ML22139A202
| ML22139A202 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 08/15/2016 |
| From: | Fiedler C, Gordon I, Tucholke D State of NM, Energy, Minerals and Natural Resources Department |
| To: | Griswold J Office of Nuclear Material Safety and Safeguards, Sundance West. |
| Caverly J | |
| References | |
| Download: ML22139A202 (128) | |
Text
STATE OF NEW MEXICO DIRECTOR OF OIL CONSERVATION DIVISION IN THE MATTER OF THE APPLICATION OF SUNDANCE WEST, INC.
FOR A
SURFACE WASTE MANAGEMENT FACILITY PERMIT APPLICATION FOR PERMIT SUNDANCE WEST AUGUST 2016 VOLUME I: PERMIT APPLICATION TEXT Prepared For:
Sundance West, Inc.
1001 6th Street Eunice, NM 88231 Submitted To:
New Mexico Energy, Minerals, and Natural Resources Department Oil Conservation Division 1220 South St. Francis Drive Santa Fe, NM 87505 (505) 476-3440 Prepared By:
Gordon Environmental, Inc.
213 South Camino del Pueblo Bernalillo, NM 87004 (505) 867-6990
P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\MasterTOC_August.2016.doc i
APPLICATION FOR PERMIT SUNDANCE WEST SURFACE WASTE MANAGEMENT FACILITY TABLE OF CONTENTS CERTIFICATION OF APPLICATION CERTIFICATION OF SERVICE C-137 APPLICATION FOR SURFACE WASTE MANAGEMENT FACILITY VOLUME I:
PERMIT APPLICATION TEXT Section Title 19.15.36 Surface Waste Management Facilities VOLUME II:
FACILITY MANAGEMENT PLANS Section Title 1
Operations, Inspection, and Maintenance Plan 2
Oil Field Waste Management Plan 3
Hydrogen Sulfide (H2S) Prevention and Contingency Plan 4
Closure/Post-Closure Plan 5
Contingency Plan 6
Migratory Bird Protection Plan 7
Liner Construction Quality Assurance (CQA) Plan 8
Vadose Zone Monitoring Plan 9
Leachate Management Plan VOLUME III:
ENGINEERING DESIGN AND CALCULATIONS Section Title 1
Engineering Design 2
Volumetrics Calculations 3
Drainage Calculations 4
HELP Model 5
Pipe Loading Calculations 6
Geosynthetic Application and Compatibility Documentation 7
Tensile Stress Analysis 8
Settlement Calculations 9
Evaporation Pond Calculations 10 Wave Action Calculations
P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\MasterTOC_August.2016.doc ii APPLICATION FOR PERMIT SUNDANCE WEST SURFACE WASTE MANAGEMENT FACILITY TABLE OF CONTENTS (cont.)
VOLUME IV:
SITING AND HYDROGEOLOGY Section Title 1
Siting Criteria 2
Hydrogeology LIST OF ENGINEERING DRAWINGS Sheet Title 1
Cover Sheet and Drawing Index 2
Existing Site Conditions 3
Site Development Plan 4
Base Grading Plan 5
Final Grading Plan 6
East Phase Development Base Grading Plan 7
East Phase Development Intermediate and Final Grading Plan 8
Landfill Completion Drainage Plan 9
East Phase Development Drainage Plan 10 Drainage Channel Profiles and Typical Sections 11 Landfill Cross Sections 12 Liner System and Cover System 13 Leachate Collection System Details 14 Stormwater Drainage Details 15 Evaporation Pond Layout 16 Evaporation Pond Details 17 Evaporation Pond Cross Sections 18 Process Layout 19 Process Layout Cross Sections
APPLICATION FOR PERMIT SUNDANCE WEST VOLUME I: PERMIT APPLICATION TEXT PART 36: SURFACE WASTE MANAGEMENT FACILITIES I-i P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx TABLE OF CONTENTS Section No.
Title Page
1.0 INTRODUCTION
......................................................................................... I-1 19.15.36.8 SURFACE WASTE MANAGEMENT FACILITY PERMITS AND APPLICATION REQUIREMENTS:.......................................................... I-13 19.15.36.9 NOTICE REQUIREMENTS FOR NEW SURFACE WASTE MANAGEMENT FACILITIES, MAJOR MODIFICATIONS OR RENEWALS AND ISSUANCE OF A TENTATIVE DECISION:........... I-22 19.15.36.10 COMMENTS AND HEARING ON APPLICATION:............................... I-25 19.15.36.11 FINANCIAL ASSURANCE REQUIREMENTS:...................................... I-25 19.15.36.12 PERMIT APPROVAL, DENIAL, REVOCATION, SUSPENSION, MODIFICATION OR TRANSFER:........................................................... I-28 19.15.36.13 SITING AND OPERATIONAL REQUIREMENTS APPLICABLE TO ALL PERMITTED SURFACE WASTE MANAGEMENT FACILITIES:
EXCEPT AS OTHERWISE PROVIDED IN 19.15.36 NMAC................. I-32 19.15.36.14 SPECIFIC REQUIREMENTS APPLICABLE TO LANDFILLS:............. I-43 19.15.36.15 SPECIFIC REQUIREMENTS APPLICABLE TO LANDFARMS:.......... I-62 19.15.36.16 SMALL LANDFARMS:............................................................................. I-62 19.15.36.17 SPECIFIC REQUIREMENTS APPLICABLE TO EVAPORATION, STORAGE, TREATMENT AND SKIMMER PONDS:............................ I-62 19.15.36.18 CLOSURE AND POST CLOSURE:.......................................................... I-70 19.15.36.19 EXCEPTIONS AND WAIVERS:............................................................... I-77 19.15.36.20 TRANSITIONAL PROVISIONS:.............................................................. I-78 LIST OF FIGURES Figure No.
Title Page I.1 SITE LOCATION MAP........................................................................... I-2 I.2 SITE PLAN............................................................................................... I-4 I.3 SITE TOPOGRAPHY............................................................................ I-15 I.4 SITE ENTRANCE SIGN (TYPICAL)................................................... I-38 I.5 LINER SCHEMATIC............................................................................. I-50 I.6 FINAL COVER PROFILE..................................................................... I-55
APPLICATION FOR PERMIT SUNDANCE WEST VOLUME I: PERMIT APPLICATION TEXT PART 36: SURFACE WASTE MANAGEMENT FACILITIES I-ii P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx LIST OF TABLES Table No.
Title Page I.1 SITE ACREAGES.................................................................................... I.3 I.2 ESTIMATED OPERATIONAL RATES................................................. I.5 I.3 PROPOSED FACILITIES........................................................................ I.5 I.4 SUNDANCE WEST DEVELOPMENT SEQUENCE............................ I.7 I.5 LIST OF PERMIT PLANS....................................................................... I.9 I.6 LIST OF ACRONYMS AND DEFINITIONS....................................... I.10 I.7 FIRE PREVENTION AND CONTROL................................................ I.44 I.8 DUST CONTROL.................................................................................. I.45 LIST OF ATTACHMENTS Attachment No.
Title I.A PARTIAL ASSIGNMENT AND ASSUMPTION OF LEASE I.B PUBLIC NOTIFICATION I.C FINANCIAL ASSURANCE
I-1 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx APPLICATION FOR PERMIT SUNDANCE WEST VOLUME I: PERMIT APPLICATION TEXT PART 36: SURFACE WASTE MANAGEMENT FACILITIES
1.0 INTRODUCTION
Sundance West is a proposed new commercial Surface Waste Management Facility for oil field waste processing and disposal services. The proposed Sundance West Facility is subject to regulation under the New Mexico Oil and Gas Rules, specifically 19.15.36 NMAC, administered by the Oil Conservation Division (OCD). The Facility is designed in compliance with 19.15.36 NMAC, and will be constructed and operated in compliance with a Surface Waste Management Facility Permit issued by the OCD. The Facility is owned by, and will be constructed and operated by, Sundance West, Inc. (Sundance West).
Sundance West herein submits this Application for Permit (Application) for the proposed Sundance West Facility. This Application has been developed in order to address the specific standards of 19.15.36 NMAC. As a Surface Waste Management Facility per 19.15.2.7.S.11 NMAC, Sundance West will meet the siting, design, and operating requirements of 19.15.36 NMAC, as detailed in this Application. More specifically, the proposed Sundance West Facility is a commercial facility as defined in Section 19.15.36.7.A.(2) NMAC: a surface waste management facility that is not a centralized facility, more specifically a landfill and a processing area.
1.1 Site Location The Sundance West Site is located approximately 3 miles east of Eunice, 18 miles south of Hobbs, and approximately 1.5 miles west of the Texas/New Mexico state line in unincorporated Lea County, New Mexico (NM). The Sundance West Site is comprised of a 320-acre +/- tract of land located in the South 1/2 of Section 30, Township 21 South, Range 38 East, Lea County, NM. Site access will be provided via NM 18 and Wallach Lane. A Site Location Map is provided as Figure I.1.
I-3 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx 1.2 Site Description The Sundance West Facility represents a new facility that will include a landfill and ancillary oilfield waste management infrastructure intended as a replacement for the current Sundance Services, Inc. (SSI) facility, which has operated adjacent to the proposed facility since approximately 1977 in accordance with OCD Permit No. NM 01-0003. Operations at the current Sundance Services, Inc. facility will be phased out and closed once the Application for the new Sundance West Facility has been approved by OCD and replacement infrastructure constructed. As a function (e.g., Landfill) becomes operational at Sundance West, that same function will be phased out at SSI. The Sundance West Facility will include two main components; a liquid oil field waste Processing Area and an oil field waste Landfill. Oil field wastes are anticipated to be delivered to the Sundance West Facility from oil and gas exploration and production operations in southeastern NM and west Texas. The Site Plan provided as Figure I.2 identifies the locations of the Processing Area and Landfill facilities, and Table I.1 provides a description of site acreages. Perimeter setbacks in excess of 100 ft are provided for surface water management and site access, as well as a buffer zone to adjacent properties.
TABLE I.1 Site Acreages Sundance West Description Acres (+/-)
Sundance West Site: Total Tract (Facility Boundary) 320 Surface Waste Management Facility: Processing Area 80 Surface Waste Management Facility: Landfill 180 A Site Plan which identifies the layout of the proposed Sundance West Facility is provided as Figure I.2. Operations at the proposed Sundance West Facility, may be constructed in phases over a period of several years, as dictated by demand. The estimated Facility operational rates are presented in Table I.2, and the phased development sequence is described in Section 1.3 and Table I.4.
I-5 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx TABLE I.2 Estimated Operational Rates1,2,3 Sundance West Average Daily Liquid Operational Rate 9,000 bbl/day Maximum Daily Liquid Operational Rate 10,000 bbl/day Average Daily Solid Waste Acceptance Rate 2,500 cy/day Maximum Daily Solid Waste Acceptance Rate 5,000 cy/day Liquid Storage Capacity 787,000 bbl Notes:
1Subject to change. The estimated operational rates are based on familiarity with local oil and gas industry operations; therefore this list may be modified in response to changes in waste streams, market conditions, technology, etc.
The proposed Sundance West surface waste management facilities are listed in Table I.3, and identified on the Site Plan provided as Figure I.2.
TABLE I.3 Proposed Facilities1 Sundance West Description No.
Oil field waste disposal landfill (180 acre +/-)
1 Produced water load-out points 8
Produced water tanks 45 Evaporation ponds 10 Stabilization and Solidification Area 1
Crude oil recovery tanks 3
Oil sales tanks 2
Customer jet wash 1 (6 bays)
Note:
1Subject to change. The proposed facilities are based on projected waste types and volumes; therefore this list may be modified in response to changes in waste streams, market conditions, technology, etc.
The improvements identified in Table I.3 are discussed in detail in this Application. In addition, various support facilities, including: an office, waste acceptance/security, maintenance building, roads, break room, emergency shower & eyewash station, and stormwater detention basins are proposed for the new Facility (see Engineering Design, Volume III).
I-6 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx 1.3 Development Sequence The development sequence for the Sundance West Facility is proposed to be conducted in four primary phases (Table I.4). This phased development sequence is estimated to take place over a period of approximately four years from the issuance of the Permit, to allow for the planned closure and transfer of operations from the existing SSI facility. However, different combinations of these improvements may be constructed at any time. The phased development is projected as follows:
Phase I - Initial Operations. This Phase will include the development of the initial landfill cell, installation of four Produced Water Load-Out points, the complete tank farm berm, the 75 HP boiler circulating a heat transfer fluid to the twenty 1,000 bbl heated Produced Water Tanks, two Mechanical Oil/Water Separation Units, four Evaporation Ponds with a capacity of 9.5 acre-feet each, capable of evaporating 3,000 bbl per day of liquid, one 1,000 bbl heated Crude Oil Recovery Tank, the Oil Recovery Centrifuge and one 1,000 bbl Oil Sale Tank. This Phase will be completed within approximately one year of permitting.
Phase II - Jet-Out Pit Operation-This Phase of the operation will include installation of the six station, Jet-Out Pit for handling BS&W, Tank Bottoms, Oily Drilling Muds and Tank Wash-Outs, the addition of one 1,000 bbl Crude Oil Recovery Tank, and the construction of the 5-acre Stabilization and Solidification Area. This Phase will be completed within approximately two years of permitting.
Phase III-Expanded Produced Water Processing Operation. This Phase will include the installation of an additional two Produced Water Load-Out points, ten additional 1,000 bbl heated Produced Water Tanks, one additional Mechanical Oil/Water Separator, four additional 9.5 acre-foot ponds capable of evaporating an additional 5,000 bbl per day of liquid, and one additional Oil Sales Tank. This Phase will be completed within approximately three years of permitting.
P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I.1-Table I.4-DevSeq_Feb 2015_August.2016 Summary Year No.2
- Initial Landfill Cell (13.5-acres)
- Produced water load-out points (4)
- Tank farm berm (complete)
- Boiler (75 HP) running a heat transfer fluid tank farm
- Produced Water Tanks (20), 1,000 bbl capacity3
- Mechanical Oil/Water Separation Unit (2)
- Evaporation Ponds (4) capable of evaporating 3,000 bbl of liquid per day
- Crude Oil Recovery Tank (1), 1,000 bbl capacity
- Oil Recovery Centrifuge
- Oil Sale Tank (1), 1,000 bbl capacity
- Jet-Out Pit (six-station) for handling basic sediment and water (BS&W), tank bottoms, oily drilling muds and tank wash-outs
- Additional crude oil recovery tank (1), 1,000 bbl capacity
- Install 5-acre Stabilization and Solidification Area
- Produced water load-out points (2)
- Additional Produced Water Tanks (10), 1,000 bbl capacity
- Additional (1) Mechanical Oil/Water Separation Unit
- Additional ponds (4) capable of evaporating an additional 4,000 bbl per day of liquid
- Additional Crude Oil Recovery Tank (1), 1,000 bbl capacity
- Additional Oil Sales Tank (1), 1,000 bbl capacity
- Produced water load-out points (2)
- Additional Produced Water Tanks (15), 1,000 bbl capacity
- Additional (1) Mechanical Oil/Water Separation Unit
- Additional ponds (2) capable of evaporating an additional 2,000 bbl per day of liquid
- Additional Crude Oil Recovery Tank (1), 1,000 bbl capacity Notes:
3 bbl = barrels of oil Phase VI - Ultimate Produced Water Processing Facility.
Description Phase II - Jet-Out Pit Operation.
The oil recovered from the top of the Jet-Out Pit will be pumped to a heated Crude Oil Recovery Tank installed in the Tank Farm. Oil recovery from the Produced Water Tanks will also be plumed to this tank. Water recovered from the Pit will be pumped to the Produced Water Receiving Tanks. Sediments from the Pit will be bucket-loaded out of the pit and transferred to the Stabilization and Solidification Area for processing prior to landfilling.
2 The additional oil recovered from the expanded Produced Water Processing Operation process, anticipated to be 6 bbl per day (for a total of 12 bbls per day), will pumped to the Crude Oil Recovery tanks for further processing.
3 Phase III -Expanded Produced Water Processing Operation.
The additional oil recovered from the ultimate Produced Water Processing Facility will be pumped to the Crude Oil Recovery Tank for further processing.
4 1 The Sundance West site development sequence is subject to change. Different combination of these improvements may be constructed at any time.
2 Estimated number of years after OCD Surface Waste Management Facility Permit issued TABLE I.4 Sundance West Phase I - Initial Landfill & Produced Water Processing Operation.
1 Sundance West Development Sequence (Phasing)1 The oil recovered from the Produced Water Processing Operations process is anticipated to be 6 bbl per day. This material will be pumped to the heated crude oil recovery tank for further processing before being pumped to the oil sale tank.
I-8 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx Phase IV - Ultimate Produced Water Processing Facility. This final phase of development will include the installation of two additional Produced Water Load-Out points, fifteen additional 1,000 bbl Produced Water Tanks, one additional Mechanical Oil/Water Separation Unit, two additional 9.5 acre-foot ponds capable of evaporating an additional 2,000 bbl per day of liquid, and one additional 1,000 bbl Crude Oil Recovery Tank, this Phase will be completed within approximately four years of permitting.
1.4 Permit Application Format For ease of review and reference, this Application for Permit has been organized into a four-volume set, in the same order and format as the current Rules for Surface Waste Management Facilities (19.15.36 NMAC). OCD Form C-137 (Application for Surface Waste Management Facilities) is provided as a preface to this Volume. The Permit Application Text provided in Volume I addresses the applicable requirements of 19.15.36 NMAC, by restating each requirement (in bold) followed by the appropriate response (in italics).
