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HomeMy WebLinkAbout20010914.tiff 01/14/2001 22:43 805-239-7377 LESAGE LAW OFFICE PAGE 01. -Pi MICHAEL T. LESAGE ATTORNEY AT LAW J( r�.r 620 13TH STREET 1 •if - P_0. Box 306 PAEC, , ORLES, GALtFORN1A 93447-0306 r TELEPHQNE (008) 238 3484 ji* FAX (805) 239.7377 January 12, 2001 • Weld County Board of Commissioners 915 10th Street Greeley, Colorado 806_'•2 . RE: Hearing regarding USK.-1198 Enviro Cycle probable cause of revocation. Dear Commissioners: This letter is to req.iest an extension of time to address the issues regarding USR-1198 and to request a rescheduling of said hearing. The reasons for an extension and rescheduling are as follows: 1. As the legal representative for Mike Cervi and Enviro Cycle I was n.Dt apprised of the issues of the hearing scheduled for January 15, 2001 until last week. The notice that I received showed a hearing date of Wednesday January 15, 2001 . Therefore there has been some confusion regarding the hearing date and even though I believe that a corrected notice has been sent out showing Monday January 15,2001 I have not received the corrected notice. 2 . The issues of the notice are complex and they require more than 12 days tine to be adequately and legally addressed. The notice was dated January 3, 2001 and was not received untilllafter said date and the hearing was scheduled for January 5 3 . In the past in attempting to resolve issues reg dinn Enviro cycle and other matters I believe that both Mr. Lee Morrison County Council and Mr. Trevor Jiricek will confirm that my office has worked with both of these gentlemen to resolve and create solutions that have been in the best interest of both Weld County 1 EX IBIT 2001-0914 (1 ' 01/14/2001 22:43 805-239-7377 LESAGE LAW OFFICE PAGE 02 and my client. I believ... that my office has always strived to bt . honest and co-operative ;fl attempting to achieve a balanced and fair solution for all p . ties and I would like time and the opportunity to resolve 3.e issues addressed in this hear:_.ig anc am requesting an extension to determine the facts and to deal with the problems. 4 . My client has engaged Mr. John Mahoney of Mahoney Environmental Consulting Inc. to help determine the issues and on his behalf. I am also asking that we be given acid'itional time to determine the facts and to address the correction or the resolving of the problems. • My client has invested substantial funds in this project and has no intention of ignoring or avoiding the issues raised. In all fairness to his position I believe that he is legally entitled to determin the exact and true nature of each of the issues and formulate either a response, correction, resolve, or legal defense and I do not believe that 12 days or less is sufficient time to accomplish what wE would all like to accomplish which is an operation that is free from onerous and sometimes over zealous inspection, correction of true and necessary issues, safe and productive operation, and a facility that is efficient and properly regulated. Thank You. Sincerely, (7-1/644 J61 "--;* Michael T. 3eSage Esquire • a DEPARTMENT OF PLANNING SERVICES Code Compliance Division 1555 N. 17th Avenue, Greeley, CO 80631 Phone: (970) 353-6100, Ext. 3540 Fax: (970) 304-6498 Vilk. COLORADO CASE SUMMARY Case Number: ZCH-2000-002 Name: Enviro-Cycle C/O Mr. Mike Cervi - Situs Address: 19094 WCR 40, LaSalle, CO 80645 Mailing Address: PO Box 117, LaSalle, CO 80645 Legal Description: Part of the NW4NW4 of Section 32, T4N, R65W of the 6th P.M., Weld County, Colorado Parcel Number: 1055-32-0-00-008 July 9, 1998 Use by Special Review (USR) application received May 19, 1999 USR-1198 approved by the Board of County Commissioners November 8, 1999 Memo listing noncompliance of conditions of approval November 30, 1999 Letter from Trevor Jiricek, Director of Environmental Health, to Mr. Cervi regarding failure to submit a "Solids Handling Plan" December 2, 1999 Memo listing Public Works concerns December 2, 1999 Memo listing noncompliance of conditions of approval December 6, 1999 Letter from Michael T. LeSage regarding final mylar May 23, 2000 Inspection completed by Cindi Etchevery, Environmental Health i - June 29, 2000 Letter to Mr. Cervi listing noncompliance with USR-1198 August 25, 2000 Inspection completed by Cindi Etchevery, Environmental Health EXHIBIT Inspection Continued January 12, 2000 Page 2 September 13, 2000 Letter to Mr. Cervi listing noncompliance with USR-1198 (including .