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2.0 BOCC Staff Report 06.16.2014
Garfield County Board of County Commissioners Public Hearing Exhibits Limited Impact Review Land Use Change Permit Marathon 32C Produced Water Impoundment (File LIPA-7775) Applicant: Marathon Oil Company June 16, 2014 Exhibit # Exhibit Description 1 Public Hearing Notice Information Form and Attachments 2 Garfield County Land Use and Development Code, as amended 3 Garfield County Comprehensive Plan of 2030 4 Application 5 Staff Report 6 Staff Presentation 7 Referral Comments from Garfield County Consulting Engineer 8 Referral Comments from Garfield County Vegetation Manager 9 Referral Comments from Garfield County Environmental Health 10 Referral Comments from the Colorado Parks and Wildlife 11 Referral Comments from the Town of Parachute 12 Referral Comments from the CDPHE Air Pollution Control Division 13 Referral Comments from Colorado Division of Water Resources 14 Community Development Policy 01-14, Waiver for Roads and Demonstration of Compliance 15 Response Letter and Attachments from the Applicant (dated 6/13/14) 16 Road Engineering Letter from Rock Solid Solutions (dated 6/15/14) 17 18 19 20 21 22 23 24 25 26 27 28 EXHIBIT 1 Garfield County PUBLIC HEARING NOTICE INFORMATION Please check the appropriate boxes below based upon the notice that was conducted for your public hearing. In addition, please initial on the blank line next to the statements if they accurately reflect the described action. My application required written/mailed notice to adjacent property owners and mineral owners. Mailed notice was completed on the 6 day of May , 2014. ih All owners of record within a 200 foot radius of the subject parcel were identified as shown in the Clerk and Recorder's office at least 15 calendar days prior to sending notice. ih , All owners of mineral interest in the subject property were identified through records in the Clerk and Recorder or Assessor, or through other means [list) information provided by Marathon Please attach proof of certified, return receipt requested mailed notice. r' My application required Published notice. jh Notice was published on the 15 day of May , 2014. ■ Please attach proof of publication in the Rifle Citizen Telegram. f My application required Posting of Notice. jh Notice was posted on the 8 day of May , 2014. ih Notice was posted so that at least one sign faced each adjacent road right of way generally used by the public. I testify that the above information is true and accurate. Name: Jeff Hofma J� j Signature: I Date: May 21, 2014 Marathon Oil Company 32C Produced Water Pond Adjacent Landowners & Mineral Rights Owners ADJACENT LAND OWNERS Parcel Number: 213532100009 Attn: Tax Department Berry Petroleum Company 1999 Broadway, Ste 3700 Denver, CO 80202 Parcel Number: 213532100009 Marathon Oil Company 5555 San Felipe Houston, TX 77056 Parcel Number: 213532100009 PGR Partners, LLC 370 17th St, Ste 4300 Denver, CO 80202 Parcel Number: 213532100009 Wapiti Oil & Gas, LLC 800 Gessner, Ste 700 Houston, TX 77024 Parcel Number: 213529100008 Chevron Texaco Property Tax Chevron USA Inc PO Box 285 Houston, TX 77001 MINERAL RIGHTS OWNERS Chevron Texaco Property Tax Chevron USA Inc PO Box 285 Houston, TX 77001 Parcel Number: 213527300015 Encana 0ii & Gas (USA) Inc. cfo Merritt Appraisals & Tax Consulting PO Box 330 Gainesville, TX 76241 Parcel Number: 213533400010 Chevron Texaco Property Tax Chevron USA Inc. PO Box 285 Houston, TX 77001 Parcel Number: 216902200019 Richard L, Lyle & Ned Prather PO Box 165 DeBeque, CO 81630-0165 Parcel Number: 216902200019 Donna J Koehler PO Box 300 DeBeque. CO 81630 Parcel Number: 216902200019 Jo.lo Properties, LLC PO Box 1926 Rifle, CO 81650 Page 1 213527300015 ENCANA 213532100009 BERRY PETROLEUM C e P`ANY 32C Water Impoundment 21 533400010 21690220 01 PRATHER, RICHARD A 216901100027 BERRY PETROLEUM COMPANY 8. Parcels represented with labels are within 200' of affected parcel Legend 32C Water ImpOungmerrl Q Parcel 2 13522100009' 1680 Acres' Parcels Route la Facility 0 0 225 0 45 Miles 0.9 PROJECT NO 012.1372 DRAWN BY Jenna Muwb ct1 DATE 5117/2013 ADJACENT PARCEL MAP 32C WATER IMPOUNDMENT MARATHON OIL COMPANY GARFIELD COUNTY. COLORADO OLSSON ASSOCIATES rS0 HORIZON DRIVE. SUITE 102 GRAN❑ JUNCTION CO 0150e TEL 970 253 3930 SAX 970 200 7455 FIGURE AP -1 U ri m ru ci7 Fit FL1 D D D n r� ru 1-9rt 6t m rU ru D w D D D FU D U.S. Postal Service,, CERTIFIED MAIL- RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery information visit our website at www.usps.com;, Postage $ Careered Foo Schen Receipt Foe (Endorsement Required) Rastncted Naivety Fee (Enenrr mentRegired) Total Pn.etaee 1 Fey X 5 c Q 48 3.3 2.7 0.0 6.48 Attn: Tax Department Berry Petroleum Company 1999 Broadway, Ste 3700 Denver, CO 80202 U.S.. Postal Servicer• CERTIFIED MAIL,,, RECEIPT (Domestic Mail Only, No Insurance Coverage Provided) Postage Cenili,d Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement. Required) Se 48 3.30 2.70 0.00 6.48 Marathon Oil Company s" 5555 San Felipe or cit Houston, TX 77056 ilL U.S. Postal Service, CERTIFIED MAIL-. RECEIPT (Domestic Marl Only: No Insurance Coverage Provided) For delivery information visit our website at www.usps.com;. Certified Feu Return Receipt Fee (Endorsement Required) Restricted Derrvery Fee (Endorsement Required) Totyl Prodar,r, * Fww cif .48 3.30 2.70 0.00 648 Richard L, Lyle & Ned Prather PO Box 165 DeBeque, CO 81630-0165 rn ru rJ r- ru D ru D D r rt.i ra m ru r- nJ Fu D D C:1 D ra ru D N fl! m ru co r- 1 -1.J ru D ru D D D f=1 r --R ru D r - U.S. Postal Service - CERTIFIED MAIL, RECEIPT (Domestic Matt Only; No insurance Coverage Provided) For delivery information visit our website at www.trsps.com,, Postage Certified Fee Rotum Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Prrrnne R Fnac .48 3.30 270 0.00 6.48 PGR Partners, LLC 3 370 17th St, Ste 4300 c Denver, CO 80202 Instructions U.S. Postal Servicer., CERTIFIED MAIL— RECEIPT (Domestic Mall Only; No insurance Coverage Provided) For delivery information visit our website at www.usps.corttc Postage Certified Foe Return Receipt Foe (Endorsement Regulate) Restricted Delivery Feu (Endorsement Required) c $ .48 3.30 2,70 0.00 6.48 Wapiti Oil & Gas, LLC 800 Gessner, Ste 700 Houston, TX 77024 U.S. Postal Service,:, CERTIFIED MAIL,,., RECEIPT (Domestic Mali Only; No Insurance Coverage Provided) For dellvory Information visit our website at www.usps.com . Postage Curtilted Fee Return Recorpt Foo (Endorsement Required) Resented Delivery Fee (Endorsement Require) Tom. o..'....... • r,.... Sent $irria or Pt crit' $ 48 3.30 2.70 0.00 6.48 JoJo Properties, LLC PO Box 1926 Rifle, CO 81650 ff m ru RJ D ru Reese ee D id rg R�i:� eco Restricted Newby Fee (Ere:seare d Rd:lured) ra U.S. Postal Service CERTIFIED MAIL RECEIPT (Domestic !.Tail Only; No ln&uranoe Coverage Provrded) For delivery information visit our website at www.usps.coin 3. 2.70 0.00 6.48 ru 56 Chevron Texaco Property Tax in Chevron USA Inc N PO Box 285 Houston, TX 77001 ru ru r- ru lu D ru to D ru rLF r- nJ ID ru 0 Gl D rR ri ru r'a U.S. Postal Service • CERTIFIED MAIL. RECEIPT (Domestic Ml3it Only. No Insurance CcLeraae Provided; For delivery information visit our wottsite at www.usps. corn Receipt Fie (Embroilment recent Required) Reetrieted Delivery Fee (Endorsement Ter.' ar soar. A Fere Ft 2I IL .48 3.3Q 2.70 0.00 6.48 Donna J Koehler P© Box 300 DeBeque, CO 81630 U.S. Postal Service CERTIFIED MAIL RECEIPT (Domestic Mail Only: No Insurance Coverage Provided) information Visit our wetts'Ie dl v. w nJ Rot Receipt Fee {Endorsement Remdred) r* trim ure it 1,••• L.... .48 3.30 2.70 0.00 6.48 7 Encana Cil & Gas (USA) Inc. c/o Merritt Appraisal & Tax Consulting .e PO Box 330 a Gainesville, TX 76241 1010 0002 0278 ru D T" - MEM IJ S. Postal Service CERTIFIED MAIL . RECEIPT (Domestic Mail °nly,` No Insurance Coverage Provided) For delivery information visit our website at vinw+.usps.comr_ Postage Candied Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsemetrt Required) Total Postage & Fees / .48 3.30 2.70 6 0.00 rr 6.48 Ssnrro )61 - or stmt. API r40-; or PO Sox No. L.+ Etize,.. City, srattr. 21P+4 I) f 14-S &I) P$ Form 3800. Augus1 2t81( Sce itc.c,;r• tor Ins tioliOne SENDER: COMPLETE THIS SECTION • Complete Items 1, 2, and 3. Also complete item 4 If Restricted Delivery is desired. • Print your name and address an the reverse so that we can return the card to you. • Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Attn: Tax Department Berry Petroleum Company 1999 Broadway, Ste 3700 Denver, CO 80202 COMPLE IE l!11S SECTION ON DELlvr_RY B. R TI ❑ Agent ❑ Addressee by (Printed` Name) C. D e of I Delivery ❑ . Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: ❑ No 2. Article Number rrrensfer (ram service label) 3. al ice Type alCertified Mail ® Registered ❑ insured Mail ❑ Express Mail l] Return Receipt for Merchandise ❑ C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 7012 1010 0002 0278 2337 PS Form 3811, February 2004 Domestic Return Receipt OLSSON ASSOCIATES 760 Horizon Drive, Suite 102 Grand Junction, CO B1506 1 1 1 111 1 111 7012 101(1 fnnp PGR Partners, LLC 370 17th St, Ste 4300 Denver, CO 80202 SENDER: COMPLETE THIS SECTION 02595-02-M-1540 11 1 5.9! $6.4 US POST, FIRST -CL) 06250007190 81 NIXIE 802 DE 1025 0005/10/ 4 RETURN 10 SENDER ATT€MPTED — NOT ithiOM1N UNA3'_E TO 0R WARD BC: 81506396627 *1279-02,393-08-19 piph1104.11,lalll ilkd lulfl olr{1+3dolhrt,,r.1 • Complete items 1, 2, and 3. Also complete item 4 If Restricted Deiivery is desired. w Print your name and address on the reverse so that we can return the card to you. • Attach this card to the back of the mailpiece, or on the front it space permits. 1. Article Addressed to: Marathon ail Company 5555 San Felipe Houston, TX 77056 COMPLETE THIS SECTION ON DELIVERY At, Sig X Is deliveiy address dfrom item ? If YES, enter delivery address below ❑ Agent ❑ Addressee eat U'f Yes 0 Na livery 3. Se, ice Type O. Codified Mail ❑ Registered 0 Insured Mall 0 Express Mail ❑ Return Receipt for Merchandise 0 C.O.D. 2. Article Number (Transfer from service label) 4. Restricted Delivery? [Extra Fee) 0 Yes 703,2 1010 0002 0278 2351 PS Form 3811, February 2004 Domestic Return Receipt 1{]2545.02-M-1546 SENDER: COMPLETE TI -HS SECT►OAI • Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ■ Print your name and address on the reverse so that we can return the card to you. • Attach this card to the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: Wapiti OU & Gas, LLC 800 Gessller, Ste 700 Houston, TX 77024 COMPLETE THIS SECTION ON DELIVERY ❑ Agent ❑ Addressee C. Date of lielivery r7,. [C/ . D. !s delivery address ." '_"-'.nt from item 1? 0 Yes If YES, enter delive a •ress below: 0 No 3.ice Type Certified Mail 0 Express Mail Rostered 0 Return Receipt for Merch 0 inured Mait 0 C.Q.D. 4. Restricted Delivery? (Extra Fe@) 0 Yes 2. Article Number ?Transfer from service Labe ) 7012 1010 0002 0278 2368 PS Form 3811, February 2004 Domestic Return Receipt SENDER: COMPLETE Ti'-I1S SECTION • Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ■ Print your name and address on the reverse so that we can return the Card to you. • Attach this card to the back of the mailpiece, or on the front If space permits. toe's -02-M-1540 COMPLETE THIS SECTION ON DELIVERY A. Signature B. Received by f ' anted Name) 1. Article Addressed to: Richard L, Lyne & Ned Prather PO Box 165 DeBeque, CO 81630-0165 ❑ Agent ressee C. -bated Delivery D. Is delivery address different torn Rom 1? 0 Yes If YES, enter delivery address below: CCit@ Type cetlfied Mail 0 Express Mail 0 Registeredetum Receipt for Merchandise ❑ Insured Mail C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (Transfer from service label) 7012 1010 0002 0278 2375 Ps Form 3811. February 2004 Domestic Return Receipt 102595-02-M-1540 SENDER: COMPLETE THIS SECTION II Complete items 1, 2. and 3. Also complete item 4 if Restricted Delivery is desired. • Print your name and address on the reverse so that we can return the card to you. II Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: JoJo Properties, LLC PO Box 1926 Rifle, CO 81650 COMPLETE THIS SECTION ON D.LIVERY ig X 0 Agent 0 Addressee D. ived by (Pn'nteld Name I e. Dale of Delivery �? ❑ Yes ` ❑ No f D. 13 delivery address diffeierft Trot#, If YES, enter deliveery rens 1 lnri 1.014 rvlce Types Certified Mail 0 Eixprels's Malt ❑ Registered 0 Return Reoelpt for Merchandise ❑ Insured Mail 0 C.O.D. 4. Reslrfcted Delivery? (Extra Fee; 0 Yes 2. Article Number (Transfer from service label) 7012 1010 0002 0278 2382 PS Forrn 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 SENDER: COMPLETE THIS SECTION • Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. MI Print your name and address on the reverse so that we can return the card to you. ▪ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Chevron Texaco Property Tax Chevron USA Inc PO Bax 285 Houston, TX 77001 COMPLETE THIS SECTION ON DELIVERY A. X ignatur0 B. Received by ( Printed Name) D. Is delivery address ditlerent front if YES, enter deffivefy address be 5 0 tr 801 Soyvlce Type Gartiflr?d Mail 0 Registered 0 Insured Mail 0 Express Mail Q Return Receipt for Merchandise ❑ C.O.D. 4. Restricted Delivery? (Extra Fee) U Yes 2. Article Number (Transfer from service label( 7012 1010 0002 0278 2399 PS Form 3811, February 2004 Domestic Return Receipt 702595.02-M-1540 SENDER: COMPLETE THIS SECTION ■ Complete Items 1, 2, and 3. Also complete Item 4 If Restricted Delivery is desired. • Print your name and address on the reverse so that we can return the card to you. ■ Attach this card to the back of the maiipiece, or on the front if space permits. 1. Article Addressed to: Donna J Koehler PO Box 300 DeBeque, CO 81630 COMPLETE THIS SECTION ON DELIVERY A. S X i'art.s ❑ Agent Addressee C. Date of Defe.ery L D. s delivery address different from item 1? 0 If YES, miter delivery address below: S iceerl Type Certified Mail. ❑Express Mail D Registered"taciturn Receipt for Merchandise ❑ Insured Mall 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (Transfer from service label) 7012 1010 0002 0278 2405 PS Form 3811, February 2004 SENDER: COMPLETE THIS SECTION Domestic Return Receipt 102.595•0244•1540 II Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. O Print your name and address on the reverse so that we can return the card to you. ▪ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Encana Oil & Gas (USA) Inc. c/o Merritt Appraisal & Tax Consulting PO Box 330 Gainesville, TX 76241 COMPLETE THIS SECTION ON DELIVERY A. SI X u ❑ Agent Addressee C. Date at Delivery 2 D. Is .:lir"' add rros drftorent from item 17 0 Yes If YES, enter delivery address below: 0 No Seitice Type 21 Certified Mail ❑ Registered ❑ Insured Mail ❑ Express Mail ❑ Return Receipt for Merchandise ❑ C.O.D. 4. Restricted Delivery/ (Extra Fee) 0 Yes 2. Article Number (Transfer from service label) 7012 1010 0002 0278 2412 PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1570 SENDER: COMPLETE THIS SECTION • Complete items 1, 2, and 3. Aiso complete item 4 if Restricted Delivery is desired. • Print your name and address on the reverse so that we can return the card to you. Is Attach this card to the back of the maiipiece, or on the front if space permits. t. Article Addressed to: 19„,4.-.<5 mac' 6 .e s i'L CCMPLEIE I' I-1: S ry-'10k '1U CatiL:I C. Date of Deirvery 2. Article Number (Transfer from service label) 3. eMce Type Certified Mail 0 Express Mail Registered 0 Return Receipt for Merchandise 0 Insured Mail 0 C.O.D. 4. Restricted Delivery'? (Extra Fee) ❑ Yes 7012 1010 0002 0278 2429 PS Form 3811, February 2004 Domestic Return Receipt 102595-O2•M-1510 PUBLIC NOTICE TAKE NOTICE that Marathon Oil Company, in cooperation with Berry Petroleum, PGR Partners, LLC and Wapiti Oil and Gas, LLC has applied to the Board of County Commissioners. Garfield County. State of Colorado, to request approval of a Land Use Change Permit, Limited Impact Review (File Number LIPA-7775). for a Water Impoundment Facility. The site is located within the County of Garfield, State of Colorado, to -wit: Legal Description Section: 32 Township: 5 Range: 96 SEC 29 S1/2SW, S1/2SE, SEC 32 N1/2NE, SWNE, NW, N1/2SW, SESW, SE, SEC 33 SW Practical Description: The site is located approximately 11 miles northwest of the Town of Parachute and accessed by private roads off of County Road 215 It is located in the SE1/4SW1/4 Section 32, T5S, R96W and is part of a property known by Assessor's Parcel No. 2135-321-00-009. Request: The Applicant is seeking approval to convert an existing produced water pond located on a COGCC approved pad to a Centralized E & P Waste Management Facility. The pond capacity will be approximately 35,279 bbls. The facility will have support infrastructure including separation equipment and tanks, pond inlet and various support and transfer equipment. The facility will serve Marathon's Piceance Basin Operations. Water will be transported to the facility primarily via pipeline and only as needed by truck. The site is approximately 6.2 acres in size and is located on an overall tract of approximately 880 acres. The Property is zoned Resource Lands (RL) Plateau. The Applicant's designated representatives are Jeff Holman and Lorne Prescott with Olsson Associates. All persons affected by the proposed use are invited to appear and state their views, protests or support. If you cannot appear personally at such hearing, then you are urged to state your views by letter, as the Board of County Commissioners will give consideration to the comments of surrounding property owners, and others affected, in deciding whether to approve. approve with conditions or deny the request for a Land Use Change Permit. The application may be reviewed at the office of the Community Development Department located at 108 8th Street, Suite 401, Garfield County Plaza Building, Glenwood Springs, Colorado, 81601, between the hours of 8:30 a.m. and 5:00 p.m., Monday through Friday. A public hearing on the application has been scheduled for the 16th day of June. 2014 at 1:00 PM and will be held in the County Commissioners Meeting Room. Garfield County Plaza Building. 108 8th Street, Glenwood Springs, Colorado, 81601. Community Development Department Garfield County May 6, 2014 Attn: Tax Department Berry Petroleum Company 1999 Broadway, Ste 3700 Denver, CO 80202 SENT VIA CERTIFIED MAIL Subject: Marathon Oil Company 32C Produced Water Pond Limited Impact Review (LIPA-7775) Per the enclosed public notice. Marathon Oil Company has applied for a Limited Impact Review from Garfield County. As a surface owner of record of property within two hundred feet (2017") of the property or an owner of mineral interest in the property that is the subject of this application, we are hereby providing you with the enclosed notice. Please note that the hearing date for this application has been set for June 16, 2014 at 1:00 PM in the County Commissioners Meeting Room. Garfield County Administration Building, 108 8th Street, Glenwood Springs, Colorado. If you have any questions regarding this matter, please contact me at 970-263-7800. Sincerely, Jeff Hofman Associate Planner Olsson Associates Encl Public Notice May 6, 2014 PGR Partners, LLC 370 17th St, Ste 4300 Denver, CO 80202 SENT VIA CERTIFIED MAIL Subject: Marathon Oil Company 32C Produced Water Pond Limited Impact Review (LIPA-7775) Per the enclosed public notice, Marathon Oil Company has applied for a Limited Impact Review from Garfield County. As a surface owner of record of property within two hundred feet (200') of the property or an owner of mineral interest in the property that is the subject of this application, we are hereby providing you with the enclosed notice. Please note that the hearing date for this application has been set for June 16, 2014 at 1:00 PM in the County Commissioners Meeting Room, Garfield County Administration Building, 108 8th Street, Glenwood Springs, Colorado. If you have any questions regarding this matter, please contact me at 970-263-7800. Sincerely, Jeff Hofman Associate Planner Olsson Associates End: Public Notice May 6, 2014 Marathon Oil Company 5555 San Felipe Houston, TX 77175E SENT VIA CERTIFIED MAIL Subject: Marathon 011 Company 32C Produced Water Pond Limited Impact Review (LIPA-7775) Per the enclosed public notice, Marathon Oil Company has applied for a Limited Impact Review from Garfield County. As a surface owner of record of property within two hundred feet (200) of the property or an owner of mineral interest in the property that is the subject of this application, we are hereby providing you with the enctosed notice. Please note that the hearing date for this application has been set for June 16. 