HomeMy WebLinkAbout20120024.tiff STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
WELD COUNTY COLORADO
1313 Sherman St,Room 215 COMMISSIONERS DIVISION OF
Denver,Colorado 80203 RECLAMATION
Phone: (303)866-3567 - MINING
FAX:(303)832-8106 1(X1 DEC 30 P 2 43 -&—
SAFETY
November 17, 2011 RECEIVED John Hickenlooper
Governor
Jennifer Magee Mike King
District Staff Assistant Executive Director
Basic Energy Services, L.P. Loretta Pineda
Director
907 Poplar, Ste. 210
Casper, Wyoming 82601
Re: Basic Energy Services, L.P., File No. M-2011-022
Peters Ranch Pit, 110c Permit Application Second Adequacy Review
Dear Ms. Magee:
The Division of Reclamation, Mining and Safety (Division) has reviewed the content of Basic
Energy Services, L.P. 110c adequacy response for the Peters Ranch Pit, File No. M-2011-022,
and submits the following comments. The Division is required to make an approval or denial
decision no later than December 1, 2011 therefore; a response to the following adequacy
review concerns should be submitted to the Division as soon as possible.
1. As required by Rule 1.6.2 (e), please submit proof of the notice to all owners of record of
surface and mineral rights of the affected land and the owners of record of all land surface
within 200 feet of the boundary of the affected land including all easement holders located
on the affected land and within 200 feet of the boundary of the affected land. Proof of
notice may be return receipts of a Certified Mailing or by proof of personal service.
On November 14, 2011 the Applicant submitted return receipts of a Certified Mailing for
Kinder Morgan, Inc. and John L. (and Sharon) Peters.
a. Kinder Morgan, Inc. is not identified as an owner of record on Exhibit A— ✓
Location Map. Please explain this discrepancy and revise the Location Map as
needed.
b. The Division did not receive proof of notice to Peters 313 Ranch Inc. Please
provide evidence of notice in accordance with Rule 1.6.2(e). If the Applicant
failed to notify the adjacent landowner, they must mail a copy of the notice
provided for in Rule 1.6.2(1)(d)to the adjacent landowner and allow 20 days
from the letter date for comments.
Alternatively,the Applicant may provide a signed and notarized statement from
the Registered Agent for Peters 313 Ranch Inc. stating they are aware of the
R tom R, proposed mining activity and have no objections to the activity.
I -`1 -1), C C- . V11_ 2 F try 2012-0024
Office of 1- jr}- i i vmce or
Mined Land Reclamation Denver•Grand Junction•Durango Active and Inactive Mines
Page 2 of 3
The address and registered agent for Peters 313 Ranch Inc. listed with the
Colorado Secretary of State are:
Peters 313 Ranch Inc.
William C. Anderson
431 Sherman Street
Fort Morgan, Colorado 80701
2. The Applicant did not respond to question #3 from the Division's adequacy letter dated
September 21, 2011.
The Division received comments from the Colorado Division of Water Resources and the
Army Corps of Engineers. The letters are attached for your review. Please address the
comments noted in the letters and make any changes in the application as necessary.
Please acknowledge receipt of the letters and commit to complying with the comments
noted in the letters.
Exhibit C- Mining Plan (Rule 6.3.3)
3. Please provide a seed mixture for vegetating topsoil and overburden stockpiles or commit
to using the reclamation seed mixture in the Reclamation Plan.
Exhibit E- Map (Rule 6.3.5)
4. The Applicant did not respond to a portion of question #7 from the Division's adequacy letter
dated September 21, 2011. Please respond to the question below and revise all applicable
maps, if required.
The Applicant has indicated no significant, valuable and permanent man-made
structures are located within two hundred(200)feet of the affected land. Please confirm
no structures, including but not limited to fences are not located within 200 feet of the
affected land which includes the access road and mine site.
Exhibit I - Proof of Filing with County Clerk(6.3.9(
5. The return receipt included in the Applicant's adequacy response was not dated. Please
provide evidence of the date on which the revised application information was submitted
with the Weld County Clerk.
6. Please provide an affidavit or receipt indicating the date on which the revised application
information indicated above was placed with the local County Clerk and Recorder for public
review, pursuant to Subparagraph 1.6.2(1)(c).
Page 3 of 3
Please be advised the Peters Ranch Pit application may be deemed inadequate, and the
application may be denied on December 1, 2011 unless the above mentioned adequacy review
items are addressed to the satisfaction of the Division. If you feel more time is needed to
complete your reply, the Division can grant an extension to the decision date. This will be done
upon receipt of a written waiver of your right to a decision by December 1, 2011 and request
for additional time. This must be received no later than the deadline date.
If you have any questions, please do not hesitate to call me at 303-866-3567 Ext. 8124.7Sincerely
is
Peter S. Hays
Environmental Protection Specialist
Cc: Tom Kaldenbach; DRMS
O col Pc
P
District Office
Rocky Mounts=Region
90-N.Foplu,Suite 210
Carmel.WV 82601
Telephone:30"-266-9280
Fan 30'-23"-5843
December 21,2011
Peter S. Hays
Environmental Protection Specialist
State of Colorado—Department of Natural Resources
1313 Sherman St., Room 215
Denver, CO 80203
Re: Peters Ranch Pit, 110c Permit Application, File No. M-2011-022
Dear Mr. Hays:
This letter is in response to The Division of Reclamation, Mining and Safety's review of Basic Energy Services, L.P., 110x
Permit Application.
1. Please find the enclosed map indicating the pipelines under the proposed access road are property of Kinder
Morgan, Inc. Also enclosed is a letter from Kinder Morgan, Inc. stating they have no objections to the proposed
gravel pit and their requirements concerning the pipelines under the access road. BASiC Energy Services, L.P.will
comply with all requirements from Kinder Morgan concerning the access road.
Also enclosed is a notarized statement from John& Sharon Peters,owners of Peters 313 Ranch stating they are
aware of the mining activity and have no objections.
2. BASiC Energy Services, L.P. has received and reviewed letter from the following agencies:
a. Colorado Division of Water Resources-BASiC Energy Services, L.P. does not anticipate exposing
groundwater during or after mining operations. Water to be used for dust control will be obtained from an
outside source,trucked to the site and will be documented that the water was obtained from a legal source.
BASiC Energy Services, L.P.will comply with Colorado Division of Water Resources conditions for
approval and will obtain any required permits concerning storm water runoff.
b. Army Corps of Engineers-BASiC Energy Services, L.P.will comply with the Department of Army Cops
of Engineers in regard to the discharge of dredged or fill material and excavation of dredged or fill material.
3. BASiC Energy Services,L.P.commits to using the reclamation seed mixture in the Reclamation Plan
4. BASiC Energy Services, L.P. confirms no structures, including but no limited to fences are not location with in 200
feet of the affected land which includes the access road and mine site.
If you need any additional information concerning this application,please do not hesitate to contact me directly at(307)266-
9280.
Thank You,
&JlniLti
J nifer Magee
Staff Assistant- BASiC Energy Services, L.P.
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We, John Peters and Sharon Peters are the owners of Peters 313 Ranch, Inc. and are
aware of the proposed mining activity and no objections to this activity.
/j.. )
Jo eters Sharon Peters
P
Date Date
The oregoin instrument was acknowledged before me on this d , day of
y 2011.
. L) ,Q
Notary Public
4)';t;V N!FP NOTARY PUBLIC
S"ATE Or
Name Printed „ u SNARCH Y1
My Commission Expires: 3/2 I/)u
KINDER MORGAN
ENERGY PARTNERS,L.P.
December 21, 2011
Ms. Jennifer Magee
Basic Energy Services, L.P.
333 North Main
P.O. Box 37
LaBarge, WY 83123
RE: Basic Energy Services Request for a Construction Materials Reclamation Permit, Weld
County, CO
Kinder Morgan Energy Partners LP (KMEP) Encroachment Number 2011.136
Dear Ms. Magee:
KMEP operates three high pressure, cathodically protected, natural gas pipelines in Section 26,
Township 12 North, Range 63 West,Weld County, CO. The three pipelines are 16, 36 and 42
inches in diameter.
KMEP has reviewed the plans for the construction materials pit proposed by Basic Energy
Services (Basic) in the above referenced section. It appears that the pit itself should have no
impact on the pipelines. While it does not appear that the pit will have a direct impact on any of
the three pipelines;the access haul road appears to cross over all three of the pipelines.
The design details are limited with respect to the road and the pipelines. KMEP will require
additional information on the profile and cross sections of the haul road where it is passing over
the pipelines to determine its impact to the pipelines. KMEP will also need to know the equipment
that will be used to build the road, use the road and reclaim the road prior to finishing the
evaluation of the impact of the road.
Please find enclosed two Kinder Morgan documents with respect to design and construction
considerations for particularly the road and indirectly the pit. They are Operating and Maintenance
Procedure 204, "Construction near Company Facilities"and OM200-209, "Design and
Construction near Kinder Morgan Operated Facilities". If you have any additional questions about
the pipelines or the enclosed documents, please call the number below.
December 21, 2011
Page Two
RE: Basic Energy Services Request for a Construction Materials Reclamation Permit, Weld
County, CO
Kinder Morgan Energy Partners LP (KMEP) Encroachment Number 2011.136
Very truly yours,
Gregory E. Smith, P.E.
Project Manager—Encroachments
Kinder Morgan Energy Partners L.P.
370 Van Gordon Street
Lakewood, CO 80228
O:303-914-7848
Enclosures: Kinder Morgan Operating and Maintenance Procedure 204, Construction near
Company Facilities
Kinder Morgan Energy Partners LP OM 200-29, Design and Construction near
Kinder Morgan Operated Facilities.
