HomeMy WebLinkAbout2.0 DD Staff Report 11.25.2014REQUEST
PROPERTY OWNER
APPLICANT
ASSESSOR'S PARCEL #
PROPERTY SIZE
LOCATION
ACCESS
EXISTING ZONING
Director Determination - Minor Amd
SUAA-8153
1112512014
Amendment to a General Administrative
Land Use Change Permit for a Small
I njection Well Facility
Puckett Land Co
Caerus Piceance, LLC
24091330001 3
The facility will be located on a 6,320
square foot site which is within a
COGCC approved well pad location and
within an overall 147.29 acre parcel.
The property is located southwest to the
Town of Parachute and Grand ValleY
High School, approximately 1000 feet
northeast of the l-70 / HwY 6
lnterchange southwest of the Town of
Parachute, in SESE, Section 14, T7S,
R96W of the 6th PM.
The facility is accessed by private
roadways off of State HighwaY 6
Frontage Road.
The property is zoned (R) Rural
PROJECT INFORMATION AND STAFF COMMENTS
I. DESCRIPTION OF THE PROPOSAL
The Applicant is requesting a minor modification to the Caerus SWD 1-14 lnjection Well,
Small in order to change the approved site plan. Specifically, the request is to relocate
the injection well location as well as the water tanks associated with the well. The new
location remains on the COGCC approved well pad location.
1
No other changes are proposed
II. BACKGROUND - AUTHORITY - APPLICABLE REGULATIONS
The original approval for the lnjection Well, Small was granted by a Directors
Determination issued October 10,2014 (see attached). The Land Use Change Permit
has not been issued to date as the Conditions of Approval have not been satisfied. As a
result, this Amendment would only impact the October 10,2014 Directors Determination
and would not impact any issued Land Use Change Permits'
Section 4-106 of the Garfield County Land Use and Development Code sets forth the
process for requesting an amendment to an existing Land Use Change Permit. Section
4-106(C) contains criteria for determining if the requested amendment is a Minor
Modificaiion. ln accordance with the Land Use and Development Code a Pre-
Application conference was held and the Director of the Community Development
Department will make a formal determination as to whether the Application meets the
minor mod ification criteria.
III. REVIEW CRITERIA - STAFF ANALYSIS
The Minor Modification criteria from Section 4-106(C) are shown below with Staff
analysis shown in italics.
Minor Modifications are those that deviate from standards or rearrange/reconfigure
elevations, structures, parking areas, landscape areas, drainage facilities, utilities, or
other site improvements in an approved Land Use Change Permit, including
Subdivisions, and that meet all of the following criteria as applicable:
1. Comply with all requirements of this Code;
The proposed amendment does not alter the facility in a way that would create
conflicts with the requirements of the code.
2. Do not conflict with the Comprehensive Plan;
The proposed amendment does not conftict with the Comprehensive Plan
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3. Do not change the character of the development;
The character of the facility is not changed by the proposal as it remains an
tnjection Well, Small. es ine changes only atter the site plan for the lniection
We1 within a COGCC approved wett pad location, no changes fo the delivery
method, impact area or water storage capacity will be impacted.
Do not alter the basic relationship of the development to adjacent property;
Based on the information provided in the Application, the basic relationship of the
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facility to adjacent properties wilt remain unchanged. No changes fo fhe access
or to the outward appearance of the facitity are proposed. The new configuration
sefs fhe injection'well facitity back from the public right of way and due to
topographi tne visual impact witt be reduced by the proposed layout.
Do not change the uses Permitted;
The proposal does not change the permitted use.
Do not require amendment or abandonment of any easements or rights-of-way;
No changes to easemenfs or right-of-ways are required or proposed.
Do not increase the densitY;
The proposa/ does not involve any increase in density either in terms of
residentia/ uses of which there are none or in terms of number of wells / storage
capacity.
Do not increase the zone district dimensions to an amount exceeding the
maximum dimension in the applicable zone district in Table 3-201; and
There is no increase or change in the zone district dimension standards.
Do not decrease the amount of the following to an amount below the minimum
required in the applicable zone district:
a. Amount of dedicated OPen Space;
b. The size of or change in the locations, lighting, or orientation of originally
approved signs; and
c. Any zone district dimensions in Table 3-201.
No reduction in open space is proposed. No changes fo any signs are proposed.
No change in the zone district dimensions are proposed'
IV. ADDITIONAL STAFF ANALYSIS
1. The original approval reflected in the October 10,2014 Directors Determination
was adopted following appropriate public notice.
2. The Application has been referred to the County Attorney's Office for comment.
3. No changes to the overall character of the facility is proposed. No increase in
impact area or water storage capacity is proposed.
4J
4. The facitity shall be required to maintain compliance with all existing conditions of
the original Direttors Determination approval including compliance with all applicable
COGCC permits.
V. RECOMMENDATION
The Staff analysis supports a finding that the Application meets the criteria contained in
Section 4-106(C) for a Minor tvlodification. Section 4-106 (C) states that upon finding it
a minor modification the Director may approve, approve with conditions or deny the
amendment and provide written notice to the Applicant. Although not altered by this
application, the following Conditions of Approval should supersede those approved by
the Director on October 10,2014.
Conditions Prior to lssuance
1. An impervious liner made of a membrane or bentonite shall be installed as a
secondary containment to prevent potential contamination of high ground
water in t-he area. Construction drawings shall be submitted and reviewed by
the Garfield County Contract Engineer demonstrating the type and installation
method for the liner prior to issuance of the Land Use Change Permit.
2. The Applicant shall provide an explanation as to the permitting status of the
Storm Water Management Plan prior to issuance of the Land Use Change
Permit. This explanation shatl be reviewed by the Garfield County Contract
Engineer prior to issuance of the Land Use Change Permit.
Other Gonditions
3. That all representations made by the Applicant in the application shall be
conditions of approval, unless specifically altered by the Board of County
Commissioners.
4. That the operation of the Caerus SWD 1-'t4 Injection Well, Small shall be
done in accordance with all applicable Federal, State, and local regulations
governing the operation of this type of facility.
S. The facility shall maintain compliance with CDPHE Storm Water Management
Permits, brainage and Grading Plans, Reclamation and Erosion Control
Plans for the site.
6. The Applicant shall maintain all required CDPHE permits for the facility
including any applicable air quality, APEN permits'
7. lmplementation of the Applicant's Dust Control Plan is required.
4
8. Diffuse Knapweed has been identified in the vicinity of the site. The Applicant
and Operator shall monitor and control any weeds, including Diffuse
Knapweed, in the vicinity of the site and take measures to control State and
County listed noxious weeds on at least an annual basis.
g. The Applicant shall maintain all required COGCC permits and forms for the
facility and shall comply with all conditions or requirements of said permits
and forms.
10.The facility shall maintain compliance with COGCC Noise
Standards/Regulations and the facility shall be required to utilize an electric
pump as represented. lf future compliance issues are identified the Applicant
shali provide noise mitigation in order to achieve compliance along with a
technical evaluation by a qualified professional to confirm compliance.
11.The Applicant shall comply with all SPCC Plan provisions and shall keep the
plan current and updated for any changes to the facility.
12.The facility shall maintain compliance with Section 7-306 Lighting, with all
lighting to be directed inward and downward toward the interior of the site.
Ficilities and storage tanks shall be painted a non-glare neutral color to
lessen any visual imPacts.
13.The Emergency Response Plan provided with the Application submittal
including contact information shall be kept updated.
14.The Applicant shall comply with their Noxious Weed lvlanagement Plan
including the best management practices.
15.Hours of operation forthe injection well pump is effectively 24 hours a day.
However other support or maintenance activities should be conducted
between the hours of 7 a.m. and 7 p.m.
16.The subject site shall be limited to the previously disturbed portion of the site.
Total subject site area shall not exceed 6,320 square feet.
17.Totat water storage shall not exceed 5,000 bbl., including any condensate
tanks.
5
Caerus Oil & Gas Ll,C
PROPOSED SIIE PLAN FOR
NOLTE #14-796
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EXHIBIT "A"
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EXH!BIT
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Garfield Coulnu
October 10,2014
Shauna DeMattee
Director of Business Development
Progressive Consulting
P.O. Box 863
Lafayette, CO 80026
DIRECTOR DETERMINATION - Puckett Land Co. (Operator- Caerus
Piceance, LLC), Nolte SWD 1-14 lnjection
Well, Small (File GAPA-7985)
Dear Ms. DeMattee
This letter is being provided to you as the authorized representative for Puckett
Land Co. and Caerus Piceance, LLC in regard to the General Administrative
Review Application for an lnjection Well, Small, known as the Nolte SWD 1-14
lnjection Well and as represented in Exhibit A. The proposed use is located
southwest of the Town of Parachute of the US 6 Frontage Road on property also
known by Assessor's Parcel No. 240913300013.
The Director's Decision on the Application is based on the following findings and
subject to the Applicant's representations and conditions of approval.
1. That proper public notice was provided as required for an
Administrative Review Land Use Change Permit.
2. That for the above stated and other reasons the proposed Land Use
Change Permit for the Caerus Nolte SWD 1-14 lnjection Well, Small is
in the best interest of the health, safety, convenience, order, prosperity
and welfare of the citizens of Garfield County.
1
3. That with the adoption of conditions, the application is in general
conformance with the 2030 Comprehensive Plan, as amended.
4. That with the adoption of conditions the application has adequately met
the requirements of the Garfield County Land Use and Development
Code, as amended.
A Directo/s Decision is hereby issued approving the Application subject to the
following conditions:
Conditions Prior to lssuance
1. An impervious liner made of a membrane or bentonite shall be
installed as a secondary containment to prevent potential
contamination of high ground water in the area. Construction drawings
shall be submitted and reviewed by the Garfield County Contract
Engineer demonstrating the type and installation method for the liner
prior to issuance of the Land Use Change Permit.
2, The Applicant shall provide an explanation as to the permitting status
of the Storm Water Management Plan prior to issuance of the Land
Use Change Permit. This explanation shall be reviewed by the Garfield
County Contract Engineer prior to issuance of the Land Use Change
Permit.
Other Conditlons
3. That all representations made by the Applicant in the application shall
be conditions of approval, unless specifically altered by the Board of
County Commissioners.
4. That the operation of the Caerus SWD 1-14 lnjection Well, Small shall
be done in accordance with all applicable Federal, State, and local
regulations governing the operation of this type of facility.
5. The facility shall maintain compliance with CDPHE Storm Water
Management Permits, Drainage and Grading Plans, Reclamation and
Erosion Control Plans for the site.
6. The Applicant shall maintain all required CDPHE permits for the facility
including any applicable air quality, APEN permits,
7. lmplementation of the Applicant's Dust Control Plan is required.
2
8. Diffuse Knapweed has been identified in the vicinity of the site. The
Applicant and Operator shall monitor and control any weeds, including
Diffuse Knapweed, in the vicinity of the site and take measures to
control State and County listed noxious weeds on at least an annual
basis.
9. The Applicant shall maintain all required COGCC permits and forms for
the facility and.shall comply with all conditions or requirements of said
permits and forms.
10.The facility shall maintain compliance with COGCC Noise
Standards/Regulations and the facility shall be required to utilize an
electric pump as represented. lf future compliance issues are
identified the Applicant shall provide noise mitigation in order to
achieve compliance along with a technical evaluation by a qualified
professional to confirm compliance,
11.The Applicant shall comply with all SPCC Plan provisions and shall
keep the plan current and updated for any changes to the facility.
