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HomeMy WebLinkAbout1.0 Application4. TThte: October 15, 1982 40 410 SPECIAL USE PERMIT Applicant: Development Engineering, Inc., Paraho Development Corporation Address of Applicant: 183 Inverness Drive West, Suite 300A, Englewood, CO 80112 Special Use Relocation, Construction, and Operation of Paraho Pilot Plant to perform Retorting Research including: Industrial Support Facilities, Processing, and Mineral Waste Disposal. SW4 SW4 Sec.17; NWaSEa. S1 SEa Sec.18 Legal Description: NWa NWa Sec. 20, T.6S, R.94W, 6th P.M. Garfield County, Colorado Requirements: 1. Plans and specifications for proposed use. 2. Letters of approval from utility companies, sewage and water. Road access and other information deemed necessary. 3. A vicinity map drawn to scale depicting the subject property, location and use of buildings and structures on adjacent lots. 4. An impact statement on the proposed use (see 5.03.07 - 403.09 of Zoning Regs.) 5. A copy of Assessor's map showing property; and a listing of all adjoining property owners and property owners within 200 feet of said property. Notice containing information described under paragraph 5 shall be mailed to all owners of record of these lots at least 5 days prior to the hearing by certified return receipt mail. 6. Notice including the name of the applicant, description of the subject lot, a description of the proposed special use and the time and place for the hearing shall be given in the newspaper of general circulation in that portion of the County at least fifteen (15) days prior to such hearing time. Applicant shall bear the cost of advertising. 7. A fee of $500.00 shall be charged for each application and shall be submitted with the application This Special Use Permit is in compliance with Sections 5.03 and 9.03 of the Garfield County Zoning Resolution and as per application. List all property owners within 200 feet of subject property lines. U.S. Department of Interior Bureau of Land Management U.S. Department of Energy, Naval Oil Shale Reserves W. F. Clough Attach map showing all improvements (present and proposed) and all pertinent distances and area. Show all improvements on your property and adjoining property within 200 feet of your boundary. The above information is correct to the best of my knowledge. Proof of Publication Mail Receipts Fee Special Use Granted Special Use Denied Reason for Denial 641 7(4,4, Applicant Robert N.Heistand Vice President of Environmental Affair Date: October 15, 1982 Board of County Commissioners Garfield County, Colorado • PILOT PLANT RELOCATION ANTICIPATED OPERATIONS 1. Mining and Crushing None (Shale Fines) 2. Raw Shale Screening, 08.8 T/D (1.2 T/H) Samplinc 3. Retorting /,, same) 4. Retorted S 3.3 T/D (81% raw shale rate) and Transf 5. Raw Shale ; 00 T (; acre) 6. Retorted Shale Storage 7500 T/Y (<4 acre) 38000 T(max) (1 acre) 7. Gas Combustion 20 MM Btu/D (171 MSCF/D) 8. Boiler Operation 1000 gal/D (max) 100 M gal/Y (Ave) • • Carbon Monoxide Hydro Carbons Oxides of Nitrogen Sulfur Dioxide GASEOUS EMISSIONS NO CONTROLS GAS COMBUSTION(1) BOILER (2) TOTAL TPY OPERATION TPY 0.06 0.01 20.55(3) 14.06 TPY 0.28 0.06 1.24 2.43 0.34 0.07 21.79 16.49 (1) Gas combustion (thermal oxidizer) serves as control of hydrocarbon, carbon monoxide, and hydrogen sulfide emissions. (2) The use of low -sulfur fuel oil does constitute BACT. (3) Includes fuel NOx (20.21 TPY) and thermal NO (0.34 TPY) T S P ACTIVITY TPY (CONTROLLED)* CONTROL EFFICIENCY & MEASURE 1. Mining & Crushing (Fines) 2. Raw Shale Handling, Retorting 3. Ret. Shale Handling 4. Raw Shale Storage 5. Ret Shale Storage 6. Gas Combustion 7. Boiler Operation TOTAL 0.00 N/A 0.05 (99) Covered conveyors, bag house 0.12 0.56 2.55 0.11 0.22 3.61 TPY (same) (50) water spray (as needed) (50-90) compaction, wet suppression None None *Factored from 40,000 BPD Paraho-Ute Project times factor of 2. 0 8 r ! V LdISSV13 aeon SPECIAL GRANT OF AUTHORITY I, William F. Clough, of Rifle, Colorado, grant to Development Engineering, Inc., a Colorado corporation, ("DEI") full power and authority to apply for and obtain any zoning determinations or any other federal, state or local permit necessary for construction and operation by DEI of a pilot oil shale retort plant on land owned by me in Garfield County, Colorado and more particularly described as follows: Township 6 Section 18 full power everything personally South, Range 94 West 6 PM, Section 17 SW1/4SW1/4, NWSE,S1/2SE, Section 20 NWNW. I and authority in exercising said necessary as fully as I might or grant power could present and fully competent, with full to DEI to do do if power of substitution or revocation, hereby ratifying and confirming all that DEI shall lawfully do or cause to be done by virtue