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Home My WebLink About20131435.tiffSPECIAL POWER OF ATTORNEY HALLIBURTON ENERGY SERVICES, INC., a company duly organised and existing under the laws of Delaware, U.S.A. (hereinafter referred to as the "Company"), having our registered office at 1209 Orange Street, Wilmington, Delaware 19801, U.S.A., and acting through Tommy E. lamail, the duly empowered Vice President -Real Estate Services of said Company does hereby appoint, authorize, designate and empower Margaret Hatfield, as the true and lawful agent and Attorney -In -Fact of the Company to act for and on behalf of the Company with respect to the following powers: (1) To contract for, purchase and take possession of real property; (2) to give evidence of the company's ownership of to real property; (3) to lease real property, including leasing oil, gas and minerals; (4) to sell or convey real property; (5) to execute deeds, contracts and documents related to such transactions; and (6) to take any other incidental actions as may be necessary or appropriate to effect the foregoing powers. The Company hereby ratifies and confirms all that the Attorney -in -Fact shall lawfully do or cause to be done by virtue of and to the extent of this authorization under this Special Power of Attorney. This Special Power of Attorney shall be effective as of November 1, 2012, and shall automatically expire and be of no further force and effect at the earliest to occur of the following events: (1) at midnight on October 31, 2013, or (2) when the Attorney -in -Fact ceases to be an employee of the Company. This Special Power of Attorney may be terminated at any time prior to that date upon Company giving notice thereof to said Attorney -in -Fact, in which event such termination shall be effective immediately as of the date of such notice. IN WITNESS WHEREOF HALLIBURTON ENERGY SERVICES, INC., has caused this to be signed by its Vice President -Real Estate Services on November 16, 2012. Halliburton Energy Services, Inc. By: il ice President -Real Estate Services STATE OF TEXAS COUNTY OF HARRIS SUBSCRIBED AND SWORN TO before me, the undersigned Notary Public by Tommy E. Jamail, known to me to be the Vice President -Real Estate Services of Halliburton Energy Services, Inc., and who certified that he executed the foregoing instrument for and on behalf of said corporation, this 16ih day of November, 2012. MARY WOOD Notary Public, Slate at Texas. My Commlesion Expires f' February 16, 2016 Notary Pu.li. State of TEXAS Mit 1111De. COLORADO DEPARTMENT OF PLANNING SERVICES 1555 N 17th AVE GREELEY, CO 80631 PHONE: (970) 353-6100, Ext. 3540 FAX: (970) 304-6498 AUTHORIZATION FORM Patrick Engineering, Inc. represent Halliburton (Agent/Applicant) (Owner) located at The West Half of the Northwest Quarter for the property LEGAL DESCRIPTION: SEC 13 TWN 10N RNG 61W SUBDIVISION NAME: USR-1787 LOT BLK I can be contacted at the following phone #'s: Home Work 303-532-8620 Fax # 303-532-8621 The property owner can be contacted at the following phone #'s Home Work Fax # Correspondence mailed to (only one): x❑ Agent/Applicant ❑ Property Owner DATE II -16- 2Oi2- OWNER'S SIGNATURE rgaret Hatfield Real Estate Services Attorney -in -Fact r X/ SITE SPECIFIC DEVELOPMENT PLAN AND USE BY SPECIAL REVIEW (USR) APPLICATION FOR PLANNING DEPARTMENT USE DATE RECEIVED: RECEIPT # /AMOUNT # IS CASE # ASSIGNED: APPLICATION RECEIVED BY PLANNER ASSIGNED: Parcel Number o22- 13 - 2 - oo - 009 (12 digit number - found on Tax ID. information, obtainable at the Weld County Assessor's Office, or www.co weld.co.us) Legal Description w2Nw4 . Section 1:; , Township 'o North Range 61 West _ Zone District: AG Total Acreage: so , Flood Plain: N/A , Geological Hazard: N/A Airport Overlay District: N/A FEE OWNER(S) OF THE PROPERTY: Name: Halliburton Energy Services Inc c/o Woody Kemp, Principal Global Manager Work Phone # 281,575.4'39 Home Phone # Email Address: 7304 Preston Road, Suite 700 Address: City/State/Zip Code Dallas TX 75252 Name: Work Phone # Home Phone # Email Address: Address: City/State/Zip Code Name: Work Phone # Home Phone # Email Address: Address: City/State/Zip Code APPLICANT OR AUTHORIZED AGENT Name: Patrick Engineering Inc Project Manager: Mickey Leyba-Farnsworth Work Phone # 303.532.8627 Home Phone # Email mleybaca)patrickengineering.corn Address: 1400 W. 122^" Ave Suite 102 Address: City/State/Zip Code Westminister CO 80234 PROPOSED USE: This Use by Special Review application is for the purpose of amending USR-1787 to allow for a commercial Recycling Facility in addition to to the existing water load out use within the AG Zone District. The facility will s pport oil a d gas companies within a 50 miles radius by s_uppl agog an recycling water used in drilling operations. In addition the facility may also provide water for municipal and industrial use. I (We) hereby depose and state under penalties of perjury that all statements, proposals, and/or plans submitted with or contained within the application are true and correct to the best of my (our)knowledge. Signatures of all fee owners of property must sign this application. If an Authorized Agent signs, a letter of authorization from all fee owners must be included with the application. If a corporation is the fee owner, notarized evidence must be inclu ,d indicating that the signatory has to legal authority to sign for the corporation. Signature) Owner or Aut orized Agent Date Signature: Owner or Authorized Agent Date Margaret Hatfield Real Estate Services Attorney -in -Fact STATEMENT OF AUTHORITY 1. This Statement of Authority relates to an entity' named Halliburton Energy Services, Inc. and is executed on behalf of the entity pursuant to the provisions of Section 38-30-172, C.R.S 2. The type of entity is a: ❑ trust ❑ nonprofit corporation ❑ limited liability company ❑ general partnership O limited partnership O ❑ registered limited liability partnership ❑ registered limited liability limited partnership ❑ limited partnership association ❑ government or governmental subdivision or agency pit corporation 3. The entity is formed under the laws of 4. The mailing address for the entity is State of Delaware 17304 Preston Road, Suite 700 Dallas, TX 75252 5. The 0 name O position of each person authorized to execute instruments conveying, encumbering, or otherwise affecting title to real property on behalf of the entity is Woody Kemp, Principal Global Manager 6.The authority of the foregoing person (s) to bind the entity is ❑ not limited O limited as follows: 7. Other matters concerning the manner in which the entity deals with interests in real property: Executed this W "'fir , �1%o�E rtgyt t Zo12- �c • TINA ROBERTSON R Notary Public, State of Texas • My Commlaston Expires Februar 18, 2016 STATE OF GalantO -MGM COUNTY OF 1('845 } SS: The foregoing �c��instrument was acknowledged before me this by \cYicc,(ic otS ' cA Witness my hand and official seal. ab�� Sig Signature \co day of vpVeM�e..1/4-- My commission expires: a —\3,—ea t) 'This form should not be used unless the entity is capable of holding title to real property. 'The absence of any limitation shall be prima facie evidence that no such limitation exists. 'The statement of authority must be recorded to obtain the benefits of the statute. Notary Public PATRICK ENGINEERING HALLIBURTON ENERGY SERVICES, INC. Pawnee Groundwater Load Out & Recycling Facility USE BY SPECIAL REVIEW QUESTIONNAIRE 1. Explain, in detail, the proposed use of the property. Facility Site Description Halliburton Energy Services is proposing to amend the existing (Phase I) groundwater load out facility to allow for a commercial water recycling facility (Phase II) within the Agricultural Zone District. The intent of the Phase II recycling facility is to provide treatment, recycling and disposal for water used in regional drilling operations. The Pawnee Facility, as a combined groundwater load out and recycling facility, will support oil and gas companies for their drilling operations within a 50 -mile radius, as well as continue to have the ability to supply groundwater for municipal, industrial, and irrigation uses. The Pawnee Stationary Commercial Water Recycling Facility (the "Pawnee Recycling Facility" or "Facility") is located at 57748 CR95, in Weld County. It is located approximately 4 miles southeast of Grover, CO, bordered by County Road 118 and County Road 95 to the north and west respectively, and more particularly described as the West % of the NW '/4 of Section 13, Township 10N, Range 61 West of the 6th P.M. The Facility is designed to provide Total Water Management Services, in that the Facility will receive hydraulic fracturing flow back water and formation produced water from area oil and gas developments, treat that water, and recycle and reuse the treated water in oil and gas operations. Utilizing its proprietary CleanWaveTM technology, Halliburton Energy Services, Inc. ("Halliburton" or "HESI") will remove suspended colloidal matter from the flow back and produced water resulting in treated water suitable for use in future oil and gas drilling and production operations. In addition to the equipment associated with this recycling process, the Facility will house a series of holding tanks for hydraulic fracturing flow back and produced water storage. The Pawnee Recycling Facility will be co -located at a larger facility that will include water supply and oil and gas waste disposal operations and will employ spill prevention procedures, including secondary containment, storage tank automated shutoff valves, and a comprehensive SPCC Plan that will limit impacts to surface and subsurface waters. Periodic ground water monitoring and water quality chemical analyses will enable prompt detection of potential impacts to ground water. The Facility will be enclosed with barbed wire fencing in order to keep cattle and other wildlife out of the premises, and for security purposes, the Facility will be manned 24 hours per day, 7 1400 West 122nd Avenue, Suite 102, Westminster, Colorado 80234 I 303-532-8620 I patrickengineeringicom Pawnee Groundwater Load Out & Recycling Facility I Use by Special Review Questionnaire days per week. Access to the facility will be limited to a single, manned entry point, and a Supervisory Control and Data Acquisition ("SCADA") system will be employed to effectively manage vehicle traffic and to prevent illegal dumping and receipt of unauthorized material. Security lighting will be in place for continuous operations. The Pawnee Recycling Facility will benefit the state and county in a number of ways. With the ability to recycle flow back and production water, the Facility will significantly reduce the need for fresh water and will reduce the total amount of water disposed of in regional oil and gas drilling and production operations. Moreover, the Facility will reduce truck traffic on local roads by providing a convenient one -stop location to drop off, recycle and load treated water for local oil and gas operations The Facility will also provide the opportunity for surface transfer water lines to be utilized in order to support local operations instead of trucks, further reducing truck traffic. Facility Design Description The proposed Pawnee Recycling Facility is comprised of four off-loading stations, ten holding tanks for the storage of flow back and produced water, two five holding tanks for the storage of the treated, recycled water, two loading stations for the distribution of the recycled water, one loading station and two holding tanks for the collection of the reclaimed hydrocarbons separated during the recycling process, and two truck tank wash stations used to clean tankers after off-loading flow back and/or production water. Please refer to the USR Plat for specific locations of these facility features. The operation will recycle flow back and produced water associated with exploration and production activities for reuse in oil and gas development, thereby reducing impacts to the state's fresh water resources as a result of oil and gas development. Residual hydrocarbons from the flow back and formation water will be recovered and properly disposed of. The main flow back water recycling operations will be situated within a concrete secondary containment pad and will contain ten 27'- 6" diameter x 24' high (2,500 BBL) Incoming Brine ("IB") horizontal storage tanks, five 38'-6" diameter x 24" high (5,000 BBL) Outgoing Brine ("OB") horizontal storage tanks, three 24' diameter (2,500 BBL) Fresh Water Storage tanks, two 27'-6" diameter x 24' high (500 BBL) Salt Water Disposal Storage tanks, two 19' diameter x 24" high (500 BBL) Oil Storage tanks, and two 12' diameter Chemical Storage tanks. The estimated maximum volume of untreated oil and gas waste water to be stored at the Facility is 1,000 BBL; maximum volume of partially treated oil and gas waste water to be stored is 4,000 barrels of system capacity. The CleanWaveTM recycling system, as well as four oil water separators ("OWS") and a Total Suspended Solids ("TSS") sludge removal pit, are located in the IB and OB storage tank area. Adjacent to the tank storage pad is an oil tank loading bay; located to the south of the tank storage facility are two loading bays from Outgoing Brine tanks and one Truck Wash Station. The entire processing facility contains concrete secondary containment designed with a Pawnee Groundwater Load Out & Recycling Facility I Use by Special Review Questionnaire watertight HDPE liner under the concrete walking surface with water stops at the joints that provides for a dual layer of protection from spills. Four ground water monitoring wells are located strategically around the facility to accurately measure and assess the subsurface water quality. A Sampling and Analysis Plan has been developed to address the groundwater monitoring requirements in Colorado, specifically the requirements in COGCC Rule 908(b)(9), and to establish a baseline groundwater quality assessment, against which future groundwater analytical data can be compared. Step -wise Facility Recycling Process Description Entrance: Upon entering the Facility, each driver will be required to enter a keypad code to identify the specific operator and origin of the delivery. Trucks will not be able to unload without an approved code. Additionally, each load is received and signed in by a dedicated Facility operator. The operator will electronically enter into a database program the time and date of receipt, operator, volume, load description, truck details if applicable, API number, lease or facility name, lease number, gas identification number, and county. Offloading at the Incoming Brine Station: The recycling process is initiated when a truck driver offloads the flow back or production water into one of the facility's Incoming Brine stations. As mentioned above, the facility's Incoming Brine offloading station is controlled and regulated by a SCADA monitoring system. This system controls the operation of each loading/unloading station and can only be activated by the truck driver swiping his client and driver -specific mag card. Once the station is active, the driver can begin offloading his waste water through a 4" flex pipe with cam -lock connections, the volume of which will be monitored by the SCADA system. Once the tanker has been emptied, the driver disconnects the 4" flex hose and can either proceed to the truck tank wash station to clean the truck's tank in preparation for loading with outgoing brine or fresh water, or the trucker may return to his respective oil and gas production site to obtain another load of incoming brine for recycling. If, during this process, any water is spilled, each offloading station is situated within a concrete pad containing a perimeter curb. The unloading pad area is equipped with a concrete trench drain that collects any spills, small drips, leaks, and storm water within this concrete pad. This fluid will then gravity flow to the central secondary containment area which will be sloped such that any liquids will sheet flow to two concrete sump collection systems. Each sump will then be pumped to one dedicated 5000 BBL incoming brine tankwhere the fluid will be held until the tank is batched through the recycling system. Truck Tank Wash: The Pawnee facility is equipped with a truck tank cleaning station that allows the inside of tankers to be cleaned after delivering a load of production waste water and before loading and transporting Outgoing Brine or freshwater. Once again, the truck tank wash station is monitored and controlled by the Facility's SCADA system. Similar to the loading/unloading stations, the truck tank wash station can only be activated by the truck driver swiping his client and driver -specific mag card. Once the station is active, the truck driver again attaches a 4" flex hose to the truck via cam -locks and activates the washing device. All water used to clean the Pawnee Groundwater Load Out & Recycling Facility I Use by Special Review Questionnaire inside of the tanker is then drained through the 4" flex hose and collected in a sump where it is transferred through a double walled pipe to the secondary containment area and deposited in a 5,000 BBL tank until it can be recycled. If any water is spilled during this process, the truck tank wash station is equipped with a concrete trench drain that collects any lost water and directs it to the truck tank wash sump where it is transferred through a double walled pipe to the secondary containment area and deposited in a 5,000 BBL tank until it can be recycled. In other words, all water used to wash tankers will be collected and added to the recycling process, once again creating recycled usable water for oil and gas drilling and production operations. Loading at the Outgoing Brine Station: The Outgoing Brine loading station is controlled and regulated by the SCADA monitoring system. Just as is the case with the offloading station, the loading station must be activated by the truck driver swiping his client and driver -specific mag card. Once the station is active, the driver can begin loading his truck with recycled brine water through a 4" flex pipe with cam -lock connections. Once again, this process is monitored by the SCADA system, but it is the truck driver's responsibility to monitor the amount of water being loaded into the truck in order to prevent overloading. If any water is spilled during the loading process, a concrete pad with perimeter curb will capture the water and direct it to a concrete trench drain. Any lost water including rainfall runoff will gravity flow within the trench drain to the central secondary containment area. Once in the secondary containment area, the water will sheet flow to two concrete sump collection systems. Each sump will then be pumped to one dedicated 5000 BBL incoming brine tank, where it is held until the tank is batched through the recycling system. 2. Explain how this proposal is consistent with the intent of the Weld County Code, Chapter 22 of the Comprehensive Plan. This proposal is consistent with the following goals and policies in the Weld County Comprehensive Plan: • G. A.Goal 7. County land use regulations should protect the individual property owner's right to request a land use change. • A.Policy 7.1. County land use regulations should support commercial and industrial uses that are directly related to, or dependent upon, agriculture, to locate within the agricultural areas, when the impact to surrounding properties is minimal, or can be mitigated, and where adequate services are currently available or reasonably obtainable. • A.Policy 2.2. Allow commercial and industrial uses, which are directly related to or dependent upon agriculture, to locate within agricultural areas when the impact to surrounding properties is minimal or mitigated and where adequate services and infrastructure are currently available or reasonably obtainable. These commercial and industrial uses should be encouraged to locate in areas that minimize the removal of agricultural land from production. Pawnee Groundwater Load Out & Recycling Facility I Use by Special Review Questionnaire The proposed treatment, recycling and disposal facility, along with the existing groundwater load out capability, will provide a valuable and indispensable service to the oil and gas industry in this particular region of northern Colorado. The construction of this facility will provide a regional hub that will allow for nearby oil and gas drilling companies to haul produced, or flowback, water for treatment, recycling, reuse and disposal. By providing recycling and treatment of produced water, the facility will allow for the re -use of water, limiting the amount of fresh water that needs to be pulled out of the ground for drilling operations. Electric service, as required during Phase I, will continue to be the only service required for operation of the facility. The now existing 3 -phase extension, provided by High West Energy, has the ability to benefit surrounding properties as it runs to the facility and the associated groundwater wells. 