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Home My WebLink About20162843.tiffHEARING CERTIFICATION DOCKET NO. 2016-74.B RE: A SHOW CAUSE HEARING, PCSC16-0004, CONCERNING A MINOR AMENDMENT TO A SITE SPECIFIC DEVELOPMENT PLAN, MUSR14-0030, AND USE BY SPECIAL REVIEW PERMIT, USR-1704, FOR A SOLID WASTE DISPOSAL SITE AND FACILITY (INCLUDING CLASS I COMPOSTING, AN ANIMAL WASTE RECYCLING OR PROCESSING FACILITY [AN ANAEROBIC DIGESTER -BASED RENEWABLE ENERGY PLANT GAS], ALONG WITH A CONCRETE BATCH PLANT TO BE USED FOR CONSTRUCTION OF THE FACILITY FOR THE ADDITION OF A DIGESTER PROCESS AND A 70 -FOOT FLARE) IN THE A (AGRICULTURAL) ZONE DISTRICT - HEARTLAND BIOGAS, LLC A public hearing was conducted on November 14, 2016, at 10:00 a.m., with the following present: Commissioner Mike Freeman, Chair Commissioner Sean P. Conway, Pro-Tem Commissioner Julie A. Cozad Commissioner Barbara Kirkmeyer Commissioner Steve Moreno Also present: Acting Clerk to the Board, Tisa Juanicorena County Attorney, Bruce Barker Assistant County Attorney, Frank Haug Planning Services Department representative, Chris Gathman Health Department representative, Phil Brewer Health Department representative, Ben Frissell The following business was transacted: I hereby certify that pursuant to a notice dated September 2, 2016, and duly published September 7, 2016, in the Greeley Tribune, a public hearing was conducted September 19, 2016, at 9:00 a.m., to consider Show Cause, PCSC16-0004, concerning revocation of a Minor Amendment, MUSR14-0030, to a Site Specific Development Plan and Use by Special Review Permit, USR-1704, for a Solid Waste Disposal Site and Facility (including Class I composting, an animal waste recycling or processing facility [an anaerobic digester -based renewable energy plant gas], along with a concrete batch plant to be used for construction of the facility for the addition of a Digester Process and a 70 -foot flare) in the A (Agricultural) Zone District, at which time, the Board deemed it necessary to continue the matter to November 14, 2016, at 9:00 a.m., to allow Heartland Biogas, LLC, an opportunity to receive and review bids pertaining to mitigation solutions and have a minimum of two (2) community meetings with proper notice given. At the aforementioned hearing, it was agreed upon by the Board that the continuance would be granted with the following conditions: to limit gas production to 60%, limit organic material received to the current amount, and have a minimum of two (2) community meetings with proper notice given. On November 14, 2016, Assistant County Attorney, Frank Haug, made this a matter of record. Mr. Haug reviewed the circumstances resulting in the Show Cause Hearing and the reasons for the continuance. He also introduced new information from the Colorado Department of Public Pe, EH, Owl) 2016-2843 PL2072 HEARING CERTIFICATION - HEARTLAND BIOGAS, LLC (PCSC16-0004) PAGE 2 Health and Environment, Solid Waste Division, regarding a letter dated November 8, 2016, referencing the Certificate of Designation and the complications resulting from the company ownership change and minor modifications to the Engineering Development and Operations Plan (EDOP) that was approved by the State in 2014; however, the Certificate of Designation was never updated with the name change. Mr. Haug explained, furthermore, that the Colorado Department of Public Health and Environment, Air Quality Division, has been conducting an investigation and has come to the conclusion that there will be an agreement to make sure Heartland Biogas, LLC, is meeting the conditions of the Air Quality Permit by setting forth certain milestones that have to be met. He reminded the Board that what is before them today is only the current USR Show Cause Hearing based on the violation of the odor threshold and that because this new information was not received before the notice of the Show Cause Hearing and this new information has not been noticed to the public in relation to the current hearing, the appropriate course of action would be to evaluate the State -issued deadlines, notice the public and have a public hearing related to those items afterward. El In response to Commissioner Cozad, Mr. Haug stated it requires a ten (10) day notification. He reviewed a few of the deadlines related to the Air Quality Permit investigation to include an Engineering Analysis deadline of November 18, 2016, the deadline of December 31, 2016, to complete construction of part of a facility that is supposed to help stop some of the odor, and mentioned a March 31, 2017 deadline. He clarified the State did not set a deadline on the completion of a corrected Certificate of Designation due to the dual jurisdiction of the State of Colorado and Weld County both to issue the Certificate and the authority regarding enforcement. • In response to Commissioner Kirkmeyer, Mr. Haug stated pursuant to Colorado Revised Statute, Section 30-21-13, the CDPHE has inspection and enforcement authority regarding compliance and can impose civil penalties utilizing various methods. Also in Colorado Code Regulation 1007-2-1.9.2, the CDPHE may issue violations, encourage compliance, and revoke the Certificate of Designation. Commissioner Kirkmeyer clarified the CDPHE can only revoke their approval of the CD that is issued by the County. Mr. Haug concurred and stated there are currently no civil penalties from the State as they are waiting to see if Heartland Biogas, LLC, will apply for a new CD. Commissioner Kirkmeyer ascertained that currently Heartland Biogas, LLC, does not have an approval for a Certificate of Designation from the State. Mr. Haug verified that to be true. In further response, he stated he is aware of a modification to the EDOP after Heartland Biogas, LLC, took ownership but he is unaware if that included a change to the waste stream. • In response to Commissioner Kirkmeyer, Phil Brewer, Health Department representative, stated the waste stream is the same for both. She asked if he was certain. He stated what was listed in the Air Permit was the same; however, he cannot verify if other documents had different information. Commissioner Kirkmeyer requested staff make certain the waste stream did not change at any point from the inception of the USR Permit. • Commissioner Cozad requested the dates and clarification related to the modification of the EDOP at the State level due to the link between the EDOP and the Certificate of Designation. • In response to Commissioner Cozad, Mr. Haug referenced a letter dated October 8, 2014, received from CDPHE regarding the change to add the Digester Processing System (DPS) as a 2016-2843 PL2072 HEARING CERTIFICATION - HEARTLAND BIOGAS, LLC (PCSC16-0004) PAGE 3 change to the EDOP and the CDPHE stated this is an operational issue and does not require a change to the Certificate of Designation. Mr. Haug verified the waste material received did not change but the processing of that material by use of the DPS was what changed. He further verified the State identified the change in the company as the problem. Commissioner Kirkmeyer requested a copy of the original USR and the original Certificate of Designation that was approved by the Board of County Commissioners. ki Bill Garcia, Attorney for the Respondent, expressed his appreciation for being included in the recent conversations and for forwarding the recent documents. He clarified the State is concerned with financial assurance which has been provided. He further stated the EDOP is being reviewed and that is no surprise. Mr. Garcia stated Heartland is providing the application for the name change and that has no bearing for today. • Commissioner Conway asked for clarification regarding the timeline related to the agreement with the