HomeMy WebLinkAbout22 NTC ResponseO\OLSSON
ASSOCIATES
NTC Response
OXY USA WTP LP
Pond 13 E/W
Centralized E&P Waste Management Facility
OA Project No. 013-0655
760 Horizon Drive, Suite 102 TEL 970.263.7800
Grand Junction, CO 81506
FAX 970.263.7456 www.olssonassociates.com
ONOLSSON
ASSOCIATES
October 22, 2013
Kathy Eastley
Senior Planner
Garfield County Community Development Department
108 8th Street, Suite 401
Glenwood Springs, CO 81601
keastley@garfield-county.com
Re: LIPA 7675 Oxy Pond 13 E&W — Water Impoundment/Material Handling
Dear Kathy,
Please find Oxy's response to your Not Technically Complete Letter of August 28, 2013. Included in this
package are:
1. Response to questions.
2. Revised application with changes to the waiver requests.
3. Deed to the parcel which was omitted from the original application.
4. Revised Waiver Request.
5. Water Supply Plan including Nontributary Ground Water Analysis.
6. Wastewater Management Plan.
7. Oxy Mesa Operational Map (source of fluids and transportation pipelines).
8. Revised Project Description.
9. Revised Vicinity Map.
10. Revised Site Plan.
11. Signed Geohazard Report.
12. Letter from Oxy regarding Air Quality Permitting.
Please let us know if you need any additional information. Be advised that Craig Richardson is no longer
with Olsson. I will be representing Oxy for this and future land use permitting.
Thank you for your consideration of this application.
Sincerely,
Jeff Hofman, AICP
Associate Scientist
Cc: Oxy
File
760 Horizon Drive, Suite 102 TEL 970.263.7800
Grand Junction, CO 81506
FAX 970.263.7456 www.olssonassociates.com
OOLSSON
ASSOCIATES
OXY USA WTP LP
Pond 13 E/W Waste Management Facility
NTC Response
In regard to Garfield County's Not Technically Complete Letter dated August 28, 2013, Oxy has
prepared the following responses:
1. GarCo Comment: Is this application resulting from a violation? It does not appear that the
existing ponds are located within the area of a COGCC-approved well pad, if not located on
a pad the pond would be required to obtain County permitting prior to construction. Can you
provide information on this issue?
Response: There is no COGCC violation. This is a COGCC approved Form 15 site. This
facility is located immediately adjacent to Oxy's 604-44 pad (COGCC Facility ID: 335849).
2. GarCo Comment: The request for waiver of submittal requirements is vastly different from
a request of waiver of the standards contained in the LUDC. A waiver of submittal of the
Landscape Plan does not negate the requirement to satisfy the standards of the code
contained in 7-303. The Director of Community Development may waive submittal
requirements however only the BOCC may waive compliance with minimum standards. If
you are requesting a waiver from the standard please add that to the application form and
provide adequate justification for the Board to make a decision on the waiver.
Response: We are requesting a waiver of submittal for the Landscape Plan (please see
the Waiver Requests section of the application). No landscaping is being proposed for this
site as it is located in a rural and remote area of Garfield County. The site is within a large
property and only accessible via a private road system. We have addressed the landscape
standards on page 7 of the Standards Analysis. If a Landscape Plan waiver is not required,
please disregard the request.
3. GarCo Comment: The request for waiver of submittal of a Water Supply Plan and the
Wastewater Management and System Plan are not appropriate and therefore the waiver is
not granted. Regardless of the fact that you provide no information in support of the request
for waiver the information in a Water Supply Plan and Wastewater Treatment Plan is
necessary to determine if the water and wastewater systems proposed for the site are
sufficient to serve the project. These plans are required even if no potable water or ISDS is
planned, as it is these reports that will provide evidence that bottled water / porta-potties are
sufficient to serve the intermittent employees at the site. Therefore please provide
information compliant with Sections 4-203 (M) and 4-203 (N) of the LUDC.
Response: We have removed the indication for a waiver of the submittal requirement for a
Water Supply Plan and the Wastewater Management and System Plan from the Application
form. Please see the Water Supply Plan and Wastewater Management and System Plan
sections of the application for these submittal items.
760 Horizon Drive, Suite 102 TEL 970.263.7800
Grand Junction, CO 81506
FAX 970.263.7456 www.olssonassociates.com
OXY USA WTP LP October 8, 2013
Pond 13 E/W Waste Management Facility
4. GarCo Comment: There is no indication that the project site is located within a Special
Flood Hazard Area, nor is this a request for a PUD >5 acres or proposing 50 lots or greater,
so there is no requirement for a Floodplain Analysis. This submittal requirement will not be
waived as it simply is not applicable to this site.
Response: Please disregard the waiver request for a Floodplain Analysis as it is not
required for this application.
5. GarCo Comment: The Landscape Plan is a submittal requirement for all Limited Impact
applications however Section 7-303 excludes industrial uses from a requirement to meet
Landscape Standards making this submittal requirement 'not applicable'. No waiver is
required.
Response: Agreed. Please see response to Item 2 above.
6. GarCo Comment: The remainder of the items requested to be waived as submitted
requirements- the Improvements Agreement and Development Agreement - are hereby
waived as submittal requirements.
Response: Noted.
