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HomeMy WebLinkAbout4.0 DD Staff Report 10.10.2014Staff Report Exhibits Puckett Land Co. Administrative Review Applicant is Caerus Piceance, LLC. October 10,2014 (File GAPA-7985) Public Hea Notice lnformation1 Return from Mail Notice2 Referral Comments from lorado Parks and Wild 2014 life (dated JulY 16,Co3 Referral Comments from Road and Bridge (dated Se Garfield CountY 18 2014 4 Referral Comments from Mountain ring (dated October 8, 2014 Cross Enginee5 Referral Comments from Garfield CountY Veg etation Management Dated October 7,2014 6 Garfield CountY Public Health (Dated OctoberReferral Comments from 2 2014 7 Referral Comments from ld County Oil and Gas Se Liaison (DatedGarfie 19 2414 8 Referral Comments from the Association's Oilement lvlesa ServiceBattl and Gas Committee Dated S ber 30 2014 I Referral Comments from Battlement Concerned Se Citizens (Datedthe ber 30 2014 10 Memorandum from KirbY County Oil and Gas LiaisonWynn, Garfield and select documents Dated Ju 3,2014 11 Referral Comments from the Water Resources Enginee r (Dated October 1 2014 12 Referral Comments from Scott of Co lo rado Pa rks nd W td ifea13 REQ EST PROPERTY OWNER APPLICANT ASSESSOR'S PARCEL # PROPERTY SIZE LOCATION ACCESS EXISTI NG ZONING Director Determination 10110114 File No. GAPA-7985 DP General Administrative Land Use Change Permit for a Small lnjection 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 Valtey High School, approximately 1000 feet northeast of the l-70 I Hwy 6 lnterchange southwest of the Town of Parachute, in SESE, Section 14, T7S, R96W of the 6th PM. The facitity 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 ,1 tf," Nolte SWD 1-14 injection well. The facility will be located on 40' * f Sa; (6,320 sq.ft.) within an existing COGCC approved well pad' The injection wells proposed to be located on the Notte #14-796 well pad is to serve 17 naturat gas weli (tb totat wells including the injeclion well) on this s?Te pad as well as 13 wells from the neighboring lsland Ranch #13-7gO well pad' No water 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 1,200tbls of water daily' The proposed injection requires coccc Form 2 (Apptiiation for Permit-To-Drill, Deepen, Re-Enter, L Or Recomplete), 31 (Underground lnjection Formation Permit Application) and 33 (lnjection Well Permit Application). The Facility will include the following equipment: a a 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. o Pipeline infrastructure for water delivery o Pump house building Vicinity tMap 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 round-trip 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 fa'ils outside of the Garfield County requirements for permitting' 2 #14-196 I I I t rl. .) 4,7i nrc!: ltollt {&a4 / .i) -rt\-.\; ^' -.ri>' \-.: -t ' t*', \ Y ,+1 r' I T 1 t t i1 I a. .t 1 , ''.. ,. ) '' j 12 ., Lt 1 a :r" It"t : 4. 1{ a ... 9'\t-xu.t'.n"il (tt\* -){:_ ' .1 J.:,". ':: .a I." ,. ^j1 1.' ) 'i.'t.- i- ,, ?.' 1t 'It ,O ACCCSS 3OrJ, fr.I 5L-\\t)R,L\{ H =13 195 PROPOIEI) [ 0t.dTIO\: , ti &!q.,,, "a 3 TC BO *1 4-?96 PTPELI ili.Gf,xtsTll{ TIN6xrs FEilCE RAILROAD PUC'(ETT. LAND COMPAI{Y, CORP Location I\Iap 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 ne'imptlmented anO-CopnE 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 ltlanagement Plan (SW[MP) 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, :luI recommends asking for an explanation of where the swMP is in the state CDPHE permitting Process. The Application also includes an area wide spill 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 currenfly a deveroped coGCC weil pad pranned for approximately 1B 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 foitre proposed facility and the placement of the project on an existing well pad will minimize additional impaits. 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 t-70 - 500 ft. away from Wel Approx. Location of lsland Ranch Well Pad LocationProposed Nolte SWD 1- 14 lnjection Well Location / Nolte L4-796 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 WellPad Location I I ln ili /t 5N 6&. ,8" 1& gel Caerug Piceance LLC PROPGED INJiC1ION PAD Stcrsl 14, T7S, R96W, 6th P.M sz 1/4 SE 1/4 sc{' ' 60 o^tc c; :l l. oi^gll BY Ig Rfv ilr.tr- l{. . ! B t, ltt,tJfill tl lt r! f,h, I l t I I i I ! t I I I I I ; I I I I I i t I I I -) Nolte 14-796 Well 4 r )0 rrili:r$Lri ,1r ITLL PAO 714 f.'.t"1, I oo oo t\ t-\ P" I a I I i I t \ LAYOUI 'j;:'- puF,HoU!: . co{ rrlrtr- !T te .i -..ilro^,Yr0;t it..x:-'RUUI{} tltil?^il Et,rt/'tgtilJc e L^no SuRYtYtto &b&tu.r.4ww{ltt,)o'tl 5 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. o 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.. SWIMP permitting was not mentioned in the application. The applicant should provide a response as to the status of SWTMP permitting for the site. 2. Garfield County Road and Bridge Department, Dan Goin District 3 Foreman (See Exhibit 4):o 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. . 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): . lnstall bentonite clay layer to be installed under the pad, if possible, to prevent contamination of groundwater. . 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. . Requests that sound mitigation be utilized for the proposed injections well 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 Concerned Citizens (See Exhibit 10): o Noted concerns with earthquakes caused by this and other injection wells in the area. o 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. g. Battlement ttlesa 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 euality Division; (b) Town of Parachute; (c) Grand Valley Fire Protection District; (d) School District tb;'(e) Battlement Mesa Metro District; (f)Colorado Department of Transportation. IV. STAFF COMMENTS AND ANALYSIS In accordance with the Land Use and Development Code, the Applicant has provided detailed responses to the Submittal Requirements and applicable sections of Article 7, Divisions 1, 2, and 3, including Section 7-1OO1 lndustrial Use Standards' The Application materials include an lmpact Analysis and related consultant reports, technical studies, and Plans. 7-101 - 1 03: Zone District ulations. Co ve Plan & Com oatibilitv The proposed use demonstrates general conformance with applicable Zone District provisions contained in the Land Use and Development Code and in particular Article lll standards for the Rural Zone District. Regarding compliance 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 Designations Residential Medium High (RMH): Small farms, esfafes, and clustered residential subdivision;-density determined by degree of clustering and land preserved in o7en condition. Secfion I - Natural Resources /ssues*The county maintains high air quatity standards, however there may be a propensity-for air pottutants fo exisf in the western part of the county Goals1. 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 witt encourage and cooperate with the protection of criticat habitat in-cluding state and federally protected, threatened, or endangered spectes. Section 9 - Alineral Extraction Goals1. Ensure that mineral extraction is regulated appropriately to promote responsibte devetopment and provide benefit to the general public. 