandizement of the world's largest waste hauling and 3 disposal company, but for the betterment of this 4 community's health and future. 5 Thank you. 6 MS. HARBERT: Thank you. 7 MR. HOBBS: Madeline Daniels. 8 MS. DANIELS: Madam Chairman, Members of 9 the Board -- 10 MS. HARBERT: Would you like to drop the 11 microphone a little bit, please. 12 Thank you. 13 MS. DANIELS: Ms. Harbert and Mr. Webster, 14 you know I am not a public speaker, so if I get shaking 15 up here -- and I don't think I can change what I 'm 16 saying, because it' s too late. 17 Chairman, Members of the Board of County 18 Commissioners, my name is Madeline Daniels. I live at 19 23732 Weld County Road 27-1/2 , Milliken. I live 20 approximately 1/4 mile southeast of the landfill. 21 Unlike Myrtle, I was not at the '71 hearing. Harold 22 and I worked in Denver and I had not yet met Harold. 23 His dad was in the hospital. His mom, at 85, signed a 24 petition against the landfill, but was unable to 25 attend. BILLINGS REPORTING SERVICE 931061 127 1 Our farm has been in the Daniels family 2 since the 1860s. In 1987 my husband retired from 3 C.U. Medical Center and I left the Denver public school 4 system to move back to Weld County so that we could 5 raise our son, Tom II in a safe, healthy environment. 6 We restored a house that Weld County had 7 built on our property in the 1880s, and we furnished it 8 with items from the period. We talked of some day 9 opening a bed and breakfast and establishing a small 10 museum with antique farm implements and artifacts of 11 Weld County's rich pioneer history. 12 Living on land that has been designated a 13 Centennial farm, we considered ourselves stewards of a 14 legacy, not only for our son, but his entire 15 generation. 16 We began organic gardening, believing that 17 vegetables grown without chemicals would provide a 18 healthier life. We were living the American dream of 19 Thomas Henry Daniels I. One afternoon our son came 20 running into tell us that our American dream had turned 21 into a nightmare. 22 The irrigation ditch was flowing with a 23 milky, foul smelling substance. The irrigation ditch 24 flows from the Spomer Lakes area through our farm into 25 the Big Thompson. This is the irrigation water we had BILLINGS REPORTING SERVICE 931061 128 1 been putting on our crops. 2 As we talked with our neighbors, we learned 3 that the water tests done by private labs, as well as 4 Golder and Associates, revealed the presence of heavy 5 metals and organic compounds. We were afraid to water 6 the garden, we were afraid to eat the vegetables we had 7 grown. 8 Plans for having a recreation room for our 9 teenage son are on hold. We do not know if the ground 10 is contaminated. 11 And who would ever visit a bed and 12 breakfast on the edge of a contaminated landfill? 13 We also worry about wildlife. We learned 14 last summer that the landfill was accepting 15 petroleum-contaminated dirt. Trucks filled with dirt 16 arrived continuously. When the air around the landfill 17 became hazy and filled with fumes, we were afraid to 18 sleep with our windows open, even in the worst of the 19 August heat. 20 Not knowing what was being disposed of or 21 what had accumulated for over 20 years causes us 22 anxiety and fear that cannot be described. When I look 23 out the window and look at the landfill and see it 24 growing higher each week, I am constantly reminded that 25 20 years of virtually unregulated disposal of sludge, BILLINGS REPORTING SERVICE 931061 129 1 asbestos, contaminated dirt and countless other 2 documented, as well as undocumented wastes could be 3 endangering the life and land that we love here in Weld 4 County. 5 When the landfill was designated in 1971, 6 there were fewer Federal, State and County level 7 regulations. There were fewer regulations at the 8 Federal, State and County levels. We did, however, 9 know that trash should not be placed in groundwater, 10 since the water would flow through the trash and leach 11 out chemicals. 12 In hearings to permit the landfill, local 13 farmers warned that groundwater was a problem, 14 particularly during the irrigation season. On our 15 farm, we have observed with regularity a spring which 16 appears shortly after farmers to the north begin 17 irrigating. It is obvious that water is moving through 18 the ground near the surface at a fairly rapid rate. 19 In '85, Orville Stoddard, an engineer at 20 the State Department of Health, analyzed existing 21 landfills in Weld County for suitability for disposal 22 of hazardous wastes. He determined all existing 23 landfills, of which Central Weld is one, were located 24 in aquifer recharge areas, floodplains or irrigated 25 farms. BILLINGS REPORTING SERVICE 921061 130 1 The overall drainage pattern in Weld County 2 is dendritic, resulting in a high degree of 3 interrelationship between streams and rivers. 4 Pollution of any part may result in pollution of the 5 whole, he said. 6 Therefore, he concluded that no hazardous 7 wastes, particularly pesticides, should be disposed of 8 in existing landfills, in order to protect ground and 9 surface water. We need to be no less careful about how 10 we handle household wastes, including lawn fertilizers 11 and pesticides, paint cans and solvents used for 12 cleaning, and especially contaminated dirt, asbestos, 13 sludge and other special wastes. 14 These wastes end up in landfills, and when 15 these landfills exist, as this one does, within a high 16 water table, we are inviting disaster in and for the 17 years to come. The potential for contact with 18 groundwater and surface water in the Big Thompson, as 19 well as other local rivers, made the siting of the 20 landfill an unwise decision in 1971. 21 Continuation and expansion of the landfill 22 22 years later is more than unwise. It is incredibly 23 foolish, now that we have experience to show that the 24 farmers ' warnings in 1971 were right. 25 We believe that our elected officials have BILLINGS REPORTING SERVICE 9310ss 131 1 the wisdom to learn from over 20 years experience. We 2 ask you to close the landfill and require its cleanup 3 according to the new Federal standards in order to 4 protect the citizens and the environment of Weld 5 County. 6 Thank you. 7 MR. HOBBS: Jane Carlson, speaking on 8 behalf of the Carlson family. 9 MS. HARBERT: Ms. Carlson. 10 MS. CARLSON: My name is Jane Carlson. I 11 live at 7191 - 49th Street. Our family has been there 12 since 1884 . 13 I 'm the mother of Albion Carlson, who is an 14 environmental scientist with the State of New Mexico 15 and who attended the School of Mines and graduated from 16 the University of Wyoming as a geologist. He has 17 submitted a statement, written statement, to the Board, 18 which is rather lengthy, but I would like to just 19 summarize a few of the main things here. 20 He lived in this community all his life 21 until he moved to New Mexico. The things that he's 22 concerned about are that the Central Weld Landfill is 23 located in a historic year-round wetland and slough 24 area, draining into the Big Thompson, Spomer Lakes, 25 wetlands, ponds and ditches and a significant area of BILLINGS REPORTING SERVICE 931%1 132 1 groundwater recharge. That the wetting and drying of 2 the clinging soil in this area expands and contracts, 3 creating a phenomenon known as piping, and that is when 4 it expands and dries, and then you have the holes. The 5 pipes that go through the ground that will conduct 6 groundwater, transfers water laterally and vertically 7 as far as water can flow, and eventually to the depths 8 of the formations that contain clay. 9 That high rate of water flow into the 10 landfill from the Knister Farms on the north side 11 always have, for 100 years gone in there during growing 12 season. That 's approximately four months, I guess, the 13 irrigation season, and it impacts it and it makes it 14 almost like a tropical area there, as far as water is 15 concerned. 16 The humidity is high, the amount of water 17 flowing through there is large. And the base of the 18 refuse and biomass is currently below the water level 19 in the Central Weld Landfill. 20 Now, he says that in New Mexico -- and he 21 writes a lot of regulations for New Mexico and 22 testifies as an expert down there -- and he says that 23 the waste in the groundwater would be sufficient for 24 closure of the landfill in New Mexico, and that those 25 were drafted -- those regulations were being drafted BILLINGS REPORTING SERVICE 9:1061 133 1 here in this state in 1993 , prior to February 1993 when 2 the officers of Waste Management requested that the 3 approval reword the sentence to state that the 4 operation of sites and facilities placing waste in the 5 groundwater after the date of these regulations is 6 prohibited. 7 Actually, we all know -- I was there when 8 this landfill started and I saw waste dumped into the 9 water. I know that it was done. I don't think anyone 10 denies it. 11 By way of analogy, the New Mexico solid 12 waste and landfill regulations are unaltered, and they 13 state that they prohibit burying trash within 100 feet 14 of an identified water table. Well, we know that the 15 water goes through there, particularly at irrigation 16 time, through this piping phenomenon, much above that. 17 Another thing he was concerned about, as 18 far as the regulations are concerned, was that there 19 was a request by Waste Management to permit field 20 filtering of the samples prior to laboratory analysis, 21 and he thinks that that is not a scientifically correct 22 thing to do. And, also, as far as they talked about 23 the dry zone and the low zone, and that there cannot be 24 a scientific degree of certainty about water going from 25 one level to another. BILLINGS REPORTING SERVICE 921061 134 1 Based upon his years of examining the 2 feasibility and measures called for in site closure, 3 he says that a purchaser of a landfill -- this is how 4 New Mexico looks at it -- requires no investigative 5 rights to derive economic gain any more than any other 6 citizen buying any business. And under the regulations 7 that there -- if they had taken the pains before they 8 made the purchase, that they would have known that 9 there were significant things there. 10 If we go to another meeting, another 11 hearing, I think Albion would be able to come. He had 12 a prior commitment for tomorrow and couldn't leave 13 New Mexico. 14 As for myself, I want to say this. On 15 behalf of my family, my neighbors and community, I want 16 to ask, What's going on here? We are faced with an 17 unsanitary, unlined landfill, located in soggy ground, 18 leaching into the Big Thompson River. 19 A big company bought it. They say, We 20 didn't cause these problems -- these nuisances that we 21 are here today on. Let us fix it. We can spend any 22 amount of money to fix this, but we can't do that 23 unless we can run it for another 12 , 15, 20 years, so 24 we can earn the money to fix it. We will have to 25 expand it to the south -- well, they say today they are BILLINGS REPORTING SERVICE 931061 135 1 not going to dump to the south -- but, anyway, going to 2 buy more land to the south, another hundred acres. 3 And what you should say to them is, This 4 operation is in violation of health standards, it's 5 hurting the public, it cannot continue. You bought the 6 problem when you bought the site. You made a bad 7 deal. You can't fix it by first making it worse and 8 then fixing a bigger problem. It' s your obligation to 9 fix it now. 10 And you ought to tell them to fix it now. 11 And these threats this morning about, Well, if you 12 close it down now, then we 're not going to be under 13 those regulations and we're not going to have to fix 14 it, that's not true at all. There are all kinds of 15 regulations that, when people have assumed this 16 responsibility, they are going to have to fix it. 17 MR. HOBBS: We are almost done. 18 MS. HARBERT: I think we are getting 19 somewhat repetitive. If you will please ask your 20 people, if they want to say the same thing as someone 21 before them, just to state that. 22 MR. HOBBS: All right. I understand that. 23 I am going to ask the public -- it' s very hard, there 24 has been pent-up frustration, and this is a public 25 proceeding, and the citizens don't need an apology, but BILLINGS REPORTING SERVICE 9431061 136 1 we will ask them, please, to, if you agree with what 2 was said before, say so. If you have something new to 3 add, add it. 4 Leon Tomczak. 5 MR. TOMCZAK: Ladies and gentlemen, good 6 afternoon. My name is Leon Tomczak. I live at 7 1107 - 30th Street Road in Greeley. I haven't brought 8 charts. I 'm a private citizen, and I 'm extremely 9 grateful to the Ashton-Daniels group for making 10 everyone of aware of what's happening so we don't 11 repeat the same problem again. 12 I had -- I listened this morning to Waste 13 Management making some comments, and this is perhaps a 14 little unusual, but I only have these to show you. 15 (Mr. Tomczak handed Mr. Morrison 16 jars of water. ) 17 MR. TOMCZAK: Now, I heard this morning 18 there is no trace -- and I know that maybe this black 19 one here, if it evaporates, someone is going to be 20 willing to drink it. I wouldn't. I 've gone out 21 yesterday to Spomer Lakes and this is where I got it. 22 And I saw muskrats swimming and ducks, and I hope 23 nobody hunted the ducks after I seen them. There are 24 dairy cows drinking this water, and I mean, I don't -- 25 if you want something different, I 'm sorry. BILLINGS REPORTING SERVICE 931061 137 1 MS. HARBERT: Would you like to explain for 2 legal counsel how to mark these exhibits, please. 3 MR. TOMCZAK: I ' ll -- sure. I guess A and 4 B. 5 MS. HARBERT: Which is which? 6 MR. MORRISON: The darker one, would you 7 explain where you got it? 8 MR. TOMCZAK: The dark bottle is from 9 Spomer Lake. Now, I 'm not sure if we are going from 10 which direction, because we were told that the drainage 11 one is in the third, I believe. And I -- or the 12 second. And I 've gotten this one from the third lake 13 from the north, as I 'm looking at it. 14 The other one is from my kitchen sink. I 15 hope I got those right. I don 't know what 's in it. 16 It, obviously, doesn't look good for wildlife, and this 17 is at a point of the lake that 's actually in the shadow 18 of this supposedly flat landfill. It overlooks it and 19 then we come down into the lakes, and this is where I 20 got that water. 21 I had a statement, and I just want to read 22 one sentence. And that is, if you kill the water, you 23 kill the life that depends on it, your own included. 24 That's natural law and it's common sense. And that 's 25 all I wanted to say and I appreciate you listening. BILLINGS REPORTING SERVICE 9.; 1061 138 1 MR. HOBBS: Dennis Dakan. 2 MR. DAKAN: Madam Chairman and Members of 3 the Commission, I am Denny Dakan. I live now in 4 Aurora, Colorado, and I grew up right here in Greeley. 5 Mr. Telep asked me to come up. 6 I am an international consultant on the 7 environment. Currently, my clients include the Federal 8 Government and the Republic of Germany. My concern and 9 tasks there are involved in the cleanup of the former 10 Russian air bases. I am also an international 11 consultant with Hierly Corporation out of Zurich, 12 Switzerland, doing work in Singapore. 13 I am concerned, and I believe if I may put 14 it in some relevance to you, the members of this 15 commission, I think that we have heard some very 16 compelling remarks on both sides of the issue today, 17 both from the Waste Management and from the local 18 personnel that live and very deeply are involved within 19 this community at large here. 20 I would like to focus, if I may, your 21 attention to the concerns that I think that are most 22 primate to the issue at the moment. And that is the 23 concern that I want to protect Weld County for what it 24 is, and I know that you do, too. 25 That is an issue that I believe, based on BILLINGS REPORTING SERVICE 931061 139 1 the testimony, the geology of the surface, the ground, 2 the underground that we have here in Weld County, with 3 the water, which is prime and premium to this County' s 4 existence. 5 I believe, and it is forthcoming upon you 6 to ensure that we hear not only an opening, but in the 7 full court system of this commission, to hear and make 8 decisions that must be done in handling both the 9 groundwater issues and the solid waste issues. 10 Thank you. 11 MR. HOBBS: We have one concluding remark. 12 That is from Mr. Kent Hanson, a colleague of mine who 13 is a environmental specialist, a lawyer. He will 14 summarize the state of the regulations. 15 Again, we want to underscore that we are 16 seeking to have a full public hearing on whether or not 17 your zoning and land use approval was violated for 18 failure to have a proper and adequate engineering 19 operation plan for the facility. 20 Mr. Hanson. 21 There are other members of the public who 22 would like to testify, but that would conclude our 23 block of the presentation. I would urge you to hear 24 other citizens who are interested. 25 MR. HANSON: My name is Kent Hanson. I 'm BILLINGS REPORTING SERVICE 9 . 1061 140 1 an attorney. I would like to address just some of the 2 legal questions that have been raised here. 3 Mr. Roy stated this morning that there are 4 two questions that this commission must answer. First 5 is, Have there been violations out at the site? And 6 the second is, What should be done? We agree on the 7 questions. We disagree on the answers. 