12.The facility shall maintain compliance with Section 7-306 Lighting, with
all lighting to be directed inward and downward toward the interior of
the site. Facilities and storage tanks shall be painted a non-glare
neutral color to lessen any visual impacts.
13.The Emergency Response Plan provided with the Application submittal
including contact information shall be kept updated.
14.The Applicant shall comply with their Noxious Weed Management Plan
including the best management practices.
15. Hours of operation for the injection wel! pump is etfectively 24 hours a
day. However other support or maintenance activities should be
conducted between the hours of 7 a.m, and 7 p.m.
16,The subject site shall be limited to the previously disturbed portion of
the site. Total subject site area shall not exceed 6,320 square feet.
17.Total water storage shall not exceed 5,000 bbl., including any
condensate tanks.
This Director's Determination will be forwarded to the Board of County
Commissioners for a period of 10 days so that they may determine whether or
not to call up the application for further review. Once this time period has passed
with no request for review or public hearing, and provided all relevant conditions
of approval have been resolved the Land Use Change Permit will be issued.
3
Please contact this department if you have any questions.
Sincerely,
(ts
F,ki:JtFr. .{trff*J
Director of Community Development Department
CC: Board of County Commissioners
Kelly Cave, Assistant County Attorney
4
Exhibit A
Site Plan
Nolte swD l-14
Injection Well Pad
Caerus Plcoanee LIf,
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Staff Report Exhibits
Puckett Land Co.
Administrative Review
Applicant is Caerus Piceance, LLC.
October 10,2014
(File GAPA-7985)
Exhibit Letter
(Numerical)
Exhibit Description
1 Public Hearinq Notice lnformation
2 Return Receipts from Mailing Notice
3 ReferralComments from Colorado Parks and Wildlife (dated July 16,
2014\
4 Referral Comments from Garfield County Road and Bridge (dated
September 18,2014\
5 Referral Comments from Mountain Cross Engineering (dated October 8,
2014\
6 Referral Comments from Garfield County Vegetation Management
(Dated October 7,2014)
7 Referral Comments from Garfield County Public Health (Dated October
2,2014\I Referral Comments from Garfield County Oi
September 19, 2014)
and Gas Liaison (Dated
I Referral Comments from the Battlement Mesa Service Association's Oil
and Gas Committee (Dated September 30. 2014)
10 Referral Comments from the Battlement Concerned Citizens (Dated
September 30, 2014)
11 Memorandum from Kirby Wynn, Garfield County Oil and Gas Liaison
and select documents (Dated July 3, 2014)
12 Referral Comments from the Water Resources Engineer (Dated October
1.2014\
13 Refenal Comments from Scott Hoyer of Colorado Parks and Wildlife
REQUEST
PROPERTY OWNER
APPLICANT
ASSESSOR'S PARCEL }
PROPERTY SrZE
LOCATION
ACCESS
EXISTING ZONING
Director Determination
1A110114
File No. GAPA-7985
DP
General Administrative Land Use Change
Permit for a Small lnjection Well Facility
Puckett Land Co.
Caerus Piceance, LLC.
24091 330001 3
The facility will be located on a 6,320 square
foot site which is within a COGCC approved
well pad location and within an overall 147.29
acre parcel.
The property is located southwest to the Town
of Parachute and Grand Valley High School,
approximately 1000 feet northeast of the l-70 /
Hwy 6 lnterchange southwest of the Town of
Parachute, in SESE, Section 14, T7S, R96W
of the 6rh PM.
The facility is accessed by private roadways
off of State Highway 6 Frontage Road.
The property is zoned (R) Rural
PROJECT INFORMATION AND STAFF COMMENTS
I. GENERAL PROJECT DESCRIPTION
The Application is requesting an Administrative Land Use Change Permit for an
lnjection Well, Small, known as the Nolte SWD 1-14 injection well. The facility will be
located on 40'x 158'(6,320 sq.ft.) within an existing COGCC approved well pad. The
injection wells proposed to be located on the Nolte #14-796 well pad is to serve 17
natural gas well (18 total wells including the injection well) on this same pad as well as
13 wells from the neighboring lsland Ranch #13-796 well pad. No wator is to be
injected during completion operations as this water will be re-used at that time. At full
development, the well is anticipated to inject 1,200 bbls of water daily. The proposed
injection requires COGCC Form 2 (Application for Permit-To-Drill, Deepen, Re-Enter,
1
Or Recomplete), 31 (Underground lnjection Formation Permit Application) and 33
(l njection Well Permit Application).
The Facility will include the following equipment:
. One injection well and electric pump
. Approximately 5-10 Water Storage Tanks at 500 bbls each with a total capacity less
than 5,000 bbls.r Pipeline infrastructure for water deliveryo Pump house building
Vicinity Map
Produced water from the Nolte #14-796 well pad (location of injection well) and lsland
Ranch #13-796 facilities will be transported to the site entirely by pipeline. Traffic
generation is expected to be one roundtrip per day for monitoring and repairs. A new
pipeline is expected to be installed from the lsland Ranch well pad to the Nolte well pad
with an overall length of approximately 2500 ft. The applicant has represented that the
new pipeline will falls outside of the Garfield County requirements for permitting.
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Location Map for lsland Ranch Location and Proposed Pipeline
The Facility will be monitored typically during daylight hours by a Caerus Employee. A
dust mitigation program will be implemented and CDPHE Air Quality permits will be
obtained, as appropriate.
Storm water management improvements and Best Management Practices are already
implemented and/or planned for the site. A Storm Water Management Plan (SWMP) is
understood to be in place, however, demonstration or explanation as to the permitting
status for this Plan has not been provided. As a condition of approval, staff
recommends asking for an explanation of where the SWMP is in the State CDPHE
permitting process.
The Application also includes an area wide Spitl Prevention Control and
Countermeasures Plan. Containment as required by COGCC will be implemented for
the production water storage tanks associated with the injection well. The projected
storage amount is consistent with the standard for a small injection well facility (less
than 5,000 bbls).
3
II. LOCATION . SITE DESCRIPTION
The site is currently a developed COGCC well pad planned for approximately 18 wells.
Land uses within 1500 ft. include residential, lnterstate 70, agricultural uses and natural
gas extraction.
The site slopes down moderately from the Frontage Road to the Colorado River with
the well pad graded to COGCC standards.
Native vegetation surrounding the site is generally sagebrush. No additional native
vegetation will be removed for the proposed facility and the placement of the project on
an existing well pad will minimize additional impacts. The site is located approximately
1500 ft. from the Colorado River and 500 ft. from l-70.
Surrounding Property Uses
Grand Valley High
School - 4300 ft.
away from Well
l-70 - 500 ft.
away from We
Approx. Location
of lsland Ranch
WellPad LocationProposed
Nolte SWD 1-
14lnjection
WellLocation
/ trtolte 14-796
Battlement Mesa
PUD - 4500 ft.
away from Well
Subject Parcel -
Puckett Land Co.
Colorado River -
1500 ft, away
from Well
4
Nolte SWD 1-14 lnjection
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III. PUBLIC COMMENTS AND REFFERAL AGENCY COMMENTS
Public Notice was provided for the Director's Determination in accordance with the
Garfield County Land Use and Development Code as amended and included mailing
notice to all property owners within 200 ft. and any mineral rights owners on the
property, The Applicant has provided evidence of compliance with the notice
requirements. Comments from referral agencies, County Departments, and the public
are summarized below and attached as Exhibits.
1. Garfield County Consulting Engineer, Chris Hale, Mountain Cross Engineering (See
Exhibit 5):. An impervious liner is necessary which could be either a membrane or
bentonite. Construction drawings for the liner should be provided.r Details on the pump building and equipment should be provided in order to
determine if further submittals or evaluation is necessary depending on pumps,
noise, emissions, etc.. SWMP permitting was not mentioned in the application. The applicant should
provide a response as to the status of SWMP permitting for the site.
2. Garfield County Road and Bridge Department, Dan Goin District 3 Foreman (See
Exhibit 4):. lndicated that since direct access is on a State highway, Road and Bridge has
no comments.
3. Garfield County Vegetation Manager, Steve Anthony (See Exhibit 6):o The noxious weed inventory, reclamation plan and proposed seed mixes are
acceptable as they are regulated by the COGCC.o Diffuse Knapweed is in the vicinity of the site and it is requested that the
applicant and operator monitor and control any weeds in the vicinity on an
annual basis.
4. Garfield County Environmental Health, Morgan Hill(See Exhibit 7):
o lnstall bentonite clay layer to be installed under the pad, if possible, to prevent
contamination of groundwater.
o Applicant should apply for any applicable APEN or Air Permit if necessary.. Applicant should control fugitive dust and other nuisance conditions that could
occur onsite.o The Operator should pay special attention to the wells capacity in order to
prevent earthquakes.
5. Colorado Parks and Wildlife (See Exhibit 13):o Noted the location is within a mapped area for mule deer, elk and black bear.o Requests that sound mitigation be utilized for the proposed injections wel! in
order to keep sound levels below COGCC 800 rules.
6
6. Colorado Water Resources Engineer (See Exhibit 12):. Submitted a letter indicating that they had no comments at this time.
7. Battlement Concemed Citizens (See Exhibit 10):
. Noted concerns with earthquakes caused by this and other injection wells in the
area.
. Requests that Caerus conduct seismic testing prior to establishment of the
injection well and to monitor seismic activity after installation.
8. Garfield County Oil and Gas Liaison (See Exhibit 8):
o lndicated that there are no concerns or comments as long as total tank volume
remains 5,000 bbls or less including any condensate tanks,
9. Battlement Mesa Service Association's Oil and Gas Committee (See Exhibit 9):
o Support the use of pipeline infrastructure to deliver water.
10.Other referral agencies that did not submit comments include: (a) the Colorado
Department of Public Health and Environment Water Quality Division and Air
Quality Division; (b) Town of Parachute; (c) Grand Valley Fire Protection District; (d)
School District 16; (e) Battlement Mesa Metro District; (f)Colorado Department of
Transportation.
IV. STAFF COMMENTS AND ANALYSIS
ln accordance with the Land Use and Development Code, the Applicant has provided
detailed responses to the Submittal Requirements and applicable sections of Article 7,
Divisions 1, 2, and 3, including Section 7-1001 lndustrial Use Standards. The
Application materials include an lmpact Analysis and related consultant reports,
technical studies, and plans.
7-101 - 103: Zone District Reoulations. Comprehensive Plan & Compatibilitv
The proposed use demonstrates generat conformance with applicable Zone District
provisions contained in the Land Use and Devetopment Code and in particular Article
lll standards forthe RuralZone District.
Regarding comptiance with Section 7-102, The Comprehensive Plan 2030 designates
the site as RMH (Residential Medium High Density). Excerpts from the Land Use
Description Section Chapter 2 and Section 8, Natural Resources and Section 9,
Mineral Extraction are provided below.
7
Chapter 2 - Land Use Desrgnations
Resrdenfral Medium High (RMH): Small farms, esfafes, and clustered
residential subdivision; density determined by degree of clustering and
land preserved in open condition.
