HomeMy WebLinkAbout2.0 BOCC Staff Report 05.10.2010Jen*t^*-+
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BoardofCountyCommissioners-PublicHearingExhibitsffii; in"tgy lnjection Well 26-348 (5/10/10)
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REQUEST
PROPERTY OWNER
O PE RATO R/REP RESENTAT]VE
LOCATION
ACCESS
SITE INFORMATION
EXISTING ZONING
RECOMMENDATION
PR 26-348 lnjeurion Well- Material Handling
BOCCSI1O/tO
KE
PROJECT INFORMATION AND STAFF COMMENTS
Land Use Change Permit -"Material Handlingl' to allow
conversion of a natural gas production well to a produced
water injection well
Donald Throm
Noble Energy, lnc. -JudiKohn
CH2M Hill-Jo Anne Lehman
26-0 Well Pad, Southwest of the Town of Parachute at
County Roads 300 and 304. Section 26,T75, R96W
County Road 304
Parcel No. 24O9-264-OO-L37 * 160-acres
Well Pad 26-0 -4-acres
Rural
Approval with conditions
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PR 26-348 lnjection Well - Material Handling
BOCC s/10/L0
KE
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On behalf of the surface owner, Noble Energy, lnc. (Noble) as lessee and operator, has applied to the
Board of County Commissioners for a Land Use Change Permit for Material Handling which would allow
for produced water gathered from Noble's Parachute field to be injected into the PR 25-348 well" The
produced water is proposed to be transported to the site from the well field via existing pipeline
systems operated by Noble. No additional aboveground facilities are required at the well pad and no
water will be delivered to the site via water trucks for injection'
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II" LOEANON AND SITE DESERIPTION
This site is located along CR 300 and CR 304 southwest of the Town of Parachute. Donald Throm is the
owner of the l-60-acre surface parcel identified as Tax Parcel Number 24O9-264-OO-L37. A Surface Use
Agreement from the owner grants the right to utilize the property for the purpose of oil and
hydrocarbon gas production and water disposal-
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PR 26-348 lnjection Well- Material Handling
BOCCSITO/LO
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SITE PLAN
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IV. REFERRALAGENCIES
Comments have been requested from the following agencies and comments received are integrated
throughout this memorandum as applicable"
1. Road and Bridge: EXHIBIT H
2. Vegetation Management: No Comment
3" Environmental Health: EXHIBIT I
The general vicinity of the project area
is zoned Rural with ranching and other
agricultural uses occurring; however
the area also has significant Oil & Gas
activities, including production wells,
compressor stations and pipelines.
BLM Public Land does exist to the east
of the Throm Parcel, approximately %
mile from the 26-0 Well Pad.
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PR 26-348 lnjection Well- Material Handling
BOCC s/10/10
KE
4. Oil& Gas Liaison: EXHIBITJ
5. CDPHE: No comment received
6. Town of Parachute: No comment received
v. REVIEW CRITERIA & STANDARDS
Limited tmpact Reviews are required to adequately address topics in Section 4-502(D) Land Suitability
Analysis, Section 4-502(E) lmpact Analysis, the general development standards found in Article Vll with
specific attention to Section 7-810 (additional standards applicable to lndustrial Uses) as codified in the
Garfield County Unified Land Use Resolution of 2008, as amended (ULUR). The following section
provides the review criteria and standards in bold italics below followed by a Staff Response.
A. Section 4-502(E) Land Suitabilitv Analvsis
l. public Access to Site. Show historic puhlic access to or through the site.
Staff Response: The site fronts along County Roads 300 and 304, however primary access to the
site is from several locations on CR 304'
Z. Access to odjoining Roodways. ldentify occess to adioining roods and site distance ond
i nte rcectio n co nstro i nts.
Staff Response: The access location to the well pad is .38 miles east of the intersection of CR 300
and CR304. A driveway permit has been issued for the access point which serves the well pad (see
Exhibit M).
3. Easements. Show all easements defining, limiting or allowing use types ond occess-
Staff Response: A Water Disposal Lease, as wetl as a Surface Use Agreement is in place between
Noble and Donald Throm-
4. Topogrophy ond Slope. Topogrophy ond slope determination'
Staff Response: The proposed location for the injection well is on an existing graded well pad
which has been graded so that stormwater is collected in a sediment trap on the northwest corner
of the wellPad.
5. Noturol Feotures. significont noturol feotures on-site and off-sik.
Staff Response: Located on a bench above the Colorado River, the site is .7 miles south of the
river. pete and Bill Creek is located 100' below the well pad - linear distance of 515'- The site is
predominantly compesed of agricultural fields with steep embankments on the sides of the bench,
as well as pinyon pine and jyniOer/sase grassland.
6. Drainoge Feotures. exiiing drainages and impoundments, noturol ond monmade.
PR 26-348 lnje- -jn Well- Material Handling
BOCCSILO/10
KE
Staff Response: As stated earlier the Colorado River is .7 miles north, Pete and Bill Creek is 515' to
the west of the well pad. The well pad is existing and has been graded to allow for run-off to be
diverted to a sediment trap located in the northwest section of the well pad. Other run-off will be
managed through the existing Stormwater Management Plan (SWMP) and the Spill Prevention
and Control Countermeasures Plan (SPCC).
7. Water. Historic irrigdtion, toilwoter issues, water demonds, adequote woter supply plon
pursuont to Sedion 7-1(M.
Staff Response: Potable water is not required for the injection site. An adequate water supply
plan is not required for this use. There are numerous Domestic and Monitoring wells in the area'
8. Floodptain. Flood plain and flood fringe delineotions.
Staff Response: The site is not located within a FEMA-designated floodplain-
9. Soils. soils determination, percolation constraints, as opplicahle.
Staff Response: The area is located within a soil area designated as Potts Loam, a soil type that
indicates well drained soil with a high available water capacity and moderate infiltration when
thoroughlY wet.
70. Hozards. Geologic hazards on-site, ond odiacentto site'
Staff Response: No known hazards are located on the site or adjacent to the site which would
impact the proPosed use.
ll. Noturat Hobitat. Existing ftora ond fauna hobitot, wetlands, migration routes-
Staff Comments: The well pad is located in the grassland vegetation area, however much of the
site has been developed for agricultural purposes. There are no wetlands on or adjacent to the
well pad. The area is mapped as Elk Winter Concentration Area in addition to Mule Deer Critical
Winter Range and Mule Deer CrucialWinter Range. There is no vegetation on the well pad'
lZ. Resource Areas. Proteded or Registered Archaeologicol, cultural, polentolagicol and historic
resource dreos.