2. Ensure thai mineral extraction activities mitigate their effects on the natural environment, inctuding air quality, water quality, wildlife habitat or i m porta nt v i su a I resources. 3. ln working with mineral extraction projects, the county will protect the pubtic health, safety and welfare of its citizens. Policies2. itlineral resource extraction activities will protect critical wildlife habitat as identified by state and federal agencies. Development within fhese designations thit cannot be designed, constructed and conducted so as to iave a minimum adverse impact upon such habitat or these wildlife specles shall be discouraged' 4. Fa'citities that are appurtenances fo oit/ gas development activities (compressors, etc.) are considered appropriate in all land uses so long as they'meet the respective mitigation requirements of the ULUR to maintain compatibility with surrounding land uses. 8 Town of Parachute Subiect Site Open SpaceJPublc Land Res i{ ( Battlement Mesa Lands Lands The location and design of the proposed facility is in general conformance with the Comprehensive Plan Policies subject to proper mitigation of impacts. Com rehensive Plan De n The Application has also provided information on neighboring land uses indicating the general character of the area. The request demonstrates general compatibility with adloining 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: Pu lic 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 & Roadways 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 traffic 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 information 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: Aoricultural Lands With no new disturbed areas, no additional impacts on nearby agricultural lands are anticipated. 7-202: Wildlife Habitat Areas The Applicant 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: Protection of Water Bodies Potential impacts on water bodies has been addressed by the Storm Water lVanagement 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: Drainaqe 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 notedpreviously, the County Engineer and Public Health Department suggest animpermeable membrane or bentonite liner with the secondary containment. Staff suggests the inclusion of an impermeable liner as a condition of afproval. 7-205 Environmental Qualitv The Applicant has represented that the use will not be subject to permitting through the Colorado Air Pollution Control Division. The condensate tanks currently on sile are 1,1, SHEET I {00 sc- IAN'( {00 88t IANX 100 BsL TAIT( *- goot ,l@ 8gL tANX 500 oBL rATK Caerus Picsance [J.C lq ol Ocfr AI I ? o8 ts DI J A R'S'o -:-r*r PR@OSC0 SECONDARY CONTAINMENT PLAN &OETA{.S -srss- scAL[ A5 gto$.l 0A1f,.06-17-1. onA*{ 8Yr P.L.8. R€V.: 06-JO-1.. P.U.8 PROPOSED IN€CNON P^D sEcTlor,r l+, T7g R96W, 6th P.Usr 1/1 SE t/1 I \ S,--u\_'ts - -F . &blirS P-pdb: -r- r +. . Progo*d Pi6rctht used in conjunction with well production and are regulated by COGCC and CDPHE' A condition of approval should call for the Applicant to obtain and keep current all permits as required by the CDPHE and maintain compliance with all conditions contained therein. Storm Water l/anagement 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 single 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 stoied 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 installation method for the liner prior to issuance of the Land Use Change Permit. The Batilement lVlesa Concerned 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 lr/esa 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 conditions/requirements is included as recommended Condition #g. 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 7-2O8: 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 well facility. 7-301 & 302: Compatible Desion. Parkinq. and Loadino 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: Landscapino As an industrial use landscaping submittals and standards are not applicable to the proposal. 7-304: Liqhtinq 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 Trails Trails standards are generally not applicable based on the industrial nature of the proposal and surrounding uses. 7-1OO1 INDUSTR 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 compliance and the following summary addresses key issues. The facility is located on a well pad location. The equipment for the injection well will be aesthetically similar to that contained on the rest of the well pad. 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. All industrial products and wastes will be stored in accordance with all applicable state and federal regulations. 13 o o a 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. The Application includes documentation that the water for injection is from nontributary sources addressing any potential Division of Water Resources concerns. 2 VI. SUGGESTED FINDINGS 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. 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. REGOMMENDATION The following recommended conditions of approval are provided for the Directors consideration. 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. 14 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 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 all applicable Federal, State, and local regulations governing the operation of this type of facility. 5. The facility shall maintain compliance with lManagement Permits, Drainage and Grading Erosion Control Plans for the site. CDPHE Storm Water Plans, Reclamation and 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. 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 professionalto 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 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 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.Total water storage shall not exceed 5,000 bbl., including any condensate tanks. 16 Guffield County PUBLIC HEARING NOTICE INFORMATION Please check the appropriate boxes below based upon the noflce that was conducted for your public hearing' ln additlon, please initlalon the blank line next to the statements if they accurately reflect the described action. d My applicatlon requlred wrltten/malled notice to adjacent property owners and mlneral owners. W Matled nouce was completed on the lb,b oayof ,Senl"rnho-2014. * All owners of record within a 200 foot radius of the subject parcel were ldentified as shown in the Clerk and Recorder's office at least 15 calendar days prior to sending notice. &All owners of mlneral interest in the subject property were identified through records in the Clerk and Recorder or Assessor, or through other means tllstl -- Please attach proof of certified, return receipt requested mailed notice. tr My apptlcation requtred published noUce. Nofice was published on the _ day of I Please attach proof of publication in the Rifle Citizen Telegram My application required postlng of Notice. Notice was posted on the _ day of 20L4. 2014. tr Notlce was posted so that at least one sign faced each adjacent road right of way generally used by the publtc. ! testlfy that the above informatlon ls true and accurate. 