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HomeMy WebLinkAbout4.0 Inspection & Compliance InfoSTATE OF COLORADO Bill Owens, Governor Jane E. Norton, Executive Director Dedicated to protecting and improving the health and environment of the people of Colorado Grand Junction Regional Office 222 S. 6th St., Rm 232 Grand Junction, CO 81501-2768 Fax (970) 248-7198 July 16, 1999 Mr. James R. Duke, President CacaLoco Compost Inc. 0256 Flying Fish Road Carbondale CO 81623 RE: inspection of the CacaLoco Compost Facility Dear Mr. Duke: Colorado Department of Public Health and Environment On June 24, 1999 a representative of this Division performed an inspection of the CacaLoco Compost facility approximately six miles west of Glenwood Springs, Colorado. The purpose of this inspection was to assess the compliance of this facility with the minimum standards of the Solid Wastes Disposal Sites and Facilities Act Title 30, Article 20 part 1, C.R.S., as amended and with the Department Regulations promulgated thereunder. A copy of the field inspection report is enclosed for your reference. No violations were noted. The facility was found to be in compliance with the Departments regulations referenced on the date of inspection. The northwest septage impoundment has been filled with wood waste that is to be excavated and incorporated into compost when and if there is a wood shortage. The east impoundment is actively being filled with wood for the same purpose. The northeast impoundment is dry and is currently being excavated and then will be lined to be put into service as a run-off retention basin and or emergency storage for septage. Mr. Duke agreed to supply an annual report summarizing volume flows at the facility as well as analytical results and temperature documentation. I would be glad to discuss specific details with you concerning the site. Please contact me at 248-7168 if you have any questions regarding this letter. Sincerely, onna Stoner Solid Waste Unit Compliance Program cc:Chris Isgrig, South Canyon Landfill t/Mr. Mark Bean, Garfield County SW GAR CAC 1B STATE OF COLORADO Bill Owens, Governor Jane E. Norton, Executive Director Dedicated to protecting and improving the health and environment of the people of Colorado Grand Junction Regional Office 222 S. 6th St, Rm 232 Grand Junction, CO 81501-2768 Fax (970) 248-7198 June 27, 2000 Mr. James R. Duke, President CacaLoco Compost Inc. 0256 Flying Fish Road Carbondale CO 81623 RE: Inspection of the CacaLoco Compost Facility Dear Mr. Duke: Colorado Department of Public Health and Environment On June 1, 2000 a representative of this Division performed an inspection of the CacaLoco Compost facility approximately six miles west of Glenwood Springs, Colorado. The purpose of this inspection was to assess the compliance of this facility with the minimum standards of the Solid Wastes Disposal Sites and Facilities Act Title 30, Article 20 part 1, C.R.S., as amended and with the Department Regulations promulgated thereunder. A copy of the field inspection report is enclosed for your reference. Any violations cited by subsection may referenced in the Regulations. The result of the inspection indicates that this facility is in non-compliance with the Department Regulations referenced above on the date of the inspection. The specific items of non-compliance are listed. 1. The compost operation has exceeded the boundaries of the liner and has some finished product off of the liner. This is in violation of subsection 3.4 (E). Mr. Duke has agreed to extend the liner or contain operations on the liner. 2. Cardboard and paper are now being used as compost bulking material. These materials were not included in the original design and operation plan. This is also in violation of subsection 3.4(E). 3. Windblown paper was noted behind (south) of the trailer in the weeds and trees in the area. This is in violation of subsections 2.1.3 and 2.1.7. Mr. Duke has agreed to construct a screened containment area for the paper and cardboard. Mr. Duke has also agreed to update the design and operation plan for this facility to include the waste streams mentioned in item #2, the containment device for the paper products mentioned in item #3 and the extended liner mentioned in item #1, if it is to be built. Mr. Duke has agreed to supply recent monitoring results. The northeast storm water impoundment had water in it from a recent storm event. This impoundment is usually Mr. Duke CacaLoco Compost July 3, 2000 Page 2 I would be glad to discuss specific details with you concerning the site. Please contact me at 248-7168 if you have any questions regarding this letter. 