HomeMy WebLinkAbout2.0 BOCC Staff Report 10.3.2011Board of County Commissioners - Public Hearing Exhibits
Rutison Compressor Station - Noble Energy lnc.
Joan Savage PropertY Owner
Limited lmpact Review
October 3,2011
(File LIPA-6893)
Exhibit Letter
(A to Z)
Exhibit Description
A Proof of Publication
B Return Receipts from Mailing Notice
C Photo evidence of Public Notice Posting
D ffind Use Respqlg! {29q9.as amended
E Garfield County Comprehensive Plan of 2030
F Application
G Staff Report
H Staff Presentation
I Referral Comments from Garfield County Consultlng Engineer
J Referral Comments from Garfield County Vegetation Manager
K neterrarcomments from Garfield County Road and Bridge Department
L Referral Comments from Garfield County Oil and GaS lgpq4rned
M Referral Comments from Garfield County Environmental Health
Manager
N Referral Comments from the Rifle Fire Protection District
o the APP|icant including uPdated
Environmental Effects - Wildlife Analysis (dated July 20,2011)
P Applicant's Response to Referral Comments and Staff 89p9!
o
R
S
T
U
V
W
X
EXHIBIT
G
REQUEST
APPLICANTS
REPRESENTATIVE
ASSESSOR'S PARCEL #
PROPERTY SIZE
LOCATION
ACCESS
EXISTING ZONING
BOCC 0610612011
File No. LIPA-6835
GH
Limited lmpact Review for a Compressor
Station
Joan L. Savage (PropertY Owner)
Noble Energy lnc.
Grant Griffin & Lorne Prescott
Olsson Associates
2405-084-00-024
The site is located on approximately 5.74
acres of a 663 acre parcel.
Approximately 3.5 miles southeast of Rulison,
approximately 0.25 miles southwest of County
Road 329 and 350. The site is located in the
E1t2 of Section 8, T7S, R94W, Garfield County,
CO
Approximately 0.1 of a mile of existing private
access road off of CountY Road 329
Rural
PROJECT INFORMATION AND STAFF COMMENTS
I. GENERAL PROJECT DESCRIPTION
Through the Limited lmpact Review process, the Application is requesting approval for
a Compressor Station with a total of six (6) compressor units. The site has previously
been developed and constructed with two (2) of the compressor units already in place.
The current Application is intended to bring the existing facility into compliance with
Garfield County's Land Use Regulations and allow for the expansion of the facility.
The Application is being processed consistent with all code requirements for a new
compressor station site.
The Compressor Site is approximately 500 ft. by 500 ft. and 5.74 acres in size.
Existing and proposed improvements on the site include: Compressor Units,
Containment and Antifreeze Tanks, Pig Receivers, Meters & Scrubbers, and related
support infrastructure. The site has been in operation for approximately 3 years
(constructed in 2OO7 & 2008) and has an operational expectancy of approximately 30
years. lt will serve Noble Energy lnc. gas wells located in the area and is requested
based on increasing gas production. The site is connected to neighboring gas wells
by an existing 20" pipeline approximately 5,500 ft. in length. An additional 500 ft. of
pipeline will be constructed as part of the final build-out of the total of 6 compressor
units. Separate permits for the pipelines are not required based on their size and
length.
The compressor units will be housed in sound attenuating structures with "hospital
grade" muffler systems. The application represents that the site will be fenced to avoid
iivestock conflicts. No water use is anticipated or needed for operation of the site and
a portable toilet will be provided for use by the occasional inspector or operator. There
is adequate space on the site/pad for vehicle parking, construction activity, and vehicle
circulation.
It. LOCATION . SITE DESCRIPTION . ZONING
The Site is located off of County Road 329 generally between Spruce Creek and
Cache Creek. lt is accessed by 0.1 of a mile of private road which is located 0.4 of a
mile beyond County maintenance on County Road 329. The topography slopes down
to the north with an estimated undisturbed grade of approximately 13%. The site was
constructed in an area characterized as "mixed mountain shrubland" with oak brush -
Gambel Oak vegetation.
Approximately 2 acres of
area was disturbed and
re-vegetation and mulch
applied to the disturbed
areas in September of
2008 and August of
2010.Containment
berms and vegetative
buffers are included in
the best management
practices for the site.
The site is enclosed bY
an existing fence. Power
lines exist to the site.
The site is zoned Rural
and zoning in the vicinitY
is Rural and Public
Lands. Adjacent land
uses are PrimarilY
agricultural and open
space. Oil and gas development is found in the vicinity including several well pads on
the Joan Savage Rulison Acreage).
III. STAFF COMMENTS AND ANALYSIS
ln accordance with the ULUR regarding Limited lmpact Reviews, Staff has considered
applicable provisions of Section 4-502(D) Land Suitability Analysis, Section 4-502(E)
lmpact Analysis, the general development standards found in Article Vll, and specific
standards for lndustrial Uses contained in Section 7-810. Key topics for the review are
covered in the following sections.
afrffi
__---.' \::l
Site Plan - Facilities
The site plan includes detailed information on proposed and existing facilities, access
to the site, fencing, berming of the site, and related infrastructure. The site is in an
area with moderate slopes with some cut and fill created to facilitate leveling and
grading. The pad itself is generally level with slopes of 0o/o - 2%. The access road
irom the west has relatively steep grades. The Applicant has clarified on the site visit
that no new fencing is anticipated and that the existing wire livestock fencing will be
maintained.
The existing compressor units are represented in the Air Quality Permitting to be 1340
hp. natural gas type of units, Caterpillar Model G3516LE. The Application does not
piovide detiils on the type of building (model) and sound attenuation systems being
currently utilized, however, they have represented that the proposed compressor units
would have the same type of building and mufflers as the existing units, consistent,with
the noise study assumptions.
Air Qualitv
The Applicant has obtained CDPHE Permits for the two existing compressor units and
provided copies with the Application submittal. The Applicant has represented that the
same type of compressor units will be used for future installations. Compliance with
the curient CDPHE Permits shall be required and the Applicant shall obtain the proper
construction and operation permits from CDPHE for each successive compressor.
NOBLE ENERGY, INC.
RULISON COMPRESSOR STATION
Construction Schedule
The Applicants indicate that construction of one additional compressor
commence upon approval of County permitting during the Fall of 201'1.
compressor units may be installed over time as the demand warrants.
unit may
Additional
Traffic
The Applicant's traffic analysis for the operational phase of the project estimates 5
vehicle trips per week, one per day and an overall ADT of 1.2 vehicles. The analysis
did not provide information on the construction phase as the facility is largely
constructed at this time. The analysis should be supplemented to clarify any impacts
related to the construction/installation of additional compressor units.
Noise
The Applicant has provided a detailed noise analysis which addresses noise
generation for the full build-out of 6 compressor units. The Applicant's analysis
indicates that the facility will be in compliance with State standards for noise generation
with the exception of the southeast property line during nighttime hours where the
estimated noise is 51.1 db(A) and the standard maximum level allowed is 50 db(A).
The Applicant will need to
provide add itional analysis
demonstrating complianceor propose additional
mitigation measures.
The Applicant shall also
provide documentation asto the type/model ofsound attenuating
structures to be
constructed and mufflers
to be utilized. Given the
extended time frame over
which compressors may
be added to the site and
the variables associated
with maintaining noise
compliance, it is
recommended that prior to
operation of each new
compresso(s) added to the site an updated noise analysis may be required to ensure
ongoing compliance with State standards.
Reclamation Plan
The Application reflects that reseeding and stabilization (mulching) reclamation efforts
were previously undertaken in 2008 and 2010. ln accordance with the Garfield County
Vegetation Manager's comments (see attached) the Applicant needs to provide a
calculation of the area of disturbance outside the industrial footprint and provide
reclamation security if determined necessary in accordance with the County
regulations and policies.
