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Home My WebLink About941412.tiff • tt RAC ; ';/ ` D DEPARTMENT OF HEALTH ' C V 1517.18 AVENUE COURT 1 GREELEY,COLORADO 80831 .J '�V .r ADMINISTRATION(303)353-0588 prij nn,....p r HEALTH PROTECTION(303)353.0833 :._..:1 •.-.--..s COMMUNITY HEALTH(303)353.0839 • COLORADO December 16, 1992 Mike Cervi Northern Colorado Brine P.O. Box 5714 Denver, Colorado 80217 Dear Mr. Cervi: The Division has reviewed your Odor Abatement Plan, dated November 25, 1992. The four-part plan was evaluated as follows: i. The Division feels that increasing the surface area by adding an additional pond may be effective in minimizing odors if two main conditions are true. First, if the odor is not an inherent characteristic of the brinewater as opposed to odors resulting from lack of aeration, this may be an effective odor reduction strategy. Secondly, if the level of brinewater intake does not increase such that the ratio of intake volume to surface area is significantly affected, odors may be reduced. Therefore, provided that the volume of brinewater processed at the facility does not increase, the Division feels that increasing the surface area may help to decrease odors. 2. Changing the aeration injection units from VCP to copper to increase airflow into the pond water is an acceptable measure to control odors. 3. The injection of enzymes to neutralize organic activity in the ponds is an acceptable measure to control odors. 4. Although the Division encourages Northern Colorado Brine to pursue any technology which may be effective in controlling odors, we do not consider that pursuit to be an odor control method in and of itself. In conclusion, the Division feels that Steps 1 through 4 are acceptable control strategies. However, please be reminded that should the above mentioned strategies prove to be ineffective, Northern Colorado Brine is still required to comply with the odor emission standard as required by the Colorado Air Quality Control Commission Regulation 2. Failure to maintain this standard will necessitate a revised odor control plan and/or further legal action in accordance with the Colorado Revised Statutes. 941412 ..F iJ+,f.,►� • Mike Cervi Northern Colorado Brine December 16, 1992 Page 2 If you have any further questions regarding this matter, please call 353-0635. Sincerely, Cel•Jeff ey L. toll, Supervisor Environmental Protection Services cc: Chuck Cunliff, Planning Services i 3RD�dl. � • COMPANY NAME: Northern Colorado Brine CE2REF PROTECT NUMBER: PR930537 Sulfide Analysis METHOD 376.1 CEI REF gANTME IDENTIFICATION gam= SQL RE Sf TT ,ALE No ( ma/1) ( ma/11 1889 ibid C 3/3/93 20 BDL 1890 Pond B 3/3/93 20 BDL 1891 Perri E 3/3/93 20 BOL 1892 Purrs D 3/3/93 20 BDL BDL = Below Sample Detection Limit SDL = Sample Detection Limit Ctfl4NTS: Please note increased detection limit. This was reauired due to sample matrix. CenefLciDs 9L200:1-e© EASTERN PLAINS ENVIRONMENTAL SERVICE P.O. BOX 142 PIERCE, COLORADO 80650 1-897-2439 or 454-3452 February 21, 1993 Harry Collier Air Pollution Control Division • Colorado Department of Health 4300 Cherry Creek Drive South Denver, CO 80222-1530 Dear Mr. Collier, In behalf of Northern Colorado Brine Facility, 10600 WCR 54, Greeley,CO, I am requesting guidance from Colorado Department of Health, Air Pollution Control Division, regarding odor control at brine water disposal facilities. NCB has made numerous attempts to determine what measures may provide adequate odor control; however there is very little information available regarding odors at brine water disposals. Please advise Eastern Plains Environmental Services for NCB as to what odor control measures would be considered Best Management Practice or Best Available Technology for a facility such as Northern Colorado Brine. I may be reached at 897-2439 or 454-3452 should you have any questions regarding this request. Sincerely, Patty Deplazes PD:sl cc John Milligan, EPS, WCHD Mike Cervi, NCB EASTERN PLAINS ENVIRONMENTAL SERVICE P.O. BOX 142 PIERCE, COLORADO 80650 1-897-2439 or 454-3452 'February 23, 1993 Mr. John Milligan, Air Quality Specialist • Environmental Protection Services Weld County Department of Health 1517 16th Avenue Court Greeley, CO 80631 Dear Mr. Milligan, RE: ODOR VIOLATION On behalf of Northern Colorado Brine, please consider the following. Northern Colorado Brine has recently completed repairs of the aeration systems. Those systems have been running continuously in an attempt to raise the dissolved oxygen levels of the evaporation ponds to effect a long term favorable response to the odor problems. Northern Colorado Brine feels that the recent odor problems are due, at least in part, to the resumption of aeration and that the odors will diminish as the aerobic state of the ponds is regained. Please be assured that NCB is making every effort to address the odor problems at the site and will continue in their efforts to solve those problems. NCB continues to search for appropriate odor mitigation procedures and has requested assistance from Colorado Department of Health, Air Quality Control Division. In addition, I have successfully completed the CDH Odor Certification process and NCB has ordered a scentometer so that I may assist them in monitoring odors at the site. Please notify me of any odor complaints at 454-3452 or 897-2439. Thank you for your consideration in this matter and do not hesitate to call if I can be of further assistance. Sincerely, Patty Deplazes cc Greg Hobbs, Hobbs Troutt and Raley, PC Keith Schuett, Weld County Department of Planning Mike Cervi, Northern Colorado Brine EASTERN PLAINS ENVIRONMENTAL SERVICE P.O. BOX 142 PIERCE, COLORADO 80650 1-897-2439 or 454-3452 February 24, 1993 Colorado Department of Health APCD-SS-A1 • 4300 Cherry Creek Drive South Denver, CO 80222-1530 Dear Air Quality Engineer, RE: REVISION PERMIT #90WE161 - NORTHERN COLORADO BRINE Please review the enclosed information for the revision of Permit #90WE161 - Northern Colorado Brine Facility. In order to help you better evaluate this facility for air emissions, I am including a description of the operation of NCB. Tank trucks enter the facility through an electronically controlled gate and register each load. The brine water is produced from the pumping of natural gas wells and is .05% - 2.0% crude oil. The brine Is dumped into a receiving pit. The brine is then skimmed through a series of engineer designed pits to separate and remove the oil. The oil then flows into a 4' x 20' upright treater to further separate the skimmed oil and water. The separated crude is sold to a refinery for processing and the water removed is piped into the evaporation ponds. Because the brine water disposed is only .05% - 2.0% crude and because the oil is skimmed prior to release of the brine to the evaporation ponds, the amount of oil available to release emissions from the ponds is very small. The goal of NCB is to remove 100% of the oil from the brine water prior to its release into the evaporation ponds. In the event that some oil scum does form on the ponds, the ponds are skimmed and the oil recovered is treated through the removal system. As you know,Weld County is experiencing a marked increase in oil well drilling, with 35 rigs actively drilling. Because of this unusual level of activity,there has been a dramatic increase In the amount of brine brought to NCB for disposal. This Increase is reflected In the NCB APEN update; however, NCB does not anticipate that this level of activity will be long term. A copy of the 1992 monthly totals is enclosed to demonstrate this increase. NCB is uncertain at this time whether any HAPS are emitted. Please call if I may be of assistance in your evaluation of 90WE161. Sincerely, Patty Deplazes PD:sl Enclosure cc Mike Cervi Northern Colorado Brine a,0 «s J • ad EASTERN PLAINS ENVIRONMENTAL SERVICE PATTY DEPLAZES Bus? (303) 454-3452 P.O. Box 142 Bogie (303) 897-2439 Pierce, CO 80650 April 6, 1993 • Mr. John Milligan Weld County Health Department Environment Protection Services 1517 16th Avenue Court Greeley, CO 80631 Dear Mr. Milligan, On behalf of Northern Colorado Brine, I am writing to update you on the status of the aeration system at NCB. As you recall, on March 18, 1993, I spoke with Charlie Cox at the Colorado Department of Health about the present aeration system at NCB. At that time, NCB had previously called in upset condition due to breakdown of the aeration system. I explained to Mr. Cox that NCB had determined a new, more efficient aeration system was needed. I told Mr. Cox that NCB anticipated installation of the new system would be completed within 30-60 days and the upset condition would continue through that time period. Mr. Cox indicated that he felt this was a reasonable approach and suggested that I call you. I telephoned you and relayed my conversation with Mr. Cox to you. Northern Colorado Brine has actively pursued the installation of a more efficient aeration system and construction of the new system is underway. At this time, NCB anticipates installation of the new system to be done within the original 60 day time frame discussed with Mr. Cox. NCB will continue to operate under upset condition during the construction and installation of the new system. Please call if you have any questions or concerns regarding this matter. Sincerely -E-7711,,;(4e;f7,A._ Patty Deplazes PD:sl cc Mike Cervi, NCB Charlie Cox, CDH Keith Schuett, Weld County Planning 7-kJk7?ouc& Rq? c Attorneys At Law 1775 Sherman Street•Suite 1300 Denver, Colorado 80203 (303)861-1963•Fax: (303)832-4465 March 18, 1993 Mr. Lou McBride Enforcement Investigator Air Pollution Control Division Colorado Department of Health APCD-ADM-B1 4300 Cherry Creek Drive South Denver, Colorado 80222-1530 RE : Conference, Northern Colorado Brine Dear Mr. McBride : Thank you for meeting with the three of us from Northern Colorado Brine . Thanks also to Jeff Stoll and John Milligan. Northern Colorado Brine presented you with a list of measures it intends to take and is taking to address the alleged odor violations at the Northern Colorado Brine facilities , including skimming the ponds , using a misting system, and taking scentometer readings on a regular basis, changing the charcoal filter each time to insure the accuracy of the readings . We presented you with a memorandum from the manufacturer of the scentometer which states that the charcoal should be changed each time . Attached is a list of the contacts Patty Deplazes made in surveying best practical treatment methods which are employed for similar facilities in neighboring States . Please feel free to contact them. As mentioned, we believe that Northern Colorado Brine should be considered to be in the manufacturing category and that best practical treatment is what we should be striving for. 9400:7;e, We requested that you provide us with all readings and field notes dating back to May of 1992 showing the results of field inspections . We believe that many compliance readings have been recorded, including at times when citizen complaints were made. Also, we believe the feedlot in the vicinity may be interfering with the readings or may be the source of the readings and complaints . Nevertheless , the goal of Northern Colorado Brine is to pursue and implement best practical treatment methods and we would appreciate any and all suggestions for improving the treatment process . This has been a hard winter and there have been upset conditions which have affected the operation. With regard to production as reflected in the permit we do not believe that a permit is required for the facility or that a production limitation in any way affects the odor situation or was required to be put in the permit . Nevertheless, we wish to work with the Divison and the Weld County Health Department to address the permit and production status of the facility, as well as available treatment methods . We request that you provide notice to Patty when you are preparing to take a scentometer reading so that she may be present and take a reading relatively contemporaneously. This is only fair, as it seems that the Health Department would welcome the opportunity to monitor the situation on the spot with a company representative. I will be out of the country from March 19 through March 29 . I ask that no compliance order be written as regards the matters we discussed at the conference; however, if one or more compliance orders is issued please know that our prior request for hearing before the Air Commission is hereby amended in my absence to include any and all compliance orders issued to Northern Colorado Brine. The same applies to my request for hearing to Weld County. I hope and expect that we can work together to resolve ottstanding issues . I would appreciate you sending a copy of this letter to your Attorney General representatives . incerely,�cy\r Gregory J. Hobbs, Jr. cc . Mike Cervi, Patty Deplazes , Jeff Stoll , John Milligan s�sn EASTERN PLAINS ENVIRONMENTAL SERVICE P.O. BOX 142 PIERCE, COLORADO 80650 1-897-2439 or 454-3462 • • — " . o --� • �QC�c /27/ OJ s c/ .1ccMACK- Y13- Piz o jeix i 1 i cpoc.z/ Ajar / .hse-rely p omit Jo/ - / '- 3J"I 2/°c't-_ } Puy cvy a odd n - 30 </V 9 -n;'s CL1a$J $e,tacL _ IsAt. tti 6,./4,4 toy 8x7/6 307- bda- yos-/ �/9 sle , - /0 1&v—ker �tf,t n slap W y 30 9- 989- 353 3 c Ir•gwnrl le: 9N61 Broken en lend 1'rkwy.(AIUNIIIR Maryland 210y6 mkpl ane:( 10)501.5070 111 p-1117 fanl7 Slna:i can[m CA 90716 Y'elcphunu:(310)610.7240 320(icrrl Lane AAdlalm 11111109 60101'lblcpinrnc:(708)90.1221 ___iiiihEASTERN PLAINS ENVIRONMENTAL SERVICE PATTY DEPLAZE3 Bus. (303) 454-3452 P.O. ex142 Home (303) 897-2439 Pierce, CO 80650 *l�z )rh 9, / 99 3 / i'6 04 61. 7, 129 3 at ritzietzia, 1--;eitA;(-d a-t em, -6 ., beer )_-) at i2n7etuvri- ebb-Letett 64;rtA-2 Qtyie_ Odd (r c1 ,(1P-44;1-"A- i G� C .�P1 G �a �� idc J (l C( / Ae to C',ev it 4-k ,ctr ' /-7-- c on top U .X- nnti126ryy1-J-tic- V U gene-e- - tii4 C�i/4. "Air /uvilaLft - t cat"- tier (Mk Mazy a.-/ 6o Q C d-tc-szof 6( %�, /qq3 Operation Standard 6 states: A six (6) foot chain link fence with three (3) strand barbed wire top shall enclose the Use by Special Review area. The chainlink fence is not complete. A portion of the fence is down on the south side of the property. Operation Standard 7-A states: The four (4) evaporative ponds shall be engineer designed and operated in accordance to the submitted application materials and Use by Special Review permit Plan Map. All evaporative ponds have not been constructed in accordance with the submitted application materials and Use by Special Review Permit Plan Map. The size of the last pond constructed was not constructed in compliance with the submitted application materials (30 inches for freeboard, 6 inches for salt accumulation, and 24 inches for brine water) . 94:0047,c Operation Standard 7-H states: A gauge height indicator shall be installed in the evaporation ponds. The gauge must clearly indicate the depth of the brine water waste. The gage height indicators that have been installed do not accurately and clearly indicate the depth of the brine water waste. The gauge only indicated a change in the surface elevation of the brine water waste. • Operation Standard Number 7-I states: The evaporation pond(s) shall be kept free and clear of oil skims. The evaporation ponds have not been kept free and clear of oil skims. Operation Standard Number 8-A states: The dump and skim tanks shall be engineer designed in accordance to the submitted application materials and Use by Special Review Permit Plan Map. The application materials states that the skim tanks are to be designed to have a minimum retention time of 72 hours. Due to the size and design of the existing skim facility, the retention time of the brine water is between 4 to 6 hours. Operation Standard Number 15 states: The Use by Special Review shall be limited to the plans shown hereon and governed by the Standards as stated above and all applicable Wald County Regulations. Any material deviations from the plans and/or standards as shown or stated above shall require the approval of an amendment of the Permit by the Weld County Planning Commission and the Board of County Commissioners before such changes from the plans and/or Standards are permitted. Any other changes shall be filed in the office of the Department of Planning Services. The Use by Special Review has not been limited to the plans as shown hereon and is not being maintained in compliance with the stated standards and all applicable Weld County Regulations. No amendment of the permit has been applied for or approved for the material deviations from the approved plans and/or standards. Operation Standard Number 16 states: The property owner and/or operator of this operation shall be responsible for complying with all of the above stated Standards. Noncompliance with any of the above stated standards may be reason for revocation of the Permit by the Board of County Commissioners. The property owner and/or operator of the operation has not maintained compliance with all of the approved standards. NORTHERN COLORADO BRINE--COMPLIANCE ISSUES--OPERATION STANDARD # 8-A Northern Colorado Brine requests approval to use a hammed area of Pond C as a temporary secondary skimming area. Oil will be skimmed from the boomed area as needed. NORTHERN COLORADO BRINE--COMPLIANCE ISSUES--OPERATION STANDARD # 15 All construction at NCB was approved by Weld County. NORTHERN COLORADO BRINE--COMPLIANCE ISSUES--OPERATION STANDARD # 16 Northern Colorado brine continues in its diligent efforts to operate and maintain the facility in compliance with all applicable regulations and requirements. 9"40ye, January 28, 1992 Patricia Deplazes Eastern Plains Environmental Service Box 142 Pierce, CO 80650 Keith Schuett, Weld County Planning Department Trevor Jiricek, Weld County Health Department Dear Keith and Trevor, • RE: NORTHERN COLORADO BRINE COMPLIANCE ISSUE I have been retained by Northern Colorado Brine Facility in order to help them come into compliance with the regulations and Use by Special Review. I have compiled the following plan to address the issues we have previously discussed regarding your areas of concern. Our intent is to respond quickly and effectively to your concerns and to comply with all applicable regulations and standards. Please consider the following items: 1. Depth gauges needed ,Qn ponds : The depth gauges are on site and ready to be installed as soon as the ice melts sufficiently. A gauge was installed in Pond C on January 26, 1993. 2. Contaminated soil from fire area: Frost currently prevents the removal of this soil. It will be removed as soon as the soil thaws sufficiently to allow digging to take place. We will contact WCHD to inspect the area prior to filling with new soil. In addition, the damaged tanks cannot be removed until the investigation into the fire is completed. 3. Update Emissions Permit: I have spoken with Tom Tistinic, Air pollution Control Division, Colorado Department of Health and Northern Colorado Brine Facility is in the process of amending Permit 90WE161 to reflect the increased volume of waste being processed at NCB. 4. Exceeding sffree board: With the new pond now approved to accept water, we are in the process of lowering the level on all ponds. Pond C has been lowered below the freeboard requirements. Ice currently prevents pumping of the other ponds. We will begin pumping from the other ponds into Pond E as soon as weather conditions permit. 5. Records 11QLQa.site: I am currently compiling the permits and documents needed to be at the site. I am also producing a set of documents to simplify the routine record keeping at the site and will initiate that record keeping process with the on site manager as soon as possible. 6. Berms: Following the fire, repair and routine maintenance was done to the berms and roads. At that time, the berms were filled and leveled where settling had occurred. Additionally, in an attempt to direct precipitation runoff and reduce rill washing of the roads and embankments, the roads were edged with a small ridge, but the ridged area is not considered to be a part of the berm. 7. Odors: The odor problems that have occurred at Northern Colorado Brine Facility are considered to be the most significant and most challenging problem at the site. I believe that the addition of the new pond will help in reducing the odors at the site. Also, we are diligently searching for an adequate control method or device for odors at the site. I have spoken with Lou McBride at CDH and Jeff Stoll at WCHD and have asked both CDH and WCHD for assistance in determining what the best management practice for odors at this site would be. However, very little data exists at this time regarding odor problems at brine water disposal sites. In addition, I have scheduled, with WCHD, BOD testing of both the ponds and the incoming water in an effort to determine the cause and nature of the odors. Perhaps these test -results will help us in determining the appropriate control measures. We will continue to search for the answer to the odor problems at Northern Colorado Brine, and I am confident that we will be able to attain compliance with the odor standard as required. Please review this compliance plan, and forward to me any comments, ideas or additional concerns you may have. I may be reached at 897-2439. Sincerely, �e �� /e.ige Patricia Deplazes PD:sl cc Trevor Jiricek, Weld County Health Department Keith Schuett, Weld County Planning Department Mike Cervi, Northern Colorado Brine Facility EASTERN PLAINS ENVIRONMENTAL SERVICE P.O. BOX 142 PIERCE, COLORADO 80640 1-897r2439 or 454-3462 February 11 , 1993 • Trevor Jiricek • Solid and Hazardous Waste Specialist • Weld County Department of Health 1517 16th Avenue Court Greeley, CO 80631 Dear Mr. Jiricek, RE: CERTIFIED LETTERS NO: P423 630 397, NO: P186 978 278 Northern Colorado Brine has received your letters dated January 11, and February 3, 1993. Regarding your December 10, 1992 and February 2, 1993 inspections of Northern Colorado Brine, please consider the following response: 1 . NCB has installed a depth gauge in pond C. Gauges have been prepared and are on site for all ponds, and will be installed as soon as weather permits. These depth gauges will clearly indicate the depth of brine as required in Operation Standard 7-H. 2. NCB is presently pumping into Pond E to lower all freeboards to acceptable levels. As stated in section 4.1.1 of the original application materials for USR - 540, 30" of freeboard is required. Compliance can easily be measured by subtracting 30' from the total depth of the pond. For ponds A, B, C, and D, freeboard compliance is 30" depth of brine. 3. NCB has responded to Certified Letter P 186 978 272, regarding the accepting of Monfort brine. NCB ceased acceptance of Monfort brine upon notification from WCHD. Please note, however, that this waste was accepted based on a verbal approval previously given by WCHD personnel. 4. NCB is making every effort to adequately address and correct all odor problems at the site. Aeration of the ponds is being increased and chemical additives are being considered. 4OO5c 5. The berms have not been raised. The berms and roads have been maintained and leveled. The edge of the roads were ridged up in an attempt to channel precipitation off the dikes in such a way as to reduce rill washing; The USR states that water level in the ponds, A,B,C and D can reach a maximum depth of 30". That compliance point is unchanged. 6. The operator on site has been given additional training in the operation of Northern Colorado Brine. 