'ncerely, Donna Stoner Solid Waste Unit Compliance Program cc: Mi;Xhris Isgrig, South Canyon Landfill frMr. Mark Bean, Garfield County SW GAR CAC 1.2 File County Facility Location Current Operat•r Mailing Address of Operator Current Owner (If different) Mailing Address of Owner "'"" FACILITY INSPECTION (Surface Impoundments) Located in Incorporated Area I (� . - -Cat Jko- L - fly (All items checked must be explaind in supplemental report) I. A. Public Health and/or Environmental Hazards B. Evidence of Potential for (Serious) Surface Water Pollution C. Evidence of Potential for (Serious) Groundwater Pollution D. Sludge or Septic Pumpings Disposal on Site (Unauthorized) E. Safety Hazards . F. Non -Compliance with Approved Design and Operation �4,t i QL G. Structural Integ ity o D kes Questionable %C', H. Records -Lo.„ (.+{_17-- I. Other * REMEDIAL ACTION REQUIRED II. Minimum Standards, CRS 30, 20-110 A. Odors and/or Vectors Present B. Inadequate Fencing (to control access) C. Not Designated and/or Improperly Zoned D. Monitoring Wells (Maintenance, Intregrity, Present) E. Evidence of Minor Spills Around Disposal F. Water/Liquid Surface Covered with oil(s) :ERG. Depth Gauges not Present and or Readible H. Pond Freeboard Level Exceeded. I. Recommendations for Site Improvement J. Other \ II Remar or Locking Cap not Area or scum L atiatiSIMI WO .4%1WWIR, _ nib �n':!_':L�►W-��.. iiM 1 • =�a3s�3=a3ssa a,s (Name) PRESENT T INSPECTION Representing) ===== Inspection Engineer/Geologist (WHITE COPY -FILE) (YELLOW COPY OPERATOR) (PINK COPY-C0)NTY) RECEi ED AUG 0 8 2000 August 7, 2000 Ms. Donna Stoner Solid Waste Unit Compliance Program Grand Junction Regional Office 222 S. 6t' St., Rm. 232 Grand Junction, CO 81501-2768 RE: Inspection of the Caca Loco Compost Facility Dear Ms. Stoner, In response to your letter of June 27, 2000 and notice of non-compliance we have taken the following actions: 1. Any compost exceeding the boundaries of the liner has been returned to the lined area and will be contained there. 2. An addendum to the original operations plan is being submitted to include the use of paper and cardboard products as bulking material (see attached). 3. An extensive litter pick-up was conducted and will be continued as necessary. Rather than constructing a screened enclosure, a covered trailer has been provided for the deposit of paper and cardboard. Materials thus collected will then be incorporated directly into incoming biosolids or covered with woodchips until used to prevent windblown litter. Producers of large volumes of waste paper such as document shredding companies will be required to schedule their drop-offs so as to insure that staff will be on site to secure these materials through incorporation with biosolids or wood chips to prevent wind blown litter. 4. The most recent lab results have been included (see attached). Please let me know if there's anything else that needs to be addressed at this time. Sincerely, m Duke CacaLoco Compost cc. Mr. Chris Isgrig, South Canyon Landfill Mr. Mark Bean, Garfield County Dear Ms. Stoner, Here are the proposed changes to CacaLoco's original operations plan: We would like to include the use of waste cardboard and other waste paper products as bulking material in our compost operation. We have been utilizing these materials on a trial basis over the past year and found them to work very well even without being ground or shredded. An enclosed trailer will be provided for the deposit of these materials next to the recycling containers. Materials thus collected will then be transferred and incorporated directly into incoming biosolids or covered with wood chips until used to prevent windblown litter. Producers of large volumes of these materials, such as document destruction companies, will be required to schedule their drop-offs to insure that staff will be on site to contain these materials with either biosolids or woodchips. A on going litter picking operation will also be conducted as a backup to these other litter prevention measures. CacaLoco has decided not to implement any expansions of the site at the present time but will keep all appropriate materials within the limits of the lined mixing pad. Thanks for your time in considering these proposed changes. Sincerely, Jim Duke CacaLoco Compost COLORADO \ ANALYTICAL \ LABORATORY t AE3ORATORY TESTING SERVICES LABORATORY ANALYSIS REPORT REPORT TO: JIM DUKE LA H N07 9739 DATE RCVD: 7/10:00 BILL TO: CACALOCO COMPOS I, INC. 256 FLYING FISH ROAD RLPOR'1'ED: 7/31/00 CARBONDAI F., CO 81623 PO NO.: VERBAL,, ANALYSIS PIQUES1ED: 1 SAMPLE FOR STD COMPOST I METALS BICSOLias ANALYSIS SAMPLE ID: SLUDGE COMPOST REC 7/10/910 ANA.LYSIS