CC: Kevin Dahncke (Houston, TX)
Arlyn Davison (Wray, CO)
Ed Hlopak (Lakewood, CO)
Blaine Johnson (Wray, CO)
Gene Thim (Sterling, CO)
KINDER,MORGAN
Guidelines for Design and Construction near
Kinder Morgan Operated Facilities
Name of Company: Kinder Morgan Energy Partners, LP (KMEP)
The list of design, construction and contractor requirements, including but not limited to the following, for the design and
installation of foreign utilities or improvements on KM right-of-way (ROW) are not intended nor do they waive or modify any
rights KM may have under existing easements or ROW agreements. Reference existing easements and amendments for
additional requirements. This list of requirements is applicable for KM facilities on easements only. Encroachments on fee
property should be referred to the ROW Department.
Design
• KM shall be provided sufficient prior notice of planned activities involving excavation, blasting, or any type of construction
on KM's ROW to determine and resolve any location, grade or encroachment problems and provide protection of our
facilities and the public before the actual work is to take place.
• Encroaching entity shall provide KM with a set of drawings for review and a set of final construction drawings showing all
aspects of the proposed facilities in the vicinity of KM's ROW. The encroaching entity shall also provide a set of as-built
drawings showing the proposed facilities in the vicinity of KM's ROW.
• Only facilities shown on drawings reviewed by KMEP (Company) will be approved for installation on KM's ROW. All
drawing revisions that effect facilities proposed to be placed on KM's ROW must be approved by KM in writing.
• KM shall approve the design of all permanent road crossings.
• Encroaching entity shall, at the discretion of the Kinder Morgan, Inc., incorporate Heath ATI"sniffer"Gas Detection Units in
the design of paved areas or"Green Belt" areas of KM ROW. The units shall be installed per KM Standard TYP-V-0100-
B010.
• Any repair to surface facilities following future pipeline maintenance or repair work by KM will be at the expense of the
developer or landowner.
• The depth of cover over the KM pipelines shall not be reduced nor drainage altered without KM's written approval.
• Construction of any permanent structure, building(s) or obstructions within KM pipeline easement is not permitted.
• Planting of shrubs and trees is not permitted on KM pipeline easement.
• Irrigation equipment i.e. backflow prevent devices, meters,valves,valve boxes, etc. shall not be located on KM easement.
• Foreign line, gas, water, electric and sewer lines, etc., may cross perpendicular to KM's pipeline within the ROW, provided
that a minimum of two (2) feet of vertical clearance is maintained between KM pipeline(s) and the foreign pipeline.
Constant line elevations must be maintained across KM's entire ROW width, gravity drain lines are the only exception.
Foreign line crossings below the KM pipeline must be evaluated by KM to ensure that a significant length of the KM line is
not exposed and unsupported during construction. When installing underground utilities, the last line should be placed
beneath all existing lines unless it is impractical or unreasonable to do so. Foreign line crossings above the KM pipeline
with less than 2 feet of clearance must be evaluated by KM to ensure that additional support is not necessary to prevent
settling on top of the KM natural gas pipeline.
• A foreign pipeline shall cross KM facilities at as near a ninety-degree angle as possible. A foreign pipeline shall not run
parallel to KM pipeline within KM easement without written permission of KM.
• The foreign utility should be advised that KM maintains cathodic protection on their pipelines. The foreign utility must
coordinate their cathodic protection system with KM's. At the request of KM, foreign utilities shall install (or allow to be
installed) cathodic protection test leads at all crossings for the purposes of monitoring cathodic protection. The KM
Cathodic Protection (CP) technician and the foreign utility CP technician shall perform post construction CP interference
testing. Interference issues shall be resolved by mutual agreement between foreign utility and KM. All costs associated
with the correction of cathodic protection problems on KM pipeline as a result of the foreign utility crossing shall be borne
by the foreign utility for a period of one year from date the foreign utility is put in service.
Reference: O&M Procedure 204 Page 1 of 3 OM200-29
09/08
KINDER,f MORGAN
Guidelines for Design and Construction near
Kinder Morgan Operated Facilities
• The metallic foreign line shall be coated with a suitable pipe coating for a distance of at least 10 feet on either side of the
crossing unless otherwise requested by the KM CP Technician.
• AC Electrical lines must be installed in conduit and properly insulated.
• DOT approved pipeline markers shall be installed so as to indicate the route of the foreign pipeline across the KM ROW.
• No power poles, light standards,etc.shall be installed on KM easement.
Construction
• Contractors shall be advised of KM's requirements and be contractually obligated to comply.
• The continued integrity of KM's pipelines and the safety of all individuals in the area of proposed work near KM's facilities
are of the utmost importance. Therefore,contractor must meet with KM representatives prior to construction to provide and
receive notification listings for appropriate area operations and emergency personnel. KM's on-site representative will
require discontinuation of any work that, in his opinion,endangers the operations or safety of personnel, pipelines
or facilities.
• The Contractor must expose all KM transmission and distribution lines prior to crossing to determine the exact alignment
and depth of the lines. A KM representative must be present. In the event of parallel lines, only one pipeline can be
exposed at a time.
• KM will not allow pipelines to remain exposed overnight without consent of KM designated representative. Contractor may
be required to backfill pipelines at the end of each day.
• A KM representative shall do all line locating. A KM representative shall be present for hydraulic excavation. The use of
probing rods for pipeline locating shall be performed by KM representatives only, to prevent unnecessary damage to the
pipeline coating.
• Notification shall be given to KM at least 72 hours before start of construction. A schedule of activities for the duration of
the project must be made available at that time to facilitate the scheduling of Kinder Morgan, Inc.'s work site
representative. Any Contractor schedule changes shall be provided to Kinder Morgan, Inc. immediately.
• Heavy equipment will not be allowed to operate directly over KM pipelines or in KM ROW unless written approval is
obtained from KMEP (Company). Heavy equipment shall only be allowed to cross KM pipelines at locations designated by
Kinder Morgan, Inc. Contractor shall comply with all precautionary measures required by KM to protect its pipelines.
When inclement weather exists, provisions must be made to compensate for soil displacement due to subsidence of tires.
• Excavating or grading which might result in erosion or which could render the KM ROW inaccessible shall not be permitted
unless the contractor/developer/owner agrees to restore the area to its original condition and provide protection to KM's
facility.
• A KM representative shall be on-site to monitor any construction activities within twenty-five (25) feet of a KM pipeline or
aboveground appurtenance. The contractor shall not work within this distance without a KM representative being on site.
Only hand excavation shall be permitted within a minimum of 18 inches (refer to state specific rules/regulations regarding
any additional clearance requirements) of KM pipelines, valves and fittings. However, proceed with extreme caution when
within three (3)feet of the pipe.
• Ripping is only allowed when the position of the pipe is known and not within ten (10) feet of KM facility unless company
representative is present. .
• Temporary support of any exposed KM pipeline by Contractor may be necessary if required by KM's on-site representative.
Backfill below the exposed lines and 12" above the lines shall be replaced with sand or other selected material as
approved by KM's on-site representative and thoroughly compacted in 12" lifts to 95% of standard proctor dry density
minimum or as approved by KM's on-site representative. This is to adequately protect against stresses that may be
caused by the settling of the pipeline.
• No blasting shall be allowed within 1000 feet of KM's facilities unless blasting notification is given to KM including complete
Blasting Plan Data. A pre-blast meeting shall be conducted by the organization responsible for blasting.
Reference: O&M Procedure 204 Page 2 of 3 OM200-29
09/08
KINDERpMORGAN
Guidelines for Design and Construction near
Kinder Morgan Operated Facilities
KM shall be indemnified and held harmless from any loss, cost of liability for personal injuries received, death caused or
property damage suffered or sustained by any person resulting from any blasting operations undertaken within 500 feet of
its facilities. The organization responsible for blasting shall be liable for any and all damages caused to KM's facilities as a
result of their activities whether or not KM representatives are present. KM shall have a signed and executed Blasting
Indemnification Agreement before authorized permission to blast can be given.
No blasting shall be allowed within 300 feet of KM's facilities unless blasting notification is given to KM a minimum of one
week before blasting. (note:covered above)KM shall review and analyze the blasting methods. A written blasting plan
shall be provided by the organization responsible for blasting and agreed to in writing by KM in addition to meeting
requirements for 500' and 1000' being met above. A written emergency plan shall be provided by the organization
responsible for blasting. (note:covered above)
• Any contact with any KM facility, pipeline, valve set, etc. shall be reported immediately to KM. If repairs to the pipe are
necessary,they will be made and inspected before the section is re-coated and the line is back-filled.
• KM personnel shall install all test leads on KM facilities.
• Burning of trash, brush,etc. is not permitted within the KM ROW.
Insurance Requirements
• All contractors, and their subcontractors, working on Company easements shall maintain the following types of insurance
policies and minimum limits of coverage. All insurance certificates carried by Contractor and Grantee shall include the
following statement: "Kinder Morgan and its affiliated or subsidiary companies are named as additional insured on all
above policies (except Worker's Compensation) and waiver of subrogation in favor of Kinder Morgan and its affiliated or
subsidiary companies, their respective directors, officers, agents and employees applies as required by written contract."
Contractor shall furnish Certificates of Insurance evidencing insurance coverage prior to commencement of work
and shall provide thirty(30)days notice prior to the termination or cancellation of any policy.
