HomeMy WebLinkAbout20203648.tiffRESOLUTION
RE: ACTION OF BOARD CONCERNING 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, 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, the Board heard all of the testimony and statements of those present and
reviewed the request of the applicant and, having been fully informed, finds that this request be
approved and the matter should be continued to January 20, 2021, at 10:00 a.m., to allow
adequate time for the hearing to be properly noticed.
NOW, THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Weld
County, Colorado, that the abovementioned matter be, and hereby is, continued to January 20,
2021, at 10:00 a.m.
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2020-3648
PL1804
CONTINUANCE (CD18-0001) - HIGH SIERRA WATER SERVICES, LLC, C/O NGL WATER
SOLUTIONS DJ, LLC
PAGE 2
The above and foregoing Resolution was, on motion duly made and seconded, adopted
by the following vote on the 16th day of December, A.D., 2020.
BOARD OF COUNTY COMMISSIONERS
WELD COUNTY, COLORADO
ATTEST: dau44.w..d.,;(1
Weld County Clerk to the Board
BY:
Deputy Clerk to the Board
APP ED A
County Attorney
Date of signature: Q1/ob/-
Mike Freeman, Chair
oreno, Pro-Tem
K. James
e er
arbara Kirk y
2020-3648
PL1804
MEMORANDUM
TO Board of County Commissioners
DATE December 16, 2020
FROM Kim Ogle
SUBJECT Certificate of Designation, CD18-0001 in conjunction with
3MJUSR18-07-1604, 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
(3MJUSR18-07-1604) 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.
Ei 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:
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.
COLORADO
Department of Public
Health & Environment
December 23, 2019
Board of County Commissioners
Weld County
1150 O 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/WLD/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 Polis, Governor Jill Hunsaker Ryan, MPH, Executive Director
ic.,ty 4,4
• �•I r``•/
`1
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 prior to doing so
Page 2 of 3
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)(a) 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 astate.co.us.
Sincerely,
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
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 I
John W Hickenlooper, Governor 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/pacific/cdphe/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.Todd@state.co.us.
Sincerely,
eak
Andy Todd
Solid Waste Permitting Unit
Solid Waste and Materials Management Program
Hazardous Materials and Waste Management Division
ec: Joe Vargo
Kim Ogle
Ben Frissell
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.gov/cdphe
John \N. Hickenlooper, Governor ; Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
COLORADO
Department of Public
Health & 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 Drive 5 , Denver, Co 80246 1530 P 303 692-2000www colorado gov/cdphe I
John W Hickenlooper, Governor I Karin McGowan, Interim 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 47
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 5 , Denver, CO 80246 1530 P 303 692-2000 www colorado gov/cdphe
John W Hickenlooper, Governor I Karin 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 thorium, 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 interim policy and guidance dated February 2007 If the facility
expects to receive wastes with uranium and thorium exceeding the above
activity concentrations, the facility should provide risk assessments on the
maximum uranium and thorium concentrations anticipated in the wastes to
establish the appropriate acceptance criteria for uranium and thorium.
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 Drive S , Denver, Co 80246-1530 P 303-692-2000 www colorado gov/cdphe I
John W Hickenlooper, Governor I Karin 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,
'Cat
Andy Todd
Solid Waste Permitting Unit
Solid Waste and Materials Management
Hazardous Materials and Waste Management Division
ec: Kim Ogle
Ben Frissell
Environment
INNIS
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.gov/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 FOR A 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
[]
D4
[]
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 Frlssell Date 11/2/2020
Agency WCDPHE
Weld County Planning Dept 1555 N 17th Ave, Greeley, CO 80631 (970) 400-6100 (970) 304-6498 fax
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