7. GarCo Comment: The pre -application summary lists the parcel as being 10,303 -acres, the
application states that the site is 640 -acres and the parcel number provided is shown as a
1,053.08 -acre parcel. Please clarify.
Response: The 10,303 acreage listed in the Preapplication Summary is incorrect. It is
based on contiguous parcels of which this parcel, 216904400003, is a small part. The
project is located on this smaller 640 acre parcel. This is the parcel referred to throughout
the application. The 1,053.08 acre parcel is a larger parcel owned by Oxy that is adjacent to
the project parcel.
8. GarCo Comment: The applicant is responsible for demonstrating legal and physical access
to the site- are there easements or agreements related to the private road system? What are
the physical characteristics of the road and does it meet County Standards in Article VII?
Response: No easements exist for the private road system. It is completely contained
within Oxy owned property. Please see the Access and Roadways Standards Waiver
Request.
9. GarCo Comment: The application states that the fluids will be transported via pipelines to
the ponds. How will the water be transported post -storage when it will be re -used? In the
same pipeline? Trucked? This information is necessary to determine the potential impacts of
the project.
Response: All water will be transported to and from the site via water distribution pipelines.
Please see the attached GIS map indicating distribution and gathering pipelines and well
pad locations. The same water pipelines serve as inflow and outflow pipelines.
10. GarCo Comment: It does not appear that a full description of the proposal was included in
the Project Description section of the submittal. There appears to be a significant amount of
storage that may or may not be related to, or accessory, to the use of the impoundment- two
areas on the site plan appear to be dedicated for storage yet no mention of this is found in
the project description. Please provide additional information on what will be stored there
and if the storage is directly related to the impoundments. If additional equipment, materials,
NTC Response Page 2
OXY USA WTP LP October 8, 2013
Pond 13 E/W Waste Management Facility
and supplies unrelated to the impoundment are proposed to be located on this site then a
request must be made to add the use of "storage" into this application.
Response: Please see revised Project Description.
11. GarCo Comment: The site plan requirement has not been adequately addressed as
indicated by the items below:
a. Sheet 1 of 2 is unnecessary as a smaller vicinity map would suffice. It is confusing to
have a "Site Plan" at a scale of 1" = 2000'.
Response: Sheet 1 of 2 has been removed.
b. Location and dimension of easements or location of the pipelines transporting the water
to the site are required - one appears to be located at the north end of the project area,
is this the only pipeline that will serve these impoundments?
Response: The site plan has been revised.
c. Does the legal description of the project area (Detail A Area) include 21.47 -acres? The
legal description doesn't include the acreage so it is difficult to ascertain what it
incorporates. The pre -application summary indicates a project area of 17.67 -acres which
is resulting in confusion;
Response: The legal description is for the whole parcel that the project is on. The
Project Area Description below Detail A is the legal description for the project area and
includes the square footage and area of the project.
d. Elevation drawings showing existing grade, finished grade, and height of the proposed
structures above existing grade are required.
Response: The site plan has been revised.
e. The location of fencing is shown around the ponds, will the storage areas be fenced?
Response: No hazardous material or other items requiring fencing will be kept at the
storage area. Fencing is not proposed at this time.
12. GarCo Comment: Provide information and a comprehensive map that indicates location of
the wellpads from which the water will be produced, along with the location of pipelines and
an indication of all surface owners related to the above. If the well pads and pipes are all on
Oxy -owned land then please provide a statement to that effect.
Response: A GIS map showing the location of pipelines and well pads is included with this
letter and will be included in the referral copies. All pads and pipelines are on Oxy -owned
land.
13. GarCo Comment: The NRCS soil survey was provided which indicates the soils type found
on-site, however no analysis of that type of soil impact on the proposed development was
included. A qualified individual is required to provide this information however there is no
indication who completed the analysis.
Response: A revised and signed Geologic Hazards report is included in this response.
Please find the signature of the qualified Geologist who prepared the report on last page.
NTC Response Page 3
OXY USA WTP LP October 8, 2013
Pond 13 E/W Waste Management Facility
14. GarCo Comment: The Geologic Hazards report is not signed nor is there any indication of
a qualified individual completing the information.
Response: A signed Geologic Hazards report is included in this response. Please find the
signature of the qualified Geologist who prepared the report on last page.
15. GarCo Comment: Please provide specific information related to fire protection at this site,
the associated with this use?
Response: This site will comply with Oxy's emergency response at all times. Fire
protection is addressed in the plan included with the original submittal. See Appendix A,
starting at pg. 35.
16. GarCo Comment: What air quality permits will be required for operation of this facility? It is
not sufficient to respond to the air quality standard that all necessary permits will be
obtained. Since this is an existing facility one would assume that all required permits had
been obtained upon operation of the ponds. Please provide copies of all air permits as well
as additional demonstration of how you will comply with this standard.
Response: See attached letter.
17. GarCo Comment: There does not appear to be any information related to netting and
escape steps from the ponds as typically required by CPW. Please respond
Response: The CPW will review the application as part of the Garfield County and COGCC
permitting process. The location is currently improved with flagging at regular intervals and
8 -foot high chain link fencing. The CPW will notify the applicant of additional wildlife BMP
requirements, and they will be required as part of the COGCC approval and enforced during
COGCC inspections.
NTC Response Page 4