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HomeMy WebLinkAbout24 BOCC Staff Report 01.20.2013Board of County Commissioners, January 20, 2013 Public Hearing Exhibits — OXY Pond 13 ENV Exhibit Letter (A to Z) Exhibit - A Public notice documents including Publication and Mail Receipts B Garfield County 2013 Land Use and Development Code C Garfield County Comprehensive Plan 2030, as amended D Application - E Staff Report - F Staff Presentation G Email dated November 15, 2013 from Kirby Wynn, Oil & Gas Liaison H Email dated November 15, 2013 from Nick Marx, DeBeque Fire Chief 1 Letter dated November 25, 2013 from JT Romatzke, Parks and Wildlife J Email dated November 25, 2013 from Morgan Hill, Environmental Health K Email dated December 2. 2013 from Wyatt Keesbery, Road & Bridge L Letter dated December 3, 2013 from Chris Hale, Mountain Cross Engineering - M Email dated December 5, 2013 from Steve Anthony, Vegetation Management N Response and supplemental information related to Environmental Health comments, dated December 6, 2013 from Olsson Assoc. Response and supplemental information related to Engineering comments, dated December 6, 2013 from Olsson. Assoc. P , Email dated December 6, 2013 from Daniel Padilla re: Weed Treatment Q Email dated December 11, 2013 from Daniel Padilla re: CPW Comments R Revision to staff recommended conditions of approval provided by Olsson Associates, hand delivered at the 12/16/13 hearing - S Noise Analysis dated December 16, 2013 T Email dated December 17, 2013 from Staff to Olsson Associates U Email dated December 19, 2013 from Olsson Associates V Email dated January 6, 2014 and supplemental material from Olsson Associates V1 — Final Drainage Report V2 — List of grading permits V3 — Reclamation and Erosion Control Plan W Email dated January 6, 2014 and supplemental material from Olsson Associates W1 — Traffic Analysis Amendment X Road & Bridge Vehicle Counts — CR 213 Y Letter dated January 10, 2014 from Colorado Parks and Wildlife Z Email dated January 10, 2014 from Chris Hale, Mountain Cross Engineering AA Letter dated January 13, 2014 from Steve Anthony, Vegetation Management AB Supplemental Staff Report AC Revised Staff Presentation AD AE Ad Name: 9698196A Customer: Olsson Associates Your account number is: 1006467 PROOF OF PUBLICATION THE ttIf��'6f crnzEN TELEGRAM STATE OF COLORADO, COUNTY OF GARFIELD I, Jim Morgan, do solemnly swear that I am General Manager of The Re Citizen Telegram, that the same weekly newspaper printed, in whole or in part and published in the County of Garfield, State of Colorado, and has a general circulation therein; that said newspaper has been published continuously and uninterruptedly in said County of Garfield for a period of more than fifty- two consecutive weeks next prior to the first publication of the annexed legal notice or advertisement; that said. newspaper has been admitted to the United States mails as a periodical under the provisions of the Act of March 3, 1879, or any amendments thereof, and that said newspaper is a weekly newspaper duly qualified for publishing legal notices and advertisements within the meaning of the laws of the State of Colorado. That the annexed legal notice or advertisement was published in the regular and entire issue of every number of said weekly newspaper for the period of 1 consecutive insertions; and that the first publication of said notice was in the issue of said newspaper dated 11114/2013 and that the last publication of said notice was dated 11114/2013 the issue of said newspaper. In witness whereof, 1 have here unto set my hand this 11/19/2013. Jim Morgan, General Manager Publisher Subscribed and sworn to before me, a notary public in and for the County of Garfield, State of Colorado this 1111912013. c4714141L- 9,01.4..443 Pamela Schultz, Notary My Commission Expires 11101/2015 My Commission expires: November 1, 2015 pU19UC NOIlCS TAKE NOTICE 1hal OXY USA WTI, t_P, has ap- plied la the Board of County Commissioners Gar- 111e1d County, Stale 01 Colorado, to request approv- al fora Land Use Change Permit on a property situated in the County of Gerrie-Id. State or Colo - MOO: lo -w4: ` Section: 4 Township. 9 Range: 97 SEC. 31.OTS 6,7.8,9,10,11,1415.1 , SW SEC. 4 LOTS 10,11,1$,1.,14,15, SE, E 1RSW. Practical Descr'Dltpn appraxlmaleIy 15 miles north of DeBartolo off of County Roads 204 and 213 ¢at - so known as Conn Crook Read). 11 is located In 0m NE114 SEIf4 Section 4, 16S, R97W and Is part of a properly known by Assessor's Parcel No. 2169.04400.003. Protect DeaCflp1on- This 11 a LInrnod Impact Re- view for Ma convoreton of an existing facility to Water Impoundments known as the Pond 13 UN Centralized E&P Waela Mona6�emenl Facility. Related Material Handling and Storage areas are propneed for the silo adjacent 10 tho ponds, also. The site is appfcuimatoly 2.1.47 acres In si28 and is totaled on an overall pmoney+ of approxlmaloly 640 acres. The Property is zoned Resource Lands - Plaleau- The Applicant's 06015 algid ropre4anla- itees ere Daniel Padilla, OXY USA WTP LP. Jail Holman and Olsson Associates. All paramtaaffected by Me proposed plan are Invit- ed to appear and state Ihed views, pretasl or 'sup- ped. If you tan nal appear porsenatly at such hearing. than you ate urged to Tanta your views hYy fetter, as the Board of County Commissioners will ghee consideration in the comments of surrounding property Owners, and 0111er0 alluded, in deciding whether le grant dr deny Ina request The applica- [len may be reviewed at the 'office 01 the Planning Dapartment Wooled at 106 8th St tent Sulfa 401, Garfield County Plaza Building, Glenwood Springs. Colorado between the hours of 810 a.m. and 5:0D pan., Monday through Friday. A public hearing on the application hoe been scheduled for Monday. December 16, 2013 at 1:00 P.M. in the County Commtsseanors Meeting Room, Garfield County Administration Bulldhg, 11188111 Street. Glens cod Spnngs. Colorado. Planning Department Garfield County Published a1 the CiUzrn Teeter= November 14.. 2013 (9666196) EXHIBIT ru R.) r- rri ru 0 r—R ru r- r- ru r- ru ru CI D ru .13 ru .10 r- ru 1=1 rU r9 it1 r - U.S. Postai Service., CERTIFIED MAIL, RECEIPT (Domestic Mad Only, No Oosuranee Coverage Provided) For delivery minutedi veil via weLeole .4 vr.,im usp „cern, koala" Colleted Foe Rem Floceipl Foe Medersordorit Required) %ided DaPnly Fee (Enderaioroord Required) Tidal Pa.ada A Faso 46 3.10 2.55 0.00 6.11 re. Donna Koehler PO Box 300 DeBeque, CO 81630 U.S. Postal Service— CERTIFIED MAIL RECEIPT Worm-. Mad Only: No flYNItranCV Cover.-tge Provided) For eu..1 ore website kya,viv.unps.eare MEINININIEMMI Pollee. Conned Fos Return tor (Endorsement 14dee RestrIcied DiMr Foe (E)dormeindelReqiire0 Todd. Po...tom A Perm 46 310 2.55 0.00 6:11 . Colorado River Valley Field Office .1 Bureau of Land Management 2300 River Frontage Rd Silt, CO 81652 U.S. Postal Service• CERTIFIED MAIL RECEIPT (Domestic' Mod Only; No insurance Covorage Provided) For delivery iiiirdrinalem Vlt.r1 DIU .it Pet, go Curetted Fee Return Roma Fee (Eddereernent Required) Reelected Deevety Fes rEndoroomern Required) a TMENOriairAm A Pim% A JoJo Properties PO Box 1926 Rifle, CO 81650 LL .46 3.10 2.55 0.00 6.11 rn ru ru U.S. Postal Service-, CERTIFIED MAIL— RECEIPT (D0rne5fiC Mai! Only: No Insurnore Coverage Provided) Fer deiivery information visit our websate al vrworcusps..roma Conrad Fee ru D Nihon Rocoipt Pao 1=1 (EedorporPord Required) ROOVIOlod Doihyry Fed (Eivicesoreard Required) Dove. num 6 4.•.• r'R [L ru ' Richard, Lyle & Ned Prather ra , = 46 3.10 2.55 0.00 6.11 id--isetnedt 52feere G'n AND PO Box 165 N DeBeque, CO 81630-0165 tr) ru 7012 1010 0E102 0278 U.S. Postal Service.. CERTIFIED MAIL- RECEIPT (Domestic Mail Only; No insurance Coverage Provided) For deuvury yiSil our websille OiWlY 'e4,5 Pomo CordaadFoo Rtwn Flocepl Foe (Ergiorco mot Roduarod) Rated Deerory Fee {endervornord Recurred) iraaal Calla+ ran & cara .46 3.10 2.55 0.00 6.11 Chevron Texaco Property Tax Chevron USA Inc PO Box 285 ' Houston, TX 77001 z U.S. Postal Service., CERTIFIED MAIL— RECEIPT (Domes(ic Mail Only: No insurance Coverage Provided) For delivery ellorrimlion visil rue errivole it www.usps.cum. 1.111111111MIB.V... Pcetage Candied Foo FlootiviFoo (Erviergeanorn Requ'red) enidiod DolFrory Foe rEnderuement RsdurretO Cakaarra .48 3.10 2.55 0.00 6.11 Property Tax Department OXY USA INC 0, PO Box 27570 Houston, TX 77227-7570 IL V, ilii 'teICCIn ti 410 0©0 Z Z Z Board of County Commissioners December 16, 2013 LIPA7675 PROJECT INFORMATION TYPE OF REVIEW APPLICANT (OWNER) CONSULTANT LOCATION PROPERTY DATA ACCESS ZONING COMPREHENSIVE PLAN Limited Impact — Water Impoundment, Storage_ OXY USA WTP, LP — Daniel Padilla Jeff Hofman — Olsson Associates EXHIBIT Northeast of Debeque in Section 4, Township 6 South, Range 97 West of the 6th P.M. Parcel - 640 -acres and Project area - 21.47 -acres CR 213 (Conn Creek) to private road Resource Lands - Plateau Agricultural Production / Natural I. DESCRIPTION OF THE PROPOSAL. Application for a Land Use Change Permit (LUCP) has been submitted to 'convert' an existing facility into a "Centralized E&P Waste Management Facility" as defined by the COGCC. The 2013 Land Use and Development Code defines the uses as "Water Impoundment" and "Storage". Both material handling and storage necessary for the operation of the facility are considered accessory uses however a portion of the site will be utilized for general storage of material, equipment and supplies on an adjacent COGCC-approved well pad. The centralized water impoundments are not located on a well pad and apparently the water impoundments were constructed without the proper land use approvals from the County. Approval of this application would cure the land use violation. The site consists of two water impoundments, Pond 13 East (1.17- Board of County Commissioners December 16, 2013 LIPA7675 rETAIL -A" . 'CAIL ,-.h, www ,.,i..rri.,,w.• ' •.t.. wrike l !Minn' fe t'� ....t% '! 11 + ' e .- • acres) with a capacity of 68,010 barrels, and Pond 13 West (2.13 -acres) which has a capacity of 53,470 barrels - for a total capacity at the facility of 121,480 barrels of produced water. Converting the facility will result in the following modifications: 1. Drain, clean and remove the existing pond liners; 2. Conduct the geotechnical survey work and make improvements, if necessary; 3. Install a geocomposite clay liner; 4. Install a leak detection system; 5. Install a new primary 60 mil liner; 6. Drill three new groundwater monitoring wells. Storage of Material, Equipment and • • 1 Mw.e'. +I++ituPY 2144 ta.010,`.—n. Y tIMr� CROSS SEcIlo 1 ■=A =au,' ; Supplies is proposed to occur within the 21.47 -acre project area. These uses are being reviewed as part of this application. All water to be stored in the ponds will be piped to the site via existing distribution and gathering pipelines from well pads as shown in the map, right. Vehicular access to the site is via a private road system from CR 213 (Conn Creek Road) and the Applicant has requested the Board waive compliance with the minimum road standards contained in the LUDC. No other information was provided with regard to the current standards, grade, width or surface, of the private road system. C) mitt aso o. Nov DOWAS, + -,. OP) ..�. 21 Page Board of County Commissioners December 16, 2013 LUPA7675 'hot(' 1 Luukiny; iturth:.j !rural uppruxmlalc . n1r: ciI flay Pork) 13 pruyecs area 14.24. is r. The application states that water and sanitation are unnecessary due to the intermittent nature of employees on the site. Mj'If, (1. Luokin_+ north from southern boundary or Oxy Pond 13 project area (4.24.13 r. 11. ADJACENT USES AND ZONING The site is located 23 miles north of Debeque in the NE %4 SEX of Section 4, T65, Range 97W on a 640 -acre parcel in the Resource Land Plateau zone district. Adjacent uses include Oil & Gas related activities as well as grazing. 3I, Board of County Commissioners December 16, 2013 LIPA7675 l ALE Y s f ' fy Jr' f r.• r ✓d / '.. r / i r r_r a � r ♦- r r ..- /_ m.mone..1.rter.00. 0W0141'04,A Air•" r1.. +'. er:rtrrl Jit rowireit onto /IrY IHI1 KW 41004W RrL t4L I/rr,r;wr eKR I Ohl .4.‘•rRrrr +iae rarw..■ r/� m ,. '4. ... m moot , 10re V •• 'IV • '. /# 1 MI Mavrrlf ` '"''trr 'r'iy�►`ti �y - /4.r 1 ISI ` %. , r 1 4=sta14!: %I. %%- r — �. It 1 r 4. 1 ; corrtrrwc. + +rl t %rwwc/teh0.urm. r arrives 1 +"‘ ANISIZEVAIL 4 R� .wvlirrimM — / *04rpralr: 'il s +.Ir-rmr"riett, { 171 /MEW f ti /- / ' CROSS SECT • 1 I 1 yV 1 I I + I 4 r t. ON A—A Site Plan i . k. I r f I 1 1 ' •r ; I it I I J 1 I I I 1 1 I I { 1 I II 1+ 1 1•, l I I r 1, I i '. 1 1 C1 , 11 ..i + . 4 1I� rmewrrnoori rAW#KHLY1" 111 r. 4 m • ' 1 _ I 1 r 4 Wag,. Board of County Commissioners December 16, 2013 L1PA7675 III. REFFERAL AGENCY COMMENTS Submittal documentation was forwarded to the numerous federal, state and local agencies for review and response. Comments have been received from: Garfield County Road and Bridge: Garfield County Vegetation Management: Garfield County Oil & Gas Liaison: Garfield County Environmental Health: Mountain Cross Engineering: Colorado Parks and Wildlife: DeBeque Fire District: Exhibit K Exhibit M Exhibit G Exhibit J Exhibit L Exhibit 1 Exhibit H No response was received from the following agencies: Colorado Department of Public Health and Environment — Air Pollution Control Division Colorado Department of Public Health and Environment — Water Quality Control Division IV. APPLICABLE REGULATIONS SECTION 4-203 G. IMPACT ANALYSIS Where the proposed Development will impact specific features of the site, the Applicant shall describe both the existing conditions and the potential changes created by the project. The Impact Analysis shall include a complete description of how the Applicant will ensure that impacts will be mitigated and standards will be satisfied. The following information shall be included in the Impact Analysis: 1. Adjacent Property. An address list of real property adjacent to the subject property, and the mailing address for each of the property owners. Staff Comment: This list was provided. 2. Mineral Owners. A list of separated mineral estate owners in the subject parcel, and the mailing address for each owner or lessee. Staff Comment: The mineral rights are not severed and are owned by OXY. 3. Adjacent Land Use. Existing use of adjacent property and neighboring properties within 1,500 -foot radius, Staff Comment: Natural gas and agricultural (grazing) operations exist on the subject site as well as neighboring properties. sir' Board of County Commissioners December 16, 2013 L1PA7675 4. Site Features. A description of site features such as streams, areas subject to flooding, lakes, high ground water areas, topography, vegetative cover, climatology, and other features that may aid in the evaluation of the proposed Development. Staff Comment: Prior to construction of the existing ponds the site contained sagebrush, Gambel oak and aspens. The site is located at an elevation of 8,600 feet above sea level in the Cascade Canyon area in the Conn Creek drainage. A 41X'I USA WIP LP OXY %A7 Widen Orgy. 6.1G7 JuM146 tO Er!Cr': Pond 13 EW Complex Soils Map rep Md. MO7G, G:+a Geo a twerp. Gov :4 5. Soil Characteristics. A description of soil characteristics of the site that have a significant influence on the proposed use of the land. Staff Comment: The site consists primarily of Parachute-Irigul Complex which is a moderately deep and well drained soil. Runoff is medium or rapid, and the hazard of water erosion is moderate to very severe. The soils are listed as "severe" for shallow excavations however the pond design was intended to mitigate these issues. The 'conversion' of the ponds will not result in additional structures or access roads. fi. Geology and Hazard. A description of the geologic characteristics of the area including any potential natural or manmade hazards, and a determination of what effect such factors would have on the proposed use of the land. Staff Comment: The Geohydrology Report indicates that no surficiai geologic hazards have been mapped in the immediate vicinity of the project nor is the site located in a mapped floodplain hazard area. Design and construction of the facility incorporated mitigation measures due to the limitations of the shallow excavation of the site. The Applicant proposes to improve the ponds by placement of additional lining and leak detection. 6 Board of County Commissioners December 16, 2013 LIPA7675 7. Groundwater and Aquifer Recharge Areas. Evaluation of the relationship of the subject parcel to Floodplains, the nature of soils and subsoils and their ability to adequately support waste disposal, the Slope of the land, the effect of sewage effluents, and the pollution of surface runoff, stream flow, and groundwater. Staff Comment: As stated above, the facility was constructed to mitigate the soils, subsoils and slope of the site. 8. Environmental Impacts. Determination of the existing environmental conditions on the parcel to be developed and the effects of development on those conditions, including: a. Determination of the long-term and short-term effect on flora and fauna; b. Deterrnination of the effect on significant archaeological, cultural, paleontological, and historic resources; c. Determination of the effect on designated environmental resources, including critical Wildlife Habitat; d. 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; e. Evaluation of any potential radiation hazard that may have been identified by the State or County Health Departments; and f. Spill prevention control and counter measures plan, if applicable. Staff Comment: The application materials state that the 'conversion of the site will not have a significant effect on the local flora and fauna. The site has been previously disturbed and graded for a pond facility.' The status of the site as a violation, occurring without review or permitting by the County, should result in a complete review of the pre- existing conditions as well as the existing conditions to determine compliance with the Garfield County Land Use Code. ti Analysis firm Rmardary 6.ec7a= • PrIo-lydy HataYtat sa,u�uar: r;pn&re1 Habitat a5.R7.3st^ The planned improvement to the ponds includes installation of a clay liner as well as 60 mil liners and a leak detection system. Impacts on wildlife was analyzed in a biological resources survey which identified one federally threatened, proposed and candidate species to occur near the project area — the Greater Sage -Grouse. ERCT Resources Corporation concluded that the site is poor habitat for the species which corresponded with the Garfield County Sage - Grouse Conservation Plan. Board of County Commissioners December 16, 2013 LIPA7675 Colorado Parks and Wildlife indicate the site as Greater Sage -Grouse Production Area and recommend a condition that no construction activity occur from March 1 through lune 30 to minimize impacts to these production areas. County mapping of Greater Sage -Grouse, above, indicate the site may be located within General Habitat. Staff is recommending a condition regarding anti -perching devices all structures on the site, including fencing, to protect this candidate species. 9. Nuisance. Impacts on adjacent land from generation of vapor, dust, smoke, noise, glare or vibration, or other emanations. Staff Comment. The application states that the site will not cause impacts but no information has been provided to support this statement, except for inclusion of OXY's Fugitive Dust Mitigation plan. No analysis of noise, vibration, vapor or odors associated with the produced water impoundments and associated storage area was provided. Environmental Health responded to the referral, Exhibit J, that the standard response of "adjacent land will not be impacted by the generation of vapor, dust, smoke, glare or vibration" is inadequate as the operation of the facility will add to regional dust and VOC emissions. 10. Reclamation Plan. A reclamation plan consistent with the standards in Section 7-212. Staff Comment: This facility's expected lifespan is 30 years. The County typically requires security to ensure revegetation of disturbed areas however that is not necessary in this case due to the fact that the facility is already constructed. The application demonstrates that reseeding will be monitored and provides a disturbance area of 3.25 -acres. An engineer's opinion of probable cost is listed at $2,500 for revegetation (completed?). DIVISION I. GENERAL APPROVAL STANDARDS FOR LAND USE CHANGE PERMITS. The following standards are approval standards that shall apply to all proposed Land Use Changes, including Divisions of Land, not otherwise exempt from the standards set forth in this Code. SECTION 7-101. COMPLIANCE WITH ZONE DISTRICT USE RESTRICTIONS. The Land Use Change shall comply with Article 3, Zoning, including any applicable zone district use restrictions and regulations. Staff Comment: Zoning of the site is Resource Lands — Plateau which requires a Land Use Change Permit for Water Impoundments and Storage. The sole exception to this requirement is for production ponds located on a COGCC-approved well pad and use of the pond is solely to support the well pad on which it is located. The subject constructed ponds are not located on a well pad and so this facility is a violation 8I Board of County Commissioners December 16, 2013 LIPA7675 in that the water impoundments have been constructed and operating without acquiring a Land Use Change Permit from Garfield County. Approval of this application would cure the violation and bring the site into compliance with the LUDC. SECTION 7-102. COMPLIANCE WITH COMPREHENSIVE PLAN AND INTERGOVERNMENTAL AGREEMENTS. The Land Use Change is in general conformance with the Garfield County Comprehensive Plan and complies with any applicable Intergovernmental Agreement. Staff Comment: The Future Land Use Map (FLUM) designates the site within the "Resource Production/Natural (RPN)" which is for agricultural and grazing land used primarily for oil, gas, oil shale, coal mining, gravel mining, etc. and includes areas with significant environmental constraints. SECTION 7-103. COMPATIBILITY. The nature, scale, and intensity of the proposed use are compatible with adjacent land uses and will not result in an adverse impact to adjacent land. Staff Comment: The 640 -acre parcel owned by OXY is used primarily for production of oil & gas as well as related facilities. This use is in support of the oil and gas operations in the area. SECTION 7-104. SOURCE OF WATER. All applications for Land Use Change Permits shall have an adequate, reliable, physical, long-term, and legal water supply to serve the use, except for land uses that do not require water, or that contain Temporary Facilities served by a licensed water hauler. Staff Comment: The facility is not manned on a on a regular basis therefore the Applicant states that water is not necessary. Workers will provide their own potable water at the site and water will be available in OXY field offices. SECTION 7-105. CENTRAL WATER DISTRIBUTION AND WASTEWATER SYSTEMS. Staff Comment: Wastewater will be provided by portable toilets with wastes hauled by licensed haulers. SECTION 7-106. PUBLIC UTILITIES. Adequate Public Utilities shall be available to serve the Land Use Change. StaffComment: A generator is on-site to provide necessary power for the operation of the water impoundments. No public utilities are required. SECTION 7-107. ACCESS AND ROADWAYS. All roads shall be designed to provide for adequate and safe access and shall be reviewed by the County Engineer. Staff Comment: The site is located 11 miles north of the terminus of CR 213, Conn Creek Road. The existing private road system is wholly located within OXY -owned land and is apparently constructed to Primitive Road standards as defined in the LDDC. Several sections of the road are said to contain a ,%./101k OXY USA WTP LP OXY 70.4 ID' "5'1 .4 ..r 11,2c. CO e f', 3,1 Board of County Commissioners December 16, 2013 JLIPA7675 Frtrag! lad/ Tram,: 2n11 (] ht41 13 E'h Pnyx1 Aca"s Pax 'Z. Prxxr Pace Ira A401.3104./.1 CO"' AC44 'N., 1' Yatitig• 7 grade of 13 -percent. The surface of the road is native material, road base and gravel. It appears that the waiver of standards is at feast applicable to road grade and road surface. No other information related to road width, turning radius, etc. was provided. The traffic analysis indicates that the traffic generated by the water impoundments will be minimal for CR 204 but significant for CR 213 due to the existing low volume of that road. However, the traffic volumes can be accommodated by the roadway. existing The volumes contained in the traffic study do not appear to contemplate traffic volume associated with the storage areas. SECTION 7-108. USE OF LAND SUBJECT TO NATURAL HAZARDS. Staff Comment: The proposed leak detection and lining of the ponds may not be sufficient protection from natural hazards as Environmental Health, Exhibit J, has identified the site as being located within a flash flood zone. They further recommend that the ponds should be constructed in a manner so as to 101 • Board of County Commissioners December 16, 2013 LIPA7675 allow for the accumulation of water and materials without the occurrence of an overflow spill from the ponds. 