CDPHE Air Quality Division. Mr. Garcia deferred to the respondent. el Chris Gathman, Department of Planning Services, presented a brief summary documenting additions to the case. He states an application for a Building Permit was submitted and approved for a building cover addition to enclose the area that receives the organic animal waste and houses temporary storage. In response to Commissioner Kirkmeyer, Mr. Gathman stated it was submitted on November 3, 2016, and issued on November 4, 2016. He clarified it was fast -tracked. He reported an additional 199 odor complaints since September 19, 2016, were submitted and that staff has been out there performing nasal ranger evaluations and there would be more information provided from Environmental Health. El Mr. Brewer explained the map locations representing the odor complaints and locations representing where odor evaluations were conducted. In response to Commissioner Cozad, Mr. Brewer explained the evaluations conducted within the square mile surrounding the Heartland facility were evaluated due to prior determinations of high concentrations of odor based on data from Trinity Consultants, and the other locations outside that square mile were conducted in relation to wind directions. He reported none of the evaluations were in violation. • In response to Commissioner Kirkmeyer, Mr. Brewer stated there were no test determinations of odor that satisfied the criterion for the violation. He further responded regarding the evaluation procedure and stated there were some readings initially at the 8:1 threshold but did not fulfill the determination to retest. Commissioner Kirkmeyer asked for the number of readings that were 8:1 at any time. • Mr. Brewer provided the slide documenting the dates and times for the odor determinations and the findings are in the second column to the right. In response to Commissioner Cozad, Mr. Gathman stated this information was provided from Environmental Health for the presentation today and has been added to the official record. In response to Commissioner Conway, Mr. Brewer stated the averages are not calculated. 2016-2843 PL2072 HEARING CERTIFICATION - HEARTLAND BIOGAS, LLC (PCSC16-0004) PAGE 4 Mr. Haug stated, in response to Commissioner Kirkmeyer, that the waste streams were approved in 2013; however, he does not know what the waste stream was exactly, or of what quantities. Jason Thomas, Plant Manager and respondent for Heartland Biogas, LLC, provided a PowerPoint presentation and began with reviewing the prior Resolution requirements, compliance with community outreach efforts, and the odor control status. He stated the facility has maintained the requirement to keep gas production to less than 60% and waste materials brought to the facility were limited to the current rate as also required. In response to Commissioner Moreno, Mr. Thomas stated approximately 80% of the total organic materials received are brought in from entities located in Weld County and approximately 20% are from entities outside Weld County. He reviewed the four (4) community meetings that took place beginning with September 29, 2016, with seven (7) attendees, and although the community requested to cancel the October 13, 2016, meeting, he was present in case anyone showed up and no one did. Another meeting was held on October 27, 2016, with seven (7) in attendance; and lastly, a meeting was held on November 10, 2016, with six (6) in attendance. He stated at the November 10th meeting it was decided to schedule a meeting for the second week of December and then tentatively in January, 2017. Mr. Thomas further described the communication tools provided to the community as being: an odor complaint email, odor hotline that is staffed 24/7, and a website, with correspondence communicated back to him, if requested. He further mentioned the invitation to tour the facility and stated these efforts to reach out were all in place on October 27, 2016. He further discussed the purchase and distribution of the nasal rangers to members of the community, one of which was returned by James Welch November 10, 2016, with no feedback, and the second was given to Steve Flippin on October 14, 2016. Mr. Thomas stated he has requested any readings that surpass the 7:1 threshold be reported to him and, to date, there have not been any. He stated Heartland continues to perform odor monitoring three (3) times each week in an effort to verify odor intensity. He reported 88 readings have been performed since the last hearing with similar readings as before and within the regulatory limits. Mr. Thomas presented a slide of the Compliance Order between the Air Pollution Control Division (APCD) and Heartland Biogas, LLC, which was signed and sent electronically on November 10, 2016, and the original documents are being mailed today. He reviewed the requirements pertinent to the Show Cause Hearing to include not exceeding the 7:1 odor threshold, an analysis of the engineering of the odor control systems which must be completed by November 18, 2016, and the required construction dates to complete the expansion and covering of the area that houses the organic material drop off by December 31, 2016, the completion of the substrate and dosing tank and related filtration systems by March 31, 2017, and the completion of DPS building #2 with an air handling system which will be a second unloading area for organic material. Mr. Thomas presented the odor monitoring requirement per the Compliance Order which must be reported monthly to the APCD. He reviewed the progress related to meeting these requirements and improving odor generation and provided approximate completion dates for each requirement. He further stated he is implementing best practices from similar facilities in Europe and has a consultant he is working with and who has visited the facility. 2016-2843 PL2072 HEARING CERTIFICATION - HEARTLAND BIOGAS, LLC (PCSC16-0004) PAGE 5 • In response to Commissioner Cozad, Mr. Thomas explained the benefits of the new filtration system which prevents the gas from being emitted into the atmosphere and instead captures it and vents it to pipework leading to a filtration system to extract the odor. la Mr. Thomas recapped additional odor mitigation actions to include being introduced to a lagoon microbiological treatment which was started last week and requires two (2) inoculations to complete the biology which then can be evaluated thereafter. He clarified that although the odors emitted from the lagoons are not a primary source of odor, this treatment is still a good fit for lessoning the overall impact to the community. Mr. Thomas introduced his final odor mitigation action as a temporary substrate filtration system that operates similarly to the planned permanent system that he put into service on November 11, 2016, and stated the initial performance is very positive and they immediately saw an improvement in the odor. He explained the operational aspect and stated he is excited for the opportunity to test and review its effectiveness; however, he cannot know if it is sufficient without testing it at full capacity of plant operations. • In response to Commissioner Kirkmeyer, Mr. Thomas stated he is currently at 40% material receipt and 60% gas production and the substrate filtration deals with the materials being received. He presented his argument and requested to move operations to full capacity to fully test the mitigations efforts. Mr. Thomas pressed that it is his firm belief that the odor will not increase and he wants to be sure that the odor mitigation is not under designed when it is completed and the plant is at 100% in March. In response to Commissioner Kirkmeyer, he stated there are no other systems in the United States that