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Home My WebLink About4.0 CorrespondenceFrom: Arfmann, Dennis To: Kathy A. Eastley; cc: Jerry Alberts; Subject: FW: Antero Hunter Mesa Pre -Construction and Construction Date: Friday, January 14, 2011 8:54:51 AM Kathy Here is the air division email. Please call either me or Jenn Biever with any questions to resolve this. Thanks Dennis Dennis Arfmann Partner Hogan Lovells US LLP 1470 Walnut Street, Suite 200 Boulder, CO 80302 Tel: +1 720 406 5300 Direct: +1 720 406 5374 Fax: +1 720 406 5301 Email: dennis.arfmann@hoganlovells.com www.hoganlovells.com Please consider the environment before printing this e-mail. From: McMillan, Mark [mailto:Mark.McMillan@dphe.state.co.us] Sent: Tuesday, January 11, 2011 4:06 PM To: Arfmann, Dennis Cc: McMillan, Mark Subject: Antero Hunter Mesa Pre -Construction and Construction Dennis — I hope this email finds you well. I understand your client, Antero Resources, is requesting some flexibility with the construction of their Hunter Mesa facility, before the permit comes out of the .public comment process. The Division is herby using our enforcement discretion with Antero Resources so that this operator may begin with the pre -construction and construction activities at Hunter Mesa prior to the completion of the public comment process, as you identified in your January 4, 2011 email to Kirsten King (copied below). Please note that since this permitting action is not quite final, Antero accepts full liability for such construction activities. Obviously, the Division is not in a position to speak to the Garfield County processes. That is a matter between Antero and the County. I recommend that you and/ or Antero Resources keep a copy of this communication on file. If you have any questions or comments, please feel free to contact me directly. Regards, Mark Mark McMillan, M.S. Supervisor, Oil and Gas Team Air Pollution Control Division Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, B-1 Denver, CO 80246-1530 303-692-3140 mark.mcmillan@state.co.us Kirsten: As we discussed, this email is to attempt to document the agreement between the Division and Antero Resource allowing Antero to begin construction activities related to the Hunter Mesa Compressor Station. Pre -Construction & Construction Activities Pre -construction activities will include., but not be limited to, dirt work, the excavation Content blocked by your organization of top soil, the preparation of the site and footings, and receipt of equipment and materials on-site. Antero crews and contractors will: 1 Initiate the preparation and forming of Compressor Unit pads on-site; 2 Initiate the preparation and forming of Dehy Unit pads on-site; 3 Initiate the preparation and forming of Separator and Scrubber pads on-site; 4. Third party transport of major equipment and bulk material directly to the site; 5. Perform pre -fabrication activities on-site. Currently we plan to pre -fabricate the bulk of the piping components off-site and truck this to the site. 6. Setting of screw piling for the pipe rack and the pouring of equipment pads on- site. Currently, the plan is to initiate actual construction activities on January 17 with approval of the Garfield County Land Use Permit. Since the minor source air permit was noticed for public comment on December 30, 2010, Antero is hopeful the Division will issue the initial approval permit by the end of January, 2011. Antero understands that the Division will allow these construction activities at risk without the issuance of the initial approval permit, under the Divisions' enforcement discretion authority. Please confirm if this is also your understanding. Best regards, Dennis Dennis Arfmann I'artnei Hogan Lovells US LLP 1470 Walnut Street, Suite 200 Boulder, CO 80302 Tel: +1 720 406 5300 Direct: +1 720 406 5374 advertisement Fax: +1 720 406 5301 Email: dennis.arfmann@hoganlovelis.com www.hoganlovells.com Please consider the environment before printing this e-mail. Hogan Lovells refers to the international legal practice comprising Hogan Lovells International LLP, Hogan Lovells US LLP, Hogan Lovells Worldwide Group (a Swiss Verein), and their affiliated businesses. Hogan Lovells International LLP is a limited liability partnership registered in England and Wales with registered number 0C323639. Registered office and principal place of business: Atlantic House, Holborn Viaduct, London EC1A 2FG. Hogan Lovells US LLP is a limited liability partnership registered in the District of Columbia. The word "partner" is used to refer to a member of Hogan Lovells International LLP or a partner of Hogan Lovells US LLP, or an employee or consultant with equivalent standing and qualifications, and to a partner, member, employee or consultant in any of their affiliated businesses who has equivalent standing. A list of the members of Hogan Lovells International LLP and of the non-members who are designated as partners, and of their respective professional qualifications, is open to inspection at the above address. Further important information about Hogan Lovells can be found on www.hoganlovells. CONFIDENTIALITY. This email and any attachments are confidential, except where the email states it can be disclosed; it may also be privileged. If received in error, please do riot disclose the contents to anyone, but notify the sender by return email and delete this email (and any attachments) from your system. From: To: cc: Subject: Date: Kathy, Kevin Whelan "Kevin Whelan"; Kathy A. Eastlev; "Jason Clark" Phil@pvcmi.com; RE: LIPA 6627 Hunter Mesa Compressor Station Thursday, February 03, 2011 