3. Explain how this proposal is consistent with the intent of the Weld County Code, Chapter 23 (Zoning) and the zone district in which it is located. The intent of the A (Agricultural) Zone District is "to provide areas for the conduct of agricultural activities and activities related to agriculture and agricultural production without the interference of other, incompatible land uses [and]...to provide areas for the conduct of uses by Special Review which have been determined to be more intense or to have a potentially greater impact than uses Allowed by Right." As the Phase I groundwater load out facility was approved as an appropriate use in an agricultural area, so could the Phase II recycling facility be considered as well. By providing a local, comprehensive, treatment, recycling, disposal and water load out facility, truck traffic and the noise, dust, traffic and waste that comes with it will be lessened. By providing recycling and re -use of process water, the amount of groundwater use will be reduced and the amount of process water that must be disposed of will be greatly minimized. The facility is designed to optimize internal truck circulation and minimize disturbance to the surrounding ranch land, which will continue to be utilized for cattle grazing. 4. What type of uses surround the site (explain how the proposed use is consistent and compatible with surrounding land uses). The proposed use remains consistent and compatible with the surrounding land uses, which are primarily agricultural in nature. The surrounding landowner and previous applicant/owner of the groundwater load out facility, Daniel P. Dietzler, currently utilizes the property for ranching operations. Existing oil and gas facilities are also characteristic of the surrounding area. In addition, future oil and gas production sites which have been identified in the surrounding area will have the ability to benefit from the groundwater load out and recycling facility, reducing travel impacts on the County Road system. 5. Describe, in detail, the following: Pawnee Groundwater Load Out & Recycling Facility Use by Special Review Questionnaire a. Number of people who will use this site: The maximum projected number of trucks (and their drivers) accessing the facility, whether to deliver processed water for treatment or disposal, or to load groundwater, recycled water or oil, will remain at 320 loads per day. This is the same volume of trucks that was proposed for the Phase I groundwater load out operation. Because Phase II is a recycling and load out facility, and the number of haul trucks in the area is the same, the volume of trucks that pick up water for their operations will be the same. Per day, it is anticipated that approximately 40 tanker trucks will deliver processed water and then fill recycled or groundwater water before leaving the site. It is estimated that a truck will discharge processing water to the facility in 20 minutes. The estimated fill time is 15 minutes. If the truck's tank is washed out prior to refilling, drivers may be on site for an additional 15 minutes. Between unloading, loading, washing and maneuvering, a driver is expected to remain on the site for approximately 1 hour or less. b. Number of employees proposed to be employed at this site: Between one (1) and five (5) full-time on -site employees will be required to staff and oversee the recycling and load out facility. c. Hours of operation: The facility will remain operational 24 hours a day, 7 days a week to provide continuous access to the facility for trucks to load and unload, as well as for recycling and treatment to occur during off-peak hours. d. Type and number of structures to be erected (built) on this site: Phase II structures include a permanent office building (50' x 20') to provide shelter, work space and operations oversight for the operator of the facility. Other structures proposed for the recycling facility include the following storage tanks, which will be placed on structurally designed concrete foundations: • 10 In -coming Brine Tanks: 2,500 BBL (27'-6" dia x 24'0" high) • 5 Out -going Brine Tanks: 5,000 BBL (38'-6" dia x 24'-0" high) • 2 Oil Storage Tanks: 500 BBL (19'-0" dia x 24'-0" high) • 2 Salt Water Disposal Tanks: 2,500 BBL (27'-6" dia x 24'-0" high) • 2 Chemical Storage Tanks: 50 BBL (8' dia x 6' high) Other required treatment process tanks and structures: • 16 Cleanwave Recycling Units: (8'-6" wide x 45'-0" long) • Sludge Press Building: (20' x 64') • Main Pump Station: (8' x 40') • Grit Chamber: (18' x 15') • Oil / Water Separator: (22' x 43') • Brine Pump Station: (7' x 20') • Oil Pump Station: (8' x 10') Pawnee Groundwater Load Out & Recycling Facility I Use by Special Review Questionnaire e. Type and number of animals, if any, to be on this site: Not applicable. f. Kind of vehicles (type, size, weight) that will access this site and how often: The type of vehicles accessing the site will include tractor trailer trucks hauling 6,000 to 6,500 gallon aluminum tanks. These vehicles are typically 60 -feet long, semi -trucks (approximately 80,000 pounds). It is anticipated that a maximum of 40 delivery tanker trucks will be delivering process water and re -loading groundwater, brine or oil 8 times per day. Based on this data, 320 loads of processed water may be delivered, and 320 loads of groundwater, brine or oil loaded, per day. The estimated traffic volumes generated by the proposed project includes 640 average daily one-way trips and 27 peak hour one-way trips (14 in / 13 out). g. Who will provide fire protection to the site: The Pawnee Fire Protection District serves this property. h. Water source on the property (both domestic and irrigation): Truck tank wash water and irrigation, as necessary, will be provided by the existing groundwater storage tanks and permitted wells. Refer to the Water Supply information provided with this submittal. There is no need for domestic water service on the property as the drivers are expected to be on the site for less than one hour. A portable water cooler or bottled water, located in the office building, will provide potable drinking water for the site operator. i. Sewage disposal system on the property (existing and proposed): Portable toilets are proposed for use by the site operator. Truck drivers are expected to be on site for less than one hour, but will have these toilet facilities to use if needed. Toilet holding tanks will be pumped bi-weekly or as needed, and their contents will be fully disposed of at proper municipal treatment facility(s). If storage or warehousing is proposed, what type of items will be stored: The facility encompasses a screened storage area to the west of the groundwater load out portion of the facility. The storage area, accessed by two 24 foot wide swing gates on either side to provide one-way traffic flow through the area, is situated on aggregate pavement and is screened by a 6 foot tall chain link fence with tan colored screening slats. The fence will be topped with three -strand barbed wire for security purposes. The screened area will be used to store piping materials for use with the water transfer and load out facility. This storage area is located approximately 920 feet from WCR 95, beyond the existing groundwater storage tanks and truck parking area. Should the storage area need to be expanded, there is space available to the west of the site, adjacent to the existing storage area. If this additional area ends up being used, the aggregate pavement and chain link screening fence will be expanded to include this additional area. Drainage Pawnee Groundwater Load Out & Recycling Facility I Use by Special Review Questionnaire swales that currently run around the facility to divert surface runoff will also be extended as the storage area requires. In addition to the screened storage area and the three existing 2,500 BBL ground water storage tanks constructed during Phase I, several storage tanks are proposed for the recycling and load out facility process: 2,500 BBL In -coming brine tanks will store process water unloaded from trucks prior to treatment. 5,000 BBL Out -going brine tanks will store treated process water for loading into trucks for re -use. 500 BBL Oil storage tanks will store oil separated from the process water during treatment. 2,500 BBL Salt Water disposal storage tanks will contain treated process water prior to be discharged at the on -site disposal well. 50 BBL Chemical storage tanks will store chemicals required in the treatment and recycling process of dirty brine water. Please refer to the Spill Prevention Control and Countermeasure Plan (SPCC) included with the USR submittal for more information on particular types of chemicals to be stored on the site. 6. Explain the proposed landscaping for the site. The landscaping shall be separately submitted as a landscape plan map as part of the application submittal. In addition to the oak trees planted during Phase I, twelve (12) New Mexico Privet shrubs shall be planted around the south and west side of the recycling facility. These deciduous shrubs are native to Colorado, prefer full sun and can tolerate poor, dry soils. The fast-growing shrub grows up to 8 to 15 feet in height, providing adequate screening from Weld County Road 95. Cattle fencing will also be installed around the perimeter of the site in order to keep cattle from entering the load out of the facility. 