7. Records are being complied and copied and will be on site for inspection. Documents have been prepared to simplify required daily and monthly record keeping at NCB. Northern Colorado Brine continues in its efforts to bring the facility fully into compliance with all state and local regulations. Please call if you have additional questions or concerns. Sincerely, 7 // • Patty Deplazes / PD:sl cc: Keith Schuett, Weld County Department of Planning Services Roger Doak, Solid Waste Section, HWWMD, Colorado Department of Health Mike Cervi, Northern Colorado Brine EASTERN PLAINS ENVIRONMENTAL SERVICE P.O. BOX 142 PIERCE, COLORADO 80650 1.897-2439 or 454-3452 March 1, 1993 Mr. Keith Schuett Department of Planning Services Weld County Administrative Offices 1400 N 17th Avenue Greeley, CO 80631 Dear Mr. Schuett, In behalf of Northern Colorado Brine, I am writing to inform you of the actions taken to correct the violations stated in your letter dated February 3, 1993. Operation Standard #1 USR 540 NCB has ceased receiving Monfort Brine upon notification from Weld County Health Department that the Monfort Brine was not an approved waste stream. Operation Standard #7H USR 540 Depth gauges have been installed in all ponds as required. The depth of brine in ponds A, C and D is now at or below 30" as required. Pond B is currently being pumped to lower the depth of brine to acceptable levels. However, a breakdown of the pump has prevented NCB from bringing Pond B completely into compliance as of this date. Operation Standard #7J USR 540 The aeration systems have been repaired and are currently operating on ponds A,B and C. The system on Pond D has suffered some breaking of pipes due to the severe winter and will be repaired as soon as possible. An aeration/misting system for Pond E is currently being designed and will be installed as soon as possible. The construction of Pond E and increased aeration are being implemented in an attempt to maintain aerobic condition of the ponds and eliminate odor problems at NCB. Northern Colorado Brine has done routine maintenance and repairs to the berms and access roads surrounding the ponds. The compliance points of 30" depth of brine in ponds A,B,C and D and 10'6" depth of brine for pond E remain unchanged. Operation Standard # 9 USR 540 Operating records have been compiled and are now on site. Operators are maintaining records as required. Also please note that records kept prior to the November 16, 1992 fire at the facility were destroyed when the operators pickup burned. 1 91-4„007;e: Operation Standard #15 USR 540 Construction of Pond E was fully approved by the Weld County Board of Commissioners, Weld County Health Department, Weld County Department of Planning Services and Colorado Department of Health. There was no material deviation from the plans and/or Standards of Operation and no amendment was required. Upon issuance of the required permits, Pond E was properly constructed and fully Inspected and approved prior to filling. In correspondence dated January 11, 1993, Roger Doak, Geologist, Solid Waste Section, Colorado Department of Health, certified that on January 7, 1993, he notified Verrt Nelson, Nelson Engineers, that the pond had met the requirements of the D & O plan for the facility. (enclosed) Operation Standard #16 USR 540 The property owner/operator has made diligent attempts to bring the facility fully into compliance as required. Although inclement weather conditions and equipment failures have interfered with these efforts, NCB has made marked progress in correcting all violations. Efforts will continue to fully correct all violations as soon as possible. A revised Air Pollution Emission Notice (APEN) has been submitted to Colorado Department of Health, Air Pollution Control Division, to update Air Emissions Permit #90WE161. (enclosed) The contaminated soil around the tank battery has been partially removed. This clean up project will be completed as soon as weather conditions permit. Frost and moisture currently prevent the completion of this project. Northern Colorado Brine intends to continue their diligent efforts to fully comply with all requirements of Regulations Pertaining to Solid Waste Disposal Site and Facilities, Section 2, and USR 540. Please call if I may be of further assistance. I may be reached at 454-3452 or 897-2439. Sincerely, 2.409_ Patty Deplazes cc Trevor Jiricek, Weld County Health Department Roger Doak, Colorado Department of Health Mike Cervi, Northern Colorado Brine 9.4005q F''.;f3flr`, NA in( i'/ ZiQ b5 s EXHIBIT INVENTORY CONTROL SHEET Exhi hi+5 `. / nn Case Jh zv(a c.�� —Ak/ G�fn(ow•Ar/ e- ea C.C-ry Exhibit Submitted By Exhibit Description �J / (Eas rn P/gins E?v/r Svc/� 19,, ,131. /"atf3 &e//ays (d7)7(/anee /n c/icri ( 53; 2. 4SSc'SS0t-L /47{ /c 3. t/s� A/a - k 4. !/ /362/-/n f'n//6 T as u 5. /r3chtaniaaC Vet/Wad li 6. n er aerrz ant) .SciernatC, end-heal d n 7. / �J"GL'0r SozU'CQS 67/t`r eeZC( it n 8. er C/fyZ>fj belie?/ dtzzetliri. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. .EASTERN PLAINS ENVIRONMENTAL SERVICE PATTY DEPLAZES _ Bus. (303) 454-3452 P.O. Box 142 Home (303) 897-2439 Pierce, CO 80650 March 30, 1993 Mr. Roger Doak, Geologist Solid Waste Section, HMWMD Colorado Department of Health 4300 Cherry Creek Drive South Denver, CO 80222-1530 Dear Mr. Doak RE: CERTIFIED LETTER # P860418511 MIKE CERVI, NORTHERN COLORADO BRINE, POND E On behalf of Northern Colorado Brine, please consider the following response to Certified Letter #P860418511 dated 03/25/93 and addressed to Mike Cervi, Northern Colorado Brine. Northern Colorado Brine believed that the construction of Pond E had been fully reviewed and approved by the regulatory agencies involved. The drawings submitted by Nelson Engineers prior to construction of Pond E (Pond 4) clearly indicate the depth of Pond E. The gauge rod detailed on those drawings is clearly marked from one (1) foot (GR1) to 13 feet (GR 13). Elevations of the floor and berm of Pond E are clearly marked. Submittal of these detailed drawings was considered by Northern Colorado Brine to be clear and complete notification to Weld County that the depth of brine in Pond E was intended to exceed 30" depth. Pond E volume calculations to a depth of 10' were submitted to Weld County Health Department and Colorado Department of Health by Nelson Engineers. Pond E was designed and constructed to contain maximum depth of brine while still providing the required 30" of freeboard. The actual depth of brine will vary depending on weather conditions, evaporation rates, drilling activity, etc. At least thirty inches (30") of freeboard will be maintained at all times. In addition, Pond E was monitored and visually inspected during construction by Weld County Health Department and Colorado Department of Health personnel. The depth of Pond E was not questioned either verbally or in writing and the pond was approved by WCHD and CDH. Mr. Nelson of Nelson Engineers was notified that Pond #4 ( Pond E) had met the requirements of the D & O plan for the facility. 940058 c�c` • /2 , fr/l_ . The fact that building permits were issued and the design submitted for Pond E was not questioned by Weld County Health Department, Weld County Planning Department or Colorado Department of Health was considered by NCB to be approvat of the submitted design by those agencies. The regulatory agencies involved did not ask for an amendment to the D & 0 prior to or during the construction of Pond E. However, if there was a misunderstanding between Northern Colorado Brine and the regulatory agencies involved in the construction of Pond E, Northern Colorado Brine is willing to work with those agencies in order to come to a timely and agreeable solution to this matter. Please advise me at your earliest convenience what process and procedures you suggest be followed to satisfy this question. I may be reached at 454-3452 or 897-2439. Please call if I may be of further assistance in this matter. Sincerely Patty Deplazes cc Weld County Board of Commissioners Mike Cervi, Northern Colorado Brine Trevor Jericek, Weld County Health Department Keith Schuett, Weld County Planning Department 311005 STATE OF COLORADO COLORADO DEPARTMENT OF HEALTH oF--:c. Dedicated to protecting and improving the health and M environment of the people of Colorado • -< • • i4:-Jg 4300 Cherry Creek Dr.S. Laboratory Building - - , • • - • Denver,Colorado 80222-1530 4210 E.11th Avenue _- ---- . •t 7 • Phone(303)692-2000 Denver,Colorado 80220-3716 (303)691-4700 . Roy Ramer Governor March 25, 1993 Certified # P 860 418 511 Patricia A.Nolan,MD,MPH Executive Director Mike Cervi P.O. Box 300397 Denver, Colorado 80203 - RE: Northern Colorado Brine Disposal, Pond E Weld County, Colorado Dear Mr. Cervi: The Weld County Health Department (WCHD) has requested that the Hazardous Materials and Waste Management Division of the Colorado Department of Health (the Division) clarify the depth of brine water allowed in pond E at Northern Colorado Brine Disposal. As a point of clarification, pond E is referred to as pond #4 during the construction of this impoundment. A letter dated March 1, 1993 from Patty Deplazes to Mr. Keith Schuett of Weld County Planning indicated the depth of brine water in pond E will be maintained at 10 feet 6 inches. This is a violation of the Design and Operations (D&O) plan for this facility. The D&O plan clearly states only 30 inches of brine water will be allowed in each pond. In the same letter, page 2 - "Operation Standard #15 USR 540", a reference is made to a January 11, 1993 letter from the Division to Mr. Cervi. The January 11, 1993 letter states "...the pond had met the requirements of the D&O plan..." This statement refers only to the fact that the construction specifications for pond E have met the requirements of the D&O plan. During the construction of pond E neither the Division or WCHD were informed that the depth of brine water would exceed 30 inches. If you intend to maintain a depth of brine water greater than 30 inches in pond E,you must submit an amended D&O plan to the Division and WCHD for approval. However, if you propose not to amend your D&O plan, immediate removal of any excess volume in pond E shall occur until a 30 inch depth is achieved. The Division requests a written response to this issue within five(5) days of the receipt of this letter. If you have any questions regarding this matter, please contact me at 303-692-3437. Sincerely, oger Doak Geologist Solid Waste Section Hazardous Materials and Waste Management Division cc: T. Jiricek, Weld County Health Department P. Deplazes, Eastern Plains Environmental Service K. Schuctt, Weld County Planning We t'y Cantistiests, file: SW/WLD/NOR 4\ I ) A, I 942 005S SURROUNDING PROPERT OWNERS AND/OR SURFACE ESTATE/MINERAL OWNERS Northern Colorado Brine ZCH-97 Mildred Hankins Phillips Trustee 423 Granada, Unit 10 San Celments, CA 92672 Booth Land and Livestock Company P.O. Box 72 Lucerne, CO 80646 Edward J. Kinzer and Company P.O. Box 280 Johnstown, CO 80534 94,O0:;e, INSPECTION REPORT NAME: Northern Colorado Brine, Mike Cervi P.O. Box 5714 Denver, CO 80217 LEGAL DESCRIPTION OF THE PROPERTY: Part of the NE4 of Section 26 and part of the NW4 of Section 25, all in T5N, R67W of the 6th P.M. , Weld County, Colorado. CASE NUMBER: USR-540 ZCH-97 ZCH-98 DATE: March 9, 1993 The property was reinspected to determine compliance with the approved Development Standards . Trevor Jiricek, of the Weld County Health Department assisted on the inspection. During the inspection it was determined that the property is not being operated in compliance with following Operation Standards 1, 6, 7-A, 7-H, 7-I , 7-1, 8-A, 15, and 16. Operation Standard Number 1 states as follows: The use shall be an oil and gas brine water disposal and oil recovery facility as described in the submitted application materials. No hazardous wastes or nonhazardous industrial waste shall be allowed at the site. The facility shall be designed, constructed, and operated to comply with the Colorado Department of Health Solid Wastes Disposal Sites and Facilities Act, Title 30-20, Part 1, CRS 1973, as amended. The use of the property has not been limited to the oil and gas disposal and oil recovery facility as described in the submitted application materials. The facility is being used for oil field equipment storage. 6 frac tanks, other than the two on site for pond skimming, are being stored on site. Materials other than brine water have been disposed of at the facility (Receipt Numbers 40925 and 40862 indicate that motor oil and other materials were disposed of at the facility) . The depth of all ponds are not consistent with the application materials. The pond depth is not to exceed 5 feet (30 inches for freeboard, 6 inches for salt accumulation, and 24 inches for brine water) . 940056 Ponds do not comply with the minimum freeboard of 30 inches. Pond A had less than 30 inches of freeboard. Freeboard is a part of the 5 foot pond depth from the top of the pond liner (30 inches of freeboard, 6 inches of salt accumulation, and 24 inches of brine water) . The facility is accepting more waste than it was designed for. The facility was designed for no more than 15,000 gallons (500 barrels) per day. The facility has received as much as 9,000 barrels in a day. The facility was designed for a retention time of 72 hours. Retention time of the brine water is as low as 4 to 6 hours with the amount of water being received. Contaminated soils are being stored on site. The height of pond berms have been raised. Pond skim is allowed to accumulate on the ponds, not allowing for property evaporation. Operation Standard 6 states: A six (6) foot chain link fence with three (3) strand barbed wire top shall enclose the Use by Special Review area. The chainlink fence is not complete. A portion of the fence is down on the south side of the property. Operation Standard 7-A states: The four (4) evaporative ponds shall be engineer designed and operated in accordance to the submitted application materials and Use by Special Review permit Plan Map. All evaporative ponds have not been constructed in accordance with the submitted application materials and Use by Special Review Permit Plan Map. The size of the last pond constructed was not constructed in compliance with the submitted application materials (30 inches for freeboard, 6 inches for salt accumulation, and 24 inches for brine water) . Operation Standard 7-H states: A gauge height indicator shall be installed in the evaporation ponds. The gauge must clearly indicate the depth of the brine water waste. The gage height indicators that have been installed do not accurately and clearly indicate the depth of the brine water waste. The gauge only indicated a change in the surface elevation of the brine water waste. 940056 .. .... .... . ... Operation Standard Number 7-I states: The evaporation pond(s) shall be kept free and clear of oil skims. The evaporation ponds have not been kept free and clear of oil skims. Operation Standard Number 7-J states : An aeration system shall be installed and operated on the four evaporative ponds. In the event of an odor problem emanating from the ponds, an odor abatement program shall be instituted. An aeration system has not been installed on all ponds and an odor abatement program has not been instituted to eliminate the existing odor problem. Operation Standard Number 8-A states: The dump and skim tanks shall be engineer designed in accordance to the submitted application materials and Use by Special Review Permit Plan Map. The application materials states that the skim tanks are to be designed to have a minimum retention time of 72 hours. Due to the size and design of the existing skim facility, the retention time of the brine water is between 4 to 6 hours. Operation Standard Number 15 states: The Use by Special Review shall be limited to the plans shown hereon and governed by the Standards as stated above and all applicable Weld County Regulations. Any material deviations from the plans and/or standards as shown or stated above shall require the approval of an amendment of the Permit by the Weld County Planning Commission and the Board of County Commissioners before such changes from the plans and/or Standards are permitted. Any other changes shall be filed in the office of the Department of Planning Services. The Use by Special Review has not been limited to the plans as shown hereon and is not being maintained in compliance with the stated standards and all applicable Weld County Regulations. No amendment of the permit has been applied for or approved for the material deviations from the approved plans and/or standards. Operation Standard Number 16 states: The property owner and/or operator of this operation shall be responsible for complying with all of the above stated Standards. Noncompliance with any of the above stated standards may be reason for revocation of the Permit by the Board of County Commissioners. The property owner and/or operator of the operation has not maintained compliance with all of the approved standards. 940056 • EASTERN PLAINS ENVIRONMENTAL SERVICE PATTY DEPLAZES Bue. (303) 454-3452 P.O. Box 142 Home (303) 897-2439 Pierce, CO 80650 April 6, 1993 • Mr. John Milligan Weld County Health Department Environment Protection Services 1517 16th Avenue Court Greeley, CO 80631 Dear Mr. Milligan, On behalf of Northern Colorado Brine, I am writing to update you on the status of the aeration system at NCB. As you recall, on March 18, 1993, I spoke with Charlie Cox at the Colorado Department of Health about the present aeration system at NCB. At that time, NCB had previously called in upset condition due to breakdown of the aeration system. I explained to Mr. Cox that NCB had determined a new, more efficient aeration system was needed. I told Mr. Cox that NCB anticipated installation of the new system would be completed within 30-60 days and the upset condition would continue through that time period. Mr. Cox indicated that he felt this was a reasonable approach and suggested that I call you. I telephoned you and relayed my conversation with Mr. Cox to you. Northern Colorado Brine has actively pursued the installation of a more efficient aeration system and construction of the new system is underway. At this time, NCB anticipates installation of the new system to be done within the original 60 day time frame discussed with Mr. Cox. NCB will continue to operate under upset condition during the construction and installation of the new system. Please call if you have any questions or concerns regarding this matter. Sincerely "- -4;7, Patty Deplazes PD:sl altulAIM/n) ii\ APR 0 7 1993 cc Mike Cervi, NCB l Charlie Cox, CDH • • -nlnin• Keith Schuett, Weld County Planning 940056 saillikEASTERN PLAINS ENVIRONMENTAL SERVICE PATTY DEPLAZES Bus. (303) 454-3452 P.O. Box 142 Home (303) 897-2439 Pierce, CO 80650 April 6 , 1993 Keith Schuett Weld County Department of Planning Services Weld County Administrative Offices 1400 N. 17th Avenue Greeley , CO 80631 Dear Mr. Schuett , On behalf of Northern Colorado , please review the enclosed document regarding the compliance inspection you conducted at Northern Colorado Brine on March 9 , 1993. In addition , please note that there are now only four (4) frac tanks on site. As noted, it is not known how many tanks will be needed to complete the skimming of the ponds , and NCB requests approval to retain the tanks on site until the skimming process is completed . Skimming will be completed as soon as weather conditions permit . Please call if you have any questions or concerns about this matter. Sincerely , Patty Deplazes enc. cc: Mike Cervi , NCB Trevor Jiricek, WCHD --!tuiLQc\V/fi? APR 0 7 1993 nhinnirr 940056 • NORTHERN COLORADO BRINE--COMPLIANCE ISSUES--USR 540 • RE: March 9, 1993 compliance inspection, Weld County Planning Department Keith Schuett, Planner Northern Colorado Brine has made diligent efforts and significant progress in attempts to address all compliance issues at the NCB facility, and to bring the facility fully into compliance. Due to the extreme weather conditions of the past winter, and the fire that occurred at the facility November 16, 1992, there have been a greater than usual number of problems relating to repair and maintenance at the site. Wet weather conditions continue to hamper efforts to complete all necessary repairs at NCB. However, Northern Colorado Brine believes that significant progress has been made, and is determined to continue in every possible way to correct all areas of concern at NCB. Northern Colorado Brine presents the following document in order to demonstrate the efforts that have been made in the past to correct all problems at NCB, as well as to outline the intentions of NCB in addressing all remaining compliance issues at the site. 940056 INSPECTION REPORT • NAME: Northern Colorado Brine, Mike Cervi P.O. Box 5714 Denver, CO 80217 LEGAL DESCRIPTION OF THE PROPERTY: Part of the NE4 of Section 26 and part of the NW4 of Section 25, all in T5N, R67W of the 6th P.M. , Weld County, Colorado. CASE NUMBER: USR-540 ZCH-97 ZCH-98 DATE: March 9, 1993 The property was reinspected to determine compliance with the approved Development Standards. Trevor Jiricek, of the Weld County Health Department assisted on the inspection. During the inspection it was determined that the .property is not being operated in compliance with following Operation Standards 1, 6, 7-A, 7-H, 7-I, 7-J, 8-A, 15, and 16. 940056 Operation Standard Number 1 states as follows: The use shall be an oil and gas brine water disposal and oil recovery facility as described in the submitted application materials. No hazardous wastes or nonhazardous industrial waste shall be allowed at the site. The facility shall be designed, constructed, and operated to comply with the Colorado Department of Health Solid Wastes Disposal Sites and Facilities Act, Title 30-20, Part 1, CRS 1973, as amended. The use of the property has not been limited to the oil and gas disposal and oil recovery facility as described in the submitted application materials. - The facility is being used for oil field equipment storage. 6 frac tanks, other than the two on site for pond skimming, are being stored on site. Materials other than brine water have been disposed of at the facility (Receipt Numbers 40925 and 40862 indicate that motor oil and other materials were disposed of at the facility) . ▪ The depth of all ponds are not consistent with the application materials. The pond depth is not to exceed 5 feet (30 inches for freeboard, 6 inches for salt accumulation, and 24 inches for brine water) . Ponds do not comply with the minimum freeboard of 30 inches. Pond A had less than 30 inches of freeboard. Freeboard is a part of the 5 foot pond depth from the top of the pond liner (30 inches of freeboard, 6 inches of salt accumulation, and 24 inches of brine water) . • The facility is accepting more waste than it was designed for. The facility was designed for no more than 15,000 gallons (500 barrels) per day. The facility has received as much as 9,000 barrels in a day. The facility was designed for a retention time of 72 hours. Retention time of the brine water is as low as 4 to 6 hours with the amount of water being received. Contaminated soils are being stored on site. • The height of pond berms have been raised. ▪ Pond skim is allowed to accumulate on the ponds, not allowing for property evaporation. 