of this grant of authority. This grant is revocable, provided that insofar as any governmental agency, or other person is concerned, who shall rely upon this grant, this grant may be revoked only by a notice in writing executed by me or DEI and delivered to such person or institution. Third parties may rely upon the representations of DEI as to all matters relating to any authority granted to DEI, and no person who may act in reliance upon the repre- sentations of DEI or the authority granted to DEI shall -1- • • incur any liability to me or my estate as a result of permit- ting DEI to exercise any authority. Unless sooner revoked in the manner above provided, this grant of authority shall expire at midnight on ,L71/_5--- , 1991. Any photographic copy of this grant shall have the force and effect of the original. This grant of authority is executed and delivered in the State of Colorado, and the laws of the State of Colorado shall govern all questions as to the validity of this grant and as to the construction of its provisions. IN WITNESS WHEREOF, I have executed this grant of authority this LC day of October, 1982. STATE OF COLORADO ) COUNTY OF GARFIELD ) ss. 1•91/(..---11/7-1-U WILLIAM F. CLOUGH The foregoing instrument was acknowledged before me this /S -day of October, 1982, by William F. Clough. (SEAL) Witness my hand and official seal. 1 %( ./J%J�.�r.'i �� (����� Notary Public � Address: /2(J . T? (_ //5L/ lX1.1 Ono 7 /' (1./) My commission expires -2- S/'l:3 • • PARAHO RESEARCH SITE IMPACT STATEMENT TABLE OF CONTENTS INTRODUCTION LOCATION SCOPE Area Manpower Operations SCHEDULE REGULATORY COMPLIANCE Federal Colorado Garfield ENVIRONMENTAL IMPACTS Water Air Quality Wildlife and Domestic Animals Others TRAFFIC PROPERTY VALUES RECLAMATION • • LIST OF ILLUSTRATIONS TABLES 1. List of Proposed Operations 2. Total Suspended Particulate Emissions 3. Projected Gaseous Emissions FIGURES 1. Area Map 2. Plot Plan 1 • PARAHO RESEARCH SITE IMPACT STATEMENT INTRODUCTION Paraho Development Corporation (Paraho) intends to relocate its Pilot Plant retort from the federal facility at Anvil Points, located approximately nine milies west of Rifle in Garfield County, Colorado. This retort will be relocated, erected, and operated on private land adjacent to the Anvil Points facility. This research operation proposed by Paraho would continue oil shale retorting testing that has been performed in this area for nearly forty years. The operation proposed by Paraho is small; an on-site staff, 30 to 40 workers (all Garfield County residents) would test oil shale retorting using less than 30 tons of oil shale per day. This impact statement has been prepared to meet Section 5.03.07 and 5.03.08 of the Garfield County Zoning Resolution, as amended. Paraho, through its operating subsidiary, Development Engineering, Inc. (DEI), has leased the Anvil Points facility from the United States Government from May, 1972 until May, 1982. During that ten year period, nearly 100 workers were employed and daily operations exceeded 300 tons of oil shale per day. During that period, DEI obtained permission from W. F. Clough to use an adjacent tract of land for retorted oil • • shale research. As part of that research, the site was protected from incoming runoff and surface water protected from any outgoing runoff ditches and a lined retorted shale were or leachate by a series of diversion evaporation pond. Nearly 16,000 tons of placed in an area about 160 feet by 400 feet to test field compaction procedures. Research regarding stability and revegetation has continued after attempts to extend the Anvil Points lease in May, 1982 failed. In early 1982 DEI laid off most of the workers and began searching for an appropriate site to continue oil shale research using the smaller Pilot Plant retort. Paraho has leased a 200 -acre tract for a 10 -year period from W. F. Clough. • LOCATION The proposed research site is located about nine miles west of Rifle, Colorado adjacent to the federally owned Anvil Points facility (see Figure 1). It is bounded on three sides (north, east and west) by Federal lands and on the south and east by other lands owned by W. F. Clough. The legal description of the plant property is: SW-1/4SW-1/4 Sec. 17; NW-1/4SE-1/4, S-1/2SE-1/4 of Sec. 18; Sec. 20, T.6S., R.94W., 6th P.M., Garfield County, Colorado 11 i SCOPE Area - The overall area of the proposed research site is 200 acres (see Figure 2). Less than five acres will be disturbed. At the northern edge, there is_aome ,raw shale feedstock that would be used in part of the planned research operations. hale will be transported by truck to a storage bin using the road system across the Anvil Point site or an existing road essentially within the 200 acre site. Most of the construction