april 27, 2018 888 first street, n.e. washington, d.c ... · disturbance will be 15.2 acres. table...

April 27, 2018 Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C. 20426 Attention: Ms. Kimberly D. Bose, Secretary Re: Wyoming Interstate Company, L.L.C.;

Docket No. CP18-117-000, Responses to Data Request

Commissioners: On April 9, 2018, Wyoming Interstate Company, L.L.C. ("WIC") received an informal request ("Request") from the Office of Energy Projects Regulation (“OEP”) for environmental-related information pertaining to the WIC Cheyenne Compressor Station Expansion Project in Docket No. CP18-117-000. WIC is herein filing the requested information with the Federal Energy Regulatory Commission (“Commission”). Description of Proceeding On March 15, 2018, WIC filed a prior notice request pursuant to Sections 157.205, 157.208(b), and 157.210 of the Commission’s regulations under the Natural Gas Act for authorization to reclassify one compressor unit that currently serves as a spare unit to mainline service and increase the available horsepower at its existing WIC Cheyenne Compressor Station located in Weld County, Colorado. The project is referred to as the "WIC Cheyenne Compressor Station Expansion Project." Description of Information Being Filed WIC is providing responses to questions that were part of the Request. Note that various responses include attachments. Filing Information WIC is e-Filing this letter and responses with the Commission's Secretary in accordance with the Commission's Order No. 703, Filing Via the Internet, guidelines issued on November 15, 2007 in Docket No. RM07-16-000. Pursuant to 18 C.F.R. § 388.113, WIC is requesting CEII treatment of the plot plans included as part of two responses. Accordingly, WIC has labeled this information “CONTAINS CUI//CEII – DO NOT RELEASE”. WIC requests that the Commission

Federal Energy Regulatory Commission -2- April 27, 2018 accord CEII treatment to this information for the life of the assets identified in the plot plans so as not to place the assets and personnel of WIC at undue risk. Pursuant to 18 C.F.R. § 388.112, WIC is requesting privileged treatment of a proprietary corporate waste management guidance document included as part of a response. Accordingly, WIC has labeled this information “CONTAINS CUI//PRIV INFORMATION – DO NOT RELEASE”. If you have any questions regarding the CEII or Privileged Information being filed herewith, please contact Mr. Francisco Tarin at 719-667-7517 or via email at [email protected].

Respectfully submitted, WYOMING INTERSTATE COMPANY L.L.C. By /s/

Francisco Tarin Director

Enclosures

Certificate of Service I hereby certify that I have this day caused a copy of the foregoing documents to be served upon each person designated on the official service list compiled by the Commission's Secretary in this proceeding in accordance with the requirements of Section 385.2010 of the Federal Energy Regulatory Commission's Rules of Practice and Procedure. Dated at Colorado Springs, Colorado as of this 27th day of April, 2018.

/s/ Francisco Tarin

Two North Nevada Avenue Colorado Springs, Colorado 80903 (719) 667-7517

WYOMING INTERSTATE COMPANY, L.L.C.

Responses to OEP Data Request Dated April 9, 2018 in Docket No. CP18-117-000

WIC Cheyenne Compressor Station Expansion Project

Resource Report 1: 1. Clarify the location of the proposed pipeline as well as whether this pipeline would

be installed above or below ground. Response: The proposed pipeline will be installed below ground parallel to existing lines within the fenced area at the Cheyenne Hub Complex. WIC has attached a plot plan under the Critical Energy Infrastructure Information section of this response that depicts the proposed location of the pipeline. The plot plan is marked as “Contains CUI//CEII – Do Not Release”. Response prepared by or under the supervision of: Raul Ronquillo Project Manager 719-520-3771




Resource Report 1: 2. Provide the separate acreages of the Project area that would be utilized as

construction workspace and contractor staging areas. Clarify the acreage of overall ground disturbance.

Response: Table 1-1 below has been updated to reflect the areas utilized for construction work space, contractor staging areas and access roads. The acreage of overall ground disturbance will be 15.2 acres.

Table 1-1 Summary of Land Requirements by Acreage1

Project Component Acreage Affected by Construction

(acres)

Acreage Affected by Operation

(acres)

Construction Workspace 5.9 5.9

Contractor Staging Areas 6.3 6.3

Access Roads 3.0 3.0

Total Project area 15.2 15.2

Notes: 1 The numbers in this table have been rounded for presentation purposes. As a result, the totals may not reflect the sum of the

addends.

