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Home My WebLink About20210163.tiffRESOLUTION RE: APPROVE CERTIFICATE OF DESIGNATION, CD18-0001 - HIGH SIERRA WATER SERVICES, LLC, C/O NGL WATER SOLUTIONS DJ, LLC WHEREAS, the Board of County Commissioners of Weld County, Colorado, pursuant to Colorado statute and the Weld County Home Rule Charter, is vested with the authority of administering the affairs of Weld County, Colorado, and WHEREAS, on the 16th day of December, 2020, a public hearing was held in the Chambers of the Board of County Commissioners of Weld County, Colorado, for the purpose of considering whether to grant a Certificate of Designation, CD18-0001, to High Sierra Water Services, LLC, c/o NGL Water Solutions DJ, LLC, 3773 Cherry Creek North Drive, Suite 1000, Denver, Colorado 80209, said site to be located on the following described property: S1/2 SE1/4 of Section 30, Township 3 North, Range 65 West of the 6th P.M., Weld County, Colorado WHEREAS, at said hearing, on December 16, 2020, the matter was continued to January 20, 2021, to allow the Clerk to the Board adequate time to correct the notice deficiency, and, WHEREAS, on January 20, 2021, said applicant was present, and WHEREAS, said request for a Certificate of Designation, CD18-0001, was submitted in conjunction with an application for a Site Specific Development Plan and 3rd Amended Use by Special Review Permit, 3MJUSR18-07-1604, for Oil and Gas Support and Service, Solids Processing Facility for Exploration and Production wastes, pursuant to Colorado State Statute and as defined and regulated by the Colorado Department of Public Health and Environment, and continued use of the facilities to include, Class II Oilfield Waste Disposal Facility — Saltwater Injection Facility parking and maintenance for 18 NGL company produced water tankers and other operation support commercial vehicles; facility offices; outdoor storage of materials and equipment accessory to an allowed use (new, used and obsolete oil field equipment, including empty frac tanks and staging frac tanks), as long as the materials are screened from adjacent lots and rights -of -way; a company vehicle only wash bay, maintenance / mechanic shop, fueling station and accessory structures associated with the operation of the facility and up to 18 cargo (Conex) containers outside of subdivisions and historic townsites in the A (Agricultural) Zone District, which was approved by the Board, and WHEREAS, Section 30-20-104, C.R.S., requires the Board to take into account certain factors to approve a Certificate of Designation and, having taken into account said factors, finds as follows: 1. The effect that the solid wastes disposal site and facility will have on the surrounding property, taking into consideration the types of processing to be used, surrounding property uses and values, and wind and climatic conditions. The Conditions of Approval and Development Standards in Site Specific Development Plan and 3rd Amended Use by Special Review Permit, 3MJUSR18-07-1604, for Oil and Gas Support and Service, Solids Processing Facility for Exploration and CC: PL(mol77o), PW (Vhrn / OA), iµ(60 Cik A-00Iv,1 rte91. REP 1 tot aoaN 2021-0163 P L 1804 CERTIFICATE OF DESIGNATION (CD18-0001) - HIGH SIERRA WATER SERVICES, LLC, C/O NGL WATER SOLUTIONS DJ, LLC PAGE 2 Production wastes, pursuant to Colorado State Statute and as defined and regulated by the Colorado Department of Public Health and Environment, and continued use of the facilities to include, Class II Oilfield Waste Disposal Facility — Saltwater Injection Facility parking and maintenance for 18 NGL company produced water tankers and other operation support commercial vehicles; facility offices; outdoor storage of materials and equipment accessory to an allowed use (new, used and obsolete oil field equipment, including empty frac tanks and staging frac tanks), as long as the materials are screened from adjacent lots and rights -of -way; a company vehicle only wash bay, maintenance / mechanic shop, fueling station and accessory structures associated with the operation of the facility and up to 18 cargo (Conex) containers outside of subdivisions and historic townsites in the A (Agricultural) Zone District, will minimize the impacts on the surrounding property and the area to the greatest extent possible, and will also provide adequate protection of the health, safety, and welfare of the inhabitants of the area and the County. This facility has been in operation since 2007, when permitted for an oil and gas support and service facility (Class II Oilfield Waste Disposal Facility) for Marcum Midstream 1995-2 Business Trust. At the time of this permit, this operator had previously permitted five (5) other facilities. In the interim period, the facility has expanded its operations to include multiple oil field support and service activities. The facility has remained compliant with the Development Standards associated with the facility operation and, if complaints were received, prompt corrective action is taken to remedy the Conditions, including addressing the concerns of the neighbors. There have been no issues associated with noise, odor, or facility lighting during the tenure of operation. 2. The convenience and accessibility of the solid wastes disposal site and facility to potential users. The location of the proposed solid waste disposal site will be convenient and accessible to the potential users. There are three (3) facilities that are able to accept Exploration and Production (E&P) wastes: Waste Management North Weld Landfill, Waste Management Buffalo Ridge, Pawnee Waste and one (1) privately held company, Anadarko Petroleum Corporation, who operates a Land Farm located on County Road 32, who are able to take only their E&P wastes. The NGL Water Solutions DJ, LLC, C-6 facility is centrally located in the south-central area of the County and will be able to accept E&P wastes from any source providing a necessary service to the oilfield industry. 3. The ability of the applicant to comply with the health standards and operating procedures provided for in this part 1 and such rules and regulations as may be prescribed by the department. The applicant has demonstrated in the submitted application materials there is a need for the proposed solid waste disposal site. The applicant has demonstrated in the submitted application materials that the Use can comply with the Weld County Code. Further, the Colorado Department of Public Health and Environment (CDPHE) has recommended that the application be approved, with Conditions, because the use can comply with the rules and regulations of CDPHE. 2021-0163 PL1804 CERTIFICATE OF DESIGNATION (CD18-0001) - HIGH SIERRA WATER SERVICES, LLC, C/O NGL WATER SOLUTIONS DJ, LLC PAGE 3 4. Recommendations by local health departments. The Colorado Department of Public Health and Environment and the Weld County Department of Public Health and Environment have reviewed this request and find, subject to conditions, the proposal will comply with the Standards of the Solid Waste Disposal Sites and Facilities Act, C.R.S. §30-20-100.5, et seq. NOW, THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Weld County, Colorado, that a Certificate of Designation, CD18-0001, submitted in conjunction with an application for a Site Specific Development Plan and 3rd Amended Use by Special Review Permit, 3MJUSR18-07-1604, for Oil and Gas Support and Service, Solids Processing Facility for Exploration and Production wastes, pursuant to Colorado State Statute and as defined and regulated by the Colorado Department of Public Health and Environment, and continued use of the facilities to include, Class II Oilfield Waste Disposal Facility — Saltwater Injection Facility parking and maintenance for 18 NGL company produced water tankers and other operation support commercial vehicles; facility offices; outdoor storage of materials and equipment accessory to an allowed use (new, used and obsolete oil field equipment, including empty frac tanks and staging frac tanks), as long as the materials are screened from adjacent lots and rights -of -way; a company vehicle only wash bay, maintenance / mechanic shop, fueling station and accessory structures associated with the operation of the facility and up to 18 cargo (Conex) containers outside of subdivisions and historic townsites in the A (Agricultural) Zone District, on the hereinabove described real property be, and hereby is, granted subject to the following conditions: 1. The Financial Assurance Plan for closure costs of $232,915.00 shall be submitted to the Colorado Department of Public Health and Environment, Hazardous Materials and Waste Management Division (Division) for review and approval within three (3) months of the date of CD issuance. Please note that pursuant to the requirements of Section 1.8.3 of the Solid Waste Regulations, the closure and post -closure cost estimate must be adjusted annually to account for inflation or deflation by using the implicit price deflator for the gross domestic product. Additionally, the Facility must replace the original cost estimate every five (5) years, unless otherwise required by the Division. Both the annual adjustment and the five (5) -year update cost estimates must be submitted to the Division for review and approval. 2. The Applicant must install two (2) additional groundwater monitoring wells downgradient of the Solids Processing Facility and at locations approved by both the Division and Weld County. Well installation must be completed within six (6) months of the date of CD issuance. 3. Compliance with this CD requires the owner /operator comply with the attached EDOP and any future Department -approved Engineering Design and Operations Plan (EDOP) conditions, including both Department -approved amendments to the EDOP and Department -approved stand-alone plans necessary to comply with the Solid Waste Act and Regulations. Violation of the EDOP as so amended 2021-0163 P L 1804 CERTIFICATE OF DESIGNATION (CD18-0001) - HIGH SIERRA WATER SERVICES, LLC, C/O NGL WATER SOLUTIONS DJ, LLC PAGE 4 constitutes a violation of this CD. This CD need not be amended upon EDOP amendment unless required by Weld County. 4. CDPHE reserves the right to make unilateral modifications to the EDOP language and Conditions at any time during the life of the facility, including during the post closure care period. CDPHE will consult with the County prior to doing so. 5. The Facility must comply with the public health and environmental laws, standards, and regulations of the Department and all other applicable state, federal, and local rules, and ordinances, including requirements of the Air Pollution Control Division and Water Quality Control Division, which were outside the scope of the review conducted by the Solid Waste Program. 6. In addition to complying with the Division's Solid Waste Regulations, the Facility must comply with all relevant federal, state, and local regulations, including, but not limited to, the appropriate requirements of the Division of Water Resources, the Water Quality Control Division, and the Air Pollution Control Division. 7. Compliance with this Certificate of Designation (CD) requires the owner/operator maintain compliance with the approved USR Permit. 8. Compliance with this Certificate of Designation (CD) requires the owner/operator comply with the attached Engineering Design and Operations Plan (EDOP) and any future County and CDPHE Department -approved EDOP conditions, including both Department -approved amendments to the EDOP and Department -approved stand-alone plans necessary to comply with the Solid Waste Act and Regulations. Violation of the EDOP, as amended constitutes a violation of this CD. This CD need not be amended upon EDOP amendment unless required by the Weld County governing authority. 9. Any transfer or change in ownership or operator requires approval of a new application for a Certificate of Designation by the Board of County Commissioners, pursuant to Section 12-8-20.A.2 of the Weld County Code. 2021-0163 PL1804 CERTIFICATE OF DESIGNATION (CD18-0001) - HIGH SIERRA WATER SERVICES, LLC, C/O NGL WATER SOLUTIONS DJ, LLC PAGE 5 The above and foregoing Resolution was, on motion duly made and seconded, adopted by the following vote on the 20th day of January, A.D., 2021. BOARD OF COUNTY COMMISSIONERS WELD COUNTY, COLORADO ATTEST: ditAtA) Steve oreno, - air Weld County Clerk to the Board ames, Pro -T Attorney Date of signature: 02/10(2 2021-0163 PL1804 WELD COUNTY, COLORADO CERTIFICATE OF DESIGNATION In accordance with the provision of Sections 30-20-101 through 30-20-115, C.R.S., the Board of County Commissioners of Weld County, Colorado, hereby grants a Certificate of Designation, CD18-0001, submitted in conjunction with an application for a Site Specific Development Plan and 3rd Amended Use by Special Review Permit, 3MJUSR18-07-1604, for Oil and Gas Support and Service, Solids Processing Facility for Exploration and Production wastes, pursuant to Colorado State Statute and as defined and regulated by the Colorado Department of Public Health and Environment, and continued use of the facilities to include, Class II Oilfield Waste Disposal Facility — Saltwater Injection Facility parking and maintenance for 18 NGL company produced water tankers and other operation support commercial vehicles; facility offices; outdoor storage of materials and equipment accessory to an allowed use (new, used and obsolete oil field equipment, including empty frac tanks and staging frac tanks), as long as the materials are screened from adjacent lots and rights -of -way; a company vehicle only wash bay, maintenance / mechanic shop, fueling station and accessory structures associated with the operation of the facility and up to 18 cargo (Conex) containers outside of subdivisions and historic townsites in the A (Agricultural) Zone District. Location of Site: S1/2 SE1/4 of Section 30, Township 3 North, Range 65 West of the 6th P.M., Weld County, Colorado Name and Address of Responsible Operator: High Sierra Water Services, LLC c/o NGL Water Solutions DJ, LLC 3773 Cherry Creek North Dr., Suite 1000 Denver, CO 80209 This Certificate of Designation may be temporarily suspended or revoked, after reasonable notice and public hearing, for cause as outlined in Section 30-20-112, C.R.S. Issued this 20th day of January, 2021, at Weld County, Colorado. ATTEST: diddis) jelib;ok. Weld County Clerk BY: - _ Deputy Clerk to the Board Steve Moreno, Chair BOARD OF COUNTY COMMISSIONERS WELDOUNTY, COLORADO 2021-0163 PL1804 MEMORANDUM TO Board of County Commissioners DATE January 20, 2021 FROM Kim Ogle, Planning Services SUBJECT Modrfications to Certificate of Designation Resolution CD18-0001, High Sierra Water Services, LLC c/o NGL Water Solutions DJ, LLC Planning Services requests to add the following three (3) conditions to the Certificate of Designation, inserted as number 7, 8, 9 of the Board of County Commissioners Resolution 1 Compliance with this Certificate of Designation (CD) requires the owner/operator maintain compliance with the approved USR Permit 2 Compliance with this Certificate of Designation (CD) requires the owner/operator comply with the attached Engineenng Design and Operations Plan (EDOP) and any future County and CDPHE Department -approved EDOP conditions, including both Department -approved amendments to the EDOP and Department -approved stand-alone plans necessary to comply with the Solid Waste Act and Regulations Violation of the EDOP, as amended constitutes a violation of this CD This CD need not be amended upon EDOP amendment unless required by the Weld County governing authonty 3 Any transfer or change in ownership or operator requires notification of the Board of County Commissioners CD r--', U MEMORANDUM TO Board of County Commissioners DATE January 20, 2021 FROM Kim Ogle, Department of Planning Services SUBJECT Certificate of Designation, CD18-0001 in conjunction with 3MJUSRI8-07-1604, High Sierra Water Services, LLC dba NGL Water Solutions LLC High Sierra Water Services, LLC dba NGL Water ,Solutions LLC, 3773 Cherry Creek North Drive, Suite 1000, Denver, Colorado 80209 is requesting a Certificate of Designation (CD) for a site located on the following described property S2 SE4 of Section 30, Township 3, Range 65 West of the 6th P M , Weld County, Colorado located North of County Road 28, West of and adjacent to County Road 39 NGL Water Solutions is currently operating at the site under USR14-0081, a Site Specific Development Plan and Amended Use by Special Review, USR14-0081(formerly known as MUSR11-0004), for Mineral Resource Development Facilities, Oil and Gas Support and Service (Class II Oilfield Waste Disposal Facility —saltwater injection facility, water recycling, a truck tanker washout facility, mobile solids processing facility and a tank storage area with confinement NGL Water Solutions LLC has now applied for a Certificate of Designation, CD18-0001 pursuant to C R S §30- 20-104 and Weld County Code Chapter 12, Article VIII, in conjunction with an amendment to their USR (3MJUSRI8-07-1604) which would allow for a Solids Processing Facility for Exploration and Production (E&P) wastes pursuant to Colorado State Statute and as defined and regulated by Colorado Department of Public Health and Environment (CDPHE), and continued use of the facilities to include ongoing Oil and Gas Support and Service (Class II Oilfield Waste Disposal Facility -Saltwater Injection Facility), and to include the parking and maintenance for 18 NGL company produced water tankers and other operation support commercial vehicles, facility offices, outdoor storage of materials and equipment accessory to an allowed use (new, used and obsolete oil field equipment, including empty frac tanks and staging frac tanks), as long as the materials are screened from adjacent lots and rights -of -way, a company vehicle only wash bay, maintenance/mechanic shop, fueling station and accessory structures associated with the operation of the facility and up to 18 cargo (Conex) containers outside of subdivisions and historic townsites in the A (Agricultural) Zone District In accordance with Chapter 12, Article VIII, Section 12-8-20 A 1 the property owner and/or operator is required to seek approval of a Certificate of Designation from the Board of County commissioners when there is development of a new solid waste disposal site or facility The request was reviewed by the Colorado Department of Public Health and Environment, Hazardous Materials and Waste Management Division and in their letter dated December 23, 2019, which recommends that /he Facility may be approved by Weld County, which specified conditions Section 30-20-104 C R S requires affirmation that certain factors to approve a Certificate of Designation have been taken into account and consideration a The effect that the solid wastes disposal site and facility will have on the surrounding property, taking into consideration the types of processing to be used, surrounding property uses and values, and wind and climatic conditions This facility has been in operation since 2007 when permitted for an oil and gas support and service facility (Class II Oilfield Waste Disposal Facility) for Marcum Midstream 1995-2 Business Trust At the time of this permit, this operator had previously permitted five other facilities In the interim period the facility has expanded their operations to include multiple oil field support and service activities The facility has remained compliant with the Development Standards associated with the facility operation and if complaints were received prompt corrective action is taken to remedy the conditions, including addressing the concerns of the neighbors There have been no issues associated with noise, odor or facility lighting during the tenure of operation b The convenience and accessibility of the solid waste disposal site and facility to potential users The location of the proposed Solids Processing Facility for Exploration and Production wastes will be convenient and accessible to the potential users There are three facilities that are able to accept Exploration and Production (E&P) wastes, Waste Management North Weld Landfill, Waste Management Buffalo Ridge, Pawnee Waste and one privately held company, Anadarko Petroleum Corporation, who operates a Land Farm located on County Road 32 who are able to take only their Exploration and Production wastes The centrally located in the south-central area of the County NGL Water Solutions LLC C-6 facility will be able to accept E&P wastes from any source providing a necessary service to the oilfield industry c The ability of the applicant to comply with the health standards and operating procedures provided for in this part 1 and such rules and regulations as may be prescribed by the department The applicant has demonstrated in the submitted application materials that the use can comply with the Weld County Code Further, the Colorado Department of Public Health and Environment (CDPHE) has recommended that the application be approved, with conditions, because the use can comply with the rules and regulations of CDPHE d Recommendations by local health departments The Colorado Department of Health and the Weld County Health Department have reviewed this request and find, subject to conditions, the proposal will comply with the Standards of the Solid Waste Disposal Sites and Facilities Act, Section 30-20-100 5, et seq , CRS The Department of Planning Services recommends that the Board of County Commissioners approve the Certificate of Designation, CD18-0001 for High Sierra Water Services, LLC dba NGL Water Solutions LLC subject to the following conditions 1 The Financial Assurance Plan for closure costs of $232,915 shall be submitted to the Colorado Department of Public Health and Environment, Hazardous Materials and Waste Management Division for review and approval within 3 months of the date of CD issuance Please note that pursuant to the requirements of Section 1 8 3 of the Solid Waste Regulations, the closure and post -closure cost estimate must be adjusted annually to account for inflation or deflation by using the implicit price deflator for the gross domestic product Additionally, the Facility must replace the original cost estimate every five (5) years unless otherwise required by the Division Both the annual adjustment and the 5 -year update cost estimates must be submitted to the Division for review and approval 2 The Applicant must install two additional groundwater monitoring wells downgradient of the Solids Processing Facility and at locations approved by both the Colorado Department of Public Health and Environment, Hazardous Materials and Waste Management Division and Weld County Well installation must be completed within 6 months of the date of CD issuance 3 Compliance with this CD requires the owner /operator comply with the approved Engineering Design and Operations Plan (EDOP) and any future Department -approved EDOP conditions, including both Department -approved amendments to the EDOP and Department -approved stand-alone plans necessary to comply with the Solid Waste Act and Regulations Violation of the EDOP as so amended constitutes a violation of this CD This CD need not be amended upon EDOP amendment unless required by Weld County 4 Colorado Department of Public Health and Environment, Hazardous Materials and Waste Management Division reserves the right to make unilateral modifications to the EDOP language and conditions at any time during the life of the facility, including during the post closure care period CDPHE will consult with the County prior to doing so 5 The Facility must comply with the public health and environmental laws, standards, and regulations of the Department and all other applicable state, federal, and local rules, and ordinances, including requirements of the Air Pollution Control Division and Water Quality Control Division, which were outside the scope of the review conducted by the Solid Waste Program 6 In addition to complying with Colorado Department of Public Health and Environment, Hazardous Materials and Waste Management Division's Solid Waste Regulations, the Facility must comply with all relevant federal, state, and local regulations, including but not limited to the appropriate requirements of the Division of Water Resources, the Water Quality Control Division, and the Air Pollution Control Division 7 Compliance with this Certificate of Designation (CD) requires the owner/operator maintain compliance with the approved USR Permit 8 Compliance with this Certificate of Designation (CD) requires the owner/operator comply with the attached Engineering Design and Operations Plan (EDOP) and any future County and CDPHE Department -approved EDOP conditions, including both Department -approved amendments to the EDOP and Department -approved stand-alone plans necessary to comply with the Solid Waste Act and Regulations Violation of the EDOP, as amended constitutes a violation of this CD This CD need not be amended upon EDOP amendment unless required by the Weld County governing authority 10 Any transfer or change in ownership or operator requires notification of the Board of County Commissioners MEMORANDUM TO Board of County Commissioners DATE December 16, 2020 FROM Kim Ogle SUBJECT Certificate of Designation, CD18-0001 in conjunction with 3MJUSRI8-07-1604, High Sierra Water Services, LLC dba NGL Water Solutions LLC High Sierra Water Services, LLC dba NGL Water Solutions LLC, 3773 Cherry Creek North Drive, Suite 1000, Denver, Colorado 80209 is requesting a Certificate of Designation (CD) for a site located on the following described property S2 SE4 of Section 30, Township 3, Range 65 West of the 6th P M , Weld County, Colorado located North of County Road 28, West of and adjacent to County Road 39 NGL Water Solutions is currently operating at the site under USR14-0081, a Site Specific Development Plan and Amended Use by Special Review, USR14-0081(formerly known as MUSR11-0004), for Mineral Resource Development Facilities, Oil and Gas Support and Service (Class II Oilfield Waste Disposal Facility —salt water injection facility, water recycling, a truck tanker washout facility, mobile solids processing facility and atank storage area with confinement NGL Water Solutions LLC has now applied for a Certificate of Designation, CD18-0001 pursuant to C R S §30- 20-104 and Weld County Code Chapter 12, Article VIII, in conjunction with an amendment to their USR (3MJUSRI8-07-1604) which would allow for a Solids Processing Facility for Exploration and Production (E&P) wastes pursuant to Colorado State Statute and as defined and regulated by Colorado Department of Public Health and Environment (CDPHE), and continued use of the facilities to include ongoing Oil and Gas Support and Service (Class II Oilfield Waste Disposal Facility- Saltwater Injection Facility), and to include the parking and maintenance for 18 NGL company produced water tankers and other operation support commercial vehicles, facility offices, outdoor storage of materials and equipment accessory to an allowed use (new, used and obsolete oil field equipment, including empty frac tanks and staging frac tanks), as long as the materials are screened from adjacent lots and rights -of -way, a company vehicle only wash bay, maintenance/mechanic shop, fueling station and accessory structures associated with the operation of the facility and up to 18 cargo (Conex) containers outside of subdivisions and historic townsites in the A (Agricultural) Zone District In accordance with Chapter 12, Article VIII, Section 12-8-20 A 1 the property owner and/or operator is required to seek approval of a Certificate of Designation from the Board of County commissioners when there is development of a new solid waste disposal site or facility The request was reviewed by the Colorado Department of Public Health and Environment, Hazardous Materials and Waste Management Division and in their letter dated December 23, 2019, which recommends that the Facility may be approved by Weld County, which specified conditions Section 30-20-104 C.R.S. requires affirmation that certain factors to approve a Certificate of Designation have been taken into account and consideration. a The effect that the solid wastes disposal site and facility will have on the surrounding property, taking into consideration the types of processing to be used, surrounding property uses and values, and wind and climatic conditions. This facility has been in operation since 2007 when permitted for an oil and gas support and service facility (Class II Oilfield Waste Disposal Facility) for Marcum Midstream 1995-2 Business Trust. At the time of this permit, this operator had previously permitted five other facilities. In the interim period the facility has expanded their operations to include multiple oil field support and service activities. The facility has remained compliant with the Development Standards associated with the facility operation and if complaints were received prompt corrective action is taken to remedy the conditions, including addressing the concerns of the neighbors. There have been no issues associated with noise, odor or facility lighting during the tenure of operation. b The convenience and accessibility of the solid waste disposal site and facility to potential users. The location of the proposed Solids Processing Facility for Exploration and Production wastes will be convenient and accessible to the potential users. There are three facilities that are able to accept Exploration and Production (E&P) wastes, Waste Management North Weld Landfill, Waste Management Buffalo Ridge, Pawnee Waste and one privately held company, Anadarko Petroleum Corporation, who operates a Land Farm located on County Road 32 who are able to take only their Exploration and Production wastes. The centrally located in the south-central area of the County NGL Water Solutions LLC C-6 facility will be able to accept E&P wastes from any source providing a necessary service to the oilfield industry. c. The ability of the applicant to comply with the health standards and operating procedures provided for in this part 1 and such rules and regulations as may be prescribed by the department. The applicant has demonstrated in the submitted application materials that the use can comply with the Weld County Code. Further, the Colorado Department of Public Health and Environment (CDPHE) has recommended that the application be approved, with conditions, because the use can comply with the rules and regulations of CDPHE. d. Recommendations by local health departments. The Colorado Department of Health and the Weld County Health Department have reviewed this request and find, subject to conditions, the proposal will comply with the Standards of the Solid Waste Disposal Sites and Facilities Act, Section 30-20-100.5, et seq., C. R.S. The Department of Planning Services recommends that the Board of County Commissioners approve the Certificate of Designation, CD18-0001 for High Sierra Water Services, LLC dba NGL Water Solutions LLC subject to the following conditions: 1.. The Financial Assurance Plan for closure costs of $232,915 shall be submitted to the Division for review and approval within 3 months of the date of CD issuance. Please note that pursuant to the requirements of Section 1.8.3 of the Solid Waste Regulations, the closure and post -closure cost estimate must be adjusted annually to account for inflation or deflation by using the implicit price deflator for the gross domestic product. Additionally, the Facility must replace the original cost estimate every five (5) years u nless otherwise required by the Division. Both the annual adjustment and the 5 -year u pdate cost estimates must be submitted to the Division for review and approval. The Applicant must install two additional groundwater monitoring wells downgradient of the Solids Processing Facility and at locations approved by both the Division and Weld County. Well installation must be completed within 6 months of the date of CD issuance. Compliance with this CD requires the owner /operator comply with the attached EDOP and any future Department -approved EDOP conditions, including both Department -approved amendments to the EDOP and Department -approved stand-alone plans necessary to comply with the Solid Waste Act and Regulations. Violation of the EDOP as so amended constitutes a violation of this CD. This CD need not be amended upon EDOP amendment u nless required by Weld County. CDPHE reserves the right to make unilateral modifications to the EDOP language and conditions at any time during the life of the facility, including during the post closure care period. CDPHE will consult with the County prior to doing so. The Facility must comply with the public health and environmental laws, standards, and regulations of the Department and all other applicable state, federal, and local rules, and ordinances, including requirements of the Air Pollution Control Division and Water Quality Control Division, which were outside the scope of the review conducted by the Solid Waste Program. In addition to complying with the Division's Solid Waste Regulations, the Facility must comply with all relevant federal, state, and local regulations, including but not limited to the appropriate requirements of the Division of Water Resources, the Water Quality Control Division, and the Air Pollution Control Division. AS COLORADO Department of Public Health & Environment December 23, 2019 Board of County Commissioners Weld County 1150 0 Street PO Box 758 Greeley, CO 80632 Re: Recommendation of Approval with Conditions Application for Certificate of Designation NGL C6 Solids Processing Facility Weld County, Colorado SW/W LD/CON 2.1 Members of the Board, The Colorado Department of Public Health and Environment, Hazardous Materials and Waste Management Division (Division), received from Weld County, Colorado, a referral notification received on June 15, 2018 requesting the Division's review of an engineering design and operations plan (EDOP) for a new Certificate of Designation (Application) for operation of the C6 Solids Processing Facility in Platteville, Colorado. The Division conducted a completeness review and subsequent comprehensive technical evaluation of the EDOP. Division comments were shared with the Weld County Department of Public Health and Environment (WCDPHE). The Division reviewed the EDOP to determine its compliance with the requirements set forth in the Solid Waste Disposal Sites and Facilities Act, Title 30, Article 20, parts 1 and 10 (Solid Waste Act) of the Colorado Revised Statues (CRS), as amended, and with the regulations promulgated there under: the Regulations Pertaining to Solid Waste Sites and Facilities, 6 CCR 1007-2, Part 1 (Solid Waste Regulations). The Radiation Risk Assessment was reviewed by the Division's Radiation Control Program to ensure that the waste streams to be accepted by proposed Facility are appropriate for regulation under the Solid Waste Regulations and do not require licensing under the Radiation Control Regulations. The applicant delivered a complete, final revision of the EDOP, identified as Revision 1. A revised closure cost estimate was added. 