HomeMy WebLinkAbout20182138.tiffINVENTORY OF ITEMS FOR CONSIDERATION
Applicant Juan Ignacio Cruz
Case Number USRI8-0032
Submitted or Prepared
Prior to
Hearing
At
Hearing
1
Surrounding Property
Owner Letter - Bauer - dated July 2, 2018
2
Surrounding Property
Owner Letter
•
- Loose - dated July 2, 2018
X
I hereby certify that the one item identified herein was submitted to the Department of Planning Services
at or prior to the scheduled Planning Commissioners hearing.
Angela SAyder, Planner
July 1, 2018
Case# US R1&0032
Juan Ignacio Cruz; df o Centennial Tools and Services, LIC
Considerations regarding the request for USR18-0032
Compatibility concerns
The industrial business is not consistent with the rural community that surrounds this property.
There is a minimum of 6 residential properties directly adjacent to the proposed site and no
consideration has been made by the property owner to the area surrounding his property.
Please refer to the map of the property and surrounding areas. This was called out in the USR
review (#4. Surround Uses) and the response clearly states that the surrounding parcels of land
have homes, and outbuildings. The proposed USR is for a company to service oil and gas
companies in the area with expectations of 70 heavy truck roundtrips per day for this property.
This is absolutely not consistent with the rural community surrounding the property.
The noise that has been ongoing with pipe loading and unloading has significantly and
negatively affected thequality of life of the surrounding properties. I work from home part of
the time and can no longer have my windows open during the day to make or take calls due to
the ongoing noise coming from the property. This not only occurs during the week but also on
Saturday's and Sundays.
The road that runs in front of our properties is a two-lane road, with noshoulder, that has
already been damaged significantly from the applicant's trucks turning in to the property. The
road is simply not capable of handling the volume of semi -trucks turning in to the residence.
The application also specifies an increase in allowable noise levels to a commercial zoning
standard. The surrounding residents currently enjoy noise levels that are low to non-existent.
This increase in noise allowance is not compatible with the surrounding residential homes.
Traffic Concerns
As stated in the Traffic Narrative for Centennial Tools & Services- Owner estimated 60 trips/day,
with 95% of the traffic associated to the North towards US 34. It also states that a maximum of
9 vehicles are projected to turn left in to the site from the North. If 60 trips per day are
expected, it is not realistic that only 9 will return heading South, resulting in a left turn in to the
property. County Road 53 turning in to the residence is a two-lane road (one lane each
direction) and has no turn lane in to the residence. This is a significant safety concern for the
neighboring properties and traffic flow for a road with residential, agricultural properties lining
both sides of the road.
Safety Concerns
The applicant provided hours of operation for Monday thru Friday from 6 00AM, to 7:00PM.
There are 6 school bus stops within a quarter mile each direction of the applicant's property,
and multiple other school bus traffic that travels past the site to pick up and drop off children
south of the proposed site. Either at pickup or drop off the children on the bus will have to cross
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the road to get to their homes. We have witnessed numerous incidents when other traffic gets
so frustrated with the significant wait time while one of these trucks is trying to turn into or off
the roadway that they speed around the truck while honking the horn in frustration. With the
amount of semi traffic expected, this is a significant safety concern for the children getting on
and off the bus during proposed operating times. In addition, because this is the main road that
goes in to Kersey, many high school students and families travel this road on their way to school
and home. It is important to note that this road is a narrow two lane paved road. It DOES NOT
have improved or paved shoulders along the road.
Accountability
There have been multiple violations and reports already made on this property owner for
operating a business without a valid USR, and failing to submit for permits until complaints were
made. If the owner has consistently failed to comply with Weld County requirements; how can
he be trusted to comply with requirements following approval of a USR.
USR Need- Not needed
Centennial Tools & Services is currently operating in a location that is properly zoned for
commercial and industrial use in Kersey. There are over 15 Semi Trucks currently parked in a
lot behind their commercial building at this time in addition to several trucks and trailers that
are currently stored at the applicant's residence.
Industrial sites are available in the area where Centennial Tools & Services operates as close as
Highway 34. Having a USR and adding a commercial property surrounded by residential and
agricultural residences is not necessary. There is no need to add a business of this type to the
existing area.