8 If we take a look at what Waste Services ' 9 position is, we can see that there have been violations 10 in each and every area that has been alleged by the 11 County staff in this case. 12 The first issue is whether or not an 13 engineering design and operations plan or report is 14 required. In Mr. Roy' s comments, he went through and 15 pointed out that the statute, under Section 103 in 16 particular, is an application statute. And from that 17 he concluded that, because it is an application 18 statute, that any deficiencies that exist with regard 19 to the approval of the initial applicant 's application 20 in this case is untimely; any challenge to that is 21 untimely at this point. 22 He also goes and he points out that the 23 statute now says that there are no requirements that 24 can be imposed on people who already have their 25 application -- no new application requirements. BILLINGS REPORTING SERVICE 91061 141 1 Now, it has been pointed out, in particular 2 by Mr. Hobbs, in going through the various exhibits in 3 this case, in particular, the reports of the health 4 department. And also you have been directed to the 5 transcript of the proceeding of September of 1971. 6 When we take a look at that, what we see is 7 that, as Mr. Hobbs pointed out, there was a commitment 8 that was made, a commitment by the applicant to abide 9 by the draft regulations, that the County took the 10 applicant at his word, and as a result, incorporated in 11 the County's resolution the requirement that the 12 Department of Health review the application and all 13 plans for his proposed landfill facility. And it 's 14 that commitment that forms the legal basis for the 15 action that has been requested by the staff in this 16 case. 17 It' s that commitment and its incorporation 18 into the resolution as a legal requirement that has 19 been violated. So we need not even take a look at the 20 statute and see which statutory provisions we have to 21 analyze here. 22 There's been some suggestion, in particular 23 in a prior application, prior submittal to the County 24 by Waste Services, that there is some perhaps ambiguity 25 in the County requirements. BILLINGS REPORTING SERVICE 91061 142 1 I would like to point out that the law on 2 this point is very clear in Colorado. If a requirement 3 in a permit of any kind is unclear, it does not give 4 the applicant carte blanche to do whatever it wishes to 5 do. It imposes an obligation on the applicant to clear 6 up any ambiguity. 7 There are a number of cases, including a 8 case out of the Colorado Supreme Court. The name of 9 the case is a Flynn versus Treadwell, which was a case 10 in which a resident in Fort Collins built a garage, and 11 argued that the permit to build the garage was 12 ambiguous. The Court ruled that he knew it was 13 ambiguous before he built his garage and made him take 14 down the garage because he failed to clear up the 15 ambiguity. 16 There are similar other cases. Follett 17 versus Lakewood, in which there was a question about 18 what the meaning of a storage barn is and, again, the 19 Court said, If you are going to assume what it means as 20 an applicant, you act at your peril. 21 And here, the resolution is quite clear, 22 and it is supplemented by the underlying record. And 23 the Court there has also said that if there is any 24 question about what a requirement of a permit really 25 means, you look at the record. BILLINGS REPORTING SERVICE 921061. 143 1 And if you look back at the proceedings in 2 July of 1971, Exhibit No. 1 in your packet, AD-1, if we 3 look at the communications from the Health Department 4 in August of 1971, the communications from Mr. Garr, I 5 believe, you see that it is very clear, the requirement 6 that was being imposed by the government, by the County 7 and by the State, on the applicant. 8 And then if we look at the transcript and 9 we look at Mr. Moffat 's own statements -- I won't 10 bother to take you through the transcript right now -- 11 but if we look at his own statements, we can see in 12 those statements in response to many questions, about 13 seepage in particular, about the final closure of the 14 facility, his response was, there are many regulations 15 that are brand-new now that we are going to have to 16 comply with. 17 And he undertook several times over to 18 comply with those new regulations. So was there a 19 engineering design and operations report required? 20 Definitely, yes, and the record shows amply that none 21 was ever submitted. 22 Now, what 's the importance of that? That 23 gets to the question of, What does the commission do? 24 In light of that evidence, the commission today's only 25 action is really to grant a hearing, a hearing on the BILLINGS REPORTING SERVICE 301061 144 1 larger question of, What's the remedy? Waste Services 2 would like to skip over this and have this commission 3 adopt right now after this preliminary hearing a 4 remedy, and that's to allow them to amend their 5 application. 6 Under the staff's proposal, they too would 7 like to put things off and allow continued violations, 8 grant them nearly another year, effectively, after the 9 applications are submitted and the proceedings take 10 place, another year to try to bring things into line. 11 The only question here is, What is the 12 authority of this commission? And that is answered by 13 Section 30-20-112, which Mr. Hobbs referred to in his 14 remarks. And the Commission's authority is simply 15 this. To determine if there was a violation and then 16 to select from among the available remedies, and those 17 remedies include only temporary suspension or 18 revocation. 19 Whether or not Waste Services is entitled 20 to amend its application is a proceeding that is 21 self-contained. It is on a separate track. This 22 track, pursuant to the law, is to determine only one 23 thing. Are there violations and should the permit be 24 suspended? That is the issue to be determined by this 25 body after we have the full-blown show cause hearing. BILLINGS REPORTING SERVICE 931061 145 1 Now, the second point, we don't have to 2 spend any time on, because in the written remarks and 3 in the statements of the various Waste Services people, 4 it has been admitted that there are discharges of 5 pollutants into the waters of the State. That's an 6 admitted violation. 7 That alone should be sufficient to have 8 this proceeding go to the next stage, the show cause 9 hearing. 10 Violation No. 3 is the violation concerning 11 the contamination of groundwater. Waste Services 12 argument is essentially this: That because the 13 language of the regulation says that a cover is 14 required to prevent certain things -- and that includes 15 blowing debris, ponding of water, and in the language 16 of the regulation, is to include prevention of 17 surface -- or of water pollution and air pollution, 18 that they are subject to violations only if it can be 19 demonstrated if groundwater in the trash is a result of 20 an inadequate cover. 21 I would submit that that argument is fairly 22 absurd for a couple of reasons. If we do look at the 23 regulation, it does read in one clause that the 24 facility shall provide an adequate cover with suitable 25 material and surface drainage denatured to prevent BILLINGS REPORTING SERVICE 921061 146 1 ponding of water and wind erosion and prevent water and 2 air pollution. 3 But, obviously, the regulations are 4 designed to prevent water pollution from a facility, 5 regardless of whether it's due to inadequate cover or 6 inadequate handling of groundwater, preventing 7 infiltration or preventing discharge from a facility. 8 And if we look at other parts of the regulations, such 9 as 2 .4 . 5, which is applicable to this facility, and 10 every facility, whether or not it is, quote, 11 grandfathered or not, it says water pollution shall not 12 occur at or beyond the site boundary after closure. 13 Well, if it 's gotten out before closure, 14 it's pretty hard to suck it in after closure. And the 15 regulations go on, and in other parts, 4 . 2 . 1 specifies 16 that groundwater shall be protected from water 17 pollution by leachate from the facility for solid waste 18 disposal. We see there are other provisions in there. 19 Also, we can see what happened with this 20 regulation if we go back and we look at the 1972 21 regulations, which this operator, the predecessor, 22 agreed to abide by. 23 And in those 1972 regulations, which are 24 found at Tab 4 of your materials, and on 25 Page 5 it's very clear. There was a semicolon in BILLINGS REPORTING SERVICE 931061 147 1 there. A semicolon that divided the requirements about 2 cover in order to protect from windblown debris and 3 from ponding, semicolon, and to prevent water and air 4 pollution. So it' s not just related to the cover 5 argument. 6 So what do we have here? Do we have 7 groundwater contamination? Yes. Need it be related 8 only to some problem with cover at the site? Obviously 9 not. Does No. 3 show a reasonable belief that there is 10 a violation of the statute? Definitely. 11 No. 4, again, that violation is one that 12 pertains to trash in the groundwater. And they've 13 admitted in a written statement, trash is in contact 14 with groundwater in the north end of the facility. 15 They put an interesting twist on things in 16 order to try to explain. They say, We didn't put our 17 trash in the groundwater; the groundwater got into our 18 trash. Well, the regulations don't differentiate 19 between that, because it recognizes that trash and 20 groundwater don't go together. They create problems. 21 What this argument means to imply and, in 22 fact, they did imply, they just said this is a problem 23 that's really created by the farmers in the area by 24 agricultural activities, which were there long before 25 the landfill. Again, that' s -- even if that were true, BILLINGS REPORTING SERVICE 9:1061 148 1 and I submit it is not, it is not an excuse for the 2 violation. 3 So if we look through on each of the four 4 violations that have been specified by the County 5 staff, we see that the evidence is, I think, pretty 6 clear. It certainly gives rise to a reasonable belief 7 that there has been a violation and, as a result, we 8 need to go on to the next step. 9 Now, let' s talk about that next step for a 10 minute. Waste Services would ask this commission to 11 leapfrog that next step; in fact, to ignore it 12 altogether. They say, Let us amend our application. 13 Well, there 's a couple problems with that. 14 One is just the legal requirements and one is a hidden 15 agenda. Let' s talk about the legal requirements 16 first. The statute is very clear. It says, if there 17 is a violation, you then determine if there should be a 18 suspension or revocation. It says nothing about 19 allowing an amendment. 20 An amendment is something that anticipates 21 an existing facility in compliance that says, We would 22 like to do something new. We would like to expand our 23 operation, which by the way, they have been doing all 24 along, anyway. But we would like to expand our 25 operation. Let's ask for an amendment before we BILLINGS REPORTING SERVICE 3:31061. 149 1 expand. 2 You don't ask for an amendment to avoid the 3 sanctions that the law imposes for failure to comply, 4 especially when that failure to comply has been for 22 5 years. So you've got two tracks. They are very 6 separate. You can't merge them. You can't put both 7 trains on the same track. 8 The County's job at this point is to 9 proceed on the track to determine, Is there a violation 10 and should there be suspension or revocation as a 11 result of the next hearing? That' s the sole issue. 12 You can't leapfrog it; you can't ignore it. 13 I 'll submit also that the staff's request 14 that this matter be delayed until December 1 achieves 15 the same result, to ignore the responsibilities and 16 authorities that this commission has in light of the 17 violation, and to await the outcome of the amendment 18 proceeding. 19 That gets us to the hidden agenda. A 20 couple of things are going on here. One, they do not 21 want their permit revoked for a number of reasons. 22 Why? Because if it's revoked, all of their facility by 23 the time they get a new permit is going to have to 24 comply with Subtitle D. Right now the existing 25 facility is grandfathered in under Subtitle D. BILLINGS REPORTING SERVICE 9241061 150 1 And Subtitle D says it applies only to 2 horizontal expansion, to new parts of the facility. 3 Subtitle D does not apply to vertical expansion. 4 That' s why, contrary to the representations and 5 commitments of Mr. Moffat when he came in here and said 6 that the elevation would be equal to the surrounding 7 grade, would be benched and stepped down from there, 8 and somebody that would have been required in their 9 EDOR, if we look at the regs under Tab 4, there is a 10 specific provision that says right upfront, when you do 11 your original engineering and design report, you have 12 to address the question of final elevation because 13 that's going to be your standard. 14 And by the way, the EDOR is very important, 15 too, because it is an enforceable part of what a 16 permittee must comply with. The regulations are 17 performance goals. It says, Don't pollute. They don't 18 tell you how not to pollute. They just say, Don't 19 pollute. 20 The EDOR is the specific plan by which the 21 government determines which way the applicant is going 22 to meet those standards. Then they become enforceable, 23 too. It never existed here in this case. 24 When we get back to Subtitle D, if this 25 permit is revoked, what happens is, all of their BILLINGS REPORTING SERVICE :l!J64 151 1 facility, if they go back for a new application or 2 amendment, as they call it, will have to comply with 3 Subtitle D. They don't want to. That' s expensive. 4 They would rather go up another 50 or 60 5 feet as their plans propose. It's a lot cheaper for 6 them. And despite all their expressed concerns for the 7 environment, it's not nearly as protective of the 8 environment as complying with Subtitle D. 9 It' s also detrimental to the neighbors. A 10 trash mountain doesn't protect property values. They 11 failed to consider the effect of the facility on 12 property values. 13 So that now we get to the second part of 14 the hidden agenda. Will you get that chance? If Waste 15 Services has its way, the answer to that is no. They 16 ask you to put this off, and they will come back in 17 here and they will argue, just as they argued in the 18 FDIC versus Arapahoe County, in which Waste Management 19 was also a party. 20 In there, they argued that a county has no 21 authority under the regulations to consider an 22 amendment for certificate of designation. There' s a 23 flaw in the regulations that gives way, makes way for 24 this argument and, as being a lawyer, we can argue 25 about whether or not their argument is correct. BILLINGS REPORTING SERVICE 931061 152 1 But they won this argument, and they 2 flashed this argument at least a couple times in this 3 case already in their correspondence to the County. 4 And they've said, We won it there and we are going to 5 apply it here. 6 What is that argument? Under the 7 regulations, in order to expand, a permit holder need 8 only submit an amended application. There is no 9 requirement in the regulations that they get an amended 10 certificate of designation. And, indeed, in the FDIC 11 case, they argued that there was no requirement for a 12 public hearing by the County and that the only thing 13 they needed to do was go to the Department of Health 14 and to submit their application and get it approved by 15 them, and So long, County. 16 So that' s the second part of the hidden 17 agenda. We've got this legal posturing going on. So 18 to delay action, the action that 's required by the 19 statute -- to delay action in this case, a delay for 20 them is victory. 21 And it means not only that will they not be 22 held up to the standard imposed by statute, but that 23 they will not ever be held up to the standards imposed 24 by the statute, and under their FDIC argument, you will 25 not even have an opportunity to consider granting an BILLINGS REPORTING SERVICE 9:1061 153 1 amended certificate of designation. That will be out 2 of your hands. 3 So what's your next step? Your next step 4 is required by the statute, is to have the show cause 5 hearing. And I submit that that hearing should be held 6 at the soonest practicable date. Otherwise, the County 7 would be in the position of actually condoning 8 continued violation at the site, not the County's role, 9 and that at the conclusion of that hearing, I believe 10 the evidence that we've seen here today alone, but the 11 evidence at that hearing will show that the appropriate 12 sanction will be revocation of the permit to operate. 13 MR. HOBBS: That concludes our 14 presentation, and according to the ruling, I am 15 submitting several questions I would like to be 16 addressed in the rebuttal of Waste Management. And one 17 clearly is, Is there other landfill and capacity in 18 Weld County that could take this material if you 19 determine that there is a violation and this should be 20 closed? 21 I believe the only landfill operator, by 22 the way, is Waste Services and Waste Management, has 23 plenty of capacity, if it would help the commission. I 24 think that will help, but they said it's in the public 25 interest to keep this open. BILLINGS REPORTING SERVICE 92,106,► 154 1 We think you have already sanctioned a 2 much, much better plan operated by these same 3 people, and the trash in Weld County can go there 4 rather than to a facility that does not comply. 