HomeMy WebLinkAbout6.0 Resolution 2013-72■Ill I+ IOXIAICY1 MAR RN 11111
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STATE OF COLORADO )
)ss
County of Garfield )
At a regular meeting of the Board of County Commissioners for Garfield County, Colorado,
held in the Commissioners' Meeting Room, Garfield County Courthouse, in Glenwood Springs on.
Monday, the 10`h clay of August, 2009, there were present:
John Martin , Commissioner Chairman
Mike Samson . Commissioner
Tresi Haupt , Commissioner
Jean Alberico , Clerk of the Board
Don DeFord , County Attorney
Ed Green (absent) , County Manager
when the following proceedings, among others were had and done, to -wit:
RESOLUTION NO. 0261a" ft'?
A RESOLUTION CONCERNED WITH THE APPROVAL OF A SPECIAL USE
PERMIT FOR THE NORTH PARACHUTE RANCH DRILLING FLUIDS RECYCLING
SYSTEM, AN INDUSTRIAL SUPPORT FACILITY WHICH INCLUDES MATERIAL
HANDLING, PUMPING FACILITIES, STORAGE YARDS AND PROCESSING
LOCATED IN PORTION OF SECTION 19, 27, 28, AND 29 OF TOWNSHIP 5 SOUTH,
RANGE 95 WEST AND IN PORTIONS OF SECTIONS 15, 22, 25, AND 26 OF
TOWNSHIP 5S AND RANGE 96 WEST ALL OF THE 6rfl P.M., OWNED BY ENCANA
OIL AND GAS (USE) INC., GARFIELD COUNTY, COLORADO
PARCEL NO# 2135- 273 -00 -015
Recitals
A. The Board of County Commissioners of Garfield County, Colorado, received a request for
A Special Use Permit to allow for an industrial support facility which includes material handling, pumping
facilities, storage yards and processing on 4.338 acres ofa 45,000 acre parcel owned by Encana Oil and Gas (USA)
Inc.
B. The Industrial Support Facility is located in portions of Sections 19, 27. 28, and 29 of
Township 5 south, range 95 west and portions of Sections 15, 22, 25, and 26 of Township 5 South,
Range 96 West all of the 6th P.M. and further described as parcel number 2135 - 273 -00 -015 and
located approximately 8.5 miles north of the Town of Parachute on County Road 215.
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C. The subject property is contained within the Resource Lands Zone District and such land
uses will comply with the zone district standards.
D. The Board is authorized to approve, deny or approve with conditions a Special Use Permit
pursuant to Section 5.03 of the Zoning Resolution of 1 978, as amended.
E. The Board of County Commissioners opened a public hearing on the 10th dayofAugust,2009
upon the question of whether the above- described Special Use Permit application should be granted
or denied, during which hearing the public and interested persons were given the opportunity to
express their opinions regarding the amendment.
F. The Board of County Commissioners closed the public hearing on the 106 day of
August, 2009 to make a final decision.
H. The Board on the basis of substantial competent evidence produced at the aforementioned
hearing, has made the following determinations of fact:
1. Proper posting and public notice were provided as required for the meeting before the
Board of County Commissioners.
2. The meeting before the Board of County Commissioners was extensive and complete,
that all pertinent facts, matters and issues were submitted and that all interested parties
were heard at that meeting.
3. The above stated and other reasons, the proposed Special Use Permit has been
determined to be in the best interest of the health, safety, morals, convenience, order,
prosperity and welfare of the citizens of Garfield County.
4. The application has met the requirements of Special Use Permit of the Garfield County
Zoning Resolution of 1978, as amended.
RESOLUTION
NOW THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Garfield
County, Colorado, that:
A. The forgoing Recitals are incorporated by this reference as part of the resolution.
B. The Special Use Permit on the 4.338 acre portion of a 45,000 acre property owned by
EnCana Oil and Gas (USA) Inc. requesting an Industrial Support Facility which includes
Material Handling, Pumping Facilities, Storage Yards and Processing for the North Parachute
Ranch Dill Fluids Recycling System on parcel number 213527300015, Garfield County, is
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hereby approved subject to compliance with the following conditions:
1. That all representations of the Applicant, either within the application or stated at the
hearing before the Board of County Commissioners, shall be considered conditions of
approval unless explicitly altered by the Board.