Excerpt from
Noise Study
A long term reclamation plan is provided in the Application for returning the site to
naturjl conditions at such time as the compressor station is no longer operational.
Spill Prevention Plan
A detailed Spill Prevention Control and Countermeasure Plan is provided with the
Application. The Plan includes Spill Response Procedures and Emergency Contact
information. The Plan needs to be updated for the Rulison Compressor Station to
reflect the additional Compressor units and any changes in tank capacities and storage
occurring on the site.
The Plan and Application material needs to be updated in response to the Rifle Fire
Protection District referral comments (see attached) and to document safety and
emergency procedures, technology and equipment required for operation of the facility.
Article Vll - Divisions I and ll
The Applicant has adequately addressed the provisions of Divisions I and ll as
summarized below subject to conditions of approval:
o lmpacts on land use in the vicinity of the site are not anticipated based on
current uses. The County Oil and Gas Department has indicated that there are
no documented violations associated with the current two compressors.
. There is no potable water demand associated with the facility.
o A portable toilet will be provided for construction workers and maintenance
inspectorso No new roads are proposed and comments from Garfield County Road and
Bridge have been received (see attached) indicating no concerns.
. The Application indicates that dust from private roads will be mitigated as
appropriate.. No geologic, slope or soils hazards have been identified for the site.
o The site will be fenced to mitigate any impacts on agricultural uses, livestock or
wildlife.o A wildlife study was provided with finding that the facility will not impact federally
listed species or designate critical habitat.
o Potential impacts on wetlands, water bodies, and water quality is mitigated by
compliance with Best Management Practices (BMP's), Storm Water
Management Plan and Spill Prevention Control and Countermeasure Plan
(SPCC Plan). Copies of Air Quality Permits have been provided for the existing compressor
units and conditions of approval shall require obtaining additional permits as
required by the State.o Building permits and building code compliance shall be required as applicable.
7
Land Suitability Analvsis and lmpact Analvsis - Sections 4-502(D) & 4-502(E)
The Applicant's Land Suitability Analysis reflects the lack of any significant issues of
concern relating to use of the site for a compressor station. The lmpact Analysis is
supported by a variety of studies, submittals, and permits intended to mitigate impacts
associated with the facility. Key components of the Land Suitability Analysis and
lmpact Analysis are summarized below:
Land Suitability Analysis:
. Access is from County Road 329. A portion of the access is across an
unmaintained portion of the County Road. Access to the site from the County
Road is across Joan L. Savage property.
o Any easements for the existing power lines shall be shown on the site plan.
o Topography and slopes are well documented as moderate.
. Natural features are reflected in the submittals and are compatible with the
proposal.
. Drainage is address by the Storm Water Management Plan.
o The use has no water demands and the site is not impacted by flood plains.
. Soils characteristics and the lack of geologic hazard are analyzed in several
reports and information submitted by the Applicant.
o Natural habitat and wildlife impacts are addressed in an updated Study dated
712012011 and included as an exhibit.
. The applicant's Cultural Resources Study recommended a finding of no historic
properties affected.
lmpact Analysis:
. Property Owners and Mineral Rights Owners are properly documented.
. Adjacent uses are rural, agricultural, open space, and oil and gas related.
. Site features, soils characteristics, and lack of geologic hazards are well
documented in the submittals.
o With no water demand/use on site, no impacts on ground water are anticipated.
. Environmental Concerns are addressed by a series of reports including: Wildlife
Sensitive Areas Report, SPCC Plan, Stormwater Management Plan, Cultural
Resources Report.
o A Traffic Study reflecting minimal traffic and related impacts was provided.
o A Noise Analysis was provided analyzing estimated noise generation and
identifying some compliance issues with State noise standards.
o A long-term reclamation plan was provided.
Additional Standards Applicable to lndustrial Use (Section 7-810)
The Applicant will comply with the Additional Standards for lndustrial Uses noted as
follows:
. Each compressor will be located in a "sound attenuated" structure with hospital
grade mufflers. The Applicant will need to provide additional details on the
installations to enable verification of compliance.
o The Applicants activities are located on private property within an existing lease
with the private property owner.
o The Site will be enclosed by fencing - with no storage of heavy equipment or
materials proposed by the Application.
o lndustrial waste will be disposed of in accordance with Federal, State and Local
regulations and the Applicant has a Spill Prevention Control and
Countermeasure Plan (SPCC) in place.
o The Applicant's sound analysis is the subject of several referral comments and
conditions of approval to ensure compliance with State standards.
. The Applicant represents that ground vibration will not be measurable at any
point along the property boundary lines.
o No other impacts, interference, nuisance or hazards are anticipated by the
compressor station.
M. COMPREHENSIVE PLAN
The Comprehensive Plan 2030 designates the site as Res-MH (2 to < 6 Ac/Du).
Surrounding properties are also designated Res-MH with some Open Space/Public
Land designations south and east of the site. The site is zoned Rural which provides
for Compressor Stations to be reviewed through the Limited lmpact Review Process.
Excerpt from Section 9, Garfield County Comprehensive Plan 2030
Secfion 9 - Mineral Extraction - Policies
2. Minerat 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
to have a minimum adverse impact upon such habitat or fhese wildlife
species, shall be discouraged.
4. Facitities 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.
The location and design of the proposed Compressor Station is in general
conformance with the Comprehensive Plan Policies subject to proper mitigation of
impacts including but not limited to air quality and noise.
9
V. PUBLIC NOTICE 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 on the Application have been received by the County at this time.
Comments have been received from the following referral agencies and County
Departments. They are summarized below and attached as Exhibits.
1. Garfield County Road and Bridge Department: lndicated no issues'
2. Garfield County Consulting Engineer, Chris Hale, Mountain Cross Engineering:
ldentified three comments addressing access and noise.
3. Garfield County Oil and Gas Department, Denise Brown: Responded that no
evidence of any Notice of Active Violations were found for the site.
4. Garfield County Environmental Health, Jim Rada: ldentified air quality permitting
and noise compliance as two issues.
5. Garfield County Vegetation Manager, Steve Anthony: Provided comments on weed
management and irecommendation for site reclamation and related security.
10
6. Rifle Fire Protection District: Identified a number of concerns with documentation
associated with the Spill Prevention Control and Countermeasures plan including
the need to update inspection dates, provide executed copies, update contact
information for ihe fire protection district, and demonstrate compliance with required
containment capacities. The District also requested that the Applicant contact their
Oil and Gas liaison and provide a variety of information on operations and safety
topics.
The Application was also referred to the following agencies with no comments received
at this time.
1. Colorado Department of Health
2. Colorado Division of Wildlife
3. City of Rifle
4. Bureau of Land Management
VI. SUGGESTED FINDINGS
The following findings are suggested should the Board of County Commissioner's
consider approval of the Limited lmpact Review.
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, tnat att pertinent facts, matters and issues were submitted or could be
submitted and that all interested parties were heard at that hearing.
3. That for the above stated and other reasons, the Land Use Change Permit for a
Compressor Station is in the best interest of the health, safety, morals,
convenience, order, prosperity and welfare of the citizens of Garfield County.
4. That the application is in conformance with the applicable Sections of the Garfield
County Unified Land Use Resolution of 2008, as amended and in general
conformance with the Garfield County Comprehensive Plan 2030.
VII. RECOMMENDATION
The following conditions are provided for the Board of County Commissioner's
consideration regarding an approval of the requested Limited lmpact Review - Land
Use Change Permit for the Rulison Compressor Station, submitted by Noble Energy
lnc., located on property owned by Joan L. Savage:
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.
1.1
4.
That the operation of the Noble Energy Inc. Rulison Compressor Station be done
in accordance with all applicable Federal, State, and local regulations governing
the operation of this type of facility.