5 But I would like to tender to the county 6 attorney these questions, and in your discretion, you 7 may or may not ask them. 8 Thank you very much. 9 MS. HARBERT: Lee, do you want those 10 questions read for the record or what? 11 MR. MORRISON: It might be more effective 12 when we get to rebuttal. I mean, I can -- I think it 13 would probably be best to provide that at that point. 14 Madam Chairman, the State Health Department 15 has representatives here. I 'm not sure how much longer 16 they are able to stay, so if there are questions to 17 pose to them, or they have comments, now might be a 18 good time. 19 MS. HARBERT: Could we have a 20 representative of the State Health Department come 21 forward, please. 22 (Mr. Mowry came forward. ) 23 MS. HARBERT: Are there questions you would 24 like to ask? 25 MS. KIRKMEYER: Maybe you would like to BILLINGS REPORTING SERVICE 9.'1061 155 1 make a statement first. 2 MR. MOWRY: I am not prepared to make a 3 statement. 4 MS. HARBERT: Would you state your name and 5 address. 6 MR. MOWRY: For the record, I am Glen 7 Mowry, and I 'm the section chief of the solid waste 8 unit. And I ' ll give my work address, which is the 9 Colorado Department of Health, 4300 Cherry Creek Drive 10 South -- is my work address. And I ' ll answer questions 11 that I can. I really don't have a prepared statement. 12 MS. HARBERT: Are there questions for 13 Mr. Mowry? 14 MS. KIRKMEYER: I guess the first question 15 would be what Mr. Hanson said, that if they were 16 allowed to amend their certificate of designation, 17 there would have to be a hearing by the Weld County 18 Commissioners. 19 MR. MOWRY: I would have to look at the 20 statute to find that. I think 30-20-103 or 104 from 21 the 1992 amendment would require a public hearing for 22 an amended application. 23 MS. KIRKMEYER: A public hearing with the 24 Board of County Commissioners or a public hearing at 25 the Department of Health? BILLINGS REPORTING SERVICE 931061 ' 156 1 MR. MOWRY: At this level, the County -- 2 MS. KIRKMEYER: At this level? 3 MR. MOWRY: The State Health Department 4 does not conduct public hearings. They are always done 5 on the local level. 6 MS. HARBERT: Are you looking that up, or 7 do you concur with that? 8 MR. MORRISON: I am looking. 9 MS. HARBERT: While he is looking, are 10 there other questions for Mr. Mowry? 11 MR. HALL: Has there been any approval of 12 this landfill site by the State Department of Health? 13 MR. MOWRY: I think the testimony today 14 says that in 1971, the department, quote, approved it. 15 I would like the Board to understand that the 16 Department of Health does not and never has approved 17 landfills in that sense of the word. 18 They make a recommendation to the Board of 19 Health that they feel that the particular landfill can 20 or cannot meet the minimum standards that we review 21 landfills for. The actual approval is on your level. 22 MS. KIRKMEYER: So has there been an actual 23 recommendation of approval made by the Department of 24 Health? 25 MR. MOWRY: The only thing I 've seen, the BILLINGS REPORTING SERVICE 991061 157 1 portion of testimony from 1971, and I would assume that 2 would be called a recommendation for approval. 3 MS. KIRKMEYER: But is there any other 4 written documentation? 5 MR. MOWRY: Not that I 'm aware of, no. 6 MS. KIRKMEYER: What about back to what 7 Mr. Hobbs was saying, Condition No. 1 on the 8 resolution, that states that any sanitary landfill 9 facility to be installed shall be approved by the State 10 Health Department? 11 He has made reference to this condition, 12 saying this was one reason why this site is not 13 grandfathered in. 14 MR. MOWRY: I think that' s a legal argument 15 that I am not prepared to address. 16 MS. KIRKMEYER: My other question, if 17 nobody else has any, the proposed solid waste 18 regulations, the draft that' s out there right now, can 19 you give us an idea of time frame of adoption of those 20 regulations? 21 MR. MOWRY: We have a hearing coming up the 22 third Wednesday in May. If the Health Department 23 approves the draft regulations at that time, they 24 become effective 20 days after that date. 25 MR. WEBSTER: You're the person that has BILLINGS REPORTING SERVICE 9:;1063 158 1 approved -- not approved -- but reviewed the discharge 2 permit? 3 MR. MOWRY: No, I 'm not. Barbara, from our 4 water Quality Division, has reviewed that. 5 MR. WEBSTER: She has, that's all I have. 6 MS. HARBERT: Do you have a question? 7 MR. WEBSTER: No. I just wondered 8 whether -- 9 MS. KIRKMEYER: Maybe she could give us a 10 time frame, because as far as we know, the discharge 11 permit hasn't been approved yet. Has it been approved 12 yet, the discharge permit? 13 MS. TAYLOR: No, it hasn't. 14 MS. HARBERT: Would you come to the 15 microphone, please, and state your name. 16 MS. TAYLOR: Okay. 17 MS. HARBERT: Thank you. 18 MS. TAYLOR: My name is Barbara Taylor. 19 I am an environmental engineer, and I 'm reviewing the 20 discharge permits. The permit is presently in the 21 review process, which will involve -- well, I asked 22 Waste Services to go back and perform many more tests 23 on their discharge, which delayed the process 24 considerably. 25 MS. HARBERT: Can you give us a time frame BILLINGS REPORTING SERVICE 931061 159 1 at all? 2 UNIDENTIFIED PERSON: Don't look at me. 3 MS. KIRKMEYER: Are there any number of 4 days, the process can only last so long? 5 MR. MOWRY: Yes, 180 days from the time the 6 application is made. 7 MR. WEBSTER: What was that time? 8 MS. HARBERT: Someone? 9 MS. KIRKMEYER: November or December. 10 MS. HARBERT: It was submitted in November 11 of '92 . So 180 days is about up? 12 (Off record comments among commissioners. ) 13 MS. TAYLOR: 180. But we did postpone it 14 to get additional chemical testing on the discharge. 15 MR. BAXTER: Have you received additional 16 tests? You required them and you received those 17 additional samples from Waste Services? 18 MS. TAYLOR: Yes. Yes, and for several of 19 them, they had to go to other laboratories, several 20 different laboratories, because we had several 21 pesticides measured, and several volatiles, heavy 22 metals. 23 MR. WEBSTER: None of these tests were 24 collected to be forwarded by our own Health Department 25 to the State Health Department? BILLINGS REPORTING SERVICE 901%61 160 1 MS. TAYLOR: No. 2 MS. KIRKMEYER: Maybe you could explain. 3 We already heard Arthur Roy's explanation of why you 4 could find VOCs at the discharge area, but not at 5 Spomer Lake 2 . 6 MS. TAYLOR: Yeah. This isn't real 7 uncommon for this type of VOC. These are ethenes and 8 ethanes, they're very light, and there are relatively 9 few carbon compounds, and they volatilize very easily. 10 And I 'm sure that that 's what' s happening on the way to 11 Spomer Lake. 12 Also, there is a change in chemistry from 13 the top of the landfill to the bottom of the landfill. 14 It's relatively sodium rich at the top, and by the time 15 we get to the bottom of the landfill , there is Spomer 16 Lake, we are dealing with calcium magnesium compound, 17 and our hydrogen sulfide, HS, is being converted to 18 H2S, and that would explain the odor that we are 19 getting. 20 And, also, the milky appearance of the 21 water. I guess -- 22 MS. HARBERT: Say that again in layman's 23 language. 24 MR. MOWRY: Well, calcium magnesium is what 25 you are getting when you mix a Pepto Bismol tablet in BILLINGS REPORTING SERVICE 9.:1061. 161 1 some water, okay? 2 MS. HARBERT: So we have that type of layer 3 of soil or chemical in the earth? 4 MS. TAYLOR: Yes. And it varies with 5 temperature and pH. And, most likely, we are getting 6 it there during the period of warmer temperature, I 7 would guess. 8 MR. WEBSTER: Have any tests been taken at 9 the mouth of the stream that goes into the Thompson 10 River, above and below at that point? 11 MS. TAYLOR: As a matter of fact, I have a 12 whole sheet of paper with results from the Thompson 13 stream at that point. The hardness, which is a measure 14 of calcium magnesium, is up in the 700s at that point, 15 which is very high. 16 Just to give you an idea, most 17 municipalities try to keep theirs down below 200 for 18 drinking water. But it's only aesthetically not 19 pleasing. It's not a health problem, as such. 20 MR. WEBSTER: No, that isn't a health 21 problem. But my next question, have you talked for VOC 22 or anything like that? 23 MS. TAYLOR: Yes, I have all those results 24 on the map. And in the process of granting a discharge 25 permit, Waste Services will have to meet the best BILLINGS REPORTING SERVICE 931061. 162 1 standard that they can meet to the mouth of that river, 2 assuming that their waste is going to go to the mouth 3 of that river. 4 MR. WEBSTER: Those figures you don't have 5 completed yet; is that what you' re saying? 6 MS. TAYLOR: I have them on a huge sheet of 7 paper. They are on a data retrieval sheet of paper, if 8 you want to see them. 9 MS. HARBERT: I guess I 'm still concerned 10 about this magnesium chloride -- or calcium. Which is 11 it? 12 MS. TAYLOR: It' s calcium and magnesium 13 carbonate. 14 MS. HARBERT: Okay. Would that be there 15 whether there was a landfill or not? That' s what I am 16 trying to figure out. Is this a natural formation of 17 land or is it a cause of the landfill, and is it high 18 at the mouth of the river because there is a landfill 19 or just because that' s the makeup of the land around 20 there? 21 MS. TAYLOR: Well I can't say whether the 22 landfill would contribute to it in any way or not by 23 selective osmosis through the exchange through the 24 piping that's under there. I do know that the region 25 itself is very rich in calcium magnesium, and also the BILLINGS REPORTING SERVICE 921061. 163 1 radioactives that were found. It's a radioactive 2 material. 3 MS. HARBERT: Okay. 4 MS. KIRKMEYER: Was the underdrain, was it 5 required to have a discharge permit back in 1982 when 6 they put it in? 7 MS. TAYLOR: The one to the northern end? 8 MS. KIRKMEYER: No. It would be the 1982 . 9 MR. ROY: I think she is referring to the 10 one that comes down to the landfill to -- 11 MS. TAYLOR: Oh, no. Huh-uh. Any more 12 questions? 13 MR. WEBSTER: Thank you. 14 MR. ROY: May we ask questions of the 15 Health Department, since we made a representation on 16 our position? 17 MS. HARBERT: You can pretty soon. 18 MR. ROY: Does the landfill -- sorry. 19 MR. MORRISON: Do you want him to ask 20 questions now or wait until he has his rebuttal? 21 Are you going to be able to stay? 22 MR. ROY: Never mind. 23 MS. HARBERT: Art, if you want to come to 24 the mike and ask questions -- 25 MR. ROY: No. BILLINGS REPORTING SERVICE 931061 164 1 MS. HARBERT: Mr. Hobbs, do you have 2 questions of the Health Department? 3 MR. HOBBS: Not if this isn't the time to 4 ask questions. I am trying to abide by the rules of 5 chair. I would love to. 6 MS. HARBERT: Well, we are trying to 7 accommodate the Health Department because they need to 8 go back to Denver. I think probably, because of that, 9 we might go out of order. If you do have a question, I 10 would entertain it at this time. 11 MR. HOBBS: I have one question. 12 MS. HARBERT: Come to the mike and state 13 your name and ask the question, please. 14 MR. HOBBS: My question would be this. 15 Could you rule out the landfill contributing to the -- 16 (Brief interruption. ) 17 MR. HOBBS: If I may, I don't see what 's so 18 funny. Waste Services has laughed at me for trying to 19 get the facts. 20 MS. HARBERT: Would you state the question 21 again so the court reporter may hear it. 22 MR. HOBBS: You were asked whether or not 23 you could say it was a natural occurrence to do the 24 landfill. You said you couldn't say. 25 What would you need to have tested or BILLINGS REPORTING SERVICE aq�� S A.062. 165 1 analyzed to see whether the landfill was contributing 2 to the high levels you saw near the Big Thompson? 3 MS. TAYLOR: I suppose, right offhand, just 4 thinking of something I did in graduate school, I 5 suppose what we would have to do is construct a pilot 6 landfill in the area and see if we get the same 7 response. I can't say. 8 MS. HARBERT: Can you -- would to be fair 9 to say that if you tested the water above the landfill 10 on the upside of the river and you got similar 11 readings, just because that whole area is about the 12 same makeup, that that would give you a comparison? 13 MS. TAYLOR: You mean upstream, up and down 14 from the landfill? 15 MS. HARBERT: Uh-huh. 16 MS. TAYLOR: Not really, because I really 17 don't know what's going on there in terms of 18 temperature or pH, or depth or flow, change in 19 gradient. All those things are going to affect what 20 precipitates out on its way down there. 21 MS. HARBERT: Thank you. 22 Art, do you have a question? 23 MR. ROY: Yes. 24 MS. HARBERT: Would you come to the 25 microphone, please. BILLINGS REPORTING SERVICE 92,1061 166 1 MR. ROY: If the opinion -- two questions. 2 If the opinion of the Colorado Department of Health, 3 does the landfill constitute an immediate threat to 4 health or environmental risk? 5 Second, what is the position of the 6 Colorado Department of Health, if it has one, with 7 respect to its preference as to whether the landfill be 8 shut down in its present state or that the operation 9 continue and corrective action or remediation take 10 place? 11 MS. HARBERT: Which one of you would like 12 to answer that? 13 MR. MOWRY: I don't know if I want to try. 14 My name, for the reporter, again, is Glen Mowry. Could 15 I have your questions again? 16 MR. ROY: That's the short, abbreviated 17 version of it. 18 MR. MOWRY: I think the key word in the 19 question was -- the question is, Does the landfill pose 20 an immediate health or environmental risk? And I think 21 the key word is immediate, and my answer to that is 22 no. If this is allowed to go on unchecked for some 23 indeterminable period of time, I would probably change 24 my mind. 25 As far as the reaction to whether the BILLINGS REPORTING SERVICE 931061. 168 1 regulations. They are national standards. 2 The regulations I mentioned to your earlier 3 question regarding the May hearing of the Board of 4 Health and Colorado Department of Health is a draft 5 regulation that takes the Federal Subtitle D and 6 integrates it into State regulation. 7 The State of Colorado is going to apply for 8 approved state status under the Subtitle D to enforce 9 the intent in Subtitle D. 10 MS. KIRKMEYER: You say they are going to 11 apply? 12 MR. MOWRY: Yes, we will be applying, 13 hopefully, before the end of this month. 14 MS. KIRKMEYER: What' s it contingent upon? 15 MR. MOWRY: We have to have regulations 16 that meet Subtitle D. To start with, we have to have 17 certain personnel and budget and various things. 18 Then the EPA makes a decision within six 19 months of the application whether or not we are 20 approved, and can then enforce the Subtitle D, or 21 whether we as a State are not approved, in which case 22 the whole system reverts to the EPA. 23 MS. KIRKMEYER: EPA then would approve -- 24 or would enforce Subtitle D? 25 MR. MOWRY: Yes. There is no approval or BILLINGS REPORTING SERVICE 91061 169 1 disapproval at this point in time for new landfills, 2 because EPA has no permitting program. They don't have 3 personnel, and it' s questionable whether they have 4 authority. 5 MS. HARBERT: I would like to ask if you're 6 taking these remediation plans back with you, how long 7 does this -- are you permitted to have them before you 8 make a decision? 9 MR. MOWRY: If we treat it as an amended 10 application, it's 180 days. If we treat it as a 11 remediation plan, there is really no statutory how long 12 it is, just a matter of how long it takes the staff 13 people to read the gist, comment, get information back. 14 It's apt to take a few months just as a remediation 15 plan. 16 MS. HARBERT: Thank you. 17 MR. HOBBS: If I may, just one, and this is 18 an important question that follows right after yours. 19 MS. HARBERT: All right. 20 MR. HOBBS : If there is no amendment -- 21 MS. HARBERT: Would you come to the mike 22 and state your name, please. 23 MR. HOBBS: Mr. Mowry , if there is no 24 amendment, no expansion, is it your testimony that you 25 currently have authority to require remediation of this BILLINGS REPORTING SERVICE 931061 170 1 landfill? 2 MR. MOWRY: Yes. 3 MS. HARBERT: Are there any other questions 4 of Mr. Mowry or the State Health Department? 5 If not, thank you very much for coming. We 6 appreciate your presence here. 7 I 'm sorry to keep reiterating, Come to the 8 microphone, but tape recorders do not have eyes and 9 they cannot tell always and, you know, all of you 10 are -- or those that have been legally involved in this 11 have listened to the tapes of the previous hearing in 12 1971 and, therefore, it's very important that you do 13 state your name when you come to the microphone. 14 I think we need a break. Can we take a 15 10-minute break? We will resume at 3 : 30. Thank you. 16 (Recess from 3 : 20 to 3 : 30) 17 MS. HARBERT: I have an announcement to 18 make. The final score was the Mets 3 and Rockies zero. 19 (Discussion off the record. ) 20 MS. HARBERT: Let' s see. Where were we? 21 Is there anyone else -- we are taking public 22 testimony. Is there anyone else who would like to 23 speak for or against the proposal before us? Would you 24 come to the microphone. 25 Oh, we have cards. Why don 't I just call BILLINGS REPORTING SERVICE 931%61 171 1 these? Would that be all right? 2 MS. HARBERT: What 's your name, sir? 3 MR. HAYES: Van Hayes. 4 MS. HARBERT: Would Clarence Kammerzell 5 take a seat right here in the front row and be ready to 6 speak. 7 Oh, Wait. He is against. 