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(9 al www.lnlormatlon, vlslt ourFor U.S. Postal Service'"' CERTIFIED MAIL@ RECEIPT Domestic Matl Only nffinffirf&0fr ffi $ *0.ri? fi.30 52.?0 $0.t0 t6.49 lnformatlon , vlsit our webslte al www. orWBoxNo. Se€ Bever$e !or lnsttuctionsPS Form 3800, JulY 2014 or PA Box No- PS Form 3400, Juty 201 a See Revcrse lor lnslrucltons U.S. Postal Service"' CERTIFIED MAIL@ RECEIPT Domestic Mail Only at PO BoxNo. Soe Beversc lor lnslruclronsPS Form 3800' JulY 2014 U.S. Postal Service'^' CERTIFIED MAILO RECEIPT Domestic Mail only $$ di r:d*J h., a*.TAMW ffiq&ffi ; .i, 1- s t0.{9 n.J0 t:,70 t0.00 ?q. -t:r visit our website at www.For Pffiu*f .ffirLrffi ; ..' $-, LJ * iX $ t? .In ts $ inlormalion, visit ou. webslle 8tFor otPOBdl'lo. See Rcvorse lor lnstructionsPS ForN 38oo, JulY 2014 U.S. Postal Serv CERTIFIED M ice'.' 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I5s$ 0 $0.4? $1.30 $?.10 $0,00 $n.{9$ orPO gox No- For del lntormatlon, vlsll our webslte 8t See Rcv€rse tor lnslruciiona PS form 3800, JulY 2014 EXHIBIT I t] David Pesnichak From: Sent: To: Subject: Dan Goin Thursday, SePtember 18,20L4 8:00 AM David Pesnichak Nolte SWD 1-1-4lnjection 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 1 EXHIBIT ( MOUNTAI ENGINEERING, INE. Civil anC Envirr;,*rl:r*ni,:i f onsr-rttirrg and Ds$igtx October 8,2014 Mr. David Pesnichak Garfi eld County Plamring 108 8th Steet, Suite 401 Glenwood Springs, CO 81601 RE: Itevierv of Nolte SWD l-l4Injection Well: GAPA-7985 Dear David: This offrce has pertbrmed a review of the documents provided for the Administrative Pennit Review application of the Nolre SWD l-14 Injection Well for Puckett Land Co. The submittal lvas tbundlo be thorough and r.vell organized. The revielv generated the following comments: L Concerning the seconclary containment of the stor:rge tanks. An impervious liner is appropriate-. Bentonite and/or a membrane liner ale typically adequate. The Applicant riro"ta provi<1e construction cletails and/or specifications concerning the liner design- 2. The Applicant shoulcl address the equipment to be housed ',vithin the proposed building' This may require other submittals and/or evaluations concerning noise, emissions, etc. depending on pumps, compressors, generators, or other equipment to be housed within' 3. The Applicant should provicle evidence of stormwater management permitting with the CDpHE if the site plan-is part of a larger overall plan if the disturbance of that larger plan exceeds one acre. Feel fiee to call if you have any questions or commeuts Sincerely, Mo Cross l1 Hale, PE 826 ',i Grancl Avenue, Glenwood Springs, CO 81601 P: S70.945.5544 F: 070.945.5558 www.mottntaincross-eng'com I Gurfield Coun ty Vegetation Management October 7,2014 David Pesnichak Garfield County Community Development Department RE: Nolte SWD 1-14 lnjection WeIIGAPA-7985 Dear Dave, Thanks for the opportunity to comment. Noxlous Weeds The noxious weed inventory submitted in the application is acceptable. The Coung and State listed noxious weed, Diffuse knapweed, and has been found about 2 miles west of the site. Staff requests that the applicant monitor the site annually for Diffuse knapweed and treat on an as needed basis. Revegetation The Reclamation Plan and proposed seed mixes are acceptable. The Colorado Oiland Gas Conservation Commission regulates reclamation on this site. Please let me knou if you have any questions. Sincerely Steve Anthony Garfield Coun$ Vegetation Manager 0375 CountY Road 352, Bldg 2060 Rlfle, CO 81650 Phone: 970-945-1377 x 4305 Fax: 970.625-5939 Garfield CountY EXHIBlT I 7 Public Health 195 W. 14th Street Rifle, CO 81650 (970) 625-5200 Garfield County Community Development 108 8th Street Glenwood SPrings, CO 81601 Attn: David Pesnichak 2014 Blake Avenue Glenwood SPrings, CO 81601 (970) 945-661 4 October 2,2014 Hello David, My comments for the Nofle SWD 1-14 lnjection Well Administrative Permit Application are as follows - lt is much easier to review an application electronically that has tabs broken out for each section rather than scrolling tnroutn-, ,"ry large document. ln the future, please break down sections by tab eithei on the CD or in the PDF itself' - Water euatitv: oLspite the fact that no waters of the US occur within the project area, the close pro*irnity[t tne 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 containeO witnin the fiad and not allowed to seep into groundwater' - Air qualitv and Nuisance Conditions oThea@theairqualityshouldnotbereducedbelow accepiable levels established by the'Colorado Air Pollution Control Division' Ho*"u"i,l could not find in the application (perhaps becau-se of the format) where there was mention of if they had coniacted the APCD about the need for either an Air pollution Emiision Nbtitication (APEN) or an Air.Permit. Due to the number of tanks on the site, tney could be abore the threshold for emissions that would require them to get a'p"rrit. I contacted the APCD about this issue and have included their email as an attachment' o I did not r"" a specific rn"r,tion of Nuisance Conditions in the lmpact Analysis' The application should address how dust, odors, and glare, and vibration will be controlled during the construction of the site, drilling oitne wells, and operation of the facilitY.- Earthquakes: *nit" tn" science behind this issue is still somewhat up in the air, reports of mlect,on wells leading to increased seismic activity have been becoming more prominent recenly. Operators of the injection well s-hould pay close attention to the well's capacity to prevent any earthquakes' Thank you, .\ ,'-! 'i 'l ''l/1,, i1{t 'tt"i '#"'t ltt-ur7" 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 02,2014 3:41 PM To: Morgan Hill; Lisa Devore - CDPHE Subject: Permit for injection well Hi Morgan, 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, pneumatic devices or pumps used to inject the water and even fugitives may also be subject to regulation depending on srze. 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. Thanks! lngrid Hewitson, MPH Air Quality Planner State of Colorado, Air Pollution Control Division P: 303.692.5331 | C: 303.868.7317 | F: 303'782-0278 4300 Cherry Creek S. Dr., Denver, CO 80246 email: ingrid.hewitson@state.co.us County Oil & Gas Liaison Kirba Wynn 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. APP|ication looks OK as long as the oPerational Pl an 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)". lf th ere is additional tankage,such as for condensate, onsite the stated oPeration al plan may exceed the 5,000 barrel threshold and thus require a seParate permit based on totaltankage volu Kirby Wynn Sent: To: Cc: David Pesnichak From: Follow Up Flag: Flag Status: Charles Hall <cdhallt4g@gmail'com> Tuesday, SePtember 30, 2014 l-:03 PM David Pesnichak Keith LammeY Nolte SWD L-14Injection Well Flag for follow uP Completed Subject: David Pesnichak, The Battlement Mesa service Association's (BMSA) Oil and Gas Committee has reviewed the Nolte swD 1-14 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, ieducing the need for water truck traffic. Charles Hall Chairman, BMSA Oil & Gas Committee 1 BATTLEMENT CONCERNED CMZENS Battlemerfi Mesa, CO 8 1 6 3 5 September 30,20L4 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 Madam: 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 ATTACHMENT'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 ls/ BCC co-chair dgdeva nney@comcast. net Doug Saxton /s/ BCC Director douglassaxton @gmail.com ATTACHMENT'A' http ://www.eenews. net/en