3. Prior to operation of any additional compressor units, the Applicant shall
demonstrate full compliance with all CDPHE Air Quality construction and
operations permitting requirements.
Prior to installation of any additional compressor units, the Applicant shall
supplement their noise analysis to confirm compliance with State regulations on
maximum noise generation including operation during nighttime hours (7:00 p.m.
to 7:00 a.m.). The updated study shall also provide clarification as to the type of
sound attenuating buildings and type of hospital grade mufflers to be installed.
The Applicant shall maintain compliance with State regulations on maximum noise
generation and the County may require additional noise analyses at the time of
building permit review associated with the installation of additional compressor
units to verify compliance.
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.
All structures and fences shall obtain building permits from the Garfield County
Building and Planning Department if required by County regulations.
All exterior lighting will be the minimum amount necessary or required by the
building code and industry standards, and shall be directed inward and downward,
except that provisions may be made to allow for safety lighting.
The Applicant shall comply with the recommendations of the Garfield County
Vegetation Manager and shall provide a calculation of the disturbed area outside
the industrial footprint, and shall provide reclamation security as determined by
the Vegetation Manager in accordance with the County Regulations. 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 re-vegetation establishment to request an inspection for
security release consideration. The reclamation standards at the date of permit
issuance are cited in Section(s) 4.06, 4.07, and 4.08 of the Garfield County Weed
management Plan (Resolution No. 2002-94)
The Applicant shall maintain compliance with the existing weed management plan
including management of any weed or thistle problems on the site. As may be
determined necessary by the Garfield County Vegetation Manager, annual site
visits may be conducted to ensure that any weed problems are properly managed.
5.
o.
7.
8.
9.
72
10.
11.
12.
Prior to issuance of the Land Use change Permit, the Applicant shall supplement
the Traffic Study to address construction related traffic. The Applicant shall
provide dust control measures as represented in the Application submittals with
particular attention to periods associated with additional site construction and
installation of compressor units.
Compliance with the Applicant's Storm Water Management Plan, Storm Water
Discharge Permit and Best Management Practices shall be required.
Prior to operation of any newly installed compressor units the Applicant shall
provide the County with an updated fully executed Spill Protection Control and
Countermeasures Plan (SPCC) that includes the proposed 6 compressor units,
any updated containment requirements, and demonstration that the proposed site
is in compliance with the provisions of the SPCC Plan. The Applicant shall
include with said update documentation of safety and emergency procedures,
technology and equipment required for operation of the facility in compliance with
all Federal, State, or Local, and industry requirements.
Prior to issuance of the Land Use change Permit the Applicant shall provide the
Building and Planning Department with a letter from the Rifle Fire Protection
District or other acceptable evidence indicating that the Applicant has satisfied the
Fire District's SPCC Plan questions and related concerns contained in their email
correspondence dated September 27, 201 1 .
13.
13
t4
EXHIBIT,L11!oDc
oarFgOJYTO-r-(!uOtlOsja
3 E co c:arEo9o I'=orl-r-8
t 3H i= ao
e=co.9.L\\J- 11 t- u-J .=EJq +orE!g-D
-]- o <-o cxfl\-ooJq./ 7\ (J !- -.isd 6z 3E 3
=od
tJco A c)\., d.
oiiiE cJ 0Jr-OC3PF o-O
ool-o
C
LU
S-olnlnol-o-
EoU
Coln
:
-J
E,
Co
a-Pc,+,v1
(u
-ooz
i(---- -)\ '-\ -,-\ "/(.; )-'---i 'r/ -i 1R\---\-1
\,\,\
I\*-l
Vtd
'-,,',"'(
iri )i
\*-
f\\ i
\i
J'r)
-.!--,).- \-,
i'"
-t'^,
.." i- /
\t= r --f\I i,.---r'|I lt e i----*---i
"'*1 a
I
I
I
I
I
I
I
I
0
|ri \
I
" r{-^\ , .-'t'il )i'
)f; i \ r-..'.i,.. \ i
i\ i I. i'. i rL'- | --1------ |l ---aat\1
3.9p?o-o
=(oL)(,
I
I
I
I
f, .1ll n !
I ' ..]'-{
, \ -r'\-
i\'. l-
"Y\_
lt
fI,t
I
)
l
*94
?,trf,oorrt- Co=
AE
I'7
Ao
.=th
o
.CP.I
o(U<u
#a -Ft.- LJv) '6
.C+,l-oC
Co
Co
a-+)(I,
E(t,
-Uol-
\r/
o
.CPq-o
=o
o
.E
v1q-oo.=o(/IEo'6
a-l--Pfl
lL-b6
=afr(I).Y O_
a
P
=(J
Iirt,
'!'$'t:
,Ai
bo
C'6
Colal-
OL'l-) I-
tr) .9YE..L FPtrq-(UoE
=Eor.-l
E'6
+)VIo
=
\r/
..lj\ ,)),\*l Iilt1r
i\lrllllllttirr!
I
t\
\\
\'lirtt
!iiitli!
i\
\\
iil\ \tti
ili iIi/[ ivt
n#
m" ti
ll+ai1!-m t'.. i
ffitr i
r-Et' t,
lrj- li)a '.
zo
t-r){1a
-rVFOHtru). LU IIJ' z fut {LErrl 5E(JOzzo
U}
=:f
0a
L]l=lloll>ltG, IlJll-llolI a Ilurllolll-lI o-llEllolB
a
Ot-
=€
';
Eb -0g,-(Jr.Co.-.
IJ.J -_ -Co* :r.n-OO-gr5 E5 2:- bN oE c
*Ea E-E€E EC O=OY.___v-l_y,9 E EE bfl 8 pL
==<l.l'=Fc
E f
=
3 83o.g o 6 trN9 o- i: rocH bo?o'.--g HEE us
0J .9 == (uo.E '= 6 = P- oA uJ v1 E vt N
tn!-o
-o-o
=l-(Ja
E
C
G'
tnl-oPoCT-
uil-o
.=(u(Jol-
.9po-
aJ
C(o+,
oNool-
=PC(o
E
C
(t,
PCo
E
.=(o
{JCo(J
oo
.=E
=E
.=
+)Co
Eo-
Ju
IJ.J
l-otnao(J(J
o
p.E
-P
=G,-) {-,t_a
O!-aOalhOtnl-(UO- !-
a...--o-L-otr:8':U/'E
b:
(osf
{-J l\P 'r;
6aoo-ol-o-
q-o
l-(u
E
E
-J(n
oo
C
.ltln'Xo
\u +)
Nq\-/
VIC?oool- .- '-
-PPicvt(oirr O Eb'. g {Ero o- c:
= : .s.gn'av1 ;s2 vt? e* .oI qE HEI.E'fr.-€P o=.=
:= == E E (,3'6
EEsEgE#+ig
iEi2E=s,E€fEE,r"rA"rAkgS
tn'6
->(t,
C
t{-q-
((,+)a
ooaOO
oth.nECo-o
F {-,6s(J(,
boC
a-o-o-(I,
C(t,
-o-
o
.za
Co1-&ol-o-
EoU
$-,E EEEEEr -;Eq
EE]$ = iE i:
Eitig
5E FSI
t$EEs Eil €I ;EiE
TEIEEiEi$iE EusEE
EEigI$$[$Eg ;$EsE sHEFI il!{: gt;i
E SsEts sE*s
Pxg
C
((,
o-
o
.=a
C(u
.Col-o-
EoU
EC
(UJO
't=o 9=E-.FI E E==v€ €^=EsE l-,LE EEE$ :!-=
83'F,q-s 'iLo9'=fi:Ez, Eoo
sEH$EFEeaio - i: E H E HqS; { =a E E f; o Ef,-,q
E g 5 -" E g E TEE
EEEEEeE=-bxto = = = = = I trP tr:5888818E8
=EEEE=.= EFo= o o o o orJ- oHHIEEEEE#:AEz (9 (, (, (, (9 E z. o z
tn
{-,Co
E
Eo(J
-c,l-l-(uq-o
E.