Response prepared by or under the supervision of: Raul Ronquillo Project Manager 719-520-3771




Resource Report 1: 3. Provide the maximum expected depth of disturbance and the anticipated depth to

shallow groundwater. Response: The maximum expected depth of disturbance for this project that will be part of trenching activities is six to ten feet below ground surface. Based on data available from the Environmental Data Resources, Inc. report retrieved from the Colorado Department of Public Health and Environment, Division of Water Resources, static well depths for wells in the Project vicinity range between 90 and 350 feet. Accordingly, WIC does not anticipate shallow groundwater to be encountered during Project activities. Response prepared by or under the supervision of: Raul Ronquillo Project Manager 719-520-3771




Resource Report 1 4. The “work area” and “contractor staging area” outlined on the Plot Plan (Tab A of

Volume 3) do not match the “construction workspace” outlined on the Natural Resources Map (Figure 1-2). Rectify this discrepancy.

Response: WIC is providing as attachments to this data request a revised Figure 1-2 and a revised plot plan that depict the correct construction workspace, contractor staging yard and access roads. The plot plan is being provided as part of the Critical Energy Infrastructure Information section and is marked as “Contains CUI//CEII – Do Not Release”. Response prepared by or under the supervision of: Raul Ronquillo Project Manager 719-520-3771

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NATURAL RESOURCES MAP

Weld CountyWeld County

Laramie CountyLaramie County

LEGENDPROJECT AREA OUTLINE

ACCESS ROAD

CONTRACTOR STAGING AREA

CONSTRUCTION WORKSPACE

NHD STREAMDELINEATED DRAINAGES

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STORMWATER POND - UNLIKELY TO BECONSIDERED JURISDICTIONALSOIL CLASS BOUNDARYNWI RIVERINE SYSTEMAPPROXIMATE BOUNDARIES OFPROPERTY OWNED BY CIG/WIC

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PROJECTLOCATION

0 300 600Feet

GRAPHIC SCALE

WIC/KINDER MORGANCHEYENNE COMPRESSOR

STATION EXPANSION

NOTES:1. 2015 IMAGERY OBTAINED FROM ESRI IMAGE SERVICE.2. NATIONAL WETLANDS INVENTORY (NWI) WETLAND DATAOBTAINED FROM THE US FISH & WILDLIFE SERVICE AT:www.fws.gov.3. NATIONAL HYDROGRAPHY DATASET (NHD) OBTAINEDFROM THE US GEOLOGICAL SURVEY AT: https://nhd.usgs.gov4. SOIL CLASS BOUNDARY DATASET OBTAINED FROM SOILSURVEY GEOGRAPHIC (SSURGO) DATABASE FOR WELDCOUNTY, COLORADO, NORTHERN PART AT:https://websoilsurvey.sc.egov.usda.gov/

±




Resource Report 1 5. Describe estimated workforce requirements and number of personnel to be hired to

operate the proposed Project. Response: WIC estimates a workforce of 20-30 contract personnel would be required during construction. WIC does not plan to hire additional personnel for the operation of the facilities that will be installed as part of the proposed Project. Response prepared by or under the supervision of: Raul Ronquillo Project Manager 719-520-3771




Resource Report 1 6. Clarify whether modifications/ground disturbance would be required to prepare

contractor staging areas for use and what those modifications would be. Response: Ground modifications within the fenced Cheyenne Hub Complex may include grading and/or installation of road base/gravel for locating construction trailers, temporary parking and material staging areas. Any grading and/or installation of road base/gravel will be undertaken as needed. Response prepared by or under the supervision of: Raul Ronquillo Project Manager 719-520-3771




Resource Report 2 7. Does WIC agree to prohibit refueling activities and storage of hazardous liquids

within at least a 200-foot radius of all private wells and at least a 400-foot radius of all municipal or community water supply wells (if present)? If not, how would WIC minimize the potential for contamination of private and municipal/community water supply wells?