can be compared in size. Commissioner Kirkmeyer responded if the mitigation efforts are not working at the current level of operations, it is logical that they will not work at 100%. • In response to Commissioner Cozad, Mr. Thomas stated only the organic non -manure materials go into the substrate tanks and he explained the process and clarified that increasing receipt of manure does not accomplish the gas production. He further explained the percentages of materials received and how it relates to the design and gas production needs. Mr. Thomas further pressed his request to be allowed to operate at 100% to be able to test the systems and meet clientele obligations. • Commissioner Conway stated covering the drop off area, which is a main source of odor, is not being addressed until June. In response to Commissioner Conway, Mr. Thomas stated presently this material is unloaded on a concrete pad because the building is too small and a truck cannot get inside. He clarified that when the building is complete 43% of the material will be unloaded inside the building and the big trash trailer will be stored inside that building. • In response to Commissioner Kirkmeyer, Mr. Barker referenced the original notice which referred to certain Development Standards. He explained there would need to be a change to the Resolution and additional notice given if there were other Development Standards that the Board wanted to address. 2016-2843 PL2072 HEARING CERTIFICATION - HEARTLAND BIOGAS, LLC (PCSC16-0004) PAGE 6 Chair Freeman opened to public hearing and stated there is a three (3) minute limit on public input. Nancy Flippin, Surrounding Property Owner (SPO), stated she has attended most of the community meetings and reported she is still getting very strong odors even with these new processes being put into place. Ms. Flippin stated she has been in communication with Heartland for the last year and each time she is told they are working on it, yet the strong odors remain. She reported attending the last meeting on November 10, 2016, and hearing there were permits submitted and issued within 24 hours for a new process and she is concerned that 24 hours was not enough time to truly review these plans. She mentioned they were told there are no digester facilities of this size in Europe and she expressed her concerns in reference to the letter received, in 2009, stating there would be no odors. Ms. Flippin reiterated her frustration with lack of notification regarding the changes in companies and how the present company continues to negatively impact the community. She pointed out this facility is forcing the County and the community to be guinea pigs, while at 40% materials receipt with the new filters and systems, there are still very strong odors. Ms. Flippin mentioned the state dilution level for hog farms and marijuana businesses being held to a 2:1 threshold and stated this industry needs to be held responsible so as to not make Weld County the laughingstock of odor. El Connie Williams, Eaton resident, stated the burden is in the wrong place as the community has come before the Board several times to regain their lives. She expressed her frustration with Heartland for only now introducing Best Practices, recently implementing odor control systems, and fruitless community meetings. Ms. Williams clarified that continued information has been reported to Mr. Brewer but there is no reason for the community to do the work for Heartland. She pleaded with the Board to help this community return to the quality of life they deserve. Steve Flippin, SPO, stated he is the closest resident to this facility and they are constantly getting the odors. He reported trash along the fence line from the plant and recapped his experience with Heartland since November, 2015. Mr. Flippin stated when he first complained he was told they were draining the lagoons and the odor would get better when that was finished; however, it did not get better, it got worse. He reiterated the frustration with the lack of promised solutions for over a year, the odor getting worse, and he stated the odor is so bad you can taste it on some days. Mr. Flippin conveyed his efforts to work with them for over a year while the garbage sits outside attracting rodents and Heartland takes forever to fix the odor problem. He stated he is sick of it. Kathy Hoyland, SPO, stated they were told at the community meeting held August 25, 2016, that the representative from AGPROfessionals that sent out the letter, in 2009, no longer works for AGPROfessionals and that Heartland Biogas has an attorney looking into the legality of the letter. She stated based on the things said at these community meetings, the lack of trustworthiness, and the poor reflection of the minutes taken at these meetings, she and her husband have chosen not to attend any more of these meetings. Ms. Hoyland expressed her frustration regarding false nasal ranger readings and stated they are not going to waste their time at the community meetings any further. She reiterated the frustrations regarding the ownership change, Heartland not abiding by the requirements of the original USR, and mentioned that they built their home, in 2005, and were not allowed to move in without a Certificate of Occupancy and 2016-2843 PL2072 HEARING CERTIFICATION - HEARTLAND BIOGAS, LLC (PCSC16-0004) PAGE 7 asked how an industry can open up and operate when obviously the design is not complete. She stated her opinion today is the USR needs to be revoked until ownership is established and the EDOP is redesigned and the company is operating at the level it should be and for the community to regain its quality of life. Ms. Hoyland reminded the Board that Heartland moved into her neighborhood, they are a nuisance neighbor and have stolen their quality of life. She pleaded with the Board to step up and do something to give them their lives back. • Rena Arens, SPO, stated she has lived in the area for 45 years and has farmed and operated dairies and a feedlot and is familiar with agricultural odors. She explained she understood the plant was supposed to be odor free and she clarified it isn't just an odor, it is a stench. She conveyed that it is impossible to have a barbeque, sit on the patio, or take a walk due to the constant odor. Ms. Arens stated she lives over two (2) miles away and there have been two (2) instances when she left the windows open and after 11:00 p.m. the odor came into the house and she had to cover her face with a blanket and the stench is so bad it fills the house and does not dissipate quickly. She believes that Heartland releases gas when people are not around and this smell is not oil and gas, it is not manure, it is a stench you cannot get used to. Ms. Arens stated the community members have become prisoners in their homes. Lastly, she mentioned the waste is high in salt and should not be spread on fields or allowed to run down the ditches and asked the Board to please look into it. El Deb Morris, SPO, stated her property is not on the map and she has submitted a number of complaints. She expressed her frustration with the lack of actual contact information provided in the presentation. Ms. Morris stated the community is part of a big experiment that is costing them their livelihood and the ability to live in their own homes. She conveyed she is not sure what the odor threshold actually means but she is fairly certain if the room was flooded with the stench they have to endure, the room would clear out quickly. Ms. Morris reiterated it is impossible to have the windows open because the smell is awful. She asked why the company did not investigate the European facilities before bringing it here. She further insisted this is not about agriculture, this is