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2.0 Staff Report
Board of County Commissioners — Public Hearing Exhibits Pond G Water Impoundment - Material Handling and Storage Facility Limited Impact Review Applicant is OXY USA WTP LP October 21, 2013 (File LIPA-7650) Exhibit Letter (Numerical) Exhibit Description 1 Proof of Publication 2 Return Receipts from Mailing Notice 3 Photo evidence of Public Notice Posting 4 Garfield County Land Use and Development Code, as amended 5 Garfield County Comprehensive Plan of 2030 6 Application 7 Staff Report 8 Staff Presentation 9 Referral Comments from Garfield County Consulting Engineer 10 Referral Comments from Garfield County Vegetation Manager 11 Referral Comments from Garfield County Environmental Health 12 Referral Comments from the Colorado Parks and Wildlife 13 Referral Comments from the Town of DeBeque 14 Referral Comments from the CDPHE Air Pollution Control Division 15 Supplemental Submittals from the Applicant including SPCC Plan, Pond Permitting/Testing Results, Form 2A and Form 15 COGCC Approvals 16 OXY Air Regulatory Permitting Statement (dated 10/18/13) 17 CPW Supplemental Email Comment (dated 10/17/13) 18 19 20 21 22 23 24 EXHIBIT BOCC 10/21/13 File No. LIPA-7650 GH PROJECT INFORMATION AND STAFF COMMENTS REQUEST Limited Impact Review for a Water Impoundment — Material Handling and Storage Facility APPLICANT — PROPERTY OWNER OXY USA WTP LP ASSESSOR'S PARCEL # 2169-214-00-026 PROPERTY SIZE The Site will be approximately 14.88 acres on an overall tract of approximately 7,732.5 acres. LOCATION The property is located approximately 15 miles north of the Town of DeBeque, in the SE%NW 1/4 Section 16, T6S, R97W . ACCESS The facility is accessed by County Road 204 and 213 (Conn Creek Rd.) and a series of private roads built and maintained for use by the natural gas industry. EXISTING ZONING The property is zoned Resource Lands (RL) Plateau I. GENERAL PROJECT DESCRIPTION The Application is requesting Limited Impact Review for a Water Impoundment — Material Handling facility along with Storage Uses. The Water Impoundment will involve the conversion of an existing production water pond to a Centralized E & P Waste Management Facility. Under the proposed approval the pond will convert from a Form 15 COGCC pond to a Form 28 COGCC pond. The conversion has largely to do with the longer term status (greater than three years) of the pond use. The proposal is designed to allow for effective re -use of water volumes, to conserve resources, improve safety and environmental exposure. The pond will serve OXY well pads and facilities in the surrounding area and is connected by existing pipelines. The surface area of the pond is approximately 2.85 acres with a capacity of 214,585 BBL's or approximately 9 million gallons. It is double lined with a leak detection system. The pond is fenced and has surface flagging as a wildlife deterrent. The pond 1 is served by a series of both below ground and above ground pipelines. No changes to the size and general operation of the pond facility are proposed by the Application. It is currently permitted by the COGCC as a From 15 Impoundment associated and is located on an existing gas well pad. It was constructed in accordance with State requirements and inspections. The current proposed use will require supplemental permitting by the COGCC as a Centralized E&P Waste Management Facility in accordance with COGCC Form 28. The change is anticipated to include additional inspections and installation of monitoring wells. Pond G Accoss Road Map OA. ko.40o4 A���o17,7J1J G1. tt11Ca.i�17, U'.dya.0 0 000 00 070 1 175 v�1 Pond 0 ti Ory Rowonrodo Road i� Unioo od Pak Rood f`hp (Ravod Pubddo Rood 4,1kI P 1110 Pudic Road Facilities as shown on the site plan include: • 3 Storage Tanks (400 bbls) on the Well Pad for gravity separation and condensate storage (associated with the well head production and not the water impoundment). • Two gas powered generators to run on site equipment including pumps. 2 • 3 Tanks (2 for Production Water 1 for separated oil) adjacent to the impoundment. • Two pumps for water transmission and material handling. • Double Pond Liner and Leak detection sight pipe. • Exit ladders at the north and south ends of the pond. • 8 ft. high fencing and wildlife deterrent flagging. • Access roadways, circulation, parking, and storage areas. byp Avrouw'wrurr APMCX umairterrati 'pool ; :WHY PIPE WkI CAM MAW � n DETAIL "A" SCALE t"=80 N lN.et SITE PLAN The proposed storage areas are immediately adjacent to the pond and include a 1.25 acre area north of the pond on the existing well pad and a smaller area east of the pond. Approximately 2 acres within the overall 14.88 acre site will be used for storage. The storage areas are not proposed to be fenced and will be located on previously disturbed areas. They will be maintained with compacted dirt or gravel surfaces. No hazardous materials will be stored in the designed storage areas. No improvements 3 are proposed and the areas will remain open, level areas accessible by vehicles and employees for storage of equipment and supplies. /Rligh OXY USA WTP LP OXY 760 Mayon Drive, suds 101 `,/ Orand Juncton, 00 61600 Pond G Adjacent Uses Map IAdp Rowwd: Juno 17.2013 0w.0 Cov1.Ca1aado 0 000 0.1 010 0 Ivo AERIAL PHOTOGRAPH AND ADJOINING OIL AND. GAS ACTIVITY .Pond 8 1,000' War wound Pond 0 0,y Onrnd PO Ory Rda Wnalbe Road 1, uninpa.d Rale Row 4.%0 OM* Public Rad 4%0 POVW Pubac Hod Benefits outlined in the application submittals and include reduced truck traffic, conservation of freshwater, use of an engineered transfer system, and reduction in development and operating costs. The pond will be unmanned and accessed by employees for typical monitoring and maintenance operations only (approximately once per day). The Storage Areas will also be unmanned with employees accessing the site for short intervals to pick up or drop off supplies. Bottled water and portable toilet facilities are provided throughout the area for use by field employees. II. LOCATION - SITE DESCRIPTION The site is currently developed with the existing pond with leveled and graded areas associated with well pad activities. The site is bare of vegetation in the developed 4 areas. The areas surrounding the site are characterized by native vegetation primarily a mixed mountain scrub -shrub habitat dominated by sagebrush with some stands of aspen and scrub oak. The site is located on a ridge/plateau above the Cascade Creek Canyon. The topography generally slopes down and away from the facility with the exception of the northwest corner of the site which slopes up along the ridge. III. PUBLIC COMMENTS AND REFFERAL AGENCY COMMENTS Public Notice was provided for the Board's public hearing in accordance with the Garfield County Land Use and Development Code as amended. No public comments have been received at this time. Comments from referral agencies and County Departments are summarized below and attached as Exhibits. 1. Garfield County Consulting Engineer, Chris Hale, Mountain Cross Engineering: • Noted the need for information on water rights and legal use of the water. 2. Garfield County Road and Bridge Department: No written comments received at this time. 3. Garfield County Vegetation Manager, Steve Anthony: 5 • Indicated that the noxious weed section of the submittals is acceptable • Noted his understanding that the facility is subject to COGCC jurisdiction in regard to reclamation bonding. 4. Garfield County Environmental Health: Morgan Hill, Environmental Health Specialist noted the following topics. • Inquired regarding Air Quality Permitting. • Discussed water quality protection, leak detection and monitoring well topics. • Inquired about the potential for future water treatment to facilitate water reuse. 5. Colorado Parks and Wildlife: Noted the location is within a greater sage -grouse production area and indicated that no significant impacts to wildlife are anticipated if the recommendations summarized below are incorporated into the development: • Limits on night lighting • Bear Proof trash storage • Re -vegetation of any disturbed areas • Proper Speed Limits (25 mph) • Pit details including fencing, escape ramp and netting. • Notification regarding any trapped or dead animals • Restricting construction to outside the time period from March 1 through June 30th to minimize impacts to sage -grouse production. 6. Town of Debeque: Had no comments on the Application. 7. Colorado Department of Public Health and Environment Air Quality Division: • Provided information on construction permits and Air Pollution Emissions Notice requirements (APEN) • Provided references to applicable codes and construction standards which require APEN permitting (i.e. construction - earth moving activities greater than 25 acres or more than six months in duration) 8. Other agencies that did not submit comments include: (a) the Colorado Department of Public Health and Environment Water Quality Divisions); (b) Bureau of Land Management; and (c) DeBeque Fire District. IV. STAFF COMMENTS AND ANALYSIS In accordance with the Land Use and Development Code, the Applicant has provided detailed responses to the Submittal Requirements and applicable sections of Article VII, Divisions 1, 2, and 3, including Section 7-1001 Industrial Use Standards. The Application materials include an Impact Analysis and related consultant reports, technical studies, and plans. 