Responsiveness Summary for the Second Explanation of Significant Differences

a o

Colorado Department V of Public Health and Environment Responsiveness Summary for the Second Explanation of Significant Differences Lowry Landfill Superfund Site

ARCS Contract No. 68-W6-0036 EPA Work Assignment No. 016-ROBF-0808 CH2M HILL Master Project No. 139814 DCN 97-456

Volume II of II

Prepared for

U.S. Environmental Protection Agency

Prepared by

CH2M HILL

October 1997

H:\DA\WORDPWIN\005.WPD Preface (How to Find Your Letter)

More than 400 letters with comments were submitted to the United States Environmental Protection Agency (EPA) during the public comment period on the Lowry Landfill Superfund Site Second Explanation of Significant Differences. This Responsiveness Summary document provides responses to all of the comments and questions received in those letters and other communications during that period. This preface explains how to find a particular letter within this two-volume document.

This document is composed of the following two volumes:

Volume I

• Preface • Executive Summary • Comment Letters Index • Acronyms and Abbreviations • Responses • References • Glossary • Attachments

Volume II

• Preface • Comment Letters Index • Copies of the original comment letters

To find a particular letter in this document, go to the Comment Letters Index that follows the Executive Summary in Volume I and this Preface in Volume n and search for the last name of the person who signed the letter. The Comment Letters Index is arranged alphabetically by the last name of the persons who signed the letters. In some cases, signatures on some of the letters were not legible. Because other copies of the form letters were available, these illegible signatures are not included in the Comment Letters Index, but copies of the form letters with the illegible signatures are included in Volume II.

The Comment Letters Index is divided into three columns. The first column is arranged alphabetically by last name. The second column provides the page number in Volumn n where a copy of the original letter the person signed can be found. The third column provides the page number in Volume I where the responses to the letter(s) the person signed can be found. In some cases, the same person sent in more than one letter. In these instances, there are multiple page numbers listed in the second and third columns.

H:\DA\WORDPWIN\009.WPD A number of questions repeated frequent themes. The Executive Summary presents general responses to these frequently asked questions.

Some of the responses in the document refer the reader to specific sections of the Executive Summary so that the response is complete. When a response says (see Executive Summary - Sludge/Biosolids), this means the reader is referred to the section in the Executive Summary with the heading "Sludge/Biosolids." Additionally, the Executive Summary contains an overview of the Lowry Landfill Superfund Site history and a description of the Publicly Owned Treatment Works option.

Upon receipt of all of the comments at the close of the public comment period, EPA and the Colorado Department of Public Health and Environment (CDPHE) carefully reviewed and evaluated each comment. Based on this review and thoughtful consideration, EPA and CDPHE developed a response to each comment. These responses are presented in Volume I.

H :\DA\WORDPWIN\009. WPD Comment Letters Index

Volume/Page No. Volume/Page No. Name of Comment of Response Moe Albert H/121 1/69 Rayma Albert n/388 1/72 Laura Alexander El/122 1/69 BillR. Allison H/123 1/69 Dene D. Allison n/124 1/69 LeonaR. Allison n/125 1/69 Adrienne Anderson U/509 1/75 Beverly Anderson n/6i7 1/129 Ken Armstrong n/i26 1/69 Pat Armstrong n/127 1/69 E. Jordan Asnicar n/5ii 1/79 Jean Bain 11/487 1/74 LeRoy O. Bank 11/647 1/148 Cindy Ban- 11/128 1/69 Marian B. Beach 11/129, 617 1/69, 129 Kathryn Beer 11/141 1/69 Deborah M. Behrens 11/130 1/69 Janet Bergdorfer 11/234 1/69 Mindi Leigh Berry 11/264 1/69 James Bilisoly 11/131 1/69 Lynne Bilisoly 11/132 U69 Cleo M. Blakney 11/389 Mil Colleen A. Boland 11/133 1/69 Richard A. Boland JJ/133 1/69 Dennis D. Bollmann 11/637 1/146 Harold Bolstad H/390 1/72 Doug Bongiorni 11/391 1/72 Evonne Bongiorni 11/392 1/72 B. Bonlee 11/134 1/69 Geraldine M. Bowman 11/135 1/69 Lucinda Boyd 11/567 1/89 B. Boyett 11/136 1/69 RuthE. Boyett 11/136 1/69 Jessica Brannan 11/137 1/69 Mike Braudrick 11/138 1/69 George Brawly 11/139 1/69 Rosie Breeden 11/140 1/69 Pamela Brosel 11/141 1/69 Daniel L. Brotzman 11/512 1/80 Paul W. Brown 11/142 1/69 Jaime Burchfleld El/393 U72 MarkR. Burchfield 11/394 1/72 Ronald E. Burchfield n/395 1/72 Ruby A. Burchfield 11/396 1/72 .in da Cacek 11/143 U69 Donn L. Calkins 11/515 1/80 L. T. L. (Lin) Callow EE/503 1/74 Comment Letters Index

Volume/Page No. Volume/Page No. Name of Comment of Response Mike Card n/144 1/69 Stephen Card Et/397 1/72 Susanne G. Card H7144, 398 1/69, 72 Bob Carlson n/618, 645 1/129, 147 Kathy Carter n/145 1/69 Caryl Cat n/i46 1/69 Ramona Chase n/u? U69 Wil Chase n/517 1/81 David Clark n/148 1/69 Valrie Clark 11/148 1/69 Richard B. Clay n/i49 1/69 DanaD. Clay H/399 1/72 Leonard W. Cole 11/488 1/74 Harry Collins n/iso 1/69 Nancy L. Collins n/151 1/69 (Illegible) Coolidge n/141 1/69 Brandy Cowell n/i52 1/69 Debbie Cowell n/i53 1/69 Thomas A. Cox n/i54 1/69 Virginia Cox n/400 1/72 Harvey Crandell n/483,617 1/73, 129 Galen Crawford n/i55 1/69 Olive Crawford n/156 1/69 W. Crawford n/157 1/69 Ken Crawford n/40i 1/72 Anne Culver n/518 1/81 James Currier 11/402 1/72 Dave Dannar H/158 1/69 Craig Darnell 11/159 1/69 Wendy Darnell 11/159 1/69 Marilyn R. Davies 11/403 1/72 Edward Davis 11/404 1/72 Tammy Sue Davis 11/405 1/72 Michael O. Dean 11/325 1/69 Walter L. Dinwiddie 11/647 1/148 R. Dobey n/i60 1/69 Charles Dorrance 11/161 1/69 Donna Dorrance n/162 1/69 Edie Dorrance 11/163 U69 fan Dorrance 11/164 1/69 Judith Dorrance n/165 1/69 vlike Dorrance n/166 1/69 Saundra Dorrance n/167 1/69 Jane Dough n/168 1/69 ;rank Doyle n/519 1/82 Patty Doyle 11/519,617 1/82, 129 bseph J. Drexler n/520 1/82 Comment Letters Index

Volume/Page No. Volume/Page No. Name of Comment olf Response John D. Drummond 11/169 1/69 Elmer Dudden 11/563 1/87 Edwin O. Edlund 11/647 1/148 Clarence G. Eldringhoff n/no 1/69 Susan Eldringhoff n/ni 1/69 Don Erickson n/i75 1/69 Sharon R. Estell JJ/564 1/87 K. M. Falino H/234 1/69 Marge Falino n/234 1/69 Justina L. Falls 11/234 1/69 Patricia Fanner 11/565 1/88 LoriL. Fischer 11/172 1/69 Terry D. Fischer 11/173 1/69 [vy Fischer n/406 1/72 Donna Fletcher n/174 1/69 Winifred Forbes n/i75 U69 D. Francis n/i76 1/69 Jerry J. Francis 11/177 1/69 Patricia R. Froman 11/178, 617 1/69, 129 Daniel Galanaugh 11/489 1/74 Deborah K. Gardner 11/179, 180 1/69 Dean Gaudat H7607 1/123 Sharon Gaudot n/181 1/69 DelLoyd George n/182 1/69 Diane Gilbert n/i83 1/69 AlanJ. Gilbert 11/502 1/74 Clarine Glass 11/407 Mil Donald E. Grahlmann n/i84 U69 Marian Grahlmann n/185 1/69 Kathy Griffin n/i86 1/69 Debby Grindel n/i2i 1/69 William A. Groves, Jr. 11/490 1/74 Ray Gunter 11/408 1/72 Shirley Gunter 11/409 1/72 Stacey John Gust n/i87 1/69 Emmy Gustafson n/i88 1/69 Tammy Guy n/189 1/69 Pearl A. Hageman n/617 1/129 Frank C. Hahn n/i90 1/129 Sheryl E. Hahn n/i9i 1/69 Elmer Hall n/192 1/69 James Hall n/i93 1/69 Dennis H. Hall H/157,410 1/69, 72 Gerald A. Hall n/4ii Mil Amber Hambek n/194 1/69 Conine K. Hammel 11/195 1/69 Elmer Hanes 11/196 1/69 Comment Letters Index

Volume/Page No. Volume/Page No. Name of Comment of Response Darlene Hanket n/4i2 1/72 Thomas W. Hanket n/4i3 1/72 Carolyn Hankins n/197 1/69 Jerry Hankins H/198 1/69 Dr. John W. Hanks n/199 1/69 Clara M. Hanks n/200, 484 1/69, 73 Harold E. Hanks H/200, 484 1/69, 73 Harry Hanks n/566 1/88 Leslie Hanks U/201, 567 1/69, 89 Peter Hanks n/202 1/69 John Hanks 11/414 1/72 M.A. Hanks 11/568, 645 1/89, 147 Margaret Hanks H/414 Mil Albert K. Hanlon 11/415 1/72 Margaret F. Hanlon JJ/416 1/72 Neil Hansen C/491 1/74 Angela Hart U/203 1/69 Eric Hart 11/417 1/72 Jack Hawkins 11/573 1/93 Larry Heath 11/204 1/69 Fred Hendrickson 11/492 1/74 Wanda Hetfield 11/205, 617 1/69, 129 Richard S. Hillier n/580, 586 1/97 Bill Hingeley U/418 Mil Robert W. Kite 11/598 1/122 ? Hollingsworth n/207 1/69 Mr. and Mrs. Forest E. Hollingsworth n/206, 419 1/69, 72 Gene Hollingsworth JI/208 1/69 WardL. Hollingsworth 11/381 1/69 Donald S. Holstrom n/596 1/121 Mr. & Mrs. Jerry Hooker U/209 1/69 JayN. Hutchison H/504 1/74 Arden L. Intermill n/2io 1/69 John R. Jacus H/602 1/122 Claudine Jeannenaud n/2ii 1/69 Rose Jennings n/421 1/72 Bill Johnson n/212 1/69 Linda Johnson n/213 1/69 RheaR. Johnson H/214,617 1/69, 129 Hugh E. Johnson U/422, 423 1/72 Nancy L. Johnson H/424 Mil. Patricia L. Johnson 11/425 Mil Roselle Johnson n/493 1/74 Almeda M. Jones 11/215 1/69 Christine Jones n/216 1/69 Michael Jones H/217 1/69 Nina Judd n/604 1/122 Comment Letters Index

Volume/Page No. Volume/Page No. Name of Comment olf Response Char K(?) n/208 1/69 Craig Keel n/218 1/69 Donna Hall Keel n/219 1/69 J. Keenan n/220 1/69 Bobbi S. Keenan n/426 1/72 Florene K. Kershman n/221 1/69 Paul Kettering H/222 1/69 Marylin Kitchen n/223 1/69 Carol Kitzman H/303 1/69 Steven A. Knutson 11/427 1/72 Daniel L. Koephe 11/224 1/69 Glenn Koephe 11/225 1/69 Sandra S. Koephe n/226 1/69 Norma J. Koephe 11/428 1/72 M. Konrath 11/228 1/69 Michele Konrath 11/227 1/69 Allen Konrath 11/605 1/123 Karen Konrath 11/606 1/123 Margaret E. Kontour 11/229 1/69 Mildred L. Kontour 11/429 1/72 Ken Koslowski 11/230 1/69 Garry J. Kramer n/231 1/69 Dolores Kroh n/232 1/69 Carl Kroh E/430 1/72 Amy Kuhn 11/233 1/69 Trudy Lacey H/234 1/69 William Larson E/431 1/72 Vlary E. Lasecke n/235 1/69 Dale Lauer H/563 1/87 Dolores Lavoie H/236 1/69 iCate Lawrence n/234 1/69 Ginger Lee tt/234 1/69 Diane Lee n/382 1/69 KentR. Lee 11/383 1/70 Robert W. Legge 11/432, 608, 618 1/72, 124, 129 Wm. A. Lehman n/237 1/69 -(?) J- Lehman n/237 1/69 Dana Lemme n/238 1/69 VeraC. Lessy n/239 U69 Margaret M. Lien U/240 1/69 Doris Lind n/24i 1/69 Harold W. Lind 11/241 1/69 Kelly Lindner n/242 1/69 Lonnie Lindner n/243 1/69 BenJ. Linnebur 11/244, 433 1/69, 72 Chris Linnebur 11/245 1/69 Jeff Linnebur U/246 1/69 Comment Letters Index

Volume/Page No. Volume/Page No. Name of Comment of Response Joseph F. Linnebur 11/247 1/69 Margie Linnebur - n/248, 436 1/69, 72 Susan K. Linnebur n/249, 437 1/69, 72 Deanne Linnebur n/434 1/72 Jill Linnebur 11/435 1/72 Douglas R. Lippett n/250 1/69 Joan I. Lippett 11/251, 438 1/69, 72 Robert Lippett H/438, 439 1/72 DoLaras Lisco H/252 1/69 Robert E. Lisco 11/253 1/69 Don Lockwood 11/254 1/69 Karen Lockwood n/254 1/69 Beverly Lowell II/255 1/69 Robert L. Mall H/494 1/74 William M. Martin U7647 1/148 Gary P. May 11/440 1/72 Carl Mayer 11/495 1/74 Donald F. McClary n/609,611 1/124, 125 R.W. McClelland n/505 1/74 Victoria McCormack 11/256 1/69 H.D. McDonald 11/563 1/87 Marjorie M. McLellan 11/496 1/74 Andrew C. McMinimee n/513 1/80 Gary Meier II/257 1/69 Nancy L. Meier 11/258 1/69 Dr. John R. Meinhold II/613 1/127 Deborah K. Messer 11/256 1/69 Brwin Mettler n/259 1/69 Dawne Robin Myers n/260 1/69 Jeffrey L. Meyer n/261 1/69 Jeffery Halley Miller U/262 1/69 Leola Miller n/263, 617 1/69, 129 Dawne M. Miller JJ/441 1/72 Dusty Miller n/442 1/72 Robert J. Miller n/615 1/128 Bob Monde 11/234 1/69 Carl Ray Monde n/264 1/69 Theodore Montgomery 11/443, 616 1/72, 129 Beverly Shaw Mooney 11/265 1/69 Joyce E. Mooney 11/266 1/69 Tina Mooney 11/267 1/69 Daniel Mooney n/268 1/69 John J. Mooney n/269 1/69 Teresa Morey U/270 1/69 William Morey 11/271 1/69 Donna Morris JJ/272 1/69 L.R. Morris n/273 1/69 Comment Letters Index

Volume/Page No. Volume/Page No. Name of Comment of Response D. Mullins 11/274 1/69 Cynthia L. Myers U/275 1/69 R.Max Myers n/444 1/72 •Tf Nelson n/276 1/69 iPaul Nelson H/277 1/69 Cynthia Ness U/445 1/72 Kathy Jere Neu H/278 1/69 Dorothy P. Nickerson n/259 1/69 Ina Nordyke n/279 1/69 Bonnie Norris U/280 1/69 Vicki Northcutt 11/281 1/69 V. O'Brien U/284 1/69 Betsy O'Brien II/282 1/69 John O'Brien H/283 1/69 Joseph O'Brien 11/384 1/70 Margaret O'Brien 11/285 1/69 Ramona O'Brien 11/286 1/69 Claude D. Off 11/497 1/74 Nancy Overly 11/446 1/72 Betty Owens 11/287 1/69 Gwendolyn A. P(?) U/618 U129 Alan Paine 11/447 1/72 Constance Paine 11/447,617 1/72, 129 Arthur A. Paine 11/617 1/129 Colleen Pakuer n/288 1/69 Floyd Pakuer n/289, 448 1/69, 72 Colleen Pakuer II/448 1/72 Lisa Palm H/290 1/69 David A. Pampu II/619 1/129 George Pazell n/291 1/69 Michael Pearson 11/292 1/69 Donna Peterson 11/293 1/69 Lisa Phillips 11/294 1/69 Melody Pierce JJ/449 1/72 Shirley A. Pisel 11/295, 485 1/69, 74 Wilhelmina Plante U7296 1/69 Alice Porter U/297 1/69 Pamela L. Post U/450 1/72 James R. Posten, II n/298 1/69 Shannon Price n/299 1/69 Pam Price H/451 1/72 ^ylamae Price H/645 U147 Richard Price, Jr. n/620, 645 1/130, 147 Bonnie L. Rader n/621, 622 1/132 John T. Rafferty H/507 1/74 Fred Raleigh 11/300 1/69 (Linda K. Rankin 11/301 1/69 10

Comment Letters Index

Volume/Page No. Volume/Page No. 0 Name of Comment of Response HJoyce Rankin n/452 1/72 iCheryl Rector H/302 1/69 1 Made line Reed n/617 1/129 ||Larry Rehm n/303 1/69 IJFred Rehner n/618 1/129 llGlenn Reid n/453 1/72 Dennis Reynolds n/304 1/69 Jeff Reynolds n/305 1/69 Penny Reynolds 11/306 1/69 Shelly Reynolds U/305 1/69 Lorna J. Rhine 11/454 1/72 Shirley A. Robbins 11/307 1/69 George Robinson 11/308 1/69 Julie Robinson H/308 1/69 Tonya Rocheur U/455 1/72 Julie Ross 11/456 1/72 Kenneth Ross 11/456, 631 1/72, 143 Chris Roth n/309 1/69 Randy Roth n/310 1/69 LoisC. Roth 11/457 1/72 Roberta Roth 11/458, 459 1/72 Helen Rouse 11/617 1/129 Vera Roy 11/460 1/72 Elizabeth M. Sala n/311 1/69 John Sala 11/312 1/69 Bruce Scherer H7313 1/69 Ronald A. Schiffer n/461 1/72 Edwin A. Schoonover 11/314 1/69 Fairie Schoonover n/314 1/69 Evelyn Schroth U/315 1/69 Walter E. Schroth 11/315 U69 Jim Scott JJ/316 1/69 Tammy Scott n/617, 632 1/129, 144 GaryL. Sears n/508 1/74 Justin W. Seitz 11/317 1/69 Michael R. Seitz n/3i8 1/69 Nancy C. Seitz 11/319 1/69 Richard Seitz H/320 1/69 Jimmy Sell 11/208 1/69 Jim Sherrill II/462 1/72 Charles Shields 11/633 1/144 rfelane Shields 11/633 1/144 LisaG. Shultz JJ/321 1/69 Margaret Shy 11/322 1/69 Byron Simpson JJ/323, 617 U69 Barbara Smith 11/324 1/69 Scott B. Smith E/634 1/145 11

Comment Letters Index

Volume/Page No. Volume/Page No. H Name of Comment of Response HBernadette M. Sonefeld 11/234, 325 1/69 HLynne Sorber 11/326 1/69 Michael C. Song 11/327 1/69 Pedro Soto 11/328 1/69 Meredith Steinman 11/329 1/69 Evelyn Stewart 11/486 1/74 Kim Stockley 11/463 1/72 Wm. Stockley 11/464 1/72 Cody Stoumbaugh 11/330 1/69 Pamela Stoumbaugh 11/331 1/69 John L. Sweet 11/498 1/74 V.Ann Swinsdorf 11/234, 325 1/69 Lori A. Tagawa 11/637 1/146 Paul J. Thiele 11/499 1/74 Phyllis Thompson 11/332 1/69 Cindy Thresher 11/465 1/72 Marian Tinklenberg 11/500 1/74 Dolores Ann Tippett 11/333, 618, 643 1/69, 129, 146 Jack Tippett 11/334 1/69 David Turecek 11/335 1/69 Janelle Turecek 11/335 1/69 Sandra Turecek 11/336 U69 Fred Tute 11/337 1/69 Dolores T. Tuxhom 11/338 1/69 Everett Tuxhom 11/339 1/69 Keith Ulmer 11/340 1/69 Mary Ulmer 11/341, 645 ]/69, 147 Gordon Van Sickle 11/342 1/69 Nelva Van Sickle 11/343 1/69 Cheryl Vashus 11/466 1/72 Charles Vest 11/385, 467 1/71, 72 John W. Vest 11/386, 468 1/71,72 Mabel Vest 11/344, 469 1/69, 72 William F. Vest 11/345 1/69 S. Vogt 11/346 1/69 Bill Voth 11/347, 470 1/69, 72 Roland Wadsworth 11/646 1/147 Richard N. Walker 11/647 1/148 Brad Weisensee 11/348 1/69 Traci Weisensee 11/349 1/69 Sharon J. Whalen 11/471 1/72 Charlotte Wheeler 11/563 1/87 Debra White 11/350 1/69 Barbara White 11/648, 649 1/148 JonB. Whitehead 11/351 1/69 Harold A. Wilborn 11/473 1/72 Hayley J. Whitehead 11/472 1/72 12

Comment Letters Index

Volume/Page No. Volume/Page No. Name of Comment of Response Theresa Williams n/352 1/69 Helen K. Witherspoon H/474 1/72 Tara Witherspoon n/475 1/72 PaulJ. Wolf n/563 1/87 GregB. Wolfer n/353 1/69 Sharlene Wood n/354 1/69 Melvin J. Wood n/476 1/72 Cynthia Worley n/355 1/69 Dennis Worley H/356 1/69 Richard G. Wright n/208 1/69 Alberta Young n/357 1/69 Brad Young n/65i 1/148 Elaine M. Zeucher 11/358 1/69 Robert L. Zeucher n/359 1/69 Illegible Names- Type A Letters n/360 1/69 Illegible Names- Type B Letters n/477 1/72 TABBED PAGE

PUBLIC MEETINC TRANSCRIPT 13

1 LOWRY LANDFILL SUPERFUND SITE

2 SECOND EXPLANATION OF SIGNIFICANT DIFFERENCES

3 FOR THE RECORD OF DECISION 4

5 REPORTER'S TRANSCRIPT OF PUBLIC HEARING

6 April 2, 1997 7

8

9 PURSUANT TO NOTICE to all parties in interest, the

10 above-entitled matter came on for public hearing on

11 Wednesday, April 2, 1997, commencing at 7:00 p.m., at

12 Horizon Community Middle School, 3981 South Reservoir

13 Road, Aurora, Colorado, before Annette Graham,

14 Registered Professional Reporter and Notary Public

15 within and for the State of Colorado. 16 17

18 19

20 21

22

23

24

25

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1 APPEARANCES:

2 U.S. ENVIRONMENTAL PROTECTION AGENCY Marc E. Herman 3 Colorado Department of Public Health and Environment 4 Joe Vranka

5 Parsons Engineering Science Tim Shangraw 6 7

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

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1 PROCEEDINGS

2 MS. HAMMER: Good evening. I would like

3 to welcome you all here to the public meeting. We are

4 glad you could make it, and we are glad the snow did't

5 prevent a lot of you from making it. I am Diana

6 Hammer. I am with the EPA.

7 And the purpose of the meeting tonight is

8 to one discuss the Explanations of Significant

9 Differences to the Record of Decision and describe the

10 wetland construction and schedule. We are here to get

11 your input to the items and hear your reactions to the

12 BSD.

13 First of all, we'll begin with a little

14 background of the Lowry Landfill Site. It should give

15 you a good idea of what's gone on in the past. And

16 next we'll talk about the wetland construction and

17 schedule. And during this presentation, we will talk

18 about the rehabilitation of some wetlands at the Lowry

19 Landfill Site.

20 Then we will discuss the first Explanation

21 of Significant Differences. These are some minor

22 changes to the ROD or the Record of Decision.

23 Following that, we will have the second

24 Explanation of Significant Differences. And this is

25 the main focus of tonight's meeting. And we really

BLANDO REPORTING & VIDEO SERVICE, INC. 16

1 want to get your input.

2 Finally, we will have a question-and-answer

3 session. We'd like to explain, also, since we have a

4 lot of material to cover tonight, after each topic

5 we'll take a few clarifying questions, but we want to

6 make sure everyone has an opportunity to hear the

7 presentation. So if you have comments or more in depth

8 questions, we'd like you to hold those for the end. We

9 should have an hour and a quarter for the questions at

10 the end of the presentation.

11 A couple of announcements also. The

12 bathrooms are just out this door, and straight across

13 of hall is the women's. To the left a little bit, is

14 the men's.

15 Our first speaker will be Marc Herman.

16 He's the Remedial Project Manager for EPA. Joe Vranka

17 is from the Colorado Department of Public Health and

18 Environment. He will be our third speaker, I think.

19 And then Tim Shangraw with Parsons" Engineering.

20 Another housekeeping item that I didn't

21 mention. Just so everyone knows who is asking

22 questions, if you could please identify yourself when

23 you ask a question, that would help us out a lot.

24 Okay.

25 With that, I'll turn it over to Marc. He

BLANDO REPORTING & VIDEO SERVICE, INC. 17

1 will give us a little bit about the site background and

2 history.

3 MR. HERMAN: Thanks, Diana. I would like to

4 thank the Academy. It's a little humor.

5 We are here to talk about Lowry Landfill

6 Superfund Site, and I'm going to give you a little bit

7 of background and history and also describe the

8 remedial plan. And it's described in the Record of

9 Decision and CERCLA. This is the law that describes

10 how hazardous waste sites will be cleaned up. It's

11 also called Superfund.

12 This is a series of amendments that were

13 enacted by Congress in 1986. The National Contingency

14 Plan is the set of regulations that define my job and

15 then also how a Superfund site will be studied and

16 cleaned up, the process.

17 Just real quickly, I will tell you about

18 the Superfund process. There are basically six steps.

19 The first step is remedial investigation, and that

20 is when you study the site, the contamination problems

21 are identified, and then the proposed method for

22 cleaning up the site is described in a feasibility

23 study.

24 EPA issues a proposed plan which is a

25 proposed cleanup design. We take public comment and

BLANDO REPORTING & VIDEO SERVICE, INC. 18

1 then issue a Record of Decision, which is the decision

2 document that describes how a Superfund site will be

3 cleaned up. And then this is -- these are the two

4 stages we are at right now.

5 Remedial design is the engineering

6 specifications for the cleanup plans, and remedial

7 action is the bureaucratic way of saying clean up.

8 The site is located pretty close to here at

9 the intersection of Quincy Avenue and Gun Club Road.

10 And you can tell this is an old map because we felt it

11 was important to point out Stapleton.

12 This is a plan view of the site. And there

13 are several remedial measures or cleanup designs that

14 are already in place. The Surface Water Removal Action

15 is an underground collection system that funnels

16 groundwater to the existing barrier wall, underground

17 barrier wall. The water is pumped from the barrier

18 wall to the treatment plant that is on-site.

19 As I said, there are a number of slides

20 that give you an idea of what happened back in the

21 mid-1960s and the '70s. About 120 million gallons of

22 industrial liquid waste were disposed of on-site and

23 there's about 12 million cubic yards of municipal solid

24 waste that is also disposed on-site. We can go through

25 these sides pretty quickly.

BLANDO REPORTING & VIDEO SERVICE, INC. 19

1 There's about 70 unlined pits that were dug

2 on-site and liquid waste was poured into these pits in

3 a number of ways. This is one of them. Sometimes the

4 drums were just rolled right off the flatbed trucks

5 into the pits. The pits were filled with liquid waste,

6 as you can see in this picture.

7 The next step in the co-disposal process

8 was to move those municipal solid wastes or trash into

9 the pits. The theory was to absorb the liquid wastes.

10 And that's what's going on right here.

11 This is named or called Unnamed Creek.

12 It's no longer here. But this was a creek that flowed

13 through the site. And ground water seeped into the

14 banks and mixed with rainwater and snowmelt and then

15 flowed off-site.

16 That's what I used to look like before I

17 worked on the project. Okay.

18 In 1992 the City and County of Denver,

19 Waste Management of Colorado, and Chemical Waste

20 Management built that underground collection system

21 that I showed you in a few slides back. And this is

22 what Unnamed Creek looks like now. It's no longer a

23 creek. There's a cover over it and the surface water

24 is diverted around the site.

25 This is a cross-section view of the

BLANDO REPORTING & VIDEO SERVICE, INC. 20

1 underground collection system. This is the on-site

2 treatment plant. And, again, the on-site treatment

3 plant.

4 I want to go through the overall remedy

5 real quickly. One component of the remedy is to

6 continue operation of the existing on-site treatment

7 plant and continue to operate the underground barrier

8 wall. And those are located on this end of the site.

9 Hopefully, you can see it. Can everybody see okay?

10 Another component of the remedy is to

11 install underground barrier walls on the eastern and

12 western boundaries of the landfill mass. And they will

13 be located here. We're having a public meeting,

14 actually, in two weeks in this very same room where a

15 presentation will be given on the designs and the

16 planned construction for these underground barrier

17 walls.

18 In addition to the eastern and western

19 boundaries, there will be a southern underground

20 barrier wall as well. They will all be tied together.

21 Also discussed in two weeks will be the

22 collection of -- the ground-water collection system

23 located at the northern side of the landfill mass.

24 That will be right here. This will be an underground

25 trench about 300 feet, I think, long. It will be

BLANDO REPORTING & VIDEO SERVICE, INC. 21

1 filled with granular material.

2 Ground water flowing underneath the

3 landfill mass here flows in this direction because

4 there's a natural drainage. And it will be collected

5 at this collection system here, will be piped to the

6 treatment plant. That will be constructed this fall.

7 Currently in place is a network of landfill

8 gas collection wells and an enclosed flare. Those were

9 built last fall.

10 Now, this slide shows a perimeter of

11 collection wells, but there are actually a complete

12 network of collection wells throughout the landfill

13 mass as well. The enclosed flare is located up here at

14 the treatment plant. And it's a tall -- 40-feet tall

15 stack that burns the landfill gas that's collected.

16 This is a photo of one of the collection

17 wells. And this is a picture of the enclosed flare.

18 The blowers are located over here to draw the landfill

19 gas through pipes to the flare.

20 Also as part of the remedy, City and County

21 of Denver, Waste Management and Chemical Waste

22 Management are going to place an additional 2 feet of

23 cover on the north face of the landfill mass. There's

24 about an average of 4 feet on the rest of the landfill

25 mass right now --4 feet of soil cover.

BLANDO REPORTING & VIDEO SERVICE, INC. 22

1 And the north face slope is right here. So

2 2 feet will be in addition to the 2 feet that are

3 currently on there.

4 This component of the remedy calls for

5 excavation, treatment, and disposal of buried drums,

6 contaminated soil and other waste pit material. This

7 will also be the subject of the presentation tonight.

8 Excavation is still proposed, but the Explanation of

9 Significant Differences is proposing to treat and

10 dispose of the waste on-site. The waste pits are

11 located in this area here.

12 Finally, in addition to all those other

13 components, there will be institutional controls, land

14 use restrictions. There will be some wetlands

15 mitigation that will be done to the northeast of the

16 site offsite in an uncontaminated area.

17 These wetlands were destroyed when the

18 on-site -- the collection system in Unnamed Creek was

19 built.

20 And, finally, in addition to ground water

21 and gas and air monitoring, there will also be surface

22 water and soil monitoring.

23 That's it for me.

24 MS. HAMMER: Our next speaker is Tim

25 Shangraw with Parsons Engineering Science. He's going

BLANDO REPORTING & VIDEO SERVICE, INC. 23

1 to talk about the wetlands construction schedule.

2 Tim.

3 MR. SHANGRAW: I think since the last time,

4 most of the people in the room have talked about the

5 wetlands remediation. We talked about it last year at

6 this time and indicated that construction of the

7 wetlands mitigation plan would begin in the spring of

8 1997. Well, here we are. We are in the spring of

9 1997, and we are ready to go, weather permitting. We

10 have equipment sitting out on the site and we are ready

11 to start digging.

12 As you can see in the slide, the site is

13 located to the northeast of the command post. There's

14 the command post right here. There's actually three

15 components: this large component here, small

16 component -- those are basically the wetlands

17 mitigation area itself. Those will be new wetlands.

18 The larger area to the west of that site is

19 what's called the disposal unit, the on-site spoils

20 area where we're going to be removing roughly 2 to 3

21 feet of soil from the lowland area and drainage channel

22 to lower the elevation of the drainage channel down to

23 within 6 inches of the lowest ground water level. That

24 is typically monitored during August. So that's the

25 driving criteria for how much soil is excavated.

BLANDO REPORTING & VIDEO SERVICE, INC. 24

1 The objective is to maintain a shallow, if

2 you will, contact zone between the roots between the

3 plants and the water table so that under natural

4 conditions the riparian habitat can proliferate.

5 Where we are today is we are ready to start

6 digging, as I indicated. And the next slide is really

7 a blowup of just that, the mitigation area. Let me

8 just quickly show you -- the stream channel follows the

9 line here. This yellow area, if you will, is the

10 existing wetlands. And our objective is to expand this

11 -- the width, the band of -- the small yellow band

12 to -- all the way out to here.

13 The red area here is the large wetland area

14 that we indicated in the prior slide. This area here

15 is a smaller area of wetland. We'll be expanding the

16 habitat, basically would be adding another acre of

17 wetland area.

18 We have a couple other things on the

19 slide. .This purple line here is basically the top of

20 the beginning of the excavation.

21 We have two objectives that we will strive

22 to achieve. One is to excavate, as I indicated, the

23 lowland area with the drainage channel, the other is to

24 actually excavate a 3-to-l side slope to be able to

25 maintain existing slopes so that they won't erode, if

BLANDO REPORTING & VIDEO SERVICE, INC. 25

1 you will. And those will be called the upland area.

2 That's the transition zone between the wetlands and the

3 existing upland area. So the beginning of that starts

4 here and ends right about here.

5 What we'll be doing is bringing in some

6 scrapers, and we'll be stockpiling the soil in this

7 area. We have about 20,000 cubic yards of soil that

8 will be removed. And that will happen, knock on wood,

9 this week or maybe next week, depending on how the

10 weather cooperates.

11 We then have three sequences of seeding

12 that follow that. The first is associated with the

13 upland area or the 3-to-l cut area in through here.

14 That will happen right away. And that seed mixture

15 basically will be upland seed or basically pasture type

16 seed mixes. The second will be planting willow sprigs.

17 One of the objectives of the wetlands

18 remediation is to develop a habitat that consists of

19 willows,, cattails and -- primarily cattails and some

20 bull rush. We've collected 2,000 willow sprigs so far

21 from a neighboring habitat, basically from neighboring

22 willow stands.

23 And then we'll -- right after the

24 excavation, we will be planting those 2,000 sprigs, and

25 they will just -- they will grow. So that's, really,

BLANDO REPORTING & VIDEO SERVICE, INC. 26

1 the second part of the planting.

2 And then right now, the water level --

3 because the water levels fluctuate -- are about 12

4 inches, roughly a foot, above the low-level water

5 depth -- that designed depth that we looked for in

6 August. So if you add numbers, we are basically going

7 to be excavating down to about 6 inches below the

8 current water level. So we are going to end up with a

9 pretty muddy condition. And that's really by design.

10 Our objective, then, is to wait until the

11 water level drops until -- basically a couple inches

12 below the final grade elevation, and then we will go

13 out and plant the wetland seed mix, basically the

14 cattail and the bull rush. That will probably happen

15 in June time frame. We'll have to monitor the water

16 levels just to make sure that those water levels drop.

17 And then when that's done, we will monitor

18 the wetland mitigation area. Our objective, again, is

19 to use Mother Nature as best as we can so that the

20 seeding -- the growth occurs naturally.

21 And then after the planting is done,

22 throughout the summer months and for the next --

23 really, for the next five years, we have a

24 monitoring program. We will have transects. We have

25 five transects that we will be monitoring to insure the

BLANDO REPORTING & VIDEO SERVICE, INC. 27

1 final wetland area grows and develops as designed.

2 There's at one transect that's associated with the

3 smaller area, two associated with the larger area, and

4 then two additional transects that are associated with

5 the existing wetlands. One in this area and one down

6 in through here. That is to make sure those existing

7 wetlands aren't compromised.

8 By transects, what I mean is basically we

9 will monitor the density of the revegetation as well as

10 the species of revegetation to make sure that they are

11 consistent with the design plan. So that's where we

12 are with the wetlands.

13 Can I answer any questions?

14 Thank you.

15 MS. HAMMER: Our next speaker is Joe Vranka

16 with the. Colorado Department of Public Health and

17 Environment. He's going to first discuss the first

18 Explanation of Significant Differences and then the

19 Second Explanation of Significant Differences, which is

20 the main focus of tonight's meeting.

21 Joe.

22 MR. VRANKA: Well, as mentioned, these are

23 the reasons we are here. The reason we are here is to

24 talk about the second proposed Explanation of

25 Significant Differences to the Record of Decision. The

BLANDO REPORTING & VIDEO SERVICE, INC. 28

1 first Explanation of Significant Differences was issued

2 in August of 1995. The Record of Decision was issued

3 March of 1994.

4 The first Explanation of Significant

5 Differences was issued to correct several regulatory

6 standards that were reported incorrectly, and it was to

7 replace some risk-based standards with regulatory

8 standards, and it was also to -make allowances for

9 naturally occurring concentrations in background and

10 also for practical quantitation limits; practical

11 quantitation limits being the levels at which you can

12 reasonably and accurately measure concentrations of

13 contaminants.

14 The proposed Second Explanation of

15 Significant Differences to the Lowry Landfill Record of

16 Decision is based upon new information received since

17 the issuance of the Record of Decision, since March of

18 1994. The two proposed changes to the Record of

19 Decision are on-site treatment and disposal of buried

20 waste excavated from the former tire pile area. I

21 think Marc pointed these areas out earlier. They are

22 the areas along Unnamed Creek where there were waste

23 pits that did not subsequently have 80 to 100 feet of

24 municipal solid waste piled on top of it and it was,

25 therefore, accessible.

BLANDO REPORTING & VIDEO SERVICE, INC. 29

1 The second proposed change is off-site

2 treatment of ground water from the site using Publicly

3 Owned Treatment Works. Publicly Owned Treatment Works

4 is basically a wastewater or sewage treatment plant.

5 We'11 begin with discussing the treatment

6 and disposal of buried waste. We will begin by

7 describing the scope of the problem. We'll detail some

8 of the record for the requirements of the Record of

9 decision. We will detail -- I will detail some of the

10 new information we received that precipitated these

11 proposed changes, and then I will describethe proposed

12 alternatives for treatment and disposal of the buried

13 waste and identify the preferred alternative.

14 The remedial investigation identified 10 to

15 12,000 cubic yards of buried drums and contaminated

16 soil in this former tire pile area. If you look at the

17 map you can see the area along Unnamed Creek. I think

18 they are highlighted. You can take a look at it later

19 and see where those are located.

20 The Record of Decision required the

21 excavation and disposal of buried drums and debris and

22 contaminated soil in this area for off-site treatment

23 and disposal. The contaminated soil and other wastes

24 would require treatment characteristics of toxicity and

25 ignitibility to render it nonhazardous.

BLANDO REPORTING & VIDEO SERVICE, INC. 30

1 The new information that came -- that has

2 become alleged since the issuance of the Record of

3 Decision has come from treatability tests performed

4 last summer which show that the contaminated material

5 can be treated on-site.

6 After treatment, the resulting nonhazardous

7 soil and debris can be disposed on-site. The proposed

8 alternatives for treatment and disposal --the ones

9 that were evaluated are Alternative 1, which is the

10 off-site treatment and disposal at a licensed hazardous

11 waste facility of these contaminated soil and debris.

12 Treatment would likely be stabilization or fixation

13 technology.

14 And Alternative 2, which is on-site

15 treatment in the controlled area, basically air drying

16 and on-site disposal. Treatment would be air drying of

17 covered stockpiles using a series of pipes to draw air

18 through the piles and then treat the air.

19 The advantage of Alternative 1, the

20 off-site treatment and disposal option, is that the

21 waste would be managed in a licensed hazardous waste

22 facility. The disadvantage of Alternative 1 is that

23 hazardous waste would be transported off-site along

24 public roads.

25 The advantage of Alternative 2, on-site

BLANDO REPORTING & VIDEO SERVICE, INC. 31

1 treatment and disposal, is that hazardous waste would

2 remain on-site for treatment, thereby reducing the

3 potential for transportation accidents. The

4 disadvantage of Alternative 2 is the treatment of this

5 soil -- contaminated soil and debris may take several

6 months to complete.

7 These proposed alternatives were evaluated

8 using criteria from the National Oil and Hazardous

9 Substances Pollution Contingency Plan, the NCP. These

10 are the criteria by which all Superfund remedies are

11 evaluated. These criteria include overall protection

12 of human health and the environment; compliamce

13 with applicable program requirements, laws,

14 regulations; long-term effectiveness and permanence;

15 reduction of toxicity, mobility, and volume; short-term

16 effectiveness; implementability; cost; state

17 acceptance; and community acceptance.

18 The following evaluation is based upon a

19 scale 1 to 5, 5 representing the highest score. As you

20 can see, both of the alternatives, both off-site and

21 on-site, have an equal level of meeting the overall

22 protection of human health and the environment,

23 compliance with laws and regulations, and long-term

24 effectiveness and permanence.

25 The score for the reduction of toxicity,

BLANDO REPORTING & VIDEO SERVICE, INC. 32

1 mobility, and volume through treatment for the off-site

2 alternative is slightly lower due to the increased

3 volume for additives for stabilization. Generally they

4 add fly ash or some type of additive to stabilize this

5 material and thereby increasing the volume. So you get

6 a greater volume which ultimately needs disposal.

7 The off-site and on-site alternatives are

8 relatively equivalent in short-term effectiveness.

9 Basically short-term effectiveness includes time to

10 implement as well as short-term impacts to the

11 surrounding area. The disadvantages of off-site

12 transportation of waste versus the additional time to

13 complete treatment on-site kind of balance each other

14 out. And then they are relatively equal in terms of

15 ease of implementation.

16 " The on-site alternative costs less --

17 involves less cost. And state and community acceptance

18 will be evaluated through public comment and through

19 this public comment period.

20 Based on the evaluation of the new

21 information, the preferred alternative at this time is

22 on-site treatment using controlled air drying followed

23 by on-site disposal.

24 Next, we'll move into the other proposed

25 change to the Record of Decision which involves ground

BLANDO REPORTING & VIDEO SERVICE, INC. 33

1 water treatment. Once again, I'll begin by describing

2 the scope of the problem, identifying the requirements

3 in the Record of Decision, present the new

4 information, describe the proposed alternatives, and

5 present the preferred alternative to the ground water

6 treatment.

7 The scope of the problem is the ground

8 water beneath the site is contaminated with organic and

9 inorganic compounds. The Record of Decision required

10 treatment of contaminated ground water either by

11 constructing a new treatment plant or by upgrading the

12 existing plant, which if it was shown that it could be

13 upgraded to meet the performance standards, then that

14 route would be the way to go.

15 The new information that's been obtained

16 since the issuance of the Record of Decision is that a

17 sanitary sewer system, an interceptor has been

18 constructed about a half mile west of the site due to

19 the new .construction in the area, which I'm sure you

20 are all aware of.

21 Previously, we had evaluated the POTW

22 option in the feasibility study for the shallow and

23 deep ground water aquifer. We had looked at this quite

24 a few years ago. At that time, the nearest interceptor

25 was a few miles away, and it was simply not economical

BLANDO REPORTING & VIDEO SERVICE, INC. 34

1 and not practical to build a sewer line that long to

2 handle the waste.

3 The City of Aurora has also indicated that

4 it will allow connection of the discharge line from the

5 site to the sewer line. The City of Aurora has also

6 indicated that they will allow pretreated site water to

7 be conveyed through the sewer line to Metro Wastewater

8 Reclamation District, Metro. Metro is a POTW,

9 Publicly Owned Treatment Works, or wastewater

10 treatment plant. Metro has indicated that it will

11 accept site water for final treatment provided that the

12 water has been pretreated to meet certain standards.

13 Alternative 1, the first of the two

14 alternatives -- the first of the alternatives we looked

15 at for treatment -- includes on-site pretreatment for

16 organic contaminants, likely using the current systems

17 that are in place, followed by offsite treatment of

18 inorganic contaminants and remaining organic

19 contaminants at the POTW.

20 Since water is removed from the shallow

21 ground water system along the creek -- the shallow

22 system along the creek, it will have to be replaced or

23 augmented or we get into surface water rights. And the

24 water that we remove and send to Metro will have to be

25 augmented with clean water from another source. This

BLANDO REPORTING & VIDEO SERVICE, INC. 35

1 amounts to about 10 to 20 gallons per day, which is to

2 a maximum of about 28,000 -- 10 to 20 gallons per

3 minute, which is up to a maximum of about 28,000

4 gallons per day.

5 Modified Alternative B, so-called because

6 we looked at a couple of different variations of this

7 alternative, it includes on-site treatment of organic

8 contaminants, on-site treatment of inorganics, likely

9 using something such as a two-stage reverse osmosis,

10 followed by evaporation and recovery of the evaporated

11 water.

12 It also includes off-site disposal of

13 evaporator sludges and discharge of the recovered water

14 to the wetlands to provide an additional water source

15 there. And that would also require some ground water

16 augmentation. It would be less, but it's likely that

17 we would lose some water in the process.

18 The advantages of Alternative 1, the POTW

19 option, .are the relative ease of implementation. The

20 sewer line is already in, the plant is already up, the

21 POTW is already operating, and the reliability of the

22 treatment system in the POTW. The disadvantage of

23 Alternative 1 is that there would be -- there would be

24 water necessary -- or an equivalent amount of water

25 necessary to augment the shallow ground water system

BLANDO REPORTING & VIDEO SERVICE, INC. 36

1 along the creek.

2 The advantage of Alternative 2, the

3 off-site -- the complete on-site treatment is that less

4 ground -- I mean the biggest advantage is that less

5 ground water augmentation is necessary. The

6 disadvantages of Alternative 2 are that it's a much

7 more complex system and has the potential to be

8 somewhat less reliable.

9 One of the other disadvantages is that

10 evaporated sludges are likely to be hazardous and

11 require off-site treatment and disposal.

12 Once again, the alternatives were evaluated

13 using the nine criteria from the NCP. Both

14 alternatives would achieve effectiveness and compliance

15 with laws and regulations. The POTW option rates

16 slightly higher in terms of long-term effectiveness

17 because of the reliability --or the relative

18 reliability of the wastewater treatment plant.

19 . The on-site treatment option is rated

20 slightly lower -- the on-site treatment system is rated

21 slightly lower for the reduction of toxicity, mobility,

22 and volume because of the evaporater sludges that are

23 generated that are likely to be hazardous and likely to

24 require off-site disposal.

25 Both alternatives rated roughly the same

BLANDO REPORTING & VIDEO SERVICE, INC. 37

1 for short-term effectiveness and permanence and both

2 would have relatively the same time frame to implement.

3 It may be take a little while to get some of the

4 systems for on-site treatment in place.

5 The POTW option is considered to be more

6 easily implementable because of the system on-site

7 because the sewer line is close and it's a fairly well

8 used or often used system.

9 The POTW option is less costly than the

10 on-site treatment option. The State of Colorado,

11 CDPHE, The Colorado Department of Public Heath and

12 Environment has indicated a preference for Alternative

13 1, POTW option. Community acceptance will be evaluated

14 with public comments based on public comments during

15 this public comment period.

16 And based upon the evaluation of the new

17 information Alternative 1, POTW option, is the

18 preferred alternative, including on-site pretreatment

19 for organic contaminants followed by further treatment

20 at the POTW.

21 Metro's pretreatment requirements are that

22 -- these are the levels that the site water will have

23 to be pretreated to before it can be discharged to the

24 sewer system -- are special levels which protect worker

25 health and safety, are compatible with their treatment

BLANDO REPORTING & VIDEO SERVICE, INC. . . 38

1 processes and won't interfere with their or upset their

2 treatment processes, will be treatable in Metro's plant

3 to meet the water quality standard to protect the water

4 quality in the South Platte River and will allow the

5 continued production of -- or to maintain their

6 exceptional quality sludge.

7 This is a pie chart that indicates what the

8 discharge from the Lowry landfill at 20 gallons per day

9 would represent -- what type of percentage of the total

10 volume of water that Metro treats at its plant. It

11 treats 150 million gallons per day. The Lowry

12 discharge is roughly 28,000 gallons per day. That's

13 got MGD on it. I think that's .028.

14 This slide gives you an indication of

15 Metro's biosolids, euphemism for sludge quality. And

16 what we have on there -- if you can't see it, is the

17 yellow represents the current concentrations of these

18 select four inorganic contaminants or inorganic

19 compounds in Metro's sludge.

20 The red represents what Lowry's

21 contribution would be were Lowry site water to be sent

22 to the Metro plant. The blue represents the combined

23 discharge from what Metro currently has in their sludge

24 today and Lowry's contribution. And the green

25 represents the levels of these particular contaminants

BLANDO REPORTING & VIDEO SERVICE, INC. 39

1 below which it's considered to be exceptional quality

2 sludge.

3 This is kind of a comparison of Lowry --

4 the slide represents the Lowry discharge in comparison

5 to some typical dischargers that discharge to Metro.

6 Same four metals. Lowry is represented by the yellow

7 bar. The typical electroplater is represented by the

8 red, typical dye manufacturer by blue, -and the green --

9 the green represents Metro's influent standards.

10 These would be the pre -- these would be standards

11 above which Metro would not -- could not or would not

12 accept the waste, the green bar.

13 This slide represents some compounds, and

14 this -- it shows what Metro's current discharge

15 concentrations to the South Platte River are in the

16 first column. The second column represents what the

17 contribution from Lowry Landfill Site waters would be

18 when considering the entire volume of Metro's

19 discharge, the entire 150 million gallons per day.

20 And then the last column shows what the

21 combination would be. And what we are trying to

22 demonstrate here --or what we are trying to show here

23 is that there would be -- there would be an

24 immeasurable change in Metro's discharge due to adding

25 the Lowry site water to it.

BLANDO REPORTING & VIDEO SERVICE, INC. 40

1 Same slide here with some other

2 contaminants, including chloride, sulfates, 1-1

3 dichloroethylene and vinyl chloride.

4 That will turn it back to Diana for

5 questions.

6 MS. HAMMER: Well, we have a little over

7 an hour for our question-and-answer period. I'd like

8 to remind you if you have any questions to please

9 identify yourself so we can know who we are responding

10 to. And with that, I'd like to open it up for

11 questions. It can be on any aspect of the

12 presentation.

13 The back, there's a question.

14 MR. HOLMSTROM: My name is Don Holmstrom,

15 and I'm the president of the Oil, Chemical and Atomic

16 Workers Denver local and also the district counsel

17 which is Montana to New Mexico. And we represent the

18 lab workers at the Metro wastewater facility as well

19 as, in the Rocky Mountain area, about 5,000 workers

20 that work in oil refineries, nuclear plants, chemical

21 facilities, et cetera.

22 Myself, I have worked the last 16 years as

23 a chief operator at the Total Oil Refinery and have

24 dealt extensively with hazardous waste and received

25 40-hour OSHA training on hazardous waste disposal,

BLANDO REPORTING & VIDEO SERVICE, INC. 41

1 et cetera. My understanding, talking to Marc Herman

2 before the meeting, is that we'd make a comment as well

3 as ask a question, so I would like to make a couple of

4 comments, if that's appropriate.

5 Our concern over this particular proposal

6 to pipe the waste through sanitary sewer to the Metro

7 wastewater facility is a reflection of our ongoing

8 problems with the Metro wastewater .facility over the

9 last several years, particularly the years of which

10 Robert Kite has been the manager of the facility.

11 There's been a long history of environmental

12 degradation there that we can document, and there's

13 been a disregard for worker health and safety.

14 I have a few particular points I want to

15 make. I don't want to make a long presentation but

16 just to express kind of examples of what our concerns

17 are.

18 We sent a letter to Marc Herman expressing

19 our concern over the fact that the wastes were being

20 sent. We were unaware of it, and we contacted the EPA.

21 In fact, a hearing hadn't even been scheduled or

22 contemplated. And our feeling was that this was going

23 to be a done deal and no one would have any say into

24 the process. I certainly hope you will listen to our

25 comments tonight.

BLANDO REPORTING & VIDEO SERVICE, INC. 42

1 Specifically, we have asked Metro district

2 for the study that -- which they are basing the

3 assertion that Metro would be protective of worker

4 health and safety in the disposal of this waste. When

5 Marc first responded to my letter of concern, he said

6 that Metro was evaluating the discharge and gave him

7 assurances that that discharge would be protective of

8 worker health and safety.

9 That was news to us. We were unaware of

10 any study. We sent a letter, an information request to

11 Metro wastewater. They responded that they had done no

12 study and there was no study to give to us. And even

13 tonight, Mr. Vranka with the State refers to that Metro

14 was -- would be protective of worker health and

15 safety.

16 I ask you -- somebody is not telling

17 the truth. If there is such a study that indicates

18 that that waste would be protective of worker health

19 and safety, let's see it. If there isn't, be honest

20 about it. Both of the those can't be true. I have

21 the documentation with me of the correspondence. And

22 if anybody is interested, they are welcome to look at

23 it.

24 Second point, in both the letter of Robert

25 Kite and Marc Herman, the assertion was made that they

BLANDO REPORTING & VIDEO SERVICE, INC. 43

1 were evaluating the waste discharge but it had not been

2 completely evaluated. In other words, you don't know

3 completely what's in this discharge.

4 And I ask you, how can you responsibly

5 assert to us that worker health and safety is going to

6 be protected when you don't even know what's in the

7 stuff that you are going to be putting through the

8 sanitary sewer?

9 I would assert to you that your credibility

10 is in question when you make those kinds of assertions

11 and yet admit you haven't done a complete

12 characterization of the discharge.

13 The relationship between the workers at

14 Metro and the represented workers and the company, the

15 district, is at a low. It took us two years just to

16 get health --a health and safety protection of safety

17 shoes from the district which they supplied to other

18 workers.

19 . And I would submit that we need to see the

20 studies, if any, that indicate that worker health and

21 safety will be protected. We need to see a complete

22 evaluation of this discharge.

23 If the examples of Metro's relationship to

24 the workers are any example of how the community is

25 going to be treated, I would submit to you that this

BLANDO REPORTING & VIDEO SERVICE, INC. 44

1 proposed plan for piping the wastewater is an

2 endangerment not only to the workers but to the

3 community as a whole.

4 It's the experience that we've had that

5 Metro has declared war on its own workers. We have

6 some workers here tonight that will testify. And we

7 would submit that this proposal is declaring war on the

8 community. The fact that Metro is going to be

9 disposing of these wastes, people think, well, you

10 know, what happens at a wastewater facility?

11 Well, let me explain a dirty little secret

12 to you. When we produce at our oil refinery a barrel

13 of either contaminants water or sludge, our company

14 pays about $500 or maybe more to take it out to Last

15 Chance hazardous waste facility. When that same barrel

16 goes into Metro, where it's going to be disposed of

17 at Metro, they can take that same barrel and go and

18 place it across the farmlands in Deer Trail and that

19 is not deemed to be contaminated waste or hazardous

20 wastes.

21 And the problem is, is there is a great

22 loophole here that would allow Metro to dispose of

23 these wastes both in Deer Trail and out the South

24 Platte, that it would be a great exposure to the

25 communities involved.

BLANDO REPORTING & VIDEO SERVICE, INC. 45

1 Finally, our workers at the Metro site are

2 not covered by OSHA. What does that mean? That means

3 there is no enforceable standards of worker health and

4 safety protection, no enforceable standards of what

5 workers can be exposed to, no medical surveillance

6 that's enforceable, no personal protective equipment

7 and evaluation of exposure and what personal protection

8 equipment that you could wear and be enforceable, no

9 enforceable standards of worker training. And this is

10 a big deal. And I know because I work at a site where

11 there is hazardous waste.

12 MS. HAMMER: Okay. Thank you very much for

13 your comment. Joe or Marc, would you like to respond

14 or do you have any comments to make?

15 Well, thank you very much for your comment.

16 We have taken note of your concerns. And that's why we

17 are here tonight, is to get public comment. It's not a

18 done deal. And we have a public comment period that

19 goes through May 22. And we're here tonight to get

20 your comments and to pay attention.

21 Does anyone else have a comment or a

22 question?

23 MR. GODDARD: I just have some comments

24 that I would like --

25 MS. HAMMER: Can you please stand up and

BLANDO REPORTING & VIDEO SERVICE, INC. 46

1 speak up so everyone can hear you.

2 MR. GODDARD: You bet.

3 My name is Phil Goddard, and I'm the

4 elected health and safety representative for Metro

5 Wastewater Reclamation District's Laboratory

6 Department. We in the lab will be some of the first

7 people to come into contact with these toxic substances

8 from Lowry as they are treated at Metro. Therefore, we

9 have some health and safety concerns regarding this

10 cleanup project.

11 Many of our concerns stem from the fact

12 that Metro district need not and does not comply with

13 OSHA standards, just like Don was explaining to you

14 guys. Because the district refuses to fully comply

15 with OSHA, this creates some risky situations for those

16 of us employed in the lab.

17 OSHA promulgates personal exposure limits

18 for most chemicals and requires that they not be

19 exceeded. Metro does not currently have an adequate

20 method for testing exposure limits for toxic chemicals

21 or radiation exposure to laboratory workers. We won't

22 know what we are being exposed to and we won't know if

23 the levels of exposure are hazardous to our health.

24 Another concern with analyzing the Lowry

25 sample is that we will be mixing them with other

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1 chemicals, distilling them, reducing them, and unknown

2 reactions could occur during these processes. We'd

3 like to guarantee that our health and safety will not

4 be jeopardized by the district's treatment of this

5 hazardous waste.

6 MS. HAMMER: Thank you very much for your

7 comment.

8 Are there any other questions or

9 comments?

10 MS. ANDERSON: My name is Adrienne

11 Anderson. I'm a board member of the Metro Wastewater

12 Reclamation District appointed by Mayor Webb of Denver,

13 which owns the landfill, and I also teach

14 environmental ethics at the University of Colorado at

15 Boulder.

16 MS. HAMMER: Can everyone hear? Please

17 speak up.

18 MS. ANDERSON: Did you not provide a mic

19 for the.public to be heard?

20 MS. HAMMER: You can come up here. And you

21 are more than welcome to come up here and use this mic.

22

23 MS. ANDERSON: I have a number of questions

24 and concerns. The first thing is the determination of

25 the background levels for the Lowry landfill being used

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1 to make a determination as to the safety levels of the

2 landfill itself.

3 One major concern is that the background

4 levels that have been -- where the samples have been

5 taken we now know to be on a site which is the Buckley

6 bombing range which now itself is under investigation

7 as a formerly used defense site. Under Superfund laws,

8 that site is being investigated for a variety of

9 hazards.