940056 NORTHERN COLORADO BRINE--COMPLIANCE ISSUES--OPERATION STANDARD # 1 The frac tanks presently located on the NCB property are intended for use in holding oil skimmed from the ponds. It is not known at this time how many tanks will be needed in the skimming process. Northern Colorado Brine requests approval to retain these tanks ,on site until the pond skimming is completed. All haulers have been reminded that NCB is approved to accept oil and gas brine and production water only. No other wasted will be accepted without prior approval by Weld County Health Department. Pond E is more than 30" deep. Northern Colorado Brine submitted detailed drawings to Weld County prior to construction of Pond E, and the construction of the pond was approved. Building permits were issued and the construction of the pond was monitored and inspected by Weld County Health Department and the Colorado Department of Health. The depth of the pond was not questioned either prior to or during construction, and the finished pond was approved by WCHD and CfH. Freeboards at the facility are monitored daily to maintain the required 30". NCB will close temporarily as needed to maintain adequate freeboard. Disposal of production water at NCB has dramatically increased due to a temporary increase in drilling activity, and due to the fact that other disposals in Weld County have had a limited amount of pond space available to accept water, As warmer conditions increase evaporation rates, and with the projected opening of the Conquest injection well, the disposal of waste at NCB is expected to decrease. The increase in need for disposal was one of the reasons for the construction of Pond-E. With the increased levels of disposal at NCB, retention times through the skim tanks are reduced. However, testing performed by Cenref Labs of Brighton indicate that 96-99% of the oil in the brine is being removed with 6-8 hours of retention time through the skim tanks. Northern Colorado Brine is now processing all incoming brine through Pond C, prior to release into any other pond. After skimming of all ponds is complete, Pond C will be permenantly boomed to contain any residual oil, and a regular skinning schedule will be implemented as needed. NCB believes that this will provide a very effective and satisfactory solution to the reduced retention time caused by the temporary increase in demand for disposal at NCB. 940056 NORTHERN COLORADO BRINE--COMPLIANCE ISSUES--OPERATION STANDARD #1 Contaminated soils resulting from the November 16, 1992 fire, have been removed from around the tank battery. Weld County Health Department has given verbal approval that this soil may be used to do routine repair and maintenance to the inner berms of the ponds. The height of the pond berms has not been raised. The berms have been graded and ruts left from the heavy equipment used in putting out the November 16,1992 fire have been repaired. The wet, snowy winter also caused some ruts to be formed on the roads between the ponds. However, in many areas, grass is growing along the outer slope of the berm to the crest of the berm, further indicating that the berms have not been raised. The unusually cold weather conditions have adversely affected the efficiency of skimming the oil from the brine at NCB, and there is presently some oil on the surface of the ponds. Ponds A, B and D have been boomed so that the oil may be skimmed as soon as the berms dry out sufficiently to allow a truck on the berms. When the skimming of these ponds is completed, the boom will be permanently installed on Pond C in order to prevent the future release of oil into any of the other ponds. A regular skinning schedule for Pond C will be implemented. 940056 Operation Standard 6 states: A six (6) foot chain link fence with three (3) strand barbed wire top shall enclose the Use by Special Review area. The chainlink fence is not complete. A portion of the fence is down on the south side of the property. Operation Standard 7-A states: • The four (4) evaporative ponds shall be engineer designed and operated in accordance to the submitted application materials and Use by Special Review permit Plan Map. All evaporative ponds have not been constructed in accordance with the submitted application materials and Use by Special Review Permit Plan Map. The size of the last pond constructed was not constructed in compliance with the submitted application materials (30 inches for freeboard, 6 inches for ■alt accumulation, and 24 inches for brine water) . 940056 NORTHERN COLORADO BRINE--COMPLIANCE ISSUES--OPERATION STANDARD #6 A portion of the south fence around the facility was damaged during the fire that occurred November 16, 1992. That fence has now been fully repaired. NORTHERN COLORADO BRINE--COMPLIANCE ISSUES--OPERATION STANDARD #7-A Northern Colorado Brine feels that the design and construction of Pond E had been fully approved, as none of the regulatory agencies involved questioned the depth of the pond either prior to or during construction. 940056 Operation Standard 7-H states: A gauge height indicator shall be installed in the evaporation ponds. The gauge must clearly indicate the depth of the brine water waste. The gage height indicators that have been installed do not accurately and clearly indicate the depth of the brine water waste. The gauge only indicated a change in the surface elevation of the brine water waste. • • Operation Standard Number 7-I states: The evaporation pond(s) shall be kept free and clear of oil skims. The evaporation ponds have not been kept free and clear of oil skims. 94U05ic NORTHERN COLORADO BRINE--COMPLIANCE ISSUES--OPERATION STANDARD # 7-H Guage height indicators have been installed on all ponds. NORTHERN COLORADO BRINE--COMPLIANCE ISSUES--OPERATION STANDARD #7-I Efforts are ongoing to skim all oil from the surface of the ponds. Skimming will be completed as soon as possible. 940056 Operation Standard Number 7-J states: An aeration system shall be installed and operated on the four evaporative ponds. In the event of an odor problem emanating from the ponds, an odor abatement program shall be instituted. An aeration system has not been installed on all ponds and an odor abatement program has not been instituted to eliminate the existing • odor problem. 940056 NORTHERN COLORADO BRINE--COMPLIANCE ISSUES--OPERATION STANDARD # 7-J Northern Colorado Brine will replace the existing aeration system with a system shown to be more efficient at aeration and more effective in reducing odors. It is expected that the installation of the new system will have a beneficial effect on odors at the site. The new system will also be installed on Pond E. In addition, NCB has retained the services of Eastern Plains Environmental Service. EPES is able to provide the services of a Colorado Department of Health Certefied Nose, to more effectively monitor odors at the site. Odor readings are taken with a Barnebey-Cheney Scentometer, according to the Colorado Air Quality Control Regulation 2. Also, NCB has done testing of the pond waters at the facility in an effort to determine the cause and nature of odors at NCB, in order to more effectively minimize odor problems at the site. The construction of Pond E was undertaken as part of an odor abatement plan submitted to WCHD on November 25, 1992. At that time, the present aeration system was also improved in order to increase aeration of the ponds, and chemicals were injected into the ponds in an effort to reduce odors. 310056 • Operation Standard Number 8-A states: The dump and skim tanks shall be engineer designed in accordance to the submitted application materials and Use by Special Review Permit Plan Map. The application materials states that the skim tanks are to be designed to have a minimum retention time of 72 hours. Due to the size and design of the existing skim facility, the retention time of the brine water is between 4 to 6 hours. Operation Standard Number 15 states: The Use by Special Review shall be limited to the plans shown hereon and governed by the Standards as stated above and all applicable Weld County Regulations. Any material deviations from the plans and/or standards as shown or stated above shall require the approval of an amendment of the Permit by the Weld County Planning Commission and the Board of County Commissioners before such changes from the plans and/or Standards are permitted. Any other changes shall be filed in the office of the Department of Planning Services. The Use by Special Review has not been limited to the plans as shown hereon and is not being maintained in compliance with the stated standards and all applicable Weld County Regulations. No amendment of the permit has been applied for or approved for the material deviations from the approved plans and/or standards. Operation Standard Number 16- states: The property owner and/or operator of this operation shall be responsible for complying with all of the above stated Standards. Noncompliance with any of the above stated standards may be reason for revocation of the Permit by the Board of County Commissioners. The property owner and/or operator of the operation has not maintained compliance with all of the approved standards. 940056 NORTHERN COLORADO BRINE--COMPLIANCE ISSUES--OPERATION STANDARD # 8-A Northern Colorado Brine requests approval to use a bommed area of Pond C as a temporary secondary skimming area. Oil will be skimmed from the boomed area as needed. NORTHERN COLORADO BRINE--COMPLIANCE ISSUES--OPERATION STANDARD # 15 All construction at NCB was approved by Weld County. NORTHERN COLORADO BRINE--COMPLIANCE ISSUES--OPERATION STANDARD # 16 Northern Colorado brine continues in its diligent efforts to operate and maintain the facility in compliance with all applicable regulations and requirements. 940056 � f � { APPLICATION - USE BY SPECIAL REVIEW Supporting Documents The following are supporting documents required in the "Procedural Guide for Use by Special Review Application" , The numbering used is that of the guide furnished by Weld County. la. The proposed Waste Disposal Site is consistent with the Weld County Comprehensive Plan. The plan considers water pollution a vital concern in Weld County. Because of the small number of approved sites for disposing of the highly saline production water from oil and gas wells, there is a good possibility that illegal dumping of this water is occurring. This illegal dumping could lead to contamination of both surface and groundwater supplies. The site will help relieve this source of possible water pollution. lb. The Waste Disposal Site is located in an agricultural dis- trict. The site is consistent with the policies and objectives of the Weld County Comprehensive Plan for agricultural districts. It will serve to help protect the water quality of the area as explained in la. Although the site is presently farmed, the location and subsurface geology of the site make it ideal for a Waste Disposal Site. lc. All adjacent properties to the Waste Disposal Site are used for agricultural purposes. The site will pose no dangers or be incompatible to the existing surrounding land uses. The site will help protect the surface and groundwater quality as explained in la. ld. The future use of all adjacent properties is expected to remain agricultural . The Waste Disposal Site will pose no dangers or be incompatible to the proposed surrounding land uses. le. The Waste Disposal Site is not within any of the Overlay Districts (Flood Hazard, Weld County Airport, Geologic Hazards) and therefore is not subject to Weld County Zoning Ordinance, Section 50, Overlay District Regulations. lf. The Waste Disposal Site is located in the "A" District. The site has been located to remove as little land as possible from agricultural production. The odd shaped site configuration was chosen so that interference to the existing center pivot irriga- tion system is kept to a minimum. The site will require that some land which is presently farmed be removed from production. The clayey nature of the soil , the absence of groundwater, and the location out of any flood plain or geologic hazard areas combine to make the site ideal for a Waste Disposal Site. It is felt that the advantages of the site in regards to the protection of surface and groundwater outweigh the loss of the site to agriculture. 940056 lg. The Waste Disposal Site has been designed using the latest engineering technology to provide protection of the health, safety, and welfare, of the inhabitants of the neighborhood and the County. 2. The application is at the front of this Appendix. 3. The certified list of all surface estate property owners within 500 feet of the Waste Disposal Site is at the back of this Appendix. 4. The certified list of all mineral owners and lessees of mineral owners on or under the Waste Disposal Site is attached to the application at the front of this Appendix. 5a. See Introduction, Page 1 5b. The nearest residential structure is approximately one-half mile from the Waste Disposal Site. 5c. It is expected that one employee will supervise the unloading of trucks and perform routine maintenance during the day. 5d. When the site reaches full capacity, (all three ponds constructed) , six trucks per day will bring wastes to the site. 5e. Not used in the Guide. 5f. There will be no animals on the site. 5g. See Engineering Design, Page 2. 5h. Vehicles using the site will be 4500 gallon tank trucks, bringing production water to the site. The trucks will use county roads and the site access road to access the site. A maximum of six trucks per day will use the site. Si . No domestic sewage facilities are planned because it is expected that the site operator will be at the site only to supervise the unloading of trucks and to perform general maintenance. 5j. See Engineering Design, Page 2. 5k. See Engineering Design, Page 4, Paragraph 2. 51 . Construction time for the first pond is expected to start as soon as the necessary permits are obtained. Construction will take approximately one to two months depending on the availability of the tanks. The second and third ponds will be built as required when the use of the site increases. 9400Sa_ 5m. Landscaping will consist of native grasses on the outer slopes of the pond banks. 5n. See Expected Life and Closure, Page 7. 5o. See Fire Protection, Page 6. 6. The "Use by Special Review Permit Plan Map" is presented as Exhibit III. 7a. Mr. Blehm's authorization of Norton , Underwood and Lamb, Inc. , as his representatives is at the end of this Appendix. 7b. It is requested due to the nature of the Waste Disposal Site, that the water supply requirement be waived by the Department of Planning Services , because no water is expected to occur at the site. 7c. A copy of the deed on which the Waste Disposal Site is located is at the back of this Appendix. 7d. It is requested due to the nature of the Waste Disposal Site, that the noise report requirements be waived by the Department of Planning Services . 7e. The geotechnical report is presented as Appendix C. 940056 TABLE OF CONTENTS SECTION PAGE Introduction 1 Location and Size 1 Hydrologic Data 1 Engineering Design 2 Site Monitoring 5 Fire Protection 6 Expected Life and Closure 7 Appendix A : Application - Use by Special Review Appendix B : Letter to State Health Department Appendix C : Geotechnical Report EXHIBITS No . I : Location Map No . II : Site Drainage No . III : Use by Special Review Permit Plan Map 940056 I ( � INTRODUCTION : The proposed Blehm Waste Disposal Site is an oil and gas well production water disposal site . The highly saline product- ion water will be trucked to the site and evaporated from clay-lined ponds . This site will serve the Greeley area , which currently has no site closer than the disposal sites near Roggen and Fort Lupton , Colorado. The site will handle an average of 8 ,000 gallons per day initially , and will be expanded to 24 ,000 gallons per day as the demand increases . LOCATION AND SIZE : The disposal site is located three miles north and one mile east of Milliken , Colorado . The site is in Section 26 , T5N , R67W , of the 6th P . M. , being more particularly described as follows : Beginning at the Northeast corner of Section 26 ; thence along the North line of said Section 26 , considering that said Section line bears North 90° 00 ' 00" West and all bearings being relative thereto ; 743 . 00 feet ; thence South 00° 00 ' 00" West 30. 00 feet to a point on the South right- of-way line of Weld County Road No . 54 , said point being the True Point of Beginning for this des- cription ; thence South 00 ° 00 ' 00" West , 1200 . 00 feet ; thence North 90° 00 ' 00" West 495 . 00 feet ; thence North 30 ° 47 ' 16" West 1396 . 86 feet ; thence South 90° 00 ' 00" East 1210 . 00 feet along the South right-of-way line of Weld County Road No . 54 , to the True Point of Beginning . Said parcel contains 23 .48 acres , more or less . HYDROLOGIC DATA : The disposal site is located approximately one mile South of the Sheep Draw which is the closest stream . The location of ( 1 ) 940056 the site in relation to Sheep Draw is shown on Exhibit No . II . The site is located near the top of a hill and is not within the 100-year floodplain of Sheep Draw . Four test holes were drilled as part of the geotechnical investigation of the site . No groundwater was found in any of the test holes and bedrock was reached at less than seven feet in three of the four test holes . The geotechnical report prepared by Empire Laboratories is presented as Appendix C . Information obtained from the Colorado Water Resources Division show the closest water well to the site to be in the Southwest Quarter of the Northwest Quarter of the Northwest Quarter of Section 34 , T5N , R67W of the 6th Principal Meridian , which is over one mile away from the site . ENGINEERING DESIGN : The production water disposal site will consist of the following components : 1 . Dump tank : Point where the production water is dumped from the truck bringing the water to the site . 2 . Skim tanks : Three 500 bbl tanks that will be used to separate the oil from the production water . 3 . Evaporation Ponds : Clay-lined ponds where the product- ion water will be evaporated . 4 . Oil Storage Tank : A storage tank for the oil removed from the skim tanks . The layout of the components is shown on Exhibit III . Initially , the disposal site will receive an average daily ( 2 ) 940056 1 t load of 8 , 000 gallons per day . It is expected that this average will increase to 24 , 000 gallons per day in the future . To handle the initial 8 , 000 gallons per day, it is proposed to build the dump tank , skim tanks , oil storage tank , all sized for the future 24 , 000 gallons per day , and one evaporation pond . As the daily load increases , the second and third ponds will be built . The dump tank and each skim tank will hold 21 ,000 gallons ( 500 bbls ) each . This provides for a minimum of three days between the time the production water is brought to the site to when it reaches the evaporation ponds . The oil will have time to separate completely from the water before the water reaches the evaporation ponds . The piping between the skim tanks is designed so that the water at the bottom of one tank is trans - ferred to the top of the next tank . This type of piping will also help to minimize transfer of oil from one tank to the next . Exhibit III shows the schematic layout of the site . At this time , it has not been decided whether to use a concrete pit or a steel tank for the dump tank . If a pit is used , it will be covered with one- inch square mesh to prevent access to the pit by wildlife , especially waterfowl . Each evaporation pond will have a 6 . 0 acre- feet capacity . Evaporation data from Fort Collins and a map showing average annual evaporation from shallow lakes prepared by the U . S . National Weather Service , shows an average evaporation of 36 ( 3 ) 94.9DSR inches per year to be a reasonable value for the Greeley area . If all evaporation is assumed to occur during four summer months , then the maximum effective pond depth will be 8/12 ' s of the average evaporation or 24 inches . Pond freeboard was — determined by using the maximum probable amount of precipitation expected to fal•1 on the pond in 48 hours- 30 inches - and : allowing :for six inches of salt accumulation . Total pond depth will , therefore , be five feet . The ponds will be lined with a minimum twelve- inch thick liner using the native clayey soils compacted to 95% of Standard Procter Density, AASHO-T99 . Liner placement techniques are outlined in the geotechnical report by Empire Laboratories , presented as Appendix A . Each pond will have a twelve foot wide access road around it . A qualified soils engineer shall monitor construction of the ponds and provide written certification to the Colorado Department of Health , Waste Management Division , and the Department of Planning Services . Salt accumulation in the ponds was calculated to be less than 0 . 40 inches per year , assuming a salt content of 100 pounds per 1000 gallons of production water . The six inches allowed for salt storage in the ponds will give approximately 15 years of operation before cleaning is necessary. At that time , the salt will be carefully removed from the ponds in such a manner as to avoid damaging the liner and sold or other- ( 4 ) 940056 wise disposed of in an approved manner . The disposal site ' s location near the top of the hill reduces the drainage area above the site to almost zero . The site will be graded so that the small amount of runoff water will be channeled around the evaporation ponds and into the drainage ditch on the south side of County Road No . 54 . The top of the pond walls and the dump tank ( if the concrete pit is used ) will be set a minimum of 12 inches above grade and the ground will be sloped away from these structures . Exhibit II shows the drainage area above the site and the drainage paths of the diverted water . The inside of all tanks and the outside of all buried tanks will be coated to minimize corrosion . The site will be fenced to prevent unauthorized access to the ponds . SITE MONITORING : The State and Weld County Departments of Health require monitoring to detect pond lining failure to avoid contamination of surface and groundwater . As there are no perennial streams within one mile downstream of the site , no surface water monitoring plans are proposed . Failure to pond lining will be monitored with a groundwater monitoring program. Four observation wells will be drilled in the locations shown on Exhibit III . The wells will be constructed from 3 " diameter PVC pipe , perforated from two feet below the ground surface ( 5 ) 940056 C to the bottom of the well . The wells will extend to bedrock . The wells will be provided with a locking lid to prevent tam- pering . The pond water will be tested every six months for the following : TDS Potassium Ph Cadmium Phenols Maganese Iron COD Lead Sulfate Sodium Nitrate Chloride Total Hardness as CaCO3 Total Alkalinity If water is found in the observation wells , the water will be tested annually for TOC and every three months for the following: TDS Nitrate Ph Sulfate Phenols Total Hardness as CaCO3 Iron Total Alkalinity Sodium Water Level Chloride At the end of five years ( from the date of final project approval ) , the liner shall be tested to determine its integrity and life expectancy performance . Copies of the test results will be sent to the Colorado State Department of Health , Weld County Health Department , and any other interested parties on a need to know basis . FIRE PROTECTION : All oil will be stored in steel tanks to minimize the ( 6 ) 940051 (- risk of fire . The design of the skim tanks will ensure that no oil reaches the open lagoons . If any oil reaches the lagoons , it will be vacuumed off the lagoon because it poses not only a fire risk , but retards evaporation . EXPECTED LIFE AND CLOSURE : The site is expected to operate as long as there are oil and gas wells in the area . It is almost impossible to project a date of site closure with the many variables involved with oil and gas drilling . When the site is closed all im- provements will be removed along with all deposited salts . Because the lining of the ponds was constructed with on -site material , it is not expected that the lining will be removed . The site will be regraded to the original contours and it is expected that it will be returned to farm land . Written By : /19€"1-titNEHuZ�. /�S KENNETH K. sRUEY , P . Reviewed By : ORGE44 . UNOERWO 0 , P . E . ( 7 ) 940056 C January 11 , 1983 Colorado Department of Health 4210 East 11th Avenue Denver , CO 80220 Gentlemen : RE : CERTIFICATE OF DESIGNATION FOR BLEHM WASTE DISPOSAL SITE , WELD COUNTY , COLORADO Our Project No . 