re: wy0023248 fourbear unit, battery #1, wypdes permit...

February 17, 2012 Mr. Roland Peterson Wyoming Department of Environmental Quality Water Quality Division 122 West 25th Street, Herschler Building, 4-W Cheyenne, Wyoming 82002

RE: WY0023248 Fourbear Unit, Battery #1, WYPDES Permit Renewal Application Legacy Reserves Operating, LP

Dear Mr. Peterson, Legacy Reserves Operating, LP (Legacy) respectfully submits the enclosed WYPDES renewal application for its WY0023248 Fourbear Unit, Battery #1 oil facility. Enclosed for your consideration are the following:

• WYPDES Permit Renewal Application for Oil and Gas Discharge • MSDS Sheets • Facility Diagram • Permit Application Map

Under this permit, Legacy will pipe produced water from up to eighteen (18) production wells completed in the Dinwoody, Phosphoria, Tensleep, Madison, and Darwin formations. The production stream from the associated wells is piped into the tank battery in a closed-loop-system. The production stream first passes through a header building before being sent to one (1) flow splitter. From the flow splitter, the production stream proceeds to three (3) free-water knockouts (FWKO). From the FWKO’s, the production stream is piped to three (3) heater treaters, which separate the stream into two separate streams. The first stream being produced water that is sent to the 3,000 bbl produced water tank, and the second being oil that is routed to three (3) 400 bbl storage tanks. The produced water from the 3,000 bbl produced water tank is sent to an onsite injection building where water is piped to eighteen (18) active injectors that inject the produced water underground. During extreme upset conditions, produced water from the 3,000 bbl tank overflows to two (2) fenced and netted skimming ponds. From the two (2) skimming ponds the produced water discharges from outfall 001 to an unnamed draw, which then flows to the Greybull River (2AB). Legacy would like to retain the ability to only discharge during extreme upset conditions. If you have any questions, please contact me at (307) 587-7232 or [email protected]; you may also contact Bret Bergstrom of InterTech Environmental & Engineering, LLC at (307) 742-4991 or [email protected].

February 17, 2012 Renewal for Fourbear Unit, Battery #1 WYPDES Permit WY0023248 Legacy Reserves Operating, LP Cover Letter, of 2

Sincerely, Legacy Reserves Operating, LP Scott Bliss Environmental Coordinator /bkb Enclosures cc: Legacy Reserves Operating, LP – File InterTech E&E - File

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SUBMIT ONE HARD COPY AND ONE ELECTRONIC COPY (CD)

FORM C-1

WYOMING POLLUTANT DISCHARGE ELIMINATION SYSTEM APPLICATION FOR PERMIT TO SURFACE DISCHARGE PRODUCED WATER FROM

OIL AND GAS PRODUCTION UNIT DISCHARGES

Revised 11-21-2011 PLEASE PRINT OR TYPE (Submission of illegible materials will results in return of the application to the applicant) 1. The discharging facility will produce:

Oil Oil and natural gas Natural gas Check the box corresponding to the type of application being applied for:

New Permit

Permit Renewal. Permit number WY0023248 Expiration Date: 6/30/2012

Permit Modification. Permit number _____________ Expiration Date: _______________

(For permit modification, please attach letter explaining modifications requested.) 2. Company, Contact Name, mailing address, e-mail address, and telephone number of the individual or company which

owns the facility producing the discharge, and the person (consultant) responsible for permit submission. Company Contact Name Scott Bliss

Consultant Contact Name Bret Bergstrom

Company Name Legacy Reserves Operating, LP

Company Name InterTech Environmental & Engineering, LLC

Mailing Address 1501 Stampede Avenue, 3rd Floor, Suite 3170

Mailing Address 3821 Beech Street

City, State, and Zip Code Cody, WY 82414

City, State, and Zip Code Laramie, WY 82070

Telephone Number 307-587-7232

Telephone Number 307-742-4991

E-Mail Address [email protected]

E-Mail Address [email protected]

Status of applicant as owner, operator or both - Operator Status of applicant as federal, state, private or public - Private 3. Name of the facility (lease, tank battery #, etc.) producing the discharge (this is the facility name that will appear on the WYPDES

permit. It is not necessary to name every well contributing to this facility’s discharge in this section) Fourbear Unit, Battery #1

For Agency Use Only

Application Number WY00_______________

Date Received:

__________________

(mo/day/yr)

WYPDES Renewal ApplicationLegacy Reserves Operating, LP

Fourbear Unit, Battery #1 - WY0023248HUC - 1008000901

February 17, 2012Page 1 of 69

4. Name(s) and mailing address(es) of owner(s) of the surface rights on whose land the discharge occurs (in cases where the land is owned by the state or federal government but surface rights are leased to a private individual, provide lessee’s name and address)

Landowner Name State of Wyoming

Lessee Name Pitchfork Ranch LLC

Mailing Address 122 W. 25th, 3rd Floor West

Mailing Address 36 Rd. 5RU

City, State, and Zip Code Cheyenne, WY 82002

City, State, and Zip Code Meeteetse, WY 82433




5. Provide outfall information in Table 1 below.

TABLE 1. Outfall information

* The mainstem is the closest perennial water (class 2). Stream distance from the outfall to the mainstem should be measured in stream miles versus as “the crow flies”.

