HomeMy WebLinkAbout20180500.tiffEXHIBIT INVENTORY CONTROL SHEET
Case USR17-0046 - ANADARKO E & P COMPANY, LP, C/O KERR-MCGEE OIL
AND GAS ONSHORE, LP
Exhibit Submitted By
A. Planning Commission
B. Planning Commission
C. Planning Services
D. Applicant
E. Staff
F. Applicant
G. Applicant
H. Applicant
Debbie Schlosser
J. Don Saathoff
K. Applicant
L.
M.
N.
O.
P.
a
R.
S.
T.
U.
V.
W.
Description
Resolution of Recommendation
Summary of Hearing (Minutes dated 2/6/2018)
PowerPoint Presentation
CDPHE Air Permit, dated 2/14/2018
Correspondence, dated 2/15/2018
Correspondence, dated 2/15/2018
Correspondence, dated 2/15/2018
Correspondence, dated 2/15/2018
Correspondence, dated 2/21/2018
Letter from Charles Baum, dated 2/21/2018
PowerPoint Presentation, submitted 2/21/2018
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STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO: 17WE1090
DATE ISSUED: February 5. 2018
ISSUED TO: Cureton Front Range LLC
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Issuance 1
Oil and gas facility. known as the Front Range Gas Plant. located in the SENE, Section 19.T2N,
R64W. in Weld County. Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Equipment
ID
AIRS
Point
Description
Fugitive
002
Equipment leaks from a natural gas plant
HTR2
003
One natural gas fired boiler make, model. serial number to be
determined. Design rated at 20 MM Btu per hour.
HTR3
004
One natural gas fired boiler make, model. serial number to be
determined. Design rated at 11 MM Btu per hour.
Pigging
005
Two pigging receivers. One 8 inch and one 6 inch.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO
AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1 YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days
of the latter of commencement of operation or issuance of this permit, by submitting a
Notice of Startup form to the Division. The Notice of Startup form may be downloaded online
at https://www.colorado.gov/pacific/cdphe/other-air-permitting-notices, Failure to notify the
Division of startup of the permitted source is a violation of Air Quality Control Commission
(AQCC) Regulation No 3, Part B, Section III G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance
with the conditions. Failure to demonstrate compliance within 180 days may result in revocation
of the permit. (Reference Regulation No, 3, Part B, Ill G 2).
AIRS ID 123 9F67
Page 1 of 7
3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i)
does not commence construction/modification or operation of this source within 18 months after
either, the date of issuance of this construction permit or the date on which such construction or
activity was scheduled to commence as set forth in the permit application associated with this
permit (ii) discontinues construction for a period of eighteen months or more; (iii) does not
complete construction within a reasonable time of the estimated completion date. The Division
may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference:
Regulation No_ 3. Part B. III.F 4.)
4. The operator shall complete all initial compliance testing and sampling as required in this permit
and submit the results to the Division as part of the self -certification process (Reference:
Regulation No. 3, Part B. Section III E.)
5. The operator shall retain the permit final authorization letter issued by the Division. after
completion of self -certification. with the most current construction permit. This construction permit
alone does not provide final authority for the operation of this source.
6. Point 003, 004: The manufacturer, model number and serial number of the subject equipment
must be provided to the Division within one hundred and eighty days (180) after
commencement of operation or issuance of this permit, whichever is later. (Reference:
Regulation Number 3, Part B, III.G.2.)
EMISSION LIMITATIONS AND RECORDS
7 Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3. Part B. Section II A.4)
Annual Limits:
Equipment
ID
AIRS
Point
Tons per Year
Emission Type
voc
NOx
CO
Fugitive
002
7.0
--
--
Fugitive
HTR2
003
--
4.4
7.3
Point
HTR3
004
--
2.4
4.1
Point
Pigging
005
4.1
--
--
Point
See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Annual records of the actual emission rates shall be maintained by the owner or operator and
made available to the Division for inspection upon request.
8. Point 002: The operator shall calculate actual emissions from this emissions point based on
representative component counts for the facility with the most recent gas and liquids analyses. as
required in the Compliance Testing and Sampling section of this permit. The operator shall
maintain records of the results of component counts and sampling events used to calculate actual
emissions and the dates that these counts and events were completed. These records shall be
provided to the Division upon request_
PROCESS LIMITATIONS AND RECORDS
9 These sources must be limited to the following maximum consumption. processing and/or
operational rates as listed below. Annual records of the actual process rate must be maintained
by the applicant and made available to the Division for inspection upon request (Reference:
Regulation Number 3. Part B. II A.4)
AIRS ID: 123 9F67 Page 2 of 7
Process/Consumption Limits
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
HTR2
003
Consumption of natural gas
174.2 MM scf
HTR3
004
Consumption of natural gas
95.8 MM scf
Pigging
005
Depressurization events
1095 events per pig receiver
The owner or operator shall monitor annual process parameters based on the calendar year.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. Point 002, 003, 004, 005: Visible emissions shall not exceed twenty percent (20%) opacity
during normal operation of the source. During periods of startup, process modification, or
adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six
minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7,
Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions_ (Reference: Regulation No. 1,
Section II A 1. & 4.)
