HomeMy WebLinkAbout4.0 Staff Report 06.15.2007June 15, 2007
Philip B. Vaughn
PVCMI Land Planning Division, President
1038 County Road 323
Rifle, CO 81650
BUILDING & PLANNING DEPARTMENT
RE: Cottonwood Compressor Station to Webster Hill 24 -inch Natural Gas Pipeline
Dear Mr. Vaughn,
Staff has reviewed the Pipeline ROW Application for the Cottonwood Compressor
Station to Webster Hill 24 -inch Natural Gas Pipeline submitted to this office on May 4,
2007.
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Staff understands this project generally consists of the construction of 8.3 miles of a 24 -
inch natural gas gathering pipeline, 2.0 miles of 12 -inch natural gas gathering pipeline and
two compressor stations to be constructed by Bargath, Inc to gather natural gas from
Williams Production RMT wells in the area.
The total disturbed acreage on private land is 109.34 -acres. Approximately 1.38 miles of
the pipeline are located on public lands, the remainder is located in private lands
comprised of 5 different owners. A large portion of the proposed line is located within
already disturbed right-of-way limiting new surface disturbance. The Applicant has
obtained signed surface agreements from all of the private properties over which the line is
proposed and these signed agreements were included in the submittal. These agreements
also contained maps that identified the permanent, construction, and staging area right -of -
108 Eighth Street, Suite 401 • Glenwood Springs, CO 81601
(970) 945-8212 • (970) 285-7972 • Fax: (970) 384-3470
ways. A typical map is shown here that clearly defines where activity is to take place on a
particular private property.
S aff understands the purpose of this line is to connect the outlets of four existing and wo
new field compressor stations to the upstream end of the recently constructed 30 -inch
gathering line. Once the gas has been collected and sent via this proposed 24 -inch line to
the existing 30 -inch line, it is then conveyed approximately 8 miles west to the existing
Williams Production RMT's Parachute Creek Gas plant for processing and delivery to
market. The two new compressors (Rabbit Brush and Webster Hill) being proposed are
appurtenant to this line and are, by definition, considered in this review as part of the
pipeline facility.
The two compressor
stations are to include two
"Caterpillar" type
compressor engines in a
building (60' x 235') at each
site with the expansion for
two additional compressor
engines at each site for a
total of 4 engines ate each
site. Noise studies were
included that show the
compressor stations can
comply with state statute
noise levels at full build out.
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S aff understands the purpose of this line is to connect the outlets of four existing and wo
new field compressor stations to the upstream end of the recently constructed 30 -inch
gathering line. Once the gas has been collected and sent via this proposed 24 -inch line to
the existing 30 -inch line, it is then conveyed approximately 8 miles west to the existing
Williams Production RMT's Parachute Creek Gas plant for processing and delivery to
market. The two new compressors (Rabbit Brush and Webster Hill) being proposed are
appurtenant to this line and are, by definition, considered in this review as part of the
pipeline facility.
The two compressor
stations are to include two
"Caterpillar" type
compressor engines in a
building (60' x 235') at each
site with the expansion for
two additional compressor
engines at each site for a
total of 4 engines ate each
site. Noise studies were
included that show the
compressor stations can
comply with state statute
noise levels at full build out.
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Upon an initial review, the Application was deemed technically complete on May 15, 2007
and has been reviewed against
the submittal requirements
required in Resolution 2005 —
53 and required in Section 9.07
of the Zoning Resolution of
1978, as amended. This letter
shall constitute Garfield
County's review of the project.
[The photo to the right shows
the view looking north towards
the main entrance to the Naval
00 Shale Reserve area where
this proposed line will cross
County Road 246.]
Staff referred the Application to the following Agencies / Departments whose comments
are included here for review and attached to this letter which is required by Resolution
2005 — 53:
A. Burning Mountain Fire Protection District: No comments received.
B. City of Rifle Fire Protection District: No comments received.
C. Garfield County Road and Bridge Department: The Garfield County Road & Bridge
Department has no objection to this application with the following comments:
1) There will be no entrances to any County roads for the project and the only
impact to the County road system will be during the construction of the
pipeline project;
2) All trucks hauling equipment or materials for the pipeline will abide by the
Garfield County Road & Bridge Department oversize/overweight permit
system; and
3) A utility permit number GRB07-U-39 was issued on May 4, 2007 for the
pipeline crossing for Cr. 246 for a road bore.
D. County Vegetation Management: The Vegetation / Rehabilitation Plan is
acceptable. This Department recommends a bond for revegetation security in the
amount of $272,500 to be held by Garfield County which is equal to $2,500 per
disturbed acre for a total of 109 acres.
