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DEPARTMENT OF PLANNING SERVICES ,
PHONE(303)353-3845, EXT.3540
WELD COUNTY ADMINISTRATIVE OFFICES
C. 1400 N.17TH AVENUE
GREELEY, COLORADO 80631
COLORADO
May 17, 1993
Patty Deplazes
Eastern Plains Environmental Services -
P.O. Box 142
Pierce, CO 80650
Subject: Installation of gauge rod to measure pond elevations, USR-540.
Dear Mrs. Deplazes: "'
Thank you for your letter of May 5. The Department of Planning Services Staff
has reviewed the information submitted for the installation of the gauge rods to
measure the elevations of the brine water in each pond. The staff has determined
that the proposed gauge height rods proposed could work, however, additional
information will need to be provided on installation, collaboration, and
anchoring of the devices. Please provide me with detailed information in writing
or in graphic form that shows the detailed installation. .
Please write me if you have any questions. _
Respectfully,
Itife
. Schuett
y
Current lanner
pc: SR-540
Trevor Jiricek, Weld County, Health Department
Ken Lind
R31ib
P 1.005g
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DEPARTMENT OF PLANNING SERVICES
PHONE(303)353-3845, EXT.3540
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WELD COUNTY ADMINISTRATIVE OFFICES
GREELEY, COLORADO N. RA AVENUE
140 ENU
COLORADO
May 12, 1993
Patty Deplazes
Eastern Plains Environmental Services
P.O. Box 142
Pierce, CO 80650
Subject: USR-540 -
Dear Mrs. Deplazes:
Thank you for your April 22 letter. The Department of Planning Services' staff
has reviewed your requests .for a temporary increase in volume of brine water
disposal, the installation of gun barrel skimming facilities, the temporary
reduction of time through the skim tanks, and processing incoming brine water
through pond C. The Staff has determined that these uses are a material
deviations from the plans and or standards as approved and would require the
approval of an amendment to USR-540.
Please write me if you have any questions.
Respectfully,
cues
Current Planner
pc: USR-540
Trevor Jiricek, Weld County Health Department
Ken Lind
rpm
\ DEPARTMENT OF HEALTH
1517-16 AVENUE COURT
W
ige GREELEY, COLORADO 80631
ADMINISTRATION (303)353-0586 HEALTH PROTECTION (303)353-0635
COMMUNITY HEALTH (303)353-0639
COLORADO
February 25, 1993
Certified Letter: P 186 978 297
Mike Cervi
Roggen Disposal, Inc.
P.O. Box 300397
Denver, Colorado 80203
Dear Mr. Cervi:
The Environmental Protection Division of the Weld County Health Department is in
receipt of Ms. Deplazes letter of February 23, 1993, in which it is indicated
that the Roggen Disposal facility will be inaccessible for monitoring well
sampling, February 25, 1993.
As you are aware, Section 2.3.1 of the "Regulations Pertaining to Solid Waste
Disposal Sites and Facilities" states "facilities for solid wastes disposal may
be inspected by the department. . . .no prior notification of said inspection shall
be required" and Development Standard #17 of USR-481:81:27 which states "Weld
County Health Department staff shall be granted access onto the site at any
reasonable time. . . ." This Division feels that the previously proposed February
25, 1993, sampling date was a reasonable time.
In response to your request, the Division will reschedule the proposed sampling
date to March 9, 1993. Failure to allow access onto the site on this date will
be considered a violation of the Solid Waste Act and USR-481:81:27.
If you have any questions, please contact me at (303) 353-0635.
Sincerely,
I✓n Iv?AJ Vi - .
Trevor Jirrice
Solid and Hazardous Waste Specialist
tj/390
cc: Roger Doak, Colorado Department of Health
Keith Schuett, Weld County Planning Department FEB 2 5
Patty Deplazes, Eastern Plains Environmental Service 1993
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.NELSON ENGINEERS
822 7TH STREET GREELEY,COLORADO 80631 (303)356-6362
•
February 10 , 1993
Mr. Ed Stoner -
Weld County Planning
1400 N. 17th Avenue
Greeley, CO 80631
RE: Weld County Building Permit #40207
WCR 54 E-Vap Park -
Dear Mr. Stoner: -
The excavating and grading to construct the fourth aeration pond - -
at- the subject site has been completed. Nelson Engineers
- provided construction observation and Empire Laboratories, Inc.
provided testing of soils for compaction and permeability.
The pond construction was completed in January 1993 in accordance
with the plans and specifications. If you have questions, please
contact me.
- Respectfully,
NELSON ENGINEERS
19,414a14111(41
-Lavern C; Nelson, P.E. _
Colorado Reg. No. 2683
cc: Mike Cervi -
� I1
I\ FEB 1 1 1993 U
97/1
rdialiEASTERN PLAINS ENVIRONMENTAL SERVICE
PATTY DEPLAZES Bus. (303) 454-3452
P.O. Box 142 Home (303) 897-2439
Pierce, CO 80650
•
May 5, 1993
•
Mr. Trevor Jiricek
•
Weld County Health Department �O�/
Environmental. Protection Service
1517 16th Ave Court / liff(4/17:/1 %/64/
Greeley, CO 80632 lU,/
/
Dear Mr. Jiricek -r®• RE: Northern Colorado Brine v°��� 'O4' T'/ di
OM fNs& Pcin1 dti
Northern Colorado Brine plans to immediately install gauge rods similar to the one .
approved on Pond 4 in the Ponds 1,2,3A and 3B. These rods will be calibrated using the 4/i
top of the six inch cement pad installed when the ponds were new, for support of the /P
aeration system, as a basis for measurement. Elevations will be measured 24" above the *Doc co,-
surface of the six inch cement pad and transferred to the gauge board on the bank to Cow 3/4,4
indicate the maximum,depth of water allowed. Because these pads were installed when p w",
the ponds were new they are not affected by any sedimentation or salt accumulation.
Please call if I may be of further assistance in this matter
Sincerely
---i-,•7(/zec:/74-dy. .