6 7-101 — 103: Zone District Regulations, Comprehensive Plan & Compatibility The proposed use demonstrates general conformance with applicable Zone District provisions contained in the Land Use and Development Code and in particular Article III standards for the Resource Lands Plateau zone district. The Comprehensive Plan 2030 designates the site as RPN (Resource Production/Natural). Excerpts from the Land Use Description Section Chapter 2 and Section 8, Natural Resources and Section 9, Mineral Extraction are provided below. Chapter 2 — Land Use Designations Resource Production/Natural (RPN): Agricultural and grazing land use primarily oil, gas, oil shale, coal mining, gravel mining, including support buildings and facilities needed for the natural resource extraction industry, and other business uses that can be adequately buffered from adjacent incompatible uses. Also includes area with significant environmental constraints such as upper plateaus, talus slopes, and steep slopes over 20%. Private inholdings mostly surrounded by public lands with limited public access. Section 8 — Natural Resources Issues *The county maintains high air quality standards, however there may be a propensity for air pollutants to exist in the western part of the county Goals 1. Ensure that natural, scenic, ecological, and critical wildlife habitat resources are protected and /or impacts mitigated. 4. Ensure the appropriate reclamation of land after extraction processes. Policies 1. The County will encourage and cooperate with the protection of critical habitat including state and federally protected, threatened, or endangered species. Section 9 — Mineral Extraction Goals 2. Ensure that mineral extraction activities mitigate their effects on the natural environment, including air quality, water quality, wildlife habitat or important visual resources. 3. In working with mineral extraction projects, the county will protect the public health, safety and welfare of its citizens. Policies 2. Mineral resource extraction activities will protect critical wildlife habitat as identified by state and federal agencies. Development within these designations that cannot be designed, constructed and conducted so as to have a minimum adverse impact upon such habitat or these wildlife species shall be discouraged. 4. Facilities that are appurtenances to oil/ gas development activities (compressors, etc.) are considered appropriate in all land uses so long as they meet the respective mitigation requirements of the ULUR to maintain compatibility with surrounding land uses. The location and design of the proposed facility is in general conformance with the Comprehensive Plan Policies subject to proper mitigation of impacts. Comprehensive Plan Future Land Use Map - Excerpt Pond G Site Location The Application has also provided information and aerial photographs indicating the character of the area and adjacent land uses. The request demonstrates general 8 compatibility with adjoining uses that are primarily oil and gas exploration/production and agricultural associated with cattle grazing. 7-104 & 105: Source of Water & Waste Water Systems The Application represents that the facilities will operated with only occasional staff activities. The proposal demonstrates that the uses will be adequately served by provision of water in individual staff vehicles and provision of portable toilets at numerous sites in the OXY field per OSHA standards. 7-106: Public Utilities No public utilities are required for operation of the facility. 7-107: Access & Roadways The Applicants access their property directly from County Road 213. The submittals include general descriptions of the roadway as currently in use and a waiver request from the Roadway Standards where certain elements of the roadway may not fully comply with the standards. A statement from a qualified representative of OXY USA WTP LP reconfirming the adequacy and safety of the roadway to serve the site should be required as a condition. The Traffic Study identifies the minimal amount of traffic associated with the proposed use. No additional improvements are recommended by the Study. The Study should be updated to include traffic related to the storage use and reconfirm the finding that no traffic improvements are required. 7-108: Natural Hazards The Application provides significant information on natural hazards including information on soils, geology, and slopes associated with the site. The information supports a determination that the proposed use is not subject to significant natural hazard risks. 7-109: Fire Protection The Application includes the Emergency Response Plan for the site. The Application was referred to the DeBeque Fire Protection District with no comment received. No structures are proposed for the water impoundment and storage areas. 7-201: Agricultural Lands With no new disturbed areas and with 8 ft. fencing for the water impoundment no impacts on cattle grazing which occurs in the area are anticipated. Fencing of the 9 proposed storage areas may be considered to further minimize impacts and delineate the extent of the storage areas. 7-202: Wildlife Habitat Areas The Applicant has provided a wildlife habitat study completed by ERO Resources Corporation (Biological Resources Memo dated July 15, 2013). The Study indicates that the proposed use is located adjacent to Sage Grouse production areas. The Study concludes that the already disturbed site provides poor sage grouse habitat and no visible evidence of sage grouse was observed during their site visit. No other threatened, endangered, proposed, candidate or other sensitive species were noted to occur in the project area. The study noted existing fencing and bird deterrents in place on the pond. A series of recommendations were provided including calendar limits on site work and re -vegetation. Compliance with the consultant's recommendations should be required. 7-203: Protection of Water Bodies The site location on a plateau/ridge is not in close proximity of active water bodies. The nearest water feature is an intermittent unnamed drainage approximately 550 southwest of the site. The facility has an existing Spill Prevention Containment and Control (SPCC) Plan which provides protection from impacts to water bodies or drainages. A copy of the SPCC Plan for the site has been provided. 7-204: Drainage and Erosion (Stormwater) The Applicant has provided a copy of the State Storm water Management Permit applicable to the site. The Applicant has also provided an Erosion Control Plan that details Best Management Practices including areas already stabilized and re - vegetated. 7-205 Environmental Quality The Application represents that all air quality permits from the CDPHE will be obtained or are currently in place. Copies of the permits need to be provided for the County's records and to confirm compliance. Storm Water Management Permits, Installation of Best Management Practices, SPCC Plans, and Reclamation and Erosion Control Plans address protection of water quality. 7-206: Wildfire Hazards No structures are proposed and no comments were received from the Fire Protection District. The site plan maintains a separation between the facilities and natural vegetation and the Emergency Response Plan includes a specific section on Field Fire 10 Prevention. A fire break separation between storage areas and natural vegetation should also be provided. La (oB1 ©JOir1W.111F 7-207 Natural and Geologic Hazards rariornerZC tralroValgger raa The soils NRCS Soils information and the Gehydrology Report contain information on soil types, limitations, local geology, and geologic hazards. The primary limitations noted were based on slopes and seep potential. The use of a double walled liner and location on an existing bench with separation from steeper slopes have been utilized to mitigate potential concerns. 7-208: Reclamation The Applicant has included a reclamation plan that addresses re -vegetation and reclamation. The Applicant should reconfirm that reclamation is covered by existing bonds with COGCC. 7-301 & 302: Compatible Design, Parking, and Loading. The proposed use is consistent with and compatible with typical oil and gas exploration and production activities. Large areas of the site plan are available for parking, circulation, and loading activities. 7-303: Landscaping As an industrial use landscaping submittals and standards are not applicable to the proposal. A waiver was requested but is not required for the use. 7-304: Lighting Lighting will only be required during periods of major pumping and distribution activities when nighttime monitoring is required. Lighting shall be limited to down directed, shielded and internally oriented fixtures in accordance with the County's lighting standards. 7-305 Snow Storage Adequate portions of the site plan including areas adjacent to the proposed storage areas are available for snow storage. 7-306 Trails Trails standards are generally not applicable based on the industrial nature of the proposal and surrounding uses. 7-1001 INDUSTRIAL USE STANDARDS The Applicant represents that the facility will comply with all the Industrial Use Standards contained in Section 1001. The following summary addresses the applicable provisions. • The facility is located on a large tract of OXY USA WTP LP property in a remote area of Garfield County. • The site is effectively screened by topography and geographical features and distance. • All industrial products and wastes will be stored in accordance with all applicable state and federal regulations. • The Applicant represents that COGCC noise limits will be adhered to. Noise associated with the site is typically limited to the natural gas generators located on the well pad and the two pump units located adjacent to the pond. Topography, geographical features and distance provide for noise mitigation. The facility has been in operation in conjunction with the adjacent well pad and has not experienced noise compliance issues. 