2. That the operation of the system be done in accordance with all applicable Federal,
State, and local regulations governing the operation of this type of facility.
3. That the Applicant shall comply with the fire protection provisions included in the
rules and regulations of the Colorado Oil and Gas Conservation Commission
(COGCC) and the International Fire Code as the Code pertains to the operation of this
system.
4. Vibration generated: the NPR Drill Fluids Recycling System shall be so operated that
the ground vibration inherently and recurrently generated is not perceptible, without
instruments, at any point of any boundary line of the property on which the use is
located.
5. Emissions of smoke and particulate matter: the Drill Fluids Recycling System shall be
so operated so as to comply with all Federal, State and County air quality laws,
regulations and standards.
6. Emission of heat, glare, radiation and fumes: the Drill Fluids Recycling System shall
be so operated that it does not emit heat, glare, radiation or fumes which substantially
interfere with the existing use of adjoining property or which constitutes a public
nuisance or hazard.
7. Volume of sound generated shall comply with the standards set forth in the Colorado
Revised Statutes, COGCC Series 800.
8. No storage of unused heavy equipment or materials is permitted.
9. No human habitation of this site is allowed at any time, other than the residence 3 miles
south of EnCana's gate.
10. Any lighting shall be pointed downward and inward to the property center and shaded
to prevent direct reflection on adjacent property.
11. Water pollution: in a case in which potential hazards exist, it shall be necessary to
install safeguards designed to comply with the Regulations of the Environmental
Protection Agency before operation of the facilities may begin. All percolation tests or
ground water resource tests as may be required by local or State Health Officers must
be met before operation of the facilities may begin.
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12. Prior to the issuance of the Special Use Permit, a reclamation security of $2500 per
acre shall be submitted for site disturbance, as per the Garfield County Vegetation
Manager. If the use as a NPR Drill Fluids Recycling System is ended, reclamation shall
be initiated within 60 days and meet the requirements set forth in the reclamation plan
in place on the date the Special Use Permit issued, or the site reclamation standards in
place at the time of use cessation, whichever is more stringent. The reclamation
standards at the date of permit issuance are cited in Section 4.06, 4.07 and 4.08 of the
Garfield County Weed Management Plan (Resolution #2002 -94).
A site visit shall be performed by the Garfield County Vegetation Management
Department to assess the site and determine the recommended acreage for the required
security.
13. All equipment to be permanently affixed on the site shall be painted with non - reflective
paint in neutral shades of desert tan or beetle green to make the site less conspicuous.
14. Dust mitigation on the sites and access roads must be performed to prevent fugitive
dust.
15. Prior to issuance of the Special Use Permit, written confirmation by a certified wildlife
biologist to ensure that no active nest sites for threatened or endangered species or
species of concern are within a distance considered by the Colorado Division of
Wildlife to be adversely affected by human activity, and that no threatened, endangered
plant species or plant species of concern are within the acreage to be affected by this
system.
16. Bear -proof refuse containers shall be required on the site.
17. A grading permit shall be required of any lines that are required to be buried as a part
of this system.
Dated this day of , A.D. 20 t 3 .
ATTEST:
ARFIEL C $ UNTY BOARD OF
MMIS.IONE `S, GARFIELD COUNTY,
LO
Upon motion duly made and seconded the
following vote:
dopted by the
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COMMISSIONER CHAIR JOHN F. MARTIN
COMMISSIONER MIKE SAMSON
COMMISSIONER TRESI HOUPT
, Aye
, Aye
Aye
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PROJECT INFORMATION AND STAFF COMMENTS
TYPE OF REVIEW:
SUMMARY OF REQUEST:
APPLICANT 1
PROPERTY OWNER:
LOCATION I ACCESS:
SITE INFORMATION:
EXISTING & ADJACENT ZONING:
I. REQUEST
The Applicant requests a SUP for the
installation of a Drill Fluids Recycling
System. This is a network of pits,
pipelines and pumps to transfer
produced water for use in completion
operations associated with the
production of natural gas on the North
Parachute Ranch (NPR).
BOCC - 8/10/09 DD
Special Use Permit ( "SUP ")
The Applicant requests a SUP for an 'Industrial Support
Facility which may include material handling, pumping
facilities, staging areas, storage areas and processing'
in the Resource Lands (RL) zone district.
