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Home My WebLink About20093533.tiff'014R Wilk COLORADO October 6, 2009 Cliff Roberts EnCana Oil & Gas (USA) Inc. 1313 Denver Avenue Ft, Lupton, CO 80621 DEPARTMENT OF PUBLIC HEALTH & ENVIRONMENT 1555 N. 17th Avenue Greeley, CO 80631 WEBSITE: www.co.weld.co.us ADMINISTRATION: (970) 304-6410 FAX: (970) 304-6412 PUBLIC HEALTH EDUCATION & NURSING: (970) 304-6420 FAX: (970) 304-6416 ENVIRONMENTAL HEALTH SERVICES: (970) 304-6415 FAX: (970) 304-6411 Wald Cah+tts +NlonmIna Departhne>Zt C d txl�RN OFFICE 1,r iv `� 7 MIN f� 9VED EnCana Oil & Gas (USA), Inc., Soil Remediation Facility — 4th Quarter Inspection 2009 Dear Mr. Roberts: On October 1, 2009, the Weld County Dept. of Public Health & Environment conducted a routine inspection of the EnCana Oil & Gas (USA), Inc., Wattenberg Land Treatment Facility, located at 1245 Weld County Road 19, Weld County, Colorado. The purpose of the inspection was to assess the facility's compliance with 4th Amended Use by Special Review Permit #589 (4a' AmUSR-589) and the Weld County Code. There was no soil treatment taking place at the facility. In order to record the plat, Health Department related prior to recording the plat condition number 1. J. of 4th AmUSR-589 needs to be satisfied. Provide attachment referenced under the Storm Water Containment Structure & Capacity section of your Design & Operations Plan for the facility. The attachment was to consist of plans stamped and signed by a Colorado Licensed Professional Engineer that demonstrate stormwater run-on and run-off controls for the treatment area have been designed per COGCC Rule 908 b. (5) E. Also, please provide copies of any submittals and bonding documents provided to the Colorado Oil & Gas Conservation Commission related to recently revised provisions of Rule 908 g. regarding closure cost estimates and financial assurance. The Department will follow-up with you on your progress during the next quarterly inspection. If you have any questions, please contact me at (970) 304-6415, ext. 2219. Sincerely, Troy E. Swain Environmental Health Specialist Environmental Health Services cc- Trevor Jiricek, Director, Environmental Health Services (e-mail) Kim Ogle, Department of Planning Services Robert Chesson, COGCC — 1120 Lincoln Street, Suite 801, Denver, CO 80203 Scott Mason, EnCana Oil & Gas (USA) Inc. (e-mail) gppq-3f33 WI IDe COLORADO August 19, 2009 Cliff Roberts EnCana Oil & Gas (USA) Inc. 1313 Denver Avenue Ft. Lupton, CO 80621 DEPARTMENT OF PUBLIC HEALTH & ENVIRONMENT 1555 N. 17th Avenue Greeley, CO 80631 WEBSITE: w w co.wCldc•cr.t ADMINISTRATION: (970) 304-6410 FAX: (970) 304-6412 PUBLIC HEALTH EDUCATION & NURSING: (970) 304-6420 FAX: (970) 304-6416 ENVIRONMENTAL HEALTH SERVICES: (970) 304-6415 Weld County Planning Department FAX: (970) 304-6411 GREELEY OFFICE Ak IG 19 70n9 r YI4 f'r 11199 q t[ EnCana Oil & Gas (USA), Inc., Soil Remediation Facility — 3r° Quarter Inspection 2009 Dear Mr. Roberts: On August 12, 20(N. the Weld County Dept of Public Health & Environment conducted a routine inspection of the EnCana Oil & Gas (USA), Inc., Wattenberg Land Treatment Facility, located at 1245 Weld County Road 19, Weld County, Colorado. The purpose of the inspection was to assess the facility's compliance with 4`I' Amended Use by Special Review Permit #589 (4th AmUSR-589) and the Weld County Code. There was ito soil treatment taking, place at the facility. Therefore, no on -site inspection was arranged for this quarter. Prior to recording the plat condition number 1. J. of 4th AmUSR-589 still needs to be met: Provide attachineni referenced under the Storm Water Containment Structure & Capacity section of your Design & Operations Plan for the facility. The attachment was to consist of plans stamped and signed by a Colorado Licensed Professional Engineer that demonstrate stormwater run-on and run-off controls fur the treatment area have been designed per COGCC' Rule 908 b. (5) E. Also, please provide copies of any submittals and bonding documents provided to the Colorado Oil & C� �s Conservation Commission related to recently revised provisions of Rule 908 g. regarding closure cost estimates and financial assurance, The Department will follow-up with you on your progress during the next quarterly inspection. If you have any questions, please contact me at (970) 304-6415, ext. 2219. Sincerely, Troy E. Swain Environmental Health Specialist Environmental Health Services cc: Trevor Jiricek, Director, Environmental Health Services (e-rnail l Kim Ole, Department of Planning Services Robert Chesson, Colorado Oil and Gas Conservation Commission (e-mail) Scott Mason, EnCana Oil & Gas (USA Inc. (e-mail) ,aaq-333 PLaOac- M1 11. 5 eL-Cs • Troy Swain From: Sent: To: Cc: Subject: Attachments: 6-2-09 - Page 6 revised of Ops... Troy, Roberts, Cliff [CIiff.Roberts@encana.com] Tuesday, June 02, 2009 8:05 AM Troy Swain Trevor Jiricek RE: EnCana Land Farm & draft operations Plan incorporating land use conditions... 