HomeMy WebLinkAbout991313.tiff iitc\f\tiloo MEMORANDU :M
1'.• 1.TO: Scott Ballstadt, W.C. Planning DATE: September 2,S1,-)
0
FROM: Trevor Jiricek, W.C. Health Department ?c
COLORADO
SUBJECT: USR-1198, Enviro-Cycle LLC/Howard Boatright
Our staff has spent a significant amount of time considering and reviewing this application. We
have previously expressed our concerns with this application in a August 11, 1998, memorandum
to you. Also,you and I have observed two (2) somewhat similar facilities in our County, as well
as a similar facility near Burns, Wyoming.
Our primary concern continues to lie in the manner that waste will be received at the facility. We
are still not completely convinced that the facility can control or prevent oil wastes from being
carried, by truck wheels, from the concrete receiving pad onto the gravel driveway and the
County Road. I discussed this concern, as well as the other concerns outlined in my August 1 1,
1998, memorandum, with the applicant and his representative on August 21, 1998. As you are
aware, in an August 24, 1998, letter to you, the applicant has committed to design and
operational practices that arc intended to address our concerns. I lowever, the operational
practice(washing of the concrete receiving pad) committed to by the applicant is labor intensive.
These practices will need to be kept up without fail.
After considering all of the available information, we have compiled a number of standards that
we recommend being a part of any approval. We have separated the standards into Conditions of
Approval and Development Standards.
Proposed Conditions of Approval:
1) A secondary containment concrete structure (floor and walls) shall be constructed around
each tank battery. The volume retained by each structure shall be greater than the volume of
the largest tank inside the structure. Each structure shall be designed by a registered
professional engineer. The structure shall prevent any release from the tank system from
reaching land or waters outside of the containment area. The operator shall provide
evidence from the engineer to the Weld County Health And Planning Departments that the
structures have been constructed to meet this criteria.
2) A permitted individual sewage disposal system shall be installed to serve the facility. In
accordance with the Weld County ISDS Regulations, the system must be designed by a
registered professional engineer. The design must be submitted to the Weld County Health
Department for review and approval prior to installation.
3) Any required Air Emissions Permits must be obtained from the Air Pollution Control
Division, Colorado Department of Health.
EXHIBIT
I 1 0
"C:P
Enviro Cycle LLC/Howard Boatright J;y
September 2, 1998 tat
Page 2 ` . e
5. '.�= ;r
4) A copy of the drilling log shall be submitted to the Weld County Health Department.
5) The applicant shall construct a seven (7) foot high metal frame over the sand trap (identified
as the concrete segmented pit on the drawing submitted in the application materials). The
frame shall be covered with one (1)inch plastic coated metal mesh netting to protect people
and wildlife from entering. The netting shall be connected on both sides of the sand trap and
have a door to permit personnel access.
6) The applicant shall submit evidence that the facility was constructed in substantial
accordance with the application materials. These include the undated materials submitted to
the Planning Department and sent to referral agencies under cover letter, dated July 17,
1998, and the supplemental materials dated August 24, 1998.
Proposed Development Standards:
1) The facility shall be constructed and operated to insure that contamination of soil and
groundwater does not occur.
2) A Manager, knowledgeable in operating an injection well, shall be on site when the facility
is receiving waste.
3) A safe and adequate fresh water supply shall be available on the facility premises.
4) A 3-foot by 4-foot sign shall be posted at the entrance gate listing wastes accepted, hours of
operation, and twenty-four hour emergency telephone number.
5) Any wastes generated on the facility shall be disposed in accordance with the Colorado
Solid Waste Act, 30-20-100.5, C.R.S., as amended, or other appropriate rule, regulation, or
law.
6) No disposal of waste, other than Class II, as defined by the Environmental Protection
Agency is permitted. Any change from the approved Class II use would require an
amendment to this Special Review Permit.
7) The maximum permissible noise level shall not exceed 70 db(A), as measured according to
25-12-102, Colorado Revised Statutes.
8) Fugitive dust must be controlled on this site.
9) All Chemicals stored on-site must be in locked buildings, on an impervious surface,
provided manufacturer recommendations for safe storage and handling are in accord. In any
event, manufacturer recommendations will take precedence.
10) The surfaces around the disposal area shall be constructed of an impervious material, and
graded to insure that all spilled waste is contained within the unloading pad.
Enviro-Cycle L LC/Howard Boatright
September 2, 1998
Page 3
11) The facility must be entirely fenced and shall maintain locking gates during periods when
the facility is closed.
12) Any analysis of waste will be forwarded to the Weld County Health Department,
Environmental Protection Division. The Division reserves the right to require monitoring at
a later date.
13) This facility must comply with the laws, standards, rules and regulations of the Air Quality
Control Commission, the Water Quality Control Commission, the I-lazardous Materials and
Solid Waste Division, the Colorado Oil and Gas Conservation Commission, any other
applicable agency, and all applicable Weld County zoning laws and ordinances.