EnCana Oil & Gas (USA) Inc.
Portions of Sections 19,27,28,29 of T5S, R95W and
Sections 15,22,25,26 of T5S, R96W I(Parcel # 2135-
273 -00 -015)
4.338 acres of a 45,000 -acre parcel owned by EnCana
Oil & Gas (USA) Inc.
Resource Lands (RL) Zone District, Open Space (BLM)
The system is fully contained on the
company -owned site 8.5 miles north
of Parachute on CR 215. Twenty -
seven (27) pits on existing COGCC-
approved well pads are proposed to
be connected with pipelines. The
pipeline system uses high carbon
steel and steel Flexpipe in varying
diameters: 4" at the pit, 8" connectors
feeding into a 12" line that links to the
Middle Fork Produced Water Storage
Facility (permitted in 2005.)
The Applicant represents the need for
this system to move produced water
from pad to pad and to the Middle
Fork Produced Water Storage Facility
via pipelines, rather than with trucks.
Moving fluids reduces the need for
additional fresh water; there is an
estimated savings of 1.26 to 2.52
million gallons per day.
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Ray understands Lou is elected as well.
Chairman Martin - As Sheriff he has to answer to the citizens on that particular issue.
Ray - I feel we can all work together here too. Maybe we need to build a prison for that purpose and normally if
they are caught here in Garfield County, they are going to spend some time.
Chairman Martin - Then we are responsible for their housing, food and medical expenses and instead of being on
the outside getting services they are getting it on the inside plus when you have them incarcerated, everyone that is
from the family gets the same benefit basically. Therefore, you have created another monster in that respect.
Ray - I understand but there still has to be - if it keeps this going on, we will have three Spanish - speaking people
sitting on the Board of County Commissioners.
Commissioner Samson - What Ray is saying; they are not citizens,
Chairman Martin - Yes, we need to work together and if we have contractors and businesses that are hiring illegal's,
then we need to follow the chain of command within the state and have enforcement there. That starts with
knowledge and if that knowledge is passed to the correct people and not just forgotten but also acted upon - that is
our true strength. If we just complain about it without any facts, we need the facts, we need to get it to the correct
person and if you have it you need to find the correct person, come to us and give us that information. We will fmd a
way to the correct person with you and send it along
Ray - Too many times, it has been reported to the Sheriff or like the Snowiness police and they say there is nothing
that we can to and then it is forgotten.
Commissioner Houpt - There is an ICE office in town too.
Ray - Is that a place paid by taxpayers money?
Commissioner Houpt - They are the ones who are supposed to be the ones who are enforcing_.
Ray - Typical federal taxpayer funded programs are a waste of our money. You call Colorado Workforce and ask
them to send some people down for you right now and they will send three illegal workers from the Colorado
Workforce Center. It is totally out of control I am not prepared with all of the information I know there are many
steps I could go to, to have more information to know exactly what the federal law says the Colorado law and try to
pinpoint who is more in charge and who is shifting the blame and who is not doing their job.
Commissioner Houpt - Everyone is passing the buck right now because we do not have a good solution and the
federal government is supposed to come up with something but we have not seen a good resolution on this yet.
Ray had an illegal tell him one day on the job and he was mad over it - he said, "Mexico was going to take back
over this country." I laughed at hint No "we are going to do it not with bombs and guns, we're going to breed it out
of your women." If I was a lawbreaker and wanted in Mexico for rape, theft, whatever, and this is the first place I
would come. I am appalled.
Chairman Martin - There are also solutions and that is the information we have and you have to share that and we
have to put it in the right channels to get the right results, It is frustrating but you cannot give up.
Ray - What you said, when I find them, write their names down, and talk to the companies.
Chairman Marlin - What needs to be done is go to the companies, not the individuals.
Ray - I heard a Congressman just say on the news the other day about health reform and he said in the bill they want
to have it to have insurance for the illegals as well The Congressman said, well they are doing our work here - they
should get the program as well. I am thinking, what is he talking about they are here illegally We have to elect
Congressman who are on this issue or the end of it is they just miss the whole boat.