2014 at 1:00 PM in the County Commissioners Meeting Room, Garfield County Administration Building, 108 8th Street. Glenwood Springs, Colorado. If you have any questions regarding this matter, please contact me at 970-263-7800. Sincerely, Jeff Hofman Associate Planner Olsson Associates Encl Public Notice May 6, 2014 Wapiti Oil & Gas, LLC 800 Gessner, Ste 700 Houston, TX 77024 SENT VIA CERTIFIED MAIL Subject: Marathon 011 Company 32C Produced Water Pond Limited Impact Review (LIPA-7775) Per the enclosed public notice, Marathon Oil Company has applied for a Limited Impact Review from Garfield County. As a surface owner of record of property within two hundred feet (200') of the property or an owner of mineral interest in the property that is the subject of this application, we are hereby providing you with the enclosed notice. Please note that the hearing date for this application has been set for June 16, 2014 at 1:00 PM in the County Commissioners Meeting Room, Garfield County Administration Building, 108 8th Street, Glenwood Springs, Colorado. If you have any questions regarding this matter, please contact me at 970-263-7800. Sincerely, Jeff Hofman Associate Planner Olsson Associates Encl: Public Notice May 6, 2014 Richard L, Lyle & Ned Prather PO Box 165 DeBeque, CO 81630-0165 SENT VIA CERTIFIED MAIL Subject: Marathon Oil Company 32C Produced Water Pond Limited Impact Review (LI PA -7775) Per the enclosed public notice. Marathon Oil Company has applied for a Limited Impact Review from Garfield County. As a surface owner of record of property within two hundred feet (200') of the property or an owner of mineral interest in the property that is the subject of this application. we are hereby providing you with the enclosed notice. Please note that the hearing date for this application has been set for June 16, 2014 at 1:00 PM in the County Commissioners Meeting Room, Garfield County Administration Building, 108 8th Street, Glenwood Springs, Colorado. If you have any questions regarding this matter, please contact me at 970-263-7800. Sincerely, Jeff Hofman Associate Planner Olsson Associates Encl:Public Notice May 6, 2014 JoJo Properties, LLC PO Box 1926 Rifle, CO 81650 SENT VIA CERTIFIED MAIL Subject: Marathon Oil Company 32C Produced Water Pond Limited Impact Review (LIPA-7775) Per the enclosed public notice. Marathon Oil Company has applied for a Limited Impact Review from Garfield County. As a surface owner of record of property within two hundred feet (200') of the property or an owner of mineral interest in the property that is the subject of this application, we are hereby providing you with the enclosed notice. Please note that the hearing date for this application has been set for June 16, 2014 at 1:00 PM in the County Commissioners Meeting Room, Garfield County Administration Building, 108 8th Street, Glenwood Springs, Colorado. If you have any questions regarding this matter, please contact me at 970-263-7800. Sincerely, Jeff Hofman Associate Planner Olsson Associates Encl: Public Notice May 6, 2014 Chevron Texaco Property Tax Chevron USA Inc PO Box 285 Houston, TX 77001 SENT VIA CERTIFIED MAIL Subject: Marathon Oil Company 32C Produced Water Pond Limited Impact Review (Ll PA -7775) Per the enclosed public notice. Marathon Oil Company has applied for a Limited Impact Review from Garfield County. As a surface owner of record of property within two hundred feet (200) of the property or an owner of mineral interest in the property that is the subject of this application, we are hereby providing you with the enclosed notice. Please note that the hearing date for this application has been set for June 16. 2014 at 1:00 PM in the County Commissioners Meeting Room, Garfield County Administration Building, 108 8th Street. Glenwood Springs, Colorado. If you have any questions regarding this matter, please contact me at 970-263-7800. Sincerely, Jeff Hofman Associate Planner Olsson Associates Encl. Public Notice May 6, 2014 Donna J Koehler PO Box 300 DeBeque, CO 81630 SENT VIA CERTIFIED MAIL Subject: Marathon Oil Company 32C Produced Water Pond Limited Impact Review (LIPA-7775) Per the enclosed public notice. Marathon Oil Company has applied for a Limited Impact Review from Garfield County. As a surface owner of record of property within two hundred feet (200') of the property or an owner of mineral interest in the property that is the subject of this application, we are hereby providing you with the enclosed notice. Please note that the hearing date for this application has been set for June 16, 2014 at 1:00 PM in the County Commissioners Meeting Room, Garfield County Administration Building, 108 8th Street. Glenwood Springs, Colorado If you have any questions regarding this matter, please contact me at 970-263-7800. Sincerely, Jeff Hofman Associate Planner Olsson Associates Encl: Public Notice May 6, 2014 Encana Oil & Gas (USA) Inc. cfo Merritt Appraisal & Tax Consulting PO Box 330 Gainesville, TX 76241 SENT VIA CERTIFIED MAIL Subject: Marathon Oil Company 32C Produced Water Pond Limited Impact Review (LI PA -7775) Per the enclosed public notice, Marathon Oil Company has applied for a Limited Impact Review from Garfield County. As a surface owner of record of property within two hundred feet (200') of the property or an owner of mineral interest in the property that is the subject of this application, we are hereby providing you with the enclosed notice. Please note that the hearing date for this application has been set for June 16. 2014 at 1:00 PM in the County Commissioners Meeting Room, Garfield County Administration Building, 108 8th Street, Glenwood Springs, Colorado. If you have any questions regarding this matter, please contact me at 970-263-7800. Sincerely, l� Jeff Hofman Associate Planner Olsson Associates End' Public Notice Ad Name: 10174342A Customer: Olsson Associates Your account number is: 1006467 PROOF OF P1 ULICATION THE RIFLE CITIZEN TELEGRAM STATE OF COLORADO, COUNTY OF GARFIELD 1, Michael Bennett, do solemnly swear that I am Publisher of The Rifle Citizen Telegram, that the same weekly newspaper printed, in whole or in part and published in the County of Garfield, State of Colorado. and has a general circulation therein; that said newspaper has been published continuously and uninterruptedly in said County of Garfield for a period of more than fifty-two consecutive weeks. next prior to the first publication of the annexed legal notice or advertisement; that said newspaper has been admitted to the United States mails as a periodical under the provisions of the Act of March 3, 1879, or any amendments thereof, and that said newspaper is a weekly newspaper duly qualified for publishing legal notices and advertisements within the meaning of the laws of the State of Colorado. l hat the annexed legal notice or advertisement was published in the regular and entire issue of every number of said weekly newspaper for the period of 1 consecutive insertions; and that the first publication of said notice was in the issue of said newspaper dated 5/15/2014 and that the last publication of said notice was dated 5/15/2014 the issue of said newspaper. In witness whereof, 1 have hers: unto set my hand this 05/16/2014. _ Michael Bennett, Publisher Publisher Subscribed and sworn to before me, a notary public in and for the County of Garfield, State of Colorado this 05/16/2014. . .c• PAMELA J. 1. SCHULTZ Cir Co -c My Commission Expires IIf01l20I5 amela J. , chultz, NotarL' uhlic My Commission expires: November 1, 2015 PUBUC NOTICE TAKE NOTICE that Marathon al Company. ,n co - a erakon with Barry Pelraluum. PUF1 P81r0'$. LLC 060 W.WI+Oil and Res. LLG has apotiaa to 1110 Beare of Gounty COmm,smnnors carhela County. Stale of Colorado. to repueal approval of a Lend Use Chanppa0 Parma. Limited Impact Review toile NumbO, iIPA•77751.'lar a Wafer Impound- ment r=aorloy The site is iuGlrod wdhn me Courtly GarLela, Nate ot Costae), ro'wa LOW DeS113000r Section 32 Township 5 Range i8 SEC 28 ST 2SW. S1!2SE. SEC 32 N1;2NE. SWNE, NW. NI 25W. SESW. SE, sEc 33 SW Practical Dearjrphprr Tha Ina rs located approxi mately t 41 miles northwest of Ma Town o! Pars - Oldie and accessed oy prrvale roads Olt 01 County Roan 215 It rt to0ate0 m Ova SF 1,4SW 1!4 SOP. !Ion 32. tis, BMW and re pan et S proprny known by Maas/toes Parcel No. 2135.321 -00 -tug Request, The Applicant is sensing approval to convert en existing produced water pond monied 071 a COGCC appr0vea pad to a Centreline F rt r Waste Management facility. The pond capacity will co approximately 35,279 bele. Ina Iatilny will have support infrastructure .ncludrny separation equipment and 107118, pried inlet and vanuua sup- pon and Inmate, equipment. the IeciLly will serve Marathon's Plcaenco Basin Operanonw. Water will oa Iranapon/d to Ilia facility primarily 01! pipeline and only as needed Oy truck. the silo ra approxi- mately 8.2 acres in sin and is located On an over. at! Iraq of approximately 8160 eana. the Properly .stoned Hesouroa l ands (ftl.) Plateau. The AppL- canl's designated repiesenlalrvea are Jell Heiman end 1 Oma Prescol1 with Olsson Ao&ociata4 All persons auricled by lh proposed use ere moil- ed t0 appear enc Su110 111011 views, proteins or turn port. lt you cannot appear pereonelIy ■1 ouch Korona, than you are urged 10 Slate you• views by letter. as the Baird 01 County Commissioners will Rive can4Oratron to the centimetres ct surrounding properly ownersand When ellemed, rn diCldmp whaIMt to appoint, approve with CofWlI,OM or de- ny Inc request 101 a Imo Use Chug@ Permit. The appbcahon may be renew/0 at the sauce O1 the Community t)evelapmenl Department located at we 8m Streit, Suite 401 Garfield County Placa. flut10.ng. Glenwood $prrn;s, Colorado. 81621. helween the noun of a 301 a.m. and 5'00 p.m., Monday Ihraut* 0,day. A. public nearing on the application has been scnrdded for the 16111 day of June, 2014 at t 00 PFA and will be held in die County Commtearoners Meeting Roam, 13arhold. Go' Phan Building. 106 8171 Street. Glenwood Springs, Colorado 8160! :anwrwrvly Deva -print Deuanmsnt Garfield County Publrsned in the Ciuren Teleprarn May 15. 2014 110'743421 TAKE NOTICE That OIL COMPANY has applied to the BOARD OF COUNTY COMMISSIONERS Garfield. County pursuant to SECTIONS 3-402. 4-104, AR1iClES7 AND 15 LANDUSE & DEVELOPMT GOPE to allowWATER: IMPOUNDMENT FACILITY on this property. A public in the Plaza fluildin Westwood Springs on this application vnii be pedCountY CommIS5b0Mcl°tinCm. .ioa ath Street, Glenwood rin s CO 81501 . cotorado Date Notice Was Posted:MAX B.4 By _ JEFF 1-143EMLN-01-5-5524 ASSOCIATES For additional information, contact the GARFIELD COUNTY COMMUNITY DEVELOPMENT DEPT or 108 8th St. , Glenwood Springs. CO 8160 EXHIBIT s BOCC 6/16/14 File No. LIPA-7775 GH PROJECT INFORMATION AND STAFF COMMENTS REQUEST Limited Impact Review for a Water Impoundment APPLICANT Marathon Oil Company PROPERTY OWNER Marathon Oil Company, Berry Petroleum, PGR Partners LLC, Wapiti Oil and Gas LLC ASSESSOR'S PARCEL # 2135-321-00-009 PROPERTY SIZE The Site is approximately 3.5 acres in size on an overall tract of approximately 880 acres. LOCATION ACCESS The site is located approximately 11 miles northwest of the Town of Parachute. It is located in the SE1/4SW1/4 Section 32, T5S, R96W. The facility is accessed by a series of private roads off of County Road 215 built and maintained for use by the natural gas industry. The private roads are known as Garden Gulch Road and Garden Gulch Extension EXISTING ZONING The property is zoned Resource Lands (RL) Plateau I. GENERAL PROJECT DESCRIPTION The Applicant is seeking approval to convert an existing produced water pond located on a COGCC approved pad to a Centralized E & P Waste Management Facility. Under the proposed Application the existing 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, reduce environmental exposure, and operational costs. 1 The pond capacity will be 35,279 bbl (approximately 1.4 million gallons). The facility will have support infrastructure including separation equipment and tanks, pond inlet and various support and transfer equipment. The proposal also includes the use of a portable water treatment system to facilitate reuse of treated water. The facility will serve Marathon's Piceance Basin Operations. Water will be transported to the facility primarily via pipeline and only as needed by truck. Several gas wells have been drilled on the well pad and are currently producing. Additional well drilling activity is anticipated in the future to further develop resources in the area. Production infrastructure including production water storage is also found on the pad separate from the water impoundment operations/proposal.. The surface area of the pond is approximately 0.7 acres. The pond dimensions are 100 ft. by 300 ft. and 14.5 ft. deep. The pond operates with a minimum of 2 ft. of freeboard between the water surface and the top of the pond embankment. The pond has a double lining system that includes leak detection, a bentonite base layer and a geo-textile under layer for rock protection. The leak detection system is set up to allow for continuous off-site monitoring. The pond area is fenced and covered with a bird deterrent netting. There are four existing monitoring wells in place. The pond will help to minimize the need for off-site disposal and hauling water by tanker truck. The primary use of the water will be completion activities associated with 2 future Marathon drilling activities_ The proposed water treatment will utilize skid mounted (portable) filter systems and. two 400 bbl water storage tanks. The treated water will be utilized on site or within the Marathon field of operations. It will not be hauled elsewhere. The site will only be utilized by Marathon operations and existing pipelines serving the facility are in place and have County permitting. The pond has been constructed to meet the COGCC Form 28 standards and no change in the pond operation or facilities is anticipated to meet with COGCC approvals. Facilities as shown on the site plan include: • Water Impoundment, liners and leak detection systems • Gun Barrel Tank (500 bbl) and two Condensate Tanks (400 bbl each) • Water Tank (400 bbl) • 3 Phase Separator • Water Treatment Building (15' x 30' x 10 `) & Storage Building (10' x 15' x 10') • Two Water Tanks (400 bbl each) SITE PLAN ,l. • r %44 1- 411.' . 1 ' • 440444.4.44k Jana. 04 444 Miii• 7 �. it .afllrrf MR= �l t •:s R r~ ea..0 rw.%f� a El ...in* J. • u{Iln"R /FMK BAR .+y rip I I 1O11AlAA111 i1.I_I66 41414. 14i4 • f 4441 J. aim 3 B The pond will be unmanned and accessed by employees for typical monitoring and maintenance operations only (approximately once per day). AERIAL PHOTOGRAPH AND ADJOINING OIL AND GAS ACTIVITY APPLICANT'S SITE II. LOCATION - SITE DESCRIPTION The site is currently developed with the existing pond located within the leveled and graded areas associated with well pad activities. The site is bare of vegetation in the developed areas. The areas surrounding the site are sagebrush dominated shrub lands, scattered mountain shrub lands, and aspen woodlands on north and east facing slopes. The site slopes steeply down to Little Creek northwest of the site and House Log Gulch is located on the on the opposite side (south side) of the ridge from the site. The water impoundment is located on the cut slope site of the well pad away from the northerly perimeter of the well pad. The cut slope adjacent and above the impoundment also has steep slopes. 4 VIEW OF THE SITE LOCKING WEST 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: • Expressed questions about details on the water treatment facility. other ponds shown on drainage plan mapping, and details and provisions related to piping water to the facility. 2. Garfield County Road and Bridge Department: Verbal comments from Wyatt Keesbery, Foreman District 2, indicated that he had no issues with the application. 3. Garfield County Vegetation Manager, Steve Anthony: • Indicated that the weed plan is acceptable but requested an on-site inventory be completed this summer. • Indicated that the reclamation plan and seed mixes were acceptable. 4. Garfield County Environmental Health: Morgan Hill, Environmental Health Specialist noted the following topics. • Proper air quality permits from CDPHE including yearly evaluations • Use of tanks rather than ponds to reduce air emissions. • Details on the water treatment • Lining and monitoring seemed adequate to prevent seepage. • Use limited to Marathon Oil • Lack of County permits for the existing facility 5. Colorado Parks and. Wildlife: • Noted that the site lies within the COGCC mapped Greater Sage -Grouse production habitat and about two miles from the Bear Run and House Log Gulch lek sites • The site is within an area mapped by CPW as summer range for mule deer and elk and within the overall range on bear and mountain lion. • Indicated that there is potential for sediment to reach the Colorado River where the confluence with Parachute Creek is designated critical habitat for 4 federally endangered species of native fish. • The proposed site is within the boundaries of the Marathon Oil Company Wildlife Mitigation Plan (MOCWMP) agreement with CPW and noted recommendations including maintaining appropriate fencing and netting of the pond, piping of water to reduce impacts from trucks, and use of bear proof dumpsters for all food related trash. 6. Town of Parachute: Stuart S. McArthur, Town Administrator, indicated that the Town had no issues regarding granting this application. 7. Colorado Department of Public Health and Environment Air Quality Division. • Provided information on construction permits and Air Pollution Emissions Notice requirements (APEN) • Indicated that additional proposed equipment should be evaluated for emissions and permitting including additional storage tanks, three phase separator, and skid mounted filters. • Inclusion of skid mounted filters in any permit modification application. 8. Colorado Division of Water Resources: Responded that they did not have any comments to offer at this time. 9. 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) Grand Valley Fire Protection Fire District. 6 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. 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, 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 Goals 1. Ensure that natural, scenic. ecological. and critical wildlife habitat resources are protected and for 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. 7 Section 9 — Mineral Extraction Goals 1. Ensure that mineral extraction activities mitigate their effects on the natural environment, including air quality, water quality, wildlife habitat or important visual resources. 2. In working with mineral extraction projects, the county will protect the public health, safety and welfare of its citizens. Marathon 32C Site Comprehensive Plan Future Land Use Map - Excerpt 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. 8 4. Facilities that are appurtenances to ail/ 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, The request demonstrates general 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 be operated with only occasional staff activities and monitoring. The proposal indicates 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 field per OSHA standards. The Application documents that the source of production water handled on the site is the non -tributary Williams Fork Formation. 7-106: Public Utilities No public utilities are required for operation of the facility. Solar panels and/or generators may be utilized, 7-107: Access & Roadways The site is accessed from the site from County Road 215 via Garden Gulch Road, Garden Gulch Extension, and Lease Road. The submittals include waiver requests regarding the roadway standards. Lease Road This road section is the final portion of the access connecting from the Garden Gulch Extension to the water impoundment site and well pad. It is approximately 0.9 of a mile in length. A detailed evaluation of the Lease Road is provided in the Application consistent with the County Policy 01-14 "Waivers for Roads and Demonstration of Compliance" (see attached) The roadway meets the majority of County Standards as reflected in the following table from the Application. Waivers to the standards are requested for maximum grade (14.3%), cross slope (varies from 0 C 2%), and ditches (not always present depending on road section). The Application includes an engineer's report on the road including field inspections, review of conditions, and maintenance topics. The report concludes that the deficiencies from the County Standards "do not compromise the access to the site" and that the lease road "functions adequately for its intended use and is typical of existing roads providing access to natural gas production in Garfield County". The report was prepared by 9 Wyatt E. Popp P.E. and Christopher M. Rolling P.E. Staff supports approval of the waivers requested for the Lease Road Section of the access. DeSIgn Standards Ale 7-10r Hoadwray Standards Primitive/ Drivewa Marathon Lease Road <20 ADT Design Capacity (ADT) 0-20 Minimum ROW Width (Feet) 15 to 30 0 Lane Width Feat Sin le Lane 12 18- to 24.6' Shoulder Width (Feet) 0 0 Ditch Width (Feet) 3 0-3 Cross Sloe 2% 0 to >2% Shoulder Slope n/a n/a Design Speed nla n/a Minimum Radius (Feet) 40 >95' to 664' Maximum % Grade 12% 14.3% Surface Native Material Native Material TYPICAL LEASE ROAD SECTION APPROACHING THE SITE Garden Gulch Extension and Garden Gulch Road The Applicant is requesting waivers for these roads in regard to the detailed assessment of the road pursuant to Policy 01-14 and from the roadway standards 10 contained in the Land Use and Development Code. While these sections of roadway have some similarity to the Lease Road section they typically carry more traffic. have wider travel lanes, more frequent drainage improvements, more sections with steeper grades, challenging terrain including some cliff sections, and slower speed limits, They are jointly used by several oil and gas operators in the area and maintained pursuant to agreements between the various users. These road sections are discussed in several sections of the Application including the Traffic Study, the Standards Section, the Waiver Section, and a collection of road access agreements, maintenance agreements, road alignment information contained in the Access and Roadway Section of the Application. The Application includes confirmation from the operator in charge of maintenance of the roadway system (Caerus Oil and Gas LLC) that Marathon is a current licensee, entitled to use the roadway and has paid in full all billing associated with the road maintenance. TYPICAL GARDEN GULCH EXTENSION ROAD SECTION Based on the Application review and a site visit to the roadway Staff offers the following summary of issues and waivers requests, • The Garden Gulch Road is approximately 6 miles in length and deals with the steeper more challenges road sections. Garden Gulch Extension was estimated on the site visit to be approximately 7 miles in length. 11 • The roadways generally maintain a two way cross section with a significant berm on the outside of the roadway (toward the slope) and a drainage swale along the inside of the roadway (adjacent to the cut slope), In a couple of narrow sections the berm is replaced by concrete "jersey barriers" and pull-outs are common in steeper or narrower sections. • Grades are often steep and turning radius at switch backs are generally widened and extended to accommodate large vehicles. • The road surface is reflective of active and ongoing maintenance with compacted natural material or gravel. No obvious surface issues such as ponding or ruts were observed. • Extensive storm water improvements are noted along many sections of the roadway including settlement ponds, culverts, and small areas for detention. • Where additional stabilization was warranted the slopes were stabilized through concrete application (shot-crete) and/or soil anchors/bolts. GARDEN GULCH ROAD SECTION The Applicant represented that maintenance and assessment of required improvements/repairs of the roadway included (depending on the roadway section) work by professionals from the following companies: Metcalf Excavation, Rock Solid, Moody Construction, and Olsson and Associates in regard to storm water inspections. The Application includes in the Standards Section the representation that the Roadway provides a safe access to the site for the Applicant. The section was prepared by Olsson and Associates consultants for the Applicant and does not appear to contain an engineer's opinion/assessment. 