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HomeMy WebLinkAbout20000457.tiff RESOLUTION RE: ACTION OF BOARD CONCERNING PROBABLE CAUSE FOR SPECIAL USE PERMIT#454 - HOWARD DUCKWORTH, DBA WELD COUNTY WASTE DISPOSAL WHEREAS, the Board of County Commissioners of Weld County, Colorado, pursuant to Colorado statute and the Weld County Home Rule Charter, is vested with the authority of administering the affairs of Weld County, Colorado, and WHEREAS, notice was given that a Probable Cause Hearing, pursuant to Section 81 of the Weld County Zoning Ordinance, would be held before the Board concerning Special Use Permit#454 issued to Howard Duckworth, dba Weld County Waste Disposal, Inc., and WHEREAS, at a hearing before the Board on February 8, 1995, staff presented a letter from Richard Judd, Attorney representing Mr. Duckworth, requesting a continuance of this matter to March 1, 1995, due to a scheduling conflict, and WHEREAS, at said hearing on March 1, 1995, the Board deemed it advisable to continue this matter to May 17, 1995, at 9:00 a.m., to allow staff to supplement notice regarding impacts to groundwater and failure to pay solid waste surcharge and to allow the Permittee to prepare for those issues, and WHEREAS, at said hearing on May 17, 1995, Mr. Judd was present, and the Board heard all of the testimony and statements of those present, studied the recommendations of the Weld County Planning and Health Department staff and all of the exhibits and evidence presented in this matter and, having been fully informed, again deemed it advisable to continue said matter to August 2, 1995, at 9:00 a.m., based upon staffs recommendation, to allow time for the global settlement of all regulatory and other issues existing to be completed in writing and result in a compliance order upon consent by the Colorado Department of Health, Weld County Health Department, and Weld County Waste Disposal, Inc., and WHEREAS, at said hearing on August 2, 1995, Mr. Judd was not present, and the Board heard all of the testimony and statements of those present, studied the recommendations of the Weld County Planning and Health Department staff and all of the exhibits and evidence presented in this matter and, having been fully informed, again deemed it advisable to continue said matter to February 21, 1996, at 9:00 a.m., based upon staffs recommendation, to allow time for the interim control measures and site characterization to be completed pursuant to the United States Environmental Protection Agency Administrative Compliance Order and for the issue concerning land application of waste on the "Martin" property to be further evaluated by the landowner and negotiations completed to bring the property into compliance with the requirements of Colorado Department of Health, Weld County Health Department, and Weld County Planning Department, and pi_ „" eA lit GK"cvoal- ' JUOel 2000-0457 PL0447 ............................... ................................. PROBABLE CAUSE HEARING FOR SUP#454 - DUCKWORTH/WCWD PAGE 2 WHEREAS, at said hearing on February 21, 1996, the Board heard all of the testimony and statements of those present, studied the recommendations of staff from the Weld County Departments of Planning and Health and all of the exhibits and evidence presented in this matter and, having been fully informed, again deemed it advisable to continue said matter to February 26, 1997, at 9:00 a.m., to allow site characterization and interim control measures to continue, in accordance with the EPA Order and to allow time for final measures to be completed, and WHEREAS, at said hearing on February 26, 1997, the Board was advised by staff that cleanup of the site by H S Resources, Inc., and Amoco Production Company is slowly progressing and site characterization and interim control measures are