7. Explain any proposed reclamation procedures when termination of the Use by Special Review activity occurs. A Pawnee Stationary Commercial Water Recycling Facility closure plan has been developed pursuant to the requirements of Section 8.3.4 of the Colorado Department of Public Health's Recycling and Beneficial Use regulations. Removal of process fluids/wastes and facility structures at the time of site closure are detailed within the closure plan and reflect Halliburton Energy Services' (HESI) intended disposition in accordance with applicable CDPHE rules. At the time of Facility closure, HESI will remove wastes, partially treated wastes, and recyclable products, as required by Section 8.3.4, and described in the Facility Closure Plan. Final site closure activities to be performed by the owner/operator shall include: • Secondary containment structures surrounding the Facility will be decontaminated, as required, and recycled and/or disposed of in accordance with legal requirements. • Samples of soil and groundwater will be collected throughout the Facility and sent to a qualified lab for analysis and reporting. Pawnee Groundwater Load Out & Recycling Facility I Use by Special Review Questionnaire • When sampling data indicates that soil and groundwater at the Facility does not contain contaminants above applicable CDPHE closure criteria, all four groundwater monitoring wells will be plugged and abandoned. • The surface of the Facility will be graded to provide positive drainage, and the area will be reseeded with native grasses appropriate to the climate, location, and time of year. 8. Explain how the storm water drainage will be handled on the site. Storm drainage that falls on the facility drive aisles and seeded areas, outside of the recycling area, will be contained on the site using overlot grading that discharges to a perimeter swale and is treated and discharged through a water quality swale. Storm water that falls within the recycling area, or on the concrete loading/unloading stations, will flow via surface flow or trench drains, to sump basins and then pumped into a designated In -coming Brine tank to be treated within the facility. Refer to the Drainage Amendment Memo included with this USR submittal. Phase I storm drainage shall remain mostly unchanged. Some additional aggregate areas will flow to the Phase I Water Quality area, which has the capacity to treat these additional flows. See the Drainage Amendment Memo for more information. 9. Explain how long it will take to construct this site and when construction and landscaping is scheduled to begin. Construction is expected to be completed within 3 months. Landscaping improvements would be installed after site grading is completed, within or near the end of the first month of construction. 10. Explain where storage and/or stockpile of wastes will occur on this site. Halliburton Energy Services proposes to incorporate the following waste management controls to strive for compliance with applicable State and National environmental health standards. A portion of the potential wastes to be generated onsite are expected to be comprised of household wastes and human waste/sewage. Trash containers and portable toilets will be located on -site during groundwater load out operations. Toilet holding tanks will be pumped bi-weekly or as needed, and their contents will be fully disposed of at proper municipal treatment facility(s). Trash will be contained within fully enclosed containers 24 hours a day, and will not be burned on -site. Any and all trash spills will be cleaned immediately following their discovery, with the spilled contents replaced into the proper receptacles. Leaking and/or damaged receptacles will be repaired or replaced prior to their reuse. Any household waste generated onsite will be picked up on a regular basis by: Waste Chasers 75 Oak Ave. Eaton, CO 80615 Pawnee Groundwater Load Out & Recycling Facility I Use by Special Review Questionnaire The bulk of the wastes to be generated on the site are those inherent to this type of recycling and treatment facility. By their nature, oil field waste water contains components whose removal is desirable if the fluids are to be reused in drilling and completion activities. This waste can include oil and/or condensate, formation solids, drilling fluids, fracturing fluid residuals, proppant, and dissolved solids from connate water. The treatment process to be employed at this facility is expected to remove many, but not all, of these constituents. The process will concentrate the waste in 500 -bbl settling tanks which will require periodic removal. The sludge in these tanks will be dewatered using conventional methods (centrifuge, filter press, etc.). The dewatering process will take place within the secondary containment area. The liquid fraction will be returned to the IB tanks for treatment, and the dried residual will be collected, tested and hauled to a licensed solid waste facility for disposal. The weight of the dewatered/dried waste, which will be weighed at the landfill, will be tracked and recorded monthly at the facility, where it will be divided by the monthly volume of water treated (converted to tons) to give a weight percentage of the waste generated by the treatment process. The frequency of sludge removal will depend on the amount and nature of the influents. Previous work suggests that sludge operations are necessary every 80-100,000bbls. At the anticipated level of oil field waters, this could be monthly. Dried solids are expected to be 1-2% of the total volume treated. This waste will be collected in a dedicated container and hauled off site when full. Dried material is not expected to present nuisance odors that will drift off the site. Testing conducted to date suggests that dried solids contain mostly clays, dehydrated frac gel (guar or a derivative), some metals (iron, alkali earths, trace heavies), and residual oil. Dried samples will be submitted to an EPA -approved laboratory annually, for a full analysis including heavy metals and NORMs. Downstream of the grit chambers, oils that are recovered in the oil/water separators during the treatment process will be stored in two 500 -bbl oil tanks. The two tanks shall float together so that oil is equally distributed or discharged from the two tanks. One oil load out station will be controlled and regulated by the SCADA monitoring system. The SCADA system will easily allow for the amount of oil recovered to be tracked and reported monthly. Just as is the case with the outgoing brine loading stations, the oil loading station must be activated by the truck driver swiping his client and driver -specific mag card. Once the station is active, the driver can begin loading his truck with oil through a flex pipe with cam -lock connections. I 10 WELD COUNTY ACCESS PERMIT Weld County Public Works Dept. 1111 H Street P.O. Box 758 Greeley, CO 80632 Phone: (970) 304-6496 After Hours: (970) 356-4000 Emergency Services: (970) 304-6500 x 2700 Inspection: (970) 304-6480 Permit Number: AP11-00268 Issuance of this permit binds applicant and its contractors to all requirements. provisions. and ordinances of Weld County. Colorado. Project Name: Dietzler Water Resources Cori Applicant Information: Name: Melissa Leyba-Farnsworth Company: Patrick Engineering Phone: 303-532-8620 Email: mleyba@patrickengineering.com Location: Access is on WCR: Nearest Intersection WCR: Distance From Intersection: Number of Existing Accesses Planning Process: 112 95 10586 1 Road Surface Type & Construction Information: Road Surface: Gravel Culvert Size & Type: 15" CMP Start Date: 07/11/2011 Finish Date: 07/31/2011 & WCR: 112 Materials to Construct Access: Agg. Base Course Required Attached Documents Submitted: Traffic Control Plan: Yes Certificate of Insurance: Yes Expiration date: 01/11/2012 Property Owner Information: Name: Company: Dietzler Water Resources Corp. Phone: Email: Proposed Use: Temporary: Single Residential: Industrial: Small Commercial: Oil & Gas: Large Commercial: Subdivision: Field (Agricultural Only)/Exempt: 0 Access Pictures: Yes A copy of this permit must be on site at all times during construction hours Daily work hours are Monday through Friday DAYLIGHT to 1/2 HOUR BEFORE DARK (applies to weekends if approved) Approved MUTCD traffic control/warning devices are required before work begins and must remain until completion of work Special Requirements or Comments Utilze the exisitng access to this parcel. Approved by: Weld County Public Works Date: 7/22/2011 Print Date -Time: 7/22/2011 10:27 28AM Report ID: PW00008v001 Page 1 of 1 FOR COMMERCIAL SITES, PLEASE COMPLETE THE FOLLOWING INFORMATION BUSINESS EMERGENCY INFORMATION: Business Name: Halliburton Energy Services, Inc. Phone: 303-899-4700 Address: 1125 17th Street City, ST, Zip: Denver, CO 80202 Business Owner: Halliburton Energy Services, Inc. Phone: 303-899-4700 Home Address: 1125 17th Street City, ST, Zip: Denver, CO 80202 List three persons in the order to be called in the event of an emergency: NAME TITLE Harold Run ADDRESS PHONE Pawnee Depot Manager 2900 County Rd 27, Fort Lupton, CO 80621 970-623-0331 Bob Shea Water Solution Lead, Northern US 1125 17th St, Denver, CO 80202 303-870-3917 Lonnie Farris HSE Tech. Professional, Brighton Dist. 2900 C.R. 27, Fort Lupton, CO 80621 303-825-4346 Business Hours: 24 Days: 7 Type of Alarm: None Burglar Holdup Fire Silent Audible Name and address of Alarm Company: Location of Safe: MISCELLANEOUS INFORMATION: Number of entry/exit doors in this building: Location(s): Is alcohol stored in building? Location(s): Are drugs stored in building? Location(s): Are weapons stored in building? Location(s): The following programs are offered as a public service of the Weld County Sheriff's Office. Please indicate the programs of interest. Physical Security Check Crime Prevention Presentation UTILITY SHUT OFF LOCATIONS: Main Electrical: Gas Shut Off: Exterior Water Shutoff: Interior Water Shutoff: PATRICK ENGINEERING GROUNDWATER LOAD OUT & RECYCLING FACILITY USE BY SPECIAL REVIEW PERMIT WASTE HANDLING PLAN Prepared By: Patrick Engineering On Behalf of: Halliburton Energy Services, Inc. Date Prepared: May 2011 Date Revised: November 2012 Background Halliburton Energy Services is proposing to amend the existing (Phase I) groundwater load out facility to allow for a commercial water recycling facility (Phase II) within the Agricultural Zone District. The intent of the Phase II recycling facility is to provide treatment, recycling and disposal for water used in regional drilling operations. The Pawnee Facility, as a combined groundwater load out and recycling facility, will support oil and gas companies for their drilling operations within a 50 -mile radius, as well as continue to have the ability to supply groundwater for municipal, industrial, and irrigation uses. The recycling facility will be located directly adjacent to the south, of the existing groundwater load out facility, on the same 80 -acre parcel. The facility is located approximately 4 miles southeast of Grover, CO, bordered by County Road 118 and County Road 95 to the north and west respectively and more particularly described as the West %2 of the NW 1/4 of Section 13, Township 10N, Range 61 West of the 6t" P.M. Waste Handling Plan Halliburton Energy Services proposes to incorporate the following waste management controls to strive for compliance with applicable State and National environmental health standards. 1) A portion of the potential wastes to be generated onsite are expected to be comprised of household wastes and human waste/sewage. Trash containers and portable toilets will be located on -site during groundwater load out operations. Toilet holding tanks will be pumped bi- weekly or as needed, and their contents will be fully disposed of at proper municipal treatment facility(s). Trash will be contained within fully enclosed containers 24 hours a day, and will not be burned on -site. Any and all trash spills will be cleaned immediately following their discovery, with 1400 west 122nd Avenue, Suite 102, Westminster, Colorado 80234 1303-532-8620 I patrickengineering.com PATRICK ENGINEERING the spilled contents replaced into the proper receptacles. Leaking and/or damaged receptacles will be repaired or replaced prior to their reuse. Any household waste generated onsite will be picked up on a regular basis by: Waste Chasers 75 Oak Ave. Eaton, CO 80615 2) The bulk of the wastes to be generated on the site are those inherent to this type of recycling and treatment facility. By their nature, oil field waste water contains components whose removal is desirable if the fluids are to be reused in drilling and completion activities. This waste can include oil and/or condensate, formation solids, drilling fluids, fracturing fluid residuals, proppant, and dissolved solids from connate water. The treatment process to be employed at this facility is expected to remove many, but not all, of these constituents. The process will concentrate the waste in 500 - bbl settling tanks which will require periodic removal. The sludge in these tanks will be dewatered using conventional methods (centrifuge, filter press, etc.). The dewatering process will take place within the secondary containment area. The liquid fraction will be returned to the IB tanks for treatment, and the dried residual will be collected, tested and hauled to a licensed solid waste facility for disposal. The weight of the dewatered/dried waste, which will be weighed at the landfill, will be tracked and recorded monthly at the facility, where it will be divided by the monthly volume of water treated (converted to tons) to give a weight percentage of the waste generated by the treatment process. The frequency of sludge removal will depend on the amount and nature of the influents. Previous work suggests that sludge operations are necessary every 80-100,000bbls. At the anticipated level of oil field waters, this could be monthly. Dried solids are expected to be 1-2% of the total volume treated. This waste will be collected in a dedicated container and hauled off site when full. Dried material is not expected to present nuisance odors that will drift off the site. Testing conducted to date suggests that dried solids contain mostly clays, dehydrated frac gel (guar or a derivative), some metals (iron, alkali earths, trace heavies), and residual oil. Dried samples will be submitted to an EPA -approved laboratory annually, for a full analysis including heavy metals and NORMs. Downstream of the grit chambers, oils that are recovered in the oil/water separators during the treatment process will be stored in two 500 -bbl oil tanks. The two tanks shall float together so that oil is equally distributed or discharged from the two tanks. One oil load out station will be controlled and regulated by the SCADA monitoring system. The SCADA system will easily allow 1400 west 122nd Avenue, Suite 102, Westminster, Colorado 80234 1303-532-8620 I patrickengineering.com PATRICK ENGINEERING for the amount of oil recovered to be tracked and reported monthly. Just as is the case with the outgoing brine loading stations, the oil loading station must be activated by the truck driver swiping his client and driver -specific mag card. Once the station is active, the driver can begin loading his truck with oil through a flex pipe with cam -lock connections. 3) All treatment and recycling processes, piping, storage tanks are located within a depressed, concrete and HDPE secondary containment lined area that will contain any potential spills, floods or contaminated storm water. Please refer to the Spill Prevention Control and Countermeasure (SPCC) Plan, included with the USR Submittal. 1400 west 122nd Avenue, Suite 102, Westminster, Colorado 80234 1303-532-8620 I patrickengineering.com PATRICK ENGINEERING GROUNDWATER LOAD OUT & RECYCLING FACILITY USE BY SPECIAL REVIEW PERMIT DUST ABATEMENT PLAN Prepared By: Patrick Engineering On Behalf of: Halliburton Energy Services, Inc. Date Prepared: May 2011 Date Revised: November 2012 Background Halliburton Energy Services is proposing to amend the existing (Phase I) groundwater load out facility to allow for a commercial water recycling facility (Phase II) within the Agricultural Zone District. The intent of the Phase II recycling facility is to provide treatment, recycling and disposal for water used in regional drilling operations. The Pawnee Facility, as a combined groundwater load out and recycling facility, will support oil and gas companies for their drilling operations within a 50 -mile radius, as well as continue to have the ability to supply groundwater for municipal, industrial, and irrigation uses. The recycling facility will be located directly adjacent to the south, of the existing groundwater load out facility, on the same 80 -acre parcel. The facility is located approximately 4 miles southeast of Grover, CO, bordered by County Road 118 and County Road 95 to the north and west respectively and more particularly described as the West 'A of the NW 1/4 of Section 13, Township 10N, Range 61 West of the 6th P.M. Dust Abatement Plan (Fugitive Particulate Emissions Control Plan) Halliburton Energy Services will incorporate dust mitigation controls in compliance with County requirements. The proposed dust mitigation techniques include the following: • On -site aggregate pavement drive aisles will be watered for dust control as needed. • County Road 95 adjacent to the Load Out Facility will be watered for dust control as needed. • On -site vehicle speeds, as well as off -site truck haul route speeds, will be restricted to reduce the amount of dust generated. • Tracking pads consisting of double cattle guards have been installed (during Phase I) at the facility access onto County Road 95. 1400 West 122nd Avenue, Suite 102, Westminster, Colorado 80234 1303.532.8620 I patrickengineering.com STATE OF COLORADO John W. Hickenlooper, Governor Christopher E. Urbina, MD, MPH Executive Director and Chief Medical Officer Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 Located in Glendale, Colorado http://www.cdphe.state.co.us April 26, 2013 Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Bob Shea Water Treatment Professional Production Enhancement Halliburton 1125 17th Street, Suite 1900 Denver, CO 80202 Mickey Leyba-Farnsworth Project Manager Patrick Engineering 1400 West 122nd Avenue Westminster, CO 80234 Colorado Department of Public Health and Environment RE: Approval- llalliburton's Pawnee Stationary Commercial Water Recycling Facility Operations Plan Mr. Shea and Ms. Leyba-Farnsworth, The Colorado Department of Public Health and Environment, Hazardous Materials and Solid Waste Management Division (the "Division") appreciates the opportunity to review the Pawnee Stationary Commercial Water Recycling Facility Operations Plan revisions ("the revised D&O plan") submitted to the Division on March 26, 2013. The Division has determined that the proposed Pawnee Commercial Water Recycling Facility's revised D&O plan and SPCC Plan comply with the requirements of Section 8 of the Regulations Pertaining to Solid Waste Sites and Facilities, 6 CCR 1007-2. Part 1. The first submittal of the Pawnee Stationary Commercial Water Recycling Facility Operations Plan was submitted to the Division on November 26, 2012 and the Division requested additional information based on the original plan on February 4, 2013. The revised D&O plan received on March 26, 2013 provided additional calculations in the Spill Prevention Containment and Countermeasures Plan ("SPCC Plan"), clarification on tank sizes and underground piping, and the unloading and truck wash pad designs that were requested in the Division's February 4, 2012 comment letter. The proposed produced water recycling facility is located at 57748 CR 95 in Weld County, CO and will treat and recycle water produced during oil and gas drilling operations. Produced water is treated in a series of specialized tanks that remove solids