E
C(t,
.9
-_o
-Jo-
'a Eg ,o El- o Ea : 'ls # e= E i E.0 sr 98 I = O.A E Ea E 6 oE E E;bb E€; TE5 H ;E= $E* EEa 3 3€.3 .E^5(9 .Hrf,a E Erl EtE .lE;: E EaE ir,= ttEH g EaI !;# ;BHEiE g EEg g€a +38EA 3
C E E EE* EE€ ;Bg
gE IH igg ;It €;Eq;J .e'= o.c.L f;:iB ;gCr# EE qE=
gE i; Eil I;n tEEH* [S utrh ieg .,eEs
E;. g: +g= lgf E5F
EE #H E5; #.EE E5E
+.i
v)
bo
C
t-
15c
.III
E(uPtno
oo
bo
-J(n
cr')c.i
.co9
€E
O'=-otCOo:
EYot)ulcr-6.=
HEo=:bo|+oEr-8EcoO-tnY
-r(EEat
gE
v)
39o9b
rJ.r UolJ- >-o o.=o=E
l(Unl(J rF(u+ o-o
b 88.
Liu.9 : 'v)
E=E
o-o oO(J-o=otvl- LtYio
L)
'-\
l-€E&F(oO
^i
o:{",€ 3-d =z o5gE =ibfr
?EE ;E:E
= iit -'= EUE: b5Eio i E:,5
=.gE !.Hio ='E o !l: cL).= iE oO IIro rE; 6: I E 8EflHn E eb
8 e rl = .= 8E
E usq E:AgE#9n -BE#
;! B s t8e
E s ii E:E
I s: * t E -;
I FE = EE#
:.:E E o .gE E
g:H! Ht E
EEi; gE;
th E f +, l- l-oEEO iDa9.
-COroc-COO-F orur
:-c
ro
(Fo
rn
Co
a-.l)
-o
Co(J
EoPtno-bo(U
:loa:
E=
-
ib
Co.F
(oE
Co
E
Eo(JoE.
C
o(J
E
o
hi(9b
(IJ+r(- G,
P=
cbobE
16 '-
EOt-( )P;*-o
oo-
.=(uE.=
^dB
.1,.t-(o'-
-ocoo:E(offB
ttt (U8ocbooc
E=
h(o-o-
tn(uE
i(U(Joo
fC
6=
{o
56
=.4E>
.=(o
8s
^9.&_.=
roE
-C,(,E
atC'=(o
F
=oBE
.,,oo
=oP()
='=E
Eetse'Ei oo=3u(r--EEE
=o(J-
@+t
E.=C(u(oo-
P- Q)b.>
E c.r
O(U'=G t,+eEUI8
A
-
ltJ, !r
rri
=E = E8e.'8 5 Ebf G E 25: e P P 5
E E EE s; sE;EoE A ro =l rU o iE F=.e 3 ;EP EE=.0HE= +9p- Q = 90.i EooE ool PE E EE;
; E ;f;E;€# Hr
tr = L6=** S6 g€sE sE;Jee g;
=d =;H;-*:i .=,- ,- 9
=
0 5g h,EH< fie:3fEEH
HS HEE; tEgEE.- FE*aEE Pr8E;e Eq€;sE:EEEEE =:!gE;E F;:i9 iaEB;E.q=E;Eg = EE#Ege€
==
uE E P B+EooeE fE='E E.H o EE e 9'+.,a
[- g E=;e;EF e#;
iE,= !tEEi* EEE
EE B E TE :sE E-*E
+cr;
Eo
=C
a-+)CoU
tn
Co
a-+)
ECoU
Eo#
1r'lo
bo
oo
=a
d
6.= os-c-c o-c c ro o oE .ll E - -'F ro A.c U
eE e* i; g s ? E.E Ei+;:Ei0E8.- pEe
gt:siigtBH E Pf
EIEIIElgEigIEE;;EiEeEHE i z=-;
EIigE;f iHF :I HEE;:i;s;:rE ;,.iEE
E.:,EE*EEtEE EEEg
TEE:EE;AI-E 3;g}
E*gIg;*iIiEE*i
;;itil::{E;EEB
EE::EEgEEI g.H:I
tr-b^E F^= E lfi E= dH,-"
=IssssertE€ IEpE
o;d
PE
E
'= +).dB
ePr-(U
Ei
G'
E='==
FSlooE
iosbE=t.l.=oCEEflP
= (U.=Al-+J\JEE6(II oJ=tr-oi
=- o
EEE'= ln t-eE#
o6=-c -lJu(,l-'E(o(Llr-.o (o.Y: E o'=sE
thoo- tr.E.oFfi.O-g; aCF!_L'3= ?s E.ex.9
-E I
1--
Eo
-J
C
a-PcoU
tn
Co
EECoU
Eo+)ao
oo
bo
-JVI
:iE* E' i+E:;; EifrtEtE= E EgEEEEE +bEE-5_i#H ? EBE;E$E #cI*E:hg E EE == LE 3fr;Y;=tF ; rEE*i€'= 'rouE
e;E€ E EEEE#Eg +fiEE
E"*EE Et ;*EH:;;.:E IHiE=o{,ns E eETEIE= ggEg:+Ei En EEE:E=5 Eit:I.e;E $,g ;esAggg EEEH
;iEE I; lEIiE;i E!EEO:= =ptEE 5g E=8##€* ^*;**;
iEi,: Es r[;fEqg sti,EgE.=: EE FHH.Eo-88 n.E6:EpE is =8gEI:= :rEEE-i-trE EE i=:Eiq€ E=iEs8H= =tr -EyEiE'= E-.-EE9st: EF- FpnE*o'8 q9=8
!IEE I; EEEtEEE !EEEagEa Ei [€EpEEi a=rE=.;#:; EE ;=. lEEEE EF-.P6:j
;sEE EE EEB iAgE E IgE*
d-inid;;;HFl
Eo
-J
C
.IPCo(J
v)Co
a-+)
ECo(J
EoPlno
bo
oo
=1I)
tn(o-
-c '6
cc(oq)
.9 .=
=(u<*:
6; .-
.CEPO
(t.=
ee5.=t.rE2(J-
EOe(J
<uOUl(J
€E'=(ooo
-ea-OC.g.!o Lr)cuC(JO:u=F1(U irrFrr- OO(u 5 crlf, ?so l-N.(oL-Loo- o
-rt!.9U EEo- o.9V' EoJ, atctqo'=-oEfigv.--goi;
9Ee{vlr- lJ- c'O ar O.= For.r- E c
#E *E:-./'E
eE bth (J
Eo
CJ
o
(o
Ec
l-E
3
co
E
(o
o-oo
bo
.=g
C(o
o
o
oo(J
(o
l-E
3
co
E
oooo
br
.E
E
C(o
o0C
==co
o.C
oE't
o
o-
(o
tt
C(o
.9
o-o-
qJ
+
th '=
LL9oLo-9c).= bo3CBF
(J-o)Rr4
=)PE
Eqc(u(u--c6tEJobE
-: (!
