HomeMy WebLinkAbout20021901.tiff STATE OF COLORADO
Roy Romer,Governor
Path Shwayder,Acting Executive Director Opp'"
tidE
Dedicated to protecting and improving the health and environment of the people of Colorado he •
: G3�HAZARDOUS MATERIALS AND WASTE MANAGEMENT DIVISION *• i •
• • ♦
4300 Cherry Creek Dr.S. 222 S.6th Street,Room 232 *'876 s
Denver,Colorado 80222-1530 Grand Junction,Colorado 81501-2768
Phone(303)692-3300 Phone(303)248-7164 ColoradoDepartment
Fax(303)759-5355 Fax(303)248-7198 of Public Health
and Environment
March 22, 1995
Weld County Board of County Commissioners
County Commissioners Office
915 10th Street
Greeley, Colorado 80632
RE: Determination of Impact to Ground Water
Weld County Waste Disposal
Weld County, Colorado
Dear Commissioners: CD
The Solid Waste Section of the Hazardous Materials and Waste Management Division (the
Division) has completed another review of ground water monitoring data for the Weld
County Waste Disposal liquid waste disposal facility. This facility, which is located at the
intersection of County Roads 12 and 35 in southern Weld County, has been the subject of
review by the Division and the Weld County Health Department for approximately two
years.
The Division's review of ground water monitoring data, as presented here, was requested
by the Board of County Commissioners to clarify the impact of the facility as discussed
during the March 1, 1995 hearing. At that hearing, some questions were raised regarding
the Division's August 26, 1993 initial determination of impact to ground water. This second
statistical analysis of the data is meant to address those questions.
In this second analysis of data, the scope of the analysis was increased to include seven
monitoring wells at the facility. The wells analyzed consist of the six originally specified in
the facility's Special Use Permit (wells MW-1, MW-4, MW-8, MW-9, MW-12, and MW-13),
as well as monitoring well MW-5, which has historically shown levels of contaminants
significantly higher than the other wells at the facility and in excess of established state
water quality standards. The chemical constituents used in this statistical analysis consisted
of ten inorganic chemicals analyzed for by the Weld County Health Department laboratory.
Based on the determination of ground water flow direction as presented in the Groundwater
Technology, Inc. October 22, 1993 report, wells MW-1, MW-12, and MW-13 were selected
as upgradient or background wells, and wells MW-4, MW-5, MW-8, and MW-9 were
EXHIBIT
LLl . PLC fit; 5Ccc °acKe+s) °cl Can) 2002-1901
Weld County Commissioners
March 22, 1995
Page 2
selected as downgradient or compliance wells. The statistical analysis of the data was
performed using U. S. Environmental Protection Agency accepted methods as documented
in the GRITS/STAT computer software manual and other EPA guidance documents. In
essence, the statistical test used compares the mean (average) concentration of the selected
chemicals in the upgradient and downgradient wells. If there is a statistically significant
difference between the upgradient and downgradient wells,the downgradient wells that show
evidence of contamination are specified in the computer printout.
The computer printouts attached to this letter show the results of the statistical analyses
performed on the referenced data. The results of this analysis indicate that, of the seven
wells analyzed, three wells -- MW-5, MW-8, and MW-9 -- showed significant evidence of
contamination. Of the ten chemical constituents used in the analysis, MW-5 showed
contamination from nine (9) constituents, MW-8 showed contamination from eight (8)
constituents, and MW-9 showed contamination from six (6) constituents.
In addition to the statistically significant increases shown by the statistical analysis of ground
water data, a further analysis shows that ground water downgradient of the Weld County
Waste Disposal facility has exceeded established state water quality standards for several
chemicals. These standards are established by the Water Quality Control Commission of
the Colorado Department of Public Health and Environment. Primary Standards are based
on the risk certain chemicals pose to human health if consumed, and are intended to protect
the public from acute and chronic health effects. Secondary Standards are set to protect
water resources from degradation, and are established for contaminants which are not
directly related to the safety of the drinking water, but rather the aesthetic quality.
Table 1 attached to this letter shows the range concentrations of hydrocarbon-based
chemicals detected in the ground water at the facility, and the Primary Standards for these
chemicals where standards exist. Table 2 shows the maximum concentration for the ten
inorganic chemicals tested for and the applicable Secondary Standards. Both tables show
which wells contained the specific range of concentrations or maximum concentrations for
hydrocarbons and inorganics, respectively. Of the eight (8) hydrocarbons detected at the
facility, five (5) have established standards, and two (2) have exceeded the applicable
standard. For the ten (10) inorganics, four (4) have secondary standards, three (3) of which
have been exceeded. Exceedance of state water quality standards by Weld County Waste
Disposal is clear evidence of an impact to ground water, and further establishes the
potential threat to human health caused by this facility.
In addition to the Primary and Secondary Standards for ground water, the staff of the Water
Quality Control Division have provided information on Health Advisories and
Recommended Limitations for some of the chemical constituents detected at the facility.
