HomeMy WebLinkAbout20150749.tiff ,r861 /,4+ MEMORANDUM
���� TO: Kim Ogle, Planning Services DATE: January 29, 2015
Vi
G al) N T—? FROM: Jen Petrik, P.E., Development Review Engineer
SUBJECT: USR14-0085, NGL Water Solutions
C5 salt water disposal facility
The Weld County Department of Planning Services-Engineering has reviewed this proposal.
Staff comments made during this phase of the application process may not be all-inclusive, as
other issues may arise during the remaining application process.
COMMENTS:
General Project Information/Location:
This project is a salt water injection facility.
This project is east of and adjacent to CR51 and is between HWY76 and CR16.
Roads:
CR51 and CR16 are County maintained local roadways.
Traffic counts on CR51 at the site entrance were 731 ADT in March of 2013.
Traffic:
A traffic study was performed by John Aldridge, PE. The Traffic study was not stamped. Janet
Lundquist with Public Works reviewed the traffic study and provided comments. The offsite
improvements can be constructed once the project reaches the triggers for specific turn lane
requirements.
The traffic study indicated the following:
1. The water disposal facility will have 10 employees with no more than seven on site at any
given time. It will be a 24 hour, seven days a week operation.
2. Initially the site expects to serve approximately 75 to 90 trucks per day spread out over a
24-hour period. This could increase to 150 to 180 trucks per day when the site is built-
out.
3. During the peak hour of usage, initially 8 to 10 trucks will enter and exit the facility, then
15 to 20 in the future at build-out.
4. The trip distribution assumes a 50/50 split to/from the north/south direction.
CDOT will be a referral agency for this project as the number of truck trips is significant and
there may be impacts to Highway 76.
Access:
An Access Permit application was submitted with the application materials. Public Works will
review the application and provide an access permit and permit number if approved. Questions
concerning access requirements can be directed to Public Works access permit division.
Tracking control is required to prevent tracking from the site onto the County Roadway.
0 Temporary Tracking Control shall be used during construction unless permanent tracking
control is installed ahead of construction activities.
0 Standard tracking control for accesses onto paved roads includes either 300 feet of
pavement onsite OR 100 feet of pavement plus double cattle guards.
General Site Plan Requirements: i.e (IA, RMA, City Town Agreement, etc..., offsite auxiliary
lanes)
Improvements Agreement:
An Improvements Agreement between the Applicant and the County will be required for this
project. It will detail the approved haul route(s), outline when offsite improvements will be
triggered, and include a maintenance agreement for the haul routes.
Geologic hazard Area:
This area IS NOT in a Geologic Hazard Area.
Floodplain:
The southwest corner of this parcel is within a known floodplain. A floodplain permit is required
for any development in the floodplain. Contact Diana Aungst with the Department of Planning
Services if developing in the floodplain.
Drainage Study:
A drainage letter dated November 21, 2014 prepared by Eric Wernsman PE33371 was submitted
with the application.
In order for stormwater detention design to not be appropriate and a simple water quality
feature be appropriate, the engineer must certify the project impacts on stormwater runoff are
minimal and insignificant. The drainage letter provided did not indicate the project impacts
were insignificant. The PE must certify the drainage runoff impacts are minimal in the
drainage narrative.
- It appears the water quality calculations assumed a 110 acre site. It appears the site is 16
acres. The overall site imperviousness for 16 acres is 22%. Please verify the correct
calculations were performed. Please provide the existing imperviousness of the project and
the increase that the project is proposing. Include the total acres of the parcel and the project
acres.
- The drainage narrative was not signed or stamped. Please submit a stamped and signed
drainage narrative.
- The applicants will be required to maintain historic drainage flows and run-off amounts on
the property.
This site is NOT in a State defined Municipal Separate Storm Sewer System (MS4) area which is
a more urbanized area with state mandated, higher water quality requirements.
Grading Permit
A Weld County Grading Permit will be required if disturbing more than 1 acre. Contact the
Planning Department for more information.
A Construction Stormwater Permit is also required with the State for disturbing more than 1 acre.
Contact: Colorado Department of Public Health and Environment, Water Quality Control
Division, Rik Gay, 303-692-3575.
CONDITIONS OF APPROVAL:
Prior to recording the plat:
A. An Improvements Agreement and Road Maintenance Agreement is required for
offsite improvements at this site. Road maintenance including dust control, damage
repair, specified haul routes and future triggers for improvements will be included.
The map shall be amended to delineate the following:
A. County Road 51 is a Paved road and is designated on the Weld County Road
Classification Plan as a Local road, which requires 60 feet of right-of-way at full
buildout. The applicant shall verify and delineate on the plat the future and existing
right-of-way and the documents creating the existing right-of-way. If the existing
right of way cannot be verified it shall be dedicated. All setbacks shall be measured
from the edge of future right-of-way. This road is maintained by Weld County.