Secflon I - Natura/ Resources
/ssues
*The county maintains high air quality standards, however there may be a
propensity for air pollutants fo exlsf in the wesfern part of the county
Goa/s1. Ensure that natural, scenic, ecological, and critical wildlife habitat
resources are protected and /or impacts mitigated.4, Ensure the appropriate reclamation of land after extraction
processes.
Policies1. The County will encourage and e,ooperate with the protection of
critical habitat including state and federally protected, threatened, or
endangered species.
Secfrbn 9 - Mineral Ertraction
Goals1. Ensure that mineral extraction is regulated appropriately to promote
responsib/e development and provide benefit to the general public.
2. Ensure that mineral extraction activities mitigate their effects on the
natural environment, including air qualt$, water quality, wildlife habitat or
i m porta nt vi su a I resources.
3. ln working with mineral extraction projects, the county will protect the
public health, safety and welfare of its citizens.
Policies2, Mineral resource extraction activities will protect critical wildlite
habitat as identified by state and federal agencies. Development within
fhese designations fhaf cannot be designed, constructed and conducted
so as to have a minimum adverse impact upon such habitat or these
wildlife species shall be discouraged.4. Facilities that are appurtenances fo oil/ gas development activities
(compressors, etc.) are considered appropriate in allland uses so /ong as
they meet the respective mitigation requirements of the ULUR to maintain
compatibility with surrounding land uses.
8
Town of
Parachute
Subiect Site
Open Space/Publrc Land
Res H
Battlement
Mesa
Lands
The location and design of the proposed facility is in general conformance with the
Cornprehensive Plan Policies subject to proper mitigation of impacts.
Com rehensive Plan Desi nation
The Application has also provided information on neighboring land uses indicating the
general character of the area. The request demonstrates general compatibility with
adjoining uses provided proper mitigation is implemented and compliance with
conditions and COGCC regulations are maintained.
7-104 & 105: Source of Water & Waste Water Svstems
The Application represents that the facilities will be operated with only occasional staff
activities. The proposal demonstrates that the uses will be adequately served by
provision of water in individual staff vehicles and provision of portable toilets on site per
OSHA standards.
7-106: Public Utilities
The site will be served with electricity for the operation of the electric pump for the
injection well. Service will be to the pump building.
9
7-107: ..Access & Roadwavs
The Applicants access their property from State Highway 6 Frontage Road and via a
private access road. The applicant has provided a detailed analysis of the roadway
including engineering representations. The submittal reflects compliance with the
County's Roadway Standards as contained in Table 7-107. Dust control and ongoing
maintenance are considerations that should be included as conditions of approval.
The Applicant's Traffic Study identifies that truck tratfic associated with the injection
well will be approximately one round trip per day in a standard pickup truck for
maintenance and monitoring.
The Applicant provided a State Highway Access Permit. Following conversations with
the Colorado Department of Transportation, Staff understands that the access is legal
and adequate for the proposed use. No requirements for County or additional State
permitting were noted and no deficiencies identified.
7-108: Natural Hazards
The Application provides information on natural hazards including infonnation on soils,
geology, and slopes. The information supports a determination that the proposed use
is not subject to significant natural hazard risks.
7-109: Fire Protection
The Application includes an Emergency Response Plan for the site. The only
structure proposed for the facility is the electric pump building and produced water
storage tanks. No comments were received from the Grand Valley Fire Protection
District.
7-201: Aqricultural Lands
With no new disturbed areas, no additional impacts on nearby agricultural lands are
anticipated
7-202: Wildlife Habitat Areas
The Appticant has provided a Wildlife and Sensitive Areas Report, completed by CK
Associates, dated September 2014. The report indicates that "The installation of a
SWD ("Salt Water Disposal") on the project area does not require any additional
surface disturbance. Therefore, no impacts to wildlife species, vegetation or wetlands
are anticipated. Adequate perimeter containment will be maintained around the project
area which will prevent surface water runoff into the nearby Colorado River thereby
preventing any impacts to this water resource or its adjacent wetland habitats." The
report also addressed threatened, endangered or candidate species and noted a
number of species that may be found in Garfield County. The report concludes that no
10
species are expected in the area of the site as habitat conditions are not appropriate.
The study notes that the project is placed within the boundaries of an existing
development and therefore avoids substantive impacts on habitats.
7-203: Protectio of Water Bod es
Potential impacts on water bodies has been addressed by the Storm Water
Management Plan, drainage plans, and Spill Prevention Containment and
Countermeasures Plans for the site. The site location is approximately 1500 ft from the
Colorado River. ln addition, the Applicant has identified three unnamed streams within
the vicinity of the well pad location, all of which are over 300 ft from the subject site. lt
is Staff's opinion that distance from these features along with the engineered drainage
plans for the site mitigate the potential for impacts.
7-204: Drainaoe and Erosion (Stormwater)
The Applicant has provided a copy of the Post Construction Stormwater Management
Program and Best Management Practices manual applicable to the site. As noted
previously, the County Engineer and Public Health Department suggest an
impermeable membrane or bentonite liner with the secondary containment. Staff
suggests the inclusion of an impermeable liner as a condition of approval.
7-205 Environmental Qualitv
The Applicant has represented that the use will not be subject to permitting through the
Golorado Air Pollution Control Division. The condensate tanks currently on site are
11
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used in conjunction with well production and are regulated by COGCC and CDPHE. A
condition oiapproval should call for the Applicant to obtain and keep current all permits
as requireO Ui tne CDPHE and maintain compliance with all conditions contained
therein. Stoim Water Management Permits, lnstallation of Best Management
Practices, SPCC Plans, and Reclamation and Erosion Control Plans address
protection of water quality.
7-206: .Wildfire Hazards
Only a singte pump house structure is proposed in addition to the water storage tanks
and no comments were received from the Fire Protection District. The facility is not
located within a "very high" wildland fire susceptibility designation according to the
Community Wildfire Pioteition Plan. ln addition, no fuels or other combustible material
will be stored onsite and no buildings will be constructed onsite with shake roofs.
7-207: Natural and Geoloqic Hazards
The Applicant has represented that no significant hazards to the proposed facility exist
and the site is not located within a flood plain. lt was noted that the area is subject to
high run-on / run-off potential and therefore conformance to the Stormwater
Management Plan and SPCC are of particular importance. Garfield County hazard
mapping identified the parcel within an area of high water table and therefore septic
constraints.
The Garfield County Public Health Department and the County Engineer noted that an
impervious liner made of a membrane or bentonite should be installed to prevent
potential contamination of high ground water in the area. Staff recommends that this be
included as a condition of approval and that construction drawings be submitted
demonstrating the type and instatlation method for the liner prior to issuance of the
Land Use Change Permit,
The Battlement Mesa Concemed Citizens identified their concern for increased
earthquake risk due to the injection well. This topic was previously researched by the
Garfield County Oil and Gas Liaison (See Exhibit 11). The memo includes an analysis
of the issue by COGCC and mapping of injection wells in the vicinity of Battlement
Mesa and the Town of Parachute. The COGCC analysis indicates the permitting,
rules, policies, and safeguards they require in regard to injection wells. Compliance
with all COGCC permits and forms along with conditionslrequirements is included as
recommended Condition #9. Additional information from the United States Department
of the lnterior, Geological Survey has been provided and includes a technical article on
seismic risk posed by wastewater disposal.
t2
7-208: Reclamation
The Applicant has included a reclamation plan that addresses re-vegetation and
reclamation issues. A reclamation bond with the State is currently in place and shall be
maintained to include well pad reclamation associated with the injection wellfacility.
7-301 & 302.i. Comoatible Design, Parkino. and Loadinq
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: Landscapinq
As an industrial use landscaping submittals and standards are not applicable to the
proposal.
7-304: Liqhtino
No permanent lighting is proposed. Any lighting shall be required to meet the County
standards for being down directed, shielded, and oriented toward the interior of the
site.
7-305 Snow Storaqe
Adequate portions of the site plan are available for snow storage and can be
accommodated by the drainage and storm water management plans.
7-306 Trailg
Trails standards are generally not applicable based on the industrial nature of the
proposal and surrounding uses.
7.1001 INDUSTRIAL USE STANDARDS
The Application represents that the facility will comply with all the lndustrial Use
Standards contained in Section 1001. The Application contains a variety of documents
to support comptiance and the following summary addresses key issues.
o The facility is located on a wetl pad location. The equipment for the injection well
will be aesthetically similar to that contained on the rest of the well pad.
o Hours of operation for the injection well pump are effectively 24 hours a day.
However other support or maintenance activities should be conducted between the
hours of 7 a.m. and 7 p.m.
o All industrial products and wastes will be stored in accordance with all applicable
state and federal regulations.
13
a No other nuisance or ground vibration hazards are anticipated based on type of
use.
V. ADDITIONAL STAFF ANALYSIS
1. The pipelines to serve the injection well will comply with the County's
permitting requirements and have been represented to be exempt. Pipelines
that are less than 2 miles in length and 12 inches or less in diameter are
exempt from the County permitting requirements.
2. The Apptication includes documentation that the water for injection is from
non-tributary sources addressing any potential Division of Water Resources
concerns.
VI. SUGGESTED FINDINGS
i. That proper public notice was provided as required for an Administrative Review
Land Use Change Permit.
2. That for the above stated and other reasons the proposed Land Use Change
Permit for the Caerus Nolte SWD 1-14 lnjection Well, Small is in the best interest of the
health, safety, convenience, order, prosperity and welfare of the citizens of Garfield
County.
3, That with the adoption of conditions, the application is in general conformance
with the 2030 Comprehensive Plan, as amended.
4. That with the adoption of conditions the application has adequately met the
requirements of the Garfield County Land Use and Development Code, as amended.
VII. RECOMMENDATION
The following recommended conditions of approval are provided for the Directors
consideration.
Conditions Prlor to lssuance
1. An impeMous liner made of a membrane or bentonite shall be installed as a
secondary containment to prevent potential contamination of high ground
water in the area. Construction drawings shatl be submitted and reviewed by
the Garfield County Contract Engineer demonstrating the type and
installation method for the liner prior to issuance of the Land Use Change
Permit.
74
2. The Applicant shall provide an explanation as to the pennitting status of the
Storm'Water Management Plan prior to issuance of the Land Use Change
Permit. This explanation shall be reviewed by the Garfield County Contract
Engineer prior to issuance of the Land Use Change Permit.
Other Conditions
3. That all representations made by the Applicant in the application shall be
conditions of approval, unless specifically altered by the Board of County
Commissioners.
4. That the operation of the Caerus SWD 1-14 lnjection Well, Small shall be
done in accordance with atl applicable Federal, State, and local regulations
governing the operation of this type of facility.
5. The facility shall maintain compliance with CDPHE Storm Water
Management Permits, Drainage and Grading Plans, Reclamation and
Erosion Control Plans for the site.
6. The Applicant shall maintain all required CDPHE permits for the facility
including any applicable air quality, APEN permits.
7. lmplementation of the Applicant's Dust Control Plan is required.
8. Diffuse Knapweed has been identified in the vicinity of the site. The Applicant
and Operator shall monitor and control any weeds, including Diffuse
Knapweed, in the vicinity of the site and take measures to control State and
County listed noxious weeds on at least an annual basis.
L The Applicant shall maintain all required COGCC permits and forms for the
facility and shall comply with all conditions or requirements of said permits
and forms.
