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HomeMy WebLinkAbout5.0 PC Staff Report 10.12.2005Exhibits for Public Hearing on October 12, 2005 — Planning Commission Special Use Permit for an E & P Waste Facility Southeast of GarCo Airport— EnCana Oil and Gas (USA) Inc h bit fetter _ � 1b € I .. A Mail Receipts B Proof of Publication C Garfield County Zoning Resolution of 1978, as amended D Garfield County Subdivision Regulations of 1984, as amended E Garfield County Comprehensive Plan of 2000 F Staff Report dated 10 -12 -05 G Application for the E &P Facility Special Use Permit 11 Email dated 9 -30 -05 from Jim Rada I Letter dated 10 -04 -05 from Michael Erion REQUEST: PC 10 -12 -2005 RW PROJECT INFORMATION AND STAFF COMMENTS Special Use Permit for "Storage, Processing, and Material Handling of Natural Resource" Exploration and Production Facility for a Bioremediation Land Farm. OWNERJAPPLICANT: EnCana Oil and Gas (USA) Inc. REPRESNTATIVE: Wagon Wheel Consulting LOCATION: Approximately one mile southeast of the GarCo Airport SITE INFO: 8.48 Acres, Parcel # 217919300128 ACCESS: CR 333 WATER: No proposal for potable water SEWER: No sewer service is proposed EXISTING ZONING: ARRD (Agricultural Residential Rural Density) Location map of proposed site — southeast of Rye 1 Photo is a portion of the proposed site 1. BACKGROUND The Building and Planning Department is in receipt of a Special Use Permit (SUP) application for "Storage, Processing, and Material Handling of Natural Resource" for a Centralized Exploration and Production Waste Facility - Bioremediation Land Farm on a 8.486 acre property owned by EnCana Oil & Gas (USA), Inc. The property is located approximately one mile southeast of the GarCo Airport. As required in §9.03.04 of the Zoning Regulations, this request was heard by the Board of County Commissioners for a possible referral to the Planning Commission. On August 8, 2005 the Board voted to refer this item to the Planning Commission. This decision was based the possible environmental impact to the area and to educate the public concerning the activity of the land farm. 2. PROPOSAL EnCana Oil and Gas USA, Inc are proposing a land farm to treat and reuse soils that have been polluted with petroleum hydrocarbons. The proposal is to use the subject property as a centralized treatment facility for impacted soils from EnCana's well sites and other E&P facilities. The treatment process will consist of bioremediation land farm cells which use microbes to degrade petroleum hydrocarbons contained within the soils. Operation of the land farm provides an environmentally responsible alternative to disposing of the petroleum impacted soils in the local landfill. By 'mediation of the soils to State standards, EnCana is able to reuse the soils at other facilities. The Site would be fenced and bermed to protect from trespassing. It is expected the impacted soils would be brought to the site and treated. After the treated soils reach acceptable State levels, EnCana will remove the soils from the site for safe use at other locations. 2 1. GENERAL REQUIREMENTS FOR ALL SPECIAL USE PERMITS §5.03 Conditional and Special Uses (Zoning Resolution of 1978, as amended) 1) Utilities adequate to provide water and sanitation service based on accepted engineering standards and approved by the Board of County Commissioners shall either be in place or shall be constructed in conjunction with the proposed use. Staff Comments: Due to the nature of the work to be conducted at the site, potable water will not be necessary. If sanitation service is needed, it will be provided to the employees by portable toilets. 2) Street improvements adequate to accommodate traffic volume generated by the proposed use and to provide safe, convenient access to the use shall either be in place or shall be constructed in conjunction with the proposed use. Staff Comments: Garfield County Road and Bridge Department has issued a driveway permit to EnCana for ingress and egress to CR 333. The land farm will create traffic trips that will vary day to day dependant upon the amount of soils needed to be treated. Trucks and heavy equipment will be used on site. 3) Design of the proposed use is organized to minimize impact on and from adjacent uses of land through installation of screen fences or landscape materials on the periphery of the lot and by location of intensively utilized areas, access points, lighting and signs in such a manner as to protect established neighborhood character. Staff Comments: The proposed facility is adjacent to a well site. A six foot high fence will be installed around the perimeter of the facility to insure safety and security. No buildings or structures requiring a building permit are expected. The visual impact of the site should be minimal §5.03.07 Industrial Operations (1) The applicant for a permit for industrial operations shall prepare and submit to the Planning Director ten (10) copies of an impact statement on the proposed use describing its location, scope, design and construction schedule, including an explanation of its operational characteristics. One (1) copy of