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.8ov/cdphe Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director On November 6, 2019, the Division published a notice in the Greeley Tribune requesting written public comments on the NGL C6 Solids Processing Facility EDOP. The public comment period ended on December 6, 2019, and the Division received no comments. It is the determination of the Division that the NGL C6 Solids Processing Facility can comply with technical, environmental, and public health standards of the Solid Waste Act and the Solid Waste Regulations if the Facility is monitored and operated as stated in the CD Application and associated EDOP Rev. 1 and with the Division's conditions of recommendation as stated below in this letter Based on our review and determination, the Division recommends, with conditions, that the Facility may be approved by Weld County based on these and any local criteria. The final revised NGL C6 Solids Processing Facility Application including the final revised EDOP (Rev. 1) and final resolution containing the CD must be placed in the Facility's operating record. Our recommendation for approval of the Application including the final revised EDOP (Rev. 1) has the following conditions that must be incorporated into the CD if issued by Weld County: 1 The Financial Assurance Plan for closure costs of $232,915 shall be submitted to the Division for review and approval within 3 months of the date of CD issuance Please note that pursuant to the requirements of Section 1.8.3 of the Solid Waste Regulations, the closure and post -closure cost estimate must be adjusted annually to account for inflation or deflation by using the implicit price deflator for the gross domestic product Additionally, the Facility must replace the original cost estimate every five (5) years unless otherwise required by the Division Both the annual adjustment and the 5 -year update cost estimates must be submitted to the Division for review and approval 2. The Applicant must install two additional groundwater monitoring wells downgradient of the Solids Processing Facility and at locations approved by both the Division and Weld County Well installation must be completed within 6 months of the date of CD issuance 3. Compliance with this CD requires the owner /operator comply with the attached EDOP and any future Department -approved EDOP conditions, including both Department -approved amendments to the EDOP and Department -approved stand-alone plans necessary to comply with the Solid Waste Act and Regulations. Violation of the EDOP as so amended constitutes a violation of this CD This CD need not be amended upon EDOP amendment unless required by Weld County 4 CDPHE reserves the right to make unilateral modifications to the EDOP language and conditions at any time during the life of the facility, including during the post closure care period. CDPHE will consult with the County pnor to doing so. 1 5. The Facility must comply with the public health and environmental laws, standards, and regulations of the Department and all other applicable state, federal, and local rules, and ordinances, including requirements of the Air Pollution Control Division and Water Quality Control Division, which were outside the scope of the review conducted by the Solid Waste Program. As required by 30-20-104(3)(x) and (3)(b), Weld County is obligated to notify its citizens and conduct a public hearing regarding the proposed solid waste facility. Please forward a copy of the Weld County final resolution concerning the CD issuance or denial to the Division. Should you have any questions, please contact Andy Todd at (303) 691-4049 or by email at Andrew.Todd@state.coms. Sincerely, at( Andy Todd Solid Waste Permitting Unit Solid Waste and Materials Management Program Hazardous Materials and Waste Management Division ec: Kim Ogle Ben Frissell Garrett Clemons Weld County Planning Department Weld County Department of Health and Environment NGL Energy Partners LP Page 3 of 3 r�tyli 1a7.Or COLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado July 13, 2018 Garrett Clemons NGL Energy Partners 3773 Cherry Creek North Drive, Suite 1000 Denver, CO 80209 RE. Completeness Review Determination: Complete Application for Certificate of Designation (CD) C6 Solids Processing Facility Weld County, Colorado SW/WLD/CON 2.1 Dear Mr Clemons. The Colorado Department of Public Health and Environment, Hazardous Materials and Waste Management Division (Division), received from Weld County, Colorado, a referral notification received on June 15, 2018 requesting the Division's review of an engineering design and operations plan (EDOP) for a new Certificate of Designation (Application) for operation of the C6 Solids Processing Facility in Platteville, Colorado. The Division has reviewed the Application to determine its compliance with the requirements set forth in the Solid Waste Disposal Sites and Facilities Act, Title 30, Article 20, Parts 1 and 10 (Solid Waste Act) of the Colorado Revised Statutes (CRS), as amended, and with the regulations promulgated there under: the Solid Waste Regulations. In accordance with the Solid Waste Statute, CRS 30-20-103 (2), a "completeness review" of the Application is required within thirty (30) days of the Application referral from the local governing authority (Weld County). The Division has conducted the completeness review and has determined the Application to be complete. Please note that it is not the intent or purpose of a "completeness review" to imply anything concerning the final approval (or disapproval) of the Application In accordance with the Solid Waste Statute, CRS 30-20-103 (2), a "technical evaluation" of the Application is required after the completeness review has been conducted, and the Division has initiated the technical evaluation process The Division may request additional information in order to clarify aspects of the Application before completing the technical evaluation A formal recommendation of approval (or disapproval) of the Application per the Solid Waste Regulations will be made after the Division has completed 4300 Cherry Creek Dnve S , Denver, CO 80246-1530 P 303-692-2000 www colorado gov/cdphe John W Hickenlooper, Govemor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer Mr. Garrett Clemons July 13, 2018 Page 2 its technical review. The Division is authorized to bill for its review of technical submittals at $125 per hour, pursuant to Section 1.7 of the Solid Waste Regulations. The fee ceiling is $35,000 for the review of your Application, and the review can include time for the completeness review, the technical evaluation, associated meetings, other communications, and any other related items. An invoice for the Division's review of the subject document will be sent under separate cover. Enclosed is a 30 -Hour Billable Time Notification Waiver/Cease-Work Notice. Please check the appropriate box on this notice and sign and date the waiver. This notice should be returned to Andy Todd at HMWMD-B2 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Please note that the Department is authorized to bill for its review of technical submittals pursuant to Section 1.7 of the Regulations. An invoice for the Division's review of the above referenced documents will be transmitted under separate cover. Our fees and billing ceilings may be viewed online at https://www.Colorado.gov/pacificicdphe/solid- waste-regulations. Should you have any questions addressing the determinations herein please contact Andy Todd at (303) 691-4049 or by email at Andrew.ToddPstate.co.us. Sincerely, Andy Todd Solid Waste Permitting Unit Solid Waste and Materials Management Program Hazardous Materials and Waste Management Division ec: Joe Vargo Kim Ogle Ben Frissel i NGL Water Solutions DJ, LLC Weld County Planning Department Weld County Department of Health and Environment 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.govicdphe John W. Hickenlooper, Governor 1 Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer COLORADO Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado December 14, 2018 Mr. Garrett Clemons NGL Energy Partners 3773 Cherry Creek North Drive, Suite 1000 Denver, CO 80209 RE: Technical Evaluation Comments: Application for Certificate of Designation (CD) C6 Solids Processing Facility Weld County, Colorado SW/WLD/CON 2.1 Dear Mr. Clemons: The Colorado Department of Public Health and Environment, Hazardous Materials and Waste Management Division (Division), received from Weld County, Colorado, a referral notification received on June 15, 2018 requesting the Division's review of an engineering design and operations plan (EDOP) for a new Certificate of Designation (Application) for operation of the C6 Solids Processing Facility in Platteville, Colorado. In accordance with the Solid Waste Statute, CRS 30-20-103 (2), a "technical evaluation" of the Application is required after the completeness review has been conducted, and the Division completed an initial technical evaluation The Division submits the following comments and questions. Based on the applicant's responses, the Division may request additional information in order to clarify aspects of the Application before completing the technical evaluation. A formal recommendation of approval (or disapproval) of the Application per the Solid Waste Regulations will be made after the Division has completed its technical review Technical Review Comments 1) Section 1 3, pg 2, paragraph beginning with "In accordance with ". The 2nd sentence a couple specific disposal sites, but not the site where the Facility is currently sending most waste (per site visit). Because the list of disposal facilities permitted to take various wastes and various levels of TENORM, it is suggested that the 1St sentence is sufficient, but the 2nd sentence can be eliminated 4300 Cherry Creek Dnve S , Denver, CO 80246 1530 P 303 692 2000 www colorado gov/cdphe John W Hickenlooper, Governor I Kann McGowan, Intenm Executive Director 2) Sections 1.3 and 1.4 general. It is stated that the facility will accept TENORM wastes with up to 50 pCi/g (above background) of radium 226/228 combined There is no discussion of acceptance of TENORM wastes that may have uranium or thorium levels above 30 and 3 pCi/g (above background) respectively. Unless the EDOP and Risk Assessment are modified to accept higher levels of uranium or thorium, the EDOP should explicitly describe that wastes containing uranium and thorium above these levels will not be accepted. Refer also to Comment 11. 3) Section 2 1 2, last sentence. This sentence refers to a process flow diagram as Figure 1. Should it say Figure 4? 4) Section 4 0: This section describes a monitoring well system/layout that consists of groundwater monitoring wells MW -3 through -06 and an additional well to be located prior to construction of the Solids Processing Facility. Figures/Drawings 2 and 3 are referenced. A Is MW -07, shown on these figures, installed? If so, please update this section accordingly. B It is stated that groundwater flow direction is southeast towards monitoring wells MW -3 and -5 These wells would then be upgradient of the Solids Processing Facility. The location of MW -07 might be downgradient of the westernmost part of the Solids Processing Facility Please provide a current potentiometric surface map of the groundwater based on data Please describe plans and locations for additional wells that can monitor downgradient of the central and eastern parts of the Facility and detention pond, or provide a basis for the lack of such monitoring. C The last sentence of this section states that the Site Groundwater Monitoring Plan is included as Appendix E. Please correct to Appendix C, or as appropriate. 5) Section 6 0• This section generally describes that all wastes, wastewater and washwater will be solidified and disposed at an appropriate disposal facility Also buildings, process areas, and concrete will be demolished and disposed 6 CCR 1007-2, Part 1 (the Regulations) requires a cost estimate for a third party to complete these activities Please provide a defensible cost estimate as part of the EDOP After approval of the cost estimate, a mechanism for financial assurance must also be developed for approval Appendix C - Site Groundwater Monitoring Plan 6) Please update the initial 2 -page letter/plan, dated October 31, 2014, consistent with revisions to Section 4.0, per comment #4. 7) The last paragraph on the 1St page appears to have semi-annual and adjustment to quarterly reversed 4300 Cherry Creek Drive S , Denver, CO 80246 1530 P 303 692 2000 www colorado gov/cdphe John W Hickenlooper, Governor i Kann McGowan, Interim Executive Director 8) Please include, in Section 4.0 and/or in this appendix, an explicit requirement for submittal of monitoring reports to the CDPHE (and WCDHE if requested) 9) Please include boring and completion logs for each groundwater monitoring well. 10) Attachment A' It is noted that this plan generally falls short of describing all requirements for groundwater monitoring as required by 6 CCR 1007-2, Part 1 However, because of the nature of materials managed at the facility and the fact that the Solids Processing Facility is not a disposal facility, it believed to be usable. The analytes listed for water analysis should suffice for detection monitoring. The Division may unilaterally expand the list of analyses, should detection monitoring indicate impact to groundwater due to Facility operations A The "Groundwater Trend Analysis" Section states that "Any BTEX constituents above the COGCC maximum allowable concentrations (MACs) discovered in a monitoring well water quality sample will be reanalyzed ". Please change this to read "Any BTEX constituent detection will be reanalyzed ". All references to COGCC MACs shall be replaced with `detection' Appendix D — Radiological Dose Assessment 11) The radiological dose assessment report (the report) only evaluates the potential doses from 50 pCi/g of radium. Since there is no dose assessment on uranium or thonum, the facility cannot be authorized to receive any waste with natural uranium above 30 pCi/g (above background; default background = 2.4 pCi/g) and natural thorium above 3 pCi/g (above background, default background = 1 3 pCi/g), in accordance with CDPHE TENORM intenm policy and guidance dated February 2007 If the facility expects to receive wastes with uranium and thonum exceeding the above activity concentrations, the facility should provide risk assessments on the maximum uranium and thonum concentrations anticipated in the wastes to establish the appropnate acceptance cntena for uranium and thonum 12) The report indicates that radium -226 normally dominates the naturally occurring radium, so that the report only evaluates the potential doses from 50 pCi/g radium -226, even though the proposed limit of 50 pCi/g is for radium -226 and radium -228 combined. It is our understanding that radium - 228 could have substantial concentrations in the oilfield wastes and radium - 228 would actually result in more doses than radium -226 with the same activity concentration. Therefore, the report should evaluate the doses from 50 pCi/g of radium -228 as well. 13) The application indicates that NGL's customers in Weld County routinely produces wastes from oil and natural gas production The TENORM wastes from natural gas pipeline pigging operations could have elevated Pb- 210 and Po 210 (from radon) without elevated radium Since this report only 4300 Cherry Creek Dnve S , Denver, CO 80246-1530 P 303-692-2000 www Colorado gov/cdphe John W Hickenlooper, Governor I Kann McGowan, Interim Executive Director evaluates doses from radium, the facility cannot be authorized to receive wastes from natural gas pipeline pigging operations until a risk assessment specific to the anticipated level of Pb-210 and Po -210 in these wastes is provided and approved. 14) Section 3.2: we understand that dose from radon in the MSPB is not expected to be high due to the use of ventilation. However, we would like to see some quantitative assessment on the dose in this section. Please provide the following information: air exchange rate in the room, expected air radon level, expected emission rate of radon at the ventilation point, some more ventilation information (such as how often it is run, etc.), the maximum amount of material at any one time that will be exposed in the room, and any other useful information 15) Please provide a detailed description on worker activities in MSPB and explain how Worker A, B, and C and Table 3 are representative of real worker activities. 16) What is the difference between Figure 1 and 3, and the difference between Figure 2 and 4? Why is the conveyor location in Figure 1 and 2 different from the location in other figures? Please provide a detailed description on what Figure 1 and 2 are presenting. The Department is authorized to bill for its review of technical submittals pursuant to Section 1.7 of the Regulations. An invoice for the Division's review of the above referenced document will be transmitted under separate cover. Should you have any questions regarding the comments submitted herein please contact Andy Todd at (303) 691-4049 or by email at Andrew.Todd@state.co.us. Sincerely, Andy Todd Solid Waste Permitting Unit Solid Waste and Materials Management Hazardous Materials and Waste Management Division ec: Kim Ogle Ben Fri sse I l Environment MIS Weld County Planning Department Weld County Department of Health and 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.aov/cdphe John W. Hickentooper, Governor Karin McGowan, Interim Executive Director Weld County Referral June 11, 2018 The Weld County Department of Planning Services has received the following item for review Applicant NGL Water Solutions DJ, LLC Case Number CD18-0001 Please Reply By Planner Kim Ogle Project CERTIFICATE OF DESIGNATION FORA SOLIDS PROCESSING FACILITY ASSOCIATED WITH USR14-0081 A CLASS II BRINEWATER DISPOSAL FACILITY IN THE AGRICULTURE ZONE DISRICT Location NORTH OF AND ADJACENT TO CR 28 SECTION LINE AND WEST OF AND ADJACENT TO CR 39 Parcel Number 121330400017-R6787665 Legal S2SE4 SECTION 30, T3N, R65W of the 6th P M , Weld County, Colorado The application is submitted to you for review and recommendation Any comments or recommendation you consider relevant to this request would be appreciated Please reply by the above listed date so that we may give full consideration to your recommendation Any response not received before or oncthis date may be deemed to be a positive response to the Department of Planning Services If you have any further questions regarding the application, please call the Planner associated with the request Please note that new information may be added to applications under review during the review process If you desire to examine or obtain this additional information, please call the Department of Planning Services [] ix [] We have reviewed the request and find that it does /does not comply with our Comprehensive Plan because We have reviewed the request and find no conflicts with our interests See attached letter Signature Ben Friesen Agency WCDPHE Date 11/2/2020 Weld County Planning Dept 1555 N 17th Ave, Greeley, CO 80631 (970) 400-6100 (970) 304-6498 fax CERTIFICATE OF DESIGNATION (CD) APPLICATION DEPARTMENT OF PLANNING SERVICES * 1555 N. 17TH AVENUE * GREELEY, CO 80631 www.weldgov.com * 970-353-6100 EXT 3540 * FAX 970-304-6498 FOR PLANNING DEPARTMENT USE: AMOUNT $ APPLICATION RECEIVED BY DATE RECEIVED: CASE # ASSIGNED: PLANNER ASSIGNED: Parcel Number": Z. 3 - 3 Q - U - 0 _ O ( -1 Address of site: 13/51 luG{Z S9 Legal Description: 6Z. S�1-I Zone District: A Acreage: 1)0 Floodplain: Solid Waste. N Hazardous Waste: Y FEE OWNER(S) OF THE PROPERTY: Name: /VGL WgT£2 itvnonrs DJ, LLG Company: (*A 12 digit number on Tax I.D. information, obtainable at www.weldgov.com). Section: 30 Township: 3 N Range: Gc W Geological Hazard: Y Airport Overlay: Y Phone #: 305. sic. !d!O Email: 1Oil& WHIrf 1VGL.1P. CoM Street Address: 3773 OfigRy Catiw /lour-{ Die, City/State/Zip Code: Ptivulia , �'�C'j gOZpq N ame: Srt - lOOD Company: Phone #: Street Address: City/State/Zip Code: N ame: Email: Company: Phone #: Street Address: City/State/Zip Code: Email: APPLICANT OR AUTHORIZED AGENT: (See below: Authorization must accompany all applications signed by Authorized Ager` N ame: Company: Phone #: Email: Street Address: City/State/Zip Code: PROPOSED USE: otinikp WASTi Dc6p0154L FAci . niA OVGG.UplivG 34m04 -7-U2 DrsPcrs4t, F4611,47 -y, Soups PR enrci /iv6 P4atiry, CoatinciAL TRoce l��s��rs, 4av/) 1l/GLe QcwNno Mtiex •51046tA-6, A14 w Arr yivit-4/0t, Alive Fvv Lpuo • 051 wad._ /Aladin ritio EmPLO ytf BoNgivovsE 1. (We) hereby depose and state under penalties of perjury that all statements, proposals, and/or plans submitted with or contained within the application . t e and correct to the best of my (our)knowledge. Signatures of all fee owners of property must sign this application. If an Authorize • • - sig , a letter of authorization from all fee •wners must be included with the application. If a corporation is the fee owner, notariz- evid = ' ce t be it luded indicating that the • ignory has to legal authority to sign for the corporation. 3 /S7 re: d ner or Authorized Agent Da e P rint Name Signature: Owner or Authorized Agent Date Print Name Rev 3 3 DEPARTMENT OF PLANNING AND BUILDING DEPARTMENT OF PUBLIC HEALTH AND ENVIRONNMENT 1555 NORTH 17TH AVENUE GREELEY, CO 80631 AUTHORIZATION FORM FOR BUILDING, PLANNING AND HEALTH DEPARTMENT PERMITS AND SERVICES I, (We), NGL 10047'£e 6zitsurIOAA , give permission to AVA- (Owner — please print) (Applicant/Agent — please print) to apply for any Planning, Building or Health Department permits or services on our behalf, for the property located at: I315q Wcg 361 Legal Description: 52 S`LL{ of Section , Township 7j N, Range CoCW Subdivision Name: Al/4 Lot IWdC Block N/4 Property Owners Information: Phone: 3b3. $15'• /CIO E-mail: De•O&. lJHirj sgs NGtiP.coM Applicant/Agent Contact Information: Phone: N/A E -Mail: N/A Email correspondence to be sent to: Owner Applicant/Agent Both Postal service correspondence to be sent to: (choose only one) Owner ?* Applicant/Agent Additional Info: Owner Signature: Date: Owner Signature: Date: DESIGN AND OPERATIONS PLAN C6 Solids Processing Facility S ubmitted to: NGL Water Solutions Disposal Facility C6 SPF 13159 Weld County Road 39 Platteville, Colorado S ubmitted by: Marquez Environmental Services, Inc. 13860 Braun Rd. Golden, CO 80401 Distribution: 1 copy - 1 copy - 2 copies - 2 copies - N GL Water Solutions, Cherry Creek Office N GL Water Solutions, Dalton Sallee Weld County Dept. of Public Health and Environment, Heather Barbare Colorado Dept. of Public Health and Environment, David Snapp September 23, 2014 1400606 Revision 1 — November 5, 2014 C6 Solids Design and Operations Plan March 1, 2018 Table ®f Contents 1 0 INTRODUCTION 1 1 Overview 1 2 Processing Area Descnption and Location 1 3 Waste Acceptance Charactenzation 2 0 DESCRIPTION OF SOLIDS TREATMENT METHODS 2 1 Overview of Processing Sequence 2 1 1 Tank Bottoms 2 1 2 Solids Processing 2 2 On -site Recycling of Water 2 3 Off -site Transportation of Post -Processed Solids 2 4 Processing Rates 3 0 OPERATIONS PLAN 3 1 Overview 3 2 Above -ground Storage Tanks (ASTs) 3 3 Truck Offload Area 3 4 Water Management 3 5 Control Systems 3 6 Fire Protection 3 7 Sanitation 3 8 Ventilation and Air Pollution Control 3 9 On -site Chemicals 4 0 GROUNDWATER MONITORING 5 0 ANNUAL REPORTING 6 0 CLOSURE PLAN List of Tables Table 1 Solids Processing Facility Storage Tanks List of Figures Figure 1 Solids Processing Facility Process Flow Diagram 1 1 1 1 3 3 3 3 4 4 4 4 4 5 6 6 6 7 7 7 8 8 9 9 C6 Solids Design and Operations Plan March 1, 2018 List of Drawings Drawing 1 Drawing 2 Drawing 3 Drawing 4 Drawing 5 Drawing 6 Drawing 7 Drawing 8 Drawing 9 Drawing 10 Drawing 11 Drawing 12 Drawing 13 Drawing 14 Drawing 15 Drawing 16 Drawing 17 Drawing 18 Cover Sheet Overall Site Plan Site Plan _ Solids Processing Facility Solids Processing Facility — Process Flow Diagram OMITTED Process and Process and Process and Process and Process and Process and Process and Process and Process and Process and Process and Process and Detail Sheet Instrumentation Diagram (Sheet 1 of 12) Instrumentation Diagram (Sheet 2 of 12) Instrumentation Diagram (Sheet 3 of 12) Instrumentation Diagram (Sheet 4 of 12) Instrumentation Diagram (Sheet 5 of 12) Instrumentation Diagram (Sheet 6 of 12) Instrumentation Diagram (Sheet 7 of 12) Instrumentation Diagram (Sheet 8 of 12) Instrumentation Diagram (Sheet 9 of 12) Instrumentation Diagram (Sheet 10 of 12) Instrumentation Diagram (Sheet 11 of 12) Instrumentation Diagram (Sheet 12 of 12) List of Appendices Appendix A Storage and Solids Mass Balance Calculation Appendix B Spill Prevention Control and Countermeasure Plan Appendix C Site Groundwater Monitonng Plan Appendix D Radiological Dose Assessment C6 Solids Design and Operations Plan March 1, 2018 1 0 INTRODUCTION 1 1 Overview The NGL Water Solutions (NGL) C6 Facility is an existing oilfield water storage, truck yard, and Class II injection facility The C6 Facility is located approximately 1,000 feet north of the intersection of Weld County Rd 28 and Weld County Rd 39 and is in the northeast and southeast quarters of Section 30 Township 3 North, Range 65 West of the 6th Prime Mendian, in Weld County, Colorado, as shown in Figure 1 NGL plans to add a Solids Processing Facility to the existing C6 Facility to process drilling muds and tank -bottom fluids containing sediments This Design and Operations Plan (D&O Plan) addresses the addition of the Solids Processing Facility in conformance with requirements outlined in 6 CCR 1007-2 Section 8 5 1.2 Processing Area Description and Location The Solids Processing Facility will be located southwest of the existing C6 Facility A site layout showing the location of the Solids Processing Facility is included as Figure 2 The Solids Processing Facility will consist of a concrete unloading pad, main solids processing building, auxiliary solids processing building tank farm, and temporary solids staging shed The site will be accessed from the existing main entrance The solids processing facility consists of four designated areas 1) truck washout/unloading area, 2) main processing building, 3) auxiliary processing building, 4) tank farm, and 5) temporary solids staging area In addition, there will be auxiliary stationary equipment, consisting of one thermal oxidizer, one flare heat exchangers, chemical storage area, solids dewatenng platform with a filter press and associated tanks, and sludge storage tanks The solids processing facility will consist of multiple tanks varying in size within the processing building, individual containment areas, and a main secondary containment 1.3 Waste Acceptance Characterization The site will accept "Solid Waste" meaning drilling fluids, drilling muds, off spec oil, oily solids, oil based water, oil based mud, water based mud, storage tank sludge, tank bottoms, fluids containing solids, but excluding dry solids, drill cuttings and sand The following describes the anticipated characteristics of these materials pre -reaction and post -reaction Tank bottoms (pre -reaction tank) Up to 50% crude oil ■ Up to 10% solids (mostly sand) ■ The remaining content is brine IM Unloading pumps need to handle particles up to one -inch diameter, all pumps after that need to handle particles up to 500 microns i C6 Solids Design and Operations Plan March 1, 2018 ® Fluid temps from 40-110 degrees Fahrenheit ® pH 6-8 ® Specific gravity (S G ) up to 1 5 Tank Bottoms (post -reaction tank) a Up to 1% crude oil ® Up to 50% solids (fine particles dominate — bentonite and barite) The remaining content brine ® High and low molecular weight long chain polymers ® Unloading pumps need to handle particles up to one -inch diameter, all pumps after that need to handle particles up to 500 microns ® Viscosity up to 500 cP a Fluid temp of 180 degrees Fahrenheit ® Aries polymers added pH 5-7 The storage and solids mass balance calculation is included as Appendix A The E&P wastes at the C6 Facility are exempt from regulation as a hazardous waste under Subtitle C of the Resource Conservation and Recovery Act (RCRA) and 6 CCR 1007-3, Part 261 4(b)(5) Waste characterization for hazardous waste characteristics or analytes will not be conducted In accordance with the guidance presented In the CDPHE letter dated November 7, 2017 and titled "RE Manage and Disposal of TENORM Wastes Generated by Oil and Gas Exploration and Production," NGL will work with the receiving landfills to establish that the wastes fit the acceptance criteria of the landfills NGL can send waste to either the Waste Management Buffalo Ridge Landfill facility (Buffalo Ridge) or the Clean Harbors Deer Trail Landfill facility (Deer Trail) Deer Trail can accept TENORM wastes with elevated radionuclides, while Buffalo Ridge cannot At the present time (March 2018), NGL is taking samples every two weeks from the waste streams that go to off -site disposal NGL collects and analyzes composite samples of waste from two locations (1) the roll -off box that receive the solids from the shaker tables, and (2) the solids at the centrifuge The samples are analyzed for natural uranium, natural thorium, radium 226, and radium 228 All samples are analyzed on a dry weight basis, with results in pCi/gm Thorium and uranium are analyzed by ICP / mass spec Radium 226 & 228 are analyzed by gamma spectrometry Sample results will be compared to background levels for each analyte Elevated levels (>3 pCi/gm above background for Radium and Thorium, and >30 pCi/gm above background for Uranium) would require the waste to go to a landfill that can handle TENORM wastes It is not anticipated that the laboratory results will exceed 50 pCi/gm above 2 C6 Solids Design and Operations Plan March 1, 2018 background for combined Radium 226 & 228 If the laboratory results exceed this level, additional characterization and an alternative waste disposal method may be required As the levels of radionuclides become established, it is expected that NGL can reduce the frequency of sampling to annually, again working with the landfills to establish the acceptable sampling frequency NGL may elect to change the landfills that take the wastes, if additional landfill options become available The C6 facility will require all generators to certify the types of wastes that are sent to the facility All generators have analyzed for natural uranium, natural thonum, radium 226, and radium 228 No waste streams that exceed 50 pCi/gm above background for combined Radium 226 & 228 will be accepted at the facility 1 4 Radiological Dose Assessment A radiological dose assessment was performed for the C6 facility See Appendix D The radiological dose assessment concluded that the NGL Solids Waste Processing Facility can accept TENORM in wastes up to 50 pCi per gram radium 226 / 228 and maintain radiological exposures below current CDPHE guidance 2.0 DESCRIPTION OF SOLIDS TREATMENT METHODS The solids processing facility consists of four designated areas 1) truck washout/unloading area, 2) main processing building, 3) auxiliary processing building, 4) tank farm, and 5) temporary solids staging area In addition, there will be auxiliary stationary equipment, consisting of one thermal oxidizers, heat exchangers, chemical storage area, solids dewatenng platform with a filter press and centrifuge, and associated tanks, and sludge storage tanks The solids processing facilities will consist of multiple tanks varying in size from 50 bbls to 840 bbls within the processing building, individual containment areas, and a main secondary containment Trucks will offload waste into offload shakers that will assist in removing large particles from the waste Solids from the shakers will be contained in a roll -off dumpster adjacent to the shakers and taken directly off site to an approved landfill 2 1 Overview of Processing Sequence Piping will be composed of PVC or flex hoses 2.1.1 Tank Bottoms Tank bottoms will be offloaded, passed through a one -inch strainer, and pumped for storage in four tank bottoms ASTs within the tank farm (four additional tanks will be installed at a later date) From the ASTs, the tank bottoms will be pumped through heat exchangers and coagulant and polymer will be 3 C6 Solids Design and Operations Plan March 1, 2018 mechanically added to aid in the sedimentation process In the future the tank bottoms may be placed in a reaction tank for this process The tank bottoms will then be pumped into a decanter centrifuge where a polymer will be mechanically added to further assist in the removal of solids Solids from the decanter centrifuge will be transferred to the solids temporary staging shed The piping connecting the oil tanks and the piping that runs downstream of the heat exchangers will be constructed of steel All other associated piping will be composed of PVC or flex hoses for the offload pumps and shale shaker inlets 2 1.2 Solids Processing Solids will typically be removed from incoming waste in the centnfuges and transferred via a conveyor belt system to the solids temporary staging shed Incoming waste may also be processed through a filter press to remove solids The filter press is intended to be used as a backup (standby) system, with the centrifuge acting as the primary dewatenng system Solids from the decanter centrifuge will be transferred to the solids temporary staging shed The fluids will continue to move into the centrate/filtrate tanks where oil and water separation occurs Oil will be pumped to six oil tanks in the tank farm where it is eventually removed by vacuum trucks on a regular basis and sold offsite The water in the centrate/filtrate tanks will be pumped out into the five water tanks within the tank farm and pumped to the existing on -site water from the tank farm and will be transferred to the existing Class II injection facility A process flow diagram for the facility is shown in Figure 1 2 2 On -site Recycling of Water Treated water from the solids processing facility tank farm will be pumped via an underground PVC double -walled 8 -inch -diameter pipe to the existing on -site Class II Injection facility A 8 -inch -diameter PVC pipe within a 6 -inch -diameter PVC pipe may also be used The pipe(s) will be sloped towards the water disposal facility 2 3 Off -site Transportation of Post -Processed Solids Solid waste from the solids processing facility will be transferred to the solids temporary staging shed and may be temporarily stored in a roll -off container As needed, the stored solid waste will be disposed of off - site at an approved landfill 2 4 Processing Rates The C6 Solids Processing Facility is designed to receive a peak daily flow of approximately 8,000 barrels per day (bdp) This receiving flow will be comprised of tank bottoms (approximately 3,500 bpd), drilling muds (approximately 3,500 bpd), and an additional flow for truck wash -down (approximately 1,000 bpd) Flows from these sources vary in oil content from 1 to 50%, and solids content from 1 to 15% 4 C6 Solids Design and Operations Plan March 1, 2018 3.0 OPERATIONS PLAN 3.1 Overview The solids processing facility consists of four designated areas 1) truck washout/unloading area, 2) main processing building, 3) auxiliary processing budding, 4) tank farm, and 5) temporary solids staging area In addition, there will be auxiliary stationary equipment, consisting of one thermal oxidizers, heat exchangers, chemical storage area, solids dewatenng platform with a filter press and centnfuge, and associated tanks, and sludge storage tanks The solids processing facility will consist of multiple tanks varying in size from 50 bbls to 840 bbls within the processing building, individual containment areas, and a main secondary containment Power for the site will be sourced from the local electric grid The facility will be controlled by numerous automatic level instrumentation devices that communicate with a plant programmable logic controller (PLC) with alarms and will be manned 24 hours a day and 7 days a week 3.2 Above -ground Storage Tanks (ASTs) All facility ASTs outside of the covered processing buildings will be within secondary containment areas sized to hold 1 25 times the volume of the largest tank in each area with an additional volume for freeboard for precipitation The secondary containment structures will be constructed of a concrete slab with rebar reinforcement and a containment curb placed on prepared subgrade and are designed to be adequately leak proof to prevent oil from escaping before cleanup can occur The pad will be sloped around each AST at a 2% grade over a distance of 10 feet towards a drainage sump Waste collected in the drainage sumps will be pumped back to the head of the process The Solids Processing Facility encompasses eight ASTs ranging in size from 598 gallons to 16,800 gallons (filter press and ASTs 40-01 thru 50-05) Additionally, the Solids Processing Facility tank farm contains four drilling mud tanks (AST 10-01 thru AST 10-04), four tank bottoms tanks (AST 20-01 thru 20- 04), four off -spec tanks (AST 30-01 thru 30-04), six oil tanks (AST 70-01 thru 70-06), and five water tanks (AST 60-01 thru 60-05) Chemical storage bins will be located inside the processing building The proposed ASTs layout is shown in Drawing 3 The following table details the storage tanks located at the Solids Processing Facility Table 1 Solids Processing Facility Storage Tanks Tank Identification Total Capacity (gallons) - Contents Description ASTs 10-01 through 10-04 67,200 Exploration and Production water Drilling mud tanks Single -wall steel shop fabricated vertical ASTs within main concrete containment ASTs 20-01 through 20-04 67,200 Exploration and Production water Tank bottoms tanks Single -wall steel shop fabncated vertical ASTs within main concrete containment 5 C6 Solids Design and Operations Plan March 1, 2018 Tank Identification Total (gallons) Capacity Contents Description ASTs 30-01 through 30-04 . 67,200 Condensate Off fabricated concrete -Spec tanks. vertical containment. Single ASTs -wall within steel main shop ASTs 40-01 and 40-02 12,600 Process Water Reaction reinforced ASTs containment. within tanks. plastic the Single shop processing wall fabricated fiberglass building vertical ASTs 50-01 and 50-02 4,200 Process Water Centrifuge fiberglass vertical containment. reinforced ASsT capture within tanks. the plastic processing Single shop wall fabricated building ASTs 50-03 thru 50-05 50,400 Process Water Centrate wall fabricated processing fiberglass — vertical Filtrate building reinforced capture ASTs containment. plastic within tanks. the shop Single ASTs 60-01 thru 60-05 176,400 Exploration Production and water Brine reinforced ASTs tanks. within plastic Single main shop concrete wall fiberglass fabricated containment. vertical AST 65-01 5,000 Water Reverse wall fabricated concrete fiberglass osmosis containment. vertical reinforced permeate AST within plastic tank. main shop Single ASTs 70-01 thru 70-06 100,800 Oil i Oil vertical containment. Tanks. ASTs Single within -wall steel concrete shop fabricated main 3.3 Truck Offload Area The truck offload area will consist of an approximately 82 -foot by 100 -foot concrete pad with four centrifugal unloading pumps. There will be bollards surrounding the pumps at each truck lane. 3.4 Water Management The facility will take the steps necessary to control and prevent the discharge of contaminated water from the processing areas. Any water (e.g., stormwater, waste water, etc.) that has come into contact with waste will be managed as contaminated water. Contaminated water will not be discharged from the site without specific CDPHE authorization. Furthermore, the processing areas will not discharge solid wastes or pollutants into waters of the United States. The generation of contaminated water will be minimized by the combination of site grading (directing run-on away from the site) and containment berms to intercept and divert stormwater. Any contaminated water will be treated at the facility. The Stormwater Management Plan and Spill Prevention Control and Countermeasure (SPCC) Plan are provided in Appendix B and C. respectively. 