CONSIDER A REQUEST FOR A MAJOR IMPACT REVIEW FOR A CAMPGROUND/RV PARK ON A
36.637 -ACRE PARCEL SOUTH OF BATTLEMENT MESA AND PARACHUTE OFF CR300 IN THE
RURAL (R) ZONE DISTRICT - APPLICANT: HIGH MESA PARTNERS, LLC. -DUSTY DUNBAR
Dusty Dunbar, Don DeFord, Jerry Rush from High Mesa Partners RV Park were present.
Jerry Rush requested a continuance for this Public Hearing He stated he would renotice everyone within the 200
feet requirements.
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Dusty Dunbar,TSou] l eFoTd; KhemSudfiiwan, 7ason Eckman and Kevin McDowell water engineer with EnCana
were present.
Deb reviewed the public notifications with Khem and determined they were timely and accurate, She advised the
Board they were entitled to proceed. The sign was posted on the guard shack and visible from CR 215
Chairman Martin swore in the speakers.
Dusty submitted the following exhibits: Exhibit A - Proof of Mail Receipts; Exhibit B - Proof of Publication;
Exhibit C - Garfield County Unified Land Use Resolution of 2008 as amended (ULUR Zoning Code); Exhibit D -
Garfield County Comprehensive Plan of 2000, as amended; Exhibit E- Application; Exhibit F - Staff report;
Exhibit G - Staff Power Point presentation; Exhibit H- Letter -Garfield County Road and Bridge Department,
Administrative Foreman, Jake Mall, dated 748.09; Exhibit I- Letter - Garfield County Vegetation Management
Department - Director, Steve Anthony, dated 7 -28 -09; Exhibit J - Letter - Garfield County Planning Department -
Project Engineer John Niewoebmer, PE, dated 7- 29 -09; Exhibit K- Email - Colorado Division of W lldlife (DOW) -
Game Officer, Dan Skinner for J.T. Romatzke, Area Wildlife Manager; Exhibit L - Noise Assessment Exhaust -
Mechanical; and Exhibit M - Email - Garfield County Public Health Department - Environmental Health Manager,
Jim Rada dated 8 -6-09.
Chairman Martin entered Exhibits A - M into the record.
This is under the old code.
Request: The applicant requests a SUP for the installation of a Drill Fluids Recycling System- This is a network of
pits, pipelines and pumps to transfer produced water for use in completion operations associated with the production
of natural gas on the North Parachute Ranch (NPR).
The system is fully contained on the company -owned site 8.5 miles north of Parachute on CR 215. Twenty -seven
(27) pits on existing COGCC approved well pads are proposed to be connected with pipelines. The pipeline system
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uses high carbon steel and steel Flex pipe in varying diameters: 4" at the pit, 8" connectors feeding in to a 12" line
that links to the Middle Fork Produced Water Storage Facility (permitted in 2005).
The applicant represents the need for this system to move produced water from pad to pad and to the Middle Fork
Produced Water Storage Facility via pipelines, father than trucks Moving fluids reduces the need for additional
fresh water; there is an estimated savings of 1.26 to 2.52 million gallons per day.
Because the use is a system of pipelines to connect produced water pits to other facilities there will be a definite
reduction in the number of tanker trucks required to haul the millions of gallons of fluid. There is a limited traffic
analysis provided. As noted earlier, the Drill Fluids Recycling System, once fully operational is expected to reduce
the number of vehicles by 120,000 trips per year , All travel traveling Garfield County is on roads built for well
beyond that level of traffic and that kind of vehicle Much of the traffic is on private roads on the NPR.
The operations at the facility will not adversely affect any abutting property, provided the facility operates within its
proposed levels. The proposed system will not encroach upon existing setbacks or reduce current separation
distances to abutting properties. Staff agrees that the Drill Fluids Recycling System is located well within required
setbacks and is sufficiently separated from adjacent properties in all directions.
In the past, the Board has required, as a condition of approval that "A sufficient monetary security, determined by the
Board of County Commissioners, to ensure rehabilitation of the site once operation has ceased shall be provided by
the Applicant "
Re- vegetation securities are standard for these kinds of applications and shall be conditions of approval. While the
well pads on which the pits are located are secured by a COGCC blanket bond, this security does not cover portions
of the Drill Fluids Recycling System that are off the well pads, namely, the connecting pipelines. Much of the
proposed pipeline that will be used in this system is already in place, so the disturbance has already occurred. (Other
portions of the system are proposed to be temporarily laid on the surface.)