10 We have no idea yet of the ground water

11 contaminants at that site that is moving toward the

12 Lowry Landfill. So it isn't comforting to say, well,

13 the background levels are within safe limits,

14 et cetera because there are clearly sources of

15 contaminants on the Buckley bombing range that may well

16 have migrated to the those areas where the backgrounds

17 have been taken.

18 When I expressed concern to the City of

19 Denver about this, they seemed to be unaware of that

20 fact. So I'm wondering whether another potential

21 Superfund site is being used as background level. And

22 so that, to me, skews the whole evaluation of the

23 levels at the Lowry Landfill itself. So that's one

24 question, the background levels.

25 And also the concern we've mentioned

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1 tonight, some of the levels that have been investigated

2 and evaluated for arsenic, copper, lead, and nickel,

3 and yet there's been no discussion whatsoever of the

4 fact that EPA's own contractors have found -- and I'm

5 quoting -- "Radionuclides were detected in the ground

6 water, subsurface and surface soil, surface water, et

7 cetera. Naturally occurring radionuclides detected at

8 the Lowry site include uranium, thorium, potassium and

9 radionuclides associated with decay of uranium and

10 thorium. Manmade radionuclides detected in

11 environmental media included plutonium, americium,

12 tritium, strontium, cerium and cesium."

13 Now, this study says that in 100 percent of

14 the ground water samples that were taken, there's

15 plutonium in this landfill. And this is going to be

16 piped into a sanitary sewer system and then to the

17 Metro workers where they will be exposed to this

18 contaminated ground water and then trucked out to

19 Deer Trail where it's going to be applied onto

20 farmland. That has not been discussed tonight.

21 Also, the fact that there's radioactive

22 levels found in the background samples to the Lowry

23 Landfill doesn't take into account that a retired

24 highway patrolman for the State of Colorado alleged in

25 written documents to the health department that Rocky

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1 Flats was dumping radioactive waste precisely along the

2 same areas of Quincy Road and Gun Club Road where

3 background levels have detected radioactive

4 constituents as well.

5 So the question is, are we comparing apples

6 to oranges and what is it that is putting those

7 radioactive levels in place?

8 There has been radioactivity found in

9 the -- at least one of the missile silos on the

10 complex at the Buckley bombing range, again, which is

11 upgradiant of the Lowry Landfill. Are we saying --we

12 will not know for years until the Army Corps of

13 Engineers does its investigation into the ground water

14 whether or not we are looking at a phenomenon that has

15 mixed liability here. That's an area of concern. Why

16 are we covering up the plutonium being in the Lowry

17 Landfill?

18 This report, by the way, was done by

19 CH2M HILL, Metro uses CH2M HILL as a contractor to

20 Metro. So, clearly, that contractor is considered to

21 be a reliable contractor. That's one other question.

22 Another area has to do with construction of

23 the pipeline itself. If we are going to build an

24 underground pipeline that would go west from the

25 landfill where we know there is contaminated ground

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1 water plume already, are we then going to invite the

2 possible transmission of that contaminated ground water

3 plume through the pipeline channel itself to

4 contaminate areas that are not presently contaminated

5 with ground water?

6 Of course, that ground water is common to

7 the water supply of the East Cherry Creek Valley Water

8 and Sanitation District, 100 percent which is supplied

9 by well, with some other sources, with ground water

10 supplying hundreds of thousands -- maybe I'm not

11 right -- tens of thousands of homes in that area. Is

12 that a source of concern? Could that be a potential

13 channel of the contaminated ground water to

14 uncontaminated areas so far?

15 I was appointed by the mayor of Denver to

16 the Metro Wastewater Reclamation District specifically

17 to represent the worker safety and health concerns,

18 which, as you have heard, have been underrepresented to

19 the board of directors.

20 I was shocked to find that the workers had

21 not been notified by the management of this proposal,

22 and I think that is a source of concern when it comes

23 to looking at whether or not there have been studies

24 done of the worker health and safety. My investigation

25 is that there has not.

BLANDO REPORTING & VIDEO SERVICE, INC. 52

1 It's also concern when we look at what is

2 the cheapest possible remedy here. And that clearly is

3 a priority. Have we collected from the polluters at

4 this site an adequate fund to do an adequate

5 treatment? Is it a cost consideration that we do not

6 have enough money in the fund to build an upgraded

7 treatment plant so we are going to dump it into the

8 sewer system where there is clearly a regulatory

9 loophole?

10 That waste, if it were trucked on ground to

11 the Metro plant --it would be considered as a Resource

12 Conservation and Recovery Act hazardous waste, which

13 has much stricter regulations for that waste. At

14 Metro, the EPA itself has indicated that if it were

15 stored at Metro it would come under much more stringent

16 requirements under RCRA. If you dump it into the sewer

17 system under those sets of final and preregulations, it

18 all of a sudden becomes not a hazardous waste. And is

19 that really what we want?

20 I have notified the Metro board of my

21 opposition to this. I was not on the board when this

22 proposal was brought to the board and approved. I

23 strongly feel this is the wrong way. Wearing my hat as

24 a -- with fiduciary concern for the Metro board, I

25 think this proposal is inviting potential future

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1 liability in terms of the risks to the farmland out

2 there, transportation issues.

3 I think that whenever we have plutonium

4 with a half life of 24,000 years, that we need to keep

5 that material exactly where it is and remove those

6 contaminants from the source.

7 Also, Metro has no capability of removing

8 toxic metals. The toxic metals will end out: in the

9 sludge in Deer Trail if there is no inorganic removal

10 process at that plant.

11 As a board member, I am advocating that we

12 invest in those technologies at Metro. It's much more

13 capital cost intensive up front but could have a

14 potential long range effect to reduce our potential

15 environmental liabilities as we have gotten into in the

16 past.

17 So I would like to urge that this proposal

18 to change the Record of Decision at Lowry Landfill be

19 roundly rejected and that the monies be collected from

20 the responsible parties to build a proper on-site

21 treatment, to remove the inorganics and, if necessary,

22 to remove the radionuclides that have been identified

23 in the landfill.

24 I will stop at that we'd like to have the

25 EPA respond to those concerns.

BLANDO REPORTING & VIDEO SERVICE, INC. 54

1 MS. HAMMER: Thank you very much for your

2 comments.

3 I also want to remind everyone that all the

4 comments and questions tonight are -- taken here

5 tonight will be -- the questions will be responded to

6 in writing. And if you would like a copy of the

7 responsiveness summary, when you signed in at the door,

8 if you could just put a little check mark by your name

9 or in the box where it says "Mailing list," put a check

10 mark and we will make sure you get a copy of the

11 responsiveness summary.

12 So we are listening to your questions and

13 your comments.

14 Right now, I think Joe or Marc would like

15 to respond to some of the questions that Miss Anderson

16 raised.

17 MR. VRANKA: Thanks. You raised some good

18 points. And I probably won't be able to answer all of

19 them tonight. We will need to go back and take a look

20 at all the comments we get from tonight and do a

21 detailed analysis because there are some concerns

22 and -- but, if I may, I can -- I will try and address

23 a couple of things, one of which is the determination

24 of background in ground water.

25 First of all, we, being the EPA and the

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1 State, adamantly maintain there was no background for

2 organic contaminants. And so with the issue of

3 background for organics, we did not allow that to be

4 used. The backgrounds we looked at were for inorganic

5 contaminants.

6 And "contaminants" I use fairly loosely.

7 It's also naturally occurring concentrations of things

8 like manganese and things like arsenic. And in this

9 region, in this state, we do have naturally occurring

10 high concentrations in background of substances like

11 arsenic.

12 As far as contaminants from other sites

13 such as the Lowry bombing range, we will have to go

14 back and look at that again. You raised a good point.

15 We will have to look at it and see whether or not there

16 were inorganic contaminants that may have contributed

17 to that. We can certainly at least look at it and get

18 a good idea of whether or not this is going to be a

19 problem.

20 Radionuclides. We have the report that you

21 mentioned from the former state patrolman. We spent a

22 great deal of effort in the shallow --in the

23 investigation for the shallow and deep ground water

24 operable units because we had reports and because we

25 had suggestions that there may be Rocky Flats wastes

BLANDO REPORTING & VIDEO SERVICE, INC. 56

1 going out there.

2 We did quite a bit of sampling. We have

3 extensive sampling records on looking for

4 radionuclides. And we did find some things. We found

5 them at concentrations which the -- the concentrations

6 were extremely low and the counting errors were

7 so high because you are dealing with detections very

8 close to the limit of what we can detect.

9 And, also, there is the issue of a certain

10 amount of manmade radionuclides now in background

11 because of all the atomic testing that's gone on since

12 the dawn of the atomic age.

13 So what we are dealing with are not high.

14 We've definitely got a problem that's directly related

15 to the site. If you go look at the radionuclides

16 analysis -- there is a specific volume that's addressed

17 to that; it's part of the risk assessment for the Lowry

18 Landfill Superfund site -- I think you will find that

19 the bulk of what you can identify out there were

20 naturally occurring radionuclides.

21 And as far as some of the other things,

22 some of the manmade ones, we could not get ahold of

23 conclusive evidence that it is there and directly

24 related to the site.

25 Worker health and safety. Interesting you

BLANDO REPORTING & VIDEO SERVICE, INC. 57

1 should bring that point up and Metro should raise the 2 point about Metro being exempt from OSHA because we 3 just had our health and safety training, as Marion can 4 attest to, yesterday, and I raised the question there 5 because I was curious because the issue had been raised 6 and I wanted to find out is OSHA enforceable at some 7 things like Metro, like Denver. 8 And the answer I got -- I'm not sure it's 9 conclusive because I haven't gone and looked at this 10 yet, but 40 CFR Part 311 -- part of the regulations -- 11 EPA's regulations allow EPA to enforce the OSHA 12 standards. And it may be just the hazardous waste. 13 That's why I need to go look at it. But it allows EPA 14 to enforce the standards on local and state 15 governments. 16 And then you had a couple of the other 17 issues. I don't think I can go into some of these 18 others at this time until we've had some time to look 19 at them. 2 0 Thanks. 21 MS. ANDERSON: Can I just ask a clarifying 22 question? Are you denying that there's plutonium, 23 americium, tritium, strontium, cesium and cerium in the 24 landfill? 25 MR. HERMAN: No, we are not denying that,

BLANDO REPORTING & VIDEO SERVICE, INC. 58

1 but if you read the risk assessment -- I was going to

2 get up anyways and clarify it to make sure the audience

3 understood what Joe was saying. What we are saying is

4 that the concentrations of those manmade contaminants

5 that were found at the site are no higher than anywhere

6 else in this area.

7 MS. ANDERSON: You are saying there's

8 plutonium in the ground water throughout the Denver

9 Metropolitan area --

10 MR. HERMAN: Right.

11 MS. ANDERSON: --at acceptable levels?

12 And, of course, there is no acceptable level of

13 plutonium.

14 MR. HERMAN: Well, there is manmade

15 radionuclides in the environment because of atmospheric

16 testing.

17 MS. ANDERSON: I'm talking about plutonium.

18 Are you claiming that there's measurable levels of

19 plutonium in the ground water, in the background

20 throughout the Denver Metropolitan area?

21 MR. HERMAN: Is that what the report said?

22 MS. ANDERSON: They said there's plutonium

23 in the ground water at Lowry Landfill.

24 MR. HERMAN: Yes. Yes. What I'm saying is

25 that the radiation -- the radioactivity that was

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1 measured at the site, whether it was plutonium or

2 uranium or whatever, is at concentrations that are

3 equal to background concentrations. It doesn't matter

4 if it's plutonium or it's uranium.

5 MS. ANDERSON: It certainly does.

6 MR. HERMAN: Why is that?

7 MS. ANDERSON: Well, one particle of

8 plutonium can cause cancer. So if we have plutonium

9 particles going out to Deer Trail that are going to be

10 windblown --

11 MR. HERMAN: Radioactivity can be a

12 concern. What I'm telling you is the studies that

13 we've performed showed -- and risk assessment indicates

14 that radionuclide contamination at Lowry -- measurable

15 radionuclide contamination at Lowry is no higher than

16 background concentrations.

17 MS. ANDERSON: That's not my question. Are

18 you denying that plutonium is in the Lowry Landfill

19 ground water?

20 MR. HERMAN: No.

21 MS. ANDERSON: Thank you.

22 MR. HERMAN: Okay.

23 Now for the audience, I will reiterate what

24 I was trying to say, and that is that the -•- what's the

25 matter?

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1 MS. ANDERSON: Well, I'm stunned, because

2 the Metro board members have not been advised that

3 there's plutonium in the ground water at Lowry

4 Landfill. Just a few board members that have been

5 surveyed are unaware of that fact.

6 MR. HERMAN: As a matter of fact, I

7 supplied the Oil, Chemical and Atomic Workers Union

8 with a copy of the assessment -- I believe it was last

9 fall.

10 MS. ANDERSON: This decision was made by

11 the board members last April, I believe, before the

12 workers were informed. The board members know nothing

13 of this.

14 MR. HERMAN: Okay. Okay. There is no

15 radionuclide contamination in the ground water that

16 would be piped to Metro that is beyond background

17 concentrations.

18 MS. ANDERSON: So there's plutonium in the

19 background wells as well? Is that what you are saying?

20 MR. HERMAN: No, I'm not. And as a matter

21 of fact, we have the background report, the background

22 -- the ground water report on inorganic contaminants

23 was compiled with information that was -- I'm pretty

24 sure was not taken from the bombing range. We're

25 pretty sure that it represents typical uncontaminated

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1 conditions.

2 MS. ANDERSON: Are you aware that radiation

3 levels are -- have been found in the missile silos on

4 the bombing range site that are as yet unexplained as

5 to the cause?

6 MR. HERMAN: I can only save so much of the

7 world. My project is Lowry Landfill Superfund Site and

8 that's my responsibility. I understand that the corps

9 and the State are looking very carefully at the

10 contamination on the bombing range -- isn't that

11 correct --or they are working --

12 MS. ANDERSON: We understand that Lowry

13 Landfill is part of the Lowry bombing range. You

14 understand that?

15 MR. HERMAN: Well, it was at one point.

16 MS. ANDERSON: Yes.

17 MR. HERMAN: That's right.

18 MS. ANDERSON: Do you also understand that

19 Lowry Landfill was built on top of a former chemical

20 warfare testing area?

21 MR. HERMAN: Ma'am, are you aware that we

22 spent over -- 1984 to 1992, what is that,

23 eight years --we spent eight years doing -- we --

24 there's a number of groups involved -- doing exhaustive

25 studies of the ground water, the landfill gas, the

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1 landfill itself? And, I'm sorry, you know. I

2 appreciate your comments, and we'll take --go back and

3 look at them. I just don't think it's a problem.

4 MS. ANDERSON: So plutonium in the ground

5 water is not a problem? I just want to be clear on

6 this.

7 MS. HAMMER: Thank you for your comments

8 and questions.

9 We have a question right here. Please

10 identify yourself.

11 MR. LEVIN: My name is Al Levin. I'm a

12 director at the Metro Wastewater Reclamation Agency.

13 And I'm here as a concerned citizen, concerned with the

14 health, safety and welfare of everybody that is here

15 today and the community at large.

16 . This is a tough act to follow. I commend

17 everybody for being here, and I assume that most of you

18 are scientists or engineers and have a background of

19 technical activity that -- I don't understand most of

20 this gobbledygook. I probably understood perhaps 10

21 percent of what was said today, scientifically

22 speaking. And so what I'm going to try and do is

23 reduce my questions to two or three simple

24 observations.

25 I think that the major question, as I see

BLANDO REPORTING & VIDEO SERVICE, INC. 63

1 it, in the simplest of terras, is whether or not the

2 Metro wastewater reclamation bureau can effectively

3 treat the toxic wastes as it comes in and as; is treated

4 and as put into the Platte River. And I'm concerned

5 about whether or not as the Platte River goes up

6 towards Deer Trail whether the communities that latch

7 up there that are engaged in agricultural pursuits will

8 have toxic wastes in their area. And, if so, I feel it

9 will be a tragedy.

10 Now, what I would like to know is what

11 evidence -- what is the evidence as of this date and is

12 the accuracy of this evidence verifiable? Where are

13 the studies? Who has them? It seems to me there's a

14 lot of secrecy in here and an awful lot of unnecessary

15 confrontation. I want to know where the studies are.

16 And, finally, let's settle this dispute in

17 such a fashion that the health, safety, and welfare of

18 the entire community is not endangered.

19 Thank you.

20 MS. HAMMER: Thank you, Mr. Levin.

21 We have another question. Aubrey.

22 MS. FENNEWALD: I had a couple questions

23 concerning the first and second ESDs specifically

24 referring to levels of contamination in the

25 ground water. We were wondering how those levels were

BLANDO REPORTING & VIDEO SERVICE, INC. 64

1 decided upon because there is significant change from

2 first numbers and second numbers, and we didn't quite

3 understand how those were determined.

4 And then just concerning this POTW proposal

5 overall, I think if we're going to be sending a trail

6 of toxic sewage lines out to the people of Deer Trail

7 we need to consider all of the --of the separate

8 entities that are going to be contributing to that

9 sewage sludge.

10 And in the draft definition of the POTW

11 treatment option there is mention of ASARCO -- the

12 ASARCO plant that would be a part of the contributors

13 to Metro and a part of the sewage sludge that would

14 eventually then be going out to the people of Deer

15 Trail.

16 There was a study done by CH2M HILL that

17 found plutonium -- lo and behold, our lovely friend

18 plutonium -- in 100 percent of the soils samples taken

19 from ASARCO. And, again, I'm wondering, our facility

20 --is the facility of Metro adequate to be treating

21 such things as plutonium that will be going out to the

22 people of Deer Trail.

23 And I'm wondering why there was no -- we

24 haven't been able to find --if there is, please point

25 it out to us -- an explanation of significant

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1 difference to the ROD concerning the Lowry Landfill

2 cleanup and the ROD concerning the ASARCO site, which I

3 think is relevant -- both relevant in this POTW

4 proposal of how ASARCO became a part of this Metro

5 proposal.

6 Thanks.

7 MR. VRANKA: I'll try and address those,

8 probably by addressing the last one first.

9 ASARCO isn't part of this BSD. It's a

10 separate site. And we don't really -- I mean, I

11 personally don't --

12 MS. NEWMAN: I think, though, it should be

13 a consideration.

14 MR. VRANKA: You think it should be a

15 consideration, the contamination from ASARCO?

16 MS. NEWMAN: Right.

17 MR. VRANKA: How we looked at that and how

18 we look at -- I hear a lot of comments about hazardous

19 waste and stuff going out to Deer Trail and Agate. And

20 I want to clarify we are not just taking hazardous

21 waste from Lowry Landfill and shipping it out there.

22 The pretreatment --

23 MS. NEWMAN: Yes, you are.

24 MR. VRANKA: Ground water is going to

25 require pretreatment, at least --we are going to have

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1 to treat ground water to meet Metro's influent

2 standards. We rely --do rely somewhat upon Metro to

3 set their standards such that they will protect

4 human -- public health and the environment, they will

5 protect worker safety, they will maintain exceptional

6 quality sludge, and they will also maintain their

7 ability to meet their effluent standards.

8 Metro is regulated by EPA. -It's regulated

9 by the State. They required -- they have discharge

10 limits. They have limits for what's in their sludge.

11 And so I do want to clarify that.

12 MS. NEWMAN: What are those limits for

13 plutonium?

14 MR. VRANKA: Well, you know, I think what

15 Marc was getting at with plutonium -- and -- I mean,

16 you raise a good issue. Adrienne was asking, is it in

17 background. The problem is, if you go and look at data

18 we have —all the data we have -- as I said, the

19 detection limits --we are dealing with detection

20 limits that are so close to the limit that you have

21 huge counting errors, you have huge errors in the

22 measurement.

23 So that uncertainty -- all we are able to

24 say and all we were able to find with the radionuclides

25 is that they were not significantly different from

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1 background. That doesn't mean that we have conclusive

2 evidence that it's in background. It doesn't mean we

3 have conclusive evidence that it's on-site. All we can

4 say, it was not significantly different from

5 background.

6 SPEAKER: So you are saying that; the

7 overall nuclides, as a whole, were not different in

8 backgrounds? You are not saying that the measurement

9 of plutonium, in particular, and americium, and other

10 manmade --

11 MR. VRANKA: Those, as well, as manmade

12 materials. Those as well --

13 SPEAKER: Those weren't particularized out,-

14 were they, in the CHM --

15 MR. VRANKA: I can't tell you without

16 having the document out in front of me. That's getting

17 into some detail. But we did go through -- and I

18 don't remember who was involved in that. I'm probably

19 not the.best one for going into detail on

20 radionuclides, but I remember from the study we had

21 nothing conclusive.

22 Had we had something that said conclusively

23 plutonium is at the site, we'd have done something

24 about it. That's not something that we let go by the

25 wayside.

BLANDO REPORTING & VIDEO SERVICE, INC. 68

1 MS. NEWMAN: Alyssa Newman, and I just had

2 a comment that shouldn't you have conclusive evidence

3 that there isn't plutonium in there before you let this

4 plan go through? Because, I mean, that's -- you know,

5 the people -- the worker safety at Metro and then out

6 at Deer Trail -- I mean -- obviously, you should be

7 certain about that about before this happens, I think.

8 MR. VRANKA: Right. Right. That's-a good

9 point. And, you know, like I said, it's not as easy to

10 do an analysis that says nothing is there. We deal

11 with -- I was talking about practical quantitation

12 limits. It's the lowest level at which you can

13 actually measure content. We can't measure zero. We

14 can't measure zero. At this point, the laboratories

15 can't measure zero. We can get closer and closer and

16 closer, but we can't measure zero.

17 MS. NEWMAN: What I'm saying is the study

18 should be begun beforehand and more extensively. It

19 sounds like you don't have a lot of conclusive evidence

20 in there.

21 MR. HERMAN: We studied quite a bit, and

22 what we are saying is that the evidence of the

23 contaminants is not there.

24 I should mention one thing that I didn't

25 mention, and I hope everybody can hear me, is that just

BLANDO REPORTING & VIDEO SERVICE, INC. 69

1 because to date we have not seen any radionuclide

2 contamination significantly different than background

3 at the site does not mean that we will not monitor for

4 it. So it will be monitored. We will continue to

5 monitor, take samples and analyze for radionuclide

6 contamination.

7 And if it does become a problem, then we

8 will develop a treatment process and insert it into the

9 already existing treatment on-site to address that

10 problem. So we are not just saying, okay, we didn't

11 find anything so we don't think it's a problem anymore.

12 We will continue to look at it.

13 MS. ANDERSON: But you did find plutonium.

14 I don't understand your response.

15 MR. HERMAN: I ask that the slide be put up

16 -- Metro. Wastewater Reclamation District is regulated

17 by both the EPA and the Colorado Department of Public

18 Health and Environment. And there are standards that

19 Metro must achieve under the law. And we only picked a

20 few examples.

21 We didn't mean to imply that these are the

22 only contaminants to be concerned about. What we're

23 trying to show is that the Metro Wastewater

24 Reclamation's district facility is completely capable

25 of treating the water from Lowry Landfill and that the

BLANDO REPORTING & VIDEO SERVICE, INC. 70

1 volume of Lowry water -- and for that matter, we can go

2 to the next slide.

3 The concentrations of contaminants in the

4 water is not that significant from industrial

5 dischargers that -- this gets to Aubrey's questions

6 about ASARCO. And as Joe indicated, we will take a

7 look at that. But Metro is by law required to operate

8 their plant in a certain way. And we believe they are

9 completely capable of operating.

10 Keep in mind that for these standards --

11 Joe alluded to it -- part of the influent standards

12 that they set for dischargers like Lowry or an

13 electroplater are based on ensuring that worker health

14 and safety is protected.

15 And I understand we have comments from the

16 union, and we'll sit down and respond to your comments

17 when they are transcribed.

18 I interrupted Joe in the middle of

19 something.

20 MR. VRANKA: Well, we can --

21 MR. HERMAN: Aubrey, I think you asked with

22 the first Explanation of significant differences --

23 MS. NEWMAN: Yeah.

24 MR. HERMAN: -- you wondered why we changed

25 some standards.

BLANDO REPORTING & VIDEO SERVICE, INC. 71

1 MS. NEWMAN: I was wondering, what is that

2 based on? I don't understand what the MCL was based

3 on. There was such significant difference in the

4 numbers --

5 MR. HERMAN: Right. Right.

6 MS. NEWMAN: -- that it was questionable.

7 MR. HERMAN: First of all, there were some

8 numbers that were just wrong. We read the -•- I know

9 it's hard to believe that EPA made a mistake, but we

10 read -- just read -- some of the regulations;, we read

11 the numbers wrong.

12 As Joe talked about, there are -•- there are

13 instruments -- laboratory instruments for measuring

14 certain chemicals, and they can only operate to a

15 certain level. And in those instances where the

16 standard is below the capability of the instrument to

17 measure, the best we can do is we -- if we measure the

18 water sample and we say, okay, well, selenium is

19 present at a certain concentration based on the

20 equipment capability, now -- and I'm not saying well

21 then we'd just jack up the equipment's capabilities so

22 that it exceeds the regulatory standard. We didn't

23 allow that to happen. The MCL, the maximum

24 contaminants levels, are levels established in the Safe

25 Drinking Water Act.

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1 MS. NEWMAN: Okay. The first levels were

2 »aeed on risk assessment?

3 MR. HERMAN: No. No. No. No, not risk

4 assessment. They are risk based.

5 MS. NEWMAN: Risk based. Right.

6 MR. HERMAN: They are theoretical

7 calculations.

8 MS. NEWMAN: Based on carcinogenic studies,

9 cancer rates from health reports across the country for

10 various studies -- so I'm wondering, that would seem a

11 more reasonable level to be following if we are talking

12 about people's health rather than some arbitrary MCL

13 based on --

14 MR. HERMAN: You have a wonderful way of

15 putting things.

16 I don't think an MCL is an arbitrary number

17 that's assigned. It is a regulatory requirement. I

18 mean, it is based on studies as well. The difference

19 is that .the maximum contaminant level as well as the

20 Colorado basic standards for ground water are based on

21 scientific evidence, the risk based numbers that we are

22 talking about. Not in all situations.

23 But in the situations where we replaced the

24 risk based standard with an MCL or Colorado basic

25 standard for ground water was when the risk based

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1 numbers were theoretical. And we felt it would be --

2 we were being more realistic.

3 MS. NEWMAN: My next question, then, is

4 this across-the-board statewide acceptance -•- level of

5 acceptance or -- it's to my understanding that there

6 could be significant difference region to region, area,

7 people in Deer Trail, that county could have a

8 different -- different MCL than Denver and Aurora. Is

9 that correct?

10 MR. HERMAN: I don't think a different MCL.

11 MS. NEWMAN: Is it a statewide thing that

12 would be --

13 MR. HERMAN: A maximum contaminent level is

14 a federal standard. Colorado basic standards for

15 ground water are state, and I'm not -- I can't speak

16 about them. Most of them are statewide, Joe says.

17 MS. NEWMAN: Most?

18 MR. HERMAN: Yes.

19 MS. NEWMAN: But there is some difference?

20 MR. HERMAN: We are getting the question

21 down so we will be able to go back and respond to it.

22 And I guess at some point throughout this

23 there was also concern expressed about the health and

24 welfare and the environment out by Deer Trail and

25 Agate. And, again, I would remind the audience and we

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1 will go back and respond to the comments. But I would

2 remind the audience that there are some standards as to

3 sludge -- regulatory standards for sludge quality --

4 MS. NEWMAN: Based on what?

5 MR. HERMAN: What?

6 MS. NEWMAN: Based on what?

7 MR. HERMAN: Regulatory standards.

8 Does anybody --

9 MS. NEWMAN: It's such a vague term,

10 "sludge quality." What is that?

11 MR. HERMAN: Hold on a second.

12 Phil Hegeman with the Colorado Department

13 of Health and Environment who deals with Metro's sludge

14 will say something.

15 MR. HEGEMAN: With respect to MCL issues,

16 those issues, the numbers that come out in the Safe

17 Drinking Water Act -- the federal Safe Drinking Water

18 Act -- those are meant to be applied nationally. There

19 are some site-specific ground water standards that the

20 Colorado Water Quality Control Commission has set for

21 specific areas within Colorado. And those can be more

22 stringent than the MCLs.

23 More typically what they are when the

24 commission adopts a site-specific standard, it's for a

25 parameter that there is no national MCL that has been

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1 established for. So when you see differences in one

2 part of the state from another, it is usually to

3 address those site-specific concerns. And the

4 site-specific concerns are usually driven by some past

5 activity that has caused some ground water problems in

6 that area.

7 MS. NEWMAN: But it's all the same

8 chemical, isn't it?

9 MR. HEGEMAN: No. It can be different

10 parameters or different chemicals. So if an MCL is

11 established for a different chemical, that is applied

12 nationally, but the commission can go into an area

13 where, again, as I say, there's been --

14 MS. NEWMAN: But lead in one place is lead

15 in another place. And lead in my body is the same as

16 lead in somebody else.

17 MR. HEGEMAN: Right. The MCL for lead is

18 applied the same way across the board, as far as I'm

19 aware. I'm not aware of any specific ground water

20 areas where the commission has adopted a different

21 standard other than the national MCL for lead.

22 An example where we have done something

23 different is out at the Rocky Mountain Arsenal where

24 they have gone in and established a site specific

25 standard for a chemical -- I can't remember the whole

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1 -- DIMP -- where there is no national drinking water

2 standard for something like that, there was not a lot

3 of toxicological data. The data that the commission

4 looked at in establishing the standard mainly had to

5 feeding chemical with mink and then looking at

6 toxicological effects on mice as a result of that

7 exposure.

8 So when you see those different standards,

9 it's usually for those oddball parameters, oddball

10 chemicals for which there is no national standard and

11 the commission felt it was a necessity to go in and set

12 a site-specific standard.

13 Does that clarify that at all?

14 MS. NEWMAN: Doesn't make me feel any

15 better, but, sure.

16 . MR. HEGEMAN: Now, I will tell you

17 what, let me talk about the biosolid standards or the

18 sludge standards real quickly. And there are

19 limitations, both state and federal. They are both the

20 same. They are both set at the same level. We don't

21 have any state specific standards for biosolids that

22 vary from the federal standards.

23 Right now, there are standards in place for

24 nine of the metals. And metals do tend to concentrate

25 in the vital zones at a wastewater treatment plant.

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1 They tend to absorb onto the suspended solids in the

2 wastewater. And in the course of treatment, they tend

r' 3 to come out and accumulate in the biosolids..

4 Federal standards are based on a risk

5 assessment approach. And they looked at a total of --

6 I don't want to get into a whole lot of detail here,

7 but basically they evaluate 20, 21 potential pathways

8 of exposure. And the limitation that is. set for most

9 of the metals were --it ended up they were driven by a

10 couple of different pathways predominantly.

11 For a number of metals they were driven

12 pica children, or children that eat soil, eat lots of

13 things. And there was a concern that there concern

14 they might be exposure to children to biosolids and

15 they'd actually end up consuming that product.

16 And that pathway actually drives the

17 numeric limitations for three or four of the metals.

18 Arsenic is one, cadmium is one, lead is one, and

19 selenium, I think, is the other. Most the other

20 metals, the limitations are derived based on

21 phytotoxicity or toxicity to vegetation.

22 And the metals will become toxic to the

23 vegetation at a concentration which is lower than when

24 they potentially create human health risk. And so by

25 virtue of the fact that the vegetation is killed off,

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1 there is no potential, then, for uptake in the food

2 chain. And that was found to be the most serious

3 pathway of concern on those.

4 I've got a couple of questions -- I saw

5 about three hands had came up. One other point I would

6 like to make. A lot of people say why aren't there

7 limitations for organic chemicals, it's all for

8 inorganics.

9 In 1989, EPA commissioned a $20 million

10 study. They took biosolid samples. They collected

11 them at 177 different POTWs nationally. And each of

12 those samples was analyzed for 350 different

13 constituents. EPA created what they called their "list

14 of lists" where they went through they reviewed all of

15 the environmental regulations that had any parameter-

16 specific limitation attached to it.

17 And they compiled all of those into their

18 list of lists and they came up with 350 different

19 parameters. And they analyzed each of those 177

20 samples for all of those 350 parameters. And what they

21 found is that, with a couple of rare exceptions, we

22 don't see organic chemicals concentrating

23 in the biosolids.

24 They are either biodegraded in the

25 treatment plant, they may be volatilized off. It may

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1 be an air emission issues. Or they may not be degraded

2 in the treatment plant and may just pass through the

3 treatment plant and into the river. So there's three

4 options there where potentially inorganics are

5 concerned. And that's why you don't see limitations

6 placed on organic chemicals for biosolids in the

7 regulation.

8 SPEAKER: Listening to this discussion just

9 --it's amazing. I do have the CH2M HILL baseline risk

10 assessment here if anyone is interested. A lot of the

11 discussion that went on, in particular about the risk

12 assessment, isn't correct.

13 First of all, if you understand the EPA

14 risk assessment methodology, you recognize that that

15 risk assessment which was conducted a couple years ago,

16 maybe even -- well, four years ago was based upon the

17 premise that everything would be treated on-site at

18 Lowry, and the risk assessment only looked at the risk

19 to future generations that might occupy that Lowry

20 Landfill Site once it's all cleaned up. Okay. That

21 makes sense. That's what the federal regulations say

22 is all they have to do.

23 Well, now we are going to take some of that

24 hazardous -- hazardous substances from Lowry Landfill

25 which is really a soup, a mixture of chemicals. No one

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1 understands the hazards of the mixture of these

2 chemicals. As an industrial hygenist who works with

3 chemicals and looks at worker exposure to chemicals

4 everyday, I know for a fact the science isn't there.

5 We don't understand how multiple chemicals affect a

6 person.

7 We can understand lead by itself, we can

8 understand mercury by itself, but we can't understand,

9 you know, all the carcinogens that I dug out of the

10 risk assessment that have never been talked about here,

11 not to mention the -- you talked about the

12 radionuclides. We don't know what the effects are of

13 all those materials.

14 But, now, we change the whole scope of

15 this. This is not a minor modification. We are going

16 to take this stuff and put it through a public sewer

17 system, it's going to leak out. Okay.

18 I have a master of science of public health

19 from the University of Washington School of Community

20 Medicine and Public Health. Sewer systems leak all the

21 time. Okay. So these contaminants that are going

22 through the sewer systems underneath Aurora on their

23 way to the Metro treatment plant are going to leak out

24 into the soil and eventually into the ground water.

25 You are going to have utility workers

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1 that's going to work on these sewers. It's going to

2 leak out. It's going to be in the sewers. The

3 workers -- the utility workers are going to be exposed

4 to this stuff. Okay. That's not unreasonable to

5 understand.

6 The Metro workers themselves who are going

7 to have to handle this stuff that they haven't had to

8 handle before have absolutely no protection. They are

9 not covered by OSHA, period. Metro -- now, some of the

10 Metro workers are OCAW union members. They have been

11 without a union contract for several years now. Why?

12 Metro refuses to work with them, refuses to bargain

13 with workers. Okay.

14 "^hat doesn't say a lot for the Metro

15 district and the management of that Metro district.

16 What that should tell you is that they are covering

17 some things up here. They are hiding some things.

18 They are not to be trusted. Okay.

19 If they can't bargain honestly with their

20 own workers, how can you expect them to put forth a

21 proposal -- this is a Metro proposal, okay, to funnel

22 this stuff through the sewer systems.

23 The bottom line is -- the question is, what

24 are the risks for transporting the Lowry hazardous

25 substance through the sewer system. Guess what? There

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1 is no federal regulation that says EPA or the Colorado

2 state has to do any risk assessments for the people in

3 Aurora or anywhere along that pipeline.

4 All they have to do so is a risk assessment

5 on the Lowry Landfill for people who won't even live

6 there for 10 or 20 years from now. Okay.

7 There's no regulation that says they have

8 to do a human health baseline risk assessment for the

9 Metro workers, the people that are going to work with

10 this stuff, okay, and treat it. You talk about

11 loopholes. Okay.

12 This is a bad idea, a very bad idea. There

13 is a $1 million --if you look at the Parsons

14 Engineering options, the things they were showing

15 earlier, the alternatives, there is a $1 million

16 difference between doing all the treatment on-site or

17 pumping it through the Metro system.

18 MS. HAMMER: I'm sorry --

19 . SPEAKER: Ask yourself, is the risk worth

20 it?

21 MS. HAMMER: I'm sorry to interrupt you.

22 We have only 10 minutes left. And I encourage you to

23 submit your comments in writing and we will respond to

24 all of them, but there is a number of people who have

25 been waiting patiently.

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1 This gentlemen over here.

2 DR. DEMOS: I'm Dr. Ed Demos, director --

3 division director of environmental services for the new

4 Department of Environmental Health, City and County of

5 Denver. And it causes me some concern when our own

6 board members are concerned about the accuracy and the

7 voracity of the information presented.

8 The hard science long ago passed me by from

9 my early days at the Lowry Landfill. Some of my

10 colleagues are here when they were first exposed to

11 this information back in early 1980. So I pass that on

12 to other scientists and engineers that are working with

13 the day-to-day.

14 Now, from a policy standpoint, Mr. Levin,

15 and you, Adrienne, as well, my office is open. I have

16 a room full of studies that we have been storing since

17 the first ones were done back in 1980. We have

18 spent millions of dollars studying the site. I am not

19 going to argue other than to say, please come in, the

20 data are there. I am concerned that you suspect

21 there's some secrecy here.

22 And the data is available to you and you're

23 welcome to come in. You don't even have to call.

24 MS. ANDERSON: I appreciate that. Just

25 want to advise you that I did go in and meet with three

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1 staff from your office back in August -- July, August

2 and have looked at the documents around this and did

3 express at that time that I, you know, was concerned

4 about the plutonium issue, and that was not

5 satisfactorily addressed.

6 Dr. DEMOS: I'm sure we will address that

7 issue. But as long as you are saying you were told --

8 you aren't given access to the information, that's.what

9 I'm concerned with.

10 MS. ANDERSON: But I was told by the Metro

11 board that they considered it devious that I was

12 looking at the public documents on this issue.

13 DR. DEMOS: I can't address that. I don't

14 know anything about that, but at least it is available

15 for you, and you, Mr. Levin.

16 MS. HAMMER: Thanks for your comment. Go

17 ahead.

18 MR. RICE: My name is David Rice. I have a

19 question regarding the sludge that's going to be

20 shipped out to Deer Trail and put on cropland. What

21 about the studies that show that crop lands such as

22 wheat and corn do take up heavy metals into the grain

23 and the kernels of corn?

24 Is this -- are these crop plants going to

25 be sold on the market and are you going to be told at

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1 that time what -- where our corn and wheat comes from?

2 MR. HEGEMAN: Are you referring to the

3 Bennett studies that have been by CSU --

4 MR. RICE: I have a series of studies that

5 show that plants do take up these metals.

6 MR. HEGEMAN: Uh-huh.

7 MR. RICE; And if we have these metals

8 uptaking into our croplands, are these going to enter

9 our food web? That's my concern.

10 MR. HEGEMAN: Well, even on sites that are

11 not amended with sewage sludge, you have metals that

12 occur naturally in the soils and you have plant uptake

13 of those metals.

14 MR. RICE: Yes, but sewage sludge has

15 increased levels of heavy metal.

16 MR. HEGEMAN: Sewage slude has, in some

17 cases, comparabale levels of heavy metals in

18 background --in soil background; in some cases it has

19 higher than background levels. It depends on what

20 metal we are talking about and what area.

21 The work that CSU has done out near Bennett

22 was a 14-year study. It's still ongoing. And they did

23 find that over -- and this was on dry land wheat, so

24 it's a two-year cropping cycle. They don't grow a crop

25 every year. They do a cropping and fallow rotation.

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1 So 14 years actually represents 7 cropping cycles.

2 An analysis of the grain over that time did

3 show that there was a statistical increase --

4 statistically significant increase in copper and zinc

5 concentration in both the grain portion of crop and in

6 the nongrain portion of crop. It did not show

7 significant increases in any of the other metals that

8 were analyzed for.

9 MR. RICE: The studies I see show increases

10 in cadmium, nickel, and copper also.

11 MR. HEGEMAN: Copper is one of them I

12 mentioned. There had been some studies that had been

13 done called POD studies. Typically, these are

14 greenhouse studies. And there are probably a few

15 others that we could find that look at selenium and

16 maybe some of the other heavy metals.

17 Those studies have generally been

18 discredited because they were done by -- instead of

19 taking a soil sample and amending it with sewage

20 sludge, they are typically performed by taking a soil

21 sample and then amending with metal salt, which is a

22 different chemical form --

23 MR. RICE: All the studies I have are

24 amended with sewage sludge.

25 MR. HEGEMAN: Well, I'm not familiar with

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1 exactly which studies you are looking at. The studies

2 that I'm familiar with are peer review journals, and

3 they have been done locally. Some of them have been

4 done in other areas.

5 And I can tell you that with the exception

6 of some of those POD studies where there have been

7 chemical salts added to simulate higher metal

8 concentrations and simulate the long-term application

9 and accumulation of biosolids -- it is possible in that

10 case to see some of the results you are talking about.

11 The long-term studies that have been done,

12 yeah, they have found increased levels of -•• here in

13 Colorado -- zinc and copper. I do recall that nickel

14 is another parameter that we have seen increase.

15 Haven't seen concentrations of cadmium that have

16 increased to the point where it's been significant.

17 And the other thing that I would point out

18 is, even if they are increased, it isn't a problem. A

19 lot of people think if it's a heavy metal, it must be a

20 problem. Your diet is probably deficient in zinc. 95

21 percent of the people in this country have dietary

22 deficiencies in zinc. So --

23 MS. NEWMAN: Did those long-term studies of

24 those biosolid applications include plutonium?

25 MR. HEGEMAN: No, they have not included

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1 plutonium. In the study I mentioned earlier, they did

2 look for plutonium, is my recollection. They didn't

3 find any in the 177 samples that they looked at. So I

4 can't really speak to you about plutonium in biosolids

5 because we have not found any.

6 MR. RICE: One final question. Are we

7 going to be informed about where these crop plants are

8 going to be sold if they are going to be sold in our

9 area?

10 MR. HEGEMAN: Most of the crops that are

11 grown --85 percent of biosolids that they generate in

12 the state are beneficially recycled. A lot of that

13 goes onto farmland, primarily dryland wheat. And that

14 dryland wheat is usually sold to buyers who end up

15 using it in flour manufacture. Chances are, we are

16 already consuming baked products that include flour

17 that is milled from that.

18 No, there is no special notification that

19 takes place.

20 MS. HAMMER: Thanks for your comment. And

21 in terms of those studies that you mentioned, if you

22 want to submit those with your comments, we would be

23 happy to look at those and take those into account.

24 In the back.

25 MS. ULMER: My name is Mary Ulmer, and I'm

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1 from out in the Bennett region.

2 MS. ANDERSON: Can you speak from the mike

3 so we can all hear you better, please?

4 MS. HAMMER: The reason I'm pushing

5 people along, we are told we have to leave at

6 9 o'clock. We really want to hear from everyone.

7 MS. ULMER: A couple of questions and

8 comments.

9 I'm from out in the Bennett area. We've

10 dealt with this sludge issue before. One of the

11 questions that I brought up before and I just want to

12 bring up again, the sewage sludge issue has been going

13 on for over a decade now. And when we first approached

14 the farmers out in eastern Colorado, they sold it --

15 they sold the ideas to us that it was going to be a

16 good fertilizer, and then they leased ground to put it

17 on.

18 Well, now they are not able to lease any

19 more ground to put it on, and I'd like to know the

20 reason that is. Obviously, I live out there, so I

21 pretty well know the reason, but that has never come

22 up. And now the City of Denver is buying ground, over

23 50,000 acres, to put sludge on.

24 Well, as you go -- you now, you are going

25 to continually produce sludge, you are going to

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1 continuously do this. Once you wear this ground out,

2 where do you go from there and what are you going to do

3 with the ground that you have already put all this

4 sludge on, because I know that it's not a good

5 fertilizer. It doesn't produce good crops. That's why

6 it's really hard to even give away to a farmer at this

7 point, because historically we already know this now.

8 The other thing I would like to-find out

9 is -- you say that the -- you pointed out that in the

10 solids, one of the risk assessment you make is whether

11 the stuff is like on grasses so kids can eat it or

12 stuff. Well, you are going to put it on farm ground.

13 Cows are going to eat the grass, and kids are going to

14 eat the cows. So aren't the kids eating the stuff

15 anyways? That would seem logical to me.

16 . And then the comment was made that when you

17 discover a problem, then you are going to take

18 measures -- to take measures for the workers to

19 eliminate that problem. My question is, once you

20 discover that problem, there's already a lot of garbage

21 distributed on the ground out there, what are you going

22 to do with that that's already on the ground? How are

23 you going to undo that problem? Because intrinsically

24 government agencies react, they don't act to prevent.

25 So I'd like to know where it's going to go

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1 from there and how much -- you know, I keep hearing,

2 once again, the extreme dumping or the long-term

3 dumping or whatever -- how long is this site in Deer

4 Trail going to be used how much sludge is going to be

5 dumped, at what point is the regulations as they are

6 passed going to say this is enough, this isn't healthy,

7 now we have to move to the next patch. And are you

8 going to just move to another patch in eastern Colorado

9 or are we finally going to come up with some

10 solutions?

11 Also I have just a little ditty from the

12 New Scientist Magazine that says, "Toxic Cadmium Found

13 in British Sheep." That's the start of it. "Britfcish

14 sheep that graze on land fertilized with sewage sludge

15 have accumulated high levels of cadmium in their livers

16 and kidneys, New Scientist Magazine reports." So

17 that's another study we might look into.

18 Thank you.

19 MS. HAMMER: Thank you for your comments,

20 Mrs. Ulmer. You have been real patient.

21 DALE: My name is Dale. Based on the

22 discussion I've heard tonight, there seems to be a lot

23 of questions that aren't answered, and it sounds like

24 there needs to be more investigation, sounds like not

25 all the answers are out there. I would like to ask for

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1 a 30-day-extension for public discussion.

2 MR. HERMAN: You got it. We will extend

3 the public comment period to May 22, 30 days from when

4 it was originally scheduled.

5 Yes, sir.

6 MR. DRUCKER: I'm Joe Drucker. I am with

7 OCAW. I did not come here knowing much about this

8 issue when -- learned a little bit tonight, but I just

9 have a few questions. And they are naive questions. I

10 think they are the kinds of questions a person in the

11 street would ask, because that's almost what I am in

12 terms of knowledge about this situation.

13 But how much have the responsible parties

14 paid in to a fund to rectify the problem at the Lowry

15 Landfill?

16 MR. HERMAN: I have to answer your question

17 in several parts. To date -- let me start by telling

18 you what EPA has spent. EPA has spent about $27

19 million studying and overseeing. That's EPA. Now, the

20 responsible parties at the site, we estimate

21 conservatively, at least 50 million, probably --

22 probably several tens of millions more than that, but

23 we feel as if we have pretty good documentation for

24 between $50 and $60 million that the Potentially

25 Responsible Parties have spent at the site.

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1 Now, if -- are you referring to the private

2 settlement litigation --

3 MR. DRUCKER: Yes.

4 MR. HERMAN: What has gone on between the

5 three principal players right now that are designing

6 and constructing the cleanup of the site, the City and

7 County of Denver, Waste Management of Colorado, and

8 Chemical Waste Management, they entered into private

9 settlements with over 140 other entities tha± are

10 responsible parties at the Lowry Landfill. The judge

11 sealed those settlement decisions. And EPA has tried

12 to get access to those, and we have been unsuccessful

13 at finding out what those private settlements were.

14 MR. DRUCKER: Do you have a ballpark figure

15 in terms of your alternatives on the BSD, the

16 difference between the cost of the on-site treatment

17 versus the off-site treatment?

18 MR. HERMAN: Yes, sir. Years. And,

19 actually, that's discussed in a technical evaluation

20 document that is available in the -- not only the EPA

21 Superfund Record Center but also available at the

22 Aurora Public Library or, you know, if somebody wants a

23 copy of it, they can let me know.

24 The alternative to ship pretreated water to

25 Metro is estimated -- this is a present worth cost --

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1 is a little over $6 million. Present worth includes

2 the capital costs of the construction of the pipeline

3 and fitting, it also includes operation and

4 maintenance. And it looks at operation and maintenance

5 for a period of 30 years as a rough ballpark figure.

6 So it's $6 million for Alternative 1, which

7 is the POTW option.

8 The second alternative -- modified

9 alternative -- the present worth estimate for that is

10 about $9 million. So the POTW option is about $3

11 million cheaper -- or would be about $3 million cheaper

12 than the other alternative.

13 Are we done?

14 MR. DRUCKER: I would like to hear from

15 Adrienne.

16 MS. ANDERSON: Just another question. I

17 see from going through the public record that there is

18 a citizens group of residents that are near the

19 landfill that has a technical assistance grant --

20 MR. HERMAN: That's right.

21 MS. ANDERSON: --to evaluate this. What

22 is their position on this issue and are they not here

23 tonight?

24 MR. HERMAN: I don't know.

25 MS. ANDERSON: I don't see representatives.

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1 MR. HERMAN: The group is Citizens for

2 Lowry Landfill Environmental Action Now. The acronym

3 is CLLEAN. They actually modified 2 B. The

4 alternative is modified because of input we received

5 from them last year. And they -- well, I'm not going

6 to speculate for them.

7 MS. NEWMAN: In the technical evaluation

8 proposed ground water treatment and disposal.

9 alternatives, this group they recommend Alternative 2,

10 not the first one.

11 MR. HERMAN: Modified Alternative 2 is what

12 you are saying?

13 MS. NEWMAN: Right.

14 MR. HERMAN: That's also in that evaluation

15 that I mentioned is available at the Superfund Records

16 Center or the Aurora Public Library.

17 MS. NEWMAN: Just in answer to which one

18 did they like, they liked the other one.

19 MR. HERMAN: I don't think we have to worry

20 about getting kicked out because Jaanelle is guarding

21 the door so we are okay.

22 MS. HAMMER: Are there any more questions

23 or comments?

24 Go ahead.

25 MR. HOLMSTROM: Again, we represent about

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1 90,000 --we have about 90,000 members across the

2 United States. Our members work in toxic industries.

3 It is not a subject that we are unfamiliar with. We

4 want to make it clear that we are not going to go

5 away. We want to get to the bottom of this. We think

6 there are serious, serious problems with your proposal,

7 not only problems from the vantage point of the

8 worker, certainly problems in the agricultural areas

9 with the farmers. We are going to be working with them

10 and you are going to hear from us.

11 MR. HERMAN: All right.

12 MR. HOLMSTROM: And you also have to

13 understand that there is an inextricable connection

14 between how our workers have been treated at the

15 Metro's Reclamation District and this proposal.

16 MR. HERMAN: And I understand that and I

17 appreciate that. And I would encourage you, in

18 addition to making the comments here tonight, please

19 submit comments to support your concerns and then any

20 evidence or documentation or data -- I mean, the more

21 information we have to look at and evaluate, the

22 better.

23 MR. BILLIARD: Is Metro licensed as a

24 hazardous waste treatment plant?

25 MR. HERMAN: No.

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1 MR. BILLIARD: So, by regulation, they

2 won't be accepting hazardous waste, right? If we take

3 a look at the water that's going there, this is, by

4 regulation, not considered hazardous. That's a

5 distinction someone needs to make, is that the water I

6 think leaving Lowry Landfill is not being considered

7 hazardous by statute.

8 MR. HERMAN: Not considered hazardous

9 waste.

10 MS. NEWMAN: Could you identify yourself?

11 MR. BILLIARD: My name is John Billard.

12 I'm just here representing myself. And I have been

13 listening to all the comments. The reason I'm standing

14 here is I do have quite a lot of site knowledge. I

15 have worked with a lot of people, but I'm not working

16 for them, now, nor probably will in the future. So I'm

17 just here, not being paid.

18 A couple of things -- I just want to clear

19 that up because I don't want there to be any -- because

20 a lot of you guys have already seen me talk at public

21 meetings before.

22 A couple of things that have not come out,

23 that I think has been glossed over, maybe not

24 intentionally, is that there's going to be a boundary

25 wall placed around the site. The purpose of this

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1 boundary wall is to contain and stop the ground water

2 movement through the site. So while there may be some

3 ground water movement today in terms of 10 or 20

4 gallons a minute, over the next several years, I expect

5 that to trickle to next to nothing.

6 So something to bear in mind is that what

7 you are looking at tonight is a proposal for 10 gallons

8 a minute, which is like a garden hose.

9 Another thing not talked about fully enough

10 is that the water, when it-goes through the treatment

11 plant, it's treated quite a bit. What goes to Metro

12 will contain some inorganic compounds. And I'm not

13 saying that's a good thing, but I don't think it's a

14 bad thing.

15 And if you can save some money -- now that

16 I'm speaking for myself and I don't have to worry about

17 what I say so much --if you can save some money, do

18 it. The concept of spending all the money that you can

19 to create a perception of a safer environment, in my

20 opinion after I've been dealing with this problem over

21 the last ten years, is not necessarily the best idea.

22 I think the EPA in some ways is to be

23 commended for at least accepting alternative approaches

24 where cost is a consideration. I think the public

25 needs --at least I'm tired of paying tax money. And

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1 to have it wasted away in this particular case -- they

2 are trying to save some money, use an existing

3 resource, meet all the regulations, I don't see a

4 problem with this.

5 MS. NEWMAN: Concerning the treatment of

6 these organics on-site -- for either one of you because

7 he said he worked there -- works with the stuff -- will

8 the alternative in your presentation as worded,-

9 "On-site treatment for removal of organics using air

10 stripping and carbon absorption and off-site treatment

11 for removal of inorganics or many organic-containing

12 contaminants using the POTW."

13 Well, I'm -- this stuff is all mixed

14 together in Lowry Landfill. You've got all this

15 hazardous toxic waste and they are all together.

16 Inorganics, organics all mixed in together. Heavy

17 metals, chemical wastes, radioactive whateve:r. How can

18 the inorganics and the organics be treated if they are

19 all mixed up together?

20 Do you first separate it on-site and then

21 treat them? Or do you treat them all when they are

22 all mixed? How is that effective? How can you

23 separate the inorganics from the organics? Is that

24 effective treatment? And, then, how are they separated

25 if you are going to separate them? If you are not

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1 going to separate them, is it effective if they are not

2 going to be separated?

3 Do you understanding what I'm saying?

4 MR. HERMAN: I sure do.

5 MS. NEWMAN: They are --

6 MR. HERMAN: Carbon absorption is effective

7 at removing organic chemicals but does not --it treats

8 a teeny bit but it is not effective at grabbing the

9 inorganic chemicals in the water. So the inorganic

10 chemicals in the water pass through that kind of

11 treatment.

12 MS. NEWMAN: Okay.

13 MR. HERMAN: But the carbon doesn't --it

14 doesn't -- I guess it does discriminate.

15 MR. BILLIARD: Well water goes through an

16 air stripper which removes the organic compounds

17 because they have a tendency to evaporate or

18 volatilize. Then the air and the water treated via

19 carbon -.- that's a way to trap it. And then the carbon

20 goes to a regenerative facility where they are licensed

21 to take the carbon, bake it, they heat it up and it

22 drives the following compound back off again. And then

23 they can trap it and recycle it.

24 MS. NEWMAN: Recycle from Metro?

25 MR. BILLIARD: No. There's a number of

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1 vendors who are licensed to do it. West States Carbon,

2 Carbon Aire. There' s a number that do that..

3 MS. NEWMAN: As to all the leftover stuff

4 after this treatment, the inorganics that are leaving

5 site go to Metro. Does Metro have proper facility

6 treatment?

7 MR. BILLIARD: I think about it in terms of

8 what they are allowed to take, and they are allowed to

9 take quite a bit. And the miniscule amounts that are

10 coming from Lowry Landfill -- you got to understand the

11 kind of concentration you are talking about here are

12 miniscule. The quantities are miniscule. I just don't

13 see it's worth spending millions of dollars to treat

14 that level of --

15 MS. NEWMAN: Where did you say you were

16 from?

17 MR. HERMAN: I was going to mention one

18 thing. John is not working in connection with the site

19 anymore. And that's evident because he was -- did some

20 studies when an air stripper was being used on-site.

21 In fact, the air stripper has been taken out of service

22 and additional carbons units, which are more

23 effective -- I'm sorry.

24 MS. NEWMAN: Who do you work for now?

25 MR. BILLIARD: It's irrelevant.

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1 MR. HERMAN: You guys can talk. It's not

2 that pertinent. There's a woman right here.

3 It's a grand offer. Really, it is.

4 MS. ANDERSON: That's what I'm hearing.

5 MS. SPEAKER: Is there an agreement between

6 Denver and Metro regarding the raw sewage that was

7 dumped into Lowry and what they were -- what they were

8 going to pay for that, if that had to do with this deal

9 that's now going to send this waste back to Metro.

10 MR. HERMAN: We estimate that Metro land

11 farmed about 37 million gallons of sewage sludge. I

12 don't think it's classified as raw.

13 MS. SPEAKER: It's 51.

14 MR. HERMAN: I'm sorry. What?

15 MS. SPEAKER: It was 51 million gallons.

16 MR. HERMAN: I could spend five hours of

17 telling you the importance of calculating liquid

18 weight --

19 MS. SPEAKER: That's not my issue.

20 MR. HERMAN: If you use certain values, you

21 come up with 51 million. I will be glad to give you --

22 MS. SPEAKER: I'm just curious about that

23 agreement and --

24 MR. HERMAN: So that was taken out to Lowry

25 Landfill. Metro Wastewater Reclamation District is a

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1 potentially responsible party as part of an agreement,

2 a private agreement, that was entered into with Metro

3 and Denver and, I think, Waste Management. This is

4 part of a settlement.

5 Now, keep in mind that they can come up

6 with this kind of settlement, but it's up to EPA and

7 the Colorado Department of Health with input from all

8 of you to decide if that's an acceptable alternative.

9 Just because they entered into this agreement doesn't

10 mean that it's going to happen.

11 MS. NEWMAN: So why did the EPA who

12 originally called the Metro a responsible party and

13 called the waste from Metro hazardous -- why is the EPA

14 now condoning Metro's treatment of waste, which would

15 appear not to be adequate since they generated

16 hazardous waste to begin with.

17 MR. HERMAN: I'm not sure I understand your

18 question.

19 MS. NEWMAN: What's so hard about that

20 question?

21 MR. HERMAN: We can talk afterwards or --

22 MS. HAMMER: Some people have been real

23 patient. We would like to hear from folks we haven't

24 heard from yet. I think someone over here had a

25 question.

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1 BOB: My name is Bob.

2 MR. HERMAN: Okay, Bob.

3 BOB: Bob. Are you going to be monitoring

4 the water coming out of Lowry?

5 MR. HERMAN: Yes.

6 BOB: Is Metro going to be monitoring for

7 chemical compounds as well?

8 MR. HERMAN: The City and County of Denver,

9 Waste Management, Chemical Waste Management and Metro

10 will all be monitoring, and we will all be reviewing

11 that information.