Response: WIC is not aware of any municipal/community water supply wells located near the vicinity of the Project. There are two private wells, both owned by WIC, which are outside of the 200-foot radius of the project work and contractor staging area. Nonetheless, WIC agrees to prohibit all refueling activities and storage of hazardous liquids within a 200-foot radius. Response prepared by or under the supervision of: Raul Ronquillo Project Manager 719-520-3771




Resource Report 2 8. Identify whether the Project area is within a wellhead protection area and the source

of this information. Response: WIC received confirmation from John Colbert Jr. Physical Science Researcher with the Colorado Department of Public Health and Environment, Water Quality Control Division confirming that the Project area is not within 150 feet of any wellhead protection areas as identified in the statewide Source Water Assessment Areas. WIC has attached behind this response a copy of the email correspondence with Mr. Colbert on April 23, 2018. Response prepared by or under the supervision of: Raul Ronquillo Project Manager 719-520-3771

1

Finch, Jocelyn

From: Colbert - CDPHE, John <[email protected]>Sent: Monday, April 23, 2018 2:56 PMTo: Finch, JocelynSubject: Re: Wellhead and Source Protection Areas

Hi Jocelyn, I combined your project area shape file with our statewide Source Water Assessment Area (SWAA) files. I found that your project area does not intersect with any SWAA areas, intakes or wells. Let me know if you have any questions or need any further assistance. Thank you, On Mon, Apr 23, 2018 at 1:49 PM, Finch, Jocelyn <[email protected]> wrote:

John,

As we discussed this morning please find attached a shapefile showing the approximate Project Area in Weld County. We are interested in finding out if there are any wellhead protection or source water protection areas within this Project Area. We have completed a search of known private wells based on data available from CDPHE. Based on field reconnaissance and a review of available data from CDPHE we have not identified any springs within this Project Area.

We appreciate your assistance in this matter.

Jocelyn Rae Finch | Project Scientist |

[email protected]

Arcadis | Arcadis U.S., Inc.

630 Plaza Drive, Suite 100 | Highlands Ranch | Colorado | 80129 | USA

T. +1 720 344 3813 | M. + 1 303 898 4733

Connect with us! www.arcadis.com | LinkedIn | Twitter | Facebook




Resource Report 2 9. Clarify whether public or private groundwater supply wells or springs are present

within 150 feet of proposed construction areas. Identify the location of any such groundwater supply well or spring.

Response: As identified in WIC’s response to question 7, there are two private wells owned by WIC that are outside of a 200-foot radius of the project work area and contractor staging area. WIC notes no public or private groundwater supply wells or springs occur within 150 feet of the proposed construction area. During the wetland and waterbody surveys conducted on December 7, 2017, no springs or natural seeps were identified within the environmental survey area, which encompassed a 150-foot buffer around the proposed Project area. In addition, the United States Geological Survey (USGS) 7.5-minute topographic map (Carr East, CO-WY quadrangle) and USGS National Hydrography Dataset did not indicate the presence of any springs or natural seeps within 150 feet for the Project area (USGS, 2016a; USGS, 2016b).





Resource Report 2 10. Discuss how WIC would monitor groundwater quality and yield for all public and

private groundwater supply wells within at least 150 feet of construction (if any), with the owner’s permission, before and after construction to determine whether water supplies have been affected by construction activities. Also indicate what types of mitigation measures would be undertaken to ensure that the water supply is returned to its former capacity in the event of damage resulting from construction (e.g., providing temporary sources of potable water, restoration, repair, or replacement of water supplies).

Response: As noted in its response to question 7, there are two private wells, both owned by WIC, which are located outside of a 200-foot radius of the project work and contractor staging area. There are no groundwater supply wells within 150 feet of the proposed construction area. Therefore, no groundwater quality and yield monitoring is necessary. Response prepared by or under the supervision of: Raul Ronquillo Project Manager 719-520-3771




Resource Report 2 11. Describe how the ephemeral drainage (Unnamed Drainage S04) would be impacted

by the Project. If this drainage would be crossed, provide the crossing method and how the drainage would be restored. Likewise, describe any impacts on the dry stormwater pond, clarify whether it would be crossed, and if so, how it would be restored.

Response: WIC proposes to install a pipeline across unnamed ephemeral drainage S04. WIC proposes to cross the drainage utilizing an open cut construction method that will be restored back to the original grade. With regard to the stormwater pond, WIC proposes to install a pad for the two inlet scrubber vessels that will be located adjacent to the pond. Therefore, no restoration activities on the stormwater pond will be required.





Resource Report 2 12. Section 2.3 states that hydrostatic test water would be discharged. Where will the

hydrostatic test water be discharged (e.g. well-vegetated upland)? Response: Hydrostatic test water will be discharged into an energy dissipation device, similar to the attached typical drawing. This device would be located in a well-vegetated upland area and no hydrostatic test water will be discharged into a “Waters of the US”. Response prepared by or under the supervision of: Raul Ronquillo Project Manager 719-520-3771




Resource Report 4 13. Provide the project location and photographic log attachments to Arcadis’ January

10, 2018 letter to the Colorado State Historic Preservation Office. Response: WIC has attached behind this response the project location topographic map and photographic log attachments that accompanied the January 10, 2018 letter to the Colorado State Historic Preservation Office.


