HomeMy WebLinkAbout1.13 Ursa BM PUD Impact Analysis - BMC B 08-06-15Article 4-203.G
Impact Analysis
Ursa Operating Company
and Battlement Mesa Partners
Major Impact Review Application
Battlement Mesa PUD Phase I
BMC B
OAProject No. 014-1829
OLSSON
ASSOCIATES
Article 4 — Impact Analysis
Ursa Operating Company and Battlement Mesa Partners
Battlement Mesa PUD Phase I
BMC B
GARFIELD CON I Y ZONING RESOLD IION OF 1978
5.03.07 INDUSTRIAL OPERATIONS IMPACT ANALYSIS
SECTION 5.03.07(1) IMPACT STATEMENT
(a) Wetland and Water of the U.S. Impacts: Construction of the BMC B Pad has limited potential
to affect wetlands and Waters of the U.S. by introducing fill, either directly during construction
or indirectly from runoff. Implementation of a Spill Prevention, Control, and Countermeasure
Plan (SPCC), a Stormwater Management Plan (SWMP), and Best Management Practices
(BMPs) associated with this type of project will provide mitigation for any potential impacts.
(b) Noise and dust may be generated during construction of the proposed well pad. The impacts
of these nuisances will be mitigated by use of industry best management practices.
In order to mitigate potential noise and visual impacts to local residents and prior to the
initiation of the Drilling Phase, Ursa may install an appropriately sized sound wall. Ursa has
applied this mitigation method at previous drilling locations near the Battlement Mesa
Community. Data gathered during previous sound monitoring has demonstrated Ursa's
compliance with the appropriate sound regulations. A preliminary noise analysis report and
the data gathered as part of the previous noise monitoring is included in this submittal. The
preliminary noise analysis anticipates Ursa's Pad B will be in compliance with the appropriate
sound regulations. After the well pad has been placed into the production phase, Ursa will
comply with COGCC and Colorado Revised Statutes for noise levels in
Residential/Agricultural/ Rural zones.
Potential impacts from air emissions, vapor and odor will be controlled via implementation of
Best Available Control Technology (BACT), Reasonably Available Control Technology
(RACT) and strict adherence to Colorado Department of Health and Environment (CDPHE)
Air Quality Regulation 7 criteria. To this end, Ursa will apply a low emissions flow back process
for well completions and will route tank venting emissions through a Volatile Organic
Compound (VOC) combustor. Ursa has in place a program to immediately respond to odor
complaints via their Land Department.
Ursa has developed and implemented a Leak Detection and Repair (LDAR) emissions
monitoring program with infrared cameras to detect and repair any emissions. In addition, they
have implemented a Storage Tank Emissions Monitoring (STEM) program to monitor and
760 Horizon Road, Suite 102 TEL 970.263.7800
Grand Junction, CO 81506
FAX 970.263.7456 www.olssonassociates.com
Ursa Operating Company
Battlement Mesa PUD Phase I — BMC B
repair any emission associated with condensate and produced water tanks. These programs
have been developed in compliance with the new CDPHE Regulation 7 requirements
Potential dust impacts will be mitigated as directed in Ursa's Fugitive Dust Plan by the use of
water or other dust suppressants as appropriate. Remote monitoring will be used to reduce
truck traffic and fugitive dust to the extent practical.
Lighting impacts during drilling and completion operations will be mitigated per the SUA.
During drilling operations, if a drilling rig is within 1,000 feet of an occupied dwelling, Ursa and
its subcontractors will align the lighting equipment to minimize the proportion of the lights that
are directed toward the dwellings and will install lighting shield devices on all of the more
conspicuous lights. Lighting will be directed inward and downward except as deemed
necessary for safety reasons.
During the production phase, all lights on the proposed well pad above the top level of berms
will be oriented in a northerly direction. The focus of lighting will be directed inward and
downward, towards the interior of the site and away from residences.
Above ground facilities will be painted to blend with the environment to minimize visual
impacts.