6-2-09 - Page 6 revises' og,QaPlan.doc 1 P Weld County planning uepaRmUUU GREELEY OFFICE (17e Jy (13 7ftfl9 5ft RECEIVED Attached is a revised copy of page 6 of 12 of the ops plan for the USR application. Sorry for the oversight ! Explains why I took a week of vacation ! Appreciate your cooperation and support !! Trevor, let's hook up and have lunch some day and talk about Maynard Nichols and your encounter as the "new guy". Remember?? Cliff Roberts Civil/Environmental Engineer EHS Field Coordinator D -J- Paradox EHS Off: (303) 774 - 3962 Cell (303) 720 - 3989 Original Message From: Troy Swain [mailto:tswain@co.weld.co.us] Sent: Friday, May 22, 2009 10:04 AM To: Roberts, Cliff Cc: Trevor Jiricek Subject: RE: EnCana Land Farm & draft operations Plan incorporating land use conditions... Cliff: Please make the following correction and send me a new page 6: You changed the 2nd sentences reference to 1,000 ppm to 500 ppm but not the reference in the 4th sentence. Page 6 of your Final Draft document under the Bio Cell Performance Monitoring. Change 1,000 ppm to new 500 ppm standard of the 900 Series COGCC Rules. Again, just send me a new page 6. Thanks, Troy E. Swain Environmental Health Specialist Weld County Dept. of Public Health & Environment 1555 N. 17th Avenue Greeley, CO 80631 (970) 304-6415, ext. 2219 (970) 304-6411 (fax) Original Message From: Roberts, Cliff [mailto:Cliff.Roberts@encana.com] Sent: Thursday, May 21, 2009 5:49 PM To: Troy Swain Subject: RE: EnCana Land Farm & draft operations Plan incorporating land use conditions... Troy, 1 30©c -3533 �V L_ Doa.5 Attached is the amended plan as per your recommendations. I will be on vacation next week so if anything comes up, please contact Scott in Denver. Thanks for your help ! Cliff Roberts Civil/Environmental Engineer EHS Field Coordinator D -J- Paradox EHS Off: (303) 774 - 3962 Cell (303) 720 - 3989 Original Message From: Troy Swain [mailto:tswain@co.weld.co.us] Sent: Thursday, May 21, 2009 4:39 PM To: Roberts, Cliff Subject: RE: EnCana Land Farm & draft operations Plan incorporating land use conditions... Cliff, please address the following items: Page 5 of your Final Draft document under Storm Water Containment Structure & Capacity does not contain the reference referring to the document as an attachment, as follows: [1.J.]"Storm Water Management Certification by a Professional Engineer." "A copy of the storm water plan and structures stamped by a PE is attached to this plan." Please include this reference to the attachment as mentioned in the previous e-mail. You can remove the reference to l.J. and add "Colorado" PE. Page 6 of your Final Draft document under the Bio Cell Performance Monitoring. Change 1,000 ppm to new 500 ppm standard of the 900 Series COGCC Rules. Page 10 of your Final Draft document under last paragraph of the Emergency Response Plan Section "Copies will be provided to COGCC." Please add "and Weld County Department of Public Health & Environment (or WCDPHE)" Troy E. Swain Environmental Health Specialist Weld County Dept. of Public Health & Environment 1555 N. 17th Avenue Greeley, CO 80631 (970) 304-6415, ext. 2219 (970) 304-6411 (fax) Original Message From: Roberts, Cliff [mailto:Cliff.Roberts@encana.com] Sent: Thursday, May 21, 2009 2:19 PM To: Troy Swain Cc: Trevor Jiricek; Jacqueline Hatch; Mason, Scott K. Subject: RE: EnCana Land Farm & draft operations Plan incorporating land use conditions... Great Troy ! See attached final draft of Operations Plan. Understand EnCana will send in the Storm Water Inspection/Certification when the work is complete. Cliff Roberts Civil/Environmental Engineer EHS Field Coordinator D -J'- Paradox EHS Off: (303) 774 - 3962 Cell (303) 720 - 3989 Original Message From: Troy Swain [mailto:tswain@co.weld.co.us] Sent: Thursday, May 21, 2009 2:11 PM To: Roberts, Cliff Cc: Trevor Jiricek; Jacqueline Hatch; Mason, Scott K. Subject: RE: EnCana Land Farm & draft operations Plan incorporating land use conditions... Cliff: The changes you proposed are acceptable. Please create a final version of the Operations Plan and send it to me. The Stormwater Design Certification was referred to as an attachment in your plan so you can forward the attachment to me when A.J. Wassenaar completes the work. When we receive the Stormwater Design Certifications and they are found acceptable you will have satisfied all health department related "prior to recording the plat" conditions of 4th Am-USR 589. Thanks, Troy E. Swain Environmental Health Specialist Weld County Dept. of Public Health & Environment 1555 N. 17th Avenue Greeley, CO 80631 (970) 304-6415, ext. 2219 (970) 304-6411 (fax) Original Message From: Roberts, Cliff [mailto:Cliff.Roberts@encana.com] Sent: Thursday, May 21, 2009 1:44 PM To: Troy Swain Cc: Mason, Scott K.; Trevor Jiricek; Axelson, John Subject: RE: EnCana Land Farm & draft operations Plan incorporating land use conditions... Troy, With regards to the following: I - J Storm Water - EnCana has engaged A.G. Wassenaar (AGW)to conduct an inspection and certification of the storm water structure for the land farm. Brian Glade, P.E. for AGW is currently working with the land surveyor to shoot a number of elevations at the site so that Brian can perform the necessary calculations required for certification. Hopefully, we will have the finished product