11. Point 002, 003, 004, 005: This source is subject to the odor requirements of Regulation No. 2.
(State only enforceable)
12. Point 003, 004: This source is subject to the New Source Performance Standards requirements
of Regulation Number 6, Part A, Subpart Dc, Standards of Performance for Small Industrial -
Commercial -Institutional Steam Generating Units.
13. Point 003, 004: This source is located in an ozone non -attainment or attainment -maintenance
area and subject to the Reasonably Available Control Technology (RACT) requirements of
Regulation Number 3, Part B, III.D.2. The use of a low N0x burner is considered to be RACT for
this source.
14. Point 002: This source is subject to Regulation No. 7, Section XII.G Gas -processing plants
located in the 8 -hour Ozone Control Area (State Only: or any specific Ozone nonattainment or
Attainment/Maintenance Area) shall comply with requirements of this Section XII.G . as well as
the requirements of Sections XII.B., XII.C.1.a.. XII.C.1.b., XII.H., and XVI
OPERATING & MAINTENANCE REQUIREMENTS
15. Point 002, 003, 004. 005: This source is not required to follow a Division -approved operating and
maintenance plan.
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. Point 002: Within one hundred and eighty days (180) of the latter of commencement of
operation or issuance of this permit, the owner or operator shall complete the initial extended gas
analysis of gas samples that are representative of volatile organic compound (VOC) and
hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas
analysis shall be used in the compliance demonstration as required in the Emission Limits and
Records section of this permit. The operator shall submit the results of the gas analysis and
emission calculations to the Division as part of the self -certification process to ensure compliance
with emissions limits.
17 Point 002: Within one hundred and eighty days (180) of the latter of commencement of
operation or issuance of this permit, the operator shall complete a hard count of components at
the source and establish the number of components that are operated in "heavy liquid service",
"light liquid service". "water/oil service" and "gas service". The operator shall submit the results to
the Division as part of the self -certification process to ensure compliance with emissions limits
AIRS ID 123 9F67 Page 3 of 7
Periodic Testing Requirements
18. Point 002: On an annual basis. the owner or operator shall complete an extended gas analysis
of gas samples that are representative of volatile organic compounds (VOC) and hazardous air
pollutants (HAP) that may be released as fugitive emissions. This extended gas analyses shall
be used in the compliance demonstration as required in the Emission Limits and Records section
of this permit.
ADDITIONAL REQUIREMENTS
19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3. Part
A.IIC)
a. Annually by April 30'" whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO. per year. a change in
annual actual emissions of one (1) ton per year or more or five percent. whichever is
greater. above the level reported on the last APEN: or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted, or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less. above the
level reported on the last APEN submitted to the Division.
Whenever there is a change in the owner or operator of any facility, process, or activity;
or
c. Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment: or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No 3. Part B. Section II.B upon a request for transfer of ownership and the submittal
of a revised APEN and the required fee_
21. If this permit specifically states that final authorization has been granted. then the remainder of
this condition is not applicable. Otherwise. the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation No 3. Part B. Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all points
has been reviewed and approved by the Division, it will provide written documentation of such
final authorization. Details for obtaining final authorization to operate are located in the
Requirements to Self -Certify for Final Authorization section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information supplied by
the owner or operator and is conditioned upon conduct of the activity. or construction, installation
and operation of the source, in accordance with this information and with representations made
AIRS ID 123 9F67 Page 4 of 7
by the owner or operator or owner or operator's agents. It is valid only for the equipment and
operations or activity specifically identified on the permit.
23. Unless specifically stated otherwise, the general and specific conditions contained in this permit
have been determined by the APCD to be necessary to assure compliance with the provisions of
Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and
upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked
at any time prior to self -certification and final authorization by the Air Pollution Control Division
(APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air
Quality Control Commission (AQCC), including failure to meet any express term or condition of
the permit. If the Division denies a permit, conditions imposed upon a permit are contested by
the owner or operator, or the Division revokes a permit, the owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division in
writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and
Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Kirk Bear
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Cureton Front Range LLC
AIRS ID: 123 9F67
Page 5of7
Notes to Permit Holder at the time of this permit issuance.