e revwire/2014/09/1Glstories/1060005g53 USGS links Colo. quakes to gas drilling Mike Soraghan, E&E reporter Published: Tuesday, September 16, 2Ol4 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 pattern 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 USGS scientists who worked on the study. The peer-reviewed study, published today in the online version of the Bttlletin of the Seismological Society of America, says that there's been a big increase in earthquakes in the Raton Basin around trinidad, Colo., und tt "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. oI It o !l I U 1970 '19E0 t990 20oo 20.to [+] A 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 Irving, Texas-based pioneer Natural 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 l8 months, Pioneer has been monitoring a sensitive anay 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. lnstead, they are tapping into the natural gas foinl in coal formations of the Raton Basin. Coal beds are found much shallower than shale, but producirr-g f.o- them also creates significant amounts of wastewater. The Raton field, though, is in decline. As with other studies from Arkansas, Oklahoma and Texas, the USGS study links the quakes to disposal of waste fluid. From lgT2through July 2001, there was one quake in the area larger than magnitude 4- Then 12 occurred between August 2001 and 2013, mostly within 3 miles of active disposal wells. The study says the statistical likelihood that such a rate chang. *o.rid occur if earthquakes behaved randomly in time is 3 percent' ln addition, earthquake activity remains low outside the drilling zone. As soon as the shaking started in 2001, seismologists were suspicious that the conlulsions in the Raton Basin were linked to drillingl But for years, USGS scientists were equivocal. McGarr said by the time of the. magnitude-5.3 earthq:uake, the ielationship between injection and earthquakes was a lot more conclusive' Another look at Colo. quakes prompted by the magnitude-5.3 quake, which occurred the same day as a better-known magnitude-5'8 quake that shook Virginia ind the East -oast, 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 yeari and began to poi"t the finger at drilling activity with increasing certainty. The series of foreshocks and aftershocks in 201 1 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 orr", ih" study says, are "high-in;ection-rate, high-volume wells." The ARP wells are within 1'7 miles of where the 2011 sequence began. ,,The proximity of the tARp] wells to the 2011 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 Geologii vince uattnews said, 'fThese cowboys from USGS are sure these are induced' They're jumping to conclusions" (ElleIgWLe, 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. In July, the state allowed the well to reopen at a lower pressure and less injectiln 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, wheie the Army manufictured chemical weapons, were the {irst 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 field dramatically increased, rising from a median rate of 500,000 banels a month to 1.2 million barrels a month. The earliest earthquakes were located in the eastem 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: @MikeSorashan I Email: msoraqhan@eenews'net EXHIBlT lt Oil e Gas Liaison Kirby Wgnn Memorandum July 3, 2014 RE: Review of COGCC injection well permitting, regional seismic monitoring and induced seismicity ln response to BOCC decieion to call up a Director's decision regarding an injection well permit application, I gathered relevant information regarding: o Currently permitted injection wells in Garfield County o COGCC injection well permit review process o Current seismic monitoring and obgerved geismic activity in western Colorado . Reeearch related to induced seiemicity from injection welle Cunently permitted injectlon wells in Garffeld County According to COGCC records, there are currently 60 injection wells that could potentially be utilized for waete dispoeal. Of those, 26 have been uged for gome injection activity since 2013. The attached map displays permitted injection wells near Battlement Mesa. COGCC injection well permlt review proce.t Discuesed with COGCC staff (Koehler and Eisinger)their injection well permit prooess. COGCC reviews geologic Etructure in vicinity of proposed wagte injection wells and evaluetee potential seismicity, including a review of all regional geiemic events trom 1973 to preaent. They aleo require teets of the well and surrounding formation characteristics. Review process is geared toward determining suitability of the well for waste disposal as well as operational preecure and injection volume limits along with various Conditione of Approval meant to reduce the possibility of adveree impact (i.e, induced seismicity) and to atate mitigation requirements if adverge impacl ic suspeoted in the future. When COGCC determines a proposed well could preaent a risk for induced seicmicity, they can and do place permit requirements such as shut down procedures in cage of a nearby seiernic event. Current seismic monitoring and obseryed seismic activity in western Colorado Western Garfield County is not prone to seismic activity based on discussions with and data provided by Anne Sheehan, Professor of Geophysics at CU Boulder. Dr. Sheehan is the lead researcher conducting investigation of the 2014 seismic events near Greeley Colorado. Reeeived similar information from COGCC and Paul Eatle, Geologic Hazards Team at the USGS National Earthquake lnformation Center. Drs. Sheehan and Earle indicate our area is currently monitored for earthquake activity at a resolution to note earthquakes of minimum 2.5 magnitude event with a location determination of +/- 6 miles. Research related to induced seismicity from injection wells Reviewed several recent academic and other publications regarding factors that have caused induced seismic aetivity from by waste water injection. The phenomenon is relativelprare as compared to the prevalence of waste injection wells but can occur under certain conditions. COGCC evaluates permit applications with the primary objective to prevent approval of injection wells that could cause induced seismicity such as: large or active faults and perturbation of rock pore pressures in the proposed injection intervals. lt can be especially important to evaluate less permeable and more brittle formations proposed for injection as those can be the most susceptible to induced seismicity if not managed carefully and using information about the permeability and capacity of target injection intervals. The attached white paper preparcd by COGCC descnbes their research and regulatory response to the latest understanding of induced seismicity. Summary quote from the white paper: "COGCC believes safeguards are in place, in accordance with federallaw 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 potential for 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." Wynn 2 Enclosures Bibliography COGCC,IOJI, COGCC Underground lnjection Control and Seismicity in Colorado, COGCC Staff White Paper, 5 pages. Earle, Paul, 2A14, July 7,2014 USGS National Earthquake lnformation Center letter response to query about regionalseismic monitoring capabilities, 2 pages. Eisinger, C.,2014, Personal communications from COGCC Senior Research Scientist supervisor regarding COGCC UIC application review procedures and curent UIC wells in Garfield County. Koehler, 8,2A14. Personal communications from COGCC Underground lnjection Control (UlC) Supervisor regarding COGCC UIC application review procedures. National Research Council. lnduced Seismicity Potentiat in Energy Technologies. Washington, DC: The National Academies Press, 2013,269 pages, Ellsworth, W.L.,2013lnjection-lnduced Earthquakes, article in SCIENCE:VOL 3411ZJULY 2013,7 pages. Zoback, M.D.,2012, Managing the Seismic Risk posed by Wastewater Disposal, Article in Earth Magazine, April2012,6 pages 3 + + oo = :l :! =o =co o .9.c ;o f E'ooo CL e 0- Oooaa g c .e Eo E- i .9 oa Eooco C')C g =-o E Lo oo E- !,q) tro!, Lott .