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E. County Oil & Gas Liaison:
• 15 — Emergency Response Plan — Sec. II 2.a.4
o Several contacts were not included in the Regulatory Notification
description. Add the following contacts:
• Emergency Control Center — 911
▪ Colorado, Oil & Gas Conservation Commission — Jaime Adkins (970' 285-90K1
• Garfield County Assist Cowart Manager — Jesse Smith (970) 309-3440
• Garfield County Public Health - Jim Rada — (9 70) 623-5200 ext. 8113
• Garfield Counn' On & Gas Department —.Tuck Jordan — (970) 625-0973 est. 2006
• 1 — Emergency Response Plan — Sec. II 2.b.1
o The emergency plan states that \VPC personnel should be contacted in the
event of a tire. The Oil & Gas department would advise that the Emergency_
Control Center (Fire Department & Sheriff Department) should be
contacted immediately. A delay u1 notify the Emergency Control Center may
result in time lost and increased damage.
F. Mountain Cross Engineering: Reviewed the proposal and provided the following
comments which are also followed by the Applicant's response:
1) Pipeline crossings within the plan sheets state that crossings should happen
at, "...low flow period, if possible". The Nationwide Permit 12 requires that it
happen at low flow. The statement, "if possible" should be removed from the
details.
Applicant Reply: We agree that the Nationwide Permit 12 will guide the work
to be done within areas under the U.S. Army Corp of Engineers jurisdiction.
The attached ERO letter dated 4/5/07 details the requirements to be met.
2) The pipeline passes beneath an overhead power line between Sta. 107+71
and Sta. 109+72. Issues with equipment and overhead clearance and power
line appurtenances are not discussed. The Applicant should coordinate with
the power company to verify.
Applicant Reply: Please see Tab 22- Construction Management Plan of our
application packet. Page 21- "Health and Safety" of the Construction
Management Plan notes:
"Health and Safety - The following health and safety measures shall be
made a requirement of the pipeline construction work:
Special precautions shall be taken when working on pipeline segments
parallel to, crossing or near high voltage overhead electric power
transmission lines. These precautions shall include:
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Measuring the pipe -to -ground voltages on pipe sections each day at
the commencement of work, prior to work involving pipe contact and
when directed by a qualified person.
Rubber tired vehicles operating on a common pipeline and powerline
ROW area shall be strap grounded to mitigate capacitive coupling.
Grounding shall be made using a metal chain or conductive strap
connected to the vehicle frame and contacting the ground.
➢ Vehicles shall not be refueled on or near an electric powerline ROW.
The pipeline contractor shall coordinate with affected utilities to avoid
utility disruptions."
Full compliance with OSHA regulations are noted within the contract
documents. 29 CFR 1926 Subpart K, Electrical, OSHA Standard
1926.550(a)(15) and other sections within the regulations note that a
mimimum of 10 feet must be maintained between equipment and energized
overhead power lines. 1926.550(a)(15)(i-ii) additionally notes that lines rated
over 50kV., minimum clearance between the lines and any part of the crane
or load shall be 10 feet plus 0.4 inch for each 1 kV., or twice the length of the
line insulator, but never less than 10 feet. Additional safety precautions will
include warning signage on both sides of the overhead power line alerting
personnel of energized overhead powerlines.
3) Whether or not any of the jurisdictional drainages also have mapped
floodplains is not discussed. Garfield County flood plain permits may be
required.
Applicant Reply: The ERO letter dated 4/5/07 notes that four of the drainages
are ephemeral and that Balzac Gulch is intermittent. I spoke with Clint
Henke with ERO on 6/8/07 regarding this question of floodplains. Clint and I
agree that these drainages have not been mapped by FEMA and I have
verified such on the FEMA mapping website. Additionally, the installation of
buried utilities within any drainage does not effect the flood elevation, as this
is a temporary disturbance of the drainage and this piping is immediately
backfilled. This disturbance is regulated through the NWP 12 noted above in
question #1. ERO noted that this is consistent with their work in other
jurisdictions as well. I have additionally reviewed section 6.00 of the Garfield
County Zoning Regulations "Floodplain Regulations" and find that the activity
of utility installation, below grade of the bottom of a drainage, does not
require a floodplain development permit in Garfield County.
4) Several roads will be inaccessible during construction of the pipeline
crossings. It is not discussed what roads will require access to be maintained
and means of doing so.
Applicant Reply: The roadways to be directly impacted within this project are
all roads on private property. Safety barriers will be maintained to ensure the
safety of workmen and workmen traveling on private property. County Road
#246 will be bored and this traffic will not be impacted.
