HomeMy WebLinkAbout1.0 Application EnCanaEnCana Oil& Gas (USA)lnc.
EnCana Oil& Gaa (USA) Inc. tel: (970) 28$2825
27{7 County Road 215, Sulte 100 fax: (970) 28$2691
Parachute, CO 81635 renata.busch@encana.com
February 25,2AlA
Molly Orkild-Larson / Senior Planner
Garfield County Planning Dept - Rifle Airport ffice
0375 County Road 352- Building #2060
Rifle, CO 81650
RE: REVTSED Written Sfatemenf / Special Use Permit Amendment Application to change a wildlife
detenence sysfem condition of approval as approved under Resolution 200*57
Dear Ms. Orkild-Larson:
As requested, EnCana Oil & Gas (USA) Inc. (En0ana) is submitting a revised Written Statement of the
Proposed Amendment and enclosing the requested Supporting Documents as were provided in the original
Special Use Permit Application: 1)Proof of ownership of the parcel, 2)Vicinity map, 3)Site plan, and 4)Letter
of authorization. This amendment does not have any impacts on traffic, noise or odor. Provided below is the
original Condition of Approval and the Proposed Language of the Condition which we intend it to read:
gb) "Tho applicant shall install a watertod deterrence sysfem f/raf consrsfs of the placement of high-
tensile wirc at rcgular interuals across the pond. These wires acf as a visual deterrent to bitds
attempting to land on the water, and as a noise deterrent, as the stretched wire creates an ultrasonic
(inaudible to humans) sound."
Prooosed Lanouase of Condition 9b): 'The applicant shall utilize water treatment and filtering as a method
of mitigation acceptable to the Colorado Division of Wldlife (CDOW to ellmlnate mortality of
migratory birds which may rest or forage on the ponds. Monitoring of effectiveness and plans for
break-downs, malfunctions or noneffecliyeness will be communicated to the CDOW.'
The wire grid deterrent cited in the original COA presents struclural integrity and safety concerns. And the
ultrasonic noise has been proven ineffective at deterring birds.
ln conclusion, the utilization of water treatment and filtering is the most reliable method available to us and
the CDOW supports this concept as noted in the original submission of the CDOW lefter written by Area
\Mldlife Manager, JT Romatzke.
We firmly believe, with EnCana's current treatment systems in place, support of our methodologies from the
DOW, and our commitment to continuing progress on protecting waterfowl, that we have shown our intentto
meet the proposed amended language.
Thank you again, for your tirne and patience in this matter. And we look forward to approval of this SUP
Amendment.
Sincerel4 ./
/*',.4,r "l,}*gr-, , /,
Rehat{Busch L-'
Permit Coordinator
Encl: Supporting Documents
County Letter (dated 02-08-10)
Proof ol ownership
()wner
Owner:
Care of 1:
Care of 2:
Owner Address:
Ownar City:
Owner $tale:
Owner ZIP:
A$s€sssr
Parcel
Number:
Tax District:
Tax Exempt
Entity:
City or
County:
Zoning
Description:
Land Use 'l:
Land Use 2:
Land Use 3:
Land Use 4:
Land Use 5:
Reception
i,lo:
Book:
Page:
l-egal
Oescription:
Section:
Township:
Range:
ENCANA OIL & GAS (U$A) INC
ENCANA Ort & GAS (USA) rNC,
C/O K,E. ANDREWS & COMPANY
3615 S. HURON SlIIIET. SUITE 2OO
ENGLEWOOD
co
80110
240936100048
o47
PRIVATE OWNERSHIP
Unincorpora ted Garfield C cunly
l'lural
IOO AC .q UP
N/A
f!/A
N/A
NiA
7i3261
NiA
N14
SHOl,l$il.l Rt.10.25-7-96 DESC: SURFACE & 314 Mll-liti l$ SESyl, SEC. 3a S2NE.
E2NW Df;.SC' [iESW, N2SE BK:0570 PG:0146 BK:0453 PG.0377 RECPT;773261
RECPI'73278a 8K 1779 PG:523 RECPI:693922 ii!'.:irl,.rri PG:8I3 R(t:Pi:6ii/75ii
BK.:1622 PG.7: r. RECi], i.o{i(i?a.r.:i Sfi.t $zil pS ,fi14 iiE(.ir r'4-18473 iiK l.. I i Ft]:608
RECPT:6|0';42 i:iK:i025 PG 076i i-:K:0838 PG.029t, B{,:Q777 PG:08a5
t't/A
AlI
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Vicinlly Map
1_.
Water frsafnent FacilitY Site
$Bdim30, I7!U, roloW
GARFIETD COUNTY, OOTORAOO
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Site MaP
T7S, R96W,6th P.M.
2694.60'
NOO'OO'00'8, 1154.59
Proposed
Eud.Poration -Neoro'oo"w' 11e2'1
Pit Site
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OM.JER:
T}A}BRFAK REALTY tLC
Nt/2 NEl/4
s0019'05'w, 510.1 1'
NA319'58"8. tOO-OO',
soo'oo'oo'w, 645.76'
O*?.JER:
ENCAi.JA O'I & GAS (USA)
'NC.Et//z NW/4, s1/2 NEl/l
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-BAS'S OF BEAH'NG NOTE-
The bose beoring for this survey is
500'56'02"W, 265J.14 feet between found
monuments of the Northeost Corner ond
the Eost One-Quorter Corner of Soid
Section 36, T7S. R96W, 6th P.M.
