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Home My WebLink About931594.tiff • { ,;., mEmoRAnDum sipig gukTo Board Data January 15, 1993 COLORADO From Clerk to the Board Subject: Central Weld/Greeley-Milliken Landfill Lee Morrison, Assistant County Attorney, submitted a packet of information concerning Central Weld/Greeley-Milliken Landfill to our office. This information, and any further information received on this matter, will be kept on file as record for a possible probable cause hearing. If you wish to review this material, it will be available in our office. 7/5 /- 'AV 4zeo OS sA 4a ✓ BAXTER HALL ✓/ HARBERT i KIRKMEYER V WEBSTER V 931594 Ckhi6ifE 931061 Waste Services Corporation 6037 77th Avenue Greeley, Colorado 80634 1ArY S[d 'M'a�nygement Company 303/330.2641 n, P'n .iU February 5, 1993 HAND DELIVERED Mr. Chuck Cunliffe, AICP Weld County Department of Planning Services 1400 North 17th Avenue Greeley, Colorado 80631 Dear Mr. Cunliffe: We are in receipt of your letter of January 18, 1993, in which it is stated that the Central Weld Sanitary Landfill (CWSL) is not in compliance with Condition of Approval Number 1 on the Board of County Commissioners' Resolution dated October 6, 1971. Your letter included "memorandum from Mr. Pickle and a letter from Mr. Jiricek," which identified alleged violations of applicable requirements. You also stated in your letter that the facility must be brought into compliance with the Conditions of Approval within thirty days from the date of your letter. I am writing this letter to seek clarification on what will be required to comply with your request. We are seeking this clarification because we are genuinely confused as to the applicability of this condition to the current operation of the landfill. This condition states that the "facility to be installed shall be approved by the State Health Department." The clear implication from the use of the phrase "facility to be installed" is that this Condition referred to a one time approval to be obtained prior to the installation of the landfill. The County was required by statute (Colo. Rev. Stat. § 30-20-103) to refer the application for the Certificate of Designation (CD) to the Colorado Department of Health (CDH) for review and recommendation prior to issuance of the CD. The County was further prohibited by statute (Colo. Rev. Stat. § 30-20-107) from issuing a CD if CDH recommended disapproval. The County was able to issue the CD because CDH did not recommend disapproval of the application. During the 1971 hearing on this matter, Orville Stoddard of CDH stated, "This is a suitable site and can be operated as a sanitary landfill." It is our understanding that CDH did not, in 1971, and, in fact, never has had the authority or mechanism for granting after the fact approvals such as the one referenced in Condition 1. In Federal Deposit Insurance Corporation v. Board of County Commissioners of Arapahoe County, (copy attached) the court determined that no such "approval" was required. Therefore, this lack of a mechanism for obtaining CDH "approval" was the reason no approval was obtained in 1971 and, furthermore, it is likely the reason why no citation was issued either when the landfill was constructed or at any time during the ensuing 21 years. It could be assumed that the original landfill owner and the other three owners prior to the purchase of the landfill by Waste Services Corporation (WSC) relied on the County's silence on this matter in not pursuing any such approval from CDH or clarification from the County on this point. Xh;bi� a:106:1\ 1V Mr. Chuck Cunliffe February 5, 1993 Page 2 In 1986, WSC and its predecessors received and relied upon affirmative County approval of the transfer of ownership of the CD without any objection to any aspect of the site operations. We are concerned that WSC, the current owner of CWSL, is being notified of alleged non- compliance 21 years after the permit was issued. In fact, the County Commissioners most recently considered, on January 20, 1992, the continued operation of CWSL and concluded that the site complied with all County regulations. You indicated in your letter that Mr. Pickle's memorandum dated January 8, 1993, and Mr. Jiricek's letter dated January 14, 1993, outline the violations of Condition of Approval Number 1. Mr. Pickle's memorandum and Mr. Jiricek's letter contain alleged violations of "Colorado Regulations Pertaining to Solid Waste Disposal Sites and Facilities." No Notices of Violation have been received from CDH regarding operation of CWSL. Since none of the alleged violations by the County involve CDH approval or disapproval of the facility, we suggest that none of these alleged violations, even if established, could constitute a violation of Condition of Approval Number 1. You stated in your letter that the County has not yet made a determination as to whether CWSL is in compliance with Condition of Approval Number 2. This Condition requires "[t]hat all applicable subdivision regulations and zoning regulations shall be followed and complied with in accordance with the Zoning Regulations of Weld County, Colorado." We believe that we are, and always have been, in compliance with this Condition. If we are advised of specific violations of this condition, we will address those issues upon receipt of notification from the County. We wish, however, to cooperate with the County and, to that end, stand prepared to work with the County in taking whatever steps are necessary to comply with all applicable requirements. In an effort to further understand the County's concerns and needs, WSC's representatives met with Lee Morrison, Trevor Jiricek and Keith Schuett on Friday, January 22nd. During that meeting, we went through each of the items in Mr. Pickle's memorandum. Based on those discussions, it is our understanding that the County would interpret items 3 and 5 in Mr. Pickle's memorandum as violations of Condition Number 1. We would dispute any such interpretation. We believe that Mr. Pickle's and Mr. Jiricek's allegations are subject to debate and are, we hope, also subject to discussion. We would like, therefore, to offer the following discussion of each of the points raised by them in this collective singular response. Both Mr. Pickle and Mr. Jiricek identified six items of concern; five of which are the same and will be addressed jointly. The remaining two will be identified by author. 11211 064 Mr. Chuck Cunliffe February 5, 1993 Page 3 1. The operators did not file a Design and Operation Plan. Response: On September 18, 1992, CDH acknowledged that a Design and Operations Plan is not required at CWSL (see attached letter from Mr. Kent Hanson). In the FDIC case referenced above, the court determined that no State approval of such plans was required. As a result of this determination, this concern of the County cannot be construed to be a violation of Condition Number 1. Nevertheless, WSC, at the request of the Board of Commissioners, voluntarily accelerated its schedule to develop a Preliminary Design Operation and Closure Plan and a Conceptual Site Development Plan. These were submitted to the County and to the CDH on December 31, 1992 and November 16, 1992 respectively. These Plans will be further refined as the CDH implements Subtitle D, which is currently scheduled to occur prior to its effective date of October 1993. Copies of these Plans and reports are submitted and included herewith. 2. The Central Weld Sanitary Landfill has operated without required Discharge Permits. Response: An underdrain was constructed at the facility in late 1982 to early 1983. The purpose of the underdrain is to maintain groundwater levels below the base of the refuse in the landfill. Immediately upon obtaining an interest in CWSL, Waste Management of Colorado, Inc. (WMC) conducted an indepth audit of the facility's compliance with applicable requirements. Even though the County had conducted routine testing of the flow from the underdrain and had never notified WSC that a discharge permit was required, WMC determined during the audit, that such a permit may be required. Over the past several months, WSC gathered the necessary information to prepare a discharge permit application. The application was submitted to CDH on November 24, 1992 (a copy is attached). The CDH has now requested additional information which WSC is expeditiously preparing. WSC has tested the pond which receives flow from the underdrain and found no volatile organic compound (VOC) contamination. We are confident that any required permit will be issued in the near future. 3. The Central Weld Sanitary Landfill contaminated groundwater. Response: Information provided by WSC to the Weld County Department of Health (WCDH), as part of the facility's hydrogeologic site characterization, showed low level groundwater contamination downgradient of the site. Additional testing showed no contamination 200 feet beyond the south property boundary. On December 17, 1992, .Qr i.064:. 1V Mr. Chuck Cunliffe February 5, 1993 Page 4 WSC submitted proposals to WCDH and CDH for remedial measures. Based on subsequent discussions with CDH and WCDH, WSC is proceeding with refinements to the remedial measures outlined in the December 17th letter (a copy is attached). We do not, however, believe that the existence of groundwater contamination is a violation of any regulatory or permit requirement. 4. The Central Weld County Sanitary Landfill has allowed ponding of water on site. Response: The ponding referred to is the retention pond specifically designed and constructed to collect water from the french drain and the perimeter ditch that collects surface water run-on from the adjacent property, and non-contact surface water run-off from the landfill. The french drain and perimeter ditch system was designed to and does divert water around and away from the facility pursuant to Section 2.2.2 of the Colorado Minimum Standards regulations. The retention pond was constructed in the undeveloped eastern portion of the landfill over a year and one-half ago. The pond has been visible at all times since construction and, until Mr. Pickle's memorandum, has never been commented on by either CDH or WCDH. As the pond is not located over refuse, there is clearly no violation of Section 2.1.4 of the Colorado Minimum Standards. 5. The Central Weld Sanitary Landfill has placed solid waste into the groundwater at the site in violation of Section 2.1.4 of the Colorado Minimum Standards. Response: There is no evidence that solid waste was placed in groundwater at CWSL. Furthermore, interviews with employees indicate that waste was not placed in groundwater during the time of their employment (1979 to present). The underdrain discussed in response to number 2 above was constructed to alleviate potential groundwater contact with waste. Preliminary site development plans also include engineering improvements to further prevent the potential for groundwater to come into contact with waste after its placement. Section 2.1.4 contains no prohibition against the placement of waste in groundwater. Therefore, even if waste had been placed in groundwater at the facility, it would not be in violation of this Section. 6. This facility is currently operating without an emissions permit. (Mr. Jiricek) F s7int;At //' X11\ Mr. Chuck Cunliffe February 5, 1993 Page 5 Response: The provisions of Regulation Number 3, Section l.A. which require an emissions permit do not apply to the CWSL. This conclusion was confirmed by the WCDH in a letter from Jeffrey Stoll, Air Pollution Specialist, dated September 2, 1992, a copy of which is attached. Mr. Jiricek's comment in his January 14th letter is in conflict with the earlier direction we had received from the County. WSC continues to believe that such a permit is not required and that we are not in violation of Section 1.A. We nonetheless submitted on January 20, 1993, Air Pollution Emission Notice (APEN) for fugitive particulate emissions. (A copy of this submission is attached) 7. In the absence of any Design and Operation Plan, the only basis for establishment of parameters for the 1971 permits are the representations of the applicant at the time the permit was considered by the Board of Commissioners. (Mr. Pickle) Response: The October 6, 1971 Resolution contains the two conditions discussed earlier in this letter. Quite clearly if the Board had felt additional restrictions were necessary they would have included them in the resolutions. However, there are no restrictions on either height or duration contained within the 1971 resolution. When the Board issued the permit in 1971, there was no requirement that there be a Design and Operation Plan for the facility and, even though the Board could have required such a plan if they felt it was necessary, they did not do so. Therefore, the absence of a Design and Operation Plan in 1971 cannot constitute a violation. Mr. Pickle indicated in his memorandum that CDH has determined that the violations outlined in 3 and 5 above constitute a public nuisance. Mr. Morrison at our meeting, related that this comment originated in a December 21, 1992 letter from CDH to me. In that letter, the CDH identified two areas of non-compliance. Even though CDH indicated that CWSL is not in compliance with Section 2.1.4 of the regulations, WSC believes that CWSL is in full compliance with all applicable requirements including those in Section 2.1.4. WSC has discussed this matter with CDH and understands that CDH is considering this matter further and has not reached a final decision. Since CDH identified the second issue as a potential area of non-compliance if proposed regulations are adopted without change, any issue of compliance, can and should be addressed if and when a regulation is adopted. We are monitoring the proposed regulation carefully and will ensure that the facility is in compliance with any requirements ultimately adopted. F. : Z1.o6'4. Mr. Chuck Cunliffe February 5, 1993 Page 6 In January of this year, the CDH published a document entitled, "Central Weld Sanitary Landfill Questions and Answers" (copy attached). You will note that the document cites no violations and expresses no disapproval of the continued operation of the landfill. Since WSC has either addressed or is currently addressing all of the County's concerns, we ask for clarification as to what specific additional actions are required by your office to show compliance with the Conditions of Approval. As we have discussed, we are working with the CDH to address the concerns set forth in Item 3 above. Until the CDH makes a final determination as to whether or not we have adequately addressed their concerns, we submit that any action by the Board dealing with Conditions of Approval Number 1 would be premature. We request that after your review of this submission, another meeting be held prior to the expiration of your 30-day limit to consider the adequacy of our response to your January 18, 1993 letter. Please contact me to establish a date and time to meet. Also, please feel free to contact me should you require additional information. Very truly yours, ICJ William J. Hedberg Division Vice President WAJ:nlp Attachments cc: Lee Morrison, Assistant Weld County Attorney Roger Doak, Colorado Department of Health Weld County Commissioners: Constance Harbert, Chairman (w/attachments) Bill Webster (w/attachments) Dale Hall (w/attachments) George Baxter (w/attachments) Barbara Kirkmeyer (w/attachments) corep.bj\matins 1.46', 6 Waste Services Corporation 6037 77th Avenue Greeley, Colorado 80634 A Waste Management Company 303/330-2641 • Ile January 13, 1993 Mr. John Pickle Weld County Department of Health 1517-16 Avenue Court Greeley CO 80631 RE: REVISED PRELIMINARY DESIGN, OPERATION AND CLOSURE PLAN FOR THE CENTRAL WELD SANITARY LANDFILL (CWSL) • Dear Mr. Pickle: Enclosed are five copies of the revised Preliminary Design, Operation and Closure Plan (Plan) for CWSL per our recent phone conversation. The revised Plan is a refinement of the Preliminary Design, Operation and Closure Plan submitted to Weld County Department of Health on December 31, 1992 and generally includes • formatting refinements to the document subheadings. Please contact Bill Hedberg at 330-2641 or Alan Scheere at 770-3324 if you have questions. Sincerely, / l , /Xyr, ..C sBill Hedberg Alan Scheere s Division V.P. Landfill Operations AS/mmp . • Enclosures cc: Roger Doak, CDH w/enc Trevor Jiricek, WCHD w/o enc Lee Morrison, Assistant County Attorney wp51W\011393L1.wch P. CWSL 4.7/9.1.1.2 �= bcc: Tom Schweitzer Tom Buchholz Len Butler Marian King • wp511aa1011393L1.wch F: CWSL 4.7/9.1.1.2 S:JOftits 3' TABLE OF CONTENTS Section Page 1.0 INTRODUCTION 1-1 1.1 PURPOSE 1-1 1.2 BACKGROUND 1-1 1.3 SITE DESCRIPTION 1-2 1.4 SUBTITLE D SITING CRITERIA 1-2 1.4.1 Airports - Draft Regulations. Subsection 3.1.1 1-2 1.4.2 flood Plains - Draft Regulations. Subsection 3.1.7 1-2 1.4.3 Seismic Impact Zones - Draft Regulations. Subsections 3.1.3 and 3.1,4 1-2 1.4.4 Wetlands - Draft Regulations. Subsection 3.11 1-2 1.4.5 Unstable Areas - Draft Regulations. Subsection 3.1.5 1-3 1.5 SITE DOCUMENTS 1-3 2.0 SITE CHARACTERISTICS 2-1 2.1 TOPOGRAPHY 2-1 2.2 SURROUNDING LAND USE 2-1 2.3 NATURAL AND GEOLOGIC HAZARDS 2-1 2.4 GEOLOGY 2-2 2.5 IIYDROGEOLOGY 2-2 2.6 CLIMATE 2-3 3.0 WASTE CHARACTERISTICS AND VOLUMES 3-1 3.1 WASTE CHARACTERISTICS 3-1 3.2 REFUSE VOLUME 3-1 4.0 LANDFILL DESIGN AND CONSTRUCTION 4-1 4.1 ACCESS AND HAUL ROADS 4-2 41 ONSITE FACILITIES 4-2 4.3 STORMWATER MANAGEMENT 4-2 4.3.1 Runop 4-2 4.3.2 Runoff 4-2 4.4 LEACHATE MODELING 4-3 4.5 FINAL GRADES 4-4 4.6 JAILY COVER 4-5 4.7 INTERMEDIATE COVER 4-5 4.8 FINAL COVER 4-5 4.9 REVEGETATION 4-6 5.0 LANDFILL DISPOSAL SEQUENCING 5-1 6.0 LANDFILL MODULE DEVELOPMENT 6-1 6.1 EXCAVATION GRADES/BASE GRADES 6-1 SECV401t\111192.REP i F 51 .08". c7 TABLE OF CONTENTS (Continued) Section Page 6.2 J.FACHATETOTJ ECTION AND MONITORING 6-2 7.0 OPERATIONS AND MAINTENANCE 7-1 7.1 HOURS OF OPERATION 7-1 7.2 SIGNS POSTED 7-1 7.3 WASTE CONTROL 7-1 7.4 SITE PERSONNEL 7-1 7.4.1 Personnel 7-1 7.4.2 Personnel Health and Safety 7-2 7.5 OPERATING EOUIPMENT 7-3 7.6 CONTROL OF NUISANCE AND HEALTH FACTORS 7-3 7.6.1 Odor Control 7-3 7.6.2 Dust Control 7-3 7.6.3 Noise Control 7-4 74.4 Site Appearance 7-4 7.6.5 Litter Control 74 7.6.6 Vector Control 7-4 7.6.7 Fire Protection 7-5 7.7 RECORD KEEPING 7-5 8.0 ENVIRONMENTAL MONITORING 8-1 8.1 GROUND WATER MONITORING 8-1 8.2 ,LANDFILL GAS MONITORING 8-1 8.3 SURFACE WATER MONITORING 8-1 8.4 LEACHATE MONITORING 8-1 9.0 CLOSURE AND POST-CLOSURE ACTIVITIES 9-1 APPENDIX A - HELP MODEL WATER BALANCE SECU40u\111192 REP 11 F /0 TABLE OF CONTENTS (Continued) LIST OF FIGURES Figure No, Title 1 Site Vicinity Map 2 Site Location Map SEC U4018 11192.REP iii 91106'. // 1.0 INTRODUCTION 1.1 PURPOSE This Design, Operations, and Closure Plan (Plan) and supporting Preliminary Site Development Plan (SDP) are intended to describe the design and operations and illustrate the method of development and closure of Central Weld Sanitary Landfill (CWSL). The Plan will provide a written overview of the design and operational methods to be used by CWSL in meeting all applicable government requirements including the Draft State of Colorado Solid Waste (Subtitle ID) Regulations dated September 3, 1992 (hereinafter referred to as "the Draft Regulations"). This Plan will be updated at such time as the Draft Regulations are finalized and approved by the State of Colorado to reflect any changes that are made in the final version. This Plan describes the facility background, site characteristics, waste characteristics, landfill design and construction, disposal sequencing, module development, operations and maintenance, environmental monitoring, closure, and post-closure care. This Plan should be reviewed along with the site documents which cover design, technical evaluation, and environmental programs for CWSL, which are listed in Section 1.5. 1.2 BACKGROUND CWSL is an active solid-waste disposal site owned and operated by Waste Services Corporation (WSC). The original CD was issued by Weld County to Earl Moffat on October 6, 1971. Browning-Ferris Inc. (BFI) owned and operated the site through 1976 at which time BFI sold its interest to Ralph and Barbara Rohweder who operated the facility until June 1979. In 1979, Mr. and Mrs. Rohweder sold their interests to Mr. Lynn Keirnes of Colorado Landfill, Inc. The certificate of designation for the site was transferred from Colorado Landfill, Inc. to Waste Services, Inc. (WSI) on May 7, 1986 by Weld County. The site was subsequently owned and operated by WSI under Mr. Lynn Keirnes until 1989. WSI became WSC under Mr. Brad Keirnes in 1989. On July 12, 1991 WSC merged with Waste Management of Colorado Inc. (WMC), an operating division of Waste Management of North America, Inc. (WMNA). SECU401B1111197.REP 1-1 92106S /3 1.3 SITE DESCRIPTION CWSL is located in Weld County, Colorado, five miles southwest of Greeley and three miles northeast of Milliken (Figure 1). Weld County Road 27 1/2 (77th Avenue) bounds the site on the east and provides access to the facility. The site covers approximately ]10 acres in the southwest quarter of Section 32, Township 5 North, Range 66 West (Figure 2). A residence and natural gas extraction well are located on the eastern portion of the site in an area which is not currently expected to be landfilled. 1.4 SUBTITLE D SITING CRITERIA The CWSL, as currently sited, meets the Draft Regulations siting criteria as described below. 1.4.1 Airports • Draft Regulations. Subsection 3.1.1 The CWSL is not located within 10,000 feet (ft) of any airports (Hydrogeologic and Geotechnical characterization for the Central Weld Sanitary Landfill, Weld County, Colorado, Golder Associates, Inc., July ]992). 1.4.2 Flood Plains - Draft Regulations. Subsection 3.1.7 The site is not located within a 100-year flood plain. According to the Federal Emergency Management Agency (FEMA), the site is classified as Zone C, subject to minimal flooding (FEMA Map #080266-0750C, 1992). 1.4.3 Seismic Imoact Zones - Draft Reeulations. Subsections 3.1.3 and 3.1.4 The nearest potentially active faults to the site are the Rocky Mountain Arsenal Fault and the Valmont Fault which are located approximately 27 miles to the south (Kirkham and Rogers, 1981). The large distance to an active fault zone indicates that seismic impacts are likely to be insignificant at the landfill. The lack of significant potential seismic impacts at the site is substantiated by work conducted by Algermissen, et al, (1982), who determined that the site does not meet the criteria for a seismic impact zone. s 1.4.4 Wetlands • Draft Regulations. Subsection 3.. The site is not located in any wetlands. SECV401a\111192.REP 1.2 .921 %%i'. Ij • 1.4.5 Unstable Areas - Draft Regulations. Subseclion 3.1.5 The nearest underground mine, a coal mine, is approximately one mile south of the site (Amvedo and Ivey, 1975). This distance indicates that subsidence due to mining activities would be unlikely at the facility. 1.5 SITE DOCUMENTS The following documents have been prepared for CWSL which cover design, technical evaluation and environmental programs: (1) "Preliminary Site Development Plan for Central Weld Sanitary Landfill, Weld County, Colorado" prepared by SEC Donohue, Inc. dated December 1992. (2) "Hydrogeologic and Geotechnical Characterization for the Central Weld Sanitary Landfill, Weld County, Colorado" prepared by Golder Associates Inc. dated July 1992. (3) "Ground Water Monitoring Plan for the Central Weld Sanitary Landfill, Weld County, Colorado" prepared by Golder Associates Inc. dated August 1992. (4) "Landfill Gas Monitoring Plan for Central Weld Sanitary Landfill, Weld County, Colorado" prepared by Golder Associates Inc. dated August 1992. (5) "Expanded Hydrogeological Investigation at the Central Weld Sanitary Landfill, Weld County, Colorado" prepared by Golder Associates Inc. dated October 23, 1992. (6) "PAP B-910 Special Waste Program for the Waste Services Corporation North Weld and Central Weld Sanitary Landfills, Weld County, Colorado," prepared by Waste Services Corporation dated February 1992. (7) "Additional Surface Water Sampling and Analysis at the Central Weld Sanitary Landfill, Weld County, Colorado," prepared by Golder Associates Inc. dated December 2, 1992. SENI0181111192.REP 1-3 2.0 SITE CHARACTERISTICS 2.1 TOPOGRAPHY The facility is located in a region of gently-rolling topography approximately 1,600 ft north of the Big Thompson flood plain. The rolling upland unit consists of broad areas of nearly flat to gently-rounded surfaces between major stream valleys. Elevations in the undisturbed areas of the site range from 4,750 ft to 4,840 ft. Surface drainage is to the south and southeast toward the Big Thompson River. A series of manmade ponds, referred to as Spomer Lakes, lie beyond the western and southwestern boundaries of the landfill. • 2.2 SURROUNDING LAND USE CWSL is located in a rural area of unincorporated Weld County. The surrounding land is primarily used for agriculture. The surrounding area consists of irrigated fields and row crops, nonirrigated field crops and pasture land. • 2.3 NATURAL AND GEOLOGIC HAZARDS The site is not located within a 100-year floodplain. According to the FEMA, the site is classified as Zone C - subject to minimal flooding. The nearest potentially active faults, the Rocky Mountain Arsenal Fault and the Valmont Fault, located approximately 27 miles to the south, are at a distance where significant seismic impacts at the facility are not likely. The nearest underground mine, a coal mine, is approximately one mile south of the site (Amuedo and Ivey, 1975). This distance indicates that subsidence due to mining activities would be unlikely at the facility. The area surrounding the landfill, as previously described, poses minimal potential for landslides in the undisturbed areas. SENOR\111192.REP 2-1 8,1 ns : /5 2.4 GEOLOGY The three geologic units which have been delineated at the site are: the (1) Surficial Unconsolidated unit; (2) Upper Weathered Bedrock unit; and (3) Lower Weathered Bedrock unit. The Surficial Unconsolidated unit is a yellowish-brown to brownish-yellow, eolian silty-clay to clayey-silt deposit which overlies the bedrock units at the site. This surficial unit is comprised of clay, silt, and fine sand. Thickness of the unit ranges from approximately 3 ft to nearly 30 ft across the site. Due to past landfill activities, this unit is no longer continuous across the site. Underlying the Surficial Unconsolidated unit is the Upper Weathered Bedrock unit, an interbedded to interlaminated silty-fine sandstone and claystone of the Upper Cretaceous age. Lenses of gypsum occur throughout the unit. The color of the unit ranges from dark grey to yellowish brown to dark orange. The thickness of the Upper Weathered Bedrock unit varies from approximately 40 ft to 70 ft across the site with the thickest area found near the southern boundary of the site. The lowest unit identified at the site, the Lower Weathered Bedrock unit, is a weathered, grey, interbedded to interlaminated silty-fine sandstone and claystone. Only the upper 15 ft of this Lower Weathered Bedrock unit was cored and sampled so a thickness has not been determined. The color of the Lower Weathered Bedrock unit is typically light to medium grey for the silty-fine sandstones and medium to dark grey for the claystones. 2.5 HYDROGEOLOGY Ground water at the site occurs in both an upper and a lower saturated zone. Hydrogeologic investigations indicate that based on a relatively dry zone identified during site drilling within the weathered bedrock, communication between the uppermost saturated zone and the deeper zone is minimal. secumns\m192.Ree 2-2 ; .D6t. 4; The uppermost saturated zone at the site occurs within the upper portion of the Upper Weathered Bedrock unit. Depth to this shallow zone ranges from 23 ft to 3 ft below the ground surface. The direction of ground water flow within this shallow zone is toward the south-southwest. The Spomer Lakes may contribute to recharge of the shallow zone. The lower saturated zone occurs in the Lower Weathered Bedrock unit. Depth to this lower saturated zone is approximately 60 ft across the site. Flow in this lower zone is toward the south-southeast. The CWSL is located in a predominately agricultural area. Consequent adjacent irrigation activities have required management of water levels within the landfill by the construction of a landfill underdrain and perimeter ditch french drain. The underdrain was constructed in late 1982 to early 1983 and is located in the western 1/3 of the site. The purpose of the underdrain is to maintain ground water levels below the base of refuse in the landfill. The underdrain generally consists of a gravel-filled dewatering trench excavated to a depth of approximately 8 ft below the predeveloped ground surface. A perforated metal pipe located in the bottom of the trench carries ground water, by gravity, to its outlet. The underdrain outlet is located west of the property and outfalls to the second lowest pond of the Spomer Lakes. A french drain was also constructed to maintain ground-water levels at elevations below the base of refuse. The french drain consists of a trench averaging about 8 ft deep below the bottom of the perimeter ditch. A 6-inch (in) perforated plastic pipe is located in the base of the trench and outfalls to the east side of the landfill to the detention pond. 2.6 CLIMATE The site is characterized by semiarid conditions on the Colorado Piedmont section of the Great Plains Physiographic Province. Mean temperatures vary between 24 degrees Fahrenheit C F) and 72.3° F. The mean annual precipitation for the area is 11.1 in. The maximum recorded 24-hour precipitation event is 3.4 in. The mean annual relative humidity 5ECV4018\111192.REP 2-3 F is 50 to 55 percent, and the mean annual evaporation rate is 70 to 80 in. The prevailing wind direction is toward the southeast. • SEC\14016\1 i 1192.REP 2-4 3.0 WASTE CHARACTERISTICS AND VOLUMES 3.1 WASTE CHARACTERISTICS The facility currently accepts household, commercial, and industrial solid waste. No hazardous wastes, radioactive wastes, sludges, or bulk liquids are accepted by the facility. Any vehicle Observed hauling unacceptable wastes to the facility will not be allowed to dispose such wastes at the site and will be informed to dispose such wastes at an appropriately permitted facility. Current gate rates are approximately 1,000 cubic yards per day (cy/day). The source of wastes accepted at the facility is from Central Weld County and the surrounding area. 3.2 REFUSE VOLUME The total remaining refuse airspace at CWSL is currently estimated at 4,015,000 gate yards. This estimate assumes an in-place refuse to soil ratio of 4.5:1 and a compaction ratio of two gate cubic yards (cy) to one in-place cy. Based on.the current gate rate of 1,000 cy/day at 300 operating days per year and assuming an annual volume growth rate of 2.5 percent, the projected site life is about 12.2 years. These estimates may change due to a variance in the actual growth rate, compaction rate, refuse to soil ratio, or other operational factors. • RECAP'S\11I191.REP 3-1 4.0 LANDFILL DESIGN AND CONSTRUCTION The SDP identified in Section 1.5 consists of Sheet Nos. 1 through 20. These sheets have been prepared with the objective of graphically showing the various aspects and details of landfill construction and operation. Each sheet addresses a specific segment of the landfill development at varying levels of detail. The major features identified on the drawings are: Sheet No. Title 1 Existing Conditions 2• Disposal Sequence Number 1 3 Disposal Sequence Number 2 4 Disposal Sequence Number 3 5 Disposal Sequence Number 4 6 Disposal Sequence Number 5 • 7 Final Grades/Surface Water Management Plan 8 Landfill Cross Sections 9 Landfill Cross Sections 10 Module 1 Excavation Grades 11 Module 1 Base Grades - Leachate Collection System 12 Runon/Runoff Surface Water Mgt. - Sheet 1 13 Runon/Runoff Surface Water Mgt. - Sheet 2 14 Runon/Runoff Surface Water Mgt. - Sheet 3 15 Runon/Runoff Surface Water Mgt. - Sheet 4 16 Runon/Runoff Surface Water Mgt. - Sheet 5 17 Final Cover, Liner, and Leachate Collection Details 18 Surface Water Management Details 19 Surface Water Management Details 20 Surface Water Management/Misc. Details SECV4W ew n92.REP 4-1 . 067, 02c 4.1 ACCESS AND HAUL ROADS The facility is accessed by Weld County Road 27 1/2 (77th Avenue) which is located to the east of the site. Access to the site is restricted by a fence around the perimeter of the landfill and a gate which is attended during operating hours and locked when the site is closed. Internal haul roads will be constructed based on need and the disposal sequencing to provide access to the active disposal area. "No trespassing" signs are posted along the perimeter fence. 4.2 ONSITE FACILITIES A gate house is located at the entrance of the facility. Vehicles entering the facility must check in at the gate house. Maintenance facilities are located onsite for servicing equipment and storing parts. An existing residence onsite is occupied by a facility employee. The existing entrance road and site structures illustrated on the SDP are subject to relocation. 4.3 STORMWATER MANAGEMENT 4.3.1 Runon The facility accepts runon from approximately 100 acres of agricultural land upgradient of the site. The runon is a combination of precipitation and irrigation water. The runon will be intercepted near the site boundary by a system of perimeter ditches. Runon in the northwest portion of the facility enters the site through existing culverts and flows to an onsite detention pond. From the detention pond, the runon discharges into the northernmost (uppermost) pond in the chain of Spomer Lakes. Runon to all other areas of the facility will be collected in a perimeter channel which will direct the flow around the perimeter of the landfill to an existing drainageway on the east side of the site. The runon detention pond in the northwest corner of the facility and all runon channels will be sized to accommodate the 100-year storm event. 4.3.2 Run The final grades at CWSL have been designed to promote positive drainage of stormwater and minimize erosion and ponding. The final grade design in combination with the use of SEN4016f111142.REP 4-2 F i n€ 1 daily and intermediate cover will promote runoff and prevent significant infiltration of surface water to the landfill. During construction of the landfill, berms, swails, ditches, or other hydraulic structures will be used to divert runoff away from the working face in order to minimize the quantity of water potentially contacting refuse. In addition, runoff velocity from incident rainfall will be further reduced by vegetation of final covered areas as soon as practical. Runoff from the north and northeast portions of the landfill will collect in a perimeter ditch and flow to a stormwater-detention pond located in the northeast corner of the site. The stormwater will then discharge from the pond to an existing drainage ditch along WCR 27 1/2 (77th Avenue) and flow toward the Big Thompson River. Runoff from the west and • southern portions of the site will sheet flow offsite. A portion of the south and east runoff will collect in a ditch along WCR 27 1/2 (77th Avenue) and flow south to the Big Thompson River. Runoff flow from the site will not exceed predevelopment flows. The onsite detention pond will have adequate capacity to detain flows which are above predevelopment levels for a 100-year storm event. 4.4 LEACHATE MODELING Leachate is water that has contacted decomposing refuse which contains organic and inorganic matter in suspended and dissolved form. The water can be introduced into a landfill in several ways, including infiltration of rainfall. Refuse, on initial placement, has a high capacity to absorb moisture before leachate is produced. Daily, intermediate, and final cover placed over the refuse protect the refuse from absorbing incident rainfall, and preserves the ability of the refuse to absorb moisture which would otherwise result in leachate. Cover soil absorbs incident rainfall and promotes runoff of stormwater. If the net water infiltrating into the cover exceeds the water holding capacity of the cover soil, infiltrating water contacts the refuse. If the net water reaching the refuse exceeds the ability of the refuse to absorb and retain liquid (the field capacity), leachate will be produced. SEC\34018\111197.REP 4-3 fr OR, Therefore, if the infiltration of water is minimized, the generation of leachate will also be minimized. The drainage control features and cover system at the site described in other sections of this plan are designed to prevent precipitation from entering the refuse. As an additional precaution to nlinimi7e the moisture content of the refuse, no bulk liquids are accepted at the facility. These measures in addition to the low precipitation rate at the facility combine to decrease the potential for leachate generation. The possibility that leachate may be generated as the result of water percolation through the final cover system has been computer modeled on a worst-case basis. This computer model, titled "Hydrologic Evaluation of Landfill Performance (HELP) - Version 2," considers the characteristics of cover soils, topography, refuse depths, vegetation, liner systems, rainfall, evapotranspiration, and rainfall infiltration. The model assumes that all layers of the landfill are at or near field capacity (saturated) and that leachate production would begin immediately. The results of the modeling conclude that even under these unlikely worse case conditions, leachate would not be generated as a result of percolation of precipitation through the final cover. The computer modeling results are presented in Appendix A of this plan. 4.5 FINAL GRADES Final grades have been designed to provide positive drainage after anticipated settlement, to minimize erosion, and to reduce long-term maintenance. The maximum final cover slope of 25 percent and minimum slope of 5 percent were designed to provide consistent runoff while minimizing erosion and preventing ponding. The maximum elevation of the facility is approximately 4,870 ft above sea level. The final grade contours shown on the SDP are approximate. In addition, operations activities such as stockpiling of soils for future liner construction, cover-placement activities, etc., may cause the final-grade contours to be temporarily exceeded. Final grades were designed such that the landform will be compatible with the surrounding land (see Sheet 7 of the SDP for a drawing of the final grades). SEC-14011\I11192.RP1 44 4.6 DAILY COVER Daily cover will be used at the facility at the end of each working day to prevent nuisance conditions such as vectors, litter, fire, and odor. Daily cover will consist of approximately 6 in of soil or an alternative daily cover (ADC) capable of controlling vectors, litter, and other nuisance conditions. 4.7 INTERMEDIATE COVER Approximately 12 in of intermediate soil cover will be placed over areas which will not be active for longer than one month. The purpose of intermediate soil cover is to minimize the amount of rainfall that might percolate into the landfill. Soil for intermediate cover will be obtained from onsite-excavation stockpiles or from alternate locations. 4.8 FINAL COVER Facility management envisions employing the Soil Final Cover design as specified under Section 3.5.3(a) of the Draft Regulations. This final cover design consists of a total of approximately 4.5 ft of soil; a 6-in foundation layer, an 18-in thick barrier layer having a hydraulic conductivity of less than or equal to 1 x 10.6 cm/sec, a 24-in thick protective layer, and a 6-in thick vegetative soil layer. The barrier layer will consist of compacted clays from onsite or alternate sources. The foundation layer and protective layer shall be composed of miscellaneous soil from onsite excavations or from alternate locations. The top vegetative layer of the final cover shall consist of soil capable of supporting vegetation. A quality- assurance program will be implemented during the final-cover construction. This program will include monitoring items such as visual observation of construction, practice, field and laboratory compaction control testing, and surveyed measurements of the landfill before and after final cover is completed. Facility management may, at its discretion, employ the Composite Final Cover design as specified under section 3.5.3(b) of the Draft Regulations which is presented in the Draft Regulations as equivalent to the Soil Final Cover design. The primary difference between these two designs is the barrier-layer component. Rather than specifying an 18-in thick low- permeability soil layer as required for the Soil Final Cover design, the Composite Final SEN40181111192.REP 4-5 Cover design specifies a geomembrane with a minimum 30-mil thickness and which displays properties adequate for its intended purpose. The final selection for the final cover design will be largely based on the availability of low- permeability soils required for the Soil Final Cover design. 4.9 REVEGETATION All areas of final cover and areas of intermediate cover which will remain undisturbed for longer than one year will be revegetated. Permanent revegetation of final-covered areas will consist of placing shallow-rooted native grasses as recommended by the Soil Conservation Service. • SECU40181111192.REP 4-6 92106,a, 5.0 LANDFILL DISPOSAL SEQUENCING The general landfill development is envisioned to occur in six sequences. The first sequence begins at the north end of the existing fill area and proceeds to the south. The fill- sequencing plan was developed to: (1) provide an orderly approach to filling; and (2) provide a sequence to control surface water runon/runoff. The fill-sequencing plan may be modified to address future conditions while maintaining consistency with these two design parameters. Intermediate and final elevations will be achieved by constructing a series of lifts approximately 10- to 15-ft thick. The lifts will be compacted and then covered at the end of each working day with approximately 6 in of soil or ADC. Approximately 1 ft of intermediate soil cover will be applied where additional refuse will not be placed for periods longer than one month. Within approximately 6 months after final refuse elevations in a 10- to 20-acre area are reached, the final cover will be placed as described in Section 4.8 of this plan. The general landfill development can be seen on Sheets 2 through 7 of the SDP. sECJ4meulilft.REP 5-1 6.0 LANDFILL MODULE DEVELOPMENT Module 1 shown on Sheets 10 and 11 of the SDP may be developed in the final disposal sequence at the site. This module will be constructed to meet all applicable government agency regulations. The module design currently includes a 3-ft thick cohesive compacted soil or equivalent liner meeting the required 1 x 10'' cm/sec maximum permeability per Section 3.2.5(c)(2) of the Draft Regulations. Based on availability of low-permeable soil, facility management may choose to employ the composite liner design as allowed under Section 3.2.5(c)(3) of the Draft Regulations. The composite liner includes an upper component consisting of a minimum 30-mil flexible-membrane liner(minimum 60 mil if high density polyethylene is used) and a lower component consisting of a minimum of 2 ft of compacted soil with a hydraulic conductivity less than or equal to 1 x 10-' cm/sec. A leachate collection system will be installed over the base liner. The leachate collection system is designed to meet the performance requirements of Section 3.5.2(c) of the Draft Regulations. This module will be developed by placing 10- to 15-ft thick lifts across the entire module and filling upward until the final grades are obtained as shown on Sheet 7 of the SDP. A quality assurance program will be implemented during liner system placement. This program will include visual observation of construction practice, field and laboratory compaction control testing, and surveyed measurements of the liner system before and after the liner system is completed. 