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HomeMy WebLinkAbout5.0 BOCC Staff Report 09.11.2006Exhibits (09/11/06) A Proof of Mail Receipts B Proof of Publication C D Garfield County Zoning Regulations of 1978, as amended (the Zoning Code) Staff Memorandum E Application F Memo from the County Road and Bridge Department dated 8/7/06 G Comments from the County Vegetation manager dated 9/01/06 BOCC — 09 /11 /06 FJ PROJECT INFORMATION AND STAFF COMMENTS TYPE OF REVIEW: SUMMARY OF REQUEST: • APPLICANT/PROPERTY OWNER: LOCATION: SITE INFORMATION: WATER: SEWER: ACCESS: EXISTING ZONING: Referral of Special Use Permit ( "SUP ") The Applicant requests a SUP for an amendment to an existing SUP for the storage of vacuum trucks and frac tanks, office, and truck maintenance and wash shop. Dalbo, Inc. The subject property is approximately 1.25 miles south on County Road 319. 35 acres Well Individual Sewage Disposal System Driveway off of County Road 319 A/R/RD (Agricultural / Residential / Rural Density) 1 rl-W4i Xn' 07-F14EAX.IIIC,N reFF. FAN. f123 brx-X,c,. ,.KSR3.irr G NEV. TANK. VA. 7 2L'X 2.'1,.I .1EQ ,-NETS TRUCK Yic. s.. aye tifsTr-;io R. I. BACKGROUND As you will recall, the Board approved a Special Use Permit in August 2003 for the creation of a storage yard for vacuum trucks and frac tanks, an office, and a maintenance shop on the subject property on CR 319. The Applicant indicated that that the proposed uses include the following: 1. Storage of 30 vacuum trucks 2. Storage of 200 frac tanks 3. Office and operations management 4. Maintenance of trucks inside shop 5. Washing of trucks 6. Potassium Chloride storage (or KCL is a week salt mixture, non -toxic and non- hazardous) used in down hole operation and maintenance of oil and gas wells. Dalbo, Inc. has been in the oil and gas service business since 1970. Dalbo, Inc. has operations in Utah, Wyoming, Colorado, and California. The home office is in Vernal, Utah. Dalbo, Inc. owns and operates vacuum trucks and rents frac tanks to oil and gas companies for the extraction of oil and gas natural resources. The primary function of the existing use is the hauling of fresh water for drilling, renting frac tanks, filling frac tanks with fresh water and KCI water, and hauling of produced water (salt water) to disposal pits. Site Description: The property has two very distinct topographic areas. The first area, a flatter or slightly slope area, contains approximately 15 acres. This area is used for the storage yard and maintenance shop. Intermittent small patches of native grass exist on this area. Sagebrush and other small native plants are sparse. Two sides of this area have existing fences. According to the Applicant, the fence was constructed for the purpose of keeping cattle on the adjacent property. There is also a very distinct drainage that traverses the property. The Applicant placed a culvert in this drainage. The second area of the property, along the northern boundary line, consists of the remainder 20 acres. This area is defined by a small hill. Sagebrush, cedar trees and intermittent small patches of grass sparsely cover this area. No disturbance of this hill is proposed. Zoning: The subject property is zoned A/R/RD (Agricultural / Residential /Rural Density). The type of use requested falls under the definition of "Storage" which is a Special Use in the A/R/RD zone district. "Storage" is a subcategory of "Industrial Operations CIassification ", therefore it is subject to the standard outlined in Section 5.03.07 of the Garfield County Zoning Resolution. The office, 2 maintenance, and truck wash should be considered accessory to the storage yard. Adjacent Land Uses: The area surrounding the proposal is pre - dominantly rangeland with similar, oil and gas, type land uses. 1. North: 2. South: Encana / Benzel Evaporation Pit 3. East: Vacant 4. West: Vacant . s . 0 • - V- I II. REQUEST The Applicant proposes to make the following changes to their operations which require a new SUP. (See the attached Impact Statement & Site Plan) 1) Increase size of office from 1040 to 2080 square feet; 2) Construct a covered outdoor parts storage on the east side of the maintenance shop and expend current parts storage to 25' x 15'; 3) Change the use of the wash bay to a maintenance shop and relocate the wash bay to a separate location on the site (20 x 20 shed); 4) Add an additional 1,000 bbl tank at the tank farm; 5) Increase the number of trucks stored from 30 to 80 at the site, III. REFERRAL COMMENTS The application was sent to the following referral agencies / departments and their comments are incorporated into the memo as appropriate. A. City of Rifle: No Comments Received B. Garfield. County Road & Bridge Department: (See Exhibit F) C. Garfield County Vegetation Management: (See Exhibit G) IV. REVIEW STANDARDS The following standards apply to the proposed expansion of the existing use. Staff has provided the standard (in bold italics) followed by the Applicant's response and any additional staff comments. Section 5.03 of the Zoning Resolution of 1978, as amended {I) Utilities adequate to provide water and sanitation service based on accepted engineering standards and approved by the Board of County Commissioners shall either be in place or shall be constructed in conjunction with the proposed use. Response: Presently, water for the office, shop and