(c) Creation of hazardous conditions: Some passerine bird species and small mammals may
choose to inhabit or nest on equipment or objects on these locations. The inherent risks
associated with these structures are low. By closing or covering all ports, hatches, cavities,
and openings (such as the ends of pipes) this potential is decreased. Most non -game bird
species and their nests are protected under the Migratory Bird Treaty Act (16 U.S.C. 703-712;
Ch. 128; July 13, 1918; 40 Stat. 755) and damaging occupied nests could be considered a
"take" resulting in a violation.
Indirect Construction Effects: Additional human presence and activity related to construction,
operation, and maintenance of the facilities may influence spatial and temporal use of habitat
surrounding the project by wildlife. The greatest influence on wildlife use would be during the
drilling and completion phases. During the operation and maintenance period the impacts
would be minimal. Since the site exists within and adjacent to significant and long-term human
presence, the additional disturbance from this project is expected to be low.
Road -kill: Speed limits are set low and most wildlife in the area has become habituated to
vehicle traffic. The potential for increased vehicle related mortalities related to this project
should be low.
Endangered Fish Species: Potential impacts could include water depletions and runoff from
storm events or snowmelt that carry increased sediment loads or pollutants to the river.
Implementation of a SPCC, SWMP, and BMPs associated with this type of project will provide
mitigation for any potential impacts
SECTION 5.03.07(2) TRAFFIC
All movements at the access are anticipated to operate at acceptable levels of service throughout
construction. The addition of site traffic, even in the height of construction, does not increase the
existing volumes to amounts required for auxiliary lanes where they are not already provided.
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Ursa Operating Company
Battlement Mesa PUD Phase I — BMC B
Once construction is complete, the daily volumes will reduce to approximately four vehicles per
day for the two well pad sites. Based on the results of the analysis, no mitigation is recommended
for the site.
Water pipelines will be installed to move produced water for reuse on other well pads in the area.
The pipelines will eliminate the need to truck water, except for upset conditions, thus keeping the
traffic volume increases to a minimum after drilling and completions operations are concluded on
the well pad.
SECTION 5.03.07(3) DISTANCE BUFFERS
The proposed well pad is located in the PSR zone district away from most residences. It is located
adjacent to the Battlement Mesa Metropolitan District Water Treatment Plant and the Battlement
Mesa RV Storage area. The closest residence is approximately 455 feet south of the proposed
well pad.
SECTION 5.03.07(5) REHABILITATION
(a) Ursa will follow COGCC Rules for Interim and Final Reclamation of the proposed well pad. A
copy of Ursa's Reclamation Plan is included with this submittal. The SUA with Battlement
Mesa also outlines the Owner's request for landscaping and reclamation where appropriate.
(b) The proposed well pad will be a COGCC approved location. Ursa will abide by all reclamation
requirements set out by the SUA and the COGCC. All of Ursa's surface disturbances are
covered under a statewide bond held by the COGCC.
" AND USE AND DEVELOPMENT CODE 2013
SECTION 4-203.G. IMPACT ANALYSIS
1. Adjacent Land Use
The adjacent uses within a 1500 foot radius of the site consist of a water treatment plant,
vehicle, boat, and RV storage; residences, a park; and vacant PUD commercial property.
See the Adjacent Uses Map located in the Figures section of this submittal. The proposed
use is consistent with the predominant existing uses in the surrounding area, including the
storage facility and water treatment plant. Visual, vegetative, and topographical buffering
will be implemented to separate the proposed facility from the less compatible nearby
uses, including the residences and the park. These uses will not be impacted by
construction and operation of the well pad beyond normal industrial uses of the parcel
once the well pad enters the production phase.
Additionally, the Colorado Oil and Gas Conservation Commission (COGCC) requires that
operators to notify all surface and building owners within 1000 feet of the proposed project
site. Ursa has planned a series of stakeholder meetings to update the status of
development plans in the PUD.
