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¶993 IT I 3 AM E: 52 CHEROKEE INVESTMENTS, INC.
2090 EAST 104Th AVENUE. SUITE 305
CLERK THORNTON.COLORADO 80233
TO THE BOC; D (303) 450-2204
November 12, 1998
Mr. Carl Mount, Senior Environmental Protection Specialist
Division of Minerals and Geology
1313 Sherman Street, Room 215
Denver, Colorado 80203
Re: Front Range Landfill - Termination of Permit M-98-035
Dear Mr. Mount:
Per our discussion several weeks ago, on behalf of the owner and operator of the Front Range
Landfill, I am hereby requesting termination of the above reclamation permit and release of the
collateral. Pursuant to CRS 30-20-10I, financial assurance collateral for final reclamation is held by
the Colorado Department of Public Health and Environment (CDPHE), and CDPHE arid the local
governing authority monitors, inspects, and oversees the operation. Thus there is assurance that the
site will be reclaimed.
The operation involves phased excavation of various portions of the property, construction of clay
liners, filling the lined area with municipal solid waste, covering both daily and at the conclusion of
each phase with earthen material, replacement of topsoil as a final cover, and revegetation of all filled
and other disturbed areas upon final reclamation of the site. The operation from time to time
produces an excess of earthen material in excavating areas for landfill construction. As with many
landfills and development projects in Colorado, where excavation for another primary purpose
occasionally creates an excess of excavated material, the operator desired to export excess excavated
material ofl=site for use as general borrow material whenever possible. The operator's primary intent
is to operate the landfill, not to excavate for borrow material. Export of excess material is clearly
secondary. The export of excess material does make the operation more efficient and may produce
some minor revenue, but any revenue from the export of excess material is negligible in comparison
to the gross revenue the landfill receives from the disposal of solid waste.
At the time the reclamation permit was issued by your agency, it was unclear whether the above
activities should be covered by both a Certificate of Designation and a MLRB reclamation permit.
Not wishing to risk violating your rules, the operator did request and receive the above reclamation
permit from your agency. However, since the above permit was issued, it has become apparent that
both the DMG staff as well as the Mined Land Board have determined that a reclamation permit from
your agency is not required for a site permitted under a Certificate of Designation for the occasional
export of excess material.
C47 982674
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In our phone discussion, you ask whether or not the reclamation activities had been completed as a
reason for the request to terminate the permit. I did check with the operator, and the reclamation
activities aren't completed and won't be completed for years, as ultimately the permit area will be
excavated, filling with municipal solid waste, and then recovered and revegetated as final reclamation.
As all of these activities will continue to be governed by the Certificate of Designation, it seems the
best course was just ro ask to terminate the MLRB reclamation permit as being unnecessary in light
of recent determinations by the DMG Staff and the Board. Therefore, we would request that the
above permit be terminated and the collateral released.
Per your normal requirements for release of collateral, I am also sending a copy of this request to
Weld County, the Town of Erie (local governing authority), and the local Soil Conservation District.
If there is someone else that should be notified, or if some other procedure needs to be followed,
please let me know. I will be out of the area next week, but I'll call you the week of November 23
to check on the status of this request.
Sincerely,
£ dming'
cc: Front Range Landfill, c/o Steve Dews Site Manager
Weld County Board of County Commissioners
Town of Erie
Boulder Valley Soil Conservation District
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