IMAGES -Operator utilized an unlined and unpermitted production pit. Operator allowed E&P waste to leak from the production pit resulting in SAR concentrations in soil exceeding table 910-1 standards

LARIMER COUNTY, COLORADO DocNum:	200307619	Date Rec'd:	4/15/2011
Operator:	SKEAR PROPERTIES LTD PARTNERSHIP	Oper. No.	79290
Address:	6054 S CR 13 LOVELAND , CO 80537
Company Rep.
Well Name/No.
Location	T R
Fac.ID:		Fac.Type:
API number:	05-069 -06213	County
COGCC Rep:	STEVE LINDBLOM	Phone:	(303 ) 894-2100

Alleged Violation:
Date of Alleged Violation: 3/11/2011			Approx. time of violation:
OPERATOR UTILIZED AN UNLINED AND UNPERMITTED PRODCTION PIT. OPERATOR ALLOWED E&P WASTE TO LEAK FROM THE PRODUCTION PIT RESULTING IN SAR CONCENTRATIONS IN SOIL EXCEEDING TABLE 910-1 STANDARDS.
Act, Order, Regulation, Permit Conditions Cited:
RULE 324.A.a, RULE 904.a.(2), RULE 906.b, RULE 907.a.(1).
Abatement or Corrective Action Required to be Performed by Operator
SUBMIT SPILL REPORT, FORM 19 AND SITE INVESTIGATION AND REMEDIATION WORKPLAN, FORM 27. CEASE USE OF THE PRODUCTION PIT BY 4/22/2011. DISCONTINUE FUTURE USE OF PRODUCTION PIT UNTIL PRODUCTION PIT PERMITTED IN ACCORDANCE WITH RULES 903 AND LINED IN ACCORDANCE WITH RULE 904 TO PREVENT FURTHER LEAKAGE OF PRODUCED WATER.
Abatement or Corrective Action Required to be Completed by: 5/15/2011
This section to be completed by Operator when alleged violation is corrected
Company Rep:		Title:
Signature?		Date:	4/15/2011 2:16:13 PM
Company Comments:
COGCC Signature? Date: N/A
Resolution approved by:		Title:

