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HomeMy WebLinkAbout5.0 Review Response from Doug Dennison1 ASG 1 'JIG Fred Jarman From: Doug Dennison Sent: Tuesday, July 06, 2004 4:03 PM To: Fred Jarman Subject: Review of SUP Application - EnCana Water Storage Pond Fred, I have reviewed the subject application for a Special Use Permit and have the following comments: General Comment -- Although this SUP application implies that this facility is yet to be constructed, the facility already exists and has been in operation as storage for fresh water for several months. As indicated in some of my specific comments below, it is not clear to me whether the facility will continue as it exists today or if new construction will occur if the SUP is approved. It might be helpful for the applicant to clearly define what modifications will be made to the facility in the future. Part 1 Comments - • The 3rd paragraph of this section states that the treatment system at EnCana's Hunter Mesa facility will lower the TDS concentration in the produced water to less than 3,000 ppm. To date, it is my understanding that EnCana's treatment system is not fully functional; therefore, it would be difficult for the applicant to demonstrate that the system is capable of achieving these kinds of treatment levels. I would recommend that the SUP not be approved unless the applicant can provide documentation as to the effectiveness of its treatment system or that a condition to this effect be placed on the approved SUP. In addition, ongoing monitoring of the treated water should be specified to assure the continued effectiveness of the system. I would also recommend that the applicant address methods used to treat produced water to remove any hydrocarbons present in the water and their effectiveness. It is possible that the methods for treating produced water and the water -quality levels that must be met are specified in the SUP issued by Garfield County to EnCana for operation of its Hunter Mesa Water Treatment Facility. If so, then it may be appropriate to cross-reference the SUP for the water storage pond to the standards specified in the Hunter Mesa facility SUP. I am also concerned what effects to vegetation, etc. might occur if there were a spill or break in the pipelines transporting this treated water throughout Grass Mesa. Most references I have reviewed specify an upper limit of 2,000 ppm TDS for waters used to irrigate crops. • The 4th and 5th paragraphs of this section discuss the installation of a pump and associated building. It is not clear as to whether this pump and building are the same as currently exist at the site or will replace or be in addition to those that already exist. Part 11 Comments — • The 3rd paragraph of this section specifies that the facility will not exceed the 75 decibel standard established under Colorado Revised Statutes (CRS) 25-12-103. However, I don't believe that this facility meets the definition of a construction project, as specified under CRS 25-12-103(5) and should be subject to a lower noise standard, such as the residential standard. Similarly, Colorado 0i1 & Gas Conservation Commission (COGCC) Rule 802, which essentially mirrors CRS 25-12-103, only allows the higher, industrial zone noise level to be applied only in specific instances for temporary activities (e.g., use of a drilling rig, stimulation, etc.), and operation of this facility can not be classified as a temporary activity under the COGCC rule. Based on recent conversations with COGCC staff on how this rule is applied, it is my opinion that the noise from this facility would have to meet the residential noise level limitations when measured at any residence where the noise could be heard. • The 5th paragraph of this section specifies that the water storage pond is lined with an impermeable high-density polyethylene (HDPE) liner. I would recommend that the applicant provide documentation regarding the installation and testing, both at installation and ongoing during operation, of this liner to ensure that leaks are prevented or quickly identified and repaired. Let me know if you have any questions or need additional clarification. 7/6/2004 [lgc L U1 L Doug Dennison Garfield County Oil & Gas Auditor mailto:ddennison(a�garfield-county.com (970) 625-5691 cell (970) 309-5441 fax (970) 625-0908 7/6/2004