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HomeMy WebLinkAbout2.0 Staff ReportBoard of County Commissioners — Public Hearing Exhibits Wolf Ranch Compressor Station, Material Handling, and Storage Limited Impact Review Applicants are Hunter Ridge Energy Services in Conjunction with Encana August 12, 2013 (File LIPA-7589) Exhibit Letter (Numerical) Exhibit. Description 1 Proof of Publication 2 Return Receipts from Mailing Notice 3 Photo evidence of Public Notice Posting free i f ttkcvf 4 Garfield County Unified Land Use Resolution of 2008, as amended 5 Garfield County Comprehensive Plan of 2030 6 Application 7 Staff Report 8 Staff Presentation 9 Referral Comments from Garfield County Consulting Engineer 10 Referral Comments from Garfield County Vegetation Manager 11 Referral Comments from Garfield County Road and Bridge 12 Referral Comments from Garfield County Environmental Health 13 Referral Comments from CDPHE Air Quality 14 15 16 17 18 19 20 21 22 23 24 I EXHIBIT BOCC 8/12/13 File No. LIPA-7589 GH PROJECT INFORMATION AND STAFF COMMENTS REQUEST APPLICANT PROPERTY OWNER ASSESSOR'S PARCEL # PROPERTY SIZE LOCATION ACCESS Limited Impact Review for the Wolf Ranch Compressor Station, Material Handling and Storage Facility Hunter Ridge Energy Services LLC Encana Oil and Gas (USA) Inc. 1917-274-00-012 The facility is located on a 15.98 acre site within an overall parcel of approximately 15,800 acres owned by Encana Oil and Gas (USA) Inc. The site is located approximately 21 miles north of Parachute, accessed off of County Road 215 and located in Section 24, T4S, R96W. Existing private access roads beyond the end of County Road 215, gate and access controlled. EXISTING ZONING The property is zoned Resource Lands — Plateau I. GENERAL PROJECT DESCRIPTION The Applicant is requesting Limited Impact Review for a new Compressor Station, amine plant and storage lay -down yard. This field compressor will boost medium pressure gas to high pressure for distribution and sales. The proposal includes 3 compressors for initial installation and 3 future compressors for a total of 6 compressor units. The amine plant is designed to remove CO2 from gas and will be located in an open area also proposed to be used as a storage/laydown yard. The facility will include a variety of equipment and facilities summarized below 1 3 Compressors 2 Generators 1 Slug Catcher 3 Filter Separators 1 Instrument AIr Skid 1 Pig Receiver 2 Pig Launchers 1 BTEX Condenser 1 LACT 1 Storage/Maintenance Building 2 Future Dehydrators 1 Future Combustor 3 Future Compressors 3 Future Filter Separators 1 Future Amine Plant The facility is proposed to be unmanned with no demand for potable water. It is located in an area with moderate slopes and native sage brush and mountain shrub vegetation. The facility will occupy approximately 14 acres and will include re - vegetation and reclamation of disturbed areas, grading of the site, and storm -water management improvements. 1,0 J...,...4T4SJR95W _I. [Enca na Oil & ©as (USA) Inc Parcel No 191727400012 R97W 2 ' - 1 i ilii I -II - t a. ! -LJ e❑ :.i r r ' a_ J'I L Ifi 11111AH I I I I I I I I1 I I0 LI LI LI LI The site will include compacted dirt roadways for access, circulation and parking areas. The primary access roadway to the site is 20 ft. — 30 ft. in width with a compacted dirt and gravel surface. The access road is subject to dust mitigation plans including application of dust inhibitors, and is serviced and maintained pursuant to joint use and cost sharing agreements. The access road serves an extensive area of oil and gas facilities including gas pads, tanks storage areas, telecommunication facilities and pipelines. II. LOCATION - SITE DESCRIPTION The site is located in a remote area characterized by natural vegetation, open space, and oil and gas operations. Existing vegetation surrounding the site is consistent with sagebrush communities, mountain shrub and aspen woodlands and development of the site is consistent with the Resource Lands Plateau zoning. The site is located along a moderate ridge between two drainages. 3 AERIAL PHOTOGRAPH Legend * Uneetuplee Raptor Nest li Mie Reaor Survey Area Compreisor Pea Access Road County Road BLM III. PUBLIC COMMENTS AND REFFERAL AGENCY COMMENTS Public Notice was provided for the Board of County Commissioner's public hearing in accordance with the Unified Land Use Resolution of 2008, as amended. No public comments have been received at this time. Comments from referral agencies and County Departments are summarized below and attached as Exhibits. 1. Garfield County Consulting Engineer, Chris Hale, Mountain Cross Engineering: Discussed roadway waivers, public notice, and Storm Water Management. 