7-109. FIRE PROTECTION. A. Adequate Fire Protection. Adequate fire protection will be provided for each land use change as required by the appropriate fire protection district. Staff Comment: The DeBeque Fire District, Exhibit H, responded to the referral that they have no issue with the application. DIVISION 2. GENERAL RESOURCE PROTECTION STANDARDS FOR LAND USE CHANGE PERMITS. The following resource protection standards shall apply to all proposed Land Use Changes, including Divisions of Land and exempt Subdivisions, not otherwise exempt from the standards set forth in this Code. SECTION 7-201. AGRICULTURAL LANDS. Staff Comment: The applicant leases the parcel for seasonal cattle grazing but this use would not directly affect that operation. The site is fenced to prevent access to the ponds. SECTION 7-202. WILDLIFE HABITAT AREAS. The Applicant shall consult with the Colorado Division of Wildlife or a qualified Wildlife biologist in determining how best to avoid or mitigate impacts to Wildlife Habitat areas. Staff Comment: The site is already disturbed as the ponds have been constructed and are in operation. The application states that no new disturbance will occur so there will be no impact to wildlife. The site has the potential for habitat for the Greater Sage -Grouse. County mapping identifies the area as General Habitat and CPW identifies it as Production Area, but a Biological Resources Survey found the area to be poor habitat for the greater sage grouse. The latter analysis, of poor habitat, was completed after the facility was constructed and in operation. Colorado Parks and Wildlife have responded to the referral, Exhibit 1, and CPW identifies the site as being located within Greater Sage -Grouse production area and black bear year-round range. No 1] 1 Board of County Commissioners December 16, 2013 LI PA7675 significant impacts to wildlifeare anticipated if the following recommendations are incorporated into the development of the project: 1. Night Lighting should be of the full -cutoff type and/or timed or otherwise minimized to reduce disruption to wildlife. 2. The location of the site within black bear year-round range has the potential for human/bear conflicts. Bear -proof trash containers should be utilized at work -site locations and workers should be advised not to feed bears. 3. Following the completion of construction activities, newly exposed soils should be revegetated as soon as possible to prevent erosion and to reduce the likelihood of non-native plant becoming established in the area. Seed mix used for revegetation should be certified as weed - fee and consist of native seeds from plants that are common to the area. 4. To reduce the likelihood of truck -wildlife collisions, proper speed limits (<25 mph) should be posted and enforced on ail service roads. 5. Fencing should consist of a minimum 7 -foot high chain-link fence with a mesh type of fencing along the bottom (buried on -foot below grade level and extending a minimum of two -feet above grade) capable of preventing small animals from entering between the gaps (gaps should be no larger than tree -inches). 6. The pit should be constructed with a 4:1 slope escape ramp and/or with chain-link fencing in one corner of the pit to allow entrapped wildlife to escape. 7. The pit should be adequately netted to ensure that waterfowl and other birds are prevented from entering, 8. CPW requests to be notified immediately if any birds and/or wildlife are found dead or trapped within or around the pit, netting, or fences. Mai 9. Construction activities for the facility should occur outside of the time period from March 1 through June 30 to minimize impacts to sage -grouse production areas. Staff recommends consideration of including all of these items as conditions of approval. SECTION 7-203. PROTECTION OF WATERBODIES. Staff Comment: It does not appear that waterbodies are located in the vicinity of this project. The map left identifies Cascade Canyon Creek, Little Creek and House Log Gulch creek as being located nearby. SECTION 7-204 DRAINAGE AND EROSION. Board of County Commissioners December 16, 2013 LI PA7675 A. Erosion and Sedimentation. B. Drainage C. Stormwater Run -Off. D. Culverts, drainage pipes, and bridges shall be designed and constructed in compliance with PASHTO recommendations for a water live load. Staff Comment: The Applicant has responded (Page 4, Standards Analysis) that the site is an existing disturbed area with no additional disturbance planned. BMP's will be used and the ponds do not create greater than 10,000 square feet of impervious area and is designed to accommodate precipitation with the maintained freeboard. The submitted information does not adequately demonstrate that the proposal meets this standard which requires sufficient drainage and erosion controls for the proposal. Environmental Health and Mountain Cross Engineering (Exhibits J and L) both identify the lack of information as an issue — the location of the site within a flash flood zone, the lack of details regarding leak detection and liner specifications, and the need for additional information to assure adequate conveyance of storm flows around and through the site, and how water will drain around the storage areas. Specific conditions are recommended regarding provision of additional sufficient information for review to determine adequate protection measures, as well as provision of monitoring well permits, prior to issuance of a land use change permit. SECTION 7-205. ENVIRONMENTAL QUALITY A. Air Quality. Staff Comment: The application does not include required air permits for the operation of the water impoundment facility but obtaining any necessary permits was discussed in the submittal documents. Environmental Health, Exhibit J, states that the applicant should obtain proper permits and utilize Best Management Practices to minimize emission of volatile organic compounds from the produced water ponds. Other comments include that the Applicant should consider the use of storage tanks, rather than pits, due to the fact that tanks are more easily controlled and often reduce air emissions. Exhibit L, Mountain Cross Engineering review also identifies air regulatory permitting analysis being 'in progress' but not included in the submittal. This air quality analysis should include the small structures and the generator building on the site, as well as items proposed to be stored in the storage areas. A condition of approval is recommended that sufficient air quality analysis be submitted and reviewed, as well as applicable permits provided to the County, prior to issuance of the land use change permit. Exhibit 0 contains an Air Pollution Emission Notice (APEN) that was issued for the generator on the site in 2011. This APEN notes that the generator is exempt from air quality permits but does not indicate whether permits are required for the ponds. B. Water Quality. Staff Comment: Insufficient information has been provided to determine compliance with water quality 13 i Board of County Commissioners December 16, 2013 LIPA7675 standards. The application states that the site will implement and adhere to the Stormwater BNPs and that the Spill Prevention Control and Countermeasures Plan (SPCC) would assure protection. The application materials do not appear to include an SPCC. SECTION 7-206. WILDFIRE HAZARDS. Staff Comment: The site is located in a moderate wildfire hazard area. SECTION 7-207. NATURAL AND GEOLOGIC HAZARDS Staff Comment: A Geohydrology Report was submitted that indicates that primary limitations for shallow excavations are based upon steep slopes and severe seepage. As well, the suitability of the soils has been identified as being somewhat to very limited in regard to construction of ponds and embankments. A liner will mitigate potential seepage and Teaks and design and construction characteristics should consider soils issues. Staff recommends a condition of approval related to provision of specifications for the liners and leak detection system. SECTION 7-208. RECLAMATION. Staff Comment: A reclamation plan is not required due to the 30 -year life of the facility. DIVISION 3. SITE PLANNING -AND DEVELOPMENT STANDARDS. These standards shall apply to all Land Use Changes proposing 2 -unit and multi -unit dwellings, Commercial and industrial Use, and Divisions of Land not otherwise exempt from this Code. SECTION 7-301. COMPATIBLE DESIGN. The design of Development associated with the Land Use Change shall be compatible with and enhance the existing character of adjacent uses. Staff Comment: The application states that the site was designed to accommodate the functional and efficient operations, monitoring and maintenance of the facility. SECTION 7-302. OFF-STREET PARKING AND LOADING STANDARDS Staff Comment- The application states that there is adequate parking to accommodate personnel and that all activities will be conducted on private property. SECTION 7-303. LANDSCAPING STANDARDS. Staff Comment: Landscaping standards are not applicable to industrial uses. SECTION 7-304. LIGHTING. Staff Comment: The Applicant has stated that lighting standards will be met. SECTION 7-305. SNOW STORAGE STANDARDS. Staff Comment: Snow will be stored in vacant sections of the disturbed area. SECTION 7-306. TRAIL AND WALKWAY STANDARDS. Staff Comment: Not applicable to this proposal. 14 1 Board of County Commissioners December 16, 2013 LIPA7675 DIVISION 10. ADDITIONAL STANDARDS FOR INDUSTRIAL USES. SECTION 7-1001. INDUSTRIAL USE These standards shall apply to ail industrial Uses: A. Residential Subdivisions. Industrial uses shall not occupy a lot in a platted residential Subdivision. Staff Comment: The site is not located within a residential subdivision. B. Setbacks. All activity associated with these uses shall be a minimum of 100 feet from an adjacent residential property line, unless the use is on an industrially zoned property. Staff Comment: The project appears to meet the minimum setbacks. C. Concealing and Screening. When an industrial use is not located on an industrial zoned property, all storage, Fabrication, service, and repair operations shall be conducted within an enclosed building or have adequate provisions, based on location and topography, to conceal and screen the facility and/or operations from adjacent property(s). Staff Comment: Concealing, and screening the facility and/or operations is not necessary due to the remote nature of the site. D. Storing. 1. Materials shall be stored on the property in a form or manner that will not be transferred off the property by any reasonably foreseeable natural cause or force. 2. All products shall be stored in compliance with all national, State, and local codes. 3. Shall be a minimum of 100 feet from an adjacent property line. 4. Petroleum and hazardous products shall be stored in an impervious spill containment area(s). 5. Staff Comment: No information was provided regarding the materials, equipment or supplies that would be stored on the site. The application states that no petroleum or hazardous produces will stored on the site and a condition of approval is recommended as no impervious spill containment areas were identified. E. Industrial Wastes. All industrial wastes shall be disposed of in a manner consistent with Federal and State statutes and requirements of CDPHE. Flammable or explosive solids or gases and other hazardous materials including wastes shall be stored according to the 151 Board of County Commissioners December 16, 2013 LIPA7675 manufacturer's standards and shall comply with the national, State, and local fire codes and written recommendations from the appropriate local fire protection district. Staff Comment: No hazardous materials will be stored on the site. F. Noise. Noise shall not exceed State noise standards pursuant to C.N.S., Article 12, Title 25, unless the use is regulated by the COGCC. In this case, the use shall be subject to COGCC rules in regard to noise abatement. Staff Comment: No information was provided regarding noise other than a statement that the site will comply with COGCC noise standards. Staff and referral agencies identified this deficiency in the submittal and recommend a condition requiring submittal of a noise study that demonstrates compliance with the applicable regulatory requirement. G. Ground Vibration. Every use shall be operated so that the groundvibration inherently and recurrently generated is not perceptible without instruments at any paint of any boundary line of the property. Staff Comment: The application states that no vibration will be perceptible. H. Interference, Nuisance, or Hazard. Every use shall be so operated that it does not emit heat, glare, radiation, or fumes that substantially interfere with the existing use of adjoining property or that constitutes a public nuisance or hazard. Flaring of gases, aircraft warning signal, and reflective painting of storage tanks, or other legal requirements for safety or air pollution control measures, shall be exempted from this provision. Staff Comment: Fumes from the ponds were not discussed. An Air Pollution Emission Notice (APEN) was issued for the generator in 2011, see Exhibit O. This APEN notes that the generator is exempt from air quality permits but does not indicate whether permits are required for the ponds. The Applicant has indicated that a Reasonable Available Control Technology (RACT) analysis was being prepared to cover OXY impoundment facilities to determine the extent of the permitting necessary for the impoundments and that they would provide any permits found to be necessary by the study. Board of County Commissioners December 16, 2013 LIPA7675 V. STAFF DISCUSSION 1. The existence of the facility is in violation of the Garfield County 2013 Land Use and Development Code which requires a Land Use Change Permit for the use of water impoundments. The intent of acquiring a permit pursuant to code requirements is to ensure that the site meets the LUDC minimum standards, proper permits are acquired, and that necessary mitigation measures are in place during construction and prior to the use. This did not occur with this project. Of particular concern is the lack of air quality permits for the site, the lack of existing leak detection and monitoring systems, the lack of information related to erosion control and drainage of the site, and the lack of wildlife mitigation measures in place at the site. The application appears to only discuss the 'conversion' of the facility to an E&P Waste Facility pursuant to COGCC requirements and does not provide adequate information, pre -construction or operation of the facility, to make a determination on compliance with code requirements. The response that 'no additional disturbance will occur is insufficient to determine if water impoundments are appropriate to this location or if the constructed ponds meet the code requirements. 2. The existing 8' high fencing around the perimeter of the ponds requires a building permit. Since the fences are already constructed the building permit fee will be double the cost, 3. Wildlife issues, particularly those related to the Greater Sage -Grouse, are a concern. The ponds are currently flagged and staff was unable to determine if escape ramps were constructed. CPW recommends netting and additional fencing protection related to netting at the bottom of the fence to prohibit small animals from accessing the ponds. 4. The LUDC requires the Applicant to demonstrate that the facility will meet minimum noise standards. In the case of Oil & Gas uses the County applies those standards contained in the COGCC 800 rules. The Applicant has provided no information regarding the compliance with these standards for the generator that is housed on the site, therefore Staff is unable to determine compliance with the noise standards. In addition, if the generator is located within an enclosed structure a building permit must be obtained, and the Applicant will be required to pay double the cost of the permit due to post -construction permitting. Structure information was not included in the application materials. 5. Staff and referral agencies have questioned whether the entirety of the ±20 -acre facility is considered in the submitted plans and reports. Many of these plans and reports only appear to analyze the standards based on the water impoundments, excluding the proposed storage areas that surround the ponds. Conditions of approval requiring amended plans to encompass the site are recommended. Board of County Commissioners December 16, 2013 LI PA7675 6. Use of Water Storage Tanks versus Water Impoundments. In the recent past the county has reviewed several applications for tank farms that store produced water, these tank storage facilities are more easily controlled and often reduce air emissions. The use of tanks rather than open ponds provides additional mitigation for wildlife impacts. The existence of these water impoundments, and the additional lining and monitoring measures proposed, may meet the code requirements however at this time staff and the referral agencies have not received sufficient information to demonstrate compliance. VI. FINDINGS That proper public notice was provided as required for the hearing before the Board of County Commissioners. 2. That the hearing before the Board of County Commissioners was extensive and complete, that all pertinent facts, matters and issues were submitted or could be submitted and that all interested parties were heard at that meeting. 3. That for the above stated and other reasons and upon compliance with the conditions of approval, the Land Use Change Permit for the Water impoundments and Storage is in the best interest of the health, safety, convenience, order, prosperity and welfare of the citizens of Garfield County. 4. That, upon compliance with the conditions of approval and the waivers granted, the application has adequately demonstrated that the proposed Facility is compliant with the minimum standards and regulations required by the Garfield County 2013 Land Use and Development Code. ISl Board of County Commissioners December 16, 2013 LIPA7675 5. That, upon compliance with the conditions of approval and the waivers granted, the application is generally consistent with the Garfield County Comprehensive Plan 2030, as amended. VII. BOARD OF COUNTY COMMISSIONERS DELIBERATION AND DECISION Should the Board seek to approve the application for OXY's Pond 13 E/W Water Impoundment and Storage, Staff provides the following conditions for consideration: General Conditions 1. That all representations made by the Applicant in the application and public hearing shall be conditions of approval, unless specifically altered by the Board of County Commissioners. 2. That the facility shall operate in compliance with all applicable Federal, State, and local regulations governing the operation of this type of facility. 3. The land use change permit is for two water impoundments, 13E and 13W, not to exceed 3.3 - acres in size and storage capacity not to exceed 121,480 Barrels of produced water. In addition, the 21.47 -acre project area is approved for two storage facilities as indicated on the approved site plan for a total area of 3.03 -acres. No hazardous material or fuel storage is permitted within the facility. Conditions Prior to Issuance of Permit 4. Prior to issuance of the Land Use Change Permit, the Applicant shall provide a supplement to the Traffic Analysis confirming that Storage traffic was included in the analysis or updating the report as appropriate. The supplement shall include a finding consistent with the current study that no additional traffic improvements are recommended or provide specific recommendations that the Applicant shall be required to comply with subject to review by the County's Consulting Engineer. 5. Prior to issuance of the Land Use Change Permit, the Applicant shall provide written confirmation that all pipelines serving the facility have been properly permitted or are exempt from permitting requirements. 6. Prior to issuance of the Land Use Change Permit, the Applicant shall provide copies of the well permits related to the three monitoring wells for the site. 7. Prior to issuance of the Land Use Change Permit, the Applicant shall provide copies of all current air quality permits from CDPHE. Any future or amended permits shall be provided to the County upon issuance by the CDPHE. 8. Prior to issuance of the Land Use Change Permit, the Applicant shall provide a statement by a qualified professional or representative of the Applicant confirming the adequacy of the access road to serve the site. A waiver from Article VII, Roadway Standards is approved pursuant to the approval criteria contained in Section 4-118 of the Land Use and Development Code, subject to 191 P . Board of County Commissioners December 16, 2013 LI PA7675 compliance with the above requirement. 