truck wash is provided by an existing and permitted water well. A septic system was designed to accommodate the wastewater from the two 3 restrooms in the office / shop. The Applicant has provided a copy of the well and septic permits. It appears that this minimal expansion will not require any additional water or septic use. (2) Street improvements adequate to accommodate traffic volume generated by the proposed use and to provide safe, convenient access to the use shall either he in place or shall be constructed in conjunction with the proposed use; Staff Response: The property has direct access onto CR 319. A driveway permit and improvements were made as a part of the original SUP approvals. The County Road and Bridge Department reviewed the expansion and provided the following comments and requirements: New traffic counts on CR 319 (West Mamm Creek Road) were taken between August 7, 2006 and August 16, 2006 showing a total of 9,388 vehicles during this period. The increased traffic load generated by this expansion would justify Dalbo adding new gravel to CR 319 from the Grass Mesa Road at the end of the paved portion past the entrance to the evaporation pit. The new gravel would also require a dust control agent (Mag. Chloride) application. The application rate would be at .6 of gallon per square yard. Our request is that Dalbo pay for the gravel, hauling to the site, supply water trucks for the project and pay for the Mag. Chloride. Garfield County Road & Bridge Department will place the gravel and compact it. Garfield County Road & Bridge Department will contract for the Mag. Chloride from our supplier and back charge Dalbo for the cost of the product. The depth of the gravel would be 4- inches at 24 feet wide. The amount of gravel would be determined after approval of the application by the BOCC. Dalbo would also be required to participate in all future applications of Mag. Chloride for the same distance when required. If these improvements are completed, this standard will be met. (3) Design of the proposed use is organized to minimize impact on and frotn adjacent uses of land through installation of screen fences or landscape materials on the periphery of the lot and by location of intensively utilized areas, access points, lighting and signs in such a manner as to protect established neighborhood character; Response: The area surrounding the property storage yard is vacant except for gas wells to the north and one of EnCana' s evaporation pit and storage yards to the south on the Benzel property which has an approved SUP. There are no homes, subdivisions, irrigated lands, and retail or commercials operations in the area. The Applicant has installed a 5' security fence along a portion of the boundary line as well as follows the base of the hill on the rear of the property preventing any disturbance of this hill area to keep it in its natural form. Lighting has been installed to light up the area around the shop and the office. This lighting will be on an electric eye to turn on at dark. The lighting used will be directed to minimize any off -site glare. The Applicant has also installed a 4' X 8' non - lighted sign will be erected to identify the facility that complies with the county sign standards. The Applicant, as a requirement from the original SUP, installed landscaping along CR 319 in front of 4 the main shop building which has been installed. The new minimal additions to the structures and additional truck storage will not adversely affect the surrounding character of the area. Section 5.03.07 for Industrial Operations Industrial Operations: Industrial Operations, including extraction, processing, fabrication, industrial support facilities, mineral waste disposal, storage, sanitary landfill, salvage yard, access routes and utility lines, shall be permitted, provided: (A) Existing lawful use of water through depletion or pollution of surface run -off, streamflow or ground water. Again, water for the office, shop, and truck wash has been obtained and the expansion will not require any additional water. A septic system has been designed to accommodate the wastewater from the two restrooms in the office / shop. The tank farm south of the shop has been surrounded by a concrete containment wall with a concrete floor. A 4' diameter culvert was placed in the wash to allow surface run -off to continue through the property. The yard has been graveled and the property slopes away from County Road 319, so that little or no water, dirt, or mud is carried onto the county road. The Applicant does not propose to change the general topography of the property with any of the new expansion. A new concrete pad will be constructed to replace the existing one in a new location to catch the wastewater from the truck wash and the water will be reused similar to a car wash. The water and silt will flow to a concrete collection sump. When it becomes necessary to remove the silt from the collection sump, a backhoe and dump truck will be used to collect and haul the silt to the landfill. The truck wash is a concrete self - contained unit. The Applicant asserted that no truck wash water would impact the ground water or the surface runoff. Frac tanks and vacuum trucks will be stored on site empty. (B) Impacts on adjacent land from the generation of vapor, dust, smoke, noise, glare or vibration, or other emanations. Response: The Applicant noted that the maintenance shop will normally have its doors closed. Any noise, smoke, dust, vibration, or other emanations from the shop should be minimal. No painting, sandblasting, or manufacturing of new equipment will take place at the shop. Storage of maintenance fluids (motor oil, antifreeze, transmission fluid, etc.) will be stored inside the shop. The Applicant indicated that when a truck is started a minimal amount of smoke and noise will be created. A minimal amount of welding, for minor repair only, will be done in the shop. All manufacture of trucks and tanks is done off site. A used oil containment tank will be placed outside of the shop to hold used oil. Use oil will be collected periodically. 