-LEGEND-
0 sfcroN coRNER LocArED
P.O,B. POINT OT BEGINNING
S'IE AOUNDARY LEGAT DFSCR'P]7ON
A TRACT 0f LAND LOCAIEO lN IHf Nl/2 Of SfCnoN J6. TOu,NSlflp 7
SCIJTH, RAN6.E 96 h€ST, 6TH P,M.. GARFIELD COUNTY. COLORAOO. SAIO
TRACT BC,NG MONT PARI]CULARLY OESCRItsED A5 FOLLOWS:
COIJMENONG AI IHE NORTH!':€ST CORNER 0f SA|O S€CION 36 ANn
RUNNING NB9'30.55.8, 2694.60 FLIT ALONC THI NORTH UNE IHERTOf rOlHE NORIH ONE-OUARIER CORNTR OF SA|O SECIION 16l
]HENCE SO'I9.O5. YJ. U24.65 TLI. I ALONG IHE NORIH-sCUTH CENIERUNE
OT SAD SECNOII "J6 TO IHI PONT OF 8TG$INING:
THENCE coNnNUrHc so'19'o5'w, 510.n FEE1 ro rilf sourH$€sT coftN€Ror IHE N1/2 Ntt/1 Or SAto $ECI|ON:
IHENCI H89't9'58'E. 1OO,0O FFFr AI-ONC rHt SourH LINE OF SAto Nl/2
NEt/a;'lHENCf S0IO'00"W' 645.76 FEET; IHTNCE flg0'O0'oo-\r{. l192.to F[EI:
THENCE N0'OO'00'E. 1154-69 FttI: THENCE Ng0'OO'OO'E. 1094.94 FEITIO IHE PONI OF BEGINI.IINC,
iAID TRACT CONTAININC 30-45 ACRIS. IIORT OR LESS.
8AA5S C^PNOrs,
CERNF'CAII OT SURIEYOB
,, ]EO IA66ARI OT-EYANSION, WYOMING HERESY
CERT]FY THAT rtl'S MAP WAS MADE FROM NOTES
IAKEN DUR'N6 AN ACTUAL SURVIY MAOT AY ME OR
UN0ER MY D,RECTICI,I fOR ENCANA Oft & cAS (USA)
,NC. AND TIIAT THE RESULTS OF I,}+i'CH ARE
CORRECILY SHOI{N HEREON.
EXHIBIT A
Map Showing
EnCana Oil & Gas (USA) lne.
Evaporation Pit Sfte Boundary
N 1/2 of Section 36
T7S, R96W,6lh P.M.
GARFIELD COUNry, COLORADO
so0'1 9'05-W, 824.85'-i
/ACRES
ffi,x:lffi
Ld'tr
r"ji\
ffiHLHB :y..# Tii::i i**:;
Phone No. (3O7)7W4545
OM,ttR: BLM
wt,/2 Nwt/4
------*----+I
Ltr ol Authorizalion
Illl ilr.ri'1}|i't lHt{Hil TrlllH,ryHUHUilFr l'lt',I+[ ll ll I
ncc.otlonf: ?6C312tztta',2ffi cs ra oO Fr J.m Alb.ri@l-ot-z i.c r.. ltt.fi) Coc F..0 OO GnfflEtD C0$|TY CC
STATETIENT OF ATXTHORI-iIY
?nrsvant to C.R-.S. S38-30-11?., t he unclersi.gneci exocLltes
this Statemenl of Authority on behalf of EnCana Oil & Gas (U!A)
Inc., a corporatlon (corporatlon, limiteci 11abi.llty company,
qenera- pa::nership, regisLered Iimited Iiabil-ity partnership,
rcg: stereo lim:tecl liability timited partnership, lirnit-ed
part-rersnip associaLion, govcrnmenc ageney, crusL or orher:) r aft
enti ty oLt'ier :han an individua.l-, capable of holding title t.c
real propert"ir (l-he "Entity") , and st"ates as f ol-icvrs:
'lhe !:cnir.: of. Ltre Ent- lt.Y is
l:; icrncc! ui:<iet the Laws of the
ErrCa.na- Oii 0 Gas (USA) Tnc. anci
SLate of DeJaware.
Tire ma:l lng address1?CC; r_lo 8020)!.
for the Ent.ity i-s 3'/C ;?rh St-reet !uire
i i: Lr I tcln',e a:d/ or posit ior: c.[ ulre pe l scr: ( s ] aut::irri zeti i.o
clxe(::r:.c inst.ru:nent-s convey:.n9, encurnbe'ing, or oLherwise
atfccti::g :.itle to real property on behai f of Ehe Unti'i-y is./arcr
Srerrda Lin-gJgt1, t<enL t:ndberq, _n,g!q!q__[gsch,L_!:=l=!Crabb, Jason
sc hna1,_!h :i-s P.g-tn-aqr anQ -(&e-!g$-i"an .