Should the Board approve the request for the Drill Fluids Recycling System, Staff suggests the industrial
performance standards be considered conditions of approval as they are specifically intended to ensure that any
industrial use (such as this system) function in accordance with the proper best management practices and within the
parameters of the State statutes.
There is limited proposed storage for heavy equipment on the site; diesel and electric generators to operate the
pumps will be in operation at varying locations on the system. An additional submittal of noise assessment for the
diesel generators required to operate the pumps (Exhibit L ) shows that the noise level at maximum output is 100
dB(A) within 4 feet of the operating machinery; dropping to 79 dB(A) at 49.2 feet
Staff estimates that the noise level at the property boundary or 350' from an occupied residence would be below 70
dB(A), the industrial noise level from the Colorado Revised Statutes. There is no residence near any of the boundary
location with the exception of D28, which is estimated by Staff to be more than one -half mile from the residence,
and it has been stated that the residence is not inhabited. The equipment is represented to be transient, moving from
location to location, always in use and therefore not stored.
The requirement for screening should not be required as the site is remote, bounded on three sides by steep canyon -
walls, far from human occupation. The boundary of the nearest potentially affected parcel (on the east side) is more
than 1700 feet away. Painting permanent installations a neutral shade of non - reflective paint will help to make the
site more inconspicuous.
The site is not situated to allow vibration to emanate beyond the boundaries, nor have fumes or other emanations
off site. The site is not proposed to be used for storage, aside from limited produced water, which shall, as a
condition of approval, be properly stored in approved lined pits inside an adequately sized spill containment basin.
Lighting will be provided by portable lighting plants, and directed downward and inward onto whatever site to
which they have been assigned.
Staff does not recommend periodic review of the site as the conditions will serve as a mechanism for operating
within the necessary standards of the permit.
bT�_ F_RE, O}OIFirllATI_PN)
Due to the &flowing conditions:
■ the limited nature of potential impacts to surrounding properties,
■ the remote location of the property,
■ the proposed is required to operated within compliance for noise and mitigate glare and other
emanations,
Staff recommends the Board approve the request for a Special Use Permit for EnCana Oil & Gas (USA)'s NPR
Drill Fluids Recycling System with the following conditions:
1) That all representations of the Applicant, either within the application or stated at the hearing before the
Board of County Commissioners, shall be considered conditions of approval unless explicitly altered by the
Board_
2) That the operation of the system be done in accordance with all applicable Federal, State, and local
regulations governing the operation of this type of facility.
3) That the Applicant shall comply with the fire protection provisions included in the rules and regulations of
the Colorado Oil and Gas Conservation Commission (COGCC) and the International Fire Code as the
Code pertains to the operation of this system.
4. Vibration generated: The NPR Drill Fluids Recycling System shall be so operated that the ground vibration
inherently and recurrently generated is not perceptible, without instruments, at any point of any boundary
line of the property on which the use is located.
5. Emissions of smoke and particulate matter: the Drill Fluids Recycling System shall be so operated to
comply with all Federal, State and County air quality laws, regulations and standards.
6. Emission of heat, glare, radiation and fumes: the Drill Fluids Recycling System shall be so operated that it
does not emit heat, glare, radiation or fumes which substantially interfere with the existing use of
adjoining property or which constitutes a public nuisance or hazard.
7. Volume of sound generated shall comply with the standards set forth in the Colorado Revised Statutes,
COGCC Series 800.
S. No storage of unused heavy equipment or materials is permitted.
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9. No human habitation of this site is allowed at any time, other than the residence 3 miles south of EnCana's
gate.
10. Any lighting shall be pointed downward and inward to the property center and shaded to prevent direct
reflection on adjacent property.
11. Water pollution. In a case in which potential hazards exist, it shall be necessary to install safeguards
designed to comply with the Regulations of the Environmental Protection Agency before operation of the
facilities may begin All percolation teats or ground water resource tests as may be required by local or
State Health Officers must be met before operation of the facilities may begin. Modified in line with him
Rada's comments,
12. Prior to the issuance of the Special Use Permit, a reclamation security of $2500 per acre shall be submitted
for site disturbance, as per the Garfield County Vegetation Manager. If the use as a NPR Drill Fluids
Recycling System is ended, reclamation shall be initiated within 60 days and meet the requirements set
forth in the reclamation plan in place on the date the Special Use Permit issued, or the site reclamation
standards in place at the time of use cessation, whichever is more stringent. The reclamation standards at
the date of permit issuance are cited in Section 4.06, 4.07 and 4.08 of the Garfield County Weed
Management Plan (Resolution #2002 -94) Site visit was included by the County Vegetation Manager to
be determined after the on -site visit.
