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HomeMy WebLinkAbout20143199.tiff MEMORANDUM � .41" TO: Kim Ogle, Planning Services DATE: 9/8/2014 I c ou N?z FROM: Wayne Howard, P.E., Development Review Engineer SUBJECT: USR14-0048, Anadarko Central Oil Stabilization Facility Engineering Development Review has reviewed this proposal. This project falls under the Use by Special Review Standard, Weld County Code, Chapter 23, Article II, Division 4, Section 23. Staff comments made during this phase of the Use by Special Review process may not be all-inclusive, as other issues may arise during the remaining application process. COMMENTS: CR 30 is a collector road and requires an 80-foot right-of-way at full build out. There is presently a 60-foot right-of-way. This road is maintained by Weld County. Pursuant to the definition of SETBACK in the Weld County Zoning (23-1-90), the required setback is measured from the future right-of-way line. The applicant shall delineate an additional 10-foot of right-of-way parallel to the WCR 30 right-of-way for future build-out. An access application has been submitted and is under review by PW. The applicant plans to use an existing access owned by others and has furnished an agreement letter with the owner allowing for its use. The applicant anticipates that 2 full time employees on site at all times. Daily site traffic consists of 10 — 15 full size pickups per day and occasional large maintenance vehicles. Additional produced water trucks will access the site two times per day. Traffic generated during construction has not been estimated. Tracking control is required to prevent tracking from the site onto the County Roadway. Standard tracking control for accesses onto paved roads includes either 300 feet of pavement onsite OR 100 feet of pavement plus double cattle guards. Alternatives such as recycled AC, recycled concrete, or gravel may be considered with lighter traffic impact projects. A drainage narrative and water quality feature design was submitted. A water quality design was submitted. Label the water quality feature on the plat as "Water Quality Feature, No Build/Storage Area" and label the required volume. If more than 1 acre is to be disturbed, a Weld County grading permit will be required prior to the start of construction. A Construction Stormwater Permit is 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. An Improvements Agreement between the Applicant and the County will be required for the construction of this project. It will detail the approved haul route(s), any onsite and offsite requirements, and a maintenance agreement for the haul routes. Road maintenance after construction may not be required for this site if traffic impacts are minimal. A drainage narrative has been submitted along with erosion and grading plans. Engineer is currently reviewing the narrative and plans. C:AUsersVtjuanicorenaAAppDataAL.ocalAMicrosoft\Windows\Temporary Internet Files V Low VContent.IE5USNP2A0KVUSR 14- 0048%20Anadarko%20Stabilization%20Facility[I].doex CONDITIONS OF APPROVAL/REQUIREMENTS: 1. Prior to recording the plat: A. An Improvements Agreement and road maintenance agreement is required for the construction phase of the project. Road maintenance including dust control, damage repair will be included. B. The plat shall be amended to delineate the following: 1. CR 30 is a collector road and requires an 80-foot right-of-way at full build out. There is presently a 60-foot right-of-way. This road is maintained by Weld County. Pursuant to the definition of SETBACK in the Weld County Zoning (23-1-90), the required setback is measured from the future right-of-way line. The applicant shall delineate an additional 10-foot of right-of-way parallel to the WCR 30 right-of-way for future build- out. 2. Show the approved access on the plat and label with the approved access permit number AP14-?. 3. Show standard tracking control on the plat. 2. 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. B. Right of way permit is required for any work within the public right of way. C. Special transport permit is required for any over size or over weight vehicles. 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 I and II, 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. 5. The right-of-way or easement shall be graded and drained to provide an all-weather access. C:A Users VtjuanicorenaAAppDataAFocalAMicrosoft\Windows\Temporary Internet Files V Low VContent.IE5U8NP2A0KVUSR14- 0048%20Anadarko%20Stabilization%20Facility[I].doex MEMORANDUM TO: Kim Ogle, Planning Services \ FROM: Lauren Light, Environmental Health U�II QU N T?