6.1 EXCAVATION GRADES/BASE GRADES The excavation sideslopes for Module I will not be steeper than 2-ft horizontal to 1-ft vertical in order to maintain slope stability. The excavated material will be stockpiled for use as daily and intermediate cover during operations at the landfill. Low permeability soils classified as clays will be stockpiled and utilized for liner material and/or final cover. • SEC1140111111192.REP 6-1 Base grades will b.e prepared as shown in the Disposal Sequence Plans and Base Grade Design Plan of the SDP and will typically be sloped at a minimum of 2 percent to provide positive drainage to a leachate collection system. 6.2 LEACHATE COLLECTION AND MONITORING In addition to taking the measures mentioned in Section 4.4 to prevent leachate production, a leachate monitoring and collection system will be installed in Module 1. The installation will be verified by observation, inspection, testing, and documented by a written report furnished to applicable government agencies. The leachate collection system will consist of perforated pipe in gravel filled trenches. The trenches will be constructed to provide positive drainage to a central collection and monitoring point located at the perimeter of the module. Sheets 11 and 17 of the SDP provide details of the leachate collection system. SECJ401euuIn.REP 6-2 O 2 7.0 OPERATIONS AND MAINTENANCE 7.1 HOURS OF OPERATION The CWSL is generally operated Monday through Saturday from 7:00 a.m. to 4:30 p.m. The facility will generally be closed on Sundays and major holidays. Facility hours may be extended before, during, and after a holiday to accommodate additional incoming wastes. Actual facility hours may also vary depending on site conditions, seasonal changes, or other operational variables. The site entrance gate is attended at all times when the site is open to the public. 7.2 SIGNS POSTED Signs are posted at the site entrance indicating the name of the facility, name of the operating authority, hours and days of operation, and price rates. In addition, a sign which lists prohibited wastes will be located at the entrance to the landfill. Traffic control and safety-requirement signs are located around the facility as deemed appropriate by the facility management. 7.3 WASTE CONTROL Incoming-waste loads are directed to the proper disposal area by a gate attendant and/or signs. If landfill personnel at the gate or the working face observe attempted disposal of unauthorized wastes, the driver will be turned away or instructed not to unload. If unauthorized wastes are observed after unloading, landfill personnel will carefully attempt to segregate them from the active disposal,area and will contact the transportation company and/or generator to remove the wastes. Depending on the nature of the waste, appropriate state or local agencies may be notified. 7.4 SITE PERSONNEL 7.4.1 Personnel CWSL is owned and operated by WSC. The manager assigned to the facility is responsible for the overall operation of the landfill. The facility manager can be reached at the site at (303) 330-2641. In addition, an environmental engineer/environmental specialist is assigned SECJ40I ern I192.REP 7-1 to the facility to assist the facility manager in ensuring compliance with applicable regulations. Personnel assigned to the site may include the following. Position Number Facility Manager Environmental Engineer/Environmental Specialist 1 Operators 3 Mechanics 1 Ticket Clerks/Administrative 1 Laborers • Total 8 The number and task of personnel may vary depending upon current site conditions; however, sufficient staff will be employed to operate the site in a safe, efficient manner. All field personnel will be trained in safe and proper landfill operating procedures. 7.4.2 Personnel Health and Safety The following are examples of measures implemented to minimize possible health and safety hazards to the site-operating personnel: • Ongoing operator safety-training courses; • Identification of wastes prior to acceptance; • Onsite first-aid supplies and hygienic facilities; • First-aid and CPR training; • Emergency management and response training; and • Spill Prevention Control and Countermeasure (SPCC) training. SEC\J/O1811I I I92.REP 7-2 '} 7.5 OPERATING EOUIPMENT The following pieces of equipment are currently maintained onsite and utilized for the landfill operations: Description EQI , Bull Dozer 1 Refuse Compactor 2 Motor Grader 1 Water Truck 1 Backhoe ] Total 6 These types and numbers may vary, however, equipment capable of performing the necessary site operations will be maintained onsite. Routine maintenance and cleaning of the equipment will be performed as necessary to keep the equipment in good operating order. 7.6 CONTROL OF NUISANCE AND HEALTH FACTORS Site operating procedures include actions to minimize nuisance and health factors such as odors, dust, wind-blown litter, noise, site appearance, fire prevention, and control of vectors. 7.6.1 Odor Control Measures will be taken at CWSL as necessary to reduce and control odors. Practices such as the application of daily cover and immediate application of cover over wastes with strong odors will be conducted. 7.6.2 Dust Control Dust generation at the landfill can occur from soil excavation, soil transport and placement, refuse compaction, and vehicular travel on access roads. Dust raised from vehicular movement is controlled by wetting roads with water and/or commercially available SECV101A\111192.REP 7-3 .3106_", Si compounds. Stripped areas and stockpiles will be limited in area. Stockpiles which will be undisturbed for longer than one year will be revegetated. 7.6.3 Noise Control Noise from onsite equipment will be controlled by the use of equipment muffler systems and by performing routine maintenance to keep equipment in proper operating condition. 7.6.4 Site Appearance All signs, fencing, and structures at the landfill will be maintained. Vegetative cover will be maintained along the entrance roads and on other areas in accordance with Section 4.9. 7.6.5 Litter Control Litter control will be achieved by the following: • Minimizing the size of the working face to the smallest area practical; • Covering the active area daily; • Using fencing to minimize offsite litter; • Using portable windscreens and temporary fencing in the area of the working face; • Requiring incoming loads to be covered during transportation to the site; • Policing the perimeter fence and areas adjacent to the facility; and • Employing temporary laborers to clean up any litter that is not controlled by operational measures. 7.6.6 Vector Control Insects, rodents, and birds will be controlled by placing daily cover to discourage food gathering and harborage. A commercial vector control company will be retained if necessary. Positive drainage will be maintained to eliminate potential mosquito breeding areas. SECU401e\111192.REP 74 324 ofg",.,.3,2 7.6.7 fire Protection Fire protection of landfill equipment and vehicles will be provided by portable fire extinguishers kept with each unit. The gate house and maintenance facility will be equipped with suitable fire extinguishers for suppression of any minor fires and for safety of personnel. Typically, any fire that occurs on the landfill will be extinguished by landfill personnel using stockpiled soil cover to smother the fire. No burning of waste is permitted at the facility. Additional fire-protection coverage is available via telephone communication to the local fire department to respond to major occurrences of fire. Vehicles containing burning materials that would otherwise be acceptable will be directed to an inspection area where the vehicle driver can safely extinguish the fire. The vehicle will then be directed to an isolated disposal area onsite where the individual load can be safely unloaded from the vehicle, covered with soil, and observed for a period of at least one week. In this manner, facility operators will be able to confirm that no burning material remains in the disposed waste. 7.7 RECORD KEEPING A system of records will be maintained at the facility office during the life of the landfill. These records will include items such as incoming-waste volumes, ground-water quality monitoring results, landfill-gas monitoring results, as-built construction plans, and approved variations from standard operating procedures. These records will be available for review at the site to authorized agents of the County Board of Commissioners and the Colorado Department of Health. SECV4Otewrt92.REP 7-5 $S21n(g'" 33 8.0 ENVIRONMENTAL MONITORING Environmental monitoring at CWSL includes ground water, landfill gas, and surface water. Monitoring will be performed as described in the following sections. 8.1 GROUND WATER MONITORING A system of ground-water monitoring wells has been installed to monitor both the shallow and deep ground-water zones. The ground-water wells will be monitored in accordance with the facility's Ground-water Monitoring Plan. 8.2 LANDFILL GAS MONITORING Soil gas probes were installed at the facility spaced approximately 500 ft apart along the perimeter of the site. Three additional probes were installed at the site; one probe near each of the three building areas on the site. The soil-gas probes will be monitored for combustible gas (methane) concentrations in accordance with the facility's Gas Monitoring Plan. Continuous gas detectors will also be installed in the gate house and residence located onsite to monitor for the presence of methane. 8.3 SURFACE WATER MONITORING The landfill underdrain discussed in Section 2.5 is currently monitored quarterly. A Colorado Discharge Permit System (CDPS) permit application has been filed with the Water Quality Control Division (WQCD) of CDH. The underdrain monitoring may change based on WQCD's review. The french drain also discussed in Section 2.5 is not routinely monitored as its flows are currently managed onsite. As CWSL intends to file for a CDPS permit for the french drain, a monitoring program for this drain may be developed in the future. 8.4 LEACHATE MONITORING The site currently does not include a leachate collection/monitoring system. However, such a system is included in the Module I design which may be developed as part of the final SEC J40181111192 8-1 9':106...v. -547 disposal sequence at the site. A leachate monitoring program will be developed for Module 1 prior to commencing landfilling in this module. SECW W eU I I192.REP 8-2 9.0 CLOSURE AND POST-CLOSURE ACTIVITIES Closure and post-closure provides for long-term operation of the environmental monitoring systems and long-term inspection and maintenance of the final cover and stormwater management structures. Sixty days before site closure, the facility will notify the County Commissioners and the Colorado Department of Health. In addition, a sign will be posted at the entrance notifying the public of the closure date. Upon the completion of the site-closure activities, post-closure monitoring/long-term care activities will commence and continue for a time period as required by state regulations. Post-closure care activities will be performed in accordance with applicable regulations and are expected to include the following: • Land surface care consisting of periodic site inspections and repair of any eroded final cover or vegetated areas; • Ground-water monitoring and system maintenance; • Landfill gas migration monitoring and system maintenance; • Leachate collection system monitoring and maintenance; and • Security fence and enclosure inspection, and repair and maintenance of same. The frequencies associated with conducting the various post-closure activities will be established by CWSL prior to site closure. Financial assurance, as required, will be maintained by the facility to ensure funding is available for the completion of the required closure and post-closure activities. SECV40181I I1192.REP 9-1 F FC106. 3o, APPENDIX A HELP MODEL WATER BALANCE 5371084..., 37108. f CENTRAL WELD SANITARY LANDFILL HELP MODEL ANALYSIS OF FINAL COVER DECEMBER 30, 1992 BY: MIKE WEINSTEIN LAYER 1 VERTICAL PERCOLATION LAYER THICKNESS • 6.00 INCHES POROSITY 0.4730 VOL/VOL FIELD CAPACITY • 0.2217 VOL/VOL WILTING POINT • 0.1043 VOL/VOL INITIAL SOIL WATER CONTENT • 0.2000 VOL/VOL SATURATED HYDRAULIC CONDUCTIVITY • 0.000719999953 CM/SEC LAYER 2 VERTICAL PERCOLATION LAYER THICKNESS • 24.00 INCHES POROSITY • 0.453'0 VOLP/OL FIELD CAPACITY • 0.1901 VOL/VOL • WILTING POINT • 0.0848 VOL/VOL INITIAL SOIL WATER CONTENT • 0.1800 VOL/VOL SATURATED HYDRAULIC CONDUCTIVITY • 0.000719999953 CM/SEC • LAYER 3 BARRIER SOIL LINER THICKNESS = 18.00 INCHES POROSITY • 0.4750 VOL/VOL FIELD CAPACITY •• F0.3777 VOL/VOL WILTING POINT • 0.2648 VOL/VOL INITIAL SOIL WATER CONTENT • 0.3400 VOL/VOL SATURATED HYDRAULIC CONDUCTIVITY 0.000001000000 CM/SEC 1.71".11 .”_..M6 38 LAYER 4 VERTICAL PERCOLATION LAYER THICKNESS 6.00 INCHES POROSITY • 0.4530 VOL/VOL FIELD CAPACITY a 0.1901 VOL/VOL WILTING POINT • 0.0848 VOL/VOL INITIAL SOIL WATER CONTENT = 0.1800 VOL/VOL SATURATED HYDRAULIC CONDUCTIVITY = 0.000719999836 CM/SEC LAYER 5 VERTICAL PERCOLATION LAYER THICKNESS = 720.00 INCHES POROSITY = 0.5200 VOL/VOL FIELD CAPACITY = 0.2942 VOL/VOL WILTING POINT = 0.1400 VOL/VOL INITIAL SOIL WATER CONTENT = 0.1700 VOL/VOL SATURATED HYDRAULIC CONDUCTIVITY = 0.000099999997 CM/SEC LAYER 6 BARRIER SOIL LINER THICKNESS = 120.00 INCHES POROSITY • 0.4300 VOL/VOL FIELD CAPACITY a 0.3663VOL/VOL WILTING POINT = 0.2802 VOL/VOL INITIAL SOIL WATER CONTENT = 0.4300 VOL/VOL SATURATED HYDRAULIC CONDUCTIVITY = 0.000=72499989 CM/SF.C GENERAL SIMULATION DATA SCS RUNOFF CURVE NUMBER • 78.00 TOTAL AREA OF COVER • 4704480. SO FT EVAPORATIVE ZONE DEPTH s 30.00 INCHES UPPER LIMIT VEG. STORAGE = 13.7100 INCHES INITIAL VEG. STORAGE = 5.5200 INCHES INITIAL SNOW WATER CONTENT = 0.0000 INCHES INITIAL TOTAL WATER STORAGE 1N SOIL AND WASTE LAYERS = 186.7200 INCHES SOIL WATER CONTENT INITIALIZED BY USER. CLIMATOLOGICAL DATA SYNTHETIC RAINFALL WITH SYNTHETIC DAILY TEMPERATURES AND SOLAR RADIATION FOR DENVER COLORADO MAXIMUM LEAF AREA INDEX • 2.50 START OF GROWING SEASON (JULIAN DATE) • 128 END OF GROWING SEASON (JULIAN DATE) • 284 NORMAL MEAN MONTHLY TEMPERATURES, DEGREES FAHRENHEIT JAN/JUL FEB/AUG MAR/SEP APR/OCT MAY/NOV JUN/DEC 23.80 28.70 35.80 47.20 57.30 67.20 73.80 71.40 61.80 50.20 35.40 27.50 AVERAGE MONTHLY VALUES IN INCHES FOR YEARS 1 THROUGH 20 JAN/JUL FEB/AUG MAR/SEP APR/OCT MAY/NOV JUN/DEC PRECIPITATION TOTALS 0.34 0.41 1.18 1.18 1.46 1.66 2.37 1.06 0.66 0.76 1.20 0.35 STD. DEVIATIONS 0.23 0.28 0.44 0.72 0.83 0.73 1.38 0.57 0.32 0.64 0.78 0.23 RUNOFF TOTALS 0.000 0.000 C.UCG C.003 0.000 0.000 0.000 0.000 0.000 O.OOC 0.000 0.000 STD. DEVIATIONS 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 EVAPOTRANSPIRATION TOTALS 0.522 0.656 0.956 1.221 1.394 2.326 2.282 1.149 0.620 0.525 0.576 0.530 STD. DEVIATIONS 0.214 0.378 0.420 0.673 0.706 0.829 1.122 0.591 0.367 0.379 0.203 0.262 PERCOLATION FROM LAYER 3 TOTALS 0.0000 0.0020 0.0075 0.0049 0.0031 0.0001 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 /�/ (371.06_a_ 4D STD. DEVIATIONS 0.0000 0.0088 0.0293 0.0186 0.0118 0.0004 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 PERCOLATION FROM LAYER 6 TOTALS 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 STD. DEVIATIONS 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 AVERAGE ANNUAL TOTALS 8 (STD. DEVIATIONS) FOR YEARS. 1 THROUGH 20 (INCHES) (CU. FT.) PERCENT PRECIPITATION 12.63 ( 2.761) 4952446. 100.00 RUNOFF 0.000 ( 0.000) 9. 0.00 EVAPOTRANSPIRATION 12.758 ( 2.753) 5001589. 100.99 PERCOLATION FROM LAYER 3 0.0176 ( 0.0688) 6889. 0.14 PERCOLATION FROM LAYER 6 0.0000 ( 0.0000) 0. 0.00 CHANGE IN WATER STORAGE •0.125 ( 1.246) •49153. •0.99 PEAK DAILY VALUES FOR YEARS 1 TMRCUGH 20 (INCHES) (CU. FT.) PRECIPITATION 1.48 580219.2 RUNOFF • 0.000 183.6 PERCOLATION FROM LAYER 3 0.0064 2523.9 HEAD ON LAYER 3 0.0 PERCOLATION FROM LAYER 6 0.0000 0.0 HEAD ON LAYER 6 0.0 SNOW WATER 1.05 409963.1 MAXIMUM VEG. SOIL WATER (VOL/VOL) 0.2028 MINIMUM VEG. SOIL WATER (VOL/VOL) 0.0884 FINAL WATER STORAGE AT END OF YEAR 20 LAYER (INCHES) (VOL/VOL) 1 0.61 0.1017 2 2.05 0.0855 3 6.12 0.3400 4 0.88 0.1468 5 122.95 0.1708 6 51.60 0.4300 SNOW WATER 0.00 FIGURES N.) 1 ( 1 / \) 1 ' - ' •..'�,,,sii—sow.-- I si ,s I 1 ) Y' <. s o ul 1 30 1 24\ ) • / / k .- il i - ( --• m t .^ bii 11 1 .A�/ \ 1 1' f� ' \Siiiii , li _ • I l •ells 3 ' \ 9918 ' Ttl( �' , \ _. •iin ,1 tl. .`\ .1f- 1 - ( Jt II V I , • 1 �� '• '�A�\I . 1f1. P\ \V1 lII 1'�A, (1 it % �e�� 1\ ` i� I. ▪ O II i 1 ., 1 III 1 . 1111�1.' II ' 1 M.fo / ( I II l''!1,'Nj \ \ I 'II �1 APPROXIMATE SITE LOCATION II 1 ) W lid.' .�A )\' / �' \ ‘,:\,\I'. ( • 32 1 ‘,.1, • / f L e^ ' : it. I A I ' ' !Iy V •nr at '' ,i ' i I Jyo . ` 4 G i .'4- ₹a '_ __1 ..__tea , 3: : i W 1 nit^ ter:ril I i I 1.1, 1+f 1 \ ;• ' . •1't' `n.IJJ 11 II i1. '"J '� .•4 . (GIN lA1 JJJ i it; . \SH . 1/4> '., ,, , ,, . , t• .- ' IL i 2CD I II ' 1,,, '1' � ' It' 'I a • ! (/f� J B - \�a.,111 11 �' .•. . , . 6.0 \ , \ \•Q� I 69' tg KK .5 1? i \j . , it l..% `�/s]7 fin' i \ • W ; I c tar .'•. . v• ;to _--3.7- ..o. Onniels AS-IrcH rSch n+ •••c, X1.6 •62 /In M,oM V/ . 1 • i I ( I 19 ..0 7 ) . .. I l ` I �� n��TTnn��j]j� ��'+ FIGURE 1 \JECDOl OHIJE SITE VICINITY MAP L;:- CENTRAL WELD SANITARY LANDFILL �/, WELD-COUNTY, COLORADO 6.1 Environment R Infrastructure u WASTE SERVICES CORPORATIpj\1r • 1 • • py `' •,, \ - l I (. 0 HAW♦ ___ _ _ -1 1 s ---_\-- C - in• Ia I 1 ° e 7 ' 11 .1• _ .! _ ._ .a 70 70• (o I „ .. 4. $W ri 1 1 C - , V rr1 Girl 1� . ` 1 II• I S \ .\ 1 ,NS ... ` I .� 1i; - —t ' N _s o 1 \ , ' — ' '� • =3`=k 1.g ,_, ;r, Part �. 0g ° k, •� I - `i, I, ' 1; .L . ,r .i I MII " vim. ` •. I • a a' _ \(t. �►1�R�,,•j•+ 1 Si nail I IEtt • = y , t1, N [ Set ^ .- • N _ f r TCe •n, ItaleleI ,. Pr` Corrs .Sean \'1 ^� M Ir.... la. e t n I ,.i �.( F ei\ n ", " �• Oarn.sawne - ,`C•r♦�. \ - . IPrI "It!, ''� Bru ii n 1 �:'. y ACI AI N� x c %.. 'I, 11 Iq ( ♦ _ • -S 8 I A��,- Iy,..►.Iil_ •ly o 1 I, p . • _- ._ wor 1`! ��.._._._-_ Wil (IT r le I/S' .LI(:� J lIy` _ � r�-�;W^y r.. �J ' _t�;1i •s.� \'" k• u Y l.^ , w _ \ Ixy I ' ^ n- ' e l�Nlr. Eln tol :�' I de, 'm• ' _� �°n Min , l.4r�%!a - :. Iris _. •��,I�� r— l 1 . ' I a 1 C v�.r� Dim, m II I r r,L i� •a. n• , L 'n JI •dehn,MI , ; t .,, w , ,,I �n, (( f CMS , --� � a z S 1. 1' � _.. 1.. 2/' C lrr w H )' IrP a I ( I/ Ej j',1%;;."& /( r,e.SS' c• r4e I d01_�s,•rr • _1:.. - i N � .. - I J X P ends 1 ' el uP Hof I' ›. I/„ . r •... dm.. •• ... .. L„47 I 2 140133 /'IMs • �' I/ t/f(/ l rsl yw, .. •- .�. ty I �\ y.tin.l. - /u �I :tee r{t I V C 1. 1-�: • $ ...' P^ era ,'�.rr.. , a I -41-p- a" Iceeta° r • V , tit O. �Q. - .��.`,, v /� ' i!(J'• a) 1r°I /w�.. . .are ,I R 5 W. 'Y ♦ " ` P,. I �.. 'II \ lI"/ �' GG/Ir 11I , to S�f I I .l•. / r win• <,. KK r I .,. 4�!anti Yr I �11•I y 1 • r� Ep _ [' Ie '` r e�it►�1�:F'}�`�!1` 6 �I` t 7 1 ►Ill r . tl. .e ill 64 -1 JP e \ 7 - I I'1�1 �V_ti911�:; I i:fiT// 0 I I;•,,• ,1��,,,,,lll I .7.7•477 '4 `l. I- II R in �\ i• . ' w 1 .'�•,a 1''/rll 3 �'_. • \L1 I'I ,,,,I. + • FIGURE 2 SITE LOCATION MAP u � �N T ,t ,,., CENTWELDAL WELD NTYNICORORADO FILL LA yl\ )j�J`' ��rj"�+ WASTE SERVICES CORPORATION F •t4�.o6". //5 APPLICATION FOR COLORADO DISCHARGE PERMIT SYSTEM WASTE SERVICES CORPORATION CENTRAL WELD SANITARY LANDFILL Weld, Colorado NOVEMBER 1992 F 931061 2fc Waste Management of North America, Inc. %e Mountain Region 5660 Greenwood Plaza Blvd. • Suite 100 Englewood. Colorado 80111 • E . 303;770.3324 November 25, 1992 Ms. Patricia Nelson, Industrial Unit Leader Colorado Department of Health Water Quality Control Division Permits and Enforcement Division WQCD-PE-B2 4300 Cherry Creek Drive South Denver CO 80222-1530 SUBJECT: COLORADO DISCHARGE PERMIT SYSTEM (CDPS) PERMIT APPLICATION FOR WASTE SERVICES CORPORATION; CENTRAL WELD SANITARY LANDFILL Dear Ms. Nelson: Enclosed are two copies of a Colorado Discharge Permit System (CDPS) permit application and related attachments for an underdrain discharge at Central Weld Sanitary Landfill(CWSL), Weld County, Colorado. There appears to be a question as to whether a permit is required for the underdrain at this time. However, we are submitting the application to avoid future questions. The Division's review and approval of the enclosed application is requested. CWSL is located approximately three miles southwest of Greeley (see Attachment 1) in a predominantly agricultural area. The facility is a permitted operating sanitary landfill which began operations as early as 1967. The CWSL is owned by Waste Services Corporation (WSC) which merged with Waste Management of Colorado, Inc. (WMC) in July 1991. The underdrain was constructed in late 1982 to early 1983 and is located in the western 1/3 of the site. The purpose of the underdrain is to maintain groundwater levels below the base of refuse in the landfill. The underdrain generally consists of a gravel-filled dewatering trench excavated to a depth of approximately 8 feet below the predevelopment ground surface. A perforated metal pipe is located in the bottom of the trench and a compacted soil cap was placed over the top of the trench. The underdrain outlet is located west of the property and outfalls to the second lowest of four manmade ponds referred to as Spomer Lakes. The upgradient (northern) elevation of the underdrain is approximately 4810 feet M.S.L. and its downgradient (southern) elevation at the outlet is about 4763 feet M.S.L. The general location of the underdrain is shown on Attachment 2. wp514.1cweldapp.909 F. CWSL 1.10w/em/3.1 wits mac F 931061 L[/- If you have any questions or need additional information, please do not hesitate to contact Bill Hedberg 1-330-2641 or Alan Scheere at 770-3324. Thank you for your assistance. Sincerely, / //11272,4Cfig,/ Bill Hedberg Alan Scheere Division V.P. Landfill Operations Environmental Specialist AS/mmp Enclosures cc: Julie Kraus, Colorado Division of Water Resources, w/ enclosures John Pickle, Weld County Department of Health, w/o enclosures Roger Doak, Colorado Department of Health, w/o enclosures Victor Sainz, Colorado Department of Health, w/o enclosures • wp51 W lcweld.pp.909 F CWSL 1 10 w/eocl3.1 w/o eoc 931061 /Fs) FJ j INDUSTRIAL WASTEWATER DISCWARGE APPLICATION FOR. AGENCY USE APPLICATION NUMCER / / / I / / / / / / / / / / / / / / / / / / DATE RECEIVED / / / / / / / / / / / / / / YEAR MONTE DAY Do not attempt to complete this form before r.adiag the accompanying instructions. NEW X RENEWAL Existing permit number C0— PLEASE PRINT OR TYPE 1. Name, address, and telephone number o= the owner of the facility producing discharge. Property Owner(s) Waste Services Corp. Central Weld Sanitary Landfill (CWSL) Telephone Number ( 303 ) 330-2641 Ares Code mit ng Address 6037 77th Ave. Street Address 6037 77th Ave. City Greeley State Cn Zip Code 80634 2. Is the facility operated other than by the owner? Na X Yes Operator Telephone Number ( ) Area Code Mailing Address Street Address City State Zip Code -4- 931061 L (1- ` 3. Specify whether owner or operator is making application for the permit. Owner and operator are the same. 4. Location of facility: Legal description (Township, Range, 1/4 Section) SW 1 of Section 32 T 5N R 66W Street 6037 77th Ave. City Greeley State CO County Weld Zip Code 80634 Local Contact (familiar with facility) William Hedberg Telephone Number ( 303 ) 330-2641 Area Code Name of operation Central Weld Sanitary Landfill (CWSLL 5. If you have an existing NPDEr or CDPS permit go to Item 6. If you do not have an existing NPDES or CDPS permit go to Item 9. 6. If a priority pollutant scan (organic toxic pollutants listed in Appendix A) has been previously submitted, give the date of submittal: If a Materials Containment Plan or Spill Prevention and Containment Plan ' has been submitted, give the data of submittal: 7. Has all of the information required in this application form been previously submitted to the Water Quality Control Division - Permits Section and is it accurately stated in your present permit? No On this application, provide that information not previously submitted and/or explain any updated information. Yes All applicants (new or renewals) must submit recent analyses as required in Item 19 A. 8. Has there been any change in chemical usage, either type or quantity, or any change in operating conditions at the site or any change which could affect the effluent quality? No Co to Item 25. Yes Complete all information on the application which pertains to the changes. -5- r 931061 50 9. A location map (preferably a topographic map) designating the facility propertyorS mdiin1utege USGSints quads sheet he or a map of• The comparablep ,hall be scale. A� north arrow shall be shown. Any public water supply intakes within 5 miles downstream of the facility shall also be identified. Included in Attachment 1, Fig No. 1-2. 10. Type of facility (power plant, petroleum refinery, etc.) plus brief description of the nature of the business and the industrial processes used. (The applicant may want to submit a process flow sheet. ) If this is a seasonal operation, list the months of operation. CWSL is a permitted operating sanitary landfill , managing non-hazardous municipal , commercial and industrial waste. No bulk liquids or radio- active materials are received at the site. Tnere are no industrial processes occurring at the site.. • 11. The principal product(s) and maximum production rats. NA 12. Standard industrial coda (SIC) Number (if known) 4953 . 13. A legibls_general sketch of the site shall be submitted and include appurtenant facilities (building, ponds, diversion ditches, intake structures, well locations, stockpiles, etc.), stream and other surface water locations, numbered discharge points, sampling and flow monitoring points. Sketch shall be on paper 8-1/2 r 11 inches. The discharge points on the sketch shall be labeled to correspond with the outfall numbers listed in Table 14 A. Included in Attachment 2. 8 1/2 x 11 and 11 x 17 sizes provided. 14. Table 14 A - for each outfall provide: (1) The name of the receiving stream; (2) A description of all operations contributing wastewater to the effluent (steeple: water associated with each industrial process, sanitary wastewater, groundwater, cooling water, .storm+ater, runoff, etc.); (3) The average and maximum flow contributed by each operation; and (4) The treatment received by the wastewater prior to discharge as well as the design capacity of the treatment system. Continue on additional sheets if necessary. Begin with outfall number 001 and number sequentially. If chemical additives (example: algicides, corrosion inhibitors, flocculants, etc.) are used at the plant fill out Table 14 B. -6- • F 51 I 0, T x M U .... c 9 y O. p. w 9 F+ to .. r U 0i a z , 0 , U wF c C. S C C. <r kJ z 9 00 G i C. F {t u 2 x o _ - C in ac a C. ••••{� E d to 00 C. U Lca .+ ` >. 0A .r O z 0 9 C c a, O C O 9 z - .a C 3 > C - 47 O S J C O I-. > C�'J or to r 0 AC 7'. O C a. - v tV a7 CJ - X c in > . [.. Q • . .r L C: • m ._ . - v .:".••4V 9 Z T�p O q ac 832 o.. 0U ^ 9 a i O t A 2 W M V v rn J I - iii ? J • ..0L. C 0 u 9 C Cal CO 3 9 a. y x O t W. V C L L C 5. J ON I 6 4., r, yJ 7 F b w t - > 31. C. 0 CJ 2 O - r V O 0 7 = $.1 4J 0 Ci 571 0 x -. Y .J U V o C C. L. Li c r O. C o .-C- C. 9 U T s c .. A r .. S C W U C l. .� U 3 L s c 9 7 L Oa C• X. a rZ.4 ,„- I al t -3 o ca u L. za c J c - .... C.. U. xi r-• .. a = -- F O == 4. TJ • c v it s x r0 "CI 9310615.2 • C .°.. C a O S 0 0 Om CU 44 C m Y 0 e 0 G ;A- a — 0 9 O a C Y 9 am LI - a s a a 0 C . 3 3 y $ 0 0 Y Y Y e • C 7 L 4 .0.1 Y C m a °tiii 0 Y L L • Y 3 a Y m • 001j O a n Y a L Y C is y la - . • a m a Yr ds a i, _ _ a 0. Y 9 O Y ✓ a W mm" d u.. ¢ Y — t 0 as a 0 7 CO CO 0 C W Y i - L C C C a C m m : m } a — trl 0 0 0 0 .0 ^ Y — I e d m c CO vmmL W 4 7 1 F u 7 a a m c u c ... ... r Ed b is Co* 0 C C a C m ° Mb C is 7 Y a °• 0 Y ° a a. c W a 0 O C a 0 a W y - W Y O " C c a 9 0 Y C r L a C -c Y 9 s• O = .0„ 944 C an 0 A 0 C 0 0 0 .C + .. 0 O y y O C 0 e Y Y n+ a 't 01 Sa 9 0 t' _ CO • e y a W 9 C C o .. y u W FF = n• d a a C '+ L L C a CJ C m C Y L a L. b 9 Y C vs A 41a W e d 41 0 a—m o e a s L. Y — L a r O 0 U a = t. Ill N - a " ma O 0 Y L 01 u e Y N ° m a`, c c o d a C = 5 W c 9 — y u O a al u m."a t • a < a •-• 0 C 3. a"' a L Ts 0 6J = 0. u a r r v . F 931061 53 15. Method of flow measurement for each discharge (i.e. 90 v-notch weir. pump capacity, parshall flume, etc. ) Designate whether currently installed or proposed. Identify the minimum and maximum flow measurement capability. Proposing the installation of a Paddle Wheel F1QI,LMeter. 16. Attach a line drawing showing the water flow through the facility. Indicate sources of intake water, operations contributing wastewater co the effluent, and treatment units labeled to correspond to the more detailed descriptions on Table 14 A. Construct a water balance on the line drawing by showing average flows between intakes, operations, treatment units, and outfalls. If a water balance cannot be determined , provide a pictorial description of the nature and amount of any sources of water and any collection or treatment measures. Elevation contours and flow direction of the shallow groundwater beneath the site included in Attachment 3. 17. Except for storm runoff, are any of the discharges described in Table 14 A intermitent or seasonal? Nom_ Yes Describe the frequency, duration and flow rate of each discharge occurrence. • • • 18. A. Do you have permits under any of the following programs? No Mined Land teclamation NA Underground Injection Control NA Dredge or fill permit under Section 404 of the Clean Water-Act (CWA) NA Sesource Conservation and Recover Act (ICU) NA B. Do you have a certified operator? NA No Yes Name Certification Number Certification Level • -9- 931061 3--ei • 19. Analytical data for the following parameters, unless waived by the WQC Division - Permits and Enforcement Section, shall be submitted from at least one composite sampling of each discharge point as well as state waters upstream of each discharge. Instream sampling is not required if upstream flow is intermittent or representative instreem data exists. See instructions. See note below: A. All applicants must submit analyses for the following: Minimum Acceptable Parameter Detection Limit TDS, mg/1 10 Flow, MGD NA pH, s.u. NA Oil and Grease, mg/1 5 Dissolved Oxygen, mg/1 NA ellvl4nl ty, mg/1 10 Total Suspended Solids, mg/1 10 Total Ammonia as N, mg/1 0.05 Temperature, °C Winter NA Summer NA Biochemical Oxygen Demand, mg/1 1 Chemical Oxygen Demand, mg/1 30 Dissolved Aluminum, mg/1 0.1 Total Arsenic, mg/1 0.05 Total Recoverable Cadmium, mg/1 0.0004 Hexavalent Chromium, mg/1 0.025 Trivalent Chromium, mg/1 0:05 Total Chromium, mg/1 0.005 Total Recoverable Copper, mg/1 0.005 Total Recoverable Iron, mg/1 0.3 Total Recoverable Lead, mg/1 0.005 Total Recoverable Manganese, mg/1 0.05 Total Mercury, mg/1 0.00025 Total Recoverable Nickel, mg/1 0.05 Total Recoverable Silver, mg/1 0.0002 Total Recoverable Uranium, mg/1 0.03 Total Recoverable Zinc, mg/1 0.05 Total Residual Chlorine, mg/1 - 0.05 Fecal Coliform, i/100 ml NA Nitrate as N, mg/1 0.1 Nitrite as N, mg/1 0.002 Sulfide as H2S, mg/1 0.1 Continued on next page. • Note The analytical parameters used for these sampling points are the parameters used by the site for its groundwater monitoring program. The suitability of these parameters for use with this application was discussed with the WQCD. The WQCD indicated that the parameters were sufficient for the purposes of this application,. -10- • F 931061 4 5 • 19. A. continued Boron, mg/1 0.05 Chloride, mg/1 • 5 Sulfate, mg/1 5 Total Cyanide, mg/1 0.01 Dissolved Manganese, mg/1 0.05 Dissolved Iron, mg/1 0.3 Gross Alpha, pCi/1 8 Total Radium 226 and 228, pCi/1 1 B. You must report that dioxin may be discharged if you use or manufacture one of the following: 2,4,5-T Silver, 2,4,5-TP • Erbon Aonnel TCP or HCP See 40 CPR 122.21(g)(7) (v) . • • • -11- 931061 56 19. C. In addition, if you have processes in one of the following industries you must also submit the analyses specified below: 1) The "Metals,, Cyanide and Total Phenols" Listed in Appendix A, and ii) the appropriate GC/MS fraction(s) (specific compounds shown in Appendix A) listed in the following table: Industry Category GC/MS FRACTION2 Volatile Acid Neutral Pesticide • Adhesives and sealants (1) (1) (1) Aluminum forming : (1) (1) (1) • Auto and other laundries (1) (1) (1) (1) Battery manufacturing (1) (1) Coil coating (1) (1) Cl) Copper forming (1) (1) (1) Electric and electronic compounds (1) (1) (1) (1) Electroplating (1) (1) (1) Explosives manufacturing (1) (1) Foundries . (1) (1) (1) Gum and wood (all sub parts except D and P)(3) (1) (1) Subpart D--tall oil rosin (1) (1) (1) Subpart F--rosin-based derivatives (1) (1) (1) Inorganic chemicals manufacturing (1) (1) (1) Iron and steel manufacturing (1) (1) (1) Leather tanning and finishing (1) (1) (1) Mechanical Products manufacturing (1) (1) • (1) Nonferrous metals manufacturing (1) (1) (1) (1) Organic chemicals manufacturing (1) (1) (1) (1) Paint and ink Formation (1) ' (1) (1) Pesticides (1) Cl) (1) (1) Petroleum refining (1) -12- F 931061 59- 19. C. continued Industry Category GC/MS FRACTION2 Volatile Acid Neutral Pesticide Pharmaceutical preparations (1) (1) (1) Photographic equipment and supplies. (1) (1) (1) Plastic and synthetic materials' manufacturing (1) (1) (1) (1) Plastic processing (1) Porcelain enameling Printing and publishing (1) (1) (1) (1) Pulp aand3paperboard millsRubber processing (1) (1) (1) Soap and detergent manufacturing (1) (1) (1) Steam electric power plants . (1) (1) Textile mills (subpart C—Greige Mills are exempt . froa..this table) (1) (1) (1) Timber products processing (1) (1) (1) (1) Landfills —(4)— Oil and gas extraction— produced water(5) (1) (1) (1) Sugar processing (1) (1) (1) (1) Oil Shale —(4)— (1) Testing Required (2) See Appendix A for specific pollutants in each fraction (3) See 40 CPR Part 122, Appendix D Table 1 for testing requirements and additional information for these specific industries. (4) Contact WIND — Permits and Enforcements concerning required analyses. (5) Per Federal Regulations produced water must be of acceptable quality for and be used in agriculture or wildlife propagation in order to be discharged. Specify the use here if you intend to discharge produced water: -13- r 931961 ?.s 19. D. All applicant must review the parameters li .ed in Appendix A and • Appendix B to this application, list any known or believed to be present and provide quantitative data for those present or believed to be present. Please see attachment 4 for water camT analycic data for discharge point 001. Attachment 6 inrtudac anaty+ic at- for waters upstream of discharge pout 001 and is_ referenced as N-Discharge and also includes upgradient groundwater monitoring wells GWMW01 , GWMW02 and GWMW03. E. All applicants must identify any biological toxicity tests which have been performed within the last 5 years on any of the discharges or the receiving water in relation to a discharge from this facility. NA no tests have been performed. F. All new applicants must perform an aquatic Life biomonitoring test of the discharge(s) and submit the results to the Division as part of this application. See 5.9.7(2)(a)(ii) of the "Regulations for the State Discharge Permit System" for details. Please see attached results. (Attachment 5I 20 . Do you have bulk storage of diesel fuel, gasoline solvents or other hazardous materials on site? No Yes X Indicate location on general site sketch Item 13. 21. Is or will land application of any wastewater be practiced? No_x Yes_ Briefly describe the process: • The water is discharged offsite into a manmadt pond • —14— • 331961 _C 7 1 Is this operation located within one mile of a landfill (existing or closed) , or any mine or mill tailings? No Yes X Indicate location of the landfill or tailings on the location map, Item 9, or general site sketch, Item 13. 23. The applicant should submit any additional relevant information (such as additional sampling results or stream flow data (07-10)) that they feel the Division should consider in establishing permit conditions. The Spomer Lake analytical data is included in Attachment 6. 24. New oermit applicants, amendment applicants or renewal applicants with changes: I certify under penalty of law that I have personally examined and am familiar with the information submitted in this application and all attachments and that, .based on$my inquiry of those individuals immediately responsible for obtaining the intonation, I believe that the information is true, accurate and complete. I am aware that therefare significant penalties for submitting false information, including the possibility of fine or imprisonment. SIGNATURE 0 DATE SIGNED ldi4-t1AM. 14-04,3 tic V.✓,sped v pp- b+17F1I.6 Of/aQitnenir NAME (PRINTED) TITLE 25. Renewal applicants if no change: I certify under penalty of law that I am familiar with the conditions at the site and that based on my inquiry of those individuals immediately responsible for the site, operating conditions, chemical usage, or other factors which could affect the affluent quality have not changed from that which is identified in our current permit. I therefore request renewal of our permit. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment. SIGNATURE OF APPLICANT DATE SIGNED NAME (PRINTED) TITLE-15- 931061 60 ATTACHMENT 1 CWSL Facility Location Map F 931061 66 / w _22 71 _ IQ \ i 69 6 - ` : -- ."gime ale ,,..,_, f _. J i 1 Table A _ _— y \ NCIo _-. U �j Halr �. I Carr �., a ',\ ./ =�J -{ `- B , °�°\'r to [• I � i N ^.� _ — 2-0=-s N___[ • yMrm.re a � I BuI r _ r „� �. o ."7 r--. ( �!.OM ,.� \ /aa ° �; ': .1%' f. r fed,AIM - y 0 .1^ '.5 ‘5 1cd 4 I 1 Q� 1.rta mot' wa r} l•ll'CMIC - ` i � �•� °1 MC \ ■,\�_ n� 1 • nCre2r r'I_ urc•K — L _ \`FOREST- K;. �•�.wl'i�'Sinnard `.��■1 �� '� sOW l•-►Yap in se.. . ��7. v I mil• 1 s /{{l -VASE l O I I o .[• \ ,.• '11? \� T[ jar ,I o�rtcn °` ` _ n°Sr N\ 1. --.5 5 --C\ vl �1• wth '. �?•_ rlith ..', . r� ! I.' �., L Ha �w ' r^•✓'�• ' am s�. GaNton Corr$sh Mtn C �. •.asr in 'o, � ' v'reer, N° I �� I C'Le II \.-.\--. � r— - •° ✓a o ° ° ±- BracsrNl° ?_-._ ` �, / Barnamll! M • 1.0 t* 6"k aaa G' Y Iciu sjlllwwr�� _ lom � � �_ ■se�� •'ate. -, Jn S°yA, - �� - rl.• ,. -rT.1>, - L _ z.-GtlYmpas — ran o f ' M •4� r r,. ° ! •Elm s bin rwrte ure +!� gy=p m l� :ud •, / 7 °� — •dia0n o eRe•'. o .•1 1 Me do J rn .� . - . , �,e -_ rl vr' '''�'a� tea iii' O lie • oma,IJ .tea \ CY,d Ira , I�.Sr " a y• lifac� .° - , n .' i - sun i• i I� ` —,lig Kro6�..e 6 9eatetu]1 V •� P •talY °a _ '+� m, T� J ae�.•IM MI r a tll —••� i !.i � --.�' ;� � \a ,+out , {- ,,Tyy - Pros( �r c,' Er,.�. S t s �� earvy Crisman 1 �4 tm V � • ' i ark D E1JI nt :ep .° .. n �' peer 9IR •o, _.maal._ O .� 7 ,� i 0 j ° 5 ��_c.e _la_ I.. �[ °` a�= a•se �-ee i�r. 1 �o aS ., s as I 1111 f1 J�� ._._. . ° I, I ;-. ``TB• , I // , • TITLE IPAIGsloOiditrailes REGIONAL SITE LOCATION MAP LIERT/PWOJECT WASTE SERVICES CORPORATION CENTRAL WELD SANITARY LANDFILL DA7EJULY 1992 ara< 111=8 MILES i10E R' 913-2403 'RAW* KAW. acme sIAC REVIEWED WEH nit DWO.NO. g Fl -EYRE F6,91 �.- • f� • R67W R66W J xl- 30 •. os • D.. ) 2 I ( , , y .I D2J1 yr. ` 1 I /�� .4 • 1 11 J 1'Sow 6916 - --..- ••• / ", 4 '.\ i 1 I ' 4293. ... ` O Q AP ' APPROXIMATE SITE LOCATION ll 11 1 I g fl� �l-\ • �r 11 I U Discharge Point 002 \ ai\c\ T SN 00 .r \ 4434r tpN , ,, A•ri • are (( R CC 47/54 �J I /U CL� p 84)It I �� J ( / ` I . - i �. , -- - I 4693 i� Y Ek \ O� / P *611 : ' 0 SS1' *fly • • y. 470- r •I snick; _. 1215• 4744- 4732 •079 ti ON -_— NI O • . / TITLE GENERAL SITE LOCATION MAP IPAirisoCiderciates Denver, Colorado 'RIT/PRO2ECi DRAWN KA/ 'WE SLY 199:2N0. WASTE SERVICES CORPORATION y. .2 J J'If. �.D r.�. ,4444 ..,• . �.b � � 1 o2,3 p. ENTRAL WELD SANITARY LANDFILL RE,,, - \ATE-! rue NO. FlOVRe NO ATTACHMENT 2 CWSL Site Plan 931061 &Li I,N Yy r • G " O o Z 6 o Z Ce J _ O o Q 0— tei • G $ 0 } Q O c ₹ i 1- =�-z z Q ; ( N Z lsl W U O O ill I. W J N ¢ r t— V 3 Z R La t V . I O o g O Fl i I C ; \� \ a \��_ / yJ M 4 / PLC 0/0Y ammo ` — HI Irf/ 1[C /T' $ fr. ! t Pil j! E$$ 1II 1I.asscnJ d � i . LI � II �1 II e f�• • II ,� II d 6 ; 1 11 i k 1 nob,/ / it �u :lit: "' / /� II /`r� 1 N '6 O< n x II \ W K'l 1 li ' g iiAli .� ,�LI il ..:,.......: ..s, '.'' -.II: ilq. //://11:1/4/; ; , ii - \_____,.. ........„1 : II, I irk ___________ Ili/ g -- ` ----r--.7-__..7.,\ d i§ n i i ; , , $/ --\ 6 it 8 / F-- 931061 -5.- _ . . . . ; . -- � , N , } y ) : g k g i0Gi k . . . . . 1 F ( k \ .4 Si fit ( i | 2 Q / i8I .t•. \ � m \ . I I © j a | ■ | > °id , | d | | \ \ In t § / , p | . . . 1| . . | / �7. - _ � .. .LL §�� l � ca | � ' . k II / #/ 1 i . I / . � t.HiJb & f! �,� &§ & || , || |)� �, _/..| §& � y 1� 1 I • ■ s § II 0 6 , |§ - / - | i 1 4 • & k | ��#-' 11 ##®ij ) \ F----11 i I / | ' —& \ � �� _ r ! \ 7 § !- � . % � li: �/=��2. — — _® ■ § . II | ® f§§§ /-® m | ftkt || . ` �� ` /. C |� 2 | / =`%� k » & z ` ® & i • Z �it1L ! _ 2 � / —/ / I t� �� _ � i .7. � j �, ■.[ ----= -- bit' ? | 6 1 sql ° ^� Z \1�— � --- . ./__ » ^ 68° � /� . , . �� | * - / & # 9 | iy, / | | ■ ATTACHMENT 3 Groundwater Contours and Flow Direction Beneath the Site 931061 U I Q d 8 a o a5 3 g O i PPPPP PPP § _ g KK 2 E3 u, V O m $ W " i7 e_ 3`i 6d G O O 0 O pV O n x W 3 4 W Q ug� J � 4 Q a4 ^-�e,/ n / i ey{45FE�j a —Z ~ v i tb ti S a 6u SSa" iaiw, 0 N g g�J�J2a3WEW rn w _ N s r Q 8 s ch S a ( -` v } � Hrr s -'(� _�i 1-: �i. � i .