rJ.t J
6 tJ'l.t) Vlqt-o-6P
l- t-ooE':-gE
rri
Fl
ttc
.e u.3 P
EaiF=E f o cs' ef, b E
;";EE EE5gE*
-LgJLL-I o.q U t
X fier g>ab =.== tr (J.Y >,:,r-.{-tP
- o L (o=
Es:-=EE*q8eirE-H'- =+: 8.8.E E:3gI s
Efl 3gEhI or = I*- O) E t *
EEEIEor.LP.Eo
-C-CEQJP io o -.=os'{= (t, fEP(o!2ulesEn:l=o- =.= cl-rn Y - qJ
l= v E ro Elq c ol-c Xl+ (o E u) .=l6-l-LTP- t*
lE q ;i Ilo-ur= =;
k'e gEE
li g.= F g
l.s = 3;El'- o I - Ulf(J+,oLP
IH; EH q
IIEE!E
iE5 EE 3
EI
gE
rol.Lzl;bl
=cl c,
sl5cl Iol G
El *
El til &
-t
I
=l <DoJ+ol *ol.9el&
El
=lol ol;lbl
orl -lsl El
EI EI(rl Ll
sl El
-'al ol
at ;t
3t€l
trlEl
f,l .ol
3Hlol tnl
EIEI
-l cLl
-trol o
-cl Qlrnl -
r=l d
sl Eol r-af
o.rl =-cl OFIU
o- .}'=oO =Lr.-!JsE- ,qt_LG'\J'9 8-E o I
= o.:l-c! -.rJ botsFo.E
L - .! - PPoE .6 n_E:!E 5Eo-i t-r=E-o-'- <u ij !o X
=cE9hi5., .9'= .= E .e
=EPSSHr s;s E E
E *=5 E a.e.9 oE = ?
= Os = = !udcSEE;< E 5 o'!'F(u = =E (u
=E Et g t I ai
sEE#EPH5:€'EH==e
5 e 3E'H: E
H 53E-ab:iaE - q, 9 9'tcl:o-I t <uE*=if;iE;3 E?iEoE? 'r.=?; ==#1- 9B - =EEeie$.Hl= e;.EE E
,E Eo'P-3s g
b o O'{= 6.'' O
E,.* : E i;EE=flEEEE:9 (o'=.9.=
EE gE EEE
tEEdE:t
$EAEI=EE; T, E E E-Er-1 >. c .6= :6glE '= q, * e u
El h€f,< E.=
-Ebo
=o
-L
o'-
ra
vl(o
ar1c
.o
o
oE
doc
LoEc)
ttt(o
C
3o
.n
th
Co
EE
cr;
1+EC(\,
e,,t'rl+t
stlt
(nc
.9.=Eco(J
o
thEEoEo
thoo0
bo
JVI
EoE
Co
- -FG'
tro
,Fi 1-Uo-oo-
EE+) v)l-C.oot{- .-uvl .l-CEoc'r= OiL L)o
EE
LU
^irl+
EXHIBIT
I
)l'"'
September 19,2011
Mr. Glenn Hartmann
Garfi eld County Planning
108 8'h Street, Suite 401
Glenwood Springs, CO 81601
Dear Glenn:
This office has performed a review of the documents provided for the Limited Impact Review
Application of the Rulison Compressor Station. The submittal was found to be thorough and
well organized. The following questions, concems, or comments were generated:
l. There seems to be some confusion on County Road 329 and if the right-of-way was ever
dedicated. The opportunity to dedicate the right-of-way for this road should be evaluated by
the Applicant.
2. In the Sound Level Study, Table 2 shows estimated averages that are above 55 dB(A). The
Applicant should clarify how these do not exceed the applicable standards.
3. Evidence of a driveway permit from Garfield County Road and Bridge was not provided.
The Traffic Analysis mentioned that this would be obtained by Noble Energy, Inc. but was
not included in the application materials if it is necessary. The Applicant should clarify this.
Feel free to call if you have any questions or comments.
Sincerely,
Mounta Cross Engine
RE: Review of Rulison !o-p".r.or Station: LIPA-6893
Chris Hale, PE
826 "l12 Crand Avenue . Clenwood Springs, CO 81601
PH: 97O.945.5544 . FAX: 970.945.5558 . www.mountaincross-en8.com
MOUNTAIN CROSS
ENGINEERING, INE.
Crv[ nruo Er.tvtnorutrttuter Corusurrtlc eruo DrstcN
sEP 2 2 lru
EXHIBIT
{
MEMORANDUM
To: Glenn Hartmann
From: Steve Anthony
Re: Comments on the Rulison Compressor Station Noble/Savage LIPA-6893
Date: September19,20ll
The noxious weed management plan submitted is generic to the area and does not include a specific
inventory for the site. There may be the biennial thistles, Plumeless thistle, and Musk thistle in the area.
We recommend that Noble monitor the area and treat if necessary.
The revegetation seed mixes and plans for reseeding are acceptable.
The County needs to determine if a revegetation security is required. We request that the applicant
quantify the areas that are disturbed outside of the industrial footprint. This would be any cut slopes or
berms that need to be reseeded.
If that level of disturbance exceeds Vz acre, the County will request a revegetation security in the amount of
$2500 per acre.
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.
The Reclamation Standards at the date of permit issuance are cited in Section(s) 4.06,4.07 and 4.08 of the
Garfield County Weed Management Plan (Resolution #2002-94).
EXHIBITIKGlenn Hartmann
From:
Sent:
To:
Subject:
Glenn,
Wyatt Keesbery
Monday, September 26,2011 11:53 AM
Glenn Hartmann
Rulison compressor station
The Road and Bridge Dept. has no issues with the construction of the proposed compressor station, .25 miles southwest
of CR 329 and CR 350.
wyatt
EXHIBITl-Glenn Hartmann
From:
Sent:
To:
Subject:
Denice Brown
Wednesday, September 07,2011 2.22 PM
Glenn Hartmann
Review
I have looked at the information you sent to me on the Rulison Compressor Station. I have not
found any NOAV's for the site. I will send back your information that you sent to me tomorrow with
Jim hopefully.
Thanks,
Denice Brown:):) 970-625-59!5
EXHIBIT
l'4Glenn Hartmann
From:
Sent:
To:
Subject:
Glenn,
Jim Rada
Monday, September 26,2011 9:03 PM
Glenn Hartmann
LIPA-6893 Rulison Compressor Station
Sorry for the delay on my review of this application. I offer the following comments:
1. There is no mention made of what the status of their air quality permits. You mentioned in your voicemail that you
have been working with them on these permits. As I recall from other land use permits, the construction permit must be in
place to construct the facilitY.
2. The noise level survey only estimates/discusses noise levels between 7:00 am and 7:00 pm. COGCC rules reduce
the allowable noise levels by 5 dbA between 7:00pm and 7:00 am. According to the data, it appears that sound levels
could exceed 50 decibels during nightime hours at 1600 feet away from the source along the SE property line.lt was not
clear from the application where the nearest occupied residences are located but I assume that they must be beyond the
property lines. Nonetheless, if sound levels do exceed 50 dbA at the property lines during the nighttime hours, I believe
iney witt be in violation of COGCC rules. I recommend that further evaluation of sound levels be required following
construction of the facilities.
Thanks for the opportunity to review this application.
Jim Rada
Glenn Hartmann
From:
Sent:
To:
Cc:
Subject:
Attachments:
Kevin Whelan Ikewhelan@riflefl redept.org]
Tuesday, September 27,2011 11:38 AM
Glenn Hartmann
'Jason Clark'; rowillits@riflefiredept.org; mamollenkamp@riflefiredept.org
Olsson Project 01 0-2489
HMARDOUS MATERIALS Declaration.doc
Glenn,
I have reviewed the Limited lmpact submittal for the expansion of Noble Energy's Rulison compressor station located
approximately 3.5 miles southeast of Rulison, Colorado; approximately 0.25 miles southwest of County Road 329 and
350, File Number LIPA-6893. The following are my comments/questions:
1. Historically, Rifle Fire Protection District has not done a detailed review on compressor stations in our district.
Federal, dtate, County, COGCC and industry rules & standards have been relied upon. We believe this has been
appropriate and reasonable. We can assist in tne fotlowing areas, if appropriate, by applying the lnternational Fire
Code:
a. Water supply requirements for fire protection
b. Fire apparatus access including turn-a rounds
c. Plan review and installation inspections & testing for flammable gas sensors. EMD's, fire eyes, auto -
ventilation, auto-shutdowns and the like.
lf these areas are already handled by another Authority Having Jurisdiction then no further action is needed
Attached are our haz mai declaration forms that need to be filled out and returned to us at Noble Energy's earliest
convenience but no later than when the plant is operational. This is for our response crews
Two areas that we are working with other gas companies are:
a. What quantities of a spill require Jfire district response? The fire district recognizes there are the federal
and state rePortable quantities.
b. ls production water a hazardous material? The fire district recognizes that the exact makeup can vary
greafly. our current policy is to treat all production water as hazardous.