-. "Frac Tank Cleaning") October 5, 2000 Letter from Mr. Cervi addressing September 13, 2000 letter October 26, 2000 Inspection completed by Cindi Etchevery, Environmental Health November 2, 2000 Letter to Mr. Cervi listing noncompliance with USR-1198 (including "Frac Tank Cleaning") November 8, 2000 Letter to Mr. Cervi from Colorado Oil & Gas Conservation Commission "COGCC" addressing concerns November 9, 2000 Letter from "Enviro-Cycle" regarding November 2, 2000 letter November 14, 2000 The Department of Environmental Health received a citizen complaint November 20, 2000 Memo regarding citizen complaints • November 29, 2000 Memo regarding citizen complaints November 30, 2000 The Department of Planning Services received a citizen complaint December 1, 2000 Letter to Mr. Cervi listing noncompliance with USR-1198 (including citizen complaints) December 7, 2000 Letter from Mr. Cervi addressing December 1, 2000 letter December 8, 2000 Inspection completed by Cindi Etchevery, Environmental Health and Bethany Salzman, Zoning Compliance January 2, 2000 Letter to Mr. Cervi regarding "Probable Cause" Hearing date and listing noncompliance with USR-1198 (including "Frak Tank • Cleaning") January 3, 2000 Revised letter to Mr. Cervi correcting day of week for hearing January 5, 2000 Meeting with Mr. John Mahoney (new consultant for Mr. Cervi) addressing all concerns with Enviro-Cycle January 10, 2000 Letter from Mr. John Mahoney asking for continuance January 12, 2000 Inspection completed by Cindi Etchevery, Environmental Health and Bethany Salzman, Zoning Compliance Officer Inspection Continued . January 12, 2000 Page 3 January 12, 2000 Telephone conversation between Mr. Cervi and Bethany Salzman, Zoning Compliance. I advised Mr. Cervi that we were proceeding with the scheduled hearing for Monday, January 15, 2001 January 12, 2000 Message left for Mr. Mahoney indicating scheduled hearing for Monday, January 15, 2001 Currently the operation is in violation of several Sections of the "Development Standards" as previously approved by the Board of County Commissioners. Please see the enclosed copy of the"Development Standards" regarding USR-1198. The Department of Planning Services along with the Department of Environmental Health recommend that the Board of County Commissioners schedule this case to be heard at a "Show Cause" Hearing. 'e SENDER: M I also wish to receive the -a .Complete items 1 andlor 2 for additional servicesfollowing services(for an (7i ■Complete items 3,45,and 4b. a> •Print your name and address on the reverse of this form so that we can return this extra fee): N card to you. y at •Attacn this form to the front cf the mailpiece,or on the back if space does not 1.0 Addressee's Address iJ ai permit. ii $' •Write'Return Receipt Reouested'on the rnailpiace below the article number. 2.0 Restricted Delivery •The Return Receipt wilt show to whom the article was delivered and the datecn — delivered. Consult postmaster for fee. . o 3.Article Addressed to: 4a.Article Number 0 a, Z 130 055 923 m a ENVIRO—CYCLE 4b.Service Type OE ATTN: MR. MIKE CERVI 0 Registered } JX ertified fr rn PO BOX 117 0 Express Mail 0 Insured c w LASALLE, CO 80645 0 Return Receipt for Merchandise 0 COD = cal 7.Date of Delivery o a' o cc 5.Received By:(Print Name) 8.Addressee's Address(Only if requested • L ead or,l-.1, G, and fee is paid) m r Ir. 6.Signature: resst3 rAgent) I- 5- 2 PS Form 3811.December 1994 102595-98-a-022n Domestic Return Receipt d SENDER: I also wish to receive the ,0 •Complete items 1 and/or 2 for additional services. re •Complete items 3,4a,and 4b. following services(for an E •Print your name and address on the reverse of this form so that we can return this extra fee): card to you. ai a ■Attach this form to the front of the rnailprece,or on the back if space does not 1.0 Addressee's Address u m permit. > m •Write`Return Receipt Requested"on the mailpiece below the article number. 2.0 Restricted Delivery d ■The Return Receipt will snow to whom the article was delivered and the datecn delivered. Consult postmaster for fee. b, o 3.Article Addressed to: 4a.Article Number --;' v 2 Z 130 055 921 i a. MR. MIKE CERVI 4b.Service Type 3 E O ENVIROCYCLE LLC 0 Registered u9 C�•rti(ied cc PO BOX 117 0 Express Mail 0 Insured r LASALLE, CO 80645 0 Return Receipt for Merchandise 0 COD 1 7. Date of Delivery - ,_5.Received By:(Print Name) 8.Addressee's Address(Only if requested Y •;','/..','-1--• .1. (L7',2.,.