proceeding in accordance with the EPA Order although it will be five or six years before final measures are completed and, having been fully informed, again deemed it advisable to continue said matter, to February 25, 1998, at 9:00 a.m., and WHEREAS, at said hearing on February 25, 1998, the applicant was not present or represented, and the Board studied the recommendations from the Weld County Departments of Planning and Health staff and deemed it advisable to again continue said matter to February 24, 1999, at 9:00 a.m. to allow site characterization and interim control measures to continue, in accordance with the EPA Order and to allow time for final measures to be completed, and WHEREAS, at said hearing on February 24, 1999, the applicant was not present or represented, and the Board reviewed the recommendations from the Weld County Department of Health staff and once again deemed it advisable to continue said matter to February 23, 2000, at 9:00 a.m., to allow site characterization and remediation measures to continue, in accordance with the EPA Order, as well as to allow time for final measures to be completed. WHEREAS, at said hearing on February 23, 2000, the applicant was not present or represented, and the Board reviewed the recommendations from the Weld County Department of Public Health and Environment staff and once again deemed it advisable to continue said matter to December 11, 2000, at 9:00 a.m., to allow the Colorado Department of Public Health and Environment and the County to evaluate other potential enforcement action in accordance with the Solid Waste Act. NOW, THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Weld County, Colorado, that this matter be, and hereby is, continued to December 11, 2000, at 9:00 a.m. 2000-0457 PL0447 PROBABLE CAUSE HEARING FOR SUP#454 - DUCKWORTH/WCWD PAGE 3 The above and foregoing Resolution was, on motion duly made and seconded, adopted by the following vote on the 23rd day of February, A.D., 2000. BOARD OF COUNTY COMMISSIONERS WELD COUNTY, COLORADO ATTEST: ,a,/ / ' ' sl fr L/.Q 7A i '- Barbara J. 'meyer, hair U Weld County Clerk to he and ' � r 0 f J. ',eile, Pro-Tem • Deputy Clerk to the B & 1 Georg E. Baxter APPROVED AS TO FOR ,_ Da a K. Hall C ti i nty'A 4orne 2 EXCUSED DATE OF SIGNING (AYE) Glenn Vaad 2000-0457 PL0447 it MEM ;ti TO: Weld County Commissioners DATE: February 17 FROM: Trevor Jiricek, Department of Public Health Enviromment 10, 4) SUBJECT: Weld County,Waste Disposal COLORADO Our Department is recommending for a continuance for a period of one year for this Probable,Show Cause hearing involving the Weld County Waste Disposal. The continuance will allow the Colorado Department of Public Health and Environment(CDPHE)and the County to evaluate other potential enforcement actions in accordance with the Solid Waste Act. STATUS: HS Resources and Amoco have completed their portion of the cleanup required under the EPA Order. They nave committed to one year's maintenance of the cover over the areas that they have closed and revegetated. They have also committed to one year of additional groundwater monitoring. This will conclude in December 2000. The CERCLA (Comprehensive Environmental Response Compensation and Liability Act also known as Superfund) action will be completed in the next month. The EPA 'viii also monitor the cover over the areas that they have closed and revegetated and will monitor groundwater until December 2000. WI?