about processing trash and the County has been sold a bill of goods. In response to Commissioner Conway, Ms. Morris stated she went to the Weld County web page to complain but her property is not shown on the map. • Sharon Welch, SPO, submitted a picture of the view at her property and stated she and her husband bought their land 13 years ago and built what they thought was their forever home. She listed the outdoor activities they used to enjoy and how those have stopped due to the smell. She stated they were forced to find another location for their daughter's wedding. Ms. Welch conveyed they cannot open their windows and are held hostage in their homes because of the stench and she communicated that it doesn't matter which way the wind is blowing someone will suffer and they want justice and their lives back. In response to Commissioner Kirkmeyer, Ms. Welch stated she can submit her notes for the Board's review. • James Welch, SPO, asked for latitude on time due to his lengthy presentation containing hundreds of hours of research, documentation of evidence, details regarding the differences in the EDOP from the original USR to the present, violations of Development Standards in the USR and violations related to state regulations. He stated the public testimony speaks to the detrimental effect on the well-being of the community and his primary focus today is the lack of 2016-2843 PL2072 HEARING CERTIFICATION - HEARTLAND BIOGAS, LLC (PCSC16-0004) PAGE 8 compliance by Heartland Biogas, LLC, in all the aforementioned areas, the proposed solutions still do not attain compliance, a series of poor decisions and noncompliance have resulted in this being the most significant odor source in the state and the only option today is a full revocation. He stated this is a solid waste facility, not an agricultural facility. Mr. Welch called attention to Development Standards (DS) #17, #21, and #45 and clarified that #45 gives latitude to investigate all other standards of which he would like to call additional attention to DS #34, #42, #6, #16, and #18. With that he mentioned violations related to signage, fencing, security access to the facility, no security measures at the facility, five (5) digesters are proposed in the original approved USR the amended USR and there are six (6) on -site. He inquired who approved the increased capacity and reported that all Solid Waste Facilities are supposed to prevent off -site nuisances and are obligated to fix any odor complainant issues. Mr. Welch reviewed the three major waste streams and focused on the liquid organic waste stored in substrate tanks which has been identified as the most significant contributor to Heartland odor, and according to the EDOP for the DPS Facility written in November, 2014, it states there will be mitigation if the odor becomes a problem. He reminded the Board that it is two (2) years later and the problem is still not mitigated. Mr. Welch insisted they knew the storage of organic waste would be an odor issue because the mitigation is in the original plan. He further explained the original design submitted in 2010, regarding the substrate tank, included a two -stage scrubber for odor control which is the same technology being presented today. Mr. Welch stated the original plans show the waste would be off loaded and handled in an enclosed building. He argued that when Heartland has been asked if they knew how to mitigate, they have requested time to investigate solutions when the plans from 2010 clearly represent best management practices (BMPs) that EDF Heartland removed after approval and not until the present when Heartland Biogas is pressured by the County and the State to mitigate and comply are they making improvements. He further pointed out the next area of odor source as the feedstock tank unloading and again pointed out that in the original plans all incoming waste streams were to be stored in enclosed covered storage areas for the reduction of any offensive odors. In response to Chair Freeman, Mr. Welch stated he would try to speed up the remainder of the presentation. • Commissioner Kirkmeyer requested Chair Freeman allow time for Mr. Welch to complete his presentation. • Mr. Barker reminded the Board that the notice contained three (3) items: 1) the facility shall operate in compliance with the Colorado Air Quality Control Regulation, and comply with any permits issued by the Air Pollution Control Division, 2) Colorado Air Quality Commission Regulation #2 regarding the odor detected off -site shall not exceed the 7:1 threshold, 3) the requirement to comply with #1 and #2. In response to Mr. Barker, Mr. Welch stated he believes everything in his presentation relates to those notice items and specific to the odor issue. • Mr. Welch stated regarding the liquid manure, all waste streams were supposed to be enclosed and all pits were to be covered which necessitated the need for unloading through hoses and is a clear indication the EDF Heartland removed all BMPs after the USR was approved. He reminded the Board that even with mitigation measures today, EDF Heartland still has not committed to cover the manure which is a requirement of their Odor Management Plan which will continue to keep them in non-compliance. Mr. Welch mentioned the DPS facility as the third source of odor and reiterated that all incoming waste streams were supposed to be covered. He displayed recent images of examples of waste being kept outside. He reported from the original 2016-2843 PL2072 HEARING CERTIFICATION - HEARTLAND BIOGAS, LLC (PCSC16-0004) PAGE 9 MUSR, there was to be no storage of waste at the DPS facility and as mentioned today and as the photos display, there is waste stored at the site. Mr. Welch insisted the BMPs were removed after the USR was approved and stated that all of this could have been prevented if they had followed best practices. He further pointed out the change from the 2010 EDOP in 2013 without notification to the County which is in violation of DS #10. Mr. Welch stated in the Odor Management Plan, the mitigation plan is to limit new material to the site or remove offending material from the site, if necessary, but rather than do that in this meeting or the last meeting, they continue to ask to bring in more which is a continued theme that the BMPs were removed and the BMPs included are not being followed. He repeated the USR is not being adhered to, Heartland Biogas has violated multiple EDOP standards, removed BMPs, are not compliant with the current plan, the proposal today does not put back in the BMPs that were removed and they are not adhering to the MUSR application and all of this has resulted in this being the most significant odor source in the entire State of Colorado in recent history. Lastly, Mr. Welch quoted Patrick Henry and asked how many more things must be added to the list until they are held accountable. • In response to Commissioner Conway, Mr. Welch stated the plan presented today by Heartland will not solve the problem because they have not addressed all the odor sources, nor does it put them into compliance by covering all the waste streams. He further stated past actions do not encourage faith in improvement and serve as a reminder that they we shouldn't be congratulated on a fix when the BMPs should have been included in the beginning. Mr. Welch provided binders with his research and documentation to the Board and County Attorney. El Chair Freeman closed public input. El In response to Commissioner Conway, Mr. Gathman explained the original hearing was in July, 2010, then the change from the proposed five (5) tanks that were to be up to 50 feet in height to the proposed six (6) tanks that are only up to 29 feet in height was considered an acceptable change