2. Garfield County Road and Bridge Department: Indicated they had no issues with the proposal. 3. Garfield County Vegetation Manager, Steve Anthony: Indicated that the weed management plans are acceptable, noted the need for control of Knapweed, 4 outlined security requirements for re -vegetation of disturbed areas, and included a copy of comments related to a grading permit application for adjacent pipeline work. View of the Site Looking North 4. Garfield County Environmental Health: Provided comments on nuisance issues - impact analysis, SPCC plans, storm -water management and the lack of any adjacent water bodies. 5. Grand Valley Fire Protection District: No comments were received from the Fire Protection District. 6. Colorado Parks and Wildlife: Indicated by email that their review was ongoing. 7. Colorado Department of Public Health: Provided general comments on air quality permitting. 8. Other agencies that did not submit comments include: (a) the Colorado Department of Public Health (Water Quality); and (b) Bureau of Land Management. IV. STAFF COMMENTS AND ANALYSIS In accordance with the ULUR regarding Limited Impact Reviews, the Applicant has provided in the Application Submittals detailed responses to Section 4-203, Submittal Requirements, applicable sections of Article VII, Divisions 1, 2, and 3, including Section 7-1101 Industrial Use Standards. The Application materials include an Impact Analysis and related consultant reports, technical studies, and plans. Key topics for the review are summarized in the following sections. 5 7-104 Sufficient Source of Water & 7-105 Waste Water Systems The Facility is an unmanned operation other than monitoring and maintenance operations. Potable water is not required for operation and portable sanitation facilities will be provided during construction activities. 7-106 Adequate Public Utilities Proposed compressors will be natural gas driven. Power needs if any will be provided on site. 7-107 Access and Roadways & Section 7-310 Site Planning — Roadway Standards Access roadways to the site are existing and in place. A small section of new access road and relocation of an existing access road adjacent to and south of the site will be constructed. A waiver request has been included in the submittals to address the potential for minor variations from the County Roadway standards that may exist in the roadway system. No operational issues have been noted and the roadway system adequately serves the site and adjoining facilities in the area. 7-108 Natural Hazards and 7-210 Natural Hazards and Geologic Hazards The submittals include geologic and soils hazard reports which provide technical recommendations and indicate that "with proper engineering, the proposed location should be safe for construction and operation of the proposed Compressor Station." 7-201 Agricultural Lands No adverse impacts on seasonal cattle grazing activities that occur in the area on the Applicant's properties are anticipated. 7-202 Wildlife Habitat Areas Approximately 14 acres of native vegetation will be removed for the facility. While no sensitive plant species are expected in the project area, the Applicant's Wildlife report indicates that the project site is within a mapped sage grouse production area based on CPW maintained mapping. No sage grouse sign was observed during the survey efforts by the Applicant's consultants. The Applicant has verbally confirmed that the site is subject to the Wildlife Management Plan that the Applicant maintains with the CPW. The plan and related agreements are intended to address wildlife impacts and mitigation. 7-203 & 7-204, Protection of Wetlands and Waterbodies and Water Quality 7-205 Erosion and Sedimentation 7-206 & 207 Drainage and Stormwater Run -Off 6 The Applicant's submittals include detailed plans for protection of water quality including storm -water drainage best management practices. Compliance with the plans and provision of any CDPHE permitting should be required. 7-208 Air Quality The Applicant has represented that all compressor units and related facilities will be properly permitted through the Air Quality Control section of the Colorado Department of Public Health and Environment (CDPHE). Air quality permits for all equipment including the Amine Plant as required by CDPHE and consistent with their referral comments need to be provided. 7-209 Wildfire Hazards Emergency response plans have been provided with the submittals and include responses to standard wildfire hazard provisions. In addition, the grading around the facility should eliminate wildland fire fuels immediately adjacent to the facility. 