Patty DBplazes
cc Mike Cervi, NCB •
Keith Schuett, WCPD
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rai EASTERN PLAINS ENVIRONMENTAL SERVICE
PATTY DEPLAZES Bus. (303) 454-3452
P.O. Box 142 Home (303) 897-2439
Pierce, CO 80650
May, 5 1993
Mr. Keith Schuett
Weld County Department of Planning
Weld County Administration Building
1400 N 17th Avenue '
Greeley,CO 80632
Dear Mr. Schuett
� pow/me
RE: Northern Colorado Brine Nee/�DCQ,AO,
Northern Colorado Brine request approval to locate a 35' semi trailer on site for additional
storage of tools. This trailer will be anchored and building permits obtained as required
by county regulation.
Please call if I may be of further assistance in this matter.
Sincerely
Patty Dep azes .
cc Mike Cervi, NCB
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PAYANT/HICKMAN 303_ 454 3112 P. 01
EASTERN PLAINS ENVIRONMENTAL SERVICE
PATTY DEPLAZ&8 Bus. (303) 454-3452
P.O. Box 142
Pierce, CO 80650 HomM (303) 897-2439
PAX(805)4314171
COVER% SHEET
•
•
Transmitting from Fax 8(303) 454-3112
DATE: 4/x3/9-3 TIME:
Please Deliver The Following y Pages To:
NAME: l d��O.14.s-e��c
FIRM: U/0 dy
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FROM: PI
Total Number of Pages(/ g , Including This Page
Response Requested: Yes No
If you do not receive all pages, or have any problems with reception,
please call us back as soon as possible.
Additional Comments:
A , Tcy/P /y<nro lr
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APR 23 '93 13:24 303 454 3112 PAGE.001
PAYANT.,HICKMAN 303 .454 3112 P.02
__ EASTERN PLAINS ENVIRONMENTAL SERVICE
PATTY DEPLAZEB Bus. (303) 454-3452
P.O. Box 142 Home (303) 897-2439
Pierce, CO 80650
April 23, 1993
Mr. Keith Schuett
Weld County Planning Department
Weld County Administrative Offices
1400 N. 17th Avenue
Greeley, CO 80632
Dear Mr. Schuett,
RE: Northern Colorado Brine
Please note the following revision to the aeration system plan sutmitted
to your department on April 22, 1993.
A double layer of 6 mil plastic will be installed under the pump and down
the berm in such a manner that any water leaking from the pump will drain
back into the pond. The pond berm will be protected from erosion by the
plastic.
Also, all aeration/sprayer heads will be located at least fifty (50) feet
from the berm.
Please call if I may be of further assistance in this matter.
Sincerely,
Patty Deplazes
cc: Mike Cervi, NCB
Trevor Jiricek, WCID
APR 23 '93 13:25 303 454 3112, PAGE.002
PAYANT/HICKMAN 303 454 3112 P.01
Sah EASTERN PLAINS ENVIRONMENTAL SERVICE
PATTY DEPLAZES Bus. (303) 454-3459
P.O. Box 142 Eon (303) 897-2439
Pierce, CO 80650
. ' FAX(803)4SI-B1.15
COVER%BREST Sc!- 0975
•
•
Transmitting from Pax 8(303) 454-3112
DATE: 4/aVei TIME: 3•sa ®A
Please Deliver The�Q Following llA Pages To:
NAME• / e,�/ r3l:I7QCP
F I RM: 4'l ddb- �/ 9.11---X7 1 g /min?
FROM: Paa�1/.J 10 /.I 1 J EP/� S (J
6 �q �
Total Number of Pages 4- , Including This Page
Response Requested: Yes No
It you do not receive all pages, or have any problems with reception,
please call us back as soon as possible.
Additional Comments:
-- l!
PJ€ a.42- (LAA LI rna.{// „/.�-c—
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APR 22 '93 14:52 303 454 3112 PAGE.001
PAYANT. HICKMAN 303 454 3112 P. 02
r, EASTERN PLAINS ENVIRONMENTAL SERVICE
PATTY DEPLAZBS Bus. (303) 454-3452
P.O. Box 142 Home (303) 897-2439
Pierce, CO 80650
•
•
April 22, 1993
Mr. Keith Schuett
Weld County Planning Department
Weld County Administrative Offices
1400 17th Avenue North
Greeley, CO 60632
Dear Mr. Schuett,
Enclosed are the plans for the aeration system to be installed at Northern
Colorado Brine. It is similar to the system previously reviewed and
approved for installation at Weld County Disposal.
Northern Colorado Brine is making every effort to attain complete compliance
with USR - 540 prior to the hearing scheduled for May 19, 1993. The
installation of this system is in answer to the violations as stated by
Weld County Planning. A timely release of the building permits for the
aeration system will be greatly appreciated.
Please call if I may provide any additional information in this matter.
Sincerely,
Patty. laze &/r
cc: Mike Cervi, NCB
Trevor Jiricek, WCHD
APR 22 '93 14:53 303 454 3112 PAGE.002
PAYANT/HICKMAN 303 454 3112 P. 03
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PAYANT,HICKMAN 303 454 3112 P.04
_G��EASTERN PLAINS ENVIRONMENTAL SERVICE
PATTY DEPLAZEB Bus. (303) 454-3452
P.O. Box 142 Home (303) 897-2439
Pierce, CO 80650
•
NORTHERN COLORADO BRINE - AERATION SYSTEM
This aeration system will consist of two (2) lines on each of Pond 1
and Pond 4 , running in an east-west direction. Each line on Pond 1
will be approximately 403 feet in length, with aeration/sprayer heads
approximately 22.5 feet apart. All aeration/sprayer heads will be
at least 75 feet from the berm.
The systems will be powered by 100 horsepower motors, using pumps rated
at 200 gallons per minute at 50 psi.
The pumps will be located'on the west side of the ponds. Each pump will
be placed on a concrete pad, edged and sloped to assure that any water
leaking from the pump will drain into the pond. The berm of the pond will
be protected from erosion from water draining into the pond.
The manifold connections will be of a flexible material approved for
outdoor use.
The aeration system will operated at all times in such a manner as to
assure that the spray stays within the berm of the pond. The pressure
and height of the spray will be reduced under wind conditions in excess of
20 mph to assure that no off-site contamination occurs.
