HomeMy WebLinkAbout09.19.13 letter from Colorado Parks & wild lifeCOLORADO PARKS & WILDLIFE
6060 Broadway • Denver, Colorado 80216
Phone (303) 297 -1192
wildlite.state.co.us • parks.state.co.us
09 -18 -13
To: Kathy Eastly
Garfield County Community Development Department
108 8th Street, Suite 401, Glenwood Springs, CO 81601
RE: MIPA 7607
EXHIBIT
Thank you for the opportunity to comment on the proposed soil treatment facility located
along the north 1 -70 corridor between Parachute and Rulison. Colorado Parks and
Wildlife (CPW) has a statutory responsibility to manage all wildlife species in Colorado;
this responsibility is embraced and fulfilled through CPWs mission to protect, preserve,
enhance, and manage the wildlife of Colorado for the use, benefit, and enjoyment of the
people of Colorado and its visitors. We encourage Garfield County to afford the highest
protection for Colorado's wildlife species and habitats through the development and
implementation of management actions combined with the use of best management
practices (BMPs) to protect wildlife and their habitats.
The project location is utilized year -round by many species of game and non -game
wildlife. The site lies within areas mapped by CPW as mule deer severe winter range and
is within 1/4 mile from mapped elk winter range. Additionally, the proposed soil
treatment site lies less than a t/a mile from the Colorado River in an area of critical habitat
for four federally listed fish species. The following comments are intended to express
and address wildlife related concerns of CPW as they apply to this project.
1. CPW is concerned with the possibility of soil contaminates from the facility
reaching the Colorado River during flooding or severe storm events.
Contaminates associated with natural gas production have the ability to negatively
impact aquatic and riparian communities including the federally listed fish species
found in this area of the Colorado River. To address these concerns, CPW
recommends that best management practices be used to contain run -off associated
with a 100 -year flood event. This includes an impermeable berm surrounding the
entire soil treatment field that has been engineered to withstand a 100 -year flood
event. To prevent contaminates from seeping into the grounds, the CPW
recommends that an impermeable ground layer underlying the treatment field be
constructed. Additionally, retention basins and removal of standing water at 50%
capacity levels within the soil treatment area should be considered to account for
excess storm water or spring run -off.
STATE OF COLORADO
John W. Hickenlooper, Governor • Mike King, Executive Director, Department of Natural Resources
Steven M. Yamashita, Acting Director, Colorado Parks and Wildlife
Parks and Wildlife Commission: Robert W. Bray • Chris Castilian • Jeanne Home
Bill Kane, Vice-Chair • Gaspar Perricone • James Pribyl • John Singletary, Chair
Mark Smith, Secretary • James Vigil • Dean Wingfield • Michelle Zimmerman
Ex Officio Members: Mike King and John Salazar
2. The facility should not be operated during the winter months to address
disturbance to mule deer and elk. As such, the CPW recommends that operations
of the facility shall cease December 1 thru April 15. Additionally, soil treatment
activities should occur only during daylight hours during non - winter months to
reduce disturbance to the local wildlife.
3. CPW recommends that actions be taken to exclude wildlife from the soil
treatment area. A 6 -foot high chain -link fence surrounding the entire field should
prevent big -game from entering the area.
4. The source of water to be utilized in this facility's operation is a concern. There
is a potential for the spread of aquatic nuisance species if a truck draws surface
water from more than one site. Equipment used for transporting water for this
facility should use the following disinfection techniques:
Disinfect heavy equipment, hand tools, boots and any other equipment that was
previously used in a river, stream, lake, pond, or wetland prior to moving the
equipment to another water body. The disinfection practice should follow this
outline:
o Remove all mud and debris from equipment and spray /soak equipment
with a 1:15 solution of disinfection solution containing the following
ingredients:
• Dialkyl dimethyl ammonium chloride, 5 -10% by weight;
• Alkyl dimethyl benzyl ammonium chloride, 5 -10% by weight;
• Nonyl phenol ethoxylate, 5 -10% by weight;
• Sodium sesquicarbonate, 1 -5 %;
• Ethyl alcohol, 1 -5%; and
• Tetrasodium ethylene diaminetetraacetate, 1 -5%
• and water, keeping the equipment moist for at least 10 minutes and
managing rinsate as a solid waste in accordance with local, county,
state, or federal regulations;
or
o Spray /soak equipment with water greater than 140 degrees Fahrenheit for
at least 10 minutes.
o Sanitize water suction hoses and water transportation tanks (using
methods described above) and discard rinse water at an appropriately
permitted disposal facility.
5. CPW recommends that on -site irrigation water be utilized if available for facility
operations to alleviate the above concerns associated with using off -site surface
water at the facility.
6. CPW recommends that ground water monitoring wells be installed to identify
seepage of contaminates into the soil.
7. Install and utilize bear -proof dumpsters and trash receptacles for all food- related
trash on location, following COGCC Rule 1204 a -1.
If you have any questions, please feel free to call Scott Hoyer, the District Wildlife
Manager in Parachute. He can be reached at 970 -250 -0873.
IT Romatzke
Area Wildlife Manager
Colorado Parks and Wildlife
Cc: Hoyer, File