10.The facility shall maintain compliance with COGCC Noise
Standards/Regulations and the facility shall be required to utilize an electric
pump as represented. lf future compliance issues are identified the
Applicant shall provide noise mitigation in order to achieve compliance along
with a technical evaluation by a qualified professional to confirm compliance.
11.The Applicant shall comply with all SPCC Plan provisions and shall keep the
plan current and updated for any changes to the facility.
12.The facility shall maintain compliance with Section 7-306 Lighting, with all
15
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.
13.The Ernergency Response Plan provided with the Apptication submittal
including contact information shall be kept updated.
14.The Applicant shall comply with their Noxious Weed Management Plan
including the best management practices
15. Hours of operation for the injection well pump is effectively 24 hours a day.
However other support or maintenance activities should be conducted
between the hours of 7 a.m. and 7 p.m.
1 6. The subject site shall be limited to the previously disturbed portion of the site.
Total subject site area shall not exceed 6,320 square feet.
17.Total water storage shall not exceed 5,000 bbl., including any condensate
tanks.
16
EXHIBIT
Garfield County
PUBTIC HEARING NOTICE INFORMATION
Please check the approprlate boxes below based upon the nottce that was conducled for your public
hearing. ln additlon, please inltlal on the blank line next to the statements if they accurately reflect the
described actlon.
d My appllcatlon requlred wrltten/malled notice to adJacent property owners and mlneral
owners.
W Malled noilce was completed on the l&'h day of ,Sool"mho.2014
* All owners of record wilhln a 200 fool radlus of the subJect parcel were ldentified as
shown in the Clerk and Recorder's office at least 15 calendar days prior to sending
notlce,
& All owners of mlneral lnterest in the subJect property were identified through records in
the Clerk and Recorder or Assessor, or through other means llstl
Please attach proof of certified, return recelpt requested mailed notice,
tl My appllcatlon requlred Publtshed nottce.
Notlce was published on the _ day of 20L4.
Please attach proof of publicatlon in the Rifle Cttizen Telegram.
n My application requlred Postlng of Notlce.
Notlce was posted on the _ day of 2014.
Notlce was posted so that at least one sign faced each adJacent road right of way
generally used by the publlc.
I testlfy that the above lnformatlon ls true and accurate.
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David Pesnichak
From:
Sent:
to:
Subject:
Dan Goin
Thursday, September L8,201,4 8:00 AM
David Pesnichak
Nolte SWD L-l4lnjection Well
David
I do not see any concerns for Road and Bridge with this permit there access is from Hwy 6 and not a county rd
lf you have any questions or concerns call me.
970-309-1856
Thanks
Dan
MOUNTA
DNGINEERINC, INE.
Civil and Hnvironmcntal Constrlting and Deslgn
October 8, 2014
Mr. David Pesnichak
Garfield County Planniug
108 8th Street, Suite 401
Glenwood Springs, CO 81601
RIi: ltcvicrv of Nolte SWD l-14 Injcction Well: CAPA-7985
f)ear David:
This office has perfbrrned a leview ol the documents provided tbr the Administrative Pemrit
Review application of the Nolte SWD l-14 Injection Well fbr Pucketl Land Co. 'l'he subrnittal
lvas fbund to be thorough and well olganized. The review gcneratecl the fbllowing comments:
l. Concerning the secondary contairunent of the storage tanks. An impervious liner is
appropriate. Bentonite and/or a mernbrane linel ale typically adequate. The Applicant
should provide construction cletails and/or specifications conceming the liner desigrr.
2. The Applicant should address the equipment to be housed lvithin the proposed building,
This rnay require other submittals and/or evaluations conceming noise, crnissions, etc.
depending on purnps, conlpl'essors, generators, or other equiprnent to be housed rvithin.
3. The Applicant should provide evictence of stonnwater management permitting with the
CDPHE if the site plan is part of a lalger overall plan if the disturbance of that larger plan
exceeds one acre.
Feel fiee to call if you have any questions or conrments"
Sincerely,
Mountain Cross
r)
PE
826 % Grand Avenue, Glenwood Springs, CO B'1601
P; 970.945.5544 F: 970.945.5558 www.rnotrntaincross-er1g.com
Guffield Co unu
Vegetation Mqnagement
October 7,2014
David Pesnichak
Garfield County Community Development Department
RE: Nolte SWD 1-14 lnJection Well GAPA-7985
Daar Dave,
Thanks for the opportunity to comment
Noxlous Weeds
The noxious weed inventory submitted in the application ls acceptable.
The County and State listed noxious weed, Diffuse knapweed, and has been found about 2 miles west of the site. Staff
reguests ltiat the applicant rnonitor the site annually for Diffuse knapweed and treat on an as needed basis'
Revogetatlon
The Reclamatton Plan and proposed seed mixes are acceptable. The Colorado Oiland Gas Conservation Commission
regulates reclamation on his site.
Please let me know if you have any questions.
Sincerely
Steve Anthony
Garfield County Vegetation Manager
0375 County Road 352, Bldg 2060
Rlfle, CO 81650 Phone: 970-945-1377 x 4305 Fax: 970.825.5939
Garfield Coun$
Public Health
195 W. 14'h Street
Rifle, CO 81650
(970) 625-5200
Garfield County Community Developmenl
108 8th Street
Glenwood Springs, CO 81601
Attn: David Pesnichak
2014 Blake Avenue
Glenwood Springs, CO 81601
(970) 945-6614
October 2,2014
Hello David,
My comments for the Notle SWD 1-14 lnjection Well Administrative Permit Application are as
follows:
It is much easier to review an application electronically that has tabs broken out for each
section rather than scrolling through a very large document. ln the future, please break
down sections by tab either on the CD or in the PDF itself.
Water Qualitv: Despite the fact that no waters of the US occur within the project area,
the close proximity of the site to the Colorado River and other wetland areas indicates
that it should be constructed and operated in a manner that prevents contamination.
Public Health recommends a bentonite clay layer be installed under the pad if possible,
so that any spills are contained within the pad and not allowed to seep into groundwater.
Air qualitv and Nuisance Conditions:o The applicant mentions that the air quality should not be reduced below
acceptable levels established by the Colorado Air Pollution Control Division.
However, I could not find in the application (perhaps because of the format)
where there was mention of if they had contacted the APCD about the need for
either an Air Pollution Emission Notification (APEN) or an Air Permit. Due to the
number of tanks on the site, they could be above the threshold for emissions that
would require them to get a permit. I contacted the APCD about this issue and
have included their email as an attachment.o I did not see a specific mention of Nuisance Conditions in the lmpact Analysis.
The application should address how dust, odors, and glare, and vibration will be
controll'ed during the construction of the site, drilling of the wells, and operation of
the facility.
Earthquakes: while the science behind this issue is still somewhat up in the air, reports
of injection wells leading to increased seismic activity have been becoming more
prominent recently. Operators of the injection well should pay close attention to the
well's capacity to prevent any earthquakes.
Thank you,
filnf.ao ffi tr/4ft
Morgan Hill
Environmental Health Specialist lll
Garfield County Public Health
Garfield County Public Health Department - working to promote health and prevent disease
From: Hewitson - CDPHE, lngrid [ingrid.hewitson@state.co'us]
Sent: Thursday, October 02,20L4 3:41 PM
To: Morgan Hill; Lisa Devore - CDPHE
Subject: Permit for injection well
HiMorgan,
Lisa forwarded your email to me about the injection well question. We typically don't deal with
injection wells themselves (they are regulated by the COGCC) but we do regulate the equipment
that may be located at them. I think you mentioned storage tanks and so those could be subject
to our APEN and permitting requirements depending on emissions. Engines, pneumatlc devices
or pumps used to inject the water and even fugitives may also be subject to regulation depending
on size.
lf you have more questions you can contact Stuart Siffring at stuart.siffring@state.co.us or 303-692-
2277, He is a permit engineer and will be better able to answer permitting questions. Let me know if you
have any
other questions,
Thanksl
lngrid Hewitson, MPH
Air Quality Planner
State of Colorado, Air Pollution ControlDivision
P:303.692.6331 | C:303.868.7317 | F: 303.782'0278
4300 Cherry Creek S. Dr., Denver, CO 80246
email: ingrid.hewitson@state.co.us
Oil & Gas Lfatson
Kirby Wyrut
Memorandum
September 19,2014
RE: GAPA-7985, Nolte (Caerus) SWD 1-l4lnjection Well
Dear David,
Thank you for the opportunity to review this application for an lnjection Well permit. Application
looks OK as long as the operational plan is certain to have no less than 5,000 barrels of total
tankage on the site. The application indicates 'less than 5,000 barrels' of tankage onsite and
also states "Approximately 5 to 10 Water Storage Tanks, 500 bbls in size (total capacity is
approximately 5000 bbls)". If there is additional tankage, such as for condensate, onsite the
stated operational plan may exceed the 5,000 barrel threshold and thus require a separate
permit based on total tankage vol
Kirby Wynn
David Pesnichak
From:
Sent:
lo:
Cc:
Subject:
Follow Up Flag:
Flag Status:
Charles Hall <cdhalll-49@gmail.com>
Tuesday, September 30, 2014 1:03 PM
David Pesnichak
Keith Lammey
Nolte SWD 1-14lnjection Well
Flag for follow up
Completed
David Pesnichak,
The Battlement Mesa Service Association's (BMSA) Oil and Gas Committee has reviewed the Nolte SwD l-14
Injection Well Land Use Change Application provided in CD form.
After this review the BMSA Oil & Gas Committee has no objection to the injection well. The Pipeline
Infrastructure for water delivery is a welcomed inclusion in the application, reducing the need for water truck
traffic.
Charles Hall
Chairman, BMSA Oil & Gas Committee
1
BATITEIVIENT CONCERNED CMZENS
BattlemerrtMesa, CO 8 1 63 5
September 30,2014
Garfield County
Community Development Department
108 8th Street, Suite 401
Glenwood Springs, CO 81601
Re: Caerus Piceance LLC lnjection Well permit application (GAPA-7985)
Dear Sir or Madarn:
We are concerned with the increasing number of injection wells and resultant potential for seismic activity,
especially where clusters of them occur. There are already seven in the immediate vicinity of
Parachute/Battlement Mesa and at least two others anticipated in addition to the one being proposed, Plus,
we see and hear reports in the media about earth-quakes in Colorado, such as the report in AfiACHMENT'A'
which is attached.
We recommend that Caerus be required to perform seismic testing prior to establishing the injection well and
to monitor for seismic activity thereafter.
Daily logs of injection pressure and volume should be available to the county and COGCC for review should
there be any reported seismic activity or measurable event.
We are working to have a seismic monitoring station located in Garfield County, in the Rifle area. ln the event
of future seismic activity in the area, accurate independent measurements can be obtained from a Colorado
Mesa University monitoring station located in Collbran. Contact David Wolny (dwolnv@coloradomesa.edu)
for more specifics,
Let us know if you have any questions or need additional information.
Sincerely,
Dave Devanney /s/
BCC co-chair
dgdevanney@co mcast.net
Doug Saxton /s/
BCC Director
douglassaxton @email.com
ATTACHMENT'A'
htto :l/www,ee news. net/e n e revwi rel2014/09/16/sto ries/1060005853
USGS links Colo. quakes to gas drilling
Mike Soraghan, E&E reporter
Published: Tuesday, September L6, 20L4
There is "clear evidence" that gas drilling activities triggered the magnitude-5.3 earthquake that shook Colorado
in August 2011, a U.S. Geological Survey study has found.