#AT'S NEXT?: The remaining issues at this facility include,but are not limited to: ▪ Long-tern: (up to 30 years) maintenance and care of the cover. This includes assuring that a cover crop is established and maintained. • institutional controls to prevent excavation or structures in areas where residual contamination remains. • Long-term (up to 30 years) groundwater monitoring to demonstrate the quality of groundwater downgradiant from the facility. • Financial assurance for post-closure monitoring, maintenance and care. Ideally,these issues will be addressed through authorities available to the County and the CDPHE in the Solid Waste Act. In the event these issues cannot be addressed through these means, the County and the CDPHE will have to re-assess our options. ATTAC€€MENTS: Attached i= the memorandum that I provided to you last year. It provides information regarding the background of the facility, the EPA Order, and the CERCLA action. tj/wcwd/2000update 2000-0457 /t z//-' t: 0 . ft fc' MEMORANDUM TO: Weld County Commissioners DATE: rry 24, 1999 FROM: Trevor Jiricek, Health Departmen a COLORADO SUBJECT: Weld County Waste Disposal Our Department is recommending for a continuance for a period of one year for this Probable/Show Cause hearing involving the Weld County Waste Disposal. The characterization, remediation, and clean up of the site continues. The one year continuance will allow for further progress. Our Department has been following all of the activities and progress which has taken place at the Weld County Waste Disposal. BACKGROUND: The following is a very brief history and update of the activities that have taken place at the Weld County Waste Disposal (WCWD) and a summary of the status of the E.P.A. order: In the spring of 1995 our Department and the Weld County Planning Department had cited the WCWD for numerous violations of its Special Use Permit. As the result of these violations, the facility was in the County's Probable/Show Cause process. However, in May 1995, under the authority of Section 7003 of the Resource Conservation and Recovery Act, the Environmental Protection Agency issued an Order "to abate an imminent and substantial endangerment to health or environment..." to the Weld County Waste Disposal, owned by Howard Duckworth. The Order alleged that a groundwater impact had occurred which was attributed to the facility and that waterfowl had been killed as the result of landing on the oily surfaces of the ponds. The Order was also issued to the two companies which had disposed the largest quantity of waste at the facility. These two companies, Amoco Production Company (Amoco) and HS Resources Inc. (HSR), have since taken the lead in implementing the Order. The WCWD is located approximately 5 miles east of Fort Lupton. It had been in operation since the 1970's and primarily accepted liquid exploration and production waste for disposal by evaporation. The site consisted of a receiving sump where liquid waste was initially dumped upon receipt at the facility. The waste was then pumped into on-site tanks where any reclaimable oil was separated out. The waste was then discharged into two large ponds for evaporation. EPA ORDER: The Order and its requirements are broken up into several major sections. The three sections specifically dealing with site characterization and remediation are briefly summarized below. Weld County Waste Disposal February 24, 1999 Page 2 They are: I. INTERIM MEASURES - This required the respondents to submit an "Interim Measure Work Plan" which included, but was not limited to the installation of a security fence, posting of signs, a method to permanently eliminate any oily surfaces which may come into contact with wildlife, characterization of the extent of off-site ground water contamination, etc. This section also addressed immediate remediation of any impact to human health and the environment. Status: The interim measures are finalized. II. SITE CHARACTERIZATION - This required the respondents to submit a "Characterization Work Plan" to characterize the magnitude and full extent, both vertical and horizontal, of all contamination of soils and groundwater on and from the receiving facility and to