12 BOB: Is there a list of what you will be

13 monitoring for, because --

14 MR. HERMAN: Yes.

15 BOB: Are you going to be monitoring for

16 plutonium?

17 MR. HERMAN: There will be a discharge

18 permit that Metro will write, and that will include

19 influent limits for the Lowry water. And, I'm sorry,

20 -- I can't --so there will be a discharge permit and

21 there will be influent that will be monitored and will

22 be available for the public to look at.

23 BOB: What about if the sewer backs up and

24 the chemicals come up through people's basements and

25 people's yards and things like that? Are you prepared

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1 for that kind of emergency stuff?

2 MR. HERMAN: That will have to be dealt

3 with adequately for the EPA and the State to accept

4 this proposal. There will have to be contingency plans

5 to deal with leaks and other problems.

6 MS. HAMMER: Thank you very much for your

7 ' questions. Is there anyone who we haven't heard from?

8 Someone in the third row.

9 SPEAKER: Can you clarify what you mean

10 require? Sort of mumbled over the discharge thing.

11 MR. HERMAN: I mumbled?

12 SPEAKER: You mumbled about the discharge

13 permit for Lowry about plutonium. I didn't understand

14 that.

15 MR. HERMAN: It's -- what I was going to

16 say is that based on the exhaustive studies and my

17 concern for human health and the environment: that I do

18 not believe, all my soul, that plutonium is a problem.

19 So I don't think it's appropriate to be talking about.

20 That's what I was going to say.

21 SPEAKER: If citizens think it's a problem,

22 is it a problem?

23 MR. HERMAN: I do not know. We will

24 monitor for radionuclides including plutonium to make

25 sure that it isn't ever a problem. I'm not going to

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1 ignore it.

2 BOB: Are we going to have citizen monitors

3 there as well to monitor these things?

4 MR. HERMAN: All this information is

5 available at the EPA Superfund Record Center for

6 anybody to look at.

7 BOB: You don't know this?

8 MR. VRANKA: A citizen monitor?

9 BOB: That's right.

10 MR. VRANKA: What do you mean?

11 BOB: In terms of like a police.

12 MR. VRANKA: How so, to monitor?

13 BOB: Just so people like myself can go

14 through and make sure that everything is fair and

15 square.

16 MR. HERMAN: Are you volunteering?

17 BOB: Absolutely.

18 MR. HERMAN: We'll need your last name so

19 we can involve you in the process.

20 BOB: You've got it.

21 MR. VRANKA: I think what Marc was

22 referring to, if there is a problem with those, we look

23 for speciation for specific radionuclides. So we

24 haven't -- we have monitored for them. And we continue

25 to monitor for them. So --

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1 Adrienne, you get to go.

2 MS. ANDERSON: This gentleman who declined

3 to tell us his employer while he was working on this

4 was, I believe, trivializing that this is a tiny amount

5 of waste that's going into the sewer system and, yet,

6 what I believe the public should understand is that the

7 -- this proposal is for this trickling to go on for

8 five years.

9 MR. VRANKA: Probably more like 30 or more.

10 MS. ANDERSON: 30? It will take 30 years

11 to take the Lowry Landfill ground water and go into

12 Metro?

13 MR. VRANKA: Well, it will be going -- when

14 we look at a remedy, we generally we estimate for

15 30-year period, and especially at a site like this

16 where it's a containment remedy. We are looking to

17 contain the waste so it doesn't migrate off-site and we

18 will treat what we can. So it will be treated a period

19 of time.

20 I think what John was getting at was, at

21 least in their calculations, they expect an initial

22 flow rate of around 10 gpm. We've stated between 10 to

23 20. They believe that it will drop off fairly rapidly,

24 so we won't be able to extract as much water as time

25 goes on.

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1 MS. ANDERSON: But your estimate is that

2 that could be 30 years?

3 MR. VRANKA: We don't know. At this point,

4 this was just an estimate for costing purposes.

5 MR. McCORMICK: Curt McCormick. And I

6 oversee the Clean Water Act Pretreatment Program for

7 this region, so I actually oversee Denver Metro's

8 operations and how they implement taking waste from

9 either industrial users, superfund sites, whatever.

10 There's a lot of questions, and I love the

11 public participation because we don't get a lot of it

12 in the Clean Water Act side. I think Marc is a little

13 more used to it than we are. But one thing I can say

14 is that any permit that Metro would develop and issue

15 to Waste Management or whoever the permittee might be

16 will be completely enforceable by Metro. It will be

17 reviewed by our office, and we are fairly concerned

18 about what would go into that permit.

19 Any monitoring data, the permit itself as

20 well as inspection data, monitoring data, is all open

21 to the public. There is no confidential information

22 involved, so --

23 BOB: I don't believe that. I have seen

24 confidential records and I wasn't allowed to look at

25 them.

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1 MR. McCORMICK: The only confidential

2 records covered under the regulations relate

3 specifically to industries and, you know, processes

4 they developed. If you ever run across a ceise where

5 effluent information is deemed confidential, you call

6 our office.

7 BOB: It's confidential.

8 MR. McCORMICK: Effluent information?

9 BOB: Says, "Confidential."

10 MR. McCORMICK: Then how do you know you are

11 denied? I don't know. What I can say is the whole

12 process is pretty open. We don't have anything

13 confidential, as far as I know, from this particular

14 process and this type of permitted discharge. I'm not

15 familiar with any confidential information, other than

16 some of the court actions that have been going on which

17 I'm not at all familiar with.

18 But as far as discharge data, the permit --

19 the basis for those permit limits, which parameters

20 were included in a permit, that information will be out

21 for comment. Any information, any effluent data

22 generated will be available, 100 percent of it, from

23 Metro or from -- I guess Marc's office would be

24 receiving copies of it.

25 I don't know how I would get you to believe

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1 it, but that is a fact. It's stated in the Clean Water

2 Act. That's the place after, you know, when the

3 permit gets in place down the road that you get any

4 effluent information you would like to have.

5 MS. ANDERSON: I just want to point out

6 that the EPA in this region has a pathetic record of

7 doing enforcement on NPDES permits in this region. You

8 allowed Martin Marietta to dump into a public water

9 supply rocket fuel for many years without a cent fined

10 against them until people were dead.

11 There are numerous areas at issue where the

12 EPA has totally abandoned its requirement under law to

13 enforce the law.

14 MR. McCORMICK: I hate to escape out of

15 this. EPA has delegated the -State as, actually, the

16 primary enforcement authority.

17 MS. ANDERSON: That's right.

18 MR. McCORMICK: Under my program, it has

19 not been delegated, and I think that corrected some

20 environmental problems. But those issues aside, we are

21 talking about a pretreatment Clean Water Act issue

22 here. The NPDES permit site with Martin Marietta or

23 whoever is more of a state action with the EPA

24 oversight, and I don't think the state has done a

25 particularly poor job. But that's not relevant to what

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1 we are looking at here, discharge to a POTW..

2 MS. HAMMER: Thank you. That's very

3 interesting discussion.

4 There are a few people we haven't heard

5 from that we would like to hear from. We were told we

6 only had the room until 9 o'clock so this is all extra

7 time.

8 MR. PEARLMAN: Steve Pearlman, Metro

9 Wastewater. Metro won't address EPA enforcement

10 history at all, but I think Metro has a very admirable

11 history of being very concerned with industrial

12 violators that we regulate under the program and have

13 very definitive enforcement record for companies that

14 don't meet our limit. The same would be true with

15 Lowry.

16 . I just also wanted to echo Dr. Demos'

17 statement earlier about opening records and Curt's

18 statements about confidentiality. We did receive --

19 and I don't want to discuss this at length here --a

20 request very early on in the process from OCAW for

21 studies.

22 And I am emphasizing, pretty early on in

23 the process for Metro site evaluation where we made

24 statements of site waste not totally characterized and

25 so forth, and it was certainly true at the time, we

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1 felt there was data we needed to review and we have

2 reviewed subsequently. But we are much further along

3 in the process today.

4 All of that data, all of the reviews, all

5 of the development of limits process have been

6 submitted to EPA. They are certainly available to

7 anybody who want them in my office, and I encourage

8 anyone to contact me. I know you said there was

9 secrecy, but we haven't --no one has called me to ask

10 for data or information on the Lowry waste evaluation

11 process.

12 All of the materials that have come up

13 about Deer Trail and biosolids and South Platte River

14 and so forth, the slides that Joe showed earlier

15 showing you know minimal pollutant concentrations for

16 selected pollutants was really for slide visual

17 purposes. We have evaluated every pollutant we have

18 seen at the Lowry site.

19 . I apologize for not being able to remember

20 plutonium particularly among the many we have

21 evaluated. We will certainly go back and look at that.

22 I have brought an armload of data. But certainly there

23 will be no measurable effect --no measurable effect of

24 biosolids from the Lowry discharge.

25 There will be no detectable increase in any

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1 heavy metals concentration, no detectable increase in

2 gross alpha and beta radiation. I'm sorry, I don't

3 remember the specific isotopes. There will be no

4 measurable increase in any of Metro's regulated or

5 unregulated stream standard effluent pollutants.

6 That doesn't mean that these pollutants

7 don't exist among the dozens and hundreds of chemicals

8 at the Lowry site. It only means that Lowry is going

9 to regulate them to the point where we are riot going to

10 have any measurable effect. I don't mean a 10 percent

11 increase. I mean no measurable effect. All I can say

12 is our data is as open as Curt said it was.

13 Businesses are entitled to get production

14 information under the Clean Water Act but not discharge

15 data. Metro gets calls from time to time on many of

16 the industries we regulate. We share that freely with

17 the public, and we'd be happy to share that with you.

18 MR. HERMAN: Don, I'm going to call on you

19 in one second. Two quick announcements. First of all,

20 there is another public meeting two weeks from tonight,

21 and it's going to be as exciting as this one. And it's

22 going to be talking about the remedial design -- the

23 next remedial design response, the cleanup plans that

24 would be constructed in the summer. And if anybody is

25 interested in what's going on this site, I would urge

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1 you to come, same place, same time, two weeks from

2 tonight.

3 The other thing is I'm looking at the

4 signup sheets, but it doesn't like like everybody

5 signed up. If you want a copy of the responsiveness

6 summary, you would need to be on the mailing list so

7 we can mail it to you.

8 MR. HOLMSTROM: One point is, it was stated

9 our asking for that information was a long time ago and

10 there's been a lot of things that develop. In fact,

11 our information request was initiated --in November --

12 November 19. Bob Kite, the district's manager

13 responded to us and said it is not -- there has been no

14 risk analysis performed by the Metro district or its

15 agents at the Lowry Site. That's No. 1. I have a

16 letter signed by Bob Kite. That's not a long time;

17 it's fairly recent.

18 The other is that Metro district is

19 characterizing the discharge safety limits. It's still

20 characterizing in November. In our information request

21 we asked for any new or updated information. A failure

22 to provide that information is another labor board

23 charge. This is -- this documentation correspondence

24 is appended to a state labor board charge. They won't

25 give us the information.

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1 What makes you think or anybody think that

2 they are going to be straight with the public? One

3 thing that was mentioned, that everything is out in the

4 open as far as Metro's discharge and the air quality

5 monitoring, well, in fact, the Polluter Amnesty Law,

6 which is law in the State of Colorado, is secrecy,

7 secrecy of the information and the pollution that was

8 done. So that's not true.

9 And, in fact, Metro in 1996 used the

10 polluter amnesty bill for emitting 200 tons of sulfur

11 dioxides in the air. If they are going to pollute and

12 come through a loophole that allows them to admit their

13 guilt without being fined, what makes you think that

14 they are not going to pollute and going to be

15 protective of the public in this instance. There's a

16 long history.

17 Metro, in 1989, had a $1 million fine for

18 violating the Clean Water Act, which was the largest

19 fine ever leveled against a municipal sewage district

20 under the act. Where is the satefy net margin there?

21 There is none.

22 Finally, please respond. We want to see

23 the studies. Worker protective studies. They haven't

24 been shown to us if they are there. Everybody said

25 they are there. We asked for them, and Mr. Kite said

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1 they don't exist. Somebody is not telling the truth.

2 Show us the studies. We want to see them.

3 Final thing is, I believe that this whole

4 proposal is unprecedented. Think about it. If this

5 country moves towards allowing all the Superfund wastes

6 to go into wastewater facilities because it's a

7 loophole that allows that material to be spread across

8 the land that otherwise would have to be disposed at a

9 hazardous waste site under different standards, that is

10 something you haven't addressed.

11 It is a reality that Metro is under

12 different, less strict standards than private

13 industry. You haven't admitted that. You've pushed

14 that off to the side, and it's absolutely true.

15 Refineries, chemical plants cannot spread across the

16 land the stuff that Metro is doing now. It's a

17 loophole of the law.

18 And as far as we are concerned, this

19 loophole is allowing some of the largest industrial

20 corporations in Colorado, some of the most powerful

21 interests in Colorado to put their wastes in a loophole

22 situation and then the sludge is a solution they are

23 going to spread across the farmlands, put it in the

24 South Platte, expose the workers. It's a bad idea.

25 MR. HERMAN: I'm going to tell you one

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1 thing. You are absolutely incorrect when you say this

2 is precedent setting. In fact, if you will leave your

3 fax number with me before you go, I will send you a

4 list of, I think, probably between 30 and 40 other

5 Superfund sites that are sending their wastestreams to

6 Publicly Owned Treatment Works.

7 And, I mean --we have guidance that

8 describes how we can decide whether --to evaluate

9 whether it's appropriate or not to send Superfund waste

10 to POTWs. So just the opposite. Is it not precedent

11 setting, it is a very standard thing to do.

12 BOB: How long have they been doing that?

13 MR HERMAN: We will look.

14 MS. HAMMER: I'm sorry. We have a janitor

15 who is really anxious to come in here and clean. I

16 want to thank everyone for coming and encourage you all

17 to submit comments that you weren't able for make in

18 writing by May 22, 1997. Thank you.

19 . (The proceedings were adjourned at

20 9:35 p.m.)

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1 I, ZXDEPONENT-FULLNAME, do hereby

2 certify that I have read the foregoing transcript and

3 that the same and accompanying amendment sheets, if

4 any, constitute a true and complete record of my

5 testimony.

6

7

8 Signature of Deponent

9 ( ) No amendments ( ) Amendments attached 10

11 Subscribed and sworn to before me this

12 day of , 1997.

13 Notary Public: 14 Address: 15

16 My commission expires 17 Seal: 18

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1 STATE OF COLORADO)

2 ) ss. REPORTER'S CERTIFICATE

3 COUNTY OF DENVER )

4 I, Annette Graham, do hereby certify that I

5 am a Registered Professional Reporter and Notary Public

6 within the State of Colorado.

7 I further certify that these proceedings

8 were taken in shorthand by me at the time and place

9 herein set forth, that it was thereafter reduced to

10 typewritten form, and that the foregoing constitutes a

11 true and correct transcript.

12 I further certify that I am not related to,

13 employed by, nor of counsel for any of the parties or

14 attorneys herein, nor otherwise interested in the

15 result of the within action.

16 In witness whereof, I have affixed my

17 signature and seal this 24th day of April, 1997.

18 My commission expires March 28, 2000.

19

20 '/• , .. ^-....Annette Graham, RPR 21

22

23

24

25

BLANDO REPORTING & VIDEO SERVICE, INC. TABBED PAGE

TYPE A LETTERS 121

em 900 $& '<£L £tii& 500 i, Co 80202

am. aqami Jv(diQ-@w inhiCiiailm Jjww %iie feio A ^ . J J wsii uudqs,& % ^io net nz&l oui Laid ana valei vitk bluiobiwm, and othzi LazaidoM waiiz,

cl/ou, TEL NO. Jul 01.97 8:43 P.01

122

9991S t. *uHz 500

S0202

ctyzunan,, am acjoMd c/V\dio-0iQ ibtz+qialin,q JJMIU tyl/adz into di iltiAc& *W& do not n&d oui Land and waUi aontam.inat£c itk blutonium and otnzi kazaidout, 123

Mr. Maic Herman Em 99918th Street Suite 500 Denver, Colorado 80202 Dew It Urn, lyIL ito2 E' wMiifUnUYP Llm . North I

wn 124

Mr. Marc Herman srn 99918th Street Suite 500 Denver, Colorado 80202

Mj vsis is MM ^f^ to [A Lfiij LssW^ fmi lift to I r fotolvtitefimaMfatfmUrtok

Jj &unan

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Co

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// am Miam

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Mr. Marc Herman EPA 999 18th Street Suite 500 Denver, Colorado 80202 Bear M: Sum, to fsfosal to pi I nto et I io not aolwfa fa fo I mat the fiiK petstm of iny fa con

#K 127

Mr. Marc Herman 999 18th Street Suite 500 Denver, Colorado 80202 Dearlklkm, MyJ vote is AGAK tte rB 128

000 $&, St. Sniiz 500 / ,' / * , Co t$0202

\Dzai d\l\i. ( I/ am aqauitt* * ^dw-^'w^*^ wfeiqialinq'' // Jlowiutj $adz into ihzii UMCUL Ws do froi nzzd cm Land and woi&i contaminated with hintonium and om&i kazaiaoii'i waitz.

DU 129

, $500 $0202

^ ^ 130

ooo & i \itti 500 y / x *

Et, Co 80202

[u Jfzunan. U am acjawd &v\dw-&)w uitzicjiaii&cj JLOWUJ *$auz into if v V +r do not ns&d om Land and wai&i ccniaminaizd

Q/ou, 131

P 01

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/ 5-

u 132

999 19*k Sr, Suite 500 o 80202 \ \

J would le to sGj O on recowl A(^M e! pan to ^iCo!f Fund Waste oj a^v kind/ Wo the siudas thai qoes out ! '" V V b the jarm cfaind h easie^n Cobade, J do not want oi^ land and wato4 and ai** contawaled with wm and a I the ot cemcas thahat a^e n e ov^y landt

13 7 133 SPA . #500 Z0202

J kluhulti* /W All m §wvwywiiv tf wyw vrw wrv 134

\i

P / / O4/ P P ( r

cfetttu 135

Mr. Maic Herman EPA 99918th Stieet Suite 500 Denver, Colorado 80202

llj wtei$A&. 136

; o &0202

\Diai d\i\L. cfyzman, U am aqain&i d\l(dw-dw inteiqiaiuiQ Xomii (mtt£ into ,P , i> i riAi [ , i f I f , . i tfaii iliuiqz, *[/¥£ do not azzd om LM& and watei contaminated with bLiiioniMn and otkzi kazaidoub waiiz. 137

Mr. Maic Herman EB\ 999 18th Street Suite 500 Denver, Colorado 80202 Unfit Htm, ^GMff tk j^ lo ft Lovrj Ui fysM 138

909 u,& 500 , Co 80202

U am aqamt J\l\dw^io inhwiaiw-o. Xom-a T/aiX£. fcio ^ a •** J J Wtii u,iuiQ£, % ^o &0£ «££j Jiiz laW ^a bLutobiiito, ana otn&i LazaidoM waltz, / 139

000 - Uik 500 X * , Co &202

U am. aaainttj ^l/[dw-^'w inhiqiatmaj j Jlowmj '(yadfc into ikzli iLiulaz.IT ^14 do not nzzd ouz Land and walzi contaminated wiln, hLti>toniiLfti and otnzi tiazaidoM wads* 140

C%7,fl J/fifllMtt as? 909 $

ET, Co 80202

Jj am- aqami JH[dio-@to intz-iGiakwq jC am mo J -r ij J lMli dudqz, % do not n&d OULI Lad, and m vim biiiionim ana otnw LazaidoM 141

Mr. Marc Herman EPA 99918th Street Suite 500 Denver, Colorado 80202

tfsi$A&. fa into tit MetM & 142

Mr. Marc Herman em 99918th Street Suite 500 Denver, Colorado 80202 143

999 18m Sf. Sufe 500 Denver, Colorado 80202

J would like to ao on recofJ ,A(^ AJ.MSI tke plan fo incorpc^de Fu^cl Wasfe a[ a^ kM/ ^o the sbdge that gaes our e arm ground n eastern o o, do not want oitf lan ancl wata* and ay contaminated with plutonlum ana al the ome/ toxic ckemicals tnat ai^e in tke Lowi^v Lanafi! 144 zw 999 $£ <& ^Utie ^OO

« £1, Co

am- aqami dl/[dio-@w inizujiatuiq Xowm ^am Inio * * . / J flM waUi ccniamuiaitd vilh, hudaiiwrn ana otnsi \iazaido\ii 145

900 is t. tii& 500 zi, Co 80202

jj am aaami J\!(dio-Qw inkz-iGiaiiaq Xowiu tyam into

Mr. Marc Herman EPA 999 18th Street Suite 500 Denver, Colorado 80202 Desf It. Umm,

M>i tlo I ml Ik of mf fwilf to k s, 147

t& 500 *

\L, Jfzunan. i)rt am aaawM, i dy\Fiio-^wM i O> iniiiCjiaurio• L " jLO(nnfl tt bLiitonitimL?* L ' and1 oth&iif nazatdoMf 1 waitz.L 148

4zman,

500 *

Co 80202

i. ctyzman. U am aaaind d^dw-@w inhwamo Jlowi ($oAi£ into - W if V thdi itudz, fyVz do not nzzd cm Land and wai u mm buitonilini and otnzi hazaidoM wads* 149

900 '$& £1* Stib 500 zi, Co 80202

am Matedj tMdw-tfw—* l^maiinaj j £ww

, Co S0202

f/ am aqami eMdio-@w inkiGiatim Xoiwi tyade, Into ^ . j t tf u yisii dvdqz, % ^/o ttfli nzd ouz Laid and wais,i ccaiatriina u vim hLuiobinta, and othzi nazaidoM waltz, 151

900 uit* 500 , Co 80202

aede,, o am aqamiJ Jl/[dio-0io^ inhiefiatim-J u % do &oi n&k oui LoxA ana vim hiUitoniiLtn and othzi nazaidoM wads* 152

Mr. Marc Herman 999 18th Street Suite 500 Denver, Colorado 80202

®kGMtk^to$lm]lMil$iftMt w r Mrfifmt tk

o 153

Mr, Marc Herman EPA 99918th Street Suite 500 Denver, Colorado 80202 DwIkHm, My Kftfth&Mtk Imria i*h ', jW/mrt % MJft 154

Mr. Maic Herman EM 99918th Street Suite 500 Denver, Colorado 80202 Bar M Homy 155

Mr. Marc Herman 999 ISth Street Suite 500 Denver, Colorado 80202 MMm®, il to pit Lmy Landi Super Funi $e Mo tk Met® liosd wtfttm r. Noiiol » 156

Mr. Marc Herman Em 99918th Street Suite 500 Denver, Colorado 80202

Mte fo to llto sbfa Iio M mlftlom i as/mfa fo to I ml ik 157

%M*

fe 500 i, Co 80202

fl • > M L /2 • L L> 0 ' ' > it am aaamttj &v{dio-vyw~* wkz'Mati&Q.J v JLcwiutj uiLdqs,f *W& do &oi nzzd OILI Land and waiti biuioblwn and dn&i liazaidoM 158

Mr. Marc Herman EPA 99918th Street Suite 500 Denver, Colorado 80202

Jtitpi

$G*£„, iI vdov uvMt vstu yitMssim lu isjj My aalwfa Mrdo/mttiefiliiflmMmofwMlytok 159 em 500

U am. Miamit) eM[dio-0io—^jiji teJztQiati/M Xcww/j ^// into £\dcfr *IV& do not M&L OLLI Lead, ana uraizi y viik hudonim and oth&i iiazaidoiti waltz,

D&ank

9)105" 160

Mr. Marc Herman EPA 99918th Sheet Suite 500 Denver, Colorado 80202 it ito Ik i 161

999 #500 $0202

JAn»V ud.V^ r^T^Mutr krr prtl' W/ *r?par »rVrru. vtu *ry. ft 162 , $500 $0202

Mm^ k

L 7

vrr*/ 163

}J\arc 6PA 999 18fn Sf . Suife 500 Colorado 80202

would 8

i& 5X5

\l

Cmslmli u~—/ - 165

I/

Oi/, / / / 1 Co S0202

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Mr. Marc Herman EPA 99918th Street Suite 500 Denver, Colorado 80202

Mp vote is AGM! tk pitjml to pot Lo Ato Ik Mto ibfe

JVlA 168

$500 $0202

ik mmvpHwLtv

(i »rv ivw i/i fa/1wjw »r/illw ikttih 169

w ctyzvnan

itt I/ IMftI *»rH• i

f I. /, / si.I t n i) i r W^L i^^feiuuk^

j 170

Mr. Man Herman 999 18th Street Suite 500 Denver, Colorado 80202 Oar It San tyw&sA to ft Imy Ui Svpet Fund 171

Mr. Mm Herman 999 18th Street Suite 500 Denver, Colorado 80202

IIWMVmK UMVmtn tint m, i

-. 6. & s <7 172 em 900 < 500 , Co

If am aqamiy J\l(d.io-@w*• whimaiin-o.j j £o®m fylfa&i& into wsii ifaulqs, *~Ws, do noi nud oui [arJ ana txraizi V vim bhitobim and oth&i liazaidoM

okd 173

Mr. Marc Herman 999 18th Street Suite 500 Denver, Colorado 80202

IL ij M sto ik > ^ fo I wt tk of sy fmty to k 174

909 $ a, Co 80202

"Le am. aqam J vitii aLdqe, % do not nidi OILI LarJ and vat& u vim hLuionlm and othzi hazaidoM waltz, 175

6PA 999 18m Sf. Suite 500 Denver/ Colorado 80202

iv1 w.V I I 14^* » » »V1»

J would ike to

yn 176

SRfi

\i

xr / n /) I/ do'ndw^ ife i^cm r 177

P 01

999 J#£ fiSt

» IW W /V

'do ii. di^k mm U I 178

it

/ / s \DEMJEI, Co &0202

fl ' > ^.(ifl I /3^ » / It /' (I/If I ^ I LI OM agaiMtJ &y{£tw-^iw~* Mteiw-aiwMJ J J^owinj *W0AV- wr.n iYidi liadqz. 'Wz do not nzzd ouz Lana an,d wat u min btliioniiifc ana otnzi iiazaidouz «

^Jhank tfjou, 179

Mr. Maic Herman 999 18th Street Suite 500 Denver, Colorado 80202 D&rM/fam,

: Norm I ml

/ 180

939 ' vzi, Co 802C&

D am- aqami dl/\dw-@w tetz-iaiatuiq JUro e inic * . * . d J u,u4q&. *W& do not K&a ouz Land and wate V vim hiaioniitin and omzi LazaidoM A 181 , #500 *De*tw,(l* $0202

^rud.r WVIrrMut.' r krr . in

Wfa

iM fifkty \rv »»w v v'wwr

x/ 182

ML Maic Herman em 99918th Street Suite 500 Denver, Colorado 80202

is MMte f^ to pt Lmy M ^ fit 183

Mr. Maic Herman 999 18th Street Suite 500 Denver, Colorado 80202

i / // 7 / j j 11 ' * /*/' imluMATTfl liuijc.FninfM IWI nf\ wfiffl wmuliulwwH/Qftr rt///r/)/)////W IE//J wj/WI7 lOQu,//)/)/7 all)Qlf t fl ' /* Wfnfl mmpuuwuubfiitMP opnpiyfrnnc nfI/I UIJnw

?/

$6 184

Mr. Maic Herman EPA 999 18th Street Suite 500 Denver, Colorado 80202 Dear Ik Hsnw, fylioMmtpMmitimj I ^lfolW$k!^R$W$MQ{®]kl$jtQk 185

Mr. Maic Herman Em 999 18th Street Suite 500 Denver, Colorado 80202 Deifttlknm Me into the Met and water, Mr do I wM the m of iny finiiy to be 186 $500 $0202

h rM wSto i /V, Mttk k

J

tkttil 187

999 18fK Sf, Sure 500 Colorado 80202

\ flowon, J would l!* and ay contaminafed witl\ piwtoniwm and at tke oi toxic chemicals tnat a^e in the lov^y landfil 188

(aia

X , fl~o 802020,

, ctyzman. ( U am aaittd•j ibid dfiriw-^/w^/dw-io-^ ittiiiqw.un-0iniziciati&J J J^o®w,J^owiuj '^woA-ti-*m into thzuif ' dudqe.f J VC\W&M do1 notL nzzdi ouz Lanaf 11 and1 ixtotei ccztomuiatzdL ' L 1 , • p P i , / P p f with bLtiioniain and otkzi kazaidont, waltz.

p c\f 'you, 189 em 900 '$£ <£L £uiit& 500 > £0202

3 am- t/aqami dv(dio-£iw^ inhieiiatin-o.ij j Ji :htii $L\jJicp, ^Ws, do &d fisza om Latzd ana , V yiin, btntoniwn and olnzi LazaidoM 190

Mr. Marc Herman 999 18th Street Suite 500 Denver, Colorado 80202 Dffl Mr. Hman, M nto ik Itto sUp 191

Mr. Maic Herman EM 99918th Street Suite 500 Denver, Colorado 80202

sto to Mlto sUp I A M mipUm i iij'U lii, 'isdwatff. fytolisttoM^gaaiimf/sffa^lDk MY®

\/t

*'j. f&/#3 192

Mr. Mane Herman EFA 99918th Street Suite 500 Denver, Colorado 80202 193

999 1WK Sf . Sufe 500 Colorado 80202 /vV» Herman/ J would BKe to go OKI record .A£i.A J]\)5T ff\e plan to incorporate Funri Waste o[ ahy kid/ Wo the sldge that goes out he [arm ^ou^l h eastern Colorado, J do not want our land ad water and air contaminated wnli pidoniuw and al ike of!\er toxic cnemicJs tnat are in the Lowry landf I 194

Mr. Marc Herman EfA 99918th Street Suite 500 Denver, Colorado 80202 195

999 18*k ST, Suite 500 Colorado 80202

J would le te qo on K-cowJ A6/J/6I the plan to ktfp*afe *J Fund Waste of aw kind, Info the siudqs that goes out i *" v/ V • \ i to the jarm ground ir\ eastern Coic^ado, J do not want ow land and wattf and ay contawnoted with pUonsw and a I the to}dc d\emica!s thai a^e in the bw^y Landfk 196

P 01

SK/I i, \u 500

_ 07 /"TTJ?. r^W^ Jy de * fo %fe fcfo 197 ctvlaw !/ ^

, o S0202

i J\l\i. cfy&man.

U am aqaindJ <^\/{dw-tyw-* inhiqiaiinqJ j Jlowwu ''/Wtti- into Itozii liuacz, ^wz do not nzza oni Land and wafai ectztaminaizd with, blutoniiLm and ouin kazaidou^ waltz, 198

Mr. Maw Herman EM 99918th Street Suite 500 Denver, Colorado 80202

vote is AGM! tk pmpl to put Lowiy

999 '13fk Si Suite 500 o 80202

J would 8

S^cereiy,

DR. JOHN W. HANKS 3955 E. EXPOSITION AVE. • SUITE 318 DENVER. CO 80209 200

Mr. Maic Herman EPA 99918th Street Suite 500 Denver, Colorado 80202

Sd/ 201

Mr. Marc Herman Em 99918th Street Suite 500 Denver, Colorado 80202 Dear tb Hem,

itoteMtosUK* I to to M iiltom ii m/ tat•' & r fir iblwttk MIR generatm of ay famify to k

fa 202

J\l[au

/ooo / / . \u 500* \benuEif Co 80202

i. Jj-zunan, J am aaitttt J^dw-Ww inteiefiaii&q JLowni (^mii- into z do not nud cm La&d and waizi contaminated with huitonilLto, and otnii liazaidoub w 203

Mr. Maic Herman EM 99918tb Street Suite 500 Denver, Colorado 80202 DwIkRm, mlwtfei: Mrdol 204 em 900 '$&, <£t. £tik 500 ti. Co $0202

3 am. aqaind

\ A t-- 205 206

& 500

Q am. aciami cMdio-@w L^hi-qiaiinq Jjww tyam into A * . . J J J l,htii dudz % do &oi K&J, oui LarA and mi&i vim bitiioninta, and othzi nazaidoM 207

Mr. Marc Herman 999 18th Street Suite 500 Denver, Colorado 80202

Mrtb/ 208

/ / /

, Co S0202

n

Jhank * \jo\L, 209

Mr. Maic Herman 999 18th Street Suite 500 Denver, Colorado 80202

pmni s sj oo ar, $wiion$ of sy Uly to k 210

900 j-i, o 80202

ast nc am- aqamiJ ^ Jii^ Lad ana tffai&i ccnimuiai&d atil dnw nazaidoni 211

» I ». W /

]/ fig pdKM fo %xk fizfo f w& no,* / / / u I

£ t *~ Jj

^7 f cu. Ott a O- 212

Mr. Marc Herman 999 18th Street Suite 500 Denver, Colorado 80202 D®r Mr. Herman,

i ii sp ftf 213

Mr. Marc Herman sm 99918th Street Suite 500 Denver, Colorado 80202 Dor'w am 'tof^ to ft Lmj LailSafy fai

V iIAaot r, fordolwtfit. 214

Mr. Marc Herman EPA 99918th Street Suite 500 Denver, Colorado 80202

Noriol 215

SKfl

I/!' I/ /• ~ / /r / M^'ndpo^ T / / lil J I 216

Mr. Marc Herman m 999 18th Street Suite 500 Denver, Colorado 80202

— s isi wj 217

Mr. Marc Herman 999 18th Street Suite 500 Denver, Colorado 80202 D&rtkltm,

MV fit«Vb L> : Mr do! 218

999 18m Si, Suite 500 r Colorado 80202

Ato "Herman/ J would ike to GO on record jAC.AJA1ST Me Dian to Incorporate \J ' * ! I Super Fund Waste of any land/ info the sludge that goes out the [arm ground in eastern Dorado, J do not want our land and water and air contaminated with plutonium and al the other toxic chemicals that are in the lowry landfi

Sincerely; 219

' S S ) o 80202

U am a-qaind dv(dw-&jw^*^ iniiiqiaiiriq ]JQ®I\\ *$a&ie, into

iiiutof.j H4 ^ ^o£ A££^t oai ioJza o mtill fbudoniUM and otnii kazaidom waiiz.

*U&ank Q/ou, 220 em 900 $& £L *&& 500 i, Co 80202

"beat // am Miam ioio -MioM AWW am o vim hLutobiwn and otn&i LazaidoM 221

300 lStk £1. 3 lute 500 i, Co 80202

LI(1 am oqainAt' i &Y\£,tw-^wJit ' & tatzicjiaurLQ• L " j^om-ii

3^, 222 em 900 < nik 500 , Co 80202

[) am. aqami*/ dv{dio-&w** fefc-iowiuMj j X'ouni/j fcio diuic^, % do &ot ns&L oui Land ana watei V vim biiiionim mi dnzi hazaidoM 223

/•S/'Sr-l :>uu o 80202 u J would IKE to QO on f*eco^cl . •J . Wasfe of a^ kind/ ^fo the sludae that qoes our I *• ' 'v' W to the [arm grcwd b ^OSTOT ColciAada J do not wawi cu/ land ad wato4 wwj or cwipwwQtecl with faarm and a! the o fejdc chemicals that a^e in the Lcwy 224 em 909 / <. u,& 500

/Wei,

^mnoxij am- aqami cMdio-Qw Lnki-qiaiin-a Xoiwi l Italic inio J ~* J u

cty&vnan em 909 $ , Co

Jjzwian, am aqami J^dio-^w bhiqiaiwq Xovw tyfodz Into J ** j V

// am. aqami J\l[dio^w tats-iqiatuiq J&wiu ty sit into * ^ ij (J J A/U^e.u tftV& do not tx&i oui Laid, ana mi* viiL bintoniwn and otn&i nazaidoM

cl/ou, 227

QQG 500 XXX *

o $0202

. cfyzunan.

U am. aqaindj dndio-tyio^ intziaiaiiaqJ j Xomnu *$adz into ihdi z do not azzd cm Land and waizi cc&iomhiaizd mm pM,tonium and otkit kazaidoui wailz. 228

P- p / O\iu Ou.U\ 1 'i£ L' .V

Lofl« ac

( U am a-QoMdj dV[dio-v4w inizwaibiqj j Xomnj mdi. into j i£. *ws, do not XZL& ouz Land and waizi cotziatninatzd wiik bLti,toniiifo am otnzi- kazaidoiti 229

Mr. Mate Herman sm 999 18th Street Suite 500 Denver, Colorado 80202 Dwltlhm, 230

. $500 $0202

rrf

w

P 0 1

S&l 999 $& £fad, £ U& 500 'Jbsnuu, CcLonado &8C2.

M \(

/ i) nd tiioii ik jidwsot fo y &tmm %dz izfo 4- / / 232

900 i \ub 500 , Co &&(&

ctf&man, am- Miami dio-tfio L^zicjiaiinq jw Into " ^ . * . J do not wdi OULI Land and wais win hudoi^wai and otnti liazaidoM 233

999 Si. Suite 500 80202

J would Ice to QO on record A6AJ/\!SI fye Dian to incorwafe c/ I i p# Fund Waste o[ any KM/ ^ the sl^e that goes out to the [arm ground « eastern Cdorado, J do not want ottf land and wafo1 and ay confaminafed with pLrfonium and al tke d toxic aiemicals tnat ai^e in the Lowv LandfI

u 234

cyvunan

VWV

V ibdi iLuhp.j tfft/s, do not &zzd cm La&a and txratzi ooniaminakzd with bLuioniam and dnii hazatdoM w

J^,CcKA ^2^ _ 235

Mr. Maw Herman EPA 99918th Street Suite 500 Denver, Colorado 80202

«$MV UM\JInto kJLlVfa ilAWAVMfhndniloR LUWfrVI Af/ln t*V ^Jt/fnrf It*HAIrwant I/IMVUJ&IUmminm AAAin iiljm ralim of my family to k ItofrVa, 236

em

, Co 80202

Jjzwian, fl am- aaami J^dio-^io ints-iGiatiaq Jloww fyfasfa lnic> A " "' " . - . ^ J :Lii i/iw/^ % ^o not «£^/ oiiz IflW W «7a££: contaminated V vitk bliiionim and offest LazaidoM waitz,

590 237 238

999 18f *. fe 500 Denver, Colorado 80202

»• « J J woiJcl le to oo on recowl A^A^SI tke pb\ to incorp^oie

ofi CM'-V kind' / ^fo the SwdoV e thatw aces out c the arm grow w east^n CoWado, J do not want ou/ land and wate^ and c# conbrninaied with piutasw and a! the oi ic chemicak that are in the Lowy Landfil

127 239

Mr, Marc Herman 999 18th Street Suite 500 Denver, Colorado 80202

tyII tie2 B' MmfifUTUrVFJ to i i/i fa i*fa TnQ 9' r.v uiwinn I *Juvur thm 240

999 18m Sf. Swfe 500 Colorado 80202

*? 1 1 H i I A/* A~fX)£T .! i ( « J would Ke to Ua o on recora •n u. •AJjx * D i m• e Ioian to rrt Fu^d Vlfesk of any KJnd/ info the skbe that Qoes our \ Ir ' J U

arm a/ownu d « eastern Coiocada J do not wawj" ow land and watec and ar contaminafeq wih\ plMtoniMm and al tke ofna* ^c cnemicals faf ore h the lowy landfl 241

Mr. Marc Herman 99918th Street Suite m Denver, Colorado 80202 Dwlklbw, 'iMUfflten l to fl Lowr i $r (k I mt tk futile jeMioos of ivy Uty to ke cm(4Jh ' '' " "' 242

Mi Mate Herman 999 18th Street Suite 500 Denver, Colorado 80202

tV tf I A Mm ft an/vats Mrdol to" 243 em 999

o 80202

LI am- aaami Jl/(dw-@w idziqiatinj £wy tyasiz into tLti duJqz % do not n&k OM [arJ and erak& V viii b[u.to&im and othzi LazaidoM 244 em 909 art, Co

// am aqami c/lf(dio-^w inhiqiaiin-o. jLwtu T/aiie t/ —* J v u Wtii dudz, ty/& do not ftzzJ, oui Laid, and vim biuioniiLto, and otn&i tiazaidoM

^0/03 245

em 909 jStfi £t. tSiuk 500

E*; Co

am- aqamt J\l[dio^io ifiiziqiatwa Xcww/ T/aiie inio J ** 'J J a do &ot ned, om LarA ana wais mm biidonlwn and otnii LazaidoM 246

900 • <. \u 500 *i, Co

// am Mpixid & into v s, do &oi rxd, oui LarJ and vitk bLuioniwn and othzi LazaidoM waste* /

A 247 em <£fc <$\dl& 500 f Co 80202

JJ&MMII, $ am- aqami J\!\dio-@w fefe-Miait/M Jloanu tyfadz into u -'•vuJ ultdqs, % do &ot nzd, oui Land ana waist ccnlamln V hiuioniiLto, and olnzi LazauloM

a&ii cl/ou,

y.{3*i 248

G¥[au

b 500

, Co

am aqaind

O 249

900 > i*ti* 500 , Co S0202

s into $ am Jaqami - i £jJw« % do &oi w-di PHI Land and wate u vim hLuioniwn and otnzi LazaidoM

QLuzfc 250

h 500 , Co Sazoz

ff am. aqami J\l(dio-@i-Q inkiqiaiinq £o(m tyfam Into ~ U * * ** i &Jqe, % do not ntd oni Lard and araizi eoniaiMMt V yiti tluionim and othzi LazaidoM 251 em 909 jM, Co £0202

am- aaami cMdio-@iQ inhiqiaiinq Jiwtw T/a«5 few i/ ^ V t v " ^tzzii tLJs, % ^o ttoi /2fi£^/ oiit £ajw/ fljw flrafs: contaminated yiih hLuiobiwn and otkw nazowtoM 252

i^L 500

/I/!' I/

^ I! I J

amjm 253

Mr. Marc Herman EPA 99918th Street Suite 500 Denver, Colorado 80202

AULHSinto feUffa. ITAVUVMtfm UlttvLviMw. A IfaW [/ 254

P 81

SRF\

'\*wr fi i /> &. . . I"* . r /./->„/( fl ft / f U OC,,_ _r if rk /4u^2i / fo iiy i oixheimd $tik fcto fe dtiwkif 255

Mr, Mane Herman 999 18th Street Suite 500 Denver, Colorado 80202

/ J. m is mfjwJjii 256

999 18m St. Suite 500 Colorado 80202 U it

J would Ike to (QJ O on record* A^AJNSI th' e! Dian to In I D# Fund Waste of any kind info the skbe that qoes out I ! tr ' J U s ! w/\' ^ e [arm g»uound 'I A« eastern r Loiorado! i , "Jt !^ o not wan«t our! iand and wata4 and as* confeminafed with plufonl^m and all Me otna* toxic d^emlcais tnat we in the lowry Landfl 257 d\l[aia ctyzman

QQQ $& Si. Suits, 500 , Co S0202

\Dzai <^v[i, Jj-zvnan.

V am oMauidti dv\dw-(fjw^^ iztitqiatinqff •§ LQWW.»j *Wa&tz into i uudqz. tf/Vz do not tezA oui Land and waUi coziaminaUd mm huitoniiifti and otnzi kazaidoM 258

ie. 50* 0 Co 80202

ctyzunan.

U am aqai&j d dv(dw-&i-^ w fatzwtaklni/ jq JsOiwtu/ tyl/adz into Ihzii diidqz. ^wz do not tezd cm loxia and wai&i contaminatzd mm fwtotiiwn and otnzi \iazaido\M wads* 259 trust $0202

f. rv fe tk

i it mwv YWWMiM* wwmviffc^W/hv M I 260

999 i»K Sf. Sufe 500 Denver, Colorado 80202

J would like to go on record y\^.AJj\lSI tke plan to incorporate

& Fund Vv/aste ofI any*- kind' info the skfov e that qoev s out , ,\ f S* , /~ i , i n « , , i ! tap\e [arm ground « eastern uto'ado, J do not want o^ land and water and air1 contaminated wltn plutenium and al me oi toxic chemicals tnat are in the towry La \n 261

Mr. Marc Herman 999 18th Street Suite 500 Denver, Colorado 80202 Dwlttim, 262

SPA 999 18*k Sf, Suife 500 Denver, Colorado 80202 u

J would ike to ;aJ o oh record ., the! oan to korawaf. e Waste of any kind/ Wo the sludae that qoes our i *• ' \) V to the [arm h easiei*^ Colorado. J do not want ou/ land and wate^ and ai^ contawinay with &m and ai the fejdc chemicals that are in fne lov/y Landfil 263

Mr. Marc Herman EPA 99918th Street Suite 500 Denver, Colorado 80202 at i war.

intoJUt'i/ tiiVfa jLtAVULVMehn UAttvLviMM AIdn W U\J*ntf ffHJJ*want LUkHVLUVUJ.nhmimi UAin AJilfme 264

\i& goo Scece.

\i

• f I IM i o ou vww Hfe^ kotn

% JlLj 265

Mr. Maw Herman 999 18th Street Suite 500 Denver, Colorado 80202 v It Sam

?ft Ji////? W UWnnf ffMXIfwant nlitiL/4tfHj V r. Nor do I w petitions ofuy 266

Mr. Marc Herman 999 18th Street Suite 500 Denver, Colorado 80202

tkfKfmltopatLo^UiS^M

j,u IdoMmtpUmiivUaki * • • Mdwater. fotolwttkiiKm^dwUytok

L

Mr. Marc Herman EPA 99918th Street Suite 500 Denver, Colorado 80202 Dot Ik tan to put Lowry UiSf Fund *, it) fa MBto sMjp IdoMMnlpUnmii) c fofolwtfal^im^JmUytok

A 268

SPA 999 IMSt $500 $0202

Aft u vy \^Hltktk 269

Jj--zman

QQQ i St <£u,itz 500 , Co S0202

. ctyzman. U am aoaind &v{zkiQ-£yw iniziqwiina Jlourw , into if if if V dudi.q % do &ok nzza oai Land and mlzi

m ibLatonium and otnzi hazaidoM waitz. DU v 270

999 $&, Sfad, Aife 500

t mi /I I/ /

0 fl n f I Itl P P ^ *" fabd^ II 111 U I miIT. til

VI2® / 271

)\Aarc "Hemon 6PA 999 18fK Sf . Sufe 500 CoUado 80202 jvV, flerman/ J would s

em 999 '$& <£l> *$tib 500

Zl, Co

A // am. aqami

em 900 < & 500 zi, Co

j am- aqami dVidio-^w inti-iqiaimQ Homu Hfeire into ^ 4/ ** j U \htii dudqz, % do &oi nidi QU.I Laid, ana (xrai& u vitn bLuioniwn and otn&i tiazaidoM

Jhannr?/' P 274

999 13m St. Sufe 500 Colorado 80202

it

» II I. J would like to go on record /\^.A JA1ST f Ke plan to Fu^d Waste ot am/ Kind/ Wo the skbe that qoes out \ tr ' (J \J afm g^ouhd in eflsiem Colowdo, J do not want ot^ land and wab1 and ar contaminated witli piutonlum and a! ti\e dhp toxic cnemicals tnat a^e in the lowy Landjl 275

Mr. Maic Herman 999 18th Street Suite 500 Denver, Colorado 80202

# I fa M wt fm i $i io I wt the

\- • s. \_ 276

999 «tk Sf . Safe 500 CoUado 80202

J would B

JJwnan, into ~ff m."' ' aaami Jl/[dio-@w—s inh do net n&k OILI and mit vitk hLuicftitito, and othzi hazaidoM 278

909 . \u 500 ET, Co 80202

// am- aqami J\!(dw-(2w Lnhiqiaiino. Jjwui *Wadz into tj —* j u */ do tioi nidi ouz Land and waist cciiiarriinai vim hliitoniiifti and otkzi hazaidoM

7 p n f azk (t/ou, / 279

50* 0 , Co 80202

,. Jfiunan. Ju am aqaiiid dv(dw-@lw iufaiqiatbiq Jtowui tyl/adz (do J sJ J J ihdi uMaqL W^ do aot n&d oui L&ka and waizi with biiitonium and otnzi hazardous wads*

< < .—-. ... J, v^' 280

900 $ t. *iufe 500

El, Co 80202

Jf&wian, am- aqami V[dio-w mhicmtina owiu {Watti Into J ^ V V J do not nzdi oui Land ana waiti ccntaiKin,ai&d vim biuiobiwm, and dnzi nazaidoM 281

QQQ . tiz 500

$0202

U am aqamtj dl/{dw-@w"/ int&iqiatinqj j JLoortuj %iX£. i&t-o ihzii dudqz. *M4 do not h&a am Land ana waizi contaminated mm blM,toti,iiini and omzi hazaidons, wads* 282

uife 500

/! I/

( . o i) do'nd totfaxk Ik kdim io •anAt

_3 283

I/

I (11 / / fo 284

Mr. Marc Herman 99918th Street Suite 500 Denver, Colorado 80202 Dor It Bom, rtiWffi & iito te Mto sUp Ho M m 285

999 tMSt $500 Owen, $0202

! in

m 286

Mr. Marc Herman EPA 99918th Street Suite 500 Denver, Colorado 80202

n/7//j /«//! /A/J f wvw/r iw\J//////1fir titv 287

&v (aw /

/ /

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, cfyzvnan,

Jy am. 'aqaitidj ^y[dio-^w intiiqiaiinqj j JlowiuJ ^Aadz into dtiaz. *W& do not tizzd oni latia and watzi caiiaminatzd u mm bttJitohilLtti and OULZI kazaidoitt

/ 288

Mr. Marc Herman 999 18th Street Suite 500 Denver, Colorado 80202

to tk SMm $M$, I

ML Maic Herman sm 99918th Street Suite 500 Denver, Colorado 80202 290

Mr. Maic Herman 999 18tb Street Suite 500 Denver, Colorado 80202 Dear Ik Mm,

'otvfa ^br (h I

OO^DO^

Bo So 291

Mr. Marc Herman 999 18th Street Suite 500 Denver, Colorado 80202 Deulklbttsi, 292

em 909 500 j-1, Co 80202

MI aqami d/(dio-&w l^i-qiaiim Jiwtu ^ */ —^ if tf J :hdi *Ldqs, ^14 ^0 not n&d om LatiJ, and wate V viik hlUitonLujn ana 293 «

, Co 80202

dm. Jj-zman, , i M , /o. . L i> n fiti i • i am aqamt d\/\E.tw-^/w uirnqiannqJ Mo^m *wa*tz into P , P f (lAl j . ! j> I !

(j and othzi kazaidont, waltz, 294

Mr. Mure Herman 999 18th Street Suite 500 Denver, Colorado 80202

to ft Lwiy IM \ I A not Mjillom ii sfixxf air,

331 ^, 'Co. 295

Mr. Maic Herman em 999 18th Street Suite 500 Denver, Colorado 80202 D<ttm, ft&iato tk Meto sbjj& /do sot mfiimm is MJ n an, t ^iMMk^mjm^md^UjtQk 296

999 18fK St. Suife 500 Colorado 80202

J would ike to go on record /^AJA5I fke plan to inaroomte e^ Fund Waste o[ any kind/ ^b ^ sldge thai goes our tke [arm ^ound i\ eastern C(to*ado, J do not want ou/ iand and wate*1 and as^ contaminated with putonium and al tke otney1 to)cc ckemicais tnat are h the Lowrv Undfl

Sincerely, 297

999 1#K Sr. Sfe 500 o 80202 nf i J would ike to oo on feccfc! A&AJA6I the Dian b incori Hfeste of any kind/ ^fo the skips rh^f qozs ' ' • V to the [arm gwwd ii eastern uoic;Aada J do not wxti ow laruJ a^l wato4 and ai^ co^fc^inated with pLtawi ancj al the fc/xic chemicals fnat a^e h the lov/y

/> ^ c? 5 298

&\/(au

900 < \* 500 *t, Co 80202

3 am- aqami dv(dio-&w fofe.Mio&iM ^cwtw {Wati& inio V v V I*

* li iiiu/ *$k do nd n&a oui Land and wai& ylik hLuioniuJn and otnii LazaidoM 299

Mr. Marc Herman EPA 99918th Street Suite 500 Denver, Colorado 80202

it i ' j/jjnffVTjt

Mrm Ms MM tot fm of ® of my Utyto k

31* 80(05 300

Q & St. tuz 500

, 6> &202

\L. oj-wnon. 1J am- aqauid Jv(riw-(3iw iniziqiatbzcj xoan-i/ ^Nadz into iteii $Uidq& ^14 do not nzzd cm Lana and waizi coaiaminatzd mm hilJitoniiJini and otkzt \iazaiao\M wadz.

CM ty*. 301

f

f Co S0202

(l U am a-qawAJ ^l[dw--^w-* inhiqiaimqJ J Xomnu /miz inio Ihdi iliulqz.t/ ™jz do not tezd cm Land and waiz mm hLu,tobiMn and omit hazaid,o\M w 302

500 EI, Co 80202

// am- te£o . vtdi £wqs« % ^o ttof ££&/ «^ii^ IflW fitta V viih, budoniVM and dn&i hazatdoM 303

M. 8M

&K2

lit !/

tfrM *s-Hv^ /M

/ /

ammi 304

Mr. Mm Herman EfA 99918th Street Suite 500 Denver, Colorado 80202 ta Mr. Herman, 305

<3/v[au crj-zwan

QQQ i St. \u $00 *

, o $0202

din*!,, oj-wnan. am again&t int&upatuiq Xom.ii tyjadz into diuLz. % do not rx&a QULI latia and waizi contaminated mm blM,toniiim and otnzt kazaidoM 306

Mr. Maic Herman 999 18th Street Suite 500 Denver, Colorado 80202

WA&P ntn ill? Mpfff) CtfaJvp ]&(} rni wfiflt nfrtffwiiin in M t/wf ar; j HtiJlv iiilv lilv IrlUlU MUU£bo 1 UU1M Waul rUMUUlulil ill M/ liAAL• all, lailifa Mr do! 307

990 $

am againd J^dio^w uihujiailnc) Xwuj tyfaiie, int {Jli&li dtoicp, ^W& do not wdi oni Ltd, and u vith, budoniwn and othzi nazaidoM

1 308

Mr. Maic Herman em 99918th Street Suite 500 Denver, Colorado 80202 309

Mr. Marc Herman sm 99918th Street Suite 500 Denver, Colorado 80202

£0IQ3 310

, Co 80202

f/ am Miami , into *~ iij duJqz, % do not nud ou.i LarJ, and uratei conimhiaitd V vith, biuiobim ana othzi tiazaidoM 311

'00 / / / ' -50202

ctyiman. (1 • t M i /O. , i " fi ftM < ' ' LI CM QMQMtt &V[£kW-^W Lttt£l$Z£tinO JL,Q(PW, *W&4t£ UltQ f v rhpii> ,* Ajlirtnef I 1 "cmv\/ c firi ) ^/lLr ncrp , i f1 b-ii/wi't' J^'fcCVt'tjfe-e \fj^ t^W I*\SL/ IvC&lA C'fci W VW/i/bV bi'/^Cv vVbVM^b' WWf^txM'//A'M^bVL^M t/ artftt. bitiionititn and ouizi haxaidoM a?

OfJha&k P *oa,ni 312

Mr. Mane Herman em 99918th Street Suite 500 Denver, Colorado 80202

to Ik Mto sbfe ani water, to to IM tk 313

000 $ < utfe 500 £*, Co 80202

IU&H dv\i. oj-wnan,.

(J am aqabzdj t^dw-^no—' infeiqiatinqj j XQWVJj tyadz. ini-o li iLiuLz. *Wz do not teza cm Land and waizi with, hLntoninfti and olnzi hazataoM waltz. 314

Mr. Man; Herman 999 18th Steel Suite 500 Denver, Colorado 80202 Dwlklknm, NO. Jui ui.ar »;ai r.ui

315

?99 18fK St. Suite 500 v Colorado 80202

J would B

QQQ $ t. \uk, 500 zi, Co 80202

,. ctyzunan. G am aaaind clv[dw^io iiztz'icjiatinq xorni/ tyJattL into ikdi dudqz ^14 do not tizzd ouz Laba and txraUz conianilnai&d mm buitonilLin ana otkzi kazaiaoM waltz. 317 dv[au ctyzunan

999 <. Suits, 500

, Co 80202

\Dzai J\l\i. Jfziman, I/ am. againd Jv(dio^w intucjiatinq Xomij %dfc into ihdi dudqz *W& do not nzzd om Land and waizi contaminated mm buitoniiJLm and otnzi hazaidout, wadx. 318

Mr. Marc Herman EPA 999"18th Street Suite 500 Denver, Colorado 80202

vote is AGMff tlie pioposal to pA Lo to iito ik Met® ship I io M mi and water. tt)t do I mt tk futoK $mtm of sy to he 319

r\r\f\

, Co &02G2

. Jj-•zwian, if OM aoaittd zMdw-tfw inhiqiatinq XQ

liL 500 , o 00202

, Jj-zman. U am o,qami zMAw-tyw iniiiqiaiinq Xomn {mAtz into J -* J J u iYi&vi iLuaqs* 'Wz do not nzza cm la.ua and waizi u mui bLutotiiiitn ana otnzi- iiazaidoM 321

SB/I

I/ +rI vWI

.() n /" / /^ .* /) /> / /" ^ ill J i

J 322

& 500

/* I/

Li !/« 323

^ t/t/W t;

, Jfzunan. rt 'i Jlf i /3 • L " 0 rtAf > ' i I/ am a^a^d-r'iri^+ v* *f *rm> dy(rtw-*~yw-*«—' - * <~f^ » w » » w imziqiaunq«r» ar ^«M> *»"S»| * •> ^ •• w^ ^ i JUG®*® "muz wto */ J- sJ ihdi diulqz. 'W& do not azzd ouz La&a and wate mm blaiotiiam a'tid omzi kazaidou* waits,.

