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HomeMy WebLinkAbout1.04 Project narrativeProject Narrative Encana Oil and Gas (USA) Inc South Middle Fork Water Facility OLSSON ASSOCIATES OA Project No. 012-0400 826 21 '/2 Road 1 Grand Junction, CO 81505 1 TEL 970.263.7800 1 FAX 970.263.7456 Encana Oil & Gas (USA), Inc. South Middle Fork Water Facility Project Narrative Encana Oil & Gas (USA), Inc. (Encana) requests a Garfield County (GARCO) Limited Impact Review (LIR) for construction and operation of the proposed South Middle Fork Water Facility (SMF) that will support the natural gas development activities of Encana. Encana is requesting this permit under the "Materials Handling and Water Impoundments" land use(s) that are allowed uses in the Resource Lands zone district. The water to be handled at this facility is produced from drilling, completion and production operations associated with natural gas wells. Water that is produced from these operations is classified as an exploration and production (E&P) waste by the Colorado Oil and Gas Conservation Commission (COGCC). Pursuant to COGCC Rule 908, this facility will also be permitted as a Centralized E&P Waste Management Facility with the COGCC. The water facility will consist of the following equipment: a dissolved air floatation (DAF) treatment system housed in a building, various tanks ranging in size from 500 gallons to 300 bbls, secondary containment (as required) for all tanks, piping, pumps and appurtenances, a control room for monitoring operation of the facility and four double lined impoundments (including leak detection) with a total storage capacity of approximately 1.2 million barrels of storage (42 million gallons). The impoundments will be covered with an impervious synthetic material in order to minimize air emissions and prevent wildlife access. Future development may occur on the unused portion of the property to the southwest. The site for the proposed Encana Water Facility is approximately three miles north of the Parachute, Colorado city limits on County Road 215. The site is located on the west side of CR 215 in the vicinity of the Wheeler Gulch Road. The site encompasses approximately 20.5 acres, at an elevation of 5,577 feet. The property is owned by Encana and the proposed water impoundment facility will operated by Encana. The relatively remote nature of Encana's operations necessitates the construction of this facility so that water produced during the drilling, completion and production of natural gas wells in the area may be collected and stored in a central location for reuse in operations or disposal. The goal of Encana's water impoundment project is to increase the ability to recycle produced water for drilling and completion activities. This facility is designed to provide a consolidated system of water storage impoundments that Encana will use to efficiently and safely transport water around their field(s). The construction of the water storage facility and associated pipeline infrastructure (which has been permitted separately with Garfield County) at this location will enhance Encana's ability to reuse produced water in its operations. The water impoundments will also reduce the amount of truck traffic thereby increasing the safety of Encana's operations and minimize their impact on neighboring properties and the environment. The proposed storage capacity will enable Encana to store water during low demand days and reduce or eliminate trucking water to a commercial disposal Project Narrative Page 1 site. Operation and monitoring of the facility will not require any additional equipment other than what is outlined above. Monitoring of operations will typically be performed periodically (on a daily basis) during the daylight hours of 7:00 am to 6:00 pm by an Encana employee arriving via pickup truck. Potable water and septic will be provided via a licensed vault and haul system provider. Safe operation of the Encana SMF facility will require the installation of a control building which will house equipment related to data monitoring and data collection. Water and waste (sewage) from the facility will be handled via a vault and haul system designed to accommodate a single person and will meet all appropriate Colorado Division of Public Health and Environment (CDPHE) (CDPHE) requirements. A licensed water and sewage hauler will monitor the system approximately every seven days. The system will also be permitted according to Garfield County Building Department requirements. The perimeter of the facility will be fenced in order to restrict access to the general public and wildlife. A dust control program will be implemented for the construction interval and use of the access road. In order to ensure water protection of water quality, Encana will install ground water monitoring wells in proximity to the facility. As part of the Garfield County permit approval process, Encana will secure all appropriate CDPHE air quality permits. The approved permit will address the impacts and appropriate level of mitigation for the facility associated with fugitive dust and hydrocarbon volatilization from the facility. The key benefits of the proposed water impoundment project are: Minimize impacts to wildlife and vegetation by constructing a facility proximate to previously disturbed surface Control emissions and minimize impacts to air quality by covering the impoundments Reduced trucking / improved safety Use of an engineering controlled transfer system Reduction in volumes of disposed water Conservation of freshwater Reduced road maintenance Overall reduction in development and operating cost Details of this request along with the information required by GARCOs LIR application are provided below. The majority of the adjacent properties are currently undergoing oil and gas development. The nearest municipality is the Town of Parachute, approximately three miles southeast. There is one residence located within 1,500 feet of the site, and two residences located just outside a 1,500 foot radial circle (See Figure 11). Copies of deeds demonstrating ownership of this property are contained in the Deeds