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 3, Part A. Section VI.B.)
2) The emission limits contained in this permit are based on the consumption rates requested in the
permit application. These limits may be revised upon request of the owner or operator providing
there is no exceedance of any specific emission control regulation or any ambient air quality
standard A revised air pollution emission notice (APEN) and complete application form must be
submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II. Subpart E. Affirmative Defense
Provision for Excess Emissions During Malfunctions The owner or operator shall notify the Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit as
soon as possible, but no later than noon of the next working day, followed by written notice to the Division
addressing all of the criteria set forth in Part II. E.1. of the Common Provisions Regulation. See:
https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
002
Benzene
71432
424
64
Toluene
108883
411
60
Ethylbenzene
100414
366
46
Xylenes
1330207
377
49
n -Hexane
110543
645
135
003
n -Hexane
110543
314
NA
Note. The emission levels for Point 002 are based on the emission factors from Table 2-4 The emission levels
for Point 003 are based on emission factors from AP -42 1 4-1.2.3.
TOC Emission Factors (kg/hr-component):
Component
Gas Service
Heavy Oil
Light Oil
Water/OilService
Connectors
2.0E-04
7.5E-06
2.1E-04
1.1E-04
Flanges
3.9E-04
3.9E-07
1.1E-04
2.9E-06
Open-ended Lines
2.0E-03
1 4E-04
1.4E-03
2.5E-04
Pump Seals
2.4E-03
NA
1.3E-02
2 4E-05
Valves
4 5E-03
8.4E-06
2.5E-03
9.8E-05
Other
8.8E-03
3.2E-05
7.5E-03
1.4E-02
AIRS ID: 123 9F67
Page 6 of 7
Source. EPA -453/R95-017
Compliance with emissions limits in this permit will be demonstrated by using the TOC emission
factors listed in the table above with representative component counts. multiplied by the VOC content
from the most recent gas and liquids analyses.
5) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the
most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit For any questions regarding a specific expiration date call the Division at
(303)-692-3150.
6) This source is subject to 40 CFR. Part 60. Subpart 0000a — Standards of Performance for Crude Oil
and Natural Gas Facilities for which Construction. Modification. or Reconstruction Commenced after
September 18, 2015 (See June 3, 2016 Federal Register posting — effective August 2, 2016.) This
rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6.
A copy of the complete subpart is available at the Office of the Federal Register website
at: https://www.federalregister.gov/documents/2016/06/03/2016-11971/oil-and-natural-qas-sector-
emission-standards-for-new-reconstructed-and-modified-sources
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Minor Source
NANSR
Minor Source
8) Full text of the Title 40. Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below.
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A — Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A — Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63 599
Subpart A — Subpart Z
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
9) A self certification form and guidance on how to self -certify compliance as required by this permit may
be obtained online at: http://www.colorado.qov/pacific/cdphe/air-permit-self-certification
AIRS ID 123 9F67
Page 7 of 7
Tisa Juanicorena
From:
Sent:
To:
Subject:
Chris Gathman
Thursday, February 15, 2018 5:11 PM
Tisa Juanicorena
FW: Anadarco hearing 2/6/18 - USR17-0046 exhibit
From: Elizabeth Relford
Sent: Wednesday, February 14, 2018 10:36 AM
To: Chris Gathman <cgathman@weldgov.com>
Subject: FW: Anadarco hearing 2/6/18
Chris,
Here is the most recent correspondence I had with Mr. Neal.
Thanks,
Elizabeth
Elizabeth Relford
Deputy Director
Weld County Public Works
1111 H Street
PO Box 758
Greeley, CO 80632-0758
Email: erelford@co.weld.co.us
Office: (970) 400- 3748
Mobile: (970) 673-5836
Web: http://www.co.weld.co.us
Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for
the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise
protected from disclosure. If you have received this communication in error, please immediately notify sender by return
e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the
contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited.
From: Elizabeth Relford
Sent: Monday, February 12, 2018 8:54 AM
To: Dennis Neal <nealdennis59@gmail.com>
Cc: Dawn Anderson (dranderson@weldgov.com) <dranderson@weldgov.com>; Evan Pinkham
<epinkham@weldgov.com>; Mike Livengood <mlivengood@weldgov.com>; Curtis Hall <chall@weldgov.com>; Jay
1
McDonald <imcdonald@weldgov.com>; Tom Parko Jr. <tparko@weldgov.com>
Subject: RE: Anadarco hearing 2/6/18
Mr. Neal,
I told you I would reach back out to after the county collected traffic counts on WCR 18; therefore, I wanted to let you
know the three-day counts came back at 370 trips per day with 32% truck traffic. When compared to other gravel roads
in the county, we have some with roads 1,000 trips per day and 70% truck traffic, which remain gravel. We recognize
this does change the maintenance responsibility the county will have to comply with for dust mitigation, which we will
bring up to the Commissioners at the hearing.