REPORT: PARAM,6TER AS RECEIVED BASIS DRY MA'rI`SB SAS14 SOLIDS -TOTAL (%) 71.28 100.00 MOISTURE (%) 74.72 0.00 ORGANIC MA'G'I R (%) 36.10 50.65 ASH CONTENT (%) 35.18 49.35 CONDUCTIVITY -SP (MMHOVCM425c) 3.73 pE (UNITS) 7.1 • NI'CROG - fO'L AL (%) 0.392 0.530 NITROGEN -AMMONIA (%) 0.66511 0.0070 NITRUGL N -NI ERA'I'E (%) 0.901 0.001 TOTAL PIIOSPIIORUS (%) as 1r 0.059 6.083 as P205 0.136 6.191 TOTAL POTASSIUM (%) as K 0.123 0.172 as K20 0.147 0.206 TOTAL CADMIUM (MG/KG) 1.0 1.4 'D'I'AL COPPER (MG/KG) 18.6 26.1 TOTAL LEAD (MG/KG) 4.1 5.8 TOTAL NICKEI, (MG/KG) 6.7 9.4 TOTAL, ZINC (MG/KO) 55.2 77.5 TGTAL ARSENIC (MG/KG) 0.4 0.6 TOTAL CHROMIUM )MO/Kti) 6.4 9.0 TOTAL MERCURY (MG/KG) <.2 <.Z TOTAL. MOLYBDENUM (MG/KG) 1.4 1.9 TOTAL SELENIUM (MG/KG) 0.2 0.2 FECAL COLIFORM (MPN/G) a2. CARBON/NITROGEN RATIO 484 lb 485 S40 S. Meir Street • Brighton, Cola -ado BOSG1 C303) 65S•Q313 Moiling Address PC. Orawer 507 Eiripticcn, Colorecto 80801 Donna Stoner, Environmental Specialist Colorado Department of Public Health and Environment 222 S. 6th Street, Rm. 232 Grand Junction, Colorado 81501-2768 April 16, 2002 Dear Ms. Stoner, RECEIVED APR 1 7 2002 The following is being submitted as the 2001 Annual Report for Cacaloco Compost per section 14.2..2 of the Composting Regulations. In the calendar year of 2001 Cacaloco Compost sold 2,852 cubic yards of compost. In the Calendar year of 2001 Cacaloco Compost accepted approximately the following volumes of various materials: 11,060 cubic yards of wood and paper wastes for use as bulking material. 2,680,050 gallons of sewage averaging less than 3% solids. 1697 cubic yards of sludge or dried cake averaging less than 15% solids. The majority of the bulking material received consisted of brush and construction waste wood in fairly even proportions with grass, leaves, and waste paper products comprising a fairly small minority of the material. Tree limbs and brush generally grind down to about 20-30% of their original volume (70-80% volume reduction) while construction waste wood generally grinds to about half it's unground volume. Averaging these percentages of reduction gives us about a 65% reduction in volume from the grinding process. The composting process involves another reduction in volume as the material digests and settles. Composting generally results in about a 40% loss of volume while the screening pulls off another 20% (returned to compost process;) of this remaining volume for a total volume loss of just over 50% during the composting and screening processes. The mixing of these bulking materials with the biosolids does not increase volumes as the biosolids basically just fill the airspace in the bulking materials. For these reasons, the sum total of all the above material is processed into about 3,500 cubic yards of finished compost. Of the 2,852 cubic yards sold, the majority came from raw materials received the year before. Because our sales season ends generally by the end of October, any material received after June of each year will not complete the 90 day total retention requirement in time to be marketed that same year. For this reason, approximately half of all material received is kept in the process or in stockpiles over the winter until the next growing season. In the calendar year 2,001 about 2,500 cubic yards of bulking material, compost, and stages in between remained on site at the end of the year. I hope this little narrative fulfills the reporting requirements and helps you understand the flow of materials through our site. Also, we have palletized all used oil containers and blamed in our fuel tanks as you requested. Please let me know if there's anything else you need from us at this time. Jim Duke, CacaLoco Compost Sincerely, 44 - Mr. Chris Isgrig, South Canyon Landfill Mr. Mark Bean, Garfield County RECEIVE) OC1 0 9 2001 STATE OF COLORADO Bill Owens, Governor Jane E. Norton, Executive Director Dedicated to protecting and improving the health and environment of the people of Colorado Grand Junction Regional Office 222 S. 6th St., Rm 232 Grand Junction CO 81501-2768 Fax (970) 248-7198 http://www.cdphe.state.co.us October 2, 2001 Mr. James R. Duke, President CacaLoco Compost Inc. 0256 Flying Fish Road Carbondale CO 81623 RE: Inspection of the CacaLoco Compost Facility Dear Mr. Duke: Colorado Department of Public Health and Environment On August 16, 2001 representatives of this Division performed an inspection of the CacaLoco Compost facility approximately six miles west of Glenwood Springs, Colorado. The purpose of this inspection was to assess the compliance of this facility with the minimum standards of the Solid Wastes Disposal Sites and Facilities Act Title 30, Article 20 part 1, C.R.S., as amended and with the Department Regulations promulgated thereunder. A copy of the field inspection report is enclosed for your reference. Any violations cited by subsection may be referenced in the Regulations. The result of the inspection indicates that this facility is in non-compliance with the Department Regulations referenced above on the date of inspection. The specific items of non-compliance are listed. 