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HomeMy WebLinkAbout3.0 Staff report BOCC 02.04.2013Board of County Commissioners, February 4,2013 Public Hearina Exhibits -Encana Divide Road Produced Water Facilitv Exhibit Exhibit Letter fA to Zl A Public notice documents including Publication and Mail Receipts B Garfield County Unified Land Use Resolution of2008, as amended C Garfield County Comprehensive Plan 2030, as amended D Application E Staff Report F Staff Presentation G ResDonse from Sheriff's Office dated December 18, 2012 H Letter dated December 20,2012 from Rob Ferguson, Grand Valley FPD I Email dated Januarv 10,2013 from Morgan Hill, Environmental Health"-f) J Letter dated Januarv 11, 2013 from Chris Hale, Mountain Cross Engineering K Letter dated Januarv 15, 2013 from Steve Anthonv, Vegetation Management L Response to ULUR Standards -received Januarv 24, 2013 M Letter dated Januarv 25, 2013 and proposed layout plan from River City Consultants N Emails dated Januarv 25,2013 regarding site changes 0 Email dated Januarv 28,2013 from Chris Hale, Mountain Cross Engineering p 3--0 Board of County Commissioners February 4, 2013 KE PROJECT INFORMATION AND STAFF COMMENTS -DIVIDE ROAD PWF REQUEST PROPERTY OWNER REPRESENTATIVE LOCATION PARCEL I PROJECT SIZE ACCESS ZONING COMPREHENSIVE PLAN Limited Impact Review -Material Handling, Water Storage Tanks Encana Oil & Gas (USA), Inc. Craig Richardson , Olsson Associates Section 26, Township 4South, Range 96 West PIN 1917-274-00-012 15,800-acres I 24.4-acres CR 215 to private road system Resource Lands -Plateau Agricultural Production I Natural I. GENERAL PROJECT DESCRIPTION Encana Oil & Gas (USA), Inc. proposes to install a 'produced water facility', to be known as the Divide Road Produced Water Facility, on a portion of a parcel located just south of the Rio Blanco County border, approximately 19 miles north of the Town of Parachute. The intent of the facility is to allow for a centralized storage area for produced water generated during the production of gas from well in the North Piceance plateau area. This water will then be recycled for delivery to hydraulic fracturing and completion operations on the plateau. Design and operation of this facility requires the following improvements on 24.4.-acres: • Five (5) 206,000 BBL Storage Tanks; • Two (2) 20,000 BBL Off-load Tanks; • Two (2) 6,000 BBL Condensate Tanks; • Vapor Recovery Unit; • Three ~phase Separator; • Dissolved Air Flotation System • Four Natural Gas Generators. The facility will function with the delivery of water routed through the three-phase separator to extract any water or oil condensate, with the water then transported to two 20,000 BBL off-load tanks and the condensate transported to two 6,000 BBL tanks where the flash gas will be recovered via a vapor recovery unit and sent to the gas gathering pipeline for transport. The produced water will then be stored until needed in completion operations. Some of the water transported to the site will require additional treatment whereby the fluids will be run from the Encana Divide Road PWF BOCC February 4, 2013 off-load tanks to a Dissolved Air Flotation System (OAF) which allows for skimming of the surface to remove suspended solids, oils and grease and other impurities. The storage tanks will be installed in concrete containment walls and the ground will be lined to provide secondary containment. Two structures are planned to contain equipment such as the generators, OAF and control systems. A majority of the produced water will be transported to the facility via an existing pipeline network, however the Applicant is also requesting allowance for delivery of fluids via trucks. The request for hauling of water to the site is an emergency contingency in the event that it is needed. However the overall intent of the request is to minimize truck traffic that would be required to transport the produced water to existing E&P Waste Facilities that lie outside of the plateau. Maintaining and storing the water for reuse will allow the water to be recycled rather than transported for disposal. All surface use agreements and pipelines are currently in place. The uses which require County review and approval include: A. Water Tanks or Treatment Facility -Storage of water in excess of 50,000 gallons -the Applicant proposes storage of greater than 1 million barrels -±43 million gallons -of produced water on the site. B. Material Handling -for the general activity of treating and separating fluids at this centralized facility. Applicant proposes to provide hauled potable water and a vault and haul system for sanitation. Though the facility is designed to function with minimal manual operations some monitoring will occur on a daily basis during daylight hours. The site will not have permanent personnel stationed at the facility. The Applicant is seeking waiver of standard for Landscaping (Section 7-305) and Roadway Standards (Section 7-308). II. LOCATION AND SITE DESCRIPTION This parcel has significant oil and gas activities within the acres, Land and Use occurring 15,800-several Change Permits have been issued by the County related to those uses. The facility is located adjacent to CR 401 , an area which is characterized by high plateaus, mesas, 2 Encana Divide Road PWF BOCC February 4, 2013 ridges and deep valleys. The site is located at an elevation between 8,261 and 8,286 feet. III. ZONING AND ADJACENT USES The subject parcel is wholly contained within the Resource Land -Plateau zone district as shown below. Public lands do occur in the vicinity however the adjacent uses are primarily oil and gas related. No homes exist within a mile of the proposed facility. IV. REFERRAL AGENCIES Comments have been requested from the following agencies and comments received are integrated throughout this report as applicable. 1. Road and Bridge: No Comment Received 2. Sheriff: EXHIBIT G 3. Vegetation Management: EXHIBIT K 4. Environmental Health: EXHIBIT I 5. Mountain Cross Engineering (on behalf of the County): EXHIBIT J 6. Colorado Division of Wildlife: No response 7. Colorado Department of Public Health and Environment: No response 8. Grand Valley Fire Protection District: EXHIBIT H 9. Rio Blanco County: Phone conversation 10. BLM: No Comment Received V. REVIEW STANDARDS & STAFF COMMENTS 3 Encana Divide Road PWF BOCC February 4,2013 Limited Impact reviews are required to adequately address Section 4-502(G) Impact Analysis, the general development standards found in Article VII with specific attention to Division 11. Additional Standards for Industrial Uses as codified in the Garfield County Unified Land Use Resolution of 2008, as amended (ULUR). The following section provides a review of those standards in bold italics followed by a Staff Comment. A. Section 4-203 G. IMPACT ANALYSIS Where the proposed Development will impact specific features of the site, the Applicant shall describe both the existing conditions and the potential changes created by the project. The Impact Analysis shall include a complete description of how the Applicant will ensure that impacts will be mitigated and standards will be satisfied. The following information shall be included in the Impact Analysis: 1. Adjacent Property. An address list of real property adjacent to the subject property, and the mailing address for each of the property owners. Staff Comment: This information was provided in the application. 2. Adjacent Land Use. Existing use of adjacent property and neighboring properties within 1,500-foot radius. Staff Comment: BLM lands do occur in areas adjacent to the parcel however the use of this parcel and significant portions of the surrounding land is utilized for natural gas extraction activities. 3. Site Features. A description of site features such as streams, areas subject to flooding, lakes, high ground water areas, topography, vegetative cover, climatology, and other features that may aid in the evaluation of the proposed Development. Staff Comment: Native vegetation in the vicinity of the facility includes rabbitbrush and greasewood with an understory of mixed native and non-native grasses and forbs. Aspen and Pinyon-Juniper woodlands are also present in the area. The proposed project area is located on a ridge-top where terrain is relatively flat and minimal flooding hazard exists. Ground water testing, though seasonally variable in this region, was not found to pose a hazard for this facility. 4. Soil Characteristics. A description of soil characteristics of the site that have a significant influence on the proposed use of the land. Staff Comment: Soils, as indicated in the National Resources Conservation Service (NRCS) Soil Survey include the Parachute-Rhone loams soil designation. An analysis of these soils was completed by Olsson Associates with a focus on the potential for corrosive soils, with a corrosion rate of steel being moderate in this area. 5. Geology and Hazard. A description of the geologic characteristics of the area including any potential natural or manmade hazards, and a determination of what effect such factors would have on the proposed use of the land. Staff Comment: A Geologic Hazards Report, prepared by an Associate Geologist with 4 Encana Divide Road PWF BOCC Februa ry 4, 2013 Olsson Associates concludes that the use of stormwater controls and best management practices can be used to divert stormwater area from the construction areas to prevent debris flow or landslide. 