-:1e I irn i t-aL ions upon the authoricy <ri tne Derson nameo
at;t.r.,re or ho)d:nq :.tre pos Lt,ion describeci abcve :.(.r b:nci the Er'l l-it.y
arc as tol lous: grgn "@ifp :nclucing, -?-r:t not
i:m!:ed --o Special Use Permit-s-i Pi_peline Oevei opqcni ..P^i,an
tiqin"tSj_:gl=_ve___PeglUt-s-; Malor and Mino:' Permi-ts and Smal-.t
Fa-c I lilv_ _?::eqki:lJ-:.__ for_j!_gmP9"r,.ery EnPicyee _llo$Itqi- qradinq
pq::!:-:s., nr: - j-d:no permits; lSlJS permit_s-; u-t:iity in:iLa t_lgliqq
ge;i11-s ; cgivqw3y perrnit s i E-qj,g_r -I-mpeS:_Egj!Li_!-qj- T,:::ted-*t_$egct
F.qr f _._; s ;.jgg__+j.n i n i s*Ui a !_ i v e_ P e r m i t s .
{ i i rro I ilrri ta::.ons, inr:er:. "lioric",'
C:her n,a::-ers concerning the manner
rli:.r. s ir::h ary l;:i,erest in reaj. properIy
in whic!': Ei:e Intity
are:
r:c cthcr t:,aiIcr,,C:',:.anl<jleave lhis
a
Il I I tl l.t l,i llFtt FlilllU lt,ll h l!t!,tJl,l,',t[tt lllrl,l, I I I IRcccptionl: 7OO3l2
l2r'18/2OOO 03: 14 O0 Pll Je.n F:mr lco2 ol 2 Rcc Faa 311 OO Doc Fe€ 3 0O GnRTIELD Col"frfY C0
I;XECUT'E0 chis
Page 2 of Statement of Aurhority
Slgn.lrure: r\ .
l';'iLness ny hand a:.ci cf !ici.'il seal''
:ianr.e it yped or pr i rt:ed:
- il I 1 I
.:tlr: ir: ;rr.yi:
) ss '
i:Lr'-'Nl'Y c!' _-_ -,-i
lr.: .::er;oi:iq r 1:it^r-lr:qn:. .rtas .tck':olliedr:;-d hef ore !:ie t_fl . s r;a'i li- _ -:-
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Feb. 8 Cty Ltr
B Ul I. ilt N {; & Pl.A x* N I N {t OE PA N'l-M F. tt* 1
February 8, 2010
Renata Busch
Encana Oiland Gas (USA), lnc.
2717 County Road 215
Parachute, CO E1635
RE:Specia/ lJse Permit Amendment Applicalion to change a wildlife cleteoence syslern
condition of Wproval as approved under Resolut'on 2AAt57.
Dear Reneta,
This otfice is ln recelpt of the Special Use Permit Amendment Application to change a condition
regarding a wildlifd, deterrence system on the High Mesa Water Storage and Evaporation Pond
originally approved under Resolution 2005-57 on a property owned by Encana Oiland Gas (USA),
lnc , for Encana Oil and Gas (USA). lnc.
We have conducted a review of the applicalion and determined it to be Technicalty lncomplele.
Please provide the following information so that we may continue to process the application:
Garfield Gounty Unified Land Use Resolution of 2008, as amended, Section 4-50, (H)
Written $tatement of the Proposed Amendment:
Please provi& a more detailed Written Statement of the Proposed Amendment. Supporting
documenls (letters) have been included with the submittal but need to be summarized in a
narrative so it is clearrvhy and how the Applicant wishes to change the High Mesa Water Storage
and Evaporation Pond. Also, with this arnendment will there be any impacts associated with this
change such as lraflic, noise, odor, etc.? Additionally, it is not clear how the Applicant wishes to
amend Condition 9b. Please write the entire condition as you wish it to read. The condition may
want to eddress the Division of Wldlife's comment in a letter dated 12/09/2009 to Fred Jarman
which slates 'Monitoring of effectiveness and plans for break-downs. malfunctions or non-
effec{iveness should be a part of the changing language.'
Supportinq Doouments;
The lollowing inforrnation needs tu be provided.. Proof of ownership of the parcel. Vicinity map. Site plano Letter of authorization
Once you have adequately addressed these issues, the Director will make a determination as to
whether the proposed change constiluies a substantial modification to the condition o{ approval
contained in the Resolution of Approval and a staff report will then be prepared.
l0B tighrh Sirsrrt. Suiu 4fi1'Ulerrrrrxrr/.liair.e.s. L'O 81601
Gn#eld County
f970t 945-ill] " r9?ttt )3:-797) o Frrr.' t970t 184-i1i0
Since thb apflication proposes to change or vary from a specific condition of approval set forth in
Reroiution 2005"57, the Drector shall set a public hearing boforo tho Board of County
Commbsioners for an amendment to a condilion of approval in a resolution of epproval.