6 C6 Solids Design and Operations Plan March 1, 2018 ' 3.5 Control Systems The facility will be controlled by an Allen Bradley Programmable Logic Controller (PLC) system with a HMI operator interface Multiple data points will be recorded All flows and tank levels will be monitored The level of the chemical totes can be observed through the clear bins and tank levels will be measured with non -contact radar level gauges An immediate loss in drum or tank weight will initiate an alarm All pH values and chemical feeds will be automated Each 12 -hour shift will be manned by two operators with additional manpower spread across several shifts to assist with dewatenng 3.6 Fire Protection , In the event of a fire at the processing facility, operators will assess the extent of the fire and the potential for the fire to spread The following actions would be taken ■ Apply water using a water truck or hose, ■ Use a fire extinguisher, or ■ Contact the local fire department (telephoning 911) Hand -operated fire extinguishers will be located throughout the building Employee orientation will include ' fire extinguisher instruction and location 3.7 Sanitation The processing facility areas will be washed down as necessary Areas will be kept tidy by sweeping the floor area and washing down equipment to maintain sanitary conditions Wash water will be collected within floor drains in the auxiliary process building and main process building and will be piped to sumps The floors of the auxiliary process building and main process building will be sloped to drain towards floor drains Sump pumps will then send wash water back to the head of the process Solids from the decanter centrifuge will be transferred to the solids temporary staging shed via an enclosed conveyor belt, which will include side guards and dust curtains to enclose the system from the external environment and will prevent meteoric precipitation from entering the processed solids A concrete pad will be located under the conveyor belt to collect any solids that may fall off the belt These solids will be periodically washed into the trench drain Waste collected in the drain will be pumped back to the head of the process Potable water and sanitary facilities will be provided for employees and visitors within the office building at the site C6 Solids Design and Operations Plan March 1, 2018 3.8 Ventilation and Air Pollution Control No significant odors or air pollution emissions are expected to result from the facility Care will be taken to minimize potential fugitive dust from the facility If nuisance odors are detected at the facility boundary, the site will take action to abate the nuisance Any vapors from oil storage tanks and tank bottoms storage tanks will be positively ventilated to the regenerative thermal oxidizer, or a flared IV a for treatment The Construction Air Permit Modification Application is included as Appendix D 3 9 On -site Chemicals All the chemicals that will be used in the treatment at the solids processing facility are National Science Foundation -approved chemicals for the treatment of potable water The following is a list of the main chemicals to be used, but is subject to change as required to meet treatment goals ® Aries 3456 Ionic Poylmer II Mxeb 1022 Emulsion breaker ® Perlite Bulk storage tanks will be labeled and an NFPA symbol will be displayed on each tank Appropriate MSDS/SDS information will be located in the main office 4 0 GROUNDWATER MONITORING There are four existing groundwater wells (MW -3, MW -4, MW -5, and MW -6) that have been installed and are monitoring the existing C6 facility An additional well will be installed downgradient and adjacent to the solids processing facility area to monitor groundwater Existing monitoring wells are shown in Drawing 2 The location of the additional monitoring well will be determined before construction of the solids processing facility An approximate location is shown in Drawing 3 The additional monitoring well will be drilled and one sampling event will be completed before the solids processing facility begins processing waste The existing monitoring wells were installed to a depth of approximately 30 to 53 feet below ground surface (bgs) The wells were constructed with approximately 25 to 35 feet of 2 -inch -diameter, 10 -slot PVC screen, and approximately 10 to 23 feet of solid PVC riser based on the depth to groundwater in each well location 10/20 silica sand surrounds the screened portion of the wells to a depth of 2 feet above the well screen, at which point the well bore is sealed with hydrated bentonite to the surface The_ wells are finished with either a flush -mounted steel manway or a 3 -foot aluminum locking stick up mount The subsurface lithology generally consists of alternating layers of sand and silty sand to sandy/silty clay and clay from the surface to approximately 20 to 41 feet bgs Starting at approximately 20 to 41 feet bgs, weathered blocky claystone with secondary calcareous and iron oxide mineralization was observed to the total depth of the borings 8 C6 Solids Design and Operations Plan March 1, 2018 Quarterly groundwater quality monitoring has been ongoing since November 2007, and has recently been adjusted to a semi-annual monitoring schedule per the suggestion of the Weld County Department of Public Health and Environment. Historic groundwater monitoring data indicates groundwater depths across the site vary from approximately 14 to 29 feet below the top of the surveyed well casings. Data indicates a consistent groundwater flow direction to the southeast towards monitoring wells MW -5 and MW -3 at a calculated hydraulic gradient of 0.05 ft/ft. Methods and procedures for field and reporting activities are provided in the Site Groundwater Monitoring Plan, included as Appendix E. 5.0 ANNUAL REPORTING An annual report will be submitted to CDPHE and Weld County and will contain the following information: ■ Characterization of accepted wastes. ■ Documentation of the monthly visual inspection of the facility to check for signs of possible defects or damage. The access lanes, unloading area, containment berm, wash pad, and storage tank(s) will also be visually inspected. The inspections will be documented and records maintained. ■ The containment area will be inspected monthly for signs of subsidence, ponding, and/or erosion, and repairs made as necessary to maintain the intent of the design as described in the Stormwater Management Plan and Spill Prevention Control and Countermeasure (SPCC) Plan. ■ If damage or defect to any of these components is found during the inspection, repairs will be initiated and completed as soon as possible. The observations and repairs will also be recorded. ■ Documentation of the monthly volume in barrel (BBL) injected in Class II well. 6.0 CLOSURE PLAN Prior to closure of the solids processing facility, a notice of closure will be published in a local newspaper of general circulation and posted at all facility access points. CDPHE will also be notified prior to the closure of the facility. Any remaining unprocessed waster will be processed or solidified as needed to pass the paint filter test and will be transported to an approved landfill. The equipment, buildings, process areas, and concrete containment areas will be washed down. The wash waters will be collected and disposed of in an appropriate manner. Equipment will be removed from the site, buildings, and process areas, and concrete containment areas will be demolished. The demolition waste will be disposed of in an approved landfill. The site will be graded to maintain positive drainage and the disturbed areas revegetated. SOLIDS PROCESSING FACILITY C6 DISPOSAL FACILITY PLATTEVILLE, COLORADO 4•CR 44 Si !~ - + -► - I_ 0 • 4 4c a Om wCR 34 • _ J I I • z tI at t! - I I N I I I - wco 30 - 4 I WCR 24 - - • • (- INCR 24 L LL 1 • west it ss i R-1 • w CR- C6 SITE I I I — L. — — — I I 41- -Q t SCR 24 1 I *MR 40- - WCR N - • • - sal 12 - -- N i • I i t k • WC M' 4 vrt:R-x w SITE LOCATION MAP PREPARED FOR NGL WATER SOLUTIONS C6 DISPOSAL FACILIITY 13159 WELD COUNTY ROAD 39 PLATTEVILLE, COLORADO PREPARED BY M3 CONSTRUCTION 2861 WEST 120TH AVENUE WESTMINSTER, COLORADO AND GOLDEN ASSOCIATES 44 UNION BOULEVARD LAKEWOOD, COLORADO AND MARQUEZ ENVIRONMENTAL SERVICES. INC 13860 BRAUN ROAD GOLDEN COLORADO LIST OF DRAWINGS DRAWING NO. REVISION TITLE 1 COVER SHEET C 2 OVERALL SITE PLAN A 3 SITE PLAN - SOLIDS PROCESSING FACILITY A 4 SOLIDS PROCESSING FACILITY - PROCESS FLOW DIAGRAM A 5 OMITTED NA 6 A PROCESS AND INSTRUMENTATION DIAGRAM (SHEET 1 OF 12) 7 A PROCESS AND INSTRUMENTATION DIAGRAM (SHEET 2 OF 12) 8 PROCESS AND INSTRUMENTATION DIAGRAM (SHEET 3 OF 12) A 9 PROCESS AND INSTRUMENTATION DIAGRAM (SHEET 4 OF 12) A 10 PROCESS AND INSTRUMENTATION DIAGRAM (SHEET 5 OF 12) A 11 A PROCESS AND INSTRUMENTATION DIAGRAM (SHEET 6 OF 12) 12 PROCESS AND INSTRUMENTATION DIAGRAM (SHEET 7 OF 12) A 13 PROCESS AND INSTRUMENTATION DIAGRAM (SHEET 8 OF 12) A 14 PROCESS AND INSTRUMENTATION DIAGRAM (SHEET 9 OF 12) A 15 A PROCESS AND INSTRUMENTATION DIAGRAM (SHEET 10OF 12) 16 A PROCESS AND INSTRUMENTATION DIAGRAM (SHEET 11 OF 12) 17 A PROCESS AND INSTRUMENTATION DIAGRAM (SHEET 12 OF 12) 18 DETAIL SHEET B 0 20 40 x b 100 SC4LE M FEET PREPARED FOR NGL WATER SOLUTIONS LLC DENVER. CO PREPARED BY MARQUEZ ENVIRONMENTAL SERVICES, INC. 13860 BRAUN ROAD GOLDEN, COLORADO C6 SOLIDS PROCESSING FACILITY PLATTEVILLE, COLORADO FIGURE 1 COVER SHEET REVISION C CIA INJECTKAI INElt -1350 ►EFT ',VEST SOLIDS PROCESSING PACKET', N CONCRETE CONTAINMENT DICE NCl TANKS NEENN CONCRETE SECONDAR, C ONTANMENT FUEL STORAGE isECTX*4 WEII IDLE TANK FARM N CCNORETE CONTAINMENT DWI MOT N USE, LOADNGAALOAONC ►AO BRAN IOADNv'.VNLOADNG PAD CEPAA TLRE ABOVEGROUND PIPING MAN SOLD! PROCESSING BLROIW CONCRETE CONTAINMENT • ICC GAL DIESEL TANK K SHOO OVMPSTER CONTAINMENT satin STORAGE WRONG CONCRETE CONTAINMENT OFTEN iNy PC7NC b I ]CONCRETE CONTAINMENT DICE NrrML WATER TREATAIENT -PACKET', *CONCRETE CCHT ANMENT DICE 1< 0 A AO 6C e0 r( SCALE IN FEET PREPARED FOR NGL WATER SOLUTIONS LLC DENVER. CO PREPARED BY MARQUEZ ENVIRONMENTAL SERVICES, INC 13850 BRAUN ROAD GOLDEN COLORADO SECURITYCAMERA SURFICIAL FLOW DIRECTION WATER SPIGOT ELECTRICAL TRANSFORMER SPILL KIT STREET UGHT INDICATES APPLICABLE AREA WITHIN SECONDARY CONTAINMENT FENCE LINE STAIRS / CATWALK OXIDIZER BOLLARD 2000 GALLON SEPTIC TANS C6 SOLIDS PROCESSING FACILITY PLATTEVILLE. COLORADO FIGURE 2 OVERALL SITE PLAN REVISION A DOMESTIC WATER .4 WELL LOADING/UNLOADING PAD APPROACH i tit -1."••••••.. f A SUMP W SOLIDS PROCESSING FACILITY IN CONCRETE CONTAINMENT DIKE t • WATER LOADING (NOT W USE) LOADING/UNLOADING PAD DRAIN LOADING/UNLOADING PAD DEPARTURE ABOVEGROUND /��PIPING 00 THER _••11," UMP • wW SOLIDS r• x f SUNG WIIDhG tams \ 18" CULV68T 1/4 viii... -- CONVEYOR BELT 4EF Plf4 L CONCRETE CONTAINMENT w t ABOVEGROUND PIPING r - P - - sumPP Sal* EION.ACif Et K CHG •••••••► CONCRETE CONTAINMENT r oor DUMPSTER CONTAINMENT • • • • r • • • • x • • • • K • • • — • • • • • •• •• • PROPANE TANK - V • I. r .-: �icet • s • P re - n. - *.F :OA ivEcc• nJj. ';ray' .. ;. b O I0 x X M SE SCALE P. FEE'. • • MW -3 ® SPF PSMP O SSMF O a IMMP •5 —x— LEGEND MONITORING WELL LOCATION PAD SUB -SUMP MONITORING POINT SUB -SUMP MONITORING POINT OXIDIZER ELECTRICAL TRANSFORMER 2000 GALLON SEPTIC TANK SURFACE FLOW DIRECTION SECURITY CAMERA SPILL KR OVERHEAD LIGHT BOLLARD FENCE INDICATES APPLICABLE AREA WITHIN SECONDARY CONTAINMENT MAP a asIZE 3 � PROCESS 1 780 PY1 2 780 PW 3 780 PW 4 780 PW 5 780 PW 5 400 OIL 7 400 OIL 8 400 OIL 9 400 OIL 10 400 OIL 11 400 OIL 12 400 OIL. 13 400 OIL 14 400 OIL 15 400 OIL 16 400 OIL 17 400 OIL 18 400 OIL 19 400 OIL 20 400 OIL 21 400 OIL 22 400 OIL 23 400 OIL 24 300 FERRIC AGO 25 400 CENTRATE/FILTRATE 25 400 CENTRATE/FILTRATE 27 400 CENTRATE/FILTRATE 28 200 REACTION TANK 29 32 PERLITE TANK 30 37 PERLITE TANK 31 33 5LURRIFK:ATION TANK 32 33 SIURRIFICAnoN TANK 33 126 PERMEATE TANK 34 90 BRINE TANK 35 90 BRINE TANK 36 500 SHAKER TANK PREPARED FOR NGL WATER SOLUTIONS LLC DENVER. CO PREPARED BY. MARQUEZ ENVIRONMENTAL SERVICES. INC 13880 BRAUN ROAD GOLDEN COLORADO C6 SOLIDS PROCESSING FACILITY PLATTEVILLE, COLORADO FIGURE 3 SITE PLAN SOLIDS PROCESSING FACILITY REVISION A SHAKER SOUDS DUMPSTER IHOT PLANT WATEI i FROM RECYCLE WATER SYSTEM _ I CONTAINMENT AREAS OUTSIDE r DRILLING MUD WASTE 00 O O TRANSFER PUMP H T O\ \ (TYP ) UNLOADING IIQ� PUMP" b O �I0I TRUCK WASHOUT > 5J SLOPED TRENCH 'HATER CATCH BASIN (COVERED) TANK BOTTOMS WASTE 00 O O L NOTES PROCESS FLOW DIAGRAM INFORMATION PROVIDED BY M3 CONSTRUCTION(SEPTEMBEEL 2014 AND IS RESPONSIBLE FOR THE CONTENTS OF THIS DRAWING O FLARE LIQUID CATCH BASIN pi�I-p I Dr 6w� MUD :TORAG? O FF�SPE� STORAG' TANK BOTTOMS STORAGE F PROCESS BULLDINGS INSIDE Q__j RROO P°RMEATE O O V I USED AS PLANT iATER THROUGHOUT N THE FACIUTY 1 0 g DECANTER CENTRIFUGE 7B CENTRATE / TRATE STORAGE FILTER PRESS RO SYSTEM IIIIIIIIIIIII O V Q� CONTAINMENT AREAS OUTSIDE T I I L 0 OIL STORAGE on.I SALE OIL STORAGE O O WATER ' STORAGE 0.09-d !WATERTRANSFEI 1O1- SOUD STORAGE 4. BUILDING 1 USED AS PLANT WATER h TRUCK. WASHOUT WATER L? _ LANDFILL OFFSITE> ACNE wFEET PREPARED FOR NGL WATER SOLUTIONS LLD DENVER CO PREPARED BY MARQUEZ ENVIRONMENTAL SERVICES INC. IMO BRAUN ROAD GOLDEN COLORADO C6 SOLIDS PROCESSING FACILITY PLATTEVILLE COLORADO FIGURE 4 SOLIDS PROCESSING FACILITY PROCESS FLOW DIAGRAM REVISION A 9 v ,:3110114#A1 •I r sappossym 1apM9 4.461 old N. � I ON3031 ONV S3 ON (ZL AO 1, 133HS) WV2IOV1O NOI1V1N3WMIISNl ONV SS30O21d alma IC))43 OOV� NSIs10 1110 MY111a11JSiG ir01SAkt 00H180100 3111A311Yld A11110VA ONISS300ad SOIIOS 90 1. t)1, 11.'11 =Alt.11•.•111111 ,M NIli lea 1#11 +/14A4 111 N 11ra OEM bN11117A 11901411.0 e11Vrr•17'M 1111 M owlet Ml MIlr NUM Ni Willa /M 40re 44nVs1o. 111 041 howl 1 u /44 110 f1/t111 !•I1JnO4r r1•s114 10WW1 103 -I 1151 •11 rank 011f1!)W Ian OOiwlOtYm-Its)1111S/1635/ 0.1011051111.all1 IAN" 011.11110 /111714 1111/ ---y � r-- Ufa! 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MY TIM TIE ANN Hull NMEIM HM W;f MH TEMTINON SIM 1 II III' L H q 00° A1R OM• Mew w a I M All ANO Hum OOtlr I PIN !1104MIt1/11 /NYII.ODtA► . Mnf aNAI KW MICA won r aMen WSW. tJd1 bRnitNt. MOON IM LOAD 00171IPSt , Mir *Tr Rlnl CONWroR earl CONVeVOw IANOAOl10 MOW CE SOI IDS PROCESSING FAC11 ITV PLATTEVILLE. COLORADO DI% • .k CMl( CmECY In'.yEb PROCESS AND INSTRUMENTATION DIAGRAM (SHEET 2 OF 12) NOTES AND LEGEND it _ tSSUEG to* as( O►AS/1 Golder ati Associates 1.7 lr IWPIUN POORCT tY. 1AOC- 7 1 l 1 1 1 i PLC rfJYllp /lad MONO DRAWING 12 WO roa ► 101 OSUMI► Om t VMI IOC ► 101 IM1r a; r lop 3 1 F F A ♦ 1 L C SYMMR1 U HOSE o- ft. 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Z 4 If i 1 1 ► I 6... — • - - J —J --------------------}-- ---------- awn UsSe laser WILOADRIO TRENCH 13M1UIM Rb ■ UR Z 2 y� LL K 0 lA 0 --------- • j Sat s =eat UNPAIDcpa MINI SUNS 1D tMO S mosisostbase rig -'*' sonout fry DRAWING 10 > v v o1f1MMTe l(TOLAfIDItl1 i 1v (pun WGI menu 1 1 DRAWING 9 > • 1 i 1 �__.�.. �* 1 �Jtr oa�wnrc3 > : r C6 SOLIDS PROCESSING FACILITY PIATTFVILIF COLORADO Ow( MICA CAM i PROCESS AND INSTRUMENTATION DIAGRAM SHEET 3 OF 12) UNLOADING AREA ► Mutt rot tong 09/25/14 oar . rc 'eve s flag Golder Associates 'tC rM 14044X• 1st1O1[Ct III e J i 1 f e r PII AIR TAU IIant PLC J f ITS 444 I Jill �J SAN POP ► PPP tNK.lN ► ICO • , !EN •INCRS DRAWING 8 NOTES INN 1 u >IS T-10-01 v DRILLING MUD STORAGE • fi rows usworiscsur T-10-02 DRILLING '•" M U O IS PS ,--hgrThi STORAGE Ems— --Nam- f DOW +PCS"- for T-10-03 v DRILLING MUD STORAGE "INcce. �4hF 1 P e T-10-05 DRILLING MUD ,. .: STORAGE •• - :.. :.-.J► r TANK CONTAINMENT AREA I r it p MOISAT1p1 •r1a•IIS0 Of tl] CCIPAMUCTIOM m«, PAO s IKtPolAA1I ION THE CONTENTS Of THIS aAMOw DRILLING • MUD STORAGE -- , • T-10-07 cla DRILLING MUD .;: -• STORAGE] l • , u I►or u Im ; T10#a u DRILLING MUD STORAGE r • I !•r 4 T-10-08 • 0RILUNG MUD �+ STORAGE 1-- • 1 i �en. ro� ()RAINING 13 .> C6 SOJDS PROCESSING FACILITY PLAT 1EVILLE COLORADO • s. r. C<s:*no% o.Ts ocsK.0 CA- Get Af.tr PROCESS AND INSTRUMENTATION DIAGRAM (SHEET 4 OF 12 DRILLING MUD STORAGE GIP Golder Associates fro Itt roman w ma** f • PLC fMq V 1 M MOWN 1-m � W J J � .w 9 a = Z I I I I I OM•t idl • 7.1 1NII0001 •-Xl3 • -- +4430r T-20-01 4.1 TANK BOTTOMS STORAGE �t►T r awl OS' -W OOT/OUS-MOM a►- lINC1 RAPS T6 N1 i•A71pr DRAWLING 8 A �! (A . l4"_iY CP rEH- 7_ DRAWING 15 T-20-05 TANK BOTTOMS ._+}{12}, STORAGE L T TANK CONTAINMENT AREA NOTES i ► 1 ID 4WOtl•MTION htTlAlO WV W C,O•RTIC/CT17M IK►TlYK11 ?Mt NO D 1!O.O•as /d M OOrnens 0 TMO ONAWI IO nx+irnor T-20-02 TANK LBOTTOMS am_ STORAGE G T6p I IKb: T-20-06 I, L! TANK BOTTOMS STORAGE rl u. L'�'"'�^'7 par. 4 T -20-03 TANK BOTTOMS STORAGE T -20-07 TANK BOTTOMS STORAGE . J . ,gin Orit T-20-04 JJ TANK BOTTOMS STORAGE a TANK BOTTOMS , f t.u.a.. STORAGE 1 1 f' gS t 0 4-4 r T I rs••(11ISN nr lesr•nu�hl) rP Jb "et td t • v ttrr .vnrw,� re I. OM OtAr r Goo Oft* NEW* 0.10 1lO11C AN1 X y 1. H 4c1 TO SOUPS MOCL' � DRAWING 12 p„.„..- IN\r rat C6 SOLIDS PROCESSING FACILITY PI ATTEVILLF COLORADO PROCESS AND INSTRUMENTATION DIAGRAM (SHEET 5 OF 12) TANK BOTTOMS STORAGE iv/co roc cc++t • ,N•' (Golder Associate~ 1 N. ,. •roxrl Nd 10 r i i fN111 /tat 1 fly IIOWA -II I 111 1\ PLC 1�_—_'•_�_a_ J iMll fpl /JOl t /RpUC.M Pan • y i-r' 'eyes DRAINING S NOTES d 0 »..W3Dt 1 T-30-01 OFF -SPEC STORAGE T r•w1� oswir.rvaer i H 1^- ..' . i`T t• • T-30-05 OFF -SPEC STORAGE T-30-02 OFF -SPEC >* STORAGE ---+9-DCLI4 MIER OFF -SPEC STORAGE --•DXN • 4 o•,.1IWCOp• G6ay1A011%4' OFF -SPEC STORAGE • • TANK CONTAINMENT AREA 1 P• b moiVa 1011.110VOm N b Ci01ff1I,71a1 GEMS •N/M41O snit MR PC =WW1 Of 1145 OqAISA g eamJ-'ioma' �- • 4 T-30-07 OFF -SPEC STORAGE • if:14 T T T-30-04 O OFF -SPEC STORAGE T-30-081, U OFF -SPEC STORAGE 4 r r 11144 f wan i ( re M OP PISS i,MP ,..11! - f r "'u"'nm1 / oMwiw!• r■r r Yd ea Pure :.4' i H Ner to autos mooasemo C8 SOLIDS PROCESSING FACILITY PLATTEVILLE COLORADO °"' DESIGN `"°° `'E"` 'M" PROCESS AND INSTRUMENTATION DIAGRAM (SHEET 6 OF 12) OFF -SPEC STORAGE A 0110 COPq[ WW1* AN AAP Su V. DLO Golder Associates Kt w ,.60100.... INICAZI r 1.6401 11 1 T N.V.4:N.S PLC • • DENS MRS I-X� _ FRCA•OMERS YlQIRC MOY REACTION VAN DRAWING 13 > _ R/rN TM! DRAVANO >a > _ PAS staTER OdRP.00 tNM r snw1411Al.r 1 1 1 1 • 1 1 I 1 N 1 1 NEATER qMiT Testa DRAWING 17 > _ TANca0110 6 DRAWING 10 • fl1• INN Mil Sling. OIL DRAWING 11 Pia TaTM AARaI 1Aq.a01TONIS LDRAWING 13 > _ moans g rJN ASIRSI t 1 _ 1 • I • • ( / 1 1 • 1 4 1 I PIRIPAIR1-C840.19 1 1 i 1 1 i 1 • I M1a►CM1' gRRFTIW(TRATI Ol DRAWING 15 > _ M0 MINICIRRiN aw I -10C INKY SWAM NOTES • IRMO ti retCHANIIMM 1 1 I a t , I 1 I I r r • • 1 _ 1 I 1 1 I , 1' r r • a► uesoMsr MIN I-XX > -= k( `I" � Cr ( t r— t• NAAS 11Mq MAR SOTTO.; RIM raffle RHOr23 MUMTOUPOUR. 1bT1II10t«w.EaA 1 1 sT1a7M-Intar • I • O a b SOMA* IC1 / lleVIDED IN 1p OOIstOrov MEP MK* NUN MO s RTES ON OSIII *'OR M COW/EIR! O. TNr OWNING s 1 r r ryThr. OA NEAT EXOWANA DRAWINGS > TAM,NOSTO SaarsafCis DRAWING; 13 VOI ., :Rw 202 37 1.40.1" DRAWING < Jl 1•YAL MOAN To SOURS SOLIDS PROCESS BUILDING ----------------- --- ---- I-XX ` C6 SOLIDS PROCESSING FACILITY PLATTEVILLE. COLORADO NO REVISION DESCRitnoto Deaf DESIGN Coal3 CHEM WADI •...._di _ PROCESS AND INSTRUMENTATION DIAGRAM (SHEET 7 OF 12 HEAT EXCHANGERS 4 ISSUER ra con; 01/73,114 AAP .w" gg ` C Golder Associates rvti 12 %Mil •(MI w I •11• • PLC 6 � � o A A A w•/ • O* , w C1 • It H WJ 1411 J l t 31 r 44 !if RANT Oa 0RM ANNO 1? TWOlf>lann DRAWING 17 1 1 I i T i 1 _ • tflit 0OTTO►r/ON (Pitt Ol = DRAWING 12 1 r l 1 1 1 1 r 3 1 i 1 SYS-3111G1Hor 1110100 terra PK'014440.1' r 1 II I ll II -f -- - -r --- - - 1 - -J - ---- I i 1 ,1.011 •M Ti i•1 • R IS 1St TOR III DO MO* IVA vvAs 1 i I D - 4o !_j 7-40-01 DRILLING MUD REACTION VESSEL 21111•211-PVCIP r wrinumor r ` Y T i * pi:liCia�• Ptifit Ort•1� w I 1 I I I • .+r nr.e. 21r. -r srsslsa.or Cal ,ter _ -T-40-02 TANK BOTTOM REACTION VESSEL asa».nar SOLIDS PROCESS BUILDING NOTES 1 r• C MOINATfOr/ PlialOtO K w comm1UCT1p/ afloat, s ••. MU 6 •tIPOMMT4! POT 11t OOwTErrTtd In ORwNerG Y' srsms-cslor n, sys-nA aso1r SYS 221CSTOa• mma.ar r aau p., r / r�TT r Srs4..10-CUOs Q► , s , L ._. Welt maim twow.a MMITT. w sat stun nos r®rtrr ■ rcn mane V)r• Ti i 0 0 .,s • $1, • 1 . l.. • • y SNI-1110-CStp.? SCUDS ALE (TO Wean I i 4 • i DECANTER CENTRIFUGE DECANTER CENTRIFUGE (FUTURE) r a a'M MRono con FILTER PRESS !- i Ott irrninOlt TO C.APPAI Tarr DRAINING 14 > To CST'S! TN/ia DRAWING 14 > NKr TO wen Erman dDRAWING 12 > To c.PTvsE Wan - DRAWING 11 r� Ca TOINE 'we K DRAWING 14 v.POR5 TO TrQTM4A OnOttte own I -X I TO CArTtR T•rrr in DRAWING 14 > TO 17Mfl/1! TOSS DRAWING 14 > 1 • 1 1 1 •.u-• C6 SOLIDS PROCESSING FACILITY PLATTEVILLE COLORADO 11EvG•ih DATE • •oo alml Rc.a. PROCESS AND INSTRUMENTATION DIAGRAM (SHEET 8 OF 12) DEWATERING SYSTEMS T:1Ji.1 16 1t.. ; ct Golder ono Associates nt ► +.oao►.oa TIONCI 13 I COO r 1 WY Mat Al l WHOP 00411A la VM N4 PLC fMM Mil ► NI 1llOCUI I ► AM 1 1 L.—_r,—_J__.J W J J I OJ J J I J d g p S2 s2- 4 4 4 4 'it II • WO OOP 1 Ube ttaMAll4 1 to 0. i I � LJ---J DRAWING 19 r LDRAWING 13 •O114 4I"tfo r`mw a i, rr,a- , aa..ah4114\ FIL>tall DRAWING 13 Alan Pallet Pet *Mb crammer cpso nvetar z 1 t l Ilu \ I I pr Vt11ISM ION Mr r q CAPTURE TANK 11 it (TANK BOTTOM_ LIQUIDS) trt i CAPTURE TANKS* (DRILLING MUD LIQUIDS) SOLIDS PROCESS BUILDING NOTES / IMO MOIMIIITIaI SAM 11roo11rwlYC ION ADTIISPI SVC NO* MMOII I IOI M CaT•I1e OP TIN OIUYw6 r 1 a • T-50-03 +--4MRt r .�� T-60.04 T-5OOS( CENTRATE/FILTRATE CENTRATE/FILTRATE • CENTRATE/FILTRATE CIPIIMIrall. a wr w v-atrIM•e TANK 1 1 I 1 1 I CIPRINI; NMI • TANK TANK fl _ ,.{-------- --- ----------------{ I -X ROI �k innater lrnallO BRIat itrww►ur :r vfw�►>owwM��w.ww.n.r loot woalw 10 VON VIIMINI DRAWING'S > • 1 1 I 1 Maa. C6 SOLIDS PROCESSING FACILITY PLATTEVILLE COLORADO MC AtWYt7M OfWO:MOM _ CAS: x, CAM 'RI PROCESS AND INSTRUMENTATION DIAGRAM (SHEET 9 OF 12) CENTRATE AND FILTRATE STORAGE ;uEO rot tarsi 0/730 Golder �o Associates -oowuoa 1•04144 14 i W -+ W i i *4 44 444 PLC �,�k SOY .« aMtwsr DRAWING 14 ua ctM HEAT t epMNMpt. DRAWING 12 I I _ a - 1 _ DRAWING 1'0 > OM TOMES 1,04Sts ,ro.r T-7001 OIL TANK 0111 -31041101- 110 -UN -0 a OIL TANK YOtl•7rl M\11 •�I nar h TANK CONTAINMENT AREA NOW t wR71t4ACI Otte pi U4t Mx, taC.02CPsaw M'OM QS, NOTES a ttusa.M• T-70-03 J OIL TANK ►10Msattnrror MwaAND tr MA COAtTWTOp ftv*tNw nsal ut,a surest row T14 CONTENTS Or The ORraM0 T-7004 OIL TANK OL tttcawr DRAMS 1Z > TO Ni-1 DRAWING 16 > swarm T-7045 OIL TANK 1-X T -7Q416 OIL TANK 1: .11..a..1 UNLOADING CONTAINMENT PAD O �? n O i C6 SOLIDS PROCESSING FACILITY PLATTEVILLE COLORADO wo NEVs.ati xsc. i. • \ oar orsMsa CAW OV CK MVO PROCESS AND INSTRUMENTATION DIAGRAM (SHEET 10 OF 12) OIL STORAGE A 'SSUE0 M'OM CO►it a Ot Golder Assc dales 15 J W � i INN r rtlRMl lflm J 1 V to ` i g g i z --.....,44444 i i PLC SAW / ill • • w9 11f /� Q z z 7 4 t T• 7 1 i i t 1 1 1 ( L--4---1_—, 1 1 ._. ___ ..______________ ___ _ ______ __________ _ __________________________ l• la lR ____ _____ _____ ______________ lR _____ _ ___ _____ _____ ________ lR _____ _ ._�__ ��, J, _ nr. u .._. m - u �t le T 7001 u - - ars t" tew .. u. / riei7 enl CralUtatw+. T40-01 — u WATER STORAGE w. *�� T40-02 WATER WATER STORAGE _ v alworsnAlle T40-03 WATER STORAGE _ v �, „Wig- T40-04 cl, v WATER STORAGE J - � T40-05 WATER STORAGE _ v SIN'I tit .: na •Acs • • .__ leawl•ew1 Q • O • CRgldnaud' I Q • 4 11 CL!!I iTLe•s' ro �r�r ..` �lilir DRAWING 14 1iAk Peas 4 PeIMPS ISM Z �� p Ili -ft0O IDRAWING 15 > — - *Cm etM `t antaw rk rorwetlw oowednt ) Pralliflllr TANK CONTAINMENT AREA SI'0P rldlnlll DRAWING 12 t. ur T45-01 sa l: V R06/01-Miall.f11' - RORt�i�,t roR�w"aNn+�weew•Io ' row oven RO SYSTEM •. __ 111w�MFIYowr (10,000 GPO) Ro►wuavgor h �� RorEitnMll� , ' �M�._ L / (INCLUDES 3 HD PUMP) "�T� a�onwtle a �Aw » SOLIDS PROCESS BUILDING ___ - _ __ . C6 SOLIDS PROCESSING FACILITY PLATTEVILLE COLORADO NOTES pc.,"m"" mown °"r °CSIC" csa) """ "ma PROCESS AND INSTRUMENTATION DIAGRAM t • a o.•a.anok mows or in oo.t*it+cnow ae•ratwt win no le ,...-4 (SHEET 11 OF 12) INEOPOSLIPOI atteri llOf McCIOUA1.ID -.. WATER STORAGE - tic ,u - _ _ , ev[Cl w> • Golder t�r��„ 16 L _n Cow � � 01/2 1. 3 �w 14:.( 1K IC. ()toAssociates PLC WU. *POP F tY Iso VIPs* Tam MOPS+"Vale [DRAWING 16 i MOP Vain WSW I MS DRAWING 16 > _ NOTES I • I • Wale TAM r HPVw20• PVCl01' 1 1♦ O NGAAYAt1011 Mlarrr0l0 N 10 o047TANCress artemeem 1[u, 0440 b R!►OlM[ K A TK ocarinas a nei 01WAM0 I j POAiAe a MrSA IMP Ists srr PERMEATE PLANT WATER PUMP SKID (VENDOR SUPPLIED) r I r 1 ■100[11 IMP (MP •an ISM *Lent *SAP TVA la •� mcipasmast sGPI4 PSI pokrse wet OCrpt. 41/44.,f : BRINE PLANT WATER PUP MOD (VENDOR SUPPLED) Weft SOPS nTO weep vas 4OP•20d WCS0-Y ROP-1117-PVC I T 10[vv*eft P0IR M6 I Car St MOWS Ts era. Nw Ce.10I J0A AtO4P HP%14203aPVTpO-A' HW[ 20! PVC[04' [414' DRAWING 13 1c 444, 0. Ps MU> We. Vilna fDRAWING 12 / same we la¢ ►K Ras) wan inmate loCAT Oral J0�6CYlpw C •esty P pB.T A la h raRROAI(i atm nom toss, A(4C*01 IMo MUM*. rarsTP 1 [[Iwaaa~otr [-DRAWING 13 l wCtoPS. C6 SOLIDS PROCESSING FACILITY P' AT?EVILLF COLORADO r�,!s;a ra•.c4.MIA• Dee ocslar CADC a+tt4 ROC* PROCESS AND INSTRUMENTATION DIAGRAM (SHEET 12 OF 12) PLANT WATER SYSTEMS A ISSlrlA rOP (Ws* Ow :3] 24 Ail' MVP xM. V QLe (voider Associates i w 1Aknoe A Pat CI w lrrr 17 PHASE 1 SOLIDS PROCESSING FACILITY TANK FARM CONTAINMENT PHASE 2 SOLIDS PROCESSING FACILITY TANK FARM CONTAINMENT 16 BULK CHEMICAL STORAGE CONTAINMENT AREA INTERIOR CONTAINMENT CURB Q AUXILIARY SOLIDS PROCESSING BUILDING FOUNDATION 90.14111 a22 m OFFLOAD SHAKERS CONCRETE PAD EDGE nun TRENCH DRAIN (TYP ) r UNLOADING PAD CONTAINMENT „L---- PINCoes•Onsneamsloaus CALL Dill MAIN SOLIDS PROCESSING BUILDING FOUNDATION vrvar.-..7.\ p I. CONVEYOR BELT HOUSEKEEPING PAD CONTAINMENT AREA SCAM KIX PROPANE TANK CONCRETE PAD EDGE 1r "TE .411; cf —1•r maimensum ® UNLOADING PAD SUMP SECTION at. OmSetlIAMIII...1• k - BULK CHEMICAL STORAGE CONTAINMENT AREA S • I-4, r- UNLOADING PAD EDGE I —±—I NOTES • ..r. .• 1ear SOLIDS TEMPORARY STAGING SHED CONTAINMENT I1 A., CB SOLIDS PROCESSING FACIUTY PLATTEVILLE COLORADO DETAIL SHEET Golder ASSOCIBiCS Ill Ma IGONIKON 18 APPENDIX A STORAGE AND SOLIDS MASS BALANCE CALCULATION M3 Consulting Client: High Sierra Water Services Project: C-6 SPF Detail: Solids Mass Balance MathCAD V13 {P}{f} Job #: CH By/Date: C6 Solids Processing Facility EQ Storage and Solids Mass Balance Calc 1.0 Objective and Background Calc By: JBA Date: 5/1/14 Rev: 2 Calc #: This calculation worksheet is used to determine EQ tank storage volume, process flow rates, and sludge production rates for the C6 solids processing facility. 2.0 References/Data Sources 1. INSERT PROCESS FLOW DIAGRAM HERE 3.0 Procedure 1. Size equalization storage tanks based on flow rates. 2. Document solids content and oil content of various process streams. 3. Determine solid cake and centrate/filtrate production rates for centrifuge and filter press (sludge dewatering processes). Legend J:=32•ft J - 32 ft J - 32 ft yellow highlight =data that must be manually entered green highlight with box = key results blue text with no box or highlight = automatic calculations Saved {fd}{ft} Page {n} M3 Consulting Client: High Sierra Water Services Project: C-6 SPF Detail: Solids Mass Balance Filter Press Size is Adequate per TM -7 Job #: C H K By/Date: Calc By: JBA Date: 5/1/14 Rev: 2 Calc #: red bold text with box = key conclusions, requires manual update green text = assumptions or sources of data 4.0 Assumptions and Limitations bbl:= 42 gal bbl bpd := day Qom := 3500 bpd =102.08 gpm QPDM := 200 gpm QTB := 3500 bpd= 102.08 gpm QPTB := 200 gpm Qwo 1000 bpd= 29.17 gpm QPwo :=100 gpm 10Tota/ ' - QDM + QTB + Qwo = 233.33 gpm SFDM :=15%v SFTB :=10%a SFwo : =1 % OFDM : =1 % OFTB:= 50% OFwo := 1 % MathCAD V13 {P}{f} Average Daily Drilling Mud flow Peak Drilling Mud Flow (pump runout) Average Daily Tank Bottoms Flow Peak Tank Bottom Flow (pump runout) Average Daily Truck Washout Flow Peak Washout Flow (pump runout) Total Average Daily Flow Solids fraction - Drilling Mud - Average Solids fraction - Tank Bottoms - Average Solids fraction - Washout - Average Oil fraction - Drilling Mud Oil fraction - Tank Bottoms Oil fraction - Washout Saved {fd}{ft} Page {n} M3 Consulting Client: High Sierra Water Services Project: C-6 SPF Detail: Solids Mass Balance MathCAD V13 {PHU Chemical Dosing CCoagu/antDM -- 10000 • mg L COrgPolymerDM :— —1000 mg L - mg ClnorgPolymeom :— 600 L CPolymerTB :— - 600 mg L p:=62.4 lb ft3 5.0 Calculation Job #: C H K By/Date: Calc By: JBA Date: 5/1/14 Rev: 2 Calc #: Ferric Chloride dosage from Pilot Test Study - Drilling Mud Organic Polymer dosage from Pilot Test Study - Drilling Mud Inorganic Polymer dosage from Pilot Test Study - Drilling Mud Inorganic Polymer dosage from Pilot Test Study - Tank Bottoms Average Fluid Density Emergency/ EQ Storage Tank Volume T:- 24 hr VE QTotal • T= 336000 gal Solids fractions Emergency Storage Time Required Emergency Storage Volume Required (SFom• QoM+ SFTB Te • Q+ SFwo' Qwo) _ 0.11 SF Qrorel (OFom• QpM + OFTB • QM + OFwo • Q1/4/0) _ _ 0.22 OF Qrotal Saved {fd}{ft} Solids fraction - Overall - not including coagulant and polymer additions Oil fraction - Overall Page {n} M3 Consulting Client: High Sierra Water Services Project: C-6 SPF Detail: Solids Mass Balance MathCAD V13 {PHU Job #: CHK By/Date: Solids fractions - including coagulant and polymer additions QDM • (CCoagulantDM + COrgPolymerDM + ClnorgPolymerDM) QTB ' (CPolymerTB)SF:= SFo++ - 0.12 QTotal' P QTotal ' P QSolids SF' QTotal = 27.06 gpm Dewatered Solids fractions DSFc:= 35% DSFFP:= 50% Calc By: JBA Date: 5/1/14 Rev: 2 Calc #: Solids fraction after dewatering - assumed for centrifuge Solids fraction after dewatering - assumed for filter press Normal plant operation involves sending all flow to the centrifuges. The filter press is intended to be used only during centrifuge downtime. Sludge and Centrate Production QSolids — 77.1 m ()sludge �— — 3 gP DSFc ()Sludge yd3 =551.2 day WSludge:= Qsivage • (DSF c • 2.65 + (1 - DSFc) • 1) • 62.4 �b = 30.52 hr ft3 hr ()Centrate QTotal - ()sludge =156.02 gpm 3 V Dumpster : = 20 yd NDumpsters ' day ()Sludge = 27.56 1 V Dumpster Centrate Recycle A portion of the centrate is recycled to the head of the solids processing facility to be used for truck washdown. The remainder is sent to the C6 water recycle facility to be sold back to oil Saved {fd}{ft} Page {n} M3 Consulting Client: High Sierra Water Services Project: C-6 SPF Detail: Solids Mass Balance MathCAD V13 {PHU Job #: C H K By/Date: and gas operators for fracking operations. QRecycle QCentrate — Qwo =126.86 gpm 7.0 Results Calc By: JBA Date: 5/1/14 Rev: 2 Calc #: The quantity of sludge and quantity of centrate produced daily are given below. These are the maximum quantities of sludge expected under worst case conditions at full build -out. It is assumed that the sludge will be hauled to landfill using 20 yd roll off dumpsters. The centrate will be pumped to the C6 water recycle facility for reuse. �PDum ster = 2 yd 31 Q =551.19 Yd Sludge day. ir- N - 27.56 1 Durnpsters day ()Recycle = 127 gpm ()Recycle= 4349 bpd Saved {fd}{ft} Page {n} APPENDIX B SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN May 8, 2017 Spill Prevention, Control, and Countermeasure (SPCC) Plan Prepared for: Energy Partners LP NGL Water Solutions DJ, LLC C6 Solids Processing Facility 13159 Weld County Road 39 Platteville, Colorado 80651 Project Number: 1-8019-10695ah _ SOLUTIONS DELIVERED ../ CCIRS 1301 Academy Ct. Fort Collins. CO 80524 www.cgrs.com 800.288.2657 Ani CGRS „,,,,,,, SOLUTIONS DELIVERED SPCC Plan I NGL Water Solutions DJ, LLC I C6 Solids Processing Facility 15/8/17 EMERGENCY DISCHARGE [112.7(a)(3)(vi)1, [112.7(a)(5)1 In the event of a discharge emergency, immediately contact and notify the following organizations and personnel as defined below. In the event of leakage or spills. always contact: Primary Contact: Alternate Contact: Mr. Mike Campbell (970) 415-3961 mobile Or Mr. Vincent Ziesmer (970) 397-8901 mobile If a spill/release occurs in which one (1) barrel or more is released outside of secondary containment, or five (5) barrels or more are released within secondary containment, you must within 24 hrs.: ■ Submit eForm 19 to the COGCC Director via https://cogcc.state.co.us/eform/ For any spill/release, Operator will determine the level of emergency. If a spill/release is not contained, has reached navigable waters. or constitutes an emergency in any way, local fire authorities must be contacted: ■ Platteville-Gilcrest Fire Protection District (970) 785-2232 Spills of any volume ultimately reaching or threatening navigable waters: Contact CDPHE Environmental Release Hotline (877) 518-5608 And The National Response Center (800) 424-8802 Other contacts as needed: ■ NGL Water Solutions DJ, LLC office — (970) 356-5560 ■ Response Coordinator, Mr. Mike Campbell — (970) 415-3961 ■ Regional Administrator — EPA Region 8 (CO) — (800) 227-8917 ■ CGRS Inc. — cleanup consultant/contractor — (800) 288-2657 ■ Waste Management — waste disposal — (303) 886-9694 ■ Excavation / Heavy Equipment — NGL ■ Vacuum Truck Services — NGL Note: See Appendix D for additional information on emergency discharge situations and descriptions. www.cgrs.com 800.288.2657 1301 Academy Ct. 2 Fort Collins. CO 80524 4//Aosi-s-4 CGRS SOLUTIONS DELIvEAEO Table Of Contents SPCC Plan I NGL Water Solutions DJ, LLC I C6 Solids Processing Facility ( 5/8/17 1.0 Plan Certification & Approval 6 1.1 Certifying Engineer's Statement [112.3(d)] 6 1.2 Management Approval Statement [112.7] 6 2.0 General 7 2.1 SPCC Plan Description [112.7(a)(1)] 7 2.2 SPCC Plan Location [112.3(e)] 7 2.3 Amendment and Review Procedures [112.5] 7 2.4 Facility Not Yet Operational [112.7] 8 2.5 Deviations from Requirements [112.7(a)(2)] 8 2.6 Facility Description [112.7(a)(3)] 8 2.7 Facility Storage [112.7(a)(3)(i)] 8 2.8 Discharge Prevention Measures [112.7(a)(3)(ii)] 9 2.9 Discharge Controls [112.7(a)(3)(iii)] 10 2.10 Countermeasures: Discovery/Response/Cleanup [112.7(a)(3)(iv)] 10 2.11 Disposal [112.7(a)(3)(v)] 10 2.12 Notification Phone List [112.7(a)(3)(vi)] 11 2.13 Discharge Notification Form [112.7(x)(4)] 11 2.14 Discharge Procedures [112.7(x)(5)] 12 2.15 Discharge Prediction [112.7(b)] 12 2.16 Secondary Containment for Loading/Unloading Areas Other Than Rack [112.7(c)] 13 2.17 Statement of Impracticability [112.7(d)(1)] 14 2.18 Statement of Impracticability [112.7(d)(2)] 14 3.0 Inspections, Tests, and Records 14 3.1 Inspections and Record -Keeping [(112.7(e)] 14 4.0 Personnel Training 16 4.1 Personnel Instruction [112.7(f)(1)] 16 4.2 Designated Individual for Spill Prevention [112.7(f)(2)] 16 4.3 Spill Prevention Briefings [112.7(f)(3)] 16 5.0 Security 17 5.1 Securing and Controlling Access [112.7(g)] 17 5.2 Securing Master Flow/Drain Valves [112.7(g)] 17 5.3 Preventing Unauthorized Access to Starter Controls [112.7(g)] 17 5.4 Securing Loading/Unloading Connections [112.7(g)] 17 5.5 Security Lighting [112.7(g)] 17 6.0 Tank Truck Loading/Unloading 17 6.1 Secondary Containment for Loading/Unloading Areas Including Racks [112.7(h)(1)] 17 6.2 Warning/Barrier Systems [112.7(h)(2)] 17 6.3 Bottom Drains of Vehicles Examined [112.7(h)(3)] 18 www.cgrs.com 800.288.2657 3 1301 Academy Ct. Fort Collins. CO 80524 4'41 CGRS I„,,, SOLUTIONS DEvVEnil( SPCC Plan I NGL Water Solutions DJ, LLC I C6 Solids Processing Facility 15/8/17 7.0 Other General Requirements 18 7.1 Brittle Fracture/Other Failure — Field Constructed Aboveground Containers [112.7(i)] 18 7.2 Conformance with Stricter State Rules [112.7(j)] 18 7.3 Qualified Oil -Filled Operational Equipment [112.7(k)] 18 8.0 Facility Drainage 18 8.1 Drainage from Diked Areas [112.8(b)(1)] 18 8.2 Dike Drainage Valves — Manual, Open/Closed Designed [112.8(b)(2)] 18 8.3 Drainage System for Undiked Areas [112.8(b)(3)] 18 8.4 Final Discharge Diversion System [112.8(b)(4)] 18 8.5 Backup Pump for Lift Station and Transfer Systems [112.8(b)(5)] 19 9.0 Bulk Storage Tanks 19 9.1 Containers Compatible with Materials Stored [112.8(c)(1)] 19 9.2 Secondary Containment [112.8(c)(2)] 19 9.3 Rainwater Drainage Procedure [112.8(c)(3)] 20 9.4 Buried Metal Tanks Corrosion Protection [112.8(c)(4)] 20 9.5 Partially Buried Tanks Protected Against Corrosion [112.8(c)(5)] 20 9.6 Integrity Testing [112.8(c)(6)] 20 9.7 Internal Coils [112.8(c)(7)] 21 9.8 Engineered to Avoid Discharges [112.8(c)(8)] 21 9.9 Plant Effluent Discharges into Navigable Water [112.8(c)(9)] 22 9.10 Oil Leaks Promptly Corrected [112.8(c)(10)] 22 9.11 Mobile or Portable Oil Storage Tanks [112.8(c)(11)] 22 10.0 Facility Transfer Operations 22 10.1 General 22 10.2 Buried Pipe Installations [112.8(d)(1)] 22 10.3 Terminal Pipe Connections Capped or Blank Flanged [112.8(d)(2)] 22 10.4 Aboveground Pipe Supports [112.8(d)(3)] 22 10.5 Testing and Inspection of Aboveground Pipes and Valves [112.8(d)(4)] 23 10.6 Warning for Trucks of Pipes [112.8(d)(5)] 23 11.0 Substantial Harm [112.20(e)] 23 12.0 Oil Spill Contingency Plan [109.5] 23 12.1 Purpose and Scope 23 12.2 Authorities, Responsibilities, and Duties [109.5(a)] 24 12.3 Notification Procedures [109.5(b)] 24 12.4 Commitment of Resources [109.5(c)] 25 12.5 Actions To Be Taken After Discovery and Notification [109.5(d)] 26 12.6 Cleanup, Disposal, Reporting, and Review [109.5(e)] 27 www.cgrs.coin 800.288.2657 4 1301 Academy Ct. Fort Collins. CO 80524 4 CG RS ,„„,, SOLUTrOr.. DEL.VEAEc Figures Figure 1: Figure 2: Figure 2C: Appendices Appendix A: Appendix B: Appendix C: Appendix D: Appendix E: Appendix F: Appendix G: Appendix H: Appendix I: Appendix J: Appendix K: SPCC Plan I NGL Water Solutions DJ, LLC I C6 Solids Processing Facility 15/8/17 Site Location Site Layout Solids Processing Facility SPCC Review Log for Technical Amendments SPCC Review Log for Non -Technical Amendments DOT Requirements Emergency Spill Response Procedures Spill Response Notification Form COGCC Form 19 Spill/Release Report Monthly Visual Inspection Form SPCC Spill Preparedness Training Dike Water Drainage Log Secondary Containment Volume Calculations Substantial Harm Criteria Checklist www.cgrs.com 800.288.2657 1301 Academy Ct. 5 Fort Collins. CO 80524 CGRS SOLUTIONS. DELIVERED SPCC Plan 1 NGL Water Solutions DJ. LLC I C6 Solids Processing Facility 5/8/17 1.0 Plan Certification & Approval 1.1 Certifying Engineer's Statement [112.3(d)] The undersigned Registered Professional Engineer is familiar with the requirements of the Code of Federal Regulations, Title 40; Part 112 (40 CFR Part 112), and he or his agent has examined the facility. The undersigned Registered Professional Engineer attests that this Spill Prevention, Control, and Countermeasure (SPCC) Plan has been prepared in accordance with good engineering practices including consideration of applicable industry standards, and in accordance with the requirements of 40 CFR Part 112; that procedures have been established for required inspections and testing; and that the Plan is adequate for the facility. This certification in no way relieves the owner/operator of the duty to prepare and fully implement this SPCC plan in accordance with the requirements of 40 CFR Part 112. I -Ailf:$rannan Davis, P.E. Colorado State Registration No: 44268 Date: 1.2 Management Approval Statement [112.7] This SPCC Plan is fully supported by the management of NGL Water Solutions DJ, LLC (NGL). NGL Water Solutions DJ, LLC is committed to the prevention of discharges of oil to navigable waters or the environment, and maintains the highest standards for spill prevention, control, and countermeasures through periodic review, updating, and implementation of this plan. NGL Water Solutions DJ, LLC will implement this plan and amend it as needed due to expansions, modifications. and improvements at the tank battery facility included in this plan and will provide the manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful. Date: Mr. Joshua Patterson Vice President, Operations NGL Water Solutions DJ, LLC www.cgrs.com 800.288.2657 1301 Academy Ct. 6 Fort Collins, CO 8052/1 4 CGRS „„„,, sOLUTPONS DELIVERED 2.0 General SPCC Plan I NGL Water Solutions DJ, LLC I C6 Solids Processing Facility 15/8/17 2.1 SPCC Plan Description [112.7(a)(1)] The following SPCC Plan has been developed as part of a comprehensive plan to minimize the potential for oil discharges. The plan is designed to guide personnel in their oil spill prevention activities and satisfy applicable federal requirements outlined in 40 CFR, Part 112, for facilities that have total aggregate aboveground oil storage capacity greater than 1,320 gallons. 