7-211 Archeological or Historical Importance The Applicant's consultant report indicates a finding that no historic properties are being affected. 7-212 Reclamation The application includes appropriate plans for re -vegetation and long term reclamation. Security for re -vegetation is addressed in the County Vegetation Managers referral comments and needs to be required as a condition of approval. Section 7-1101 Industrial Use Standards The Application addresses and demonstrates general compliance with the Industrial Use Standards. As noted in referral comments from the County Envronmental Health Department careful mitigation of nuisance issues is needed with industrial operations. The Applicant has provided a noise mitigation analysis and plan estimated to maintain compliance with all County and COGCC noise regulations. A detailed dust mitigation plan for the site and internal roadways needs to be provided. Access - Traffic The Application documents the legal access to the site along with a general description of the roadway as currently in use. A traffic analysis is provided which notes traffic impacts during the construction period (approximately 27 weeks) and minimal traffic during operations and reclamation. The report includes the finding that "No roadway improvements or turn lanes are anticipated to be required to support this project." 7 The existing roadway system appears to adequately accommodate industrial traffic accessing the site. A statement of adequacy including safety of the existing access road is provided with the Application submittals. Spill Prevention and Safety Compliance with all containment requirements for the storage of materials associated with the site needs to be maintained. Installation of all required containment shall occur prior to operation and copies of the Spill Prevention Containment and Control Plan (SPCC) for the site provided to the County once approved by the appropriate State Agencies. Operation plans including emergency notification information and procedures need to be maintained and kept current. Noise The Applicant's noise analysis provides an extimated noise level at the nearest property line (approximately 2,300 ft. to the north) at 35 db(A). This level is well below the County and COGCC limit of 50 db(A). The Applicant's noise mitigation plans include enclusure of compressors within fabricated strucures and critical grade silencers/mufflers. The report recommends noise measurements be taken after construction and while the facility is in operation to ensure regulatory compliance. This provision should be included as a condition of approval. Other Standards and Requirements • Dust mitigation plans for the roadways and site need to be documented in the Application Submittal. • Review of building code compliance as applicable for existing structures shall be required. • All pipelines serving the facility need to be properly permitted or exempt from permitting requirements. V. COMPREHENSIVE PLAN The Comprehensive Plan 2030 designates the site as Resource Production/Natural RPN. Surrounding properties include the same designation. Excerpts from Section 9, Mineral Extraction are provided below. Section 9 — Mineral Extraction - Policies 2. Mineral resource extraction activities will protect critical wildlife habitat as identified by state and federal agencies. Development within these designations that cannot be designed, constructed and conducted so as 8 to have a minimum adverse impact upon such habitat or these wildlife species shall be discouraged. 4. Facilities that are appurtenances to oil/ gas development activities (compressors, etc.) are considered appropriate in all land uses so long as they meet the respective mitigation requirements of the ULUR to maintain compatibility with surrounding land uses. VI. SUGGESTED FINDINGS The following findings are suggested should the Board of County Commissioner's consider approval of the Limited Impact Review. 1. That proper public notice was provided as required for the hearing before the Board of County Commissioners. 2. The hearing before the Board of County Commissioners was extensive and complete, that all pertinent facts, matters and issues were submitted and that all interested parties were heard at that meeting. 3. That for the above stated and other reasons the proposed Land Use Change Permit for a Compressor Station, Material Handling, and Storage, also known as the Wolf Ranch Compressor Station is in the best interest of the health, safety, convenience, order, prosperity and welfare of the citizens of Garfield County. 4. That with the adoption of conditions, the application is in general conformance with the 2030 Comprehensive Plan, as amended. 