HomeMy WebLinkAbout20010912.tiff &Araeye /e
Colorado Department of Public Health and Environment
Hazardous Materials and Waste Management Division
INTEROFFICE COMMUNICATION
To: Glenn Mallory
From: Doug Ikenberry (04'
Date: November 29,2000
Subject: Enviro-Cycle Injection Well
On November 14, 2000,I received notice of a complaint concerning the Enviro-Cycle
•
Injection Well. This facility is located at 19094 Weld County Road 40.
A November 15, 2000 telephone conversation with the complainant revealed the
following intimation:
• There are residences located approximately 100 yards and 150 yards from the facility.
• There allegedly are explosions and"bangs"originating from the facility.
• The facility is allegedly causing constant and excessive vibrations that affect nearby
residences. Evidently,these vibrations can be seen when a glass of water is placed on
the windowsill of a nearby residence.
• There is concern that these excessive vibrations are also adversely affecting nearby
water wells. The water well filters reportedly have to be changed much more
frequently since the vibrations began.
• There allegedly are"natural gas"odors emanating from the facility.
• Trucks have allegedly been sighted at the facility around 8:15 PM and 11:00 PM at
night.
Please also see the attached Weld County Department of Public Health and Environment
memo(dated November 20,2000)that addresses the same facility.
FILE: SW WLD ENC 1.8
2001-0912
STATE OF Pr invite Cycle
COLORADO DEMENT OF NATURAL R OURCES
Bill Owens, Governor
OIL & •
1120 Lincoln St., Suite 801 _-
Denver, CO 80203
GAS Phone: (303) 894-2100
FAX: (303) 894-2109
CONSERVATION COMMISSION www.oil-gasstate.co.us
November 8. 2000
Mr. Mike Cervi j ITT 11
Enviro-Cycle LLC R,F+C '
P.O. Box 117 U 9 LOCO
LaSalle, CO 80645 Nov
lowitattw. NAIR KIVICfb
RE: Geraldine 32-1 Disposal Well / Facility #159042
NWNW Section 32 —T4N— R65W
Weld County, Colorado
Dear Mr. Cervi:
For your information, a Memorandum of Understanding (MOU) between the Hazardous
Materials and Waste Management Division (HMWMD) and the Colorado Oil & Gas
Conservation Commission (COGCC) was approved on October 6,2000. This MOU is
intended to recognize that the HMWMD and the COGCC may have overlapping regulatory
authority regarding the disposal of E&P wastes at commercial solid waste facilities with
Class II injection wells. The HMWMD will defer to COGCC regulation including E&P
wastes placed in surface structures appurtenant to such wells, prior to disposal of Class II
wastes down the well (downhole disposal). A copy of the MOU is attached.
As you are aware, Colorado Oil & Gas Conservation Commission (COGCC) staff and
Cindy Etcheverry with the Weld County Department of Public Health & Environment
conducted an inspection of the subject facility on October 26, 2000. The purpose of the
COGCC inspection was to evaluate a potential violation of COGCC rules in regards to
frac tanks being washed out and associated petroleum contaminated soils being stored in
a leaking dumpster. During the inspection, a dumpster was observed full of contaminated
soil and leaking fluids onto the ground. It is my understanding that the soils originated
from HS Resources, Inc. (HSR) operations and are periodically transported to the HSR
landfarm facility. Please find attached a Field Inspection Report that describes the
findings of the inspection. The following corrective measures should be taken with the
dumpster:
A metal dumpster that leaks is not a suitable container for the storage and
transportation of contaminated soils saturated with fluids.
If the metal dumpster is to be used for these operations in the future, it is required
to be lined with an appropriate material to prevent leakage at the site and during
transportation to any offsite destination.