� SUBJECT: USR14-0048 Kerr-McGee DATE: 10/9/2014 Environmental Health Services has reviewed this proposal for a site specific development plan and a special review permit for a mineral resource development facility, oil and gas support and service, including, but not limited to a central oil stabilization facility; a united power substation and more than one cargo (conex) container in the A (Agricultural) Zone District. There will be two full time employees located at the facility. Either Central Weld County Water District will provide water or a commercial well will be drilled. The main pump/electrical building will contain an office and a septic system will be installed. The waste handling plan stipulates that a dumpster will be provided and will be serviced by Waste Management. Procedures for cleanup and disposal of spilled hazardous materials will be included in the Spill Prevention Control and Countermeasure plan (SPCC). Liquids will be disposed or recycled as necessary. On site dust will be controlled by having the access drive and driving areas graveled. A water truck will be utilized if necessary. An Air Pollution Emission Notice (A.P.E.N.) and Emissions Permit may be required. Noise may be regulated by the Colorado Oil and Gas Conservation Commission. The application states there will be minimal noise emitted from the site. We have no objections to the proposal; however, we do recommend that the following conditions be part of any approval: We recommend that the following requirement be incorporated into the permit as a condition that must be met within six months of operation: 1. A signed copy of the Spill Prevention, Control and Countermeasure Plan shall be provided to Environmental Health Services Division of the Weld County Department of Public Health & Environment. 2. Prior to the issuance of the Certificate of Occupancy: A. An individual sewage disposal system is required for the proposed facility and shall be installed according to the Weld County Individual Sewage Disposal Regulations. The septic system is required to be designed by a Colorado Registered Professional Engineer according to the Weld County Individual Sewage Disposal Regulations. We recommend that the following requirements be incorporated into the permit as development standards: 1. 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. 2. 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. 3. Waste materials shall be handled, stored, and disposed in a manner that controls fugitive dust, blowing debris, and other potential nuisance conditions. The applicant shall operate in accordance with the approved waste handling plan, at all times. 4. Fugitive dust and fugitive particulate emissions shall be controlled on this site. The facility shall be operated in accordance with the approved dust abatement plan, at all times. 5. The applicant shall obtain an Air Pollution Emission Notice (A.P.E.N.) and Emissions Permit from the Air Pollution Control Division, Colorado Department of Health and Environment, as applicable. 6. Adequate drinking, hand washing and toilet facilities shall be provided for employees and patrons of the facility, at all times. 7. 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. 8. A permanent, adequate water supply shall be provided for drinking and sanitary purposes. 2 9. 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 (HAP's) and volatile organic compounds (VOC's). All chemicals must be stored secure, on an impervious surface, and in accordance with manufacturer's recommendations. 10.The Spill Prevention, Control and Countermeasure Plan shall be available on site, at all times. 11.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. 12.The applicant shall obtain a Colorado Discharge Permit System or CDPS permit from the Colorado Department of Public Health and Environment (CDPH&E), Water Quality Control Division, as applicable. 13. In accordance with Colorado Oil and Gas Conservation Commission Rule 604, a spillage retention berm shall be constructed around the aboveground storage tanks. The volume retained by the spillage berm should be greater than the volume of the largest tank inside the berm and sufficient freeboard to contain precipitation. Alternative protective measures may be allowed provided they comply with the Colorado Oil and Gas Conservation Commission regulations. 