Service Layer Credits: Sources: Esri, HERE,DeLorme, Intermap, increment P Corp.,GEBCO, USGS, FAO, NPS, NRCAN,GeoBase, IGN, Kadaster NL, OrdnanceSurvey, Esri Japan, METI, Esri China (Hong

NOTES:1. USGS TOPOGRAPHIC QUADRANGLE OBTAINED FROM ESRI IMAGE SERVICE. QUAD: CARR EAST, 1997

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SITE LOCATION MAP

Weld CountyWeld County

Laramie CountyLaramie County

LEGENDPROJECT AREA

PROJECTLOCATION

0 2,000 4,000Feet

GRAPHIC SCALE

±

WIC/KINDER MORGANHIGH PLAINS EXPANSION

PHOTOGRAPHIC LOG

Project Name:

Wyoming Interstate Company High Plains Expansion

Location:

Cheyenne Compressor Station, Weld County, Colorado

Project No.

CO002302.0001

Photo No.

1 Date:

12/7/2017

Direction Photo Taken: Southwest

Description: Overview of contractor staging area (foreground) and High Plains Expansion Project area (background)

PHOTOGRAPHIC LOG

Project Name:


Location:


Project No.

CO002302.0001

Photo No.

2 Date:

12/7/2017

Direction Photo Taken: Southeast

Description: Overview of High Plains Expansion Project area (west end) with Colorado Interstate Gas Jumper Compressor in background

PHOTOGRAPHIC LOG

Project Name:


Location:


Project No.

CO002302.0001

Photo No.

3 Date:

12/7/2017

Direction Photo Taken: Northeast

Description: Overview of contractor staging area, High Plains Expansion Project area

PHOTOGRAPHIC LOG

Project Name:


Location:


Project No.

CO002302.0001

Photo No.

4 Date:

12/7/2017

Direction Photo Taken: Southeast

Description: High Plains Expansion Project area with Colorado Interstate Gas Jumper Compressor

PHOTOGRAPHIC LOG

Project Name:


Location:


Project No.

CO002302.0001

Photo No.

5 Date:

12/7/2017

Direction Photo Taken: East

Description: Overview of High Plains Expansion Project area, east end

PHOTOGRAPHIC LOG

Project Name:


Location:


Project No.

CO002302.0001

Photo No.

6 Date:

12/7/2017

Direction Photo Taken: South

Description: Proposed access road from US Highway 85 (at left), High Plains Expansion Project area




Resource Report 4 14. Provide the U.S. Geological Survey map attachment to the December 22, 2017

“Limited-Results Cultural Resource Survey Form.” Response: WIC notes that the U.S. Geological Survey map that was attached to the December 22, 2017 “Limited-Results Cultural Resource Survey Form” and filed with the tribal consultation letters is the same project location map included as part of WIC’s response to question 13. Therefore, please reference the project topographic map included in that response.





Resource Report 4 15. In the Unanticipated Discovery Plan for Cultural Resources, update the FERC

contact to: Laurie Boros, 202-502-8046. Provide the revised plan. Response: WIC has attached a revised Unanticipated Discovery Plan for Cultural Resources that reflects Laurie Boros as the correct FERC contact.


Wyoming Interstate Company

UNANTICIPATED DISCOVERY PLAN

FOR CULTURAL RESOURCES

WIC Cheyenne Compressor Station Project, Weld

County, Colorado

February 12, 2018

UNANTICIPATED DISCOVERY PLAN FOR CULTURAL RESOURCES WIC CHEYENNE COMPRESSOR STATION EXPANSION PROJECT

UNANTICIPATED DISCOVERY PLAN FOR CULTURAL RESOURCES

WIC Cheyenne Compressor Station

Project, Weld County, Colorado

Prepared for:


65001 CanAm Highway

Carr, Colorado

Prepared by:

Arcadis U.S., Inc.