12 In order to approve the Application waivers from the Roadway Standards (contained in Section 7-107) need to be approved for the Garden Gulch and Garden Gulch Extension Roadway sections. The Staff assessment is that waivers from standards in Table 7-107 are needed as follows including evaluation by a qualified engineer: • Minimum ROW Width: Applicant needs to confirm minimum easement width. • Lane Width: Most sections appear to meet standards. • Shoulder Width: Vanes • Ditch Width: Varies. often replaced with berm cross-section. • Cross Slope: Road is typically graded toward the inside/cut slope. • Shoulder Slope: Varies • Minimum Turn Radius: Need additional information to confirm compliance. • Maximum Grade: General representation that grades exceed 12% The Traffic Study identifies the minimal amount of traffic associated with the proposed use and no additional improvements are recommended by the Study. 7-108: Natural Hazards The Application provides significant information on natural hazards including information on soils, landslides, rock fall, detailed geology, and slopes. The detailed information and geotechnical study 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 Grand Valley Fire Protection District with no comment received. Input from the Fire District should be obtained to address the adequacy of the access for emergency vehicles. 7-201. Agricultural Lands With no new disturbed areas and with fencing for the water impoundment no impacts on cattle grazing which occurs in the area are anticipated. 7-2Q2: Wildlife Habitat Areas The Applicant has provided a wildlife habitat study completed by WestWater Engineering (WWE), dated November 2012. The Study indicates that several threatened, endangered, or species of concerns have potential to be found in the project area including the Greater Sage Grouse. The other species include the Northern Pocket Gopher, big Eared Bat, and several fish species in the Colorado River. The nearest raptor nesting is located approximately 1,500 ft. from the site. Habitat mapping from the Garfield County Greater Sage Grouse Conservation Plan is attached below showing the proximity of the site to priority and general habitat. The 13 WestWater Engineering study concludes that due to previous development on the site "... it is unlikely that Sage Grouse would be adversely affected by the project during the breeding or brood rearing season." Impacts on threatened or endangered species are mitigated as Marathon has in place CPW approved fencing and netting installed on the pond. Marathon also has a CPW approved Wildlife Mitigation Plan that includes specific policies for mitigation including for the Sage Grouse habitats and Leks in the vicinity of the site. Compliance with the CPW plan should be required and a copy of the plan should be provided for inclusion in the Applicant's file. APPLICANT'S SITE SOURCE: GARFIELD COUNTY GREATER SAGE -GROUSE CONSERVATION PLAN Analysis Area Boundary 220.96 4c • $LM Viands Pnotrty Habitat 31.070 ac MI USES Land; • General Habitat 28.023 Me ❑ Private Lands 2 Municipal Boundary County Boundary Interstate I'`/► State Highway 14 7-203: Protection of Water Bodies The site location is n a plateau/ridge with the nearest water feature, the Little Creek drainage north of the site. The House Log Gulch is located on the opposite (south) side of the ridge from the well pad site. The facility has an existing Spill Prevention Containment and Control (SPCC) Plan and storm water management — drainage plans which provide protection from impacts to water bodies or drainages. A copy of the SPCC Plan for the site has been provided and will need to be updated to include the water storage for the water treatment facility. The lining system and leak detection system also are designed to prevent and avoid impacts on water bodies. 7-204: Drainage and Erosion (Stormwater) The Applicant has provided a copy of the State Storm Water Management Permit and Grading and Drainage Plans for the site. The Storm. Water Permit includes seeding and hydro -mulching of slopes below the well pad above Little Creek. The effectiveness of the reseeding appears to be limited and re-application of seeding and mulch should be considered. Compliance with the grading and drainage plan should continue to be required . View of Slopes Above Little Creek North West Corner of Well Pad 7-205 Environmental Quality The Application represents that all air quality permits from the CDPHE will be obtained or are currently in place. Evaluation of existing and proposed facilities associated with 15 the Water Treatment should occur and any additional CDPHE permitting obtained consistent with the referral comments from CDPHE. 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 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 Fires. 7-207 Natural and Geologic Hazards The NRCS Soils information and the Geologic and Soils Hazard Report contain information on soil types, limitations, local geology, and geologic hazards. No significant geological hazards affecting the site were noted. Use of double liner system with additional under layers, leak detection and location on an existing bench with separation from steeper slopes mitigate potential concerns. 7-208: Reclamation The Applicant has included a reclamation plan that addresses re -vegetation and reclamation. 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. 7-304: Lighting 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 are available for snow storage. 16 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 Marathon property in a remote area with setbacks well in excess of those required. • 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 was determined to be associated with the pumps on site. The noise analysis indicates that the sound will be 51.5 dB(A) at 350 ft. from the facility. While this meets the industrial use standards the calculation of noise at the closest property line should meet the residential standards of 50 dB(A). • No other nuisance or ground vibration hazards are anticipated based on type of use, existing operation, COGCC compliance, and the remote location. VI. SUGGESTED FINDINGS FOR APPROVAL 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 the Marathon 32C Produced Water Pond 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 waivers from the roadway standards, the application has adequately met the requirements of the Garfield County Land Use and Development Code. as amended. 17 VII. RECOMMENDATION The following draft conditions are provided for the Board of County Commissioners consideration for approval of the Limited Impact Land Use Change Permit in conjunction with the suggested findings noted above. That all representations made by the Applicant in the application shall be conditions of approval, unless specifically altered by the Board of County Commissioners. That the operation of the Marathon 32C Water Impoundment 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 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 including any required for the operation of the water treatment facility shall be provided to the County upon issuance by the CDPHE. A waiver is granted from Section 7-107 Roadway Standards for the Lease Roadway section of the access roadway pursuant to the criteria contained in Section 4-118 and based on the Applicant's Lease Road Assessment and Field Observation Report. Prior to issuance of the Land Use Change Permit, the Applicant shall provide a statement by a qualified professional engineer confirming the adequacy of the Garden Gulch and Garden Gulch Extension sections of the access roadways. A waiver from Section 7-107, Roadway Standards is approved pursuant to the criteria contained in Section 4-118 and subject to compliance with the above requirements. Prior to the issuance of the Land Use Change Permit the Applicant shall provide confirmation from the Grand Valley Fire Protection District indicating that the access roadways are adequate for emergency vehicle access. The Emergency Response Plan shall also be kept updated and shall include a section on wildland fire response and mitigation. Prior to the issuance of the Land Use Change Permit the Applicant shall provide a detailed dust mitigation program for the site and access roads or copies of existing dust mitigation plans. Other Conditions The facility shall maintain compliance with CDPHE Storm Water Management Permits, Drainage and Grading Plans, Reclamation and Erosion Control Plans for the site. 18 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. The facility shall maintain compliance with COGCC Noise Standards/Regulations including a maximum decibel level of 50 dB(a), the residential standard, at the closest property line. 10. The Applicant shall comply with all SPCC Plan provisions and shall update the plan to include the water treatment facility and related storage. 11. 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. 12. The Applicant shall comply with their Noxious Weed Management Plan including best management practices and shall provide a weed inventory of the site in accordance with the Garfield County Vegetation Manager referral comments. 13. The Applicant shall document compliance with reseeding and hydro -mulching of steep slopes above the Little Creek drainage and shall reapply as appropriate in order to successfully re -vegetate and stabilize the slope in accordance with Storm Water Management Plans and Permits. 14. The Applicant shall comply with the recommendations of the WestWater Engineering consultants contained in their Wildlife and Sensitive Areas Report dated November 2012. The Applicant's shall comply with the Colorado Parks and Wildlife (CPW) referral comments and the Marathon Wildlife Mitigation Plan and Agreement with CPW including but not limited all mitigation requirements for protection of nearby Greater Sage Grouse habitat and leks. A copy of the Wildlife Mitigation Plan shall be provided for inclusion in the County files. Fencing and netting wildlife deterrents as required by CPW shall be required for the water impoundment. 15. The water impoundment and water treatment facility shall be limited to use by Marathon Oil and storage of water produced at its facilities within Marathon's Piceance Basin Operations as represented in the Application Submittals. Water shall be transported to the site primarily by pipeline as represented in the Application with trucking permitted only in emergency conditions when pipelines are not operational. 19 ADDITIONAL VIEWS OF THE SITE 20 21 ADDITONAL VIEWS OF THE ACCESS ROADS 22 2 . 24 EXHIBIT 0 � r Eve ca O ri .v .� O Tv' cti C7 16 Applicant: Marathon Oil Company NI, a -r7.1 0 0 a 0 E E V'! al cn O 0 .c ,-, c-4 bO v U'- Ct ;4ILI 1;4 o � CL) vi '44 �> �10CrS E E .- c p, '- � � 0 vct U CU "I: -70cn 0 0 co 4 u al ;-' �' cn (1)\ n 0 • E ^ K o UN N a, a - Q)--° CO ci) CU CO X > CO 0 cu u -4J' . 4 Ca-, cc2 E cn ,ID ›, o s.� c 0, a) ,- j � -7 tea) u~ O as 73 cs -� o ._ c Ca- UUvE-E(*Egl)Pngt c,1,-, Oa)21_4 cu O H up v "i i---• co 71) a) ;cT4 as 0 ;) -,-, 41) ,4 *-4 m cn cu a) 5 - - ri c 5 4 -C9 ,,,,› sc3 'cir dzi ct5-' rg Ou .-4e-r- .!.-,4 a5 0 •,-4, ‘- cz ;- (2) p_ >1') ""C:' u ;_4 0 in Ta.4 i .:::4 • r -o 4-4 (75 •x4 Op �cG� v 0� .+amu �M 0 Q-+ 'j 3 ) = ;-4 . r 2Ti 17_0, *R cc' ,t174( 0 .4_, ;. ,....,_ cu al cu .g 4;'< cnci) ez: 0 -ct.' 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CI Ze c G) oE� ° g 7J tino X Ta a 601 48 ,tea E ,tea a) �&) CU CU to U U 2. 75,E U acu 00 Cin ICL) CU 60 U4 o0$.417w 2 oU 0173z o cuv� sc4i U Q o U a 0 cu 0c-'; EL JF-: u o 73•G -U ca -tea Ute(Is' ©'�CIJ 06 l Conditions or C L.) E E 0 L) �3A Q) ; Tzs(•_ a)7.12 U (13 tU�aG.) 0 cu 61) Cs G • r4 1-,i © ;-4 O) )6„,„ „.;-.x, r. i- - 5 Q u0 u iU V Icy (13 . *g-0 11"� *.'4_,1 +a a E O 822' ti cu 0 c 0 `I o 4J 0 .0 .5 v Lb • as 073 o-+ 44 a `c.5 N; ;4 Qat • GJ .; a, a '_ cU "*5 s._ i,s • Vi- • C 07 >445 13) Ce. tit ' O 41 e cu v CCS` w 117 r I T Civil and Environmental Consulting and Design MOUNTAIN CROSS ENGINEERIING, INC. May 30, 2014 Mr. Glenn Hartman Garfield County Planning 108 8th Street, Suite 401 Glenwood Springs. CO 81601 RE: Review of Marathon 32C Produced Water Pond: LIPA-7775 Dear Glenn: EXHIBIT This office has performed a review of the documents provided for the Limited Impact Review‘ Application of the Marathon 32C Produced Water Pond. The submittal was found to be thorough and well organized. The following comments were generated: 1, The project narrative talks of additional treatment facilities that are yet to be determined. Since the extent, location, and equipment associated with these facilities is not addressed in this application, the impacts associated with them cannot be determined. The Applicant should incorporate this information into the application materials or this may require another application. 2. There are proposed ponds labeled D. E. and F on the Location Map. No review of these ponds was included as part of this application. 3. The plan sheets provided show details for the manifold pads and piping that would deliver water to and from the pond. There is no detail showing the manifolds themselves. Also, the site plan does not show the water piping being tied into the pond piping. This seems to imply that trucking water is proposed as the primary delivery method, at least for the short term. The Applicant should discuss any piping projects proposed to deliver water, timing of construction, and if trucking is to be used to fill in the gap. 4. Depending on the above. the traffic report assumes piped delivery of water to the site and not. truck delivery. The Applicant should verify that the estimated assumptions for truck trips are valid for the short and long terms of the project. Feel free to call if you have any questions or comments. Sincerely. 1l rl in Cross Est in •ening. Inc. ris Hale, PE 826 `4 Grand Avenue, Glenwood Springs, CO 81601 P: 970.945.5544 F: 970.945.5558 www.mountaincross-eng.com EXHIBIT (II; Garfield County Vegetation Management June 9, 2014 Glenn Hartmann Garfield County Community Development Department RE Marathon 32C Produced Water Pond, File # LIPA-7775 Dear Glenn, Thanks for the opportunity to comment. Noxious Weeds The noxious weed plan submitted in the application is acceptable: however a site specific inventory is not included Staff requests that the applicant conduct an on-site inventory this summer and provide the information on a map to this office by July 17, 2014. Revegetation The Reclarnation Plan and proposed seed mixes are acceptable. Staff will not recommend a revegetation security as the COGCC regulates reclamation on this 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, May 30, 2014 3:37 PM To: Glenn Hartmann Subject: Marathon Oil Company - 32 C Produced Water Pond Hi Glenn, EXHIBIT My comments for the Marathon Oil Company 32 C Produced Water Pond are as follows: - Air Quality: o The applicant appears to have obtained the proper air quality permits from CDPHE. We encourage the practices mentioned in the Nuisance Conditions section of the Impact Analysis: "Marathon evaluates their facilities on a yearly basis to determine if additional permits are required or existing permits need modification." o When possible, tanks rather than ponds are encouraged to control and reduce air emissions. - Water Quality: o The application mentions that "Water treatment facilities are currently being reviewed and are not currently in place at the facility." However, I did riot see any specific plans of the design of the water treatment plant. The applicant should notify Garfield County in the event that they are ready to move forward with planning and installation of this operation. o Liners and monitoring seem adequate to prevent seepage. General: o I noticed that in the Project Description the applicant mentions that this facility will be utilized 100% by Marathon Operations, but elsewhere in the plan there is mention of property ownership by other oil and gas companies. Are these companies also currently using the facility but would cease to do so upon approval of the application? o This seems to be a fairly substantial facility to have gone unpermitted up to this point. It sort of goes without saying, but future development should be permitted and reviewed before installation. Thank you, Morgaw Mite Environmental Health Specialist III Garfield County Public Health 195 W, 14th Street Rifle, CO 81650 Phone: (970) 665-6383 Email: mhiill@garfield-county.com www.garfield-county.com/environmental-health 1 COLORADO PARKS & WILDLIFE 6060 Broadway • Denver, CoLLorado 80216 Phone (303) 297-1192 cpw.state.co.us To: Glenn Hartmann Garfield County Community Development Department 108 8th Street, Suite 401, Glenwood Springs, CO 81601 RE: LIPA - 7775 EXHIBIT 10 Thank you for the opportunity to comment on the proposed water impoundment facility to be located 11 miles northwest of Parachute (Section 32, T5S, R96W). Colorado Parks and Wildlife (CPW) has a statutory responsibility to manage all wildlife species in Colorado; this responsibility is embraced and fulfilled through the CPW's mission to protect, preserve, enhance, and manage the wildlife of Colorado for the use, benefit, and enjoyment of the people of Colorado and its visitors. We encourage Garfield County to afford the highest protection for Colorado's wildlife species and habitats through the development and implementation of management actions combined with the use of best management practices (I3MPs) to protect wildlife and their habitats. The project location is utilized year-round by many species of game and non -game wildlife. The site lies within an area mapped by the CPW as summer range mule deer and elk and within the overall range on bear and mountain lion. Additionally, the proposed site lies within COGCC mapped Greater Sage -Grouse production habitat and about two miles from the Bear Run and House Log Gulch lek sites. Finally, there is the potential for sediment from the site to reach the Colorado River via perennial streams draining into Parachute Creek. The area at the confluence of Parachute Creek and the Colorado River is designated a critical habitat for 4 federally endangered species of native fish. In 2010, Marathon Oil Company (MOC) entered into an agreement with the Colorado Parks and Wildlife (CPW) known as the Marathon Oil Company Wildlife Mitigation Plan (MOC WMP). This document was intended to provide guidance in the development of the Marathon's natural gas resources on the Roan Plateau northwest of Parachute so that impacts to local wildlife would be minimized. In addition, MOC has agreed to extensive mitigation as specified in the WMP in an effort to offset its development on the Roan Plateau. Since the proposed site is within the boundaries of the established MOC WMP, the CPW recommends that the 2010 WMP is utilized during the planning and development of this project. The CPW's primary concern is the potential for negative impacts to Greater Sage Grouse in the area. The CPW recommends that MOC continues to utilize appropriate fencing and netting to prevent grouse from accessing the water impoundment pond. Use of netting and fencing will also prevent other animals including big -game, STATE OF COLORADO John W. Hlckenlooper, Governor • Mike King, Executive Director, Department of Natural Resources Bob D. Broschetd, Director. Colorado Parks and Wildlife Parks and Wildlife Commission: Robert W. Bray ■ Chris Castilian, Secretary • Jeanne Horne Bill Kane, Chair • Gaspar Perricone • James Pribyl • John Singletary Mark Smith, Vice -Chair • James Vigil • Dean Wingfield • Michelle Zimmerman Ex Officio Members: Mike King end John Salazar small mammals, and song birds entering the impoundment area as well. Finally, additional truck traffic can also increase disturbance to wildlife. However, by piping fluids to and from the facility as called for in the project plan, this additional disturbance can be avoided. Finally, in accordance with COGCC Rule 1204 a-1, the CPW recommends that bear - proof dumpsters and trash receptacles be utilized for alt food -related trash on location to minimize nuisance bear issues in the area. If you have any questions, please feel free to contact Scott Hoyer, District Wildlife Manager for the Parachute area at 970-250-0873. JT Romatzke Area Wildlife Manager Colorado Division of Wildlife PLL Omen Town a Pal-xcri,a4 EXHIBIT 1 it 222 Grand Valley Way Parachute, Colorado 8 1 (3 3 5 i? D 2 S - 7 6 3 0 Stuart S. McArthur, Town Administrator May 13, 2014 Garfield County Building and Planning Department ATTN: Glenn Hartmann 108 8'h Street, Suite 401 Glenwood Springs, CO 81601 SUBJECT: MARATHON 32C PRODUCED WATER POND The purpose of this letter is to respond to your Referral Form dated May 9. 2014, for File Number LIPA-7775. The Town of Parachute has no issues regarding granting this application. If you have any additional questions or concerns, please contact me at 970-285-7630. Sincerely your Stuart S. McArthur Town Administrator SSMc STATE 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 people of Colorado 4300 Cherry Creek far. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 Located in Glendale, Colorado wwwcolorado.govicdp he June 2, 2014 Glenn Hartmann Garfield County Community Development Dept. 108 8th St., Suite 401 Glenwood Springs, CO 81601 RE: Marathon 32C Produced Water Pond Dear Mr. Hartmann: Colorado Department of Public Health and Environment (i 6 2]14 On May 13, 2014, the Colorado Air Pollution Control Division (APCD) received a request for an air quality determination concerning Marathon 32C Produced Water Pond. 