DSHW-2018-005914 - 0901a0688085c8d3

State of Utah
GARY R. HERBERT
Govemor
SPENCER J. COX
Lieutenant Govemor
TO:
THROUGH:
FROM:
DATE:
SUBJECT:
Department of
Environmental Quality
Alan Matheson
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T. Anderson
Director
MEMORANDUM
File
Allan Moore, Solid Waste Program Manager
Doug Taylor, Environmental Scientist III
June 19, 2018
Liner Damage and liquid wastes at Brennan Bottoms Exploration and Production
Waste Class IIIb Landfill, SW#397 (BBL)
On May 23,2018,I received a voice mail from Richard Powell, Senior Petroleum Specialist, Division of
Oil Gas and Mining (DOGM) concerning damage to the High Density Polyurethane Liner (HDPE) at
the BBL, Uintah County, Utah. Richard is a field hand for DOGM, so he regularly visits the
Exploration and Production disposal sites in Uintah County. He followed his voice mail up with an
email and pictures of the BBL. His email and pictures are attached to this MEMO.
I called Nathan Hall, DEQ's District Engineer for the Basin, and asked him to follow up on the report.
Nathan was able visit the BBL on May 29,2018. He took pictures and sent an email to me verifying
Richard Powell's report. His email and pictures are attached to this MEMO.
When I received Richard Powell's email, I called Jim Nebeker, owner of BBL, to discuss his report. He
doubted the validity of the report, but told me he'd check on it. He called me back the next day to report
that the liner was indeed damaged by one of their employees not operating the equipment properly. He
told me the employee is no longer allowed to run equipment and that they would fix the damaged liner.
Jim also informed me BBL is fabricating large tanks for customers to temporarily place liquid E & P
waste prior to disposing the waste into the landfill. The liquid fraction will be decanted off and sent to
their onsite evaporation ponds while the solid fraction of the waste will be blended with onsite native
soils before it is landfilled.
Jim sent me pictures of the repairs made to the BBL liner and pictures of the tanks to be used at the
landfill. The pictures of the repairs and the new tanks are found at the end of this MEMO.
Jim will send the Division a report of the repairs and tank system.
195 North 1950 West. Salt Lake City, UT
Mailing Address: P.O. Box 144880 . Salt Lake City, UT 84114-4880
Telephone [phone] . Fax [phone]. T.D.D. [phone]
zuww.deq.utah.goo
Printed on IOOVo recycleA paper
Page2
June 2018 Brennan Bottoms Landfill Liner Damage Report
Email and pictures from Richard Powell, Senior Petroleum Specialist,
Division of Oil Gas and Mining
isday 24,2018
During a compliance/I.{OV follow up inspection of this facility Wednesday May 23rd,I observed
numerous large tears and holes in the liner of pond 4. This liner damage has been done with heavy
equipment blades pushing waste into the pond. There are pools of liquid wastes over many of these
large liner tears.
It appears the integrity of this liner has been destroyed along the entire west edge, most of the south edge
and around the northwest corner. It appears this facility's routine practices will continue to create more
damage to the liner and pond integrity.
I am concerned with how the loss of this liner integrity, current practices and pools of liquid wastes over
the liner tears at the edge of this pond may affect the DOGM regulated aspects of the facility.
Attached are numerous pictures. The liner material seen in the pictures is 60 mil HDPE liners used in
the construction of this pond are not liner remnants imported with waste material. Please call with any
questions.
Richard Powell, Operations - Senior Petroleum Specialist, Division of Oil Gas and Mining
East view of the south side of the landfill showing liner damage.
Page 3
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West view of the south side ol-the landfill showing liner danrage .
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West view of the landfill material showing the liquid nature of some of the waste material in the landf ill.
Page 4
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South view of the west side of the landfill showing damage to the liner.
East view of the southwest side of the landfill showing liner damage
Page 5
View south of the south west side of the landfill showins liner damaee
East view of the landfill showing liner material in the foreground and the runny nature of much of the
waste disposed of in the landfill.
Page 6
Damased liner in the landfill
East view of the southeast side of the landfill showing liner damage
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Liner material and liquids in the landfill
Liner material in the landfill
Page 8
East view showing damaged liner
Email and pictures by Nathan Hall, DEQ District Engineer
1sday 29,2018
Doug,
I agree with Richard's assessment. They are dumping material on the side then using a backhoe to push it into the
pond, and it looks like they have ripped the liner in several places between the key trench and where the liner goes
down the bank, then dumped a lot really wet material on top of the ripped areas. So in addition to compromising
the liner for long term storage, there is a good chance some of the oil and other good stuff is making its way down
under the liner.
That brings up my second question - from what I remember you saying last year they are not really supposed to be
handling a lot of liquids in this lined area right? There is still a large pond on the east end, pretty much the same
as when we were there last year.
Here is a Google drive link to the pictures I took today and a couple of video clips of a tanker dumping fairly
liquid waste on the east end. This tanker did offload the wetter material to the blue tanks on the north side, and it
looked like they have been draining the "water" to the produced water cells to the east... but what he dumped into
the pit was still pretty much liquid.
Jim Nebeker has a bit of a reputation of being surprised when he sees some of the things like this that happen
under his name. I'm not sure how often he goes to this facility and he might not be aware of the liner damage.
Also, the area on the southwest corner where most of the damage Richard noticed last week has been covered up
with fresh dirt.
Page 9
The guy that replaced Logan came out and I talked to him, said I'd pass my findings on to you. I did recommend
they slope the grade into the pit on the south side, because as you can see from the pictures it slopes away from
the pit right now... I think they are waiting to hear from you before doing anything about the ripped liner
Not sure if that is what you are looking for? If not let me know.
Cheers,
Nathan D. Hall, P.E. I District Engineer I Uintatr Basin (Tri-County) District
435.247.1167 (office) | 435.630.3352 (cell), 133 Sourh 500 Easr, Vernal, UT 84078
East view
Page 10
Northeast view
Northeast wide angle view of the landfill from the southwest corner of the landfill
Page l1
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Landfill liner in the landfill
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Liner in the landfill
Page 12
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Liquid material in the landfill
Liner repair pictures from Jim Nebeker, BBL Owner
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