8 (Discussion off the record. ) 9 MR. HAYES: I hope that we 're not getting 10 out of context here. I am for the continuation of the 11 landfill, and I represent the group -- 12 MS. HARBERT: We need your name and address 13 for the record, please. 14 MR. HAYES: My name is Van Hayes. I 'm from 15 Saratoga, Wyoming. My wife is the former Ella Marie 16 Spomer. She and her sister, Susanne Stephens, are the 17 present owners of the Spomer place, which is adjacent 18 to the landfill on both sides, south and west. 19 We have better than a full mile of county 20 roads. They've been there since 1911, and I would say 21 we are the fourth generation on the place. 22 I have been associated with the farm myself 23 for more than 40 years and act as spokesman for the 24 families that I represent. The Spomer place, as I 25 said, surrounds the landfill on two sides, and we are BILLINGS REPORTING SERVICE 301961 172 1 the only owner on the south and the west sides. There 2 is no one else. 3 We have a full quarter mile on the south, 4 full quarter mile on the west. We are on the downslope 5 side all the way through. We are the ones most 6 directly and immediately affected by any contaminants 7 that might arise off the landfill. 8 The past landfill operations have not 9 allowed adequate space from the fill liquid, and they 10 are filled right up to the boundary lines. I 'm not 11 going to deny it. We sold this land or have a contract 12 to sell land to the landfill company. We are not going 13 to get rich on it. 14 But the thing here is, the way it is right 15 now, they need room to remediate any possible problems 16 that they have now or in the future. We have done 17 this, and it has allowed the landfill already to come 18 in and set down several new wells and monitoring sites 19 that they would not have been able to do if we had not 20 cooperated. 21 We have a contract on the place to sell a 22 buffer strip. That buffer strip does not allow -- the 23 contract does not allow any additional waste or any 24 waste at all to be placed in it. It is to be used only 25 for additional fill material to continue and complete BILLINGS REPORTING SERVICE 321061 173 1 operations. 2 As I stated earlier, we are the only ones 3 who are really in the immediate vicinity that is at 4 risk right now. I 'm not going to go into the past 5 history. I have it here. But I see no problem with 6 what's already been given. I 'm not going to go through 7 it again. 8 MS. HARBERT: We appreciate that. 9 MR. HAYES: Now, water from the Spomer 10 Lakes is being used to irrigate land we have below it 11 for the last, as long as as I can remember. It's my 12 wife's place. Our family feels some water 13 contamination has taken place and has occurred on the 14 farm. We have been assured by Waste Management that 15 that will be taken care of. 16 We also personally collected some water 17 samples last year and had them analyzed. Naturally, 18 they have not going into VOCs and heavy metals and so 19 forth. Agricultural labs don't do that. But the 20 report we have back indicates that the water was 21 satisfactory for both irrigation and for livestock 22 use. 23 Just last week my wife and I were up at the 24 lake. We saw a lot of birds, ducks, a pair of geese, a 25 lot of redwing blackbirds -- obviously, what this other BILLINGS REPORTING SERVICE 9.21061 174 1 gentleman said he saw up here. We also have fish in 2 the lake. There are fish in there. My son saw some 3 last year. That's not a dead lake, folks. 4 The Ashton-Daniels group now has focused 5 attention on possible pollution and they advocate 6 closing the landfill right now. They have given the 7 impression they speak for all the landowners in the 8 area. In reality, they only speak for a few. 9 We haven't had time to canvass all the 10 people in the area. But looking at the map here, you 11 can see where the site location is for the landfill . 12 The colored-in areas around it are areas that are 13 people that we have canvassed and talked with, that 14 they have no objection to the landfill continuing until 15 the proper time to close it. 16 Now, I think we passed to you folks last 17 week a pamphlet with a number of letters and some other 18 information on it. This map is in there. 19 Approximately 35 individuals within 2-1/2 miles of the 20 landfill were also named in there and have a vested 21 interest in land in the area. 22 Other issues now raised by the 23 Ashton-Daniels group and their associates indicates -- 24 includes the implication that local wells have been 25 contaminated and are no longer useable for human BILLINGS REPORTING SERVICE aa- 2,1061 175 1 consumption. Even wells as far away as two miles have 2 been alluded to as being undrinkable, unuseable, and 3 they are alluding to the landfill problem. 4 At our farm, which is just south, and in 5 that area, we have never, and I repeat never, been able 6 to drink the water from wells in that area. 40 years 7 ago, when I got married to my wife, and prior to that 8 as long as she can remember -- and that' s not just 9 yesterday -- now I 'm in trouble -- but they had Dan the 10 Water Man here in Greeley deliver water to cisterns. 11 Our neighbors did, too. 12 I can't say specifically how far and how 13 much country that covered, but I do know below that 14 landfill there, we never have had wells that we could 15 utilize, not for human consumption. 16 While we don 't approve of the 17 Ashton-Daniels methods, we do feel they have provided 18 a service by bringing this problem to the community. 19 However, their stated goal that appeared in their 20 January 15, 1993 , newsletter was, I quote, When we 21 first started this endeavor, all we really wanted was a 22 public hearing and the opportunity to be heard. 23 Unquote. 24 Their goal is being met today. Now, it 25 appears they are looking for larger and better things. BILLINGS REPORTING SERVICE 176 1 Although we originally opposed the CWSL, we must now 2 deal with present reality, folks. The mistakes of the 3 past are coming back to haunt us. 4 Closure at this time, I don't feel, is in 5 the best interest of the people of Weld County. 6 Premature closer sure will not allow Waste Management 7 any time and means for crowning that will allow proper 8 runoff from the landfill. 9 Proper crowning and sealing is absolutely 10 necessary. This will reduce infiltration, percolation 11 down through the soil, and trash, and reduce the 12 incidence of any runoff or leachates that might be down 13 there already coming in there, or compound it in the 14 future. Just placing a cap on a landfill is not going 15 to solve those problems. 16 As it stands right now, there are basically 17 level areas up there. There are rolling areas. It's 18 undulated. You fill those areas and leave it flat, and 19 you are going to get runoff, not coming. You are going 20 to get water running in, leaching in, soaking in. 21 I 'm now retired, and after 30 years with 22 the USDA Soil Conservation Service, I am a trained and 23 knowledgeable soil conservationist. 24 The way in which a landfill is closed and 25 when it' s closed will determine for many years what BILLINGS REPORTING SERVICE n ✓ _L19g1 177 1 problems we may determine or may have in the future. 2 My chief -- my family's chief concern with the 3 continued operation is the environmental and sound 4 closure, that CWSL is done properly. 5 We are concerned about scenic values, but 6 we are more concerned about the environmental issues at 7 stake. We believe that these environmental issues 8 affect our family more than anyone else in this room. 9 Our contacts with management and employees 10 of Waste Management have demonstrated to us a high 11 degree of professionalism and concern for the neighbors 12 and protection of the environment. They are the ones 13 that have the expertise and the ability to do the job 14 right. 15 We are convinced that Waste Management is 16 our best alternative. They can professionally operate 17 and at the proper time close the landfill in a safe and 18 professional manner. As a quick sidelight -- 19 basically, that' s my prepared notes, so I might make a 20 couple more quick thoughts here. 21 In a closing thought, we heard from the 22 attorneys, we've heard from just about everybody, it 23 seems like -- and I am sure everybody is getting 24 tired -- but who is responsible for monitoring a 25 landfill? BILLINGS REPORTING SERVICE 931061 178 1 21 years ago a decision was made to put it 2 in. You don't put the fox in charge of the henhouse. 3 Somebody dropped the ball . The gentleman that came up 4 with the water here a minute ago, obviously, he was 5 trespassing. We have never posted the place, but in 6 visiting with him here a little bit ago and trying to 7 determine where he picked that water up on the place, 8 he can't tell me. He doesn't know which pond it was 9 out of. 10 He says there was a light somewhere in 11 there. We don't have any lights on the post, not like 12 he's describing. He came in on a gravel or dirt road. 13 We are right on the pavement. The access to the place 14 is on the pavement. So I question, actually, if he 15 even knows where he got that from. 16 One other question I do have, and then I 17 will sit down. In the presentations, there is 18 ambiguity to me in terms of height above existing 19 terrain. On our place alone, we have better -- I 'd say 20 better than a 100-foot elevation in that half mile to 21 the west side. 22 Are you starting at the bottom of the 23 drainage, or are you starting at the top of the hill 24 for your original amount of fill you put in? There is 25 no defined notification of this anywhere. BILLINGS REPORTING SERVICE A 9fl061t 179 1 It seems to me that attorneys can argue, 2 that people can become emotional, but what 's the real 3 issue? The issue is what are we going to do with 4 what's happening now, not what happened 20 years ago. 5 What you folks do here today or tomorrow or the next 6 day, when you make your decision on whether you are 7 going to continue to allow the landfill to fill and 8 close properly, is going to determine what happens to 9 our place down there. 10 Is the County ready to clean it up? They 11 haven't done so in 20 years. They haven't monitored it 12 in 20 years. I know it's not your fault. But, again, 13 someone dropped the ball. 14 As far as some of these landfill papers, 15 recommendations from County, State, Federal Government, 16 it takes time to get things through the bureaucracy. 17 I 've worked in it for years. And I hope things will 18 move along so we can all have a decision on this in a 19 very short time. 20 Thank you for your attention. Do you have 21 any questions? 22 MS. HARBERT: Any questions for Mr. Hayes? 23 Thank you, Mr. Hayes. 24 Mr. Kammerzell? Or Mrs. Kammerzell. 25 Mrs. Florence Kammerzell . I apologize. BILLINGS REPORTING SERVICE 931061 180 1 (Off record comments. ) 2 MS. KAMMERZELL: I am Florence Kammerzell. 3 I guess I 'm the new kid on the block. We have only 4 been on our farm since 1963 . 5 Madam Chairman, County Commissioners, I 6 endorse what Mr. Van Hayes said. I swear he read my 7 notes. The only thing I want to endorse is that the 8 issue is like spilled milk. The 1971 engineering plans 9 and Mr. Moffat's plans are behind us. 10 That the landfill was used and operated 11 under poor County Commissioners ' judgment is not the 12 point today. By the way, who was the County attorney 13 at that time? Today's point is we do have a cleanup 14 job. Mr. Hayes ' graphic photographs endorse that, and 15 I agree. 16 May I address the Waste Management or the 17 Waste Services? Do I understand that Waste Management 18 is already making physical improvements to correct the 19 past 20 years and will continue to clean up the 20 problems and close the landfill in a proper and 21 ecological, fit manner? 22 UNIDENTIFIED PERSON: Yes. 23 MS. KAMMERZELL: Then I ask, do we of Weld 24 County, do you, the County Commissioners, plan to pay 25 for the cleanup if the landfill is closed? BILLINGS REPORTING SERVICE 931061 181 1 If pollutants are there, then I believe we 2 should let the Waste Management get on to the 3 commitment, according to Health and State regulations, 4 for our future protection. 5 Thank you. 6 MS. HARBERT: Thank you, Florence. 7 Fred Rehmer; is that correct? 8 UNIDENTIFIED PERSON: He had to leave. 9 MS. HARBERT: He had to leave, all right. 10 Some of you may not have chosen to speak, and that' s 11 fine. 12 Sharon Davis, you've already spoken; is 13 that correct? 14 MS. DAVIS: Yes. 15 MS. HARBERT: Diane McMullin? 16 MS. McMULLIN: I 'm against, not for. 17 That's written incorrectly. 18 My name is Diane McMullin. I live at 19 1012 Cranford Place. I am a student at UNC. And on 20 behalf of COPIRG, which is Colorado Public Interest 21 Research Group, the University of Northern Colorado 22 Chapter of COPIRG supports the efforts of the Colorado 23 residents concerned over water. 24 The issues being discussed today concerning 25 the Central Weld Sanitary Landfill are more the rule BILLINGS REPORTING SERVICE 9. 1961 182 1 than the exception to landfills around the state. 2 According to information released by the United States 3 Public Interest Research Group and COPIRG, more than 4 half the landfills in the state will close within five 5 years because they cannot meet Federal RCRA standards. 6 Environmental and health problems 7 surrounding unlined and unregulated lakes concern 8 COPIRG, and COPIRG sees the need to clean up landfills 9 that are hazardous to the land and people around them. 10 Thank you. 11 MS. HARBERT: Thank you. 12 The court reporter has asked that anyone 13 that reads a prepared statement give a copy of it to 14 her with your name on it. It makes it easier for her 15 to transcribe it later on. 16 If you have a prepared statement and would 17 bring it up to her, we would appreciate it. If you 18 want it back, make a note on it that you want it back, 19 and she will see that you get it returned. Thank you. 20 Dr. Ray Knapp? 21 Would June Kane, if you are in the 22 audience, would you be prepared to be next, please. 23 DR. KNAPP: I 'm Ray Knapp. I am live at 24 5960 - 37th Street. I have been living there for 25 26 years. When the landfill first opened up there, I BILLINGS REPORTING SERVICE 331061 183 1 was really quite supportive of it, because it was close 2 to only three miles from where I lived and it seemed to 3 be a much better location than the previous dumps. 4 Back in 1966, when I first came here, we 5 were taking our tin cans and bottles -- at that time 6 you didn't take all your trash to the dump, but we took 7 them to the dump by Kersey, and it was dumped in a pit 8 right close to the river, just like right on the flood 9 plain. 10 The second dump site that we took it to was 11 down in Evans, again right near the river. I thought 12 these were just horrible places to be dumping trash. 13 So this seemed to be a much better place. It was 14 located higher, a little bit farther away from the 15 river. 16 I 've been hauling my own trash to the dump 17 for all these 26 years. I have a little 4-by-7 foot 18 trailer. The most that Weld County landfill ever 19 charged me for taking my trash to the dump was $7. 00. 20 But then we had a change of management; Waste 21 Management came in. I found out they wanted $18.50. 22 Mr. Butler says Waste Management wants to 23 be neighborly. I don't know if that' s a very 24 neighborly thing to increase the fees on a neighbor by 25 200 percent. I got to thinking, maybe a lot of people, BILLINGS REPORTING SERVICE 331061 ' 184 1 rather than taking their trash to the dump and paying 2 those high rates, will say, Hey, maybe some other place 3 I can just dump it alongside of the road. 4 So I think that 's an issue which we haven't 5 really thought about, these high rates they are going 6 to be charging. It seems like they are not only -- 7 well, I walked out there and found at their gate they 8 have actually raised their rates, so now it will cost 9 me $20 for my little trailerload of trash. 10 I guess over the years that I 've been 11 there, I live on this major route -- there's two major 12 routes going from the city of Greeley out to the dump. 13 My 37th Street is one of them, and I have been picking 14 up trash for years. 15 I mean, it' s all kinds of trash, old 16 furniture, limbs are dropped off loads. I do know that 17 the landfill has a sign up there saying, If you bring 18 an uncovered load, we will charge you more, but it 's 19 been very ineffective. We still have a tremendous 20 amount of trash being dumped. 21 If the Waste Management was really 22 neighborly, I think they would be patrolling these 23 major routes and picking up this trash that their 24 customers dropped off their loads. That ' s really -- 25 one other thing I might say. BILLINGS REPORTING SERVICE 931061 185 1 I was looking around for another place to 2 take my trash last January, and so I wound up way down 3 at Erie, that landfill, and that was really an eye 4 opening for me. I drove in there, and there was this 5 huge, great big pit down there, very deep, had a large 6 capacity, and it was lined. It opened up my eyes to 7 what a landfill should really look like. 8 I said, Well, this is such an improvement 9 over what we have here in Central Weld County. Why 10 can't we have this kind of a dump to take our trash 11 to? So I really think we have to look at the broad 12 issue. 13 And it sort of irked me this morning when 14 I heard the people from Waste Management trying to 15 grandfather themselves into this process. I think back 16 in the 1960s, early 1970s, we weren't very much 17 environmentally aware as we are today. They are more 18 sophisticated, and we shouldn't accept the conditions 19 that were laid down 22 years ago for the operation of 20 10 or 15 years. 