Health Advisories and Recommended Limitations are based primarily on ongoing research,
Weld County Commissioners
March 22, 1995
Page 3
or on health risks to limited groups of individuals. For example, the Recommended
Limitation for sodium is based on the effect sodium can have on individuals with heart
disease or high blood pressure. Where applicable, information on Health Advisories and
Recommended Limitations is presented in Tables 1 and 2.
This letter is intended to reiterate and reaffirm the Division's position as originally stated
on August 26, 1993 that Weld County Waste Disposal has impacted the shallow ground
water in the vicinity of the facility. I hope this letter serves to clarify for the Commissioners
the effect this facility has had on the ground water in the vicinity of the facility.
If you have any questions, please contact me at (303) 692-3462.
Sincerely,
Stephe Laudeman, P.E.
Geological Engineer
Solid Waste Section
Hazardous Materials and Waste Management Division
enclosures
cc: Howard Duckworth, Weld County Waste Disposal, w/enclosures
Richard C. Judd, Attorney, w/enclosures
Don Shosky, Groundwater Technology, Inc., w/enclosures
Tim Monahan, Attorney General's Office, w/enclosures
Keith Schuett, Weld County Planning Department, w/enclosures
Trevor Jiricek, Weld County Department of Health, w/enclosures
File: SW/WLD/WEL/1A
Weld County Waste Disposal
Summary of Ground Water Contamination and Applicable Standards
TABLE 1
Range of Detected Primary Secondary Health
Parameter Concentrations in Wells Standard Standard Advisory
(PPb) (PPb) (PPb) (PPb)
1,1,2,2—Tetrachloroethane 8.4 MW-5 — — —
1,2—Dichloroethane 4.3-6.59 MW-5 0.4 — —
1,2,4—Trimethylbenzene 2.1 MW-8 — — —
Bromomethane 14 MW-8 — — 10
Benzene 4.29-183 MW-5, MW-7, MW-8 5.0 — —
Ethylbenzene 15.6 MW-8 680 — —
Toluene 2.2-237 MW-5, MW-8 1000 — —
Xylenes 12.4-168 MW-5, MW-8 10000 — —
TABLE 2
Maximum Detected Primary Secondary Recommended
Parameter Concentration in Wells Standard Standard Limitations
(PPm) (PPm) (PPm) @Pm)
TDS 19700 MW-8 - 900 -
Sodium 5700 MW-8 — — 200
Chloride 11000 MW-8 — 250 —
Hardness 4500 MW-5 — — 400
Alkalinity 1100 MW-8 — — —
Calcium 3200 MW-5 — — —
Magnesium 460 MW-9 — — 29
Potassium 1200 MW-8 — — —
Iron 250 MW-8 — 0.3 —
pH 6.4 - 7.7 ALL — 6.5 - 8.5 —
Secondary Standard for TDS computed by 1.25 X Background Concentration
March, 1995
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Kruskal-Wallace Test
Report Printed: 03-13-1995 14 :50
Facility:WCWD Weld County Waste Disposal
Address:5019 WCR 35
City:Fort Lupton ST:CO Zip:80621
County:WELD
Contact:Howard Duckworth
Phone: (210) 525-1940
Permit Type:Detection
Constztuent:TDS Total Dissolved Solids
CAS Number• - -
MCL: 500000.000 ppb
ACL: 0. 000 ppb
Detect Limit: 1000.000 ppb
Start Date:Aug 13 1990
End Date:Dec 27 1994
"ta Mode:Original
Background Wells
Well ID N %ND Max Value Min Value Mean Std Dev
MW-1 17 0 800000. 00 630000. 00 714352 .94 56388. 10
MW-12 14 0 2100000.00 1530000. 00 1827142 .88 175474.23
MW-13 16 0 2470000.00 1680000. 00 2193124.75 184705.86
Compliance Wells
Well ID N %ND Max Value Min Value Mean Std Dev
MW-5 13 0 18920000. 00 4320000. 00 13428846. 00 5141814. 50
MW-8 18 0 19700000. 00 3790000. 00 6332778. 00 3795160. 50
MW-4 7 0 740000. 00 570000. 00 644285. 69 57404. 16
MW-9 16 0 9500000. 00 6100000. 00 7398750. 00 992403 . 56
H Statistic: 82 . 6522
H Adjusted for Ties: 82 .6676
Degrees of Freedom: 4
Chi-Squared: 9 . 4878
Za/DF: 2. 2414
* Indicates significant evidence of contamination
Well ID Crit. Diff. Rank Avg. Background Rank Avg. Difference
*MW-5 20.5740 89. 62 30.56 59. 05
*MW-8 18. 1985 68.33 30.56 37 .77
"4-4 26.5988 6.93 30. 56 -23 .64
*MW-9 19. 0031 79 .44 30. 56 48 . 87
Kruskal-Wallace `Test
Report Printed: 03-13-1995 14: 53
Facility:WCWD Weld County Waste Disposal
Address: 5019 WCR 35
City:Fort Lupton ST:CO Zip: 80621
County:WELD
Contact:Howard Duckworth
