NATURE OF CASE BRODERICK WOOD PRODUCTS CO. OPERATED A WOOD PROCESSING AND TREATMENT FACILITY IN DENVER, COLORADO, FROM 1946 UNTIL 1981. IN 1982, THE COMPANY FILED ARTICLES OF DISSOLUTION WITH THE COLORADO SECRETARY OF STATE. AT THAT TIME, ALL ASSETS OF THE COMPANY REVERTED TO AN ELABORATE ARRANGEMENT OF INTER VIVOS AND TESTAMENTARY TRUSTS ADMINISTERED BY THE COLORADO NATIONAL BANK AND THE FIRST NATIONAL BANK OF DENVER (NOW THE FIRST INTERSTATE BANK OF DENVER). FOR PURPOSES OF DISPERSING THE ASSETS OF BRODERICK WOOD PRODUCTS CO. IN 1982, THE TWO TRUSTEES FORMED A PARTNERSHIP, BRODERICK IN- VESTMENT COMPANY. BOTH PRIOR AND SUBSEQUENT TO THE LEGAL DISSOLUTION OF BRODERICK WOOD PRODUCTS CO., EPA INSPECTORS OBSERVED NUMER- OUS VIOLATIONS OF RCRA AND EPA'S RCRA REGULATIONS AT THE SITE. IN ADDITION TO NUMEROUS VIOLATIONS OF THE IMPORTANT PROCEDURAL REQUIREMENTS OF THE RCRA REGULATIONS, EPA IN- VESTIGATIONS OF AND NEAR THE SITE HAVE REVEALED SIGNIFICANT SOIL, SURFACE WATER, AND GROUNDWATER CONTAMINATION. CAUSE OF ACTION NEGOTIATIONS UNDERWAY. PROPOSED CONSENT DECREE UNDER REVIEW BY EPA/HQ AND DOJ ENCOMPASSING RCRA VIOLATIONS AND SUBSEQUENT CERCLA REFERRAL. <AT THE REQUEST OF EPA-HQ HAZARDOUS WASTE CHIEF, JACK WINDER, A LATER ACTION AGAINST BRODERI