1. Statutory Coverage Workers' Compensation Insurance in accordance with the laws of the states where the work is to be
performed. If Contractor performs work on the adjacent on navigable waterways Contractor shall furnish a certificate of
insurance showing compliance with the provisions of the Federal Longshoreman's and Harbor Workers' Compensation
Law.
2. Employer's Liability Insurance, with limits of not less than $1,000,000 per occurrence and $1,000,000 disease each
employee.
3. Commercial General Liability Insurance with a combined single limit of not less than$2,000,000 per occurrence and in the
aggregate. All policies shall include coverage for blanket contractual liability assumed.
4. Comprehensive Automobile Liability Insurance with a combined single limit of not less than $1,000,000. If necessary,the
policy shall be endorsed to provide contractual liability coverage.
5. If necessary Comprehensive Aircraft Liability Insurance with combined bodily injury, including passengers, and property
damage liability single limits of not less than$5,000,000 each occurrence.
6. Contractor's Pollution Liability Insurance this coverage shall be maintained in force for the full period of this agreement with
available limits of not less then$2,000,000 per occurrence.
7. Pollution Legal Liability Insurance this coverage must be maintained in a minimum amount of$5,000,000 per occurrence.
Reference: O&M Procedure 204 Page 3 of 3 OM200-29
09/08
KINDERORGAN No. O&M 204/C1005
Title: Construction near Company
O&M PROCEDURE/CONSTRUCTION STANDARD Facilities
Dual Use Document Revised: 2011-11-10
Table of Contents
1. Applicability 1
2. Scope 1
3. Core Information and Requirements 1
3.1. Basic Rights 2
3.2. Basic Responsibilities 2
3.3. One-Call Systems 2
3.4. Marking Underground Structures 3
3.5. Surveillance, Awareness and Reporting 6
3.6. Investigating Third Party Construction Activity—Company Not Notified 6
3.7. Inspecting Construction Activity—KM Notified 7
3.8. Excavating Pressurized Lines 11
Table 1 —Tolerance Zones by State 12
Figure 1 — Minimum Tolerance Zone 12
3.9. Horizontal Distance 13
Table 2 - Horizontal Distance from Company Facilities 13
3.10. Vertical Facility Clearance 13
Table 3 - Vertical Clearance from Company Facility 14
3.11. Engineering Assessment 14
3.12. Heavy EquipmenUVehicle Crossings, Roadways and Parking Lots 15
3.13. Directional Drilling 15
3.14. Land Leveling or Improvement—Company Notified 16
3.15. Blasting and Seismic Activity 16
3.16. Buildings near Pipelines 17
4. Training 17
5. Documentation 17
5.1. Company Report Forms 17
5.2. Response to Third Party 17
5.3. Photographs 17
5.4. All Documentation 18
6. References 18
Attachment 1 —One-Call Center and Emergency Phone Numbers 19
1. Applicability
x❑ Gathering
Processing
x❑ Transmission/Regulated Onshore Gathering
❑ Kinder Morgan Treating
2. Scope
This procedure applies to all facilities and provides guidance in addressing all construction projects or
activities that encroach upon the Company's pipelines, fee owned property, easements, etc. Such
encroachments must be evaluated to assure compliance with Company requirements as those
requirements are prescribed in this procedure, prevent damage to the pipeline facilities and protect
the public and employees.
3. Core Information and Requirements
Third Party activities near pipeline facilities that may require inspection and or assessment including,
but are not limited to:
• Blasting
• Installing foreign pipelines
• Installing electric cables, telephone or cable TV lines
• Drilling holes for poles, posts, anchors or oil, water and gas wells
Highlighting indicates revisions made as of the date on this procedure Page 1 of 19
KINDERORGAN No. O&M 204/C1005
Title: Construction near Company
O&M PROCEDURE/CONSTRUCTION STANDARD Facilities
Dual Use Document Revised: 2011-11-10
• Installing parking lots, driveways, mobile homes, garages, sheds, swimming pools, barns,
junkyards or trees
• Any other activities that may require excavation
• Crossing pipelines with heavy vehicles or equipment
• Permanent or temporary removal of cover from pipelines (e.g., agricultural land leveling, road or
highway construction, drainage work)
3.1. Basic Rights
The Land and Right-of-Way Department enforces Company land rights insofar as or to the
extent provided by underlying agreements.
When a third party's activities threaten the safety of Company operated facilities, the Company
will request that the third party discontinue such action. If the third party fails to adhere to the
request, then assistance from operations management and the Land and Right-of-Way
Department shall be pursued. When a third party damages a pipeline or other Company
operated facility, the Company has the right to reimbursement for such damages.
The Company has certain basic land rights through easements, franchises, permits, license
agreements, leasehold, fee ownership, etc., that allow for constructing and operating Company
facilities. The value and extent of the Company's rights depend upon the underlying agreement's
terms and conditions.
The Company has the right to act in accordance with the terms and conditions of the underlying
agreement. In cases where the Company owns the property in fee, any encroachment on the
property is considered trespassing. The Company is prepared to take any legal action necessary
to protect its real and personal property rights and the safety and property of other persons.
3.2. Basic Responsibilities
The Company has the following basic responsibilities in relation to its pipelines:
• When Company pipelines are identified by pipeline markers, stakes or by telling a third party
where the line is located, such identifiers must be accurate and comply with the requirements
of state One-Call organizations and the Company's procedures whichever is more stringent.
• Managers and supervisors shall plan accordingly for workload fluctuations, vacations, etc. to
ensure notices received are completed in a timely manner.
• Section 4 of the Common Ground Alliance's (CGA) Locating and Marking best practices are
incorporated in this procedure and shall be followed.
3.3. One-Call Systems
Every location will participate in a state One-Call system. Attachment 1 — One-Call Center and
Emergency Phone Numbers lists the One-Call center phone numbers, as well as Company
control center phone numbers. The One-Call system serves as a means for receiving and
recording excavation notification as well as notifying excavators how to identify temporary
pipeline markings. In order to maintain the One-Call database; once each calendar year, each
Damage Prevention Supervisor shall review the current pipeline assets in their area of
responsibility and compare them with the lines in PODS or One-Call Agency database to ensure
that all lines the Company operates are listed and have not been sold or abandoned. Any
changes needed in pipeline location or one call boundaries will be coordinated through the GIS
Department.
Participating in the state One-Call program may meet the following damage prevention
requirements:
• If the State One-Call Center maintains a list of excavators who have used the One-Call
service, document in local files how to easily access this information when it is needed or
store the information in the Public Awareness Database.
Highlighting indicates revisions made as of the date on this procedure Page 2 of 19
KINDERMORGAN No. O&M 204/C1005
Title: Construction near Company
O&M PROCEDURE/CONSTRUCTION STANDARD Facilities
Dual Use Document Revised: 2011-11-10
• If the State One-Call Center provides notification to excavators explaining the One-Call
program and excavation procedures, obtain documentation for local files or store the
information in the Public Awareness Database.
3.3.1. Receiving Notices from One-Call Centers
When the field receives a One-Call notice of intended excavation, a response is required per
the procedures below and state One-Call Laws.
When the field receives a notice of intended activity, (One-Call) the person receiving the
information will determine as to the location of work versus the Company's assets. If
Company assets will not be impacted, document in the electronic One-Call system. The
documentation must include justification for no physical locate and the individuals name.
When the person receiving the one call determines there is a question as to whether
Company assets will be impacted, a Company representative will contact the excavator for
additional clarification. If at this time, it is determined that Company assets will not be
impacted, document in the electronic One-Call system. The documentation must include
justification for no physical locate, excavator contacted, and the individuals name.
If the pipeline will not be marked, the Petris One-Call System will be used to notify the
excavator via e-mail, fax or phone and/or respond back to the one-call center if required.
If the work is within 50-feet of Company assets, or if there is a potential for the work to
encroach to within 50-feet of Company assets, Company Personnel will physically mark the
asset according to Subsection 3.4 — Marking Underground Structures below, and document
in the electronic One-Call system. O&M Form OM200-31 -- Line Locate Inspection Report
shall be completed when meeting with the excavator.
3.3.2. Design or Planning Notification
When the one call notification is a request to meet for the purposes of design or planning, the
Company Representative is to contact the person designated on the one call ticket as the
contact person to ensure that no excavation is planned in the area noted on the one call
ticket and to schedule a meeting at a mutually agreeable time. If an excavation is planned,
which meets the definition of this procedure or the state one call law then Subsection 3.3.1 —
Receiving Notices from One-Call Centers applies. Also, refer to Subsection 3.4.3 — Meeting
Requirements with Excavator. O&M Form OM200-31 — Line Locate Inspection Report
shall be completed when meeting with the excavator and the line has been physically
marked.
3.4. Marking Underground Structures
Company personnel will locate and mark pipelines in areas where excavation activities are
observed or will occur as indicated by the One-Call notification. ONLY Company personnel are
approved to locate and mark underground structures.
Exception: Line marking may not be required for routine long-term activities where the depth of
cover is known, and it has been established that the activity will not, in any way, affect the
integrity of the pipeline. These include activities such as tilling of farmland, and road grading
operations. In these cases, a standing procedure may be established with the parties involved
that would apply as long as surface conditions and/or activities do not change. All other parts of
this procedure do apply.
3.4.1. Locate and mark the pipeline, within 50-feet of the excavation work area, as specified
below.
• Pipelines will be marked within 48 hours of receipt of notification (excluding weekends
and holidays) or in accordance with local One-Call laws, and before any excavation
activities begin. Emergency Notifications will be responded to promptly. It is recognized
that there will be circumstances that prohibit marking the pipeline within the allowed time.