�' I )� 1[ ( 1 t 1 Ta7-‘.2 '� .._ I h�� _ �•Fi g "b ' /t ,,. . 41 t2 I ,1 '[ ! , \i; Za�,32 :LI:, ffr y"53.1 -- tlana, C a7 I1 kiiiiI3 _ ,J 4c ' Ic f ' y �� t zE 3 a �i �Iye rit a QQ s ill it a QJ�Yttc3 II�1 02 1 ' �. 095 w v r‘ ' ~ III II I >ko id 4 e�Qo �__„924), _. �_� � x II I I ) �t in �, I co,- g aZ r 619 bf a p1 g3(5 to)e ( I — ' 1 y i I C7CO € w ilbw, ~ , _ _ ^ryl..� ` , ✓ / / i`Ill, I.. i a II .i � U .g. 7 C7 m / Ihi �� II� F ' I I; r i ! I t , Nya i , t ' 1 �:� r ., , r ) III rP e *'. .a, 3 ,� TTT ®^ O '' /, N 0.O / :::_ill _ li,, /// v N v �3 / • / � , ire ICt.:i%/II 1 I i tit 1 1 y''n R h /T` • ,-- "' Al✓ _.Q i.°" !I I '._ 1 S /A, i tb d' Ir Pv.lam;. .,�a v0 - � . t ;I� r'AraZm i 01 061 F ATTACHMENT 4 Water Analysis Data Discharge Point 001 931061 6`�' Enseco Volatile Organics , Target Compound List (TCL) Method 8240 Client Name: Waste Management of North America, Inc. Client ID: LF-UD Lab ID: 021825-0005-SA Matrix: AQUEOUS Sampled: 26 MAR 92 Received: 27 MAR 92 Authorized: 27 MAR 92 Prepared: 31 MAR 92 Analyzed: 06 APR 92 Reporting Parameter Result Units Limit Acetone ND ug/L 10 Benzene ND ug/L 5.0 Bromodichloromethane ND ug/L 5.0 Bromoform ND ug/L 5.0 Bromomethane ND ug/L 10 2-Butanone (MEK) ND ug/L 10 Carbon disulfide ND ug/L 5.0 Carbon tetrachloride ND ug/L 5.0 Chlorobenzene ND ug/L 5.0 Chloroethane ND ug/L 10 Chloroform ND ug/L 5.0 Chloromethane ND ug/L 10 Dibromochioromethane ND ug/L 5.0 1, 1-Dichloroethane 5.4 ug/L 5.0 ' ,2-Dichloroethane ND ug/L 5.0 1,1-Dichloroethene ND ug/L 5.0 1,2-01chloroethene (total) ND ug/L 5.0 1,2-Dichloropropane ND ug/L 5.0 cis-1,3-Dichloropropene ND ug/L 5.0 trans-1,3-Dichloropropene ND ug/L 5.0 Ethylbenzene ND ug/L 5.0 2-Hexanone ND ug/L 10 Methylene chloride ND ug/L 5.0 4-Methyl-2-pentanone (MIBK) ND ug/L 10 Styrene ND ug/L 5.0 1,1 ,2,2-Tetrachloroethane ND ug/L 5.0 Tetrachloroethene 5.0 ug/L 5.0 Toluene ND ug/L 5.0 1, 1,1-Trichloroethane ND ug/L 5.0 1,1,2-Trichloroethane ND ug/L 5.0 Trichloroethene ND ug/L 5.0 Vinyl acetate ND ug/L 10 Vinyl chloride ND ug/L 10 Xylenes (total ) ND ug/L 5.0 Surrogate Recovery Toluene-d8 101 % 4-Bromofluorobenzene 94 % (continued on following page) ND - Not detected NA • Not applicable Reported By: Scott McPhail Approved By: Karen Kuiken 93106170 Volatile Organics. Target Compound List (TCL) Method 8240 Client Name: Waste Management of North America, Inc. Client ID: LF-UD Lab ID: 021825-0005-SA, Matrix: AQUEOUS Sampled: 26 MAR 92 Received: 27 MAR 92 Authorized: 27 MAR 92 Prepared: 31 MAR 92 Analyzed: 06 APR 92 Surrogate Recovery 1,2-Dichloroethane-d4 88 S ND = Not detected NA * Not applicable Reported By: Scott McPhail Approved By: Karen Kuiken 9310617 / Enseco Chlorinated Pesticides and PCB's ACoann C�. Target Compound List (TCL) Method 8080 Client Name: Waste Management of North America, Inc. Client ID: LF-UD Lab ID: 021825-0005-SA, Matrix: AQUEOUS Sampled: 26 MAR 92 Received: 27 MAR 92 Authorized: 27 MAR 92 Prepared: 31 MAR 92 Analyzed: 08 APR 92 Reporting Parameter Result Units Limit gamma-BHC (Lindane) ND ug/L 0.050 Endrin ND ug/L 0.10 Methoxychlor ND ug/L 0.50 Toxaphene ND ug/L 5.0 Surrogate • Recovery Dibutyl chlorendate 95 X ND - Not detected NA - Not applicable Reported By: Lue Lor Approved By: Karen Kuiken • fj 931061 `-i Enseco RCRA Herbicides Method 8150 Client Name: Waste Management of North America, Inc. Client ID: LF-UD Lab I0: 022450-0004-SA Matrix: AQUEOUS Sampled: 27 APR 92 Received: 29 APR 92 Authorized: 29 APR 92 Prepared: 01 MAY 92 Analyzed: 08 MAY 92 Reporting Parameter Result Units Limit 2,4-0 ND ug/L 12 2,4,5-TP (Silvex) ND ug/L 1.7 Surrogate Recovery DCAA 96 X • • NO = Not detected NA • Not applicable Reported By: Susan McCool Approved By: Karen Kuiken 931061 1-3 Ensec A COMMA Metals • �A, Total Metals Client Name: Waste Management of North America, Inc. Client ID: LF-UD Lab ID: 021825-0005-SA Matrix:. AQUEOUS Sampled: 26 MAR 92 Received: 27 MAR 92 Authorized: 27 MAR 92 Prepared: See Below Analyzed: See Below Reporting Analytical Prepared Analyzed Parameter Result Units Limit Method Date Date Arsenic ND mg/L 0.010 7060 30 MAR 92 02 APR 92 Barium 0.010 mg/L 0.010 6010 30 MAR 92 31 MAR 92 Cadmium ND mg/L 0.0050 6010 30 MAR 92 31 MAR 92 Calcium 432 mg/L 0.20 6010 30 MAR 92 31 MAR 92 Chromium ND mg/L 0.010 6010 30 MAR 92 31 MAR 92 Iron 0.26 mg/L 0.10 6010 30 MAR 92 31 MAR 92 Lead ND mg/L 0.010 7421 30 MAR 92 02 APR 92 Magnesium 292 mg/L 0.20 6010 30 MAR 92 31 MAR 92 Manganese 1.5 mg/L 0.010 6010 30 MAR 92 31 MAR 92 Mercury ND mg/L 0.00020 7470 30 MAR 92 31 MAR 92 Potassium ND mg/L 5.0 6010 30 MAR 92 31 MAR 92 Selenium ND mg/L 0.050 7740 30 MAR 92 01 APR 92 Silver ND mg/L 0.010 6010 30 MAR 92 31 MAR 92 Sodium 258 mg/L 5.0 6010 30 MAR 92 31 MAR 92 ND - Not detected NA - Not applicable Reported By: Sandra Jones Approved By: Sandra Jones 931061 71 lSe General Inorganics � mwmc MP,,,. Client Name: Waste Management of North America, Inc. Client ID: LF-UD Lab ID: 021825-0005-SA, Matrix: AQUEOUS Sampled: 26 MAR 92 Received: 27 MAR 92 Authorized: 27 MAR 92 Prepared: See Below Analyzed: See Below Reporting Analytical Prepared Analyzed Parameter Result Units Limit Method Date Date Alkalinity, Bicarb. as CaCO3 at pH 4.5 532 mg/L 5.0 310.1 NA 27 MAR 92 Alkalinity, Carb. as CaCO3 at pH 8.3 ND mg/L 5.0 310.1 NA 27 MAR 92 Chloride 39.0 mg/L 3.0 300.0 NA 27 MAR 92 Ammonia as N ND mg/L 0.10 350.1 NA 30 MAR 92 Nitrate as N 2.8 mg/L 0.10 300.0 NA 27 MAR 92 Sulfate 2320 mg/L 50.0 300.0 NA 27 MAR 92 ND - Not detected A - Not applicable Reported By: Steve Pope Approved By: Blake Besser • F 9x1061 75 Metals Enseco n, Total Metals Client Name: Waste Management of North America, Inc. Client ID: LF-UO Lab ID: 021825-0005-SA Matrix:. AQUEOUS Sampled: 26 MAR 92 Received: 27 MAR 92 Authorized: 27 MAR 92 Prepared: See Below Analyzed: See Below Reporting Analytical Prepared Analyzed Parameter Result Units Limit Method Date Date Arsenic ND mg/L 0.010 7060 30 MAR 92 02 APR 92 Barium 0.010 mg/L 0.010 6010 30 MAR 92 31 MAR 92 Cadmium ND mg/L 0.0050 6010 30 MAR 92 31 MAR 92 Calcium 432 mg/L 0.20 6010 30 MAR 92 31 MAR 92 Chromium ND mg/L 0.010 6010 30 MAR 92 31 MAR 92 Iron 0.26 mg/L 0.10 6010 30 MAR 92 31 MAR 92 Lead NO mg/L 0.010 7421 30 MAR 92 02 APR 92 Magnesium 292 mg/L 0.20 6010 30 MAR 92 31 MAR 92 Manganese 1.5 mg/L 0.010 6010 30 MAR 92 31 MAR 92 Mercury ND mg/L 0.00020 7470 30 MAR 92 31 MAR 92 Potassium ND mg/L 5.0 6010 30 MAR 92 31 MAR 92 Selenium ND mg/L 0.050 7740 30 MAR 92 01 APR 92 Silver - ND mg/L 0.010 6010 30 MAR 92 31 MAR 92 Sodium 258 mg/L 5.0 6010 30 MAR 92 31 MAR 92 ND = Not detected NA = Not applicable Reported By: Sandra Jones Approved. By: Sandra Jones F- 93106i 76 ElS General Inorganics tc onni.,,. Client Name: Waste Management of North America, Inc. Client ID: LF-UD Lab ID: 021825-0005-SA, Matrix: AQUEOUS Sampled: 26 MAR 92 Received: 27 MAR 92 Authorized: 27 MAR 92 Prepared: See Below Analyzed: See Below Reporting Analytical Prepared Analyzed Parameter Result Units Limit Method Date Date Alkalinity, Bicarb. as CaCO3 at pH 4.5 532 mg/L 5.0 310.1 NA 27 MAR 92 Alkalinity, Garb. as CaCO3 at pH 8.3 ND mg/L 5.0 310.1 NA 27 MAR 92 Chloride 39.0 mg/L 3.0 300.0 NA 27 MAR 92 Ammonia as N ND mg/L 0.10 350.1 NA 30 MAR 92 Nitrate as N 2.8 mg/L 0.10 300.0 NA 27 MAR 92 Sulfate 2320 mg/L 50.0 300.0 NA 27 MAR 92 ND - Not detected IA a Not applicable Reported By: Steve Pope Approved By: Blake Besser r 931061 7 7 El5e Radiochemistry A E2.IIV Client Name: Waste Management of North America, Inc. Client ID: LF-UD Lab ID: 021825-0005-SA- Matrix: AQUEOUS Sampled: 26 MAR 92 Received: 27 MAR 92 Authorized: 27 MAR 92 Prepared: See Below Analyzed: See Below Reporting Analytical Prepared Analyzed Parameter Result Units Limit Method Date Date Gross Alpha 40 pCi/L +/- 26 900.0 NA 09 APR 92 Radium 226 0.1 pCi/L +/- 0.4 705 Modified NA 14 APR 92 Gross Beta 18 pCi/L +/- 22 900.0 NA 09 APR 92 Radium 228 0.9 pCi/L +/- 2.4 EPA Specified NA 09 APR 92 ND - Not detected I , - Not applicable Reported By: Ramona Power Approved By: Blake Besser r 9310617..g Page: 2 11� „ - NMI SAL MONITORING LABORATORIES, INC CLIENT - REPORT • ite: 488 - Central Weld County Sample Point: LFUD ENS: 92-11934 Sampled: 16-JOL-1992 Sanitary Landfill Sample Type: RIV/STREAM MP: 488921 Received: 17-JUL-1992 Weld County Road 271/2 Semple masr: AF2942 REV: 00 Reported: 1-SEP-1992 Miliken CO 80543 Analyte Result ESL AL Units Comments Method 1.1,2-TRICHLOROETHANE ND 1.000 OG/L VOMSAAX424 1,1-DICHLOROETHANE • 7. 3.000 OG/L VOMSAAX424 1,1-DICHLOROETHENE ND 2.000 OG/L VOMSAAX424 1,2, 3-TRICHLOROPROPANE ND 2.000 OG/L VOMSAAX424 1,2-DICHLOROETHANE ND 2.000 OG/L VOMSAAX424 1,2-DICHLOROPROPAME ND 2.000 OG/L - VOMSAAX424 1,4-DICHLORO-2-BUTENE(TOTAL) ND 2.000 OG/L VOMSAAX424 1,4-DIFLUOROBENZENE NA OG/L VOMSAAX424 2-BUTANONE ND 20.000 OWL VOMSAAX424 2-CHL0R0ETHYLVINYL ETHER ND 5.000 OG/L ST VOMSAAX424 2-HEXANONE ND 4.000 OG/L VOMSAAX424 4-BROMOFLUOROBENZENE ND 0.800 OG/L VOMSAAX424 4-METHYL-2-PENTAMONE ND 5.000 OG/L VOMSAAX424 ACETONE ND 25.000 OG/L VOMSAAX424 ACROLEIN ND 10.000 OG/L PY VOMSDAX101 ACRYLONITRILE ND 10.000 OG/L PY VOMSDAX101 BENZENE ND 1.000 DG/L VOMSAAX424 BROMOCHLOROMETHANE ND - 2.000 OG/L VOMSAAX424 BROMODICHLOROMETRANE ND 1.000 OG/L VOMSAAX424 BROMOFORM ND 1.000 OG/L VOMSAAX424 BROMOMETHANE ND 2.000 OG/L VOMSAAX424 CARBON DISULFIDE ND 3.000 OG/L VOMSAAX424 • CARBON TETRACHLORIDE ND 1.000 OG/L VOMSAAX424 CHLOROBENZENE ND 1.000 OG/L VOMSAAX424 CHLOROETHANE ND 3.000 OG/L VOMSAAX424 CHLOROFORM ND 2.000 OG/L VOMSAAX424 CHLOROMETHANE ND 2.000 OG/L VOMSAAX424 CIS-1,3-DICHL0ROPROPENE ND 1.000 OG/L VOMSAAX424 D IBROMOCHLOROMETHANE ND 1.000 OG/L VOMSAAX424 DIBROMONETHANE ND 1.000 OG/L - VOMSAAX424 DICHLORODIFLOOMONETHANE 9. 2.000 OG/L VOMSAAX424 ETHANOL ND 100.000 OG/L PY VOMSDAX101 ETHYL METNACRYLATE ND 10.000 OG/L PY VOMSDAX101 ETHYLBENZENE ND 1.000 OG/L VOMSAAX424 IODOMETHANE ND 2.000 OG/L VOMSAAX424 METHYLENE CHLORIDE ND 3.000 OG/L VOMSAAX424 STYRENE ND 1.000 OG/L VOMSAAX424 TETRACHLOROETHENE 5. 1.000 OG/L VOMSAAX424 TOLUENE ND 1.000 OG/L VOMSAAX424 TRANS-1,2-DICHLOROETHEIIE ND 3.000 OG/L VOMSAAX424 TRANS-1,3-DICHLOROPROPENE ND 1.000 • OG/L VOMSAAX424 TRICHLOROETHENE - 3. 1.000 OG/L VOMSAAX424 TRICHLOROFLOOROMETHANE 3 2.000 OG/L - VOMSAAX424 VINYL ACETATE ND 4.000 OG/L VOMSAAX424 VINYL CHLORIDE -- ND .2.000 OG/L VOMSAAX424 XYLENE(TOTAL) ND 2.000 OG/L VOMSAAX424 MA - Not Analysed ND - Not Detected TEE - Trip Blank / K 931061 '7- y ATTACHMENT 5 Aquatic Life Biomonitoring Test Results 931061 PREFACE Attachment 5 includes the biomonitoring test results of a water sample collected from an underdrain at the Central Weld Sanitary Landfill (CWSL). The test results show that the water sample did not cause 50% or greater mortality to either the Ceriodaphnia or Fathead Minnow in any testing concentration. The calculated LC(50) value was greater than 100%, indicating that exposure to 100% water from the underdrain would be lethal to fewer than 50% of test organisms in the duration of an acute test. The sample therefore is not acutely toxic based on Colorado's definition for acute toxicity. The report also noted a statistically significant difference in mortality between the control replicate and the 100% concentration. During testing, the laboratory concluded that the sample includes the calcium and magnesium carbonate constituents of hardness and the bicarbonate that accounts for alkalinity. The sample had a specific conductance of 4010 umho/cm and an alkalinity (bicarbonate) of 525 mg/1. The laboratory concluded that the hardness and alkalinity of the sample would explain the statistical difference. The laboratory also indicated the possibility that the constituents are naturally occurring. Included in Attachment 6 are analytical data for GWMW01, GWMWO2 and GWMWO3 which are the upgradient shallow groundwater monitoring wells for the CWSL. These wells are considered to represent pre-CWSL conditions of the shallow groundwater. The locations of these wells are shown on the CWSL Site Plan in Attachment 2 and the Shallow Groundwater Potentiometric Surface Contour Map in Attachment 3. The water supply to the underdrain includes the shallow groundwater represented by these wells, and likely a portion of the upgradient surface water represented by the North.Discharge sampling point(analytical data also included in Attachment 6). A comparison of the underdrain results with the upgradient analytical data (i.e. specific conductance, alkalinity, calcium and magnesium) supports the laboratory's suggestion that the hardness and alkalinity characteristics are naturally occurring. wp3l aa\cwcldapp.909 F CWSL 1 10 wkac/31 w/o eoc 9"'1061 l/ • CTLCOMMERCIAL TESTING & ENGINEERING CO. GENERAL OFFICES:1919 SOUTH HIGHLAND AVE.,SUITE 210-8.LOMBARD,ILUNOIS a0148•(312)953-9300 NC f soe Mentor of the SGS Group(Soct Goitre a Swalll•na) • PLEASE ADDRESS ALL CORRESPONDENCE TO: 490 ORCHARD ST..GOLDEN,CO 80401 TELEPHONE:(303)2784521 FM:(303)278.1779 WASTE SERVICES CORPORATION UNDERDRAIN WATER BIOMONITORING Results of tests completed on July 20 , 1992 Prepared for Mr . Alan Scheere Waste Services Corporation 5660 Greenwood Plaza Blvd. Suite 400 Englewood, CO 80111 • Prepared by Esequiel Zarco Commercial Testing and Engineering 490 Orchard Street Golden, CO 80401 Approved and Submitted by Anthony G. Stoyko �t / +14 July 24 , 1992 • e OVER 40 BRANCH LABORATORIES STRATEGICALLY LOCATED .IN. PRINCIPAL COAL MINING AREAS, q J 1Os1 _Sln�„•+nn n/.n�.�r .vnr- Mn�n •.rn..nr..nn ,�.nr..n n.n...«nn INTRODUCTION A two species acute bioassay was conducted with a water - collected from an underdrain of the Central Weld Sanitary Lan ` _ _ _ (CWSL) . This testing was conducted as part of Waste Corporation ' s application process for a NPDES permit . METHODS A grab sample was collected by Ms . Leticia Sanchez on LThiJ 1952 , delivered to Commercial Testing and Engineering (CT&F that same date , and assigned CT&E number 165770 . Testing was conducted in accordance with the most recent protocols specified by the Water Quality Control Division of the Colorado Department of Health (1992) , outlined in Table 1 . Basic characteristics of the water sample from the underdrain cf the CWSL was measured including pH , alkalinity, hardness , disso'1 ; oxygen, ammonia and residual free chlorine , as shown in Table 2 . The pH was measured using a Fisher Scientific model 910 pH met : and ammonia was measured using the same pH meter with an Orion model 95-12 ammonia-specific electrode . Total residual chlorine was measured using a LaMotte model STC-Cl colorimeter . Alkalinity and hardness were determined by titrimetric methods specified by the American Public Health Association ( 1989) . Dissolved oxygen was measured with a YSI model 54A oxygen meter . The tests exposed the Cladoceran Ceriodaphnia dubia and Fathead minnow Pimephales promelas to five concentrations of underdrain water from the CWSL. 100%, 75% , 50%, 25%, and 12 . 5% dilutions were prepared using laboratory reconstituted water. Control replicates were exposed to 100% laboratory reconstituted water. -1- COMMERCIAL ING & ENGINEERING CO.ACliklk �] 1j� 466 931.061 , 13 / _^!gmai Watermarked For Your Protection Colorado law defines acute toxicity as greater than 50% mortality in any effluent concentration , or a statistically significant difference , at the 95% confidence level , between mortality in the control and in any effluent concentration equal to or less than the instream waste concentration (Colorado Department of Health , 1991 , page 10) . Survival data did not meet Shapiro-Wilk ' s test of normality and was , therefore , analyzed for statistically significant differences in survival between the control and any effluent concentra`_i :n using Steels Many-One Rank Test and Fisher ' s Exact Test . In addition, survival data was used to calculate the LC;, value , an estimate of the concentration of effluent that would be lethal to exactly 50% of each species of test organism in the duration of an acute test , using the Binomial and Probit methods , as shown in Appendix A. • RESULTS Water Chemistry The waters ' chemical characteristics appear in Table 2 . Toxicity Tests The water sample from the underdrain of the CWSL did not cause 50% or greater mortality to either species in any testing concentration. The LC5 value calculated was >100% for both species , indicating that exposure to 100% water from the underdrain of the CWSL would be lethal to fewer than 50% of test organisms in the duration of an acute test . However , a significant difference in mortality between the control and 100% sample concentration was observed for Ceriodaphnia and Fathead minnows . -2- COMMERCIAL TESTING & ENGINEERING CO. 466 AS, 93106147 _ngmal Watermarked For Your Protection DISCUSSION Because Waste Services Corporation does not currently have a NP ES permit , it can not be determined if this water sample from the underdrain of the CWSL is acutely toxic . The sample did not cause a 50% or greater mortality to either species , therefore it is npt acutely toxic based on that definition . However , there ryas a statistically significant difference in mortality between t:h_ control and the 100% concentration. Based on that definition , this sample would be acutely toxic if the IWC was 100% . The statistically significant difference in mortality to both test species may have resulted from the concentration of solids present in the sample . ' Conductivity for this sample was 4 , 010 umho/cm, which translates to roughly 3 , 300 mg/L Total Dissolved Solids , a level that could cause acute toxicity to both test species . During the testing period , a layer of precipitate formed on the bottom of the testing chambers . This precipitate readily effervesced and dissolved in contact with hydrochloric acid, suggesting that this precipitate includes carbonates such as the calcium and magnesium carbonate constituents of hardness and the bicarbonate that accounts for alkalinity. A hardness of 2 , 540 mg/L and alkalinity of 525 mg/L, reported for this sample , does support this data. It is difficult to say if the CWSL is responsible for the dissolved solids in this sample . The extreme hardness and alkalinity can be naturally occurring and, therefore , would not be a result of the CWSL . It could prove advantageous to Waste Services Corporation to perform another acute bioassay using water collected just before it enters the underdrain of the CWSL. -3- COMMERCIAL ING & ENGINEERING CO. F.466 931061 S5 _nginal Watermarked For your Protection By doing this additional test it might show that this water comes in with the same amount of dissolved solids , thereby causing the same amount of toxicity to both species of test organisms . This would indicate that the CWSL is not responsible for the toxicty t both test species and should not be included in a NPDES permit . REFERENCES American Public Health Association, American Water Works Association and Water Pollution Control Federation . 1939 . Standard Methods for the Examination of Water and Waste- water , 17th ed. American Public Health Association , Washington , DC . Colorado Department of Health. 1992 . Guidelines for Conducting Whole Effluent Toxicity Tests . Water Quality Control Division, 4210 E. 11th Ave . , Denver , Colorado 80220-3716 . United States Environmental Protection Agency. 1985 . Methods for Measuring the Acute Toxicity of Effluents to Fresh- water and Marine Organisms . EPA/600/4-85/013 . Environ- mental Monitoring and Support Laboratory, Cincinnati , OH . United States Environmental Protection Agency. 1990 . Region VIII NPDES Whole Effluent Toxics Control Program. USEPA Region VIII Water Management Division, 999 18th Street , Denver, Colorado 80202-2405 . • -4- COMMERCIAL ING & ENGINEERING CO. 466 331061 ' / oral Watercai.eG co. your Protection Table 1 . Colorado Acute Test Conditions . Ceriodaphnia Fathead Minnows Sample preparation : 60 um. Filtration 60 um Filtration Test type : Static Renewal Static Renewal Temperature : 20 +/- 1 ' C 20 +/- 1 Photoperiod: 16h light/ 8h dark 16h light/ 8h der'•; Test Chamber size : 30 ml 600 ml Test Sample vol . : 15 ml 150 ml Renewal Period : 24 hours 24 hours Age of Organisms : <24 hours < 168 + 12 hours Number per Chamber: 5 5 Replicate Chambers/Conc . : 4 4 Feeding Regime/Chamber : None 0 . 1 ml brine shrimp at 0 and 48 hours Test Duration: 48 hours 96 hours Dilution Water : Reconstituted Water Reconstituted water -5- COMMERCIAL TESTING & ENGINEERING CO. 466 931061 S 7- _riginal Watermarked For Your Protection _ —. Table 2 . Initial Water Chemistry Measurements . Parameter Underdrain from CWSL Reconstituted wat_r pH 7 . 1 8 . 7 ( std. units ) Alkalinity 525 60 (mg/L CaCO3 ) Hardness 2540 60 (mg/L CaCO3 ) Dissolved Oxygen 4 . 9 6 . 5 (mg/L) Ammonia <0 . 1 <0 . 1 (mg/L as N) Residual Chlorine <0 . 1 <0 . 1 (mg/L) -6- COMMERCIAL TESTING & ENGINEERING CO. 466 AL 931061 RS -rigmal Watermarked For Your Protection Table 3 . Ceriodaphnia and Fathead Minnow Survival Data for Acute Toxicity Tests of sample July 16 , 1992 . Number Exposed Number Dead Percent Mcrtaii-_ Conc . (As) Cerio. FHM Cerio . FHM Cerio . FHM 100 20 20 9 8 45 . 00 40 . 00 75 20 20 4 4 20 . 00 20 . 00 50 20 20 0 0 0 . 00 0 . 00 25 20 20 0 0 0 . 00 0 . 00 12 . 5 20 20 0 0 0 . 00 0 . 00 0 20 20 0 0 0 . 00 0 . 00 • -7- COMMERCIAL TESTING & ENGINEERING CO. A 3O <66 9 1061 ny!nai Watermarked For Your Protection • • • • • APPENDIX A Statistical analyses applied to results of acute toxicity tests completed 6-20-92 on sample 165770 . • • • COMMERCIAL TESTING & ENGINEERING CO. (� _r96a1 Watermarked For Your Protection 931061 C��) dutla Acute - -ogram run on 07-22-1992 16 : 41 : 07 RESULTS CALCULATED USING THE BINOMINAL METHOD JNC. NUMBER NUMBER PERCENT BINOMIAL EXPOSED DEAD DEAD PROB . (PERCENT) 100 20 9 45 .00 41 . 1901 75 20 4 20 .00 0 .5909 50 20 0 0 .00 LESS THAN 0 .001 25 20 0 0 . 00 LESS THAN 0 . 001 12.5 20 0 0 .00 LESS THAN 0 .001 T A CONFIDENCE LEVEL OF 95 PERCENT , THE BINOMIAL TEST iOWS THAT THE LC50 IS ABOVE 75 HE USEFULNESS OF ANY LC50 CALCULATED FROM THIS SET OF DATA 5 QUESTIONABLE BECAUSE A CONCENTRATION-EFFECT RELATIONSHIP :IAS NOT BEEN DEMONSTRATED OVER A REASONABLE RANGE (e.g . < 37 TO>63 OF PERCENT DEAD EITHER THE APPROXIMATE LC50 CALCULATION NOR THE MOVING AVERAGE METHOD CAN BE USED WITH THIS SET OF DATA. ITHER THE HIGHEST CONCENTRATION KILLED LESS THAN 50 ERCENT OR THE LOWEST KILLED MORE THAN 50 PERCENT. THE PROBIT SLOPE IS NEGATIVE, ENTER THE DATA AGAIN "SING THE NUMBER ALIVE INSTEAD OF THE NUMBER DEAD. ESULTS CALCULATED USING THE PROBIT METHOD GOODNESS OF FIT TERATIONS G H CHI-SQUARE PROBABILITY 6 0 .408 1 .000 0 .492 0 .921 _OPE = 7.422439 Q5 PERCENT CONFIDENCE LIMITS = 2.678711 AND 12. 16617 50 = 101 .9195 5 PERCENT CONFIDENCE LIMITS = 89.51225 AND 147.799 Cl = . 49.5271 _5 PERCENT CONFIDENCE LIMITS = 18.39696 AND 62.6841 JMPARE RESULTS WITH ORIGINAL DATA TO SEE IF THEY ARE EASONABLE. COMMERCIAL TESTING & ENGINEERING CO. G466 931061 9/ _nia Ana Water—an" Cn Your Oro'^[IIOn C . dubia-Acute-Survival ile : waste Transform: NO TRANSFORMATION _hapiro Wilke test for normality = 10 . 750 I = 0 .741 critical W (P = 0 .05) (n = 24) = 0 .916 :ritical W (P = 0 .01 ) (n = 24) = 0 . 884 'Data FAIL normality test. Try another transformation. arning - The two homogeneity tests are sensitive to non-normal data and should not be performed. FISHERS EXACT TEST NUMBER OF IDENTIFICATION ALIVE DEAD TOTAL ANIMALS CONTROL 20 0 20 12.5: 20 0 20 TOTAL 40 0 40 CRITICAL FISHERS VALUE (20 ,20 ,20) (p=0 .05) IS 15 . b VALUE IS 20 . • Since b is greater than 15 there is no significant difference between CONTROL and TREATMENT at the 0 .05 level . • • • • COMMERCIAL TESTING & ENOINEERINO CO. 1=nq LL 931061 yA ono'ner Watermarked For Your Protection FISHERS EXACT TEST . NUMBER OF IDENTIFICATION ALIVE DEAD TOTAL ANIMAL CONTROL 20 0 20 25: 20 0 20 TOTAL 40 0 40 CRITICAL FISHERS VALUE (20 ,20 ,20) Cp=0 .05) IS 15. b VALUE IS 20 . Since b is greater than 15 there is no significant difference between CONTROL and TREATMENT at the 0 .05 level . FISHERS EXACT TEST • NUMBER OF IDENTIFICATION ALIVE DEAD TOTAL ANIMAL CONTROL 20 0 20 50: 20 0 20 TOTAL 40 0 40 CRITICAL FISHERS VALUE (20 ,20 ,20) Cp=0 .05) IS 15. b VALUE IS 20 . Since b is greater than 15 there is no significant difference between CONTROL and TREATMENT at the 0 .05 level . COMMERCIAL TESTING & ENGINEERING CO. �T.E/�C.E 42 1 a66 J 9U1�191 / rigipal Watermarked For Your Protection • FISHERS EXACT TEST NUMBER OF IDENTIFICATION ALIVE DEAD TOTAL ANIMALS CONTROL 20 0 20 75% 16 4 20 TOTAL 36 4 40 CRITICAL FISHERS VALUE (20 ,20 ,20 ) Cp=0 .05) IS 15. b VALUE IS 16. Since b is greater than 15 there is no significant difference -etween CONTROL and TREATMENT at the 0 .05 level . FISHERS EXACT TEST NUMBER OF IDENTIFICATION ALIVE DEAD TOTAL ANIMALS CONTROL 20 0 20 100: 11 9 20 TOTAL 31 9 40 CRITICAL FISHERS VALUE (20 ,20 ,20) (p=0 . 05) IS 15. b VALUE IS 11 . Since b is less than or equal to 15 there is a significant difference between CONTROL and TREATMENT at the 0 .05 . 1evel . COMMERCIAL TESTING & ENGINEERING CO. LIB 9.31061{N' F 466 anginal Watermarked For Your Protection SUMMARY OF FISHERS EXACT TESTS NUMBER NUMBER SIG GROUP IDENTIFICATION EXPOSED DEAD (P= .05) CONTROL 20 0 1 12.5. 20 0 2 25% 20 0 3 50% 20 0 4 75% 20 4 5 100: 20 9 • • • • • COMMERCIAL TESTING & ENGINEERING CO. 931061 I .fin final Watermarked for Your?r0IB0Ii0n Promelas Acute ogram run on 07-22-1992 a 16 : 44 : 29 :SULTS CALCULATED USING THE BINOMINAL METHOD )NC . NUMBER NUMBER PERCENT BINOMIAL EXPOSED DEAD DEAD PROB . CPERCENT) 00 20 8 40 . 00 25. 1722 75 20 4 20 .00 0 .5909 50 20 0 0 . 00 LESS THAN 0 .001 .5 20 0 0 . 00 LESS THAN 0 .001 .2.5 20 0 0 .00 LESS THAN 0 .001 ' A CONFIDENCE LEVEL OF 95 PERCENT , THE BINOMIAL TEST OWS THAT THE LC50 IS ABOVE 75 IE USEFULNESS OF ANY LC50 CALCULATED FROM THIS SET OF DATA QUESTIONABLE BECAUSE A CONCENTRATION-EFFECT RELATIONSHIP HAS NOT BEEN DEMONSTRATED OVER A REASONABLE RANGE (e.g. t7 TO>63 OF PERCENT DEAD .ITHER THE APPROXIMATE LC50 CALCULATION NOR THE MOVING ^uERAGE METHOD CAN BE USED WITH THIS SET OF DATA . THER THE HIGHEST CONCENTRATION KILLED LESS THAN 50 k :RCENT OR THE LOWEST KILLED MORE THAN 50 PERCENT. IF THE PROBIT SLOPE IS NEGATIVE, ENTER THE DATA AGAIN 1 ;ING THE NUMBER ALIVE INSTEAD OF THE NUMBER DEAD. SULTS CALCULATED USING THE PROBIT METHOD GOODNESS OF FIT 'ERATIONS G H CHI-SQUARE PROBABILITY 6 0 . 454 1 .000 0 .679 0 .878 .OPE = 6 .774271 PERCENT CONFIDENCE LIMITS = 2. 211402 AND 11 .33714 I :50 = 106. 1029 PERCENT CONFIDENCE LIMITS = 91 .55382 AND 177 .5842 :1 = 48. 11993 3o PERCENT CONFIDENCE LIMITS = 14.49944 AND 62.02679 MPARE RESULTS WITH ORIGINAL DATA TO SEE IF THEY ARE f._ASONABLE . • COMMERCIAL TESTING & ENGINEERING CO. fr' 466 931061 9co P . Promelas-Acute-Survival 'ile: waste Transform : NO TRANSFORMATION ohapiro Wilks test for normality • 4 .000 • = 0 . 576 Critical W (P = 0 .05) Cn = 24) = 0 . 916 ritical W CP = 0 .01 ) Cn = 24) = 0 .884 :ata FAIL normality test. Try another transformation. arning. - The two homogeneity tests are sensitive to non-normal data and . should not be performed . P . Promelas-Acute-Survival ile : waste Transform : NO TRANSFORMATION STEELS MANY-ONE RANK TEST - Ho: Control<Treatment TRANSFORMED RANK CRIT. OUP IDENTIFICATION MEAN SUM VALUE df SIG 1 Control 5. 000 2 12.5: 5.000 18.00 10 .00 4.00 3 25: 5.000 18.00 10 .00 4 .00 4 50: 5.000 18.00 10 . 00 4.00 5 75: 4.000 12.00 10 .00 4 .00 6 100: 3.000 10 .00 10 . 00 4 .00 * Critical values use k = 5, are 1 tailed, and alpha = 0 .05 • • • • • COMMERCIAL TESTING & ENGINEERING CO. O66 93106 / 2- .., ,. • APPENDIX B Forms to report results of toxicity tests on sample 165770 to the Colorado Department of Health . • • COMMERCIAL TESTING & ENGINEERING CO. �yf '}�j agnal Watermarked For Your Protection V 31%1 9" 2 LCR. . — =as WET Tt3... RE?CRT. ?CRM AC'v k , dird re,, ,, PSRM:'TTEE: u la site Str v;ce S Lars). cD Ps NO. CD-00 d/f/ OCTAL:: A O 'AL:: a + e cc 5 L TT?! :'EST: RODTI:IE: ACCELERATED: TEST SPECIES: c. dl.u ; 41/4 AGE: aaaaaaaaaaaaaaaaaaaaaasaaaasaaaaaaoaaa.aaaaaaaaaaaaaa TEST RESULTS: IWC: / 4 i CONTROL MCRTALITI: n P. LCZO: >100 P SC% MORTALrn LIMIT: AS ?RITE cONC WIPE STAT. SIGNIFICANT MORTALITY: /0 0 aaaaaaaasa • . . . . . . . . . aaaaaaaaasaaaa SAMPLE TAFFY /COMPOS7"-F =HE a DAME: IO30 AM/PM 7-16- SZ TEST TIME & DATE: BEGIN 144S. AM/?H 7 / /6 /9*END AM/?H 7 /_i e f 5 Z Dfl7?_ONS f'1 mY?LDENTI MEa5TRti1r TS CCNTROL(0%) ,Z• r is 2 C i r . 7S ' i 0 a i NO. I START OF 'LEST: 2- O 2 O �It V ZV 2 O 2 U B0. LZ7E AFTER 24 MRS: AFTER <a MRS: _ / 6 1/ AFTER 72 BRS: AFTER 96 BRS: DISSOLVED OXYGEN, MG/L: / u i i C .1.2j-19f1 T � 22,../441 TEMPERATURE •C: tin /Z� zi.d,Z 4 � N O 7/•D /zO.a zl.o ,zce 2/.C1 ZCZo - RECEI TENG WATER asza FOR: OII nor r � 'SAMPLE AERATE? -- HARDNESS, MG/L: REGE'IVING WATER UFLCENT ZS40 REp LAB WATER 60 s_r,,E I..nail, MG/L: RECEIVING WL ER EF?LOENT CZS OitRILAS WATER to PH: tarnaL - corn Cf. 7 1001 7. 1 FINAL - CONTROL 7 9 100' ?C T. AMMONIA AS N, MG/L: IIflTrn*_ - 100% LO. 1O FINAL - 100% N/4 �q TOT. RESID. CELORINE, MG/L: 100% 4=0, 10 SAMPLE OECCBLORINATE-D BEFORE TES:' rz5/BO/ LABORATORY: ( arimJK;a/ MA/ c Cvthe?e,np ANALYST: &e je/ zaceeo CDrrTS: 1/1/91 931061 99 COLOR:,_J - CUPS 4ET TEST REPORT PC R`i ACT; Un aeidf0.„G PSR.Y .rZ: Ua de Cc.i I/1 ce S Grr P cops No. cc-co nn Al/4 cD^n : ci C1/42 CZ-- TM TES.: ROOTTNE: ACCEL"RATED: _ BEST SPECIES: T• Pats,e /A S ACE: 3 4 nna.a.a�/ aaaaaaaaaa..aaaaaaaaaaaaa a :ES^. Rzsn:s: IWC: /Y7 % CONTROL MORTALITY: 0 1 LC50: 7/0c % 50% MORTAL.= IMLTT: atil) PA ,l CONC WITS STAT. SIGNIFICANT MORTALITY: 1O Ct swam SAMPLE TTPE: cotsposT rtla & DATZ: I°3O AR/PM 7—/ 6 S z 'LS. ilrasE & DATE: 8EGtt 160O AN/?M 7 ult./_2(.,_?tmD 1 rs- AM/?m 7 / Z'/ 9z D=TIM n♦ ,P*'LIIEPT 1 MEASOREMENTS cCNTROL(0%) /2, f% 7 S 1 /0 a NO. @ S.ART of TEST: 2 0 '2 O 0 20 r. LIVE AFTER 24 BR.s: Art 48 BRS: AFTER 72 ORS: ± / AF.ER 96 SRN: /Z PAS/MIN VALUES OLSSOLVED CZYGEN. MLitt 12:—/-..a &/it/ g// G.1. C 9J //C J'V / }/,y 'TEMPERATURE •C: '11.0 /Zd212 24,42a 2Sp0.o Z/,O /'loo 21:0/20 21.6/41L - =arms- NATa as= FOR 0t. t1ON? ra -SAMPLE AERATED? HARDNESS, MG/L: REC:IVING WATER EFFLUENT 2S4 0 gg1La8 WAT-R /Co LLL2IITY Sa , MG/L: REC:IVENG WATER EFFLUENT 575 ` �»; = WA"'�R :o a pH: INI"_-eaL - CONTROL 2'. 7 100% 7. / FINAL - CONTROL 7, 9 100% 7 9 T. AMMONIA AS N, MG/L: INITIAL - 100% A 4, / FINAL - 100% Nhi TOT. RES=. C *34E SLOR , MG/Ls 100% 20. )0 SAMPLE DECRLOR-'NATED 3EPORE TEST' !ZS / 70. LABORATORY: l 6)retl d l lfl�,hy c ��y.eeer: j ANALYST: �ief/.iof 7-is COMMITS: 1/1/91 1% 93106.1/0 0 ATTACHMENT 6 Additional Water Analyses North Discharge (N-Discharge) Spomer Lake (SP Lake) GWMWO1 GWMWO2 GWMWO3 931061 /0 / Enseco Volatile Organics ^ ^ins C«^a^° Target Compound List (TCL) Method 8240 Client Name: Waste Management of North America, Inc. Client ID: N-Discharge Lab ID: 021837-0004-SA Matrix: AQUEOUS Sampled: 27 MAR 92 Received: 28 MAR 92 Authorized: 28 MAR 92 Prepared: 31 MAR 92 Analyzed: 09 APR 92 Reporting Parameter Result Units Limit Acetone ND ug/L 10 Benzene ND ug/L 5.0 Bromodichloromethane ND ugh 5.0 ND ug/L 5.0 Bromomethane ND ug/L 10 2-Butanone (MEK) ND ug/L 10 Carbon disulfide ND ug/L 5.0 Carbon tetrachloride ND ug/L 5.0 Chlorobenzene ND ug/L 5.0 Chloroethane ND ug/L 10 Chloroform ND ug/L 5.0 Chloromethane ND ug/l 10 Dibromochloromethane ND ug/L 5.0 1, 1-Dichloroethane ND ug/L 5.0 1,2-Dichloroethane ND ug/L `.0 1, 1-Dichloroethene ND ug/L 5.0 1,2-Dichloroethene (total ) ND ug/L 5.0 1,2-Dichloropropane ND ug/L 5.0 cis-1,3-Dichloropropene ND ug/L 5.0 trans-1,3-Dichloropropene ND ug/L 5.0 Ethylbenzene ND ug/L 5.0 2-Hexanone ND ug/L 10 Methylene chloride ND ug/L 5.0 4-Methyl -2-pentanone (MIBK) NND D ug/L L 10 Styrene 5.0 1, 1 ,2,2-Tetrachloroethane ND ug/L 5.0 Tetrachloroethene ND ug/L 5.0 Toluene ND ug/L 5.0 1,1, 1-Trichloroethane ND ug/L 5.0 1, 1,2-Trichloroethane ND ug/L 5.0 Trichloroethene ND ug/L 5.0 Vinyl acetate ND ug/L 10 Vinyl chloride ND ug/L 10 Xylenes (total ) ND ug/L 5.0 Surrogate Recovery Toluene-d8 106 % 4-Bromofluorobenzene 97 % (continued on following page) ND - Not detected NA . Not applicable Reported By: Stephanie Boehnke Approved By: Karen Kuiken • fr 93106 Erlseco Volatile Organics Target Compound List (TCL) Method 8240 Client Name: Waste Management of North America, Inc. Client ID: N-Discharge Lab ID: 021837-0004-SA Matrix: AQUEOUS Sampled: 27 MAR 92 Received: 28 MAR 92 Authorized: 28 MAR 92 Prepared: 31 MAR 92 Analyzed: 09 APR 92 Surrogate Recovery 1,2-Dichloroethane-d4 99 x • • ND • Not detected NA - Not applicable Reported By: Stephanie Boehnke Approved By: Karen Kuiken 931061 /O Chlorinated Pesticides and PCB's nseco ACcormiscamm" Target Compound List (TCL) Method 8080 Client Name: Waste Management of North America, Inc. Client ID: N-Discharge Lab ID: 021837-0004-SA Matrix: AQUEOUS Sampled: 27 MAR 92 Received: 28 MAR 92 Authorized: 28 MAR 92 Prepared: 31 MAR 92 Analyzed: 08 APR 92 Reporting Parameter Result Units Limit gamma-BHC (Lindane) ND ug/L 0.050 Endrin ND ug/L 0.10 Methoxychlor ND ug/L 0.50 Toxaphene ND ug/L 5.0 Surrogate Recovery Dibutyl chlorendate 88 % ND - Not detected NA • Not applicable Reported By: Lue Lor Approved.By: Karen Kuiken 931061 /G'/ Enseco RCRA Herbicides A CatlinChwnaw Method 8150 Client Name: Waste Management of North America, Inc. Client ID: N-Discharge Lab ID: 021837-0004-SA Matrix: AQUEOUS Sampled: 27 MAR 92 Received: 28 MAR 92 Authorized: 28 MAR 92 Prepared: 30 MAR 92 Analyzed: 13 APR 92 Reporting Parameter Result Units Limit 2,4-0 ND ug/L 12 2,4,5-TP (Silvex) ND ug/L 1.7 Surrogate Recovery DCAA 92 % • ND • Not detected NA - Not applicable . Reported By: Lue Lor Approved By: Karen Kuiken r 931061 /D5 Metals EnsecoM" Total Metals Client Name: Waste Management of North America, Inc. Client ID: N-Discharge Lab ID: 021837-0004-SA Matrix: AQUEOUS Sampled: 27 MAR 92 Received: 28 MAR 92 Authorized: 28 MAR 92 Prepared: See Below Analyzed: See Below Reporting Analytical Prepared Analyzed Parameter Result Units Limit Method Date Date Arsenic ND mg/L 0.010 7060 30 MAR 92 02 APR 92 Barium 0.016 mg/L 0.010 6010 30 MAR 92 31 MAR 92 Cadmium NO mg/L 0.0050 6010 30 MAR 92 31 MAR 92 Calcium 409 mg/L 0.20 6010 30 MAR 92 31 MAR 92 Chromium ND mg/L 0.010 6010 30 MAR 92 31 MAR 92 Iron 0.24 mg/L 0.10 6010 30 MAR 92 31 MAR 92 Lead ND mg/L 0.010 7421 30 MAR 92 02 APR 92 Magnesium 217 mg/L 0.20 6010 30 MAR 92 31 MAR 92 Manganese 0. 17 mg/L 0.010 6010 30 MAR 92 31 MAR 92 Mercury NO mg/L 0.00020 7470 30 MAR 92 31 MAR 92 Potassium ND mg/L 5.0 6010 30 MAR 92 31 MAR 92 Selenium ND mg/L 0.050 7740 30 MAR 92 01 APR 92 Silver . ND mg/L 0.010 6010 30 MAR 92 31 MAR 92 Sodium 91 .3 mg/L 5.0 6010 30 MAR 92 31 MAR 92 ND - Not detected NA - Not applicable Reported By: Sandra Jones Approved .By: Sandra Jones • 931061 /o F-nseco General Inorganics A Corning CTa-._ Client Name: Waste Management of North America, Inc. Client ID: N-Discharge Lab ID: 021837-0004-SA Matrix: AQUEOUS Sampled: 27 MAR 92 Received: 28 MAR 92 Authorized: 28 MAR 92 Prepared: See Below Analyzed: See Below Reporting Analytical Prepared Analyzed Parameter Result Units Limit Method Date Date Alkalinity, Bicarb. as CaC03 at pH 4.5 338 mg/L 5.0 310.1 NA 28 MAR 92 Alkalinity, Garb. as CaCO3 at pH 8.3 ND mg/L 5.0 310.1 NA 28 MAR 92 Chloride 33.3 mg/L 3.0 300.0 NA 28 MAR 92 Ammonia as N ND mg/L 0. 10 350.1 NA 30 MAR 92 Nitrate as N 15.9 mg/L 0. 10 300.0 NA 28 MAR 92 Sulfate 1720 mg/L 25.0 300.0 NA 28 MAR 92 • ND - Not detected NA = Not applicable Reported By: Steve Pope Approved. By: Blake Besser r 931061 /o EILSeco Radiochemistry ,c.,�.,Coma . Client Name: Waste Management of North America, Inc. Client ID: N-Discharge Lab ID: 021837-0004-SA Matrix: AQUEOUS Sampled: 27 MAR 92 Received: 28 MAR 92 Authorized: 28 MAR 92 Prepared: See Below Analyzed: See Below Reporting Analytical Prepared Analyzed Parameter Result Units Limit Method Date Date Gross Alpha 15 pCi/L +-20) 900.0 NA 14 APR 92 Radium 226 0.0 pCi/L +-0.3) 705 Modified NA 14 APR 92 Gross Beta 14 pCi/L +-20) 900.0 NA 14 APR 92 Radium 228 0.3 pCi/L +-1.3) EPA Specified NA 16 APR 92 ND - Not detected NA - Not applicable Reported By: Ramona Power Approved• By: Roxanne Sullivan /- 931061 / ) Page: 3 liCill 1Q ENVIROIB8ENIAL MONITORING LABORATORIES, INC ‘e CLIENT REPORT Rite: 488 — Central Weld County Sample Point: NDIS NIB: 92-11934 Sampled: 16-JAL-1992 Sanitary Landfill Sample Type: RIV/STREAM MP: 488921 Received: 17-JAL-1992 Wald County Road 271/2 Sample Number: AF2941 REV: 00 Reported: 1-SEP-1992 Miliken CO 80543 Analyte Result OIL RL Units Comments Method FIELD DATA: PH FIELD 8.02 PH UNITS FDPHQOADO1 PH FIELD 8.01 PH UNITS FDPHQUADO1 PH FIELD 7.99 PH UNITS FDPHQUADO1 PH FIELD 7.98 - PH UNITS FDPHQUADO1 SPECIFIC CONDUCTANCE FIELD 1350. UIOOs/CM FDSPCONDO4 SPECIFIC CONDUCTANCE FIELD 1350. OMNOB/CM FDSPCONDO4 SPECIFIC CONDUCTANCE FIELD 1360. ANUS/CM FDSPCONDO4 SPECIFIC CONDUCTANCE FIELD 1360. UMOOS/CM FDSPCONDO4 WATER TEMPERATURE IN DEGREES CELSIUS 16.2 DEGREES C FDXTEMPC01 CHEMICAL METHODS a ROBOTICS: ALEALINITY,BICARBONATE 542 100.000 MG/L DL CRALEBIC01 ALKALINITY,CARBONATE ND 10.000 MG/L NQ CRALKC0301 CHLORIDE 13.0 0.500 MG/L CRCHLORIO1 NITROGEN, AMMONIA ND 0.020 MG/L CRN2NH3X01 NITROGEN, NITRATE 3.12 0.100 MG/L DL CRNO3HYD01 SULFATE 542 5.000 MG/L CRSULFATO1 INORGANICS: ARSENIC-TOTAL ND 10.000 UG/L INGFAATOSS BARIUM-TOTAL ND 200.000 UG/L INICPTOTBA CADMIUM-TOTAL ND 5.000 UG/L INICPTOTCD CALCIUM-TOTAL 171000 5000.000 UG/L INICPTOTCA CHROMIUM-TOTAL ND 10.000 UG/L INICPTOTCR IRON-TOTAL 5320 100.000 UG/L INICPTOTBE LEAD-TOTAL ND 5.000 UG/L INGFAATOPB MAGNESIUM-TOTAL 82200 5000.000 UG/L INICPTOTMG MANGANESE-TOTAL 287 15.000 UG/L INICPTOTMN MERCURY-TOTAL ND 0.200 OG/L INCVAATOHG POTASSIUM-TOTAL ND 5000.000 UG/L INFAATOTXK SELENIUM-TOTAL ND 25.000 UG/L DL INGFAATOSE SILVER-TOTAL ND 25.000 UG/L INICPTOTAG SODIUM-TOTAL 49400 5000.000 OG/L INICPTOTNA SOB-CONTRACT DATA: GROSS ALPHA 5.5 0.100 PCI/L +1- SBALPHBETA GROSS BETA 0.6 0.100 PCI/L +/- SBALPHBETA RADIUM 226 0.6 0.100 PCI/L +/- NA,SB SBRA226228 RADIUM 226-STANDARD DEVIATION 0.7 PCI/L +/- NA,SB SBRA226228 RADIUM 228 ND 0.100 PCl/L +/- NA,SB SBRA226228 RADIUM 228-STANDARD DEVIATION 2.2 PCI/L +1- NA,SB SBRA226228 STANDARD DEVIATION-GROSS ALPHA 7.9 PCI/L +1- SBALPHBETA STANDARD DEVIATION-GROSS BETA 8.6 PCI/L +/- SBALPHBETA SEMI-VOLATILE CBGAJICSt- 2,4-DICHLOROPHENOEYACETIC ACID ND 1.000 UG/L SVGC2HRB01 2-(2,4,5-TRICHI.OROPH87OXY)PROPIONIC ACID ND 1.000 UG/L SVGC2HRB01 ENDRIN ND 0.100 UG/L SVGC10CP01 LINDANE (GAMMA-BBC) ND 0.050 DG/L SVGC10CP01 METHOXYCHLOR ND 0.500 UG/L SVGC10CP01 TOXAPHENE ND 1.000 UG/L SVGC10CP01 VOLATILE OIW ASwS: 1,1,1-TRICHLOROETHANE ND 2.000 UG/L VQMSAAX424 1,1,2,2-TETRACHLOROETHANE ND 2.000 UG/L VOMSAAX424 1,1,2-TRICHLOROETHANE - ND 1.000 UG/L - VOMSAAX424 1,1-DICHLOROETHANE ND 3.000 UG/L VOMSAAX424 NA a Not Analysed ND a Not Detected TON a Trip Blank Item Additional Comment Explanations (NQ/DL) .LKALINITY,BICARBONATE Dilution factor 10 applied. LKALINITY,CARBONATE CARBONATE ALKALINITY IS 0 MG/L BECAUSE SAMPLE PH < 8.3. ��ITROGEN, NITRATE Dilution factor 2 applied. ;ELENIUM-TOTAL Dilution factor 5 applied. 9:31i)61 /6 j Page: 4 NMI ENVIRONMENTAL MONITORING LABORATORIES, INC ‘a CLIENT REPORT 'its: 488 — Central Weld County Semple Point: NDIS RIDS: 92-11934 Sampled: 16-JUL-1992 Sanitary Landfill Sample Type: RIV/STREAM IC: 488921 Received: 17-JUL-1992 Weld County Road 271/2 Sample Number: AF2941 REV: 00 Reported: 1-SEP-1992 Miliken CO 80543 Analyte Result OIL RL Units Comments Method 1, 1-DICHLOROETHENE ND 2.000 OG/L - VOMSAAX424 1,2,3-TRICHLOROPROPANE ND 2.000 OG/L V0MSAAX424 1,2-DICHLOROETHENE ND 2.000 OG/L VOMSAAX424 1,2-DICHLOROPROPANS ND 2.000 OG/L VOMSAAX424 1,4-DICHLORO-2-BDTENE(TOTAL) ND 2.000 OG/L VOMSAAX424 1,4-DIFLUOROBENZENE NA OG/L VOMSAAX424 2-B0TAN0NE ND 20.000 UG/L VOMSAAX424 2-CHLOROETHYLVINYL ETHER ND 5.000 0G/L VOMSAAX424 2-HEXANONE ND 4.000 0G/L VOMSAAX424 4-BROMOFLUOROBENZENE ND 0.800 OG/L VOMSAAX424 4-METHYL-2-PENTANONE ND 5.000 OG/L VOMSAAX424 ACETONE ND 25.000 OG/L - V0MSAAX424 ACROLEIN ND 10.000 OG/L PY VOMSDAX101 ACRYLONITRILE ND 10.000 OG/L PY VOMSDAX101 BENZENE ND 1.000 OG/L VOMSAAX424 BROMOCHLOROMETHANE ND 2.000 COIL VOMSAAX424 BROMOD ICHLOROMETHANE ND 1.000 0G/L VOMSAAX424 BROMOFORM ND 1.000 OG/L VOMSAAX424 BROMOt4eTHANE ND 2.000 UG/L VOMSAAX424 CARBON DISULFIDE - ND 3.000 COIL VOMSAAX424 CARBON TETRACHLORIDE ND 1.000 OG/L VOMSAAX424 CHLOROBENZENE ND 1.000 OG/L V0MSAAX424 CHLOROETHANE ND 3.000 OG/L VOMSAAX424 CHLOROFORM ND 2.000 OG/L VOMSAAX424 CHLOROMETHANE ND 2.000 OG/L V0MSAAX424 CIS-1,3-DICHLOROPROPENE ND 1.000 OG/L V0MSAAX424 D IBROMOCHLOROMETHANE ND 1.000 OG/L VOMSAAX424 DIBROMOMETHANE ND 1.000 OG/L V0MSAAX424 DICHLORODIFLOOROMETHANE ND 2.000 OWL VOMSAAX424 ETHANOL ND 100.000 UG/L PY VOMSDAX101 ETHYL METHACRYLATE ND 10.000 OG/L PY VOMSDAX101 ETHYLBENZENE ND 1.000 OG/L V0MSAAX424 IODO8=BANE ND 2.000 OG/L V0MSAAX424 METHYLENE CHLORIDE ND 3.000 OG/L VOMSAAX424 STYRENE ND 1.000 UG/L VOMSAAX424 TETRACHLOROETHENE . ND 1.000 00/L VOMSAAX424 TOLUENE ND 1.000 OG/L VOMSAAX424 TRANS-1,2-DICHLOROETHENE ND 3.000 OG/L VOMSAAX424 TRANS-1,3-DICHLOROPROPENE ND 1.000 OG/L V0MSAAX424 TRICHLOROETNENE ND 1.000 OG/L VOMSAAX424 TRICHLOROFLOOROMETBANE ND 2.000 OGIL VOMSAAX424 VINYL ACETATE ND 4.000 OG/L � . VOMSAAX424 VINYL CHLORIDE ND 2.000 00/L VOMSAAX424 XYLENE(TOTAL) ND 2.000 COIL VOMSAAX424 NA AA Not Analysed W - Not Detected TBE .• Trip Blank / F--- 931061 / /(1 Page: 7 \a !I EMVIRINHINTAL MONITORING LABORATORIES, INC CLIENT REPORT te: 488 - Central Weld County Sample Point: SPLAKE INS: 92-11934 Sampled: 16-JUL-1992 Sanitary Landfill Sample Type: RIV/STREAM IF: 488921 Received: 17-JUL-1992 Weld County Road 271/2 - sample Number: AF2943 RSV: 00 Reported: 1-SEP-1992 Miliken CO 80543 Analyte Result EML RL Units Comments Method FIELD DATA: 8.35 PH UNITS FDPHQUADO1 PH FIELD 8.35 PH OMITS FDPHQUADO1 PH FIELD 8.34 PH UNITS FDPHQUAD01 PH FIELD 8.32 PH UNITS FDPHQUADO1 PH FIELD 1358. OMEOS/CM FDSPCOND04 SPECIFIC CONDUCTANCE FIELD 1357. OMNOS/CM FDSPCONDO4 SPECIFIC CONDUCTANCE FIELD 1348. USOS/CM FDSPCONDO4 SPECIFIC CONDUCTANCE FIELD 1323. 