5. That with the adoption of conditions and granting of waivers from the roadway standards requirements, the application has adequately met the requirements of the Garfield County Unified Land Use Resolution of 2008, as amended. VII. RECOMMENDATION The following conditions are provided for the Board of County Commissioner's consideration regarding an approval of the proposed Limited Impact Review - Land Use Change Permit for the Wolf Ranch Compressor Station, submitted by Hunter Ridge Energy Services LLC in conjunction with Encana Oil and Gas (USA) Inc. 1. That 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. That the operation of the Wolf Ranch Compressor Station shall be done in 9 accordance with all applicable Federal, State, and local regulations governing the operation of this type of facility including SPCC Plans. Conditions Prior to Issuance 3. Prior to issuance of the Land Use Change Permit, the Applicant shall update the Application with a copy of the State Storm -water Management Permit for the site. Compliance with all Best Management Practices for the site shall be required. 4. Prior to the issuance of the Land Use Change Permit, the Applicant shall provide additional Dust Control — Mitigation Plans for the site including internal roadways and storage areas. 5. Prior to issuance of the Land Use Change Permit the Applicant shall update the safety and emergency procedures for the site to include reference to compliance with all Federal, State, Local, and industry safety and fire protection requirements. The emergency contact information and procedures shall be kept updated. 6. Prior to the issuance of the Land Use Change Permit, the Applicant shall provide confirmation that the site is covered by bonding for long term site reclamation. The Applicant shall also comply with the referral comments from the County Vegetation Manager, dated July 26, 2013 including provision of required security in an amount and form acceptable to the county for re -vegetation. Waiver Approvals 7. A waiver from Article VII, Roadway Standards is approved pursuant to the approval criteria contained in Section 4-117 of the ULUR. Other Conditions 8. The Applicant shall maintain proper permitting and compliance with CDPHE Air Quality Regulations including the Amine Plat. 9. The Applicant shall comply with all SPCC Plan provisions and provide the County with a copy of the final SPCC Plan once approved by the State. 10. All pipelines serving the facility shall maintain proper County permitting or be exempt from the County pipeline review. 11. The facility is approved for six compressor units. Once operational the Applicant shall provide additional noise measurements to ensure compliance with County and COGCC noise regulations. If compliance issues are noted by the noise readings the Applicant shall provide additional noise mitigation in order to achieve compliance. 10 12. Portable toilet facilities will be provided for employees during construction and periods where maintenance personnel are required to be on site for longer periods of time. 13. All equipment and structures associated with this permit shall be painted with non - reflective paint in neutral colors to reduce glare and mitigate any visual impacts. 14. The Applicants shall obtain proper Building Permits and Approvals as may be required for structures within the facility. Construction including foundations shall comply with the recommendations of the Yeh and Associates Geotechnical Investigation dated June 17, 2013. 15. All exterior lighting shall be the minimum amount necessary or required by the building code or industry standards, and shall be directed inward and downward on the site. 16. The Applicant shall comply with their Integrated Vegetation and Noxious Weed Management Plan including the best management practices described in Section 3.7, of the plan. 17. The Applicant shall maintain compliance with the CPW Wildlife Mitigation Plan in place for the site. 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'O ▪ r-1 Q OU -0 0 U (I) 0 0 U CU E E 0 V C c N C 'a O C .( j N - o p S C U O +� 0 C O �n Q C c' — }, C v 0 E .+_. f'6 O -0 Z U 2 +� -0 Q) U U C 13 c ,__E a 73 O U +, cp (00 U C CP N L S a--, La co b.a) fl- N = a j V V O E v Q -c o`~Q to ro ( N O0 -0 O c C° as tw L— c LnQ O u co < t1A ULU c 0C >•` C f0 .. U co c c 0+� co a) v +-. }J [D +-, w C >. = c c Q U c v o� �" CU v L C Q- CU .4_, a O w N 03 Q co O Q O N -a,U I— 2 cri 1- 0_ .