section. The proposed water storage facility is located more than 200 feet from the exterior boundary of the property owned by Encana. Project Narrative Page 2 As part of the GARCO LIR approval process, proper notification will be provided to all appropriate landowners and mineral owners. The list of landowners and mineral owners that will be sent certified letters informing them of the proposed project and hearing dates are included as part of the overall GARCO LIR submittal package. The design for the proposed water storage facility is provided in the facility site diagram and construction documents. Stormwater management protections, specific best management practices (BMPs) and other drainage controls have been designed into the facility as shown on the Grading Plan and Construction Erosion Control Plans. The produced water impoundments will be constructed according to the criteria identified in the Colorado Oil and Gas Conservation Commission (COGCC) Rule 904. D. including double lining with 60mi1 liner(s), a leak detection system and high level detection monitors/alarms. All impoundments will be permitted in compliance with the appropriate COGCC regulations for E&P Waste Facilities. All production water handled at this facility will have already been gravity separated to remove hydrocarbons. This initial separation occurs on the location where the water has been used in E&P operations. Upon arrival at the SMF, additional separation via filtration equipment will remove trace hydrocarbons from the produced water. The water will then be sent to the storage impoundments. The impoundments will be treated with biocide as necessary. As detailed in the Auxiliary Lane Analysis, prepared by River City Consultants, access is proposed via a new access to County Road 215. This access will be the fourth leg of the County Road 215/Wheeler Gulch Road intersection. The Auxiliary Turn Lane Assessment addressed the sight distance, trip generation, directional distribution, site -assignment of trips, and recommendations for auxiliary turn lanes associated with the proposed SMF near Parachute, Colorado. Based on the Colorado Department of Transportation (CDOT) Access Code, the projected trip generation and directional distribution; a northbound left -turn deceleration lane is not warranted. However, the deceleration lane will be provided due to truck traffic. A copy of the report, which includes the turn lane assessment, is included in the Supplemental Materials section. There is an existing access to this site that is located north of the Wheeler Gulch Road intersection. This access will be eliminated when the new access is constructed and the Water Facility is completed. The existing access will be used during construction, until the new access has been built. Construction at the site will begin upon approval of this application and may take up to 120 days per impoundment to complete. No less than 45 days prior to the commencement of construction activities, Encana will submit a Notice of Intent to Construct a Non -jurisdictional Water Impoundment Structure (as per Section 37-87-125, C.R.S.) to the Office of the State Engineer, Division of Water Resources. Project Narrative Page 3 The water storage facility will be accessible to Encana personnel and their contractors 24 hours - a -day, 365 -days -a -year. The facility will generally be manned during daytime hours. Daily inspections will be conducted by local operations personnel. Operations and maintenance of the proposed facility will be coordinated with the existing operation of the impoundments to the southeast. An analysis of the traffic anticipated to be generated by this project is provided in the Supplemental Materials section. Construction at the water storage facility will result in a temporary traffic increase as follows: Phase Vehicles Duration Construction Phase 10-15 pickups and 2 semi trucks* Cranes Earth moving equipment 6 months Lining Phase 4-6 pickups 3 weeks Cover Phase 4-6 pickups 4-6 weeks *Semi trucks will be utilized on first and last days of construction phase No additional mobilization of heavy equipment will be required for this location. All vehicles hauling equipment and material for project construction on County Road 215 will abide by Garfield County Road and Bridge's oversize/overweight regulations. All construction and operations personnel will park on the proposed site and will not block or hinder normal traffic on County Road 215. All activities on this site will be conducted out of the right-of-way of County Road 215 on the subject parcel, and all loading and unloading of vehicles will be conducted out of the public right-of-way. As discussed in the previous section, the construction of this facility will result in minor, temporary increases in traffic on County Road 215. As noted previously, this facility will ultimately result in a significant reduction in tanker truck traffic required to haul water to Encana's operations. Regardless of the traffic volume, Encana will implement the following measures, as necessary, to minimize impacts to transportation and roads: Control dust along unsurfaced access roads and minimize tracking of soil onto paved roads, as required by the CDPHE Construction Stormwater Permit and as per the details contained in the Dust Control Plan. Comply with county and state weight restrictions and limitations. Limit construction and operation traffic speeds to a low and reasonable level. Keep dusty, exposed areas damp with water or a magnesium -chloride solution or other dust suppressant. Project Narrative Page 4 Stabilize traffic areas with gravel. Revegetate or stabilize non -traffic areas as soon as practicable. The proposed water storage facilities will comply with all of Encana's safety practices including emergency response procedures. A copy of Encana's Emergency Response Plan, which includes emergency contact numbers, is provided in the Supplemental Material Section. If required, electricity will be supplied on-site by either a new utility connect to Xcel Energy or by diesel or natural gas generator(s). If generators are used on site, they will comply with with appropriate