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HomeMy WebLinkAbout1.27 NTC ResponseNTC Response PDC Energy Piceance Centralized Soil Treatment Facility OLSSON ASSOCIATES OA Project No. 011 -2627 760 Horizon Drive, Suite 102 1 Grand Junction, CO 81506 1 TEL 970.263.7800 1 FAX 970.263.7456 O LSSO N ASSOCIATES August 23, 2013 Kathy Eastley Senior Planner Garfield County Community Development Department 108 8th Street, Suite 401 Glenwood Springs, CO 81601 Reference: Piceance Centralized Soil Treatment Facility — MIPA7607 Dear Kathy, Please find attached a copy of our response to your Not Technically Complete (NTC) letter dated July 26, 2013 for the above referenced project. An electronic set of this response has been sent by email. Also included in this package are: • Water Haul Route Map • Updated Site Plan • Signed Geologic and Soils Hazards Report • Signed Noxious Weed Report These items address the issues in the NTC letter. Copies of all this information will be incorporated into the Agency Review copies once a Technically Complete letter is issued. Please contact me if you have any questions. Sincerely, Lorne Prescott Senior Project Scientist Attachments 760 Horizon Drive, Suite 102 Grand Junction, CO 81506 TEL 970.263.7800 FAX 970.263.7456 www.olssonassociates.com O\ OLSSON A S S O C I A T E S Piceance Centralized Soil Treatment Facility Not Technically Complete Response Reference: Piceance Centralized Soil Treatment Facility- MIPA7607 In response to the Not Technically Complete Letter dated July 26, 2013, Olsson Associates submits the following information on behalf of PDC Energy /Caerus Piceance LLC. 1. Pursuant to Table 4 -201, a Water Supply Plan is a submittal requirement. The request for waiver from Section 7 -104 does not release you from this submittal requirement. This Substitute Water Supply Plan is but one component of the Water Supply Plan which shall include the following information: a. The representation is that the proposed facility will only have workers onsite "occasionally ", also described as proposed intermittent use. Please provide the following specific information related to this issue: i. How many workers will there be? Response: One to three workers will be onsite during the delivery and /or treatment of the impacted soils. ii. How many hours per day, days per week, etc.? Response: Time onsite will vary according to the scope of what is required to accommodate delivery, treatment and transport for beneficial reuse. This could range from 2 to 8 hours per day. Typical operations will be for 1 or 2 days twice a month. iii. Will these workers have access to drinking water and sanitary facilities? If on site, where /how? If off -site, where /how? Response: A source of potable water will not be required for workers utilizing the site. This facility is not manned on a regular basis and does not require a water distribution and wastewater system to properly function. Workers will provide their own potable water in their trucks. Potable water is made available at the applicant's local office for personnel and contractors. A source of water is not required for the operation of the facility. Portable toilets located throughout the applicant's holdings will be used to accommodate staff and contractors. All wastes will be hauled to a licensed treatment facility. b. Water Hauling for treatment: i. How many trucks will be required for hauling? Response: One (1) truck will typically be used for hauling water to and from the site. 760 Horizon Drive, Suite 102 Grand Junction, CO 81506 TEL 970.263.7800 FAX 970.263.7456 www.olssonassociates.com PDC Energy Inc /Caerus Piceance LLC Piceance Centralized Soil Treatment Facility ii. At what point along Parachute Creek will water be drawn from? Response: From the Chevron Water Draw, Garfield County Permit LIPA -7533 iii. What route will they use to get to the project site? Response: Please see the attached map. iv. How many trips per day? Response: One trip per day. Please see the traffic analysis that accompanies the original application submittal for additional information. 2. What documentation is provided in support of the statement that "Operation of the facility will not exceed the Rural Zone standards established by the Colorado Oil and Gas Conservation Commission (COGCC) and Colorado Noise Statute requirements. "? A noise analysis or machinery specifications are required to demonstrate that the facility will operate within acceptable levels pursuant to the C.R.S. requirements. Response: No permanent machinery will be operated at the site. During typical operations the only sound emissions will be from a tractor used to amend /mix the soils. 3. A 'site plan' is required in compliance with Section 4 -203 (D), and although the Individual requirements may occur within the submittal documentation we do need one document that meets these requirements. See code section for all requirements. Response: An updated Site Plan that fully accommodates the code requirements is attached to this submittal. 4. Section 4 -203 (A) requires that preparation and certification of certain documents is required; please update plans and reports with signatures of the preparer and certification stamps, as applicable. For example, the Geologic and Soils Hazard Report should be signed by the preparer and stamped as a certified engineer or geologist and the preparer of the noxious weed plan should also be signed. Response: Copies of the appropriate signed disclosure documents are attached to this submittal. 5. We understand that a State Highway Access Permit is required to assure legal access to the site and the certain physical improvements are necessary as well. The pending exemption application may resolve these issues which will be further discussed through the review process. Response: The above statement ( #5) is correct. 6. Please add information to the project description that discusses the lining or other treatment of the remediation cell(s) Response: No lining or additional remediation of the soils is planned for the proposed project. All remediation activities are detailed in the Project description, NTC Response Page 2 PDC Energy Inc /Caerus Piceance LLC Piceance Centralized Soil Treatment Facility Operational Plans and adhere fully to COGCC permitting requirements. The geologic and hydrologic investigation conducted for this project (and required as part of the COGCC permit approval process) has assessed the permeability of the subsurface soils and determined a liner is not required. Please see the Geologic and Hydrologic Report accompanying the original submittal for additional information. 7. Please provide a list of the air quality permits that will be required for a facility of this type, the project description mentions obtaining the appropriate permits but does not indicate what they are. Response: A single air quality permit will be secured from CDPHE to accommodate operation of the facility. This permit will assess the potential VOC emissions and assign limits to the proposed soil treatment process. This facility will not cause air quality to be reduced below acceptable levels established by the Colorado Air Pollution Control Division (CAPCD) of the CDPHE and will comply with appropriate Colorado air emissions permitting regulations (as applicable). The AQ permit is currently in draft form. A copy of the approved permit will be provided to the county prior to commencement of operational activities. NTC Response Page 3 PDC Energy Inc /Caerus Piceance LLC Piceance Centralized Soil Treatment Facility THIS PAGE LEFT BLANK FOR TWO -SIDED DUPLICATION. NTC Response Page 4