6. Groundwater and Aquifer Recharge Areas. Evaluation of the relationship of the subject parcel to Floodplains, the nature of soils and subsoils and their ability to adequately support waste disposal, the Slope of the land, the effect of sewage effluents, and the pollution of surface runoff, stream flow, and groundwater. Staff Comment: The facility will be designed with adequate controls for stormwater management and drainage. Encana's Stormwater Management Plan, Drainage Report and Erosion Control Plans all function to protect surface runoff and groundwater. 7. Environmental Impacts. Determination of the existing environmental conditions on the parcel to be developed and the effects of development on those conditions, including: a. Determination of the long-term and short-term effect on flora and fauna; b. Determination of the effect on significant archaeological, cultural, paleontological, and historic resources; c. Determination of the effect on designated environmental resources, including critical Wildlife Habitat; d. Impacts on Wildlife and domestic animals through creation of hazardous attractions, alteration of existing native vegetation, blockade of migration routes, use patterns, or other disruptions; e. Evaluation of any potential radiation hazard that may have been identified by the State or County Health Departments; and f. Spill prevention control and counter measures plan, if applicable. Staff Comment: Approximately 11.76 aces of native vegetation will be removed for construction of this facility however no threatened, endangered, sensitive species (TESS) will be impacted. Existing wildlife in the area includes Greater Sage-grouse, raptors, elk and mule deer, as well as bear and mountain lions. Impacts or effects on flora and fauna include potential for creation of hazardous attractions, alteration of vegetation, impact to elk production area and deer and elk overall range, bird nesting habitat, vehicle collision, and impact from construction related nuisances. Flattops Archaeological Consultants prepared a Class 1 Cultural Resource Study which resulted in a finding of no historic properties affected. Information within the submittal materials discusses spill prevention and secondary containment measures sized to contain 110% of the fluids on the site. Lining of facilities is also proposed. Chris Hale, reviewing engineer, has responded to the referral (EXHIBIT J) with a statement that a site-specific Spill Prevention, Control and Countermeasure Plan (SPCC) was not provided and that secondary containment 5 En cana Divide Road PWF BOCC February 4, 2013 requirements and verification of the sizing would be expected. Staff has since verified that information submitted is sufficient until such time as amendment to the SPCC occurs -this cannot be completed until the facility is constructed. Staff recommends a condition that, once completed, a copy of the site specific addition to the SPCC be provided to the County Planning Division. 8. Nuisance. Impacts on adjacent land from generation of vapor, dust, smoke, noise, glare or vibration, or other emanations. Staff Comment: The size of the parcel, 15-800 acres, and the location of the facility within that parcel minimizes potential impact to adjacent land. A fugitive dust plan is included in the application and staff recommends a condition to assure ongoing mitigation. 9. Reclamation Plan. A reclamation plan consistent with the standards in Section 7-212. Staff Comment: The applicant has included potential reclamation measures that will occur upon ceasing activity at the site. The anticipated life of this facility is 20 years or greater and, as a COGCC-approved E&P Waste Facility, the reclamation would be included in blanket bond from Encana that is held by the COGCC. The County typically does not hold security for 'permanent' facilities where surety is held by a state agency. The County does require a bond to assure that revegetation measures, postconstruction, are completed . Encana has submitted a bond in the amount of $14,750.00 for 5.9 acres of revegetation to the site. B. Section 7-100 GENERAL APPROVAL STANDARDS 1. Section 7-101 Compliance with Zone District Use Restrictions Staff Comment: The Resource Lands -Plateau zone district permits these proposed uses through the review and approval by the Board of County Commissioners. 2. Section 7-102 Compliance with Comprehensive Plan and Intergovernmental Agreements Staff Comment: As the map below indicates, the Future Land Use Map designation for the site is Agricultural Production I Natural. Open Spacel Public Land is designated on adjacent public land. Rio Blanco County was sent a request for review and comment related to potential impacts of the proposed use and in a phone conversation with Anna Smith, 6 Encana Divide Road PWF BOCC February 4, 2013 County Planner, it was requested that if heavy equipment were to utilize Rio Blanco County Roads that a 'Transport Permit' be obtained from Rio Blanco Road and Bridge. Staff recommends the addition of this condition. 3. Section 7-103 Compatibility Staff Comment: The Piceance Basin area experiences significant oil and gas activity and this parcel or area is no exception. As stated earlier the County has reviewed other O&G-related activities and issued permits for those uses. 4. Section 7-104 Sufficient Adequate, Legal and Physical Source of Water Staff Comment: The water produced is from the Williams 1.. Fork Formation. No full time ;-.-g ..... -c .~ /""X :.:r--on-site employees are planned I however intermittent review of 'I the site will occur. A vault and J haul system is proposed to .r-~-7c,:/j serve the needs of this facility. 5. Section 7-105 Adequate Central Water /~ )'" 0 '" L-'V! --~' j .~I(. Distribution and Wastewater Systems fi Staff Comment: Not applicable. 6. Section 7-106 Adequate Public Utilities Staff Comment: Adequate utilities, in the form of natural gas driven electric generators, are proposed to supply power. Fuel gas, instrument air and other control systems will be utilized however no public utilities are available to the site. 7. Section 7-107 Access and Roadways Staff Comments: The Applicant seeks a waiver of compliance with the minimum road standards in the ULUR. This road system, past the terminus of CR 215, occurs on 7 Encana Divide Road PWF BOCC February 4, 2D13 private land for which a reciprocal use agreement exists. The road has been used for significant 0 & G activity and historically has functioned properly. 8. Section 7-108 No Significant Risk from Natural Hazards Staff Comments: Yeh and Associates has completed a geotechnical investigation of the site as well as Olsson Associates having completed a a Geologic Soil Hazards report. Neither reported any existing significant risk. C. Section 7-200 GENERAL RESOURCE PROTECTION STANDARDS 1. Section 7-201 Agricultural Lands Staff Comment: No significant Agricultural lands are mapped in this area. 2. Section 7-202 Wildlife Habitat Areas Staff Comment: WestWater Engineering (WWE) completed an analysis of the project site and had no site-specific recommendations necessary to mitigate potential impacts, other than the standard comments regarding preservation of native vegetation and treatment of noxious weeds. 3. Section 7-203 Protection of Wetlands and Waterbodies Staff Comment: No wetlands or waterbodies are found within the project area. 4. Section 7-204 Water Quality from Pollutants Staff Comment: Encana's Stormwater Management Plan, Drainage Report and Erosion Control all require the use of Best Management Practices which provide adequate protection from potential pollutants. 5. Section 7-205 Erosion and Sedimentation 8 Encana Divide Road PWF BOCC February 4, 2013 Staff Comment: Sufficient measures have been proposed to protect the area during construction. The Stormwater Management Plan will be expanded to include this facility. 6. Section 7-206 Drainage Staff Comment: River City Consultants prepared a Drainage Report for the facility which evaluated existing and proposed drainage conditions at the site. It is important to note that the location of the proposed facility is at the apex of a ridgeline and requires significant earthwork to prepare the site. The Engineer states that the site receives no off-site flows. Drainage improvements will include earthen ditches, culvers, sediment ponds and temporary BMP's. Water quality will be protected by revegetation, check dams in the ditches, sediment basins, level spreader and surface stabilization. 7. Section 7-207 Storm water Run-Off Staff Comment: Run-off has been addressed in area-wide Stormwater Management Plan (SWMP) applicable to all of Encana's facilities, as well as in the Drainage Report. The latter states that there is likely exposure of high runoff potential however the design, including two sediment/detention ponds, ditches and culverts will adequately address these issues. Morgan Hill form Environmental Health has reviewed the proposal and provided comment (EXHIBIT I) that the County requests notification if groundwater monitoring wells are required at this location. Staff recommends a condition of approval to this effect. 