soon. I - H Septic Systems - I have inserted a paragraph on page 9 of 12 of the operating plan under "Additional BMPs" which states as follows: "Portable Toilets/Septic System: At present, the facility is unmanned. Consequently, portable toilets will be used to accommodate the limited presence of EnCana employees at the site for pick up and drop off of stored materials at the site as well as the limited activities associated with the land farm. However, in the event that use of the facility involves the presence of EnCana employees at the site on a continuous basis, all existing septic systems at the site to be activated shall be inspected and certified by a Colorado Professional Engineer to be adequate for the proposed sewage load and will be in good working order. If inadequate, a repair permit will be obtained from Weld County and the system will be brought into compliance." If this language is acceptable, please let me know. I hope we can wrap up this process in the near future. Thanks for your guidance and support 3 in 'this matter. Give me a call if you have any questions or comments. Cliff Roberts Civil/Environmental Engineer EHS Field Coordinator D -J- Paradox EHS Off: (720) 774 - 3962 Cell (303) 720 - 3989 Original Message From: Troy Swain [mailto:tswain@co.weld.co.us] Sent: Wednesday, May 20, 2009 2:03 PM To: Roberts, Cliff Cc: Mason, Scott K.; Trevor Jiricek; Axelson, John Subject: EnCana Land Farm & draft operations Plan incorporating land use conditions... Cliff, here's the Departments response to your plan. Also, you may want to update the Management of Impacted Soils Section to reflect the TPH levels of the new version of the COGCC Rules (900 Series, Table 910-1). Thanks. Look forward to your revisions. Troy E. Swain Environmental Health Specialist Weld County Dept. of Public Health & Environment 1555 N. 17th Avenue Greeley, CO 80631 (970) 304-6415, ext. 2219 (970) 304-6411 (fax) This email communication and any files transmitted with it may contain confidential and or proprietary information and is provided for the use of the intended recipient only. Any review, retransmission or dissemination of this information by anyone other than the intended recipient is prohibited. If you receive this email in error, please contact the sender and delete this communication and any copies immediately. Thank you. http://www.encana.com ENCANA T. EnGana Oil & Gas (USA) Inc. AN OPERATIONS PLAN FOR A CENTRALIZED E & P WASTE MANAGEMENT (LAND FARM) FACILITY LOCATED AT 1245 WCR # 19 BRIGHTON, COLORADO PREPARED BY ENCANA OIL & GAS USA INC. 3601 Stagecoach Road Longmont, Colorado 80504 TABLE OF CONTENTS Section Name Page No. General Information 1 — 3 Geologic/Hydrologic Description 3 — 4 GOGCC Rules 907 & 908 4 — 5 Bio Management of Impacted Soils 5 — 6 Waste Handling 7 — 8 Additional BMPs 9 Emergency Response Plan 9 - 10 Soil & Ground Water Monitoring 10 — 11 Closure Plan 12 Surety Bond 12 Appendix Non — Hazardous Waste Manifest Document Storm Water Inspection Document and Certification OPERATIONS PLAN CENTRALIZED E & P WASTE MANAGEMENT FACILITY Page 1 of 12 GENERAL INFORMATION SECTION: Owner/Operator: EnCana Oil & Gas USA Inc. 3601 Stagecoach Road Longmont, Colorado 80504 Ph. (303) 659-7740 Fax. (303) 774 - 3973 Designated Contact Person(s): Surface Owner of Site: EnCana Oil & Gas USA Inc. 3601 Stagecoach Road Longmont, Colorado 80504 Ph. (303) 659-7740 Fax. (303) 774 - 3973 Mr. Cliff Roberts Legal Description of Site: A part of the SE/4 of the SE/4 of Section 28, Ti N, R67W, of the 6th P.M., Weld County, Colorado (see lengthy legal description included in the Appendix Section of this application). A General topographic, geologic, and hydrologic description and map of the site: Topographic Description of Section 28 and the Subject Site: Section 28 is part of the plains area of the Front Range with elevations ranging from 5,000 ' ASL to 5,081 ' ASL. The section is divided diagonally across its southwest - northeast axis by Big Dry Creek which represents the lowest elevation in the section and is part of the South Platte River water shed. The area to the southeast in the section drains in a northwest direction draining into the Big Dry Creek. The area to the northwest in the section slopes in a southeast direction and also drains into the Big Dry Creek. An irrigation levee enters and exits the northeast corner of the section in a horseshoe pattern. A small irrigation water storage pond is located in the southeast corner of the section and up gradient from the subject site. A second and larger irrigation water storage pond is located in the northwest corner of the section but is of no consequence to the subject site. Surface use of the section varies from dry land cultivation to irrigated cultivations with two farmsteads located in the section. The historic Wattenberg Gas Plant (no longer operating) is located in the southeast corner of the section and is up -gradient to Big Dry Creek. i OPERATIONS PLAN CENTRALIZED E & P WASTE MANAGEMENT FACILITY Page 2 of 12 Topographic Description of Section 28 and the Subject Site Cont'd: Currently, the gas plant site was, at one time, under a COGCC mandated ground