Do not tresitate to contact me if you have any queslions
Sincerely,
ll,lolly Orkild-Llrson, AICP, RLA
Senior Planner
970.625.5903
2
_o
BK 3825 PG 952
Defawwe
(fie first $tate
PA6E 7
"255845
BK 3825 P6 952
01i??/2005 otr59 pg
Janice Hard CLK&REC l{esa Cor.mtB, r:0
RecFee $5.fi1 $,rrtlhs 91.[i0
r/ EeRRrgT 9MITE r,INDSOR, SECRETaRr OF Sr,ATE OF TEE SrATE OE
DEr.I;nI RE, DO EEE.EBr CgRrIiy TgE CgnrrEretrE oF.lrEncER, wgtcg
MERGES:
nrBI PTPELINE CO,,PAilIL", A DELAryARE COFPORArIONI
t,rBr wBsr ylR6rtlrrA/ LNc."t A DEr,AwAp& CORPORATIONI
,TOlt BROInI/ INC."| A DELAflARE CORPOruATION.
wITg ArrD r$ro rEilctfl?I oIL e cAs (us;j INe. n UNDaR tsE N,.loE
ot' ".Eilcefit orL e ois (asil INc.,, I A coRpoRAffoM ORGNiTIZED etID
EIISTTNG uItlDER TEE r.Atls oE TEE srArE oF DEr.I;wIP'jp, til/-si nEcEIwD
ArlD Ffi.SD M rErS oHwcE IEE TfiEIrfY-sEcOND DAY oF DBCEMBER, A.D-
2004t lr 6:75 O'CLOCN, P.lt.
AIID Z DO EEREBY EARTEER CERTIr:Y TEAT TEE AEI9.RESATD
C'OAPORATTON SEALL BE @'/ERNED BY TEE T,a'TS OE TgE STATE OF
DELETERE.
AI'P I DO EEPEBY I:OATSER CERMW r,EAT TEE EEFECTIW DATE O?
rgS ffDEESATD CERr,,ETCATE OF
'TERGaR
ZS TgE ffN.Sr DAY OE ,IVIIUARY,
A.D.2005.
2737895 8330
450439247
Hrrrler Srnith Wlndtor. Srcr:ary of Satc
A.,IIJEtilTICllffOIV: 352 I I 3 3
DATE: Al-20-05
STATE OF COLORADO
Bill Ritter, Jr., Governor
DEPARTMENT OF NATURAL RESOURCES
ForWldlife-
For People
The Colorado Division of Wildlife greatly appreciates the partnership and willingness of Garfield County to allow
us the opportunity to review and recommend strategies on this and other projects that may pose significant threats
to wildlife.
It has been brought to my attention that after the meeting with EnCana and you regarding the strategies for water
treatment at these two facilities that you need to have some assurance from the CDOW that this will ameliorate
the wildlife concerns. The CDOW has been hesitant to state that one method or another will be the best solution
for wildlife protection with regard to produced water ponds in Garfield County. It is the operator's responsibility
to ensure that the taking of wildlife does not occur. With that being said, EnCana has moved forward with
concepts that set them apart from most other industry operators. The ability to treat water completely and to
remove any possibility that illegal take of wildlife may occur is a great concept that the CDOW supports. We
believe that EnCana has come up with a possible solution that will alleviate our concerns.
We support the proposal that EnCana has come up with and look forward to future communication and assurance
that this technique is working. Monitoring of effectiveness and plans for break-downs, malfunctions or non-
effectiveness should be a part of the changing language. Again, while this may not be end all solution, we believe
this will accomplish our goal if implementation occurs to the degree that has been proposed.
If you have further questions please feel free to contact me at any time.
Sincerely,
JT Romatzke
Area Wildlife Manager
(970)2ss-6178
DEPARTMENT OF NATURAL RESOURCES, James B. Martin, ExecutivE DirEdOT
WILDLIFE COMMISSION, Brad Coors, Chair. Tim Glenn, Vice Chair. Dennis Buechler, Seoetary
Members, Jeftey Crawford. Dorothea Fanis. Roy McAnally. John Singletary. Mak Smith . Robert Streeter
Ex Officio Members, James B. Martin and John Stulp
ffiDIVISION OF WILDLIFE
AN EQUAL OPPORTUNITY EMPLOYER
Thomas E. Remington, Director
6060 Broadway
Denver, Colorado 80216
Telephone: (303) 297 -1 1 92
wildlife.state.co.us
Received and reviewed by Fred Jarman on l2-09-2009
Garfield County Planning
Attn: Fred Jarmin
108 8th Street
Glenwood Springs, CO 81601
Re: EnCana High Mesa and Hunter Mesa water facilities
Fred,
Octolrer 23,2009
Fred Jarman
Director, Burlclrng & Planrring Department
108 Bth Street, SLrtte 40'1
Glenwood SPrings, CO 81601
ilL- High Mesa atrcl l-lltnter' lt/esa Waler
Sr-r bseq Lrent APProval
EnCana Oil & Gas (USA) lnc.
271.7 CovnLy Road 215
Suite 100
Parachute, CO 81635
pr,
tel: (970) 285'2825
fax: (970) 285-2691
rerrata. busch@encatta. coln
www.encana.com
i-reatr rrent i:acilities Special tJse irermil /\rnetrdtnent and
Dear iVlr. ,Jarnran:
Here is the letter you requested at the conclusiorr of the October 6 2009 meeting with EnCana oil & Gas
iUSn; tnc. (EnC'ana), ihe Colorado Division of Wilcllife (DO\ /), anei (3arfieicl tlor:nllt The rneeting
addressed two outstancling Conditions of Approval (CoA s) for the Special Use Permits pertaining to the
Hunter tVlesa Water Treatirent Facility (Wl'F) and High Mesa W-l'F. -l-he COA's in question are cited tn
two separate letters clated March27,2009 from the Building & Plannrng Department of Garfield County
and state that all COA's had been met except Hunter Mesa Water Storage Facility had not met the COA
.on,r,r,on 5(c) ancl the liigh Mesa water Storage Facility had not met conclition 9(b,)"vhich'i'ead a's followe:
5c) ,,pond nettipg over all the pits, or another methocJ of mitigation acceptable to the Colorado
Division of Witcllife, shalt be installecl to help prevent migratory bircts fram resitrrg and/or foraging
)-- . on the poncls, particularly during winter months "
.gbi ,,-fhe appticant shatt install a waterfowl deterrence systetrr that consists of the placetnent of higlt'
tensile w1e at regttlar intervals across the ponc.l. fhese uvires acl as a rztsttal- cleterrent tcs birc.ls.