B. County Road 16 is a Gravel road and is designated on the Weld County Road
Classification Plan as a Local road, which requires 60 feet of right-of-way at full
buildout. The applicant shall verify and delineate on the plat the future and existing
right-of-way and the documents creating the existing right-of-way. If the existing
right of way cannot be verified it shall be dedicated. All setbacks shall be measured
from the edge of future right-of-way. This road is maintained by Weld County.
C. Show the approved access(es) on the plat and label with the approved access permit
number (will be provided).
D. Show and label standard tracking control onto publically maintained roadways on
the map.
E. Show the accepted water quality feature on the map with volume and label as
WATER QUALITY FEATURE, NO-BUILD OR STORAGE AREA.
F. Show and label the drainage flow arrows, turning radii, and parking and circulation
on the map.
Prior to Construction:
A. If more than 1 acre is to be disturbed, a Weld County grading permit will be required
prior to the start of construction. Contact the Planning Department for application
information.
DEVELOPMENT STANDARDS (NOTES ON THE PLAT)
1. Should noxious weeds exist on the property, or become established as a result of the
proposed development, the applicant/landowner shall be responsible for controlling the
noxious weeds, pursuant to Chapter 15, Articles T and TT, of the Weld County Code.
2. The historical flow patterns and runoff amounts will be maintained on the site.
3. Weld County is not responsible for the maintenance of onsite drainage related features.
4. There shall be no parking or staging of vehicles on County roads. On-site parking shall be
utilized.
MEMORANDUM
��■Ii �� TO: KIM OGLE,PLANNING SERVICES
a - Ni T Y FROM: HEATHER BARBARE, ENVIRONMENTAL HEALTH
SUBJECT: USR14-0085, EH REFERRAL-NGL C5 SWD WELL AND
RECYCLING FACILITY
DATE:FEBUARY 2, 2015
Environmental Health Services has reviewed this proposal to a commercial Class II
Oilfield Waste Disposal Facility to include A Class II injection well, a vehicle washout
area, a produced water recycling facility, and associated infrastructure. The applicant is
proposing to have 10 total employees onsite to operate the facility over a 24 hour
period. Five employees will be onsite at one time. The facility will have a temporary tank
area. The temporary tank area will be required to meet secondary containment
requirements and other applicable conditions of approval and development standards.
The applicant is proposing to permit and install a septic system for the facility. The
applicant is proposing to have a commercial well for drinking water. The applicant will
need to submit evidence of septic system and well.
The applicant submitted a Waste Handling Plan. The waste handling plan provides
information about what chemicals are stored onsite and what wastes will be generated
onsite. It indicates that wastes generated onsite will be disposed of off-site. The waste
handling plan requires review and approval.
The applicant submitted an approved Dust Abatement Plan. The dust abatement plan
indicates that onsite roads will be maintained with an aggregate surface and
water/magnesium chloride will be applied to keep dust down. The parking and activity
areas will be moistened with water, as needed for dust control.
The applicant submitted a Recycling Facility Registration Form for the facility.
The applicant submitted a Groundwater Monitoring Plan for review and approval. The
applicant also submitted an SPCC Plan dated November 5, 2014 and evidence of an Air
Pollution Emission Notice (APEN) and Emissions Permit application from the Air
Pollution Control Division, Colorado Department of Health and Environment.
The applicant submitted evidence that blanket financial assurance ($60,000) had been
provided for well plugging per COGCC Rule 706. The applicant will be required to provide
evidence of financial assurance ($50,000) for Commercial UIC wells per COGCC Rules 706 and
704.
We have no objections to the proposal, however, we do recommend that the following
conditions be part of any approval:
1. Prior to allowing the plat to be recorded:
A. The applicant shall submit written evidence of a commercial well to Weld
County Department of Public Health and Environment.
B. Vehicle washing areas should be designated on the plat.
C. Temporary tank areas should be designated on the plat.
D. The applicant shall submit a waste handling plan, for approval, to the
Environmental Health Services Division of the Weld County Department of
Public Health & Environment. The plan shall include at a minimum, the
following:
1. A list of wastes which are expected to be generated on site (this should
include expected volumes and types of waste generated).
2. A list of the type and volume of chemicals expected to be stored on site.
3. The waste handler and facility where the waste will be disposed (including
the facility name, address, and phone number).
4. Solids and sediment will accumulate in the storage tanks. The waste handling
plan shall include a detailed plan that describes the method of how those solids
will be removed, including all on-site handling procedures.
5. The waste handling plan shall provide a commitment to notify the Weld County
Department of Public Health and Environment in writing, in the event the plan is
amended. The plan shall be reviewed and approved by the Weld County
Department of Public Health and Environment.
2. We recommend that the following requirements be incorporated into the permit
as conditions that must be met prior to release of building permits:
A. The applicant shall submit a Groundwater Monitoring Plan, and the
Groundwater Monitoring Plan shall be approved by Weld County Department
of Health and Environment. Evidence of such shall be submitted, it writing, to
the Department of Planning Services.