12 • No other nuisance or ground vibration hazards are anticipated based on type of use, existing operation, COGCC compliance, and the remote location. V. SUPPLEMENTAL SUBMITTALS AND ADDITIONAL STAFF ANALYSIS 1. The Applicant has provided a supplemental package of COGCC Permitting, Notices, SPCC Plan, and From 15 Approvals for the water impoundment. The documents are attached as exhibits and demonstrate the history and current status of COGCC approvals. The plans also include additional details on the design and engineering of the facility. 2. The Facility is served by existing pipelines with no new pipelines proposed by the Application. The Applicant shall provide confirmation that all existing pipelines serving the facility are either in compliance with County permitting requirements or exempt from County Permitting based on pipeline diameter or length. OIL AND GAS ACTIVITY AND nIPLLIIVL VIArrl VG .• Pond G Site 9r4�.' e � �r . r ♦.;te '1:Nr ti 'r}! �.4 �'I� }� i• i M1''. sot , =.fir; , : �+'op- 44 -11 PIPELINES = Purple, Green and Tan Lines OTHER ACTIVITES (INCL. WELLS) = Red Triangles 13 3. The Application represents that all water stored at the facility is from non - tributary sources. The Applicant's Representative has verbally confirmed that the sources are the Williams Fork Formation and non tributary. The Applicant shall provide written confirmation for inclusion in the County files. VI. SUGGESTED FINDINGS 1. That proper public notice was provided as required for the hearing before the Board of County Commissioners. 2. The hearing before the Board of County Commissioners was extensive and complete, that all pertinent facts, matters and issues were submitted and that all interested parties were heard at that meeting. 3. That for the above stated and other reasons the proposed Land Use Change Permit for OXY USA WTP LP Pond G Water Impoundment - Material Handing and Storage Facility is in the best interest of the health, safety, convenience, order, prosperity and welfare of the citizens of Garfield County. 4. That with the adoption of conditions, the application is in general conformance with the 2030 Comprehensive Plan, as amended. 5. That with the adoptions of conditions and granting of a waiver from the roadway standards, the application has adequately met the requirements of the Garfield County Land Use and Development Code, as amended. VII. RECOMMENDATION The following recommended conditions of approval are provided for the Board of County Commissioners consideration. 1. That all representations made by the Applicant in the application shall be conditions of approval, unless specifically altered by the Board of County Commissioners. 2. That the operation of the Pond G Water Impoundment — Material Handling and Storage Facility shall be done in accordance with all applicable Federal, State, and local regulations governing the operation of this type of facility. Conditions Prior to Issuance 3. Prior to issuance of the Land Use Change Permit, the Applicant shall provide a supplement to the Traffic Analysis confirming that Storage traffic was included in the analysis or updating the report as appropriate. The supplement shall include a finding consistent with the current study that no additional traffic improvements 14 are recommended or provide specific recommendations that the Applicant shall be required to comply with subject to review by the County's Consulting Engineer. 4. Prior to issuance of the Land Use Change Permit, the Applicant shall provide written confirmation that all pipelines serving the facility have been properly permitted or are exempt from permitting requirements and that all water being stored on the site is from non -tributary geologic formations and therefore exempt from water well regulations. 5. Prior to issuance of the Land Use Change Permit, the Applicant shall provide copies of all current air quality permits from CDPHE. Any future or amended permits shall be provided to the County upon issuance by the CDPHE. 6. Prior to issuance of the Land Use Change Permit, the Applicant shall provide a statement by a qualified professional or representative of the Applicant confirming the adequacy of the access road to serve the site. A waiver from Article VII, Roadway Standards is approved pursuant to the approval criteria contained in Section 4-118 of the Land Use and Development Code, subject to compliance with the above requirement. Other Conditions 7. The facility shall maintain compliance with CDPHE Storm Water Management Permits, Drainage and Grading Plans, Reclamation and Erosion Control Plans for the site. 8. Implementation of the Applicant's Dust Control Plan shall be required. A copy of the plan or applicable excerpts shall be provided for inclusion in the County Files. 9. Compliance with all COGCC fencing, lining, leak detection, monitoring well, and high level monitoring/alarms shall be required. Copies of the COGCC Form 28 approvals shall be provided to the County upon issuance by COGCC. 10. The facility shall maintain compliance with COGCC Noise Standards/Regulations. If future compliance issues are identified the Applicant shall provide noise mitigation in order to achieve compliance along with a technical evaluation by a qualified professional to confirm compliance. 11. The Applicant shall comply with all SPCC Plan provisions and shall keep the plan current and updated for any changes to the facility. 12. The facility shall maintain compliance with Section 7-306 Lighting, with all lighting to be directed inward and doward toward the interior of the site. Facilities and storage tanks shall be painted a non -glare neutral color to lessen any visual impacts. 15 13. The Emergency Response Plan provided with the Application submittal including contact information shall be kept updated. 14. The Applicant shall comply with their Noxious Weed Management Plan including the best management practices and provide confirmation that the site is covered by existing COGCC bonding for re -vegetation and reclamation. 15. The Applicant shall comply with the recommendations of the ERO Resources Biological Resource Report (dated July 15, 2013) included in the Applicant's submittals and the Colorado Parks and Wildlife recommendations contained in their referral letter dated October 3, 2013 including upgrading fencing, netting for waterfowl deterrents and calendar limitations on construction activities to avoid impacts on candidate species including the Sage Grouse. 16. Storage areas shall be limited to the previously disturbed portion of the site and a a fire break separation between the storage areas and native vegetation shall be maintained at the perimeter of the site. 16 VIEWS OF THE SITE 1 17 • 18 19 20 21 Ci LJ.J mo - N J W Q ~ LL W 3 Z °NE7uj LJJ Ci Uj Cseajr Z Z a 2Q • r-4 r -i V 0 CD O ":5 .CA -, 0 V ¢' CZ O t• raS c c N CU0 u 0 O L t Oil and Gas Activities VITES (INCL. WELLS) = Red Triangles tt 0 0 E V pp r-1 v N J CO N CO -N bJJ CDC 0 vi O ' v bA CU 4-4 :=4"(O U O'�� v v v (t) 73 0 0 CCS v u .. .5 k in .P.A 5.. a) 0 LJ?*E -ti u bJ �U Or f ,>_., b1OcS cz • a)4. �u.+�• r-1 • u CLS CZ . r -a CCS .� CU ° t CCS 4-4 Cr .4-4 . rts 0 ,..,CZ 1 rt CZr"\ p_iC) 40 a) .5 0 .2 .1-) (75 v 4J r--•4 v cz O0 cz CCS .2 N '�1 ''-' CCS N . X ~-+ O .�, Ems, o �O ) F)-4`4' .-;21, N� CU ;-.4 �(LS�+--a�n� �'dU� cti .CU #.., Opp 0) • a) r 17e) U 4 O U rr CZ OU N c(n tn New �, u N -+" al U ` j ei "t1 b� � CLS ;-+• CU p "Q p U 0 0 4- och 5� .4°' g3 a.; 4�'� �v N OU Or 'O wO O v O.O UWHU+�HV)E-+v Hi4A4cclEmsi H 5 El El E. o U tim GLt irtE EI 4) 4u bb vi v `� ~ri m M "p o bIJ be 4) • '. , c -, tip aj .r.c g .2 ci'—d rj b4) 0 ''' P-0 O • cl' 2L_, � � c1n � ��O 0 ral czT) . 61.14 c9 ;..4(I) a o co cnf., O r' 0 '_ O crSric CDC) b.° (1) a CA u 8 CI) b0 r -C) ,.(4) y'ri ti t,J, ct �H�� 0 -4-gy0 �� Nrj • -'N•�-' XOcr) appQ 754 (-` Zi `1) 71 0 ct rTi 0 ct 4., • 8 ccS��Hp O x� u fs•, c� cn ►.� H . co +-� H p W oo El o 0 0 11 a o 0 0 AlNW bpu O )• N C42 92 • a O �a , . • $ 4 CZ cn CZ b N 41) rip c,1 711) O O O 0-i P—, c'cS 0 0 r—, CU cu O v 0 GIS 1-4 v CU bO v O O CT' ( ) bO • � cit b.0 '—' 8 • ,- O cid co co 0 O cu N CU .� (f) C "71 CU 4 ccs C --+ u rri �cn O bo u CAn • cu E a) cp (Afir--, Ci) (175 CCI (i)�, cn bp a) 0> •••4 (1) • `.OCZ VD .1.Z54 . v (1) v au •- - .- .' 4� rLw wiz E E 0= No public comments have been received at this time. 0. cn (f) b J 0 • v 0 0 O �{ O Nac czTid O 1.1 u� U \o N v .V (f) ;i O U � U•El O v 741) • bf b L w - N o written comments Q.) ..4 J btJ ��--- (1) .a; { 0 v 0 u O wU 4-:ZU4)-) vuU Cf) ') v Q bt1. ten• • N • O U �l I cij by • .a_, • T-, 57i.„ 0 0 (1),150 b�J� � UU rtcc$ v-0 cr).v Q 0 ent to facilit CU rZSCI) 0 A A A (Iv 4.0 E o X zc O w u v v °/' 0 Q •, • O 0 (1) ,...5. 'C) bo • O O Ivo Ti f)N �a>o +-, CO H acs § g (1) . 30 ou 0 d CO ? d CU b G o U & a' '-d . S s " ao aJ cn O 4 O G 70 (1)u vcd � m 0 - ,al in ' n. H b0 v M In OF r bf) u d p0 PiS.*��}rbU rel, {ter_' ���—y,O (. Obf .(.) '.p bA (1.1,9N 1° N. r, O c`'a', O ,-,-. 0 N p 0 CCU v'--1 U }„� A A A A A A A 0 0 A it a u 3 G 0 CO 0 r- 0 Y (te 0:1 0 co o u 4 • v —24 .o 4U 0 (13 E (6:4 o4 vo.+� 1 IN 6' v CD 0g4�� 0 0 tji .;�v•-0 0 v0C14 o(i) 0 0 Staff Au1ialysrs Key Topics in the Staff Analysis are noted below: c,n 0 'Ti, _U M p 61) tU, cZ c CU•� biJ © 0 l) H � M - • H '-+-1.0 0 0 c� 7-0 � . c�i� _� 0 +x U r—+ O w . H U Ti A 0 r can' p ®� 0 .� ..4—+ "i by (Jr) 0 u) 0 71 ' . B o9 E: , cu ;! 7; U cu N 0P V'� Water and Waste 0 . c/ J ) (1)v re•a `��tn1 �U'• '771Q, bt :, N CUA Q H X sxCU 4.1.