Thanks,
Elizabeth
Elizabeth Relford
Deputy Director
Weld County Public Works
1111 H Street
PO Box 758
Greeley, CO 80632-0758
Email: erelford@co.weld.co.us
Office: (970) 400- 3748
Mobile: (970) 673-5836
Web: http://www.co.weld.co.us
Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for
the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise
protected from disclosure. If you have received this communication in error, please immediately notify sender by return
e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the
contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited.
From: Dennis Neal [mailto:nealdennis59@gmail.com]
Sent: Thursday, February 1, 2018 10:12 AM
To: Elizabeth Relford <erelford@weldgov.com>
Subject: Anadarco hearing 2/6/18
Hello Elizabeth; After I e -mailed copies of all the truck traffic on WCR 18 to Chris Gathman on January 18, I received a
phone call from Reed at Anadarco. Reed informed me that Anadarco has the right to do what they are doing. I asked
about the belly dump trucks and, Reed said no they are not agriculture or legal. I asked about the hay bale trucks and,
Reed once again said they are not agricultural or legal either. We discussed the issue further and Reed stated that they
would not be there much longer. I asked if he could tell me how much longer, and how many more trucks. Reed said he
would find out and get back to me. January 25, Reed called me back and said he could not tell me how much longer or
how many trucks to expect. I told Reed that they were running hundreds of trucks per day before and, asked him how
many trucks we can expect per day? Reed told me that they have no idea.
My question is How many trucks will travel on this dirt road?, in total?, daily? How can Weld county make a
decision without the traffic volume?
2
Thank You! Dennis Neal 303-775-9297
3
Tisa Juanicorena
From:
Sent:
To:
Subject:
Dear Tisa,
Chris Gathman
Thursday, February 15, 2018 5:10 PM
Tisa Juanicorena
FW: Anadarco photos
Here is some correspondence for USR17-0046. I realize this did not get into the record for the Planning Commission
hearing. I have a couple of more e -mails to forward.
Regards,
Chris Gathman
Planner III
Weld County Department of Planning Services
1555 N. 17th Avenue
tel: 970-400-3537
fax: 970-400-4098
V
Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for
the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise
protected from disclosure. If you have received this communication in error, please immediately notify sender by return
e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the
contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited.
From: Keiser, Nathan[mailto:Nathan.Keiser@anadarko.com]
Sent: Thursday, January 18, 2018 12:30 PM
To: Chris Gathman <cgathman@weldgov.com>
Subject: RE: Anadarco photos
Chris,
Thanks for passing along. For your information, we notified ALL individuals who signed our sign -in sheet at our
community meeting of the February 6th hearing via a phone call.
We did not notify those who opted not to sign the sheet. This included Dennis Neal.
1
The use of the mud farm has pretty much stopped minus the small amount of traffic needed to cultivate the land and
minor hydrovac trucks as shown in the pictures. Even the numbers supplied by our traffic study show that this does not
create a burden on the surrounding community.
The mud farm was permitted almost 4 years ago with the COGCC.
According to the property portal Mr. Neal didn't purchase the property until well after this use was permitted.
Also, a colleague spoke with all people who signed the sheet and almost every one of them mentioned how they were
happy with the level of traffic on the roads.
You can do what you'd like with this info, but we have no obligation to cease use of the mud farm since it's not
associated with a land -use case and permitted by the State.
Do you plan on responding to Mr. Neal?
If not I may call him and tell him the same information.
Thanks Chris!
Nathan
From: Chris Gathman [mailto:cgathman@weldgov.com]
Sent: Thursday, January 18, 2018 12:03 PM
To: Keiser, Nathan <Nathan.Keiser@anadarko.com>
Subject: FW: Anadarco photos
One more e-mail. I am forwarding to PW.