the impact statement shall be filed with the County Commissioners by the Planning Director. The impact statement shall address the following: (A) Existing lawful use of water through depletion or pollution ofsurface run -off, stream flow or ground water. Staff Comments: The facility will require the use of water to suppress dust and treat the soil. . The water will be brought to the site from existing EnCana water sources. If needed, the applicant will 3 provide water through a well or detained stone water. The applicant will need to properly line the facility to protect against pollution of surface run -off, stream flow or groundwater. (B)Impacts on adjacent land from the generation of vapor, dust, smoke, noise, glare or vibration, or other emanations Staff Comments: Impacts to adjacent land is expected to be minimal. Vapors emanating will be less than those found at a typical gas condensate tank battery. By keeping the soils moist, dust will be suppressed. Noise at the site will consist of machinery operating at the site and will be below the standard of 75 decibels at 25 feet from the property. (C) Impacts on wildlife and domestic animals through the creation of hazardous attractions, alteration of existing native vegetation, blockade of migration routes, use patterns or other disruptions. Staff Comments: The site will be fenced with a six foot chain link fence with locking gates which will keep out wildlife, domestic animals, and serve to deter entry by unauthorized personnel. (D) Affirmatively show the impacts of truck and automobile traffic to and from such uses and their impacts to areas in the County. Staff Comments: Traffic to the site will be episodic. There will be daily traffic to the site for land farm operators and authorized personnel making routine inspections. (E) That sufficient distances shall separate such usefrom abutting property which might otherwise be damaged by operations of the proposed use(s). Staff Comments: The site is isolated from abutting uses; there are no residential properties in close proximity to the site. The nearest building is located more than 1,500 feet to the northwest. The remaining use near the proposed land farm is a well site. (F)Mitigation measures proposed for all of the foregoing impacts identified and for the standards identified in Section 5.03.08 of this Resolution. Staff Comments: The applicant is proposing a six foot high fence around the entire perimeter of the site that will provide safety and security. There are few impacts expected as a result of the land farm. Machinery will only be operated during the unloading activities and when turning the soil. (2) Permits may be granted for those uses with provisions that provide adequate mitigation for the following: (A) A plan for site rehabilitation must be approved by the County Commissioners before a permit for conditional or special use will be issued. Staff Comments: The applicant is required by the COGCC to submit a closure (reclamation) plan. This plan is attachment G of the application materials, which outlines in detail the proposed measures for reclamation. Additionally the applicant is required to post $50,000 in financial assurance with the COGCC for reclamation purposes. The proposed reclamation plan is acceptable to staff. The applicant has not submitted a weed inventory or a weed management plan for the site. Prior to issuance of this SUP the applicant shall provide this information. 4 (B)The County Commissioners may require security before a permitfor special or conditional use is issued, if required. The applicant shall furnish evidence of a bank commitment of credit, bond, certified check or other security deemed acceptable by the County Commissioners in the amount calculated by the County Commissioners to secure the execution of the site rehabilitation plan in workmanlike manner and in accordance with the specifications and construction schedule established or approved by the County Commissioners. Such commitments, bonds or check shall be payable to and held by the County Commissioners. Staff Comments: It shall be at the discretion of the Board of County Commissioners to determine whether additional security is needed. (C) Impacts set forth in the impact statement and compliance with the standards contained in Section 5.03.08 of this Resolution. (A. 93 -061) §5.03.08 Industrial Performance Standards All industrial operations in the County shall comply with applicable County, State, and Federal regulations regulating water, air and noise pollution and shall not be conducted in a manner constituting a public nuisance or hazard. Operations shall be conducted in such a manner as to minimize heat, dust, smoke, vibration, glare and odor and all other undesirable environmental effects beyond the boundaries of the property in which such uses are located, in accord with the following standards; (1) Volume of sound generated shall comply with the standards set forth in the Colorado Revised Statutes at the time any new application is made. (A. 93 -061) Staff Comments: The proposed use of the site will create noise that is proposed to be below 75 decibels at 25 feet from the property. The applicant shall be aware of all sound volume standards and meet all State requirements. (2) Vibration generated: every use shall be so operated that the ground vibration inherently and recurrently generated is not perceptible, without instruments, at any point of any boundary line of the property on which the use is located;. Staff Comments: No vibrations are expected to result from the operation of land farm. During construction it may be necessary to compact the soils, but is anticipated that this activity will not be perceptible. (3) Emissions of smoke and particulate matter: every use shall be operated so as to comply with all Federal, State and County air quality laws, regulations and standards. 