2.2 SPCC Plan Location [112.3(e)] In accordance with 40 CFR 112.3(e), a complete copy of the SPCC Plan is maintained for facility personnel. and is available 24 hours per day, 365 days per year at the C6 Solids Processing Facility located at 13159 Weld County Road 39. Platteville, Colorado 80651. The plan is also available for inspection by regulatory officials during regular business hours at the NGL office, located at 8207 W 20th, Suite B. Greeley, CO 80634. 2.3 Amendment and Review Procedures [112.5] The SPCC Plan will be amended as needed whenever there is a change in the facility design, construction, operation, or maintenance that materially affects the potential to discharge oil into navigable waters or adjoining shorelines. Any technical amendment to this SPCC Plan will be effective only if certified by a Professional Engineer in accordance with 40 CFR, Part 112.3(d). In addition, the SPCC Plan will be reviewed and evaluated at least once every five years. As a result of such review, the SPCC Plan will be updated and modified to include more effective prevention and control technology where applicable. All technical plan amendments will be certified by a Professional Engineer and fully implemented within six months of the date of the facility change. All administrative plan amendments will be made by the owner/operator; however, administrative amendments do not require certification by a Professional Engineer. SPCC Plan reviews will be documented on a review log that will be maintained with the SPCC Plan. The following table outlines administrative verses technical amendments and describes the management review process. The SPCC Plan Review Log for Technical Amendments is provided in Appendix A, and the SPCC Review Log for Non -Technical Amendments is provided in Appendix B. Technical Amendments ■ Technical amendments are certified by a Professional Engineer. ■ Examples of technical amendments include, but are not limited to. commissioning or decommissioning containers; replacement, reconstruction, or movement of containers; reconstruction, replacement. or installation of piping systems: construction or demolition that may alter secondary containment structures; changes of product or service; or addition or deletion of standard operation or maintenance procedures related to discharge prevention measures. It is the responsibility of the operator to determine, and confirm with the regulatory authority as necessary, what constitutes a technical amendment. The preamble of the rule states that an amendment is required only "when there is a change that materially affects the facility's potential to discharge oil" (67 FR 47091). ■ An amendment made under this section will be prepared within six (6) months of the change and implemented as soon as possible but no later than six (6) months following preparation of the amendment. www.cgrs.com 800.288.2657 7 1301 Academy Ct. Fort Collins. CO 80524 _ SOLUTIONS DELIVEnt_i. CGRS SPCC Plan I NGL Water Solutions DJ, LLC I C6 Solids Processing Facility 15/8/17 Non -Technical Amendments ■ Administrative amendments are not required to be certified by a Professional Engineer. ■ Examples of administrative amendments include, but are not limited to, phone numbers, name changes. or any non -technical text change or changes. 2.4 Facility Not Yet Operational [112.7] The facility described in this SPCC Plan is fully operational. 2.5 Deviations from Requirements [112.7(a)(2)] There are no deviations from the SPCC requirements. 2.6 Facility Description [112.7(a)(3)] NGL Water Solutions DJ, LLC (NGL) owns and operates the C6 Solids Processing Facility (C6 SPF). The C6 SPF is located in Weld County at 13159 Weld County Road 39. Platteville, Colorado 80651, in the Southeast 1/4 of the Southeast 1/4 of Section 30. Township 3 North. Range 65 West. The facility entrance is on the west side of Weld County Road 39, approximately 700 feet north of Weld County Road 28. C6 Solids Processing Facility is surrounded by native grasses, with an E&P facility adjacent to the west side of the property boundary. Regional topography is relatively level with surface drainage flowing to the east-southeast. The nearest water body within the flow path is the Beebe Seep Canal, approximately five miles southeast of the facility. The nearest navigable water is Milton Reservoir, located approximately three miles northeast of the facility. Site location and topographic and surface water features are illustrated in Figure 1. The facility consists of an office, main solids processing building, auxiliary solids processing building. solids storage building, concrete loading/unloading pad, and concrete secondary containment for aboveground storage tanks (ASTs). In addition, the following areas provide secondary containment for containers housing oil bearing fluids: ■ Loading/Unloading Pad ■ Solids Processing Tank Containment ■ Main Solids Processing Building ■ Auxiliary Solids Processing Building ■ Centrate/Filtrate Tank Containment General site conditions are depicted in the green shaded portion of Figure 2. The C6 SPF details are depicted in Figure 2C. Secondary containment volume calculations are presented in Appendix J and summarized in section 9.2. 2.7 Facility Storage [112.7(a)(3)(i)] The following table describes tanks associated with the treatment of slurry and storage of oil and water at this facility: www.cgrs.com 800.288.2657 1301 Academy Ct. 8 Fort Collins. CO 80524 "ji CGRS SPCC Plan I NGL Water Solutions DJ, LLC I C6 Solids Processing Facility 15/8/17 Solids Processing Facility # of Units Individual Capacity Cap BBLs (gallons) Tank y Capacity BBLs (gallons) Total Installed Year (ASTs) Storage Description Unit AST Dimensions Construction Material 5 780 (32.760) (163,800) 3.900 2015 Water Produced ASTsfabricated 15.5)(25 fiberglass Single vertical -wall shop AST 18 (16.800 400 7.200 (302,400 2015 Oil ASTs 12' x 20' Single shop vertical fabricated -wall steel AST 3 (16.800) 400 1,200 (50,400) 2015 Centrate/Filtrate ASTs 12' x 20' fiberglass vertical Single fabricated -wall shop AST 2 (1,400) 33 66 (2,800) 2015 Capture p ASTs 7' x 5� fiberglass Single vertical fabricated -wall shop AST 2 90 (3,780) 180 (7.560) 2015 Brine ASTs 8' x 10' fiberglass vertical Single fabricated -wall shop AST 1 200 (8,400) 200 (8.400) 2015 Reaction AST 10' x 12' fiberglass Single vertical fabricated -wall shop AST Total (535,332) 12,746 2.8 Discharge Prevention Measures [112.7(a)(3)(ii)] Operator requires all tanker truck drivers to comply with Department of Transportation (DOT) regulations in 49 CFR Part 177 regarding tank loading and unloading procedures. DOT requirements and tanker truck loading standard operating procedures are provided in Appendix C. The following procedures are implemented when a tanker truck is being loaded: ■ Vehicle's parking brake is set. ■ Outlet valves are closed. ■ Grounding procedures are followed. ■ Ungrounded objects are removed from tanker loading area. ■ Driver assures that hose connections are secure and flow is started slowly. www.cgrs.com 800.288.2657 1301 Academy Ct. 9 Fort Collins. CO 80524 414 CGRS SOLU71ON5 DES Pvi- r.'-_ r SPCC Plan I NGL Water Solutions DJ, LLC I C6 Solids Processing Facility 15/8/17 ■ Transfer operator remains outside the vehicle, present and attentive. After tanker truck loading is complete, the following procedures are followed: ■ The driver checks the liquid level versus the compartment marker. ■ The driver waits at least one minute before lowering any metal or conductive objects (gauge tapes. samplers, thermometers, etc.) into the compartment. This allows any static charge to dissipate. ■ All loading valves are closed and hose connections are capped or plugged. Signs of spillage are noted and remedial action is taken, if necessary. ■ All hatches are closed tightly and internal safety valves are closed. 2.9 Discharge Controls [112.7(a)(3)(iii)] The solids processing facility is designed to contain process fluids through every step of the separation process. All tanks on -site are contained within an impermeable secondary containment. The design of the unloading pad is such that liquids are contained on the pad before diverting to the pad drain that drains into the loading/unloading pad sump. NGL maintains spill response oil absorbent materials readily available at the facility that can be rapidly deployed to contain and abate potential discharges outside the secondary containment areas. NGL ensures that all transfer equipment is compatible with the products being dispensed. NGL instructs oil handling personnel to ensure that any 55 -gallon oil drums are stored inside the processing buildings and that drum openings are sealed appropriately when not in use to prevent spills. Furthermore, drum fittings are securely attached to the appropriate bung openings and operated according to manufacturer recommendations. 2.10 Countermeasures: Discovery/Response/Cleanup [112.7(a)(3)(iv)] Employees and contractors will immediately report all spills of oil products to the primary contact. If the primary contact is not available, the alternate contact, will be notified. See the second page of this report for primary and secondary contact information. Spill response will be initiated as soon as possible to stop additional spillage and to implement containment measures. Facility personnel maintain spill response supplies and oil absorbent materials at the C6 SPF facility to respond to spills and begin immediate cleanup measures. Heavy equipment, excavation equipment, pumps, and vacuum tanker trucks are available in the area. See the second page of this report for a list of local services and contact information. Manual tools, such as shovels and rakes, for use in the containment and cleanup of spills will be employed if needed. Discovery, response, and cleanup activities are described in more detail in the following sections. 2.11 Disposal [112.7(a)(3)(v)] The final operation in spill response and cleanup is the disposal of impacted materials. Any plan for disposal used must be coordinated through the appropriate regulatory agency. If the impacted material is related to a release of oil or produced water from a tank battery system, the agency for oversight is the Colorado Oil and Gas Conservation Commission (COGCC). Impacted material must be disposed at an appropriate facility or other regulatory agency, to receive the type of waste being shipped and each shipment documented using proper www.cgrs.com 800.288.2657 1301 Academy Ct. 10 Fort Collins. CO 80524 CGRS SOLUTIONS DELPVEQEC. SPCC Plan I NGL Water Solutions DJ, LLC I C6 Solids Processing Facility 15/8/17 manifest or bill -of -lading forms, if needed. Follow-up written reports will be submitted to the appropriate agency at times commensurate with all applicable requirements. 2.12 Notification Phone List [112.7(a)(3)(vi)] A contact list and phone numbers for individuals, emergency response authorities, spill response/cleanup contractors, and regulatory agencies to be notified in the event of leakage or spills is provided as the second page of this report. Spills ultimately reaching navigable waters in harmful quantities as defined by 40 CFR Part 110.3 (that which violates applicable water quality standards or causes a sheen on the water surface) are required to be reported under 40 CFR Part 110.6. If a spill or release of exploration and production waste or produced fluids occurs outside of containment and is equal to or greater than 1 BBL (42 gallons). it must be reported within 24 hours. See the second page of this report and Appendix D for contact information and notification instructions. 2.13 Discharge Notification Form [112.7(a)(4)] An example form for spill documentation and reporting is provided in Appendix E. When contacting regulatory agencies, the following information should be provided: ■ Name and owner/operator of facility ■ Responsible company/person, including mailing address and telephone number ■ Name of person reporting the release ■ Date and time of release ■ Legal description of release location ■ Type and amount of substance released ■ Waterway affected, including amount reaching water ■ Cause of release ■ Action taken to control, contain, and remove release ■ Other pertinent information specific to the release In accordance with 40 CFR Part 112.4(a), if the facility has a discharge to navigable water of more than 1,000 gallons of oil in a single event or discharges more than 42 gallons of oil in each of two discharges occurring within any twelve month period, Operator will submit the following information to the EPA Regional Administrator within 60 days from the day of the discharge: ■ Name of the facility ■ Callers name ■ Location of the facility ■ Maximum storage or handling capacity of the facility and normal daily throughput ■ Corrective action and countermeasures taken. description of equipment repairs and replacements ■ Description of the facility. including maps. flow diagrams, and topographic maps, as necessary ■ Description of the cause of the discharge, including a failure analysis of the system or subsystem that failed ■ Additional preventative measures taken or contemplated to minimize the possibility of recurrence www.cgrs.com 800.288.2657 1301 Academy Ct. 11 Fort Collins. CO 80524 pip... CGRS ill SOLUTIONS DELIVERED SPCC Plan I NGL Water Solutions DJ, LLC I C6 Solids Processing Facility 15/8/17 ■ Any other information as the Regional Administrator may reasonably require pertinent to the Plan or discharge 2.14 Discharge Procedures [112.7(a)(5)] After identifying and locating a spill, the necessity for, and feasibility of, effective containment will be assessed. Containment will be initiated as soon as possible to prevent undue spreading of released product. The first action should be the elimination of any additional spillage. This may be accomplished by shutting off a pump or valve, placing a cap or a plastic or epoxy patch over the leak, putting a temporary plug in a puncture or tear, or other appropriate action. Oil absorbent materials are maintained within a spill kit and will be used to contain, and clean up, spilled product. If required, excavation equipment and/or manual tools, such as shovels and rakes, will be used to erect earthen berms along the leading edge of the spill to prevent spreading. Materials recovered during cleanup will be placed in appropriate containers or stockpiled using an impermeable liner and cover (such as polyethylene sheeting) to prevent cross -contamination with unexposed media prior to disposal. If free phase petroleum product is present or if the spill reaches surface water, the spill must be contained and removed. Mechanical methods of spill removal include suction hoses, excavation. the use of skimmers, and sorbent materials. The use of chemical or biological collecting agents is discouraged and can only be used with prior approval from both state and federal regulatory officials. 2.15 Discharge Prediction [112.7(b)] The following table describes storage containers and associated equipment where potential discharges could occur. The table includes predictions of failure types, estimated volume, flow rate and the direction of flow, which could be discharged from the facility as a result of each type of major equipment failure and general secondary containment notes. Solids Processing Facility Source Typ Failure e e of Volume (gallons) BBLs Estimated Flow Rate Direction Flow of Secondary Containment Process (MAP ID Water 1-5) Rupture p 780 (32,760) Gradual instantaneous to Onward containment within Concrete Dike Recovered (MAP ID 6-23) Oil Rupture p (16,800) 400 Gradual instantaneous to Outward containment within Concrete Dike Centrate/Filtrate (MAP ID 25-27) Rupture p (16,800) 400 Gradual instantaneous to Onward containment within Concrete Dike www.cgrs.com 800.288.2657 12 1301 Academy Ct. Fort Collins. CO 80524 Aer lispre SOW TIONS Dan/ERE° CGRS SPCC Plan I NGL Water Solutions DJ, LLC I C6 Solids Processing Facility 15/8/17 Source Type Failure of Volume (gallons) BBLs Estimated Flow Rate Direction Flow of Secondary Containment Reaction ( MAP ID Tank 28 ) Rupture 200 (8,400) Gradual instantaneous to Onward containment within Main Building Solids Containment Walls Processing (MAP Slurrification Tank ID 31-32) Rupture (1,386) 33 Gradual instantaneous to Onward containment within Main Building Solids Containment Walls Processing (MAP Brine ID Tank 34-35) Rupture 90 (3,780) Gradual instantaneous to Onward containment within Auxiliary Processing Containment Solids Building Walls Aboveground Piping p g Rupture 1 to 5.000" 500 gal/min Outward piping from Loading/Unloading Active Containment and Pad Tanker Offloading Truck connection rupture, overfill Hose or 1 to 7,500* 750 gal/min Outward truckfailure, from Loading/Unloading Active Containment and Pad Tanker Loading Oil Tank Truck from connection rupture, failure, overfill Hose or 1 to 3,000* 300 gal/min Outward truck from Concrete Active Containment Dike and * Predicted releases associated with transfer activities are based on the attendant being present in close proximity to the pump controls, the loading valve or pump switch accessible, and the attendant shutting the valve or pump switch within a period of 10 minutes. 2.16 Secondary Containment for Loading/Unloading Areas Other Than Rack [112.7(c)] All loading and unloading connections and equipment associated with the ASTs are within secondary containment. If a spill occurs from a tanker truck outside the containment areas, NGL maintains readily available absorbent materials and equipment on -site that can be rapidly deployed to contain and abate any potential spill. Secondary containment volume calculations are provided in Appendix J. Loading/Unloading Pad Slurry delivered to the C6 SPF is offloaded from transports over a concrete containment pad that slopes to a drain in the center of the pad. The slurry is pumped directly from the transports to the shaker tank. where the sediment and production water are initially separated. If a spill were to occur, the design of the pad is such that the slurry would be contained on the pad before migrating to the containment drain and loading/unloading pad sump. Slurry that reaches the sump is pumped out as needed and sent to the shaker tank for processing. www.cgrs.com 800.288.2657 1301 Academy Ct. 13 Fort Collins. CO 80524 CGRS SOLUTrOr4S DELIVERED SPCC Plan I NGL Water Solutions DJ, LLC C6 Solids Processing Facility ( 5/8/17 The concrete pad is designed to hold the volume of the shaker tank (500 barrels) plus freeboard precipitation allowance. The total calculated holding capacity of the containment is approximately 1,282 barrels. When considering the freeboard allowance for a predicted 24 -hour. 25 -year storm event, the adjusted available holding capacity is approximately 870 barrels. 2.17 Statement of Impracticability [112.7(d)(1)] Provided the flowline outside of secondary containment from the pump house to the injection well. see Section 12.0, which follows the provisions of CFR 40 Part 109. 2.18 Statement of Impracticability [112.7(d)(2)] A written commitment of manpower, equipment. and materials required to expeditiously control and remove any quantity of oil discharged from a flowline outside secondary containment is presented in Section 12.0. 3.0 Inspections, Tests, and Records 3.1 Inspections and Record -Keeping [(112.7(e)] Inspections are an integral part of facility procedures. Field operations personnel periodically, and upon a regular schedule, visually inspect each container of oil for deterioration and maintenance needs, including the foundation and support of each container that is on or above the surface of the ground. Periodic inspections are also performed on the tanks, piping, and transfer equipment. Storage tank inspection reports which have been completed are signed by the appropriate supervisor or inspector and are made part of the current SPCC Plan. Operator management is responsible for all inspection reporting and documentation procedures. These records are kept on file with the SPCC Plan for a minimum period of three years. On a daily basis, the facility is inspected by operations personnel. The AST systems are visually inspected every two hours, in addition to monthly, to ensure that there has been no failure of the tanks or associated equipment. Diked secondary containment areas are inspected for the presence of oil and accumulated water, and tank system valves are inspected. The storage tanks are gauged daily and a production report is maintained. Scope of Daily Inspection Facility Area Inspection Items Observations AST Containment Leaks ■ ■ • ■ ■ Tank Drip Base Corrosion, Cracks liquid marks, of in tank, especially metal level leaks puddles gauged from containing at welded the base seams oil (pitting. flaking) www.cgrs.com 800.288.2657 14 1301 Academy Ct. Fort Collins. CO 80524 this,_ SOLUTIONS DELivEAEO CGRS SPCC Plan I NGL Water Solutions DJ, LLC C6 Solids Processing Facility 15/8/17 Facility Area Inspection Items Observations ■ Cracks AST Containment. Puddles contain oil or leaked material Loading/Unloading Pad Foundation Settling ■ Gaps in base ■ Evidence of leaks, especially at connections and collars AST Loading/Unloading Containment, Pad Flowlines • Corrosion Evidence including of oil g seepage pitting p g from and valves flaking g or seals On a monthly basis, visual inspections are performed and documented by a contractor who inspects the condition of the storage tanks, secondary containment systems, flowlines, piping and all associated processing equipment. Storage tanks are inspected for signs of deterioration and leakage. The secondary containment areas are checked for proper drainage, general condition, evidence of oil, and signs of leakage. All aboveground valves and pipes are inspected, noting the general condition of items such as flange joints, expansion joints, valve glands and bodies, spill containment vessels, pipe supports, and pumping wellhead equipment. If needed, gaskets are replaced and threaded connections are tightened. The general scope of the monthly inspections is summarized in the following table. A monthly inspection and recording form is included in Appendix G. Scope of Monthly Inspections Facility Area Inspection Items Observations ■ Leakage, gaskets, thief hatches ■ Tank liquid level checked ■ welds in good condition Tank ■ Vacuum vents present and operational AST Containment Storage Tanks • Overflow piping present and operational ■ Piping, valves, and bull plugs operational ■ Presence of corrosion and paint condition ■ Pressure/ level safety devices present ■ Pressure relief valves ■ Integrity of concrete foundation and walls AST Secondary Containment • Equipment protectors and signage Containment Dike General housekeeping ■ Gauges in good condition with no leaks AST Containment Production Equipment Pressure safety devices in good condition and operational ■ Pressure relief valves in good condition and operational ■ Valves closed and in good condition Loading/Unloading Pad Offloading Piping • Cap pipe/connection or bull plug at the end of the offloading ■ Equipment protectors and signage www.cgrs.com 800.288.2657 15 1301 Academy Ct. Fort Collins. CO 80524 4.4 CGRS ,,„,, SOLLMONS Dan/ERE° SPCC Plan ( NGL Water Solutions DJ, LLC I C6 Solids Processing Facility 15/8/17 Facility Area Inspection Items Observations Loading/Unloading Pad Secondary Containment ■ ■ ■ Presence containment Presence Integrity General of housekeeping of of concrete oil oil or in standing the surroundingarea foundation water in the secondary In addition to the daily and monthly inspections, the Standard for the Inspection of Aboveground Storage Tanks (STI SP001) requires a schedule and scope for inspections to be performed on steel tanks by a certified inspector on a periodic basis, as defined in STI SP001. Utilizing tables from STI SP001, single wall tanks resting on concrete, sized 5,001 - 50,000 gallons, with secondary containment.. and spill control, require a formal external inspection every 20 years. in addition to periodic inspections. STI SP001 should be referenced for any parameters outside this example or for other inspection options. Guidance for formal external inspections can also be found in STI SP001. The Fiberglass Tank and Pipe Institute (FTPI) 2007-1 Recommended Practice requires certified external inspections every 10 years and certified integrity inspections every 20 years. The certified inspector is responsible for providing Operator with the inspection reports, which are maintained on file with the SPCC Plan. Provision for inspecting, monitoring, and maintaining the integrity of flow -through vessels is provided in Section 9.6 of this SPCC Plan. 4.0 Personnel Training 4.1 Personnel Instruction [112.7(f)(1)] Training is provided for personnel involved with handling oil products and in the operation and maintenance of the AST systems to prevent discharges and requires that contracted personnel are similarly trained. Operations and maintenance training includes review of applicable owner's manuals and reference guides related to the tanks and associated equipment, and general facility operations. New hire training instructs oil handling personnel in the operation and maintenance of equipment to prevent discharges; discharge procedure protocols: applicable pollution control laws, rules, and regulations; general facility operations; and, the contents of the facility SPCC Plan. 4.2 Designated Individual for Spill Prevention [112.70)(2)] The designated individual for the C6 SPF spill prevention and reporting is Mr. Mike Campbell. 4.3 Spill Prevention Briefings [112.7(f)(3)] Spill prevention briefings are conducted at least annually during regularly scheduled safety meetings for all personnel involved with produced water handling operations to assure adequate understanding of the SPCC Plan. These briefings highlight and describe spill events or failures, malfunctioning components, recently developed precautionary measures, and a review of spill response deployment measures. Employees acknowledge attendance and understanding of these briefings with their signatures on an attendance form. An www.cgrs.com 800.288.2657 1301 Academy Ct. 16 Fort Collins. CO 80524 4 CGRS „,,, SoLUTionts pakv... SPCC Plan I NGL Water Solutions DJ, LLC I C6 Solids Processing Facility15/8/17 5/8/17 SPCC training attendance form is provided in Appendix H. Spill prevention briefing attendance forms are maintained on file in the operator's office. 5.0 Security 5.1 Securing and Controlling Access [112.7(g)] The C6 SPF is manned and operates 24 hours per day. 365 days per year. Access is controlled by the facility entry and exit roads and the requirement of personnel to check in at the office upon arrival. Security is provided by the presence of NGL operations personnel 24 hours per day which provides a deterrent to unauthorized access. Security cameras are also utilized at the C6 SPF to monitor operations. 5.2 Securing Master Flow/Drain Valves [112.7(g)] NGL locks master flow/drain valves on applicable ASTs when not in use, or in standby mode for extended periods of time. 5.3 Preventing Unauthorized Access to Starter Controls [112.7(g)] Starter controls for the AST transfer pumps are located in a control panel which is locked with switches in the off position when not in use, or in standby mode for extended periods of time. NGL limits access into the control panel to authorized personnel trained in the operation of the AST systems. 5.4 Securing Loading/Unloading Connections [112.7(g)] Loading/unloading pipe connections are securely capped and valves are locked when not in use. 5.5 Security Lighting [112.7(g)] Overhead lighting is present in all of the storage/transfer areas. and outlying areas that will assist in the discovery of discharges occurring during hours of darkness both by operating personnel and non -operating personnel, and to deter acts of vandalism. 6.0 Tank Truck Loading/Unloading 6.1 Secondary Containment for Loading/Unloading Areas Including Racks [112.7(h)(1)] Not applicable. There are no loading racks at the C6 SPF. 6.2 Warning/Barrier Systems [112.7(h)(2)] Not applicable. There are no loading racks at the C6 SPF. www.cgrs.com 800.288.2657 1301 Academy Ct. 17 Fort Collins. CO 80524 CGRS SOLUTIONS DELDvEAEC SPCC Plan I NGL Water Solutions DJ, LLC I C6 Solids Processing Facility 15/8/17 6.3 Bottom Drains of Vehicles Examined [112.7(11)(3)] N ot applicable. There are no loading racks at the C6 SPF. 7.0 Other General Requirements 7.1 Brittle Fracture/Other Failure — Field Constructed Aboveground Containers [112.7(i)] N ot applicable, the facility does not include field -constructed ASTs. 7.2 Conformance with Stricter State Rules [112.7(j)] N o stricter State discharge prevention and containment procedures are applicable to the facility. 7.3 Qualified Oil -Filled Operational Equipment [112.7(k)] The C6 SPF utilizes transformers that are owned and operated by a third party. 8.0 Facility Drainage 8.1 Drainage from Diked Areas [112.8(b)(1)] In the event of excess precipitation accumulation, minor spills, or AST or piping discharges within the secondary containment areas, fluids are allowed to drain into the containment sump via a drain located within the secondary containment, or pumped into processing tanks. Furthermore, precipitation onto the concrete unloading/loading pad flows into a central drain, which flows into the loading/unloading pad sump and is subsequently pumped to the unload tanks. A Dike Water Drainage Log is provided in Appendix I. 8.2 Dike Drainage Valves — Manual, Open/Closed Designed [112.8(b)(2)] Dike drainage valves utilized at the facility are designed for manual open/close operation. Drainage valves are kept in a closed position. 8.3 Drainage System for Undiked Areas [112.8(b)(3)] Secondary containment is provided for all aboveground tanks and tanker truck transfer areas to prevent discharges to storm drainages outside the contained areas. 8.4 Final Discharge Diversion System [112.8(b)(4)] In the event of a discharge outside a containment area, oil absorbent materials maintained at the facility will be used to contain a spill on -site. If required, earthen berms will be erected with available excavating equipment along the leading edge of the spill to retain oil on -site until cleanup measures are completed. www.cgrs.com 800.288.2657 1301 Academy Ct. 18 Fort Collins. CO 80524 Ai CGRS ,„„„, SOLUTIONS DELPVEAEO SPCC Plan I NGL Water Solutions DJ, LLC I C6 Solids Processing Facility 15/8/17 8.5 Backup Pump for Lift Station and Transfer Systems [112.8(b)(5)] Not applicable. The facility does not include drainage lift systems or drainage return transfer systems. 9.0 Bulk Storage Tanks 9.1 Containers Compatible with Materials Stored [112.8(c)(1)] The ASTs used for storage of petroleum products are designed and shop manufactured for their intended use, with materials compatible with the oil products stored and storage conditions such as pressure and temperature. 9.2 Secondary Containment [112.8(c)(2)] In addition to the loading/unloading pad containment, C6 SPF houses four additional secondary containment areas, as described below. Each secondary containment was constructed to accommodate a minimum 1.5 times the volume of the largest tank or compartment. Secondary containment volume calculations are presented in Appendix J. Aboveground Storage Tank Containment Secondary containment for the produced water and recovered oil ASTs (1-23) is provided by a concrete containment diked by walls 18 -inches in height. Any fluid that collects within the containment will drain to a sump (located inside the containment) before being pumped to the shaker tank for further processing. This process allows the C6 SPF to operate under a closed system and prevents any oil from being improperly drained or disposed of. The secondary containment is designed with adequate capacity to hold the volume of the largest tank (780 barrels) plus freeboard precipitation allowance. The total calculated holding capacity of the containment is approximately 2,705 barrels. When considering the freeboard allowance for a predicted 24 -hour, 25 -year storm event, the adjusted available holding capacity is approximately 1,717 barrels. Centrate/Filtrate Storage Tank Containment Secondary containment for the centrate/filtrate ASTs (25, 26, 27) is provided by a concrete containment diked by walls 48 -inches in height. Any fluid that collects within the containment will drain to a sump (located inside the containment) before being pumped to the shaker tank for further processing. The secondary containment is designed with adequate capacity to hold the volume of the largest tank (400 barrels) plus freeboard precipitation allowance. The total calculated holding capacity of the containment is approximately 800 barrels. When considering the freeboard allowance for a predicted 24 -hour, 25 -year storm event. the adjusted available holding capacity is approximately 582 barrels. Main Solids Processing Building Secondary containment for ASTs (28-32) within the main solids processing building is provided by the concrete foundation of the building, which was built nine -inches below grade to provide secondary containment for any rupture within the building. Any spill or release within the building flows to a central drain that diverts fluids to an www.cgrs.com 800.288.2657 1301 Academy Ct. 19 Fort Collins. CO 80524 _ SOLUTIONS DELIVERED CGRS SPCC Plan I NGL Water Solutions DJ, LLC I C6 Solids Processing Facility 15/8/17 interior sump on the west side of the building. From the sump, fluids are pumped to the brine tanks in the auxiliary solids processing building. The secondary containment is designed to adequately hold the volume of the largest tank (200 barrels) inside containment. The total calculated holding capacity of the containment is approximately 534 barrels. Being that the building is enclosed and not exposed to the elements, the freeboard precipitation allowance is not considered when calculating the available holding capacity. The available holding capacity (or. total calculated holding capacity of the containment minus the volume occupied by equipment) is 401 barrels. Auxiliary Solids Processing Building Secondary containment for ASTs (33-35) within the auxiliary solids processing building is provided by the concrete foundation of the building which was built four -inches below grade to provide secondary containment for any catastrophic rupture within the process building. Minor spills within the building flow to a central drain that diverts fluids to an interior sump on the east side of the building. From the sump, fluids are pumped to the brine tanks in the auxiliary building for further processing. The secondary containment is designed to adequately hold the volume of the largest tank (90 barrels) inside containment. The total calculated holding capacity of the containment is approximately 595 barrels. Being that the building is enclosed and not exposed to the elements, the freeboard precipitation allowance is not considered when calculating the available holding capacity. The available holding capacity (or, total calculated holding capacity of the containment minus the volume occupied by equipment and permeate tank) is 448 barrels. 9.3 Rainwater Drainage Procedure [112.8(c)(3)] Precipitation that accumulates within the diked areas is pumped into the unloading tanks before entering the system tanks. 9.4 Buried Metal Tanks Corrosion Protection [112.8(c)(4)] N ot applicable. The facility does not currently operate buried tanks. 9.5 Partially Buried Tanks Protected Against Corrosion [112.8(c)(5)] N ot applicable. The facility does not operate partially buried tanks. 9.6 Integrity Testing [112.8(c)(6)] N GL ensures that all ASTs and associated equipment are maintained and in operating condition. The ASTs, valves, transfer equipment, and aboveground piping components are readily accessible for visual inspection. Preventive spill measures include regular periodic inspections of the storage tanks and associated equipment and secondary containment systems following guidelines of the Steel Tank Institute (STI) Standard for the Inspection of Aboveground Storage Tanks SP001, September 2011, 5th Edition and the Fiberglass Tank and Pipe Institute (FTPI) 2007-1 Recommended Practice for the In-service Inspections of Aboveground Atmospheric Fiberglass Reinforced Plastic Tanks and Vessels. Based on tank volumes, tank configurations, the tanks being in contact with the ground, and spill control provided by secondary containment dikes, these activities include the following: www.cgrs.com 800.288.2657 1301 Academy Ct. 20 Fort Collins. CO 80524 Ai CORS ,.