21 Well, that' s my statement. Thank you. 22 MS. HARBERT: Are there any questions for 23 Dr. Knapp? 24 I have one. How much did it cost you to 25 take your trash to Erie? BILLINGS REPORTING SERVICE 31.06 186 1 DR. KNAPP: It's $11. 00. 2 MS. HARBERT: Thank you. 3 DR. KNAPP: So it was a bit cheaper. 4 MS. KIRKMEYER: Plus gas? 5 MS. HARBERT: Plus your gas. 6 DR. KNAPP: Plus my gas. I don't like to 7 drive that far, but . . . 8 Maybe I ' ll find another place. But it 9 seems like Waste Management will be taking over every 10 dump and will have a monopoly and they can raise the 11 rates as high as they want to. 12 MS. HARBERT: Thank you. Are there any 13 other questions. 14 June Kane? 15 Ella Marie Hayes, would you be the next to 16 speak, please. 17 MS. KANE: My name is June Kane. I live at 18 712 - 14th Avenue. Madam Chairperson and 19 Commissioners, my comments will be brief and I hope 20 pertinent to your mission. 21 I represent today the Greeley Audubon 22 Society and its 220 members throughout Weld County. 23 Our goals are to share our pleasure in the natural 24 world and to encourage healthy, life-supporting 25 surroundings for all creatures. BILLINGS REPORTING SERVICE 91061 187 1 We are here to listen and to learn. We do 2 question what effect a much larger landfill operating 3 for many more years might have on the nearby Big 4 Thompson River. We hope this hearing will clarify the 5 condition of groundwaters and of the river water both 6 now and in some future projection. 7 On our field trips to the area and river, 8 we see a variety of animals and birds, including our 9 great national bird, bald eagles, whose main food is 10 fish from rivers. We must keep our waterways as pure 11 as possible for ourselves and for wildlife. 12 Businesses that bring money to the 13 community must not receive greater consideration than 14 the health and well-being of people and wildlife. If 15 there has been a lack of consistent, orderly monitoring 16 of this operation under an approved design and 17 operations plan, then it is the duty of the County and 18 State to take action. 19 Waste Management, probably the largest 20 disposal business in the United States, reportedly 21 takes in 4 billion dollars a year. If the company 22 inherited problems at the site, we assume it is willing 23 to help rectify past mistakes and oversights to bring 24 this landfill in line with the best available 25 practices. BILLINGS REPORTING SERVICE 188 1 Also, is waste being trucked into this 2 landfill from other counties and states? We are told 3 there is a recycling program at the landfill and we 4 commend the owners for this. 5 You commissioners are charged with 6 promoting a healthy economic environment which need not 7 be inconsistent with a healthy natural environment. We 8 commend the Ashton-Daniels Neighborhood Action Group 9 for alerting the community to this matter, and we thank 10 all participants in this hearing. 11 Thank you. 12 MS. HARBERT: Thank you. 13 Ella Marie Hayes. And then Jon Stephens. 14 MS. HAYES: Madam Chairman, Members of the 15 Board, I 'm Ella Marie Hayes from Saratoga, Wyoming, and 16 I am a Spomer. My sister, Susanne Spomer Stephens, and 17 I are the property owners directly south of the 18 landfill . 19 My husband spoke for us, and I believe he 20 basically covered everything that I needed to say, and 21 Florence Kammerzell also did say some things. I just 22 had a couple of points I wanted to make. 23 The gentleman that brought the black water 24 up, number one, obviously, trespassing on our land, and 25 this, if the term radical was used -- and I might have BILLINGS REPORTING SERVICE 8C1061. 189 1 been the one guilty of using the term radical -- I was 2 not referring to being environmentally open, because 3 I 'm an environmentalist myself. What I was referring 4 to were the methods that have been used. This was not 5 a very scientific method. 6 I recall as a child -- and that 's obviously 7 before the landfill went in -- we began to -- we begged 8 and pestered our parents to go swim in the lake. 9 Within a few minutes of being in that lake, we emerged 10 covered with black muck. We never were allowed to go 11 swim in that lake again. 12 So I don't think that was a very scientific 13 exhibit. And this is the thing that we have objected 14 to. So many of the exhibits are taken out of context. 15 Are they really valid? 16 And we are not here today to decide whether 17 1991 (sic) was correct. I think we all agree it 18 wasn't. We don't understand why it wasn 't put in 19 writing. We all know today written agreements. 20 We are here to decide what we are going to 21 do in 1993 to determine the best future for ourselves 22 and our next generation. And we do feel that Waste 23 Management has already made a commitment, they've 24 already started, and we do feel that they are the ones 25 that can go forward and clean up this. BILLINGS REPORTING SERVICE 9:1061 190 1 And I do think that the Ashton-Daniels 2 group still has a role to play. Keep watch. And 3 everyone can do this. But I still believe Waste 4 Management is the way to go, and we would like to see 5 them be able to continue operation. 6 Thank you. 7 MS. HARBERT: Mr. Stephens. 8 MR. STEPHENS: Chairperson Harbert and 9 Commissioners, my name is Jon Stephens, Stove Prairie, 10 Colorado. I would like to say that I agree with Van 11 Hayes and the others that have spoken as far as the 12 best future for the Central Weld County Landfill. 13 What I would like to urge is now a spirit 14 of cooperation between the Commissioners, the County 15 Health Department, the State Health Department, Waste 16 Management, to solve this problem. This is not going 17 to go away by our meeting here today. 18 That problem is sitting out there festering 19 right now while we talk. And the only way we are going 20 to be able to solve that problem is technology, 21 financial capability, and the determination and the 22 oversight provided by the State and County officials to 23 make sure that it' s done. 24 Thank you. Do you have any questions? 25 MS. HARBERT: Do you have any questions of BILLINGS REPORTING SERVICE 9C1n61 191 1 Mr. Stephens? 2 MR. STEPHENS: Thank you. 3 MS. HARBERT: Thank you. 4 Susanne Stephens. 5 MS. STEPHENS: Madam Chairperson and County 6 Commissioners, I 'm the other half of the Spomer 7 landowners, and I think everyone in my family has just 8 spoken and given me -- said everything that I feel in 9 my heart. And I think we have to not concentrate on 10 1971; it' s 1993 . We have to go forward. We have to 11 have this problem corrected. 12 And, again, Waste Management is the company 13 that has the expertise and the finances to do it. Does 14 the County? Does the State? And I think they are 15 committed, and with all of us cooperating, it will be 16 done. 17 And I thank you. 18 MS. HARBERT: Thank you. 19 (Discussion off the record. ) 20 Did you not say your name? 21 MR. WEBSTER: You said you are related. 22 MS. STEPHENS: I 'm sorry. I 'm Susanne 23 Spomer Stephens. I 'm sorry. 24 MS. HARBERT: I have a Bradley Carver. 25 MR. CARVER: Yes. I 'm here to speak on BILLINGS REPORTING SERVICE 3:1061 192 1 behalf -- 2 MS. HARBERT: Would you state your name. 3 MR. CARVER: My name is Bradley Carver. I 'm 4 the board chair for the Colorado Public Interest 5 Research Group, and I am just here to speak on behalf 6 the University of Northern Colorado. We fully support 7 the efforts to close and clean up the Central Weld 8 Sanitary Landfill for the following reasons -- and just 9 forgive me. I 'm just going to read the statement, due 10 to brevity. 11 According to estimates by the Environmental 12 Protection Agency, 50 percent of Colorado' s landfills 13 will close in the next five to eight years because they 14 cannot meet Federal health and safety laws. By these 15 standards, the Central Weld Landfill is certainly not 16 the exception, rather the rule. 17 As an unlined facility located in a major 18 drainage basin, and having accepted several forms of 19 unacceptable waste, this landfill cannot meet the 20 standards necessary to ensure public health and safety. 21 In addition, the cost of cleaning up a 22 100-acre landfill in Colorado to meet with Federal 23 regulations would be approximately $65 million. Rather 24 than extending the life of this unsafe landfill for 25 another decade and escalating the costs of its eventual BILLINGS REPORTING SERVICE 931061 _ 193 1 cleanup, we at COPIRG feel the resources must be 2 focused on closing the site and cleaning it up now. 3 In addition, the development of effective 4 recycling programs, from collection to processing, to 5 purchasing, must be implemented to divert trash from 6 the waste stream and extend the lives of the truly safe 7 and sanitary landfills already in operation today, such 8 as the facility located near Ault, Colorado. 9 Thank you. 10 MS. HARBERT: Thank you. 11 J.B. Merrell. 12 MR. MERRELL: Thank you. My name is J.B. 13 Merrell. I live on East 18th, and I am representing 14 Bunting Trash Service today. I am not representing our 15 over 7, 000 customers, but I would like to think that we 16 are speaking in their best interests. 17 We know all about the increase in the 18 landfill rates, and we can empathize, too, with the 19 good doctor, what he has had to bear in increased 20 rates. However, we are against an immediate closing of 21 the landfill. 22 We, too, would like to believe the best 23 about Waste Management and their ability to close the 24 landfill properly. If the landfill were closed 25 immediately, that drastically changes our mode of BILLINGS REPORTING SERVICE 30106a 194 1 operations and where we have to dump all of our 2 customers' trash, which is going to be in the Ault 3 area. 4 That is going to increase our overhead, and 5 as water trickles down, we would like to think the best 6 about our ability to control that and not pass that 7 increase to our customers, but that could very much be 8 a reality. 9 So we are in favor of a closing, the 10 inevitable closing of this landfill, but not an 11 immediate closing, and we would like to think that our 12 position is in the best interest of over 7 , 000 business 13 and private consumers. 14 Thank you. 15 MS. HARBERT: Thank you. 16 That 's all the cards I have. Is there 17 anyone else who would like to speak for or against? 18 MS. KAMMERZELL: I have a postscript. 19 MS. HARBERT: We don't usually allow that. 20 Just this one. 21 MS. KAMMERZELL: This is Florence 22 Kammerzell. I did want to emphasize our farm was on 23 the map. We are about a mile and a half north of the 24 landfill, so, therefore, our water table is much higher 25 than the Thompson drainage. We have never been able to BILLINGS REPORTING SERVICE 301064 195 1 drill a well for water consumption due to the high 2 mineral content, hard water. 3 MS. HARBERT: Is there anyone else who 4 would like to speak for or against? 5 State your name, please. 6 MR. DANIELS: Tom Daniels. I live at 7 2732 Weld County Road 27-1/2, Milliken. I 'm worried 8 about what is in the landfill . Waste Management 9 collects or samples and sends them to their labs. Then 10 they send a report to the Health Department. I 'd feel 11 safer if the Health Department took samples and did 12 testing in their lab. 13 For four generations we have lived by the 14 Big Thompson. I 'd like to have my family here, but I 'm 15 scared of what I see in the ditches. I want future 16 generations to be able to live by the Big Thompson and 17 have a good life like everyone deserves. 18 Please help my generation' s dreams come 19 true by closing the landfill . Thank you. 20 MS. HARBERT: Thank you. 21 Is there anyone else that would like to 22 speak for or against? 23 Come forward, please. If you have not 24 spoken before, come forward and state your name and 25 address for the record. BILLINGS REPORTING SERVICE 9:1061 196 1 MS. CHENEY: I am Kay Cheney. I am a 2 member of the Greeley Audubon Society and I live out in 3 Weld County, 52230 Weld County Road 149 . 4 And I would like an answer to a question, 5 if possible. Are we getting a lot of truckloads coming 6 into the landfill from other counties and from other 7 states? 8 MS. HARBERT: I 'm not sure that really 9 concerns our question today, but we' ll see that Waste 10 Management answers that when the time comes. 11 MR. ROY: The answer is no. The short 12 answer is no. 13 MS. CHENEY: Thank you. 14 MS. HARBERT: Is there anyone else who has 15 not spoken who would like to speak for or against the 16 probable cause hearing -- the show cause hearing? 17 Hearing none, Waste Management, we will 18 give you the floor to rebut. We are now closing the 19 public hearing part, portion of this hearing, the 20 public input of this hearing. 21 MR. ROY: Am I to understand I 'm last? 22 MS. HARBERT: You are last, sir, thank 23 goodness. 24 MR. ROY: Good. First, to address the 25 questions from the neighborhood that were proposed in BILLINGS REPORTING SERVICE 921061 197 1 writing through the County Attorney. 2 MS. HARBERT: We don't have those 3 questions. 4 MR. ROY: I ' ll read you the questions and 5 give you the answers. 6 MS. HARBERT: All right. Thank you. 7 MR. ROY: The first question is -- and 8 they weren't numbered, so I ' ll say it' s the first 9 question -- Waste Services, Inc. and Waste Management, 10 Inc. , where are your other landfills in Weld County and 11 Colorado? 12 I didn't see the tag to that about 13 Colorado. There are two other landfills operated by 14 Waste Services or Waste Management in Weld County. One 15 is on Highway 14 east of -- or correction -- west of 16 Ault, Colorado, approximately 25 miles from Greeley. 17 The other is located near Keenesburg, was recently 18 certificated, is not open, and probably will not be 19 open for a year, and is substantially further away from 20 Greeley than is the facility near Ault. 21 Second question is -- and there are others 22 in Colorado, I think down further south -- What is the 23 expected life of your other facilities in Weld County 24 and the state of Colorado? 25 Again addressing the Weld County BILLINGS REPORTING SERVICE a146t 198 1 facilities, both are anticipated to have a life of 2 30-plus years. That estimate obviously contemplates 3 Central Weld remaining open for a while, and so those 4 lives may be somewhat shortened, if Central Weld were 5 closed. 6 Third, if Central Weld Landfill is closed, 7 is there capacity available in or in the near term to 8 take solid waste in Weld County? 9 The obvious answer is yes, but not without 10 expense, and not without two kinds of expense and 11 costs. One is the obvious increased cost of 12 transportation for the major metropolitan area in Weld 13 County, which is Greeley and its environs, to a solid 14 waste disposal site. And that' s already been alluded 15 to by one of the witnesses. 16 Also included, or should be calculated, is 17 environmental costs of transporting that waste that 18 distance, heavy trucks operating over a much larger 19 distance, consuming much more fuel, having an impact on 20 the air far in excess of what is now the case. 21 And there is a third and perhaps more 22 indirect impact that Dr. Knapp, perhaps inadvertently, 23 referred to. And that is when he said, Perhaps I ' ll 24 find a better place. He had driven down to Laidlaw, 25 which is, I think, 30 miles. He says he will find a BILLINGS REPORTING SERVICE n 199 1 better place. 2 I suggest many others will find a better 3 place and leave it in the borrow pits around the county 4 rather than drive to Ault or Laidlaw or drive to 5 Keenesburg, and that is an environmental impact you can 6 almost be assured will occur if the availability of 7 safe disposal becomes more inconvenient to the 8 consuming public. 9 The licensed carriers, obviously, will have 10 to abide by those rules, but the private people like 11 Dr. Knapp might find a, quote, better place. 12 Questions were addressed basically to Brad 13 Keirnes, the second group of questions. What are the 14 dates of his family ownership of the landfill? 15 His family ownership of the landfill or the 16 ownership of the landfill by corporations which his 17 family controlled commenced in June of 1979 and 18 terminated in July of 1991. 19 Did his family file an engineering report 20 and design and operations plan with the State of 21 Colorado Department of Health for its approval? 22 I think the answer is that they did not 23 file any document bearing that name. They filed a 24 large number of documents with the Department of 25 Health, some of which were prepared by engineers who BILLINGS REPORTING SERVICE nsos 1 200 1 were consulting engineers to them, dealing with the 2 operation of the landfill. Whether those constitute, 3 in collection, such a document, I don't know. 4 But suffice it to say, during their 5 ownership they were in fairly constant contact and 6 worked with the Colorado Department of Health. 7 Was there an engineering report and design 8 and operations plan submitted to the State Department 9 of Health for its approval by those who owned and 10 operated the landfill prior to his family ownership? 11 Well, whoever wrote the question knows that 12 Mr. Keirnes can't answer that question. He wasn't 13 there. Any answer he would give would be speculative. 14 There is allusion in the letter submitted by counsel 15 that there was one. The -- when the landfill was 16 transferred, it alluded to one. The State Department 17 of Public Health can't find one now. That doesn't mean 18 there was not one. We will get back to that discussion 19 later. 20 Was there an engineering -- last question, 21 I believe -- was an engineering report and design and 22 operation plan in existence at the time the ownership 23 was transferred to Waste Services? 