Phone: (210) 525-1940
Permit Type:Detection
Constituent:Na ; Sodium
CAS Humber: 7440-23-5
MCL: 20000. 000 ppb
ACL: 0. 000 ppb
Detect Limit: 5000. 000 ppb
Start Date:Aug 13 1990
End Date:Dec 27 1994
eta Mode:Original
Background Wells
Well ID N %ND Max Value Min Value Mean Std Dev
MW-1 17 0 150000. 00 120000. 00 141764 .70 8828.43
MW-12 14 0 360000. 00 180000. 00 317857. 13 46769. 25
MW-13 16 0 710000. 00 430000. 00 592500. 00 88806.91
Compliance Wells
Well ID N %ND Max Value Min Value Mean ; Std Dev
MW-5 13 0 4700000. 00 1500000.00 3630769.25 1138994 .25
MW-8 18 0 5700000. 00 990000.00 1793888 .88 1116860.75
MW-4 6 0 52000. 00 44000.00 49000. 00 3098. 39
MW-9 16 0 1200000. 00 110000.00 992499 .94 248555.83
H Statistic: 82 .0951
H Adjusted for Ties: 82 .2017
Degrees of Freedom: 4
Chi-Squared: 9 . 4878
Za/DF: 2 . 2414
* Indicates significant evidence of contamination
Well ID Crit. Diff. Rank Avg. Background Rank Avg. Difference
*MW-5 20.3692 91. 96 31. 00 60. 96
*MW-8 18 . 0173 78. 50 31. 00 47.50
'^W-4 28 . 1794 3 . 50 31. 00 -27. 50
• 14W-9 18.8139 60. 22 31. 00 29. 22
r
Kruskal-Wallace 'Test
Report Printed: 03-13-1995 14: 56
Facility:WCWD Weld County Waste Disposal
Address: 5019 WCR 35
City:Fort Lupton ST:CO Zip:80621
County:WELD
Contact:Howard Duckworth
Phone: (210) 525-1940
Permit Type:Detection
Constituent:Chloride Chloride
CAS Number:16887-00-6
MCL: 250000. 000 ppb
ACL: 0. 000 ppb
Detect Limit: 3000. 000 ppb
Start Date:Aug 13 1990
End Date:Dec 27 1994
to Mode:Original
Background Wells
Well ID N %ND Max Value Min Value Mean Std Dev
MW-1 17 0 120000. 00 67000.00 94000. 00 20582 . 15
MW-12 14 0 230000. 00 140000.00 172857 . 14 27295. 70
MW-13 16 0 300000. 00 180000.00 224374 . 98 27560. 54
Compliance Wells
Well ID N AND Max Value Min Value f Mean Std Dev
MW-5 13 0 10000000. 00 950000. 00 6879999. 50 3274795. 00
MW-8 18 0 11000000. 00 1200000. 00 2832222 . 25 2314884. 25
MW-4 7 0 97000. 00 63000. 00 73000. 00 11298. 97
MW-9 16 0 1000000. 00 500000. 00 766250. 00 143706.86
H Statistic: 86. 3690
H Adjusted for Ties: 86.4168
Degrees of Freedom: 4
Chi-Squared: 9.4878
r Za/DF: 2 .2414
* Indicates significant evidence of contamination
Well ID Crit. Diff. Rank Avg. Background Rank Avg. Difference
*MW-5 20. 5740 91.85 30. 63 61. 22
*MW-8 18. 1985 81. 67 30. 63 51. 04
'—"W-4 26. 5988 6.50 30. 63 -24. 13
-s4W-9 19. 0031 62 . 63 30. 63 32 . 00
Rruskai-Wallace Test
Report Printed: 03-13-1995 16: 01
Facility:WCWD Weld County Waste Disposal
Address:5019 WCR 35
City:Fort Lupton ST:CO Zip:80621
County:WELD
Contact:Howard Duckworth
Phone: (210) 525-1940
Permit Type:Detection
Constituent:pH pH
CAS Number -
MCL: 0.000 ppb
ACL: 0. 000 ppb
Detect Limit: 0.000 ppb
Start Date:Aug 13 1990
End Date:Dec 27 1994
to Mode:Original'
Background Wells
Well ID N %ND Max Value Min Value Mean Std Dev
MW-1 17 0 8. 20 7 . 50 7. 92 0. 18
MW-12 13 0 7.90 7 .40 7. 56 0. 15
MW-13 15 0 8. 00 7 . 00 7. 50 0.25
Compliance Wells
Well ID N %ND Max Value Min Value Mean Std Dev
MW-5 13 0 7.40 6.40 6.78 0.28
MW-8 17 0 7.70 6. 60 7. 14 0. 35
MW-4 6 0 8. 00 7. 60 7.75 0. 16
MW-9 15 0 7. 60 7.40 7.48 0. 09
H Statistic: 50.7796
H Adjusted for Ties: 51. 3318
Degrees of Freedom: 4
Chi-Squared: 9 . 4878
Za/DF: 2 . 2414
* Indicates significant evidence of contamination
Well ID Crit. Diff. Rank Avg. Background Rank Avg. Difference
MW-5 19. 6602 11. 42 64.22 -52 .80
MW-8 17 .7753 28 . 65 64.22 -35. 58
"W-4 27 . 1365 73 . 08 64.22 8.86
AW-9 18. 6155 46. 13 64.22 -18. 09
n
Kruskal-Wallace :Test
Report Printed: 03-13-1995 15: 00
Facility:WCWD Weld County Waste Disposal
Address:5019 WCR 35
City:Fort Lupton ST:CO Zip:80621
County:WELD
Contact:Howard Duckworth
Phone: (210) 525-1940
Permit Type:Detection
Constituent:Hardness Hardness
GAS Number: - -
MCL: 0. 000 ppb
ACL: 0. 000 ppb
Detect Limit: 50000. 000 ppb
Start Date:Aug 13 1990
End Date:Dec 27 1994
to ModeOriginall.