From: Dennis Neal [mailto:nealdennis59@gmail.com]
Sent: Thursday, January 18, 2018 11:46 AM
To: Chris Gathman <cgathman@weldgov.com>
Subject: Anadarco photos
Click here for Anadarko's Electronic Mail Disclaimer
2
Tisa Juanicorena
From:
Sent:
To:
Subject:
Chris Gathman
Thursday, February 15, 2018 5:10 PM
Tisa Juanicorena
FW: USR17-0046 Traffic Study - USR17-0046 exhibit
From: Keiser, Nathan[mailto:Nathan.Keiser@anadarko.com]
Sent: Friday, January 26, 2018 9:33 AM
To: Evan Pinkham <epinkham@weldgov.com>
Cc: Chris Gathman <cgathman@weldgov.com>
Subject: RE: USR17-0046 Traffic Study
Good morning Evan,
Here is the response from our traffic contractor in italics. Is this sufficient or do you need something additional?
It looks like there are three comments from the County:
• Speed limit we used in model was assumed to be 30 mph and county is stating all their roads are 55 mph
o We can certainly update the synchro models to reflect the correct speed limit for all roadways located
inside the study area. This update will not affect the level of service documentation we have in the report
as speed in Sycnhro is only used to determine timing and offsets between signalized intersections. The
study intersections in our analysis are all stop controlled, therefore, the delay reported would not be
affected by this model update.
• We used an estimated growth rate of 1% and county is stating they have estimated 6.2% growth rate.
o We can apply this revised growth factor to our collected traffic counts and revise the existing and future
scenarios as needed. This increase in growth rate would add approximately 3 to 5 vehicles to an
intersection approach depending on the existing volume that was collected. Overall, this update to the
growth rate would increase the LOS for each intersection, however the overall reporting would be the
same - very minor change in LOS for all study intersection.
• Show analysis for site driveways
o We have included the approach delay for the site driveways as part of the future traffic analysis.
In short, I don't anticipate updating these assumptions relative to comments 1 and 2 will have a substantive impact on
the conclusions — i.e., the impact is still very minor. The third comment from the County is a bit confusing, as we had
included that analysis already - these are shown in Tables 6, 7 and 8.
From: Evan Pinkham mailto:epinkham@weldgov.com]
Sent: Thursday, January 25, 2018 11:55 AM
To: Keiser, Nathan <Nathan.Keiser@anadarko.com>
Cc: Chris Gathman <cgathman@weldgov.com>
Subject: USR17-0046 Traffic Study
Nathan,
We were going through the traffic study, and had some issues that we wanted to have resolved prior to the Planning
1
Commission hearing. Below are the comments related to the study. Please send me the updated study that resolves this
issues.
The traffic review study for the Strear Farms Stockpile Area, prepared by Arcadis for Anadarko Petroleum Corporation,
was reviewed on 11-29-17 and a few questions arose. First, on page 2, WCR 18 and WCR 21 are both assumed to be 30
mph roadways. All Weld County roads are 55 mph unless clearly signed otherwise. If WCR 18 and WCR 21 are assumed
to be 55 mph, how does that affect the Traffic Impact Study and the Level of Service at the respective intersections that
were analyzed? Second, page 6 states that an annual growth rate of 1% was used to forecast future background
traffic. According to the 2035 Transportation Plan, which can be found on the Weld County Public Works website, this
facility is located in Subarea 6 which has an annual growth rate of 6.2%. If 6.2% is used as the growth rate, how does
this affect the Traffic Impact Study and the Level of Service at the respective intersections that were analyzed? Thirdly,
the traffic impact study should consider the entrances into and out of the site and how they are preforming with the
anticipated traffic.
Thanks,
Evan
Evan Pinkham
Development Review Planner
Weld County Public Works
1111 H Street, P.O. Box 758
Greeley, CO 80632
(970)400-3727
Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for
the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise
protected from disclosure. If you have received this communication in error, please immediately notify sender by return
e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the
contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited.
Click here for Anadarko's Electronic Mail Disclaimer
2
Tisa Juanicorena
Dm:
.,, nt:
To:
Subject:
Chris Gathman
Thursday, February 15, 2018 5:16 PM
Tisa Juanicorena
FW: USR17-0046 - a couple of questions and heads up on hearing schedule -
USR17-0046 exhibit
From: Keiser, Nathan[mailto:Nathan.Keiser@anadarko.com]
Sent: Monday, January 29, 2018 2:27 PM
To: Chris Gathman <cgathman@weldgov.com>
Subject: RE: USR17-0046 - a couple of questions and heads up on hearing schedule
This was your response from September after the community meeting (below in italics). Just checking to see if there
is anything else that you are proposing (beyond what is below in italics) since September — We have greatly reduced
traffic on the location — We have also been applying a lot of water to the roads since the community expressed the
opinion that mag chloride was not preferred. We may evaluate alternating mag/water applications since Mr. Neal
prefers the mag. Please note that even though mud farm and hauling has been restricted as night, there is a large
oil and gas production facility on the location and it may be required to have trucks at the facility during evening
hours. This is purely for safety reasons.