The Facility Management Plans provided in Volume II address the operation and closure of storage tanks, evaporation ponds, solid waste landfill and supporting infrastructure (i.e.,
stormwater drainage). Design data and supporting calculations in accordance with the applicable sections of 19.15.36 NMAC are presented in Volume III. Volume IV of this Application provides the results of focused site characterization and hydrogeological investigations for the entire 320 acre +/- site.
In many cases, the technical response to a particular item is so sufficiently detailed or complex that a separate graphic, table, report, plan, or calculation has been prepared. The applicable technical documents in this Application are cross-referenced in the narrative responses to each of the individual regulatory requirements as delineated in Volume I. Each section of each volume also includes, as applicable:
- Table of Contents
- List of Figures
- List of Tables
- List of Attachments
I-9 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx The Table of Contents for the entire four-volume Application is also included in each volume in order to assist in cross-referencing, along with the List of Permit Plans (Table I.5). The four-volume Application is provided in four binders. Each binder is divided by tabs which identify the Volume and Section as referenced in the master Table of Contents.
TABLE I.5 List of Permit Plans Sheet Title 1
Cover Sheet and Drawing Index 2
Existing Site Conditions 3
Site Development Plan 4
Base Grading Plan 5
Final Grading Plan 6
East Phase Development Base Grading Plan 7
East Phase Development Intermediate and Final Grading Plan 8
Landfill Completion Drainage Plan 9
East Phase Development Drainage Plan 10 Drainage Channel Profiles and Typical Sections 11 Landfill Cross Sections 12 Liner System and Cover System 13 Leachate Collection System Details 14 Stormwater Drainage Details 15 Evaporation Pond Layout 16 Evaporation Pond Details 17 Evaporation Pond Cross Sections 18 Processing Area Layout 19 Process Layout Cross Sections
TABLE I.6 List of Acronyms and Definitions Sundance West ADC Alternative Daily Cover:
Materials that are suitable for use, with Department approval, as a replacement for the 6 daily cover layer include; tarps, foams, select C & D and other emerging technologies that conserve landfill capacity.
ASTM American Society for Testing and Materials BBL Barrels; 42 gallons (oil)
BTEX Benzene, Toluene, Ethylbenzene, and Xylenes C/PC Closure/Post-Closure:
C/PC refers to two independent steps following completion of facility operations:
Closure typically refers to regrading the surface and repositioning of infrastructure to accommodate the post-closure.
Post-closure care refers to maintenance and monitoring after completion of closure.
CQA Construction Quality Assurance:
CQA is the process of applying field and laboratory testing, and construction observation to confirm that environmental control systems (e.g., liners and covers) are installed according to the design, regulatory requirements, and current industry standards.
FEMA Federal Emergency Management Agency, which administers the Flood Insurance Rate Map (FIRM) program.
FML Flexible Membrane Liner (or geomembrane):
Geosynthetic plastic liners are the standard design for the primary (upper) containment layer of the composite liner system, which in a RCRA Subtitle D (solid waste) Landfill is underlain by a compacted clay liner (CCL) or a geosynthetic clay liner (GCL).
GCL Geosynthetic Clay Liner:
These are composite materials with geotextiles (fabrics) used in conjunction with dense bentonite clays, and are commonly used as the secondary lower liner in the landfill liner system.
HDPE High Density Polyethylene:
This geomembrane (plastic) is the preferred material for FML landfill liners, and is typically installed in 60 - 100 mil thicknesses. HDPE is also used for leachate collection system piping and landfill gas management systems.
H2S Hydrogen Sulfide LEL Lower Explosive Limit is the lowest percent by volume of a mixture of explosive gases in air that will propagate a flame at 77 degrees Fahrenheit and atmospheric pressure.
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LFG Landfill Gas:
Decomposing organic wastes in landfill environments typically produce LFG, which in MSW landfills is comprised of approximately 50% methane (CH4) and 50% carbon dioxide (CO2), both of which are odorless and colorless. C & D produce less gas, and at a slower rate, than other MSW waste streams (i.e., residential).
mcf Thousand Cubic Feet mg/l Milligrams Per Liter MSW Municipal Solid Waste:
Municipal Solid Waste is an industry term that includes residential, commercial, and some industrial wastes; and specifically excludes defined hazardous, radioactive, and infectious wastes. C & D is considered part of the MSW stream, and recyclables are subtracted if recovered.
NMAC New Mexico Administrative Code NMDOT New Mexico Department of Transportation:
The NMDOT is committed to providing safe and reliable transportation systems to the state of New Mexico. NMDOT also works closely with other state agencies on transportation related issues.
NMPM New Mexico Principal Meridian NOI Notice of Intent:
Application to USEPA for stormwater discharges associated with industrial activity under the NPDES program.
Notice of Inspection:
The written record of a compliance inspection by a regulatory agency.
NORM Naturally Occurring Radioactive Material NPDES National Pollutant Discharge Elimination System:
The federal permit program which requires all point sources discharging pollutants to waters of the United States to obtain a permit.
NRCS Natural Resources Conservation Service:
The federal agency with local offices that provide guidance on seeding of the final cover.
OCD Oil Conservation Division; a division of the New Mexico Energy, Minerals, and Natural Resources Department OSE Office of the State Engineer PE Professional Engineer PSL Protective Soil Layer:
All liners shall have a protective cover of at least two feet of granular soil. This protective cover shall, in addition to providing physical protection for the liner, facilitate the collection of leachate in the leachate collection system.
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PVC Polyvinyl Chloride RAI Request for Additional Information; typically issued by a regulatory agency to an Applicant in response to an Application.
RCRA Resource Conservation and Recovery Act; the program administered by USEPA that sets national standards for solid waste management and disposal.
SWPPP Stormwater Pollution Prevention Plan:
Sites subject to the federal National Pollutant Discharge Elimination System (NPDES) regulations must prepare and implement a SWPPP. The Plan identifies potential pollutant sources and plans to mitigate/eliminate these sources.
TDS Total Dissolved Solids; a measure of water quality TPH Total Petroleum Hydrocarbons USEPA United States Environmental Protection Agency:
The federal entity responsible for administering the RCRA program. USEPA also sets national standards for air quality (NSPS) and stormwater quality (NPDES) protection.
USGS United State Geological Survey
µm Micrometers UV Ultra-violet light; one component of sunlight WQCC Water Quality Control Commission (NMWQCC); responsible for the protection of groundwater and surface water in New Mexico.
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I-13 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx 19.15.36.8 SURFACE WASTE MANAGEMENT FACILITY PERMITS AND APPLICATION REQUIREMENTS:
A.
Permit required. No person shall operate a surface waste management facility (other than a small landfarm registered pursuant to Paragraph (1) of Subsection A of 19.15.36.16 NMAC) except pursuant to and in accordance with the terms and conditions of a division-issued surface waste management facility permit.
Sundance West proposes to operate a new Surface Waste Management Facility, pursuant to and in accordance with the terms and conditions of a Surface Waste Management Facility Permit issued by the Oil Conservation Division (OCD) of the New Mexico Energy, Minerals and Natural Resources Department.
B.
Permitting requirements. Except for small landfarms registered pursuant to Paragraph (1) of Subsection A of 19.15.36.16 NMAC, new commercial or centralized facilities prior to commencement of construction, and existing commercial or centralized facilities prior to modification or permit renewal, shall be permitted by the division in accordance with the applicable requirements of Subsection C of 19.15.36.8 NMAC and 19.15.36.11 NMAC.
Sundance West is requesting a new commercial Surface Waste Management Facility Permit in accordance with the applicable requirements of 19.15.36.8.C NMAC and 19.15.36.11 NMAC. The purpose of this Application is to detail the Facility design, capacity, and operational practices in accordance with the Rules. For ease of regulatory review, this Application provides the information required in applicable sections of 19.15.36 NMAC as delineated in this Volume.
C.
Application requirements for new facilities, major modifications and permit renewals. An applicant or operator shall file an application, form C-137, for a permit for a new surface waste management facility, to modify an existing surface waste management facility or for permit renewal with the environmental bureau in the divisions Santa Fe office. The application shall include:
(1) the names and addresses of the applicant and principal officers and owners of 25 percent or more of the applicant; The purpose of this Application is to request a Permit for a new surface waste management facility, and to document Facility design, capacity, and proposed operational activities. The completed form C-137, provided for informational purposes, is located as the preface to this Volume. The names and addresses of the Applicant and principal officers and owners of 25 percent or more of the Applicant are listed on C-137.
I-14 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx (2) a plat and topographic map showing the surface waste management facilitys location in relation to governmental surveys (quarter-quarter section, township and range); highways or roads giving access to the surface waste management facility site; watercourses; fresh water sources, including wells and springs; and inhabited buildings within one mile of the sites perimeter; A Site Location Map that shows the Sundance West Facility plotted on the most current United States Geological Survey (USGS) Quadrangle map is provided as Figure I.1. The Site Location Map shows the Facility and the surrounding area, and Figure I.3 is a detailed Site Topograph. A more detailed discussion of site characteristics and land use is provided in Volume IV.1 (Siting Criteria). A Partial Assignment and Assumption of Lease for the Sundance West site is provided as Attachment I.A. Facility access is provided from NM-18 to Wallach Lane through an intersection that includes turning, acceleration and deceleration lanes.
(3) the names and addresses of the surface owners of the real property on which the surface waste management facility is sited and surface owners of the real property within one mile of the sites perimeter; The owner of the real property on which the Surface Waste Management Facility is sited is:
Wallach Ranch, LLC PO Box 3175 Midland, TX 79702 Sundance West, Inc. has been assigned a long-term lease that allows for their use of this property as a Surface Waste Management Facility. Attachment I.B (Public Notification) includes a list of the names and addresses of real surface owners of the real property within one mile of the sites perimeter based on the data available from the Lea County Assessors Office.
(4) a description of the surface waste management facility with a diagram indicating the location of fences and cattle guards, and detailed construction/installation diagrams of pits, liners, dikes, piping, sprayers, tanks, roads, fences, gates, berms, pipelines crossing the surface waste management facility, buildings and chemical storage areas;
I-16 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx Volume III.1 (Engineering Design) includes a set of Permit Plans which are listed on Table I.5. The Permit Plans (Volume III.1) indicates the location of roads, pipeline crossings, fences and gates. The Permit Plans (Volume III.1) provides construction and installation details on the landfill liner, and provides these details for the leachate collection system.
Layout details for the processing area, which includes the produced water loadout tank farm, ponds, tanks, jet out pit and stabilization/solidification area is depicted in the Permit Plans (Volume III.1); with additional details provided. The Permit Plans (Volume III.1) provide construction and installation details for the evaporation ponds including the mechanical evaporator locations.
(5) engineering designs, certified by a registered professional engineer, including technical data on the design elements of each applicable treatment, remediation and disposal method and detailed designs of surface impoundments; The Permit Plans included in Volume III.1 are provided at a reduced scale and establish the engineering design criteria for the Facility. The same drawings are submitted to the OCD with this Application as a full-size (24 x 36-inch) plan set. The List of Permit Plans is provided with the master Table of Contents and included as Table I.5. These Permit Plans, and the Certification Statement that prefaces this volume, have been signed and sealed by a Professional Engineer registered in the State of New Mexico. That engineer, who is a specialist in geotechnical engineering and waste containment design, is identified as follows:
I. Keith Gordon, P.E.
New Mexico Professional Engineer #10984 Principal, Gordon Environmental, Inc.
213 South Camino del Pueblo Bernalillo, NM 87004 (505) 867-6990 Phone (505) 867-6991 Fax (6) a plan for management of approved oil field wastes that complies with the applicable requirements contained in 19.15.36.13 NMAC, 19.15.36.14 NMAC, 19.15.36.15 NMAC and 19.15.36.17 NMAC;
I-17 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx The Oil Field Waste Management Plan included as Volume II.2 provides the applicable information required in 19.15.36.13.A through H, 19.15.36.14, 19.15.35.15, and 19.15.36.17 NMAC.
(7) an inspection and maintenance plan that complies with the requirements contained in Subsection L of 19.15.36.13 NMAC; The Operations, Inspection, and Maintenance Plan included as Volume II.1 provides the applicable information required in 19.15.36.13.L.(1) and (3).
(8) a hydrogen sulfide prevention and contingency plan that complies with those provisions of 19.15.11 NMAC that apply to surface waste management facilities; The Hydrogen Sulfide Prevention and Contingency Plan included as Volume II.3 provides information to ensure that the regulatory thresholds in 19.15.11 NMAC are not exceeded. In addition, the Contingency Plan provided as Volume II.5 addresses the requirements of 19.15.36.13.N NMAC concerning contingencies to minimize hazards to fresh water, public health, safety or the environment.
(9) a closure and post closure plan, including a responsible third party contractors cost estimate, sufficient to close the surface waste management facility in a manner that will protect fresh water, public health, safety and the environment (the closure and post closure plan shall comply with the requirements contained in Subsection D of 19.15.36.18 NMAC);
The Closure/Post-closure (C/PC) Plan is provided as Volume II.4. The C/PC Plan addresses the information required in this section as well as 19.15.36.18.D NMAC; and provides the estimated third-party C/PC cost estimate (Attachment II.4.A) to address the requirements in this section.
(10) a contingency plan that complies with the requirements of Subsection N of 19.15.36.13 NMAC and with NMSA 1978, Sections 12-12-1 through 12 30, as amended; A Contingency Plan written in compliance with 19.15.36.13.N NMAC and the NMSA 1978 as referenced, is provided as Volume II.5.
I-18 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx (11) a plan to control run-on water onto the site and run-off water from the site that complies with the requirements of Subsection M of 19.15.36.13 NMAC; Volume III.1 provides the design for berms, conveyance channels, and detention ponds to control run-on/run-off during the peak discharge from a 25-year, 24-hour storm; and Volume III.3 provides the supporting calculations. The Sundance West Facility may be required to obtain a permit under the Multi-Sector General Permit for Stormwater Discharges promulgated June 4, 2015, and the Applicant will consult with the NMED Surface Water Quality Bureau for compliance requirements. Sundance West through adherence to the Operations, Inspection, and Maintenance Plan (Volume II.1) and construction of the detention structures described in this Application (Volume III.1), will prevent discharge of pollutants to the waters of the State or United States in violation of state water quality standards.
(12) in the case of an application to permit a new or expanded landfill, a leachate management plan that describes the anticipated amount of leachate that will be generated and the leachates handling, storage, treatment and disposal, including final post closure options; The Leachate Management Plan included as Volume II.9 provides details including the anticipated volume of leachate that will be generated; and the leachate handling, storage, treatment and disposal technologies that will be employed during operations and final post-closure management options. Leachate management details are also described in Volume II.1 as well as the Permit Plans.
(13) in the case of an application to permit a new or expanded landfill, a gas safety management plan that complies with the requirements of Subsection O of 19.15.36.13 NMAC; In compliance with 19.15.36.13.O NMAC, landfill gas safety management is addressed in Section 6.6 of Volume II.1. The Hydrogen Sulfide (H2S) Prevention and Contingency Plan is provided as Volume II.3.
(14) a best management practice plan to ensure protection of fresh water, public health, safety and the environment;
I-19 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx Best management practices to ensure the protection of fresh water, public health, safety, and the environment, are described in detail in the Operations, Inspection, and Maintenance Plan (Volume II.1) as well as on the Permit Plans.
(15) geological/hydrological data including:
The Sundance West site is located in a hydrogeologic setting that is ideally selected for waste processing and disposal. This same locale was selected for Subtitle C (Waste Control Specialists) and Subtitle D (Lea County Landfill) disposal facilities, as well as the Nuclear Regulatory Commission-approved Louisiana Energy Services National Enrichment Facility.
Regional and site-specific hydrogeologic data are presented in Volume IV.2 (Hydrogeology).
Additional site-specific hydrogeologic information is provided in a report and supplements by Gordon Environmental, Inc. (GEI) in Attachments IV.2.A and IV.2.B.
(a) a map showing names and location of streams, springs or other watercourses, and water wells within one mile of the site; The USGS Quadrangle Map provided as Figure I.1 identifies streams, springs, and watercourses with the vicinity of the Sundance West Facility. There are no defined watercourses, streams or springs within 1/2 mile of the proposed facility. In addition, wells within the vicinity are identified on the Water Well Location Map provided as Figure IV.2.5.
This map is based on data from the NM Office of the State Engineer. There are five wells identified within one mile of the proposed site: one domestic water supply well and four other use wells. Additional detail is provided in Volume IV.2 (Hydrogeology).
(b) laboratory analyses, performed by an independent commercial laboratory, for major cations and anions; BTEX; RCRA metals; and TDS of ground water samples of the shallowest fresh water aquifer beneath the proposed site; Although the shallow water encountered in well MP-4P (re-named monitoring well VZ-4 as described in Volume II.8), installed during the April 2009 drilling program, is not within the shallowest fresh water aquifer beneath the site, Attachment IV.2.D includes the laboratory report for analysis of the water samples collected from well MP-4P. No groundwater was encountered in any of the borings or core holes drilled during the October 2009 drilling
I-20 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx program. More detailed data on local groundwater resources are provided in Volume IV.2 (Hydrogeology).
(c) depth to, formation name, type and thickness of the shallowest fresh water aquifer; The Santa Rosa Sandstone (Lower Dockum Group) is considered to be the shallowest fresh water aquifer in the vicinity of the Sundance West site at a minimum depth of approximately 675 ft +/- below grade. A detailed description of this aquifer, including potentiometric surface, depth and thickness, is provided in Volume IV.2.