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Ursa Operating Company
Battlement Mesa PUD Phase I — BMC B
2. Site Features
The site is located on private lands located within the Battlement Mesa PUD adjacent to
the Battlement Mesa PUD Water Treatment Plant. The proposed well pad will be located
off of River Bluff Road (CR 307) in the SW 1/4 of the NW 1/4 of Section 18, Township 7
South, Range 95 West of the 6th P.M. Access to the site is via River Bluff Road from the
intersection of West and South Battlement Parkway. The project site encompasses
approximately 4.5 acres at an elevation of about 5100 feet. No geologic hazards have
been mapped by Garfield County in this area, and no faults or other hazards are evident
on the Geologic Map of Colorado.
Native vegetation in the vicinity of the proposed well pad includes a mixture of
greasewood, rabbitbrush, and sagebrush along with several mature cottonwood trees.
The proposed well pad is located in an upland area with relatively flat terrain, which is
essentially the second terrace above the Colorado River flood plain. The terrain slopes
gradually in the direction of the river, and the elevation along the north edge of the pad is
approximately 20-25 feet higher than the banks of the river. The northeast corner of the
proposed well pad is approximately 130 feet from the southern boundary of the 100 -year
flood plain of the river. The eastern edge of the pad is located more than 100 feet of a
wetland. No drainages showing characteristics of Waters of the U.S. occur within the area
of the proposed well pad or the access road. As a result of applying engineering design
criteria (detailed in the accompanying drawings), as well as implementation of mandated
stormwater best management practices (BMPs) and Ursa's voluntary BMPs, the facility
will not impact the surrounding vegetation and water resources beyond the initial
construction of the proposed well pad.
3. Soil Characteristics
The Natural Resources Conservation Service (NRCS) Soils Map shows the area soil
types. The following soil units, are within the study area around BMC B well pad:
Arvada Loam, 6% to 20% slopes, Map Symbol 4: The Arvada loam is a deep, well
drained, sloping soil formed on fans and high terraces at elevations between 5,100
feet and 6,200 feet above mean sea level. Typically the surface layer is a
moderately alkaline, pale brown loam about three inches thick and the substratum
is light brown to brown silty clay loam to a depth of 60 inches. Permeability is very
slow, and available water capacity is high. Surface runoff is moderately rapid, and
the erosion hazard is severe.
The Arvada loam soil is corrosive to steel and concrete due to the large amounts of clay
and salts. Construction is limited by high shrink -swell potential, salinity, and steep slopes.
Buried piping and structures onsite will need to have adequate cathodic protection to
prevent corrosion due to the high salinity of these soils.
4. Geology and Hazard
For a full report of the Geology and Soils Hazards, see the Geologic Hazard Report
included in this submittal. The BMC B well pad site is located in the southeastern part of
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Ursa Operating Company
Battlement Mesa PUD Phase I — BMC B
the Piceance Basin. The Piceance Basin is an irregularly-shaped elongated basin formed
by tectonic forces associated with the Laramide orogeny. These forces down warped the
earth's crust and formed the Piceance Basin as a result of the uplift of the surrounding
Colorado Rocky Mountains and the Colorado Plateau.
The Piceance Basin is the major structural geologic feature in the region. It is bound to
the east by the Grand Hogback monocline, the White River Uplift to the northeast, the
Gunnison Uplift to the south, the Uncompahgre Uplift to the south and southwest, the
Douglas Creek Arch to the west-northwest, and the axial basin uplift to the north.
Sedimentary rocks in the southwestern Piceance Basin gently dip to the north - northeast
except where this regional dip is interrupted by low -amplitude folds. Numerous small sub -
parallel northwest trending folds have been identified in the Green River Formation within
the basin.
There are no mapped faults shown in the area of the site on the Geologic and Structure
Map of the Grand Junction Quadrangle, Garfield County, Colorado or on the Preliminary
Geologic Map of the Grand Valley Quadrangle, Garfield County, Colorado.
5. Groundwater and Aquifer Recharge Areas
The site is located on a terrace above the Colorado River flood plain. The Colorado River
is located approximately 400 feet to the north. The Monument Gulch creek drainage is
located approximately 1,000 feet to the southwest. There is an unnamed intermittent
drainage 300 feet to the east northeast of the site.
