Laserfiche WebLink
exploration and extraction of natural petroleum in a liquid or gaseous state by means of wells or <br />pipe. The proposed methane facility, in its entirety, is considered a component of the <br />"extraction" of the gas resource. This includes piping, generators, operational control buildings, <br />and, importantly, the subject electrical substation. <br />The coal mine methane powered generators will produce output power at 4160 volts. The <br />installation of the substation is an essential component of the facility and necessary to step up the <br />power to 46,000 volts (46kV). The 46kV voltage is the electrical energy supplied to the primary <br />side of the nearby DMEA substation, and thus, supplied to the power grid and available for <br />subsequent wheeling to the electricity customers. <br />To protect the safety of facilities and workers, the industry standard for the separation distance <br />between the gas powered generators and a substation is a minimum 100'. The final location of <br />the substation was dictated by the overall safety concerns at the site and the need to keep the <br />setback distances in accordance with the gas generation industry standards. Protection of <br />employees was a primary concern, and location of the facility relative to the location of a <br />predicted "Disturbance Boundary" line on a Permit map, was a secondary concern. (See the <br />Permit Disturbance Boundary Line discussion below in Section 4.) <br />Finally, the elevated location of the substation reduced the required excavation that would <br />otherwise have been required to expand the extent of the lower pad. We also encountered an <br />exposed large rock in the face of the cut (Photo #1) which presented uncertainties as to the <br />expansion in that SE corner of the pad. The final, elevated location avoided excavation <br />uncertainties and reduced the potential overall footprint of the facility yet providing for the <br />required setback safety margins. <br />3. CDRMS Inspection of October 19, 2012 contains contradictory lan ugz age. <br />While the October 19, 2012 Inspection Report Section "OTHER (SPECIF " on Page 3/6 <br />correctly acknowledges that the electrical generating station "is not within the jurisdiction of the <br />Division" later in the Inspection Report Section "SUPPORT FACILITIES — Rule 4.04" the <br />Division contradicts itself and incorrectly states, regarding the substation, "The Division was not <br />aware of its construction and it was not permitted." Further, the Division states in the Inspection <br />Report that "NOV CV- 2012 -008 is being issued for failure to permit and submit a reclamation <br />bond for the substation." Clearly, the Division has contradicted itself and committed a substantial <br />procedural error in mandating that an acknowledged non jurisdictional facility later be permitted <br />and required to submit a reclamation bond for the facility. <br />Will the Division next request that any Somerset homes located in the Permit Boundary obtain <br />permits and reclamation bonding for new garages? Will the Division next request that CDOT <br />obtain permits and reclamation bonding for CDOT highway projects in the Permit area or <br />disturbance boundary? Will the Division next require the UP Railroad to obtain permits and <br />reclamation bonding for rail projects located in the Permit area or disturbance boundary? We <br />certainly hope not! <br />Clearly, the Division has overstepped its authority with North Fork Energy, LLC. to require <br />permits and reclamation bonding for the substation and the NOV should be vacated on this basis. <br />• Page 2 <br />