in the staff review because at the time staff was concerned regarding the visual impact and it was brought before the Board in February, 2013. Based on the changes to the original plan of covered pools to tanks, staff re -notified because the plat had not been recorded and USR-1704 had not been approved yet, so it was brought before the Board at that time. Commissioner Cozad interjected the MUSR was administratively approved in 2014. Mr. Gathman stated the minor amendment approved the additional processing of food wastes. He reiterated the Board held a hearing in February, 2013, to discuss changes to the design of the approved USR to change some of the application materials and design. Commissioner Kirkmeyer stated she would like to see the minutes from the February, 2013, hearing. In response to Commissioner Cozad, Mr. Gathman stated the plat was recorded February 5, 2014. • Mr. Garcia objected for the record regarding the presentation from Mr. Welch because it was not provided to Heartland and because it brought up new issues that should have been presented at the Probable Cause Hearing. • Mr. Thomas stated that Heartland Biogas has recognized there is an odor issue and has demonstrated a desire to improve that by taking immediate action to install misting systems while investigating the more permanent engineering solutions. He reiterated they have demonstrated 2016-2843 PL2072 HEARING CERTIFICATION - HEARTLAND BIOGAS, LLC (PCSC16-0004) PAGE 10 meeting the requirements of the 7:1 odor threshold and remained in compliance; however, he insisted that is not enough as a professional and as a good neighbor so they continue to perform significant testing and monitoring. Mr. Thomas reminded the Board that this is a $100 million facility and it is not done yet. He further reminded the Board that this facility is good for Weld County on multiple levels. Mr. Thomas stated he made a commitment to pick up the trash and that once the building is finished the trash will be stored inside the building. He stated the facility is designed to run at 100% capacity and anything less than that is not at design capacity. Mr. Thomas mentioned this is a recession proof business. To which, Commissioner Kirkmeyer promptly requested the County Attorney remind the Respondent that the Board is to consider the three Development Standards not recession proof businesses. • Mr. Garcia stated a factor in regard to the request of revocation would be the economic impact on Weld County. Commissioner Kirkmeyer disagreed. Mr. Barker repeated the noticed Development Standards that are being considered today. • Mr. Thomas stated Heartland has done all that has been asked of them from both the County and the community to meet the requirements and they continue to do so and insisted they are in compliance with the standard. • In response to Commissioner Moreno, Mr. Thomas stated this is the first time he has been made aware of these BMP changes from 2010 and he was not involved at that time; therefore, he would need time to research these questions to be able to provide an answer. • Commissioner Cozad asked for clarification from counsel regarding the original notification and pointed out that DS #45 requires compliance with all the DS. Mr. Barker explained the notice recognized the DS #17 and #21 related to the Air Quality Control Commission Permit which includes compliance with the EDOP. Commissioner Cozad stated the EDOP is part of the CD and asked how to take that into consideration. Mr. Barker stated it goes back to the notice and the two (2) Permits that they were out of compliance with. Commissioner Cozad called attention to the fact that there are several EDOPs in place and the DS refers back to the 2010 EDOP. Commissioner Kirkmeyer agreed. Mr. Barker encouraged reviewing the Development Standards of the Minor Amendment in 2014. Commissioner Cozad stated it mentions the EDOP approval letter dated April 7, 2010, from the CDPHE, and the addendum approval letter dated December 18, 2014, and she requested the applicant address the addendum from 2014, and explain the change from 2010. • In response to Commissioner Cozad, Mr. Thomas stated he is not prepared to talk about the addendum change in 2014 to the 2010 EDOP. • Commissioner Kirkmeyer stated she has the same line of questioning that Commissioner Cozad has and given the fact that Heartland continues to say they are not prepared to answer these questions. She requested a two (2) hour recess to give the respondent an opportunity to review the 2014 addendum and 2010 plan and she recommended staff review these as well. She reiterated that DS #17 requires they be in compliance with the EDOP from 2010 and the addendum from 2014. She reviewed the relationship regarding compliance with DS #17 and #21 regarding the Air Permit and the link which requires compliance with the EDOP. 2016-2843 PL2072 HEARING CERTIFICATION - HEARTLAND BIOGAS, LLC (PCSC16-0004) PAGE 11 ▪ Commissioner Kirkmeyer stated she also has questions for staff to answer when the hearing is reconvened after the recess. She directed staff to research the compliance of the 2010 EDOP and the addendum from 2014. She further requested Mr. Brewer be able to explain the page with all the odor readings, in particular, the listings of 4:1 to 8:1 and the three (3) cases that were mentioned earlier of higher than average readings. • Chair Freeman recessed at 11:49 a.m. • Chair Freeman reconvened the Show Cause Hearing at 2:05 p.m. and asked staff to begin with answering Commissioner Kirkmeyer's questions presented before the recess. ▪ Mr. Haug began with the question referring to the compliance with EDOPs from 2010 and 2014. He provided a timeline and stated in 2010 there was an EDOP Plan approved by the state with the initial Certificate of Designation and the USR Permit. He further stated that in 2013, another EDOP was approved and in 2014 there was an addendum to the approved 2013 EDOP. With regard to the issues raised about the fencing, signage, if they are off-loading in an enclosed facility, if the waste is piped out of a truck or dumped in the open, Mr. Haug recommended more time to inspect these issues to be able to provide a good factual basis for the Board. • In response to Commissioner Conway, Mr. Haug stated part of the issue is in the DS #6, which references both the 2010 EDOP and the 2013 EDOP with the 2014 addendum. He clarified the 2010 EDOP describes the old design which did not include the Digester Processing System (DPS), and the 2013 EDOP to include the 2014 addendum modified the EDOP to take into account the DPS. • Commissioner Cozad stated the original requirements follow through even if there are addendums or amendments and the only things that would change are the specific items being addressed, otherwise the original requirements are held in place. Mr. Haug verified that to be true. Mr. Barker interjected that one can replace the other if it states that in the Resolution. In response to Commissioner Cozad, Mr. Haug stated they do not replace each other; however, these are two large documents that include portions that clearly state they replace each other; however, there are inconsistencies between the two documents and may need to be investigated more closely to make a determination. Commissioner Cozad reiterated the history of the USR process with the original public hearing that occurred in 2010, at which the public could come and hear the input; whereas, in 2013, a very minor tweak to the permit was madebecause the plat was not recorded, and in 2014 staff reviewed the changes and determined it was a minor amendment to the permit and approved it. • Mr. Barker clarified the DS that carried over states it must comply with the permit which ties back into the EDOP and the CD and he reminded the Board to review what is current and what is not. Chair Freeman interjected there was a public hearing. Mr. Gathman also verified the public was noticed for the 2013 hearing. Commissioner Cozad stated there was a public process that happened with the CD and the USR process. 