8. Section 7-208 Air Quality 9 Encana Divide Road PWF BOCC February 4, 2013 Staff Comment: Air quality permits apparently exist for the generators that will be located on the site however the facility may be required to obtain an Air Pollution Emission Notice (APEN) which will be determined upon review of the operation. The significant amount of stored water may release VOC's and create odors. A Fugitive Dust Plan was provided as access to the site is via gravel roads. Air quality issues can arise if mitigation measures are not instituted. A plan to minimize emissions from dust focuses on identifying sources, control for unpaved roads, control for disturbed areas, control for transport, storage and handling of bulk materials and a contingency plan for alternative action. 9. Section 7-209 Areas Subject to Wildfire Hazards Staff Comment: The area is designated as a low to moderate wildfire hazard. Encana has submitted a copy of the emergency management plans that would be applicable to this site. 10. Section 7-210 Areas Subject to Natural Hazards and Geologic Hazards Staff Comment: Though steep slopes exist on the plateau the location of the proposed facility is on a ridgetop and therefore fairly level. The construction of the facility does require significant earthwork, including 122,388 cubic yards of cut and 120,695 cubic yards of fill. No other hazards were identified that would impact this facility. 11. Section 7-211 Areas with Archeological, Paleontological or Historical Importance Staff Comment: A Class I Cultural Study was completed by Flattops Archeological Consultants and a finding of "no historic properties affected" was included in the report. 12. Section 7-212 Reclamation Staff Comment: This facility is proposed to function for at least 20 years and therefore is considered a 'permanent' facility. Encana has a blanket bond with the COGCC who will review and potentially issue a permit for an E&P Waste Facility. The site reclamation is therefore under the purview of the COGCC who will apply the Encana bond to this site for collateral regarding future reclamation. The Applicant has provided a bond for revegetation purposes post-construction. D. Section 7-300 PLANNING & DEVELOPMENT STANDARDS 10 Encana Divide Road PWF BOCC February 4, 2013 1. Section 7-301 Compatible Design Staff Comment: The design of the facility is compatible with other Oil & Gas facilities in the area. 2. Section 7-302 Building Design Staff Comment: Two structures are proposed to be located at this site, however building design does not appear to be applicable to this facility, 3. Section 7-303 Design and Scale of Development Staff comment: Not applicable. 4. Section 7-304 Off-street Parking and Loading Staff Comment: The site plan indicates one that sufficient parking and loading has been provided. 5. Section 7-305 Landscaping Staff Comment: The Applicant has requested waiver from this standard due to the location, project size and anticipated impact. 6. Section 7·306 Lighting Staff Comment: The site proposes to utilize lighting necessary to meet minimum safety standards. Any lighting utilized will meet the County requirements for downcast and shielded lighting sources. 7. Section 7·307 Snow Storage Staff Comment: Adequate area for snow storage exists on the site. 8. Section 7·308 Roadways Staff Comment: The Applicant is requesting waiver of the minimum roadway standards contained in the ULUR. County Road 215 access terminates several miles south of this facility and an existing private roadway system is 11 Encana Divide Road PWF BOCC February 4, 2013 utilized. An existing agreement between the surface owners of the roadway allows for reciprocal use of the road. The width, grade and other components of the road appear to be sufficient as Divide Road is the sole access for a significant area utilized for Oil & Gas activities. Section 7-309 Trail and Walkways Staff Comment: Not applicable. 9. Section 7-310 Utilities Staff Comment: There are no public utilities available to this site however the facility will have four natural gas generators for electricity and a vault and haul system will be utilized for water and wastewater to serve the transient employees who may be at this site. E. Section 7-1100 ADDITIONAL STANDARDS FOR INDUSTRIAL USES 1. Section 7-1101 Industrial Use a. Residential Subdivisions. Industrial Uses shall not occupy a lot in a platted residential Subdivision. Staff Comment: This facility is not located within a subdivision. b. Setbacks. All activity associated with these uses shall be a minimum of 100 feet from an adjacent residential property line, unless the use is on an industrially zoned property. Staff Comment: The facility is not located within 100 feet of an adjacent residential property line. c. Concealing and Screening. All storage facilities, including outdoor storage, fabrication, service, and repair operations shall be conducted within an enclosed building or have adequate provision to conceal and screen the facility and/or operations from adjacent property(s). Screening shall be at least 8 feet in height and obscure the facility and/or operation from view at the same elevation. All screening shall be maintained. Staff Comment: The facility is not visible from adjacent properties. d. Loading and Unloading. All operations involving loading and unloading of vehicles shall be conducted on private property and shall not be conducted on a public right-of-way. Staff Comment: There is no adjacent public right-of-way. 12 e. Storing. Encana Divide Road PWF BOCC February 4, 2013 All products shall be stored in compliance with all national, State and local codes and shall be a minimum of 100 feet from an adjacent property line. In addition, petroleum, and hazardous products shall be stored in an impervious spill containment area(s). Staff Comment: The facility meets these requirements. f. Hours of Operation. Any activity that will generate noise, odors, or glare beyond the property boundaries will be conducted between the hours of 7:00 a.m. to 7:00 p.m. Monday through Saturday, or as approved by the decision-making authority. Staff Comment: This is an unmanned facility that operates continuously and there will be no activity that will exceed the property boundaries. g. Industrial Wastes. All industrial wastes shall be disposed of in a manner consistent with Federal and State statutes and requirements of CDPHE. Staff Comment: A general condition of approval is applied that the site must comply with all federal, state and local regulations. h. Noise. Noise shall not exceed State noise standards pursuant to C.R.S., Article 12, Title 25, as amended, unless the use is regulated by the COGCC. In this case, the use shall be subject to COGCC Rule 802, Noise Abatement. Staff Comment: This use is regulated by the COGCC and therefore is subject to the rules of that agency. i. Ground Vibration. Every use shall be operated so that the ground vibration inherently and recurrently generated is not perceptible without instruments at any point of any boundary line of the property. Staff Comment: Ground vibration will not be perceptible at the boundary line of the property. j. Interference, Nuisance, or Hazard. Every use shall be so operated that it does not emit heat, glare, radiation, or fumes which substantially interfere with the existing use of adjoining property or which constitutes a public nuisance or hazard. Flaring of gases, aircraft warning signal, and reflective painting of storage tanks, or other legal requirements for safety or air pollution control measures shall be exempted from this provision. Staff Comment: Adjoining property use is related to Oil & Gas extraction activities and it does not appear that this facility will interfere with those uses. 13 Encana Divide Road PWF BOCC Februa ry 4, 2013 VI. STAFF DISCUSSION A. Site Plan Revision -The Applicant has submitted a site plan revision that has not been reviewed by planning staff as of the date of completion of this staff report. See Exhibit M and N. B. Request for Waivers -The following waivers are requested from the minimum standards required by Article VII of the ULUR: 1. Landscaping -The Applicant has requested waiver from this standard due to the location, project size and anticipated impact. A reclamation plan, revegetation plan and a Weed Management Plan were prepared for this facility. 2. Roadway -This road system, past the terminus of CR 215, occurs on private land for which a reciprocal use agreement exists. The road has been used for significant 0 & G activity and historically has functioned properly. VII. SUGGESTED FINDINGS Should the BOCC decide to approve the request for the Divide Road Produced Water Facility, Staff suggests the following findings: 1. That proper public notice was provided as required for the hearing before the Board of County Commissioners. 2. That the hearing before the Board of County Commissioners was extensive and complete, that all pertinent facts, matters and issues were submitted or could be submitted and that all interested parties were heard at that meeting. 