1. The Annual Report for year 2000 has not been submitted. This is in violation of subsection 14.2.2(A) of the Regulations. The outlined area of non-compliance must be addressed in order to protect the local public and the environment. The Division requests that a response be submitted within 30 days of this letter regarding area of non-compliance. I would be glad to discuss specific details with you concerning the site. Please contact me at 970-248-7168 if you have any questions regarding this letter. Sincerely, Donna Stoner Solid Waste Unit Compliance Program cc: Mr. Chris Isgrig, South Canyon Landfill i . Mark Bean, Garfield County SW GAR CAC 1.2 File RECEIVED OCT 2 ,, 2111 Donna Stoner, Environmental Specialist Colorado Department of Public Health and Environment 222 S. 6th Street, Rm. 232 Grand Junction, Colorado 81501-2768 October 22, 2001 Dear Ms. Stoner, In response to your letter of October 2, 2001 and the associated notice of non-compliance, the following is being submitted as the 2001 Annual Report for Cacaloco Compost per section 14.2.2 of the new Composting Regulations. In the calendar year of 2000 Cacaloco Compost sold 1,056 cubic yards of compost. In the Calendar year of 2000 Cacaloco Compost accepted approximately the following volumes of various materials: 9,467 cubic yards of wood and paper wastes for use as bulking material. 2,130,051 Gallons of sewage averaging less than 2% solids. 719 cubic yards of sludge or dried cake averaging less than 20% liquids, The majority of the bulking material received consisted of brush and construction waste wood in fairly even proportions with grass, leaves, and waste paper products comprising a fairly small minority of the material. Tree limbs and brush generally grind down to about 20-30% of their original volume (70-80% volume reduction) while construction waste wood generally grinds to about half it's unground volume. Averaging these percentages of reduction gives us about a 65% reduction in volume from the grinding process. The composting process involves another reduction in volume as the material digests and settles. Composting generally resu itc in about a 40% loss of volume while the screening nulls off another 20% (returned to compost process) of this remaining volume for a total volume loss of just over 50% during the composting and screening processes. The mixing of these bulking materials with the biosolids does not increase volumes as the biosolids basically just fill the airspace in the bulking materials. For these reasons, the sum total of all the above material is processed into about 1600 cubic yards of finished compost. Of the 1056 cubic yards sold, the majority came from raw materials received the year before. Because our sales season ends generally by the end of October, any material received after June of each year will not complete the 90 day total retention requirement in time to be marketed that same year. For this reason, approximately half of all material received is kept in the process or in stockpiles over the winter until the next growing season. In the calendar year 2,000 about 1,500 cubic yards of bulking material, compost, and stages in between remained on site at the end of the year. I hope this little narrative fulfills the reporting requirements and helps you understand the flow of materials through our site. Our sales this year (2001) have almost tripled last year's by the way. Also, we have palletized all used oil containers and burmed in our fuel tanks as you requested. Please let me know if there's anything else you need from us at this time. Jim Duke, CacaLoco Compost Sincerely, L•L:4 cc: Mr. Chris Isgrig, South Canyon Landfill Mr. Mark Bean, Garfield County RECEIVED JUN 1 4 2002 STATE OF COLORADO Bill Owens, Governor Jane E. Norton, Executive Director Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 TDD Line (303) 691-7700 Located in Glendale, Colorado http://www.cdphe.state.co.us June 12, 2002 Laboratory and Radiation Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Certified Mail # ,2 y6 :S` tf 4'3 -- Return Receipt Requested Mr. James R. Duke, President CacaLoco Compost Inc. 0256 Flying Fish Road Carbondale CO 81623 Colorado Department of