5 In the event of potential violations with respect to vapor, dust, smoke, noise, glare or vibration, the Applicant will be required to provide proof of compliance with applicable Federal, State, and County Iaws, regulations and standards. (C) Impacts on wildlife and domestic animals through the creation of hazardous attractions, alteration of existing native vegetation, blockade of migration routes, use patterns or other disruptions. Response: The application did not contain an analysis of wildlife impacts on the property. There is existing fence that has been installed on the property by the previous property owner which has probably disrupted the migration routes or use patterns by wildlife habitat if it existed. The proposed use should not result in increased adverse impacts to wildlife or domestic animals through creation of hazardous attractions, alteration of existing native vegetation, blockade of migration routes, use patterns or other disruptions. The activities of the expanded business will not result in the generation of products or waste products that will attract wildlife or domestic animals. (D) Affirmatively show the impacts of truck and automobile traffic to and from such uses and their impacts to areas in the County. Response: Previously, Applicant has noted that County Road 319 is one of the main roads being used by EnCana to access their gas extraction activities. The Applicant feels that there are some distinct advantages to locating on the subject property. These include: 1. Currently, all of Dalbo's vacuum trucks are traveling into the Rifle area via 1 -70 from Grand Junction and Debeque. The vacuum traffic should decrease on the freeways and secondary roads. The truck drivers will drive their personal vehicles to the yard each day, pick up the trucks and go to work. 2. The tank storage yard is currently located in a leased yard on the west Rifle I -70 frontage road. Winch trucks travel to the yard to retrieve our tanks and move them to various oil field locations. If the tanks were located in the new yard, the winch truck traffic would also decrease, because access to the oil field locations would be closer to the new storage yard. 3. The KCI storage tanks are also located in the leased yard on the west Rifle 1-70 frontage road. Vacuum trucks travel on this frontage road to load the KCI water and haul to various oil field locations. The across town traffic on secondary roads should decrease. (E) That sufficient distances shall separate such use from abutting property which might otherwise be damaged by operations of the proposed use(s). Response: Much of the adjacent land is vacant except for EnCana's evaporation pit to the south and gas wells and tanks to the north. There are no homes or neighborhoods adjacent to the property. The Applicant noted that the SUP request coincides with the current land uses on adjoining properties. 6 (F) Mitigation measures proposed for all of the foregoing impacts identified and for the standards identified in Section 5.03.08 of this Resolution Response: Mitigation measures for all of the foregoing impacts identified have been addressed throughout this memorandum. Mitigation measures for the standards identified in Section 5.03.08 [Industrial Performance Standards] of the Garfield County Zoning Resolution are addressed in this memorandum. Special Use Permits may be granted for those uses with provisions that provide adequate mitigation for the following: (A) A plan for site rehabilitation must be approved by the County Commissioners before a permit for conditional or special use will be issued; Response: The Board approved the following steps will be followed for "partial" rehabilitation of the property: A. All frac tanks shall be hauled away. B. All vacuum trucks shall be driven away. C. All KCI storage tanks shall be hauled away. D. Building and structures may stay and be sold to other industrial uses. E. Replacement of stockpiled topsoil. F. Compliance with all prevailing COGCC and Garfield County regulations governing final reclamation. Staff is of the opinion that the proposed "partial" rehabilitation plan of the property is the preferable plan. Steve Anthony, Director of Vegetation Management, previously noted that the primary concern is that the storage facility could act as a vector that will facilitate the spread of weed seeds throughout the County as various items will be stored on site and than transported to other areas. Weeds on the Garfield County Noxious Weed list are not common on this site, however, cheatgrass (bromus tectorum) is found in the area. Cheatgrass is not a county- listed