APR 22 '93 14:54 303 454 3112 PAGE.004
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M/ 540
EASTERN PLAINS ENVIRONMENTAL SERVICE
PATTY DEPLAZES Bus. (303) 454-3452
P.O. Box 142 Home (303) 897-2439n
Pierce, CO 80650 �/1-°1/1
•
I'
April 22, 1993
Mr. Keith Schuett
. Weld County Department of Planning
Weld County Administration_ Building
140O N 17th Avenue
Greeley, CO 80632
Dear Mr. Schuett
RE: Northern Colorado Brine
Northern Colorado Brine has operated within the permit requirements of 2000 bbllday and
24 hours retention time since April 15,1993. /War LI`s1/6&
However, due to the urgent demand of brine disposal NCB hereby-rears—temporary)
approval't'o'increase"disposatto 10;000 bb1.per dire. ‘Irraddition,_NCB proposes;to_install(
`additional gun barrel skimming facilities to better skim-the=incoming-brine_and to reduce-
todors-caused-by-oil-and_condensation on=the-pon_ds
b.
The temporary-increase:is-requested_for a period oft24mmonths? to provide adequate
disposal of the brine produced during the temporary increase in drilling currently taking
place in Weld County.
With increased levels of disposal at NCB, retention times through the skim tanks will be
reduced. However, testing performed by Cenref Labs of Brighton indicate that 96-99%
of the oil in the brine is removed with 6-8 hours of retention time through the skim tanks.
Northern Colorado Brine is now processing all incoming brine through Pond C, prior to
release into any other pond. NCB proposes that Pond,C will be permanently boomed to
contain any residual oil, and a regular skimming schedule will be implemented as needed.
This will provide an effective and satisfactory solution to the reduced retention time
caused by the temporary increase in disposal at NCB.
Northern Colorado Brine does not consider this temporary increase to be a major change
from the original USR-540.
{ MAY 0 5 1993 [II
Because the need for disposal is urgent, please review and provide your response as
soon as possible. Call if I may provide any additional information on this matter.
Sincerely
Patty Deplazes
cc Mike Cervi, NCB .
Trevor Jiricek, WCHD
MAY
051995;IA
- J ` —"z 91anlinr
( t‘
DEPARTMENT 0 HEALTH
ti 1517-16 AVENUE COURT
I I GREELEY, COLORADO 80631
' APR 1 6 1993 U ADMINISTRATION(303)353-0586
HEALTH PROTECTION(303)353-0635
C °8%!r^'°t Rennin,- COMMUNITY HEALTH(303)353-0639
•
COLORADO
April 15, 1993
Patty Deplazes
Eastern Plains Environmental Service
P.O. Box 142
Pierce, Colorado 80650
Dear Ms. Deplazes:
The Environmental Protection Division of the Weld County Health Department has
completed the review of the April 14, 1993 proposal, in which Northern Colorado
Brine submitted a remediation plan, regarding the April 13, 1993, soil
contamination at this facility.
The Division in its review finds the plan to be inadequate, specifically in
regard to the mode of disposal of the contaminated soil. The proposal requested
that the soil be disposed by ". . . .placing it inside the berm of the pond." As
you know, this facility has not been approved to accept this waste stream. The
contaminated soil on site must be removed and disposed in an approved sanitary
landfill. Please notify this Division when the removal has been completed, so
that the affected area may be inspected.
If you have any questions, please contact me at (303) 353-0635.
Sincerely, • •
Italkil9Wat
Trevor Jiricek
Solid & Hazardous Waste Specialist
/tj-687
cc: Mike Cervi, Northern Colorado Brine
Keith Schuett, Weld County Planning Department
Lee Morrison, Weld County Assistant Attorney
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") DEPARTMENT OF HEALTH
1517.16 AVENUE COURT
APR 1 6 1993 IP IGREELEY, COLORADO 80631
"Hip
C ',TWO l�°^^+NV PS8n11i1!^ LDMINISTECTION (303)353-0635
O HEALTH PROTECTION (303)353-0635
COMMUNITY HEALTH (303)353.0639
April 15, 1993
COLORADO
Mike Cervi
Northern Colorado Brine
P.O. Box 169
Sterling, Colorado 80751
Dear Mr: Cervi: - -
On April 14, 1993, a representative of the Environmental Protection Division of .
the Weld County Health Department inspected Northern Colorado Brine, Inc. ,
located at 10600 Weld County Road 54, Milliken, Weld County, Colorado. The
purpose of the inspection was to observe the sprinkler aeration device which was
installed and operated on site.
It has been determined that the installation and use of this device has not been
approved as a part of the Design and Operation Plan for the facility. This
constitutes a violation of the Solid Waste Disposal Sites and Facilities Act,
specifically Section 30-20-103, as well as a violation of U.S.R.-540:83:3,
Operation Standard #1, which states:
The use shall be an oil and gas brine water disposal and oil
recovery facility as described in the submitted application
materials. No hazardous wastes or non-hazardous industrial waste
shall be allowed at the site. The facility shall be designed,
constructed and operated to comply with the Colorado Department of
Health Solid Wastes Disposal Sites and Facilities Act, Title 30-20,
Part 1, C.R.S. 1973, as amended.
This facility must cease operation of such equipment until written approval has
been obtained from the Weld County Health Department and the Colorado Department
of Health.
If you have any questions, please contact me at (303) 353-0635.
Sincerely •
9t11)4°
Trevor Jiricek
Solid & Hazardous Waste Specialist
/tj-686
cc: Patty Deplazes, Eastern Plains Environmental- Service
Lee Morrison, Weld County Assistant Attorney
Roger Doak, Colorado Department of Health
Keith Schuett, Weld County Planning Department
a
{ r STATE OF COLORADO
dOLORADO DEPARTMENT OF HEALTH 4:°F:ep
,Del{{icated to protecting and improving the health and �•j
rnvi onment of the people of Colorado • : G9
•
4300 Cherry Creek Dr.S. Laboratory Building •re�e
Denver,Colorado 80222-1530 4210 E.11th Avenue
Phone(303)692-2000 Denver,Colorado 80220-3716
(303)691-4700 Roy
Romer
Governor
March 18, 1993 CERTIFIED # P 860 418 207 Patdda A Nolan,MD,MPH
Executive Director
Mike Cervi
Roggen Disposal . ,
P.O. Box 300397 r J
Denver, Colorado 80203 1 MAR 2 2 1993 I
31.�_.