24 We don't know. The only allusion to the 25 existence of one is the letter by the State Department BILLINGS REPORTING SERVICE 921061 201 1 of Health, which indicated there, in fact, was one. 2 Now, rebuttals are always disorganized 3 because you jump from subject to subject, and I 4 apologize for it being -- perhaps jumping around. And 5 my clients -- and there are 12 of them here -- all have 6 ideas of what I should say, and have all bit my ears 7 about what I should say, and I probably won't satisfy 8 any of them with what I 'm going to say, but I ' ll try to 9 go through everything that ' s been said and try to 10 respond to it in some order. 11 Mr. Hayes got up and distributed or showed 12 some picture on the view graph, as I recall, of some 13 dead animals in the landfill, and alluded that those 14 pictures were taken very recently, I think as early as 15 last weekend, or as recently as last weekend. 16 According to the exhibit prepared by the 17 Ashton-Daniels neighborhood and submitted to you as 18 Exhibit AD-46, those same pictures would show the ears 19 of the dead animals were taken in January of 1992 . 20 Now, either Mr. Hayes is mistaken or I misunderstood 21 what he said, or the exhibit is wrong. 22 The pictures were, in fact, taken in 23 January of '92 . They were taken at a time when the 24 landfill was experimenting with this plastic cover, 25 temporary cover, which I don't believe is still in use. BILLINGS REPORTING SERVICE vsns• 202 1 And there is no reason to believe the pictures don't 2 accurately depict what was there at the time they were 3 taken. 4 There are some pictures that were taken in 5 '93 in the exhibit that show trash and the fences and 6 show the operation, and those pictures that were 7 taken in March of '93 , you can review on your own time, 8 are not all that objectionable and indicate that the 9 operation is being operated reasonably well , 10 considering the type of operation it is. 11 They -- he alluded to a fire that burned 12 some of the family crop. That was in the paper, 13 newspaper article about that fire, is in your 14 exhibits. That fire was not caused by the landfill as 15 a landfill. That fire was caused when -- I think it 16 was Mr. Len Keirnes was doing some weed burning, which 17 everybody does. 18 And to my knowledge, in the county, there 19 are at least three or four traffic accidents a year 20 attributed to weed burning along the roads. Weed 21 burning sometimes gets out of control and damages 22 things. That weed burning did get out of control and 23 damaged the crop, and the Telep family, I understand, 24 was fully compensated for that damage. 25 I get the impression from hearing a lot of BILLINGS REPORTING SERVICE 931061 203 1 people in the neighborhood -- and I might add that 2 includes people who have generally spoken in favor of 3 Waste Services -- that they don't like landfills. They 4 don't like a landfill in their neighborhood. 5 They basically take two approaches to that, 6 however. One group says, Close it. One group says, Be 7 careful. One group says, Let's be orderly, let's be 8 responsible, let' s close it in an orderly fashion. 9 I would submit neither one of those groups, 10 if you were to have an application for a landfill, 11 would come in here and do handstands. But there really 12 are two approaches. One, I submit, is irresponsible, 13 and one is not. 14 And those suggested by the Spomers and 15 others who, in fact, live downstream or downgradient 16 happen to be the more responsible response. 17 Counsel made a lot of arguments to you 18 about the impact or failure to have a design and 19 operations plan. Now -- and essentially argues that 20 this landfill has been void, ab initio, been void since 21 it started, okay, because there is no design and 22 operations plan. Never was one, according to him. I 23 don't think that' s the law. 24 Another thing I would tell you is that you 25 have an attorney sitting with you, and you have an BILLINGS REPORTING SERVICE ; 2106 204 1 attorney sitting with you and he has a bunch more 2 upstairs, and they know the law. And I am sure you 3 will get your advice from them, and I would recommend 4 you do so. 5 So the arguments I make or the arguments 6 that counsel for the neighborhood make will ultimately 7 be deciphered by Mr. Morrison, and he will tell you 8 what you can and cannot do with respect to these 9 proceedings. 10 I ' ll submit to you that the administrative 11 proceedings that took place in 1971 are entitled to a 12 presumption of regularity. That presumption carries 13 until a substantial body of evidence to the contrary is 14 presented. You cannot prove a negative. 15 The certificate of designation was issued. 16 It was issued in October of 1971, after a hearing held 17 in September of 1971. The resolution was prepared and 18 signed by the County Commissioners on the same date. 19 That certificate of designation and that use permit has 20 been in continuous use for over 20 years. It has been 21 back before this body on at least five occasions. 22 No one has questioned the validity of that 23 certificate of designation, and nobody has questioned 24 the validity of this land use in all of these years. 25 And I would submit to do so now and to use that as a BILLINGS REPORTING SERVICE 9:1061 205 1 precursor for shutting the landfill is wrong legally, 2 and it's wrong morally, and it' s wrong ethically. 3 The statements made by the presenters at 4 the meeting in 1971 do not constitute a condition. 5 The conditions are in the resolution. The fact that 6 someone said they were going to grade it a certain way, 7 the fact they thought it might be used for an irrigated 8 farm, the fact they thought it might close in 15 years, 9 all of those things are statements made in a hearing. 10 They are not conditions on the use of this land. The 11 conditions are contained in the resolution. 12 And if you are not convinced of that, if 13 you are not convinced about the attitude of the Weld 14 County Commissioners in 1971, bless them, I commend 15 to you to read the letter of Ralph Waldo dated 16 December 14 , 1971, addressed to his clients. He 17 appeared at the hearing in 1971. He represented the 18 opposition to the landfill . 19 On December 14, 1971, he wrote a letter to 20 his clients and said, I have tried to get the County 21 Commissioners to put conditions on this operation. 22 They refuse. Now, it wasn't like they weren't 23 approached to put conditions on. It was not as if 24 conditions weren't suggested. They were. 25 What came out of that is the resolution BILLINGS REPORTING SERVICE 831.06't 206 1 that's before you. It contains no conditions, save 2 the two. Courts do not apply laws retroactively. 3 Administrative agencies do not apply laws 4 retroactively. 5 Mr. Mowry stated he can't give a legal 6 opinion. He gave an opinion in a letter to the 7 neighborhood counsel this year that this landfill was 8 grandfathered. 9 MR. HOBBS: Objection. He did not. I 10 would like to respond to that. 11 MR. ROY: The letter was from Mr. Austin 12 Buckingham to Mr. Hanson, not Mr. Mowry. I stand 13 corrected, and I apologize. 14 MR. HOBBS: I would like to explain. 15 MR. ROY: If that didn't grandfather it, 16 the legislation in 1991 did. There is no ambiguity in 17 the permit, so one need not look for an ambiguity. 18 The neighborhood would like you to revisit 19 1971. They would like you to rehear this application 20 20 years later. You cannot do that. At that hearing, 21 a representative of the State Department of Health 22 recommended approval. His -- the text of his remarks 23 are before you two or three times over. You can read 24 it. 25 A great deal has been said about an BILLINGS REPORTING SERVICE 93106a 207 1 expansion proposal. The proposal that' s before you is 2 not an expansion proposal. I have not studied it in 3 detail. My clients advise me it is, in fact, a 4 reduction over what could be done on that site as it's 5 presently certificated. 6 There has been a lot of argument by counsel 7 that we are seeking to avoid enforcement of Subtitle D. 8 The contrary is true. If we wanted to avoid the impact 9 of Subtitle D, we would close the landfill now under 10 State regulations, close it with the remedial action 11 required by the State. 12 Those requirements and regulations are 13 substantially below those which we will face if the 14 landfill remains open after October of 1993 and 15 Subtitle D comes into effect. 16 There are lots of other things that are 17 missing if we close it before Subtitle D comes into 18 effect. Financial assurance is missing. Financial 19 post-closure care is omitted. All of those things, 20 this operator is not trying to avoid; he is, indeed, 21 willing and able to undertake. 22 As a matter of fact, in meetings with my 23 clients, I asked them, Why don't you just close it? I 24 mean, there are business reasons for keeping it open, 25 obviously. Why not close it? Then you don't have to BILLINGS REPORTING SERVICE 3:1061 208 1 put up money to financially ensure 30 years of 2 post-closure maintenance. You don't have to do 3 remedial action for the next 30 years and guarantee it 4 financially. You can close in accordance with the 5 existing regulations, which is cheaper and has a lot 6 less exposure. 7 They would prefer to continue to operate 8 it. They would prefer to be responsible. They would 9 prefer to close it in due course. They would prefer 10 to close it in accordance with the most modern 11 restrictions and regulations, and not those currently 12 in effect. 13 The allusion was made that we would like to 14 avoid a public hearing and we did so in the SFLIC case 15 and, therefore, we've got some sort of hidden agenda 16 and are trying to pull the wool over your eyes. 17 I don't think anybody in Waste Management 18 underestimates your sophistication or underestimates 19 your ability to require us to meet whatever 20 requirements there are. And we are certainly not 21 trying to pull the wool over your eyes and have no 22 hidden agendas that have not already been disclosed, 23 including what happened in the FSLIC case. 24 Mr. Megyesy is here, was counsel to Waste 25 Management in that case. He advises me in that case BILLINGS REPORTING SERVICE 1 J1 i1 0cc t 4 209 1 Arapahoe County didn't want to have a public hearing. 2 The County Commissioners did not want a hearing, and 3 the issue was, Was a hearing required, and the answer 4 was, No, it was not. And Waste Management in that case 5 aligned itself with the Arapahoe County Commissioners. 6 Had the Arapahoe County Commissioners 7 wanted a public hearing, Waste Services would have been 8 there, or Waste Management would have been there. It 9 was the commissioners who did not want a hearing. 10 The question or the issue has been 11 addressed that this landfill cannot comply with 12 Subtitle D -- and this is by the university students -- 13 cannot comply. Umpteen landfills are going to close in 14 the next five years because they can not comply. Waste 15 Management believes this landfill can comply. Waste 16 Management believes this landfill will comply. 17 Waste Management is willing to put its 18 money where its mouth is and make it comply. And I 19 would suggest to you that that is better for the 20 neighborhood than the alternatives which have been 21 suggested. 22 If the landfill is continued, permitted to 23 continue to operate, you will have closure with four 24 feet of cover, compacted in accordance with Federal 25 standards, raised according to Federal standards, BILLINGS REPORTING SERVICE 9:31.06° 210 1 permitability in accordance with Federal standards of 2 the cap. You will have post-closure maintenance, and 3 you will have financial assurance of closure, 4 post-closure and corrective action. 5 You will have remedial action by the 6 operator for the existing problems. And you will have 7 Subtitle D compliance, in all its glory. A lot of 8 people have talked to you today who inherited their 9 land or received their land, one or another, through 10 their families. I suggest we do not inherit the land 11 from our parents. We hold the land in trust for our 12 children. 13 To shut this landfill down in its present 14 condition violates that trust. You have -- and your 15 counsel will advise you as to what your alternatives 16 are -- you have the right to not find probable cause, 17 which we believe has not been shown. 18 You can continue these proceedings until 19 some other time in the future, after you have had a 20 chance to review the plans that have been submitted to 21 you. But even if you find a violation has occurred, I 22 would commend you to the language of the regulations 23 and to the statement of your counsel when this started, 24 Does the violation warrant a show cause hearing? Do 25 the violations you've heard warrant a show cause BILLINGS REPORTING SERVICE :1061 211 1 hearing? 2 I suggest they don't, even if you find them 3 to exist. You are not locked into a show cause hearing 4 by virtue of having this hearing. Your flexibility is 5 significant. And we would suggest, A, there is no 6 evidence to support probable cause. 7 We would suggest, two, all the evidence 8 that might suggest probable cause, we produced, we 9 voluntarily disclosed, and made available to all other 10 relevant officials. And three, if you think there was 11 evidence for probable cause, you have many options 12 short of a show cause hearing, and we would suggest 13 that you exercise one or more of those options. 14 Do you have any questions? Sorry to ramble 15 and skip around. 16 MS. HARBERT: Are there any questions for 17 Mr. Roy? 18 I guess I have a question, and that is, 19 in -- we have not seen your remediation plan, had the 20 chance to look it over. 21 MR. ROY: I understand that. 22 MS. HARBERT: How long a period of time 23 would it take to do whatever is in the remediation 24 plan? What time period is considered in that? 25 MR. BUTLER: The pilot scale proposed will BILLINGS REPORTING SERVICE 8:1061 212 1 take between four to six months as addressed in our 2 remediation measures. Once that pilot test is done, we 3 will evaluate the success of it and then determine how 4 to expand it and what additional time will be needed 5 for additional cleanup along that very small area south 6 of the current landfill. 7 MS. HARBERT: And what constitutes this 8 pilot program? I mean, you can't go into detail, I 9 realize, but what are you going to do to put this pilot 10 program into operation? 11 MR. BUTLER: What we are going to do is 12 install a technique we discussed earlier today, called 13 air sparging. 14 MS. HARBERT: All right. 15 MR. BUTLER: This involves putting in a 16 well where we inject air into the shallow groundwater. 17 We funnel it in. We have monitoring wells that will be 18 installed, or use existing ones to measure its 19 effectiveness. We will be taking monitoring data and 20 will be monitoring not only water quality, but the 21 equipment that's bubbling in, what the rates are, 22 pressures, what works, what doesn't work with that 23 particular aquifer's characteristics. 24 MS. HARBERT: Is that basically what you 25 described this morning is your pilot plan? BILLINGS REPORTING SERVICE .92)1061in61 213 1 MR. BUTLER: Yes, ma'am 2 MS. HARBERT: Okay. 3 MR. ROY: There is a second aspect of that, 4 and that is the improvement of the drains north of the 5 site. 6 Leonard, do you know how the drains north 7 of the site are reduced to lower the ground table, when 8 those can or will be installed? 9 MR. BUTLER: The second part, in the 10 interim measures that 's addressed specifically in the 11 development plan, is the enhancement of the French 12 drain. That work, as proposed in our amended 13 application, would presumably be worked through review 14 by the Weld County Health Department, State Health 15 Department. 16 Depending upon that review and that 17 process, we would be prepared to do it at the 18 appropriate time. If we could get through it early, we 19 would like to do it this summer. If we have to go 20 through what I believe is, as Glen Mowry indicated 21 earlier a 180-day process, because of weather and other 22 constraints, it may be ' 94 before it can be put in. 23 MS. HARBERT: Okay. Lee, I have a question 24 for you, and that is, Do we have a letter of credit or 25 any financial surety right now, that the landfill would BILLINGS REPORTING SERVICE S12;1061 214 1 be closed properly? 2 MR. MORRISON: No. The current Federal 3 Subtitle D regulations and proposed regulations -- and 4 our two or three most recent permits all have those 5 provisions -- but this site and others of its era do 6 not. And the closure provisions under existing State 7 regulations are fairly short, nonspecific as to how a 8 closure is to occur. 9 MS. HARBERT: Okay. I guess what my 10 question is, is if we found them in violation at a show 11 cause hearing, who would bear the expense of cleaning 12 up the landfill? 13 MR. MORRISON: Well -- 14 MS. HARBERT: I mean -- 15 MR. MORRISON: Well , I think our position 16 would be they would still be bearing the expense. 17 However, to some extent, it depends on whether this 18 stays as a solid waste site or if it is categorized as 19 a CERCLIS cleanup site. It changes the rules for under 20 which responsible parties my have to contribute to the 21 cleanup. 22 So I don't think in either case that they 23 lose their responsibility. But current regulations, in 24 terms of how it' s cleaned up, if it 's under the solid 25 waste regulations, are very sketchy. BILLINGS REPORTING SERVICE W y1�6" 215 1 MS. HARBERT: Thank you. Are there any 2 other questions? 