Discharge Point

(Outfall) #

Quarter/ Quarter Section Township

Range

Latitude

(NAD 83, decimal degree format,

accuracy to nearest 5 decimal

places)

Longitude

(NAD 83, decimal degree format,

accuracy to nearest 5 decimal places)

Immediate Receiving

Stream

Mainstem*

(Nearest

Perennial

Water)

Distance from outfall to main stem (stream

miles) *

County

001 SESE 20 48 103 44.108395 -109.241653 Unnamed Draw Greybull River 0.4 Park




6. Describe measures to prevent access to the skimming ponds by large grazing animals. Skimming ponds are fenced.

7. Describe control measures (such as installation of flagging or netting) employed to deter waterfowl from landing on the

skimming ponds. Skimming ponds are netted.

8. Attach a description and clear, legible, detailed topographic map of the discharging facility extending one mile beyond the

property boundaries of the source. Include the following:

a. A legend b. Discharge points (outfalls) c. Immediate receiving streams d. Location of nearest downstream irrigator – Not Applicable (Facility is pre-1998) e. Section, Township, and Range information f. Water flow lines (from outfall to receiving water).

9. Attach a site diagram including a schematic line drawing showing the water flow through the facility. Please include:

a. Water flow lines (through treatment system). b. Treater units c. Skimming tanks d. Skimming Ponds e. Stock tanks If any of the above items in 8 or 9 are not applicable please indicate in the description and include a brief explanation as to why the items are not applicable)

10. Describe the control measures that will be implemented to achieve water quality standards and effluent limits. If proposing

to utilize a treatment process, provide a description of the treatment process. Include list of chemicals used and provide a Material Safety Data Sheet (MSDS) for each chemical.

The production stream from the associated wells is piped into the tank battery in a closed-loop-system. The

production stream first passes through a header building before being sent to one (1) flow splitter. From the flow splitter, the production stream proceeds to three (3) free-water knockouts (FWKO). From the FWKO’s, the production stream is piped to three (3) heater treaters, which separate the stream into two separate streams. The first stream being produced water that is sent to the 3,000 bbl produced water tank, and the second being oil that is routed to three (3) 400 bbl storage tanks. The produced water from the 3,000 bbl produced water tank is sent to an onsite injection building where water is piped to eighteen (18) active injectors that inject the produced water underground. During extreme upset conditions, produced water from the 3,000 bbl tank overflows to two (2) fenced and netted skimming ponds. From the two (2) skimming ponds the produced water discharges from outfall 001 to an unnamed draw, which then flows to the Greybull River (2AB).

Below is a list of chemicals that are used to achieve water quality standards, please see attached MSDS sheets for

more detail.

• EC1071A – Corrosion Inhibitor • EC2003A – Demulsifier • EC2007B – Battery and Well Demulsifier • EC2462A – Battery Demulsifier • EC6019A – Water Clarifier

11. Describe the control measures that will be implemented to prevent significant damage to or erosion of the receiving water

channel at the point of discharge. Rip rap and or geotextile is placed at discharge point to prevent erosion.




12. Provide the results of a water analyses for a sample collected from a location representative of the quality of water being proposed for discharge for the parameters listed below, in Table 2.

Not applicable. This facility has been permitted since 1992 to only discharge during emergency upset conditions. No emergency upset conditions have occurred that has required a water analysis to be collected.

The analyses must be conducted in accordance with approved EPA test procedures (40 CFR Part 136). Include a signed

copy of your lab report that includes the following: a. detection limits b. results of each of the chemical parameters at the chemical state given below c. quarter/quarter, section, township and range of the sample collection location d. Time and date of sample collection e. Time and date of analysis for each parameter f. Detection limit for each parameter as achieved by the laboratory.




*The values listed in the Standard or Limit column are associated with water quality standards (Chapter 1 of Wyoming Water Quality Rules and Regulations) or technology-based effluent limits (Chapter 2 of Wyoming Water Quality Rules and Regulations). **This parameter is only required for those discharges located within one stream mile of a class 2AB water.