9. Prior to issuance of the land Use Change Permit, the Applicant shall obtain the proper building permits for structures on the site, including any fencing that exceed 6' in height, and pay double the building permit fees for obtaining the permits post -construction. 10. Prior to issuance of the Land Use Change Permit, the Applicant shall provide specifications and details for the proposed liners and leak detection systems of the ponds for review and determination of sufficiency by Mountain Cross Engineering. 11. Prior to issuance of the Land Use Change Permit, the Applicant shall provide an Erosion Control Plan that includes all area within the 21.47 -acre site and the plan reviewed for sufficiency by Mountain Cross Engineering. 12. Prior to issuance of the Land Use Change Permit, the Applicant shall provide a revision to site grading and drainage plan that clearly shows how the water will drain around the water impoundments and storage areas. This should include Best Management Practices to ensure positive drainage of the site. 13. Prior to issuance of the Land Use Chang_ a Permit, the Applicant shall provide a noise analysis that demonstrates the site is compliant with the COGCC Noise Standards/Regulations. 14. Prior to issuance of the Land Use Change Permit, the Applicant shall comply with the following recommendations from the Colorado Department of Parks and Wildlife: A. Night Lighting should be of the full -cutoff type and/or tinned or otherwise minimized to reduce disruption to wildlife. B. Bear -proof trash containers should be utilized at work -site locations and workers should be advised not to feed bears. C. Fencing should consist of a minimum 7 -foot high chain-link fence with a mesh type of fencing along the bottom (buried one -foot below grade level and extending a minimum of two -feet above grade) capable of preventing small animals from entering between the gaps (gaps should be no larger than three -inches). D. The pit shall be constructed with a 4:1 slope escape ramp and/or with chain-link fencing in one corner of the pit to allow entrapped wildlife to escape. E. The pit shall be adequately netted to ensure that waterfowl and other birds are prevented from entering. F. No construction activity shall occur during the time period from March 1 through June 30 to minimize impacts to sage -grouse production areas. 15. Prior to issuance of the Land Use Change Permit, The Applicant shall install anti -perching devices on all structures within the facility, including fences, to prevent predators from preying on small animals and Greater -Sage Grouse. 201 'a Board of County Commissioners December 16, 2013 LI PA7675 Other 16. CPW shall be notified immediately if any birds and/or wildlife are found dead or trapped within or around the pit, netting, or fences. 17. The applicant shall conduct on-site weed inventory in the spring or early summer of 2014 and provide the information to the County Vegetation Manager by June 30, 2014. 101, irr n . ,10.74. tIvr-J.fir .1 --lir 1 ihia,1441.;.41,414fit'.01.1..likui.••.i..•-: • tri:t.••111,,iht• 1lT1L 11 .121•14 EXHIBIT 111.111111111.1.1111111111 •ZIPF11:111, 1 PROJECT INFORMATION Request Applicant Representative Location Access Property Data Water Sanitation Zoning Water Impoundments/Storage OXY USA WTP LP — Daniel Padilla Jeff Hofman — Olsson Associates 23 miles north of DeBeque CR 213 (Conn Creek Road) to private road system 640 -acre parcel; 21.47 -acre project Unmanned Facility Unmanned Facility Resource Lands — Plateau Comprehensive Plan Resource Production/Natural• 1 ` r S1# SI, • 6�"1 1 s 63 itt!i --if ii �te it lil,fk'. r 1 r 1tY rro ix 0°0'14 !! !� ✓ r i, !! 0. -; l 11 ,mr11•- s f r�,el 2 i1 �2 Ir ^) r M P. au) cc V• W IL1+In CS ▪ Ct. Fe 63 10 C3 R t4 tu 7 / ___ .0 r J i. (6C-3) ) -. SITE PLAN ▪ ..' 7 - � ---- / \ �. I / ?'-6-WATERLINES � '� air' *•� lJ /'� W.A L PANELS �` ft r '' , L '. , r } '" NC SEED) NON -ENCLOSE▪ D/ #�� Cv$7•1�` • 1 r — r coNCRt Tr. ar,% f G.4.04 -E� ! PUMP PAD I ETAIL "A" LLE'=A: J /�� SOLAR PANEL ' -� 8.41411,.,� � (NON -ENCLOSED) '`• . / ``iI\ SOLAR PANEL N.` 1 ` ` i % �..., ,.. .�....,., - - Y� u+ (NON -ENCLOSED) ac, , T pa , — ___,111 == ti •sue .ri-,ue.„,..„ I i , ..,• '' R e. ' ,� C'�� \ "\ WEST POND / , /' / w=, ,l ti0100r0, ... \ \ \ - t1+ ,, 0.981 ACRES / / % 4► .,‘":,4,,,S, ► \ r \ 4. .tib r CENTER POND ARA / / ' •, �%�- e� \ \ \ \ \ \... `\ NOTAL POND AREA: 2.131. ACRES 1 / / i .4•\••••v% .,-% . ' - • \ \ \ ,it ` NAD 83 POSITION: —~ -^o+' / / tie '11S •` fi Yr. . t \ \ \ xr \ 39.32'55.0" NORTH ' / / .II ` ` Z ► + "\ \ '' \ ' u,',\ \\i; 106'13'01.0- WEST ]� 6 / / \ \ \ \ \ • ' -- * a ► rax MCP \\ \ \ \ \ 4.::412100<s. % / : . \ \ \ \ \ \ \ . \ \V 44'4 a ilk .i- / / 1 `\\ \ \\ \ \\ \\ \ - ,�1, ea, CO),.. , 2 // //1' StiOCAR PANEL \ 91t, \\ \ \\ \ \ 1- N I - qw ��--11 / / (NON -ENCLOSED) la ,1 \'"' cr �\ \\ \� \I \\� �,� \ yam'` y r rf (NON-ENCLOSED)N • Q•••. y • • ti SITE PLAN I EVIL "A" EXISTING FENCE.0.'LINER N. f 1 / / ;I / / Es f / / / ! / / #f S3 / l a Pt / / / f SOLAR PANEL / (NON -ENCLOSED) Capacity 68,010 BBL EAST POND 1.17± ACRES �� )�n / 1 .r /, / / / / I ' r / / / 1 �I / I CONCRETE PAD (NON -ENCLOSED)/ / POWER PANEL _ ; ,r / / / / / r ♦ 1 (NON -SNCL OSED) �.. / _ 0 LIMITED IMPACT REVIEW o Issues • Existing facility is a violation of the land use code; • Demonstration of adequate access is lacking — Applicant seeks a waiver from this standard; • Water Quality Issues- Grading, Drainage and Erosion Control information; • Liners and leak detection systems specifications needed; • Wildlife Impacts — CPW recommendations / Greater -Sage Grouse; • Environmental/Nuisance Impacts — odor and noise. • CONDITIONS o CPW recommendations include: • Chain-link fencing of the site should include a mesh type of fencing along the bottom capable of preventing small animals from entering between gaps; • Construction of the pit with a 4:1 slope escape ramp and/or with chain-link fencing in one corner of the pit to allow entrapped wildlife to escape; • The pit shall be adequately netted to ensure that waterfowl and other birds are prevented from entering. Applicant response, Exhibit Q, appears to agree to these conditions but requests that CPW amend the netting requirement to "sufficient bird landing deterrent controls to ensure that waterfowl and other birds are prevented from entering." No response from CPW. • +ONDITIONS o Engineering recommendations include: • Provision of Grading and Drainage Plan of project area; • Provision of an Erosion Control Plan for the project area; • Provision of specifications and details for the proposed liners and leak detection system; • Provision of information regarding materials to be stored on the site; • Air quality analysis and permitting should include all activities on the site. • CONDITIONS o Staff recommendations include: • Installation of anti -perching devices to minimize predation on small animals and Greater -Sage Grouse; • Provision of a noise analysis demonstrating site compliance with COGCC noise standards; • Confirmation from the Applicant that all pipelines serving the facility are properly permitted, as applicable; • Provision of a supplement to the Traffic Study to include all uses within the project area; • Provision of permits from state agencies; • That all applicable building permits be obtained for structures existing or proposed within the project; • Provision of a site weed inventory prior to June 30, 2014. z 0 H MW W 1--1 11 W z 0 11 W C? P4 0 Fronts IUrbv Wvnr Tot Kathy A. Eastiev Subject Referail: LIPA7e75 Oxy central water Dates i'rWiy, November 15, 2013 6:6:27 AM EXHIBIT Hi Kathy, Gave it a look, I have no comments on this application. --Kirby Kirby Wynn 01! and Gas Liaison Community Development o (970) 625-5905 c (970) 987-2557 kwynnalgarfleld-county.corn e. Garfield County From' Mprgan Hill TO; Kotive A. Eastli Subject) Oxy Pond 13 !IW LIR Ref rril Dotal Wedhtidpv, November 27, 2013 4:05:56 PM Hi Kathy, My comments for the Oxy USA WTP LP Pond 13 E/W Centralized E&P Waste Management Facility are as follows: Air quality; The applicant should be sure to obtain proper permits from the Alr Pollution Control Division as mentioned in the letter included in the application. Best management practices to minimize the emission of volatile organic compounds from the produced water ponds should also be adhered to. Water quality; Since the location of the site Is considered to be in a flash flood zone, the pond should be constructed in a manner so as to allow for the accumulation of water and materials without the occurrence of an overflow spill from the pond. o The applicant should pay close attention to the leak detection units mentioned In the application that will be utilized on the centralized produced water impoundments. Leak detection should also be a prlorlty In the pipelines coming to and from the ponds. Despite the fact that the materials stored in this facility are exempt from a hazardous waste designation as exploration and production waste, they still have the potential to adversely impact regional air and water quality if not properly managed. Please consider this in the construction and operation of the facility. o As always, I take issue with the statement that "adjacent lands will not be impacted by the generation of vapor, dust, smoke, glare, or vibration." Despite the fact that this facility is proposed adjacent to compatible land uses, Its construction and operation can and will add to regional dust and VOC emissions. Please use language reflective of the impacts that will occur and how the applicant plans to manage those. The applicant should consider the use of storage tanks rather than pits as they are more easily controlled and often reduce air emissions. Thank you and have a Happy Thanksglvingl Mo?Q i i NI/V Environmental Health Specialist II Garfield County Public Health 195 W. 14th Street Rifle, CO 81650 Phone; (970) 665-6383 Email: mhill@garfield-county.com www.garfleld-county.com/environmental•health • Following the completion of construction activities, newly exposed soils should be revegetated as soon as possible to prevent erosion and to reduce the likelihood of non- native plants becoming established in the area. Seed mix used for revegetation should be certified as weed -free and consist of native seeds from plants that are common to the area. • To reduce the likelihood of truck wildlife collisions, proper speed limits (< 25 mph) should he posted and enforced on all service roads. • Fencing around the pit should consist of a minimum of a 7 -foot chain-link fence capable of preventing elk and deer from entering the pit; concurrently it should have a small mesh type of fencing along the bottom of the fence (buried one -foot below grade level and extending a minimum of two -feet above grade) capable of preventing small animals from entering between the gaps (gaps should be no larger than three -inches). • The pit should be constructed with a 4:1 slope escape ramp and/or with chain-link fencing in one corner of the pit to allow entrapped wildlife to escape. • The pit should be adequately netted to ensure that waterfowl and other birds are prevented from entering. CPW requests to be notified immediately if any birds and/or wildlife are found dead or trapped within or around the pit, netting, or fences. • Construction activities for the facility should occur outside of the time period from March 1 through June 30 to minimize impacts to sage -grouse production areas. Colorado Parks and Wildlife appreciates the opportunity to work with Garfield County on this and other projects for the benefit of wildlife. If you have any questions please contact Albert Romero, District Wildlife Manager, at 970-216-3847. Area Wildlife Manager cc: Ron Velarde, NW Regional Manager Dean Riggs, Assistant NW Regional Manager Michael Warren, Energy Liaison Albert Romero, District Wildlife Manager Jim Kornatinsky, Land Use Specialist File 2 COLORADO PARKS & WILDLIFE Northwest Regional Office 711 independent Ave! Grand Junction, Colorado 81505 Phone (970)255.6100 ■ FAX (970)255-6111 wildlife.state.co.us • parks.state.co.us November 25, 2013 Kathy Eastley Garfield County Building and Planning Department 108 81h Street, Suite 401 Glenwood Springs, CO 81601 REt Oxy Pond 13 WW Centralized E&P Waste Management Facility Dear Ms. Eastley: EXHIBIT 1 �i Colorado Parks and Wildlife (CPW) would like to thank you for the opportunity to work with Garfield County in the review of the Oxy Pond 13 EIW Centralized E&P Waste Management Facility. This project is to be located in the NE './.1 of the SE'-{ and the SE 1/1 of the SE of Section 4, Township 6 South, Range 97 West, of the 6th Principal Meridiani in unincorporated Garfield County on an existing location. This request would convert an existing production pond to a centralized E&P waste management facility. It is our understanding that the purpose of the facility is to conserve water by recycling flow -back and produced water for re -use in well stimulations or drilling and that no proposed facility structures, access roads. or surface water diversion structures will be required. This site and associated access road k located within a greater sage -grouse production area and black hear year-round range No significant impacts to wildlife are anticipated if the following recommendations are incorporated into the development of this project: • Night lighting should be of the full -cutoff type and/or tinted or otherwise minimized to reduce disruption to wildlife. • The proposed location lies within year-round black bear habitat where human/bear conflicts have previously occurred. There is potential for human/bear conflicts with gas exploration employees who are working andfor camping in these areas during development operations. The potential for human/bear conflicts within these project areas would be greatly reduced by placing and utilizing "bear proof" trash containers at work-site/camping locations. Furthermore, workers affiliated with these projects should be advised not to feed bears, whether intentional or not, since this activity is a violation of Colorado Parks and Wildlife Commission Regulations and is detrimental to wild bears. CPW has information on the design and purchase of "bear prooftrash containers, and will provide this information to anyone who is interested in preventing conflicts with bears. STATE OF COLORADO John W. Hlcker>looper, Governor • Mike King, E=xecutive Oirevlor. Department of Mature! Resourule Steven M Yamashita, Acting Direclor, Colorado Parks and mama Parka end Wildlife Commission: Robert W Bray • Chris Caetilian • Joanne Homo URI Kane, Vlce•Chdr • Gaspar Porr4cane • James Pnbyl • John Singletary, Chair Mark Smith, Secretary • James Vigil • Dean Wing4M1eld • Michelle Zimmerman Ex Officio Members: M,ke King and John Salazar From: Nick Marx To; Kathy A. Eastlev Subjects Oxy pond 13 EIW Oita: Friday, November 15, 2013 8:21:35 AM EXHIBIT I see no problem with having this pond converted. It should be benificial in reducing transportation of hazardous material. Nick Marx ❑eBeque Fire Chief Prom Mitt Keesbery Tot KaOw A. Eaatiev 1i.14ecto 'Oxy Pond 13 VW Daus Monday, Osoenber 02, 2013 10:23:04 AM Kathy, Road and Bridge hu no exceptions to Oxy USA request to convert 2 existing ponds to a centralized impoundment area. wyatt wyaitt Key Garfield County Road & Bridge District foreman 0298 C.R. a333A Rifle, Co. 81650 Office: 970-625-8601 Cell: 970=309-6073 December 3, 2013 Ms. Kathy Eastley Garfield County Planning 108 81l' Street, Suite 401 Glenwood Springs, CO 81601 MOUNTAIN CROSS ENGINEERING, INC. Clvl! end Environmental Cor.....",. ~ •,__, RE: Review of OXY USA WTP LP Pond 13 is/W: MPA -7675 Dear Kathy: EXHIBIT This office has performed a review of the documents provided for the Limited Impact Review Application of the OXY USA Pond 13 E/W. The submittal was found to be thorough and well organized, The following comments were generated: 1, The narrative makes it sonnet as if it will also be a contractor/storage yard, The rest of the application does not discuss what is intended to be stored. The Applicant should explain in greater detail the intended storage use. Depending on the materials being stored, this may require amendments to previously submitted reports, 2. On the northern storage area there appears to be a generator building and some smaller structures, perhaps some storage tanks. These items need to be addressed in the impact analysis and may require amendments to the reports initially provided by the Applicant: tank sizes, secondary containment volume, noise studies for the generator, effects on wildlife, etc. 3. The drainage report states that there will be no change to the site. It is lay understanding that there may not have been a drainage study for the initial site grading. The drainage study should evaluate that the existing grading and constructed conveyances are adequate to convey the anticipated stoma flows around and through the site. Calculations would he necessary to, justify this, 4. The site grading/drainage plan should be revised to show how water will drain around the site and from the storage areas to the designed f3MPs. Some mlinor grading of the site may be required to ensure positive drainage. 5, The Erosion Control Plan only shows one of the proposed storage areas, The northern storage area should be included. 6, The Applicant states that waters in the ponds are from non -tributary sources only. Precipitation would be a tributary source of water. The Applicant should discuss if the ponds will be covered and how precipitation will be separated and/or drained from non -tributary waters, Water -rights and/or an augmentation plan may be necessary. The Applicant should clarify. 020 Y Grand Avenue, Glenwood Springs, CO 81601 P: 970.945.5644 F; 970.945.5556 www.rnotantnlncross-eng.corn Pond 13 E'W Page 2 oft December, 2013 7. The Applicant should provide specifications and details for the proposed liners and leak detection systems of the ponds. 8. Air regulatory permitting analysis was in progress and not included in the materials. This analysis should include the small structures discussed above, the generator building, and the items proposed to be stored in the storage areas. If these items arc not include, an amended analysis should be prepared to include them. Feel free to call if you have any questions or comments. Sincerely, Mountaju Cross Engine ing, Inc. f;l Chris I -tale, P12 Mountain Cross Engineering. Inc Civil and Environmental Consulting and Design 826' /a Grand Avenue, Glenwood Springs, CO 81601 P: 970.945.5544 F: 970.945.5550 www.mountainaross-ang.com December 6, 2013 EXHIBIT '\4 Garfield County Kathy Eastley Garfield County Community Development Department RE: Oxy Pond 13 ENV, File # LUPA 7676 Dear Kathy, Thanks for the opportunity to comment. Noxious Weeds Vegetation i1'1a►rrrjenrent The noxious weed plan submitted in the application is acceptable, however a site specific inventory is not included. Due to the time of year, an inventory won't be possible until next spring Staff requests that the applicant conduct an on- site weed inventory in the spring or early summer of 2014 and provide the Information on a map to thls office by June 30. 2014. Revegetation The Reclamation Plan and proposed seed mixes are acceptable. Staff will not recommend a revegetation security as there will not be any immediate seeding done. Please let me know if you have any questions. Sincerely, Steve Anthony Garfield County Vegetation Manager 0375 County Road 352, Bldg 20130 Rifle, CO 01680 Phone; 470.945.1377 x 4308 Fix: 970.628.8939 O\OLSSON (,0 A s s O C i A r e s December 6, 2013 Kathy Eastley, AICP Senior Planner Garfield County Community Development 108 8th Street, #401 Glenwood Springs, CO 81601 keast i ey+2ga rf Feld-cou nty. com EXHIBIT Re: OXY USA WTP LP Pond 13 ENV, LIPA 7675 Dear Ms. Eastley: This Fetter is in response to Morgan HMV's environmental health comments dated November 27, 2013. Air Quality: The applicant should be sure to obtain proper permits from the Air Pollution Control Division as mentioned in the letter Included in the application. Best management practices to minimize the emission of volatile organic compounds from the produced water ponds should also be adhered to. Response: Noted. The proposed use of the ponds is to recycle water for hydraulic fracturing. Minimizing the use of the ponds is the best management practice that Oxy employs. Oxy has assessed the need for Air Quality permits for these ponds. The ponds qualify fora CDPHE Reg 3, II,D.1.uuu exemption, which states: Surface water storage impoundment of non -potable water and storm water evaporation ponds, with the exceptions of oil and gas production wastewater impoundments (including produced water tanks) containing equal to or more than one percent by volume crude oil on an annual average and commercial facilities that accept oil and gas production wastewater for processing. Additionally, Oxy's legal department determined that Oxy pond operations are not considered commercial facilities. Oxy performs quarterly sampling of the pond to monitor compliance with the exemption. - Water Quality: o Since the location of the site Is considered to be in a flash flood zone, the pond should be constructed In a manner so as to allow for the accumulation of water and materials without the occurrence of an overflow spill from the pond. 760 Horizon {Drive, Suite 102 TEL 970283.7800 Grand Junction, Co 81506 FAX 970,263,7456 www.olssonassociates.com OXY USA WTP LP Pond 13 EIW, LIPA 7675 Response: The ponds are located 200 to 400 feet above Cascade Creek, the flash flood zone. The ponds will be reviewed through the COGCC Rule 900 series, specifically Rule 908.b(5)E: "Surface water diversion structures, including, but not !united to berms and ditches, shall be constructed to accommodate a one hundred (100) year, twenty-four (24) hour event. The facility shall be designed and constructed with a run-on control system to prevent flow onto the facility during peak discharge and a run-off control system to contain the water volume from a twenty-five (25) year, twenty-four (24) hour storm." Additionally, per COGCC Rule 902.b the pond will maintain 2 feet of freeboard between the surface of the fluids in the impoundment and the top of the liner. Please see attached as -built construction document and approved COGCC Form 15 pit permits for more details. The applicant should pay close attention to the leak detection units mentioned In the application that will be utilized on the centralized produced water impoundments. Leak detection should also be a priority in the pipelines coming to and from the ponds. Response: Noted. When the ponds are upgraded, Oxy will install a leak detection system that will be monitored at least monthly and will be documented on the attached monitoring form. Oxy will conduct the appropriate investigation if fluids are identified in the leak monitoring. Transfers of fluid through pipelines are monitored by Operations personnel. Loss of pressure or other signs of a spill will be investigated and reported to applicable agencies Despite the fact that the materials stored In this facility are exempt from a hazardous waste designation as exploration and production waste, they still have the potential to adversely impact regional air and water quality if not properly managed. Please consider this in the construction and operation of the facility. 