(d) soil types beneath the proposed surface waste management facility, including a lithologic description of soil and rock members from ground surface down to the top of the shallowest fresh water aquifer; A summary of the soil data obtained during GEIs site investigations is provided in Table IV.2.2. This table summarizes the standard engineering index properties (i.e., USCS soil classification; grain size distribution; natural dry density, Atterberg limits; and gravimetric moisture content) for selected soil samples obtained during the drilling program at Sundance West. Table IV.2.2 also summarizes lab test results for Standard Proctor density and permeability. The soils laboratory testing was conducted in accordance with guidance provided by OCD. The site geology is described in detail in Volume IV.2 including lithologic descriptions of the soil borings installed at the site.
(e) geologic cross-sections; Geologic cross-sections of the site are provided as Figures IV.2.8, including a site map identifying the locations of the geological cross-section (Figure IV.2.7). These cross-sections are discussed in Volume IV.2.
(f) potentiometric maps for the shallowest fresh water aquifer; and The precise potentiometric groundwater surface data for the Santa Rosa Sandstone is not well-defined in the immediate vicinity of the Facility. The Lower Dockum Group potentiometric surface contours (Figure IV.2.13) likely represent the minimum possible depth of water
I-21 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx bearing units of the Santa Rosa Formation (Upper Dockum Group), and not necessarily the Santa Rosa Sandstone. The geometry of land surface and underlying geologic units, as well as groundwater saturations in the vicinity of the Sundance West site are depicted in the hydrogeologic cross-section shown on Figure IV.2.8. This diagram indicates that no shallow alluvial groundwater is present at the Sundance West site, consistent with site-specific drilling results. Based upon information projected from nearby petroleum wells, the shallowest potential water-bearing zone is the Santa Rosa Sandstone (Lower Dockum Group; Figure IV.2.11), which is approximately 675 ft +/- below grade at the Sundance West site.
(g) porosity, permeability, conductivity, compaction ratios and swelling characteristics for the sediments on which the contaminated soils will be placed; A detailed description of porosity, permeability, conductivity, compaction ratios, and swelling characteristics is provided in Volume IV.2. The calculated porosities and permeabilities are summarized in Table IV.2.2. Table IV.2.2 also summarizes the standard proctor densities and optimum moistures; and summarizes the swell/collapse characteristics of the onsite soils.
(16) certification by the applicant that information submitted in the application is true, accurate and complete to the best of the applicants knowledge, after reasonable inquiry; and The certification is located in the preface to this Volume of the Application (i.e., Form C-137).
(17) other information that the division may require to demonstrate that the surface waste management facilitys operation will not adversely impact fresh water, public health, safety or the environment and that the surface waste management facility will comply with division rules and orders.
Sundance West will provide other applicable information reasonably requested by the OCD in order to demonstrate that the surface waste management facilitys operation will not adversely impact fresh water, public health, safety or the environment. In addition, Sundance West will comply with applicable Rules and Orders issued by OCD.
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Application requirements for minor modifications. An existing surface waste management facility applying for a minor modification shall file a form C-137 with the environmental bureau in the divisions Santa Fe office describing the proposed change and identifying information that has changed from its last C-137 filing.
At this time, Sundance West is not seeking a minor modification. Sundance West will comply with this requirement when applicable.
E.
Determination that an application is administratively complete. Upon receipt of an application for a surface waste management facility permit or modification or renewal of an existing surface waste management facility permit, the division shall review the application for administrative completeness. To be deemed administratively complete, the application shall provide information required by Subsection C or D (as applicable) of 19.15.36.8 NMAC. The division shall notify the applicant in writing when it deems the application administratively complete.
If the division determines that the application is not administratively complete, the division shall notify the applicant of the deficiencies in writing within 30 days after the applications receipt and state what additional information is necessary.
No response required.
19.15.36.9 NOTICE REQUIREMENTS FOR NEW SURFACE WASTE MANAGEMENT FACILITIES, MAJOR MODIFICATIONS OR RENEWALS AND ISSUANCE OF A TENTATIVE DECISION:
A.
Upon receipt of notification of the divisions determination that the application is administratively complete, the applicant for a new surface waste management facility permit, permit renewal or major modification shall give written notice of the application, by certified mail, return receipt requested, to the surface owners of record within one-half mile of the surface waste management facility, the county commission of the county where the surface waste management facility site is located, the appropriate city officials if the surface waste management facility site is within city limits or within one-half mile of the city limits, and affected federal, tribal or pueblo governmental agencies. The notice shall contain the information in Paragraphs (1) through (4) of Subsection F of 19.15.36.9 NMAC.
The division may extend the distance requirements for notice if the division determines that the proposed surface waste management facility has the potential to adversely impact fresh water, public health, safety or the environment at a distance greater than one-half mile. The applicant shall furnish proof that it has given the required notices.
I-23 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx Draft Public Notification language is provided in Attachment I.B. The Draft Public Notification was prepared in accordance with 19.15.36.9.F(1) through (4) NMAC. Following OCD approval, Public Notification will be provided in compliance with 19.15.36.9.A NMAC, to the surface owners of record located within one-half mile of the Facility. Owners of record, as determined by the Lea County Assessors Office, are listed in Attachment I.B, and include the State Land Office (SLO) and Bureau of Land Management (BLM). Additionally, the Public Notification will be provided to the Lea County Commission. The Facility is not located within one-half mile of any city limit and therefore no additional federal, tribal or pueblo governmental agencies are affected.
B.
The division shall distribute notice of its determination that an application for a new surface waste management facility or for a renewal or major modification of an existing surface waste management facility is administratively complete to persons who have requested notification of division and commission hearing dockets within 30 days following the date that the division determines the application to be administratively complete.
No response required.
C.
A person wishing to comment on an application prior to the divisions preliminary consideration of the application may file comments within 30 days, or as extended by the director, after the later of the date when the applicant mails the notice required by Subsection A of 19.15.36.9 NMAC or the date when the division distributes the notice provided in Subsection B of 19.5.36.9 NMAC.
No response required.
D.
Within 60 days after the end of the public comment period provided in Subsection C of 19.15.36.9 NMAC, the division shall issue a tentative decision concerning the application, renewal or modification, including proposed conditions for approval or reasons for disapproval, as applicable. The division shall mail notice of the tentative decision, together with a copy of the decision, by certified mail, return receipt requested, to the applicant and shall post notice on the divisions website, together with a copy of the tentative decision.
No response required.
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Within 30 days after receiving the divisions tentative decision, the applicant shall provide notice of the tentative decision by:
(1) publishing a display ad in English and Spanish, in a form approved by the division, in a newspaper of general circulation in this state and in a newspaper of general circulation in the county where the surface waste management facility is or will be located; the display ad shall be at least three inches by four inches and shall not be published in the newspapers legal or classified sections; (2) mailing notice by first class mail or e-mail to persons, as identified to the applicant by the division, who have requested notification of applications generally, or of the particular application, including persons who have filed comments on the particular application during the initial public comment period, and who have included in such comments a legible return address or e-mail address; and (3) mailing notice by first class or e-mail to affected local, state, federal or tribal governmental agencies, as determined and identified to the applicant by the division.
Sundance West will comply with the notification requirements identified in 19.15.39.9.E NMAC. It is proposed that the display ad be published in the Albuquerque Journal and the Hobbs News-Sun, both of which are newspapers in general circulation in the State of New Mexico and Lea County.
F.
This notice issued pursuant to Subsection E of 19.15.36.9 NMAC shall include:
(1) the applicants name and address; (2) the surface waste management facilitys location, including a street address if available, and sufficient information to locate the surface waste management facility with reference to surrounding roads and landmarks; (3) a brief description of the proposed surface waste management facility; (4) the depth to, and TDS concentration of, the ground water in the shallowest aquifer beneath the surface waste management facility site; (5) a statement that the divisions tentative decision is available on the divisions website, or, upon request, from the division clerk, including the division clerks name, address and telephone number; (6) a description of alternatives, exceptions or waivers that may be under consideration in accordance with Subsection G of 19.15.36.18 NMAC or 19.15.36.19 NMAC; (7) a statement of the comment period and of the procedures for requesting a hearing on the application; and (8) a brief statement of the procedures the division shall follow in making a final decision.
Sundance West will, upon receiving OCDs Tentative Decision, issue Public Notification of Tentative Decision in compliance with this section.
I-25 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx 19.15.36.10 COMMENTS AND HEARING ON APPLICATION:
A.
A person, whether or not such person has previously submitted comments, may file comments or request a hearing on the application by filing their comments or, in accordance with 19.15.4.9 NMAC, a hearing request with the division clerk within 30 days after the date that the applicant issued public notice of the divisions tentative decision. A request for a hearing shall be in writing and shall state specifically the reasons why a hearing should be held. The division shall schedule a public hearing on the application if, in addition to the requirements in 19.15.4.9 NMAC:
(1) the division has proposed to deny the application or grant it subject to conditions not expressly required by rule, and the applicant requests a hearing; (2) the director determines that there is significant public interest in the application; (3) the director determines that comments have raised objections that have probable technical merit; or (4) determination of the application requires that the division make a finding, pursuant to Paragraph (3) of Subsection F of 19.15.2.7 NMAC, whether a water source has a present or reasonably foreseeable beneficial use that contamination would impair.
B.
If the division schedules a hearing on an application, the hearing shall be conducted according to 19.15.14.1206 through 19.15.14.1215 NMAC.
No response required.
19.15.36.11 FINANCIAL ASSURANCE REQUIREMENTS:
A.
Centralized facilities. Upon notification by the division that it has approved a permit but prior to the division issuing the permit, an applicant for a new centralized facility permit shall submit acceptable financial assurance in the amount of $25,000 per centralized facility, or a statewide blanket financial assurance in the amount of $50,000 to cover all of that applicants centralized facilities, unless such applicant has previously posted a blanket financial assurance for centralized facilities.
No response required, as Sundance West is a proposed Commercial Facility per 19.15.36.7.A(2) NMAC.
B.
New commercial facilities or major modifications of existing commercial facilities.
Upon notification by the division that it has approved a permit for a new commercial facility or a major modification of an existing commercial facility but prior to the division issuing the permit, the applicant shall submit acceptable
I-26 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx financial assurance in the amount of the commercial facilitys estimated closure and post closure cost, or $25,000, whichever is greater. The commercial facilitys estimated closure and post closure cost shall be the amount provided in the closure plan the applicant submitted unless the division determines that such estimate does not reflect a reasonable and probable closure and post closure cost, in which event, the division shall determine the estimated closure and post closure cost and shall include such determination in its tentative decision. If the applicant disagrees with the divisions determination of estimated closure and post closure cost, the applicant may request a hearing as provided in 19.15.36.10 NMAC. If the applicant so requests, and no other person files a request for a hearing regarding the application, the hearing shall be limited to determination of estimated closure and post closure cost.
Once OCD has approved the Sundance West Application for Permit, Sundance West will submit financial assurance for $1,048,611, as detailed in the C/PC Cost Estimate Tables provided as Attachment II.4.A. The C/PC Cost Estimate will be reviewed prior to issuance of the Permit, and also prior to each new Phase of site development (see Table I.4). This amount represents the closure costs and post closure care requirements that will be required for Phase I of the development. This estimate will be revised upon review and approval of the Engineers C/PC Cost Estimate prior to issuance of the new permit, and as each Phase of the development is conducted.
C.
Terms of financial assurance. The financial assurance shall be on division-prescribed forms, payable to the state of New Mexico and conditioned upon the surface waste management facilitys proper operation, site closure and post closure monitoring in compliance with state of New Mexico statutes, division rules and the surface waste management facility permit terms. The applicant shall notify the division of a material change affecting the financial assurance within 30 days of discovery of such change.
Sundance West will comply with this requirement.
D.
Forfeiture of financial assurance. The division shall give the operator 20 days notice and an opportunity for a hearing prior to forfeiting financial assurance.
No response required.
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Forms of financial assurance. The division may accept the following forms of financial assurance.
(1)
Surety bonds. A surety bond shall be executed by the applicant and by a corporate surety licensed to do business in the state, and shall be non-cancelable.
(2)
Letters of credit. A letter of credit shall be issued by a bank organized or authorized to do commercial banking business in the United States, shall be irrevocable for a term of not less than five years and shall provide for automatic renewal for successive, like terms upon expiration, unless the issuer has notified the division in writing of non-renewal at least 90 days before its expiration date. The letter of credit shall be payable to the state of New Mexico in part or in full upon receipt from the director or the directors authorized representative of demand for payment accompanied by a notice of forfeiture.
(3)
Cash accounts. An applicant may provide financial assurance in the form of a federally insured or equivalently protected cash account or accounts in a financial institution, provided that the operator and the financial institution shall execute as to each such account a collateral assignment of the account to the division, which shall provide that only the division may authorize withdrawals from the account. In the event of forfeiture pursuant to Subsection C of 19.15.36.18 NMAC, the division may, at any time and from time to time, direct payment of all or part of the balance of such account (excluding interest accrued on the account) to itself or its designee for the surface waste management facilitys closure.
Once the Permit is approved and prior to issuance, Sundance West will elect a financial assurance mechanism pursuant to 19.15.36.11.E NMAC. Documentation will be included in Attachment I.C once OCD approves the Application for Permit. The amount of the mechanism will represent the closure costs and post-closure care requirements that will be required for Phase I of the development, as identified in the C/PC Cost Estimate Summary provided as Attachment II.4.A. The C/PC Cost Estimate will be reviewed prior to issuance of the Permit, and also prior to each new Phase of site development (see Table I.4).
F.
Replacement of financial assurance.
(1)
The division may allow an operator to replace existing forms of financial assurance with other forms of financial assurance that provide equivalent coverage.
(2)
The division shall not release existing financial assurance until the operator has submitted, and the division has approved, an acceptable replacement.
Sundance West will comply with this requirement.
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Review of adequacy of financial assurance. The division may at any time not less than five years after initial acceptance of financial assurance for a commercial facility, or whenever the operator applies for a major modification of the commercial facilitys permit, initiate a review of such financial assurances adequacy. Additionally, whenever the division determines that a landfarm operator has not achieved the closure standards specified in Paragraph (3) of Subsection G of 19.15.36.15 NMAC, the division may review the adequacy of the landfarm operators financial assurance, without regard to the date of its last review. Upon determination, after notice to the operator and an opportunity for a hearing, that the financial assurance is not adequate to cover the reasonable and probable cost of a commercial facilitys closure and post closure monitoring, the division may require the operator to furnish additional financial assurance sufficient to cover such reasonable and probable cost, provided that the financial assurance required of a commercial facility permitted prior to the effective date of 19.15.36 NMAC shall not exceed $250,000 except in the event of a major modification of the commercial facility. If such a commercial facility applies for a major modification, the division shall determine the applicable financial assurance requirement based on the total estimated closure and post closure cost of the commercial facility as modified, without regard to the $250,000 limit.
Sundance West will comply with this requirement.
19.15.36.12 PERMIT APPROVAL, DENIAL, REVOCATION, SUSPENSION, MODIFICATION OR TRANSFER:
A.
Granting of permit.
(1)
The division may issue a permit for an new surface waste management facility or major modification upon finding that an acceptable application has been filed, that the conditions of 19.15.36.9 NMAC and 19.15.36.11 NMAC have been met and that the surface waste management facility or modification can be constructed and operated in compliance with applicable statutes and rules and without endangering fresh water, public health, safety or the environment.
Sundance West will comply with the public notice requirements of 19.15.36.9 NMAC and the financial assurance requirements of 19.15.36.11 NMAC, as necessary to achieve Permit approval. Attachment I.B includes the current list of property owners within one-half mile of the Facility, which will be updated prior to formal notice. Following OCD review and approval of the Application, Sundance West will distribute the public notice in accordance with 19.15.36.9 NMAC. Attachment I.C provides the proposed C/PC Cost Estimate that will be the basis for the financial assurance mechanism to be put into place in accordance with 19.15.36.11 NMAC upon approval of the Permit. This Application provides the required plans
I-29 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx and engineering calculations to construct and operate the Facility in compliance with applicable statutes and Rules that ensure fresh water, public health, safety, or the environment will be protected.
(2)
Each permit the division issues for a new surface waste management facility shall remain in effect for 10 years from the date of its issuance. If the division grants a permit for a major modification of a surface waste management facility, the permit for that surface waste management facility shall remain in effect for 10 years from the date the division approves the major modification.
This Application requests a Permit in accordance with 19.15.36.8 NMAC. A new Application for Permit Renewal will be submittal to OCD at least 120 days prior to the expiration of the Permit granted in response to this Application (i.e., 10 years).
(a)
A surface waste management facility permit may be renewed for successive 10-year terms. If the holder of a surface waste management facility permit submits an application for permit renewal at least 120 days before the surface waste management facility permit expires, and the operator is not in violation of the surface waste management facility permit on the date of its expiration, then the existing surface waste management facility permit for the same activity shall not expire until the division has approved or denied an application for renewal. If the division has not notified the operator of a violation, if the operator is diligently pursuing procedures to contest a violation or if the operator and the division have signed an agreed compliance order providing for remedying the violation, then the surface waste management facility permit shall continue in effect as above provided notwithstanding the surface waste management facility permit violations existence. A surface waste management facility permit continued under this provision remains fully effective and enforceable.
This Application requests a Permit in accordance with 19.15.36.8 NMAC.
(b)
An application for permit renewal shall include and adequately address the information necessary for evaluation of a new surface waste management facility permit as provided in Subsection C of 19.15.36.8 NMAC. Previously submitted materials may be included by reference provided they are current, readily available to the division and sufficiently identified so that the division may retrieve them.
I-30 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx This Application requests a Permit in accordance with 19.15.36.8 NMAC.
(c)
The operator shall give public notice of the renewal application in the manner prescribed by 19.15.36.9 NMAC. The division shall grant an application for renewal if the division finds that an acceptable application has been filed, that the conditions of 19.15.36.9 NMAC and 19.15.36.11 NMAC have been met and that the surface waste management facility can be operated in compliance with applicable statutes and rules and without endangering fresh water, public health, safety or the environment.