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B. The facility shall post financial assurance with the COGCC. The financial
assurance shall be adequate to cover a third-party closure of the facility,
including the plugging and abandonment of the well, in accordance with
industry standards, and the removal of all structures (including concrete) on
the facility. The site shall be returned to its original grade. The facility shall
submit evidence to Weld County Department of Public Health and
Environment that the appropriate financial assurance has been obtained.
C. A Detailed Closure Plan shall be submitted to Weld County Department of
Public Health and Environment and the Colorado Oil and Gas Conservation
Commission. The Closure Plan shall include a description of the manner in
which the well will be plugged and abandoned, as well as specific details
regarding reclamation of the property. No structures or equipment associated
with the facility shall remain on the property following closure.
D. Detailed Plans for a concrete unloading pad shall be submitted for
acceptance. A leak detection system shall be designed and installed beneath
the concrete unloading pad(s), piping, and sump(s). The plans and
engineered drawings will be stamped and signed by a Colorado Registered
Professional Engineer (PE). Plans shall be submitted to and accepted by
Weld County Department of Public Health and Environment.
E. Detailed plans for the concrete secondary containment structure for all
storage and processing tanks shall be submitted for acceptance. Secondary
containment volume shall provide containment for the entire contents of the
largest single tank plus sufficient freeboard to allow for precipitation. The
plans and engineered drawings will be stamped and signed by a Colorado
Registered Professional Engineer. The Weld County Department of Public
Health and Environment will consider structures other than concrete, provided
a Colorado Registered PE provides a certification indicating that the proposed
alternate containment system meets, or exceeds, the function of a concrete
system with regard to containment, spills, and unintended releases. Plans
shall be submitted to and accepted by Weld County Department of Public
Health and Environment.
3. Prior to the issuance of the Certificate of Occupancy:
A. An onsite wastewater treatment system is required for the proposed facility
and shall be installed according to the Weld County Onsite Wastewater
Treatment System Regulations. The septic system is required to be
designed by a Colorado Registered Professional Engineer according to the
Weld County Onsite Wastewater Treatment System Regulations.
4. We recommend that the following requirement be incorporated into the permit as
a condition that must be met within six months of operation:
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A. A professional engineer certified and signed copy of the Spill Prevention,
Control and Countermeasure Plan, prepared in accordance with the
applicable provisions of 40 CFR, Part 112 shall be provided to Environmental
Health Services Division of the Weld County Department of Public Health and
Environment.
B. The applicant shall submit documentation to the Weld County Department of
Public Health and Environment that the facility was constructed in accordance
with the application materials.
5. We recommend that the following requirement be incorporated into the permit as
a condition that must be met one month prior to operation of the Recycling
Facility:
A. The applicant shall provide evidence of a Recycling Facility Registration and
a CDPHE-approved design and operations plan.
6. We recommend that the following requirement be incorporated into the permit as
a condition that must be met one month prior to operation of the truck washout
facility:
A. In the event vehicle or equipment washing will occur on site, the applicant
shall submit documentation to demonstrate that washing area(s) shall capture
all effluent and prevent discharges.
7. Prior to the issuance of the Certificate of Occupancy:
A. An onsite wastewater treatment system (OWTS) is required for the
proposed facility and shall be installed according to the Weld County
OWTS Regulations. The septic system is required to be designed by a
Colorado Registered Professional Engineer according to the Weld County
OWTS Regulations.
8. We recommend that the following requirements be incorporated into the permit
as development standards:
A. No disposal of waste, other than Class II, as currently defined by the
Environmental Protection Agency, is permitted. Any changes from the
approved Class II use will require an amendment to this Use by Special Review
Permit.
B. All liquid wastes received at the facility shall be unloaded on the unloading pad.
The unloading/loading pad leak detection system shall be constructed and
operated in accordance with the approved design. The unloading pad will be
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kept in good condition and cleaned at a frequency that prevents oils and other
wastes from building up on the pad. During winter months, the facility shall
maintain the unlading pad free of ice.
C. Analytical waste data and environmental monitoring data shall be made
available to Weld County Department of Health and Environment upon request.
The Weld County Department of Health and Environment reserves the right to
require additional monitoring.
D. All liquid and solid wastes (as defined in the Solid Wastes Disposal Sites and
Facilities Act, 30-20-100.5, C.R.S., as amended) shall be stored and removed
for final disposal in a manner that protects against surface and groundwater
contamination.
E. No permanent disposal of wastes shall be permitted at this site. This is not
meant to include those wastes specifically excluded from the definition of a
solid waste in the Solid Wastes Disposal Sites and Facilities Act, 30-20-100.5,
C.R.S., as amended.
F. Any contaminated soils on the facility shall be removed and disposed of in
accordance with applicable rules and regulations. All spills will be documented
and records will be kept onsite for WCDPHE review upon request. All spills will
be reported to local, state and federal agencies in accordance with all state and
federal regulations.
G. The facility shall comply with the approved Groundwater Monitoring Plan.
H. Temporary tanks will be onsite no longer than six months. All tanks, including
temporary tanks will be labeled in accordance with COGCC and NFPA
requirements.