01110E/CM FDSPCONDO4 WA SPECIFIC CONDUCTANCE FIELD DEGREES C FDXTEMPC01 WATER TEMPERATURE IN DEGREES CELSIUS 19.5 CHEMICAL METHODS a ROBOTICS: 143 10.000 MG/L CRALKBICOI ALKALINITY,CIOBONATETE ND 10.000 MG/L NQ CRALKCO301 ALKALINITY,CARBONATE 9.0 0.500 MG/L CRCHLORIO1 CHLORIDE ND 0.020 MG/L CRN2NH3X01 NITROGEN, AMMONIA 0.064 0.050 MG/L CRN03HYD01 NITROGEN, NITRATE 553 50.000 MG/L DL CRSOLFATO1 SULFATE INORGANICS: ARSENIC-TOTAL ND 10.000 UG/L INGFAATOAS BARIUM-TOTAL ND 200.000 UG/L INICPTOTBA CADMIUM-TOTAL ND 5.000 UG/L INICPTOTCA CALCIUM-TOTAL 147000 5000.000 UG/L INICPTOTCA CHROMIUM-TOTAL ND 10.000 UG/L CR IRON-TOTAL 254 100.000 UG/L INICPTOTFE LEAD-TOTAL ND 5.000 OG/L INGFAATOPB MAGNESIUM-TOTAL 101000 5000.000 OG/L INICPTOTMG MANGANESE-TOTAL 277 15.000 OG/L - INICPTOTMN MERCURY-TOTAL - ND 0.200 00/L INCVAATOHG INA POTASSIUM-TOTAL ND 5000.000 OG/L TOTXK SELENIUM-TOTAL ND 25.000 OG/L DL INGFAATOSE SILVER-TOTAL ND 25.000 OG/L INICPTOTAG SODIUM-TOTAL 72200 5000.000 0G/L INICPTOTNA SUB-CONTRACT DATA: 15.8 0.100 PCI/L +/- SBALPHBETA GROSS ALPHA A ND 0.100 PCI/L +/- SBALPHBETA GROSS 822 0.2 0.100 PCI/L +/- SB SBRA226228 RADIUM 226 0.6 PCl/L +/- SB 5BRA226228 RADIUM 226-STANDARD DEVIATION ND 0.100 PCI/L +/- SB SBRA226228 RADIUM 228 2 3 PCI/L +/- SB SBRA226228 RADIUM 228-STANDARD DEVIATION 11 4 PCl/L +/- SBALPHBETA STANDARD DEVIATION-GROSS ALPHA 8 6 PCl/L +/- SBALPHBETA STANDARD DEVIATION-CAROBS BETA. SEMI-VOLATILE ORGANICS: ND 1.000 OG/L SVGC2HRB01 2, 4-DICHLOROPHENOXYACETIC ACID B01 2-(2,4,5-TRICHLOR0P1ENOXY)PR0P IONIC ACID ND 1.000 OG/L SVGC5VGC2HR25RP01 ENDRIN ND 0.100 OG/L SVGC10CP01 LINDANE (GAMMA-BHC) ND 0.050 00/L 0.500 UG/L SVGC10CP01 TOXAPHENE NNDD 1.000 OG/L SVGC10CP01 TOXAPHENE VOLATILE ORGANICS: ND 2.000 OG/L VOMSAAX424 1, 1, 1-TRICHLOROETHANE ND 2.000 OG/L VOMSAAX424 1,1,2,2-TETRACHLOROETHANE ND 1.000 OG/L VOMSAAX424 1, 1,2-TRICHLOROETHANL ND 3.000 OG/L VOMSAAX424 1, 1-DICHLOROETHANE NA - Not Analysed ND - Not Detected TIE - Trip Blank Item Additional cant Explanations (ND/DL) ALKALINITY,CARBONATE CARBONATE ALKALINITY IS 0 MG/L BECAUSE SAMPLE PH < 8.3. SULFATE Dilution factor 10 applied. SELENIUM-TOTAL Dilution factor 5 applied. Rai/k<• TSBPA226228 ENSECO NJ 931061 , /1 / Page: 8 NC/ MC ENVIROIIENfAL MONITORING LABORATORIES, INC CLIENT REPORT ite: 488 - Central Weld County Sample Point: SPLARE ENS: 92-11934 Sampled: 16-JUL-1992 Sanitary Landfill Sample Type: RIV/STREAM MP: 488921 Received: 17-JUL-1992 Weld County Road 271/2 Sample NUmber: AF2943 REV: 00 Reported: 1-SEP-1992 Miliken CO 80543 Analyte Result EMI RL Onits Comments Method 1, 1-DICHLOROETHENE ND 2.000 UG/L VOMSAAX424 1,2, 3-TRICHLOROPROPANE ND 2.000 OG/L VOMSAAX424 1,2-DICHLOROETHANE ND 2.000 OG/L VOMSAAX424 1,2-DICHLOROPROPANE ND 2.000 UG/L VOMSAAX424 1,4-DICHLORO-2-BUTENE(TOTAL) ND 2.000 OG/L VOMSAAX424 1,4-DIFL0OROBENZENE NA OG/L VOMSAAX424 2-BUTANONE ND 20.000 OG/L VOMSAAX424 2-CHLOR0ETHYLVINYL ETHER ND 5.000 OG/L ST VOMSAAX424 2-HEXANONE ND 4.000 OG/L VOMSAAX424 4-BROMOFLUOROBENZENE ND 0.800 OG/L VOMSAAX424 4-METHYL-2-PENTANONE ND 5.000 OG/L VOMSAAX424 ACETONE ND 25.000 OG/L VOMSAAX424 ACROLEIN ND 10.000 OG/L PY VOMSDAX101 ACRYLONITRILE ND 10.000 OG/L PY VOMSDAX101 BENZENE ND 1.000 UG/L VOMSAAX424 BROMOCHLOROMETHANE ND 2.000 UG/L VOMSAAX424 BROMODICHLOROMETHANE ND 1.000 OG/L VOMSAAX424 BROMOFORM ND 1.000 OG/L VOMSAAX424 BROMOMETHANE ND 2.000 OG/L VOMSAAX424 CARBON DISULFIDE ND 3.000 OG/L VOMSAAX424 CARBON TETRACHLORIDE ND 1.000 OG/L VOMSAAX424 CHLOROBENZENE ND 1.00O OG/L - VOMSAAX424 CHLOROETHANE ND 3.000 OG/L VOMSAAX424 CHLOROFORM ND 2.000 OG/L VOMSAAX424 CHLOROMETHANE ND 2.000 OG/L VOMSAAX424 CIS-1, 3-DICHLOROPROPANE ND 1.000 OG/L VOMSAAX424 DIBROMOCHLOROMETHANE ND 1.000 OG/L VOMSAAX424 DIBROMOMETHANE ND 1.000 OG/L VOMSAAX424 DICHLORODIFLOOROMETHANE ND 2.000 OG/L V0MSAAX424 ._ ETHANOL ND 100.000 OG/L PY VOMSDAX101 ETHYL METHACRYLATE ND 10.000 OG/L PY VOMSDAX101 ETHYLBENZENE ND 1.000 UG/L VOMSAAX424 IODOMETHANE ND 2.000 OG/L VOMSAAX424 METHYLENE CHLORIDE ND 3.000 OG/L VOMSAAX424 STYRENE ND 1.000 OG/L VOMSAAX424 TETRACHLOROETHENE ND 1.000 OG/L VOMSAAX424 TOLUENE ND 1.000 UG/L VOMSAAX424 TRANS-1,2-DICHLOROETHENE ND 3.000 OG/L VOMSAAX424 TRANS-I, 3-DICHLOROPROPENE ND 1.000 OG/L VOMSAAX424 TRICHLOROETHENE ND 1.000 OG/L VOMSAAX424 TRICHLOROFL0OROMETHANE ND 2.000 OC/L VOMSAAX424 VINYL ACETATE ND 4.000 OG/L VOMSAAX424 VINYL CHLORIDE ND 2.000 OG/L VOMSAAX424 XYLENE(TOTAL) ND 2.000 OG/L VOMSAAX424 NA - Not Analysed ND - Not Detected TIE - Trip Blank / 931061 / /A Page: 6 1 ` R42 ENVIRONlENTAL MONITORING LABORATORIES, INC SCLIENT REPORT Site: 488 — Central Weld County Sample Point: GWMW01 ENS: 92-11933 Sampled: 16-JUL-1992 Sanitary Landfill Sample Type: WELL 4@: 488921 Received: 11-JUL-1992 Weld County Road 271/2 Sample Number: AF2926 REV: 00 Reported: 2-SEP-1992 Miliken CO 80543 Analyte Result EML RL Units Comments Method VOLATILE ORGANICS: 1, 1, 1-TRICHLOROETHANE ND 2.000 UG/L VOMSAAX424 1, 1,2,2-TETRACHLOROETHANE ND 2.000 UG/L VOMSAAX424 1, 1,2-TRICHLOROETHANE ND 1.000 UG/L - VOMSAAX424 1, 1-DICHLOROETHANE ND 3.000 UG/L VOMSAAX424 1, 1-DICHLOROETHENE ND 2.000 DG/L VOMSAAX424 1,2, 3-TRICHLOROPROPANE ND 2.000 UG/L VOMSAAX424 1,2-DICHLOROETHANE ND 2.000 UG/L VOMSAAX424 1,2-DICHLOROPROPANE ND 2:000 UG/L VOMSAAX424 1,4-DICHLORO-2-BUTENE(TOTAL) ND 2.000 UG/L VOMSAAX424 i,4-DIFLUOROBENZENE NA UG/L VOMSAAX424 2-BUTANONE ND 20.000 UG/L VOMSAAX424 2-CHLOROETHYLVINYL ETHER ND 5.000 UG/L ST VOMSAAX424 2-HEXANONE ND 4.000 UG/L VOMSAAX424 4-BROMOFLUOROBENZENE ND 0.800 UG/L VOMSAAX424 4-METHYL-2-PENTANONE ND 5.000 UG/L VOMSAAX424 ACETONE ND 25.000 UG/L VOMSAAX424 ACROLEIN ND 10.000 UG/L PY VOMSDAX101 ACRYLONITRILE ND 10.000 UG/L PY VOMSDAX101 BENZENE ND 1.000 UG/L VOMSAAX424 BROMOCHLOROMETHANE ND 2.000 UG/L VOMSAAX424 BROMODICHLOROMETHANE ND 1.000 OG/L VOMSAAX424 BROMOFORM ND 1.000 OG/L VOMSAAX424 BROMOMETHANE ND 2.000 UG/L VOMSAAX424 CARBON DISULFIDE ND 3.000 UG/L VOMSAAX424 CARBON TETRACHLORIDE ND 1.000 UG/L VOMSAAX424 CHLOROBENZENE ND 1.000 UG/L VOMSAAX424 CHLOROETHANE ND 3.000 UG/L VOMSAAX424 CHLOROFORM ND • 2.000 00/L VOMSAAX424 CHLOROMETHANE ND 2.000 OG/L VOMSAAX424 CIS-1,3-DICHLOROPROPENE ND 1.000 OG/L VOMSAAX424 . DIBROMOCHLOROMETHANE ND 1.000 UG/L VOMSAAX424 DIBROMOMETHANE ND 1.000 OG/L VOMSAAX424 DICHLORODIFLOOROMETHANE ND 2.000 OG/L VOMSAAX424 ETHANOL ND 100.000 OG/L PY VOMSDAX101 ETHYL METHACRYLATE ND 10.000 OG/L PY VOMSDAX101 ETHYLBENZENE ND 1.000 OG/L VOMSAAX424 IODOMETHANE ND 2.000 OG/L - VOMSAAX424 METHYLENE CHLORIDE ND 3.000 OG/L VOMSAAX424 STYRENE ND 1.000 UG/L VOMSAAX424 TETRACHLOROETHENE ND 1.000 UG/L VOMSAAX424 TOLUENE ND 1.000 OG/L VOMSAAX424 TRANS-I,2-DICHLOROETHENE ND 3.000 OG/L VOMSAAX424 TRANS-1, 3-DICHLOROPROPENE ND 1.000 UG/L VOMSAAX424 TRICHLOROETHENE ND 1.000 DG/L VOMSAAX424 TRICHLOROFLUOROMETHANE ND 2.000 UG/L VOMSAAX424 VINYL ACETATE ND - 4.000 OG/L VOMSAAX424 VINYL CHLORIDE ND 2.000 OG/L VOMSAAX424 XYLENE(TOTAL) ND 2.000 OG/L VOMSAAX424 NA - Not Analyzed ND - Not Detected TBR - Trip Blank F� 931061//i/ Page: 5 NMI ENVIRONMENTAL MONITORING LABORATORIES, INC ‘S CLIENT REPORT ;ite: 488 - Central Weld County Sample Point: GWMWO1 ENS: 92-11933 ' Sampled: 16-JUL-1992 Sanitary Landfill Sample Type: WELL MP: 488921 Received: :7-JUL-1992 Weld County Road 271/2 Sample Number: AF2926 REV: 00 Reported: 2-SEP-1992 Miliken CO 80543 Analyte Result EIII. RL Units Comments Method FIELD DATA: DEPTH TO WATER FROM TOP OF CASING 24.07 FT FDWDTWTCO1 GROUNDWATER ELEV. 4811.10 FT MSL FDWGWELWCT PH FIELD 7.42 PH UNITS FDPHQUADO1 PH FIELD 7.40 PH UNITS FDPHQUADOI PH FIELD 7.38 PH UNITS FDPHQUADO1 PH FIELD 7.36 PH UNITS FDPHQUADOI SPECIFIC CONDUCTANCE FIELD 3370. O)RIOS/CM FDSPCONDO4 SPECIFIC CONDUCTANCE FIELD 3360. UMHOS/CM FDSPCONDO4 SPECIFIC CONDUCTANCE FIELD 3330. UMHOS/CM FDSPCONDO4 SPECIFIC CONDUCTANCE FIELD 3390. UMHOS/CM FDSPCONDO4 WATER TEMPERATURE IN DEGREES CELSIUS 12.5 DEGREES C FDXTEMPCOI WELL DEPTH TOTAL 34.37 FT FDWGWELWDT. CHEMICAL METHODS i ROBOTICS: ALKALINITY,BICARBONATE 429 10.000 MG/L CRALKBIC01 ALKALINITY,CARBONATE ND 10.000 MG/L NQ CRALKC030: CHLORIDE 16.9 0.500 MG/L CRCHLORI01 NITROGEN, AMMONIA ND 0.020 MG/L CRN2NH3X01 NITROGEN, NITRATE 0.096 0.050 MG/L CRNO3HYD01 SULFATE 1810 250.000 MG/L DL CRSULFATO1 INORGANICS: ARSENIC-DISSOLVED ND 10.000 UG/L INGFAADIAS BARIUM-DISSOLVED ND 200.000 UG/L INICPDISBA CADMIUM-DISSOLVED ND 5.000 UG/L INICPDISCD CALCIUM-DISSOLVED 415000 5000.000 UG/L INICPDISCA CHROMIUM-DISSOLVED ND 10.000 UG/L INICPDISCR ' IRON-DISSOLVED ND • 100.000 UG/L INICPDISFE LEAD-DISSOLVED • ND 25.000 UG/L DL INGFAADIPB MAGNESIUM-DISSOLVED 254000 7250.000 UG/L DL • INICPDISMG MANGANESE-DISSOLVED ND 15.000 UG/L INICPDISMN MERCURY-DISSOLVED ND 0.200 UG/L INCVAADIHG POTASSIUM-DISSOLVED ND 5000.000 UG/L - INFAADISXK SELENIUM-DISSOLVED ND 25.000 UG/L DL INGFAADISE SILVER-DISSOLVED ND 25.000 UG/L INICPDISAG SODIUM-DISSOLVED 78800 5000.000 UG/L INICPDISNA SUB-CONTRACT DATA: GROSS ALPHA 79 0.100 PCI/L +/- SBALPHBETA GROSS BETA 1.7 0.100 PCI/L +/- SBALPHBETA RADIUM 226 4.1 0.100 PCI/L +/- SB SBRA226228 RADIUM 226-STANDARD DEVIATION 1.1 PCI/L +/- SE SBRA226228 RADIUM 228 ND 0.100 PCI/L +/- SB SBRA226228 RADIUM 228-STANDARD DEVIATION 2.3 PCI/L +/- SB SBRA226228 STANDARD DEVIATION-GROSS ALPHA 38.6 PCI/L +/- SBALPHBETA STANDARD DEVIATION-GROSS BETA 33.6 PCI/L +/- SBALPHBETA SEMI-VOLATILE ORGANICS: 2, 4-DICHLOROPHEN•OXYACETIC ACID ND 1.000 UG/L SVGC2HRBOI 2-(2,4,5-TRICHLOROPHENOXY)PROPIONIC ACID ND 1.000 UG/L SVGC2HRB0I ENDRIN ND 0.100 UG/L SVGC1OCP01 LINDANE (GAMMA-BHC) ND 0.050 UG/L SVGC10CP01 METHOXYCHLOR ND 0.500 UG/L SVGC10CP01_ TOXAPHENE ND 1.000 OG/L SVGC1OCP01 NA - Not Analyzed ND - Not Detected Tat - Trip Blank Item Additional Cement Explanations (NQ/DL) I LKALINITY,CARBONATE CARBONATE ALKALINITY IS 0 MG/L BECAUSE SAMPLE PH < 8.3. ULFATE Dilution factor 50 applied. EAD-DISSOLVED Dilution factor 05 applied. AGNESIUM-DISSOLVED Dilution factor 5 applied. IGELENIUM-DISSOLVED Dilution factor OS applied. 3RA226228 CORE - 931061 // 3 Page: 7 NMI ENVIRONMENTAL MONITORING LABORATORIES, INC ‘S CLIENT REPORT ite: 488 - Central Weld County Sample Point: GWMWO2 ENS: 92-11933 Sampled: 20-JUL-1992 Sanitary Landfill Sample Type: WELL MP: 488921 Received: 21-JUL-1992 Weld County Road 271/2 Sample Number: AF2934 REV: 00 Reported: 2-SEP-1992 Miliken CO 80543 Analyte Result EML RL Units Comments- Method FIELD DATA: DEPTH TO WATER FROM TOP OF CASING 13.94 FT FDWDTWTCO1 GROUNDWATER ELEV. 4824.68 FT MSL FDWGWELWDT PH FIELD 7.25 PH UNITS FDPHQUADO1 PH FIELD 7.24 PH UNITS FDPHQUADO1 PH FIELD 7.22 PH UNITS FDPHQUADO1 PH FIELD 7.21 PH UNITS FDPHQUADO1 SPECIFIC CONDUCTANCE FIELD 2520. UMHOS/CM FDSPCONDO4 SPECIFIC CONDUCTANCE FIELD 2520. OMHOS/CM FDSPCONDO4 SPECIFIC CONDUCTANCE FIELD 2550. UMHOS/CM FDSPCONDO4 SPECIFIC CONDUCTANCE FIELD 2600. UMHOS/CM FDSPCONDO4 WATER TEMPERATURE IN DEGREES CELSIUS 14.3 DEGREES C - FDXTEMPCO1 WELL DEPTH TOTAL 23.52 FT FDWGWELWDT CHEMICAL METHODS i ROBOTICS: ALKALINITY,BICARBONATE 376 10.000 MG/L CRALKBIC01 ALKALINITY,CARBONATE ND 10.000 MG/L CRALKC0301 CHLORIDE 21.4 0.500 MG/L CRCHLORIO1 NITROGEN, AMMONIA ND 0.020 MG/L CRN2NH3X01 NITROGEN, NITRATE 15.9 0.500 MG/L DL CRNO3HYD01 SULFATE 1190 100.000 MG/L DL CRSULFATO1 • INORGANICS: ARSENIC-DISSOLVED ND 10.000 UG/L INGFAADIAS BARIUM-DISSOLVED ND 200.000 UG/L INICPDISBA CADMIUM-DISSOLVED ND 5.000 UG/L INICPDISCD CALCIUM-DISSOLVED 363000 5000.000 UG/L INICPDISCA CHROMIUM-DISSOLVED ND 10.000 UG/L INICPDISCR IRON-DISSOLVED ND . 100.000 UG/L INICPDISFE LEAD-DISSOLVED ND 5.000 UG/L INGFAADIPB MAGNESIUM-DISSOLVED 127000 5000.000 UG/L INICPDISMG MANGANESE-DISSOLVED ND 15.000 UG/L INICPDISPII4 MERCURY-DISSOLVED ND 0.200 UG/L INCVAADIHG POTASSIUM-DISSOLVED ND 5000.000 UG/L INFAADISXK SELENIUM-DISSOLVED ND 25.000 UG/L DL INGFAADISE SILVER-DISSOLVED ND 25.000 UG/L INICPDISAG SODIUM-DISSOLVED 107000 5000.000 UG/L INICPDISNA SUB-CONTRACT DATA: GROSS ALPHA 26.1 0.100 PCl/L +/- SBALPHBETA GROSS BETA 31 0.100 PCl/L +/- SBALPHBETA RADIUM 226 3.9 0.100 PCI/L +/- SB SBRA226228 RADIUM 226-STANDARD DEVIATION 1.1 PCI/L +/- SB SBRA226228 RADIUM 228 ND 0.100 PCl/L +/- SB SBRA226228 RADIUM228-STANDARD DEVIATION 1.6 PCI/L +/- SB SBRA226228 STANDARD DEVIATION-GROSS ALPHA 21.8 PCl/L +/- SBALPHBETA STANDARD DEVIATION-GROSS BETA 20.8 PCI/L +/- SBALPHBETA SEMI-VOLATILE ORGANICS: 2, 4-DICHLOROPHENOXYACETIC ACID ND 1.000 UG/L SVGC2HRB01 2-(2, 4,5-TRICHLOROPHENOXY)PROPIONIC ACID ND 1.000 UG/L SVGC2HRB01 ENDRIN ND 0.100 UG/L - SVGC10CP01 LINDANE (GAMMA-BHC) ND 0.050 UG/L SVGC10CP01 METHOXYCHLOR ND 0.500 UG/L SVGC1OCP01 TOXAPHENE ND 1.000 UG/L SVGC10CP01 NA - Not Analyzed ND - Not Detected TBK - Trip Blank Item Additional Comment Explanations (NQ/DL) I ITROGEN, NITRATE Dilution factor 10 applied. :LFATE Dilution factor 20 applied. ELENIUM-DISSOLVED Dilution factor 05 applied. BRA226228 CORE I-VGC2HRB01 THE LAB CONTROL STANDARD ASSOCIATED WITH THIS SAMPLE FAILED RECOVERY CRITERIA. 931061 j16 Page: 8 NMI ENVIPON4ENT11L MONITORING LABORATORIES, INC 11457 CLIENT REPORT :ite: 488 - Central Weld County Sample Point: GWMWO2 ENS: 92-11933 Sampled: 20-JOL-1992 Sanitary Landfill Sample Type: WELL MP: 488921 Received: 21-JUL-1992 weld County Road 271/2 Sample Number: AF2934 REV: 00 Reported: 2-SEP-1992 Miliken CO 80543 Analyte Result ElC. RL Units Comments Method VOLATILE ORGANICS: 1, 1, 1-TRICHLOROETHANE ND 2.000 UG/L VOMSAAX424 1, 1,2,2-TETRACHLOROETHANE ND 2.000 UG/L VOMSAAX424 I, 1,2-TRICHLOROETHANE ND 1.000 UG/L VOMSAAX424 1, 1-DICHLOROETHANE ND 3.000 UG/L VOMSAAX424 1, 1-DICHLOROETHENE ND 2.000 UG/L VOMSAAX424 1,2, 3-TRICHLOROPROPANE ND 2.000 OG/L V0MSAAX424 1,2-DICHLOROETHANE ND 2.000 UG/L V0MSAAX424 1,2-DICHLOROPROPANE ND 2.000 UG/L VOMSAAX424 1, 4-DICHLORO-2-BUTENE(TOTAL) ND 2.000 UG/L VOMSAAX424 1, 4-DIFLUOROBENZENE NA UG/L VOMSAAX424 2-BUTANONE ND 20.000 UG/L V0MSAAX424 2-CHLOROETHYLVINYL ETHER ND 5.000 UG/L ST VOMSAAX424 2-HEXANONE ND 4.000 UG/L VOMSAAX424 4-BROMOFLUOROBENZENE ND 0.800 UG/L VOMSAAX424 4-METHYL-2-PENTANONE ND 5.000 UC/L VOMSAAX424 ACETONE ND 25.000 UG/L V0MSAAX424 ACRCLEIN ND 10.000 UG/L VOMSDAX101 ACRYLONITRILE ND 10.000 UG/L VOMSDAX101 BENZENE ND 1.000 DG/L VOMSAAX424 BROMOCHLOROMETHANE ND 2.000 UG/L VOMSAAX424 BROMODICBLOROMETHANE ND 1.000 DG/L VOMSAAX424 BROMOFORM ND 1.000 UG/L VOMSAAX424 BROMOMETHANE ND 2.000 DG/L VOMSAAX424 . CARBON DISULFIDE ND 3.000 UG/L VOMSAAX424 CARBON TETRACHLORIDE ND 1.000 UG/L VOMSAAX424 CHLOROBENZENE ND 1.000 UG/L VOMSAAX424 CHLOROETHANE ND 3.000 UG/L V0MSAAX424 CHLOROFORM ND • 2.000 UG/L VOMSAAX424 CHLOROMETHANE ND 2.000 UG/L VOMSAAX424 CIS-1,3-DICHLOROPROPENE ND 1.000 OG/L VOMSAAX424 DIBROMOCHLOROMETHANE ND 1.000 OG/L V0MSAAX424 DIBROMOMETHANE - ND 1.000 0G/L V0MSAAX424 DICHLORODIFLUOROMETHANE ND 2.000 UG/L VOMSAAX424 ETHANOL ND 100.000 DG/L VOMSDAX101 ETHYL METHACRYLATE ND 10.000 UG/L VOMSDAX101 ETHYLBENZENE ND 1.000 UG/L VOMSAAX424 IODOMETHANE ND 2.000 DG/L VOMSAAX424 METHYLENE CHLORIDE ND 3.000 DG/L VOMSAAX424 STYRENE ND 1.000 UG/L VOMSAAX424 TETRACHLOROETHENE ND 1.000 UG/L VOMSAAX424 TOLUENE ND 1.000 DC/L VOMSAAX424 TRANS-1,2-DICHLOROETHENE ND 3.000 DC/L VOMSAAX424 TRANS-1, 3-DICHLOROPROPENE ND 1.000 UG/L VOMSAAX424 TRICHLOROETHENE ND 1.000 UG/L V0MSAAX424 TRICHLOROFLUOROMETHANE ND 2.000 UG/L VOMSAAX424 VINYL ACETATE ND 4.000 DG/L VOMSAAX424 VINYL CHLORIDE ND 2.000 UG/L VOMSAAX424 XYLENE(TOTAL) ND 2.000 UG/L VOMSAAX424 NA .. Not Analyzed ND • Not Detected TSE - Trip Blank 931061// Page: 9 iQhNMI ENVIRONMENTAL MONITORING LABORATORIES, INC ‘e CLIENT REPORT ite: 488 - Central Weld County Sample Point: GWMN03 ENS: 92-11933 Sampled: 15-JUL-1992 Sanitary Landfill Sample Type: WELL MP: 488921 Received: 16-JUL-1992 Weld County Road 271/2 Sample Number: AF2924 REV: 00. Reported: 2-SEP-1992 Miliken CO 80543 Analyte Result EMI. RL Units Comments Method CHEMICAL METHODS 6 ROBOTICS: ALKALINITY,BICARBONATE 206 10.000 MG/L CRALKBIC01 ALKALINITY,CARBONATE ND 10.000 MG/L NQ CRALKC0301 CHLORIDE 76.9 0.500 MG/L CRCHLORI01 NITROGEN, AMMONIA ND 0.020 MG/L CRN2NH3X01 NITROGEN, NITRATE 8.13 0.500 MG/L DL CRN03HYD01 SULFATE 3010 100.000 MG/L DL CRSULFATO1 INORGANICS: ARSENIC-DISSOLVED ND 10.000 UG/L INGFAADIAS BARIUM-DISSOLVED ND 200.000 OG/L INICPDISBA CADMIUM-DISSOLVED ND 5.000 OG/L INICPDISCD CALCIUM-DISSOLVED 461000 5000.000 UG/L INICPDISCA CHROMIUM-DISSOLVED ND 10.000 OG/L INICPDISCR IRON-DISSOLVED ND 100.000 DG/L INICPDISFE LEAD-DISSOLVED ND 25.000 OG/L DL - INGFAADIPB MAGNESIUM-DISSOLVED ND 7250.000 OG/L DL INICPDISMG MANGANESE-DISSOLVED ND 15.000 OG/L INICPDISMN MERCURY-DISSOLVED ND 0.200 OG/L INCVAADIHG POTASSIUM-DISSOLVED 9980 5000.000 UG/L INFAADISXK SELENIUM-DISSOLVED ND 50.000 UG/L DL INGFAADISE SILVER-DISSOLVED ND 25.000 OG/L INICPDISAG SODIUM-DISSOLVED 221000 5000.000 OG/L INICPDISNA SUB-CONTRACT DATA: GROSS ALPHA 62.3 0.100 PCl/L +/- SBALPHBETA GROSS BETA 27.8 0.100 PCl/L +/- SBALPHBETA RADIUM 226 8.4 0.100 PCI/L +/- SB SBRA226228 RADIUM 226-STANDARD DEVIATION 1.5 • RPCI/L +1- SB SBRA226228 RADIUM 228 2.8 0.100 PCI/L +/- SB SBRA226228 RADIUM 228-STANDARD DEVIATION 1.8 PCl/L +/- SB SBRA226228 STANDARD DEVIATION-GROSS ALPHA 37.1 PCI/L +/- SBALPHBETA STANDARD DEVIATION-GROSS BETA 31.8 PCl/L +/- SBALPHBETA SEMI-VOLATILE ORGANICS: 2,4-DICHLOROPHENOXYACETIC ACID ND 1.000 OG/L SVGC2HRB01 2-(2,4,5-TRICHLOROPHENOXY)PROPIONIC ACID ND 1.000 OG/L SVGC2HRBO1 ENDRIN ND 0.100 OG/L SVGC10CP01 LINDANE (GAMMA-BHC) ND 0.050 OG/L SVGC10CP01 METHOXYCHLOR ND 0.500 OG/L SVGC10CP01 TOXAPHENE ND 1.000 OG/L SVGC10CP01 VOLATILE. ORGANICS: 1, 1, 1-TRICHLOROETHANE ND 2.000 UG/L VOMSAAX424 1, 1,2,2-TETRACHLOROETHANE ND 2.000 OG/L VOMSAAX424 1, 1,2-TRICHLOROETHANE ND 1.000 OG/L VOMSAAX424 1, 1-DICHLOROETHANE ND 3.000 OG/L - VOMSAAX424 1, 1-DICHLOROETHANE ND 2.000 UG/L VOMSAAX424 1,2, 3-TRICHLOROPROPANE ND 2.000 OG/L VOMSAAX424 1,2-DICHLOROETHANE ND 2.000 OG/L VOMSAAX424 1,2-DICHLOROPROPANE ND 2.000 OG/L VOMSAAX424 1,4-DICHLOR0-2-BUTENE(TOTAL) ND 2.000 OG/L VOMSAAX424 1,4-DIFLUOROBENZENE NA OG/L VOMSAAX424 2-BUTANONE ND 20.000 OG/L VOMSAAX424 2-CHLOROETHYLVINYL ETHER ND 5.000 UG/L ST VOMSAAX424 NA - Not Analysed ND - Not Detected TSE - Trip Blank Item Additional Comment Explanations (NQ/DL) i a_LKALINITY,CARBONATE CARBONATE ALKALINITY IS 0 MG/L BECAUSE SAMPLE PH < 8.3. ITROGEN, NITRATE Dilution factor 10 applied. . ULFATE Dilution factor 20 applied. ,EAD-DISSOLVED Dilution factor 5 applied. vIAGNESIUM-DISSOLVED' Dilution factor 5 applied. ELENIUM-DISSOLVED Dilution factor 10 applied. 3RA226228 CORE r u.31061 1, 7 Page: 10 /IQli an ENVIRONMENTAL MONITORING LABORATORIES, INC ‘457 CLIENT REPORT ite: 488 — Central Weld County Sample Point: GWMWO3 ENS: 92-11933 Sampled: 15-JUL-1992 Sanitary Landfill • Sample Type': WELL NP: 488921 Received: 16-JUL-1992 Weld County Road 271/2 Semple Number: AF2924 REV: 00 Reported: 2-SEP-1992 Miliken CO 80543 Analyte Result EMI, RL Units Comments Method 2-HEXANONE ND 4.000 OG/L VOMSAAX424 4-BROMOFLOOROBENZENE ND 0.800 UG/L VOMSAAX424 4-METHYL-2-PENTANONE ND 5.000 OG/L VOMSAAX424 ACETONE ND 25.000 OG/L VOMSAAX424 ACROLEIN ND 10.000 OG/L PY VOMSDAX101 ACRYLONITRILE ND 10.000 UG/L PY VOMSDAX101 BENZENE . ND 1.000 OG/L VOMSAAX424 BROMOCHLOROMETHANE ND 2.000 OG/L . VOMSAAX424 BROMODICHLOROMETHANE ND 1.000 UG/L VOMSAAX424 BROMOFORM ND 1.000 OG/L VOMSAAX424 BROMOMETHANE ND 2.000 OG/L VOMSAAX424 CARBON DISULFIDE ND 3.000 OG/L VOMSAAX424 CARBON TETRACHLORIDE ND 1.000 OG/L VOMSAAX424 CHLOROBENZENE ND 1.000 UG/L VOMSAAX424 CHLOROETHANE ND 3.000 UG/L VOMSAAX424 CHLOROFORM ND 2.000 UG/L VOMSAAX424 CHLOROMETHANE ND 2.000 OG/L VOMSAAX424 CIS-1,3-DICHLOROPROPENE ND 1.000 UG/L VOMSAAX424 DIBROMOCHLOROMETHANE ND 1.000 UG/L VOMSAAX424 DIBROMOMETHANE ND 1.000 UG/L VOMSAAX424 DICHLORODIFLUOROMETHANE ND 2.000 UG/L VOMSAAX424 ETHANOL ND - 100.000 OG/L PY VOMSDAX101 ETHYL METHACRYLATE ND 10.000 OG/L PY VOMSDAX101 ETHYLBENZENE ND 1.000 UG/L VOMSAAX424 IODOMETHANE ND 2.000 UG/L VOMSAAX424 METHYLENE CHLORIDE ND 3.000 UG/L VOMSAAX424 STYRENE ND 1.000 UG/L VOMSAAX424 TETRACHLOROETHENE ND 1.000 UG/L VOMSAAX424 TOLUENE ND • 1.000 UG/L VOMSAAX424 TRANS-1,2-DICHLOROETHENE • ND 3.000 UG/L VOMSAAX424 TRANS-1,3-DICHLOROPROPENE ND 1.000 UG/L VOMSAAX424 TRICHLOROETHENE ND 1.000 UG/L VOMSAAX424 TRICHLOROFLUOROMETHANE ND 2.000 OG/L VOMSAAX424 VINYL ACETATE ND 4.000 OG/L VOMSAAX424 VINYL CHLORIDE ND 2.000 UG/L VOMSAAX424 XYLENE(TOTAL) ND 2.000 UG/L VOMSAAX424 NA a Not Analyzed ND a Not Detected TER - Trip Blank F 931061 //h' Page: 11 INC • ENVIRONMENTAL MONITORING LABORATORIES, INC teCLIENT REPORT ;its: 488 — Central Weld County Sample Point: GWMW03 ENS: 92-11933 Sampled: 15-JUL-1992 Sanitary Landfill Sample Type: WELL MP: 488921 Received: 29-JUL-1992 Weld County Road 211/2 Sample Number: AF2924 REV: 00 Reported: 2-SEP-1992 Miliken CO 80543 Analyte Result .EML RL Units Comments Method FIELD DATA: DEPTH TO WATER FROM TOP OF CASING 24.98 FT FDWDTWTCO1 GROUNDWATER ELEV. 4789.84 FT MSL FDWGWELWDT PH FIELD 7.45 PH UNITS FDPHQUADO1 PH FIELD 7.45 PH UNITS FDPHQUADO1 PH FIELD 7.45 PH UNITS FDPHQUADO1 PH FIELD 7.44 PH UNITS FDPHQOAD01 SPECIFIC CONDUCTANCE FIELD 4730. UMHOS/CM FDSPCOND04 SPECIFIC CONDUCTANCE FIELD 4780. UMHOS/CM FDSPCOND04 SPECIFIC CONDUCTANCE FIELD 4750. UMHOS/CM FDSPCOND04 SPECIFIC CONDUCTANCE FIELD 4700. UMHOS/CM FDSPCOND04 WATER TEMPERATURE IN DEGREES CELSIUS 16.7 DEGREES C FDXTEMPC01 WELL DEPTH TOTAL 29.86 FT FDWGWELWDT NA a Not Analysed MD .0 Not Detected TBE - Trip Blank • • C P931961 of coto Ne `I January 1993 *i \*-thus * Central Weld Sanitary Landfill Colorado Questions and Answers Department of Health This question and answer fact sheet is the Colorado Department of Health (CDH) response to questions and concerns raised by the public over the Central Weld Sanitary Landfill (CWSL) northeast of Milliken in Weld County. Q. Is the landfill regulated? A. Yes. Even though the landfill received its Certificate of Designation in 1971 before many of the current solid waste regulations were on the books, the landfill must still comply with the minimum standards (Section 2) of Colorado's "Regulations Pertaining to Solid Waste Disposal and Facili- ties." In addition, the landfill will soon be governed by newly-revised solid waste regulations. In many cases, the proposed regulations are more restrictive than the current regulations. Q. Has the landfill contaminated ground water in the area? A. The owner/operator of the landfill has completed extensive investigations of the ground water over a large area. As a result of these investigations, CDH and Weld County were notified that there is minimal contamination of the ground water by volatile organic chemicals (VOCs) in four monitoring wells, two on the southeast edge and two on the southwest edge of the landfill. VOCs are solvents commonly found in paint and cleaning fluids. Both CDH and Weld County have For more information on the CWSL please contact: • Roger Doak, Geologist, Solid Waste Section,Hazardous Materials and Waste Manage- ment Division,Colorado Department of Health (303) 692-3437 •• Barbara Taylor,Environmental Engineer,Water Quality Control Section,Water Quality Control Division,Colorado Department of Health (303)692-3615. 931061 l,0-o rage c ✓ 1llbj /a 1 r „us- i k.-.4-A1 Sc iaE 4. WaSte Management of North Anr, ri , !nr. Motinhain Region �, J// 5660 Greenwood Plaza Blvd.•EngJev ood.Cole., cc aOl H t I- 1 Suite 42,•303/770-3324 ' ' -December 17, 1992 Mr. John Pickle Weld County Department of Health 1517 - 16 Avenue Court Greeley, CO 80631 - Mr. Glen Mallory Colorado Department of Health 4300 Cherry Creek Drive South Denver, CO 80222-1530 RE: Central Weld Sanitary Landfill (CWSL) Dear Mr. Pickle and Mr. Mallory: Waste Services Corporation (WSC) would like to meet with the Weld County Department of Health (WCDH) and the Colorado Department of Health (CDH) regarding WSC's suggestions for interim remedial measures to mitigate offsite groundwater contamination. Specifically, we would like to discuss the potential for placing air sparging wells upgradient of Groundwater Monitoring Well (GWMW) 5, which is located offsite at the southeast sand of the CWSL. The purpose of these wells would be to treat volatile organic compounds (VOCs) that were detected at low levels in a limited area around GWMW-5 and thereby provide a prompt and effective remedy to the identified presence of VOCs in the shallow groundwater in that area. In addition, WSC envisions installing a treatment device such as a shallow tray air stripper or a granular activated carbon treatment unit for the outfall of the underdrain located west of the CWSL. Either device would be used to remove low levels of VOCs detected in the outfall that drains to one of four manmade ponds referred to as the Spomer Lakes. BACKGROUND Prior to the July 1991 merger of WSC with Waste Management of Colorado, Inc. (WMC) , WSC conducted hydrogeologic and groundwater investigations at the site. These investigations include: * Warzyn Engineering Inc. , 1984, "Hydrogeologic Assessment, Greeley Landfill, Weld County, Colorado. " • f: CWSL 3.1 to\L&M\dec10.01\ehi 931061 /A3 Mr. John Pickle Mr. Glen Mallory Central Weld Sanitary Landfill Page 2 * Industrial Compliance, 1991, "Ground-Water Investigation, Waste Services Corporation, Central Weld Sanitary Landfill. " The Warzyn, 1984 , report was based on a field investigation program which consisted of installing five shallow groundwater monitoring wells (GWMW-1 through GWMW-5) , conducting in-site permeability tests, and groundwater/surface water quality sampling. The geology, hydrogeology, and water quality of the site were evaluated in this report. The Industrial Compliance, 1991, report characterized the site for the potential of leachate and methane generation. In addition, an evaluation of the conceptual design of a diversion ditch was presented. The field investigation involved the installation of several piezometers to observe groundwater elevations in and around the site. After the merger, WSC conducted an additional hydrogeologic characterization of CWSL which included: (1) installing ten new groundwater monitoring wells; (2) significantly increasing the number of groundwater constituents analyzed; and (3) expanding the number of sample locations to include the new groundwater monitoring wells, a culvert for upgradient surface water at the north end of the site, an outfall for the french drain at the east end of the site, and the outfall for the previously-mentioned landfill underdrain. The analytical results from the additional characterization has shown the presence of low levels of VOCs in certain shallow groundwater monitoring wells, including GWMW-5, at the downgradient (south) side of the site. Low levels of VOCs were also detected in the outfall of the landfill underdrain. The locations of all monitoring/sampling points are shown on Figure 1. This additional site characterization effort (including the analytical results) was presented to the WCDH and the CDH in a report entitled "Hydrogeologic and Geotechnical Characterization for the Central Weld Sanitary Landfill, Weld County, Colorado" dated July 1992. In addition, and based on this additional site characterization work, WSC supplemented its existing groundwater monitoring program by preparing the "Groundwater Monitoring Plan for Central Weld Sanitary Landfill, Weld County, Colorado" dated August 1992. This more extensive plan has been submitted to WCDH and CDH. i f: CWSL&M\d 3.1 t 9 1061/ / o\L6M\ ec10.01\ehi Mr. John Pickle Mr. Glen Mallory Central Weld Sanitary Landfill Page 3 Confirmation sampling conducted by WSC under its own initiative verified the presence of VOCs in the monitoring locations where VOCs had been initially detected. Based on this analytical data, an expanded investigation was conducted by wsc south of the site to characterize the lateral extent of VOCs in the shallow groundwater. This investigation showed low levels of VOCs in the area immediately adjacent to GWMW-5, about 25 feet south of the site near the southeast corner. No VOCs were detected at sampling locations 200 feet downgradient of the site. The results of this investigation were presented to WCDH and CDH in a report entitled "Expanded Hydrogeological Investigation at the Central Weld Sanitary Landfill, Colorado" , dated October 23 , 1992. SHALLOW GROUNDWATER REMEDIATION USING AIR SPARGING Air sparging is a physical/chemical remediation technique for removing dissolved contamination by introducing oxygen into the groundwater and converting the contamination compounds into the vapor phase. Air injection wells are typically installed into areas of contaminated groundwater, and positive pressure is applied to the wells. The air is diffused through the screened interval of the well into the formation groundwater. Air bubbles contacting dissolved/adsorbed phase contaminants cause the VOCs to volatilize. Air sparging essentially turns the saturated zone into an air stripper using the soil as packing. The air carrying the volatilized compounds migrates to the ground surface through natural mechanisms. A conceptual schematic of an air sparging system is provided in Figure 2. LANDFILL UNDERDRAIN REMEDIATION OF VOCs As previously indicated, two potential types of treatment for the landfill underdrain outfall are air stripping and granular activated carbon treatment. Shallow tray air strippers use air which is forced through baffled aeration trays to remove VOCs from water. The water to be treated is sprayed into an inlet chamber of the unit and flows along a baffled aeration tray . Air, blown up through small holes in the aeration tray, forms a froth of bubbles generating a large mass transfer surface area where the VOCs are volatilized. A conceptual illustration of a shallow tray air stripper is included as Figure 3 . Granular activated carbon treatment, or carbon adsorption, would use sealed single-use canisters packed with activated carbon. Carbon adsorption is a physical/chemical process that removes VOCs from an aqueous or vapor phase and bonds them to the surface of a solid phase medium (carbon) . A typical adsorption operation would f: CWSL 3.1 t to\L&M\dec10.01\ehi 931061 /4J Mr. John Pickle Mr. Glen Mallory Central Weld Sanitary Landfill Page 4 likely consist of two treatment canisters connected in series. Water to be treated would enter the canister inlet, flow through the carbon, and exit at the outlet. The internal pore structure of the activated carbon provides a large surface area for adsorption of VOCs. WSC filed a Colorado Discharge Permit System (CDPS) application for the landfill underdrain with the CDH Water Quality Control Division (WQCD) on November 25, 1992. Employment of either method for treating VOCs in the underdrain will be subject to WQCD's approval based on its review of the application. FUTURE REMEDIAL MEASURES WSC is currently performing quarterly sampling and analysis of the groundwater monitoring wells. After eight sampling events are completed- (2nd quarter, 1994) a statistical program will be developed to determine the potential impact of groundwater from the landfill. Development of this program is in response to requirements of Section 2 . 2 . 3 of the "Regulations Pertaining to Solid Waste Disposal Sites and Facilities" Title 30, Article 20, Part 1, Colorado Revised Statutes. The program will be modified as necessary to conform to any changes brought about by the State of Colorado's anticipated 1993 Subtitle D Program. Until a statistical program is in place and a permanent remedy is determined, the air sparging wells could serve as an interim remedy to address the presence of VOCs in offsite shallow groundwater. It must be recognized, however, that by proceeding with a remediation method (e.g. air sparging) prior to completion of the eight quarters of sampling, the remediation may affect the statistical data on which a long term remedy would' be based for GWMW-5 and GWMW-5N which is located onsite immediately north of GWMW-5. Whether the potential downside impacts on development of the statistical data base override the positive aspects of undertaking an interim remedy is an issue we would like to discuss with WCDH and CDH. Regardless of the approach ultimately decided upon, WSC wishes to reaffirm its commitment to employ appropriate measures necessary to mitigate and prevent adverse site-related environmental impacts. ft CWSL 3.1 F- is\L&M\dec10.01\ehi 931061 2 Mr. John Pickle Mr. Glen Mallory Central Weld Sanitary Landfill Page 5 Please contact Bill Hedberg at 330-2641 (Greeley) or Alan Scheere at 770-3324 (Englewood) should you have questions. We will call you in the next few days to request a meeting date convenient to your schedules. sincerely, -r%' Gl� (11411. fej ,e. Bill Hedberg Alan Scheere Division V.P. Landfill Operations Environmental Specialist Enclosures cc: Trevor Jiricek, WCDH Roger Doak, CDH Patricia Nelson, CDH, WQCD Barbara Taylor, CDH, WQCD Lee Morrison, Assistant County Attorney 6 9 fs CWSL 3.1 t3100o\LSM\dec10.01\ehi J 61 /� e. i, N 4 iJ l gi I i o r WO zzFO O w r 2 u.z. s o go i •°: jp1 G L r 3 . 'l• ill 30 ,�. - -ti _ �l- i go i Q e .....,_„_...- -7-e is""\,,, k.,. - t :1 c , ._ ict II . I / /.-- ---. i - - \ ..\ 3 s ii ..:, i 1 _ yam . -, _- t • s �a '\ 1 \-,, 1am \, ' � l• `• .. • .. •fr• _ �rS\ \ . \-v II \ 1 i o-- \ i\ 1 \ - . I 11 ; ~� • 61 6 / -j X N y ` CA weir,— I t:4-4v-, ,4,-c-----itez a g5 1 tot �`�0`" 4'; �-�"Vii' aro"fLMy�. .5),.-:----„,..- a.. 0 a 4 d Fstianb., qw::rir"'f(rr� yp 1 LL t aGaa'oa'bb ';'/ ''� /w t"0 g 0 g `YR .. art.0.'421,7, k- noo 1- 4.-..i,:4.-,<W,471 `��} fr, F 1 4-c"-Y.. '7 ter�-43-",.-1:41 ,7 In e ... )s a ` - J fry-fir CS SFzj -, IY� 'IAflF 44,4 g44,..L.,,,-...,,Z41:44`./..44' ` d CZ bf w�w � � -71,4-44- k-h,-, cr- iri low a'b� -C• ." c�f�`jp, Ij, - -wa c$. i;;;• 9"'Petr,- •:`,ii.i.,-.1-&-:.--:5; R -t--- ..6--A--k?,,., 1 i Fy n r:, 1 w }�t�/ �.�;ra,^ Y, y4 8 F 1 ,;5.... vFJ�y4fra L w�` hY:r. tr ig jUcci@ d 00 ificag Y. 4 931061 ,p_9 ` Conceptua nitration of a Shallow Tray Air Stripper As- mat`' AN.aESSU1E GAGE AIR PRESSURE SWATCH f - AIR EXHAUST SAMPLE PORT . TOSERATIIM GAGE FLOW MITER _ • 1 [ a•nae GANI 1, •EMTEIH `,7n ;J -000 mos mow TR•. i • CLE4VWT PORTS[ _ ♦EMTIGH I 6'J' Twr 11 HARMED t - Alm r EISPECTEIH PORT L �s SW ro, -IR • WATER-LEVEL AA EIT4TE { I YS I SIGHT TUN ► .f•. • TMAD .RESSU Pawl PORT 0 _ � HIGH LEVEE ALPS { . TEMPERATURE GAGE RMT SWITCH ' FLOW CONTROL VALVE Z E, i aIITIET FLED FLOAT SWITCH ■� L DAMN Put OVnVE sop MOURT=ARE • E RROHT -. .'l. RIGHT Sax VIEW tanim /� lilt �. .. • i I. I I•IJ Y S. r X TOP VIDV • $ i Vote: This figure is in' J•: • to generally illustrate the system configuration. The actual system ired may vary based on project specifications. . Fiaure 3 --. r 931061 /30 ° Hd - Waste Services Corporation A 6037 77th Avenue _ ___• A Waste Management Company Greeley, Colorado 80634 ��`./'y_/IEF 303/330-2641 January 18, 1993 Colorado Department of Health APCD-SS-B1 4300 Cherry Creek Drive South Denver CO 80222-1530 RE: AIR POLLUTION EMISSION NOTICE (APEN) FOR CENTRAL WELD SANITARY LANDFILL (CWSL) Dear Sir/Madam: Enclosed is the Air Pollution Emission Notice (APEN) for CWSL. Also enclosed is an estimate of fugitive particulate emissions generated by CWSL. Please contact Bill Hedberg at 654-1133 or Alan Scheere at 770-3324 if you have questions in this matter. Sincerely, () : —C/ Bill Hedberg Alan Scheere Division V.P. Landfill Operations Environmental Specialist AS/mmp • Enclosure • cc: John Pickle, WCHD Jeff Stohle, WCHD • REC R JAN 2 0 1993 W931Vc\011493t2.cdb F:CWSL 1.4 ',iif POWWOW (IOi1a)L litUNAIir S0i176ES PRii 931061 /3/ Letter Colorado Department of Health January 18, 1993 Page 2 bcc: Tom Buchholz Len Butler Tom Schweitzer • wpSIW1011493L2.cd p:CWSL IA F931061 , EMISSIONS FACTOR Emissions Factor (EF) _ ( SV) ( 365-W) N/4 60 365 Given at CWSL V = Average vehicle speed = 10 mph N = Number of wheels = 6 W = Mean annual number of days with .01 inches or more rainfall = 80 days S = Silt Content (unknown) assume 15% Y = Vehicle miles traveled per day 80 vehicles average per day x approximately .5 miles of unpaved haul road from the gate house to the active disposal area = 80 (2 x .5) = 80 EF = 15x10 x 365-80 x 6 = 2 .931b/vmt (vehicle miles traveled per day) 60 365 4 Emissions = . 3 (EF) x Y x 365/yr. = tons/year 2000 lb per ton • • E _ . 3 (2 .92) (80) 365 = 12 . 8 tons/year 2000 CWSL generates approximately 12 . 8 tons/year of particulates RECE!V rp31WW11493L].ca P:CwSL i.1 JAN 2 0 19.93 k POLLUTIONS CONTROL t1lONARY SOURCES PIV 931061 /33 5.4 ^ in 2 Z 01 C 'EV 1 < I 'a Zo O O NK ro_ u ^ a I j 16 d < ea v Z t A .I = I z f rX en F UtO i _ I `o ^ ( i c mZO r tT 2 W `o r •a u 3a .Wil .o C O cc o x 2 c s c.+ .j = � a d iY f ' � & < 1 ry U. ...I ix o U in lu I a f1 W p( 2• . 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S I ++ `o € 1O Z O r c4p( Z Z IC al < �2 I J °14 a � o e -I Eof - _ x L Z J O W O a i en t O c u Z oc 'C Z 1 4 Zd G O a oC Z < Z. m x LL x — '� f s• 2 '. c O U 2 Q. al 16 /3V IN THE UNITED STATES DISTRICT COURT 2 FOR THE DISTRICT OF COLORADO 3 FEDERAL DEPOSIT INSURANCE CORPORATION, ) 4 ) Plaintiff ) 5 ) vs. ) 89-M-880 6 ) 89-M-1241 BOARD OF COUNTY COMMISSIONERS OF ) 7 ARAPAHOE COUNTY, et al. , ) ) 8 Defendants. ) 9 ORAL ARGUMENTS - DISPOSITIVE MOTIONS 10 TRANSCRIPT OF PROCEEDINGS 11 Proceedings held before the HONORABLE RICHARD P. 12 MATSCH, U. S. District Judge, for the District of' Colorado, 13 beginning at 10: 20 a.m. on the 22nd day of December, 1989 , in 14 Courtroom A, United States Courthouse, Denver, Colorado. 15 APPEARANCES 16 For the Plaintiff: James Merrill, Esq. 17 20 Boulder Crescent Colorado Springs, CO 80903 18 Albert Maule, Esq. i9 Christopher Zibart, Esq. Three First National Plaza 20 Chicago, Illinois 60602 21 For the City & County of Denver: Kevin Ward, Esq. 22 1700 Lincoln St. , #3500 Denver, Colorado 80203 23 For Arapahoe County: Edward Caswell, Esq. 24 5334 S. Prince St. Littleton, Colorado 80166 25 Proceedings recorded by electronic sound recording, transcript produced by transcription service. 931061 351I, 2 1 APPEARANCES: (Continued) 2 For Waste Management of Colorado: David Bellack, Esq. 3 Eugene Megyesy, Jr. , Esq. 707 - 17th Street, Suite 3500 4 Denver, Colorado 80202 5 For the State of Colorado Department of Health: David Kopel, Esq. 6 1525 Sherman Street, 3rd Floor Denver, Colorado 80203 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 931061 /3 3 1II PROCEEDINGS 2I (At 10 : 20 a.m. on December 22 , 1989 , in the United States 3i District Court at Denver, Colorado, before the HONORABLE 4 ' RICHARD P. MATSCH, U. S. District Judge, with Mr. James Mer- 5 rill, Mr. Albert Maule and Mr. Christopher Zibart appearing as 6 , counsel for the plaintiff and Mr. Kevin Ward, Mr. Edward 7 Caswell, Mr. David Bellack, Mr. Eugene Megyesy and Mr. David e Kopel appearing as counsel for the defendants, the following 9 proceedings were had: ) 10 THE COURT: Be seated, please. 11 This is consolidated civil actions 89-M-880 , 89-M- 12 1241. The Federal Deposit Insurance Corporation as manager of 13 the Resolution Trust Company brought these actions against the 14 Board of County Commissioners of Arapahoe County, City and is County of Denver and Colorado Waste Management and Colorado 16 Department of Health, and there are motions for summary 17 judgment filed by everybody. 18 State your appearances. 19 MR. MERRILL: James L. Merrill for the plaintiff, Your 20 Honor. 21 THE COURT: All right. 22 MR. WARD: Good morning, Your Honor. Kevin Ward of 23 Cogswell & Eggleston appearing on behalf of the City and 24 County of Denver. 25 THE COURT: Denver. 931061 /3 7 4 1 MR. CASWELL: Edward M. Caswell, Assistant County Attor- 2 ney representing the Arapahoe County Board of Commissioners . 3I THE COURT: Okay. si MR. MEGYESY: Eugene Megyesy with David Bellack, repre- 5I senting Waste Management of Colorado. 6 THE COURT: It ' s Waste Management of Colorado, not 7 Colorado Waste Management. Okay. sl MR. MEGYESY: That is correct, Your Honor. g MR. KOPEL: David Kopel, Assistant Attorney General , 10 representing the Colorado Department of Health. I THE COURT: All right. I 'm sorry we 're delayed in 12 starting. The criminal matters took longer than we 'd sche- 13 duled, but I 'm going to take the approach here of telling you 14 what I think and then giving you an opportunity to address 15 your arguments in view of that, but I--the briefing has been 161 extensive and good. I 've read those briefs, the exhibits, the 17 Colorado Solid Waste Disposal Sites and Facilities statute at 18 30-20-101 and following. I have reviewed the administrative 19 record. That isn't to say that I 've read every page of all of ', 20 these volumes, but I 've reviewed the--what I consider to be 21 the most pertinent parts, using the index that was provided 22 conveniently. I've also read the Colorado Supreme Court 23 opinion in City and County of Denver against Eggert again. 24 That's 645 P. 2d 216, and I went back and read the Colorado 25 1971 session laws, Chapter 103, which was Senate Bill No. 132 , 931061 /.3.r which amended the Solid Waste Disposal Act. 2I And having done these things, this is what I think 31 about the dispute; that the plaintiff ' s motion in 89-M-880, 4j the plaintiff seeks declaratory relief and judicial review of 5 Arapahoe County' s decision not to hold a public hearing on the 6 landfill operations to take place in Section 31, I guess the 7 west half. 8 Incidentally, aren' t there other operations in 9 Section 31, too, that have already--the Hazardous Waste io Disposal part is in 31 already, isn' t it? 11 MR. MEGYESY: That is correct. There were other disposal 12 ' activities in 31, including some brine ponds and some sludge 13 disposal. 14 THE COURT: Yeah, which was the subject of another t5 lawsuit that was settled. 16 MR. MEGYESY: That' s correct. 17 THE COURT: Okay. So I think we're in the western half 18 principally here for this, and hazardous waste is not involved 19 in the present matters as I understand it. So--but at any 20 rate, we' ll just talk about Section 31 as the parties have. 21 And in 89-M-1241, with the Colorado Department of 22 Health as the only defendant, the plaintiff seeks reversal and , 23 remand of its Colorado Department of Health agency action 24 reflected in its letter recommending approval by Arapahoe 25 County of construction and operation of landfill in 31 , 931061 7-59 6 1 Section 31. 2 while the cases were consolidated, there are two 3 separate issues as identified in the briefing. Separate 4 briefs were filed, and they are clearly questions of law that 5 can be resolved in summary judgment, it appears to me, and 6 both the disputes require a careful analysis of both statutory 7 and regulatory control of solid waste disposal sites in 8 Colorado. 9 The statute now is codified in the 30-20-101 through 10 118 . The basic structure of this statute is that it ' s unlaw- ful to operate a solid waste disposal site and facility in any 121 incorporated portion of any county in Colorado without first 13 obtaining a certificate of designation from the board of 14 county commissioners of that county. 15 30-20-123 governs the process for an application for 18 such a certificate. Apparently that was formerly 36-23-3 , 17 which was substantially amended by this Senate Bill 132 in the 18 1971 session laws. That amendment required that the applica- 19 tion contain such engineering, geological, hydrological and 20 operational data as may be required by. the Department of 21 Health by regulations, and the application is to be referred 22 to the department for review as to approval or disapproval on 23 criteria established by the State Board of Health, the State 24 water Pollution Control Commission, and the Air Pollution 25 Control Commission. 