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5) A CDOT permit will be required.
Applicant Reply: Please find attached a letter to Fred Jarman dated 6/7/07
requesting an amendment to delete the 12" Rulison jumper line that would
have required a boring of 1-70 and a Special Use Permit from CDOT. This
permit is no longer required.
6) It is not clear whether or not the Bureau of Land Management has the
authority to give approvals for construction on the lands of the United States
Naval Oil Shale Reserve.
Applicant Reply: Naval Oil Shale Reserve -1 -Properties East of Parachute,
CO and Naval Oil Shale Reserve -3- Anvil Points Oil Shale and Research
Facility was transferred to the U.S. Department of Interior via U.S. Senator
Ben Campbell legislation in the late 1990's.
It appears that Parcel numbers 2173-222-00-951 and 2175-082-00-953,
noted on sheets 3, 4 and 5 of the alignment sheets within Tab 2, are noted as
U.S. Naval Oil Shale Reserve but have indeed been transferred to the U.S.
Department of Interior. Conversations and negotiations between Williams
Production RMT Co. landmen and the U.S. BLM have confirmed the details
of this ownership. We have mailed notice to the U.S. Naval Oil Shale
Reserve in c/o the U.S. Department of Energy office in Grand Junction simply
because the federal agencies have not updated the files of the Garfield
County Assessor's office.
7) An agreement with the Bureau of Land Management has not been executed.
Applicant Reply: This is correct. The SF 299 was submitted to the U.S. BLM
on 3/13/07 and is attached in Tab 7. After the license is approved by the
BLM a copy of this will be submitted to Garfield County for their files.
8) To mitigate building movement and settlement, the recommendations of the
geotechnical engineer are that the buildings be built on piers. The use
planned for the buildings may not allow movement and may be required to be
built with pier foundations.
Applicant Reply: We will follow the recommendations of Geotechnical
Engineering Group in regards to construction of the Rabbit Brush and
Webster Hill compressor stations. Each of the buildings has building permit
applications under review by the Garfield County Building Department.
9) The application does not discuss whether or not sewer and water facilities
will be necessary for any employees.
6
Applicant Reply: The compressor stations will be unmanned facilities with
one employee reviewing the facility daily. There will be a portable toilet on-
site and water will not be supplied on-site.
10) The traffic impacts discuss construction traffic, which is temporary in nature.
The application should discuss the post construction traffic anticipated and
the impacts that traffic will have on the surrounding roads.
Applicant Reply: The compressor stations will be unmanned facilities with
one employee reviewing the facility daily. During maintenance, one
additional service truck and employee will be on-site. This would equal 4
average daily trips to each of the compressor stations. All of these trips will
access CDOT Highway 6 & 24.
11) In the noise analysis, the decibel levels at the eastern property line have not
been detailed.
Applicant Reply: Please see Tab 23- Review Criteria. Attached within is the
HFP noise model prediction dated 4/30/07 for the Webster Hill Compressor
Station. A schematic on page 7 of the report notes that the phase 2
expansion of the station will maintain less than 65 dB(A) 350 feet from the
facility. The outline noted within this diagram as "Property Line" is incorrect.
This is the lease line of the facility. The distance between the lease line and
the W.F. Clough property line is actually in excess of 1,000 feet in all
directions.
Also attached within is the HFP noise model prediction dated 4/30/07 for the
Rabbit Brush Compressor Station. A schematic on page 7 of the report
notes that the phase 2 expansion of the station will maintain less than 65
dB(A) 350 feet from the facility. The outline noted within this diagram as
"Property Line" is incorrect. This is the lease line of the facility. The distance
between the lease line and the ExxonMobil property line is actually in excess
of 500 feet in all directions.
Determination of Review
Upon substantive review of the documents submitted against the required standards and
criteria in Section 9.07.06, Staff has made a determination of Approval with Conditions for
the Cottonwood Compressor Station to Webster Hill 24 -inch Natural Gas Pipeline.
The specific conditions include the following:
1. Any equipment used in construction or operation of a pipeline must comply with the
Colorado Oil and Gas Conservation Commission Rules and Regulations, Section
802, Noise Abatement. Additionally, all power sources used in pipeline operations
shall have electric motors or muffled internal combustion engines.