Sundance West will continue to comply with the public notice requirements of 19.15.36.9 NMAC and the financial assurance requirements of 19.15.36.11 NMAC, as necessary to achieve Permit renewal. This Application provides the required plans and engineering calculations to construct and operate the Facility in compliance with applicable statutes and Rules that ensure fresh water, public health, safety, and the environment will be protected.
(3)
The division shall review each surface waste management facility permit at least once during the 10-year term, and shall review surface waste management facility permits to which Paragraph (2) of Subsection A of 19.15.36.12 NMAC does not apply at least every five years. The review shall address the operation, compliance history, financial assurance and technical requirements for the surface waste management facility. The division, after notice to the operator and an opportunity for a hearing, may require appropriate modifications of the surface waste management facility permit, including modifications necessary to make the surface waste management facility permit terms and conditions consistent with statutes, rules or judicial decisions.
Sundance West will make available all necessary operational, compliance, financial assurance and other technical documents to OCD at any time during the 10 year permit period for the completion of a mid-term review. Sundance West will respond to OCD requests for updates to address changes in regulatory standards.
B.
Denial of permit. The division may deny an application for a surface waste management facility permit or modification of a surface waste management facility permit if it finds that the proposed surface waste management facility or modification may be detrimental to fresh water, public health, safety or the environment. The division may also deny an application for a surface waste
I-31 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx management facility permit if the applicant, an owner of 25 percent or greater interest in the applicant or an affiliate of the applicant has a history of failure to comply with division rules and orders or state or federal environmental laws; is subject to a division or commission order, issued after notice and hearing, finding such entity to be in violation of an order requiring corrective action; or has a penalty assessment for violation of division or commission rules or orders that is unpaid more than 70 days after issuance of the order assessing the penalty. An affiliate of an applicant, for purposes of Subsection B of 19.15.36.12 NMAC, shall be a person who controls, is controlled by or under is common control with the applicant or a 25 percent or greater owner of the applicant.
No response required.
C.
Additional requirements. The division may impose conditions or requirements, in addition to the operational requirements set forth in 19.15.36 NMAC, that it determines are necessary and proper for the protection of fresh water, public health, safety or the environment. The division shall incorporate such additional conditions or requirements into the surface waste management facility permit.
Sundance West will comply with any additional requirements or conditions imposed by OCD intended to protect fresh water, public health, safety or the environment, and comply with any applicable permit conditions.
D.
Revocation, suspension or modification of a permit. The division may revoke, suspend or impose additional operating conditions or limitations on a surface waste management facility permit at any time, for good cause, after notice to the operator and an opportunity for a hearing. The division may suspend a surface waste management facility permit or impose additional conditions or limitations in an emergency to forestall an imminent threat to fresh water, public health, safety or the environment, subject to the provisions of NMSA 1978, Section 70 23, as amended. If the division initiates a major modification it shall provide notice in accordance with 19.15.36.9 NMAC. Suspension of a surface waste management facility permit may be for a fixed period of time or until the operator remedies the violation or potential violation. If the division suspends a surface waste management facilitys permit, the surface waste management facility shall not accept oil field waste during the suspension period.
No response required.
E.
Transfer of a permit. The operator shall not transfer a permit without the divisions prior written approval. A request for transfer of a permit shall identify officers, directors and owners of 25 percent or greater in the transferee. Unless the director otherwise orders, public notice or hearing are not required for the transfer requests approval. If the division denies the transfer request, it shall
I-32 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx notify the operator and the proposed transferee of the denial by certified mail, return receipt requested, and either the operator or the proposed transferee may request a hearing with 10 days after receipt of the notice. Until the division approves the transfer and the required financial assurance is in place, the division shall not release the transferors financial assurance.
Sundance West will comply with this requirement.
19.15.36.13 SITING AND OPERATIONAL REQUIREMENTS APPLICABLE TO ALL PERMITTED SURFACE WASTE MANAGEMENT FACILITIES:
EXCEPT AS OTHERWISE PROVIDED IN 19.15.36 NMAC.
Siting documentation is detailed in Volume IV.1 to demonstrate that the operation of the Facility will protect public health and the environment. This section confirms the remote location, absence of any residential housing within over one mile of the Facility boundary, absence of churches, schools, parks or other unrelated business in the area. With the location of the National Enrichment Facility as the neighbor to the south, and the WCS hazardous waste processing and disposal facility to the east, open pasture and oil field production facilities surrounding the Sundance West Facility, the location is ideally suited for development as a surface waste management facility.
A.
Depth to ground water.
(1)
No landfill shall be located where ground water is less than 100 feet below the lowest elevation of the design depth at which the operator will place oil field waste.
Groundwater is demonstrated to be more than 100 ft below the lowest elevation of the design depth of the landfill where oil field waste will be placed. Additional detail is provided in Volume IV.1 (Siting) and in Volume IV.2 (Hydrogeology).
(2)
No landfarm that accepts soil or drill cuttings with a chloride concentration that exceeds 500 mg/kg shall be located where ground water is less than 100 feet below the lowest elevation at which the operator will place oil field waste. See Subsection A of 19.15.36.15 NMAC for oil field waste acceptance criteria.
Not Applicable. Sundance West does not propose to operate a landfarm permitted under 19.15.36.15 NMAC.
I-33 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx (3)
No landfarm that accepts soil or drill cuttings with a chloride concentration that is 500 mg/kg or less shall be located where ground water is less than 50 feet below the lowest elevation at which the operator will place oil field waste.
Not Applicable. Sundance West does not propose to operate a landfarm permitted under 19.15.36.15 NMAC.
(4)
No small landfarm shall be located where ground water is less than 50 feet below the lowest elevation at which the operator will place oil field waste.
Not Applicable.
(5)
No other surface waste management facility shall be located where ground water is less than 50 feet below the lowest elevation at which the operator will place oil field waste.
Groundwater is not located less than 50 ft below the lowest elevation of the processing area where oil field waste will be placed. Additional detail is provided in Volume IV.1 (Siting) and in Volume IV.2 (Hydrogeology). The closest water-bearing zone is over 675 ft +/- below ground surface.
B.
No surface waste management facility shall be located:
(1) within 200 feet of a watercourse, lakebed, sinkhole or playa lake; The Facility is not located within 200 feet of a watercourse, lakebed, sinkhole or playa lake.
Documentation regarding the locations of watercourses, lakebeds, sinkholes and playa lakes with respect to the Sundance West site is provided in Volume IV.1.
(2) within an existing wellhead protection area or 100-year floodplain; The Facility is not located within an existing wellhead protection area or 100-year floodplain. Documentation regarding wellhead protection areas and 100-year floodplains is provided in Volume IV.1.
(3) within, or within 500 feet of, a wetland; The Facility is not located within 500 ft of a wetland. Documentation regarding wetlands in the vicinity of the Sundance West site is provided in Volume IV.1.
I-34 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx (4) within the area overlying a subsurface mine; The Facility is not located in an area overlying a known subsurface mine. Documentation of mines, mills, and quarries is provided in Volume IV.1.
(5) within 500 feet from the nearest permanent residence, school, hospital, institution or church in existence at the time of initial application; or The Facility is not located within 500 ft of the nearest permanent residence, school, hospital, institution, or church. Land use setback documentation is provided in Volume IV.1.
(6) within an unstable area, unless the operator demonstrates that engineering measures have been incorporated into the surface waste management facility design to ensure that the surface waste management facilitys integrity will not be compromised.
As documented in Volume IV.1, the Sundance West Facility is not located in an unstable area.
C.
No surface waste management facility shall exceed 500 acres.
The Sundance West Facility will not exceed 500 acres. Total acreage for the Sundance West site is 320 +/- acres. The Sundance West Facility will include two main components; a liquid oil field waste Processing Area (80 acres +/-), and an oil field waste Landfill (180 acres +/-);
therefore the Sundance West Facility comprises 320 acres +/-. A copy of the Partial Assignment and Assumption of Lease for the Sundance West site, which describes the size of the site and the site boundary is provided in Attachment I.A. Table I.1 provides details regarding site facilities and acreages.
D.
The operator shall not accept oil field wastes transported by motor vehicle at the surface waste management facility unless the transporter has a form C-133, authorization to move liquid waste, approved by the division.
Sundance West will comply with this requirement. The Oil Field Waste Management Plan provided as Volume II.2 requires that, prior to acceptance of any liquid waste, the transporter must provide the Facility with a Division-approved Form C-133.
I-35 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx E.
The operator shall not place oil field waste containing free liquids in a landfill or landfarm cell. The operator shall use the paint filter test, as prescribed by the EPA (EPA SW-846, method 9095) to determine conformance of the oil field waste to this criterion.
Sundance West will comply with this requirement. The Oil Field Waste Management Plan (Volume II.2) requires that, prior to acceptance of any oil field waste in the landfill portion of the Facility, the material will pass the paint filter test. Solidification, if necessary, will be accomplished in the lined stabilization and solidification area and described in Operation, Inspection, and Maintenance Plan (Volume II.1).
F.
Surface waste management facilities shall accept only exempt or non-hazardous waste, except as provided in Paragraph (3) of Subsection F of 19.15.36.13 NMAC.
The operator shall not accept hazardous waste at a surface waste management facility. The operator shall not accept wastes containing NORM at a surface waste management facility except as provided in 19.15.35 NMAC. The operator shall require the following documentation for accepting oil field wastes, and both the operator and the generator shall maintain and make the documentation available for division inspection.
Sundance West will comply with this requirement. The Oil Field Waste Management Plan (Volume II.2) provides a detailed description of oil field waste acceptance protocol. Included in this Plan are Form C-138 certification, and certification frequency. Sundance West will maintain and make documentation of this available for OCD inspection.
(1)
Exempt oil field wastes. The operator shall require a certification on form C-138, signed by the generator or the generators authorized agent, that represents and warrants that the oil field wastes are generated from oil and gas exploration and production operations, are exempt waste and are not mixed with non-exempt waste. The operator shall have the option to accept such certifications on a monthly, weekly or per load basis. The operator shall maintain and shall make the certificates available for the divisions inspection.
Sundance West will comply with this requirement. The Oil Field Waste Management Plan (Volume II.2) provides a detailed description of oil field waste acceptance protocol. Included in this Plan is the Form C-138 certification and additional documentation that the oil field waste is Resource Conservation and Recovery Act (RCRA) exempt.
I-36 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx (2)
Non-exempt, non-hazardous, oil field wastes. The operator shall require a form C-138, oil field waste document, signed by the generator or its authorized agent. This form shall be accompanied by acceptable documentation to determine that the oil field waste is nonhazardous.
Sundance West will comply with this requirement. The Oil Field Waste Management Plan (Volume II.2) provides a detailed description of oil field waste acceptance protocol. Included in this Plan is the Form C-138 certification and additional documentation that any non-exempt oil field waste is non-hazardous.
(3)
Emergency non-oil field wastes. The operator may accept non-hazardous, non-oil field wastes in an emergency if ordered by the department of public safety. The operator shall complete a form C-138, oil field waste document, describing the waste, and maintain the same, accompanied by the department of public safety order, subject to division inspection.
Sundance West will comply with this requirement.
G.
The operator of a commercial facility shall maintain records reflecting the generator, the location of origin, the location of disposal within the commercial facility, the volume and type of oil field waste, the date of disposal and the hauling company for each load or category of oil field waste accepted at the commercial facility. The operator shall maintain such records for a period of not less than five years after the commercial facilitys closure, subject to division inspection.
Sundance West will comply with this requirement. The Oil Field Waste Management Plan (Volume II.2) provides a detailed description of oil field waste acceptance recordkeeping forms.
The forms in this Plan include the information required in this subsection and will be maintained and retained for a period of not less than five years following Facility closure. Sundance West will make these records available for OCD inspection upon request.
H.
Disposal at a commercial facility shall occur only when an attendant is on duty unless loads can be monitored or otherwise isolated for inspection before disposal.
The surface waste management facility shall be secured to prevent unauthorized disposal.
Disposal operations at Sundance West will only be conducted when an attendant is on duty.
Sundance West may conduct Facility operations 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 7 days a week. The Facility will be secured with barbed wire fencing, and locking gates to prevent any unauthorized access or disposal when an attendant is not on duty. A truck with an acceptable load of oil field waste
I-37 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx that may arrive while the facility is closed may park in a designated area outside the fence until a qualified inspection can take place upon the arrival of an attendant. In this case, the temporarily parked load will be inspected for any leakage and will be required to have any valves or access ports secured and locked to prevent spillage or tampering.
I.
To protect migratory birds, tanks exceeding eight feet in diameter, and exposed pits and ponds shall be screened, netted or covered. Upon the operators written application, the division may grant an exception to screening, netting or covering upon the operators showing that an alternative method will protect migratory birds or that the surface waste management facility is not hazardous to migratory birds. Surface waste management facilities shall be fenced in a manner approved by the division.
Sundance West herein requests an exception to 19.15.36.13.I NMAC. The Migratory Bird Protection Plan presented as Volume II.6 describes an alternate methodology to the screening requirement of the storage ponds. This Plan describes visual inspections and migratory bird retrieval and clean-up procedures should bird(s) require decontamination. The Engineering Design (Volume III.1) provides a process design for produced waters and other liquids that will remove the oils present in these materials prior to discharge through the evaporation ponds.
J.
Surface waste management facilities shall have a sign, readable from a distance of 50 feet and containing the operators name; surface waste management facility permit or order number; surface waste management facility location by unit letter, section, township and range; and emergency telephone numbers.
The proposed Site Entrance Sign is provided as Figure I.4. The sign was designed in compliance with the requirements of 19.15.36.13.J NMAC. A 4-ft by 8-ft sign with 3-inch lettering will identify the Facility operator as Sundance West, Inc., and will include the Facility permit number, location and emergency phone numbers.
K.
The operators shall comply with the spill reporting and corrective action provisions of 19.15.30 NMAC or 19.15.29 NMAC.
I-39 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx The Sundance West Facility is specifically designed to prevent pollutants from entering surface and groundwater, as demonstrated through the Facility Management Plans (Volume II), and the Engineering Design and Calculations (Volume III) and the Permit Plans (Volume III.1) presented in this Application. Successful implementation of the engineering design and operational programs will ensure compliance with 19.15.30 NMAC. The Sundance West Contingency Plan (Volume II.5) is designed to comply with the notification and corrective action as required in 19.15.29 NMAC.
L.
Each operator shall have an inspection and maintenance plan that includes the following:
(1) monthly inspection of leak detection sumps including sampling if fluids are present with analyses of fluid samples furnished to the division; and maintenance of records of inspection dates, the inspector and the leak detection systems status; (2) semi-annual inspection and sampling of monitoring wells as required, with analyses of ground water furnished to the division; and maintenance of records of inspection dates, the inspector and ground water monitoring wells status; and (3) inspections of the berms and the outside walls of pond levees quarterly and after a major rainfall or windstorm, and maintenance of berms in such a manner as to prevent erosion.
The Operations, Inspection, and Maintenance Plan for the Sundance West Facility is provided as Volume II.1. The Plan describes in detail the methods and frequency for inspections, sampling, recordkeeping, and maintenance for the leak detection sumps, and containment berms.
M.
Each operator shall have a plan to control run-on water onto the site and run-off water from the site, such that:
(1) the run-on and run-off control system shall prevent flow onto the surface waste management facilitys active portion during the peak discharge from a 25-year storm; and (2) run-off from the surface waste management facilitys active portion shall not be allowed to discharge a pollutant to the waters of the state or United States that violates state water quality standards.
Volume III (Engineering Design and Calculations) provides the design for berms, conveyance channels, and detention capacity to control run-on/run-off for at least the peak discharge from a 25-year 24-hour storm. Sundance West will prevent discharge of pollutants to the waters of the State or United States in violation of state water quality standards through adherence to
I-40 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx the Operations, Inspection, and Maintenance Plan (Volume II.1), and construction of the detention ponds described in this Application. If required after consultation with New Mexico Environment Department (NMED), Sundance West will obtain a permit under the Multi-Sector General Permit for Stormwater Discharges (promulgated June 4, 2015).
N.
