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Home My WebLink About941587.tiff LIND, LAWRENCE & OTTE'NHOFF ATTORNEYS AT LAW THE LAW BUILDING " ' - • (' I'7 1011 ELEVENTH AVENUE P.O. BOX 326 GREELEY, COLORADO 80632 - GEORGE H. OTrENHOFF :� _ TELEPHONE KENNETH F. (303) 353-2323 ND KIN R. LAWREENCE December 20 , 1993 (303) 3569160 TELECOPIER (303) 356-1111 JEFFREY R. BURNS Weld County Department of Planning Services 1400 North 17th Avenue Greeley, CO 80631 Attention: Keith Schuett Re : Wrights Disposal, Inc . USR and CD Application Dear Mr. Schuett : On December 16 , 1993 you contacted me requesting some additional information regarding the above referenced application. Hereinbelow are your questions and/or, comments and responses . 1 . Question or Comment : Page 2 of the application letter dated December 2 , 1993 made reference to a May 9 , 1989 letter from Weld County and said May 9 , 1989 letter was not included in the application materials . Response: Attached to this letter is a copy of said May 9 , 1989 letter. 2 . Question or Comment : The $10 . 00 USR recording plat fee check was not enclosed. Response: Attached to this letter is our check in the amount of $10 . 00 payable to Weld County Department of Planning Services . 3 . Question or Comment: The vicinity map showed, by a hatched line, access to the USR site from Weld County Road 19 but the plan map did not include the access road in dark lining. Is the access road to be part of the USR area? Response: The USR area will be approximately 40 acres which will include the access road. At the present time it is contemplated that said access road will only need to be 20 ' in width. If the access road needs to be larger for any reason, the applicant and the current owner of the property, Suckle Farms, Inc . , have agreed that the applicant can acquire additional property to widen the access road. The exact parcel configuration including access road will be delineated and plotted by metes and bounds description upon final approval , and prior to recording of the Use by Special Review map . 941587 isaa.A6//C „gel/teed 4e1/1/7179 a of/ieN Weld County Department of Planning Services December 20 , 1993 Page 2 4 . Question or Comment: The application discusses a retaining structure around the tanks for purposes of confining any spill . What is the total capacity of the area within the retaining walls? Response: The EPA has approved 9 holding tanks with the largest tank having a capacity of 400 barrels . The concrete retaining wall encloses all 9 tanks and will hold 431 barrels . It was required that the retaining wall be of sufficient capacity to hold all fluid from the largest holding tank. 5 . Question or Comment: The USR parcel is 40 acres in size but the actual operations and business area is less than 3 acres in size . What is the current use of the balance of the property and what is contemplated for future use? Response: The 40 acre parcel will consist of approximately 1/2 acre for access road, 3 acres for the operational site and the balance of the property being approximately 36 . 5 acres is currently used for dryland agricultural production. The future use will remain the same as the applicant and current property owner, Suckla Farms , Inc . , have entered into a lease providing for farming of the acreage not used for the active operational site and road. 6 . Question or Comment : The application did not address noise . Are motors on site electric, gas, diesel or other? Response: All on site motors are electric with the only main source of noise coming from the 24 ' x 24 ' pump building. This is a totally enclosed building which has a door that can be opened on the East side of the building. The nearest residence (Suckla) is not bothered by any noise emanating from the pump building and this noise can be controlled by closing the door. The other source of possible noise is entry and exit of trucks to the operational site . The applicant will comply with all applicable State and/or Federal noise and sound restrictions for this type of use . 7 . Question or Comment: Do we have an address for the Bull Ditch which runs through the property? Response: As of the date of this letter we have not yet determined an address for the Bull Ditch. The applicant is checking with neighbors to determine responsible parties and/or addresses which will be provided to the County as soon as possible . 