and operation activities will be carried out in the southernmost 40 acre section. Retorted shale will be stored in the 1 acre section comprising the northern half of the existing retorted shale compaction test area. The southern half of that test area will be maintained to continue on-going vegetation studies. The diversion ditches and evaporation pond will be maintained as -is to preven water contamination. The existing parking area will be upgraded. Ne construction consisting of the erection of the Pilot Plant retort and shale storage bins, control room and offices, laboratory, shop, oil storage, and roadway should not impact more than five acres. Permanent disturbance should be less tha Manpower - During construction, as many as Z5 workers will be employed. This workforce would consist primarily of DEI workers, both those retained and tho.a.2-__terminat444 in May, 1982, augmented, whenever necessary, by local contractors. The construction is expected to require approximately six months. • • During operations, about 40 workers may be required. This workforce would consist, as in the case of the construction workforce, of DEI workers. About 10-15 of this operating workforce would work in the shop, lab, and office during the normal day shift. Others would work shiftwork. Thus, the typical on-site workforce would vary from about 5 to 20 workers. Duration of the operations is unknown. The term of the lease will be ten years. Operations - A list of the proposed operations is presented in Table 1. No mining or crushing activities are planned at the present time. Retorting and shale feed preparation, screening, sampling and transfer will be performed at the maximum rate of 1.2 tons per hour (28.8 Retorted shale handling • . •- operations (sampling and transfer) will be performed at the maximum rate of 23.3 to y (81% of the raw shale feed rate - on the average 19% of the raw shale is lost as gas, oil, and water). Transfer operations will be performed using covered conveyors and bag houses to control par I . ate (dust) emissions. Two storage piles are planned - a 5,000 ton existing raw storage and a maximum , 00 ton retorted shale storage. The maximum retorted shale storage is based upon performing one month research runs for clients approximately 50% of the time over the 10 year lease. Plans are being developed to use this retorted shale material for research procedures in above -ground slope -protection for long-term stability or in -mine disposal. Table 1 PILOT PLANT RELOCATION ANTICIPATED OPERATIONS 1. Mining and Crushing Shale Fines) 2. Raw Shale Screening, Sampling and Transfer 3. Retorting 4. Retorted Shale Sampling and Transfer 5. Raw Shale Storage 6. Retorted Shale Storage 7. Gas Combustion 8. Boiler Operation None at Present 28.8 T/D (1.2 T/H) (same) 23.3 T/D (81% raw shale rate) 5000 T (1/4 acre) 7500 T/Y (<1/4 acre) 38000 T(max) (1 acre) 20 MM Btu/D (171 MSCF/D) 1000 gal/D (max) 100 M gal/Y (Ave) • • If necessary, these storage piles will be protected from particulate'emissio water sprays or wetting as needed. Oil produced from the research operations will be de- livered to the client in drums or tank trucks. Crude oil produced from the Pilot Plant operation will be collected, guaged, and sampled in two run-down tanks having capacities for 30-40 barrels each (about 1,500 gallons each). From there, the crude oil will be pumped to drums for shipment to the client or to intermediate storage. This intermediate storage will consist of one -to -two 100 barrel tanks (total storage not to exceed 10,000 gallons). From intermediate storage, the crude oil will be returned to the client in drums or tank trucks. All storage areas will be protected b d.- operation will conform to the SPCC Plan. There are other fuel st. research site. These include: (1) Diesel Fuel (Process) 8,000 gallons 10,000 gallon tank (2) Propane (Process) 1,000 gallons 1,000 gallon tank (3) Motor Fuel 500 gallons 500 gallon tank (4) Diesel Fuel (Vehicles) 1,000 gallons 1,000 gallon tank (5) Lube Oils & Greases 250 gallons drums These storage areas will be located outside buildings and .0, e•uirements planned for the will be adequately protected against heat, flames and static electricity. "No Smoking" regulations would be in effect as appropriate. All waste water (steam condensates, boiler blow -down, etc.) will be evaporated. No _process water will be discharged. • The gas produced from the retorting operations will be completely combusted to minimize the discharge of gaseous hydro -carbons, carbon monoxide and hydrogen sulfide. This will be performed using a thermal oxidizer, permitted for DEI's previous Anvil Points operations. The other combustion source is the package boiler for steam production. In order to minimize the discharge of sulfur