Colorado air emissions permitting regulation as applicable. Any fuel storage tanks located on-site for operation of the generator(s) will be included in the area wide Spill Prevention Control and Countermeasures (SPCC) plan. A Storm Water Management Plan (SWMP), detailing the use of site-specific BMPs, has been prepared for this area and copies of construction permit issued by the Colorado Department of Public Health and Environment (CDPHE) are provided in the supplemental material section. Further, the SWMP is being updated to reflect changes to Encana's storm water plan. All updates to the SWMP will be completed prior to initiating any construction activity. Implementation of the SWMP and the appropriate BMPs will ensure that activities conducted at the site comply with storm water management regulations as required by Garfield County, the State of Colorado, and the United States Environmental Protection Agency. Implementation of this plan also ensures that installation and operation of this facility will not impact surface runoff, stream flow, or groundwater. Site specific BMPs implemented to accommodate erosion control will include (but not be limited to) the following: straw bales, silt fencing, straw wattles, check dams and berms. A complete Drainage Plan that addresses potential on -flows and off -flows has been prepared for this project and accompanies this submittal. This plan is also a component of the COGCC permitting review/approval. The plan will be engineered to accommodate typical storm water construction activities and also accommodate a 100 year, 24 hour storm water event. No flammable or explosive solids or gases will be stored on site. Drawings detailing the locations of wells that will (potentially) be contributing water to the proposed impoundments are attached. These drawings demonstrate that the wells are located within the non -tributary designation of the Williams Fork formation as per data available from the Colorado Division of Water Resources (CDWR). Leak detection and water level detection alarm systems will be installed on all impoundments in order to prevent an accidental release of fluids. As required by COGCC rules, all spill and releases from this facility will be reported to the COGCC in accordance with Rule 906. In the event that a reportable spill or release does occur, Encana will notify all agencies as required by the COGCC. Project Narrative Page 5 A Noxious Weed Management Plan is included in the Supplemental Materials Section. In addition to the measures that are outlined in this plan, Encana will implement other measures to prevent infestation of noxious weeds. These measures include seeding cut and fill slopes around the facility to re-establish native vegetation. The potential impacts to wildlife from this facility are anticipated to be negligible as discussed in the Wildlife Assessment and Mitigation Report provided as part of this application. The Wildlife Assessment and Mitigation also discusses several mitigation measures that could be employed to further minimize wildlife impacts. The facility design will also ensure that the environment is protected at all times through engineered controls and equipment. Possible impacts to wildlife from this facility are associated with collisions with the traffic into and out of the facility. Additional details are provided in this application's Land Suitability Analysis (LSA) and Impact Analysis (IA) section(s). The remote location of this facility and the type of operations that will occur should eliminate many of the other impacts required to be addressed in this application. No smoke, vibration, heat, radiation or fumes will be produced as a result of the operation of this facility. In order to minimize potential air quality impacts the impoundments will be covered with an impervious synthetic liner. Any potential air quality impacts from the produced water impoundments will be evaluated and the appropriate notices and/or permits will be filed with the CDPHE as required. A CDPHE air permit will be obtained for the facility. Lighting will only be required during pumping operations and unscheduled nighttime maintenance and all lights on the property will be downcast and screened to prevent direct impacts to any adjacent property. The facility will be operated in compliance with the noise standards set forth in the Colorado Revised Statutes. Adjacent property will not be affected and a public nuisance or hazard will not be created. It is not anticipated that operation of the pumps at the facility will create a nuisance since they will be located inside of a building. Adjacent property will not be affected and a public nuisance or hazard will not be created. Solid waste refuse generated during the construction and operational activities will be stored in wildlife proof containers provided by a licensed refuse hauler. Encana will use a refuse hauling service to empty the refuse receptacle. Receptacles will be emptied as needed and disposed of at the Garfield County Landfill or other permitted facility. Encana's refuse hauler will maintain all records including, but not limited to, trip logs/reports and landfill receipts, and all records will be available to the County upon request. The facility will be operated for the life of the gas wells in the area. This is currently estimated to be 20 years or more. At the end of the economic life of wells in the area, the site will be reclaimed by removing all surface facilities, grading to restore original contours, replacing topsoil, and revegetating the reclaimed area as outlined in the reclamation plans included in the Impact Analysis. Project Narrative Page 6 If deemed necessary by the County Commissioners, Encana will provide financial assurance for the purpose of ensuring the proper reclamation and closure of the facility. The entire proposed area of disturbance will be reviewed and approved by the COGCC prior to construction and operation. A site visit has been conducted with the COGCC and Colorado Parks and Wildlife (CPW). Their inputs have been factored into engineering design and wildlife protections of the facility. Project Narrative Page 7