14.The operation shall comply with all applicable rules and regulations of State and Federal agencies and the Weld County Code. 3 Department of Planning Services 1555 N 17th Ave Greeley, CO 80631 G O U N T Y (970) 353-6100 Weld County Referral Date: October 6,2014 Applicant: Russell Gurtler Family Trust;c/o Kerr-McGee Oil &Gas Onshore LP Project: A SITE SPECIFIC DEVELOPMENT PLAN AND A SPECIAL REVIEW PERMIT FOR A MINERAL RESOURCE DEVELOPMENT FACILITY, OIL AND GAS SUPPORT AND SERVICE, INCLUDING, BUT NOT LIMITED TO A CENTRAL OIL STABILIZATION FACILITY; A UNITED POWER SUBSTATION AND MORE THAN ONE CARGO (CONEX)CONTAINER IN THE A(AGRICULTURAL) ZONE DISTRICT • Case Number: USR14-0048 Parcel Number: 121324400006-R4909507 After reviewing the application and documents submitted the Building Department has the following comments: A building and electrical permit will be required, per Section 29-3-10 of the Weld County Code, for any new structures ,additions or renovation to any structures. A building permit application must be completed and two complete sets of engineered plans. Buildings and structures shall conform to the requirements of the various codes adopted at the time of permit application. Currently the following has been adopted by Weld County: 2012 International Building Code; 2012 International Mechanical Code; 2012 International Plumbing Code:; 2012 International Fuel Gas Code; 2006 International Energy Code; 2011 National Electrical Code; 2009 ANSI 117.1 Accessibility Code and Chapter 29 of the Weld County Code. RESOLUTION #35 Factory Built Nonresidential Structured CRS 24-32-3305 Every Factory-Built Nonresidential Structure manufactured after the effective date of these regulations that is manufactured, sold, or offered for sale in this state must display an insignia issued by the Division of Housing certifying that the unit is constructed in compliance with the standards adopted in schedule "B" which is incorporated herein and made a part of these Rules and Regulations by reference, and all other requirements set forth by this resolution.A Fire District Notification letter shall be submitted to the Fire District with jurisdiction for review and comments and submitted with Commercial Permit application to Weld County All building permit requirements can be found on the Weld County web-site. www.co.weld.co.us/Building Inspection/Commercial Permits Frank Piacentino Department of Building Inspection KINDER,`, MORGAN Guidelines for Design and Construction near Kinder Morgan Operated Facilities Name of Company: Colorado Interstate Gas Company (CIG) The list of design, construction and contractor requirements, including but not limited to the following,for the design and installation of foreign utilities or improvements on KM right-of-way(ROW)are not intended nor do they waive or modify any rights KM may have under existing easements or ROW agreements. Reference existing easements and amendments for additional requirements. This list of requirements is applicable for KM facilities on easements only. Encroachments on fee property should be referred to the Land and Right-of-Way Department. Design KM shall be provided sufficient prior notice of planned activities involving excavation, blasting, or any type of construction on KM's ROW to determine and resolve any location, grade or encroachment problems and provide protection of our facilities and the public before the actual work is to take place. Encroaching entity shall provide KM with a set of drawings for review and a set of final construction drawings showing all aspects of the proposed facilities in the vicinity of KM's ROW. The encroaching entity shall also provide a set of as-built drawings showing the proposed facilities in the vicinity of KM's ROW. Only facilities shown on drawings reviewed by CIG (Company)will be approved for installation on KM's ROW. All drawing revisions that effect facilities proposed to be placed on KM's ROW must be approved by KM in writing. KM shall approve the design of all permanent road crossings. Encroaching entity shall, at the discretion of the Kinder Morgan, Inc., incorporate Heath ATI "sniffer"Gas Detection Units in the design of paved areas or "Green Belt"areas of KM ROW. The units shall be installed per KM Standard TYP-V-0100- B010. Any repair to surface facilities following future pipeline maintenance or repair work by KM will be at the expense of the developer or landowner. The depth of cover over the KM pipelines shall not be reduced nor drainage altered without KM's written approval. Construction of any permanent structure, building(s)or obstructions within KM pipeline easement is not permitted. Planting of shrubs and trees is not permitted on KM pipeline easement. Irrigation equipment i.e. backflow prevent devices, meters,valves,valve boxes, etc. shall not be located on KM easement. Foreign line, gas, water, electric and sewer lines, etc., may cross perpendicular to KM's pipeline within the ROW, provided that a minimum of