2) Some previous correspondence (September 2017) indicated that the mud farm had met its limit and would not be
accepting tailings for the next year. Just verifying that this means - does this mean no tailings will be accepted until
2019? We have stopped hauling in drill cuttings. I will have more of a firm date tomorrow on when we expect to be
bringing more in though. Also, there are a few daily hydrovac trucks visiting the site. This helps keep dust down on
the site by keeping some moisture at the location. Without this the farm would be dusty.
3) Did you happen to contact Dennis Neal? We have spoken with him twice in the past week. He is mostly upset that
we have not been asked to pave a road, when he was asked to pave a road on one of his development projects in
the County. I'm not sure what or where this is but he will be unhappy no matter what.
4) There are 4 cases on the agenda — the 1st two cases are not mine (but I see no SPO objections) — these will be heard
1st. Then USR17-0065 (proposed gas plant) — we have received a couple of objections. Then USR17-0046. FYI: I have
been informed that Mr. Neal may have hired an attorney.
From: Keiser, Nathan
Sent: Monday, January 29, 2018 10:02 AM
To: 'Chris Gathman' <cgathman@weldgov.com>
Subject: RE: USR17-0046 - a couple of questions and heads up on hearing schedule
Good morning Chris,
I see you were burning the midnight oil and working on Sunday! I enjoy doing that sometimes since the office is so
quiet.
I'll have these answers for you soon. Working on getting them now. Also, we have communicated multiple times with
Ir. Neal. I'll provide more clarity around that when I responds to the other questions.
Thanks Chris!
1
1) This was your response from September after the community meeting (below in italics). Just checking to see if
there is anything else that you are proposing (beyond what is below in italics) since September.
2) Some previous correspondence (September 2017) indicated that the mud farm had met its limit and would not be
accepting tailings for the next year. Just verifying that this means - does this mean no tailings will be accepted until
2019?
3) Did you happen to contact Dennis Neal?
4) There are 4 cases on the agenda — the 1st two cases are not mine (but I see no SPO objections) — these will be heard
1st. Then USR17-0065 (proposed gas plant) — we have received a couple of objections. Then USR17-0046. FYI: I
have been informed that Mr. Neal may have hired an attorney.
From: Chris Gathman [mailto:cgathman@weldgov.com]
Sent: Sunday, January 28, 2018 10:56 AM
To: Keiser, Nathan <Nathan.Keiser@anadarko.com>
Subject: RE: USR17-0046 - a couple of questions and heads up on hearing schedule
Nathan,
Staff recommendation has been drafted and is being reviewed by staff — I anticipate having to you by Monday or
Tuesday of this week. I had a few questions/clarifications:
1) This was your response from September after the community meeting (below in italics). Just checking to see if the --
is anything else that you are proposing (beyond what is below in italics) since September.
2) Some previous correspondence (September 2017) indicated that the mud farm had met its limit and would not be
accepting tailings for the next year. Just verifying that this means - does this mean no tailings will be accepted until
2019?
3) Did you happen to contact Dennis Neal?
4) There are 4 cases on the agenda — the 1st two cases are not mine (but I see no SPO objections) — these will be heard
1st. Then USR17-0065 (proposed gas plant) — we have received a couple of objections. Then USR17-0046. FYI: I have
been informed that Mr. Neal may have hired an attorney.
Thanks,
Chris Gathman
Planner III
Weld County Department of Planning Services
1555 N. 17th Avenue
tel: 970-400-3537
fax: 970-400-4098
2
Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for
the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise
protected from disclosure. If you have received this communication in error, please immediately notify sender by return
nail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the
ntents of this communication or any attachments by anyone other than the named recipient is strictly prohibited.
as an FYI we did have the community meeting and are working through the concerns that were brought up during the
meeting.
Some of the items that have already been set into motion are:
.
.
•
.
.
Putting dust suppression on both County Roads and roads inside the facility
Limiting soil hauling during daylight hours
Closing and locking facility during the evening
Signs on property along county road (see example)
Provided response line information to residents (see example)
From: Keiser, Nathan[mailto:Nathan.Keiser@anadarko.com]
Sent: Thursday, January 18, 2018 12:30 PM
To: Chris Gathman <cgathman@weldgov.com>
Subject: RE: Anadarco photos
rhris,
Thanks for passing along. For your information, we notified ALL individuals who signed our sign -in sheet at our
community meeting of the February 6th hearing via a phone call.