„, SOLUTIONS DEL+VEFIEO SPCC Plan I NGL Water Solutions DJ, LLC I C6 Solids Processing Facility 15/8/17 ■ On a monthly basis, the owner inspects the tanks. piping, and associated equipment for evidence of leakage. If needed, gaskets are replaced and threaded connections are tightened. Secondary containment areas are inspected for the presence of spills or leaks, which are removed if present. The containment sump pump is inspected to assure proper operating condition and that transfer piping is u nobstructed. Tank gauge calibrations are checked by obtaining stick readings to verify gauge readings. Overfill equipment is tested to ensure proper operation. ■ On an annual basis, the owner inspects the condition of the tank containment structure. Tank foundations and supports are inspected for evidence of settling, cracking or distortion, proper water drainage and grounding. Inspections of the AST exteriors are performed to identify and repair damage to the tanks or surface coatings. Bolts on flanged manways, piping and equipment are inspected for tightness, wear, and corrosion. Normal operating and emergency vents are inspected for proper operation and cleaned if n eeded. Tank liquid level sensing and overfill prevention devices are tested for proper operation. Electrical equipment, including grounding devices, control boxes and lights are inspected for proper operation. ■ According to the STI SP001. Formal External Inspections shall be performed on steel tanks by a Certified Tank Inspector every 20 years. The formal inspections generally include items covered in the monthly and annual inspections, comparison of tank conditions in relation to the original construction standards, and checking leak detection equipment. The extent and frequency of future inspections will be based on the recommendations of the Certified Tank Inspector. ■ According to the FTPI RP 2007-1. a Certified External Inspection shall be performed on fiberglass tanks by a Certified Tank Inspector every 10 years, or sooner if evidence of material stress appears or if a tank o r vessel leak occurs. Every 20 years. a Certified Integrity Inspection shall be performed by a Certified Tank Inspector in accordance with FTPI RP 2007-1. Any leaks discovered during inspection are promptly evaluated and reported to the facility manager. Operator assures that personnel who operate, maintain and inspect the AST systems are properly trained in the operation and maintenance of the systems, and characteristics of the fluids stored thereby reducing the probability for a spill. As noted in Section 3.1, monthly inspection documentation forms are provided in Appendix G. Written inspection records will be maintained with the SPCC Plan at the facility. 9.7 Internal Coils [112.8(c)(7)] Not applicable. The solids processing facility does not employee tanks with internal coils. 9.8 Engineered to Avoid Discharges [112.8(c)(8)] NGL only accepts product when there is adequate capacity in the tanks to receive the product. Monitoring of the transfer operation is done visually, with strict attention being paid to the volume received in accordance with available tank capacities. Tank levels are monitored by an automated system and sight confirmation of tank liquid levels are performed frequently. Tank filling does not begin until the plant operator has verified and documented the ullage (available capacity) based on tank monitoring sensors and sight confirmation. Furthermore, all system processing tanks are equipped with overfill pump shut off sensors, which automatically shut down the pumps once tanks reach a defined capacity. All product transfers are performed within secondary containment areas. The engineered design of the facility forms a closed loop system to contain spills and precipitation within the secondary containment areas and prevent discharges to the surrounding environment. www.cgrs.com 800.288.2657 1301 Academy Ct. 21 Fort Collins. CO 80524 r'� cc Rs SPCC Plan I NGL Water Solutions DJ, LLC C6 Solids Processing Facility 15/8/17 9.9 Plant Effluent Discharges into Navigable Water [112.8(c)(9)] There are no effluent discharges from the facility to navigable waters. 9.10 Oil Leaks Promptly Corrected [112.8(c)(10)] Oil leaks identified through routine inspection are promptly corrected and reported to the facility manager or the identified alternate contact. Any accumulation of oil in diked areas is promptly removed. 9.11 Mobile or Portable Oil Storage Tanks [112.8(c)(11)] Oil -handling personnel are instructed to store oil-bearing tanks within containment and maintain appropriate seals and plugs on any containers when not in use to prevent spills. A spill kit is also maintained at the processing building. If a spill occurs, spilled product will be contained within the building walls and cleaned up with readily available oil absorbent materials. 10.0 Facility Transfer Operations 10.1 General General safety features which are applicable to maintaining the integrity of transfer operations include: ■ Valves and pipelines are examined monthly to assess the condition of the transfer equipment. ■ Steel pipes aboveground have a coating of paint to help prevent corrosion. ■ If corrosion damage is found, additional examination and corrective action is taken as appropriate for the magnitude of the damage. 10.2 Buried Pipe Installations [112.8(d)(1)] Most facility piping is aboveground and accessible for inspection. All underground piping is constructed with schedule 80 PVC, which is not susceptible to corrosion and does not require cathodic protection. If a section of buried pipe is exposed for any reason. it will be carefully inspected for deterioration. If deterioration or damage is found, additional examination and corrective action will be taken as indicated by the magnitude of the damage. 10.3 Terminal Pipe Connections Capped or Blank Flanged [112.8(d)(2)] There are no out -of -service pipes associated with the AST systems. The terminal pipe connections where the tanker trucks connect to unload oil from the recovered oil ASTs are securely capped and remain in the AST containment when not in use. The connections are also marked as to origin. 10.4 Aboveground Pipe Supports [112.8(d)(3)] NGL maintains adequate bracing on aboveground pipe runs to avoid excess movement that can cause stress and abrasion. Aboveground piping is of heavy gauge steel construction and is installed per manufacturer specifications. Piping is securely attached with threaded fittings to the tanks and the various piping components are supported with steel braces and connected to the tank and concrete. www.cgrs.com 800.288.2657 1301 Academy Ct. 22 Fort Collins. CO 80524 4 CGRS „...„, 5OLuTIONS DELIVERED SPCC Plan I NGL Water Solutions DJ, LLC I C6 Solids Processing Facility 15/8/17 10.5 Testing and Inspection of Aboveground Pipes and Valves [112.8(d)(4)] As discussed in section 9.6, valves and piping are examined monthly to assess the condition of the transfer equipment. If corrosion damage or leakage at valves or pipe connections is found, additional examination and corrective action will be taken commensurate with the magnitude of the damage. 10.6 Warning for Trucks of Pipes [112.8(d)(5)] No aboveground piping is exposed outside of the secondary containment, or exposed to vehicular traffic. The u nloading pumps and associated piping are protected by steel bollards. NGL instructs personnel operating in the u nloading area to be aware of piping and pumping equipment and to use caution when approaching the area. 11.0 Substantial Harm [112.20(e)] 40 CFR Part 112.20 (f)(1), lists criteria under which "a facility could, because of its location, reasonably be expected to cause substantial harm to the environment by discharging oil into or on the navigable waters or adjoining shorelines..." if it meets any of the listed criteria. The C6 Facility does not meet the listed criteria, including: (1) does not transfer oil over water; and (2) have total oil storage capacities of less than one million gallons. Because of the design of the ASTs, no history of spills to navigable waters, no proximity to drinking water intakes, and the well -trained operational personnel monitoring the facility, no Facility Response Plan should be required. The required Certification of Applicability of the Substantial Harm Criteria checklist, Part 112.20, Appendix C, Attachment C -II, has been completed for each facility and is maintained with the SPCC Plan in Appendix K. 12.0 Oil Spill Contingency Plan [109.5] 12.1 Purpose and Scope This Oil Spill Contingency Plan (Contingency Plan) is prepared in accordance with 40 CFR Part 112.7(d) to address Operator flowlines that are not provided with secondary containment. The purpose of this Contingency Plan is to define procedures and tactics for responding to discharges of oil into navigable waters or adjoining shorelines of the United States, originating from the applicable flowlines between the injection well and associated equipment. The Contingency Plan is implemented whenever a discharge of oil has reached. or threatens, n avigable waters or adjoining shorelines. The objective of procedures described in this Contingency Plan is to protect the public, Operator, contract personnel, and other responders during an oil discharge. In addition, the Contingency Plan is intended to minimize damage to the environment, natural resources, and facility installations from a discharge of oil. This Contingency Plan complements the prevention and control measures presented in the SPCC Plan by addressing the flowlines that are not provided with secondary containment and impacts that may result from a discharge from the flowlines. The flowlines applicable to the Contingency Plan are depicted on a facility specific Site Condition Map in Figure 2 of the SPCC Plan. The Operator implements a detailed and stringent flowline maintenance and inspection program to prevent and identify leaks from the primary flowline systems, which is discussed in Section 9.6 and 10.5 of the SPCC Plan. www.cgrs.com 800.288.2657 1301 Academy Ct. 23 Fort Collins. CO 80524 Firr AD CGRS „„,,, SOLUTIONS DELivEQEC SPCC Plan I NGL Water Solutions DJ, LLC I C6 Solids Processing Facility 5/8/17 This Oil Spill Contingency Plan follows the content and organization of 40 CFR Part 109 and describes the distribution of responsibilities and basic procedures for responding to an oil discharge and performing cleanup operations. 12.2 Authorities, Responsibilities, and Duties [109.5(a)] The facility operator has the primary responsibility for providing the initial response to oil discharge incidents originating from its facility. To accomplish this, the designated individual for spill prevention is the Site Manager who will act as the Response Coordinator (RC) in the event of an oil discharge. The RC plays a central coordinating role in any emergency situation, and has the authority to commit the necessary services and equipment to respond to the discharge and to request assistance from the local fire authority and/or the local sheriff's department, contractors. or other responders. as appropriate. 12.3 Notification Procedures [109.5(b)] The RC will direct notifications and initial response actions in accordance with training and capabilities. In the event of a fire or emergency situation that threatens the health and safety of those present at the site. the RC will direct evacuations and contact the local fire authority and sheriff's department. In the event of an emergency involving outside response agencies, the RC's primary responsibility is to provide information regarding the characteristics of the materials and equipment involved and to provide access to Operator response personnel and cleanup contractors as requested. The RC shall also take necessary measures to control the flow of people, emergency equipment. and supplies, and obtain the support of the local fire authority and sheriff's department, as needed, to maintain control of the site. These controls may be necessary to minimize injuries and confusion. 12.3.1 Critical Water Use Areas [109.5(13)(1)] ■ The nearest critical water use area to the location for the site is the Bebe Seep Canal, located approximately 2.5 miles east of the site. The C6 SPF facility is surrounded by native grasses and undeveloped land. Several agricultural lie between the Bebe Seep Canal and the facility location. If a release were to occur from one of the aboveground flowlines outside of secondary containment, the oil would ultimately be retained within the surrounding soil, or a nearby agricultural cut out or drainage ditch well before it reached the Bebe Seep Canal. The site location and proximity to surface waters is depicted in the Figure 1 Attachment of this SPCC Plan. 12.3.2 Emergency Contacts and Notification Procedures [109.5(13)(2)] As discussed in Section 2.12 of the SPCC Plan, a contact list and phone numbers for individuals, emergency response authorities, and regulatory agencies to be notified in the event of leakage or spills is provided on the second page of this plan. See Appendix D for additional information on emergency discharge situations and descriptions. www.cgrs.com 800.288.2657 1301 Academy Ct. 24 Fort Collins. CO 80524 this, 5Ot_UTIONS DEL►vEAEO ,_ SPCC Plan ( NGL Water Solutions DJ, LLC C6 Solids Processing Facility 15/8/17 12.3.3 Communication System for Timely Notification [109.5(b)(3)] Facility personnel and contract personnel have access to cell phones to immediately contact the RC in the event a spill is identified. The RC serves as the coordinator for communications by acquiring all essential information and ensuring clear communication of information to emergency response personnel. The RC has access to reference material on the flowline locations and specifications at the main office either as printed material or on computer files that can further assist the response activities. Whenever circumstances permit. the RC transmits assessments and recommendations to Operator Senior Management for direction. In the event that the primary RC is not available. the responsibility and authority for initiating a response to a discharge rests with the most senior Operator Manager on site at the time the discharge is discovered. 12.3.4 Procedure for Requesting Assistance During Major Disaster [109.5(b)(4)] In the event of a major disaster or if the situation exceeds the response capabilities of the local emergency responders or State authorities (COGCC), the RC will consult with the on -scene Field Supervisors of the local emergency responders and COGCC Officer, and as agreed, either one of the Field Supervisors or the RC will contact the National Response Center to request further assistance. 12.4 Commitment of Resources [109.5(c)] Operator is committed to providing the manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful. Furthermore, Operator assures that designated facility spill response personnel are aware of the location and use of spill response resources. 12.4.1 Inventory of Spill Response Resources [109.5(c)(1), (c)(2), and (c)(3)] Oil absorbent materials and hand tools for use in digging catchment pits, trenches. and/or erecting earthen barriers to contain spills are maintained on -site and accessible to facility personnel either working in the area or responding to a spill. An estimate of the response materials and equipment present to respond to a potential flowline spill include: ■ Loose granular oil absorbent and/or pads or booms capable of containing and cleaning up minor spills are available on -site. Shovels for use in erecting earthen barriers, digging cutoff trenches or pits along the leading edge of a spill for containment are also available to staff. ■ Heavy equipment that includes backhoes and front-end loaders can be dispatched for use in erecting earthen barriers for spill control/containment and excavation to implement immediate cleanup of oil impacted soil. ■ Vacuum trucks can be dispatched to expeditiously remove free -phase oil from spill containment areas, drainage pathways, and/or from impacted surface water. The spill response oil absorbent materials and tools are sufficient to respond to most minor discharges that could occur at the facility and to initially contain a major discharge until additional materials, equipment, and support arrive from outside contractors and/or emergency responders. Inventories of spill response materials and tools are checked daily during scheduled facility inspections by designated personnel. and are replenished as needed. www.cgrs.com 800.288.2657 1301 Academy Ct. 25 Fort Collins. CO 80524 4 CGRS rn,„, SOLUTIONS DELivEAEO SPCC Plan ( NGL Water Solutions DJ, LLC ( C6 Solids Processing Facility 15/8/17 12.5 Actions To Be Taken After Discovery and Notification [109.5(d)] 12.5.1 Discharge Response Operating Team [109.5(d)(1)] As discussed in Section 4.0 of the SPCC Plan, Operator provides, or requires contractors to obtain training, which includes spill response review and deployment exercises, and annual spill prevention briefings for personnel involved with handling oil products. operating, and maintaining the facility. The spill response team consists of the RC or designated alternate who is in charge of coordinating spill response activities and facility maintenance personnel who operate and maintain the facility. The facility is manned and operates 24 hours per day, 365 days per year. An oil spill from a flowline will most likely be identified within a short period of time and reported to the RC. Based on communicated reports from the first responder(s), the RC will deploy trained operations personnel with appropriate spill response materials and equipment, as indicated by the magnitude of the spill. 12.5.2 Response Coordinator [109.5(d)(2)] As discussed in Sections 2.0 and 3.0 above, the Operator designates a qualified oil discharge RC as Site Manager (see the second page of this SPCC plan for RC identification). Through experience and training, the RC is fully knowledgeable of all facility operations, equipment safety and maintenance protocol, and lines of communication with applicable local, State, and Federal authorities, including those specified in Section 3.2, associated with spill response. 12.5.3 Spill Response Center [109.5(d)(3)] The spill response center is the facility office (see front cover for address). As discussed in Section 3.0 above, Operator and contract personnel are equipped with cell phones to immediately contact the RC in the event a spill is identified. In turn, the RC has readily available communication devices including a cell phone to communicate information to emergency response personnel and notify local, State, and Federal authorities. 12.5.4 Spill Response Level of Effort and Order of Priority [109.5(d)(4), (d)(5)] After identifying and locating a spill, control and countermeasure actions taken will depend on whether the oil is contained. All efforts will be made to prevent oil from reaching surface water. Based on safety concerns with the flowlines, any attempts to stop additional spillage will only be performed by qualified facility personnel or authorized contractors familiar with the facility equipment and operations. ■ If the oil has not yet reached surface water: Erect temporary barriers down gradient of the spill such as trenches or earthen mounds to prevent the oil from flowing down a surface drainage pathway. ■ If the oil has reached water: Contact local fire authority and cleanup contractor(s). c Deploy oil -only floating booms immediately downstream from the release point. Control oil flow on the ground by placing granular absorbent, absorbent pads. and other sorbent material or physical barriers (e.g.. available loose soil, pits, trenches, earthen berm) across the oil flow path. www.cgrs.com 800.288.2657 1301 Academy Ct. 26 Fort Collins. CO 80524 4 CGRS ,„,,,, SoLut,ON5 DEL,VEFf-C SPCC Plan I NGL Water Solutions DJ, LLC I C6 Solids Processing Facility 15/8/17 Deploy additional oil absorbent pads and/or booms across the whole length of the impacted ground surface. The flowline locations and surface flow features are depicted on a facility specific Site Layout Map (Figure 2) included in the SPCC Plan. 12.6 Cleanup, Disposal, Reporting, and Review [109.5(e)] 12.6.1 Cleanup Materials recovered during cleanup must be placed in appropriate containers (such as DOT rated drums), impervious bags or buckets with labels describing the contents, or stockpiled using an impermeable liner and cover (such as polyethylene sheeting) to prevent cross -contamination with unexposed media prior to disposal. The RC ensures that cleanup has been completed and that the contaminated area has been treated or mitigated according to the applicable State and/or Federal cleanup action levels. Furthermore, the RC collaborates with the applicable local. State. and/or Federal authorities regarding the assessment of damages. 12.6.2 Disposal The RC ensures that all contaminated materials generated during cleanup are properly characterized as non- hazardous or hazardous waste and disposed of at an appropriate facility permitted with the CDPHE, or other appropriate regulatory authority, to receive the type of waste being shipped and each shipment documented using proper manifest or bill -of -lading forms. 12.6.3 Reporting Operator will submit a follow-up written report to COGCC and other appropriate regulatory agencies requesting documentation of the spill event and mitigation activities within 10 days following a release. or in accordance with requirements of the agency. See COGCC Rule 906. 12.6.4 Review After the spill cleanup activities have been completed, the RC will ensure that all repairs to the defective equipment have been completed. Circumstances that led to the discharge will be reviewed and all necessary precautions taken to prevent or reduce the likelihood of a recurrence. The effectiveness of the response activities will be evaluated and adjustments made as necessary to response procedures and personnel training. The review process will include debriefing personnel and contractors, as necessary, to emphasize prevention measures or to communicate changes in operations or response procedures. www.cgrs.com 800.288.2657 1301 Academy Ct. 27 Fort Collins. CO 80524 CGRS SOLUTIONS DELIVERED Figures Figure 1: Site Location Figure 2: Site Layout Figure 2C: Solids Processing Facility Site Details www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 COLORADO ■ QUADRANGLE LOCATION SITE LOCATION NORTH 1000 2000 SCALE IN FEET Wind iN,4 BS, r PROJECT: 1-8019-10695aa DATE: 1/30/2017 FIGURE 1 SITE LOCATION MAP NGL WATER SOLUTIONS DJ. LLC C6 FACILITY 13159 WCR 39 PLATTEVILLE, COLORADO DRAFT: SJK REVIEW: ...EP C 7✓E S TIC c+Eq.-0—;41 b�Ll OADNGAANtCMDN: PAD APPROACH SOEDS ►ROLEaSiNO FActUry 1 N wsRSETE C(arrste T OKI HATE R TR EA 1 NENT AND C ONORIONANG PROCEDE SAL DWG NCi TANKS MESS CONCRETE SE:ONDART CONTAINMENT wrtcnw w[la RECYCLED *ATER LOADING PAD IOAONOUNtOADM.T PAD DOAN 1LNDIGAIN.OAPN RAC DEPMTVRE AscAtoROI'Nt, PIPING GEiT I MkTTOROJND P► k° CONCRETE I.OWAIM WENT \‘ 1r Cut UERT CONCRETE CONTANUE NT SCALE IN FEET ','W-3 ® PSRIP LEGEND MONITORING WELL LOCATION PAD SUB -SUMP MONITORING POI,' PAD SUB -SUMP MONITORING POINT • s SECURITY CAMERA -�� SURFICIAL FLOW DIRECTION 3 WATER SPIGOT 0 ELECTRICAL TRANSFORMER J sPILL KIT STREET LIGHT INDICATES APPLICABLE AREA A "I0 r: SECONDARY CONTAINMENT FENCE LINE STAIRS / CATWALK OXIDIZER BOLLARD 2000 GALLON SEPTIC TANK SALTWATER DISPOSAL FACUTY SCUDS PROCESSING FACIUTY FIGURE 2 SITE LAYOUT SALTWATER DISPOSAL FACILITY NOL WATER SOLUTIONS DJ. LLC Cd FACILITY 13160 wCR JD PLATTEVILLE. COLORADO =u:E 148319.106140 DATE 5/3/2017 DRAFT DRS REvIEw `R RECYCLED wATER�/ _ LEGEND • ® e MW SPF --" O Q -3 MONITORING WELL LOCATION PSMP PAD SUB -SUMP MONITORING POINT SUB -SUMP MONITORING POINT OXIDIZER ELECTRICAL TRANSFORMER IO/DNG PAL, 6I.... -4::_ .100- i OCIME„IC WATER -441 HELL y -, c- yr -r � � `• �+s / -'- I f DECK S 2000 GALLON SEPTIC TANK -Ow FLOW SURFACE DIRECTION •s SECURITY CAMERA 0 SPILL KIT * OVERHEAD LIGHT • BOLLARD - FENCE • LOAD«avNLDAnIw PAD DRAM - J v \ /7 I Is IDADNavNLowNu �_. i ` ` r c,.. ER INDICATES APPLICABLE AREA WITHIN V • ~ r I t -t +- . LOAD►IOJNLDADINO DBARTtAE 6.........11 1 ouMPDTER CWTAIRMENT SECONDARY CONTAINMENT MAP SIZE PROCESS • rah '` y A iir NI I. 1 r 1 A6OAGR0WD PNWO • T8C PW PW 3 78: PW sri�r �6,A� �►�/ 4 78' PW o4 a © I _ .rte .RAN came YOROn 5 780 PW 8 400 OIL 7 4X OIL .0 a ] O Oc J SOLIDS B 400 OIL *010. OFFICE - r• STORAGE 9 400 OIL LEC + { BUILDING f AS f 10 400 OIL ® .0 0 0 AUXILIARY SOLIDS 0 ® ® 1 400 OIL PROCESSING BUILDING a + ': 400 OIL - • _ ' 3 400 OIL J/ / 0� , -..- ® © ® _ • K • 1a 400 OIL ,r GENERATOR 4: 15 400 OIL E ` • OS. ROOM tAil o ®• • 16 400 OIL 1? 400 OIL `� • or. ...--17:3-, " • 18 400 OIL O �- • 19 400 OIL / 15) VIA' 47 It J rya+owo • • 20 400 OIL SQm5 ►ROCESSWOFKCrtY w _ .4 �+ I CDN0IETE cc«oyETE �CorrA,NaENr • • 21 400 OIL 22 400 OIL N CDNCRETE COIRA•IAIENT DINE \I .O • F L.. ��. CCN!At11f.E NT • ;► • • • • • j, / lit • • • v. • • •0 r w..! 23 400 OIL 24 300 FERRIC ACID 25 400 CENTRATEcILTRATE 28 400 CENTRATEIFILTRATE 27 400 CENTRATEJFILTRATE 28 200 REACTION TANK 29 32 PERLITE TANK •- _ r--- '�' PROPANE TANK 30 37 PERLITE TANK 31 33 SLURRIFK:ATION TANK -1 . • P R � ....awe. r - ; •�rI 32 33 SLt1RRIflK) GATN TANK 33 128 PERMEATE TANK - 34 90 BRINE TANK SA: T �P :.. '� _ ...1.: 35 90 BRINE TANK 36 500 SHAKER TANK 41101�;'��E1+ r . r J•� ' .. `+_ , • . ,_V a• w I • I Mkt It • • 4. FIGURE 2C SITE DETAILS SOLIDS PROCESSING FACILITY NGL WATER SOLUTIONS DJ. LLC O6 FACILITY 13169 WCR 39 PLATTEVILLE COLORADO N PROJECT CRAFT o to jo so a so 14019-10666611 DRS S CGRS DATE PEvEw t_.\11 •oanwwa. SCALE IN FFET 5/3/2017 CGRS SOLUTIONS DELIVERED Appendix A SPCC Review Log for Technical Amendments www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 CGRS SOLUTIONS DELIVERED REVIEW LOG FOR TECHNICAL AMENDMENTS Company Name: Facility Name: In accordance with 40 CFR Part 112.5(b), a review and evaluation of this Spill Prevention Control and Countermeasure (SPCC) Plan will be conducted at least every five years. As a result of such a review and evaluation, the SPCC Plan will be amended within six months of completing said review and evaluation to include more effective and proven prevention and control technologies if: 1) such technologies will significantly reduce the likelihood of a spill event from the facility, and 2) if such technologies have been field -proven at the time of review. Any amendment to this SPCC Plan shall be certified by a Professional Engineer. in accordance with 40 CFR Part 112.3(d), within six months after a change in the facility design, construction, operation, or maintenance occurs which materially affects the facility's potential for the discharge of oil into or upon the navigable waters or the United States or adjoining shorelines (40 CFR Part 112.5(a)). Amendments to the plan shall be completed and implemented within six months of the facility changes. • I have completed review and evaluation of the SPCC Plan for NGL Water Solutions, DJ, C6 Facility and ( will / will not ) amend the plan as a result. Date Name Signature Title Amendment (if applicable) Certifying Engineer Statement (if applicable) This plan amendment was prepared using sound engineering practices. I have examined the facility and find this plan conforms to the guidelines and provisions of 40 CFR Part 112. Date Name Signature • I have completed review and evaluation of the SPCC Plan for NGL Water Solutions, DJ, C6 Facility and ( will / will not ) amend the plan as a result. Date Name Signature Title Amendment (if applicable) Certifying Engineer Statement (if applicable) This plan amendment was prepared using sound engineering practices. I have examined the facility and find this plan conforms to the guidelines and provisions of 40 CFR Part 112. Date Name Signature www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 4,0.CGRS SOLUTIONS DELIVERED Appendix B SPCC Review Log for Non -Technical Amendments www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 CGRS SOLUTIONS DELIVERED REVIEW LOG FOR NON -TECHNICAL AMENDMENTS Company Name: Facility Name: REVIEW AND AMENDMENT LOG Review/Amend Date Signature g Amend (will / will Plan not) Description Amendment of Review Affected Pa e(s g www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 CGRS SOLUTIONS DELIVERED Appendix C DOT Requirements www.cgrs.com 800.288.2657 1301 Academy Ct. Fort CoIlms, CO 80524 CGRS SOLUTIONS DELIVERED DOT REQUIREMENTS Code of Federal Regulations - Title 49 - Transportation § 173.30 Loading and unloading of transport vehicles. A person who is subject to the loading and unloading regulations in this subchapter must load or unload hazardous materials into or from a transport vehicle or vessel in conformance with the applicable loading and unloading requirements of parts 174. 175, 176, and 177 of this subchapter. [68 FR 61941, Oct. 30, 2003] PART 177 - CARRIAGE BY PUBLIC HIGHWAY - Subpart B - Loading and Unloading Note: For prohibited loading and storage of hazardous materials, see § 177.848. § 177.834 General requirements. (a) Packages secured in a motor vehicle. Any package containing any hazardous material, not permanently attached to a motor vehicle, must be secured against shifting. including relative motion between packages. within the vehicle on which it is being transported, under conditions normally incident to transportation. Packages having valves or other fittings must be loaded in a manner to minimize the likelihood of damage during transportation. (b) Each package containing a hazardous material bearing package orientation markings prescribed in § 172.312 of this subchapter must be loaded on a transport vehicle or within a freight container in accordance with such markings and must remain in the correct position indicated by the markings during transportation. (c) No smoking while loading or unloading. Smoking on or about any motor vehicle while loading or unloading any Class 1 (explosive). Class 3 (flammable liquid), Class 4 (flammable solid). Class 5 (oxidizing). or Division 2.1 (flammable gas) materials is forbidden. (d) Keep fire away, loading and unloading. Extreme care shall be taken in the loading or unloading of any Class 1 (explosive), Class 3 (flammable liquid). Class 4 (flammable solid), Class 5 (oxidizing), or Division 2.1 (flammable gas) materials into or from any motor vehicle to keep fire away and to prevent persons in the vicinity from smoking, lighting matches, or carrying any flame or lighted cigar, pipe, or cigarette. (e) Handbrake set while loading and unloading. No hazardous material shall be loaded into or on, or unloaded from, any motor vehicle unless the handbrake be securely set and all other reasonable precautions be taken to prevent motion of the motor vehicle during such loading or unloading process. (f) Use of tools, loading and unloading. No tools which are likely to damage the effectiveness of the closure of any package or other container, or likely adversely to affect such package or container, shall be used for the loading or unloading of any Class 1 (explosive) material or other dangerous article. (g) [Reserved] (h) Precautions concerning containers in transit: fueling road units. Reasonable care should be taken to prevent undue rise in temperature of containers and their contents during transit. There must be no tampering with such container or the contents thereof nor any discharge of the contents of any container between point of origin and point of billed destination. Discharge of contents of any container, other than a cargo tank or IM portable tank, must not be made prior to removal from the motor vehicle. Nothing contained in this paragraph shall be so construed as to prohibit the fueling of machinery or vehicles used in road construction or maintenance. (i) Attendance requirements (1) Loading. A cargo tank must be attended by a qualified person at all times when it is being loaded. The person who is responsible for loading the cargo tank is also responsible for ensuring that it is so attended. www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins, CO 80524 CGRS lool SOLUTIONS DELIVERED (2) Unloading. A motor carrier who transports hazardous materials by a cargo tank must ensure that the cargo tank is attended by a qualified person at all times during unloading. However, the carrier's obligation to ensure attendance during unloading ceases when: (i) The carrier's obligation for transporting the materials is fulfilled; (ii) The cargo tank has been placed upon the consignee's premises; and (iii) The motive power has been removed from the cargo tank and removed from the premises. (3) Except for unloading operations subject to §§ 177.837(d), 177.840(p), and 177.840(q), a qualified person "attends" the loading or unloading of a cargo tank if, throughout the process, he is alert and is within 7.62 m (25 feet) of the cargo tank. The qualified person attending the unloading of a cargo tank must have an unobstructed view of the cargo tank and delivery hose to the maximum extent practicable during the unloading operation. (4) A person is "qualified" if he has been made aware of the nature of the hazardous material which is to be loaded or unloaded. he has been instructed on the procedures to be followed in emergencies, he is authorized to move the cargo tank. and he has the means to do so. (j) Except for a cargo tank conforming to § 173.29(b)(2) of this subchapter, a person may not drive a cargo tank motor vehicle containing a hazardous material regardless of quantity unless: (1) All manhole closures are closed and secured; and (2) All valves and other closures in liquid discharge systems are closed and free of leaks. (k) [Reserved] (I) Use of cargo heaters when transporting certain hazardous material. Transportation includes loading, carrying, and unloading. (1) When transporting Class 1 (explosive) materials. A motor vehicle equipped with a cargo heater of any type may transport Class 1 (explosive) materials only if the cargo heater is rendered inoperable by: (i) Draining or removing the cargo heater fuel tank; and (ii) disconnecting the heater's power source. (2) When transporting certain flammable material (i) Use of combustion cargo heaters. A motor vehicle equipped with a combustion cargo heater may be used to transport Class 3 (flammable liquid) or Division 2.1 (flammable gas) materials only if each of the following requirements are met: (A) It is a catalytic heater. (B) The heater's surface temperature cannot exceed 54 °C (130 °F) either on a thermostatically controlled heater or on a heater without thermostatic control when the outside or ambient temperature is 16 °C (61 °F) or less (C) The heater is not ignited in a loaded vehicle. (D) There is no flame, either on the catalyst or anywhere in the heater. (E) The manufacturer has certified that the heater meets the requirements under paragraph (I)(2)(i) of this section by permanently marking the heater "MEETS DOT REQUIREMENTS FOR CATALYTIC HEATERS USED WITH FLAMMABLE LIQUID AND GAS." (F) The heater is also marked "DO NOT LOAD INTO OR USE IN CARGO COMPARTMENTS CONTAINING FLAMMABLE LIQUID OR GAS IF FLAME IS VISIBLE ON CATALYST OR IN HEATER." (G) Heater requirements under § 393.77 of this title are complied with. (ii) Effective date for combustion heater requirements. The requirements under paragraph (I)(2)(i) of this section govern as follows: (A) Use of a heater manufactured after November 14, 1975, is governed by every requirement under (I)(2)(i) of this section; (B) Use of a heater manufactured before November 15, 1975, is governed only by the requirements under (I)(2)(i) (A), (C), (D), (F) and (G) of this section until October 1, 1976; and www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 CORS100, SOLUTIONS DELIVERED (C) Use of any heater after September 30, 1976, is governed by every requirement under paragraph (I)(2)(i) of this section (iii) Restrictions on automatic cargo -space -heating temperature control devices. Restrictions on these devices have two dimensions: Restrictions upon use and restrictions which apply when the device must not be used. (A) Use restrictions. An automatic cargo -space -heating temperature control device may be used when transporting Class 3 (flammable liquid) or Division 2.1 (flammable gas) materials only if each of the following requirements is met: (1) Electrical apparatus in the cargo compartment is nonsparking or explosion proof. (2) There is no combustion apparatus in the cargo compartment. (3) There is no connection for return of air from the cargo compartment to the combustion apparatus. (4) The heating system will not heat any part of the cargo to more than 54 °C (129 °F). (5) Heater requirements under § 393.77 of this title are complied with. (B) Protection against use. Class 3 (flammable liquid) or Division 2.1 (flammable gas) materials may be transported by a vehicle, which is equipped with an automatic cargo -space -heating temperature control device that does not meet each requirement of paragraph (l)(2)(iii)(A) of this section, only if the device is first rendered inoperable, as follows: (1) Each cargo heater fuel tank, if other than LPG, must be emptied or removed. (2) Each LPG fuel tank for automatic temperature control equipment must have its discharge valve closed and its fuel feed line disconnected. (m) Tanks constructed and maintained in compliance with Spec. 106A or 110A (§§ 179.300, 179.301 of this subchapter) that are authorized for the shipment of hazardous materials by highway in part 173 of this subchapter must be carried in accordance with the following requirements: (1) Tanks must be securely chocked or clamped on vehicles to prevent any shifting. (2) Equipment suitable for handling a tank must be provided at any point where a tank is to be loaded upon or removed from a vehicle. (3) No more than two cargo carrying vehicles may be in the same combination of vehicles. (4) Compliance with §§ 174.200 and 174.204 of this subchapter for combination rail freight. highway shipments and for trailer -on -flat -car service is required. (n) Specification 56, 57, IM 101. and IM 102 portable tanks, when loaded, may not be stacked on each other nor placed under other freight during transportation by motor vehicle. (o) Unloading of IM and UN portable tanks. No person may unload an IM or UN portable tank while it remains on a transport vehicle with the motive power unit attached except under the following conditions: (1) The unloading operation must be attended by a qualified person in accordance with the requirements in paragraph (i) of this section. The person performing unloading functions must be trained in handling emergencies that may occur during the unloading operation. (2) Prior to unloading, the operator of the vehicle on which the portable tank is transported must ascertain that the conditions of this paragraph (o) are met. (3) An IM or UN portable tank equipped with a bottom outlet as authorized in Column (7) of the § 172.101 Table of this subchapter by assignment of a T Code in the appropriate proper shipping name entry, and that contains a liquid hazardous material of Class 3. PG I or II. or PG III with a flash point of less than 100 °F (38 °C); Division 5.1, PG I or II; or Division 6.1, PG I or II, must conform to the outlet requirements in § 178.275(d)(3) of this subchapter. [29 FR 18795, Dec. 29, 1964. Redesignated at 32 FR 5606. Apr. 5. 