I. All stormwater, which has come into contact with waste materials on the site,
shall be confined on the site. In the event the storm water is not adequately
controlled on the site, upon written notification from the WCDPHE or CDPHE, a
comprehensive site-wide Stormwater Plan shall be developed and
implemented. The plan must be approved, in writing by the WCDPHE or
CDPHE, prior to implementation.
J. Waste materials shall be handled, stored, and disposed in a manner that
controls fugitive dust, fugitive particulate emissions, blowing debris, and other
potential nuisance conditions. The facility shall operate in accordance with the
approved "waste handling plan", at all times.
K. Any vehicle or equipment washing areas shall be maintained to capture all
effluent and prevent discharges in accordance with all county, state and federal
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rules and regulations.
L. Should recycling occur at the facility, the facility shall operate in accordance
with their CDPHE-approved design and operations plan. A copy of the annual
Recycling Facility Annual Reporting Form shall be submitted to the CDPHE and
WCDPHE by March 1 of each year.
M. Fugitive dust and fugitive particulate emissions shall be controlled on this site.
The facility shall operate in accordance with the approved "dust abatement
plan", at all times.
N. This facility shall adhere to the maximum permissible noise levels allowed in
the non-specified Zone as delineated in Section 14-9-30 of the Weld County
Code, or with all applicable State noise statutes and/or regulations.
O. Adequate drinking, handwashing and toilet facilities shall be provided for
employees and patrons of the facility, at all times. If employees or contractors
are on site for less than 2 consecutive hours a day or less than 2 fulltime
employees are onsite, portable toilets and bottled water are acceptable.
Records of maintenance and proper disposal for portable toilets shall be
retained on a quarterly basis and available for review by the Weld County
Department of Public Health and Environment. Portable toilets shall be
serviced by a cleaner licensed in Weld County and shall contain hand
sanitizers.
P. Sewage disposal for the facility shall be by septic system. Any septic system
located on the property must comply with all provisions of the Weld County
Code, pertaining to On-site Wastewater Treatment Systems.
Q. A permanent, adequate water supply shall be provided for drinking and sanitary
purposes. The facility shall utilize the private water supply.
R. All potentially hazardous chemicals must be handled in a safe manner in
accordance with product labeling and in a manner that minimizes the release of
hazardous air pollutants and volatile organic compounds. All chemicals must be
stored securely, on an impervious surface, and in accordance with
manufacturer's recommendations.
S. A current professional engineer certified and signed Spill Prevention, Control
and Countermeasure Plan shall be available on site, at all times.
T. The operation shall comply with all applicable rules and regulations of State
and Federal agencies and the Weld County Code.
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MEMORANDUM
✓ELI
TO: KIM OGLE, PLANNING SERVICES
O_
a a - - N T Y FROM: ENVIRONMENTAL HEALTH
_—T
SUBJECT: NGL WATER SOLUTIONS, LLC: C5 SUBMITTAL
INJECTION FACILITY COMMENTS
DATE:FEBRUARY 18,2015
The Weld County Department of Public Health and Environment (WCDPHE) has
reviewed the proposed shallow groundwater monitoring plan and waste handling plan
for the NGL Water Solutions C5 Injection Facility in Weld County, Colorado. Upon
review, WCDPHE has the following comments.
Groundwater Monitoring Plan
WCDPHE requests sulfates be included on all analysis lists/tables throughout the plan
for a consistent parameter list.
WCDPHE requests a commitment to install additional groundwater monitoring wells as
necessary.
Appendix A indicates that groundwater monitoring wells will be installed to a depth
greater than or equal to five feet below static groundwater table elevation. WCDPHE
concurs with this approach and requests that the text indicating that the well will be
installed to 30 feet below ground surface be revised to be consistent with well
installation to shallow groundwater.
The report indicates "Pertinent information, such as soil sample descriptions of color,
texture, consistency, moisture content, and soil vapor readings along with well
construction details of each monitoring well will be provided in the associated quarterly
groundwater monitoring report." WCDPHE requests that this include soil boring logs,
well registrations, and soil sample results listed in Appendix A.
WCDPHE requests leak detection well monitoring be conducted in conjunction with
groundwater sampling events and if liquid is detected in the leak detection wells it
should be sampled for the groundwater sampling constituents.
WCDPHE does not consider reanalyze at the lab to be a final investigation measure
and requests that CGRS include a commitment to conduct additional groundwater
monitoring and site investigation and/or remediation as warranted (for example when
there is a significant statistical increase over background levels, detection greater than
groundwater standards, or an indication that a leak/spill/release has occurred).