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.govlcdphe/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.govtcs/Satellite/CDPHE-APICBONI1251595265316. 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 UNCONTROLLED ACTUAL EMISSIONS Attainment Area 2 tons per year Non -attainment Area 1 ton per year All Areas 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 ding 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. Implementation of small government wastewater projects should be guided by the following chart to estimate VOC and HAPS emissions in order to determine if you are required under Regulation No. 3 to apply for a permit and ADEN_ Pollutant Emission Factor Lb/MM gallon Bin # VOC 3.49414 Hexamine 0.41207 C Perchloroethylene - 0.00890 A Benzene 0.22873 C Toluene 0.00267 C Total Xylene 0.00267 C Amonia 19.0000 C Contact Chip Hancock, Permit Engineer, at 303-692-3168 if you have any questions about the calculation. A permit may also be required if odors are produced from a wastewater facility in order to equip the facility with control equipment. Please refer to Air Quality Regulation No. 2 for guidance on odor suppression actions. • The current Construction Permit (Permit Number 09GA0337) only covers an impoundment and a gun barrel separator and the current GP05 permit only covers one 400BBL produced water tank. Additional equipment identified in the project description includes, condensate tank or tanks, additional produced water tank or tanks, three phase separator, and skid mounted filters. The Division requests that Marathon evaluate this additional equipment for emissions prior to commencing construction at projected processing rates. • Page 4 of 8 in the "Project Description" states, "The proposed water treatment equipment will consist of a series of skid mounted filters." if these filters are part of the treatment process at this centralized facility, the Division recommends that the skids are appropriately represented in any permit modification application. • Page 4 of 8 under "Project Description" states "It is anticipated that all equipment associated with this treatment process will be exempt from CDPHE air quality permitting due to the limited emissions it will generate."However, the land use packet does not provide an adequate engineering description to support that proposed operations will not require an Air Pollution Emissions Notice or Construction Permit. The Division requests that Marathon evaluate all emission points with projected processing rates. prior to commencing any construction of the described 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 jirn.dileo�+ustate.co.us. Thank you for contacting the Division about requirements for your project or permit. Sincerely, es A. DiLeo EPA Coordinator Air Pollution Control Division Colorado Department of Public Health and Environment Glenn Hartmann From: Franco - DNR, Ivan [wan .franco©state.co.us] Sent: Monday. June 02, 2014 10 46 AM To: Glenn Hartmann Subject: Marathon 32C Produced Water Pond LIPA7775 Mr. Hartmann, EXHIBIT /3 Thank you for the opportunity to review the above referenced referral, however the Colorado Division of Water Resources does not have any comments to offer at this time Regards. Ivan Franco, E.I.T. Water Resources Engineer P 303.866.3581 / F 303.866.2223 1313 Sherman Street, Room 818, Denver, CO 80203 ivan.franco®state.co.us / www.water.state.co.us Policy 01-14 Waivers for Roads and Demonstration of Compliance March 3, 2014 Section 7-107, Access and Roadways, of the Garfield County Land Use and Development Code (LUDC) requires all roads to be designed to provide for "adequate and safe access" and reviewed by the designated County Engineer. The LUDC defines "road" as "a County road, State highway, public road, street or alley, or private thoroughfare which affords primary access to abutting property, excluding a driveway accessing a single property." The LUDC defines "private road" as "a right-of-way constructed, established, owned, and maintained by a private party for access exclusively to private property." Many of the roads in Garfield County are private roads in that they are gated and do not serve the general public and they pre-existed the design currently required by the County's Road Standards as defined in Table 7-107. The LUDC allows for the waiver of specific standards provided that the following criteria have been met: 1) an alternative design achieves the intent of the subject standard to the same or better degree and 2) the proposed alternative will impose no greater impacts on adjacent properties than would occur through compliance with the specific standard (Section 4-118). In applications that include roads that do not meet current County road standards as outlined in Table 7- 107, the County has asked that Applicants request a waiver of Section 7-1075, Design Standards, and include in the Application submittal sufficient information, prepared by a professional qualified in the specific discipline, to demonstrate that they meet the criteria outlined in Section 4-118 for granting a waiver. In doing so, the application must include: A Statement of Adequacy - The evaluation of the existing roadway and waiver will need to include a clear statement that finds that the road will be adequate for the proposed use. This statement must be signed by a professional engineer qualified in traffic engineering and licensed by the State of Colorado. To support this evaluation, the following information will be required to be provided: Geometry of the road — A description of how the private road does/does not meet the design standards in Table 7-107. This should include a chart that compares the private road design to those standards in Table 7-107, as well as a map that shows the existing road design and highlights those areas that deviate from the standards. A narrative may also be helpful in describing the characteristics of the road as they compare to Table 7- 107 design standards. Unless available, this is not intended to imply construction -level drawings. c, Safety/Structural Issues — A description of obvious safety and/or structural issues observed and a statement about how these issues will be addressed. Maintenance — A description of how the road is and/or will be maintained. This should be supported with the submittal of any existing or proposed maintenance agreements for the road sections. Travel Demand — An accurate count of the existing peak travel demand as well as the Average Daily Traffic on the road. This should also include the types of vehicles that currently use the road as wel'I as the additional amount and type of traffic that the proposed use will generate through all phases of its development. Other Evidence of Compliance. In addition, Sections 7-107.A, 8, C, D, and E are required to be addressed, which includes documentation about legal access. Sufficient evidence will be required to be submitted to demonstrate compliance with these sections of the Code. OLSSON ot ASSOCIATES June 13, 2014 Glenn Hartmann, Senior Planner Garfield County - Community Development Department 108 81h Street, Suite 401 Glenwood Springs, CO. 81601 EXHIBIT RE: Marathon 32C LIR Application LIPA 7775 — Response to COAs Dear Glenn, The following information is a response to the Conditions of Approval generated by the Marathon 32C LIR Application staff report and recommendations. Staff Recommended Conditions of Approval 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. Response: Marathon agrees to this condition. That the operation of the Marathon 320 Water Impoundment shall be done in accordance with all applicable Federal, State and local regulations governing the operation of this type of facility. Response: Marathon agrees to this condition. 3. 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 including any required operation of the water treatment facility shall be provided to the County upon issuance by the CDPHE. Response: Marathon has supplied the approved air quality permit of the impoundment facility with the LIR application. Additional permit information for the tanks located on the site is attached to this letter. If a water treatment facility is developed and requires an air quality permit a copy of the permit will be submitted to the County. Marathon requests that the first portion of this condition is found to be satisfied and the second portion of this condition should not be required prior to the issuance of the Land Use Change Permit. 760 Horizon Drive, Suite 102 TEL 970.263.7800 Grand Junction, 00 81506 FAX 970.263.7456 www.olssonassociates.com A waiver is granted from Section 7-107 Roadway Standards for the Lease Roadway section of the access roadway pursuant to the criteria contained in Section 4-118 and based on the Applicant's Lease Road Assessment and Field Observation Report, Prior to issuance of the Land Use Change Permit, the Applicant shall provide a statement by a qualified professional engineer confirming the adequacy of the Garden Gulch and Garden Gulch Extension section of the access roadways. A waiver from Section 7-107, Roadway Standards is approved pursuant to the criteria contained in Section 4-118 and subject to compliance with the above requirements. Response.. Marathon agrees to this condition and wilt provide a statement by a qualified professional engineer confirming the adequacy of the Garden Gulch and Garden Gulch Extension section of the access roadways. 5. Prior to the issuance of the Land Use Change Permit the Applicant shall provide confirmation from the Grand Valley Fire Protection District indicating that the access roadways are adequate for emergency vehicles access. The Emergency Response Plan shall also be kept updated and shall include a section on wildland fire response and mitigation. Response: A letter from the Grand Valley Fire Protection District stating that the district is familiar the facility and has the necessary equipment to access the site is provided as an attachment to this letter. The Emergency Response Plan contains over 700 pages and addresses fire in Section Z2.7 and includes the following directives.. • Analyze the type of fire; call the local Fire Department(s) or 917 as appropriate for your area. If the fire is not beyond incipient stage, attempt to extinguish fire using appropriate equipment and methods, if trained to do so. If the fire is beyond incipient stage, evacuate and secure the area until fire department arrives. • Make sure that fire department(s) has adequate directions to the facility. Inform the fire fighters if sour gas is present. • Shut off all feeder lines into the facility/ installation. • Cut off all electrical power in area of fire. • Account for personnel who may have been in the area at the time. In the event of injury, call for medical and/or ambulance service. • Remove unauthorized personnel from the area and isolate area. Notify local law enforcement agency and request assistance, if necessary. 2 • If liquid hydrocarbons or gas are in the storage tanks or gas plant, pump or flow from the affected installation when practical. If fluid being pumped is highly flammable, check temperature and remove hydrocarbons from installation as long as possible. • If condensate or produced water is flowing or spilling on the ground, call a service company to dig earthen pond at safe distance so that product can flow and collect in the pond. Make every reasonable effort to keep flowing product out of streams, draws and drainage ditches. Activate spill containment and cleanup procedures, if applicable. • Make arrangements for continuous water supply. • Maintain a safe working distance from fire at all times. • In the event the fire curtails sales or deliveries the Asset Team leader, and/or his designee will notify the purchaser. In addition to the EFT, Marathon has supplied a Fire Protection and Response Plan Appendix which is attached. Marathon requests that this information satisfies this condition and remove it from the recommendations. 6. Prior to the issuance of the Land Use Change Permit the Applicant shall provide a detailed dust mitigation program for the site and access road or copies of existing dust mitigation plans. Marathon complies with numerous COGCC rules addressing dust control including Rule a05. c.. Fugitive dust. Operators shall employ practices for control of fugitive dust caused by their operations. Such practices shall include but are not limited to the use of speed restrictions, regular road maintenance, restriction of construction activity during high - wind days, and silica dust controls when handling sand used in hydraulic fracturing operations. Additional management practices such as road surfacing, wind breaks and barriers, or automation of wells to reduce truck traffic may also be required if technologically feasible and economically reasonable to minimize fugitive dust emissions Marathon's primary dust control method is the application of water to the roads accessing the facility as needed to control dust, which is contingent on traffic volume and weather patterns. The most effective means of dust control is to utilize existing water infrastructure to pump produced water to the 32C facility, in an effort to minimize truck traffic. 3 The Garden Gulch Road and Garden Gulch Road Extension are maintained by third - party contractors through the roadway managing partner, Caerus Oil and Gas. The maintenance contracts for these roads dictate dust control schedules on these roads. A copy of the maintenance portion of these contracts is attached to this Letter. Marathon requests that this information satisfies this condition and remove it as a recommendation. 7. The facility shall maintain compliance with CDPHE Storm Water Management Permits, Drainage and Grading Plans, Reclamation and Erosion Control Pians for the site. Response: Marathon agrees to this condition. 8. 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. Response: Marathon agrees to this condition. The facility shall maintain compliance with COGCC Noise Standards/Regulations including a maximum decibel level of 50 dB(a), the residential standard, at the closest property line. Response: Marathon agrees to comply with the COGCC Rule 802 Noise Abatement standards. The anticipated noise level at 350 feet from the noise source is estimated to be 51.5 dB(e) at 350 feet. The nearest property line is over 800 feet from the noise source associated with the impoundment. 10. The Applicant shall comply with all SPCC Plan provisions and shall update the plan to include the water treatment facility and related storage. Response: The water impoundment is included in the SPCC and is included in the application. Marathon will update the SPCC as required by the EPA when the water treatment facility is developed on the site. Marathon requests that the condition be modified to reflect compliance with EPA standards. 11. The facility shall maintain compliance with Section 7-306 Lighting, with all lighting to be directed inward and downward toward the interior of the site. Facilities and storage tanks shall be painted a non -glare neutral color to lessen any visual impacts. Response: Marathon agrees to this condition. 12. The Applicant shall comply with their Noxious Weed Management Plan including best management practices and shall provide a weed inventory of the site in accordance with the Garfield County Vegetation Manager referral comments. Response: Marathon has provided a weed inventory of the site and requests that this condition be removed from the recommendations. 13 The Applicant shall document compliance with reseeding and hydro -mulching of steep slopes above the Little Creek drainage and shall reapply as appropriate in order to 4 successfully re -vegetate and stabilize the slope in accordance with Storm Water Management Plans and Permits. Response: The slope in question has been reseeded and some re -vegetation has taken place. The slope consists of rock and shale and little soil. Water tends to flow off the slope and not soak in or provide benefit to any vegetation. Additional reseeding will not likely increase the amount of vegetation on this slope. Adding topsoil to the slope would likely only result in the accumulation of soil at the bottom of the slope. The slope is stabilized in the current condition and shows no sign of erosion, gullies or rills. Only two wells are drilled on the site but additional wells are planned, The pad is currently sized for the additional drilling and to accommodate the rig and additional temporary equipment that would be required. Once all the wells are drilled and completed the pad will be pulled in and the slope will be reduced and re -vegetated. Marathon requests that this condition be removed as a recommendation. 14. The Applicant shall comply with the recommendations of the WestWater Engineering consultants contained in their Wildlife and Sensitive Areas Report dated November 2012. The Applicant shall comply with the Colorado Parks and Wildlife (CPW) referral comments and the Mitigation Plan and Agreement with CPW including but not limited to mitigation requirements for protection of nearby Greater Sage Grouse habitat and leks. A copy of the Wildlife Mitigation Plan shall be provided for inclusion in the County files. Fencing and netting wildlife deterrents as required by CPW shall be required for the water impoundment. Response: Marathon will comply with the recommendations of the WestWater report, CPW referral comments and will provide the fencing and netting deterrents around the impoundment. In lieu of the Wildlife Mitigation Plan (WMP) Marathon will supply an audit of that plan. This audit was performed by a third party and was provided to the CPW to demonstrate compliance with the WMP and is supplied as an attachment to this letter. Marathon requests that this condition be modified to substitute WMP audit for the actual WMP. 15. The water impoundment and water treatment facility shall be limited to use by Marathon Oil and storage of water produces at its facilities within Marathon's Piceance Basin Operations as represented in the Application Submittals. Water shall be transported to the site by pipeline as represented in the Application with trucking permitted only in emergency conditions when pipelines are not operational. Response: Marathon agrees to the first portion of this condition. Marathon requests that the second portion of this recommendation be struck or amended to correspond with the application and allow truck transport of water as represented in the traffic analysis and Response to NTC Letter. It is Marathon's preference to transport water whenever possible via a pipeline to reduce overall costs and impact to roads. However that may not always be practical even during non -emergency operating conditions. 5 Thank you for the opportunity to respond to these recommended conditions. Please contact me if you have any questions. Sincerely,lit Jeff Hofman Attachments 1. Produced Water Tank GPM General Permit Approval for Application Package #250245 2. Letter from Grand Valley Fire Protection District 3. Marathon Fire 'Protection and Response Plan Appendix 4. Road Maintenance Contract 5. Weed Inventory Memo and Map 6. Wildlife Mitigation Plan Audit 6 Attachment 1 Produced Water Tank GP05 General Permit Approval for Application Package #250245 STATE OF COLORADO .; IIF;••• ,'SI YI'111.4 ',r hry I rt 1 11,1:to. 1.111 421111 • ..r•12.r 1w1 CI".+r :� f:l1-•I'i +I I,1 „•1'11 "' .] 1.1 141l..14 I•721.1%.A 11+ •'-.I" 1"•1"• 1 nl IN.. j 4.•1/ r+.1"-,"•1 MI111:1 t1 rr,r.•. I1 i :1F1`faw /1'41.•pl""Prr:'tf !til I1• v f1 r•r•4 t:r.r.11►1 ..+00. : III I f ••F er. 0:4,1. M tcI127.2(113 1 . .. tel.•.,. •1(901 t.va•4 11414 rw' •.1-r,,,Itlff. 4rr1" Melissa. Velasquez Marathon Oil Co 743 Horizon Court Suite 220 Grand Junction, Co 81506 . Y. IV,� • 1111• . s111u.atulhp.asllrsnl ul N111+1111 1111111( ,loll! 1 I ir,IIIIIiclll RE: Produced Water Tank GP05 General Permit Approval for Application Package #250245 Dear Melissa Velasquez. The Colorado Air Pollution Control Division approves registration of the produced water tank batteries listed in the table below for coverage under general permit GP05 Please refer to general permit GP05 for all applicable requirements, limitations, terms and conditions. A copy of the general permit, as well as guidance documenls for oil and gas industry produced water tank batteries, may be obtained via the Internet at the following web address I1{Ill lhnhvw c riphu mak, t't1 4 isflail/ 1IIL kr(.(i(i(:(: hitnl Sources approved for General Permit GPO5 Coverage AIRS ID Battery/Plant Name 1Losation Synthetic Site Specific Mirror 7 EF Submitted? :►45 1741 41+? 140; 37C t'Ou !SW SEC 32 TSS R96W No No Applsca ion Package *250245 Page 1 nt 2 The synthetic minor and site-specific emission factor status columns are provided for informational purposes and are based on the best available data provided by the applicant at the time of submittal. Please note; ttre a responsible affect this status and to take appropriate steps to notify the Divs on of these changeshai may If the synthetic minor status column is marked -Yes', the operator is expected to comply with all requirements, including those specific to synthetic minor sources, Contained in the general permit if you have any questions regarding this letter, please contact me directly at (303) 692-3257_ Sincerely, David Daboll, PE Environmental Engineer Stationary Sources Program Air Pollution Control Division '}ppticahoii f`arr;� r_ 1;250' Page 2of2 STATE QF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 GENERAL CONSTRUCTION PERMIT 011 and Gas industry Produced Water Storage Tank Batteries PERMIT NO: GPOS Version 2 FINAL APPROVAL May 15, 2013 Roland C. Hee. P.E. Date Issued Permitting Section Supervisor 1. General Permit Applicability IA Qualified Sources The owner or operator of any all and gas industry (exploration and production (E&P), non -E&P, midstream and downstream) operation that can comply with al of the operating conditions described in Section II of this permit and meet all of the requirements in this Section may register for this general permit. This general permit covers the tollowing: 1.A.1. Produced water storage tank batteries comprised of a single storage tank or a group of storage tanks used for the storage of produced water. I.A.2. Combustion devices, vapor recovery units, or other Division approved control equipment used to reduce emissions by at least 95%. 