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DEPARTMENT OF HEALTH
Garfield County Commissioners
P. 0. Box 640
Glenwood Springs CO 81602
Gentlemen:
876
Frank A. Traylor, M.D.
Executive Director
At the April 8, 1982 general meeting the Colorado Air Quality Control
Commission (AQCC) passed major revisions to the State's Regulation con-
cerning control of fugitive particulate matter. This Regulation is to
become effective May 30, 1982.
Enclosed is a copy of the fugitive particulate section of this new
Regulation (Reg. 1, Sec. III.D.). In past Regulations there existed a
distinction between public and private unpaved roadways. The legal
authority of the Air Pollution Control Division (APCD) to control dust
was separated by this distinction. However, this distinction has been
removed from the new Regulation. Now, all unpaved roads are subject
to the same legal requirements to control excessive dust (Sec. III.D.2 a.).
In -most instances this should not cause any insurmountable problems for
Garfield County. The main concern of the APCD is with large new develop-
ments, mostly industrial, that will increase significantly the amount of
traffic on public roads. If not careful, the public entity owning or
maintaining unpaved roads may find itself subsidizing industrial develop-
ment by providing dust control or facing legal action by the APCD.
In an attempt to forestall any such situations, it is recommended that
Garfield County consider not only the road maintenance aspects but also
the air pollution control aspects of allowing a project to utilize
public unpaved roadways for which the County is responsible. It is not
uncommon to require as a condition of operation that the project owners
assume the responsibility for dust control. The owners should be answer-
able to the County Commissioners to comply with the AQCC's Regulations.
If action -is then taken by the APCD for excessive dust the County should
have recourse against the project or projects causing the problem(s).
The County should require the owners to comply with these Regulations.
125 NORTH 8TH STREET, GRAND JUNCTION, COLORADO 815Ui. PHONE (303) 245-2400
HERRINGTON & KNAUS, P.C.
RICHARD A. HERRINGTON, M.D.
DIPLOMATE. AMERICAN BOARD OF FAMILY PRACTICE
GARY D. KNAUS, M.D.
DIPLOMATE. AMERICAN BOARD OF FAMILY PRACTICE
May 15, 1982
Garfield Board of County Corr issioners
Garfield County Courthouse
Glenwood Springs, Colo. 81601
Dear Sirs:
I am writing this letter to express my opinion about the situati.l
road from Westbank to Carbondale in regard to the heavy truck tra
is present.
on the
f1 c that
I had written a letter approximately 1 year ago to Flaven Cerise, d I
hope that that letter is on file with you in regard to this probl- ,. I am
not in a position to make an "impassioneplea, but my concerns arseveral.
As I had stated in my previous letter, feel that the speeds exhib ted by
the large trucks are excessive, not on on the narrow, graveled po tion,
but\noe importantly an the paved por on from C.R.M.S. to the stoplight.
'There is large amount of bicycle an pedestrial traffic along that area
and I am oncerned for the safety of those people. We all know of a
least 3 - ' or accidents involving . that have occurred on that oad
in the las year. I suspect that weed and loss of control were a s gni-
ficant port . of each of these accidents.
My secoid con
those persons
as many las 15
couples Oho use
who ride their b
also be mention
road with their p
traffic factor is
ern is that of the aesthetic and safety considerations
o use the back road as a recreational area. This in
20 runners
that area for
cycles, hors
that a n
rents wh
e ma
is the situation wit
I personally know, a number of el
eir daily exercise, and a number of
back ride etc. along that route. It
er of our younger drivers in training
' e learning to drive. Again, the speed
consideration in this regard. Not to b
e dust. It seemed to re that the attempts
for
ludes
rly
eople
ould
e that
d heavy
ignored
ast summer
of watering down the road were helpful, until approximately 10:00 .m., if
it was done at all, but by the middle of the afternoon the dust s'tuation
was just as ad as it would have been.
Thank you for the opportunity to share my concerns. I hope thaw you will
consider these problems and issues in your final decision in r-_ard to the
traffic situation on the road in question.
Thank you.
Sincerely,
Gary D. aus, M.D.
GDK:sb
366 STATE HWY. 133 TRE -COUNTY MEDICAL CENTER CARBONDALE. COLORADO 91623
TELEPHONE 303/963.3350
Garfield County Commissioners
May 3, 1982
Page 2
Further, it should be noted that the requirement to control dust is not
limited to new roads or new activities. It is recommended that the County
reevaluate some of their existing roadways to determine if problems may '
exist. One example of an existing situation within Garfield County with
the possibility of creating a confrontation between the County and the
APCD is County Road 109 south of Carbondale. This road presently serves
the Siever's Ranch and Development Project which has the potential to
cause action to be taken by the APCD due to the amount of heavy trucks
utilizing this unpaved County road to haul not only sand and gravel but
also asphalt and concrete from the subcontractors' operations at the
project site. Other roads in the vicinity of both Rifle and Parachute
should also be evaluated for potential dust problems due to the same sort
of growth in existing projects.
If I can answer any questions, please call me.
Sincerely,
Scott J. Miller
Air Pollution Control Division
Sart/zp
cc: Denver Office
Garfield County Planning Dept
Enclosure
1
J.
, b � "
1. General ,ecuir ements
a. Existing Sources
(i)
Every owner or operator of a source or activity
which is subject to this Section III.D. shall
employ such control measures and operating
procedures as are necessary to minimize
fugitive • particulate emissions into the
atmosphere through the use of all available
practical methods which are technologically
feasible and economically reasonable and which
r educe, pr event and control. emissions so as to
facilitate the achievement of the maximum
practical degree of air purity in every portion
of the State.
(ii) In determining what control methods are
available, practical, economically reasonable
and technologically fe.asible, the following
factor s shall be considered: effects on the
health, welfare (as defined in Section I.G. of
the Common Provisions regulation), convenience,
and comfort of the inhabitants of the State of
Colorado; effects on :.he enjoyment and use of
the scenic and natural resources of the State;
the impact on normal operating procedures;
altitude, topography, climate, and anticipated
meteorological conditions (including wind and
precipitation); soil conditions; the degree to
which a type of emission to be controlled is
significant; the continuous, intermittent, or
seasonal nature of the emission, the economic,
environmental, and energy impacts and other
costs of compliance; the proximity of the
source or activity to populated areas; and the
nature, scope and duration of the source or
activity.
(iii) This Section III.D.1.a. shall be enforceable
only through the procedures specified below in
Sections III.D.i.b. through III.D.1.e.
b. New Sources
Every owner or operator of a new source or activity
which is subject to this Section IIID. and which is
required to obtain an emission permit under
Regulation No. 3 shall submit a fugitive particulate
emission control plan meeting the requirements of
this Section III. 3D . at such time as, and as part of,
the required permit application. Such plan shall be
approved or disapproved by the Division in the course
of acting to approve or disapvrove the permit
application and no emission permit shall be issued
until a fugitive particulate emission control plan
has been approved.
c. Trill salon Limitation Guidelines
If the Division determines that a source or activity
which is subject to this Section IIID. (whether new
OT existing) is operating with emissions in excess of
201 opacity and such source is subject to the 20Z
opacity emission limitation guideline; or if it
determines that the source or activity is operating
with visible emissions that are being transported off
the property on which the source is located and such
source is subject to the no off property transport
emission limitation guideline, or if the Division
receives a complaint that a source or activity
subject to the nuisance emission limitation guideline
is operating with emissions that create a nuisance;
it shall inspect such source or activity in order to
determine if the source or activity is operating in
accordance with the requirements of this Section
III.D.1.a(i) (as used herein, "nuisance" shall mean
the emission of fugitive particulates which
constitutes a private or public nuisance as defined
in common
law, the essence of which is that such
emissions are unreasonably interfering with another
per son' s use and enjoyment of his property. Such
interference must be "substantial" in its nature as
measured by a standard that it would be of definite
offensiveness, inconvenience, or
normal per son in the community) .
[Cross Reference: Appendices A and B]
d. Control Plans
(1) If the Division determines that a source or
annoyance
to a
activity (whether new or existing) exceeds
applicable emission limitation guidelines
is not being operated in accordance with
requirements of this Section III.D.1.a(i),
any
and
the
tne
Division shall require the owner or operator of
tnat source or activity to submit a written
plan to the Division for the control of
fugitive particulate emissions within the time
period specified by the Division. In the case
of a source or activity which nas a control
plan, the Division shall review said control
plan and if it determines the plan does not
meet the requirements of this Section
III.D.1.a(i), it shall require tne submission
of a revised control plan.
(ii) With respect to operations or activities which
have more than one source of fugitive
particulate emissions, submission of control.
plans or plan revisions pursuant to Section
III. D• 1- d(i) shall be required only with
respect to those individual sources for which
there does not exist a currently approvable
control plan and which are not being operated
in accordance with the requirements of this
Section III.D.1.d(i), provided, however , that
control plans required by Section III.D.1.b.
for new sources and activities shall contain
provisions for control of fugitive particulate
emissions from all significant sources of such
emissions.
(iii) Sources required to submit conrrol plans for
revisions to the Division snail do so within
sixty (60) days of the date such plan or
revision is requested; provided, however, that
the Division, in its discretion, may where
appropriate establish a different time period
for submittal, taking into consideration such
factors as the duration of the operation of the
source or activity, the significance and nature
of the emissions, and the relative. complexity
of the operation and applicable control methods.
(iv) Each control plan shall include all available
pr actical methods which .are technologically
feasibl-e and economically reasonable and which
reduce, prevent and control fugitive
particulate emissions from the source or
activity into the atmosphere. For rho se
materials, equipment., services or other
resources (such as water for abatement and
control purposes) which are likely to be scarce
at any given time, an alternative control
method must be included in the control plan.