0 As always, I take Issue with the statement that 'adjacent lands will not be Impacted by the generation of vapor, dust, smoke, glare, or vibration." Despite the fact that this facility Is proposed adjacent to compatible land uses, Its construction and operation can and will add to regional dust and VOC emissions, Please use language reflective of the impacts that will occur and how the applicant plans to manage those. Response: The nearest adjacent property boundary is approximately 1086 feet to the south. That parcel is owned by Oxy. The nearest adjacent property that Oxy does not have an interest in is approximately 3178 feet to the north. Potential impacts to adjacent property from the generation of vapor, dust, smoke, glare or vibration will be investigated and mitigated if appropriate in order to accommodate the intent and regulatory limits set forth by Garfield County, the COGCC, the CDPFIE and other regulatory agencies. Dust control due to transport truck activity will be implemented by Oxy field personnel to ensure compliance with COGCC Rule 805.c, which states Response to Environmental Health Comments Page 2 OXY USA WTP LP Pond 13 EIW, LIPA 7675 Operators shall employ practices for control of fugitive dust caused by their operations. Such practices shall include but are not limited to the use of speed restrictions, regular road maintenance, and restriction of construction activity during high -wind days. Additional management practices such as road surfacing, wind breaks and barriers, or automation of wells to reduce truck traffic may also be required if technologically feasible and economically reasonable to minimize fugitive dust emissions, The current dust control measures used on existing Oxy operations have been extended to this Facility and its access roads. Oxy implements reduced speed limits, a roving speed check to monitor speed on its private roads, application of water by road spreader, and chemical applications to suppress dust. The primary method used will be to apply water to the roads accessing this Facility as needed to control dust, as necessary. As stated in the Traffic Analysis, Oxy anticipates truck support traffic to be minimal. The applicant should consider the use of storage tanks rather than pits as they are more easily controlled and often reduce air emissions. Response: Noted. Use of large capacity above ground storage tanks was contemplated. These are existing ponds which are being upgraded from multi -well production pits to a Centralized E&P Waste Management Facility in order to make the best use of existing facilities. These pits are being upgraded to minimize new surface disturbances, construction activity and additional capital expenditures in the area. Thank you for your consideration. Sincerely, Tilde Evans Olsson Associates Cc: Daniel Padilla, Oxy File Attachments. Sheet 1 - Water Storage Pit Location B As -Constructed Volumes Form 15 - Facility 414403 Form 15 - Facility 414404 Response to Environmental Health Commente Page 3 ._ MOM .IMMf Pat* lI Y W...1..J '.r• 1 .. YMsa I$YFY MyII N S$ r{wM M I*q* tfS11IiN WNI.,rt..MM IMMO rucirrrirrant rrrwri 1 11 1 1 1 1 1 1 { 1 1 1 1 1 I i #1 i 1 1 1 11 T Iy 1 r a 1 1 1 1 n 1 1 i C4V USA WITIt4. WATER STO Roe /IT! W4 141 ■M 0.1 WATER STORAGE PIT • LOCATION 8 A8•CONBTRUCTE0 VOLUMES twn MQN' Id hOIIQ BM onnwir 11101411111 ifirnn nRRIEtiaaiillrgikilr rucirrrirrant rrrwri 1 11 1 1 1 1 1 1 { 1 1 1 1 1 I i #1 i 1 1 1 11 T Iy 1 r a 1 1 1 1 n 1 1 i C4V USA WITIt4. WATER STO Roe /IT! W4 141 ■M 0.1 WATER STORAGE PIT • LOCATION 8 A8•CONBTRUCTE0 VOLUMES twn MQN' Id hOIIQ BM onnwir 11101411111 1111111 11111 State of Colorado 011 and Gas Conservation Commission t t n. Lincoln 8trool, Sulie 301, Denver, Colorado 80203 (303}804.2100 Fee f303)(194.2100 EARTHEN PIT REPORTIPERMIT RECEIVED Nov 0 8 COGCC This form II 113 be used for both mooning and permitlinfl pits. Ruta SO3 deacrrbea when a Permit with prior approval, ora Report within 30 days. li required for ono Submit rsgwred sllechmsnta and forms. FORM SUBMITTED FOR; 0Pit Report f JPIt Permit FOA 00CC UR ONLY Complete the A(1aohment Ctteoklhl 9oor OOCC cele 104 10 film OGCC Operator Number; eve' Nome of Cper/lot OXY VSA WFP LP Addrssi P.O. BOX 27787 City Hourlon Soil: TX p 771187.707 Contact Nora Ind TNphony a_Pad - No (070 283.3637 Fox (17012434026 ~ API Number (or &sicc4t/d wig) 01-041.1 MU - OGCC Foolllty 10 (of olher 'twilled leolliiyl: PN Locution IOtr0v, Sec. Twp. Ftop, Vend'si 8181- Sec 4 Teb, P37W, dth Pot LHllude 31149417 1ppihrde. '101 +47a County airfield Uee t4 Produclon ❑ (A liilq (Mao mud pogrom) DSpociel Purpose (O,Kribe WIN - - - Pit Type: 0lined M Unlined Surface 0recharpo Permit: 0 yes m No 011,11, disposal of pit contlnto, ❑ leen-ton QJ Commsrcill PillFeellily Name clxr Mesa Ara Pond AIIWOh Form 31 to I*Ntdfy Soros Wills turd Form i to provldl Produced Wily Analyill r11Wls. tore 41 wi ntierarw wow MOW do ?4 aevrw well horn N) n,oww.,.10141,64.1 baui}ry1 Cetautetwne /Inas A.rw Dolton r I4ud Prpiram Form M Diff !illy No; 131 ExI Pt7 Site 4 dl inn is the lccatwn Ina '10,15 444 ku'r' (] Yea o A a wed for datermineddn. Drelerc4 (in dill to mem IWIEC4 *tier Inc' - oround *Cr 300' welsr w/41 1 a miry LAND USE (or sllech copy of Form 2A If previously submllled for wlotilted well) 8elsot plywtsloh beet described lend uar. Crop Lend, ❑ Impaled Non•Crop Llnd:m RongWnd S bdhirled. Q Irrdul341 Dry lord ❑improved Pialuro 1:11-1 by MNdow ❑CRP ❑ "unbo ❑ Rocruellpnel ❑ ou,r (describe) ©Commwper ❑ Nadeau TOILS (or insch copy of Forst dA if prertoualy submitted for esioclalsd veld) Soil Nip Lois form USNRCS ivrvsy. 5140 No. IT - Skil Corn/11001e Nis N Soils Sono. Nems- f ereohuio•Irlui Cornps x Mori ion IN4kn/a1 ikl PdIeI}: k 040 111 80111 Soh Serie' Noma - Heinen Ihlcknoso 1ln Inoheel' k ;I: Attach detseed sits plan end lopo mop *Nh pll looadon, C:. ftyA C: Pit Design and Construction &z1 of pt resets Lsnpe+: J10 _ _ Wsdth 110 _ -- _ Depth-_-- CsIctNeled phi whams (1411(. 81,544 Dolly inflow rete (odyday)240 Doily diswool rotes (aNeon sakulallons): Erapa(llion;__bb(Vday PerccN4011: "Dile bbk/doy Type of liner motorial: Damon Pohyethyhne Tnicknell 00 mos Attsoh dewripUon of propol/d dollen Ind oonitruOlen (lnoIuds s4ilehu and 4Noulotion i). (AH1gd01MtWient of produoelwelsr pricv to Mows, into pi•(11permor. nester sestet, a0M4) IeserII h pi kneed IZYN DNo I1 pi MtM4 ❑Yes No I hereby certify tFif8M slaismertla made In this form ere, Print Name, Dim* Padela Title; IleeulaloryCoordrasor OQCC Approved: CONDITIONS Of APPROVAL, IP ANTI the Rest of my ftnowillrTe, uu r Cele: Signed nd ci7mpiele. J. Title JER5. FACILITY HUMS : GO Moses landing 81' to 804-44 Pad Approx. Scale; 1" • 100' SERE, Sac 4, TOS, ROM, 81" PM OXY USA WTP LP As -Built of OXY's Mesa WS Pond 13E Garfield County, Colorado Oct 15, 2008 RECC1VED NOV 0 3 2108 8E9E, floc 4, TAB, R87W, 6th PM Approx. Scale: 1" a 200' OXY USA WTP LP As•8ullt of OXY's Mesa W8 Pond 13E Garfield County, Colorado Oct 20, 2008 Figure 2 1 Side View Dens* PolYelhylene >fr�f -•, ,1 Power° solar powered ecopment Water level with 2' fr c `••,. Pads outside pit 11ft W C PRODUCTION PIT Raid level indicator masses pressure and =weft hydric head to feet of ticpid above it Volume of Pit = 52,555 bb%s (with 2' freeboard) Volume Calculariorr = 111(250•120)44200•150)+(22575)] 3 295,075 cu ft = 52,555 bbls Volume of r = 499 l it free board tine OXY USA YYTP LP Production Pit OXY Mesa WS Pond 13E SESE. Sec 4. T6S, 1397W, 66 PMA (Garfield County) ��(y0 2 Oct , 2008 Not to scale I Page 1 of 1 RECEIVED 1 NOV q 3 2000 Calculations for Earthen Pit Permit Application COG+ Calculation of Pit Capacities. Pit capacities were estimated from length and width measured at ground level and at the bottom of the pit Figure 1 shows the top view with the measured dimensions shown. For non -rectangular shapes, equivalent dimensions were used for volume calculations. For capacity calculations, the depth was reduced by two feet Brom the total pit depth to allow for a minimum of the required two feet of freeboard, Figure 1. Top View den earthen pit. Figure 2 shows the dimensions and calculated terms in a cross-sectional view du pit. The angle (i is calculated From the length and width at the Surface and the freeboard depth. Pits aro designed to have a 2 (horizontal) to 1 (vertical) slope on the sides. With a 2 to 1 slope the angle 13 is 63.435° from vertical as shown by tho yellow shaded area, a Surface Length Du c Total Depth Of ■ Freeboard Depth Figure 2. Cross-section of an earthen pit. RECEIVED NOV 03 1000 A sample calculation is shown based on the construction design for 2500 barrel i51 a I0 -ft depth. The following terms are defined: L. - surface length 80' W. = surface width - 50' Lb - length along bottom - 40' Wb - width along bottom 10' D, - total depth - 10' Dr - depth with 2' t onboard (D, — 2') The distance at can be calculated from the measured surface Lengths: ai - (L... W/2 - (80'- 40')12 - 20' The angle 13 can be calculated using the two sides of the yellow -shaded triangle. Tariff - opposite side/adjacent side - 20'f 10' - 2.0 and taking the arctangent, a - 63.435°. Side km the 'mailer yellow triangle can then be calculated using the angle 13 with the freeboard depth as: a:- Dr* Tangent it-8'*2.0- 16' 1-r- Ls - 2 * (al -a2) - 80' -- 2*(20'-16') - 72' The widths were calculated in the same manner using the same angle 8: al - (W,. Wb)/2 - (50'- 10')11 - 20' as - Dr* Tangent 13 - 8'*2.0 -16 Wr - '4Ws • 2 * (al -aa) = 50' — 21(20'.161 — 42' Capaoities were calculated using the standard formula for a truncated rectangular pyramid at follows where V is the pit capacity in cubic Net: Dr*[Lr* Wr+(Li +W;r��/XLb+ V%)+Lb* 'b] /3 Substituting example values (all dimensions are in feet) into the volumes equation: RECEIVED NOV 0 3 2008 8*`72*42+(72+4/)40--1„0/1)+40* 10,1 V = /2 3 The resulting volume is 12,930.7 ft3. Convening to barrels the capacity is: Capacity - 12930.7 f13f5,61458 f13/bbl - 2303 bblt; Freeboard Surface Calculations Surface Volume at Freeboard Line The volume at the freeboard line is calculated fora depth of 1 inch using the freeboard length and width and converting to barrels as: SurfaeeVolumc • I.r (ft) • Wr (ft) • (1 "depth) 5.61458 cu ft/bbl For the example calculation: Surface volume of 1" Q freeboard line . (721•(42')"(1/12')15.61458 t13fbbl - 45 bbls Erraporatlon Rate The evaporation rate is calculated from the:;urfacv area at the freeboard bald on the average evaporation rata for Garfield County of 45 in/yr/sq ft surface area. The evaporation rate in barrels per day is calculated by the equation: Evaporation Rate Lf (fl) * Wr (ft) * (evap rate (in) / 12) (365 days/yr) * (5,61458 cu ft/bbl) Using the sample calculation numbers the evaporation in bbl/day is: Evaporation rate . (72')*(42')*(45 'VI2) / (365 days/yr)*(5.61458 f13/bbl) 5,5 bblfday iii iuiian1i 15 State of Colorado Rev 610 I 011 end Gu Coneervatlon Commission 1120 Lincoln steal, Wheal. Denver. Colorado e0203 ('003)a44.210D Pax:{303) 4.2139 EARTHEN PIT REPORT/PERMIT Thea form Is to be uasd for both reporting end psrmItlin9 piss. Ruse 403 dsicdbes when s Permit with prior epprovel, or Report within 30 days, Is required far pile. Submit required enrichments and forme OCT 2 3 2008 COGCC FORM SUBMITTED FOR: Plt Report Pit Permit Complete the Allsohmenl Cheokllel flaw oaec NMI ed tip}} Pian ropyAispwrisLveke e OGCC Operelor Number: eee7i Nems of operelec OXY USA WTP LP Addrm P.O. Dag 117767 City, Heuv Ion Stell. TA Ilp: 77777.7057 Contact Nems end Telephone. Denial Pedalo No: (070) 703.3037 Fax, 1070) 141,N26 WMnrFroyve ?OM t DI rkiCtawill for" U1 •90414HtIo►ssi %elan Celouladons i.nr1M. Arae Delsrm, 1Asr4 Pr e+ Ppm 2A API Number (of ss1oNH4l wN1). OOCC FscIy ID (01 oiler ieeoolsted hcrlltyt: RA Looedon (271920+, Sao, Twp, Rog, Merlin): I411 Sue, TSI, 107W, ere PM LaRuds: )1,449447 .OAQ tud4:.10l Mee County: Gereeld P1 Use ® Production D Dii (AREA mud progrsml ❑8pedsl Purpose (Describe UM). PP Type m Lhsd ❑ li arned Sarflcs O'iceirge Perm! 0 Yes to No 011r0s dlspeiol or p1 contmh ❑ IrOicie ' [l Commercial ;klPsdley Nur,. OXY Mese WO Pend Peg k No. 13W Mein Mem 21 to Identify Soares Wows sod Farm tl to provide Produud W.Nr Anslytrls rNYlls. ExlEi oShe�rdl Q Is tee iDr,�on h a 'Witty. Areal' c] Yu o u dllsrmins4ian, Dkit 'ce (1n h4) to nearest norm a water. 1714' Around 200 wile' wail:. 21 move LAND USI (or sltsch copy or Form 2A If previously subrrltNd for ueoolsled woe) 'nut Dbl which Deet deuoriees land use: Crop Lend: ❑ Impaled ❑ Dry Lend ❑Improved Pastan ❑eiay Msedow ❑CRP Non•CrcpLend:®Rugslsnd 0TrmDOr ❑Reatetic nrd ❑ Other (descries): 8ubdlvided' ❑ incluselei ❑ Commercial ❑Raklonlid 801.11 (or snot on of Form 2A if pfin lously eubmIlled for essoolalsd will) eoH msp units lam USNRCS survey. Sheet No: 1e _ _ 5o0 Complex/101.i No: ga SoJIs Sulu Nemo. PIlecihutorleseriCrimplia Horizon thtlinfie{In Iniac); k 010 ;1: Solis 84110 Herne: Horizon IhlOkneel (In hte111): Al 0: Allsop delink alts plan end logo map Ato pit!Dutton. 1075 ; C, WA :C Pit Design end Construction tiles of pH (SISI): Lingle. 7711 Widal: IVY NO: 10r Cudulals° pit volume )bbi tiI, Dilly Irk/write (bbfsWey); Drily dieposelntss (mach ca'culetlbne): Erewelkin: k__,„ _bA4ldsy Peroalstion: nom oft,* Typo al skill me*erlat: ►egh Deru,b PoNtinylana Thickness: 00 milt Aileohdeio1pt(on or proposed daslgn end OanslNllion (Inoludsseetolse end osfculitions), Method of eutnAM of prodtoed water prior to Outage Into psi (Npistor, hosier lrftli oewr): 0+pereror h ell fenced? ❑Yes ❑No le pH ner,dO❑Y.. No 1 hereby paltry list the steel menu made In thl.Torm ars, to the 11es pf my knowledge, True. Cor i red co Print Name: Danly P0doe signed: Titre. f'49001elY Coonfna o' - �� Dl) : Q ale. OCC Approved; 7111e: CONDITIONS OP APPROVAL, 1! A Osla: 'PAClLITYNUMBRRI' i 4L.1 JAL OCT 2 3 2008 CQ - Access landing 81' to 604-+14 Pad SESE, Soo 4, T88, R87W, 9M PM Approx, Scala: 1" • 100' OXY USA WTP LP As -Built of OXY Mesa WS Pond 13W Garfield County, Colorado Oct 16, 2008 1 Figure 1 OCT 2 3 2008 COGCC 8E8E, Seo 4, T88, RQ7W, 8th PM Approx. Scale: 1" 200` OXY USA WTP LP Oct 20, As -Built of OXY Mesa W8 Pond 13W Garfield County, Colorado 2006 Figure 1 r MOE 1 S State of Colorado Itry'"i 1 Oil and Gas Conservation Commission 1120 Lincoln Itrsst. Sults 801, Denver, Colorado 40.203 (X131104.2100 Fu:(303)614.2140 wort f 5.1 EARTHEN PIT REPORT/PERMIT FThls form It lo be used for bosh reporting and permltIng pati, Rule SO3 dncrlbas when a Permit wllh prior approval, or a Report within 30 days, Is required for pile. Iubr II required ettiohmsnts end forms. 1/4 FORM SUBMITTED FOR: PIt Report l PIt Permit OCT 2 3 2009 COGCC OGCC Cpefelor Number, WTI Contract Nems end Ts4 hone; Omit Padllia (170) 213.30317 Pm WO} 243•21.28 Nome of Cpemtor: OXY u11A WTP I.1+ Mdliu: P.D. IO1ITN? C y: l ot.el°n e*.' TX zip' 77227.71117 Complete the Misch mint Ch.okllst Ose OOCC veluemi Pi/n T porMa++rPilw1110, l Waist MOM ?OM e/I ,sw weik(Fam to PIo.e M��rLi4 OHIO IW CeYen Celoofelfons �1lnllrw Area Wan. Muclineutot 1 Farm AA API Number (of eieedstsd ws0 OGCC Pacaky ID (of other sssoC1led fit'kty): Pk LDCiter(Q Q'r, Seo, The, R4, ktertderl): X111, No 4, Tei Re7W, sbv PM _ Lioluds: 3e.54840 WNW: .tod2le2s_ county Oartled Pe We: ¢I Produolon O DIN (,Medi mud prooron+l ®Sped.! Purdy., (Describe Wee): Pit Typo ® Chid 0Urikild Surfed D Wench Permit: ❑ Ya. m No Olfute a'NISI of piconlealn ❑Y'4eadal OCarrrnerClel AUPickky Name 09[V Meea WS pard Mich Form 2i a ldittUlyr Source Wells end Fern 2e to provide Produced WMer Aesfysls reeudts PWPeoilty No: 13W oc n a rte a 11 N es 1 ro '. U. Dltance in reit) is Aures! /tannic/ weir. 1 i8O' ()round walar, 200' _ Waiter wells: 1.i rMs LAND UM (w Misch copy of Porm 2A if pfwbusly mubmHtad far usaolatsd wall) Beloit 10010 ball delergeSS Isnd vow Crop Lind ©irnpsled ❑ Dry Lend ❑Improved Figure ❑ Key Meadow ❑ CRP Nan•CropLord ,0RIngP.nd ❑Tinbar Reveller* ❑Othor(daswAbe); _ — 544vidsd; []lydueul/I ❑Cower/mil ©Res'dal;al f)Ofle (or .!itch Dopy of Form 2A If pravlauty submitted for esaoolated well) Soli mop tanks form UINRC5 survey: dhoti No a Iola Complexl8arlss No: 11 Soils 8srlos Nome: Fareuh;lle.ingul Com$Nx Horizon thickness (In inches); A MO ! e; HMI ; C; NIA Sale Series Name: Horizon eifokrtoI (in inch/.); AI it ;C: Atlioh deleltud sits plan and !opo map vett plt location, Pit Ceelen and Construotlo daze of pII (fssc)' Langur: 170' Width: 124' Depth; CeloufII$d pit voltam/ (WO- al Gily Inibw rate (bbliMuy); Deity disponi rates (.Mich calauistlons): f viporstion: �, ��ibllfd.y Percolation: r+or+4 - bblilday Type of kir materiel: Hie Deneb Parietl+Yr9Pe TMwee/: 40 m{ AHaoh de/.nelson of proposed dellen end conatnuolton (Ino/ude lk$lohee end col oviIUono). MIII,od of troareril of pradosd water WV to d ao s'yi OW pit (eepurator. heater treater, oder): sspereictr is pit t, ld, MVO ❑No le pit nixed, ❑ YM m No 1 hereby Certify tial the stiiarrrerlta rnIn tela form ere, to the bast of my knowledge, true, Cor,,��� nd oomplele. N / Print Name: Pv'14444 Signed: ! 7;Nr'►f Title; R p7 Coordkµtor _ � - lets: 00CC Approved:,( CONDITIONS OF APPROVAL IPA Title; �+ Dote: IrACiLI1'NNUMED1tl JAL Contact Name end Telephone: DiMel Papua 140.4570) 2534137 Fuc (P70) 24.3.2523 111111 NH 18 State of Colorado 41" ©II and aces Conservation Commission i I24l.lrcoln avail. Suite N il, Denver, Cake do 10203 (303)294.2100 Fss:(303)894.2109 EARTHEN PIT REPORT/PERMIT This form Is to ba used for both reporting and permitting pits. Rule 903 describer when a Permit with prior approval, or a Report within 30 days, Is required for Oh Submit required laltaohmenta and forms, FORM SUBMITTED FOR: PIt Re, ori Ft Pit Permit OGCC Op,TTEor Number: 7e871 Nsme of Dwow; OXY USA WfP LP mom P.O. las VW Sicuebsn State: Tx yip! 77917.7617 OCTlEVIVEIr 2 3 2008 coGcc Complete the Attachment Checklist • Ialf 'd 111 MOM _® AP'I Nuxabef (01111bo411d wsN)1 OVA Peo1 y ID ref othst amoclated faintly): Pk LooNlon (CYQ7, Sea, rip, Rep, Meridian): 1888, 1104, TIS, IoW, S61 PM Lslllude: 99,841427 _ lorgllude; •10821028 County: 06fled Pb We IZ1 Production D Drilling (Attach mud program) flpedrl Purpose {NKrlbs Use)' Ptt Type: Milled p Unlined Surface Dircherge Permit. ❑ Yn M No °Stile disposal of pi =den is 0 InJrcdon M Commercial plVFec*Iy Name: O)IY Mels Wb Pond Pitif 101ly No 13W Attach Fond 20 to kindly Source Wells end Form 2810 prorlde Produced Wiley Analysis results. Exlstlna Bite Conndltions 11 $. Welkin in 4'3end6ve Anal J] Yes mm No, e utile for determine-1ton, Dlydence tin lest} 10 Mania suds cs water: 1210' ground wale( 300' water wally; 1.6 mllea LAND UIS (or sheet copy of Form 2A If previously aubmilled for associated well) Select oda whloft beet describes land use: Crap land 0Irrigated ❑ Dry Lend ❑lmprav,d Ps vivre ❑Hay Meadow D CRP Non•Crdp L end ® Reng*Iand © Thebe ©Rf estarel 0 Cthet ldeserie : 96 tomdad: itvotrial ❑Gammen* ❑RerklMlii WILE (or ettaoh copy of Form 2A 11 previously submItlW for Meooleled wlil) Bac map units born USN'RC8 uuney, Shan Nor 18 Soh Cadged/Swiss No. 11 Sala Series Meme: Perwn,415•Ir$pvi Complex Monroe IhlckMes {In inches): A: 0.10 ; S; I1.1e C; NIA Solt 8onlos Nene: Horizon 4hltkMse (In VII). A: : C: Attach detailed sits plan end logo map All pill location, PH Design and Construction Size or o,t (last): Lsegity azo' _ _ *Mt 108 OK CMaired pd vokims (b910 40041 Doty Mow re* (bblefdey). 280 13 Deily disport non (MO r.I vEECdns): evaporation: 54 _ bbb'dry Perac1arion: 'seine obi silty Typs of attar mune( I Wei Oen* P478P+yrsne Thickness 60 tura Anaoh demrlption of proposed dollen and oonrtruotion {Include aketahu and Wooled ons). Mrlhod of beatmsnt of produosd wales prior to d(oherge Into pit Wipers tor, holler 114stsr, other); Nperrlor Is ph fenced? ®Yee DNo Ispll netted? 0Yas rallo I hereby oerl[fy Viet Ifhe atetemMlu naris M )hie form In, 10 theles! of my knowledge, Irue, cozand complete, Print Herne: Cantel Padilla Signed;. > Tine Reguat0ry Coordinator I Date:, O3CC Approved: CONDITIONI OP APPftC1VAL. IF A Tide OA. 4t4EMC--- FACILITYNUMBER; l 7 r 11110 • PORki 15 State of Colorado ger 1"6 .1 011 and Gu Conservation Commission 1120 Limb 8lre*t Suite 601, Domrer. C44100 10203 (303)891.2100 Fix ;{S73)b24.210D EARTHEN PIT REPORTIPERMIT r s3 J• l; This form 11 to be used for both reporting and perrnlMing p'te, Rues 203 dsscribta when* Pernik with prior approval, or a R*port within 30 days, Is required for pii1. Submit required *ltiohmentl end forms. 1 FORM SUBMITTED POR: ❑Pit Report MPH Permit OGCC Operator Number: S4671 Nemo of Opsrstor: QXV USA WTP LP Addrttl: P.Q. Tort 27767 Coy: Nourion &late' TXIIp: 77227.7617 Control Name Ind Tellphons: DIn! 1loodli No: tem 1e3 7 pax; (874943-28211 OCT 2 3 2008 COGCC Compliti the Aileohmint ChsakPsi Dosrca Osuga4lu Plan tato Mie wt ra L04211Prt MAN Mskrlr IPor. K1 IawGT Wil4 (Pim it 0�41ovr l Grrl iwk. 141gn Cakulllfons h A/1.DOIwm. 1 1 Mu4 Pr arsm Perm 1A API Number sof aaiodstld *411); QOCC Flaky 10 (of olive 1.1o011104 fi ;I : PI looslion (QlrCitr, boo, Twp. R09,1,404144): alibi. leo 4, TIC 1417W, at PM+ Lalrluda 7/44/417 .on , •102.11010 _ Court Oi1IiO RI Um ® Production t7 Veins IAnwh mud proprsmi 08p041 Purpaa 1Dtecrise Ula); Pt Tyr/ : 231 id ❑ LJ*.d Sur loi Dllc1 arcs Ptml ❑ YM M No Olhlte 0404141 o( 04 cCnitn:l: ❑ Irdldion M CorwnertIs1 Pk'Frdsly Nims' OX MOO we Pond PIUPacilry No: 13W Attach Farm 211 to Identity loads WINS and Forel id to provide Prodassd Were Anply li reau4la. Exi , a lite fiQn tian1 r1 els U6 e e0 is rho 1pcaeon Ih a °Isnt!Evi Amer - - ❑ Yes r dilerminafton, 0i!YKe ton tsst) 10 nuLii1 *write wow. SAID' 1fOtind water: 21Ze0' wiIx+ wags' _,a 71" LAND UN for Wish Dopy of Pon 2A If prlvinuely evbmttled for asuoolaWd wall] Seim( wt+loh bw1 dosorlbu lied use; Grog Lend: ❑ Irrlpetpd 0 Dry Lend ❑Improved Picture El Hey Meadow ❑ 0R9 Non•CIOpLlnd:®Rlnpl:erd ©TInbor ❑Rscrootlorll 00*her(dsxxrl ) gawks pp Cl 1nduix it ❑Corm :trciel 1:R4110044i 8011.0 for aflaah ocpy of Porm 2A 11 previously subreKted for associated well) Soo moo milli form UBNRCI troy. Shull No: Se Ioll Compoxl8idii No. FI Sol Sods; Nome: Parixhuli•lriVul Oomplix 4ronidn thlckntel (In Ante). A; COQ , 0: SO.10 C. NIA kelt Bolts Name: _ Koko ih4 I nns (In Indus): A: ; 8: ; C: Minh def ailed ills Men and lopo mop with pK lowttelt. PR Design and Construction fibre of pIt (fest): Lwrglh: 1T4' W4d x D1pet: 1S' C/Ioultlld pit voiurno (bbls): 422111 Dally Mow rile ltttilllide4 Dllly(Repoli rill (MO 0111000nlj: Ilviporsilan_.. _0011101y Ptrc01slox: nprte odlldly nos or liner outwit War! QlnNly Porvtlnyllrxl Thic4Mle: 00 mer Attach dslorlPOOP of proposed dollar end osn.tivetlon (Inoludaakelohe6 Ind oalavlationl), *hod of to Nmtnl of produold wIi r prior to dlrllargs IMo p4! leo New, hestw decor. orhor1: whets l0r Is pi !wool ®Yes [J44o l pk nttld7 [arra mNo 1 Hereby osrly the( mods In tlils Form vs, to die bell of my knovr�sdgl, irve. Cotr n corn e PAM Nemo. 00n4 Psdse _ Signed 'Lr" Till: 1142I4IIO7 Cam (vis r r _ Dote:._ L 0000 Approved. OQHOITIQNa or APPROVAL, rP A TIlra: OPS - 'r rr• r,� � . Dare: PACILITYNUMSIR: Ian A sample calculation is shown based on the construction design for a 2500 barrel pit with a 10 -ft depth. The following terms are defined: L, - surface length - 80' W, - surface width - 50' Lb - length along bottom - 40' Wb - width along bottom 10' Dt ti total depth - 10' Dr- depth with 2' freeboard (Dt — 2') The distance al can bo calculated from the measured surface lengths: al - (L,. 