-, u < l0 N to • L 0 V1 a, L 0 E O v u c ra cc 4- d July 22, 2013 Mr. Glenn Hartmann Garfield County Planning 108 8th Street, Suite 401 Glenwood Springs, CO 81601 RE: Wolf Ranch Compressor Station: LIPA-7589 Dear Glenn: MOUNTAIN CROSS ENGINEERING, INC. Civil and Environmental Consulting and Design EXHIBIT This office has performed a review of the documents provided for the Limited Impact Review Application of the Wolf Ranch Compressor Station. The submittal was found to be thorough and well organized. The following comments were generated: 1. The Applicant requests a waiver from roadway standards. The Applicant should be more descriptive on which standards in particular they are requesting to be waived. 2. One of the parcels listed on the adjacent properties has no ownership information. 3. The applicant provides a SWMP that covers a wide range of activities throughout the region. The SWMP states compliance with an existing permit that was not included in the application materials. A copy of the CDPHE Permit should be submitted for review. Feel free to call if you have any questions or comments. Sincerely, Mountaji Cross Engine ing, Inc. is Hale, PE 826 Grand Avenue, Glenwood Springs, CO 81601 P: 970.945.5544 F: 970.945.5558 www.mountaincross-eng.com July 26, 2013 EXHIBIT /0 Garfield County Glenn Hartmann Garfield County Community Development Department Vegetation Management RE: EnCana-Hunter Ridge/Wolf Creek Compressor Station LPA -7589 Dear Glenn, 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. Spotted knapweed is listed in the inventory as being near the project area. 1 believe this was addressed in the Grading Permit process by the applicant; my comments for the Grading Permit are attached. 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 2.6 acres. A revegetation security in the amount of $6,500 (2.6 acres x $2500/acre) is recommended. • 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. Steve Anthony Garfield County Vegetation Manager 0375 County Road 352, Bldg 2060 Rifle, CO 81650 Phone: 970-945-177 x 4305 Fax: 970-625-5939 Garfield County Vegetation Management June 7, 2013 Andy Schwaller Garfield County Community Development Department RE: Wolf Ranch Pipeline Grading Permit Dear Andy, The Integrated Vegetation and Noxious Weed Management Plan for this project is acceptable. The noxious weed, spotted knapweed, has been located within the 30 meter weed survey area. Staff requests that this infestation of approximately 50-100 plants be treated immediately and that the treatment application records be forwarded to this office via email to santhonvaciarfield-countv.com The surface area to be reseeded has been quantified as 6.72 acres. Community Development has requested a revegetation security of $16,800. 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, Steve Anthony Garfield County Vegetation Manager 0375 County Road 352, Bldg 2060 Rifle, CO 81650 Phone: 970-945-1377 x 4305 Fax: 970-625-5939 Glenn Hartmann From: Wyatt Keesbery Sent: Friday, July 26, 2013 11:31 AM To: Glenn Hartmann Subject: Compressor station Glen, Road and bridge has no issues with the proposed compressor station up cr. 215. Wyatt Sent from my Verizon Wireless 4G LTE DROID 1 E XHIBIT 11 Glenn Hartmann From: Morgan Hill Sent: Friday, July 26, 2013 3:13 PM To: Glenn Hartmann Subject: Wolf Ranch Compressor Station Hi Glenn, Thank you for taking the time to meet with me today. It was very helpful in answering my questions. My comments/questions are as follows: "Adjacent lands will not be impacted by the generation of vapor, dust, smoke, noise, glare or vibration." Impact Analysis, pg. 5 - The applicant addresses both noise from the Waukesha engines and their plans to apply for proper permits/notices from the CDPHE Air Pollution Control Division. However, while it is clear that there are no adjacent land owners that will be affected by any of the above-mentioned factors, I would like to see an acknowledgment that there will be dust, noise, and vibration present on this site as a result of both the construction process and the operation of a compressor station. The area of new disturbance is fairly large and will cause dust to be produced that can contribute to an increase in regional PM10 levels. This could simply be to mention that proper dust control will be utilized during construction and then include a reference to noise and air permits/controls. "All hydrocarbon based liquid storage will be in accordance with the SPCC plan that will be developed and implemented within six months of the construction of the project. " Impact Analysis, pg. 5 - While I trust that secondary containment will be constructed properly as mentioned, this statement is unclear. Does EnCana not already have an SPCC plan in place for that area or type of facility? Is six months a typical time frame for development of one of these plans? It would seem that a plan should be in place should a spill occur at