13. Which geologic formation is the origin of the produced water? Dinwoody, Phosphoria, Tensleep, Madison, Darwin

TABLE 2

PARAMETER

REQUIRED DETECTION LIMIT and Required Units

STANDARD OR LIMIT* SAMPLE RESULTS (Also submit lab results with application)

Aluminum, Dissolved 50 µg/L 750 µg/L Not applicable

Arsenic, Total Recoverable 1 µg/L 150 µg/L Not applicable Barium, Total Recoverable (New Facilities Only)

100 μg/L 2000 µg/L

Not applicable

Boron, Dissolved (New Facilities Only) 100 µg/L 5000 µg/L Not applicable

Cadmium, Dissolved 5 µg/L 0.25 µg/L (hardness dep) Not applicable

Calcium, Dissolved 50 µg/L, report as mg/L Not applicable

Chloride – Technology Based 5 mg/L 2000 mg/L Not applicable

Chloride, For Class 2A and 2B Waters 5 mg/L 230 mg/L Not applicable

Chromium, Dissolved (III) 1µg/L 74.1 µg/L (hardness d d )

Not applicable

Copper, Dissolved 10 µg/L 9 µg/L (hardness d d )

Not applicable

Fluoride, Dissolved (New Facilities Only) 100 µg/L 4,000 µg/L Not applicable

Hardness (CaCO3) mg/L 10 mg/L as CaCO3 (for metals analyses) Not applicable

Iron, Dissolved 50 µg/L 1000 µg/L Not applicable

Iron, Dissolved, for Class 2A and 2AB waters 50 µg/L 300 µg/L Not applicable

Lead, Dissolved 2 µg/L 2.5 µg/L (hardness dep) Not applicable

Magnesium, Dissolved 100 µg/L, report as mg/L Not applicable

Manganese, Dissolved 50 µg/L 1462 µg/L (hardness dep) Not applicable

Manganese, Dissolved, for Class 2A and 2AB t

50 µg/L 50 µg/L Not applicable

Mercury, Dissolved 1 µg/L 0.77 µg/L Not applicable

Molybdenum, Dissolved (New Facilities Only) 100 µg/L 300 µg/L Not applicable

Nickel, Dissolved 10 µg/L 52 µg/L (hardness dep) Not applicable

Oil and Grease 1 mg/L 10 mg/L Not applicable

pH 0.1 pH unit 6.5-9.0 s.u. Not applicable

Radium 226, Total Recoverable 0.2 pCi/L 5 or 60 pCi/L Not applicable

Radium 228, Total Recoverable** 0.2 pCi/L 5 pCi/L Not applicable

Selenium, Total Recoverable 5 µg/L 5 µg/L Not applicable

Silver, Dissolved 3 µg/L 3.4 µg/L (hardness dep) Not applicable

Sodium Adsorption Ratio Calculated as unadjusted ratio Not applicable

Sodium, Dissolved 100 µg/L, report as mg/L Not applicable

Specific Conductance 5 micromhos/cm 7500 micromhos/cm Not applicable

Sulfates 10 mg/L 3000 mg/L Not applicable

Sulfide-Hydrogen Sulfide (S2-, HS-) 50 µg/L 2 µg/L Not applicable

Total Dissolved Solids 5 mg/L 5000 mg/L Not applicable

Total Petroleum Hydrocarbons 1 mg/L Not applicable

Zinc, Dissolved 50 µg/L 118.1 µg/L (hardness dep) Not applicable




14. Were the above analyses collected from this facility (referenced in item 3)?

YES NO

Not applicable. This facility has been permitted since 1992 to only discharge during emergency upset conditions. No emergency upset conditions have occurred that has required a water analysis to be collected.

If no, describe origin of samples including well name, location, depth, geologic formation, field, and date sample was analyzed:

15. For new facilities, provide the expected (estimated) flow rate from each outfall in barrels per day and million gallons per

day, and provide the rationale behind the flow rate estimate. Not applicable, this is an existing facility. For existing facilities, provide actual flow data from each outfall within the last six months. Outfall 001 did not flow within the last six months.

Will discharge be continuous or intermittent?

If the discharge is to be intermittent the following information for each outfall shall be provided: (I) Number of times per year the discharge is to occur. (II) Anticipated duration of each discharge. (III) Anticipated flow of each discharge. (IV) Months in which discharge is expected to occur. Not applicable. This facility has been permitted since 1992 to only discharge during emergency upset conditions. If

discharge does occur, Legacy will immediately notify WDEQ/WQD of the discharge by telephone and provide a written report explaining the situation within seven days of discharge as stated in the 6/18/2007 signed permit

renewal.

16. Are any of the required chemical constituents in the laboratory analysis present in concentrations above Wyoming Water Quality Standards or limits as identified in the third column in Table 2, page 5?

YES NO

This facility has been permitted since 1992 to only discharge during emergency upset conditions. No emergency upset conditions have occurred that has required a water analysis to be collected.