Contingency plan. Each operator shall have a contingency plan. The operator shall provide the divisions environmental bureau with a copy of an amendment to the contingency plan, including amendments required by Paragraph (8) of Subsection N of 19.15.36.13 NMAC; and promptly notify the divisions environmental bureau of changes in the emergency coordinator or in the emergency coordinators contact information. The contingency plan shall be designed to minimize hazards to fresh water, public health, safety or the environment from fires, explosions or an unplanned sudden or non-sudden release of contaminants or oil field waste to air, soil, surface water or ground water. The operator shall carry out the plans provisions immediately whenever there is a fire, explosion or release of contaminants or oil field waste constituents that could threaten fresh water, public health, safety or the environment; provided that the emergency coordinator may deviate from the plan as necessary in an emergency situation. The contingency plan for emergencies shall:
(1) describe the actions surface waste management facility personnel shall take in response to fires, explosions or releases to air, soil, surface water or ground water of contaminants or oil field waste containing constituents that could threaten fresh water, public health, safety or the environment; (2) describe arrangements with local police departments, fire departments, hospitals, contractors and state and local emergency response teams to coordinate emergency services; (3) list the emergency coordinators name; address; and office, home and mobile phone numbers (where more than one person is listed, one shall be named as the primary emergency coordinator);
(4) include a list, which shall be kept current, of emergency equipment at the surface waste management facility, such as fire extinguishing systems, spill control equipment, communications and alarm systems and decontamination equipment, containing a physical description of each item on the list and a brief outline of its capabilities; (5) include an evacuation plan for surface waste management facility personnel that describes signals to be used to begin evacuation, evacuation routes and alternate evacuation routes in cases where fire or releases of wastes could block the primary routes; (6) include an evaluation of expected contaminants, expected media contaminated and procedures for investigation, containment and correction or remediation; (7) list where copies of the contingency plan will be kept, which shall include the surface waste management facility; local police departments, fire departments and hospitals; and state and local emergency response teams;
I-41 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx (8) indicate when the contingency plan will be amended, which shall be within five working days whenever:
(a) the surface waste management facility permit is revised or modified; (b) the plan fails in an emergency; (c) the surface waste management facility changes
- design, construction, operation, maintenance or other circumstances in a way that increases the potential for fires, explosions or releases of oil field waste constituents that could threaten fresh water, public health, safety or the environment or change the response necessary in an emergency; (d) the list of emergency coordinators or their contact information changes; or (e) the list of emergency equipment changes; (9) describe how the emergency coordinator or the coordinators designee, whenever there is an imminent or actual emergency situation, will immediately; (a) activate internal surface waste management facility alarms or communication systems, where applicable, to notify surface waste management facility personnel; and (b) notify appropriate state and local agencies with designated response roles if their assistance is needed; (10) describe how the emergency coordinator, whenever there is a release, fire or explosion, will immediately identify the character, exact source, amount and extent of released materials (the emergency coordinator may do this by observation or review of surface waste management facility records or manifests, and, if necessary, by chemical analysis) and describe how the emergency coordinator will concurrently assess possible hazards to fresh water, public health, safety or the environment that may result from the release, fire or explosion (this assessment shall consider both the direct and indirect hazard of the release, fire or explosion);
(11) describe how, if the surface waste management facility stops operations in response to fire, explosion or release, the emergency coordinator will monitor for leaks, pressure buildup, gas generation or rupture in valves, pipes or the equipment, wherever this is appropriate; (12) describe how the emergency coordinator, immediately after an emergency, will provide for treating, storing or disposing of recovered oil field waste, or other material that results from a release, fire or explosion at a surface waste management facility; (13) describe how the emergency coordinator will ensure that no oil field waste, which may be incompatible with the released material, is treated, stored or disposed of until cleanup procedures are complete; and (14) provide that the emergency coordinator may amend the plan during an emergency as necessary to protect fresh water, public health, safety or the environment.
I-42 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx The Contingency Plan included as Volume II.5 provides detailed information in response to 19.15.36.13.N.1 through 14 NMAC.
O.
Gas safety management plan. Each operator of a surface waste management facility that includes a landfill shall have a gas safety management plan that describes in detail procedures and methods that will be used to prevent landfill-generated gases from interfering or conflicting with the landfills operation and protect fresh water, public health, safety and the environment. The plan shall address anticipated amounts and types of gases that may be generated, an air monitoring plan that includes the vadose zone and measuring, sampling, analyzing, handling, control and processing methods. The plan shall also include final post closure monitoring and control options.
Sundance West does not believe that this Section applies to the proposed Facility. Landfill Gas (LFG) is typically produced when there is a significant supply of readily putrescible organic material, moisture; and a lack of oxygen in the fill. Oil field wastes do not contain significant amounts of putrescible wastes and will not provide a suitable environment for LFG production. Typical oil field wastes will not generate significant quantities of LFG, nor the requisite pressure to promote migration. Conventional LFG monitoring and control systems would not be necessary or effective; and the waste matrix itself would inhibit migration or collection if it contained primarily soils and <5% degradable organics.
However, a gas monitoring program consisting of testing incoming vehicles during unloading will be utilized to ensure that hydrogen sulfide (H2S) gas concentrations do not exceed 10 parts per million (ppm) on-site or at the property boundary. Areas around the landfill disposal cells, treating plant, liquid solidification, and evaporation ponds will utilize monitors that issue a visual and audible signal at 10 ppm H2S to ensure compliance with regulatory alert levels.
Routine gas monitoring of the proposed groundwater monitoring wells will also be conducted.
Monitoring points may be added or replaced as necessary. Gas safety management details are presented in Volume II.1, Volume II.5, and the H2S Prevention and Contingency Plan (Volume II.3).
I-43 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx P.
Training program. Each operator shall conduct an annual training program for key personnel that includes general operations, permit conditions, emergencies proper sampling methods and identification of exempt and non-exempt waste and hazardous waste. The operator shall maintain records of such training, subject to division inspection, for five years.
Sundance West will comply with this requirement. The Operation, Inspection, and Maintenance Plan (Volume II.1) describes in detail the training programs for site personnel.
Training records will be maintained by Sundance West for OCD inspection for a period of not less than five years.
19.15.36.14 SPECIFIC REQUIREMENTS APPLICABLE TO LANDFILLS:
A.
General operating requirements.
(1)
The operator shall confine the landfills working face to the smallest practical area and compact the oil field waste to the smallest practical volume. The operator shall not use equipment that may damage the integrity of the liner system in direct contact with a geosynthetic liner.
Sundance West will follow accepted principles of landfill engineering for waste placement, compaction and covering methods. Operations will be conducted to maintain a confined working face so that it is sufficiently wide to provide for the safe unloading of trucks, but no greater than necessary. It is estimated that the typical thickness of each daily cell will be approximately 10 to 15 ft, with working slopes not greater than 2:1. In order to compact the waste to the smallest practical volume, the lifts will be spread in layers approximately 2 ft thick and worked by a high ground-pressure bulldozer or equivalent. The Engineering Design (Volume III.1) and the Liner Construction Quality Assurance (CQA) Plan (Volume II.7) mandate a 2 ft thick protective soil layer over the geosynthetic liner. The Operations, Inspection, and Maintenance Plan (Volume II.1) addresses daily fill face activities in detail provided to protect the liners during operations.
(2)
The operator shall prevent unauthorized access by the public and entry by large animals to the landfills active portion through the use of fences, gates, locks or other means that attain equivalent protection.
I-44 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx The Sundance West facility will be enclosed with barbed wire fencing, and locking gates (Figure I.2). This will prevent unauthorized access by the public or entry by large animals (Engineering Design, Volume III.1).
(3)
The operator shall prevent and extinguish fires.
Sundance West will provide adequate means to prevent and extinguish fires. Fire protection measures are described in detail in the Contingency Plan (Volume II.5). Measures to prevent and control fires are listed in Table I.7, which are augmented by focused employee training.
TABLE I.7 Fire Prevention and Control Sundance West
- 1. Fire Prevention Measures
- Routine cleaning of debris from equipment, particularly radiators.
- Random inspections of incoming loads at the Facility Gatehouse to prevent unauthorized waste acceptance.
- Training of equipment operators to identify suspect (hot) loads and measures for mitigation (e.g., covering smoldering waste with stockpiled soil).
- Coordination with local fire response professionals for input on fire prevention and control.
- Incompatible waste.
- 2. Fire Control Procedures
- The placement and maintenance of fire extinguishers in all mobile equipment and on-site structures.
- Locating cover material or borrow areas near the working face that can be used to smother fires.
- Ensuring water availability from the water truck and/or detention basins.
- Implementation of a site-wide communication network to optimize mobilization of appropriate response personnel and equipment.
- Employee training.
- Well established emergency response procedures.
(4)
The operator shall control litter and odors.
As described in the Operations, Inspection, and Maintenance Plan (Volume II.1), Sundance West will be operated using proven disposal practices to minimize and control litter and odor.
The waste stream will consist primarily of contaminated soils, which are not prone to wind-blown dispersion. The size of the actual working face will be minimized to facilitate compacting and covering the waste. Also, depending on wind direction and/or velocity,
I-45 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx portable litter fences may be used to control blowing debris, in addition to the perimeter fencing; and most operations can be conducted below the grade of the perimeter berms as necessary.
Staff members will closely monitor the area adjacent to the working face for waste and litter.
Litter will be removed and disposed of on a regular basis and within 24-hours if the waste has a potential for diversion or being transported by vectors. In order to control litter and mitigate potential odors, the active working face will typically be covered at the end of each operating day with at least 6 inches of daily cover, or an approved alternative daily cover material, when the solid waste contains significant amounts of waste prone to become windblown. The prevailing wind is from the south and southeast, and adjacent land uses to the north and northwest are open pasture/oil exploration.
(5)
The operator shall not excavate a closed cell or allow others to excavate a closed cell except as approved by the division.
Excavation of permanently closed cells is not anticipated; however, if a permanently closed cell needs to be excavated, such excavation will be conducted only after prior approval has been obtained from OCD.
(6)
The operator shall provide adequate cover for the landfills active face as needed to control dust, debris, odors or other nuisances, or as otherwise required by the division.
Soil cover, or an approved alternate cover, will be applied to the active face as needed.
Approximately 3,000,000 cy of soil equivalent to 15% of the gross airspace, has been devoted to cover operations. In addition to the activities described in the response to 19.15.36.14.A.4 NMAC above regarding debris, odors, or other nuisances, Sundance West will implement dust control measures as outlined in Table I.8.
I-46 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx TABLE I.8 Dust Control Sundance West A water truck will be available to apply water or approved recycled waters to the access roads and active areas within the Facility, as needed to reduce dust. In addition, the posted speed limit will be 15 mph inside the Facility. Listed below are routine operations that are the most likely sources of dust, along with recommended primary and secondary control measures:
- Disposal Operations -
o Primary Control Measure: Pave high-traffic areas, apply water to unpaved roads as necessary, enforce speed limit posted on site.
o Secondary Control Measure: Apply dust surfactant to unpaved portions of the Facility, provide additional pavement.
- Excavations -
o Primary Control Measure: Pre-water areas prior to and during excavation.
Water areas of excavation and haul roads during and at the end of each day to form a dust-binding soil crust.
o Secondary Control Measure: Phase work to reduce the amount of disturbed surfaces, apply additional water, work at lower elevations (i.e., below-grade) and when wind velocity is high.
- Stockpiles -
o Primary Control Measure: Pre-water areas prior to excavation. Apply water to short-term stockpiles and when transporting soils.
o Secondary Control Measure: Control vehicle access to the area. Apply dust surfactant to long-term stockpiles and apply seed/mulch to prevent erosion.
- Track out extending onto public roadways -
o Primary Control Measure: Pave on-site entrance road, sweep as necessary.
o Secondary Control Measure: Apply recycled asphalt, gravel pads or similar materials at the transition from unpaved to paved roadways.
- Unpaved roadways and parking areas -
o Primary Control Measure: Limit vehicle speed via posting speed limits; apply water, use aggregate or caliche.
o Secondary Control Measure: Apply water and surfactants to unpaved roads and parking lots, as needed, provide additional pavement.
(7)
For areas of the landfill that will not receive additional oil field waste for one month or more, but have not reached the final waste elevation, the operator shall provide intermediate cover that shall be:
(a) approved by the division; (b) stabilized with vegetation; and (c) inspected and maintained to prevent erosion and manage infiltration or leachate during the oil field waste deposition process.
Sundance West will place an intermediate cover at least 6-inches thick, in addition to daily cover, over areas of the landfill that will not receive further oil field waste for one month or more, but have not reached final elevation. Areas of intermediate cover will be properly sloped to promote clean run-off and minimize leachate generation, and may be used for temporary
I-47 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx cover stockpiles. Intermediate cover may be seeded with temporary grasses such as rye if the area will not be subject to additional landfilling within 12 months. If long-term re-vegetation is required, native grass will be applied after consultation with the local Natural Resources Conservation Service (NRCS) representative (see Closure/Post-closure Plan, Volume II.4).
Areas of intermediate cover will be inspected periodically for erosion and settlement, and prompt regrading and maintenance action will be initiated as required. An Intermediate Cover Inspection and Maintenance Plan is provided as Attachment II.1.G.
(8)
When the operator has filled a landfill cell, the operator shall close it pursuant to the conditions contained in the surface waste management facility permit and the requirements of Paragraph (2) of Subsection D of 19.15.36.18 NMAC. The operator shall notify the divisions environmental bureau at least three working days prior to a landfill cells closure.
Sundance West will close a landfill cell when it has been filled to final grade in accordance with the conditions established in the Surface Waste Management Facility Permit, 19.15.36.18.D(2) NMAC, and the Closure/Post-closure Plan provided in Volume II.4 of this Application. Sundance West will install an alternative final cover system in accordance with 19.15.36.14.C(8) NMAC (see Permit Plans, Volume III.1). Sundance West will notify OCD at least three working days prior to the landfill cell closure.
B.
Ground water monitoring program. If fresh ground water exists at a site, the operator shall, unless otherwise approved by the division, establish a ground water monitoring program, approved by the divisions environmental bureau, which shall include a ground water monitoring work plan, a sampling and analysis plan, a ground water monitoring system and a plan for reporting ground water monitoring results. The ground water monitoring system shall consist of a sufficient number of wells, installed at appropriate locations and depths, to yield ground water samples from the uppermost aquifer that:
(1) represent the quality of background ground water that leakage from a landfill has not affected; and (2) represent the quality of ground water passing beneath and down gradient of the surface waste management facility.
Sundance West presents information in Volume IV.2 (Hydrogeology) relating to the confirmed absence of groundwater resources beneath the proposed Facility. Justification for not monitoring the uppermost aquifer reportedly in excess of 675 ft +/- below the site is specifically outlined in Volume IV.2. For this reason Sundance is proposing to monitor the vadose zone
I-48 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx encountered onsite in monitoring well (re-named monitoring well VZ-4, as discussed in Volume II.8), located in the southwest corner of the Sundance West site. Monitoring well VZ-4 is located downgradient of the proposed Sundance West disposal and processing areas, and appears to capture limited vadose water at the interface of the Chinle and Ogallala/Antlers/Gatuna (OAG). This interface in VZ-4 was measured at approximately 60 ft below ground surface (1/12/10). A Vadose Zone Monitoring Plan is included in Volume II.8 to discuss sampling and analysis.
C.
Landfill design specification. New landfill design systems shall include a base layer and a lower geomembrane liner (e.g., composite liner), a leak detection system, an upper geomembrane liner, a leachate collection and removal system, a leachate collection and removal system protective layer, an oil field waste zone and a top landfill cover.
Sundance West will construct a liner designed consistent with the requirements of 19.15.36.14.C NMAC at the proposed Facility. The liner design is described in Volume III.1 (Engineering Design) and will be installed on a compacted subgrade and employ the prescriptive 60-mil high-density polyethylene (HDPE) liner as both the lower and upper components of the double-liner system (see Permit Plans, Volume III.1). The leak detection system will consist of a 200-mil geonet installed between the upper and lower geosynthetic liner system that will drain to the sump areas and confirm the integrity of the liner system. A 200-mil geonet will be installed above the upper geosynthetic liner system to reduce any potential for hydrostatic head on the primary liner. The entire liner system will be protected with 2 ft of compacted soil. The proposed alternative liner system was evaluated with the HELP Model (Volume III.4) and confirmed to be equivalent to the prescriptive liner system.
The liner system is detailed in the Permit Plans (Volume III.1); and in the Liner CQA Plan (Volume II.7) provides geosynthetics specifications; and compatibility documentation is demonstrated in Volume III.6.
(1)
The base layer shall, at a minimum, consist of two feet of clay soil compacted to a minimum 90 percent standard proctor density (ASTM D-698) with a hydraulic conductivity of 1 x 10-7 cm/sec or less. In areas where no ground water is present, the operator may propose an alternative base layer design, subject to division approval.
I-49 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx Sundance West is proposing to install the primary synthetic liner on a 6-inch-thick subgrade, compacted to 90% standard proctor density followed by a geosynthetic clay liner (GCL) with a hydraulic conductivity of 5 x 10-9 cm/sec or less as the alternative base layer design.
Calculations and technical properties of the compacted subgrade system and GCL are included in Volume III. The Permit Plans (Volume III.1) provide design elements of the subgrade component of the composite liner. The proposed alternative liner subgrade was evaluated with the HELP Model (Volume III.4) in conjunction with the proposed liner system and confirmed to provide protection equivalent or greater as to the prescriptive liner system.
(2)
The lower geomembrane liner shall consist of a 30-mil flexible PVC or 60-mil HDPE liner, or an equivalent liner approved by the division.
The proposed liner design for the Sundance West Landfill will employ the prescriptive 60-mil high-density polyethylene (HDPE) liner as the lower component of the liner system. HDPE has proven itself over numerous years to provide vastly superior performance to the 30-mil flexible polyvinylchloride (PVC) material that is also prescribed. The ease of seaming and testing HDPE also enhance its use in this application. The liner system is shown on Figure I.5 and in the Permit Plans (Volume III.1). The Liner CQA Plan (Volume II.7) provides geosynthetics specifications; and compatibility documentation is demonstrated in Volume III.6.
(3)
The operator shall place the leak detection system, which shall consist of two feet of compacted soil with a saturated hydraulic conductivity of 1 x 10-5 cm/sec or greater, between the lower and upper geomembrane liners.
The leak detection system shall consist of a drainage and collection system placed no more than six inches above the lower geomembrane liner in depressions and sloped so as to facilitate the earliest possible leak detection at designated collection points. Drainage piping shall be designed to withstand chemical attack from oil field waste and leachate and structural loading and other stresses and disturbances from overlying oil field waste, cover materials, equipment operation, expansion or contraction, and to facilitate clean-out maintenance. The material placed between the pipes and laterals shall be sufficiently permeable to allow the transport of fluids to the drainage pipe. The slope of the landfill sub-grade and drainage pipes and laterals shall be at least two percent grade; i.e., two feet of vertical drop per 100 horizontal feet. The piping collection network shall be comprised of solid and perforated pipe having a minimum diameter of four inches
I-51 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx and a minimum wall thickness of schedule 80. The operator shall seal a solid drainage pipe to convey collected liquids to a corrosion-proof sump or sumps located outside the landfills perimeter for observation, storage, treatment or disposal. The operator may install alternative designs as approved by the division.