RE: Roggen Disposal t J
Weld County, Colorado
Dear Mr. Cervi:
The Weld County Health Department (WCHD)has requested that the Hazardous Materials
and Waste Management Division of the Colorado Department of Health (the Division)
review ground water data from Roggen Disposal to determine if ground water is being
impaired by this facility. All information and data were reviewed under the authority of the
Solid Wastes Disposal Sites and Facilities Act, Title 30, Article 20, Part 1, C.R.S. as
amended and with the regulations promulgated thereunder 6 CCR 1007-2(the Regulations).
Based on the review of the ground water data and facility files the Division has the following
comments:
1. Interwell comparison of ground water data clearly shows significate increases
in many parameters at the site. Section 6.1.4 of the Regulations states "sites
and facilities in operation prior to adoption of these regulations may be
— required to come into compliance with these regulations upon a-determination
that such sites and facilities are causing impairment to existing or future use
of surface water or groundwater." Based on ground water data submitted to
the Division by WCHD and information contained within the files it appears
that this site is causing impairment of the ground water. The Division
requests that a detailed geologic and hydrologic characterization of the site
be prepared, and a comprehensive document which addresses these issues be
sent to this Division for review. This document shall discuss both local and
regional geologic units, geologic structures, geologic hazards, and
identification of the upper most aquifer t s characteristics (ie. depth to aquifer,
hydrologic properties, aquifer use, and water quality).
r
. Mike Cervi
Roggen Disposal
March 18, 1993
Page 2/3
2. Section 2.23 of the Regulations states that a statistical evaluation shall be
utilized to assist in determining if ground water contamination exists. Please
provide this information.
3. Please provide an accurate, and readable site map. This map should include
at a minimum; the location off all impoundments both active and inactive,
facility structures and roads, location of all surface water features and location
of all ground water monitoring points (both abandoned and active).
4. Is ground water monitoring well 4A still used for sampling? If not, provide
information detailing when and why this well was abandoned.
5. Were is well #6 located?
6. Analytical data is missing from monitoring wells 3, 4A, 4B and 6 for several
of the 1991 and 1992 sampling events. Please clarify.
7. Please provide the following information on all ground water monitoring
wells; total depth of the well, depth to ground water, screened interval of each
well, and position of the well in relationship to ground water flow direction
(ie. upgradient, downgradient or crossgradient).
. 8. Section 6.8.8 of the Regulations requires clay or soil liner material to be
tested for permeability at intervals of not more than five (5) years. The
Division's files indicate the last leak test was performed in 1988. If
additional permeability tests for the impoundment liners have been
- -
completed, please provide this documentation to the Division. Data
contained in a letter dated November 25, 1992 form Nelson Engineering to
the Division estimates the permeability for pond B. Estimated permeabilities
are not acceptable. If a leak test has not been performed at this facility since
1988, provide a schedule when these tests will be completed.
9. Please provide a map which shows all ground water wells within a one mile
radius of this facility. The following information on these wells shall be
included: year the well was drilled, drillers log, total depth, depth to ground
water, well yield, well use, screened interval, aquifer in which the well is
completed, and all geologic units encountered during drilling.
..
Mike Cervi
Roggen Disposal
March 18, 1993
Page 3/3
10. Based on the poor management history of this facility and the apparent
impairment of the ground water at this site, the Division requests that volatile
organic compounds (VOCs) be included in ground water sample analyses.
VOCs shall be monitored for four (4) consecutive quarters starting with the
next ground water sampling event. The Division may reevaluate the
frequency and necessity of VOC analysis after reviewing the four quarters of
ground water data.
These conclude the Division's comments concerning Roggen Disposal. Please respond to
the issues detailed above in a comprehensive document within thirty (30) days of the receipt
of this letter. If you have any questions please contact me at 303-692-3437.
Sincerel
Roger Doak enn F. Mallory
Geologist ection Leader
Solid Waste Section Solid Waste Section
Hazardous Materials and Hazardous Materials and
Management Division Waste Management Division
cc: cJrPickle Weld County Health Department
_ L. Perrault, AG Office
File: SW/WLD/ROG/#3 Monitoring
6'e; ciellic-Th\ DEPARTMENT OF HEALTH
1517-16 AVENUE COURT
C
GREELEY, COLORADO 80631 ADMINISTRATION (303)353-0586
® HEALTH PROTECTION (303)353.0635
COMMUNITY HEALTH (303)353-0639
COLORADO
February 25, 1993
Certified Letter: P 186 978 297
Mike Cervi
Roggen Disposal, Inc.
P.O. Box 300397
Denver, Colorado 80203
Dear Mr. Cervi:
The Environmental Protection Division of the Weld County Health Department is in
receipt of Ms. Deplazes letter of February 23, 1993, in which it is indicated
that the Roggen Disposal facility will be inaccessible for monitoring well
sampling, February 25, 1993.
As you are aware, Section 2.3.1 of the "Regulations Pertaining to Solid Waste
Disposal Sites and Facilities" states "facilities for solid wastes disposal may
be inspected by the department. . . .no prior notification of said inspection shall
be required" and Development Standard #17 of USR-481:81:27 which states "Weld
County Health Department staff shall be granted access onto the site at any
reasonable time. . . ." This Division feels that the previously proposed February
25, 1993, sampling date was a reasonable time.
In response to your request, the Division will reschedule the proposed sampling
date to March 9, 1993. Failure to allow access onto the site on this date will
be considered a violation of the Solid Waste Act and USR-481:81:27.
If you have any questions, please contact me at (303) 353-0635.
Sincerely,
/JLLI/G',./ L t
Trevor Jirice
Solid and Hazardous Waste Specialist
tj/390
cv
cc: Roger Doak, Colorado Department of Health 7
Keith Schuett, Weld County Planning Department FEB 2 5 1993 II
Patty Deplazes, Eastern Plains Environmental Service
nP-. 1 b+..._o-.
h)wrorgd�„
•
NELSON ENGINEERS
822 7TH STREET GREELEY,COLORADO 80631 (303)356-6362 - -
February 10, 1993
Mr. Ed Stoner -
Weld County Planning
1400 N. 17th Avenue.
Greeley, CO 80631
RE: Weld County Building Permit #40207
WCR 54 E-Vap Park
Dear Mr. Stoner:
The excavating and grading to construct the fourth aeration pond
at the subject site has been completed.. Nelson Engineers
- provided construction observation and Empire Laboratories, Inc.
provided testing of soils for compaction and permeability.