5 Staff Comments: There will not be emissions of smoke from the land farm. Due to the nature of the treated soils, open flames will not be permitted onsite. All air quality permits will be issued by the State and shall be in place prior to issuance of this SUP. (4) Emission of Beat, glare, radiation and fumes: every use shall be so operated that it does not emit heat, glare, radiation or fumes which substantially interfere with the existing use of adjoining property or which constitutes a public nuisance or hazard. Flaring of gases, aircraft warning signals, reflective painting of storage tanks, or other such operations which may be required by law as safety or air pollution control measures shall be exempted from this provision. Staff Comments: The land farm will not create glare, radiation or fumes that will substantially interfere with adjoining property. The activity on the site will be passive, microbial degradation which will not cause radiation or fumes that will interfere with the existing use of adjoining properties. Once again, the applicant shall be aware of all State and Federal guidelines and provide any mitigating measures prior to issuance of this SUP. (5) Storage area, salvage yard, sanitary landfill and mineral waste disposal areas: (A97112). (A) Storage of flammable or explosive solids or gases shall be in accordance with accepted standards and laws and shall comply with the national, state and local fire codes and written recommendations /comments from the appropriate local protection district regarding compliance with the appropriate codes; (A97 -112) Staff Comments: Storage of the waste soil will not be explosive and shall be in accordance with all COGCC rules. (B) At the discretion of the County Commissioners, all outdoor storage facilities may be required to be enclosed by fence, landscaping or wall adequate to conceal such facilities from adjacent property; (A97 -112) Staff Comments: The proposed facility is adjacent to an existing well site. A six foot high fence and berming will be installed around the perimeter of the facility in order to insure safety and security. Although the site will be visible from adjoining property, it will be compatible with existing uses and will not detract from the "neighborhood character" (C) No materials or wastes shall be deposited upon a property in such form or manner that they may be transferred off the property by any reasonably foreseeable natural causes or forces; (A97 -112) Staff Comments: The contaminated soils will be managed on site and will not be tracked offsite by trucks. Staff is recommended the affected areas of the land farm be properly lined to mitigate any leaching of pollutants into the ground water. 6 (D) Storage of Heavy Equipment will only be allowed subject to (A) and (C) above and the following standards: (A97 -112) 1. The minimum lot size is five (5) acres and is not a platted subdivision. 2. The equipment storage area is not placed any closer than 300 ft from any existing residential dwelling. 3. All equipment storage will be enclosed in an area with screening at least eight (8) feet in height and obscured from view at the same elevation or lower. Screening may include berming, landscaping, sight obscuring fencing or a combination of any of these methods. 4. Any repair and maintenance activity requiring the use of equipment that will generate noise, odors or glare beyond the property boundaries will be conducted within a building or outdoors during the hours of 8 a.m. to 6 p.m., Mon. -Fri. 5. Loading and unloading of vehicles shall be conducted on private property and may not be conducted on any public right -of -way. Staff Comments: Equipment will be stored on the site by independent contractors and the machinery will be on site within the fenced area. The lot size is 8.48 acres. There is no residential dwelling within 300 feet. Fencing and berming is proposed for the site. (E) Any storage area for uses not associated with natural resources shall not exceed ten (10) acres in size. (497 -112) Staff Comments: The proposed site is 8.48 acres and no additional storage is proposed. (F) Any lighting of storage area shall be pointed downward and inward to the property center and shaded to prevent direct reflection on adjacent property (A97 -1I2). Staff Comments: The applicant has not submitted any lighting plans. Should outdoor lighting be used, the