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Home My WebLink About931755.tiff --VESSELS OIL & GAS COMPANY SUITE 2000,PRUDENTIAL PLAZA 1050 SEVENTEENTH STREET•DENVER,COLORADO 80265 303 825-3500 THOMAS 0 VESSELS,Chairman of the Board I}}y++��} THOMAS J.VESSELS,President a i' I 12 November 1993 NOV 16 1993 c Mr . Keith Schuett Wok' *Pi Weld County Department of Planning 1400 North 17th Avenue Greeley, CO 80631 Subject : Permits submitted under USR 589 Mr . Schuett Thank you for taking the time this morning to review with me the permits Vessels Oil & Gas (VOG) has applied for under USR 589 in conjunction with the expansion of VOG' s Ft . Lupton processing facility. I also appreciate the opportunity to address in writing the concerns that have been expressed about the permit applications in question and the how the work alluded to in these applications conforms to the approved plan. A. TB26138 - Inlet gas dehydration equipment In the case of this equipment VOG sees essentially no devia- tion from the approved plan. The approved plot plan clearly shows dehydration equipment ( "Dehydrators" ) located at the area VOG intends to install this equipment as shown on the permit application. The only difference between the represen- tation shown on the approved plot and that submitted with the permit application is in the detail of the representations . The plot plan shows an idealized representation of a dehydra- tion unit installation, i . e . , an area devoted to dehydration equipment containing at least one major vessel with an associated contacter. The drawing submitted with the permit application identifies this equipment by name and shows exact details as to its configuration. This does not constitute a major difference any more than an actual representation a compression unit on a permit application showing an engine and compressor with its associated scrubbers and heat exchangers would constitute a major difference from the block representa- tion shown on the approved plan. 7 ) 755 pLOO 5 12 November, 1993 2 B . TB26140 - Inlet gas filter/separators The same argument as that given above can be applied to the permit application for the installation of the inlet gas filter/separator equipment . These filter/separators are inlet gas treating equipment, used to separate entrained liquid and particulate matter from field grade natural gas prior to its entering the process unit . Combined they comprise a "Gas Treating System" , an area for which is clearly shown on the approved plot plan with this being the same area VOG has indicated these to be located on the permit application. Again the difference lies in the detail of the respective representations, which VOG would not construe to constitute a major deviation from the plan. C . TB26139 - Natural gas processing unit In the case of this permit application the difference between what has been approved per the plan and what has been proposed for permitting is mainly in the addition of the product pump and product pump surge tank module . The original approval was for two 20 MMscfd processing units to be located proximal to each other directly north of the existing processing unit and directly west of the main N-S utility rack. VOG is attempting to permit a single 40 MMscfd process unit located in the same area, The major equipment for this is contained on two process skids located proximal to each other with a third area devoted to process liquids pumps and a surge vessel . The surge vessel is needed to provide suction head for these pumps and has been sized based on the safety consideration that, should there be an upset or shutdown downstream of the processing unit sufficient liquid holding capacity be available to contain the high vapor pressure liquids produced at the process unit during the time it takes to properly take the process unit off line. The size of the surge vessel makes it impractical to mount it on one of the process skids . VOG does not feel that the combination of two 20 MMscfd process units into one 40 MMscfd unit of essentially the same total size constitutes a major change from the approved plan. VOG does not consider the addition of the surge vessel/pump module to be significant or unwarranted as the approved plan gives VOG permission to install associated pumps and piping and should give VOG implied permission to install reasonable auxiliary equipment based on process safety considerations . 12 November, 1993 3 As to the moving of the process skids approximately 50 feet north of their positions as shown on the approved plot and the extension of the E-W utility rack to connect with the main N-S rack this was done as the result of maintenance access considerations . VOG does not feel that this constitutes a major deviation from the plan especially in light of Weld County Planning' s recent approval of the permit application for the installation of refrigeration and recompression units . These units have been approved for a location approximately 75 feet south and 30 feet east of their locations as shown on the approved plot plan and this change also alters the configura- tion of their auxiliary utility rack from that shown on the approved plot plan. D. TB26278 - Natural gas liquids treating equipment The approved plant expansion plan lists installation of gas liquids processing equipment, including a contaminated liquid handling system and a butane splitting system, as being covered under the plan. While the approved plot shows locations allocated to the butane splitting equipment it unfortunately fails to identify any areas allotted to the processing of contaminated liquids, in this case liquids containing higher than acceptable concentrations of carbon dioxide that result from the cryogenic recovery and subsequent processing of these liquids . Recongizing this VOG submitted a permit request to install the contaminated liquid processing equipment in the area allocated to the butane splitting equipment on the approved plot plan. Areas unidentified but obviously set aside for liquids processing are shown on the approved plot to the east of the existing fractionator heaters and other liquid processing modules are shown to the south of the existing fractionation plant . The equipment involved is essentially generic for separation