> G og E _o g tr .96otr s ) a =g co o .0,E. ; .E (, s .E! Lo ooP2v#o8 -e2oo33trtr.9 .9aa aattootr- E' t, -Lo E)oJ 6oLo 6oo =I Eo Eo Iflaoo osf .E L -o 'EoIIflt,o .I E. aa* a o o o 6,', i ,6" .t I ,) 18\ t].G,l I a -i I ,/-r.r-\( ct)\9/ "-l-. \ I .) t'- _,"] ) / \ STATE OF COLORADO otL&GAS CONSERVATION COMM ISSION DEPARTMENT OF NATURAL RESOURCES John W. HickenlooPer, Governor 1120 Lincoln St. Suite 801 Denver, CO 80203 Phone: (303) 894-2100 FAX: (303) 894-2109 rlww. colorado. gov/cogcc January 19,2011 COGCC UnclerorounCl tniection Control and SeismiciW in Coloraclo colorado's earliest documented earthquake occurred on December 7, 1870.The colorudo iinscriptstated, "A careful observer at Fort Reynolds, 20 miles east of Pueblo, noted that botles 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 crea[ed when large blocks of the Earth's crust move with respect to one another "iong , fault plane. The Col-orado Earthquake Hazard Mitigation Council published a map in 2008-of earthquakes and faults in colorado. The map can be obtained at the colorado Cloloqicat Su'ruev (CGS). The United States Geological Survey (USGS) mgl{alns_a database of Colorddo earthquakesat the National Earthquake 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 iocty Mountain Arsenal (t'he "Arsenal") near Denver. Earthquakes began after a 12,000-foot ifition wellwas drilled it tne Arsenal for the disposalof waste fluids. lnjection commenced in Mlrch 1g62. Shorly 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 frornthe Arsenal well at a very slow rate in an effort to reduce earthquake activitv. ln Nicholson, 1ggo, Earthquake Haiard Associated with Deep well lniection- A Report t; i;'i.i. i.i.n: inl.ction votumes 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 bolorado Division of Water Resource's (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 Sburces of Drinking Water (USDWs) from impacts related to underground fluid 'ri".ii6n practices. The EpA dedgated piimacy for regulation of Class ll Ulc wells to the State of Colorado for underground injeJtion oi oil and gas eiploration and production waste on April 2, 1gg4. Colorado has atministerld the UtC proqrim 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. epa.qov/tvpe/qro u ndwater/u lc/index' cfm DEPARTMENT OF NATURAL RESOURCES: Mike King, Executive Director CoGCC COMMISSIoN: Richard Alward - John Benton - Thoma" r- compton --oea-n-n-Ciaisllom'y Fto'lton - W Perry Pearce - Androw-Spielman-- Mike King - Chris Urbina coGcc STAFF: David Nestin, Director- MargaBt Asn, rieto tnspeaion n/lln"g"i - duoi" arrd*in, Envircnmmtal Manager - stuart Ellswofth, Engineering Manager COGCC Underqround lniection Controland Seismicitv in Colorado (cont.) The Colorado Oil and Gas Conservation Commission (COGCC) is the State regulatory agency that permits Class ll UIC wells for injection of oiland 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, Rule 326 Mechanical lntegrity Testing, and Rules 706,707, and712, which identiff FinancialAssurance requirements. The permit process involves the review and approval of Form 21, Mechanical lntegrity Test, Form 26, Souree 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 quali$, 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) waterwell information, 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 verify 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 veriff 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 radialvolume. 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 injection, because they are considered to be USDW's 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 operato/s requested injection rate as a condition of permit approval. COGCC's policy is to keep injection pressures below the fracture gradient, which is defined uniquely for each injection well, minimizing the potentialfor seismic events related to fluid injection. Some injection wells do not need to inject under pressure because the formation willtake water on a vacuum. Beginning in September of 2011, the COGCC UIC permit review process was expanded to include a review Page2 for seismicity by the CGS. CGS uses their geologic maps, the USGS earthquake database, and area-specifii rnowtedge to provide an opinion ofseismic potential. lf historical seismicity has been identified in the Jicinity of a proposed Class ll UIC well, COGCC requires an operator to define the seismicig potential and tne 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 provid'ing tecirnical expertise regarding seismicity and possible relationships to Class ll UIC wells. COGCC believes safeguards are in place, in accordance with federal law and COGCC's rules and policies, but we wil-l continue to ieview induced seismicity findings in other parts of the country with interest. The current safeguards defined by COGCC permit proce_ss_ are injection volume; pressure below the fracture giadient; and, input frorn the CDWR and CGS to reduce the potentialfor induced seismicity related to UIC Class ll wells. COGCC strives to continually impiove our evaiuation methods, and the effectiveness of regulations, rules policies and procedures. COGCG Underqround lniection Controland Seismicitv in Colorado (cont') References 1. USGS Earthouake Hazards Prooram, Earthquake History of Colorado. http'//earthquake. usqs.oov/earthq uakes/states/colorado/h istorV. ph p 2.DivisionofMinera@eologicalSurvey,RockTalk,Volume5Number 2 April 2002. 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 rational assessment, Seismo/ogical Research, Lefters, v. 64, p' 207-224' S. Nicholson, Wesson, 1990, Earthquake HazardAssociated with Deep Well lnjection- A Report to ine U.S. E.p.A., USGS Bulletin 1951, 74p. (Note: Also available as USGS open File Report 87-331). default.htm 6. Osborne, Paul, ediior ,2002, EPA Technical Program Review: Underground lnjection Control Regulations, EPA 816-R-02-025. 7 Shirley, Kafny, 2001, Colorado Quakes Cause Concern, AAPG Explorer, htto://www.aipo.oro/explorer/2001/12declcolo ouakes.cfm, last accessed 1111712005. Page 3 WhatisaClassllUndergroundlnjectionControl(UlC)well? Class ll UIC wells iniecl nrliOs associated with oil and natural gas production' Mosl of the injected fluid is salt watli ibrine;, which.is brought to the syrf.lce in the process of producing ie*tractingl oil and gri.