dioxide, low sulfur fuel oil will be utilized in this operation. Initially, the services of sanitation and ectrical power will be provided as follows: drinking water will be supplied by a local vendor; installation and maintenance of portable toilets will be -contracted; and power will be generated on-site. SCHEDULE The schedule for construction consisted of the following tasks: (1) Dismantling and removal of the Pilot Plant retort from its current site at Anvil Points (October - November, 1982). (2) Prepare the proposed site to maintain current water diversion system, upgrade parking area, and prepare specific areas for foundation (October - November, 1982). (3) Prepare foundations and infrastructures (November - December, 1983). (4) Relocate Pilot Plant retort and other equipment to the proposed research site (November - December, 1982). (5) Erect retort, storage bins, conveyors, buildings, (January - March, 1983). Complete construction and begin start-up operations (March - April, 1983). NOTE: Tasks (3, 5, 6) will depend upon receiving approval of required permits. The operations schedule will result from contract (6) retorting which will last, normally, from four to six weeks each. Round-the-clock operations are planned with an on -stream operating factor of 90% or higher. It is anticipated that approximately four to six operations would be carried out per year resulting in an annual on -stream factor of about 50%. -8- REGULATORY COMPLIANCE The proposed Paraho research site will comply with all applicable laws and regulations of Garfield Count the State of Colorado, and the United States Government. The following perm- an approvals have been considered: Federal (1) Prevention of Significant Deterioration (Air Quality); estimated emissions do not require PSD (J. Dale, EPA, 10-01-82). (2) Spill Prevention Control and Countermeasure Plan, the SPCC Plan, developed for DEI's use of Anvil Points will be modified as required. (3) Dredge and Fill (404), Tall Structures, Rights -of -Ways (R -O -W's), Hazardous Wastes; currently planned operations do not require these permits. Colorado Colorado Department of Health, APCD; the air permit currently in force for DEI's Anvil Points Operation can be transferred to the proposed site (G. McCutchen APCD, 10-01-82). Colorado Department of Health, Solid Wastes; a permit will be required before operations are begun (D. Hotovek, WMD, 10-01-82); an application is being prepared. (3) Colorado Department of Health, WQCD; NPDES, S.404, are not needed for current operations. (4) Colroado Department of Health, Sanitation/Drinking Water. No permits needed for planned operations. (5) Reclamation and Mining; since planned operations do not include mining, no permits are required (D. Shelton, MLRB, 10-01-82). Garfield County (1) Certificate of Solid Waste Disposal; permit is required, the application is being prepared for submittal to Garfield County. Planning Department (see Colorado permits (2)). (2) Zoning. A special use permit is required ( D. Stranger, G.C.P.D., 10-04-82). (3) Building. Building permits will be required for all new structures (D. Stranger, G.C.P.D., 10-04-82). Work is underway to prepare applications and/or secure transfers of above permits as indicated. This work should be completed by November, 1982. • • ENVIRONMENTAL IMPACTS Water - The proposed Paraho research site will not adversely impact water. Surface runoff will be directed around the operating area to avoid contamination of surface water. Runoff or leachates from the operating area will be channeled to an existing lined pond for evaporation. An existing monitoring well, located down stream of the area will be checked periodically for any sign of impact. There are no active ground water aquifers in the region of the proposed site. Recent gas wells, drilled in the Sharrard Park plain, situtated between the proposed site and the Colorado River, did not encounter water until depths of more than one thousand feet were reached. Water use will be minimal. Potable water needs should be less than 100 gal/day. Process water for steam generation should not exceed 3,000 gal/day. Average overall water needs should not exceed 10,000 gal/day. No process wa er will be discharged. Product water will not be separated from the crude shale oil. Other process waters, runoffs, and possible leachates will be disposed of by evaporation. Air Quality - Adverse effects of the proposed operations on air quality will be minimal. First, these research operations are small scale; the total amount of material expected to be procesed during the anticipated ten-year lease would be less than that processed during one day of full-scale commercial operations. • • Secondly, even though the research operations proposed by Paraho are small