Staff Comments: The well pad was constructed without benefit of an analysis of potential
resources on the site. The conversion of one well to the proposed use occurs within that well pad
area.
Section 4-502(E) lmoact Analvsis. The lmpact Analysis shall provide a description of the impacts that the
proposed land use change may cause, based upon the standards that the proposed use must satisfy' The
lmpact Analysis shall include a complete description of how the Applicant will ensure that impacts will
be,initigated and standards will be satisfied. The following information shall be included in the lmpact
Analysis.
PR 26-348 lnjection Well- Material Handling
BOCC s/10/10
KE
Adjocent Propefi. An oddress list of real property adjacent to the subject property, ond the
moiling addr*s for each of the property owners.
Staff Comments: The applicant has provided a copy of the adjacent propefi owners.
Adjocent Land llse. Existing use of adjacent property ond neighboring properties within 75OU
radius.
Staff Comments: Use of land adjacent to this site is primarily agricultural, with some residential
use. Oil and Gas activities also exist in the area, and public lands are located to the west of the
parcel.
Site Feotures. A description of site features such os streoms, oreos subjed to flooding, lokes,
high ground woter areos, topogrophy, vegetotive cover, climotology, ond other feotures thot
may aid in the evaluation of the proposed development.
Staff Comments: Construction of the well pad and other improvements commenced in 2008,
improvements which include storage tanks and production units for the production of natural
gas on the site. Vegetative cover is minimal to non-existent as the 4-acre well pad site was
graded prior to drilling activities on the site. The parcel vegetation (16Gacre site) includes
Pinyon-Juniper forest and agricultural grazing grasses.
Soil Characteristics. A description of soil choracteristics of the site which have a significont
influence on the proposed use ofthe land.
Staff Comments: NRCS data of the soil characteristics does not identify any constraints
associated with the proposed use. The depth of the injection will prevent impact the surface
soil.
Geology ond Hozard. A desuiption of the geologic chamcteristics of the oreo including any
potentiol natural or mon-made hazords, ond o determinotion ol whot effea such fadorc
would have on the proposed use of the lond.
Staff Comments: No hazards are identified on the County Hazard Map and neither Noble nor the
COGCC identified hazards which would impact the proposed use.
Elfect on Existing Woter Supply ond Adequocy oI Supply. Evoluation of the elfed of the
proposed land use on the copocity ol the source of water supply to meet existing ond luture
domestic and ogricukurol requirements ond meeting the adequate woter supply requirements
of Section 7-7(H.
Staff Comments: The injection is classified as a Class l! disposal well with the produced water
injected into authorized zones in a manner that does not allow for the migration of the fluids
into underground sources of drinking water. Sampling of the water to be injected is required by
6
7.
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PR 26-348 lnje- .on Well- Material Handling
BOCCSI1.O/to
KE
the COGCC, and prior to injection the chemical compatibility of the fluid is checked with the
receiving formation.
The eleven (j.1) domestic water wells in the area are drilled to depths ranging from 55-160 feet,
while the produced water will be injected into the Cozzette and Corcoran formations located at
an approximate dePth of 6,072 feet-
No potable water or irrigation water is required for the installation and/or operation of this use'
7. EffeA on Groundwater ond Aquifer Rechorge Areas. Evaluotion ol the relotionship of the
subject parcel to floodploins, the nature of soils ond subsoils and their obility to adequately
support woste disposal, the slope of the land, the effect of sewoge effluents, ond the pollution
of surface runoff, streom flowgltAgroundwater.bo t (-
Staff Coqmenq;droun-clwater depths range from t4 to 45 feet, with injection occurring at a
depth & +,Ol{f"Et. The closed nature of the system - fluid is piped to site, stored in tanks, and
injected\nir#zes the potential for the fluids to either cause impacts or to be released from
the system. ln the event of an unanticipated spill or emergency, the SPCC plan would
adequately contain the fluids.
g. Environmental Efiects. Determinotion ol the existing environmental conditions on the porcel
to be developed ond the effects of development on those anditions, including:
a. Determination of the long term ond shortterm effect on flora ond founa.
h. Determinotion oI the effect on significont archaeologicol, cultuml, palentological, historic
resources.
c. Determination of the effect on designated environmental resources, including critical
wildlife habitot.
(l) tmpacts on wildlife and domestic onimals through creotion of hozordous attroctions,
alteration of existing native vegetotion, blockode of migration routes, use potterns or
other disruPtions.
d. Evoluotion of ony potentidl radiotion hozard thot mdy have been identified by the State or
County Health DePa ftments.
e. spill Prevention control ond counter Measures plon, if opplicoble.
Staff Comments: No additional activities are required on the site that would impact flora and
fauna, historic resources, or environmental resources. The storage tanks would be located on
already disturbed area contained within the Well Pad. Radiation hazard has not been identified
by the State or county Health Departments. An SPCC is in place for al! aboveground storage
facilities and equipment located on the 26-0 well pad'
B.
PR 26-348 lnjection Well- Material Handling
BOCC s/1'0l10
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g. Traffic. Assessment of trofiic impacts bosed upon o traflic study prepared in compliance with
Section 4-502(l).
staff comments: A Traffic Study was not required due to the nature of the proposal which
specified that the fluids would be transported to the via an existing pipeline system' Minimal
traffic is expected for maintenance activities'
70. Nuisance. tmpocts on odjocent lond from genemtion o! vopor, dust, smoke, noise, glore or
vibrotion, or other emonotions'
StaffComments:Nuisanceimpacts,particularlydustand/orvibrationarenotanticipatedto
occurinrelationtotheinjectionwe]landmaintenanceactivitiesassociatedwiththeuse.
TT.ReclomotionPlon.AreclamationplanconsistentwiththestandordsinSectionT-272.
staffcomments:Thewellpadwillbereclaimedonceproductionhasceased'andthat
reclamation will be conducted based upon coccc requirements. Bonding for that reclamation
is held bY the COGCC.
T.SectionT-T1TComptiancewithZoneDistridllseRestridions
Staff Comments: The Rural Zone District allows this use through a Limited Impact Review'
2. Section 7-702 ComPlionce
with ComPrehensive Plan
ond lntergovernmentol
Agreements
Staff Comments: The site is
contained within StudY Area
2 & 3 and, as shown on the
adjacent maP, is designated
as OutlYing Residential.
3. Section 7-703 ComPatibilitY
Staff Comment: Other Oil& Gas activities o.i* in the area, including a proposal for an injection
well on the adjacent property to the south. The conversion of a production well to an injection
well does not appear to be an incompatible use to other uses in the area'
PR 26-348 lnjr- on Well- Material Handling
BOCCs/LOlLO
KE
Section 7-lM Suflicient Legol ond Physical Source of Woter
Staff Comments: Not applicable.