Background Wells
Well ID J N %ND Max Value Min Value Mean Std Dev
MW-1 18 0 320000. 00 140000. 00 271666. 66 45146.82
MW-12 14 0 700000. 00 440000. 00 576428. 63 82332 . 09
MW-13 16 0 250000. 00 110000. 00 151250. 00 42875.79
Compliance Wells
Well ID ! N %ND Max Value Min Value Mean ! Std Dev
MW-5 13 0 4500000. 00 220000. 00 2433846. 00 1445651.75
MW-8 18 0 2100000. 00 150000. 00 636111. 13 518313 . 31
MW-4 7 0 430000. 00 330000. 00 378571.44 35790. 39
MW-9 16 0 3600000. 00 220000. 00 2758125. 00 804439.44
H Statistic: 55.4977
H Adjusted for Ties: 55. 5212
Degrees of Freedom: 4
Chi-Squared: 9.4878
Za/DF: 2 .2414
* Indicates significant evidence of contamination
Well ID Crit. Diff. Rank Avg. Background Rank Avg. Difference
*MW-5 20.7299 82 . 35 32. 19 50. 16
*MW-8 18 .3248 53 . 58 32 . 19 21.40
eit'W-4 26. 8248 44.79 32 . 19 12 . 60
*riW-9 19 . 1396 84.97 32 . 19 52 .78
r
Kruskai-WallaceTest
Report Printed: 03-13-1995 15: 04
Facility:WCWD Weld County Waste Disposal
Address:5019 WCR 35
City:Fort Lupton ST:CO Zip:80621
County:WELD
Contact:Howard Duckworth
Phone: (210) 525-1940
Permit Type:Detection
Constituent:Ca Calcium, total
CAS Number: 7440-70-2
MCL: 0. 000 ppb
ACL: 0. 000 ppb
Detect Limit: 1000000. 000 ppb
Start Date:Aug 13 1990
End Date:Dec 27 1994
eta Mode•Original'
Background Wells
Well ID N %ND Max Value Min Value Mean Std Dev
MW-1 17 0 200000. 00 74000. 00 161411. 77 33598 . 84
MW-12 14 0 470000. 00 130000. 00 378571. 44 86278 . 37
MW-13 16 0 170000. 00 31000. 00 105187 . 50 34021. 98
Compliance Wells
Well ID N %ND Max Value Min Value Mean Std Dev
MW-5 13 0 3200000. 00 170000. 00 1834615. 50 1071040. 13
MW-8 18 0 1400000. 00 58000. 00 448777.78 353181. 94
MW-4 6 0 310000. 00 240000. 00 276666. 66 30110. 91
MW-9 16 0 1700000. 00 650000. 00 1274375. 00 263893 . 13
H Statistic: 60.9423
H Adjusted for Ties: 60.9712
Degrees of Freedom: 4
Chi-Squared: 9 . 4878
Za/DF: 2 . 2414
* Indicates significant evidence of contamination
Well ID Crit. Diff. Rank Avg. Background Rank Avg. Difference
*MW-5 20. 3692 84 . 19 30. 26 53 . 94
*MW-8 18 . 0173 52 . 50 30.26 22 . 24
' --W-4 28 . 1794 43 . 42 30.26 13 . 16
-AW-9 18 .8139 83 . 00 30.26 52 .74
Kruskal-Wallace 'Test
Report Printed: 03-13-1995 15: 09
Facility:WCWD Weld County Waste Disposal
Address: 5019 WCR 35
City:Fort Lupton ST:CO Zip:80621
County:WELD
Contact:Howard Duckworth
Phone: (210) 525-1940
Permit Type:Detection
Constituent:Mg , Magnesium, total
CAS Number: 7439-95-4
MCL: 125000. 000 ppb
ACL: 0. 000 ppb
Detect Limit: 1000. 000 ppb
Start Date:Aug 13 1990
End Date:Dec 27 1994
eta Mode:0riginal
Background Wells
Well ID N %ND Max Value Min Value Mean Std Dev
MW-1 17 0 32000. 00 22000. 00 27000. 00 2828.43
MW-12 14 0 63000. 00 35000. 00 44571. 43 8829. 27
MW-13 16 0 19000. 00 7000. 00 10556. 25 3576. 40
Compliance Wells
Well ID N %ND Max Value Min Value Mean Std Dev
MW-5 13 0 320000. 00 7300. 00 140176. 92 99800. 58
MW-8 18 0 170000. 00 7000. 00 43277.78 42140.95
MW-4 6 0 32000. 00 23000. 00 25666. 67 3386. 25
MW-9 16 0 460000. 00 49000. 00 334312 . 50 107257.76
H Statistic: 49 . 4249
H Adjusted for Ties: 49 . 5015
Degrees of Freedom: 4
Chi-Squared: 9. 4878
Za/DF: 2 . 2414
* Indicates significant evidence of contamination
Well ID Crit. Diff. Rank Avg. Background Rank Avg. Difference
*MW-5 20. 3692 68. 12 36.59 31.53
MW-8 18. 0173 43 . 31 36.59 6. 72
e-sW-4 28. 1794 35. 17 36.59 -1.42
*MW-9 18.8139 90.91 36.59 54 . 32
P"'"
Kruskal-Wallace Test
Report Printed: 03-13-1995 15: 12
r
Facility:WCWD Weld County Waste Disposal
Address: 5019 WCR 35
City:Fort Lupton ST:CO Zip:80621
County:WELD
Contact:Howard Duckworth
Phone: (210) 525-1940