14)/2 - (80'- 40')/2 - 20' Tho angle 13 can be calculated using the two sides of the yellow -shaded triangle. Tarifa.. opposite side/adjacent side - 201/10' - 2.0 and taking the =tangent, Gl - 63.435°. Side ea on the smaller yellow triangle can then be calculated using the angle 0 with the freeboard depth as: ax- DrTangent 0-8'*2.0- 16' Lf Ls - 2 * (al -a2) - 80' — 2*(20'46') - 72' The widths wore calculated in the same manner using the same angle 1: al - (W, . Wb)/2 - (50'- 10')12 - 20' ay. Dr*Tangent 13-8'*2.0- 16 Wr- Ws - 2 * (al -al) - 50' — 2*(20'-16') 42' Capacities were calculated using the standard formula for a truncated rectangular pyramid as follows where Vis the pit capacity in cubic feet: Dr*[Lf* Wr+( + )(Lb+ W )/)+Lb* Wbj V = / 3 Substituting example values (all dimensions are in feet) into the volume equation: 8 ij72*42+ (72 + 4% x40+1%)+ 40'110 OCT 2 3 2008 COGCC 3 Tho resulting volume is 12,930.7 ft3. Converting to barrels the capacity is: Capaoiry - 12930.7 ft3/5.61458 ft3/bbl • 2303 bbls Freeboard Surface Calculations Surface Volume at Freeboard Line The volume at the freeboard line is calculated for a depth of 1 inch using tho freeboard length and width and converting to barrels as: SurfaccVolume - Ir (ft) * Wr (ft) • (1 "depth) 5,61458 cu fVbbl For the example calculation: Surface volume of 1" Q freeboard Zine (72')*(42')*(1112")15.61458 f13/bbl - 45 bbls Evaporation Rate The evaporation rate is calculated from the surface area at the freeboard based on the average evaporation rate for ©arfleid County of 45 in/yr/sq ft surface area. The evaporation rato in barrels per day is calculated by the equation: Evaporation Rate•Lr (ft) * Wr (ft) * (ern rate (in�112) (365 days/yr)* (5.61458 cu ft/bbl) Using the sample calculation numbers the evaporation in bbVday is: Evaporation rate - (72')*(42')*(45 "/12) / (365 dayslyr)*(5,6145$ ft3/bbl) - 5,5 bbVday O\OLSSONkt ASSOCIATES December 6, 2013 Kathy Eastley, AICP Senior Planner Garfield County Community Development 108 8th Street, #401 Glenwood Springs, CO 81601 keastleyQgerfietd•county,com Re. OXY USA WTP LP Pond 13 EIW, LIRA 7675 Dear Ms. Eastley This letter is in response to Mountain Cross Engineering's comments dated December 3, 2013. The narrative makes it sound as if it will also be a conlractorlstorage yard. The rest of the application does not discuss what is intended to be stored. The Applicant should explain in greater detail the intended storage use. Depending on the materials being stored, this may require amendments to previously submitted reports. Response: As stated in the Protect Description, Oxy proposes to use a portion of the well pad to the north of the water impoundments as a storage yard as defined in the Garfield County Land Use Code. Examples of items to be stored include surface poly pipe, supplies needed for maintenance such as fencing and netting, and equipment such as front loaders and backhoes. No hazardous materials will be stored at the site. 2. On the northern storage area there appears to be a generator building and some smaller structures, perhaps some storage tanks. These items need to be addressed In the impact analysis and may require amendments to the reports initially provided by the Applicant: tank sizes, secondary containment volume, noise studies for the generator, effects on wildlife, etc. Response: The northern storage area consists of a COGCC permitted well pad. Aboveground appurtenances associated with the well pad include the well head, production unit and production tanks. See the attached approved APD and associated SPCC site diagrams and overview sheets. The generator structure located on the pad supports the pond operations. This structure has been discussed with Andy Schwaller and the appropriate building permits will be obtained along with a sound analysis for the generator. 3. The drainage report states that there will be no change to the site. It is my understanding that there may not have been a drainage study for the Initial site grading. The drainage study should evaluate that the existing grading and constructed conveyances ere adequate to convey the anticipated storm flows around and through the site. Calculations would be necessary to justify this. Response: A drainage study is in progress to evaluate the appropriate run-on and run-off control for the project. The study is anticipated to be submitted in approximately two weeks. 760 Horizon Drive, Suite 102 TEL 970,203.7800 Grand Junction, CO 81506 FAX 970.263.7456 www.olssonassociates.com OXY USA WTP LP Pond 13 E/W, LIPA 7675 4. The site grading/drainage plan should be revised to show how water will drain around the site and from the storage areas to the designed BMPs. Some minor grading of the site may be required to ensure positive drainage. Response: Noted. Conveyance around the project site and within the project site will be evaluated with the previously mentioned drainage study. 5. The Erosion Control Plan only shows one of the proposed storage areas. The northern storage area should be included. Response: Noted. The Erosion Control Plan will be modified during the preparation of the previously mentioned drainage study. 6. The Applicant states that waters In the ponds are from non -tributary sources only. Precipitation would be a tributary source of water. The Applicant shoutd discuss if the ponds will be covered and how precipitation will be separated and/or drained from non -tributary waters. Water -rights and/or an augmentation plan may be necessary. The Applicant should clarify. Response: The ponds will not be covered. The Department of Water Resources and the COGCC view precipitation with respect to these types of ponds as being de ntinimis. The precipitation that enters the ponds becomes Exploration & Production (E&P) waste and shall be handled as E&P waste. Water rights and augmentation plans are not required. Offsite run-on will be minimized and analyzed in the previously mentioned drainage study 7. The Applicant should provide specifications and details for the proposed liners and leak detection systems of the ponds. Response: Noted. Specifications and details will be submitted when available 8, Air regulatory permitting analysis was in progress and not included in the materials. This analysis should include the small structures discussed above, the generator building, and the items proposed to be stored In the storage areas. If these Items are not Included, an amended analysis should be prepared to Include them. Response: The generator is exempt from CDPHE permit requirements Attached is the APEN only/permit exemption letter from CDPHE. All required testing for NSPS Subpart JJJJ has been completed for the unit. The production tanks associated with the well pad are exempt from APEN filing due to very low production rates. Current emission rates are 0.6 tpy VOC In addition the heater associated with the separator is also exempt from APEN filing or permitting since it has a low burner rating. Thank you for your consideration. Sincerely, Tilde Evans Olsson Associates Cc: Daniel Padilla, Oxy File Attachments: Approved COGCC Form 2 APD Pad 844.44 SPCC Overview and Site Diagram Pond 13W SPCC Overview and Site Diagram Pond 13E SPCC Overview and Site Diagram CDPHE Permit Exempt Letter No. 11GA1950 Response to Mountain Cross Engineering Comments Page 2 State of Colorado 6.7.3 Oil and Gas Conservation Commission 1110 Wain Strut. $uili 801, 0enrr, CaNis5a 90203 13031991-1108 Faa, (303091 j21{099#- { j] {{jj uu 1n50r e'yO APPLICATION FOR PERMI ��I �I�ill f I fi 11 O Drill, ❑ Deepen, D Re-enter, 0 Recons 012663 5 2 TYPE Of WELL /1' y I sialoetr�llingci� L OIL 0 DAD E COAL DED ❑ °TFIER' p BINDLE zONC ( MULTtPL6 zone 0 corium LE zoeiEs [] 3. OOCC Operetor Number 66571 4, Nam M Operator- OXT 014 IMP LP 5. Memel; 5 oR*RMtAY PLAZA, 50I7t 110 Cly. HOUSTON Steal: TX ;p;77046 ec Woes 5 Moro tar CP 411 I*T Do!ooc RECEIVED JUN 6 Vit; PFusiofl rilattrety 100: MR. T. KEZST WOO plans, 17531 250-4565 Fes. 17131 350.4973 7. Win Name' CASCADE CDIDEK ,./ was llanbel: 604-44 5 Unt Nuns {if VP'.]] T4/A 9, Pr *id Taal Depth: 9,. 350' Vna No: N/A Complete the Attachment Checklist Ocrc rPe 41ewr44 a C4.44 4, .V M terve .A0 a r Cpluse ,__I Fr NW Swam Prel £t.,, r T WELL LOCATION 1NFORMATiON 10 QtrQ41: NESE sac 4 Twp: 6S Eng: 97W Msrelken- 111 Y.M. Footage From Extorter Soden Lines: Atburtaou 927 'FEL 3,044'ESL 0.- $1 ' 11. rold Nene :GRAND VALLEYt/ PlreNumber 31290 rou 12 Gnd E!waft n 8601' ye_ 13. County: GARFtELO N' 14 M 4410 ts: (] 04'440060 0+ oareetel 41450tel 0114151061 eebrret 444e1Med c1 p Pilo. Fedi gebum [jingo,SeditoUna sNinaSoo Two Fire N/1a Vertical well P+®vn5war Wert Lew 6144 1.4 Pant WM.14} Qnlrr.derM.ri Tian Rory ex E. " araea l -_ er.�vilarMe�YW,ar/ tae Ilona Deem e ewe Polo. f.aM�idyrwM1wtt W • tent templet. porter swell) re towel At Top of Prorio:eon Zees - At OOtton1Hole ........... 15 els lopHon on a high deroairy a.'*J (R;AI 803027 p 0 Yes •• 1 0+ ca 14Oat newest bu7d,ig, 514c roof. agpyq irryncuu 1y or ul5vaa more than a mile 17 swim. to Neereu Property UN, j 1 ell G IL Mance lo few met wd 60n501444 51 Lama ro'maron x 3,525' -o 6 E o� e la- a_ 1,4 05 022. o cUt 500 c10t"_ maU O Q_ a d) > 19 LEASE SPACING. AND POOLING INFORMATION lZiketlfee Fdn1 Monts) FornUtt on Code 15pec005 order Nrallber 1ku1 assess A1sleeee to Wee Llnit Cen.tun!!on tea sew -141 wsl. urine XVI Fl MO, 10 ACLU rasa 2400 0 9 oduct.ion 7 7/9 4 1 /2 11.5 9350 1000 9350 4200 20 Malerer 0ronsrlhlp. 0 Flee 0 St.S. D %dere n !Mian 21 Sul eco Owers p: ] Fee Dstam 0 Peeve 0ir4Es7, 11 the 5urta 0r,rr Nilo Or Rowel Owner? C I vs* �N0 &mew If No E flu olan 0001012 AersennsM Method a 0 225,000 &wart Storm ane 23 Neat* lease are■ modeled oily *1h 81e I try gee, Top. Ado tram* Leaf e: +''1,�r 8wey er e: ,Qf i0 f p 0 12.000 sudice Bond 13 WOW Surface Wand ware. fi eettnep 6 reou5ledl: 24 Oiskenn, to Nonni Lase Ura. 3 F 4 2 1 ' ----- 25 rotas Abbe be Lula:. x —1 -td Q 50 • DRILLING PLANS AND PROCEDURES 24. open Spud0s5e. July 2, van NOTE: F5kibesdrihs,roWry 21. OrranyCOn4etror%umber: 10050 Nom, 0ARY HILLER 28 la 1445 Anildpa1ed- Q Y.p 1 No it res. sawn od4En/gsncy pIFi. 29. WH 444 ricins be encountereddum (Wee �© Yes 2 NO 30 16 30 ()•15,000 ppm Tin 00 or or based rade be L,200 during dreep T 0 Yes lel 4uneane 29 or 30 elle roe. a this emotion in. s seeetee ern We* 40317 0 Yss Q NO JA�,6� ■ DKINS 32 ssuo disposal I0 o11sMs 0 4rn4e caYLi'1. J,lYai. tu+ MaihCd. 0 Lana rarmrns puna spraadng ❑ imam&Fey 0 001er ® (970).285.9000. SEE NOTICES NOTE: The use of an earthen pit For ream fluids rbrNulret a pit a.perms (Rule BO6b), 33. CASING AND CEMENTING PROGRAM braxy Saar of Hale Size of Ca Leg We1sh1 Per Fw1 Steens Dam Saris Gamsrn rout an offlrle4 --1 U d h Phones; (305)555-5309 ! 24 HOUR SPUD NOTICE © No REQUIRED. CONTACT COOCC N+ Cerra n1 tfottom Cermet Tep 8urfetc e 14 3/4 9 5 /s 23 2400 1300 2400 0 9 oduct.ion 7 7/9 4 1 /2 11.5 9350 1000 9350 4200 / L Spee Tool 34. SOP FeelP i,1i T s 0 Annutr ',mentor 0 Double Ram G Hoban Hue 0 Nell. 35 Comm ,ti,a.ny-5Fs3: ATTACHED COVER LETTER DATED Jt1EE 15, 2004 FOR ADDITIQNAL xl vaIuTIoN.. ]F/„cel 304 I hereby ear* ihe1 the statements made In this Frim ate, to 'ha best 01 my knowledge, true, correct, and complete, Print Name. - -- K �..- W i .` LEYC.l7wt le-,/ :147;14 YItW' .,_tdiur la.1111.2Bd±SI4 Gate: %►3. OGCC Approved 17 j' }741,4401C.... Director of IC OGCC Date 1 //�� API NUMBER Permit Number 4 14 z f rration pate OS- 1 s { i418S- cats' fT30Niit1FAEM AL_I ti1Lt _ 2 e- ? t n -et)kd r ssetre. on Cr�lM?Viet-ftin c-efer - .~,�” ..) .Yr 0 0 O.yS cAL Cowk li -i o ✓� P •(- Slimed ff15i,pfi STATE OF• COLORADO CONSERVATION COMMISSION EPARTMI t r OF NAYIlRAC RESOJACES Bill Owens, Gmernor 1120 Lincoln St., Suite 861 • Denver, CO 80203 Phone: (303) 894-2100 FAX: (303) 894.2109 wwwilli-gas.state.co.us NOTICE TO ALL OPERATORS DRILLING WILLIAMS FORK FORMATION WELLS IN GARFIELD COUNTY SURFACE CASING DEPTH AND MODIFICATION OF LEAKOFF TEST REQUIREMENTS May 3, 2001 (Amends September 22, 1998 Notice) • Based on the evaluation of leakoff test data, drilling histories, and reservoir pararne'ers for Williams Fork Formation weirs In Garfield County, the surface casing setting depth requirements specified in the September 22, 1998 policy statement will remain in effect with the exception of new requirements for welts drilled in the Grand Valley Field. Surface casing leakoff tests will be performed at the discretion of the operator when the 10% of total depth or 1,100 ft of surface casing Inset as specified In this policy. With the exception of wells drilled in the Grand Valley Feld, the following conditions are to be attached to al Permits to Drill for Williams Fork Formation gas wells in Garfield County. The following shall be required In the Rulison Field Overpressured Area, and Is optional In all other fletds: 1. The Rulison Feld Overpressured Area is the following (see attached map): Township 6 South, Mange 94 West, Sections 9,15.23,26.35 Township T South, Range 94 West, Sections 2-6,8-10,11,15,16 ` 2. Surface casing must be set at s minimum depth of 1,100 feet A surface casing shoe leakoff test will be performed at the discretion of the operator. Notify the COGCC Northwest Area Engineer during the running of the surface casing so that he may have the opportunity to witness the test. 3. Provide all leak off fest results with the Completion Report Form 5 when it is submitted. The following shalt be required in all fields outside the Rulison Field Overpressured Area: I. Surface casing must be set at a minimum depth of ten percent (10%) of the total depth of the well. 2. A surface casing shoe leak off test will be performed atthe discretion of the operator. Notify the COGCC Northwest Area Engineer during the running of the surface casing so that he may nave the opportunity to witness the test. 3. Provide all leak off test resuits with the Completion Report Form 5 when R is submitted. The following shall also be required for ALL Williams Fork Formation welts drilled In Garfield County 1. Ail iostrirculationzones and.gas kicks:rnu -Lbe reported to the COGCC No'rthwest Colorado Area Engineer es soon s#easibtewftnlrrtwenty four.tnours,.and;shall be provided with the Completion Report Form 5 when . it is submitted.7,Thekillowingtlata Is required: depths, -mud volumes lost, mud weights before and after kicksnndproceduees..used-to controi kicks. Submittal of mud logs which Include this information is also aCceptabie. . 2. When the well reaches total depth, the operator must notify the COGCC Northwest Colorado Area Engineer as soon es feasible within six hours to provide an opportunity for the prodtitrtion casing cementing operations to be witnessed. Thank you for cooperating with these requirements. Rich Griebling,, Director bye The Northwest Colorado Area Engineer Is: Jaime Adkins, Loma, Colorado Battlement Mesa Office (910) 285-90Q0 Battlement Mesa FAX (970) 285.5559 Cellular Phone (970) 250-2440 niENrr OF NATURAL RESOURCES. Grog E. Mew. E+aw0+s OYpeta COOOC CO+MrnlflSiOtt Tb,, M , Caul - anon Gee . enx• Johnsen - Michael 101A . Abe 9MiHp o . Dolled gumboot • SMohen Solvesr•berq COGCC STAFF; Riswd T. Gerabllnq. Ofterif - RAan J. Marks, Deputy Minim - 14o04 Beit ape *kg a Manager PaT C. Sower. Hastings :tanager - Tlsomae 1140r, lam/nation Minim' 2 18 17• 19 4- sto pg, aa+1.1•P4,• �.. •.,a• P Lames Glom - yar—yn 2,. 9 • ,�.... , r4•• all.. ea.+ee 16 • '10 C e7.4 -IP INIC414 35.004.1 ! X111• NA-S"TOT fosse* ToTeeer Itigmet41 u.seIary ••a•an Awl SWOT K. .w. •�^�' riP cam 1.1 4• 15 sa• 14 •we.au 44 IMANIen 1•■ Om* 42"" Wag* • I 74RN.11 i . •CRS.• laµ. . .60, .44 ' •r w• war • NK' Ole 04 an 144 Dorm• impinctt • [.1 1.-,a .- 4F-,• 41.•• wt. rYl laYar PLOW ,10 alLOOO l' '29 RRb jljl K Ia.� bra 31 �' ■ 26 lm • raw rt. • .4•. 1 �1•f1 33 I 4.49 4,' b ..i lea4• I ..i 1i-• •r• � : 4i l•P .5 G y r.y. w. ,, . •.I.■ r germ 'ewe" 18 4 u • OimirM 0" OuL, 44 do .0-140.1 — ott.-17 16 'Ova 1•`111•'•'• 7. .4.01.06.4 Oapo•ovimpou limmt Odima f,1a• /Y• fawn ■r,..,■ Illi • ■e• 15 T &S 11ll T,7 s . — fl.a•/ SOP w OOL gUL/son/ F/ECA t' VE R PR ssPR t A 14 OAR A Woof 0e/30/2004 10:23 FAX 3037219298 GREYSTONE J002 • • • iwimnl'mental COnSulta44, Inc: - • `Sem t.by Facsimile J .,. ..303.894.21;)9:. . June 30, 2004' Ms.' Linda Pavelka Permitting Senn . • ' . Colorado:Oil :and Gas •Conservation Comtn7ission • • '1120.Liacoln Street, Suite 801 Ttettver, Color *tk, 80203 • • AFP'h'•cttio i ITor Pertlt to Drill (APP) • Colorado.a11 and Gas Conservation Cuuntission (COGCC) Well Name: Cascade Creek 604-44 Legal Location: 927' FEL, 1814' FSL, Section 4 (T6S, R97W, 6th P.M.) Operator.: OXY •USA WTI' LP . County: •GaitelilCOunty, Colorado • • pear Ms. Paveilca. :- - • OXY•'USA :WTP LP '(o YY) is 'currently" drilling the OXY Federal 23115 well in the SW/4SW/4`of'Section 15 (T6S, R97W, 66 P.M.) in Garfield County, Colorado. As: of =thin mo ing,;OXY's drilling contra tor was drilling below 7,000' is this well'witli a ' planned TDof9,200'. As soon as the drilling contractor, reaches. TD•m the QXY Federal•.- ' .=23-15,„well; OXY wishes to move the drilling rig to -the Cascade Creek:60444 well. 1 subinitted the APD material, to you for the Cascade Creek 614-44 well. en June 16, .2604:. That 'sa]me day, Mr. Doug Dennison, acting *on behalf of Garfield County,': 'submitted a- letter. addressed to Mr.. Richard Grnebling with the COGCC stating that the county waived the local governmental designee and notification: requircmenta contained in COGCC Rules 103(d) and 305(1?). 1n 'addition, at:OXY's requtst, the surface owners the .;.drilis rte location for the; Cascade Creek60444 well . waived the notice -. requirements imposed under = CO.GCC. Rule 3(15 by _ sighing OXY's Mono covering ' COGCC:.Rule305- 'Notice Requirements?' A copyof the signcd memo wasincluded with.the:APD material that I subrnitted'to you on June 16: If peissible; `OXY requests that .the COGCC approve the :drilling Wit- for the Cascade • Creek 60444 'well,by. next Tuesday (July 6) so that Oxy's drilling conlr4ctor can Move • : the: drilling rig to the location for:the Cascade Creek 604-44 well: • • '5 3`['South Quebec•Sttreet ■ Grecawood Village, ColoradolO1'11 ' Phone (303) 850.=0930 •'Fax (303)•,72119248 . 06/30/2004 16.29 FAI 30372192©8 GREYSTONE IVILr+. L nrda Paviika. Permitting Solon Colorado Oil Ind Gas Conservation C..arnrnission 3uhc 30, 2004 . 'pip 2.:• Please contact me •at.:3031850-0930 if you have anyquestions or need any additional iniformation rt gardi tg the APD fna.the Cascade, Creek 604-44 well. ..Thank you for your assistance. y .'Yours rdon R.Pa • . GPljg• .Enclosures Co:• Mr. T. Kent Woolley. Senior Landman Advisor Occidtmtal Oi and Gas Corporation Yames W; Konat Operations Manager ,` fail and Gas Corporation - . ' 0630:030 (Mc.l.aidt. Naeolk.-COGcC) • 1003 •, 08/30/2004 16:23 FAX 3037219298 GREYSTONH I oo1 FAX TRANSMISSION GREYSTONE ENVIRONMENTA[. CONSULTANTS, INC. 5231 South Quebec Street Englewood, CO 80111 Phone: (303) 850.0930 Fax: (303) 721-9290 Date: June 30, 2004 Pages: plus this Facsimile Cover Page To: Ms. Linda Bavelka Fax: 303/894-2109 Permitting Section Colorado Oil and Gas Conservation Commission Gordon R. Palmer Greystone Subject: Application of Permit toDrell; Cascade Creek 604-44 Well Legal Location: 927' FEL, 1844' FSL, Section 4 (T6S, R97W, 66 P.M.) Operator: OXY USA WTP LP (OXY) County: Garfield County, Colorado Linda, OXY believes that its drilling contractor will finish drilling the well that it is currently drilling by early next week. if possible, OYY is seeking COGCC approval of the drilling permit for the Cascade Creek 604-44 well by July 6. Thank you, 0630.13 (l6. Lind P. vejjca - C)GGCC) QX' FACILITY OVERVIEW Facility Name 604-44 Operational Area Cascade Creek 3. Physical Location (coordinates) NESE Scc.4 T6S R97W, 6`s PM 4. Facility Contact Phone t (970)263.3600 Photo: 6. Facility Description (physical layout & function of facility): Natural gas production pad with one (1) wellhead, piped to a single separator. From the separator, the gas phase enters the Gas Soles Linc and the liquid phase is piped to one of two (2) storage tanks. A container of corrosion/scale inhibitor is maintained near the wellhead for in-line application as needed. A container of methanol is also maintained on-site for addition to Tines as needed to help inhibit freezing. 7. Drainage Pathway and Distnnce to Navigable Waters: Shill direction is t4 the West. The nearest surface water bodv is greater than Y4 mule from the Dad, Oil Storage Containers/Other Bulk Chemical Storage: SPCC Tank ID Contents Capacity Units (bblfgat) Type A Discharge Prevention CM T l Produced Water 400 bbl Steel wi Liner 1 l 1.1 CI T2 Condensate 400 bbl Stool wi Liner 1•I1.i C2TI Methanol 300 gal Steel ACC C3TI Corrosion Inhibitor/MCC-6252 150 gal Poly ACC C4T I Diesel ,, 7 Double Walled Tank ACC " Containment Types: Steel w/ or wfo Liner, Earthen, Poly, Hesco, Concrete, Steel Stock Tank, Steel Trough, etc. or a combination, as applicable a Discharge Prevention Measures: High Level Indicator (H1.1), Adequate Container Capacity (ACC), Top Equalization Lines ('TEL), Bottom Equalization Lanes (1311.), etc. or a combination, as applicable `9. Flow-Throt gh Process Vessels (Separators, Knock -out Po s, Filter Pods, etc). SPCC Unit ID Unit Type Material Processed Capacity Units (bblfgai) Containment Type SEPI 2 Pack Separator Produced Water & Condensate 42-84 gal General Secondary refer tv Section 5. IL, 10. Notes (out -of -service, cmnty tank storaue. nortable containers on-site. deviation from SPCC rules, etc.) Oxy SPCC Facility 604.44 Rev Datc, 10/15/2012 Page 3 E tb u u 1 '\ .. safe, seD ti • (Jail u g 1.1.10 pgmadl Tint ODD IirC'.'.'►0 FACILITY OVERVIEW Facility Narne Pond 13 West 2. Operational Area Cascade Creek 3. Physical Location (coordinates) SESE Sec.4 T6S R97W, 66 PM Facility Contact Phone # (970)263-3600 Photo: 6. Facility Description (physical layout & function of facility): This facility is a storage pond for produced or fYoah water, Oxy monitors the fluid level to ensure adequate fYeeboard by installing 'CONICS electronic equipment which transmits the fluid level to the field office in a daily report. Pond l3 West is equipped with a 60 -mil HDPE liner. 