Sundance West proposes to install a leak detection system consisting of a 200-mil geonet between the lower (primary) and upper (secondary) liners, as the preferred alternative to the prescriptive 2-ft of compacted soil with a saturated hydraulic conductivity (ksat) of 1 x 10-5 cm/sec. The geonet will have a minimum hydraulic conductivity (k) of 10 cm/sec. Calculations, compatibility, demonstrations and technical properties of the leak detection system are included in Volume III which document superior performance vs. the prescriptive design. The Permit Plans (Volume III.1) provide design elements of the leak detection system including:
- Minimum 2.8% slope on the liner and leak detection system vs. 2% standard
- Sump and riser pipe details
- Solid and perforated pipe details
- Composite liner (i.e., FML/GCL) beneath the entire double-lined footprint The Engineering Design (Volume III.1) and the Permit Plans provide detailed specifications demonstrating that the performance of the materials exceed the prescriptive standards. This use of the geonet in this alternative liner cross-section was evaluated with the HELP Model (Volume III.4) and confirmed to provide protection superior to the prescriptive liner system.
(4)
The operator shall place the upper geomembrane liner, which shall consist of a 30-mil flexible PVC or 60-mil HDPE liner, or an equivalent liner approved by the division, over the leak detection system.
Sundance West will construct a liner design that will employ the prescriptive 60-mil high-density polyethylene (HDPE) liner as the upper component of the liner system. The liner system is shown on Figure I.5 and the Permit Plans (Volume III.1); and the Liner CQA Plan (Volume II.7) provides geosynthetics specifications; and compatibility documentation is demonstrated in Volume III.6.
(5)
The operator shall place the leachate collection and removal system, which shall consist of at least two feet of compacted soil with a saturated hydraulic conductivity of 1 x 10-2 cm/sec or greater, over the upper geomembrane
I-52 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx liner to facilitate drainage. The leachate collection and removal system shall consist of a drainage and collection and removal system placed no more than six inches above the upper geomembrane liner in depressions and sloped so as to facilitate the maximum leachate collection. Piping shall be designed to withstand chemical attack from oil field waste or leachate and structural loading and other stresses and disturbances from overlying oil field waste, cover materials, equipment operation, expansion or contraction and to facilitate clean-out maintenance. The material placed between the pipes and laterals shall be sufficiently permeable to allow the transport of fluids to the drainage pipe. The slope of the upper geomembrane liner and drainage lines and laterals shall be at least two percent grade; i.e., two feet of vertical drop per 100 horizontal feet. The piping collection network shall be comprised of solid and perforated pipe having a minimum diameter of four inches and a minimum wall thickness of schedule 80. The operator shall seal a solid drainage pipe to convey collected fluids outside the landfills perimeter for storage, treatment and disposal. The operator may install alternative designs as approved by the division.
Sundance West is proposing to install a leachate collection and removal system consisting of a 200-mil geocomposite above the upper (secondary) liner, as an alternative to the prescriptive 2 ft of compacted soil with a saturated hydraulic conductivity of 1 x 10-5 cm/sec. The geocomposite will have a minimum hydraulic conductivity (k) of 10 cm/sec. This collection zone will be protected with two ft of compacted soil with a hydraulic conductivity of 1 x 10- 5 cm/sec. This component of the alternative liner cross-section was evaluated with the HELP Model (Volume III.4) and confirmed to provide protection and performance equivalent to the prescriptive liner system. Drainage piping consisting of appropriately sized HDPE pipe will be installed to monitor for leakage. Calculations, compatibility, and technical properties of the leak detection system are included in Volume III, Engineering Design and Calculations.
Permit Plans (Volume III.1) provides design elements of the leachate collection and removal system including:
- Minimum 2% slope on the liner and leak detection system
- Solid and perforated pipe details
- Sump and riser pipe
- Composite liner (i.e., FML/GCL) under each leak detection sump The Engineering Design (Volume III.1) and the Permit Plans provide detailed specifications for the piping collection systems demonstrating that the materials exceed the prescriptive standards.
I-53 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx (6)
The operator shall place the leachate collection and removal system protection layer, which shall consist of a soil layer at least one foot thick with a saturated hydraulic conductivity of 1 x 10-2 cm/sec or greater, over the leachate collection and removal system.
Sundance West is proposing to install a 200-mil geonet protected by 2-ft of uncompacted soil with a minimum ksat of 1 x 10-5 cm/sec, or greater, as the protection layer over the leachate collection and removal system. This component of the alternative liner cross-section was evaluated with the HELP Model (Volume III.4) and confirmed to provide protection and performance superior to the prescriptive liner system. HELP Modeling results indicate a maximum head of 2.0 inches on the liner vs. the design standard of 12 inches.
(7)
The operator shall place oil field waste over the leachate collection and removal system protective layer.
Sundance West proposes to place oil field waste over the PSL for the leachate collection and removal system. The first lift, up to 5 ft in thickness, will consist of select uncompacted materials screened for items that could damage the liner (i.e., pipes, metal, etc.).
(8)
The top landfill cover design shall consist of the following layers (top to bottom): a soil erosion layer composed of at least 12 inches of fertile topsoil re-vegetated in accordance with the post closure provisions of Subparagraph (b) of Paragraph (2) of Subsection D of 19.15.36.18 NMAC; a protection or frost protection layer composed of 12 to 30 inches of native soil; a drainage layer composed of at least 12 inches of sand or gravel with a saturated hydraulic conductivity of 1 x 10-2 cm/sec or greater and a minimum bottom slope of four percent, a hydraulic barrier-layer-geomembrane (minimum of a 30-mil flexible PVC or 60-mil HDPE liner, or an equivalent liner approved by the division); and a gas vent or foundation layer composed of at least 12 inches of sand or gravel above oil field waste with soils compacted to the minimum 80 percent Standard Proctor Density. The operator shall install the top landfill cover within one year of achieving the final landfill cell waste elevation. The operator shall ensure that the final landfill design elevation of the working face of the oil field waste is achieved in a timely manner with the date recorded in a field construction log. The operator shall also record the date of top landfill cover installation to document the timely installation of top landfill covers.
The operator shall provide a minimum of three working days notice to the division in advance of the top landfill covers installation to allow the division to witness the top landfill covers installation.
I-54 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx Sundance West proposes an alternative final cover system as described in 19.15.36.14.C(9)
NMAC. The final cover design is an evapotranspiration (ET) cap consisting of on-site soils.
This is a more sustainable design than the prescriptive standard, as it does not require importation of off-site materials (i.e., HDPE from Houston) or extensive maintenance due to potential slippage (Figure I.6).
(9)
Alternatively, the operator may propose a performance-based landfill design system using geosynthetics or geocomposites, including geogrids, geonets, geosynthetic clay liners, composite liner systems, etc., when supported by EPAs hydrologic evaluation of landfill performance (HELP) model or other division-approved model. The operator shall design the landfill to prevent the bathtub effect. The bathtub effect occurs when a more permeable cover is placed over a less permeable bottom liner or natural subsoil.
Sundance West has undertaken an evaluation of the materials and climate of the Facility based on the United States Environmental Protection Agencys (USEPA) HELP Model and is proposing an alternative final cover system (Figure I.6) based on the ET technology. The proposed final cover will include 2 ft of vegetation cover on top of a 0.5-ft barrier layer as demonstrated in Volume III.4.
(10)
External piping, e.g., leachate collection, leak detection and sump removal systems shall be designed for installation of a sidewall riser pipe. Pipes shall not penetrate the liner with the exception of gas vent or collection wells where the operator shall install a flexible clamped pipe riser through the top landfill cover liner that will accommodate oil field waste settling and will prevent tears.
Sundance West proposes to install the necessary piping to transfer liquids collected in the leak detection and leachate collection sumps up the sideslope and through the proposed alternative final cover system on the sideslope. This will allow for the measurement and removal of liquids that accumulate in either system. Risers for both systems will be constructed of 12 in dia.
HDPE; and there are no pipe penetrations of either the primary or secondary liners.
D.
Liner specifications and requirements.
(1)
General requirements.
I-56 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx (a)
Geomembrane liner specifications. Geomembrane liners shall consist of a 30-mil flexible PVC or 60-mil HDPE liner, or an equivalent liner approved by the division. Geomembrane liners shall have a hydraulic conductivity no greater than 1 x 10-9 cm/sec.
Geomembrane liners shall be composed of impervious, geosynthetic material that is resistant to petroleum hydrocarbons, salts and acidic and alkaline solutions. Liners shall also be resistant to ultraviolet light, or the operator shall make provisions to protect the material from sunlight. Liner compatibility shall comply with EPA SW-846 method 9090A.
Sundance West proposes a landfill liner design that will employ the prescriptive 60-mil HDPE liner as the upper component and the lower component of the liner system. The liner system is shown on the Permit Plans (Volume III.1); the Liner CQA Plan (Volume II.7) provides geosynthetics specifications and installation standards; and compatibility documentation is demonstrated in Volume III.6.
(b)
Liners shall be able to withstand projected loading stresses, settling and disturbances from overlying oil field waste, cover materials and equipment operations.
The liner system will be able to withstand projected loading stresses, settling, and disturbances from overlying oil field waste, cover materials and equipment operations as demonstrated in the Liner Stress Analysis (Volume III.7), and Settlement Calculations (Volume III.8).
(c)
The operator shall construct liners with a minimum of two percent slope to promote positive drainage and to facilitate leachate collection and leak detection.
Sundance West will construct the liner with a 2.8% slope to promote positive drainage and to facilitate leachate collection and leak detection. The liner system design is shown on the Permit Plans (Volume III.1).
(2)
Additional requirements for geomembranes.
(a)
Geomembranes shall be compatible with the oil field waste to be disposed. Geomembranes shall be resistant to chemical attack from the oil field waste or leachate. The operator shall demonstrate this
I-57 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx by means of the manufacturers test reports, laboratory analyses or other division-approved method.
The liner system geosynthetics specifications are provided in the CQA Plan (Volume II.7);
and compatibility documentation is demonstrated in Volume III.6.
(b)
Geosynthetic material the operator installs on a slope greater than 25 percent shall be designed to withstand the calculated tensile forces acting upon the material. The design shall consider the maximum friction angle of the geosynthetic with regard to a soil-geosynthetic or geosynthetic-geosynthetic interface and shall ensure that overall slope stability is maintained.
There are no liner systems designed for slopes greater than 25%. The liner system will be able to withstand calculated tensile forces acting upon the material as demonstrated in the Liner Stress Analysis (Volume III.7), and Settlement Calculations (Volume III.8).
(c)
The operator shall thermally seal (hot wedge) field seams in geosynthetic material with a double track weld to create an air pocket for non-destructive air channel testing. In areas where double-track welding cannot be achieved, the operator may propose alternative thermal seaming methods. A stabilized air pressure of 35psi, plus or minus one percent, shall be maintained for at least five minutes. The operator shall overlap liners four to six inches before seaming, and shall orient seams parallel to the line of maximum slope; i.e., oriented along, not across, the slope. The operator shall minimize the number of field seams in corners and irregularly shaped areas. The operator shall use factory seams whenever possible. The operator shall not install horizontal seams within five feet of the slopes toe. Qualified personnel shall perform all field seaming.
The Engineering Design (Volume III.1) and Liner CQA Plan (Volume II.7) provide detailed specifications for the installation of geosynthetics in compliance with this section, including:
- Foundation preparation
- Maximum (4:1) and minimum slopes (2.8%)
- Thermal seaming and testing procedures
- Field seams that will be oriented parallel to the line of maximum slope.
- Minimizing the number of field seams in corners and irregularly shaped areas.
- No horizontal seams within 5 ft of the toe of slope.
I-58 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx All liner systems will be installed by qualified contractors with a least 10 million square ft of geosynthetic installation experience.
E.
Requirements for the soil component of composite liners.
(1)
The operator shall place and compact the base layer to 90 percent standard proctor density on a prepared sub-grade.
Sundance West is proposing to place and compact the base layer to 90% Standard Proctor Density on a prepared subgrade of in situ soils per the CQA Plan (Volume II.7). Calculations and technical properties of the subgrade are included in Volume III, the Permit Plans provides design elements of the subgrade component of the composite liner.
(2)
The soil surface upon which the operator installs a geosynthetic shall be free of stones greater than one half inch in any dimension, organic matter, local irregularities, protrusions, loose soil and abrupt changes in grade that could damage the geosynthetic.
Sundance West will install the GCL on a surface that is free of angular stones (maximum 1/2-inch), organic matter, local irregularities, protrusions, loose soil or abrupt changes in grade that could potentially damage the GCL (Volume II.7). Technical properties of the geosynthetic are provided in the CQA Plan, Volume II.7. The Permit Plans (Volume III.1) provide installation guidance for the geosynthetic component of the composite liner.
(3)
The operator shall compact a clay soil component of a composite liner to a minimum of 90 percent standard proctor density, which shall have, unless otherwise approved by the division, a plasticity index greater than 10 percent, a liquid limit between 25 and 50 percent, a portion of material passing the no. 200 sieve (0.074 mm and less fraction) greater than 40 percent by weight; and a clay content greater than 18 percent by weight.
Sundance West proposes to install a GCL below the synthetic liner. The soil subgrade below the GCL will be in situ materials with superior foundation characteristics to the fine-grained soils specified. Calculations and technical properties of the GCL and compacted soil subgrade system are included in Volume III. The Permit Plans (Volume III.1) provide design elements of this component of the composite liner. This component of the alternative liner system was evaluated with the HELP Model (Volume III.4) and confirmed to provide protection and performance equivalent to the prescriptive liner system.
I-59 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx F.
The leachate collection and removal system protective layer and the soil component of the leak detection system shall consist of soil materials that shall be free of organic matter, shall have a portion of material passing the no. 200 sieve no greater than five percent by weight and shall have a uniformity coefficient (Cu) less than 6, where Cu is defined as D60/D10. Geosynthetic materials or geocomposites including geonets and geotextiles, if used as components of the leachate collection and removal or leak detection system, shall have a hydraulic conductivity, transmissivity and chemical and physical qualities that oil field waste placement, equipment operation or leachate generation will not adversely affect. These geosynthetics or geocomposites, if used in conjunction with the soil protective cover for liners, shall have a hydraulic conductivity designed to ensure that the liners hydraulic head never exceeds one foot.
Sundance West proposes to install a leak detection system consisting of a 200-mil geonet between the primary and secondary liners. The geocomposite has a minimum k value of 10 cm/sec. Calculations, compatibility, demonstrations and technical properties of the leak detection system are included in Volume III. The Permit Plans provide design elements of the leak detection system including:
- Minimum 2.8% slope on the liner and leak detection system
- Sump and riser pipe detail
- Composite liner (i.e., FML/GCL) under each leak detection sump This component of the alternative liner cross-section was evaluated with the HELP Model (Volume III.4) and confirmed to provide protection and performance equivalent to the prescriptive liner system.
G.
Landfill gas control systems. If the gas safety management plan or requirements of other federal, state or local agencies require the installation of a gas control system at a landfill, the operator shall submit a plan for division approval, which shall include the following:
(1) the systems design, indicating the location and design of vents, barriers, collection piping and manifolds and other control measures that the operator will install (gas vent or collection wells shall incorporate a clamped and seamed pipe riser design through the top cover liner);
Not Applicable. LFG is generated from the decomposition of readily degradable organic material, such as paper and other organic household and commercial wastes. The primary by-products, typically comprising over 99% of LFG by volume, are methane and carbon dioxide as stated in USEPAs AP-42 Emission Factor Documentation (08/19/97):
I-60 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx AP 42 - 2.4 Municipal Solid Waste Landfills 2.4.4 Emissions Methane (CH4) and CO2 are the primary constituents of landfill gas, and are produced by microorganisms within the landfill under anaerobic conditions. Transformations of CH4 and CO2 are mediated by microbial populations that are adapted to the cycling of materials in anaerobic environments.
LFG is produced when there is a significant supply of readily putrescible organic material and moisture; plus a lack of oxygen. Oil field wastes do not provide a suitable environment for LFG production, and over 95% of the projected waste types would be subtracted from the decomposition equation used to demonstrate compliance with air quality requirements.
Typical oil field wastes will not generate significant quantities of LFG, or the requisite pressure to promote migration. Conventional landfill gas monitoring and control systems are not necessary or effective, and the waste matrix itself would inhibit migration or collection if it contained < 5% degradable organics.
In addition, the New Mexico Environment Department (NMED) and USEPA do not mandate the installation of LFG controls until the landfill reaches a design capacity of over 3.2 million cubic yards (cy); or if migration is confirmed. Of this volume, typically over 75% is assumed to be organic waste subject to decomposition (as opposed to <5% of oil field waste). A surface waste management facility would need a design capacity of 64 million cy to qualify for landfill gas controls under NMED and USEPA standards, and Sundance West has a design capacity of 17 million +/- cubic yards.
(2) if gas recovery is proposed, the design of the proposed gas recovery system and the systems major on-site components, including storage, transportation, processing, treatment or disposal measures required in the management of generated gases, condensates or other residues; Sundance West does not propose to conduct gas recovery or processing, as it will not be practical.