noxious weed, however, it is a State of Colorado listed noxious weed. Cheatgrass is an invasive species that quickly spreads and it poses an immediate fire hazard once it has been established. The seed of cheatgrass has a very long awn and will attach itself to vehicles and other items. The obvious concern is the potential of cheatgrass to attach itself to any of these items that are stored on site and to be carried to a previously cheatgrass free site. Mr. Anthony indicated that the Applicant shall provide to the County a commitment to minimize the spread of cheatgrass through any activities on site. This may include, but is not limited to, 1) a plan 7 to wash items before they leave the site, and 2) a plan that details how cheatgrass seed production will be eliminated. (B) The County Commissioners may require security before a permit for special or conditional use is issued, if required. The applicant shall furnish evidence of a bank commitment of credit, bond, certified check or other security deemed acceptable by the County Commissioners in the amount calculated by the County Commissioners to secure the execution of the site rehabilitation plan in workmanlike manner and in accordance with the specifications and construction schedule established or approved by the County Commissioners. Such commitments, bonds or check shall be payable to and held by the County Commissioners; Response: The Applicant shall comply with this provisions if deemed necessary by the Board of County Commissioners. The Applicant asserted that if any bonds, commitments, or other security is deemed necessary, the Applicant will comply. (C) Impacts set forth in the impact statement and compliance with the standards contained in Section 5.03.08 of this Resolution. (A. 93 -061) Response: See responses in Section 5.03.08 below. Section 5.03.08 [Industrial Performance Standards }: Pursuant to section 5.03.08 of the Zoning Resolution, all Industrial Operations in the County shall comply with applicable County, State, and Federal regulations regulating water, air and noise pollution and shall not be conducted in a manner constituting a public nuisance or hazard. Operations shall be conducted in such a manner as to minimize heat, dust, smoke, vibration, glare and odor and all other undesirable environmental effects beyond the boundaries of the property in which such uses are located, in accord with the following standards: (1) Volume of sound generated shall comply with the standards set forth in the Colorado Revised Statutes at the time any new application is made. Response: Volume of sound generated by the proposal has been addressed previously in this memorandum. The Applicant noted that the proposed operation shall comply with the maximum standards established in the CRS 25 -12 -103. Upon a receipt of a legitimate allegation of a violation with respect to noise, the Applicant will be required to provide proof of compliance with State dB levels. (2) Vibration generated: every use 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. 8 Response: No vibration is anticipated with the proposed use. Upon a receipt of a legitimate allegation of a violation with respect to vibration, the Applicant will be required to provide proof of compliance with applicable Federal, State, and County laws, regulations and standards. (3) Emissions of smoke and particulate matter: every use shall be operated so as to comply with all Federal, State and County air quality laws, regulations and standards. Response: No emissions of smoke and particulate matter are anticipated as part of this project. Upon a receipt of a legitimate allegation of a violation with respect to smoke or particulate matter, the Applicant will be required to provide proof of compliance with applicable Federal, State, and County laws, regulations and standards. (4) Emission of heat, glare, radiation and fumes: every use 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. Flaring of gases, aircraft warning signals, reflective painting of storage tanks, or other such operations which may be required by law as safety or air pollution control measures shall be exempted from this provision. Response: No emission of heat or radiation is anticipated as part of this project, aside from the emissions from the trucks. Upon a receipt of a legitimate allegation of a violation with respect to the emission of heat and radiation by the proposed use, the Applicant will be required to provide proof of compliance with applicable Federal, State, and County laws, regulations and standards. Propane is used to heat the office and shop. The 1,000 gallon propane tank has been located between the shop and the truck wash. (5) Storage area, salvage yard, sanitary landfill and mineral waste disposal areas: (A) Storage of flammable or explosive solids or gases shall be in accordance with accepted standards and laws and shall comply with the national, state and local fire codes and written recommendations / comments from the appropriate local protection district regarding compliance with the appropriate codes; Response: The Applicant noted that any flammable soils or gases will be stored in accordance with accepted laws and standards. The Applicant shall comply with all Local, State and Fire Codes that pertain to the operation of this Facility. (B) At the discretion of the County Commissioners, all outdoor storage facilities may be required to be enclosed by fence, landscaping or wall adequate to conceal such facilities from adjacent property; Response: The Applicant asserted that if required, fencing or landscaping of the facility from adjacent properties will be accomplished. 