_ The pond construction was completed in January 1993 in accordance
with the plans and specifications. If you have questions, please
contact me.
Respectfully, - -
NELSON ENGINEERS
LaVern C; Nelson, P.E.
Colorado Reg. No. 2683 .
cc: Mike _Cervi -
FEB 1 1 1993 ' U
II
',RAJ•e.....2_.negmrArto•
•
t. 4.
G' •
`e •
EASTERN PLAINS ENVIRONMENTAL SERVICE •
:350 OAK AVENUE,, SUITE 1 40 •
PO BOX 446 - '
EATON, CO 80615 •
_0 -L(4-^0E;E
September 25, 199: •• - - Fir.": . i�.ai.-,t.h °Schueti.`. •.. -`- '
' - --...
Weld. County .Planning. Department ' -
Weld County Administrative Building - ' -
1 400 N. 17th Avenue
Greeley, CO 8O631 '
Dear Mr . Schuett,.
RE: Northern Colorado Brine
Northern Colorado Brine' requests approval to construct a shelter
building over the two-stage heater treater and sludge tank • -,
previously approved at the sita. The purpose of the building is •
to prote r t the equipment from the weather . The proposed building
will •be approximately 54' s<: 96' , with 10 footsi.dewal7.s . The • - .
building will be a pole structure with a steel skin and a dirt
floor . The building will have two large sliding doors, and two '
walk through doors . There will be no electrical or plumbing
inside the building. The propane burner for the first stage of
the heater treater and the chemi cal storage and pumps will al 1
be located outside the building ,
Please call if I may provide any additional information or answer
any questions regarding this matter . I may be reached at
.4547:3.08S . - •
,
Sincerely, •
.6::;,d&----ei- - .. • .
Patty epl«..es, , ='E
•
cc : Mike C e r v i. , NCB _R _
SEP 3 01993
Wald C un1 PIannJo9
e
t.
LIND, LAWRENCE & OTTENHOFF
ATTORNEYS AT LAW SEP 3 u^ 1993
THE LAW BUILDING ��i�.9
1011 ELEVENTH AVENUE 'ii Pec BBRA
P.O. BOX 326
GREELEY, COLORADO 80632
GEORGE H. OTTENHOFF TELEPHONE
KENNETH F. LIND (303) 353-2323
KIM IL LAWRENCE September 28, 1993 (303) 356-9160
TELECOPIER
JEFFREY R. BURNS (303) 356-1111
Weld County Department of Planning Services
1400 North 17th Avenue
Greeley, CO 80631
Attention: Keith Schuett
Re: USR-540 (Northern Colorado Brine)
Dear Mr. Schuett :
This office is in receipt of your letter dated September 21,
1993 which contains three pages of proposed new operation
standards . As I discussed with you by telephone conversation on
September 20 , 1993 the Planning Department as well as' Health
Department continue to formulate and develop new operation
standards which are both improper, illogical and go far beyond the
resolutions of the Board of County Commissioners which determine
that the new equipment is a "minor change" and could be installed
subject only to review by the Planning and Health Department .
We have attempted to cooperate with you on a continual basis
even going to the extremely expensive and lengthy process of
submitting amended design and operation plans which were also not
required by the Board of County Commissioners . When I state that
you continue to add numerous requirements far beyond ' reason, I
would refer you to a letter- dated September 21, 1993 from Mr. Doak
with the Colorado Department of Health. His extensive review
resulted in only four comments whereas you have three pages .
Additionally, I would refer you to a memo dated August 27th from
Mr. Pickle to yourself which 'contained only eight recommended
conditions for approval, and I am sure that you remember that I
only had one minor change on those original eight conditions. Now,
you continue to heap new requirements and recommendations upon this
minor change and the volume and extent of your changes are
unacceptable.
In reviewing your proposed operation standards, we do find
some of them to be reasonable and acceptable . Specifically, we can
accept 1 (a) , (b) , (c) , (e) , (f) , (g) and (i) as written.
As to 1 (d) , the word "observe" is objectionable and not
acceptable. Please remember that we are only talking about brine
water and I am sure there is not .a single facility in Weld County
Weld County Department of Planning Services
September 28, 1993
Page 2
or industry that is required to continually "observe" every single
facet of operations . Having an employee stand and observe all
operations at the site is not reasonable, is a significant waste of
time and money and does not make sense. I have suggested to you
that the word "supervise" be substituted and we have no problem
- with our client supervising operations but to request an employee
to continually observe all disposal operations is far beyond
• reason.
As to proposed operation standard 1 (h) , the last sentence must
be deleted. Representatives of the district have 'inspected the
plans and facilities and have issued a letter to Mr. Stoner which
you have on file . You had originally requested Northern Colorado
Brine to have the plans inspected, this was done, but now you are
adding additional requirements which are unacceptable . Your
proposed operation standard removes authority from the Board of
County Commissioners and grants it to a district which is not
subject to any type of oversight or review and is thus
unacceptable . We have always worked with the district and have
incorporated many of their recommendations and suggestions into
operations at the site. However, requiring some type of
recommendation to be followed is not appropriate and, I would add,
it shifts potential legal liability to the district which I am sure
the district would not desire in any way.
Your proposed standards (j ) , (k) and (1) are also
inappropriate as they have nothing to do with installation and
operation of new equipment . We have provided to you radioactive
screening tests which have been performed at the site and you do
have those in your files. Your suggestions as to new indicators
are also not acceptable according to our client ' s engineers and, I
would add, that the existing indicators have been specifically
approved and are quite reliable . As to existing trees, we cannot
determine which, if any, trees are dead at this time and this also
goes beyond logic .
Our consultants have also advised us that your request to
screen all water at the site as you have proposed cannot be
accomplished. The site currently screens the water in accordance
with State Health Department regulations .