931061 /c/c The same bill amended the factors to be considered 2 section, which is now 30-20-104 , to add the requirement that 3 before issuing a certificate of designation, the Board must 4 require--the Board of County Commissioners must require 5 approval of the Health Department and, among other things , 6 that the application and the department ' s report be presented 7 to the Board of County Commissioners at a public hearing to be e held after a prescribed form of notice that requires notice of 9 the time and place of the hearing, the matter to be consi- 0 dered. Notice has to be published in a newspaper. That ' s in i now 30-20-104 (3) . 12 • The Colorado Department of Health has had the 13 authority to promulgate rules and regulations all along. That 14 authority is now at 30-20-109 and the regulations have to meet 15 the legislature's minimum standards in 30-20-110. 16 I noted, too, that the Senate Bill in 1971 added to 17 the county's revocation authority, which is now at 30-20-112 , l 18 the addition being that the failure of a site and facility to 19 comply with all applicable laws, resolutions and ordinances, 20 as well as the failure to comply with the provisions of the 21 statute or any rule or regulation adopted. 22 The Supreme Court in the City and County of Denver 23 v. Eggert established the law of this case as the law of this 24 case that the certificate of designation issued by Arapahoe 25 County to the City and County of Denver on September the 16th 931061 P7// 3 11 of 1968 covers the entire Lowry Landfill that was transferred 2 to the City and County of Denver, including Section 31 . It is 3 also the law of the case that the City and County of Denver 4 , can operate through a contractor without obtaining a new certificate under the Solid Wastes Act and, as I 've said, it ' s 6 my understanding that the Hazardous Waste Act is not involved 7 in the present disputes. 8 The requirement for a public hearing that the 9 plaintiff asserts in this case, then, depends entirely on the io construction of the Colorado Department of Health regulations. n Those are in 6 CCR 1007-2 . Regulation 1 . 3 . 7 reads: "An 12 amended application shall be made for a substantial change in 13 operations as defined in Section 1. 2 of these regulations and 14 shall be referred to the County Board of Commissioners and the 15 Department for review and approval before such change shall 16 become effective. " 17 Section 1.2 . 72 defines substantial change, that 16 "Substantial change in operations means any redesign or 19 planned construction which would significantly change the 20 planned design performance of a facility for solid waste 21 disposal as originally designated, the addition of a category 22 of wastes or other waste handling processes that have not been ! 23 previously reviewed and accepted as complying with these 24 regulations, or the selling or transferring of the certificate 25 of designation to a new operator. " II 931061 14:; 9 it The plaintiff concedes here that there is nothing in 2 the statute which provides for an amended certificate of 3j designation. The defendants, other than the Colorado Depart- 4I ment of Health, have asked this Court to declare the CDH 5 regulation as invalid and unauthorized. I don't think that 6 it ' s necessary to do that to resolve this case, this par- 7 ticular dispute. I think that the regulation about an amended , a certificate of designation on--requiring it on a substantial 9 change in operation can be harmonized with the statute by 10 simply relating this to the enforcement authority of the--and m monitoring of an enforcement authority of CDH and the County 12 Commissioners, leading to a suspension or revocation under the , 13 statutory authority to do so. 14 The Supreme Court, in the Eaaert case said: "If they! 15 commissioners wish to review or halt--" , then it was Colorado 16 Disposal's, "--landfill operation or Metro ' s sewage sludge 17 operation, they must do so in the context of a revocation or 18 suspension hearing under Section 30-20-112 or an injunctive 19 proceeding in a district court of competent jurisdiction under 20 30-20-113." 21 Now, the requirement by regulation for an amended 22 application can be valid if it's considered to simply require 23 an operator or an owner to call to the attention of the 24 Colorado Department of Health and the county any changes in 25 operations which might result or cause an enforcement action P 9;1061 //3 :0 1 to be considered. There is no statutory authority for a 2 public hearing in acting on an application for an amended 3 certificate. The statute requires on a public notice, public 4 hearing, requires that for a new certificate of designation 5 and the applicable regulation, 5 . 1. 3 , which also requires a 6 public hearing simply tracks the language of the statute and, 7 again, requires a hearing for--by the County Commissioners of 8 a new application for a certificate of designation. 9 The plaintiff--well, actually, the Colorado Depart- 10 ment of Health apparently has acted in making the recommenda- 11 tion to the County Commissioners in Arapahoe County with the 12 'expectation that Arapahoe County would hold a public hearing 13 in the same manner as if it were a new application. The 14 County Commissioners, of course, first--their response to that 15 was that they don't need to hold a public hearing and they 16 have not taken action to actually issue an amended certifi- i 17 cate. 18 Now, my view of the case, then, is that there is no 19 valid requirement that an amended certificate itself be 20 issued; that I find nothing wrong with the Colorado Department 21 of Health's regulation to be interpreted as I have, which 22 would require Waste Management of Colorado and Denver, or on 23 behalf of Denver to let the Colorado Department of Health know 24 that it was going to conduct these operations in Section 31 25 and open that additional part of the Lowry Landfill to solid 931061 /`/ / ' 11 waste disposal activities. But as I say, to my mind, and what 2 the Colorado Department of Health ought to do is rewrite their 3 regulation, it seems to me, to require that that kind of 4 submission be made so that the Colorado Department of Health 5 can exercise its monitoring obligation and as a part of that 6 monitoring obligation, advise the County if anything ' s going 7 on that warrants the County' s taking a look at enforcement 6 here, and the view that I take, then, is that Arapahoe County 9 doesn't have to hold a public hearing in this situation and, io secondly, that the Colorado Department of Health' s action in 11 making the recommendation that it did is really not reviewable 12 agency action because all it amounts to is a recommendation 13 that the County not proceed with any enforcement action or 14 require the operators out there, the City and County of 15 Denver, to do anything different from what they're doing under 16 the plan that was submitted to the Colorado Department of 17 Health, and which the Colorado Department of Health reviewed. 18 I 'd say further, though, that even if I were review- 19 ing that letter from Colorado Department of Health to Arapahoe 20 County Commissioners as final agency action on the basis of a 21 new application, I would not agree with the plaintiff ' s 22 characterization that it was arbitrary, capricious, or con- 23 trary to law. The plaintiff makes much of the requirement 24 that Waste Management of Colorado provide further information 25 as saying then the plaintiff ' s argument is that that shows in 931061 / 5 12 and of itself that they didn 't--that CDH didn' t have an 2 adequate record. 31 It' s been argued by the defendants, and it persuades 4 me, that all that amounts to is to--for CDH to be requiring 51 that it be kept informed, and that the necessary monitoring-- 6 its necessary monitoring functions can be performed by having 7 the additional information submitted, so I 'm prepared to 8 dismiss both cases. 9 Before doing so, I ought to give an additional due io process of an opportunity for plaintiff ' s counsel to say why n it is that I shouldn't rule as I 've just said I intend to. 12 • Mr. Merrill? And, you know, what I 'm really saying 13 to you is I think that you all did an excellent job of sub- 14 mitting this by brief and summary judgment motion, and that 15 gave me the opportunity to study this carefully. I think the ie only thing that--I just want to make sure that I haven' t 17 overlooked something that was submitted and, of course, I did is add myself the--going back and looking at the sessions law to 19 see--because I got curious about the history of the require- 20 manta in this solid waste disposal statute, so I was curious 21 about what happened in 1971 to change things. 22 Okay, Mr. Merrill. You can come forward here to be 23 more comfortable. 24 MR. MERRILL: Thank you, Your Honor. 25 THE COURT: If you can be comfortable in a position where 9 061 At I _ I .3 it I 'm telling you why I shouldn 't sentence you to dismissal . 21I MR. MERRILL: Your Honor, I ' ll be as comfortable and as 3 ! candid as I can. We obviously appreciate your compliments-- I 'm sure that all parties do--with respect to the quality of 51 the briefing. A great deal of effort did go into that. g I think that rather than reiterate the points that 7 we have made in the briefs, because I think we have essential- ' 8 ly set forth the gist of the arguments from all parties , I 9 would address simply one issue, and that ' s the Court' s view 10 that the substantial change language of the Colorado Depart- ii ment of Health regulations which the Court is apparently not 12 inclined to find invalid as some of the defendants have 13 requested-- 14 THE COURT: Right. 15 MR. MERRILL: --we do not understand or fully appreciate 16 the Court' s tying that provision to the enforcement and 17 monitoring portions of both the Health Department regulations 18 and the Act itself. We obviously studied it carefully in 19 terms of preparing to brief the case to you, and that linkage 20 simply did not occur to us. It seems fairly plain on the face 2� of the regulations at least that a substantial change does, in 22 fact,, require the issuance of an amended certificate of 23 designation and that the Health Department' s June 21st letter 24 to the County clearly contemplated that that would be done. 25 THE COURT: I ought to emphasize--and I thought I 931061 14 1 referred to it--that the statute doesn' t provide for an 2 amended certificate of designation, and I 'm saying that none 3I is required here. So to the extent that the regulation and 4 ' the communication from the Colorado Department of Health says 5 you must issue an amended certificate of designation, it is 5 invalid. 7 MR. MERRILL: Okay. 8 THE COURT: So I strike the requirement for amended 9 certificate of designation. and I guess what I 'm saying to the io Colorado Department of Health is, as I said, they should n rewrite that to say if you're going to make these changes, 12 tell us about it. 13 MR. MERRILL: Okay. The difficulty I 'm having, Your 14 Honor, is that the certificate of designation which is issued 15 by the Board of County Commissioners constitutes, in my 16 understanding at least, the permit, if you will, to operate 17 the landfill. It incorporates the blessings of the Health is Department from a technical point of view, and it also has 19 embodied in it essentially the aspects of a special use 20 permit, for lack of a better analogy, in land use law. And it 21 seems to me that what we have here is a new operation com- 22 mencing on Section 31. The Health Department has reviewed 23 this particular application, obviously with the intent in 24 their minds that their recommendation, if affirmative, would 25 be embodied by the County Commissioners into an amended F 931061 /'a 15 1 certificate of designation, perhaps with additional restric- 2 tions or provisions such as the ones that the Health Depart- 3 ment suggested, the inclusion of financial assurances for 4 closure and post-closure costs, and other things. And if no 5 amended certificate is issued, I 'm wondering how do we tie the 6 Section 31 operations into an enforceable document such as an 7 amended certificate of designation? In other words, I can ' t 8 make the nexus between how this is going to be enforced if we 9 don't have an amended certificate of designation that carries • 10 out the Health Department ' s provisions and restrictions in n that June letter, and says, "This is the way you have to 12 operate that landfill, " so that there' s a backdrop, if you iu will, against which the enforcement and monitoring authority 14 at the landfill can be carried out. 15 THE COURT: Well, the enforcement is as the Supreme Court ; 16 said it in City and County of Denver v. Eaaert. If Waste 17 Management in Denver aren't proceeding in accordance with is their plan that was submitted to the Colorado Department of 19 Health and has been approved by the Colorado Department of 20 Health by its letter, as I understand it, then it seems to me 21 that the Colorado--that the Commissioners of Arapahoe County 22 should proceed with a revocation or suspension hearing, after 23 notice, under 30-20-112. 24 MR. MERRILL: Okay. 25 THE COURT: And your argument would have carried a lot of 9 2,1061 V`�' 16 , I different weight with me had it not been for the language of 2 the Supreme Court of Colorado in the E4aert case, because I 3I read it very carefully. It governs this tract of land. It 4 governs the parties, and it said very clearly to me that when 5I Arapahoe County used that cease and desist order without going 6 through the public-- 7 MR. MERRILL: Hearing process. 8 THE COURT: No due process, really. 9 MR. MERRILL: Yeah. 10 THE COURT: They were acting improperly, but the County was doing at that time, was, you know, had its concern about 12 what Denver was doing. Of course, that also involved hazar- dous waste, which made it a more complicated case than this 14 one. 15 MR. MERRILL: That' s true. 16 THE COURT: But my view of it is that the statute hasn' t 17 been changed since the Supreme Court of Colorado dealt with 18 it. 19 MR. MERRILL: That's right. 20 THE COURT: And my view of it is that Denver has a vested 21 certificate of designation. They can use it for all 2 , 000- 22 whatever acres they've got out there and can carry on a 23 landfill there subject to the power of the County to stop them 24 under a revocation or suspension proceeding, and Colorado 25 Department of Health has the monitoring obligation. r 9310611Y9 17 Now, your arguments, as I said, would carry great 2 weight without the Supreme Court of Colorado, but I look to 3 that, of course, as the authority in dealing with Colorado 4 law, as clearly it is. 5 MR. MERRILL: I 'm certain they are more persuasive than I 6 am, Your Honor. I think that there-- 7 THE COURT: Well, they may not be more persuasive, but 8 they' re more compelling. 9 MR. MERRILL: We' re still confronted, I think, with a 10 pair interrelated problems. One is that in framing their 11 recommendation for approval here, I don 't think that the 12 Health Department intended that their June 21st letter would 13 serve as the permit, the blessing to go forward with these 14 operations. They clearly expected that someone else would 15 grab the baton and carry it on over the line and that there 16 would be this process. 17 THE COURT: I agree. 18 MR. MERRILL: And the other sort of related aspect to it, 19 if I could, is that the documents on file with the Health 20 Department are not intended or well-suited to be a backdrop 21 for enforcement. There is lots and lots of technical material 22 there, and for someone to try to come in and even say, "You're 23 not operating this landfill in accordance with the documents 24 on file, " is going to require quite a bit of searching through 25 a lot of detailed, technical information, and it seems to me F 931061 /5o 13 that from the enforcement perspective, the regulatory perspec- 2 tive of the Health Department and anyone else whose interests 3I are intended to be protected by this statutory scheme, that a ' you really need some sort of permit, some sort of embodiment, 5 much like the original certificate of designation, that says: 6 "Here 's what you can do. Here are the restrictions on it and 7 here ' s what happens if you don't do it, " so that you have a 6 ticket, if you will, something that' s not volumes and volumes 9 of information out there against which people can evaluate and io judge and monitor the performance of these operations. n THE COURT: I understand what you' re saying. I think, 12 though, that that argument should be addressed to the body 13 that convenes over there under the gold dome next month. 14 MR. MERRILL: Well, perhaps we' ll have to do that, Your 15 Honor. 16 Your Honor, could I have just a moment to check with . 17 my co-counsel to see if there are any points they ' d like to 18 make? 19. THE COURT: Yes, sure. 20 MR. MERRILL: Thank you. 21 THE COURT: Certainly. 22 (Pause. ) 23 MR. MERRILL: Your Honor, in light of the anticipated 24 rulings, I 'd like to just ask one other point of clarifica- 25 tion, if I could. 93106I /5/ it 19 1 THE COURT: Sure. 2 MR. MERRILL: As you know, my client's concerns with 3 respect to the new landfill operation on Section 31 stem 4 largely from the threat of groundwater contamination of its 5 property and there is already technical information out there 6 -you 've seen it in the record--with respect to the contamina- 7 tion in Section 31 and the potential for off-site migration to 6 the property which my client is trying to manage. And I g suppose my question, if that ' s the way to phrase it, is if we 10 have concerns or we develop information, for example, showing that the landfill operations or some other operations on Lowry ! 12 are contaminating the property off-site--Section 30, for 13 example--is it correct to assume that under your ruling the 14 place we should go with that is to the Arapahoe County Commis- 15 sioners in the context of this monitoring enforcement that you 16 discussed earlier? 17 THE COURT: Because I think they have the enforcement 16 authority. Now, you may want to go to the Colorado Department 1, 19 of Health to enlist their aid to support your assertions. 20 MR. MERRILL: Okay. 21 THE COURT: But my view of the law is that the appro- 22 priate governmental authority to be exercised is that which is 23 possessed by the Board of County Commissioners in Arapahoe 24 County. 25 MR. MERRILL: Okay. F 921061 __' 20 1 THE COURT: Now, I don 't--I'm not excluding the law of 2I nuisance. I don't know, you know, what the common law of 3 nuisance is and whether in Colorado, as it might relate here 4i or, for that matter, the law of trespass. I 'm not inviting 5i you to exercise your avenue to this Court because of your 6 liquidating authority here to explore that. 7 MR. MERRILL: I understand, Your Honor, and I believe 8 there are other authorities. s THE COURT: But in governmental terms, it belongs with 10 Arapahoe County, as I see it. ii MR. MERRILL: So you see the Arapahoe County Commis- 12 sioners, as I understand it, as sort of the front line enfor- 13 cement authority with respect to this landfill in their 14 county? 15 THE COURT: Yes. 16 MR. MERRILL: I believe that's all I have, Your Honor. 17 Thank you very much. 18 THE COURT: Okay. I invite comment from--or argument 19 from any of the defendants, including the Colorado Department 20 of Health. I have changed, I think, the Colorado Department 21 of Health's letter by my ruling, but the Colorado Department 22 of Health was quite silent in the briefing with respect to the 23 matter of its regulation. 24 MR. KOPEL: Your Honor, the Department recognizes that 25 the procedures in its regulations regarding amended 91.063 /5J 21 1 ! certificates of designation did not provide sufficient clarity .. 21 in all situations, and this being one of them, and the Depart- ! 31 ment of Health will likely be revising its regulations, taking 4 into account your ruling. 5I THE COURT: Good. All right. I 'd like to go with this, 5 you know. I could write an opinion, too, but I think it ' s 7 important that this be done and done so that if you choose to a appeal, you do that, given my recollection that February is 9 the time that there may be dumping--I shouldn ' t say dumping ,o activities--disposal activities on the site, so what I would i I i simply like to do is incorporate these--I think my position is 12 on this record, right or wrong, and I may be a bit more 13 eloquent if I had time, but all I need to do is tell you the 14 basis for the ruling and the Court of Appeals and direct the is clerk to enter judgments of dismissal, so that' s what I intend to to do. And of course, your appeal time starts to run when 17 those judgments get entered. That may or may not be today. 18 We've got a lot of other things on our plate. 19 Okay. Again, you know, it's a little unusual to 20 have a hearing like this set up with all these motions and all 21 the counsel come, and then I rule before you argue. But, 22 believe me, I 've given careful consideration to what you've 23 briefed and because you've done it as well as you all have, I 24 was able to do it that way and we have, if not correctly, at 25 least efficiently decided. / 931081 `{ 22 1 Court ' s in recess. 2 (Whereupon, the hearing was concluded. ) 3 4 I certify that the foregoing is a correct transcript ', 5 from the record of proceeding in th abov entitled matter. 6 January 1, 1990 �l/akk, , K 7 J. Ford & Associates, Inc. 991 Ursula Street 8 Aurora, Colorado 80011 (303) 364-5776 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 F 921061 /.5-2 6-ssi Iff\\ DEPARTMENT OF HEALTH I HEALTH 1517 - 16 AVENUE COURT GRE ELEY,EELEY, COLORADO 80631 OADMINISTRATION PROTECTION (303)353-0586 WI P PROTECTION (303) 353-0635 COMMUNITY HEALTH (303)353.0639 COLORADO September 2, 1992 Alan Scheere Regional Compliance Coordinator Waste Management of North America, Inc. Mountain Region 5660 Greenwood Plaza Boulevard Suite 400 Englewood, Colorado 80111. Dear Alan, This Department is in concurrence with you that since construction and operation of Central Weld County Sanitary Landfill commenced prior to February 1, 1972, an Emission Permit was not required. Provisions of Regulation No. 3, Section I.A. places the original disposal site in the grandfathered category. However, an Air Pollution Emission Notice is required. Should you have any further questions, please give me a call at 353-0635. Sincerely, fetel of rey L. Stoll, Supervisor Environmental Protection Services JLS\jg-1814 92,1061 /5 ry,, ROY ROMER Tekfax Nawbeet s Main Building, Denver �7 '�'�^- Governor (303)322-9076 PATRICIA A. NOLAN, Mn, MPH (303Ptar)3 0-gan Place, Denver (303)320-1529 Executive Director Pint National Bank Building, Denver (303)355-6559 Hazardous Materials and Waste Management Dlvbion Grand Junction Office --. • 1 4210 East 11th Avenue (303)248-7198 COLORADO ORADO Denver, Colorado 80220-3716 Pueblo Office �..�la.ti (303) 331-4830/FAX (303) 331-4401 (719)543-8441 • DEPARTMENT OFAHEALTH September 18, 1992 Kent E. Hanson Attorney at Law Clayton Center 1881 9th Street, Suite 216 Boulder, Colorado 80802 RE: Central Weld County Landfill Weld County Dear Mr. Hanson: The Hazardous Materials and Waste Management Division (the Division) of the Colorado Department of Health has received and reviewed your September 11, 1992 letter regarding the Central Weld County Landfill. The following is the Division's response to the issues set forth in your letter. 1. Weld County is has no obligation under the Solid Waste Disposal Sites and Facilities Act (the Statute) to hold a public hearing for substantial changes in operations, though Weld County may if they so choose. A Certificate of Designation is issued for a specific solid waste land use (i.e. incinerator, sanitaryQandfill, or impoundment), and in this case the land use is a landfill. As long as the facility is a landfill and continues to operate as such, no public hearing is required. To date, the Division has no evidence to suggest that any other solid waste operation, beside landfilling, is occurring at the site. This same issue was the subject of a law suit between FSLIC vs the City and County of Denver, the Board of County Commissioners of Arapahoe County, Waste Management of Colorado and the Colorado Department of Health (1989). If you are interested in reviewing this document, please contact the Division to make an appointment for file access. The Division does, however, concur that any redesign or planned construction which would significantly change the planned design performance of a facility is subject to Division technical review. Following a recommendation for 931061 /5� Kent Hanson, Attorney at Law Central Weld County Landfill September 18, 1992 Page 2 of 3 approval of the plan, the application shall be amended. The regulation does not state that the Certificate of Designation shall be amended. The County must utilize its own discretion or regulation as to whether an amended Certificate of Designation is required for facilities which amend their application, but continue to perform the same type of solid waste disposal. 2. The Central Weld County Landfill received a Certificate of Designation on October 6, 1971. At that time, the state had not promulgated solid waste regulations pursuant to the Statute. Between 1968 (the date the Statute became effective) and 1972, solid waste disposal sites and facilities complied with the minimum standards set forth in the Statute. The minimum standards detailed operational standards, but did not specifically require a design and 'operations plan. In 1972 regulations were promulgated pursuant to the Statute. That 1972 regulation set forth the requirement that all landfills with an existing Certificate of Designation were 'grandfathered,' that is they were required to meet the minimum standards of section 3, but not the standards of section 4 (which applied to all solid waste disposal sites and facilities that were designated after the effective date of the regulation). In 1983, when the regulations were revised to their current form. The Division concurs, and certainly Subtitle D will require, that the Central Weld County Landfill must develop an enhanced design and operations plan to bring the facility up to current standards. To the Division's knowledge, no design or operations plan has ever been developed for the landfill, nor are any plans of this nature contained in the Division files. 3. It is true, that ground water contamination has been identified off-site. The County has wisely chosen to allow the facility to take over the ground water monitoring activities at the landfill. The Central Weld County Landfill has expanded the list of ground water analytes, and through this effort has revealed the presence of volatile organics in the ground water. Golder Associates has recently submitted a hyrogeologic and geotechnical characterization report detailing and summarizing recent investigations. The Division is in the process of reviewing the report, and will work with Weld County and Waste Services Corporation to obtain a satisfactory resolution to the ground water contamination issue. 4. Waste Services Corporation does intend to submit (and is currently in process 931061 /53 Kent Hanson, Attorney at Law Central Weld County Landfill September 18, 1992 Page 3 of 3 of developing) a comprehensive site development plan, and a design and operations plans. The Division has not been informed of any pending change in operations at the Central Weld County Landfill during this interim period. 5. The Division is not aware of any existing requirement or agreement that the final elevation of the landfill may not exceed the adjacent land surface. Hopefully, this letter responds to your issues. The Division is interested in pursuing, and will pursue the ground water contamination identified at the site, and in bringing the facility up to the State's standards. Thank-you for your letter and for the extension you were able to grant, so that an adequate response could be prepared. may be contacted at this office if you have any additional questions or concerns. Si erely t Aus ' N. Buckingham \ Geologist Hazardous Materials and Waste Management Division cc: B. Hedberg, Central Weld County Landfill B. Keirnes, Waste Services Corporation G. Kennedy, Weld County Commissioners L. Morrison, Weld County Attorney D. O'Sadnick, Golder Associates J. Pickle, Weld County Health Department A. Scheere, Waste Management of North America K. Schuett, Weld County Department of Planning file: SW/WLD/CENTRAL 9431061 /159 Waste Services Corporation 6037 77th Avenue Greeley, Colorado 80634 - � "TY A Waste Managem"^* Company 303/330.2641 r5 CI February 5, 1993 T i Mr. Roger Doak CERTIFIED Colorado Department of Health RETURN RECEIPT REQUESTED 4300 Cherry Creek Drive, South P 024-916-657 Denver, CO 80222-1530 Re: RESPONSES TO CDH COMMENTS ON ADDITIONAL HYDROGEOLOGICAL AND GEOTECHNICAL CHARACTERIZATION AND SITE OPERATIONS, FOR CENTRAL WELD SANITARY LANDFILL, WELD COUNTY, COLORADO Dear Mr. Doak: This letter is in response to Colorado Department of Health (CDH) comments of December 21, 1992 on the subject reports later discussed during a January 20, 1993 meeting at CDH. The CDH comments are reiterated below verbatim, followed by detailed responses prepared with the assistance of Golder Associates, Inc. A. ISSUES WHICH ARE INCOMPLETE OR NEEDING CLARIFICATION Comment No. 1: Point#2 from the October 27, 1992 letter sent by the Division requested a cross-section relating the on-site geology and hydrology to all ground water wells within a 1/4 mile of the facility. Please provide this information. Response: WSC provided an initial response dated December 2, 1992 to CDH Comment#2. Below is a summary of that response: ► Only one ground water well is located within 1/4 mile of the landfill which is approximately 500 feet north and east (upgradient) of the landfill; and, ► No well completion information, including well logs, screen depth, and well completion diagrams, is available for this well. wp5l\Ib\I&m\Fcb02.01 F. CWSL 3.2.93 Mr. Roger Doak February 5, 1993 Page 2 Based on the lack of geologic and hydrogeologic information for the well located within a 1/4 mile of the landfill, it is not possible to construct a cross-section relating the on-site geology and hydrology to the off-site well. Comment No. 2: Please provide documentation which would identify if the retention pond is in direct communication with the ground water, and provide clarification between the relationship of the retention pond and the ground water. Response: Based on clarification provided by the CDH during the January 20, 1993 meeting, it is understood that the CDH comment was directed at the potential relationship between the pond and the mound of shallow ground water identified west of the pond(please refer to the "Hydrogeologic and Geotechnical Characterization Report" for additional background information). The retention pond is located approximately 400 feet east and side gradient of the ground water mound. As shown on Figure 4-lA and 4-1B included in the "Hydrogeologic and Geotechnical Characterization Report," the water level in the retention pond is lower than the elevation of the ground water mound inferred to exist west of the pond. Based on the water levels, the pond is not a potential recharge source of the water level mound. Comment No. 3: There seems to be some confusion over Point #8 from the October 27, 1992 letter. The Division requests cross-sections along (intercepting monitoring points TP-1, TP-6, and GWMW-7) and perpendicular (intercepting monitoring points GWMW-6, TP-6, TP-7, SG- 14, and SG-11) to the underdrain. The Division apologizes for any misunderstanding. Response: The cross-sections requested by the Division have been prepared and are enclosed as Figure 2 to this response letter. Please note that as-built elevations for the underdrain are not available. Therefore, the underdrain elevations shown on Figure 2 are approximations only. wp51\Ib\I&m\Fcb02.01 F: CWSL 3.2.93 }31oci* ti Mr. Roger Doak February 5, 1993 Page 3 Comment No. 4: Please provide as-built drawings for the perimeter french drain. If as-built drawings are not available, provide an illustration which shows the extent of lined portions, thickness and types of construction materials, and relationship of geologic and saturated geologic units to the french drain. Response: As-built drawings for the perimeter french drain are included in the enclosed report prepared by Industrial Compliance, Inc. (IC) dated November 12, 1992. Comment No. 5: The Division requests that additional hydrogeologic evaluations be performed west of the facility. This investigation shall determine whether Spomer Lakes are influencing ground water characteristics along the western boundary of the facility. Response: The existing ground water monitoring network, is considered sufficient to determine the potential interrelationship between Spomer Lakes and the ground water along the western boundary of the facility. As discussed in the "Hydrogeologic and Geotechnical Characterization Report," water levels from the monitoring wells and soil gas probes can be used to identify recharge/discharge relationships between the lakes and the ground water. Vertical hydraulic gradient data near Spomer Lakes discussed in Section 4.4 of the "Hydrogeologic and Geotechnical Characterization Report" suggest that the lakes may be locally recharging ground water. It was noted in the report that seasonal variations in ground water may affect the relationship between the lakes and the shallow ground water. WSC will continue to collect ground water data as part of our quarterly environmental monitoring program which can be used to determine the potential seasonal variations to further address CDH concerns. Comment No. 6: To understand the relationship between the quality of ground water from the private wells in the vicinity of the site and those at the facility, the Division requests that the following wpS1\Ib\I&m\Feb02.01 F: CWSL 3.2.93 Mr. Roger Doak February 5, 1993 Page 4 wells be sampled, (permit #159091, #765, #11090, and #90580). These wells shall be analyzed for the identical parameters as the monitoring wells at the facility. Please provide cross-sections through the private wells to show the relationship of the landfill geologic and saturated geologic units to those of the private wells. Response: During the January 20, 1993 meeting CDH indicated that it agreed with WSCs' concerns regarding the capability of samples collected from the private wells to identify impacts from the landfill and generate geologic cross-sections through private wells to relate to the landfill. The CDH comment incorporates two primary components: (1) sampling and analysis of ground water from the private wells; and (2) generating cross-sections through the private wells. Each component is discussed below. 1. SAMPLING AND ANALYSIS OF GROUND WATER FROM THE PRIVATE WELLS Sampling ground water from the wells identified above is unlikely to provide reliable information for comparison to ground water quality at the landfill due to (1) the demonstrated limited extent of impacts to ground water from the landfill, (2) different completion depths of selected private wells, and (3) unknown completion techniques for the private wells, and (4) other potential impacts to ground water quality. (al Limited Extent of Impacts to Ground Water from the Landfill Additional hydrogeologic characterization activities conducted at the site subsequent to submittal of the "Hydrogeologic and Geotechnical Characterization Report" revealed that volatile organic compound concentrations in the shallow aquifer are limited to within approximately 25 feet of the south side of the landfill (see letter report entitled"Expanded Hydrogeological Investigation at the Central Weld Sanitary Landfill," October 23, 1992). Of the downgradient wells listed by the CDH (i.e., permit #765, 11090, and 90580), the closest is approximately 2000 feet from the landfill and the farthest is approximate 4500 feet from the landfill. Based on these data, the downgradient wells are at least 10 times farther from the landfill than the extent of detectable volatile organic compounds. This indicates that analysis of wp51\Ib\I&m\Feb02.01 F: CWSL 3.2.93 S.31,06?. V Mr. Roger Doak February 5, 1993 Page 5 ground water from the private monitoring wells will not provide useful information for comparison to the ground water quality at the landfill. Since the remaining well (permit #159091) is located upgradient approximately 500 feet from the landfill, it would be inappropriate to use this well to determine impacts from the landfill. (b) Different Completion Depths of Selected Wells Table 1-2 of the "Hydrogeologic and Geotechnical Characterization Report" includes depths of the wells (permit #765, #11090 and #90580) as provided by the State Engineer's office. The depth of well (permit #159091) has not been reported to the State Engineer's office. However, based on available information, this well is upgradient of the landfill. As shown on Table 1-2, the well with permit #765 is completed to a depth of 263 feet and well with permit #11090 and #90580 are completed at shallow depth (i.e. less than 40 feet) below ground surface. Additional information subsequently obtained from the State Engineer's office indicates that screened interval for this well (permit #765) is from 233 to 263 feet below ground surface. The screened interval is approximately 200 feet deeper than the shallow aquifer beneath the landfill. Based on this deep completion interval and the absence of any detectable contamination in onsite deep wells, sampling of the offsite residential deep well is not necessary. (c) Unknown Completion Techniques The drilling and completion techniques used on the downgradient wells are unknown but were likely much less stringent than the drilling and completion techniques used to complete the monitoring wells at the landfill. Incomplete decontamination procedures inappropriate well completion materials (such as carbon steel, grease, oils, etc.) and inadequate well maintenance and security often render monitoring of private wells unreliable. Based on the limited extent of impacts from the landfill, the deep completion depths for selected wells, and the unknown completion techniques of the wells, sampling of the private wells is considered inappropriate for understanding the relationship between the quality of ground water in the vicinity of the site and at the facility. (d) Other Potential Impacts to Ground Water Ouality wp51\ib\I&m\Feb02.01 F: CWSL 3.2.93 a a�:"1O6'Jam. Mr. Roger Doak February 5, 1993 Page 6 In addition to potential impacts from CWSL to surrounding ground water quality, past land use impacts including agricultural practices can impact ground water quality. For instance, pesticide and fertilizer application, equipment maintenance and septic systems, all may be potential impacts not from CWSL. 2. GENERATING CROSS-SECTIONS THROUGH THE PRIVATE WELLS In response to CDH comment #2 from the October 27, 1992 letter, an additional review of the information on file with the State Engineer's office was conducted for the private wells identified above. Of the four wells identified by the CDH, geologic information is available for only two (permit #765 and #11090). These wells are located approximately 4500 and 3000 feet east of the landfill, respectively. The great distance from the landfill to these wells renders geologic and hydrogeologic interpretation unreliable due to the great intervening distance for which no data exists. Furthermore, as is typical, the geologic data collected during drilling of these wells is incomplete and inadequate for proper comparison to the data collected at the landfill. For example, geologic data collected for well #11090 included only three units: gravel, clay, and sandstone. Gravels were the predominant geologic unit identified for this well. No gravels were encountered at the landfill. Accordingly, it is not possible to reliably correlate the geology at the landfill to the geology at this well. Based on the great distance from the landfill to the downgradient wells which have geologic data, combined with the sparse geologic data available for the wells and the grossly different geologic conditions at the wells, construction of geologic cross- sections through the private wells to show the relationship of the landfill geologic units to those of the private wells is technically inappropriate and not possible. Comment No. 7: Figure 1 from "Responses to Colorado Department of Health Comments on the Hydrogeologic and Geotechnical Characterization Report for the Central Weld Sanitary Landfill" indicates an historical maximum water level. What is the date of this water level? Please illustrate the top of the ground water surface between monitoring points. Ground water is shown below the completion depth of trash piezometer TP-4. Please provide an explanation/data which verifies the depth of ground water at this location. wp51\Ib\I&m\Feb02.01 F: CWSL 3.2.93 • Mr. Roger Doak February 5, 1993 Page 7 Response: The date of the historical maximum water level shown on Figure 1 is March and April of 1992, based on data collected by Golder. The dates have been added to the figure to provide clarification. The ground water surface between the monitoring points has been added to the figure. As discussed in the footnotes included and illustrated in Figure 1, the ground water level in TP-4 (4762.36) as reported by Golder on 4/28/92 is similar to the ground water level elevation reported by IC (4764.90) on 1/4/91. IC reports the completion elevation of TP-4 as 4766.76, but notes in their report that subsequent completion depth measurements of the piezometers differ from the original measurements taken following installation, in some cases 3 to 6 feet. However, a reason for this difference was not determined, but, this should not affect any of the ground water data presented. Verification of the completion depth of the piezometer will be included in the first quarter 1993 monitoring event. Comment No. 8: Please explain why the detection limits were increased(Central Weld Sanitary Landfill Third Quarter 1992 Ground Water Monitoring Results) for volatile organic analyses for monitoring well GWMW-5N. It appears that these limits were raised exclusively on GWMW-5N. In addition, VOC samples from monitoring wells GWMW-5N and GWMW- 10, when checked by the lab (PX), did not have the required preservation of a pH less than 2. In the Division's judgment these samples are invalid and these wells must be resampled. Response: Since receipt of this comment, CWSL has provided additional information to CDH that we believe adequately responds to this comment. CWSL provided an explanation concerning the detection limits in a letter submitted