630 Plaza Drive

Suite 100

Highlands Ranch

Colorado 80129

Tel 720 344 3500

Fax 720 344 3535

Our Ref.:

CO002301.0001

Date:

February 12, 2018


This page intentionally left blank.


arcadis.com i

CONTENTS

1 UNANTICIPATED DISCOVERY PLAN FOR CULTURAL RESOURCES .............................................. 1

1.1 Discovery Situations ....................................................................................................................... 1

1.2 Human Remains ............................................................................................................................. 2

1.3 Contact Information ......................................................................................................................... 3


arcadis.com ii

ACRONYMS AND ABBREVIATIONS

APE area of potential effects

CFR Code of Federal Regulations

CRC cultural resource contractor

CRS Colorado Revised Statutes

FERC Federal Energy Regulatory Commission

Plan Unanticipated Discovery Plan

Project WIC Cheyenne Compressor Station Project

SHPO State Historic Preservation Office

THPO Tribal Historic Preservation Officer

Tribes Federally Recognized Tribes

WIC Wyoming Interstate Company

1 UNANTICIPATED DISCOVERY PLAN FOR CULTURAL

RESOURCES

This Unanticipated Discovery Plan (Plan) was prepared for Wyoming Interstate Company’s (WIC) Cheyenne

Compressor Station Project (Project) to assist the Federal Energy Regulatory Commission (FERC), Office

of Energy Projects, in compliance with Title 36 Code of Federal Regulations (CFR) Part 800.13, which

implements Section 106 of the National Historic Preservation Act (54 U.S.C. 306108). In addition, the Plan

will assist WIC in compliance with Colorado state law that governs the protection of Indian burial sites

(Colorado Revised Statutes [CRS] 24-80 Parts 1301-1305). The Plan describes the measures to be taken

by WIC in the event that cultural resources that may qualify as historic properties, or human remains, are

discovered during project-related activities.

Before any undertaking-related activities begin within the area of potential effects (APE), WIC must provide

the FERC with a list of, and schedule for, WIC employees or authorized representatives who are empowered

to halt all activities in a discovery situation, and to protect the discovery. These employees will be responsible

for notifying the FERC of any discoveries. At least one of the WIC employees or authorized representatives

on this list must be present during all undertaking-related activities. WIC must also identify a qualified cultural

resource contractor (CRC) who will be responsible for evaluating and documenting unanticipated cultural

resources and human remains found during the Project. The CRC will then advise WIC during consultations

with the FERC, the Colorado State Historic Preservation Office (SHPO), and Federally Recognized Tribes

(Tribes).

1.1 Discovery Situations

(a) On discovery of any artifact, sign, evidence, or related find that may indicate that a buried or

heretofore unidentified cultural resource may be present within the Project area, all project-related

activities, including vehicular traffic, within 100 meters of the discovery shall cease immediately. In

addition, WIC will notify the FERC and WIC’s CRC, and will protect the discovery pending further

guidance.

(b) Further guidance will be solicited in the following manner:

a. WIC will notify SHPO and FERC and take into account these consulting parties’ initial

comments on the discovery.

Within two (2) working days of the discovery, the WIC CRC will provide recommendations for the

SHPO, FERC, and the appropriate Tribes for comments.

(c) If mitigation is appropriate, comments for the development of mitigation measures will be solicited.

a. Comments on mitigation will be solicited by WIC from the SHPO, FERC, and appropriate

Tribes to develop mitigation measures. The FERC and SHPO will consider these

comments in the decision on the extent of efforts.

In addition, WIC will notify all parties on mitigation efforts and implement the mitigation measures.

(d) Work may not resume in the vicinity until authorized by the FERC.

(e) WIC will provide reports of mitigation efforts for discovery situations in a timely manner and conform

to the standards for reports of data recovery programs. Drafts reports will be submitted to the SHPO,

FERC, and appropriate Tribes for review and comment. All final reports for efforts associated with

federal lands, will be submitted to the SHPO, FERC, and the appropriate Tribes.

1.2 Human Remains

(a) If human remains are discovered under any circumstances, WIC will immediately stop all Project-

related activities, including incidental traffic within 100 meters of the location of discovery. WIC will

conform to all appropriate Colorado statutes concerning possible unrecorded dead bodies, human

remains, or crime scenes. The human skeletal remains will be carefully covered and secured

protecting them from degradation by weather or unauthorized individuals. If necessary, WIC will

provide 24-hour on-site security for the discovery. Absolutely no photographs of the human remains

may be taken for personal use.

(b) WIC will immediately notify local law enforcement authorities, the SHPO and FERC of the discovery.