3. That for the above stated and other reasons, the Land Use Change Permit for "Water Storage Tanks and Treatment" and "Material Handling" is in the best interest of the health, safety, convenience, order, prosperity and welfare of the citizens of Garfield County if recommended conditions of approval are required. 4. That, upon compliance with conditions of approval, the application is in general conformance with the Comprehensive Plan 2030, as amended. 5. That, upon granting of waiver(s) of Section 7-305 and 7-308 (regarding Landscaping Standards and Roads Standards) and upon compliance with conditions of approval, the application is in conformance with Garfield County Unified Land Use Resolution of 2008, as amended. VIII. BOARD CONSIDERATION The Board has several options regarding the review of this application including approving the request, approving the request with conditions, denying the request or continuing the public hearing for acquisition of additional information. 14 Encana Divide Road PWF BOCC February 4, 2013 Should the Board of County Commissioners approve the request for a Land Use Change Permit for the Divide Road Produced Water Facility -including the use of water tanks and material handling, staff would recommend consideration of the following conditions: 1. All representations made by the Applicant in the application, and at the public hearing before the Board of County Commissioners, shall be conditions of approval, unless specifically altered by the Board of County Commissioners; 2. The operation of the facility be done in accordance with all applicable Federal, State, and local regulations governing the operation of this type of facility; 3. The facility shall comply with the fire protection provisions included in the rules and regulations of the Colorado Oil and Gas Conservation Commission (COGCC) and the International Fire Code as the Code pertains to the operation of this facility. 4. Any transportation of heavy equipment on Rio Blanco County roads will require that the Applicant obtain a Rio Blanco County Road and Bridge Department "Transport Permit". 5. Industrial activities shall be required to comply with the following standards: A. All products shall be stored in compliance with all national, State and local codes and shall be a minimum of 100 feet from an adjacent property line. In addition, petroleum, and hazardous products shall be stored in an impervious spill containment area(s). B. All industrial wastes shall be disposed of in a manner consistent with Federal and State statutes and requirements of CDPHE. C. Noise shall not exceed State noise standards pursuant to C.R.S., Article 12, Title 25, as amended, unless the use is regulated by the COGCC. D. Every use shall be operated so that the ground vibration inherently and recurrently generated is not perceptible without instruments at any point of any boundary line of the property. E. Every use shall be so operated that it does not emit heat, glare, radiation, or fumes which substantially interfere with the existing use of adjoining property or which constitutes a public nuisance or hazard. Flaring of gases, aircraft warning signal, and reflective painting of storage tanks, or other legal requirements for safety or air pollution control measures shall be exempted from this provision. AIR QUALITY 6. Mitigation shall be performed on the site and access roads to prevent fugitive dust. 7. The Applicant shall provide notification to Garfield County that the facility has met all CDPHE air quality emission control notice and permitting requirements. WATER QUALITY 8. A site specific Spill Prevention Control and Countermeasures Plan shall be submitted 15 Encana Divide Road PWF BOCC February 4, 2013 to Garfield County which included secondary containment requirements and verification of sizing. 9. The County Environmental Health Department shall be notified if the COGCC requires monitoring wells at this location; 10. Existing ditches, berms, culverts, and sediment traps as indicated on the site plan must be properly utilized and maintained for the life of the facility. 16 Date Sent: December 14, 2012 Return n, ..lan.u 11 ')011 Garfield County Building and Planning Department &-jl 108 8th Street, Suite 40 I, Glenwood Springs, CO 8160 I II (970) 945-82 12IFax: (970) 384-3470 File" , w(.\ Project l"L (s) Type of Annl LlPA7368 Encana Produced Water Facility Limited Impact Staff Planner: Kathy Eastiey (keastlex@garfield-coun!'y.com) Phone: 970-945-1 377 x 1580 Applicant: Encana Oil & Gas (USA), Inc. Phone: Contact Person: Craig Richardson -Olsson Associates Phone: 970-263-7800 Location: South of Garfield/Rio Blanco County line -16 miles north of Parachute Summary of Request: Creation of a 12-acre fac ility to include 2-20,000 BBL off-load tanks, 2-6,000 BBL condensate tanks and vapor recovery unit, 5-206,000 BBL water storage tanks, 5 natural gas generators to treat and store produced water for re-use. The Garfield County Planning Department has received a land use request as referenced above. Your comments are an important part of the evaluation process. In order to review all appropriate agency comments and incorporate them into the Staff Report, we request your response by Friday January 11, 2013. GARFIELD COUNTY Office or Division OTHER Number or Detail Road & Bridge (Wyatt K) Paper Engineering -Chris Hale Min. Cross Paper and CD Attorney r7iJ CD Sheriffs Dept.-Jim Scars ~ CD -~'" \', rc k5\~ ---f),lrK!;:} Vc~c lalio n ManaJ!.cr /CD Hoard orc6unt/Commissioners 4 Environmental Health -Paul Reaser CD Planner CD and Paper Public Paper I COLORADO STATE I I LOCAl.JFED GOVT ENTITIES I I Health Dcpar1ment CDPHE Air Quality CD Wildlife Division (GJ Office) CD Rio Blanco County CD Bureau of Land Management CD I DISTRICTS/SERVICES I I I I Fi" Di, tti" Gmnd Vallev CD GRAND VALLEY FIRE PROTECTION DISTR;.I-C..T .I !!I!I!II!I!!I!!~'" 0124 STONE QUARRY RD EXHIBIT PARACHUTE, CO 81635 PHONE: 285-91 19, FAX (970) 285-9748 I __ !H...-!... _ December 20, 2012 Kathy Eastley Garfield County Plmming and Building Department 108 8th Street, Suite 40 I Glenwood Springs, CO 8160 I Subject: EnCana Produced Water Facility -limited Impact review Ms. Eastley, I have review EnCana's Produced Water Facility limited impact application and the Fire District doesn't have requirements for this site. Where this site is located it will have a delayed fire response from our district due to distance and climate. I do see a needed change in their Emergency Response Plan (ERP) that has been wrong for a while now and has not been fixed previously and EnCana has been made aware of this several times. On page ten of the ERP under Ambulance & Fire it shows Parachute Fire Dept. This does not exist it should be Grand Valley Fire Protection District address is 0124 Stone Quarry Rd, Parachute, CO 81635. As well the phone number is a real old number. The actual non emergency number is 970-285-9119. I will be forwarding this letter to Craig Richardson with Olsson Associates. Other than the noted change above I do not see objections for this project to not be approved. Even with the Fire Districts review of the plans it is the respon sibility of the owner to make sure the building complies with the International Fire Code 2003 Edition. If you should have any further questions please feel free to contact me. Rob Ferguson Deputy Fire Chief -Operations Cc: Chief Blair File II 1 I I \ 11 \\1"11111 .... l: l ll1Hl·11I I' (\11 ! ) I! I ! ! I. I! II r "J l P 1'1 [ '1\ '1 tl \. " I I I , I' " From: To: Subject: Date: Moman Hi" Kathy A Eastley Encana Divide Road Produced Water Impoundment and Treatment FaCility-EH COmments Thursday, January 10, 2013 5:22:43 PM EXHIBIT 1 '1-Hi Kathy, Below are my comments/questions for the Divide Road Water Treatment Facility: Air Quality and Nuisance Conditions: "Adjacent lands will not be impacted by the generation of vapor, dust, smoke, noise, glare or vibration. Encana will apply the appropriate level of controls to accommodate poten tial impacts via adherence to COPHE Air Quality regulations and the implementation of industry BMPs included in the SWMP and dust control plan." -Pg. 7, Impact Analysis o It was difficult to tell from the documents I examined if there will be any new road construction to access the facility. It also sounded like there was an existing disturbance at this location; however, the site plan indicates that the installation of the 206,000 BBL storage tanks, condensate and offload tanks, and the DAF treatment facility will likely dramatically increase the size of the disturbed area. To what degree is this the case? o Is it anticipated that an APEN will be required for the operation? There are a number of components of this facility that have the potential for emitting VOCs. Water Quality and Stormwater Management: "Variations in groundwater conditions may occur seasonally. The magnitude of the variation will be largely dependen t upon the amount of spring snowmelt, dura tion and in tensity of precipitation, site grading changes, and the surface and subsurface drainage characteristics of the surrounding area. "-Pg. 4, Impact Analysis o What are the expected changes in construction and facility activity that may result from this variability in groundwater conditions? Because the Stormwater Management Plan is not specific for this location, Garfield