to WCDH and CDH on December 12, 1992. This letter was in response to the WCDH comments on the CWSL third quarter 1992 ground water sampling results. CWSL believes the results for GWMW-5N and GWMW-10 are valid based on the January 20, 1993, information from SEC-Donohue that is enclosed for your review. wp51\Ib\I&m\Feb02.01 F: CWSL 3.2.93 if) 132106-'. / Mr. Roger Doak February 5, 1993 Page 8 Additionally, these wells were resampled as part of the CWSL fourth quarter sampling event conducted during December 1992. B. OPERATIONAL IMPROVEMENTS Comment No. 1: In the judgment of the Division, the number of ground water monitoring points are not adequate for the southeastern boundaries of the facility to delineate contaminant migration. To improve the ground water monitoring situation the Division request that additional nested wells be installed along the south and southeastern property boundaries. Please provide all information to the Division for review. Response: The CDH and WSC discussed this issue during the January 20, 1993 meeting and agreed to delay submittal of a response to this comment until additional information regarding designation of point of compliance wells at the site is determined by WSC. Comment No. 2: Please provide documentation which demonstrates that the french drain is adequate to transport water and prevent continued infiltration to the shallow aquifer. If the construction of the perimeter french drain is not appropriate, please provide design improvements. Response: The french drain was not installed to prevent recharge to the shallow aquifer but rather was installed to control infiltration to the landfill from off-site irrigation activities of the site. As discussed in the January 20, 1993 meeting, it is assumed that CDH intended for WSC to demonstrate that the french drain is adequate for controlling infiltration to the landfill from off-site irrigation activities north and east of the site. Documentation was previously given as response to CDH Comment No. 6 in WSC's letter of December 2, 1992. This response stated that seasonal rises in ground water levels immediately east of the landfill in response to irrigation activities do not occur within the landfill near the french drain. The lack of water level rise within the wpsl\Ib\I&m\Feb02.01 F: CWSL 3.2.93 Mr. Roger Doak February 5, 1993 Page 9 landfill near the french drain indicates that the drain is effective in controlling the migration of irrigation water east of the landfill onto the site. Comment No. 3: Surface water sample locations (landfill underdrain, north discharge pipe, discharge from the french drain into the retention pond, and Spomer Lakes) shall be sampled for eight (8) consecutive quarters. Response: As discussed during the January 20, 1993 meeting, surface water sampling at the site will be regulated by the Water Quality Control Division and will be coordinated with the Solid Waste Division of the CDH. Accordingly, it is understood that this particular comment is no longer applicable. Comment No. 4: All deep ground water monitoring wells shall be monitored for eight (8) consecutive quarters and include all parameters as required by the Division. Monitoring frequency and parameters may be modified, at the request of the applicant and approval of the Division, after completion of required background sampling. Response: All deep ground water monitoring wells will be monitored for eight (8) consecutive quarters for the parameters to be agreed upon by the CDH and WSC. After completion of the eight (8) quarters of sampling, CDH and WSC will review the results and evaluate the sampling frequency and parameter list as appropriate based on the results obtained. Comment No. 5: The proposed revised Solid Waste Regulations do not allow for field filtering of water samples. Please make this change in all texts and implement this plan during the next sampling event. wp51\Ib\I&m\Feb02.01 F: CWSL 3.2.93 Mr. Roger Doak February 5, 1993 Page 10 Response: It is agreed that field filtering of samples to be analyzed for total alkalinity, total organic carbon, volatile organic compounds, and specified conductance is inappropriate, as specified in the "Ground Water Monitoring Plan" for the site. However, as further stated in the "Ground Water Monitoring Plan", field filtering of samples to be analyzed for metals is considered necessary in order to avoid false data which are not representative of the constituents actually present in the ground water. In addition, altering sample procedures to comply with draft regulations is not considered appropriate, since draft regulations are often revised prior to becoming final. As a matter of fact, we understand a proposed rule lifting the ban on field filtering is being considered by EPA. Finally, Section 2.2.3 of the Solid Waste regulations currently requires the collection and analysis of dissolved (i.e., filtered) iron, cadmium, lead, mercury, zinc, and manganese. If these samples were collected and analyzed for the parameters without field filtering, the facility would be in violation of currently existing regulations. Field filtering of metals samples will be revised if necessary after the proposed Solid Waste Regulations are finalized. However, until the proposed regulations are finalized, it is appropriate to continue to field filtered metal samples in accordance with existing regulations. Comment No. 6: Table 5-1 in the "Ground Water Monitoring Plan for the Central weld Sanitary Landfill, Weld County, Colorado" is inadequate. The following parameters shall be added to Table 5-1: all 34 volatile organic compounds (VOCs) included in the "Hydrogeological and Geotechnical Characterization for the Central Weld Sanitary Landfill;" carbon disulfide: dichlorodifluoromethane and trichlorofluoromethane;radionuclides;chromium;barium and nickel. Table 5-1 shall be changed to read "Ground Water and Surface Water Parameter List Central Weld Sanitary Landfill." Response: The parameter list specified on Table 5-1 of the "Ground Water Monitoring Plan" complies with current regulations governing sampling and analysis of ground water at solid waste landfills (see Section 2.2.3 of the Solid Waste Regulations) and also wp51\lb\Vim\Feb02.01 F: CWSL 3.2.93 Mr. Roger Doak February 5, 1993 Page 11 includes additional volatile organic compounds not specified in the Solid Waste Regulations but which were detected in shallow ground water. Accordingly, the parameter list specified in Table 5-1 is appropriate. The basis for requesting the additional parameters listed above is unclear. WSC has demonstrated that only a select few volatile organic compounds are present in ground water at the site. These compounds are included in the monitoring plan. Radionuclide concentrations have been shown to represent natural conditions. Chromium was detected in only one sample. Barium concentrations were all below the State of Colorado primary drinking water standard of 1.0 mg/1 and were determined to be present as a result of natural, geologic sources. As discussed at our January 20, 1993 meeting WSC agrees to add chromium, barium and nickel to the parameter list in Table 5-1. However, before adding additional VOCs, WSC respectfully requests CDH reconsider the request for additional parameters and require only those parameters detected in previous sampling events. WSC agrees also to add radionuclides to Table 5-1 but, because it is naturally occurring, we suggest the frequency be annually rather than quarterly. Enclosed for your information is a study entitled "A Comparison of Chemical Constituents in Industrial Hazardous Waste and Municipal Waste Landfill Leachates" which was prepared for Waste Management of North America, Inc. (WMNA) to evaluate the presence of VOCs at municipal solid waste landfills. This report shows from using a national compilation of leachate data from municipal solid waste landfills that only a few and relatively low levels of volatile organic compounds are present. Consequently, we request your reconsideration to allow WSC to continue with its recommended list of parameter as modified by this response. Comment No. 7: All piezometers shall be monitored for depth to ground water. Monitoring shall be conducted during each quarterly sampling event and data submitted to the Division. Response: In response to the CDH comment, water levels in the piezometers will be monitored on a quarterly basis and the data will be submitted to the CDH. wp51\Ib\I&m\Feb02.01 F: CWSL 3.2.93 // Mr. Roger Doak February 8, 1993 Page 12 Comment No. 8: The Division requests that those constituents identified from monitoring well GWMW-5N(target parameter list) be analyzed on a monthly basis. Sampling shall commence during January 1993 and continue for twelve (12) consecutive months. Routine quarterly sample of this well shall continue for the established suite of parameters. If additional constituents are identified during quarterly sampling, they will be added to the target list. The Division will evaluate sample frequency and parameters after completion of this sampling schedule. Response: Any benefit of monthly sampling of GWMW-5N would be minimal. Data obtained during the hydrogeologic study of the site indicates that ground water flow within the shallow aquifer is approximately 95 feet per year with idealized optimum conditions. This corresponds to a flow rate of approximately 8 feet per month and 24 feet per quarter. Monthly samples would therefore represent ground water which had migrated only about 8 feet from the previous month. This flow rate is so small that monthly sampling is unlikely to provide any significantly increased protection to human health and the environment when compared to quarterly ground water sampling. In fact, and due to real world conditions such as a cone of depression established during sampling and at a flow rate of 8 feet per month, it is likely that a significant portion of each month's ground water samples will include ground water which was sampled during the previous month. This type of mixing of samples is unlikely to provide an accurate characterization of the ground water quality changes near GWMW-5N. As clarified by the CDH during the January 20, 1993 meeting, the CDH comment was prepared based on a concern regarding potential impacts from off-site upgradient irrigation activities on the water quality data for GWMW-5N. However, this concern should be minimal given the great distance between off-site upgradient irrigation activities and GWMW-5N the interceding influence of the french drain and the flow rate for the shallow ground water near the site. As shown on Figure 4-lA and 4-1B in the "Hydrogeologic and Geotechnical Characterization Report," the distance between the closest off-site upgradient source of irrigation water and GWMW-5N is approximately 1200 feet. Section 4.3.1 of the "Hydrogeologic and Geotechnical Characterization Report" states that shallow ground water flow at the site is approximately 95 feet per year. Accordingly, assuming that the perimeter french drain did not intercept the irrigation water (i.e., a worst-case scenario), approximately 12.5 years would be needed for the off-site upgradient irrigation water to reach GWMW-5N. This time frame is wp5111b\Mat\Feb02.01 F: CWSL 3.2.93 s 1fl6 . Mr. Roger Doak February 8, 1993 Page 13 excessively long and indicates that monthly sampling of GWMW-5N will not provide information which is any more reliable or useful than is the quarterly ground water monitoring information to be collected. Based on the hydrogeology of the site, WSC requests that sampling of GWMW-5N be continued on a quarterly basis to provide reliable results with which to determine potential impacts on human health and the environment. C. AREAS OF NON-COMPLIANCE Comment No. 1: Central Weld Sanitary Landfill has contaminated the ground water. This is a violation of subsection 2.1.4 of the Regulations. The Regulations clearly state a site and facility operated as a sanitary landfill shall prevent water pollution. Please provide a corrective action plan which addresses the contamination issues on and off site. Response: As requested by CDH during our meeting on January 20, 1993, the enclosed legal interpretation of Section 2.1.4 was prepared and is attached for your review. Based upon this interpretation, WSC believes CWSL is in compliance with Section 2.1.4 of the Regulations. WSC would request that CDH consider removing this issue as an area of non-compliance and provide written clarification in this regard. WSC has reviewed potential remedial options as you requested and has provided its recommendations to the CDH in the December 17, 1992 letter describing a corrective action plan. Comment No. 2: Solid wastes have been placed into ground water at this facility. The Purpose, Scope and Applicability as defined in Section 3 of the proposed revised State's Solid Waste Regulations, defines standards for new landfills, existing landfills and lateral expansions. Subsection 3.1.11 (draft of November 5, 1992) states "landfills shall not be place wastes below or into surface water or ground water . . . ." Please be aware, the Division fully expects the proposed revised Solid Waste Regulations will become effective in the very near future. At that time Central Weld Sanitary Landfill will be in violation of area 'C', point #2 as detailed above. wp51\Ib\I&m\Feb02.01 F: CWSL 3.2.93 Mr. Roger Doak February 5, 1993 Page 14 Response: Since this comment addresses a potential area of non-compliance if proposed regulations are adopted without change, it is our understanding that, any issue of compliance will be addressed, when a regulation is adopted. We are monitoring the proposed regulation carefully and will ensure that the facility is in compliance with any requirements ultimately adopted. We would like to state, however, that there is no evidence that waste was ever placed in ground water at CWSL. Interviews with employees indicate that waste was not placed in ground water during the time of their employment (1979 to present). We have separately requested clarification of this proposed regulation as part of our ongoing participation with you incorporating USEPA Subtitle D into Colorado's regulations. Until this regulation is adopted, we further request your clarification to indicate this is not an area of non-compliance. Please contact me if you have any questions about these responses. We appreciate the opportunity to meet with CDH on January 20, 1993 and believe future meetings will facilitate our working relationship. Sincerely, Bill Hedberg Division Vice President - Landfill Operations Enclosures BH/mmp wp51\@\b&m\Feb02.01 F: CWSL 3.2.93 sziocsn /y S?iO6'; /5 Mr. Roger Doak February 5, 1993 Page 15 cc: Glenn Mallory, CDH, w/enclosure John Pickle, WCHD, w/o enclosure Lee Morrison, Weld County, w/o enclosure B. Taylor, CDH, WQCD w/o enclosure L. Perrault, Colorado Attorney General, w/enclosure C. Cunliffe, WCPD, w/o enclosure A. Scheere, WSC, w/enclosure Constance Harbert, Weld County Commissioner, w/o enclosure Bill Webster, Weld County Commissioner, w/o enclosure Dale Hall, Weld County Commissioner, w/o enclosure George Baxter, Weld County Commissioner, w/o enclosure Barbara Kirkmeyer, Weld County Commissioner, w/o enclosure Ward Herst, Golder Associates, Inc. wp51\Ib\I&m\Ftb02.01 F: CWSL 3.2.93 raft& P C Attorneys At Law J 7 1775 Sherman Street • Suite 1300 Denver, Colorado 80203 . (3031 861-1963 • Fax: (303) 832-4465 Ext. 123 February 15, 1993 Ms. Connie Harbert, Chairperson Mr. David Shelton, Director Weld County Commissioners Hazardous Materials and Waste 915 - 10th Street, P.O. Box 758 Management Division Greeley, Colorado 80632 Colorado Department of Health 4300 Cherry Creek Drive South Mr. Chuck Cunliffe Denver, Colorado 80222-1530 Director, AICP Department of Planning Services Mr. Tom David, County Attorney Weld County Administrative Offices Weld County 1400 N. 17th Avenue 915 - 10th Street Greeley, Colorado 80631 Greeley, Colorado 80632 RE: Violation Notice ZCH-96 of January 18, 1993, and Certified Letter to Waste Services Corporation Central Weld Sanitary Landfill, Dated January 14, 1993 Dear Ms. Harbert, Mr. Cunliffe, and Mr. Shelton: The Ashton-Daniels Neighborhood Association and Sam and Myrtle Telep sent the enclosed letter and attachments on January 18, 1993 to the Weld County Commissioners for the purpose of ensuring that the violations occurring at the Central Weld Sanitary Landfill are remedied in accordance with the law and the representations made to the Weld County Commissioners when the land use approval and Certificate of Designation for the landfill were obtained from Weld County. We enclosed a transcript which shows that the landfill authorization was obtained on the basis that the facility would not contaminate groundwater, would be in existence for fifteen years, and would he graded so that the natural ground level was maintained upon closure. �Xhlhl-f-_ H cz h , cit L/ft5i., /It Gnt Qi i,O6 . l Connie Harbert, Chuck Cunliffe and David Shelton February 16, 1993 Page Two The conditions for approval of the landfill have been violated, and no operations plan can be approved which allows the natural surface of the ground to be exceeded in light of the representations made when the land use approval was given. To the extent that the Colorado Health Department and/or Weld County is considering an operations plan for the facility, it must include a condition restricting and prohibiting exceedence of the natural grade of the ground. However, our position is that no operations plan, and definitely no expansion of the facility, should be allowed. We believe that legal and technical review will demonstrate that the only appropriate plan and order for this facility consists of a closure and remedial plan to intercept and treat contaminated groundwater and surface water, and restore the natural grade. Sincerely, Gregory J. Hobbs, Jr. for HOBBS, TROUT & RALEY GJH/det C- • Glenn Mallory • John Pickle • Lee Morrison GJHldet/2169311 :331.061". DEPARTMENT OF PLANNING SERVICES PHONE(303)353-3845, EXT. 3540 C. WELD COUNTY ADMINISTRATIVE OFFICES WI ip 1400 N. 17TH AVENUE GREELEY, COLORADO 80631 COLORADO January 18, 1993 Waste Services, Inc. C/0 Waste Management P.O. Box 122283 Ft. Worth, Tx. 76121 Subject: Violation Notice - ZCH-96 on a parcel of land described as part of the W2 SW4 and the SE4 SW4 of Section 32, T5N, R66W of the 6th P.M. , Weld County, Colorado. Dear Sirs: A review of your property was conducted to determine if the Conditions of Approval placed on the property at the time SUP-116 was approved by the Board of County Commissioners are in compliance. The review revealed violations of Condition of Approval #1. John Pickle' s memorandum dated January 8, 1993, and Trevor Jiricek's certified letter Number P423 630 398 dated January 14, 1993 , outlines the violations of Condition of Approval #1 on the Board of County Commissioners' Resolution dated October 6, 1971. The Department of Planning Services is still evaluating the possibility of violations of Condition of Approval #2 on the Board of County Commissioners' Resolution dated october 6 , 1971. You will be notified if violations are identified during the Department' s evaluation. Copies of John Pickle' s memorandum dated January 8, 1993, Trevor Jiricek' s certified letter dated January 14, 1993, and the Board of County Commissioners' Resolution dated October 6, 1971 are enclosed for your review. The Use by Special Review area must be brought into compliance with the Conditions of Approval within 30 days from the date of this letter. Noncompliance will result in our office scheduling a Probable Cause Hearing before the Board of County Commissioners . If the Board determines there is sufficient probable cause to warrant further action, a Show Cause Hearing will be scheduled to consider revocation of the Use by Special Review permit 116. If you have information that may clear up this matter, please call or write. Sincerely,C.k Chu�`'unliffe, AICP Director enclosures pc: William J. Hedberg Bill Jeffry e Morrison, Assistant County Attorney John Pickle, Weld County Health Department 9064 q 3 � rat • t‘a\4: Cl � `lJA 11 1 4 1993 1 , DEPARTMENT OF HEALTH U .1I- 1517.16 AVENUE COURT ' GREELEY, COLORADO 80631 WI O ADMINISTRATION (303)353-0586 HEALTH PROTECTION (303)353-0635 COMMUNITY HEALTH (303)353-0639 COLORADO January 14, 1993 Certified Letter No.. : P 423 630 398 William J. Hedberg Waste Services Corporation 6037 77th Avenue Greeley, Colorado 80631 Dear Mr. Hedberg: On December 20, 1992, a representative of the Environmental Protection Division of the Weld County Health Department inspected the Central Weld Sanitary Landfill, located at 6037 77th Avenue, Greeley, in Weld County, Colorado. The purpose of the inspection was to inspect and assess the facilities compliance with the "Regulations Pertaining to Solid Waste Disposal Sites and Facilities" (The Regulations) as promulgated by the Solid Waste Disposal Sites and Facilities Act (The Act) , Title 30, Article 20, Part 1, C.R.S. , as amended. On the date of the December 20, 1992, field inspection, the following was observed, or has been observed previously: 1. This facility continues to discharge pollutants into state waters without an approved discharge permit. 2. This facility continues to allow water to pond on the eastern portion of the facility. 3. This facility continues to operate in the absence of an approved Design and Operations plan. 4. This facility has contaminated the groundwater beyond the facility property line. 5. Solid waste has been placed into groundwater at this site. 6. This facility is currently operating without an emissions permit. It has been documented that previously disposed solid waste is currently exposed to groundwater and that groundwater pollution has occurred at this location. As you are aware, subsection 2.1.4 of The Regulations states that "A site and facility operated as a sanitary landfill shall provide means of finally disposing of solid wastes on land in a manner to minimize nuisance conditions. . . ." and that 324.06'. William J. Hedberg • Certified Letter No. : P 423 630 398 January 14, 1993 Page 2 "nuisance condition are those which may result from explosive gas, bird hazards, disease vectors, odors, windblown solid wastes or cover materials, open burning, water pollution. . . ." This facility allows water to pond on the eastern portion of the site. According to subsection 2.1.4 this facility "shall provide adequate cover with suitable material and surface drainage designated to prevent ponding of water. . . ." and subsection 2.2.2 which states "Surface waters shall be diverted from, or around, the disposal site and facility and its working face." The Central Weld Sanitary Landfill is currently operating without an emissions permit as required by the Air Pollution Control Commission of the Colorado Department of Health. In addition, this facility continues to discharge pollutants into state waters without an approved discharge permit. Operating without a discharge permit is a noncompliant activity according to Title 25, Article 8, Part 5, Colorado Revised Statutes, as amended. Both deficiencies are in violation of Subsection 2.1.2, of The Regulations which states in part "facilities shall comply with the health laws , standards, rules, and regulations of the department, the Water Quality Control Commission, the Air Quality Control Commission. . . ." The operation of this facility in the absence of an approved Design and Operations Plan is a violation of 30-20-103 of The Act, as it states in part, "Such application shall. . . .set forth the location of the site and facility; the type of site and facility; the type of processing to be used, such as sanitary landfill, composting, or incineration; the hours of operation; the method of supervision; the rates to be charged, if any; and such other information as may be required by the board of county commissioners. The application shall also contain such engineering, geological, hydrological, and operational data. . . ." The Division has taken into consideration that a preliminary Design and Operations Plan, a remedial action plan, and a discharge permit have either been applied for or submitted, which address some of the above issues. If you have any questions, please feel free to contact me at 353-0635. Sincerely, i Trevor Jiricek Solid and Hazardous Waste Specialist TJ-085 cc: Roger Doak, Colorado Department of Health Lee Morrison, Assistant Weld County Attorney Chuck Cunliffe, Weld County Planning Department Alan Scheere, Waste Management of North America, Inc. Bill Webster, Weld County Commissioner Kart l mEmoRAnDum W IL D c. Chuck Cunliffe, Planning January 8, 1993 70 COLORADO John Pickle, Health�_`7 • � From Central Weld Sanitary Landfill Subject: The Central Weld facility has been the subject of very close monitoring over the past six (6) months. Disclosure of offsite groundwater contamination by Waste Management in August 1992, along with growing community concern, prompted increased surveillance since July, 1992, and it continues to the present. During this time period, Environmental Protection staff have spent considerable time in field inspections of the site, meetings and correspondence with Waste Management, Waste Services, Colorado Department of Health, and other county offices, as well as review of reports and records from the facility. In the process of these activities we have determined the following areas of concern, which our Division submits as violations: 1. The operators of the Central Weld Sanitary Landfill did not file a Design and Operations plan, although a partial submission was made at the County's request on November 12, 1992. Additional information is still being submitted as it is developed by Waste Services. This failure to file would be a violation of C.R.S. 30-20-103 and Subsection 3.1.2 of the Solid Waste Regulations. There is some question as to whether or not this was a requirement at the time this facility was permitted. Such a report was required in the 1971 Amendments to the Solid Waste Act prior to the hearing by the Board of County Commissioners, but the Act requires such a report only "as may be required by the [State Health] Department by regulation." The State appears to have decided that no report was necessary as they treated the landfill as a grandfathered site. Regardless of the State's position, it appears that the Board of County Commissioners expected such a review and that one never occurred. A review of the files does not show that there ever has been an "approval" by the State Health Department, though there has been some correspondence in recent months. The only correspondence that could be construed as any kind of approval, was that of Dennis Hotovec, approving a change of operator, so long as the landfill continued to be operated in accordance with an operations plan, which apparently, has never existed. 2. The Central Weld Sanitary Landfill has operated without required Discharge Permits. This is a violation of Subsection 2.1.2. of the Solid Waste Regulations, and 25-8-501, Colorado Revised Statutes. 3. The Central Weld Sanitary Landfill contaminated the ground water. This is a violation of Subsection 2. 1.4. of the Solid Waste Regulations. The facility has been notified of this violation by our Division on October 5, 1992, and also by the Colorado Department of Health on. December 23, 1992. ci VD- 14- 821.06.1. JAN 1 1 1993 /4" •131LJ6 '. P w. . 1 tr. , q ,tea+ C •_[` - .... L t'E.k ln. OLD 0 L„l �..' ,) t 4-3 i µ, J l-..L-C..�-- 1,, 4 LA_ t , C.�ti..u-..�� .y.- C. GL , L { Ly Liu L.) 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To The Tribune: .The Central Weld Landfill has until Feb.18 to correct six vi- Unfortunately,it requires a lot of gumption olthlons of Weld County and state health standards or face hear- to speak out in our county against the status ings that could revoke its permit for operation. quo.Granted,there have been a few bold souls • But WasteManagement Inc.,the landfill's operator,says the out there speaking for many of us too timid to landfill is not in violation of any of the standards cited by the say anything or to even think of the problems county. at hand.One who did speak out Dec.29 was Health officials allege:that toxins called volatile organic Ann Hayes on the Central Weld (Milliken) • compounds are contaminating groundwater at the site,which is Landfill.She gives us a wake up call to envi- `northeast ofMilliken:Also,a milky-white waste water is leach- ronmental disaster in Weld County.Evident- ing from the landfill onto nearby property, the officials charge. ly,the county chooses to look the other way The problems probably existed before-Waste Management while being wooed by big industry — the took over the landfill,officials said. same ones who make huge profits, leave the The contamination of groundwater by the toxins has violat- air,land,and/or job market in a blighted state, edseveral County health regulations and several Colorado laws, eventually leaving the county with a woeful • according toam'ernorandumfrom the Weld County Health De- calamity. It appears as thought the county Js partment to Chuck Cunliffe,director of Weld County Planning selling its soul for a slice of big business lever- and Zoning.. age;but unfortunately,the only businesses we The intention of the landfill's operators,Waste Management attract now are the polluting and/or cheap .Ine.,.to operate•the landfill for another decade and to raise the labor industries. Why do we accept Waste level of the landfill by 30 feet in places also violates the condi- Management when it has along record of con- tions on which the landfill was originally permitted in 1971,ac- troversial business practices across the coun- cording to the memorandum. states We don't believe we're in violation,and we are preparing western er National Hog Farm, after several states refused to let them operate; or our response right now,"stild Bill Hedberg,division vice pies- thq waste incinerator In3outhem Weld;or the Ident of landfill operations for Waste Services Corp., a sub- brio sidiary of Waste Management. bring collection pools and the injection wells? What happens when toxic pollutants start . "We continue to meet regularly with the county over the life showing up as known causes of cancer and of the site.Any concerns in the area axe things we found in the birth defects in Weld County residents?Who •first place.In the last six to eight months,we have been pro-. pays the lawsuit costs and clean-up costs? gressing and we have been proactive to cure anything that needs attending to,"Hedberg said. How can an unlined landfill not cause toxic .The volatile organic compounds contaminating groundwater and hazardous run-off when petroleum coma- •were discovered through self-testing by Waste Management tninated soil,alleged radioactive material and Waste Management has another landfill in Weld, the North pesticides, asbestos, sludge and other toxins 'Weld Sanitary Landfill,five miles west of Ault off Cob. 14. are dumped into 5 to 25 feet of standing water, • John Pickle, director of Weld environmental protection ser- draining into now-dead lakes,Into an irriga- . vices, says there have never been any problems at the North tion ditch and thence to the Big Thompson Weld landfill. River,a source of irrigation water for the City .The problems at Central Weld probably were caused before of Evans?Would you eat produce or animals Waste Management took over operation of the landfill in 1992, watered by this runoff? . ,.s accordingtoArkle_ .. _ - -, Sharon Davis there's aptoblem with leal ing in older? itis—ones in- Greeley • .stalled in the.''70s and the..'60s..We think,we'll see more prob- - ..- . . -_-_._- lems in landfills,"Pickle said. : e !"'?• .'Nowadays,We are much more strict about what is allowed in landfills.Sortie'older landfills werenot managed as effec- "'tively'aethey are now.The substances that are causing prob- "dems at Central Weld are no_longer accepted. They probably k � noivnever wereaccepted.They just weren't policed as well as they .r >'arei ,",hesaid;i.; ••f:-. ,06_. 3 :2 i. O >�t]7 N— i., .p .` R -, E .a3 �' 4oc .';L7 csc cN i1 ` � C•1 0 a > a v C C N "Y 1 • '° A - a '° e • c 0 0� '° ± '' a '° .p —p •n3c 3 u. ... 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'� 'mv ". 8v � 2 , O a �2 = e.“ 22y° 42gee 3 .c �° � ,o 8eha, ua8a Ep.� .5 , DS -' `s iri 3 's LI: S a5 e as 50 2 O0 fill x = 51 .= 4, 0 .58 = ,‘ " c .... ... y •vJ Cv to OD D (�pv •5 �70748 o.0 o = c $ a ^ 0v c ._ 3 : -17, 2 .. 8 >+ $ u 5 '3 0 owo 9 c ; 3 . 0 .5 sta ,< F 3 . c c E o c `o o .o a A M • J Sfa.06 February 17, 1993 Dr. Patricia A. Nolan Executive Director Colorado Department of Health 4300 Cherry Creek South Denver, CO 80222 Dear Dr. Nolan, Regarding: Central Weld Landfill Thank you for your recent letter. We feel you are our one thread of hope with Colorado Department of Health. We appreciate that! The so-called fact sheet put out by Mr. David Shelton has been disturbing, and Mr. Mallary's letters to my husband and myself have been discouraging, but today something came up that cannot be ignored . . . we were trying to do that! Earlier Mr. Glen Mallary invited my husband and I to view the files (this was in November) . There was a letter in the file from Ronald L. Forlina, Colorado Department of Health, to Alan Sheere, Waste Management Incorporated. Mr. Sheere was told of the deficiencies of a Special Waste Plan and was told to correct the same and re-submit the plan. The "plan" itself was missing from the file. We eventually, through the County Health Department, viewed this "plan. " It was "scary" . . . they were proposing to dump medical waste, banned products, asbestos, contaminated dirt, etc. etc. Again in January, Mr. Glenn Mallary invited us to "view" the Colorado Department of Health files. We did. This time, not only was the Special Waste Plan missing from the file, but also Mr. Forlina's letter, referred to earlier. Today, I found out from Mr. John Pickle that Colorado Department of Health approved this Special Waste Plan but can't even let the County Health Department have a copy because trade secrets of the giants (Waste Management Incorporated) have to be protected! Colorado Department of Health never approved this dump. The county aave a Certificate of Designation. We the citizens of Weld County and dwellers by the Big Thompson need to be protected, not Waste Management Incorporated. If odor, flies and blowing trash are considered a public nuisance, what of gigantic trucks rolling by with contaminated dirt, semi-trailers and just ordinary trash trucks rolling by? We don't know what is in them. I can't sleep once the trucks start in the morning. It physically hurts to think of what may 821061 5 2 eventually leach out of Central Weld Landfill and go down the Big Thompson and on into the South Platte. Are we no longer to believe that Colorado Department of Health is to protect the health and the environment of all Colorado residents? Weld County has been #1 in agriculture in Colorado and #2 in the nation, according to your own Mr. Stoddard. We are fast becoming #1 in pollution. We have no quarrel with Waste Management's "rights" providing they are operating in a lined, dry facility. It is beyond comprehension that their "trade secrets" have any bearing on this drenched, soggy dump, nestled in an irrigation system, one-fourth mile from the Big Thompson. Please help. Thanking you in advance, )74S 5-d-r".4.tJ Madeline Daniels 23732 WCR 271 Milliken, CO 80543 339-0629 or 587-2265 Copies: Governor Romer Senator Hank Brown Senator Ben Knighthorse Campbell Congressman Wayne Allard Senator Tom Norton Mr. Dave Owen Environmental Defense Fund Environmental Protection Agency Weld County Health Department Weld County Planning Weld County/Board of County Commissioners Attorney General 's Office J 9 21.06 ce O � � Ua 331a6!. 7""k Attorneys At Law _ " 0 I 1775 Sherman Street • Suite 1300 Denver, Colorado 80203 (,1_t.; (303) 861-1963 • Fax: (303) 832-4465 ,,;_ ' Ext. 123 February 26, 1993 Ms. Connie Harbert, Chairperson VIA FAX: 1-352-0242 Weld County Commissioners 915 - 10th St., P.O. Box 758 Greeley, Colorado 80632 RE: Request for Rescheduling of March 24, 1993 Hearing Dear Chairperson Harbert: I have just learned that a public hearing has been set for March 24, 1993 on the Central Weld County Sanitary Landfill matter. The Ashton-Daniels Neighborhood Association has a vital interest in this matter and requested a hearing. Nevertheless, we were not contacted regarding the hearing date. I will be out of the United States traveling in Bolivia from March 20- 29, 1993, this being the spring break for my wife who is a teacher. The cost of the airline tickets was $2,000.00, and we purchased them in early January. n -o e ' d /114-I 9 3 a 1!o erdl-N(. tti5 7) fritl-P,- , 0-A! 0,0-r0-; SA06' / ail1&+ k, -FA-k_ z/21, c . a, ('A, VatiYi -nttitq - Ms. Connie Harbert February 26, 1993 Page Two In view of the circumstances, in order to allow the Ashton-Daniels Neighborhood Association to prepare for and participate in the hearing, we request that the hearing be rescheduled for an appropriate date in April. My secretary, Dee Trees, has my calendar and can coordinate the date with your staff and that of the County Attorney and the Landfill representatives. Sincerely, Greg r J. Hoa , Jr. for HOBBS, TROUT&RALEY, P.C. GJH/det c: • Weld County Commissioners • Mr. Tom David • Mr. Sam Telep • Mr. Lee Morrison • Mr. Chuck Cunliffe • Mr. John Pickle • Ashton-Daniels Neighborhood Citizens K 331061 Ashton-Daniels Community Action Group r,. c 3707 65th Ave. Greeley, CO 80634 March 6, 1993 Dear Ms. Harbert, We, the members of the Ashton-Daniels Community Action Group would like you to read these documents regarding Waste Management. Pages 19 and 20 "Garbage dumping and Waste Management's sham recycling efforts", could have been written about Central Weld Sanitary Landfill. Also included is page 36 from another document, please notice the photo of severely eroding Waste Management's landfill on Chicago's Southeast Side. We sincerely hope you will read this manuscript and that you will cast your vote in favor of the preserving environment. Sincerely, Ashton-Daniels Community Group 931.061 �: M1 Many of WMI's "state-of-the-art"landfill designs employ a double-layer Emelle, A high-density polyethylene(HDPE)liner with leachate collection piping be- tween. In 1990 WMI purchased a minority interest in National Smeal, a privately held landfill liner manufacturer. (670) According to the Phillips Petroleum Company, a leading maker of polyethylene, there are a number of chemicals that can weaken polyethylene landfill liners. (628) Liners made out of clay also leak due to the ability of organic chemicals to permeate clay and shrinkage and ex- pansion from varying weather conditions. (632) CWM has also sought to weaken regulations governing hazardous waste landfills. On April 24, 1989, CWM won a decision from the U.S. Ap- pellate Court to drop a provision in regulations issued under the Resource Conservation and Recovery Act's "first-third" land-ban rule, a decision that effectively weakened leachate treatment standards, (633) CWM currently operates seven hazardous waste landfills in the U.S., including the nation's largest in Emelle, Alabama. What follows is a chronology of problems at CWM's hazardous waste landfills. 