Any source required to submit a control plan
may ask for a "control plan conference" with
the Division, and if so requested the Division
shall hold such a conference for the purpose of
advising what types of control measures and/or
operating procedures will meet the requirements
of this section.
[Cross Reference: Sections III.D.2.a. through
III.D.2.k.
e.
(v) The Division shall appy ove any plan
under this Section III.D., unless the
determines that the plan does not
submitted
Division
meet the
requirements of Section III .D.1.a(i). If a
control plan is not approvable in its entirety,
the Division shall approve those portions which
meet the requirements of this section and
disapprove those portions which fail to meet
the requirements of this section.
Enfor cement
(i)
It shall be a violation of this regulation and
the Division may take enforcement action
pursuant to C.R.S. 1973, 25-7-115, as amended,
if the owner or operator
(A)
Fails to submit a control plan (or
revision of an existing plan) within
sixty (60) days (or otner Lime period
specified by the Division) after being
notified by the Division tnat such
submittal is required unless operation
such source is discontinued
permanently eliminate the cause
of
so as to
of
fugitive particulate emissions therefrom;
or
(B) Owns or operates a source or activity for
which the Division has disapproved a
control plan or a revised control plan
(C)
unless operation
discontinued so
of
as
such
to
eliminate the cause of
source is
permanently
fugitive
particulate emissions therefrom; or
Fails to comply with the provisions of an
approved control plan.
(ii) the 20% opacity, no off -property transport, and
nuisance emission limitation guidelines of this
Section III.D. are not enforceable standards
and no person shall be cited for violation
thereof pursuant to C.R.S. 1973, 25-7-115 as
amended.
2. Sources Subject to Section III. D.
The control measures and operating procedures listed in
Sections III.D.2.a. through III.D.2.k. are generally
considered appropriate for the specific types of sources
under which they are listed - at least as applied
individually. Wnether they remain appropriate when used in
combination. with other measures and procedures, must be
determined on a case by case basis.
a.
Roadways
(i) Unpaved
(A) Applicability — Attainment and
Nonattainment Areas
(B). General Requirement
Any owner or operator responsible for
construction or maintenance of any
(existing or new) unpaved roadway which
has vehicle traffic exceeding 200
vehicles per day in attainment areas or
150 vehicles per day in nonattainment
areas (averaged over any consecutive
3—day period) from which fugitive
particulate emissions will be emitted
shall be required to use all available,
practical methods which are
technologically feasible and economically
reasonable in order to minimize emissions
resulting from the use of such roadway in
accordance with the requirements of
Section III.D.1.a(i) of this regulation.
(C) Applicable Emission Limitation Guideline
The nuisance emission limitation
guideline shall apply to unpaved
roadways. Abatement and control plans
submitted for unpaved roadways shall be
evaluated for compliance with the
requirements of Section III.D.1.a.(i) of
this regulation.
(D) Control Measures and Operating Procedures
Control measures or operations procedures
to be employed may include but are not
necessarily limited to, watering,
chemical stabilization, road carpeting,
paving, suggested speed restrictions and
other methods or techniques approved by
the Division.
(E) If the Division receives a complaint that
any new or existing unpaved roadway is
creating a nuisance, it may require
persons owning or operating or
maintaining such roadways to supply
vehicle traffic count information by any
reasonable available means for the
purpose of determining if they nave
sufficient traffic to subject them to the
requirements of this Section III. D.
(ii) Paved
(A) Applicability — Attainment
Nonattainment Areas
(B) General Requirement
and
Any per son who through operations or
activities repeatedly deposits materials
which may create fugitive particulate
emissions on a public or private paved
roadway is required to submit a control
and abatement plan upon request by the
Division which provides for the removal
of such deposits and appropriate measures
to prevent future deposits such that
fugitive particulate emissions which may
result are minitu.zed; except tnat sand,
salt or other materials may be dropped on
snow or ice covered roadways for tne
purpose of safety and such deposits small
not be required to be removed on a more
frequent basis than the community`s
normal street cleaning schedule except as
otherwise provided in an applicable SIP
pr ovision.
(C) Applicable Fri ssion Limitation Guideline
The nuisance emission limitation
guideline shall apply to paved roadways.
Abateznent and control plans submitted for
paved roadways shall be evaluated for
compliance with the requirements of
section III.D.1.a(i) of this regulation.
(D) Control Measures and Operating Procedures
Control measures or operational
procedures to be employed may include but
are not necessarily limited to, covering
the loaded haul truck, washing or
otherwise treating the exterior of the
vehicle, limiting the size of tne load
and the vehicle speed, watering or
treating the load with chemical
suppressants, .keeping the roadway access
point free of materials that may be
carried onto the roadway, removal of
materials from the roadway and otner
methods or techniques appioved by the
Division.
[Cross Reference: Subsection f. of
Section III.D.2. of this regulation.]
b. Construction Activities
(i)
Applicability - Attainment and Nonattainment
Areas
(ii) General Requirement
Any owner or operator engaged in clearing or
leveling of land or owner or operator of land
that has been cleared of greater than five (5)
acres in attainment areas or one (1) acre in
nonattainment areas from which fugitive
particulate emissions will be emitted shall be
required to use all available and practical
methods which are technologically feasible and
economically reasonable in order to minimize
such emissions in accordance with the
requirements of Section III.D.I.a(i) of this
regulation.
(iii) Applicable Emission Limitation Guideline
Both the 20% opacity and the no off -property
transport emission limitation guidelines shall
apply to construction activities; except that
with respect to sources or activities
associated with construction for which there
are separate requirements set forth in this
regulation, the emission limitation guidelines
there specified as applicable to such sources
and activities shall apply. Abatement and
control plans submitted for construction
activities shall be evaluated for compliance
with the requirements of Section III.D.1.a. (i)
of this regulation.
[Cross Reference: Subsections e. and f. of
Section III.D.2. of this regulation.]
(iv) Control Measures and Operating Procedures
Control measures or operational procedures to
be employed may include, but are not
necessarily limited to, planting vegetation
cover, providing synthetic cover, watering,
chemical stabilization, furrows, compacting,
minimizing disturbed area in the winter, wind
breaks and other methods or techniques approved
by the Division.
c. Storage and Handling of Materials
(i) Applicability - Attainment and Nonattainment
Areas
(ii) General Requirement
Any owner or operator or any new or existing
materials storage and handling operation from
which fugitive particulate emissions will be
emitted shall be required to use all available
practical methods which are technologically
feasible and economically reasonable in order
to minimize such emissions in accordance with
the requirements of Section III.D.1.a(i) of
this regulation.
(iii) Applicable Emission Limitation Guideline
Both the 20% opacity and the no off -property
transport emission limitation guidelines shall
apply to
Abatement
storage and
and control
storage and handling
evaluated for compliance
Handling operations.
plans submitted for
operations shall be
with the requirements
of Section III.D.1.a(i) of this regulation.
(iv) Control Measures And Operating Procedures
Control measures or operational procedures to
be employed may include, but are not
necessarily limited to, the use of enclosures,
covers, stabilization, compacting, watering,
limitation of fines and other methods or
techniques approved by the Division.
d. Mining Activities
(i) Applicability - Attainment and Nonattainment
Areas
(ii) General Requirements
Any owner or operator of any new or existing
mining operation from which fugitive
particulate emissions will be emitted shall be
required to use all available practical methods
which are technologically feasible and
economically reasonable in order to minimize
such emissions in accordance with the
requirements of Section III.D.1.a(i) of this
regulation.
(iii) Applicable Emission Limitation Guideline
Both the 20% opacity and the no off—property
transport emission limitation guidelines shall
apply to mining _activities' except that with
respect to sources or activities associated
with mining for which there are separate
requirements set forth in this
emission limitation guidelines
as applicable to such sources
shall apply. Abatement and
regulation, the,
there specified
and activities
control plans
submitted for mining activities shall be
evaluated for compliance with the requirements
of Section III.D.1.a(i) of this regulation.
• (iv) Control Measures and Operating Procedures
Control measures or operating procedures to be
employed may include, but are not necessarily
limited to:
(A) watering or chemical stabilization of
unpaved roads as often as
minimize r eincr ai nment
particulate matter from the
or paving of roads;
necessary to
of fugitive
road surface,
(B) prompt removal of coal, rock minerals,
soil, and other dust—forming debris from
paved . roads and scraping and compaction
of unpaved roads to stabilize the road
surface as often as necessary to minimize
reintrainment of fugitive particulate
matter from the road surface;
restricting the speed of vehicles in and
around the mining operation;
revegetating, mulching,
stabilizing the
adjoining roads
or
surface of
that are a
fugitive particulate emissions;
(E) to the extent practicable
vehicular travel vehicles to
roads;
otherwise
all areas
source of
restricting
established
(F) enclosing, covering, watering, or
otherwise -treating loaded haul trucks and
railroad cars, or limiting size of load,
to minimize loss of material to :rind and
spillage;
(G) substitution of conveyor systems for haul
trucks;
(H) minimizing the area of disturbed land;
(I) prompt' revegetation of disturbed surface
areas;
(J) planting of special wind break vegetation
at critical points;
(K) restricting the areas to be blasted at
any one time;
(L) reducing the period of time between
initially disturbing the soil and
revegetating or other surface
stabilization;
(M)
e. Haul Roads
control of fugitive particulate emissions
from storage piles through use of
enclosures, covers, or stabilization,
minimizing the slope of the upwind face
of the pile, confining as much pile
activity as possible to the downwind side
of the pile and other methods or
techniques as approved by the Division.