Final Resolution
Date		Case Closed?		Letter Sent?		COGCC person
No Final data found. click images to enlarge 910. ALLOWABLE CONCENTRATIONS AND SAMPLING FOR SOIL AND GROUND WATER a. Soil and ground water allowable concentrations. The allowable concentrations for soil and ground water are in Table 910-1. Ground water standards and analytical methods are derived from the ground water standards and classifications established by WQCC. b. Sampling and analysis. (1) Existing workplans. Sampling and analysis for sites subject to an approved workplan shall be conducted in accordance with the workplan and the sampling and analysis requirements described in this rule. (2) Methods for sampling and analysis. Sampling and analysis for site investigation or confirmation of successful remediation shall be conducted to determine the nature and extent of impact and confirm compliance with appropriate allowable concentrations. A. Field analysis. Field measurements and field tests shall be conducted using appropriate equipment, calibrated and operated according to manufacturer specifications, by personnel trained and familiar with the equipment. B. Sample collection. Samples shall be collected, preserved, documented, and shipped using standard environmental sampling procedures in a manner to ensure accurate representation of site conditions. C. Laboratory analytical methods. Laboratories shall analyze samples using standard methods (such as EPA SW-846 or API RP-45) appropriate for detecting the target analyte. The method selected shall have detection limits less than or equal to the allowable concentrations in Table 910-1. D. Background sampling. Samples of comparable, nearby, non-impacted, native soil, ground water or other medium may be required by the Director for establishing background conditions. (3) Soil sampling and analysis. A. Applicability. If soil contamination is suspected or known to exist as a result of spills/releases or E&P waste management, representative samples of soil shall be collected and analyzed in accordance with this rule. B. Sample collection. Samples shall be collected from areas most likely to have been impacted, and the horizontal and vertical extent of contamination shall be determined. The number and location of samples shall be appropriate to the impact. C. Sample analysis. Soil samples shall be analyzed for contaminants listed in Table 910-1 as appropriate to assess the impact or confirm remediation. D. Reporting. Soil Analysis Report, Form 24 shall be used when the Director requires results of soil analyses. E. Soil impacted by produced water. For impacts to soil due to produced water, samples from comparable, nearby non-impacted, native soil shall be collected and analyzed for purposes of establishing background soil conditions including pH and electrical conductivity (EC). Where EC of the impacted soil exceeds the allowable level in Table 910-1, the sodium adsorption ratio (SAR) shall also be determined. F. Soil impacted by hydrocarbons. For impacts to soil due to hydrocarbons, samples shall be analyzed for TPH. (4) Ground water sampling and analysis. A. Applicability. Operators shall collect and analyze representative samples of ground water in accordance with these rules under the following circumstances: i. Where ground water contamination is suspected or known to exceed the allowable concentrations in Table 910-1; ii. Where impacted soils are in contact with ground water; or iii. Where impacts to soils extend down to the high water table. B. Sample collection. Samples shall be collected from areas most likely to have been impacted, downgradient or in the middle of excavated areas. The number and location of samples shall be appropriate to determine the horizontal and vertical extent of the impact. If the concentrations in Table 910-1 are exceeded, the direction of flow and a ground water gradient shall be established, unless the extent of the contamination and migration can otherwise be adequately determined. C. Sample analysis. Ground water samples shall be analyzed for benzene, toluene, ethylbenzene, xylene, and API RP-45 constituents, or other parameters appropriate for evaluating the impact. D. Reporting. Water Analysis Report, Form 25 shall be used when the Director requires results of water analyses. E. Impacted ground water. Where ground water contaminants exceed the allowable concentrations listed in Table 910-1, operators shall notify the Director, and submit to the Director for prior approval a Site Investigation and Remediation Workplan, Form 27, for the investigation, remediation, or monitoring of ground water to meet the required allowable concentrations. 912. VENTING OR FLARING NATURAL GAS a. The unnecessary or excessive venting or flaring of natural gas produced from a well is prohibited. b. Except for gas flared or vented during an upset condition, well maintenance, well stimulation flowback, purging operations, or a productivity test, gas from a well shall be flared or vented only after notice has been given and approval obtained from the Director on a Sundry Notice, Form 4, stating the estimated volume and content of the gas. The notice shall indicate whether the gas contains more than one (1) ppm of hydrogen sulfide. If necessary to protect the public health, safety or welfare, the Director may require the flaring of gas. C Gas flared, vented or used on the lease shall be estimated based on a gas-oil ratio test or other equivalent test approved by the Director, and reported on Operator's Monthly Production Report, Form 7. d. Prior to flaring of any gas, operators shall construct a special purpose pit in compliance with Rule 903. e. Operators shall notify the local emergency dispatch or the local governmental designee of any natural gas flaring. Notice shall be given prior to flaring when flaring can be reasonably anticipated, or as soon as possible but in no event more than two (2) hours after the flaring occurs. 900-13 as of November 30, 2006 Table 910-1 ALLOWABLE CONCENTRATIONS AND LEVELS Contaminant of Concern Allowable Concentrations Organics in Soil: EPA Method 8015 (modified) TPH-Non-Sensitive Area 10,000 mg/kg TPH-Sensitive Area 1,000 mg/kg Organics in Ground Water: EPA Method 8020 1 Benzene 5 μg/l 1 Toluene 1,000 μg/l 1 Ethylbenzene 700 μg/l 1 Xylenes (Total) 1,400 to 10,000 μg/l 5 Inorganics in Soils4 Electrical Conductivity (EC) <4 mmhos/cm or 2x background Sodiun Adsorption Ratio (SAR) <12 pH 6-9 Inorganics in Ground Water Total Dissolved Solids (TDS) <1.25 x background 1 Chlorides <1.25 x background 1 Sulfates <1.25 x background 1 Total Metals in Soils: EPA Method 3050 4 Arsenic 41 mg/kg 2 Barium (LDNR True Total Barium) 180,000 mg/kg 2 Boron (Hot Water Soluble) 2 mg/l 2 Cadmium 26 mg/kg 2 Chromium 1,500 mg/kg 2 Copper 750 mg/kg 2 Lead 300 mg/kg 2 Mercury 17 mg/kg 2 Molybdenum 3 Nickel 210 mg/kg 2 Selenium 3 Silver 100 mg/kg 2 Zinc 1,400 mg/kg 2 1Concentrations taken from CDPHE-WQCC 2Concentrations taken from API Metals Guidance: Maximum Soil Concentrations 3Concentrations are dependent on site-specific conditions 4Consideration shall be given to background levels in native soils 5For this range of standards, the first number in the range is a strictly health-based value, based on the WQCC’s established methodology for human health-based standards. The second number in the range is a maximum contaminant level (MCL), established under the Federal Safe Drinking Water Act which has been determined to be an acceptable level of this chemical in public water supplies, taking treatability and laboratory detection limits into account. The WQCC intends that control requirements for this chemical be implemented to attain a level of ambient water quality that is at least equal to the first number in the range except as follows: 1) where ground water quality exceeds the first number in the range due to a release of contaminants that occurred prior to September 14, 2004 (regardless of the date of discovery or subsequent migration of such contaminants) clean-up levels for the entire contaminant plume shall be no more restrictive than the second number in the range or the ground water quality resulting from such release, whichever is more protective, and 2) whenever the WQCC has adopted alternative, site-specific standards for the chemical, the site-specific standards shall apply instead of these statewide standards. What were the imposed fines for such an atrocity? An unlined pit? Absolutely ridiculous! Is this notice of  'alleged violation' still alleged? Email WTFRACK.ORG@GMAIL.COM  to request the full pdf analytical report. please comment