HomeMy WebLinkAboutMONTAVA PUD - ODP180002 - MONTAVA SUBMITTAL DOCUMENTS - ROUND 1 - ALTERNATIVE COMPLIANCE REQUESTBHA Design Incorporated
1603 Oakridge Drive
Fort Collins, CO 80525
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fax: 970.223.1827
landscape architecture | planning | urban design www.bhadesign.com
December 5, 2018
Stephanie Blochowiak
Environmental Planner
City of Fort Collins,
281 North College Avenue
Fort Collins, Colorado 80524
RE: Montava PUD – Section 3.8.26 Alternative Compliance Request
Dear Ms. Blochowiak,
Section 3.8.26 of the LUC establishes buffering for residential and high occupancy building
units from existing industrial uses. These uses include existing oil and gas operations,
including plugged and abandoned wells. The minimum buffer distances from oil and gas
operations are established as 500’ from residential development and 1,000’ from high
occupancy building units. Alternative compliance buffer reduction from plugged and
abandoned wells is available for consideration and approval by the decision maker if
specific measures are taken.
We would like to request an Alternative Compliance buffer reduction to 150’ from the
two oil wells on the Montava property. To support this request, we offer the following
information for your review.
Background
There are two oil wells located near the north end of the Montava property. Unlike many
wells in the area, these two wells were most likely historic test wells that never found an oil
resource. The underground oil wells are not operational, have no documented history of
active operations, and have been permanently capped and abandoned for many years.
Figure 1 - Underground well locations on Existing Conditions Plan
BHA Design Incorporated
1603 Oakridge Drive
Fort Collins, CO 80525
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fax: 970.223.1827
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Existing Conditions
There is no visible indication of either of the wells. Farming operations have been in place
over the well locations for many years.
The two well sites are mapped from the COGCC website, and GPS coordinates for each well
are documented. Since there is no visible sign of the wells, the Developer engaged GPRS
(Ground Penetrating Radar Systems, LLC) to help confirm the location of the underground
well heads. Using electromagnetic equipment, they have confirmed the two well locations.
Shallow excavations (2’ depth) have been conducted in both locations but no well head was
found or exposed, so they are presumed to be deeper underground.
Figure 2 - Image from COGCC mapping
Testing Measures Underway
The Developer has engaged engineering firm, TRC Solutions, to test the areas around both
underground well sites and document any adverse impacts such as odor, air pollutants,
hazardous materials or site contamination. TRC is also undertaking similar investigations for
the two off-site wells. When these measures and testing are complete for the two wells on
the Montava property, we will share this information with the City – anticipated to be
complete prior to hearing.
BHA Design Incorporated
1603 Oakridge Drive
Fort Collins, CO 80525
Page 3 of 5 voice: 970.223.7577
fax: 970.223.1827
landscape architecture | planning | urban design www.bhadesign.com
Figure 3 - West underground well location
Figure 4 - West underground well - GPR mapping
BHA Design Incorporated
1603 Oakridge Drive
Fort Collins, CO 80525
Page 4 of 5 voice: 970.223.7577
fax: 970.223.1827
landscape architecture | planning | urban design www.bhadesign.com
Figure 5 - East underground well location
Figure 6 - East underground well - GPR mapping
BHA Design Incorporated
1603 Oakridge Drive
Fort Collins, CO 80525
Page 5 of 5 voice: 970.223.7577
fax: 970.223.1827
landscape architecture | planning | urban design www.bhadesign.com
Buffer Reduction Plan
a. The Montava PUD establishes a minimum setback of 150’ from each underground
well site to planned residential buildings. The west well area will be protected as a
natural open space, and the east well area will remain in farming operations with
the planned farm use. This plan will equally well or better eliminate potential
nuisances and reduce the adverse effects referenced in the purpose of Section
3.8.26 than would a plan which complies with the separation and spacing standards
because the developer is:
a. Identifying and verifying the locations of the underground wells;
b. Identifying appropriate minimum setbacks in the master plan;
c. Minimizing grading in the areas near the underground well sites; and
d. Conducting testing and documentation to meet applicable EPA and State
regulations regarding the site conditions.
b. Environmental testing: Measures are currently being taken by engineering firm,
TRC Solutions, to test and document any other adverse impacts such as odor, air
pollutants, hazardous materials or site contamination in conjunction with the
Alternative Compliance request. TRC is also undertaking similar investigations for
the two off-site wells. When these measures and testing are complete for the two
wells on the Montava property, we will share this information as part of the
Alternative Compliance request. These measures will include:
- Site survey, historical research, and/or physical locating techniques to determine
the exact location and extent of the plugged oil wells.
- Documentation of plugging activities, abandonment and any subsequent
inspections.
- Soil sampling, including soil gas testing.
- Groundwater sampling.
- Installation of permanent groundwater wells for future site investigations.
- Upon completion of the site investigation and sampling, TRC will provide a written
report verifying that the soil and groundwater samples meet applicable EPA and
State residential regulations and that a reduced buffer would not pose a greater
health or safety risk for future residents or users of the site.
c. A written report from TRC Solutions will be submitted once the findings are
completed, prior to hearing.If deficiencies are found and recommended for the
reduced buffer, the Applicant will complete remediation of environmental
contamination to background levels and/or will repair or re-plug the abandoned
wells.
Sincerely,
Angela K. Milewski, BHA Design, Inc.