applicant shall ensure that all lighting is downward and inward facing and no light will trespass on adjoining property. (6) Water pollution: in a case in which potential hazards exist, it shall be necessary to install safeguards designed to comply with the Regulations of the Environmental Protection Agency before operation of the facilities may begin. All percolation tests or ground water resource tests as may be required by local or State Health Officers must be met before operation of the facilities may begin. Staff Comments: The applicant has stated the operation and construction will be in accordance with all COGCC standards and requirements. The applicant is also proposing three to five ground water monitoring wells and three leak detection wells. Regardless, ground water pollution is a concern to the City of Rifle and to Garfield County. Staff is recommending the storm water detention pond must be lined and the land farm area must be contained within an impermeable material. 7 4. SUGGESTED FINDINGS 1. That proper public notice was provided as required for the hearing before the Planning Commission 2. That the hearing before the Planning Commissioners was extensive and complete, that all pertinent facts, matters and issues were submitted and that all interested parties were heard at that meeting. 3. That for the above stated and other reasons, the proposed Special Use Permit is in the best interest of the health, safety, convenience, order, prosperity and welfare of the citizens of Garfield County. 4. That the application is in conformance with the Garfield County Zoning Resolution of 1978, as amended. 5. STAFF RECOMENDATION: Staff is recommending the Planning Commission recommend approval to the Board of County Commissioners for this Special Use Permit to allow a Centralized Exploration and Production Facility for a land farm to treat soils contaminated with petroleum hydrocarbons. 1. That all representations of the Applicant, either within the application or stated at the hearing before the Planning Commissioners, shall be considered conditions of approval unless explicitly altered by the Commission. 2. That the operation of the facility be done in accordance with all applicable federal, state, and local regulations governing the operation of this type of facility. 3. Should the need arise, the County reserves the right to retain outside expertise, at the expense of the applicant / operator of the facility, in order to conduct tests or analyses of the physical nature, water chemistry or groundwater properties on or away from the site. 4. That this facility is for the sole use of the applicant. If any other entities are to be added as users, then they would be subject to an additional SUP as well as rules and regulations as administered by the COGCC. 5. The Applicant shall submit a weed inventory and control plan of the subject property. 6. The Applicant shall comply with all standards as set forth in §5.03.08 "Industrial Performance Standards" of the Garfield County Zoning Resolution of 1978 as amended. 7. The storm water detention pond must be Iined.axki4ite-tarrtraim area mtiMn4alita within an impermeable material. 8 8. The ownership of E & P wastes shall be documented as to generation and the disposal location. Such data shall be made available to the County upon request. 9. That the Applicant shall obtain a City of Rifle Watershed District Permit prior to issuance of the JP; Al4A&C SUP SwI'`, 10. That there shall be five ground wate o itorin: w- lls . d three Ieak detection wells; these wells shall be sampled and tested in accordance with State and Federal regulations. Results shall be provided to the County on an annual basis. 11. That the Applicant shall insure its contractor obtains Storm water Discharge Permit from CDPHE prior to issuance of the SUP and complies with the approved erosion and sediment control plan. 12. That the Applicant shall submit an Air Pollutant Emission Notice to the CDPHE prior to issuance of the SUP. 13. That the Applicant phases the berming to the area or areas that are immediately used for the land farm. ! I. ifres Offi'- 6. RECOMMENDED MOTION "I move to approve the Special Use Permit request for a Centralized Exploration and Production Facility for a land farm to treat soils contaminated with petroleum hydrocarbons on a parcel owned by EnCana Oil and Gas (USA), Inc that is southeast of the Garfield County Airport." 41-7 bill font Lift/ , Alr►gSSr,1S AM "64% ‘ friAt-P ArR 4p/5' l'/I/IT iw GlisJ 01/w-- W1,1, GC Af ; agile-- agile-- , w ( Li N i;11 Ok ;lie asuos ? R Pte) up% 4i io kribka, It.0 lid IA g0« 4 n A4.05 44.71411-/-. 