[Doss Reference: Subsections a., b.,
c., e., f., g., and i. of Section
III.D.2. of this regulation.)
(i) Applicability - Attainment and Nonattainment
Areas
(ii) General Requirement
Any owner or operator of any new or existing
haul road which has vehicle traffic exceeding
40 haul vehicles or 200 total vehicles per day
(averaged over any consecutive 3 -day period)
from which fugitive particulate emissions will
be emitted shall be required to • use all
available practical methods which are
technologically feasible and economically,
reasonable in order to minimize such emissions
in accordance with the requirements of Section
III.D.l.a(i) of this regulation.
(iii) Applicable Emission Limitation Guideline
iv
)
e no off --property transport emission
limitation guideline shall apply to on-site
haul roads (i.e., those located on and abutted
by the property o'6.-ned or under control of the
owner or operator of the haul road) and the
nuisance guideline shall apply to off-site Haul
roads (i.e., those abutted on both sides by
property not owned or under the control of the
owner or operator of the haul road). Abatement
and control plans submitted for haul roads
shall be evaluated for compliance with the
requirements of Section III.D.'.a(i) of this
r egulation.
Control Measures and Operating Procedures
Control measures and operational procedures to
be employed may include, but are not
necessarily limited to, the use of vehicular
speed reduction, watering, chemical
stabilization, road carpeting and other methods
of techniques approved by the Division.
(v) The Division may require persons owning or
operating or maintaining any new or existing
haul roads to supply vehicle traffic count
information by any reasonable available means
for the purpose of determining if they have
sufficient ti affic to subject them to the
requirements of this Section IIID.
f. Haul 7Yucks
(i) Applicability -- Attainment and Nonattainment
Ar eas
(ii) General Requirement
Any owner or operator of any new or existing
haul trucks from which fugitive particulate
emissions will be emitted shall be required to
use all available practical methods which are
technologically feasible and economically
reasonable in order to minimize such emissions
in accordance with the requirements of Section
III.D.l.a(i) of this regulation.
(iii) Applicable Emission Limitation Guideline
Tne no off -property transport emission
limitation guideline shall apply to haul
trucks; except that :men operating off the
property of the owner or operator, the
applicable guideline shall be no off --vehicle
transport of visible emissions. Abatement and
contxol plans submitted for " haul trucks shall
be evaluated for compliance with the
requirements of Section III.D.1.a of this
regulation.
(iv) Control Measures and Operating Procedures
Control measures or operation procedures to be
employed may include but are not necessarily
limited to, covering the materials, washing or
otherwise treating loaded haul trucks to remove
materials from the exterior of the vehicle
prior to transporting materials, limiting load
size, wetting the load and other methods or
techniques approved by the Division.
[Cross Reference:
42-4--1208]
Tailings Piles and Ponds
(1)
C.R.S.
1973, Section
Applicability - Attainment and Nonattainment
Ar eas
(ii) General Requirement
Any owner or operator of any new or existing
tailings piles and ponds from which fugitive
particulate emissions will be emitted shall be
required to use all available practical methods
which are technologically feasible and
economically reasonable in order to minimize
such emissions in accordance with the
requirements of Section III.D.1.a(i) of this
r egulation.
(iii) Applicable Phission Limitation Guideline
Both the 20% opacity and the no off -property
transport emission limitation guidelines snail
apply to tailings piles and ponds. Abatement
and control plans submitted for tailings piles
and ponds shall be evaluated for compliance
frith the requirements of Section III. D.1.a(i)
of this regulation.
(iv) Control Measures and Operating Procedures
Control measures or operational procedures to
be employed may include, but are not
necessarily limited to:
(A) watering and/or chemical stabilization,
(B) synthetic and/or revegetative covers,
(C) wind breaks,
(D) minimizing the area of disturbed tailings,
(E) restricting the speed of venicles in and
around the tailings operation, and/or,
(F) other equivalent methods or techniques
approved by the Division.
h. Demolition Activities
(i) Applicability - Nonattainment Areas
(ii) General Requirements
Any owner or operator of any new demolition
activities from which fugitive particulate
emissions will be emitted shall be required to
use all available practical methods which are
technologically. feasible and economically
reasonable in order to minimize such emissions
in accordance with the requirements of Section
III.D.1.a(i) of this regulation.
(iii) Applicable Emission Limitation Guideline
Only the no off -property transport emission
limitation guideline shall apply to demolition
activities. Abatement and control plans
submitted for demolition activities shall be
evaluated for compliance with the requirements
of Section III.D.1.a(i) of this regulation.
(iv) Control Measures and Operating Procedures
Control measures or operational procedures to
be employed may include, but are not limited to:
(A) wetting down, including pre ---watering of
work surface,
(B) removal of dirt and mud deposited on
improved streets and roads,
(C) wetting down, washing, or covering
haulage equipment when necessary to
minimize fugitive dust emissions during
loading and transit.
—23—
Any demolition or renovate , activity that has
materials insulated or fireproofed with triable
asbestos will also be subject to the provisions
of the Air Quality Control Commission's
Regulation No. 8, Section II.B.4.
i, Blasting Activities
J•
(i) Applicability - Attainment and Nonattainment
Areas
(ii) General Requirement
Any owner or operator of any new or existing
blasting activities from hick fugitive
particulate emissions will be omitted shall be
required to use all available practical methods
which are technically feasible and economically
reasonable in order to minimize such emissions
in accordance with the requirements of Section
III.D.1. of this regulation.
(iii) Applicable Emission Limitation Guideline
Only the no off -property transport emission
'limitation guideline shall apply to blasting
activities_ Abatement and control plans
submitted for blasting activities shall be
evaluated for compliance with the requirements
of Section III.D.1.a(i) of this regulation.
(iv) Control Measures and Operating Procedures
Control measures or operational procedures to
be employed may include, but are not limited
to, the use of:
(A) the removal of overburden prior to
blasting,
(B) watering down the blasted area as soon as
practicable after blasting,
(C) other equivalent methods or techniques
approved by the Division.
Sandblasting Operations
(1)
Applicability - Attainment and Nonattaiment
Areas
(ii) General Requirement
-24--
Any owner or operator of any new or existing
sandblasting activities from which fugitive
particulate emissions will be emitted shall be
required to use all available practical methods
which are, technologically feasible and
economically reasonable in order to minimize
such emissions in accordance with the
requirements of Section III.D.1.a(i) of this
regulation.
(iii) Applicable Emission Limitation Guideline
Only the 20% opacity emission limitation
guideline shall apply to sandblasting
operations. Abatement and control plans
submitted for sandblasting operations shall be
evaluated for compliance with the requirements
of Section III.D.1.a(i) of this regulation.
(iv) Control Measures and Operating Procedures
Control measures and operating procedures to be
employed may include, but are not limited
to,the use of enclosures with necessary dust
collecting equipment, using wet sandblasting
methods, and other methods or techniques
approved by the Division.
k. Livestock Confinement Operations
(i) 'Applicability — Attainment and Nonattainment
Areas
(ii) General Requirement
Any owner or operator of any new or existing
livestock confinement operations from which.
fugitive particulate emissions will be emitted
shall be required to use all available
practical methods which are technologically
feasible and economically reasonable in order
to minimize such emissions in accordance with
the requirements of Section III.D.1.a(i) of
this regulation.
(iii) Applicable Emission Limitation Guideline
Only the no off—property transport guideline
shall apply to livestock confinement
operations. Abatement and control plans
submitted for livestock confinement operations
shall be evaluated for compliance with the
requirements of Section III.D.1.a(i) of this
regulation.
(iv) Control Measures and Operating Procedures
Control measures or operating procedures to be
employed may include', but are not limited to
tbe use of sprinkler systems and/or other
equivalent methods or techniques as -approved by
the Division.
IV. CONTINUOUS EMISSION MONITORING REQUIREMENTS FOR EXISTING SOURCES
A. Sources which axe required to install, calibrate, certify and
maintain continuous emission monitoring systems for opacity,
and/or SO2 (listed in Sections B, C, and D, of this Section IV)
shall have such equipment installed in a location which in accord
with sound engineering practice will provide for accurate opacity
and/or SO2 emission readings and approved by the Division
within eighteen (18) months of the effective date of this
regulation (i.e., no later than November 30, 1983).
B. Fossil Fuel—fired Steam Generators
1. A continuous emission monitoring system for the measurement
of opacity shall be installed, calibrated, maintained and
operated by the owner or operator of any steam generator of
a total rated capacity of or greater than 250 million BTU
per hour heat input except where:
a. gaseous fuel is the only fuel burned or,
b. oil or a mixture of gas and oil are the only fuels.
burned and the source is able to comply with the
applicable particulate matter and opacity regulation
without utilization of particulate matter collection
equipment,
c.
where the source demonstrates that a continuous
monitoring system would not provide accurate
determinations of the opacity of emissions (e.g.,
condensed, uncombined water vapor in the emissions
would prevent accurate readings) and an alternative
method of determining opacity is approved by the
Division is employed.
2. Either a continuous emission monitoring system for the
measurement of sulfur dioxide shall be installed,
calibrated, maintained and operated or a Division approved
sampling plan shall be developed and implemented for
determining the amount of sulfur in the fuel in order to
calculate sulfur oxide emissions on any fossil fuel fired
steam generator of a total rated capacity of or greater
than 250 trillion BTU per hour heat input.
0 4 198
EVI ��.Y ?