-tn'ro.e oilfields, brinJand other fluids are injected to enhance (improve) oil and gar piodr"tion by^using an enhanced recovery method known as "water flooding." There are approximately 885 active ct".t ll ulc wells in colorado, with 297 operating as exploration and pioiuction (E&P) waste disposalwells and 588 enhanced recovery wells' ine waste disposai*Lfr. inj".i appioximately 355,000 barrels of brine Ber day' What are the types of Glass !l UIC wells? There are three types of Class ll injection wells associated with oil and natural gas production' 1. EnhanceO Oiliecovery Welts GOnl inject brine, water, steam, polymelg' naturalgas and/or carbon dioxide into oil-bearing foimations to recover residual oil' This is also known ". r".onO.ry or tertiary te.oi"ry. The injected fluid thins (decreases the viscosity) oiOitpf""L" tne resiOuat oil and gas aher primary productio.n' which is then available tor i"corery. ln a simple "onngut;tion, a single injection well-is surrounded by multiple production wells. proouction *ltrc nring oil and gas to the surface; the UIC Program does not regulate production wells. Enhanced recovery wells are the most numerous tvp" oic-rirs llwells, iepiesenting as much as 60 percent of the class ll Ulc wells in colorado. There are currentty 588 permitted EoR wells in colorado' 2. DisposalWells inject brines and oiher eai'waste fluids associated with the production of oil and natural gas operations. \lVhen oil and gas are produced' brine is also brought to the surface. The brine is segregated from the oil and gas by surface production facilities. rt is inen injected intdth; same deep underground formation or a similar formation "p".inlrlrv p-ritt"o t- oi"porrt. btass lt.iisposalwells can only be used to dispose of fiuiOs ,rrobirt"O witfr oit anOgas production' Disposal wells represent about 30 percent of Colorado's Class ll UIC wells. There are 885 total UIC Class llwells with 297 operating as E&P waste disposalwells tn Colorado' 3. HydrocarOon-Siotage Wells inject liquid hydrocarbons in underground formations (such as salt caveris or abandoned irydrotarbon fields) where they are stored' generally, as part of the U.S' Strategic Petroleum Reserve' ls UIC Class ll Exploration and Production Disposalthe same as hydraulic fracturing? No. lnjection well opeiations are not nvarzuriciracturing. Hydraulic fraciuring and underground injection are not related activities. Clais ll waste dispoial is conducted below rock fracture gradient so as not to create new fracture". Ctr"r ll waste disposal occurs over a long period of time, typically many years during the life or, urc well. on the other hand, hydraulic fracturing is performed over a snort period oi1ir9, typically hours, with "flowback" occurring over the course of several days or weeks. By definition, it"ttrt"9 used for hydraulic fracturing are above the fracture gradient, with the inient of inducing new fractures. within a hydrocarbon extraction zone and doeJ not include the permanent emplacement of fluids. What are the requirements for Class llwells? A state has the option of requesting prir..viorClass ll wells under section 1422 of the Safe Drinking Water Act: section 1422 requires states to meet EPA',s minimum requirements for Ulc programs' programs authorizeJ under section 1422 must include construction, operating, monitoring and testing, reporting, and closure requirements for well owners or operators' Enhanced oil and gas recovery wells may either be issued p"rriii or be authorized by rule' Disposalwells are issued Page 1 COGGC Underqround lniection eontrol - Frequentlv Asked Questions (cont.l 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 the wells. COGCC has primacy to administer EPA's requirements for Class ll UIC wells.. lndustrial & lr/unicipal Waste Disposal 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 lllwells in Colorado. . Shallow Hazardous and Radioactive lnjection 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.. Geoloqic Sequestration Wells (Class Vl) - There are no Class Vl wells in Colorado. Page2 United States Department of the Interior GEOLOGICAL SURVEY Geologic Hazards Team MS 966,8ox25046 Denver, Colorado 80225'0046 30 June,2014 I l I AL I I I Dear Kirby WYnn and Douglas Saxton, This letter is in response to questions I received from both of you concemitrg usGS monitoring capabilities in Garfield county. There were several questions raised in our discussions' llhat are the current uscs earthquake monitoring procedures and capabilities in Garfield County? The usGS National Earthquake Information center (NEIC) publishes earthq-uake locations and magnitudes for arl detected earthquakes magnitude 2.5 or'rarger or reported felt within the U.S. In your region, NgiCt procedure is to rap-idly release earth(uakes that are reported felt and/or those with -ugnitod" +.0 o.larger. It may iake several weeks before the smaller earthquake, *. p.o""tsed and released on the website' what resources are required to improve the monitoring capabilrties in this and other regions? currently, the usGS NEIC rr."ir", data from 22 stations within 200 km of Rifle' co' The vast majority of these are to the southwest in Paradox valley' These stations are run by the Bureau of Recrarnation to monitor their brine injection we[s. with this station coverage' we estimate we can automatically detect earthquakel with magnitudes 2'5 andabove' Accurate estimates of location uncertainty *"rld ;;;i; t rtt.. {oi{, but horizontal uncertainty is likely in the 10 to 15 km range with similar ", #;t";;;certaintyin our estimates of earthquake depth' To achieve location uncertainties in th? I km range andtg robustly detect quakes smaller than about 2.5, requires the installation of a m.a t"it*ii *ruy similar to that currently being run by Dr. Anne sheehan near Greeley, CO. Additional resources would be required to build realtime capabilities *a p.o"L* "urtftqirur."s falling below the ct,rent USGS magnitude 2'5 threshold' What type ofseismic activity should trigger an injection well be shut down? The USGS is not a regulatory body and has not authored a specific "stop light" sYstem for 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 possi ble sources for 1 advice include the Bureau of Reclamation since theY have been seismicallY monitoring disposal wells in Paradox Valley, Colorado for many years' Sincerely, Paul Earle USGS National Earthquake lnformation Center Telephone (303) 27 3 -8417 pearle@usgs.gov Liquid carbon dioxide has been injected into the Sleipner gas- and oilfield in the North Sea for 15 years without triggering any seismicity' tt serves as a good example of how fluid injec- tion can be done safelY. Managing the Seismic Risk Posed bY Waste-water Disposal Mark D. Zoback f--t rom an earthquake perspective, 2011 was f , = .o*rrLnhk' \,ear. While th"e cl-evastation .-l o lculqrr\uvlL rL l- u..ott panying the magnitude-9'0 Tohoku I earthquake that occurred off the coast of Japan on March 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 natural events, the types of earthquakes that occur from time to time in all intraplate regions. For example, the magnitude 5.8 that occurred in central Virginia on Aug. 23 was felt throughout the northeast, damaged the Washington Monument, and caused the temporary shutdown of a nuclear Power plant. This earthquake occurred in the Central Virginia Seismic Zone, an area known to produce relatively frequent small earthquakes' However, a number of the small-to-moderate earthquakes that occurred in the U'S' interior in 2011 appear to be associated with the disposal of wasiewater, at least in part related to natural gas production. Several small earthquakes were appirently caused by injection of wastewater associated with shale gas production near Guy' Ark.; the largest earthquake was a magniiude-A7 event on Feb.27.In the Trinidad/Raton area near the border of Colorado and New Mexico, injection of wastewater associated with coalbed methane production seems to be associated with a magni- ird"-5.3 "r"nt that occurre d on Aug'?2, and small earthquakes that appear to have been triggered by www.ea rth magazi ne.org o o i oE 38 . EARTH APril 2012 * ,. .'