Examples include, but are not limited to:
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o Weather (blizzards, heavy rain, or flooding)
o Locations that require marking in roadways where we will be utilizing the contractors
traffic control plan which will not be set up within the allowed time
o When the excavator is requesting a joint meet, which will occur after the allowed time
o Inability to gain access to property for locate (inaccessible fenced properties,
threatening pets, etc.)
o There is lack of clear delineation of the proposed area of excavation and the
excavator cannot meet with us within the allowed time.
If the state law allows it, in these cases delay in marking time is allowed; however,
concurrence of the delay in marking shall be received from the applicable ROW
Specialist, Supervisor or Manager and the excavator. Facts and circumstances of the
delay, name of Kinder Morgan (KM) person concurring and excavator contact who
agreed, shall be documented in the Comments section of Petris. Contact the excavator
and arrange to meet an authorized representative of the excavator. Discuss provisions in
Subsection 3.4.3 — Meeting Requirements with Excavator. Document excavator
communications in the One-Call system. O&M Form OM200-31 — Line Locate
Inspection Report shall be completed when meeting with the excavator.
• Locates and markings shall be performed safely. Consideration should be given to items
such as, but not limited to; traffic, site conditions, and personal protective equipment
(refer to O&M Procedure 120— Personal Protective Equipment).
• Available Company records/strip maps/alignment sheets are to be reviewed prior to
marking the pipeline(s). Look for taps, both active and abandoned, or any other below
grade facilities. The minimum length of pipeline to be marked shall be as required by
conditions of the site and job. Any errors or omissions discovered shall be communicated
to the Engineering Records Department immediately
• Perform a visual inspection of the locate area to determine if there is evidence of a
Company pipeline which is not on any record, map or alignment sheet. Also, be aware of
other pipelines that might be in the area that are not on Company drawings.
• When marking the line, the marks must be able to identify where the pipeline is located,
the lesser of within 2-feet off the center point, or as required by state One-Call Laws. If
this criterion is not possible, then no mark shall be made, but a positive "finding" (pothole)
will be necessary.
• Point of Intersection (PI) and other changes of direction shall be marked so that the
pipe's location is clearly delineated.
• When marking facilities, Company is to consider the type of facility being located, the
terrain of the land, the type of excavation being done and the method to adequately mark
its facility for the excavator. The spacing of the markings shall be 10-feet or less apart.
• Any crossings in the area must be marked.
• Any crossing, not shown on the alignment sheet must be reported immediately to the
Engineering Records Department for inclusion on as-built drawings.
• Temporarily mark the physical location of a pipeline using yellow flags, laths and/or
fluorescent yellow paint per the ULCC Color Code Guide. Use the appropriate marking
for the existing and expected surface conditions.
• When feasible, the owner/operator of a facility is identified by the markings at the time the
facility is located.
• Locate and mark any KM operated transmission or gathering facility within 50-feet of the
excavation work.
• Buoys, poles or PVC markers may be used for submerged underwater facilities in areas
such as wide commercially navigable waterways and bays. Markers should be placed as
close as practical over the facilities that are submerged in such a manner without
impeding or creating additional hazards.
• Multiple Company pipelines in the same ROW will be marked individually. Care should
be taken at all locations where there are multiple lines in the same ROW (either KM or
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third party). A sweep of the area should be performed to help identify the intended
pipeline as well as any other KM operated lines that may be in the vicinity.
• If there is doubt concerning the location or depth of the line, either request assistance to
locate or use soft digging methods to determine exact location.
• All marked locations shall be photographed in accordance with Section 5 —
Documentation.
• Treat each updated One-Call ticket as a "new" ticket. Pipeline markings need to be
verified or re-marked for each ticket AND new photographs taken. Remarks for each
ticket need to be completed in Petris. Descriptions and comments need to be completed
for each updated ticket, as if it were the only ticket received for the job. Reference to the
previous ticket should be noted in comments.
• All One-Calls must be responded to, via the electronic One-Call system, even if there is
no conflict with Company facilities.
Additional notification may be made by phone, fax, or email. The date and name of the
person contacted should be recorded in the electronic One-Call System.
3.4.2. Line Locating Equipment used in Locating Pipelines for Marking
Conductive locating (direct connection to the pipeline) is the preferred method for locating
Company pipelines.
Line locating equipment will be field checked for proper operation prior to initial use, each day
that it is used for locating. Documentation of this check will be recorded in the electronic
One-Call system. If Inductive locating is used for locating Company pipelines, a direct
positive confirmation by a water probe, probe rod, vacuum truck or other methods must be
performed.
3.4.3. Meeting Requirements with Excavator
• Meet with the encroaching party's representative. Obtain the information needed by the
Company concerning the type of activity, crossing, drawings, schedules, blasting plans
including charge size and location (if applicable), contact information (names, numbers),
etc. Use this opportunity to obtain contractor information for Company's damage
prevention program and to promote the use of the applicable state One-Call systems and
the national 811 number.
• Review with the excavator/encroaching party's supervisor or designated responsible
person the requirements of this procedure (O&M Procedure 204 — Construction Near
Company Facilities) such as scope of the job; location of Company facilities; the
requirements for crossing Company lines or facilities; and the requirements that a
Company Representative must be on-site whenever work will be done within 25-feet of
Company Facilities.
o Required clearance from any underground structure not associated with the pipeline
is 24-inches
o Company pipelines must be exposed per Subsection 3.8 — Excavating Pressurized
Lines of this procedure.
• Excavations entered by and performed by Company employees or their representatives
must meet the requirements of O&M Procedure 109 — Excavating, Trenching and
Shoring
• Special provisions are required when working over or near Dresser coupled lines. These
provisions are outlined in O&M Procedure 237—Dresser-Coupled Pipelines
• Verify that the information received concerning dates, locations and scope of work is
accurate
• The Company representative assigned to locate a pipeline or monitor excavation
activities shall complete O&M Form OM200-31 — Line Locate Inspection Report and
sign when meeting with the excavator and the line has been physically marked.
• For excavations 25-feet or less from Company assets, contractor should counter sign
O&M Form OM200-31 — Line Locate Inspection Report. The original will be given to
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the third party excavator's representative on the site during the initial meeting and a copy
electronically attached to the ticket in the One-Call system.
• For excavations greater than 25-feet, contractor is not required to counter sign O&M
Form OM200-31 — Line Locate Inspection Report. Retain the document for district
records
• The form must be re-issued for changes in activities, including, but not limited to:
o Changes in the scope of work that could affect the safety of the line
o Changes of affected personnel on the site (excavator, supervisor, etc.)
o Changes to the schedule/work plan, that is, digging faster or moving to another area
e.g., across the road.
O&M Form OM200-31 — Line Locate Inspection Report helps assure communications
between the Company representative and the third party excavator regarding the planned or
actual date(s) of excavation activities. If applicable, the form should include any observation
waivers granted and the basis on which the exception was granted, with instructions to
contact the KM Employee if any of the conditions, which was the basis for exception, change.
O&M Form OM200-31 — Line Locate Inspection Report shall be completed when meeting
with the excavator. If the excavator refuses to sign, the Company representative will so
indicate on the form.
3.5. Surveillance, Awareness and Reporting
Be alert for upcoming projects that may encroach upon or endanger Company operated pipelines
or facilities. Construction activity that may involve Company operated pipelines or facilities
should be immediately reported to the appropriate supervisor. If the appropriate supervisor
cannot be reached, notify the next available supervisor or Gas Control.
The public is often aware of projects, including underground phone, electrical, sewer and water
facilities and street construction projects long before work begins. Since rural road construction
and land leveling are less publicized, inform area contractors and road crews of Company line
locations and the rules regarding construction activity.
Notify Operations Manager or designee of any construction projects that may affect or endanger
Company operated facilities. Report any activities on fee owned property to ROW. When
construction work is within city or corporate limits or part of a city project, contact city officials and
remind them of the Company's rules and policies. Try to attend any city or county planning
committee meetings concerning major construction activities that could affect the Company's
assets. The necessary provisions can then be written into an ordinance or into the contract under
which the work will be performed.
3.6. Investigating Third Party Construction Activity—Company Not Notified
If a Third Party is seen within 50-feet of, or working over the Company's pipeline, the excavation
and construction activities shall immediately be stopped until the Company facilities have been
located and investigated for possible damage.
When Third Party construction activity involving a Company pipeline or facility is started without
prior approval, notify the operations supervisor immediately. Contact the Land and Right-of-
Way Department to determine the Company's rights. Inspect the premises immediately and take
necessary steps to correct or prevent unsafe conditions.
When physical evidence of an unmonitored encroachment over the pipeline is discovered, the
area must be investigated to determine if an excavation is required, an informational ERL must be
issued and the event documented in STARS. If an excavation is required, the pipeline shall be
inspected for damage in conformance with existing company procedures. Upon discovery of
pipeline damage, an ERL notification shall be initiated and the occurrence treated as an
Abnormal Operation in conformance with O&M Procedure 1902— Abnormal Operation.
High Consequence Areas: When physical evidence of encroachment over the pipeline is
discovered in an HCA that was not monitored, the area must be excavated near the
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encroachment or an above ground survey must be conducted using methods defined in NACE
RP-0502-2008.
When land leveling or improvements involving a Company pipeline or facility are started without
prior approval, notify the operations supervisor immediately. Contact the Land and Right-of-
Way Department to determine the Company's rights. Inspect the premises immediately and take
necessary steps to correct or prevent unsafe conditions.
If excavation or other activities are identified within the Company's pipeline easement that are not
allowed by the pipeline easement or permit agreement, the activities shall be stopped until an
agreement is reached. If excavation activities continue, local management should be advised
and the Company's Legal Department and/or local law enforcement authorities may be called for
assistance.