attetnpting to land on the water, and as a nolse cleterrent, as the sl,r:elc,4ecl 'wire creates 2n
ttltrasonic (inauclible to humans) sound."
With regards to 5c, EnCana has had engineers analyze both the Hunter and Hiqh Mesa facilities vrrith the
inient to iret these ponds but determlned this rnitigation effo11 to be urrfeasibie Diie io tha geometr'" oi
these ponds, the weight of the nets and suspension wires, proper supports could not be physically
installed with the areaZ'railable around the poncls. Safety conce,{ns.were also raised since facilitv r,vorkers
are required to have r:nobstructed access to the ponds for regular tnaintenance. The ruire- grid rleieirenI
cited as 9b in the High Mesa COA above also presents the same structural inlegrity and safety concerns
While wire grids rnay be effective at preventing large birds such as geese or herons from approaching a
water bodyiue lo the long slope of therr landing and iake-off ihis grid would,nct be effective at'Jeterring
smaller biids with better iraneuverability in flight such as small waterfowl Also, ultrasonic noise has
been proven ineffeciive at deterring birds.
In an effort lo fincl a new method of prolecting ir.raterfcr,^,,1, EnCana hes le':n -:clrvely rasearching and
,tu,lying the feasrbility of various methods cf preventiorr and has concludecl that water treatment is the
rnosi re'irable rnethod available to us AlthoLrgh water treatment of these waters is very comple;<, allov;ing
only treated waters to be discharged to the ponrjs shor-rld prevent l-rarm lo any'+ralerfowl thai do hapl;en
to lancl rn ihr:se waters Hourly inspectioirs will cotrtinue io be employed by plant rlperatr-'r's to ensure
waterfowl cjo loi stay in ihe area while rlarly insirectir-.rrrs of ihe wildlife exclusir;ri riletliods vvill also be
r;orrducted Haz-inc; cievi,:es will also oe inrplemeirted if we find rr:i-.eated aiter-rrpls liy waierfovrl to resi or
irlr:ri itr I.ltis :trea.
October 13, 2009
Letter to County
Page 2
Since 2005, EnCana has spent significant money, time and effort on testing and researching various
water treatment methods and has determined that this complexity of treatment requires a step-wise
approach. This step-wise method addresses only one constituent or group of constituents at a time for
treatment and will require installation of the necessary equipment prior to moving to the next removal
step. Currently, dissolved air flotation (DAF) systems have been installed and are operational at both the
Hunter and High Mesa WTF s for the bulk removal of hydrocarbons and solids The next phase, that has
already been pilot tested, will be a polishing/filtration process to take DAF elflLrent and remove the
remairring hydrocarbons and solids from the water prior to pond discha,rge !nstallation of these filters is
scheduled for late 2009 or eady 2010. EnCana's ultimate goal is to clean our prodr:ced water to the
stanclards necessary for surface water discharge which will require no less than six distinct treatment
steps, rnore testing and significant time and ntoney. ln the meantime, EnCarra ',vill provide biannual
updates to both DOW and to Garfield County on ollr progress wiih ireahneni.
EnCana has cliscussecl these COA's and our rnethod of mitigation ai length wilh lhe DOW and although
they support our efforts ancl believe in our comt'r.ritntenl to waterlowl protection, the agetrcy cannot provicte
a written docunrent lhat rnight be construed as a wairrer ol EnCana's responsibtltty lo prevent waterfowl
mortalities, Therefore, the meeting on October 6 2009 lvas sclreduled betweetr EnCana, DOW, and
Garfrelcl Coun[y to allow DOW to show support for EnCana's work ic date :rrcl e:<piain lhat they cannot
linrilc,.ur liabrlity in writittg ciirectly to Garfielci County.
\A/ith i:rtCana's (ll.ll-r(:nt lreatment systetns in lrlace, suppoti oi Our rnefttocJol(-)(]les ;'1 '')rir i6'11 t.)()\ltl, anci rlt.tr
comrritrnent to continuing progress on protecting waterfowl, EnCana believes we have shown our intent
[o meet the COA's oullined in the letters dated March 27,2009 for bolh i-l'unierarrc-i Hiuir iVlesa W'[F's and
wish these COA s to be considered met by Garfleld County
-lhani< you for your time and patience in assessing this matter. lf we can be of fLtr-ther assistanrje or yoLt
require additional information, please do not hesitate lo conlact us.
Siriceiely,;
Renata Busch, EnCana
Permit Coordinator
(970) ?_85-2825
ln concutrence wilh
Davicl Grisso, EnCana Operations Field Leadet (970)285-2601
Chris Durrairl, EnCana Water Systetns Engineer J2C\ 87A-5707
irJicole Byr'nes, EnCana, Natural Resource Specraltst (970) 285-2713
Oc Jl- Romalzke CLIOW Area Wtldlife Marragei
Dewey Neely tireld ConsLruction Leader
ENCNA,.