0 324

Ja0^V[f)Jlf\" T IfcV VW

/ /

, o 80202

Jf £ma&,

I/ a/?2. ao&in&iJ &Y(EiiQ-^w-^ iniiiaiaiinGJ J J^QIPIII j *w0At£ into li utiacfc *Wfc ao ^oi ,»2£xa oiii iana and wak:i contaminated biti,toniiitti and oinzi kazaidoiM 325

Mr. Marc Herman EPA 99918th Street Suite 500 Denver, Colorado 80202

My vole is AG/. T . » , .1 4\faffar IiHi*ff\I I liirhAr /i 4UW JJU^l/ *LIV II ! do not M> IMm ii r $r do I mt tk filtiK pwtiois of iy Uty to k 326

}J\arc

999 -WH St. Sufe 500 Colorado 80202 "Herman/ J would like to go on record .A^AJASI fi\e plan to hcorpo^afe pe^ Fuhd Waste o| any Id4 «fo the sludge that goes out l\e [arm ground* h eastern Cdorado, J do not want our land water and a^ contaminated witk plutonlum and al tl\e otder cemicals tat are in te lowr landl 327 em

000/ s j '$& & £ti&t 500 *i, Co 80202

jj am aaami Jl/{dw-@w inhiqiaimo. Jjww ty/arie, into ~*

c. 328 em 900

// am aqami J\/(d-io-tfiQ inhiqiaiin-q Xoma 'tyasu, Into U ** ij tj

Mr. Marc Herman Em 99918th Street Suite 500 Denver, Colorado 80202

My wte is AGM! the piv^ to ft tiwy U$ >. Vrt: Mrfil MKu, //~! 330

Mr. Marc Herman 999 18th Street Suite 500 Denver, Colorado 80202 331

Mr, Maic Herman 999 18th Street Suite 500 Denver, Colorado 80202 Dor Ik Urn® 332

Mr. Marc Herman 999 18th Street Suite 500 Denver, Colorado 80202 333

. $500 $0202

'ir 'Prv i

altWW. tWVh run/*ttU vr»4 334 z?v(au

lL JULtui, f / / , Co &0202

. Jfzman. LIn am aqaiMt, t dv\rtw-^wM , n. imiiqiaunq, i i. 2,otnnn dm*m-tti- i into, L sj J J

DKattfe Q/oit, 335

Mr. Maic Herman EPA 999 18th Street Suite 500 Denver, Colorado 80202 Dtstlkltm, tito ib Mr jo I 336

Mr. Marc Herman EPA 999 18th Street Suite 500 Denver, Colorado 80202 Dot lit Km, 337

$0202

jW Sfte ^ty( Wfe At

f tkttiku 338

Mr. Maic Herman EfA 99918th Street Suite 500 Denver, Colorado 80202 taMr. ttm, ito tb Mto sHs I&MmtDllomiiiiifMair, wefapiitytok 339

Mr. Marc Herman sm 99918th Street Suite 500 Denver, Colorado 80202 Its Ilk Urn, astute fo to I 340

}J\arc

99918iKSf.Ste500 Colorado 80202

J would ike to go on record A(^JJNlSI fta plan to incorporate >er Fund Waste o[ any kind/ info me sLu^e Mar goes out fke (arm ^ound in eastern Colorado, J do not want our land and water and air contaminated wirfi plwlonium and af tke fojdc ckemicals fkat are h tke Lowry londfl

e: c». CO 341

999 18*K Sf, Suite 500 Dem/e*v Colorado 80202

J would Ike to GO on record fiG^NSi tke plan to Incorporate l >er Fund Waste o[ any mdf hto tke sludge that goes out ike [arm

Sr>£efely; ,- \ 342

6PA 999 18iK St. Suite 500 Denver, Colorado 80202

J wow!ci lie to ao on recoftJ fi($3}$i fl\e dan fo 0 I # FuruJ Wasfe o[ any kM/ ^te ^ s^g^ ^Hat cpes OMT the (arm yowul ^\ eastern CoSo^ada J Jo nof worrf" ottf land and watef and a^ contaminafed wifk pluloniwm and al tk ic diemicals fnat a^e in the Lowy 343 $500

'/ u. 344

em 909 $&

$ am Mated J\(diQ-(3w i^s-iGiatteq Xomu fyfadz into lj ** J (J J ic ^W& do not n&A Q\JLI Land ana Kraizi ccaianiinated vim bLuioniwn and oth&i nazaidoM 345 em 999 $

£.it Co

am- aqai&d dlf(dw-@w Lsts-iGiakuiQ jUwtu 'T/aite tefo

Jjiunan, S am- aaami Jl/[dio-tfw inhiqiaiin-q JJcww ^am Into J -* J u it yzsii i/tdV ^14 do not n&A OILI LarJ and mi&i contaminated u mik hltiiobLwn and othzi hazaidoM 347 em<^ 999 $ El, Co 80202

3 am aqami J^dw-Qw L^iicjiailn^ Jlwuj tyfadz teio Wtii d\JiC£, % do net nud, OILI [aid, ani waUi c&damuidzd V yiti tluiobim and olnzi LazaidoM 348

900 $ L nit& 500

iit Co

am- aqami \dwio LnhiqiaiLnq joww 4X£. into V "^ J U J UIUIQS, *M4 do mot n&Ji ou.i Land and vats, u bLdoniUM and olhzi LazaidoM waltz, 349

900 n, Co

am aqami dl/{dio-(3w bds-iQiduuj JAWIU fyfa&fa into J •** J u J uudqz. % do not nedi oui Land ana iffai&i u viih, blulobiiLto, and olnzi iiazaidoM waltz,

DUi

f.O- 350

C?%7,<2 *-&wian

999 $, t. \Jiit& 500

EC, Co 80202

~ff am-— Miami~ cMdio-@w inhwiaiinq £ww fyfode. Into do act nzd oui lead, and wai&i ccn yiik, hluiobim and othw hazaidoM

, CJD So/oi 351

jff am- aqami Jv(d-iQ-@w L^tiiqidiM £ww tyam into lj ** 'J U d do noi nzzd OULI Land and wai&i ccaianiinaizd viih biidobiuto, and otiiii LazaidoiM waits*

rtf P Jkank

Jon 577 352

Mr. Maic Herman 999 18th Street Suite 500 Denver, Colorado 80202 DMTM: Urn, MJif Msi ' mmj/vinflvtiii to toftt Lowry UiSuper H asltals Jtnbf

loll 353 em 999 /We*, Co 80202

3 am. aqami *" " / 4 /aoi ttfse oiiz ar and vo yiti biittobiiLto, and QMILI nazaidoM 354

909 EI, Co &0202

- £- teio i/ ** < v fl7dic« ccniamuu&ul hluionim and ottei liazaidoM 355

990 ;$ l tilts, 500 i, Co

// am aqami

W**—Tif ' 356

900 EI, Co

ctfiunan, am aqami d/[dio-@w inkiqiaiincj Xcwtu tyadx, V v V ** tf$£ do not YxA OULI [arJ ana vak&i ccnia vitii biuiobiwn and oth&i LazaidoM 357

SBA fe 5CO toe

/I/I I/

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omm

^V*r-K 358

Mr. Marc Herman 999 18th Street Suite 500 D&nver, Colorado 80202 Den Mr. HfflM, to ft Lmj LssS ^ I do not mtpllQM is V vats Mr do I ml tkt^soAs ofvyUyto be JUHs,

V??. 359

Mr. Maic Herman EfA 99918th Street Suite 500 Denver, Colorado 80202

'M te$,fc 'aadwatff.

/c?S~ 360

I/

, ctyzman, / am aaoMttr , .&V{Etw-rfi,o_/l/f / /2 tniiiqiaunq' / " jjwiti/7 ^/J*wau£/ ' unto' / t f ^^^ V» i *$/ i V/ / ffe£tz dudqE. *W& do not tizzd cm Land and waist eoziaminaizd u with, ibLuionitim and otnzi iiazaidout, waitz,

rr>7 P m Jkank *ljonf 361 em 909 < & 500 , Co S0202

am. aqami e${dw-@w inhiqiaiiM Jjww fyfauz into j * * *" do not need oui iarA and vaki viih bLu.toniuto, and om&i iiazaidoM 362 em 900 '$

D&ai am- aqaiiPM. d\!(dio-Qw inhiqiaiinq Jjww *Wa&i& into U ^ 'J V J 4 do &oi n&d oni Land ana uratei c&ii&minated bLdobiwn and otkzi LazaidoM 363

&vaw

r\r\n i$l A » , lli. Oa&LC

;; Co 80202

\i. Jj-zman. OM aqaind ( S an J dw-^'w uihwiaiinqJ jLowmj "/mii. into ? . f & doI not. nzzd/ cuz LG&&P ( and i iffatzz contaminated, ! mm bluioniMn and oknzi kazaidoat, waitz. 364

QOO 1 . \i 500 XXX * , Co S02D2

(i. a}zmoxi.

U am aqaindj &l/[dio-(-iw intiwaiino.j j Jloww(j M/Kwfe into P , pi r\M \ i ( P ! ( i ten undaz*j *W& do not nzzd oai Land and warn ritk•? buitoniumf anaI CMILIif kazaidoM° /

DU 365

I/

/ / &202

{i. Jfzman. L am aaaind &y\dw-^lw ijifewaiuiG j^om "tfadz into tksi,P , i iliuioEP ! . (~>tiwz dIo not' nzzdj cm Lanf aI andI waizi

mtLin •bitiioniiifti ana otnzi kazaidoiti ore 366

J\l[ aic

999

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TYPE B LETTERS 388

Marc Herman United States EPA Region Vm (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely,

\ VN 389

Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Dyers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 390

Marc Herman United States EPA Region VHI (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley. —/9 Sincerely,

/Z-£ CjLo 391

Marc Herman United States EPA Region Vffl (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer hi Elbert county and above the live water hi Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely,

0C^—^o——^ £. o/EJ. 392

Marc Herman United States EPA Region VIE (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 393

Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer hi Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 394

Marc Herman United States EPA Region VIE (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfimd waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 395

Marc Herman United States EPA Region VHI (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat laud owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail iuid Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 396

Marc Herman United States EPA Region VIE (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely,

/ 77 397

Marc Herman United States EPA Region VII] (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Grceley.

Sincerely,

II 1 II I II 398

Marc Herman United States EPA Region VIII (8HWM-FR) 999 18m Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Supcrfund waste water to Mctrogro sludge coming out to Arapahoe and Elbcrt counties.

1 feel there is not a plant made that can remove all radioactive panicles from 1.77 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Mctrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debn washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail ar.d Dyers and hundreds of farms and ranches reaching from Deer Trail north to Grcclcy.

^Pl/VL x&V'JM- ^-ULXX

, do 399

Marc Herman United States EPA Region VTfl (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by • Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 400

Marc Herman United States EPA Region VHI (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge dairy on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely,

, CO- 401

Marc Herman United States EPA Region Vffl (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made mat can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer hi Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 402

Marc Herman United States EPA Region VUI (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer hi Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

3^5 OO ^ J / #&t> 3 403

Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 404

, Marc Herman United States EPA Region Vffl (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley. •r— Sincerely, 405

Marc Herman United States EPA Region VIE (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 406

Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 407

Marc Herman United States EPA Region Vffl (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made mat can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 408

Marc Herman United States EPA Region VID (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

1 feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious waiter.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely,

00 , 409

Marc Herman United States EPA Region Vm (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into ft by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail norm to Greeley.

Sincerely, 410

Marc Herman United States EPA Region VIE (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in me soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 411

Marc Herman United States EPA Region VHI (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 412

Marc Herman United States EPA Region Vffl (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxnill Aquifer hi Elbert county and above the live water in Arapahoe county that recharges the Foxnill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley. 413

Marc Herman United States EPA Region VID (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elberi counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 414

Marc Herman United States EPA Region VID (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 415

Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 1 77 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41 ,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail arid Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely,

^ o =z^ co CO 416

Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely,

ou aH

o ;•. CXJ \± 417

Marc Herman United States EPA , Region Vffl (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 418

Marc Herman United States EPA Region Vffl (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in me soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 419

Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious waiter.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water hi Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail norm to Greeley.

Sincerely, ,7-1

ft^A^

IU.iim..l.Mi.....i.]i.

Marc Herman United States EPA Region VHI (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made mat can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 421

Marc Herman United States EPA Region Vlll (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 4 1 ,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-oft" which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and 2yers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 422

Marc Herman United States EPA Region Vffl (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177. chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail norm to Greeley.

Sincerely,

H.E.JO Hugh Box 274 Deer Trail CO 80105-0274

CUUCL 423

Marc Herman United States EPA Region VHI (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 424

Marc Herman United States EPA Region VIH (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superrund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 425

Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off'which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely,

CD 303 1(t°i- ^25 7 426

Marc Herman United States EPA Region VHI (8HWM-FR) 99918™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

1 am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 5 437 SO/03 427

Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 428

Marc Herman United States EPA Region Vffl (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

1 feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 429

Marc Herman United States EPA Region Vffl (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals hi the soil mat will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county mat recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail norm to Greeley.

Sincerely,

~n rr. §c: en >•—-.~ CD if Z> 430

Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 431

Marc Herman United States EPA Region VIH (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, Marc Herman United States EPA Region V1I1 (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Melrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley. 433

Marc Herman United States EPA Region Vlll (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoc and Elbcrt counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around Uic headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized dcbn washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail ar.d Dyers and hundreds of farms and ranches reaching from Deer Trail north to Grcclcy.

Sincerely, 434

Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daiJy on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 435

Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

C.T I am protesting the addition of treated Lowry Landfill Supcrfund waste water to Metrogro sludge coming out to Arapahoe and Elbcrt counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and^ above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Sysrs and hundreds of farms and ranches reaching from Deer Trail north to Grccley.

-T- 00 Mo

:co

•:£f*^. 436

Marc Herman United States EPA Region VI]J (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Mctrogro sludge coming out to Arapahoc and Elbcrt counties.

I feel there is not a plant made dial can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 vear plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Mctrogro, creating a build-up of chemicals in the soil that will never go away.

Mctrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized dcbn washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail ar.d 2yerc and hundreds of farms and ranches reaching from Deer Trail north to Grcclcy.

Sincerely,

Margie Lmnebur P.O. Box 22 Deer Trail, CO 80105O022

C'F$2 I'SNUEf \ • "-'- Xx^/3Sl./ ' n 437

Marc Herman United States EPA Region Vlll (8HWM-FR) 999 IS7" Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Supcrfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxliill Aquifer serves the towns of Deer Trail ar.d Bysrs and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely,

80103 438

MarcHennan United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the £••-••' live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already ?•;£. been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of forms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 439

Marc Herman United States EPA Region VHI (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north tojkeeley.

Sincerely, 440

Marc Herman United States EPA Region Vffl (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 441

Marc Herman United States EPA Region VIE (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge dairy on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer hi Elbert county and above the live water hi Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely,

, CD 442

Marc Herman United States EPA Region VIH (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely,

fo ai &f

J 443

Marc Herman United States EPA Region VIH (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious waiter.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely,

'~ ff >|

V 444

Marc Herman United States EPA Region Vffl (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 445

Marc Herman United States EPA Region VIE (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

1 feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, /I 446

Marc Herman United States EPA Region VIH (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in die soil that will never go away.

Metrogro owns land around the headwaters of Foxbill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail norm to Greeley.

Sincerely, Marc Herman United States EPA Region VIII (8HWM-FR) 999 1 8™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 448

Marc Herman United States EPA Region VHI (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made mat can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 449

Marc Herman United States EPA Region VIE (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 450

Marc Herman United States EPA Region VHI (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off'which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, yj 451

Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail «nd Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley. 452

Marc Herman United States EPA Region VIH (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 453

Marc Herman United States EPA Region VID (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer hi Elbert county and above the live water hi Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into h by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail find Byers and hundreds of farms and ranches reaching from Deer Trail norm to Greeley. / Sincerely, / 454

Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail norm to Greeley.

Sincerely, . 455

Marc Herman United States EPA Region Vffl (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

1 feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 456

Marc Herman United States EPA Region VID (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 457

Marc Herman United States EPA Region Vffl (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of forms and ranches reaching from Deer Trail north to Greeley.

Sincerely, frOstA- /£5

The Roths 2479So.Cty.Rd. 185 Bvers, Colo. 80103 458

Marc Herman United States EPA Region Vm (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made mat can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in die soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely,

3 so 459

Marc Herman United States EPA Region Vm (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made mat can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, ^uJ^Q^ ) <— i C.L- & U> 460

Marc Herman United States EPA Region VHI (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious waiter.

Your 30 year plan will add tons of sludge dairy on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in me soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, ^wa^&fr SC^< 461

Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made mat can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley. 462

Marc Herman United States EPA Region VHI (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 463

Marc Herman United States EPA Region Vffl (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made mat can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer hi Elbert county and above the live water in Arapahoe county mat recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail sind Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely,

5. 464

Marc Herman United States EPA Region VIE (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail sind Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 465

Marc Herman United States EPA Region Vffl (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made mat can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in me soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 466

Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 1 77 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat laind owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert count}' and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 467

Marc Herman United States EPA Region Vm (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made mat can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge dairy on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county mat recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely,

SCANN

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Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 469

Marc Herman United States EPA Region Vffl (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made mat can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley. Sincerely'

...... M. •• •,':••'. \\. V.V.I•.«•••.-•••,••••. '.\. .-" !':":»"i::i \V. l':

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IliililliiMiiillliinililuliliiiilliliil/liiiilii/iiindiii 470

Marc Herman United States EPA Region Vffl (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

/ 471

Marc Herman United States EPA Region VIH (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out 10 Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 472

Marc Herman United States EPA Region VHI (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminate^ by sludge-fertilized debri washed into h by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely,

§63-769 - Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley,

Sincerely, 474

Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious waiter.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley. 475

Marc Herman United States EPA Region VIII (8HWM-FR) 99918™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 476

Marc Herman United States EPA Region VIII (8HWM-FR) 99918™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live waiter has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely,

I 477

Marc Herman United States EPA Region VIE (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat latnd owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county mat recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely,

s^^S. 478

Marc Herman United States EPA Region VIE (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer hi Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 479

Marc Herman United States EPA Region Vm (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 480

Marc Herman United States EPA Region Vffl (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious waiter.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley. 481

Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely,

b Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

fv I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or °° else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water hi Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, 484

Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel mere is not a plant made that can remove all radioactive particles from 177 chemicals or else mat water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail norm to Greeley.

Sincerely, 485

Marc Herman United States EPA Region VIH (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer hi Elbert county and above the live water in Arapahoe county mat recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely,

r "\2_ CO* 486

Marc Herman United States EPA Region VIII (8HWM-FR) 999 18™ Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am protesting the addition of treated Lowry Landfill Superfund waste water to Metrogro sludge coming out to Arapahoe and Elbert counties.

I feel there is not a plant made that can remove all radioactive particles from 177 chemicals or else that water would be used for human consumption to conserve precious water.

Your 30 year plan will add tons of sludge daily on the 41,000 acres of wheat land owned by Metrogro, creating a build-up of chemicals in the soil that will never go away.

Metrogro owns land around the headwaters of Foxhill Aquifer in Elbert county and above the live water in Arapahoe county that recharges the Foxhill Aquifer. The live water has already been contaminated by sludge-fertilized debri washed into it by hard rain run-off which is on privately owned grassland. The Foxhill Aquifer serves the towns of Deer Trail and Byers and hundreds of farms and ranches reaching from Deer Trail north to Greeley.

Sincerely, TABBED PAGE

TYPE C LETTERS 487

SOUTH SHERIDAN SANITATION DISTRICT 900 South Wadsworth Boulevard Lakewood, Colorado 80226-4398

Phone:(303)922-1113

June 18, 1997

Marc E. Herman (8EPR-SR) Remedial Project Manager U.S. Environmental Protection Agency 999 18th Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

After looking at a lot of information concerning whether the Metro Wastewater Reclamation District should treat the pretreated groundwater from the Lowry Landfill Superfund Site, I believe you should decide to let the Metro District do it.

The Metro District treatment solution looks like it is the best solution from both an environment^ and an economic point of view. I know there have been some activists who are trying to urge you not to do this, but I have not heard them come up with a better solution. I think it is time for the EPA to do what you think is the right thing to do and what the science tells us is the best thing to do. Let's get on with treating the groundwater from the Lowry Landfill, and let's let the Metro District do it. They are the best qualified, and it is not going to put any appreciable extra pollution into the environment.

Sincerely,

SOUTH SHERIDAN SANITATION DISTRICT

Jean^Sain, Secretary 1452 S. Ames Street Lakewood, Colorado 80232-2054 488

SOUTH SHERIDAN S^ITATION DISTRICT 900 South Wadsv^rtbTBbufe&l-d Lakewood, Colorado 80226ff 398 ;:jP^ruS BRANCH Phone:(303)922-1113

June 18, 1997

Marc E. Herman (8EPR-SR) Remedial Project Manager U.S. Environmental Protection Agency 999 18th Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

After looking at a lot of information concerning whether the Metro Wastewater Reclamation District should treat the pretreated groundwater from the Lowry Landfill Superfund Site, I believe you should decide to let the Metro District do it.

The Metro District treatment solution looks like it is the best solution from both an environment^ and an economic point of view. I know there have been some activists who are trying to urge you not to do this, but I have not heard them come up with a better solution. I thiink it is time for the EPA to do what you think is the right thing to do and what the science tells us is the best thing to do. Let's get on with treating the groundwater from the Lowry Landfill, and let's let the Metro District do it. They are the best qualified, and it is not going to put any appreciable extra pollution into the environment.

Sincerely,

SOUTH SHERIDAN SANITATION DISTRICT

Leonard W. Cole, Treasurer 1686 S. Depew Street Lakewood, Colorado 80232-7234 489

SOUTH SHERIDAN SANITATION DISTRICT 900 South Wadsworth Boulevard Lakewood, Colorado 80226-4398

Phone:(303)922-1113

June 18, 1997

Marc E. Herman (8EPR-SR) Remedial Project Manager U.S. Environmental Protection Agency 99918th Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

After looking at a lot of information concerning whether the Metro Wastewater Reclamation District should treat the pretreated groundwater from the Lowry Landfill Superfund Site, I believe you should decide to let the Metro District do it.

The Metro District treatment solution looks like it is the best solution from both an environmental and an economic point of view. I know there have been some activists who are trying to urge you not to do this, but I have not heard them come up with a better solution. I think it is time for the; EPA to do what you think is the right thing to do and what the science tells us is the best thing to do. Let's get on with treating the groundwater from the Lowry Landfill, and let's let the Metro District do it. They are the best qualified, and it is not going to put any appreciable extra pollution into the environment.

Sincerely,

SOUTH SHERIDAN SANITATION DISTRICT

Daniel Galanaugh, Assistant Secretary 1433 S. Ames Street Lakewood, Colorado 80232-5946 490

SOUTH SHERIDAN SANITATION DISTRICT 900 South Wadsworih BbuleVafd' !: 58 Lakewood, Colorado 80226-4398__TT

". •'.. L":;.'; :•;•") ~. 3 A IIPLJ Phone: (303) 922-lTir;' ~MH'

June 18, 1997

Marc E. Herman (8EPR-SR) Remedial Project Manager U.S. Environmental Protection Agency 999 18th Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

After looking at a lot of information concerning whether the Metro Wastewater Reclamation District should treat the pretreated groundwater from the Lowry Landfill Superfund Site, I believe you should decide to let the Metro District do it.

The Metro District treatment solution looks like it is the best solution from both an environment^ and an economic point of view. I know there have been some activists who are trying to urge you not to do this, but I have not heard them come up with a better solution. I think it is time for the EPA to do what you think is the right thing to do and what the science tells us is the best thing to do. Let's get on with treating the groundwater from the Lowry Landfill, and let's let the Metro District do it. They are the best qualified, and it is not going to put any appreciable extra pollution into the environment.

Sincerely,

SOUTH SHERIDAN SANITATION DISTRICT

William A. Groves, Jr., Vice-Chairperson 1462 S. Ames Street Lakewood, Colorado 80232-5947 491

£ Sjf EAST LAKEWOOD SANITATION DISTRICT ^ -;: '^- 900 South Wadsworth Boulevard ^2 H ^ Lakewood, Colorado 80226-4398

^ "g Phone:(303)922-1113

June 11, 1997

Marc E. Herman (8EPR-SR) Remedial Project Manager U.S. Environmental Protection Agency 999 18th Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

After looking at a lot of information concerning whether the Metro Wastewater Reclamation District should treat the pretreated groundwater from the Lowry Landfill Superfund Site, I believe you should decide to let the Metro District do it.

The Metro District treatment solution looks like it is the best solution from both an environmental and an economic point of view. I know there have been some activists who arc trying to urge you not to do this, but I have not heard them come up with a better solution. I think it is time for the EPA to do what you think is the right thing to do and what the science tells us is the best thing to do. Let's get on with treating the groundwater from the Lowry Landfill, and let's let the Metro District do it. They are the best qualified, and it is not going to put any appreciable extra pollution into the environment.

Sincerely,

EAST LAKEWOOD SANITATION DISTRICT

NeU Hansen, Director

850 Gray Street Lakewood CO 80214-2442 492 BANCROFT-CLOVER Water k Sanitation DISTRICT 900 SOUTH WADSWORTH BOULEVARD LAKEWOOD, COLORADO 80226-4398 PHONE 8122-1113

June 18, 1997

Marc E. Herman (8EPR-SR) Remedial Project Manager U.S. Environmental Protection Agency 999 18th Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

After looking at a lot of information concerning whether the Metro Wastewater Reclamation District should treat the pretreated groundwater from the Lowry Landfill Superfund Site, I believe you should decide to let the Metro District do it.

The Metro District treatment solution looks like it is the best solution from both an environment^ and an economic point of view. I know there have been some activists who are trying to urge you not to do this, but I have not heard them come up with a better solution. I think it is time for the EPA to do what you think is the right thing to do and what the science tells us is the best thing to do. Let's get on with treating the groundwater from the Lowry Landfill, and let's let the Metro District do it. They are the best qualified, and it is not going to put any appreciable extra pollution into the environment.

Sincerely,

BANCROFT-CLOVER WATER & SANITATION DISTRICT

Hendrickson, Vice-President 1000 S. Upham Street Lakewood, Colorado 80226-4522 493 BANCROFT-CLOVER Water k SamtatioH DISTRICT 900 SOUTH WADSWORTH BOULEVARD LAKEWOOD. COLORADO 80226-4398 PHONE 922-1113

June 18, 1997

Marc E. Hennan (8EPR-SR) Remedial Project Manager U.S. Environmental Protection Agency 999 18th Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

After looking at a lot of information concerning whether the Metro Wastewater Reclamation District should treat the pretreated groundwater from the Lowry Landfill Superfund Site, I believe you should decide to let the Metro District do it.

The Metro District treatment solution looks like it is the best solution from both an environmental and an economic point of view. I know there have been some activists who are trying to urge you not to do this, but I have not heard them come up with a better solution. I think it is time for the EPA to do what you think is the right thing to do and what the science tells us is the best thing to do. Let's get on with treating the groundwater from the Lowry Landfill, and let's let the Metro District do it. They are the best qualified, and it is not going to put any appreciable extra pollution into the environment.

Sincerely, BANCROFT-CLOVER WATER & SANJT£T}ON DISTRICT

RoseUeJohnson, Secretary 167 f S.Dover Court Lakewood, Colorado 80232-6622 494 BANCROFT-CLOVER Water k Sanitation DISTRICT 900 SOUTH WADSWORTH BOULEVARD LAKEWOOD, COLORADO 80226-4398 PHONE 9)22-1113

June 18, 1997

Marc E. Herman (8EPR-SR) Remedial Project Manager U.S. Environmental Protection Agency 999 18th Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

After looking at a lot of information concerning whether the Metro Wastewater Reclamation District should treat the pretreated groundwater from the Lowry Landfill Superfund Site, I believe you should decide to let the Metro District do it.

The Metro District treatment solution looks like it is the best solution from both an environmentiil and an economic point of view. I know there have been some activists who are trying to urge you not to do this, but I have not heard them come up with a better solution. I think it is time for the EPA to do what you think is the right thing to do and what the science tells us is the best thing to do. Let's get on with treating the groundwater from the Lowry Landfill, and let's let the Metro District do it. They are the best qualified, and it is not going to put any appreciable extra pollution into the environment.

Sincerely,

BANCROFT-CLOVER WATER & SANITATION DISTRICT

Robert L. Mall, Treasurer 1791 S. Cape Street Lakewood, Colorado 80232-6610 495

.- uV/o ?^%X^TLAKEWOOD SANITATION DISTRICT 900 South Wadsworth Boulevard Lakewood, Colorado 80226-4398 ',Aw> Phone:(303)922-1113

June 11, 1997

Marc E. Herman (8EPR-SR) Remedial Project Manager U.S. Environmental Protection Agency 999 18th Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

After looking at a lot of information concerning whether the Metro Wastewater Reclamation District should treat the pretreated groundwater from the Lowry Landfill Superfund Site, I believe you should decide to let the Metro District do it.

The Metro District treatment solution looks like it is the best solution from both an environmental and an economic point of view. I know there have been some activists who are trying to urge you riot to do this, but I have not heard them come up with a better solution: I think it is time for the EPA to do what you think is the right thing to do and what the science tells us is the best thing to do. Let's get on with treating the groundwater from the Lowry Landfill, and let's let the Metro District do it. They are the best qualified, and it is not going to put any appreciable extra pollution into the environment.

Sincerely,

EAST LAKEWOOD SANTTATION DISTRICT

'Carl Mayer, President

5200 W. 9th Avenue Lakewood CO 80214-2514 496

SOUTH SHERIDAN SANITATION DISTRICT 900 South Wadsworth Boulevard Lakewood, Colorado 80226-4398

Phone:(303)922-1113

June 18, 1997

Marc E. Herman (8EPR-SR) Remedial Project Manager U.S. Environmental Protection Agency 999 18th Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

After looking at a lot of information concerning whether the Metro Wastewater Reclamation District should treat the pretreated groundwater from the Lowry Landfill Superfund Site, I believe you should decide to let the Metro District do it.

The Metro District treatment solution looks like it is the best solution from both an environmental and an economic point of view. I know there have been some activists who are trying to urge you not to do this, but I have not heard them come up with a better solution. I think it is time for the EPA to do what you think is the right thing to do and what the science tells us is the best thing to do. Let's get on with treating the groundwater from the Lowry Landfill, and let's let the Metro District do it. They are the best qualified, and it is not going to put any appreciable extra pollution into the environment.

Sincereiy,

SOUTH SHERIDAN SANITATION DISTRICT

MarjopfeM. McLellan, Chairperson 1325 S. Gray Street Lakewood, Colorado 80232-5851 497

EAST LAKEWOOD SANITATION DISTRICT 900 South Wadsworth Boulevard Lakewood, Colorado 80226-4398

Phone: (303) 922-1113

June 11, 1997

Marc E. Herman (8EPR-SR) Remedial Project Manager U.S. Environmental Protection Agency 999 18th Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

After looking at a lot of information concerning whether the Metro Wastewaiter Reclamation District should treat the pretreated groundwater from the Lowry Landfill Superfund Site, I believe you should decide to let the Metro District do it.

The Metro District treatment solution looks like it is the best solution from both an environmental and an economic point of view. I know there have been some activists who are trying to urge you not to do this, but I have not heard them come up with a better solution. I tliink it is time for the EPA to do what you think is the right thing to do and what the science tells us is the best thing to do. Let's get on with treating the groundwater from the Lowry Landfill, and let's let the Metro District do it. They are the best qualified, and it is not going to put any appreciable extra pollution into the environment.

Sincerely,

EAST LAKEWOOD SANITATION DISTRICT

/ Claude D. Off, Director ' / J

860Benton Street Lakewood CO 80214-2530 498 BANCROFT-CLOVER Water k Sanitation DISTRICT 900 SOUTH WADSWORTH BOULEVARD LAKEWOOD, COLORADO 80226-4398 PHONE 912-1113

June 18, 1997

Marc E. Herman (8EPR-SR) Remedial Project Manager U.S. Environmental Protection Agency 999 18th Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

After looking at a lot of information concerning whether the Metro Wastewater Reclamation District should treat the pretreated groundwater from the Lowry Landfill Super-fund Site, I believe you should decide to let the Metro District do it.

The Metro District treatment solution looks like it is the best solution from both an environmental and an economic point of view. I know there have been some activists who are trying to urge you not to do this, but I have not heard them come up with a better solution. I think it is time for the EPA to do what you think is the right thing to do and what the science tells us is the best thing to do. Let's get on with treating the groundwater from the Lowry Landfill, and let's let the Metro District do it. They are the best qualified, and it is not going to put any appreciable extra pollution into the environment.

Sincerely,

BANCROFT-CLOVER WATER & SANITATION DISTRICT

John^L. Sweet, President 5235 W. Mississippi Avenue Lakewood, Colorado 80226-4805 499 to CD _^ ^ EAST LAKEWOOD SANITATION DISTRICT f; ^ 900 South Wadsworth Boulevard : r? Lakewood, Colorado 80226-4398

7.^" Phone:(303)922-1113

June 11, 1997

Marc E. Herman (8EPR-SR) Remedial Project Manager U.S. Environmental Protection Agency 999 18th Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

After looking at a lot of information concerning whether the Metro Wastewater Reclamation District should treat the pretreated groundwater from the Lowry Landfill Superfund Site, I believe you should decide to let the Metro District do it.

The Metro District treatment solution looks like it is the best solution from both an environment^ and an economic point of view. I know there have been some activists, who are trying to urge you not to do this, but I have not heard them come up with a better solution. I think it is time for the EPA to do what you think is the right thing to do and what the science tells us is the best thing to do. Let's get on with treating the groundwater from the Lowry Landfill, and let's let the Metro District do it. They are the best qualified, and it is not going to put any appreciable extra pollution into the environment.

Sincerely,

EAST LAKEWOOD SANITATION DISTRICT

Paul J. Thiele, Secretary

5775 W. 8th Avenue Lakewood CO 80214-2412 500

EAST LAKEWOOD SANITATION DISTRICT __ 900 South Wadsworth Boulevard Qig Lakewood, Colorado 80226-4398

p « Phone: (303) 922-1113

Junle^ll,

Marc E. Herman (8EPR-SR) Remedial Project Manager U.S. Environmental Protection Agency 999 18th Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

After looking at a lot of information concerning whether the Metro Wastewater Reclamation District should treat the pretreated groundwater from the Lowry Landfill Superfund Site, I believe you should decide to let the Metro District do it.

The Metro District treatment solution looks like it is the best solution from both an environment^ and an economic point of view. I know there have been some activists who are trying to urge you not to do this, but I have not heard them come up with a better solution. I think it is time for the EPA to do what you think is the right thing to do and what the science tells us; is the best thing to do. Let's get on with treating the groundwater from the Lowry Landfill, and let's let the Metro District do it. They are the best qualified, and it is not going to put any appredable extra pollution into the environment.

Sincerely,

EAST LAKEWOOD SANITATION DISTRICT

Marian Tinldenberg, Treasurer

891 Gray Street Lakewood CO 80214-2441 501

ATTORNEYS Se COUNSELORS AT LAW FIRST INTERSTATE TOWER NORTH 633 SEVENTEENTH STREET. SUITE 3000 Sherman & Howard L.L.C. DENVER. COLORADO 80202 TELEPHONE 303 297-2900 FAX: 303 299-0940 OFFICES IN: COLORADO SPRINGS RENO-LAS VEGAS

ALAN J. GILBERT DIRECT DIAL NO. (393) 2994354

May 21, 1997

Mr. Marc £. Herman Remedial Project Manager U.S. Environmental Protection Agency Mail Code 8EPR-SR 999 18th St. #500 Denver, CO 80202

Re: Lowry Landfill - Second Explanation of Significant Differences (ESD) for the Lowry Landfill Superfund Site Record of Decision

Dear Mr. Herman:

On behalf of Eastman Kodak Company, we submit the following comments regarding the proposed second ESD to the Lowry Landfill Record of Decision (ROD).

Former Tire Pile Area

Recent treatability testing in the former tire pile area has determined that onsite treatment to meet RCRA Subtitle C and D requirements of the Solid Waste Disposal Act and the State Hazardous Waste Act is possible, and will significantly reduce risks assodated with offsite transportation and disposal. Eastman Kodak supports the proposed onsite treatment and disposal of the former tire pile materials.

Water Treatment Plant/POTW

The selection of the Metro POTW option offers additional protection to the environment, downstream residents and worker health and safety. Metro has the authority to enforce the Clean Water Act and ensure that any effluent meets its discharge permit requirements. Eastman Kodak supports the proposed POTW option. ^ ^

—I S<-* o 502

Sherman & Howard L.L.C.

May 21, 1997 Page 2

In light of the new information from recent design investigations and proposed changes to the selected remedy, Eastman Kodak Company believes that the remedy remains protective of human health and the environment, complies with applicable or relevant and appropriate requirements and is cost-effective. The Company supports the proposed second ESD.

Very truly yours,

AJG:lw cc: Mr. Joe Vranka, CDPHE - HMWMD 503 TELEPHONE (403) 233-4000 FAX (403) 233-5127

ASAMERA OIL (U.S.) INC P.O. BOX 130 CALGARY, ALBERTA T2P 2H7

May 28, 1997

Mr. Marc E. Herman Remedial Project Manager U.S. Environmental Protection Agency Mail Code 8EPR-SR Suite 500, 999 18 Street Denver CO .30202

Dear Mr. Herman:

Subject: Lowry Landfill - Second Explanation of Significant Differences (ESD) for the Lowry Landfill Superfund Site Record of Decision

On behalf of Asamera Oil (U.S.), Inc., we are submitting the following comments regarding the proposed Second ESD to the Lowry landfill Record of Decision (ROD)

Former Tile Pile Area

Recent treatability tests in the former tire pile area have determined that onsite treatment to meet RCRA Subtitle C and D requirements of the Solid Waste Disposal Act and the State Hazardous Waste Act is possible and will significantly reduce risks associated with offsite transportation and disposal. We support the proposed onsite treatment and disposal of the former tire pile materials.

Water Treatment Plant/POTW

The selection of the Metro POTW option offers additional protection to the environment, downstream residents and worker health and safety. Metro has the authority to enforce the Clean Water Act and ensure that any effluent meets its discharge permit requirements. We support the proposed POTW option.

In light of the new information from recent design investigations and proposed changes to the selected remedy, we believe that the remedy remains protective of human health and the environment, complies with applicable or relevant and appropriate requirements and is cost- effective. We support the proposed Second ESD.

Yours truly,

L.T.L. (Lin) Callow Manager of Remediation

/die cc: Joe Vranka, CDPHE - HMWMD

cr» 504

City of Lakewood Public Works Department Engineering Division 445 South Allison Parkway Lakewood, Colorado 80226-3105 (303) 987-7900 Voice/TDD (303) 987-7979 Fax May 13, 1997

Mr. Marc E. Herman Remedial Project Manager U.S. Environmental Protection Agency Mail Code 8EPR-SR 999 18th Street, Suite 500 Denver, Colorado 80202

Subject: Lowry Landfill-Second Explanation of Significant Differences (ESD) for the Lowry Landfill Superfund Site Record of Decision

Dear Mr. Herman:

On behalf of the City of Lakewood, I am submitting the following comments regarding the proposed Second ESD to the Lowry Landfill Record of Decision (ROD).

Former Tile Pile Area

Recent treatability tests in the former tire pile area indicate that onsrte treatment to meet RCRA Subtitle C and D requirements of the Solid Waste Disposal Act and the State Hazardous Waste Act is possible, and will reduce risks associated with offsite transportation and disposal. We support the proposed onsite treatment and disposal of the former tire pile materials.

Water Treatment Plan/POTW

The selection of the Metro POTW option offers an appropriate means to treat site effluent. Metro has the authority to enforce the Clean Water Act and ensure that any effluent meets its discharge permit requirements. We support the proposed POTW option.

In light of the new information from recent design investigations and proposed changes to the selected remedy, we support the proposed Second ESD.

Sincerely,

Jay N. Hutchison City Engineer c: Joe Vranka, CDPHE-HMWMD Peter Nadel, Gorsuch Kirgis 1 54 - City Engineer Correspondence

Alternative formats of this document available upon request. r:\weet\horman.jh 505

Ball Corporation 345 South High Street. Muncie, IN 47305-2326 (317)747-6100 Fax (317) 747-6806 '-^ . Reply to: PO. Box 2407. Muncie. IN 47307-0407 -v '

Robert W. McClelland cr ' ." Associate General Counsel ;^r: :-. - (317)747-6430 "-' ••.'.; April 25, 1997 § £3 o9 Mr. Marc E. Herman = Remedial Project Manager U.S. Environmental Protection Agency Mail Code 8EPR-SR 999 18th Street, Suite 500 Denver, Colorado 80202 Subject: Lowry Landfill - Second Explanation of Significant Differences (ESD) for the Lowry Landfill Superfund Site Record of Decision

Dear Mr. Herman: On behalf of Ball Corporation, we are submitting the following comments regarding the proposed Second ESD to the Lowry Landfill Record of Decision (ROD). Former Tile Pile Area

Recent treatability tests in the former tire pile area have determined that on-site treatment to meet RCRA Subtitle C and D requirements of the Solid Waste Disposal Act and the State Hazardous Waste Act is possible, and will significantly reduce risks associated with off-site transportation and disposal. We support the proposed on-site treatment and disposal of the former tire pile materials. Water Treatment Plant/POTW

The selection of the Metro POTW option offers additional protection to the environment, downstream residents and worker health and safety. Metro has the authority to enforce the Clean Water Act and ensure that any effluent meets its discharge permit requirements. We support the proposed POTW option.

In light of the new information from recent design investigations and proposed changes to the selected remedy, we believe that the remedy remains protective of human health and the environment, complies with applicable or relevant and appropriate requirements and is cost-effective. We support the proposed Second ESD. Yours truly, BALL CORPORATION

~R. W. McClelland

cc: Joe Vranka, CDPHE - HMWMD 506 Benjamin Moore & Co. Paints * Stains * Clear Finishes EXECUTIVE OFFICE • 51 CHESTNUT RIDGE ROAD « MONTVALE. NEW JERSEY 07645-1862 •> (201) 573-9600 - FAX: (201) 573-9046

April 30,1997

> rs

Mr. Marc E. Herman Remedial Project Manager U.S. Environmental Protection Agency Mail Code 8EPR-SR 99918th Street, Suite 500 Denver, Colorado 80202

Subject Lowry Landfill - Second Explanation of Significant Differences (ESD) for the Lowry Landfill Superfund Site Record of Decision

Dear Mr. Herman:

On behalf of Benjamin Moore & Co., we are submitting the following comments regarding the proposed Second ESD to the Lowry Landfill Record of Decision (ROD).

Former Tire Pile Area

Recent treatability tests in the former tire pile area have determined that onsite treatment to meet RCRA Subtitle C and D requirements of the Solid Waste Disposal Act and the State Hazardous Waste Act is possible, and will significantly reduce risks associated with offsite transportation and disposal. We support the proposed onsite treatment and disposal of the former tire pile materials.

Water Treatment Plant/POTW

The selection of the Metro POTW option offers additional protection to the environment, downstream residents and worker health and safety. Metro has the authority to enforce the Clean Water Act and ensure that any effluent meets its discharge permit requirements. We support the proposed POTW option.

MONTVALE, NJ » N£W YORK, NY * NEWARK., NJ • FLANDERS, NJ « NUTLEY, NJ * BOSTON, MA i RICHMOND, VA t JACKSONVILLE. FL » JOHNSTOWN. NY t CHICAGO. IL * ST. LOUIS. MO CLEVELAND" OH» DALLAS, TX . BIRMINGHAM. AL « DCNVER, CO • LOS ANGELES. CA • SANTA CLARA. CA . TORONTO. ON » MONTREAL, PO « LANGLEY, ec » BURLINGTON ON Established 1883 507 April 30,1997 Page 2

In light of the new information from recent design investigations and proposed changes to the selected remedy, we believe that the remedy remains protective of human health and the environment, complies with applicable or relevant and appropriate requirements and is cost-effective. We support the proposed Second ESD.

Very truly yours, BENJAMIN MOORE & CO.

John T. Rafferty Secretary and General Counsel

JTR/ik cc: Joe Vranka, CDPHE - HMWMD 508 Mayor City Council Joe Rice CITY OF Irma Reiss Mayor Pro Tern Cecil Milligan Tracey DeHart GLENDALE Catherine Dempsey City Manager David Dye Gary Sears Anita Kreutzer

May 6, 1997

Mr. Marc E. Herman Remedial Project Manager U.S. Environmental Protection Agency Mail Code 8EPR-SR 999 - 18th Street, Suite 500 Denver, CO 80202

Subject: Lowry Landfill - Secocd Explanation of Significant Differences (XSD) for the Lowry Landfill Superfund Site Record of Decision

Dear Mr. Herman:

On behalf of the City of Glendale, we are submitting the following comments regarding the proposed Second ESD to the Lowry Landfill Record of Decision (ROD).

Former Tire Pile Area

Recent treatability tests in the former tire pile area have determined that onsite treatment to meet RCRA. Subtitle C and D requirements of the Solid Waste Disposal Act and the State Hazardous Waste Act is possible, and will significantly reduce risks associated with offsite transportation and disposal. We support the proposed onsite treatment and disposal of the former tire pile materials.

Water Treatment Plant/POTW

The selection of the Metro POTW option offers additional protection to the environment, downstream residents and worker health and safety. Metro has the authority to enforce the Clean Water Act and ensure that any effluent meets its discharge permit requirements. We support the proposed POTW option.

In light of the new information from recent design investigations ar.d proposed changes to the selected remedy, we believe that the remedy remains protective of human health and the environment, complies with applicable or revelant and appropriate requirements and is cost-effective. We support the proposed Second ESD.

Yours truly,

MAY 121S97 5;i Gary L. /Sears City Manager HAZARDOUS MATERIALS — ^ ~-r AND WASTE MANAGEMENT §p z! = r—! 'V cc: P.B. "Lynn" Walker, Senior Environmental Counsel QP - Bob Taylor, City of Glendale Public Works Director C.O

Glendale Municipal Building 950 South Birch Street Glendale. Colorado 80222-2599 Phone (303) 759-1513 FAX (303) 759-0561 Glendale Council Meetings: Island 3rd Tuesdays at 7 p.m. • Recorded Meetine Information Line (303)639-4717 TABBED PAGE

OTHER LETTERS 509

Tune 30, 1997

Marc Herman EPA Region VIII 999 IS* Street, Suite 500 Denver, Colorado S0202

RE: LOWRY BOMBING RANGE LANDFILL SUPERFUND SITE/POTW PLAN VIA: Electronic mail and facsimile, June 30, 1997

Dear Mr. Herman:

The following are comments in opposition to the EPA Region VIII office's amendment of the Record of Decision at the Lowry T^nHfill Superfund site in Arapahoe County, Colorado, by a plan to pipe partially and ineffectively treated radioactive and hazardous wastes to the public sewer system, for ultimate distribution as "fertilizer" applied to food-producing farm land in rural Colorado Counties. These comments supplement the oral comments which I made at the EPA'3 April 2nd, 1997 Public Meeting on the subject.

This plan should be rejected on the following grounds:

1) The Lowry Superfund Site groundwater is mixed waste, contaminated with both hsizardoua and radioactive wastes. The EPA Region VIII Office, while it is fully aware of these facts, has opted to ignore them.

2) A large volume of contaminants identified at the Lowry Superfund Site have no retaliatory standards i;et for them. While EPA Region VIII office is fully aware of these facts, it has opted to ignore them.

3) The EPA Region Vin Office has failed to consider the additive, cumulative and synergist effects of the: combined load of contaminants already known to be present.

4) The EPA Region VIII Office is fully aware of the fact that land on, contiguous to, and in the immediate vicinity of the Lowry Landfill 3ite (as its boundaries have been defined by EPA Region VIII) was used as a dumping area for hazardous and/or radioactive wastes prior to the time the federal government transferred title to the City and County of Denver in 1964 for use aa a municipal trash dump, yet has opted to ignore these facts of record.

5) The EPA Region VIII Office is fully aware that the area surrounding the Lowry Landfill on the south and east was declared by the federal government's U.S. Army Corps of Engineers in 1995 as a "Probable Catastrophic Risk Zone", due to unexploded ordnance, napalm bomb drops by the Rocky Mountain Arsenal, reported chemical weapons testing and other hazards, yet has used this area to define "background" levels for comparison to contaminant levels inside the presently-defined boundaries for iJie Superfund site.

6) Within the area EPA Region VTII has considered as "background" for Lowry Landfill - both within ami just outside the fenceline of the site •• are numerous other uperadient sources of contamination, which have been inadequately investigated or completely ignored by EPA Region Vm to date: a) former Titan Missile silos, where Martin/USAF housed a nuclear warhead intercontinental ballistic missiles in the early 60*3, including the 1A Titan silo immediately to the east of the Landfill; b) roads bordering the Lowry Landfill, including Gun Club Road on the east and Quincy on the south, where credible and corroborated eyewitnesses have reported "hundreds" of incidents of indiscriminant dumping of liquid hazardous and/or radioactive wastes by tanker trucks hauling loads to the Lowry Bombing Range and Landfill area. 510

Page 2, Anderson Comments to EPA Region VTII

7) I personally accompanied one such eye witness, retired Colorado State Highway Patrolman William H. Wilson, in February 1990 to the site of such incidents, which he had reported both at the time in the early 60's. and again in the 70's and 80'a, to various state and federal authorities; including the EPA; c) a former military munitions dump; e) a former military demolition range where several unexploded bombs and other debris have been found in the last year alone by federal officials; and d) other known sources of contamination at the southeastern corner of the Lowry Landfill which EPA Region VIII has completely failed, to date, to examine as contributing sources to Lowry Landfill's extensively contaminated radioactive and hazardous groundwater and other environmental media.

8) EPA Region YIII's failure to collect adequate funds for remediation and clean-up from the Department of Defense, Department of Energy and its various contractors in the region, for military-related waste dumping in, around and near the Lowry Landfill site, and inappropriately negotiating sweetheart-deal "de minimia" settlements without local notice to potentially affected citizens, blatantly ignoring clear grounds upon which such settlements should not even been considered.

9) EPA Region VEITa apparent failure, to date, to even contact or adequately consider significant "potentially liable parties" such as Dow Chemical, in its capacity as a former operator at Rocky Flats, with known and/or alleged dumping activities at and near the Lowry Bombing Range and Landfill, and possible other former Atomic Energy Commission contractor(s) and/or agent(s) acting in their behalf.

10) EPA Region VTII's stunning and astounding attempts to distort, deny, mislead and/or fail to acknowledge key information related to all of the above, in statements made to the public, local governmental officials, the local, national and international media, and others, all of which warrants investigation by proper oversight authorities, based upon extensive review of the Administrative Record of the Lowry Landfill Superfund Site.

Please respond to each of these comments in writing before a final decision IB made on this outrageous proposal to pipe mixed, hazardous and radioactive waste to the public sewer lines for ultimate disposal to food- producing farms and ranches in Colorado^

Since:

Ad f • i _ son Street Dtriver. Colorado 80206-0625

cc: Nikki L. Tinsley, Inspector General, USEPA Other interested parties 511

Marc Herman USEPA Region 8 999 - 18th St. Denver, CO 80202 June 27, 1997

Dear Sir: Another Love Canal tragedy? Why flush toxic waste residues dumped at Lowry landfill into the public sewer? These toxic residues contain industrial pollutants, spent rocket fuel, and even some plutonium. Once these pollutants enter a public sewer, the corporations who used Lowry as a dump have no further responsibility or liability.

These toxic residues would remain in the water and sludge even after going through the sewage treatment plant. This sludge is currently being spread on crops in Deer Trail, Colorado or packaged and sold to the public as fertilizer by the Metro Vastewater Reclamation District.

Since water moves downstream from the treatment plant to other communities they would be affected as well. Contrary to some claims there is presently no technology capable of removing the worst pollutants from these residues.

Toxic pollutants in the water supply and food chain can damage innocent families for generations. Please don't let such a needless tragedy occur on your watch.

Sincerely

E. Jordan Asnicar Boulder

cc: David Skaggs Ben Nighthorse Campbell 512

City of Englewood OFFICE OF THE CITY ATTORNEY

March 31,1997 Daniel L. Brotzman, City Attorney 3400 South Elati Street Nancy N. Reid, Assistant City Attorney Englewood. Colorado 80110-2304 Dugan S. Comer. Assistant City Attorney Phone (303) 762-2320 FAX Marc T-E,. THermanT , nRemedia j- il nProjec • ' . t nManager r (303)762-2331 U.S. Environmental Protection Agency Mail Code 8EPR-SR - 999 18th Street, Suite 500 Denver, Colorado 80202

REGARDING: Public Comment on Lowry Landfill Superfand Site Explanation of Significant Differences (March 1997).

The City of Englewood submits this comment in support of the Lowry Landfill Superfund Site Explanation of Significant Differences (March 1997).

The City has been intimately involved in the study of contamination at the Lowry Landfill Site and the means to address that contamination since the mid-1980's through the involvement of the Littleton/Englewood Bi-City Wastewater Treatment Plant at the Site. As a result, the City is familiar with the underlying components of the Record of Decision (ROD), the goals sought to be accomplished by the ROD and the manner by which those goals are to be accomplished. The City also is extremely familiar with the operational capabilities of publicly owned treatment works (POTW) facilities by virtue of its joint ownership of the Littleton/Englewood Bi-City Wastewater Treatment Plant.

The City has reviewed the Explanation of Significant Differences (March 1997) insofar as it proposes to change the ROD to allow 1) on-site treatment of waste in the former tire pile area instead of excavation and off-site treatment and disposal, and 2) treatment of groundwater at the Metropolitan Wastewater Reclamation District POTW facilities in lieu of building a new treatment plant on site. The City fully supports proposed changes to the ROD described in the Explanation of Significant Difference (March 1997) as being environmentally sound and consistent with the goals to be achieved by the ROD.

The City believes that on-site treatment of contaminated materials in th«; former tire pile area to meet RCRA Subtitle C and D requirements of the Solid Waste Disposal Act and the Colorado Hazardous Waste Act is preferable to off-site treatment and is consistent with current waste disposal practices and policies. The City further believes that off-site treatment of contaminated groundwater pursuant to the conditions set forth in the Explanation of Significant Differences (March 1997) is preferable to on-site treatment because of the experience and operational capabilities of the Metro Wastewater Reclamation District facilities in controlling and treating such wastewater to meet discharge permit limitations.

For the foregoing reasons, the City supports the proposed changes to the ROD as set forth in the Explanation of Significant Differences (March 1997) and urges adoption of those changes.

'/Darnel IZ ' City Attorney ) 513 C/tv or" Littleton

City Manager 2255 West Berry Avenue Littleton, Colorado 801 65 303 795-3720 FAX 795-381 9 April 2, 1997

Marc E. Herman Remedial Project Manager U.S. Environmental Protection Agency Mail Code 8EPR-SR 999 18th Street, Suite 500 Denver, Colorado 80202

Re: Public Comment on Lowry Landfill Superfund Site Explanation of Significant Differences (March 1997)

Dear Mr. Herman:

The City of Littleton submits this comment in support of the Lowry Landfill Superfund Site Explanation of Significant Differences (March 1997).

The City has been intimately involved in the study of contamination at the Lowry Landfill Site and the means to address that contamination since the mid-1980s through the involvement of the Littleton/Englewood Bi-City Wastewater Treatment Plant at the Site. As a result, the City is familiar with the underlying components of the Record of Decision (ROD), the goals sought to be accomplished by the ROD and the manner by which those goals are to be accomplished. The City also is extremely familiar with the operational capabilities of publicly owned treatment works (POTW) facilities by virtue of its joint ownership of the Littleton/Englewood Bi-City Wastewater Treatment Plant.

The City has reviewed the Explanation of Significant Differences (March 1.997) insofar as it proposes to change the ROD to allow (1) on-site treatment of waste in the former tire pile area instead of excavation and off-site treatment and disposal, and (2) treatment of groundwater at the Metropolitan Wastewater Reclamation District POTW facilities in lieu of building a new treatment plant on site. The City fully supports the proposed changes to the ROD described in the Explanation of Significant Difference (March 1997) as being environmentally sound and consistent with the goals to be achieved by the ROD. 514 City ofLittleton

Marc E. Herman Page Two April 2, 1997

The City believes that on-site treatment of contaminated materials in the former tire pile area to meet RCRA Subtitle C and D requirements of the Solid Waste Disposal Act and the Colorado Hazardous Waste Act is preferable to off-site treatment and is consistent with current waste disposal practices and policies. The City further believes that off-site treatment of contaminated groundwater pursuant to the conditions set forth in the Explanation of Significant Differences (March 1997) is preferable to on-site treatment because of the experience and operational capabilities of the Metro Wastewater Reclamation District facilities in controlling and treating such wastewater to meet discharge permit limitations.

For the foregoing reasons, the City supports the proposed changes to the ROD as set forth in the Explanation of Significant Differences (March 1997) and urges adoption of those changes.

Sincerely,

Andrew C. McMinimee City Manager 515

GABLEHOUSE & EPEL A LAW PARTNERSHIP OF PROFESSIONAL CORPORATIONS

1050 SEVENTEENTH STREET j (303)572-0050 SUITE 1730 (800)818-0050 DENVER. COLORADO 80265 FAX (303) 572-3037

May 12, 1997

Marc E. Herman 2i p ~ Remedial Project Manager £f ^' .~ U.S. Environmental Protection Agency ~> Mail Code 8EPR-SR 999 18th Street, Suite 500 Denver, Colorado 80202

Re: Lowry Landfill, Second Explanation of Significant Differences for the Lowry Landfill Superfund Site Record of Decision

Dear Mr. Herman:

We represent Cummins Power, Inc. ("Cummins") in matters relating to the Lowry Landfill Superfund Site. On behalf of Cummins, we would like to take this opportunity to offer our comments on the Second Explanation of Significant Differences ("ESD") for the Lowry Landfill Superfund Site Record of Decision ("ROD").

We note that EPA is considering physical drying/controlled aeration and enhanced bioremediation for the treatment of contaminated materials in the former tire pile area. Cummins believes that onsite treatment of these wastes to meet RCRA Subtitle C and D requirements will be more cost- effective and efficient than the originally proposed offsite treatment and disposal. Onsite treatment will also be significantly safer than the originally proposed remedy. Cummins, therefore, supports EPA's proposal for the former tire pile area.

Cummins further believes that the piping of pre-treated ground water offsite for treatment at the Metro Wastewater Reclamation District ("Metro") facility is an improvement over the originally proposed remedy in terms of both cost and safety. Using an existing facility for part of the groundwater treatment avoids the cost of new construction or extensive upgrades. Metro's authority to enforce discharge permit requirements under the Clean Water Act will also ensure the protection of public health. For these reasons, Cummins supports EPA's proposal for treatment of groundwater at the Metro facility.

Cummins has reviewed the proposals put forth in the Second ESD and believes, that the remedy remains protective of human health and the environment, complies with applicable or relevant and

PRINTED ON RECYCLED P.APER 516

Marc E. Herman Lowry Landfill, Second ESD Page 2

appropriate requirements, and is cost-effective. Cummins supports the proposed changes to the ROD contained in the Second ESD. Thank you for this opportunity for input.

Sincerely,

Donn L. Calkins for Gablehouse & Epel

DLC/dc cc: Joe Vranka, CDPHE - HMWMD Andy Limes, CT Power, Inc. 517 1-70 Corridor Chamber of Commerce Post Office Box 312 • Strasburg, Colorado 80136 • (303)644-4607 Located in the Bennett Community Center. 1100 West Colfax (west of Bennett on US. 36)

May 21.1997

Marc Herman 8EPR-SR Remedial Project Manager 989 18th Street, Suite 500 Denver, CO 80202-2466

Dear Mr. Herman,

In response to the proposed *Lowry Landfill Superfund Site Second Explanation of Significant Differences for the Record of Deanon", we, as community busmesis members, landowners and rural residents, request mat the public comments period be extended 60 from May 22,1997 to end on July 22,1997. so mat we can review the inferm»tinn provided to u> in the libraries. We have not had sufficient time to get access to mis pifiuiinfltinn_ an«i send our comments to you co flit* subject.