WCDPHE requests information pertaining to groundwater sampling report content,
including: background information and description of quarterly activities, site location,
sampling dates, significant events or changes, field parameters (pH, specific
conductance, temperature and observations), analytical results compared to applicable
standards, statistical analysis, groundwater elevation data, total well depth (including
measurements of non-aqueous phase liquids), well integrity, damage to wells, leak
detection information and sampling results, potentiometric surface maps, laboratory
reports with chains of custody, current/historical fluid levels, field sheets, and any
deviations from the groundwater monitoring plan. Additionally, WCDPHE requests a
commitment to provide quarterly monitoring reports and information to WCDPHE in a
timely manner (for example 30 or 45 days after sample results are received).
WCDPHE requests a commitment to dispose of groundwater generated as a result of
groundwater investigation and/or remediation activities in accordance with all applicable
state and federal rules and regulations.
Waste Handling Plan
WCDPHE requests the following additional information:
E Waste facility name, address, and phone number
Information indicating how the fluid generated at the vehicle washout area
(shown on site map) will be contained, managed and disposed of
- A statement indicating how containment of potentially contaminated solids (such
as filter socks) will be covered, contained, and disposed of off-site to prevent
stormwater from contacting waste
L Information indicating how tank bottoms and solids will be removed from tanks
and disposed of off-site.
Please add a comment that if the plan is amended than WCDPHE will be notified in
writing.
Additionally, please note: WCDPHE does not recognize that the Waste Handling Plan
text discussing spill reporting is consist with federal and state requirements; however,
spill reporting procedures are not a WCDPHE-required element of Waste Handling
Plans. WCDPHE would anticipate that waste generated from a spill or release would be
handled in accordance with all applicable state and federal rules and regulations.
WCDPHE requests information concerning the handling and disposal of this waste
stream. WCDPHE considers it the responsibility of the facility to ensure spill reporting
and response procedures are consistent with all federal, state and local requirements
and all rules and regulations are required to be followed.
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MEMORANDUM
TEL" � TO: KIM OGLE,PLANNING SERVICES
N T Y t FROM: ENVIRONMENTAL HEALTH
SUBJECT: NGL C5 USR14-0085 EH CONDITIONS OF APPROVAL
DATE: MARCH 2015
Weld County Department of Public Health and Environment(WCDPHE) reviewed information
submitted for the NGL C-5 facility Conditions of Approval (COA) (USR14-0085). Please see the
following comments.
Prior to recording the Plat:
COA 1.A.11 Vehicle Washing Area:
Vehicle washing areas should be designated on the plat. COA pending plat.
COA 1.A.12 Temporary Tank Areas:
Temporary tank areas should be designated and delineated on the plat. COA pending plat
COA 1.C Commercial Well:
Information was not submitted to meet this COA.
COA 1.D Waste Handling Plan:
WCDPHE requests the following additional information:
L Waste facility name, address, and phone number
L Information indicating how the fluid generated at the vehicle washout area (shown on site
map) will be contained, managed and disposed of
L A statement indicating how containment of potentially contaminated solids (such as filter
socks) will be covered, contained, and disposed of off-site to prevent stormwater from
contacting waste
• Information indicating how tank bottoms and solids will be removed from tanks and
disposed of off-site.
Please add a comment that if the plan is amended than WCDPHE will be notified in writing.
Additionally,please note: WCDPHE does not recognize that the Waste Handling Plan text
discussing spill reporting is consist with federal and state requirements; however, spill reporting
procedures are not a WCDPHE-required element of Waste Handling Plans. WCDPHE would
anticipate that waste generated from a spill or release would be handled in accordance with all
applicable state and federal rules and regulations. WCDPHE requests information concerning the
handling and disposal of this waste stream. WCDPHE considers it the responsibility of the
facility to ensure spill reporting and response procedures are consistent with all federal, state and
local requirements and all rules and regulations are required to be followed.
COA 1.E. Groundwater Monitoring Plan:
WCDPHE reviewed a Groundwater Monitoring Plan dated February 20, 2015 titled "Site
Groundwater Monitoring Plan update". Based on this review, WCDPHE has the following
comments.
WCDPHE requests leak detection well monitoring be conducted in conjunction with
groundwater sampling events and if liquid is detected in the leak detection wells it should be
sampled for the groundwater sampling constituents.
WCDPHE requests information pertaining to groundwater sampling report content, including:
background information and description of quarterly activities, site location, sampling dates,
significant events or changes, field parameters (pH, specific conductance, temperature and
observations), analytical results compared to applicable standards, statistical analysis,
groundwater elevation data, total well depth (including measurements of non-aqueous phase
liquids), well integrity, damage to wells, leak detection information and sampling results,
potentiometric surface maps, laboratory reports with chains of custody, current/historical fluid
levels, field sheets, and any deviations from the groundwater monitoring plan. Additionally,
WCDPHE requests a commitment to provide quarterly monitoring reports and information to
WCDPHE in a timely manner (for example 30 or 45 days after sample results are received).
Prior to the Release of Building Permits:
COA 5.A Financial Assurance:
Evidence that blanket financial assurance ($60,000) had been provided for well plugging per
COGCC Rule 706 was provided to WCDPHE. Evidence of financial assurance ($50,000) for
Commercial UIC wells per COGCC Rule 712 is required. Information has not been submitted to
meet this COA.