3 MR. BAXTER: Just a follow-up on that. 4 Then you concur with the contention that if they closed 5 it now, it would be a lot cheaper and a lot -- wouldn't 6 follow near the regulations as if it was kept open and 7 closed later. 8 MR. MORRISON: I 'm not going to judge 9 whether it's cheaper or not. There will be more 10 extensive regulations to go into effect in October of 11 this year, either by the State regulations or the 12 Federal, by default. 13 There is some issue as to whether, to the 14 extent those regulations apply to vertical expansion of 15 existing areas. They clearly apply to areas that are 16 greater horizontally from the operations prior to 17 October. But I think, in general, there is much more 18 detailed regulations that will pertain if they continue 19 to operate past that date and expand horizontally. 20 MR. HALL: What would be the grandfathering 21 clause, or whatever you want to call that, of the 22 October '93 rules and regulations as pertaining to this 23 specific issue? 24 MR. MORRISON: Well, there wouldn't be for 25 any new horizontal area. That would require meeting BILLINGS REPORTING SERVICE /� ✓: 146 b 216 1 whatever the State -- the states approve those 2 regulations. There may be some opportunity to continue 3 to operate certain -- in terms of currently filled 4 areas, without full compliance. 5 You don't have to go back in, for instance. 6 At least, you don't have a prima facie requirement that 7 you go back in and line a site that' s already been 8 filled. And some of the remediation measures -- and 9 John, you can help me on this -- will come in under 10 certain circumstances and then another time frame in 11 '95. 12 So, again, it's not a black and white. You 13 just can't -- you' re not allowed to continue operating 14 any way you want after that period if it 's not a 15 horizontal expansion. On the other hand, the 16 requirements are less unless you fit into one of the 17 special categories. 18 One of the debates has been over what 19 category you put, whether there is contact between 20 groundwater and waste, in terms of whether the ' 95 will 21 provide another critical point. 22 MR. PICKLE: 1996. 23 MR. MORRISON: ' 96? 24 MR. PICKLE: Right. 25 MR. MORRISON: Thanks. BILLINGS REPORTING SERVICE ::. 1061 217 1 MS. HARBERT: John, do you have anything 2 you will like to add to that? 3 MR. PICKLE: What Lee alluded to is that 4 there are other considerations that come into play in 5 1996 that would toughen up the requirements for sites 6 to qualify to continue operation. 7 One of the debates here was, of course, 8 solid waste in contact with groundwater. And at this 9 point that still is up in the air as to whether that 's 10 a regulation or not according to the State. 11 I really think that ' s the only one that 12 would apply right now. But there are some 13 considerations as far as sites that would prevent 14 operation past October ' 96. And that's in the Federal 15 guidelines. 16 MS. HARBERT: Any more questions? 17 MR. WEBSTER: Yep. If you were to -- No. 1 18 question. On the extension of height, what do you 19 think you need to go up, or what is your -- 20 MR. ROY: I haven't seen the profiles. 21 It' s my understanding that the final sillouette of the 22 facility will not be above, or substantially above the 23 existing grade at the top of the landfill is 5 percent. 24 It' s my perception it 's going to extend out 25 further, perhaps slightly higher, but we are not BILLINGS REPORTING SERVICE 83106a 218 1 talking about substantial height over the land, north 2 edge of the landfill, but that plan will have to speak 3 for itself. I am speaking from what I have been told. 4 I have not seen the plan. 5 MR. WEBSTER: My next question, then, you 6 couldn't answer. How many feet would be necessary to 7 put a proper mound on it and cap it? 8 MR. ROY: Now? 9 MR. WEBSTER: At this point. If you went 10 ahead and started to fill to the low spots and then put 11 on a cap or a mounding situation, so that you would -- 12 MR. ROY: We are talking 12 years. 12 13 years of operation, and that's a lot of dirt to haul 14 in. 15 MR. WEBSTER: 12 years to cap it? 16 MR. ROY: 12 years to get the fill to get 17 the profile to cap it. 18 MS. HARBERT: To get the mound, to put the 19 right drainage mound on it? Is that what you' re 20 saying? 21 MR. ROY: 12 to 14 years. I have heard 22 various figures. I think the most authorative is 12 to 23 14 years, depending on how effective recycling is. If 24 recycling is more effective, it will extend the life as 25 much as two years. BILLINGS REPORTING SERVICE X1!6' 219 1 MS. HARBERT: Did you have something, 2 Mr. Butler? 3 MR. BUTLER: Yes, please. Leonard Butler. 4 I wanted to be very succinct again, given the hour, but 5 to respond directly to your question, Commissioners. 6 What has been discussed here, and 7 specifically that as laid out by Mr. Roy, is, in fact, 8 what we feel is a significant reduction from what was 9 envisioned by Weld County back in their more 10 comprehensive solid waste plan. 11 And that reduction basically accounts for a 12 minimum slope by providing for a significant reduction 13 in what may have been envisioned by the operator and 14 Weld County three or four years ago, and that that, by 15 that reduction, we are looking again, as Mr. Roy 16 pointed out, on the success that we have with recycling, 17 as well as per capita waste generation rates, of a 18 minimum of 12 years. 19 MR. HALL: A couple questions for John. 20 MR. BUTLER: Excuse me. That was maximum, 21 not minimum. 22 MR. HALL: What is the County's role in the 23 monitoring of the wells and how progress is moving 24 forward and that type of thing, as far as -- 25 MR. PICKLE: As I indicated earlier, up BILLINGS REPORTING SERVICE aa.3lll.+ /� st 220 1 until this May or June we monitored these wells 2 quarterly only for the required constituents, which did 3 not include VOCs. So we discontinued any monitoring of 4 the wells in our lab when Waste Management offered the 5 fact that they had discovered VOCs and suggested that 6 they may be able to find a better lab to do that, which 7 I am sure they can. 8 We can't do VOCs. We do receive and they 9 do submit to us any laboratory results that they do or 10 have conducted. And we've reviewed several from 11 several different labs since -- during this whole 12 process. So they have been open with laboratory 13 results that they've received and send us a copy of 14 those, but we do no monitoring ourselves. 15 MR. HALL: How do you -- I guess this is 16 almost a pointed question -- but how do you assure that 17 those reports or those samples are properly taken? 18 MR. PICKLE: Well, there is a standard 19 process for sampling and a standard chain of custody 20 and the forms are all pretty much standard. I can't be 21 there with the person, so I couldn't sit here and swear 22 to you that every sample was taken in accordance with 23 the care that we would take them, or anybody else. 24 But these laboratories are professional 25 laboratories, and they do have a license and there is, BILLINGS REPORTING SERVICE 821.06 221 1 in fact, the -- you can take action against the lab if 2 you can prove they fraudulently provided information, 3 and it's quite a hefty fine and, of course, would 4 totally ruin a laboratory. 5 So the assurances remain the economical 6 ones, you know. But the government is just not capable 7 of financially providing that type of service for all 8 the different industries today. 9 So it 's been privatized, but I think 10 there's enough safeguards within the privatization 11 system where it should -- you shouldn't see a lot of 12 any type of fraudulent reporting or that sort of thing. 13 MR. BAXTER: Those labs are involved in 14 taking those samples? The obvious question in 15 everybody's mind, you know, whatever lab you send them 16 to, is where they are taken, who takes them. So those 17 labs are involved in the sampling? 18 MR. PICKLE: In most instances that I 've 19 seen reports from Waste Services and Waste Management, 20 the laboratory that conducted, or did the collection, 21 also did the analysis. 22 And I know that when we did the analysis, 23 we also did the collection, too. I think that 's fairly 24 standard practice. 25 MR. WEBSTER: Could I ask John a question? BILLINGS REPORTING SERVICE : v1�V 222 1 If -- let's say that we stay out of the picture, 2 meaning we don't -- we defer or whatever, and the 3 State's findings, by continuing their tests, the State 4 people who were here, and they complete those tests and 5 they deny them a discharge permit, would the State 6 close down the landfill or would they look to us to 7 close down the landfill? 8 MR. PICKLE: That' s a legal question. 9 MR. MORRISON: Yeah. The revocation of 10 permits for a solid disposal site is a function of the 11 Board of County Commissioners. 12 MR. WEBSTER: So they will direct us to do 13 it. 14 MR. MORRISON: But the discharge permit is 15 a different issue. It might require -- 16 MR. WEBSTER: Let 's say they are out of 17 compliance. Let's not use that particular point. 18 Let's just say that they found contamination in the 19 river and they found contamination of the lakes, and 20 the monitoring wells show satisfactory, as far as 21 pollutants and so forth. They have to direct us to do 22 it? 23 MR. ROY: I think I can give you a 24 practical answer. 25 MR. MORRISON: I would appreciate it if you BILLINGS REPORTING SERVICE 22106 223 1 would give them an answer. 2 MR. ROY: The practical answer, the permit 3 that's been applied for, for discharge, relates to the 4 underdrain, the drains into or near Spomer Lake. The 5 Waste Services has already proposed or suggested or 6 discussed with the State installing a treatment 7 facility there that would treat that water before it' s 8 released. They would basically aerate the water, get 9 rid of the VOCs before it' s discharged. 10 The State ' s response was, Why do that, 11 because they are naturally disposed of immediately 12 after they are discharged from the drain. 13 But if they were to deny us a discharge 14 permit, we would stop discharging. 15 MR. MORRISON: I think you have to 16 understand the discharge permit is a different 17 situation. Basically, if you can meet the standards 18 that the State sets for the discharge permit, you would 19 be allowed the permit. It ' s a matter of standard 20 setting, whereas -- and you can either meet it or you 21 don't, in which case you don't discharge if you can't 22 meet the standards set. 23 Whether they can operate without the 24 ability to have that discharge permit is a judgment 25 they have to make. That's separate. The State is not BILLINGS REPORTING SERVICE 831061 224 1 going to come in and take over this problem that's on 2 your plate because there 's a minimum discharge. 3 MR. ROY: The simple, short answer is, 4 if we are denied a discharge permit, we will stop 5 discharging. 6 MR. WEBSTER: What about -- let 's throw the 7 discharge permit out and use the other violations that 8 the State talks about. 9 MR. MORRISON: Excuse me, Mr. Webster, is 10 that to Mr. Roy or to me? 11 MR. WEBSTER: Yeah. 12 MR. ROY: The discharge we applied for 13 relates to surface water, okay, contamination and 14 discharge. The other matters relate to groundwater 15 contamination, and the highest groundwater table. We 16 have not asked for a permit. We are not -- we are, 17 according to what we have been told, not in compliance. 18 Our suggestion is to direct that with 19 remediation, which involves upstream diversion of the 20 irrigation water and downstream air injection. Because 21 the VOCs are highly volatile, as soon as they are hit 22 by the air, they will vaporize and come out of the 23 well. That's the first technology we are suggesting be 24 tried. 25 If that technology proves unsatisfactory, BILLINGS REPORTING SERVICE 82,1061 225 1 there are secondary and tertiary techniques that can be 2 applied. 3 MR. HOBBS: Chairperson Harbert -- 4 MS. HARBERT: When Mr. Roy is done. 5 Do you have something that is totally new 6 evidence, or new, that you want to talk about? 7 MR. HOBBS: I want to correct a statement 8 that is very important. 9 MS. HARBERT: Is it totally new material? 10 MR. HOBBS: Yes. 11 MS. HARBERT: Are you sure it 's totally new 12 material? 13 MR. HOBBS: In view of what he said, I need 14 to -- at least, before you make a decision, I need to 15 address this. 16 MS. HARBERT: Will you go to the 17 microphone, please. 18 MR. HOBBS: We sat here for almost an hour 19 listening to a legal exchange. I would like to suggest 20 that these questions can only be addressed at a public 21 hearing, and we are prepared to brief these legal 22 issues. 23 But I want to correct a misstatement and, 24 therefore, it's new information which Mr. Roy made, and 25 it's contained on the face of the exhibit that he BILLINGS REPORTING SERVICE Oc"4f6 1 226 1 cited, Austin Buckingham's letter of -- it 's marked 2 as AD-48 -- and I would just like to read you one 3 statement from the letter, which was not brought to 4 your attention. 5 "To the Division's knowledge, no design or 6 operations plan has ever been developed for the 7 landfill, nor are any plans of this nature contained in 8 the Division files. " Paragraph 2 , Page 2 of the 9 Buckingham letter. 10 This is very important. As Mr. Hanson 11 stated, if there is a design operations plan, it 12 controls the operation and the closure. If there is 13 no plan, there was a violation ab initio of your 14 resolution. 15 It is unfair, I believe, of counsel to say 16 the State grandfathered this facility, when the State 17 itself says that there was never any design or 18 operations plan. 19 If there is one -- and he suggested there 20 was one based on the ' 86 transfer -- then for that 21 reason alone, you need to order the hearing and have 22 the Health Department come and show whether or not 23 there is such a plan, because if there is such a plan, 24 it governs this facility. If there is not, you have no 25 compliance with the land use approval. BILLINGS REPORTING SERVICE .9:106.1 227 1 And, again, I don't want to expand this. 2 We are very tired, all of us. They tried the case here 3 on the merits just now in legal arguments. I didn't 4 get a chance to respond. All we are asking for is a 5 hearing. That's the reason for today's meeting. I 6 wish it were not so. 7 I would have preferred to have come here in 8 one fell sweep. That's not how your procedures were 9 set up. We want a chance to brief this and have the 10 evidence here. 11 MS. HARBERT: Let the record show that the 12 person speaking was Greg Hobbs, the attorney for the 13 Ashton-Daniels Neighborhood Association. 14 MR. ROY: That same exhibit, Page 2 , dated 15 September 18, 1992 : "The Central Weld County Landfill 16 received a Certificate of Designation on October 6, 17 1971. At that time, the state had not promulgated 18 solid waste regulations pursuant to the Statute. 19 Between 1968 (the date the Statute became effective) 20 and 1972 , solid waste disposal sites and facilities 21 complied with the minimum standards set forth in the 22 Statute. The minimum standards detailed operational 23 standards, but did not specifically require a design 24 and operations plan. In 1972 regulations were 25 promulgated pursuant to the Statute. That 1972 BILLINGS REPORTING SERVICE 931()61 228 1 regulation set forth the requirement that all landfills 2 with an existing Certificate of Designation were 3 'grandfathered, ' that is they were required to meet the 4 minimum standards of section 3 , but not the standards 5 of section 4 (which applied to all solid waste disposal 6 sites and facilities that were designated after the 7 effective date of regulation) . In 1983 , when the 8 regulations were revised to their current form. " 9 And then there is the paragraph quoted by 10 counsel. 11 MS. KIRKMEYER: I would like you to address 12 that question of grandfathering, Condition No. 1 on the 13 resolutions. No. 1, any sanitary landfill facilities 14 being installed shall be approved by the State Health 15 Department. 16 MR. ROY: I -- I 'm sorry. 17 MR. MORRISON: First, I guess I would 18 remind you that the standards you are dealing with is a 19 fairly minimal one in terms of making a finding that 20 you need to go to the next stage, so that you don't 21 need to make a final determination. 22 And, in fact, any of your findings here are 23 preliminary in nature, only for the purpose of 24 determining whether we go to the show cause. I think 25 you are going to -- I think you are going to have to BILLINGS REPORTING SERVICE 931061 229 1 weigh evidence that maybe points in two directions. 2 There are statements from Mr. Stoddard on 3 the record that have been presented to you about this, 4 essentially, that this is an okay site. But there are 5 two letters, an exchange of letters that have to do 6 prior to the hearing in, I believe, July of ' 71, where 7 the -- Mr. Moffat was requested to provide the 8 engineering. He then argued that, you know, he didn't 9 want to go to that expense until he knew whether the 10 site would be approved. 11 There is, of course, this letter that both 12 sides have now quoted from Austin Buckingham. What is 13 clear is, I think the State could have required in 1971 14 that Mr. Moffat submit a complete engineering and 15 design package, because the statute was in effect. 