Discharge Control and Permitting

Summary of Expertise

  • NPDES
  • Underground Injection Control
  • Pollution Prevention Plans

The client needed to plug and abandon several injection wells that extended into a flooded salt mine.  The problem was that the casing in many of the wells had corroded to the point that standard bridge plugs could not be reliably set.   In many instances, the casing was entirely missing at the depth where the plug needed to extend to satisfy regulatory requirements.  Enter EarthFax who, together with a team of renowned subcontractors, developed a unique plan to achieve the end result.   Read about this and other experiences below.

PREPARATION OF AN SPCC PLAN FOR A GEOTHERMAL POWER PLANT.  EarthFax prepared a Spill Prevention, Control, and Countermeasure (“SPCC”) plan for a binary cycle geothermal power plant located in southwest Utah.  The plant is located on approximately 1100 acres of land with 68 developed acres and includes groundwater extraction and reinjection wells, electrical turbines, and auxiliary equipment that support the production of electricity.  The plan covers operation of the power generation facility and remote extraction and reinjection wells.  It is designed to protect against potentially harmful effects of oil discharges to navigable waters.  Components of the plan include a description of facility drainage, secondary containment, inspection procedures, security requirements, personnel training, and spill response. 

POND LINER REPLACEMENT AT A PROCESS GAS MANUFACTURING PLANT. In 2005, EarthFax began monitoring a lime pond at a process gas manufacturing plant to verify that the pond liner system was intact and not leaking. In 2010, the primary liner showed signs of leaking and the pond was taken out of service by the client. At the client’s request, EarthFax served as agency liaison to the Utah Division of Environmental Quality ("UDEQ") in submitting and implementing designs to replace the primary liner. Following UDEQ approval of a suitable work plan, EarthFax assisted the client in procuring a construction contractor to perform the work and supervised replacement of the pond liner. During project construction to remove the primary liner, EarthFax assessed the condition of the secondary liner and the geosynthetic membrane between the primary and secondary liners. Upon EarthFax’s recommendation, additional sections of geosynthetic membrane were placed between the secondary liner and the new primary liner to provide adequate interstitial spacing between the liners and protect against abrasion that might lead to leakage in the future. A geosynthetic fiber material was also placed on top of the membrane material as an additional buffer against abrasion of the primary liner. Following completion of these tasks, EarthFax installed four groundwater monitor wells around the pond to determine the elevation and gradient of groundwater flow beneath the pond and to monitor groundwater for any signs of lime solution leakage to groundwater.

PREPARATION OF AN SPCC PLAN FOR A MAJOR DATA STORAGE CENTER. EarthFax was subcontracted by a general contractor to develop a Spill Prevention Control and Countermeasures Plan ("SPCC plan") at a 1,000,000 square foot data storage center. The purpose of the plan was to ensure that spill prevention control and countermeasures were in place at the facility during initial fueling activities at two tank farms that supply fuel to numerous emergency backup generators. The overall scope of work included preparation of a plan that complies with 40 CFR 112. Components of the plan include a description of measures implemented to prevent oil discharges from occurring during initial fueling operations at the tank farms and its associated equipment; and to prepare the general contractor and its personnel to respond in a safe, effective, and timely manner to mitigate the impacts of a discharge of oil should it occur. EarthFax conducted site visits to inspect fuel storage tanks, above-ground and underground fuel conveyance piping, off-loading areas for fuel trucks, emergency generator day tanks, and emergency generators. In response to the client’s need to complete the plan in a timely fashion on this design-build project, EarthFax completed the work in approximately two weeks using approximately eight man-days.