and other contaminants, creating a quality of water acceptable for reuse in oil and gas drilling operations. The Division's approval to operate as a recycling facility is based on the following criteria: 1. The facility will not negatively impact groundwater; 2. The facility will not create offsite odors; 3. The recycled water will only be used for downhole uses; 4. The facility will maintain a 75% annual turnover for the water recycled at the facility; and 5. Operation of the facility complies with all other local, federal and state regulations. Sincerely, hr, -t David Snapp Environmental Protection Specialist Solid Waste and Materials Management Program Hazardous Materials and Waste Management Division Charles G. Jo n, Manager Solid Waste and Materials Management Program Hazardous Materials and Waste Management Division CC: Troy Swain, Weld County Department of Public Health and Environment Kim Ogle, Weld County Planning Office Robert Eber, Colorado Attorney General's Office Trim: SW/WLD/HAL 1.1 From: Kim Ogle To: "Levba-Farnsworth. Mickey" Cc: Kristine Ranslen-; Jim Oale Subject: RE: USR12-0077 Pawnee Phase II Recycling Facility Date: Saturday, March 30, 2013 4:24:54 PM Mickey I am waiting for the final determination from CDPHE and Troy's comments prior to completing the staff report. I have a 80% draft of comments in place and would like to schedule this case for PC on May 7, realizing that CDPHE may not have a letter to the County before this date. Please submit mineral notice for this hearing date. Call with questions. Thanks Mickey. Kim Kim Ogle Planner Ill Department of Planning 1555 North 17th Avenue Greeley, Colorado 80631 Direct: 970.353.6100 x 3549 Office: 970.353.6100 x 3540 Facsimile: 970.304.6498 Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited. From: Leyba-Farnsworth, Mickey [mailto:mleyba@patrickco.com] Sent: Monday, February 25, 2013 12:15 PM To: Donald Carroll Cc: Kim Ogle Subject: FW: USR12-0077 Pawnee Phase II Recycling Facility Donald, I am following up on the email I sent last Monday regarding USR12-0077 (Pawnee Phase II Recycling Facility). Our Team is currently working to address referral comments and request your assistance in order to adequately address your Traffic Study comments. Please let me know if you have any questions or if I may provide any additional information. Your assistance is appreciated. Mickey Leyba-Farnsworth Project Manager Office 303.532.8627 Cell: 720.212.9598 From: Leyba-Farnsworth, Mickey Sent: Monday, February 18, 2013 6:00 PM To: Donald Carroll Subject: USR12-0077 Pawnee Phase II Recycling Facility Don — I received your review memorandum for USR12-0077 and am currently working on addressing the comments. In regard to Traffic Study comment No. 1, you requested we submit a revised copy of the study that is signed, stamped, and dated. We are not intending for any changes to be required or be made to the 2011 Traffic Study that was accepted by the County. Since our application is for the purpose of amending the Pawnee Water Loadout USR, we propose submitting a Phase II Traffic Narrative Memorandum that is signed, stamped, and dated by a registered engineer licensed in the State of Colorado. Will you confirm if this will be acceptable for addressing your comment? The traffic memorandum would confirm that the 2011 study prepared for the Phase I loadout facility remains valid. The number of trucks to access the facility is anticipated to be reduced. With the addition of the Phase II operations the Facility will reduce truck traffic on local roads by providing a convenient one -stop location to drop off, recycle, and load treated water for local oil and operations. The facility will also provide the opportunity for water surface transfer lines to be utilized in order to support local operations instead of trucks, further reducing ruck traffic. Thank you for your assistance and please let me know if you have any questions. If the proposed traffic memorandum is acceptable, I will have it prepared and forward it to you once complete. Thank you. Mickey Leyba-Farnsworth Project Manager Office 303.532.8627 Cell: 303.594.4542 From: Troy Swain To: rim Ogle Cc: Tom Parko; Trevor Jiricek Subject: USR12-0077 Halliburton Pawnee Water Station & Water Recycle Facility Date: Tuesday, April 09, 2013 11:33:14 AM Attachments: }ialliburton Pawnee Recycling Facility DRAFT HD Referal MEMO.docx USR12-0077 Halliburton Pawnee Water Station & Water Recycle Facility Kim, here's a draft provided the Class II Injection Well will be a future use requiring a minor amendment at that time and that no financial assurance (FA) will be required. The Department has a legacy condition on Class II Injection Wells (similar type facility and same waste being handled) that states if COGCC does not have authority for FA that FA must be posted with County. As discussed, have a call in to Trevor re this legacy condition. Also, recycling facilities (this will be designated as such by CDPHE) are not required to post FA with CDPHE. Troy E. Swain EH Program Coordinator Weld County Dept. of Public Health & Environment 1555 N. 17th Avenue Greeley, CO 80631 (970) 304-6415, ext. 2219 (970) 673-2218 (cell) (970) 304-6411 (fax) Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited. PATTON 8OOGS,, March 21, 2013 VIA EMAIL AND U.S. MAIL Mr. Charles G. Johnson, Manager Mr. David Snapp, Environmental Protection Specialist Solid Waste and Materials Management Program Hazardous Materials and Waste Management Division Colorado Department of Public Health and Environment 4300 Cherry Creek Dr. South Denver, CO 80246-1530 1801 California Street Suite 4900 Denver, CO 80202 303-830-1775 Facsimile 303.894-9239 wwwpattonboggs.com Anne I) f lan•ington 303-894-6179 aharrington@pattonboggs.com Re: Response to Department's Comments on the Pawnee Stationary Commercial Water Recycling Facility Operations and SPCC Plans Messrs. Johnson and Snapp, On behalf of Halliburton Energy Services, Inc., I am writing to respond to your February 4, 2013 letter in which you provided comments based on your review of the Pawnee Stationary Commercial. Water Recycling .Facility Operations Plan (the "Operations Plan") and the accompanying Spill Prevention and Countermeasure Plan (the "SPCC Plan") submitted to the Division on November 26, 2012 and December 17, 2012, respectively. The goal of this letter is to address your comments and requests for clarification so that the Division can make a final determination that the Pawnee Stationary Commercial Water Recycling Facility (the "Facility") qualifies as a recycling facility subject to Section 8, Recycling and Beneficial Use, of the regulations pertaining to Solid Waste Sites and Facilities, 6 CCR 1007-2, Part 1. Enclosed with this letter are updated versions of both the Operations Plan and the SPCC Plan, incorporating your requested changes or clarifications. For your convenience, we have provided a summary of our responses to your comments below. Comments Regarding the Operations Plan: 1. On Page 2 under Section 3, Facility Design and Process Description, the height of the "IB" and "OB" tanks is described as 24" high. Please verify that this is the design height, or correct accordingly. 4848.6241-0259.1. Washington DC I Northern Virginia I New Jersey I New York I Dallas I Denver I Anchorage I Doha I Abu Dhabi PATTON NHL March 21, 2013 Page 2 • Response: Section 3(a), Paragraph 2 of the Operations Plan has been updated to correctly state that the IB and OB tanks are 24 feet high rather than 24 inches high. 2. On Page 4, in the first and second paragraphs the incoming brine tanks' volume is described as 5000 BBL(s). The tanks are identified as 2500 BBL tanks in other sections of the Recycling Plan. Please identify the appropriate volume and correct. • Response: The Truck Tank Wash description in Section 3(b) of the Operations Plan has been updated to correctly state that the incoming brine tanks have a volume of 2,500 gallons. 3. The second paragraph of page 4 references a schematic in "Exhibit 5D." The Division did not receive a schematic labeled 5D. Please provide Exhibit 5D with the response to these comments. • Response: Exhibit SD, a schematic of the loading / unloading and truck tank wash pad plan, sections and details, is enclosed with this letter. The sheet number identified in the title block has been revised to reflect EX -5D. 4. Underground piping details and leak detection systems/elements are not provided or described in the Recycling Plan. Please provide the leak detection details with your response to these comments. • Response: Section 4(a) of the Operations Plan describes the leak detection systems/elements of the facility. Reference to the drawing exhibits has been updated to reflect Exhibits 5B, 5C, and 5D rather than 5A, 5B, and 5C. Exhibits 5D — 5K have been revised to include a note that states, "All underground piping used for recycled liquid transport shall be double -wall pipe. Only above ground piping shall be located within the secondary containment area." 5. The engineered plans are not stamped and signed by a professional engineer licensed by the State of Colorado. Please submit plans that are stamped and signed by a professional engineer Registered by the State of Colorado. The Division only requests those designs already submitted with the Recycling Plan and those additional designs requested in this letter. • Response: The engineered drawing exhibits have been stamped and sealed by a professional engineer licensed by the State of Colorado. The drawings have been stamped as "Preliminary Not for Construction." In addition, a note has been added to each of the sheets indicating that the exhibits have been issued for commercial recycling designation and Weld County USR approval. 4848-6241-0259.1. PATTON BOGGS. March 21, 2013 Page 3 Comments Regarding the SPCC Plan: 1. Please state that the SPCC Plan will be certified by a professional engineer licensed by the State of Colorado prior to facility operations. Also, please state that the certified plan will be submitted to the Division for review and approval prior to commencing operations. • Response: Halliburton hereby confirms that the SPCC Plan will be certified by a professional engineer licensed by the State of Colorado and that the certified plan will be submitted to the Division for review and approval prior to operation of the Facility. 