The Wasatch Formation locally yields water to wells in some areas, but is generally
considered a confining unit. The Tertiary sedimentary rocks in the Piceance Basin are
generally fine-grained and well cemented resulting in very low hydraulic conductivity in the
rock matrix. Sandstone and siltstone generally occur in lenticular bodies and locally have
moderate hydraulic conductivities which range from 0.001 to 0.01 foot per day. These
lenses of sandstone and siltstone are often widely spaced and not interconnected which
further limits the volumes of groundwater the formation can yield to wells. In some areas,
fracturing during the structural deformation that occurred when the Piceance Basin was
uplifted and through dissolution of cementing minerals has enhanced the permeability and
hydraulic conductivity in parts of the Piceance Basin aquifer system.
Water well depths in the area typically range from 50 feet to 150 feet below ground surface
along the Colorado River and 151 feet to 300 feet below ground surface (bgs) in areas
further south of the Colorado River. Static water levels reportedly range between 40 feet
and 60 feet bgs based on a review of permitted water wells in the vicinity of the site.
Surficial aquifers are present in the alluvium along the Colorado River and its major
tributaries. The depth to groundwater is expected to be less than 20 feet in close proximity
to the Colorado River. This alluvium is typically too thin, narrow, and discontinuous to be
considered a major aquifer, although in some areas the alluvium is locally important as
surficial aquifers. Groundwater within the unconsolidated sediments in the area of the
proposed site is controlled by the thickness of the sediments and the depth to the top of
the Wasatch bedrock. The estimated groundwater flow direction in the vicinity of the site
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Ursa Operating Company
Battlement Mesa PUD Phase I — BMC B
is likely to be sub -parallel with the Colorado River, flowing north-northwest toward the
Colorado River through the center and northern part of the proposed site.
6. Environmental Impacts
See the Impact Analysis: Section 4-203-G (8) Environmental Impacts Report prepared by
WestWater Engineering and the Geologic Hazards Report prepared by Olsson Associates
for a full analysis of the Environmental Impacts. The project area was evaluated for
threatened, endangered, or sensitive wildlife and vegetative species, including but not
limited to Greater Sage Grouse and Colorado hookless cactus, listed in Garfield County.
a. Determination of long-term and short-term effects on flora and fauna
Flora
The proposed well pad would occur in fragmented habitats and altered vegetative
communities adjacent to significant residential developments. Additional modification
and development would have minimal landscape scale effects, but would contribute to
cumulative effects on a local scale. No special status plant occurrences are known to
exist nearby and no effects would occur. The site is moderately to heavily infested with
noxious weeds.
The wetland east of the proposed well pad could potentially be affected by excavated,
side cast, or other fill material during construction of the pad. Proper marking and
temporary fencing will reduce the likelihood of inadvertent impacts to the wetland.
Fauna
Designated critical habitat for Colorado pikeminnow and razorback sucker occurs in
the Colorado River adjacent to the proposed well pad and extends both upstream and
downstream. Potential impacts could include water depletions and runoff from storm
events, or snowmelt that carries increased sediment loads or pollutants to the river.
Potential impacts to the wetland to the east and the Colorado River backwater to the
north will be mitigated through the use of stormwater BMPs.
There is low potential for long-term effects to raptors other than the loss of foraging
habitat within the footprint of the project. Short-term effects include temporary
displacement of raptors in an avoidance area immediately surrounding the proposed
well pad due to increase human presence and equipment activity associated with
construction, operation, and maintenance. The proximity of the proposed well pad to
Bald Eagle foraging, roost, and winter range may cause temporary displacement of
birds. Bald Eagles along the Colorado River corridor appear to habituate to impacts
from development if no direct disturbance occurs.
Loss of foraging habitat will occur within the footprint of the proposed well pad. No
migration corridors would be affected. Human presence and activity may affect animal
distribution by creating avoidance areas and increasing stress on wintering big game.
Due to significant human presence, deer and elk that winter in this area have become
habituated to human activity and the indirect effects of avoidance and displacement
will be diminished. An increase in vehicle traffic may result in additional vehicle related
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Ursa Operating Company
Battlement Mesa PUD Phase I — BMC B
wildlife mortality, although additional traffic resulting from this project would contribute
minimally, given current traffic volumes on the existing roads.