7. Drainage Pathway and Distance to Navigable Waters: Spill direction is to the south and the ngargs; water qdy is aporoximate'ly'/4 mile to the southwest, 8. Oil Storage Containers/Other Bulk Chemical Storage: SPCC Tank ID Contents Capacity UnitsDischarge Containment TypePrevention" Containment Type CIP1 Produced or Fresh Water 49,084 .(bbl//a) bbl Pond w/ 60 mil HDPE liner Level monitor and freeboard " Containmen Typos; Stool w/ or w/o Liner, Earthen, Poly, Hoseo, Concrete, Stool Stock Tank, Steel Trough, etc. or a combination, as applicable a Discharge Provontion Measures: High Level Indicator (HLI), Adequate Container Capacity (ACC), Top Equalization Linos (TEL), Bottom Equalization Linos (BPL), ctc. or a combination, as applicable 9, Flow-Thro ugh Process Vessels (Separators, Knock -out Pots, Filter Pods, otc): SPCC Unit ID Unit Type Material Procossed Capacity Units (bbl/gal) Containment Type PMP1 Pump Produced or Fresh WaterGeneral Secondary gofor to Section 5.1) PMP2 Pump Produced or Fresh Water _ General Secondary (rotor to Section 5.1) Notes (out•of service, empty tank storage, portable containers onsite, deviation fYom SPCC rules, etc,): Oxy SPCC Facility Pond 13 West Rev Date: 10/15/2012 Page 3 in) FACILITY OVERVIEW 1. Facility Mane Pond 13 East 2. Operational Arca Cascade Crock 3. Physical Location (coordinates) NESE Scc.4 T6S R97 W, 6'h PM 4. Facility Contact Phone 1* (970)263-3600 Photo: Drainage Pathway and Distance to Novi able Waters: 6. Facility Description (physical layout & function of facility): This facility is a storage pond for produced or fresh water. Oxy monitors the fluid level to ensure adequate freeboard by installing 'CONICS electronic equipment which transmits the fluid level to the field office in a daily report. Pond 13 East is equipped with a 60 -mil I IDPE liner. w 1f, Oil Storage Containers/Other Bulk Chemical Storage= SPCC Tank Contents Capacity UnitsDischarge'D (bbl/gal) Containment Type"Prevention" Containment Type CI P l Produced and Fresh Water 52,555 bbl Pond wi 60 mil 1IDPF liner Level monitor & freeboard ' C'ontainmcn Types: Steel w/ or w/o Liner, Earthen, Poly, 'loco, Concrete, Steel Stock Tank, Stool Trough, oto. or a combination, ns applicable a Discharge Prevention Measures: High Level Indicator (1ILI), Adequate Container Capacity (ACC), Top Equalization Lines (TEL), Bottom Equalization Lines (BLL}" etc. or a Cambin1ll011, us applicable " 9. Flow-Thro igh Process Vessels (Separators, Knock -out Pots, Filter Pods, etc): SPCC Unit ID Unit Typo Malorial Processed Capacity Units (bbl/gal) Containment Type PMP' Pump Produced and Fresh Water treneral Secondary (refer to Section 5.1) - . 10. Notes (out-or.sorvicc, en pty tank storage, portable containers on-site, deviation from SPCC riles, etc.): PMPI h Bitting in a catch basin that is 13"x1510" Oxy SPCC Facility Pond 13 East Rev Date: 10/15/2012 Pago 3 PP ...p........HHN.M,U.U \ 3�� ?.. g I i i 1811 11 w. g IA 1 1 1 1 ` 1 3 i g iA ::.. • ..■ u.iuuC..C'pe ......■ ........»CCC... w....... �•i.UU onmpimom�i�C�iul i ■.. mmumm C ...............ai.......R......,'..1 M I0 i 1 I I 41 i .9 g fpC x I ! 1 • 1 i f 1 [1. ,., i ifli, PP STATE OF COLORADO John W. Kickenrooper, Governor Christopher E. Urbino, MO MPH Executive Director an Cniel Medias! Othcer Dedicated to protectdnq and improving the health And environment of the people of Colorado 4300 Cherry Creek Dr, 9. Denver, Colorado 60246.1630 Phone (303) 692.2000 Located in Wendel,. Colorado hIlpllwww,Wont ete10 co.w December 6, 2011 Laboratory ServlceS Division 6100 Lowry Blvd. Denver, Colorado 60230-602a (303)692.3000 Mike Bryggsr OXY USA WTP Llmlted Partnership 760 Horizon Derive, Suite 101 Grand Junction, CO 81608 Colorado Department of Public Health and Environment ACTION: APEN REQUIRED PERMIT EXEMPTED RE Permit Application No. 11GA1950 Dear Mike Brygger: The Air Pollution Control Division (the Division) has reviewed your air emission permit application for the following engine One (1) Caterpillar, Model G3412C Tale, Serial Number to be determined, natural gas-fired, turbo - °harped, 4SLB reciprocating Internal combustion engine, site rated at 666 horsepower at 1800 RPM. This engine is equipped with no controls. This emission unit Is used to power electric pumps, for heat tracing and facility lighting. This engine will be located at the Pond 13 Generator, in the SESE Section 4, Township 65, Range 97W, In Darfield county, Colorado. It has been determined that this engine 1 exempt from permit requirements The flung of en Alr Pollutant Emissions Notice(s) (ADEN) is required. The above emission unit 1 a listed source that is specifically exempt from construction permit requirements, per Regulation No. 3, Part B, Section It,D.1.c.11i, Specifically, this exemption has been granted because emissions of nitrogen oxides and carbon monoxide are less than 10 tone per year each and the source Is located in en attainment area. If this engine is replaced with another engine, with uncontrolled actual emissions less then 10 tpy or mpnufacturer"s slits -rated horsepower less than 100, this exemption shall remain valid as long as a revised APEN la filed with the Division reflecting the change In equipment. This source shall be limited to a maximum consumption rate as listed below and all other activities, operational rates and numbers of equipment as stated in the eppilcation' Consumption of natural gas as fuel shall not exceed 33.94 MMaof per year. This exemption from permit requirements 1 issued in reliance upon the accuracy and completeness of Information suppiled by the applicant and Is conditioned upon construction, installation and operation In accordance with this information end with representations made by the applicant or applicant's 'gents. AIRS: 048171671001 Page 1 of 2 NGEnp+rle XP Version 20094 According to the Division's preliminary analysis, based on the submitted data and information, the equipment identified above will result in the emission of the following air pollutants. Annual fees will be billed for this source in accordance with and in the amounts and limits specified in the provisions of Colorado Revised Statutes section 25-7-114.1. Facility Equipment ID G-1 AIRS Point 001 NOx Tons per Year CO Voc 8.81 9.95 2.82 11 should be noted that although exempted sources may not need air emission permits, they are still required to meet all applicable standards and regulations of the Air Quality Control Commission, including visible emissions shall not exceed 20% opacity. A Revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, Section ILC.) a. Annually whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five tons per year or more, above the level reported on the last APEN submitted, or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the fast APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. The APEN associated with this exemption shall expire on 612012016. Any changes with respect to the original submittal which would result in increases in either emissions or ambient air impacts, or which would result in the emission of any pollutants not listed in the original submittal, automatically nullifies this exemption. Before actually making any such change, you must apply to the Division for a new exemption based on the anticipated change; if the Division denies the new exemption, you will have to obtain a permit before implementing the change, Sincerely, Adam Reed, EIT 1 Permit Engineer Stationary Sources Program Air Pollution Control Division PERMIT EXEMPT AIRS 045/2157/001 Page 2 of 2 NGEnpine XP Version 2009-1 Frotni Qdr Iel PadilloBoxy_ m Tot Steve Anthony Ct t jo athv A. Eastfev; ihoftnan olssonassociates.ca,r1 iubjicti 2013 Noxious Weeds Treatment at Pond 13!/W and 604.44 Pad dates Friday, December 06, 2013 2:43:15 PM Steve, We reviewed our noxious weeds treatment records for 2013 and Identified the following activities: 05/24/13: 604.44 (pad was vegetation free), conducted bareground treatment 06/01/13: Pond 13 E/W (grass present/type not specified), conducted bareground treatment 10/09/13: 604-44 and Pond 13 E/W (houndstongue and mulien), conducted spray treatments We'll make sure to conduct our noxious weed survey for these facilities in the spring/early summer and provide you with the report. Thanks, Daniel Daniel I, Padilla Regulatory Advisor OXY USA WTP LP and OXY USA Inc. Occidental 011 and Gas Corporation 760 Horizon Drive, Suite 101 Grand Junction, CO 81506 970,263.3637 - office 970.263.3694 - fax danlel_padllla@oxy,com From; paniel Pade a�a� ru To; albert_rpmero state.os.uk Cc: Kathy A, Easdev; it r Hama=nlssor}assmateIaor ; Pair Rollins{doxy con); r IlE2ELCCEI Subject: CPW Comment Letter to GarCo for Oxy"s Pond 13 EIW Facility Date; Wednesday, December 11, 2013 11:42:26 AM Attachments: Cove Pond 13 CPW Comment_ Lettei 11 25.2013,oclt Albert, EXHIBIT IQ Your office provided a comment letter dated November 25, 2013 to Garfield County's referral of Oxy's proposed Pond 13 E/W E&P Facility, see attached. Oxy is requesting your consideration to the following CPW recommendations: - Bullet 3, second page: Fencing around the pit should consist of a minimum of a 7 -foot chain-link fence capable of preventing elk and deer from entering the pit; concurrently it should have a small mesh type of fencing along the bottom of the fence (buried one -foot below grade level and extending a minimum of two feet above grade, capable of preventing small animals from entering between the gaps (gaps should be no larger than three -inches). o Oxy has an existing chain-link fence (approximately 8 feet tall) around the facility, but does not have the small mesh type fencing along the bottom of the fence. GarCo is proposing to make CWP's recommendation a Condition of Approval, but Oxy would like consideration of the existing fencing as constructed. Oxy would like to postpone any physical modifications of the fence until the facility finers are refit (existing liner pulled and replaced with a dual -liner and leak detection system). This would be completed as part of COGCC Form 28 permitting. Once approved by the COGCC Oxy would refit the facility which would require removal of the fence. At that time, Oxy would reinstall the fence with the recommended specifications. Would it be acceptable to recommend a postponement of the small mesh until COGCC review/approval? Please let us and GarCo know if you concur, - Bullet 5, second page: The pit should be adequately netted to ensure that waterfowl and other birds are prevented from entering. o GarCo is proposing make CPW's recommendation a Condition of Approval. Oxy is committed to keeping waterfowl and other birds from entering the facility. However, Oxy would like the flexibility to review and implement other sufficient bird deterrents bedsides netting. Although Oxy is currently costing out the installation of nets for this facility, Oxy is also considering the following devices: RADAR triggering noise deterrents, floating covers or similar floating deterrents that prohibit landing (floating rubber balls), non -RADAR noise deterrents, and a combination of passive controls such as flagging with decoy predators or other sight deterrents. Oxy is requesting that the verbiage be updated to consider other options and proposes the following verbiage: '"The pit should have sufficient bird landing deterrent controls to ensure that waterfowl and other birds are prevented from entering." Please let us and GarCo know if this or similar language would be sufficient to allow Oxy the flexibility to chose the most appropriate device for the facility. Please let me know if you have any questions and thank you for your consideration. Daniel Thanks, Daniel Daniel I. Padilla Regulatory Advisor OXY USA WTP LP and OXY USA Inc. Occidental Oil and Gas Corporation 760 Horizon Drive, Suite 101 • EXHIBIT I R POND 13 Conditions of Approval General Conditions 1. That all representations made by the Applicant in the application and public hearing shall be conditions of approval, unless specifically altered by the Board of County Commissioners. 2. That the facility shall operate in compliance with all applicable Federal, State, and local regulations governing the operation of this type of facility. 3. The land use change permit is for two water impoundments, 13E and 13W, not to exceed 3.3 -acres in size and storage capacity not to exceed 121480 Barrels of produced water. In addition, the 21.47 -acre project area is approved for two storage facilities as indicated on the approved site plan for a total area of 3.03 -acres. No hazardous material or fuel storage is permitted within the facility. Oxy agrees to these three general conditions. Conditions Prior to Issuance of Permit 4. Prior to issuance of the Land Use Change Permit, the Applicant shall provide a supplement to the Traffic Analysis confirming that Storage traffic was included in the analysis or updating the report as appropriate. The supplement shall include a finding consistent with the current study that no additional traffic improvements are recommended or provide specific recommendations that the Applicant shall be required to comply with subject to review by the County's Consulting Engineer. The traffic associated with the storage facilities wail originate Iron) the surrounding natural gas operations in the general area. Pickup and transport trucks will store or remove materials that will be used in daily operations or during drilling and completing wells in the area. The site will be monitored and inspected by personnel currently doing similar activities in the field and will not cause an increase of traffic on the public road system. The storage use is not expected to generate additional traffic on public roads and has the potential to reduce traffic by providing a place for extra materials and equipment that would otherwise be hauled in or out of the larger field. Oxy agrees to this condition 5. Prior to issuance of the Land Use Change Permit, the Applicant shall provide written confirmation that all pipelines serving the facility have been properly permitted or are exempt from permitting requirements. Oxy agrees to this condition. 6. Prior to issuance of the Land Use Change Permit, the Applicant shall provide copies of the well permits related to the three monitoring wells for the site. The number and location of any monitoring wells is a requirement established under the authority of the COGCC during the Form 28 review process. Oxy proposes the following substitute language for Condition 6 The Applicant shall provide copies of the well permits related to the monitoring wells for the site after the E & P Centralized Waste Facility (Form 28) has been approved by the COGCC. 7. Prior to issuance of the Land Use Change Permit, the Applicant shall provide copies of all current air quality permits from CDPHE. Any future or amended permits shall be provided to the County upon issuance by the CDPHE. • As noted in Exhibit N, the ponds qualify for a CDPHE Reg 3, II.D.1.uuu exemption and do not require an air quality permit. • As noted in Exhibit 0, the generator is exempt from CDPHE permit requirements. • The production tanks associated with the well pad are also exempt from APEN filing due to very low production rates. Oxy proposes the following substitute language for Condition 7. The Applicant shall provide copies of any air quality permits issued by the CDPHE when triggered by applicable State regulations. 8. Prior to issuance of the Land Use Change Permit, the Applicant shall provide a statement by a qualified professional or representative of the Applicant confirming the adequacy of the access road to serve the site. A waiver from Article VII, Roadway Standards is approved pursuant to the approval criteria contained in Section 4-118 of the Land Use and Development Code, subject to compliance with the above requirement. Oxy has confirmed the adequacy of the access road in the application (see Waiver Request Section 7-107 Access and Roadways). Additionally, the BOCC found on October 21, 2013 during the public hearing for Oxy's Pond G facility that the same access road was adequate. Oxy requests that condition 8 be removed. 9. Prior to issuance of the land Use Change Permit, the Applicant shall obtain the proper building permits for structures on the site, including any fencing that exceed 6' in height, and pay double the building permit fees for obtaining the permits post -construction. Oxy was not aware that wildlife fences and self-contained skid -mounted generators required a building permit but will comply with this condition. 10. Prior to issuance of the Land Use Change Permit, the Applicant shall provide specifications and details for the proposed liners and leak detection systems of the ponds for review and determination of sufficiency by Mountain Cross Engineering. Oxy will provide specifications and details of the proposed liners and leak detection systems of the ponds to the County when they become available but the determination of sufficiency is under the COGCC "s authority Oxy requests that condition 10 be amended to read as follows: The Applicant shall provide specifications and details for the proposed liners and leak detection system of the ponds as approved by the COGCC. 11. Prior to issuance of the Land Use Change Permit, the Applicant shall provide an Erosion Control Plan that includes all area within the 21.47 -acre site and the plan reviewed for sufficiency by Mountain Cross Engineering. Oxy agrees to this condition 12. Prior to issuance of the Land Use Change Permit, the Applicant shall provide a revision to site grading and drainage plan that clearly shows how the water will drain around the water impoundments and storage areas. This should include Best Management Practices to ensure positive drainage of the site. Oxy agrees to this condition. 13 Prior to issuance of the Land Use Change Permit, the Applicant shall provide a noise analysis that demonstrates the site is compliant with the COGCC Noise Standards/Regulations. The generator is used to supply power for pumps that a ove water through pipelines associated with the existing pond facility. As stated in Exhibit N, the nearest adjacent property boundary is approximately 1086 feet to the south. That parcel is owned by Oxy. The nearest adjacent property that Oxy does not have an interest in is approximately 3178 feet to the north. The generator located on the site is enclosed and is muffled. Oxy will perform a noise analysis that demonstrates the site is compliant with the COGCC Noise Standards. Oxv requests the follow changes to Condition 14: 14, Prior to issuance of the Land Use Change Permit. the Applicant shall comply with the following recommendations from the Colorado Department of Parks and Wildlife: A. Night Lighting should be of the full -cutoff type and/or timed or otherwise minimized to reduce disruption to wildlife but not compromise the safety of personnel who may be working at the facility. B. Bear -proof trash containers should be utilized at work -site locations and workers should be advised not to feed bears. C. Fencing should consist of a minimum 7 -foot high chain-link fence with a mesh type of fencing along the bottom (buried one -foot below grade level and extending a minimum of two -feet above grade) capable of preventing small animals from entering between the gaps (gaps should be no larger than three -inches). The mesh type fencing shall be installed when the liners are replaced and the leak detection system is installed. D. The pit shall be constructed with a 4:1 slope escape ramp and/or with chain-link fencing in one corner of the pit to allow entrapped wildlife to escape. E. from_ entering The pit should have sufficient CPW approved bird landing deterrent controls to ensure that waterfowl and other birds are prevented from entering. These deterrents may include RADAR triggering noise deterrents, floating covers or similar floating deterrents that prohibit landing, non -RADAR noise deterrents, and a combination of passive controls such as flagging with decoy predators or other sight deterrents. F. No oonstrustion earth moving activity shall occur during the time period from March 1 through June 30 to minimize impacts to sage -grouse production areas. Oxy requests that Condition 15 be removed for the following reasons: • As noted in the Biological Resource Analysis the site contains poor sage grouse habitat: • There is an abundance of natural perching opportunities in the immediate area as documented in the site photos contained in the Biological Resource Analysis. Anti - perching devices on fences and facility equipment would not have a significant impact on reducing the number of perching opportunities; • The need for anti -perching devices is not a recommendation of the Colorado Parks and Wildlife project review; • The policy regarding anti -perching devices originates in the Garfield County - Greater Sage Grouse Conservation Pian. Implementation is voluntary on private land according to this plan. Other 16. CPW shall be notified immediately if any birds and/or wildlife are found dead or trapped within or around the pit, netting, or fences. Oxy agrees to this condition. 17. The applicant shall conduct on-site weed inventory in the spring or early summer of 2014 and provide the information to the County Vegetation Manager by June 30, 2014. Oxy agrees to this condition O\OLSSON ASSOCIATES December 16, 2013 Daniel Padilla OXY USA WTP LP 760 Horizon Drive, Suite 101 Grand Junction, CO 81506 Subject Noise Analysis — Pond 13 Generator Building Garfield County, Colorado Dear Mr. Padilla, At the request of OXY USA WTP LP (Oxy) Olsson Associates (Olsson) has conducted a noise analysis of noise generating equipment installed at the Porid 13 Facility, specifically the generator building. The intent of this survey was to review the equipment specifications provided by the manufacturer (Attachment A), and determine if the equipment's operation would be in compliance with the noise limits set forth in the Colorado Oil and Gas Conservation Commission (COGCC) Rule 802 and Section 25-12-103 of the Colorado Revised Statutes (CRS). The COGCC and CRS limits are the same for general noise measurements. The noise generating equipment is a generator enclosed in a fabricated structure. The generator is rated to a sound pressure level of 81.78 dB(A) at 15 meters (42.9 feet). This sound pressure level includes sound generated from engine mechanics and exhaust and also accounts for building attenuation. Olsson has assessed the potential noise level at 350 feet using the noise/distance extrapolation equation provided in COGCC Rule 802 and this enclosure rating. The calculated sound pressure level at 350 feet from the station will be approximately 64.7 dB(A) (see Attachment B). Note that this distance is less than the distance from the compressor to the nearest property boundary. As prescribed in COGCC Rule 802, in remote locations, where there is no reasonably proximate occupied structure or designated outside activity area, the light industrial standard may be applicable. The most stringent light industrial noise level is for night time operation. This limit is 65 db(A). The calculated sound pressure levels at 350 feet from the equipment is below the applicable Colorado noise standards. 