WIC will coordinate with the local authorities. Local authorities will determine whether the remains

are of an unrecorded dead body as defined by Colorado statutes (CRS 24-80 Part 1301) and

whether the remains are part of a crime scene. If the remains are part of a crime scene, local law

enforcement shall assume jurisdiction and responsibility, and WIC or the CRC will immediately notify

the SHPO and the FERC by either telephone or in person. This initial notification will be followed by

a written notification. Work will not resume until authorized by the local authorities.

(c) If the human remains do not constitute a crime scene, the CRC will, without disturbing the remains

or matrix in which the remains are interred, inspect the remains and report the discovery to the

SHPO and FERC. The report will describe any human remains and any other cultural material found

as part of the discovery. The specific treatment of the remains will depend on whether or not the

remains are identified as Native American.

(d) If the remains are not Native American, WIC will try to find the most likely descendant and treat the

burial in consultation with the SHPO and the FERC.

(e) If the remains are identified as American Indian, the SHPO will notify the Colorado Indian

Commission and the appropriate Tribe(s). The Protection of Indian Burial Sites Section of the

Colorado Revised Statutes (24-80 Part 1304) specifies the duties of the SHPO in the sensitive

treatment and disposition of unmarked human burials, funerary cairns, unregistered graves, and

any associated artifacts.

(i) The Tribe(s) may inspect the discovery, with permission of WIC, and will have 48 hours to make

a recommendation on the disposition of human remains and associated artifacts.

(ii) WIC will submit a treatment plan consistent with tribal recommendations to the SHPO and the

FERC. After the final treatment plan is accepted by FERC and SHPO, WIC will implement the

treatment, which may include scientific studies.

(iii) After the treatment plan is completed and the report is accepted, all human remains and artifacts

must be reinterred under the supervision of the Tribe(s). No human remains associated with a

Tribe or associated grave goods will be publicly exhibited or be displayed in any manner without

the explicit consent of the Tribe(s). Any such public display is subject to criminal penalty and

civil action. No media will be alerted to or allude to this discovery without the written Tribal

consent.

(iv) Work may not resume until authorized, in the vicinity, by the FERC.

WIC will be responsible for all expenses associated with the discovery including tribal site visits, excavation,

analysis, reporting, and reinternment. WIC will also be responsible for any reasonable costs incurred by

tribal members to receive the remains, to perform ceremonies, or to reinter the remains.

1.3 Contact Information

Contact List for Unanticipated Discoveries


Name Title Telephone

To be contacted by Colorado Interstate Gas Company

Title Name Telephone

To Be Determined;

will be updated prior to construction

Contractor Foreman

Weld County Sheriff Non-emergency (dispatch) (970) 356-4015

Colorado Deputy SHPO Dr. Holly Norton (303) 866-2736

FERC Archaeologist Ms. Laurie Boros (202) 520-8046FERC Project Manager

To be contacted by Wyoming Interstate Company

Name* Tribe Telephone

Yufna Soldier Wolf Northern Arapaho-Wind River Reservation (307) 856-6120

Karen Little Coyote Cheyenne & Arapaho of Oklahoma (405) 422-7733

Teanna Limpy* Northern Cheyenne- Northern Cheyenne

Reservation

(406) 477-4839

Notes:

*THPO-Tribal Historic Preservation Officer

Arcadis U.S., Inc.

630 Plaza Drive

Suite 100

Highlands Ranch, Colorado 80129

Tel 720 344 3500

Fax 720 344 3535

www.arcadis.com




Resource Report 6 16. The Project area is underlain by the High Plains Aquifer, an unconsolidated to semi-

consolidated aquifer which may be susceptible to ground subsidence from over-pumping. Describe whether incidents of land subsidence resulting from over-extraction of groundwater are known to have occurred within the Project vicinity and cite the source of this information.

Response: The Project area is located at the far western edge of the High Plains Aquifer system (HPA), within the Brule Formation (J. A. Miller, 1999). The Brule Formation, the deepest of the HPA, appears to be relatively impermeable and only acts as part of the aquifer where it is extensively fractured.

Subsidence, or the lowering of the land-surface due to underground changes, is most commonly attributed to over-drafting of aquifers. Between 1980 and 1996 groundwater levels within the Brule Formation in the Project area have not changed significantly (USGS, 1999). Fractured consolidated deposits like the Brule Formation are also typically less conducive to subsidence than unconsolidated aquifers. Based on a review of available literature there are no known incidents of land subsidence resulting for over-extraction of groundwater within the Project vicinity.

Furthermore, the Project area is located at a facility owned and operated by WIC since the early 1980s. During this time, WIC has not encountered any instances of ground subsidence or ground subsidence due to over-pumping of groundwater. Therefore, WIC does not anticipate any impacts to the Project from localized subsidence.