( i -aZUE C7 Cl El Cl D O E D tjl MIN cu 1 w r • a)IP ch,c7j Q) 0 0 v S; Xcn ,_7_,„) ,..g 1,4+ (ir' ;-- ‘-i— r-1 ‘‘.-e fr:H's- '4.C°Ir`i CL) . ;- lal v cz c r O L Ti a Q�ri co ct tiro) h v ova bA�a .v caves +. a cv— U CV) N� UU CO 0 .-+ 0 cc1 vii Q)cr� cua 0U ;--4 CZ a)-4 �-' bo U• c+A n, � v © 0 0 J0 Co nditions w cu 0 0.) General Conditions ,..� 05 M i 0 0 li xCZ mow c� , v '5 ''''' 1 g .: Lo 03 ,i, © r, p —4-1 Conditions Prior to Issuance CL) CLi CU wcuif„ '8 vuvcnv w 0.4 auu�'G bap O as 03.v�.› 8 ,, a) 71 (JDM � 0) 0_1 ; v c "ti cal Otz,S .r.144 (1)r O v 0 ©(1) d rd 0•p cjjcri co al 4Z51)t Q) CI) o t ',o 754 Pal - s ' CD ctS . -.' ( r (1.) (1) bo U E "Cs ¢,� • CU 1, -+ bA pLib v 0 ill 4 a 0 0 co . u(13 17:$ ., �'rn F-1 cu w 0 U • cf), a,Q) (I) o u .5 0 ctIcii uo a rzi0 H 4-4 •H ' + 0� u CUrt v Oro Other Conditions '(,-t-1 O -4 kohl O AnommtbiMadI 0 C101 MUM e E E O L) w keep the plan Cr) cn `© `( H ft .-1 r O g 1rd o l b0 l • b!o' a o- cci . r, ", dj v Cin C-J'Al Fal' ttj -w (t . Ou Qe- vu•v v '000 r+ r -a 4...a r -I u bi) 11. •I-1 r1 ui •r -i buyy va .14 N v° .-- , o CLI 1) ~~ bJJ I at 0 4 La u ,� rd c r-+ . H 0 .,, Fel 5-.4 v en 4-, V p v,4 Ev u bcrU, f co Pct c'z1 o O E o v :0 Zp V rw fa 0v ,bA u0 cJ Q, w.,- <'- v a v•~ v (U HI V V til C.7 U r- cu 4.4c c E u w CCCO p u C u , 7-4• 44 CICI u WCU cti u• 40 r u in" ��vaa 0 cu " a4-, •H cu cu Nvv 6,06,0d , v� ;; 'C-, 0.1 ," c bDD otnNb4) f L) X09 uo u cu c u v 4+ o v iri •0 October 7, 2013 Mr. Glenn Hartmann Garfield County Planning 108 8th Street, Suite 401 Glenwood Springs, CO 81601 MOUNTAIN CROSS ENGINEERING, INC. Civil and Environmental Consulting and Design EXHIBIT RE: Pond G Centralized E&P Waste Management Facility: LIPA-76511 Dear Glenn: This office has performed a review of the documents provided for the Limited Impact Review Application for the Pond G Centralized E&P Waste Management Facility. The submittal was found to be thorough and well organized. The following comment was generated: • The application materials did not include any information on any water rights pertinent to the proposed water to be stored. The Applicant should provide evidence to address the legal use of the water. Feel free to call if you have any questions or comments. Sincerely, Mount in Cross Engir}eering, Inc. Chris Hale, PE 8261/2 Grand Avenue, Glenwood Springs, CO 81601 P: 970.945.5544 F: 970.945.5558 www.mountaineross-eng.com October 8, 2013 EXHIBIT 10 D a� Garfield County Glenn Hartmann Garfield County Community Development Department RE: OXY Pond G Water Impoundment LIPA-7650 Vegetation Manaaemen t Dear Glenn, Thanks for the opportunity to comment. Noxious Weeds The Biological Resources section addresses noxious weeds and is acceptable. Revegetation The proposed seed mix listed in the Biological Resources section is acceptable. It is my interpretation that the proposed project falls under the jurisdiction of the Colorado Oil and Gas Conservation Commission as it is a well pad site. Please let me know if you have any questions. Sincerely, Steve Anthony Garfield County Vegetation Manager 0375 County Road 352, Bldg 2060 Rifle, CO 81650 Phone: 970-945-1377 x 4305 Fax: 970-625-5939 Glenn Hartmann From: Morgan Hill Sent: Friday, October 04, 2013 3:30 PM To: Glenn Hartmann Subject: OXY Pond G Water Impoundment and Storage Facility LIR Hi Glenn, EXHIBIT I've reviewed the appropriate application materials and have a couple questions/comments on the OXY Pond G Water Impoundment and Storage Facility LIR: - Air Quality: I didn't see any mention of air permitting for the pond. Other water impoundment/water treatment facilities of this type that 1 have seen are required to obtain at least an APED or an exemption. Water quality: the applicant should use all measures to be sure that Cascade Creek is not impaired by pollution from the water impoundment and storage facility. Perhaps this should include a monitoring well, or at least strict attention to leak detection equipment. Future facilities: One of the benefits of the facility described in this application are decreased need for disposal and the potential for reuse of the water. However, I did not see a description of a water treatment facility, other than gravity separation, on the site. What are the applicant's plans for water treatment before reuse? Is there another treatment facility located away from the storage pond? While a site visit will require significant travel time due to its remote location, please let me know if you go and I will try to tag along. Thanks and have a good weekend! Morga# ;nee Environmental Health Specialist II Garfield County Public Health 195 W. 14th Street Rifle, CO 81650 Phone: (970) 665-6383 Email: mhill@garfield-county.com www.garfield-county.com/environnnental-health COLORADO PARKS & WILDLIFE Northwest Regional Office 711 independent Ave.. Grand Junction, Colorado 81505 Phone (970)255-6100 • FAX (970)255-6111 wildlife.state.co.us • parks.state.co.us October 3, 2013 Glenn Hartmann Garfield County Building and Planning Department 108 8th Street, Suite 401 Glenwood Springs, CO 81601 RE: Oxy Pond G Centralized E&P Waste Management Facility Dear Mr. Hartmann: Colorado Parks and Wildlife (CPW) would like to thank you for the opportunity to work with Garfield County in the review of the Oxy Pond G Centralized E&P Waste Management Facility. This project is to be located in the SE 'A of the NW 'A of Section 16, Township 6 South, Range 97 West, of the 6th Principal Meridian in unincorporated Garfield County on an existing pad site. This request would convert an existing production pond to a centralized E&P waste management facility. It is our understanding that the purpose of the facility is to conserve water by recycling flow -back and produced water for re -use in well stimulations or drilling. This site and associated access road is located within a greater sage -grouse production area. No significant impacts to wildlife are anticipated if the following recommendations are incorporated into the development of this project: • Night lighting should be of the full -cutoff type and/or timed or otherwise minimized to reduce disruption to wildlife. • The proposed location lies within year-round black bear habitat where human/bear conflicts have previously occurred. There is potential for human/bear confl icts with gas exploration employees who are working and/or camping in these areas during development operations. The potential for human/bear conflicts within these project areas would be greatly reduced by placing and utilizing "bear proof" trash containers at work-site/camping locations. Furthermore, workers affiliated with these projects should be advised not to feed bears, whether intentional or not, since this activity is a violation of Colorado Parks and Wildlife Commission Regulations and is detrimental to wild bears. CPW has information on the design and purchase of "bear proof" trash containers, and will provide this information to anyone who is interested in preventing conflicts with bears. • Following the completion of construction activities, newly exposed soils should be revegetated as soon as possible to prevent erosion and to reduce the likelihood of non - STATE OF COLORADO John W. Hickenlooper, Governor • Mike King, Executive Director, Department of Natural Resources Steven M. Yamashita, Acting Director, Colorado Parks and Wildlife Parks and Wildlife Commission: Robert W. Bray • Chris Castilian • Jeanne Horne Bill Kane, Vice -Chair • Gaspar Perricone • James Pribyl • John Singletary, Chair Mark Smith, Secretary • James Vigil • Dean Wingfield • Michelle Zimmerman Ex Officio Members: Mike King and John Salazar native plants becoming established in the area. Seed mix used for revegetation should be certified as weed -free and consist of native seeds from plants that are common to the area. • To reduce the likelihood of truck - wildlife collisions, proper speed limits (< 25 mph) should be posted and enforced on all service roads. • Fencing around the pit should consist of a minimum of a 7 -foot chain-link fence capable of preventing elk and deer from entering the pit; concurrently it should have a small mesh type of fencing along the bottom of the fence (buried one -foot below grade level and extending a minimum of two -feet above grade) capable of preventing small animals from entering between the gaps (gaps should be no larger than three -inches). • The pit should be constructed with a 4:1 slope escape ramp and/or with chain-link fencing in one corner of the pit to allow entrapped wildlife to escape. • The pit should be adequately netted to ensure that waterfowl and other birds are prevented from entering. • CPW requests to be notified immediately if any birds and/or wildlife are found dead or trapped within or around the pit, netting, or fences. • Construction activities for the facility should occur outside of the time period from March 1 through June 30 to minimize impacts to sage -grouse production areas. Colorado Parks and Wildlife appreciates the opportunity to work with Garfield County on this and other projects for the benefit of wildlife. If you have any questions please contact Albert Romero, District Wildlife Manager, at 970-216-3847. `Sincerely, JT Romatzke Area Wildlife Manager cc: Ron Velarde, NW Regional Manager Dean Riggs, Assistant NW Regional Manager Michael Warren, Energy Liaison Albert Romero, District Wildlife Manager Jim Komatinsky, Land use Specialist File 2 Glenn Hartmann From: Guy Patterson [gpatterson@debeque.org] Sent: Thursday, September 19, 2013 3:46 PM To: Glenn Hartmann Subject: OXY Pond G Water Impoundment and Storage Facility LIPA-7650 The Town of De Beque has no comment on this application. Thank you, Guy Patterson Guy Patterson Town Manager Town of DeBeque PO Box 60 381 Minter Ave De Beque, CO 81630 P 970-283-5475 x109 f- 970-283-5205 www. debeque. orq 1 EXHIBIT ! 