Permit Type:Detection
Constituent:CaCO3 Alkalinity (calcium carbonate)
CAS Number: 1317-65-3
MCL: 0. 000 ppb
ACL: 0. 000 ppb
Detect Limit: 0. 000 ppb
Start Date:Aug 13 1990
End Date:Dec 27 1994
ta Mode:Original'.
Background Wells
Well ID '; N %ND Max Value Min Value Mean Std Dev
MW-1 16 0 250000. 00 190000.00 228749 . 98 15438 . 05
MW-12 14 0 410000. 00 310000.00 345000. 00 30064 . 04
MW-13 16 0 650000. 00 440000.00 558125. 00 60246. 02
Compliance Wells
Well ID ! N %ND Max Value Min Value Mean Std Dev
MW-5 13 0 2700000. 00 510000.00 864615. 38 562548 . 00
MW-8 18 0 1100000. 00 290000. 00 563333 . 31 263684 . 31
MW-4 7 0 180000. 00 160000. 00 165714 .28 7867 . 96
MW-9 16 0 320000. 00 2310.00 215769 . 38 69858 . 22
H Statistic: 60.9223
H Adjusted for Ties: 60.9915
Degrees of Freedom: 4
Chi-Squared: 9.4878
Za/DF: 2 .2414
* Indicates significant evidence of contamination
Well ID Crit. Diff. Rank Avg. Background Rank Avg. Difference
*MW-5 20. 4171 88. 69 49.29 39.40
*MW-8 18 . 0714 68. 19 49.29 18. 90
e-14l-4 26. 3711 5. 14 49.29 -44 . 15
MW-9 18 . 8658 22 .88 49.29 -26.42
r
4
Kruskal-Wallace 'Teat
Report Printed: 03-13-1995 15: 15
Facility:WCWD Weld County Waste Disposal
Address: 5019 WCR 35
City:Fort Lupton ST:CO Zip: 80621
County:WELD
Contact:Howard Duckworth
Phone: (210) 525-1940
Permit Type:Detection
Constituent:K Potassium, total
CAS Number: 7440-09-7
MCL: 0. 000 ppb
ACL: 0. 000 ppb
Detect Limit: 0. 000 ppb
Start Date:Aug 13 1990
End Date:Dec 27 1994
eta Mode:Original
Background Wells
Well ID N %ND Max Value Min Value ' Mean Std Dev
MW-1 16 6 44000. 00 2500. 00 7531.25 9895.23
MW-12 14 0 330000.00 19000. 00 46785.71 81648.57
MW-13 15 0 280000. 00 65000. 00 158333 . 33 46967.57
Compliance Wells
Well ID N %ND Max Value Min Value Mean Std Dev
MW-5 13 0 7400000. 00 200000. 00 943076.94 1945368. 00
MW-8 18 0 1200000. 00 190000. 00 451666. 69 242226. 19
MW-4 6 0 22000. 00 2000. 00 6166. 67 7782 .46
MW-9 16 6 180000. 00 2500. 00 24281.25 41833 .79
H Statistic: 65. 9350
H Adjusted for Ties: 65. 9821
Degrees of Freedom: 4
Chi-Squared: 9.4878
e^ Za/DF: 2 . 2414
* Indicates significant evidence of contamination
Well ID Crit. Diff. Rank Avg. Background Rank Avg. Difference
*MW-5 20. 0614 82 .42 38.97 43 .46
*MW-8 17. 7686 82 . 33 38.97 43 . 37
rig-4 27 .6904 12 . 08 38.97 -26.88
14W-9 18 . 5449 29.47 38.97 -9.50
r
Kruskal-Wallace lTest
Report Printed: 03-13-1995 15: 18
Facility:WCWD Weld County Waste Disposal
Address: 5019 WCR 35
City:Fort Lupton ST:CO Zip:80621
County:WELD
Contact:Howard Duckworth
Phone: (210) 525-1940
Permit Type:Detection
Constituent:Fe Iron, total
CAS Number: 7439-89-6
MCL: 30000. 000 ppb
ACL: 0. 000 ppb
Detect Limit: 100000. 000 ppb
Start Date:Aug 13 1990
End Date:Dec 27 1994
r'ta Mode:Original
Background Wells
Well ID N %ND Max Value Min Value ' Mean Std Dev
MW-1 17 0 400.00 20. 00 117 . 06 100.24
MW-12 14 0 580.00 30. 00 144 .29 142 .54
MW-13 16 0 11000. 00 50. 00 1952 .50 2761. 64
Compliance Wells
Well ID N %ND Max Value ; Min Value Mean ' Std Dev
MW-5 13 0 4200. 00 300. 00 1581. 54 1047 . 02
MW-8 18 0 250000. 00 550. 00 45436. 11 60429. 92
MW-4 7 0 1900. 00 40. 00 578 . 57 661.88
MW-9 16 0 2200. 00 80. 00 440. 63 518.85
H Statistic: 52 . 4642
H Adjusted for Ties: 52.4881
Degrees of Freedom: 4
Chi-Squared: 9.4878
Za/DF: 2 .2414
* Indicates significant evidence of contamination
Well ID Crit. Diff. Rank Avg. Background Rank Avg. Difference
*MW-5 20.5740 68 . 46 34.51 33 . 95
*MW-8 18 . 1985 89 . 92 34.51 55.41
eTh-4 26.5988 42 .79 34.51 8.28
MW-9 19 . 0031 45. 06 34.51 10.55
r
r-
Probable Cause
DATE: February 21, 1995
' IC
C;_C.
CASE NUMBER: ZCH-102 j
SUP-454