4 a.,
May 2, 1982
Mr. Dennis Stranger, Planning Director
Garfield County Planning Department
2014 Blake Avenue
Glenwood Springs, Colorado 81601
Dear Mr. Stranger
The purpose of this letter is to bring to your attention
a serious traffic problem which is intensifying as a result
of industrial use of County Road 109 which emties on to west
Main Street in Carbondale.
The Carbondale City. Council would like you to be aware
that we join with residents along this stretch of county
road in urging you to consider some long term solution to
dust and safety problems which are continually intensifying
as a result of industrial activity.
As you are aware, the only north access from the Fox
Gravel Pit and coal loading heavy truck traffic to the north
side of the Roaring Fork River is through Carbondale by use of
the Highway 133 bridge. This is due to the limited load
carrying capacity of the Westbank bridge.
We would appreciate your consideration of interim safety
and dust abatement improvements and long term consideration of
some other access from Highway 82 to this area.
We will be happy to discuss with you further our concerns
and participation in whatever way we are able towards achieving
a solution.
76 So. 2nd
warboadala, Colorado 81Clw 303.963.2733
Mr. Dennis Stranger
May 2, 1982
Page Two
Thank you very much for your consideration.
RAF/jj
XC:
Sincerely yours,
1 ,
C./( 7
Richard A. Flewelling
City Manager
Garfield County Commissioners
Mr. Stan Broom, Garfield County Manager
Colorado Rocky Mountain School
Mr. & Mrs.J.E. DeVilbiss
Mr. & Mrs.Jack Snobble
Mr. & Mrs.Robert Oxenberg
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Sievers Ranu}and Development Corp. first applied for a special
use permit to operate a gravel pit in 1977. The original property
to be mined was 8+ acres. "The purpose of the application is to
extract and process sand and gravel and quarry aggregate for the
sole purpose of obtaining said materials for highway, road, or
similar -type construction pursuant to a subsequent negotiated com-
tract with the county and construction and maintenance road require-
ments imposed on others to repair or improve county roads."(P. 1,
Feb,,'77 Application for Spec. Use Permit)
Under "Streets" in this application, they wrote:"
" The Ranch and general area is presently serviced by an exist-
ing county -maintained road, delineated in green on exhibit "B",
known as County Road 108.Such road is now only sporadically used
as a result of a nearby State Highway running parallel to County
Road 108 and only two residential properties, other than the Ranch,
using said Road. Access to such County Road is in place, and will
be over an adequate existing bridge South of the Ranch. No improve-
ments to County Road 108 is forseeable as a result of only an expect-
ed 20 trips per day from the excercise of such permit. "
Throughout this application, they refer to 108 Road, rather
than the correct 109 Road. Although at the time of issuance of
their Special Use Permit, they correct this, it is possible that
at the time this could have given the Commissioners a false impress-
ion. 108 Road is adequately wide and paved, while 109 Road is
narrow, dangerous, inadequate, and tat that time) dirt. They also
stated in their application that the road was little used " as a
result of a nearby state highway running parallel". This gives the
impression that the 108(109) Road was the main thoroughfare until
Highway 82 came along. This may have been true very early in the
century. However, the Westbank development was at the end of the
road and the road was mainly used, and still is, as the back road
2
to Carbondale. As to the "only two residential properties", there
were, even in 1977, considerably more than that. Starting at the
South end of 109 Road, there were the Wilsons, who have two houses
on their property, the Snobbles,(with all their children), what
is now the DeVilbiss property, the Coryell Ranch, the Readings(which
is now the Oxcnber. g property) , the Holmes Ranch, Jim Rose, two small
properties on the West side of the North end of 109 Road, and, of
course, all of Westbank.
The 1977 Sievers application also failed to lay out the whole
route that their trucks would have to take to reach Highway 82. On
the map that was attached to their original application, only 109
Road is marked in ink. The whole route is really 109 Road, 108 Road,
Highway 133 to Highway 82, a distance of 62 miles. The "practical
description", however, that was published in the public notices, as
well as in the public hearings, located the Ranch property as " 2
miles South of the Hardwick Bridge", which is under a mile from Highwy
82. Nowhere in their application was the whole route mentioned, nor
the fact that 108 Road passed by Colorado Rocky Mountain School and
was used by hundreds of teenagers and faculty members and their child-
ren. Nor was Crystal Village mentioned at the end of 108 road. Nor
was Highway 133 mentioned, which is commercial/residential. An indus
trial use was incompatible with the surrounding uses , not of the
adjacent land, but of the route. Sievers also failed to mention
that 109 Road does not access directly to Highway 82.
At the Commissioners meeting on March 28th, 1977, Leonard Liss
the attorney for the Sievers said :
that loaded gravel trucks would use the county road on
the west side of the river to Carbondale, rather than
use the Hardwick Bridge, which only has a load limit of
17 tons. (minutes of meeting)
It would appear that their original intention was to use the
Hardwick Bridge to bring in the empty trucks and to have the loaded
ones use 109 Road. Sievers R & D also states:
No improvement to County Road 108(109) is forseeable
as a result of only an expected 20 trips per day.(Applic.,
Special Use Requirements,"Streets")
Under "Design", they write:
As a result of the relative remoteness of the site from
any residential area, no impact on adjacent or nearby
land area will occur.
As a result of neglecting to mention that their true route was
109 Road, 108 Road,Highway 133, to Highway 82, they are able to
make this statement. Actually, as I have a1r:,ady pointed out, it
is not true.
The meeting was adjourned until April 4th, 1977. At that meet-
ing, Neil Mincer...
"voiced concerns about dust control, and the noise generat-
ed by a gravel operation. He said that the county road to
be used is quite dusty already and with 20 or so loads of
gravel being hauled over the road every day, it could really
present a problem...He asked who was to enforce regulation,
the County or individuals. Mr. Velasquez said it was up
to the County...Mr. Cerise felt that there should be a
stipulation that the opacity from fugitive dust not exceed
20%...Carried unanimously."(Public Hearing,April 4•,77,min--
utes)
In July, 1977 a text change amendment was granted in response
to a request by the Sievers R & D for a zone change to permit the
addition of a concrete batch plant. Planner, Bob Witkowski, stated
"that a batch plant is a natural extension of a gravel pit and that
if one is allowed, so should the othe.r...He recommended that the
word "concrete be deleted so that asphalt batching could also be
included."(mintues of Comm. Meeting, July 11, 1977. It was at this
time that the correction was made to change 108 Road to 109 Road.
In the fall of 1979, The Sievers R & D applied to expand their
original 8 acre pit into a 122 acre pit, and asked permission to
allow extraction of"more than 70,000 tons in any one year."(Applic.
for Extended Gravel Operation, 1979) The impact statement makes no
mention of their haul route, or traffic to be generated, and their
practical description is still respresenting their location with
respect to the short Hardwick Bridge route to Hgihway 82.
The turnoff to the property is 2.8 miles South of the Hard -
Wick Bridge.
In march of 1980, a Resolution was passed for a gravel operation
that now encompassed 122 acres and included the operation of a concret
batch plant. The gravel permit was for 99 years, but I cannot find
any mention of this either in their application, the impact statement
or the Special Use Permit. The 99 year span is only mentioned in the
Mined Land Reclamation Plan.
At the March 24th Public Hearing for the Concrete batch plant,
Dick Martin of Carbondale...
"did, however, express concern over the dust created from
trucks. After some discussion, Mr. Cercise agreed that
it was the County's responsibility to see that the road
was oiled. Mr. Velasquez moved to close the public hear-
ing and dealy the discussion until the Comm. Meeting on
the 3lst of March...Carried Unanimously.
The oiling of the road, and the maintenance of it and its
dust problem was never brought up again.
On march 31st, Resolution 80-47 was passed. The determinations
of fact, which were constructed from the application and testimony
at the public hearings, are not true, due to the lack of accurate
input.
Determinations of Fact:
2. That neither the impact on traffic volume and safety or
on utilities, or any other impact of the special use will
be injurious to the established neighborhood or zone dis-
trict in which the special use is proposed to be located.
1. The proposed use is compatible with the uses existing and
permitted in the district in which it is to located, pro-
vided that certain herinafter conditions be complied with:
1. That the use of the tract of land comply
with all present and future regulations of Garfield
County relating to all uses...in the zone district
in which the property is now or may later be located.
2. That no more than 20% opacity of fugitive dust
be created at the plant and on County Road 109.
Special Condition number 1 would seem to preclude "grandfather-
ing" since the pit must be current with all regulations and zoning,
as well as Health, Road, etc. The second has been consistently
violated, and is the most accessible "handle" to open the Sievers
Special Use Permit for Review.
The following are the zoning regulations that are applicable
to Sievers special use permits and with which they are out of
compliance.
1) As a precedent, the Commissionsers wrote regarding Smoss Coal's
special use application " that the impact of the proposed facility
opon traffic volume and safety, vis Sec. 5.03.11 and 5.03.12(1) would
require denial unless the applicant improves and maintains the road..."
From Amended Zoning Regs of 1978- In effect at time of Permit issuance
2) 5,03,12 states: All conditional and special uses must be provided
with access routes if adequate design to accomodate traffic volume generated
by the proposed use and to provide safe, convenient access for the use
constructed in conjunction to the proposed use. The minimum design standards
shall be the Garco. Road Specs.
3) 5.03.11- Denial of S2eci.al Use Permit ; The Comms, may deny any request
for special use based ori the lack of physical separation in terms of distance
from similar uses on the same or other lots, the impact on traffic
volume and safe, or on utilities or any impact of the special use which it
deems injurious to the established character of the neighborhood or zone
district in which such speciaol use is proposed to be located.