Thankyou! Sincerely,

1-70 Corridor Chamber of Commerce Wil Chase, President

WC/Igc

Serving the communities of Watkins • Bennett • Strasburg • Byers • Deer Trail J=HP 518 ^HEALTH CARE '97

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June 27, 1997

Marc Herman 999 iRth Street Denver, Colorado 80702 Dear Marc, As concerned citizens along the 1-70 Corridor east of Aurora, we asV- that you take into consideration the possibility of contaminated SLUDGE being distributed in our area on our farm lands. We ask that you follow OSHA regulations as we have to in our health industry and that contaminants be placed in the proper containers and taken to the proper authories. Thank you for your assistance. Sincerely, xx

7A*" 5, Patty Strasburg. Colorado P0i?6 OCAW OIL, CHEMICAL & ATOMIC WORKERS INTL. UNION, AFL-CIO

ROBERT E. WAGES PRESIDENT ERNEST J. ROUSSELLE June 29, 1997 SECRETARY-TREASURER L. CALVIN MOORE VICE PRESIDENT Mr. Marc Herman (SEPR-SR) JAMES K. PHILLIPS, JR. Remedial Project Manager VICE PRESIDENT U.S. Environmental Protection Agency 999 18th Street, Suite 500 INTERNATIONAL Denver, CO 80202 OFFICE 255 UNION BLVD. LAKEWOOD. CO 80228 Dear Mr. Herman: MAO. P.O. Box 281200 On May 6, 1997, Richard Hillier of the OCAW Health and Safety Department LAKEWOOD. CO submitted comments to you concerning the objections of the Oil, Chemical & Atomic 80228-8200 Workers International Union (OCAW) to the plan to treat waste from the Lowry Superfund site at the sewage treatment facility operated by the Metro Wastewater 13-987-2229 :: 303-987-1967 Reclamation District (MWRD). Since that time, OCAW has discovered additional documents at the EPA Records Center which reinforce many of the concerns raised in Mr. Hillier's letter about the possible presence of significant and dangerous levels of radionuclides at the Lowry Superfund site. The following are written comments submitted by OCAW in addition the comments submitted by Richard Hillier.

The first document, which is attached, consists of a December 13, 1991 letter authored by John D. Faught of the Lowry Coalition of which MWRD was a member at the time the letter was written. Accompanying Mr. Faught's letter was a copy of an evaluation of radioactive wastes at the Lowry Landfill prepared by Harding Lawson Associates, and a letter written by William Wilson on the illegal dumping of radioactive waste from Rocky Flats at the Lowry Landfill. The assertions made in Mr. Faught's letter and in documents which accompanied the letter include:

(1) significant quantities of man-made radionuclides from the Rocky Flats nuclear weapons facility are present at the Lowry Landfill; (2) there is evidence of illegal disposal of radioact've material from Rocky Flats at the Lowry Landfill; (3) levels of Americium 241 and Plutonium 239/240 detected in wells at the Lowry Landfill are 10 to 10,000 times greater than background levels reported for Rocky Flats by EG&G; (4) the owners and operators of Rocky Flats have significant liability for the dumping at the Lowry Landfill; 521

(5) any treatment alternatives will result in the generation of hazardous residuals, some of which may contain concentrated levels of radionuclides.

The assertions contained in these documents support OCAW concerns over the existence of significant and dangerous quantities of man-made radionuclides at the Lowry Landfill. Please answer in writing each of these allegations noted above. In addition, please provide copies of any and all EPA correspondence pertaining to the aforementioned letter from John Faught and all of the assertions therein. OCAW has so far been unable to locate a detailed trail of correspondence from EPA pertaining to the assertions raised in Mr. Faught's letter. We find this highly unusual since the assertions made in Mr. Faught's letter were very serious, especially coming from PRPs. Please provide copies of any and all studies conducted to specifically answer of refute the assertions made by John Faught and the Lowry Coalition.

Since these assertions concerning the existence of significant quantities of radioactive waste at the Lowry Landfill were made by entities who comprise the Lowry Coalition, including MWRD, and who now support the plan to treat waste from the Lowry Landfill at the MWRD sewage treatment plant, please explain in writing from EPA's perspective the series of events and discussions which led members of the Lowry Coalition to support the current plan to clean up the Lowry Landfill. Making knowingly false statements to federal officials is a crime under federal law. If EPA thought the assertions made in the letter from John Faught were false, did EPA attempt to bring any charges against Mr. Faught, MWRD or other entities comprising the Lowry Coalition? If EPA made no attempt to bring charges against Mr. Faught or members of the Lowry Coalition please explain the reason for EPA's inaction.

The second document, attached, consists of an end log from the Lowry Landfill indicating that radioactive waste from Rocky Flats was dumped at the Lowry Landfill. The third document, also attached, consists of another end log from the Lowry Landfill indicating that highly toxic hydrazine from Martin Marietta was dumped at Rocky Flats.

As an EPA official, you have specifically denied that man-made radioactive materials from Rocky Flats were dumped at the Lowry Landfill. You have also said that no hydrazine from the Martin Marietta facility was dumped at the Lowry Landfill. Please explain in writing the discrepancy between your statements and the official end log documents from the Lowry Landfill.

You are undoubtedly aware that there is growing public skepticism of the plan to treat the waste from the Lowry Superfund site at facilities operated by MWRD. Attached are resolutions unanimously endorsed by the executive boards of the Colorado AFL-CIO and the Denver Area Labor Federation to "oppose the current plan to treat waste from the Lowry Superfund site at MWRD facility which could result in radioactive material being spread throughout the Denver metropolitan area and in Eastern Colorado, thus endangering the health and safety of the workers and the public at large." OCAW 522 maintains that the Lowry Landfill site has not been adequately characterized and that no one, including the EPA, knows what will be in the toxic soup to which workers and the public will be exposed.

OCAW is deeply concerned about the health and safety risks to MWRD workers. As you are aware, these workers are not covered by OSHA. Currently, the lab workers are not even protected by a collective bargaining agreement due to the intransigence and union busting practiced by MWRD management. Trust and confidence that MWRD District Manager Robert Kite will look after the health and safety of workers is non- existent.

OCAW believes the plan to treat the Lowry Superfund waste at the MWRD facility is reckless and irresponsible. We respectfully ask that you provide written responses to all of our comments and requests.

, Soecial Projects Director cc: Robert E. Wages, President Greg Mooney, General Counsel Don Holmstrom, President, Local 2-477 Joe Anderson, Acting Director, Health and Safety Richard Hillier, Industrial Hygienist 523

ADMINIoiMMilVERECORD JHE LOWRY 233468 COALITION -'-FILE PLAN

PO Bos I342S Denver. Colorado 80201 December 13, 1991

vr,\ HAND pg Robert L. Duprey. Director Environmental Protection Agency, Region Hazardous Waste Management Division One Denver Place, Suite 1300 999 18th Street Denver, Colorado 30202-2413 Re: Department of Energy and Department of Defense/ De Minimis Settlement_ _ ^--. •••_ Dear Mr. Duprey: It is our understanding that the Environmental Protection Agency ("EPA") is presently negotiating with certain potentially responsir ble parties ("PRPs") at the Lowry Landfill Superfund site with regard to a de minimis settlement, it is further our understand ing\ that the PRPs participating in the negotiations are those eligible under EPA's de minimis criteria published on August 1, 1991. The Lowry Coalition objects to any consideration of the Department of Energy ("DOE") . or any of its contractors at the Rocky flats Plant, including Rockwell International, Inc. ("Rockwell") and Dow Chemical Company ("Dow"), for de minimis settlement. The informa- tion and data available to EPA demonstrates that man-made radionu- clides which only could have originated from the Rocky Flats. Plant V are present in significant quantities at Lowry Landfill. Such man-1-; made radionuclides isay have a significant impact on the potential "' 3J remedies at Lowry. Accordingly, it is inappropriate to consider DOE, or any other entity associated with the Rocky Flats Plant. Cor 10 de minimis settlement at this time. tn The Coalition also objects to any consideration of the Department of Defense ("DOO"). or any of its related entities, including the U.S. Air Force, U.S. Array, U.S. Veterans Administration Center and U.S. Defense Logistics Agency, for de minimis settlement. OOO, and its related entities, used the area in and around Section 6, known as the Lowry Bombing Range, for over 20 years prior to the transfer of Section 6, and other sections, to the City and County of Denver ("Denver") in 1964. The full extent of DOO activities, including the disposal of wastes on Section 6, has not been determined and. therefore, DOO and its related entities should not be considered for dc minimis settlement. 524

Robert L. Duprey, EPA December 13',•"1991 • —•

DO£AP.ockwel 1/Oow Rockwell, the operator of the Rocky Flats Plant from June 30, 1975 to late 1990, is among the Lowry Landfill PRPs eligible for de minimis settlement based upon EPA's criteria. A review of information and data available to EPA demonstrates the inappropri- ateness of allowing Rockwell, or DOE, to avoid its share of liability for Lowry Landfill through de minimis settlement. The information and data available to EPA include: (1) Rockwell's 104(e) response which leaves many questions unanswered as to the volume of wastes disposed at Lowry Landfill and the constituents of those wastes; (2) other information which presents significant evidence of the disposal of radioactive materials from the Rocky Flats Plant at or near the Lowry Landfill site; .and (3) the site data, as developed through the investigations of EPA and the Coalition, which reflect elevated levels of man-made radionuclides attributable only to the Rocky Flats Plant. •;

104fe) Response/Other Information t In its initial 104(e) response, dated July 1, 1986, DOE denied having knowledge of the shipment of any waste material to Lowvy Landfill and claimed that any off-site waste shipments from the Rocky Flats Plant were sent to DOE facilities in Idaho and Nevada. The DOS further claimed that many documents had been destroyed and were no longer available. In a follow-up letter dated August 18, 1986, however, EPA notified DOE that its 104(e) response was inconsistent with information, provided in a 1979 State of Colorado Industrial Waste Survey in which DOE reported that it transferred paint thinner and motor oil to waste Transport Company, a transporter known to have taken wastes to Lowry Landfill. Although DOE claimed in the Survey that the materials were shipped off-site for "reclamation," EPA asked for an explanation. On November 13, 1986, DOE revised its 104(e) response acknowledging that it had shipped paint thinner and motor oil to waste Transport Company. The DOE also acknowledged that it had shipped to "unknown" recipients several waste materials. These wastes included: scrap batteries, machine oil, coolants, solvents, cleaners, transmission oil, lead, silver, liquid mercury, beryllium scrap, photographic solution, trichloroethylene, paint primer and thinner, tires, acids and other miscellaneous chemicals and resins. The DOE further reported that in most instances the annual quantity of these wastes shipped off-site was unknown. 525

Robert L. Duprey, EPA December 13, 1991 Page -3- ' "' ' '" "" In its December 1990 Waste-In List, EPA attributed to Rockwell 213,180 gallons of wastes shipped frc.-a the Rocky Flats Plan:: to Lowry Landfill. On February 15, 1991, Rockwell responded to EPA's Waste-In List claiming that it was not responsible for any waste shipments prior to June 30, 1975, because Dow Chemical Company ("Dow") was the DOE operating contractor at the Rocky Flats Plant prior to that date. Based on Rockwell's response, EPA in its May 1991 Waste-In List reduced RockveLl's volu.-ae to 55,630 gallons described as paint sludge, waste oil ar.d solvent. This apparently is the same volume and description of materials included in EPA's most recent November 4, 1991 Waste-In List. The history of EPA's 104(e) requests to DOE and Rockwell, and their responses, leaves several questions unanswered: 1. EPA identified on its "Lowry Landfill File Review Fo.rm" (November 4, 1990) (Attachment A), prepared from Rockwell's 104(e) response and other information, three waste streams attributable to Rockwell in addition to paint sludge, waste oil and solvent. These waste streams are identified as follows: Grease — Solvents -Haz.-2.2(a)(k) Waste Chemicals.— Haz.-2.2(e) 4 Evaporator Salts -- Haz.-2.2(a), Radioactive Because the volumes of these wastes are listed as "unknown," however, EPA attributes no volume whatsoever to Rockwell. The failure to take these waste streams into account without further explanation unfairly places Rockwell's, and therefore DOE's, liability on other PRPs. 2. EPA's failure to include the waste streams identified in its Lowry Landfill File Review Form is even more egregious when other information is readily available. For example, one document1 prepared by Rockwell in 1987, reports the annual volume rates and radionuelide concentrations of waste streams virtually identical to those indicated on EPA's Review Form. Table 1.0 (Attachment B) is a summary of those waste streams. As readily noted, there ace a number of waste streams identified as "solvents" and "chemicals." Many of the waste streams are generated in substantial volumes and contain high levels of radionuclides. Additionally, one item, "Cemented Salt Residue," is generated at a rate of 2 million pounds/year and contains the following radionu- clides: Pu-239, 160' pCi/g; Am-244, 83 pCi/g; U-233, 25 pCJ./g ; U-238, 88 pCi/g; and H3, 1300 pCi/g, This waste stream is simi.lar to the "Evaporator Salts," which were disposed off-site. EPA attributes no voluree to Rockwell for this waste stream listed on EPA's Review Form.

'"Waste Stream Identification and Characterization, U.S. DOE Rocky Flats Plant, Rockwell International/Roy weston, April 6, 19S7; Overview and Areas 1, 2{Vol. 1 and 2), 3, -;(Vol. 1-6)" 526

Robert L. Duprey, EPA December 13, 1991 Page -4- -• • o -• ^ 3. EPA has not attributed to any PRP wastes shipped off-site 3<= °^ —=- fron the Rocky Flats Plant during the period of 1965 through June 5 30, 1975. During this period the Rocky Flats Plant was operated by S S" ' Dov and wastes were being received at Lowry Landfill! To our knowledge, EPA's 1986 104(e) request was not even issued to Dow. Nor has EPA determined the amount or nature of wastes Dow may have disposed at or near Lowry Landfill prior to 1955. A former Colorado State Patrolman, W. H. Wilson, reported to the Colorado Department of Health ("CDH") by letter "dated April 20, 1977 (Attachment C): In the year 1961 when I was a Colorado State Patrolman on patrol of State Highway 30 (east of Buckley Naval Air Station) I had the opportunity to stop for a PUC check a Boulder County Milk Transport Truck that bore Boulder County License plates. The driver stated he was not hauling Boulder milk but rather "polluted radioactive waters" from the P.ocky Flats Plant to areas near the missile sites under construction for disposal. He said they disposed the polluted waters in any old valley or hole on the range by government agreement. The missile silo sites were located in the adjacent section to the Lowry Landfill and were accessed frora Quincy Road which forms the south boundary of the Landfill. Mr. Wilson also reported: The hauling of polluted waters frora the Rocky Flats Plant continued, and I confirmed it was very dangerous material frora a Army Reserve Officer friend who was employed at Dow. In approximately 1964, or later, when employed in other specialized law enforcement work, the milk company trucks were observed to be hauling the waters to old missile site silos or burial grounds near sites on the Buckley Missile Range. Mr. Wilson was apparently interviewed by EPA representatives in 30 1985. In a handwritten memorandum dated November 3, 1985 (Attach- ment D), John Haggard of EPA reported that Mr. Wilson stated that 10 wastes from Dow were dumped in drainages, "including the drainages in Section 6." Mr. Haggard recommended follow-up by EPA. In spite 01 of this recommendation, Dow was not issued a 104(e) request by EPA in 1986. In summary, many questions are left unanswered by DOE and Rock- well's 104(e) responses. The questions concerning man-made and other radionuclides in the waste streams known to have been disposed at Lowry Landfill from the Rocky Flats Plant need to be answered before DOE, Rockwell or Dow can be released fron liability at Lowry Landfill. 527 I 3' fi. = 5" 10 ~ ~ v

Robert L. Duprey, EPA December..13, .1991 .. . . . _... -...... Page -5-

Site Data 3 n •a EPA did riot conduct.any radionuclide analyses of samples collected during Phase I of the Remedial Investigation ("RI")- Radionucl. ide analyses, however, were performed for all five quarters of sampling during Phase II of the RI and also during the Additional Site Characterization ("ASC") conducted by the Coalition. The Coalition requested that Harding Lawson Associates (."HLA") review the data and evaluate the presence of radionuclides. HLA's report is enclosed as Attachment E. Because of the presence of .•nan-made radionuclides in the Phase II and ASC samples, and the ici.-ainer.ee of a de minirais settlement which could include Rockwell, HLA was asked to evaluate atomic weights greater than 238 which result from neutron bombardment associated with nuclear fission. Nuclear fission is generally associated with commercial nuclear power production and production of sourr.e materials for nuclear weapons manufacture. HLA's report contains evaluations of the site data for Am-241, Pu- 239/240 and Pu-241. To our knowledge, the only local source of these man-made radionuclides during the period of 1960 through 1980. would have been the Rocky Flats Plant. Based upon its evaluations/- HLA reached the following conclusions: 1. Analyses of the waste pits and shallow and deep groundwater samples taken during Phase II of the RI and the ASC show elevated levels of Am-241, Pu-239/240 and Pu-241. 2. All three man-made radionuclides were detected in shallow groundwater monitoring wells located at the south and southwest margins (upgradient) of the Lowry Superfund site. 3. The levels of Am-241 and Pu-239/240 detected in wells on. i Lowry Landfill are 10 to 10,000 times greater than the background' levels reported for the Rocky Flats Plant.by EG4G, the current DOE contractor. 9 4. All three man-made radionuclides (Am-241; Pu-239/240; and 10 Pu24l) were detected in the upgradient wells at Lowry Landfill at concentrations 50 to 5,000 times greater than background levels ui reported for the Rocky Flats Plant by EG&G. 5. The occurrence of Am-241 and other man-made radionuclides in the upgradient shallow groundwater monitoring wells located in the south and southwest of the site along Quincy and Gun Club Roads are consistent with reports that tanker trucks from the Rocky Flats Plant disposed of liquid wastes along these roads during the early 1960s. 528

Robert L. Duprey, EPA December 13, 1991 •Page -6-" ' ' In addition to evaluating the site d^ta, KLA was asked to assess the impact of the man-made radior.uclides on potential remedies for Lowry Landfill. HLA concluded that the occurrence of the man-made radionuclides could have a deleterious impact on the ability o£ potential remedial alternatives to achiove ARARs and the costs associated with residuals management and groundwater collection and treatment. The Lowry Coalition has not yet completed its review of the implications of the presence of man-made radionuclides at Lowry Landfill or the information available to implicate DOE, Dow or Rockwell. Enough information is available, however, to demonstrate that the Rocky Flats Plant and its owners and operators have significant liability and responsibility at Lowry Landfill. Consideration of any of these entities for de minimis settlement is inappropriate. DOD/Related Facilities In 1940, the City and County of Denver donated property known as the Lowry Bombing Range to the Department of War.2 "The property, including Section 6. was used for a number of years for personnel training and the testing of explosives and ballistics. In 1959, •• the use of the site as a bombing range was discontinued and" construction was commenced on the Buckley missile complex. A portion of the Lowry Bombing Rar.ge, including Section 6, was transferred back to Denver by the federal government in 1964, for the express purpose of use as a sanitary landfill. In fact, the federal government retained a reversion interest if the property was not used as a sanitary landfill.3 Historical aerial photographs show activities on Section 6 prior to the transfer to Denver in 1964. As presented in the HLA report (Attachment E) , 1950 and 1956 aerial photographs show a surface' disturbance at the south boundary of the Landfill. A 1963 aerial photograph (Attachment F) also shows activity at the 35 south end of Section 6. The photograph shows a constructed facility, including a pond containing liquids. Well MW22 in the 10 area of the location of this facility now contains high levels of Am-241 and Pu-241. EPA, to our knowledge, has not determined the origin of the pond or its source. Ul

2Preliminary Assessment, Missile Silo Sites, Arapahoe County, Colorado, prepared by Austin Buckingham and dated September •;, 1991. JQuit Claim Deed, between United States of A-crica and City and County of Denver, dated July 15, 1964. 529

Robert L. Duprey, EPA December-1-3,- 1991 - • • • - •• • • •• ••.•.-•• ,.....••-•..•••••• ••• - •• Page -7- It is also evident that the Air Force disposed of waste materials at Lowry Landfill, but the true volumes remain unknown. In its 104(e) response, the Air Force stated that records of off-site disposal for the period of 1965-1980 have been destroyed. It was reported, however, that interviews with former employees confirmed shipments to Lowry Landfill from Lowry Air Force Base and Buckley. Additionally, there reportedly was an informal agreement' bef./een Lowry Air Force Base and Denver that allowed the Base to dispose of wastes at Lowry Landfill for free. Accordingly, no records were kept of these disposals by either party. To our knowledge, EPA has not investigated the activities of federal PRPs, such as DOE and DOD, to determine the full extent: of their contribution of wastes to the Lowry Landfill. The Coalition has sent Freedom of Information Act requests to various federal agencies in an attempt to obtain information which would explain the many unanswered questions, including why man-made radionuclides are present at the Lowry La.-.dfill and the only known source is the Rocky Flats Plant, but DOE and its contractors deny any responsi- bility. To date, the Coalition's requests have been met with.- resistance by these agencies. We have recently issued new requests and hope to receive more forthcoming responses. \ Until such time as the contribution of DOE, and its contractors, 4 and DOD, and its related entities, to Lowry Landfill is determined, these entities should not and cannot be eligible for de minimis settlement. Furthermore, EPA has a statutory responsibility under the Comprehensive Environmental Response, Compensation and Liability Act oC 1980 to determine the volume and nature of the wastes contributed by these federal PK?s. we appreciate your consideration of these comments and are prepared to answer any questions. i Yours very truly, 39 10 Ul Enclosures cc: Angus C. Campbell, CDH Nancy H. Mueller, EPA Brenda L. Harris, Esq., EPA • I - CWMXXOGICtl CfW(»»'0* |WM«H»l 10* «OCK«(U lull tAHlieM OAlt: M/A lAlfil 0*11: M/* M DOC 0 S IVPf D»i( S. IOC v 79 3.000.00 OS-3-OK7AOOOI »5/IO/O« M Oil AM 3.000 00 V JV 10/00 06 OIL 1 MH.VIMI 3.000 00 y oc Oil AMD SIXVtMt soo on y o*. r.ooc 03 V DO c:i ii P. 'W CO v fV V 4.1S-6-OOCO J7/OO/00 y> ox r V 79 .'•/37,'JS V. • >oi •••£!.•: G • ^v **«* rv/oo/oc »-'.• - * f C v? 7? •o/oo/o•9/^0 j/»o; -s . : rcxi 66 OV-b-OX-l

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!j 6u;aq juaiunaop gqj jo X;i| 34J 6S,3| S| ^P Table 1.0 1 * . N" utllVt •••!•• Radionuchde Concentrations in Various 239470 W ; r/^Sr Watle SlrcamJ al «hcRFp0 > i o't.v/O'N I ..- Kndionnclide Concent rationalJlO/l) Ann. Vol. Onsile Cross Gross W»nc SKcarn Sample No. Process Gal./vr Disposal Loc. Aloha Beta JV2J9 Am-241 U233.4 U238 JJ,

Heat Quench Walcr 04900 Treatment 40.000 Bldg. 374 130.000 140.000 0.75 -0.03' 3400 50.000 100

1 Procets Wane Composite j (Organic*) 05250 Wane 500.000 Bldg. 374 11.000 16,000 110 41 1600 8.300 -30 ) i Piooe«s Waste Composite *) (chemicals) 05320 Waste 22,400 Bldg. 374 26,000 46,000 14 11 1400 5.800 -70

Wulc water Sewage/ ^K Sludge SP995B Treatment 78,000lb/yr Mixed Waste 95pCi/g 7R|,Ci/g UpH/g 2.2pCi/g IRpf'i/g 33pC.7g 120

Waitcwaler Sewage/ Sludge SP995D1 Treatment 78,000lb/yr Mixed Waste 130pCi/g 180pCi/fi 7.4pCi/g 1.6pCi/g 24pCi/g IJOpCi/g' 120

Clean. PaJnt. r Rags wjih TOE 09590 Tools 50lb/yr Landfill 30pCi/g l.-lpCi/g I3pCi7g 0.43pCi/g 0.25pCi/g 0.40pCi/g -730 r Composite Waste Oil 11120 Waste Oil 26,400 Bldg. 774 2.500 5.100 •0.4 -1.3 360 2.800 60

Watte Composite 'i Solventyorganic 11170 Solvents 100 Bldg. 774 1.100 980 -0.8 -1.2 120 810 -30

Sump Cooling Water > Sludge 11890 Table 820lb/yr Landfill 65pG7g 1 IOpCi/r. IMVipCi/p -0.03nCi/g 7.2rCi/g 27pCi/g 30 ^ ** >fc ^ Developer/Fixer Photographic , <\ T Baths 13651 Enlargement 20 Bldg. 374 350 3.600 0.10 0.03 -0.9' O.lt.: 90 4 •> «> Non line gen. «s " Wane Oil 13700 in Manufac. Did*. 550 DUlR.774 * 74 2R • i: R.O .. .. .so ^ '

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fHI^INWV luauinaop am jo'x»!i«nb raiaszaMi iwAvniiMur , , p jj -aajjou WftSiMEISi ora ii aij 0 9fl 6| SS3J SI !J eqj ji :30IION Table 1.0 (cont'd.) Page 2 of 3

Ann. Vol. Onsile Gross Gross AJpha FVta Pu-2M Am-244 U233 U238 Waste Stream Sample No. Process QaLm Disposal \juC, — • H,

Scinlillation Medical Analysis Fluid 03010 Ub» 100 Mixed Waste 4 73 0.02 0.0 1.1 2.7': 2700

Machining of KimwipciA Rap 04120 Metals "580lb/yr Mixed Waste 1400pCi/g 2100pCi/g O.OIpCi/g O.OpCi/g 130pCi/g MOOpCi/g 600

Lubricant for CooUnl 041300 Machining 1.300 Bldg. 774 2.100 3.000 -.02 0.08 1ROO230 360

Wajle Oil and Machining of Coolant 05170 Melnls 1.980 Bldg. 774 18.000 33.000 0.46 0.67 440 3700 20

Machining of 9200 50 Wa«le Oil 0517001 Metals 1,980 Bldg. 774 10.000 17.000 1 2.4 1200

Proc. Waste Pumping 3700 80 . (Chemicals) 05230 Station 150,000 Bldg. 374 4.600 5,000 0.02 -2.4 510 Wfl» Pumping Pioc Waste 4 (Chemicals) 05320 Station 22,400 Bldg. 374 3.6x10' 4.6x10' 1.4 x 10' 1.1 x 10 1.4x10* 5.8x10* -

Cemented Salt Evaporation KHpCi/ji 1300 Reiidue 09140 of Liquid 2 x Kflb/yr Mixed Waste 240pCi/g 170pCi/j; If.OpCi/g «8pCi/g 2.

Nitric Arid (with Ag) 14000 Plating 150 Bldg. 374 16.000 24.000 0.61 C.56 2200 •-; ~ J> ~t> Caustic -vb 10 Oakile 14230 Geaning 200 Bldg. 374 420 -300 0.12 -0.04 2.6 30^ i Waste DC greasing 1500 -40^^ Solvtnt 14510 Metal Parts 55 Storage 1.900 5.600 3 1.7 220 vt^\> Chemical 1. -0.06 14 51 •2.0 fc Waste Acid 14570 Mill Beryllium 10 Bldg. 774 , ^

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^HB 1 i*fl50MV«iiPi r•• S• ^m Zr •^• Hium IMIB VI^iB B W(iHiKH V V«MH •rfMIA 1<\Il M vdkvl \l IIIIN(MJ IM 3U1^0^^6 «*| }v| •aopo» ^i ^ tSSKti Vf£m&m*immlm& e>iu« ^^^H in<*i*\ a6euii UJIM oin n Table 1.0 (confti.) 3 of J

I Ann. Vol. Onsilc Gross Gross W»5ic Stream Sample No. Process Cal./vr Disposal Loc. Alpha Ikta Pu-239 Am-244 U233 U2J8. ^

Machining 3.2 82 : 20 Cutting Oil 14320 Mclal Parts 2,750 Bldg. 774 370 780 -0.1 4

Machining 70 Machine Coolant 14320 Metal Parts 7,800 Bldg. 374. -46 1.600 0.2K 0.13 -0.24 -0.1

Filtered Liq. Process Waste 14371 Composite Waste 955,400 Bldg. 374 2.900 7,200 -0.4 0.7 330 2600 270 ; Filtered Liq. ! Composite 1300; 1100 Process Waitc 14370 Waste 955,400 Bldg. 374 933 1,600 -2.04 -0.02 180

Cyanide Cyanide Treat 0.23 0.09 52 390 180 Rime 14350 in Plating 11,300 Bldg. 374 260 430

Add Acid linei un 420 ; 10 RJn*e 14360 in Plating 47,300 Bldg. 374 370 490 -0.12 -0.02 57

Spent Electrolyte Electrochemical 3400; 480 14650 Machining 100 Bldg. 374 3,700 7.500 -0.01 0.07 470

Geanlng Solution Germing Metal 8.7 ; 340 (TCE and OaIdle) 14660 Parts 1000 Bldg. 374 6 3KO 0.01 0.04

Rngs (with paint Gean Mixed Waste 20pCi/g 38pCi/p J.RpCi/g 0.38pCi/g O.I7pG/g 1.2pCi/g 50 thinner) 11070 Paint brushes 200IWyr 0 i P.tnt Thinner 11080 Soak Paint 10 Bldg. 774 470 1,100 -0.1 2.2 54 510

1) Source of data is analysis of samples from 'Wailc Stream Identification and Characterisation' Reports prepared by Roclcwcll/We: on. '<

2) Negative concentrations are indicative of instnsitivity of sample analysis. ± variability is wide on sample analyses. , §

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239471

December 13. 199!

18376.053.10 John D. Faught & Associates 717 Sevemeenth Street. Suite ISSO Denver. CO 80202 ADMINISTRATIVE RECORD

Gentlemen: FILE PLAN Preliminary Evaluation of Potential Department of Energy Radioactive Wastes Lowry Landfill. Arapahoe County. Colorado In accordance with your request. Harding Lawjon Associates (HLA) has- reviewed the radio- isotope data developed as part of the Remedial Investigation/Feasibility Study (Rl/FS) for Operable Units 1 and 6 at Lowry Landfill rejative to the occurrence of manmade radionuclides associated with nuclear weapons manufacturing. Specifically, we have conducted the following evaluations: 1. Identified manmad; radionuclides detected in waste-pit liquid and groundwater at the site that arc associated with nuclear weapons manufacturing and testing. 2. Compared the detected concentrations of these manmade radionuclides to background levels resulting from atmosphere testing as reported by EG&G for (he Rocky Flats facility near Golden. Colorado. 3. Evaluated the occurrence and distribution of these manmade radionuclides relative to (I) the disposal of materials in waste pits between 1967 and 1980 and (2) pre-1967 activities at the site. r- •>. Conducted a preliminary qualitative assessment of the potential impacts that the occur- rence of manmade radionuclides associated with wastes from nuclear weapons manu- facturing may have on remedy selection and implementation.

On the basis of these evaluations, we have concluded that the occurrences of manmade radion- uclides at Lowry Landfill cannot be attributed to background levels associated with atmospheric 10 testing of nuclear weapons but are most likely associated with disposal associated with nuclear weapons manufacturing wastes at or near Lowry Landfill. From the areal and vertical distribu- tion of the occurrence of these radionuclides. we have also concluded that their origin at the site results, in part, from activities associated with disposal in the waste pits between 1967 and IS'80 and. in part, from disposal outside of the waste pit/refuse area, potentially including disposal activities conducted at or adjacent to the site before 1965. Finally, we have concluded that the presence of manmade radionucl'ides associated with nuclear weapons manufacturing will havi; a significant impact on the scope, fcasibificy and cose of any containment, treatment or removal actions implemented as part initial remedial measures, operable unit remedies, or a sitewide remedy. A summary of ihe evaluations used in developing these conclusions is presented below.

Attachment E M 535 o C .»< ;- <• r- 3:2.~S-=;

Harding L>v*ion Atiociaict

Drcrnter I.".. 1991 ISS*6.05S.IO John D. Fausht

IDENTIFICATION OF MANMADE RADIONUCLIDES AT LO\VRY LANDFILL

Radionuclide analyses were noi performed during Phase I of the RI. During the first two quarters of Phase it of ihc RI. E?A performed gross alpha and teta ir.alyses and gamma spectroscopy on waste-pit liquid samples and the U and B series grov:r.dwater samples and alpha specuoscopy for specific radionuclides on a few selected samples. Diring the third, fourth, and fifth quarters of Phase II of the RI. The Lo\vry Coalition performed alpha spectroscopy analyses on selected groundwater s.imples each quarter with the end result b;ir.j that at least one groundwater sample from nearly all of the U and B series wells r.alyzcd by alpha spectro- scopy by the completion of Phase II of the RI. During the Addition:! Site Characterization (ASC) effort, all of the upgradier.t wslls w-re sampled and analyze* see by alpha spectroscopy. The wasie-pi: liquid was nlso sampled and analysed once by alpha ::••;:troscopy. and the C\V- " series wells, along with a few select 0700-series wells, were samplfi 2nd analyzed twice by alpha spectroscopy. From these analyses, a large number of radionuclides have been de:;::;d in waste-pit liquid. shallow ground water, and deep groundwatcr at Lowry Landfill (Tai'.j I). Currently, there are no data available relative to the occurrence and concentrations of s?i:ific radionuclides in other media (e.g.. waste pit solids, landfill solids, soil, and surface water) :: the site. All radionuclid?; at the site a_re either naturally occurring or are th; :i«ult of wastes from nuclear weapons manufacturing, commercial manufacturing, medi;:! services, and/or are the daughter products resulting from radioactive decay of radionuclide; :ontained in those wastes. The origin of certain radionuclides detected at the site cannot be rei.ily ascertained because they could be one or more of the following: naturally occurring i»o;:?es. decay products of naturally occurring isotopes, or decay products of manmade fission rroducts (isotopes of traasuranic elements or those with an atomic weight greater than :;•• .. Because the purpose of this document is to assess the likelihood tha: :he radionuclides detected at Lowry Landfill had their origin in the manufacture of nuclear wea;-:r.s. the evaluations presented in this document will focus on transuranics only. 30 Specifically, these evaluations will include the following: :41 ro Amcricium ^41 ( Am) Plutonium I.vj.'NO (:J9':<0Pu) ci Plutonium Ul (:

These nuclear fission products are generally associated with the pro:.:tion of commercial nuclear power and the production of source materials for and the rr.ir.ufaciuring of nuclear weapons. It is clear thnt wastes associated with commercial nuclear power are not the source of the transuranics detected at the rite for the following reasons: I. The radiation lc\cl! and radionuclide concentrations at th? «::* are too lo«- to suggest the presence of srcnt nuclear fuel components. 536 _,«< . <» r f s,~s-=

Harding Li*ri

Dc;-:r::l-(.T I.'. 1901 IKS~6.05S.tO John D. Pnuchi A;

I. Most of the site disposal activities occurred between 1965 and 19SO, before the genera- tion of any spent fuel from the only nuclear power generation plant (Ft. St. Vrain) in the region. In addition, the reactor at Ft. St. Vrain is a gas-cooled reactor, and it is unlikely that cooling waters or other wastes would have'beja generated from that facility. .". Storage, reprocessing, and eventual disposal of spent nuclear fuel from commercial power generation is strictly controlled by the Nuclear Regulatory Commission. J. There is no reported record of any waste material that migh: contain fission products from commercial reactors having been sent to the site. However, there is a record of waste oils and solvents having been sen: to the site froir the Rocky Flats facility. Because the manufacturing operations at that facility comprise fabrication of Plutonium metal and other metallic parts by machining, it is likely that contaminated solvents and cutting oils comprised the largest portion of the waste stream generated at Rocky Flats. Therefore, waste from Rocky Flats is the only credible source of the transuranics detected because of the tranjuranic species detected at Lowry. because there is no other plausible source . of those transuranicj. because they are not naturally occurring, because there is a history of the disposal of wastes from Rocky Flats at Lowry. and finally, because wastes similar to those disposed from Rocky Flats are known to contain transuranics.

EXTEN'TOFCROUNDtt'ATER POTENTIALLY REQUIRING REMEDIATION On the basis of limited sampling, manmade radionuclides have been cetected offsite of Section 6 and within deep groundwater within the site. Specifically, the following observations have been noted: 1. All three of these manmade radionuclides. in particular 1<:Am. have been detected in shallow groundwater monitoring wells located at the margins of the Superfund site. These wells include M\\'OOI. M \V003. M \V004. and NUVOOJ. M\V02. MW| I. M\v;2. M\v:.». U510. and 05*0. 2. One or more of these three radionuclides have also been detected in several deep to monitoring wells (including C~0~P3. C702QI. G\V105. and C\\'l 13). 01 The occurrence of these radionuclides at the margins of the site or within deep groundwater could increase the scope and extent of any groundwater remedy that may be selected for the site. :u 2<1 M I40 Tatle 1 present? a summary of the concentrations of Am. Pu, and - / pu detected in wajte-pil liquid, shallow groundwater. and deep groundwater at Lowry Landfill. Table 1 also presents the range of concentrations of these elements in background groundwater at the U.S. Department of Energy's (DOE) Rocky Flats Plant. The background \alues reported for Rocky Flats are the only available put'.ijhed background levels for these compounds. Comparison of the background ievelr of these radionuclides as defined by EC&G for the Rocky Flats facility to the levels of these samt radior.uclidcs directed at Lowry Landfill ir.iicaies that the levels of P 82 rtM*fcMihi

-6 -0060 -

<4mg liwton AttocJii«»

December l>, 1991 I8876.058.IO John D. Taught It Page 4

"'Am and :"/"40pu detected at Lo»-ry Landfill are IO to 1 0.000 litr.ti greater than the average or maximum background levels reported Tor Rocky FbU. Therefor*. the occurrence of these radionuclides at L*wry Landfill cannoi be attributed to background Itvtlj associated with aboveground. atmospheric testing of nuclear weapons. Comparison: of the concentration! of 2

Occurrence and Distribution of Manmade RadtpnucHdn »t ^owrv 1.?ndfilf

Amcncium-r4l and s>»/s«j»u were detected in the waste-pit liquid ind shallow groundwater (OU I) and the deep groundwater (OU $) operable units at Lowry Landfill. Ptutonium-241 was not detected in the waste-pit liquid bo» was detected in shallow and 2eep groundwater at the site. Alt three of these radionuclidcs were also detected in the upjniiem wetls at Lowry at concentrations SO to 5000 times greater than background levels reported for Rocky Flats.

D'tnibutitm of M»nmadf Radlonuellde* w^Vm ihf VVaytf Pit/R/fujj- Area J>lutonium-i4l was not detected in Mine-pit liquid, however, it «i> delected in five shallow gfoundwater monitorlnc wells completed within the waste-pit area. Americium-241 was detested in six waste-pit well points and one shallow monitoring wt.'I within the source area. Plutonium 239/240 were delected in 3 waste-ph well points and 1 1 {Hallow groundwater monitoring wells within the w-aste-pit area. The occurrence or these radionuclides is dominated by two general areas at the site: (I ) the northwest portion of the waiir pit/refuse area in waste-pit welt points \\T003 and WP70I and . shat^w groundwater monitoiing wells U70J and D?04 and (2) the ceatral portion of the waste pit.'refuse area in waste-pit well points WP002, WP7008. and XV'PIO.'A and shallow monitoring • ells t'706. B706. U707, U7IO. B7|0. and U7I I. These two areas trs dominated by waste pits (hat were used for disposal between 1976 and 1980. According to Rjck well's J04e responses. this period coincides with the period during which waste oils and sc-lventj from Rocky Flats were disposed of at Lowry Landfill. These three radionuclides were also detected in the .follow-in) area;: 1. Southeast and east central portion of the waste pit/refuse ar«3 (WP709. WP712. IP 02, and U703) 2. North and north central portion of the waste pit/refuse area (WP7 j 3 and \vp? 1 6) 3. Along Unnamed Crwk (WP007, \VP71S, and U504) 4. In shallow groundwater wetls at the toe of the landfill (UJCC-. U712, and GWi |2)

The waste pits in the southeast/east central area In which these marjr.ade radionuclides are present were used for disposal from t977 to 1979. Waste pits in the north/north central area that contain these manmadc radionuclides were used for disposal betwec: (974 and 1977 (WP7I6) and in 1980 (\VP7IJ). The timefrarnes in which these waste pits \\trt used for disposal is the

J P 93 538 3 !• a 3* If

December 13, l88T6.05fi.10 John D. Haught & Associate* ilsfw r Page 3 same timeframe over which wastes from Rocky Flats were reportedly disposed of •( Lowry Landfill. The waste P*'* located along Unnamed Creek thai contain these minmade radionuclides were used Tor disposal In 1970. This period is before the timeframes when Rocky Flats reported waste shipments to Lowry Landfill. However, we understand ih.M Rocky Flats records docu- menting waste shipments to unknown recipients in the 1969 to 19*0 timeframe. Therefore. occurrences of manmade radionuclides in these waste pits ii consistent with an origin. associated with Rocky Flat's wastes. The occurrence of manmade radionuclides in shallow groundwater at the toe of the landfill cannot be attributed to any particular timeframe. This area colleiti leachate and shallow groundwater from * Urge portion of the waste pit/refuse area. piMfibulion of M^ptnadf RadionucHdes Relative 10 Prr-J967 Activities 31 the Site As previously indicated, manmade radionucljdes, principally "'Am. were detected in all eight of the up$radlent shallow groundwater monitoring wells or Lowry Landfill. Indications of a pre- 1967 waste disposal along the south boundary of the site are a likel\ source for the occurrences of manmade radionuclides in the upgradient shallow groundwater monitoring wells at Lowry Landfill. Specifically, the following observations have been noted en the basis of a review of aerial photographs of the site and historical information: I. Both the 1930 and 1936 aerial photographs of the area clearly show a surface distur- bance of the south boundary of the site. 10 the west of the former location of Unnamed Creek and immediately to the east of upgradient well UJIO. which contains 14lAm at

2. The 1965 aerial photograph (Figure I) clearly Indicates the presence of a constructed facility consisting of an access road, perimeter road, enclosing fence, gate, »nd con- structed pond containing liquid. This facility was located it the south margin of the siti: at the head of a small tributary to Murphy Creek In the area of .the current upgiadient monitoring well MW22. Well M\V22 contains high levels of *Am and other manmade radionuclides in the eight upgradient shallow monitoring *e!li located to the south and southwest of the site along Quincy and Gun Club Roads.

IMPACT Of MANMADE ftADIONUCLlDES ON POTENTIAL REMEDIES AT LOWRV I ANTlFILt. The occurrence at Lowry Landfill of nuclear weapons-related radlcnuclidcs at concentrations substantially above background levels is anticipated to impact the selection, scope, and cost of potential remedies for waste pits and groundwater at Lowry in the following three ways:

m* P 94 539

* 3 c o

Hirdinfi littton AittdtU t

Deifmt-tr 15. 1991 ISS-6.0J3.IO John D. Faught & Associates Page 6

1. Achievement of applicable or relevant and appropriate requirements (ARARj) 2. Management of residuals 3. Volume and extent of groundwater potentially requiring remediation

of At this time, three potential chemical-specific ARARj have b«en identified relative to manmade radionuclides. These include (I) NRC Standards for Protection Against Radiation (10 CFR fart 20 el at.). (2) Colorado Primary Drinking Water Standards 5CCR1003-I. and (3) Colorado Basic Standards for Groundwater (S CCR 1002-8). The, NRC Standards would restrict effluent limitations for discharge! to water Tor *4lAm and ««J40pg w 20 j>Ci/> each and for *"Pu to 1000 pCi.'l. The concentrations of *°Ara inGWlin GWI U (94 pCi/l) and »»/.«oru }n u$04 (21 pC!/l) exceed these standards. Colorado Primary Drinking Water Reflations have set a maximum contaminant level for beta particle and photon radioactivity from manmade radionoclides in community water systems at lev* Is such that an «nnual dose equivalent to the total body or «ny internal organ shall not exceed 4 millirems tier year (mrem/year). EPA has indicated (I9S6) that concentrations of 3UAm of 4 pCi/l or 1M Pu of JO pCi/l yield a risk equal to (hat from a dote rate of 4 mrem/year. The concentrations of *41Am in upgradiem shallow groundu-ater monitoring wells MWOOJ and MW22 exceed this level The concentrations of -4I Am in GW| U (94 pCi/li and MWI I (5.1 pCi/l) also exceed lhi» level. M Finally, Colorado has established a standard for »/'«°ptt in ground*ater of 15 pCi/l. The concentrations of :"''"Pu in w«Hs U504 and M\VI 1 exceed this l»v«l. AS a result of these evaluations, remediation to reduce the levels of radionuclides in shallow groundvoter may be required. In addition, any discharge of treated water from the site may require additional treatment to meet these ARARs. i

Any treatment alternatives at the site will result in the generation of hazardous residuals, some of which may contain concentrated levels of manmade radionuclidei. Currently, no permitted commercial or DOE facility exists that cm accept mixed wastes containing both hazardous constituents and tadionuclides. regardless of their origin. Two DOE facilities currently provide 01 the capacity for the 'temporary* storage of mixed wastes: the Low Level Waste Management Facility at the Nevada Test Site and the Idaho National Engineering Laboratory. The only other potential repository for transuranics from nuclear weapons productions is the Waste Isolation Pilot Plant (\VIPP) near Carlsbad. New Mexico. While W|PP is intended to store ind manage defense wastes from the DOE complex, and while It may eventually receive mixed wastes, the dare for the opening of the facility has been postponed indefinitely for a variety of technical, legal, and administrative reasons. P 85 540

H*rtfln( Ltwton AiMCUtt* ffecembrr IX 1991 1XS76.fl2K.IO John D. Fought A Aiioclatos Page 7

Finally, because the expected concentrations of iransuranic element* and other radionuclides in the reiiduals generated during remediation at Lowry cannot be qualitatively estimated until the ongoing treatabitkty tiudie* are comptctrd. it is unknown whether thete wisie» could be accepted at a commercial low-level ndioactive »-a»e disposal facility.

CONCLUSIONS

On the basis of the data obtained to date as pan of the remedial investigation/feasibility study (RI/FS) for the shallow and deep groundwater OUs at Lowry, the following conclusions with respect to manmade transuranic radionuclides can be made: l. Manmade radionuclidei nisccuted with nuclear weapons production are present in the shallow groundwairr at Lowry Landfill at concentrations 10 to 10,000 limes background

2. On the basis of the nature and occurrence of these radionu:lides, their origin at Lowry Landfill strongly appear to be the result of pre-1967 waste disposal activities at Lowry and disposal of Rocky Flats wastes during 197$ 10 1980 and possibly earlier. :-. The occurrence of these radionuclides could have a significant impact on the ability of potential remedial alternatives to achieve ARARs snd the com associated with residuals managements and groundwater collection and treatment.

We appreciate the opportunity to assist you with this effort. Please contact either of us to dlscuM the data used to develop this evaluation or the resultant conclusions. • Sincerely. HARDING LAWSON ASSOCIATES

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Monitoring Monitoring Wells Wells Waste-Pit Within Outside Upgradis.it Dees well Source Source Monitori.-.j Monitoring Rocky Points A re.i Ar»a Fists' Plutonium - 239/240 0.58 - 9.2 0.4: - 21.0 0.17-45.0 0.59 0.09-0.60 0.011 -0.004 Plutonium - 241 ND 9.7 - 150 14.0 - IS.O 21.0 - 78.0 1.5 - 24.0 NR Americium - 24 I 1.4-4.0 94.0 0.22 - 10.0 1.3 - 13.0 0.11 - 0.66 -0.003 - 0.009

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Concentrations nre in picocuricj per liter. ND • not detected NR - not reported

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IS02 Amrrielvjn-241 01/15/91 0.2000 U 0 2594: 0.0000 I50Z •A<«rleiuii-24t 03/12/91 0.3030 u 0 31S59 0.0000 1502 Pluceniun-241 01/15/91 0.2000 u 0 25>t' 0.0000 1502 03/12/91 20.0000 u 0 3 :5'.S 0.3CCO 1502 Ptutonlun- 239/243 07/12/89 0.6600 0 724'J C.44CO 1502 H u: onion- 239/2 « 3 01/15/91 0.3COO u 0 25Wt 0.0000 I5C2 Plutoniun-239/243 03/12/91 0.3COO u 0 31557 O.OOCO

12/10/90 0.2000 u » 22S?2 o.ocoo I5C4 Aincrlciin-241 (ilphi) 12/10/90 0.3000 u r 22E73 0.0000 1504 A/nor icibn- 241 (ilprii) 01/07/91 0.3000 u 0 24423 0.0000 1504 Americlvn-241 <»lp*» 01/07/91 0.3000 u R 248iA 0.0000 1504 P(u:on(iii.241 12/10/90 25.0000 u t 22*73 0.0000 15S4 Plutoniun-241 12/10/T? 27.0000 u R 22U2 0.0000 IS04 Ptutan

1513 A«ericlu»-241 (tlpfx) 08/23/90 9.0000 U J 0 131:4 0.0000 1518 Ptvtoniua-241 08/23/90 38.0000 u 0 13i:6 0.0000 1518 Plutoniui- 239/240 08/28/90 0.2000 U J 0 131* 0.0000

1519 A.nerlclui-241 (itptii) 08/28/90 4.0000 u 0 131M ' 0.0000 1519 Amerlclin-241 (ilph.) 08/28/90 1.8030 R 13*7 0.4000 1519 Ptutoniu*-241 08/23/90 24.0000 u 0 1313C 0.0000 1519 Ptutoniuv-241 08/28/90 24.0000 u X 13W7 0.0000 1519 P tut on tun- 239/240 08/28/90 0.2000 u t 13W7 0.0000 1519 Ptutonivn- 239/240 08/28/90 0.1 COO u 0 13 1M 0.0000

1523 Anerlclu«-241 (alpfx) 09/11/90 0.20T.O u 0 14623 0.3000 1520 Ptutonlun-241 . 03/31/89 7B.OC30 0 KLA-31Q6J 40.00 1520 Ptutonlui-241 09/11/90 25. MOO u 0 14623 0.0000 1520 Ptutonlun-239/240 03/31/89 0.5903 0 MI.A-31063 0.32 01 1520 Ptutonlu*- 239/240 09/25/89 0.3000 u 0 779^6 1520 Plutonlvn- 239/240 09/11/90 0.2000 u 0 1462C 0.0000

1521 PtutonluB-241 03/28/89 300.0000 U KU-:i256

Concrtt.'itlons In pic»Curiti per liter 1 • indicitti detection or neixittection (U) of r*4ionucl(de 4 • d«t» qu*(i fiert 6 • origin*! (0). repllc«t< (I), or t;a«n«nt (')

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location ltdionuclide v«luc 1 4 6 tr»(fie CUtc v-j trror

1521 Ptutoniun-239/240 03/28/89 0.9C30 U 1521 Plutoniun-239/240 09/19/89 o.aoco u 75^44

1704 Plutonioi-241 04/07/89 97.00CO 0 XLA-0172S 70.00 1701 Plutonian-239/240 04/07/89 1.3000 0 KLA-0172S 0.70 1704 Plutonium-239/240 07/19/89 0.6000 U 0 72971 1704 Plutoniun-239/240 09/Z7/89 0.4300 U X 77197 Olutonlus-239/240 09/27/89 0.3000 U 0 77194

8705 Plutonium- 239/240 07/12/89 0.0800 U 72416

1706 Plutoniun-239/240 07/:e/37 C7»000 U T2SM

1707 Plutoniun-239/240 07/17/89 0.9100 0 72889 0.5200

8708 Plutoniun-239/240 07/11/89 0.10CO U 0 72368 1708 Plutoniun-239/243 09/22/89 0.2000 U 7S674 1708 Plutoniun-239/240 07/22/89 0.1000 U 0* 7867J

Plutonian-239/240 07/12/89 0.8200 0 7Z417 0.3800

1710 Plutonlon-241 04/06/89 76.0000 0 KU-OI804 43.00 1710 Plutoniun-239/240 04/06/89 0.5800 0 MLA-01804 0.51 1710 Plutoniun-239/240 07/21/89 (.0000 0 731S2 0.4000 1710 Plutonlon-239/240 07/21/89 0.9400 R nisi 0.6400 1710 Plutoniun-239/240 09/27/89 0.1000 U 0 77194 i 33 1711 P tutonla.-239/240 07/11/89 0.4000 u 0 72367 ro 1712 Aawrleiuif241 Catpna) 01/10/91 0.4000 u 0 25952 0.0000 1712 Aaerlciun-241 (alpha) 02/28/91 20.0000 u 0 30C41 0.0000 fji 1712 Plutonlua-241 01/10/71 30.0000 u 0 2S9S2 0.0000 1712 •lutonlin-2U 02/28/71 40.0000 u 0 30041 0.0000 1712 Plutonium-239/2«0 09/13/88 3.0000 u 0 MWCOO 1712 Plutonlui-239/240 07/06/89 0.3000 u 0 7166S 1712 Plutonlua-239/240 09/21/89 1.0000 u 0 7S622 1712 Plut9nlun-239/2«0 01/10/71 0.4000 u 0 25952 0.0000

Conetntrttlont In plcocurttt per liter 1 • Iniicitri detection or r>onc!t:ectlon (U) of r>dlonuclld« 4 • d<:> guallfleri 6 • original (0). replicate (I), or ttaonwi: (F) sample

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S«"Dle V«lu« 1 4 6 tn"ic Count i.- Date IKTW-- C.-ror

1712 Hutonlun-239/240 02/28/91 0.0600 U 0 30041 0.0000

PlutanItn-241 03/23/89 24.0000 0 Hu-aiois 12.00 Plutoniun-239/240 09/27/88 0.3COO U 0 Mxiotar Plutonlua-239/240 03/23/89 0.2250 0 ML4-OIOI5 0.10

Plutonius-239/240 09/29/M 1.40QO t XW3C9 Plgtonlun-239/240 09/28/98 0.6300 0 HHiOJ7f C70201 Plutonian-239/240 09/13/89 O.OS30 U 0 7S.-.Z7

CV10'. Ancriclui-2« (alpha) 04/24/91 o.oaoo u 0 36SU 0.0000 CV101 04/24/91 10.0000 U 0 365'i 0.0000 CW101 Ptutonlin- 239/240 0*/24/«l 0.1700 0 365:4 0.1500

CV102 Americlui-241 (alpha) 01/04/91 0.2000 U 0 24Si7 0.0000 CU102 Plutoniin-241 01/04/91 30.0000 U 0 24417 0.0000 CW102 Plutonium 239/240 01/04/91 0.1000 U 0 2«J7 0.0000

CV103 Anerlclut-241 (alpha) 01/08/91 0.6600 0 „„. 0.3900 CV103 fcnerlclvm-241 (alpha) OS/10/91 0.4200 U 0 1145 4 0.0000 W103 Plutonlwi-241 01/08/91 100.0000 U 0 25574 0.0000 CV103 Plutonluc241 OS/10/91 8.0000 U 0 34454 0.0000 CV10J Plutonlun-239/240 01/04/91 0.2000 U 0 25574 o.oaoo CU103 Ptutonlu>-239/240 OS/10/91 0.0900 0 M454 o.isoo

CW104 A«rrlelui-24t (alpha) 01/15/91 1.0000 U 0 25963 0.0000 CU104 Awrlclm-241 (alpha) 02/26/91 0.2600 0 29745 0.2400 CU104 Plutonluo-241 01/15/91 50.0000 U 0 25963 0.0000 3= CV104 Plutonlvn-241 02/26/91 40.0000 U 0 29745 0.0000 CV104 Plutonlm-239/240 01/15/91 0.2000 U 0 23963 0.0000 Plutenlun-239/240 02/26/91 0.2000 U 0 «7iS 0.0000 33 ro CU106 tocrlelui-241 (alpha) 01/09/91 O.SOOO U 1 25572 0.0000 CW136 Amerlelua-241 (alpha) 01/09/91 O.SOOO U 0 25590 0.0000 Cli CU106 Anerle

Coneentritions In plcocurtes per liter 1 • Irdictttt d«trctlon or naodcttctlon (U) of r*dionuclid« <• • d«t» qu«li(lcrt 6 • original (0), rc9llci:e (I), or ttioncnt (F) stnpl* 551 2. c ° c t If f-£ -0060 - /f-SS0? -S'fSF Historical SoiFwry el lovry landHll Man-nude ladionue: ides = ^ - -— 0 ^ ,. _,4 . . .,. _ ..(Amv'iclvff-241- Plutonlk*-24.1_ Flutonlui- 239/240} . 9 t*^ r* ™ »* 12/04/9H °"?L^.f §• • to ^ V»lu* 1 4 local ion IXionuctldt Sanple 6 trt«»-e CM:

CV107A Amerleiura-2'1 (alpha) 02/20/91 0.4COO U 0 27247 0.0000 &•. CVI07A Plutonltn-241 01/08/91 140.0000 U 0 25159 o.ooco ss; CU107A Plutoniun-241 02/20/91 300.0000 U 0 29247 0.0000 ^r- CU107A •lutoniui- 239/240 01/08/91 O.SOOO U 0 2515J 0.0000 c>^> CU107A Plutonlvw 239/240 02/20/91 0.9000 U 0 29267 0.0000 gg

CU108A Ao«rfciuif241 (alpha) 03/05/91 0.1COO U 0 3S4I3 0.0000 III mc&A Plutoruim-241 03/05/91 SO. 3000 U 0 3C433 0.0000 svioaA P lut onlu»- 139/240 03/OS/91 0.1000 U 0 30433 0.0000 1 '1 •

CU109 Ajnerlctun-241 (alpha) 01/08/91 0.7000 U 0 25157 0.0000 1§; .. CU109 Americ lua- 241 (alpha) 02/20/91 0.3000 U 0 29244 0.0000 CU109 Plut:polum-24t 01/08/91 24.0000 U 0 2J1J7 0.0000 CV109 Plutonium- 2' 1 02/20/91 SO. 0000 U 0 29248 0 . 0000 * CU109 •lutonluii-239/240 01/08/91 0.4000 U 0 25IJ7 0.0000 CV109 P lut on lu»- 239/240 02/20/91 0.2000 U 0 29218 0.0000 • . Aowrlclui-241 (alpha) 01/03/91 W^A 1.0000 U 0 24777 0.0000 0/110 A Anrlc(um-2(l (alpha) 03/04/91 O.S300 U 0 33474 .0000 .' l GUI IDA Ptutoniui-241 • 01/03/91 54.0000 u 0 24777 .0000 V •*' - - CU110A •lutonlut-241 03/04/91 20.0000 U 0 334M .0000 B ^ •'• ' WHOA Plutonlvn- 239/2(0 01/03/91 0.2000 U 0 24777 .0000 aflCS ^ CU110A Plutonlui- 239/2(0 03/04/91 0.3000 U 0 30494 .0000 SQ •/'.-

: cum A*erlclui-2(1 (alpha) 01/08/91 4.0000 U 0 25 :« 0.0000 •f] : •.'• cum Aoerlclui-241 (alpha) 02/22/91 8.0000 U 0 29744 0.0000 • p»^»v - . . cum Plutonluc24t 01/08/91 40.0000 U 0 251J4 0.0000 ' ftw^ ' " ' • cum • Iutonluf241 02/22/91 30.0000 U 0 29744 0.0000 i • %•» f- ••' :' cum Plutonlu«-239/240 01/08/91 0.2000 U 0 25154 0.0000 ' \ cum Plutonlun-239/240 02/22/91 0.0700 U 0 29744 0.0000 . : w t •••I '• cum Aoitrlctun-241 (alpha) 01/09/91 94.0000 0 »5H 80.0000 aguriHjft CU112 Amrlclun-241 (alpha) 02/27/91 30.0000 U 0 29993 0.0000 ^flHEjHHi CU112 Pint onlui- 2(1 01/09/91 70.0000 U 0 2SSM 0.0000 rSSSS Concentrations In picocurles per liter (FS5V 1 • indicates detection or mode:eitlon (U) of radionuclldc 4 • data quali fieri ILsl & • orijirval (0). replicate (1),or stagnant

-•• / *7^* ^} f I' * 1 • • J 552 i». c o " O -• ft, •-> _ _4 — TT* n — f . *• .k f ^^ j* ~ ~* p. ^ ua s: S t* o -&-00&O -/tfttfj ;-.v; . «• m _• ^a^^* • to«rv landfill Han-x«tfe ladlonjclldes Nlttorical SiflMfy of . -, ,...... t Pa«« Mo. .„. -..- ...,. (Anerfclum-2*!. Plutonium- 241. Plgtonlum-2J9/240> " - '• t 12/06/91 "fl^-^• g-g:^- 0- « m ~* o =2 =: r> •-" 5^ C *O* ^^ =3 1 ad 1 O^OX tide Sanplt value 1 4 6 Tr»fli; eauntii^ IOi fC^ •A v ( *i »*o^n 3 r» =r — Oate »-j>oc.- frr»r » rr JT~ 3 sow * •f CO SO.OOCO u" 0 2-WJ 0.0000 o ewti2 Plut3nium-241 02/27/91 01/09/91 3.10CQ 0 2S5?' 1.8000 CW112 Plutonium- 239/243 02/27/91 0.1000 U 0 29993 0.0000 CU112 Plutonium-239/240 • • • .