Public Health and Environment RE: Compliance Advisory — CacaLoco Compost Facility This Compliance Advisory provides notice related to information gained during an inspection of the CacaLoco Compost Facility, conducted by the Colorado Department of Public Health and Environment, Hazardous Materials and Waste Management Division ("the Department") on June 5, 2002. The inspection was conducted to assess the compliance of the facility with the Solid Waste Disposal Sites and Facilities Act, Title 30, Article 20, Part 1, C.R.S. as amended (Act), and the Regulations promulgated thereunder, 6 CCR 1007-2 (Regulations). The Department advises you that the information gained during the inspection indicates that the CacaLoco Compost Facility may have violated Colorado's solid waste law. Department personnel will review the facts established during this inspection and this notice may be revised to include additions or clarifications as a result of that review. Please be aware that you are responsible for complying with the State solid waste regulations and that there are civil penalties for failing to do so. The issuance of this Compliance Advisory does not limit or preclude the Department from pursuing its enforcement options concerning this inspection including issuance of a Compliance Order and/or seeking an assessment of civil penalties. Also, this Compliance Advisory does not constitute a bar to enforcement action for conditions that are not addressed in this Compliance Advisory, or conditions found during future file reviews or inspections of your facility. The Department will take into consideration CacaLoco Compost Facility's response to the requested actions listed below for each cited deficiency in its consideration of enforcement options. Mr. James Duke, President CacaLoco Compost June 12, 2002 Page 2 Deficiency 1. The facility no longer operates in compliance with its design and operation plan. This is in non-compliance with subsection 14.4.2(c) of the Regulations. The wood storage area overlaps into the run-off containment pond and into the excess septage/overflow containment pond. Mixing of septage and bio -solids is sometimes being conducted in the overflow containment area. The facility was originally designed to incorporate all incoming septage into the compost piles. Deficiency 2. Storm water run-off that has mixed with septage and some of the solids dredged from the hypalon-lined pond has been intentionally diverted to the run-off containment pond, creating a nuisance condition and potential public health concern. This is in non-compliance with subsections 14.2.1 and 2.1.3 of the Regulations. All excess septage and the solids dredged from the hypalon-lined pond are to be re- circulated back onto the compost mixing area in compliance with the original design. Deficiency 3. The surface water run-on control structure now merges with the facility's run-off control measure. The surface water flowing onto the site then mixes with the leachate from the site. This is in non-compliance with subsection 14.2.1 and 14.4.3 of the Regulations. Although a berm has been constructed to direct the run-on and run-off mixture into the clay lined run-off containment pond, evidence of fluid bypassing this structure was evident. The visible flow pattern stops at a point where the surface water run-on control drainage, on the east side of the operations area, ends and a downhill slope is apparent. This is approximately '/2 mile west of South Canyon Creek. Additionally, material screened out of the final compost product has formed a pile that blocks the run-on control channel in one spot. In general it appears that the operation has outgrown its original plan and perhaps the physical space of the original design. Additionally, a design problem that does not allow for proper or easy clean out of the septage and bio -solids from the hypalon-lined pond has lead to improper management practices of these materials. These practices include the intentional mixing of the septage and bio -solids with wood chips in the clay lined overflow containment and not on the clay lined pad. Also, the septage and bio -solids have been intentionally directed into the clay lined run-off containment producing the nuisance condition and potential public health concern. Mr. James Duke, President CacaLoco Compost June 12, 2002 Page 3 You may contact me at 970-248-7168 or Glenn Mallory at 303-692-3445 concerning the deficiencies detailed under this Compliance Advisory and/or to set a meeting to discuss this Compliance Advisory. Sincerely, Z6).