3.7. Inspecting Construction Activity—KM Notified
Excavation Monitoring (periodic monitoring)— For excavations between 25-feet and 50-feet
from a Company facility. A properly trained and OQ qualified Company representative shall
periodically monitor the excavation to assure that the work is continuing as planned. Excavations
greater than 50-feet from a Company facility should be monitored as necessary.
On-Site Monitoring (mandatory monitoring) —When construction activity is within 25-feet
of the Company operated transmission or gathering pipeline facilities, a properly trained
and OQ qualified Company representative shall, unless excepted by Subsection 3.7.1. — Waiver
to On-Site Monitoring, be on site.
Excavation Observation —Observation is mandatory when excavation activity is within 10-
feet of the pipeline. When an excavation is within 10-feet of a Company facility a properly
trained and OQ qualified Company representative shall be continuously present during all
excavation and backfilling activities to observe compliance with agreed upon
design/specification/scope of work and to ensure the excavation and backfilling criteria are being
met. If a Company representative is not observing the activities, absolutely no work is to be
allowed.
The Company Observer shall be aware of the hazards of operating equipment and shall use
audible warning devices to warn equipment operators of impending danger or threat to the safety
of personnel or facilities. The audible warning device should be a portable air horn or other
approved device that the equipment operator can hear above normal equipment noise.
If the excavation results in a foreign utility crossing of KM's pipeline, the KM employee shall
complete O&M Form OM200-01 — Foreign Structures Report. If the excavation results in a
metallic object crossing also complete O&M Form OM200-03 — Underground Structure
Crossing Report. If the excavation results in the exposure of a KM pipeline, the KM employee
shall complete O&M Form OM200-02—Pipeline Examination Report.
A KM representative may give permission for work to be performed over the pipeline without
being on site. Prior to giving permission, the KM representative must have marked the pipeline
(unless exempted by Section 3.4) and assured themselves that there is no risk to the pipeline
from grading operations or excavation activities, where the depth of the pipeline is known to be
below plow depth. Work is defined as digging or disturbing the soil, moving any heavy equipment
over the pipeline with less than the required cover.
In the event of parallel encroachments or other circumstances where the excavation activities will
require a Company representative to be present for a long duration, and there is to be no
crossing of the Company's pipeline, the contractor's work schedule shall be provided to the
Company and a meeting held with Company inspector(s)when necessary to review the schedule.
Any deviations to the schedule will require advance Company approval.
Company representatives should be aware of the O&M Form OM200-29 — Guidelines for
Design and Construction near Kinder Morgan Operated Facilities during construction near
Company facilities:
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When an encroachment (1s` 2nd or 3rd party) involves any one of the following conditions, the
Damage Prevention Supervisor, Operations Supervisor or their designee must be contacted to
determine if additional precautions need to be taken to protect the Kinder Morgan Pipeline. This
discussion will be documented in the electronic one call system:
• Excavation less than 10-feet
• Foreign line crossing
• Exposed KM pipeline
• Parallel construction within 25-feet
3.7.1. Waiver to On-site Monitoring
When the scope and location of the proposed excavation is greater than 10-feet from the
Company's asset and there appears to be no benefit to being continuously present to
protect the asset, a waiver to the observation may be granted.
Examples where this may be applicable include, but are not limited to:
• Excavation, such as paving or digging foundation footings on private property when the
pipeline is under the city street or on the opposite side of the road.
• Replacing utility poles when the utility easement is offset from the pipeline at a distance
greater than 10-feet and guy wires will not encroach upon the easement.
• Excavation on the other side of an immovable barrier or natural demarcation, such as,
construction separated from our pipeline by railroad, or stone/concrete fence, etc.
• Other digging that will not damage the pipeline, i.e. hand digging, shallow/well defined.
• Concrete Barriers installed between the area of excavation and the KM pipe
• Permanent or temporary fencing installed between the area of the excavation and the KM
pipe
• Video monitoring
• Other situations where the activity will not affect the pipeline.
Care should be taken to ensure that the scope of work does not include utility work that could
potentially cross the pipeline or that the pipeline is not within the designated excavation area
(white lined area).
Note: KM does not have the authority to waive a State One-Call requirement.
When seeking a waiver to continuous monitoring, for construction within 25-feet but greater
than 10-feet of the pipeline, the KM Line Locator must contact the Damage Prevention
Supervisor, Area Manager or Operations Supervisor to get their concurrence. After approval,
the site should be monitored periodically to ensure work remains within the original scope.
• The justification, date and time of the concurrence and the name of the person granting
the exception must be recorded in the notes section of the electronic One-Call system
and the "waiver"box checked.
• The person granting the exception must also record the decision and the basis for the
decision in their records.
3.7.1.1. Exceptions to Company Personnel Observing/Monitoring Excavation and Backfilling
Activities
• Operations Management will decide when it is necessary to use a contract
representative to monitor excavation and/or backfilling activities.
• The Damage Prevention Supervisor will follow the appropriate Company
procedure(s) for selection and contracting of a contract representative.
• The Damage Prevention Supervisor will coordinate with the Operations Manager
to ensure that the contract representative has completed the required training
and approve the Operator Qualification (OO) credentials.
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• The Damage Prevention Supervisor must confirm proficiency and knowledge of
covered procedures and training for the contract representative.
• As a minimum the contract representative shall be Operator Qualified on the
following tasks:
OO Requirements for KM Representatives
o 01.01.01 Abnormal Operations
o 08.02.01 Damage Prevention During Excavation Activities
o 14.02.01 Backfilling
o 14.05.01 Underground Clearances
o 14.08.01 Cover
o 14.10.01 Line Markers
o 14.13.01 Protection When Minimum Cover Not Met
o 14.09.01 Inspection: Compliance with Procedures & Standards
• The Damage Prevention Supervisor will be responsible for ensuring that the
contract representative has reviewed, understands and provides proper
documentation of the following the Company Operating & Maintenance (O&M)
Procedures:
o O&M Procedure 109— Excavating,Trenching and Shoring
o O&M Procedure 159—Incident Reporting and Investigation
o O&M Procedure 166—Safety Hazard/Near Miss Reporting
o O&M Procedure 168-Safety Orientation
o O&M Procedure 204—Construction Near Company Facilities
o O&M Procedure 205—Pipeline Markers and Cover
o O&M Procedure 214—Reporting Pipeline Safety-Related Conditions
• The Operations Manager will communicate to the Director of Operations the
intent to utilize a contract representative for excavations and/or backfilling
activities within their area of responsibility.
• The Director of Operations will review the need to utilize contract inspectors and
if deemed necessary will conditionally approve the use per project.
• Final approval to use contract inspectors will not be given until all training is
completed.
• The Damage Prevention Supervisor will be responsible for ensuring that the
contract representative has reviewed, understands and provides proper
documentation of the following the Company Construction Inspection
procedures:
o Construction Inpection Section CON0020—General Requirements
o Construction Standard C1010—Clearing, Grading and Site Preparation
o Construction Standard C1100—Backfillinq
o Construction Standard C1160—Horizontal Directional Drilling
• The Damage Prevention Supervisor will be responsible for ensuring that the
contract representative has reviewed, understands and provides proper
documentation of the Kinder Morgan Contractor Safety Manual.
• The Damage Prevention Supervisor will be responsible for providing copies of
the training requirements stated above to the Operations Manager for approval,
then to the Director of Operations for review and approval before proceeding with
the use of contract representatives during excavations and backfilling activities
on existing Company right-of-ways and property. Including the following:
o Confirmation of the completion and acceptable scores of the OQ training
stated above.
o Copies of O&M Procedures, Construction Inspection Manual and Contractor
Safety Manual - signed and dated by the contract representative as well as
the project manager or their designee.
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o A general summary that identifies the planned excavation and backfilling
activities.
• The Director of Operations will:
o Provide confirmation to the Damage Prevention Supervisor and Operations
Manager, via email, if they are in agreement that all training requirements
have been satisfied and use of the contract representative for monitoring of
excavation and/or backfilling activities is approved.
- OR -
o Respond to the Damage Prevention Supervisor and Operations Manager, via
email, that training requirements are deficient and the use of the contract
representative is NOT approved.
3.7.2. Kinder Morgan Initiated Excavation Activities
When excavating, Kinder Morgan and Contractors doing work for Kinder Morgan have the
same obligations to comply with state One Call laws and follow the practices that we expect
from 3rd party excavators. To that end, the person responsible for excavating on behalf of
Kinder Morgan will:
• Make notification to the appropriate one call center of the intent to excavate the pipeline
within the required timelines specified by applicable State One Call Law.
• If the excavation location cannot be specifically identified by landmark, address, legal
description or GPS point, identify the proposed area of excavation using white lining prior
to notification of the One-Call center.
• Maintain the ticket number from the one call center that verifies the locate request was
requested.
• If multiple excavators for KM are working at the same site, each will have a separate one
call reference.
• When practical the KM excavator will request a meeting with the other facility locator(s) at
the job site prior to the actual marking of facility locations.
• An excavation procedure, plan or job scope must be reviewed and approved by the local
Damage Prevention Supervisor, Operations Supervisor or Operations Manager, prior to
the excavation. The approval will be documented in the electronic one call system.
• Soft digging (hydrovac or other) may be required, to expose KM facilities, if deemed
necessary during excavation review and planning.
• Depending on the complexity of the job, different types of documentation may be used for
the excavation plan. Some examples include: Form OM200-31, The Project
Management Excavation Procedure for New Construction, The Project Management
Excavation Procedure for Existing Facilities, facility drawings, red lined drawings, or other
documents.
