HomeMy WebLinkAbout971858.tiffSTATE OF COLORADO
Roy Romer, Governor
Patti Shwayder, Executive Director
Dedicated to protecting and improving the health and environment of the people of Co/orario
HAZARDOUS MATERIALS AND WASTE MANAGEMENT DIVISION
http://www.cdphestate.coms/hm/
4300 Cherry Creek Dr. 5. 222 S. 6th Street, Room 232
Denver, Colorado 80222-1530 Grand Junction, Colorado 81501 -2 768
Phone (303) 692-3300 Phone (303) 248-7164
Fax (303) 759-5355
1O, 1997 Fax (303) 248-7198
July
07/4
Jarrald Jamison
Tire Mountain, Inc.
12311 Weld County Road 41
Hudson, CO 80642
Re: Financial Assurance
SW WLD TIR lE
Dear Mr. Jamison:
Colorado Department
of Public Health
and Environment
The information that you submitted for the financial assurance
for Tire Mountain has been reviewed. Financial assurance is
required by state statute and details are found in section 1.8
and Appendix A of the regulations. Based on the information
submitted by you dated March 25, 1997 several problems have been
identified, which I have listed below.
I am assuming that the 25 pits mentioned in your March 25, 1997
correspondence are currently open. The closure cost estimate
must be increased as additional pits are installed. The
financial instrument is to be based on the largest open area of
the facility and is to include closure and post -closure costs.
These costs must be estimated so a third party can close the
facility. The financial instrument must be available to the
State.
1. Since no details accompanied your March correspondence, the
pits are all assumed to be 100 feet by 250 feet by 15 feet deep
per your letterhead. This yields a gross volume for each pit of
approximately 13,900 cubic yards. Your correspondence assumes
two feet of cover, which is assumed to be final cover, over each
cell or pit. This represents approximately 1850 cubic yards of
soil cover material.
No allowance has been made, in your correspondence, for void
space or settlement during the covering of the pits. To allow
for settlement and compaction during cover operations a factor of
0.5 void space was assumed. Therefore, 0.5 x 13,900 gross cubic
yards is approximately equal to 6950 cubic yards. It is further
assumed that this 6950 cubic yards plus the 1850 cubic yards of
soil, for final cover, will be needed to properly close each pit
for a total of 8800 cubic yards of soil per pit.
It is generally accepted that it costs approximately $1.00 per
LC : Pi; Nz'J; {4
P�o4s10
971858
cubic yard to move onsite soil. At this price the estimated cost
to move the soil would be: 25 pits x 8800 cubic yards/pit x $1.00
per cubic yard = $220,000.
While these figures are rough, they are representative of similar
facilities closure costs for moving soil. Also, verification
that there is enough onsite soil available is required;
importation of offsite soil will add to the closure costs.
I did note in your facility file that in 1990 you requested not
to use a plastic material as an interface between the cover and
the tires. This request was approved by the Weld County
Commissioners. Closure by the use of some sort of plastic or
geotextile would change the costs for soil mentioned above.
2. Your estimate of $45.00 per acre for 38 acres of seed does
not mention inclusion of mulch, fertilizer, watering or spreading
or drilling in the seed. The costs should be revised to take
these items into account.
3. The closure cost estimate contains no provision for post -
closure care and inspection during the post -closure care period.
This effort would include erosion control, reseeding and control
of illegally dumped materials, as necessary.
4. The financial assurance is to be established for an
independent third party to close the facility and maintain it
during the post -closure period. To enable the State to hire a
contractor the financial instrument must be available to the
State. A stand-by trust may be required dependent on the
financial instrument that is used. If a financial instrument
that is not specifically mentioned in the regulations is desired,
such as a certificate of deposit, it must be approved by the
Department under section 1.8.16 of the regulations.
It would help if you were to use the standard form that was
developed for assessing costs for closure. I have enclosed a
copy for your use. It is available electronically for $15.00.
In summary, your estimate for closure and post -closure care is
not adequate in its present form. It is underfunded according to
my estimates and does not take into account numerous details that
would be necessary to close the site and maintain the site during
post -closure.
97185S
sufficie
complete
at 303/69
((/'
rely,
%n F. Mallory
olid Waste Unit
Compliance Progr
enclosure
cc T. Jireck, WCHD
Weld County Board
M. Sheets, AGO
Your revised financial assurance package which includes
ormation to support third party closure should be
and resubmitted by September 1, 1997. I am available
5 if you wish to discuss this matter.
971858
Hello