14) Upon cessation of injection activities, a detailed closure plan shall be submitted to
Environmental Protection Services for review and approval. This shall include the manner
in which the well will be plugged and abandoned, as well as specific details regarding
reclamation of the property. No structures or equipment associated with the facility shall
remain on the property following closure.
15) Any petroleum contaminated soils on the facility shall be removed and disposed in
accordance with all applicable rules and regulations.
16) The concrete receiving pad shall be cleaned at a frequency that prevents oils and other
wastes from building up on the pad. At a minimum, the pad shall be washed daily, with a jet
hose to remove any waste build-up.
17) During winter months, the facility shall maintain the receiving pad free of ice.
18) At a minimum, the Underdrain shall be inspected weekly. The facility shall maintain a log
on-site recording the date the underdrain was inspected and any observations during the
inspection. In the event fluids are detected in the underdrain, the facility shall cease
operations and notify the Colorado Oil and Gas Conservation Commission and the Weld
County Health and Planning Departments. No fluids shall be received at the site until the
source of the fluids in the underdrain is identified, repaired, and any remedial work has been
completed.
19) A biocide shall be injected into fluids received at the facility. The biocide shall be injected
into the first compartment of the sand trap.
20) The integrity of the netting material covering the sand trap shall be maintained.
21) Personnel from the Weld County Health Department and Weld County Department of
Planning Services shall be granted access onto the property at any reasonable time in order
to ensure the activities carried out on the property comply with the Development Standards
stated herein and all applicable Weld County Regulations.
‘totriii,6
MEMORANDUM
•
TO: Scott Ballstadt, Planning Dept. DATE: Aug t 14 T998 ;
C FROM: Trevor Jiricek, Health Department-.1 \�
•
COLORADO SUBJECT: USR-1198, Enviro-Cycle LLC/Howard Boatright
Our Department has reviewed this application. We cannot recommend for approval of this
application as currently proposed.
It is our opinion that the proposed facility design is not adequate for the following reasons:
1) According to the applicant, Howard Boatright, trucks containing wastes will enter the
facility and park on the concrete slab shown on the submitted drawing. The liquid wastes
transported in the trucks will be discharged by gravity flow from the trucks onto the slab.
The wastes will then flow across the slab into the trough. Once the truck has emptied all of
its wastes it will pull off the concrete slab and the next truck will pull into the same spot the
previous truck was just parked. We have two concerns with this design. They are:
A) A small percentage of the waste being discharged onto the concrete slab will be crude
oil. Truck traffic through the facility will "track" this material off of the concrete pad,
onto the gravel driveway, and possibly the County road. This creates not only an
aesthetic concern but also an environmental concern.
B) The majority of the waste being discharged onto the concrete slab will be composed of
water. During the winter months this water will freeze and likely create a build-up of
ice on the slab. This would create a safety hazard to employees of the facility, truck
drivers using the facility, and any other incidental personnel that may enter the facility.
An operator of an existing similar facility has confirmed that their facility experiences
this condition, during the winter months, when incidental water contacts their concrete
slab.
2) The application materials indicate that a 4 foot concrete block wall is proposed on both sides
of the concrete slab. In discussing whether the concrete block wall is adequate to contain
splashing during unloading with the applicant, he indicated that he was unsure if this was
adequate.
3) As presented in the application materials, the cement pit with 3 compartments does not
appear to be covered. We have two concerns with this design. They are as follows:
EXHIBIT
a
II
USR-1198
Page 2
A) Without a cover,people, birds, and animals, have the potential to fall into the pits. This
is a worker safety concern as well as a threat to wildlife. This is an area of concern with
the EPA as well as the U.S. Fish and Wildlife.
B) Open pits will create unnecessary odor. Liquid exploration and production wastes
typically emit odors that are offensive to some people.
4) The application materials do not provide the location of the proposed well. This should be
delineated in the application materials.
We recommend that the applicant either amend the design so that the off-loading portion of the
facility is similar to that which is currently in use at either of the existing Conquest Disposal
facilities, located in our County, or provide information or data that demonstrates that the
proposed design would perform equivalently. As you have observed, the Conquest facilities
pump wastes directly from the rear of the truck into holding tanks.
All of the above issues must be adequately addressed for us to consider a recommendation for
approval. As you are aware, I have discussed our concerns previously with Mr. Boatright and his
attorney, Jackie Johnson. Mr. Boatright indicated that he would provide our Department with
videos of similar facilities that are currently operating in Texas.
Please do not hesitate to have the applicant or his representative contact me if they have any
questions or concerns. If you have any questions, please do not hesitate to call me at extension
2232.
tj\1073
MEMORANDUM
TO: Scott Ballstadt, Current Planner II DATE: August 4, 1998
IFROM: Donald Carroll, Engineering Administrator x.
C.