scale, appropriate control measures have been incorporated in the plans. These measures include the following: • covered conveyors • baghouses • water sprays • wetting suppression to control particulate emissions • combustion to control hydrocarbon, carbon monoxide and hydrogen sulfide • use of low -sulfur fuel oil to minimize sulfur dioxide emissions Anticipated levels of emissions of the pollutants are listed in Tables 2 and 3. All are expected to be less than 25 tons/year far below the 100 tons/year levels which would trigger the need for the PSD permit. The planned operations will not be a major source of air pollution. Wildlife and Domestic Animals - The planned research operations will not affect more than five acres. Most of the areas planned for the relocation project are already being used. The areas planned for the Paraho operations do not include Table 2 TOTAL SUSPENDED PARTICULATE CONTROL EFFICIENCY ACTIVITY TPY (Controlled)* & MEASURE 1. Mining & Crushing (Fines) 2. Raw Shale Handling, Retorting 3. Ret. Shale Handling 4. Raw Shale Storage 5. Ret Shale Storage 6. Gas Combustion 7. Boiler Operation 0.00 0.05 0.12 0.56 N/A (99) Covered conveyors, bag houses (same) (50) Water spray (as needed) 2.55 (50-90) Compaction, wet suppression 0.11 0.22 None None TOTAL 3.61 Tons per Year *Factored from 40,000 BPD Paraho-Ute Project times factor of 2. -13- • • Carbon Monoxide Hydro Carbons Oxides of Nitrogen Sulfur Dioxide Table 3 GASEOUS EMISSIONS NO CONTROLS Gas Combustion(1) TPY 0.06 0.01 20.55(3) 14.06 Boiler Operation(2) Total TPY TPY 0.28 0.06 1.24 2.43 0.34 0.07 21.79 16.49 (1) Gas combustion (thermal oxidizer) serves as control of hydro- carbon, carbon monoxide, and hydrogen sulfide emissions. (2) The use of low -sulfur fuel oil does constitute BACT. (3) Includes fuel NOx (20.21 TPY) and thermal NOx (0.34 TPY) -14- • • important migration routes, browse, range land, or nesting, fawning, or lambing areas. Thus, impacts on wildlife or domestic animals will be minimal. Others - For the most part, the Paraho operations will be carried out in a secluded valley that is not visible from he interstate highway, I-70, located about one and one half miles south. The present housing area, consisting of 21 houses about one-half mile west of the proposed research site, have been slated to be demolished by the G. S. A. of the federal government. The next nearest dwellings are at least four to five miles away. Thus, the area is quite remote. The small scale of operations and the remoteness of the site shoud pose no serious adverse effects in the areas of noise, vibrations, heat or glare. At times during construc- tion, noise may exceed 95 decibels. • • TRAFFIC The limited research operations planned by Paraho should not create levels of truck and automobile traffic that would create hazards or nuisances within Garfield County. During construction, the peak traffic loads to the site would be less than 200 trips per day. During operations, this load will be -iced by more tha�Q -ha-}-er Large vehicular loads should be minimal; no oversized or overweight loads are anticipated. • • PROPERTY VALUES As discussed under" LOCATION" and "ENVIRONMENTAL IMPACTS, Others", there are sufficient distances to separate abutting properties from damage. The federal property at Anvil Points has been used for forty years for extensive oil shale research operations much larger than that proposed by Paraho. The private property adjacent to the south and east of the proposed site, has been used for gas well exploration and development, industrial staging sites, and limited grazing by sheep and cattle. Damage to the abutting properties should be insignificant. • • RECLAMATION PLAN After the completion of the planned research operations, Paraho will reclaim the site to the Zresent conditions. This reclamation plan will consist of the following: 1. dismantlement of all structures and foundations and removal from the property 2. removal of all storage bins, tanks, and drums from the property 3. removal of all shale oil and fuel 4. removal of all materials from the shop yard used to construct and operate the research site 5. proper disposal of retorted shale - this entails a. on-site disposal using means approved by the landowner and all appropriate agencies, and/or b. off-site disposal or use, meeting all required approvals 6. revegetating all disturbed areas with cover approximating conditions that now exist 7. protecting the reclaimed site and adjacent areas from damage due to run-off, leachates, etc. Although the cost of this reclamation is not available at this time, it should (based upon engineering studies performed for larger, commercial operations) be less than the salvage value of the buildings, equipment and supplies on site at that time. -18-