01/04/91 0.3100 0 24SU 0.2300 CWl 13 Awericiun-241 (alpha) ""^^.i 03/06/91 0.5700 0 30736 0.2600 •^ J • CW113 Aflwrlelura-241 (alpha) 01/04/91 110.0000 u 0 2<-Si£ 0.0000 a^~ CU113 Plutonlum-241 03/06/91 40.0390 U 0 30736 0.0000 •*^ ! CWl 13 Plutonium-241 01/04/91 0.43CQ U 0 24&U 0.0000 <^r> CWl 13 Plut onion- 239/240 03/06/91" 0.1000 U 0' 30736 0.0000 CU113 Plutonium- 239/240 ^ O.JMO u 0 ZJJW 0.0000 GU1 14* Amerlcium-241 talpha) 01/09/91 111 . 0.2000 U 0 30477 0.0000 CV1HA Aeerlclue-241 t»ljha) 03/01/91 20.0040 U 0 2557t 0.0000 GUI HA Plutonium-241 01/09/91 40.0050 U 0 3U77 0.0000 CWl Hi Plutonium-241 03/01/91 01/09/91 0.3000 U 0 25593 0.0000 CU1HA Plutoniun-239/240 s 0.6000 U 0 30497 0.0000 CVMHA Plutonian- 239/240 03/01/91 •^

0.5000 U 0 25754 0.0000 \ XVCOI Amrictun-241

08/30/90 4.6930 0 13414 1.2000 si MU903 Amrlelua-241 (alpha) mm* '• 38.0000 U 0 13414 0.0000 KU003 Plutonium- 241 08/30/90 0.3000 U 0 1J4-.4 0.0000 3^•^^0F ..-. KU003 Plutonium- 239/240 08/30/90 M•wP 1.3000 0 13233 0.3000 NU004 Amrlclum-241 (alpha) 08/29/90 29.0000 U 0 13233 0.0000 NU004 Plutonium- 241 08/29/90 08/29/90 0.1000 U 0 13233 0.0000 HU004 Plutonium- 239/240 2 oa/jo/m 1.9000 0 13418 0.4000 NUQ05 A«er(c(um-2

-•• ^//. 1 J 553 1 2. = o w c S3 *• •? 2L — r — ff 1-(s~ 00&0 'A00* ^ Mlitor*c*( Smr*«ry of lo«ry landfill Rjn-mtde • •dlo'vc'. idet a" ° rv ° * ,1 • 12/06/91 Hi-ii location iatfionucl 'it S

\ m02 Aovricium.241 (alpha) 01/23/91 0.2000 U 0 269S6 0.0000 MW02 Anrlelun-241 (alpha) 03/14/91 0.2200 0 3156C 0.1700 >

U5C3 PIU.^,^24, 04/03/89 150.0000 0 MI.A-01517 120.00

Concentratlona In plcocurlet per liter \ • Indicates detection or nondttectlon (U) of radlonucllde ' * • data qualifiers 6 • original (0). replicate (*). or stagnant ( F) sample

-'• (0

* J 554 T J3 3 f» C O W-£ -0066 -ftoooi • 1§ KitSS' >C»l Sundry el lavry H-dtHl «»n-««

U504 Plutoniu»-24J 04/05/89 2CO.OOOO U 0 NU-Ct&es •-'. U504 Plutcnlu*-241 04/OS/B9 60.00CO U * NlA-01621 •"•• USO* Ptutsnlai- 239/240 09/02/88 21.0000 0 MHX2U -'.' US 04 Plutsnlun- 239/240 04/05/S9 0.2500 U 0 NLA-01643 -^_— _. U504 Plutoniun-239/?4- 04/05/89 1.0450 « MUL-0162! 0.33 S

" Awerieitn-241 (ilprii) 08/33/90 2.3000 0 13422 0.5000 USC9 cyS> V5C9 P I U'. 00109-241 08/30/90 26.0000 U 0 13422 0.0000 USW Plutonian- 239/240 06V30/90 0.2000 U 0 \3tZ2 o.ooco • • usto A/nerician-241 (•Iphi) 09/05/70 1.7SCO 0 13745 0.7000 ^m USIO Plut9niu«-241 03/15/89 20.0000 U 0 MU-03944 usto Ptutonlirt-241 09/05/90 20.0000 U 0 13765 0.0000 r-»-i usto Plutonian- 239/243 03/15/89 0.5300 U 0 HLA-C0944 ^-.^ usia Plutonian- 239/240 07/05/89 0.3000 U 0 714L6 ;_jj p

UTOt Plutonian- 239/240 09/13/89 0.1000 U 0 78123 ifs&O- :??*> U702 Ptutonfun-241 04/11/89 100.0000 U 0 IOA-01752 : 1 08/25/SS 50.0000 U X KWG49 1 .»^v' • .s . •- . U702 Plutonian- 239/240 % • .'.•-. U702 Plutonium- 239/240 08/25/88 50.0000 U 0 MWQU S ~' U702 Plutonlui- 239/240 04/11/89 0.99SO 0 Km-01752 0.46 •H ; U702 Plutonian- 239/240 07/24/89 0.5000 U 0 73182 ;'"' r '. 9^•^^•9r U702 Plutontai-239/240 07/24/89 0.4000 u * 73 1U 0702 Plutonivn-Z39/240 09/2S/89 2.8000 0 793 U 1.3000 ro i\v^;- i * *. .'•' U703 Ptutonlvn-241 04/12/89 60.0000 U 0 IOA-017T7 Ol 04/12/89 0.9600 0 KLA-01777 0.50 U703 Plutonlui- 239/240 !•":• ." U703 Plutonium- 239/240 09/29/89 0.0600 U 0 794 Jt " \ L^Z.- m--A-,.• .^hM»^^ Concentrations In pleoeurlet per llttr BBX rSH 1 • ln«Jleite« dttcctlon or nend«t*ctlon (U) of r*dlonuelfo> AH•B 4 • d>tt qutliriert KSI 6 « orlglrxl (0). repllctte (1).or tt»gn*nt (f) tuple

|j3

J£.

K » • .. • 1 .' J1i 555

iff (^ {SISIpf T • w \r\f t •5 5?S S < xlitorlcil Suim*ry of lovrr ItndMlt H«n-m»d« txfl wuel Idtt -,,«< • o» r Mo. 8 utonlum-2*', Plutonlum-239/2*0) s-?="5s «• Q. _. c s • •iionxlide S^,l« Vttuc 1 4 6 Tri'fic Counting ° s = 0*tf •uicer Crror S o" _. = 3 •» =: = 3 a ** E U704 •lutonlu»- 2*1 04/07/89 50.0000 0 m.A-01700 27.0 c Plutonium- 239/2(0 08/25/88 20.0000 U 0 MMM273 U704 Plutoniu»-239/2(0 04/07/89 1.2000 0 m.A-Ot674 O.S .- U704 Plutonlu*-239/2(0 04/07/39 0.2000 U 1 KIA-OI700 t ' • . •• U7C4 Plutonlun-239/2(0 07/20/89 0.6600 0 7305J 0.3000 • • U70* Plutonium- 239/2(0 09/27/89 0.0500 U 0 79175 ~~^I''-. '•

= ; ' . U7Q6 Plu,onlu,-2(l 04/04/89 61.0000 0 Nl.A-015** 50.00 U706 Plutonium- 239/2*0 04/04/89 1.0000 0 KLA-01545 O.S ^25 ' :-. Plutonium- 239/2*0 07/19/89 U706 0.4000 u 0 73058 ——5" ' U706 P tut on I on- 239/240 09/18/89 0.0400 u 0 7SU3 1=5 V"

0707 Plutonlui»-2d 03/13/89 80.0000 u 0 m.A-00840 • •I 0707 Plutonlua- 239/2(0 03/13/I* 0.4250 0 HLA-00840 0.23 uu " 0707 Plutonium- 239/240 07/10/89 0.6000 u t 72366 • i • 0707 Plutonium- 239/2(0 07/10/89 0.5900 0 72365 O.S100 ^ "^. Plutonium- 239/2(0 09/25/89 0.2000 u 0 79047 -. S; • • ••-.' 0710 Plutonlum-2(1 04/04/89 200.0000 u 0 XLA-01594 0710 Plutonium- 239/2*0 04/04/89 0.9200 0 MLA-OI594 0.70 0710 Plutonium- 239/2(0 07/13/89 0.1000 u 0 72575 Plutonium- 239/240 0710 09/20/89 . 1.0000 u 0 78623 ;

' — ._il.-- T •T.X. 0711 Plutontum-241 03/31/89 200 .0000 u 0 HU-01442 - '•:*' :5.'^; 0711 Plutonium- 239/2*0 03/31/89 1.4500 0 NU-014«2 0.60 tm^l^B '•**'• 0711 Plutonium- 239/2(0 07/14/89 0.1000 u 0 T2J96 V^^^'-^'''

\

UP002 An«r1elvjf2(1 (ilpht) 01/14/91 5.0003 U 25957 0.0000

Co«centrit(on» In plceeurlct ptr liter 1 • tndicitei dettetlon or nondttcctlon (U) of rtdlonuellde 4 • dttt quttlfUrt 6 « ortjlntl (0). rtpllcatt (t), or ttifunt (F) twrplt 556

Hltlorlol Sumwry of loo'y •iff "0. 9 1;**>crlclu.-2<.1, Hu tonlw~2(l. Plutooiu /2t:: •12/00/911 - . -.-. .- -.-. .-•••• —• •— • •

i ladionucllde Valu« 1 4 6 T Cawrt in) Bate ;:~: trror

01/U/91 37.0000 U 0 25*5' 0.0000 IS! • lutonlira- 239/2(0 C1/U/91 0.7700 0 2595' 0.6800

UPOOJ 01/22/91 1.OOO 0 247— 0.6000 VPOCJ •lutonlun- 239/2(0 01/22/91 1.0000 U 0 24 r- 0.0000

UPC07 Ajnrrlcf *A*2d (alpha) 01/22/91 1.70CO 0 267.: 0.7000 UP 007 •lutoniu«*2(1 01/22/91 83.0000 U 0 247.5 0.0000 UP007 Plutonium 239/2(0 01/22/91 1.0000 U 0 247.! 0.0000

VP101A 01/2S/91 1.8000 0 273S 0.9000 VP10U 01/2J/91 26.0000 U 0 273C 0.0000 UPIOU rlutonlui- 239/2(0 01/2S/91 0.6000 U 0 271= 0.0000

UP 102 01/2(/91 8.0000 U 0 0.0000 VP102 •lutoniui- 239/2(0 01/2(/91 S.OOOO U 0 2672 0.0000

vproi A«crlcfin-2(1 (alpha) 01/18/91 S.OCOO U 0.0000 > VP7C1 Aoierlc fuv*2(1 (alpha) 01/18/91 4.0COO 0 2.3000 VP701 •luton(ui-239/2(0 01/18/91 26.0000 I 24515 11.0000 UP 701 Mutonluf 239/2(9 01/18/91 2.0000 U 0 265Sd 0.0000

UP 702 01/09/91 ' 3.0000 U 0 256tC 0.0000 UP 732 Plutonlu»-239/2(0 01/09/91 10.0000 U 0 0.0000

IS 703 Axcriclui-211 (alpha) 01/10/91 4.0000 U 0 0.0000 VP703 Plutonlvn-2(1 01/10/91 110.0000 U 0 o.oooo • . UP703 Plutoniu*' 239/2(0 01/10/91 2.0000 U 0 KX* 0.0000 33 Ancrl clue 2(1 (alpha) 01/04/91 3.0000 U 0 0.0000 WP 707 • lutonluc 239/2(0 01/04/91 10.0000 U 0 25-.JS 0.0000 *ro UP 708 A«erlc(u*-2(1 (alpha) 01/17/91 4.0000 U 0 2423C 0.0000 oil UP 704 Mutoniu»-2(1 01/17/91 260.0000 U 0 265: 0.0000 VP708 •Iuton(uc239/2(0 01/17/91 9.2000 0 4.7000

Concentration* In ptcocurie* per tlttr 1 • Indicatti d*ttctlon or nondctcctton (U) of radicruellde 4 • data qualifier! 6 • ordinal (0). repllcatr <«). or tta«rtant (') swplr

J 557

—E 4 f f -^ - Nlttoriol JowMry of lovry landfill w.n-nwd* tadlorvxl loJet 10 (Aiiirricla»-241. Plvtoniyn-Zd. Plutonian- 239/240) __ __^_ I2^o/«i location Sw-ott Vtlue 1 4 6 8 Dflf Error -3« '•ET=r rr a3 s » ™ at

UP 709 Anrrlciin-2t1 d(pf<*) 01/14/91 1 .eooo u 0 2595? 0.0000 u» 709 l!lgtoniu*-2«1 01/14/91 26.0000 U 0 25955 0.0000 UP 709 Ptutonluo-239/20 01/14/91 0.5900 0 25959 0.5600

UP710 Amerleltn-241 <«lp*n) 01/16/91 4.0000 U 0 2&2:5 0.0000 up7io Ctutor>iu»-2H 01/16/91 32.0000 U 0 26215 0.0000 UP710 Plutonivn-239/2«0 01/16/91 0.4000 U 0 26215 0.0000

VP71I A«rlelu»-2l1 (tlphi) 01/09/91 0.2000 U 0 256C2 0.0000 wprn »tutonlu«-2t1 01/09/91 30.0000 U 0 2S6C2 0.0000 UP7I1 Ptutoniuv 239/2^0 01/09/91 0.3COO u 0 256-12 0.0000

VP712 Ac«r(clui-2«1 01/38/41 2.4000 J« 0 25165 1.6S30 VP712 A«rieio»-241 (alpha) 01/08/91 6.0000 U J* X 2515S 0.0000 UP 712 •lutonitn-211 01/08/71 150.0000 U t 25151 0.0000 UP 712 01/08/91 87.0000 U 0 25163 0.0000 WP712 Plutaniuv 239/2O 01/08/91 0.6000 U K 25153 0.0000 VP712 Plutonium- 239/210 01/08/71 0.5000 U 0 25163 0.0000

UP 713 A/ncrlcluc2t1 (alpha) 01/07/91 0.7000 U 0 2488i 0.0000 M»713 Plutoniu>-2«1 01/97/91 100.0000 U 0 2484- 0.0000 Ptutonlu»>239/2O 01/07/91 0.6000 U 0 2484i 0.0000 —^^ VP714 Amrlelun-211 (atpha) 01/21/71 0.3000 U 0 26538 0.0000 VP7H PlutonIun-241 01/21/71 40.0000 U 0 26538 0.0000 UPTH Plutonian-239/210 01/21/71 0.3000 U 0 26538 0.0000

VP71S Aff«r(clu<>-2«1 (alpha) 01/11/91 7.0000 U 0 25953 0.0000 UP715 Hutonfu»-2U 01/11/91 39.0000 U 0 25953 0.0000 UP7J5 Plutonian-239/ZiO 01/11/91 0.5800 0 25953 0.5700

VP716 ju«rlcia»-2H (alpha) 01/10/71 7.0000 U 0 256=8 0.0000 WP716 Plutonloi-2t1 01/10/71 71.0000 U 0 2S6C8 0.0000 UP716 Plutonium-239/2(0 01/10/71 1.3000 0 2S6C8 1.4000

WP717 Plutenlua-239/2(0 01/15/71 1.0000 U 23942 0.0000

Concentrations In pleoeurlet fxr liter 1 • Irdlcatti detection or nontfetectton (U) of radlonuclldc 4 • data quallfieri 6 • original (0). replicate (I), or ttagnant (f) tairplc 558 i I

Historical Sumwry of la«ry landfill Man-wade ladlwc1. ld«i «a-. U- 1, Plutonlvfi-2t1. Ptutanlu»239/2»:i .. -.., 32.' 12/04/91 loctlion l»dienuclide Vtlue Tn":: Dice k.rc«.- Error

01/23/91 4.2000 0 26VT! 2.7000 01/23/91 3.0000 U 0 0.0000

01/17/91 0.7000 U 0.0000 01/17/91 1.0000 U 0.0000

K) Olte

Concentrttlont In plcocuritx per liter 1 • lndic*t«t detection or nortfetectlon (U) of ridionucllde t • d«ta qutlltlert 6 • orl»ln*l (0), replicate (I), or stagnant (f) tanple

j 439*6-0900 ARALTST BATE LOVRY LANDFILL FILE RBVIEU FORM TZ4-CQ8013-DT-03758 QA 11/12/90 DATE PACE 1 OF

PREFIX NATURE OF BUSINESS Rockv Flats GENERATOR Rockwell International 091 TRANSPORTER BTP. Capital Citv PREFIX 733 PRP STATUS: 5/18/88 t UNDETERMINED BASIS FOR 104(e) REQUEST _ •_ VASTE STREAM(S) Waste Oil & Solvent RAZ. Hag.-2.2fli.fkl SOURCE . 435-3-0162-A0001. 06 Y_ VOL. 17.SOO gals 0165-ADqOL 06 _ VOL. Crease Solvents-Has.-2.2(aWk> 435-3-0011 _ 06 H Waste A35-3.Q012 Evaporaor 435-3-0013 Paint Sludce 435-3-0169

EXTRAPOLATION PERFORMED VTP ^nvotcea froa 197^ aqd 1978 ftotal 17f500) eatabllah an annual generation ^a^e of 8.750 gals. V/l Extrapolation done for 1976-77 and 79-flO yo cover genera^gr'a period of operation. Ul 3.8fl vearB x 8.750 "33.950 -»- 17.500 - 51.450 gala.

DbPLICATIVE RECORDS INVALIDATED CIWS \ 435-5-0001-AOQ02 and AQOQ7 DISPOSAL DECISION Aaamae transporter decision. PRP STATOS AJTtt REVIEW ^ PRP NON-PUP INCONCLUSIVE Capitol City Disposal-4.180 g*ls TOTAL VOLUMETRIC ALLOCATION FOR GENERATOR 55.630 gals. TRANSPORTERIK VTP - 51.650 gala. T>

COMMENTS 'See 435-3-0169-A0003 »0

A wide.variety of wastes is listed In 435-3-0009-A0001, which will not be duplicated hera. The CIWS (435-5* 0001-A0001 thru A0012) also Lists a nunbet of waste streams which fit into those listed in 435-3-0009-A0001. Revised A/25/91. 645-6-0900 DDB_ AHALTST 9/14/90 DATE LOWRT LANDFILL FILE REVIKtf FORM T24-C08013-DT-03758 ES Q* 10/18/90 DATS PAGE 1 OF 2

GENERATOR Martin Marietta Aerospace PREFIX 645 MATURE OF BUSINESS Space Hardware TRANSPORTER WTP PREFIX 093 PRP STATUS: Y _J R URDETERMItlED BASIS FOR 104(«) SJ (M(el 1? •I WASTE StRBAH(; SOURCE 6AS-3-5617 VOL. jlBnk. 0. • 6*5-3-0015- : I 645-3-0018 Haz. ConstttueaCs Listed Referee Liquids 645.3.Q01S-A0001 2.2(al 645-3-0019 •'•• *•*•'. Rtnsewaters Hag. - g.2f«> 645-3-0020 Lqfy phemlcals Haz. - 2.2(11 645-3-0021 Clewing Solvents Haz. - 2.2flUaV 645-3-0022 Fiux/Soldar Waste Hat. -Lead. Zinc 2.2fal 645-3-0023 EXTRAPOLATION PERFORMED

.JWFUCATIVR RECORDS INVALIDATED

DISPOSAL DBCISIOB Aasuae tranaportoer declalon - PRP STATUS AFTER REVIEW / PRP DON-PRP _ INCONCLUSIVE TOTAL VOLDHETUC ALLOCATIOH FOR OE1ERATOR 16.795 gals. TRANSPORTER WTP - 16.795 gala. CQUMEHTS All of the waste streams in th> 104(e} contain hazardous substances, and all of trie waste descriptions on WTP Invoices can be lin|c«d to those waste streads (Protocols, 2.4{e)). Therefore all WTP shipments assuned to contain hazardous substances. Several shipnents disposed of on-site. Revised 4/25/91, 8/15/91. 12/10/91. ARALTST 11/4/90 DATE LOVRY LANDFILL FILE REVIEW FORM TZ4-C08013-DT-0375B ES QA 11/12/90 DATE PACE I OF

GENERATOR Rockwell International PREFIX NATURE OF BUSINESS Rockv Flats 093 TRANSPORTER PTP. Capitol City PREFIX 733 nt STATUS: 5/1B/S8 t UNDETERMINED BASIS FOR 104(e) REQUEST VASTE SIBEAM(S) Kaste Oil Solvent HA2. ag.-2.2fl).fk) SOURCE 43S-3-016:!-

Crease Solvents-Haz.-2.2(aVk> aate Evaporator- Salts Paint Sludve 06 _ VOL. EXTRAFOLATIOH PERFORMED VTP invoLcea from 1975 and 1971 ftotal 17.500) eatabllafi an annual feneratlon rate of 8.750 eals. Extrapolation done for 1976-77 and 79-80 fro cover generator*a period of operation. 3.88 vearh x 8.750 - 33.950 + 17.500 - 51.450 gala.

9BFLICATIVE RECORDS INVALIDATED £13JS_ A35-5-0001-AOQ02 and A0007 DISPOSAL DECISIOM Aaaune transporter Decision. FRF STATUS AFTER REVIEW J FRF NOH-FRF INCONCLUSIVE Capitol City Disposal-4,180 gala TOTAL VOLOMETRIC ALLOCAT10B FOR GENERATOR SS.630 gala. TRANSPORTER VTP - 51.650 gala. T) (9 COHMEHTS »S«e 435-3-0169-A0003

A wide .variety of wastes Is listed in 43S-3-0009-A0001, which will not be duplicated here. The CIVS (435-5- 0001-AOOOl thru A0012) also lists a nuaber of waste atraams which fit into those listed in 435-3-0009-A0001. Revised 4/25/91. 645-6-0900 POT AHALtCT 9/14/99 DATE LOBBY LANDFILL FILE REVlktf FORM TZ4-C08013-DT-03758 ES QA 10/18/90 DATE PAGE 1 OF 2 cpmrRATOR Martin Marietta Aerosnace . PREFIX $45 NATURE OF BUSINESS Space tfardware TBAHfiPORTER WTP PREFIX 093 PRP STATUS: T / N UNDETERMINED •AffTfi VOft 104 («) BMOEST PDK^ .•*Z3t 104(el VASTE SfRira<6>4l?f£azine ^^^SSsS.HAZ. Haz. - 2-2{a) SOURCE 64S.3.0017 06 N VOL./Dhk .f X Haz. - Z.Z(a) 645-3-0015- .' 645-3-0018 >••! Mttiiiwft'iTfiriftKSWaSHi&wiwo' Haz. constituents Listed O$ N VOL./ Vnk : Referee Moulds 645-3-0015-AOOOL 2.2fa) 645-3-0019 06 N VOL 4 Unk 1 •-..'•>:•. glnsjgjfaters Haz. - 2. 2fe'> 645-3-0020 06 N VOLJ Unk | \ l^b Chemicals Haz, - 2 2(J,1 645-3-0021 06 N VOLi Unk 1 filea.ninf Solvents Haz. • 2T2flKaV 645-3-0022 06 H VOL.it viUnmk FlUK/S°ltfftr Waste Haz. - lyeatj Zinc 2.2fa) 645-3-0023 06 N VOL A Unk I UTRAMLATIOH PKRFORMKD /« ^~' '"

PDPLICATIVK RKCORDS INVALIDATED

DISPOSAL DICISION AfiFMAfi tS8*111001^*' .decision - no infolflttion. PRP STATUS AFTER REVIEV / PRP NON-PRP INCONCLUSIVE TOTAL VOLUMETRIC ALLOCATION FOR CEMERATOR U.725 EfllS^ TRANSPORTER UTP - 16.795 pals. COMMENTS All of the waste streams in the 104(e) contain hazardous substances, and all of trie waste descriptions on UTP invoices can be linked to those vasta screens (Protocols, 2.4(e)). Therefore all UTP shipments assured to contain hazardous substances. Several shipments disposed of on-aite. Revised 4/25/91, 8/15/91. 12/10/91. PLEAS•L. .^^k^ ^M •B^B^^AK

June 19, 1997 Mr. Robert W. Hite, Manager Metro Wastewater Reclamation Dist. 6450 York Street Denver, CO. 80229-7499 RE: Affirmation of the proposed Lowry Landfill pretreated groundwater treatment agreement. Dear Mr. Hite: We the undersigned Directors of the Pleasant View Water and Sanitation District fully support EPA's proposal to have the Metro District treat the Lowry site groundwater. We agree it is the most economical and environmentally sound way to treat the groundwater under the rules and regulations of the EPA and the Colorado Department of Public Health and Environment. We also agree that it is a money saving option for all of Metro's ratepayers.

CC: Mr. Marc Herman Sincerely,. EPA Project Manager for the Lowry Super- Elmer Dudoen,' President fund Site Charlotte Wheeler,^Vice. Prei^ident •^sr'c fi i is~zt'~ •-- .^ .-^9i^t^..^^ Paul J. Wolf^ Sec. Treasurer

d, Direct- o &&&€'&<

555 Moss Street Golden. Cole. 8040' (303; 275-333: . 6-28-37 -16:08 ; ^.K^OS.C- ! 3033126837;* 3, 3

564

Sharon R. Ertell, CFP 183 Allen Avenue Portland ME 04103 207-797-0355

THIS IS A FAX COVER SHEET.

TO: Marc Herman, US EPA Region X

FAX #(303)312-6897

FROM: Sharon R. Estell, CFP

THERE ARE £ PAGEfS) INCLUDING THIS COVER PAGE.

DATE: */2*/97 TIME:

IF THERE ARE PROBLEMS OR QUESTIONS, PLEASE CALL ME AT (207)797-0355

MESSAGE: Mr. Herman: Telling the American people that spreading "Superftmd Sludge" on farmland is safe is the biggest lie that the Federal Government has told us since Watergate. It is dangerous enough that the EPA allows industrial waste to be spread on farmland, but to allow Superfund level toxins to be spread in this manner is unthinkable. The American people are being used as guinea pigs in a scientific experiment of massive scale.

I was the fifth generation to live on our family farm in Pennsylvania. I am intimately familiar with the farm lifestyle and mentality. T have met New England fanners who have been duped into believing that they are getting "something great for free" by accepting sewage sludge as fertilizer. The EPA and the Solid Waste Industry should be ashamed of taking advantage of these hard working people by telling half truths and withholding important information about the potential dangers to their land, their crops, and their families.

Since Professor Adriermc Anderson from the University of Colorado at Boulder has evidence to prove that the Lowry Landfill Superfund Site has contamination from plutoniutn, dioxrn, PCBs.and other man-made radionucUdes (such as: amend um, tritium, strontium, cerium, and cesium why is your project allowed to continue? T oppose the amendment to the Record of Decision at the Lowry Landfill Superfund Site. This is not a "clean up" of a Superfund site. It is the organized, government authorized contamination of our food chain. 565

Patricia Fanner 450 Broadway P.O. Box 1696 Grand Lake, Co. 80447 o=> (970) 627-0085 <= Lf- 71 '—~ - \~~ July 10, 1997 giVi JT

— on Mr. Marc Herman (8EPR-SR) Remedial Project Manager U.S. Environmental Protection Agency 999 18th St., Suite 500 Denver, Co. 80202

Dear Mr. Herman,

On June 26, 1997, CNN Moneyline aired a report on the Lowery Landfill Superfund site and the plan to pump ground water fron this site to the Metropolitan Wastewater Redaimation District for treatment. In this report you were quoted as saying: "This is not a precedent-setting proposal. It is being done at Superfund sites around the country." I am a Colorado citizen and former Denver resident, and have tried to keep informed of toxic cleanups in my state and others. Please send me a list of the other Superfund sites in the United States where the ground water is being treated at municipal sewage treatment plants. I would appreciate getting this information as soon as possible. Thank you for your help on this matter.

I Patricia Farmer 566

, cc

**•o§- tt kcau ~*i '"Tvi? -,r~^ . / ^^|«f r0^ >ru "4ft "ft^r^ /rt^/t. /

/ cJ N Y aJi MftY-19-97 MON 16:51 LESLIE HANKS 3642138 P. 01

567

B.R.EAC.H.

"Telephone (303) 364-213B F«x (303) 364-2138 P.O. Box 26 WBtkira. Colorado 80137

May 19, 1997

Mark Herman 8-EPR-SR Remediation Project Manager 99918*81 Suite 500 Denver, Colorado 80202

Dear Mr. Herman,

It has come to our attention that the Metro Waste Water Plan for Lowry Landfill Superfund Sludge to be applied on Deer Trail farmland is proceeding with little awareness of the public.

Because the citizens of the eastern plains are to be negatively impacted by this dangerous proposal, we request that the comment period be extended another 60 days beyond the current May 22, 1997 deadline.

BREACH is a grassroots citizens action committee working on the bombing range and other environmental issues affecting the eastern plains.

Thank you for your attention to this matter. We look forward to hearing from you at your earliest convenience.

Leslie Hanks, Lucinda Boyd BREACH 568

May 12, 1997

M. A. Hanks Box 346 Deer Trail, CO 80105

Environmental Protection Agency-Region 8 8-EPR-SR 999 18th Street, Suite 500 Denver, Colorado 80202-2466

Attn: Marc Herman

Re: Lowry Landfill Superfund Site Second Explanation of Significant Differences for the Record of Decision issued by the US Environmental Protection Agency and Colorado Department of Public Health and Environment; information from Reporter's Transcript of the Public Hearing April 2, 1997.

Dear Mr. Herman,

After reviewing the Reporter's Transcript of the Public Hearing April 2, 1997, as well as other information, I feel the proposed Lowry Landfill Superfund clean up plan does not offer adequate protection to public health and the environment (see enclosed copy of my letter to Phil Hegeman, Colorado Department of Public Health and Environment, dated May 12, 1997 regarding this matter). ._

Respectfully yours, Q t— i

M. A. Hanks 569

May 12,. 1997

M. A. Hanks Box 346 Deer Trail, CO 80105

Phil Hegemen CDPHEAVQCD-PE-B2 4300 Cherry Creek Drive South

Denver, Colorado 80222-1530

Re: Lowry Landfill Superfund Site Second Explanation of Significant Differences for the Record of Decision issued by the US Environmental Protection Agency (EPA) and Colorado Department of Public Health and Environment (CDPHE); information from Reporter's Transcript of the Public Hearing April 2, 1997.

Dear Mr. Hegemen,

In reviewing the April 2, 1997 Reporter's Transcript of the Public Hearing regarding the EPA and CDPHE's Superfund proposal plan for clean up of Lowry Landfill, I see where the public is invited to submit comments about the plan until May 22, 1997; therefore, I would like to offer the following comments in support of concerns which were brought up by .others at the April hearing:

THE SUPERFUND CLEAN UP PLAN

(I) I feel it will be a great risk to public health and the environment to flow toxic and hazardous waste materials containing concentrations of plutonium as well as other manmade radionuclides. inorganic and organic contaminants, from the Lowry Landfill Site as indicated at the April 2,1997 Hearing. As we are aware, the plan is to flow waste from (com.) 570

(cont. 5/12/97 to Hegemen, CDPHE, from M. Hanks)

Lowry Landfill through a pipeline which will be connected to the City of Aurora sewer line. This waste will then flow to the Public Owned Treatment Works in Denver (Metro Grow), be mixed with sewage, be treated like sewage, the residue liquids will be dumped into the South Platte River, and the sludge will be transported via trucks traveling over public roads to be spread on farmlands in Arapahoe and Elbert counties in the Deer Trail and Agate Colorado area.

AN ENORMOUS AMOUNT OF WASTF./A 30 YEAR PROCESS

(2) The amount of waste is so enormous at the Lowry Landfill Site that the Colorado

Department of Public Health and Environment indicated at the April 2, 1997 Public Hearing that they had estimated it would be a 30 year process to flow ground water containing the waste materials through the pipeline and Aurora City sewer system to Metro Grow. If this type hazardous waste flows through those sewer system, flows down the So. Platte River, and is spread on farm lands over such a great period of time it will inevitably endanger public health and the environment.

AURORA RESIDENTS & WORKERS:

(3) Such contaminants in the sewer lines would be a health risk to Aurora residents and any workers or others exposed. One example of exposure would be when sewer lines backed up in homes.

THE SOUTH PLATTE RIVER

(4) These liquid residues from the waste dumped into the South Platte River would

(cont.)

2 571

(cont. 5/12/97 to Hegemen, CDPHE, from M. Hanks)

contaminate the immediate area and flow downstream contaminating water supplies for humans, livestock, and irrigated food crops.

EASTERN ARAPAHOE & ELBERT COUNTY FARMLANDS:

(5) Where the sludge would be spread on farmlands in Arapahoe and Elbert counties, there would be great risk to public health and the environment via water run-off from heavy rains and snow which would wash the contaminated sludge dirt, carrying it to human dwellings, water supplies, livestock pastures, and food crops. There would also be great risk when wind storms, common to eastern Colorado, blow the contaminated sludge dirt and spread it by being carrying it through the air.

IT WOULD BY HAZARDOUS WASTE; BIJT, NOT CLASSIFIED AS HAZARDOUS:

(6) There is no method to remove inorganic wastes at Metro Grow; therefore, the liquid residue dumped in the Platte River and sludge spread over farm land in Deer Trail and Agate will, indeed, be hazardous waste, but since the waste will go through the Public

Owned Treatment Works. // will no longer be classified as hazardous by the EPA and CDPHE even though it will still be the same hazardous material.

THE DANGER OF MIXING TOXIC CHEMICALS

(7) The EPA and CDPHE do not know (no one knows) what mixing all the toxic/hazardous substances from Lowry Landfill will chemically create and impose upon health and environment. It seems like this would be of great concern to the EPA and CDPHE. (cont.) 572

(cont. 5/12/97 to Hegemen, CDPHE from M. Hanks)

WHO WTLL BE LIABLE:

(8) Isn't it correct that no one will be liable for the waste after it's dumped in the river and spread on the farm lands? Who will be liable for possible environmental damages and

health injuries resulting from exposure to such contamination?

The Environmental Protection Agency and Colorado Department of Public Health

and Environment must find a safer plan and method to clean up the Lawry Landfill Site which will not impose such great risk upon Public Health and the Environment.

Respectfully yours,

M. A. Hanks

cc Marc Herman. EPA

U.S. Senator. Wayne Allard

U.S. Senator, Ben Nighthorse Campbell

U.S. Representative, Bob Schaefer Colo. St. Senator, Dick Mutzbaugh

Colo. State Representative, Brad Young

Arapahoe County Commissioners, Marie Mackenzie and Polly Page Elbert County Commissioner, Ralph Johnson Denver Area3 Labor Federation A Mj^ | Serving UnionistsUnionists inin Adams,Adams, ArapahoeArapahoe, / m M M ^ ••' Denver, Douglas and Jefferson Counties

360 Acoma Street = Suite 202 Denver, Colorado 80223 Telephone (303) 722-1306 FAX (303) 722-0378

June 30, 1997

Marc Herman Remedial Project Manager, EPA 999 18th Street, Ste 500 Denver, CO 80202

Dear Mr. Herman; I am writing on behalf of the 88,000 members represented by my organization. On Thursday, June 26, 1997 representatives of this organization unanimously adopted a resolution that speaks to a Superfund plan being reviewed by the EPA. The "plan" would have materials transported from the Lowry Landfill Superfund site to the Metro Wastewater Reclamation District (MWRD) facility in Commerce City. My organization is adamantly opposed to these materials being shipped, processed, and in any way handled by MWRD. The workers at MWRD have absolutely no protection from exposure to the known, or unknown hazardous materials. They are not covered by OSHA,' or any other Federal, State, or local laws. These employees will be working 'at their own risk*. It is also our feeling that MWRD has not done a full disclosure to officials or residents that are downstream on the South Platte river. We feel the disclosure needs to happen from the treatment plant at 6450 York in Commerce City, CO to the confluence of the Missouri river in Omaha, NE. The MWRD facility at 6450 York Street in Commerce City, CO simply is not equipped to handle the different fissile materials that are present at the Lowry Landfill Superfund site. Nor is the facility equipped to handle some of the most toxic non-fissile materials at the Landfill. There has also been an ongoing labor dispute between the OCAW and MWRD. The District Manager, Mr. Robert Hite, has employed the services of a regionally known union-busting firm to handle their labor relations. This dispute has lead to a level of mistrust that should cause alarm. Under these current circumstances, treatment of hazardous materials has a heightened danger level. 574

page 2 Marc Herman Ltr, EPA June 30, 1997

For these reasons, we demand that the EPA deny the "plan" for treatment of Lowry Landfill Superfund materials by the Metro Wastewater Reclamation District in Commerce City, CO. There are too many problems in too many areas to endanger so many people.

Sincerely,

Tack Hawkins, President Denver Area Labor Federation end resolution cc: HHRD Board

opeiu 5 afl-cio DALF RESOLUTION REGARDING METRO_WASTEWATER RECLAMATION DISTRICT

WHEREAS: Members of OCAW Local 2-477 employed at Metro Wastewater Reclamation District (MWRD) have been without a collective bargaining agreement for four years; and

WHEREAS: MWRD, under the direction of District Manager Robert Hhe has utilized Mountain States Employers Council (MSEC), the most notorious union-buster in the Rocky Mountain region, as its representative for collective bargaining; and

WHEREAS: The lack of a collective bargaining agreement and a grievance/arbitration procedure has forced OCAW to utilize the Colorado court system to obtain relief result in great legal expenses on both sides; and

WHEREAS: MWRD has recklessly spent thousands of public money to keep OCAW members from securing a contract, and MSEC has made thousands of dollars from this public trough; and

WHEREAS: Union busting in the public sector to the extent practiced by MWRD and Robert Hhe is almost non- existent and that four years of conflict have destroyed trust between OCAW and MWRD; and

WHEREAS: MWRD has agreed to a plan to ship toxic waste from the Lowry Landfill Superfund site to its Commerce City facility where the workers are not protected by OSHA without notifying OCAW of this

y 3IK1

WHEREAS: There is increasing evidence that phitonium, americhnn and other man-made radionucUdes exist at the Lowry Landfill she; and

WHEREAS: This radioactive waste will be run through the Aurora sewer system, will be processed at the MWRD sewage plant, and will be deposited into the Platte River or as sludge on farmland in. Eastern Colorado; and

WHEREAS: The plan by MWRD to treat Lowry Superfund waste poses severe dangers to worker and public health and could result in an even more serious environmental disaster, therefore be it

RESOLVED: That the Denver Area Labor Federation does hereby (1) recognize that four years of union busting and denying a union contract to OCAW members at MWRD is an outrage and demsind that MWRD negotiate in good faith with OCAW to obtain a contract and end the labor dispute; (2) condemn MWRD for utilizing thousands of dollars of public money to pay MSEC for its union busting services and demand that this union busting firm be fired immediately; (3) oppose the current plan to treat waste from the Lowry Superfund she at the MWRD facility which could result in radioactive material being spread throughout the Denver metropolitan area and in Eastern Colorado, and (4) call upon MWRD to replace District Manager Robert Hhe for bis callous disregard for worker lights and the health and safety of all concerned; and be h finally

RESOLVED: That the Denver Area Labor Federation will communicate this resolution forthwith to the management and board members of MWRD, the Environmental Protection Agency, the Colorado Department of Health, the Mayor of Denver, the Governor of Colorado, and members of the Colorado Coiagressional Delegation.

opeiuS afl-cio 576

Draft Resolution by OCAW Local 2-477 to Colorado AFL-CIO on Labor Dispute with Metro Wastewater Reclamation District

Whereas, members of OCAW Local 2-477 employed at Metro Wastewater Reclamation District (MWRD) have been without a collective bargaining agreement for four years;

Whereas, MWRD under the direction of District Manager Robert Hite has utilized Mountain States Employers Council, the most notorious union-buster in the Rocky Mountain region, as its representative for the purpose of collective bargaining;

Whereas, the lack of a collective bargaining agreement and a grievance/arbitration procedure has forced OCAW to utilize the Colorado court system to obtain relief resulting in great legal expenses on both sides;

Whereas, MWRD has recklessly spent thousands of dollars of public money to keep OCAW members from securing a contract, and Mountain States Employers Council has made thousands of dollars from the public trough;

Whereas, union busting in the public sector to the extent practiced by MWRD and Robert Hite is almost non-existent;

Whereas, four years of conflict have destroyed any trust between OCAW and MWRD;

Whereas, MWRD has agreed to a plan to ship toxic waste from the Lowry Landfill Superfund site to its Commerce City facility, where workers are not protected by OSHA;

Whereas, MWRD never officially notified OCAW of this agreement;

Whereas, there is increasing evidence that plutonium, americium and other man-made radionuclides exist at the Lowry Landfill site;

Whereas, this radioactive waste will be run through the Aurora sewer system, will be processed at the MWRD sewage plant, and will be deposited into the Platte River or as sludge on farmland in Eastern Colorado;

Whereas, the plan by MWRD to treat the Lowry Superfund waste poses severe dangers to worker and public health and could result in an even more serious environmental disaster,

BE IT THEREFORE RESOLVED that the Colorado AFL-CIO does hereby (1) recognize that four years of union busting and denying a union contract to OCAW members at MWRD is an outrage and demand that MWRD negotiate in good faith with OCAW to obtain a contract and end the labor dispute; (2) condemn MWRD for utilizing thousands of dollars of public money to pay Mountain States Employers Council for its 577

union busting services and demand that this union busting firm be fired immediately; (3) oppose the current plan to treat waste from the Lowry Superfund site at the MWRD facility which could result in radioactive material being spread throughout the Denver Metropolitan area and in Eastern Colorado, thus endangering the health and safety of workers and the public at large; and (4) call upon the MWRD to replace District Manager Robert Kite for his callous disregard for worker rights and the health and safety of all concerned.

BE IT FURTHER RESOLVED that the Colorado AFL-CIO will communicate this resolution forthwith to the management and board members of MWRD, the Environmental Protection Agency, the Colorado Department of Health, the Mayor of Denver, the Governor of Colorado, and members of the Colorado Congressional Delegation. 578

Draft Resolution by OCAW Local 2-477 to DALF on Labor Dispute with Metro Wastewater Reclamation District

Whereas, members of OCAW Local 2-477 employed at Metro Wastewater Reclamation District (MWRD) have been without a collective bargaining agreement for four years;

Whereas, MWRD under the direction of District Manager Robert Hite has utilized Mountain States Employers Council, the most notorious union-buster in the Rocky Mountain region, as its representative for the purpose of collective bargaining;

Whereas, the lack of a collective bargaining agreement and a grievance/arbitration procedure has forced OCAW to utilize the Colorado court system to obtain relief resulting in great legal expenses on both sides;

Whereas, MWRD has recklessly spent thousands of dollars of public money to keep OCAW members from securing a contract, and Mountain States Employers Council has made thousands of dollars from the public trough;

Whereas, union busting in the public sector to the extent practiced by MWRD and Robert Hite is almost unheard of,

Whereas, four years of conflict have destroyed any trust between OCAW and MWRD;

Whereas, MWRD has agreed to a plan to ship toxic waste from the Lowry Landfill Superfund site to its Commerce City facility, where workers are not protected by OSHA;

Whereas, MWRD never officially notified OCAW of this agreement;

Whereas, there is increasing evidence that plutonium, americium and other man-made radionuclides exist at the Lowry Landfill site;

Whereas, this radioactive waste will be run through the Aurora sewer system, will be processed at the MWRD sewage plant, and will be deposited into the Platte River or as sludge on farmland in Eastern Colorado;

Whereas, the plan by MWRD to treat the Lowry Superfund waste poses severe dangers to worker and public health and could result in an even more serious environmental disaster,

BE IT THEREFORE RESOLVED that the Denver Area Labor Federation does hereby (1) recognize that four years of union busting and denying a union contract to OCAW members at MWRD is an outrage and demand that MWRD negotiate in good faith with OCAW to obtain a contract and end the labor dispute; (2) condemn MWRD for utilizing thousands of dollars in public money to pay Mountain States Employers Council for its 579 union busting services and demand that this union busting firm be. fired immediately; (3) oppose the current plan to treat waste from the Lowry Superfund site at the MWRD facility which could result in radioactive material being spread throughout the Denver Metropolitan area and in Eastern Colorado, thus endangering the health and safety of workers and the public at large; and (4) call upon the MWRD to replace District Manager Robert Kite for his callous disregard for worker rights and the health and safety of all concerned.

BE IT FURTHER RESOLVED that the Denver Area Labor Federation will communicate this resolution forthwith to the management and board members of MWRD, the Environmental Protection Agency, the Colorado Department of Health, the Mayor of Denver, the Governor of Colorado, and members of the Colorado Congressional Delegation. OCAW OIL, CHEMICAL & ATOMIC WORKERS INTL. UNION, AFL-CIO

ROBERT E. WAGES May 6,1997 PRESIDENT

ERNEST J. ROUSSELLE SECRETARY-TREASURER Mr. Marc Herman (8EPR-SR) Remedial Project Manager L. CALVIN MOORE VICE PRESIDENT U.S. Environmental Protection Agency 999 18th Street, Suite 500 JAMES K. PHILLIPS, JR. VICE PRESIDENT Denver, CO 80202

Dear Mr. Herman: INTERNATIONAL OFFICE 255 UNION BLVD. The following are written comments requested by EPA concerning the Lowry Landfill LAKEWOOD, CO 80228 Superfiind Site. These comments are in addition to the verbal comments provided at the April 2nd public meeting on proposed changes to the Lowry ROD. As noted during this MAO. th nd P.O. Box 281200 public meeting the comment period extends from March 24 to May 22 . LAXEWOOO. CO 80228-8200 The Oil, Chemical and Atomic Worker's International Union (OCAW) has a proud history of defending the health and safety (H&S) interests of its members as well as the general -2229 public. Consistent with this history, the OCAW will do everything within its power to :: 303-987-1967 ensure that both the Metro Wastewater Reclamation District (Metro) workers and the public are informed and protected from the H&S and environmental concerns associated with the ROD proposed changes.

It is the opinion of the OCAW that this proposal represents: 1) An irresponsible action by the Metro District, EPA Region VIE, Colorado Department of Public Health and Environment, City and County of Denver, Chemical Waste Management, Inc., Waste Management of Colorado, Inc. and Parsons Engineering Science, Inc.; 2) An unnecessary endangerment of the public and environment, and; 3) An increased and unnecessary risk to Metro workers of exposure to superfund hazardous substances.

The following points are indicative but not all inclusive of OCAW"s health, safety and environmental concerns.

1) The Baseline risk assessment conducted by CH2M Hill in 1993 focused only on human health risks to future populations that may occupy the Lowry site. Additionally, the assessment provided to our office considered risks only from lead and certain radionuclides.

The OCAW has not seen any risk assessments that address risks to the current populations that will be potentially exposed to the more than 130 identified hazardous substances proposed to be transported through the public sewer system. There is Little doubt that these contaminates will leak from the public sewer pipes into the soil and potentially into the groundwater beneath the City of Aurora and any other communities 581 served by these pipes. The risk assessment does not address the effects to the aquatic life of the South Platt River and all downstream users/uses of this river which will receive the effluent of the Metro/Lowry wastewater. It does not appear that effluent limits have been established for all of the contaminants nor have any current limits been factored into the risk assessment. It does not appear that any risk assessment has been conducted to determine the effects on users and the environment from the use of Metro Gro fertilizer or the application of the Metro wastewater sludge on farm lands. It is this same sludge that was deemed a hazardous waste by court ruling in 1996. It does not appear that any risk assessment has been conducted on the livestock that graze off the lands where Metro wastewater sludge has been placed. The addition of the Lowry landfill wastes to the public sewer system will increase both the number and concentration of contaminants in the sludge. It does not appear that any risk assessment has been conducted on the Metro treatment plant workers who will be exposed to the Lowry landfill wastes.

The risk assessment conducted by CH2M Hill while not adequate in scope, was more appropriate for the original ROD requiring on-site treatment of wastes. There is no doubt that the CH2M Hill risk assessment is not adequate for the proposed amendment to the ROD.

2) Transport of Lowry hazardous substances (many of which have not been adequately characterized) through a public sewer system, under residents' homes, knowing that these pipes will leak, is irresponsible. It is especially irresponsible in light of the fact that all of the Lowry wastes can be treated on-site with no risk to the public or off-site environments. According to Parson Engineering's cost estimates, the difference between these two options (i.e., on-site vs. off-site treatment) is $1 million over 30 years. This is an insignificant amount of money considering the potential clean-up costs associated with leaking sewer pipes and adverse effects on the river and the farm lands and the adverse publicity to all parties involved with the Metro treatment plant option.

3) In 1996, a Denver judge ruled against Metro by declaring that the waste sludge from the Metro plant was hazardous waste. Yet this hazardous waste sludge has been applied to farm lands and the gardens of residents. This sludge was deemed hazardous before Metro had received any additional wastes from Lowry. Is this sludge going to be somehow less hazardous now? It is hazardous now and will continue to be hazardous.

4) The Lowry landfill waste contains radionuclides above background concentrations. Based on the March 1994 Record of Decision and the 1992 final RI report the following statements are correct: 1) Am-241 is found in the waste pits and shallow ground water in a concentration 963 times greater than regional background levels; 2) Pu-239 is found in the same locations in a concentration 16 times greater than regional background levels and 5 times greater in the down gradient weathered Dawson monitoring wells, and; 3) Am-241 is found in the deep water monitoring wells at a concentration 1,963 times above regional background levels found in shallow groundwater. The CH2M Hill risk assessment employed a screening methodology to eliminate, from the risk assessment, those radionuclides not deemed to be present for statistical reasons (including detection limits and background considerations). After this screening process, the radionuclides remaining were deemed to be significant enough to be included in the assessment. These included, among others, Cesium-137, Plutonium-239, Americium-241, etc... The Metro treatment plant is not equipped to perform real-time monitoring for radioactivity. The workers have no training or proper PPE to work with such materials. The sewers are not designed to transport this type of hazardous material. If a person or the Metro equipment/facility becomes radiologically contaminated, it will go undetected. Workers risk the possibility of bringing this material home with them. 582 Very few samples were analyzed for radionuclides. The few samples that were analyzed represent a very small portion of the Lowry Landfill Site. It is very possible that significant hot spots of radiological contamination have gone undetected to date. At the very least, it cannot be taken for granted that such hot spots do not exist. This is a risk that does not need to be taken. -' i • 5) The potential escape of Lowry hazardous substances into the public/environment via the sewer system and the contamination of the Metro facility will result in a far greater clean-up effort in the future. There is, according to the Parson's engineering cost analysis, only a $1 million difference between this proposal and an on-site treatment proposal. Such a cost difference does not warrant the increased risk to the public and Metro workers.

6) The workers employed by Metro and who will be working with and around the Lowry hazardous substances are not protected by worker health and safety regulations such as OSHA. Further, the OCAW Metro workers are not covered by any labor contract and thus have no protection from recourse (i.e., "whistle blower protection") when bringing up H&S issues. This type of fear becomes a serious impediment to reporting H&S concerns when working with hazardous substances.

7) In a January 1997 letter from EPA Region Vffl, EPA stated that this proposal"...is a significant change to a component of the remedy selected in the ROD, but does not fundamentally alter the overall approach intended by the remedy". The fact is the entire approach to die remedy has been altered by this proposal. Instead of on-site treatment, treatment will now be effected by a different technology off-site. Transport of the Lowry hazardous substances through the public sewer system will adversely impact the remedy if indeed this material leaks from the sewers. Additional remedlies will be needed to clean-up contamination due to leakage or accidents associated with the sewer. Finally, the Metro facility and workforce are not designed to handle radioactive and carcinogenic. materials.

8) If Metro is allowed to treat Lowry hazardous substances then Metro will need to be designated and designed as a Treatment, Storage and Disposal facility. Is Metro designed to be such a facility?

9) It is not apparent that the risks to the following receptors have been evaluated as a result of this proposed modification to the ROD: Current residents Groundwater beneath the sewer piping and Metro facility Soil beneath the sewer piping and Metro facility People who work on the sewer system People who excavate around the sewer to install TV cable, phone lines; and gas/utility lines. Metro workers Downstream users Crops and Livestock

10) According to Parson's April 1996 cost estimates, this proposal would cost ~ $ 6.4 million while an on-site treatment option would cost ~ $ 7.3 million. Are all of these risks woith ~ $ 1 million? We would hope that even the life of one person is worth far more than $ 1 million.

11) Based on the March 25, 1992 final RI report for the shallow groundwater and subsurface liquids and deep groundwater operable units, it is apparent that the data indicates significant radiological 583 contamination exists and at the very least the presence of this contamination cannot be excluded. The following comments are based on the information provided in this RI report: • The shallow groundwater background levels established for Am-241, Pu-241 and Pu-239/240 for the Lowry site are on the order of at least 10 to 134 times greater than regional background values previously established for the Rocky Flats site. This would indicate the probability that the Lowry background values are not true background values but actually much higher than the true values. Thus, all statements made regarding transuranic values being below Lowry background (i.e., Lowry upper gradient wells) are not necessarily true. • Pu-241 was detected in concentrations 1.5 to 4 times higher than the artificially high Lowry upper gradient background well values. This report states that sampling for Pu-241 was too limited to fully assess the potential degree of contamination. Also it states that Pu-241 was not analyzed for in surface water. Thus, the Lowry site has not been adequately characterized for Pu-241. • Am-241 was detected in concentrations 100 to 1000 times higher that regional background levels. A groundwater sample from the source area indicated Am-241 concentrations greater than 8 times the,already artificially high Lowry background level. This report indicated that proper concentrations of Am-241 could not be determined because of problems with analytical procedures. Thus, the Lowry site has not been adequately characterized for Am- 241. • Pu-239/240 was detected and confirmed in concentrations above both the regional and Lowry site background levels. • The report states that Cs, Ce and Sr are all present in concentrations above Lowry background and their presence may be related to previous site activity. It would appear on the surface that the use of transuranic radionuclides was a common practice associated with this site.

12) Based on a preliminary review of the EPA document, CERCLA Site Discharges to POTWs, the following comments and questions are raised for your review and response: • Based on the evaluation criteria outlined on pages ES-1&2, there is concern as to whether or not the METRO POTW meets all of the criteria. Specifically, the following criteria are called into question: • The discharged CERCLA wastewater must not contaminate sludge or become hazardous to employees at the POTW. The METRO sludge currently is considered a hazardous waste. This is one of the reasons METRO is a PRP at Lowry. Since pre- treatment will not eliminate inorganic contaminants and only some of the organics, these CERCLA contaminants may become hazardous to the POTW employees. This is particularly important, as will be shown later, since the calculations performed to establish safe levels for worker exposures are not correct. Further, the METRO workers are not covered by state or federal health and safety rules. Many of the contaminants are known human carcinogens which both EPA and NIOSH and many H&S professionals believe have no safe level of exposure. The evaluation performed in accordance with the EPA document, "Guidance to Protect POTW Workers from Toxic and Reactive Gases anc} Vapors", besides being done incorrectly, did not take into consideration synergistic health effects from multiple chemical exposures. • The POTW should have a good record of NPDES permit compliance. METRO, in 1989, received a $1.1 million fine for violations of the Clean Water Act. In 1989 METRO announced it was going to discharge 25 million gallons of raw sewage into the South Platte river. This was prevented by the Adams County Commissioners. In 584 1982, METRO was targeted for stricter controls on the amount of ammonia, chlorine and nitrogen in its treated water. This is not a great track record. • The potential for volatilization of wastewater contaminants and the potential for groundwater contamination from transport of the CERCLA wastewater needs to be evaluated. There is no argument that these contaminants will leak from the sewer pipes into the soil. They will also volatilize in sewer manholes. The leakage will reach the groundwater. There has been no written evaluation of these potentials arid how they will be prevented. • The CERCLA wastewater discharge into the POTW's receiving waters must meet the standards of "no toxics in toxic amounts." There has been no voitten evaluation as to the bioaccumulation effect in the receiving waters, especially from the inorganic contaminants and radionuclides. According to this document, am analysis of the fate of the contaminants in the wastewater is required. Dilution is not an acceptable treatment option. • The POTW must be knowledgeable of and hi compliance with any applicable RCRA or other environmental statute. Will METRO be considered a TSD facility?

13) What is meant by the statement on pg. 3-1, "In addition, hazardous waste cannot simply be introduced to sewers outside the POTW property boundary, this would violate RCRA manifesting regulations."?

14) It is assumed that either METRO or the EPA had to evaluate this option in accordance with Table 4- 1 beginning on page 4-6. Please provide the written responses to each of the 26 considerations y presented in this table.