2016-2843 PL2072 HEARING CERTIFICATION - HEARTLAND BIOGAS, LLC (PCSC16-0004) PAGE 12 el Commissioner Cozad questioned the validity of the CD and in turn the EDOP. Mr. Barker stated the requirement to operate in compliance with the Colorado Air Quality Control Division. Ei Commissioner Cozad requested clarification on consideration of the validity of the CD, and in regard to DS #17, further requested staff report whether the applicant is compliant. Mr. Brewer stated the Permit that the State issued January 20, 2016, shows they are not in compliance with that permit and they were not in compliance on April 27, 2016. Commissioner Kirkmeyer asked for clarification. Mr. Brewer stated it was an Emissions Permit, and reiterated the Permit was issued January 20, 2016, and on April 27, 2016, Heartland was out of compliance with Permit term #12. Commissioner Kirkmeyer asked if the facility is currently in compliance with the EDOP and does staff have enough information to answer that today. IR Ben Frissell, Department of Environmental Health, stated staff is using the approved 2013 EDOP and 2014 addendum for inspection purposes. He clarified the items brought up such as signage and fencing are not typical for Environmental Health. Commissioner Kirkmeyer asked if they are in compliance today. Mr. Frissell stated based on a spot check on June 24, 2016, they were in compliance and there has not been another inspection since that date. He reiterated the Department of Environmental Health does not look at signage or fencing. Commissioner Kirkmeyer asked if a two -stage scrubber was present and he stated he would need to check to see if that is a requirement. Mr. Frissell stated there is an enclosed building; however, wastes are not necessarily stored in that. ci In response to Commissioner Kirkmeyer, Mr. Brewer explained the readings taken and documented. He explained there were 21 readings taken that were greater than 4:1 but less than 8:1 and, therefore, were not violations. He clarified the only violation he has record of was on April 27, 2016. Mr. Brewer stated the violation on April 27th was evaluated on the criterion of greater than 7:1 threshold level and it was reviewed by the state attorney general and determined that it was appropriate because it is a residential level. He stated he is not aware of any changes in the state dilution levels or particularly to Heartland's compliance levels. In response to Commissioner Conway, Mr. Brewer explained the 15:1 dilution level is the industrial level and the 7:1 dilution threshold is for residential areas. le In response to Commissioner Kirkmeyer, Mr. Barker stated today's hearing is based on the original notice which contained the following three issues: 1) The facility shall operate in compliance with the Colorado Air Quality Control Regulations and comply with any permits issued by the Air Pollution Control Division; 2) In accordance with Colorado Air Quality Control Commissioner, Regulation #2, the odor detected off -site shall not exceed the residential 7:1 dilution threshold; and 3) The property owner or operator shall be responsible with complying with all the foregoing Development Standards. Not complying with all the foregoing Development Standards may be reason for revocation of the permit by the Board of County Commissioners. He reiterated that today's notice is looking at the odor issue. He mentioned the Air Quality Control Commission Permit issued on January 20, 2016, contains a compliance requirement that needs to be reviewed which he summarized to conclude that the owner/operator shall develop a revised Operating and Maintenance Plan to include the equipment listed in this permit in record keeping format that outlines how the applicant will maintain compliance with ongoing requirements of this permit. It further says compliance is mandatory beginning at the time of the start-up of the 2016-2843 PL2072 HEARING CERTIFICATION - HEARTLAND BIOGAS, LLC (PCSC16-0004) PAGE 13 anaerobic digester. Commissioner Cozad clarified the owner operator must be in compliance with the operation and maintenance plan which is the same as the EDOP at the time of start-up of the DPS which ties back in with compliance of the permit referenced by DS #17 and noticed as such. Mr. Barker verified that to be true. Commissioner Cozad noted for the record that the respondent was shaking his head in disagreement. Mr. Garcia stated the respondent continues to object to any introduction or consideration of any new information that was not noticed and requests more time to respond. He stated if there are continuing requests for the comparison and contrast of the EDOPs, they can provide that under a brief if that is the request of the Board. He further reminded the Board that the ultimate goal for today is to provide enough information to be able to dismiss this matter. Mr. Garcia reviewed the progress to -date and reiterated that the Board gave Heartland a number of items to perform. • Mr. Thomas stated in the two hour recess they did begin working through those documents and they are large documents and they would need more time to make a complete presentation. He stated today's hearing is about odor and compliance with the odor threshold and insisted Heartland has since been in compliance and they have demonstrated a high level of commitment to mitigation solutions. Mr. Thomas requested more time to prepare. In response to Commissioner Conway, he stated 30 days would be adequate but he asked if it applies to what is being discussed today. He further stated the Operations and Maintenance Plan associated with the permit is not the EDOP, it is a requirement to be provided to the State and describes the specific equipment operation and maintenance associated with plant emissions, for example the operation and maintenance of the equipment that reads the stack. • Commissioner Kirkmeyer stated DS #17 requires compliance with any permits issued by the Air Quality Control Division. In response, Mr. Thomas stated he does not know of any. • Mr. Brewer stated Heartland Biogas has two (2) additional Air Pollution Emission Notices, one for a caterpillar generator that is not permitted and another is for the composting operation and it is not permitted. Mr. Thomas submitted these as an additional emission source and the State deemed they did not require permits. In response to Commissioner Kirkmeyer, Mr. Thomas stated he does not know if there are additional permits. El Commissioner Kirkmeyer asked why it took so long to get a building permit. She reviewed the process of the Probable Cause hearing that began in July and has moved forward to the Show Cause hearing in September and again today. In response, Mr. Thomas stated it has been an ongoing conversation and he began with treating the odors with misting systems and later when the conversation escalated, he continued to identify additional odor sources and seek mitigation solutions as the expectations have changed each time and he insisted the company has been reasonable with following these expectations and has done everything asked of them. He further stated Heartland has even accelerated the dates and are not dragging their feet. In response to Commissioner Kirkmeyer, Mr. Thomas stated he is aware of all the complaints which Mr. Brewer sends on a weekly basis. In further response, he stated if the USR was suspended, he would have to go through the process of shutting the digester down by draining