8232 Mr . Theodore Blehm is proposing to build an oil and gas well production water disposal site north of Milliken , Colorado . The report of which this letter is a part , describes the project . The firm of Norton , Underwood and Lamb , Inc . , is the authorized agent for Mr . Blehm on this project . We are requesting that the Department issue a Certificate of Designation for the project . Please contact me if I can provide any further information on this project . Sincerely, NORTON , UNDERWOOD AND LAMB , INC . /yFiry t<_ tk S/uu y Kenneth K. Shuey , P . E . jc 940056 • _______ EASTERN PLAINS-ENVIRONMENTAL SERVICE PATTY DEPLAZES • r Bus. (303) 454-3452 P.O. Box 142 Home (303) 897-2439 Pierce, CO 80650 • March 30, 1993 Mr. Roger Doak, Geologist Solid Waste Section, HMWMD Colorado Department of Health 4300 Cherry Creek Drive South Denver, CO 80222-1530 Dear Mr. Doak RE: CERTIFIED LETTER # P860418511 MIKE CERVI, NORTHERN COLORADO BRINE, POND E On behalf of Northern Colorado Brine, please consider the following response to Certified Letter #P860418511 dated 03/25/93 and addressed to Mike Cervi, Northern Colorado Brine. Northern Colorado Brine believed that the construction of Pond E had been fully reviewed and approved by the regulatory agencies involved. The drawings submitted by Nelson Engineers prior to construction of Pond E (Pond 4) clearly indicate the depth of Pond E. The gauge rod detailed on those drawings is clearly marked from one (1) foot (GR1) to 13 feet (GR 13). Elevations of the floor and berm of Pond E are clearly marked. Submittal of these detailed drawings was considered by Northern Colorado Brine to be clear and complete notification to Weld County that the depth of brine in Pond E was intended to exceed 30" depth. Pond E volume calculations to a depth of 10' were submitted to Weld County Health Department and Colorado Department of Health by Nelson Engineers. Pond E was designed and constructed to contain maximum depth of brine while still providing the required 30" of freeboard. The actual depth of brine will vary depending on weather conditions, evaporation rates, drilling activity, etc. At least thirty inches (30") of freeboard will be maintained at all times. In addition, Pond E was monitored and visually inspected during construction by Weld County Health Department and Colorado Department of Health personnel. The depth of Pond E was not questioned either verbally or in writing and the pond was approved by WCHD and CDH. Mr. Nelson of Nelson Engineers was notified that Pond #4 ( Pond E) had met the requirements of the D & O plan for the facility. II APR 0 2 1993 ! y 940056 Oc: i2G , "vz, The fact that building permits were issued and the design submitted for Pond E was not questioned by Weld County Health Department, Weld County Planning Department or Colorado Department of Health was considered by NCB to be approval of the submitted design by those agencies. The regulatory agencies involved did not ask for an amendment to the D & 0 prior to or during the construction of Pond E. However, if there was a misunderstanding between Northern Colorado Brine and the regulatory agencies involved in the construction of Pond E, Northern Colorado Brine is willing to work with those agencies in order to come to a timely and agreeable solution to this matter. Please advise me at your earliest convenience what process and procedures you suggest be followed to satisfy this question. I may be reached at 454-3452 or 897-2439. Please call if I may be of further assistance in this matter. Sincerely Patty Deplazes cc Weld County Board of Commissioners Mike Cervi, Northern Colorado Brine Trevor Jericek, Weld County Health Department Keith Schuett, Weld County Planning Department EASTERN PLAINS ENVIRONMENTAL SERVICE PATTY =BLAZES Bus. (303) 454-3452 P.O. Box 142 Home (303) 897-2439 Pierce, CO 80650 March 30, 1993 Mr. Roger Doak, Geologist P Solid Waste Section, HMWMD Colorado Department of Health yI! APR 0 1 1993 U 4300 Cherry Creek Drive South 5 — Denver, CO 80222-1530 Dear Mr. Doak RE: CERTIFIED LETTER it P860418511 MIKE CERVI, NORTHERN COLORADO BRINE, POND E On behalf of Northern Colorado Brine, please consider the following response to Certified Letter #P860418511 dated 03/25/93 and addressed to Mike Cervi, Northern Colorado Brine. Northern Colorado Brine believed that the construction of Pond E had been fully reviewed and approved by the regulatory agencies involved. The drawings submitted by Nelson Engineers prior to construction of Pond E (Pond 4) clearly indicate the depth of Pond E. The gauge rod detailed on those drawings is clearly marked from one (1) foot (GR1) to 13 feet (GR 13). Elevations of the floor and berm of Pond E are clearly marked. Submittal of these detailed drawings was considered by Northern Colorado Brine to be clear and complete notification to Weld County that the depth of brine in Pond E was intended to exceed 30" depth. Pond E volume calculations to a depth of 10' were submitted to Weld County Health Department and Colorado Department of Health by Nelson Engineers. Pond E was designed and constructed to contain maximum depth of brine while still providing the required 30" of freeboard. The actual depth of brine will vary depending on weather conditions, evaporation rates, drilling activity, etc. At least thirty inches (30") of freeboard will be maintained at all times. In addition, Pond E was monitored and visually inspected during construction by Weld County Health Department and Colorado Department of Health personnel. The depth of Pond E was not questioned either verbally or in writing and the pond was approved by WCHD and CDH. Mr. Nelson of Nelson Engineers was notified that Pond #4 ( Pond E) had met the requirements of the D & O plan for the facility. 940056 The fact that building permits were issued and the design submitted for Pond E was not questioned by Weld County Health Department, Weld County Planning Department or Colorado Department of Health was considered by NCB to be approvat of the submitted design by those agencies. The regulatory agencies involved did not ask for an amendment to the D & O prior to or during the construction of Pond E. However, if there was a misunderstanding between Northern Colorado Brine and the regulatory agencies involved in the construction of Pond E, Northern Colorado Brine is willing to work with those agencies in order to come to a timely and agreeable solution to this matter. Please advise me at your earliest convenience what process and procedures you suggest be followed to satisfy this question. I may be reached at 454-3452 or 897-2439. Please call if I may be of further assistance in this matter. Sincerely Patty Deplazes cc Weld County Board of Commissioners Mike Cervi, Northern Colorado Brine Trevor Jericek, Weld County Health Department Keith Schuett, Weld County Planning Department 940056 STATE OF COLORADO COLORADO DEPARTMENT OF HEALTH ai t c' Dedicated to protecting and improving the health and � • � environment of the people of Colorado I t, rl ei? 4300 Cherry Creek Or.S. Laboratory Building \ Denver,Colorado 80222-1530 4210 E.11th Avenue \rs T6� Phone(303)692-2000 Denver,Colorado 80220-3716 (3031691-4700 Roy Romer Governor March 25, 1993 Certified # P 860 418 511 Patricia A.Nolan,MD,MPH Executive Director Mike Cervi P.O. Box 300397 Denver, Colorado 80203 RE: Northern Colorado Brine Disposal, Pond E Weld County, Colorado Dear Mr. Cervi: The Weld County Health Department (WCHD) has requested that the Hazardous Materials and Waste Management Division of the Colorado Department of Health (the Division) clarify the depth of brine water allowed in pond E at Northern Colorado Brine Disposal. As a point of clarification, pond E is referred to as pond #4 during the construction of this impoundment. A letter dated March 1, 1993 from Patty Deplazes to Mr. Keith Schuett of Weld County Planning indicated the depth of brine water in pond E will be maintained at 10 feet 6 inches. This is a violation of the Design and Operations (D&O) plan for this facility. The D&O plan clearly states only 30 inches of brine water will be allowed in each pond. In the same letter, page 2 - "Operation Standard #15 USR 540", a reference is made to a January 11, 1993 letter from the Division to Mr. Cervi. The January 11, 1993 letter states "...the pond had met the requirements of the D&O plan..." This statement refers only to the fact that the construction specifications for pond E have met the requirements of the D&O plan. During the construction of pond E neither the Division or WCHD were informed that the depth of brine water would exceed 30 inches. If you intend to maintain a depth of brine water greater than 30 inches in pond E,you must submit an amended D&O plan to the Division and WCHD for approval. However, if you propose not to amend your D&O plan, immediate removal of any excess volume in pond E shall occur until a 30 inch depth is achieved. The Division requests a written response to this issue within five(5) days of the receipt of this letter. If you have any questions regarding this matter, please contact me at 303-692-3437. Sincerely, ox_ oger Doak Geologist Solid Waste Section Hazardous Materials and Waste Management Division cc: T. Jiricek, Weld County Health Department P. Deplazes, Eastern Plains Environmental Service u ;ftSchuettlWeld County Planning Weld County Commissioners y 1993ma 2 file: SW/WLD/NOR 940056 1 DEPARTMENT OF PLANNING SERVICES PHONE(303) 353.3845, EXT. 3540 C WELD COUNTY ADMINISTRATIVE OFFICES O 1400 N. 17TH AVENUE GREELEY, COLORADO 80631 COLORADO March 12, 1993 Northern Colorado Brine c/o Mike Cervi 10600 Weld County Road 54 Milliken, CO 80543 Subject: ZCH-97, USR-540, located on part of the NE4 of Section 26, and part of the NW4 of Section 25, all in T5N, R67W of the 6th P.M. , Weld County, Colorado. Dear Mr. Cervi: Notice is hereby given that on Monday, April 12, 1993 , at 9:00 a.m. , or as soon thereafter as the agenda of the Board of County Commissioners permits , the Board of County Commissioners of Weld County will hold a Probable Cause public hearing pursuant to Section 24.8.1 of the Weld County Zoning Ordinance. This meeting will take place in the Commissioners' Hearing Room, Weld County Centennial Center, 915 Tenth Street, Greeley, Colorado. The purpose of this public hearing will be to review Case Number USR-540 for compliance with the Operation Standards as approved by the Board of County Commissioners on December 12, 1983 , to determine if probable cause exists to hold a hearing on revocation of USR- 540. Inspection by representatives of this office have identified that you are not in compliance with all approved Operation Standards of USR-540. If it is determined at the public hearing that there is probable cause that you are not . in compliance with Operation Standards as approved by the Board of County Commissioners will schedule a Show Cause public hearing to consider revocation of the Special Review permit. If you have any questions regarding this matter, please telephone. Respectfully, .1".' tF'ASchume /-C Current Planner pc: Eastern Plains Environmental Services c/o Patricia DePlazes P.O. Box 142 Pierce, CO 80650 940056 9S0ovc PS Form 3800, June 1991 - .. p o 1° 13 _. oo CL 7Y s; £6/ZT/£ b - oar m - 02O :3 Os p' w a Q r • Dg ' 1p r a A c « -. CD n o _ C _ N w m o 09 -.J 0o ▪ G r I $ c g 2 N `° I _ _ m r 1 Cr, I W1NI , I y S PS Form 3800, June 1991 £VSOS OD - • awn all pue aie,5 C a o oH.7" N Z- i 8o Cluno3 PiaM0Q90.G. .17 70 y a e , o °• 0 TAIeD aK oI^I K = ,23 _ x= o Z m �as �• o _ =14 .11 o a * 5 c'»o a- (asraned aa51 iro ,7,na,.,.w A - o o pey,1 Ieuonewalul .io; asn 1ou oa - '_ _ ' a' ('J a CD 0 a'm ^ `c' K W '� papinad a6eranop aoueinsul oN r k : = O o o m` a 'w_ W v Pe1N Paligia0 - to s n - Jo} ldlaoaa w c o = g 3 ° o- ru 252 L L 6 99't d 4n v} a P < °'. ry w o03 So ' M 92 el fa. CD do co a n Ka a m �. £6/ZT/£ o . 3 ( . 0124 10)02wlSed O $ MIMI L C „am a as g.0 a rue awe Du PS Form 3800, June 1991 — _ uuM 01 fiu wou5.oiavay wmatl O n 9 y = N n m o ^ [b rc' illi . V o _ _ �• fD SI ~ • 9ay » coo N f _ co c = o F+ < c n .1 ® .be m : m O so n n Rl VD CA 1 ° m 1r 8b908, OD,,�. of yr — d = w 96 ?toll A}�°J piaM ?S09i„ o▪ „ sareIdaG tT3tal,Pcbs v _a lasranay 0051 3 is vs pen (000020'31ul lo; asn Sou 00 papinoid 06919A03 aoueinsul ON I! IN pal}13ia3 sir - Jo; 3dleoaa LS2 LL6 99T d i-i-bg --4-ro&v p o OvA,1 Crn._, — — I services. I also wish to receive the following services (for an extra . ._ roierse of this form so feel: that we can return this care ._ you. 1. ❑ Addressee's Address • Attach this form to the front of the mailpiece, or on the back if space does not permit. 2. Restricted Delivery • Write "Return Receipt Requested" on the mailpiece next to the article number. Consult postmaster for fee. 3. Article Addressed to: 4a. Article Number Mike Cervi P 186 977 261 P.O. Box 14.2-1_4, 4b. Service Type _ Roggen, CO 80652 El Registered _ Insured . Certified _ COD E Express Mail ❑ Return Receipt for Merchandise 17. Date of Delivery 5. Signature (Addressee) 6 8. AddresseZs' /Address(Only if requested and fee is paid) 6. attire (Agent) / G/cGw :71', PS For�81 I, October 1990 *U.S.GPO:1990-273881 DOMESTIC RETURN RECEIPT • I also wish to receive the .tional services. • _ following services (for an extra • f,,,1t tu,,, „e,,,. reverse of this form so feel: that we can return this card to you. 1. ❑ Addressee's Address • Attach this form to the front of the mailpiece, or on the back if space does not permit. 2. ❑ Restricted Delivery • Write "Return Receipt Requested" on the mailpiece next to the article number. Consult postmaster for fee. 3. Article Addressed to: 4a. Article Number Northern Colorado Brine P 186 977 262 4b. Service Type c/o Mike Cervi ❑ Registered ❑ Insured 10600 Weld County Road 54 DICertified ❑ COD Milliken, CO 80543 ❑ Express Mail ❑ Return Receipt for Merchandise � ,, �J� 7. Date of Delivery .7__, 5. Sig%.-72,211,1„t ature (Ad ressee) 8. Addressee's Address(Only if requested and fee is paid) 6. Signature (Agent) PS Form 3811, October 1990 au.s.GPO:1990-273861 DOMESTIC RETURN RECEIPT • NUER: I also wish to receive the • • Complete items 'I and/or 2 for additional services. following services (for an extra • Complete items 3, and 4a & b. • Print your name and address on the reverse of this form so fee):1. ❑ Addressee's Address that we can return this card to you. • Attach this form to the front of the mailpiece, or on the back if space does not permit. 2 ❑ Restricted Delivery • Write "Return Receipt Requested" on the mailpiece next to Consult postmaster for fee. the article number. 4a. Article Number 3. Article Addressed to: P 186 977 263 • Mike Cervi -- - - 4b. Service Type ❑ Insured ❑ Registered P.O. Box 300397 Certified ❑ COD Denver, CO 80203 Return Receipt for ❑ Express Mail ❑ Merchandise I 7-Q 6fpelivery ��C j. i s�, 8, ,Ddressee's•Address(Only if requested 5, -i. a fe IAddr. see) C 1d,fge'� Pte) . A t 6. Signature (Agent) ; 940056 GPO:,99o—z73as, PS Form 3811, October 1990 >us. y bOMESTIC RETURN RECEIPT EASTERN PLAINS ENVIRONMENTAL S v P.O. BOX 142 PIERCE, COLORADO 80650 1- - drly +,-lJ a _..«.mannln• March 11 , 1993 Mr . Trevor Jiricek Mr . Keith Schuett Weld County Health Department Weld County Department of Planning 1517 16th Ave . Ct . 1400 North 17th Avenue Greeley , CO 80631 Greeley , CO 80631 Dear Mr. Jiricek and Mr . Schuett , On behalf of Northern Colorado Brine , please consider the following response to your inspection of March 9 , 1993 . I . A . 1) Frac tanks are on site to receive oil removed from ponds in skimming process . 2) Expansion of the facility was approved by the Weld County Board of Commissioners in response to the need for increased disposal of brine in Weld County . 3) Wash water disposed was from using hot water to rinse out brine trucks . This is nothing more than brine dilluted with freshwater. 4) Pond E was approved and inspected prior to and during construction. No ammendment to USR-540 was required. Northern Colorado Brine therefore concludes that Weld County Department of Planning Services does NOT consider Pond E to constitute a major change from USR-540 as approved. 5) Berms at NCB have NOT been raised, and the compliance points on all ponds remain as approved . H. DEPTH of brine records are kept as required . Recording of freeboard is NOT required. I . NCB DOES have an approved air emissions permit #90WE161 . An APEN update form has been submitted to Colorado Depart- ment of Health for review. II .A. The validity of odor violations at NCB has not been established . The facility is NOT required to operate without odors . B. The fence on the south side of the facility was damaged in the fire and will be repaired as soon as possible. F. Equipment to skim the ponds was on site at the time of your inspection , awaiting favorablend a 5 Pond n conditions . 6Su0% Sum con ponds as : Pond A-- 2-3%, Pond D-- 2-3%, Pond E--1%. C . Freeboard guages are accurately installed and readable. Freeboard records are not required to be kept . H. Freeboard is NOT less than 30" on Pond A. The I contaminatedl resulting from the fire has removed, and samples have been submitted foranalysist. MAR 1 11993 LI h .,_,,,. .._4..4�an�,il-940056 March 11 , 1993 EPES to Weld County RE: NCB, March 9 , 93 inspection page 2 Northern Colorado Brine is in compliance at this time , and Northern Colorado Brine continues in its diligent efforts to respond to your concerns , and to bring the facility fully into compliance with USR-540 and all applicable regulations . Please call if you have any questions or concerns regarding this matter. I may be reached at 454-3452 or 897-2439 . Sincerely , Patty Deplazes cc: Mike Cervi , Northern Colorado Brine 3400% `�iiishEASTERN PLAINS ENVIRONMENTAL SERVICE PATTY DEPLAZES Bus. (303) 454-3452 P.O. Box 142 Home (303) 897-2439 Pierce, CO 80650 March 11 , 1993 Trevor Jiricek, Solid and Hazardous Waste Specialist Weld County Health Department, Environmental Protection Services 1517 16th Avenue Court Greeley, CO 80631 Dear Mr. Jiricek On behalf of Northern Colorado Brine, I am responding to the letter you recently addressed to Roger Doak, Colorado Department of Health, regarding possible groundwater impact at NCB. Northern Colorado Brine believes it is important to carefully consider the geologic and engineering data contained in the original Design and Operation Plan submitted for NCB. The D & O clearly states that there is no groundwater underlying the NCB facility. Application - Item i "... The clayey nature of the soil, the absence of groundwater and the location out of any flood plain or geologic hazard areas combine to make the site ideal for a Waste Disposal Site..." Application - Certificate of Designation 10-19-83 "...Fox Hills Aquifer does not extend into the area of the proposed site because it is hydrologically cut off at the Big Thompson and Platte Rivers. The Laramie and Fox Hills formation is the bedrock underlying the site, but no aquifer is present..." Apolication - Certificate of Designation 4.1.3 ...There are no significant aquifer recharge areas to be impacted by the site... In order to impact the recharge area leachate would have to first reach the alluvial aquifer and then travel against the flow of groundwater into the aquifer. This is physically impossible... 940056 4.1.5 ...There is no existing groundwater beneath the site other than that which might exist below the Pierre Shale... 4.4.1 ...The surface thickness of the alluvial deposits varies from seven to fourteen feet and is not a water bearing deposit... 4.5.2 ...There is no aquifer designated on this site... 4.5.4 ...Since there is not a defined uppermost aquifer we have concluded that any seepage from an inadvertent break in the liner at the facility will flow primarily along the surface of the bedrock to the underdrains connected to the proposed observation wells... 4.5.6 ...The potential for impact on groundwater is also negligible as previously stated in 4.5.4 because even unlined ponds would not allow seepage to reach groundwater sources... 4.5.7 ... There is no existing groundwater beneath the site other than that which might exist below the Pierre Shale... therefore the site will not affect the groundwater quality. The Addendum to Report of a Geotechnical Investigation further states: Page - 3 ...At the time of investigation, no free groundwater was encountered at the site to the depths explored... Page - 5 ...excessive movement of water through this formation is not anticipated due to the interbedded nature of the siltstones, sandstones and claystones...Since the bedrock is relatively impervious, it is felt water would travel on the bedrock surfaces to the observation wells... Northern Colorado Brine believes that the design of the facility, with a continuous French Drain surrounding the site, provides excellent protection. Any seepage from the ponds will be intercepted by the French Drain before it can migrate from the site. Application Certificate of Designation 4.1.4 ...The ponds will be surrounded by a continuous French Drain which will be connected to the monitoring wells. The drains will be placed one foot into sound bedrock and surrounded by gravel. The drain trench will be backfilled with compacted clay soil. This back fill will act as an impervious barrier, similar to the pond liners, forcing any escaping leachate into the drains where it will flow to the monitoring wells and be detected. The drains will slope towards the observation wells. The wells will be located at the low points of the bedrock and there will be a minimum of seven... 940056 Northern Colorado Brine is confident that there is no impact to groundwater from the facility. • If you have any questions or concerns about the design of NCB, or if I can be of further assistance, please call. I may be reached at 454-3452 or 897-2439 . Sincerely Patty Deplazes DP:sI cc Roger Doak, Colorado Department of Health Keith Schuett, Weld County Department of Planning Mike Cervi, Northern Colorado Brine • 340056 DEPARTMENT OF PLANNING SERVICES PHONE (303)353.3845, EXT. 3540 WELD COUNTY ADMINISTRATIVE OFFICES Ci 1400 N. 17TH AVENUE GREELEYEY, COLORADO 80631 COLORADO March 11, 1993 Northern Colorado Brine c/o Mike Cervi 10600 Weld County Road 54 Milliken, CO 80543 Subject: ZCH-98 Dear Mr. Cervi: An on-site inspection of your property was conducted on March 9 , 1992, to determine if the Conditions of Approval and the Development Standards placed on your property at the time USR-540 was approved by the Board of County Commissioners are in compliance. The inspection revealed violations of Development Standards 1, 6, 7-A, 7-H, 7-I, 7-J, 8-A, 15 and 16 #. A copy of these items from the approved resolution are enclosed. The Use by Special Review area must be brought into compliance with the Conditions of Approval and the Development Standards within 30 days from the date of this letter. Noncompliance will result in our office scheduling a Probable Cause Hearing before the Board of County Commissioners. If the Board determines there is sufficient probable cause to warrant further action, a Show Cause Hearing will be scheduled to consider revocation of the Use by Special Review permit. If you have information that may clear up this matter, please call or write. Sincerely, -gfirotS":447.4. Current Planner KAS/sfr enclosures pc: Patricia DePlazes Eastern Plains Environmental Services P.O. Box 142 Pierce, CO 80650 940056 MAR- 9-93 TUE 22:43 WEI0 CO HEALTH DEPT FAX NO. 303?"4966 P. 02 SOLID WASTE FACILITY INSPECTION (Surface Impoundments) County .. � DATE 5/9/4 3 Located in Facility f1ttva talk _r+Att- Incorporated Area Location IAl,Cr0 WUrc cq Mill it- Current Operator /C'e44 ."Ti eyni.(r Mailing Address of Operator /Yfrs ('vywt. - Current Owner (If different) Mailing Address of Owner �a�ra��m...e�au��w�w�edw�wsowW W W W W W�.wmarearwrsbnewnoiss.umewr (All items checked must be explaind in supplemental report) I. A. Public Health and/or Environmental Hazards B. Evidence of Potential for (Serious) Surface Water Pollution — C• . Evidence of Potential for (Serious) Groundwater Pollution __— D• . Sludge or Septic Pumping' Disposal on Site (Unauthorized) • Safety Hazards ✓ P. Non-Compliance with Approved Design end Operation G. Structural Integrity of Dikes Questionable Records nI. y _ Other Eiui u f1Ga 'rvn.Jl * REMEDIAL ACTION REQUIRED II. Minimum Standards, CRS 30, 20-110 • Odors and/or Vectors Present B. Inadequate Fencing (to control access) - C. Not Designated and/or Improperly Zoned D. Monitoring Wells (Maintenance, Intregrity, or Locking Cap not Present) E. Evidence of Minor Spills Around Disposal Area ✓ it. Water/Liquid Surface Covered with oil(s) or scum G. Depth Gauges not Present and or Readible i/—H. Pond Freeboard Level Exceeded. 1 Recommendations for Sits ta Improvement...rovemen r fre J. Other AI J� us.)..? f}e't " 110 Ck Siff W't u+' "a III. Remazks�q�C� �^ 1 -/A;14FiC4 4f,esyltir, sign m$c gas 'v J Div 3) aril earn uaskohrvari wed-t4F?