4) 12.00 Any violation of zoning relulations, the County Comms,, and
district attorney, or any owner of real estate, within the district where
such real estate is situatioed may institute an injunction mandamus,
abatement, or other appropriate action or proceding to prevent, enjoin,
abaete, or remove such unlawful...mainteneance or use.
5) 9.03.05 Periodic Review Any SUP may be made subject to a periodic
review not less than every 6 months.
5.03 Conditional and Special uses...shall conform to all regulations listed
thereunder and elsewhere in these regulations plus the following:
5.03.(2) Street improvements adequate to accomodate traffic volume
generated by the proposed use and to provide safe convenient access to the
use shall either be in place or shall be constructed in conjunction with
the proposed 1 ;
. 5.03.07(2) Truck and auto traffic to and from such uses shall not create
hazards or nuisance to areas elsewhere in the County.
5.03.08 Industrial Performance Standards Opera±i:onsshall be conducted
in such a manner as to minimize...dust
5.03.09 Uses Not Itemized;
(1) appropriateness
(2) more hazard
(offensive noise and dust
(4) compatibility
On March 30, 1981 a public hearing was held regarding a spu appli.c.
to allow an asphalt batch plant, described in the minutes as "2 miles
South of Hardwick Bridge about mile east of Co. Rd. 109. An impact
statement was called for, and one dated April 8th, 1981 was presented.
fn the Impact Statement, it says, "The following information addresses
the Garfield Col Zoning resolution, Section 5.03.07 Industrial Ues.
5.03.07(2) "Traffic from the proposed asphalt plant is expected to
add approximately 30 round trips per working day to County Rad 109.
Thi -01 -,estimate is for 1-1-e peak season and will varry with demand, weather,
and season. It is no expected that this traffic m County Road 109 will
create a hazard or nuisance to areas -elsewhere in the County.
The 1980 impact statement does not address traffic or access
roads at all, and this 1981 statement addresses only additional
traffic generated by the asphalt plant, with no mention of the
total number of trips that the whole operation is going to generate.
There is also no update and the condition or appropriateness of
109 road, nor of the fact that by 1980/81, Carbondale has grown
so that the center of Carbondale has become the 108 traffic light
where the trucks turn onto Hiway 133, nor that 109 road has become
a fairly heavily used road as the short cut from Westbank to C'dale.
I did a spot check over a week in August, and came up with
these approximate figures for the usage of 109 road by type of
vehivcle"
6 am to 6 pm
92 trucks
4.8 pickups or small trucks
116 cars
256 vehicles per day
If you include another 10 trucks that go during the night and about
another 30 cars you get almost 300 vehicles per day.
If you count 1 large truck as 3 cars, that makes the heavy truck
traffic the equivalent of 276 cars per day. The vehicle count on
109 road per day would then be around 440 vehicles per day. That
is a far cry from their representaion of the road in 1977, which even
then was incorrect.
Leonard Bowlby did a road count using the counter that cannot distinguish
the type of_vehicles. He laid the counter down for the Friday and
Saturday of iii-6A5,4o4talkolawaligy weekend, when the traffic of every type
was extremely reduced. Even under those conditons, he got a count
in September
of 260 vehicles in 48 hours.
One of the Statements of Fact in their 1981 Resolution 81-165
incorrectly states:
3. That the proposed use is compatible with the uses existing and
permitted in the district...and the proposed use will not have a
significant adverse impact upon other existing uses, providing
that certain herinafter contained conditions are complied with.
4. That a substantial amount of traffic will be generated by the
proposed industrial operation...much of which will require access
to and from the North acorss Garfield Co. Road 109...which road
will be under increased pressure for improvement as a result of the
proposed industrial operation.
5. That the traffic impact of the proposed industrial operation will
have approx. the same impact as fiVe residential units and that the
impact upon Co. Rd. 109, requiring mitigation will be satisfied by
payment of $.1,000 which will be used at a fuuture time and applied
toward the improvemnt of log in a manner alleviating the pressures
caused by the proposed industrial use.
The Road budget for 109 Road is approx. $4,500.00 dollars per year
and other than paving, no improvements are practical. All the traffic
generated by the operation will be using 109 road, since the Hardwick
Bridge cannot be used. Since there are almost no employees, the
Hardwick Bridge use is negligible. However, since the cost of paving
109 road or rebuilding the bridge both have been estimated by the
Comms to come to around 3/4 million dollars, the $1000 cannot even
begin to mitigate the dust and noise and danger. The Sievers R&D
constargy misrepresent the approriateness and adequacy of 109 Rd.
when, in fact, they dare to bring it up at all. It is also quite
suprising to hear 60 12 -and -14 --wheelers a day compared to 5 residential
units.
Keeping in mind the actual figure of 92 trucks in the 12 hour
period of 6 am to 6 pm, and neglecting the fact that trucks also run
all night, in a letter dated January 11th, 1982, John Kemp
responds to an inquiry from Earl Rhodes with these figures:
" Please note that the estimate for asphalt operations is 30 round trips
per day and that the esti a for the unlimited gravel permit, based
on the limited graveI per'mit"�"""w t` EE was specifica y exc 1. -d- —Condition
3 of the sorrtian80-47oof 3/31/80)41 hat the special use permit
issued pursuant to the winthin resolution shall supercede that special {
use permit numbered 136 dated the loth and llth day of July, 1977!
i 6 round trips pgr-_._d y_. This a total from those two operations
of 46.5 round—Trips per day"( This is of course93 trips -pe± day without
cou~-n ng in
the -E0 ---O-1- so trips for the concrete operations. They forgot
to mention there were three operations and not two!) The letter contines:
"Further, we have been unable to find any documents by which we estimated
, or provided data for, the cement batch plant permit.(They neglected
to give any in their impact statement) Logically, the cement batch plant
permit would generate more round trips per day AND THIS WOULD BE OBVIOUS
TO THE COUNTY."(!!!) The letter continues:"Therefore, it appears that
by way of all three proceedingson the three special -use permits, the County
would have had some knowledge that there would be round trips per day
considerabl in excess of 46.5 based on estimates or data which we
provided an based on the County's own knowledge that a cement batch poant
would generate additional trips per day."(!!1J
At the Gravel Pit public, hearing on March 17th, 1982, it was argued
by a member of the gravel profession that it would not do the Comms. or
the Planning Commission any good to have a range of figures for pit
operations because they can vary so much!
Kemp's letter continues, contradicting what he just said:"Next, I am
providing you with a letter dated January 8th, 1982, from
the sub -leasee of Sievers R&D Co., Fox Aggregates, Inc. which gives
actual round trip totals for the past six months, including all t#pes
of vehicles. As you can see this letter shows conclusively that Tram
all operations, the average rotrips sh
un - per ay was . X111 _
Altrwtx Last summer, I called the Fax pit and asked them if they
kept a log of trucks in and out and was told they did not. Suddenly,
however, we get indusputable figures from June to Dlmmistigimmt4a December
of 1981 that somehow did not exist in August of 1981 when I called.
The 18 round trips a day, or 36 trips is a total misrepresentation.
On December 15th, 1981 Kemp wrote to Earl Rhodes about the accuracy
of their figures.
I would like to take issue with your use of the word "representation"
in reference to certain figures alleged to have been provided to the County
by my client in regard to truck traffic on Road 109. It is our contention
that during previous hearings on the asphalt permit, the concrete batch
plant permit, and the gravel prmit that the County asked us to give
estimates of what we felt the truck traffic would be if the particular
facility was installed, andwe did our best to honestly provide the
County with figures which were within our contemplation a -t -that time.
(This is another reason that having a profile of the range of gravel
pit operation would give the Commi ftei the P&Z some guidlines from
which to judge the accuracy of the proposed operations based on the
real numbers generated by currently running operations. Other wise,
the applicants, when charged with misrepresentation of facts can
answer as Kemp does, denying all responsibility and accountability for
their figures.)
"...SUCH FIGURES WERE NEVER MEANT TO BE ANYTHING MORE THAN ESTIMATES, AND
I DIDNiT KNOW THAT THE COUNTY TOOK THEM TO BE ANYTHING MORE THAN THAT.(!!!)
Also, we have been unable to determine at what hearings such estimates
were given and exactly what those estimates wee since it has been some
years since some of these permits were applied for.:"
In order to get some sort of a picture of the actual figures for
oprating gravel pits, and their locational profile as well, I called
all the operations listed in the 1982 yellow pages.
ACCIDENTS: The Denver Highway Department supplied the information that
from April 1980 through October 1981 there were ±1 at least 11 accidents
with 7 injured. In August, 1981, a truck on the way to the gravel pit
was speeding,lost control, and turned over. In September, 1981 a truck
on the way from the gravel pit,went down the embankment. In Octovwr, 181,
a utility truck pulled over to avoid a car, and turned over. Just
ast week, in March of 82, an asphalt truck pulled over quickly to avoid
colliding with a gravel truck coming around the blind corner near Jack
Snobbles and truned over down the bank. - I /
Speeding, the narrowness of the road, and the soft shoulders aixza
and sharp drop orfs make this one of the most dangerous roads in the
County.
Sand SF Gravel (lrc'r::i t.i onr;
1)Mt-. Aggregate Construction Inc . (876-2676)
'100 335 Rd, Silt
miles to main road; access road is unpaved but wide enough -no
accidents. Around 15 trips a day; neighborhood just farms.
/ 3J --Mt. Mobile Mix (625-1598)
27346 Hiwy 6, Rifle
50 yds to main road- around
access road is paved.