9 Landfarming Page 1 of 5 Landfarming U, Environmental Protection Agency Underground Storage Tanks Recent Additions I Contact Us I Search: EPA Home > Underground Storage Tanks > Cleaning Up UST System Releases > Landfarming GO The following description of Landfarming is an excerpt from Chapter V of OUST's publication: How to Evaluate Alternative Cleanup Technologies for Underground Storage Tank Sites: A Guide for Corrective Action Plan Reviewers. (EPA 510 -B -95 -007). This publication also describes 9 additional alternative technologies for remediation of petroleum releases. You can download PDF files of every chapter of the document at: http:// www. epa.gov /swerustl /pubs/fums.htm. Landfarming, also known as land treatment or land application, is an above - ground remediation technology for soils that reduces concentrations of petroleum constituents through biodegradation. This technology usually involves spreading excavated contaminated soils in a thin layer on the ground surface and stimulating aerobic microbial activity within the soils through aeration and /or the addition of minerals, nutrients, and moisture. The enhanced microbial activity results in degradation of adsorbed petroleum product constituents through microbial respiration. If contaminated soils are shallow (i.e., less than 3 feet below ground surface), it may be possible to effectively stimulate microbial activity without excavating the soils. If petroleum- contaminated soil is deeper than 5 feet, the soils should be excavated and reapplied on the ground surface. Application Landfarming has been proven effective in reducing concentrations of nearly all the constituents of petroleum products typically found at underground storage tank (UST) sites. Petroleum products generally encountered at UST sites range from those with a significant volatile fraction, such as gasoline, to those that are primarily nonvolatile, such as heating and lubricating oils. Petroleum products generally contain more than one hundred different constituents that possess a wide range of volatility. In general, gasoline, kerosene, and diesel fuels contain constituents with sufficient volatility to evaporate from a landfarm. Lighter (more volatile) petroleum products (e.g., gasoline) tend to be removed by evaporation during landfarm aeration processes (i.e., tilling or plowing) and, to a lesser extent, degraded by microbial respiration. Depending upon your state's regulations for air emissions of volatile organic compounds (VOCs), you may need to control the VOC emissions. Control involves capturing the vapors before they are emitted to the atmosphere, passing them through an appropriate treatment process, and then venting them to the atmosphere. The mid -range hydrocarbon products (e.g., diesel fuel, kerosene) contain lower percentages of lighter (more volatile) constituents than does gasoline. Biodegradation of these petroleum products is more significant than evaporation. Heavier (non - volatile) petroleum products (e.g., heating oil, lubricating oils) do not evaporate during landfarm aeration; the dominant mechanism that breaks down these petroleum products is biodegradation. However, higher molecular weight petroleum constituents such as those found in heating and lubricating oils, and, to a lesser extent, in diesel fuel and kerosene, require a longer period of time to degrade than do the constituents in gasoline. Operation Principles Soil normally contains large numbers of diverse microorganisms including bacteria, algae, fungi, protozoa, and actinomycetes. In well - drained soils, which are most appropriate for landfarming, these organisms are generally aerobic. Of these organisms, bacteria are the most numerous and biochemically active group, particularly at low oxygen levels. Bacteria require a carbon source for cell growth and an energy source to httpi/ www. epa .gov /cgi- binlepaprintonly.cgi 9/30/2005 Landfarming Page 2 of 5 sustain metabolic functions required for growth. Bacteria also require nitrogen and phosphorus for cell growth. Although sufficient types and quantities of microorganisms are usually present in the soil, recent applications of ex -situ soil treatment include blending the soil with cultured microorganisms or animal manure (typically from chickens or cows). Incorporating manure serves to both augment the microbial population and provide additional nutrients. The metabolic process used by bacteria to produce energy requires a terminal electron acceptor (TEA) to enzymatically oxidize the carbon source to carbon dioxide. Microbes are classified by the carbon and TEA sources they use to carry out metabolic processes. Bacteria that use organic compounds (e.g., petroleum constituents and other naturally occurring organics) as their source of carbon are heterotrophic; those that use inorganic carbon compounds (e.g., carbon dioxide) are autotrophic. Bacteria that use oxygen as their TEA are aerobic; those that use a compound other than oxygen, (e.g., nitrate, sulfate), are anaerobic; and those that can utilize both oxygen and other compounds as TEAs are facultative. For landfarming applications directed at petroleum products, only bacteria that are both aerobic (or facultative) and heterotrophic are important in the degradation process. The effectiveness of landfarming depends on parameters that may be grouped into three categories: 1. soil characteristics 2. constituent characteristics 3. climatic conditions. Soil texture affects the permeability, moisture content, and bulk density of the soil. To ensure that oxygen addition (by tilling or plowing), nutrient distribution, and moisture