• Coordinate work that requires temporary or permanent interruption of a facility's service
with the affected facility owner/operator.
• Re-call the one call center if the facility owner/operator fails to respond to the KM request
for a locate (within the timeframe established by the state one call law).
• Verify that the excavation site is at the correct location as described on the one call ticket.
• Verify the locate markings and check for unmarked facilities by conducting an electronic
and visual sweep of the site. Perform an "electronic sweep" of the white lined area by
using a KM approved locator, set to inductive mode. Visually check for such things as
signs, markings, and trenches that might indicate underground utilities are present.
• The excavator should review the location of underground facilities with the facility
operator prior to excavation.
• The KM employee on site should have access to the names and phone numbers of all
facility owner/operators contacts and the one call center.
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• Reasonable care will be used to avoid damaging underground facilities. The excavation
should be planned to avoid damage and or minimize interference with the underground
facilities in or near the work area.
• Protect and preserve the staking, marking or other designations for underground facilities
until no longer required for proper and safe excavation. If any facility mark is removed or
no longer visible, excavation is to be stopped and the facility owner or one call center is
notified to request a re-mark.
• An observer is required to assist the equipment operator when operating excavation
equipment around known underground facilities.
• Mechanical excavation is not allowed within the tolerance zone of the underground facility
unless otherwise allowed by this procedure.
• The facility owner/operator is to be contacted, either directly or through the one call
center if an underground facility is not found where one has been marked or if an
unmarked underground facility is found. Following this notification work can be
continued, unless otherwise in state law, if the work can be performed without damaging
the facility.
• Exposed pipeline facilities will be supported and protected from damage.
• The one call center will be called to refresh the ticket if it is expected that the excavation
will continue past the life of the ticket.
• If an underground facility is damaged or is discovered to be damaged, the owner/operator
of the damaged facility will be notified either directly or via the one call center (unless
otherwise specified by state law). All breaks, leaks, nicks, dents, gouges, grooves, or
other damages to facility lines conduits, coatings or cathodic protection will be reported.
• If the damage results in the escape of any flammable, toxic, or corrosive gas or liquid or
endangers life, health, or property 911 and the facility owner/operator is to be notified
immediately. Reasonable measures will be taken to protect those in immediate danger
(employees, contractors, public), property and the environment until the facility
owner/operator or emergency responders have arrived and completed their assessment.
• In the case of an emergency excavation of a KM pipeline, maintenance or repairs may be
made immediately provided the one call center and impacted facility owner/operators are
notified as soon as reasonably possible. This includes situations that involve danger to
life, health or property.
• Protect all facilities from damage when backfilling an excavation. Trash, debris or other
material that could damage existing facilities or interfere with the accuracy of future
locates is not to be buried in the excavation.
• For trenchless excavations (boring, etc.) the KM excavator will adhere to all best
practices stated in this section.
• All applicable federal and state safety regulations, which include training as it relates to
the protection of underground facilities, will be adhered to.
• High Consequence Areas: An excavation in an HCA shall be evaluated for the potential
of stress corrosion cracking (SCC) by reviewing the existing conditions with the SCC
criteria (refer to the Pipeline Integrity Management Program)
When a KM pipeline is exposed O&M Form OM200-02— Pipeline Examination Report must be
completed
3.8. Excavating Pressurized Lines
Tolerance Zone — The tolerance zone is a buffer area around the circumference of the pipeline.
State law and Company operating procedures determine what types of digging may be done
within the tolerance zone. The minimum tolerance zone to be observed is 18-inches or state law
whichever is more stringent. Refer to Table 1 —Tolerance Zones by State.
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Dual Use Document Revised: 2011-11-10
State Tolerance Zone
Alabama 18"
Arkansas 18"
Colorado 18"
Illinois 18"
Indiana 24"
Iowa 18"
Kansas 24"
Louisiana 18"
Mississippi 18"
Missouri 24"
Nebraska 18"
New Mexico 18"
Ohio 18"
Oklahoma 24"
Texas 18" + 1/2 Pipe O.D. **
Wyoming 24"
Table 1 —Tolerance Zones by State
** In Texas, the qualified onsite KM
representative may approve for the
excavator to dig up to the 18"
tolerance zone (for KM facilities
only).
Before excavation by powered equipment, the line must be located with a water probe, probe rod,
vacuum truck or exposed by hand or other soft digging methods. Probing shall be done during
excavation across the entire ditch. Probe bars shall be used to verify depth and to size the line.
Locate the top of pipe and both sides at the point the line is being crossed. When excavating,
power equipment shall not dig within the tolerance zone of the pipeline and Probing shall be done
during excavation. Pipeline shall be exposed by hand digging, hydrovac, or other soft digging
methods only at this point. Be aware of possible side taps and or top taps that have been
abandoned or are not reflected on alignments; for known taps additional hand digging may be
required.
18"
18" 18"
•
18"
Figure 1 — Minimum Tolerance Zone
If a probe rod must be used, inspecting the coating in the excavated area is required and any
damaged areas must be repaired before backfilling. DO NOT locate pressurized lines using
power equipment.
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KINDER IORGAN No. O&M 204/C1005
Title: Construction near Company
O&M PROCEDURE/CONSTRUCTION STANDARD Facilities
Dual Use Document Revised: 2011-11-10
Power equipment excavation should be done with the equipment positioned parallel to the
pipeline unless ROW congestion prevents adequately positioning excavating equipment. Digging
across the line with power equipment positioned above the line should be avoided wherever
possible.
Care should be used when removing rock adjacent to the pipeline. With any type of rock breaker,
the force of the tool should always be directed away from the pipeline. Rock breakers can move
in unexpected directions when rock is broken. Use a protective barrier (e.g., wood, rubber)
placed between the tool and pipe during this operation. Ensure that the protective barrier is
adequate to protect the pipeline integrity should any inadvertent deflection of the tool occur.
If circumstances warrant it a hand held jack hammer or air shovel may be used within the
tolerance zone as long as all of the other conditions of this part are met and:
• The tool operator should also exercise caution to avoid placing their body, arms, hands, etc.
between the tool and the pipeline in order to avoid "pinch points" if the tool is deflected.
• The pipeline pressure will be reduced as low as operationally acceptable by the system Gas
Control
• The excavation meets OSHA requirements with emphasis on the following;
o Adequate unrestricted work space is provided to allow proper handling and manipulation
of the jack hammer, air shovel and other tools
o An excavation exit plan is available.
• All other personal protective equipment required for this type of work; gloves, face shield,
long sleeves, hard hats, steel-toed shoes, etc. will be utilized.
High Consequence Areas: An excavation in an HCA shall be evaluated for the potential of
stress corrosion cracking (SCC) by reviewing the existing conditions with the SCC, criteria (refer
to O&M Procedure 917—Stress Corrosion Cracking).
3.9. Horizontal Distance
When new facility construction parallels the Company's transmission or gathering pipelines,
horizontal clearances shall be as defined in Table 2 — Horizontal Distance from Company
Facilities or shall be the extent of the ROW, whichever is less. Establish any horizontal clearance
less than that specified in the table by agreement between the Company and the underground
facility's owner. Discuss horizontal clearances requested within fee owned property with the
Land and Right-of-Way Department.
Third Party Facility Horizontal Distance from Company
Facilities
Buried pipelines At least 10-feet
Buried telephone cable At least 10-feet
Overhead telephone cable At least 25-feet
Buried electric cables 440 VAC or less At least 10-feet
Buried electric cables 440 VAC to 37.5 KVAC At least 25-feet
Overhead electric lines 37.5 KVAC or less At least 25-feet
Buried or overhead electric lines — facilities over Only by agreement between the utility and
37.5 KV, AC or DC electric cable the Company's Regional Technical Manager
or designee
Table 2-Horizontal Distance from Company Facilities
3.10. Vertical Facility Clearance
Follow recommended minimum vertical clearances as shown in Table 3—Vertical Clearance from
Company Facilities when repairing, installing or constructing pipelines or cables across a
Company transmission or gathering pipeline. Maintain underground utility depth to obtain these
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KINDER MORGAN No. O&M 204/C1005
Title: Construction near Company
O&M PROCEDURE/CONSTRUCTION STANDARD Facilities
Dual Use Document Revised: 2011-11-10
clearances across the entire easement. The Company must approve any deviation from vertical
clearance requirements.
Third Party Vertical Clearance from Company Facility
Facility
New When installing underground utilities, the last line should be placed beneath all
construction existing lines unless it is impossible or unreasonable to do so.
Buried steel At least a 24-inch vertical earth separation from a Company pipeline
pipelines
Buried non- At least a 24-inch vertical earth separation from a Company pipeline.
steel pipelines At least a 24-inch vertical earth separation from a Company pipeline 12-inches
or greater in diameter. Install flagging tape above the Company pipeline,
approximately 3-feet on each side and directly over the cable or utility line for a
distance of at least 15-feet.
Buried At least a 24-inch vertical earth separation from a Company pipeline
telephone and The cable must have a nonconductive outer sheath extending at least 10-feet
electric cables each direction from the Company pipeline. Install flagging tape above the
—440 VAC or Company pipeline, approximately 3-feet on each side and directly over the
less cable or utility line for a distance of at least 15-feet.
Fiber optic Efforts should be made to install all fiber optic cable crossings at least 3-feet
cables below Company pipelines.
Installing a concrete barrier is recommended but may not be practical when the
cable is a direct bore. In that case, the clearance and markings become more
critical.