101111111 x y 0 , 90p CWM'.s eroding CID landfill in Chicago's Southeast Side. SL'a.os1 TRASH ,„. �� fF INTO / T S , r CASH fly 1/1 *:\N ` WASTE MANAGEMENT INC.'S ENVIRONMENTAL CRIMES & MISDEEDS An Abstract of A GREENPfACE REPORT 91.061 3 INTRODUCTION Waste Management, Inc. (WMI)is the largest waste-hauling and disposal firm in the world;its total revenues exceeded six billion dollars ($6,000 million)in 1990. Obviously, managing waste is an exceedingly lucrative business. The very name of the company—Waste'Management—sug- gests that wastes can be safely controlled after they are created. Unfortu- nately,history reveals that this is not true. Once they are produced, dangerous wastes cannot be managed safely. No incinerator,landfill, or other method of waste disposal can protect fu- ture generations and the environment from hazardous chemicals, includ- ing the hazardous chemicals used in our homes everyday(oven cleaner, paint thinner,pesticides, and so forth). The laws of physics dictate that disposal equals dispersal.Everything must go somewhere, and sooner or later, all wastes that are created will be released into the environment; waste disposal has caused steadily increasing contamination worldwide. The deepest oceans are contaminated;wildlife in remote Antarctica is contaminated;human breast milk is contaminated. While still in the womb, babies are contaminated. Pesticides,heavy metals, industrial sol- vents, and a dazzling spectrum of toxic halocarbon compounds are now being measured in living creatures everywhere, and their concentration • throughout the earth's environment is increasing relentlessly. Some of the damage caused by this widespread contamination has been docu- mented in scientific reports. Much awaits to be learned from future study. But this much is clear already: dousing our children, and all liv- ing things on the planet,with steadily increasing types and quantities of toxins cannot be beneficial. If humans are to survive, we must diminish our releases of chemicals into the environment. And this means we must rely less and less upon waste disposal technologies to remedy the waste crisis. This report is intended to help citizens understand the problem of waste disposal as it is practiced by one company, Waste Management, Inc., a leader in the waste-hauling and disposal business. The report is intended to help people protect their community not only from bad actors, but also from bad ideas. The lessons learned from this company have to do with the nature of the waste disposal industry as a whole—the use and promotion of dangerous technologies and the abuse of economic and political power. As we come to recognize that "state-of-the-art" waste dis- posal technologies don't work, even when practiced by the world's wealthi- est waste hauler,we must eventually recognize that the very idea of disposal is wasting our natural resources. People across America are taking direct action to protect themselves • against companies like WMI. For example, in 1982, the Chickasaw Com- munity Affairs Group in Alabama mobilized and successfully stopped a proposed WMI toxic waste storage facility in the neighboring port of Mo- bile. Citizens worked to change local laws to close loopholes that EPA had used to help WMI establish its new facility. Since then, grassroots groups around the world have been stopping or stalling WMI with in- creasing success as the company's dismal record is exposed when the com- pany seeks opportunities to operate in new communities. People are willing to sacrifice momentary convenience for environmen- tal well-being, as poll after poll has shown. But the choice—and the infor- mation to understand that choice,both in the marketplace and the political arena—must be available. The grassroots movement for envi- ronmental justice works to protect the environment by practicing democ- Page 1 Le az;tor • racy. By producing this report we hope to provide citizens and decision makers with information in a form they can use. It is our hope that this report will help generate even more pressure to end WMI's attempts to site new disposal facilities and force decision mak- ers to look at the real solutions to the waste crisis. A well-informed, well- organized group of citizens can keep even a powerful adversary like WMI out of a community. This report, along with reports issued by other envi- ronmental organizations(such as the Citizen's Clearinghouse for Hazard- ous Wastes, which published their WMI Corporate Profile in 1988)is intended to provide information about the company to grassroots groups, enforcement officials, public employee unions and others who are faced with the company's operations in their community. In fact, without a lot of hard work by such people, our report would not have been possible. More and more, grassroots groups are cooperating with others, sharing information, and organizing strategies to prevent disposal companies such as WMI from gaining a foothold in their communities. WASTING AWAY Promoted as an enterprise that"profits by protecting the environment," WMI has become a primary actor in, and accessory to, the process of global contamination. The technologies employed by WMI are all inher- ently destructive; the company's only major line of business—waste dis- posal—severely damages the environment. Even wastes that are "recycled" eventually re-enter the environment, causing pollution through re-manufacturing processes and ultimate disposal. Because Waste Management thrives on the production of waste, the company spends enormous resources promoting the myth of"safe" waste disposal, which it usually calls "state-of-the-art waste disposal technology." The myth of safe disposal is used to persuade government agencies to allow WMI to create new dumps and incinerators or expand the capacity of old ones. The result is a diversion of attention and resources away from pro- duction-end preventive solutions to the waste crisis. Even if WMI operated as a model corporate citizen, its daily opera- tions would contribute in major ways to the destruction of the environ- ment. However, evidence suggests that WMI is not run as a model corporation. In fact, an in-depth study of WMI's corporate conduct re- veals a history of environmental and antitrust law violations, a history of attempts to gain illegitimate political influence, and a history of disre- spect for the communities where the company conducts business. In this sense, WMI not only destroys the natural environment,but also under- mines democratic decision-making from the local to the national level. Many local grassroots leaders can attest to the truth of this latter point. As used in WMI's public relations campaigns, "the environment" is often an abstract concept. But the environment is a tangible and diverse ecosystem that is integral to the lives and neighborhoods of real people— in real communities where WMI has demonstrated disregard for the con- . tern of residents. This Greenpeace report documents WMI's track record in many of these communities, focusing on the company's operations in- the United States, where the company has built an unrivaled waste dis- posal empire. Reports of environmental damage from landfills, incinerators, deep well injection sites, and other"state-of-the-art waste disposal operations". 1 Page 2 931.061 s have become commonplace. Several years ago, concerned citizens began to ask, "If these problems are happening at so many facilities, could there be something wrong with the use of all waste disposal technologies?" That general concern has grown into a widespread,recognition that "dis- posal equals dispersal"—all waste disposal technologies release contami- nants into the environment—and a powerful grassroots environmental protection movement now confronts WMI and other waste disposal com- panies wherever they turn. Meanwhile, the federal government has been going down a different track—trying to curb environmental destruction by creating a compli- cated web of rules and regulations to govern the generation and disposal of waste. Naturally, this government effort has been joined enthusiasti- cally by waste haulers like Waste Management, Inc., who profit from every pound of waste produced and who would be put out of business by serious efforts at waste reduction. Together, the coalition of waste haul- ers and government officials has created the myth of"safe" disposal, a myth bolstered by a vocabulary of catch-phrases such as "integrated waste management," "negligible risk," "state-of-the-art," and "best avail- able control technology(BACT)."These phrases are employed to promote unproven technologies,to hide the truth about the failures of existing technologies, and to divert attention away from the real solution to these problems: to reduce the use of toxic materials with an eye toward elimi- nating them entirely while employing cleaner, more efficient production processes. All "state-of-the-art waste disposal technologies" have failed to work as promised. Furthermore, phrases like "state-of-the-art" work against democratic decision-making because they invite the public to trust "the experts." These experts are usually company officials or hired consultants who have an interest in seeing the waste disposal industry expand or regulatory officials who feel justified in granting any permit if it meets written standards,no matter how inadequate those standards may be. One result has been a massive loss of faith in government's ability to pro- tect the public from polluters. The unholy affiance of waste haulers and government officials is now deeply entrenched in the fabric of American life. The regulatory attempt to make disposal safe has become a deeply entrenched approach to the problem of waste over the last two decades as the U.S. government has written sweeping waste disposal regulations. It is no coincidence that Waste Management, Inc.'s growth skyrocketed during this period. Many current Waste Management employees helped write federal and state en- vironmental regulations when they worked as regulatory officials or as Congressional staff members. The general concept is so common, people have given it a name: the revolving door, through which government regu- lators become highly paid employees of the firms they used to regulate. Knowing that the future promises a lucrative pass through the revolving door, government officials would be fools to urge strict enforcement against violations by the waste-hauling industry. Probably the best- . known example of the "revolving door"is the career of William Ruck- elshaus, who has twice served as chief of the U.S. Environmental Protection Agency and now is chief executive officer of Browning-Ferris Industries (BFI), the second largest hauler in America. But Mr.Ruck- elshaus represents only the tip of the iceberg. The web of government rules on waste disposal has not prevented mas- sive contamination of the environment,but it has benefitted companies Page 3 93 061 like Waste Management and BFI enormously. Waste producers who can't meet on-site disposal regulations now hire commercial waste disposal firms, such as Waste Management, Inc., to take wastes off their hands, in- stead of looking for ways to eliminate wastes entirely through prevention. By playing hardball with communities, Waste Management finds loca- tions—often in sparsely populated rural areas where the local people are naive, politically weak, and financially needy—to dispose of the gener- ators unwanted, dangerous wastes. The existence of a politically powerful, slick, and wealthy waste dis- posal industry has encouraged the generation and disposal of increasing amounts and types of waste. Despite (in a sense, even because of) 10,000 pages of rules and regulations now governing waste disposal, annual gen- eration of hazardous waste in the U.S. is doubling every 12 years. As a result, incentives for waste reduction have actually diminished because the oversight of more and more commercial waste dumps and incinera- tors has sapped the resources of government agencies. Although some waste-generating companies have gained a competitive advantage by eliminating wastes and have even profitted in the process, most compa- nies have come to rely upon the waste disposal industry in order to com- ply with environmental regulations. As a result, the waste disposal industry is one of the fastest growing sectors of the U.S. economy. In the aggregate, the cost for waste disposal and pollution control in America amounted to $90 billion in 1987 and is expected to more than double by the end of the 1990s. The myth of safe disposal has prevented government officials from looking into the manufacturing processes where wastes originate. Gov- ernment officials ignore raw materials and manufacturing techniques— the fundamental sources of pollution. The myth of safe disposal has also allowed regulators to avoid banning toxic materials and unsafe technolo- gies. WMI has played a major part in maintaining the myth of safe dis- posal, and in helping political officials see things in the same light. The great size of WMI's political contributions and the pervasiveness of its ad- vertising reveal how important the myth of safe disposal is to the com- pany's growth and survival. In the 1988 elections,WMI had the seventh largest corporate PAC in America. So long as WMI and other waste industry giants are allowed to influence elections, elected officials can be expected to avoid fundamental solutions to the waste crisis,no matter how tragic the consequences in terms of public health, economic cost, and environmental damage. Contamination by toxic chemicals is increasing relentlessly. But there are exceptions to the rule. Where unsafe materials have been banned, contamination levels are diminishing. In the U.S. the banning of DDT, lead(in gasoline), and PCBs has taught us that prevention works. The great gaps in knowledge about the effects of pollutants (gaps that will never be closed, so long as we allow between 1000 and 2000 new chemi- cals to enter commercial channels each year)should lead to a cautious ap- proach to expanding the use of dangerous materials and polluting technologies. Global warming, destruction of the planet's ozone shield, acid rain,loss of many wildlife species, and indisputable evidence of wide- spread contamination of humans should serve as stark warnings. It is be- coming increasingly clear that long-term sustainability requires a resolute commitment to clean technology and safe materials—and to drastically reduced reliance on waste disposal. Page 4 93106 WMI is the leader of an industry inherently at odds with such positive approaches to the toxics crisis. Without waste, the industry would have no business. Without increased waste generation, these companies could not grow. To maintain its status as one of the best buys on Wall Street, WMI requires a constant increae in waste. Its main line of business is odds with the continued well-being of humans at and other forms of life on earth. Waste Management's growth has also resulted from predatory behav- ior as the company has devoured its economic competition—usually smaller waste haulers and disposal firms—exerting its influence from the streets of small town America to the halls of Congress. In many in- stances the company has used illegal competitive tactics—bid-rigging, price-fixing, and allegedly even physical threats—resulting in criminal and civil suits. In other instances, the company has simply bought out its competition or has positioned itself to underbid and squeeze out its com- petition for waste disposal services. Antitrust enforcement WMI g cies moving are understaffed and usually lack the political will to stop toward monopoly. Even when the will exists, current laws provide au in- adequate deterrent to the company's practices. For a giant like WMI,en- vironmental penalties, antitrust penalties, and legal fees(many of which can be written off against taxes) are easily absorbed as normal costs of do- • ing business—even when those penalties run into millions of dollars. The result of monopolization is that the company's customers,both house- holders and businesses, suffer artificially inflated costs. In this respect, the company's operations cause not only environmental deterioration but also economic decline. WMI's aggressive expansion strategy has been exceedingly lucrative for its directors and stockholders. Waste Management's top executives are among the U.S.'s highest paid, and the company's growth—now in- creasing at a billion-dollar-a-year clip—has thrust the firm toward the top of the U.S. corporate charts. In the 1990s,the company expects to increase its growth through inter- national expansion and diversification into specialized services. Chemi- cal Waste Management(CWM), the hazardous waste disposal subsidiary of WMI, for instance, expects to make Superfund site cleanup, and the cleanup of military bases and of contaminated nuclear weapons produc- tion sites, a big part of its business in the 1990s. Growth and profits in this business require the shipment of contamination from one community to another. CWM's Superfund cleanup division—the Environmental Re- medial Action division(ENRAC)—is handsomely paid for moving waste from contaminated sites around the country to other contaminated sites: to the Emelle,Alabama,landfill,for example, which continues to receive the largest share of Superfund waste in the country, even though it has been shown to be leaking. This shell game allows the government to claim that is has the situ-. ation under control and is"doing something about it," allows Waste Man- agement and other companies like it to become fabulously wealthy (wealth which they then use to support re-election bids by sympathetic political candidates),while moving wastes out of middle-class communi- ties into poor communities(and more often than not into communities of racial and ethnic minorities). The last advantage of this shell game is that it allows responsible government officials—politicians and regula- tors alike to avoid having to confront e the real are selected, e l source materials of the waste where prob- lem:the manufacturing places Page 5 • manufacturing techniques are devised, and where products are made. Government does not want to reach its hand into this arena, which corpo- rate management has traditionally viewed as entirely its own. So, in- stead, government forms coalitions with the polluters against the local citizenry, runs interference for the polluters so they never have to con- front the victims of their handiwork, helping the waste haulers develop and license new dumps and incinerators, and enthusiastically promotes the myth of safe disposal. Until government abandons the myth of safe disposal andbegins to recognize that companies like Waste Management, Inc., are a major part of the problem, and not part of the solution, global environmental destruc- tion will continue to accelerate. WMI AT A Waste Management Inc. is the world's largest waste disposal company. GLANCE Its annual revenue grew from 76 million dollars in 1971 to 6 billion dol- lars in 1990. It ranks 19th in the Fortune 500 list of the largest diversi- fied service companies in the U.S. It hauls garbage from almost eight million households in the U.S., in over 1350 communities. It operates over 128 landfills in at least 36 states. (1) Each landfill is a time bomb in the earth, waiting to poison future generations when it begins to leak According to a Prudential-Bache securities analyst,WMI's subsidiary, Chemical Waste Management(CWM), is the largest hazardous waste dis- posal company in the U.S. CWM controls up to one-third of the entire U.S. commercial hazardous waste treatment and disposal capacity. CWM's revenues doubled in the late 1980s, and the company earned over one billion dollars in revenue in 1990. (1) WMI also controls the largest nuclear waste disposal firm in the U.S. (Chem-Nuclear), owns 49 percent of the U.S.'s largest asbestos removal company(Brand Industries), and owns 55 percent of the U.S.'s largest garbage incineration firm (Wheelabrator Technologies). Waste Management's growth is achieved mainly by devouring its com- petitors—smaller waste haulers and disposal firms—from the streets of Milwaukee,Wisconsin, to Venezuela. In some cases their tactics—which reportedly include bid-rigging, predatory pricing, price-fixing, and alleg- edly even physical threats—have resulted in criminal and civil suits. The corporation's growth has paid WMI's executives handsomely. WMI's president, Philip Rooney, earned $14,276,000 in 1987. Donald Flynn, a WMI senior vice president, received $13,217,000 in 1987, and Dean Buntrock, the Chief Executive Officer of WMI, was the highest paid CEO in Illinois in 1988. (2) ECONOMIC Mere fate and providence have not guided the transformation of an ob- MALPRACTICE scure regional garbage hauler into a powerful global waste disposal jug- gernaut. To create an empire, the company has mixed business acumen FOR PROFIT and foresight with strong doses of deception, corruption, and monopolism. The company, its subsidiaries, and its employees have faced antitrust lawsuits or government investigations in at least 17 states. Since 1980, WMI, its subsidiaries, and its employees have paid more than $28 million Page 6 93106'" in fines or settlements for price-fixing,bid-rigging, and other allegedly il- legal means of discouraging competition. (This figure includes out-of- court settlements in which WMI pays its adversaries what they ask but does not admit any wrongdoing.) Here are some examples: • In March 1989,WMI of California was fined $1,000,000 for conspir- ing against trade. Los Angeles'district attorney described this as the biggest criminal antitrust case in California's history.'WMI of California conspired with other haulers to eliminate competition, to not touch each others'business and to use below-cost "blitzes" to lure customers from businesses that did not go along with the trade conspirators. (10) • In October 1988, the supervisor of garbage disposal for the city of New Orleans alleged that officials of WMI's New Orleans subsidiary warned him and a colleague that they would wear "cement boots" and "meet their maker" if they persisted in investigating garbage • disposal overcharges. After investigating the allegations, the U.S. Attorney did not file charges. (9) • In October 1987, subsidiaries of WMI were fined $1,000,000 by the U.S. Justice Department for conspiring with Browning-Ferris Indus- tries—the second largest waste hauler in America after WMI—to fix prices and divide markets in the Toledo, Ohio, area. The compa- nies involved, including Waste Management of North America, also split a $700,000 fine paid to the state of Ohio. (7) • In April 1986, David Hoopengardner, the manager of WMI's Florida subsidiary, United Sanitation Services, was sentenced to two years probation and fined $10,500 for price-fixing and customer allocation (that is, illegally divvying up customers with other haulers). WMI then transferred him to a Caracas, Venezuela, subsidiary, where he could avoid having to report to probation officials. Later he was fired. (6) • In January 1988, a subsidiary of Waste Management Inc. of Florida • was fined $1,000,000 after pleading "no contest" to charges of in- volvement in a conspiracy to keep prices fixed at artificially high and non-competitive levels and for other antitrust activities. (8) This case stemmed from the same facts charged against Hoopen- gardner. • In 1983,WMI's wholly owned subsidiary, Georgia Waste Systems, was convicted of conspiring to fix prices, and fined $350,000. The company's former general manager was also found guilty and sen- • tenced to a one-year jail term, with all but 45 days suspended. WMI refused to fire the official, proclaiming his innocence. Although ac- cording to a 1981 FBI memo, illegal activities at Georgia Waste Sys- tems "were probably directed by corporate officials from the [WMI] company headquarters," the parent company and senior executives were never charged with antitrust violations. (5) The victims of these criminal activities are the people who pay WMI to take their trash away. Ira Reiner, the district attorney for Los Angeles, has said, "the crime here amounts to a theft from the public...who are pay- ing artificially high fees to have their trash hauled away. The high prices are ultimately passed along to the public." (11) .�.:. .� � /0 Records in the 1988 antitrust case that led to a $1,000,000 fine for WMI alleged that the company and other haulers in southern Florida ' "carted off more than 2.5 million dollars in the past ten years through overcharges and other suspect billings," according to newspaper ac- counts. (86) In Toledo, Ohio, where WMI was convicted of an antitrust s conspiracy and fined $1,000,000 in 1987 for price-fixing and other anti- trust violations, customers included dozens of schools and even a convent. (12) Because of these convictions and settlements, WMI and its subsidiar- ies face potential bans from eligibility in bidding on new contracts in sev- eral U.S. cities and states including Chicago, IL; Palmer, MA; and the state of Florida. Many federal, state and local laws prohibit governments from hiring or contracting with convicted criminals. The laws allow com- panies to be barred from government contracts when the company has a record of repeated violations of laws and regulations. • WMI CASE STUDY: WMI was formed in 1968 when Dean Buntrock's midwestem U.S.-based SEEDS OF waste-hauling firms, Ace Scavenger and Atlas Refuse Disposal, merged with Florida-based Southern Sanitation, owned by H. Wayne Huizenga. CORRUPTION Ace and Atlas had been accused of belonging to associations of waste- hauling companies that allegedly used strong-arm tactics against their competitors. In 1962, the State of Wisconsin filed a suit in the Milwaukee Circuit Court against 11 hauling companies and their owners for illegally re- straining competition.Dean Buntrock and his Ace Scavenger Co. were sued for allegedly engaging in a "conspiracy to restrain trade, to willingly injure the business of others, to hinder others from performing lawful acts, and an attempt to monopolize the rubbish collection, waste removal or disposal business in and around Milwaukee County."(3) Buntrock and the owners of the other ten waste haulers were jointly accused of having "threatened physical harm to the owners of competing [firms)...and their families and destruction or damage to their property and equipment, or threatened to haul all their accounts for nothing" if they competed against the accused firms. (3) The practice of"lowballing"— ,j -offering to haul wastes for such a low fee that no one can compete—is re- portedly mpetitive ind a Ater common customer has beenpractice won over, the rates can n the thenbe raised. The Milwaukee Circuit Court prescribed a temporary injunction against the accused firms, which stood for eight years. The charges were finally dismissed in 1970, after Ace and many of the other accused gar- bage firms became subsidiaries of the newly formed Waste Management, • Inc. Buntrock faced similar legal problems in Chicago, where a local trade association, Chicago Refuse Corp., was sued in 1971 for allegedly price- fixing and harassing competitors since 1965. Ace Scavenger, the WMI subsidiary, was a member of the association. Chicago Refuse paid $50,000 to settle the suit in a consent decree, which neither admits nor denies guilt. (4) Page 8 3 331.061 / CORRUPION OF WMI complements its business dealings with a massive effort seeking to THE ENEMY legitimize itself with environmentalists, politicians, and regulatory offi- cials. It has successfully used the power of money to capture the favor of potential enemies. WMI purchases goodwill through glitzy TV and news- paper public relations blitzes and through cash gifts: to Congress, where it lobbies for legislation favorable to the company; to federal agencies, where it seeks to manipulate the drafting and implementation of disposal rules;to national environmental organizations, where it seeks to gain the veneer of legitimacy; and even to local chapters of organizations like the League of Women Voters and the Boy Scouts in communities where the company wants to haul or dump wastes. POLLUTED The company and its officials have been willing to pay almost any price POLITICS for assistance from politicians. WMI and its employees have paid politi- cians hundreds of thousands of dollars annually through speaking fees, campaign contributions, "Christmas gifts," and bribes. Whenever local politicians help WMI set up shop somewhere(to expand an old dump, for example),those politicians'favorite charities soon may be receiving a sub- stantial contribution from WMI—a perfectly legal way of purchasing in- fluence at the local level and of undermining the democratic process. WMI began using the power of cash to influence politicians early in its history. Between 1972 and 1974, according to a federal Securities and Exchange Commission(SEC) investigation, a unit of WMI operated a se- cret slush fund for unlawful political contributions in Florida, and WMI or its subsidiaries gave away about $36,000 in "dubious outlays" from un- recorded cash received in the course of doing business. (13) WMI has become of one of the main corporate financiers of U.S. con- gressional campaigns in the United States. The WMI Employees' "Better Government Fund"was the seventh largest corporate political action com- mittee (PAC) during the 1988 U.S. elections, giving over $430,000 to can- didates for U.S. Congress from 1987 to 1988. (14) Untold additional funds went to politicians from WMI subsidiary PACs and directly from WMI stockholders, employees, and their relatives. In addition, WMI paid members of the U.S. Congress $57,500 for speeches and appearances in 1985, ranking tenth among corporations giv- ing such "honoraria." It once paid U.S. Representative Walter Jones of .. North Carolina $2,000 for a speech to WMI officials in which he an- nounced that he personally would oppose legislation that would delay WMI's plans to burn toxic wastes on an incinerator ship in the Atlantic . Ocean. (15) Money equals power on Capitol Hill, and,Waste Management has pur- chased substantial influence over waste policy legislation in Congress. The company's generosity to politicians is often even more obvious at the local level,in city halls and state legislatures. WMI has learned that a few thousand dollars can secure and protect disposal arrangements worth millions. • In 1988, Philip Elfstrom, the president of the Kane County, Illinois, Forest Commission accepted donations from WMI to help his bid for a National Association of Counties(NACO). Elfstrom had pre- viously claimed under oath that he never accepted donations from Page 9 Sal 064 /7- . .. ._._._- -.�e..._-......._.v,_.. _.,.,..._...._........,v..�,.��:.-, _... ...:..c.....ue�.r.r.L...-..-W:.........w�_se........-........-........:.- . 4 w. ._._....•:,a..:-i_.aYa+e.vi.. WMI. Elfstrom helps supervise a county-owned landfill operated by • WMI. (23) • Also in 1988, former Chicago City Alderman Edward Vrdolyak ad- mitted that he used WMI-owned airplanes for free flights from Chi- cago to his house in Florida. While Vrdolyak was in office, he helped ensure the siting and expansion of WMI waste dumps and a hazard- ous waste incinerator in his political district. Vrdolyak was no longer in office in 1990, but WMI continued to contribute thousands of dollars to political funds controlled by him. (24) • That same year, in Alabama, where CWM operates the largest toxic waste dump in North America, the company gave $2,500 to mem- bers of a state House committee that killed toxic waste measures dis- couraging waste shipments to the landfill. In 1985, CWM sent $500 checks as "Christmas presents" to numerous other Alabama legisla- tors. (17) • In 1986,John Horak, the general manager of a WMI subsidiary, was jailed for six months for giving $12,000 in bribes to a Fox Lake, Illi- nois, mayor and a Village Board member. Horak stated that the bribes had the approval of top WMI officials including James De- Boer, a WMI vice president. (22) • Sometimes influence comes cheap. A former Margate City, Florida, commissioner testified in court that he sold his vote on a 1979 city garbage contract to WMI for $3,000. Charges against the commis- sioner were later dismissed. (16) WMI CASE STUDY: The Chicago area, the hub of WMI's empire, has been crisscrossed by SWEET HOME WMI officials offering government officials gifts in exchange for favorable political decisions. In addition to the case involving Chicago City Alder- CHICAGO man Edward Vrdolyak(see above), other bribes and "gifts" given to Chi- cago area politicians have included: • In 1986,WMI lobbyist Raymond Akers pleaded guilty of mail fraud and of charges that he paid$6,500 in bribes to Chicago City Alder- man Clifford Kelley. Akers stated he "participated with certain cor- porate officers of Waste Management in conferring secret benefits from Waste Management to certain office holders." (21, 87) • In 1981-82,WMI gave Chicago mayor Jane Byrne $13,000 in cam- paign contributions while she extended certain WMI waste-hauling contracts. (19) • Between 1972 and 1975,WMI hired Chicago-area politician Patrick • O'Block for $55,885 to "neutralize any adverse community or politi- cal reaction" to a landfill. (18) 4 • REGULATORS Cozy relationships between WMI and the U.S. Environmental Protection Agency(EPA) have transformed the agency from one that protects the en- vironment to an advocate for the waste disposal industry. Though official policy favors pollution prevention, regulatory practices focus solely on Y Page 10 931061 S . • waste control, encouraging a bull market for waste disposal companies. In many cases, these regulations have been authored by EPA officials who later turned to WMI for lucrative, post-governmental employment. Anticipation of these positions also encourages the EPA to circumvent public accountability and scientific evidence in favor of industry in waste disposal siting battles throughout the country. At least seven former top EPA officials have been hired by WMI and CWM. For example, Walt Barber, a CWM vice president, once was the acting administrator of EPA; Gary Dietrich, a WMI consultant, once helped write solid waste disposal regulations for the EPA's Office of Solid Waste;Jeffrey Miller, a WMI attorney, once directed EPA's enforcement division; and Joan Bernstein, a CWM vice president, once was EPA's Gen- eral Counsel. WMI CASE STUDY:The public policy impact of this "revolving door" between EPA and WMI EPA & CWM was clear in the early 1980s, when well-placed CWM employees helped write EPA's ocean incineration and liquid waste disposal permits. In Oc- WORK HAND tober 1981, the EPA issued a permit for a series of"research" bums of IN GLOVE millions of gallons of PCB wastes aboard CWM's incinerator ship, Vulca- nus I. It was later learned that CWM lobbyist Scott Clarkson helped write the research permit. One EPA official said, "CWM wrote the per- mit. There was no research protocol." (25) At the same time, an attorney for CWM,James Sanderson, was in a perfect position to influence EPA agency decisions. He worked as Special Assistant to EPA Administrator Anne Gorsuch from March to July 1981 and from October 1981 to June 1982. Before,between, and after his em- ployments at EPA, Sanderson was an attorney for CWM in Colorado. Sanderson quit EPA in June 1982 after senior White House officials re- portedly urged Gorsuch to fire him for unethical conduct and potentially criminal conflict-of-interest violations. In February 1982, after Gorsuch lifted a ban on dumping liquid wastes in hazardous waste dumps across the country, CWM dumped 2,491 barrels of liquid hazardous wastes in its Colorado toxic waste landfill. CWM had "stored" 1434 of the barrels in disposal pits at the Colorado site in anticipation of Gorsuch's ruling. (26) WMI AND The "revolving door" to WMI's corporate riches is open even to environ- ENVIRONMENTAL mental groups in the U.S. As with regulatory agencies and politicians, many "environmentalists" have established close relationships with WMI GROUPS in exchange for cash. WMI's corporate "grants" to environmental and conservation groups to- taled more than $892,000 between 1987 and 1989. (27) In turn,WMI's association with a variety of large environmental groups serves to im-' prove the company's public profile and to disarm its potential opposition. The company has given the following environmental groups $50,000 or more in grants since 1987: National Audubon Society($110,000) National Wildlife Federation($102,500) Page 11 / .`3 71.06? 1$ • The Nature Conservancy($70,000) • International Union for the Conservation of Nature ($51,000) World Wildlife Fund/Conservation Foundation ($50,000) • Some groups even have WMI executives on their board of directors. In 1987, the National Wildlife Federation(NWF)elected WMI's chief execu- tive officer,Dean Buntrock, to its Board of Directors. Alexander Trow- bridge, a director of WMI, serves on the U.S. national council of the World Wildlife Fund. Waste Management president Phillip Rooney sits on the Board of Directors of the National Audubon Society. 4 Fortunately, not all environmental groups have allowed themselves to" be infiltrated by WMI. For the past few years,WMI has been trying to gain acceptance as the first for-profit member of the Environmental Grantmakers Association (EGA), a three-year-old association of about 90 foundations that help support many environmental activist groups in the U.S. When WMI Environmental Affairs Director William Y. Brown was in- vited to EGA's 1988 meeting, several grantmakers refused to participate. Finally, in 1989,-the EGA voted to disqualify WMI from membership, cit- . I ing corporate practices "contrary to the Association's fundamental goals and aspirations....It is readily apparent thatWMI has engaged in a pat- tern of abusive corporate conduct involving repeated violations of both criminal and civil laws, with the effect of endangering and degrading the environment." (29) Similar rejections came from a church and a citizens' group in CM- -t cago's economically poor southeast side. In the spring of 1987, St. Kevins Church and the United Neighborhood Organization rejected WMI's offers to donate food for the hungry because the offer was perceived as an effort to buy off community opposition to the company's waste disposal opera- tions. St. Kevins Church is located near a pollution-plagued hazardous waste dump and incinerator operated by WMI. (30) - The purpose of WMI's "generosity" is perhaps best described by WMI executive Joseph Jack. After WMI distributed over $25,000 in scholar- ships to 115 southern Florida high school students,Jack explained, 4 "When they grow up,they can't say anything nasty about Waste Manage- ment because maybe we made it possible for them to go to college." (31) y6y WMI CASE STUDY: The value of such ties to environmental groups became clear last year THE NATIONAL when National Wildlife Federation president Jay Hair set up a breakfast 1 meeting between WMI and EPA Administrator William Reilly; sub- WILDLIFE sequently Reilly reversed national policy, taking aggressive steps to pre- FEDERATION vent states from enacting environmental regulations that are more stringent than federal rules, an effort later overruled by a judge as violat- MEDIATES ing basic legal principles. In March 1989, Hair arranged a breakfast meeting between Buntrock FOR WMI and Reilly with the stated purpose of discussing the national implications of a recent decision by North Carolina's state government to restrict waste dumping into rivers and streams. Hair's invitation to Reilly read: "Bill—if at all possible I would like to arrange a breakfast meeting with you, Dean Buntrock and myself to discuss [the] national implication of' the North Carolina situation. WMI prepared a briefing paper for Reilly, Page 12 Q_ �+ •7�a.�r1.;/�!!V /5` G 1 Impairment Liability insurance coverage, the Company's net income I could be adversely affected." (34) 3 One U.S. EPA official has estimated the potential cost of"cleaning up" WMI's contamination at over 2.4 billion dollars. (35) Investors, too, fear the long-term financial threats inherent in the con- taminants released by WMI's landfills and incinerator stacks. In 1985, a federal court approved an $11.4 million settlement of a suit filed by WMI shareholders. The shareholders charged that WMI had failed to disclose potential liability arising from "investigations, complaints, enforcement actions, and other suits" relating to the firm's toxic waste handling opera- tions. In 1990, an investment analysis firm quoted in Fortune magazine gave WMI its worst environmental rating. (36) Waste Management's promises of"safe management of wastes using state-of-the art technologies" have already been disproved by the escape of pollution from its disposal facilities. WMI's disposal methods range a from shooting poisons into the sky (incineration), heaping wastes to- ' gether in a pile (landfilling), and pumping them into the earth(deepwell injection). All of these disposal methods have one thing in common: they are guaranteed to contaminate the earth's life support systems—air, water, and soil. , _ a } i 4 "BURN AS SI MULE" United Stat often eos "state-of-the-art" incinerator.ints to its hazardous waste The Chicago Chicago ner for is AS POSSIBLE one of largest commercial hazardous waste incinerators in the U.S., burning an estimated 32,000 tons of toxic waste annually. (37) In 1988,the Illinois State Environmental Protection Agency called for a temporary closure of the incinerator because operators frequently and deliberately disconnected pollution detectors in the incinerator stack. (38) In 1990, CWM paid a$3,750,000 penalty—one of the highest EPA Hazardous Waste fines ever in the U.S.—for numerous violations at the Chicago incinera- tor. Among the crimes that EPA found: failing to monitor emissions and failing to halt PCB waste incineration when scrubbers and stack moni- z tars were not operating. There may have been many violations that EPA 4 missed; one former worker at the incinerator reportedly said that"break- ing regulations was more the routine than the exception." According to newspaper reports, the operations manager of the incinerator had a favor- Ili ite phrase: "Burn as much as possible." (39) a Pollution problems are not confined to the incinerator stack. In May 1990, the Chicago Metropolitan Water Reclamation District revealed that 1 CWM repeatedly violates its water discharge permit, exceeding discharge limits for mercury, lead, copper, zinc, and PCBs. In 1988, CWM was 7 fined $18,240 for groundwater contamination and groundwater monitor- ng problems at the Chicago incinerator. Spills of toxic waste are com- mon on plant property, and toxics are leaking into the city's sewer system. (40) In February 1991, an explosion at the Chicago incinerator blew a door s off the machine, releasing an unknown quantity of hazardous waste into the outside air. In a letter to WMI, the Illinois Environmental Protection Agency(IEPA) said it has "serious concerns" about continued operation of the CWM incinerator. State officials cited the inadequacy of the facility's Page 14 331.061 ,, which asked him to"emphatically restate [EPA] opposition to these states actions" by threatening to withdraw North Carolina's authority to legislate hazardous waste policy. One month after the March 16, 1989 breakfast meeting, Reilly an- nounced that EPA would re-open hearings on whether to withdraw North Carolina's hazardous waste disposal authorization. NWF's Hair has frequently denied any role in Reilly's decision, and publicly opposed it. However,EPA's Reilly expressed surprise,that Hair opposed the North Carolina hearings, because "Jay Hair hosted the [March meeting with Buntrock] at which I was lobbied to do the very thing that we are doing." An investigation conducted by the EPA inspec- tor general,John C. Martin, was itself called into question by J. Richard Wagner, an official in the EPA inspector general's office. The Oversight and Investigations Subcommittee of the House Energy and Commerce Committee opened an investigation into the matter, but their investiga- tion was never completed. (28) POLLUTING While WMI is integral to the U.S. government's strategy of ensuring plen- FOR THE tiful waste disposal capacity,public concern over pollution has forced regulators to appear to be penalizing the polluters. Government agencies MODERN have fined WMI repeatedly for violations of environmental regulations. These fines do not reflect the true cost of damage done to the environ- INDUSTRIAL meat by the company's disposal operations, nor do they reflect the profits ECONOMY made from such violations. However, the frequency of these penalties shows that,even under a permissive regulatory climate,WMI's crimes are so obvious that government officials cannot avoid penalizing their friends. WMI has thus set the U.S. record for environmentally related penal- ties and settlements in the 1980s. Greenpeace estimates that since 1980, WMI has paid over $45,000,000 in fines, penalties, and out-of-court settle- ments for admitted and alleged violations of environmental laws at its dump sites. At least 45 WMI waste sites have been found out of compliance with federal or state environmental regulations. At least five WMI sites have closed. At least ten WMI dump sites have contaminated groundwater. By the end of 1989,WMI was listed as a Potentially Responsible Party at 96 sites on the U.S. Superfund National Priority List, while its subsidiary Chemical Waste Management was listed for 25. Although WMI claims these are problems of the past, there are no signs that pollution violations are decreasing at WMI dump sites. Accord- ing to newspaper reports, WMI was issued at least 547 citations and or- ders for pollution violations between 1980 and 1983. Between 1984 and 1987,this number reportedly increased to 632. (33) Statistics such as these drive insurers away from WMI and from all others in the waste business. Because of the company's potentially disas- trous operational deficiencies,WMI has operated without meaningful out- side liability insurance for its hazardous waste sites for years. This could impact the company's long-term viability. In a 1990 report to the Securi- ties and Exchange Commission,WMI admitted that if"the Company con- tinues to be unsuccessful in obtaining risk-transfer Environmental Page 13 ea waste analysis plan. More importantly, IEPA said that on "several occa- sions" IEPA officials investigating the explosion were "refused informa- tion" about what chemicals were being burned at the time of the explosion. Furthermore, the IEPA charged that WMI had made "inaccu- rate statements".when WMI said they had reported the explosion to the Illinois Attorney General's office. (83) Another major CWM toxic waste incinerator is located in Sauget, Illi- nois. Dirty operations there, too, have forced the state to fmn CWM for environmental violations. In February 1990, Illinois fined CWM $250,000 for operating the incinerator for four days without a stack gas hydrocarbon monitor and for other violations, such as burning waste faster than permitted. (41) Operations began at CWM's newest incinerator, in Port Arthur,Texas, this year. CWM plans to eventually burn three times the waste at this fa- cility than at any other CWM incinerator complex. CWM is trying to build or purchase hazardous waste incinerators throughout the U.S.