16 And I think you ultimately have to make a 17 judgment whether, when you get to this issue -- and I 'm 18 not sure you have to finally resolve it today -- when 19 you get to this issue, was the set of representations 20 and the -- when the commissioners arrived at this 21 conclusion, it has to comply with State Health 22 Department regulations. Was that based on a view that 23 there was something more coming? Was there a planning 24 coming? Or had it already occurred when Mr. Stoddard 25 stood up and said it was an okay site? BILLINGS REPORTING SERVICE JiJS!l6 230 1 MS. KIRKMEYER: I guess, to that, I would 2 say, in reading some of the other documentation here in 3 the transcripts, there was supposed to be a plan 4 coming, because it said in the documentation or the 5 transcript that it was supposed to be presented to the 6 Board of Health after that, in 1971, after this initial 7 hearing in September for their adoption of that plan. 8 MR. MORRISON: Well, I 'd appreciate -- 9 Mr. Roy, I would appreciate it -- what I am trying to 10 tell you is that, although it is primarily a legal 11 question, you still have some intent to determine. 12 Whether it was, was that the intent? We are not trying 13 to create new standards that aren't shown on this 14 resolution. We are trying to interpret, I believe, the 15 intent of that provision. 16 And I 'm not contending that if someone 17 stands up in regulation and says it 's only going to be 18 2 feet high, or stands up at a hearing and says the 19 mound will only be 2 feet high, that they are bound to 20 that. What I am saying is, you are looking at that 21 process of approval and trying to interpret your 22 prior -- your prior Board's resolution, and you're 23 looking at the intent of the Board when they passed 24 that resolution. 25 And that is at least a part -- that part of BILLINGS REPORTING SERVICE •O6s 231 1 it is a factual judgment based on all the records that 2 you have before you. 3 MS. HARBERT: Are there any more questions? 4 MR. BAXTER: Madam Chairman, I would like 5 a clarification, with all respect to the two attorneys 6 out here, that obviously, it 's their business to have a 7 vested opinion. I find a legal opinion -- I don't want 8 to put Lee on the spot, but your contention is we don't 9 have to make that initial legal determination right 10 now? That can be saved for a show cause hearing? 11 MR. MORRISON: That 's true, because all you 12 need -- I mean, the standard that you have to meet 13 today is a probable cause, which is a reasonable ground 14 for belief in the existence of facts warranting the 15 proceedings complained of. 16 That cuts both ways. If you find probable 17 cause today, that doesn't assure that you will find 18 grounds to revoke in the future. But what I 'm saying 19 is, you don't have to determine with finality the facts 20 upon which you base your decision. 21 You need to weigh them and say, Is there 22 grounds to go forward? Are there enough facts that 23 have been laid out to justify having a more complete 24 hearing? 25 MR. BAXTER: Thank you. BILLINGS REPORTING SERVICE 831061 232 1 MS. HARBERT: Do you have anything else? 2 MR. CUNLIFFE: Yes. I guess we would like 3 to explain the position that we took. 4 MS. HARBERT: State your name. It's been a 5 long time since you spoke. 6 MR. CUNLIFFE: Chuck Cunliffe, Weld County 7 Department of Planning Services. 8 We would like to explain the position that 9 we took and, hopefully, it will shed some light on 10 this. Some people have questioned the length of time 11 that we asked for the continuance. The purpose of the 12 hearing today was, as Lee has just explained, to 13 determine whether or not probable cause exists. 14 If you find no probable cause, we can all 15 go home and forget it. If you find probable cause, 16 then the staff looked at three different scenarios, 17 the first one being to continue the probable cause 18 hearing until December 1 of 1993 . 19 And in looking at that, that was a 20 three-step process that has been or is consistent with 21 how we've handled probable cause hearings in the past. 22 And the length of time involved requires the six-month 23 review by the State Health Department, which they are 24 required by statute, and also historically have taken 25 the six months. BILLINGS REPORTING SERVICE 0 233 1 We then need a minimum of 30 days before 2 the first Planning Commission hearing. And again, we 3 have waited until we actually have in hand the 4 recommendation of the State Health Department on the 5 certificate of designation before we schedule the 6 Planning Commission hearing. 7 Following the Planning Commission hearing, 8 then it's roughly three or four weeks before it comes 9 before the Board of County Commissioners. So that's 10 the date that we looked at, December 1, taking into 11 account that three-step process and the time frame that 12 historically has been there. 13 The other two possibilities which we did 14 not recommend was you could schedule a show cause 15 hearing in a relatively short time frame. The other 16 possibility we looked at was to schedule a show cause 17 hearing. Again, staff would, if the Board so chose 18 that, again, we would recommend the December 1, 1993, 19 hearing date. That allows the amended applications for 20 the special use permit and certificate of designation 21 to follow that time line. 22 And I guess the reason that both the 23 Planning Department and the Health Department felt that 24 that was, I guess, reasonable, is that the remediation 25 plan addressing the problems with groundwater is BILLINGS REPORTING SERVICE 234 1 included as a part of that amended application 2 process. 3 So that was the way, I guess, we went about 4 the reasoning behind what we recommended. I don't know 5 if that will help the Board, but again, we would like 6 to stress that has been consistent with what we have 7 done when we have gone to probable cause and the 8 applicant has come forward with an amended application. 9 And we've allowed that or recommended that 10 the application proceed to give him due process to come 11 into compliance, or at least direct the issues that we 12 were attempting to focus on today. 13 MS. HARBERT: Thank you. That gives us a 14 lot of clarification as to what our options are. 15 The time being 5: 15, I need to caucus my 16 commissioners up here as to how you want to proceed. 17 Do you want to -- I guess we have three options. We 18 can take a break, we can go on until we finish, or we 19 can recess until tomorrow morning. So those are our 20 three options, and I guess I need to get some input 21 from you before we go on. 22 MS. KIRKMEYER: I would like to go on until 23 we finish. 24 MR. BAXTER: I 'm for going on. 25 MR. WEBSTER: Fine. BILLINGS REPORTING SERVICE 9:1061 235 1 MS. HARBERT: All right. That' s all I need 2 to know. 3 MR. MORRISON: Madam Chairman, I have two 4 points to clarify. 5 (Discussion off the record. ) 6 MR. MORRISON: One is the State is not 7 required to take, I think, 150 days, but they 8 inevitably seem to, so . . . 9 MR. CUNLIFFE: I guess -- we checked with 10 the State, with Glen Mowry today, and they said they 11 had to take 180 days. 12 MR. MORRISON: That 's consistent. They 13 have never done them any more quickly than the time 14 allowed. 15 MR. CUNLIFFE: I think the other thing we 16 need to point out is that that six months could extend 17 if they request additional information. So that's 18 looking at the minimums, with no problems. 19 MR. MORRISON: The other clarification from 20 my statement, when we were talking about what would 21 happen in terms of closure, the Subtitle D regulations 22 do apply to landfills currently operating with respect 23 to additional closure requirements more strict than 24 what the State currently requires. 25 So they -- that 's the one, if you don't BILLINGS REPORTING SERVICE ::2106 . 236 1 close before October of this year, you still have to 2 comply with regulations, closure requirements. 3 It's an additional closure requirement, not 4 post-closure monitoring, not posting collateral, but in 5 terms of how you go about closure. 6 MS. HARBERT: So what you're saying is, if 7 we would have a show cause hearing before October 1, 8 their requirements wouldn't be as stringent as if we 9 had a show cause hearing after October 1. 10 MR. MORRISON: If they were revoked before 11 versus revoked afterwards, yes. My answer to that 12 question is the same. It ' s just that I neglected to 13 advise you, in Section 258 . 6 (a) 2 of the Subtitle D 14 regulations does require some additional physical means 15 of closure, even though they cease operation before the 16 October date. 17 MS. HARBERT: I guess, is the Board ready 18 to make a decision or -- 19 MS. KIRKMEYER: Do we have any more 20 questions? 21 MS. HARBERT: Are there any more questions? 22 MS. KIRKMEYER: I would move the Board of 23 County Commissioners determine that there is probable 24 cause and reasonable grounds to believe that facts 25 exist that Central Weld County Landfill and its owner BILLINGS REPORTING SERVICE 8:1061 237 1 is not in compliance with SUP-116. 2 And why don't we schedule a show cause 3 hearing. I am open for a date here, maybe the first 4 Wednesday in October. 5 MS. HARBERT: I would prefer to take staff 6 recommendation on December 1, but I guess I need to 7 have some input. 8 MS. KIRKMEYER: Maybe I should stop my 9 motion that we schedule a show cause hearing and make 10 another motion for the date. 11 MR. WEBSTER: Time to be determined later. 12 MS. KIRKMEYER: We need to do that. 13 MR. BAXTER: Madam Chairman, could I ask 14 Chuck a question? Does that present a problem you can 15 see, if it goes before December? 16 MR. CUNLIFFE: If it goes before December, 17 then the State may not have completed its review. 18 Regardless of what happens here today, we are 19 processing the amended applications for Special Use 20 Permit 116 and CD-26, so that will continue on in the 21 process. 22 But you're looking at six months from today 23 before we get any kind of a response back from the 24 State Health Department, unless they ask for additional 25 information from Waste Services. BILLINGS REPORTING SERVICE cc :Z S!J . 238 1 MR. WEBSTER: That' s terrible. I 'm 2 irritated with the State. So that's my problem. 3 MS. HARBERT: That's not helping us make 4 our decision at all. If we could have a State 5 recommendation back next month, well, it would 6 certainly help us, but there's no way that we can do 7 that. 8 And I feel that we at least need their 9 input into this. And if we can't -- if we can 't get 10 theirs back for six months, and then it takes what, 11 approximately four weeks after that to post -- 12 MR. CUNLIFFE: Get to the Planning 13 Commission. 14 MS. HARBERT: -- do the hearings and so on, 15 we are to December 1, and I think that 's why Chuck 16 recommended that. I think our hands are somewhat tied 17 in a way, if we want the State 's input on it. 18 MS. KIRKMEYER: I guess, first of all, 19 Chuck is talking about an amended certificate of 20 designation plan or application, and there 's also the 21 remedial plan. So are they one and the same? 22 MR. CUNLIFFE: They are an element of the 23 application. 24 MS. KIRKMEYER: So they could rule on the 25 remedial plan in any length of time? They don't have BILLINGS REPORTING SERVICE 3:1061 239 1 any deadline or anything of that nature? 2 MR. CUNLIFFE: That's true. But, again, 3 historically, they have taken as much time as they 4 choose to, and Mr. Mowry indicated in his testimony 5 earlier, there is no set deadline, so they don't have 6 to have it out in six months. They can take seven 7 months or eight months. 8 MS. KIRKMEYER: Or indefinitely? 9 MR. CUNLIFFE: That 's right. 10 MS. KIRKMEYER: If we don't set a deadline, 11 that can keep them going indefinitely? 12 MR. CUNLIFFE: Weill , again, the 13 remediation plan is part of the application for use by 14 special review and amended CD. That 's locked into the 15 180 days, so they have to have something back to us. 16 So we're assuming they will have a response back to us 17 in the six months on the remediation plan. 18 MR. MORRISON: The other side of that, 19 though, is, if you go to the next level, I think the -- 20 that I 've heard Waste Management say that that 21 remediation plan portion of the permit application goes 22 to show how they are going to resolve any violations. 23 So you want, hopefully, to have the State 24 comments on that plan, whether you do the show cause 25 first or not. I mean, you can -- you know, the fact is BILLINGS REPORTING SERVICE JJ.!s b 240 1 you can proceed with the show cause. You are not 2 precluded from doing that in an earlier order, or 3 setting that and not -- and without knowing exactly 4 when the permit might be heard. 5 MS. HARBERT: Well, we can always set a 6 show cause hearing date, too, and if we don't have the 7 information we want, we can continue it without having 8 the hearing. That's what you're saying? 9 MR. MORRISON: Yes. 10 MS. HARBERT: I mean, if we set it for 11 October 15 and we don 't have the information we need, 12 we can gather it October 15 and continue it to whenever 13 we want to? 14 MR. MORRISON: Yes. 15 MS. HARBERT: I mean, that' s an example. 16 MR. MORRISON: Yes. 17 MS. KIRKMEYER: Carol, could you give me a 18 date in October around the 15th? 19 MS. HARDING: 13th. 20 MS. KIRKMEYER: I would add that to my 21 motion, and schedule show cause hearing on October 13 , 22 1993 . 23 MR. WEBSTER: Second. 24 MS. HARBERT: It ' s been moved by Barbara 25 Kirkmeyer and seconded by Bill Webster to schedule a BILLINGS REPORTING SERVICE 241 1 show cause hearing for October 13, 1993 . That is a 2 Wednesday, at 10: 00 in the morning. 3 Is there any further discussion? 4 MR. BAXTER: I just have a question maybe 5 of legal counsel, and maybe Chuck, whoever is involved 6 in this. This in no way hampers going ahead with the 7 amended permit, or be construed as putting a damper on 8 that? 9 MR. MORRISON: Not if that 's your -- I 10 mean, that should not. It could affect -- if, under 11 the scenario that the existing permits are revoked, you 12 could still hold a hearing on the new application. It 13 might change the framework under which it ' s judged 14 because some of these grandfathering provisions would 15 evaporate. 16 But it wouldn't prevent -- and you could 17 revoke, could have revoked it today. It wouldn't 18 prevent the application and the processing. And as 19 long as it 's a complete application and one that isn't 20 prohibited in some fashion in the regulations, I think 21 we have to process it. 22 MS. HARBERT: Any other discussion? 23 MR. HALL: It seems like, to me, though, 24 that the best possible solution to this whole process 25 is to review the use by special review -- or permit by BILLINGS REPORTING SERVICE O:106t 242 1 use of special review amendment process, and I guess 2 I 'm not convinced totally that we have probable cause 3 in this situation. 4 My preference would be to allow a 5 continuation of this probable cause hearing. 6 MS. KIRKMEYER: I guess, to that, I would 7 answer, not only has Waste Management stated they feel 8 there is a violation. Whether it' s minor or they think 9 it could be remedied, it's still a violation. 10 Also, the Attorney General 's letter of 11 March 5, 1993 , that concurs with the Colorado 12 Department of Health that there is a violation of 13 2. 1. 4 . And our own Weld County Health Department also 14 cited the operation for four violations that they still 15 feel they are not in compliance with. 16 MS. HARBERT: Roll call, please. 17 MS. HARDING: George Baxter. 18 MR. BAXTER: : Aye. 19 MS. HARDING: Dale Hall . 20 MR. HALL: No. 21 MS. HARDING: Barbara Kirkmeyer. 22 MS. KIRKMEYER: Yes. 23 MS. HARDING: Bill Webster. 24 MR. WEBSTER: Yes. 25 MS. HARDING: Connie Harbert. BILLINGS REPORTING SERVICE 921061 243 1 MS. HARBERT: Yes. 2 Thank you. I have to terminate the 3 meeting. I forgot we started at 9: 00 this morning. At 4 this time, there being no other business to come before 5 the regular Board of County Commissioners of Weld 6 County, I declare us adjourned. 7 I would like to say that I thank each and 8 every one of you for spending the day with us. It's 9 been a long day for both us and you, both, and the 10 commissioners, also. But things like this are really 11 necessary, and it' s what makes our democracy work. 12 Thank you very much for coming. 13 (Proceedings concluded at 5 : 30 p.m. ) 14 15 16 17 18 19 20 21 22 23 24 25 BILLINGS REPORTING SERVICE 831061 244 1 STATE OF COLORADO ) ss. REPORTER'S CERTIFICATE 2 COUNTY OF WELD 3 I, Barbara Billings, do hereby certify that 4 I am a Certified Shorthand Reporter and Notary Public 5 within the State of Colorado. 6 I further certify that these proceedings 7 were taken in shorthand by me at the time and place 8 herein set forth and were thereafter reduced to 9 typewritten form, and that the foregoing constitutes a 10 true and correct transcript. 11 I further certify that I am not related to, 12 employed by, nor of counsel for any of the parties or 13 attorneys herein, nor otherwise interested in the 14 result of the within action. 15 In witness whereof, I have affixed my 16 signature and seal this 8th of May, 1993 . 17 My commission expires April 11, 1994 . 18 19 20 =O �Y'e.1.49 '1 BARBARA } ��i B rbara BillingsR-CM 21 i B , 710 - 11th Avenue, Suite 106 BILLINGS }ce1s Greeley, Colorado 80631 22 11N.% .......23 24 25 BILLINGS REPORTING SERVICE 245 1 BILLINGS REPORTING & VIDEO, INC. 2 710 - 11th Avenue, Suite 106 Greeley, Colorado 80631 3 (303) 356-3306 4 5 PLEASE ATTACH TO YOUR COPY OF THE TRANSCRIPT OF 6 THE CENTRAL WELD/GREELEY-MILLIKEN LANDFILL HEARING 7 8 9 10 THIS TRANSCRIPT HAS BEEN FILED WITH: 11 Clerk to the Board, Weld County Commissioners 12 On approximately the 10th day of May, 1993 . 13 14 cc: All Counsel 15 16 17 18 19 20 21 22 23 24 25 BILLINGS REPORTING SERVICE Hello