8 . Question or Comment: What are the plans for parking for employees and/or users of the facility? Response: Employee parking is located within the area bordered by the tank facilities on the West, the 24' x 24 ' pump building on the North, the facility entrance from the road on the South, and the 10 ' x 16 ' office building on the East . The employee Weld County Department of Planning Services December 20 , 1993 Page 3 parking area is approximately 30 ' x 30 ' . Other "parking" takes place at the South end of the facility on the 11 . 6' x 60 ' cement pad which is the truck unloading area. This is no actually parking but is used for truck unloading but the vehicles are parked during unloading. Also enclosed is a copy of the United States Environmental Protection Agency Minor Permit Modification which provides for an increase in injection pressure . This minor permit modification is considered an addendum to the EPA approval . Should you have any additional questions or comments, please feel free to contact the undersigned. We are enclosing the original plus 27 copies of this response for your use . Very truly yours, LIND, LAWRENCE TTENHOFF 4:12.--: •,{""4" / Kenneth F . Lind KFL/cg Enclosure OEPAliT MT Or. _.ANININ3 `._ r = 1 , �, � •( # • pt,ONE X7071 ].e-+(:a0 ++Ca - )F 9�5 letn STRE?- 1.1�+ 'i GREELEY.COLORADO d061: • WIDc. COLORADO May 9 , 1989 A & r Water Service , Inc. Attn: Mr. Charles Wright ' .G. Bak 446 3righccn, CO 80601 Legal Description: Parc 'of the SEi NEh of Section 10, TIN, 167W of the 6th P.M. , Weld County, Colorado. Dear Fr. Wright: This letter is to inform you chat the Department of ?leaning Services has determined that an injection storage facility for the disposal of water of we by trucks existed before August 30, 1982, zoning of your Therefore, we have determined that the injection facility for the disposal of brine water by trucks is a nonconforming use. Nonconforming s r NCU-217 has been assigned to the file. Please retain this number for further reference. Production water disposal through either secondary recovery or deep well disposal vda and o o transport such injection CVeins the eA exclusively elyly via pip pipeline is defined as a use by right (Agricultural) tone district. Should the present use change in any way, it would need to comply with the present zoning ordinance. We want co thank you for your cooperacton in this matter. • Sincerely, ogle Curre t Planner • 3J3:rjg -- i • • 9CC0•2fl aCCN-:mow-.:f CS= _AC.- C_<r- - N.C.U.EZL7 Nare (Otitar) A u T4 `dater Service . Inc. Address: P.0. Box 446 3righcan, CO 80601 Phone No. . 639-65Z3 LEGAL DESCA:?T'_0N: Part of the SEE NEE of Section LO. TIN, R67W of the 6th F. '. , IJeLd County, Colorado LOCATICNr Approximately Z miles vast of the City of Fart Lupton; south of Scare 8ighvay 5Z and vest of geld County load ZL USE OF PROPERTT: Aa infection storage facility for the disposal of brine water by truck. Based as as annual figure. traffic to the site averages 9.4.7 truck trips per day. These calculations were obtained from the AND CO _Production Company accounts receivable sheets for 1986 and 1987. CURRENT ZONING: A (Agricultural) APPROPREATE DATE FOR. DETERMINATION OF NONCONFORMING USE: Ianuary 5, 1977 — Use by light is the I (Agricultural) tone district.. August 10, 1982 — Ordinance 89-3. Cse by Special Review_ REASONS FOR DETERMINATION OF NONCONFORMING IISE: Records of AMOCO Production Company accounts receivable records indicate the use of the storage facility for infection as early as 1978. - Adoption of Ordinance 39-3. August 30. L98Z, establishing injection wells as a Use by Special. Review is the A, (Agricultural) zone district_ • 900 - 12-20-1993 10: 12AM FROM R 8 R 17661111 2' ,i► etji.. UNITED`STATES ENVIRONMENTAL PROTECTION.AGENCY 4. $�t t�a _} REGION VIII lirn Y 949 18th STREET • SUITE 500 DENVER, COLORADO 80202-2466 N DEC 6 1993 • Ref: 8WM-DW CERTIFIED MAIL{ • RETURN RECEIPT REQUESTED Martin J. Wohnlich Wright' s Disposal, Inc. 2323 South Wadsworth, Suite 103 Denver, Colorado)S.0227 1,: 'x'•' RE: UNDERGROUND INJECTION::CONTROL ( JIC) ` ; Minor Permit Modification for tie Class I Suckle Farms #1 Well (EPA Permit #CO1516-02115) Weld County, Colorado' Dear Mr. Wohnlich: Enclosed is a minor modification to the above-referenced permit. Your 'request to increase the maximum surface injection pressure was received in our office on September..10 .1993 . The results of a step.