it and removing the material in the digester and being received for the digester and divert this waste elsewhere. He 2016-2843 PL2072 HEARING CERTIFICATION - HEARTLAND BIOGAS, LLC (PCSC16-0004) PAGE 14 further explained he would be unable to meet the requirements of the Air Pollution Control Division to demonstrate compliance with the scrubbers within the 180 -day time frame, and he would be unable to meet the contractual obligations and he conveyed that this would seem excessive for one odor violation. • In response to Commissioner Conway, Mr. Thomas stated he and his company are committed to removing the odor. He stated he understands the odor is a problem and the goal is to improve each day. He reiterated the facility is excellent, recession proof, and financially positive for Weld County. He further reminded the Board that Heartland has agreed with everyone. The goal is to continue to improve. Mr. Thomas stated everyone at the facility reports improvement. He stated he gets whiffs of the odor but cannot find the continuous odor so he is attempting to isolate and treat the brief odors. Mr. Thomas concurred that the neighbors are correct when they report going to the community meetings and he says he is doing something. He reviewed the efforts to mitigate to include building buildings and are making progress with an accelerated construction schedule and a temporary scrubber system. He insisted he does not want the neighbors to endure odors and Heartland wants to make it better. He stated it is a continuous effort and now they are fighting against losing the permit when in fact the facility is in compliance. • In response to Commissioner Moreno, Mr. Thomas explained the process of cleaning out the digester and removing organic waste from the system and the facility. • Commissioner Cozad expressed her frustration with the situation by stating that although Heartland was only out of compliance the one time in April and currently are in compliance with the permit, the odor levels out there are bad for the people who live out there and this puts everyone in a tough position. She further stated the Board must make a decision based on the permit while listening to constituents being impacted by the presence of the facility. She asked if there is a way to expedite the options to address the odor issues and ensure compliance. Mr. Thomas responded the answer is always yes, and although he does not know the exact way to expedite it, he is committed to finding a way. He gave the example of hearing about the temporary substrate system 30 days ago and it is now installed and working. Commissioner Cozad stated although the one documented time of being out of compliance is on record, no one truly knows if Heartland has been out of compliance otherwise. Mr. Thomas interjected that is true; however, he has provided nasal rangers to neighbors to be able to measure and no one has reported a measurement out of compliance. Commissioner Cozad pressed that odor is difficult to measure and the fact is the odor is out there and the smell is bad. Mr. Thomas stated the best way to document the situation is to actually use the nasal ranger. He further stated there are brief transients of odor that are around the 8:1 but the background odor is less than 2:1 and that Heartland is measuring within compliance but continues to go after the bad odors and the transient odors. • Commissioner Kirkmeyer stated this is not pleasant to be going through for anyone; however, she reviewed an email she received on November 5, 2016, regarding the horrible smell and she purposely drove home a different way to observe the smell and stated it made her grandsons want to throw up as they drove past and that every time she drives past the facility, it smells horrible. She stated she does not know if it is a 7:1, 3:1 or 2:1 but she does know it smells horrible and that is what these neighbors are living with and, this is not what the Board was told 2016-2843 PL2072 HEARING CERTIFICATION - HEARTLAND BIOGAS, LLC (PCSC16-0004) PAGE 15 when the permit was approved. Commissioner Kirkmeyer clarified the Board did not approve the 2014 amendment and the 2013 approval was for a clarification. She stated there is still an odor and the public deserves to have their lives back and Heartland should be held accountable. She further stated the Board was under the assumption this had more to do with agriculture and as far as the findings, there isn't anything that requires finding a violation multiple times and to be clear it only takes once for the Board to find cause to revoke a permit. Commissioner Kirkmeyer stated there was other evidence brought forward today and that two (2) hours is not long enough for the respondent or the Board to consider the evidence in reference to the EDOP; however, there is enough probable cause to show there is a possible violation of the EDOP and the standards. El Commissioner Kirkmeyer moved to notice and set a date for another Show Cause hearing to consider the additional evidence in regard to violating Development Standards (DS) #6, #10, #16, #17, #18, #21, #30, #34, #42, and #45, for December 21, 2016, making sure the entire Board is present. She further insisted that it is vital to ensure the validity and compliance of the Certificate of Designation which may not be transferred unless it is reviewed and approved by the State and the County and she stated her motion would include the aforementioned items and the suspension of all operations related to Minor Amendment, MUSR14-0030, to a Site Specific Development Plan and Use by Special Review Permit, USR-1704, for a Solid Waste Disposal Site and Facility (including Class I composting, an animal waste recycling or processing facility [an anaerobic digester -based renewable energy plant gas], along with a concrete batch plant to be used for construction of the facility for the addition of a Digester Process and a 70 -foot flare) in the A (Agricultural) Zone District, by virtue of the violation until December 21, 2016, until the Board makes further determinations. Commissioner Cozad seconded the motion with discussion. In response to Commissioner Cozad, Mr. Barker clarified the purpose of the Probable Cause hearing is to bring to attention enough evidence to move forward to a Show Cause hearing and that if the Board has heard enough probable cause today, and the proper notification is sent to the respondent, the Board can move forward to another Show Cause hearing. In response to Mr. Barker, Commissioner Kirkmeyer stated it is correct that her motion to move forward with another Show Cause hearing is based on the SPO presentation, the respondent's comments to follow up questions, and the basis that staff is not certain the respondent is in compliance with the 2013/2014 addendum to the EDOP or the aforementioned Development Standards along with information received at the prior hearing on September 19, 2016. El Commissioner Cozad agreed with Commissioner Kirkmeyer and stated she had most of the same Development Standards written down and the direction to have another Show Cause hearing is reflective of testimony from today and the hearing on September 19, 2016. The Commissioners have all been in that area and observed some of these issues resulting in her support of the motion. In response to Commissioner Cozad, Chair Freeman clarified that part of the motion was to suspend the license until the Show Cause hearing. CI Chair Freeman suggested there be two (2) separate motions, one motion regarding the suspension, and one motion for the additional Show Cause hearing. Commissioner Kirkmeyer reminded the Board what is before them today is to revoke, suspend or dismiss the permit and she suggested further discussion regarding the