County Environmental Health would like to know what measures will be taken to account for these differences. We are glad to know that there is a plan in place to withstand a 100 year, 24 hour precipitation event and encourage Encana to continue these practices. o What is the expected "relationship" between the Middle Fork Produced Water Treatment Facility and this proposed water treatment plant? Will they both serve the same purpose but in two different locations? What resources will be transported between Middle Fork and Divide Road? o Garfield County requests that Encana submit notification if the COGCC does require utilization of groundwater monitoring wells. That's what I have for now. Thanks! Moro_ Hlee Environmental Health Specialist II Garfield County Public Health 195 W. 14th Street Rifle, CO 81650 Phone: (970) 665-6383 Email: mhill@garfield-county.com www.garfield-county.com/environmental-health EXHIBIT I J January I I, 2013 Ms. Kathy Eastley Gilrfield County Planning 108 8th Street, Suite 401 Glcnwood Springs, CO 8160 I MOUNTI\IN ENGINEERING, INC. Civil and Environmental Consulting and O •• lgn RE: Review of Eneann Produced Water Facility: L1PA-7361! DcaI' Kathy: This oflice has perfomled a review of the documents provided for the Limited Impact Application for the Produced Water Facility of Encan3. The submittal was found to be thorough fllld well organized. The following comment was generated: • The AppliQant did not provide a site specitic Spill Prcvcntion, Control, and Countermeasure plan. As part of the SPCC, the secondary containment requirements and verification of the sizing would be expected. Feel fi'ee to call if you have any questions or comments. Sincerely, Mountain Cross Engi 826 Y, Grand Avenue, Glenwood Springs, CO 81601 P: 970.945.5544 F: 970.945.5558 www.mounlaincross-eng .com Garfield County . Ve1!etation Mana1!ement January 15, 2013 Kathy Eastley Garfield County Building & Planning Department RE: EnCana Produced Water Facility LlPA 7368 Dear Kalhy, Comments are below: Noxious Weeds The noxious weed information contained in the Wildlife and Vegetative Impact Analysis section and the Noxious Weed Management Plan is acceptable Revegetation • A detailed reclamation plan was included in the packet in the Impact Analysis section and is acceptable. • The applicant has quantified the surface area of disturbance to be revegetated as 5.9 acres and has submitted revegetation security in the amount of $14,750 (5.9 acres x $2500/acre) • The security shall be held by Garfield County until vegetation has been successfully reestablished according to the Reclamation Standards section in the Garfield County Weed Management Plan. The Reclamation Standards at the date of permit issuance are cited in Sections 4.06, 4.07 and 4.08 of the Garfield County Weed Management Plan (Resolution #2002-94). Please let me know if you have any questions. Sincerely, ~ ~-/"---------.. -. ..~ t~ .~ Steve Anthony Garfield County Vegetation Manager 0375 County Road 352, Btdg 2060 Rifle, CO 81650 Phone: 970-625·1091 x 4305 Fax: 970·625·5939 I L Encana Oil & Gas (USA), Inc. Divide Road Produced Water Treatment Facility Standards Narrative Division 1 General Approval Standards for Land Use Change Permits Article VII, § 7-101 Compliance with Zone District Use Restrictions The Limited Impact Review process is required for the proposed Water Treatment Facility within the Resource Lands Plateau (RLP) zone district. The project site is located on a larger parcel that is approximately 15,800 acres. The project site will be developed on approximately 12 acres of the larger parcel. There will be no subdivision of the parcel to accommodate the Water Treatment Facility so the minimum lot area of 35 acres is clearly met and the minimum setback of 100 feet is far exceeded with the facility being setback over 1 mile from the closest abutting parcel. Article VII, § 7-102 Compliance with Comprehensive Plan and Intergovernmental Agreements The proposed Water Treatment Facility generally conforms to the Garfield County Comprehensive Plan. The site is not within an area governed by an intergovernmental agreement. Article VII, § 7-103 Compatibility The proposed facility is consistent with the agricultural and natural gas operations on the subject parcel and adjacent properties. The limited impacts of this facility are compatible with uses in the surrounding area and are intended to reduce traffic impacts related to natural gas production activities. Article VII, § 7-104 Sufficient Legal and Physical Source of Water Water stored at the proposed facility is generated by Encana's natural gas production assets in the Piceance region. Water delivered to the facility will not infringe on any existing water rights. The produced water generated from Encana's natural gas production operations and stored at this facility is a result of Encana's drilling operations within the Williams Fork Formation. Williams Fork Formation is classified as a non-tributary formation. Details specific to the nontributary nature of the water that will be delivered to the proposed facility are provided in an attachment accompanying this submittal. Article VII, § 7-105 Adequate Central Water Distribution and Wastewater This facility will not require a potable water distribution system or a wastewater system due to the Water Treatment Facility being unmanned. Article VII, § 7-106 Adequate Public Utilities Supply Utility electricity is not available at the site. One small and four large natural gas driven electric generators are planned to supply power for the site. In addition, support utilities such as fuel Standards Page 1 gas, instrument air, electric distribution, and control systems are planned. No public utilities will be utilized. Article VII, § 7-107 Access and Roadways A. Access to Public Right-of-Way No new roads are proposed to accommodate this facility. The facility will be accessed from County Road 215 (Parachute Creek Road) and an existing private roadway. The facility is located adjacent to CR 215. According to the guidelines in the Colorado Department of Transportation (COOT) State Highway Access Code, this road is classified as a Rural Highway (R-B). CR 215 is a two lane asphalt roadway with gravel shoulders. The road has a posted speed limit of 35 mph. B. Safe Access The private road system that provides access to the site was deSigned and built the natural gas industry for their exclusive use. Public access is controlled by a security stop near CR 215. The public is prohibited from using this private road. This road provides safe access for vehicles serving the natural gas development in this area of Garfield County. C. Adequate Capacity A drawing related to access for the proposed facility and information related to legal access for the proposed facility are provided in an attachment accompanying this application. The proposed access is described in the Project Description accompanying this submittal. The private road system provides adequate capacity of natural gas development in this area of Garfield County. Article VII, § 7-108 No Significant Risk from Natural Hazards The proposed facility project is located basically on the eastern edge of the Piceance Basin near the Grand Hogback. The elevation is approximately 8,261 feet above mean sea level (msl). The water treatment facility will be located approximately 16 miles northwest of the Town of Parachute. No geologic, slope, and soil hazards have been mapped by Garfield County in this area and no faults or other hazards are evident on the Geologic Map of Colorado. Additionally, the Geotechnical Investigation provided by Yeh and Associates as well as the Geologic and Soil Hazards report provided by Olsson Associates did not identify any existing significant risk from natural hazards nor will the construction of this facility create any hazards. Division 2 General Resource Protection Standards for Land Use Change Permits: Article VII, § 7-201 Protection of Agricultural Lands A. No Adverse Affect to Agricultural Operations The proposed facility will not adversely impact agricultural operations that are conducted on the subject property or adjacent lands. The project is located over a mile from the nearest abutting property. Standards Page 2 B. Domestic Animal Controls The applicant will comply with this standard. No dogs and other domestic animals will be kept or knowingly allowed onto the site. The lower pad where the tanks will be located will be surrounded by a wall and the upper pad will be fenced. C. Fences The facility will not generate a potential hazard to domestic livestock or wildlife. No open storage of hazardous material or attractions will be conducted on-site. Fencing and walls will further restrict the movement of animals onto the project site. Agricultural operations will not be affected due to the closest abutting property being over a mile away and no agricultural operations are being conducted on Encana's property. All fencing and walls will be designed to accommodate Colorado Parks and Wildlife (CPW) criteria. D. Roads An existing access point will be utilized from CR 215 and then private roads located on Encana's property will be utilized to access the project site. Control of dust along