water remediation project No. #000012. Subsequent to the construction of the gas plant, a portion of the extreme southeast corner of the gas plant was been split off to accommodate the Conquest Class II Disposal well facility and the EnCana production offices and pipe yard. These lot splits are excluded from the remaining Wattenberg Gas Plant site. The land farm facility site is part of the historic Wattenberg Gas Plant and is located in the extreme southern part of the plant site. The subject site is approximately 5.0 acres in size and has irregular boundaries created by pre-existing structures such as boundary fencing and fire lanes. The south and west boundaries of the subject site are bordered by a chain link fence, a 20 foot fire lane, and an exterior "Vee" Ditch which diverts surface runoff from the south from entering the subject site. The north edge of the proposed site is bordered by a fire land 20 feet in width which serves the dual purpose as a fire lane and as a diversion structure to force surface run off waters to the northwest and into the storm drain system. The east edge of the proposed site is bordered by a berm wall 15 feet wide and 36 inches high which runs the entire length of the east edge of the subject site and provides truck access via a ramp area. The subject site has been laser contoured to create a northwesterly drainage pattern with an average slope of 1 % with 5 feet of fall from the east edge to the west edge of the subject property - a distance of approximately 500 feet. This drainage from the proposed site culminates into a small "catch basin" which then drains into an 18 inch storm drain. The waters entering this storm drain pass through the drain to a storm water retention basin located to the north of the subject site but on the same property. More details on this storm water basin are provided in the section of this application dealing with the facility's design and engineering. A topographic map of section 28 and the subject site is included in the appendix section of this application. Conquest Class II Disposal Well Facility - The proposed land farm unit and the disposal well facility are separated by a chain link fence. The Conquest facility is up gradient to the proposed land farm unit. The entire east -west course of the subject fence is clear of any equipment or tanks. Conquest has a "spill/release" section in their operating manual which is attached to this document for review. An inspection of the Conquest site reveals that produced water delivered to the site is dumped in a two sided sloping concrete basin from which they are pumped through a filtering system either directly into the injection well or temporarily stored in one of several above ground steel tanks which are contained within a concrete bunker which the Conquest operator advises conforms with the containment regulations stipulated in the SPCC rules. Accidental spills or releases of E & P waters in the dump area or from the bunkered tank battery are remote possibilities, in our opinion. OPERATIONS PLAN CENTRALIZED E & P WASTE MANAGEMENT FACILITY Page 3 of 12 Topographic Description of Section 28 and the Subject Site Cont'd: However, Conquest has no diversion or containment structures for handling storm water runoff. Encana has constructed an elevated "fire road" 10 foot wide which will run along the north side of the chain link fence (property boundary line) as well as a continuation of that same fire road along the west Encana property line which will restrict the flow of any surface waters from the Conquest facility from entering the proposed land farm area. The distance from the injection wellhead to the chain link fence is approximately 30 feet. EnCana Pipe Yard - Further to the west along this same fence line and past the northwest corner of the Conquest property, Encana operates a pipe and tank yard. A recent inspection of the yard indicated that no tanks are currently being stored along this fence line. At present, there are no diversion or containment structures for handling storm water runoff. However, storm water from the pipe yard will be diverted to the west and thence north in the same manner as the storm waters from the Conquest site. GEOLOGIC & HYDROLOGIC INFORMATION SECTION: Geologic Description of Section 28 and the Site: The surface soils are represented by the Weld Loam with 1 to 3 percent slopes. This is a deep, well drained soil on smooth plains at elevations of 4,850 - to 5,000 feet. It formed in Aeolian deposits. Included in mapping are small areas of soils that have a subsoil of loam and light clay loam. Also included are some leveled areas. Typically, the surface layer of this Weld soil is brown loam about 8 inches thick. The subsoil is brown and pale brown heavy clay loam and light clay about 20 inches thick. The substratum to a depth > 60 inches is silt loam. With depth, hard gray clay is encountered underlain by a shale bed located at approximately 25 feet BGL. This shale bed is considered to be the top of an impermeable structural series that is includes coal stringers to a depth of 793 feet which is the deepest stratigraphy data available for the