That rupture was the largest quake in a l3-year pattem of shaking along the New Mexico border, which the
study links to disposal of waste water from coalbed methane production.
"The earthquakes are clustered around wells that have been quite active since about a year before the
earthquakes started," said Art McGarr, one of four USCS scientists who worked on the study.
The peer-reviewed study, published today in the online version of the Billetin of the Seismological Society of
Ameitca,says that there's been a big increase in earthquakes in the Raton Basin around Trinidad, Colo., and the
only other thing that has changed has been the arrival of new disposal wells.
But one of two companies producing gas in the area sharply disagrees.
8tt
ttw
tt70 re€o relo 2000 20ro
[llA time progression of earthquakes in the Raton Basin, The dashed line indicates the earthquake detection
threshold for the Raton Basin over the entire study period. Graphic courtesy of the Bulletin of the Seismological
Society of America.
"We would categorically disagree," said Jennifer Webster, spokeswoman for lrving, Texas-based Pioneer
Nafural Resources Co. "We're not seeing any connection with disposal activity in the area."
The area has a history of natural earthquakes, she noted. And for the past 18 months, Pioneer has been
monitoring a sensitive array of 25 instruments in the area. Webster said the seismicity they detected is far from
the injection wells and 2 miles deeper than the injection zone.
The other operator in the area, Atlas Resource Partners of Philadelphia, did not return a phone message seeking
comment.
How Colorado quakes line up
The two companies are not engaged in high-volume hydraulic fracturing of shale formations. Instead, they are
tapping into the natural gas found in coal formations of the Raton Basin. Coal beds are found much shallower
ttran s,iate, but producing from them also creates significant amounts of rvastewater. The Raton field, though, is
in decline.
As with other studies from Arkansas, Oklahoma arrd Texas, the USGS study links the quakes to disposal
of rvaste fluid.
From 1972 through July 2001, there was one quake in the area larger than magnitude 4. Then 12 occurred
between August iOOt and 2013, mostly within 3 miles of active disposal wells. The study says the statistical
tikelihood that such a rate change would occur if earthquakes behaved randomly in time is 3 percent. [n
addition, earthquake activiry remains low outside the drilling zone.
As soon as the shaking started in 200 l, seismologists were suspicious that the convulsions in the Raton Basin
were linked to drilling. But for years, USGS scienlists were equivocal. McGarr said by the time of the
magnitude-S.3 earthquake, the relationship between injection and earthquakes was a lot more conclusive.
Another look at Colo. quakes
Prompted by the magnitude-S.3 quake, which occurred the same day as a better-known magnitude-S.8 quake
that sLook Virginia and the East Coast, USGS re-examined the Colorado earthquakes going back to the
"swarm" of 2001. Seismologists at the agency put out new instruments, went back into the data they had
gathered in the past 10 years and began to point the finger at drilling activity with increasing certainty.
The series of foreshocks and aftershocks in 201I was centered within 6 miles of five injection wells in the
.Raton Basin, the study says, two owned by Atlas Resource Partners on the same site and three owned by
Pioneer. All but or", lh. study says, are "high-injection-rate, high-volume wells." The ARP wells are within 1.7
miles of where the 2011 sequence began.
"The proximity of the IARP] wells to the 201I earthquake sequence also suggests that they are the wells most
likely to have induced the earthquake sequence," the study says.
Colorado officials, though, have long rejected the USGS conclusions as premature. In 2012, then-
Colorado State Geologist Vince Matthervs said, "These cowboys from USGS are sure these are induced.
They're jumping to conclusionst' (Enerwlfire, Dec, 3, 2012).
State officials, under fire from suburbanites and environmentalists charging lax regulation of drilling, have been
taking a less dismissive tone on the issue in recent months. After a smaller, magnitude'3.2 quake near Greeley-.
in May, the Colorado Oil and Gas Conservation Commission asked the operator of a nearby deep-injection well
to temporarily shut down for 20 days. ln July, the state allowed the well to reopen at a lower pressure and less
injection than before. The state said the well was "potentially" related to earthquakes in the area.
Colorado has a long history with man-made quakes. In the 1960s, disposal wells drilled at the Rocky Mountain
Arsenal near Denver, where the Army manufactured chemical weapons, were the first to be linked to
earthquakes. The largest Rocky Mountain Arsenal earthquake was magnitude 4.85.
After that, the Bureau of Reclamation began tracking man-made quakes in a river desalination project in the
Paradox Valley of western Colorado"
There was drilling and disposal in the Trinidad area from 1994 through July 2001, with no uptick in
earthquakes. But in early 2001, the study says, injection rates in the Colorado portion of the fietd dramatically
increased, rising from a median rate of 500,000 barrels a month to 1.2 million barrels a month. The earliest
earthquakes were located in the eastern portion of the gas field, shortly after six wastewater injection wells were
put into operation.
"Total injection volumes and the number of earthquakes roughly track each other," the study says.
Twitter: @MikeSoraqhan I Email: msorashan@eenews.net
Oil& Gas Ltaison
Rirby Wynn
Memorandum
July 3, 2014
RE: Review of COGCC injection well per.mitting, regional seismic monitoring and inducad
seismicity
ln responee to BOCC decision to call up a Director's decision regarding an lnjection well permit
application, I gathered relevant information regarding:
o Curently permitted injection wells in Garfield County
o COGCC injection well permlt review procese
r Current ceiemic monltoring and observed eeismic activity in western Colorado
o Reeeerch related to induced aeiemicity from injecflon wells
Currently permltted inJecflon wellr ln Garfleld County
According to COGCC rocords, there are currently 60 injection welle that could potentially be
utilized for waste dispoeal. Of those, 26 have been uaed for eome injection activily eince 2b13.
The altached map displays permitted lnjection wells near Batilement Mesa,
COGCC lnJactlon well permlt revlew proco.!
DircuEeed with COGCC staff (Koehler and Eisingefl their lnjection well permit procoee. COGCC
revlews. geologic structure in vicinity of proposed waate inJection wells and ovaluatee potential
seismicity, including a review of all regional eeigmic everite tron 1973 to preeent. They aleo
require teata of the wsll and surrounding formatlon characteristice. Revlew process ie gjearad
loJvard datermining eultablllty of lhe well for waete dispoeal ae well as operational precaure and
injection volume limits along with varioue ConditionE of Approval meant to reduce ihe possibility
of sdverse impact (i,e. induced seiemiclty) and to etate mitigatlon requirements ii advers€
lmpact ia suapected ln the future.
When COGCC determinee a propoaed well could preeent a risk for induced seiemicity, they oan
and do place permit requirements such as shut down procedures in case of a nearby geiemlc
event.
I
Current selsmic monitoring and observed setsmlc activlty ln weatern Colorado
Western Garfield County is nd prone to seismic activig based on discuseions with and data
provided by Anne Sheehan, Professor of Geophysics at CU Boutder. Dr. Sheehan is the lead
researcher conducting investigation of the 2014 seismic events near Greetey Colorado,
-Received-similar-information from COGCC and Paul Eerle, Geol{iie HazdrdS Team- dt the
USGS National Earthquake lnformation Center.
Drs. Sheehan and Earle indicate our area ls currently monitored for earthquake activity al a
resolution to note earthquakes of minimum 2.5 magnitude event with a tocation determination of
+/- G miles.
Research related to lnduced selsmlclty from lnfectton lvetls
Reviewed severa! recent academic and other publications regarding factorc that have caused
- -induced seisnlc-aciivity-from. by-waste-water-injeetion-The-phenurenon-is-relatMelyrareas
compared to the prevalence of waste lnJec{ion wells but can occur under certain condltions.
COGCC evaluates permit applications with the primary objedive to prevent approval of inJec.tlon
wells that could cause induced seismicity such as: large or actirre faults and perturbation of roc*
pore pressures in the proposed injec'tion intervals. lt can be especially important to evaluate tess
permeable and more brlttle formations proposed for injection as those can be the most
susceptible to induced seismicity if not managed carefully and using informalion abut the
permeability and capacity of target injection intervals.
The attached white Wper preparcd by COGCC descnbes their research and regulatory
rasponse to tl'E latast udarstanding of indued seismlcity. Summary quote fr,m the whlte
paper: .COGCC believes safeguards are ln place, in accordance with federal law and COGCC's
rules and policies, but we wlll continue to raniew induced selsmicig findings in other parts of the
country wilh interest. The cunent eafeguards defined by COGCC permit process are inJectlon
volume; pressure belo,t/ the fracture gradient; and, input from the CDWR and CGS to reduca
the potentialfor lnduced selsmicity related to UIC Class ll r,rrells, COGCC strives to continually
improve our evaluation methods, and the effectiveness of regulations, rules poticies and
procedures,'
Wynn
4
I
2
Enc'losures
Bibliography
COGCC,.-201-1, COGCC Underground lnjection Control and Seismicity in Golorado, COGC0
Staff White Paper, S pages.
Earle, Paul, 2014, July 7 , 2014 USGS National Earthquake lnformation Center lettar response
to query about regional selsmic monitoring capabililies, 2 pages.
Eisinger, C.,2014, Personal communications from COGCC Senior Research $cientist
supervi.sor regarding COGCC UIC application revlerv procedures and curront UIC wells in
Garfield County.
Koehler, 8,2A14. Personalcommunications fom COGCC Underground lnjection Control (UlC)
SupeMsor regarding COGCC UIC application review procedures.
National Research Council. lndued Seismiclly Potentiat in Eneryy Tachnotogies, Washington,
DC: The NationalAcademies Press, 2013, 263 pages.
Ellsrorth, W.L.,2013lnjection-lnducod Earthquakes, article in SCIENCE:VOL 341 12 JULY
2013,7 pages.
Zoback, M.D.,2012, Managing tha Seismic Risk posed by
Wastewater Disposal, Article in Earth Magazine, April2012, 6 pages.
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STATE OF
coLof?ADo
DEPARTMENT OF NATURAL RESOURCES
John W. HickenlooPer, G over nor
f 120 Lincotn St. Suite 801
Denver, CO 80203
Phone: (303) 894-2100
FAX: (303) 894-2109
www. colorado. gov/cogcc
otL&GAS
CONSERVAIION COMMISSION
January 19,2011
COGCG Underqround lniection Control and Selsmicity in Colorado
Colorado's earliest documented earthquake occurred on Decembet T, 1870.The Colorado
Tmnscipt stated, "A careful observer at Fort Reynolds, 20 miles east of Pueblo, noted that
bottles standing 1 inch apart were knocked together violently." Many earthquakes have
occurred throughout Colorado since that time and continue to occur today. Earthquakes are
vibrations created when large blocks of the Earth's crust move with respect to one another
along a fault plane. The Colorado Earthquake Hazard Mitigation Council published a map in
2008 of earthquakes and faults in Colorado. The map can be obtained at the Colorado
9eolooical Survev (CGS). The United States Geological Survey (USGS) maintains a database
of Colorado earthquakes at the National Earthouake lnformation Center (NEIC) in Golden.
Most earthquakes or seismicity occur as a result of naturally-occurring geologic phenomena.