Resource Report 7 17. Given current and past industrial use of the Project area with natural gas facilities,

and because “PCBs are known to exist elsewhere on the 5A and 5B pipelines”, discuss the potential for encountering contaminated soil during construction activities. If there is a potential for encountering contaminated soils, discuss the procedures that WIC would follow to identify, handle, temporarily store, and properly dispose of these soils, and precautions for minimizing the exposure of workers and the public.

Response: Even though WIC has not encountered PCB contaminated soils within the existing Cheyenne Compressor Station, there is potential for PCBs to be encountered. If PCB contaminated soil is encountered, WIC would comply with its proprietary corporate waste management guidance document. This document is being provided under the Privileged and Confidential Information section of this response and is marked as “Contains CUI//PRIV Information – Do Not Release”. Response prepared by or under the supervision of: Mike Bonar Environmental Project Manager 719-520-4817




Resource Report 7 18. Provide a revised table 7-1 which identifies the acreage of the Project area underlain

by each soil unit. Response: WIC has revised and included below Table 7-1.

Table 7-1 Soil Map Units Within the Project Vicinity

Map Unit Symbol

Acres within Project

area

Map Unit Name Shallow

Bedrocka

Poor Revegetation

Potential

High Compactionb

High Wind Erodibilityc

High Water Erodibilityd

Farmland Classification

4 12.6 Ascalon fine sandy loam, 0 to 6 percent

slopes

No No No No Yes Farmland of Statewide

Importance

16 2.3 Bresser sandy loam, 3 to 9 percent

slopes

No No No No No Not Prime Farmland

46 0.1 Otero sandy loam, 0 to 3 percent slopes


47 0.2 Otero sandy loam, 3 to 9 percent slopes


49 0 Paoli fine sandy loam, 0 to 6 percent

slopes

No No No No No Farmland of Statewide

Importance

Notes: a Shallow bedrock is defined as bedrock within 5 feet or less from the soil surface. b High Compaction category includes clay contents greater than 28 percent, weighted average of surface layer. c High Wind Erodibility category includes Wind Erodibility Groups 1 and 2. d High Water Erodibility category includes all K-factor ratings of 0.27 or higher. Source: NRCS 2017





Resource Report 9

19. Identify any procedures which would be used by WIC to mitigate fugitive dust emissions. If watering would be used, identify the source and quantity of water required.

Response: The generation of fugitive dust during construction would be reduced through the application of appropriate control measures. Based on typical practices for natural gas pipeline installation the following specific control measures would be used as needed to control fugitive dust emissions from the Project.

Utilize existing public and private roads and pipeline ROW for access during construction wherever possible. Use only Project-approved roads for access.

Reduce vehicle speeds on unpaved roads; reduced speed limits may be set on unpaved roads.

Clean up track-out and/or carry-out areas at paved road access points. Ensure that all haul truck cargo compartments are constructed and maintained

so as to minimize spills and loss of materials. Cover haul truck loads or maintain at least 6 inches of freeboard space in each

cargo compartment; cover truck loads of sand, gravel, solid trash, or other loose material.

Apply water to affected unpaved roads, unpaved haul/access roads, and staging areas (when in use).

Apply water to active construction areas as needed. Areas should be pre-watered and soils maintained in a stabilized condition where support equipment and vehicles would operate.

Water disturbed soils would form a crust, reducing the potential for dust creation. Control water spray so that over-spraying and pooling would be avoided to the

extent possible. Where roads are paved, no dust mitigation may be necessary.





Resource Report 9 20. Provide the emission rate of criteria pollutants (NOx, CO, SO2, PM10, PM2.5, VOC),

greenhouse gases (GHG), and hazardous air pollutants from the compressor unit that is proposed for reclassification, expressed in tons per year for maximum operating conditions and any increase this unit would add to overall operational emission. Include supporting calculations, emission factors, fuel consumption rates, and annual hours of operation. Emission Factors should be based on one of the following methodologies: EPA-certified emission standards, manufacturer data; current EPA AP-42 emission factors; or peer reviewed studies for the equipment.