unsurfaced access roads and minimization of tracking soil onto paved roads, as required by the CDPHE Construction Stormwater Permit and per the details contained in the Fugitive Dust Control Plan will be abided by for the construction and operations phases. No additional road construction will be required. E. Irrigation Ditches Irrigation ditches on and adjacent to the subject property will not be impacted by the facility. Implementation of the engineered drainage plan and conformance with stormwater best management practices will assure irrigation ditches on and adjacent to the subject property will not be impacted by the facility. Article VII, § 7-202 Protection of Wildlife Habitat Areas WestWater Engineering (WWE) provided an analysis of the project site with respect to Section 7-202 Protection of Wildlife Habitat Areas of the Garfield County Unified Land Use Resolution 2008 in their report dated April 2012. The following text is taken directly from the WWE report. WILDLIFE Raptors No occupied raptor nests have been documented near the site since intensive surveys began in the area in 2007. Activities associated with construction of the water treatment facility have minimal potential to impact raptor populations, as no nesting habitat will be directly affected. The nearest high-quality nesting habitat (aspen grove) occurs approximately 0.23 miles south of the project site. Construction and operation of the facility are likely to have little indirect effect on raptors that have become at least partially habituated to a significant amount of human activity in the area. Standards Page 3 Greater Sage-Grouse Sage-grouse occupy and potentially nest in the sagebrush habitat near the site, which is mapped as a sage-grouse production area (NDIS 2012). Construction during the nesting and brood-rearing season (March through late-July) should be avoided, if possible. If brush clearing can take place prior to nesting, the potential for sage-grouse to nest on the site would be reduced. Sage-grouse predators such as Red-tailed Hawks and Golden Eagles could benefit from additional edge habitat and potential hunting perches created by the project, resulting in an increase in predation on sage-grouse. Deterrent devices should be used to prevent raptors from utilizing structures on the site as hunting perches. The potential for road-kill exists, although speed limits are low and signage warning drivers of the presence of sage-grouse is in place. American Elk and Mule Deer The proposed site is near, but not within, an elk production area. Elk in this area typically calve in aspen stands or dense mountain shrublands (serviceberry) from late-May through mid-June. The nearest potential calving areas are north of the project and are blocked from view by terrain features. Given the cumulative scale of ongoing activities along Divide Road, which would likely cause elk to select more remote areas for calving, it is unlikely that construction or operation of the facility will affect elk in the area. Approximately 11.76 acres of foraging habitat for big game will be lost as a result of construction of the water treatment facility. Implementation of Encana's noxious weed management plan 0NWE 2009) would promote continued health of the vegetation community in the area surrounding the development. A reclamation plan should be implemented to reduce the establishment of noxious weeds in disturbed areas. Reclamation of disturbed areas not utilized as part of the facilities would decrease the presence of noxious weeds and provide forage for mule deer and elk. Wildlife should be considered before any fencing is designed or built. Following wildlife friendly fencing standards reduces the costs of repairing fences damaged by wildlife, reduces the chance of mortality from animals becoming entangled in the fence, and allows for less restricted movements throughout an area. The CPW has published guidelines for fence construction that reduces impacts to wildlife (Hanophy 2009). Black Bear Black bear will likely be foraging in the habitat surrounding the project site, particularly when berries and acorns ripen. Personnel may be unfamiliar with wildlife in the area and should be informed of the potential for bear interactions. Personnel should not feed bears at any time. Bears should not be approached if encountered in the project area. All garbage and any food items should be removed from the site on a daily basis. Standards Page4 Mitigation of Habitat Loss to Migratory Birds Approximately 11.76 acres of vegetation removal will occur as a result of construction of the water treatment facility. If vegetation removal can take place prior to nesting season (early May), these birds will choose to nest elsewhere and no nest would be directly affected. Implementation of Encana's noxious weed management plan CNWE 2009) would promote continued health of the vegetation community in the area surrounding the development. A reclamation plan should be implemented to reduce the establishment of noxious weeds in disturbed areas. Reclamation of disturbed areas not utilized as part of the facilities would decrease the potential for infestation by noxious weeds and replace foraging habitat for birds. Small Mammals and Reptiles There are no seasonal limitations or special requirements for development related to these species. PRESERVATION OF NATIVE VEGETATION The best method to mitigate loss of wildlife habitat is to increase the availability of native forage in the form of grasses and shrubs by reseeding disturbed areas. Native grasses would provide the greatest benefit for wildlife. Application of Encana's integrated vegetation management plan CNWE 2009) would provide a basis for appropriate mitigation. Treatment and Control of Noxious Weed Infestations The highest priority for noxious weed management is to prevent the establishment of any noxious weed infestation of the project site. Noxious weeds aggressively compete with native vegetation. Most have come from Europe or Asia, either accidentally or as ornamentals that have escaped. Once established they tend to spread quickly because the insects, diseases, and animals that normally control them are absent. Prevention is especially valuable in the case of noxious weed management. Noxious weeds are spread by man, animals, water, and wind. Prime locations for the establishment of noxious weeds include roadsides, construction sites, wetlands, riparian corridors, and areas that are overused by animals or humans. Subsequent to soil disturbances, vegetation communities can be susceptible to infestations of invasive or exotic weed species. Vegetation removal and soil disturbance during construction can create optimal conditions for the establishment of invasive, non-native species. Construction equipment traveling from weedinfested areas into weed-free areas could disperse noxious or invasive weed seeds and propagates, resulting in the establishment of these weeds in previously weed-free areas. Several simple practices should be employed to prevent most weed infestations. The following practices should be adopted for any activity to reduce the costs of noxious weed control through prevention. The practices include: • Prior to delivery to the site, equipment should be thoroughly cleaned of soils remaining from previous construction sites which may be contaminated with noxious weeds. Standards Page 5 • If working in sites with weed-seed contaminated soil, equipment should be cleaned of potentially seed-bearing soils and vegetative debris at the infested area prior to moving to uncontaminated terrain. • All maintenance vehicles should be regularly cleaned of soil. • Avoid driving vehicles through areas where weed infestations exist. During the reclamation phase, the property will be reseeded and regraded to predisturbance levels. Article VII, § 7-203 Protection of Wetlands and Water bodies As detailed in the April 2012 Impact Analysis provided by WestWater Engineering biologists "no jurisdictional wetlands or drainages would be affected by the project." Additionally engineering controls and stormwater Best Management Practices (BMP's) will be utilized to ensure the continued protection of water bodies from stormwater runoff during operation of the facility. Article VII, § 7-204 Protection of Water Quality from Pollutants The operator will operate the facility in order to maintain the required buffer between the disturbed area and the natural vegetation and waterways. Implementation and adherence to Encana's Stormwater Management Plan (SWMP) Best Management Practices (BMPs) and Spill Prevention Control and Countermeasures Plan (SPCC) will assure that natural vegetation and waterways are protected. BMPs utilized during construction and operation will include (but not be limited to) straw wattles, check dams, hay bales and silt fencing. According to the SPCC criteria, secondary containment will be comprised primarily of berms, impervious synthetic liners and steel containment structures. Article VII, § 7-205 Erosion and Sedimentation Encana's Area Wide Stormwater Management Plan is currently being renewed and expanded to include this facility. No construction will begin until such time as said plan is approved. BMPs will be utilized to ensure the