However, there have been some cases where seismicity was suspected to have been triggered
by injection of fluids into the subsurface. The term 'lnduced Seismicity' has been used to
describe man-made earthquakes of this type. The most notable case in Colorado was at the
Rocky Mountain Arsenal (the'Arsenal") near Denver. Earthquakes began after a 12,000-foot
injection well was drilled at the Arsenal for the disposal of waste fluids. lnjection commenced in
March 1962. Shortly thereafter, an unusually frequent series of earthquakes occurred during the
period from January 1963 to August 1967. ln 1968 injection stopped, and the Army began
removing fluid from the Arsenal well at a very slow rate in an effort to reduce earthquake
activity. ln Nicholson, 1990, Eafthquake Hazard Associated with Deep Well lnjection- A Report
fo the U.S. E.P.A.s injection volumes were related to earthquake events, demonstrating that
these earthquakes were induced by fluid injection at the Arsenal.
COGCC, in accordance with federal law and COGCC's rules and policies, believes safeguards
are in place to reduce the likelihood of induced seismicity. The current safeguards defined by
COGCC permit process are injection volume; pressure below the fracture gradient; and, input
from the Colorado Division of Water Resources (CDWR) and CGS to reduce the potentialfor
induced seismicity related to UIC Class ll wells.
The federal Underground lnjection Control (UlC) program began on December 1974 with the
creation of the Safe Drinking Water Act (SDWA). The SDWA established the UIC Program,
administered by the United States Environmental Protection Agency (EPA), to protect
Underground Sources of Drinking Water (USDWS) from irnpacts related to underground fluid
injection practices. The EPA delegated primacy for regulation of Class ll UIC wells to the State
of Colorado for underground injection of oil and gas exploration and production waste on April 2,
1984. Colorado has administered the UIC prooram in accordance with federal regulations (40
CFR, Parts 144,145,146, and 147) since that time, providing the EPA with semi-annual
reports, http://water.qpa.qov/type/qroundwater/uic/index,cfm.
OEPARTMENI OF NATURAL RESOURCES| Mik6 KirE. Execuiw DiEctor
C@CCCOMMISSION: RichardNwsd- Jdm B€nton-Tioms L. Compts-OoAmCraig-TmmyHollon -W. Peny Pearco - Andw Spelman -Miko KirE- Chris Ulblna
COGCC STAFF: DiliJ Ne6lln, DlBcltr - Margffit Ash, Field ln$€cllon M{Egtr - Debble 8al6flin. Efrirmmatal Manag€r - Stuarl Ellsworth, Eoglf,srhg Manager
CQGCC Underqround lniection Gontroland $eismlcltv in Colorado (cont.l
The Colorado Oil and Gas Conservation Commission (COGCC) is the State regulatory agency
that permits Class ll UIC wells for injection of oil and gas exploration and production waste and
enhanced recovery wells. The COGCC Class ll UIC permit review process is defined by
COGCC Rule 303 Permit to Drill, Rule 3248 Exempt Aquifers, Rule 325 Underground Disposal
of Water, Rute 326 Mechanical lntegrity Testing, and Rules 706,707, and712, which identiff
FinancialAssurance requirements. The perrnit process involves the review and approval of
Form 21, Mechanical lntegrity Test, Form 26, $otrrce of Produced Water for Disposal, Form 31
Underground lnjection Formation Permit Application, and Form 33 lnjection Well Permit
Application. lnformation included with these forms and required supplementary documentation
describe well construction, ground water and injection zone isolation, fracture gradient,
maximum injection rate, maximum injection volume, maximum injection pressure, injection zone
water quality, and potential seismicity associated with fluid injection.
lnjection wells must utilize a well construction method of cemented surface casing and
production casing, which isolate and prevent fluid flow between injection zones and USDWs, To
verify isolation, the COGCC UIC engineer reviews all relevant information, including:
hydrogeologic studies, Colorado Division of Water Resources (CDWR) waterwellinformation,
and COGCC's geophysicalwell log database. This information is used in conjunction with
specific formation and well construction data submitted by the injection well operator, including
resistivity and cement bond geophysical logs to veriff that: 1) the surface casing is set below all
fresh water zones used as a water supply, and 2) production casing cement placement and
quality allows for adequate isolation of the injection zone and USDWs, including fresh water
zones that are not currently being used as a water supply. Further, the geophysical logs are
used to determine the injection zone thickness and porosity, and the logs are used to verify that
the bounding shale zones are thick enough to provide zonal isolation. The COGCC UIC
engineer calculates a maximum injection volume, based on thickness and porosity from the log
data. By COGCC policy, the injection volume is restricted to a one.quarter mile radial volume.
The restriction is intended to constrain the total volume of injected fluids during the life of the
injection well.
After a well has been drilled and completed into the injection zone, an injection zone water
sample test must be submitted. The sample is required to meet EPA-defined levels for total
dissolved solids (TDS). COGCC Rule 3248 Aquifer Exemption is required, if the sample has a
TDS below 10,000 milligrams per liter and above 3,000 milligrams per liter. Water zones
containing TDS of less than 3,000 milligrams per liter cannot be exempted and used for
iniection, because they are considered to be USDWs suitable for possible future use as
treatable water supplies. COGCC solicits written opinion from the CDWR regarding the
occurrence of surface and subsurface fresh water sources in the vicinity of the injection well and
the suitability of the injection well's proposed casing and cement configuration to protect those
resources.
Maximum surface injection pressure is calculated based on a default fracture pressure gradient
of 0.6 psi per foot of depth. The operator may elect to conduct a Step Rate lnjection Test to
define whether a higher injection zone fracture gradient exists. From the resulting fracture
gradient, the COGCC UIC engineer designates a maximum surface injection pressure at the
operator's requested injection rate as a condition of permit approval. COGCC's policy is to keep
injection pressures below the fracture gradient, which is delined uniquely for each injection well,
minimizing the potential for seismic events related to fluid injection. Some injection wells do not
need to inject under pressure because the formation will take water on a vacuum. Beginning in
September of 2011, the COGCC UIC permit review process was expanded to include a review
Page2
COGCG Underqround lniection Controland Seismlcitv in Colorado (cont.)
tor seismicity by the CGS. CGS uses their geologic maps, the USGS earthquake database, and
area-speciflc knowledge to provide an opinion of seismic potential. lf historical seismicity has
been identified in the vicinity of a proposed Class ll UIC well, COGCC requires an operator to
define the seismicity potential and the proximity to faults through geologic and geophysical data
prior to any permit approval.
COGCC has had recent discussions with operators, EPA and the USGS regarding induced
seismicity. Th'e USGS earthquake specialists visited the COGCC and CGS in January 2012.
Discussions related to providing technical expertise regarding seismicity and possible
relationships to Class ll UIC wells.
COGCC believes safeguards are in place, in accordance wlth federal law and COGCC's rules
and policies, but we will continue to review induced seismicity findings in other parts of the
country with interest. The current safeguards defined by COGCC permit process are injection
volume; pressure below the fracture gradient; and, input from the CDWR and CGS to reduce
the potentialfor induced seismicity related to UIC Class ll wells. COGCC strives to continually
improve our evaluation methods, and the effectiveness of regulations, rules policies and
procedures.
References:
1. USGS Earthquake Hazards Program, Earthquake History of Colorado'
http:l/earthquake. usos.qov/eartho uakes/states/colorado/historv. php
2. Division of Minerals and Geology Colorado Geological Survey, RockTalk, Volume 5 Number
2 April2002.
3. Colorado Earthquake Mitigation Council, Colorado's Earthquake and Fault Map, 2008
4. Davis, S.D., and Frohlich, C., 1993, Did (or will) fluid injection cause earthquakes? - Criteria
for a rationalassessment, SelsmologrbalResearch, Leffers, v. 64, P' 207'224.
5. Nicholson, Wesson, 1990, Earthquake Hazard Associated with Deep Well lnjection- A
Report to the U.S. E.P.A., USGS Bulletin 1951, 74p. (Note: AIso available as USGS Open
File Report 87-331). default.htm
6. Osborne, Paul, editor, 2002, EPA Technical Program Review: Underground lnjection
Control Regulations, EPA 81 6-R-O2-025.
7 . Shirley, Kathy, 2001, Colorado Quakes Cause Concern, AAPG Explorer'
http://www.aapg.orq/exolorer/2001/12dec/colo quakes.cfm.last accessed 1111712005.
Page 3
coccc underqround lniection control and selsnnlcltv ln colorado
What is a Class ll Underground lnJection Control(UlC) well?
Cf"*r f i UIC wells inject flu-ids associated with oil and natural gas production' Most of the
i.j;;i"d fluid is salt irailiiOrinei, wnich is brought to the surface in the process of producing
Glnii.ti-gl oil and gas. tn'some oil fields, brine and other fluids are injected to enhance
t*pt*-i;iland gai production by using an enhanced recovery method known as "water
flooding., There .r" ,pprorirrtety AAS Jctive Class ll UIC wells in Colorado, with 297 operating
as exploration anO production tEapl waste disposalwells an-O Slp enhanced recovery wells'
ine *aste disposaiwells injeci appioximately 355,000 barrels of brine per day'
What are the types of Class ll UtG wells?
There are three types of Class ll injection wells associated with oil and natural gas production'
1. Enhanced oir necoverv w"lb (ron) inject brine, water, steam, polymers,.naturalgas
and/or caruon dioxiOe iirto oil-biaringj foimations to recover residual oil. This is also
known as secondary or tertiary recoiery. The injected fluid thins (decreases the
.
viscosity) or, iirpi..6t the residual oil anO gas after PriTlry productio.n, which is then
available for ie-covery. ln a simple configurition, a single injection well-is surrounded by
multiple production wells. Production w6lls bring oil and gas to the surface; the UIC
program Ooes noi regulate production wells. Enlanced recovery wells are the most
numerous type of Cdss ll wells, representing as much as-60 percen! of-thg Class ll
Ulc wells in colorado. There are currently 588 permitted EoR wells in colorado'
2. Disposal wens iniect Urin.i and other eA'p wasie fluids associated with the production
of oil and n"trt"f g"" operations. \Men oil and gas are produced, brine is also brought
to the surface. mE nrine is segregated from thaoil and gas by surface production
facilities. tt is tnen injected intdth! same deep underground formation or a similar
formation up*.inrrifv permitted tor disposal. btass tl.disposalwells can only be used to
dispose of nuiOi isiociatea with oil-arid gas production. Disposal w-ells represent about
30 percent oicotoraoo's Ctass tl UtC we'ils. th"re ure 885 total UIC Class ll wells with
29i operating as E&P waste disposal wells in Colorado'
3. HydrocarUon"storage Wells inject liquid hydrocarbons in underground formations
(sucn as salt caver;s or abandoned irydrobarbon fields) where they are stored,
generally, as part of the U.S. Strategic Petroleum Reserve'
Is UIC Class ll Exploratlon and Productlon Dlsposalthe same as hydraulic fracturing?
No. lnjection wetl opeiations are not nyOrauticiracturing. Hydraulic fracturing and underground
iniectibn ar" not retateO activities. Class ll waste dispoial is conducted below rock fracture
gradient so as not to cieaie new fracturet. Ctrtt ll waste disposal occurs over a long period of
time, typically many Veats Outing the life of a Uf C well. On the other hand, hydraulic fracturing is
p"rf,i*i"O ove, a rn6tt p"rioO oiti*e, typically hours, with "flowback" occurring over the course
of several days or weeks. By definition, pt"ssrtes used for hydraulic fracturing are above the
ioctrr" gradient, with the intlnt of inducing new fractures within a hydrocarbon extraction zone
and doei not include the permanent emplacement of fluids'
What are the requlrements for Class ll wells?