Environmental Concerns
There is limited information provided in the responses of the Questionnaire regarding fluid
transfers on the property from Hydro Vacs and Vacuum Trailers which are operated and in use
with Centennial Tools and Services. Because this property is surrounded by residential and
agricultural properties this is a significant concern for the water and land at and around the
property of the applicant.
Noise pollution from the everyday operations at this location is beyond a nuisance. Windows
cannot be open during the day due to the noise generated by the loading and unloading of
pipes. The proposed business hours will impact the rural residential properties before sunrise
and after sunset during many months out of the year. This also includes weekend operations.
The location is surrounded by residential properties that will be negatively impacted by this
business operations.
Jack and Kristine Bauer
Todd Loose
R.O. Box 418
Kersey, CO. 80644
July 1, 2018
Weld County Planning Commission,
This letter is express significant concerns over the proposed USR 18-0032. The facility being
proposed on WCR 53 is inconsistent with the surrounding community and flies in the face of the
intent provided to oil and gas operators in Weld County utilizing the USR process. I do not
believe the way to solve a situation where an applicant blatantly engages in multiple infractions
of county code is to simply recommend approval of a USR for an industrial use site within 150
feet of two residences. From my observations of county maps, I believe there are more than 25
homes within one mile of the proposed facility. I do not see a USR as a legitimate solution.
will bullet point my concerns and comments below to provide a quick read for the planning
commission in respect of their review time.
Compatibility
• Two residences within 150 feet — one on the north and one on the south. Many more
are very close.
• The entire surrounding area south of Kersey has been developed into large lot
residential tracts. These residences vary in size from an acre to over 20 acres, but
review of the map will show that historical development of this area was fully intended
to be residential.
• WCR 53 is smaller paved road with a fairly high traffic count. The road going north turns
into 1st street (Main Street) in Kersey. It is obvious that traffic generated from the
proposed site is fully intended to travel directly through downtown Kersey. It is my
understanding that the applicant indicted a very different story to the town when
discussing the potential use with them.
o Please evaluate the inconsistencies in the application. The application states
95% of traffic will travel north from the site. This traffic flow is directly into
Kersey. In the letter dated April 28th, 2018 referencing Julie Piper and Barb
Brunk with the Town of Kersey whereas the applicant agreed to divert traffic
from coming north on 53 into Kersey. These statements are exactly the
opposite.
• There are multiple Commercial and Industrial sites available for sale or lease in the
Kersey area. There are two currently vacated sites directly on highway 34 that are
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available. To apply for a USR based on a need to locate the business is misleading and
u ntrue.
• The business currently has an office and truck parking on a commercial parcel in Kersey.
The applicant has a shop and office adjacent to the truck parking. There is not a
business case or need for relocating his business to his residence.
• The applicant proposes to operate a pipe yard. This is very different than the multitude
of USR approved for owner operators of trucking companies. The pipe yard is industrial
in nature and includes a number of nuisance conditions not addressed in the USR
application that are difficult to mitigate.
• Noise — I live approximately �/2 mile west of the site. My home is located over a slight hill
and the site is not directly visible. I can hear the pipe clanging all hours of the day, not
just the hours the applicant has indicated as business hours. I held a family gathering
on Easter Sunday this year and the "pipe sound" was readily available for all my family
to share in. Activity located in a residential neighborhood is not expected to generate
loud banging sounds and should not be located at this site. It is my belief that there is
n o way to truly mitigate the noise from this activity.
■ Noise walls can be engineered to deflect and control noise but these are
typically concrete structures that can exceed 20 feet in height. A wall like
this would be completely out of place in between two residences. This is
n ot compatible.
■ Vegetative screening is not an effective noise mitigation technique and
n ot normally used in a site like this.
■ Point source mitigation cannot be obtained due to the nature of the
n oise and constant unloading and loading of pipe in an industrial storage
lot.
■ There simply is no reasonable or effective way to mitigate noise from the
site.
• Lighting — lighting is not addressed in the application. Operating hours of 6am to 7pm as
indicated will require significant lighting for safe operation during much of the year.