3 D EXHIBIT ry STAI F. OF COLO John W. Hickenlooper, Governor Larry Wolk, MD, MSPH Executive Director and Chief Medical Officer Dedicated to protecting and improving the health and environment of the 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 Located in Glendale, Colorado www.colorado.gov/cdph e October 8, 2013 Laboratory Services Division 8100 Lowry Blvd. Deriver, Colorado 80230-6928 (303) 692-3090 Glenn Hartmann Garfield County Community Development Dept. 108 8th St., Suite 401 Glenwood Springs, CO 81601 people of Colorado RE: OXY Pond G Water Impoundment and Storage Facility Dear Mr. Hartmann: EZ CF IV r OCT 1 11013 GARHELD COUNTY MINTY DEVELOPMENT Colorado Department of Public Health and Environment On September 16, 2013, the Colorado Air Pollution Control Division (APCD) received a request for an air quality determination concerning OXY Pond G Water Impoundment and Storage Facility. APCD staff has reviewed the request and has determined that the following provisions of the Colorado Air Quality Regulations apply to the project. All sources of potential construction project air emissions in Colorado are required to obtain a construction permit unless specifically exempt from the provisions of Regulation No. 3. Go to the website www.colorado.gov/cdphe/APCD to view this regulation - click on Air Quality Regulations, then Regulation No 3. Section II.D,1 lists which projects are exempt from requirements of the regulation. In addition, you will need to establish whether you are in an air quality attainment or non -attainment area, by accessing the information at www.colorado.gov/cs/satellite/CDPHE-AP/CUON/ 1251595265316. Once it has been determined that an Air Pollution Emissions Notice (APEN) is required, the next phase of air permitting involves submission of an Application for Construction Permit for each facility and one APEN for each emission source. A source can be an individual emission point or group of similar emission points (see Regulation No. 3, Part A), Both APEN reporting and permit requirements are triggered by uncontrolled actual emission rates. Uncontrolled actual emissions are calculated based upon the requested production/operating rate assuming no control equipment is used. In general, an APEN is required for an emission point with uncontrolled actual emissions of any critical pollutant equal to or greater than the quantities listed below: AREA Attainment Area Non -attainment Area All Areas UNCONTROLLED ACTUAL EMISSIONS 2 tons per year 1 ton per year Lead emissions: 100 pounds per year Sources of non -criteria reportable pollutants have different reporting levels depending upon the pollutant, release point height and distance to the property line. Please see Regulation No. 3 Appendix A and C to determine the appropriate reporting level for each pollutant, and for a list of non -criteria reportable air pollutants. However, none of the exemptions from an APEN filing requirement shall apply if a source would otherwise be subject to any specific federal or state applicable requirement. Information concerning submittal of revised APEN is also given in Regulation No. 3, Part A. An APEN is valid for five years. The five year period recommences when a revised APEN is received by the Division. If you have any questions regarding your reporting or permitting obligations, please contact the Small Business Assistance Program at 303-692-3148 or 3175. Land development construction activities (earth moving) that are greater than 25 acres or more than six months in duration will require an APEN from the Air Division and may be required to obtain an air permit. In addition, a start-up notice must be submitted thirty days prior to beginning a land development project. Please refer to the website www.colorado.gov/cdphe/APCD for information on APEN forms. Click on Construction Permit and Compliance Forms, then click on the menu item that applies to your project. If you have any questions or need additional information, please call the phone number(s) listed above, or you may call/ e-mail me directly at 303-692-31271 jim.dileo@state.co.us. Thank you for contacting the Division about requirements for your project or permit. Sincerely, --(77\--1 J es A. DiLeo "NEPA Coordinator Air Pollution Control Division Colorado Department of Public Health and Environment Glenn Hartmann From: Jeff Hofman [jhofman@olssonassociates.com] Sent: Thursday, October 10, 2013 4:16 PM To: Glenn Hartmann Cc: daniel_padilla@oxy.com Subject: Pond G LIR Application Additional Information Attachments: Approved Earthen Pit Report 11-18-09.pdf; Form 2A Approved 09-20-09.pdf; HYDROTEST 2010 - 01-06-2011.tif; Signed Pond G Liner Sundry 08-18-2011.pdf; Pond G SPCC Documentation 10-8-13 .pdf EXHIBIT Glenn, Please find attached to this email a copy of the updated SPCC information for the Pond G E&P Centralized Waste Facility. Also attached is a copy of the approved Form 2A and Form 15 that originally established this facility plus documentation on the as -built and testing of the liners. Please let me know if there is additional information that you require for this application. After this week Craig Richardson will no longer be with Olsson Associates. Please copy me on any communications or additional questions regarding this Garfield County LIR application. Thanks Jeff Hofman, AICP 1 Olsson Associates 760 Horizon Drive, Suite 1021 Grand Junction, CO 81506 I jhofman@olssonassociates.com TEL 970.263.78001 DIRECT 970.263.6016 1 FAX 970.263.7456 L6OLSS N ASSOCIATES Please consider the environment before printing this e-mail. 1 PaIlk WAY SUBSTANTIAL HARM CRITERIA CHECKLIST Facility Name: Pond G Facility Location: SENW, Sec 16, T6S, R97W, 6th PM 1. Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000 gallons? Yes No 2. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and does the facility lack secondary containment that is sufficiently large to contain the capacity of the largest above ground oil storage tank plus sufficient freeboard to allow for precipitation within any above ground oil storage tank area? Yes X No 3. Does the facility have a total oil storage capacity greater than or equal to I million gallons and is the facility located at a distance (as calculated using the formula in Attachment C -III, Appendix C, 40 CFR 112 or a comparable formula) such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments? For further description of fish and wildlife and sensitive environments, see Appendices 1, 11, and III to DOC/NOAA's "Guidance for Facility and vessel Response Environments" (Section 10, Appendix E, 40 CFR 112 for availability) and the applicable Area Contingency Plan. Yes X No 4. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance (as calculated using the appropriate formula (Attachment C -III, Appendix C, 40 CFR 112 or a comparable formula) such that a discharge from the facility would shut down a public drinking water intake? Yes X No 5. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and has the facility experienced a reportable oil spill in an amount greater than or equal to 10,000 gallons within the last 5 years? Yes No X CERTIFICATION I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document, and that based on my inquiry of those individuals responsible for obtaining this information, I believ . : t the submitted info., ation is lure, accurate, and complete. Signature Name (print) Chris Clark Title Operations Manager Date /b 8 1-3 Oxy SPCC Facility Pond G Rev Date: 10/03/13 Page 1 piss oxy ENGINEERING CERTIFICATION Facility Name: Pond G Pursuant to §112.3(d) and by means of this certification, I attest that: - I am familiar with the requirements of the SPCC rule (40 CFR 112); - The facility has been visited and examined by myself or my agent; — This plan has been prepared in accordance with good engineering practice, including consideration of applicable industry standards, and with the requirements of the SPCC rule; - Procedures for required inspections and testing have been established; and, This plan is adequate for the facility. 38514 State Registration Number 4, Date CO State Note: The PE's certification does not relieve the owner/operator of the facility of the duty offirlly implementing the SPCC plan in accordance with all applicable requirements. Oxy SPCC Facility Pond G Rev Date: 10/03/13 Page 2 FACILITY OVERVIEW 1. Facility Name Pond G 2. Operational Area Cascade Creek 3. Physical Location (coordinates) SENW, Sec 16, T6S, R97W, 6th PM 4. Facility Contact Phone # (970) 263-3600 5. Photo: 6. Facility Description (physical layout & function of facility): This facility is a storage pond for produced or fresh water. Oxy monitors the fluid level to ensure adequate freeboard by installing ICONICS electronic equipment which transmits the fluid level to the field office in a daily report. Pond G is equipped with (2) 60 -mil HDPE liners and a monitoring system to visually identify any accumulation of liquid between the two liners. 7. Drainage Pathway and Distance to Navigable Waters: Spill direction is to the south and the nearest water body is approximately 600 feet to the south. 