760 Horizon Drive, Suite 102 TEL 970.263.7800 Grand Junction, CO 81506 FAX 970.263.7456 www.clssonassociaies.com 013-0655 Noise Analysis - Oxy Pond 13 Generator Building 12/16/13 These sound pressure levels are calculated and actual noise levels should be measured during equipment operation to insure regulatory compliance. If you have any questions regarding this assessment, please contact me at 970-263-7800. Sincerely, Olsson Associates Ken Kreie Senior Scientist Enclosures — Attachment A - Table 1 Noise Attenuation Calculation Attachment B - Generator Building Noise Specifications Cc: Project File ATTACHMENT A Table 1 Distance Extrapolation Worksheet Site: OXY Pond 13 Generator Building Extrapolation to 350 ft. dBA1 = 81.8 dB (A) (Noise Attenuation Rating of Generator Building) 02= 350 ft. (C©GCC Compliance Distance) D, = 49.2 ft. (Distance of Noise Attenuation Rating of Enclosure) dBA2 = 64.7 dB (A) (Calculated dB (A) at 350 ft.) COGCC Rule 802(c) 1 - dB(A)}oislance 2 = dB(A)0islance 1 20 x log,a(Distance2/Distance, ) ATTACHMENT B G 34120 GAS ENGINE TECHNICAL DATA CATERPILLAH® ENGINE SPEED: 1800 COMPRESSION RATIO: 11.4:1 AFTERCOOLER - MAX, INLET (°F): 130 JACKET WATER - MAX. OUTLET (°F): 210 COOLING SYSTEM: JW+OC, AC IGNITION SYSTEM: EIS EXHAUST MANIFOLD: WC COMBUSTION: LOW EMISSION FUEL: NAT GAS FUEL SYSTEM: LPG IMPCO FUEL PRESS. RANGE (PSIG): 1.5 - 5.0 MIN. METHANE NUMBER: 80 ' RATED ALTITUDE (FT): 4922 AT AIR TO TURBO. TEMP. ('F): 77 NOx EMISSION LEVEL: 1.9 glbhp-hr FUEL LHV (BTU/SCF): 905 APPLICATION: 60 Hz GENSET LOAD 100% 75% +spa/a RATING AND EFFICIENCY NOTES ENGINE POWER (WITHOUT FAN) GENERATOR POWER (WITH MECH FAN) ENGINE EFFICIENCY (ISO 304611) ENGINE EFFICIENCY (NOMINAL) THERMAL EFFICIENCY (NOMINAL) 1TOTAL EFFICIENCY (NOMINAL) 11) (2) (3) (3) (4) (5) BHP EKW % °r'° °I° % 637 375 37.0 36.3 42.4 78.6 478 259 35.4 34.7 44.6 79.3 318 154 32.8 32.2 50.9 83.1 1 ENGINE DATA FUEL CONSUMPTION (ISO 304611) (6) BTU/bhp-hr 6887 7192 7753 FUEL CONSUMPTION (NOMINAL) (5) BTU/bhp-hr 7021 7332 1 7904 -AIR FLOW (77 °F, 14.7 psi) (7) SCFM 1354 1047 673 AIR FLOW (7) Ib/hr 6003 4641 2983.00 COMPRESSOR OUT PRESSURE in. HG (abs) 66.3 63.2 47.4 COMPRESSOR OUT TEMPERATURE °F 286 265 200 AFTERCOOLER AIR OUT TEMPERATURE °F 148 145 140 INLET MAN. PRESSURE (8) in. HG (abs) 59.5 52.9 47.8 INLET MAN. TEMPERATURE (MEASURED IN PLENUM) (9) °F i 148 145 140 TIMING (10) °BTDC 27 27 27 EXHAUST STACK TEMPERATURE (11) °F 700 700 727 EXHAUST GAS FLOW ('@ stack temp.) (12) CFM 3153 2440 1616 )EXHAUST MASS FLOW L12 Ib/hr 6229 4818 3110 �(13) EMISSIONS DATA NOx (as NO2) 1 gibhp-hr I 1.9 2 5.4 ICO (14) gfbhp-hr 1.93 1.96 2.05 THC (molecular weight of 15.84) (14) gfbhp-hr 5.35 5.87 5.05 NMHC (molecular weight of 15.84) (14) g/bhp-hr 0.8 0.88 0.76 02 (15) % DRY 8.7 8.5 6.9 )EXHAUST LAMBDA (15) 1.68 1.66 1.48 HEAT BALANCE DATA LHV INPUT (16) BTU/min 74538 58378 41956 HEAT REJECTION TO JACKET (JW) (17) (22) BTU/min 18937 16021 13908 HEAT REJECTION TO ATMOSPHERE (16) BTU/min 2962 2335 1678 HEAT REJECTION TO LUBE OIL (OC) (19) (22) BTU/min 2994 2533 2199 HEAT REJECTION TO EXHAUST (LHV to 77°F) (20) BTU/min 18962 14775 9862 HEAT REJECTION TO EXHAUST (LHV to 350°F) (20) BTUfmin 9647 7467 5236 HEAT REJECTION TO AJC (AC) (21)(23) BTU/min 3626 2436 790 CONDITIONS AND DEFINITIONS ENGINE RATING OBTAINED AND PRESENTED IN ACCORDANCE WITH 150 304611STD. REF. CONDITIONS OF 77°F, 29.6 IN HG BAROMETRIC PRESSURE, 500 FT ALTITUDE). NO OVERLOAD PERMITTED AT RATING SHOWN. CONSULT ALTITUDE CHARTS FOR APPLICATIONS ABOVE MAXIMUM RATED ALTITUDE AND/OR TEMPERATURE. EMISSION LEVELS ARE BASED ON THE ENGINE OPERATING AT STEADY STATE CONDITIONS AND ADJUSTED TO THE SPECIFIED NOx LEVEL AT 100% LOAD. EMISSION TOLERANCES SPECIFIED ARE DEPENDANT UPON FUEL QUALITY. METHANE NUMBER CANNOT VARY MORE THAN ± 3. PUBLISHED PART LOAD DATA MAY REQUIRE ENGINE ADJUSTMENT. ENGINE RATING IS WITH 2 ENGINE DRIVEN WATER PUMPS. FOR NOTES INFORMATION CONSULT PAGE THREE. 0M5444-02 PAGE 1 OF 3 03 -Mar -09 G3412C GAS ENGINE TECHNICAL. DATA CATERPILLAR' FUEL USAGE GUIDE CAT METHANE NUMBER IGNITION TIMING DERATION FACTOR 30 35 40 45 50 55 60 65 70 75 80 85-100 0.68 1.00 1.00 1.00 1.00 0.96 0.92 0.89 23 25 27 27 0 0 a a a 0 0 0 1.00 ; 1.00 1.00 1.00 ALTITUDE DEi'tA,TION FACTO 130 120 AIR 110 TO 100 TURBO 90 80 (°F) 70 60 50 1.00 1.00 1.00 0.98 0.94 0.91 0.87 0.84 0.81 0.77 0.74 0.71 0.68 1.00 1.00 1.00 1.00 0.96 0.92 0.89 0.85 0.82 0.79 0.76 0,73 0.70 1.00 1.00 1.00 1.00 0.98 0.94 0.90 0.87 0.83 0.80 0.77 0.74 0.71 1.00 1.00 _ 1.00 1.00 0.99 0.96 0.92 0.88 0.85 0.82 0,78 0.75 0.72 1.00 1.00 1.00 1.00 1.00 0.97 0.94 0.90 0.86 0.83 0.80 0.76 0.73 1.00 1.00 1.00 1.00 1.00 0.99 0.95 0.92 0.88 0.85 0.81 0.78 0.75 1.00 1.00 1.00 1.00 1.00 1.00 0.97 0.93 0.90 0.86 0.83 0.79 0.76 1.00 1.00 1.00 1.00 1.00 1.00 0.99 0.95 0.91 0.88 0.84 0.81 0.78 1.00 1.00 1.00 1.00 1.00 1.00 1.00 0.97 0.93 0.90 0.86 0.83 0.79 0 1000 2000 3000 4000 5000 6000 7000 8000 9000 10000 11000 12000 ALTITUDE FEET ABOVE SEA LEVEL) AFTERCOOLER HEAT REJECTION FACTORS (ACHRF) 130 120 AIR 110 TO 100 TURBO 90 80 ('F) 70 60 50 1.49 1.57 1.65 1.74 1.83 1.91 1,91 1.91 1.91 1.91 1.91 1.91 1.91 1.39 1.47 1.55 1.64 1.72 1.80 1.80 1.80 1.80 1.80 1.80 1.80 1.80 1.29 1.37 1.45 1.53 1.62 1.70 1.70 1.70 1.70 1.70 1.70 1.70 1.70 1.19 1.27 1.35 1.43 1.51 1.59 1.59 1.59 1.59 1.59 1.59 1.59 1.59 1.09 1.17 1.25 1,33 1.41 1.49 1.49 1.49 1.49 1.49 1.49 1.49 1.49 1.00 1.07 1.15 1.22 1.30 1.38 1.38 1.38 1.38 1.38 1.38 1.38 1.38 1.00 1,00 1.04 1.12 1 20 1.27 1.27 1.27 1.27 1.27 1.27 1.27 1.27 1.00 1.00 1.00 1.02 1.10 1.17 1.17 1.17 1.17 1.17 1.17 1.17 1.17 1.00 1.00 1.00 1.00 1.00 1.06 1.06 1.06 1.06 1.06 1.06 1.06 1.06 0 1000 2000 3000 4000 5000 6000 7000 8000 9000 10000 11000 12000 ALTITUDE )FEET ABOVE SEA LEVEL) FREE FIELD MECHANICAL & EXHAUST NOISE 100% Load Data dB(A) (dB) Free Field Mechanical DISTANCE FROM THE ENGINE (FEET) 3.2' 22.9 49.2 97.7 87.2 91.2 92.2 94.2 93.2 92.2 76,2 69.2 87.7 80.8 79.8 80.8 81.8 82.6 82.8 75.8 65.8 81.7 77.3 76,3 79.3 78.3 76.3 75.3 70.3 58.3 Free Field 1 Exhaust D44rPWCE FROM THE ENG1E (FEETM 4.9 22.9 49.2 113.0 102.5 112.5 113.2 112.5 105.5 103.2 101 9 92.1 99.7 93.2 102.8 97.8 97.5 92.2 91.2 91.2 83.3 93.0 86.6 96.2 91.2 90.9 85.6 84.6 84.6 76.6 Overall SPL 63 Hz 125 Hz 250 Hz 500 Hz 1 kHz 2 kHz 4 kHz 8 khz Octave @and Qente Freauencv (OBCF) FUEL USAGE GUIDE:. This table shows the derate factor required for a given fuer.. Note that derabon occurs asthe methane number decreases. Methane number is a scale to measure detonation characteristics of various fuels. The methane number of a fuel is determined by using the Caterpillar Methane Number Calculation program. ALTITUDE DERATION FACTORS: This table shows the deration required for values air inlet temperatures and altitudes. Use this information along with the fuel usage guide chart to help determine actual engine power for your site. ACTUAL ENGINE RATING: II is Important to note that the Altituderremperature deration and the Fuel Usage Guide derailed ire not cumulative. They we not to be added together. The same +.s true for the Low Energy Fuel deration (reference the Cale/War Methane Number Perinea) and the Fug Uepe Guide deratron However. the Al5tudeTemperatuse deralon and Low Energy Fuel derabon are curnula0 e: and they most be added together lel the method shown berth,/ To deteiie ne the actual power available, take the lowest rating between 1) and 2). 1) (AllnudefTemperature aeration). (Low Energy Fuel Deration) 2) 'Fuel Usage Guide Uerallon Note: For NA's always add the Low Energy Fuel deration to the Maude/Temperature devotion For TA engines only add the Low Energy Friel derabon to the Albtude7Temperature deration whenever the Atidude7Temperaeue deration is less than 1.0 1100%) This will give the actual rating for the engine al the corrdrtiero spear ed AFTERCOOLER HEAT REJECTION FACTORS IACHRF): Aflercooler heal rejection is given for standard conditions of 77'F and 500 ft altitude To maintain a constant air Inks manifold temperature, as the air to turbo temperature goes up, so must the heat rejection. As altitude Increases, the turbocharger must work. harder to overcome the lower atmospheric pressure. This rncreases the amount of heat that must be removed from the riled air by the akercaoier. Use the aftercooier heat rejection factor (ACHRF) to adjust for ambient and altitude conditions- M dI ply the tactor by the standard aflercoder heal rejection. Failure to properly account for these factors could revat m detonation and cause the ince* to shutdown or Mall. SOUND DATA: Data determined by methods similar la ISO Standard 01$-3524-10 Accuracy Grade 3. SPL = Sound Pressure Level DM5444-02 PAGE 20F 3 03 -Mar -09 G3412C GAS ENGINE TECHNICAL DATA CATERPILLAR® NOTES 1 ENGINE RATING IS WITH 2 ENGINE DRIVEN WATER PUMPS. TOLERANCE IS ± 3% OF FULL LOAD. 2 GENERATOR POWER DETERMINED WITH AN ASSUMED GENERATOR EFFICIENCY OF 93% AND POWER FACTOR OF 0.8 [GENERATOR POWER = ENGINE POWER x GENERATOR EFFICIENCY]. 3 ISO 3046/1 ENGINE EFFICIENCY TOLERANCE IS (+)0, (-)5% OF FULL LOAD % EFFICIENCY VALUE. NOMINAL ENGINE EFFICIENCY TOLERANCE IS ± 3% OF FULL LOAD % EFFICIENCY VALUE. 4 THERMAL EFFICIENCY: JACKET HEAT + LUBE OIL HEAT + EXH. HEAT TO 350°F. 5 TOTAL EFFICIENCY = ENGINE EFF. + THERMAL EFF. TOLERANCE IS ± 10% OF FULL LOAD DATA. 6 ISO 3046/1 FUEL CONSUMPTION TOLERANCE IS (+)5, (-)O% OF FULL LOAD DATA. NOMINAL FUEL CONSUMPTION TOLERANCE IS ± 3 % OF FULL LOAD DATA. 7 UNDRIED AIR. FLOW TOLERANCE IS ± 5 % 8 INLET MANIFOLD PRESSURE TOLERANCE IS ±5 % 9 INLET MANIFOLD TEMPERATURE TOLERANCE IS ± 9°F. 10 TIMING INDICATED IS FOR USE WITH THE MINIMUM FUEL METHANE NUMBER SPECIFIED. CONSULT THE APPROPRIATE FUEL USAGE GUIDE FOR TIMING AT OTHER METHANE NUMBERS. 11 EXHAUST STACK TEMPERATURE TOLERANCE IS (+)63°F, (-)54°F. 12 WET EXHAUST. FLOW TOLERANCE IS ± 6 % 13 NOX VALUES ARE SET POINTS AND WILL VARY WITH OPERATING CONDITIONS. 14 CO, CO2, THC, and NMHC VALUES ARE "NOT TO EXCEED". 15 02% TOLERANCE IS ± 0.5; LAMBDA TOLERANCE IS ± 0.05. LAMBDA AND 02 LEVEL ARE THE RESULT OF ADJUSTING THE ENGINE TO OPERATE AT THE SPECIFIED NOX LEVEL. 16 LHV INPUT TOLERANCE IS ± 3%. 17 HEAT REJECTION TO JACKET TOLERANCE IS ± 10 % OF FULL LOAD DATA, BASED ON TREATED WATER. 18 HEAT REJECTION TO ATMOSPHERE TOLERANCE IS ± 50% OF FULL LOAD DATA, BASED ON TREATED WATER. 19 HEAT REJECTION OF LUBE OIL TOLERANCE IS ± 20% OF FULL LOAD DATA, BASED ON TREATED WATER. 20 HEAT REJECTION TO EXHAUST TOLERANCE IS ± 10% OF FULL LOAD DATA. BASED ON TREATED WATER. 21 HEAT REJECTION TO A/C TOLERANCE I5 ± 5 % OF FULL LOAD DATA. BASED ON TREATED WATER. SITE SPECIFIC COOLING SYSTEM SIZING EQUATIONS (WITH TOLERANCES) 22 TOTAL JACKET CIRCUIT (JW+OC) = (JW x 1.1) + (OC x 1.2). 23 TOTAL AFTERCOOLER CIRCUIT (AC) = AC x ACHRF x 1.65. 0M5444.02 PAGE 3 OF 3 03 -Mar -09 SOUND ESTIMATE C-32 - 1000KW 85011 DISCHARGE 63 xZ 12.5_14Z 2.5.4 500 HZ 1000 HE 2000 H7 4000 HZ 11.000 AZ OVERALL ENGINE-MECH AT 1 METER 87.20 91.20 92.20 94.20 93.20 92.20 76.20 69.20 DB(A) 61.00 75.10 83.60 91.00 93.20 93.40 77.20 68.10 97.68 AT 7 METERS 80.80 79.80 80.80 81.80 82.80 82.80 75.80 65.80 DEW 54.60 63.70 72.20 78.60 82.80 84.00 76.80 64.70 87.67 AT 15 METERS 77.30 76.30 79.30 78.30 76.30 75.30 70.30 58.30 DB(AI 51.10 60.20 70.70 75.10 76.30 76.50 71.30 57.20 81.66 ENGINE-EXH AT 1 METER 102.50 112.50 113.20 112.50 105.50 103.20 101.90 82.30 DB(A) 76.30 96.40 104.60 109.30 105.50 104.40 102.90 81.20 113.03 AT 7 METERS 93.20 102.80 97.80 97,.50 92.20 91.20 91.20 83.30 DB(A) 67.00 86.70 89.20 94.30 92.20 92.40 92.20 82.20 99.65 AT 15 METERS 86.60 96.20 91.20 90.90 85.60 84.60 84.60 76.60 D8(A) 60.40 80.10 82,60 87.70 85.60 85.80 85.60 75.50 93.05 TOTAL ATTEN 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 AT 1 METER 61.00 75,.10 83.60 91.00 93.20 93.40 77.20 68.10 97.68 AT 7 METERS 54.60 63.70 72.20 78.60 82.80 84.00 76.80 64.70 87.67 AT 15 METERS 51.10 60.20 70.70 75.1D 76.30 76.50 71.30 57.20 81.66 SP-RCSI-2216-08 20.00 30.00 37.00 35.00 28.00 25.00 23.00 26.00 TOTAL ATTEN 20.00 30.00 37.00 35.00 28.00 25.00 23.00 26.00 AT 1 METER 56.30 66.40 67.60 74.30 77.50 79.40 79.90 55.20 84.45 AT 7 METERS 47.00 56.70 52.20 59.30 64.20 67.40 69.20 56.20 72.65 AT 15 METERS 40.40 50.10 45.60 52.70 57.60 60.80 62.60 49.50 66.04 2' STEEL WALL 17.00 20.00 22.00 32.00 42.00 50.00 57.00 58.00 MECH 1 M MECH 7 M MECH 15 M 44.00 55.10 61.60 59.00 51.20 43.40 20.20 10.10 64.38 37.60 43.70 50.20 46.60 40.80 34.00 19.80 6.70 52.88 34.10 40.20 48,70 43.10 34.30 26.50 14.30 (0.80) 50.44 TOTAL SOUND AT 1 METER 62.33 75.69 83.73 91.09 93.32 93.57 81.77 68.32 AT 7 METERS 55.37 64.53 72.27 78.65 82.86 84.09 77.50 65.27 AT 15 METERS 51.53 60.64 70.74 75.13 76.36 76.62 71.85 57.88 pgfAl TOTAL 1 MUTER 7 METERS 15 METERS 97.88 87.80 81.78 NOTE: THESE CALCULATIONS ARE BASED ON SOUND LEVEL DATA PROVIDED 8Y THE ENGINE! GENERATOR MANUFACTURER,AND SOUND ATTENUATION CHARACTERISTICS SUPPLIED BY THE EXHAUST SILENCER, PANEL WALL AND LOUVER MANUFACTURERS. ACTUAL SOUND LEVELS MAY VARY BASED ON INTERACTION OF COMPONENTS AND SITE CONDITIONS. From: Kathy A. Eastley To: "Jeff Hofman" Cc: Tamra Allen, Freo Jarman Subject: OXY Pond 13 Date: Tuesday, December 17, 2013 2:32:00 PM EXHIBIT Good afternoon Jeff, As you are aware, at yesterday's meeting the Board continued the Pond 13 pubic hearing to January 20, 2013. How would the Applicant like to proceed in discussing the outstanding issues and recommended conditions of approval? County staff is available to meet with you or to review any additional information submitted with regard to this application, however due to the holiday season my schedule is limited as I will be out of the office from December 23rd until January 6th. D have time available to meet this week or we could schedule time for early January. Any information to be submitted regarding this application would need to be received in time for staff to complete a review prior to issuance of the staff report (January 13th). One week minimum time period for review would be deemed sufficient thus January 6tl' would be the deadline for submittal of information to be incorporated into the staff review. I look forward to hearing from you at your earliest convenience. Thank you. Kathy Eastley, ALCP Senior Planner Garfield County Community L3evelopment 108 8th Street, #401 Glenwood Springs, CO 81601 Phone: 970-945-1377 ext. 1580 Fax: 970-384-3470 k astleyC!aarfieid county.com EXHIBIT S 4 From: To: Subject: Pond 13 follow-up Date: Thursday, December 19, 2013 8:03:12 AM Kathy, I just wanted to reiterate what we plan on providing as a follow-up to the Pond 13 application. This information will includes Traffic Analysis Addendum (COA 4) Written Confirmation that all pipelines either received permits or were exempt (COA 5) Apply for Building Permits for Fences and Generator (COA 9) Revised Erosion Control Plan (COA 11) Revised Site Grading and Drainage Plan (COA 12) Noise Analysis — Provided (COA 13) Additional documented dialogue with CPW regarding bird deterrents. (COA 14) Please let me know how many copies you will need to review (paper and CD) or if an electronic version is adequate. We will see you after you get back next year. Thanks Jeff Hofman, AICP Olsson Associates 760 Horizon Drive, Suite 1021 Grand Junction. CO 81506 1 jhofmanL olss, nassgclates corn TEL 970,263.78001 DIRECT 970.263.6016 1 FAX 970.263.7456 O\OLSSON , Era A 5 5 c c l A i( 5 From: Jeff Forman To: Katnv A. Eastlev Cc: Dadiliaia oxy.com; Mair Roil�ns Subject: Oxy Pond 13 UR Date: Monday, January 06, 2014 11:17:09 AM Attachments: Ftriµl.Lw Pond 13 Generator Noise Analysis oat Piolines.oQF Reclamat,Fpn Plan 11 26- limit EXHIBIT / Kathy, Welcome back. ! hope you had an enjoyable Christmas break. It is amazing how quickly time goes by away from work. Getting back to the Pond 13 LIR; attached is the Final Drainage Report, Generator Noise Analysis, confirmation that the pipelines serving this facility received the required permits, and a Reclamation. Plan that contain erosion control for the entire project area. A revised Traffic Analysis will follow. Additionally, Oxy is consulting with the CPW in regards to the bird deterrents issue. Additional information on this issue will also follow. Oxy has consulted with Andy Schwaller in regards to the building permits. Building permit applications are being prepared and will be submitted but the Building Division will not issue permits them until the LUCP is issued. We will also submit 6 hard copies of these reports as you requested. We would like to schedule a meeting with you either this week on Friday, January 10 or next week on Monday, January 13 or Tuesday, January 14 to further discuss the project. Please let us know which day and time works for you. Please contact me if you have any questions. Thanks Jeff Hofman, AICP 1 Olsson Associates 760 Horizon Drive, Suite 1021 Grand Junction, CO 81506 jhofman(@olssonassocjates con, TEL 970.263.7800 1 DIRECT 970,263.6016 1 FAX 970.263.7456 O\OLSSON.lr' A 5 5 O C A+ E S "" EXHIBIT v( FINAL DRAINAGE REPORT POND 13 E/W AND CASCADE CREEK 604-44 PAD STORAGE AREA GARFIELD COUNTY, COLORADO PREPARED FOR: OXY USA WTP LP 760 HORIZON DRIVE, SUITE 101 GRAND JUNCTION, CO 81506 PH: (970) 263-3637 CONTACT: DANIEL PADILLA PREPARED BY: OLSSON ASSOCIATES 760 HORIZON DRIVE, SUITE 102 GRAND JUNCTION, CO 81506 PH: (970) 263-7800 CONTACT: JEFF HOFMAN WYATT E. POPP, PE, LEED AP JANUARY 3, 2014 OLSSON ASSOCIATES PROJECT No.: 013-0655 O6' OLSSON ASSOCIATES DRAINAGE REPORT ENGINEER'S STATEMENT This report and plan for the final drainage design of the Pond 13 ENV and Cascade Creek 604- 44 Pad Storage Area was prepared by me, or under my direct supervision, in accordance with the provisions of the Col; ,: �t.••=�;... d Gas Conservation Commission (COGCC)and Garfield County Land Use Dew = v :'�. the owners thereof. /A .` Wyatt E. Popp, PE ; t] :• Registered Profess! 'engineer State of Colorado No < .« .4 + :51O�tpr. 173 1Y Da e Pond 13 ENV and Cascade Creek 604-44 Pad Storage Area Garfield County, CO 013-0655 DRAINAGE REPORT TABLE OF CONTENTS A. INTRODUCTION 1 1. Purpose of Report ........................................................ 1 2. Site Location 1 3, Site Description 1 4. Existing Drainage Facilities 1 5. Proposed Drainage Improvements 2 B. PROPOSED (DEVELOPED) DRAINAGE SYSTEM 2 1. Criteria 2 2. Sub -Basin Run-off Flows 2 3. Retention 3 C. ANALYSIS OF UPSTREAM AND DOWNSTREAM EFFECT 3 D. CONCLUSIONS 3 E. REFERENCES 3 APPENDIX A: RUNOFF CALCULATIONS APPENDIX B: RETENTION VOLUME CALCULATIONS APPENDIX C: IMPROVEMENTS PLAN Pond 13 ENV and Cascade Creek 604-44 Pad Storage Area Garfield County, CO 013-0655 DRAINAGE REPORT A. INTRODUCTION Purpose of Report This Final Drainage Report has been prepared for OXY USA WTP LP for Pond 13 E/W and Cascade Creek Pad 604-44 Storage Area site in order to improve the site's ability to alleviate the impact of storm water run-on/run-off, and bring the site into compliance with the COGCC rule stating, Surface water diversion structures, including. but not limited to berms and ditches, shall be constructed to accommodate a one hundred (100) year. Twenty-four (24) hour event. The facility shall be designed and constructed with a run-on control system to prevent flow onto the facility during peak discharge and a run-off control system to contain the water volume from a twenty-five (25) year, twenty-four (24) hour storm. The design of proposed structures and associated recommendations presented herein are intended to satisfy site-specific storm water regulations of the COGCC and Garfield County. 2. Site Location The OXY Pond 13 EN and Cascade Creek Pad 604-44 Storage Area project is located in the SE '/a of Section 4, Township 6 South, Range 97 West of the Sixth Principal Meridian, County of Garfield. State of Colorado. Refer to Figure 1 for project location. The project is located in mountainous terrain at the north end of Cascade Canyon. County Road 213 is approximately 12,000 ft south of the project. 3. Site Description The project consists of a 1.91 acre pad (approximately 220 ft x 380 ft), which was graded into the mountain side, with an access road along the east side of the pad. Associated with the pad are two multi -well lined production pits, Pond 13 east and west, 0.96 acres and 1.17 acres of surface area respectively, and a 1.12 acre storage area south of the ponds. The site was originally designed for natural gas drilling operations and currently houses two multi -well fined production pits with associated separators, condensate tanks and a concrete pad for heavy truck unloading. Steep mountainous terrain with slopes ranging from 10-50 percent surrounds the east and west sides of the graded pad. The pad, itself, has a gravel base and is relatively flat with a low -point near the southwest corner. The pad has been bermed on the western side as a containment measure. 4. Existing Drainage Facilities Fill slopes located at the southeast and southwest sides of the site are stabilized with vegetation to mitigate storm water run-off scour_ Since this site is located on a ridge, there no/minimal run-on flows. The existing ponds currently, and will continue to,, capture runoff Pond 13 ENV and Cascade Creek 604-44 Pad Storage Area Garfield County, CO 013-0655 1 DRAINAGE REPORT from the remainder of the site. The west pond (EX1) captures an area of 2.73 acres of which 0.96 acres is the pond surface. The east pond (EX2) captures an area of 2.00 acres of which 1.17 acres is the pond surface. These ponds are maintained and controlled by the operator, by monitoring freeboard and pumping when necessary. 5. Proposed Drainage Improvements Again, since this site is located on a ridge, there no/minimal run-on flows to address. So, this report will address the measures that could be employed to capture and retain the 25 -year, 24-hour on-site flows and reduce the existing run-off from the pad. The volume required to hold the 25 -year, 24-hour pad run-off, thus reducing and/or eliminating discharge to downstream basins during events up to the 25 -year storm, is 31,958 ft3 (refer to Appendix B for retention volume calculations). B. PROPOSED (DEVELOPED) DRAINAGE SYSTEM 1. Criteria Two sub -basins, EB1 and EB2, were used to model the pad during the 25 -year storm event. Refer to the Drainage Improvement Plan in Appendix D for basin delineation. Hydrologic Method The Rational Method was used to compute peak runoff flows and volumes. This method is defined as follows: t = CIA Where: 0 = Peak Discharge (cfs) C = Runoff Coefficient I = Rainfall Intensity (inlhr) A = Drainage Area (ac) Design Storm Frequencies (Rainfall Information) The 25 -year and 100 -year design storm frequencies were used for the design of storm water facilities for this project. Point rainfall data and rainfall intensity information were taken from the NOAA Atlas 14, Volume 8, Version 2. 