—in Alabama, California, Georgia,Kentucky, New York, North Carolina, Ohio, Oregon, and Tennessee. (42) .WMI's rush to burn toxic wastes in incinerators across the country fol- lows its failed, hard-fought attempt to burn toxic wastes at sea in a flo- tilla of incinerator ships. WMI would have preferred to avoid local community battles and burn industry's wastes at sea, out of public view. .The company's limited and now-extinct ocean incineration program in the U.S. and its nearly extinct incineration of wastes in the North Sea prove that even in the middle of the ocean,WMI cannot avoid opposition to the severe environmental impacts caused by its disposal operations. Strong evidence of pollution from incinerator ships led the world's govern- ments, under the London Dumping Convention, to collectively ban ocean incineration by 1994. Household and WMI is also constructing a national network of incinerators to burn gar- bage and medical wastes. WMI recently purchased control of the largest p garbage incinerator firm in the U.S., Wheelabrator Technologies, and hopes to burn garbage in 80 incinerators on land adjacent to its garbage landfills. It's a marriage made in heaven: 30 percent of the waste that goes into an incinerator comes out as a toxic ash, which no one wants bur- ied nearby. WMI's control of so many landfills makes ash disposal from Wheelabrator incinerators a natural. At least 10 garbage incinerators in the U.S. are currently operated by WMI and Wheelabrator. (43) WMI refers to its first garbage incinerator,built in 1986 in Tampa, Florida, in the same manner as its hazardous waste incinerator in Chi- cago: "state-of-the-art." Sadly, the state of the art is not good. The Tampa incinerator has been plagued by air emissions, toxic runoff from incinerator ash, and financial disappointment for the city of Tampa. The Florida Department of Environmental Regulations has ordered WMI to prevent toxic ash runoff from flowing into a ditch that runs into the Gulf of Mexico. As in Chicago, operators of the Tampa incinerator were reluctant to turn on pollution control equipment. For 17 months,WMI refused to op- erate air pollution control equipment when turning on the furnace. (44) Page 15 C, s_ nip /5 ".er;�,,, Medical waste incinerators, like garbage burners, routinely discharge extremely toxic dioxins, furans, lead, and mercury into the atmosphere. They also emit small amounts of radioactive waste. Incineration pre- cludes more environmentally benign medical waste disposal options such as steam sterilization, and discourages the implementation of programs to separate infectious wastes from harmless, recyclable hospital waste streams. (Infectious waste generally represents just 15 percent of the waste that is burned in medical waste incinerators). (45) WMI operates at least seven medical waste incinerators, a dh plansve to own a total of 18 in the U.S. (46) In this field, too, op n troubled. In-March 1989,state of Ohio inspectors uncovered three environmen- tal violations at WMI's medical waste incinerator in stoa Jackson age Township, Ohio. Potentially toxic runoff was draining off the incinera- tor dust was blowing out of containment boxes, and the incinerator was operating without a valid solid waste disposal license. (47) Shortly after WMI signed a 10-year lease from the city of Terrell, Texas, for an old idle incinerator, it ran into numerous legal problems. In October 1988,the Texas Department of Health opposed WMI's attempt to burn infectious waste in an incinerator that had not previously inciner- ated such waste. WMI began burning medical waste, without a valid air permit,on October 12, 1989. By December 1989,the Texas Air Control Board ruled that WMI could operate the facility, though not on a full- time basis. (48) "S AVING A HELL Loopholes in U.S. hazardous waste regulations have made deep well injec- tion the cheapest and most poorly monitored waste disposal method. De- OF A LOT spite little understanding of the long-term fate and effect of chemicals in OF MONEY" geological formations, waste disposal companies drill a deep hole in the earth and inject huge quantities of pressurized waste into underground layers of permeable rock. Injection wells are known to have caused groundwater contamination, well blow-outs, and even sizeable earthquakes. Leakage and geologic events will become more likely as time passes and wastes migrate further from injection wells. Deep Well Despite these environmental hazards, legal loopholes in U.S. waste dis- posal laws have allowed CWM to inject millions of gallons of extremely Injection hazardous wastes into the earth, particularly in Ohio and Texas. Since 1982, CWM's Corpus Christi,Texas, toxic waste injection well has been found to be in violation of environmental laws in 10 of 18 inspec- tions by the state of Texas(49). Near the coast of Lake Erie, in Vickery, Ohio, CWM operates an infa- mous.toxic waste storage, disposal, and deepwell injection facility.* In 1983, an estimated 40 million gallons of industrial wastes leaked from the well shaft, above the injection wells, at depths prohibited by law. (51) In 1986, an Ohio University professor predicted that continued deep well injection at,Vickery "will to a reasonable degree of professional certainty cause an earthquake within the area of the Vickery site." (52) In 1990, a class action lawsuit by local residents against the Vickery injection well was ally settled. n what is described by attorneys as the largest settlementl ever awarded in the U.S. related to a hazardous • 1 Page 16 � �..061 /9 waste disposal site,WMI agreed to pay $15,000,000 to property owners and their attorneys. However,under terms of the settlement, local prop- erty owners are forbidden from "objecting to migration[of toxics from the deep well] in any forum," and even their heirs are not allowed to make any legal claims regarding damage from such migration. CWM could not buy every Vickery citizen's silence, however:William Warner, one of the original plaintiffs,rejected the agreement, stating that he refuses to sell his human rights to the company. (53) LANDFILLS The U.S. Environmental Protection Agency recently reported that "there is good theoretical and empirical evidence that the hazardous constitu- ents that are placed in land disposal facilities very likely will migrate from the facility into the broader environment. This may occur several years, even many decades, after placement of the waste in the facility, but...it will occur eventually."(56) WMI's toxic waste and garbage land- fills are no exception. All landfills leak. There is no such thing as a se- cure landfill. "A TALE OF Over the past century, dumping hazardous wastes in landfills has be- 'IWO BOOKS" come an industrial tradition. Now, hazardous wastes are being exhumed from hundreds of leaking landfills across the U.S. and shipped to newer landfills across the U.S. under the Superfund program. WMI is responsi- ble for many of these sites, both those that are being unburied, and those that are receiving Superfund wastes. Most of CWM's dumps receiving Superfund and other hazardous wastes have begun to show signs of leak- age. Others are already closed, such as CWM's toxic waste dump in Lowry, Hazardous Waste Colorado. The Lowry landfill has been closed since 1982, when CWM em- Landfills ployees tried to hide a major toxic waste leak. According to two employ- ees, Lowry's general manager instructed them to keep two sets of books: one of them a black colored logbook to be shown to inspectors that did not reveal the leak, the other a yellow colored log that did record the leak but was not given to inspectors. (57) CWM currently operates seven hazardous waste landfills in the U.S., including the one at Emelle,Alabama, one of the world's largest. Since 1978, CWM has dumped over five million tons of toxic wastes on what was once lush farmland in remote rural Alabama. In 1989 alone, Emelle received 790,000 tons of wastes from 42 U.S. states and U.S. military bases abroad. (58) 'Deep well injection is not the dirtiest disposal method employed by CWM in Vickery, Ohio. Between 1980 and 1983, CWM illegally dumped PCBs and dioxin-contaminated wastes in open lagoons. Worse,the company mixed PCB wastes with waste oil at Vick- ery, and then sold over six million gallons of the toxic concoction as"heating oil"to unsus- pecting Midwestern oil customers.(54) The U.S.EPA eventually penalized CWM$2.5 million for these violations,but it is estimated that WMI saved over$20 million by selling the PCBs rather than disposing of them. William Sanjour of the U.S.EPA's Office of Solid Waste says that the agency"never really made a strong effort to find out where[the toxic oil)went. By doing so,they saved Waste Management a hell of a lot of money. All of those buyers could have sued."(55) Page 17 CWM's Emelle dump has experienced on-site fires, off-site water con- tamination, and over two million dollars in penalties for environmental violations. PCBs have been found in wetlands near the dump. (59) In 1989,mounting evidence that the Emelle landfill would soon con- taminate a major aquifer inspired the state of Alabama to try to ban waste imports from states that do not have their own hazardous waste disposal facilities. (Less than 25 percent of the wastes dumped in Emelle are generated in Alabama.) In 1990,Alabama Governor Guy Hunt pro- posed raising the state tax on out-of-state waste imports to $116, to end Alabama's status as "the waste dumping ground of the nation." (60) It is not a coincidence that the Emelle dump site is located in a remote community, many of whose residents—primarily African Americans— live in poverty. Toxic waste is generally dumped on those with the least economic and political power. According to a local official, when the dump's original developers first announced that they were opening a facility in Emelle in 1978, residents were told that "they had found a new use for the Selma chalk...and we thought it was going to be some kind of liming operation. And lo and be- hold, the use they found for the Selma chalk was the holding of chemi- cals." (61)And "lo and behold," the rate of unemployment in surrounding Sumter County rose from 5.6 percent in 1978 to 21 percent in 1986 as clean industry left and plants shut down. (62) It is probably also more than mere coincidence that WMI's second larg- est toxic waste dump(and the fifth largest in the U.S.)is located in Ket- tleman Hills, California,a small, remote community of primarily Spanish-speaking farm workers.* In 1988,the Kettleman Hills dump suffered a toxic landslide. As CWM wrote,"We encountered an unfortunate incident in one section of • our...Kettleman Hills facility. For an as yet unknown reason, part of the landfill's liner system pulled away from its anchor on March 19." Accord- ing to CWM, the accident caused "extensive damage" to the landfill's top liner and its leachate collection system. (65) In 1989, the state of California fined CWM $82,500 for eleven viola- g. tions of environmental regulations, including failure to report a fire and discrepancies on written records for weight and volumes of wastes re- ceived. That brought the total amount of fines, penalties, and settle- ments paid by CWM for its Kettleman Hills operations to over $4,000,000. (66) Similar histories of fines and evidence of groundwater contamination are evident at other WMI/CWM toxic waste dumps in•Port Arthur,Texas; Carlyss, Louisiana;Arlington, Oregon;Joliet and Calumet City, Illinois; and Furley, Kansas. • *Another alleged form of racial exploitation at a WMI-owned toxic waste disposal site: In 1989,four CWM employees and one former employee at the Carlyss,Louisiana,toxic waste dump sued CWM for racial discrimination in hiring and promotion practices.One worker claims he was harassed by CWM officials, another says that his firing was racially motivated and that co-workers verbally abused him with racial slurs.(64) 1 Page 18 321O 44 WE ARE A WMI is also capitalizing on the growing and lucrative "low-level" radioac- HICK TOWN IN tive waste disposal market in the U.S. This type of waste includes danger- ous radionuclides generated by commercial nuclear power reactors, THE MIDDLE industry, and research and medical institutions. Wastes dumped in "low- OF NOWHERE" level"radioactive waste dumps range from radioactive animal carcasses and contaminated clothes to radioactive hardware and pipes, resins, and sludges from nuclear reactors. Radioactive The largest "low-level" radioactive waste service company in the coun- try, CWM's subsidiary, Chem-Nuclear Systems, Inc. (CNSI), operates one Waste Landfills of three licensed commercial "low-level" radioactive waste dumps in the U.S., in Barnwell, South Carolina. Like most of WMI's network of hazard- ous waste landfills, the Barnwell dump is leaking. In 1982, a U.S. Geo- logical Survey report found that radioactive tritium is migrating "downward, outward and upward from the buried waste." The survey re- ports contamination of water beneath the buried waste, including tritium levels 100 times higher than background levels. (67) The Barnwell dump is expected to close before the end of 1992. By then, Chem-Nuclear hopes to open at least four new radioactive waste dumps (in Connecticut, Illinois, North Carolina, and Pennsylvania) un- der the Low Level Radioactive Waste Policy Act, which encourages the construction of regional radioactive waste dumps across the country. Chem-Nuclear also operates a nuclear waste compacting station in Channahon, Illinois. The station began operation in January 1987, with- out WMI informing local residents, including the mayor. "The whole thing that is upsetting to us here is that we are a hick town in the middle of nowhere, and they think they can dump on us," said the town's mayor. The U.S. Nuclear Regulatory Commission agreed that the company may not have adequately informed the Channahon police and fire depart- ments about the presence of low-level radioactive waste. (68) In 1990, an Illinois Senate Executive subcommittee accused WMI and state officials of secretly agreeing to relocate Chem-Nuclear's supercom- pactor to Martinsville, Illinois. The "confidential side agreement" also al- lows Chem-Nuclear to expand planned operations at a proposed regional nuclear dump in Martinsville. CNSI denied the agreement existed before the state acknowledged its existence. The director of the Illinois Depart- ment of Nuclear Safety was fired over the incident. (69) GARBAGE At the beginning of 1990, WMI operated 127 landfills for household gar- DUMPING AND bage in North America. The U.S. EPA has warned that household waste landfills "have degraded and continue to degrade the environment." (70) WMI'S SHAM Contamination at almost 200 garbage dumps has been so severe that RECYCLING they have been declared Superfund sites. WMI is a partially responsible party for the Superfund "cleanup" of at least 15 garbage landfills. EFFORTS Because of its track record, WMI's subsidiaries use a variety of lanfill- siting strategies. In some instances,WMI will mask its identity as a subsidiary whose ties to the parent company are not well known. Another strategy is to have an existing local operator develop a new landfill and then hand it over to WMI for a fee. Old landfills are often relatively cheap because they are leaking or otherwise in trouble and no one wants the associated liabilities. WMI promises local officials it will clean i- the mess if it receives authority to reopen, or keep open, a troubled landfill. Page 19 331O6". 4 • Under these circumstances, local officials have little choice. If they re- fuse, the WMI subsidiary can seek to develop its own competing landfill, while pressuring government officials to close down the existing dump in order to gain a monopoly on dumps in the area. Gaining control over dis- posal capacity—landfills and incinerators-is key to the company's mo- nopolization strategy. When it comes to privatizing municipal garbage disposal services, some officials worry that there will be no way to control prices on a long- term basis and control what goes into a landfill. Local officials have little say over who dumps waste once a landfill is turned over to private opera- tors. Even though a private waste company like WMI may relieve public officials of short-term political headaches when they monopolize dumps in the area, the responsibility will still return to the community in the form of contributions to a superfund site (for which they may be held li- able as waste generators)or directly to taxpayers, who usually foot the bill for dump cleanups. As always, WMI continues to claim their latest landfill designs are "state-of-the-art,"by which they mean they won't leak. It's difficult to prove a dump is leaking while it is in operation; the enforcement system is based on company self-monitoring. (Despite this, WMI has admitted that at least 10 of its dumps have contaminated groundwater.)The com- pany's incentive for making sure its dumps appear to be leakless is based on transferring its liabilities to future generations: once the period of the company's financial responsibility for dumps expires (usually 30 years of ter a dump closes), taxpayers foot the bill for cleanup. WMI plans to open 60 new garbage dumps and many new garbage in- cinerators. These new landfills and incinerators will not just contami- nate our drinking water and air, their availability will discourage real solutions to the garbage crisis: the reduction in the toxicity of garbage, and the implementation of maximum waste recycling, composting, reduc- tion, and reuse programs. U.S. television networks often air advertisements that portray WMI as the country's leading recycler. Yet very little recyclable waste handled by j WMI is ever recycled. In 1989,WMI hauled away recyclables for recy- cling from just 16 percent of their household customers. A recent article in Business Week explains the importance of WMI's small but highly visible recycling program: "even though recycling has yet to turn a profit, it's working...to pull in business for WMI's landfill op- erations, which boast a pretax profit margin of 20%." (72) WMI probably has not invested more heavily in recycling because it gets people thinking about pollution prevention and waste reduction—direct threats to the company's revenue, which is generated almost entirely from waste dis posal. - Currently, the U.S. recycles about 13 percent of its solid waste. The EPA has set a national goal of 25 percent reduction in the waste stream through recycling. New Jersey has set a goal of 65 percent. Studies by in- stitutions such as the Center for Biology of Natural Systems in New York have shown that between 70 and 90 percent of the household waste stream can be eliminated through an intensive recycling, composting, and waste reduction program. WMI officers, such as William Hulligan, president of Waste Management of North America, claim that only 10 to 20 percent of household waste can be reduced through recycling. (73) Even where Recycle America and Recycle First(WMI and Wheelabra- tor's recycling divisions)operate extensive recycling programs, the corn- 1 ,Page 20 S3106t �c'3 pany has not eliminated the use of landfills and incinerators. For exam- ple, in San Jose, California, where it runs a showcase recycling program, WMI continues to heap garbage in a leaking dump in a canyon occupied by an endangered type of butterfly. (74) WMI says they have taken steps to preserve the butterfly; the dumping continues and time will tell. In March 1991, the Arkansas Gazette reported that heavy lobbying by WMI and BFI derailed part of Governor Bill Clinton's package of garbage and recycling bills. The paper quoted Representative Byrum Gibson (sponsor of the bills)saying, "We all know what will happen if those bills don't pass. BFI and Waste Management will be the two czars of the state in five years, and we'll pay whatever garbage fees they want us to pay." (84) Aware of WMI's motivations and history of operations, communities like Oak Park, Illinois, have chosen alternative contractors over WMI for city recycling contracts. The city of Tamarac, Florida, turned down WMI's offer to handle residential recycling "because of uncertainty of the fairness of the proposed pact."WMI's subsidiary, Recycle America,was also blocked in its attempt to take over a Montevallo, Alabama, church- based recycling program. (75) Waste Management's new image as a recycler should not, therefore, be confused with a sincere desire to reduce household waste. Nor should anyone be fooled by CWM's Waste Reduction Consulting Services divi- sion, which does next to nothing to prevent the production of waste by in- dustry. According to one industry analyst, CWM's Waste Reduction Consulting Service"tends in the balance to result in more waste for [CWM]facilities." (85) True "toxics use reduction" does not mean shifting toxic exposures be- tween workers, consumers, and various segments of the environment. True "taxies use reduction" means changing raw materials, products, and production processes to avoid the use of toxic substances. CWM's Waste Reduction division focuses entirely on the reduction of hazardous waste after it has been produced by an industrial plant. For example, it advises companies to divert wastes from a deionizing waste- water treatment process and dump them directly into the sewer, instead of into a treatment plant. (76) CWM also recommends, and engages in, shipping toxic solvent wastes to cement kilns where they are burned as fuel. Federal regulations allow waste generators to reclassify solvent wastes as "recycled" when deliv- ered for blending as a supplemental fuel for cement kilns. This sham "re- cycling" loophole in federal law has transformed the cement manufacturing industry into a major disposal point for toxic wastes. Ce- ment kilns "recycle" (by which they mean burn)three billion pounds of toxic wastes annually. (77) Since 1988, CWM has become a supplier of solvent waste fuel for many cement kilns in the U.S. and for a WMI-owned incinerator in Mex- ico. The company's West Carrollton, Ohio, solvent fuel blending plant re- ceived over 108 million pounds of chlorinated solvent wastes from 26 states in 1989. CWM currently operates fuel blending facilities in New- ark, New Jersey;Azusa, California; Henderson, Colorado; and Tijuana, Mexico. CWM's hazardous waste landfills in Alabama and Chicago also ship solvents to cement kilns. (78) Page 21 L 3:'..-1.06.1 A THE EMPIRE WMI is diversifying rapidly into operations such as asbestos removal EXPANDS (Brand Companies)and Superfund site remediation(ENRAC division), whose profitability takes advantage of the historic failure of industry to reduce waste and convert to the use of safe materials and clean technolo- gies. WMI is also going into such industries as the lawn pesticide busi- ness, a business whose entire existence is sustained through the unnecessary and harmful dispersion of chemicals. WMI is also quickly expanding from North America to the rest of the world. Waste Management's International division now accounts for 10 percent of the company's total revenue. Thomas Smith,WMI's manager of Far East business development, has predicted that Asia will replace North America as the biggest WMI customer within 20 years. WMI has entered into a partnership with a ministerial-level investment wing of the government of China in a bid for a chemical waste plant in Hong Kong. (79) This is not the first time WMI's search for profits across the globe have taken precedence over concerns for human safety and human rights. In 1979, during the height of Argentine government-sponsored "disappearances"of thousands of political dissidents,Waste Management took advantage of the country's move to privatize services by entering into a ten-year municipal contract to haul garbage in Buenos Aires. Dean Buntrock,WMI's chief executive officer, commented at the time that the contract with the city "reflects the pro-business policies of the federal government which have created an attractive atmosphere in Ar- gentina." (80) WMI's biggest current expansion is in Europe. An investment firm re- cently reported that WMI "has grown its European business from $35 mil- lion to $500 million annually over the past two years." WMI expects that its 1990 European revenues will exceed $700 million. By May 1990, WMI held contracts in more than 325 European communities. (81) The company is establishing major operations in Sweden, the Nether- 4 lands, Spain, France, Germany, England, and Italy. WMI operates a haz- ardous waste incinerator in Moerdijk, Netherlands. It is trying to gain control over the French waste management firm, PEC, whose subsidiary, Tredi, operates five incinerators in France. WMI is also believed to be trying to take over Italy's largest waste-hauling company, SASPI, which would give WMI 55 percent of the Italian garbage hauling market. (82) 41 FIGHT THE Greenpeace and other environmentalists and community groups around POWER THAT the world are fighting WMI with ever-increasing success as the com- pany's dismal track record—and the fundamentally destructive nature of POLLUTES all its technologies—is revealed. It is our hope that this report will help generate even more success in blocking WMI and other companies' at- tempts to site new disposal facilities. The following is a list of just a few of the places where, since 1988, a combination of knowledge of WMI's troubled history, combined with com- munity pressure, forced WMI to cancel plans to burn,bury, or store haz- ardous wastes and garbage: 1 Page 22 -_1,15 Douglas County,Colorado Dallas County,Missouri Nobel County,Indiana Rapid City,South Dakota Anchorage,Alaska Stickney,Illinois New York City Pike County,Mississippi Palmer,Massachusetts New Orleans East,Louisiana Calumet City,Illinois Blairsville,Pennsylvania A well-informed, firmly entrenched group can keep WMI's unsafe op- erations out of a community. These groups have proven that WMI is vul- nerable. Grassroots groups across the continent have publicized WMI's sorry history, used civil disobedience, and forced authorities to enact local ordinances to prevent this company from entering their community. Greenpeace, the Citizens' Clearinghouse for Hazardous Wastes, and many well-organized grassroots groups can help you learn how to organ- ize such a group. We hope this report will aid community groups, enforcement officials, and public employees across the world in their decisions about dealing with WMI. THE END? This abstract is incomplete and has no ending—because there is no ap- parent ending to the company's assault on the global environment. At the same time, there is a growing movement for environmental justice around the world, and a growing sense that things can and must change before it's too late. Please send us your information about the company and your success in stopping its efforts to expand, so we can help complete the story. Send information, with complete references (including page numbers) to the ad- dress listed below. The full report, Waste Management, Inc.:An Encyclopedia of Environ- mental Crimes and Other Misdeeds, will provide citizens with dozens of pages of facts, figures, and stories about the world's largest waste hauler. To receive a copy, please send $20.00 to: Information Services, Green- peace USA, 1436 U Street. N.W.,Washington, DC 20009 • ;r Page 23 f ia. a.•. [4.�auiriiYw.iM, OTHER Other excellent sources of information about Waste Management Inc. in- SOURCES dude: Waste Management Inc.:A Corporate Profile,published by the Citizens'Clearing- house for Hazardous Wastes in 1988. This manual is designed to arm citizens with information needed to fight WMI in every community. The report is available from CCHW,P.O.Box 8606,Falls Church,VA;telephone:(703)237-2249. See also,'There Ought Be a Law,"by Brian Lipsett and Will Collette,an article about'enacting con- tract crimes ordinances in your community,in the June issue of"Everyone's Back- yard." Each issue of"Everyone's Backyard"covers the latest in WMI follies, misdemeanors,and crimes. The newsletter,Rachel's Hazardous Waste News,edited by Peter Montague. Available from:Environment Research Foundation,P.O. Box 73700,Washington, DC 20056-3700. Subscription rate:$40 per year for individuals and citizens groups; $15 for students and seniors. • A series of articles about WMI and Browning-Ferris Industries by the Ft. Lauder- dale News/Sun-Sentinel. A news-magazine edition of the series,titled The Titans of Trash,was published by the newspaper in December 1988. d ' For the early history of the waste-hauling industry,including the birth and growth of WMI and BFI,see Harold Crooks,Dirty Business:The Inside Story of the R New Garbage Agglomerates .Toronto,Canada:James Lorimer&Co.,1983. Contact 1 the Canadian Union of Public Employees,John Calvert,Research Department,21 ' A Florence St.,Ottawa,Ontario,Canada K2P OW6. For more information about WMI's garbage incineration subsidiary,Wheela- brator Technologies,see: Waste Not,a weekly publication of Work on Waste USA, Inc.,82 Judson,Canton,N.Y. 13617, (315)379-9200,and Robert Collins,Bad Deals and Broken Promises:A Survey of Wheelabrator's Performance. Washington,DC:Clean Water Fund, September 1989. Copies are available from Clean Water Fund, 1320 18th St., g N.W., Washington,DC 20036, (202)546-6614. j i 1 t a NOTES 1.Waste Management Inc.,"Company Fact Sheet"Oak Brook,IL:Waste Manage- ment,Inc.,1990. Sulam,Mark."Waste Services Industry Review."New York,NY: Kidder Peabody Equity Research,June 27,1990. Vishnu Swarup,'Pollution Control Industry."New York,NY:Prudential-Bache Securities,July 1989,p.3. 2.Trillin,Calvin."Uncivil Liberties."The Nation May 28, 1988,p.738. Associated I Press."Waste Company Chief Highest Paid Executive in State at$8.5 Million."Mt. s Vernon IILI Region-News May 15,1989,p. 1. 3. Wisconsin v.Acme Disposal Service Corp.,Complaint(Cir.Ct.Wis.Sept.28, 1962). 4.Bremner,Brian."Waste Management:A Rogue,or a Star?" Crain's Chicago Busi- ness October 12, 1987,p. 1.Crooks,Harold.Dirty Business:The Inside Story of the New Garbage Agglomerates .Toronto,Canada:James Lorimer&Co.,1983.Schulte,Fred. "Laws Provide Little Deterrent to Price Fixing[in'Titans of Trash' series]."Ft.Lauder-, - dale Sun-Sentinel December 7,1987,p. 1. 5.Culp,Guterson,et al."Report on Charges and Claims of Corrupt Practices,Price Fixing,Violations of Environmental Standards at landfills,etc."presented to Seattle City Council,November 16,1989,p.38. Available from:Culp,Guterson,27th floor, 1 Union Square,600 University St.,Seattle,WA 98101-3143;phone(206)624-7141. #dt Memo entitled"Compliance History report"from Kathryn Jones Cooper,Assistant Attorney General to the North Carolina Joint Select Committee on Low-Level Radio- active Waste.Raleigh,NC:North Carolina Department of Justice,July 21,1989,p. 3; .4 x P Page 24 S71.1 064 16. Available from:State of North Carolina Department of Justice,P.O.Box 629, Raleigh 27602-0629. See also Schulte,cited above. 6.Schulte,cited above. 7.Culp,Guterson,et al.cited above,pp.39-40.Richards,Bill.'Two Waste Firms to Pay$700,000 in Ohio Lawsuit." Wall Street Journal August 16, 1988,p. 1. 8.Associated Press."Garbage Hauler Collects Fine in Price Fixing Case."Pensacola Nees-Journal January 17,1988,p. 1. Ditzen,Stuart,and Mark Jaffe."Price-fixing Ac- cusations Follow Waste Management and BR."Philadelphia Inquirer May 9,1988,p. 4. North Carolina Department of Justice,cited above. Pierce,Rick."Hauler Fined$1 million,Waste Management Inc.Pleads No Contest in U.S.Suit."Ft. Lauderdale Sun- Sentinel January 13,1988,p. 1. 9.Culp,Guterson,et al.,cited above. Donze,Frank."Officials Say Garbage Collec- tor Threatened Lives."New Orleans Times-Picayune October 7, 1988,p.Bl. 10.Chen,Edwin.'Waste Hauler Fined$1 million in Price-Fixing Case."Los Angeles Times March 14,1989,Metro Section,p. 1 11."Reiner Sees Pervasive Cartel Conspiracy by Trash Hauling Firms."Los Angeles Times June 10,1987,p.6. 12.Associated Press.'Top Garbage Hauler Fined$1 million."Columbus Dispatch January 17,1988,p.1. Ditzen and Jaffe,cited above. 13.Blumenthal,Ralph.'Waste Hauler's Business Acts Faulted."New York Times March 24,1983,p.1. McClure,Robert,and Fred Schulte."Bribery Investigations Dog Waste Hauler."Ft. Lauderdale Sun-Sentinel December 8, 1987,p. 1. 14.U.S.Federal Electoral Committee,as reported in the Universal Almanac,1990,p. 95. 15.Jackson,B. "Interest Groups Pay Millions in Appearance Fees to Get Legislators to Listen as Well as to Speak." Wall Street Journal June 4,1985,p. 1. Common Cause, press release,June 25,1986. 16.Burke,M. 'Waste Corporation Tries Selling Self to Commissioners."Pensacola Journal November 14,1984,p. 1. McClure,Robert,and Fred Schulte."Bribery Inves- tigations."cited above. 17.Associated Press."Business,Lobby Give Money to Alabama Legislators."Atlanta Constitution September 14,1988,p. All.Brock,Brightman."To keep or not to keep is question."Mobile[AU Register December 19, 1985,p. 1. 18.Pierce,Rick,and Fred Schulte."Haulers Curry Favor in Community."Ft.Lauder- dale Sun-Sentinel December 8, 1987,p. 1. 19.Gaines,W.,and D.Baguet."City Can't Dispose of Waste Firm."Chicago Tribune June 29,1986,p. 1. 20. Brock,cited above. 21.Possley,M."Guilty Pleas by Bribery Case Figure."Chicago Tribune May 19, 1988, p. 1. Possley,M.,and R Davis."Ex.-Ald. Kelley to Plead Guilty."Chicago Tribune April 24,1987,p. 1. 22.Crawford,W.,Jr.'Waste Company Official Jailed for Bribery."Chicago Tribune March 14,1986,p. 1. 23.Seigenthaler,K."Kane County Official Linked to'81 Donation."Chicago Tribune August 25,1988,Metro Section,p. 1. Page 25 x;31.06' 3 October 19,1988. Webb,Andrew. 'Waste Management Cleans Up C Times 24.Neal,S.'Toxic Eddie Flies Free on Waste Management Jets." Chicago Sun hicagoMaga- zine June 1990,p.122. 25.Peterson,C.,and H.Kurtz. "EPA Speeds Friend's Permit." Washington Post Febru- ary 19,1983,p.. 1. Schneider, Keith.'The Leper Ships:Incinerators Sent to Sea." Oceans Magazine May 1984,p.65. 26.Lash,Jonathan. A Season of Spoils:The Reagan Administration's Attack on the Envi- ronment. New York,NY:Pantheon Books,1984. 27.List of WMI environmental grants recipients provided by WMI, 1990. n, 28. McNeil,J."Protective Instincts at the EPA,Part II:Keeping Reilly Covered."In These Times November 22,1989,p.12. Waste Management Inc. State Initiatives to In- hibit Development of Hazardous Waste Disposal Capacity and to Restrict Interstate Ship- 4 ment of Hazardous Waste[briefing paper prepared for Dean Buntrock's breakfast meeting with William Reilly]Oak Brook,IL:Waste Management,Inc.,1989. Martin, t T., and J.Healy."Ecologists Outraged Over Attack on Program." Winston-Salem Jour- nal April 21,1989,p. 11. J.Hair, president of the National Wildlife Federation,let- ter to Elizabeth Spence,executive director of South Carolina Wildlife Federation, December 21,1989. Gold,A."House Panel Opens Inquiry Into EPA Office."New York Times December 10,1989,p.5. 29."Federation Hires Chief,Plans Campaign;New International Law Effort."The Chronicle of Philanthropy July 25,1989,p. 15. Montague,Peter"EGA Gives WMI the Boot"Rachel's Hazardous Waste News#181 May 16, 1990,p.2. 30.Nolan,M."Church Refuses Donation from Waste Management."The(Chicago[ Times December 28,1986,p. I. pi 31.Pierce,Rick,and Fred Schulte. "Haulers Curry Favor in Community."Ft. Lauder- dale Sun-Sentinel December 8,1987,p.1. 1 32. Hanson,David."Hazardous Waste Management:Planning to Avoid Future Problems."C&EN(Chemical and Engineering News]Vol.67,No.31.July 1989,pp.9- 1 18. Warren,John L."Status of Hazardous Waste Management in the United States: 4 Focus on Incineration."Presented at Incineration of Industrial Wastes:Fourth An- � nual National Symposium.Houston,Texas,February 28-March 2, 1990. i 33. Schulte,Fred,and Robert McClure.'Nation's Top Two Garbage Haulers Leave y Legacy of Pollution,Soaring Prices."Ft. Lauderdale News(Sun-Sentinel December 6, 1987,p. 1. 34.CWM Form 10K,filed with the Securities Exchange Commission,1989,p.9. 35.Correspondence from Hugh Kaufman of U.S.Environmental Protection Agency, Washington,DC,to John Martin,U.S.Environmental Protection Agency Inspector General, October 17,1989. 36.Franklin Research and Development,Boston,MA."How One Investment Firm Rates 25 Companies on the Environment."Fortune Feb. 12,1990,p.27. 37.Ritter,Jim."S.Side Incinerator Hit With a Second Big Fine." Chicago Sun-Times October 9,1990,p. 1. 38.Bukro,Casey."Illinois EPA Wants to Shut Southeast Side Incinerator."Chicago 1 Tribune April 22,1988,Section 2,p.3. x 39. Nelson,D.,'Toes Step Up Attack on Incinerator."Chicago Sun Times,October 2, „. 1989,p. 1. Webb,Andrew.'Waste Management Cleans Up."Chicago Magazine July, 1990,p. 122. 40.Bergsvik,R."Incinerator to Stay Open."(Calumet City,IL]Daily Calumet June 16, 4 1989,p. 1. "Charge 219 Companies Polluted Local Streams."The News(Chicago,IL] 's 3v1Q r � Page 26 S* 7;r/ April 26,1990,p.12. Chicago Metropolitan Water Reclamation District,Summary of FOIA Report,May 24,1990. D.Nelson,October 2,1989. 41. Smith,A.,and J.Aubuchon."Waste Company Will Pay Penalty" Belleville[IL] News-Democrat February 17,1990,p. 1. 42.Kemezis,P."Chemical Waste Outlines Ambitious Expansion Plans."Environment Week February 22, 1990,p. 1. 43. Hutson,J."How Clean are the Titans of Trash?"New Hampshire Broadcaster July 5, 1989,p.1. O'Conner, M.'Waste Firm Conquers New Worlds." Chicago Tribune Feb- ruary 7, 1988,p.Cl. Richards,B.,and F.Rose."Henley and Waste Management to Merge Trash to Energy Lines into a New Firm." Wall Street Journal April 22,1988,p. 3. 44.Pierce,R."City Gets Burned."Ft. Lauderdale Sun-Sentinel December 10, 1987,p. 1. 45."Draft Technical Support Document to Proposed Dioxins and Cadmium Control Measure for Medical Waste Incinerators."Prepared by the California Air Resources Board,1990,cited in Rachel's Hazardous Waste News#179 May 2,1990. 46.'Waste Management's Growing Medical Services." WMI Report [WMI newslet- ter]October,1989,p.3. 47.Budd,D.Ohio EPA Division of Solid and Hazardous Waste.Correspondence to George Hubert,Multi Tech Industries Inc. [WMI's medical services division],April 3,1989,p. 1. 48.Correspondence between the Terrel,Texas,city government,the Texas Depart- ment of Health,the U.S.EPA,the Texas Air Control Board and Waste Management Inc.,October 20,1988 to December 22,1989. 49.Scarlett,H."Environmental Group Gives Notice About Suit."Houston Post March 2,1989,p. A21. 50. Ibid. 51."Ohio EPA Study Says Waste Management Unit's Wells Leaked." Wall Street Jour- nal April 6,1984. 52. Warner v. 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'Workers Sue;Claim Racial Bias at CWMI."Southwest Daily News February 12,1989,p. 1. 65.Letter from Steven Drew,CWM Regional Community Relations Manager,to "Environmental and Public Interest Group Leaders,"April 5,1988,p.1. Clemings, R"Kettleman Landfill Unit Shut Down."Fresno Bee March 24,1988,p.Bl. 66.Nielsen,R"ChemWaste Deluged with Questions"Hanford[WA]Sentinel June 30,1988,p.1. ,. 67.Smith,Brenda H."U.S.Government Studies Contradict Spiker's Beliefs."Solomon Valley Post March 19,1987,p. 1. 68.Bukro,Casey."Nuclear Waste Plant Moves in Without Whisper;Town Hollers." li Chicago Tribune January 26,1987,p. 1. Bukro,Casey.'Nuclear Safety Unit Hit on Compactor."Chicago Tribune January 29,1987,p. 1. "CNSI Sued for Planned Waste Compactor."Nuclear News April,1987,pp.57-58. i. 69.Nicodemus,C."Secret Nuke Plan Bared."Chicago Sun-Times March 18, 1990,p. 1. 70.U.S.Environmental Protection Agency. Solid Waste Report to Congress,cited above. 72.Bremner,B.'Recycling:the Newest Wrinkle in Waste Management's Bag."Susi- - ness Week March 5,1990,pp.48-49. 73.Commoner,Barry. Making Peace With the Planet. New York,NY:Pantheon , Books,1990. Correspondence from Hans Mueller,Surveillance and Enforcement Branch,Division of Solid Waste Management,Texas Department of Health,to Kevin Yard,MNA,Inc.,December 22,1989. Waste Management,Inc. 1987 Annual Report to Stockholders. Oak Brook,IL:Waste Management,Inc.,1987,p. 11. 74.Rodebaugh,D."Landfill Leak Exported by Opponents."San Jose Mercury News March 10,1989,p.1B. Rodebaugh,D."Landfill Toxics Ooze Toward Water.' San 1 Jose Mercury News March 9,1989,p.1B. Witt,B."Little Competition Foreseen in F, Trash Service."San Jose Mercury News January 6,1988,p. 1. 75.Jensen,T."Tamarac Recycling Program Talks Stalled."Ft. Lauderdale Sun-Sentinel February 15,1989,p.3. , 76.Chemical Waste Management. Waste Reduction Services. Oak Brook,IL:Chemical i Waste Management,Inc.,1989,p.5. t 77.For more information on the use of hazardous waste in cement and aggregate ers,Part I: tes In- ft do ation in Cemlns,see eentand Aggregaat,and Joe te Knilns. Washington,ton. Sham c1DC:GreenppeaeeU.S.A.s .,1990. J 78.Ohio Environmental Protection Agency."1988 Facility Annual CAPs Report: CWM Recovery,Inc." An undated computer printout provided to the author by Ohio Environmental Protection Agency,June 1990. Page 28 321.061 Si • 79.Aderman,G."U.S.Waste Specialist Opens Asian Office."Journal of Commerce February 7,1990, Brown,Alex,and Sons."'Waste Management Inc.—Company Re- port."April 1, 1990. Waste Management Inc., WMI Report MMI newsletter]June 1990. 80.Crooks,H.cited above. 81.Investext,May 14, 1990. "U.S.Waste Major Targets European Acquisition."Euro- pean Chemical News Vol.52,February 13, 1989, p. 1. 82.Hamilton,M. 'Turning Trash Into Cash."The Washington Post July 8, 1990,p. HI. 83.Bergsvick,Robert. 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