1.A.3. Equipment as described in condition I.A,1 and 1.A.2 located at a true minor source or synthetic minor source for Operating Permit (OP), New Source Review (NSR), and Maximum Achievable Control Technology (MALT) program applicabil ly I.B. Excluded Sources: The following sources may not register for this general permit 1.13.1. Equipment located ata major source as defined in Regulation No. 3, Part A, Section 1.6.25. I.B.2. Equipment subject to a New Source Performance Standard (NSPS) other than NSPS Subpart 0000 - Standards of Performance for Crude Oil and Natural Gas Production. Transmission and Distribution. 1.113. This general permit applies only to the equipment as described in Section I A above. Other equipment at the same stationary source must be permitted separately as required by Regulation No 3, Part B. OIL AND GAS INDUSTRY PRODUCED WATER STORAGE TANK BATTERY GENERAL PERMIT Page 1 of 6 Permit Number GP05 Version 2 Colorado Department of Public Health and Environment Final Approval — May 15, 2013 Air Pollution Control Division II. Operating Terms and Conditions U.A. Emission Limitations II.A.1. Combined actual controlled emissions of criteria air pollutants from all produced water tank batteries that are owned or operated by the same person and co -located at a common well pad shall not exceed the following limitation: (Reference: Regulation No. 3. Part B, Section II.A.4.) Volatile Organic Compounds: 10.0 tons per year II.A.2. Combined actual controlled emissions of hazardous air pollutant(s) (HAPS) from all equipment at the same stationary source shall not exceed the following limitations: (Reference Regulation No. 3. Part B, Section II.A.4.) Each Individual HAP: 8.0 tons per year Total of all HAPs: 20.0 Ions per year II.A.3. A control device may be used to comply with these emission limits, 11.B. General Operating Conditions 11.13.1. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) II.B 2. The AIRS number (ex. 123/12341001) shall be marked on the subject equipment for ease of identification. (Reference: Regulation No 3, Part B, Section III.E.) (State only enforceable) II.B.3. The permittee must follow the Operating and Maintenance 1 Recordkeeping plans specified in Sections IV and V (Reference: Regulation No. 3, Part B, Section 111.1.6.) 11.B.4. This source's produced water throughput shall be limited by the emission limits specified in this permit, arid all other activities, operational parameters and numbers of equipment as stated in the registration. (Reference: Regulation No 3, Part B. Section II A.4 ) 111. Alternative Operating Scenario (AOS) III.A. Provided that the emission limits set forth in Section II.A are still met, the permittee may invoke an AOS for the following modifications to an existing tank battery registered under the general permit without modifying the general permit registration: Increase in throughput resulting in a facility classification change from true minor to synthetic minor, addition or replacement of a control device: addition of a tank: or relocation of a tank battery within the same quarter -quarter section, township, and range, III.B. The permittee shall maintain a log to contemporaneously record the date and description of any modification made under the provisions of this AOS. (Reference: Regulation No. 3, Part A, Section IV.A.1.) If exercising the APS, a revised APEN should be submitted by April 30th of the year following the modification(s). The revised APEN shall be accompanied by the appropriate APEN filing fee and a cover tetter detailing all such AOS modifications that occurred within the previous calendar year. OIL AND GAS INDUSTRY PRODUCED WATER STORAGE TANKS BATTERY GENERAL PERMIT Page 2 of 6 Permit Number GPOS Version 2 Cotorado Department of Public Health and Environment Final Approval -- May 15. 2013 Air Pollution Control Division IIID. The following changes are not considered modifications and are not subject to Condition III.0 provided that none of the modifications listed in Condition (IIA occurred within the same calendar year. These changes should be reflected in any revised APEN required by Condition VI A.1. Changes in throughput not resulting in a facility classification change, removal of a well serviced by the battery: repiping of an existing well; addition of a new well to the battery; or removal of a separator or tank. IV. Operatinft and Maintenance Plan IV.A. Flares shall be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare, or by other convenient means approved by the Division, determine whether the flare is operating properly. IV.B. If a control device is used to comply with the emission limits of this permit the following conditions must be met: v. V.A. IV.B.1. Leakage of VOCs to the atmosphere must be minimized as follows; IV.B.1.a. Thief hatch seals shall be inspected for integrity annually and replaced as necessary. Thief hatch covers shall be weighted and properly seated IV_B.1.b Pressure relief valves (PRV) shall be inspected for proper operation annually and replaced as necessary. PRVs shall be set to release at a pressure that will ensure flashing, working and breathing losses are routed to the control device under normal operating conditions. IV.B.f.c. Annual inspections of thief hatches and PRV shall be documented with an indication of status, a description of any problems found, and their resolution. IV.B.2. Control devices shall be adequately designed, and operated and maintained according to manufacturer specifications to achieve a control efficiency of at least 95%, and to handle reasonably foreseeable fluctuations in emissions of VOCs. Fluctuations in emissions that occur when the separator dumps into the tank are reasonably foreseeable. IV B.3. All produced water collection, storage, processing and handling operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds 10 the atmosphere to the maximum extent practicable IV.B.4. The permittee shall monitor and document the proper operation of the control device. Time intervals between monitoring shall not exceed 14 days. Indications of improper operation for a flare include, but are not limited to, absence of pilot light. malfunction of electronic ignition, and/or presence of smoke. A check box is suitable for recording proper operation Improper operation of a control device shall be further documented with a description of the problem and its resolution, the date range the control was inoperable, and the produced water production through the battery during the downtime. During control device downtime, emissions shall be considered to be uncontrolled. IV.B.5. Operating and Maintenance plans for alternative control equipment may be proposed to the Division for approval on a case-by-case basis. Recordkeepinq Plan Records may be kept in either electronic format or hard copy provided that they can be promptly supplied to the Division upon its request All records shall be retained for a period of three years. OIL AND GAS INDUSTRY PRODUCED WATER STORAGE TANK BATTERY GENERAL PERMIT Page 3 of 6 Permit Number GP45 Version 2 Colorado Department of Public Health and Environment. Final Approval — May 15, 2013 Air Pollution Control Division V.B. For all tank batteries, the following records shall be maintained on site or at a local field office with site responsibility for Division review: V.B.1. The current version of this general construction permit. V.B.2. The most recently submitted APEN and any required site-specific emission factor documentation V.B.3. The general permit registration approval letter. V.B.4. Records that clearly demonstrate compliance with the emission limits of this permit. This shall include the most currently available produced water production records necessary to calculate emissions in accordance with this Condition V.B.4 and documentation of all periods of control device downtime. V.B 4.a. For sources located at a true minor facility. compliance with the emission limits in Section II.A shall be determined by calculating the annual emissions from each emission unit for the calendar year, V.B.4.b. For sources located at a synthetic minor facility, compliance with the emission limits in Section ILA shalt be determined by recording the annual emissions from each emission unit on a rotting (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. During the first year of operation, compliance shall be assumed providing that cumulative emissions from all months of operation do not exceed the emission limits in Section ILA. V.B.5 Records required by Conditions Ill.t3 (AOS), IV.B.1.c (Annual tank inspections) and IV. B.4 (Control device monitoring). VI. General Permit Terms and Administration VI A. General Terms VI.A.1. A revised APEN shalt be filed. (Reference. Regulation No. 3, Part A, Section II.C.) VI.A.1.a. Annually by April 301' of the year following a significant increase in emissions as follows:: Vt.A.1.a.(i) For VOC, a change in actual emissions of live (5) tons per year or more, above the level reported on the last APEN; or VI.A.1.a (ii) For any non -criteria reportable pollutant, if the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN. VIA 1.h. Whenever there is a change in the owner or operator of any facility. process, or activity, or VI.A.1.c. As required by the alternative operating scenario allowed by Section NII. VI.A.1.d. No later than 30 days before the existing APEN expires. VI.A.2. Prevention of Significant Deterioration (PSD) requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition, Any relaxation that increases the potential to emit above the applicable PSD threshold and will require a full PSD review of the source as though construction had not yet commenced on the source. The source shall not exceed the PSD threshold until a PSD permit is granted. (Reference: Regulation No. 3, Part 0, Section VI.B.4 ) VI A.3. Sources covered by this General Permit are subject to the Common Provisions Regulation Pari II, Subpart E, Upset Conditions and Breakdowns. The permittee shall notify the Division of any OIL AND GAS INDUSTRY PRODUCED WATER STORAGE TANK BATTERY GENERAL PERMIT Page 4 of 6 Permit Number GPOS Version 2 Colorado Department of Public Health and Environment Final Approval — May 15, 2013 Air Pollution Control Division upset condition which causes a violation of any emission limit OF limits stated in this permit as soon as possible, but no later than two (2) hours atter the start of the next working day, followed by written notice to the Division explaining the cause of the occurrence and that proper action has been or is being taken to correct the conditions causing said violation and to prevent such excess emission in the future VI.A.4. This pen -nil is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention And Control Act C.R.S. (25-7-101 et seq), to those general and specific terms and conditions included in this document. Ui.A.5. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the Division to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. VI A.6. Each and every condition of this permit is a material part hereof and is not severable Any challenge to or appeal of, a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab iniio. VI.A.7. Section 25-7-114.7(2)(a), C.R S. requires that all sources required to file art Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. VI A.8. Violation al the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AOCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement). -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. VI.A.9. Registration under this permit is approved in reliance upon the accuracy and completeness of information supplied by the applicant and is conditioned upon operation of the source, in accordance with this information and with representations made by the applicant or applicant's agents. It is valid only for the equipment and operations or activity specifically identified on the general permit registration. VI.B. VI B.1. Registration Revision 1 Termination The Division may deny or revoke registration under the general permit under the circumstances specified in Regulation No. 3. Part B, Section 111.1 3.c. VI.B 2. A registration under this general permit may be reissued to a new owner by the Division as provided in Regulation No. 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fees. VI.B.3. Registration under this general permit is voluntary. The permittee may withdraw or cancel a registration under this general permit at any time by notifying the Division in writing General Permit Revision / Termination This general permit remains in effect until revised or terminated by the Division in accordance with the provisions of Regulation No 3. VI C. Vl.C.1. VI.C.2. After public notice and comment as provided by Regulation No_ 3, Part B, Section 1111.7., the Division may revise this general permit in order to add or delete requirements or limitations to the permit. This public notice shall be conducted in a manner consistent with the provisions of Regulation No. 3, Part B. Section VI C.3. If a revised general permit is issued by the Division, any existing registration to use the general permit will be automatically converted to a registration to use the revised general permit, provided OIL AND GAS INDUSTRY PRODUCED WATER STORAGE TANK BATTERY GENERAL PERMIT Page 5 of 6 Permit Number GP05 Version 2 Colorado Department of Public Health and Environment Final Approval — May 15, 2013 Air Pollution Control Division that the permittee continues to meet all requirements of the revised general permit. Persons not wishing to continue coverage under the revised general permit shall have the option of applying for an individual permit as required by Regulation No. 3, Part B. VI.0 4. If the Division terminates this general permit, it will provide written notice to affected registrants prior to the termination of the general permit. The notice will advise registrants that they must apply for an individual permit as required by Regulation No. 3. Part B. VI.D. General Permit Registration Approval Process VI 01, Conditional certification of a registration under this general permit is effective from the date the complete registration request is received by the Division. A complete registration request consists of all General Permit application materials required by the Division. The owner or operator may commence construction and operation of the storage tank(s) as represented in the registration upon receipt of the completed registration request by the Division. In the event the storage tank(s) does not qualify for registration under the general permit the owner or operator accepts the liability of commencing these activities, VI.D.2. The Division will determine completeness of the General Permit registration request within thirty (30) days of the date of receipt of the request and provide written notification to the applicant. If the applicant does not receive notification of a completeness determination from the Division within thirty (30) days, the General Permit registration request shall be deemed complete for the purpose of Condition Vt.D.1 VI.D.3 The Division has ninety (90) calendar days from the date the Division receives a complete General Permit registration request to provide the applicant with a written approval or denial of the registration VII. Colorado Oil and Gas Conservation Commission Requirements VII A This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(B). VIII. Additional Requirements VIIIA. Produced water storage tanks subject to 40 CFR Part 60, Subpart 0000 - Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution shall comply with all applicable requirements of that subpart including, but not limited to, emissions standards, testing, notification, monitoring, records and reporting. VIII.B The permittee shall maintain documentation clearly outlining applicable requirements of New Source Performance Standard (HSPS) Subpart 0000 for the produced water storage tank battery registered under this general permit. The documentation shall be Located onsite or al a local field office with stationary source responsibility. Records may be kept in either electronic or hard copy format provided that they can be promptly supplied to the APCD upon request. Permit History Date Issued Notes September 28, 2009 Final Approval Version 1 May 15, 2013 Final Approval Version 2 OIL AND GAS INDUSTRY PRODUCED WATER STORAGE TANK BATTERY GENERAL PERMIT Page 6 of 6 Attachment 2 Letter from Grand Valley Fire Protection District GRAND VALLEY FIRE PROTECTION DISTRICT 0124 STONE QUARRY RD PARACHUTE, CO 81635 PHONE: 285-9119, FAX (970) 285.9748 41 - December 18, 2012 Zach Toellner Marathon Oil Company 970-244-5743 Re: Emergency Access — marathon's 596-32C Pond. Mr. Toellner; This letter is to clarify the access to the 596-32C pond area. We do have the necessary equipment needed to access this property and around all pond. The 25 foot wide road is assessable by our brush units and the 10 to 12 feet is ok for a buffer zone. This project is within our response district and 1 am very knowledge about the project area. All of our brush units, tenders and one stnictiue type engine are all four wheel drive or all wheel drive. I also have the site plan and proposed changes to the location and I do not have any objections with this project. The 569-32C pond area is protected on the two sides with high vertical dirt areas there is no need for a buffer zone at these points. Our Fire District is complemented with all necessary equipment for this location as well as certified personnel to handle the incident if/when it arises. If you should have any further questions please feel free to contact me at the number in the letterhead. It was nice working with you this morning about this project and look forward to working together on future projects. Sincerely. Rob Fergrr os�n }� Deputy Fire Chief -- Operations GVFPD Attachment 3 Marathon Fire Protection and Response Plan Appendix WILLIAMS FIRE & HAZARD CONTROL Marathon Fire Protection and Response Plan Appendix iftivhf Marathon Oi ■MILLIAMS Pilo r.umm�ocrPn UP We wish to underscore that the following recommendations are not based on empirical engineering analysis of Marathon's capacity and facilities but draws on William's comprehensive experience (32 years of corporate history) in combating the exact emergencies anticipated for the Marathon facilities. The commentary offered is done in good faith with the welfare of Marathon's fire fighters, the most vulnerable of Marathon's employees, and the prevention of significant losses to Marathon's investors as the core purpose of these recommendations. Introduction: Purpose This Fire Prevention and Response Appendix is designed to provide Marathon Oil field operations the basic outline for preventing and responding to wildfire, tank battery, pressure system, operating equipment and other fire related emergencies that could impact local operations. This guide is intended to be an appendix for the main emergency response plan and is designed as a set of guidelines to assist local operations in coordinating a fire fighting response in coordination with local or area fire departments and specialized industrial fire fighting resources. Marathon Oil personnel are trained to respond to fires that are in the incipient stage only and will manage larger fire incident response using the Incident Command System as outlined in the main body of the Area Emergency Response Plan. The main goal of this guide is to protect the public, the responders and the environment. Objectives The primary objective of this Appendix is to establish a standard, basic response process for handling wildfire, tank battery, pressure system, and mobile equipment fire related emergencies. This appendix was created with the assumption that the emergency has already progressed through the incipient phase. This will include identifying responsibilities for the following: 1) Protect the personnel at the site in case of a fire emergency. 2) Define the notification Protocols. 3) Prevent as much environmental and facility damage that can safely and adequately be saved while additional personnel and equipment are being mobilized. 4) Define the information that is required in order to determine the appropriate response levels and strategies. 5) Organize personnel and provide guidelines for their role in the emergency and incident management. 6) Source and pre -plan for personnel and equipment required to handle a fire emergency. 7) Proper training in the control and management of fire emergencies. This Appendix is not intended to replace sound judgment. Modification of the mobilization plan and intervention strategy might be necessary depending on the circumstances of the emergency. Fire emergencies require common sense and professional judgment on the part of the person or persons in charge of operations, and no operation should be undertaken if it involves unreasonable risk to personnel. information is essential to implement an effective fire control management system. Recommendations are included for the information to be gathered both at the facility and from office records. Incident Command System Structure Marathon Oil Corporation has adopted the National Incident Management System (NIMS) ICS organization as outlined in: Homeland Security Presidential Directive Five (HSPD-5) National Response Framework, January 2008 All Federal, State, tribal, and local levels of government, as well as many private sector and non-governmental organizations use ICS for a broad spectrum of emergencies. These range from small to complex incidents, both natural and manmade, and include acts of catastrophic terrorism. The Company has adopted the NIMS ICS to allow the partnership of Unified Command to be developed when required in training, exercises or responses.. Note: The document, FEMA 501, National Incident Management System was referenced in the development of this document. This appendix is specifically designed for major events, as defined by the Marathon levels of response standards. The following charts shows examples of Marathon Oil organizational arrangement of responsibility and management in the event of an emergency. The responsibilities indicated on the charts are not necessarily to be filled by one person each. In some events, due to personnel availability, some personnel will have to fill multiple roles. Incident Command Structure Operations Branch Williams Fire and Hazard Control Fire Operations Chief Rescue Operations Chief Water Supply Chief Foam Operations Chief Suppresion Chief EMS Branch Triage Treatment Transport Logistics Branch Staging Area Chief Law Enforcement Branch Evacuation Perimeter Security Finance Operations Branch The Operations Branch comprises Company and/or contract personnel on a 24-hour callout who have the experience to deal with fire control related emergencies. It will also have additional vendor support personnel to assist in the emergency. Primary Objectives of the Operations Branch 1. Have specific members of the staff immediately available in the event of an incident. 