2. Figure C-1 does not show underground or connecting pipes. Please submit designs for the underground piping to the Division. • Response: Please see Exhibits 5D — 5K of the Operations Plan, which show underground or connecting pipes. As stated above, these exhibits have been revised to include a note that states, "All underground piping used for recycled liquid transport shall be double -wall pipe. Only above ground piping shall be located within the secondary containment area." 3. Please include the expected date for the installation of the spill kits in Section 3.3. • Response: Though the construction dates for the Facility are unknown, Halliburton intends to install the spill kits described in Section 3.3 prior to final approval of the SPCC Plan and prior to operation of the Facility. 4. Section 5.0, Failure Analysis and Containment, addresses containment volumes of the outgoing oil tanks, and the oil separator tanks. Please explain why containment of the volume of wastes in the incoming brine tanks, Cleanwave treatment tanks, and the outgoing brine tanks were not considered in the containment calculations and in Table 1. • Response: As requested by the Division, Table 1(Facility Survey) and Table 2 (Failure Analysis and Containment) have been modified to include the Incoming Brine (IB) Tanks, the C1eanWaveTM Treatment Tanks and the Outgoing Brine (OB) Tanks and are enclosed with this letter. These components were initially excluded from the Facility Survey because it was our understanding that the low concentration of oil in the units referenced would classify them as non -oil. This is especially true for the outgoing brine tanks, which are designed to hold treated water suitable for use in drilling and production operations. The level of treatment using Halliburton's CleanWaveTM (electrocoagulation) technology is such that suspended solids, heavy metals, some alkali earth metals, and residual hydrocarbons are removed, and the resulting product is reusable brine. We understand that dependent on the Division's definition of oil, the incoming brine and material within the treatment system would need to be included in the 4848-6241-0259.1. PATTON OOHS.P March 21, 2013 Page 4 containment volumes. Accordingly, the containment volume for these storage areas as well as the outgoing brine tanks will be contained within the secondary containment area and are included in the facility survey as well as the containment calculations of the SPCC Plan. All tanks that could possibly contain traces of oil are adequately contained within the Facility's secondary containment structure. Please do not hesitate to contact me if you have any questions about the additional information provided herein, which we hope will enable the Division to deem the Facility a recycling facility subject to Section 8 of the regulations pertaining to Solid Waste Sites and Facilities, 6 CCR 1007- 2, Part 1. We looked forward to continuing to collaborate with the Division on this endeavor, and we appreciate your time and efforts in reviewing the Operations Plan and SPCC Plan. Best regards, Vla • Anne D. Harrington Enclosures cc: Robert Eber, Esq. Mr. Bob Shea Ms. Mickey Leyba-Farnsworth Carolyn McIntosh, Esq. 4848-6241-1125').1. From: Mickey Leyba-Farnsworth To: Kim Ogle Cc: Troy Swain; Tom Parko Subject: RE: Pawnee Stationary Commercial Water Recycling Facility Date: Wednesday, January 23, 2013 2:03:56 PM Kim - I am following up on the status of the Pawnee Phase II referral process and staff report. contacted David Snapp from CDPHE and he indicated he had finished his review of our application and would be sending his comments off to one of their engineers to look at this week. Can you provide me an update as to when we can expect to receive your staff report with referral comments. Thank you. Mickey From: Kim Ogle [mailto:kogle@co.weld.co.us] Sent: Monday, January 07, 2013 12:54 PM To: Mickey Leyba-Farnsworth Cc: Troy Swain; Tom Parko Subject: Pawnee Stationary Commercial Water Recycling Facility Mickey Hello and Happy New Year. The referrals for the case are due back into the office on January 9, 2013. The Town of Grover called and indicated they would be unable to meet the referral deadline due to the scheduling of their Town Board meetings. I indicated that a late referral would be anticipated and would be incorporated into the staff report when received. Per previous discussions with Troy and Tom, I am not in receipt of the letter from CDPHE stating that the facility will be a recycling facility and will not required a Certificate of Designation (CD). As previously indicated to you, staff is unable to proceed with the scheduling of the land use hearing until this issue is resolved. If I may be of further assistance, please let me know. Kind regards, Kim Kim Ogle Planner III Department of Planning 1555 North 17th Avenue Greeley, Colorado 80631 Direct: 970.353.6100 x 3549 Office: 970.353.6100 x 3540 Facsimile: 970.304.6498 Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited. From: Troy Swain Sent: Wednesday, December 12, 2012 11:42 AM To: Snapp - CDPHE, David Cc: Kim Ogle; Tom Parko Subject: RE: Pawnee Stationary Commercial Water Recycling Facility David, CDPHE could send a letter to Weld County stating that the facility will be a recycling facility and will not required a Certificate of Designation (CD). Troy E. Swain EH Program Coordinator Weld County Dept. of Public Health & Environment 1555 N. 17th Avenue Greeley, CO 80631 (970) 304-6415, ext. 2219 (970) 673-2218 (cell) (970) 304-6411 (fax) Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited. From: Snapp - CDPHE, David[mailto:david.snapp(astate.co.us] Sent: Wednesday, December 12, 2012 10:03 AM To: Troy Swain Cc: Leyba-Farnsworth, Mickey Subject: Pawnee Stationary Commercial Water Recycling Facility Troy, I just spoke with Mickey Leyba Farnsworth regarding the Halliburton Pawnee Water Recycling Facility. She mentioned that she could not get a hearing with the county until CDPHE approved them as a recycling facility. Will they need to wait until they have a CDPHE approval letter in hand? Or can I simply say that CDPHE is evaluating their D&O plan to determine compliance with Section 8, but the facility is still subject to County approval? Let me know if there is something I can do to help them along with the county process. Thanks -David David Snapp Environmental Protection Specialist Hazardous Material and Waste Management Program Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver, CO 80246-1530 303-692-3425 I david.snapp@state.co.us From: Levba-Farnsworth. Mickey To: Kim Oale Cc: Troy Swain Subject: REQUIRE EVIDENCE OF APPROVAL FROM CDPHE BEFORE 7 -DAY COMPLETENESS COMMENTS RELEASED Date: Tuesday, November 27, 2012 8:01:39 PM Attachments: HalliburtonSAPCommentsll-19-2012.odf Kim — Our Team has submitted Halliburton's Recycling Facility Initial Registration and Application to be designated as a Recycling Facility, which was prepared pursuant to Federal, State and county requirements to CDPHE in c/o David Snapp on November 21, 2012. We have had two prior meetings with CDPHE in which Troy Swain attended regarding our application. We have confirmed that the Pawnee Project is considered by the state to constitute a commercial recycling facility subject to subsection 8.5 of the CDPHE regulations for "Industrial Recycling Operations" and exempt from the certificate of designation permitting process that is otherwise required for commercial solid waste disposal facilities under 6 CCR 1007-2 §1.3.3. In addition, we previously submitted our Draft Sampling and Analysis Plan to CDPHE and requested written comments regarding the groundwater monitoring well placement and baseline sampling plan. Attached for your reference is the comment review letter we received from the Division. Based on the above information we are requesting to move forward with the Weld County land use application. I would be happy to discuss our request in more detail and will provide any additional information. Thank you for your assistance and I look forward to continuing to work with you Troy on this project. Mickey Leyba-Farnsworth Project Manager Office 303.532.8627 Cell: 720.212.9598 Mickey Planning staff will require written evidence of determination that the Pawnee Water Depot is also permitted for a water recycling facility by the CDPHE or written evidence that a Certificate of Designation application has been submitted and conditionally approved before moving the land use application forward with Weld County. Questions on this issue may be addressed to Kim in Planning or Troy in Environmental Health. Thanks! Kim Kim Ogle Planner III Department of Planning 1555 North 17th Avenue Greeley, Colorado 80631 Direct: 970.353.6100 x 3549 Office: 970.353.6100 x 3540 Facsimile: 970.304.6498 Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited. From: ISv Swart To: urn Colo Cc: Sxee. MWd Subject RE: PRE12.0102 Pawnee(li.dee Date: Tuesday, November 27, 201211:36:30 AM Kim, as discussed, I'm not comfortable moving forward with these types of applications until and unless the recycling designation is approved by CDPHE Solid Waste. This designation, in effect, says a CD is not required it is a Recycling Facility. I will review the recycling designation application concurrently with CDPHE and have met twice with CDPHE and the applicant regarding the recycling designation. Based on these meetings, CDPHE's design requirements appear to have morphed beyond our (County) typical requirements for produced water recycling facilities. However, it should be noted that our typical facilities were co -located with existing injection wells where CDPHE jurisdiction has been limited to the recycling process itself (beginning where the produced water already treated for injection is diverted for recycling). Troy E. Swain EH Program Coordinator Weld County Dept. of Public Health & Environment 1555 N. 17th Avenue Greeley, CO 80631 (970) 304-6415, ext. 2219 (970) 673-2218 (cell) (970) 304-6411 (fax) Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited. From: Kim Ogle Sent: Tuesday, November 27, 2012 10:20 AM To: Troy Swain; Oonald Carroll; Frank Piacentino Cc: 'Mickey Leyba-Farnsworth' Subject: PRE12-0102 Pawnee[1).doc All A 7 -Day completeness review application is into the Planning office for review and comment. Please find attached the link to the case commencing on page 3 jGnnc//arrelawehrgwpJ4rn ns/onrtlnts/rao/ranarmmarv/CanTahf,:mmary dn> jnode=tabSummarv&servicePmviderfnde=WFI DA,ID1=12CAP&ID2=00000&103=00080&re0uireNotice=YES&clearForm=clearForm&module=Planning&isFmmCaoList=tme&isGeneralCAP=Y Questions, please contact me at 3549. Thanks! Kim PS. Mickey, I pulled the contract from the application, will requested redacted copy to be submitted when application is deemed complete K. Kim Ogle Planner in Department of Planning 1555 North 17th Avenue Greeley, Colorado 8063I Direct: 970.353.6200x 3549 Mee: 970.353.6100 x 3540 Facsimile: 970.300. 