assess the physical integrity of all waste management units and devices. Status: The on-site soils have been characterized. However, the off-site groundwater characterization work plan has not yet been approved by the E.P.A. Additional off-site groundwater characterization may still be required. III. SITE CLEAN-UP - This requires that the respondents submit a "Clean-Up Work Plan" which evaluates alternatives for the treatment and disposition of all contaminated media, including contaminated soils, ground water and other materials and debris. Status: An on-site closure work plan has been submitted and is currently under review. In general, for each major section, the respondents must submit a plan in accordance with strict submittal dates. The plans are reviewed by the County and State Health Departments, and the E.P.A. In addition, the respondents were required to develop a community involvement plan. This plan has been developed and implemented to the satisfaction of all of the Agencies. It included surveys, newsletters, and public meetings for interested parties. Other routine activities required by the Order include monthly progress reports to the agencies and the submittal of quarterly groundwater monitoring reports. CERCLA (Comprehensive Environmental Response Compensation and Liability Act also known as Superfund) REMOVAL ACTION: During characterization of the site, chlorinated compounds were detected in the soils beneath pond D (see attached site layout) and in the groundwater downgradient from the facility. Many Weld County Waste Disposal February 24, 1999 Page 3 of these same chlorinated compounds were also found in the groundwater downgradient from pond D. Chlorinated compounds are not typically found in exploration and production wastes. In reviewing historical aerial pictures taken of the site, HSR and Amoco discovered an older waste pond, now known as pond E (see attached photographs), that existed in the location (within the perimeter of pond D) where the chlorinated compounds were discovered. Waste was disposed in Pond E from approximately 1978 to 1980. It was then covered with soil. Pond D was constructed in approximately 1981, and operated until the facility closed in May 1995. Chlorinated compounds were also found in the area identified as the "former receiving area". This receiving area operated from approximately 1978 to 1984. Following detection of the chlorinated compounds and after review of the aerial photos, HS Resources and Amoco argued that they should not be responsible for the remediation of the impact from the chlorinated compounds as they did not dispose waste at the facility during the time period that pond E and the "former receiving area" were operated. They also argued that the chlorinated compounds are not typically found in exploration and production wastes. EPA agreed not to pursue the Order requirements at these areas at these times. However, the EPA was also of the opinion that the contaminated materials in pond E should be addressed in a timely fashion. As a result, EPA contacted their emergency response staff EPA assessed the site by collecting samples, etc. and found that the site warranted action under CERCLA. EPA determined that the site was appropriate for a non-time critical removal of the waste material. Currently, this removal action is scheduled for early April 1999. The removal action will consist of excavation of the soil and thermal treatment in a thermal desorption unit. Once treated the soil will be returned to the excavation. Treatment of the impacted soil should eliminate the source of the impact to the groundwater. However, additional remedial actions are currently being considered for groundwater emanating from the site. It should be noted that the EPA is only addressing those impacts from the chlorinated wastes disposed at the facility. HSR and Amoco will continue to address all other portions of the Order and clean up of the site. tj\1186 e r e f s � • ,%--•r01-v,.7 i xN" , y f uT' #0. v k /raw rf a sJ xx -tikto925?