continued protection of water bodies from stormwater runoff during construction of the facility. Article VII, § 7-206 Drainage: A. Site Design to Facilitate Positive Drainage This standard requires that lots be laid out to provide positive drainage. Lots are not proposed as part of this land use application. Because of the small size of the proposed project area, the site will not create any impacts to existing drainage patterns. Additional details are provided in the Stormwater Management Plan, Drainage Report and Erosion Control Plan accompanying this submittal. B. Coordination with Area Storm Drainage Pattern This standard also addresses individual lot drainage within a residential development and is not applicable to this use. The proposed facility will not impact natural drainage patterns. Standards Page 6 Article VII, § 7-207 Stormwater Run-Off The SWMP has been included with this application and covers all applicable activities associated with the facility's disturbance. The proposed Facility is not within 100 feet of a waterbody. Additionally, the Water Treatment Facility will not create 10,000 square feet or more of impervious surface area. The facility will be covered by a CDPHE stormwater construction permit. Article VII, § 7-208 Air Quality Because this Water Treatment Facility will utilize enclosed tanks, the potential for degradation of air quality will be significantly reduced. As a result, the land use change shall not cause air quality to be reduced below acceptable level established by the Colorado Department of Public Health and Environment (CDPHE). Encana will obtain all applicable federal and state air quality permits. Article VII, § 7-209 Areas Subject to Wildfire Hazards The project site is designated in a low to moderate wildfire hazard on the Garfield County Wildfire Hazard Map. Article VII, § 7-210 Areas Subject to Natural Hazards and Geologic Hazards No geologic hazards have been mapped by Garfield County in this area and no faults or other hazards are evident on the Geologic Map of Colorado. No other hazards have been observed by Encana. Article VII, § 7-211 Areas with Archeological, Paleontological or Historical Importance Given the limited construction activity and small footprint of the proposed facility, no protected or registered archaeological, cultural, paleontological or historic resources will be impacted. Flattops Archaeological Consultants (FAC) conducted a Class I inventory. FACs recommended a finding of no historic properties affected. However, if cultural resources are discovered or unearthed during ground-disturbing activities, a qualified archaeologist should be notified. See the Cultural Resources Report located in the Supplemental Materials section of this submittal. Article VII, § 7-212 Reclamation A reclamation plan has been provided as a component of the Impact Analysis. During the reclamation phase, the property will be reseeded and regraded to predisturbance levels. Division 3 Site Planning and Development Standards: Article VII, § 7-301 Compatible Design Operation of the proposed facility will be consistent with nearby uses. Adjacent lands will not be impacted by the generation of vapor, dust, smoke, glare, noise or vibration. The facility is designed to operate with minimal manual operations with remote communications of critical process information at other Encana facilities which are manned 24 hours per day 365 days per year. The facility is planned to be unmanned with daily operator visits to check on equipment Standards Page? and perform needed manual operations and maintenance functions at the facility. The site will be visited for maintenance purposes only. There will be minimal impacts, if any, to the roadway system during the operational phase. Article VII, § 7-302 Building Design The facility will be constructed to minimize sound and visibility and will meet the Garfield County Building Department requirements. Buildings will be designed per applicable building codes and building permits will be submitted when the designs are complete. Article VII, § 7-304 Off-street Parking and Loading Standards Adequate parking will be made available to accommodate Encana personnel during regular operation, inspection and maintenance of the facility. All activities on this site will be conducted out of the public right-of-way of any county road and will take place on the subject parcel. Article VII, § 7-305 Landscaping and Lighting Standards No landscaping will be installed. The operator will follow the attached Weed Management and Reclamation Plan recommendations and guidelines in order to maintain the integrity of the existing landscape and to assure the preexisting landscape conditions are accommodated at the time of final reclamation. Article VII, § 7-306 Lighting Standards A minimal amount of lighting will be installed around the impoundments, buildings and access areas to allow for safe operations during low light conditions and to accommodate emergencies. Lighting will comply with Garfield County standards. Any lighting utilized at the site will meet the requirements for downcast, shielded, flashing, and hazardous lighting. Article VII, § 7-307 Snow Storage Standards Snow will be stored in a vacant section of the existing disturbed area. The site will be graded to accommodate snowmelt to insure sufficient drainage. Article VII, § 7-308 Roadway Standards Access to the subject property is from County Road (CR) 215 (Parachute Creek Road). An existing private roadway network used primarily by Encana connects the proposed water treatment facility to CR 215. CR 215 is a two lane asphalt roadway with gravel shoulders. The road has a posted speed limit of 35 mph. The Colorado Department of Transportation (COOT) Access Category Classification classifies County Road 215 as Rural Highway, Category R-B. The RB category is appropriate for use on highways that have the capacity for moderate to high travel speeds and moderate traffic volumes. There are no historic access points to public lands within the property boundaries. A drawing related to access for the proposed facility and information related to legal access for the proposed facility are provided in an attachment accompanying the application submittal. No new accesses or auxiliary lanes onto a County or State roadway will be required as indicated in the Traffic Study. The existing private roadway has been constructed to limit Standards PageS erosion and dust. Additionally dust control and erosion control BMPs will be implemented. The roadway will be utilized for maintenance and monitoring purposes only. Article VII, § 7-309 Trail and Walkway Standards The site is located in a rural and remote area of Garfield County. A trail or walkway is not warranted at this location. This standard is not applicable. Article VII, § 7-310 Utility Standards Utility electricity is not available at the site, so one small and four large natural gas driven electric generators are planned for the site. In addition, support utilities such as fuel gas, instrument air, electric distribution, and control systems are planned. No additional public utilities will be utilized. Section 7-1101 Additional Standards Applicable to Industrial Use A, Residential Subdivisions This site is not located in a residential subdivision. B. Setbacks The site is located more than 100 feet from a residential property line. C. Concealing and Screening There will be three buildings including a duplex pump house, high pressure pump house and office (unmanned). All outdoor storage facilities for fuel, raw materials and products shall be screened by natural topography due to the project location being located at a higher elevation than the most of the surrounding area. Additionally, the Water Treatment Facility will be fenced and walled. D. Loading and Unloading All operations will be conducted on site (private property). There will be 2 bays located within the confines of the subject property for any offloading activities. E. Storing All products will be stored in compliance with national, state and local codes and shall be more than 100 feet from an adjacent property line. All petroleum and hazardous products will be stored in an impervious spill containment area. F. Hours of Operation This facility will operate 24 hours a day. No noise, odors or glare detectable beyond the property line. G. Industrial Wastes All industrial wastes will be disposed of in a manner consistent with Federal, State statutes and requirements of the CDPHE. Standards Page 9 H. Noise Noise will not exceed standards regulated by the COGCC. I. Ground Vibration Ground vibration will not be measurable at any point along the property boundary lines. J. Interference, Nuisance, or Hazard This facility will not emit heat, glare, radiation or fumes that interfere with existing uses on adjoining properties or which constitutes a public nuisance. Standards Page 10 744 HORIZON COURT SUITE 110 GRAND JUNCTION. CO 81506 From: Marc Kenney, P.E. tl\~~ (970) 241·4722 (970) 241·8841 (Fax) info@rc(west.com To: Kathy Eastley, Garf~' ounty CC: Christopher Putnam, cana; Mike Sanville, Encana; Bill Wilde, Encana; Date: January 25, 2013 RE: Layout Revisions to the Divide Road Water Facility The purpose of this letter is to