DEPARTMENT OF NATURAL RESOURCES.Greg E.Walther,Executive Director
COGCC COMMISSION Tom Ann Casey.Brian Cree-Bruce Johnson-Michael Klish-Abe Phillips-Daniel Skrabacz-Stephen Sonnenberg
COGCC STAFF.Ricnara T Griebling,Director Brian J.Macke,Deputy Director-Morns Bell,Operations Manager
Patricia C.Beaver,Hearings Manager-Thomas J.Kerr,Information Manager
Memorandum
TO: Incident File
1111k. DATE: November 20, 2000
7.71
COLORADO FROM: Cindi Etcheverry, Environmental Specialist
SUBJECT: Enviro-Cycle Injection Well, 19094
WCR 40
On November 14, 2000, I received a complaint concerning Enviro-Cycle, LLC, located at 19094
Weld County Road 40. The complaint alleges that the activities at Enviro-Cycle are generating
severe vibrations in the ground,and within the walls of their homes. Additionally, a constant `roar'
is heard and is accompanied by sudden bursts of noise which sound like a cannon has been shot. The
complainant also alleges that the constant vibration is causing damage to their water wells, and
occurrences of periodic strong natural gas odors are emanating from the facility,causing nausea and
other health concerns.
On November 14, 2000, at approximately 8:00 p.m., I went to the complainant's address to
investigate the complaint. There are several residences in the area. I spoke with two residences,one
who filed the complaint, we walked the perimeter of their properties. Upon walking the perimeter
of their property, which is on the west side of the facility, it appears that the heater treater unit may
be the cause of the vibration. The residence also invited me into their home, where I could feel the
vibration while sitting or standing in their home, and hear the roaring noise.
At that time I did not detect strong odors.
Additionally,the facility is accepting waste during the night. I have not yet determined whether the
facility is manned at night, while accepting waste.
On November 20,2000,Linda Pavelka of the Colorado Oil and Gas Conservation Commission went
to the facility to investigate the noise and vibration complaint. She conducted a noise level test
which failed their limits for residential areas. She also mentioned the heater treater unit was not
running properly and is the cause of the vibration and noise. Linda said she will be writing them a
Notice of Alleged Violation after Thanksgiving. However, she spoke to the new person maiming
the facility, and he agreed to try to reduce the vibration and noise levels.
M:\Etch\Waste\Envirocycle\complaint111400.wpd
Mr. Mike Cervi
November 8,2000
Page 2
Rule 907.a.(I). states that operators shall ensure that Exploration & Production (E&P)
waste is properly stored, handled, transported, treated, recycled or disposed to prevent
threatened or actual significant adverse environmental impacts to air, water, soil or
biological resources (see attached). Should subsequent inspections result in the same
violation, a Notice of Alleged Violation (NOAV) will be issued and potential fines
assessed.
Should you have any questions, please call me at(303) 894-2100 ext.118.
Respectfully,
1---64-11
all H. Ferguson
Environmental Protection Specialist
Attachments
Cc: Rich Griebling—COGCC
Debbie Baldwin— COGCC
Cindy Etcheverry— Weld County Dept. of Public Health & Environment
Pat Flynn—HS Resources, Inc.
r
->' COLORADO OIL & GAS CONSERVATION COMMISSION
FIELD INSPECTION rIEPORT
• PA./NOTICE OF UNSATISFACTORY INSPECTION
• 1120 Lincoln Street, Suite 801
:NOTICE OF SATISFACTORY INSPECTION
Denver, CO .80203 (303)-894-2100
API No. 05- - -- - --
R3 - rl 'Lr' ZE LEASE NAME: :aer� 1 d, ,,,,_ #/ 1),-} 04)3.. /
LOCATION: N;,1 4J 3 - T�/N - Orj
6Sc.Ji OPERATOR: c71 1/,./d/,, _ C', ` C4 LL L !