Section 7-7O5 Adequote Water Supply
Staff Comments: Not applicable.
6. Section 7-706 Adequate Woter Distribution ond wastewater systems
Staff Comments: Water and wastewater are not applicable.
7. Sedion 7-707 Adequote Public Utilities
Staff Comments: Public utilities are available to the site and adequate for the proposed use.
8. Sedion 7-lM Access and RoadwaYs
Staff Comments: One of the main goals for this use is to minimize the truck trips that would
otherwise occur if the produced water were trucked to the site, or trucked to other disposal
facilities. Minimaltraffic will result from the use and the existing County Road system is
adequate for this use.
9. Section 7-IN) No Significont Riskfrom Notural Hazards
Staff Comments: There is no significant risk from Natural Hazards.
SectiOn 7-2OO GENERAL RESOURCE
PROTECTION STANDARDS FOR LAND USE
CHANGE PERMITS
7. Section 7-2Ol Protection of Agricultural
Londs
Staff Comment: The County GIS maPs do
indicate that this site is contained within
the lmportant Farmlands in Garfield
County. As the adjacent map indicates,
prime farmland exists with irrigation.
The proposed use on the 4-acre well pad
does not preclude agricultural use on
the remainder of the parcel.
PR 26-348 lnjection Well- Material Handling
BOCCSILO/70
KE
2. Section 7-2O2 Protection of Wildlile Habitot Areos
Staff Comment: The 4-acre wel! pad is located within Wildlife Habitat Areas however the
conversion of a production well to an injection well will not cause additional disruption to
habitat/
3. Sedion 7-203 Protection otWetlands ond Waterbodies
Staff Comment: An adequate SPCC and SWMP are in place to protect groundwater and Pete and
BillCreek.
4. Sedion 7-2(M Protedion of Water Quality from Pollutonts
Staff Comment: Same as above.
5. Sedion 7-2A5 Erosion and Sedimentotion
Staff Comment: The well pad has been graded and currently exists. The conversion to an
injection well will not affect erosion of sedimentation.
6. Sedion 7-206 Dminage & Section 7-2O7 Stormwater Run-Off
Staff Comments: An adequate Stormwater Management Plan is place.
7. Sedion 7-208 Air Quolity
Staff Comments: Air emission permits may be required due to the use of non-required burners
to minimize VOC odors. Staff recommends adoption of a condition that requires the applicant
to obtain all required federal and/or state permits prior to the Land Use Change Permit being
issued to allow this use.
8. Sedion 7-2(D Areos SubjecttoWildftre Hozords
Staff Comments: The County maps do not indicate significant wildfire hazard. The well pad does
contain adequate water for firefighting purposes.
9. Section 7-270 Areos Subject to Natural Hazords ond Geologic Hozards
Staff Comments: There are no natural or geologic hazards that would preclude the proposed
use-
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PR 26-348 lnjt . -.on Well- Material Handling
BOCCs/LOl70
KE
70. Sedion 7-277 Areas with Archeologicol, Paleontological or Historical lmportonce
Staff Comments: Any area of historical importance would already have been disturbed during
the construction and grading of the existing well pad, the location of the injection well on that
well pad would not cause any additional disturbance.
77. Sedion 7-272 Reclamation
Staff Comments: Reclamation of the well pad is under the jurisdiction of the COGCC who also
holds collateral to assure completion.
D. Additional Standards Applicable to lndustrial Use
lndustrial standards applicable to the current applications include noise; vibration; heat, glare, radiation
and fumes. The Applicant has demonstrated the ability to comply with these standards and ongoing
compliance is recommended as a condition of approval.
STAFF DISCUSSION
Staff has found few issues associated with the proposal and in fact any minor impacts that may result
are mitigated by the reduction in traffic that will occur if produced water injection (via a pipeline) is
approved as the disposal method for Noble's Parachute Field produced water. The County review is
based upon impacts to the surface while COGCC reviews the chemical composition and geologic
compatibility with injection at this site (the 'downhole' issues). The "closed system" nature of the use -
the produced water is wholly contained from origination point of where it is produced to the site of
injection, minimizes the potentialfor surface impacts. Any impact resulting from the use would relate to
the tank storage (which will be placed in proper secondary containment) and the potential for Volatile
Organic Compound (VOC) odor. The applicant has stated that a non-required burner will alleviate odors
from this site. Jim Rada has responded that the burner will require an emission permit from CDPHE (see
Exhibit l).
Other referral response included questions regarding driveway permits (see Exhibits H and M) and the
issue of lab results from the water characterization identified by Judy Jordan (see Exhibit J) which the
Applicant has addressed (see Exhibit N).
VII. SUGGESIED FINDINGS
Should the BOCC decide to approve the request for Material Handling for conversion of a production
well to a produced water injection well through this Limited lmpact Review, Staff suggests the BOCC
make the following findings:
1.. That proper public notice wai provided as required for the hearing before the Board of County
Commissioners.
LL
PR 26-348 lnjection Well - Material Handling
BOCC s/10/10
KE
z. That the hearing before the Board of County Commissioners was extensive and complete, that
alt pertinent facts, matters and issues were submitted or could be submitted and that all
interested parties were heard at that meeting'
3. That for the above stated and other reasons, the Land Use Change Permit for a Material
Handling to allow for pR 26-348 as a produced water injection well is in the best interest
of the health, safety, morats, convenience, order, prosperity and welfare of the citizens
of Garfield County if recommended conditions of approval are adopted'
4- That, with the adoption of recommended conditiont the application has adequately met the
requirements of the Garfield County Unified Land Use Resolution of 20O8, as amended'
VIII. STAFF RECOMMENDATION
staff recommends the Board of county commissioners approve the request for a Land use change
permit for Material Handling to allow conversion of PR 26-348 into a produced water injection well, on
property owned by Donald Throm and operated by Noble Energy, with the following conditions:
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. prior to issuance of the Land Use Change Permit, the Applicant shall obtain all required federal, state
and tocal permits including but not limited to, the COGCC permit for the injection well and any air
emission permits that may be required from CDPHE'
3. Operation of the fucility must be in accordance with all Federal, state and Local regulations and
permits governing the operation of this facility'
4. lndustrial activities shall be required to comply with the following standards:
(1) The volume of the sound generated shall be so operated that the volume *- *'i1i1n"fl1lo
and recurrently generated does not exceed the coGCC requiremen ts;Q1' (e $vdlutZ\-t/t*Y'
VOlrvt rnZ-J
(2) Vibration generated: every use shall be so operated that the ground vibration inherently and
recurrently generated is not perceptible without instruments at any point of any boundary lihe of
the ProPertY;
(3) Emissions of smoke and particulate matter: every use shall be so operated so as to comply with
all Federal, state and county air quality laws, regulations and standards;
(4) Every use shall be so operated that it does not emit hea! glare, radiation or fumes which
substantially interfere with the existing use of the adjoining property or which constitutes a public
nuisance or hazard. Flaring of gases, aircraft warning signals, reflective painting of storage tanks, or
other such operations which may be required by law as safety or air pollution control measures shall
be exemPted from this Provision.