1967] www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 CGRS SOLUTIONS DELIVERED § 177.837 Class 3 materials. (See also § 177.834 (a) to (j).) (a) Engine stopped. Unless the engine of a cargo tank motor vehicle is to be used for the operation of a pump, Class 3 material may not be loaded into, or on, or unloaded from any cargo tank motor vehicle while the engine is running. The diesel engine of a cargo tank motor vehicle may be left running during the loading and unloading of a Class 3 material if the ambient atmospheric temperature is at or below -12 °C (10 °F). (b) Bonding and grounding containers other than cargo tanks prior to and during transfer of lading. For containers which are not in metallic contact with each other, either metallic bonds or ground conductors shall be provided for the neutralization of possible static charges prior to and during transfers of Class 3 (flammable liquid) materials between such containers. Such bonding shall be made by first connecting an electric conductor to the container to be filled and subsequently connecting the conductor to the container from which the liquid is to come, and not in any other order. To provide against ignition of vapors by discharge of static electricity, the latter connection shall be made at a point well removed from the opening from which the Class 3 (flammable liquid) material is to be discharged. (c) Bonding and grounding cargo tanks before and during transfer of lading. (1) When a cargo tank is loaded through an open filling hole, one end of a bond wire shall be connected to the stationary system piping or integrally connected steel framing, and the other end to the shell of the cargo tank to provide a continuous electrical connection. (If bonding is to the framing, it is essential that piping and framing be electrically interconnected.) This connection must be made before any filling hole is opened, and must remain in place until after the last filling hole has been closed. Additional bond wires are not needed around All -Metal flexible or swivel joints, but are required for nonmetallic flexible connections in the stationary system piping. When a cargo tank is unloaded by a suction -piping system through an open filling hole of the cargo tank, electrical continuity shall be maintained from cargo tank to receiving tank. (2) When a cargo tank is loaded or unloaded through a vapor -tight (not open hole) top or bottom connection, so that there is no release of vapor at a point where a spark could occur, bonding or grounding is not required. Contact of the closed connection must be made before flow starts and must not be broken until after the flow is completed. (3) Bonding or grounding is not required when a cargo tank is unloaded through a nonvapor-tight connection into a stationary tank provided the metallic filling connection is maintained in contact with the filling hole. (d) Unloading combustible liquids. For a cargo tank unloading a material meeting the definition for combustible liquid in § 173.150(f) of this subchapter, the qualified person attending the unloading operation must remain within 45.72 meters (150 feet) of the cargo tank and 7.62 meters (25 feet) of the delivery hose and must observe both the cargo tank and the receiving container at least once every five minutes during unloading operations that take more than five minutes to complete. [29 FR 18795, Dec. 29. 1964] www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 CGRS ii, SOLUTIONS DELIVERED Appendix D Emergency Spill Response Procedures www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 CORS 00/ SOLUTIONS DELIVERED EMERGENCY SPILL RESPONSE PROCEDURES Refer to the second page of this report for specific phone numbers. ■ After identifying and locating a spill, containment must be initiated as soon as possible to prevent undue spreading of released product. The first action should be the elimination of any additional spillage by shutting off a pump or valve, placing a cap or a plastic or epoxy patch over the leak, putting a temporary plug in a puncture or tear, righting an overturned container, or other appropriate action. ■ Spill response materials maintained within field service vehicles will be used to contain and clean up spilled product. Place portable dike materials or erect berms with granular absorbent or earthen material along the leading edge of the spill to prevent spreading. Apply absorbent pads or granular absorbent to the spilled product for clean up. ■ Materials recovered during cleanup must be placed in appropriate containers (such as DOT rated drums) or stockpiled using an impermeable liner and cover (such as polyethylene sheeting) to prevent cross - contamination with unexposed media prior to disposal. ■ EPA 40-CFR-PART 112.4(a) Whenever the facility has discharged more than 1,000 U.S. gallons (23.8 bbl) of oil in a single discharge, or discharged more than 42 U.S. gallons (1 bbl) of oil in each of two discharges, occurring within any twelve month period, the Operator shall submit a report to the Regional Administrator within 60 days from the day of the discharge. ■ COGCC Rule 906 Report to the Director. Operators shall report a spill or release of E&P Waste or produced fluids that meet any of the following criteria to the Director verbally or in writing as soon as practicable, but no more than twenty-four (24) hours after discovery (the "Initial Report"). A. A spills/release of any size that impacts or threatens to impact any waters of the state, a residence or occupied structure, livestock, or public byway; B. A spill/release in which one (1) barrel or more of E&P Waste or produced fluids is spilled or released outside of berms or other secondary containment; C. A spill/release of five (5) barrels or more regardless of whether the spill/release is completely contained within berms or other secondary containment. If the Initial Report was not made by submitting a COGCC Spill/Release Report. Form 19 the Operator must submit a Form 19 with the Initial Report information as soon as practicable but not later than 72 hours after discovery of the spill/release unless extended by the Director. In addition to the Initial Report to the Director, the Operator shall make a supplemental report on Form 19 not more than 10 calendar days after the spill/release is discovered that includes an 8 1/2 x 11 inch topographic map showing the governmental section and location of the spill or an aerial photograph showing the location of the spill: all pertinent information about the spill/release known to the Operator that has not been reported previously; www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 esE CGRS ••• SOLUTIONS DELIVERED and information relating to the initial mitigation, site investigation. and remediation measures conducted by the Operator. Notification to the local government. In addition to the Initial Report to the Director, as soon as practicable, but not more than 24 hours after discovery of a spill/release of E & P Waste or produced fluids reportable under Rule 906.b.(1)A or B, above; an Operator shall provide verbal or written notification to the entity with jurisdiction over emergency response within the local municipality if the spill/release occurred within a municipality or the local county if the spill/release did not occur within a municipality. The notification shall include, at a minimum, the information provided in the Initial Report to the Director. Notification to the Surface Owner. In addition to the Initial Report to the Director, within 24 hours after discovery of a spill/release of E & P Waste or produced fluids reportable under Rule 906.b.(1)A or B, an Operator shall provide verbal notification to the affected Surface Owner or the Surface Owner's appointed tenant. If the Surface Owner cannot be reached within 24 hours, the Operator shall continue good faith efforts to notify the Surface Owner until notice has been provided. The verbal notification shall include, at a minimum, the information provided in the Initial Report to the Director. Report to Environmental Release/Incident Report Hotline. A spill/release of any size which impact or threaten to impact any surface water supply area shall be reported to the Director and to the Environmental Release/Incident Report Hotline (1-877-518-5608). Spills and releases that impact or threaten a surface water intake shall be verbally reported to the emergency contact for that facility immediately after discovery. Reporting chemical spills or releases. Chemical spills and releases shall be reported in accordance with applicable state and federal laws. including the Emergency Planning and Community Right -to -Know Act, the Comprehensive Environmental Response, Compensation, and Liability Act, the Oil Pollution Act, and the Clean Water Act, as applicable. www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 CGRS SOLUTIONS DELLVERED Appendix E Spill Response Notification Form www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 • Fs CGRS SOLUTIONS DELIVERED SPILL RESPONSE NOTIFICATION FORM Fill Contact out this List form as for guidance completely on as regulatory possible agencies prior to calling to notify regulatory and telephone agencies. numbers. Refer to the Emergency RELEASE INFORMATION Notification Person Name: Date: Time: Agency Being Notified: Phone Number: Facility Name: Address: City: State: Zip Code: Telephone Number: Fax Number: Owner/Operator Name: Address: City: State: Zip Code: Primary Contact Name / Position: Work Phone: Cell Phone: Other (24 -Hour): Location of Release: Address: . Section: Range: County: Township: Latitude: Longitude: Date/Time of Release: Date/Time of Discovery: of Oil Released: Quantity Released: Duration of Release: Type Describe Source and Cause of Release: Actions Taken to Stop. Contain. Remove and Mitigate Impacts of the Release: Impacted (Check All Media: That Apply) Soil Water Air Stormwater Sewer Sanitary Sewer Dike/Berm Oil -Water Separator Other: Did Oil Reach a Waterway: Yes/No Quantity Released to Waterway: Waterway Name: Number of Injuries: Number of Deaths: Was Evacuation Required: Yes / No Environmental Impacts: Was Damage: Yes / No Damage Cost: $ There Notification Person: Work Phone: Cell Phone: Other (24 -Hour): Any additional information about the incident that was not recorded elsewhere: Local Agency Notified: State Agency Notified: Federal Agency Notified: State/Local Agency On -Scene: Other: www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 CGRS SOLUTIONS DELIVERED Appendix F COGCC Form 19 Spill/Release Report www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 FORM 19 Rev 6/99 State of Colorado Oil and Gas Conservation Commission 1120 Lincoln Street, Suite 801, Denver, Colorado 80203 (303)894-2100 Fax (303)894-2109 SPILL/RELEASE REPORT This form is to be submitted by the party responsible for the oil and gas spill or release Any spill or release which may impact waters of the State must be reported as soon as practicable, any spill over 20 bbls must be reported within 24 hours and all spills over five bbls must be reported within ten days Submit a Site Investigation and Remediation Workplan (Form 27) when requested by the Director OPERATOR INFORMATION Name of Operator OGCC Operator No Address City State Zip Contact Person FOR OGCC USE ONLY Spill report taken by FACILITY ID Phone Numbers No Fax E -Mail DESCRIPTION OF SPILL OR RELEASE Date of Incident Facility Name & No Type of Facility (well, tank battery, flow line, pit) Well Name and Number API Number Specify volume spilled and recovered (m Oil spilled Oil recov'd Ground Water impacted? Contained within berm? Current land use ❑ Yes ❑ Yes El County QtrQtr Township Meridian Section Range bbls) for fie following materials Water spilled Water recov'd Other spilled No Surface Water impacted? ❑ Yes ❑ No No Area and vertical extent of spill Weather conditions Other recov'd x Sod/geology description IF LESS THAN A MILE, report distance IN FEET to nearest Livestock Cause of spill (e g , equipment failure, human error, etc ) Surface water water wells wetlands buildings Depth to shallowest ground water Detailed description of the spill/release incident CORRECTIVE ACTION Describe immediate response (how stopped, contained and recovered) Describe any emergency pits constructed How was the extent of contamination determined Further remediation activities proposed (attach separate sheet if needed) Describe measures taken to prevent problem from reoccurring OTHER NOTIFICATIONS List the parties and agencies notified (County, BLM, EPA, DOT, Local Emergency Planning Coordinator or other Date Agency Contact Phone Response Spill/ReleaseTracking No• 4si CGRS TI 1 SOLUTIONS DELIVERED Appendix G Monthly Visual Inspection Form www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins, Co 80524 40 CGRS SOLUTIONS DELIVERED girwiniglaw MONTHLY VISUAL INSPECTION FORM Facility Name: nspection Date: Facility Location: nspector Name: Oil Tanks Inspected (ID #s): Production Water Tanks Inspected (ID #s): Inspector: Please note any additional comments or recommendations in the space provided at the end of the inspection form. Furthermore. please indicate the tank ID if an issue is noted. Item Inspected Status 'Comments (A) SECONDARY CONTAINMENT STRUCTURE(S) 1. satisfactory product. Secondary water, containment condition? debris (Free and fire structure of hazards) standing in No Yes If taken/required done. "no," describe and to correct record problem action and date 2. obstructions? Containment entry/exits clear of No Yes If taken/required done. "no," describe and to correct record problem action and date 3. Secondary or other evidence containment of release? shows staining No Yes If taken/required done. "yes.' describe and to correct record problem action and date , 4. other Secondary structural containment faults? shows cracks or No Yes If taken/required done. "yes," describe to and correct record problem action and date 5. operable Secondary and containment closed? drain valve(s) No Yes N/A taken/required If done. "no," describe to and correct record problem action and date Page 1 of 5 www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 CO CGRS 00, SOLUTIONS DELIVERED MONTHLY VISUAL INSPECTION FORM Facility Name: Inspection Date: Item Inspected 'Status Comments (B) OIL AND PRODUCED WATER STORAGE TANKS General Tank Condition 1. roof pealing, Evidence paint of coating noticeable failure? or rust) tank (Cracking, shell and No Yes If taken/required "yes," describe and to correct record problem action and date done. blistering, 2. roof cracking, general deterioration) Evidence integrity damage, buckling of failure? noticeable or corrosion, (Distortions. bulging, tank or shell holes, or No Yes If taken/required "yes," describe and to correct record problem action and date done. 3. Standing water present on tank roof? No Yes If taken/required "yes," describe and to correct record problem action and date done. 4. volume missing Are contents label, or damaged? and hazards warning (Contents label. signs etc.) label. No Yes If taken/required "yes," describe to and correct record problem action and date done. 5. with damage? Ladder no or sign platform of severe structure corrosion secure or No Yes N/A If to "no," describe correct problem and and record date action done. taken/required Tank Foundation and Supports 6. foundation burrowing? Evidence of washout, tank settlement. or animal No Yes taken/required If "yes," describe to and correct record problem action and date done. 7. condition? Tank and pipe supports in satisfactory No Yes to If "no," describe correct problem and and record date action done. taken/required 13. tank? Water able to drain away from the No Yes to If "no," describe correct problem and and record date action done. taken/required Page 2of5 www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 CGRS SOLUTIONS DELIVERED MONTHLY VISUAL INSPECTION FORM Facility Name: Inspection Date: Item Inspected Status}Comments 8. Grounding good condition? strap(s) secured and in No Yes N/A If to "no," describe correct problem and and record date action done. taken/required Tank Component Condition & Leak Detection 9. Visible seams. connections. leaks/staining fittings on tanks, tank No Yes If taken/required "yes," identify to tank, correct describe problem and record and date action done. or valves? the 10. Evidence ground of surface? leakage or spillage on No Yes If taken/required "yes," describe and to correct record problem action and date done. tight leakage? 11. seals, Flanged with valve no pipe seals, signs connections, gaskets, of wear, and corrosion thief bolts hatch or No Yes If to "no," describe correct problem and and record date action done. taken/required 12. Buried piping is exposed? No Yes If taken/required "yes," describe and to correct record problem action and date done. 13. blank Are flanged out -of -service or valves pipes locked? capped, , No Yes N/A to If "no," describe correct problem and and record date action done. taken/required 14. (Enardo Normal vents. vents atmospheric free of obstructions? vents) No Yes to If "no," describe correct problem and and record date action done. taken/required 15. as Thief required? hatch vent(s) operable and lifts No Yes to If "no," describe correct problem and and record date action done. taken/required Page 3of5 www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins, CO 80524 : at, CGRS SOLUTIONS DELIVERED MONTHLY VISUAL INSPECTION FORM Facility Name: Inspection Date: item Inspected Status Comments 16. device operation? Has the been tank tested liquid to ensure level sensing proper No Yes N/A If "no.- when will it be tested? 17. device Does operate tank liquid as required? level sensing No Yes N/A If correct "no." describe problem and and record date done. action taken/required to 18. proper Are overfill working prevention condition? devices in No Yes If correct "no," describe problem and and record date done. action taken/required to (C) WELLHEADS, FLOWLINES/PIPING AND RELATED EQUIPMENT - OUTSIDE CONTAINMENT fittings, 1. components, Visible flanges. leaks aboveground on or the valves? well head(s), pipes, No , Yes N/A If to "yes," describe correct problem and and record date done. action taken/required 2. and Evidence gaskets? of leakage at valve seals No Yes If to "yes," describe correct problem and and record date done. action taken/required 3. Buried flowlines are exposed? No Yes If to "yes," describe correct problem and and record date done. action taken/required 4. show ground evidence surface of leakage? above flowlines No Yes If to "yes," describe correct problem and and record date done. action taken/required The (D) TRUCK LOADING AND TRANSFER EQUIPMENT (Within flanged) 1. Are connections containment capped? vessel or blank No Yes If correct "no." describe problem and and record date done. action taken/required to Page 4of5 www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 CGRS SOLUTIONS DELIVERED MONTHLY VISUAL INSPECTION FORM Facility Name: Inspection Date: Item Inspected Status 'Comments 2. leaking vessel(s)? Evidence of from the accumulated spill containment oil within or No Yes N/A If to eyes," describe correct problem and and record date done. action taken/required 3. deteriorated? Loading pipes are damaged or No Yes If to "yes," describe correct problem and and record date done. action taken/required 4. vehicular Loading traffic? pipes are protected from No Yes If correct "no," describe problem and and record date done. action taken/required to 5. the Cracks loading/unloading or other structural pad observed? faults in No Yes If to "yes," describe correct problem and and record date done. action taken/required 6. station Disconnect A sign is that posted states, Hose Before at 'Warning. the transfer Departing'? No Yes If correct "no." describe problem and and record date done. action taken/required to Additional Comments: Inspector Name: Signature: Date: Page 5 of 5 www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 1 CGRS SOLUTIONS DELIVERED Appendix H SPCC Spill Preparedness Training www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 ,r p s /•- :ja h♦ CGRS SOLUTIONS DELIVERED SPCC SPILL PREPAREDNESS TRAINING COMPANY NAME/ADDRESS: FACILITY NAME(s)/LOCATION(s): INSTRUCTOR(s): SUBJECT: SIGNATURES OF ATTENDEES: Signature indicates awareness and understanding of the SPCC Plan and its contents. Signature Printed Name Date www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins, CO 80524 CGRS SOLUTIONS DELIVERED Appendix I Dike Water Drainage Log www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 CORS SOLUTIONS DELIVERED DIKE WATER DRAINAGE LOG This discharged the diked log is area. to from be completed the The dike diked valve whenever area. must The dike be water closed valve is discharged must promptly remain after from closed the a diked diked except area. when area is Only drained. draining clean water water may from be Facility Name Address Dike Area # or Date Oil Sheen resen.rainageeganStopped or Time ODescriptionened Dike Valve or Time Closed Dike Valve or Signature g , , , 1 , *Note: from Contaminated disposal the Water diked or recycling. which water area. must or has transported visible be treated oil off or so that -site sheen by is does a must licensed not not contain hazardous be discharged oil or a visible waste from or sheen used the diked oil prior contractor area. to being for discharged proper www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 CGRS SOLUTIONS DELIVERED Appendix J Secondary Containment Volume Calculations www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 SECONDARY CONTAINMENT VOLUME CALCULATIONS C6 - Solids Processing Facility Loading/Unloading Pad Containment 1. Applicable Measurements Volume of Largest Tank (Shaker Tank) _ Pad Seconda East Pad Height (HE) East Pad Length (LE) East Pad Width (WE) West Pad Height (Hw) West Pad Length (Lw) West Pad Width (W„ �) rY Containment ft. ft. ft. 1.5 60 82 1.5 38 82 ft. ft. ft. 500 bbls 25 -year, 24 -hr storm event rainfall = Pad Containment Drain Trench Height (HT,) Trench Height (HT2) Trench Length (LT) Trench Width (WT) 0.5 1.5 82 2 ft. ft. ft. ft. 3.39 Pad Sump Sump Depth (HS) Sump Length (Ls) Sump Width (WS) 7 12 12 in ft. ft. ft. 2. Gross Containment Volume (GCV) at Containment West of Trench i i --- i i i ' i i i i i mom . w ' West Pad Length (LW) - -la Air 40 Containment East of Trench .00 . I I I I I 40. Volume of Containment West of Trench (Vw) = 1/2 * (Lw * Ww * Hw) East Pad Width (WE) East Pad Height (HE) 2,337 Volume of Containment East of Trench (VE) = 1/2 * (LE* WE * HE) i r . I I I I I I I West Pad Height (Hw) West Pad Width (WW) 3,690 cubic ft. cubic ft. SECONDARY CONTAINMENT VOLUME CALCULATIONS C6 - Solids Processing Facility Loading/Unloading Pad Containment Trench Length (LT) Trench Height (HT2) I , .0 . .0t .0 . . , 40 , . , , , , ...0, .0.. , H Trench Width (WT) 40 Volume of Containment in Trench (VT) _ (LT ' WT * ((HT1 + HT2) / 2)) r i , Trench Height (Hu) 164 4 Sump Width (WS) Volume of Containment in Sump (VS) = WS H, Gross Containment Volume (GCV) _ (VE + VW + VT + VS) J' ,T A cubic ft. Sump Depth (HS) Sump Length (Ls) 1.008 7,199 cubic ft. cubic ft. 3. Estimated Freeboard Allowance (predicted 25 -year, 24 -hour storm event) Total Freeboard Volume = TA ' (Rainfall Height) 2,317 cubic ft. 4. Final Conclusion Gross Containment Volume (GCV) Available Holding Capacity (ADV minus Freeboard Allowance) 7,199 4,883 cubic ft. cubic ft. ***SECONDARY CONTAINMENT IS ADEQUATELY SIZED*** 1,282 870 bbls bbls Note Freeboard allowance is based on a historical 25 -year 24 -hour storm event for the region from the National Oceanic and Atmospheric Administration's (NOAA) Atlas 14, Volume 8, Version 2. SECONDARY CONTAINMENT VOLUME CALCULATIONS - CONCRETE DIKE C6 - Solids Processing Facility Aboveground Storage Tank Containment 1. Applicable Measurements: Volume of Largest Tank = Secondary Containment Dike Height (H) *Dike Length (Li) *Dike Width (W, *Dike Length (L2) *Dike Width (W2) *Dike Length (L3) *Dike Width (W3) 18 118.67 40.67 88.67 44.67 43.67 30.67 in. ft. ft. ft. ft. ft. ft. 780 i bbls 12 ft. Diameter Tanks Diameter Quantity 12 18 ft. 15.5 ft. Diameter Tanks Diameter Quantity 25 -year, 24 -hr storm event rainfall = *Length and width represent the inside measurements of the containment 15.5 4 3.39 1 2. Gross Diked Volume (GDV) Length (Li) Gross Diked Volume = (L,*W,*H) + (L2*W2*H) + (L3*W3*H) 15,190 cubic ft. 3. Base Area of Vertical Tanks (within the containment other than the single largest) 12 ft. Diameter Tank Volume 15.5 ft. Diameter Tank Volume Total Tank Occupied Volume Within Diked Area 4. Adjusted Diked Volume (ADV) Adjusted Diked Vol = GDV - Tank Occupied Vol 3,054 1,132 4,186 11,004 cubic ft. cubic ft. cubic ft. cubic ft. 5. Estimated Freeboard Allowance (predicted 25 -year, 24 -hour storm event) Total Freeboard Volume = (L,*W,*Rain) + (L2*W2*Rain) + (L3*W3*Rain) 1,363 cubic ft. 6. Final Conclusion Gross Diked Volume (GDV) Available Holding Capacity (ADV minus Freeboard Allowance) 15,190 9,641 cubic ft. cubic ft. 2,705 1,717 ***SECONDARY CONTAINMENT IS ADEQUATELY SIZED*** bbls bbls Note: Freeboard allowance is based on a historical 25 -year 24 -hour storm event for the region from the National Oceanic and Atmospheric Administration's (NOAA) Atlas 14, Volume 8. Version 2. SECONDARY CONTAINMENT VOLUME CALCULATIONS - CONCRETE DIKE C6 - Solids Processing Facility Centrate/Filtrate Storage Tank Containment 1. Applicable Measurements: Volume of Largest Tank = Secondary Containment Dike Height (H) *Dike Length (L) *Dike Width (W) 48 52.2 21.5 in. ft. ft. 400 bbls 12 ft. Diameter Tanks Diameter Quantity 12 2 ft. 25 -year, 24 -hr storm event rainfall = *Length and width represent the inside measurements of the containment 3.39 2. Gross Diked Volume (GDV) Length (L) Gross Diked Volume = Length *Width * Height Height (H) 4,489 cubic ft. 3. Base Area of Vertical Tanks (within the containment other than the single largest) Total Tank Occupied Volume Within Diked Area = 905 cubic ft. 4. Adjusted Diked Volume (ADV) Adjusted Diked Vol = GDV - Tank Occupied Vol • • 3,584 cubic ft. 5. Estimated Freeboard Allowance (predicted 25 -year, 24 -hour storm event) Total Freeboard Volume = L *W * (Rainfall Height) 317 cubic ft. 6. Final Conclusion Gross Diked Volume (GDV) Available Holding Capacity (ADV minus Freeboard Allowance) 4,489 3,267 cubic ft. cubic ft. • • • • 800 582 ***SECONDARY CONTAINMENT IS ADEQUATELY SIZED*** bbls bbls Note: Freeboard allowance is based on a historical 25 -year 24 -hour storm event for the region from the National Oceanic and Atmospheric Administration's (NOAA) Atlas 14, Volume 8, Version 2. SECONDARY CONTAINMENT VOLUME CALCULATIONS - CONCRETE DIKE C6 - Solids Processing Facility Main Solids Processing Building 1. Applicable Measurements: Volume of Largest Tank = Secondary Containment Dike Height (H) Dike Length (L) Dike Width (W) 9 80 50 in. ft. ft. 200 bbls 2. Gross Diked Volume (GDV) Gross Diked Volume = Length * Width * Height 3. Estimated Occupied Volume (EOV) Estimated Volume Occupied by Equipment 4. Adjusted Diked Volume (ADV) Adjusted Diked Vol = GDV - EOV Height (H) 3,000 750 2,250 cubic ft. cubic ft. cubic ft. 5. Final Conclusion Gross Diked Volume (GDV) Available Holding Capacity 3,000 2,250 cubic ft. cubic ft. ***SECONDARY CONTAINMENT IS ADEQUATELY SIZED*** 534 401 bbls bbls SECONDARY CONTAINMENT VOLUME CALCULATIONS - CONCRETE DIKE C6 - Solids Processing Facility Auxiliary Solids Processing Building 1. Applicable Measurements: Volume of Largest Tank = Secondary Containment Dike Height (H) Building Length (L) Building Width (W) *Dike Length (L,) *Dike Width (W, *Dike Length (L2) *Dike Width (W2) *Dike Length (L3) *Dike Width (W3) 9 60 100 30 11 17 25 18 44 in. ft. ft. ft. ft. ft. ft. ft. ft. i _ 90 bbls Storage Tanks Diameter Quantity 8 2 ft. *Length and width represent the inside measurements of the containment 2. Gross Diked Volume (GDV) Length (L) Gross Diked Volume =RL*W)-((L,*W,)+(L2*W2)+(L3*W3))]*H 3,340 cubic ft. 3. Base Area of Vertical Tanks (within the containment other than the single largest) Total Tank Occupied Volume Within Diked Area 4. Estimated Occupied Volume (EOV) Estimated Volume Occupied by Equipment 5. Adjusted Diked Volume (ADV) Adjusted Diked Vol = GDV - Tank Occupied Vol 75 750 2,514 cubic ft. cubic ft. cubic ft. 6. Final Conclusion Gross Diked Volume (GDV) Available Holding Capacity 3,340 2,514 cubic ft. cubic ft. 595 448 ***SECONDARY CONTAINMENT IS ADEQUATELY SIZED*** bbls bbls to CGRS SOLUTIONS DELIVERED Appendix K Substantial Harm Criteria Checklist www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 CGRS SOLUTIONS DELIVERED CERTIFICATION OF THE APPLICABILITY OF THE SUBSTANTIAL HARM CRITERIA CHECKLIST FACILITY NAME: LOCATION: 1. Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000 gallons? Yes No X 2. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and does the facility lack secondary containment that is sufficiently large to contain the capacity of the largest aboveground oil storage tank plus sufficient freeboard to allow for precipitation within any aboveground oil storage tank area? Yes No X 3. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance (as calculated using the appropriate formula in Attachment C -III or a comparable formulas) such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments? For further description of fish and wildlife and sensitive environments, see Appendices I, II, and III to DOC/NOAA's 'Guidance Guidance for Facility and Vessel Response Plans: Fish and Wildlife and Sensitive Environments" (see Appendix E. section 13, for availability) and the applicable Area Contingency Plan. Yes No X 4. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance (as calculated using the appropriate formula in Attachment C -III or a comparable formula) such that a discharge from the facility would shut down a public drinking water intake'? Yes No X 5. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and has the facility experienced a reportable oil discharge in an amount greater than or equal to 10,000 gallons within the last 5 years? Yes No X CERTIFICATION certify under penalty of law that I have personally examined and am familiar with the information submitted in this document. and that based on my inquiry of those individuals responsible for obtaining this information, believe that the submitted information is true, accurate, and complete. Name (please type or print) Title Form 40 CFR 112 Appendix C, Attachment C -II Signature Date www.cgrs.com 800.288.2657 1301 Academy Ct. Fort Collins. CO 80524 APPENDIX C SITE GROUNDWATER MONITORING PLAN CG October 31, 2014 Mr. Jack Lopez M3 Construction 2681 W. 120th Ave, Ste. 250 Westminster, CO 80234 Via email; jlopez@M3-consult.com Subject: Dear Mr. Lopez, Site Groundwater Monitoring Plan NGL Water Solutions: C6 Facility 13159 WCR 39 Platteville, Colorado 80651 S1/2, E1/4, Sec. 30, T3N, R65W CGRS Project No.1-12462-10695ae ENVIRONMENTAL EE This correspondence summarizes the water quality monitoring program and well construction details from groundwater monitoring wells located at the above -referenced NGL Water Solutions (NGL) production water disposal and solid waste processing facility. Water quality sampling activities for the C6 facility are performed on a quarterly basis. The most recent sampling activities were performed on September 16, 2014. Water quality samples obtained from the groundwater monitoring wells are analyzed for benzene, toluene, ethylbenzene, and xylenes (BTEX), total dissolved solids (TDS), dissolved metals, and chlorides. These compounds are commonly associated with the oil field production water and associated sediment which is disposed of at the NGL facility. The water quality monitoring program provides baseline background groundwater quality data, which will facilitate early detection of an unknown release of production water related to facility operations. Furthermore, depth to groundwater is measured in each monitoring well and the groundwater elevation, flow direction and hydraulic gradient are calculated using surveyed well elevations in order to monitor groundwater flow trends. A total of four groundwater monitoring wells (MW -3, MW -4, MW -5, and MW -6) have been installed for facility monitoring purposes. An additional monitoring well has been proposed downgradient of the solids processing tank farm. See Figure 2 for monitoring well locations and site condition details. The monitoring wells were installed to a depth of approximately 30 to 53 feet below ground surface (bgs). The wells were constructed with approximately 25 to 35 feet of 2 -inch diameter, 10 -slot PVC screen and approximately 10 to 23 feet of solid PVC riser based on the depth to groundwater in each well location. 10/20 silica sand surrounds the screened portion of the wells to a depth of 2 feet above the well screen, at which point the well bore is sealed with hydrated bentonite to the surface. The wells are finished with either a flush mounted steel manway or a 3 foot aluminum locking stick up mount. Based on information collected during well installation activities, the subsurface lithology generally consists of alternating layers of sand and silty sand to sandy/silty clay and clay from the surface to approximately 20 to 41 feet bgs. Starting at approximately 20 to 41 feet bgs, weathered blocky claystone with secondary calcareous and iron oxide mineralization was encountered to the total depth of the borings. Semi-annual groundwater quality monitoring has been ongoing since November, 2007, and has recently been adjusted to a quarterly monitoring schedule per the suggestion of the Weld County Department of Public Health and Environment. Historic groundwater monitoring data indicates groundwater depths across the site vary from approximately 14 to 29 feet below the top of the surveyed well casings. OC 1301 Academy Court Fort Collins, CO 80524 T 800-288-2657 F 970-493-7986 www.cgrs.com Site Groundwater Monitoring Plan NGL Water Solutions; C6 Disposal Facility 13159 Weld County Road 39 Platteville, Weld County, Colorado S1/2, E1/4, Sec. 30, T3N, R65 W Furthermore, data indicates a consistent groundwater flow direction to the southeast towards monitoring wells MW -5 and MW -3 at a calculated hydraulic gradient of 0.05 ft/ft. CGRS' Methods and Procedures for field and reporting activities are provided in Attachment A. CGRS appreciates the opportunity to provide consulting services to NGL Water Solutions. Should you have any questions or require additional information, please call me at (800) 288-2657 or email to ksutton@cgrs.com. Sincerely, CGRS, Inc., Kelly Sutton Project Manager/Scientist Reviewed By: Craig Mulica Associate Geologist Enclosures: Figure 1 — Site Location map Figure 2 — Site Overview Attachment A: CGRS' Field and Reporting Methods and Procedures cc. 2: us -40 LL -4• Iy �O O , AtAILIARr SOLIDS PROCESSIN ,BUI OFFLOAD SHAKERS 01 000 `4 o0 � D°D raCOC saw ma« .y wn 000 00000 00000000 O 00000 00000 SOLIDS PROCESSING TANK FARM IN CONCRETE CONTAINMENT DIKE CONCRETE UNLOADING PAD PROPOSED MONITORING WELL LOCATION r NAME 90k /V[GETATo• Orj OO 00 O I �1Av9 OFFICE x x A X X X X x x x x x x X 7t • LEGEND MONITORING v/LL(. LC.CA!iU!: TREE ELECTRIAL TRANSFORMER BOLLARD PUMP OVERHEAD LIGHT WATER WELL ELECTRICALIELEPHONE UTILITY CORRIDOR FENCE LINE p NATURAL GAS UNE OVERHEAD ELECTRIC LINE FIBER OPTICS LINE yy WATER LINE 1 INJECTION WELL WATER LM:' E ELECTRICAL LINE ABOVEGROUND STORAGE TANK ABOVEGROUND STORAGE TANK (FUTURE INS TALIA T/ON LOCATION 0 7 !G fix SCALE IN FEET FIGURE 2 SITE OVERVIEW NOL WATER SOLUTIONS C-6 FACILITY 13160 WCR JC PLATTEVILLE CO_.