High Mesa Water Storage &
Evaporation Pond
Garfield County
SUP Amendment
NTC RESPONSE SUBMITTAL
Sepfe mber 29, 201 0
Permitting/South Rockies Construction :
SUP Amendment (modify 1) COA language) | Renata Busch
ENCANIA,.
EnGana Oil & Gas (USA) Inc.
EnCana Oil & Gas (USA) lnc.
2717 County Road 215
Suite 100
Parachute, CO 81635
tel: (970) 285-2825
fax: (970) 285-2691
renata. busch@encana.com
www.encana.com
September 29,2010
Fred Jarman
Director, Building & Planning Department
108 8th Street, Suite 401
Glenwood Springs, CO 81601
EnCana's High Mesa Water Storage & Evaporation Pond
SUP Amendment - Modified lnformation Request of August 4,2010
Dear Fred,
The following attachment contains comments which are itaticized and address each of the
concerns with regard to Tom Veljic's August 4,2010 Technically lncomplete Letter (attached) as
it relates to the High fUesa Water Storage & Evaporation Pond SUP Amendment; proposed
language change to the waterfowl deterrent condition of approval.
Together with EnCana's Water Systems Engineer, Chris Durrant, we feel that we haye
ad6quately addressed each of the concerns and that this submittal is sufficient to allow for the
approval process to continue. Please do not hesitate to contact me with questions or concerns.
Sincerely,_.--) -? ./-, ,.-4.21 uZz,bu-, (/-(*
Renafa Busch
Perm itting/South Rockies Construction
Chris Durrant, Water Systems Engineer
David Grisso, Operations Field Leader
Technically lncomplete Letter (dated August 4,2010)
EnCana's Modified lnformation
Cc:
GARFIELD Cq.lNTY
Hril(fng & Pltmilg DeparEnent
{0S S[ $Feet. Suite401
Glemuood Sffigs, Gobrado 81 601
Telephone: $/0-945-821 2 Facsimile : $70-3E4-%7 4
www. qarfield-countv. co m
August4,2010
RenataBusch
EnClrml Oil:rrxl Cras (l.J$A) twc"
2717 County Rsad 215
Parachute, C() 81635
f;E; .Str"zful-6 250 - Sprcir/ L{se Permil Anrcwlment
Ilear Renarc
I am writing rhis latct regarding thc En(hna applicalion for Major trnpact Revict' frrr an amcndmcrf,
fo an approl'ed Spccial Use Perrnit to allow a change of Ccndition No. 9b to aJter the rquirEd
*r*alerforryl deterrence s5/$temo'. I'r'e rerricwtd the sutlnrittal docrrmsn8. neceived. on Aug;usf 2,2A10.
arxlL at this tirnc, the appliration drrs rrct inclu& atl required inftrrmatirrn 5rr (iarfield Cbunty
Reguliliox$" fte upplicati.x, is tknet'ore deemed Tcchnictll-1" Incrompkte and ttre Planning
Departrnent will not pmcess this a1rytir:ation any l"urther unlil the fullowing information, lisfied beloq
tras tccn provided d *rc sarlsfaction of this olfice. Plcasc addreis ttrc following itcms and :ubmit
tllee copies of t6e nmdifisl infrnration to this olfice so that $€ rnay contirnre tk retic:ur of this
qrplicaion
On ,rms 23, 2010 [ sent you an emait with my initial evaluation of .vor application (afladxd) flrd
notod thar three itcrns neerJ to he addre$sod; a rwised and consolidaed narraive, ,nklitional
infrrrrnation on thc trcatmcnt sJ.:Scrn, and a rwiscd sitc plan- I still ftrd your informarion on thc
tneatmtnt prucess inadequate. Ptease provide nmre detail a$ notsd belo*'.
. Please pruvidc more tcchnical infurnration about the Dis.xrlyerl Air Filtcr (DAf) prorxs that
is notd in your stcord application submittal-
o Does ttre DAF procress im'oh'e emi*siom of hytfuocarbons or rflfuer ctrmgrurxls info fte ail? tf
so, has En(kna liltrt APED.Is or nrcivsl agprupriatc pcrmits -ttn thesv wrissions?
EnClana irxlicates t'rat "ultimalely' ttrcy r*art to ueat the ruater to discharge standards-
Assrrnitrg this rneans ttrey are nor tbere 1,'et, are there evaporative emissitltrs from the ponds
th:U rerprire APENs or appmpriate ernission perrnits from CDPHE APCD?
Ilocs Eocana intcnd to tli:rchargle the trcatsl \tr'iiler at v)me prirt in time? [f so, an ap;[opriate
C:t PHE discharge prmil nrust hc obtaitretl prior to relear"ing flny $liller.
The information provitled indicdes that there Ls a slulge tank ass<rciated with the treatrnent
procsss. No infornration is pnrvidod as to tlre nature of this waste arxl how it is managedin_
actnrdance with locat, stflle ard fqtcral rcgulaions. Is this xlckesssd ehewhere in the SUP?