8. Oil Storage Containers/Other Bulk Chemical Storage: SPCC Tank ID Contents Capacity Units (bbl/gal) Containment Type A Discharges Prevention C1P1 Produced or Fresh Water 191,320 bbl Pond w/60 mil HDPE liner (x2) Level monitor and freeboard C2T1 Condensate 95 bbl Steel w/ liner ACC C2T2 Produced Water / Condensate 200 bbl Steel w/ liner ACC C2T3 Produced Water / Condensate 200 bbl Steel w/ liner ACC A Containmen Types: Steel w/ or w/o Liner, Earthen, Poly, Hesco, Concrete, Steel Stock Tank, Steel Trough, etc. or a combination, as applicable D Discharge P evention Measures: High Level Indicator (HLI), Adequate Container Capacity (ACC), Top Equalization Lines (TEL), Bottom Equalization Lines (BEL), etc. or a combination, as applicable 9. Flow -Through Process Vessels (Separators, Knock -out Pots, Filter Pods, etc): SPCC Unit ID Unit Type Material Processed Capacity Units (bbl/gal) Containment Type PMP1 Pump Produced or Fresh Water General Secondary (refer to Section 5.1) PMP2 Pump Produced or Fresh Water General Secondary (refer to Section 5.1) PMP3 Portable Pump Produced or Fresh Water General Secondary (refer to Section 5.1) 10. Notes (out -of -service, empty tank storage, portable containers on-site, deviation from SPCC rules, etc.): A Facility Response Plans is being prepared for this Facility. Oxy SPCC Facility Pond G Rev Date: 10/03/13 Page 3 NNtl1DV8d Feeder line from off-site n z 111 L-0 LLIJ Containment Production Tanks Non -Production Tanks Portable containment 0o ¢ cO c LL a Vapor Combustion Unit d .rne; ¢ Y 0 U a o ea c Y .O.i Above Ground Piping DO o• 0 4 1 Underground Water Piping Above Ground Water Piping t X TemporaryTank Storage area Direction of Flow Loading and Unloading Area m 2 'C a a. aOmEl a° E ,0w cc3 e 100 tcid W - 3 H r iU = u v L2 w w w U. t uuy,i C7 2i v .o z d 0 w N � a N ti 0 0 N O O Y 0) a) i U K Locations of underground piping are approximate. Not to scale. Page 1 FORM State of Colorado Anne, Oil and Gas Conservation Commission 1120 Liman Meet 9s Bol, Dow.Cyeaa 80203 Meow n01i6L21m FaD)089e2199 trikENI err SUNDRY NOTICE Submit plow pus ere copy. ma fermis In be used fa paltry. leclnial and Cn*wni r8e sundry Hamulbn. FO proposed or corbeled gmnuom. s.sae in an on maned inronnwon Page (Pegg 2 at N. ram.) Wendy ,sae or other hdMy by API Number or by OGCC Fadlky ID. Operator shoe seed en kfmnSla S copy dad sundry notlm for ma* !seeded b High Density Nese to the Load Government Designee (Rye 6036) 1. UGu: Operator Number. 66571 4. Contact Name 2 Nam) o10poabc OXY USA WIT LP Daniel 1. Padilla 3. M4rew 760 Horizon Drive, Suite 101 Phone: 970.263.3937 CIN: Grand Junoton Sora: co ZIp:a1epos Fax 970.293.3699 5.AR Number (15. CorrelateMs Attachment Chrdyy OP 000c 6. We6Facay None: Pond G OGCC Faaq ID Neter 414402 7. WelOFad9N Number 6. Lova (Ob06, Sec, Top, Rig, MMdan): SENW Sec 16, T6S R97W, 6th PM 70. FloM Now Grand Valley S. Cady Garfield 11. Federal. Indiana Stele Lone Number. Simper D0ettlonal Survey Slake Eqpt aagrana Technka Info Page General Notice CHANGE OF LOCATION: Attach New Survey Plat Change Vance ramp from EgahrSecton Lies Change d9mhee Footage to Exkmr Section Wes: Gunge oBatlbleaole Footage from ExWbrSectlm Lines: Change d°Womaek Footage to Ueda Sedan Una: Satchels bndm W/06, Sec, Tep, Fes Mer p duce of surface gb/gabsubskrSmand Rea requires new permit) FEI.FYA ❑ ❑ P1 mad. directional stray pubic rd, Play °dal Area (Me 603b)1 Yeetril, ❑ ❑ L ❑ ❑ I Nig, Densly Lade Distance to nearest poperty Me tie Distance b neared Longitude Dsknce to nearatlease Is location k a High Ground Bevel* Distance lo nearest sell None formation Surface owner caaoatlondate bra UAIA: Dee of Measurement PDD' Reading Instrument 0parebfa Nara ❑CHANGE SPACING UNIT Fomegdn Formad*Cole Spedlg serer number UMAcreage we oon%ureoon Remove from surface bond Signed eufese use apemen snubs 1 1 1 P1CHANGE OF OPERATOR (prior to drilling): tveoae: alarCHANGE WELL NAME NUMBER : Plugging BOnI: 0 Maser . bdaidud To: Efe dve Dau: [ LOCATION: ;NOTICE OF CONTINUED 5T IN SKIT well shut bOrSenn* abendced: Has Frodulion Equipment been removed from NR regsed 1/ dotal beau hen boyen. Date STATUS 5�'local* ever Wird 0 Yes 0 No Is site ready for lrepolm7 I. Yes 0 No del n Yes 0 N0 Dela Reedy for Inspection: ofbar ❑SPUD DATE ❑REQUEST FOR CONFIDENTIAL STATUS Rmnkenmeusmysee 0 SUBSEQUENT REPORT OF STAGE, SQUEEZE OR REMEDIAL CEMENT WORK •siren W and cernadlob &urmalbs came Cement bp Cement hybm Date Method used Cementing tool setllrggeddepth Conant I I I I 1 I I RECLAMATION: A0ech (ethnical page daahhp mal reclamation Teri reclamation WI commence on approximately picadores pa Rule 1004. le mnpleed and db bready brtapec6on II. Fired mtlpaIon Technical EnglneedrlgEEnvlfonmeatal Notice ❑Notice a Intent Appmsnate 8614 03W ❑Repro*Work Dae Date Won Competed: Details *Imre must be described In full on Technkal Informan on Page (Page 2 must be submitted.) DIrebntb Recd pole (submtbm 1) ❑Cha ge Daring Rem Epos Interval Chapped? OCesino CmeyYp Propam Cheng* CRepwdb Vent or Fate Crap* Wel OR* 502 variance requested lder. Change in Ph liner DEAF Wane Disposal ❑SeneSda Reuse of ESP Waste Callus UpdetetChage a Retned bl* Plea for Spas end Rebases I herebyced6y gat le daimenk made In PM?cm are, the amlmmybudedge, an, Caftan and impala Oda /r/l _ 5re1: denblyadille®oky.Com PMaNwre: Daniel I. Padilla The: 'initiatory Advisor COGCC Approved: CONDITIONS OF APPROVAL, IF ANY: Me: Date: FORM 4 Re 1TVfi Page 2 TECHNICAL INFORMATION PAGE 1. OGCC Operator Number: 66571 API Number. 2. Name of Operator. OXY USA WTP LP OGCC Fadliy ID # 414402 3. Udell/Facility Name: Pond G Well/Facility Number: 4. Location (OlrQtr, See, Twp, Rno, Meridian): SENW, Sec 16, TBS, R97W, 5th PM Tele ism Is to be completed Wierever a Sundry Notics4 sudrwed requiring dslSS report 01wurk to be pergrmed or comoNted. TNS Awn Null be lnnenwad%Rolm 30 drys «wo.t oompyledne'ertseguanf noon end mut eemT wy Form 4, papa 1. 5. DESCRIBE PROPOSED OR COMPLETED OPERATIONS FOR OGCC USE ONLY OXY USA WTP LP (Oxy) is notifying the COGCC regarding the revised liner configuration for Pond G. Oxy has constructed Pond G to have two (2) 60 -mil high-density polyethylene (HDPE) liners and one geocanposhe clay liner Instead of the proposed liner configuration following the COGCC Form 15 Earthen Pit Pemhh (approved November 13, 2009). Additionally, Oxy installed a gravel sump sight -pipe between the two 60 -mil HDPE liners to monitor any acaanulation of liquid between the liners. Oxy believes the configuration of the two 60 -mil HDPE linen, the geocomposite day liner, and the gravel sump argot-plpe gales greater protection and leak detection due to the increased HOPE thickness and early detection to potential leaks. The proposed configuration In the above-mentioned Form 15 induded one 60 -mil HOPE liner, a geosynthetic liner, and a gexanposite day liner which Oxy felt would not provide the needed thickness protedion, as wed as early detection of potential leaks. Oxy conducted a successful hydrotest In December 2010 and provided documentation to the COGCC on January 6, 2011. LL Y O N O co N E oN II w «. 7 d U o 4)E E 75 O > > U 0 O N CT 2 d / L O / _ i / 0 4 -•ET 0Q)) • a ; E a 0 / 4)) 0 N 4 b / ` G) O V W I 0 N C c Q) U' D 1_ N Q 00 1 01 ((00 d P U) E a 0 0. 0 1- 0. 0 M N co _ -1,204,910 cu ft = 214,585 bbls (w/2' FB) l4_ ) . / aa0a OXY USA WTP LP OXY A eubeldiary of Occidental Petroleum Corpomtbn 111111Q21111111111,9111111 III January 6, 2011 Chris Canfield, P.G. Environmental Protection Specialist, Northwest Region Colorado Oil and Gas Conservation Commission 707 Wapiti Court, Suite 204 Rifle, CO 81650 Subject: Pond G Status Date Facility ID # 414402 Garfield County, Colorado Dear Mr. Canfield, 760 Horizon Drive, Suite 101 Grand Junction, CO 81608 OXY USA WTP LP (Oxy) is pleased to provide documentation of the successful hydrotest completed on Oxy's Pond G. The hydrotest was completed in compliance with the Colorado Oil and Gas Conservation Commission's Notice to Operators Drilling Wells Within 3A Mile of the Rim of the Roan Plateau (6/12/2008). The pit maintained integrity throughout the 72 -hour hydrotest. In addition to the Pond G hydrotest, Oxy also completed a dye test. The pond was filled with dyed fresh water prior to the hydrotest while Oxy personnel monitored the gravel sump sight -pipe. During the hydrotest, no dyed liquid was identified in the sump area or sight -pipe. Oxy requests the effective status date for Pond 0 be changed from the permit approval date to December 19, 2010, the date of successful hydrotest. Oxy began the hydrotest on December 16, 2010 and finished on December 19, 2010 with a fluid change in the pond of + 4.5 inches of fluid. This increase in fluid is attributed to the snowy weather that occurred on two of the three days during the hydrotest. Please let me know if you have any questions or concerns, or if I can provide additional information regarding Pond G. Thank you, ��llF Daniel 1. Padilla Regulatory Advisor Enclosures: Hydrotest Notification Form cc: Wes Hobbs File OXY USA WTP LP - OPERATOR NO. 66571 HYDROTEST NOTIFICATION FORM Type of Pit: Flare Pit L Surface interval/well control L Blooey Pit L Reserve Pit 'NE Flowback Pit Cement returns Pit 5.4- Avco, Water Storage Pond Day 3 Other (Specify) L Pit Information Pit Name: Pond G Pit Location (Common Name): API Number (of Associated Well): . Location (Qtr. Qtr, Section, Township, Range, Meridian): Latitude: Longitude: Is pit located within '/a mile of Rim of the Roan Plateau: YES Hydrotest Parameters inspector Name (Print):f`Zab a& Gasanaignature: ..-tr,6eig D Beginning hydrotest tlme/date: /2/ntho /2270,,., • Beginning hydrotest fluid Level (feet): c f /Z N Completed hydrotest time/date: / z//t/io2 ''00/ Completed hydrotest fluid level (feet): q / e,, iy n iiaa�o�./ct,J, Fite 444 5.4- Avco, Weather Conditions: ay 1 v Da r2 Day 3 Ave, Temperature: 32'. AM 3Zit PM 34' AM 28'r PM 28F AM Zy°3c PM Cloudiness/Wind: Pt's/ cloudy / Pa, C/j4 swow ,SNar✓/ S,t/dtw Precipitation: 3"SMo4, CONsgpw Humid' : SO To 4t)% eio jo Did fluid level change after 72 -hour hydrotest? If yes: RECONSTRUCT PIT AND RECOMPLETE HYDROTEST If no: Date of pit operation: Were pictures taken during hydrotest? I.Cy re, hit GiiJte.Gtt Tn'kcn{ Additional notes of hydrotest: Fuld Le&e/ tGtiv-.r t'r/ /.