L2
' PR 26-348 lnie- -'on Well- Material Handling
BOCCs/Lol70
KE
5. The transport of fluids to the site is via pipelines and is not to be trucked to the site, except in
emergency situations, unless an amendment is approved to the Land Use Change Permit allowing
such transport.
13
GARFIELD COIINTY
Building & Planning DePartment
Review AgencY Form
Date Sent: APril9,2010
Comments Due: APril 30,2010
Name of application: PR 26-348lnjection Well
Sent to: Garfield County Road & Bridee
Garfield county requests your colnment in review of this project' Please notifyie
Planning Deparhent in the event vou are-unable to respond ll*^*lll5-ft "'*
Ir#oTirri;'f,r*r"* response, or you may atrach vgur.owladditional sheets as
necessary. Wriuen "omm"ott
*uy b" mailed' e-mailed' or faxed to:
GarEeld County Building f,a planning
Staff Contact: KathY EastleY
109 8tt'Stee! Suite 301
Glenwood SPrings, CO 81601
Fax: 970-384-3470
Phone: 970-945-8212
lrJame of review agency: Garfield Countv Road and Bridse Dept
By: Jake B. Mall Date APril 14' 2010
Revised 3130100
Kathv A.
From:
Sent:
To:
Subject:
Attachments:
Kathy
Monday, April26, 2010 4:19 PM
Kathy A. EastleY
fW:Llpn 12-09$246 - Noble Energy lnjection well'
Jim Rada 0rada@garfi eld-county.com).vcf
No major issues from my limited perspective on this'
ls this a Z4/7 operation? lf so, is there lighting needed and will this impact the home that is nearby' No
mention is made of odor or vapor emissions from this site. lt is likely that additional Voc's could be emitted
from the additional tanks. The submittal says they have reported to the state but I didn't see a report'
Although this may not involve any regulatory permits or mandatory controls, there could be odors generated
unless this is a totally closed system.
Let me know if you need further assistance- Thanks for the opportunity to contribute'
J;, (rd", KLHS
Environmental Healih Manager
Garfield CountY Public Health
195 W 14th Street
Rifle, CO 81650
Phone 970-625-5200 x81 1 3
Cell 970-319-1579
Fax 970-625'8304
Email irada@qarfi eld-countv.com
Web www.qarfield-countY,com
Jim Rada
Judith JordanFrom:
Sent:
To:
Subiect:
Monday, APril26, 2010 4:09 PM
Kathy A. EastleY
Noble UIC APPlication
Hi KathY,
Thank you for referring the Noble lnjection LIR application for comments- I don't have any significant comments on this
application. An insignificant fact is that I was unable to locate lab results from their water characterization' I think that
could become something we would want to know if they ever had a spilr on the surface of the site, but we could
probably get a lab analysis for use in prescribing any fotlow up sampling at that point in time' Also' they say in the
apprication that they're exempt from county pelmitting for piperines because they have permits from feds and state' I
guess it would be worth B&p making sure thai none of their pipelines meet the county threshold' Finally' I note that
they have a rease with the surface owne6 to inject. This is important because pore space ownership is unresolved in
CO. In all likelihood, when the law is clarified, ownership of the empty pore spaces in a formation after hydrocarbons
have been produced courd go to the surface owner or to the minerar owner. co probably won't determine the answer
to this question for a year or more. rn the meantime, r suspect the onry way to cover both ownership scenarios is to
have permission from both owners. presumabry, Noble owns or has reased the minerars- And the surface owners have
signed agreements that are included in the application' So it appears that they're good to go'
Thanks again for the opportunity to submit comments'
Judy
Judy Jordan
Oil & Gas Liaison
Garfield CountY
0375 CountY Rd 352
Building 2060
Rifle, CO 81650
(s7o)62s-se0s (P)
(s7o)62s-se3e (f)
iiordan @sa rfield-cou ntv'com
EXHIBITL
From:
Sent:
To:
Subiect:
John Niewoehner
Tuesday, January 12,2010 3:25 PM
Kathy A. Eastley
NobE Energy Federal-26-34B I njection Wel I ( Ll PA-l 2-09 $246)
Kathy - -
There are no engineering comments on this injection well application. There are no new land disturbances. Water to be
injected will be pied to the Pad.
- - John
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Garfield Counfii
Application for Driyeway Permit
Person Obtaining Peruit: Noble Etergy, htc
App I icati on D ate : 7/1 7/2 0 0 I
County Rotd Ntrnfier: 304 District: Silt
Penn it Nunfier: GRB 08-D-74
Terntilt otiotr D nte: 8/1 7/2 008
Inspector: fuke Mull
hereby requests pemtission and authority fi'onr the'Board of County Conrmissioners to construct a rlrivervay approach (es)
on the right-of-rvay off of County Road, 304. .4 tnilcs East of CR 300 / CR 304, Iocated on the Nqrtlt side of road for
the purpose of obtaining access to properry.
Applicant subn:its herervith for the consideration and approval of the Board of County Comnrissioners, a sketch.of the
proposed installation shorving all the necessary specification detaii including;
1. Frontage oflot alongroad.
2, Distance from centedine of road to property line.3. Number of drivelays requested
4, Width ofproposed drivelays and angle of approaoh.5. Distance from drivervay to road intersection, if any.6, Size and shape ofarea separating ddvervays ifmore than one approach.
7. Setback distance of building(s) and other shucture improvements.
8. No unloading of equipment on counfir road, any damage caused to county road rVill 1
expense. '9. Responsible fol trvo ycars fi'orn the date of corrpletion.
General Proyisions
1) The applicaut represetrts all parties in interest, and affiuns that tlre drivervay approach (es) is to be constnrcted by
him for the bona fide purpose of securing access to his property and not for the purpqse of doing business or
servicing vehicles on the road right of rvay.