15) Based on a preliminary review of the April 23,1996 document, Evaluation of the POTW Treatment Option, Appendix B - Summary of Metro's Pretreatment Requirements, the column (1) Worker Health and Safety Sewer Cone. Values are not calculated or evaluated properly. Specifically, the following concerns exist: • This Appendix B lists only 79 of the 176 contaminants of concern listed in the ROD. Further, none of the radionuclides are listed in this appendix and thus no worker H&S exposure limits are calculated for radionuclides. • Of the 79 contaminants listed, 49 do not have any H&S exposure limits calculated. As a result of these first two listed observations it is apparent that the hazards of the constituents coming into the POTW have not been adequately characterized with respect to worker health. • For most of the contaminants listed in Appendix B which have a calculated H&S exposure limit value, this value was taken directly from Table 4-2 of the EPA document, Guidance to Protect POTW Workers from Toxic and Reactive Gases and Vapors. These Table 4-2 values were calculated using exposure limit values that are now out of date and inappropriate for use today. Thus, most of the H&S worker exposure limit values in this appendix are incorrect. • Most important to note is that many of the chemicals which need to have H&S exposure limits established, act synergistically. It is inappropriate to simply pull these values off a table (which is what was done). Mixture exposure limit values need to be calculated for those contaminants that act synergistically or have similar effect on the same target organs. This has not been done. • There are a number of problems with following the EPA document on. protecting POTW workers. This document is not current with new methodologies for assessing worker risks and establishing protective limits. A copy of a methodology i? attached for your 585 consideration. The EPA document does not take into consideration non-volatile substances and metals. Also, it does not consider radionuclides. Overall the document is an oversimplification to a very complicated and serious issue.

We respectfully request that you provide written responses to these comments as well as those provided during the April 2 public meeting. Thank you and I hope to hear from you soon.

Sincerely,

Richard S. Hillier, MSPH.CIH OCAW Health and Safety Department cc: Robert E. Wages, President James K. Phillips, Vice President Gregory J. Mooney, General Counsel Joseph A. Anderson, Acting Director, Health and Safety Joseph J. Drexler, Director, Special Projects Sylvia Kieding, Health and Safety Coordinator Donald S. Holmstrom, President, Local 2-477 OCAW OIL, CHEMICAL & ATOMIC WORKERS INTL. UNION, AFL-CIO

May 15, 1997 ROBERT E. WAGES PRESIDENT ERNEST J. ROUSSELLE SECRETARY-TREASURER Mr. Marc Herman (8EPR-SR) Remedial Project Manager L. CALVIN MOORE VICE PRESIDENT U.S. EPA 999 18th Street, Suite 500 JAMES K. PHILLIPS, JR. Denver, CO 80202 VICE PRESIDENT Dear Mr. Herman: INTERNATIONAL OFFICE 255 UNION BLVD. In my May 6, 1997 letter to you regarding public comments on the Lowry Landfill site an LAKEWOOD. CO attachment was apparently not sent with that letter. Attached to this letter is the 30228 attachment for your review and use. MAIL P.O. Box 281200 LAKEWOOD, CO Thank you again for the opportunity to discuss the important health and safety issues 80228-8200 surrounding this superfund site.

3-987-2229 Sincerely, W. 303-987-1967

Richard S. Hillier, MSPH, CIH OCAW Health and Safety Department

cc: Joseph A. Anderson. Acting Director, Health and Safety Joseph J. Drexler. Director. Special Projects Donald S. Holmstrom, President, Local 2-447 File

.3 587

AMERICAN INDUSTRIAL HYGIENE ASSOCIATION JOURNAL 57:641-649 (1996)

A Screening Method for

AUTHORS Occupational Reproductive Health John Jankovic* Frances Drake* Risk

•Safety and Hcahh Technical Most currently recognized occupational exposure limits do not consider reproductive Support, Oak Ridge National Laboratory, P.O. Box 2008, Oak lexicological end points consistently when establishing recommended exposure limits. In many Ridge, TO 37831-6292; cases the information is not available, but perhaps as often, existing data is not employed 'Midwest Trrtinical, Inc^ Oak Ridge, TN 37830 Further, many manufacturer's material safety data sheets omit reproductive hazard information. A method for identifying potential reproductive toxins and screening levels for associated health risks useful for hazard communication and exposure control is presemedJo date, the Registry of Toxic Effects of Chemical Substances jists between 5000 and 6000 chemicals, drugs, and natural substances that show a positive outcome in at least 1 reproductive effects study. This reproductive health risk assessment began with these substances. Usinq elements of the Environmental Protection Agency's health risk assessment process, the list was reduced to 213 chemicals during the hazard identification step. Occupational reproductive guidelines (ORGs) were developed in the dose-response evaluation step. At the time of this writing, 85% of the chemicals identified in the hazard identification step have had a screening level dose-response assessment completed. Of these, 13% are greater than or equal to a threshold limit value (TLV»).The remaining 87% do not have a TLV or ORGs below the TLV.The reproductive toxins list along with the corresponding dose-response-derived ORGs that have been completed, appears at the end of the text Keywords: exposure limits, hazard communication, material safety data sheets, reproductive hazards, reproductive toxins

method for identifying potential reproduc- point, establishing/adjusting occupational expo- tive toxins is presented in Figure 1. This sure guidelines, and controlling exposures below method is useful for hazard communica- these lex-els, the need Tor a special reproductive AQOR 2fiO in CB3P"!EP^^rT tCUtuCuACS tor d* health program is eliminated. posure control. The objectives are to provide in- Based on the current state of health protec- formation on potential reproductive hazards that tion legislation and scientific knowledge, such a safety and health professionals can use to estab- method is timely and justifiable. The Occupa- lish a healthful workplace for all employees, re- tional Safety and Health Administration (OSHA) gardless of gender, and to protect all workers re- requirements for employee hazard communica- gardless of reproductive status. By treating repro- tion include reproductive toxins in the definition ductive toxiciry as any other toxicological end of "health hazard,**2 yet according to a 1991 Government Accounting Office report,'*1 work- ers, as well as the general public, remain inade- . quately protected from reproductive hazards un I'if'i n -^tcpnxficBvt iiuii JHCis one der federal regulations. Although material s fimcDomng of the tnalc or fnniir BQOI [_ data sheets are required for employee health iimainii adnMmLAdndapncoai " yare(l) death of the tection in the workplace, these sheets generally — •m do not provide reproductive hazard informa- tion.141 Established occupational exposure limits

Copyright 1996, American Industrial Hygiene Association AIHA JOURNAL (57) July 1996 The hazard identification process included the develop- ment of the reproductive toxins Hist that was derived from the Registry of Toxic Effects of Chemical Substances (RTECS) database. RTECS, developed by 1

IDENTIFY THE CWTICAL lional setting, omitting sub- •TUDY(t). MOST SENSITIVE stances used exclusively as drugs Review QUARTERLY or hormones. The final repro- ENDPOINT(S). NOAEULOAIL, STATUS CHANOB CALCULATE OHO ductive toxins list emuaa*. of AND 213 potential toxins. These were UNCeHTAIKTV FACTO* taueied into a FoxPro® data- l>ase (Table I). UMMfark Dose-response assessment involved several assumptions. 'first was the assumption that {reproductive effects harrc thres- frequcndy do not take into consideration reproductive end points holds.^' The assumption of a threshold underestimates the risk for that are clcariv below the thresholds established for other toxic ef- a toxin that does not have a threshold. An adjustment for this con- fects." cern was made in the case of transplacental carcinogens by the use There is a growing legal imperative for nondisoiminatory gen- of an additional uncertainty factor of 10. der-neutral occupational health policy*5' diat is contrary to tradi- The second assumption was that animal data is a reasonable hu- tional reproductive health policy, which relies solely on pregnancy man predictor. This is based on the evidence from known human reporting and job reassignment as a means of fetal protection. Such developmental ternary, which in most cases demonstrate!: that an- limited policy falls short of preventing harmful parental exposures imal data are predictive of human developmental effects/*' An un- that may adversely impact me health of the unborn child or die re- certainty factor of 10 was used for animal-to-human extrapolation. productive capacity of adults. For all of these reasons, this effort is Using a single positive animal study for initial inclusion in the data- considered nrifimy- P33ff is uCfiffficu to minimize the iffO'ffiPi"^y or **^imnff 2 true hu* man reproductive m™, Lc_, a false: negative. Requiring positive ef- fects in two or more species is an attempt to limit the number of METHODS DOCCIltUu Du$C POfiQVCS* The third major assumption was that absorption of daic is com- freadoa of the reproductive toxins required idcnrifica- plete regardless of the route of cnioy, and that the toxicny is unal- tion of potential reproductive toxicants, searching the literature tered.'" This assumption frequently leads to an overestimation of for reproductive no-observed-adverse-effea levels (NOAEL) and the risk at a particular exposure level, and no uncertainty factor is lowest-observed-adversc-effcct levels (LOAEL) for the reproduc- applied for route-to-route extrapolation. Taken in total iit is likely tive tmdcamy and determining corresponding occupational rcpro that these assumptions provide a reasonable margin of safety. ductivc guidelines (ORG). Aspects of the Environmental Protec- The dose-response evaluation began with an examination of cur- tion Agency's (EPA's) procedure for risk assessment were used for rent occupational exposure guides for established limits reported as hazard identification and dose-response assessment as appEed in protective of reproductive health. If an exposure limit inclusive of the National Institute for Occupational Safety and Health reproductive health was found, it was adopted as the ORG for that (NIOSH) gh/col ether criteria document'*1 ORGs were calculated substance and entered into the database. The references for occu- using the uncertainty factor method.'7' pational limits included the American Conference of Governmental 589 Reproductive Toxin Guidelines* Chemical Mane Cat No. ORtf m UF Endpoiat' a Z4'-DDD 53-19-0 incomplete 1 Z4.5-T 93-76-5 0.18 mg/m 100 R NA 1 Z45-T. N-butyl ester 93-79-8 0.18 mg/m 100 R NA 1 Z4-0 94-75-7 150 mg/m 100 R NA 1 Z4-D butyl ester 94-80-4 6.0 mg/m 100 D NA Z4-D, isooctyl ester- 25168-26-7 incomplete 1 2-MePA 70657-70-4 7 .06 mg/m 100 D NA 1 Acetaldehyde 75-07-0 14.4 mg/m yit>~) 100 0 NA 1 Acetic add. indolyl- 87-51-4 6 mg/m 100 D NA 1 Acetonitrite 75-05-8 22.7 mg/m 7*1 100 D NA 1 Acrolein 107-02-8 0.1 2 mg/m t.*fn 100 D NA Aoytamide© 79-06-1 043 mg/m' NA NA 220 Aflatoxin-B 1162-65-8 incomplete 1 Alcohol. 2-ethylhexyl 104-76-7 97.7 mg/m 100 D NA 1 Alcohol, ethyl-© 64-17-5 1880 mg/m NA NA NA 1 Alcohol, methyl© 67-56-1 262 mg/m NA NA NA 1 Aldrin 309-00-2 0412 mg/m 1000 D 34 1 Allyl chloride© 107-05-1 3 mg/m NA NA NA 1 Aluminum-chloride- 7446-70-0 036 mg/m 100 R NA 1 Aminonicotinamide 329-89-5 042 mg/m 1000 D NA 1 Aminopteridine 54-62-6 1.2 ug/m 100 D NA 1 Amitrole© 61-82-5 OJmg/m NA NA NA Amudane 126-07-8 0.75 mg/m* 1000 D NA 1 Arodor 1016 12674-11-2 1.4 ug/m 30 D 33 1 Arodor 1254 11097-69-1 14 ug/m 30 D 33 Arodor 1260 11096-82-5 14 ug/m* 30 D 33 1 Arsenic (ehnti/organic) 7440-38-2 05 ug/m 1000 0 AJ 1 Atrazine 1912-24-9 Z1 mg/m 100 R NA 1 BAPN 151-18-8 oesmg/m 1000 D NA BAPN Fumarate 2079-89-2 Oj68mg/m* 1000 D NA Baygon© 114-26-1 OS mg/m* NA NA NA 1 Benomyl 17804-35-2 030 ug/m 1000 R NA 1 Benzene 71-43-2 -J2K. ,t. "> O05 mg/m 1000 0 14 1 Benzene, (epoxy ethyl}- 96-09-3 0.78 mg/m 100 D NA Benzhnidazolecarbamic 10605-21-7 incomplete 1 Benzo(A)pyrene 50-32-8 0.175 ug/m NA TC 1 1 Bisphenol A 80-05-7 03 mg/m 1000 D NA 1 Boric acid 10043-35-3 1.5 mg/m 100 R NA 1 Butadiene, 1,3- 106-99-0 O26 mg/m £ 3^>c?**j 1000 D 400 1 Butyl alcohol, tert- 75-65-0 106 mg/m 100 D NA Butyronitrile, 10232-92-5 incomplete 1 Cacodyfic add 75-60-5 0.1 8 mg/m 1000 0 NA 1 Cadmium© 7440-43-9 2 ug/m NA NA 8 1 Cadmium chloride 10108-64-2 2 ug/m NA NA NA Captan 133-06-2 0.75 mg/m1 100 D NA Carbaryl© 63-25-2 Smg/m* NA NA NA 1 Carbofuran 1563-66-2 O03 mg/m 100 R NA 1 Carbon dioxide 124-38-9 1800 mg/m 3f 00 sy 10 D/R NA Carbon disulfide 75-1 5-0 84 mg/m1 100 D NA 1 Carbon monoxide 630-08-0 14 mg/m ^Vj NA D/R NA Cartap 15263-52-2 incomplete Chlorhydrin 96-24-2 incomplete 1 Chlorine dioxide© 10049-04-4 0.28 mg/m NA D NA 1 Chloroamphenicol 56-75-7 12 mg/m 100 D NA Chlorobenzene© 108-90-7 46 mg/m1 NA NA NA J Chloroform 67-66-3 Z6mg/m Jtf'v, 100 D 200 Chloromethyl mercury 115-09-3 LOD NA NA NA

continued

A1HA JOURNAL (57) July 1996 Reproductive Toxin Guidelines* (continued) OtemiolNam CasNo. ORC* (IF Eodpotat' a Coal-derived complex None 3 mg/m1 1000 D 6300 Cydohexanone© 108-94-1 lOOmg/m1 NA NA NA Cyciohexytamine 108-91-8 43 mg/m1 25 R NA Cydophosphamide 50-18-0 6p.g/mJ 1000 D/R NA Cyclophosphoramide 51-18-0 incomplete DDT 50-29-3 0.01 mg/m1 1000 R 3 Oiaminotoluene. 2, 4- 95-80-7 0.1 1 mg/m1 1000 R 300 Oiazinon 333-41-5 1.08ng/mJ 1000 D NA Oibenzofuran. 57117-31-4 incomplete Dibromodiloropropane 96-12-8 4jig/m* 1000 R 7A Oichlorobenzene, p-© 106-46-7 60 mg/m1 NA NA NA Dichlorvos 62-73-7 0.03 mg/m1 1000 D NA Dicumarol 66-76-2 00)1 mg/m1 10 D NA Dieldrin 60-57-1 00)12 mg/m1 1000 R 3.4 Diethylene glycol 111-964 0.75 mg/m1 1000 D NA Diethytstilbesterol 56-53-1 2ng/mJ NA TC NA Dtfblatan 2425-06-1 incomplete Dimethoate 60-51-5 036 mg/m1 100 D NA Dimethyl-2-thiourea, 534-13-4 incomplete Dimethytbenzanthracene 57-97-6 0.1 mg/m1 10000 R NA Dimethytfbrmamide 68-12-2 135 mg/m1 100 D NA Dimethylurea, 13- 96-31-1 120 mg/m1 100 D NA Dtnocap 39300-45-3 0X13 mg/m1 1000 D NA Dinoseb 88-85-7 0.01 mg/m1 1000 D NA Dioctylphthalate 117-81-7 3 mg/m1 100 R NA DPPD 74-31-7 0.08 mg/m1 1000 D • NA Duuffiram 97-77-8 046 mg/m1 100 D NA EGOME 110-71-4 0.18 mg/m1 1000 D NA EGEE 110-80-5 13 mg/m1 100 D NA EGMBE 111-76-2 3j6mg/mJ 100 D NA EGME 109-86-4 03 mg/m1 100 D NA EGMEdt- 111-77-3 9 mg/m1 100 D NA EGMEA 110-49-6 03 mg/m1 NA D NA EGMEEA 111-15-9 2.7 mg/m1 100 D NA EGPE 2807-30-9 25.6 mg/m1 100 D NA Endrin 72-20-8 0.01 2 mg/m1 1000 R NA Enflurane 13838-16-9 incomplete Epichlorhydrin© 106-89-8 038 mg/m1 NA NA 13 Ergocalriferol 50-14-6 1 iig/m1 NA D/R NA Ethyl methane sulfonate 62-50-0 0.03 mg/m1 10000 R NA Ethylene dibromide 106-93-4 Spg/m1 100 R 5.6 Ethylene glycol 107-21-1 26 mg/m1 100 R NA Ethylene glycol diethyl 629-14-1 incomplete 1 Ethylene oxide© 75-21-8 1.8 mg/m NA D 600 Ethylene thiourea 96-45-7 030 mg/m1 100 D 10 Ferbam 14484-64-1 634 mg/m1 100 D NA J FiremasterBP-6 59536-65-1 1.4ng/m 30 D NA Folpet 133-07-3 6 mg/m1 10 D NA Formamide 75-12-7 5.22 mg/m1 100 R NA Fungaflor 35554-44-0 Oj60 mg/m1 100 D NA Furffuramide 3688-53-7 13 mg/m1 10000 R NA Gallium-arsenide 1303-00-0 incomplete Glycidol 556-52-5 0.09 mg/m1 1000 R NA Glycol ether 111-46-6 75 mg/m1 10 D NA Gosjypol 303-45-7 00)2 mg/m1 100 R NA Halothane 151-67-7 0.1 6 mg/m1 1000 D NA Hexachlorobenzene© 118-74-1 0.025 mg/m1 NA NA 40

continued 591 Reproductive Toxin Guidelines* (continued) OwmiallUmt CatNo. onf jgL OF Endponit a 1 Hexachlorphene 70-30-4 0.6 mg/m 100 D NA 1 HexaneO 110-54-3 176 mg/m NA NA NA Hexanedione, Z5- 110-13-4 incomplete 1 Hydrazine 302-01-2 0.006 mg/m 1000 D NA Hydroxymethyl mercury 1184-57-2 LOD NA NA NA Iodine 7553-56-2 incomplete 1 Isocyanate, Methyl- 624-83-9 0.002 mg/m 1000 D NA 1 KanechlorSOO 61788-33-8 1.4 ug/m 30 D NA Kepone 143-50-0 incomplete 1 Lead 7439-92-1 04)1 mg/m 1000 D NA 1 Lead acetate 301-04-2 0.01 mg/m 1000 D NA 1 Leadtetraethyl 78-00-2 04)1 mg/m 1000 D NA 1 Lewisite 541-25-3 05 ug/m 1000 D NA Lindane 58-89-9 04)03 mg/m1 0^.^ 1000 R NA 1 Maneb 12427-38-2 3 mg/m NA D NA Melamine hexamethyl- 645-05-6 incomplete. Mercury OD chloride 7487-94-7 04)1 mg/mj NA NA NA Mercury (11) oxide 21908-53-2 04)1 mg/m1 NA NA NA 1 Mercury and compounds 7439-97-6 04)1 mg/m NA NA NA Methanesulfbnic acid, 66-27-3 incomplete 1 Methotrexate 59-05-2 0.15 mg/m 100 D NA 1 Methoxychlor 72-43-5 34)1 mg/m 10 R NA 1 Metnoxyfiurane 76-38-0 8.1 mg/m 100 D NA Methyl benzimidazole 1065-21-7 incomplete 1 Methyl chloride 74-87-3 4.65 mg/m 100 R NA 1 Methyl ethyl ketoned 78-93-3 590 mg/m NA NA NA Methyl mercury 22967-92-6 LOD NA NA NA Methyl metiram 8064-35-5 incomplete Methytene chloride 75-09-2 2.4 mg/m1 100 R 14 1 Methytfbrmamide. N- 123-39-7 5 A mg/m 10 D NA Methylpyrrolidone, N- 872-50-4 051 mg/m* 1000 D NA 1 MIBK© 108-10-2 205 mg/m NA NA NA 1 Mimezol 148-79-8 04) mg/m 100 D NA Mirex 2385-85-5 incomplete Molybdenum 7439-98-7 incomplete Morpholine 24602-86-6 incomplete Mustard gas 505-60-2 04)03 mg/m1 1000 R NA 1 Nickel 00 chloride 7718-54-9 04)1 mg/m 100 R NA 1 Nickel and compunds 7440-02-0 04)1 mg/m 100 R 8 Nickel carbonyl 13463-39-3 04)1 mg/m1 100 R NA 1 Nicotine 54-11-5 04)1 ug/m 100 D NA Nitrofen 1836-75-5 lOug/m* 100 D NA 1 Nitrefurazone 59-87-0 04)9 mg/m 1000 R NA Nitrogen dioxide 10102-44-0 0.1 8 mg/m1 10 R NA 1 Nitrosamine, diethyl- 55-18-5 7 ng/m NA TC 1 Nitresamine, dimethyl- 62-75-9 04)2 ug/m1 NA TC 1 NitrosometnylureKM .1 a 684-93-5 0.4 ug/m1 10000 TC NA Ntaotoluene.o- 88-72-2 incomplete Nitrous oxideO 10024-97-2 90 mg/m1 NA NA NA Oxygen 7782-44-7 ppO, 148 mm Hg NA D NA 1 efcruofoeuiyiene 127-18-4 11 Sfl mg/m 100 R 20 1 Petroleum naphtha 64742-95-6 12 mg/m 100 D NA 1 Phenol 108-95-2 34i mg/m 100 D NA Phenylalanine nitrogen 148-82-3 incomplete DW^M^Mrnenyirncrujn* ^ffi f ncr acetata^ftt Jt e^ 62-38-4 LOD NA NA NA 1 Phosmet 732-1 1-6 04)1 mg/m 1000 D NA 1 Phosphate, trimethyl- 512-56-1 0.60 mg/m 1000 R NA

continued

AIHA JOURNAL (57) July 1996 592

Reproductive Toxin Guidelines* (continued) Chemical Mam Us No. /»yCu..r^j ouf OF Endporat' a j Phthalate,dibutvt- 84-74-2 0.72 mg/m 1000 D NA 1 Piperonyl butoxide 51-03-6 0.90 mg/m 1000 R NA J Porybrominated biphenyt 67774-32-7 1.4ug/m 30 0 NA J Polychlorinated biphenv) 1336-36-3 1.4ug/m 30 D 33 1 Potassium iodide© 7681-1 1-0 ID mg/m NA NA NA Propionicacid 120-36-5 incomplete Resorcinol methyl ether 150-19-6 incomplete Ronnel 299-84-3 ODBmg/m1 1000 D NA 1 Sodium arsenite© 7784-46-5 0.01 mg/m NA NA 100 1 Sodium chlorite 7758-19-2 634 mg/m 1000 D NA 1 Sodium fluoride© 7681-49-1 23 mg/m NA NA NA 1 Sodium iodide© 7681-82-5 1 mg/m NA NA NA Sodium nitrite 7632-00-0 incomplete Sodium seJenate 13410-01-0 incomplete Sodium setenite 10102-18-8 incomplete 1 Styrene 100-42-5 85 mg/m NA O 03 1 Sulfur dioxide 7446-09-5 23 mg/m 100 D NA TCDO 1746-01-6 incomplete 1 TEG 112-27-6 338 mg/m 100 D NA 1 TEGDiME 112-49-2 75 mg/m 10 D NA _ 1 1 T cii jujiy I 1 ic 143-24-8 3.6 mg/m NA NA NA 1 Tetrahydrofuran© 109-994 590 mg/m NA 0 NA Thiadiazote. 26907-37-9 4ug/nr1 100 D NA 1 Thiourea 62-56-6 6 mg/m 1000 D NA 1 Ttiiram 137-26-8 0.16 mg/m 1000 D NA 1 Toluene 108-88-3 9.6 mg/m 10 D NA 1 Tohienediamine. o- 95-80-7 13 mg/m 100 D NA 1 Tohwnesulfonamide. o- 88-19-7 2.4 mg/m 100 D NA 1 Toxaphene 8001-35-2 0.02 mg/m 1000 D 20 Tributyl tin oxide 56-35-9 incomplete 1 Trkhlorfon 52-68-6 0.48 mg/m 100 D NA 1 Trichloroethylene 79-01-6 55 mg/m 100 O NA 1 Tridiphane 58138-08-2 0.02 mg/m 500 R NA J Triethytenemelamine 51-18-3 60ng/m 10000 R NA 1 Triethylenetetramine 112-24-3 25 mg/m 10 D NA 1 Trlfluralin 1582-09-8 3 mg/m 1000 D NA 1 Urethane 51-79-6 6 mg/m 1000 O NA 1 Vmyl chloride 75-01-4 1 3^.:,^ 4ug/m NA TC 1 J 1 Vmylidene chloride 75-35-4 14 mg/m 10 D NA 1 Warfarin 81-81-2 lOug/m 10 D NA 1 Xytene,o-,m-,p- 1330-20-7 15 mg/m 10 D NA 1 ZncsuHate 7733-02-0 2 mg/m 1000 D NA limlti. 'ORGs represent 8 hour time-weighted averages unless otherwise noted. CD- Developmental; B - reproductive; TC= transpUcenal cardnogen; CR - cancer risfc/10.000; uf «= uncertainty factor;9 ° TIV believed to be adequate to protect reproductive health; LOB ° Ihnit of detection

Industrial Hygiarists' Documentation of Threshold Limit Values, preferred for the NOAEL/LOAEL, but in the majority of cases OSHA substance-specific standards permissible exposure limits, quantitative human exposure data were not available. If human (FELs), the German Maximum Concentrations in die Workplace0 data were not found, NOAELs/LOAELs obtained from animal (MAKs), and NIOSH recommended exposure limits (RELs). studies were used, typically employing the most sensitive end If an exposure limit was not found, the literature was searched point from the most sensitive mammalian species. If inhalation for a NOAEL or LOAEL with a reproductive end point. The data were unavailable, ingestion studies or dermal studies were search for information on the NOAEL/LOAEL consisted of used. studies from peer-reviewed literature found in the following The NOAEL or LOAEL was converted to a value for hu- 1 (IO databases: Hazardous Substances Database," TOXLINE, > mans using the calculations employed by NIOSH'" and IRIS, NIOSHTIC,11" REPROTOX,'"' and IRIS/11' Human data were i.e., scaling the NOAEL or LOAEL to a humain equivalent 593 dose and dividing by a combined uncertainty factor, including a The lifetime cancer risk was included to provide a comparison 10 for variability in human susceptibility. For inhalation data the between the reproductive guideline and the cancer risk at that absorbed animal dose was determined using the average animal level body weights and inhalation rates described in EPA's Toxicology For substances listed by the World Health Organization'20' as Handbook.™ transplacental carcinogens in animals, the ORG was established Absorbed animal dose (inhalation) for reproductive end points: based on the exposure corresponding to an occupational lifetime risk of 1 in 10,000 when an EPA slope factor was available. This (mg/kg/day) = NOAEL (mg/m3) risk was chosen to represent a level equated with the risk of mor- tality from work in the retail doming scout."*' If a slope factor was inhalation rate (mVday) exposed hours unavailable, the ORG was "'nilatH using the uncertainty factor animal body weight (kg) 24 hours method with an added uncertainty factor of 10 for the nonthrcsh- old possibility extant with transplacental carcinogenesis. The absorbed animal dose was converted to an equivalent hu- Unit risk per ug/m3 man concentration by assuming a 60-kg body weight (average fe- male weight"5') and a 10-mJ inhalation rate for an 8-hour work- slope factor per mg/kg/day x IQ m3/day (U> day. The average female body weight was used, as it results in a body weight (60 kg) x 1000 ug/mg more conservative ORG. (10~») X (70 yrs.) Equivalent exposure for humans: Hg/m3 (40 yrs) X unit risk per ug/nr absorbed dose for animals (mg/kg/day) X 60 kg (mg/ms) 10 mVday An example of a reproductive record is depicted in Figure 2. Fields i CAS number, np*^"' When oral or dermal animal data was used, it was converted to fm\f _ r\**x of chemical gnmpnnnj ^ animal m^ix With positive rC- aa equivalent human airborne concentration by assuming a 60-kg productivc TOidict,ORG , UF, end point, an^ the ""ffr risk asso- body weight and a 10-m1 inhalation rate. dated with the ORG (if an EPA unit risk was available). A memo Equivalent exposure for human* (oral and dermal): held contammK dcscnpove information on human and animal re— productive/developmental data along with the information used 60kg for fsnhlrthrng the ORG (indudmg the uncertainty factors) was (mg/ms) = mg/kg/day x 10 mVday Substances may be *^«H. *+i*™"\ for a or deified from the database on the basis of new in- The equivalent exposure for humans was then divided by an un- ton certainty factor to obtain the ORG: A copy of the d*Tf mg the ORG list and the descrip- no odd is available by sending two floppy disks and a seif- equivalent exposure for humans addrcssed envelope to the authors. ORG uncertainty factor The multiplicative uncertainty factors"6' included 10 for most DISCUSSION sensitive human, 10 for animal to human extrapolation, 10 for use of a LOAEL, 10 for inadequate study design and a possible modi- The purpose of dm study was to provide a frame of reference for fying factor of 0.1 for a high animal dose (>1000 nig/kg/day),117) I reproductive rKJlUi ^Wvm» uon in the workplace regardless of gen- and 0.1 for an animal study with effects seen only at maternally der or reproductive status. The safety of the workplace dfpm** on tone doses. The modifying factor for studies reporting develop- n2Z2PQ Kicnoncjnoii followed bv ^TCPOiHiTf CDQCDOI Dtiow m CSCXD** ntenral effects only at maternally toxic doses was included since "ad- lishcd limit, and these limns should protect workers from afl adverse verse effects on development that occur only with maternal toxkity , inrinriing reproductive effects. While ORGs do not i may not indicate a specific hazard to the conceptus" and thus are vTTnsrirms standards or l****n\ they are pj^yn on reproducove end not as great a concern."*' The uncertainty factors (UF) applied in points. ORGs can be used to flag rwfnii.il reproductive mikity each ORG determination are included in the list at the end of this conmiii. for workers at the levds fisted. As ten™* earlier, where a article. TLV is bcEcved to be protective of reproductive effects, it is used as For carcinogens with slope factors published by EPA,"" an up- the ORG. The assumption that other nonreproductive eficns are per bound estimate of the cancer risk expected over a lifetime of automatically safeguarded at a particular ORG or TLV is not justi- occupational exposure at the ORG was determined using the fol- lowing calculations. which cancer risk could be g4% (26/31) of the corre- sponding ORGs equated to a nrvrr risk in excess of 1 in 10,000; Unit risk per fig/m1 » some consider risk above this level unacceptable, slope factor per mg/kg/day x inhalation rate (10 mVday) The study has generated a daah»tf consisting of 213 poten- tial reproductive toxins. The majority of the substances have as- body weight (60 kg) x 1000 ug/mg sociated ORGs based on animal reproducove NOAELs or LOAELs. As expected, there are differences between the ORGs- Lifetime cancer risk - and existing TLVs. At this time 85% (180/213) of the dose/re- ' 3 3 sponse determinations have been completed; of these, 47% exposure at ORG (lig/m ) x 40 yrs x unit risk per ug/m (85/180) do not have established TLVs. For substances with 70yrs TLVs, 25% (24/95) have established limits equal to or lower

AIHA JOURNAL (57) July 1996 594

recognized. The two major categories of limitations an: lack of CAS NO: 67-56-1 information on specific chemicals and inadequate mechanistic U&9509 models useful in extrapolating from animals to humans. The Ch**" type: A C D M S T • ' identification process of potential reproductive toxins is limited Species: Rat Mas by the amount of currently available toxicological data on repro- ORG: 262 mg/taf ductive effects. If, during the literature search, insufficient data is UF: NA—TLV believed to be protective CA-RBK/1E4: NA found on the reproductive effects of a substance, this is reported ENDPOINT:D in the memo field. RTECS is used as a primary data source due to its comprehensive inclusion of positive data. However, RTECS PROFILE: METHYL ALCOHOL does not report negative studies, which limns the documentation available for a weight of evidence approach to substance selection PHYSICAL DATA: MW: 32.04; Physical state: liquid; VP: or elimination. Another problem frequently encountered is the 96mmHgat20>C. difficulty in finding certain citations, especially foreign citations. Less frequently encountered, but just as limiting, a citation is lo- OCCUPATIONAL STANDARDS: ACGIH 262 mg/m1; cated that does not include a dose level from which to calculate NIOSH 260 mg/m1; MAK 260 mg/in1. Group D. an ORG. The ORGs presented are based on the most sensitive "Classification in a pregnancy group is not yet possible.' (lowest) reproductive NOAEL/LOAEL discovered using the sources lefereiiccd earlier. A reasonable effort was made to locate PPE: Material is toxic via skin absorption. Therefore, skin the best available information. Beyond this no claim of veracity is contact must be prohibited or else the ORG is invalidated. made. The majority of the available reproductive data used in es- Butyl Robber and Saranex are best PPE «Mt»p«ic Natural tablishing-human inhalation ORGs is from oral studies in ani- Robber. Nitrite Robber. PVAL, and PVC are not mals. The difficulties with extrapolation between species and routes of exposure are frequently discussed in the Uteruure. In the absence of human data or mechanistic models the usual al- ANIMAL DATA: Rogers, et aL. reported two studies in mice ternative is to apply uncertainty tfactors for the various assump- win inhalation doses of MeOH at 5000 and 10.000 ppm (smdy tions inherent in the assessment. 1) and 2000 and 5000 ppm (study 2) for 7 boon a day on days 6 iimiMjii 16 of getnnon. In bom Bwft** the 5000 ppm : exposure produced exeocephary in one-nurd of the tttutn. At CONCLUSION TfjfjQry**! 1 of 220 femes had exencephary. Controls bad no incirtrnre of exencepbaly in the offspring. (Rogers, This stud)' presents information on reproductive exposure Toxicologist, 11(1)344. 1991). In a monuecent study. I guides on which to base huard assessment and make in- Rogers exposed mice to 1000, 2000.5000, 7500. 10.000, or formed decisions on the need for exposure control. In most 15.000 ppm methmol for 7 hrs/day on days 6-15 of gestation. cases, the ORGs have been derived from a screening level of risk The NOAEL fat developmental toxiciry was reported at 1000 assessment and should not be construed as unequivocally safe ppm (1310 mg/m1). A dose-related increase in cervical ribs H fm exposure limits. It is hoped that they will serve as a catalyst and was significant at !k* 2000 ppm level. ^* ** ^t4 fTfiyrp*"*y forum for further debate resulting in refinements thai: will en- and cleft pa lair were lepuiied at 5000 ppm, and increased hance occupational health without being unnecessarily burdcn- embryo/fetal death at 7500 ppm (Rogers, et aL. Teratology. some. Man 47(3), pp: 175-88,1993). Rats have been found to be less sensitive than mice to the **"***"[ "»'•* effects of metfaanol, with effects seen only at 10,000 ppm and above (Rogers, Toxicologist, Mar. 13(1), pp:l3,1993). REFERENCES 1. Office of Technology Atccasmeit Talk Force Repmlattm Health ORG RECOMMENDATION: Using the NOAEL of 1000 Hmxardi in du WyrkfUte. Philadelphia, PA: J.B. Lippincon Co., 1938. pp. ppm (1310 mg/m1), the ORG is 458.5 mg/m when an 6,55. uncertainty fauini of 10 is applied (10 for most vinilivc 2. "Labor," CUt rfftdaml Rjyubtiatu Tide 29, PL 1910.1200 1989. pp. 10 for i and 0.1 as a modifying 354-355. factor for the high dose). Since me calniltwl ORG is above 3. United Sates Cental Accounting Office: RtproAnam und Dntlop- the TLV. the TLV of 262 mg/m1 is accepted as the ORG as mtnttl Ttaaanus, Rffulattn Actual Prnide Uactrtam Prtuaion tlVC OT TCpfOuUCDYC CltCCtft* (GAO/PEMD-92-3). Washington DC, October 1991. pp. 2-3. 4. Paul, M. and S. Knrcc Analysis of reproductive heakh hazard informa- tion on material safctv data sheets Ibr lead and die ethyicnc gtool cthen. Am.J.lmLUU. 25*03-415 (1994). 5. Headapohl, Dana AL: Sex, gendcx, biology, and work. In Ottmponm*! Matiame: Soot eftke Art Rentn, vol. 8, no. 4, DM. HaidapohL, ed. than the calculated ORG and were assumed adequate for protec- Philadelphia, PA: Hanky and Bdftis, Inc, 1993. p. 693. tion of reproductive effect*,, leaving 75% that have established 6. National Imoxnte for Occupational Safety and Health (NIOSH): Crittna far a RtttmmnM SuauJard, Occupttiantl Expoant t» EtMeut limits greater than the ORG. Overall, 87% (156/180) of the sub- Gljtel MnumaW Ether, EtMau Chad MtnottM Edxr, a«d Tter At- stances identified by the dose/response portion of this assess- earns (pab. no. 91-119). Cindnnao, OH: NIOSH, 1991. pp. 115-118. ment method have inadequate reproductive exposure limits. As 7. "Guidelines for Devdopmental Tcoriciry Ride Assessment" ffderml Rtgit- expected, animal data make up the majority of die available toxi- trr 56234 (5 December 1991). p. 63801. cologicai information, although 9% (17/180) of the ORGs are 8. Calabrece, E.J. and EJkL Korean: Air Taaa amd RM Aaeamtut. based on human data. Several limitations to this method must be Chdiea, MI: Lewis PubuMien, Inc., 1991. p.613. 9 SilverPlatter Information: Hazardous Subnantts Database (CD-ROM). 16. National Academy of Scicncri- Ritk Aatomtnt in tbt ftdtnl Gortrn- Norwood, MA: U.S. National Library of Medicine, 199S. mtMK Manaaing the Prectn. Washington, DC: National Academv Press, 10 SUverPUnerInfonnatioa:7T)XL/NE(CD-ROM). Nonvood,MA:U^. 1983. pp. 17^83. National Library of Medicine, 1995. 17 European Community Council: Claaificaaan and labelling afDangtr- tut Subunta. Annex VI, 67/548/EEC, 1967. 1 1 saverPlatter Information: TOXUNE (CD-ROM). Norwood, MA; Na- tional lmnf"g for Occupational Safety and Health, 1995. 18. Khera, R5-- Maternal toxicitv: A possible etiological (actor in embryo re- p Reproductive Toxicology Center, Columbia Hospital for Women:. al df*h« and fetal malformations of rodent rabbit species. TiranWagr * REWOTOX [Computer Database]. Washington, DC, 1995. 32:129-153 (1985). 13. SaverPlatter Information: NIOSHTIC (CD-ROM). Norwood, MA: 19 U.S. Environmental Protection Agency: Health Effort Aoaomtat Sum- National Institute for Occupational Safety and Health, 1995. mon T«Wa(OERR 9200.6-303). Springfkld, VA: National Technical In- 14. Environmental Protection Agency (EPA): Tcodcolegy Handlnek. formation Sen-ice, 1991. pp. B-l, B-19. Rockvillc, MD: Government IT^H"**. Inc., 1987. pp. 6-7. 20. World Health Organization (WHO): Prinaplafor Evaluating Health J 15 milr-fr"*. . WJL and ILM.. Crninrngrum: Quantitative Ritt Aaat- Ratt n Pngcni Amritrr with Exfaatn to Cbcmuah During Prtgnann matt For Enrirmxtaual and Ocatfotmal Health. Chelsea, Ml: Lewis Geneva, Switzerland: WHO, Environmental Health Criteria 30,1984. pp. Publishen, Inc., 1987. p. 45. 79-80.

AIHA JOURNAL (57) July 1996 DEC-11-iyyb lfc>:;>Y hKUn IU

596 '.^. Denver Local 2 477 Donald S. Holmstrom, President 6200 Gale Drive OCAW 1 Oil, Chemical and Atomic Workers V%H~ T ^^ Boulder, Colorado 8030.* International Union, AFL-CIO ^^SiK/ 303-494-9684 (Voice and Fax)

December 11, M r. Vfa.tr. United Scares EPA Region VET (8 HWM-FR) 999 ISA Street, Suiws 500 Denver, CO 80202

Deal Mi. Herman:

This .is a. follow-up to my August 20.1996 \e.rre.r to you regarding die proposed modification of the Rix.iurtl of Decision (ROD) for Lowry Landfill. The purpose of this letter is to formally request that the EPA: I) Pro-vide a minimum 90-day Public Comment Period and provide for public meetings for potentially impacted and interested parties; and 2) Consider rliix process an Amendment to tlic Record of Decision ioi Low ry.

In your August 29,1996 lector to me, you indicated that an Explanation of Significant Differences (HSU) document would be issued followed by a public comment period and a public nice ting. "We request spciu that the public conjroentpcriod.be no less than 90 days and that more than one public meeting be held. As y know, the Oil, Chemical and Atomic Workers Unba, Local 2477 and the International only recently learned about tlie proposal to pipr l.owry Landfill Supcrfond Site Laxord.ous waste effluent to die Metro Dlsuifr tor treatment. In recent phone co nvctsatioos between yourself and the OCAW yo n have iudicared that you are proposing a 30 day public comment period beginning in January 1997. We do not believe such asho rt com men i period will allow the OCAW, its Metro Worker* and udicr potcnmltv Lu«jr^:ic

In hght of the volumes of information which man. be reviewed, the upcoming holiday's of C'.hristmas and N cw Years will Itmh die ability of interested groups to begin reviewing information prior to the official comment period. Input I have received regarding ditcuscioiu nidi, our Metro workeis, .Deer Trail residents, neighborhood residents and individuals down river indicate they are not aware of diis new ROD Amendment- It is oiir opinion thai; a 30 day public commcntperiod would noibc reasonable for these people to adcrjuatery pro vide yo u t ag«ncy vjuntlr input. We recognize dcu Lrvjucsung a 90 day public comment period is not unusual and is normally granted- We request your serious consideration of this reasonable request. It u also recognized that rb» ROD Amendment ha* die poieuual 10 im pact various popiclarions in dtfrerent geographical locations. Examples of this include, the Metro workers (working in close proximity of effluent under normal and emergency conditions), neighborhood residents along the sewer line route {potential for exposure vk sewer line backups, breakage, cue...), Deer Trail £um residents (potential for exposure to biosolids «5?c:ee'iing sdlowabk limits), and the communities down river of the effluent discharge (poteuvial for discharge* to 16.57 FRD, T0

597 EPA Letter Page 2

exceed allowable limits). Because of this, we request that you provide fo r more than o ne public m ecting on this issue. Doing SO will allow your agency u> uiajumizc valuable input from all interested and potential}}' impacted patties. Since rJicCERCLA process requires public input before decision making to asstuc fullaccouutahUu/ for work«, public and envitonmencalsafccy, we liope the EPA wiQ grant our rcquesrs and assure char diis imporuut matter is open to 6iUpubfic.%cruany.

Please notify us is co yon decision regard'uigourrcqaests. Thank you for your consideration.

Sincerely,

Don Holmscrom Pr*ki«CLT:, OCA WI .ocal 2-477 cc Metro Wastc^aBrc Reclaraatioo District Board of Directors Denver City Council Aurora City Council Toe Vcanfca, Colorado Department of Public Health Jack Hawkins, Denver Area Labor Federation (AFL-CIO) Robert E. Wages, Ptesid«nt, OCAW Intl. James 1C PhilJips, Vke President, OCAW Intl. Gregory Mooncy, Genetal Counsel, OCAW^ Intl Joseph A. Andcrsou, Director, Health and Safety Dept., OCAW lnt'1. XJ/ 598

Richard J. Plastino, Chairman of the Board Robert J. Werner, Chairman Pro Tern I \ METRO WASTEWATER Richard N. Walker, Secretary J RECLAMATION DISTRICT Martin E. Flahive, Treasurer Robert W. Hite District Manager 6450 York Street - Denver, Colorado 80229-7499 (303) 286-3000 Telefax (303) 286-3030 April 23, 1997 Mr. Marc Herman U.S. Environmental Protection Agency, Region VIII 999 18th Street, Suite 500 Denver, Colorado 80202-2466 Dear Mr. Herman: With the public comment period on treating the groundwater at the Lowry Land- fill Superfund Site open until May 22, I thought you would like to know that the Metro District's Board of Directors voted overwhelmingly on April 15 to reaffirm the District's intent to treat the pretreated Lowry Site ground- water. The Board deemed the attached resolution prudent in light of the potential for public concern about the District treating the Lowry groundwater. Feeling the public might not understand the precautions the District has taken, the Board included language discussing the precautions and reaffirmed the District's position by a vote of 48-2. The key points of this resolution are these: • Both the EPA and the Colorado Department of Public Health and Environment have determined that the Metro District treatment option will protect human health and the environment and be cost effective. • We have evaluated the groundwater at the site and determined it is safe to treat without adversely affecting worker health and safety, the water the District discharges to the South Platte River, the treated wastewater solids (biosolids) it applies as an organic soil conditioner and fertilizer, the plant's treatment processes, or air quality near the plant. • The District has the authority to enforce its pretreatment standards through its pretreatment permitting process. The District did not take lightly its original June 6, 1996, position nor the reaffirmation of that position on April 15. All the information to date shows this is the best solution for the protection of both public health and the environment and is the best economic solution as well. If you have any questions regarding this matter, I invite you to call me at 286-3000 so I can help provide you whatever information you may need. Yoursjjruly,

Robert W. Hite District Manager

RWH/SDF/bc N:\l_owryl_tr.doc

Enclosure Serving Greater Denver WE USE RECYCLED PAPER 599

0497-6.6 Page 1 of 3 RESOLUTION BOARD OF DIRECTORS METRO WASTEWATER RECLAMATION DISTRICT APRIL 15, 1997 WHEREAS, on June 4, 1996, the Board of Directors of the Metro Wastewater Reclamation District, hereinafter referred to as the "Metro District," unanimously approved a settlement of a lawsuit brought by Chemical Waste Management, Inc.; Waste Management of Colorado, Inc.; and the City and County of Denver against the Metro District in U.S. District Court, Colorado, Case No. 94-Z-1025; and WHEREAS, the settlement has been approved by the U.S. District Court; and WHEREAS, the Metro District has agreed to treat Lowry Landfill Superfund Site (Site) groundwater which meets Metro District pretreatment standards and is in compliance with the terms of a pretreatment permit issued by the Metro District under its approved Pretreatment/Industrial Waste Control Program; and WHEREAS, the volume of Site groundwater proposed to be treated is estimated at 14,400 gallons per day, or about 1/10,000 of the 150 million gallons of wastewater treated daily by the Metro District; and WHEREAS, the U.S. EPA and the Colorado Department of Public Health and Environment have determined that Metro District treatment of the Site groundwater will protect human health and environment and be cost effective; and WHEREAS, Metro District treatment is subject to formal approval by the U.S. EPA before it can be implemented; and WHEREAS, the staff of the Metro District has evaluated the Site groundwater sampling data and determined the. Metro District's permit authority will enable the Metro District to enforce the Clean Water Act and ensure the Metro District will: • protect Metro District workers from adverse health and safety effects caused by the presence of toxic and reactive gases in the sewer system;

• comply with the Metro District's Colorado Discharge Permit System/National Pollutant Discharge Elimination System Discharge Permit;

• comply with State Water Quality Standards; 600

0497-6.6 Page 2 of 3

• achieve the risk-based effluent concentration limits developed by EPA for pollutants not regulated by Water Quality Standards;

• maintain "exceptional quality sludge" levels of pollutants in the biosolids products;

• prevent interference with the Metro District's treatment processes;

• restrict releases of hazardous air pollutants from the Metro District's facilities; and WHEREAS, all of the groundwater sampling data, Metro District's evaluation of the data, Metro District's pretreatment permit requirements, and EPA's determination that Metro District treatment of the Site groundwater is a matter of public record and has been and is available to the public upon request; and WHEREAS, the Site groundwater will be monitored and sampled on an ongoing basis for compliance with Metro District standards and the pretreatment permit; and WHEREAS, on April 2, 1997, the U.S. EPA and the Colorado Department of Public Health and Environment held a public meeting to provide opportunities for public involvement and comment prior to making its final decision on whether to approve the Metro District treatment of Site groundwater; and WHEREAS, at the public meeting, two members of the Metro District Board of Directors spoke against Metro District treatment of Site groundwater, after having introduced themselves; as members of the Metro District Board of Directors; and WHEREAS, the two members of the Metro District Board of Directors did not clearly indicate that they were not speaking on behalf of the Metro District or the Metro District Board of Direc- tors; and WHEREAS, Article XV of the Metro District Bylaws provides that the Chairman of the Board of Directors (or his designee) shall be the general spokesman for the Metro District; and WHEREAS, the Budget/Finance Committee of the Metro District, after having reviewed the matter, recommends that the Metro District reaffirm its commitment to Metro District treatment of Site groundwater; and 601

0497-6.e Page 3 of 3 WHEREAS, the Personnel Committee of the Metro District, after having reviewed the matter, recommends that the Metro District reaffirm its commitment to Metro District treatment of Site groundwater and reaffirm the Bylaw provision making the Chairman or his designee the spokesman for the Metro District; and WHEREAS, the Executive Committee of the Metro District, after having reviewed the matter, concurs in the recommendations of the Budget/Finance and Personnel Committees; and WHEREAS, it is in the best interests of the Metro District to treat Site groundwater; and NOW, THEREFORE, BE IT RESOLVED, that the Metro District hereby reaffirms its commitment to treat Lowry Landfill Superfund Site groundwater which meets Metro District pretreatment standards and is in compliance with the terms of a pretreatment permit issued by the Metro District under its approved Pretreatment/Industrial Waste Control Program; and BE IT FURTHER RESOLVED, that the Metro District reaffirms the Chairman of the Board of Directors (or his designee) shall be the general spokesman for the Metro District under Article XV of the Bylaws.

THIS IS A CERTIFIED AND TRUE COPY OF ADOPTED , ~7 602 THE LOWRY CH2MHILL Reply*: John Davis, Graham & Stubbs LLP P.O. Box 185 Denver, Colorado 80202-0185 (303) 892-7305 Fax: (303)893-1379

May 21, 1997

- Marc E. Herman g i j -^ Remedial Project Manager Si": ^ U.S. Environmental Protection Agency S^ M "^ Mail Code 8EPR-SR oQ ^ 999 18th Street, Suite 500 ~" do Denver, Colorado 80202

Re: Comments of the Lowry Coalition on Proposed Second Explanation of Significant Differences to the Record of Decision for the Lowry Landfill Suoerfund Site

Dear Mr Herman: I am writing on behalf of the Lowry Coalition and its members to provide you with comments supporting your agency's proposed Second Explanation of Significant Differences to the Record of Decision ("ROD") for the Lowry Landfill Superfund Site ("Lowry Site"). The Lowry Coalition's current members include Adolph Coors Compaq, Amax Research and Development, Inc., the City of Englewood, the City of Lakewood, the City of Littleton, Conoco, Inc., Gates Rubber Company, Metro Wastewater Reclamation District, the S.W. Shattuck Chemical Company, Inc., and Syntex Chemicals, Inc. It is my understanding that the cities of Englewood, Lakewood and Littleton have submitted or will be submitting additional comments directly to your office concerning this matter. The Lowry Coalition and its members have actively participated in the study and response to environmental conditions at the Lowry Site since it first became the subject of regulatory concern in the early 1980's. The Coalition and its members are intimately familiar with the ROD for the Lowry Site and the goals sought to be accomplished by the U.S. EPA and the Colorado Department of Public Health and Environment ("CDPHE") through implementation of the ROD. The Coalition and its members have reviewed the Explanation of Significant Differences and support its adoption. The proposed onsite treatment of waste in the former tire

DGS-strrr.i Miyll. 19971 36pm 603

Marc E. Herman May 21, 1997 Page 2

pile area through aeration and/or biodegradation would appear to meet all relevant criteria for such a change from offsite treatment as currently provided in the ROD. Treatment of pretreated groundwater offsite at the Metro Wastewater Reclamation District facilities in lieu of building a new treatment plant onsite is also supported by the Coalition and its members. Offsite treatment at Metro's facility would meet all relevant criteria and be consistent with the goals to be achieved by the ROD.

For all of the foregoing reasons, the Lowry Coalition and its members support EPA's and CDPHE's proposed changes to the ROD for the Lowry Site as set forth in the Second Explanation of Significant Differences (March 1997), and urges prompt adoption of those changes following the close of comment on May 22, 1997.

Respectfully submitted,

ihn R. Jacus 'he Lowry C cc: Coalition Members io the death over sludge;fclPfcaiirtfCflfl"^! byL.. Gy~_; /-__^~L_I/ <; nHtoBol^SLMfonin*

:.,,^*;^<^ *>.•*

.catch-all place for aU the Metrogro stuff," Price says, noting that floods, tornadoes and thunderstorms often send soil into the reservoir. "All of that crap's going to come down on us." His wife tried to relay these concerns to Marc Herman, the EPA remedial manager for the Lowry site who's poised , to approve the plan in spite of admitted flaws in EPA-data that he's used to deem .•everyone safe. When she told Herman •• that the aquifer was full of "live" water £po oJ2^ . (meaning that, like a spring, it often bub- bles to the surface and recharges the reservoir) Herman didn't know what that meant. This was greeted with laughter from the farmers. ««V—"--r ows along the line that smart," she says.' jbably true, and it ccr- Nina JmJd p the first indication.- (n 2505 Juniper ekly reported that EPA Boulder, CO 80304-1959 Jrmine the safety of the in was flawed on the background data 'used as }. levels of "background" pjnatipn th,at.was up to .'than that discovered by 605

May 9. 1997

Mr. Marc Herman 8EPR-SR Remedial Project Manager U.S. Environmental Protection Agency 999 18th Street. Suite 500 Denver.Colorado 80202-2466

Dear Mr. Herman,

This letter is in regards to the proposed Second Explanation of Significant Differences for the Record of Decision, at the Lowry Landfill Superfund Site, now recieving public comment.

It has been brought to my attention that the surrounding landowners, and the residents of the nearby rural communities are concerned about the hazardous contents of the waste. It is significant that this waste includes plutonuim, and other manmade radionudides. and that no treatment process is in place to remove these radionudides, from this waste, either at the Lowry Landfill, or at the Metro Treatment plant, before it is incorporated into the sludge. With this sludge being placed on thousands of acres of farmground owned by the Metro Wastewater Redaimation District, in eastern Arapahoe County, near Deer Trail, as well as other privately owned farmground in Washington and Weld counties, this proposal has many far reaching implications.

The distribution of any kind of hazadous waste containing plutonium, by any application, on land that is used to produce food, or where there may be widespread exposure to the people farming, and residents of the surrounding area and communities, is not acceptable.

I am opposing this proposal, and would appreciate being kept informed of the EPA's dedsion on this matter, as well as any further proposals on this issue.

Thank You, 606

Mav9. 1997

Mr. Marc Herman 8EPR-SR Remedial Project Manager U.S. Environmental Protection Agency 999 18th Street, Suite 500 Denver.Colorado 80202-2466

Dear Mr. Herman,

This letter is in regards to the proposed Second Explanation of Significant Differences for the Record of Decision, at the Lowry Landfill Superfund Site, now recieving public comment.

It has been brought to my attention that the surrounding landowners,, and the residents of the nearby rural communities are concerned about the hazardous contents of the waste. It is significant that this waste includes plutonuim, and other manmade radionuclides, and that no treatment process is in place to remove these radionuclides, from this waste, either at the Lowry Landfill, or at the Metro Treatment plant, before it is incorporated into the sludge. With this sludge being placed on thousands of acres of farmground owned by the Metro Wastewater Reclamation District, in eastern Arapahoe County, near Deer Trail, as well as other privately owned farmground in Washington and Weld counties, this proposal has many far reaching implications.

The distribution of any kind of hazadous waste containing plutonium, by any application, on land that is used to produce food, or where there may be widespread exposure to the people farming, and residents of the surrounding area and communities, is not acceptable.

I am opposing this proposal, and would appreciate being kept informed of the EPA's decision on this matter, as well as any further proposals on this issue.

Thank You, 607

May 9, 1997

Mr. Marc Herman Remedial Project Manager U.S. Environmental Protection Agency 999 18th Street, Suite 500 Denver.Colorado 80202-2466

Dear Mr. Herman,

This letter is in regards to the proposed Second Explanation of Significant Differences for the Record of Decision, at the Lowry Landfill Superfuind Site, now recieving public comment.

It has been brought to my attention that the surrounding landowners, and the residents of the nearby rural communities are concerned about the hazardous contents of the waste. It is significant that this waste includes plutonuim, and other manmade radionuclides. and that no treatment process is in place to remove these radionuclides, from this waste, either at the Lowry Landfill, or at the Metro Treatment plant, before it is incorporated into the sludge. With this sludge being placed on thousands of acres of farmground owned by the Metro Wastewater Reclamation District, in eastern Arapahoe County, near Deer Trail, as well as other privately owned farmground in Washington and Weld counties, this proposal has many far reaching implications.

The distribution of any kind of hazadous waste containing plutonium, by any application, on land that is used to produce food, or where there may be widespread exposure to the people farming, and residents of the surrounding area and communities, is not acceptable.

I am opposing this proposal, and would appreciate being kept informed of the EPA's decision on this matter, as well as any further proposals on this issue. 608

c. PA €PP€RSON, McClflRY, ZORN and McClflRV

G€ORG€ fl. €PP€RSON (iwu - loss) 317 6NSIGN ST. • P.O. BOX 597 DONflLD F. McCLflRV FORT MORGflN. CO 80701 €DLUflRD 1. ZORN T€L€PHON6: (970) 867-5621 RNDR6LU F. McCLflRV FRX: (970) 867-3703

16 May 1997

Marc Herman > f-0 United States EPA Region VIII (8HWM-FR) 999 18th St., Suite 500 Denver, CO 80202

Re: North Kiowa Bijou Ground Water Management District/Lowry Landfill Superfund Waste Water Disposal

Dear Mr. Herman:

I am writing this letter on behalf of my client, North Kiowa Bijou Ground Water Manage- ment District, which was formed under the statutes of the State of Colorado, which has both the duty and responsibility to protect the quantity and quality of water within their district. The district is rather large and includes much of the Counties of Morgan. Adams, Arapahoe and Weld. For some unknown reason, no one has seen fit to contact the district for our input into this matter.

As of this date we do not have much detailed information, other than there is apparently a proposal for disposal of Lowry landfill waste water or other product; on land owned by Metrogro in an area south of Deer Trail and in the vicinity of Muddy Creek. The ground- waters underlying these areas, including Muddy Creek, Bijou Creek, etc. are under tbe jurisdiction of the North Kiowa Bijou Ground Water Management District and any possible contamination, deterioration of quality and quantity of waters in this basin is critical.

The North Kiowa Bijou Ground Water Management District area and the North Kiowa Bijou Basin has been declared by both the State Engineer's office and our courts to be a critical area.

At this juncture, the purpose of this letter is to communicate to you the: vital interest of the North Kiowa Bijou Ground Water Management District and any such proposal that would import foreign water or matter in an area that may affect our groundwater and drainage system. On behalf of the district I would request that we be informed more fully concerning 610

Page Two 16 May 1997

this matter, including but not limited to any engineering data available at this time. Our district and its board of directors would be glad to meet with any of the responsible parties or organizations involved in this project, with the hope that more information may avoid future difficulties and even possible litigation.