Response: Emissions from the spare compressor unit, i.e., CG-7401, are presented here based on the full potential utilization (8760 hours per year) at the maximum heat input rate of 18.83 MMBtu/hr. Maximum annual fuel consumption, based on full-time operation and a nominal fuel heat value of 940 Btu/scf is 175.5 MMscf/year. Criteria pollutant emissions for unit CG-7401 are summarized in the table below. Emissions of NOx, CO, and VOC are based on manufacturer data. Emissions of SO2 and particulate matter are based on AP-42 emission factors. Criteria Pollutant Emissions

Pollutant Emission Factor

Emission Factor Basis lb/hr tpy

NOx 0.47 lb/MMBtu Manufacture

r data 8.9 38.8

CO 0.47 lb/MMBtu Manufacture

r data 8.9 38.8

SO2 0.000588 lb/MMBtu AP-42 Table 3.2-1 (7/00) 0.01 0.05

PM10/PM2.5 0.0483 lb/MMBtu AP-42 Table 3.2-1 (7/00)* 0.9 4.0

VOC 0.36 lb/MMBtu Manufacture

r data 6.8 29.7 *Particulate factor includes the filterable fraction plus the condensable fraction. All particulate emissions are assumed to be less than 2.5 microns in diameter (i.e., PM2.5)

Greenhouse gas emissions are summarized in the table below. Emission factors for natural gas combustion are from Tables C-1 and C-2 of 40 CFR Part 98. Calculation of carbon dioxide equivalent (CO2e) emissions are based on the global warming




potentials (GWP) of each pollutant for the 100-year time horizon from Table A-1 in 40 CFR Part 98 (GWP of 1 for CO2, GWP of 25 for CH4, and GWP of 298 for N2O). Greenhouse Gas Emissions

Carbon Dioxide (CO2)

Methane (CH4) Nitrous Oxide

(N2O)

Total GHG Mass

Emissions

CO2e CO2e

(kg/MMBtu)

(tpy)

(kg/MMBtu)

(tpy) (kg/MMBt

u) (tpy) (tpy) (tpy) (MT)

53.02 9,642

1.00E-03 0.18 1.00E-04 0.02 9,642 9,652 8,756

Hazardous air pollutant (HAP) emissions are based on AP-42 emission factors and are summarized in the table below. Hazardous Air Pollutant Emissions

Pollutant Emission Factor Emission Factor Basis lb/hr tpy

1,3-Butadiene 8.20E

-04 lb/MMBt

u AP-42 Table 3.2-1 (7/00) 0.02 0.07

2,2,4-Trimethylpentane

8.46E-04

lb/MMBtu

AP-42 Table 3.2-1 (7/00) 0.02 0.07

Acetaldehyde 7.76E

-03 lb/MMBt

u AP-42 Table 3.2-1 (7/00) 0.15 0.64

Acrolein 7.78E

-03 lb/MMBt

u AP-42 Table 3.2-1 (7/00) 0.15 0.64

Benzene 1.94E

-03 lb/MMBt

u AP-42 Table 3.2-1 (7/00) 0.04 0.16

Ethylbenzene 1.08E

-04 lb/MMBt

u AP-42 Table 3.2-1 (7/00) 0.00 0.01

Formaldehyde 5.52E

-02 lb/MMBt

u AP-42 Table 3.2-1 (7/00) 1.04 4.55

Methanol 2.48E

-03 lb/MMBt

u AP-42 Table 3.2-1 (7/00) 0.05 0.20

Methylene Chloride

1.47E-04

lb/MMBtu

AP-42 Table 3.2-1 (7/00) 0.00 0.01

n-Hexane 4.45E

-04 lb/MMBt

u AP-42 Table 3.2-1 (7/00) 0.01 0.04

Naphthalene 9.63E

-05 lb/MMBt

u AP-42 Table 3.2-1 (7/00) 0.00 0.01

PAH 1.34E lb/MMBt AP-42 Table 3.2-1 0.00 0.01




-04 u (7/00)

Toluene 9.63E

-04 lb/MMBt

u AP-42 Table 3.2-1 (7/00) 0.02 0.08

Xylene 2.68E

-04 lb/MMBt

u AP-42 Table 3.2-1 (7/00) 0.01 0.02

Total HAPS 1.50 6.56 Response prepared by or under the supervision of: Leslie Nolting Manager - EHS 719-520-4652




Resource Report 9 21. Identify the hours during which WIC would perform construction activities. Response: Regular construction hours would be from 7:00AM to 5:00PM. If needed, construction activities may occur in consecutive work shifts that would cover a 24 hour period. Response prepared by or under the supervision of: Raul Ronquillo Project Manager 719-520-3771

april 27, 2018 888 first street, n.e. washington, d.c ... · disturbance will be 15.2 acres. table...

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