site. OPERATIONS PLAN CENTRALIZED E & P WASTE MANAGEMENT FACILITY Page 4 of 12 Hydrologic Description of Section 28 and the Site: The general hydrology for the section indicates that it is a part of the aquifer recharge area for the South Platte River system (Colorado Land Use Commission Map). The hydrology of the subject site best described in a series of cross sections developed previously for an air sparging project designed to remediate shallow ground water present in a series of sand stringers located at depths ranging from 15 to 25 feet. A large number of monitor wells were installed during the initial stage of this project which provides a detailed stratigraphy of the shallow soil structure at the subject site. Additionally, a rather deep domestic well 793 feet deep was drilled in 1974 to provide domestic water to the gas plant. This cross sectional data and well stratigraphy data is presented in the Appendix Section for further review. COGCC RULE 907 & 908 PROVISIONS SECTION: Site Plan: General Description: The land farm site is approximately 5.0 acres in size and part of a larger property approximately 60 acres in size which is owned by EnCana Oil & Gas USA Inc. The land farm site is located in the lower section of the larger property. Containment Structure Design: The containment structure in place at the land farm facility consists of an elevated fire road that encompasses the entire perimeter of the land farm treatment area with an average elevation of 2 feet AGL. This containment structure prevents the migration of any off site storm water from entering the land farm. Additionally, any storm water accumulated within the interior of the land farm is prevented from leaving the treatment area except through the storm water discharge pipe located at the west end of the land farm facility. Surface Contour Design: The entire land farm site was laser contoured to produce a surface flow gradient in a northwesterly direction (1 % average grade). Storm water accumulated within the land farm treatment area is directed to a storm water inlet located at the west end of the treatment area. The storm water travels down gradient in a buried 18 inch diameter pipe and discharges into a retention pond structure. OPERATIONS PLAN CENTRALIZED E & P WASTE MANAGEMENT FACILITY Page 5of12 Appropriate measures to limit access to the site: A chain link fence encompasses the site at present. A chain link gate with security access provides ingress/egress to the Wattenberg site. A pipe gate, located in the northeast corner of the land farm controls access to the land farm. The fencing pattern and locked gate policy restricts unauthorized entry by the public as well as restricting entry to the site by wildlife and domestic animals. Establishment of a fire lane around the perimeter of the site: A fire lane currently exists around the perimeter of the proposed facility which is 20 feet wide (except the fire lane on the north side which is 20 foot wide) with a 10 foot buffer zone to be maintained between the fire lanes and the treatment areas. The fire lane has been constructed to serve as a storm water diversion structure to prevent up gradient storm water runoff (Conquest and EnCana pipe yard) from entering the land farm area. Storm Water Containment Structure & Capacity: A storm water basin has been constructed approximately 160 feet north along the west fence line of the EnCana property to accept the surface run off waters from the subject site. The approximate dimensions of the basin are 60 feet wide X 200 feet long X an average depth of 3.5 feet and representing a storage volume capacity of approximately 42,000 cubic feet or 315,000 gallons of water. The 25 year 24 hour precipitation rate is for the subject site is 3.02 inches (based on 5 CCR 1002 - 81). The annual evaporation rate is 45.0 inches (based on data provided by the Greeley NRCS engineering staff). The estimated contained surface area of the subject site is 152,460 square feet. Given a 25 year - 24 hour event, the total potential volume of storm water accumulation is 38,115 cubic feet or 285,863 gallons. Therefore, the storm water basin has a calculated capacity of 110 % of the 25 - 24 hour event. A copy of the storm water plan and structures stamped by a Colorado PE is attached to this plan. BIO MANAGEMENT OF IMPACTED SOILS SECTION: Bio Cell Wind Rows — Bio cells will be constructed as "windrows" running east to west and parallel to the north and south fire roads. These bio cell rows will be created as tandem trucks deliver treatment soils to the facility from EnCana sites. The trucks will back up and dump their loads of soil beginning at a target flag at the beginning of the road. Each successive truck will dump its load up against the preceding soil pile. This dumping procedure will be followed until the row has reached the eastern end point, after which a new row will be started leaving a 15 foot space interval between each bio cell row. A front end loader will compact and shape the rows to provide a "pitch roof" pattern to minimize soil erosion and enhance crusting of the bio cell mass. OPERATIONS PLAN CENTRALIZED E & P WASTE MANAGEMENT FACILITY