DATE: /o OO j INSPECTOR:E_ ��nID�'L C, / �F�
�G cJ.$O-J I
INS?TYPE
5INSP STAT
- 71 ICI )Y ) PASS/FAIL P 0 VIOLATION Y N NOV Y
UIC VIOL TYPE UA ❑ MI ❑ OP O PA
❑ OT ❑ I TBG/PICK LK0Well ID Signs ❑ IIMI Fences
(Rule 210) ❑
(Rule 604.C. 31 1003.A)
Production Pits PRODUCED WATER PITS TOTAL
(Rule 902, 903, 904) Olt ACCUMULATION p YES 0 NO 1-3
SKIMMINGISETTLING PITS ram Jt
EARTHEN PITS ONLY COVERED # uNcov�RED #
SPECIAL PURPOSE PITS Tara. # LINED #
UNLINED #
COMMEMS150E
SENSITNE AREA O YES O NO
Tank Battery Equipment
(Rule 604) O
BURIED OR PARTIALLY BURIED VESSELS : *STEEL *FIBERGLASS *CONCRETE #OTHER
:re Wails/Beans/Dikes
(Rule 604)
General Housekeeping i
(Rule 603.G) • ❑
Spills (Oil!YYater') Jun.pS}er Ca 124:try,iA-
(Rule 908) 457,7):11sL...34-.. .� e J 6Ct ;`` ` r�.4
UIC ROUTINE INSPECTION IN.! PRESssU � mac... r"`'"� rest/47.;
v r ��
RE
PSiG COMMENTS
FILL OUT FORM 21 T-C ANN PRESSURE
WHEN WITNESSING MIT PSIG
MHO PRESSURE PSiG
Drilling Well/Workover
(Rule 315) O
Surface Rehabilitation
' (Rule 31 7) O
' Miscellaneous
O
CORRECTIVE. ACTION REQUIRED: 4� —04-1 J�.� 5F,4v -� �c� 5,• (s a,)1 � Cis, ^ � E
uate Cre t ve A�ton Required �° ° s s
t q d B y: /, �` �� -;�. �,'�
_ _ -3 O o a Date Remedied:
This report is a Notice of Inspectionreportrimplv
-
MEMORANDUM OF UNDERSTANDING
Between the Hazardous Materials and Waste Management Division and
the Colorado Oil and Gas Conservation Commission
Regarding the Disposal of Eligible Wastes at Commercial Class II Injection Wells
WHEREAS, the Oil and Gas Conservation Commission ("OGCC") has regulatory
authority over the disposal of exploration and production wastes ("E&P wastes") from oil
and gas operations, pursuant to §§ 34-60-105 and 106, C.R.S.; and
WHEREAS, pursuant to § 34-60-106(9), C.R.S., the OGCC has authority to regulate
Class II injection wells for the purpose of protecting underground drinking water
supplies; and
WHEREAS, the Environmental Protection Agency and the OGCC have entered into a
Memorandum of Agreement that grants the OGCC primacy over Class II injection wells
pursuant to 42 U.S.C. § 300h-1(b); and
WHEREAS, pursuant to the Solid Waste Disposal Sites and Facilities Act, § 30-20-
100.5 et seq., the Hazardous Materials and Waste Management Division ("the
Division") in the Department of Public Health and Environment has regulatory authority
over disposal of solid waste; and
WHEREAS, pursuant to § 30-20-101(6)(b)(VI), C.R.S. the term "solid waste" includes
E&P wastes when such wastes are deposited at a commercial solid waste facility; and
WHEREAS,the term `Class II wastes"includes those E&P wastes that have been
brought to the surface in connection-with natural gas storage operations or conventional
oil and natural gas production, which may be commingled with waste waters from gas
plants which are an integral part of production operations provided those waters are not
classified as hazardous waste at the time of injection. Class II.wastes shall be the only
E&P wastes.eiigibie.for_dispnsalinfn a nags II well; and
WHERFASgthere-ebsbin3hisrsta mial:solid_ nrastezdisposatlaciiities that
includelhause-otaamtLinjectiontwellsItorlherdisposal of Class II wastes,with
incidentalprocessing-ortlisposahofE&Pwvastes;
Y
CONSEQUENTLY,the OGCC and the Division may have overlapping regulatory
authority regarding the disposal of E&P wastes at commercial solid waste facilities with
Class II injection wells.
NOW, THEREFORE, the OGCC and the Division agree as follows:
1. The Division will defer to OGCC regulation of disposal of E&P wastes at Class II
commercial injection well disposal sites, including OGCC regulation of E&P wastes
placed in surface structures appurtenant to such wells, prior to disposal of Class II
wastes down the well (collectively, "downhole disposal").
2. The OGCC shall determine which E&P wastes may be eligible for disposal into a
Class II injection well as a Class II waste.
3. The Division will exercise its authority under the Solid Waste Disposal Sites and
Facilities Act ("Solid Waste Act") regarding disposal of E&P wastes at commercial
disposal sites, other than downhole disposal. OGCC will defer to such regulation.