2) The applicant shall furnish all labor and materials, perforrn all rvork, and pay all costs in connection rvith the
cotrstruction of the dlivervay(s). All rvorkshall be completed rvithin thir$ (30) days of the peurrit date,
3) The fype of constmction shall be as designated and/or approved by thc Board of County Conrmissioneis or their
representative and all n:aterials used shall be ofsatisfactory qualily and subject to inspection and approval ofthe
Board of County Commissioners or their representative.
4) 'fhe traveling public shall be protected during the installation rvith proper warning signs and signais and thc Board
of County Comrnissioners and thcir duly appointed agents and employee shall be held haruless against any action
for persoual injury or properly dairage sustained by any reason of the exercise of the Permit,
5) The Applicant shall assume responsibility for the renroval or clearance of snorv, ice, or sleet upon auy portion of
the drivervay approaclt (es) even though deposited on the drivervay(s) in the course of the County snorv renroval
operations.
:: - ,'
'ri' ' ,.
be repaired at subdivision,-
d) Intheeve.titbeconresnecessalytorenroveanyright-of-rvayfeu_cl,thepostsotteitlrelsideofrlreetttt'ancesllall
be surely braced before the feuce is cut to plevJnt a'rry slacking of the rellraining fence and all posts ancl tvire
removed shall be turned over to the DistriCt Roacl Superuisor oflthe Board of CottntyCoilltnissionets'
7) No revisious or. additions sfualt be made to the drivervay(s) or its appuffenattces on tlte right-of-rvay rvitltottt
rvritien perntissiott of the Board of County Comntissioners'
g) provisiorrs aud specifications outlined herein shalI apply orr all roacls uudel the jurisdictiorr.of the Board of county
Cornprissioners of Garfield County, Colorado, a,ra thi Specifications, set fofill on the attaclted hereof and
incorporated hetein as conditions lteteof.
9) Fiual inspection of drivervay rvill be requirerl [pon conrpletiott att<I trrust be approved by pct'sott issuing
pernrit or rept'esentative of person issuing perniit'
The inspectiorr an4 sign off must 6. Oou" prior to arry CO from the Building atttl Plartttiug
Department being issrred,
10) Contractot'rigrees to all Provisions in Exlribit A'
SPeiial Conditions:
1. Driveway Width- 100ft
2. Culvert requiretl? Tt'ue Size: 24" by 100ft
3. Asphalt or concrete pnrl requiretl? False Size of pacl:
4, Gravclportion requiretl?True Lertgth; 100ft
5. Tr.ees, b,r'ush antl/or.fellce rreed to be.retnovetl for visibility? False
6. Distnuce nnd Directiolt:
7,, Certilietl Tr:affic Control Reqrriied?' Falsc "
i''' - '''
8. Wor'hzonesigttsrcquirerl?Trrie' I "''' : ' '''"'
g. Stop:sign reguirerl at enttance to County Rd '." L' ' '
the Board of County Contnrissiouet's.
Aiklress:
Telepltole Nuntber:
per.nrit granted L117llq,subject to the plovisious, specifications and contlitions stipulatetl herein'
in signlng this applicatioir arrd upon receiving.authorizatisn ancl pemlissibtt to install tltedriiervay approach (es)
described lerei*tlre Appli"arit signifies tlrat he ha's read, nnderstantls ancl accepts the-foregoing provisiotts and conditions
,Jri:rtt";i*";;;,ri;; the rlrivervay(s) in accoldan." *itl, the accotnpatrying specificatioh plan revietved and approved
e25^ 1494
onrtnissiottet's' of Garfield County, Colorado:
Rept'esetrtative of Garfield Cotrnty Road and Bridge Sigttatttt'e
Signed:
Specifications
l ' A drivervay approach is understood to be that portion of the county roarl right-of rvay bctrveen the parernent edge
and the prrcperfy Iine that is desigred and rrsedfor the interclrang" of traftiJU.tween'the roadrvay and abuttingproperfy,
2' At arry intetsection, a drivervay shall be restricted for a sufficient distance frorn the intetsection to preserve (he
normal and safe moveme[t of traffic, (It is recommended for rural residence entrances that a minimuur
intersection clearance of 50 feet be provided and for nrral commercial entmnces a urinimum of 100 feet bepro',,ided)
3' All eltrances and exits shall be so located and constructed that vehicles approachirrg or using the,r rvill be able toobtain adequate sight distance in both directions atong the county road in-or-cler to rianeuver safely and rvithoutinterfering rvith'county road traffi c.
4' The Applicant shall not bepermitted to erect any sign or display material, either fixed or movable, on orextending ov. er any portion of the county road right-of+vay.'
5' GenerallS no rnore_than one approaeh shall be allorved any parcel or propcrty the frontage of ivhich is less than
one hundreC (100) feet. Adciticnal entranses or exjts for parcels having u front"g" in"xcl.r. of onc hundr-ed l0c)feet shall be perrnitted only after shorving of actual convenience ald nJcessiry. l. ,. i ;.
6' All driveways shall be so located that the flared portion adjacent to the traveled rvdy ivill not encrodch uponadjoining property. ri. .i.
7. No conrmercial drivervay shall have arvidthgr"eater than thidy (30) feet measuredat right angles to the-centerlirie' "of the drivervay eicept as increased by perrnissible radii: No ror.**r.."ial drivervaylhall h'ave.a rvidth greater:: tlian tiventi" (20)'fee t measljred at right angles to the cdnteiline of tlie driveiyuy,."^."pt,u. increased by' pe.rrnissibleiradii.. .
8, The axis of an approach to the road nraybe at a right angle to the centerline of the'county road and of ar:y angle
betrveer ninety (90) degrees and six[r (60) degreei but shall not be less than sixty (60) degrees. Adjustment rvill
be made according to the type of h'affic to be served and other physical colditions.
9. Theconstructionofparkingorservicingareasorrthecountyroadright-of-rvayisspecificallyprohibited.
Conurrcial establisluuents for customer vehicles shoulcl piovide oif-th"-rooi parking faciliiies.
l0' Thegradeoferrtranceaudexitshallslopedorunvardandarvayfromtheroadsurfaceatthesanerateas the
PtAul shoulder slope and for a distance equal to the rvidth ofthe shoulder but in no case less than trventy (20)
feet fi'orn the pavemclrt edge. Approaclr grades are restricterl to not more than ten per-cent OA%).
l1' All ddvervays and approaches ihall be so constructed that they shail not interfere rvith the drainage systen: of thestreet or counfy road, The Applicant rvill be required to provide, at his orvn expense, drainage shuctures at
entlances and exits, rvhichrvill become an integral part of the existingdrainage system. ThJBoard of County
Cotnnrissioners or their representative, prior to installation, must appiove the dinrensions and gpes of all drainageshrchrres.