If no! EnCana should provide thl* inf,ormation-
NOflE: The 1nified kwl Llse ftesolutian a!20f,8 (U/.ffi) requires tht l]irector to meka u l]eterminution of'
@rc.*rt for t and f-lse (lfumge. ,Lppt*winns rvithin thirty (30) rt.tr*ing -dtss af receipt of the
tryplirution nitertats (10 working cfoy,s f"r Aclrrrinistrulairry .&eview Permrtsi- Il" an applicntion ir trct
ii^ptutr, the Nrector stanil in{orm tlu tqtfiicrtnt oJ"the eleJicieneies in writintr; awl shY,ll takt tu "l'wther
uctin on (he tpplicarion uiit the deficUwies ffe re.medied If the applica$ fails to cotrect the
defrciencies withiil s;ixty (6tt) catcndrr days, tt e opplication s*all he considered wilhdrawn-
homa Veljic, AICP
09 -29 -2010 Response Attachment
High Mesa Water Storage and Evaporation Pond SUP Amendment
In response to August 412Ol0 Technically Incomplete Letter
EnCana's Responses in itulics:
o Please provide more technical information about the Dissolved Air Filter (DAF) process
that is noted in your second application submittal.
The Double-DAFTM Sofds Thickener is designed to recover sords from plant wastewater prior to
discharge to a holding pond. This recovery process is defined in the following paragraphs.
lnfluent water is pumped into the coagulation chamber of the DAF tank. Here coagulants are
mixed using high speed mixers to create pin floc. Flow is then directed up and through a poft
into the floccuation chamber. Here polymer is thoroughly mixed using low speed mixers to
enhance flock formation. Flow out of the stilling chamber is directed upward over the
downstream baffle wall allowing the more dense solds to settle to the bottom and the floatable
sofids to rise. Micro-AirerM aerated recycle enters via VanAire supplied breakout valves
immediately downstream from the baffle. The flow path created by the baffle leaves the
floc/solids in a bubble-rich zone near the surface so fhe floatable soids need only travel about a
foot to the sufface. This minimizes the amount of buoyancy lost due to the re-absorption of
bubbles into the wastewater.
As the wastewater stream continues on the flow path through the DAF Thickener it flows
through the pari of the DAF Thickener unique to the Double-DAFM system. A cross-flow plate-
pack, which is located mid-DAF Thickener provides a damping effect on the water in the DAF
Thickener, and provides a surface for the coalescing of bubbles and microscopic pafticles. As
the bubbles and particles build up on the underside of the plates, the particles agglomerate into
larger particles, eventually floating to the suiace. Our cross-flow design does not affect the
normalflow patterns in the DAF Thickener; so hydraulic loading rates are not affected. A second
hit of Micro-AirerM aeration is administered just below the plate pack for enhanced
recovery/removal of water contaminates and late forming floc. The second recycle air hit
imitates and has the effectiveness of the second DAF Thickener in a series sysfem.
Floated sofds are skimmed from the sufface of the DAF Thickener using a variable speed
concurrent skimming sysfem for maximum float density. A limit switch sfops the flights on the
beach plate for an adjustable period of time to allow free water to drain from the float. A pitched
false floor concentrates seff/ed solds near four blow down valves where they can be removed
via manually or automatically controlled "blow down" valve(s). There are also blow down valves
located in each chamber and near the effluent end for removal of settled sofds from this area.
Floated soids are held in the float hopper, which is located near the effluent end of the DAF
Thickener. A bridle pipe is provided to mount a level sensor to start and stop a customer
supplied float pump, and to stop the skimming flight system on float hopper high level.
An adjustable rectangular weir located between the float hopper and the clear well controls the
level of the DAF Thickener. The weir is adjusted to maintain DAF water at the front edge of the
beach during low flow. Water passrng over the weir exits the clarifier through the DAF effluent
pipe.
o Does the DAF process involve emissions of hydrocarbons or other compounds into the
air? If so, has Encana filed APENs or received appropriate permits for these emissions?
Emisslons from the DAF unit are de minimus. An emission fesf was attempted on the unit, but
air flow and thus the emission rate were below detection levels; therefore APEN reporting was
not required.
o Encana indicates that "ultimately" they want to treat the water to discharge standards.
Assuming this means they are not there yet, are there evaporative emissions from the
ponds that require APENs or appropriate emission permits from CDPHE APCD?
Encana has the appropriate CDPHE Construction Permit for the residual emissions from the
ponds. No APENs required, as deep well disposal is permitted via state and federal regulations.
o Does Encana intend to discharge the treated water at some point in time?
Yes, into holding pond for the foreseeable future, eventually we will discharge to surface but
likely many years from now.
o The information provided indicates that there is a sludge tank associated with the
treatment process. No information is provided as to the nature of this waste and how it is
managed in accordance with local, state and federal regulations. Is this addressed
elsewhere in the SUP? If not, Encana should provide this information.