150 round trips perday;no accidents
�;-. S'Ya'.ls rsr9
-� jRam Construction (923-3337)
1893 River Road, Woody Creek
No longer in gravel business; sold to Fox Concrete. They used
to do about 20/30 trips a day when pit was in first stages. They
graveled and widened the road, on their initiate; tried to improve
the road however they could, because "it was beatin the hell out
of our trucks".Spoke to Larry. Always came thru Carbondale, never
used Hardwick Bridge. Howard Vagner is owner.
, 1 Roaring Fork Sand and Gravel -(963-3516)
14156 Hwy 82 , C 'dale
They are right on the highway -estimate around 100 round trips
per day; no accidents
5) mlock Construction -4065 15+1 Road -(945-7720)
here is a concrete and a asphalt plant on same property but
nder different owners -They yse Cty road 154, which is paved and
wide enough --They are around 700/800 feet from highwat. They make
around 100 trips per day.
.moi) Casey Concrete (625-1464)
2070 West 2, Rifle
Highway is 100yds away; access road is gravel but wide enough;
100 round trips a day and no accidents
6) Elam Construction (923-2399)
001+1 Mc Lain Flats Rd, Aspen
Spoke to Harold Elam - their access road runs about 1 mile parallel
to the main road; they go down West Creek Canyon Rd; it is
paved and wide enough; they do around 200 round trips a day. They
wrked with the commissioners when they began the operation; the
road was widened and paved; no accidents. They are located between
Little Texas and Woody Creek Canyon. There is the small town and
a trailer park; is a residential road. They are highly safety
conscious. took them 4 years to get commissioners to let them move
pit from River to this larger location and they are doing everything'
they can"tyring our darndest to obey all the laws,we don't want
to have to go back to the river again." Not a terribly busy road
but because of the residential nature of it, setn letters to all
their customers about the problems of driving on a resident.road
and asked them to be extra careful.35 mph speed limit, widened,
paved, put in guard rails.
?) Loy E'nterp_ es(625-3270L
2070 InleFJ,, 2nd, Iii 11r�-pi I: 1.nc sLi��n
'1'1ic,y :ii't. i:ih Lw(.i Ili pxi;;1 ,i.iirl i;; :[hidAL i rri.i1r2;; Lo o Lher• on.
Road As paved, "pretty narrow". Never had an accident. Do about
rt's per• d:ry. . There are a Yew houses on road , themselves,
and the rest is deserted, just sagebrush.
Concrete Batch Plants
Flash Concrete-- 256 Main C'dale (963-2970)
Batch plant on Hiwy 52- around ti trucks, doing around 3 trips per
day each; around ?Iii trips or 24 rt's per day. No accidents except
one , maybe two years ago , on a dirt road, she didn't remember which,
where truck got too close to edge and slid down; had to be pulled up.
Mt. Mobile Mix -just off Hiwy 52 (previous page)
Batch Plant on 154 Road, as is Zemlock Construction Gravel pit.
Asphalt Batch Plants
Elam Construction(previous page)
Grand River Construction -4067 154 Rd. -(945-7535)
Highway 52 is 400 yds away. Road is paved, now has chipped top;
no accidents; they do around 20 rts oer day.
Analysis:
No other gravel pit, asphalt..or concrete batch plant reported
Waving any accidents at all.this year. The longest distance
to a main road was IMT.AGGREGATB in SILT, but they reported that
although the access road is unpaved, it is wide enough, there
is little traffic, and they only do around 15 trips a day. Elam
Construction in Woody Creek is around 1 mile from Highway, but
road has been recently paved, widened and guard rails put up in
conjunction with commissioners. They are most highly motivated
and safety conscious of all because they just got permission for
their new location afer 4 years and they don;t want to be moved
back to old location. They sent letters asking safety cooperation
to all their clients, they scrupulously obey speed limits; have
had no accidents. The other are all around 100 to 400 yards from
the highway. Where the access road is gravel it is wide enough
for two truck to pass from different directions. The only com-
parable situation is County Road 154 in Glenwood Springs. This
road contains Zemlock Construction, gravel operation; they make
about 100 round trips per day and estimate themselves to be
around 800 feet from highway;reported no accidents. Grand River
Construction has an asphalt batch plant there; they estimate
they are 400 yards from Hiway 82, do around 20 rts per day, and
have had no accidents. MT. Mobile Mix maintains a concrete batch
plant there; they estimate around 40 trips per day out of this
plant. The total traffic for this triple operation would be
about 140 round trips per day at an average busy period.
f%
Comparative Analysis of Fox Concrete Operation and all Others in Area
Distance.: Fox is about 6 miles west of Carbondale Howay 133, and
about .8irmiles from Hiway 52.
Access Road: `1'ne Route they must take from the gravel pit to Hiway
82 is 10d ,100Ed , & Hiway 133. County Road 109 is a dirt road that
has been graveled. It was reported by Ram Consturction, the original
gravel pit users on that road that it was an inadequate road when
they first began as a small operation. They widened the road where
they could and graveled it because of the wear and tear it was
causing on their vehicles. It contains 6 blind curves along the
Li. miles from the pit to 108 road. There are also at least 5
stretches of road where it is slightly larger than 1 lane and two
truck could not safely pass one another doing the speed limit.
Character of neighborhood along access roads: Since most of the
other operations are just off Hiway 52, this is not a factor.
Elam (Jonstruction , Mt. Aggregate, and Loy Enterprises are the
only ones that have to travel any distance to the main hiway.
In the case of Mt. Aggregate and Loy Enterprises, the surrounding
area is mainly farm and field/sagebrush. In the case of Elam
Construction, it is a residential area,near the Woody Creek Trailer
Park, and Little Texas, and extra safety precautions have been
anf are being taken to protect the population and preserve their
right to maintain this location. I spoke to the Woody Creek
Trailer Court, however, and they told me that the entire town of
Woody Crek was against the gravel pit when it was put it, and
that they are still trying to find a way to convince the commiss-
ioners that it is inappropriate to have a pit in a residential
area. They said the main problems were speeding and noise pollution.
Fox trucks pa s CRMS school, residences & Crystal Village & Hwy 133.
Condition of, Acess RoadS;In most cases, the distance is short
and the road is paved. However, where it is a dirt road, it is
wide enough for two trucks to pass confortably.
Accidents: ALL the gravel pits, and the concrete and asphalt
batch plants report NONE, 'e j - 0 Foy /� /Z,9,{f%,
In the Special Use Permit, granted under Resolution 81-165 of Mlay,l981
it states:
The within SUP is issued subject to the
conditions set forth in the above mentioned
resolutions...and shall be valid ONLY DURING
COMPLIANCE WITH (this) ...and otherr gura'tions
of the Bd. of County Comms.
The Sievers operation has clearly and continues to, violates the
previously mention Zoning r.egulations,'since it received its permits
under false pretences to avoid having to be in compliance with them.
It could actually never have obtained the three permits that it did
if it had correctly stated the information pertainly to those regulations.
The following are quotes from the current Garfield CountLMaster
Plan which the Sievers operations also contradict:
In a letter dated August 13th, 1981 from Walter Brown,III, attoq
for Oxenberg to Sievers R & D, he states:"...The County has requested
the Highway Patrol to patrol Raad 109 since the speed limit has been so
consitenly violated by Lruck emanating; from your operational area.."
To my knowlege, I have only seen a Sheriffs car go down that road
once, on a Sunday. The Sheriffs Dept. and Highway department are not
large enough to provide additonal cars and men to patrol this road,
Under Community/Social Services, p. 5 of the GCO Plan, it says:
A. Police/Sheriff
1. The County Sheriff's Dept. serves the entire County. The Dept.
is not oriented to handle and cannot serve large scale developrnent without
specific measures to mitigate the demans of such development en the Dept.
Under Industrial/Commercial , p. 6:
VT. OTHER (POLICIES?REGULATIONS)
A. Policies
6. Encourage industrial expansion where similar developrnent already
exists in appropriate areas, i.e. eithin or adjacent to platted industrial
parks, within desgnated industrial zones in existing town, or adjacent
to existing similar development.
7. Encourage industrial development in areas where adequate transportaion
facilities and public utilities are available.
POLICIES:(p. 6)
1. The County may require significant commercial and industrial proposals
to compltete a statement of impact on surrounding adjacent land uses,
transportation facilities, local•economy, local taxes, and demand on
services.
2. The County shal- require all large scale i„uustrial and commercial
development to mitip;ato any advrse impacts it amay have on the County or tc
in proximity to the proposed development. :such actions may apply to,
but are not limited to, schools, health care, fire and police protection,
ROAD CONDITIONS, TRAFFIC GENERATED, and sewer and water facilities.
5. Industrial development shall occur within designated areas within
existing municipalities or adjacent to existing appropriate industirial
areas.
Under TRANSPORTATION, p. 20
OBJECTIVES:
2. Ensure that, roads considered inadequate to service additona.l developmenr
are upgraded as development occurs.
10. Require,t. w developmet to contribute to the improvement of roadways
wyhich will be adversely impacted by the glconstruction of that development
11. Separate heavy truck And commercial traffic from local commuter and
tourist traffic.
13. Maintain roads as their designated t
local.
r,
Q- arterial, collector, and
14. Establish standards for road improvments or upgrades,(I.E. 500
vehicle trips per day should have a paved surface)
17. Maintain existing roads in a manner which will meet demands. Con-
struction o f new roads in undisturbed areas is discouraged.
POLICIES
2. The County may require all development proposals to include a
` statement, regarding the transportation impact of the proposal,
i.e traffic generated, increased maintenance costs, inc.
3. The County sihal1 require any development proposed which accesses
from a poor or inadequate road to improve that road to standards
acceptable for the proposed type and volume of traffic generated by the
development and other existing uses in the area.