As your operation standards have nothing to do with the
installation and operation of the new equipment and are
unreasonable, we have no choice but to reject all of them at this
time . As your department was requested to review the plans, it is
your sole responsibility for any delay in operations that this may
cause at the site. Due to your unreasonable delay, response and
recommendations, our office will now inform the Colorado Air
Quality Control Commission that the compliance schedule cannot be
Weld County Department of Planning Services
September 28 , 1993
Page 3
followed due to actions of administrative officials with Weld
County. If you would like to revise your recommendations in
accordance with Mr. Pickle ' s August 27th memo, Mr. Doak' s letter of
September 21, 1993 and my comments, we would be pleased to again
review them. However, this review as contemplated has gone beyond
all reasonable standards and requirements and will result in
needless delay and expense .
Very truly yours,
LIND ENCE & T
K e h F.
KFL/cg
pc : Board of County Commissioners
Ed Stoner, Weld County Building Inspection
Trevor Jiricek, Weld County Health Department
Lee Morrison, Assistant County Attorney
Vern Nelson
Mike Cervi
Greg Hobbs
Patty DePlazes
•
it 1?(
tf.
DEPARTMENT OF PLANNING SERVICES
PHONE(303)353-3345, EXT. 3540
mei
WELD COUNTY ADMINISTRATIVE OFFICES
1400 N.17TH AVENUE
; ' 1",i ye GREELEY, COLORADO 80631
Vl'v4 j r M21�� Et: n
COLORADO
September 21, 1993
Mr. Kenneth F. Lind
Lind, Lawrence, and Ottenhoff
1011 Eleventh Avenue
P.O. Box 326
Greeley, CO 80632
Subject: USA-540 (Northern Colorado Brine) , located on part of the NE4 of
, Section 26, and part of the NW4 of Section 25, all in TSN, R67W of
the 6th P.M. , Weld County, Colorado.
Dear Mr. Lind:
•
Thank you for the information you provided our Department and the Weld County
health Department on the proposed water treatment equipment to be located at
Northern Colorado Brine. The information that was submitted for the design and
operation plan was reviewed by both Departments. The Department of Planning
Services' staff and the Health Department staff request that the following items
be incorporated into the Operation Standards for Special Review Permit #540.
1(a) . The use shall be an oil and gas brine water disposal, oil and gas
production water disposal, and oil recovery facility as described in
the submitted materials. Only brine water and production water
which occurs as the result of oil and gas exploration and production
shall be received for processing and disposal at this facility. No
hazardous wastes or non-hazardous industrial waste shall be allowed
at the site. The, facility shall be designed, constructed, and
operated to comply with the Solid Waste Disposal Sites and
Facilities Act, Title 30-20, .Part 1, CRS 1973, as amended.
1(b) . The facility shall abandon and remove all existing bubbler, misting
aeration systems no later than December 15, 1993, and not operate
nor install any aeration, bubbler, misting system or other type of
aeration system until the design and operation plan of such a system
is approved by the Weld County Planning and Health Departments and
the Solid Waste Division of the Colorado Department of Health.
Mr. Kenneth F. Lind
September 9, 1993
Page 2
1(c) . Permits and approvals if necessary must be obtained from the Water
Quality Control Division of the Colorado Department of Health or the
Colorado Oil and Gas Commission prior to discharging or removing any
processed water off-site.
1(d) . A responsible employee, trained to differentiate between brine water
and other fluids, shall observe all disposal opeiations.
1(e) . The disposal ponds on this facility shall be operated to maintain a
total pond depth, of five feet (30 inches of freeboard, 6 inches for
salt accumulation, and 24 inches for brine water) from the average
height of the pond liner. Any deviation from the approved freeboard
distance and pond depth must be approved by the Weld County Health '
and Planning Departments.
1(f) . The facility shall comply with the Stipulation and Agreement with
the Air Quality Control Commission signed July 30, 1993.
•
1(g) . The facility shall consist only of those features as described in
the submitted supplemental (El Toro Management Systems, Inc.)
materials.
1(h) . All plans for, construction on site shall be reviewed by the
Johnstown Fire and Rescue Protection District prior to the release
of building permits. Recommendations from the Johnstown Fire and
Rescue Protection District shall be followed to the greatest extent
possible.
1(i) . Other non-hazardous waste, such as underground storage tank water,
may be accepted at this facility on an individual basis only, if
written approval is given, for each load delivered, -by the Weld
County Health Department.
1(j) . The current gauge height indicators shall be replaced with permanent
height/freeboard indicators' as each pond is drained and prior to
allowing the ponds to be filled with water. The height/freeboard
indicators shall be constructed of concrete or metal. The permanent
height/freeboard indicators shall be accurately installed in
relation to the average height of the pond floor liner. The
indicator shall clearly show the height of water (6 inches for salt
accumulation and 24 inches for brine water) in relation to the top
average height of the pond liner and the 30 inches of freeboard. To
accomplish this, both the average depth ,of each pond and the
height/freeboard indicators shall be surveyed for accuracy. A copy
of the survey with benchmarks identified shall be provided to the
Department of Planning Services and the Weld County Health
Department.
ar
Mr. Kenneth-F: Lind "
September 9, 1993 . "
Page 3
1(k) Existing dead or dying evergreen and Russian Olive trees shall be
replaced within the 1993 fall planting season with substantially
similar kind to maintain the approved landscaping and shelter belt '
area. Dead or dying evergreen and Russian Olive trees shall be
replaced with substantially similar kind withinothe next planting
season to maintain the approved:landscaping and shelter,.belt-area. _ , .
1(1) .; ; The facility shall screen all 'water to;be disposed ofat 'the `site
, for radioactivity The ,method.to be,.incorporated•at the sitemust
'-7,-,(' - be, reviewed and ,approved` by;Weld County. Environmental Protection _;`
, Services and Weld County Planning. Department: If radioactive`water
is detected at the site, either the source of the- radioactive water "
Will be identified and barred from using the site or applications,
• will be made to allow the site to handle the radioactive water.
Prior to the release of building permits for the new- equipment designed by El- .
. Toro Management System, Inc. , written evidence '•shall be provided to the_
Department of Planning Services that,the above conditions and operation standards,.. .,
have beentincorporated .into the Conditions of Approval and=Operation Standards
.r
for ,SpecialReview, Permit #540
Please call or write me if you.have; any• questions:.