COA 5.B Unloading Pad and Leak Detection:
Information has not been submitted to meet this COA.
COA 5.C Secondary Containment:
Information has not been submitted to meet this COA.
Prior to the issuance of the Certificate of Occupancy:
COA 7.A Onsite Wastewater Treatment System:
Information has not been submitted to meet this COA.
One Month Prior to Operation of the Recycling Facility:
COA 9.A Recycling Facility Registration and Approved Design and Operations Plan:
Information has not been submitted to meet this COA.
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One month prior to the operation of the Truck Washout Facility:
COA 10.A Truck Washing Areas:
WCDPHE has not received documentation demonstrating how the washing area(s) will capture
all effluent and prevent discharges.
Within Six Months of Operation:
COA 11.A Spill Prevention, Control and Countermeasure Plan:
A P.E. certified signed copy of the SPCC was provided to WCDPHE on November 5, 2014. The
plan states that once the C5 facility is constructed, an inspection will be completed. This final
inspection and plan will be certified by a P.E. WCDPHE requires the final signed plan to meet
this condition.
COA 11.B Constructed with Application Materials:
Documentation is needed that the facility was constructed in accordance with the application
materials.
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MEMORANDUM
TO: Kim Ogle DATE: January 12, 2015
I> c qU_i T FROM: Diana Aungst, CFM
SUBJECT: USR14-0085, M3 Construction, LLC
PROJECT:
A SITE SPECIFIC DEVELOPMENT PLAN AND SPECIAL REVIEW PERMIT FOR MINERAL
RESOURCE DEVELOPMENT FACILITIES, OIL AND GAS SUPPORT AND SERVICE (CLASS II
OILFIELD WASTE DISPOSAL FACILITY - SALTWATER INJECTION FACILITY) IN THE A
(AGRICULTURAL)ZONE DISTRICT
PARCEL: 130529300028
COMMENT:
The southern portion of the lot is in the Jim Creek Floodplain. It appears that the development is outside
of the floodplain. If there is any development on this site in the floodplain a floodplain development permit
(FHDP)will be required. This floodplain is zoned A.
CONDITION OF APPROVAL:
The applicant shall submit a Floodplain Development Permit (FHDP) for all development activities
located within the special flood hazard area. The FEMA definition of development is any man-made
change to improved or unimproved real estate, including by not limited to buildings or other
structures, mining, dredging, filling, grading, paving, excavation, drilling operations, or storage of
equipment and materials. (Department of Planning Services—Floodplain)
DELINEATE ON THE PLAT:
Show the floodplain and floodway (if applicable) boundaries on the map. Label the floodplain
boundaries with the FEMA Flood Zone and FEMA Map Panel Number or appropriate study.
(Department of Planning Services- Floodplain)
DEVELOPMENT STANDARDS:
1. All construction or improvements occurring in the floodplain or floodway as delineated on Federal
Emergency Management Agency (FEMA) FIRM Community Panel Map # 080266-0900C dated
September 28, 1982, shall comply with all applicable Weld County requirements, Colorado Water
Conservation Board requirements as described in Rules and Regulations for Regulatory
Floodplains in Colorado, and FEMA regulations and requirements as described in 44 CFR pads
59, 60, and 65. (Department of Planning Services- Floodplain)
Submit by Email
Weld County Referral
JAN 21 2015
Weld County Planning uepertment
January 05, 2015 GREELEY OFFICE
The Weld County Department of Planning Services has received the following item for review:
Applicant: NGL Water Solutions DJ, LLC Case Number: USR14-0085
Please Reply By: February 02, 2015 Planner: Kim Ogle '
Project:A SITE SPECIFIC DEVELOPMENT PLAN AND SPECIAL REVIEW PERMIT FOR MINERAL
RESOURCE DEVELOPMENT FACILITIES, OIL AND GAS SUPPORT AND SERVICE (CLASS II
OILFIELD WASTE DISPOSAL FACILITY- SALTWATER INJECTION FACILITY) IN THE A
(AGRICULTURAL) ZONE DISTRICT
Location: EAST OF AND ADJACENT TO CR 51; NORTH OF AND ADJACENT TO CR 16
Parcel Number: 130529300028-R2614603 Legal: PART SW4 SECTION 29, T2N, R64W LOT B REC
EXEMPT RE-3520 of the 6th P.M., Weld County, Colorado.
The application is submitted to you for review and recommendation. Any comments or
recommendation you consider relevant to this request would be appreciated. Please reply by the
above listed date so that we may give full consideration to your recommendation. Any response not
received before or on this date may be deemed to be a positive response to the Department of Planning
Services. If you have any further questions regarding the application, please call the Planner
associated with the request. Please note that new information may be added to applications
under review during the review process. If you desire to examine or obtain this additional
information, please call the Department of Planning Services.
We have reviewed the request and find that it does/does not comply with our Comprehensive
Plan because:
ViWe
have reviewed the request and find no conflicts with our interests.