9 (C) No materials or wastes shall be deposited upon a property in such form or manner that they may be transferred off the property by any reasonably foreseeable natural causes or forces; Response: No materials or waste are associated with the proposed use. All garbage generated will be stored within standard garbage receptacles and will be removed accordingly. (D) Storage of Heavy Equipment will only be allowed subject to (A) and (C) above and the following standards: 1. The minimum lot size is five (5) acres and is not a platted subdivision. 2. The equipment storage area is not placed any closer than 300 ft. from any existing residential dwelling. 3. All equipment storage will be enclosed in an area with screening at least eight (8) feet in height and obscured from view at the same elevation or lower. Screening may include berming, landscaping, sight obscuring fencing or a combination of any of these methods. 4. Any repair and maintenance activity requiring the use of equipment that will generate noise, odors or glare beyond the property boundaries will be conducted within a building or outdoors during the hours of 8 a.m. to 6 p.m., Mon. -Fri. 5. Loading and unloading of vehicles shall be conducted on private property and may not be conducted on any public right -of -way. Response: The subject property is 35 acres in size and is not part of a platted subdivision. There are no residential dwellings within 300 ft. of the property. The Applicant noted that if deemed necessary, the storage area will be screen. All repairs and maintenance will be conducted within the shop. All loading and unloading of equipment will occur on the property. (E) Any storage area for uses not associated with natural resources, shall not exceed ten (10) acres in size. (A97 -112) Response: The Applicant noted that the storage areas are associated with natural resources extraction. (F) Any lighting of storage area shall be pointed downward and inward to the property center and shaded to prevent direct reflection on adjacent property (A97 -112) Response: Lighting has been previously installed to light up the area around the shop / office and the tank farm. The locations of the proposed lights are delineated on the site plan. This lighting is motion sensored to turn on at dark. The lighting used will be directed to minimize any off premise lighting. A condition of approval remains that all lighting shall be directed inward and downward towards the interior of the property at all times. 10 (6) 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. Response: The only chemical being stored on site will be a weak salt solution that is non -toxic and non - hazardous, known as potassium chloride (KC1). The maximum amount to be store on site would be 2,500 bbls. The Applicant has provided a copy of the Material Safety Data Sheet on KC1. There is no real or potential impact to surface or ground water supplies. In the event of potential violations with respect to water pollution, the Applicant will be required to provide proof of compliance with applicable Federal, State, and County laws, regulations and standards which primarily includes the Colorado Department of Public Health and Environment / Air / Water Quality Control Division. V. SUGGESTED FINDINGS 1. That proper public notice was provided as required for the hearing before the Board of County Commissioners. 2. That the hearing 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. That for the above stated and other reasons, the proposed Special Use Permit is in the best interest of the health, safety, morals, convenience, order, prosperity and welfare of the citizens of Garfield County. 4. That the application is in conformance with Section 5.03, 5.03.07, and 5.03.08 of the Garfield County Zoning Resolution of 1978, as amended. VI. STAFF RECOMMENDATION The proposal appears to double the size of the office, add 50 new vacuum trucks to the operations, and add a new truck wash facility. While these are increases to the existing facility, the site is already converted to the existing use with little adverse visual affect to the existing area. As a result, Staff recommends the Board approve the expansion with the following conditions: 1. All representations of the Applicant, either within the application or stated at the meeting before the Board of County Commissioners, shall be considered conditions of approval, unless specifically altered by the Board. 2. The Applicant shall comply with all applicable requirements of the Garfield County Zoning Resolution of 1978, as amended. 3. The Applicant shall comply with all State and Federal regulations and standards, such as Noise 11 Abatement, Water and Air Quality. 