Page 6 of 12 BIO MANAGEMENT OF IMPACTED SOILS SECTION CONT'D: Treatment Method - Impacted soils will be treated at the land treatment facility using techniques that have been proven to be environmentally safe, cost effective, and efficient at reducing hydrocarbon concentrations by enhancing the degradation of hydrocarbon molecules by indigenous bacteria. Depending on a variety of weather related factors, the indigenous bacteria will be stimulated by the periodic addition of water, nutrients, and oxygen. On an "as needed" basis, the soil mass in each Bio Cell will be turned using heavy equipment to continually expose the various layers of the soil mass to oxygen, moisture, and sunlight. No tillage of the soils will occur during periods of high winds or when surface conditions would create the emission of fugitive dust from the site. Impacted soils received at the land treatment site that reflect hydrocarbon concentrations in excess of 20,000 ppm TRPH will be blended with cleaner soils to avoid pockets of high hydrocarbon concentrations in each Bio Cell soil mass and thus eliminate the potential for odors emitting from the site. Bio Cell Performance Monitoring - When an individual Bio Cell is filled to the designated dimensions and volumes described above, hydrocarbon concentrations will be measured using an Organic Vapor Meter (OVM) on a periodic basis. When the OVM readings indicate that the Hydrocarbon concentration in the soil mass has dropped to below 500 ppm, a composite sample of the soil mass will be collected and submitted for TPH analysis. This lab data will be entered into the log book for the land treatment facility. When the TPH concentration has dropped below the COGCC mandated 500 ppm. The soil mass will be removed from the Bio Cell for recycling as berm wall material or will be stockpiled elsewhere on the land treatment facility to be used for construction soils in other EnCana operations. OPERATIONS PLAN CENTRALIZED E & P WASTE MANAGEMENT FACILITY Page 6 of 12 BIO MANAGEMENT OF IMPACTED SOILS SECTION CONT'D: Treatment Method - Impacted soils will be treated at the land treatment facility using techniques that have been proven to be environmentally safe, cost effective, and efficient at reducing hydrocarbon concentrations by enhancing the degradation of hydrocarbon molecules by indigenous bacteria. Depending on a variety of weather related factors, the indigenous bacteria will be stimulated by the periodic addition of water, nutrients, and oxygen. On an "as needed" basis, the soil mass in each Bio Cell will be turned using heavy equipment to continually expose the various layers of the soil mass to oxygen, moisture, and sunlight. No tillage of the soils will occur during periods of high winds or when surface conditions would create the emission of fugitive dust from the site. Impacted soils received at the land treatment site that reflect hydrocarbon concentrations in excess of 20,000 ppm TRPH will be blended with cleaner soils to avoid pockets of high hydrocarbon concentrations in each Bio Cell soil mass and thus eliminate the potential for odors emitting from the site. Bio Cell Performance Monitoring - When an individual Bio Cell is filled to the designated dimensions and volumes described above, hydrocarbon concentrations will be measured using an Organic Vapor Meter (OVM) on a periodic basis. When the OVM readings indicate that the Hydrocarbon concentration in the soil mass has dropped to below 500 ppm, a composite sample of the soil mass will be collected and submitted for TPH analysis. This lab data will be entered into the log book for the land treatment facility. When the TPH concentration has dropped below the COGCC mandated 1,000 ppm. The soil mass will be removed from the Bio Cell for recycling as berm wall material or will be stockpiled elsewhere on the land treatment facility to be used for construction soils in other EnCana operations. OPERATIONS PLAN CENTRALIZED E & P WASTE MANAGEMENT FACILITY Page 7 of 12 WASTE HANDLING SECTION: NOTE: No Hazardous or Special wastes are allowed to be transported or received at the subject site under EnCana Environmental Policy and Guidelines. Waste profile of proposed waste streams: The land treatment facility will be used to treat and recycle two types of E & P waste materials. The types of E & P waste and anticipated monthly volumes to be treated are as follows: • Oil stained soils - 300 - 500 cubic yards. • "Frac" sand, 100 - 200 cubic yards. Waste characterization - Hydrocarbon Affected Soils: Point sources for hydrocarbon affected soils are wellhead and production battery spills and releases as well as gas line leaks. These soils vary in texture and makeup depending on the impacted site. Typically these oil stained soils exhibit a range of hydrocarbon contamination expressed as Total Recoverable Petroleum Hydrocarbons (TRPH) from < 500 ppm to 20,000 ppm. Waste Characterization - "Frac" Wastes: Frac Fluids Characterization - The typical waste characterization for frac fluids (flow back waters) consists of the following constituents: - Biodegradable gels <1,000 ppm* - Chlorides <1,000 ppm* - Calcium/Magnesium <200 ppm* - BTEX