provide and discuss the impacts of the revisions to the layout at Encana's proposed Divide Road Water Facility (DRWF). The proposed Divide Road Water Facility is to be constructed on Parcel No. 191727400012, which is owned by Encana Oil & Gas (USA) Inc. Access to the site is by Garfield County Road 215 and a network of private roads. In legal terms this project is located in the south half of Section 26 of Township 4 South, Range 96 west of the 6th Principal Meridian. River City Consultants, Inc. worked with Encana to develop a Civil Plan set of the Divide Road Water Facility in August of 2012. This Civil Plan set included a site plan, grading plans, road plan and profile sheets, and erosion control plans. The basis of these plans was a preliminary site and equipment layout provided by Encana.The preliminary site and equipment layout was recently updated by Encana. The update included changes to the limits of the secondary containment areas, building and equipment relocation, and other internal changes. These changes will impact the site grading, especially internally within the site. The impacts/changes around the perimeter of the site will be minimal, if there are any at all. However, these changes do not alter the grading concept and do not Significantly impact how stormwater will be directed and handled. The site footprint has not substantially changed and obviously it is in everyone's best interest to minimize the limit of disturbance, and that will be a goal when updating the Civil Plans. There are no anticipated changes to the quantity and quality of stormwater discharged from the site. It is unlikely these changes will impact impervious area and/or curve numbers enough to change peak flows and ditch and culvert sizes. The same BMPs will be used as previously proposed. Although their physical location(s) may be adjusted to better suit the revised layout and grading, it is not anticipated the Attachments mjk/S:\PROJECTS\"1086 EnCana\041 DRWF\Dcsign\DRWF _Revised_Layout_Letter.doc Page 1 of1 L PC STA 4,00 RECEIVING CONT AINMENT AREA: -. BRU ""-3 f THIGH y,;g'\ SECONDARY ~ CONT AlNMENT 206,000 bbls r~·· i//__ _ _ I STORAGE lfUTURt -. I TANK 4 ---J \ (168' OIA l( 54 ' TALLl SEPARAT ORS~--@\ , -. -. '\ , , -. -. \ \ , I Of WALL EL 8271 TOP Of WALL EL 8271 206,000 bbls STORAGE 206,000 bbls TANK 2 STORAGE TANK 3 n68' OIA l( 54' TALl) (168' OIA l( 54 ' TALl) STORAGE CONT AINMENT AREA: GROSS AREA· 157,945 CU fT LESS SLUDGE TANKS· 6,362 CU fT LESS CONPENSATE TANKS · 2651 ell FT NET CONTAINMENT AREA· 148,932 CU FT VOLUME TO BE CONTAINED: 20,000 bbls PLUS 107. • 112,299 CUBIC HET PLUS RAIN: • 3,152 CUBIC fEET NET VOLUME TO CONTAIN 126,681 CUBIC FEET ® CD ® o Of WALL 8271 Sl UOCE TANKS CONO(NSAT( STORACE IJ D 400 bbll TANKS) OUPlEX PUMPS TRUCK orr'LOAO (2 BAY> SECONDARY CONT ~MEN T (Of f · l DAil T ANKSI fRESH WATER TANK RECEIVN(; PUMP STATION Plot Dote: 1/25/2013 1: 08: 29 PM : I------------------------+----------~+---~ ------------------------------~--+---~----~--+-~ I DRAFT CAUTION READ BEFORE EXCAVATION ALL EXCAVATIONS MUST BE CARRIED OUT AS PER "ENCANA'S GROUND DISTURBANCE PRACTICE" /q £ -AA 190 (SOLE IN FEET ) Of WALL 8271 206,000 bbls STORAGE TANK 1 (168' DIA l( 54 ' TALl) @@@@@@@@@HE AllER RECEIVING TANK 1:10,000 bbl5) " CC STORAGE CONTAINMENT AREA: GROSS AREA · 2,075,620 CU fT LESS TANK NO.1 ' 221,670 CU fT LESS TANK NO.2 ' 22 1,670 CU fT LESS T lINK NO. 3 ' 221,670 CU fT NET CONTAINMENT AREA -1,410,610 CU fT VOLUME TO BE CONTNNED: 206,000 bbls PLUS 107. • 1,272,638 CUBIC f EET PLUS RAIN: • 26,555 CUBIC fEET NET VOLUME TO CONTAIN 1, 298,923 CUBIC f EET @Of'flCE WHOllEr © TURBINE BUilDING @R(CYClE SYSTEM @SEPTIC HOLDING TANK POLYMER STORAGE PALLET @SLUDGE PROCESSING COAGULANT STORAGE ""' @PRODUCED WATER SEPARATOR POlYMER 1011 )( TANK @HDWBACK SEPARATOR COAGULANT 1.11)( TANK @VENT RECOVERY UN!T f l OW EQUALIZING T AHk @COMBUSTOR HIGH PR(SSUR( PIJU'> HOUSE ® rEUl. CAS SKO encana PROPOSED LAYOUT PL AN "" ~ ~ E 8 DR-C-'2j Kath A. Eastle From: Sent: To: Cc: Subject: Kathy, Craig Richardson [crichardson@olssonassociates.com) Friday, January 25, 20133:09 PM Kathy A. Eastley christopher.putnam@encana.com; Carey Gagnon RE: Divide Road Desgin Alterations EXHIBIT I rJ I would aga in like to apologize for the delay in getting you th is information, I know how inconvenient last minutes changes are. Chris Putnam spoke with Mike Sanville {Encana water engineer)and had him outline the changes. His email is included below for your review. Again, I know how frustrating a situation like this is and I rea lly appreciate all your help. Cra ig From: Sanville, Mike Sent: Friday, January 25, 201314:56 To: Putnam, Christopher A. Cc: Durrant, Christopher D. Subject: RE' Divide Road Design Alterations Chris, The form, fit, and function of the Divide Rood Water Facility has not changed since the initial LlR permit submittal. Working through the mare detailed engineering processes has allowed us to specify sizes for water, sludge, and condensate storage tanks, transfer pumps, and treatment equipment. During the process we have optimized equipment locations, containment sizes, building sizes, and vehicle road ways. The more detailed design has impacted the plan view of the site, but has not changed the disturbance area nor equipment onsite. As we further developed the design basis for the facility, we have made the following changes: 1. Removal of Storage Tank S. 2. Conversion from four (4) reciprocating gas generators to one (1) turbine style gas generator. 3. Reduction in condensate storoge volume from 12,000 bbls to 2,SOO bbls. Thanks, Mike Mike Sanville, MS Water Engineer -S. R. B. U. Water Management 906.553.3500 From: Kathy A. Eastley [mailto:keastley@garfield-county.com] Sent: Friday, January 25, 2013 2:08 PM To: Craig Richardson 1 Cc: christooher.putnam@encana.com; Carey Gagnon Subject: RE: Divide Road Desgin Alterations Thanks for provid ing th is update. I will include this information as an exhibit for the BOCC however I will not be revising my staff report to incorporate this information due to the late date of the submittal. I would expect you to fully explain this change at the public hearing and request that a revised site plan be included as a condition of approval should the Board incorporate this plan revision in their approval. I would very much appreciate an email which specif ically details the changes associated with the new plan. Kathy Eastley, AICP Senior Planner Garfield County Community Development 108 8th Street. #401 Glenwood Springs. CO 81601 Phone: 970-945-1377 ext. 1580 Fax: 970-384-3470 keastley@garfield-county.com From: Craig Richardson [mailto:crichardson@olssonassociates.comj Sent: Friday, January 25, 2013 2:00 PM To: Kathy A. Eastley Cc: christopher.putnam@encana.com Subject: Divide Road Desgin Alterations Kathy, Chris and I spoke with you last week about a minor change in the Divide Road layout. Chris has been working with his engineers to expedite the details of their proposed changes. As outlined in our phone call and the PE letter attached to this email, the proposed alterations will not significantly impact stormwater runoff and the overall surface disturbance is reduced. Please do not hesitate to contact us with any questions or concerns. Thanks, Craig Craig Cell-970-462-6989 Chris Cell -970-208-3409 Craig Richardson I Grand Junction Permitting I Olsson Associates 826 21 Y, Road I Grand Junction, CO 81505 I crichardson@olssonassociate s.com TEL 970.263.7800 I CELL 970.462.6989 I FAX 970.263.7456 o\'OLSSON® A SSOC I AT e s 2 EXHIBIT 1 0 From: To: Subject: Date: Chris Hale Kathy A Eastley RE: Divide Road Desgln Alterations Monday, January 28, 2013 11 :05:55 AM I have reviewed the attached and have no additional comments. Thanks. Sincerely, Mountain Cross Engineering, Inc. Chris Hale, P.E. 826 1/2 Grand Avenue Glenwood Springs, CO 81601 Ph: 970.945.5544 Fx: 970.945.5558 From: Kathy A. Eastley [mailto:keastley@gariield-county.com] Sent: Friday, January 25, 2013 2: 10 PM To: Chris Hale Subject: FW: Divide Road Desgin Alterations Please review the attached information regarding changes to the Divide Road facility. Kathy Eastley, AICP Senior Planner Garfield County Community Development 108 8th Street. #401 Glenwood Springs. CO 81601 Phone: 970-945-1377 ext. 1580 Fax: 970-384-3470 keastley@garfield-countycom From: Craig Richardson [mailto:crichardson@olssonassociates.com] Sent: Friday, January 25, 2013 2:00 PM To: Kathy A. Eastley Cc: christopher.putnam@ encana.com Subject: Divide Road Desgin Alterations Kathy, Chris and I spoke with you last week about a minor change in the Divide Road layout. Chris has been working with his engineers to expedite the details of their proposed changes. As outlined in our phone call and the PE letter attached to this email, the proposed alterations will not significantly impact stormwater runoff and the overall surface disturbance is reduced. Please do not hesitate to contact us with any questions or concerns. Thanks, Craig Craig Cell -970-462-6989 Chris Cell -970-208-3409 Craig Richardson I Grand Junction Permitting I Olsson Associates 826 21 Y, Road I Grand Junction, CO 81505 I crjchardson@olssonassocjates com TEL 970.263.7800 I CELL 970.462.6989 I FAX 970.263.7456 O\OLSSON® ASSOCIATES