HomeMy WebLinkAbout9.0 Request for Preventative MeasuresCOLORADO
Department of Public
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
December 31, 2014
Mr. Eric Hick
Greenback Produced Water Recovery LLC
1301 Academy Court
Fort Collins, CO 80524
Re: Request for Preventative Measures -Approved
GreenBack Produced Water Recovery, LLC Schaeffer Ranch Facility
SW I GAR SHA/ 2.2
Dear Mr. Hick:
The Solid Waste and Materials Management Program of the Hazardous Materials and Waste Management Division of
the Colorado Department of Public Health and Environment (the Division) received the document identified below for
the Schaeffer Ranch facility located in Garfield County.
• Request/or Preventative Maintenance dated December 30, 2013 and prepared by GreenBack Produced Water
Recovery, LLC (GreenBack).
The facility accepts exploration and production (E&P) waste liquids for treatment via multiple step processes including
evaporation and operates under a Certificate of Designation issued by Garfield County December 13, 2010 (Resolution
2010-90) and an Engineering Design and Operations Plan revised October 2010 (D&O). The sequential treatment
process includes particle/bacteria filtration, oil/water separation, clarification for fine suspended solids and air
stripping to remove dissolved organics. Clarified water is stored in three 35,000 barrel double lined ponds. Operations
at the facility were "temporarily" suspended in early 2014 due to the poor economy in the Piceance Basin and the
Division approved temporary shutdown status and therefore delayed initiation of closure activities until June 30, 2015.
GreenBack is proposing to perform several activities intended to minimize the potential for equipment failures,
releases of waste and impact to human health and the environment should the electrical service to the facility cease
during the winter resulting in frozen and broken piping/equipment. The piping used to pump waste water uphill to the
ponds will be plugged to eliminate gravity draining of the ponds to the pump house down hill (80,000 barrels). The
lines are full because there is no valve/cap in the line isolating them from the pond fluids and if the pump house is not
heated the lower end of the pipes could freeze/break allowing gravity draining of the 3 ponds. The water treatment
processes involve multiple tanks and piping lines that may also freeze/break resulting in a release of waste. These will
be drained into the waste load out sump and some holes may be drilled into piping/tanks to allow complete drainage.
A dirt berm will be constructed surrounding the load out drain to keep storm water from entering the load out sump to
minimize the potential for the sump to overflow.
The Division has reviewed the submittal to determine compliance with the Solid Wastes Disposal Sites and Facilities
Act, Title 30, Article 20, Part 1 of the Colorado Revised Statutes, as amended (Act), with the regulations promulgated
there under 6 CCR 1007-2 (Regulations) and with the approved D&O.
The Division approves the proposed requested actions in an effort to minimize the potential for a large release to the
environment should the facility freeze. As we discussed at the site on December 18, 2014, capping of the piping
within the ponds may also stop the gravity flow of waste water down hill to the pump house should the pump house
freeze and lines break. The activities proposed are extreme and will inhibit future operation of the facility (as
designed) until repairs or design revisions can be completed. The Division requests that all preventative measures
222 South 6t11 Street Room 232, Grand Junction, CO 81501 P 303·692·2000 www.c olorado .gov/cdphe
John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director an d Chie r Medical Orricer
Request for Preventative Maintenance -Approved
GreenBack Schaeffer Ranch E&P Facility
December 31, 2014
Page2
completed are well documented in writing and photographs and submitted to the Division and Garfield County. Please
also document any unanticipated problems, changes in the planned activities and spills/releases that occur. Inspections
of the pump house, pipe plugs, storm water berm and load out sump should be conducted weekly with the other site
inspections required GreenBack Variance request dated January 23, 2014 . The site maintenance, monitoring and
financial assurance activities and submittals identified in the Variance request shall continue during the temporary
suspens ion of operation .
The Division appreciates your proactive attempt to anticipate and circumvent potential problems at this facility given
the unique situation. If additional preventative measures are deemed necessary to protect human health and the
environment, please notify the Divis ion if possible prior to performing the measure and document the activity in the
submittal upon completion of all of the measures .
In closing, please note that the Department is authorized to bill $125/hr for review of technical submittals pursuant to
Section 1.7 of the Regulations. An invoice for the Department's review of the document will be transmitted to you
under separate cover . Please contact the Bob Peterson at 970-248-7151 concerning the information provided above.
Sincerely,
tu~J~~~
Robert J. Peterson, Environmental Protection Specialist
Solid Waste and Materials Management Program
Hazardous Materials and Waste Management Division
cc: OJ file
Garfield County BOCC
ec : D. Brown, GreenBack
F. Jarmon , Garfield Co Planning
K. Wy nn , Garfield Co
222 South 61ll Street Room 232 , Grand Junction, CO 8 1501 P 303 ·692 ·2000 www.col orado.gov/cdphe
John W. Hickenlooper , Governor I Larry Wolk, MD, MSPH , Executive Director and Chief Medical Officer