not available *Data Source: BJ Services, Tom Smith, Lab Manager, Brighton, Colorado. See attached "Water Analysis Lab Report" provided by B -J Services, USA and located in the Appendix Section of this document. NOTE: No flow back frac fluids are to be received at the land farm facility. This data is presented for reference purpose only. Frac Sands Characterization - hydrocarbon concentrations are generated during the flow back stage in the well fracturing/completion process. Hydrocarbon contamination concentrations in "Frac" sands expressed as Total Recoverable Petroleum Hydrocarbons (TRPH) range from < 300 ppm to 10,000 ppm. Waste Characterization - Fresh water based drilling mud: Typically, drilling mud generated in the Denver-Julesburg Basin exhibit minimal hydrocarbon concentrations expressed as Total Recoverable Petroleum Hydrocarbons (TRPH) ranging from 50 ppm to 1,000 ppm. OPERATIONS PLAN CENTRALIZED E & P WASTE MANAGEMENT FACILITY Page 8 of 12 Note: The land treatment facility will not receive any waste materials that are listed and defined as hazardous wastes under Subtitle C of RCRA. COGCC 910 Allowable Concentrations and Sampling for Soil and Groundwater: Periodically, all E & P Exempt wastes are sampled and analyzed for a wide spectrum of properties described in COGCC Rule 910 —1. Waste Manifest Procedure - All hydrocarbon contaminated soils excavated from an impacted site will be transported to the land treatment site with each load accompanied by a waste manifest document which will be completed by an EnCana representative or an assigned agent and the driver transporting the load. These waste manifests will be used to monitor volumes of impacted soils entering the land treatment facility. Frac Sands will be transported to the land treatment site using these same waste manifest forms. The EnCana employee or designated EnCana representative will complete the "generator" section of the manifest document at the site where the waste is being extracted and loaded for shipment to the land farm. The transporter will complete the "transporter" section of the manifest form. When the transporter reaches the land farm unit, the semi -completed waste manifest form will be placed in a steel box located at the entrance to the land farm facility. A copy of the EnCana "Non -Hazardous Waste Manifest" document form is located in the "Appendix Section" of this plan. The EnCana environmental engineer will, periodically pick up the waste manifest documents, complete the "facility" section of the waste manifest document and enter the data in the permanent file for the land farm facility. In this manner, the quantity and types of waste materials delivered to the land farm facility can be monitored. A file will be maintained at the Wattenberg Production offices containing the waste manifests and other materials related to the operation of the land farm including periodic test data of soils sampled from the several Bio Cell pads. This information will be available, upon request, to COGCC representatives. NOTE: No soil wastes will be accepted by EnCana from any other operator for deposit at the subject site. Solid Waste Containers: A 20 cy roll off bin will be utilized to dispose of misc. non -hazardous wastes under a management agreement with the Waste Management Corporation (WMC). Containers are picked up by WMC on a scheduled basis. Scrap Iron & Steel Container: A 20 cy roll off bin will be utilized to dispose of non -hazardous iron and steel under a management agreement with Republic Steel (RS). Containers are picked up by RS on a scheduled basis. • OPERATIONS PLAN CENTRALIZED E & P WASTE MANAGEMENT FACILITY Page 9 of 12 ADDITIONAL BMPs: Portable Toilets/Septic System: At present, the facility is unmanned. Consequently, portable toilets will be used to accommodate the limited presence of EnCana employees at the site for pick up and drop off of stored materials at the site as well as the limited activities associated with the land farm. However, in the event that use of the facility involves the presence of EnCana employees at the site on a continuous basis, all existing septic systems at the site to be activated shall be inspected and certified by a Colorado Professional Engineer to be adequate for the proposed sewage load and will be in good working order. If inadequate, a repair permit will be obtained from Weld County and the system will be brought into compliance. Operating Hours: The land farm facility will be under lock and key at all times and accessible to authorized EnCana personnel and assigned truck units only. No activity before dawn or after dark is anticipated Dust Abatement Procedure: During periods of drought and in the presence of high winds, surface areas of the facility prone to dust erosion will be water wetted to minimize fugitive dust. Water trucks with sprayer nozzles will be used to wet down areas prone to dust. EMERGENCY RESPONSE PLAN SECTION: EnCana maintains a formalized plan for responding to and reporting spills and releases of crude oil, produced water, and other E & P related materials. The land farm facility will be incorporated into the EnCana Emergency Response Plan