- 4":>. g Donna Stoner Solid Waste Unit Compliance Program Enclosure cc: Mr. Chris Isgrig, South Canyon Landfill Mr. Robin Millyard, , Public Works Director Mr. Mark Bean, Garfield County Mr. Wes Carr, WQCD, Denver Mr. Dwain Watson, WQCD, Grand Junction SW GAR CAC 1.6 File Glenn F. Mallory Solid Waste Unit Compliance Program Donna Stoner, Environmental Specialist Colorado Department of Public Health and Environment 222 S. 6th Street, Rm. 232 Grand Junction, Colorado 81501-2768 June 2.5, 2002 Dear Ms. Stoner, RECEIVED JUN 2 7 2I102' This letter is in response to your Compliance Advisory dated June 12, 2002. Please excuse my tardiness in responding. I was initially unclear as to whether you desired a written response or if that was unnecessary in light of your upcoming reinspection.. At any rate, please accept my. apoiogies In regard to Deficiency 1. The recent coal seam fire unfortunately resolved the problem of the overflowing wood piles. Although not as cost effective as having wood delivered to my site for bulking agent, I have basically unlimited access to bulking agent in the form of used animal bedding from the numerous stables in our area as well as from several other sources such as utility line clearing contractors and sawmills in our area. These sources will allow our operation to continue while our wood stock piles accumulate. As we have discussed in the past, the wood grinding contractors desire the largest possible quantities of wood prior to setting up for grinding and are considerably more cost effective with larger quantities. 1 obviously exceeded the limits at least for the general appearance of the site and will not allow this to happen again. In regard to the mixing of biosolids and bulking agent in the overflow area, this was done only the one time and will not be repeated. While our system has worked well in general, our greatest design flaw is the difficulty in removing solids from our hypalon lined lagoon which has proven necessary about once a year. Having tried several methods such as pumper trucks and large solids handling pumps with limited success and great expense, we attempted to purnp as much liquid back up to our approved mixing area with a six inch trash pump thinking that the remaining solids would be thick enough (12-14% solids) to be trucked up to our mixing area, in a regular dump truck.. The material proved still too sloppy for this to be practical and while too thick to be pumped uphill, it was marginally possible to pump the material the short distance downhill to our stock pile of bulking agent where it could be mixed and thickened with wood chips to the point that it could be transported up the hill without spilia.ge. This was never intended as a routine practice, but only as a one time effort to get us by until the improvements we have discussed to remedy this design flaw could be implemented. While this was a poor decision and an unacceptable solution, I would like to point out that this was conducted in such a fashion that little if any leachate could soak beyond the wood chip pad the sludge was put on and any leachate that. might have resulted would still be contained in the limits of the historic biosolids lagoon upon which this operation was conducted. In other words, any potential leachate would not have left our site nor even reached an area that had not been historically used as a biosolids impound. Regardless of this weak defense, it was obviously a poor decision and improper practice and will not be repeated I am currently working with Schmueser Gordon Meyer Engineering firm to remedy this situation through the new design we have discussed (shotcrete over the hypalon in the current lagoon and the addition of an overflow lagoon) and hope to have the improvements operational this fall. Deficiency 2. This was also a result of our improper effoits to remove solids from our hypalon lined lagoon and will not be repeated. Once again, although not acceptable, all materials were at least confined to an area historically used for biosolids storage. Deficiency 3. As our operation and volumes increased, the area used for pfrp and 90 day retention began to extend into an area that, although approved for this use in our permit, had previously not been used and was diverted away as run-on. As we began to use this area, the easiest quick fix (because we have so little run on) was to treat everything as run off and divert it into a retention pond. This situation has been rectified so that any runoff from pfrp and stockpile areas is kept separate frorri any run-on and is diverted back to the hypalon lined pond as originally designed. Please accept my apologies for having become lax in keeping up with the growth of my operation. I sincerely hope that all involved