STREAM ALTERATION PERMITS AND ENGINEERING DESIGN FOR A PETROLEUM PIPELINE EXPANSION.  EarthFax prepared 10 stream alteration permits in connection with expansion of a petroleum pipeline that spanned approximately 90 miles from Evanston, Wyoming to Salt Lake City, Utah.  These were prepared for submittal by the client to the U.S. Army Corps of Engineers and the Utah State Engineer’s Office.  The pipeline expansion project included installing a 16-inch diameter pipeline parallel to an existing pipeline owned by the client to provide additional flow, thereby allowing the client to satisfy demands and delivery requirements to petroleum refineries in the Salt Lake City area.  Alternatives considered by EarthFax for installation of the new pipeline at the stream channel crossings included spanning, boring, and trenching, with trenching selected as the most effective and economical alternative.  EarthFax provided design drawings and specifications as well as construction alternatives for completing the stream channel crossings.  As a voluntary effort by the client in behalf of a private landowner in Lost Creek Canyon, EarthFax prepared one additional stream alteration permit in connection with a failed beaver dam that had caused significant erosion on private land.
 
SPILL PREVENTION CONTROL AND COUNTERMEASURES PLAN FOR A MAJOR UNIVERSITY. EarthFax recently completed a Spill Prevention Control and Countermeasures Plan (“Plan”) for a major university located in northern Utah. The Plan was written to comply with Federal regulations promulgated to prevent discharges of oil to navigable waters of the United States and adjoining shorelines. We evaluated over 200 oil storage locations to assess the reasonable potential for equipment failure at each site; whether secondary containment was adequate; and determine the direction, rate of flow, and the quantity of oil that would be released in the event of equipment failure. Additionally, a substantial harm determination was made according to regulatory requirements to evaluate whether a Facility Response Plan would be required. Project work included visiting and developing written summaries for each site, conducting interviews with maintenance personnel, and writing a Plan that is compliant with regulatory requirements. The location of each site was described using grid locations from a commonly used campus-wide map and each site was placed on a more detailed AutoCAD® map for easy reference. Inspection forms, training guidelines, and inspection protocols were included in the Plan to allow campus personnel to maintain it. Organization of the Plan was designed to be readily useable by response personnel, risk management personnel, and maintenance personnel.

DEVELOPMENT OF AN NPDES DATA BASE. Surface-water and waste-water discharge samples were collected from a rocket-motor manufacturing facility in Utah to develop a data base required for preparation of NPDES permit applications. Grab and composite samples were collected from numerous discharges over a period of one year to characterize the sources. Input was provided into preparation of the NPDES permit applications.

STORM WATER DISCHARGE PERMIT COMPLIANCE REVIEW. Storm water discharges from a potash mining and processing facility were examined to assess the applicability of storm water NPDES permit requirements to the site. The adequacy of existing runoff controls was examined. Special attention was paid to areas where additional controls were required. A baseline monitoring program was recommended to collect the data needed for submission of the permit application.

PREPARATION OF AN NPDES BEST MANAGEMENT PRACTICE PLAN. A Best Management Practices Plan was prepared to meet the requirements of an NPDES permit for an industrial facility in northern Utah. This facility manufactures gas-generate pellets used to actuate air bags in automobiles. Areas of the facility were reviewed and programs were established to control both routine and emergency discharges of treated or untreated contaminants to waste water and storm water. Plans were also developed to address agency concerns in the event of spills, leaks, or other emergency discharges.

STORM WATER INSPECTIONS. Inspections were performed at 14 food-processing facilities throughout the United States to determine the presence or absence of storm water discharges associated with industrial activity. Recommendations were provided to mitigate storm water exposure of material handling activities. The study was designed to aid management's decision to claim an exemption from NPDES storm-water regulations for each facility.

PREPARATION OF STORM WATER POLLUTION PREVENTION PLANS. Storm Water Pollution Prevention Plans were prepared for four facilities in Utah used for the production and assembly of automobile air-bag components. The plans were prepared in accordance with U.S. Environmental Protection Agency guidance and included identification of the pollution prevention teams, materials inventories, identification of significant materials that were exposed to rainfall, lists of previous spills, pollutant source identification, recommended best management practices, and plans for employee training.