Note: This pcrrnit shall be made available rt the site rvhere antl ryheu rvork is being donc. A ryork sketcl or.drarving of the proposed drivervay(s) rnusf accompany application. No permit rvill b"e issuetl ryithout ttr.arvilg,
blueyirint, or. sketch.
8Og AtPori Eoad
Sulle 3
Fina,CO.81650
Phcnc 970162+1494
.
Fax970rB2il654
ria.r,v.nouleene6yilcrcrtt
NorlhAmcdci Oivlshn
Date:
rc "8HL",sv
Receiveds Phonel
'Rec6iv.l's Far(: (-12J.F
Sultject:
tr Urgent D For Rovieur
Fax
Sonder'g Fax:
Total Flo. Pages:
D Please Comrnent D Please RePl!E Please Recycle
. Messagei
Thank youl
Drivervay permit Cherk OffForm
I,
)
3.
Pennit Orvaer:
rVailing Address;
City: Carbondale 8i623 f
Ncn, Castle S164T
Parachutc g1635
@oo*il
NEE[s[ wD
3o-foot I nnroot I-J too-roor ffi
Other:l I
-%
I ts-incrr l8-inch f
lI
13' tength of culvert required: 3,-foor [ 40-foot [ofi*rFoo f
14. Asphalt or concrere pad iequired:Yes I No
15. size :tTr, 30-foot w'ide x l0-foor long x 4 ,inches rhick; yes
40-foot rvide X l0-foot long X 4-inches thick: yes
1O0-foot ruide X 20-foot Iong X 4-inches thick; yes
trIrlI
tll
silt 8t5s2 f] aia.8r6so
Glenwood Springs St60l I
Phone No:
County Rd. No:
9. Side of rcad:
I0. Widrh ofdriveway:
ll, Culyert required: yes
12. Size of culvert required: l2-inch
Other;
Other
24"
Other;
4.
J..
6. Nearest lnfersection or address:
7, Distance from Inf. oradrlress:
I6. Gravel portion requirerJ;
t7, Len6.lr oFgravel portiort:
18. Trees or brush rcmoved for visibility:N"K
I9. Distance and direction from drivervay to be
Yes ffi
4o-foot I so-rootI
visibility: t]
drivervay to be removed:
NoI
I00-foot
20, Driveway nrust be no more th'an 3 %o slope away frorn County road.
21. Dtive rnu5t be con$tructed'so no drainage accesses County road ftom driveway,
22. Cer.tified traffic control required:vus[ No K
23. Work zone signage only required: V", ffi No W
24. {itop sigu required at entrance to countlr Rd. Yes X No f]
25. Inspection of drivcway will required upon completion and must be approved
by per.ton irtsuiltg pennit or representative of person issuing pcnnit.
26. Person R.qu.riing Pennit:Baa (rnauxt
27. Person issuing perrrrit:
28, Distr.ict pennit issued io;
29, Date checklist com
2[]rErildXII
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hHeatprrc fi,lLECnL arreNs-'
Thq CgrltrEcto.F. urhota fr68^ !r! -, --.-fotlor.,.il--""'^r llhose name snd signaturo qppEs.rs EsJo$, certl€ies ahd aEr6eF as
t. lhe Contrn
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hE€frhDffiC XhTE6iT& AX,TENS
Ilir:ll:*-tnr, lthose naIuo and sLgnatqre appears e*ton, cErrlfi.es and agroes as
1;r, .11t"fi[}llii!"t shall oonpl'v 'dilh Lhe-pro,risr.on.e cf c:H.6, 0-r1.r-101 6Eto.'perior:n ';;;io-'?;*n'ir_!x!-t"3i'{rryiiu,l-iiftr"",T
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trhar. knowihsiye:nploys or ctntracta *Lulr-oi' iirlgn'i''urr"n,
2' fho conblacEor EeptesenEo, .,arrone.g,. ag.d €gr6es lhaL tt has Terifj.od thst;:.f;:i"l;: n'Hr anv irieiif i-ii"iii tr,;! i'. !$-r..iiJrp,r"a or srqonp(ecr rotr,e i-'-.,;i- s,i,*1i."#Tii'Ii3ff"lHl"n:1-*lil*,'*.:-",tll Tilitil.; y_dl_t*..
"*lptha.rvise sharl corriprvi;iLii-;fr;'iiqurl"rurrr: oe i.ir.s.. ri)^u ,s-\02(a) (b,-.3: the Contractor sh.a11 cornply r+lth sII rFl.canrhta *a^,.^of an irvcstrstabio;-u;'d;;di'*"^';i,'.j'ii""^:easQnEhl€ Toguects mede J.R the qaureeancnmpiov,n;;il"ii-i#a;f ir#;r+itltf f
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flar
From:
Sent:
To:
Cc:
Subject:
Attachments:
Joanne. Lehman@CH2M.com
Tuesday, Apn127,2010 3:46 pM
Kathy A. Eastley
J Kohn@nobleenergyinc.com
LIPA 6246 Water Characterization
Water Characterization Data.pdf
Kathy,
Attached are the analytical results for pH and TDS in the water sampled at the four well locations. Any additionalanalytical results will need to be obtained through Noble, as appropiiate. As stated in our application ihe produced watertanks will be placed in the proper secondary containment and'once updated, covered in the applicable SpCC plan.
I will be in training for the 19xt two days. I willbe picking up voice mail messages as well as e-mails as time permits. I witlbe back in the office on Friday, until than if nothing is urgent, I will call you on Friday to follow-up.
Thank-you,
Jo Anne
our ofFtce has moved, Please note mn chanqe of address and nhone number,
fi 4*u /ul*u
Environmentol Permitting Coordinotor
CH2M HiII
6399 So. Fiddlers Green Cir, Suite 500
Greenwood Villoge, CO B0llt
Direct Line: 7 20-286-0228
Cell: 303-250-4259
Fox: 303-792-2212
ioonne.lehmon@ch2m.com
Water to be lnjected
Locations of Pits and wells where samples of produced water were obtained
SGV.IB.PW.GPTF
SGV.IJ.PW.GPTF
SGV.IK.PW.GPTF
DUTI.34B.PW.GPTF
NW NE sec 1 T8S R96W
NW SE sec 1 T8S R96W
NE SW sec 1 T8S Rg6W
SWSE sec 1 TBS R96W Niobrara production
Work Order Number: 090.t066
Reporting Basis: As Received
Prep Method: NONE
pH in water @ZS Degrees Celsius
Final Volume: 20 ml
Mablx: WATER
Result Units: pH
Method SW9040B
Sample Results
Lab Name: ALS.paragon
Client Name: URS
Client Project lD: Noble-Water Characterization Z2Z3}4S7.OOOO1
Client Sample lD Lab lD
Date
Collecied
Date
Prepared
Date
Analyzed
Percent
Moisture
Dilution
Factor Result
Reporting
LImit Flag
Sample
Niquot
SGV..'BPW.GPTF 090106F1 01h2n00s 01/13/2009 01/1s/2009 N/A 1 7.25 0.1 20 ml
SGV-1J.PW-GPTF 0901066-2 01t12t2m8 01/132009 01/132003 l{/A 1 6.94 0.1 20 ml
SGV-1K.PW-GPTF 0901066-3 01t12,:009 01/13r2009 01113t2009 N/A 1 7.O7 0.1 20 ml
DUTI-34B,PW€PTF 090106S.4 un2n@9 o1113t2009 01/132009 N/A 1 6.45 0.1 20 ml
Comments:
i. fVi o, U = Not Detected at or above the client requested detection nmit.