- ->' and fee is paid) R 6.Signature:{A r e or Agent) ti ct X ."--- 22 PS Form 3811,December 1994 102595-9if-B-11229 Domestic Return Receipt ^� a r DEPARTMENT OF PLANNING SERVICES C S Code Compliance Division O 1555 N. 17th Avenue, Greeley, CO 80631 Phone: (970) 353-6100, Ext. 3540 • Fax: (970) 304-6498 COLORADO INSPECTION REPORT NAME: Enviro-Cycle do Mr. Mike Cervi LEGAL DESCRIPTION OF PROPERTY: Part of the NW4NW4 of Section 32, T4N, R65W of the 6th P.M., Weld County, Colorado DATE: January 12, 2001 r CASE NUMBER: ZCH-2000-002 Upon a visual inspection completed by Cindi Etcheverry (Department of Environmental Health) and myself(Zoning Compliance Officer), the following items were noted: Semiannual analysis of fluids has not been completed and report not submitted to Weld County Environmental Health Underdrain is not inspected or recorded in a log and upon inspection contained 14" of liquid (should be free of liquids) "Frac Tank Cleaning"still occuring Dumpster reconstructed with seal; however, not yet been tested for leakage New "Site Manager" (Bob Gray) appeared fairly knowledgeable with facility operations Neighboring property owners reported that facility still accepts waste after posted hours of operation Their"Waste Management Plan" is not being followed, nor,was the "Site Manager" informed of • the "Waste Management Plan" Since the facility is still accepting waste after hours of operation the gate is not locked Concrete receiving pad showed evidence of spilled waste 6 additional storage tanks were present Additionally, Several tanks not in an "Earth Tone"color Ice on the "Receiving Pad" Substantial spill occurred which was not contained on the concrete receiving pad • i • Laz BE eeIsa HfM RAT AT • 7 GAO) CAUTION CAREFUL ' 4. 1 SIO) ,f TRIPPING wascN rs.1 nu , ,wawa som '°"`° NQ TIC Ito 5E? w•1 IA • LOC fd Ir jPillillia\'S41.. !, ^ llill , r.", I -4 : a - ill �y i4 ` K III Lit . r VAIN t• LIa _ • c41ITa 0 Lai... .. .._.. .- r,-------.. /y' T- --4:77 —7 cX J� L,_- T .!--- roc` _ anti I 1 3 4 5 ! 6 I '7 t ' H. r- ✓ ,,., ilailLrAlm ;it,/Isle /Iris. a I ie 41-6N6/11 rall. nn• 4asa $9n!ja P.JA NI/. u. 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I i -i_i r r : - - r ' , - iir I Crs I L i`' I 1: I • 'Ai i i I — a - I • I- — E i • " III {a, '' 4 ilk • '} ' l:bl I Ilk Via 1 III II .K tli F4')I:lI li # is Gj ytk f===ll; ,111 I i i"�Iii" t I : hO, 9 at..', I1iI,.. 1 ."F .Ii, (:Pu:, , ; " t.`L I I.FRNLi to ii x,il• A• N x { if 1 il Name: MVC-044S.JPG Size: 35215 bytes Dimensions: 640 x 480 pixels Weld County Planning Dept IAN 10 2.001 RECEIVED MAHONEY MYEIRONMEARALOMMULITNG C IMI INAYENVE CAMAY,CMUMN s_u January 10, 2001 ,„,>:,,,, Ms. Bethamy Salzman Zoning Compliance Officer Weld County Planning Department and Ms. Cindi Etcheverry Environmental Specialist Weld County Department of Public Health and Environment 1555 N. 17th Avenue - Greeley, Co. 80631 RE: Response to January 3, 2001, Probable Cause public hearing notification, ZCH-2000-002, (USR-1198). Dear Ladies: I appreciated the opportunity to meet with you and Ms. Julie Chester on January 4, 2001. Since that meeting, Mike Cervi has received your January 3, 2001 letter and I have reviewed your comments and information from the January 4th meeting with hint Mr. Cervi has requested that I contact you and provide the following information and too request an extension of the scheduled January 15, 2001 Probable Cause public hearing meeting with the Board of County Commissioners. This letter is not intended to address all of the issues in the January 3, 2001 letter or is it intended to provide the final response to these issues. One of the primary issues in the January 3, 2001 letter pertains to the "Frac Tank Cleaning" activities at the site. On January 5, 2001 I inspected the "Frac Tank Cleaning" area at the site. Mr. Randall Ferguson from the Colorado Oil and Gas Conservation Commission (COGCC) was also present. At the time of the visit, the portable dumpster container was only approximately 10% full. Free liquids and solid were in the container. No indications of leakage were observed on the concrete pad under or around the container. A rubber gasket was observed around the gate edge of the portable container (the probable source of leakage during transport). Mr. Ferguson was not aware if the gasket was present during the previous site inspection. Therefore, we asked the site manager Mr. Bob Gray to confirm whats repairs have been made to the container and to contact us when the