Sincerely, '
u t%t""
urrent Planner
pc:-�,�.'. Board of County Commissioners,:-.*-- , -, } -'
,:'Ed:Stoner, Weld County Building Inspection
Trevor Jiricek, Weld County Health Department
.73de Morrison, Assistant County Attorney " - '
.=•'� yr �..:-` �t
• _ , .. -
•
. .
•
•
•
EASTERN PLAINS ENVIRONMENTAL SERVICE
} - 36€' OAK AVENUE, SUITE 14€'
. PD BOX 446
«r EATON, CO 80515 •
13-••4.54-3085
September 28, 1993
. !
, ,. •. - •y:i..� ..n-.. .,,. :f �.....t✓err• , r _ - w
rIr '-Keitfei 5chue`tt . �.; , ._"'• • :.;. =' 1r!!..q:,;,
' rt
. ' �Jel'd:.:County Planning Department . - '
. Weld 'County Administ.rative 'Eui:lding
1400 N . 17th Avenue t '
Greeley, CO 80631
- Dear Mr . E,chuet.t, '
RE: Northern Colorado Brine .
Northern Colorado Brine requests approval to construct a shelter .
building over the. two-stage heater treater and sludge tank ,, -.,
previously approved• at the site:. _ The 'purpose of the building is ' - :.)1-', . ,,
to protect• the equipment from the' weather . The proposed building' ,!, • k
,will :be approximately 54' x 96' , with 1.43 foot sidewa3.ls. The' ' ... .kr .
- . building will be a pole structure , with a steel skin and a dirt ,ti'r ' _ 414
.; .,
• floor . The building will have tloo large sliding doors, and two '-
walk through doors . • There will be no electrical or plumbing- ' . . .
inside the building. ' The propane burner for the first stage of
the heater treater and the chemi cal storage and pumps will all - .
be located outside the building,
•
Please call if I may provide any additional information or answer
any questions regarding ' this 'matter . I may be reached at .
454=3085. - . ' `i • .
`
sincerely,.-6/0Patty eplc-es, ='E3 '
cc : Mike Cervi. , NCB
. . . . \. 't801993k ,
• . Weld fteen1y PI noing -
•
•
--- ' --_ ___ :__._.._ ,.....;.......„...-_,..4._
(._ €
o
LIND, LAWRENCE & OTTENHOFF \ SAP 3 1993
ATTORNEYS AT LAW
THE LAW BUILDING _A� ee,n,.�,w=
1011 ELEVENTH AVENUE Wald r�ineaninp
P.O. BOX 326
GREELEY, COLORADO 80632
GEORGE H. OTTENHOFF TELEPHONE
KENNETH F. LIND (303) 353-2323
KIM IL LAWRENCE September 28, 1993 (303) 3569160
TELECOPIER
JEFFREY R. BURNS (303)356-1111
Weld County Department of Planning Services
1400 North 17th Avenue
Greeley, CO 80631
Attention: Keith Schuett
Re : USR-540 (Northern Colorado Brine)
Dear Mr. Schuett :
This office is in receipt of your letter dated September 21,
1993 which contains three pages of proposed new operation
standards . As I discussed with you by telephone conversation on
September 20 , 1993 the- Planning Department as well as Health
Department continue to formulate and develop new operation
standards which are both improper, illogical and go far beyond the
resolutions of the Board of County Commissioners which determine
that the new equipment is a "minor change" and couldbe installed
subject only to review by the Planning and Health Department .
We have attempted to cooperate with you on a continual basis
even going to the extremely expensive and lengthy process of
submitting amended design and operation plans which were also not
required by the Board of County Commissioners . When I state that
you continue to add numerous requirements far beyond reason, I
would refer you to a letter dated September 21, 1993 from Mr. Doak
with the Colorado Department of Health. His extensive review
resulted in only four comments whereas you have three pages .
Additionally, I would refer you to a memo dated August 27th from
Mr. Pickle to yourself which contained only eight . recommended
conditions for approval, and I am sure that you remember that I
only had one minor change on those original eight conditions . Now,
you continue to heap new requirements and recommendations upon this
minor change and the volume and extent of . your changes are
unacceptable .
In reviewing your proposed operation standards, we do find
some of them to be reasonable and acceptable. Specifically, we can
accept 1 (a) , - (b) , (c) , (e) , (f) , (g) and (i) as written.
As to 1 (d) , the word "observe" is objectionable and not
acceptable. Please remember that we are only talking about brine
water and I am sure there is not a single facility in Weld County
Weld County Department of Planning Services
September 28, 1993
Page 2
or industry that is required to continually "observe" every single
facet of operations . Having an employee stand and observe all
operations at the site is not reasonable, is .a significant waste of
time and money and does not make sense. I have suggested to you
that the word "supervise" be substituted and we have no problem
with our client supervising operations but to request an employee
to continually observe all disposal operations is far beyond
reason.
As to proposed operation standard 1 (h) , the last sentence must
be deleted. Representatives of the district have 'inspected the
plans and facilities and have issued a letter to Mr. Stoner which
you have on file. You had originally requested Northern Colorado
Brine to have the plans inspected, this was done, but now you are
adding additional requirements which are unacceptable. Your
proposed operation standard removes authority from the Board of
County Commissioners and grants it to a district which is not
subject to any type of oversight or review and is thus
unacceptable . We have always worked with the district and have
incorporated many of their recommendations and suggestions into
operations at the site. However, requiring some type of
recommendation to be followed is not appropriate and, I would add,
it shifts potential legal liability to the district which I am sure
the district would not desire in anyway.
Your proposed standards (j ) , (k) and (1) are also
inappropriate as they have nothing to do with installation and.
operation of new equipment . We have provided to you radioactive
screening tests which have been performed at the site and you do
have those in your files . Your suggestions as to new indicators
are also not acceptable according to our client ' s engineers and, I
would add, that the existing indicators have been specifically
approved and are quite reliable . As to existing trees, we cannot
determine which, if any, trees are dead at this time and this also
goes beyond logic .
Our consultants have also advised us that your request to
screen all water at the site as you have proposed cannot be
accomplished. The site currently screens the water in accordance
with State Health Department regulations .