(3) if gas processing is proposed, a processing plan designed in a manner that does not interfere or conflict with the activities on the site or required control measures or create or cause danger to persons or property; (4) if gas disposal is proposed, a disposal plan designed:
I-61 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx (a) in a manner that does not interfere or conflict with the activities on the site or with required control measures; (b) so as not to create or cause danger to persons or property; and (c) with active forced ventilation, using vents located at least one foot above the landfill surface at each gas vents location; (5) physical and chemical characterization of condensates or residues that are generated and a plan for their disposal; Not Applicable.
(6) means that the operator will implement to prevent gas generation and lateral migration such that (a) the concentration of the gases the landfill generates does not exceed 25 percent of the lower explosive limit for gases in surface waste management facility structures (excluding gas control or recovery system components); and (b) the concentration of gases does not exceed the lower explosive limit for gases at the surface waste management facility boundary; and In addition the following factors which inhibit the potential generation of other explosive gases (i.e., CH4):
- The oil field waste proposed to be accepted by Sundance West is primarily non-putrescible (i.e., < 5%).
- The semi-arid climate characteristics of Lea County (low precipitation e.g., 12 inches of annual rainfall) (Volume IV.1).
- Low potential for moisture contribution from other sources, due to the installation of engineered control systems that divert run-on away from the disposal area.
- Waste is encapsulated by multilayered liner and cover systems.
(7) a routine gas monitoring program providing for monitoring at least quarterly; the specific type and frequency of monitoring to be determined based on the following:
(a) soil conditions; (b) the hydrogeologic and hydraulic conditions surrounding the surface waste management facility; and (c) the location of surface waste management facility structures and property lines.
Sundance West will implement a routine gas monitoring program for H2S as outlined in Volume II.3; Hydrogen Sulfide Prevention and Contingency Plan and Volume II.1; Operations, Inspection, and Maintenance Plan.
I-62 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx H.
Landfill gas response. If gas levels exceed the limits specified in Paragraph (6) of Subsection G of 19.15.36.14 NMAC, the operator shall:
(1) immediately take all necessary steps to ensure protection of fresh water, public health, safety and the environment and notify the division; (2) within seven days of detection, record gas levels detected and a description of the steps taken to protect fresh water, public health, safety and the environment; (3) within 30 days of detection, submit a remediation plan for gas releases that describes the problems nature and extent and the proposed remedy; and (4) within 60 days after division approval, implement the remediation plan and notify the division that the plan has been implemented.
Sundance West will comply with this section in the event that landfill gas is detected in the groundwater monitoring system; and emergency response to elevated H2S levels is addressed in Volume II.3; Hydrogen Sulfide Prevention and Contingency Plan.
19.15.36.15 SPECIFIC REQUIREMENTS APPLICABLE TO LANDFARMS:
Not Applicable. Sundance West does not propose to operate an OCD regulated landfarm.
19.15.36.16 SMALL LANDFARMS:
Small landfarms as defined in Paragraph (5) of Subsection A of 19.15.36.7 NMAC are exempt from 19.15.36 NMAC except for the requirements specified in 19.15.36.16 NMAC.
Not Applicable.
19.15.36.17 SPECIFIC REQUIREMENTS APPLICABLE TO EVAPORATION, STORAGE, TREATMENT AND SKIMMER PONDS:
A.
Engineering design plan. An applicant for a surface waste management facility permit or modification requesting inclusion of a skimmer pit; an evaporation, storage or treatment pond; or a below-grade tank shall submit with the surface waste management facility permit application a detailed engineering design plan, certified by a registered profession engineer, including operating and maintenance procedures; a closure plan; and a hydrologic report that provides sufficient information and detail on the sites topography, soils, geology, surface
I-63 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx hydrology and ground water hydrology to enable the division to evaluate the actual and potential effects on soils, surface water and ground water. The plan shall include detailed information on dike protection and structural integrity; leak detection, including an adequate fluid collection and removal system; liner specifications and compatibility; freeboard and overtopping prevention; prevention of nuisance and hazardous odors such as H2S; an emergency response plan, unless the pit is part of a surface waste management facility that has an integrated contingency plan; type of oil field waste stream, including chemical analysis; climatological factors, including freeze-thaw cycles; a monitoring and inspection plan; erosion control; and other pertinent information the division requests.
The proposed Sundance West Facility includes both a Processing Area and a Landfill. The Processing Area design includes (at full build-out) 10 evaporation ponds. Volume III (Engineering Design and Calculations), certified by I. Keith Gordon, P.E., provides the detailed engineering design plan for the proposed surface waste management facility, including:
- liner details
- calculations detailing dike protection and structural integrity
- leak detection system
- liner specifications and compatibility documentation
- freeboard and overtopping (wave action) analysis
- erosion control
- fluid collection and removal system Volume II (Facility Management Plans) describes:
- operation and maintenance procedures
- Closure/Post-closure Plan
- H2S Prevention and Contingency Plan
- emergency response plan
- monitoring and inspection plan
- oil field waste management plan
- Contingency Plan
- chemical analysis Volume IV (Siting and Hydrogeology) describes:
- site topography
- soils
- geology
- surface hydrology
- groundwater hydrology
- climatology
I-64 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx B.
Construction, standards.
(1)
In general. The operator shall ensure each pit, pond and below-grade tank is designed, constructed and operated so as to contain liquids and solids in a manner that will protect fresh water, public health, safety and the environment.
The Liner CQA Plan (Volume II.7) provides detailed procedures for the proper construction of the berms and liner system in compliance with the Permit Plans (Volume III.1). The Processing Area, including pits, and ponds, is designed and will be constructed and operated so as to protect fresh water, safety, and the environment.
(2)
Liners required. Each pit or pond shall contain, at a minimum, a primary (upper) liner and a secondary (lower) liner with a leak detection system appropriate to the sites conditions.
Sundance West will comply with this requirement. Volume III.1 provides the detail for the primary liner, secondary liner, and leak detection system that will be installed for each evaporation pond in compliance with these requirements.
(3)
Liner specifications. Liners shall consist of a 30-mil flexible PVC or 60-mil HDPE liner, or an equivalent liner approved by the division. Synthetic (geomembrane) liners shall have a hydraulic conductivity no greater than 1 x 10-9 cm/sec. Geomembrane liners shall be composed of an impervious, synthetic material that is resistant to petroleum hydrocarbons, salts and acidic and alkaline solutions. Liner materials shall be resistant to ultraviolet light, or the operator shall make provisions to protect the material from sunlight. Liner compatibility shall comply with EPA SW-846 method 9090A.
The liner system design for the Processing Area ponds has been designed consistent with Section 19.15.36.17.B.(3) NMAC. The liner design will employ the prescriptive 60-mil HDPE liner as the upper component and the lower component of the liner system. The leak detection system will consist of a 200-mil HDPE geonet installed between the upper and secondary liner system that will drain to the sump areas. HDPE is the preferred material for waste containment based on over 30 years of successful applications.
I-65 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx The liner system is shown on the Permit Plans (Volume III.1); and the Liner CQA Plan (Volume II.7) provides geosynthetics specifications; and compatibility documentation is demonstrated in Volume III.6.
(4)
Alternative liner media. The division may approve other liner media if the operator demonstrates to the divisions satisfaction that the alternative liner protects fresh water, public health, safety and the environment as effectively as the specified media.
The liner design will employ the prescriptive 60-mil HDPE liner as the upper component and lower component of the liner system. The alternative leak detection system will consist of a 200-mil geonet installed between the upper and secondary liner system draining towards the sump areas.
(5)
Each pit or pond shall have a properly constructed foundation or firm, unyielding base, smooth and free of rocks, debris, sharp edges or irregularities, in order to prevent rupture or tear of the liner and an adequate anchor trench; and shall be constructed so that the inside grade of the levee is no steeper than 2H:1V. Levees shall have an outside grade no steeper than 3H:1V. The levees tops shall be wide enough to install an anchor trench and provide adequate room for inspection and maintenance.
The operator shall minimize liner seams and orient them up and down, not across a slope. The operator shall use factory seams where possible. The operator shall ensure field seams in geosynthetic material are thermally seamed (hot wedge) with a double track weld to create an air pocket for non-destructive air channel testing. A stabilized air pressure of 35 psi, plus or minus one percent, shall be maintained for at least five minutes. The operator shall overlap liners four to six inches before seaming, and orient seams parallel to the line of maximum slope, i.e., oriented along, not across, the slope. The operator shall minimize the number of field seams in corners and irregularly shaped areas. There shall be no horizontal seams within five feet of the slopes toe. Qualified personnel shall perform field seaming.
The Engineering Design (Volume III.1) and Liner CQA Plan (Volume II.7) provide detailed specifications for the installation of geosynthetics in compliance with this section, including:
- Foundation preparation
- Maximum (3:1) and minimum slopes (2.8%)
- Thermal seaming and testing procedures
- Field seams that will be oriented parallel to the line of maximum slope
- Minimizing the number of field seams in corners and irregularly shaped areas
I-66 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx
- No horizontal seams within five ft of the toe of slope Liner systems will be installed by qualified contractors with a least 10 million square ft of geosynthetics installation experience.
(6)
At a point of discharge into or suction from the lined pit, the liner shall be protected from excessive hydrostatic force or mechanical damage, and external discharge lines shall not penetrate the liner.
The liner details shown on the Permit Plans (Volume III.1) indicate the methods used to protect the liner. To address the hydrostatic forces and potential mechanical damage to the primary liner as a result of pumping into or suction out of the lined ponds; an additional sheet of 60-mil HDPE liner will be welded overtop of the primary liner in the areas that these activities are expected to be conducted. The Permit Plans shows the location of the additional 60-mil HDPE layer. There are no liner pipe penetrations in the facility design with the exception of the leak detection riser at the top of the slope.
(7)
Primary liners shall be constructed of a synthetic material.
See response to 19.15.36.17.B.(3) NMAC.
(8)
A secondary liner may be a synthetic liner or an alternative liner approved by the division. Secondary liners constructed with compacted soil membranes, i.e., natural or processed clay and other soils, shall be at least three feet thick, placed in six-inch lifts and compacted to 95 percent of the materials standard proctor density, or equivalent. Compacted soil membranes used in a liner shall undergo permeability testing in conformity with ASTM standards and methods approved by the division before and after construction. Compacted soil membranes shall have a hydraulic conductivity of no greater than 1 x 10-8 cm/sec. The operator shall submit results of pre-construction testing to the division for approval prior to construction.
Sundance West is not proposing a secondary alternate liner constructed of a soil component.
Sundance West proposes to utilize a secondary liner option consisting of 60-mil HDPE. See response to 19.15.36.17.B.(4) NMAC.
(9)
The operator shall place a leak detection system between the lower and upper geomembrane liners that consists of two feet of compacted soil with a saturated hydraulic conductivity of 1 x 10-5 cm/sec or greater to facilitate
I-67 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx drainage. The leak detection system shall consist of a properly designed drainage and collection and removal system placed above the lower geomembrane liner in depressions and sloped so as to facilitate the earliest possible leak detection. Piping used shall be designed to withstand chemical attack from oil field waste or leachate; structural loading from stresses and disturbances from overlying oil field waste, cover materials, equipment operation or expansion or contraction; and to facilitate clean-out maintenance. The material placed between the pipes and laterals shall be sufficiently permeable to allow the transport of fluids to the drainage pipe.
The slope of the interior sub-grade and of drainage lines and laterals shall be at least a two percent grade, i.e., two feet vertical drop per 100 horizontal feet. The piping collection system shall be comprised of solid and perforated pipe having a minimum diameter of four inches and a minimum wall thickness of schedule 80. The operator shall seal a solid sidewall riser pipe to convey collected fluids to a collection, observation and disposal system located outside the perimeter of the pit or pond. The operator may install alternative methods as approved by the division.
Sundance West is proposing to install an alternative leak detection system consisting of a 200-mil geonet between the primary and secondary liners. The geocomposite will have a minimum k value of 10 cm/sec. Calculations, compatibility, demonstrations and technical properties of the leak detection system are included in Volume III. The Permit Plans (Volume III.1) provide design elements of the leak detection system including:
- Minimum 2.8% slope on the liner and leak detection system
- Sump and riser pipe details
- Composite liner (i.e., FML/GCL) under each leak detection sump The Engineering Design and the Permit Plans (Volume III.1) provide detailed specifications for the piping collection systems demonstrating that the materials exceed the prescriptive standards.
(10)
The operator shall notify the division at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to the primary liners installation so that a division representative may inspect the leak detection system before it is covered.
Sundance West will provide a milestone schedule to OCD in advance of liner construction, and notify OCD at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to the primary liner installation.
(11)
The operator shall construct pits and ponds in a manner that prevents overtopping due to wave action or rainfall, and maintain a three foot freeboard at all times.
I-68 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx Sundance West will comply with this requirement. Volume III provides detailed calculations demonstrating compliance with wave action, rainfall, and freeboard standards.
(12)
The maximum size of an evaporation or storage pond shall not exceed 10 acre-feet.
Sundance West will comply with this requirement. The proposed ponds are each approximately 9.5 acre-ft in capacity. Volume III.1, Engineering Design provides detail calculations regarding capacity.
C.
Operating standards.
(1)
The operator shall ensure that only produced fluids or non-hazardous waste are discharged into or stored in a pit or pond; and that no measurable or visible oil layer is allowed to accumulate or remain anywhere on a pits surface except an approved skimmer pit.
The Oil Field Waste Management Plan (Volume II.2) provides detailed procedures to ensure that only produced fluids are placed into or stored in a pit or pond, including load rejection procedures.
The Operations, Inspection, and Maintenance Plan (Volume II.1) addresses measurable or visible oil layer.
(2)
The operator shall monitor leak detection systems pursuant to the approved surface waste management facility permit conditions, maintain monitoring records in a form readily accessible for division inspection and report discovery of liquids in the leak detection system to the division within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Sundance West will comply with this requirement. The Operations, Inspection, and Maintenance Plan (Volume II.1) provides a more detailed description of monitoring, recordkeeping and procedures for management of liquids in the leak detection system.
(3)
Fencing and netting. The operator shall fence or enclose pits or ponds to prevent unauthorized access and maintain fences in good repair. Fences are not required if there is an adequate perimeter fence surrounding the surface waste management facility. The operator shall screen, net, cover or otherwise render non-hazardous to migratory birds tanks exceeding eight feet in diameter and exposed pits and ponds. Upon written application, the division may grant an exception to screening, netting or covering requirements upon the operators showing that an alternative method will
I-69 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx adequately protect migratory birds or that the tank or pit is not hazardous to migratory birds.
The perimeter of the Sundance West Facility (i.e., the Processing Area and the Landfill) will be enclosed with barbed wire fencing and locking gates. The Permit Plans (Volume III.1) graphically describes the proposed locations of the existing and proposed perimeter fencing.
Sundance West requests an alternate method to the prescriptive migratory bird screening requirement. The Migratory Bird Protection Plan (Volume II.6) describes the proposed alternate methodology to the screening requirement of the storage ponds. This Plan describes visual inspections and migratory bird retrieval and clean-up procedures in the unlikely event that birds require decontamination.
(4)
The division may approve spray systems to enhance natural evaporation.
The operator shall submit engineering designs for spray systems to the divisions environmental bureau for approval prior to installation. The operator shall ensure that spray evaporation systems are operated so that spray-borne suspended or dissolved solids remain within the perimeter of the ponds lined portion.
Sundance West proposes to install a spray system utilizing mechanical evaporators to enhance natural evaporation in the proposed ponds. The Operations, Inspection, and Maintenance Plan (Volume II.1) provides the design, operation and maintenance of the proposed system.
The proposed mechanical evaporation system is designed to prevent spray-borne suspended or dissolved solids from exiting the perimeter of the ponds liner area. In addition, this system will not be operated when wind velocity exceeds twelve miles per hour (sustained) via automatic shut-off mechanisms. There is also a minimum setback between the ponds and the property line of 50 ft.
(5)
The operator shall use skimmer pits or tanks to separate oil from produced water prior to water discharge into a pond. The operator shall install a trap device in connected ponds to prevent solids and oils from transferring from one pond to another unless approved in the surface waste management facility permit.
Sundance West will utilize tanks to process water accepted at the Facility that requires separation of oil from water as described in the Operations, Inspection, and Maintenance Plan
I-70 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx (Volume II.1). No oil processing is proposed in open pits, and oil residues will be removed from water prior to discharging into the evaporation ponds.
D.
Below-grade tanks and sumps.
(1)
The operator shall construct below-grade tanks with secondary containment and leak detection. The operator shall not allow below-grade tanks to overflow. The operator shall install only below-grade tanks of materials resistant to the tanks particular contents and to damage from sunlight.
Sundance West does not propose to construct or operate below-grade tanks at the proposed Facility.
(2)
The operator shall test sumps integrity annually, and shall promptly repair or replace a sump that does not demonstrate integrity. The operator may test sumps that can be removed from their emplacements by visual inspection. The operator shall test other sumps by appropriate mechanical means. The operator shall maintain records of sump inspection and testing and make such records available for division inspection.
The Sundance West Facility design includes below-grade sumps. The tank farm, landfill and evaporation pond containment will include leak detection systems and sumps which will be monitored in compliance with 19.15.36.17.D(2) NMAC.
E.
Closure required. The operator shall properly close pits, ponds and below-grade tanks within six months after cessation of use.
Sundance West will comply with this requirement. The Closure/Post-closure Plan (Volume II.4) describes closure timeframes in detail.
19.15.36.18 CLOSURE AND POST CLOSURE:
A.
Surface waste management facility closure by operator.
(1)
The operator shall notify the divisions environmental bureau at least 60 days prior to cessation of operations at the surface waste management facility and provide a proposed schedule for closure. Upon receipt of such notice and proposed schedule, the division shall review the current closure plan for adequacy and inspect the surface waste management facility.
Sundance West will comply with this requirement. The Closure/Post-closure Plan (Volume II.4) describes closure notification requirements in detail.