NAIVE,: Howard Duckworth
Weld County Waste Disposal
12018 Warfield
San Antonio, Texas 78216
LEGAL DESCRIPTION: Located in part of the Northwest 1/4, of Section 12, Township 1 North,
Range 66 West of the 6th P.M., Weld County, Colorado.
LOCATION: South of and adjacent to Weld County Road 12; east of and adjacent to Weld County
Road 35.
It is the opinion of the Department of Planning Services staff, that the following Standards as
approved for SUP-454 are not in compliance.
Development Standard Number one states:
1. The water and oil fluids recycling and disposal site granted by this Special Use
Permit on the hereon described parcel is limited to the facilities shown hereon. Said
facilities shall be:
a. 600 square foot(minimum)structure built in accordance with the requirements
of the Uniform Building Code and utilized as an office and residence by an
employee for the control, operation and security of the facility;
b. Eight 300 barrel tanks;
c. One circulating pump and motor:
d. One 8 foot and 20 foot heat and filtering vessel.
e. Four bentonite sealed lagoons as shown hereon. The lagoons may include an
aeration system as part of the operation. The dimensions of the lagoons shall
be as follows:
Pond A - 83,000 square feet 1.9 acres 3 EXHIBIT
Pond B - 82,000 square feet 1.9 acres
Pond C -312,600 square feet 8.2 acres
Pond D - 83,000 square feet 1.9 acres
ZCH-102
Howard Duckworth
Weld County Waste Disposal
f. Settling pit screened with one-inch mesh.
g. Concrete sump divided by cement petitions into three (3) separate holding
tanks. Additionally, all uses permitted by right in Section 3.3 of the Weld
County Zoning Resolution are allowed within the Special Use Permit area.
The property is not being maintained in compliance with this standard. The operator of the facility
applied waste which had been received into the facility onto property to the south (Martin property).
This area is outside of the special review permit area and is an expansion of the operation.
Development Standard Nnumber 4 states:
4. All phases of the operation shall comply with all County and State Health
Standards and Regulations pertaining to air quality, water quality, noise
emission, and sanitary disposal systems. Representatives or members of the
Weld County Health Department, Weld County Department of Planning
Services Staff and /or Colorado Department of Health shall be granted access
onto the site and any reasonable time in order to insure the operations carried
out on the site comply with all applicable Weld County and State Health
Regulations.
All phases of the operation are not being maintained in compliance with all County and State Health
Standards and Regulations pertaining to air quality, water quality, and sanitary disposal systems as
identified below.
- The facility has impacted groundwater at this location. The facility has
detected levels of benzene in monitoring wells on site in excess of the
groundwater standards as defined in "the Basic Standards for Groundwater".
The CDPHE and the Office of the Attorney General issued this determination
in letters dated August 26, 1993 and February 2, 1994. This letter also
required that pursuant to Section 9.1.4 of the Regulations Pertaining to Solid
Waste Disposal Sites and Facilities, the facility come in to compliance with all
applicable requirements of Section 9 of these regulations.
The impact to groundwater is a violation of Section 2.1.3 and 2.1.4 of the
Regulations Pertaining to Solid Waste Disposal Sites and Facilities.
ZCH-102
Howard Duckworth
Weld County Waste Disposal
- The facility has accepted hazardous waste on four (4) previous occasions.