- Martilt 3 qs iAlvVttad `{0929 E 10162-- a /t . tsuvdf Keg ilk Enzility 2 �,- �.,, 3:V ei Pat YI p rcr..d Might) ,eviniL it/01-12 ,.'l1!it/01-12a x eewrilhik rll gCui'iPtiil 1N r�a7� nals� AF tine o 1 ne .•gym nbIAI p r r Farr Saw fd<. Frc 'y rM <Ju Srtar Alurv.wl a+ luring' For, 4 451 i R10`Yo . ( EOfo 'b ? . E LSlro r_ ,d vljtt 44 rat acc“AA tuck r..Un rrsm.o� m� ?s-)s. abit� eeaw m.+ (Name)1 PRESENT AT cI1NSPECTION (Representing) Fvc4zo4L a.p.ptG '.1 Ra b >30° C44. pw4b •. s) Biros &UOAt1 rvof Ck t v. lro U oars b io: ‘A'•t-A : wkAn (Y-W° Pods /( taept'crlon-cngineer/Csulogter 1 IY'?W1/ ciwtc.c K (WRITE COPY-FILE) (YELLOW COPY OPERATOR) (PINK COPY-COUNTY) MAR 9 '93 22142 3033564966 PAGE.022 940056 EASTERN PLAINS ENVIRONMENTAL SERVICE P.O. BOX 142 PIERCE, COLORADO 80650 1-897-2439 or 454-3452 March 1, 1993 Mr. Keith Schuett Department of Planning Services Weld County Administrative Offices 1400 N 17th Avenue Greeley, CO 80631 Dear Mr. Schuett, In behalf of Northern Colorado Brine, I am writing to inform you of the actions taken to correct the violations stated in your letter dated February 3, 1993. Operation Standard #1 USR 540 NCB has ceased receiving Monfort Brine upon notification from Weld County Health Department that the Monfort Brine was not an approved waste stream. Operation Standard #7H USR 540 Depth gauges have been installed in all ponds as required. The depth of brine in ponds A, C and D is now at or below 30" as required. Pond B is currently being pumped to lower the depth of brine to acceptable levels. However, a breakdown of the pump has prevented NCB from bringing Pond B completely into compliance as of this date. Operation Standard #7J USR 540 The aeration systems have been repaired and are currently operating on ponds A,B and C. The system on Pond D has suffered some breaking of pipes due to the severe winter and will be repaired as soon as possible. An aeration/misting system for Pond E is currently being designed and will be installed as soon as possible. The construction of Pond E and increased aeration are being implemented in an attempt to maintain aerobic condition of the ponds and eliminate odor problems at NCB. Northern Colorado Brine has done routine maintenance and repairs to the berms and access roads surrounding the ponds. The compliance points of 30" depth of brine in ponds A,B,C and D and 10'6" depth of brine for pond E remain unchanged. Operation Standard # 9 USR 540 Operating records have been compiled and are now on site. Operators are maintaining records as required. Also please note that records kept prior to the November 16, 1992 fire at the facility were destroyed when the operators pickup burned. 940056 Operation Standard #15 USR 540 Construction of Pond E was fully approved by the Weld County Board of Commissioners, Weld County Health Department, Weld County Department of Planning Services and Colorado Department of Health. There was no material deviation from the plans and/or Standards of Operation and no amendment was required. Upon issuance of the required permits, Pond E was properly constructed and fully inspected and approved prior to filling. In correspondence dated January 11, 1993, Roger Doak, Geologist, Solid Waste Section, Colorado Department of Health, certified that on January 7, 1993, he notified Vern Nelson, Nelson Engineers, that the pond had met the requirements of the D & O plan for the facility. (enclosed) Operation Standard #16 USR The property owner/operator has made diligent attempts to bring the facility fully into compliance as required. Although inclement weather conditions and equipment failures have interfered with these efforts, NCB has made marked progress in correcting all violations. Efforts will continue to fully correct all violations as soon as possible. A revised Air Pollution Emission Notice (APEN) has been submitted to Colorado Department of Health, Air Pollution Control Division, to update Air Emissions Permit #90WE161. (enclosed) The contaminated soil around the tank battery has been partially removed. This clean up project will be completed as soon as weather conditions permit. Frost and moisture currently prevent the completion of this project. Northern Colorado Brine intends to continue their diligent efforts to fully comply with all requirements of Regulations Pertaining to Solid Waste Disposal Site and Facilities, Section 2, and USR 540. Please call if I may be of further assistance. I may be reached at 454-3452 or 897-2439. Sincerely, Patty Deplazes cc Trevor Jiricek, Weld County Health Department Roger Doak, Colorado Department of Health Mike Cervi, Northern Colorado Brine 940056 ---- o \ _ = c\ — � E : < z n = L N L 31 1 _ < v 4 - xo � � y o S. � = Ip ',I _ th co (L Z O 'c 'I a f<.7 Q.. A o •- u < E CO „ z as o `e • } 9 C W I O ^i. {, = Ci Z t-• �. V p V O cc c I u L 'c Q o i n v: d i s = - Y j 2 a o C a i c < WX : � u , = F, W N sy t u < u •U ,:tW c z < g.JJ W K \ O O W E c O'. y Y in Z 51 J `\ i C N L J Vp V U O f.1 v to i .. 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E - ' z` o' er 6" z - < = i re• s z < zzv. e w ° w a, LL 'c _y E c.C s •c , _ 2 ; ` • 2 0 ^ < 1 Et W "� < Z L_� � .. �'Y _ ✓ O P 1 .! u � � v Z i :1 '`` S T El r t..( y L L tJ 940056 EASTERN PLAINS ENVIRONMENTAL SERVICE P.O. BOX 142 PIERCE, COLORADO 80650 1-897-2439 or 454-3452 March 1, 1993 Mr. Trevor Jiricek, Solid & Hazardous Waste Specialist Weld County Department of Health, Environmental Protection Services 1517 16th Avenue Court Greeley, CO 80631 Dear Mr. Jiricek, RE: CERTIFIED LETTER P186978297 In behalf of Northern Colorado Brine, please consider the following response to Certified Letter P186978297. As you are aware, the Roggen Disposal Facility is presently under temporary voluntary closure. No wastes are being accepted at this site and no operator is currently employed at the site. Access has been controlled as required by Section 2.2.1 of the "Regulations Pertaining to Solid Waste Disposal Sites and Facilities," ... Facilities for solid waste disposal shall be kept adequately fenced to prevent unauthorized public access without operator supervision." Additionally, Development Standard#1, USR 481:81:27, requires that "... The site shall be secured to prohibit dumping when an employee is not on the subject site..? Development Standard #14 further states "... The applicant shall install adequate fencing for control of access..? As you can see, every effort has been made to comply with the controlled access requirements of the Regulations Pertaining to Solid Waste Disposal Sites and Facilities and with the USR-481:81 :27 during this time of voluntary closure. Northern Colorado Brine does not feel that three working days was adequate notice to provide access for sampling at a temporarily closed facility. There is no intent on the part of NCB to deny or limit access to the site. NCB was simply unable to provide access on the requested date due to the short notice provided by Weld County. Access as required by USR 481:81:27 will be available on March 9, 1993. Please advise NCB as to what time will be convenient for you. Sincerely, • Patty Deplazes cc Roger Doak, Colorado Department of Health Keith Schuett, Weld County Department of Planning Mike Cervi, Northern Colorado Brine 940056 EASTERN PLAINS ENVIRONMENTAL SERVICE P.O. BOX 142 PIERCE, COLORADO 80650 1-897-2439 or 454-3452 March 1 , 1993 Trevor Jiricek, Solid and Hazardous Waste Specialist Weld County Health Department, Environmental Protection Service 1517 16th Avenue Court Greeley, CO 80631 Dear Mr. Jiricek, On behalf of Northern Colorado Brine, please consider the following response to a February 12, 1993 memo you sent to Keith Schuett, Weld County Department of Planning Services, regarding the Northern Colorado Brine Design and Operation Plan. In the subject memo, you stated that the facility is in violation of Section 6.7.5 of the Regulations Pertaining to Solid Waste Disposal Sites and Facilities. Please note that Northern Colorado Brine is regulated under Section 2, Minimum Standards, of the Regulations, not Section 6 as you stated in the memo. Sincerely, Patty Deplazes cc Roger Doak, Colorado Department of Health Keith Schuett, Weld County Planning Mike Cervi, Northern Colorado Brine 940056 A(Cs mEmORAnDUm Wine. f(,, C !� -c-(_ a (A��w: / C ToI l 'e \ \ JG�I�- ` � y DatsZ � Z.b rL - COLORADO n From tt 4 I 1.:L5.Ft4 LA C(.4 Subject: a. C. f i u„_c___, (j,-cpjZ U O c.c,- Gam( J2(b r l a.S5 L-12_11 IAA-Q-.> SreAL-C( (--. c1L.S---- c% C.C3-' 1 4 cLzS Iq. -'ec1- cdc J ,ok { oCV l_cr eke FZ_-_nl CO (�4 i_ vm-t-it-co Z (ZZi 9 i . ZQ \& clot--- ct u oLai- 6---(O ).. r- ( . tb ? Luy5Jjk nnwww. 940056 COLORADO DEPARTMENT OF HEALTI. AIR- POLLUTION CONTROL DIVISION QmFZ ANALYTICAL REPORT OF VISIBLE EMISSION VIOLATION COMPANY ,t otermi,Ai /CO I.DYc n -, egQc DATE �/ 1I ADDRESS OF SOURCE it, . 0 0 WC: ,cy City Street County AOCR STACK NAME / BACKGROUND SKY CONDITION Ai/41/7— RELATIVE HUMIDITY -iiin % PSYC. WEATHER BUREAU ‘ T AIR TEMP,(1oF 4 / WIND SPEED `t- f1(A . WIND DIRECTION(From) G. A 1 c PLUME CHARACTERISTICS(Color,me.) STACK HEIGHT Feet OBSERVERS LOCATION / /Ud .;set of StaFk WET PLUME or DRY PLUME: (If WET,admits the breakpoint distance from the stack) 4$ irfr CLOCK TIME 0 15 30 45 SKETCH: Include 1) Wind Direction; 2) Sun Position: 3) Observer Position: If Tr f 0 1 - 41 Approximate Location of stack: 5)North Arrow. 01 — lO If more than one stack is located at the plant site �'• .7 02 M specifically identify the stack being read. Include remarks. /O: OZ 03 m— /6: 11 04 n— AD 05 42:24- NM— 9 e ' i /0 : 3:1,1-- as -.— �D 09 wC rz,5L( 09 ' 11 12 13 \°l `- 14 s Q1" 15 'eh` 16 O 17 IJ* 18 i {" 19 1 p ,I 20 , i 21 1 wCg- 52- 22 23 24 25 1 26 27 28 29 CI:OBSERVER: ' 1 IkS ", SIGNATURES: Duplicate of this Analytical Report Given To a ---) PERSONS P SE DUR( THE EVALUATION: f Name: --7-4 (1° —4 Uo d e•-- V I el=-G• T\ Name: , Y C�0 '� I Title: Scot4 9W4c e,�AS7z 5Plc' Title: J`-' Date. !J Time / C • [ 7 // 940056 Signature. 2 A ,/ 1� ff .>P^. 55 5.'S.';01 "�' ��J . mEmoRAnDum Keith Schuett, W.C. Planning Date February 24, 1993 To / COLORADO Trevor Jiricek, W.C. Environmental Protection \-) From r Northern Colorado Brine, new pond construction Subject: As you know, the new evaporation pond at Northern Colorado Brine has been in operation since January 14, 1993. This pond obviously has been constructed so that the depth of waste in the pond will exceed 2 1/2 feet and that the pond is greater than 5 feet deep. According to Section 4.7.7, page 17, of the approved Design & Operation Plan for N.C.B. "each pond will contain a maximum of two and one half (2 1/2) feet of liquid. Each pond will be five (5) feet deep." This would also render the installed depth gauge useless. I am bringing the above mentioned deviations to your attention because they may require amendments to the C.D. and the U.S.R. If you have any further questions, please contact me at 353-0635. /tj-385 -385 cc: Roger Doak, Colorado Department of Health 1\1 FEB 2 5 1993 ' I I 940056 EASTERN PLAINS ENVIRONMENTAL SERVICE P.O. BOX 142 PIERCE, COLORADO 80650 1-897-2439 or 454-3452 'February 23, 1993 Mr. John Milligan, Air Quality Specialist Environmental Protection Services Weld County Department of Health 1517 16th Avenue Court • Greeley, CO 80631 Dear Mr. Milligan, RE: ODOR VIOLATION On behalf of Northern Colorado Brine, please consider the following. Northern Colorado Brine has recently completed repairs of the aeration systems. Those systems have been running continuously in an attempt to raise the dissolved oxygen levels of the evaporation ponds to effect a long term favorable response to the odor problems. Northern Colorado Brine feels that the recent odor problems are due, at least in part, to the resumption of aeration and that the odors will diminish as the aerobic state of the ponds is regained. Please be assured that NCB is making every effort to address the odor problems at the site and will continue in their efforts to solve those problems. NCB continues to search for appropriate odor mitigation procedures and has requested assistance from Colorado Department of Health, Air Quality Control Division. In addition, I have successfully completed the CDH Odor Certification process and NCB has ordered a scentometer so that I may assist them in monitoring odors at the site. Please notify me of any odor complaints at 454-3452 or 897-2439. Thank you for your consideration in this matter and do not hesitate to call if I can be of further assistance. Sincerely, Patty Deplazes cc Greg Hobbs, Hobbs Troutt and Raley, PC Keith Schuett, Weld County Department of Planning Mike Cervi, Northern Colorado Brine 940056 mEmoRnn m II W�`D John Pickle, Direct February 11, 19� FEB 1 To / Date `,� COLORADO Trevor Jiricek, Solid d Hazardous Waste Specialist . From Subject: Northern Colo Brine proposal to accept Monfort hide waste This memo is in regard to the Eastern Plains Environmental Service proposal of February 5, 1993, in which Northern Colorado Brine requested to receive brine water from the Monfort hide washing facility. Provided that the proposed waste had been documented to meet the concentrations outlined in the February 5, 1993 proposal letter, the waste could be considered chemically compatible for this facility. It may, however, be a substantial deviation from Operation Standard #1 of U.S.R.540-83:3 which states the facility "shall be an oil and gas brine water disposal. . . .no non-hazardous industrial waste shall be allowed. . . ." I would interpret the proposed waste to be a non- hazardous industrial waste. If it were determined that accepting this waste is not a substantial change from Operation Standard 1F 1, we would require that samples be submitted to two independent laboratories initially for analysis, followed by monthly or, at least quarterly sampling to insure the character of the waste has not changed substantially. Given the recent series of violations at this facility, including accepting unapproved waste and exceeding the maximum odor threshold, it would be prudent to consider this waste stream very carefully. tj/285 `7 //S3 940056 EASTERN PLAINS ENVIRONMENTAL SERVICE P.O. BOX 142 PIERCE, COLORADO 80640 1-897-2439 or 454-3452 February 11 , 1993 \YL ?dl l\r, FEB ' 1993 �� Trevor Jiricek --' Solid and Hazardous Waste Specialist Weld County Department of Health 1517 16th Avenue Court Greeley, CO 80631 Dear Mr. Jiricek, RE: CERTIFIED LETTERS NO: P423 630 397, NO: P186 978 278 Northern Colorado Brine has received your letters dated January 11 , and February 3, 1993. Regarding your December 10, 1992 and February 2, 1993 inspections of Northern Colorado Brine, please consider the following response: 1 . NCB has installed a depth gauge in pond C. Gauges have been prepared and are on site for all ponds, and will be installed as soon as weather permits. These depth gauges will clearly indicate the depth of brine as required in Operation Standard 7-H. 2. NCB is presently pumping into Pond E to lower all freeboards to acceptable levels. As stated in section 4.1-1 of the original application materials for USR - 540, 30" of freeboard is required. Compliance can easily be measured by subtracting 30" from the total depth of the pond. For ponds A, B, C, and 0, freeboard compliance is 30" depth of brine. 3. NCB has responded to Certified Letter P 186 978 272, regarding the accepting of Monfort brine. NCB ceased acceptance of Monfort brine upon notification from WCHD. Please note, however, that this waste was accepted based on a verbal approval previously given by WCHD personnel. 4. NCB is making every effort to adequately address and correct all odor problems at the site. Aeration of the ponds is being increased and chemical additives are being considered. 940056 _ _l 5. The berms have not been raised. The berms and roads have been maintained and leveled. The edge of the roads were ridged up in an attempt to channel precipitation off the dikes in such a way as to reduce rill washing: The USR states that water level in the ponds, A,B,C and D can reach a maximum depth of 30". That compliance point is unchanged. 6. The operator on site has been given additional training in the operation of Northern Colorado Brine. 7. Records are being complied and copied and will be on site for inspection. Documents have been prepared to simplify required daily and monthly record keeping at NCB. Northern Colorado Brine continues in its efforts to bring the facility fully into compliance with all state and local regulations. Please call if you have additional questions or concerns. Sincerely, / < s/ 4;. «z Patty Deplazes / PD:sl cc: Keith Schuett, Weld County Department of Planning Services Roger Doak, Solid Waste Section, HWWMD, Colorado Department of Health Mike Cervi, Northern Colorado Brine 940056 EASTERN PLAINS ENVIRONMENTAL SERVICE P.O. BOX 142 PIERCE, COLORADO 1-897-2439 or 454-3452 February 10, 1993 Mr. Roger Doak, Geologist Solid Waste Section, Hazardous Waste and Waste Management Division Colorado Department of Health 4300 Cherry Creek Drive South Denver, CO 80222-1530 Re: Certefied Letter # 860 418 649 Dear Mr. Doak, In response to the above referenced letter: Northern Colorado Brine ceased accepting the unauthorized Monfort brine immediately upon notification by the Weld County Health Department that this was not an approved waste stream. Please note, however, that the previous Director of the Weld County Health Department was fully aware of the disposal of Monfort brine at NCB and had given his approval for that disposal. However, that verbal approval was not verified in writing. Further, please consider that NCB made no effort to conceal or deny the acceptance of this waste stream, and that NCB acted in good faith in accepting this waste as NCB believed it had been approved. I have enclosed a copy of Northern Colorado Brine's response to Weld County Health Department regarding this waste stream. Please call if you have any additional questions or concerns regarding this matter. Sincerely, Patty Dep az cc: Trevor Jiricek, Weld County Health Department Keith Schuett, Weld County Department of Planning Weld County Board of Commissioners Mike Cervi, Northern Colorado Brine LiIuj,Jaia�\V/c121 II FEB 1 1 1993 940056 T February 2, 1993 • • Eastern Plains Environmental Service P.O. Box 142 Pierce, CO 80650 • • Mr. Trevor Jiricek • Solid and Hazardous Waste Specialist Environmental Protection Services Weld County Department of Health 1517 16th Avenue Court Greeley, CO 80631 Dear Mr. Jiricek, REF: NORTHERN COLORADO BRINE CERTIFIED LETTER NUMBER M86978272 In response to your letter dated January 25, 1993 and received by Northern Colorado Brine January 29, 1993, NCB has ceased accepting hide washing waste water from Monfort. This waste was accepted under the belief by NCB that approval had previously been granted by WCHD personnel. Please consider that no attempt was made by NCB to deny or disguise acceptance of this waste, as we believed it had been approved as an alternate waste stream. Again, we have ceased taking in this waste and regret the misunderstanding that caused us to accept this product. Please call if you have further questions or concerns regarding this matter. I may be reached at 897-2439 or 454-3452. Sincerely, Patty D plaz CC:. Kieth Schuett, Weld County Planning Mike Cervi, Northern Colorado Brine 940056 41.6 EASTERN PLAINS ENVIRONMENTAL SERVICE P.O. BOX 142 PIERCE, COLORADO 1-897-2439 or 454-3452 February 5 , 1992 ��w� X11t- ri21 Keith Schuett I�� FEB 1 7. 1993 Department of Planning Services Weld County Administrative Offices 1400 North 17th Avenue Greeley , CO 80631 Dear Mr . Schuett , Northern Colorado Brine Facility hereby requests approval to receive brine water from the Monfort hide washing facility . The volume of waste is estimated to be 6000-10000 gallons per day . The Environmental Protection Division of the Weld County Health Department has previously indicated that the sodium chloride concentration of the Monfort brine is compatible with the waste stream currently approved for disposal at NCB , but has expressed concern about the high biological oxygen demand (BOD) and total suspended solids (TSS) of the Monfort brine . Monfort is presently installing a dissolved air flotation and filtering system that will remove virtually all of the BOD and TSS from the brine waste . An identical system is in use at ConAgra 's Garden City, -Kansas facility . This system, which is expected to be on line in two weeks , will reduce both the BOD and the TSS to less than lOppm. After treatment through the system, the brine is expected to meet the following parameters : BOD lOppm TSS lOppm TDS 280 , 000-320 , 000ppm (28-32% NaCl) Northern Colorado believes that with the removal of the BOD and TSS , the Monfort brine waste is not significantly different from the currently approved waste stream, and that approval to accept the treated waste is not a material change to USR-540. Therefore , Northern Colorado Brine requests that this change be granted by staff approval of the Weld County Department of Planning Services . As previously stated , the new treatment system at Monfort is expected to be on line in approximately two weeks . At that time , test results to document the reduction in BOD and TSS will be available for your review . Please call if you have any questions regarding this matter . Sincerely , eglat1 Patty De azesritir— i FEB cc : Trevor Jiricek , Weld County Health Department Mike Cervi , Northern Colorado Brine 94 hr„i�6 - — r�VJ EASTERN PLAINS ENVIRONMENTAL SERVICE P.O. BOX 142 PIERCE, COLORADO 1-897-2439 or 454-3452 February 5 , 1992 Keith Schuett Department of Planning Services Weld County Administrative Offices 1400 North 17th Avenue Greeley , CO 80631 Dear Mr . Schuett , Northern Colorado Brine Facility hereby requests approval to receive brine water from the Monfort hide washing facility . The volume of waste is estimated to be 6000-10000 gallons per day . The Environmental Protection Division of the Weld County Health Department has previously indicated that the sodium chloride concentration of the Monfort brine is compatible with the waste stream currently approved for disposal at NCB , but has expressed concern about the high biological oxygen demand (BOD) and total suspended solids (TSS) of the Monfort brine . Monfort is presently installing a dissolved air flotation and filtering system that will remove virtually all of the BOD and TSS from the brine waste . An identical system is in use at ConAgra 's Garden City, -Kansas facility . This system, which is expected to be on line in two weeks , will reduce both the BOD and the TSS to less than lOppm. After treatment through the system, the brine is expected to meet the following parameters : BOD lOppm TSS lOppm TDS 280 , 000-320 , 000ppm ( 28-32% NaCl) Northern Colorado believes that with the removal of the BOD and TSS , the Monfort brine waste is not significantly different from the currently approved waste stream, and that approval to accept the treated waste is not a material change to USR-540. Therefore , Northern Colorado Brine requests that this change be granted by staff approval of the Weld County Department of Planning Services . As previously stated , the new treatment system at Monfort is expected to be on line in approximately two weeks . At that time , test results to document the reduction in BOD and TSS will be available for your review. Please call if you have any questions regarding this matter . Sincerely , �fr Yv 4fii?L� cn� Patty De azes �J � FEB 7.1 cc : Trevor Jiricek , Weld County Health Department FEB Mike Cervi , Northern Colorado Brine ....,- 94 MSG FEB- 5-93 FR: 9:34 WELD..CO HEALTH DEPT FAX NO. 30335frS6 P. 01• Weld County Health Department 1517 1618 AVENUE COURT GREELEY, COLORADO 80631 V enrllrasTRATION (303) 353-0586 FEB 0 5 1993 ENVIRONMENTAL PROTECTION SERVICES (303) 353-06 COMMUNITY REALM SERVICES (303) 353-0639 Q FAX (303) 356-4966 • DATE 2 S - / /��/' /Y . - l TO C„' \I . L' (,,_4,;fi[ TELEPHONE • evsnNEss Plan "1Lam) 74 • TAX # SENDER \t h n TELEPHONE a ' G MESSAGE _ c-1/4Th • C *********wril*sn*******************wn*t**********r***** ****ns*****sA A£A**e* This transmittal consists of pages, including this cover page. If you