For your information the board of directors of the North Kiowa Bijou Ground Water Management District meet at my office at 317 Ensign Street, Fort Morgan, Colorado, on the first Wednesday of each month. If you are interested in arranging a meeting, we would appreciate your contacting me, however, I would advise that our present calendar would not allow a meeting prior to the July meeting, unless an emergency exists.

Yoursj^ery truly,..

DFM/by xc: Richard Price, President North Kiowa Bijou Ground Water Management District 6PP6RSON. McClflflV, ZORN and McClflflV

G€ORG6 fl. €PP€RSON cwos - 317 €NSIGN ST. • P.O. BOX 597 DONRID f. McCLflflV PORT MORGflN. CO 30701 €DUUflflD L. ZORN T€L€PHON€: (970) 867-5621 flNDfl€UJ f. McClflRY Htt: (970) 867-3703

23 June 1997

Joe Vranka Phil Hagaman Colorado Public Health & Colorado State Health Department Hazardous Waste Management WQCD-TF-B2 HMWMD-RP-B2 4300 Cherry Creek Drive South 4300 Cherry Creek Drive South Denver, CO 80222-1530 Denver, CO 80222-1530

Patti Schwader Marc Herman Water Quality Control Commission United States EPA 4300 Cherry Creek Drive South Region VIII (8HWM-FR) Denver, CO 8022201539 999 18*51., Suite 500 Denver, CO 80202

Re: North Kiowa Bijou Ground Water Management District/Lowry Landfill Superfund Waste Water Disposal

Ladies and Gentlemen:

On behalf of the North Kiowa Bijou Ground Water Management District, which is a political subdivision formed for ground water management under the statutes of the State of Colorado. I contacted you by letter of May 16, 1997, concerning the above matter and expressed the concern of the District as to the possible effect of any proposed dumping under the above project. Based upon the information presently furnished the District this project would impact upon the quality of water within their area and jurisdiction. To this date we have not received any reply from any of the above parties involved in this matter.

The District is becoming increasingly alarmed about this project and is particularly concerned in the total lack of any communication or attempt by anyone to contact them to get their input in this proposed project.

In 1971 and as part of the investigation made by the District of the groundwater conditions under their jurisdiction, they had a hydrogeologic study of the bedrock aquifers of their district prepared by Willard Owens & Associates. Included within that study were regulation recommendations which have been adopted and followed by the District regarding the protection and preservation of the quantity and quality of waters in their jurisdiction. One of these recommendations particularly apply to the above project and reads as follows: 612 Page Two 23 June 1997

"The surface disposal of all waste materials, including but not limited to municipal sewage sludge, all well water, feedlot waste, nuclear by-products, and chemical by- products, shall be done only in a manner approved by the Board of District. Such disposal shall be done in a manner to prevent pollution or contamination of the bedrock and alluvial aquifers. Such disposal areas shall be limited to non-water table areas of impermeable bedrock."

To my own personal knowledge, the jurisdiction and authority of the Ground Water Management District in this matter of protection of quality and quantity of waters under their jurisdiction have been tested, both in the Colorado courts and the Federal courts, who have unanimously upheld the jurisdiction and authority of the District Board in these matters.

The District Board has been informed that the above project includes use of surface area for dumping or the waste water disposal in Township 5 South, Range 58 West of the 6* P.M., which includes (although not limited to) Sections 16, 17,18, 20 and 21. Although this project is immediately adjacent to the boundaries of the District may also affect the ground waters of the District and be under the jurisdiction of the District Board, certainly the above sections are directly established by law, rules and regulations as subject to the jurisdiction of the North Kiowa Bijou Ground Water Management District Board.

Inasmuch as no one has seen fit, as of this date, to either contact or apply to the District Board for approval on the above project, although it certainly appears that the same would be subject to their approval and jurisdiction, the District Board has instructed me to advise each of you of their interest and claim of jurisdiction in this matter. It is sincerely hoped that this matter can be resolved short of the expense and delay of litigation regarding this entire matter. However, unless some contact is made, the District and its Board feel they may have no other alternative but to apply to the courts for relief. I would suggest that if any of you desire to make contact with the Board concerning this matter, to contact either me or the President of the Board, Richard Price, whose address is Post Office Box 130, Deer Trail, Colorado 80105.

Yours very truly,

Donald F. McClary

DFM/by xc: Richard Price, President North Kiowa Bijou Ground Water Management District SENT BY:Klnko's Copies ; 6-28-97 ; 16=08 ; WWW.KINKOS.COM- 13033126897;* I/ 3 613

Dr. John R. Meinhold P.O. Box 5271 Portsmouth NH 03802 (603)431-0513

THIS IS A FAX COVER SHEET.

TO: MBIT Herman, US EPA Region 8 999 18th St. Suite 500 Denver CO 80202

FAX* (303)312-6897

FROM: John R. Meinhold, OJX

THERE ARE 2 FACETS) INCLUDING THIS COVER PAGE.

DATE: June 28,1997 TIME:

IF THERE ARE PROBLEMS OR QUESTIONS, PLEASE CALL ME AT (603)664-7290,

MESSAGE:

Mr. Herman:

I am a board certified health care professional and a reserve officer in the US Public Health Service. The US Public Health Service comes under direct authority of the US Surgeon General. One of the major missions of the US Public Health Service is preventive mcdccinc.

I am completely outraged at the EPA's ongoing procedures to "clean up"Superfund sites via sewage treatment systems, and then spread or sold as "fertilizer" to the innocent and unknowledgeable citizens of our country. 1 am in opposition to the amendment to the Record of Decision at the Lowry landfill Superfiind Site. Professor Adrierme Anderson from the University of Colorado at Boulder has documentation showing the lx>wry Landfill Superfund Site has contamination from plutonium, dioxin, PCBs,fiind other man- made radionuclides (such as: americium, tritium, strontium, cerium, and cesium). Quite simply, these chemical and radionuclides are some of the most deadly, toxic, and carcinogenic compounds known to man. What ionpterm studies can you ciite and document to show there will be no detrimental effects to the land, air, water, wildlife and crops to support your "cleanup" procedures? What jongterm epidemiologies! studies can you cite or document to prove increased cancer rates, increased mortality rites, or other serious health effects will not occur? BY:Klnko's Copies ; 6-28-97 ; 16:09 ; WWW.KINKOS.CONH 13033126897;* 2/ 3

614

Page 2 Fax to: Marc Herman June 28,1997

Because of the magnitude of the potential health consequences involved, I am requesting an immediate answer in writing to my aforementioned questions. Tf you cannot provide me with the scientific and epidemiologicaj proof to show there will be no harm done to our health and environment, then I demand that you immediately stop this disgraceful environmental disaster in the state of Colorado and at all other Superfund locations nationwide.

John R. Meinhold, O.D. 615

Sundstrand Corporation

COHPORfflTE OFFICES • 4949 HARRISON AVENUE. P.O. BOX 7003 • ROCKFORO. lUJNOS 61125-7003 • PHONE (815) 226-6000 • TWX 910^91-4255 • THEX 25-7440

May 22, 1997

Mr. Marc E. Herman Remedial Project Manager U.S. Environmental Protection Agency Mail Code 8EPR-SR 999 18th Street, Suite 500 Denver, CO 80202

RE: Comments of Sundstrand Corporation on Proposed Second Explanation of Significant Differences ("BSD") to the Record of Decision for the Lowry Landfill Superfund Site

Dear Mr. Herman:

On behalf of Sundstrand Corporation, we submit the following comments regarding the proposed BSD for the Lowry Landfill ROD. We support the agency's proposed BSD. Our support is based upon a review of the BSD and communications regarding the same.

Very truly yours,

SUNDSTRAND CORPORATION

Robert J. Miller Director, Environmental Health & Safety

/bt g£ ~ cc: ToriHaines §§:!; -^ * 0 0 AT"

vo 10 617

May 14. 1997 Mare Herman 8FPR-SR Remedial Project Manager 999 1Bth Street, fituile 5OO Denver. Co 8O2O2-24OG Dear Mr. Herman. " . In response lo the proposed "Lowry LandRB Supeffund Site Second Explaination of SlgnJflaant DNTerenam lor Ihe Record of Decision*, we as community Duiriness members, landowners, and rural residents, request that me pobnc commomt period bo extended «O days from May 22. 1997. to end on July 22. 1997. so that we can review intormatlon provided to us in the libraries. Vva have not had sufTtciam time to get i to this InfotMMtUan and send our comments to you on this subject. ThwnH You,

p 618

May 14. 1997 Marc Herman HhPR-SR rtemediei Pn^ec* Manager 999 10th Street, Suite 600 . Co 80202-24G6

Dear Mr. Herman. : : ';•".'•;'••,.". ' • • . ..••'.• ' .- ' . "• >'••':?>''^H^• fn response to (fie proposed "Lowry Landfiff Superfund Site Second f-«pfaiinnlion of • >',.. Significant Differences for the Record of Decision'', we as community business . . ; ;;•;-• members, lanoowners, and rural residents, request that the publla comment period be :• - extended 60 days from May 22, 1997,10 end on July 22, 1997. so that we '&&' ~/y.^^

^ JUN-3B-'97 16:IB ID;D R C 0 5 Ttl_

619 2460 W. 26th Avenue • Suite 200B Denver, Colorado 80211-55(10 (303) 455-1 ODD • FAX (303) 480-6790 Regional Council of Governments Accessible on RTD Route 28 A partnership of local governments serving the region since 1955 June 30,1997

Mr. Marc Herman EPA Project Manager for the Lowry Superfund Site U.S. Environmental Protection Agency 999 18th Street, Suite 500 Denver. Colorado 80202

Dear Mr. Herman:

Re: Lowrv Landfill Superfund Site Publicly Owned Treatment Works Potion

The Denver Regional Council of Governments is the designated planning agency in the metropolitan area responsible for maintaining the regional Clean Water Plan as defined under section 208 of the Clean Water Act. The Clean Water Plan contains wastewater management strategies to protect water quality and meet beneficial uses assigned by the Colorado Water Quality Control Commission to receiving waters in the region. The plan also identifies clean-up of contaminated groundwater as a regional issue with a recommendation that this type of clean-up should be done on a timely basis.

The proposed Publicly Owned Treatment Works Option developed by the U.S. Environmental Protection Agency for the Lowry Landfill Superfund Site has been reviewed for consistency with the regional Clean Water Plan. The proposal is consistent with the Clean Water Plan and is protective of water quality. The 14.400 gallons of Lowry site groundwater to be potentially treated by the Metropolitan Wastewater Reclamation District will not have a measurable impact on effluent discharge quality. This option is appropriate and feasible and will allow clean-up of groundwater to begin at the site without delay.

Sincerely,

David A, Pampu Deputy Executive Director

c: Wellington Webb, Mayor, City & County of Denver, DRCOG Board Representative Joyce Foster, Councilwoman, City & County of Denver, DRCOG EJoard Representative Mike Dino, Administrative Assistant, City & County of Denver Bob L eGare CQuncilmember, City of Aurora DRCOG Board RaprosentatK/p Board Officers Executive Committee Margaret W. Carpenter. Chairman Polly Page, Chairman M. Michael Cooke Michelle Lawrence Polly Page. Vice Chairman Jan Schenck. Vice Chairman Paul D. Danish Dennis S. Reynolds Jan Schenck, Secretary-Treasurer Margaret W. Carpenter Candy C. Flga Ken Siler Roland E. Cole. Immediate Past Chairman Roland E. Cole Martin J. Flaum Wellington E. Webb Robert D, Farley, Executive Director 620

ffiichard thrice,

p. o. BOX 130

DEER TRAIL, COLORADO 80105 IV

May 11,1997

Marc Herman United States EPA Region Vm (8HWM-FR) 999 18* Street, Suite 500 Denver, CO 80202

Dear Mr. Herman:

I am writing to object to incorporating Lowry Landfill Superfund waste water into tine Metrogro sludge.

Land already owned by Metrogro east and south of Deer Trail drains norm into the Muddy Creek, also known as Deer Trail Creek. Muddy Creek has already had sludge-fertilized trash and. dirt wash into it from the six-inch rain in 1996 that washed out the road to the Metrogro site. We want you to be aware that mere ia 7 tnilfts of |ive water on the, Mllddv Creek and this is an important FKhBTK fiff the Ffflthill BflUJfeTi

The Muddy runs through our property and into our reservoir which holds 3000 acre feet of water and is 1 3V4 miles from Metrogro's norm property line. Our reservoir is stocked with fish and is home to pelicans, ducks, geese, and small herons and other water birds. There have been Blue Heron on occasion and it is a migration stop for Sandhill cranes. Since all of the run-off from Metrogro south of us runs into the Muddy and the reservoir, it has become the settling pond for fertilized sludge.

Water pumped from the chemically saturated sand below the Lowry Landfill Superftmd will have particles of all of the 177 chemicals, including plutonium, in it If this treated water is clean enough to put in sludge, then why can't it be used for household use?

Contamination from Superfund sludge blown by high winds and run-off will be felt by people hundreds of miles away. The Muddy Creek runs into the Bijou and on into the Platte River. Huge dust clouds are carried miles away from the shes, and die eastern plains are known for high winds.

The Foxhill Aquifer Basin runs from the Muddy Creek which is on the east border, south of Deer Trail 20 miles, West to Kiowa Creek and North to Greeley. The towns of Deer Trail and Byers have Foxhill water, as do hundreds of farms and ranches.

Sincerely,

P.O. Box 130 Deer Trail, CO 80105 cc: Water Quality Control Commission Colorado State Health Department Arapahoe County Commissioners Norm Kiowa Bijou Water District FROM : The Rader's PHONE NO. : +3616713 May. 18 1997 09:553PM P01 621 CLLEAN CITIZENS FOR LOWRY LANDFILL ENVIRONMENTAL ACTION NOW

Strut •Aurora, CO 80018 • (303) 364-2905 • FAX (303) 361-6713

May 18.1997

DELIVERED VIA FACSIMILE - (303) 3 J 2-6897

MarcE. Herman Remedial Project Manager Lenny Landfill Superfimd Site DSEPA. Region VI1J 999 18tb Street - Suite 500 Denver, Colorado 80202-2466

RE: Comment Regarding Lowiy Landfill Activities Due May 22,1997

•" - ' "*"-." .' . "* ; Dear Marc: • • . • ' -• ••'••'••' - •' • ••>•••'"•'•'•': ' "^'''•'.' ••••.'••"•""..:"• :^ftlll?>;* " • •.' • •• '•"'• • ' "•••' ' •;" • •,/; ?W^':.:-:'-.-•' During our telephone conversations during the week of May 12,1997, we discussed a number oT new issues such as the Aurora Waste Water Treatment plant that wfll impact th« Lowry LandfiD dean up plan.

It is my understanding that because of these new issues there will need to be an extended comment period. CLLEAN will require more time to review the new information when His released and then we win submit our comment. Please advise us of the new comment deadline.

Respectfully nibmitted.

Bonnie L. Rader Director, Citizens for Lowry Landfill Environmental Action Now (CLLEAN) FROM : The Rader's - PHONE NO. : +3616713 Jun. 30 1997 85:55RM P02_ 622 CLLEAN CITIZENS FOR LOWRY LANDFILL ENVIRONMENTAL ACTION NOW

71 Algonquatn Strtet •Aurora, CO 800J8 • (303) 364-2905 • FAX (303) 361*67J3

June 30,1997

Marc E. Herman Remedial Project Manager, Lowry Landfill Superfund Site United States Environmental Protection Agency, Region VTII 999 18th Street, Suite 500 Denver, Colorado 80202-2466

RE: Comments On Discharge Of Treatment Plant Effluent To Metro Wastewater Reclamation District POTW, Treatment and Disposal of Buried Waste

Dear Marc:

The intent of the Federal Superfund program for cleaning up toxic waste sites is the protection of public health and the environment. This does not mean just the public health acid environment of the community that exists near the facility, it includes those communities in to which the wastes may be transported. The members of CLLEAN want to re-emphasize the importance of a cleanup at the Lowry Landfill Superfund Site that does not adversely impact another neighborhood and one that will not further deplete our natural resources (water) or adversely impact our air quality.

CLLEAN remains concerned that any cleanup of the Lowry Landfill Superfund site should be one that utilizes technologies that will efficiently and permanently clean the site. CLLEAN is adamant that the cleanup of the site should not adversely impact another community in the name of saving moneys. The reluctance by the Responsible Parties, the City of Denver and Waste Management to utilize (or even test on site) more aggressive and permanent remedial cleanup technologies is discouraging to CLLEAN.

It is frustrating and next to impossible to understand the reason that the HPA either can not, or will not, support the citizen's request for an on-site cleanup that, in the long term, is cost effective and permanent. Under the current scenario, the operator of the site will be paid to "baby-sit" the site for years, there is no guarantee that the problems will not get worse, and repeated costs are almost inevitable. Environmentally, the risks and future cleanup costs are transferred from one community to another, and to future generations. Lower costs when selecting cleanup options is not always the most protective or efficient, FROM : The Rader's PHONE NO. : +3616713 Jan. 30 1997 05:56fiM P03 623

Marc Herman June 30, 1997 Page Two

Attached you will find the comments from CLLEAN and their Technical Advisor regarding the POTW and the treatment and disposal of the buried wastes.

Respectfully Submitted,

Bonnie L. Rader Director, CLLEAN FROM : The Rader's PHONE NO. : +3616713 Jun. 30 1997 B5:S9SN P07 624

COMMENTS ON DISCHARGE OF TREATMENT PLANT EFFLUENT TO METRO WASTEWATER RECLAMATION DISTRICT POTW

RESPONSE FOR EXPLANATION OF SIGNIFICANT DIFFERENCES FOR LOWRY LANDFILL RECORD OF DECISION For June 30, 1997 Comment Period

Based on a data from the document entitled "Evaluation of the POTW Treatment Option" by Parsons Engineering dated April 23, 1996.

TECHNICAL COMMENTS

CERCLA CRITERIA

The CERCLA process uses a variety of criteria to judge the merits of various alternatives for a proposed remediation. Some of the arguments used in this document are very questionable relative to their bearing on the selection. For instance, stating that two trucks of waste being hauled (Alternatives 2B and 2C) from the site is a detriment based on the criteria of 'Overall Protection of Health and Environment' is uot a valid weighting factor. There is a tremendous amount of truck traffic around this site and two more trucks in a year has to be considered inconsequential.

The criteria were close enough for all the alternatives to be judged equal on the basis of arguments presented in this document. Additional arguments will be made below that question the long term effectiveness of the POTW option, the treatment capability of the POTW option, the cost factors, community acceptance and reduction of mobility, toxicity, and volume criteria. The comments will be presented in a general context, not related to . specific statements in the document which is the common format for comments on this type of document.

The analysis of alternatives implies that the treatments in the alternatives are similar. This is not the case. The POTW alternative does not treat heavy metals. They are simply diluted in the mass of sludge. This is not treatment. The costs of the POTW alternative should not be directly compared to the costs of the options labeled 2 A, 2B and 2C. These alternatives truly treat the inorganic heavy metals in that they are removed from contact with the environment. That cannot be said about the POTW option.

In fact, the POTW treatment option may ultimately be detrimental to the environment. As the sludge is landfarmed, the organic components and necessary trace metals are used in the biocycle. The heavy metals and salts that are a concern at Lowry Landfill will simple accumulate in the soil. At some point they may read) levels that will be detrimental to the punwi= Kin • +^£16713 ^n. 30 1997 05:59RM P08 FROM : The Rader's PHONE NO. - 625

land. There are documented cases where land applied sludges have caused unacceptable metal build up in the soil over time.

In CERCLA terms, the reduction of TMV is judged by us to be better for Alternative 2. The POTW option spreads the materials treated at Metro over a large volume of sludge and discharge water. The volume of waste is thus increased and the mobility increases for inorganic materials sent to the POTW. Alternative 2 reduces inorganic waste volumes and reduces mobility by placing them in a secure landfill. This criteria favors Alternative 2.

The community acceptance for Alternatives 2B and 2C were judged negatively based on plume presence. There is no reason to have a plume. The steam effluent should be passed through a heat exchanger to recover the heat and pre-heat the incoming stream. The example of this type of equipment used in the document, Appendix C, aqua-chem evaporative cryslallizer, even had this feature. They indicate in their literature that 99+% of the water could be recovered. This should be struck as a negative community acceptance item for Alternatives 2B and 2C.

The factor of extra trucks in the vicinity as a negative factor for options in Alternate 2 (with the exception of Alternative 2A) should also be struck. This is based on the fact that the operation of the Metro facility also entails a large amount of truck traffic. There is merely the displacement of traffic to another area, not the absence of traffic as this document tends to infer. Similar treatment chemical deliveries and sludge removal operations occur at Metro and would be increased proportionately for treatment of this stream in the area of the POTW.

One issue of particular importance to the community is the removal of water from their aquifer. This is a negative item for community acceptance of Alternative 1 and is not addressed in the document. It would appear that the authors took it upon themselves to decide what was significant to community acceptance without actually asking the community.

Costs within engineering uncertainties are judged to be equal for the alternatives. Likewise, the short term effectiveness and compliance with ARARS are judged to be equal for Alternatives 1 and 2. Implementabilily will be slightly higher for the options in Alternative 2. However, the equipment is certainly established technology and is no more complex than the treatment equipment currently installed and maintained at the Metro Treatment complex.

The long term effectiveness of the Metro POTW itself can hardly be considered an issue. However, there is question relative to the site effluent and the long term effectiveness of the POTW alternative. The combination of remedies to be installed includes slurry walls and an effective cap. This treatment will effectively eliminate the majority of ground and surface water recharge to the site. The amount of contaminants will not diminish significantly and the net effect could likely be a significant increase in contamination concentration levels in the effluent. It is very likely that as the overall effluent stream PHONE NO. : +3616713 Jun. 30 1997 05:59flM P09 FROM : The Rader'S 626

drops it will be mainly due to a. drop in percentage of the water component. This could easily create an effluent stream from T/owry thai is over the influent limits for the discharge to the POTW in inorganics. The site treatment plant would be unable to address this situation and equipment simitar to what is available in Alternative 2 may very well have to be added in the future if Alternative 1 is chosen. On this basis, Alternative 2 should be judged as more effective for long term effectiveness.

PROCESS COMMENTS

Reverse Osmosis - It is common in this type of scenario to install a second stage RO unit to retreat the brine discharge from the first unit. The efficiency is not as good as the first pass, however, more water can be recovered. A second stage RO would typically recover 50% of the primary brine discharge. Thus a 10 gpm stream with 75% primary recovery would produce 7.5 gpm of clean water and the 2.5 gpm secondary treatment might yield another 1.25 gpm for a total recovery of 8.75 gpm. Numbers from water supply district personnel indicate that a 75%. recovery of supply water is considered good. If we can recharge 87.5% of the treated-water with a primary/secondary RO system, along with the condcnsate from an evaporative treatment of the 1.25 gpm brine stream, there should be no need to supply augmentation water. Tliis would remove this line item from the cost and have better community acceptance. Also, the size and cost of the evaporative unit under Alternative 23 would decrease significantly. This scenario should improve the overall standing of Alternative 2B.

Evaporator - As stated earlier under community acceptance, the vapor stream from the evaporator in Alternative 2B and 2C should be condensed and recovered. The condensing apparatus can be used as a preheater for the incoming treatment stream as a cost savings.

WETLANDS MITIGATION

The on-site recovery of the water from the treatment process could be used to augment the wetlands program. A recharge system to groundwater would also be in place so that the water could be diverted either way as necessary. This would allow for more flexibility in the wetlands design and maintenance, and increase the likelihood of a successful implementation of the wetlands mitigation project.

OVERALL CONCLUSION

On a technical basis, the above information indicates that Alternative 2R would be tlie most acceptable choice for treatment of the effluent water at the Lowry Superfund Site. Furthermore, community acceptance is judged to be higher for this alternative rather than the transfer of effluent to the Metro POTW. FRO. : The Rader's PHONE NO. : +3616713 Jun. 30 1887 *:**« P10 627

Further, the cost of Alternative 2 options could be reduced even further if, as contemplated, the State relaxes the recharge standards to allow some of the non- hazardous, native salts to be returned to the aquifer with the effluent water. This would greatly decrease the cost and complexity of the inorganic treatment portion of the scheme and improve their standing from the cost, standpoint.

TREATMENT OF WASTE PIT MATERIAL FORMER TIRE PILE AREA

The off-gas from the treatment of the tire pile pits will have to be captured and treated. Presumably this could be accomplished with a carbon absorber or by sending it through the landfill gas flare. Of specific concern will be the contents of the off gas and the method of treatment.

While the burning of the gas in the flare seems to be a logical and economical choice, the issue of hazardous waste treatment will arise with this method. These implications wilJ also have to be addressed in addition to the technical issues. Cllean will be very interested in the specifics of these issues. FROM : The Rader's PHONE NO. : +3S16713 Jun. 30 1997 05:!56fiM P04 628

Summary On a. technical bases Alternative 2B with secondary treatment suggested by CLUiA^Lis the most acceptable for treatment of the effluent water at the Lowery site. Furthermore^ Community acceptance is highest for this treatment alternative rather than the transfer of effluent to the Metro POTW.

• CLLEAN's concerns regarding the POTW is not whether it will work as currently proposed by Denver (City) and Waste Management (WML) The issue is - does this proposal offer a clean up of the contaminated water, one that will not adversely impact our natural resources or citizens living in other neighborhoods. Our position is that the proposal, without our suggested secondary treatment, is not a clean up. Rather it is the disbursement of the contaminants to other neighborhoods. Metro Waste Water should not pay their share of the clean up with "in kind" through use of the POTW, they should pay for the secondary treatment requested by CLLEAN The solution to pollution is not dilution.

• Under the Super Fund law, the legal requirement is that any amount of contaminated/treated water that is pumped off-site through the POTW must be replaced with a new source of clean water. The only source of clean water available to us is the water that comes from our aquifers which are currently being depleted at an alarming rate. WM1 and the City state that iit will only take pumping a maximum of 10 gallons per minute (gpm) of "clean" water back into the site. In reality, 10 pom equals 5.2 million gallons of water each and every year. Those citizens who utilize water from domestic wells consider this a tremendous amount of water to be taken from our supply.

• The city and WM1 are required, by law, to construct the wetlands that were destroyed during the time that chemicals were disposed at the Lowry Landfill. This wetlands: will require a water source to keep it alive. CTJ J3AN has recommended that Alternative 2B, with our • . suggested addition of a secondary process, will provide an opportunity to clean the site while preserving the existing water sources in the area. Although the treated water would not replenish the deeper aquifers, new water sources would not need to be tapped to support the Wetlands.

• Alternative 1 states that the POTW is removing inorganics. This is incorrect. The inorganics are either p««ed through the plant and in to the Platt River, or they art' dispersed into the sludge. The sludge, containing metals and bacteria, is then applied to the farm land. We concur with the citizens from the Eastern Plains who are complaining that they do not want the contaminated sludge brought into their neighborhoods. If the sludge is land applied the heavy metals will slowly accumulate (as e.g. selenium in the California irrigation water reservoirs). The organic portion of the sludge is used by bio-growth, however, the heavy . metaJs would just accumulate and be in a form that is susceptible to exposure to the public. Passing the metals through the plant does not specifically "fix" them into an inert form. FROM : The Rader'S PHONE NO. : +3616713. Jan. 30 1997 05:S7«1 P05

Treatment system costs; CLLEAN's position is that Alternative 2B including secondary process will cost more at the start up but, it will actually save moneys over the life of the process/clean-up. Long term monitoring needed for the stated processes will escalate the costs of the clean-up.

CLLEAN does not support the claim made by tne citizens from the Eastern Plains that the crops will be contaminated by plutonium in the resultant sludge from the POTW. The evidence just does not exist. CLLEAN continues to be very vigilant regarding the piutonium and/or radionuclides issue.

supports the Oil Chemical and Atomic Workers in their concerns that chemicals will travel through th&POTW. The on site treatment systems, as suggested by WMI and the City, will only treat the chemicals to minimal standards thus sending chemical residues and heavy metals to the POTW. Further, as the contaminated waters are treated, the amount of water should decrease, the concentration of chemicals will increase. At that point in time, the POTW can not legally receive the liquids. FROM : TKe Rader's PHONE NO. : +3616713 Jan. 30 1997 05:57flM P06 630

TREATMENT OF WASTE PIT MATERIAL FORMER TIRE PILE AREA

It is disconcerting to note that the models that have been utilized to determine the treatment of the chemical contamination at the 1 -owry Landfill Superiund site describe a normal household garbage landfill. These models are erroneous and can not possibly reflect the very real problems that exist at the Lowry Landfill Superfund site. Please revise the models to reflect the true picture before any final decisions for cleanup are finalized.

It is not yet clear how the old tire pile pits will be opened and the on site controlled aeration will be accomplished. It is of the upper most importance lo CLLEAN that neither of these activities move forward with out the prior construction of a bubble over the pits as they are opened to prevent the noxious gases from escaping into our atmosphere. The plan must include safety measures to protect the on site workers.

AH gases that escape in to the bubble should be piped to the flare for destruction.

It is important to examine the possibility of in-situ bacterial treatment for the toxins. Considering the fact that the flare is removing the methane from the mass, and this encourages the "bugs" to multiply, this is an important alternative to consider as it would allow treatment without the exposure of the chemicals gases in to the atmosphere.

CLLEAN supports the cleanup concept that is currently in effect at the Rocky Mountain Arsenal called the Pica Child. It is our opinion that private industry should be held to the same standards of cleanup as the military. 631

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STSASBDKG COMMODITY C00ICIL, IIC.

P.O.Box 181, Strasburg, CO 80136

May 16, 1997

Mr. Marc Herman Remedial Project Manager 8 EPR-FRS 999 18 St., Suite 500 Denver, CO 80202

Dear Sir:

The Strasburg Community Council is an all-volunteer group serving the unincorporated community within the boundaries of the Strasburg School District.

At our monthly meeting May 15,' 1997, a presentation was made by Ms. Mary Olmer regarding Lowry Landfill Superfund Site Second Explanation of Significant Differences for the Record of Decision.

The seven voting members of the Council present decided that we should state our opposition to this plan before the present deadline for public comment expires on May 22, 1997.

It would be helpful if the deadline for public comment could be extended so that residents in our area could become more knowledgeable about the issues involved and about any proposed methods of dealing with any problems that might result.

Thank you for considering our concerns.

Very truly yours,

STRASBURG COMMUNITY COUUCIL, IJC.

^cr> r_ • Tammie Scott, President ~S. -'-

co§ 5 06/28/1997 10:03 6038752288 ALTON VIDEO PACE 01 633

June 27, 1997

Mr. Marc Herman c/o Attorney Jamie Goldfarb US EPA - Region 8 999 18th Street - Suite 500 Denver, Colorado 80202 Dear Mr. Herman: We in New Hampshire stand with those in Colorado who oppose your plan to pump water contaminated with radioactivity and hazardous wastes from the Lowry landfill Superfund Site into the Denver-Metro sewer system, with the toxlo residuals to be sold to an unsuspecting public as "bagged fertilizer" or spread on America's farmland for introduction into the food chain. We always knew the landspreading of ssware sludge was a monumental scam pinrpotnted on the American people by the EPA and the waste companies to dispose of toxic industrial wastes on the cheap, But now the EPA is carrying this fraud to new heights. Once these radioactive and hazardous wastes enter the sewer plants, they become the "property" of the taxpayers who own the wastewater treatment plants and are ultimately responsible for the financial consequences of dumping these toxLo sludges on land uued to grow cattle feed and food crops.

And the industries who dumped these poisons on the land and created these Superfund Sites are off the hook I The "Environmental Protection Agency" ? Who is going to protect our air, land and water from YOU ?? Very truly yours,

Charles and Helano Shields Box 1133, Alton, NH 03809 634

Coors Brewing Company Golden, Colorado 80401-1295

May 20, 1997

Mr. Marc Herman Remedial Project Manager U.S. Environmental Protection Agency Mail Code 8EPR-SR 999 - 18th Street, Suite 500 Denver, CO 80202

Subject: Lowry Landfill - Second Explanation of Significant Differences (ESD) for the Lowry Landfill Superfund Site Record of Decision

Dear Mr. Herman:

On behalf of Coors Brewing Company (Coors), we are submitting comments in support of the proposed Second ESD to the Lowry Landfill Record of Decision (ROD). Coors fully agrees with EPA's decision to consider minor modifications to their previously selected remedy for the waste materials beneath the former tire pile area (FTPA) and the approach to the treatment of contaminated groundwater collected as part of remediation activities. We concur with EPA's conclusions presented in the Second ESD that the proposed modifications do not fundamentally alter the site-wide remedy and that the sfta- wide remedy, as modified by the proposal, will remain protective of human health and the environment Coors applauds the EPA's willingness to consider the results of the ongoing data collection efforts and to modify and adapt the overall remedy to be consistent with the current understanding of Site conditions. Specific comments regarding the two proposals presented in the ESD are presented below:

Former Tire Pile Area

Coors supports EPA's proposal to treat the materials present beneath the Former Tire Pile Area (FTPA) on-site rather than shipping these materials off-site for treatment. Treatment on-site will not only reduce the potential risks associated with possible accidents associated with off-site transportation but will also allow Lowry wastes to be treated on-site and remain on-site consistent with EPA guidance. In addition, on-site treatment may potentially be more cost-effective while still providing an equivalent level of protection to human health and the environment

Our understanding of the intent of EPA's Record of Decision regarding the excavation and treatment of waste pit materials from the (FTPA) was that highly concentrated "RCRA hazardous" wastes would be excavated, treated on-site and shipped off-site to an RCRA facility for further treatment as necessary and final disposal.

Review of the data obtained as part of the Site investigations performed during the remedial design effort indicates that highly concentrated liquids were only encountered in one of the three test pit excavations and only groundwater was encountered in the other two test pits. Tests performed as part of the excavation and handling of the excavated materials indicated that the excavated soils and sludges did not contain free-draining 635 Mr. Marc Herman U.S. Environmental Protection Agency May 20,1997 Page 2 liquids. Drummed liquids were apparently encountered in two of the three test pits; however, these drums reportedly lacked integrity and none of the drummed materials could be recovered intact Review of the analytical laboratory test results obtained during the Remedial Design investigations indicates that with the exception of the levels of tetrachlorethylene (PCE), trichloroethylene (TCE) and a condition of ignitability, the soils/sludges excavated from the test pits would not be considered RCRA hazardous wastes. Furthermore, it is our understanding that on-site treatment for removal of PCE and TCE would be required regardless of whether or not these materials are ultimately treated and disposed on-site or off-site. Numerous readily implementable, simple and cost-effective technologies exist for on-site removal and treatment of PCE, TCE and other volatile organic compounds (VOCs).

Once the PCE and TCE levels and the ignitability conditions are reduced through on-site treatment, it is our understanding that these materials would no longer be considered RCRA characteristic hazardous wastes. Clearly, on-site treatment of PCE and TCE, which is necessary regardless of the ultimate disposition of these materials, obviates the need for shipment of these materials for off-site treatment and disposal as hazardous wastes. We applaud EPA's reconsideration of their prior decision in light of the results obtained during the Remedial Design effort

Discharge of Treated Groundwater to the POTW

Coors also supports EPA's decision to allow treated groundwater to be discharged to the publicly owned treatment works (POTW) for further treatment and ultimate discharge. During the preparation of the Remedial Investigation/Feasibility Study (RI/FS), the option of discharging collected waters to the POTW, either with or without pretreatment was considered. This alternative was heavily favored by many of the RI/FS participants due to the inherently difficult and costly nature of treating relative low volumes (e.g., approximately 10 gallons per minute or less) at a remote facility. Ultimately, an on-site treatment system was selected as the representative process option fur further evaluation in the RI/FS process due in large part to the distance of the Site from the nearest sewer line connection. Subsequent to the completion of the RI/FS, it is our understanding that a sewer line inceptor has been extended to within one-half mile of the Site effectively removing this constraint

Based on the data obtained as part of the ongoing operation of the existing groundwater barrier and treatment plant and the surface water removal action (SWRA), it is our understanding that the principal chemicals in the Site groundwater at levels above the remediation standards are VOCs, phenolic compounds, and pesticides (collectively referred to as organic compounds) and trace metals. All of these chemicals are readily treated with the technologies typically present at most POTW facilities. Furthermore, it is our understanding the EPA's current proposal will include on-site pretreatment to reduce the levels of VOCs. Such pretreatment may also reduce the concentrations of phenolics and pesticides. As a result, the POTW is primarily being relied on to provide final treatment of the organic constituents and treatment for metals reduction. Both the ROD and the ESD proposal include discharge of the treated water to the South Platte River drainage system. EPA's proposal to have the POTW provide metals reduction treatment and final treatment for organic compounds provides a more effective and efficient 636 Mr. Marc Herman. U.S. Environmental Protection Agency May 20, 1997 Page 3 method for treating the Site groundwater than that envisioned by the ROD while still being protective of human health and the environment

Finally, by allowing for the discharge of the pretreated water to the F'OTW and final treatment of this water by the POTW, EPA is allowing the City of Aurora and the Metro Wastewater Reclamation District (METRO) the opportunity to provide services in lieu of monetary contributions to meet their respective responsibilities for clean up at the Lowry Landfill. Such an approach provides additional benefits to the public who reside within these jurisdictions who might otherwise have to pay increased charges to meet these entities' responsibilities for clean up at the Site.

Conclusion

Based on the additional information developed as part of the ongoing remediation activities at the Site, we support EPA's proposed revisions to the Site-wide remedy as presented in the Second ESD. We concur with EPA's assessment that the Site-wide remedy with the proposed modifications remains protective of human health and the environment, complies with applicable, relevant and appropriate requirements and is cost-effective. We further support EPA's selection of permanent solutions utilizing orv srte technologies in contrast to off-site treatment and the use of alternative treatment technologies that allow the Lowry Landfill remediation effort to be performed in both a protective and cost-effective manner with the least impact possible to citizens of the area. .

Sincerely,

Scott B. Smith Coors Brewing Company Director, EH&S Policy Public Affairs Division

SBS/stoC:\DATA\WINWORD\FORMS\LTRFORM.DOC pc: Joe Vranka - CDPHE-HMWMD 637

May 20, 1997

Mr. Marc E. Herman §§ ~- =^ Remedial Project Manager ^ ~j cp U.S. Environmental Protection Agency S -— ' — Mail Code 8EPR-SR "° 999 18th Street, Suite 500 Denver, Colorado 80202

Subject: Lowry Landfill - Second Explanation of Significant Differences (ESD) for the Lowry Landfill Superfund Site Record of Decision

Dear Mr. Herman:

On behalf of the City and County of Denver, Waste Management of Colorado, Inc. and Chemical Waste Management, hie., and their settling defendants (collectively Respondents), the following are comments regarding the March 17, 1997 proposed ESD to the Lowry Landfill Record of Decision (ROD).

We commend Region VIII for considering the new information developed during the remedial design process and support the ESD. Two ROD changes are proposed in the ESD to modify specific aspects of the Lowry Site remedy. The first proposed change addresses the treatment and disposal of contaminated materials from the former tire pile area. The ROD issued in 1994 stated that these materials would be excavated and characterized for treatment and disposal offsite; however, recent data from the treatability test indicate that onsite treatment can meet RCRA requirements for onsite disposal. We believe that onsite treatment and disposal of these wastes is in the public interest, particularlyto people residing in the vicinity of the Site since in- site management will significantly reduce the risks associated with trucking amd hauling the contaminated material to offsite facilities. Essentially, Lowry waste will be contained safely at the Lowry site.

The second proposed change addresses collection and treatment of groundwater from the existing north boundary barrier wall/collection system and proposed north toe extraction system. The ROD stated that the groundwater would be collected from new and existing collection systems and barrier walls, and a new onsite treatment plant would be designed and constructed unless it could be demonstrated through pilot-testing that the existing plant could be upgraded to effectively treat groundwater from the toe of the landfill. The proposed change to the ROD would involve pretreatment of the groundwater onsite in the existing water treatment plant to meet publicly-owned treatment works (POTW) pre-treatment permit standards, followed by offsite treatment at the POTW.

During the remedial investigation/feasibility study for shallow groundwater and subsurface liquids and deep groundwater, Harding Lawson Associates evaluated the use of a POTW for 638 treatment of site waters. This option was not carried through to the recommended remedy due to the extreme distance to the nearest POTW line and Metro's unwillingness at that time to accept Site waters. Since that time, treatment of CERCLA wastes at POTW's has become very common around the country.

On April 23, 1996, the Respondents submitted a Draft Evaluation of the POTW Treatment Option to the EPA/CDPHE in conformance with the EPA Guidance Manual - CERCLA Site Discharges to POTWs (EPA, 1990). In this document, the Respondents discussed the changed conditions which led to the evaluation of the POTW option, the benefits of offsite treatment of Site waters at a POTW, the identification and characterization of Site waters, and the ability of Metro to effectively and safely treat Site waters and Metro's permit requirements. Results of this evaluation were presented to the public at a Technical Advisory Group meeting held on May 16, 1996. After several rounds of responses by the Respondents to EPA/CDPHE comments, the agencies stated on September 23, 1996 that they had sufficient information to evaluate the POTW option.

Conclusions of this evaluation are as follows:

Changed conditions at the Site include: the extension of a sewer line by the City of Aurora to within one-half mile of the Site, Metro's agreement to accept Site waters for final treatment and Aurora's agreement to transport Site waters through its lines to Metro's lines.

Benefits of offsite treatment at a POTW included: the reduction of truck traffic and increased road hazards associated with transport of chemicals required for onsite treatment and transport of treatment wastes for offsite disposal, the elimination of the process to evaporate treatment brines and the associated atmospheric discharge, the reduction in energy usage, and the reduction of the potential for mechanical failures or upsets of treatment systems because of the greater reliability of a POTW as compared to an onsite treatment system.

Site waters requiring treatment included approximately 8 gallons/minute from the existing north boundary system and 2 gallons/minute from the proposed north toe groundwater extraction system. The report summarized historical and estimated total influent water quality. The report determined that the influent waters were not RCRA hazardous. Since the evaluation was prepared, the Respondents have collected four additional quarters of groundwater data, which have confirmed the previous analyses.

Activated sludge treatment processes such as that used at Metro was shown to be effective in removing most Site organic constituents.

Metro's permit requirements for discharge to its system would probably require pre- treatment for several volatile organic compounds. This pre-treatment can be achieved by using the existing Site water treatment plant processes. 639

The POTW option provides the most protection to the environment and dov/nstream residents. In particular, during the evaluation process which led to recommendation of the POTW option, numerous on-site treatment/reinjection alternatives were considered. All of these necessitated some form of mechanical evaporation which is technically complex, and requires significant operation and maintenance risk. The potential for system failure, which would also result hi extended periods of downtime, is a real and major concern. Mechanical evaporation operations would also produce relatively large volumes of brine waste that would require offsite transport and disposal. Onsite treatment would require use of large volumes of acids and other chemicals with their inherent safety risks. The POTW option offers a simple, straightforward, reliable and effective method of treatment, without the downside risks imposed by the alternative treatment/reinjection options.

Lowry waters that will be transported to the POTW will not be hazardous wastes. Literally thousands of samples have been taken of the Lowry groundwater and analyzed for hundreds of organic, inorganic and radionuclide compounds. The Lowry effluent contains significantly lower levels of many types of industrial contaminants than waste streams routinely handled by Metro. In any event, waters from Lowry must meet POTW pre-treatment standards. Metro will issue a discharge permit which will include pollutant limitations to ensure that the Site effluent will not compromise the POTW's ability to: a) meet requirements for Colorado Discharge Permit System (CDPS)/National Pollutant Discharge Elimination System (NPDES) discharge permit; b) comply with state water quality standards; c) achieve risk-based effluent concentration limits for pollutants not regulated by water quality standards; d) maintain clean sludge levels of pollutants in biosolids; e) prevent interference with POTW treatment processes; f) prevent releases of significant quantities of hazardous air pollutants; and g) protect workers from adverse health arid safety effects. These issues are discussed in more detail in the attached letter from Metro to EPA dated September 19, 1996. The limitations included in the discharge permit issued by Metro will be enforceable under Metro's Pretreatment/Industrial Waste Control Program. Metro has the authority to enforce the Clean Water Act and ensure that Lowry effluent meets its pre-treatment permit requirements.

Metro discharge standards will also protect workers from adverse health and safety effects that may be present in the sewer systems in the form of flammable, explosive and/or toxic gases. Based on the Guidance To Protect POTW Workers From Toxic and Reactive Gases and Vapois (EPA, 1992) Metro developed preliminary screening levels for Site pollutants. The guidelines provide air contaminant levels above which the "average worker" should not be exposed. Whe:re flammability/explosivity is the concern, screening levels were developed based on the explosivity of a particular compound. The screening level approach uses conservative assumptions that are examined during the permit process. For example, Metro's preliminary discharge permit limitations assume that Site waters are the only wastewater in the line at the point of connection to the sewer system. Screening levels also assume that the sewer line atmosphere will contain a certain percentage of each pollutant based on its ability to evaporate. Air movement in the system may cause pollutants to be swept out of the system, so that concentrations are lower than screening levels. If no additional information is available, final 640 screening levels will be used to establish Site discharge permit limitations. In the case where a pollutant is regulated by more than one concern (e.g., health and safety and water quality standards), Metro will apply the most stringent of the limits identified during the limits development process. The discharge permit will be revised as necessary based on changing conditions.

The POTW (in this case, Metro) has a capacity to treat 185 million gallons of water per day and has efficiently and safely met Colorado Discharge Permit System (CDPS) standards. Over the past five years, Metro has had only one exceedance of any of its effluent limits. This was an exceedance of the chlorine concentration limit caused by a temporary failure of the dechlorination system. No exceedances of permit limits have been experienced over this time frame related to the treatment of industrial wastewaters or other pollutants.

The proposed monitoring program for Site effluent to Metro includes sampling an initial batch for all monitored parameters . The effluent will then be monitored continuously for all monitored parameters in the first three consecutive days of discharge. Assuming these compounds are in compliance, the monthly and quarterly monitoring requirements and frequencies will be reevaluated after the first year, and will then be adjusted accordingly. Sampling requirements will be reevaluated during the five year review process.

Twenty-four hour flow composite samples will be collected for all but two monitored parameters. Cyanide and volatile organics will be grab samples per method guidance. The lower explosive limit and discharge volume will also be monitored.

The pre-treatment permit will require a contingency plan to prevent the accidental discharge of prohibited material and other substances to the POTW.

Metro initially established pollutant limits for all compounds listed by EPA as chemicals of concern for Site groundwater. Metro then evaluated the Lowry groundwater chemical database to determine whether compounds were ever detected above proposed limits and the detection frequency of these compounds. Metro used the following criteria to determine monitoring requirements and the inclusion of specific pollutant limits in the permit:

a) Samples above proposed limit; detected in 10% Limit exists Monthly or more samples

b) Samples above proposed limit; detected in less Limit exists Quarterly than 10% of samples

c) Samples above proposed limit; values not Limit exists Annual confirmed

d) Samples below proposed limit; detected in 70- No limit Monthly 100% of samples exists 641

e) Samples below proposed limit; detected in 40- No limit Quarterly 70% of samples exists f) Samples below proposed limit; detected in 10- No limit .Annual 40% of samples exists g) Samples below proposed limit; detected in less No limit None than 10% of samples exists

On April 15,1997, Metro's Board of Directors voted overwhelmingly to reaffirm Metro's intent to treat Site waters as discussed in the artahced letter dated April 23, 1997.

The proposal to treat Lowry effluent at a POTW is a common option considered to treat waste streams from both CERCLA and industrial waste sites. Currently, there are 83 permitted industrial dischargers to the Metro system alone, including electroplating shops, metal finishing and paint stripping facilities, and groundwater remediation systems.

We offer additional comment in response to a question/concern raised during the public meeting on the BSD regarding the potential presence of plutonium (Pu) in Site waters released to the POTW. In addition to the risk assessments already performed by EPA, a recent thorough examination of the Site groundwater quality database was conducted. Wells that are representative of groundwaters that will be extracted from the Site and that had Pu data, included MPZ-1 located near the existing treatment plant, and GW-111 and GW-112 located near the north toe extraction system. In all cases, Pu 239/240, which are the most prevalent Pu isotopes, were never detected. Detection limits were 0.06, 0.07, and 0.1 pico Curies per liter ( pCi/L) for MPZ-1, GW-111 and GW-112. respectively. In comparison, the cleanup standard listed in the ROD for both surface water and groundwater is 15 pCi/L. Potentially as relevant, the Colorado Water Quality Control Commission recently adopted a 0.15 pCi/L standard for all State waters. This standard would be applicable for total discharge from Metro. Because the reported detection limits are less than even this more stringent standard, discherge of Lowry waters to a POTW would not cause Metro to exceed this regulatory criteria. In addition, Pu 238 was not detected at MPZ-1 at a detection limit of 0.06 pCi/L. Pu 241 was not detected at GW-111 and GW-112.

In light of the new information from recent design investigations and proposed changes to the ROD, the Respondents believe that the remedy as proposed to be modified in the ESD is protective of human health and the environment and complies with applicable or relevant and appropriate requirements. In conclusion, we commend EPA and CDPHE for considering the options for cost effective treatment technologies available at this time, reading that technology has progressed in the last few years. We strongly support the two changes to the ROD in the recent ESD. 642

If we can be of assistance in addressing any technical issues regarding these proposals, please do not hesitate to call either of us.

Yours truly,

LorrT. Taga^^P.G. Dennis D. Bollmann, P.O. Waste Management of Colorado, Inc. Environmental Services Chemical Waste Management, Inc. City and County of Denver 3900 South Wadsworth Blvd., Suite 800 216 16th Street, Suite 1500 Lakewood, Colorado 80235 Denver, Colorado 80202 attachments cc: Joe Vranka, CDPHE - HMWMD Steven D. Richtel, WMI E.K. Demos, Denver IFP Women Involve643 d in Farm Economics .X

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Farmers for Environmentally Safe Use of Property

May 15,1997

Marc Herman 6EPR-SR Remedial Project Manager 999 18th Street, Suite 500 Denver, Co 80202-2496

Dear Mr. Herman. ,;;; ' •• . ' • . '" '•!*>••'.:•.'•' '•••"• • •'••.••••' . '• . '.iff-:.'- • In regards (o (he proposed "Lowry LandfiO Superfund Site Second Explaiiudion of :-< •':~....- Significant Differences for the Record of Decision", we request that the public " comment period be extended 60 days from May 22,1997, to ertd.on July 22,1997, to ~-:M give the people of the communities time to review the information, and research any • '^'-- : questions they. have. Due to the delay In getting.al the documents to the public |: - libraries, and the limited access to It, due to distance and times the libraries are open. '; ':t there are many people In these communities, that are Interested in this issue, that ,. '-• ^ have not had sufflclant time to review this information and send comments to you on thtsnwlter. .:;;'•'£}-•• . .. '--'•••'•" '•."'". '""" ' "•' "V. '"'. "•"•' ' ,' •" ;

We hove abo had numerous requests'for copies of the April 2. 1997. PubBc Meeting transcripts. We are therefore requesting that you send a copy of these transcripts to each of the county libraries (Bennett and Deer Trail), so mat they can be available for people to review.

We would appreciate a response on this extension as soon as possible. Please contact Mary Ubner, 48000 E. Cnty. Rd. 34. Bennett, Co 80102; ph. (303)644-3593. Thank You,

Mary Ulmer Richard Price Lyiamae Price Bennett Deer Trail Deer Trail

Bob Carlson MA Hanks Strasourg Deer Trail ,--. A > . ' '- 646

&£ APPLEWOOD SALTATION DISTRICT 3000 Youngfield St., Suite 285 Lakewood, CO 80215 303-232-6883

June 12, 1997

Mr. Marc Herman Remedial Project Manager U.S. Environmental Protection Agency 999 18th Street, Suite 500 Denver, CO 80202

Mr. Mr. Herman: :

The Board of Directors of the Applewood Sanitation District, Jeflerson County, Colorado is in compltJte agreement with the EPA proposal to have the Metro District Plant treat ground -water from the Lowry T-anHfill Superfund site which will be pre-treated at the Superfimd site.

We have followed this proposal through periodic updates by our representative on the Metro Board of Directors. We have complete confidence in Metro being able to do the treatment: and fully protect tide health of Metro employees, the environment and the public at large.

As rate payers we believe the proposed plan is the most economic for all parties and gives all parties the greatest return for money spent.

Sincerely yours,

President /''/' .LL.±*-ii Secretary / a* jJWKfit Treasurer

Board Member

Board Member \ —^ 3 cc Robert W. Hite Metro District Manager

Robert E. Wages President, OCAW 648

P. O. Box 638 Byers, CO 80103 June 30, 1997

Environmental Protection Agency 401 "M"St. Washington, D.C. 20460

ATTENTION: Carol Browner, Administrator

Dear Ms. Browner:

I am writing to^you in regard to a matter of great concern to many residents of our area, the impending contamination of our soil and water by radioactive waste pumped into municipal sludge and to be used in fanning land near Deer Trail and Agate, Colorado.

My family and I moved from metropolitan Denver to Byers, Colorado (a small community 11 miles west of the proposed Superfund site) one and a half years ago and thought: that we had escaped the pollution and hazards of Denver with its environmental disasters like Rocky Flats and the Rocky Mountain Arsenal and that we could live out our lives in our dream home in this wonderful little town wrth.clean. air, clean water, and a spirited people who care about each other and about the land. We are appalled that the place we had chosen to live and raise our son could endanger our lives and health in the future.

I have expressed my emotions and opinions and those of other residents fully in the other letters I have written, and I wont prolong your letter in that way, since I have included copies of local newspaper articles about the matter as well as copies of letters We written to Marc Herman of the: EPA in Denver and President Clinton. Please read these and give them your attention and then PLEASE take action to stop this project from happening! Let's please start acting more responsibly, no matter what the cost, so that hazardous waste cleanup will not become an environmental nightmare for us, our children, and our children's children. PLEASE do not let rural areas become the rugs to sweep these problems under!!

Thank you for any help you may give in this matter.

Sincerely,

Barbara Whhe Phone #(303)822-9322 649

P. O. Box 638 Byers, CO 80103 June 30, 1997

President William Clinton The White House 1600 Pennsylvania Avenue Washington, D. C. 20090

Dear President Clinton:

I am writing in regard to a matter that has many residents in our area very concerned—the impending contamination of our soil and water by radioactive waste pumped into municipal sludge and used in farming land near Deer Trail and Agate, Colorado.

Our family moved from metropolitan Denver to Byers, Colorado (a small community 11 miles west of the proposed Superfund waste site) one and a half years ago and thought that we had escaped the pollution and hazards of Denver with it's environmental disasters like-Rocky Flats and the Rocky Mountain Arsenal, and that we could live out our lives in our dream home in this wonderful little town with clean air, clean water, and a spirited people who care about each other and about the land. We are appalled ihat the place we have chosen to live andd raise our son could endanger our lives and health in the future.

The residents of this area feel violated by the possibility of inundation by radioactive waste. Ii may be the policy of large metropolitan areas to cast off the results of their mistakes with hazardous waste onto rural areas thinking, "Oh, well, not very many people live out there. If we kill off a few of them, no big loss.", but there are actually thousands of people who would be affected in this generation and generations to come by the decision of a few non-caring officials as they attempt to sweep their waste under the rug.

Although officials are attempting to reassure residents of the safety of this venture, I speak for myself and Im sure for many others when I say that I firmly believe that there is NO completely safe method for the disposal of hazardous waste. No matter how "leakproof the containers are, there is always a possibility of failure somewhere down the road, endangering the health of many thousands through drinking water, air, and soil, which would contaminate crops and livestock and maybe end up in food that even you and your family would eat.

I believe that as a free citizen of this country that I should not be unwillingly exposed to these dangers, nor should anyone else. Isnt there some other place that can be used for disposal, such as a very remote area where no one would ever want to live, like the Arctic regions? This may sound like a far-fetched idea, but I think we need to start caring about each other once again and about future generations. We cannot just continue to subject the good residents of American

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rural and metropolitan areas to this waste.

Mr. President, I am including copies of newspaper articles from our area in regard to this matter, as well as a copy of a letter of protest I wrote to Marc Herman of the EPA in Denver. There is a large group of concerned citizens out here and many letters of protest have been written and are being presented this date to Mr. Herman by representatives of this group. PLEASE give this matter your attention, Mr. President, and help save the good people out here from what would be a disaster to humans and the environment alike!!

Thank you for any help you may give in this matter!!

Sincerely,

Barbara White Phone #(303)822-9322

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.uthor: [email protected] (Brad Young) at IN late: 6/30/97 -5:25 PM riority: Normal BCC: marc herman at R8CCP02 TO: [email protected] at IN Sub j ect: lowry Message Contents Received: by ccmail from merlin.rtpnc.epa.gov From [email protected] X-Envelope-From: [email protected] Received: fromiguana.ruralnet.net (root®[205.198.192.2]) by epamail.epa.gov (PMDF V5.1-8 #22480) with SMTP id for [email protected]; Mon, 30 Jun 1997 17:37:53 -0400 (EDT) Received: fromPbyoung53.ruralnet.net (ppp2-20.ruralnet.net [205.198.193.50]) by iguana.ruralnet.net (8.6.9/8.6.9) with SMTP id NAA06226 for ; Mon, 30 Jun 1997 13:57:09 -0600 Date: Mon, 30 Jun 1997 13:57:09 -0600 .From: [email protected] (Brad Young) Subject: lowry X-Sender: [email protected] (Unverified) To: [email protected] Message-id: <[email protected]> MIME-version: 1.0 X-Mailer: Windows Eudora Version 1.4.4 Content-type: text/plain; charset="us-asciin Dear Mr. Herman: I am writing to comment on the Metro Wastewater plan to receive ter from the Lowry Landfill Superfund Site. The project is being objected by environmental activists and by neighbors of the sites where the sludge will be applied. As the State Representative of eastern Arapaho and Elbert counties, I must alert you that I have concerns about the plan. I have had discussions with Adrienne Anderson of Colorado University, Steve Perlman of Metro, Mark Herman of EPA, Fred Bueck of the Agage Soil Conservation District, Leslie Hanks of B.R.E.A.C.H (citizens group), and others who are concerned about the project. Some objectors are contending that plutonium and hydrazine are present in the landfill and will be contaminants added to the waste stream. Metro has assured me that such • materials would not be allowed to be injected into their sewage system, and I cannot imagine why they would. Steve Perlman of Metro Wastewater assured me that the level of contaminates added to Metro's biosolids by the Lowry plan would be immeasureable. If that is so, I would not object to the plan. I have not had time to fully investigate all the claims made by the opponents to the plan. My main concern is that, if the plan goes forward, adequate safegards be implemented. Those who live in the subject area have every right to be certain that the Lowry Landfill problem does not just get moved to their back yards. During the next few weeks, I will be taking steps to make sure that the plan poses no health risk to the eastern plains. If I find evidence that The Lowry plan does pose a health risk to the citizens, I will make certain that the health risk is eliminated. I do not, at this time, object specifically to the Lowry plan. But I am very concerned that Metro has failed to control wind and water erosion on its property. That is another matter which I intend to take up with Metro.