processes involving natural gas liquids - staged separation vessels, heaters , heat exchangers, and pumps . VOG has applied merely to substitute one specific process for another, neither involving the use of different equipment, use of equipment on a greater lesser scale, or being inherently more hazardous than the other, and to make minor relocations of some equipment . VOG does not see how this contradicts the plan, which permits the installation of equipment to perform either process, and under which some relocation of equipment has been permitted. The utility rack shown on the application is not shown on the approved plot but VOG feels that the installation of piping, etc . auxiliary to the processes approved is covered under the plan. 12 November, 1993 4 E . TB26330 -- Installation of pipeline pumps and surge tank The plan as approved allows VOG to install liquid handling facilities at the north central area of the facility and to the south of the main storage batteries . VOG feels that relocating this equipment on a smaller scale than is shown on the approved plot plan to the area shown on the permit application does not constitute a major deviation from the approved plan. It should be noted here that the vessel in question is not a storage vessel but is process equipment designed to provide constant suction head to the pipeline pumps . This vessel has been sized to provide a margin of safety for proper shutdown of liquids processing equipment in the event pipeline problems prevent the continuous flow of high vapor pressure liquids from the plant . While the relocation of approved equipment in this case involves a fairly large distance with respect to the approved plot plan VOG will point out that in January 1991 Weld County Planning approved the installation of a recompression unit at the Ft . Lupton facility at a similar distance from the approved location as shown on the plot plan. I have tried to show above that the deviations from the plan, most of them involving discrepancies with the approved plot plan, discussed during our conversation of this morning should not be considered significant deviations from the approved plan for purposes of permit approval . I feel that the arguments related to ideal representation with respect to the approved plot plan and those related to modifications based on engineering and safety considerations are sound. I have cited precedent as to the approval of past permits where I could because these precedents have guided VOG in the making of decisions regarding the selection and placement of equipment at the Ft . Lupton plant . Again I thank you for giving me this opportunity to present the position of VOG in this matter and should you have any questions please do not hesitate to contact me . Sincerely Steven D. Smith Engineer �• ;� i DEPARTMENT OF PLANNING SERVICES N, PHONE(303)353-3845, EXT. 3540 r . -y` �- . , WELD COUNTY ADMINISTRATIVE OFFICES Rt. . 1400 N. 17TH AVENUE GREELEY, COLORADO 80631 .• COLORADO November 8, 1993 Steven D. Smith Vessels Oil and Gas Company Suite 2000 Prudential Plaza 1050 Seventeenth Street Denver, CO 80265 Subject: Special Use Permit 589 , located on property described as part of the SE4 of Section 28, T1N, R67W of the 6th P.M. , Weld County, Colorado. Dear Mr. Smith: Thank you for your August 24 Letter. I have reviewed the Amended Special Review permit file and determined that the conditions of approval have been met for the proposed expansion. Building permits must be applied for and released prior to the start of construction for the proposed approved expansion. Building permits for the installation of equipment requested in the attached unissued building permits and a special review permit (Conquest Oil) for an injection well, have been applied for through our office. The Department of Planning Services' staff has reviewed these applications and determined that this equipment and the new special review permit were not approved as part of the existing special review permit and is considered to be a material deviation from the plans or standards. An amended special review permit will need to be approved and conditions of approval met prior to the release of building permits. Please, call or write me if you have any questions. Respectfully, tO � / 'tgYch et Current Planner KAS/sfr pc: Amended Special Review Permit 589-8 95 /755 pL ooh ESSELS OIL & GAS COMPANY SUITE 2000,PRUDENTIAL PLAZA•1050 SEVENTEENTH STREET•DENVER,COLORADO 90255 303 825.3500 THOMAS G VESSELS,Chairman of the Board THOMASJ VESSE LS,President 24 August 1993 Mr. Kieth Schuett Weld County Planning 1400 North 17th Avenue Greeley, CO 80631 Reference: USR 589 (Amended) Mr. Schuett Pursuant to our telephone conversation of 08/18/93 regarding the amended USR 589, approved 06/15/88, I am requesting that you review your file on USR 589 and grant VOG permission to draw building permits under USR 589. VOG is preparing to begin construction on expansion work at the natural gas processing facility for which the USR was obtained. My review of the VOG files indicates that conditions of USR 589 and the appended Development Standards have been complied with. Notices of compliance with individual conditions or standards should have been communicated to Weld County Planning as these conditions and standards were met. Should this not have occurred VOG is prepared to demonstrate compliance with individual conditions or standards at this time. A good deal of the work VOG undertook to meet the Development Standards under USR 589 involved the independent fire safety review conducted by the Brighton Fire Protection District. We have been in communication with the BFPD on this issue and as regards the construction that is to take place. Fire Protection Officer Robert L. Parker of the BFPD, (303) 659-4101, should be able to answer any questions you might have pertaining to this part of our compliance with the Development Standards or the compatibility of our expansion plans with the conditions of the independent fire safety review. Vessels Oil and Gas is anxious to begin work on this project. Should you need information or wish to inspect the facility please contact me and I will arrange to meet your requirements immediately. Sincerely Steven D. Smith Engineer g3 /755 pLaoa Hello