2. Help plan and implement the fire control plan. 3. Liaise between facility corporate management and unified command. 4. Liaise between facility management and 3`' party responders. 5. Establish on-site operations, communications, and medical facilities. 6. Operations Branch has command over all company related response assets. Fire Operations Branch The FOB comprises Company, Local Fire 1" Responders, and/or- contract personnel on a 24-hour callout who have the experience to deal with fire control related emergencies. It will also have additional vendor support personnel to assist in the emergency. Objectives of the Fire Operations Chief 1. Secure the incident site and determine status of all personnel. 2. Make initial assessment of emergency situation. 3. Provide notification to the Company 4. Activate/establish air monitoring. 5. Mobilize locally available equipment and services. 6. Determine equipment and services required for operations and safety. 7. Provide regular updates to the Company. 8. Establish and implement the fire emergency control plan. Objectives of the Rescue Operations Chief 1. Secure the incident site and determine status of all personnel. 2. Technical. Rescue 3. Patient(s) recovery. 4. Coordinate with EMS branch for treatment. Objectives of the Water Supply Chief 1. Determine water sources adequate for supply. 2. Determine water source access. 3. Activate water shuttling and/or relay pumping as necessary. 4. Coordinate with Foam Operations and Suppression branches to ensure adequate supplies and provided. Objectives of the Foam Operations Chief 1. Coordinate foam placement and foam system setup. 2. Determine foarn requirement 3. Setup and operate foam proportioning system 4. Provide foam as required for firefighting operations 5. Access future needs and coordinate replacement foam. Objectives of the Suppression Chief 1. Secure the incident site. 2. Make assessment of emergency situation. 3. Provide notification to the Operations Chief 4. Activate/establish cooling water on exposures. 5. Attempt with lease amount of danger possible, fire containment. 6. If resources and personnel are available and capable, extinguish the fire. EMS Branch The EMSB comprises Local EMT 1''` Responders, and/or contract personnel on a 24-hour callout who have the experience to deal with health related emergencies. Responsibilities include triage, treatment, and transportation of patient(s) from the site. Objectives of the EMS Branch 1. Coordinate triage, treatment, and transportation operations. 2. Provide notification to the Company Objectives of the Triage Branch 1. Recover patient(s) from rescue branch and stabilize for treatment. Objectives of the Treatment Branch 1. Determine severity of injury 2. Treat as required to stabilize. 3. Immobilize patient(s) for transport Objectives of the Transport Branch 1. Coordinate transport for patient(s) as required. Logistics Branch The LB comprises Company and/or contract personnel on a 24-hour callout who have the experience to deal with emergency logistics and shipping. The logistics branch will also have additional vendor support personnel to assist in the emergency. Objectives of the Logistics Branch 1. Coordinate with the finance and operations branches to establish needs. 2. Make initial assessment of on hand equipment and storage spaces. 3. Provide notification to the Company 4. Establish staging area. 5. Per operations, prepare site to receive equipment and supplies. 6. Coordinate with other branches to establish priority for site access. 7. Coordinate with other branches to assure safety in the Iaydown areas. 8. Provide regular updates to the Company. 9. Establish and implement the fire emergency control plan. Objectives of the Staging Area Coordinator 1. Ensure all supplies and equipment are stored in an easily accessible manner 2. Ensure all equipment is staged by need and priority 3. Ensure all equipment and supplies are available for operations on request. Law Enforcement Branch The LEB comprises Local Law Enforcement 1S1 Responders, and/or contract personnel on a 24-hour callout who have the experience to deal with emergencies. The law enforcement branch will also have additional' vendor support personnel to assist in the emergency. Objectives of the Law Enforcement Branch 1. Establish and secure rally points for evacuees 2. Assist with accountability 3. Coordinate with operations for hot zone and site access control. 4. Coordinate with operations to establish perimeter access guidelines. 5. Coordinate with operations on escalation to assist with the establishment of safe and effective traffic control. Objectives of the Evacuation Team 1. Rally all evacuating personnel to a central location for accountability 2. Keep non-essential personnel from re-entering the site. 3. Assist with initial site traffic safety. Objectives of the Perimeter Security Team 1. Prevent any non-essential personnel from entering the site. Objectives of the Traffic Control Team 1. Maintain traffic control to ensure personnel safety when entering and leaving the emergency area. Finance Branch The FB comprises Company and/or contract personnel on a 24-hour caliout who have the experience to deal with emergencies. The finance branch will also have additional vendor support personnel to assist in the emergency. 1. Procurement of services and/or supplies as designated by operations. 2. Coordinate with logistics 3. Document all financial costs of the incident. 4.Obtain any and all needed incident records for potential cost recovery efforts. General Activities and Practices Laydown/Staging area Special consideration should be given to account for staging and laydown during the initial phases of lease construction. The design of a road (including the turning radius of corners and access onto the lease) should be considered in the overall design of the access to a lease during the scout or survey phase. Care must be taken to ensure that the spacing of well -servicing equipment allows easy egress for personnel involved in the well -servicing procedures, and adequate access for fire fighting teams. The following criteria should determine the positioning fire fighting equipment: a. Direction of the wind in relation to the HOT ZONE and Facility Equipment should be a minimum distance of 25m from any fuel source b. Fire fighting equipment must be positioned so as to avoid any spillage of well- service fluid on the firefighting equipment, should a rupture occur, and should not be located directly in line of any plugs, valves, or other components of the pressurized system. c. Level and/or grade must be considered when positioning equipment. Due to the large volumes of water necessary, flowing liquids can become a hazard and compromise personnel life safety. Housekeeping Sites must follow all Marathon HES&S guidelines as they pertain to onsite safety and housekeeping. Hot work Sites must follow all Marathon HES&S guidelines and standards as they pertain to hot work. Inspections and Maintenance Sites must follow all Marathon HES&S guidelines and those of specific equipment manufacturers for the inspection and maintenance of all equipment prior to use. Basic Information for Firefighting Operations There are certain pieces of information that are general and apply to all types of hazards that should be established. Once the source is identified as spill/fuel in depth or three- dimensional pressure fed liquid and/or gas fire, you can determine the type of response. Water/Foam Supplies for Spill Fires or Fuels in Depth Foam Type to be used: AFFF- Class B Fires for Hydrocarbons only, they will not be effective on Polar -Solvents (Alcohols) AR-AFFF- Class B fires an Polar Solvents (ethanol, alcohol, etc.) AND Hydrocarbons (Gasoline, Diesel, etc.) Determining Foam percentage: On all manufacturer labels for foam products, the label will indicate the percentage at which the foam is to be proportioned. In the event that the label indicates two percentages, the left number is for Hydrocarbons and the Right number is for Polar Solvents. EXAMPLE: This label indicates 1% for Hydrocarbons, and 3% for Polar Solvents EXAMPLE (cont.) These pails indicated that this foam is to be proportioned at the indicated percentage regardless of fuel burning. 1 %pr roffwiqbwq ihll14174J4F►D 6%AFFF % izr Spill Fires (Depth Tess than one inch) if the event is a spill/pooi fire, the foam should be proportioned at the indicated percentages and applied to the surface of the fire using "bounce off" or "rain down" techniques. Depending on the size of the spill the water/foam application may need to be increased from handheld nozzles to master streams on monitors. Fuels in depth of greater than one inch NFPA 11 states that to properly extinguish fuels in depth greater than one -inch firefighting foam should be applied at an application rate of .16 gallons per square foot regardless of tanks size. Williams Fire and Hazard Control have found through experience that the application needs to be increased as tank diameters increases. The larger streams required for larger tanks cause more disruption of the fuel surface and degradation of the foam quality, increasing the application rates counteract this effect. WF&HC APPLICATION RATES Tank Diameter 0-1SO feet Limin.m7 6.52 Gpm.ft2 0.16 151-200 feet 7.3 0.18 201-2.50 feet 8.1 0.2 251-300 feet 9 0.22 300+ feet 10.4 0.26 The first thing you need to account for is the required flow to achieve the required application rate: Tank Flow Rate Calculations Units (Imperial): GPM/ScFt — Ft — SgFt - GPM Units (Metric): LPM/SgM _ M -- SqM - LPM Application Rate = *see above chart* Tank Radius = Tank Diameter / 2 Tank Area = (Tank Radius " 2) * 3.14 Total Flow Rate = Application Rate * Tank Area Example: 20' diameter tank Tank Radius = 20 / 2 = 10 Tank Area = (10"2) * 3,14 = 3145gFt Total Flow Rate = 0.16 * 314 = 50.24 GPM This means that in order to effectively extinguish a 20 -foot storage tank, you must be able to flow foam and water solution at 50.24 Gallons/Minute. Once you have established the required flow, your can calculate the required foam. NFPA 11 dictates the application length for different fuel types, APPLICATION DURATION • er NFPA 11. Product Duration 65 Combustible Liquid (flash point <38°C) Flammable Liquid (flash point >38°C) 65 Crude Oil 65 Alcohols 65 This time is used to calculate total water and foam required for extinguishment. Example: 50.24 Gallons per Minute X 65 minutes = 3,265.6 gallons. Onsite, prior to attempting extinguishment, you should have 3265.6 gallons of water. Foam Requirements: 1%=.01 3%=.03 Multiply Gallons per minute X Foam Percentage X 65 Minutes Example: Using 1% Foam 50.24 Gallons per minute X .01(For 1% Foam) = .5024 gallons per minute foam .5024 gallons per minute foam X 65 minutes = 32.656 gallons total Onsite, prior to attempting extinguishment, you should have 32.656 gallons of foam. Post Fire Suppression: Once a foam blanket is applied, it is degrading. After extinguishment the foam blanket must be maintained. Due to the lowered risk and simpler application involved with maintaining a foam blanket, Williams Fire utilizes the following calculations to figure the water/foam required to maintain a foam blanket. Foam Requirements: 1%=.01 3%=.03 Multiply Gallons per minute X Foam Percentage X 30 Minutes Example: 50.24 Gallons per minute X .01 = .5024 gallons per minute foam .5024 gallons per minute foam X 30 minutes = 15.072 gallons total Total Foam Requirement: Onsite, prior to extinguishment, you should have the total amount of foam required to extinguish the fire, and maintain the foam blanket. This can be calculated using the following: Extinguishment Foam Required + Post Fire Suppression Foam Required = Total Required Example: 32.656 gallons + 15.072 gallons = 47.728 Total Gallons Required Operations should not begin until this quantity is available onsite. Spill Fire As with any spill fire, care should be taken to nate level/grade of surface, diking around the area, and possible runoff/failure locations for containment. Determine the type of chemical that has been released, select the correct type of foam (as explained previously) and apply a foam blanket to the surface of the liquid to accomplish extinguishment. Pressurized Liquids/Gases Three-dimensional fires are fires that have height, width, and depth. They will commonly be from a flange or pipe that is pressurized or a burning liquid falling through space. The two types of common three-dimensional fires are pressurized gases, and pressurized liquids. Pressurized liquids commonly cause spilt/pool fires, where pressurized gas fires appear as more of a jet/torch type fire. Three-dimensional fires need to be handled in steps: 1. Secure the spill/pool fire with a foam blanket 2. Cool/Protect exposures with copious amounts of water 3. Use master stream nozzles to control the flame 4. If a liquid, extinguish with dry chemical or Hydro -Chem' S. If a gas, isolate source and cool while depressurizing. Note: Using dry chemical to extinguish 3 Dimensional fires is very effective, always keep in mind that due to their nature, 360 -degree coverage must me accomplished. To accomplish this, hand lines and light portable equipment may be required. Identifying Hazards While each site will present it's own unique and challenging tasks, the following guidelines represent what Williams Fire views as the most likely scenarios and how to deal with them. Tank Batteries Tank batteries are the most common fuel in depth hazards that will be found on Marathon Industrial sites. Fuels in depth require large volumes of water to be applied at the proper application rate to extinguish (see previous section). Due to the large volumes of water, water sources that can provide the required amounts must be available prior to attempting extinguishment. Water sources can consist of: 1) Portable tanks 2) Municipal water shuttling 3) Rivers 4) Lakes 5) Ponds 6) Ditches connected to waterways Water sources can be any body of water that is ACCESABLE, and contains enough VOLUME. Due to the large amounts of water necessary, and the potential distance it may have to be transported at pressure, large diameter fire hose and pumps may be required. Extinguishment (Offensive) Certain information should be collected and recorded prior to an emergency: 1) Tank Diameter 2) Chemical stored 3) Foam Type on Hand/Available 4) Percentage of Foam Required 5) Application Rate required 6) Water/foam solution (Gallons per Minute) Required 7) Monitor/Nozzles available 8) Total Foam Needed 9) Total Water needed 10) Drafting Locations Available 11) Distance from Drafting to site 12) Large diameter hoses available 13) Alternate water sources (Portable Tanks, Shuttling, etc.) All this information can be filled out on the attached worksheet Exhibit 1, and added as needed to individual plans. Exposure Protection (Defensive) Exposure protection is essential to controlling the fire. Control is required to allow limited loss of equipment and limit down time. Always be aware of water runoff and containment. Never apply water only to the exterior of a burning tank; the only water applied should be over the top with foam for extinguishment. Large amounts of water should be applied to the areas of the surrounding structures and equipment that are facing the fire. Water should be applied until the surface appears to stay wet, if the water is flashing immediately to steam, increase cooling water volume until this stops. Drilling Activities The common types of fire that can be expected during drilling operations are spill/pool fires and/or three-dimensional fires. Spill Fire As with any spill fire, care should be taken to note level/grade of surface, diking around the area, and possible runoff/failure locations for containment. Determine the type of chemical that has been released, select the correct type of foam (as explained previously) and apply a foam blanket to the surface of the liquid to accomplish extinguishment. Pressurized Liquids/Gases Three-dimensional fires are fires that have height, width, and depth. They will commonly be from a flange or pipe that is pressurized or a burning liquid falling through space. The two types of common three-dimensional fires are pressurized gases, and pressurized liquids. Pressurized liquids commonly cause spill/pool fires, where pressurized gas fires appear as more of a jet/torch type fire. Three-dimensional fires need to be handled in steps: 1. Secure the spill/pool fire with a foam blanket 2. Cool/protect exposures with copious amounts of water 3. Use master stream nozzles to control the flame 4. If a liquid, extinguish with dry chemical or Hydro Chem'"" 5. If a gas, isolate source and cool while depressurizing. Well Sites and Gas Pressure Systems (Flares, Separators, etc.) The common types of fire that can be expected in the event of a wellhead failure are spill/pool fires, pressurized liquids, and pressurized gas fires. Spill Fire As with any spill fire, care should be taken to note level/grade of surface, diking around the area, and possible runoff/failure locations for containment. Determine the type of chemical that has been released, select the correct type of foam (as explained previously) and apply a foam blanket to the surface of the liquid to accomplish extinguishment. Pressurized Liquids 1) Secure the spill/pool fire with a foam blanket 2) Cool/Protect exposures with copious amounts of water 3) Use master stream nozzles to control the flame 4) If a liquid, extinguish with dry chemical or Hydro -Chem'' 5) If a gas, isolate source and cool while depressurizing. Pressurized Gas In the event of a gas leak, master stream nozzles are the most effective method for controlling and dispersing the gas. These types of events will require: 1) Air monitoring to ensure effective dispersal of the gas cloud 2) Copious amounts of water to accomplish effective dispersal Wild Fires The most likely cause of wildfire from an industrial facility is a fire in the storage, process, or gas pressure systems that ignites surrounding foliage that left uncontrolled can lead to a wild fire. Onsite Threat The most effective way to manage wildfire prevention is maintain discipline with the current, in place, housekeeping procedures outlined by Marathon. Common causes for onsite wildfires are: 1) Uncontrolled foliage around processes, storage, and flares 2) Poor discipline with the housekeeping program The most effective tactic for dealing with an onsite grass/foliage fire is: 1) Isolate effected processes 2) Cool effected processes with master stream nozzles 3) Using hand or vehicle portable monitors extinguish the fire If extinguishment is not accomplished quickly, wildfires and brushfires can quickly grow beyond the capabilities of local assets and escalate to large-scale events. Offsite Threat In the event of an offsite threat that is advancing on the facility, shutdown, securing the site, and advising local authorities of the hazard is recommended. Due to the unpredictability of wildfires, attempting to protect the site can quickly become an immediate danger to life and health. HZS Safety: Personnel responding to emergencies at well sites or facilities where H2S is potentially present must wear positive pressure self-contained breathing apparatus (SOBA). Some wells contain a high percentage of H25. H2S is extremely dangerous and has killed oil field workers and other petrochemical employees during accidental releases. The IDLH (Immediate Danger to Life and Health) for H25 is 100 parts per million (ppm). The STEL (Short Term Exposure Limit) for H2S is 20 ppm, while the PEL (Permissible Exposure Limit) is 10 ppm. Marathon corporate HES&S policy may set a different standard. Firefighters, whom may respond to facilities, including well sites where H25 may be present, should receive specialized training in H25 awareness and safety. When operating in and around such facilities, proper monitoring equipment should be available and used. H Firefighting: When dealing with pressurized gas fires, sometimes the best course of action is to allow it to burn while protecting exposures. When ignition of a well occurs, either intentional or accidental, other problems can occur. it can lead to additional wellheads being damaged, contributing to further blowouts. An intentional blowout may take place when the well contains high concentrations of H2S. By igniting the blowout, it will reduce the danger of the H2S spreading by wind to the surrounding area. 502 When burning, H25 emits a by-product, 502, which is also a toxic gas. The downwind side of the fire poses a threat from 502. Evacuation and constant monitoring for toxic concentrations of downwind areas will be necessary. H2S Firefighting Tactics: Gas/Liquid fires involving "Sour" gasses and liquids should be handled using the same steps as in the well sites section of this appendix. Water vapor mitigation to disperse the vapor cloud, when possible secure the source with a valve. Alternate Water Supplies: Alternate water supplies can be lakes, rivers, streams, or man made storage devices. The two most important requirements for a water supply are quantity and accessibility. The water source has to have an adequate supply for the emergency, and it needs to be accessible with large equipment. Typical municipal firewater pumps and transportable trailer mounted pumps are large in size and heavy in weight. This requires a drafting area that is both accessible with large equipment and can handle the weight of a truck or pump. Firewater pumps are typically rated for 10 ft. of lift. This means that the centerline of the pump unit is designed to be no more than 10 ft. from the surface of the water that you are drafting. This is important to remember whether you are drafting from a pond or using portable frac tanks. With frac tanks, you will improve efficiency if they are staged and used either level or above grade from your firewater pumps. See below for example. Alternate Water Sources (Cont.) MAXIMUM 150 LIFT The pump manufacturer will provide a curve that indicates how performance is affected when the lift is increased above or decreased below 10 ft. Natural Drafting Points: Natural drafting points consist of Takes, rivers, streams, ditches, etc. They need to be accessible and able to hold a substantial amount of weight. The following are examples of drafting points Williams Fire has used in the past. Utilizing floodwater in a mine. Utilizing Rainwater in a dike. Utilizing confined access in a refinery Drafting large volume from a pond Man Made "Prefabricated" Water Sources: Natural drafting points consist of lakes, rivers, streams, ditches, etc. They need to be accessible and able to hold a substantial amount of weight. The following are examples of drafting points Williams Fire has used in the past. _ --- .10.7"- tee► illifILLIAMS FIRE & HAZARD CONTROL Site Name: Marathon Oil Tank Battery/Containment Dike Pre Fire Plan Worksheet Tank Number: Tank Diameter/Dike Size: _- Chemical Stored: Foam Type: Foam Percent: Application Rate Required: Water/Foam Requirement: Total Foam Required: Total Water Required: Drafting Locations: Distance from drafting to site: Large Diameter Hose Available: Alternate Water Sources: tycc Fire Protection Products Z4HR EMERGENCY +1-409.727.2347 or +1-281-999-0276 9605 Richara Wycoff Drlvc 1 Part Arthur, TX 77640 1 +14109-745,3232 1 www.wttliamsHrc.com Copyright © 2013 Tyco Fire Products LP. I All rights reserved Attachment 4 Road Maintenance Contract Description of Work: The Contractor shall provide Mobilization and De - Mobilization for all equipment required to complete the "Routine Maintenance" tasks described under this section and within this RFP. Method of Payment: The cost for Mobilization and De -Mobilization shall be included in Bid Schedule No. 1 for "Routine Maintenance". 