do not receive all of the copies, please contact the sender at the above telephone number. Thank you. FEB 5 '93 09 32 3033564966 PAGE.001 940056 FEB- 5-93 FRI 9:35 WE( CO HEALTH DEPT FAX NO. 3033( `166 P. 02 FEE- 5-93 FRI 10:15 P.04 STATE OF COLORADO COLORADO DEPARTMENT OF HEALTH 4,c>> ntm�the patpk&&Coket the hewhhandenvironment r` gr.tl6 Creek O.S. CCoolonka6Ync6 Bum ••\- }.Y=� Omer, ndo 60221-t 530 1210 E i77hAwws •`. - Phone 003)691.7000 Newer,Cgkndo D012c4776 0037 691.4200 Itof Pinar February 2, 1993 CERTIFIED # P 860 418 649 Flab A. tan,MD.MPH Mitre Ccrvi P,O. Box 300397 Denver, Colorado 80203 RE: Northern Colorado Brine Disposal Disposal of an Unapproved Waste ' Weld County, Colorado Dear Mr. Cervi: The Solid Waste Section of the Hazardous Materials and Waste Management Division of the Colorado Department of Health (the Division) was notified by Weld County Health Department that Northern Colorado Brine facility has accepted two unauthorized loads of waste water from Monfort, Inc. on January 21, 1993. Acoprding to Weld County officials, the waste water is produced as the result of washing cow hides. The acceptance of the aforementioned waste is in violation of the approved Design and Operations Plan(D&O) for this facility. Page 1 of the D&O plan states this facility "is an oil and gas well production water disposal site." The acceptance of this unapproved waste stream constitutes a violation of section 6.7.2 of the states's solid waste regulations. Section 6.7.2 states "Disposal of any waste streams significantly different from those originally approved shall constitute a substantial change In operation." The Division defines a substantial change in operations as"...the addition of a category of wastes or other waste handling processes that have not been previously reviewed and accepted as complying with these regulations..." Section 30-20-113(1)of the Solid Wastes Disposal Sites and Facilities Act Title 30,Article 20, Part 1, (the Act) empowers the board of county commissioners where the violation occurred to take enforcement action. Section 30-20-114 of the Act provides that a violation • of the Act is a misdemeanor and is punishable by a fine of not more than two thousand dollars, or imprisonment in the county jail for not more thaai thirty days or both fine and imprisonment. Furthermore, each day of violation shall be deemed a separate offense. Section 30-20-112 of the Act authorizes the governing body having jurisdiction(Weld County Commissioners)to temporarily suspend or revoke a certificate of designation that has been granted by the governing body for failure of a site and facility to comply with all applicable laws,resolutions,regulations and ordinances, If the Weld County Commissioners decide to pursue any option of the above mentioned A4 the Division would provide them with technical support. \vr�\ lFEB 5 1993 FEB 5 '93 09;33 3033564966 PRGE.002 940056 a c \„, i.JO 66 P. 03 FEB- 5-93 FR1 10,18 P.06 Mike Cat?! Northern Colorado Brine Disposal February 2, 1993 Page 2/2 The Division requests a written response to this noncompliance issue within(10) ten days of receipt of this letter_ If you have any questions regarding this matter, please contact me at (303) 692-3437. Sincerely, ,1& Roger D iak Geologist Solid Waste Section Hazardous Materials and Waste Management Division cc 7. Pickle, Weld County Health Weld County Commissioners P. feplazes File: SW/WLD/NOR FEB 5 '93 0933 3033564966 PAGE.003 940056 j1 I DEPARTMENT OF PLANNING SERVICES PHONE(303)353.3845, EXT.3540 WI t �• WELD COUNTY ADMINISTRATIVE OFFICES 1400 N. 17TH AVENUE GREELEY, COLORADO 80631 COLORADO February 3, 1993 Northern Colorado Brine c/o Mike Cervi P.O. Box 5714 Denver, CO 80217 Subject: ZCH-97 Dear Mr. Cervi: An on-site inspection of your property was conducted on January 29, 1993, to determine if the Conditions of Approval and the Development Standards placed on your property at the time USR-540 was approved by the Board of County Commissioners are in compliance. The inspection revealed violations of Development Standards # 1, 7-H, 7-J, 15, and 16. A copy of these items from the approved resolution are enclosed. The Use by Special Review area must be brought into compliance with the Conditions of Approval and the Development Standards within 30 days from the date of this letter. Noncompliance will result in our office scheduling a Probable Cause Hearing before the Board of County Commissioners. If the Board determines there is sufficient probable cause to warrant further action, a Show Cause Hearing will be scheduled to consider revocation of the Use by Special Review permit. If you have information that may clear up this matter, please call or write. Sincerely, Current Planner pc: Northern Colorado Brine Patricia Deplazes 10600 Weld County Road 54 Eastern Plains Environmental Services Milliken, CO 80543 P.O. Box 142 Pierce, CO 80650 enclosures 940056 INSPECTION REPORT NAME: Northern Colorado Brine, Mike Cervi P.O. Box 5714 Denver, Co 80217 Northern Colorado Brine 10600 Weld County Road 54 Milliken, Colorado Eastern Plains Environmental Service c/o Patricia Deplazes P.O. Box 142 Pierce, CO 80650 LEGAL DESCRIPTION OF THE PROPERTY: Part of the NE4, Section 26 and part of the NW4, Section 25, all in Township 5 north, Range 67 west of the 6th P.M. , Weld County, Colorado. CASE NUMBER: USR-540 ZCH-97 DATE: January 29, 1993 The property was inspected after reviewing the approved Development Standards. Trevor Jiricek, of the Weld County Health Department assisted on the inspection. A video of the property was filmed. During this inspection it was determined that the property is not in compliance with Operation Standards 1, 7-H, 7-J, 15, and 16. Operation Standard Number 1 states as follows: The use shall be an oil and gas brine water disposal and oil recovery facility as described in the submitted application materials. No hazardous wastes or nonhazardous industrial waste shall be allowed at the site. The facility shall be designed, constructed, and operated to comply with the Colorado Department of Health Solid Wastes Disposal Sites and Facilities Act, Title 30-20, Part 1, CRS 1973, as amended. The use of the property has not been limited to oil and gas brine water disposal and oil recovery facility as described in the submitted application materials. - Nonhazardous waste from Monfort and other facilities have been disposed of at this site. The height of the approved pond berms have been raised and the 3 foot free board has been exceeded. Appropriate records are not being maintained on site. - Contaminated soils are located on the property and must be properly disposed of. 940056 INSPECTION REPORT Northern Colorado Brine, Mike Cervi Page 2 Emissions permit 90WE161 has not been amended to reflect the increased volume of waste being processed. Operation Standard Number 7-H states : A gauge height indicator shall be installed in the evaporation ponds. The gauge must clearly indicate the depth of brine water waste. A gauge height indicator is not located on all ponds. The gauge height monitor must clearly indicate the depth of the brine water waste, not the height of the brine water in relation to the height of the berm. Operation Standard number 7-J states: An aeration system shall be installed and operated on the four evaporative ponds. In the event of an odor problem emanating from the ponds, an odor abatement program shall be instituted. The aeration system has been installed on four ponds but has not been installed on the newly constructed ponds. The aeration system is not being operated. Odors are a problem and an odor abatement program has not been instituted. Operation Standard Number 15 states: The Use by Special Review shall be limited to the plans shown hereon and governed by the Standards as stated above and all applicable Weld County Regulations. Any material deviations from the plans and/or Standards as shown or stated above shall require the approval of an amendment of the Permit by the Weld County Planning Commission and the Board of County Commissioners before such changes from the plans and/or Standards are permitted. Any other changes shall be filed in the office of the Department of Planning Services. The Use by Special Review site has not been limited to the plans shown and is not in compliance with all applicable Weld County Regulations. The Use by Special Review site is not in compliance with all Development Standards and all applicable Weld County Regulations and amendments to the approved plans have not been applied for. Operation Standard Number 16 states: The property owner and/or operator of this operation shall be responsible for complying with all of the above stated Standards. Noncompliance with any of the above stated Standards may be reason for revocation of the Permit by the Board of County Commissioners. The property owner and/or operator of this operation has not maintained compliance with all operation standards. 940056 • DEPARTMENT OF HEALTH ict•p 1517- 16 AVENUE COURT GREELEY, COLORADO 80631 O ADMINISTRATION (303) 353-0586 HEALTHH PRO PROTECTION (303)353-0635 COMMUNITY HEALTH (303)353.0639 COLORADO February 3, 1993 Certified Letter No. : P 186 978 278 Mike Cervi Roggen Disposal, Incorporated P.O. Box 300397 Denver, Colorado 80203 Dear Mr. Cervi: On February 2, 1993, a representative of the Environmental Protection Division of the Weld County Health Department inspected Northern Colorado Brine, located at Weld County Road 54, Milliken, in Weld County, Colorado. The purpose of the inspection was to inspect and assess the facilities compliance with the "Regulations Pertaining to Solid Waste Disposal Sites and Facilities" (The Regulations) as promulgated by the Solid Waste Disposal Sites and Facilities Act, Title 30, Article 20, Part 1, C.R.S. , as amended, and the Operational Standards as set forth in U.S.R.-540. On the date of February 2, 1993, field inspection, the following observations were made: 1. The berms/dikes appear to have been heightened around all evaporation ponds. This issue is currentkr being investigated by the Weld County Planning Department. 2. Accurate depth gauges were not present on evaporation ponds. Depth gauges must be available on all ponds to insure adequate freeboard levels are maintained. 3. The facility was cited (certified letter dated January 25, 1993) for accepting a waste stream which is unapproved. 4. The facility was cited for exceeding the allowable odor threshold for a third time (certified letter dated January 26, 1993) . 5. Freeboard levels were estimated to exceed the approved three (3) foot level on the two northwestern most ponds. Due to the lack of depth gauges, exact levels could not be determined. In addition, daily records of freeboard levels must be available for review. b-u vi FEB 0 5 1993 U 940056 6. Operating records are not readily available for review. These include a copy of the Certificate of Designation, approved design and operations plan, site safety plan, operational variances, Use by Special Review Permit, water monitoring data, etc. Observation of the berms/dikes on this facility suggest that they may have been raised in elevation. Operation Standard #15 states "the Use by Special Review shall be limited to the plans shown hereon and governed by the standards as stated and all applicable Weld County Regulations. Any material deviations from the plans and/or standards as shown or stated above shall require the approval of an amendment of the permit. . . ." In addition, if it is determined that the berms/dikes have been raised it also would violate Section 30-20-103 of the "Solid Waste Disposal Sites and Facilities Act". This facility has yet to employ accurate depth gauges on the evaporation ponds as required. According to Operation Standard #7, H, set forth in U.S.R.- 540:83:3, "A gauge height indicator shall be installed in each pond. The gauge must clearly indicate the depth of brine water waste." In addition, these indicators are required in order to assure that a minimum of three (3) feet of freeboard is maintained on each pond. The facility was recently cited for accepting an unapproved waste stream and exceeding the allowable odor threshold (see attached) . This facility does not currently maintain adequate records. Operation Standard #9, states "all operating records will be made available to the State Health and County Health Department upon request. Operating records shall be maintained as described " Also, Section 2.2.13, of The Regulations which states "all operating records shall be made available to the County Board of Commissioners and the Department upon their request." The violations outlined above constitute noncompliance with the "Regulations Pertaining to Solid Waste Disposal Sites and Facilities", and the Operation Standards in U.S.R.-540:83:3. This facility must respond to this violation notice within thirty (30) days. Failure to respond to this notice will result in further action in accordance with Section 2.3.4. of The Regulations. If you have any questions, please contact Trevor Jiricek at (303) 353-0635. Sincerely, ' c Trevor Jirice Solid and Hazardous Waste Specialist tj/218 cc: Roger Doak, Colorado Department of Health Keith Schuett, Weld County Planning Department Lee Morrison, Assistant Weld County Attorney Patty Deplazes, Eastern Plains Environmental Service Bill Webster, Weld County Commissioner 9t15,C_ d OEPARTMEiVT OF HEALTH 1517. 18 AVENUE COURT. ICREtE?, COLORADO 80631 0 ADMINISTRATION PROTECTION TECTION (303)353-0335 HEALTH (303)333-0835 COMMUNITY HEALTH(303)353-0839 COLORADO January 23, 1993 Mike Cervi Northern Colorado Brine. Inc. P.O. Box 300397 Denver, Colorado 80203 • Certified Letter No.: P 186 978 272 Dear Mr. Cervi.: On January 22, 1993, a representative of the Environmental Protection Division of the Weld County Health Department inspected Northern Colorado Brine. Inc. located at 10600 Weld County Road 54, Milliken, Colorado, Weld County. The purpose of the inspection was to review waste volume delivery invoices accepted the date of January 21. 1993 in order to assess the facilities compliance with the "Solid Waste Disposal Sites and Facilities Act" (the Act) . Title 30, Article 20, Part 1, C.R.S. , as amended, the "Regulations Pertaining to Solid Waste Disposal Sites and Facilities", and the Operation Standards as set forth in USR- 540:83:3. In reviewing the available documents. it was observed that two unauthorized loads of waste were accepted on the date of January 21, 1993. Invoices 37083 and 37119 indicate that waste water from Monfort was accepted at the facility and introduced into the impoundments on site. According to the operator on site, this water is produced as the result of washing cow hides. The acceptance of the above mentioned waste is in violation of the Design and Operation plan. October, 1983 (D&O plan) approved by the Colorado Department of Health (see attached letter. October 28, 1983) as required by Section 30-20-103 of the Act. Page 1 of the D&0 plan states this facility "is an oil and gas well production water disposal site." In addition, the acceptance of this waste constitutes a violation' of the operation standards set forth in USN-540:83:3. Operation standard #1 states: The use shall be an oil and gas brine water disposal and oil recovery facility as described in the submitted application materials. No hazardous wastes or non-hazardous industrial waste shall be allowed at the site. The facility shall be designed, constructed and operated to comply with the Colorado Department of Health Solid Wastes Disposal Sites and Facilities Act, Title 30-20, Part 1. CRS 1973, as amended. 940056 Mike Carol Nortaern Colorado 3rine, Inc. Certified Latter No.: P 186 978 272 January 25. _993 Page 2 Additionally operation standard /115 states in part "the Use by Special Review shall be limited to the plans shown hereon and governed by the standards as stated. .. .any material deviations from the plans and/or standards as shown or stated shall require the approval of an amendment of the Permit by the Weld County Planning Commission and the Board of County Coendssionen before such changes from the plans and/or standards are permitted.... This facility must immediately cease accepting wastes of this nature upon receipt of this notice. The violations outlined above constitute noncompliance with the Solid. Waste Disposal Sites and Far+7,ties Act, and USR-540:83:3. In addition. this facility must provide a written response to this notice within (5) days of receipt, your response will be considered in a determination as to whether further proceedings will be held in accordance with Section 30-20-113, C.R.S. , and USR-540:83:3. If you have any questions, please contact Trevor Jiricek at (303) 353-0635. Sincerely, _ Trevor Jirs �`.J S. Pickle.-M.S� Solid and Hazardous Waste Specialist rector Environmental Protection Services /tj-161 cc: Wes Potter, Monfort. Inc. Roger Doak, Colorado Department of Health Victor Sainz, Colorado Department of Health Bill Webster, Weld County Commissioner Chuck Curliffa, Weld County Planning Department Randolph L. Gordon, M.D. , M.P.H. , Director, Weld County Health Department 940056 herd ‘It DEPARTMENT OF HEALTH 1517•18 AVENUE COURT GREELEY.COLORADO 80631 !Inge AD H PROTECTION(303)353-0635 HEALTH PROTECTION(303)353-0635 COMMUNITY HEALTH(303)353-0639 COLORADO January 26, 1993 Certified Letter No: P 186 978 271 Legal Action No. : 93-008 Mike Cervi Northern Colorado Brine P.O. Box 5714 Denver, Colorado 80217 Dear Mr. Cervi: This letter constitutes a formal "Notice of Violation" as a follow up to the January 21, 1993, investigation of odors from the evaporation ponds of Northern Colorado Brine Located at 10600 WCR 54, Weld County, Colorado, conducted by John Milligan, a duly delegated representative of the Weld County Health Department. This Notice of Violation is being issued pursuant to the Division's authority under Section 25-7-115(2) , C.R.S. (1989 & 1992 Supp.) During the Division's October 15, 1992, investigation, it was determined by using the Barnebey-Cheney scentometer that odor emissions from your evaporation ponds were in excess of the limits allowed by the Colorado Air Quality Control Commission's Regulation No. 2 (copy attached) . A copy of the attached report was left under the door of the caretaker's residence and was acknowledged by Mike Cervi by telephone the following morning. Odor intensity between 6:00 p.m. and 7:30 p.m. on January 21, 1993, was detected at 31:1 dilutions to threshold (D/T) . Regulation 2, Section A.2. limits odor emissions to 15:1 D/T for "other" sources. Section 25-7-122(1) (b) provides that any person who violates any applicable emission control regulation shall be subject to a civil penalty of not more than $15,000.00 per day for each day of violation. In addition, Section 25-7-115 (5) requires the Division to determine whether a noncompliance penalty is applicable. If a noncompliance penalty is found to be applicable, such penalty generally must be assessed for any period of violation from the date on which the emission source is brought to compliance. The amount of noncompliance penalty is calculated in accordance with the provision of Section 25-7-115(5) (b) , C.R.S. 940056 Mike Cervi Northern Colorado Brine Certified Letter No: P 186 978 271 Legal Action No. : 93-008 January 26, 1993 Page 2 In accordance with requirements of Section 25-7-115(3) , a conference regarding the violations described above will be scheduled at a future date. This conference will provide Northern Colorado Brine an opportunity to submit data. views and arguments concerning the above violation, and whether assessment of a civil penalty and noncompliance penalty is required. The Division may provide further opportunity for Northern Colorado Brine to respond after the conference. if circumstances warrant. As a result of the conference a determination will be made as to whether a Compliance Order will be issued and whether a civil penalty and noncompliance penalty must be assessed. You will be informed about the hearing date in future correspondence. - Failure to attend the conference will result in the issuance of a Compliance Order and possible assessment of penalties against Northern Colorado Brine. • If you have any questions concerning the conference or other matters prior to the scheduled conference, please contact this office. The conference is an informal proceeding. You may, however, have legal counsel attend with you. Sincerely, e John Milligan John S. Pickle, M.S.E.H. Air Quality Specialist Director Environmental Protection Services cc: Harry Collier, A.P.L.D. , CDH Tony Trumbly, Assistant Attorney General Air Quality Control Commission Bill Webster, Weld County Board of Commissioners Lee Morrison, Assistant County Attorney Randolph Gordon, M.D. , Director, Weld County Health Department JM/jg-157 940056 mEmORAnDUm Vin Keith Schuett R Weld County Planning February 12, 1993 v To Date // e. COLORADO Trevor Jiricek, Solid and Hazardous Waste Specialis't ‘y, From } Northern Colorado Brine Design Operation Plan Subject: A review of the approved Design and Operation Plan (October 1983) for the Northern Colorado Brine facility revealed that the facility is not operating in compliance with the approved operational plan. According to Section 4.6.4, page 15, in regard to the dump and skim tanks on site states "the tanks and piping will be designed so that the water will have a minimum retention time through the tanks of 24 hours. The oil will rise to the top of the skim tanks and will flow by gravity to the oil treatment unit. The difference in specific gravities of the oil and water will allow the oil to rise to a higher elevation in the tanks and flow out the oil piping." The 1992, volume data supplied to this Division from Northern Colorado Brine indicates that the facility accepted 155,205 and 117,869 barrels in November and December. This translates to an approximate 8 hour retention time in November and an approximate 10 hour retention time in December. This constitutes a violation of 30-20-103 C.R.S. This would also violate Section 6.7.5 of the "Regulations Pertaining to Solid Waste Disposal Sites and Facilities". tj/293 cc: Roger Doak, Colorado Department of Health (*r it.qJI 1�l/ j� 1 940056 1 ‘,8t(?, mEmoRAnDum To John Pickle. Dirertnr Dote February 9 1001 COLORADO From Judy Sctynidt Supervi cnr Dil(tje' /" r Gf01�C v (/ Subject: iahnra tory Results On Monday, January 25, 1992, Wes Potter. Vice President, Environmental Operations of Monforts called requesting laboratory testing on wastewater. The source of this sample was from their Hide Plant rinsewater. The tests requested included pH, BOD, TDS, TSS, oil and grease, sodium and chloride. Because of the laboratory workload and the BOD (five-day incubation) , the samples were scheduled to be brought in by Monfort staff on Wednesday, January 27, 1992. The results are enclosed. The facility was requesting permission to dispose of this waste at the brinewater site, Northern Colorado Brine. This is a highly concentrated solution (28%) of sodium chloride which would appear to be compatible with brinewater at a brinewater facility, however due to the extremely high concentration of BOD (17,000 mg/L) , the staff does not recommend disposal of this waste at this facility, due to the probable existence of potential odor problems. Brinewater will usually run a BOD of between 100- 200 mg/L. This would be a significant burden at the already oxygen-taxed brinewater facility. Also, there is a significantly high level of suspended solids (11,000 mg/L) , in this wastewater which would further preclude it for disposal at Northern Colorado Brine. cc: Keith Scheutt, Weld County Planning Roger Doak, Colorado Department of Health `J \)f FEB 0 3 1993 940056 February 2, 1993 Eastern Plains Environmental Service P.O. Box 142 Pierce, CO 80650 Mr. Trevor Jiricek Solid and Hazardous Waste Specialist Environmental Protection Services Weld County Department of Health 1517 16th Avenue Court Greeley, CO 80631 Dear Mr. Jiricek, REF: NORTHERN COLORADO BRINE CERTIFIED LETTER NUMBER P186978272 In response to your letter dated January 25, 1993 and received by Northern Colorado Brine January 29, 1993, NCB has ceased accepting hide washing waste water from Monfort. This waste was accepted under the belief by NCB that approval had previously been granted by WCHD personnel. Please consider that no attempt was made by NCB to deny or disguise acceptance of this waste, as we believed it had been approved as an alternate waste stream. Again, we have ceased taking in this waste and regret the misunderstanding that caused us to accept this product. Please call if you have further questions or concerns regarding this matter. I may be reached at 897-2439 or 454-3452. Sincerely, Patty plazes CC: Kieth Schuett, Weld County Planning Mike Cervi, Northern Colorado Brine rtan?4111 4I FEB 5 1993 U 940056 SOLID WASTE FACILITY INSPECflUd (Surface Impoundments) County u L p DATE ki t I c ,3 Located in Facility i Lt,ryu Cato 74 Incorporated Area Location -•=c-4_ c't db(?)) (> Current Operator ,,;; skzw..