will be nothing but impressed with future inspections. Sincerely, Ite im Duke, CacaLoco Compost cc Mr. Chris Isgrig, South Canyon Landfill Mr. Robin Millyard, Glenwood Springs Public Works Director Mr. Mark Dean, Garfield County Mr, Wes Carr, WQCD, Denver Mr. Dwain Watson, WQCD, Grand Junction Mr. Glen Mallory, State of Colorado Solid Waste Unit Leader Donna Stoner, Environmental Specialist Colorado Department of Public Health and Environment 222 S. 6th Street, Rm. 232 Grand Junction, Colorado 81501-2768 December 13, 2002 Dear Ms.. Stoner, REC ; JVED DEC `i 1ilU1 GARFIELD COUNTY BUILDING 8, PLANNING Attached please find the proposed expansion plan for the CacaLoco compost operation at the South Canyon Landfill. Also attached please find the Construction Plan and the updated Operations Plan for this site. The engineering process proved somewhat more lengthy than I had expected reducing my hopes of completion of construction during the fall and winter off-season. The plan has been modified, however, to allow construction without significant site closure so timing is not quite so critical anymore. This proposed phased construction is outlined in the Construction Plan. Depending, of course, on your pending approvals as well as weather conditions throughout the winter, we're still hoping for completion by raid to late spring. Thanks for your time in reviewing these documents. Jiiat Duke, President CacaLoco Compost v Sinceely, cc. Mr. Chris Isgrig, South Canyon Landfill cc. Mr.. Robin Millyard, Glenwood Springs Public Works Director cc Mr. Mark Bean, Garfield County cc Mr. Wes Carr, WQCD, Denver CONSTRUCTION PLAN The primary changes in site plans since our last discussion involve the switching the locations of the riew proposed poly -lined pond and the site run-off pond as well as the deepening of the poly -lined pond. The locatiocis of the ponds were changed in order to keep the poly -lined pond further from public access for safety and odor reduction purposes. The site runoff pond will generally be empty and will not have the slick sides or active aeration as will the poly -lined pond. The proposed depth of the poly -lined pond has been increased for two reasons. Realizing that wide shallow ponds are most efficient for evaporative losses, we still wanted the additional storage of a deeper pond, This will allow some storage capacity during winter months when evaporative losses are minimized and will also extend the useful life of the pond by allowing more storage for the solids that settle out. The difficulty and expense of constructing a pond that would allow equipment access for the removal of solids (as we had originally discussed) proved this to be a less feasible approach than increasing the depth to allow a longer t.irne frame for solids to accumulate with the assumption that the liner will be sacrificed and reconstructed when the pond finally needs to be cleaned out. We have also proposed the installation of two large sand trap type catch basins immediately above each of the poly -lined ponds to settle out solids prior to discharge into these ponds tUnher extending their useful lives. The sand traps will consist of customized, 2,500 gallon, concrete septic tanks designed to be cleaned out by use of a backhoe bucket. The use of these sand traps will also allow the construction of the proposed improvements with a minimum time of amount of site closure. With the larger down gradient poly -lined pond being constructed first, the furthest up gradient sand trap could be Installed to intercept and temporarily divert biosolids to bypass the up gradient poly - lined pond allowing construction of this pond without site closure (see site plan for details). Our final improvement will involve the expansion of the existing recompacted clay pad extending it east to our access road. It is hoped that these improvements will accommodate any increased volumes of incoming materials for at least the next five to ten years. Thanks for your time in reviewing these plans. REVISED OPERATIONS PLAN For CACALOCO COMPOST Revised December 11, 2002 HOURS: The compost facility will have the same hours as South Canyon Landfill, The South Canyon Landfill office is responsible for the collection of tip fees for. the Compost Facility so that hours of operation, fencing, and security measures are the same as those listed in the South Canyon Landfill Operations Plan. DESCRIPTION OF PROCESS: While the basic operation of Cacaloco's compost facility at South Canyon Landfill has not changed significantly, proposed expansions and improvements have necessitated the revision of the Operations Plan. This Operations Plan is intended to replace