Data Package lD: ph0901 066-1
ALS Paragon
LIMS VeEion: 6.23SA
Date Printed: Tuesday, January 20, 2009 Page 'l of 'l
2t
TOTAL DISSOLVED SOLIDS
Method EPA160.1
Sample Results
Lab Hame: ALS Paragon
Client Name: URS
Client ProJect lDl Nobl+Water Characterization 22239457.00001
Work Order Number: 0901066 Final Volume: 100 ml
Reporting Basis: As Received MaEix: WATER
Prep Method: METHOD Result Unlts: MG/L
Cllent Sample tD Lab lD
Date
Collected
Date
Prepared
Date
Analyzed
Percent
Mo'lsture
Dilution
Factor Result
Reporting
Limit Flag
Sample
Atiquot
SGV.1&PW.GPTF 090106G1 01/122009 01/132009 ut14r2009 N/A 1 2,1000 1 000 2ml
SGV.lJ.PW.GPTF 090106s2 oilenoog 01/13/2009 01/14/2009 lvA I 23000 1 000 2ml
SGV.1K-PW.GPTF 0901066-3 01l12t2m9 01/132009 01n42009 N/A I 21000 1 000 2ml
DLTTL34B-PW.GPTF 0901066-4 01t1212409 01113/2009 01/14/2009 t.UA 1 33000 1 000 2ml
Gomments:
i. ND or U = Not Detected al or above lhe clienl requested detection limit.
Data Packag e lD: td0901 06&1
ALS Paragon
LIIIS VeEion; 52354
Date Printed: Tuesday, January 20, 2009
' Pagelofl
)\
From:
Sent:
To:
Cc:
Subject:
Truck Loading
Tank Heaters
Generator Engine TBD
Please let me know if
Catherine Flandens
J Kohn@nobleenergyinc. com
Thursday, May 06, 2010 5:30 pM
Kathy A. Eastley
Joanne Lehman
Fw: Noble lnjection Well26-348
o.4 tpy
minimal
you have furthen questions.
Hmmmm not sure this makes things clearer but this is the response from my air personThanks again Judi
Original Message
Fnom: Catherine Flanders
Sent: 05/06/20\0 O3:19 pM MDT
To: ludi Kohn
Subject: Re: Noble fnjection htell 26-348 Judi,
I hope this addresses your questions. It should be noted that the flare is to be installedas part of a secondary safety system and has no bearing on the permitting appticabitity ofthe site.
Cunrent equipment at the sGV26o and SGV35B pads consists of typical wellhead, sepanator, andproduction tanks. The only negulated emission source would be flash emissions fnom the dualpnoduct (condensate and
water) production tanks. Curnent VOC emission estimates for the two pads are in the 2.5-4.5tpy range based upon initial production from the wells.
As such, the tank batteries ane APEN required, but permit exempt. While emissions are notexpected to exceed 5 tpy, NEf is proactively permitting the batteries under Gp01 in caseproduction is higher than estimated.
The waten injection system will add skim system tanks, heaters, and a generator engine to thesite- This equipment is sepanate from the pnoduction equipment. AII }iquids entering theskim system are at stable atomspheric conditions and there are no associated flash emissions.Therefore, tank emissions are limited to working / bneathing losses and are minimal.
With the exemption of the engine and tank heaters, all of the injection system equipment are
exempt from APEN and permitting nequirements per Reg 3, part A Slction rr.D.L.a.
The tank heaters are exempt per Reg. 3, part A, fI.D.1.k.
The engine size requirements are still being evaluated. However, we expect the engine to be
APEN Required, but Penmit Exempt per Reg 3, Part B, Section II.D.1.c. and will submit theappropriate paperwork to ApcD once the equipment has been designed.
Estimated Uncontnolled VOC Emissions
Water Tanks 0.5 tpy
Skim Tank 1.6 tpy
Noble Energy, Inc.
L625 Broadway, Suite 2200
Denver, CO 8O2O2
3O3 228 4150 Direct
3O3 3O4 424O CeIL
3O3 228 428O Fax
cf landers@nobleenergyinc . com
From:
To:
Cc:
Date:
Subject:
I udi Kohn/Denver/NobleEnergy/Samedan
"Kathy A. Eastley" <keastley@garfield-county.com>r "Joanne
Lehman" <Joanne. Lehman@CH2M. com>
"Cathenine Flanders" <cflanders@nobleenergyinc.com>
05/05/2016 O7:Q6 M
Re: Noble Injection Well 26-348
Kathy...I still haven't heard from my air person but what I gather from that e-mail is that
we need an air permit with the state if we cross certain thresholds, which in our case for
these purposes, we do not. It is why we were actively taking steps to put 'controls' in place
in order to not meet the threshold limits (even though we weren't close anyway.) This
operation is far too small and the controls put in place off-set the VOCs it does produce.
I wilt get you more but hope that helps for now.
Thanks
ludi
Original Message
From: "Kathy A. Eastley" Ikeastley@ganfield-county-com]
Sent: O5/O4/2O70 LO:M AIvl CST
To: "Joanne Lehman" <Joanne.Lehman@CH2M.com>
Cc: ludi Kohn
Subject: FI'l: Noble Injection WelI 26-348
As you can see from the history of the emails below I had forwarded your nesponses to
identified issues to the refernal agencies. lim Rada is our Environmental Health Manager and
he contacted Colorado Department of Pubtic Health and Environment regarding the necessity of
Air Emission Permits - perhaps you could translate the response below to inform me whether an
emission permit is requined in this instance or not. Thanks-
Kathy Eastley, AICP
Senior Planner
Garfield County Building & Planning
108 8th Street, #401
Glenwood Springs, CO 81601
Phone: 97O-945-82L2 ext. 1.580
Fax: 97A-3A4-3470
keastley@ga rf ield - county. com
P Please considen the envinonment before printing this e-mail-
-----original Message-----
Imailto: *.,patefi@smtpgate. dphe. state. co. us.