^Rir:e PROJECT 14019-' 0695r DATE 10/3112014 DRAFT AASB REVIEW \ ATTACHMENT A CGRS' Field and Reporting Methods and Procedures CGRS, INC NGL Water Solutions C6 Facility METHODS AND PROCEDURES NOL Water Solutions: C6 Disposal Facility S % E % Section 30, T3N, R65W 13159 WCR 39 Platteville, Weld County, Colorado CGRS Project # 1-12462-10695ae Soil Borings Soil sampling will be conducted to accordance with ASTM D 1586-87 Using this procedure, a 2 -inch O D split -spoon sampler will be dnven mto the soil by a 140 -pound weight falling 30 inches After an nutial set of 6 mches, the number of blows required to dnve the sample an additional 12 inches, known as the penetration resistance (N value), will be recorded The N value is an index of the relative density of cohesionless soils and the consistency of cohesive soils Soil Classificahon/Characterization As samples are obtained in the field, they will be visually inspected and classified m accordance with ASTM D 1488-84 Representative portions of the samples will then be retained for further examination and for venfication of the vanous strata, the N value, water level data, and pertinent information regarding the method of mamtanung and advancing the bonng will be provided Charts illustrating the soil classification procedure, descnptive terminology and symbols used on the logs will be provided As samples are collected they will be examined for evidence of petroleum hydrocarbons using visual appearance, odor, and by screening with portable,phototonization equipment Decontamination To avoid potential transport of contaminated matenals to the project site, all dnllmg equipment and down - hole tools will be steam cleaned pnor to mobihzation To prevent cross contamination between soil bonngs or momtonng wells all down -hole equipment will also be steam cleaned and rinsed with water between soil borings Momtonng Well Construction New Momtonng wells will be installed utilizing the following general construction cntena ® borehole diameter minimum 2 0 inches push probe / 6 25 mches conventional boring ® well diameter 1 inch for push probe / 2 inches for conventional boring ® estimated depth > 5 feet below static groundwater table -a- CGRS, INC NGL Water Solutions C6 Facility ® casing matenal schedule 40, flush thread PVC • well screen 1 inch I D for push probe / 2 inch I D for conventional bonng, # 0 01 slot PVC • estimated screened interval 10 feet above and 10 feet below the groundwater table (may be ) adjusted based on total depth and water table position) • annular pack 10-20 silica sand e protective casing 4" aluminum above grade mount, locking cap • annular seal cement grout and bentomte pellets Groundwater Sampling All borings where groundwater is encountered will be sampled from the suspected cleanest to the most contaminated according to the protocols listed below All pertment information will be recorded on a samplmg information form Field Protocol Step 1 - Measure water level Step 2 - A dedicated polyethylene bailer will be used to develop each bonng Three bore volumes will be evacuated from each bonng pnor to sampling Step 3 - Collect water samples Water samples will be collected using a polyethylene bailer Step 4 - Store samples in a cooler on ice for transport to the laboratory Follow all documentation and chain -of -custody procedures Step 5 - Clean equipment Water level measurement equipment will be cleaned with ethanol followed by a delonized water nnse Upon completion of soil or groundwater sampling, a chain of custody log will be initiated A copy of the chain of custody will be returned to the project manager Chemical Analysis An approved contract laboratory will provide stationary laboratory analysis The following analyses will be performed Soil Analyses Chemical Parameters Benzene/Toluene/Ethylbenzene/Total Xylenes Total Recoverable Petroleum Hydrocarbons Method Used EPA - 8260 EPA - 418 1 -b- CGRS,LINC NGL Water Solutions C6 Facility Total Metals EPA 6010C & 7471B Water Analyses Benzene/Toluene/Ethylbenzene/Total Xylenes (BTEX) Total Dissolved Solids (TDS) Chloride Dissolved Metals Groundwater Trend Analyses EPA - 8260 B EPA - 160 1 EPA - 300 1 EPA -3005A Groundwater concentrations are measured in site monitonng wells on a quarterly basis Upon receiving groundwater analytical data from the laboratory the data is inserted into an histonc groundwater analytical data table Chlondes and TDS concentrations will be evaluated to ensure that the current concentrations in each well do not exceed 1 25 times the average background conditions If results indicate that this threshold is exceeded, then further analyses or investigation will be conducted Any BTEX constituents above the Colorado Oil and Gas Conservation Commission (COGCC) maximum allowable concentrations (MACs) discovered in a momtonng well water quality sample will be reanalyzed at the laboratory If the laboratory re -analyses confirms the presence of a BTEX constituent above the MACs then the well will be resampled The presence of BTEX above MACs will prompt a complete evaluation of site operations since the last quarterly sampling event, and prompt further subsurface investigation if warranted Groundwater Elevation Measurements The followmg outlines our standard groundwater quality sampling methodology Before purging any of the soil test bonngs or momtormg wells, water level measurements must be taken Measurinz Point Estabhsh the measuring point for the well The measuring point is marked on the north side of the top of the temporary momtonng well nser The top of the nser is normally a 2 -inch schedule 40 PVC casmg mside a locked protective casing The measunng point should be descnbed on the groundwater sample collection record -c- CGRS, INC NGL Water Solutions C6 Facility Access After unlocking or opening a momtonng well, the first task will be to obtain a water level measurement Water level measurements will be made using an electronic water level mdicator Depth to water and total depth of the well will be measured for calculation of purge volume Measurement To obtain a water level measurement, lower a decontaminated electronic water level probe into the momtonng well Care must be taken to assure that the electronic probe hangs freely m the momtonng well and is not adhering to the well casmg The electronic probe will be lowered mto the well until the audible sound of the unit is detected and the light on the electromc sounder illuminates At this time, the precise measurement should be determined by repeatedly raising and lowenng the probe to obtam an exact measurement The water level measurement is then entered on the groundwater sampling collection record sheet or groundwater level data sheet to the nearest 0 01 feet Decontamination The electronic probe shall be decontaminated immediately after use by wipmg with isopropyl alcohol - soaked paper towels Always proceed in order from the suspected cleanest well or soil test boring to the suspected most contaminated one Purge Volume Computation All soil test bonngs and temporary momtonng wells will be purged pnor to sample collection Dependmg upon the rate of recovery, three to five volumes of groundwater present in a well or borehole shall be withdrawn pnor to sample collection If a well or bore hole bails dry, the well or bore hole should be allowed to recharge and a sample taken as soon as there is sufficient volume for the mtended analysis The volume of water present to each well or bore hole shall be computed using the two measurable vanables, length of water column in soil bonng or momtonng well depth and diameter Purgmg and Sample Collection Procedures Bailing ® Obtam a laboratory decontaminated disposable bailer and a spool of nylon rope or equivalent bailer cord Tie a bowline knot or equivalent through the bailer loop Test the knot for adequacy by creatmg tension between the line and the bailer Tie again if needed New rope will be used for every sample or purge event New clean latex gloves will be used when touching the rope or bailer -d- CGRS, INC NGL Water Solutions C6 Facility 6 Spread a clean plastic sheet near the base of the well The plastic sheet should be of sufficient size to prevent bailer or bailer rope from contacting the ground surface a Place the bailer inside the well to venfy that an adequate annulus is present between the bailer and the well casing to allow free movement of the bailer ® Lower the bailer carefully into the well casing to remove the sample from the top of the water column, takmg care not to agitate the water in the well O Pour the bailed groundwater into a bucket Once the bucket is full, transfer the water to a barrel and contain on -site ® Raise the bailer by grasping a section of cord, using each hand alternately This bailer lift method will assure that the bailer cord will not come mto contact with the ground or other potentially contaminated surfaces San:plinz ® Instructions for obtammg samples for parameters are reviewed with the laboratory coordinator to insure that proper preservation and filtenng requirements are met ® Appropnate sample containers will be obtained from the contract laboratory for the Hazardous Substance List (HSL) for organics After samples are collected, they will be put on ice to coolers (4°C) Care will be taken to prevent breakage dunng transportation or shipment ® Samples collected by bailing will be poured directly into sample contamers from bailers The sample should be poured slowly to minimize air entrapment into the sample bottle Dunng collection, bailers will not be allowed to contact the sample containers o Upon completion of samplmg a cham-of-custody log will be initiated Cham-of-custody records will include the following information project name and number, shipped by, shipped sampling point, location, field ID number, date, time, sample type, number of contamers, analysis required and sampler's signature The samples and chain -of -custody will be delivered to the laboratory Upon amval at the laboratory the appropnate laboratory personnel will check m the samples Laboratory identification numbers will be noted on the chain -of -custody record Upon completion of the laboratory analysis, the completed cham-of-custody record will be returned to the project manager Field Cleaning Procedures For all equipment to be reused in the field, the following cleaning procedures must be followed -e- , CGRS, INC NGL Water Solutions C6 Facility • Disassemble the equipment to the extent practical O Wash the equipment with distilled water and laboratory -grade detergent O Rinse with distilled water until all detergent is removed O Rinse the equipment with isopropyl or methanol, making sure all surfaces, inside and out, are nnsed O Tnple nnse the equipment with distilled water Laboratory Selection The project manager should consider the following factors when selectmg a laboratory I' O Capabihties (facilities, personnel, instrumentation), mcludmg O Participation in interlaboratory studies (e g , EPA or other Federal or State agency sponsored analytical programs), O Certifications (e g , Federal or State), O References (e g other clients), and o Expenence (UST, RCRA and other environmentally related projects) O Service O Turnaround time, and ® Technical input (e g , recommendations on analytical procedures) The project manager is encouraged to gather perhnent laboratory -selection information pnor to extensively defining analytical requirements under the project A request may be made to a laboratory to provide a qualifications package that should address the points listed above Once the project manager has reviewed the various laboratory qualifications, further specific discussions with the laboratory or laboratones should take place In addition, more than one laboratory should be considered For large-scale mvestigations, selection of one laboratory as a pnmary candidate and one or two laboratones as fall -back candidates should be considered The quality of the laboratory service provided is dependent on various factors The project manager should be able to control the quality of the information (e g , samples) provided to the laboratory It is extremely important that the project manager communicate to the laboratory all the requirements relevant to the project This mcludes the number of samples and their matrices, sampling schedule, parameters and constituents of interest, required analytical methodologies, detection limits, holding times, deliverables, level of QA/QC, and required turnaround of analytical results -f- CGRS, INC NGL Water Solutions C6 Facility Field and Laboratory Quality Control General Quality control checks are performed to ensure that the data collected is representative and valid data Quality control checks are the mechanisms whereby the components of QA objectives ore momtored Examples of items to be considered are as follows 1 Field Activities o Use of standardized checklists and field notebooks, • Venficatton of checklist information by an independent person, • Strict adherence to chain -of -custody procedures, © Calibration of field devices, • Collection of replicate samples where applicable, and • Submission of field blanks, where appropnate 2 Analytical Activities • Method blanks, O Laboratory control samples • Calibration check samples, o replicate samples, 6 Matrix -spiked samples, • "Blind" quality control samplers, • Control charts, e Surrogate samples, • Zero and span gases, and • Reagent quality control checks Management of Waste Material Dunng the advancement of soil bonngs, decontamination of field equipment and development of soil bonngs or temporary momtonng wells, waste matenals will be generated This section addresses both the management of solid waste (soils) and the liquid wastes generated Soil generated dunng remedial activities will be contamenzed in 55 -gallon drums or stockpiled on an impermeable membrane and covered with plastic, which ever is most appropnate The waste charactenstics of the soil will be determined by appropnate analytical methods and the soil disposed of m accordance with state and federal regulations Water generated dunng field activities will be contamenzed in storage vessels, -g- CGRS, INC. NGL Water Solutions C6 Facility which are compatible with the suspected or identified contaminant(s). If required, the water will be analyzed by appropriate analytical methods to determine its waste characteristics. If a water treatment system is available wastewater will be treated on -site, thus eliminating the need for disposal. A portable aeration system can also be utilized to eliminate volatile contaminants in wastewater. In any event, the ultimate disposition of water will be in accordance with all applicable regulations. Reporting After data has been compiled and analyzed, CGRS submits a summary report to NGL Water Solutions and M3 Construction at the following address: Mr. Josh Patterson NGL Water Solutions 8203 West 20t'' Street, Suite A Greeley, Colorado 80634 M3 Construction, LLC 2681 W. 120t'' Ave, Ste #250 Westminster, CO 80234 Furthermore, CGRS submits an electronic copy to the following recipient and email address: Ms. Rae Chrisman — NGL Water Solutions; raeconques@aol.com Mr. Nick Valencia; M3 Construction, LLC; nvalencia@M3-consult.com Additional reports may be submitted upon the request of, or permission from, NGL Water Solutions. This includes the anticipated submittal of quarterly reports to the Weld County Department of Public Health and Environment. APPENDIX D , RADIOLOGICAL DOSE ASSESSMENT SHB INC., 7505 S. XANTHIA PLACE, CENTENNIAL, COLORADO 80112 Steven H Brown, Certified Health Physicist 303 941 1506; shb 12@msn.com; http://www.shbinc.us March 27, 2018 TO: John Jankousky, Marquez Environmental ; Garrett Clemons, NGL ; II Kim, NGL CC: Kurt Rhea, Secure Energy Gentlemen : At the request of Marquez Environmental, a radiological dose assessment was performed of the NGL Solids Waste Processing Facility in Platteville, Colorado. The complete report is attached. The assessment was focused specifically on the potential for occupational radiation exposure associated with work in the Main Solids Processing Building (MSPB) and at the Solids Storage Building (SSB). The assessment was based on the assumption that 50 picocuries (pCi) per gram of naturally occurring radium 226 (Ra-226) would be present in all solid waste materials processed and temporarily stored within these facilities. Although naturally occurring radium also can contain the isotope Ra-228, e xperience has shown that the Ra-226 isotope dominates radiological dose from e aturally occurring radium and it was therefore assumed that all radium in the waste materials was the isotope Ra-226. Accordingly, this is a conservative assumption. The potential for both external radiation exposure (via exposure to gamma rays) and internal e xposure (via inhalation of dusts and radon gas) were both evaluated in this assessment. The Microshield computer code was used for the external dose rate e xposure assessment. Three "example workers" were modeled, distinguished by varying percentages in a year (of 2000 hours) assigned to activities and work areas at the MSPB and SSB. Estimates of typical occupancy times at each location were provided by NGL staff. The modeled exposure rates were then combined with the occupancy times to produce e stimates of annual exposure in millirem (mrem). The highest projected annual exposure to any of the three "example" workers modeled in this assessment was 17 mrem. Additionally, the potential for workers receiving internal occupational exposures from inhalation of radionuclides, either as Ra-226 in dusts and/or Rn-222 gas was evaluated. A combination of relatively small sources, minimum occupancy in potential dust or radon producing plant areas and well ventilated conditions including source areas out of doors suggest the potential for internal exposure associated with the NGL Solids Waste Processing facility is quite small and is not expected to add any measurable occupational exposure to that estimated from external (gamma) sources and be indistinguishable from exposures to natural background levels of Ra-226 and Rn-222 in air The Colorado Department of Public Health and Environment recently issued revised guidance on management of Technologically Enhanced Naturally Occurnng Radioactive Material, - TENORM (in 2014) which limits exposure to 25 mrem per year for non radiation workers (e g , those who do not work in licensed facilities) That is, workers at TENORM facilities that are not licensed facilities are considered members of the public for radiation exposure control purposes Accordingly, it is concluded that the NGL Solids Waste Processing Facility can accept TENORM in wastes up to 50 pCi per gram radium 226 / 228 and maintain radiological exposures below current CDPHE guidance am of course available at any time to answer questions or provide additional information I have designated_ this version of the report as "Draft Final" as I am continuing to finalize a few numbers and to accommodate any revisions you may require Regards - Steve jr---/4,_ . RADIOLOGICAL DOSE ASSESSMENT - NGL SOLIDS WASTE PROCESSING FACILITY DRAFT FINAL P repared for Marquez Environmental and the NGL S olids Waste Processing Facility in Platteville, Colorado March 27, 2017 P repared by SHB Inc. Centennial Colorado Steven H. Brown, C H P In Association with S ecure Energy Parker Colorado 1 RADIOLOGICAL DOSE ASSESSMENT - NGL SOLIDS WASTE PROCESSING FACILITY - DRAFT FINAL - 27 MARCH 2018 - SHB INC, CENTENNIAL COLORADO Table of Contents 1.0 INTRODUCTION, SUMMARY AND CONCLUSIONS 2.0 EXTERNAL RADIATION EXPOSURE ASSESSMENT 2.1 Methods And Model Inputs 2.2 Sources 2.3 Estimates of Exposure Rates 2.4 Estimating Annual Exposure of Workers 3.0 ESTIMATE OF INTERNAL EXPOSURE OF WORKERS 3.1 Exposure to Particulate Dusts 3.2 Radon Exposure 3.3 Conclusions on Potential for Internal Exposure 4.0 REFERENCES TABLES Table 1: Description and Specifications of Modeled Process Components Table 2: Gamma Exposure Rates Associated with the Boiler and Solids Storage Building (SSB) Table 3: Average Area Exposure Rates Table 4: Worker Exposure Assessment Table 5: Potential Area Sources of Dust and/or Radon Appendix A: Figures 1-6 Appendix B: Background Radiation - We Live in a Radioactive Environment 2 1.0 INTRODUCTION, SUMMARY AND CONCLUSIONS At the request of Marquez Environmental, a radiological dose assessment was performed of the NGL Solids Waste Processing Facility in Platteville, Colorado The assessment was focused specifically on the potential for occupational radiation exposure associated with work in the Main Solids Processing Building (MSPB) and at the Solids Storage Building (SSB) The assessment was based on the assumption that 50 picocunes (pCi) per gram of naturally occurring radium 226 (Ra-226) would be present in all solid waste materials processed and temporarily stored within these facilities Although naturally occurring radium also can contain the isotope Ra-228, expenence has shown that the Ra-226 isotope dominates radiological dose from naturally occurring radium and it was therefore assumed that all radium in the waste materials was the isotope Ra-226 Accordingly, this is a conservative assumption The potential for both external radiation exposure (via exposure to gamma rays) and internal exposure (via inhalation of dusts and radon gas) were both evaluated in this assessment The Microshield computer code (Grove Software, 2014) was used for the external dose rate exposure assessment Three "example workers" were modeled, distinguished by varying percentages in a year (of 2000 (hours) assigned to activities and work areas at the MSPB- and SSB Estimates of typical occupancy times at each location were provided by NGL staff The modeled exposure rates were then combined with the occupancy times to produce estimates of annual exposure in millirem (mrem) The highest projected annual exposure to any of the three "example" workers modeled in this assessment was 17 mrem Additionally, the potential for workers receiving internal occupational exposures from inhalation of radionuclides, either as Ra-226 in dusts and/or Rn-222 gas was evaluated A combination of relatively small sources, minimum occupancy ,in potential dust or radon producing plant areas and well ventilated conditions including source areas out of doors suggest the potential for internal exposure associated with the NGL Solids Waste Processing facility is quite small and would be expected not to add any measurable occupational exposure to that estimated from external (gamma) sources and be indistinguishable from exposures to natural background levels of Ra-226 and Rn-222 in air The Colorado Department of Public Health and Environment recently issued revised guidance on management of Technologically Enhanced Naturally Occurring Radioactive Matenal - TENORM (CDPHE 2014) which limits exposure to 25 mrem per year for non radiation workers (e g , those who do not work in licensed facilities) That is, workers at TENORM facilities that are not licensed facilities are considered members of the public for radiation exposure control purposes Accordingly, it is concluded that the NGL Solids 3 Waste Processing Facility can accept TENORM in wastes up to 50 pa per gram radium 226 / 228 and maintain radiological exposures below current CDPHE guidance 2.0 EXTERNAL RADIATION EXPOSURE ASSESSMENT 2.1 METHODS AND MODEL INPUTS Each source was modeled separately and for those components in proximity to each other, the exposure rates were summed This method did not account for shielding from components or equipment, other than self -shielding of the component being modeled The model inputs included components, sources and receptors (locations of the workers and estimates of their occupancy times), as presented in Table 1 2 1 Components Eight components or areas were modeled Dimensions of each component were provided by NGL To facilitate the modeling effort, each was modeled as a cylinder of varying radius and length based on its dimensions, in Microshield A radius for each cylindrically modeled component was found by dividing the volume calculated using the provided dimensions and dividing by the length of the component which was then divided by pi and the square root taken 2 2 Sources Each component in Table 1 was modeled as a source of radiation with radioactive matenal (50 pa per gram Ra-226) contained in its intenor or as the component itself (eg, , the waste conveyor) Important characteristics of these sources included estimates of the mass, density, volume and percent solids To facilitate the modeling effort, the interior of each component was assumed to be filled with radioactive matenal i e the matenal was distributed evenly in its volume, even if it occupied only a portion of the volume However, the mass of the matenal was unchanged The modeled density of the material was calculated as the matenal mass divided by the volume of the mtenor of the component This is a conservative assumption, which allows for less mass to contnbute to the attenuation of gamma radiation between the source and receptor Based on expenence with companson of results to more sophisticated and ngorous codes such as MCNP5 (LANL 2011), this assumption could be quite conservative and result in overestimates of exposure rates by approximately 40% 4 Table 1 Description and Specifications of Modeled Process Components Component / Area Dimensions Applicable to Capacity for Waste Volume Maximum Waste Volume at a Time Material of Construction Outer Wall Thickness Brief Description of Contents 1 Boiler / Heat Exchanger 54" diameter x 50" depth 260 gal/min SA -516-70 steel 0 3125 inches body, 1 73 inch end cap oil/water/solids Oil consists of mostly heavy oils and paraffins 2 Centrifuge* 14" diameter x 160" length 260 gal/min SS %" steel Heat exchanger feeds centrifuge, very similar composition to centrifuge 3 Filter Press* 61" x 23" N/A SS body, fabric filters N/A Heat exchanger feeds filter press should have very similar composition oil/water/solids Oil consists of mostly heavy oils and paraffins 4 Surge Tank under 2 and 3 90" diameter x 70" tall 1,200 Ibs In 12 hours Fiberglass 1/4" thick Oil/water, 20/80 mixture Oil consists of mostly heavier oils 5 Conveyor 24" wide x 30' long 34 cubic feet/hr Belt is rubber, 3 ply — 330 PIW Conveyor frame is steel N/A Open to the atmosphere Solids/some oil Solids (cake) from centrifuge, similar to a slightly moist fine dirt 6 Main Solids Processing Building (MSPB) 100' x 60' N/A N/A N/A Water/oil/solids 7 Solids Storage Budding (SSB) 40' x 45' 40' x 45' x 5' total capacity of cake building Will not exceed the capacity of solids from conveyor fed by centrifuge N/A N/A Solids/some oils Same as conveyor 8 Shaker Screens N/A N/A N/A N/A Solids / liquids separation *Approximate distance (height) from upper platform with Centrifuge and Filter Press to floor level where surge tank is located = 12 feet Approximate distance across MSPB from boiler to surge tank/filter press / centrifuge area = 50 feet 5 2.3 Estimates of Exposure Rates. All exposure rates for components or combination of components are presented in units of microroentgens (uR) per hour and were plotted and knged to produce Figures 1 thru 6 (Appendix A)' which are maps depicting the exposure rates (at receptor locations and interpolated via kriging techniques) that are predicted for the MSPB Kriging Interpolates exposure rates, between a number of receptor points As a basis of comparison, typical background radiation exposure rates along the front range of Colorado are 10 — 20 uR per hour and , can be several times greater at higher elevations and/or areas of enhanced natural mineralization Appendix B to this report provides some perspectives on the natural radiation environment and its variability across the US Since the boiler (heat exchanger) located in the MSPB is isolated and a considerable distance from other sources in this building (approximately 50 feet from where the surge tank, filter press and centrifuge are located - see discussion below), it was modeled separately Similarly, the SSD where processed waste awaits to be removed to roll offs for offsite disposal was also modeled separately as a single source Results for these two sources are depicted in Table 2 Table 2: Gamma Exposure Rates Associated with the Boiler and Solids Storage Building (SSB) Boiler SSB Distance From Edge of Boiler (m) Results (uR/hr) Distance from Middle -Edge of Matenal (m) Results (uR/hr) 0 3142 28 26 1 284 15 17 1 3142 7 036 6 284 4 211 2 3142 , 3 051 11 284 1 83 3 3142 1 673 16 284 0 9887 4 3142 1 05 21 284 0 6081 The corner area within the MSPB in which the centrifuge and filter press are located in the elevated loft area above the surge (feed) tank to the conveyor and the conveyor itself were modeled together since the close proximity of these four components will potentially result in gamma exposure contributions from all four of them at once while a worker is in this area Figures 1 thru 6 in Appendix A present graphically the results of the analyses Several conclusions are drawn from these results, which are used in the next section to estimate the actual worker doses It is noted that all dose rates stated below are above the natural background rate estimated to be 10 — 20 uR/hr The highest exposure rates are near contact with the surge tank at ground level, approximating 30-40 uR / hr This includes contribution from the conveyor and either the centrifuge or filter press above on loft (It is understood the filter press is a backup for the 6 centrifuge They do not both operate at the same time) However, the exposure rate drops off quickly to < 10 uR /hr under the loft and conveyor but to < 3 uR/hr at about 5 —10 feet into general MSPB areas • Little difference is seen at the location of the surge tank, whether the filter press or centrifuge is active • Exposure rates are less on the loft level as one moves away (above) from the surge tank below • The highest average exposure rates on the loft level are when the filter press is active, generally in the range of 10 - 15 uR/hr • Exposure rates on the loft level when the centrifuge is active generally average < 10 uR /hr • Although over 25 uR/hr near contact, exposure rates associated with the Boiler are < 10 uR/hr at about 3 feet from the unit and decrease rapidly to < 3 uR/hr into the MSPB • Although the exposure rate immediately in front of the processed waste in the SSB is about 15 uR/hr , it decrease rapidly to just a few uR/hr as one moves away toward the area where the roll off bins are stored An additional consideration here is that the worker is in the cab of a loader and has benefit of shielding which reduces the exposure to the worker • However, and most importantly, exposure rates decrease quickly moving away from the immediate vicinity of all sources, e g , from the surge tank and loft area and from the boiler, exposure rates decrease quickly to < 3 uR/hr above background at 5 —10 feet away into the general MSPB area 2.4Estimating Annual Exposure of Workers Annual doses for several "example workers" are estimated in this section It is recognized that actual workers may be engaged in a number of activities throughout and around the MSPB However, in the interest of simplicity and in an attempt to provide "maximum credible cases", the following workers were modeled Worker A 20 % MSPB General Areas, 40 % on Loft, 20 ')/0 under loft, 20 % other plant areas Worker B 20 % MSPB General Areas, 20 % SSB, 20 % on loft, 20% under loft, 20% other plant areas 7 i Worker C 20% MSPB, 10 % on loft, 40% under loft, 10 % boiler, 20% other plant areas All workers are "full time" at 2000 hrs per year and work performed in "other plant areas" assumes no additional radiological exposure above background occurs there Average Exposure rates for each area are depicted in Table 3 Table 3: Average Area Exposure Rates Area Assumed Average uR/hr MSPB General 3 Under Loft / i Conveyor 15 On top of Loft 10 Boiler 10 SSB 5 Using the distribution of activities assigned to each of the example workers A B and C above and applying the average exposure rates for each area as presented in Table 3, annual worker exposure estimates are provided in Table 4 Table 4: Worker Exposure Assessment (millirem per year , 1 mrem = 1000 uR from gamma rays) Worker MSPB General Area On Loft Under Loft SSB Boiler Total A 1 2; 8 6 152 B 1 2 4 6 2 13 2 C 1 2 2 12 2 17 2 3.0 ESTIMATE OF INTERNAL EXPOSURE OF WORKERS The two potential circumstances that could result in workers receiving internal exposure above background at the NGL Platteville Solids Waste Processing Facility are inhalation of radium bearing dusts generated by process activities and/or inhalation of radon gas, produced from the radioactive decay of radium that could evolve from process materials exposed to air The potential for worker exposure to each is discussed below 8 3.1 Exposure to Particulate Dusts Most of the NGL solid waste process operations are conducted within a closed system of tanks, pumps and pipes and much of the process involves materials in liquid or moist sludge like physical forms Accordingly, the potential for release of airborne dusts into the workplace is quite small Areas of the process that could potentially produce airborne dusts and/or radon gas and estimates of worker occupancy in these areas is depicted in Table 5 below Table 5: Potential Area Sources of Dust and/or Radon Component / Area Material \ Description Circumstances of Worker Occupancy Shaker Screens Receives fluidized waste or sludges from delivery trucks At elevated level relative to ground Separates solids via particle size, fluids into tank below - Unoccupied area most of time Worker occupancy estimated at 1 hr per week only for start up and shut down and some housekeeping duties Filter Press Moisture removal Only used as backup for centrifuge If operational, employees in MSPB on loft and/or at ground level 10 -12 hrs per day Conveyor Moves moist solid wastes from surge tank to approximately 10 - 15 feet above to discharge into SSB Employees in main solids process building at ground level 10 -12 hrs per day Solids Storage Building (SSB) Interim storage of solid waste product Three sided structure open on one side to allow access by front end loader to move wastes to roll off for offsite shipment Occupancy only during load out, worker in front end loader, 4 hours per week The inhalation dose rate per hour for a maximum concentration of 50 pCi / gram Ra — 226 in all matenals is calculated as follows 9 Id = (DCFRa226) (1/PEF) (C) (BR) (T) Where Id = Committed Effective Dose Equivalent (CEDE) rate per hour from inhalation of Ra- 226 in dusts at a concentration of 50 pa / gram (in mrem) DCFRa226 = CEDE from inhalation for Ra-226 per unit intake (mrem / pa) via inhalation of dust = 2 2 E-6 Sieverts / Becquerel (from Table A-1 of IAEA 2004) = 8 E-3 mrem / pa PEF = Particulate Emission Factor (PEF) from USEPA 2008, Section 3 3 3 = 1 32 E9 m3/kg The PEF is a measure of dust generation rate and is expressed in units of inverse airborne concentration This value was used by EPA to model dry dust inhalation from areas contaminated with legacy uranium ore containing all natural uranium decay products including Ra-226 For the NGL application, this value is considered quite conservative since all NGL waste matenals are "moist" and would have much less potential for becoming airborne than dry soil like matenal C = Concentration of Ra -226 in all matenal dusts = 50 pa/gram BR = Breathing (inhalation) rate from USEPA 2008, Section 3 3 3 = 20 m3/day T = Time of exposure = 1 hour Id. (8 E-3 mrem / pa)(1/1 32 E-9 kg/m3)(50 pa/g)(E+3 g /kg)(20 m3/day)(1/24 day/hr ) = 2 5 E-7 mrem /hr Accordingly, as can be seen from Table 5 above, even if (the filter press were in operation for a full year or for workers in the vicinity of the conveyor in the MSPB with worker occupancy at 2000 hours per year, the annual dose from dust inhalation is estimated to be (2000 hrs ) X (2 5 E-7 mrem / hr ) = 5 E-4 mrem which is essentially zero addition to the occupational external exposure above natural background of these workers 3.2 Radon Exposure Radon (Ra - 222 for our purposes here) is a naturally occurnng inert noble gas arising as the radioactive decay product of Radium 226 Thus, Ra - 222 is produced wherever Ra-226 is present Radon is found everywhere in at least small amounts because its predecessor, Ra-226 (and its onginal parent nuclide, Uranium 238), is found in all rock and soil In outdoor air, radon concentrations are usually less than one picocune per liter (pa/I) but can be higher, particularly in Western States with higher natural 10 concentrations of uranium and therefore radium in the soil and rocks Additionally, higher concentrations of radon outdoors may be observed dunng bnef penods, such as dunng a temperature inversion, when a warm air mass traps_a colder one beneath it Concentrations can vary by a factor of 2 or more, diurnally or seasonally associated with variation in air temperatures, humidity and barometnc pressure Indoor air concentrations, in contrast, can vary from around 0 5 pa/I to over 2,000 pCi/I Results from USEPA's National Residential Radon Survey (USEPA 1992) indicate that over 6 percent of all homes nationwide have average annual indoor radon levels above 4 pCi/I, which is the US EPA recommended value for new home construction and home sales (USEPA 2013) Most indoor radon comes from the rocks and soil around a home or building, although other, usually less significant sources include radon dissolved in water entering the structure and construction matenals with elevated levels of naturally occurring uranium and radium The dose from Rn-222 comes pnmanly from its short lived particulate progeny ("decay products") which attach to lung surfaces and deposit alpha energy, not from the inert gas itself, most of which is quickly exhaled The importance of this dosimetnc relationship between radon gas and its progeny was well documented early in the history of uranium mining (Altshuler et al 1964, Holaday et -al 1957, Jacobi 1964) That is, without time for ingrowth of the radon progeny, inhalation of Rn-222 by itself results in little dose However, the NGL waste process is to large degree an enclosed system with a few areas from which radon can evolve out of the matenals into workplace air And the radon released from the decay of Ra-226 is "fresh radon", i e , it is initially free of its particulate progeny that produce the radiation dose The same plant areas discussed above in Section 3 1 and table 5 regarding potential for dusting and /or particulate releases into workplace air would also be applicable to the potential for radon releases However, at both the shaker screen area and the Solids Waste Storage building workers are out of doors and it is unlikely that any potential for radon exposure in excess of natural background would be detectable a few feet from the sources IAEA 2011 presents findings of an investigation to determine the doses expected to be received by members of the public exposed to large NORM residue deposits (uranium senes radionuclides including Ra-226), with consideration being given to all potentially significant exposure pathways Specifically regarding the radon inhalation pathway, Rn- 222 emissions, from a representative uranium residue deposit were calculated using a simple air dispersion model The outdoor radon concentration was found to be about 10-20 Bq/m3 in the immediate vicinity of the deposit (0 4 - 0 7 pa/I — about the same as typical "background") This range of radon concentrations is comparable with the 11 range of natural variability of outdoor radon concentrations Given this intrinsic vanability in natural radon levels and the fact that the "fresh radon" released from the soil disperses quickly with the wind, the authors stated that it would be very difficult to identify any clear increase in radon levels out of doors in the vicinity of a uranium residue deposit This should also be the case out of doors where NGL workers are moving waste matenals between the SSB and roll off area Similarly, regarding the shaker screen area, this is also an out of doors area with a very small occupancy factor Regards to releases of radon into work areas of the Main Solids Processing Building (MSPB), only the filter press (when in operation) or matenal on the conveyor could be sources since all other components are enclosed and pressunzed Most of the length of the conveyor is external to and above the MSPB main floor area and the majonty of any radon released from it would be to out of doors areas The MSPB is a large open area facility, is well ventilated via outside air but the rate of radon released from these sources can be conservatively estimated The United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR) provides information on sources of radon and the processes that affect the release of radon from soils [UN 2000] A key parameter that controls radon transport in soils is the radon diffusion coefficient A number of models for estimating the radon flux from the surface of porous media such as soil, uranium ore or waste rock are reported in the literature (e g , USNRC 1980, USEPA 1983) For dry soils, using the methods and values reported in USNRC 1980, the estimated unit area radon flux per unit Ra-226 activity concentration (in becquerels per gram) is about 1 Bq / m2 -sec (or in picocunes per gram, about 1 pCi/m2-sec) The use of this value has been the basis for historical calculations of radon emission from soils and land surfaces and is considered conservative since diffusion occurs through the unsaturated pore space of the sod and therefore the diffusion of radon in sod, where the soil is compacted or the pore space is filled with water (saturated), will be much slower than in non -compacted or unsaturated soils However, for our application here, involving moist solid waste matenals, 1 pCi/m2- sec Rn-222 per pCi / gram Ra-226 in a soil like matenal is considered conservative Accordingly, from a maximum concentration of 50 pCi / gram in all matenals, the radon flux associated with the filter press (when in operation) would be expected to be much less than 50 pa/m2-sec Rn-222 For example, given that the exposed surface area of the filter press is relatively small (about 1 m2) the associated radon release would be < < 50 pCi / sec As a frame of reference, an average back yard of 100 — 200 m2 almost anywhere in the temperate zones with a typical Ra-226 soil background of 1 pCi / gram, emits about 100 - 200 pCi of Rn - 222 per second A square mile of the earth's surface almost anywhere in the temperate zones with a typical Ra-226 soil background of 1 pCi / gram, emits about 2 6 million pCi per second 12 However, as stated above, this small radon release rate is primarily "fresh radon" and is expected to be carried by the large normal building ventilation flow into out of doors areas before any appreciable ingrowth of radon's particulate progeny, which are the source of the dose to humans. 