A state has the option oirequesting orimacv for Class ll wells under section 1422 of the Safe
Drinking Water Act:
secflon {422 requires states to meet EPA's minimum requirements for Ulc programs'.
Programs authorized under sectio n 1422 musi inctuOe construction, operqling, monitoring and
testing, reporting, and closure requirements for well owners or operators' Enhanced oil and gas
recovery wells may "itfr"iU"
issued permits or be authorized by rule- Disposal wells are issued
Page I
COGCC Underqround lniection eontrol - Frequentlv Asked Questlons (cont.I
permits. The owners or operators of the wells must meet all applicable requirements, including
strict construction and conversion standards and regular testing and inspection.
Are there other types of underground injection wells?
Yes, there are six-injection welltypes, which are designated based on the different types of
waste injected into t-he wells. COGCC has primacy to administer EPA's requirements for Class ll
UIC welts.. lndustrial & Municipal Waste Disoosal Wells (Class l) - There are 13 Class I wells in
Colorado.. Oil and Gas Related Wells (Class ll) - There are 885 Class ll wells in Colorado.. Solution Mininq Wells (Class lll) - There are 37 Class lll wells in Colorado.. Shallow Hazardous and Radioactive lniection Wells (Class lV) - There are no permitted
Class lV wells in Colorado.. Shallow Non-Hazardous lniection Wells (Class V) - There are 1759 Class V wells in
Colorado.. Geologic Sequestralion Wells (Class Vl) - There are no Class Vl wells in Colorado.
Page2
sI
United States Department of the Interior
GEOLOGICAL SURVEY
Geologic Hazards Team
MS 966, Box 25046
Denver, Colorado 80225-0046
30 June,2014
Dear Kirby Wynn and Douglas Saxton'
lYhat tyPe of seismic activity should trigger an in1 ectionwell be shut down?
lighf'sYstem for
The USGS is not a regulatory body and has not authored a sPecific "stoP
shutting down waste water injection wells.To provide some background on the issue, I have
emailed You a short article bY Mark Zobackthat rePresents his views not those of the USGS
Additional information can be found in a USGS authored here:
. Other possible sources for
seismicallY monitoring disPosal
advice include the Bureau of Reclamation since theY have been
wells in Paradox V alley, Colorado for many Years'
SincerelY,
Paul Earle
USGS National Earthquake Information Center
Telephone (303) 27 3 -8417
pearle@usgs.gov
l
x
This letter is in response to questions I received from both of you concerning usGS monitoring
capabilities in GarfielJ County. There *rr, ,"r.,ul questions raised in our discussions'
what are the currentuscs earthquake monitoring procedures and capabilities in Gorfield
"1i?LroS National Earthquake Information c:nY qPlclryb.llt'-'^:*:*:locations
and magnitudes for "fia-J..i"a
earthquakes ;d;*dt)'S or'larger or reported felt within the
U.S. Inyour regiorq GiA,;;";.aur" i*;;il?.l*.I.*..u.ttiuakes that are reported felt
and/or those with magnitude 4.0 or larger. iiJ"Vi"ft stve'al *'Lkt before the smaller
earthquakes *. pro""-,,td and released on the website'
what resources are required to improve,the monitoring capabilities in this and other regions?
Cunently, tf,. USA6 NriC r"r.iu.t d"d;;;-,' ttitiont within200 km of Rifle' CO' The
vast majority of *r.s.Ir.'to tt. ,oott *.tt t P;"d"x Valley' These stations are run by the
Bureau of Reclamat#; ;;; their brine injection wells. with this station coverage' we
estimate we can automatically detect.utttq'"n'it with magnitudes 2'5 and above' Accurate
estimates of location uncertainty would td;;lilh;i 1tui1' but horizontal urcertai,ty is likely
in the l0 to 15 km range with similar or-griu* uncertaintyin our estimates of earthquake depth'
To achieve location-uncerrainties i" thr;-k*;;;;;ig robustly detect quakes smaller than
about 2.5, requires the installation of a local "it*iJ*uy similar toihut currently being run by
Dr. Anne sheehan near Greeley, co. Additi;;;;;;";..es would be required to build realtime
capabilities unA pro".i, ""nt
qii"f", f"Ui";;;l"* tht current USGS magnitude 2'5 threshold'
Uquid carbon dioxide has been injected lnto
the Sletpner gas- and ollfleld in the North Sea
for 15 years without triggerlng any;e!$1iV'
It serves as a good example of how fluld injec-
tion can be done safelY.
Managing the.seismic Risk Posed by
Wiitdwaier Disposal
Mark D. Zoback
-IEf rom an earthquake perspectirre, 2011 was
I r aremarkable year' While the devastation
la u.*-panying the magnitude-g'O Tohoku
I earthquake that occurred off the coast
of Japan on t'tarch 11 still captures attention
worldwide the relatively stable interior of the
U.S. was struck by a somewhat surprising num-
ber of small-to'moderate earthquakes that were
widely felt. Most of these were nahrral events'
the types of earthquakes that occur from time to
timiin all intraplate regiors' For example' the
magnitude S.g tirat occurred in central Virginia
on
-Arg' 23 was felt throughout the northeasL
damagla tne Wastrington Monument'.and caused
the temporary shutdown of a nuclear power
plant. Tiris earthquake occurred in the Central
38 . EARTH APril2012
Vireinia Seismic Zone an area known to produce
relJtivelv frequent small earthquakes'
fto*"rut, a number of the small-to-moderate
earthouakes that occurred in ttre U'S' interior in
;i;;p";t to be associated with the disposal
oi *.r'td*u,"t, at least in part related to natural
sas production. Several small earthquakes were
Ipp.re.tUy caused by injection of wastewater
usso.lat"d wi[T shale gas production near.Guy'
Ark.; the largest earthquake was a matrutuqe-+'/
event on Feb.27. In the Trinidad/Raton area near
tfre border of Colorado and New Mexico injection
of wastewater associated with coalbed methane
pioa"Jion t*nis to be associated with a magni-
Ld"-53 "*ntthatoccurred
onAug' 22' and small
earthquakes that appear to have been triggered by
www.earth ma gazine'org
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oo
110' 105' t00" 95"90"85'80'75"70"65'
105' too' 95" 90" 85' 80" 75" 70'
Earthquakes above magnitude-3.0 have been recorded by the U.S. Geologlcal Survey in the Central
and Eastem United States and southeastern Canada since 1960. The dates and largest magnhudes
assoclated wlth recent earthquakes apparentlv triggered by fluid lnjectlon are noted.
49"
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wastewater injection occurred on Chrisfrnas Eve
and New Year's Eve nearYoungstowrg Ohio, the
largest of which was a magnitude 4.0. Although
there hasbeen speculation that the magnitude-5.6
earthquake that occurred in Oklahoma on Nov. .5
may have been triggered by similarfluid injectio4
no linkage between this earthquake and fluid
injection has been established.
The occurrence of injection-related earthquakes
is understandably of concem to the public, govem-
ment regtrlators, polirymakers and industry alike.
Yet it is important to recogrrize that with ProPer
planning, monitoring and nesponse, ttrc occurrence
of small-to-modemte earthquakes associated with
fluid injection canbe reduced and the risks associ-
ated with such events effectively managed.
First, the Facts
No earthquake triggered by fluid injection has
evercaused serious injury or significant damage.
Moreover, approximately 14O000 wastewater
disposal wells have been operating safely and
without incident in the U.S. for many decades.
That said, we have known for more than
40 years that earthquakes can be triggered by
No earthquake triggered by fluid iniection has
ever caused serlous iniury or significant damage.
fluid injection. The first well-studied cases were
earttquakes triggered by waste disposal at the
Rocky Mountain arsenal near Denve!, Colo.,
in the early 1960s, and by water injection at the
Rangely oilfield in westem Colorado in the late
'50s and eady'7Os.
Such quakes occur when increasing pore pres-
sure at depth caused by fluid injection reduces
the effective normal stress acting peqpendicular
to pre-existing faults. The effective normal stress
on a fault canbe thought of as a force that resists
shear movement - mudr as how putting a weight
on abox makes it more difficult to slide along the
floor. Increasing pore pressure reduces the effec-
tive normal stress, allowing elastic energy already
stored in brittle rock formations to be released
in earthquakes.These earthquakes would some-
day have occurred anyway as a result of slowly
accumulating forces in the earth resulting from
natural geologic proc€sses - injeCtion just speeds
up the process.
www.earthmagazine.org EARTH April 2012 39
fu there has been an appreciable increase in
hydraulic fracturing associated with shale gas
development in recent years, it should be
pointed out that the water iniection associated
with hydraulic fracturing is not responsible for
the triggered seismicity in question.
As there has been an appreciable increase in
hydraulic fracturing associated with shale gas
development in recent years, it should be pointed
out that the water injection associated with hydrau-
lic fracturing is not responsible for the higgered
seismicity in question. The reason for this is that
pressurization during hydraulic fracturing affects
only limited volumes of rock (typically several
hundred meters in extent) and pressurization
typically lasts only a few hours. Thus, while very
small earthquakes have occurred during hydraulic
fracturing (such as a magnitude-2.3 earthquake
near Blackpool, Englan4 in April 2011), these are
extnemely rare events. The concem about triggered
seismicity associated with shale gas development
arises after hydraulic fracturing when wastewater
that flows back out of the wells is disposed of at
dedicated injection wells.
Five straightforward steps can be taken to
reduce the probability of triggering seismicity
whenever we inject any fluid into the subsur-
face. First, it is important to avoid injection into
active faults and faults in brittle rock. Second,
formations should be selected for injection (and
injection rates should be limited) to minimize pore
pres$rre changes. Third, local seismic monitor-
ing arrays should be installed when there is a
potential for iniection to trigger seismicity. Fourth,
protocols should be established in advance to
define how operations will be modified if seis-
micity is triggered. And fifth, operators need to
be prepared to reduce injection rates or abandon
wells if triggered seismicity poses any hazard.
These five steps provide regulators and operating
companies with a framework for reducing the risk
associated with triggered earthquakes.
Step 1: Avoid lniection into
Active Fauls
Aside from plate boundaries where large earth-
quakes occur with regularity, earthquakes also
occur in brittle rocks nearly everywhere within
continental interiors around the world as a result
of nafural geologic processes. It is thus no sur-
prise that fluid injection occasionally triggers
earthquakes. In fact, building dams for surface
reservoirs occasionally triggers small- to moder-
ate-sized earthquakes even though resultant pore
pressure increases at depth are extremely small.
Shale gas and tight oil are produced ln the Bak-
ken Formation in North Dakota.
Modem 3-D seismic imaging methods are suf-
ficiently advanced that we can identify faults
capable of producing potentially damaging earth-
quakes at depth. Faults large enough to produce
damaging earthquakes - say, those above mag-
nitude 5.0 - shoutd be easily detectable as Part
of geologic characterization studies of potential
injection sites because they are associated with
slip on faults that are many tens of kilometers in
size. Smaller faults may be harder to detect, but
will only produce small earthquakes that might
be felt locally but will not cause damage.
Modern 3-D seismic imaging methods are
sufficiently advanced that we can identify faults
capable of producing potentially damaging
earthquakes at dePth.