Buried electric At least a 24-inch vertical earth separation from a Company pipeline.
cables 440 The cable shall have a nonconductive outer sheath extending at least 10-feet
VAC to 37.5 each direction from the Company pipeline. Install flagging tape above the
KVAC Company pipeline, approximately 3-feet on each side and directly over the
cable or utility line for a distance of at least 15-feet.
Facilities over Vertical separation of an electric cable or line operating at more than 37.5
37.5 KV Kilovolts A.C. or D.C. will be established by agreement between the utility
involved and the Company Regional Technical Manager or designee.
Table 3-Vertical Clearance from Company Facility
3.11. Engineering Assessment
When an encroachment with the potential to impact a Company facility is identified, an
assessment and determination of the impact shall be required. Company representatives will
notify the Regional Technical Manager or designee, who can include local Land and Right-of-
Way Department, or regional corrosion supervisor, to review information and respond to the third
party. Upon notification of an encroachment by a third party, gather pertinent facts, including:
• The exact location, scope, description and schedule of the proposed third party activity
• The exact location and description of the Company facility(s)
• Identify encroaching entity and record contact information.
• Identify local Operations contact.
• Determine which pipeline(s) or other Company facilities are impacted. Record location and
rechain station from inventory sheet or PODS database.
• Gather critical pipeline data such as pipe specifications, MAOP, class location, depth and
coating type. Depending on the coating type, it may be necessary to take a coating sample
and test for asbestos. Refer to O&M Procedure 1211 —Asbestos.
• Contact designated Land Department representative for ROW information.
• Fee property or easement, (i.e. year established) (contact the Land and Right-of-Way
Department)
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KINDER MORGAN No. O&M 204/C1005
Title: Construction near Company
O&M PROCEDURE/CONSTRUCTION STANDARD Facilities
Dual Use Document Revised: 2011-11-10
• ROW width, (i.e. special conditions) (contact the Land and Riaht-of-Wav Department)
• Determine scope of third party project and scope of Company mitigation work.
• Determine project scheduling.
• Review Corrosion records prior to approval of a parking lot to determine if any recoating or
other maintenance work is needed.
The Engineering Assessment required by this section must include analysis of the impact of
abnormal loads or stresses on the pipeline.
• The pipe must be protected from hazards that may cause the pipe to sustain abnormal loads.
• Pipe must be of sufficient thickness or adequate protection must be provided to withstand
anticipated external pressure and loads.
• Adequate protection must be provided to prevent damage that might result from the proximity
of structures that are within 24-inches of the pipeline.
After conducting the Engineering Assessment, the Regional 'Technical Manager may approve
permanent structures to be built with clearance from the pipeline of less than 24-inches but no
closer than 12-inches. Variance from the requirements of this procedure for clearance of
structures of less than 12-inches must be obtained through O&M Procedure 001 — Standards
Modification.
3.12. Heavy Equipment/Vehicle Crossings, Roadways and Parking Lots
Roads, construction equipment crossings and parking lots over steel pipelines shall be evaluated
using the Company's stress calculation program, "PLStress" or other suitable method for
calculating stress for uncased pipelines by Regional Technical Manager or designee to determine
the total stress on the pipeline. If the total stress exceeds recommended limits, a permanent
protective structure should be considered. For pipelines constructed of material other than steel,
contact Regional Technical Manger or designee.
The following information will be required for the stress analysis. This information should then be
provided to Regional Technical Manager or designee and used as inputs into the stress
calculation for heavy loads crossing uncased pipelines.
• Loaded vehicle axle load (single, tandem)
(1) Heaviest construction equipment evaluated at the bottom of the sub-base
(2) Street legal vehicles such as concrete truck, trash truck, commercial vehicles evaluated
at the top of the finished structure
• Equipment make and model
• Caterpillar equivalent make and model, if available
• Depth of cover over pipeline
• Soil Characteristics
• Roadway or parking lot material (asphalt, concrete, dirt, gravel, etc).
3.13. Directional Drilling
A Company representative must follow the procedures outlined in this section when a third party,
contractor, etc. will perform directional drilling operations parallel to and/or within the minimum
specified clearance of the Company's pipeline facilities.
The Company representative can ask a contractor to stop drilling if the operation is deemed
unsafe or there is a concern that damage to the pipeline facilities may occur. A contractor is
responsible for any damage to the pipeline facilities incurred because of the drilling.
Before starting a job,the contractor will:
• Notify One-Call for a utility locate request
• Contact the Company and advise of the proposed drilling route, expected clearance between
the drilling tool and pipeline facilities and construction schedule
• Demonstrate that the boring tool can be accurately positioned
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KINDER4MORGAN No. O&M 204/C1005
Title: Construction near Company
O&M PROCEDURE/CONSTRUCTION STANDARD Facilities
Dual Use Document Revised: 2011-11-10
• The Company representative will periodically measure clearance when practical between the
boring tool and pipeline facilities and if necessary, require a viewing window to help
determine that the tool will miss the pipeline. A third party's facility must maintain the vertical
and horizontal clearances described in Table 2 — Horizontal Distance from Company
Facilities and Table 3—Vertical Clearance from Company Facilities.
Upon completion of the directional drill, the Company representative will:
• Conduct a leakage survey along the length of the directional drilled path
• Refer to O&M Procedure 215 — Patrolling and Leak Detection for leakage survey
documentation.
Field personnel will complete applicable OM Buried Facility Reports and develop as-built
Company drawings (except for block cards) and send to Engineering Mapping/CADD in
Lakewood. Drawings should indicate the third party's name, location of its utility line and the
measured horizontal and vertical separation between the third party's and Company's facilities.
3.14. Land Leveling or Improvement—Company Notified
When advance notice of proposed land leveling or improvement is received, field personnel will
notify the Land and Right-of-Way Department. Submit requests to reduce pipeline cover or
construction over the pipeline to Regional Technical Manager or designee for review.
• Upon notification, determine to what extent the Company pipeline may be affected.
• Evaluate alternatives for sloping the land or making improvements to avoid relocating
Company pipeline or removing soil over a buried line. If possible, the landowner should
achieve desired results without jeopardizing or disturbing the Company pipeline.
• Conduct a cover survey, profile and mark the pipeline's location.
If the leveling or improvement cannot be accomplished without relocating or modifying the
Company pipeline, gather pertinent facts, including:
• The exact location and description of the proposed leveling or improvement
• A description of the required modification to Company pipeline facilities
• Possible alternatives to avoid disturbing Company pipeline
• The Regional Technical Manager or designee will review the information and determine
required modifications.
Regional Technical Manager or designee will provide modification details and costs and will
advise what agreements are necessary between the Company and landowner. The Land and
Right-of-Way Department will then contact the landowners and notify them of the portion of the
cost for which they are responsible before beginning the project.
3.15. Blasting and Seismic Activity
Provide the Technical Manager or designee the following information when blasting is anticipated:
• Configuration of explosive charges (point, line or grid)
• Number of charges, spacing between charges, types of charges and weights
• Distance between pipeline and nearest charge for each pipeline
• Angle between pipeline and explosive line or grid (if grid, number of rows and charges per
row)
• Pipe description of each pipeline
• Alternatives to blasting that were considered
Technical Manager or designee will prescribe proper blasting procedures and minimum distances
to avoid pipeline damage for all blasting within 300-feet of the pipeline. Standoff distances of
100-feet for line or grid configurations containing a total charge weight of greater than 100 pounds
are required.
If the Technical Manager or designee believes blasting could damage a facility, field personnel
must perform leakage surveys as often as necessary during and after blasting to verify the
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KINDERINORGAN No. O&M 204/C1005
Title: Construction near Company
O&M PROCEDURE/CONSTRUCTION STANDARD Facilities
Dual Use Document Revised: 2011-11-10
pipeline's integrity
3.16. Buildings near Pipelines
It is recommended that buildings be a minimum of 25-feet or greater (if required by local
ordinances) from any gathering or transmission pipeline or off the pipeline easement, whichever
distance is greater. Contact the Land and Right-of-Way Department to determine the
Company's rights.
4. Training
Regional management will ensure that individuals involved in tasks required in this procedure are
trained in operating locating instruments, appropriate documentation and all other provisions of this
procedure.
Persons performing locating functions must meet the requirements of the Company Operator
Qualification program. This will be confirmed yearly in the l&M Program, Procedure 1-0266.00.
Personnel should review this information as necessary before performing the procedure.
In order to ensure that responses made by a Company representative to an excavation notification is
handled correctly, and that line locating procedures are properly followed, the local supervisor,
manager, or director, shall periodically, but at least once each calendar year, accompany the
Company Representatives assigned to line locate duties to assess work demands, quality of line
marking, and coordination of excavations along the ROW. The yearly reviews will be documented on
O&M Form OM200-34— Line Locator Review and Report. This will be confirmed yearly in the l&M
Program, Procedure 1-0266.01.
5. Documentation
5.1. Company Report Forms
With the exception of distribution systems, report all foreign crossings, foreign structure
retirements and inspection activities on O&M Form OM200-01 — Foreign Structures Report or
the state's One-Call form. Report the condition of existing underground pipeline O&M Form
OM200-02— Pipeline Examination Report. Report any pipeline damage or any near-miss from
third party activities into STARS as soon as possible.
Report metallic foreign structure crossings on O&M Form OM200-03— Underground Structure
Crossing Report. Use O&M Form OM200-31 — Line Locate Inspection Report to document
on-site communications with contractors or other third parties. Report any pipeline damage or
near-miss into STARS as soon as possible.
Document the annual One-Call pipeline asset review using l&M Procedure 1-0265.00 —
Maintaininq Pipelines in One-Call System.