motion. She further stated at the prior hearing they suspended, in part, and gave the respondent two (2) months to come back with solutions 2016-2843 PL2072 HEARING CERTIFICATION - HEARTLAND BIOGAS, LLC (PCSC16-0004) PAGE 16 and one of the solutions was to operate at 100% which is not viable at this point. She reiterated her reasons for recommending a suspension. • Commissioner Cozad stated the Board is back to where it was in September and the neighbors continue to put up with the odor. She continued that while efforts have been made by the respondent, a suspension takes time to clean everything out and between now and December 21, 2016, she is not sure there will be much of a difference other than not having additional waste being brought in. She expressed interest in keeping the permit with the current restrictions and would appreciate more discussion. • Commissioner Moreno stated this is a tough discussion as he has smelled the odor on -site and it is awful and made him feel like vomiting; however, he stated he also hears what the respondent is saying and that it takes time to shut the facility down. He expressed his struggle with a suspension at the same time they are constructing new buildings, and he recommended minimizing the product coming in. • Commissioner Conway stated he is looking at the unintended consequences and he has also smelled the odor. He stated he is trying to figure out the measurement threshold and he is more in line with the comments from Commissioners Cozad and Moreno regarding making progress toward solutions to include the construction of the new building and not knowing what impact the building will have. Commissioner Conway stated he empathizes with the neighbors but continues to ask the question of how do we get to the point of what we were promised in 2010 and is it possible that if right plan is implemented we will get there. He stated he is wary of shutting down the facility and he does not want to halt the remedies that are in progress. • Commissioner Cozad asked if there is a way to do additional monitoring on a regular basis and require the applicant to cover the cost of that. She stated she thinks there may be times of violations not being documented and a third party, other than Trinity Consultants, may provide additional information. • Commissioner Kirkmeyer stated she continues to support a suspension because the neighbors out there deserve a peaceful Thanksgiving and Christmas. She reiterated the effort to limit the intake and production at the prior hearing and it still stinks and makes you want to throw up; therefore, nothing has changed and that is not a good neighbor. She asked for further suggestions if the Board does not want a suspension but insisted there has to be a clear message sent that we are not guinea pigs and we deserve better. She reminded the Board of the prior limitation and stated nothing has changed. Commissioner Moreno asked if there is data showing complaints from last year and if the colder weather has a relation to the odor complaints. In response to Commissioner Moreno, Mr. Brewer stated he has not analyzed the number of complaints by month but he can attest to receiving over 500 complaints since November 11, 2015, and he offered to analyze the data if the Board wishes. Commissioner Conway asked if there is a weather correlation to the complaints. Mr. Brewer stated he does not know. 2016-2843 PL2072 HEARING CERTIFICATION - HEARTLAND BIOGAS, LLC (PCSC16-0004) PAGE 17 • After further discussion regarding materials received, Commissioner Cozad stated there is no way of coming up with a number. Commissioner Conway stated he can support keeping the restriction at the current level based on the requirements of the Resolution from September 19, 2016. Mr. Barker read the restrictions from the aforementioned Resolution. • Commissioner Cozad moved to amend the motion to a suspension, in part, to limit the gas production to 60% and limit the organic materials received to the current amount and again have two additional community meetings with proper notice provided. Chair Freeman asked for clarification regarding community meetings and Commissioner Kirkmeyer recommended keeping the same conditions from the previous Resolution. Commissioner Cozad agreed to the amendment. Commissioner Conway seconded the amended motion. El Commissioner Kirkmeyer stated she can appreciate the amended motion regarding the suspension, but she will be voting against it. Commissioner Cozad stated she does not disagree with Commissioner Kirkmeyer's comments; however, she expressed her hope for true mitigation and resolution otherwise it could come to the point of additional conditions not being met and the permit being revoked. • Commissioner Conway expressed his appreciation for the comments of his fellow Commissioners and expressed his empathy for the neighbors; however, he insisted there are unintended consequences with a suspension and the problem has to be addressed and fixed. He stated there are some options submitted by Heartland that should be considered, the Board has requested the process be expedited and he is willing to wait until December 21, 2016, to see the progress and additional evidence presented at that hearing. • Commissioner Moreno expressed his respect for the comments from his fellow Commissioners; however, based on what he has heard he supports a suspension. • Chair Freeman expressed his appreciation for the comments from his fellow Commissioners and he expressed empathy for the neighbors; however, he also recognized the efforts being made by Heartland. He stated he wants to see progress and the problem fixed. • Chair Freeman asked for a roll call vote on the amended motion, resulting in a 3-2 split vote with Commissioners Kirkmeyer and Moreno voting "NO." • Commissioner Kirkmeyer clarified the motion regarding the Show cause which was seconded by Commissioner Cozad, and stated there are Findings of Fact of an admitted violation on April 27, 2016, which concludes there is an admitted violation of what was previously noticed referencing Development Standards (DS) #17, #21, and #45; therefore, she moved to schedule an additional Show Cause hearing for December 21, 2016, to review the additional evidence presented regarding possible violations to Development Standards #6, #10, #16, #17, #18, #21, #30, #34, #42, #45, to be included in the notice, and also to include a review of the validity of the Certificate of Designation to be determined, and with direction to staff to review the EDOP and the regulations for solid waste disposal facilities. 2016-2843 PL2072 HEARING CERTIFICATION - HEARTLAND BIOGAS, LLC (PCSC16-0004) PAGE 18 IR Mr. Barker recommended clarifying the suspension. In response to Mr. Barker, Commissioner Kirkmeyer clarified, as a part of her motion, the suspension is now, in part, with the same conditions in the Resolution from September 19, 2016, with limitations on waste and production and the requirement to have community meetings. Chair Freeman called for a roll call vote on the amended Resolution resulting in unanimous approval. He thanked the public for attending and with no further discussion, the meeting was adjourned at 3:40 p.m. (Clerk's Note: the additional Show Cause hearing set for December 21, 2016, was subsequently reconsidered on November 16, 2016, and was unanimously moved to December 19, 2016, due to a scheduling conflict that was unknown at the time of this hearing.) This Certification was approved on the 16th day of November, 2016. BOARD OF COUNTY COMMISSIONERS WELD COUNTY, COLORADO ATTEST: dddiyv ..aCl/o;ok• Weld County Clerk to the Board APPRO ounty Attorney Date of signature: I/13/ (C2 Mike Freeman, Chair Sean P. 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