STORM WATER POLLUTION PREVENTION PLAN DEVELOPMENT FOR A SUPERFUND SITE. A storm water pollution prevention plan was developed to cover excavation of a repository for contaminated soil to be removed from a Superfund site.The site was contaminated with radioactive materials and selected metals. Construction methods were evaluated and potential sources of pollution were identified. Best management practices were then established, employee training was discussed, and pollution prevention teams were organized.

UNDERGROUND INJECTION CONTROL SERVICES. EarthFax provided technical and field supervisory services related to revisions of an underground injection control permit for a salt and potash solution mine in southeastern Utah. Abandonment plans were revised for several old wells, wireline logging was supervised, and plugging of the wells was supervised. Field decisions regarding appropriate equipment and techniques were made to ensure proper plugging and abandonment. In some cases, working with a team of subcontractors, it was necessary to develop specialty cements that would float in the brine while hardening in order to permit plugging where corroded casing would not allow the use of bridge plugs. Mechanical integrity tests were also selected and testing was supervised in the field. All abandonment and mechanical integrity test data were assessed to ensure that the intent of the regulatory agencies was met. Liaison was provided between the client and the regulatory agencies on permit issues.

WETLANDS PERMITTING AT A PIPELINE CROSSING.  EarthFax has provided assistance to its clients on numerous wetlands projects including wetlands permitting, protection, enhancement, and banking.  We help the client by delineating wetlands, working to ensure that the timing of permit approvals is coordinated with pipeline project planning and construction schedules, and negotiating acceptable mitigation banking options with the U.S. Army Corps of Engineers. We also develop systems to protect and enhance existing waterfowl and shorebird habitats.  In some cases, we have been able to identify under-utilized resources and put them to beneficial use on these projects.   

As an example, EarthFax provided wetlands delineation and permitting services for a pipeline company at two stream channel crossing locations.  The pipeline in these locations was exposed in the stream channel due to high spring runoff and pipeline personnel had elected to mitigate the problem by boring beneath the stream channel to install new pipeline segments.  The project plans included advancing directional underground boreholes, installing the new pipe segments, making tie-ins with the existing line, and removing the old pipe segments from the stream channel.  Some land disturbance was required to complete the project.  EarthFax assisted the client by delineating wetlands at each of the two channel crossings in accordance with the U.S. Corps of Engineers (“USCOE”) 1987 Wetland Delineation Manual.  Wetlands were identified, mapped using a sub-meter accurate GPS unit, and marked in the field with pin flags to identify areas that should be excluded from land disturbance and construction activities.  Since the timing of the wetlands delineations was close to the onset of winter, there was some concern that accurate delineations may not be possible should snow cover be on the ground when delineation work is performed.  In the event completely accurate delineations would not be possible due to snow cover, we sought USCOE approval to delineate approximate wetland boundaries for the purpose of identifying approximate impacts to wetland areas.  We proposed to follow this effort with a final delineation during the growing season.  The USCOE agreed with our plan if the approximate delineation predicted a suspected wetlands impact of less than 1/10th of an acre.  The project met this criterion, allowing the schedule to be maintained. 

SUPPORT OF HYDROTEST OPERATIONS.  EarthFax has assisted its clients with permitting and sampling services associated with pipeline pressure testing where water discharge control was required.  We have prepared and submitted numerous permits for discharging water during pipeline hydrotests.  To mitigate the potential for erosion and flooding to surrounding areas, we have designed temporary control features such as detention basins, baffle systems, and straw bale dikes.  At the client’s request, we have also provided inspection services during construction of these features, inspected and maintained the integrity of water control features during the life of the project, and performed water quality sampling to verify compliance with the conditions of the discharge permit.

Copyright 2013 EarthFax Engineering Group, LLC
7324 South Union Park Ave., Midvale, Utah 84047 | Phone: 801-561-1555

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