See attached letter
Signature P{ GU Date /AL/AS--
Agency -SI 6C4-4141.SCY1
Weld County Planning Dept. 1555 N 17th Ave,Greeley,CO.80631 (970)353-6100 ext.3540 (970)304-6498 fax
i[unoN
s TOWN OF HUDSON
.• 557 ASH STREET, P:O. BOX 351, HUDSON, CO 80642-0351
,gr'_kap Phone: (303) 536-9311 FAX: (303) 536-4753
G1 r1;vt$i www.hudsoncolorado.orn
January 16, 2015
Kim Ogle
Weld County Planning Department
1555 North 17th Avenue
Greeley, CO 80631
Subject: Referral Response - USR14-0085, Town of Hudson
Dear Mr. Ogle,
The Town of Hudson Planning Commission met at their regularly scheduled meeting on
Wednesday, January 14, 2014 to consider, among other items, a referral from Weld County
concerning USR14-0085 —NGL Waster Solutions proposal for a Class II Oilfield Waste
Disposal Facility.
Mr. Ryan Surroz from NGL Water Solution made a presentation describing the physical and
operational characteristics of the proposal. Key concern of the Town is the impact of the 150 -
250 truck trips per day generated by the facility. We are most concerned with minimizing travel
through Town as it affects the condition of our roads and is a potential safety issue.
Mr. Surroz explained the trucking operations to the facility is provided by "third-party"
contractors and that NGL has no influence or control over the route used to access their facility.
Furthermore, the third party hauling contractors are hired by the well producer and NGL argues
that they have no direct influence over driver routes. He did, however, testify that almost all of
the related truck traffic would access the site from the north, across the CR 51 rail crossing.
We request that the applicant make every effort to inform the waste haulers to avoid travel
through the Town of I ludson. Each haul truck unloads at the facility and is there any reason why
the drivers can't be directed to avoid Main Street (Hwy 52), CR 49 south of I-76, CR 16 east of
CR51, and CR 51 south of CR16 to access the site?
Sincerely,
Laura Hargis, Chair
Hudson Planning Commission
100 Years as an Incorporated Town-Join Us in Building for Our Next 100 Yew's
From: (fanny kioo
To: Ryan Surroz
Cc: todd Hodges; Keenesburg Clerk; Tom Parko Jr.; Kim Ogle
Subject: Re: NGL Water Solutions
Date: Monday, February 02,2015 4:26:53 PM
Thank you for your time and best of luck with your project. Thank you
Danny kipp mayor town of keenesburg
Reply message
From: "Ryan Surroz" <Ryan.Surroz@nglep.com>
To: "mayorkipp@live.com" <mayorkipp@live.com>
Subject: NGL Water Solutions
Date: Mon, Feb 2, 2015 4:18 PM
Danny,
Thanks again for meeting with me last week and providing information about annexation into the
town of Keenesburg.
After a follow-up conversation with Weld County, I have confirmed that our USR package is properly
submitted. Given the rigor of regulatory approvals, NGL has decided to complete the USR process
through Weld County. However, given the potential benefits that we discussed, NGL may consider
the annexation of this property into the town of Keenesburg in the future.
Having said this, I would like to confirm my intent to recruit within Keenesburg. And NGL and its
contractors intend to enjoy the services provided within the town of Keenesburg.
Thanks,
Ryan
Ryan Surroz
Vice President
NGL Water Solutions, LLC—Rockies Region
Cell 303-304-6523
3773 Cherry Creek North Drive, Suite 1000
Denver, CO 80209
**Please note:my email address has changed to ryan.surrozlc3nglen.corn
TOWN OF KEENESBURG
FOUNDED JULY, 1906
A MUNICIPAL CORPORATION SINCE JULY, 1919
February 4, 2015
Weld County Department of Planning Services
1555 N 17th Avenue
Greeley, CO 80631
Attention: Tom Parko, Kim Ogle
RE: Comments on Proposed NGL Water Solutions Injection Well, (USR 14-0085) -Lot B,
Southwest'/.Section 29, Township 2 North, Range 64 West
Dear Weld County Planning:
This Use by Special Review (USR) application to Weld County is a project located within the 3-
mile referral area covered under the Coordinated Planning Agreement. Although Keenesburg
was not included in the original requests for comments for this USR project, we request that the
comments below be included in the record and included in the presentations at the Planning
Commission and Board of County Commissioner's hearings for this project. We also request that
the Town be contacted with the hearing dates so that we may attend and present our comments
in person.
1. There are inconsistancies between the application materials:
• The November 14, 2014 "Traffic Study" by Alderidge Transportation Consultants
describes vehicle counts and traffic impacts to WCR 51; however the proposed
NGL Water Solutions Injection Well facility is shown to access onto WCR 53 on
the "USR map, C5 Grading Plan, and C5 Erosion Control Plan" drawings
prepared by Wernsman Engineering.