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The division shall notify the operator within 60 days after the date of cessation of operations specified in the operators closure notice of modifications of the closure plan and proposed schedule or additional requirements that it determines are necessary for the protection of fresh water, public health, safety or the environment.
No response required.
(3)
If the division does not notify the operator of additional closure requirements within 60 days as provided, the operator may proceed with closure in accordance with the approved closure plan; provided that the director may, for good cause, extend the time for the divisions response for an additional period not to exceed 60 days by written notice to the operator.
Sundance West will comply with this requirement.
(4)
The operator shall be entitled to a hearing concerning a modification or additional requirement the division seeks to impose if it files an application for a hearing within 10 days after receipt of written notice of the proposed modifications or additional requirements.
Sundance West will comply with this requirement.
(5)
Closure shall proceed in accordance with the approved closure plan and schedule and modifications or additional requirements the division imposes. During closure operations the operator shall maintain the surface waste management facility to protect fresh water, public health, safety and the environment.
Sundance West will comply with this requirement.
(6)
Upon completion of closure, the operator shall re-vegetate the site unless the division has approved an alternative site use plan as provided in Subsection G of 19.15.36.18 NMAC. Re-vegetation, except for landfill cells, shall consist of establishment of a vegetative cover equal to 70 percent of the native perennial vegetative cover (un-impacted by overgrazing, fire or other intrusion damaging to native vegetation) or scientifically documented ecological description consisting of at least three native plant species, including at least one grass, but not including noxious weeds, and maintenance of that cover through two successive growing seasons.
I-72 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx Sundance West will comply with this requirement. The Closure/Post-closure Plan (Volume II.4) describes in detail revegetation and maintenance plans for the Facility.
B.
Release of financial assurance.
(1)
When the division determines that closure is complete it shall release the financial assurance, except for the amount needed to maintain monitoring wells for the applicable post closure care period, to perform semi-annual analyses of such monitoring wells and to re-vegetate the site. Prior to the partial release of the financial assurance covering the surface waste management facility, the division shall inspect the site to determine that closure is complete.
The Closure/Post-closure Plan (Volume II.4) provides the estimated amount, in current dollars, required for the Post-closure care and maintenance.
(2)
After the applicable post closure care period has expired, the division shall release the remainder of the financial assurance if the monitoring wells show no contamination and the re-vegetation in accordance with Paragraph (6) of Subsection A of 19.15.36.18 NMAC is successful. If monitoring wells or other monitoring or leak detection systems reveal contamination during the surface waste management facilitys operation or in the applicable post closure care period following the surface waste management facilitys closure the division shall not release the financial assurance until the contamination is remediated in accordance with 19.15.30 NMAC and 19.15.29 NMAC, as applicable.
Sundance West will comply with this requirement.
(3)
In any event, the division shall not finally release the financial assurance until it determines that the operator has successfully revegetated the site in accordance with Paragraph (6) of Subsection A of 19.15.36.18 NMAC, or, if the division has approved an alternative site use plan, until the landowner has obtained the necessary regulatory approvals and begun implementation of the use.
No response required.
C.
Surface waste management facility closure initiated by the division. Forfeiture of financial assurance.
(1)
For good cause, the division may, after notice to the operator and an opportunity for a hearing, order immediate cessation of a surface waste management facilitys operation when it appears that cessation is necessary to protect fresh water, public health, safety or the environment,
I-73 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx or to assure compliance with statutes or division rules and orders. The division may order closure without notice and an opportunity for hearing in the event of an emergency, subject to NMSA 1978, Section 70-2-23, as amended.
No response required.
(2)
If the operator refuses or is unable to conduct operations at a surface waste management facility in a manner that protects fresh water, public health, safety and the environment; refuses or is unable to conduct or complete an approved closure plan; is in material breach of the terms and conditions of its surface waste management facility permit; or the operator defaults on the conditions under which the division accepted the surface waste management facilitys financial assurance; or if disposal operations have ceased and there has been no significant activity at the surface waste management facility for six months the division may take the following actions to forfeit all or part of the financial assurance:
(a) send written notice by certified mail, return receipt requested, to the operator and the surety, if any, informing them of the decision to close the surface waste management facility and to forfeit the financial assurance, including the reasons for the forfeiture and the amount to be forfeited, and notifying the operator and surety that a hearing request or other response shall be made within 10 days of receipt of the notice; and (b) advise the operator and surety of the conditions under which they may avoid the forfeiture; such conditions may include but are not limited to an agreement by the operator or another party to perform closure and post closure operations in accordance with the surface waste management facility permit conditions, the closure plan (including modifications or additional requirements imposed by the division) and division rules, and satisfactory demonstration that the operator or other party has the ability to perform such agreement.
Sundance West will cooperate with OCD concerning this requirement and does not foresee any instance in which the Facility will not be operated in compliance with the Permit or Permit Conditions.
(3)
The division may allow a surety to perform closure if the surety can demonstrate an ability to timely complete the closure and post closure in accordance with the approved plan.
No response required.
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If the operator and the surety do not respond to a notice of proposed forfeiture within the time provided, or fail to satisfy the specified conditions for non-forfeiture, the division shall proceed, after hearing if the operator or surety has timely requested a hearing, to declare the financial assurances forfeiture. The division may then proceed to collect the forfeited amount and use the funds to complete the closure, or, at the division's election, to close the surface waste management facility and collect the forfeited amount as reimbursement.
(a)
The division shall deposit amounts collected as a result of forfeiture of financial assurance in the oil and gas reclamation fund.
(b)
In the event the amount forfeited and collected is insufficient for closure, the operator shall be liable for the deficiency. The division may complete or authorize completion of closure and post closure and may recover from the operator reasonably incurred costs of closure and forfeiture in excess of the amount collected pursuant to the forfeiture.
(c)
In the event the amount collected pursuant to the forfeiture was more than the amount necessary to complete closure, including remediation costs, and forfeiture costs, the division shall return the excess to the operator or surety, as applicable, reserving such amount as may be reasonably necessary for post closure monitoring and re-vegetation in accordance with Paragraph (6) of Subsection A of 19.15.36.18 NMAC. The division shall return excess of the amount retained over the actual cost of post closure monitoring and re-vegetation to the operator or surety at the later of the conclusion of the applicable post closure period or when the site re-vegetation in accordance with Paragraph (6) of Subsection A of 19.15.36.18 NMAC is successful.
No response required. The conditions listed are not anticipated.
(5)
If the operator abandons the surface waste management facility or cannot fulfill the conditions and obligations of the surface waste management facility permit or division rules, the state of New Mexico, its agencies, officers, employees, agents, contractors and other entities designated by the state shall have all rights of entry into, over and upon the surface waste management facility property, including all necessary and convenient rights of ingress and egress with all materials and equipment to conduct operation, termination and closure of the surface waste management facility, including but not limited to the temporary storage of equipment and materials, the right to borrow or dispose of materials and all other rights necessary for the surface waste management facilitys operation, termination and closure in accordance with the surface waste management facility permit and to conduct post closure monitoring.
I-75 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx No response required. The conditions listed are not required.
D.
Surface waste management facility and cell closure and post closure standards.
The following minimum standards shall apply to closure and post closure of the installations indicated, whether the entire surface waste management facility is being closed or only a part of the surface waste management facility.
(1)
Oil treating plant closure. The operator shall ensure that:
(a) tanks and equipment used for oil treatment are cleaned and oil field waste is disposed of at a division-approved surface waste management facility (the operator shall reuse, recycle or remove tanks and equipment from the site within 90 days of closure);
(b) the site is sampled, in accordance with the procedures specified in chapter nine of EPA publication SW-846, test methods for evaluating solid waste, physical/chemical methods, for TPH, BTEX, major cations and anions and RCRA metals, in accordance with a gridded plat of the site containing at least four equal sections that the division has approved; and (c) sample results are submitted to the environmental bureau in the division's Santa Fe office.
Sundance West will implement the Closure/Post-closure Plan (Volume II.4) for closure activities in compliance with 19.15.36.18.D NMAC.
(2)
Landfill cell closure.
(a)
The operator shall properly close landfill cells, covering the cell with a top cover pursuant to Paragraph (8) of Subsection C of 19.15.36.14 NMAC, with soil contoured to promote drainage of precipitation; side slopes shall not exceed a 25 percent grade (four feet horizontal to one foot vertical), such that the final cover of the landfills top portion has a gradient of two percent to five percent, and the slopes are sufficient to prevent the ponding of water and erosion of the cover material.
(b)
The operator shall re-vegetate the area overlying the cell with native grass covering at least 70 percent of the landfill cover and surrounding areas, consisting of at least two grasses and not including noxious weeds or deep rooted shrubs or trees, and maintain that cover through the post closure period.
Sundance West will implement the Closure/Post-closure Plan (Volume II.4) for the Landfill cells. The Permit Plans (Volume III.1) provides the engineering design for the overall final grading contours for the Landfill. Sundance West proposed to install an alternate cover per 19.15.36.14.C(9) NMAC. The side slopes will be no greater that 25% (4 horizontal to 1 vertical) and the top crown will be constructed to a design grade of 5%. The alternate final
I-76 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx cover includes 12-inches of compacted impermeable materials (intermediate cover) overlain with a 2-ft thick barrier (infiltration layer; k 5.0 x 10-5 cm/sec) that is capped with a 12-inch vegetative (erosion) layer, all graded to drain. The Landfill final cover details are shown in Figure II.4.3 and on the Permit Plans (Volume III.1). The final cover, as well as other disturbed areas of the site, will be seeded with native vegetation. Vegetation on the site will be established during the optimum planting period, whenever possible. Examples of seed types have been identified and recommended by the NRCS.
(3)
Landfill post closure. Following landfill closure, the post closure care period for a landfill shall be 30 years.
(a)
A post closure care and monitoring plan shall include maintenance of cover integrity, maintenance and operation of a leak detection system and leachate collection and removal system and operation of gas and ground water monitoring systems.
(b)
The operator or other responsible entity shall sample existing ground water monitoring wells annually and submit reports of monitoring performance and data collected within 45 days after the end of each calendar year. The operator shall report any exceedance of a ground water standard that it discovers during monitoring pursuant to 19.15.29 NMAC.
Sundance West will implement the Closure/Post-closure Plan, (Volume II.4) for the post-closure care and monitoring required.
(4)
Landfarm closure. The operator shall ensure that:
Not applicable; Sundance West is not proposing landfarm facilities.
E.
Pond and pit closure. The operator shall ensure that:
(1) liquids in the ponds or pits are removed and disposed of in a division-approved surface waste management facility; (2) liners are disposed of in a division-approved surface waste management facility; (3) equipment associated with the surface waste management facility is removed; (4) the site is sampled, in accordance with the procedures specified in chapter nine of EPA publication SW-846, test methods for evaluating solid waste, physical/chemical methods for TPH, BTEX, metals and other inorganics listed in Subsections A and B of 20.6.2.3103 NMAC, in accordance with a gridded plat of the site containing at least four equal sections that the division has approved; and
I-77 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx (5) sample results are submitted to the environmental bureau in the division's Santa Fe office.
Sundance West will comply with this requirement. The Closure/Post-closure Plan (Volume II.4) describes in detail facility decommissioning, including liquid, liner and equipment disposal; as well as sampling, testing, and reporting when closure of the Facility is implemented.
F.
Landfarm and pond and pit post closure. The post-closure care period for a landfarm or pond or pit shall be three years if the operator has achieved clean closure. During that period the operator or other responsible entity shall regularly inspect and maintain required revegetation. If there has been a release to the vadose zone or to ground water, then the operator shall comply with the applicable requirements of 19.15.30 NMAC and 19.15.29 NMAC.
No response required.
G.
Alternatives to re-vegetation. If the landowner contemplates use of the land where a cell or surface waste management facility is located for purposes inconsistent with re-vegetation, the landowner may, with division approval, implement an alternative surface treatment appropriate for the contemplated use, provided that the alternative treatment will effectively prevent erosion. If the division approves an alternative to re-vegetation, it shall not release the portion of the operators financial assurance reserved for post-closure until the landowner has obtained necessary regulatory approvals and begun implementation of such alternative use.
If applicable, Sundance West will comply with this requirement.
19.15.36.19 EXCEPTIONS AND WAIVERS:
A.
In a surface waste management facility permit application, the applicant may propose alternatives to requirements of 19.15.36 NMAC, and the division may approve such alternatives if it determines that the proposed alternatives will provide equivalent protection of fresh water, public health, safety and the environment.
Sundance West is requesting alternatives to the requirements consistent with the flexibility provided for:
- LFG Control requirements per 19.15.36.13.O NMAC (this Volume)
- Groundwater monitoring per 19.15.36.14.B(1-2) NMAC (Volumes II.8 and IV.2)
- Geonet Detection and Drainage Layers per 19.15.36.14.C (Volume III.4)
I-78 P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx
- Final Cover per 19.15.36.14.C(9) NMAC (Volume III.4)
- Bird Control Alternatives per 19.15.36.19 NMAC (Volume II.6)
Demonstrations and justifications have been provided in the referenced sections and associated technical documentation.
B.
The division may grant exceptions to, or waivers of, or approve alternatives to requirements of 19.15.36 NMAC in an emergency without notice or hearing. The operator requesting an exception or waiver, except in an emergency, shall apply for a surface waste management facility permit modification in accordance with Subsection C of 19.15.36.8 NMAC. If the requested modification is a major modification, the operator shall provide notice of the request in accordance with 19.15.36.9 NMAC.
Sundance West will comply with this requirement.
19.15.36.20 TRANSITIONAL PROVISIONS:
Sundance West is a proposed new commercial Surface Waste Management Facility. No response required.
APPLICATION FOR PERMIT SUNDANCE WEST VOLUME I: PERMIT APPLICATION TEXT PART 36: SURFACE WASTE MANAGEMENT FACILITIES P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx ATTACHMENT I.A PARTIAL ASSIGNMENT AND ASSUMPTION OF LEASE
APPLICATION FOR PERMIT SUNDANCE WEST VOLUME I: PERMIT APPLICATION TEXT PART 36: SURFACE WASTE MANAGEMENT FACILITIES P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx ATTACHMENT I.B PUBLIC NOTIFICATION
P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-Att I.B-Notice Text_August.2016.docx NOTICE OF APPLICATION SUNDANCE WEST - SURFACE WASTE MANAGEMENT FACILITY Pursuant to 19.15.36, Oil Conservation Division Surface Waste Management Facilities regulations, Sundance West, Inc. is providing notice that the Oil Conservation Division (OCD) has deemed administratively complete an Application for Permit for a new Surface Waste Management Facility (Sundance West Facility). The Application for Permit was submitted to OCD by Sundance West, Inc. on 08/15/2016. Comments regarding the Application may be submitted to OCD within 30 days of Notice.
- 1. Applicants name and address: Sundance West, Inc., P.O. Box 1737, Eunice, NM 88231; Telephone: 575.394.2511.
- 2. Facility location and address: The proposed Sundance West Facility is located approximately 3 miles east of Eunice, 18 miles south of Hobbs, and approximately 1.5 miles west of the Texas/New Mexico (NM) state line in unincorporated Lea County, NM. The Sundance West Site is comprised of a 320-acre +/- tract of land located in the South 1/2 of Section 30, Township 21 South, Range 38 East, Lea County, NM. Site access will be provided via NM 18 and Wallach Lane.
- 3. Brief description of surface waste management facility: The proposed Sundance West Facility will include a liquid oil field waste Processing Area (80 acres +/-) and an oil field waste Landfill (180 acres +/-). At full build-out, the Processing Area will include an oil treatment facility consisting of an estimated 8 produced water load-out points, 45 produced water tanks, 10 evaporation ponds, 3 crude oil recovery tanks, and 2 oil sales tanks; as well as 1 stabilization and solidification area; and 1 customer jet wash (6 bays). The Landfill disposal footprint is 180 acres +/- with a waste capacity (airspace) of approximately 17.4 million cubic yards. In addition, various support facilities, including: a Gatehouse/Office, waste acceptance/security features, roads, emergency shower and eyewash station, and stormwater detention basins are proposed for the new Facility.
- 4. Depth and quality of shallowest aquifer: The permanent uppermost regional aquifer beneath the Sundance West site area lies at a depth of at least 675 to 1,075 feet (ft) below ground surface (bgs) in the Santa Rosa Formation of the Dockum Group. The depth to the intermittent perched water zone beneath the site is approximately 55 ft bgs (Well MP-4P), on top of, or within, the Chinle formation. Analytical results from a water sample collected from Well MP-4P (perched zone) show that three constituents (barium, fluoride, and iron) were detected at concentrations above the Water Quality Control Commission groundwater protection standard (GWPS); and the remaining analytes for which a GWPS is established were not detected above the laboratory method practical quantitation limit. Site-specific data collection from on-site drilling investigations demonstrates that the proposed site meets the requirement for a minimum separation distance of 100 ft between the base of the proposed landfill area and the uppermost regional aquifer; and for other non-landfill operations subject to the 50 ft vertical groundwater setback (i.e., lined ponds and process facilities) located south of the landfill footprint.
Interested parties may contact Jim Griswold, Bureau Chief, Oil Conservation Division at (505) 476-3465 for further information.
APPLICATION FOR PERMIT SUNDANCE WEST VOLUME I: PERMIT APPLICATION TEXT PART 36: SURFACE WASTE MANAGEMENT FACILITIES P:\\FILES\\530.06.01\\PermitApp\\RAI.1\\Volume I\\SWest-I-19.15.36.NMAC_August.2016.docx ATTACHMENT I.C FINANCIAL ASSURANCE TO BE PROVIDED UPON PERMIT APPROVAL