12:17:18 PM All items and comments from the below e-mail have been adequately addressed and the fire district recommends approval. Any questions , please let me know! "The Mission of the Rifle Fire Protection District is to Enhance Health and Safety and to Protect the Life , Home and Property of the People We Serve" Kevin C. Whelan Division Chief/ Fire Marshal Rifle Fire Protection District 1850 Railroad Ave. Rifle, CO 81650 kewhelanAriflefiredept. org Office- 970-625-1243 ext .12 Fax- 970-625-2963 From: Kevin Whelan[mailto:kewhelan@riflefiredept.org] Sent: Friday, December 24, 2010 10:06 AM To: 'Kathy Eastley' Cc: 'Jason Clark' Subject: LIPA 6627 Hunter Mesa Compressor Station Kathy, I have reviewed the Limited Impact -- Material Handling Application for the Hunter Mesa compressor Station (LIPA 6627) on County Road 333, Garfield County. The following are my comments: 1. Historically, Rifle Fire Protection District has not done a detailed review on compressor stations in our district. Federal, State, County, COGCC and industry rules & standards have been relied upon. We believe this has been appropriate and reasonable. We can assist in the following areas, if appropriate, by applying the International Fire Code: a. Water supply requirements for fire protection b. Fire apparatus access including turn -a rounds c. Plan review and installation inspections & testing for flammable gas sensors. EMD's, fire eyes, auto — ventilation, auto -shutdowns and the like. If these areas are already handled by another Authority Having Jurisdiction then no further action is needed 2. J. -Both the SPCC plan and the SWMP plan need the signatures of the engineer of record or company representative. 3. Rifle Fire has experienced some delays in gas industry delaying calling 911 immediately. The EAP Quick reference chart does a good job of making this a priority. We would suggest changes in the following areas: a. J. --SPCC plan: i. Section 7.2- change step # 7 to step # 2 ii. . Section 7.2 & 8.4 -Change all phones numbers for Rifle Fire to "dial 911 or 970-625-8095/ office number- 970 625-1243". Although we staff our stations 24/7, the response crews are not at the stations 24/7 and thus no one would answer 970- 625-1243. iii. Attachment H-1- IA - Add "dial 911 or call 970-625-8095" iv. H-1- IV - Add fire district(s) to government contacts b. J. Emergency Action Plan i. Pg 1- Change non -emergency number to 970-625-8095/ office number- 970 625-1243 ii. Section IV —pg 3- 1st appropriate action is "dial 911" in 1. l st sentence 2. bulleted item number 3 iii. section VI remove the "or" in "and / or contact 911" iv. Quick Reference- change fire non emergency phone number to "970-625-8095 or office number - 970 625-1243" 4. J- SPCC section 8.4- change heading that says Grand Valley to just Fire Protection District since Grand Valley FPD covers the Parachute Area. If appropriate add Burning Mountains FPD which covers the Silt /New Castle areas. 5. J. Emergency Action Plan- section IV- last line change "All fires, even those that have been extinguished, must be reported" to "All fires, even those that have been extinguished, must be reported the fire department". This is in line with state statue. 6. Attached are our haz mat declaration forms that need to be filled out and returned to us at Antero's earliest convenience but no later than when the plant is operational. This is for our response crews 7. Two areas that we are working with other gas companies are: a. What quantities of a spill require a fire district response? An example would be in the SPCC plan -section 7.2 -step 9 where it states "a minor amount of oil". The fire district recognizes there are the federal and state reportable quantities. b. Is production water a hazardous material? The fire district recognizes that the exact makeup can vary greatly. Our current policy is to treat all production water as hazardous. "The Mission of the Rifle Fire Protection District is to Enhance Health and Safety and to Protect the Life , Home and Property of the People We Serve" Kevin C. Whelan Division Chief/ Fire Marshal Rifle Fire Protection District 1850 Railroad Ave. Rifle, CO 81650 kewhelan(a7riflefiredept.org Office- 970-625-1243 ext .12 Fax- 970-625-2963 Cell- 970-618-7388 December 17, 2010 Ms. Kathy Eastley Garfield County Planning 108 81h Street, Suite 401 Glenwood Springs, CO 81601 MOUNTAIN CROSS ENGINEERING, INC. CIVIL AND ENVIRONMENTAL CONSULTING AND DESIGN RE: Hunter Mesa Compressor Station Limited Impact Application: LIPA 6627 Dear Kathy: This office has performed a review of the documents provided for the Hunter Mesa Compressor Station Limited Impact Application by B.J.M. Ltd. The submittal was found to be thorough and well organized. The following questions, concerns, or comments were generated: I. The submittal materials do not discuss how many people will regularly be at the site and for how long. This will be necessary to determine if the proposal of providing only portable toilets and no potable water is reasonable. 2. The proposed snow storage areas conflict with the truck turning movements shown on the "Grading and Drainage" plan. 3. The proposed drainage and slope between the proposed compressor buildings is very flat (0.5%). This slope will be difficult to construct and maintain as a gravel surface and does not likely match the drainage recommendations of the Geotechnical engineer. Feel free to call if you have any questions or comments. Sincerely, Mountin Cross Engine :+ ing Inc. is Hale, PE 826 1/2 Grand Avenue • Glenwood Springs, CO 81601 PH: 970.945.5544 • FAX: 970.945.5558 • www.mountaincross-eng.com