-rate test performed in the Suckla=Farms #1 well support your request for an adjustment in inject£on•spressure; therefore, your request has been approved. The enclosed. "Addendum to Statement of Basis" discusses the ` reasons for the:permit modification and the upward;radjustment of injection pressure from 2, 397 pounds per square: inchgauge (psig) to a maximum of 3, 700 psig. If you haves any questions on this action,' Y.91,2?-may contact I. John Carson ,at ,_.(.303). 293-1435 . Also, vleas directaall. r.1. c rresoondence to >the attention of John Carson. at;Mill` Code 8t*-DW. Sincerely, 3' . . . Do , Director Wa r Management .Division Enclosures : Addendum to Statement of Basis •Minor Permit Modification Printed on Recycled Pepw 12-20-1993 10: 12PM FROM R 8 R 70 _355111: 7, a Martin J. Wohnlich Wright' s Disposal/ Inc. CO1516-02115 4 Page 2 • cc: Glenn F. Mallory w/encicsures X Colorado Department of F ealth ' • John S. Pickle w/enclos• res Weld 'Count " Health Depa: tment • Ken Merefeider Wright' s Disposal, Inc. • • r 12-20-1993 10: 12AM FROM R . R G :5'So: :_ "Pe`% • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY c T} REGION VIII t, 999 18th STREET - SUITE 500 DENVER, COLORADO 80202-2466 • MINOR PERMIT MODIFICATION Class I Well Suckle Farms #1 . EPA Permit #CO1516-02115 Pursuant to Part III, Section B. 1. of the above-referenced Class. I Underground Injection Control (UIC) permit, .a modification to 'said permit is to be made. Changes to the original version of Part II, Section C. 4 . (a) areas follows: Original version:. • ' 4 . Injection Pressure Limitation. • (a) Injection pressure, measured at the surface, shall not exceed 2, 397 pounds per square inch gauge. • Is Modified to r9ad: 4. Injection Pressure Limitation. 0 (a) Injection pressure, measured at the.. surface, shall ' rot exceed 3 , 700 pounds per square inch. gauge. All other provisions and conditions of the final permit for the Suckle Farms #1 well remain as originally issued. December 3, 1993 �-, Date . Dodso , Director Wat Management Division • EPA Permit #CO1516-02115 Page 1 of 1 Printed on Recycled Paper 12-20-1993 10: 13AM FROM R & R _356____ '. • Addendum to Statement of Basis • for EPA Permit #C01S16-02115 Class I Well Suckle Farms #1 Date prepared 10/8/93 Wright' s Disposal, Inc. submitted a request for a minor permit modification on September 10, 1993 . The request was to increase themaximum permitted surface injection pressure. from *µ. p ..2, 397 poundsperisquare inch gauge. (psig) to 3 , 7QOr sg.; based on the results of a step-rate test of the Lyons injection zone' (9 ,276-9,418 feet) in the Suckle Farms #1 disposal well. Injection Pressure: A review of data from a step-rate test performed on • • July 9 , 1993, indicates that no formation breakdown of the Lyons occurred up to the termination of the test at a surface injection of 3, 700 psig at an. injection rate of 8 .0 barrels ofrwater per minute. This surface injection pz :ssure, adjusted for hydrostatic. pressure and friction 7oss in the tubing5:.string, corresponds to a`'bottom-hole pressure of 4, 515 psig. • ` Subsequent to the step-rate test, a temperature log and a radioactive tracer survey were run in the well during injection. Both tests indicated that all fluids were ent . ring and being contained in the injection zone. Under Part ii-, Section C. 4. of the permit, the injection' pressure may be increased' by the Director if the permittee demonstrates that: the proposed increase in surface injection pressure .will:.not.'exceed the injection formation fracture pressure. •Ths•pressure limit is to be determined .by.:;::performing a step-rate test:or. other authorized well test(s) . H Therefore., on the basis of the'-test results, a maximum surfaces..iajsection pressure of 3,700 psig shall be approved for the Suckla Farms #1. is i EPA Permit #CO151.6-02115 Page 1 of 2 12-20-1993 10: 13RM FROM R & R 0 Suckle Farms Injection Well #1 Wright's Disposal, Inc. - CO1516-02115 4000 Figure 1 . 3500 .fl„ 3000 Step Ratn Injection Test x-2500 c • 2000 • O u.1 1500 z at 1000- 500- , 0 r r 0 1 2 3 4 5 6 • 7 8 RATE (bbl/mir: - • EPA Permit *CO1516-02115 .. .. Doha '7 of _7 Hello