.1 . . J .'5+ .f.4 i i.L tu ,*{. t t.t a. t 1.. :'j. a. .ftFrr aL ( Iti t ii ti CJ I .l .c J ,alii:' -. l-, '{ 10' 1&5' 100'95 90-85 80"75 7A"{i5 tr5 49" 45" 40" 35 30' 26 45 45" 40- 35" 30" 26 1i0"1 05"100"95 l, Ealthqu akes atlove maEnitucle-3.O trave been recorcJed oy the U.5. Geological Survey in the Central and Eastern 1..!nited States and southeastern Canada since 1960. The dates and largest magnitudes 70"80"6)90" associated witfr tece!1t eai'tl-rq uakes a ppa-.el1ti y ereL{ lJy fiuic.i iiijectioil are i1o'leLi o f .9oo a \f{l o ! IoN .i ! a wastewater injection occurred on Christmas Eve and l,Jew Year's Erie near Youngsto\ /n, Chio, ihe largest of nrhich r.aras a magnitr-rde 4'0' Althougi'l theie has been specuiation that the magnitude-5'6 earth-quake tha-t occurred in Oklahoma on |dor"' i may have been triggered by simllar fluicl injection, no iinkage betweeir this earthqual<e anci fluid injectic;n has been established. -fhe occurrence of injection-rei ated ea rthq urakes is understandabl,v of concern to the pr-rblic, govem- nrer rt reguiarors, poiicynrar€r> ctrl!l it rri r'rstr 1' ;rii i<e" Yet it is irnportant to recognize that r't'ith proPel" plannlng, monitoring and resporse, thc occttrrt'nce tf sma1l-to-moderate earthquakes associateci wiLh fluid injection can be redltced and the risks associ- rted wrlh such erCntS eflct-tively marriged" Ncl earthquake triggered b-y f1i-rid iniection l'ras ever caused seiions injury or signific;rnt tlarnage' Moreovet approximately 140,000 \^/aste'v'/ater ciisposal rarells harre been oper;iting safety.an<1 without incicieni in the LI.9" fol many decades' 'Lhat saicl, we have klrotn;rt foi ttir'lre ihart 40 years that eari'thcluakes carL bc triggereel [r1" flr,ric! injection. I'he first rvell-str-rdied cases 1"/erc ear thquakes tr:iggered bv r'vastc disposai eJ tht' ii.o,:l<y Mor-intain arsenal near f)envcr, Colo'' in lhe earl,v 1960s, ancl by v'rritcr rnjection a't the l{arri;eiy rilii"l.i in western Coiorado in the iate '5(.s ancl eariY'7[]s. ,ir,rch qltaices t;ccLlr rrvilett rnti--asittg p()r'(' prr--'r- eu,'e at clepth causeel by 1'lr-ri'-1 injcctiori i'ccluces th,: clfcctii,e i..otmal sircss aciing perpcncliculat' to pre-existi ng iauits. l he eifectirre normal stress or a iault can bc thor-rg;ht o1'as a l'orce that resi:"is shaar mo\./cmorl - mr-ich as hovtz pr-rtting a rrrcigirt r-.1 I bor ina1..e: it ilor"c,,l jlficiilt t'.r slicl'..';iloi:g r1:'': f1<,o,'. Inri:e;rsing pcrre prcssl-lrtl rcrlrtces thc' efiec- tii e rrormal str^eia allowing clasiic t'nergy ali'e'atr' st,ri:ed ii-t brittle rocl< fr:nnatitxs to be relcast-tl in ealthqua irt-' g.'L-l-iese earthqr-la k':s "r" ltu I d so rn e- ,-liry iiave ocr-urred nlly\vay.:s i: resrtlt of slov"il' arci-rmr-rlatir,pl forccs in thc eartl'r rcl;ultirrg ii'orr rr;riLlrai geoltigie ilrocesses - iiriection jt"ist sPeeli:l tt;t lhe Pr,::lt-cs:;. ww$/.earth rna gazi n€.org EARTI'I Aprii 201.1 39 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 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 recentyears, it should be pointed out thatthewater 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 typicaily lasts only a few hours. Thus, while very small earthquakes have occurred during hydraulic fracturing (such as a magnitude-2.3 earthquake near Blackpool, England, in April 2011), these are extremely 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 shouldbe limited) to minimize pore pressure changes. Third, local seismic monitor- ing arrays should be installed when there is a potential for injection to trigger seismicity. Fourth, protocols should be established in advance to define how operations will be modified if seis- micity is triggered. And fiftb 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 reciucing the risk associated with triggered earthquakes. Step l: 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 natural 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. 40 r EARTH April 2012 Shale gas and tight oilare produced in 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 6.0 - should 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 also enables 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 : . ' -1 '.-- -. field is well knowri fromano tne reglonal sucss . basic principles of structural geology and rock mechanics. In other words, only faults of cer- tain orientations are potentially activated during in;'ection in a given area. The earthquakes 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 studies carried out as part of the permitting process, this site would not have been used for injection. www.earth magazine.org o 6 Wastewater from hydrau lic fracturing is trucked away from drilling operations in Pennsylvania in ttre Marcellus Shale and moved elsewhere in the region where it will most tikely be rein- jected and reused. Nearly all of the water used in hydraulic fractur- ing in the Marcellus Shale is reinjected during suisequent hydraulic fracturing operations' fVf"in*t il., it is stored in wastewater impound- Step 2: Minirnize Pore Pressure Chinges at Depth Rocks in the upper part of Earth's crust contain pre-existing po." tpu.", fractures and flaws' These vold spacei are normally fitled with freshwater near Eirth's surface (in the upper 1 kilometer or so) and filled with saline brines at greater depths' Injecting fluids into the subsurface will increase tt " pr"Jt t" in these voids, depending on the ratelt is injected and the volume of pore space available to accommodate the injected fluids' It should be pointed out that injection always o:curs at depths where the injected fluids are isolated from near-surface water supplres' 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 varieff 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 Mircellus Formation of the northeastem U.S. Typically, 25 to 50 percent of the-water used durin[ irydraulic fracturing flows back and needs to be lisposed of. However, because it has been difficult to find suitable injection sites in this ment like this one in Pen o s '6 o osd L '6 co C I o -9oI E o6 region (and quite expensive to haul water great aiit*."t to alreadl operating injection wells)' it is common practice to recycle flowback water by using it in subsequent hydraulic fracture op" rutio-r,s rathe r than disposing. of it. i"'", ":tt:l wells. In the Marcellus, nearly all of the water ls rerycled. That certainly minimizes the pore pres- sure perturbations. Rnother way to reduce the pressure blit9Yp associate<i wilh injection is tr-r utiiize higiiiy permeable regional saline aquifers to dispose tf wastewater. These aquifers can accommo- date large volumes of injected fluids without experien"cin g si gnif icant Pre ssure ch anges' The ftiu.,trr.g"r'Fo"rmation in Texas is regionally extensive and highly permeable - one reason why many of the approximately 50'000 per- mitied wastewater disposal wells in the state have operated for so long, essentially without the occurrence of triggered seismiciry' In cases where saline water is used for hydraulic frac- turing, it is possible to reinject the water that flowiack aiter fracturing into the same forma- tions. When flowback water is iniected into the www.earth magazine.org EARTH APril 2012 ' 41 operational protocols - like perhaps a "traffic light" system - for wastewater iniection sites lo-cated in areas where there is concern about the potential for triggered seismicity:.Green ,""n, go, all systems working Gorredly; yel- low me-ans proceed with caution, seismicity detected; red means stop, seismicity poten- tially presents a hazard. 