rather than supplement the existing Operations Plan. The Cacaloco facility accepts a wide range of organic material including construction waste wood, yard wastes, manures and spoiled hay, and waste paper products to be used as bulking agent to mix with biosolids. Materials such as construction waste wood and and trees or branches that need to be ground or shredded prior to use as bulking agent are currently being accepted at the lower end of the site over the areas historically used as biosolids impounds (see attached site plan). Materials such as leaves, grass, and hay that don't need size reduction prior to composting are received just above the recompacted clay pad used for the mixing of biosolids and bulking agents (see plan). Waste paper products are received in a trailer located near the other recycling containers near the landfill's office trailer. Large quantities of waste paper are accepted above the recompacted clay pad and are immeadiatley either incorporated into biosolids in the mixing area or covered with other bulking agents to prevent wind blown litter. The shredded waste wood, leaves, paper, and other such bulking agents are constructed into a small 'lagoon' on the recompacted clay pad to capture and retain the incoming biosolids. The incoming biosolids are dumped directly into this bulking agent `lagoon' where solids are filtered out as liquids percolate through the bulking agent and eventually flow into the currently hypolon-lined pond proposed to by relined with polyethaline. As this bulking agent `lagoon' approaches saturation, it is stirred and further mixed by use of a backhoe or excavator several times over a couple of days and then moved slightly downgradient on the recompacted clay pad and reformed into a small secondary 'lagoon' for further soaking and percolation of liquids. This process allows sufficient retention time for bulking agents to become thoroughly saturated. The saturated bulking agent is then moved to a lateral position on the recompacted clay pad outside the flow of incoming biosolids where it is stacked up and allowed to drain and come up to temperatures. The proposed expansion of the recompacted clay pad will be utilized for this draining and initial heating process. When the biosolids and bulking agent mixture has thoroughly drained and exceeded 55 degrees centigrade, it is moved to the PFRP and stockpile area Iocated just above the recompacted clay pad with drainage directly back into the recompacted clay pad. The compost mixture is restacked in this area and covered with a minimum of one foot of material that has already completed the PFRP process. These piles are then labeled and dated with survey stakes to initiate the 90 day total retention time and for the documentation of PFRP and vector control temperatures. PFRP and vector control are both conducted via the time and temperature requirements. Upon completion of these requirements, the finished compost is screened through a' inch minus screen and marketed. The screened product is sampled for pathogen reduction and heavy metals at least twice annually. The screened rejects are recycled back into the compost process as bulking agent. The liquids from the PFRP/stockpile and recompacted clay pad areas flow through a 2,500 gallon sand trap to help settle out solids and then into the currently hypolon-lined pond proposed to be reconstructed with polypropylene. This sand trap will be cleaned out as needed by use of a backhoe. This upper poly -lined pond will have an overflow into another larger evaporative pond also equipped with a sand trap(see site plan). Both ponds will be equipped with pumps to recycle material back up to the biosolids receiving area at the top of the recompacted clay pad. These pumps will also be used to bypass liquids directly back into the ponds to promote stirring and aeration as well as increased evaporation used in conjunction with several blowers. It is proposed that the lower poly - lined pond be constructed with greater depth than is conventional for evaporative ponds to allow for the build up of solids over time thus increasing the useful life of this impound. It is proposed that when this pond finally fills with solids it be reexcavated (with solids going back into the compost process) and relined. DRAINAGE: All areas containing biosolids that have not completed PFRP will have drainage directly onto the recompacted clay pad and on into a poly -lined pond. All other portions of the site will have drainage into a site run-off retention impound. Potential site run-on is intercepted by use of a ditch above the site and diverted around the site (see site plan for details).