-', �'s , r pm�y cf.13 j4+.„e 7"r fW,..5 vJt r• 14,,,i,,,...).-:•;44.7,5:' t r '.^ ..a m .�+ S m. a}-' ,, y.F4 n� ` v.,ii404'' � « k tr'}° .,. 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' ," �, y,- 414ic�//7A,,, `*L,�w' 'GIs ry ,57, -,, � ' ,� ,w" ,',y,a: w' in.= µxµ r q°44 i yrr Y� 5. p r '3ry ?� 'IC., �a' v i Y '& *5 x4 fJ w, Yr �ar'Aki Sav,itS l v , `, ` . ; . 1.2 44iiN w j 7Jq 44kei`th 1 a �' '‘:Y,7',1::'''. ,.ti r"`r"` i R,%f 1 .4; -,],,,,N Tr,In �1 0 1'3r,.v j� •f a. ✓"r v 11 f�^*° x 1m1,,, : 4IMWNY '' 3^Y'' r .. .lb. S ". ,/„�"�.� "S�r ., wykn u..." ,. �� ,. . w.;aFMw< m"+AM, ;"`T d:d --:-__• Figure A-2 z,.;. Aerial Photograph October 1978 Weld County Waste Disposal Inc. Site 4..............m , i Ft. Lupton, Colorado I Forme- -- Recievin c Pond ,::4_41(41, . , Former Pond B £ ; + . i S4 , Drfir"'�Tt*.l� t, P +fi.. r + 0SX �t m T' fr pr� N9 y .i r .,+o-,C: j' #�� Former Pond E r' n.. , r , „ . ,`. Speer Canal ..,„§:74:::: ; crV ,k ; { P Y' ftri y. 1,..::: ” --°-'47.4‘.C,r, {1LYa 4 'b'tc 1 I rtt f .' � {wv1 `i An $t Ar' 't-'-' -' - - 2 y`x - ¢ -49,,,,t--.. ti �� '�y :e S�• ] '�+r Vin. ! h> r ar 5~ ... VAS h4 .. Ar.. wH'YyY+,+,A(.u`}„�' .yh.'r,ig.�4. ,. Figure A-3 ;s' ' :,;,) Aerial Photograph May 1979 �� J Weld County Waste Disposal Inc. Site Ft. Lupton, Colorado M 11 Former Recievino Pond - Former Pond B T li T . t v ate,, ty34, j /Ka F+ ..u.1 RR4 MGM.. s Pond A tY-r✓. uk tit -,Low Area -, Speer Canal b ' e^` 4 M t q J h �hw e 4 titL'Y /t( yy Mr �� �>' r'4 saW� �zh�.Ylti 3�i3r w �^ro. ....2,ew }'c?+2. "°. idv tnc S_. Vb,:a+ ;:,,/,‘;',..,,,,,.„,7,,. 3,�,� .e4(7fii 7 a at+�l x �e� r t , +.YrowM ...., . r �.+.. `�a�7'?'^.i. "z a ,..,‘,1O,..,:-.,.; •.+M�'ut w,+e,.. ' .^•u.. AiG... . . .. ..SJm a _ __ Aerial Photograph Figure A-4 7 s:': -... October 1979 j) Weld County Waste Disposal Inc. Site Ft. Lupton, Colorado FForn,er - Recieving Pond -11:.-' :ewt . J Former Pond B � >-77b s ,-... - r pcs,ra r. el'e Low Areas, : u 5 7l ' Speer Canal I.. c .m -g a r ''' . F W -._r..♦ fit: rF'..,... vp = 5 O h ^.X S i .. . 'zee ,et ss•bra 3, _.A�`,zta-iz."-4=sIC...c1Oi7 -,. - - sFy '.3)': x, 'T..i- ?i?_ Figure A-5 ,a:f:ss::ssi ,r,.\ Aerial Photograph June 1980 1\ )/ Weld County Waste Disposal Inc. Site :'/ Ft. Lupton, Colorado.....r.. ! f..f . ....,:se '.... h Former Recieving Pond +r' 4ir ykA '+4r. c . .. 07 m Former Pond B na+'�`�;',,,'✓.,�. •,' ' t .d. Y '�' tg$ • s ' > . aL �, 5 l i < /ir>' , .0 'p�j 3 41,:1-41'P l / ..[s'wt' =u� Pond A { �`l lj .. s )l y ?f ^ elf: . ¶4* ate P;;;PC.:4:; ,../�ti. N ; < Yli, .:...-‹..fl" .;.4:% l'l l t.f; jn/l "'.';G J<. i ti Pond Din Speer Canal ., cd rr 4.4.--74`r,t;F 1 .. - • N - - e sp _„�'+�j� i 4 „t-,(..44:94?!. f-1s, cc R-� w agct 5 x '";"»',��..r F . r4 ' j y '}ax''''''';')4'1';',1: kk} c �� � tatttca »4 t "�' ++a.y. .r.'7%#,*� e„:.�M t ff s +Sfamn .,.4t 'rf'n *g'4 ax > 4 .', <t'ak c x" " t t 4.5{4•44.:::1 ° { :” ri t't; x in -h rt+* r:x . Ty'•� ` ��a� - ,.ry , Y`s. ''`, a`g+�*r'c- "r. ....ssn ;v_.+.dni��...... -r„+�d a. d� e a'�c m Figure A-6 .: % • photograph 1982 s ' Weld CountyAerial Waste Disposal October Inc. Site Ft. Lupton, Colorado ex Former Recieving Pond r R s f-, `•y " {z7/41.7.,•744. Former Pond B Area '' 'fn'r ' 5 * z Pond C ' ., , • rws; " ,. f " `! �gnyY ,� e3i . �h , tl pdt pry. 4`.a.: i Pond A _ - y g pry .rte. 4d a.�. , 'f` AgA.T 6 ' ,. ` ''t Pond D Speer Canal 4, •A • iis� lr r t ₹`r Te g ".4 7 � ..�.S � i— !c�. CC:i3�'�1FI� ''..-g",‘47 � r 1r T'hn i .. ?J'dM:.2: .wvv�.. .. _...n...... . � +.vAulu u.nW...- .