Will this facility be handling H2S ?
Our fire district liaison with the Oil & Gas Companies is Battalion Chief Rob Jones. Since this is the first review for
this company, please have Noble's Safety manager contact BC Jones to go over fire district response capabilities
and assistance.
page 10 -19 of the SPCC has containment capacity required and current containment values. lt appears what is
required does not equalwhat is currently in place in some of the listings. More information is needed.
Signatures are missing from company representatives in Appendix A, B, C, E ,F and the Stormwater Management
Plan.g. Notification contact information for Fire is incorrect. Rifle Fire Protection District- 970-625-1243 is the correct
non-emergency information.
9. Appendix E- Annual SpCC inspection Facility list has the last date of inspections as2OO7. More information is
needed.
10. Any use of fire for weed control would require an Open Burn Permit from Rifle Fire and proba bly an air q ua lity
permit from the State of Colorado. lt is unknown if any open burning will take place
L1. Any blasting may require a blasting permit from Rifle Fire Protection District. lt is unknown if any blasting will
take place at this site.
Thank you for the opportunity to review this project and if there are any questions ,please let me know.
Kevin C. Whelan
Division Chief/ Fire Marshal
Rifle Fire Protection District
1850 Railroad Ave
Rifle, CO 81650
kewhela n@ riflefiredept.o rs
2.
3.
4.
5.
6.
7.
EXHIBIToGlenn Hartmann
From:
Sent:
To:
Subject:
Grant Griffin [gg riffin@oaconsu lting.com]
Monday, September 26,2011 3:02 PM
Glenn Hartmann
FW: Noble Rulison Compressor Station Completeness Letter
From: Grant Griffin
Sent: Wednesday, August L7,20tL B:53 AM
To:'Glenn Haftmann'
Subject: RE: Noble Rulison Compressor Station Completeness Letter
Glen,
Sorry for the delay. Please see below to our responses to the Completeness Review letter:
Attached is the approved CDPHE Piceance Basin SWMP. The SWMP provided to Garfield County with the
original application covers all materials related to the Rulison Compressor Station.
The BMP Map has been updated to include allsix compressors. The existing BMPs will not be altered with the
additionalfourcompressors. The numbers located on the BMP Map referto inspection report references.
The original access road was constructed in 2OO7. lt appears a Grading Permit was not obtained for the access
construction. The roadway has been constructed to accommodate construction traffic for the additional
compressors.
Attached is the updated Wildlife Report. The Biologist has included impacts to Threatened and Endangered
Species and assessed the overall impact of all six compressors.
According to Noble's Operations Manager, the first two compressors were installed in 2008 and 2009. The four
additional compressors will be the same as the original two and produce the same amount of noise (3516 units).
Pleaseletmeknowifyouneedadditional information. llookforwardtoproceedingwiththisapplication. Thankyou
Grant
Grant C. Griffin I Olsson Associates
8262L%Road I Grand Junction, CO 81505 | ssriffin@oaconsultine.com
TEL 970.263.7800 ext. 2026 | CELL970.21.6.9467 I FAx 970.263.7456
{.J\OLSSON
ASSOCIATES
From : Glenn Haftman n lmailto : gha rtman n @gafield-countv.com'l
Sent: Wednesday, )uly 27,2011 10:19 AM
To: Grant Griffin
Subject: RE: Noble Rulison Compressor Station Completeness Letter
1)
2)
3)
4)
s)
g! etease consrder the envrronment before prrnting thrs e-mail
Noble Energt,Inc Garfield County UniJied Land Use Resolution Section 4-502: Wildlift
NOBLE ENERGY, INC.
GARFIELD COUNTY UNIFIED LAND USE
RESOLUTION SECTION 4-502: WILDLIFE
Environmental Cumulative Effects Impact Analysis
for the South Rulison Facility Site A Compressor
Station
July 20,2011
Prepared and Submitted by:
Jerald M. Powell,
Wildlife Specialties, L.L.C.,
PO Box 1231Lyons, CO
80s40
Introduction
This report fulfills the requirements set forth in Section 4-502 of the Garfield county Unified Land UseResolution of September 2008. Section 4-502 requires that the tmpact Analysis provide a description ofthe impacts that the proposed land use change may cause, based upon the standards that the proposeduse must satisfy' This report specifically determinei the cumulative effect of additional compressors onwildlife habitat, the creation of hazaidous attractions, the alteration of existing native vegetation,blocking of migration routes, and changes in habitat use or a disrrftio, of habitat use by wildlife.
Location and Landform
The Rulison Facility Site A compressor Station (compressor Station) is located approximately 5 milessouth of the Interstate 70 Rulison.exi!and approximatety tz.tkilometers (km - s miles) east of parachute,Colorado' The compressor Station is locaied in the NE v4 sE % Section g, Township 7 South, Range 94West, 6h Principal Meridian (Figure l).
Climate
result of climatic conditions iions interactilng wtith the local
Weather patterns in the project area are a
topography. Mild summers and cold winters are characteristic and temperatures and precipitation vary;,;i; i;".,;t i;;il"?dil ""i
I
"
r ;'*" i I"'i' ffi il ;:;""il'",r:receivino ? ? renfimptors o-.1 1 1 ^^^+:*^-
rvo/ vvrur vvrvusr utrrrrB [Ilc wgttgsr an0 June belngreceiving 3.3 centimeters and 2.2 centimet"rrlt.:l and 0.g7 inches) of pre
tng the driest months respecti
precipitation, typically in the
;'1j:,1"*':::,'"* a*T: -Y+l*"-,.*;i';T':?*:'::3,,"J":i::'xJit:ftYli::'1il1ff i"#
fl:::::::^ler hour) (8 miles per hour). There are no significan, r.^"""r #rt#"r"#';ilJi',".'J;?or velocities.
lltildlife Habitot
The. pre-dominant vegetation of the project area is typical of the eco-region identified as the southemRocky Mountain steppe----open woodlind, coniferoui forest, and alpine meadow province of the drydomain (Bailey 1995). Soil_s,within the project area are predominantly aridisols common to foothill andlower mountain elevations. Habitat types are determined ty ao*in*t vegetation types.
vegetation around the compressor Station is comprised of Gambel oak (Quercus gambetii) shrublands;there is no vegetation located o1tle compressor station (Photo l). Gambel oak shrublands often includeserviceberry (Amelanchier alnifolia) and snowberry (symphoricarpos albufl shrubs; however,chokecherry (Prunus virginiana ssp. melanocarpa) andmouniain mahogany (Cercocarpus montanus) arealso commonly found' -ln the understory, elk sedge (carex geyeri) is tne mLst
"orn-on herbaceous plant.other grasses and forbs include sticky false starwort (Pseudostellaria jamesiana/, Nuttall,s larkspur(Delphinium nuttallian,um), lambstongue groundsel (Senecio integenimw). and northern bedstraw(Galium s eptentrionale) .