4. Nothing herein affects the authority of any local governing body having jurisdiction to
require a Certificate of Designation ("CD") under the Solid Waste Act.
5. If a local governing body having jurisdiction requires a CD for surface facilities
related to downhole disposal, the Division will be the point of contact for
communications with the city or county. The Division will promptly forward a copy of
the CD application to the OGCC for review. The Division and the OGCC agree to
meet the time frames for review set out in § 30-20-103(2) and (3) of the Solid Waste
Act, and to determine the state regulatory agency that will provide oversight for the
CD application. The state regulatory agency providing oversight for the CD
application shall provide the opportunity for public comment required by § 30-20-
103(1). When the OGCC exercises oversight over the CD application, the Division
will defer to the OGCC's evaluation of the environmental impacts of such disposal.
6. The Division does not have authority over disposal of E&P wastes at non-
commercial facilities.
e-. T. APPROVALS
Department of Natural Resources Department of Public Health and
Environment
Richard.Griebiing.Di Howard Roitrnan,O ctor
Oil and:Gas_Co ission =HazardousMateriatsand:Waste
Date: /'7 —O —Qa Date: t 0
.LJJ vj4.vllr' FKUI'l we id Laoor'ator lest Inc. ru
�✓J40411 r,Vl
W ..JD LABORATORIES, NC.
1527 First Avenue • Greeley, Colorado 80631
Phone: (970)353-8118 • Fax: (970) 353-1671
Methods 602/8020 and 5030/8015 Modified Report
Client Sample ID: Water Sample Sample Location: Enviro-Cycle Mon. Well
Laboratory No.: 4107 Client Project ID: N/A
Date Collected: 5/24/00
Date Received: 5/24/00 Sample Matrix: Water
Temperature of Sample(C): 4
Method: E602/SW8020A BTEX
Date Prepared: 5/30/00 Effective Dilution : 1
Date Analyzed: 5/30/00
Compound Concentration RL Units
Benzene
Toluene U 0.4 ug/L
Ethylbenzene 0.4 ug/L
U
m,p-Xylene U 0.4 ug/L
o-Xylene 0.4 ug/L
U 0.4 ug/L
Surrogate Recovery: 74.8 %
1,2,4-Trichlorobenzene 64-133 QC Limits
Notts: Total Xylca s consist of three isomers,two of which co-elute. The Xytenc RL is for a single peak.Confirmation analysis was not performed.
Qualifiers. Definition,:
U-Compound analyzed for but not detected
S Spike Recovery TV =TOtalVrtg latilet
outside accepted recovery/units TVH=Total Volatile hydrocarbons
J=Indicates an estimated value when the compound is detected TEH Total Extractable Hydrocarbon
s
but is below the Repotting Limit _ '-- —-----`--- -----.
Post.lr brand fax transmittal memo 7671 a ol payee
TOCA Y stet.
�. CO.
Dept. shone a —
Fax a Pax
T/60
ager D tat
•
•
Sampling procedures can affect the value or analytical results-customers are advised to use appropriate sampling protocol to insure samples
are truly representative of the bulk sample.
TOTAL P.01
✓t' a dUUtJ 10:SINN flUll weld Laboratories, Inc. IU .k74b411 N.Ul
WEJL,D LABORATORIES, INC.
1527 First Avenue • Greeley, Colorado 80631
Phone: (970) 353-8118 • Fax: (970) 353-1671
I P:47
May 25, 2000 'fib' •
Sni 47 See -
Mike Cervi
Envim-Cycle ITywQdyfs
P.O. Box 169
Sterling, CO 80751
Laboratory No. 4107
Date of Sample: 5/24/00
Time of Sampling: 1130
Sampled By: David A. Bossie
Date of Analysis: 5/24/00
Sample ID Chloride(mg/L) Method'
Water from Monitoring Well 385 4500 B.
1-Standard Methods for the Examination of Water and Wastewater, 19th Ed.
51445-/n,fie' Dgte
Sampare trulyg ur procedures
can affect c f the rue sample
TOTALanalytical result,—customers arc advised to use appropriate sampling protocol m insure samples
TOTAL P.01
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