• The Access Permit Application form for this project, submitted to Weld County
Public Works on November 20, 2014 requests an access on WCR 16, not WCR
51. The other documents show the access on WCR 53.
• The USR application states that the facility would have 150 trucks per 24 hours
(so 300 total trips per day excluding onsite employee traffic). The Alderidge
Traffic Study states 250 trucks per 24 hours (500 trips per day excluding onsite
employee traffic). The other descriptions of site actrivity (10 trucks per hour)
indicate that the higher 500 truck trips per day is the likely traffic loading.
2. The Ground Water Monitoring program proposed for the NGL Water Solutions Injection
Well by CGRS (November 3, 2014) includes installation and sampling of four (4)
monitoring wells surrounding the proposed NGL site. Leakages, spills, or other shallow
ground water contamination emanating from the NGL site may impact nearby and
downgradient water impoundments, wind mills, and shallow wells. Also, Keenesburg
owns and operates a public water supply well located within two (2) miles of this
proposed injection well facility. Keenesburg requests that the Applicant/site manager
contact Keenesburg to arrange sampling of the Town's well water to obtain a baseline
sample prior to commencing operations. Keenesburg also requests that the quarterly
sampling program as proposed by the Applicant be continued on a quarterly basis
thereafter as long as required by regulatory authorities and for the same list of analytes
proposed by CGRS for the site monitoring program. Keenesburg requests that the cost
of the sampling and analyses be borne by the Applicant/site manager (NGL or
successor).
The sampling protocols proposed by CGRS are appropriate. The analyte suite (Total
Volatile Hydrocarbons, BTEX, TDS, and chlorides) are appropriate. Keenesburg
requests that the Applicant/site manager be committed to provide the quarterly sampling
as proposed in the CGRS program. Keenesburg also requests to be given copies of all
monitoring well sampling analyses when they are produced.
3. Road Maintenance. The truck traffic from the proposed NGL Water Solutions Injection
Well site will impact WCR 16, WCR 51, and the Interstate frontage road. A Road
Maintenance Agreement between Weld County and the Applicant is recommended as a
condition of County approval of this USR. These roads are not currently under
Keenesburg maintenance, however may eventually be annexed to the Town in
association with future development adjacent to Keenesburg. Keenesburg requests that
the Town be referenced as successor to any Road Maintenance Agreement between the
applicant and the County so that obligations for road repairs and maintenance
necessitated by wear and tear or damages due to traffic from this USR do not impact
Keenesburg budgets and area citizens. Keenesburg also requests that they be notified
and have input in the event that the Applicant proposes to change the haul route as
proposed in the USR application.
4. Pre-Annexation Agreement. The proposed NGL site is in close proximity to the current
Keenesburg Town limits and well within the Town's growth boundary as shown in the
Town's current Comprehensive Plan. Keenesburg requests, that as a condition of
approval of the County's USR, that the Applicant for the proposed NGL Water Solutions
project develop and execute an Pre-Annexation Agreement with the Town to be signed at
the earliest opportunity.
Sincerely,
Danny Kipp, Mayor, Town of Keenesburg
140 South Main Street
P.O. Box 312
Keenesburg, Colorado 80643
140 SOUTH MAIN P.O. BOX 312 KEENESBURG, COLORADO 80643
PHONE 303-732-4281 FAX 303-732-0599
4 Diik
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COLORADO
CO Resources
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1313 Sherman Street, Room 821
Denver, CO 80203
January 8, 2014
Kim Ogle
Weld County Planning Services
Transmission via email: kogle@co.weld.co.us
Re: NGL Water Solutions DJ, LLC
Case No. USR14-0085
9N114 of Section 29, T2N, R64W
Water Division 1, Water District 2
Dear Mr. Ogle:
This referral does not appear to qualify as a "subdivision" as defined in Section 30-28-
101(10)(a), C.R.S. Therefore, pursuant to the State Engineer's March 4, 2005 and March 11,
2011 memorandums to county planning directors, this office will only perform a cursory
review of the referral information and provide informal comments. The comments do not
address the adequacy of the water supply plan for this project or the ability of the water
supply plan to satisfy any County regulations or requirements. In addition, the comments
provided herein cannot be used to guarantee a viable water supply plan or infrastructure, the
issuance of a well permit, or physical availability of water.
The application is for a Site Specific Development Plan and Special Review Permit for Mineral
Resource Development Facilities, Oil and Gas Support (Class II oilfield water disposal facility -
salt water injection facility) in the Agricultural Zone District. The Applicant indicated that there
will be 10 total employees that will utilize the site with no more than 5 on site at any one time.
The proposed source of water for the commercial business on property will be provided by a
new commercial well. Any well permit application for the proposed well would be evaluated at
the time it is received in this office.
Should you have any questions, please contact loana Comaniciu of this office.
Sincerely, �� �
Aiv
Joanna Williams, P.E.
Water Resource Engineer
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1313 Sherman Street, Room 821, Denver, CO 80203 P 303.866.3581 F 303.866.3585 www.water.state.co.us
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