Gambel oak shrublands generally do not provide
federally threatened, endangered, and candidate
County.
habitat for federally listed species. Table I provides the
species (USFWS 201l) which may occur in Garfield
The compressor Station as it currently exists and prior to its construction and operation, does/would notimpact any federally listed species or designated critical habitat.
American elk (elk - Cervus elaphus nelsoni) and mule deer (deer - odocoileus hemionus) are thedominant wildlife species in oak shrubland habitats near the iorp...ro. station. f#"6fd;rj,j;Station is mapped by the colorado Division of Parks and wildlife (cDopw) as elk winter range andconcentration are4 and as deer winter range. The compressor Station sets on ihe southem edge of thesecritical habitat types'
- The majority of tlhe critical ha'bitat is north of the compressor Station whereagricultural lands (i'e' hay fields) u.L "o,n.on. These agricultural lands provide winter and early springforage of greater quality than oak shrublands and the winler snow depth is much less.
The location of the compressor Station does not.exist within any cDopw mapped migration corridors orwildlife habitat linkages. The initial construction and operation of the compressor Station likely didcause a decrease in habitat use by deer and elk within at a minimum of 400 meters. Research shows thatdeer and elk will avoid humall use areas, but with time use of these areas .u, *t,r.n to near pre-disturbance levels if habitat conditions are.capable of providing hiding cover (e.g. in areas clear ofvegetation wildlife will have a reaction to humans, noir., .rc. u-t a greater distance than if the samedisturbance was occurring in heavy shrublands).
Additional development at the compressor station will not create hazardous attractions to avian ormammalian wildlife species, alter additional native vegetation, block migration routes, o.
"uur" a changein habitat use' The cumulative effect of the addition Jr ,o." torni."rro.. will not result in an impact towildlife for the following reasons:
o The Rulison Facility Site A compressor Station is existing and is devoid of wildlife habitat.
Table l.
Canada lynx
Mexican spotted owl
Yellow-billed cuckoo
Greenback cutthroat trout Oncorhynchus c larki stomias
Colorado pikeminnow Ptychocheilus lucius
Gila elegans
Humpback chub
-
Noble Energt, Inc. Cache Creek Master
o Wildlife has become accustomed to the presence of the compressor station, human activityassociated with the compressor station, and the noise of the compressor station.
Additionally, it is preferred to 'cluster' impacts and human activity within one area to reduce the totaldirect impacts (loss of habitat) and indirecf impacts (human activity and avoidance of areas) to wildlife.The. addition of compressors at this location will help to cluster impacts and eliminate the need foradditional compressor locations in habitat that is not impacted and deveioped.
Professio nal Oualification
This report was prepared by Jerald M. Powell of wildlife Specialties, L.L.c. Mr. powell has both hisBachelor of Science and Master of Science in wildlife Biology. Mr. powell is a Certified wildlifeBiologist through The- wildlife Society and..a..certified Ecoloiist rhrough the Ecological Sociefy ofAmerica' Mr' Powell has conducted many wildlife surveys and Impact assessments throughout GarfieldCounty and Western Colorado.
Photographs
Photo l: Rulison Facility Site A Compressor Station.
t-";I'
,i
'*.1..-r\h
EXHIBITa?O\oLssoN
ASSOCIATES
October 3,2011
Glenn Hartman, Senior Planner
Garfield County Building and Planning Department
1oB 8tn Street, #401
Glenwood Springs, CO 81601
RE: Conditions of Approval - Noble Rulison Compressor Station Expansion Staff Report
Noble Energy lnc. (Noble) has reviewed the Noble Rulison Compressor Station Expansion staff
report and has no further comments at this time. Noble shall adhere to all applicable regulations
pursuant to the Garfield County 20AB Unified Land Use Reso/ution as Amended. The following
are Noble's responses to Review Agency Comments:
Steve Anthonv - Weed Manaqement and Reveqetation Comments
1) The noxious weed management plan submifted is generic to the area and does
not include a specific inventory for the site. There may be the biennial thistles,
Plumeless thistle, and Musk thistle in the area. We recommend that Noble
monitor the area and treat if necessary. The revegetation seed mixes and plans for
reseeding are acceptable. The Gounty needs to determine if a revegetation
security is required. We request that the applicant quantify the areas that are
disturbed outside of the industrial footprint. This would be any cut slopes or
berms that need to be reseeded. lf that level of disturbance exceeds % acre, the
County will request a revegetation security in the amount of $2500 per acre.
Response: Noble will monitor and control all noxious weeds on-site. According to Noble's
Operators Manager, the pad site has been reseeded twice since 2008. There is
approximately 12,000 sq ft. of disturbed area outside the industrial footprint which will be
reseeded. Since this area does not exceed Yz an acre, a revegetation bond will not be
required.
Chris Hale. PE - Enoineerinq Comments
1) There seems to be some confusion on County Road 329 and if the right-of-way
was ever dedicated. The opportunity to dedicate the right-of-way for this road
should be evaluated by the Applicant.
Response: No Public Road Right-of-Way appears to exist on CR 329. The Garfield County
Road and Bridge Department review comments have indicated that dedication of Right-of-
Way will not be required with this application.
2) ln the sound Lgyel study, Table 2 shows estimated averages that are above 5sd-B(Al'The Applicant shoutd ctarify how these aonoi exceed the applicabtestandards.
Response: Following the installation of additional compressors, the applicant will perform asupplemental noise anatysis to confirm compliance witn state ano Loiatnoi"" iegulations.Noble will utilize mitigation techniques to address
"ny
noL" irpacts to the surroundingcommunity.
3) Evidence of a driv-eway permit fromGarfield county Road and Bridge was notprovided' The Traffic Anatysis mentioned that this woura oe outai"iJ uirrr"ul"Energy, lnc. but was not inctuded in the application materials if it is n"d"r""ry.The Appticant should clarify this.
Response: The Garfield county Road and Bridge Department review comments haveindicated that a driveway permit will not be required rilr tre expansion of this facility.
1) Historically, Rifte Fire Protection District has not done a detailed review oncompressor stations in our distric{. Federal, State, Gounty, COGCC and industryrules & standards have been relied upon. w" u"rur thas lias been appropriateand reasonabre. we can assist in the fo[owing aieas, ir approfriate, [i appryingthe lnternational Fire Gode:
a. Water supply requirements for fire protection
b. Fire apparatus access including turn_a rounds
c' Plan review and installation inspections & testing for flammable gassensors. EMD's, fire eyes, auto - ventilation, auto-shutdourns and the like.
!f these areas are-atready handled by another Authority Having Jurisdiction thenno further action is needed
Response: Allapplicable lnternational Fire code standards will be met.
2) Attached are our haz mat declaration forms that need to be filled out and returnedto us at Noble Energy's earliest convenience but no tater than when it e-plant isoperational. This is for our response crews
Response: The Haz Mat Declaration form will be filled out and submitted to the FireProtection District.
3) Two areas that we are working with other gas companies are:
a' What quantities of a spil! require a fire district response? The fire districtrecognizes there are the federal and state reportaLre quantities.
b' ls production water a hazardous material? The fire district recognizes thatthe exact makeup can vary greafly. our current poricy is to treat-aiiproduction water as hazardous.
Response: The proposed expansion of the Compressor Station will not utilizeproduced water or other liquids.
4) Willthis facitity be handting H2S?
Response: No H2S will be handled at this facility
5) Our fire district liaison with the Oil & Gas Companies is Battalion Chief RobJones. Since this is the first review for this company, please have Noble,s Safetymanager contact BC Jones to go over fire district response capabilities andassistance.
Response: This condition will be met.
6) Page 10 -19 of the SPCC has containment capacity required and currentcontainment values. lt appears what is requiied does not equal what is currenttyin place in some of the ristings. More information is needed.
Response: Noble will review the SPCC to insure the accuracy of the plan. The appticant willprovide the County an updated version of the SPCC document to reflect the as-builtdrawings.