�-t Mailing Address of Operator Current Owner (If different) Mailing Address of Owner .....n....... (All items checked must be explaind in supplemental report) I. A. Public Health and/or Environmental Hazards _ B. Evidence of Potential for (Serious) Surface Water Pollution __ C. Evidence of Potential for (Serious) Groundwater Pollution _ D. Sludge or Septic Pumpings Disposal on Site (Unauthorized) E. Safety Hazards B. Non—Compliance with Approved Design and Operation G. Structural Integrity of Dikes Questionable ✓H. Records __ I. Other * REMEDIAL ACTION REQUIRED II. Minimum Standards, CRS 30, 20-110 ✓A. Odors and/or Vectors Present _ B. Inadequate Fencing (to control access) C. Not Designated and/or Improperly Zoned D. Monitoring Wells (Maintenance, Intregrity, or Locking Cap not Present) Z. Evidence of Minor Spills Around Disposal Area 6.-°" F. Water/Liquid Surface Covered with oil(s) or scum 17=2-G. Depth Gauges not Present and or Readible -;77-H. Pond Freeboard Level Exceeded. I. Recommendatiot/18 for Site Imgro ement t/ ��J. Other `yic.J,�y L4UU* w ✓V4kt £ui(Ctea.I :PcurkC -F. s) Remarks // �" �yF .) �ti,L�p1 ti'-ti ha-vi tor b Levkll ht`-� . I) .c.tlt -1-14A-S" !1-cc20t-- ,L,,,,,,,rct, L iJ+2 �(TlatPvt r� Z ,I op«_r.,-�y �Zzca f .b>f rr-ir* v 6t. c, r f"�/ We t 1.-al rt.c�rCI f' • 74" tlbtr lit c-d WI! 1r,GA Hr ha.zl., cif ' nr- .uct.�J,,� flert,./2.e/ of nhg.- ch&d �S'} w of P, d 9lst4 b CI, y4 it',t 8a� cOV42-cd w1 m kcii+l. anetAA_ to N•'/;t•1140,ce < Cc {IH nrt,Geult a. es tow' i l ltt to celya, ctWd. ,1 6 it o44-6. ev u-est. c' n¢-t- e rt{c.f a& &a l 4c n,cie g-.4 S.4.) c. 4Y't"'A hats.,!'_. i3,, w t'�rr1.t4O I e.w ,� 7' 3' cM 6e M. w�Y .,, . t vLI �Y `(Name) PRESENT AT INSPECTION (Representing) ` v._ , T- 9l4 e Nit-c.3 _ _ `J V - \I 1993 \ � .. Ian_._...••nlanninr Inspection r .ot �r+r -L_ Wwt JR1, tC-lb< (WHITE COPY-FILE) (YELLOW COPY OPERATOR) (PINK COPY-COUNTY) 940056 / . , DEPARTMENT OF HEALTH 1517- 16 AVENUE COURT GREELEY, COLORADO 80631 O ADMINISTRATION (303)353-0635 HEALTH PROTECTION (303) 353-0635 COMMUNITY HEALTH (303) 353.0639 COLORADO January 25, 1993 Mike Cervi Northern Colorado Brine, Inc. P.O. Box 300397 Denver, Colorado 80203 Certified Letter No. : P 186 978 272 Dear Mr. Cervi: On January 22, 1993, a representative of the Environmental Protection Division of the Weld County Health Department inspected Northern Colorado Brine, Inc. located at 1O6OO Weld County Road 54, Milliken, Colorado, Weld County. The purpose of the inspection was to review waste volume delivery invoices accepted the date of January 21, 1993 in order to assess the facilities compliance with the "Solid Waste Disposal Sites and Facilities Act" (the Act) , Title 30, Article 20, Part 1, C.R.S. , as amended, the "Regulations Pertaining to Solid Waste Disposal Sites and Facilities", and the Operation Standards as set forth in USR- 54O:83:3. In reviewing the available documents, it was observed that two unauthorized loads of waste were accepted on the date of January 21, 1993. Invoices 37O83 and 37119 indicate that waste water from Monfort was accepted at the facility and introduced into the impoundments on site. According to the operator on site, this water is produced as the result of washing cow hides. The acceptance of the above mentioned waste is in violation of the Design and Operation plan, October, 1983 (D&0 plan) approved by the Colorado Department of Health (see attached letter, October 28, 1983) as required by Section 30-20-103 of the Act. Page 1 of the D&O plan states this facility "is an oil and gas well production water disposal site." In addition, the acceptance of this waste constitutes a violation of the operation standards set forth in USR-54O:83:3. Operation standard #1 states: The use shall be an oil and gas brine water disposal and oil recovery facility as described in the submitted application materials. No hazardous wastes or non-hazardous industrial waste shall be allowed at the site. The facility shall be designed, constructed and operated to comply with the Colorado Department of Health Solid Wastes Disposal Sites and Facilities Act, Title 30-20, Part 1, CRS 1973, as amended. \\I1i I\� FEB B `� 1 9��- „sr+O Mike Cervi Northern Colorado Brine, Inc. Certified Letter No. : P 186 978 272 January 25, 1993 Page 2 Additionally operation standard #15 states in part "the Use by Special Review shall be limited to the plans shown hereon and governed by the standards as stated. . . .any material deviations from the plans and/or standards as shown or stated shall require the approval of an amendment of the Permit by the Weld County Planning Commission and the Board of County Commissioners before such changes from the plans and/or standards are permitted. . . . This facility must immediately cease accepting wastes of this nature upon receipt of this notice. The violations outlined above constitute noncompliance with the Solid Waste Disposal Sites and Facilities Act, and USR-540:83:3. In addition, this facility must provide a written response to this notice within (5) days of receipt, your response will be considered in a determination as to whether further proceedings will be held in accordance with Section 30-20-113, C.R.S. , and USR-540:83:3. If you have any questions, please contact Trevor Jiricek at (303) 353-0635. Sincerely, 67 • Trevor Jiri ek . Pickle, M.$.E Solid and Hazardous Waste Specialist rector Environmental Protection Services /tj-161 cc: Wes Potter, Monfort, Inc. Roger Doak, Colorado Department of Health Victor Sainz, Colorado Department of Health Bill Webster, Weld County Commissioner Chuck Cunliffe, Weld County Planning Department Randolph L. Gordon, M.D. , M.P.H. , Director, Weld County Health Department 940056 _l� N ( f; mEmORAnDUm Wilk Chuck Cunliffe, Planning January 25, 1993 To ii. COLORADO John Pickle, Healt From Northern Colorado Brine Subject: Please reference my memo of 12-10-93 to you regarding this facility. The attached Compliance Order apparently was never finalized and is still pending action at the Attorney General's office. Unfortunately the violations have not stopped. Please review the attached NOV's for this facility. They have again been cited for an odor violation. They have also been cited for accepting waste not approved in their USR. I have also enclosed a letter from the community which is self-explanatory. It seems to me that this should be brought to the attention of the Board of Commissioners in the form of a Public Hearing. If you need further information, please contact Jeff, Trevor, or me. xc: Lee Morrison, Asst. County Attorney u cu t') 1� JAN 2 6 1993 Weld Perm*,Planninn 940056 iI L tl H tie.,i it t ri.- 1, \.. \ DEPARTMENT OF HEALTH 1517- 16 AVENUE COURT ' pc GREELEY, COLORADO 80631 WI ADMINISTRATION (303)353-0586 HEALTH PROTECTION (303)353.0635 COMMUNITY HEALTH (303) 353.0639 COLORADO January 25, 1993 Mr. Louis McBride Air Pollution Control Division Colorado Department of Health 4300 Cherry Creek Drive South Denver, Colorado 80222-1530 Dear Louis: This letter is a follow-up to the November 16, 1992 hearing on the Northern Colorado Brinewater Disposal facility. As you may recall, this facility was cited by our personnel on October 15, 1992 for an odor violation. At the hearing, it was determined that the citation was valid and that a violation of Rule ak 2 had occurred. It was also determined at that time that a Compliance Order was to be issued. This was made public by the news media present at the hearing. We prepared, and I signed a copy of the Compliance Order on December 10, 1992. This was sent to you for review and signature. We have heard nothing since. Unfortunately, as you probably know by now, this facility has been cited again by our Department. Since we still have no Compliance Order, we wonder what to tell the press, and the public in that community. On a local level, we cannot operate with delays such as this. Please contact Jeff Stoll or me, as soon as possible, with regard to further action on this matter. Very truly yours, 4 ;a1 ilia irector Environmental Protection Services Division xc: Lee Morrison, Asst. County Attorney Chuck Cunliffe, Planning 940056 _1 �' Town of C Johnstown SOAKS MEETS FIRST MONDAY IN MONTH P.O.SOS 906 JOHNSTOWN, COLO.80534 January 19 , 1993 Randolph L. Gordon, M.D. Director, Weld County Health Department 1517 16th Avenue Court Greeley, CO 80631 Dear Doctor Gordon, On behalf of the Johnstown Town Board, we would like to express concerns of our residents for our health and safety regarding the Northern Colorado Brine facility located northeast of our community. The potential hazards from the Brine Facility that the residents feel will affect them are fire, explosions, truck traffic and ground water contamination. The major hazard and of great concern which can affect our health is the complex hydrocarbon gasses in the air. We are asking you to institute procedures to close this facility for the safety and well being of our residents. Sincerely, 1 Wadas Mayor RW/ds cc: Ted Chavez, Milliken Mayor Johnstown Board of Trustees U! j JAN 2 6 1993 a Weld Cum *planning, 340056 /-o u o r• STATE OF COLORADO COLORADO DEPARTMENT OF HEALTH ��.o*.coca Dedicated to protecting and improving the health and 4 environment of the people of Colorado C w�. 4300 Cherry Creek Dr.S. Laboratory Building K L 1. i : .��/ � -� . 1c * Denver,Colorado 80222-1530 4210 E.11th Avenue EA,Jr. rp.��;��n( Phone(303)692-2000 Denver,Colorado 80220-3716 (303)691-4700 Roy Romer January 11, 1993 Comma Patricia A bia .MD,MPH t eCLAW Dveoor in rt �,-,,..-y !jr l:W 1' ,'7 Mike Cervi ...:�i •,� P.O. Box 300397 Denver, Colorado 80203 RE: Northern Colorado Brine Disposal Amendment to the Design and Operation Plan Weld County, Colorado Dear Mr. Cervi: This letter is intended to summarize the events which occurred during the period from December 10, 1992 thru January 7, 1993. The following events relate to activities at the Northern Colorado Brine Disposal (NCBD), Weld County. December 10 Weld County Health Department notified the Hazardous Materials and Waste Management Division of the Colorado Department of Health (the Division) that NCBD was planning on connecting the three existing impoundments with the newly constructed impoundment (pond #4) via subsurface piping. December 11 Mike Cervi, owner and operator of NCBD was notified, by the Division, that the piping construction was not included in the site's approved design and operation (D&O) plan, and would constitute an amendment to the original application. The Division and Weld County must approve any change in the DISCO plan. Mr. Cervi faxed a map with information on the piping plan and compaction test for pond #4. December 21 The Division reviewed the submitted information from December 11th. The information provided was not adequate to complete the review. The Division faxed its concerns to Vern Nelson, consultant for Mr. Cervi. December 22 Mr. Nelson faxed response to the Division's questions concerning the piping plan. 940056 Mike Cervi Northern Colorado Brine Disposal January 11, 1993 Page 2/3 December 28 The information sent by Mr. Nelson on Dec. 22nd was reviewed by the Division, all concerns were adequately addressed. December 30 A verbal approval was given to Mr. Cervi for construction of the piping. December 31 The Division completed its review of the permeability and compaction tests submitted for pond # 4. Two permeability test were taken. One test failed to meet the specifications detailed in the D & O plan. Mr. Cervi and Mr. Nelson were notified that an additional permeability test must be preformed for the liner material and that the sample should be taken from the area were the test had failed. January 7 The result of the permeability test was faxed to the Division. The data was reviewed, the test met the specifications detailed in the D&O plan. Mr. Nelson was notified that pond #4 had met the requirements of the D&O plan for the facility. The Division requests additional information concerning the rip rap and filter material used for the inlet pipe, pond #4. 1. Identify specifications of the rip rap and filter material. 2. Provide dimensions (thickness and aerial extent) of the filter and rip rap material. The Division requests that all data and information regarding the piping plan and construction of pond #4 be placed in a comprehensive document and submitted to the Division within thirty (30) days of receipt of this letter. The Solid Waste Disposal Sites and Facilities Act, Title 30, Article 20, Part 1, C.R.S. as amended gives authority to the Colorado Department of Health to charge a review fee for amendments to an original application, which would include the design and operation plan. The current fee is $72.47 per hour. 94005-6 • Mike Cervi Northern Colorado Brine Disposal January 11, 1993 . Page 3/3 These conclude the Division's comments concerning the piping plan and construction of pond #4, Northern Colorado Brine Disposal. If you have any questions please contact me at (303) 692-3437. c- ssi.s4 Sincerely, Roger Doak Geologist Solid Waste Section Hazardous Materials and Waste Management Division cc: ✓J. Pickle, Weld County Health V. Nelson, Nelson Engineering File: SW/WLD/NOR 940056 STATE OF COLORADO COLORADO DEPARTMENT OF HEALTH orcoto Dedicated to protecting and improving the health and .` _\ environment of the people of Colorado • „ G a 4300 Cherry Creek Dr.5. Laboratory Building i r_ C - : , a c_ • - Denver,Colorado 80222-1530 4210 E.11th Avenue 1876' Phone(303)692.2000 Denver,Colorado 80220-3716 -' (303)691-4700 Roy Romer H' IGovernor January 11, 1993 - .! -19$ Patricia A.Nolan,MD,MPH Executive Director .r Mike Cervi P.O. Box 300397 Denver, Colorado 80203 RE: Northern Colorado Brine Disposal Amendment to the Design and Operation Plan Weld County, Colorado Dear Mr. Cervi: This letter is intended to summarize the events which occurred during the period from December 10, 1992 thru January 7, 1993. The following events relate to activities at the Northern Colorado Brine Disposal (NCBD), Weld County. December 10 Weld County Health Department notified the Hazardous Materials and Waste Management Division of the Colorado Department of Health (the Division) that NCBD was planning on connecting the three existing impoundments with the newly constructed impoundment (pond #4) via subsurface piping. December 11 Mike Cerv;_owner and operator of NCBD was notified, by the Division, that the piping construction was not included in the _ site's�as proved design and operation (D&O)_plan, and would onnstitute an amendment to the original application- The _ Divisio must a rove any change in the O plan. Mr. Cervi faxed a map with i orrnatton on the ping p an an com December 21 The Division reviewed the submitted information from December 11th. The information provided was not adequate to complete the review. The Division faxed its concerns to Vern Nelson, consultant for Mr. Cervi. December 22 Mr. Nelson faxed response to the Division's questions concerning the piping plan. -JAN 1 5 1993 sushi orpontr otanninn 94005g c c Mike Cervi Northern Colorado Brine Disposal January 11, 1993 Page 2/3 December 28 The information sent by Mr. Nelson on Dec. 22nd was reviewed by the Division, all concerns were adequately addressed. December 30 A verbal approval was given to Mr. Cervi for construction of the piping. December 31 The Division completed its review of the permeability and compaction tests submitted for pond # 4. Two permeability test were taken. One test failed to meet the specifications detailed in the D & O plan. Mr. Cervi and Mr. Nelson were notified that an additional permeability test must be preformed • for the liner material and that the sample should be taken from the area were the test had failed. January 7 The result of the permeability test was faxed to the Division. The data was reviewed, the test met the specifications detailed in the D&O plan. Mr. Nelson was notified that pond #4 had met the requirements of the D&O plan for the facility. The Division requests additional information concerning the rip rap and filter material used for the inlet pipe, pond #4. 1. Identify specifications of the rip rap and filter material. 2. Provide dimensions (thickness and aerial extent) of the filter and rip rap material. The Division requests that all data and information regarding the piping plan and construction of pond #4 be placed in a comprehensive document and submitted to the Division within thirty (30) days of receipt of this letter. The Solid Waste Disposal Sites and Facilities Act, Title 30, Article 20, Part 1, C.R.S. as amended gives authority to the Colorado Department of Health to charge a review fee for amendments to an original application, which would include the design and operation plan. The current fee is $72.47 per hour. 940056 r • Mike Cervi Northern Colorado Brine Disposal January 11, 1993 .Page 3/3 These conclude the Division's comments concerning the piping plan and construction of pond #4, Northern Colorado Brine Disposal. If you have any questions please contact me at (303) 692-3437. c).9.4 Sincerely, 44—\--- Roger Doak Geologist Solid Waste Section Hazardous Materials and Waste Management Division cc: ✓J. Pickle, Weld County Health V. Nelson, Nelson Engineering File: SW/WLD/NOR 940056 1 January 28, 1992 Patricia Deplazes Eastern Plains Environmental Service Box 142 Pierce, CO 80650 Keith Schuett, Weld County Planning Department Trevor Jiricek, Weld County Health Department Dear Keith and Trevor, RE: NORTHERN COLORADO BRINE COMPLIANCE ISSUE I have been retained by Northern Colorado Brine Facility in order to help them come into compliance with the regulations and Use by Special Review. I have compiled the following plan to address the issues we have previously discussed regarding • your areas of concern. Our intent is to respond quickly and effectively to your concerns and to comply with all applicable regulations and standards. Please consider the following items: 1. Depth gauges needed on ponds : The depth gauges are on site and ready to be installed as soon as the ice melts sufficiently. A gauge was installed in Pond C on January 26, 1993. 2. Contaminated soil from fire area: Frost currently prevents the removal of this soil. It will be removed as soon as the soil thaws sufficiently to allow digging to take place. We will contact WCHD to inspect the area prior to filling with new soil. In addition, the damaged tanks cannot be removed until the investigation into the fire is completed. 3. Update Emissions Permit: I have spoken with Tom Tistinic, Air pollution Control Division, Colorado Department of Health and Northern Colorado Brine Facility is in the process of amending Permit 90WE161 to reflect the increased volume of waste being processed at NCB. 4. Exceeding of free board: With the new pond now approved to accept water, we are in the process of lowering the level on all ponds. Pond C has been lowered below the freeboard requirements. Ice currently prevents pumping of the other ponds. We will begin pumping from the other ponds into Pond E as soon as weather conditions permit. 940056 5. Records not on site: I am currently compiling the permits and documents needed to be at the site. I am also producing a set of documents to simplify the routine record keeping at the site and will - initiate that record keeping process with the on site manager as soon as possible. 6. Berms: Following the fire, repair and routine maintenance was done to the berms and roads. At that time, the berms were filled and leveled where settling had occurred. Additionally, in an attempt to direct precipitation runorf and reduce rill washing of the roads and embankments, the roads were edged with a small ridge, but the ridged area is not considered to be a part of the berm. 7. Odors: The odor problems that have occurred at Northern Colorado Brine Facility are considered to be the most significant and most challenging problem at the site. I believe that the addition of the new pond will help in reducing the odors at the site. Also, we are diligently searching for an adequate control method or device for odors at the site. I have spoken with Lou McBride at CDH and Jeff Stoll at WCHD and have asked both CDH and WCHD for assistance in determining what the best management practice for odors at this site would be. However, very little data exists at this time regarding odor problems at brine water disposal sites. In addition, I have scheduled, with WCHD, BOD testing of both the ponds and the incoming water in an effort to determine the cause and nature of the odors. Perhaps these test results will help us in determining the appropriate control measures. We will continue to search for the answer to the odor problems at Northern Colorado Brine, and I am confident that we will be able to attain compliance with the odor standard as required. • Please review this compliance plan, and forward to me any comments, ideas or additional concerns you may have. I may be reached at 897-2439. Sinceereelly,, Patricia Deplazes PD:sl cc Trevor Jiricek, Weld County Health Department Keith Schuett, Weld County Planning Department Mike Cervi, Northern Colorado Brine Facility 940056 DEPARTMENT OF HEALTH 1517• 16 AVENUE COURT GREELEY, COLORADO 80631 O ADMINISTRATION (303) 353-0586 HEALTH PROTECTION (303) 353-0635 COMMUNITY HEALTH (303) 353-0639 COLORADO January 11, 1993 Certified Letter No. : P 423 630 397 Mike Cervi Roggen Disposal, Incorporated P.O. Box 300397 Denver, Colorado 80203 Dear Mr. Cervi: On December 10, 1992, a representative of the Environmental Protection Division of the Weld County Health Department inspected Northern Colorado Brine, located at Weld County Road 54, Milliken, in Weld County, Colorado. The purpose of the inspection was to inspect and assess the facilities compliance with the "Regulations Pertaining to Solid Waste Disposal Sites and Facilities" (The Regulations) as promulgated by the Solid Waste Disposal Sites and Facilities Act, Title 30, Article 20, Part 1, C.R.S. , as amended, and the Operational Standards as set forth in U.S.R.-540. On the date of December 10, 1992, field inspection, the following observations were made: 1. Depth gauges were not present on evaporation ponds. Depth gauges must be available on all ponds to insure adequate freeboard levels are maintained. 2. Freeboard levels were estimated to be very near and possibly exceed the approved three (3) foot level. Due to the lack of depth gauges, exact levels could not be determined. In addition, daily records of freeboard levels must be available for review. 3. The operator on site was not familiar with the facility, approved waste streams, nor operations. 4. Operating records are not readily available for review. These include a copy of the Certificate of Designation, approved design and operations plan, site safety plan, operational variances, Use by Speci-1 R wk vr' - Permit, water monitoring data, etc. �1 JAN 1 2 1993 • num.,r-,.M.Dtangjflr 940056 DEPARTMENT OF HEALTH 1517. 