container was full (prior to transporting the container) so that the leakage can be evaluated during transport. The container transportation issue is the primary concern of the COGCC. I have done a preliminary review of the "Frac Tank Cleaning" operation. The waste materials from the "Frac Tank Cleaning" process should be considered as E&P waste as defined by the EPA and the COGCC. Also, these waste materials received at the site are generated from one operator, HS Resources. The free liquid (primarily water and crude oil) are separated from the solids at Enviro and subsequently discharged in the disposal well. The solids are transported offsite to the HS Resources land farm facility. Mr. Ferguson, OGCC, indicated that the HS Resources land farm facility is permitted for this operation and the waste stream has been profiled. Enviro will request the waste stream profiling information from HS Resources. Mr. Ferguson also indicated that he has no current problem with Enviro's handling of the "Frac Tank Cleaning" waste as long as the portable transport container is located on the concrete containment pad and the container does not leak during transport. Also, only waste from HS Resources is permitted to managed at the site and transported to the HS Resources land farm. With regards to the noise issue, Mr. Ferguson indicated that Ms. Linda Pavelka, OGCC performed a noise inspection on or about December 12, 2000. The results reportedly were satisfactory. Mr. Bob Gray is the new facility manager at Enviro. Mr. Gray has started to institute management changes to improve the facility operations. Operations issues such as hours of operation, hosing down the pad, signage, etc. will be thus addressed. In addition, MEC Inc. will assist Enviro in the preparation of a Waste Management Plan and the issues pertaining to monitoring the containment pad underdrain wells. The majority of the fixtures at the site are painted light brown or light gray. Mr. Cervi considers these colors to be 'Earth Tones'. Additional clarification is necessary as to what are considered acceptable 'Earth Tone' colors. The black or red colored tanks on the concrete containment pad are temporary portable tanks. The facility management is not aware that these portable tanks also require Earth Tone colors. At the January 4, 2001, Ms. Julie Chester returned the site plats that were previously submitted by Enviro. The plats were indicated to be incomplete and required additional work and they also needed to be recorded. Mr. Cervi has asked me to make the necessary changes to the plat. I have reviewed the information provided to me at the meeting pertaining to the preparation of the plat. There is no indication that a registered engineer or surveyor is required to prepare such plats. Therefore, unless there is any objection from Weld County, Mr. Cervi has asked me to proceed with making the changes using the original plat prepared by Enviro. The above responses do not address all the issues discussed at the January 4, 2001 meeting or as listed in the January 3, 2001 letter. 2 Based on the above information provided, Mr. Cervi would like an extension of the scheduled January 15, 2001 Probable Cause meeting. There is not enough time to adequately address the issues with the less than 12 days of notification. I believe it will take a minimum of 60 days to address these issues. Some issues may take more time, for example if weather conditions influence the activity or for other unforeseen reasons. Therefore, Enviro requests the hearing to be rescheduled accordingly. If you have any questions or comments, please do not hesitate to contact me at (970) 352-2644, cell 970-690-1680. Thank ou, * Note: Two copies,delivered to Weld County office in person on January 10,2001. 3 /Ott MEMORANDUM wokTO: John Mahoney and Mike Cervi 0 COLORADO FROM: Julie Chester, Lead Plann 4.V SUBJECT: Envirocycle, USR-119 This memo is in reference to the above mentioned Special Review Permit and the office visit with John Mahoney. Bethany Salzman, Cindi Etcheverry and myself had a meeting with Mr. Mahoney regarding the noncompliance of the site. Mr. Mahoney indicated that he would send a letter indicating the plan for compliance, prior to January 15, 2001 (Probable Cause Hearing). We explained to him all of the problems with the current permit, so that there was a basic understanding of what the issues were and the processes to bring the property into compliance. Six pages of mylar plats were