content of the soils can be maintained within effective ranges, you must consider the texture of the soils. For example, soils which tend to clump together (such as clays) are difficult to aerate and result in low oxygen concentrations. It is also difficult to uniformly distribute nutrients throughout these soils. They also retain water for extended periods following a precipitation event. The volatility of contaminants proposed for treatment by landfarming is important because volatile constituents tend to evaporate from the landfarm, particularly during tilling or plowing operations, rather than being biodegraded by bacteria. Depending upon state - specific regulations for air emissions of volatile organic compounds (VOCs), control of VOC emissions may be required. Control involves capturing vapors before they are emitted to the atmosphere and then passing them through an appropriate treatment process before being vented to the atmosphere. Control devices range from erected structures such as a greenhouse or plastic tunnel to a simple cover such as a plastic sheet. Although nearly all constituents in petroleum products typically found at UST sites are biodegradable, the more complex the molecular structure of the constituent, the more difficult, and less rapid, is biological treatment. Most low molecular- weight (nine carbon atoms or less) aliphatic and monoaromatic constituents are more easily biodegraded than higher molecular weight aliphatic or polyaromatic organic constituents. Typical landfarms are uncovered and, therefore, exposed to climatic factors including rainfall, snow, and wind, as well as ambient temperatures. Rainwater that falls directly onto, or runs onto, the landfarm area will increase the moisture content of the soil and cause erosion. During and following a significant precipitation event, the moisture content of the soils may be temporarily in excess of that required for effective bacterial activity. On the other hand, during periods of drought, moisture content may be below the effective range and additional moisture may need to be added. Erosion of landfarm soils can occur during windy periods and particularly during tilling or plowing operations. Wind erosion can be limited by plowing soils into windrows and applying moisture periodically. In colder parts of the United States, such as the Northeastern states, the length of the landfarming season is shorter, typically ranging from only 7 to 9 months. In very cold climates, special precautions can be taken, including enclosing the landfarm within a greenhouse -type structure or introducing special bacteria (psychrophiles), which are capable of activity at lower temperatures. In warm regions, the landfarming season can last all year. System Design Landfarm Construction includes: site preparation (grubbing, clearing and grading); berms; liners (if httpJ/ www. epa .gov /cgi- bin/epaprintonly.cgi 9/30/2005 Landfarming Page 3 of 5 necessary); leachate collection and treatment systems; soil pretreatment methods (e.g., shredding, blending and amendments for fluffing, pH control); and enclosures and appropriate vapor treatment facilities (where needed). To support bacterial growth, the soil pH should be within the 6 to 8 range, with a value of about 7 (neutral) being optimal. Soils with pH values outside this range prior to landfarming will require pH adjustment prior to and during landfarming operations. Soil pH within the landfarm can be raised through the addition of lime and lowered by adding elemental sulfur. Soil microorganisms require moisture for proper growth. Excessive soil moisture, however, restricts the movement of air through the subsurface thereby reducing the availability of oxygen which is also necessary for aerobic bacterial metabolic processes. In general, the soil should be moist but not wet or dripping wet. The ideal range for soil moisture is between 40 and 85 percent of the water - holding capacity (field capacity) of the soil or about 12 percent to 30 percent by weight. Periodically, moisture must be added in landfarming operations because soils become dry as a result of evaporation, which is increased during aeration operations (i.e., tilling and/or plowing). Excessive accumulation of moisture can occur at landfarms in areas with high precipitation or poor drainage. These conditions should be considered in the landfarm design. For example, an impervious cover can mitigate excessive infiltration and potential erosion of the landfarm. Water Management systems for control of runon and runoff are necessary to avoid saturation of the treatment area or washout of the soils in the landfarm. Runon is usually controlled by earthen berms or ditches that intercept and divert the flow of stormwater. Runoff can be controlled by diversion within the bermed treatment area to a retention pond where the runoff can be stored, treated, or released under a National Pollution Discharge Elimination System (NPDES) permit. Soil Erosion Control from wind or water generally includes terracing the soils into windrows, constructing water management systems, and spraying to minimize dust. Microorganisms