Yes, itis addressed in the original SUP... natural separation process allows fhe so/tds to be
skimmed off the produced water (solidified) then be hauled away for disposal at a permitted site,
while the produced water is pumped directly into the storage pond for reuse in drilling
operations.
ffihl{ETVEI}HIGH MESA WATER STORAGE & EVAPORATION POND
SUP AMENDMENT PLANNER REQUIREMENTS PER JUNE 2I,2OIO IMPROII,qflI$
MEETING WTOM VELJIC
0 4 2010
)OUNT'i
:.ANNINGJulv 28.2010
Consolidation of the narrative
Additional information on the treatment system
(Consolidation of narrative and qddition information ls contained below within the
History/Background of Application and Description of the Ll/ater Treatment Process
Update the site plan adding the treatment facilities with legend
Special Use Permit Amendment to change a wildlife deterrence system condition of approval of
Resolution 2005-57
RE:Resolution 2005-57 Original Condition 9.b:
"The applicant shall install a waterfowl deterrence system that consists of the placement of high-
tensile wire at regular intervals ocross the pond. These wires act as a visual deterrent to birds
attempting to land on the water, and as q noise deterrent, as the stretched wire creates an
ultrasonic (inaudible to humans) sound."
Proposed Language of Condition 9.b:
"The applicant shall utilize water treatment and filtering as a method of mitigation acceptable to
the Colorado Division of lllildlife (CDOW) to eliminate mortality of migratory birds which may
ret or forage on the ponds. Monitoring of ffictiveness and plans for break-downs, malfunctions,
or non-effectiveness will be communicated to the CDOW."
HISTORY / BACKGROUND OF APPLICATION:
2006 - EnCana contracted Wagon Wheel Consulting to permit The High Mesa Water Storage &
Evaporation Pond (High Mesa WF). All conditions of approval (COAs) were addressed in a letter to the
County on January 28, 2009, whereby it was noted that we were working closely with the Division of
Wildlife (DOW) regarding migratory bird mitigation, but there was some reluctance on the part of DOW
regarding providing written acceptance for any method of mitigation. Further noted was that at the
County's request, we could establish and facilitate a meeting between Garfield County & DOW to discuss
this issue further. Response back from Fred Jarman on March 27, 2009 indicated that all conditions had
been met with exception to condition 9(b) and that staff cannot forward a permit to the BOCC for
signature until EnCana has constructed the *high-tensile wire.
"The original COA presenfs structural integrity and safety concerns, as well as fhe ultrasonic noise being
proven ineffective at deterring birds.
I was briefed on this issue in .}lfay 2009 and steps had been taken between April and August to get
interested parties together to discuss.
August 2009 EnCana issued an invitation to Fred Jarman to visit the site and discuss DOW's acceptance
ofour procedures. He declined the request.
October 2009 a meeting was held at the County with Fred Jarman, DOW representative, and three
EnCana representatives. I was instructed to provide a letter to Fred indicating that all three agencies were
in agreement and that our method of treating the water was acceptable to the DOW.
December 2009 Fred informed me that since a change to a condition of approval cannot be made
administratively, I was instructed to submit an SUP Amendment. SUP Amendment was submitted, along
with DOWs Support Letter, whereby they indicated support of our processes; in brief: "The ability to
treat water completely and to remoye any possibility that illegal take of wildlife may occur is a great
concept that CDOW supports. We believe that EnCana has come up a with a possible solution that will
alleviate our concerns. "
CONSOLIDATION OF NARRATIVE
A DESCRIPTION OF THE WATERTREATMENT PROCESS
Incorporation of the water treatment system has been accomplished at the site and the equipment is
located in the DAF Building (dissolved air flotation). The DAF system has been installed and is
operational at High Mesa WTF for the bulk removal of hydrocarbons and solids. Filters have since been
installed (25 micron filters) along with oil absorption filters. The filtering process takes DAF effluent and
removes the remaining hydrocarbons and solids from the water prior to pond discharge. EnCana's
ultimate goal is to clean our produced water to the standards necessary for surface water discharge which
will require no less than six distinct treatment steps, more testing, and significant time and money. In the
meantime, EnCana will provide biannual updates to both DOW and to Garfield County on our progress
with treatment. EnCana also provides yearly water chemistry analyses. All water offloaded at the facility
flows through the upfront tanks for free oil recovery and then is processed through the above described
treatment system prior to discharge to the ponds. A detailed explanation of the water treatment process
was established at the October 6,2009 meeting with Fred Jarman, DOW and EnCana.
Monitoring and Inspections
Site monitoring for effectiveness, via hourly inspections, are employed by plant operators to ensure
waterfowl do not stay in the area while daily inspections of the wildlife exclusion methods are also be
conducted, as well as specific monitoring of ponds for oil sheen. Hazingdevices will also be implemented
if we find repeated attempts by waterfowl to rest or feed in this area. EnCana does monitor for
effectiveness and malfunctions or non-effectiveness will be communicated to the DOW.
Assurances that it will operate as proposed
Assurances that the treatment system will operate as proposed can only be guaranteed through hourly
inspections and a robust treatment system design. System design includes a three step treatment system
in which each step is a backup to the prior step to ensure no failure in the treatment system occurs.
Repeated backwashing of the filters will be an indicator that the system is not operating properly and will
signal the operator to fine tune the system without allowing any untreated water to the ponds.
Plans for operational break-downs. malfunctions. and maintenance
Operational breakdowns are minimal due to the lack of mechanical moving parts on the system. Hourly
checks of the system will identiff any breakdowns or malfunctions that may occur and spare parts for all
the equipment is on the shelf at each location. Maintenance for pumps and compressors is done as per
manufacturer's recommendations and is performed by a third party pump company. Chemical pumps are
serviced monthly with through disassembly and a thorough cleaning of all parts.
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