COLORADO SUBJECT: USR-1198; Enviro-Cycle LLC/Howard Boatright
The Weld County Public Works Department has reviewed this proposal; the following requirements are
recommended to be a part of any approval:
COMMENTS:
WCR 39 is designated on the Transportation Plan Map as a Collector Status road requiring 80 feet of right-of-way
at full build out, there is presently 60 feet. The applicant is indicating an additional 10 feet of easement dedications.
This should be clarified on the plat as additional right-of-way. WCR 40 is designated as a local gravel road, both
these roads are maintained by Weld County.
REQUIREMENTS:
A 25-foot wide auxiliary road will be used for fire protection and emergency use only and will be approximately 400
feet west of the entrance.
The trucks will turn east at the end of the entrance road and enter onto a concrete grain slab. After depositing their
water, the trucks will move west across the slab and exit the facility through the main entrance.
The applicant is reserving an additional 10 feet of right-of-way adjacent to WCR 39 to accommodate future build
out of this road section. This will be identified on the plat and/or the deed in more detail.
A Road Improvements Agreement (off-site) needs to be in place to accommodate the additional upgrading and
paving through the main entrance for approximately 500±feet. This paving will be three inches thick and 24 feet
wide with four-foot gravel shoulders. This will minimize dust and maintenance due to the expansion, heavy hauling,
and the proximity to WCR 39. The existing gravel road measures 27 feet in width. The typical cross section will
be developed and placed on the plat of WCR 40 identifying width and depth of base and asphalt or full depth
asphalt.
Drainage culverts will be placed at both accesses to the facility. The drainage at the facility runs to a major holding
pond between the two access points, there is no outlet. It appears that the farm had been pumping from the lowest
spot to recycle the water. The applicant needs to provide a storm water drainage plan and identify how the water
will be handled. This could be accomplished by evaporation or pumping from this location.
On site parking appears to be adequate for the facility. Adequate radiuses are in place to accommodate the tractor
trailers. The remaining driving surface will be gravel which needs to be wetted, compacted an celled to provide
an adequate. Veld County Planning
AN 0 6 1998 EXHIBIT
RECEIV E i ,,
Page two
The applicant is indicating that the entrance road will taper to a 36-foot wide gravel road. All areas used by trucks
delivering water will be gravel. Dust will be controlled by the applicant of calcium chloride or magnesium chloride,
as needed.
cc: Commissioner Webster
USR-1198
plan11
La Salle lire Protection District
PHONE 97O-284-6336 • FAX 970-284-6042
August 10, 1998
Weld County Planning Dept.
Mr. Scott Ballstadt, Current Planner AUG 1 0 1998
Department of Planning Services
1700 C1olorado
radoAven8e
Greeley, Colorado 80631 RECEIVED
Mr. Ballstadt,
After reviewing the proposal submitted by Enviro-Cycle LLC/Howard Boatright I have
the following recommendations.
First of all there needs to be two fire hydrants installed at this facility. I have indicated
their location on the map provided. Hydrants shall be per La Salle Fire Protection District
specifications, see attached specification sheet. With the truck traffic at this facility it may
be necessary to place protective posts to prevent any vehicle damage to the hydrant.
Parking shall not be permitted within a fifteen foot radius of a fire hydrant. Hydrants shall
be located so that fire apparatus can drive broadside to within a distance of not more than
six feet from the pumper outlet of the hydrant.
I would also ask that a sign be attached to the office building listing phone numbers of
facility personnel to be contacted in the event of an emergency, and that the list be current
at all times. Also the La Salle Fire Department should be contacted after the facility is in
operation in order to participate in a training exercise and develop a preplan of the facility.
Thank you for the opportunity to comment on this proposal, if you have any questions
don't hesitate to give me a call.
S cerely��
a�
Gary Sandau, Fire Marshal
EXHIBIT
13
118 MAIN STREET P.O. BOX 414 LA SALLE, COLORADO 80645
,Ca Salle lire Protection District
PHONE 970-284-6336 • FAX 970-284-6042
FIRE HYDRANT SPECIFICATIONS
Fire Hydrants shall be installed and maintained so that the center of the
lowest water outlet is not less than twelve inches, nor more than thirty inches
from the ground. All hydrants, existing and future, shall be free from
obstructions a minimum of five feet in all directions. All hydrants shall be red
in color. All curbing in from of each hydrant shall be painted yellow for a
distance of fifteen feet from the center of the hydrant in both directions. All
hydrants shall have three outlets consisting of two -- two and one-half inch
hose outlets and one -- four and on-half inch pumper outlet. All threads shall
be American National Fire Hose Connection Screw Thread, abbreviated as
NH, NST or NS. All hydrants shall have a one and three-eighth inch pentagon
on the stem and on all caps. All hydrants shall have a shut off valve located in
front of the hydrant on the water line. Nothing less than a six inch water line
shall be attached to a fire hydrant. Minimum residual pressure of 20 p.s.i. at
the fire hydrants shall be required to provide minimum fire protection.
Weld County Planning Dept.
AUG 1 0 1998
RECEIVED
118 MAIN STREET P.O. BOX 414 LA SALLE. COLORADO 80645
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