Potential encounters with black bears could occur if garbage or food is available to
resident bears. Ursa will mitigate the potential impacts to black bears by keeping trash
in bear -proof containers and removing on a regular schedule. Once the well pad enters
the production phase, all trash will be removed by employees during their periodic
maintenance visits.
The proposed well pad is not located in Greater Sage Grouse habitat.
b. Determination of the effect on designated environmental resources, including
critical Wildlife Habitat
Development of the project would not be expected to significantly affect biological
resources if precautions are taken during construction and potential post -construction
mitigation techniques are used to protect natural resources. This project would result
in a contribution to cumulative effects of habitat alteration and fragmentation on a local
scale.
c. Impacts on wildlife and domestic animals through creation of hazardous
attractions, alteration of existing native vegetation, blockade of migration
routes, use patterns, or other disruptions
Creation of hazardous conditions: Some passerine bird species and small mammals
may choose to inhabit or nest on equipment or objects on these locations. The inherent
risks associated with these structures are low. By closing or covering all ports, hatches,
cavities, and openings (such as the ends of pipes) this potential is decreased. Most
non -game bird species and their nests are protected under the Migratory Bird Treaty
Act (16 U.S.C. 703-712; Ch. 128; July 13, 1918; 40 Stat. 755) and damaging occupied
nests could be considered a "take" resulting in a violation.
Indirect Construction Effects: Additional human presence and activity related to
construction, operation, and maintenance of the facilities may influence spatial and
temporal use of habitat surrounding the project by wildlife. The greatest influence on
wildlife use would be during the drilling and completion phases. During the operation
and maintenance period the impacts would be minimal. Since the site exists within and
adjacent to significant and long-term human presence, the additional disturbance from
this project is expected to be low.
Road -kill: Speed limits are set low and most wildlife in the area has become habituated
to vehicle traffic. The potential for increased vehicle related mortalities related to this
project should be low.
Wetland and Water of the U.S. Impacts: Construction of the BMC B Pad has limited
potential to affect wetlands and Waters of the U.S. by introducing fill, either directly
during construction or indirectly from runoff. Implementation of a Spill Prevention,
Control, and Countermeasure Plan (SPCC), a Stormwater Management Plan
(SWMP), and Best Management Practices (BMPs) associated with this type of project
will provide mitigation for any potential impacts.
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Ursa Operating Company
Battlement Mesa PUD Phase I — BMC B
Endangered Fish Species: Potential impacts could include water depletions and runoff
from storm events or snowmelt that carry increased sediment loads or pollutants to
the river. Implementation of a SPCC, SWMP, and BMPs associated with this type of
project will provide mitigation for any potential impacts
d. Evaluation of any potential radiation hazard that may have been identified by the
State or County Health Departments
Naturally occurring radioactive materials are not expected to be an issue at the Site.
Colorado oil and gas operations are not known to have a significant problem with
naturally occurring radioactive materials (NORM) or technologically enhanced
naturally occurring radioactive materials (TENORM); however, there have been some
instances where pipe scale has contained radium and associated radon gas. A NORM
survey including site specific testing could be performed to further assess the radon
potential at the Site to serve as a baseline assessment if used pipe or pipe scale is to
be disposed offsite in the future.
Olsson reviewed the Colorado Bulletin 40, Radioactive Mineral Occurrences of
Colorado which states that nearly all of Garfield County's uranium production came
before1954, and most of that came from the Rifle and Garfield mines, located along
the same ore body near the town of Rifle. These occurrences were all hosted in the
Jurassic Morrison and Entrada Formations, and the Triassic -Jurassic Navajo
Sandstone, or the Triassic Chinle Formation which are known to contain uranium and
vanadium deposits in the county and in the Colorado Plateau in general. These
formations lie at great depth in the vicinity of the Site and are stratigraphically below
the depth of the Wasatch Formation.
The Colorado Department of Public Health and Environment (CDPHE) has posted a
statewide radon potential map on their website based on data collected by the EPA
and the U.S. Geological Survey. Garfield County and most of Colorado has been
mapped as being within Zone 1 — High Radon Potential, or having a high probability
that indoor radon concentrations will exceed the EPA action level of 4 picocuries per
liter (pCi/L).