5. The Cou^ty shall establish a program to schedule street improvements
throughout the County. The program should be based on current need and
oroad conditions.
67) Major Roadwaysshall be designed to mitigate potential impacts on
adjacent land uses Ample rights-of-way, landscaping and careful
attention to views and other natural amenities should be used to create
a safe, attractive, compatible roadway system. Buffers of landscaping
should be used to screen noise and odor pollution cause by trucks.
12. The County may deny development proposals on the basis of:
1. Lack of road access to the site
;' . .inadequate road accesF, which will create an indequate road with.
large daily traffic volumes
_3. a road which isalready at or above its design capacity and due
to the terra- or geology of the area, cannot be 4further improved
to safely ac modate additional daily 'fic volumes.
P. 116
CARBONDALE URBAN AREA OF INFIX
"The lands surrounding Carbondale are agrarian in nature. Productive
agricultural lands should be buffered from development to ensure
minimum interference with agriculture operations. Developmemt should
mitigate its impact on agricultural atreas.
ACCESSIBILITY: fair
Roads leading west from Carbondale are limited and generally are not
in a condition to support further development. Directly west are County
Roads 106, 109, and 108....County Road 106 is paved and County Road 109
is gravel. Neither road is in a condition to support further developement
Roads: p. 70 ff
Road access and conditions shall be used to evaluate the relative
ability of areas within District (C,D,E,) to absorb growth. Roads
in a condition unsuitable to support further development and/or
areas with no access shall be considered lest able to absorb growth.
PART III -PERFORMANCE STANDARDS p. 87
e ff standards apply to the road system in Garco. These guidelines
are intended to ensure the ability of the Garco roads to safely and
adequatly accomodate growth.
I. Road Systems
A. Potential Problems
1. Congestion, traffic back --up
2. Hazardous intersections, accident areas
=3. Inneficient road system design
4. Dangerous roads in poor conditions.
B. Performance Standards
1. Traffic generated by a development shall not exceed the
existing capacity of adjacent roads or identified critical
intersections that will serve the project. If the traffic
generated negatively impacts roads or intersections, the
developer shall aid in alleviating these negative impacts.
p. 89
The ff standards are intended to ensure the compatibility of proposed
land used and existing land uses. These guidlines mma should be used to
mitigate potential adverse impacts of new development and to avoid
conflicts among varying typs of land uses.
89
The following standards are intended to ensure the com-
patibility of proposed land used and existing land uses.
These guidelines should be used to mitigate potential
adverse impacts of new development and to avoid conflicts
among varying types of land uses.
I. Co patibility: Ceneral
A. Potential Problems
1. Creation of public nuisance in adjacent
or surrounding areas.
2. Adverse effects to the desirability of
neighborhoods or the entire community.
3. Alteration of the basic character of
adjacent land uses.
4. Impairment of the stability or value of
adjacent or surrounding properties.
b Performance Standards
1. Proposed land uses shall be required to
provide adequate mitigation of potential
impacts to ensure maximum compatibility
with all adjacent land uses.
2. An incompatible situation shall be solved
before the proposed development will be
approved.
a. Proposed land uses with a more intensive
land use rating than the adjacent land
uses shall reduce or alter all the more
intensive uses until that proposed use
is compatible with the adjacent property
to the satisfaction of the County
Commissioners.
3. Compatibility may be judged in two different
ways depending on the existing and the pro-
posed land uses:
a. A higher intensity land use proposed
adjacent to a lower intensity use shall
remedy those higher impacts. (Example:
A commercial center proposed adjacent to
a low density residential neighborhood.)
90
b. A low intensity use proposed adjacent
to a higher or unsightly use shall
screen or otherwise alleviate the
existing negative impact. (Example:
A proposed low density residential
development adjacent to a gravel pit.)
Any proposed land use may be deemed incom-
patible for the following reasons:
a. Adversely affecting the desirability
of the immediate neighborhood or the,/
entire community.
b. Impairing the stability or value of
existing adjacent properties.
c. Adversely affecting the quality of life
of existing adjacent residents.
d. Showing a lack of quality or function
in site planning and design.
,e. Creating a public danger or nuisance"
to surrounding areas. 7
f. Altering the basic character of adja-
cent land uses or the entire community.
II. Compatibility: Traffic
A. ,"Potential Problems
1. Dangerous truck routes and high speed traf-
fic on roads which access residential areas.,
2. Dangerous traffic near residential areas.
B Performance Standards
1. Proposed traffic of a higher volume shall\
not be generated through a lower traffic
volume area without appropriate mitigating,
or buffering methods.
2 Trucks, high speed, or heavy traffic shall,
not be routed through local roads, resi-
dential areas or towns.
3. Truck traffic shall be rerouted around
municipalities as soon as adequate by-
passes are designed and constructed,
4. Residential developments adjacent to
arterials or major collectors shall be
appropriately screened from that road,
both visually and from noise effects.
91.
5 Developments adjacent to arterial or
collector streets shall avoid the use of
individual driveways. Local frontage roads,
shared driveways or other acceptable methods
should be used instead.
11.1. Compatibility: Smoke Dust_ 2 Odors
A. Potential Problems
1.. Hazard to public health and safety.
2. Nuisance Co surrounding area or community.
3. Reduction of land values and degeneration
of properties.
B. Performance Standards
1. All new roads and parking areas shall be
maintained in a condition which will pre-
v„ent_ dust generation.
/
2. Dust, odors and fumes shall be contained
/ within the site generating such emissions
and shall not negatively affect any sur-
rounding land use. (Exception: Agricul-
tural land uses shall not have to comply
with this performance standard.)
3. Smoke emission shall be kept to a minimum
within acceptable EPA standards.
IV. Compatibility: Noise
A. Potential Problems
1. Unpleasant disturbance in noise -sensitive
areas.
2.. Reduction in property values.
3, Conflict with numerous noise -sensitive land
uses which may potentially inhibit residen-
tial life-styles.
B. Performance Standards
*NOTE: Noise sensitive land uses include, but
are not limited to, residential, cultural,
educational, natural environment, agri-
cultural, and areas of public assembly.
Proposed land uses which may cause a noise
disturbance or nuisance to adjacent or sur-
rounding properties shall be prohibited, un-
less the noise disturbance can be effectively
"ontralled within the proposed project site.
/9
In Resolution, 80-47, of March, 1980, the SPU permit was issued"upon
.he following specific conditions:
1. That the use of the tract of land comply with ALL PRESENT
AND FUTURE REGULATIONS of Garfield Co. relating to all uses...
in tYp zone district in which the property is now or may later
he located.
2. That no more than 20% opacity of fugitive dust be cereated
at the plant or on Co. Rd. 109.
COLORADO DEPARTMENT OF HEALTH
Richard D. Larnm �c " c Frank A. Traylor. M.D.
Executive Director
Governor J 8 Z 6
CERTIFIED MAIL NO. P454055153
June 30, 1983
Sievers Ranch and Development Co.
3794 County Road 109
Carbondale CO 81623
c.
Re: Official Notice of Violation
Dear Sirs:
Your attention is directed to the Colorado Air Quality Control Act, CRS, 1973,
Sections 25-7-114(1) and (4), which read as follows:
"(1) No person shall permit emission of air pollutants from, or construc-
tion or alteration of any facility, process, or activity except residen-
tial structures from which air pollutants are, or are to be, emitted un-
less and until an air pollutant emissions notice has been filed with the
Division with respect to such emission. A revisedemissions notice shall
be filed whenever a significant change in emissions is anticipated or has
occurred. The commission shall exempt those sources or categories of
sources which it determines to be of minor significance from the require-
ment that an air pollutant emissions notice be filed."
"(4) No person shall construct or substantially alter any building,
facility, structure, or installation, except single family residential
dwellings, or install any machine, equipment, or other device, or commence
the conduct of any combinations thereof, or commence operations of any of
the same which will or do constitute a new stationary source or a new in-
direct air pollution source without first obtaining or having a valid per-
mit therefor from the division, board, or commission, as the case may be;
except that no permit shall be required for new indirect air pollution
sources until regulations regarding permits for such sources have been
promulgated by the commission. The commission shall establish rules,
regulations, and procedures in accordance with the provisions of this
article for the granting or denial of permits which shall be in conformity
with the purposes of this article, as set forth in Section 25-7-102, but
125 NORTH 8TH STREET, GRAND JUNCTION, COLORADO 81501 PHONE (303)245-2400
Sievers Ranch and Development Company
June 30, 1982
Page 2
in no event shall regulations governing indirect air pollution sources be
more stringent than those required for compliance with the federal act and
final rules and regulations adopted pursuant thereto. Such procedures
shall include, but not be limited to, the following:..."
It has come to the attention of the Air Pollution Control Division that your
firm owns a gravel pit located south of Glenwood Springs on County Road 109.
A review of the Division's Permit files indicates that a permit has never been
issued for this operation.
Should the gravel pit continue to operate without first obtaining a valid
emission permit you will be subject to enforcement action in accord with
Section 25-7-121(1) (court injunction) CRS, 1973, which reads in part as
follows:
"In the event any person fails to comply with a final order of the board,
the division, or the commission that is not subject to stay pending admin-
istrative review, or in the event any person constructs, modifies, or com-
menceo operation of any air pollution source in violation of Section
25-7-114(4), the board, the division, or the commission, as the case may
be, may request the district attorney for the district in which the alleg-
ed violation occurs or the attorney general to bring, and if so requested
it is his duty to bring, a suit for an injunction to prevent any further
or continued violation of such order or of Section 25-7-114(4)."