7l Signatures are missing from company representatives in Appendix A, B, c, E ,Fand the Stormwater Management plan.
Response: The applicable signatures will be obtained to update the latest version of theStormwater Management plan.
8) Notification contact information for Fire is incorrect. Rifle Fire protection District-970-625'1243 is the correct non-emergency information.
Response: The Plan will be updated to reflect the above contact information.
9) Appendix E- Annual SPCC inspection Facility list has the last date of inspectionsas 2007. More information is needed.
Response: The applicant will provide the County an updated version of the SpCCdocument to reflect the as-built drawings.
10) Any use of fire for weed contro! woutd require an Open Burn permit from Rifle Fireand probably an_air quality permit from the State of Colorado. lt is unknown if anyopen burning wifl take place
Response: No burning of weeds is anticipated at this time.
11) Any blasting may require a btasting permit from Rifle Fire protection District. lt isunknown if any blasting will take place at this site.
Response: No blasting is anticipated at this time.
Jim Rada - Review comments
1) There is no mention made of what the status of their air quality permits. you
mentioned in your voicemail that you have been working withitiem on these
permits. As I recallfrom other land use permits, the construc{ion permit must be
in place to construct the facility.
Response: A CDPHE Air Quality Construction Permit has been submitted. All applicable
CDPHE permits will be obtained before the construction and operation of the additional
compressors.
2) The noise level survey only estimates/discusses noise levels between 7:00 am
and 7:00 pm. GOGCC rules reduce the allowable noise levels by 5 dbA between
7:00pm and 7:00 am. According to the data, it appears that sound levels could
exceed 50 decibels during nightime hours at 1600 feet away from the source along
the SE property line. !t was not clear from the application where the nearest
occupied residences are located but I assume that they must be beyond the
property lines. Nonetheless, if sound levels do exceed 50 dbA at the property lines
during the nighftime hours, I believe they will be in violation of COGGC rules. I
recommend that further evaluation of sound levels be required following
construction of the facilities.
Response: Following the installation of additional compressors, the applicant will perform a
supplemental noise analysis to confirm compliance with State and Local noise regulations.
Noble will utilize mitigation techniques to address any noise impacts to the surrounding
community.
Glenn Harhran's Staff Report - Gonditions of Approval
1) That all representations made by the Applicant in the application, and at the pubtic
hearing before the Board of County Commissioners, shal! be conditions of
approval, unless specifically altered by the Board of County Commissioners.
Response: Noble will adhere to this requirement.
2) That the operation of the Noble Energy lnc. Rulison Compressor Station be done
in accordance with all applicable Federal, State, and local regulations governing
the operation of this type of facility.
Response: Allapplicable Federal, State, and Local regulations will be met.
3) Prior to operation of any additional compressor units, the Applicant shall
demonstrate fullcompliance with atl GDPHE Air Quality construction and
operations permitting requirements.
Response: All applicable CDPHE Air Quality permits will be obtained before construction
and operation of the additional compressors.
4l Prior to installation of any additional compressor units, the Applicant shall
supplement their noise analysis to confirm compliance with State regulations on
maximum noise generation including operation during nighttime hours (7:00 p.m.
to 7:00 a.m.). The updated study shall also provide clarification as to the type of
sound attenuating buildings and type of hospital grade mufflers to be installed.
The Applicant shall maintain compliance with State regulations on maximum
noise generation and the Gounty may require additional noise analyses at the time
of building permit review associated with the installation of additional compressorunits to verify compliance.
Response: Following the installation of additional compressors, the applicant will perform asupplemental noise analysis to confirm compliance with State and Localnoise rejutations.Noble will utilize mitigation lechniques to address "nt;oGl;pacts to the surroundingcommunity.
5) All equipment and struc'tures associated with this permit shall be painted withnon'reflective paint in neutral colors to reduce glaie and mitigate iny visualimpacts.
Response: The compressors and associated structures will be painted with non-reflective paint to reduce grare and mitigate visuar impacts.
6) All structures and fences shall obtain building permits from the Garfield CountyBuilding and Planning Department if required1y county regurations.
Noble will adhere to this requirement.
7) All^exterior lighting wilt be the minimum amount necessary or required by thebuilding code and industry standards, and shall be directed inward anddownward, except that provisions may be made to allow for safetlr rilrriing.
All lighting willadhere to this requirement.
8) The Applicant shall comply with the recommendations of the Garfield CountyVegetation Manager-and shall provide a calculation of the disturbed area outsidethe industrialfootprint, and shill provide reclamation security as determined bythe Vegetation Manager in accord-ance with the county Reguiitions. rne Securityshall be_-held by Garfield county untilvegetation has be"n-"r"o""irirv-reestablished according to the Reclamation Standards in the Garfield 6ounty
W""d Management Plan. tt is the responsibility of the appticant to contact thecountlt, upon successful re-vegetation estabtishment to request an insfection forsecurity release consideration. The reclamation standards it tne date of permitissuance are cited in Sec{ion(s) 4.06, 4.07, and 4.og ;} the Garfiela County weedmanagement plan (Resolution No. ZOOZ-g4l
Response: According to Noble's operators Manager, the pad site has been reseeded twicesince 2008. There is approximately 12,000 sq ft. 6r ai.trrb"J area outside the industriatfootprint which will be reseeded. Since this area does not exceed /, an acre,a revegetationbond will not be required.
9) The Applicant shall maintain comptiance with the existing weed management planincluding management of any weed or thistle problems on the site. Ashay bedetermined necessary by the Garfield county vegeiation Manager, innu"r "it"visits may be conducted to ensure that any,i*ip."otems areffip"ilv ,un"g"a.
Noble will monitor and control all noxious weeds on_site.
10) Prior to issuance of the Land Use change Permit, the Applicant sha[ supplementthe Traffic Study to address construction related traffic. The Applicant shalprovide dust control measures as represented in the Application submittals withparticular attention to periods associated with additiona-l site construction andinstallation of compressor units.
Response: The construction phases are anticipated to be approximately two weeks each
and will be limited to two one-time construction deliveries trips (heavy vLnictes; and two
daily construction trips (light vehicles) per phase. Noble will utiiize a chloride-based solutionto mitigate dust along the access road and pad site.
11) Compliance with the Applicant's Storm Water Management ptan, Storm WaterDischarge Permit and Best Management Practices shalt be required.
Response: The Applicant will comply with the SWMP, Stormwater Discharge permit, andBMPs.
12)Prior to operation of any newly instalted compressor units the Applicant shalprovide the County with an updated fully executed Spill Protection Gontrot andCountermeasures Ptan (SPGC) that includes the proposed 6 compressor units,any updated containment requirements, and demonstration that the proposed siteis in compliance with the provisions of the SPCC Plan. The Applicani shal includewith said update documentation of safety and emergency procedures, technotogyand equipment required for operation of the facitity in compliance with alt Federli,State, or Local, and industry requirements.
Response: The applicant will provide the County an updated version of the SPCCdocument to reflect the as-built drawings.
13) Priorto issuance of the Land Use change Permit the Applicant shafl provide theBuilding and Planning Department withl letter from the-Rifle Fire protection
District or other acceptabte evidence indicating that the Applicant has satisfiedthe Fire District's SPGC Plan questions and related conceins contained in theiremail correspondence dated September 21, 2011.
Response: This standard will be met.
Please provide a copy of this letter to the Board of County Commissioners, and include thiscorrespondence in the project file. Please contact with further questions. Thank you
Project Scientist
Olsson Associates
Aoriff in@oaconsultino. "o,TEL: 970-263-7800
CC: Debbie Nau Redmond, Noble Energy lnc. Rocky Mountain Project CoordinatorLorne Prescott, orsson Associates senior projett scientist