This is a violation of the Colorado Hazardous Waste Regulations as
documented by the Notice of Violation and Request for Information from the
CDPHE, Certified letter No. P 860 415 499. In addition, this is a violation of
Section 2.1.1 and 9.7.2 of the Regulations pertaining to Solid Waste Disposal
Sites and Facilities.
- The facility has been issued Notice of Violation of odor emissions by the Air
Pollution Control Division (APCD), Colorado Department of Public Health
and Environment.
The Notice of Violation, Certified letter No. 392782581, was issued for odor
emissions from evaporation ponds on site in excess of the limits allowed by the
Colorado Air Pollution Control Commission's Regulation No. 2. The APCD
is currently considering a Compliance Order for this violation.
This is a violation of Section 2.1.1 of the Regulations Pertaining to Solid
Waste Disposal Sites and Facilities.
- The facility had applied waste that was received at the facility onto property
out side of the special use permit area. This property is known as the "Martin
Property".
This land application of waste is a violation of Section 1.3.3 and 1.6.1 of the
Regulations Pertaining to Solid Waste Disposal Sites and Facilities. The
facility was cited by the Weld County Health Department in certified letter No.
P 186978 550.
- Pond C has been observed on numerous occasions to have a floating oil scum
on the surface. The dates and percentage of coverage on Pond C are as
follows:
September 29, 1993, approximately 5-10% covered with scum
November 5, 1993, approximately 15% covered with scum
March 29, 1994, approximately 10% covered with scum
October 5, 1994, approximately 33% covered with scum
ZCH-102
Howard Duckworth
Weld County Waste Disposal
This is a violation of Section 9.7.5 of the Regulations Pertaining to Solid
Waste Disposal Sites and Facilities. The facility was cited by the Weld County
Health Department by letters dated November 10, 1993 and January 31, 1995,
and a notice of violation by the CDPHE in a letter dated October 25, 1994, for
floating scum on the surface of Pond C.
- The ponds are not equipped with fixed gauges to determine the depth of the
waste to the nearest five-hundredths (.05) of a foot.
This is a violation of Section 9.5.1 and 9.5.7 of the Regulations Pertaining to
Solid Waste Disposal Sites and Facilities. The facility was cited in a Notice
of Violation by the CDPHE, dated October 25, 1994, for this violation.
- - Monitoring wells 5, 6, 8, and 9 were not equipped with locks.
This is a violation of Section 9.5.5 of Regulations Pertaining to Solid Waste
Disposal Sites and Facilities. The facility was cited in a Notice of Violation
by the CDPHE, dated October 25, 1994 for this violation.
- Erosion within the ponds has been observed at the facility, the erosion was
located where the receiving area discharges into Pond C, and the Southwest
corner of Pond C.
This a violation of Section 9.7.3 of the Regulations Pertaining to Solid Waste
Disposal Sites and Facilities. The facility was cited in a Notice of Violation
by the CDPHE, dated October 25, 1994 for this violation.
- The facility does not maintain adequate records on site to verify the following:
a) Each waste stream accepted by the facility is tested at least annually.
•
(Section 9.8.1 of the Regulations Pertaining to Solid Waste Disposal
Sites and Facilities )
b) Individual loads receipts being maintained for at least two (2) years.
(Section 9.8.2 (B) Regulations Pertaining to Solid Waste Disposal
Sites and Facilities )
c) Monthly summaries are maintained for total waste volumes and waste
identification(s), (Section 9.8.2 ( C ) Regulations Pertaining to Solid
Waste Disposal Sites and Facilities)
d) Repairs to the embankments and liners as needed have been
performed. (Section 9.8.4 Regulations Pertaining to Solid Waste
Disposal Sites and Facilities )
ZCH-102
Howard Duckworth
Weld County Waste Disposal
e) Frequent general inspections concerning the condition of the facility
are being conducted. (Section 9.8.7 Regulations Pertaining to Solid
Waste Disposal Sites and Facilities )
f) Soil liner material has been tested hor hydraulic conductivity.
(Section 9.8.8 Regulations Pertaining to Solid Waste Disposal Sites
and Facilities )
The above are violations of the Section number as indicated in the Regulations
Pertaining to Solid Waste Disposal Sites and Facilities. In addition, failure to
maintain the above records available for inspection is a violation of Section 9.9
of the Regulations Pertaining to Solid Waste Disposal Sites and Facilities. The
facility was cited in a Notice of Violation by the CDPHE, dated October 25,
1994, for these violations.
- Evidence that waterfowl may have perished after coming into contact with the
impounded wastes was observed and collected on October 5, 1994, by
representatives of the CDPHE and the Colorado Division of Wildlife.
This is a violation of Section 9.1.2 of the Regulations Pertaining to Solid
Waste Disposal Sites and Facilities. The facility was cited in a notice of
Violation by the CDPHE, dated October 25, 1994, for this violation.
Development Standard Number fourteen states:
14. The Special Use Permit shall be limited to the plans shown hereon ans
governed by the Development Standards stated above and all applicable Weld
County Regulations. Any material deviation from the plans ans/or
Development Standards as shown or stated above shall require the approval
of an amendment to the Special Use Permit by the Planning Commission and
the Board of County Commissioners Before such changes from the plans
and/or Development Standards shall be permitted. Any other Changes from
the plans and/or Development Standards shall be filled in the office of the
Department of Planning Services.