5.2 Normal Maintenance Activities 5.2.1. Blading and Grading Description of Work: Normal blading and grading consists of those work tasks to maintain the grade, width, and cross-section of the road, Small holes, washed-out sections, and wash board areas shall be bladed to maintain a smooth and well drained road section. Blading operations shall not significantly alter the cross-section or slope of the road in such a manner that disturbs the existing drainage pattern. Flat blading of the road shall not be allowed. Source Material: Available on-site material shall be designated by PDC. In cases where the Contractor must provide materials other than on-site source material, such as gravel, the Contractor shall provide PDC with price bids from at least two sources. PDC shall approve the vendor in advance of ordering materials, and in some cases materials shall be directly billed to PDC. Stockpile Material: If directed by PDC, a stockpile of approved road grading material shall be kept on-site for minor filling, shaping, or adding material where poor drainage has caused road saturation to occur. Stockpile locations shall be approved by PDC and any stockpiled material will be subject to the dust control requirements outlined in this RFP. Method of Payment: The cost for Blading and Grading shall be included in Bid Schedule No. 1 for "Routine Maintenance". 5.2.2 Stormwater and BMPs Description of Work: The Contractor shall provide the routine inspection, maintenance, and management of the existing Best Management Practices (BMPs) located along the Garden Gulch Road. This road is currently covered under the Colorado Discharge Permitting System (CDPS) General Construction Stormwater Permit (Permit) as issued by the Colorado Department of Public Health. and Environment (CDPHE) Water Quality Control Division (WQCD). This Permit has a site specific Stormwater Management Plan (SWMP) that identifies the location of BMPs, inspection, documentation, recordkeeping, and -7- additional compliance requirements that must be performed in a timely manner in order to maintain this Permit. Under this Maintenance and Management Program, the Contractor shall assume responsibility for compliance with all of the requirements outlined in the Permit and communicate any areas of concern to PDC immediately. In addition, the Contractor shall implement the requirements of the SWMP as stated, documenting the maintenance and inspection activities as they occur. The Contractor will be responsible for the compliance and implementation of the Construction Stormwater Permit and. SWMP for the duration of the contract period. PDC retains the right to perform third party audits and inspections and request information from the Contractor at any time. PDC currently tracks the BMP maintenance and inspection activities in both hard copy and in an electronic database. The hard copy log books are located on-site at the Garden Gulch LLC Maintenance Yard or PDC Operating office and shall be updated and maintained on a regular basis. An electronic copy of any new log entries andfor updates shall be provided to the PDC Stormwater Program Manager, Jesse Rippee within one-week of the hard copy entry at the maintenance yard. Electronic copies shall be provided to PDC in an Excel (or approved) format. The Contractor is responsible for all of the tasks in support of the implementation of this Permit including. but not limited to the following: o Log maintenance activities in the database including, but not limited to: o Roadside ditch and ditch check cleanout and repair. o Culvert cleanout and repair. o Cattle guard cleaning and repair. o Cleaning and maintenance of the Mud Tracking Pad located between the new bridge and Garfield County Road 215. o Include what was repaired; date and time of the repair; who completed the repair; follow-up inspection details of the repair and who accepted the repair. o Verify that all BMPs are designed, built and working as defined in the Stormwater BMP Manual. o Recommend additional BMPs as needed immediately, including providing location and construction details to scale in CAD drawing fonnat. This includes both structural and non -structured BMPs (signs, memos to those using the road, etc.). o Continually track the chain of communication regarding action items and identified maintenance activities, including why an item was not repaired. -8- 5.3 Snow Removal Description of Work: Snow removal consists of alt those activities associated with the collection, removal, and disposal of snow from Garden Gulch Road, coordination of all Contractor personnel (including subcontractors), and coordination with PDC, during normal operating hours as defined in 8.4.1 Summer Period and 8.4.2 Winter period. Contractor may be required to provide pilot vehicles or provide transportation of rig crews during severe weather conditions. The contractor shall supply all of the equipment, labor, and materials necessary to accomplish the work, including radios for each operator involved in snow removal activities. General: In the early stages of winter, the contractor shall leave approximately 5"to 6" of snow on the ground until the ground freezes to minimize road damage due to tire chains. Under no circumstances shall snow removal operations be accomplished by excavating below the existing roadbed. Should it become apparent that removed snow contains embedded gravel, the contractor shall contact PDC and not simply push the contaminated snow into the surrounding vegetative areas. Disposal of snow shall be in designated areas as directed by PDC and any Contractor damage of BMPs caused by Contractor (or subcontractor) activities shall be repaired at the expense of the Contractor. During Inclement Weather: The contractor shall be prepared to mobilize snow removal equipment at any time during a 24-hour period in order to keep the road cleared of snow. Snow removal shall continue throughout the duration of the storm to provide for, at a minimum, scheduled drilling operations, crew changes, and safe access to the Garden Gulch Extension Road, In extreme weather conditions the Garden Gulch Road may be shut down to travel, if recommended by the Contractor and approved by PDC. All snow removal operations shall be coordinated with PDC or their designated personnel. Following the Storm: The Contractor shall continue to use graders and dozers for snow removal, but may also employ the use of snow blower equipment. Snow blowers may be used for turns and cuts, or to remove snow placed in windrows by graders or truck blade equipment. Snow removed by blower equipment shall not contain any excavated material or road gravel. Hazard Warning: The contractor is notified that an avalanche chute exists above the road at MP 4.2 (see Map, Garden Gulch Road, Appendix). The contractor shall take extra precautions to avoid the buildup of snow and avalanche debris within this area so that progressive 12- o Invoice preparation and backup documentation, including assignment of proper billing codes. Method of Payment: The cost for Managerial and Administrative services shall be included in Bid Schedule No, 1 for "Routine Maintenance". 6.0 Additional Work (Other Than Routine Maintenance) Description of Work: Additional work includes any work not already included as part of "Routine Maintenance". Additional work includes both Capital improvement projects recommended by the Contractor as well as work directed by PDC. The Contractor is encouraged to recommend Capital Improvement Projects that will improve the safety and performance of Garden Gulch Road and reduce the disruption 10 traffic due to the presence of routine maintenance equipment. It is expected that the cost for any Capital improvement Projects will be offset by savings in routine maintenance or operational delay. Capital Improvement projects are considered to be Additional Work as defined under Section 2.1.4. Any GGR partner may request the Contractor to perform other additional work which may include, but is not limited to, such work as drill pad construction, new access roads, rig moves, fence repair, hydro -mulching for specific slope areas, and specialty geotechnical services and mitigation as long as it does not interfere with the performance of the GGR contract. Additional work shall be based upon an agreed scope of work and the Contractor shall provide PDC with a cost proposal prior to commencing any additional work. The cost proposal shall include all of the labor, equipment, fuel, materials, rentals, third party services, managerial, and administrative staff necessary to complete the work. Method of Payment: The Contractor shall use the Contract Unit Rates established under Bid Schedule No. 2 in the preparation of any cost proposal for additional work. Unit costs not already established under Bid Schedule No. 2 shall be submitted to PDC along with any requested supporting documentation. 7.0 Time and Materials Work 7.1 Interim Dust Control Description of Work: Contractor shall be responsible for the control of fugitive dust along the Garden Gulch Road from Garfield County Road - 15 - 215 to Puckett Ponds (see Map, Garden Gulch Road, Appendix), in accordance with the requirements of the Air Quality Permit (to be provided upon successful award), the CDPHE, the APCD and the COGCC, in the interim between applications of DustGard 820. Water shall he used for interim dust control and applied to trouble areas as required. The Contractor shall determine the rate of water application necessary to control visible dust and modify the rate of application in accordance with seasonal weather conditions or other factors that may generate excessive dust. such as scheduled periods of high traffic volume. The Contractor shall not excessively water or waste water at any time The Contractor shall provide all of the trucks. equipment, labor, and. materials necessary to complete the work. The water source shall be from Parachute Creek or a suitable source nearby and water trucks will be allowed access directly adjacent to the creek at a site designated by PDC. Water storage tanks will be allowed at designated sites along the Garden Gulch Road, including the upper guard shack. Should an additional application of DustGard 820 be required to adequately control the dust on all or portions of the Garden Gulch Road, a cost proposal shall be submitted to PDC, once an actual scope of work has been determined. PDC Supplied. Materials: PDC will provide the water source and designated sitgi be.0 fe: ` li :f• - 8'lied water trucks.. Method of Payment: The cost for Interim Dust Control shall be performed on the basis of time and materials. Unit costs not already established under Bid Schedule No. 2 shall be submitted to PDC along equested supporting documentation. 7,2 Geotechnical Inspections Description of Work: Geotechnical inspection of the road segments should be conducted at the request of PDC Energy. The Geotechnicai inspection shat] be documented in a formal report, providing the time: of and Limits of the inspection, condition of the road segment, photos, and recommendations for action items. A Table of Action items and their status between inspections shall he a part of this report. The cliff section of the road wilt require inspection of the highwall and stability assessment of cut slopes, fill slopes and natural slopes above the road (see Map, Garden Gulch Road, Attachments). The report should identify areas of concerns and identify potential remedial measures for the partners to assess. The inspection shall be conducted by a third party Professional Geotechnical Engineer licensed in the state of Colorado. -lh- Attachment 5 Weed Inventory Memo and Map i;InterTech Providing Innovative Solutions in a Complex Environment To: Marathon Oil Company — Piceance Operations From: Scott Distel, M.S., Environmental Specialist — InterTech Environmental and Engineering, L.L.G. Date: June 12, 2014 Re: 596-32C Well Pad and Access Road Weed Survey and Herbicide Treatment Message: On May 20, 21, and 22, 2014, a field -wide weed survey was conducted along access roads and well pads for leases held by Marathon Oil Company in the Piceance area. As part of that survey, Marathon's 596-32C well pad and access road leading to the 596- 32C well pad were surveyed an May 20, 2014, for the presence of county- and state - listed noxious weeds. The presence and general locations of observed weeds are noted on the attached maps. During the survey, isolated bull thistle (Cirsium vulgare) was observed immediately north of the sediment trap associated with the outflow from culvert 1, as identified on Marathon's stormwater management map for the 596-32C access road. Along the length of the 596-32C access road maintained by Marathon, isolated houndstongue (Clynogfossum officfnale) was observed occurring on both sides of the road. There was also an area along the southern edge of the 596-32C well pad where isolated houndstongue (C. officinale) was observed growing. On May 30, 2014, representatives from Marathon met with their weed control contractor and discussed the findings of the weed survey. A plan was developed whereby the weed contractor would apply approved herbicides to weeds occurring along Marathon's Piceance well pads and access roads. On June 11, 2014, the weed contractor treated the weeds along the 596-32C access road and well pad. A subsequent weed survey will be conducted to ascertain the effectiveness of the June 2014 herbicide treatment, and to note any new infestations for treatment later in the year. Attachments: Weed Survey Maps 3821 Beech Street, Laramie, WY 62070 * Tel: 855.687-8324 • Fax: 307-745-1582 9 interTechEE.com Regional Offices. Gillette, WY • Oenvei, CO • Grana Junction, CO Field Offices: Buffalo, WY . Casper, WY • Cody, WY • Bismarck, NO Receiving Waters: Little Creek 1380 Feet Northwest House Log Gulch 3000 Feet Southeast a \\ ='T $ 'ter_ Y.I f .zed 5tA 1. Pad 596-32C e �' 1 } 1 /;_ ,fiss 'se _ Access Road To / Garden Gulch Extension Road 1 / N./4R / Non -Marathon Road & BMPes Is. -4-4,-,d buf/ 441 oile if) `;U Access Road To Berry Site r.I r / j r 3c1 �t1 11,:a. 0.4 longue - 5i de G 1{- 01- c {-01.cread •Culven S.:Smoot Trap C.tR. PaM . ea. Ws tai- Dar Ri. Legend ao Area Ta 9. etedairt d sere, i V-0tdv WtGy. cis D,rn - .. e:.end. oit<n }}; sna Ilstrs 'No Ssrin Fre-, Re? Da Fens, Oren.. isS S..E.d Jt boenuWed Sol Rcups:Vny S'sss Morose ao 16 t= Feet 1:2.400 Not Presant Asphalt Or Concrete Balch Plants Project Location *num =bra►,igi i Garfield County trgaMill Map Index Overview Access Road To Pad 596-32C Approx mate Road Length = 830 LF MARATHON OIL REVISED'.BY: COMMENT: 2a/2012 B TEMPLATE CREATION 012 BJB AP CREATION "`1ntarTech ,,,.,»d.. in Receiving Waters: Lithe Creek 1 000 Feet Northwest Log House Gulch 1800 Feet Southeast 5124,0_ (eel Suri Slug lixma Spoil Area Produced Water Reserve Pit 0 0 O 1731,4,1 ►7CUIaj' I 4Ct 00 (00 CO) p Soli Area 7 7 Legend 4116111. /tap ere. Q v oKa rwCie.r Rem - otie,elon Eder j)j.filc dRr.+ .....1"ber Rol in Fence ore• To et 4e ets'reed Penns 9tenlel Seeded S Wydrmereled SW Roughening &ogee eMge MP Rae Eueemap 0 70 so -1 cr=aw 1:1,000 Not Pment Asphstt Or Concrete Retch Kerns Project Location Garfield County Map Index Overview Pad Site 596-32C Tots! Oisiurbed Area = 3.57 Acres MARATHON OIL REVISED BY: COMMENT: 3!28!2012 BJB KAP CREATION 5181'2012 BJB BMP REVISION 8127/2012 _ BJB BMP REVISION 111712014 BJB BMP REVISION InterTech Attachment 6 Wildlife Mitigation Plan Audit CK A5S0ClATE5,1 LC 17170 PERKINS ROAD BATON ROUGE. LA 70810 PH (225) 755.1000 FAX (225) 751-2010 hItp://www.c-ko.COm ENV P.ONVE.NT, d'1rFtuLNG. UOTAS v L FAF11-S January 30, 2013 Colorado Parks and Wildlife 711 Independence Avenue Grand Junction, Colorado 81505 Attn: Mr. Michael Warren Re: Marathon Oil Company Wildlife Mitigation Plan Agreement Third Party Review C -K Associates' Project No. 5738E Dear Mr. Warren: REGIONAL OFFICES LAKE CHARLES. LA PH(337)439-8699 LAX{337)421-1479 SHREVEPORT. to PH13181 7978636 FAX{318)798.0478 HOUSTON, TX PH [281) 397.9016 FAX {28t) 397-6637 On March I6, 20W Marathon Oil Company (Marathon) and the Colorado Parks and Wildlife (CPW) entered into a formal Wildlife Mitigation Plan (WMP) agreement (Agreement), which mitigated for direct and indirect impacts to wildlife species of concern and sensitive wildlife habitats (SWH) from Marathon's oil and gas operations within the Piceance Basin. The Agreement is conditional and requires all components to be maintained. One requirement is to conduct an annual review to ensure that all Agreement components and acceptable best management practices (BMPs) are maintained. Marathon contracted C -K Associates, LLC (C- K) as a third party to conduct the annual review to validate adherence to the Agreement. The purpose of this correspondence is to document that the annual review was conducted and that all components of the Agreement have been fulfilled and are maintained through established policies, BMPs and standard operating practices (SOPS) by Marathon. 2012 Annual WMP Agreement Review Marathon's overall development for the Piceance Basin at the time of the Agreement included a total of 56 well pads: 23 existing and 33 proposed. Of the 56 well pads, 36 are located within SWH boundaries according to Marathon's wildlife proximity database and consultation with CPW. At present, 19 of the 22 active pads are located within SWH boundaries. Early in the Agreement process, the CPW and Marathon determined that several BMPs were effective at avoiding and/or rninimizing impacts to the landscape from oil and gas development. The Agreement identifies six primary mitigation. BMPs that are part of Marathon's SOP to reduce environmental impacts. Primary Mitigation BMPs • Supervisory Control and Data Acquisition (SCADA) • Voluntary Timing • Man Camps • Liquids Distribution • High Efficiency Rigs • Closed -Loop Drilling 20120116_ WMP Survey,doc C -K Associates, LLC Mr. Michael Warren January 30, 2013 Page 2 of 4 Additionally, Marathon implements other BMPs as part of their SOPs that are designed to reduce the operating footprint, human -wildlife encounters, and traffic in combination with other practices to reduce natural resource impacts (see Attachment 1). In order to determine Marathon's adherence to the Agreement, C -K identified a process to validate Marathon's intent and actions regarding the Agreement. The selected process chosen by C -K consisted of (1) interviews, (2) field review, and (3) policy reviews. C -K conducted meetings and follow-up correspondence with Marathon before and after the site visit conducted on June 12, 2012. The meetings consisted of interviews to discuss primary mitigation and other SOPS, including BMPs, which benefit wildlife species of concern and SWH. Marathon stated that no new drilling has occurred since June 2010, and no completion activities have occurred since December 2010..Since December 2010, Marathon has focused on the production operations for the 77 producing wells on 22 active pads. Marathon also provided updates on the liquids distribution system for managing fresh and produced water. For 2012, there were no updates for the freshwater system (Valley Pump Station). During Marathon's drilling and completion activities (2008-2010), fresh water was delivered to locations via pipeline to minimize trucking impacts. Beginning in September of 2011, Marathon began to more fully utilize the produced water pipelines which dramatically reduced truck traffic within the field. Marathon's perspective is that the company is adhering to the Agreement; this is based on daily operations and existing programs/policies that are specific for the Piceance Basin. Marathon has established their BMPs in accordance with the CPW's "Action to Minimize Adverse Impacts to Wildlife Resources" based on the location and operational timing requirements for each pad. These BMPs include annual educational training for Marathon staff and contractors on wildlife issues of concern, implementation of wildlife protection policies on Marathon property, and overall consolidation and increased efficiency of operations to minimize wildlife disturbance. One example of BMPs recently implemented is the liquids distribution system that moves produced water to Pad 18A or to Pad 32C. Since September 2011, Pad I8A has been used to gather most of the produced water via pipeline in order to minimize trucking within the field. Marathon also has a water impoundment at Pad 32C. Produced water was stored and pumped from Pad 32C via pipeline to support the final completions activities in late 2010. Since then, the pond has been utilized to store produced water for eventual disposal. Between the liquids distribution system (produced water lines), Pad 18A, and Pad 32C, Marathon is able to minimize trucking within the field and have more operational flexibility for managing produced water. As part of the Agreement there are three continuing components that were reviewed; (1) CPW Piceance Project Research Contribution, (2) Marathon Raptor Monitoring, and (3) Land Cover Analysis. CPW Piceance Project Research Contribution Marathon annually (2010-2012; three calendar years) contributed $100,000 (overall total of $300,000) to the CPW. The CPW project is designed to facilitate studies of sage grouse (GrSG) and mule deer habitats within the Piceance Basin. Marathon completed 201201 16_WMP survey.doe C -K Associates, LLC Mr. Michael Warren January 30. 