two (2) feet of vertical clearance is maintained between KM pipeline(s) and the foreign pipeline. Constant line elevations must be maintained across KM's entire ROW width, gravity drain lines are the only exception. Foreign line crossings below the KM pipeline must be evaluated by KM to ensure that a significant length of the KM line is not exposed and unsupported during construction. When installing underground utilities, the last line should be placed beneath all existing lines unless it is impractical or unreasonable to do so. Foreign line crossings above the KM pipeline with less than 2 feet of clearance must be evaluated by KM to ensure that additional support is not necessary to prevent settling on top of the KM natural gas pipeline. A foreign pipeline shall cross KM facilities at as near a ninety-degree angle as possible. A foreign pipeline shall not run parallel to KM pipeline within KM easement without written permission of KM. The foreign utility should be advised that KM maintains cathodic protection on their pipelines. The foreign utility must coordinate their cathodic protection system with KM's. At the request of KM, foreign utilities shall install (or allow to be installed) cathodic protection test leads at all crossings for the purposes of monitoring cathodic protection. The KM Cathodic Protection (CP) technician and the foreign utility CP technician shall perform post construction CP interference testing. Interference issues shall be resolved by mutual agreement between foreign utility and KM. All costs associated with the correction of cathodic protection problems on KM pipeline as a result of the foreign utility crossing shall be borne by the foreign utility for a period of one year from date the foreign utility is put in service. Reference: O&M Procedure 204 Page 1 of 3 OM200-29 09/08 KINDER,`, MORGAN Guidelines for Design and Construction near Kinder Morgan Operated Facilities The metallic foreign line shall be coated with a suitable pipe coating for a distance of at least 10 feet on either side of the crossing unless otherwise requested by the KM CP Technician. AC Electrical lines must be installed in conduit and properly insulated. DOT approved pipeline markers shall be installed so as to indicate the route of the foreign pipeline across the KM ROW. No power poles, light standards, etc. shall be installed on KM easement. Construction Contractors shall be advised of KM's requirements and be contractually obligated to comply. The continued integrity of KM's pipelines and the safety of all individuals in the area of proposed work near KM's facilities are of the utmost importance. Therefore, contractor must meet with KM representatives prior to construction to provide and receive notification listings for appropriate area operations and emergency personnel. KM's on-site representative will require discontinuation of any work that, in his opinion, endangers the operations or safety of personnel, pipelines or facilities. The Contractor must expose all KM transmission and distribution lines prior to crossing to determine the exact alignment and depth of the lines. A KM representative must be present. In the event of parallel lines, only one pipeline can be exposed at a time. KM will not allow pipelines to remain exposed overnight without consent of KM designated representative. Contractor may be required to backfill pipelines at the end of each day. A KM representative shall do all line locating. A KM representative shall be present for hydraulic excavation. The use of probing rods for pipeline locating shall be performed by KM representatives only, to prevent unnecessary damage to the pipeline coating. Notification shall be given to KM at least 72 hours before start of construction. A schedule of activities for the duration of the project must be made available at that time to facilitate the scheduling of Kinder Morgan, Inc.'s work site representative. Any Contractor schedule changes shall be provided to Kinder Morgan, Inc. immediately. Heavy equipment will not be allowed to operate directly over KM pipelines or in KM ROW unless written approval is obtained from CIG (Company). Heavy equipment shall only be allowed to cross KM pipelines at locations designated by Kinder Morgan, Inc. Contractor shall comply with all precautionary measures required by KM to protect its pipelines. When inclement weather exists, provisions must be made to compensate for soil displacement due to subsidence of tires. Excavating or grading which might result in erosion or which could render the KM ROW inaccessible shall not be permitted unless the contractor/developer/owner agrees to restore the