To: ludith Jordan; Jake
ZOLO 1O:32 AI4
MaIl; Jim Rada; Kathy A. Eastley
Cc: Deborah Quinn
Subject: RE: Noble Injection hlell 26-348
A11,
The Division would issue and enforce a penmit for a source who is not exempt from the AQCC
permitting nequinements. fn the case of a water tank, or tank battery, the Division has a
categorical exemption for produced water tank permitting for water with less than 1% cnudeoil content. Otherwise, thene is an uncontrolled emission threshold of 5 tons/year of VOC
emissions that would need to be exceeded to require a penmit.
From: Scott Patefield
Sent: Tuesday, May 04,
In the case of the HB 134t,
water tank with greater than
rule 805 requirements, there is the
5 ton/year of VOC emissions within
95% and have a permit issued by the
us authority to negulate and tnack
COGCC requinement for any
L/4 nlle of a "dwelling unit"
APCD. Once the penmit is
compliance with that permit.
produced water tanks (in
stating that the company
to have a control that meets
issued by the APCD, it gives
Let me know if you have any questions or comments.
Thanks,
Scott Patefield
Enforcement Supenvisor - OiI
scott . patefield@state. co. us
303-692-3L85
a
by
and Gas Team Colonado Air Pollution Control Division
>>> "lim Rada" <jnada@garfield-county.com> 5/3/2OLO L1:O9 AM >>>
Thanks Kathy,
The information is acceptable with regards to the issues f naised. If they are planning a
"non-requined bunner for the tanks", my undenstanding is that CDPHE wilt require an emission
permit for this unit. This permit will require inspection, maintenance and record keepingfor the unit to be submitted periodically to CDPHE fon purposes of tracking compliance. I
have copied Scott Patefield from CDPHE.
Scott, if a
this case,
must obtain
company voluntarily installs a combustor on a set
storage tanks fon an injection well), am I conrect
a permit fon this unitl
of
in
Jim Rada, REHS
Environmental Health Managen
Garfield County Public Health
195 W L4th Street
Rifle, CO 81659
Phone
CelI
Fax
Email
Web
970-625-528O x8tl3
970-3L9-L579
970-625-8304
j rada@garfield- county. com
www. garfield-county. com <http : / /wrtw.Sarfield-county. com/>
From: Kathy A. EastIeY
Sent: Monday, MaY 03, 2OLO 9:54 Alvl
To: ludith Jordan; Jake MaIl; lim Rada
Cc: Deborah Quinn
Subject: Nob1e Injection WelI 26-348
Thank you al1 for responding to the referraL request for the above referenced injection well.
I just wanted to keep you all aware of the additional information that has been submitted to
respond to your comments, and to provide a few photos of the site.
As you
1.
2.
can see below
The site has
The site will
Noble has responded that:
an existing driveway penmit (attached);
not operate 24/7 therefore lighting is only for
emergency purposes;
3. No additional VOC emissions therefore no additional odors (see
response below);
4-Water testing analysis submitted (attached).
f appreciate all the comments.
Kathy East1ey, AICP
Senior Planner
Garfield County Building & Planning
108 8th Street, #401
Glenwood Springs, CO 8150L
Phone: 97O-945-82L2 ext. L58O
97A-384-3470
kea stley@garf ield - cou nty. com
P Please consider the environment befone printing this e-mair.
Fnom : JKohn@nobreenengyinc . com Imairto : JKohn@nobleenergyinc . com]Sent: Tuesday, April 27, 2O7O 4:O9 pt4
To: Kathy A. Eastley
Cc : foanne. Lehman@CH2M. com
Subject: RE: 2 of 2
Thanks Kathy -
Regarding comments:
lake MalI - Road and Bridge - r believe Joanne provided copies of both driveway permits foreach location
lim Rada - REHS -
This will not be a manned 24/7 operation, so lighting wilt only be necessary for
emergency purposes.
There will be no additional VOC emissions as Noble is planning a non-required burnerfon the tanks.
Therefore...no additional odors ane expected either.
Chnis HaIe and Judy Jondan - The peniodic water sampling (within one year of injection, anytime a source is added and/or in 5 year increments with a Mechanical integrity test) requiredby the cOGcC permit is for the waten being injected. A nepresentative samfle ir om tie tankprior to injection is the representative target sample. It witl be a fuII sweet of TDS, majorcations and majon anions and submitted to the COGCC. AII produced water spitls fall unden the
SPCC plan and will have secondary containment as weII.
f hope that covens evenything.
Thanks
Judi
ludi C. Kohn
Environmental Compliance Coondinator
Nob1e Energy Inc.
1625 Bnoadway, Suite 22O0
Denven, CO 8O2O2
Direct: 3A3-228*M7L
Fax: 303-228-4/.59
CeIl: 303-72O-23LL
"Kathy A. Eastley" <keastley@garfield-county.com>
04/27/2OLO 03:35 PM
To
< J Kohn@nobleenergYinc . com>
cc
< Joanne. Lehman@CH2M. com>
Subject
RE:2of2
I've checked with my director about the
Since this is located on a wellpad, it
to be no need for a site visit. I wiII
presentation.
Any infonmation that you can provide to
appreciated.
site visit and one is NOT nequined by the code-
isn't visible from the County Road, etc. there appears
use these photos in the staff report and
me in response to refenral agency comments would be
Thank you.
Kathy EastIeY, AICP
Senior Planner
Garfield County Building & Planning
108 8th Street, #401
Glenwood Springs, CO 81601
Phone: 97O-945-82L2 ext- L580
Fax: 970-384-3470
keastley@ga rf ield - county. com <mailto : keast ley@ga rf ield - county . com>
P Please considen the environment before printing this e-mail.
From : JKohn@nobleenergyinc. com Imailto : JKohn@nobleenergyinc. com]
Sent: Tuesday, APriI 27, ZOLO 3:2L PM
To: Kathy A. EastleY
Cc: Joanne. Lehman@CH2M.com
Subject: 2 of 2
ludi C. Kohn
Environmental Compliance Coordinator
Nob1e Energy Inc.
1625 Broadway, Suite 22OO
Denver, CO 80202
Direct: 3O3-228-447L
Fax: 3O3-228-M59
CelI: 3O3-72O-231L