returned to Mr. Mahoney, as they were not complete and ready for recording. Mr. Mahoney indicated that he would address getting the mylar plat corrected and returned to our office for recording. • SERVICE,TEAMWORK,INTEGRITY,QUALITY WELD COUNTY 4.00.1 C MASONRY ENVIRONMENTAL CGMIOLfIAG INC 2""I J/1 17 171 2C. NW January 17, 2001 O415234/4"It 17•404M4 RECE ED Board of County Commissioners of Weld County Weld County Centennial Center 915 10th Street Greeley, Co. 80631 RE: Request for document regarding the Probable Cause for Enviro-Cycle, ZCH-2000-002, (USR-1198). Dear Gentleman: At the Probable Cause public hearing for Enviro-Cycle LLC, on Monday, January 15, 2001 the Weld County Planning and/or the Weld County Department of Public Health and Environment provided the board with a document at the start of the meeting. Mr. Cervi or I were not provided a copy of this document. Mr. Cervi would like to have a complete copy of this document as it is assumed that the document contains information pertinent to the situation. Please provide a copy of this document, as soon as possible. If you have any questions or comments, please do not hesitate to contact me at(970) 352-2644, cell 970-690-1680. you Mahoney J * Note:Delivered to Weld County Commissioners office in person on January 17,2001,on or about 2:30 PM. en lr7 / 2001-1625 ti EXHIBIT i G 4' Memorandum TO: File ' DATE: January 29, 2001 COLORADO FROM: Cindi Etchevetry, Environmental Specialist SUBJECT: Envirocycle - Compliance Meeting On Friday, January 26, 2001, Mr. Cervi met with Julie Chester and I. The purpose of the meeting was to review the Amended notice, dated January 3, 2001 and other applicable documents in order to discuss compliance with the Development Standards. During our meeting Mr. Cervi discussed listed items of noncompliance in the letter dated January 3, 2001. Below, is a summary of the discussion. 1) Standard#3,Mr.Cervi said he will sample the underdrain semi-annually,in June and December of every year, and records of the amount of fluids, and maintenance will be kept. Frac tank cleaning will be discontinued by January 28, 2001. 2) Standard#4,the new manager,Bob Grey, is knowledgeable with the facility. However,he needs to be knowledgeable with the facilities USR,waste management operations,and other regulations concerning the facility. Mr. Cervi said he would get a waste management plan to us. This plan will include waste streams, approximate amounts of waste, and the schedule of waste removal by their waste handler. 3) Standard#6,hours of operation should be discussed. Envirocycle had been accepting waste after 7 p.m. We ask that Planning and or the County is notified prior to dumping outside hours of operation. This activity should be a rare occurrence. Concerning the noise and vibrations after hours,Mr.Cervi believes hours of operations do not include pumping downhole after 7 p.m. and before 7 a.m. 4) Standard#7,this concern will be address when a waste management plan is written for the facility,and Frac tank activities have been discontinued. 5) Standard#13,Mr.Cervi has agreed to keep the gates closed after 7:00 p.m.to ensure that no more waste will be accepted after hours of operation. However, due to safety reasons,the gates will not be locked when employees are in the facility. 6) Standard#15,this concern will be addressed when Frac tank cleaning activities are discontinued. 7) Standard#16,this concern will be addressed when Frac tank cleaning activities are discontinued. — . 8) Standard#17,the concrete receiving pad will be cleaned,and the materials generated from Frac cleaning will be removed from the receiving pad. 11 EXHIBIT EnvirCycle - Compliance Meeting January 29, 2001 Page 2 9) Standard#31, Substantial changes from the plans or Development Standards as shown or stated shall require the approval of an amendment of the Permit. Planning advised Mr. Cervi that if he wanted to conduct Frac tank cleaning activities,he would have to file for an amendment of the Permit. Mr.Cervi submitted a Mylar to Julie for her review. 10) Standard #32, the property owner, or operator shall be responsible for complying with all of the Development Standards. Additionally, Mr. Cervi said he would remove the additional tanks on sight. However, it will take him around 60 days to empty them. We discussed the color of the tanks, and agreed gray or tan would be appropriate earth tone colors at the facility. O:\Etch\Waste\Envirocycle\Meeting memo 012601.wpd r. r Hello