area to its original condition and provide protection to KM's facility. A KM representative shall be on-site to monitor any construction activities within twenty-five (25) feet of a KM pipeline or aboveground appurtenance. The contractor shall not work within this distance without a KM representative being on site. Only hand excavation shall be permitted within a minimum of 18 inches (refer to state specific rules/regulations regarding any additional clearance requirements) of KM pipelines, valves and fittings. However, proceed with extreme caution when within three(3)feet of the pipe. Ripping is only allowed when the position of the pipe is known and not within ten (10) feet of KM facility unless company representative is present. . Temporary support of any exposed KM pipeline by Contractor may be necessary if required by KM's on-site representative. Backfill below the exposed lines and 12" above the lines shall be replaced with sand or other selected material as approved by KM's on-site representative and thoroughly compacted in 12" lifts to 95% of standard proctor dry density minimum or as approved by KM's on-site representative. This is to adequately protect against stresses that may be caused by the settling of the pipeline. No blasting shall be allowed within 1000 feet of KM's facilities unless blasting notification is given to KM including complete Blasting Plan Data. A pre-blast meeting shall be conducted by the organization responsible for blasting. Reference: O&M Procedure 204 Page 2 of 3 OM200-29 09/08 KINDER,`, MORGAN Guidelines for Design and Construction near Kinder Morgan Operated Facilities KM shall be indemnified and held harmless from any loss, cost of liability for personal injuries received, death caused or property damage suffered or sustained by any person resulting from any blasting operations undertaken within 500 feet of its facilities. The organization responsible for blasting shall be liable for any and all damages caused to KM's facilities as a result of their activities whether or not KM representatives are present. KM shall have a signed and executed Blasting Indemnification Agreement before authorized permission to blast can be given. No blasting shall be allowed within 300 feet of KM's facilities unless blasting notification is given to KM a minimum of one week before blasting. (note: covered above)KM shall review and analyze the blasting methods. A written blasting plan shall be provided by the organization responsible for blasting and agreed to in writing by KM in addition to meeting requirements for 500' and 1000' being met above. A written emergency plan shall be provided by the organization responsible for blasting. (note:covered above) Any contact with any KM facility, pipeline, valve set, etc. shall be reported immediately to KM. If repairs to the pipe are necessary, they will be made and inspected before the section is re-coated and the line is back-filled. KM personnel shall install all test leads on KM facilities. Burning of trash, brush, etc. is not permitted within the KM ROW. Insurance Requirements All contractors, and their subcontractors, working on Company easements shall maintain the following types of insurance policies and minimum limits of coverage. All insurance certificates carried by Contractor and Grantee shall include the following statement: "Kinder Morgan and its affiliated or subsidiary companies are named as additional insured on all above policies (except Worker's Compensation) and waiver of subrogation in favor of Kinder Morgan and its affiliated or subsidiary companies, their respective directors, officers, agents and employees applies as required by written contract." Contractor shall furnish Certificates of Insurance evidencing insurance coverage prior to commencement of work and shall provide thirty(30)days notice prior to the termination or cancellation of any policy. 1. Statutory Coverage Workers' Compensation Insurance in accordance with the laws of the states where the work is to be performed. If Contractor performs work on the adjacent on navigable waterways Contractor shall furnish a certificate of insurance showing compliance with the provisions of the Federal Longshoreman's and Harbor Workers' Compensation Law. 2. Employer's Liability Insurance, with limits of not less than $1,000,000 per occurrence and $1,000,000 disease each employee. 3. Commercial General Liability Insurance with a combined single limit of not less than $2,000,000 per occurrence and in the aggregate. All policies shall include coverage for blanket contractual liability assumed. 