With two residences within 150 feet lighting cannot be designed to serve the proposed
site without significant impact to neighbors.
Safety
• The following except is taken directly from a recent EPA publication examining radiation
concerns of scale generated in oil field pipe (March 2018).
`Approximately 100 tons of scale per oil well are generated annually in the
United States. As the oil in a reservoir dwindles and more water is pumped out
with the oil, the amount of scale increases. In some cases brine is introduced
into the formation to enhance recovery; this also increases scale formation.
The average radium concentration in scale has been estimated to be 480 pCi/g
(17.76 becquerels per gram (Bq/gj). It can be much higher (as high as 400,000
pCi/g or 14, 800 Bq/g►) or lower depending on regional geology. Scale in gas
wells and equipment can also contain the radon progeny lead -210 (Pb-210)
and polonium -210 (Po -210).
• It appears that Lauren Light with Environmental Health Services did not evaluate the
materials to be stored outside in a storage lot in an easily filtrated sand basin soil and
has not considered impact to ground water and airborne health concerns generated
from pipe scale in her referral letter. It is a solidly know issue in the industry and was
n ot considered in environmental review. I do not believe an environmental assessment
of the proposed activity was completed.
Noble Energy no longer sells oilfield pipe to local consumers due to the
environmental concerns of pipe scale and radiation impregnation in the pipe.
Why would we allow this to be banged around, dropping the scale into the soil
on a continual basis where it will either enter ground water or be ground up and
become airborne with traffic.
o The application does not address the environmental concerns of pipe scale nor
does it provide testing or quality control provisions to ensure community safety
from soil, water, and airborne particles.
o What other oil field equipment will be stored in an outdoor storage lot. The
application does not establish any criteria for this.
• Traffic flow impact is not acceptable without significant road improvements and should
n ot be approved as is.
o The pictures on the following page show that truck traffic cannot safely enter or
leave the site. WCR 53 is a narrow -paved road and does not have improved
shoulders. You can see road damage already occurring to the road. You also see
deep truck tracks in the barrow pit. There have been times when the trucks
actually get stuck with the tractor across the road in the ditch and the trailer
completely blocking the road.
o Creating a bottleneck on this road impedes all traffic going south from Kersey.
Emergency and first responders will be impacted in their response time in the
event of a truck blockage (which is common at this site).
o The applicant has submitted a traffic guestimate that conveniently allows for his
operation to exist just under the threshold requirement for widening the road
and installing turn lanes in both directions. As you see in the picture the site
orientation to the road will not allow for safe entry and exit even after
reconstruction of the egress points.
o There are multiple school bus stops in the near vicinity of the proposed site.
Trucks leaving or entering the site have already caused frustration, long delays
where traffic is stopped in both directions while a truck is attempting to access
the site.
• Liquid tank trucks are used in the applicant's operation to haul various products. Vac
trucks and tank trailers will be stored at the proposed site.
o There are liquid materials used in local oil and gas operations that are designated
hazardous, flammable, combustible, and known carcinogens. The applicant does
not identify or limit their proposed material hauling.
Environmental Health did not address the storage of trailers or trucks that may
be stored full of these products. Tank trailers are required to have pressure
venting to prevent tank ruptures, these vents may release fumes into our
neighborhood. Storage of these types of materials within 150 feet of residences
does not make sense.
o The applicant proposes a truck repair shop. We should assume that trailers and
containers will be repaired as well. This means welding on tank trailers
(aluminum trailers crack continually) will be occurring and normal residual
amounts of the liquid material listed above will be present. The applicant will
probably install a ventilation fan system to remove noxious fumes from the
repair bays and welding areas. These fumes will be vented outside the building
where they will directly impact nearby residences.
In summary this USR is not compatible with the surrounding residential neighborhood, multiple
nuisance conditions cannot be effectively mitigated, there is significant safety concerns with
respect to both operational activity and traffic. This USR is not needed as the applicant is
already operational at a local commercial location. I respectfully request the planning
commission recommend denial based on the above issues.
Todd Loose
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Note that WCR 53 does not have improved or paved shoulders.
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