Radon is not expected to be a significant problem at the proposed site since the
development will not include any permanent structures, personnel will not be onsite
for extended periods, and the site will not be developed with structures containing
basements or substructures in which radon can accumulate.
7. Nuisance
Noise and dust may be generated during construction of the proposed well pad. The
impacts of these nuisances will be mitigated by use of industry best management
practices.
In order to mitigate potential noise and visual impacts to local residents and prior to the
initiation of the Drilling Phase, Ursa may install an appropriately sized sound wall. Ursa
has applied this mitigation method at previous drilling locations near the Battlement Mesa
Community. Data gathered during previous sound monitoring has demonstrated Ursa's
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Ursa Operating Company
Battlement Mesa PUD Phase I — BMC B
compliance with the appropriate sound regulations. A preliminary noise analysis report
and the data gathered as part of the previous noise monitoring is included in this submittal.
The preliminary noise analysis anticipates Ursa's Pad B will be in compliance with the
appropriate sound regulations. After the well pad has been placed into the production
phase, Ursa will comply with COGCC and Colorado Revised Statutes for noise levels in
Residential/Agricultural/ Rural zones.
Potential impacts from air emissions, vapor and odor will be controlled via implementation
of Best Available Control Technology (BACT), Reasonably Available Control Technology
(RACT) and strict adherence to Colorado Department of Health and Environment
(CDPHE) Air Quality Regulation 7 criteria. To this end, Ursa will apply a low emissions
flow back process for well completions and will route tank venting emissions through a
Volatile Organic Compound (VOC) combustor. Ursa has in place a program to
immediately respond to odor complaints via their Land Department.
Ursa has developed and implemented a Leak Detection and Repair (LDAR) emissions
monitoring program with infrared cameras to detect and repair any emissions. In addition,
they have implemented a Storage Tank Emissions Monitoring (STEM) program to monitor
and repair any emission associated with condensate and produced water tanks. These
programs have been developed in compliance with the new CDPHE Regulation 7
requirements
Potential dust impacts will be mitigated as directed in Ursa's Fugitive Dust Plan by the use
of water or other dust suppressants as appropriate. Remote monitoring will be used to
reduce truck traffic and fugitive dust to the extent practical.
Lighting impacts during drilling and completion operations will be mitigated per the SUA.
During drilling operations, if a drilling rig is within 1,000 feet of an occupied dwelling, Ursa
and its subcontractors will align the lighting equipment to minimize the proportion of the
lights that are directed toward the dwellings and will install lighting shield devices on all of
the more conspicuous lights. Lighting will be directed inward and downward except as
deemed necessary for safety reasons.
During the production phase, all lights on the proposed well pad above the top level of
berms will be oriented in a northerly direction. The focus of lighting will be directed inward
and downward, towards the interior of the site and away from residences.
Above ground facilities will be painted to blend with the environment to minimize visual
impacts.
If a nuisance complaint is received on a location for noise, odor, dust, or other nuisances,
Ursa's standard operating practice is to respond to each complaint as soon as possible.
The person receiving the complaint, usually the Landman, gathers as much information
(such as wind direction, time, duration, strength, nature of odor or noise, etc.) about the
issue as possible. This information is relayed to the operations leads who begin to
determine the source of the issue and what may be causing it. Once the root cause of the
issue is identified, the team determines mitigation efforts that will help remedy the
concern(s). The land team follows up with the stakeholders on the effectiveness of the
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Ursa Operating Company
Battlement Mesa PUD Phase I — BMC B
mitigation efforts and adjustments are made as necessary. All complaints are logged and
tracked to improve Ursa's overall best management practices (BMP) performance on
existing and future assets.
8. Hours of Operation
Per the SUA, there will be no time of day restrictions with regard to drilling, completing, re -
completing, workover, or reservoir fracture stimulation operations. Routine ongoing
maintenance, development and production operations activities will be limited to the hours
of 7:00 am to 8:00 pm.
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