any point after the facility has been constructed. Documents pertaining to stormwater management and the designs outlined in the site plan seem to be adequate. Applicant should be sure that system is functioning properly after its construction. Since there are no adjacent water bodies, I have no major comments related to water quality. Thank you for your consideration to my comments. Please pass along any relevant information related to the applicant's responses. Morgai ;me 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-countv.com/environmentahhealth 1 STATE OF CO EXHIBIT 1 13 John W. Hickenlooper, Governor Karin McGowan Interim Executive Director Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 60246-1530 Phone (303) 692-2000 Located in Glendale, Colorado http://www.cdphe.state,co.us July 16, 2013 Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Glenn Hartmann Garfield County Community Development Dept. 108 8th St., Suite 401 Glenwood Springs, CO 81601 RE: Encana-Hunter Ridge Wolf Creek Compressor Station Dear Mr. Hartmann: Colorado Department of Public Health and Environment On July 5, 2013, the Colorado Air Pollution Control Division (APCD) received a request for an air quality determination concerning Encana-Hunter Ridge Wolf Creek Compressor Station. APCD staff has reviewed the. request and has determined that the following provisions of the Colorado Air Quality Regulations apply to the project. All sources of potential construction project air emissions in Colorado are required to obtain a construction permit unless specifically exempt from the provisions of Regulation No. 3. Go to the website www.colorado.gov/cdphe/APCD to view this regulation - click on Air Quality Regulations, then Regulation No 3. Section II.D.1 lists which projects are exempt from requirements of the regulation. In addition, you will need to establish whether you are in an air quality attainment or non -attainment area, by accessing the information at www.colorado.govics/Satellite/CDPHE-AP/CBON/1251595265316. Once it has been determined that an Air Pollution Emissions Notice (APEN) is required, the next phase of air permitting involves submission of an Application for Construction Permit for each facility and one APEN for each emission source. A source can be an individual emission point or group of similar emission points (see Regulation No. 3, Part A). Both APEN reporting and perrnit requirements are triggered by uncontrolled actual emission rates. Uncontrolled actual emissions are calculated based upon the requested production/operating rate assuming no control equipment is used. In general, an APEN is required for an emission point with uncontrolled actual emissions of any critical pollutant equal to or greater than the quantities listed below: AREA UNCONTROLLED ACTUAL EMISSIONS Attainment Area 2 tons per year Non -attainment Area 1 ton per year All Areas Lead emissions: 100 pounds per year Sources of non -criteria reportable pollutants have different reporting levels depending upon the pollutant, release point height and distance to the property line. Please see Regulation No. 3 Appendix A and C to determine the appropriate reporting level for each pollutant, and for a list of non -criteria reportable air pollutants. However, none of the exemptions from an APEN filing requirement shall apply if a source would otherwise be subject to any specific federal or state applicable requirement. Information concerning submittal of revised APEN is also given in Regulation No. 3, Part A. An APEN is valid for five years. The five year period recommences when a revised APEN is received by the Division. If you have any questions regarding your reporting or permitting obligations, please contact the Small Business Assistance Program at 303-692-3148 or 3175. Land development construction activities (earth moving) that are greater than 25 acres or more than six months in duration will require an APEN from the Air Division and may be required to obtain an air permit. In addition, a start-up notice must be submitted thirty days prior to beginning a land development project. Please refer to the website www.colorado.gov/cdphe/APCD for information on APEN forms. Click on Construction Permit and Compliance Forms, then click on the menu item that applies to your project. If you have any questions or need additional information, please call the phone number(s) listed above, or you may call/ e-mail me directly at 303-692-3127 / jim.dileo@state.co.us. Thank you for contacting the Division about requirements for your project or permit. Sincerely, es A. DiLeo EPA Coordinator Air Pollution Control Division Colorado Department of Public Health and Environment