The uses conducted have not been limited to the plans shown and have not been maintained in
compliance with the approved Development Standards or applicable Weld County Regulations. The
uses listed above and the noncompliance with the approved Development Standards are material
deviations from the approved permit and no amendment has been applied for or approved for such
changes. Additionally no other changes from the approved plans and/or Development Standards
have been filed with the Department of Planning Services.
ZCH-102
Howard Duckworth
Weld County Waste Disposal
The Department of Planning Services staff requests that the Board of County Commissioners find
Probable Cause and Schedule a Show Cause Hearing on April 5, 1995, to determine if the Special
Use Permit should be revoked.
i nC
fijit ;C: .
f7 73
D I n _ c: - .
C. DEPARTMENT OF (3o NIN 6 00,VIC 4
ONE 0
FAX (303) 351-0978
COLORADO WELD COUNTY ADMINISTRATIVE OFFICES
N00 N. 17TH AVENUE
GREELEY, COLORADO 80631
February 8, 1995
Weld County Commissioners
915 10th Street
Greeley, Colorado, 80615
Subject: ZCH-102, SUP-454 Weld County Waste Disposal, Inc., Located in the
Northwest I/4, of Section 12, Township 1 North, Range 66 West of the
6th P.M., Weld County, Colorado
Dear Commissioners:
Richard D. Judd, Attorney at law, representing Mr. Howard Duckworth in this
matter, submitted the attached letter requesting a continuance to March 1, 1995.
Mr. Judd has indicated in his letter that he will be out of state from February 7 to
February 12, 1995. The Department of Planning Services staff requests that the
Board continue this matter to March 1, 1995
Sincerely,
rr—
itn A. Sc uett
Current Planner II EXHIBIT
ed
SERVICE,TEAMWORK,INTEGRITY,QUALITY
RICHARD D. JUDD, P.C.
ATTORNEY AT LAW
1660 LINCOLN STREET, SUITE 2800
DENVER, COLORADO 80264
FACSIMILE: 303/831-1181
TELEPHONE: 303/831-1110
February 1, 1995 ���ia�r�\��r
VIA FACSIMILE AND REGULAR MAIL 1\t FEB 3 1995
' '^-..emu Planning
Clerk of the Board of County Commissioners
Board of County Commissioners
Weld County
915 10th Street
Greeley, Colorado 80631
Re: Weld County Waste Disposal, Inc.
Zch-102, SUP-454
Located: A part of the northwest 1/4 of Section 12, Township 1 North,
Range 66 West of the 6th P.M., Weld County, Colorado
Dear Clerk:
By letter dated January 27, 1995, sent by facsimile transmission to me on that date and
to Weld County Waste Disposal, Inc., notice was given that a probable cause public hearing
pursuant to Section 81 of the Weld County Zoning Ordinances would be held before the County
Commissioners of Weld County commencing on February 8, 1995 at 9:00 a.m. or as soon
thereafter as the agenda of the Board of County Commissioners permit. I was out of my office
on January 27, 1995 and did not receive the notice until January 30, 1995. I then received, by
Federal Express, the complete package of January 31, 1995.
I will be unavailable to be present at that time as I am scheduled to be out of the State
of Colorado from February 7 through February 12, 1995. I would, therefore, respectfully request
that the hearing be continued to one of the following Mondays or Wednesdays at which time I
will be available:
February 20, 1995
March 1, 1995
March 6, 1995
March 13, 1995
March 15, 1995
March 20, 1995
March 22, 1995
March 27, 1995
March 29, 1995
RICHARD D. JUDD, P.C.
Clerk of the Board of County Commissioners
February 1, 1995
Page 2
Please contact me just as soon as possible to set a date for the hearing so that I can schedule it
without conflict.
I today discussed this request for continuance with Lee Morrison, Esquire, the Weld
County Attorney handling this matter for the County. Mr. Morrison indicated that a March 1,
1995 hearing date would be an alternative. That date is satisfactory with Weld County Waste
Disposal, Inc.
The rights of Weld County Waste Disposal, Inc. may be impacted by any determination
reached by the County Commissioners at this hearing. Weld County Waste Disposal, Inc. desires
to and should be represented by counsel at that hearing.
Further, the packet which I received yesterday indicates ten violations, many of which
have subparts, are set for hearing. Less than ten days prior notice is inadequate to prepare to
address these issues.
I would request that if the Department of Planning Services has filed any documentation
with the Weld County Commissioners seeking the hearing on the same, that copies of those
documents be provided to me.
Thank you for your attention to this matter.
Yours very truly,
Richard D. Judd
RDJ/vab
cc: Lee Morrison, Esq. (via facsimile)
Mr. Keith A. Schuett (via facsimile)
Mr. Trevor Jiricek (via facsimile)
Mr. Don Shosky (via facsimile)
Mr. Howard Duckworth (via facsimile)
Hello