5.2. Response to Third Party
A response letter should be written to the third party outlining what impact the encroachment has
to our pipeline(s), request additional information, if needed, identify any special requirements and
relay our expectations for reimbursement (if adjustment is required).
The Company's O&M Form OM200-29 — Guidelines for Design and Construction near
Kinder Morgan Operated Facilities should be included, in their entirety, in the response letter.
All correspondence should be sent to the appropriate Operations and Land and Right-of-Way
Department / Land and Right-of-Way representative for review/comment prior to sending to the
encroaching entity. Consideration should be given as to whether any response should be
recorded as a legal document along with the existing easement.
5.3. Photographs
• Photographs shall be taken in sufficient detail to demonstrate the adequacy of marking within
the area of proposed excavation.
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KINDER ORGAN No. O&M 204/C1005
Title: Construction near Company
O&M PROCEDURE/CONSTRUCTION STANDARD Facilities
Dual Use Document Revised: 2011-11-10
• Photographs shall be readily associated with the One Call ticket by the use of white
boards/cards (or other approved methods) and file name nomenclature. White boards/cards
at a minimum should include:
o One Call Ticket Number
o Location (Lat/Lon or address)
o Compass Bearing
o Time and Date of the Photograph
o Name of Photographer
• Photographs shall be stored in Petris, unless technical difficulties such as bandwith or
download speed creates a problem. The Manager must approve of not storing the
photographs in Petris.
• When technical difficulties prevent the storing of the photographs in Petris, the photographs
shall be attached to a hard copy of the completed One-Call ticket and maintained in local files
where they will be readily identifiable to the location.
• Photographs shall be retained in accordance with applicable state laws for One-Call
documentation.
5.4. All Documentation
In the event of litigation, unresolved situations, or as instructed by management, affirmative steps
must be taken to preserve all records (whether in electronic or written form) until such time as
otherwise directed by a representative of Company's legal department.
6. References
• 49 CFR 192.614 (c)(3), (4) and (6)(ii), 192.929(b)1, 192.935(d)2; 192.935(b)iii
• Iowa Chapter 479, Section 479A.26
• Common Ground Alliance Best Practices
• O&M Procedure 120— Personal Protective Equipment
• O&M Procedure 205—Pipeline.Markers and Cover
• O&M Procedure 206—Land and Right-Of-Way
• O&M Procedure 214—Reporting Pipeline Safety-Related Conditions
• O&M Procedure 215—Patrolling and Leak Detection
• O&M Procedure 232—Damage Prevention and Public Awareness
• O&M Procedure 237—Dresser-Coupled Pipelines
• O&M Procedure 903— External Corrosion Control for Buried or Submerged Pipelines
• O&M Procedure 917—Stress Corrosion Cracking
• O&M Procedure 1700 — Inspection & Maintenance, 1-0265.00 — Maintain Pipelines in One-
Call System
• O&M Form OM200-01 —Foreign Structures Report
• O&M Form OM200-02— Pipeline Examination Report
• O&M Form OM200-03- Underground Structure Crossing Report
• O&M Form OM200-29 - Guidelines for Design and Construction near Kinder Morgan
Operated Facilities
• O&M Form OM200-31 —Line Locate Inspection Report
• O&M Form OM200-34— Line Locator Review and Report
• l&M Procedure 1-0266.00 - Operator Qualification Review for Line Locating Personnel
• l&M Procedure 1-0266.01 - Line Locator Personnel Assessment
• Construction Drawing CST-P-1000-A305—Typical Undercrossinq of Tile Drainlines
• Construction Drawing CST-P-1000-A325—Crossing Foreign Pipelines
• STARS
• Pipeline Integrity Management Program
• PLStress Pipeline Stress Calculation
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KINDERMORGAN No. O&M 204/C1005
Title: Construction near Company
O&M PROCEDURE/CONSTRUCTION STANDARD Facilities
Dual Use Document Revised: 2011-11-10
Attachment 1 — One-Call Center and Emergency Phone Numbers
State One-Call Center Telephone Number
Alabama Alabama One-Call 800-292-8525
Arkansas Arkansas One-Call System, Inc. 800-482-8998
Colorado Utility Notification Center of Colorado 800-922-1987
Illinois JULIE, Inc. 800-892-0123
Indiana Indiana Underground Plant Protection Service 800-382-5544
Iowa Underground Plant Location Service, Inc. 800-292-8989
Kansas Kansas One-Call System, Inc. 800-344-7233
Louisiana DOTTIE—Louisiana One-Call System, Inc. 800-272-3020
Mississippi Mississippi One-Call 800-227-6477
Missouri Missouri One-Call System, Inc. 800-344-7483
Montana Montana One-Call 800-551-8344
Utilities Underground Locating Center 800-424-5555
Nebraska Diggers Hotline of Nebraska 800-331-5666
New Mexico New Mexico One-Call System, Inc. 800-321-2537
Oklahoma Oklahoma One-Call System, Inc. 800-522-6543
Ohio Ohio Utilities Protection Service 800-362-2764
Texas TESS-Texas Excavation Safety System, Inc. 800-344-8377
Lone Star Notification Center 800-669-8344
Wyoming One-Call of Wyoming 800-849-2476
National Call 811 811
Company Emergency Control Center Numbers
Entity Telephone Number
KinderHawk 866-775-5784
Kinder Morgan 888-763-3690
Kinder Morgan Interstate Gas Transmission Company 888-763-3690
Kinder Morgan Louisiana Pipeline, LLC 800-733-2490
Kinder Morgan North Texas Pipeline 800-633-0184
Kinder Morgan Tejas Pipeline, LLC 800-568-7512
Kinder Morgan Texas Pipeline, LLC 800-633-0184
Midcontinent Express Pipeline, LLC 800-733-2490
Natural Gas Pipeline Company of America 800-733-2490
Trailblazer Pipeline Company 800-733-2490
TransColorado Gas Transmission 800-944-4817
Rockies Express Pipeline, LLC 877-436-2253
Highlighting indicates revisions made as of the date on this procedure Page 19 of 19
16C
Cat-e,
O� DEPARTMENT OF NATURAL RESOURCES
N
DIVISION OF WATER RESOURCES
1 * John W.HIckenlooper
4. 1876 Governor
Mike King
Executive Director
Response to Reclamation Permit Application Consideration Dick Wolfe P.E.
,Director/State Engineer
DATE: September 14, 2011
TO: Peter S. Hays, Environmental Protection Specialist
CC: Division 1 Office, District 1 Water Commissioner
FROM: Sarah Brucker, P.E.
Peters Ranch Pit, File No. M-2011-022
Operator: Basic Energy Services LP
Contact: Michael Denison, (307) 386-2608
SW'/ Sec. 26, Twp. 12 North, Rng. 63 West, 6th P.M., Weld County
CONDITIONS FOR APPROVAL
The proposed operation does not anticipate exposing groundwater. Therefore, exposure of ground
water must not occur during or after mining operations.
The applicant has indicated plans to use other water for dust control purposes at the permit site. The
source of water for this use is to be obtained from an outside source and trucked to the site. Applicant
will need to document that this water was obtained from a legal source, or the water was diverted in
priority under a water right decreed for such industrial use.
COMMENTS: This will be a surface mining operation located on a ridge top. No water will be required to
process the mined material. A series of berms and shallow sediment containment retention areas will keep
surface water within the pit boundary. If stormwater runoff is intercepted by this operation and is not diverted or
captured in priority, it must be released to the stream system within 72 hours. This may require a discharge
permit from CDPHE-WQCD. Otherwise, the operator will be required to make replacements for evaporation.
The land will be reclaimed to pasture and wildlife use at the conclusion of mining operations.
RECE.WE D
SEP 14 2011
Division of Reclamation,
Mining ref.Safety
Office of the State Engineer
1313 Sherman Street,Suite 818•Denver,CO 80203•Phone: 303-866-3581 •Fax:303-866-3589
www.water.state.co.us
Ma ' DEPARTMENT OF THE ARMY
7e,} I/ CORPS OF ENGINEERS,OMAHA DISTRICT
DENVER REGULATORY OFFICE,9307 SOUTH WADSWORTH BOULEVARD
` LITTLETON,COLORADO&0128-6901
%,rsasw " September 12, 2011 EyW
IEWIND
Mr. Peter Hays SEP 1 3 2011
Division of Reclamation, Mining and Safety Division or Reclamation,
Department of Natural Resources Mining and Safety
1313 Sherman St., Room 215 C.2, ,c
Denver, CO 80203
RE: Basic Energy Services LP,Peters Ranch Pit,File No. M-2011-022
Dear Mr. Hays:
Reference is made to the above mentioned project located in Section 26, T12N, R63 W, Weld
County, Colorado.
If any work requires the discharge of dredged or fill material, and any excavation associated with
a dredged or fill project, either temporary or permanent in an aquatic site,which may include ephemeral
and perennial streams, wetlands, lakes, ponds, drainage ditches and irrigation ditches, this office should
be notified by a proponent of the project for Department of the Anny permits, changes in permit
requirements or jurisdictional determinations pursuant to Section 404 of the Clean Water Act.
Work in an aquatic site should be identified by the proponent of the project and be shown on a
map identifying the Quarter Section, Township, Range and County or Latitude and Longitude, Decimal
Degrees (datum NAD 83) and the dimensions of work in each aquatic site. Any loss of an aquatic site
may require mitigation. Mitigation requirements will be determined during the Department of the Army
permitting review.
If there are any questions call Mr. Terry McKee of my office at 303-979-4120.
Sincerely,
Timothy T. Carey
Chief, Denver Regulatory Office
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