require inorganic nutrients such as nitrogen and phosphorus to support cell growth and sustain biodegradation processes. Nutrients may be available in sufficient quantities in the site soils but, more frequently, nutrients need to be added to landfarm soils to maintain bacterial populations. However, excessive amounts of certain nutrients (i.e., phosphate and sulfate) can repress microbial metabolism. If the site is located in an area subject to annual rainfall of greater than 30 inches during the landfarming season, a rain shield (such as a tarp, plastic tunnel, or greenhouse structure) should be considered in the design of the landfarm. In addition, rainfall runon and runoff from the landfarm should be controlled using berms at the perimeter of the landfarm. A leachate collection system at the bottom of the landfarm and a leachate treatment system may also be necessary to prevent groundwater contamination from the landfarm. pH Adjustment and Nutrient Supply methods usually include periodic application of solid fertilizers, lime and/or sulfur while disking to blend soils with the solid amendments, or applying liquid nutrients using a sprayer. The composition of nutrients and acid or alkaline solutions /solids for pH control is developed in biotreatability studies and the frequency of their application is modified during landfarm operation as needed. Air Emission Controls (e.g., covers or structural enclosures) may be required if volatile constituents are present in the landfarm soils. For compliance with air quality regulations, the volatile organic emissions should be estimated based on initial concentrations of the petroleum constituents present. Vapors above the landfarm should be monitored during the initial phases of landfarm operation for compliance with appropriate permits or regulatory limits on atmospheric discharges. If required, appropriate vapor treatment technology should be specified, including operation and monitoring parameters. It is important to make sure that system operation and monitoring plans have been developed for the landfarming operation. Regular monitoring is necessary to ensure optimization of biodegradation rates, to track constituent concentration reductions, and to monitor vapor emissions, migration of constituents into soils beneath the landfarm (if unlined), and groundwater quality. If appropriate, ensure that monitoring to determine compliance with stormwater discharge or air quality permits is also proposed. http:// www. epa .gov /cgi- bin/epaprintonly.cgi 9/30/2005 Landfarming Advantages and Disadvantages Page 4 of 5 Advantages Disadvantages Relatively simple to design and implement. Concentration reductions greater than 95% and constituent concentrations less than 0.1 ppm are very difficult to achieve. Short treatment times (usually 6 months to 2 years under optimal conditions). May not be effective for high constituent concentrations (greater than 50,000 ppm total petroleum hydrocarbons). Cost competitive: $30-60/ton of contaminated soil. Presence of significant heavy metal concentrations (greater than 2,500 ppm) may inhibit microbial growth. Effective on organic constituents with slow biodegradation rates Volatile constituents tend to evaporate rather than biodegrade during treatment. Requires a large land area for treatment. Dust and vapor generation during landfarm aeration may pose air quality concerns. May require bottom liner if leaching from the landfarm is a concern. References Alexander, M. 1994. Biodegradation and Bioremediation. San Diego, CA: Academic Press. Flath man, P.E. and D.E. Jerger. 1993. Bioremediation Field Experience. Boca Raton, FL: CRC Press. Freeman, H.M. 1989. Standard Handbook of Hazardous Waste Treatment and Disposal. New York, NY: McGraw -Hill Book Company. Grasso, D. 1993. Hazardous Waste Site Remediation, Source Control. Boca Raton, FL: CRC Press. Norris, R.D., Hinchee, R.E., Brown, R.A., McCarty, P.L., Semprini, L., Wilson, J.T., Kampbell, D.H., Reinhard, M., Bower, E.J., Borden, R.C., Vogel, T.M., Thomas, J.M., and C.H. Ward. 1994. Handbook of Bioremediation. Boca Raton, FL:CRC Press. Norris, R.D., Hinchee, R.E., Brown, R.A., McCarty, P.L., Semprini, L., Wilson, J.T., Kampbell, D.H., Reinhard, M., Bower, E.J., Borden, R.C., Vogel, T.M., Thomas, J.M., and C.H. Ward. 1993. In -Situ Bioremediation of Ground Water and Geological Material: A Review of Technologies. Ada, OK: U.S. Environmental Protection Agency, Office of Research and Development. EPA/5R-93/124. Pope, Daniel F., and J.E. Matthews. 