4. Comprehensive Automobile Liability Insurance with a combined single limit of not less than $1,000,000. If necessary, the policy shall be endorsed to provide contractual liability coverage. 5. If necessary Comprehensive Aircraft Liability Insurance with combined bodily injury, including passengers, and property damage liability single limits of not less than$5,000,000 each occurrence. 6. Contractor's Pollution Liability Insurance this coverage shall be maintained in force for the full period of this agreement with available limits of not less then $2,000,000 per occurrence. 7. Pollution Legal Liability Insurance this coverage must be maintained in a minimum amount of$5,000,000 per occurrence. Reference: O&M Procedure 204 Page 3 of 3 OM200-29 09/08 Submit by Email V. Weld County Referral �1, .t f ;�^ !, L ycjN-Y - August 11, 2014 The Weld County Department of Planning Services has received the following item for review: Applicant: Russell Gurtler Family Trust; Case Number: USR14-0048 c/o Kerr-McGee Oil & Gas Onshore LP Please Reply By: September 08, 2014 Planner: Kim Ogle Project: A SITE SPECIFIC DEVELOPMENT PLAN AND A SPECIAL REVIEW PERMIT FOR A MINERAL RESOURCE DEVELOPMENT FACILITY, OIL AND GAS SUPPORT AND SERVICE, INCLUDING, BUT NOT LIMITED TO A CENTRAL OIL STABILIZATION FACILITY; A UNITED POWER SUBSTATION AND MORE THAN ONE CARGO (CONEX) CONTAINER IN THE A (AGRICULTURAL) ZONE DISTRICT Location: WEST OF AND ADJACENT TO CR 49, 0.5 MILES NORTH OF CR 30 Parcel Number: 121324400006-R4909507 Legal: LOT B OF RECX14-0092 BEING PART OF THE N2SE4 SECTION 24, T3N, R65W 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. n We have reviewed the request and find that it does/does not comply with our Comprehensive Plan because: HWe have reviewed the request and find no conflicts with our interests. See attached letter. Signature Stephen Bacon Date 9/12/14 Agency Colorado Interstate Gas Company Weld County Planning Dept. 1555 N 17th Ave,Greeley,CO.80631 (970)353-6100 ext.3540 (970)304-6498 fax Colorado Interstate September 12, 2014 Gas Company, L.L.C. a Kinder Morgan company Weld County Planning Dept. Attn: Kim Ogle 1555 N. 17th Avenue Greeley, CO 80631 Re: Anadarko's proposed Mineral Resource Development Facility Case # USR14-0048 Hi Kim, Thank you for allowing us to review and comment on the proposed development. Colorado Interstate Gas Company ("CIG") owns and operates a 30 inch diameter high-pressure natural gas pipeline inside a 50 foot wide easement through this parcel. Said ROW Agreement was executed by Dorothy K. Gurtler Trust and Russell L. Gurtler, Jr Family Trust on November 28, 2007 and recorded in the Weld County Clerk & Recorder's Office in Reception # 3522692 on December 10, 2007. Anadarko and CIG have had several discussions regarding the effects of the proposed development upon our facility and easement. CIG's approval will be contingent on Anadarko signing an encroachment agreement with stipulations regarding CIG's access, maintenance, and utilization of our pipeline and easement. Attached is our Encroachment Permit along with two documents related to working in close proximity of our facilities (OM 200-29 and OM204-C1005). We will fill out the permit and send it and the two OM documents to Joe Aucoin (Anadarko's PM/Sr. Staff Facilities Engineer) for his review and permit execution by the end of next week. Upon review of the proposed project, Anadarko has designed two containment berms which will affect our access through the easement. CIG and Anadarko met onsite August 5th to discuss the effects of the project along with other items. CIG's approval of the proposed project is conditioned on the following stipulations which will be included in an Encroachment Permit, which will need to be signed prior to work commencing within the CIG easement. 1). Anadarko, its successors and assigns, is agreeable to temporarily remove the berms to provide CIG access and perform any maintenance activities within its right of way at Anadarko's, its successors and assigns, sole cost. Except for an emergency, CIG, at a minimum, will notify Anadarko at least one week in advance to have the berms removed within the right of way. Anadarko will fully compensate CIG for the cost to relocate its existing test station due to proposed improvements within 45 days of receipt of invoice. Ruby Anomaly Dig 5 Toll-free Telephone: 877-337-2237 Fax: 202-219-2730 Email: ferc.adr@ferc.gov. This letter is being provided to you by Ruby at least five days prior to the referenced maintenance activities taking place on your property. Thank you for your time and cooperation. Sincerely, Stephen Bacon Sr. ROW Agent 2 Ruby Pipeline, L.L.C. Encl: Aerial maps showing dig site location Page 2 of 2 Hello