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HomeMy WebLinkAboutMONTAVA PUD - ODP180002 - MONTAVA SUBMITTAL DOCUMENTS - ROUND 1 - ALTERNATIVE COMPLIANCE REQUESTBHA Design Incorporated 1603 Oakridge Drive Fort Collins, CO 80525 Page 1 of 5 voice: 970.223.7577 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 Page 2 of 5 voice: 970.223.7577 fax: 970.223.1827 landscape architecture | planning | urban design www.bhadesign.com 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.