1993. Environmental Regulations and Technology: Bioremediation Using the Land Treatment Concept. Ada, OK: U.S. Environmental Protection Agency, Environmental Research Laboratory. EPAI600 /R- 93/164. Additional Information • Glossary EPA Home I Privacy and Secudy Notice I Contact Us http:// www. epa .gov /cgi- bin/epaprintonly.cgi 9/30/2005 Landfarming Page 5 of 5 This page was generated on Friday, September 30, 2005 View the graphical version of this page at: http: / /www, epa .gov /swerust1 /cat/landfarm.htm http: /lwww. epa .gov /cgi- binlepaprintonlv.cgi 9/30/2005 RECEIVED SEP 2 9 2005 GARFIELD COUNTY BUILDING & PLANNING September 26, 2005 Mr. Richard Wheeler Garfield County Building & Planning 108 8i1' Street, Suite 201 Glenwood Springs, CO 81601 SUBJECT: ENCANA Centralized E &P Waste Management Facility Dear Mr. Wheeler, The subject application was circulated to City of Rifle staff. I am attaching a bullet list prepared by Richard Deussen, City Engineer, on behalf of the Public Works Department. The identified issues represent the City's position on this matter, and many items will be addressed in the City's watershed permit. You will see, the City's greatest concern is in regard to water quality issues and protecting the City's potable water supply. Should Garfield County choose not to adopt these conditions as its own, at a minimum the City of Rifle requests Garfield County require the applicant obtain a City of Rifle Watershed Permit prior to the land use being established. Should you have questions regarding this matter, please contact me directly at 625 -6221 As always, thank you for the opportunity to comment. Sincerely, Department of Public Works Bill Sappington, Director Enclosure. c. Jim Neu, City Attorney Michael Erion, Resource Engineering Jimmy Smith, Wagon Wheel Consulting, Inc C I T Y OF R I F L E 202 R A I L R O A D A V E N U E • P.O. B O X 1 9 0 8 • R I F L E , CO 8 1 6 5 0 W W W . R I F L E C O. O R G Comments on the Special Use Permit Application for A Centralized Exploration & Production (E & P) Bioremediation Waste Management Facility R. Deussen, City of Rifle 9/14/05 1. Watershed Permit Required. 2. Provide secondary containment for land farm. 2. No discharge of liquid or solid wastes will be allowed outside of the containment area to areas that will discharge stormwater to the Colorado River. 3. Inspection of the site at any time by City staff or its consultants shall be allowed by Encana. Soil and water sampling and testing by others will likewise be allowed by Encana. 4. Liquid detention pond shall be lined with impregnable material. 5. Each disposal of treated wastes shall be reviewed if within the watershed areas of the Colorado River or Beaver Creek prior to disposal. 6. Spills at the site shall be reported to the City of Rifle Public Works Department. 7. A responsible operator shall be provided for the site and be available at any time for consultation with the City. 8. Washing of vehicles leaving the site shall be required using highly chlorinated water with the water used contained on site and /or used for moisture control. 9. Management of the facility shall be by approved qualified waste operators subject to oversite by State regulators. 10. A mobile office trailer or building shall be provided on -site for management & operating personnel. 11. Provide a site management plan showing cell development and use depending upon treatment or age of materials, maximum depth of soil to be treated in any one cell, spraying equipment and moisture control equipment, dust control, secondary containment, fertilizer and nutrient storage areas and containment. 12. Provide a site development plan showing vehicle washing area, piping, drainage facilities, pumping facilites, spraying equipment layout, storage, signage, buffer zone, landscaping, fencing and cells. 13. Water trucks carrying potable water to the site shall be provided with approved cross - connection control devices which shall be annually inspected by a certified inspector. 14. Sanitary facilities for operating personnel shall be provided and contained in a holding tank with wastes removed as needed to an appropriate treatment facility. 15. The ownership of E & P wastes shall be documented as to generation and the disposal location for tracking purposes. 16. Provide a Bond for spill remediation affecting the watershed which may be used by the City for remediation, if not performed satisfactorily within 2 days of the spill by Encana. 17. Visibility of the site and vehicles shall be reduced by the construction of berms (higher than 2 feet) or by landscaping or by obscure fencing. 18. All vehicles at the site shall be provided with hospital (quiet) type mufflers. 19. Monthly test results of the monitoring wells by an independent laboratory shall be provided to the City of Rifle. 20. Tests may be conducted for other physical characteristics at the direction of the City of Rifle with the cost of such test paid for by Encana. 21. Monitoring wells shall be sampled and tested by an independent testing laboratory. 22. Berms shall be provided around each bioremediation cell with underdrains and overflows to stormwater retention pond. 23. Provide pilot plant test result to show this as a viable treatment option so that we are not approving a process that will not work with this type of waste and will just be a dump site for wastes. 24. Fertilizer and nutrients shall be provided with contaiiunent and shall be non- flammable. 25. Wash water shall be contained on site. 26. Erosion control and stormwater management are required during construction to limit runoff to the Colorado River. 27. Freeboard above the 100 year storm in the retention pond shall be a minimum of two feet.