Also be advised that you are subject to civil penalties up to 05,000 per day
as provided by Section 25-7-122(1)(h), CRS, 1973, which reads as follows:
"Any person who violates the requirements of Section 25-7-114(4) regarding
construction, modification, or commencement of operation of an air pollu-
tion source without such a permit shall be subject to a civil penalty of
not more than twenty-five thousand dollars per day for each day of opera-
tion after receipt of the notice of noncompliance or violation."
Finally, you are also subject to a $100.00 civil penalty, in addition to the
above cited penalty, as provided by Section 25-7-122(1)(c), CRS, 1973, which
reads as follows:
"Any person failing to comply with the provisions of Section 25-7-114(1)
shall be subject to a civil penalty of not more than one hundred dollars."
Sievers Ranch and Development Company
June 30, 1982
Page 3
If your firm submits an ADEN and permit application with all necessary in-
formation, a preliminary analysis of proposed air pollution control meas-
ures will be made to insure compliance with all applicable air quality con-
trol regulations and standards. If no problems are found, an initial ap-
proved permit will be issued allowing you to operate at that time.
YOUR OPERATION WITHOUT A PERMIT IS ILLEGAL. All operations must be discon-
tinued immediately and until such time as an emission permit has been ob-
tained or action may be taken under the above cited Sections of Title 25,
Article 7, CRS, 1973.
If you have any questions, please contact me.
Sincerely,
ScAt .J ler . %
Air Pollu on Control Division
SJM/zp
cc: Garfield County Commissioners
Ed Feld, Garfield County Sanitarian
Steve Frey, EPA
Denver Office
File
DIVISION OF MINERALS AND GEOLOGY
Delta rtmrnl of Natural Resources
1 11 I Sherman S1.. Ronne 2( 5
11cnvel. (() 8(12111
I'linno.. 41(1, 81,6-1567
AX: . 1114! 812.81116
MINERALS PROGRAM INSPECTION REPORT
R. rc Rnnmr
emu,
Mt hare If. 1 nng
Ukuin 11)ur. h n
The Division of Minerals and Geology has conducted an inspection of the mining operation
noted below. This report documents observations concerning compliance of the mining
operation with the permit and the regulations of the Mined Land Reclamation Board. The
report notes 1) Areas of successful compliance; 2) Problems and suggested corrective actions
and/or 3) Possible violations to be considered for possible enforcement action by the Mined
Land Reclamation Board. OPERATORS SHOULD READ THIS REPORT CAREFULLY BECAUSE IT MAY REQUIRE
CORRECTIVE ACTION AND/OR RESPONSES TO THE DIVISION IN ORDER TO AVOID CONSIDERATION OF
POSSIBLE ENFORCEMENT ACTION BY THE MINED LAND RECLAMATION BOARD.)/
MINE NAME
S/�vers /27HGK- 7„9- / '1 OPERATOR' /4ifrtH 4/Pk 401 121/—S
COUNTY 6AR�f+/eth ,,qq 1 MINERAL^J/F�/4 lE/ 4%2/�l/%r./ TYPE OF OPE T ON oPr U /T -//Z
INSPECTOR(S) (4gKi (.//r%/st (Air/ /"WU� SIGNATURE thy �/r
MINE ID # OR PROSPCTING ID # 11% 77— o98 /
/O//Z/ r 3 DATE OF COMPLAINT ,m,.
G So-�•oIC TIME OF DAY (MILITARY) — o /vdv
HZ POST INSP. CONTACTSe4 0 /I-
INSPECTION DATE
INSPECTOR'S INITIALS
INSPECTION TYPE CODE(11
JOINT INSP. AGENCY CODED'
WEATHER CODE(a1 C
4-4-0 640
REASON FOR INSP. CODEO1
OP. REP. PRESENT /'en SO�/QJ e/ /
CI //l WfiOledd(W, Uolhic_)/4seest
1. INSPECTION TYPE CODE - (CL -IN: IL=Illegal Operation, MI=Monitoring, MP=Mineral Prospect, SI=Surety-related, PR= Pre-operation)
2. POST INSPECTION CONTACTS AND JOINT INSPECTION AGENCY CODE - ICL -AG: NO=None, BL=BLM, CH=Colo. Dept.Health; CL= Land
Board, CT=Citizen; C W =Wildlife, FS =Forest Service, HW = Hwy. Dept., LG = Local Government, SE=Sate Engr.I
3. REASON FOR INSPECTION CODE - [CL -RS: AG=Other agency request, CT=Citizen Complaint, IE=Normal l&E Program, HP=High Priority,
PY = Priority]
4. WEATHER CODE - [CL -WE: CL=Cloudy, CR=Clear, IN =Inclement - prevented inspection, RN=Raining, SN =Snowing, WD= Windy]
This list identifies the environmental and permit parameters inspected and gives a
categorical evaluation of each. IF PB OR PV IS INDICATED YOU SHOULD READ THE FOLLOWING
PAGES CAREFULLY IN ORDER TO ASSURE COMPLIANCE WITH THE TERMS OF YOUR PERMIT AND APPLICABLE
RULES AND REGULATIONS. If PV is indicated, you will lbe notified under separate cover when
the Mined Land Reclamation Board will consider possible enforcement action.
(AR)RECORDS
(HB)HYDROLOGIC BALANCE
(PW)PROCESSING WASTE/TAILINGS
(MP)GENL MINE PLAN COMPLIANCE
(SM)SIGNS AND MARKERS . . . .
(ES)OVERBURDEN/DEV. WASTE .
(AT)ACID OR TOXIC MATERIALS .
GENERAL INSPECTION TOPICS
(FN)FINANCIAL WARRANTY . )7
713 (BG)BACKFILL & GRADING .
Y (SF)PROCESSING FACILITIES
(FW)FISH & WILDLIFE . .
�7�r` (SP)STORM WATER MGT PLAN
/ (SC)EROSION/SEDIMENTATION PIS
/Aid(OD)OFF-SITE DAMAGE . . P/3
LLQ
(RD)ROADS . . . . I'!
(EX)EXPLOSIVES . NA -
(RV) REVEGETATION /PA
(TS)TOPSOIL . . .
(RS)RECL PLAN/COMP
(ST)STIPULATIONS ry JT
Y = Inspected and Found in Compliance PV = Inspected and Possible Violations Noted PB = Inspected and Problems Noted
N = Not Inspected NA = Not Applicable
WHITE - PUBLIC FILE
PINK - OPERATOR
YELLOW - CORRESPONDENCE FILE
,M (PAGE 2)
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INSPECTIN DATE _7 O / a/ q 3 :NSY:CrCR S INITIALS ( S G
( J OBSERVATIONS �/ J/ ---�
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INSPECTION DATE 4//2/93
INSPECTOR'S INITIALS a'SC
OBSERVATIONS
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The following problems (PB) and/or possible violations (PV) (and suggested correctiVe actions) were
identified during this inspection. The problems should be corrected by the dates given, or they will
become possible violations. The possible violations should be corrected by the dates given to reduce
their severity when considered by the Mined Land Reclamation Board.' The inspector noted on the
previous page should be notified of all corrective actions taken.
L'E4sLEuaceusatam_SLIOLAII4Ns
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CQEEECIIVE_flCIIQNS
Correction q
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CURRENT SPECIALIST a V C.
FILE NO. M_
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TOPIC g J$ / C2 b
**NOTE; DP Entry go to Permit File
Decision/Issuance Data Entry to
change Current Specialist.**
MINE ID # OR
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(PAGE 1)
PROSPECTING ID #: i�7 7^ O9
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PROBLEMS/POSSIBLE VIOLATIONS
AND
CORRECTIVE ACTIONS
INSPECTION DATE
INSPECTOR'S
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TOPIC (SI S c
STATE OF COLORADO
COLORADO DEPARTMENT OF HEALTH
Dedicated to protecting and improving the health and
environment of the people of Colorado
4300 Cherry Creek Dr. S. Laboratory Building
Denver, Colorado 80222-1530 4210 E. 11th Avenue
Phone (303) 692-2000 Denver, Colorado 80220-3716
(303) 691-4700
October 28, 1993
Mark Bean
Garfield County Planning Director
109 8th St.
Glenwood Springs, CO 81601
Re: Sievers Ranch Pit
SW GAR GEN
NGS 0 1993
GARFIELD COUNTY
Roy Romer
Governor
Patricia A. Nolan, MD, MPH
Executive Director
Dear Mr. Bean:
In a telephone conversation with you on October 27, 1993 you referred to an inspection to
of the Sievers Ranch Pit by members of the Division of Minerals and Geology that occurred
on October 12, 1993. Your concern is regarding the potential of having to obtain a
certificate of designation (CD) under the Solid Waste Act for placing clean fill, ie. clean soil
into this pit to be used for reclamation purposes. My purpose in writing is to inform you that
a CD is not required in this instance. If the pit were taking trash, construction debris,
garbage or the like a CD would be required.
I have enclosed a copy of the inspection report that I received for your use plus a copy of
our draft inert fill policy. The latter document will remain draft until our assigned attorney
general and the Division Director approve it. I hope that you find these to be of use if you
have questions conc ning -tliis matter I may be reached at 692-3445.
Sincerely,
o F. Mallory 24-1-ely
ectin Chief
Solid Waste Program
Hazardous Materials and
Waste Management Program
enclosures
cc: Carl Mount, DMG
Post -It'" brand fax transmittal memo
7671# of pages .
I
To 't , t/r-/L6l'7/ L1r4
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Co. GGs7s° v Nio4 4-
co.6ar4e4i ep .
Dept.
Phone ft/73— (3,2_ / 1J
Fax #,-4-5--747--
Fax#