2013 Page 3 of 4 the 2012 contribution on July 6, 2012. This July 6, 2012 payment represents the final installment of the overall $300,000. Raptor Monitoring Marathon is scheduled to conduct annual raptor surveys through 2015. Raptor surveys have been completed for 2010, 2011 and 2012. The 2010 raptor survey indicated 27 nest sites, the 2011 raptor survey indicated 31 nest sites and the 2012 raptor survey indicated 35 nest sites. The 2012 raptor survey found 31 nests that were discovered in previous surveys and four previously undocumented nests. The three annual surveys utilized the same protocols and covered the same geographical area in order to evaluate sustainability of nest counts (occupied and unoccupied nest sites within the Marathon leasehold). Land Cover Analysis In accordance with the Agreement, Marathon is scheduled to obtain satellite imagery for 2010, 2012 and 2014 to evaluate natural and operational changes to the landscape, including detectable vegetation changes. The baseline for the analysis utilized the 2008 satellite imagery that was provided to the CPW. The 2010 and 2012 satellite imagery was acquired in August 2010 and 2012, respectively. A comparative analysis has been developed utilizing the 2008 and 2010 satellite image, which represents a subsequent submittal to the CPW. Marathon has managed well pad development with wildlife timing considerations with a focus towards GrSG, raptors and elk. The interviews also indicated that Marathon included wildlife timing considerations for all 2011 pit closure activities, beyond what is required through the Agreement. Based on the interviews and policy reviews, C -K concluded that Marathon has the appropriate policies in place to communicate and manage their operations in balance with wildlife and SWH concerns. In order to determine the field implementation of these policies, BMPs and SOPs, in 2011, C -K identified five well pads for field review to form an independent opinion regarding Marathon's adherence with the Agreement. In order to maintain consistency over the life of the Agreement, in 2012, C -K visited the same five well pads from the 2011 survey plus an additional four well pads (see Figure 1). Well Pads Visited in 2011 Pad 697-12A Pad 696-5C Pad 596-35D Pad 596-29C Pad 596-32C Well Pads Visited in 2012 Pad 697-12A 20120116_WMP Survey.doc C -K Associates, LLC Mr. Michael Warren January 30, 2013 Page 4 of 4 Pad 696-5C Pad 596-35D Pad 596-29C Pad 596-32C Pad 697-1IX Pad 696-18C Pad 596-31 A Pad 596-34D The selected well pads represent geographical locations that are within or in proximity of SWH for GrSC, elk, golden eagle, and peregrine falcon (see Attachment 2). The well pads depicted consistency in design features and represented different stages of surface use and/or reclamation (see Attachment 3: Photo Documentation). According to the National Drought Mitigation Center, Colorado has experienced abnormally dry to extreme drought conditions since May 2012. All well pads had been recently hydromulched and had perimeter earthen berms that were sloped to direct surface flows towards natural landscapes, road way ditches and/or sediment traps. The earthen perimeter berm slopes were appropriate for storm water and erosion controls. Secondary containment for tanks consisted of corrugated metal walls with internal plastic lining. All production equipment had fencing to limit wildlife entry; this was also practiced for multiple wells associated with the well pads. There were no observations of drips and/or leaks within the secondary containment. In general, the well pads were clean of debris and trash, with equipment and materials properly staged for utilization as needed. Numerous elk and mule deer tracks were observed on Pads 697-12A, 596-35D, 596-29C, and 596-32C, as well as all other well pads visited indicating movement within the operational area. WMF Agreement Review Conclusions Based on the interviews and correspondence with Marathon, the review of Marathon policies, and subsequent site visits to various well pads, C -K concluded that Marathon operations within the Piceance Basin are compliant with all WMP requirements. If you have any comments and/or questions regarding the information provided, please do not hesitate to contact me at (225)-755-1000 office or my cell at (225) 252-6526. Very truly yours, C -K Associates, LLC Keith Nichols Senior Environmental Scientist 20120116_WMP Survey. doe C -K Associates, LLC Attachment 1 Marathon Oil Company BMPs Updated January 2013 Marathon has established an evaluation process for operations within the Piceance Basin that addresses wildlife concerns. This listing of Items 1-5 represents our specific actions that are considered avoidance and minimization actions by the Colorado Parks and Wildlife (CPW). Marathon has developed these BMPs as part of our Standard Operating Procedures (SOP) to provide operational and wildlife management for the Piceance Basin. No new drilling has occurred since June 2010, and no completion activities have occurred since December 2010. The following list reflects current, active BMP's implemented based on current operations within the Piceance Basin. Marathon will adhere to the original BMP's as outlined in the March 16, 2010 Wildlife Mitigation Plan agreement. 1. Riparian Area Protection for Wildlife • Marathon will locate roads as far from riparian areas and bottoms of drainages as possible and outside of riparian habitat. However, Marathon is limited in areas where landowners dictate utilization of roads. 2. Company Vehicle Guidelines and Traffic Reductions for Wildlife Protection • Marathon has 25 mph limit for all roads (speed limit signs are posted); additionally it is Marathon's policy to prohibit the use of radio/cell phone while driving to enhance driving awareness. Car pooling for major projects is encouraged for all Marathon contractors to reduce traffic; carpooling is evaluated and used where practical for major projects. • Marathon utilizes SCADA/Automation system to better understand and operate wellsite operations. The SCADA/Automation system provides a real-time view of the site with the ability to remotely start-up and shut -down certain operations. The system can be used to eliminate unnecessary trips to the production pad. Marathon currently has twenty-two pads in production and all pads are monitored by the SCADA/Automation system. The SCADA/Automation is a key component to safe, efficient, and environmentally friendly operations. • When actively drilling, Marathon utilizes one Temporary Living camp to house the resources needed to support the drilling operations within the Piceance Basin. The site supports approximately 50 personnel that function on 12 -hour shifts. The shift work schedule is 2 -weeks on and 2 -weeks off. This is a traffic reduction of 25 vehicles per day, 7 -days per week. There is an understanding that the reduction of traffic as a whole reduces the opportunity for wildlife impacts. 3. Infrastructure Layout for Wildlife Protection • Marathon has installed consolidated and centralized fluid collection facilities and water pipelines to manage fluids in the field. Through 2011, Marathon has installed approximately 50 miles of pipelines to manage existing production as well as future developments. The majority of the water pipelines are located adjacent to existing roads and within existing ROWs. The installation ofmost of the water pipelines was performed in conjunction with the installation of gas gathering lines performed by Enterprise. During the installation, both Marathon and Enterprise utilized the same contractor to reduce the overall disturbance and traffic by making one ground disturbance; thereby, reducing manpower, pieces of equipment and installation schedule. • From 2008 through 2011, Marathon has utilized the fluid infrastructure to move approximately 2.2 million barrels of water throughout the field. The use of the pipelines and central facilities has saved approximately 22,000 truck loads and over 330,000 trucking miles. As Marathon continues to produce from this field, there will be continued utilization of this infrastructure to manage fluids which will continue to reduce disturbances and traffic. Produced water can be pumped via pipeline to Pad 18A for storage and offsite disposal. Produced water can be pumped via pipeline to Pad 32C for storage and enhanced evaporation. The use of Pads 1 8A and 32C for managing produced effectively minimize truck traffic within the field. Based on development to date, future development of the field will utilize the infrastructure that has been installed. Each future well requires approximately 25,000 barrels of water to drill and complete. The water trucks used for transport carry approximately 100 barrels per load. As a result, continuing to utilize the infrastructure will save up to 250 truck loads per well during future development. Total development will require an average of eight wells per pad to achieve 20 acre spacing. This equates to 2,000 truck loads per pad and would increase with more aggressive development. As stated earlier, the traffic reduction will continue as long as the wells are producing and the water pipelines and facilities arc utilized to manage fluids. 4. Drilling and Completions Operations for the Protection of Wildlife • Marathon will review annually the scheduled civil construction, drilling and completion activities (Plan of Development [POD]} to avoid portions of SWH, specifically for the GrSG. Additionally, Marathon through the POD will schedule our activities in a effort to avoid and/or minimize operations near and within lek sites, elk production areas and active raptor nests. The POD will be submitted to the CPW by the end of January for each calendar year. This component of the WMP will be a living document. Marathon will utilize C -K. Associates, LLC (C -K) as our third party review team jointly with our regulatory compliance group to balance developments and ecological concerns within the Piceance Basin. Marathon's goal during the annual POD scheduling is to avoid at a minimum 66% of the GrSG SWH. • If for some reason an area cannot be avoided, Marathon will attempt to avoid the timing period associated with the wildlife category of concern. - Lek avoidance is from March 1 through May 15 for major activities Elk Production is rotation of production areas on a seasonal basis; 4 -mile buffer for GrSG March 1 -June 30 (4 -months) Note: there is an overlap of geographical areas between the elk production areas and the 4 -mile GrSG buffer area (SWH). In Marathon's effort to meet the timing for an elk production area, we also achieve avoidance for a portion of the 4 -mile buffer area. • Marathon has agreed to seasonal rotation development activities for the elk production areas. • As ofJanuary 2012, Marathon has closed all drilling reserve pits. • No drilling has occurred since June 2010; no completions have occurred since December 2010. 5. Additional Minimizations for Wildlife Protection • Marathon is following the rule requirements for noise. Regarding raptor perch deterrents, Marathon will provide deterrents in areas where surrounding habitats do not provide natural perches. • Marathon joint ownership properties can utilize approved seed mixes and restore disturbed sagebrush. In lease areas the land owner dictates the decision on seed mix and restoration of sagebrush. There are discussions with land owners on decisions regarding high priority habitat (lek areas and adjacent lands) where sagebrush can be restored. In other areas the approved land owner seed mix would be applied. Marathon conducts raptor surveys and utilizes the CPW's approach to evaluate survey data protocols. 6. Additional Awareness for Wildlife Protection • Marathon requires that each individual (company and contractor) go through orientation prior to working on locations and annually thereafter. Wildlife awareness is discussed. • Marathon shares a general site map that includes Marathon locations, roads, personnel contacts, etc. In addition, the map highlights Wildlife Timing Periods and the two lek sites within Marathon's acreage. The map is shared with company employees, contractors, and other operators. • Marathon conducts monthly HES (health, environment and safety) meetings that include company and contract employees. At least one meeting per year focuses on wildlife issues. Attachment 2 Wildlife Considerations Well Pad Well Pad Status Primary Wildlife Considerations 596-29C Existing RSO - GrSG & SWH - Elk Production Area 596-32C Existing SWH - Sage Grouse 596-35D - Existing SWH - Sage Grouse & Golden Eagle Nest 696-5C Existing None 697-12A Existing RSO - P. Falcon & SWH - Sage Grouse 697-11X Existing SWH- Sage Grouse, Mule Deer Summer Range & Elk Summer Range 696-18C Existing SWH- Sage Grouse, Mule Deer Summer Range & Elk Winter Range 596-31A Existing SWH- Sage Grouse, Mule Deer Summer Range, Elk Summer Range & Elk Production Area 596-34D Existing SWH- Sage Grouse, Mule Deer Summer Range, Elk Summer Range & Elk Production Area RSO = Restricted Surface Occupancy SWH = Sensitive Wildlife Habitat Species - Tinting Restrictions for Consideration SWH - Sage Grouse March 1 -June 30 RSO - Sage Grouse March 1 - May 15 (breeding season) SWH - Elk Production Area May 15 - June 15 SWH -Golden Eagle Nest December 15 - July 15 - no encroachment wfin 0.5 miles RSO - P. Falcon March 15 - July - no encroachment wlin 0.5 miles Attachment 3 Photo Appendix ATTACHMENT 3 Pad 5C Photos Pad conditions in 2012 showing recent hydrnmulching. Reclaimed areas surrounding the pad continue to exhibit healthy, robust revcgetation. Pad conditions in 2 11. Recently reclaimed areas surrounding the pad with healthy, robust vegetative cover. 1 C -K Associates, LLC Attachment 3 Photo Appendix Pad 5C Photos Pad conditions in 2012. Pad showing equipment, secondary containment and recent hydromulching. Pad conditions in 2011. 2 C -K Associates, LLC Pad 5C Photos Secondary containmen of Fad 5C tank battery in 2012. Containsnent is in adequate and. in good working condition. 3 Attachment 3 Photo Appendix C -K Associates, LLC Attachment 3 Photo Appendix Pad 12A Photos Pad conditions in 2012 showing hydromulching. Reclaimed areas surrounding the pad continue to exhibit healthy, robust revegetation. • — wagon F • A Pad conditions in 2011. Reclaimed areas surrounding the pad continue to exhibit healthy, robust revegetation. 4 C -K Associates, LLC Attachment 3 Photo Appendix. Pad 12A Photos 14*Aitv:9i5• ifsa s. Pad conditions in 2012. Secondary containment and perimeter fencing surround the pumps. Perimeter berm in good condition along pad edges. No active drilling or pad development in 2012. Pad conditions in 201 1. Secondary containment and perimeter fencing surrounding the pumps. Perimeter berm in good condition. No active drilling or pad development in 2011. C -K Associates, LLC Pad 12A Photos Pad conditions in 2012. Overview of pad showing equipment and perimeter fencing. Pad conditions in 2011. Overview of pad showing equipment and perimeter fencing. 6 Attachment 3 Photo Appendix C -K Associates, LLC Pad 12A Photos Attachment 3 Photo Appendix Secondary containment of Pad 12A tank battery in 2012..Cuntairunent is in adequate and in good working condition. Pit closure in 2011 showing perimeter berm and fencing. 7 C -K Associates, LLC Pad 29C Photos Attachment 3 Photo Appendix Pad conditions in 2012. Showing secondary containment around tanks an perimeter fencing around equipment. Pad conditions in 2011. Showing secondary containment around tanks and perimeter fencing around equipment. 8 C -K Associates, LLC Pad 29C Photos 2012 pad conditions showing hydromuiching. Perimeter berm remains in pine and in good working condition. ,` •, • ;r r ..dry . a rix.. _.i 2012 pad conditions. Perimeter berm remains in place and in good working condition. 9 Attachment 3 Photo Appendix C -K Associates, LLC pad 29CPhotos ti'; # , 4. ‘ _e....r•-• • 1 Secondary containment of tank battery in 2012. Containment is adequate and in good working condition. Secondary containment of tank battery in 2011. Containment is adequate and in good working condition. 10 Attachment 3 Photo Appendix C -K Associates, LLC Pad 32C Photos Pad conditions in 2012.showing Attachment 3 Photo Appendix rirneter bean, hydromulching and wildlife fencing around the pit. Pad conditions in 2011 showing fencing surrounding equipment. 11 C -K Associates, LL(_' Attachment 3 Photo Appendix Pad 32C Photos Wildlife exclusion fencing surrounding pit in 2012. Wildlife exclusion fencing surrounding pit in 2011. C -K Associates, LLC Pad 32C Photo Attachment 3 Photo Appendix Secondary containtnent of tank battery in 2012. Containment is adequate and in good working condition. Secondary containment of tank battery in 2011. Containment is adequate and in good working condition. i.3 C -K Associates, LLC Attachment 3 Photo Appendix Pad 32C Photos Overview of pad in 2012 showing pit and wildlife exclusion fencing, bird netting in place (barely visible) and perimeter fencing surrounding equipment. Niue deer tracks observed in 2012 that suggests operational areas do not adversely affect wildlife movement 14 C -K Associates, LLC Attachment 3 Photo Appendix Pad 35D Photos Pad conditions in 2012 showing hydrornulching. Tank battery surrounded by secondary containment. Pad conditions in 2011. Tank battery surrounded by secondary containment. 15 C -K Associates, LLC Attachment 3 Photo Appendix Pad 35D Photos Pad conditions in 2012 showing hydromulching. Sloping, revegetation and secondary containment are all in good condition. Pad conditions in 201 1. Sloping, revegetation and secondary containment are all in good condition. 16 C -K Associates, LLC Pad 35D Photos Secondary containment of tank battery in 2012. Containment is adequate an in good working condition. Pir 1111 Apr ..iss .1.1* APC -t4 kNf. -WX,61.44"tari 5 • "1„, •,; Iv; 47, ,-4 . / • 1 , • * 1 .4 Secondary containment of tank battery in 2012. Containment is adequate and in good working condition. 17 Attachment 3 Photo Appendix C -K Associates, LLC Attachment 3 Photo Appendix Miscellaneous Photos Stormwater velocity reduction BMPs observed in 2012 reduction BMPs in place along roadside. eti ," • :rpt Stormwater velocity reduction BMPs in place along roadside observed in 2012. 18 C -K Associates, LLC 4�isceltaneous Photos Example of pad reclamation area showing revegetation in 2012 near pad Pad 696-18C. 19 Attachment 3 Photo Appendix C -K Associates, LLC FIGURE I Legend 2012 WMP Wall Pada - Existing Pada Proposed Pads () Sage Grouse Leka IOW S Sage Grouse Sign WW! -• Sage Grouse Survey Transects (WW} I I Production Area (Neseng Handal) • Active Lek {4 MINI Nulling Kennel - ACliva Left 10.e M MI Goldin Eagle HEWS! {0 25 Mlle} n Pereira Felcon Habitat (0 5 Mlle) IVierarnorAemit Propenles Proposed Mklgation Areas PrbpbSed ROanan Mlligason Areas ProdudngLease States cowry Bou5danes Proposed Exleting Garden G4Ich Road RPM% & Streams Inlermilteni Slrsam Perennial Strewn MARATHON OIL COMPANY GRAND JUNCTION, COLORADO PICEANCE BASIN WMP REVIEW MAP GARFIELD COUNTY. COLORADO sviAiiitss FIGURE 1 . STABILUZ4Ti0h ROCK SOLID SOLUTIONS IGN . BUIL9 To: Marathon Oil Company Piceance Operations Wyoming Asset Team Grand Junction, Colorado (970) 244-5754 Office (970) 712-0554 Cell Memorandum June 15, 2014 Project: Garden Gulch Cliff Road & Garden Gulch Extension Road " Adequacti> "' Garfield County Colorado RE: Limited Impact Review Application & Land Use Change Permit — 32C Produced Water Impoundment Ms. Vicki Schoeber, As discussed. Rock Solid personnel are intimately familiar with the Garden Gulch Cliff Road and. Garden Gulch Extension Road system. The two road segments were designed and constructed by a partnership of oil & gas companies in 2005 to access the Roan Plateau in the Piceance Basin and have been operational since. Like all roads, maintenance of the roadway system is an on-going process, and as such the Garden Gulch road system is no exception. The road has been designed to provide access for drilling and service equipment for the oil & gas industry and is not intended for public use. The road grades are steep and the travel rate is generally very slow. As a result, it is aur opinion that the Garden Gulch Road system is very adequate for the intended use of providing private access for the partners to the oil & gas sites in the Piceance Basin. Rock Solid is confident that the Garden Gulch Road system can and will continue to provide adequate access to the Roan Plateau if proper maintenance is conducted on the roads. Please call/email if any questions. Respectful I t . Donald J. Berger, P.E Project Engineer Rock Solid Solutions (970) 987-2743 195 Lodgepole Circle, Parachute, CO 81635 Office: (970) 987-4247 Fax: (970) 712-5715