✓,f!, �N.�r �Aielf di -cc owt/7. 2e.¢/c (deteGlio.t! is dC ,Vo «"end_e/e/a1 Pit Hydrotest Form FORM 2A Rev 04/01 State of Colorado 00 and Gas Conservation Commission 1120 Lincoln Street, Suite 801, Denver, Colorado 80205 Phone: (303) 894-2100 Fax: (303) 894-2109 1 New Location Oil and Gas Location Assessment Ix Amend Existing Location Location#: 324288 Submit original plus one copy. This form is to be submitted to the COGCC prior to any ground disturbance activity associated with oil and gas development operations. This Assessment may be approved as a stand alone application or submitted as an informational report accompanying an Application for Permit -To -Drill, Form 2. Approvalof this Assessment will allow for the construction of the below specified location; however, it does not supersede any land use rules applied by the local land use authority. This form may serve as notice to land owners and other interested parties, please see the COGCC web site at http://colorado.gov/cogcc/ for all accompanying information pertinent to this Oil and Gas Location Assessment. Ix This location assessment is included as part of a permit application DE ET OE ES Document Number: 1813668 Location ID: 324288 Expiration Date: 09/19/2012 1. CONSULTATION n This location is included in a Comprehensive Drilling Plan. CDP # f This location is in a sensitive wildlife habitat area. r This location is in a wildlife restricted surface occupancy area. I This location includes a Rule 306.d.(1)A.ii. variance request. 2. Operator Operator Number: 66571 3. Contact Information Name: DENNY VIGIL Name: OXY USA WTP LP Phone: (970) 263-3650 Address: P 0 BOX 27757 Fax: (970) 263-3694 City: HOUSTON State: TX Zip: 77046 email: DENNY_VIGIL@OXY.COM 4. Location Identification: Name: POND G Number: County: GARFIELD QuarterQuarter: SENW Section: 16 Township: 6S Range: 97W Meridian: 6 Ground Elevation: 8314 Define a single point as a location reference for the facility location. This point should be used as the point of measurement in the drawings to be submitted with this application. When the location is to be used as a well site then the point shall be a well location. Footage at surface: 1595 feet, from North or Sourth section line: FNL and 1607 feet from East or West section line. FWL Latitude: 39.525690 Longitude: -108.228311 PDOP Reading: 2.5 Date of Measurement: 08/28/2008 5. Facilities (Indicate the number of each type of oil and gas facility planned on location): Special Purpose Pits: O Drilling Pits: 1 Wells: O Production Pits: 1 Dehydrator Units: Condensate Tanks: Water Tanks: O Sparators: O Electric Motors: Multi -Well Pits: Gas or Diesel Motors: 1 Cavity Pumps: 1 LACT Unit: Pump Jacks: Pigging Station: Electric Generators: Gas Pipeline: Oil Pipeline Water Pipeline: 1 Flare: Gas Compressors: VOC Combustor: Oil Tanks: Fuel Tanks: Other: Date Run: 9/20/2009 Page 1 of 4 6. Construction: Date planned to commence construction: 05/01/2009 Size of disturbed area during construction in acres: 7.00 Estimated date that interim reclamation will begin: 06/01/2012 Size of location after interim reclamation in acres: 3.90 Estimated post -construction ground elevation: 8330 Will a closed loop system be used for drilling fluids: Yes r Will salt sections be encountered during drilling: Yes r No TX Is H2S anticipated? Yes I No r Will salt (>15,000 ppm TDS CI) or oil based muds be used: Yes 7 No Tx Mud disposal: Offsite r Onsite r Method: Land Farming r Land Spreading r Disposal Facility Other: 7. Surface Owner: Name: Phone: Address: Fax: Address: Email: City: State: Zip: Date of Rule 306 surface owner consultation: Surface Owner: Tx Fee r State EFederal I Indian Mineral Owner: Tx Fee r State I Federal I Indian The surface owner is: Xthe mineral owner r committed to an oil and gas lease r is the executor of the oil and gas lease jg the applicant The right to construct the location is granted by: r oil and gas lease r Surface Use Agreement F Right of Way applicant is owner Surface damage assurance if no agreement is in place: r $2000 F $5000 r Blanket Surety ID 8. Reclamation Financial Assurance: TK Well Surety ID: 20060012 F Gas Facility Surety ID: r Waste Mgnt. Surety ID: 9. Cultural: Is the location in a high density area (Rule 603.b.): Yes r No K Distance, in feet, to nearest building: 16579 , public road: 2966 above ground utilit: 4200 , railroad: 63360 property line: 3954 10. Current Land Use (Check all that apply): Crop Land: I Irrigated I Dry land r Improved Pasture r Hay Meadow r CRP Non -Crop Land: TX Rangeland F Timber I Recreational r Other (describe): Subdivided: 7 Industrial F Commercial r Residential 11. Future Land Use (Check all that apply): Crop Land: r Irrigated F Dry land r Improved Pasture F Hay Meadow r CRP Non -Crop Land: Tx Rangeland r Timber r Recreational F Other (describe): Subdivided: F Industrial F Commercial r Residential 12. Soils: List all soil map units that occur within the proposed location. Attach the National Resource Conservation Service (NRCS) report showing the "Map Unit Description" report listing the soil typical vertical profile. This data is to used when segregating topsoil. Date Run: 9/20/2009 Page 2 of 4 The required information can be obtained from the NRCS web site at http://soildatamart.nrcs.usda.gov/ or from the COGCC web site GIS Online map page found at http://colorado.gov/cogcc. Instructions are provided within the COGCC web site help section. NRCS Map Unit Name: PARACHUTE -RHONE LOAMS. 5-30% SLOPES. #57 NRCS Map Unit Name: NRCS Map Unit Name: 13. Plant Community: Complete this section only if any portion of the disturbed area of the location's current land use is on non -crop land. Are noxious weeds present: Yes F No r Plant species from: g NRCS or, 1R field observation Date of observation: 08/28/2008 List individual species: ARIZONA FESCUE. COLUMBIA NEEDLEGRASS. SLENDER WHEATGRASS. LETTERMAN'S NEEDI FGRASS El K SFDGE AND MOIINTAIN BIG SAGE Check all plant communities that exist in the disturbed area. L Disturbed Grassland (Cactus, Yucca, Cheatgrass, Rye) r- Native Grassland (Bluestern, Grama, Wheatgrass, Buffalograss, Fescue, Oatgrass, Brome) FR Shrub Land (Mahogany, Oak, Sage, Serviceberry, Chokecherry) F lains Riparian (Cottonwood, Willow, Aspen, Maple, Poplar, Russian Olive, Tamarisk) I Mountain Riparian (Cottonwood, Willow, Blue Spruce) FR Forest Land (Spruce, Fir, Ponderosa Pine, Lodgepole Pine, Juniper, Pinyon, Aspen) r Wetlands Aquatic (Bullrush, Sedge, Cattail, Arrowhead) r Alpine (above timberline) F Other (describe): 14. Water Resources: Rule 901.e. may require a sensitive area determination be performed. If this determination is performed the data is to be submitted with the Form 2A. Is this a sensitive area: No I Yes Was a Rule 901.e. Sensitive Areas Determination performed: IX No f Yes Distance (in feet) to nearest surface water: 440 , water well: 8765 , depth to ground water: 110 Is the location in a riparian area: if No F Yes Was an Army Corps of Engineers Section 404 permit filed FR No fl Yes Is the location within a Rule 317B Surface Water Suppl Area buffer zone: Ix No F 0-300 ft. zone r 301-500 ft. zone r 501-2640 ft. zone If the location is within a Rule 317B Surface Water Supply Area buffer have all public water supply systems within 15 miles been notified: F No r Yes 15. Comments: 1) PRODUCTION PIT WILL BE LINED WITH 60 MILLS REINFORCED POLYETHYLENE. 2) 11x17" MAPS WERE SUBMITTED INSTEAD OF 8x11" IN ORDER TO PROVIDE DETAILED INFORMATION CONCERNING THE OPERATION AND SURROUNDING LANDS, 3) NRCS MAP INFORMATION WAS OBTAINED USING THE COGCC'S MOST UP TO DATE MAPPING TOOLS. 4) OXY IS BOTH THE SURFACE AND MINERAL OWNER FOR THE PROPOSED LOCATION. 5) OXY IS ALSO PROVIDING AN ATTACHMENT EXPLAINING WHY THE PROPOSED LOCATION IS NOT WITHIN A SENSITIVE AREA DETERMINATION. 6) LOCATION IS WITHIN A ROAN RIM NOTICE TO OPERATOR AREA. 7) LOCATION PICTURES, LOCATION DRAWING AND HYDROLOGY MAP IS BEING RESUBMITTED BECAUSE THEY WERE NOT IN COMPLIANCE WITH COGCC RULES; ALL OTHER DOCUMENTATION ON THE CHECK LIST WERE PREVIOUSLY SUBMITTED. I hereby certify that the statements made in this form are, to the best of my knowledge, true, correct and complete. Signed: Date: 06/08/2009 Email: DENNY_VIGIL@OXY.COM Print Name: DENNY VIGIL Title: REGULATORY ANALYST Date Run: 9/20/2009 Page 3 of 4 Based on the information provided herein, this Application for Permit -to -Drill complies with COGCC Rules and applicable orders and is hereby approved. COGCC Approved: Director of COGCC Date: 9/20/2009 Attachment Check List Att Doc Num Name Doc Description 1710646 LOCATION PICTURES LF@2061314j1710646 1710647 LOCATION DRAWING LF@20613151710647 1710648 HYDROLOGY MAP LF@206131611710648 1710649 REFERENCE AREA MAP LF@206131711710649 1710650 PROPOSED BMPs LF@206130911710650 1710651 CONST. LAYOUT DRAWINGS LF@206131111710651 1710935 CONST. LAYOUT DRAWINGS LF@208342811710935 1813668 FORM 2A LF@206130711813668 1813686 OTHER LF@206199311813686 2063082 LOCATION PICTURES LF@206131212063082 2063085 ACCESS ROAD MAP LF@206131812063085 2063086 NRCS MAP UNIT DESC LF@206130812063086 2063087 SENSITIVE AREA DATA LF@206131012063087 Total Attach: 13 Files Date Run: 9/20/2009 Page 4 of 4 FORM 15 Rev 6/99 11111101836551111 !II III III I III State of Colorado Oil and Gas Conservation Commission 1120 Lincoln Street, Suite 801, Denver, Colorado 80203 (303)894-2100 Fax:(303)894-2109 EARTHEN PIT REPORT/PERMIT This form is to be used for both reporting and permitting