We did not notify those who opted not to sign the sheet. This included Dennis Neal.
The use of the mud farm has pretty much stopped minus the small amount of traffic needed to cultivate the land and
minor hydrovac trucks as shown in the pictures. Even the numbers supplied by our traffic study show that this does not
create a burden on the surrounding community.
The mud farm was permitted almost 4 years ago with the COGCC.
According to the property portal Mr. Neal didn't purchase the property until well after this use was permitted.
Also, a colleague spoke with all people who signed the sheet and almost every one of them mentioned how they were
happy with the level of traffic on the roads.
You can do what you'd like with this info, but we have no obligation to cease use of the mud farm since it's not
associated with a land -use case and permitted by the State.
Do you plan on responding to Mr. Neal?
'r lot I may call him and tell him the same information.
Thanks Chris!
3
Nathan
From: Chris Gathman [mailto:cgathman@weldgov.com]
Sent: Thursday, January 18, 2018 12:03 PM
To: Keiser, Nathan <Nathan.Keiser@anadarko.com>
Subject: FW: Anadarco photos
One more e-mail. I am forwarding to PW.
From: Dennis Neal [mailto:nealdennis59@gmail.com]
Sent: Thursday, January 18, 2018 11:46 AM
To: Chris Gathman <cgathman@weldgov.com>
Subject: Anadarco photos
Click here for Anadarko's Electronic Mail Disclaimer
4
•
Tisa Juanicorena
Sent:
To:
Cc:
Subject:
FYI. For this morning's hearing.
Chris Gathman
Wednesday, February 21, 2018 7:27 AM
Tisa Juanicorena
Ben Frissell; Bob Choate; Esther Gesick; Keiser, Nathan; Evan Pinkham; Dawn Anderson
FW: USR17-0046 Strear Farm Soil Stockpiling/Hauling/Hay Storage Operation
From: Debbie Schlosser [mailto:foothil4@aol.com]
Sent: Tuesday, February 20, 2018 10:01 PM
To: Karla Ford <kford@weldgov.com>; Mike Freeman <mfreeman@weldgov.com>; Julie Cozad <jcozad@weldgov.com>;
Barbara Kirkmeyer <bkirkmeyer@weldgov.com>; Sean Conway <sconway@weldgov.com>; Steve Moreno
<smoreno@weldgov.com>; Troy Swain <tswain@weldgov.com>; Chris Gathman <cgathman@weldgov.com>
Subject: USR17-0046 Strear Farm Soil Stockpiling/Hauling/Hay Storage Operation
Date: February 20, 2018
To: Weld County Board of Commissioners
From: Scott and Debbie Schlosser, 10624 County Road 18, Fort Lupton, CO 970-532-3253
Re: Docket #2018-12, PL2523 - A Site Specific Development Plan and Use by Special Review
Permit, USR17-0046.
ear Commissioners:
Due to an emergent illness in our family, resulting in us having to travel out of state, we will be unable to attend
the Board of Commissioners meeting tomorrow, February 21, 2018, where we had hoped to speak against Use
by Special Review Permit USR17-0046. We did attend the Planning Commission meeting held on February 6,
2018 for over three hours, but due to the length of discussions on other items on the agenda prior to USR17-
0046, as well as a previously scheduled doctor's appointment, we found ourselves unable to voice our concerns
during that meeting.
Therefore, we would like to respectfully request that the Weld County Board of Commissioners vote NO on the
Use by Special Review permit for the Strear Farm Soil stockpiling/hauling, hay storage operation, and drill
cutting spreading operation for the following reasons:
1. Tremendous increase in noise and dust from dirt stockpiling operation. Last August, during the height of
Anadarko's UNPERMITTED dirt hauling operation, the noise level and dust became completely
unbearable. How does the county and Anadarko plan on mitigating this? Who will be responsible for
maintaining the deterioration of the road caused by such a large number of trucks? Who will oversee the
operation of the staging area for the dirt operation since Anadrako uses contracted truckers (i.e.,
compliance with ingress/egress, ensuring covered loads, adherence to posted speed limit, jake brake
compliance, etc.)?
2. We do not believe this facility is in keeping with the Weld County Agricultural Zone District. This
operation in no way constitutes anything resembling AGRICULTURAL USE, other than the storage of
hay, which will not be used for livestock but only for use at oil well drilling sites (INDUSTRIAL USE).
We have grave concerns about the potential for an uncontrolled fire from this enormous hay stockpiling
i
area (which is already in place, even though it has not been permitted and, in fact, has been in violation
since June 21, 2017 (Zoning Violation Case #7CV 17-00128).