13. All equipment to be permanently affixed on the site shall be painted with non - reflective paint in neutral
shades of desert tan or beetle green to make the site less conspicuous.
14, Dust mitigation on the sites and access roads must be performed to prevent fugitive dust
15. Prior to issuance of the Special Use Permit, written confirmation by a certified wildlife biologist to ensure
that no active nest sites for threatened or endangered species or species of concern are within a distance
considered by the Colorado Division of Wildlife to be adversely affected by human activity, and that no
threatened, or endangered plant species or plant species of concern are within the acreage to be affected by
this system.
16. Bear.proof refuse containers shall be required on the site.
Dusty asked to speak to these conditions in No. 9 to be more clear `that no human habitation of this site is
allowed at any time other than the residence and sited the located the site of that residence." It was unclear
until fairly late in the analysis as to whether or not this was an abandoned farm house or an occupied farm
house. It is occupied and therefore the conditions have been revised to reflect this.
No. 11 -- Dusty, in response to the analysis from Jim Rada's continents and the oil and gas liaison analysis
contribution about COOCC proposed this addendum to Condition No. 11 and it calls for a plan to the
satisfaction of Garfield County's Environmental Health Department shall be developed by the applicant to
provide on -going verification that the indignity of the system is not allowing drill fluids to escape into the
soil and water. Part of the plan shall be letter stating the results of all annual reports required under
COGCC regulations to ensure integrity of both sub - terrain and surface flow and gathering lines used as
components to be provided within 30 -days of the report so we have the current assessment and
information.
No. 12 - Dusty left out a portion of the requirement whereby the Garfield County Vegetation Management
Department requested a site visit to do an assessment over this large province to determine what the
adequate response was. The applicant has shared their willingness to work with them to come up with a
reasonable response. This was balanced against requiring this for the entire acreage, part of and it was best
to allow the specialist to go on site and determine what really needed to be done "A site visit shall be
performed by the Garfield County Vegetation Management Department to assess the site and determine
the recommended acreage for the required security."
No. 15 - Mostly talks about the surface lines that will be laid across the area.
Commissioner Houpt - For clarification, this is a 4.33 acre project but isn't it a project that includes all these
various pads.
Dusty - It does, the 4.33 acres made the conditions hard to write because the 4.33 acres is the acreage covered
in and affected by the distinct ponds; it may not include the acreage that is affected by the surface lines
that are laid out and, that is why I tried to have a condition of approval to come up with the effective
acreage.
Commissioner Houpt - Is there anything included concerning a grading permit?
Dusty - There are not interring anything. The surface lines are laid out on the top of the ground. They
represented no interment If the applicant changes that Dusty would then recommend a condition requiring
adequate grading permits to be in place prior to site disturbance.
EnCana Presentation:
Jason Eckman stated they did not have anything to add, they have looked through the conditions, and fat that
we can meet them.
Chairman Martin - All lines that are being laid are going to be on the surface or will there be any digging of
holes to put them in. The drainage area along the roadways will collect everything for recycling pipelines.
Jason - They will be surface lines and if we do determine later on that, we need a larger line that needs to be
buried then we will certainly let you know.
Chairman Martin - You would need a new application in reference if you change the size and decide to bury it.
Dusty - It might be a safeguard to add that as a condition.
The Board agreed.
Commissioner Houpt That would be condition No 17.
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presen* Eby staff; uicludiag evwrdmg ir-- - 11,15 and added Co-iid o:4 :.N - .i 7: Comnxtss Samwa
fkik'` -vtipt ay Martin ,aye samsiin:,eyg5 - J
N (DER A ' t Olt AYQNITEDTMl Cr i17IEW FOR STORAGE, SUPPLIES,
MACHINERY, EQUIPMENT OR PRODUCTS ON 3.12 ACRES OF A 44.61 -ACRE PARCEL IN THE
RURAL (It) ZONE DISTRICT. APPLICANT IS ENCANA OIL & GAS (USA) INC. - DUSTY DUNBAR
352