3.3 Conclusions for Potential of Internal Exposure The potential for workers receiving internal occupational exposures from inhalation of radionuclides, either as Ra-226 in dusts and/or Rn-222 gas was evaluated. A combination of relatively small sources, minimum occupancy in potential dust or radon producing plant areas and well ventilated conditions including source areas out of doors suggest the potential for internal exposure associated with the NGL Solids Waste Processing facility is quite small and would be expected not to add any measurable occupational exposure to that estimated from external (gamma) sources and be indistinguishable from exposures to natural background levels of Ra-226 and Rn-222 in air. 4.0 REFERENCES Altshuler, B., Nelson, N., and Kuschner, M. 1964. "Estimation of Lung Tissue Dose from the Inhalation of Radon and Daughters," Health Phys. 10:1137-1161. CDPHE 2014. Colorado Department of Public Health and Environment, TENORM Policy and Guidance. Available at: https://www.colorado.gov/pacific/sites/default/files/HM tenorm-policy-revisiondraft- 080514.pdf Grove Software. 2014. MicroShieldRadiation Software: http://radiationsoftware.com/microshield/. Copyright O 1992-2014 Grove Software, 4925 Boonsboro Rd, #257 Lynchburg, VA 24503 USA. Holaday, D.A., Rusing, D.E., Coleman, R.D., Woolrich, P.P., Kusnetz, H.L., and Bale, W.F. 1957. Control of Radon and Daughters in Uranium Mines and Calculation of Biological Effects. U.S. Public Health Serv. Pub. 494 IAEA 2004. International Atomic Energy Agency. Occupational Radiation Protection in the Mining and Processing of Raw Materials; No. RS -G-1.6. Annex: Relationships Between Gross Alpha Activity and Committed Effective Dose For The Inhalation of Ore Dust Containing Uranium or Thorium. IAEA 2011. International Atomic Energy Agency. Exposure of the Public from Large Deposits of Mineral Residues. IAEA-TECDOC-1660.\ 13 Jacobi, W 1964 The Dose to the Human Respiratory Tract by Inhalation of Short -Lived 222Rn and 220Rn Decay Products Health Phys 10 1163-1175 \ LANL 2011 Los Alamos National Laboratory Monte Carlo N -Particle 5 v 1 60 MCNP webpage https //mcnp lanl gov/ © Copyright 2011 Los Alamos National Secunty, LLC UN 2000 United Nations Scientific Committee on the Effects of Atomic Radiation UNSCEAR 2000 Report to the General Assembly USEPA 1983 U S Environmental Protection Agency Final Environmental Impact Statement for Standards for the Control of Byproduct Matenals from Uranium Ore Processing, Vol 1, EPA 520/1-83-008-1 USEPA 1992 United States Environmental Protection Agency National Residential Radon Survey Summary Report EPA 402-R-92-011 USEPA 2008 US Environmental Protection Agency Technical Report on Technologically Enhanced Naturally Occurring Radioactive Matenals from Uranium Mining, EPA 402-R-08-005, Vol 2 USEPA 2013 United States Environmental Protection Agency Home Buyer's and Seller's Guide to Radon EPA 402/K-13/002 USNRC 1980. U S Nuclear Regulatory Commission Final Genenc Environmental Impact Statement on Uranium Milling, NUREG 0706 1 14 APPENDIX A: FIGURES 1-6 FIGURE 1 Surge Tank (Ground) Legend Exposure Rate (uR/hr) Contours < 3.0 9.0 Ilk 15.0 20.0 > 25.0 Exposure Rate on Ground Floor with Centrifuge Active 0 2.25 4.5 1 Meters 9 FIGURE 2 i" Surge Tank (Ground) Centrifuge (Loft) Legend Exposure Rate (uR/hr) i Contou -s < 3.0 9.0 15.0 20.0 > 25.0 Exposure Rate on Ground Floor with Filter Press Active 0 2.25 4.5 1 Meters 9 FIGURE 3 Maximum Exposure: 40.2 uR/hr .vvv > Conveyor (Angled 0 - 3 meters) ,Orsoe')e)evy' v X)6% Exposure next to Coveyor: 19.3 uR/hr ter Press (Loft) Legend Exposure Rate (uR/hr) < 3.50 3.51 - 4.00 4.01 -4.50 4.51 -6.00 6.01 - 7.00 7.01 - 10.00 10.01 - 20.00 20.01 - 30.00 30.01 - 40.00 > 40.00 Exposure Rate on Ground (Centrifuge Active) 0 1.25 2.5 Meters 5 FIGURE 4 Maximum Exposure: 44.2 uR/hr Conveyor (Angled 0 - 3 meters) x"_)<?Ki Exposure next to Coveyor. 19.3 uR/hr Legend Exposure Rate ( u R/h r) < 3.50 3.51 - 4.00 4.01 - 4 50 4.51 - 6.00 601 -700 7 01 - 10.00 10.01 - 20 00 20.01 - 30 00 30.01 - 40.00 > 40.00 Exposure Rate on Ground (Filter Press Active) 0 1.25 2.5 Meters 5 FIGURE 5 Maximum Loft Exposure: 16.0 uR/hr Exposure next to Coveyor: 19.3 uR/hr Legend Exposure Rate (uR/hr) < 3.50 3.51 - 4 00 4.01 - 4.50 4.51 - 6.00 601 -700 7.01 - 10.00 10 01 - 20.00 20.01 - 30.00 30_01 - 40.00 > 40.00 Exposure Rate on Loft (Centrifuge Active) 0 1.25 2.5 Meters 5 FIGURE 6 Maximum Loft Exposure: 40.8 uR/hr <XXXXXXXXX> )Ax: Conveyor (Angled 0 - 3 meters Anna Ana Exposure next to Coveyor 19.3 uR/hr Legend Exposure Rate (uR/hr) <350 3.51 - 4.00 4.01 - 4.50 4.51 - 6.00 6.01 - 7.00 7.01 - 10.00 10.01 - 20 00 20.01 - 30.00 30.01 - 40.00 > 40.00 Exposure Rate on Loft (Filter Press Active) 0 1.25 2.5 Meters 5 APPENDIX B - WE LIVE IN A RADIOACTIVE ENVIRONMENT The magnitude and variability of natural background radiation can be used as a benchmark to provide some perspective on the radiation doses received from Technologically Enhanced Naturally Occurring radioactive Material (TENORM) associated with water treatment facilities This is particularly relevant since a large percentage of our background radiation exposure is a direct result of naturally occurring uranium, radium, radon and associated other decay products in the soil and rocks under our feet, in the air we breath and in the food and water we consume every day Natural background radiation exposure to humans is ubiquitous, unavoidable and highly vanable depending on ,where you live (In the present context, "radiation" is assumed to mean ionizing radiation, as opposed to microwaves, radio and TV waves, ultraviolet radiation and other forms of non -ionizing radiation ) People are exposed to cosmic radiation from solar radiation and outer space that is constantly bombarding the earth's atmosphere Humans are constantly immersed in a field of cosmic radiation that vanes with elevation (higher doses from cosmic radiation are found at higher elevations) Naturally occurnng radioactive matenals are present in the rocks and soil of the earth, in the houses we live in and in the buildings where we work, as well as the food and drink we consume There are radioactive aerosols and gases in the air we breathe and even our own bodies contain naturally occurnng radioactive elements The level of this inescapable natural "background" radiation exposure vanes greatly from place to place For example, according to the U S National Council on Radiation Protection and Measurements (NCRP 1987), background sod in the U S contains a mean of 31 parts per million (ppm) of uranium (and 65 ppm of thonum) although much higher concentrations, especially in areas of mineralization, are not uncommon (NCRP 2009, UNSCEAR 2000) A square mile of the earth's surface one foot deep, just about anywhere in the temperate zones, contains over a ton of uranium Natural background radiation, which comes from a number of sources, typically results in a dose rate of roughly about 200 to 400 millirem (1) per year (UNSCEAR 2000), although some places in the world, including parts of the U S , expenence much higher exposure rates The average annual exposure from natural background radiation in the U S (311 millirem/y) is shown in Table 1 and Figure 1 (NCRP 2009) The typical variability across the US, demonstrating how where one chooses to live can affect their background radiation exposure by several hundred millirems a year, is depicted in Table 2 Table 1: Exposure to Natural Background Radiation in the United States Source of Exposure (millirem/year) Average in U.S. (%) Internal, inhalation (radon and thoron) 228 (73°/o) External, cosmic (space) 33 (11`)/0) Internal, ingestion (food and water) 29 (9°/o) External, terrestrial 21 (7%) Total 311 (100`)/0) Figure 1: Natural Background Radiation in the United States A millirem (mrem) is a unit of effective radiation dose. It is related to the amount of energy absorbed by human tissue and other factors. 1,000,000 µrem=1,000 millirem = one rem. Table 2: Comparison Of Average Radiation Backgrounds In US vs. Colorado (Units of millirem/year) Source Colorado Avg.a Florida Avg.a Illinois Avg.a Leadville Avg.b Cosmic Radiation 49 27 28 85 Terrestrial Radiation 39 13 24 97 Internal Radiation including Radon Inhalation, Food and Water Ingestion 300 54 181 344 Totals 387 93 233 526 a From USEPA 2005 ° From Moeller 2006 Natural radiation exposure can vary considerable from place to place across the United States or over relatively small areas within a region This is due to effects of elevation (higher cosmic radiation exposure at higher elevations), greater levels of naturally occurnng radioactive elements in soil and water in mineralized areas (e g igneous formations in Rocky Mountains) and other factors like local geology and geochemistry This was depicted in Table 2, which allows companson of average annual background radiation exposure for the US (from Table 1 and Figure 1 above) relative to annual averages for all of Colorado, Leadville, Colorado (high elevation and mineralization) and several other States This table shows the major components of natural background radiation, including terrestnal radiation (uranium, radium, thorium and potassium 40 in soil, rocks and water), cosmic radiation (high energy rays from space) and internal radiation (from food, water and radon gas from natural uranium decaying in the ground) According to the NCRP, exposure to radon (or specifically, Rn-222), pnmanly while indoors, is responsible for almost 70°/0 of the average dose from background radiation, although radon doses are highly variable In the U S , the average indoor radon concentration at home is 46 3 becquerels per cubic meter (Bq/m3) (1 25 picocunes per liter (pCi/L)), and the average outdoor concentration is 15 Bq/m3 (0 40 pCi/L) (NCRP 2009) (z) An additional perspective is depicted in Figure 2, which shows the change in radiation exposure rate due to a variation in elevation and mineralization as one travels across the Interstate 70 corridor through the Rocky Mountains between Denver and Grand Junction, Colorado z A picocune (pCi) is a measure of the amount of radioactivity used only in the US It is the amount of radioactivity where approximately two atoms decay per minute A Becquerel (Bq) is the unit of radioactivity used internationally, and is equal to about 27 pCi Figure 2: Variability of Terrestrial and Cosmic Radiation Background Across The Interstate 70 Corridor Of Colorado (units of nanograys per hour) Moving a hundred miles can change exposure by a factor of 4). (Stone, 1999) 250 200 i a150 v 4•• e3 a 100 - 50 - 0 Eisenhower Tunnel (continental Divide) Ved Paso O O D R from terrestrial Sources -- D R from cosmic sources — Elevations' profile Geologic unit boundary - 4000 - 3000 8 C - 2000 w a 0 50 100 150 200 250 300 350 Distance (km) 1.2 Naturally Occurring Radioactivity in Food and Water 400 1000 Our lifestyles, where we choose to live, what we eat and dnnk, has a much larger impact on our radiation exposure than control at the regulatory limits for public exposure (Discussed in the next Section 1 3) For example, the average concentration of natural uranium in groundwater in the US is about 2 picocuries 1 per liter (pCi/liter) The US Environmental Protection Agency's drinking water standard for uranium is about 20 picocuries per liter (expressed on a mass basis as 30 micrograms (millionths of gram) per liter (USEPA, 2012) However, concentrations can vary considerably from place to place depending on local geology and other environmental factors Numerous studies that have been conducted in the US indicate levels in groundwater that are used for domestic purposes including drinking water can be many times higher than EPA's standard (Hakonson 2002, OEHHACEPA 1997, USGS 2006) Radioactive isotopes are inherent in all foods Natural radioactive isotopes, such as potassium 40 (K- 40), carbon-14 (C-14), tritium (H-3), natural uranium, thorium and radium and various other radioactive elements are part of the food chain- Plants assimilate radionuclides into their structure through respiration, transpiration, and soil uptake Examples of typical annual uranium intake by humans in example foods include (NCRP, 1984, Welford, 1967) o Whole -grain products 10 pCi o Meat 50-70 pCi o Fresh fruit 30-51 pCi o Potatoes 67-74 pCi o Bakery products 39-44 pCi i In some instances, these radioisotopes may be concentrated into certain parts of the plant where other stable isotopes of the same element are also being concentrated, such as the roots, fruits, or nuts This effect is especially notable in fruits with high levels of potassium, such as bananas One banana contains approximately 422 mg of potassium (Chiquita Banana, 2013) The radioactive isotope of potassium mentioned above, K-40, has a natural occurrence of 0 0117% (Strom et al, 2009) Therefore, of the 422 mg of potassium in a banana, about 0 5 mg are radioactive With knowledge of the specific activity of natural potassium (31 7 Bq/g - Strom et al, 2009), this translates into 13 3 Bq (about 360 pCi) of radioactivity per banana from K-40 If you were to eat a bunch of 10 bananas, you have consumed 133 Bq of radioactive K-40 (about 3600 pCi) To put this in perspective however, the human body contains 1 to 2 grams of potassium per kilogram of body mass A 70 kg person therefore, would contain 70 to 140 grams of potassium This means a person that weighs 70 kg might contain between 8 and 16 mg of radioactive K-40, or between 2,220 and 4,440 Bq2 (60,000 to 120,000 pCi) of radioactivity from K-40 alone Annually, this results in a dose to that person of 13 6 mrem3/year (Strom et al, 2009) However, note that eating extra bananas will not necessanly increase your average annual radiation dose from extra K-40 since your body eliminates excess potassium through homeostasis 1.3 Regulatory Limits for Public Exposure to Radiation The basic regulatory public exposure limits applicable to facilities or activities that use radioactive matenal are 100 millirem per year from all sources including radon and 25 millirem / year excluding radon Examples of Federal and Colorado radiation exposure limits for occupational workers and the public are presented in Table 3 Table 3: Example Federal and Colorado Radiation Exposure and Dose Limits Applicable to Uranium Mining and Milling Exposure Condition Limit Regulatory Reference Trained Radiation Worker Annual Exposure 5000 millirem /year USNRC 10 CFR 20 1201, Occupational Dose Limits, Colorado 6 CCR 1007-1 Part 4 4 1, Occupational Dose Limits, USMSHA 30 CFR 57 5047 Worker Annual Radiation Exposure (Mining) 5 Rem / year (5000 millirem /year) gamma radiation exposure USMSHA 30 CFR 57 5047 , Radiation Exposure Limit for Members of the Public - General 100 millirem / year including radon USNRC 10 CFR 20 1101, Radiation Dose Limits for Individual Members of the Public, Colorado Department of Public Health and Environment 6 CCR 1007-1 Part 4 parapraph 4 14 1, Radiation Dose Limits for Individual Members of the Pubhc Exposure Condition Limit Regulatory Reference NRC license ; termination and uresncted release of site ("w/o i radon") 25 mrem / year U S Nuclear Regulatory Commission Consolidated Decommissioning Guidance - Decommissioning Process for Materials Licensees, NUREG 1757, Vols 1-3, 2006 EPA — Public exposure limit for releases from Nuclear Fuel Cycle 25 mrrem / year 40 CFR 190 - Environmental Radiation Protection Standards for Nuclear Power Operations EPA Drinking Water 4 mrem / year from man made radionuclides 40 CFR 191 66 - Maximum contaminant levels for radionuclides Compare the public exposure limits in Table 3 to the annual radiation doses we receive as citizens of planet Earth as depicted in Table 1 and 2 above Note that, for example, although the basic Federal (and Colorado) annual exposure limit for a member of the public is 100 mrem, people who choose to live in Colordao vs lets say as an example, Flonda, will received on the average 200 - 300 mrem more radiation 'exposure every year For those people who choose to live in Leadville, the difference compared to their relatives in Flonda is an average of 300 - 400 mrem higher radiation exposure every year REFERENCES FOR SECTION 2.0 Chiquita Banana 2013 All About Banana Potassium, 2013 Available at http //www chiquitabananas com/Worlds-Favonte-Fruit/bananas-and-potassium aspx Hakonson 2002 Hakonson,-Hayes A C, Fresqueza, P R, Whicker, F W Assessing Potential Risks from Exposure to Natural Uranium in Well Water, Journal of Environmental Radioactivity, 59 Moeller 2006 Moeller D, Sun LSC Companson of Natural Background Dose Rates foi- Residents of the Amargosa Valley, NV, to those in Leadville, CO and the States of Colorado and Nevada Health Physics 91 338-353 NCRP 1984 National Council on Radiation Protection and Measurements Exposures from the Uranium Series with Emphasis on Radon and its Daughters; NCRP Report No. 77. NCRP 1987. National Council on Radiation Protection and Measurements. Exposure of the Population in the United States and Canada from Natural Background Radiation. NCRP Report No. 94 NCRP 2009. National Council of Radiation Protection and Measurements. Ionizing Radiation Exposure of the Population of the United States. NCRP Report No.160. OEHHACEPA 1997. Office of Environmental Health Hazard Assessment California Environmental Protection Agency (OEHHACEPA). Public Health Goal for Uranium in Drinking Water. UNSCEAR 2000. United Nations Scientific Committee on the Effects of Atomic Radiation. Sources and Effects of Ionising Radiation - Volume 1: Sources. Report to the General Assembly, with Scientific Annexes, United Nations, New York. Stone 1999. Stone, JM, Whicker, RD et al. Spatial Variations in Natural Background Radiation: Absorbed Dose Rates in Air in Colorado. Health Phys. Vol. 9(5). Strom 2009. Se.rom, DJ, Lynch, TJ, & DR, Weier. Radiation doses to Hanford workers from natural potassium -40. United States Department of Energy. 2009. Available at: http://www.pnl.gov/main/publications/extemal/technical reports/PNNL-18240. pdf. Accessed on November 6th, 2013 USEPA 2005. US Environmental Protection Agency. Assessment of variations in radiation exposure in the United States. Available at: http://pbadupws.nrc.gov/docs/ML1224/ML12240A227.pdf. USEPA 2012. US Environmental Protection Agency USEPA). Basic information about the radionuclides rule. Available at: http://water. epa. gov/lawsregs/rulesregs/sd wa/radionuclides/basicinformation. cfm. USGS 2006. United States Geological Survey open file report 97-492; reformatted 1975 — 1980 data from U.S. NURE HSSR program. Welford 1967. Welford GA, Baird. Uranium Levels in Human Diet and Biological Materials. Health Phys. 13(12): 1,321-1,325 1111111 iI1111111111111 IiIII 111111111111 !11111111111 III! 726 37!2725 06/07/2011 03.48P Weld County, CO 1 of 2 R 16.00 D 400.00 Steve Moreno Clerk & Recorder SPECIAL WARRANTY DEED THIS DEED, dated June 1, 2O11 between Marcum Midstream 1995-2 Business Trust, a Delaware statutory business trust of the County of Weld and State of Colorado, grantor, and High Sierra Water Services, LLC, a Colorado limited liability company, duly organized and existing under and by virtue of the laws of the State of Colorado, grantee, whose legal address is 3773 Cherry Creek Drive North, Suite 1OOO, Denver, CO 80209, grantee. WITNESS, that the grantor, for and in consideration of the sum of $10,00 and other good and valuable consideration, the receipt and sufficiency of which 1s hereby acknowledged, has granted, bargained, sold and conveyed, and by these presents does grant, bargain, sell, convey and confirm unto the grantee, its successors and assigns forever, all the real property, together with improvements, if any, situate, lying and being in the County of Weld and State of Colorado, descnbed as follows LOTS A AND S, RECORDED EXEMPTION NO 1213-30-4 RE 4612, RECORDED MARCH 12, 2008 AT RECEPTION NO. 3541173, BEING LOCATED IN THE S 1/2 OF THE SE 1/4 OF SECTION 3O, TOWNSHIP 3 NORTH, RANGE 65 WEST OF THE 6TH P M , COUNTY OF WELD, STATE OF COLORADO also known by street and number as 13159 WCR 39 Platteville, CO 8O651 assessor's schedule or parcel number Parcel 3 TOGETHER with all and singular the heredrtaments and appurtenances thereunto belonging, or in anywise appertaining, the reversion and reversions, remainder and remainders, rents, issues and profits thereof, and all the estate, right, title, interest, claim and demand whatsoever of the grantor, either in law or equity, of, m and to the above bargained premises, with the hereditaments and appurtenances, TO HAVE AND TO HOLD the said premises above bargained and described, with the appurtenances, unto the grantee, its successors and assigns forever. The grantor, for itself, its successors and assigns, does covenant, grant, bargain, and agree to and with the grantee, its successors and assigns, that at the time of the ensealing and delivery of these presents, it is well seized of the premises above conveyed, has good, sure, perfect, absolute and indefeasible estate of mhentance, in taw, in fee simple, and has good right, full power and lawful authority to grant, bargain, sell and convey the same in manner and form as aforesaid, and that the same are free and clear from all former and other grants, bargains, sales, liens, taxes, assessments, encumbrances and restrictions of whatever kind arising by, through or under grantor, but not otherwise. The grantor shall and will WARRANT AND FOREVER DEFEND the above bargained premises in the quiet and peaceable possession of the grantee, its successors and assigns, against all and every person or persons lawfully claiming the whole or any part thereof by, through or under grantor, The singular number shall include the plural, the plural the singular, and the use of any gender shall be applicable to all genders IN WITNESS WHEREOF, the granto $1 executed this deed on the date set forth above &awn144 ierra hkitr Cvi(.ef� !JL°+ "r ^ a5tc)ozoN s, f Giea Br51313 ste ) O: T1P.erti�f�''� GO $OZ461 I li11111 MI111111111111 3772726 06/07/2011 03:48P Weld County, CO 2 of 2 R 16.00 D 400.00 Steve Moreno Clerk 8 Recorder Marcum Midstream 1995-2 Business Trust By. Name: Dale S. Butdher Title* President SPATE OF COLORADO County of -Weld Den.W611-- The foregoing instrument was acknowledged before me this by Dale S Butcher as President of Marcum Midstream 1995-2 Business Trust. day of June 2011, ott tit!' .`MCP. Witness my hand and official seal r \.NO;Any - Mycommission expires: s-((e— r. PuotAG .O GP'COi �'co Expires — iL„ Notary Public RESOLUTION RE: APPROVE VACATION OF RECORDED EXEMPTION, RE -4612 - NGL WATER SOLUTIONS WHEREAS, the Board of County Commissioners of Weld County, Colorado, pursuant to Colorado statute and the Weld County Home Rule Charter, is vested with the authonty of administenng the affairs of Weld County, Colorado, and WHEREAS, on March 26, 2007, the Department of Planning Services administratively approved Recorded Exemption #4612, creating parcels of 45.5 acres and 34.5 acres, more or less, and WHEREAS, said property is located In part of the S1/2 of the SE114 of Section 30, Township 3 North, Range 65 West of the 6th P M, Weld County, Colorado, being more particularly described as Lots A and B of Recorded Exemption, RE -4612, and WHEREAS, the Department of Planning Services staff, as a Condition of Approval of Minor Amendment (MUSR11-0004) to Use by Special Review Permit (USR-1604), required the vacation of Recorded Exemption, RE -4612, and WHEREAS, the Board has received a request from NGL Water Soluhons (formerly known as High Sierra Water Services, LLC), c/o M3 Construction, LLC, 2861 West 120th Avenue, Surte 250, Westminster, Colorado 80021, to vacate said Recorded Exemption, RE -4612, which was recorded on March 12, 2008, at Reception #3541173, in the records of the Weld County Clerk and Recorder, and WHEREAS, the Board of County Commissioners heard all of the testimony and statements of those present, studied the request of the applicant and the recommendations of the Department of Planning Services staff and all of the exhibits and evidence presented in this matter and, having been fully mformed, deems it advisable to approve said vacation NOW, THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Weld County, Colorado, that Recorded Exemption, RE -4612, be, and hereby is, vacated. 4030593 Pages: 1 of 2 07/15/2014 12.20 PM R Fee $0.00 Steve Moreno, Clerk and Recorder, Mold County. CO VIII iralti7lirtl~'lidEli? iiikViVildn MONK lid ®l Ili 20141840 RE4612 VACATE RE -4612 - NGL WATER SOLUTIONS PAGE 2 The above and foregoing Resolution was, on motion duly made and seconded, adopted by the following vote on the 98th day of June, A D , 2014 ATTEST•Id ii ...eito%IA Weld County Clerk to the Board BY. %%Jerk ��Qi to the Board .7 APP rney BOARD OF COUNTY COMMISSIONERS LD COUNTY, COLORADO Dougla s� demac er, haO1 ir Dou, arbara lurkmeyer, Pro-Tem -1 I Sean P. Conway arcla Date of signature 7-$-14 4030693 Pages: 2 of 2- 07/15/20t4 12.20 pm R Frv$9.00 Steve Moreno, Clark and Raoardor, WeldCounty. ftait OM OM1 2014-1840 RE4612 VACATION OF LOT A AND LOT B OF RECORDED EXEMPTION NO. 1213-30-4 RE -4612 l5undrRt AAtuanPLFfO'Navosimai 5 7 sCC1101TT4TYLRELY COWER FOUND �wwt C�APUI� THE SOUTH HALF OF THE SOUTHEAST QUARTER OF SECTION 30, TOWNSHIP 3 NORTH, RANGE 65 WEST, OF THE 6TH PRINCIPAL MERIDIAN, WELD COUNTY, COLORADO Daum suacomaoRNER II EMMONS&TSRROAY ID` MUMS I C PIN MAD=N0..VS OttSOX Pa IMO f - 'RESERVEDFOR ADINnoRMACRIE RIOMPONRAY j ID DS= ROIC-0FYIRY •-1 ----T--- .._. ^_. 80 04 ACRES GROSS (77.32 ACRES NET) +1_ - - -- �.-_,.. fIU81 1u'R W:MD FOR 1..- ADORIONILMCRID RRORR-0FMMY y bi r. � YI ACAT'TE!, _ c I i T _ +=-_JIMa_. _ _ _ _ _ W —..... aruntetwrincomaR ST=DONKUNARSMt fW1o>aROAR WM =P IPOIkIM�6ERVICES 1 ate 1 Doi .SOFEET WELD COUNTY ROAD n BOARD OF COUNTY COMMISSIONERS CERTIFICATION YNS OTOCERVI TNTITE SOAROCFCOIROYCAIDSGDA314MOD=MY FOR DOESHFREDYCCCCIIRRJNANAIOOADCPrTA&HfE17E011:OMOillNIY �DESCRUDNO � rHageDAY P :.- FNfaEN/DWO&A6W13114 t 4WRE4LliSciffasa ATIESTI4OLY MELDCOIDTT CEAKTOTKMI RO BASIS OF BEARING: OEREC�DCROVIO �K�S NO� BS OMEE 6111 PRIMAL 7D MAR 130=07427r EMIASSTAK01110 ateRFDA9ON(om PROVOS: BP MOWS U RDERRIVEMO.ISC ae1&MEeT WM MEET RD.6UOEU CREW =mode 0701740104� DATED SURVEYOR'S STATEMENT L RO&ERTD IROLM4A PROFEIDquLUlC&ANEYCRUCEKED NINE MRCP CERRA WAVER SCRVIDES LLD �MIIDC�OUNTY�TNNTTASSOFEA Y�O DFTL'�BDdEDpE �MIEEDpPRFIRLDS MOORDUCTED et REM URDERUYRESMOBIEOWIOE ON JURE1D=IC a - R ODERTaTICRAE v1530riJ DATE FOUNDED RREEMli li aFRALUMNA CAP ROLBIIIF� PEY:RACES RS660R PLANNING NOTE: CCAPAISTORR9 OR JLME14�{AS tTNEREOLESTOFT CURREMPROPEAIYRYINEVELDCOUNIY BOARD � . WON 0®WARRTERSEAMCE4LLCM WCA1 iLOTAMID&OF RECORDED MERMEN NORE•1612OPXDOED rtWRCH R0P9��44 08DOM= 6SOM NTIERECOR RECORDS MELD =Oft= OF IAW�®�P9TTERSOURIEHEOLYOFFTTE��DREARTPAItC9. CHEOLWE�EROFSEC R�IRN TOWIAAI 0.1 HORDE RINOEtlWESTOF THER LEGAL DESCRIPTION MECUM Mr OFTREBOURffAST MUTER OFSECTION 0, SmN 6SYRASTO TREETHPRDICIPIRVELDCOURMFAIDINT. COLORADO NOTES; 1. TAR&OW& MS OUTTREB9alIRCFACuRRsOIME COSILETYEMNiDCOED NOT CNADMEATRIESFARCHEIYMORASLORD suRvEYYR6.LLD.7ODETE RmE7mEOREASEMDNISOPRECCRD 7TYa 51IRVEY DOES NOT RBRFORTTOREILECTIXIOFT1ESDLLOYMOVRICH RAM APPLICABLE TIME &MECT REALESTAIBEASEll MEMO( RONALD DA6IDOOD AI nEREVISIBLEATTIEMID OFLiNowDO WRAP SI2lFM7 SETEILKDMB& REETRK7NECOVFNARRSI@OMsiON IMETRICHOTS 101W.��TE�0 T RA NDARY Coto gSCLOSE ACRDII sBASEDUPORARYDEFELI DONS SURVEYmoi TEREE`FARDAAREAYRRT FEW DRCCVEROXRCFtECT NNOEMIT RAY ANY ACTOR DASEDUPON ANY DEEECrOiTABEUNEYSECONNEMED YOIEIYMTEN YEatsFpOy TREDATEOFTSECERTIFICATION DWAIN REREOR 1 �61FRRAT TERSFAyy��ST=YCO IMNEDDITNE STATEYdf E¢igi.6PID STAIF]OW motor FJOElEI7T ANY Malta) MERiOOrANDORMS STATEMEN @!TEE SURVEYOR IMMOSAO 411iSil4R MSW.000f6Y1PPTENT IW ORMOLU SEALANDNWU7utECC S. MYPEIFuONNfiDKNOMAi.YREROvE8-ALTERsoRCE'FACESW YEVaUC UlIDSVaVEritom RFNEARDoA DOORWAY ROM ERMA OCCILSZORY. COIdO5A CUeSTW [�ppIR,1,SSID9Ei IOR PURSIWRTO STATE STATUTE au! DEC tE•48081MgEYEq RILLFULLY DESTROY& DEPACE9.ONANOES OR MOVED TOMORIE SPSACEAMEEDDONCORFER, WARM CORNOI, OR WARDERPOS7 0NANY00,ERNYEM INEOF SLAM ORM7EFUALY CLOCCIEIMIYYM266TREEARMY7REE&UTID7011AFXINE QC OF MIEOR ROASCHED DOT IDDRETRAN =MOODS; C41DOM ISU.D.C.. 0. IRE=AKE SEASLVOWDB*WAN NGSECNMEUR.SURVEYFOOT 7 OATESO FS:LOWRK6O102N4 6 ACRE44 MOREEOORLDS&&MAAS WAR KREDNraaLL AREDULIANT UII DSO{ FMCELNOT ADETERIMATREF RMAYOWICEstGAPA'JN6Y =DM PERFICOR �p@ RC LCIRRAATOt1�fFSREM*. IltE MEALS RCCLIVIEEACIORFOR REAL MAMMIES PURPODED. OWNER'S APPROVAL t�PAARRIONEA CCEF1L�M6IOF RD HERRED(AM NE MEAD SitchPARCH ) LOCTRAO49WLPIMEIWRZULT. LLI�AIET PARCBDRnUDC11EDEDNAP lfbMBETiGhUECNEDRORIOMOSSAI.S2MIMEO70PRoVIDE Ft�@g OFOMERUSW N101=SYSFVOI. REM SEMI VIOEMFAIORRTNOI.MRYER SOURIOICI CLLLD IKR�.MYOFCM�00S0.cLFDLtELE MY=MOW NOTARY MRNE56 W AUOAVD C4nrcuNe%301.2 a NWMY MUG 09COt� o NOTARY IP 70U.SIDT Mr4are4Talcomica14T11T 1MMAUI PROPERTY .�• MAPROPERTY• KERBYAGM TO DE14 ENTTO DSA9 • .; : : REREONYI D_M REVFEW "` PRDJECTFRI ICS= DRAIWOZ ERNS UIPOORykRRALSP fLOTLE SVACADORA AFFIDAVIT OF INTEREST OWNERS SURFACE ESTATE Property Legal Description: 51Z SV-I OF 5 3O, r3�v, g(O.6-td Parcel Number / Z l 3-5 O - u- 0 0- O j 7 (12 digit number - found on Tax I.D. information, obtainable at the Weld County Assessor's Office, or www.co.weld.co.us) (Include all lots being included in the application area, if additional space is required, attach an additional sheet) THE UNDERSIGNED, being first duly sworn, states that to the best of his or her knowledge the attached list is a true and accurate list of the names, addresses, and the corresponding Parcel Identification Number assigned by the Weld County Assessor of the owners of property (the surface estate) within five hundred feet of the property being considered. This list was compiled from the records of the Weld County Assessor, or a person qualified to do the task, and shall be current as of a date no more than thirty days prior to the date the application is submitted to the Department of Planning Services. Signatures of all fee owners of property must sign this application. If an Authorized Agent signs, a letter of authorization from all fee owners must be included with the application. If a corporation is the fee owner, notarized evidence must be included indicating the signatory has the legal authority to sign for the corporation. I (We) hereby depose and state under the penalties of perjury that all statements, proposals and/or plans submitted with or contained wi i the application are true and correct to the best of my (our) knowledge. Signature Date Signature Date WELD COUNTY COLORADO LAND RECORDS AFFIDAVIT OF INTERESTED LAND OWNERS SURFACE ESTATE 3/15/2018 2:40:34 PM THE UNDERSIGNED, States that to the best of his cr her knowledge the attached list is a true and accurate ist of the names, addresses, and the corresponding Parcel Identification Number assigned by the Weld County Assessor of the owners of the property (the surface estate) within 500 feet of the property being considered. This list was compiled utilizing the records of the Weld County Assessor available on the Weld County Internet Mapping site, http://www.co.weld • .us, and has not been modified from the original. The list compiled for the records of the Weld C% n Assessor was assembled within thirty days of the applications submission date. rature Date Property Owners Within 500 ft of Parcel # 121330400017 w Account Parcel Owner Mailing Address R7900999 121329000007 WARDELL ROY T LIVING TRUST 16512 PLATTEVILLE, ESSEX RD CO N 806519317 R4956586 121330000002 NELSON PHYLLIS EDITH CAMP 1/2 INT R4956586 121330000002 MRJ CAMP HOLDINGS LLC 1/2 INT C/O PO PLATTEVILLE, MELVIN BOX 127 J CAMP CO 806510127 M1177100 121330-00013 BRUNSON NANCY M1113599 121330400013 BRUNSON NANCY HILTY R6806596 121330400013 HILTY-BRUNSON NANCY (BN) M1113599 121330400013 BRUNSON KEVIN 13471 PLATTEVILLE, COUNTY ROAD CO 806518208 39 M1177100 121330400013 BRUNSON KEVIN 13471 PLATTEVILLE, COUNTY ROAD CO 806518208 39 R6806596 12133C400013 BRUNSON KEVIN S (BN) 13471 PLATTEVILLE, COUNTY ROAD CO 806518208 39 Parcels: 8 Owner Records: 13 Page 1 of 3 WELD COUNTY COLORADO LAND RECORDS AFFIDAVIT OF INTERESTED LAND OWNERS SURFACE ESTATE 3/15/2018 2:40:34 PM THE UNDERSIGNED, States that to the best of his or her knowledge the attached list is a true and accurate ist of the names, addresses, and the corresponding Parcel Identification Number assigned by the Weld County Assessor of the owners of the property (the surface estate) within 500 feet of the property being considered. This list was compiled utilizing the records of the We • County Assessor available on the Weld County Internet Mapping site, http://www.co.wel .co. s, and has not been modified from the original. The list compiled for the records of the Weld o�,�,� ssessor was assembled within thirty days of the applications submission date. nature Property Owners Within 500 ft of Parcel # 121330400017 Date Account Parcel Owner Mailing Address R6787665 121330400017 HIGH SIERRA WATER SERVICES LLC C/O 1900 ROWLETT, K E DALROCK ANDREWS TX 750885526 RD R4957586 121331000003 NELSON PHYLLIS EDITH CAMP 1/2 INT _, R4957586 121331000003 MRJ CAMP HOLDINGS LLC 1/2 INT C/O PO PLATTEVILLE, BOX MELVIN 127 J CAMP CO 806510127 R8941720 121332200032 SILICON RANCH CORPORATION 150 NASHVILLE, 3RD AVE S TN STE 372012011 2000 Parcels: 8 Owner Records: 13 Page 2 of 3 WELD COUNTY COLORADO LAND RECORDS AFFIDAVIT OF INTERESTED LAND OWNERS SURFACE ESTATE 3/15/2018 2:40:34 PM THE UNDERSIGNED, States that to the best of his or her knowledge the attached list is a true and accurate I st of the names, addresses, and the corresponding Parcel Identification Number assigned by the Weld County Assessor of the owners of the property (the surface estate) within 500 feet of the property being considered. This list was compiled utilizing the records of the Weld County Assessor available on the Weld County Internet Mapping site, http://www.co.weld.co.us, and has not been modified from the original. The list compiled for the records of the Weld unty essor was assembled within thirty days of the applications submission date. Property Owners Within 500 ft of Parcel # 121330400017 Parcels: 8 Owner Records: 13 //s/rgnature Date Page 3 of 3 Hello