2. Pipeline operations shall be located in a manner to minimize their visual impact and
disturbance of the land surface. Facilities shall be painted in a uniform, non -
contrasting, non -reflective color, to blend with the adjacent landscape. Right-of-way
shall be located in existing disturbed areas unless safety or visual concerns or other
adverse surface impacts clearly dictate otherwise,
3. All access and oversize or overweight vehicle permits shall be obtained from the
County Road & Bridge Department prior to beginning operation. Any new roads or
intensified driveway accesses created as a result of the pipeline construction,
intended to be permanent for maintenance and repair operations shall be placed
behind a locked gate or other barriers preventing use by recreational vehicles. Any
gates or barriers need to be consistent with the surface owner's preferences.
4. Revegetation along the pipeline corridor and along the County Road for the
crossings shall be required to be approved by Garfield County Vegetation Manager
and the ROW restoration will be approved by Garfield County Road & Bridge
Department representative.
5. All vehicles working within Garfield County Right of Ways will be licensed and
registered in the State of Colorado. All vehicles hauling equipment and materials for
the pipeline construction will abide by Garfield County Road & Bridge Departments
oversize/overweight regulations. All vehicles requiring an oversize/overweight
permit will send a letter showing proof that they can operate under a known bond
holder on file with Garfield County Road & Bridge Department before a permit will
be issued.
6. The Applicant shall provide the County with a revegetation security for fee lands in
the amount of 9272,500.00 for 109 acres disturbed. Additionally, the Applicant shall
submit the original tags from each seed bag. The seed mix in the Plan shall match
the seed mix used in the field. Seed mix containing yellow sweet clover (Melilotus
offcinalis) or annual yellow sweetclover (M. indicus) shall not be used. The amount
of seed specified to be planted in the Plan shall match the quantity of seed used in
the field. The security shall be held by Garfield County until vegetation has been
successfully reestablished according to the Reclamation Standards in the Garfield
County Weed Management Plan. It is the responsibility of the applicant to contact
the County, upon successful revegetation establishment, to request an inspection
for security release consideration.
7. The Applicant shall provide the County with a digital alignment of the pipeline once
constructed in a format readable to the County Geographic Information System
(GIS) analyst.
8. In no case shall an operator engage in activities which impact Federal or State
threatened and endangered species.
9. Air contaminant emissions shall be in compliance with the applicable permit and
control provisions of the Colorado Air Quality Control Program, Title 25, Resolution
7, C.R.S.
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10. Prior to the issuance of a permit, the Applicant shall satisfy the following comments
from the County Oil & Gas Department:
• 15 — Emergency Response Plan — Sec. II 2.a.4
0 Several contacts were not included in the Regulaton• Notification
description. _*dd the following contacts:
• Emergency Control Center — 911
• Colorado Oil & Gas Conservation Commission — Jaime Adkins (970) 285-9000
• Garfield County Assist County Manager —.Jesse South (9'0) 309-5440
• Garfield Count- Public Health - Tim Rada — (970) 625-5300 est. 8113
• Garfield County Oil & Gas Department—Judy Jordan— (970 635-0973 ext. 3006
• 15 — Emergency Response Plan — Sec. II 2.b.1
o The eurergencv plan states that WPC personnel should be contacted in the
event of a tire. The Oil & Gas department would advise that the Emergency
Control Center (Fire Department & Sheriff Department) should be
contacted immediately. A delay in notify the Emergency Control Center may
result in time lost and increased damage.
11. A1/ operations shall comply with all applicable Federal and State Public Health and
Environment, Noise, and Air and Water Quality Control standards.
12.Any proposed waste disposal or treatment facilities shall comply with all
requirements of the County Individual Sewage Disposal System Regulations.
13. Should an abandoned pipeline be removed, it will be subject to the original
revegetation and weed management requirements in the original application.
14. There will be no entrances to any County roads for the project and the only impact
to the County road system will be during the construction of the pipeline project.
15. Portable toilets to be used on site at the two compressor stations shall not be visible
from any public right-of-way.
Finally, this determination shall not be final, and no permit based upon the determination
shall be issued, for 14 calendar days after the date of the determination in order to allow
time for the Applicant to appeal, or for the Board of County Commissioners to call up the
determination for further review, pursuant to Sections 9.07.08 and 9.07.09 of the Pipeline
Resolution.
This determination shall become final, and permits applied for in accordance with the
determination may be issued, only after the expiration of this 14 -day period, and only if the
determination is not reviewed and acted upon by the Board of County Commissioners at a
subsequent appeal or call-up hearing. This determination has been sent to the Board of
County Commissioners to determine if they wish to call up the matter. Staff will let you
know if this matter is called up within the next 14 days which will expire on June 26, 2007.
(Note, the permit cannot issue until all conditions have been met.)
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Do not hesitate to contact this office if you have any questions.
Very truly yours,
Fred A. Jarman, AICP
Director, Building & Planning Department
970.945.8212
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