We also know a lot about the relationship
between the orientation of potentially active faults
and the ambient stress field in a given region. This
alsoenables us to identify (and avoid) potentially
problematic faults prior to injection' Potentially
active faults can be identified because the rela-
tionship between the orientation of active faults
and the regional stress field is well known from
basic principles of structural geology and rock
mechanics. In other words, only faults of cer-
tain orientations are potentially activated during
injection in a given area. Theearthquakes appar-
ently triggered by fluid injection at Guy, Ark.,
occurred on northeast trending, near-vertical
faults, consistent with what would be expected
from knowledge of the regional stress field and
quite similar to the trend of active faults in the
New Madrid Seismic Zone immediately to the
east. Had these faults been identified during site
characterization sfudies carried out as part of the
permifting process, this site would not have been
used for injection.
o
40 r EARTHApril20l2 www,earth magazi ne.org
Wastewater from hydraulic fracturing ls trucked
away from drltling operations in Pennsylvanla
in the Marceltus Shale and moved elsewhere
in dte reglon where lt wlll most llkely be rein-
Jected and reused.
Step 2: Minimize Pore Pressure
Changes at Depth
Rocks in the upper part of Earth's crust contain
pre-existing pore spacg fractures and flaws. These
void spaces are normally filled with freshwater
near Earth's surface (in the upper 1 kilometer or
so) and filled with saline brines at greater depths'
lnjecting fluids into the zubsurface will increase
the preszure in these voids, depending on the
rate it is injected and the volume of pore space
available to accommodate the injected fluids. It
should be pointed out that injection always occurs
at dePths where the injected fluids are isolated
from near-surface water zuPPlies.
To minimize the potential for injection to trigger
seismicity, it is obviously a good idea to minimize
the pore pressure perturbations associated with
injection. This can be accomplished in a variety
of ways.
The best way, of course, is to minimize the
injected volume of fluid. Consider the case of the
disposal of flowback waters following hydraulic
fracturing associated with shale gas development
in the Marcellus Formation of the nottheastem
U.S. Typically,25 to 50 Percent of the water used
during hydraulic fracturing flows back and needs
to be disposed of. However, because it has been
difficult to find suitable injection sites in this
Nearly atl of the water used ln hydraulic fractur-
ing in the Marcellus Shale ls relnJected durlng
subsequent hydraullc fractudng operations'
Meanwhile, itis stored ln wastewaterlmpound-
ment ponds like thls one ln PennsYlvania.
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region (and quite expensive to haul water Sreat
dGtances to alrrady operating injection wells),
it is common practice to recycle flowback water
by using it in subsequent hydraulic fracture
operations rather than disposing of it in injection
wells. In the Marcellus, nearly all of the water is
recycled. That certainly mipimizes the pore pres-
sure perturbations,
Another way to reduce the pressure buildup
associated with tnjection is to utilize highly
permeable regional saline aquifers to dispose
of wastewater' These aquifers can accommo-
date large volumes of iniected fluids without
experiencing significant Pressure changes. The
Elienburger Formation in Texas is regionally
extensive and highly permeable - one reason
why many of the approximately 50,000 per-
mitted wastewater disposal wells in the state
have operated for so long, essentially without
the occurrence of triggered seismicify. In cases
where saline water is used for hydraulic frac-
turing, it is possible to reiniect the water that
flows back after fracturing into the same forma-
tions. When flowback water is injected into the
www.earth ma gazi ne.org EARTH APril2012 r 41
Operators and regulators should establlsh
operational protocols - like perhaps a "traffic
light" system - for wastewater injection sites
located in areas where there is concern about
the potential for triggered selsmlcity: Green
means go, all sy$ems working correctly; yel-
low means proceed wlth cautlon, seismicity
detected; red means stop, seismicity poten-
tially presents a hazard.
same saline aquifers from which the
water used for hydraulic fracturing
was produced, pressure in the aquifers
decreases over tirne as more water is pro-
duced for hydraulic fracturing than injected
following flowback.
Alternatively, weak, poorly cemented and
Nghly permeable sandstone formations would
also be ideal for injection. Such formations deform
plastically and do not store elastic strain energy
that can be released in potentially damaging
earthquakes. No earthquakes have been triggered
in the 15 years during which a million metric tons
per year of carbon dioxide frorn the Sleipner gas-
and oilfield in the North Sea has been injected
into the Utsira sand, a highly porous, regionally
extensive saline aquifer.
ln the same way that it's important to plan
for the possibility of triggered seismicity in
advance, we have to be prepared to reduce
iniection rates, or even abandon wells if
triggered seismicity cannot be stopped by
limiting iniection rates.
Obviously cases will arise where well-cemented,
less permeable and more brittle formations must
be used for injection. In those cases, care rrrust be
taken to avoid large pore pressure changes. This
can be done through modeling prior to injection
once the permeability and capacity of the injection
intervals have been determined. Well-established
procedures have been developed over many
decades by petroleum engineers to do this.
Step 3: lnstall Local Seismic
Monitoring Arrays
Potentially active faults that might cause large
and damaging earthquakes should be identifiable
during the site characterization phase of permit-
ting potential injection wells. Because smaller
faults can escape detection, seismic monitoring
42 r EARTH April 2012
proceed with
caution:
seismlcity
detected
anays should be deployed in the vicinity of injec-
tion wells when there is a cause for concem that
injection might trigger seismicity.
The locations and magnitudes of naturally
occurring earthquakes are routinely determined
on a real-time basis in numerous seismically
active regions around the lvorld. The instrumenta-
tion, data telemetry and analysis techniques used
to accomplish this monitoring are well developed
and easily implemented at relatively Iow cost.
By supplementing regional networks with local
seismic arrays near injection wellg accurate loca-
tions of earthquakes that might be triggered by
injection can be used to determine the locations
and orientations of the causative faults.
Although small faults cannot cause large
earthquakes, even small earthquakes felt by
the public will be a cause for concem and should
be monitored.
Step 4: Establish Modification
Protocols in Advance
Following precedents established to deal with
earthquakes triggered during the developrnent
of enhanced geothermal systemg operators and
regulators should jointly establish operational
protocols for injection sites located in areas where
there is concem about the potential for triggered
seismicity. These protocols are sometimes referred
to as "traffic light" systems.
Green means go: Once operational protocols
and local seismic networks are in place and
injection begins at agreed-upon rates, operators
would have a green light to continue unless
earthquakes begin to occur that appear to be
www,earth magazine,org
t9
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Ui
cc
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| 13llne wastewater injection well owned by Northstar Disposal Services LLC ln youngstown, Ohlo.Following several small earthquakes in the area in December 201l, the company hatted injection ofwast€watel into the well which stopped the earthquakes. The wastewate] ii from the projuction ofoil and gas.
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related to injection. The occurrence of seismic-
ity would be a cautionary yellow tight. Once
seismicity occurs, operators would slow injec-
tion rates and study the relationship between
the seismicity and injection. Should seismicity
cease, operations could potentially continue at
reduced injection rates. In fact, it was demon-
strated 40 years ago at Rangely that earthquakes
could be h.rmed on and off by modulating the
injection rate and resultant increase in pore pres-
sure at depth. With such protocols in place, the
potential occurrence and associated response to
triggered seismicity are pre-defined and known
to all parties.
Step 5: Be Prepared to Alrer plans or
Abandon Wells
In the same way that it's important to plan for
the pos.sibility of triggered seismicity in advance,
we have to be prepared to reduce injection rates,
or even abandon wells if triggered seismicity
cannot be stopped by limiting injection rates.
That would be the red traffic light: Seismicity
has been detected that appears to be associated
with a fault potentially capable of producing a
moderate-sized earthquake. In the case of the
Arkansas triggered earthquakes, as well as a
series of quakes thought to have been caused
by wastewater injection in the Bamett Shale in
Texas near the Dallas-Fort Worth metro area in
2008, the seismicity abated once injection in the
problematic wells was terminated.
Overall, it is important for the public to recog-
nize that the risks posed by injection of wastewa-
ter are extremely low. In addition, the risks can
be minimized further through proper study and
planning prior to injection, careful monitoring in
areas where there is a possibility that seismicity
mightbe triggered, and operators and regulators
taking a proactive response if triggered seismicity
were to occur.
Zoback is a professor of geophysics at Stanford
Unlversity. The vlews expressed are his own.
www.ea rth magazi ne.org EARTH April 2012 43
David Pesnichak
From:
Sent:
To:
Subject:
Follow Up Flag:
Flag Status:
Franco - DNR, Ivan <irran.franco@state,co.us>
Wednesday, October Al, ZAl412:4g pM
David Pesnichak
Nolte SWD 1.-l4 tnjection Well
Flag for follow up
Flagged
David,
we have reviewed the Nolte small injection well referral in carfield county. Thank you for the opportunity toreview the application however we hive no comments at this time.
Regards,
lvan Franco, E.l.T.
Water Resources Engineer
tr
P 303.866.3581 / F 303.86 6.2223
1313 Sherman Street, Room g1g, Denver, CO 80203ivan.franco@state.co.us / www.water.state.co.us
I
AffiI COLORADO
Parks and Wildtife
Department of Natural Resonrces
Northwest Regionat Office
711 lndependent Avenue
6rand Junction, CO 81505
David Pesnichak
$1fiqld County Building and planning Department
108 8tr' Skeet, Suite 401,
Clenwood Springs, CO 81601
RE: Nolte SWD l-14Injection Well
Dear Mr. Pesnichak,
Lt$ ryl r"r the opportunity to review the Caerus Piceance LLC., proposal for an injection well (NolteswD l-14) on existing welr pad. please consider the forlowing co'mI-rents.
The proposed project will occur on a pre-existing well pad, which cpw anticipates will minimize impactsto wildlife' The water will be transported via pifeline, which will also minimize long-term vehicle trafficand human disturbance.
This project lies within the boundary of the cPW-PDC (norv caerus) wildlife Mitigation plan (wMp);this plan describes the best manaqement practices that caerus will use to avoid, minimize and mitigate (asnecessary) impacts to wildlife and wildliie habitat from oil rna gu. J"u.lopment.
cPW recognizes the project site lies in habitat for multiple species (mule deer, elk, and black bear);however, we are satisfied that the commitment caerus d;;"d.i;;rotect witotife and habitats within thewMP boundary is fully sufficient to protect the species that may be irnpacted.
In addition to the protections described in the wildlife mitigation plan, Caerus must comply with thecolorado oil and Gas conservation commission's (cocct) *t", *rut are applicable to an injectionwell; representative surface regulations may include pit fencing.ra *ii*e,TJtr., i*irr."j nr"rreclamation, and weed management.
cPW requests that caeru|1e-sound mitigation for engines and necessary appurtenances associated withwith the iqiection well. coGCc 800 seriis rules defin-e n"."rrrry.t'*dards for sound mitigation, cpwrequests that the Rules be implemented at the Residential/Agricuitu.uirRrrut Zone which isisau(a)from 7:00 am to nexr 7:00 pm. and 50db(A) from 7:00 pm to next 7:00 AM.
CPW appreciates the opportunity to comment on projects that may affect wildlife and their habitats.Please contact me by phone at 970-250-0g73 if you need further information.
Sincerely,
Scott Hoyer, District Wildlife Manager
cc. JT Romatzke, Area Wildlife Manager
File.
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