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 n'iust be taken to avoid large Pore pressure changes' This can be done through modeling prior to injection once the permeability and capacity of the i!-:tlo" 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 plotential injection wells' Because smaller fJts ca., escape detection, seismic monitoring same saline aquifers from which the water used for hydraulic fracturing was produced, pressure in the aquifers decreases over time as more water is pro- duced for hydraulic fracturing than iniected following flowback. Altern-ativety, weak, poorly cemented and highly p".rr,"u'blu sandstone formations would alJo 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 ln theiS years during which a million metric tons per year of carbon dioxide from the SleiPner gas- and oilfield in the North Sea has been injected into the Utsira san,l, a lrighly Porous, regionally extensive saline aquifer. arrays should be deployed in the vicinity of injec- tion wells when there is a catrse for concem that injection might trigger seismicity' 'tn" to"utlon, ur,d -ugttitudes of naturally o".,lrri.rg earthquakes are routinely determined on a rea"l-time tasis in numerous seismically actir,'e regions around the r'l'orld' The irstrumenta- tio.,, artl t"t"metry and analysis techniques used io u..o*ptitt this monitoring are well developed and easiiy implemented at relatively low cost' fy ,rpptu*"niing regional networks with local seismic affays near lnJection wells, accurate loca- tio., of "arihqrraket tttut *igttt be triggered by injection can bt used to determine the locations and orientations of the causative faults' Although small faults cannot cause large earthquakes, even small earthquakes- felt by Ure puUtlc will be a cause for concem and should be monitored. Steo 4: Establish Modification Protocols in Advance Following precedents established to deal with earthquakei triggered during the development of e#anced geJtttermat systems, operators and ,"gutu,o.t shiuld jointly establish operational pritocols for injection sites located in areas where there i, concem about the potential for triggered seismicity. These protocols are sometimes referred to as "traffic light" sYstems' O-- Green *"un", go, btttu operational protocols i and local seismic networks are in place and E injection begins at agreed-uPon rates' operators ! would have a green light to continue unle-ss E earthquakes begin to oicur that appear to be ; www.earth magazine'org proceed with caution: seismicitY detected 42 , EARTHAPril2012 A saline wastewater injection well owned by Northstar Disposa! Services LLC in Youngstown, Ohio. Following several small earthquakes in the area in December 2011, the company halted injection of wastewater into the well, which stopped the earthquakes. The wastewater is from the production of oil and gas. o c6 E o dr related to injection. The occurrence of seismic- ity would be a cautionary yellow light. 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- ctralod dn varrc acn a+ Pancol.' +ha+ a.r+L.-"^L-i Li cLEu e' i =dr i du,u,a r r.dr l6Eii i.r r.r i. tsdr Lr trll.iax,cs could be turned 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 Alter Plans or Abandon Wells In the same way that it's important to plan for the possibility 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 Seismicify 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 'T'owac noer +ha T.)allac-E'nr+ \4./nr+h motrn aroa 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 University. The views expressed are his own. www.earthmagazine.org EARTH April 2012 . 43 David Pesnichak From: Sent: To: Subject: Follow Up Flag: Flag Status: Franco - DNR, Ivan <ivan.franco@state.co.us> Wednesday, October 0L, 20L4 12:48 PM David Pesnichak Nolte SWD 1--l4Injection Well Flag for follow up Flagged David, We have reviewed the Nolte small injection well referral in Garfield County. Thank you for the opportunity to review the application however we have no comments at this time. Regards, lvan Franco, E.l.T. Water Resources Engineer x P 303.866.3s81 / F 303.866.2223 1313 Sherman Street, Room 818, Denver, CO 80203 ivan.franco te.co.us /www.water. state. co. us AffiI COLORADO Parks and Witdlife Department of Natural Resources Northwest Regionat Off ice 71 1 lndependent Avenue Grand Junction, CO 81505 David Pesnichak Garfield County Building and Planning Department 108 8th Street, Suite 401, Glenwood Springs, CO 81601 RE: Nolte SWD 1-l4InjectionWell Dear Mr. Pesnichak, Thank you for the opportunity to review the Caerus Piceance LLc.,proposal for an injection well (Nolte swD r-14) on existing well pad. Please consider the following.comments. The proposed project will occur on a pre-existing well pad, which CPW anticipates will minimize impacts to wildlife. The water will be transported via pipeline, which will also minimize long-term vehicle traffic and human disturbance. This project lies within the boundary of the CPW-PDC (now Caerus) Wildlife Mitigation Plan (WMP); this pian describes the best management practices that Caerus will use to avoid, minimize and mitigate (as necessary) impacts to wildlife and wildlife habitat from oil and gas development' CpW recognizes the project site lies in habitat for multiple species (mule deer, elk, and black bear); however, i. *. satisfied that the commitment caerus has made to protect wildlife and habitats within the WMP boundary is fully sufficient to protect the species that may be impacted. In addition to the protections described in the wildlife mitigation plan, Caerus must comply with the Colorado Oil and Gas Conservation Commission's (COGCC) rules that are applicable to an injection well; representative surface regulations may include pit fencing and netting, noise, interim and final reclamation, and weed management. CpW requests that Caerus use sound mitigation for engines and necessary appurtenances associated with with the injection well. COGCC 800 Series rules define necessary standards for sound mitigation, CPW requests that the Rules be implemented at the ResidentiaVAgricultural/Rural Zone which is 55db(A) from 7:00 am to next 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 at970-250-0873 if you need further information' Sincerely, Scott Hoyer, District Wildlife Manager JT Romatzke, Area Wildlife Manager File. Bob D. Broscheid, Director, Cdorado Park and Witdtife. Parks and Witdtife Commission: Robert W. Bray ' Chas Castitian, S€cretar Jeanne Horne Bitt Kane, Chair. Gaspar perricone, Vice-Chair. Date Pizel o James Pribyt . James Vigit . Dean Wingfietd. Michette Zimnrerman o Atex ZiPP cc EXHIBlT