�+rv.A... .......LYw+e,.. _ _ Figure A-7 Aerial Photograph October 1983 * . �i7 Weld County Waste Disposal Inc. Site Ft. Lupton, Colorado 1 Former Recieving Pond Area ' `',`, te;:t),4--,... s r1, ro�A1.uc 44" W a f_' GV.G '� cY i' �'i.. ^'r ."4-44 "11; 4244 f l^9• 4 Former Pond B Area px Pond C .,. .4 .yII 3 ::-..".42......,:,....-..-:.:%44-"7.-z-, Js tf' iyi'A1' rtar _ Yr- -^rte f � Ji."' c f yda. : 744 L.,4,44 rm. t .:1;•. - tr _ 44 vf.G.w., f• ^f ice. 4.`-''' ' �Y0.' f"r y J.j4A 44 ia4 ^"^' +I iM l+\/ Ski .c/ y _ 5k,14 raf4,�"..a` ` F: >rzt.' irk Pond Dx. -Speer Canal 4�.•,..Q.•µii y et n 4 �� ��rYy.Yt. o}Vr s •-(42• Pi. T s 4u �P ' " N Figure A-8 Aerial Photograph November 1984 � AjW Weld County Waste Disposal Inc. Site Ft. Lupton, Colorado / I 1, ___,,_________ I _ — —_......._ -----------'-77:-::-.''u `:.:--^,'/"----'s.��tilji�lTY;-_R0Af3-,-.1.2. "` - _ ..-._._.. . .2.:.,-,-,.-.....,....1 --.........-so iII �� ROAD.. ___ _____( i I ?!....--,.--1' .'11) REC VING ARE 98C u11cr8J IC0NCR SUMP ■ I — I ozst 1 P Sp4O',N-1,....„)..\ w 1983 I ., j a 74 l f I . 1983 / `n I 19E7` ----y-Ct t983-(0 y- I 1928 � / 5� 1----,.. lir,5Q°J o 71 , I ii I:,, i V\\\. `1 r , II'..,7' 1 �, sus O_ O - - - - -- I- - O - I -� { N i 1 i Jr _, �- I / •tl / ..-"'''..-------- ‘( A,,,,%.L_________T.... \ windmill 1 \5069 { SA . So BORROW PIT O\ I 5060-----., . \ ' I .\.. \ 0 100 200 300 MICOOMSSMUSSM \ LEGEND FIGURE 1 cwear HS RESOURCES/AMOCO 1978-1983 ACTIVE PONDS 1978 EXISTING PONDS 1979 EXISTING PONDS COLORADO AERIAL WELD COUNTY 1980 EXISTING PONDS PHOTO SERVICE 1982 EXISTING PONDS AERIAL PHOTOSURVEYS WASTE DISPOSAL, INC. SITE 1983 EXISTING PONDS Sovice: 1976-1995 WELD COUNTY, COLORADO ---- WATER PONDING AREA Locat,aa:WELD COUNTY, COLORADO ,���,,��••��T�*T+�T Scab: 1" = 300 FEET ��! �VI ON1V1ENTAL,INC. NSR96120 Dare: MAY 1996 Compliance•Risk Analysis•Rerncdiation / II I .. 5080 i i if/ _.,...9 l 0 ..:-� C-b�IiNTY B�2 IT. -.--- VII ROA 1 19..4 % - - ...--- __.----:-----:-----'7- r I 1 \ - ( / \ , i ' / R£CI •-• , NG ARE 19977 `� 1 ■ CONCR iLSUM - r" I I I 5O4� c 1 v 0 J ii • 1 I/ .1 \C',. ! j 1984 \ inl to / / 7/ ..,:c. 1986 1984 /' / 4 - .. '/ - --- ,_ „, ,, .. 0 I CX 7 /• I . ii---7.,, • /„______, , .,/,./4j 0 ,_ !- I / J ,, ,,, I at %:( 611 ( 1 \, 7----___________ ‘ / •----. ---,...,, -. 1 \ 1 / \ mii 5069 I SPEER.'SfANAL: ` sow BORROW PIT •---O i 5060 I ` o 100 200 300 1 I LEGEND FIGURE 2 - 1984 EXISTING PONDS Cliem: HS RESOURCES/AMOCO 1986 EXISTING PONDS 1984-1987 ACTIVE PONDS - 1987 EXISTING PONDS COLORADO AERIAL WELD COUNTY PHOTO SERVICE AERIAL PHOTOSURVEYS WAS-.-E DISPOSAL, INC. SITE smece. 1976-1995 WELD COUNTY, COLOF ADO Location.WELD COLINIY, COLORADO Scale: 1" = 300 FEET ENVIRONMENTAL,INC. HSR96120 oa. MAY 1996 Compliance•Risk Analysis•Renmcdialicn r 1 _v� _.. ���- 5080 IJ (��J ,r ' Qt NfY, R 2 f ! ROAD -� I r / 1 `-;-- .-----"" ' 1 . -119951 0 I R.--1 REC VING AREt, 11 989 199 3 \ I CONCRiri SUM I' 111990 1994 1992 rn' • ‘I19911995 1993 1994 1995 1 5040 ` ,L m 1988 ` �� tT ro I:: r r J- rcii...........) Nt I1993 MI , Q� Ir t989 19Q / a I+fI _ 1988 /j bolo f �i� 1 7.." o4t r (// \�� z4 I . .. 0'.i 'I 1992 ? _. I, .�--� U .r•i I • t 993 I! I. Y 1995 I « r . \ II l S ;, SO piSC-1-O-- -)\if"—--________ / N...., ."--‹.,..i. / f / • winelmill _ 5069 SP. E-�R -7. .0jp �B�0RR0W PIT V ANq� • • \ i 5060 • 0 100 200 300 I ' LEGEND FIGURE 3 1988 EXISTING PONDS Client: HS RESOURCES/AMOCO 1989 EXISTING PONDS .1988-1995 ACTIVE PONDS 1990 EXISTING PONDS COLORADO AERIAL 1991 EXISTING PONDS PHOTO SERVICE WELD COUNTY 1992 EXISTING PONDS AERIAL PHOTOSURVEYS WASTE DISPOSAL, INC. SITE 1993 EXISTING PONDS S,,,,ce; 1976-1995 -- 1994 EXISTING PONDS - WELD COUNTY, COLORADO ---- 1995 EXISTING PONDS Location:WELD COUNTY, COLORADO PONDS C AND D BASICALLY UNCHANGED 1992 THROUGH 1995 (FROM 1991 LEVELS) sere: 1' = 300 FEET ENVIRONMENTAL,INC. HSF196120 u,io: MAY 1996 Compliance•Risk Analysis•Reined iaiior) Hello