As your operation standards have nothing to do with the
installation and operation of the new equipment and are
unreasonable, we have no choice but to reject all of them at this
time . As your department was requested to review the plans, it is
your sole responsibility for any delay in operations that this may
cause at the site . Due to your unreasonable delay, response and
recommendations, our office will now inform the Colorado Air
Quality Control Commission that the compliance schedule cannot be
z
Weld County Department of Planning Services
September 28, 1993
Page 3
followed due to actions of administrative officials with Weld '
County. If you would like to revise your recommendations in
accordance with Mr. Pickle ' s August 27th memo, Mr. Doak' s letter of
September 21, 1993 and my comments, we would be pleased to again
review them. However, this review as contemplated has gone beyond
all reasonable standards and requirements and will result in
needless delay and expense .
Very truly yours,
LIND ENCE & T
K e h F.
KFL/cg
pc : Board of County Commissioners
Ed Stoner, Weld County Building Inspection
Trevor Jiricek, Weld County Health Department
Lee Morrison, Assistant County Attorney
Vern Nelson
Mike Cervi
Greg Hobbs
Patty DePlazes
tSD
a'orma
DEPARTMENT OF PLANNING SERVICES
PHONE (303)353-3845, EXT. 3540
r n- ' - WELD COUNTY ADMINISTRATIVE OFFICES
{ �- ttekt
to pt:- 1400 N.17TH AVENUE
c v GREELEY, COLORADO 80631
re. o
COLORADO •
September 21, 1993 f
Mr. Kenneth F. Lind
Lind, Lawrence, and Ottenho£f
1011 Eleventh Avenue
P.O. Box 326
Greeley, CO 80632
Subject: USR-540 (Northern Colorado Brine) , located on part of the NE4 of
Section 26, and part of the NW4 of Section 25, all in T5N, R67W of
the 6th P.M. , Weld County, Colorado.
Dear Mr. Lind:
Thank you for the information you provided our Department and the Weld County
health Department on the proposed water treatment equipment to be located at
Northern Colorado Brine. The information that was submitted for the design and
operation plan was reviewed by both Departments. The Department of Planning
Services' staff and the Health Department staff request that the following items
be incorporated into the Operation Standards for Special Review Permit #540.
1(a) . The use shall be an oil and gas brine water disposal, oil and gas
production water disposal, and oil recovery facility as described in
the submitted materials. Only brine water and production water
which occurs as the result of oil and gas exploration and production
shall be received for processing and disposal at this facility. No
hazardous wastes or non-hazardous industrial waste shall be allowed
at the site. The facility shall be designed, constructed, and
operated to comply with the Solid Waste Disposal Sites and
Facilities Act, Title 30-20, Part 1, CRS 1973, as amended.
1(b) . The facility shall abandon and remove all existing bubbler, misting
aeration systems no later than December 15, 1993, and not operate
nor install any aeration, bubbler, misting system or other type of
aeration system until the design and operation plan of such a system
is approved by the Weld County Planning and Health Departments and
the Solid Waste Division of the Colorado Department of Health.
Mr. Kenneth F. Lind
September 9, 1993
Page 2
1(c) . Permits and approvals if necessary must be obtained from the Water
Quality Control Division of the Colorado Department of Health or the
Colorado Oil and Gas Commission prior to discharging or removing any
processed water off-site.
1(d) . A responsible employee, trained to differentiate between brine water
and other fluids, shall observe all disposal ope,ations.
1(e) . The disposal ponds on this facility shall be operated to maintain a
total pond depth, of five feet (30 inches of freeboard, 6 inches for
salt accumulation, and 24 inches for brine water) from the average
height of the pond liner. Any deviation from the approved freeboard
distance and pond depth must be approved by the Weld County Health
and Planning Departments.
1(f) . The facility shall comply with the Stipulation and Agreement with
the Air Quality Control Commission signed July 30, 1993.
1(g) . The facility shall consist only of those features as described in
the submitted supplemental (El Toro Management Systems, Inc.)
materials.
1(h) . All plans for. construction on site shall be reviewed by the
Johnstown Fire and Rescue Protection District prior to the release
of building permits. Recommendations from the Johnstown Fire and
Rescue Protection District shall be followed to the greatest extent
possible.
1(i) . Other non-hazardous waste, such as underground storage tank water,
may be accepted at this facility- on an individual basis only, if
written approval is given, for each load delivered, 'by the Weld
County Health Department.
1(j) . The current gauge height indicators shall be replaced with permanent
height/freeboard indicators' as each pond is drained and prior to
allowing the ponds to be filled with water. The height/freeboard
indicators shall be constructed of concrete or metal. The permanent
height/freeboard indicators shall be accurately installed in
relation to the average height of the pond floor liner. The
indicator shall clearly show the height of water (6 inches for salt
accumulation and 24 inches for brine water) in relation to the top
average height of the pond liner and the 30 inches of freeboard. To
accomplish this, both the average depth ,of each pond and the
height/freeboard indicators shall be surveyed for accuracy. A copy
of the survey with benchmarks identified shall be provided to the
Department of Planning Services and the Weld County Health
Department.
•, .,. :w. 7.. t
Mr: Kenneth F. Lind
September 9; 1993
Page 3
1(k) Existing dead or dying evergreen and Russian Olive trees shall be
replaced. within the 1993 fall planting season with substantially
similar kind to maintain the approved landscaping and; shelter belt
area. Dead or dying evergreen and Russian Olive trees shall be
replaced with substantially similar kind withinsthe next planting
• ' season to maintain the approved landscaping and shelter belt area.
1(1) ' , ' .The facility shall screen all'.water,' to beidisposed of-at the site
-for radioactivity. , The:method to:be' incorporated an-the site-must
.
,' be reviewed and ,approved' by 'Weld ',County Environmental Protection
Services' and Weld County Planning Department: If radioactive'water'
is detected at the site, either the, source of the radioactive water
will be identified and barred from using the site or applications
will be made to allow the site to handle the radioactive water.
Prior to the release of building permits for the new equipment designed by El
Toro. Management System, Inc. , written evidence shall be provided to the
Department of Planning Services that the above conditions and:operation standards
have been incorporated into the Conditions of Approval and Operation Standards
for„Special Review Permit 4540.
Please call or write me if you have any questions.
Sincerely,
•
u t�tom/
urrent, Planner
pc:-,.' Board of County Coissioners
Ed Stoner, Weld County Building Inspection Trevor Jiricek; Weld County Health Department
e Morrison, Assistant County Attorney
•
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