6498 Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient Is strictly prohibited. STATE OF COLORADO John W. Hickenlooper, Governor Christopher E. Urbina, MD, MPH Executive Director and Chief Medical Officer Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Laboratory Services Division Denver, Colorado 80246-1530 8100 Lowry Blvd. Phone (303) 692-2000 Denver, Colorado 80230.6928 Located in Glendale, Colorado (303) 692-3090 http://www.cdphe.state.co.us November 19, 2012 Mickey Leyba-Farnsworth Project Manager Patrick Engineering 1400 West 122114 Avenue, Suite 102 Westminster, CO 80234 Colorado Department of Public Health and Environment RE: Comments In Response to the Draft Sampling and Analysis Plan For Pawnee Water Loadout Facility Ms. Leyba-Farnsworth, The Hazardous Waste and Materials Management Division ("the Division") of the Colorado Department of Public Health and Environment ("the Department") appreciates the opportunity to review the Draft Sampling and Analysis Plan ("Draft SAP") provided to the Division during a meeting with Patrick Engineering, Halliburton, Patton Boggs and Division staff on October 26, 2012. The Draft SAP details specific ground water monitoring details for the proposed Pawnee Water Loadout Facility ("the Facility") located at the intersection of County Road 95 and County Road 118, in Weld County, CO. The Facility will serve as recycling option for multiple oil and gas produced water haulers in the area. The Facility will treat produced water and send the water back into the oil field of generation for reuse in the drilling process. Commercial produced water recycling facilities are required to meet the requirements of Section 8.5 of the Regulations Pertaining to Solid Waste Disposal Sites and Facilities 6 CCR 1007-2, Part 1 ("the Regulations"). Section 8.5 requires facilities that recycle liquid or leachable materials to provide the Division a Design and Operations Plan ("D&O Plan") for review and approval prior to construction and operation. The Draft SAP is one component of the broader D&O Plan. On November 1, 2012, Patrick Engineering requested the Division provide written comments regarding the groundwater monitoring well placement and baseline sampling plan. The Division recommends the following additions to the Draft SAP: 1. The planned onsite well locations are acceptable. However, groundwater flow shall be confirmed and documented based on the results from implementing the Final SAP. Well locations shall be modified if the groundwater flow is found to differ from the initial findings. 2. The groundwater monitoring well construction shall comply with the requirements of the Colorado State Engineer's Office. 3. The onsite baseline sampling shall include the entire list of constituents for Table A. If the first sampling event shows non -detect for the organic constituents, the facility may request, with justification and supporting information, that the Division and the County consider reducing the constituents used in on- going sampling program. The non -detect levels shall have a minimum detection level at or below the state groundwater water standards. Please specify, in the Final SAP, which constituents will be tested for on an ongoing basis. Baseline monitoring shall consist of the entire list of constituents in Table A if they are detected during the initial sampling events. Baseline shall be assessed by sampling and analyzing each on -site well every three months for two years. 4. As stated in Appendix B(B3)(G) of the Regulations, "Following collection of background constituent concentration data, the owner of operator must specify in the operating record one or more of the following statistical methods to be used in evaluating ground water monitoring data for each hazardous waste constituent." Please identify which statistical method will be use to analyze groundwater monitoring data following the collection of background concentrations. Please keep in mind that the above requirements only include additional requirements to satisfy the Division's Regulations. The SAP is subject to approval by the Weld County Department of Public Health and Environment and shall meet all other applicable state, local or federal requirements. In closing, the Division is authorized to bill for its review of technical submittals at $125 per hour, pursuant to section 1.7 of the Solid Waste Regulations. An invoice for the Division's review of the above referenced document will be sent under separate cover. Please contact David Snapp at (303) 692-3425 or Charles Johnson at (303) 692-3348 if you have any questions regarding this letter. Sincerely, David Snapp Environmental Protection Specialist Solid Waste and Materials Management Program Hazardous Materials and Waste Management Division Charles G. Jgfijrfson, Manager Solid Waste nd Materials Management Program Hazardous Materials and Waste Management Division CC: Troy Swain, Weld County Department of Public Health and Environment Bob Shea, Halliburton SW/WLD/HAL 4.3 TABLE 2 FAILURE ANALYSIS AND CONTAINMENT STORAGE AREA NAME AND CONTAINER NOS. FAILURE TYPE, VOL OF LARGEST CONTAINER, AND RESULT IS CONTAINMENT SYSTEM OR DIVERSIONARY STRUCTUREEa] W/ MINIMUM VOL OF 110% OF LARGEST CONTAINER PROVIDED? DESCRIBE DISCHARGE CONTROLS AND PATH TO NEAREST OUTFALL Incoming Brine Tanks Tank: Rupture, 105,000 gal into integral concrete containment. Yes. Concrete containment is adequate to capture contents of tank and precipitation. Loading: Hose disconnection or tank truck rupture, 2500 gal into concrete containment. Cleanwave Treatment Tanks Tank: Rupture, 21,000 gal into integral concrete containment Yes. Concrete containment is adequate to capture contents of tank and precipitation. Outgoing Brine Tanks Tank: Rupture, 210,000 gal into integral concrete containment. Yes. Concrete containment is adequate to capture contents of tank and precipitation. Loading: Hose disconnection or tank truck rupture, 2500 gal into concrete containment. Oil Storage Tanks Tank: Rupture, 21,000 gal into integral concrete containment. Yes. Concrete containment is adequate to capture contents of tank and precipitation. Loading: Hose disconnection or tank truck rupture, 2500 gal into concrete containment. Yes. Concrete containment is adequate to capture contents of tank truck and precipitation. Unloading Bays for Incoming Brine Unloading: Hose disconnection or tank truck rupture, 2500 gal into concrete containment. Yes. Concrete containment is adequate to capture contents of tank truck and precipitation. Loading Bays for Outgoing Brine Loading: Hose disconnection or tank truck rupture, 2500 gal into concrete containment. Yes. Concrete containment is adequate to capture contents of tank truck and precipitation. 0 I- 'm 2 CO N • ui cW 30 ^• m N 8N m N 02 m 0) C 5 W u o O 4, ✓ m • m • 3 H J a DATE OF SURVEY: Recycling Storage Tanks end Treatment Area O a 9yal t4,0#4,54,/04"%2Rz2 ,�2 a'ibge p col, YES "I!4 z '' 4 4i�, 4.-4>k,%�°9'y 66 3 3 3 3 2 0 `pf�y,)pb0 b b% i n A 6 /p gOp G.. V›.... Y iP OObp bye O� Ti g gz i 2 VA, bb^rb° -, r °iy0.4. l by bbr op N#0., b "J' '6t' ! s WRAPPED a a * c ° * s C y 0 i 5 s 04,045>, +0-44_0 y %Iv.% O i YES z z NO z (v 4 O r 'AUTO CUTOFF VISUAL VISUAL O 2 AUTO CUTOFF 0 O °J '0,,,,,,, 0 C C C �`ya�J pifl, 9p$�S� b s z 4i g z 2 4z b°6 se NORMAL NORMAL NORMAL .9(0 2 44 a 0 0 0 0 0 0 0 %N 96�°b� OO Cl 6' p /j, f obo ` �)1‘1.1,7„ '1/ )i .y4/flit, p) b d' B O di 0)0 '!! 0o O Yj �'ry� m N +. N F, N E N e72 R .= g '2 g ¢f T 0 w O m > 9 m a k 0 xw in O W o FIELD WELDED w D a d FIELDWELDED VOYp. 46i, w '14 w w w w LculLL w �d bOe% L N +z N z z z x 'j z (-IJ b. �)4'bb4 dl /hio op y N N S N N N ., a b Yong y` o°�Ob 40.4 °o 3. _ ro _ o O CYLINDRICAL CONTAINER I RECTANGULAR C <LOl te s t v t J Z ro 4. a, pt ) z O z e Z - 2 4>k - 0 0 '2) 04.41 ra c. �)r°h S K a S 3 VL s L CHarmwe Tr gmenl Tank 3 �b J°v Rj 7'��, 4..s4 )ba 0,4:4 4>- %4'4'e6.*'4 pa glop b°v ,f o s o V r a 2 l 3 2 k 5 4 s 5 5 ie J e a z O Y O w e n`' � p O a > O a y O 3 z > /al°Y°'Ja�Y 6 (,b s '°b b" bb �ke> C8ip. °Zj`°6O r N . N OJ a. r N r N r N N r�0 y� O° ob.O C0y b a a a 0 a a a /b°Ra,J DRUM TANK Y 4:42"`U cv �b're b6 o. Nb, -4 Y Y 3 3 0 Y c ,a- a Drum 0 $ __ € y fi Cb 5 5 g u g 5 N 8 5J N 2 8 .2 i. f .9 ail O 0) e N a CC W 4 cc r W r 3 2 0 J O O 8 at G F Q c e5 iV 26 a a TI a>a"gz =aar.x3 8 tu z 2 U m 0 W 4- >a &S O 0 22 cc O 2 a O 2 LL w s z 0 V 0 0 0 O N O Z 0 G Yz₹ a N RECTANGULAR 0 z G a Y 2 0 0 0 0 6 a 2 I' 0 Oa m' a a a 2 h 2 4,4 2 O 4 CC 0 a Oa C05. C DIMENSIONS 2 m 0 a 2 t C'' O 0 2 It a Z O z It c w 8 2 7„d5 F ctin6 N j W S an: 5 15g0 a0 8 00oo 0 a 8 0 U o y J W g C a W w 8 8 C 2 a 5 W Q 2 CO 52 io a _. h It 2 z It 0 2 It 3 U a 0 N 2 It 0 a O 2 2 C It 0 2 �p 8 a O W 028 55'2 A O, O. 2 2 0 2 HDOHT OR DEPTH 2 It TOP INNER LENGTH 2 It 70P INNER MOM z It C 0 K 8 aeti,000em$. and qty, to 0 Si t]t 14 KEI All UI as Sts 0 Pawnee - SPCC Table 1 REV1 3-20-13.xls, Storage Area © 2012 Halliburton. All Rights Reserved. Version 3, Issued 3/2712012 Hello