4. The Applicant shall comply with the Vegetation Plan approved by the Garfield County Vegetation Manager to minimize the spread of cheatgrass through any activity on -site. The Plan includes, but is not limited to, washing items before they leave the site and spraying the yard each year to control cheatgrass. . The Applicant shall comply with the following recommendations from the Garfield County Road and Bridge Department: A. The Applicant shall be required to add new gravel to CR 319 from the Grass Mesa Road at the end of the paved portion past the entrance to the evaporation pit. This new gravel shall also require a dust control agent (Mag. Chloride) application. The application rate shall be at 0.6 of gallon per square yard. B. The Applicant shall obtain the gravel, haul it to the site, and supply water trucks for the project and pay for the Mag. Chloride. Garfield County Road & Bridge Department has agreed to place the gravel and compact it. Garfield County Road & Bridge Department will contract for the Mag. Chloride from our supplier and back charge the Applicant for the cost of the product. C. The depth of the gravel would be 4- inches at 24 -feet wide. The amount of gravel would be determined after approval of the application by the BOCC. The Applicant shall also be required to participate in all future applications of Mag. Chloride for the same distance when required. 6. Vibration, emission of smoke and particulate matter, and the emission of heat. or radiation shall comply with applicable Federal, State, and County laws, regulations and standards. 7. The Applicant shall comply with all Local, State and Federal Fire Codes that pertain to the operation of this type of facility, this shall include compliance with the National Fire Protection Association and the Colorado Department of Labor and Employment, Oil Inspection Section for the fuel farm (tank farm on the site plan). The Applicant shall also work with the Rifle Fire Protection District to mitigate any fire protection concerns with regards to the additional 1,000 gallon LP tank. S. Any signage installed on -site shall comply with the County's sign regulations. 9. Any changes to the Special Use Permit shall require a new Special Use Permit. 10. Partial rehabilitation of the property, should the use terminate, shall consist, at a minimum, of the following: 12 A. All frac tanks shall be hauled away. B. All vacuum trucks shall be driven away. C. All KCl storage tanks shall be hauled away. D. Building and structures may stay and be sold to other industrial uses. E. Replacement of stockpiled topsoil. F. Compliance with all prevailing COGCC and Garfield County regulations governing final reclamation. 11. Prior to the issuance of the Special Use, Permit, the Applicant shall provide a copy of an approved City of Rifle Watershed Permit, if required, for this expansion. 12. Groundwater resources shall be protected at all times. In the event of potential violations with respect to water pollution, the Applicant shall provide proof of compliance with applicable Federal, State and County laws, regulations and standards. 13. All parking (vacuum tanks) along the south end of the property shall be set back and in line with the office / maintenance shop. 14. All lighting on the property shall be inward and downward with limited glare off site. 15. The subject property shall not become a regional parking and maintenance facility. /)0, 2D + 13 GARFIELD COUNTY Building & Planning Department Review Agency Form Date Sent: August 7, 2006 Comments Due: August 29, 2006 Name of application: Dalbo Inc. Expansion at Rifle Facility Sent to: Garfield County Road & Bridge Dept. 2 EXHIBIT t Garfield County requests your comment in review of this project. Please notify the Planning Department in the event you are unable to respond by the deadline. This form may be used for your response, or you may attach your own additional sheets as necessary. Written comments may be mailed, e- mailed, or faxed to: Garfield County Building & Planning Staff contact: Fred Jarman 109 8th Street, Suite 301 Glenwood Springs, CO 81601 Fax: 970 -384 -3470 Phone: 970- 945 -8212 General Comments: Garfield County Road & Bridge Department has no objection to this application with the following comments. New traffic counts on Cr. 319 West Mamm Creek Road were taken between Au ust 7 2006 and August 16, 2006 showing a total of 9,388 vehicles during this period. The increased traffic load generated by this expansion would justify Dalbo adding new gravel to Cr. 319 from the Grass Mesa Road at the end of the paved portion past the entrance to the evaporation pit. The new gravel would also require a dust control agent (Mag. Chloride) application. The application rate would be at .6 of gallon per square yard. Our request is that Dalbo pay for the gravel, hauling to the site, supply water trucks for the project and pay for the Mag. Chloride. Garfield County Road & Bridge Department will place the gravel and compact it, Garfield County Road & Bridge Department will contract for the Mag. Chloride from our supplier and back charge Dalbo for the cost of the product. The depth of the gravel would be 4- inches at 24 -feet wide. The amount of gravel would be determined after approval of the application by the BOCC. Dalbo would also be required to participate in all future applications of Mag. Chloride for the same distance when required. Name of review agency: Garfield County Road and Bridge Dept By: Jake B. Mall Date August 24, 2006 Revised 3/30/00 EXHIBIT MEMORANDUM To: Fred Jarman From: Steve Anthony Re: Comments on the Dalbo Expansion Special Use Permit Date: September 1, 2006 I have no concerns as long as the conditions of approval listed under Resolution 2003 -65 are followed.