document. An outline of the emergency response actions to be taken in the event of a spill includes: - The individual who discovers the release will take whatever immediate steps are necessary to mitigate the source of the release and to prevent the spill or release from impacting surface water or other environmentally - sensitive receptors; - The individual who discovers the release will contact EnCana's Environmental Engineer and/or designated supervisor. If an immediate threat to health or safety is involved, the individual who discovers the release will contact the Brighton Fire Protection District at (303) 659 - 2629; - Local spill response contractors will be contacted to clean up the spill; • OPERATIONS PLAN CENTRALIZED E & P WASTE MANAGEMENT FACILITY Page 10of12 EMERGENCY RESPONSE PLAN SECTION CONT'D: - EnCana's Environmental Engineer will report the release to the appropriate authorities, depending on the type and volume of the material released; - EnCana's Environmental Engineer will assess the effects of the release on soil, surface water, or ground water resources and make recommendations to the EnCana operations group to take whatever remedial actions are necessary; and, - A written record of the release incident will be maintained with the land farm facilities records located in EnCana's Wattenberg offices and at the Longmont Operations Managers' offices. Copies will be provided to COGCC and Weld County Department of Public Health & Environment (WCDPHE). SOIL & GROUND WATER MONITORING PLAN SECTION: Site Soil Monitoring: Initial Background Soil Sampling Protocol - Samples of the native soils along the perimeter and within the interior of each bio-cell pad were collected initially and are collected semi - annually as follows; The interior area of the proposed land farm unit was divided into three equal divisions along the north -south axis. Within each division, soil borings were conducted in a 100 foot grid pattern to encompass the interior each division at a depth of 12 inches and 24 inches. The aggregate grab samples from the two depths were co -mingled to create a composite soil sample at two depths for each of the three divisions. Additional individual soil samples were collected initially in the primary "catch basin" immediately up gradient from the inlet to the storm drain which carries storm runoff waters to the storm water retention pond. Soil samples from the retention pond were collected along the centerline of the pond at 100 foot intervals. OPERATIONS PLAN CENTRALIZED E & P WASTE MANAGEMENT FACILITY Page 11 of 12 SOIL & GROUND WATER MONITORING PLAN SECTION CONT'D: Soil Analysis Profile - Each composite soil sample collected as described above were analyzed for the constituents for the following; * RCRA metals * Oil & Grease * pH *TPH This data formed the 'baseline" soil profile for the site. Semi - annual Soil Sampling Protocol - Semi - annually, soil samples will be collected in accordance with guidelines stipulated by Weld County using the COGCC 910-1 "Allowable Concentrations and Levels" protocol. A minimum of one soil sample will be collected per treated acre. The analysis for the soils samples will be TPH using 8015 Mod. DRO/GRO. This data will be reported jointly to the COGCC and to Weld County on a scheduled basis. Ground Water Monitoring - COGCC (908.b.(9) Ground water at the site is sampled and analyzed for BTEX on a quarterly basis. The monitor well inventory consists of the following: Two — up gradient monitor wells (MW # 1 & MW # 2) located on the south side of the land farm facility. One — lateral monitor well (MW # 3) located at a midway point on the west end of the land farm facility. Three — down gradient monitor wells (MW # 4, MW # 5 & MW # 6) located on the north side of the land farm facility. Two — down gradient (retention pond) monitor wells (MW # 7 & MW # 8) located in the interior base of the retention pond. See the "Appendix Section" fora site map indicating the location of the monitor wells. OPERATIONS PLAN CENTRALIZED E & P WASTE MANAGEMENT FACILITY Page 12 of 12 CLOSURE PLAN SECTION: At the conclusion of operations of the land farm facility, all treated soils will be removed from the land farm treatment area for beneficial use elsewhere at EnCana facilities (production, drilling, and pipeline sites) or at a Class II land fill facility. Soil samples will be collected from the surface of the treatment area and tested under the COGCC 910-1 test protocol to assure that no residual contaminants are present. Once the surface treatment areas of the land farm have been established has being free of contaminants, the site will be re -contoured to its original grade. Depending on the future use of the site, re -vegetation of the site may occur to prevent soil erosion or fugitive dust. There are no structures present in the land farm facility and none are anticipated to be constructed. Once closure of the site has been completed, no unauthorized access to the site will be permitted. SURETY BOND SECTION: COGCC 908.d Submittal of Surety Bond: A surety bond is on file with the COGCC and the Weld County Department of Public Health and Environment. Hello