16 AVENUE COURT ip GREELEY, COLORADO 80631 C ADMINISTRATION (303) 353-0586 HEALTH PROTECTION (303)353-0635 COMMUNITY HEALTH (303)353.0639 COLORADO January 6, 1992 Mike Cervi Roggen Disposal P.O. Box 169 Sterling, Colorado 80751 Dear Mr. Cervi: As you are aware, data submitted to the Environmental Protection Division of the Weld County Health Department in regard to the monitoring wells at the Roggen Disposal indicate that contamination of groundwater at that facility may have occurred. This contamination appears to have the potential for impairment of existing or future use of groundwater. This situation is currently under review by the Hazardous Materials and Waste Management Division of the Colorado Department of Health. If the Hazardous Materials and Waste Management Division determines that the above mentioned contamination is in fact causing an impairment to existing or future use of groundwater, this facility, will be required to come into compliance with the "Regulations Pertaining to Solid Waste Disposal Sites and Facilities". This would include Section 6.3.2 which would require submittal of a detailed written assessment of the impact of the seepage on the receiving aquifer and proposed remedial action within forty-five (45) days. This Division will notify your facility of any determination and necessary requirements in regard to this matter. If you have any further questions, please contact Trevor Jiricek at (303) 353-0635. Sincerely, Trevor Jiricek Solid and Hazardous Waste Specialist tj/041 cc: Roger Doak, Colorado Department of Health Glenn Mallory, Colorado Department of Health Lee Morrison, Assistant Weld County Attorney Keith Schuett, Weld County Planning - u cu v gIJAN 0 8 1993 'Vold Pam*,mumble' 940056 a \ DEPARTMENT OF HEALTH 1517- 18 AVENUE COURT GREELEY, COLORADO 80631 O ADMINISTRATION (303) 353-0635 HEALTH PROTECTION (303)353.0635 COMMUNITY HEALTH (303) 353.0639 COLORADO January 11, 1993 Certified Letter No. : P 423 630 397 Mike Cervi Roggen Disposal, Incorporated P.O. Box 300397 Denver, Colorado 80203 Dear Mr. Cervi: On December 10, 1992, a representative of the Environmental Protection Division of the Weld County Health Department inspected Northern Colorado Brine, located at Weld County Road 54, Milliken, in Weld County, Colorado. The purpose of the inspection was to inspect and assess the facilities compliance with the "Regulations Pertaining to Solid Waste Disposal Sites and Facilities" (The Regulations) as promulgated by the Solid Waste Disposal Sites and Facilities Act, Title 30, Article 20, Part 1, C.R.S. , as amended, and the Operational Standards as set forth in U.S.R.-540. On the date of December 10, 1992, field inspection, the following observations were made: 1. Depth gauges were not present on evaporation ponds. Depth gauges must be available on all ponds to insure adequate freeboard levels are maintained. 2. Freeboard levels were estimated to be very near and possibly exceed the approved three (3) foot level. Due to the lack of depth gauges, exact levels could not be determined. In addition, daily records of freeboard levels must be available for review. 3. The operator on site was not familiar with the facility, approved waste streams, nor operations. 4. Operating records are not readily available for review. These include a copy of the Certificate of Designation, approved design and operations plan, site safety plan, operational variances, Use by Special R-wi- v! Permit, water monitoring data, etc. l JAN 1 2 1993 Welt!P,..na.e1s•nain� 940056 e Mike Cervi Roggen Disposal, Incorporated January 13, 1993 Page 2 This facility currently does not employ depth gauges on the evaporation ponds as required. According to Operation Standard #7,H, set forth in U.S.R.-540:83:3, "A gauge height indicator shall be installed in each pond. The gauge must clearly indicate the depth of brine water waste." These indicators are required in order to assure that a minimum of three (3) feet of freeboard is maintained on each pond. An operator knowledgeable of the facility, its operations, and the approved waste stream must be present on site. Operation Standard #10, states that "a responsible employee, trained to differentiate between brine water and other drilling fluids, shall be at the facility during receipt of all brine water." Additionally, Section 2.2.9 of The Regulations states "no facility for solid wastes disposal shall knowingly receive any waste classified as acutely hazardous. . . ." If the current operator is to continue operating this facility, adequate training must be provided. This facility does not currently maintain adequate records. Operation Standard #9, states "all operating records will be made available to the State Health and County Health Department upon request. Operating records shall be maintained as described " Also, Section 2.2.13, of The Regulations which states "all operating records shall be made available to the county board of commissioners and the department upon their request." The violations outlined above constitute noncompliance with the "Regulations Pertaining to Solid Waste Disposal Sites and Facilities", and the Operation Standards in U.S.R.-540:83:3. This facility must respond to this violation notice within thirty (30) days. Failure to respond to this notice will result in further action in accordance with Section 2.3.4. of The Regulations. If you have any questions, please contact Trevor Jiricek at (303) 353-0635. Sincerely, 9AUett Trevor Jiricek Solid and Hazardous Waste Specialist tj /076 cc: Roger Doak, Colorado Department of Health Keith Schuett, Weld County Planning Department Lee Morrison, Assistant Weld County Attorney • 940056 t ` F if s DEPARTMENT OF HEALTH `• Ilat 1517- 16 AVENUE COURT IGREELEY, COLORADO 60631 C ADMINISTRATION (303) 353-0586 HEALTH O PROTECTION (303)3530635 COMMUNITY HEALTH (303) 353-0639 COLORADO December 4, 1992 Mike Cervi Roggen Disposal Inc. lNorthern Colorado Brine P.O. Box 169 Sterling, CO 80751 Dear Mr. Cervi: I am writing to confirm the general content of the meeting which took place at Northern Colorado Brine, Tuesday, December 1, 1992. Present at the meeting were: Roger Doak, Colorado Department of Health; Vern Nelson, Nelson Engineers; and of course you and myself. At this meeting, it was expressed that the Roggen Disposal, Inc. proposal, November 25, 1992, was inadequate as submitted. The following documentation was requested to complete the proposal and thus allows the Environmental Protection Division of the Weld County Health Department and the Hazardous Materials and Waste Management Division of the Colorado Department of the Health to complete the necessary review of the proposal prior to construction: 1. Provide all manufacturer specifications in regard to the proposed liner. Particularly, information, test data, etc. demonstrating the compatibility of the liner for the waste this facility is approved to accept. 2. Provide all quality assurance and quality control measures which will be incorporated to ensure adequate installation of liner, i.e. , destruction/construction tests of materials. 3. Provide an engineered plan on the method in which the liner is to be installed and anchored. 4. Provide an engineered plan on the specific construction of the facility. Specifically, the method in which the three (3) ponds will be joined. 5. Discuss and justify the classification of the impoundment. DEC 0 7 1992 U i- I wpm env*h,elnanino 94005G a, DEPARTMENT OF HEALTH \' 1517• 16 AVENUE COURT GREELEY, COLORADO 80631 O ADMINISTRATION (303) 353-0586 HEALTH PROTECTION (303)353-0635 COMMUNITY HEALTH (3031 353 0E39 COLORADO December 18, 1992 Certified Leter No. : P 423 630 378 Legal Agent of Service for Northern Colorado Brine P.O. Box 5714 Denver, Colorado 80217 BEFORE THE AIR POLLUTION CONTROL DIVISION COLORADO DEPARTMENT OF HEALTH STATE OF COLORADO COMPLIANCE ORDER IN THE MATTER OF NORTHERN COLORADO BRINE This Compliance Order is being issued by the Weld County Health Department and the Colorado Department of Health through the Air Pollution Control Division ("Division") to Northern Colorado Brine pursuant to the Division's authority under section 25-7-115(3) (b) , C.R.S. (1989 & 1992 Supp.) . GENERAL FINDINGS OF FACT 1. An evaluation of the odor emissions of Northern Colorado Brine, located at 10600 Weld County Road 54 in Weld County, Colorado, was made on May 20, 1992, by Jeffrey L. Stoll. At that time the odor intensity registered at 31:1 dilutions to threshold on the Barnebey-Cheney Scentometer. It was determined that the facility was out of compliance with the Colorado Air Quality Control Commission Regulation 2. The operator at the facility was notified immediately after the evaluation. 2. A warning letter was sent to Northern Colorado Brine on May 21, 1992. The letter informed Northern Colorado of the potential of further legal aGgp +iyryTl if violations continued. DEC 221121 'Held Cn1",t,01inninp 940056 3. Violations of Regulation 2 were documented by Weld County Health Department on October 15, 1992. Readings obtained were at 31:1 dilutions to threshold using the Barneby-Cheney Scentometer. Notification of the violation was attempted immediately after performing the evaluation, however, there was no response to knocks on the door of the attendant's residence. A copy was left at the desk in the office outside the attendant's residence. The attendant, Herb Ikenouye, called and acknowledged receipt of the notice at 8:00 a.m. the following morning, October 16, 1992. 4. A Notice of Violation, dated October 28, 1992, was issued to Northern Colorado Brine, in accordance with the provisions of Section 25-7-115(2) , C.R.S. (1989) , by certified mail, return receipt requested. 5. On November 16, 1992, a conference was held for Northern Colorado Brine, at the Weld County Health Department in accordance with the requirements of the Colorado Air Quality Control Act, Section 25-7-115 (3) (a) , C.R.S. (1989) . The conference was held to give Northern Colorado Brine the opportunity to submit data, views, and arguments concerning a NOTICE OF VIOLATION which was issued in accordance with the provisions of 25-7-115 (2) and dated October 28, 1992. No representatives for Northern Colorado Brine attended the conference due to the occurrence of an explosion at the facility the same morning. 6. The conference was continued on November 25, 1992, with representatives of Northern Colorado Brine in attendance. 7. A conference was held by the Weld County Health Department on November 25, 1992, in accordance with the requirements of the Colorado Air Quality Control Act, Section 25-7-115(3) (a) , C.R.S. (1989) , at which time the Division reviewed the data and evidence concerning the odor violations of Northern Colorado Brine. CONCLUSIONS OF LAW It has been determined that a violation of the Colorado Air Quality Control Commission's Regulation No. 2 did exist, as cited in the NOTICE OF VIOLATION dated October 28, 1992. ORDER Based on the foregoing Findings of Fact and Conclusions of Law, and pursuant to Section 25-7-115(3) (b) and (c) , Northern Colorado Brine is hereby ordered to comply with the following: 1. Effective immediately, Northern Colorado Brine shall comply with the odor standard of 15:1 D/T for "other land use areas" as required by Air Quality Control Commission Regulation 2, A.2. 2. This Compliance Order is a final order of the Division. OPPORTUNITY TO APPEAL Pursuant to Section 25-7-115(4) (a) , Northern Colorado Brine has the right to file a written petition with the Air Quality Control Commission within twenty (20) days of receipt of this Compliance Order, requesting a hearing to determine 940056 I any one or all of the following: 1. Whether the alleged violation or noncompliance exists or did exist; 2. Whether a revision of the State Implementation Plan or revision of a regulation or standard which is not part of the State Implementation Plan should be implemented with respect to such violations or noncompliance; The Air Quality Control Commission' s Procedural Rules, at Paragraph V.G.l.a. , mandates that all petitions for review of this order shall contain: a. Identification of the person requesting such hearing, address and telephone number. b. A statement of the relief requested and a general statement of the factual basis and legal justification for the requested action. c. A statement describing the person's interest in the matter. d. An estimate of the time required for the hearing. All hearing requests must be addressed to Chairman, Air Quality Control Commission, Colorado Department of Health, 4300 Cherry Creek Drive South, Denver, Colorado 80222-1530. NOTICE OF POTENTIAL LIABILITY FOR ADDITIONAL CIVIL PENALTIES AND INJUNCTIVE RELIEF Section 25-7-121, C.R.S. , states that in the event any person fails to comply with a final order of the Division, or the Commission, that is not subject to stay pending administrative or judicial review, the Division may request the Attorney General to bring suit for injunctive relief. Section 25-7-115(3) (b) , C.R.S. , authorizes the Division to assess penalties for failure to comply with a final order of the Division in accordance with Section 25-7-122, C.R.S. , for civil penalties in accordance with Section 25-7-122 in an amount up to $15,000 per day of violation. Section 25-7-123(3) (b) authorizes the Division to assess penalties up to $10,000 per day of violation for each day of odor emission in excess of 15:1 D/T. NOTICE OF EFFECTIVE DATE OF ORDER This Compliance Order shall become effective upon receipt. WELD COUNTY HEALTH DEPARTMENT COLORADO DEPARTMENT OF HEALTH John Pickle, M.S.E.H. David R. Ouimette Director Chief, Compliance, Monitoring Environmental Protection Services and Enforcement Section Division Air Pollution Control Division -3- 940056 • cc: Air Quality Control Commission Tony Trumbly, Assistant Attorney General Carol Smith, EPA Region VIII George Kennedy, Weld County Board of Commissioners Randolph L. Gordon, M.D. , M.P.H. , Director, Weld County Health Department • -4- 940056 mEmoRAnDum WI I p c. Chuck Cunliffe, Planning - -- vember 16, 1992 To e COLORADO John Pickle, E.P. . From Northern ColoraBrine Subject: On October 15, 1992, Jeffrey Stoll of our staff investigated an odor complaint at Northern Colorado Brine located at 10600 WCR 54, Weld County, Colorado. At that time, it was determined by using the Barnebey-Cheney Scentometer, that odor emissions from the evaporative ponds were in excess of the limits allowed by the Colorado Air Quality Control Commission's Regulation It 2. Odor intensity between 10:00 P.M. and 10:50 P.M. on that date was detected at 31:1 dilutions to threshold (D/T) . Regulation # 2, Section A.2. limits odor emissions to 15:1 D/T for "other" sources. The facility appeared to be open, as two (2) trucks delivered brinewater during the time period of the investigation. Mr. Stoll followed the second delivery onto the property and into the office area. Attempts were made to deliver the notice of violation in person, however, the manager did not respond to knocks on the door of his residence. A copy of the notice was left on the manager's desk, and contact was made with him by telephone at 8:00 A.M. on October 16, 1992. A formal Notice of Violation was sent to Mr. Cervi on October 28, 1992, with a hearing date set for November 16, 1992. The hearing was held on that date, with Louis McBride, Colorado Department of Health in attendance, as well as Dr. Gordon, Jeff Stoll and myself. Mr. Cervi was not in attendance at that meeting. ( As you may recall, that was the date of the fire at Northern Colorado Brine.) At that hearing it was determined that a violation of Regulation # 2, Section A.2. did occur on October 15, 1992. An Order for Compliance has been issued by this Division, and Colorado Department of Health. Copies of all pertinent documents are attached. It appears that this violation, is also a violation of Development Standard II 1, of the USR for this facility. Please let me know how to proceed in this matter. If you have any questions, please contact me. xc: Lee Morrison, Assistant County Attorney DEC 18 199 2 Weld �aatvPlaaalap 940056 • .P 423 6 EC 36E ., Receipt for Certified Mail No Insurance Coverage Provided Do not use for International Mali DEPARTMENT OF HEALTH .v.. (See Reverse) sent m MIKE CERVI 1517-16 AVENUE COURT sweet atNORTHERN COLORADO BRINE GREELEY, COLORADO 80631 ADMINISTRATION (303)353-0586 vo.,stabDEN NVV..R ERode 'CO 80217 HEALTH PROTECTION (303)353-O635 Posuga $ COMMUNITY HEALTH (303)353-0639 Car-titled Fee Soeuu Oenvery Fee Resmcted Deuvwy Fee Os Return Recent Showing to Whom&Oat.Oelwered Return Recerot Showing to Whom. C Date.and Addressees Address 3 TOTAL Postage C a Fees Postmark or Date SENT TO STATE 423 630 362 ON 10/28/92. STATE TO 6 SEND OUT LETTER AFTER a STATE'S SIGNATURE. Denver, Colorado 80217 RE: NOTICE OF VIOLATION Dear Mr. Cervi: This letter constitutes a formal "Notice of Violation" as a follow up to the October 15, 1992, investigation of odors from the evaporation ponds of Northern Colorado Brine located at 10600 WCR 54, Weld County, Colorado, conducted by Jeff Stoll, a duly delegated representative of the Weld County Health Department. This Notice of Violation is being issued pursuant to the Division's authority under Section 25-7-115(2) , C.R.S. (1989 & 1992 Supp.) During the Division's October 15, 1992, investigation, it was determined by using the Barnebey-Cheney scentometer that odor emissions from your evaporation ponds were in excess of the limits allowed by the Colorado Air Quality Control Commission's Regulation No. 2 (copy attached) . A copy of the attached report was left under the door of the caretaker's residence and was acknowledged by Mike Cervi by telephone the following morning. Odor intensity between 10:00 p.m. and 10:50 p.m. an October 15, 1992, was detected at 31:1 dilutions to threshold (DPI) . Regulation 2, Section A.Z. limits odor emissions to 15:10/T for "other" sources. Section 25-7-122(1) (b) provides that any person who violates any applicable emission control regulation shall be subject to a civil penalty of not more than $15,000.00 per day for each day of violation. In addition, Section 25-7-115 (5) requires the Division to determine whether a noncompliance penalty is applicable. If a noncompliance penalty is found to be applicable, such penalty generally must be assessed for any period of violation from the date on which the emission source is brought to compliance. The amount of noncompliance penalty is calculated in accordance with the provision of Section 25-7-115(5)(b) , C.R.S. DEC 1 8 1992 \\\ Weld County Plannina 940056 • RE: NOTICE OF VIC..AT ' October 28, 1992 kG Page 2 In accordance with requirements of Section 25-7-115(3) , a conference regarding the violations described above has been scheduled for November 16, 1992, at the Weld County Health Department located at 1517 16th Avenue Court, Greeley, Colorado at 11:00 a.m. This conference will provide Northern Colorado Brine an opportunity to submit data, views and arguments concerning the above violation, and whether assessment of a civil penalty and noncompliance penalty is required. The Division may provide further opportunity for Northern Colorado Brine to respond after the conference, if circumstances warrant. As a result of the conference a determination will be made as to whether a Compliance Order will be issued and whether a civil penalty and noncompliance penalty must be assessed. Should the scheduled date or time be inconvenient for you, contact this office at 353-0635 for rescheduling. Failure to attend the conference will result in the issuance of a Compliance Order and possible assessment of penalties against Northern Colorado Brine. If you have any questions concerning the conference or other matters prior to the scheduled conference, please contact this office. The conference is an informal proceeding. You may, however, have legal counsel attend with you. Sincerely,11:124-4d ohn Pickle, Director Harry Collier, Field Services Supervisor Environmental Protection Services Stationary Sources Program Weld County Health Department Air Pollution Control Division Colorado Department of Health cc: Tony Trumbly, Assistant Attorney General Air Quality Control Commission George Kennedy, Weld County Board of Commissioners Randolph Gordon, M.D. , Director, Weld County Health Department JS/lam-2226 940056 COLORADO DEPARTMENT OF HEALTH` AIR' POLLUTION CONTROL DIVISION COoP— A /n�ANALYfT,AIICAL REPORT OF VICH}LC EMISSION r,VIOLATION ,(/� COMPANY kYr C--r z/vr f cL-c kin"'Le 8 21/15: DATE BLS/l4 / l .."--- ADDRESS OF SOURCE / G� /� n pCiitt}y�- ) �e+ Street j� County AOCR STACK NAME FBI C'rf 4i1 ! ! i flv r% BACKGROUND SKY CONDITION N/ C'kr 1,-r-L.V CeGGL,ChY •__w� N -3.r` RELATIVE HUMIDITY LI.� % PSYC. �� Pr, WEATHER BUREAU ^ AIR TEMP, F WINO SPEED aprre_/ f7 si rt fD L,.. . WIND DIRECTION (From) I`J C. PLUME CHARACTERISTICS(Color,etc.) ` e ‘ STACK HEIGHT Foot OBSERVER YS LOCATION J!-c O Feat _c w of Stack C prtliS) WET PLUME or DRY PLUME: .Ilf WET,intimate the breakpoint distance from the Reek) #Ise; CLOCK TIME 0 15 30 46 SKETCH: Include 1) Wind Direction: 2) Sun Position: 3) Observer Position; /O: D :! 0 I — — 41 Approximate Location of stack; 5) North Arrow. /v :/o 01 3 I If more than one stack is located at the plant site 02 -- —' ktr, specifically identify the stack being read. Include remarks. its, 03 '-e31 - II /0: se05 -- - No in 06 .4 -PSK 09 0 14•1 ` L 10 N � 11 `12 • , ' 13 14 4� (((,,,//// 14 V 15 16 II 17 • 18 �.yr . in 19 I 'tom 21 20 WC �r-se� Q l zz 23 24 u r• 25 26 27 ji DEC 1 8 1992 I 28 29 /\/'�j��//'n///�J'jy� Weld Count,Planning OBSERVER:/] ti a �� uIl7k15 " SIGNATURES: Duplicate Of this Analytical Report Given To PERSONSP SE T URIN THE EVALUATION: 26 �mOU $ — Name: 1T Name: ern •ES Title: JLe �JCci �//��/� s ey. Date; Title: ��,c1,oC F..- t✓^Q ) CI- 1W •Q.u-4�� " \• Time: //: 0 ‘ Signature: 940056 APC-55(6-75-100) C • NELSON ENGINEERS 822 7TH STREET GREELEY. '2OLORA0O 80631 (303) 356-6362 November 25 , 1992 • Mr. John Pickle Environmental Protection Services Weld County Department of Health 1517 16th Avenue Court Greeley, Colorado 80631 RE: Road 54 E-Van; Revorted Odor Problem, Northern Colorado Brine Dear Mr. Pickle: On behalf of Mr. Mike Cervi, owner of Northern Colorado Brine, and as the engineering representative, I am submitting the following odor abatement plan as requested by your office. Implementation of the plan has already begun with earthmoving activity as authorized by Weld County, injection of enzymes, aeration changes, and investigations of aeration systems . The plan is as follows: 1. Pond surface area is being increased primarily by construction of Pond 4 from a total surface area of 19 . 3 acres+ to 28 .3 acres+, an increase of about 46 . 6% . r2. Aeration injection units have been changed from VCP to copper to increase airflow into the pond water and increase agitation effect. /3. In early November, 1992, enzymes were injected into the brine to neutralize microorganic activity (The effect is being monitored and if deemed advisable, a schedule for periodic application will be created) . 4. Various methods of aeration are being investigated in an attempt to find the most effective method of application. These methods include different air diffusers, optimum depth of injection, and water surface agitation. J 11 DEC 1 8 1992 I Weld County Plowing n 940056 There has been a substantial change in the amount of brine wastes generated in recent weeks and months due to the extreme increase in oil and gas drilling activity in the Weld County area. It is an acknowledged fact this drilling activity is cyclical. Weld County is currently in the high activity phase of the cycle. As a result, more storage capacity and increased evaporation area is needed. The construction of the new pond will provide for reduced concentration of the waste and provide for increased evaporation as well as providing more volume of storage to accomodate the increased waste generation at this time. The aeration process may be amenable to effecting more efficiency in the system once the existing process is evaluated. The injection of air in combination with appropriate enzymes in optimum amounts will decrease the odor generation. As a result of the evaluation, the aeration systems in the existing ponds may be changed to be more effective. The owner is effecting the above operational changes and modifications to significantly reduce any odor and to improve the overall operations. Respectfully, NELSON ENGINEERS L �� Vern elson LCN:kb 1125.EVAPodor 94006 Hello