pits. Rule 903 describes when a Permit with prior approval, or a Report within 30 days, is required for pits. Submit required ` attachments and forms. FORM SUBMITTED FOR: ❑Pit Report :Pit Permit OGCC Operator Number: 66571 Name of Operator. OXY USA WTP LP Address: RD: Box 27757 City: Houston State: TX Zip: 77227-7757 Contact Name and Telephone: Denny Vigil No: 970-263-3650 RECEIVED APR 0 7 2009 C®CiCC FOR OGCC USE ONLY Complete the Attachment Checklist Oper OGCC Detailed Site Plan Topo Map 04 P4 Location Water Analysts (Form 251 eource Wells (Foran 26) PII Wpi on et Goss Sect 1 Design Calculations Fay; 970-263-3694 Sensilre Mao Detenn. Mud Program Form 2A API Number (of associated well): 05-045-10444-00 OGCC Facility ID (of other associated facility): Pit Location (QtrQtr, Sec, Twp. Rng, Meridian): SENW, Sec. 16, T6S, R97W. fith P.M. Latitude: 39.525690 Longitude: -108.228311 County: Garfield Ph Use: ❑ Production 0 Drilling (Attach mud program) ❑Special Purpose (Describe Use): Pit Type: ❑+ Lined 0 Unlined Surface Discharge Permit: ❑ Yes 0 No Offsite disposal of ph contents: ❑Injection 0 Commercial Pit/Facility Name: Pit/Facility No: Attach Form 28 to identify Source Wells and Form 25 to provide Produced Water Analysis results. J Existing Site Conditions Is the location in a 'Sensitive Area?' ❑Yes a No Attach data used for determination. Distance (in feet) to nearest surface water: 440' ground water: 110' water wells: 8765' LAND USE (or attach copy of Form 2A if previously submitted for associated well) Select g1le which best describes land use: Crop Land: 0 Irrigated 0 Dry Land 0 Improved Pasture 0 Hay Meadow 0 CRP Non -Crop Land:❑ Rangeland 0 limber ['Recreational 0 Other (describe): Subdivided: ❑Industrial 0 Commercial 0 Residenfial SOILS (or attach copy of Form 2A if previously submitted for associated well) Soil map units form USNRCS survey: Sheet No: 57 Sail Complex/Series No: Soils Series Name: Parachute -Rhone Looms Horizon thickness (in inches): A: 10 g; 15 C: 25 Soils Series Name: Horizon thickness (In inches): A: : B: ; C: Attach detailed site plan and topo map with pit location. Pit Design and Construction 1, Size of pit (feet): Length: 450'Width: 253' Depth: 14' (FreeBoard) Calculated pit volume (bbls): 214,565 (Freeboard} Daily inflow rate (bbls/day): Daily disposal rates (attach calculations): Evaporation: 194 bbls/day Percolation: 0 Type of liner material: Reinforced Polyethylene Thickness: 60 Milts bbls/day Attach description of proposed design and construction (include sketches and calculations). Method of treatment of produced water prior to discharge into pit (separator, healer treater other) Separator Is pit fenced? ❑+Yes ❑No Is pit netted? ❑Yes ❑No I hereby certify that the statements made in this form are, to the best of my knowledge, .e, correct, and complete. Print Name: Denny Vigil Signed: Title: Regulatory Analy;,� Date: 04/02/2009 OGCC Approved: LOSS/ Title: ;� "%WuDate: `//i/rN!�1 CONDITIONS OF APPROVAL, IF ;4Y: FACILITY NUMBER: y i L.1 a z 0 V 0 O cc a 0 N -a Volume of Pit = 258,230 bbls (without FB) N > 0 Volume Calculation: 0. 2 M N a w N RECEIVED APR c 72 DGc 309 G Production Pit c (7 0 0 0 OXY USA WTP LP Not to scale April 02, 2009 0 439' fb I 362 ft / \ RECEIVED APR c 72 DGc 309 G Production Pit c (7 0 0 0 OXY USA WTP LP Not to scale April 02, 2009 • RECEIVED I APR 0 7 2009 COCCI Calculations for Earthen Pit Permit Applications Calculation of Pit Capacities: Pit capacities were estimated from length and width measured at ground level and at the bottom of the pit. Figure I shows the top view with the measured dimensions shown. For non -rectangular shapes, equivalent dimensions were used for volume calculations. For capacity calculations, the depth was reduced by two feet from the total pit depth to allow for a minimum of the required two feet of freeboard. Ls = Surface Length NNNLn = Bottom Length E m ._ u 3 Figure 1. Top View of an earthen pit. Figure 2 shows the dimensions and calculated terms in a cross-sectional view of a pit. The angle 3 is calculated from the length and width at the surface and the freeboard depth. Pits are designed to have a 2 (horizontal) to 1 (vertical) slope on the sides. With a ...2 -to 1 slope the angle 9 is 63:433° from vertical as shown by the yellow shaded area. 3 -io.o eq 4 Ls = Surface Length Lf = Freeboard Length Df = Total Depth • Df = Freeboard Depth at H Figure 2. Cross-section of an earthen pit. A sample calculation is shown based on the construction design for a 2500 barrel pit with a 10 -ft depth. The following terms are defined: Ls = surface length = 80' W, = surface width = 50' Lb = length along bottom = 40' Wb = width along bottom = 10' = total depth = 10' Dr= depth with 2' freeboard (D1 — 2') The distance al can be calculated from the measured surface lengths: at = (L, . Lb)/2 = (80'- 40')/2 = 20' The angle p can be calculated using the two sides of the yellow -shaded triangle. Tanp = opposite side/adjacent side = 20'/10' = 2.0 and taking the arctangent, (3 = 63.435°. Side az on the smaller yellow triangle can then be calculated using the angle (3 with the freeboard depth as: az = Dr* Tangent p = 8' *2.0 = 16' Lr = Ls - 2 * (ai -az) = 80' — 2 *(20'-16') = 72' The widths were calculated in the same manner using the same angle p: a, = (W,. Wb)/2 = (50'- 10')/2 = 20' az = Dr* Tangent p = 8'*2.0 = 16 Wf= Ws - 2 * (a1 -a2) = 50' — 2*(20'-16') = 42' Capacities were calculated using the standard formula for a truncated rectangular pyramid as follows where V is the pit capacity in cubic feet: V= 3 Df*[Lf *Wf+(Lf +Wf2 )(Lb+W/)+ Lb * Wbj Substituting example values (all dimensions are in feet) into the volume equation: 8*[72*42+(72+40(40+I%)+40*10] V- 3 The resulting volume is 12,930.7 ft3. Converting to barrels the capacity is: Capacity = 12930.7 ft3/5.61458 ft3/bbl = 2303 bbls Freeboard Surface Calculations Surface Volume at Freeboard Line The volume at the freeboard line is calculated for a depth of 1 inch using the freeboard length and width and converting to barrels as: SurfaceVolume = Lr (ft) * W` (ft) * (1"depth) 5.61458 cu ft/bbl For the example calculation: Surface volume of 1" @ freeboard line = (72')*(42')*(1/12')/5.61458 ft3/bbl = 45 bbls Evaporation Rate The evaporation rate is calculated from the surface area at the freeboard based on the average evaporation rate for Garfield County of 45 in/yr/sq ft surface area. The evaporation rate in barrels per day is calculated by the equation: Evaporation Rate — Lr (ft)* Wr (ft)*(evap rate (in) /12) (365 days/yr) * (5.61458 cu ft/bbl) Using the sample calculation numbers the evaporation in bbUday is: Evaporation rate = (72')*(42')*(45 "/I2) / (365 days/yr)*(5.61458 ft3/bbl) = 5.5 bbl/day "° °""`"'° ory S310N 1N3WdOl3A3O IIS ONtl NOIiV b1ONOd xosxvazss— oaiaxm _ xm oP.wAo...x�W NONOd M0 J /NOW -110 ]NI' S1NV11IISNDD AU :»aawe ..A o aocwz —�— _ MSN _ I I`III J NVId SS30'Jtl 4 3'JtlNIV210'`JNIOVM'J 0ONOd xosmnvss O,IONSV MOr. ® 0.22129 11.1111 SU. n14N� 99NOd �a^'^� dl .11.1/1 Ysn.uro NOJ INON-tlO ']NI'(1NYILI OXY USA WTP LP OXY 760 Horizon Drive, Suite 101 Grand Junction, CO 81506 �r f 161`'� I OXY Cascade Creek Operations y.J'fy 1 Garfield0County, Colorado \, 0 .075 0.0375 0.15 Miles { 1 I 11 L / Or/owned roads _. unimproved Pudic Road Gravel Public Road Pared Puoik Rose! "1411,, OXY USA WTP LP and OXY USA Inc. o x Y Subsidiaries of Occidental Petroleum Corporation October 18, 2013 Mr. Glenn Hartmann Community Development Department Garfield County 108 81h Street, Suite 401 Glenwood Springs, CO 81601 a 2 EXHIBIT 1(� 760 Horizon Drive, Suite 101 Grand Junction, CO 61506 Re: Oxy Air Regulatory Permitting Statement for Proposed E&P Waste Management Facilities Located in the Cascade Creek Operating Area Garfield County, Colorado Dear Mr, Hartmann, OXY USA WPT LP (Oxy) is upgrading its existing storage ponds from COGCC permitted multi -well storage ponds to COGCC Centralized E&P Waste Management Faculties. The upgrades triggers a review of air permitting regulatory (local, state, and federal) requirements. Oxy has hired an air consultant to prepare a Reasonably Available Control Technology (RACT) analysis for determination of appropriate control of hydrocarbons from the produced water and flowback water storage impoundments. The RACT analysis covers the following facilities: Pond 10,. Pond 13 East and West, and Pond G, Once the RACT control method and facility wide potential emissions are identified and analyzed, Oxy will respond accordingly, which may Include preparing and submitting any required APENs to the CDPHE. The target completion and submittal date for this activity Is November 30, 2013. Oxy will provide the Garfield County Community Development Department (CDD) with the results of the RACT analysis and if APEN application submittal's are required, Oxy will also provide them to CDD. Copies of approved APEN's will be provided to CDD. Please contact me if you have any questions, comments, concerns, or if you require additional information. I can be reached at 970.263.3637 or at daniel_padilla roxy.com. Sincerely, /� Daniel I, Padilla Regulatory Advisor Cc: file M. Brygger Olsson Glenn Hartmann From: Albert Romero - DNR ralbert.rornero@state.co.us] Sent: Thursday, October 17, 2013 11:40 AM To: Glenn Hartmann Subject: Oxy pond G EXHIBIT 17 Glenn - I spoke with Daniel Padia of OXY yesterday regarding netting vs flagging on Pond G. I also spoke with you regarding the same project on Monday October 14. CPW is OK with the use of flagging with the understanding that if issues with water entering the pond arise, netting will be used to mitigate such issues. If you have questions please call me at 970-216-3847 i