If the answer to question # 16 is yes, answer 16a.–16.c below. If no, proceed to question 17.

a. Which constituents? _________________________________________________________________________ b. Has this constituent been addressed in the response to question 10? _______________________ _____________________________________________________________________________________ c. Describe how the exceedance was addressed. _____________________________________________________

17. Will blending of fresh water with produced water be used as a treatment option? YES NO If the answer to question # 17 is yes, answer 17a.–17.c below. If no, proceed to question 18.

a. What is the anticipated blending rate of fresh water and produced water? ____________________________ Be advised that permit will require water quantity and quality monitoring before and after blending occurs. Also, an automated shutdown system must be installed and maintained on site that terminates the discharge of produced water in the event of the shutdown of the fresh water supply.

b. Provide confirmation from the State Engineer’s office of fresh water use.

c. What is source of fresh water to be blended? No surface water source is allowed.




18. For facilities new after January 1, 1998: Is there active irrigation in the drainage downstream of the discharge? (Please note that this response includes both artificially and naturally irrigated bottomlands.)

Not Applicable (Facility is pre-1998) YES NO

If yes, at a minimum, the WYPDES Program requires submission of the following information:

1. Location(s) of irrigation diversions and/or sub-irrigated acreage; 2. Type(s) of Crops grown under irrigation; 3. Description of Irrigation Practices 4. A topographic map showing irrigated acreage, any structures, ownership of irrigated acreage. In addition to the minimum information described above, the WYPDES Program may require additional information should the permittee request site-specific effluent limits protective of irrigation uses. Contact the WYPDES Program for more information regarding requirements for site-specific SAR, TDS, and EC limits. 19. For facilities new after January 1, 1998: Provide name(s) and address(es) for all downstream irrigators between the

outfalls and the mainstem. Not Applicable (Facility is pre-1998) 20. 40 CFR Part 435 Subpart E requires that the permittee document agricultural and wildlife uses of produced water. Provide

documentation that the produced water will be used for agriculture or wildlife during periods of discharge. Agriculture and wildlife use includes irrigation, livestock watering, wildlife watering, and other agricultural uses. Agricultural and wildlife use documentation includes (but is not limited to) a certified letter from a landowner(s), a formal written statement from a state, federal or local resource management agency, or a formal written statement with supporting documentation from a natural resources or environmental professional accompanied by the credentials of the natural resources or environmental professional. Agriculture and wildlife use documentation must be provided for each outfall included in the application. Agricultural and wildlife certification must be submitted for each outfall’s discharge, and must have original signatures.

Facilities permitted prior to June 10, 2002 are exempt from the above requirement. The Wyoming Game and Fish Department has determined that discharges of produced water from WYPDES-permitted oil production units in Wyoming, existing as of June 10, 2002, are being used to enhance wildlife propagation and habitat.

This facility was WYPDES or NPDES permitted prior to June 10, 2002 Documentation of beneficial use is enclosed

21. Provide a listing of all active permits or construction approvals received or applied for by the applicant for the site described

in this permit application in accordance with Chapter 2, Section 5.(a).(v). T. of the Wyoming Water Quality Rules and Regulations.

This is the only active permit associated with this facility. ___________________________________________________________________________________________




Authorized signatories for this application are the following:

For corporations: A principal executive officer of at least the level of vice president, or the manager of one or more manufacturing, production, or operating facilities, provided the manager is authorized to make management decisions which govern the overall operation of the facility from which the discharge originates.

For partnerships: A general partner.

For a sole proprietorship: The proprietor.

For a municipal, state, federal or other public facility:

Either a principal executive officer or ranking elected official.

I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

_Scott Bliss___________________________________ _Environmental Coordinator___________________ Printed Name of Person Signing Title _____________________________________________ __________________________________________ Signature of Applicant Date _(307) 587-7232_______________________________ _(307) 527-4943_____________________________ Telephone Fax [email protected]___________________________ Email

Section 35-11-901 of Wyoming Statutes provides that: *All permit applications must be signed in accordance with 40 CFR Part 122.22; “for” or “by” signatures are not acceptable. Section 35-11-901 of Wyoming Statutes provides that: Any person who knowingly makes any false statement, representation, or certification in any application ... shall upon conviction be fined not more than $10,000 or imprisoned for not more than one year, or both. Mail this application to: WYPDES Permits Section Department of Environmental Quality/WQD 122 West 25th Street, Herschler Building, 4W Cheyenne, WY 82002 Please include unique footer information on each page of this application and on all supporting documentation using the following format: Company Name: Year/Month/Day/NEW, MOD, RENEWAL/8Digit HUC Code/Permit # (if a modification or renewal) or Application # (from this particular company) for that particular day




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Upper Greybull River1008000901

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Explanation_ Outfall - Constructed

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Fourbear Unit - Battery #1WYPDES Renewal

WY0023248HUC 10 - 1008000901

February 9, 2012

re: wy0023248 fourbear unit, battery #1, wypdes permit...

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