3. Potential for contamination of the water table from chemicals contained in drill cuttings, including
uranium -238 and radium -226, as well as radioactive isotopes uranium -234, thorium -230, lead -210 and
polonium -210. Since our property must rely on well water, we are very concerned about the potential
future impact this may have on our only water source.
Thank you for your time and consideration in this matter.
Sincerely,
Scott and Debbie Schlosser
2
February 21, 2018
To whom it may concern,
I am writing this memo to confirm my conversation with a neighbor whom I believe plans to
attend a meeting concerning upgrading (paving) Roads 18 and 21.
Back in 1970, my wife Marian (deceased) and I purchased our present property at a reasonable
price based upon the area's poor conditions and the need of a handyman to do allot of work to make my
property livable. J. L. Sears Reality, Fort Lupton, was the business we dealt with in the purchase of this
8519 WCR property. There were no trees, no driveways and many other things expected with any
property. The previous owners were Bill and Anne Steele, whom, while residing here were constantly
on the County's back to improve (pave) the roads against being rough and dusty as well as be safer to
drive on.
Soon after the contract was completed, Mr. Sears (deceased) as well as Anne Steele both told us
that appropriations were approved to have roads 18, 20 and 21 paved within a period of eight (8) years.
That would be about 1978 (30 years ago) and nothing has been done except road 20 was paved two and
a half years ago. I had my two driveways sloped to provide a level access between a paved approach
between the road and my home with a trust in the County to live up to what we were told.
At my present age (84), I am not expecting to see any progress in my lifetime, as housing
developments are a priority, being paved due to dense populated area and more tax payers available to
support the County. We have, however, added a few homes, scattered here and there, but not enough
to convince someone to do something to make things safer and cleaner to drive on. Anadarko has also
talked with someone in the County concerning the poor conditions for their employees and equipment
safety. The geologist who approached the County was (I believe) Rhead Cannon, who's office phone
number is 720-929-6858. I am sure he or another representative would support us in the effort to have
the County get the lead out and make an effort to get the roads cleaner and safer. I nearly lost my life a
year ago at intersection 18 and 21 due to high overgrowth and un-maintained intersections. (They cut
the tall grass down the day after the accident.)
Guess I have said enough about the past and would love to see a brighter, cleaner and safer
means of travel on these poor road conditions, soon before I leave this world. The grading
maintenance is done well, but it lasts only a couple days and when it rains, they are very slippery, rutty
and dangerous, especially where treated for dust. I hope this memo may help in getting things done
sooner to make the area a better and safer place to live in.
Sincerely
Charles M. Baum
Strear Farms - USR Application
PLEASE SILENCE CELL PHONES
ANADARKO
ROCKIES TEAM
Strear Farms - USR Application
PLEASESILENCE CELL PHONE
Strear Farms - History
• Purchased in 2011 by Anadarko for proposed drilling
operations, E&P waste management, and agricultural
operations
ANADARKO PETROLEUM CORPORATION
Strear Farms - Multi Use Location
to Mud Farm - Permitted by COGCC in
2014 - Centralized E&P Waste
Management Facility
to Accepts water -based bentonitic drill
cuttings from drilling activities
b Hydrovac mud for dust suppression
S
Mud not impacted by hydrocarbons
` Agricultural Use - In accordance with
dry -land farming practices - Wheat,
dry -land grasses, and sunflowers
w Intermittent Use
ANADARKO PETROLEUM CORPORATION
Strear Farms - Multi Use Location
is Existing Wells and Production
Facilities on site for Anadarko
operated wells
to Existing Wells and Production
Facilities on site for wells
owned by other operators
ANADARKO PETRO
LEUI'I CORPORATION
Strear Farms - Multi Use Location (continued)
dSoil and Hay Bale Stockpile
Area - Used to store material
for construction of drill pads
'Multiple locations throughout
the County to traffic impacts to
local municipalities
e Intermittent Use
Soil and Hay Bale
Stockpile Location
ANADARKO PETROLEUM CORPORATION
Operational Path Forward for Traffic Mitigation
to Community Notifications -During times
when heavier traffic is expected notices
will be sent to surrounding community.
Similar approach to drilling activities.
Proactive Dust Suppression -Application
of mag chloride and/or water prior to
usage and then continuous applications
Minimal use of Mud Farm during 2018
to Limit hours of operation from 7 am to 6
pm
is Split Use - During times when traffic is
heavier at the mud farm, efforts will be
made to use soil and hay bales from
alternative locations.
Continued conversations with Mike
Livengood
ANADARKO PETROLEUM CORPORATION
Questions?
7
Hello