Union Pacific Railroad well, pollution update
December 13, 2016
At the Dec. 6 BOCC (Board of County Commissioners) meeting, Grand County Water Quality Specialist Katherine Morris gave an update on the meeting that was held between the EPA (Environmental Protection Agency), participants from Grand County, CDPHE (Colorado Department of Public Health and Environment), UPRR (Union Pacific Railroad), CDM Smith (UPRR's consultant), Winter Park Ranch and HRS Water Consultants, Inc. on November 21. The meeting was to address the Class V injection well permitting process regarding the permit that will be submitted by the UPRR for a well near the Moffat Tunnel.
According to the EPA website, a Class V well uses injection techniques different from those used by wells in other classes. Some Class V wells are technologically advanced disposal systems, but most are low-tech holes in the ground. A typical Class V well is shallow and relies on gravity to drain or inject waste into the ground, which is often directly into, or above, an underground source of drinking water. Class V wells are used to inject non-hazardous fluids underground. Most are used to dispose of waste into or above underground sources of drinking water. This disposal can pose a threat to ground water quality if not managed properly.Examples of simple class V wells are dry wells, cesspools, and septic system leach fields.
According to the update submitted by Morris, UPRR representatives described the treatment plant process at the meeting.
The plant would treat and return 95 percent of the contaminated groundwater issuing from the tunnel and return it, clean, to the Fraser River. The remaining five percent of flows (approximately 1,728 gallons per day) would be destined for the injection well. There are three components to this flow: sanitary waste; "clean in place" flows, consisting of the neutralized rinsate (a mixture of pesticides diluted by water, solvents, oils, commercial rinsing agents or any other substances, according to the EPA website) from membrane cleaning; and centrate from centrifuge flows—the majority of the flow. Solids and uranium removed by centrifugation and other treatment processes will be removed by truck to an appropriate location, according to the update. Grand County shared their concerns with the EPA stating that the plant was designed to treat only metals and total suspended solids (TSS), but the current discharge permit only recognizes TSS and metals as contaminants. According to Morris, Grand County does not know what will be the fate of the organic pollution that will also be in the discharge during annual tunnel cleaning operations, which is what caused the pollution found in September. Morris said the EPA assured them that if there is a demonstrated reason for putting permit requirements for organics on the injection well, they would do so.
Morris pointed out that the injection well has already been built well in advance of receiving any permit approval, which was disclosed at the meeting.
The County provided photographs of discharge from the UPRR pollution incident. Some of the photos dated back to August 2015. UPRR will be required to test on a monthly basis for diesel range organics and total petroleum hydrocarbons, and will be required to utilize best management practices (BMPs) to control sediment during tunnel cleaning activities. The permit will not require testing for semi‐volatile organic carbons, nor will the UPRR be required to use time monitoring to coincide with annual tunnel cleaning operations. Morris said Grand County was commended for their active participation in the public process for permitting.
On Sept. 29 the Sky-Hi News was tipped off about polluted water being discharged into the Fraser River. The pollution appeared to be derived from annual maintenance work conducted by the Union Pacific Railroad (UPRR) within the Moffat Tunnel.
At the Dec. 6 BOCC meeting, Lurline Underbrink-Curran, a contract employee for Grand County overseeing much of the County's efforts on water issues, briefly discussed the fate of the pollution issue.
The Grand County Learning By Doing (LBD) Cooperative Effort, a partnership of East and West slope water stakeholders in Colorado, discussed the pollution during their last meeting.
According to Underbrink-Curran the meeting was focused on reports on the UPRR violation, beaver issues in Ranch Creek, monitoring and direction on an operations plan for 2017. Representatives from the Water Quality Control Commission were present to report on compliance as well as possible fines that may be imposed on UPRR. If fines are applied, there is a possibility that some of the funds could come to LBD. LBD was asked for possible projects that the funds could be used for.