2. Sub -Basin Run-off Flows Run-off from the pad during the 25 -year event was analyzed and the volume of the 25 -year, 24-hour storm was determined. All run-off from the pad (Basins EB1 and EB2) during the 25 -year storm could be captured and stored within the west lined pit, or a new pond could be constructed. Calculations for the 25 -year run-off rate can be found in Appendix A. Pond 13 EAI and. Cascade Creek 604-44 Pad Storage Area Garfield County, CO 013-0655 2 DRAINAGE REPORT 3. Retention The 25 -year, 24-hour volume of pad run-off could be captured within a newly constructed pond. Refer to Appendix B for retention facility sizing. C. ANALYSIS OF UPSTREAM AND DOWNSTREAM EFFECT The proposed drainage improvements consist of a retention pond to reduce run-off flows from the pad. Retention will eliminate 25 -year pad run-off to downstream basins. For storms greater than the 25 -year event, the pond will function as a water quality pond, allowing sediment in the pad run-off to separate before discharging to downstream basins. D. CONCLUSIONS Proper implementation of the proposed measures outlined in this report will alleviate the direct impacts of storm water run-off, and bring the site into compliance with current COGCC storm water regulations. The proposed improvements contained herein will not adversely impact adjacent basins, and will reduce the impact of run-off flow on downstream basins A registered licensed engineer in the state of Colorado should be consulted for the preparation of construction plans related to the recommendations outlined within this report_ E. REFERENCES 1) Mesa County Storm Drainage Criteria Manual 2) NCAA Atlas No, 14, Volume 8, Version 2 Pond 13 ENV and Cascade Creek 604-44 Pad Storage Area Garfield County, CO 013-0655 3 DRAINAGE REPORT APPENDIX A: RUNOFF CALCULATIONS Pond 13 E/W and Cascade Creek 604-44 Pad Storage Area Garfield County, CO 013-0655 4 COMPOSITE 'C' FACTORS (DEVELOPED) - - 1 T g W ; 2 ■ 8 ■ 8 e E e , K § a g § ! | . ■ } \ © 1 ƒ i `R ! z ! f § 5 _ I ■ 3 - -re k m } ¥ CD ƒ K % ; . » a !, W , . 3. .7. ! f;, ( \ . K t / . 4 & , §R..� 1 t f / ! ). ` & f ® . � ` 1 § . , � ! \ » "J : 4 2 f2 p COMA RES M'lT { GRAY [ ROOFS k LAWNS 1 7f § ; i - E § - 1 k REMARKS FORMULAS • TI = 1.8 (1.1-C5)LA0.5/S^113 V=10^(.S Iog(S/100)+k § ce FORMULAS: "TI a 1.8 (1.1-05)L^0.515"li3 V=1041.5 bg(51100)M1 1 TIME OF CONCENTRATION (DEVELOPED) LOCATION: Oxy 604-44 Pad Drainage Study _ BY: Kris PickettDATE: 113/2014 I FINAL Tc i TIME OF CONCENTRATION (EXISTING) LOCATION: Oxy 604-44 Pad Drainage Study BY: Kris PIckett DATE: 11312014 ) tL Tc Check (Urbanized Basins)_ ; ,2 v k Te Chgck (Urbanized Basins) e \ ° k i § § $ k/ ) / kk 2 % § 3 . b 2 g , § 0 iil - > § ƒ # • f § § k > \ ^ [ § |§ § ) || \ \ INT /OVERLAND TIME (TI) \ 2 § u k k E@ § ri !§ ) § § | R _ k _ ( f e e ( s k § k ( § P.' SUB -BASIN DATA ( § § S f 10 0 10 0 | 0 § § | $ S 4 1 2B STORM DRAINAGE SYSTEM (RATIONAL METHOD DESIGN STORM: 25 -YEAR Oxy 604-44 Pad DESIGN PROCEDURE) DEVELOPED Calc_ by Kris Pickett Chk'd by: WEP Date: 1/3/2014 DESIGN POINT DIRECT RUNOFF - REMARKS - Q coU AREA (AC) COEFF. (C) Tc (Man.) ¢ V 1 1 1.26 0.42 10.6 0.529 3 4 1.80 2 2 2.78 0.42 10.6 1.168 3.4 3.98 3 0 0.00 0.00 0.0 0.000 4 0 0.00 0.00 0.0 0.000 a 5 0 0.00 0 00 0.0 0.000 TOTAL 5.8 Olsson Associates 1/3/2014 Oxy 604-44 Pond 13 E/W Pad Storage Area Oxy604-44 charts STORM DRAINAGE SYSTEM DESIGN (RATIONAL METHOD PROCEDURE) DESIGN STORM: 100 -YEAR DEVELOPED Oxy 604-44 Pad Calc. by: Kris Pickett Chk'd by: DLA Date: 1/3/2014 DESIGN POINT DIRECT RUNOFF s REMARKS z al AREA (AC) COEFF. (C) C o < L C _ ► t 0 1 1 1 1.26 0.50 10.6 0.63 4.6 2.9 Full `low to detention pond 2 2 2.78 0.50 10.6 1.39 4.6 6.4 Full flow to detention pond 3 0 0.00 0.00 0.0 0.00 4 0 0.00 0.00 0.0 0.00 5 0 0.00 0.00 0.0 0.00 TOTAL 9.3 Olsson Associates 1/3/2014 Oxy 604-44 Pond 13 E/W Pad Storage Area Oxy604-44 charts DRAINAGE REPORT APPENDIX B: RETENTION VOLUME CALCULATIONS Pond 13 EJ N and Cascade Creek 604-44 Pad Storage Area Garfield County, CO 013-0655 5 DEVELOPED RUN-OFF RETENTION VOLUME NEED TO RETAIN DEVELOPED FLOW VOLUME FROM A 2SYR-24HR EVENT RAINFALL AMOUNT, Pr=2.19 inches (from NOAA Atlas 14, Volume 8, Version2) PAD AREA, A= 4.02 acres Volume, V= (2.19in)(4.O2ac) = 8.80 ac -in 0.73 ac -ft 31,958 cubic feet (REQUIRED POND VOLUME) Olsson Associates 1/3/2014 Oxy 604-44 Pond 13 E/W Pad Storage Area Oxy604 44 charts EXISTING BASIN RETENTION VOLUME TO RETAIN FLOW VOLUME FROM A 25YR-24HR EVENT RAINFALL AMOUNT, P=2.19 inches (from NOAA Atlas 14, Volume 8, Version2) Basin EX1 = 2.73 acres Volume, V= (2.19in)(2.73ac) = 5.98 ac -in = 0.50 ac -ft 21,703 cubic feet (REQUIRED VOLUME) Basin EX2 = 2.00 acres Volume, V= (2.19in)(2.00ac) = 4.38 ac -in = 0.37 ac -ft = 15,899 cubic feet (REQUIRED VOLUME), Olsson Associates 1/3/2014 Oxy 644-44 Pond 13 E/W Pad Storage Area Oxy 644-44 charts DRAINAGE REPORT APPENDIX C: IMPROVEMENTS PLAN Pond 13 EJW and Cascade Creek 60444 Pad Storage Area Garfield County, CO 013-0655 6 ,Lg PR. 11111FIDOSIV NOSS1O\O I Ili 1 ,i, ii 141 10101 Jail! 11011hh1e P.041.13)4. 'riDe OfTeldOlGQ 'A1Nnoo Olio dl dI.M %Mel &SO Vab'S 30Y)O$QprYCI CIMOd PlYld .003NRACIkidril 3treNiVbill 11-9,111 11 ' II. I Z [-,1 NNN 1 s'S-\\,\\Z>.‘;''', •ss''-\\''::'', \ NN , N.' ''''\,\N:\''\':\ ,''' \m‘ '''''':, \ ' •• '-'''kY 'kkk N,,,•-••;',,,,1\\•••\;\ N‘C.,N,'\ ''\,:\\\ ,.‘ \\,\ Kt-_ :;•,•_-,__.- _ %:.-'• ''.1"Ws:•\:.'''''•,-.1:0,„.‘,.\\'..\`A.,,A,\''',\As\\N l'14‘1" \ \ .':- ---- \ BO 5 ?! ! ! 1 • ‘NV • , \N\ • • N \\\\ • '114:-.-44V:404• lt 1' r- 11 - - • - 1° in'r 11*''1' IA. ''1';V.,:•1 .-:'. ',. •••",v1.,,,, ‘‘, ,.t),, 1,‘ 1,, \ t, 'I',,,,, \ .i. ,1/4.„, ,. . !-'\\,'''';'). '''''''V';(:\t')* '''\;Cir'l j•' (:'.....--'-i, -7•—..?:,_.(7-77-:-• 0.'1,,4\,•':,\ *10 \U'\ " l'\ 111 q4\\ ''''',.'\ ...: \.\\''''''', 1:'';: /I'll; '1''')..IC';1'''''\\\)'''',‘'i'''cl''::1.,,i'l,,',i ; '11!':((i, PcCS 'LL.4.,1'''-k:.•kl" a_a ...op. 1.0 ..1-wasro n ti O'sk.OLSSON ASSOCIATES OXY USA WTP LP POND 13 E & P CENTRALIZED WASTE MANAGEMENT FACILITY PIPELINES EXHIBIT I 1' The Oxy Pond 13 facility is served by water pipelines. Oxy confirms that these pipelines have been properly permitted through Garfield County. These pipeline permits include: • Grad -9-10-1756 • Grad -9-11-2230 • Grad -7-11-2101 760 Horizon Drive, Suite 102 TEL 970.263.7800 Grand Junction, CO 81506 FAX 970.263.7456 www.olssonassociates.com OXY USA WTP LP Pond 13 E&P Waste Management Facility THIS PAGE LEFT BLANK FOR TWO-SIDED DUPLICATION. Pipelines Page 2 1 RECLAMATION AND EROSION CONTROL PLAN POND 13 GARFIELD COUNTY, COLORADO PREPARED FOR: OXY USA WTP LP 760 HORIZON DRIVE, SUITE 101 GRAND JUNCTION, CO 81505 PH: (970) 263-3668 CONTACT: DANIEL PADILLA PREPARED By: OLSSON ASSOCIATES CONTACT: WYATT E. POPP, PE AUGUST 13, 2013 REVISED: NOVEMBER 26, 2013 OLSSON ASSOCIATES PROJECT No. 013-0655 �OLSSON ASSOCIATES 760 Horizon Drive, Suite 102 !Grand Junrtlon, CO 015061970.263.70001 Fax 970.263.7456 EXHIBIT 1 V5 THIS PAGE LEFT BLANK FOR TWO-SIDED DUPLICATION. TABLE OF CONTENTS 1. RECLAMATION PLAN a. Top Soil Management b. Seeding Procedures and Schedules c. Disturbance Area d. Cost Estimate 2. DRAINAGE AND EROSION CONTROL PLAN a. Drainage b. Erosion Control Measures LIST OF ATTACHMENTS Attachment A Top Soil Salvage Attachment 8 Regional Drainage Analysis Attachment C Proposed Erosion Control Figure Attachment D Weed Management Plan Attachment E Cascade Creek Stormwater Permit COR -035414 THIS PAGE LEFT BLANK FOR TWO-SIDED DUPLICATION. Reclamation Plan Oxy has developed a water impoundment, Pond 13, and storage area. Upon closure of the site, revegetation activities are anticipated to take no longer than forty (40) days weather permitting. Upon closure of the site, the disturbed area will be re-contoured at slopes no greater than 2:1 to catch the existing terrain. Topsoil will be replaced on the disturbed areas. The entire disturbed area will be reseeded with the following seed mixture: Mixed Mountain Shrubtand, Including Oakbrush Common Name Scientific Names Form PLS lbsiacre* Thickspike Wheatgrass Elymus lanceolatus ssp. lanceolatus, Agropyron dasystachyum Sod- forming 3.4 Bluebunch Wheatgrass Pseudoroegneria spicata, Agropyron spicatum Bunch 3.7 Bottlebrush Squirreltail Elymus elymoides, Sitanion hystrix Bunch 2.7 Slender Wheatgrass Elymus trachycaulus, Agropyron trachycaulum Bunch 3.3 Canby Bluegrass Poa canbyi. P. secunda Bunch 0.6 Mutton Bluegrass Poa fendleriana Bunch 0.6 Letterman Needlegrass Achnatherum [Stipa] lettermanii Bunch 1.7 Columbia Needlegrass Achnatherum [Stipa] nelson'''. Stipa Columbiana Bunch 1.7 Indian Ricegrass Achnatherum [Oryzopsis] hymenoldes Bunch 1.9 Junegrass Koeleria macrarrtha, K. cristata Bunch 0.1 "Based on 60 pure live seeds (PLS) per square foot, drill -seeded. Double this rate (120 PLS per square foot) if broadcast or hydroseeded. Top Soil Management Topsoil has been reutilized during the initial construction of the site for initial reclamation. During closure of the site the topsoil will be re -stockpiled so that it will not interfere with closure activities. Should the reclamation activities during the closure phase exceed forty (40) days, appropriate measures will be taken to protect all topsoil stockpiles (covering, seeding, windbreaks, etc.), Following final contouring, all disturbed areas will be covered evenly with the stockpiled topsoil. The topsoil will be heavily pocked using the excavator bucket to form an uneven soil surface complex which will aid in revegetation. Soil amendments or import of new topsoil is not anticipated. Review of the vegetation establishment will be required to determine whether soil amendments are required at a later date. (Attachment A). Seedinq Procedures and Schedules As recommended grass mixture reseeding will be done in late autumn in order to take advantage of natural precipitation for the region. The reseeding rate should be doubled for broadcast application. Oxy's contractor will utilize a no -till -drill without any soil preparation other than simple grading to slope and waterbars, where applicable. It is anticipated that the disturbed areas will be returned to match the original vegetative state. Seeding will be conducted by means of drilling the prescribed seed mix according to the recommended rate. The seed will be drilled with a common range drill at a depth of 0.25 — 0.5 inch beneath the soil surface. The reseeding will be monitored and reseeded as appropriate until the reclamation standards are acceptable to Garfield County Vegetation Management. The reclaimed site will be monitored for stormwater and noxious weeds. Disturbance area The project has an anticipated total disturbance of approximately 5.16 acre. (224,770 square feet). Encineer's Opinion of Probable Cost Below is a table that outlines the estimated costs associated with the revegetation of the project. during final closure. There are no costs associated with the initial reclamation. The estimate is an opinion of probable cost and may vary based upon site conditions encountered or market conditions related to the unit cost. OLSSON ASSOCIATES Olsson Associates 760 Horizon Drive, Suite 102 Grand Junction, CO 81506 REVEGETATION COST SUMMARY PROJECT: Pond 13 LOCATION: Garfield County. CO DATE: 11(26(13 Item Description (Source of Cost) Garfield County Vegetation Management Total Acres Estimated Total Cost (costs have been provided by Garfield County Vegetation Management) Cost/ Acre $2,500 5.2 513,000 2 Drainage and Erosion Control Plan The primary disturbance anticipated with the closure Pond 13 is re -grading. Topsoil will be stockpiled so that it will not interfere with closure activities, Should the construction activities during the closure phase exceed forty (40) days, appropriate measures will be taken to protect all topsoil stockpiles (covering, seeding, windbreaks, etc.). The final reclamation plans prepared by D.R. Griffin and Associates, Inc illustrate the proposed final grades. Drainage Nolte Associates prepared the Regional Drainage Analysis. The improvements associated with this project are located within the CA04 and OS18 drainage basins as described within the Regional Drainage Analysis. This project is not anticipated to significantly alter the drainage patterns or flow rates described within the Regional Drainage Analysis. Additional analysis may be warranted due to the nature of construction activity associated with this project. However, it is expected that existing drainage measures will be maintained. Deviation from the Regional Drainage Analysis is not expected, however, if site conditions dictate a deviation then a Colorado Registered Professional Engineer shall be consulted. The Regional Drainage Analysis prepared by Nolte Associates demonstrating drainage patterns for the project area is included as Attachment B. Erosion Control Measures Olsson Associates prepared a Stormwater Management Plan (SWMP) for Cascade Creek Development. It is anticipated that the project will be in conformance with Oxy's SWMP (permit no. COR038414). The Stormwater Management Plan will be revised accordingly. An exhibit demonstrating approximate locations of anticipated erosion control measures is included as Attachment C. Closure will be completed as described in the Reclamation Plan and SWMP. The recommendations associated with the Reclamation Plan and review of the Drainage and Erosion Control Plan were prepared on behalf of Olsson Associates under the supervision of: Wyatt E. Popp, PE Olsson Associates THIS PAGE LEFT BLANK FOR TWO-SIDED DUPLICATION. Attachment A Top Soil Salvage THIS PAGE LEFT BLANK FOR TWO-SIDED DUPLICATION. R.O.W. BDY. TRENCH R.O.W. BDY. 15'± WORKING LANE 1.5'± PASSING LANA �-- TOPSOIL CLEARING WIDTH 20'± SPOIL SIDE 30'± W+RKIN: Ir, 50' CONSTRUCTION ROW - NOT TO SCALE - NOTES: 1. SALVAGE TOPSOIL (BULLDOZER BLADE WIDTH) OVER TRENCH AT LOCATION AND DEPTHS IDENTIFIED ON THE CONSTRUCTION DRAWINGS OR AS DIRECTED BY THE COMPANY, STRIP SHALL BE WIDE ENOUGH TO ACCOMMODATE TRACKED BACKHOLE OR WHEELED DITCHER. 2. STOCKPILE TOPSOIL AS SHOWN OR IN ANY CONFIGURATION APPROVED BY THE COMPANY. KEEP TOPSOIL CLEAN OF ALL CONSTRUCTION DEBRIS, MAINTAIN A MINIMUM 1' SEPARATION BETWEEN TOPSOIL AND SUBSOIL PILE EDGES. 3. LEAVE GAPS IN TOPSOIL PILES AT OBVIOUS DRAINAGES. DO NOT PUSH TOPSOIL INTO CREEKS OR WETLANDS, DO NOT USE TOPSOIL FOR PADDING. 4. AVOID SCALPING VEGETATED GROUND SURFACE WHEN PLACING BACKFILL FROM THE SPOIL PILE. TYPICAL R.U.W. SECTION BLADE WIDTH TOPSOIL SALVAGE dir•Eg RIFFIN & ASSOCIATES, INC. REVISIONS NO. DATE DESCRIPTION DRF CHK APR 1414 ELK ST., SUITE 202 ROCK SPRINGS, WY82901 (307) 362-5028 SCALE: NONE C&E No.: 9145 DATE: THIS PAGE LEFT BLANK FOR TWO-SIDED DUPLICATION. SLOPE SURFACE CROSS SECTION N.T.S. SPACING DEPENDS ON SLOPE: SEE NOTES #4 AND 05 BELOW r � f If / if /// N/ if I f`/ ///f/'/ / 1 ` / u N DETAH_ 2 N.T.S. NOTES: 1. EROSION CONTROL/SEDIMENT ("WATTLE") LOGS SHALL BE INSTALLED ON SLOPES AS SHOWN ON THE ALIGNMENT SHEETS, DESIGNATED IN THE PROJECT STORM WATER MANAGEMENT PLAN (SWMP) OR AS DIRECTED BY THE ENVIRONMENTAL INSPECTOR. 2. EROSION CONTROL/SEDIMENT LOGS SHALL BE MADE OF SHREDDED ASPEN, STRAW, OR SIMILAR VEGETATIVE MATERIAL FREE OF THISTLE AND OTHER NOXIOUS WEEDS AND WRAPPED IN TUBULAR BLACK PLASTIC NETTING OR OTHER APPROVED ENCLOSURE. THE NETTING SHALL HAVE A STRAND THICKNESS OF ABOUT 0.03", A KNOT THiGKNESS OF ABOUT 0.055", AND WEIGHT OF ABOUT 0.35 OZ/FT. THE NETTING SHALL BE MADE OF 857 HIGH-DENSITY POLYETHYLENE, 14% ETHYL VINYL ACETATE, AND 1% COLOR FOR UV INHIBITION OR OTHER APPROVED COMPOSITION. 3. COMMERCIAL PRODUCTS THAT SATISFY THESE REQUIREMENTS INCLUDE AMERICAN EXCELSIOR LOGS, STRAW LOGS BY GREENFIX AMERICA OR STRAW WATTLES BY CALIFORNIA STRAW WORKS. 4. WHERE DESIGINATED FOR INSTALLATION ON THE ALIGNMENT SHEETS, IN THE SWMP OR REQUESTED BY THE ENVIRONMENTAL INSPECTOR, EROSION CONTROL/SEDIMENT LOGS SHALL BE INSTALLED AT THE FOLLOWING SPACINGS: PRIVATE & STATE LANDS FEDERAL LANDS ABUTT ADJACENT LOGS TIGHTLY SLOPE SURFACE EROSION/SEDIMENT CONTROL LOG ("WATTLE") 8" TO 12" DIAMETER (D) 10' TO 20' LONG 2" MIN TO 1/3 0 BELOW GRADE 1" X 2" X 2' TO 3' WOOD STAKE OR NO. 4 REINFORCING STEEL 2' TO 3' LONG DETAIL 1 N. T.5. SLOPE (%) SPACING (FT) < 5% NONE 5-15 300' 15-30 200' >30% 100' SLOPE (%) SPACING (FT) D-2 400' 2-5 300' 5-13 200' 10-20 100' 20+ 50' 5. SPACING REQUIREMENTS STATED IN THE BLM R.O.W. GRANT STIPULATIONS AND LANDOWNER AGREEMENTS, IF ANY, SHALL SUPERCEDE THE ABOVE. TYPICAL EROSION CONTROL / SEDIMENT ("WATTLE" LOGS RIFFIN & ASSOCIATES, INC, REVISIONS NO. DATE DESCRIPTION DRF CHK APR 1414 ELI( ST., SUITE202 ROCK SPRINGS, WY 82901 (307) 362-5028 SCALE: NONE C&E No.: 9167 DATE: THIS PAGE LEFT BLANK FOR TWO-SIDED DUPLICATION. a 5 61 VI 0 gli -,se in 5 LF WI LIOR Fs au�l WA�1 %al 4 m SgiffE- Pi Y21g ski o'g`d u 5 i`g 46 004 g ag 544� xfPg Poi Da cc W i— a 1 a O <4 i" PI; u mya�" m W f}FT* 'ZX m 3g r a 2 :4; ws ga_W=o m: o 46 WI tJ as 1!X/rNx a :sN 2 d yyW } ® T Z N O m 42 OV( b I[5 ,1.,6 it1544 V4 i Z Wo m. y 4 5r t 1w'mOG(4S Dg_N S a 2OA -mV 6y 1ltt �j 1[ a 4.5 i uy #I P i. a< N 6 '!'ii O p y Nlil Z 4W W, p ~ t L�1W�� W��� 2 P. K e A Ott.zoM W� W E 15 i a!, - h -4 yyv:C o' blo Q. c � Oet `g g0I� 2 �th""i O_W Y N0 RM'�. Ox SS�t� �C1 g <i WQ 4-. NW M w C i`a �5 �W S 6A. y _W ii g pS.gN w3 g8;; ; flat a� $ Nm ¢. o'er Waa 6,,P, zpo th w VM [� 6 0 i C qj a lh 4 M i1 re z .f C1 All Z aNnvitnrmus A 1:5 L_1(1' 4 V` O 2 4 N W 4 Fq� wP 3 1 fl 1 t gR m ix g i g} m da a mg N is g aw d� F 9 0 TILE, SUCH A5 MIRAFI 100X Yf, 4 ES OF SUFFICIENT LENGTH TO MEND A MINIMUM OF 1Y INTO 1HE r L aF 4 w W WG 1 ¢ hbl i9 tY X 4 m U Ci s Z at F 3. THE SILT FENCE SHALL BE INSTALLED AS SPECIFIED BY THE MANUFACTJREA OR AS FOLLOWS: TRENCH NG A 4- GROUND FLAP WITH ROCK FILL TO H Attachment B Regional Drainage Analysis THIS PAGE LEFT BLANK FOR TWO-SIDED DUPLICATION. • f FORERU MR[R NO LTE OCCIDENTAL OIL AND GAS CORPORATION REGIONAL DRAINAGE ANALYSIS WATERS ED EXHIBIT V w. v IM1NNm Pe. .D.l'xvi.cn 1.1e794..0o111 Dark wrtr® Attachment C Proposed Erosion Control Figure THIS PAGE LEFT BLANK FOR TWO-SIDED DUPLICATION. SliVIDOISV /411410111 itoortiti mw| 00.11010D Aurano3�� w��wn*v Prekl 1041403 140,140b3 --` ` in Mee \, ` ^``\ \ � `` ` . � ` ` ` ` ' ` ` ` � ` ` � ' ` � ` �`` `` ^ `` `~ .`` . . . ` • . c`^ � . ` � .� ,` ` .- .``~^ . ` � .� • • ` \r� � ` ` , �`. � , ` � `-^ ~----- ---' . *�� ` � ~ _- __ `^x ` —` � / ` ` ` ` ^ ` ` --. -- �x"x^ .-___- `- .. - °'^` � ``� ` , '^ ,` \ ` S. , _ �~~- `� (��� ` _ \ '_ ^���'^��, ` ` -- --.—... ____ _ `.` ~ ` v`^ �� ` ` ~~� ` ��^ �^ ` ` ' `` \'`��` ' ` J' • -- --' ` `` ` ` ~ -_--� ~ ` ` ` L. ~^ _ `.»` .`` ` � \ ------.- ' ` ` �'` ` ` x ` `x ` \`��`\��` ^ `. ..----- -- '- . \ . � \ ~'��`�`` � ` \Y� ' ` ` ` _- ` ` � ` . ` . . ` � � `, \'i �`'r �|[ -./^ ``^ ~`` `1 ` V. � \```` y, ` // / "1 \ ` / 1 1 `\ : ' /`~~~ /� / ` `` `r- / / � � � \ / ~. `~.~` �~ . /'/ � ~^// / ' '/.` e ��� .` -/ . 1 1 I ` ' / � / � ��� iT ~ ' / / X�,i El `��� / /,''— ' --^ -~ ~.'-' i if' ,!! ,''/ m:' ' _,--- .... ,.''' // ��>� 1 ~/ - ' - ^ ~. '� � - ~ ^ � ..---- ._ - .~-�~ --- ~' �� vn /° ~° _--- - - ^ ' - ' , . ` ~. . - ' - - ~ ~ ' '4 1`�r�`- '-• -`, `- '-- - --� .- - -- -_- - __ --- ---- -�-__------ -�--_ ---'-_------ '-_--------------- - ' / ' ' �' -.-----------.- , ' ~ .- - ° '� '� ~ / / .' '' ' '— — _--- . . _--_� � - � / � ' ' / / ` > '- -- .---- � - ---- / 1 ' ' ' ` '_ -_- _- t 1 YA. '.'. i� / / / ` . / / '- � ---' -~-�~---�-- �/ `` . ` ' . - ' -- ----- -- .^` ' \� / ''. / � � ` ! / ` '-'---�—_---- __— __ .... . . 4 - /� 1 ` `` ` / �``' ,� ` 1 `.1 I. ` '�_- --'----`-- - ./. ' , ._ ..�1 ` `Y� 1 1 "1 1 ', / . �/ � ._--`—�—/ . ' ` , ` ``�`�\�`� �� � � � � ` `�� '�,,—�- ^ ^ V `'. , ,` ```/r--� 1 `�. \ \� ` �� 'i ` . ` Y 1 ` 1 1 �' ' -�'' / i'y r ' , . ) \ / / 1 , Y , 1 \ ' / .~ 4 I � . 4 / 1 1 \ -'o .1 ', ‘, ^ ` ., ___~__ Attachment D Weed Management Plan THIS PAGE LEFT BLANK FOR TWO-SIDED DUPLICATION. OXY OXY USA WTP LP and OXY USA INC. Subs+c ares of Occorental Petroleum Corporation Noxious Weed Management Plan August 2010 THIS PAGE LEFT BLANK FOR TWO-SIDED DUPLICATION. Table of Contents 1. Background 3 2. Compliance Statements 3 3. Contacts 3 4. Locations 4 5. Land Use Objectives 4 6. Weed Management Objectives and Implementation Strategies 4 6.1 Inventory and Monitoring 4 6.2 Prevention 5 6.2.1 Construction Prevention Measures 5 6.2,2 Revcgetation 5 6.3 Control and Management 6 7. References 9 8. Local, State and Federal Contacts and Resources 10 THIS PAGE LEFT BLANK FOR TWO-SIDED DUPLICATION. Noxious WEED MANAGEMENT PLAN OXY USA WTP LP and OXY USA INC Mesa and Garfield County Operations 1. Background The Colorado Noxious Weed Act (C.R.S. Title 35. Article 5.5) requires that "noxious weeds" be managed on private and public lands. The Act further declares that control of noxious weeds should use methods that are least damaging to the environment but also practicable and economically reasonable. The state requires management of noxious weeds included on one of three lists (see Appendix A): List A — designated for statewide eradication; List B managed to prevent further spread and, for selected species, designated for eradication in large areas, and List C — of more localized concern, but for which the State will provide education, research, and biological control assistance to jurisdictions that choose to manage the species. OXY USA WTP LP and OXY USA Inc. (individually and collectively referred to herein as "Oxy"), are affiliated companies that separately own and operate certain mineral properties in the State of Colorado. This plan is intended for all Oxy operations in order to comply with all state and federal requirements including the Colorado Noxious Weed Act, Colorado Oil and Gas Conservation Act, Bureau of Land Management (BLM) and Forest Service (FS) National Invasive Weed Strategies. Mesa County and Garfield County weed standards. 2. Compliance Statements Oxy will manage all noxious weeds, as defined by the Mesa County. Garfield County or State Law (CRS 35-5.5), in all newly disturbed project areas using recommendations identified in this plan or those provided by biological consultant at the time of project specific inventories. The term, "disturbed area" includes all access roads, easements, pipelines, special purpose pits, berms, soil stockpiles, well pads, electrical and compressor stations and other structures. and other areas disturbed by project activities. Oxy will immediately report all State List A and List B populations to be eradicated and any other species slated by Mesa and Garfield Counties for eradication upon discovery to the appropriate County designee. 3. Contacts Regulatory Lead. Sean Norris OXY USA WTP LP 760 Horizon Drive, Suite 101 Grand Junction, CO 81506 (970) 263-3628 Regulatory Advisor: Daniel Padilla OXY USA WTP LP 760 Horizon Drive, Suite 101 Grand Junction, Colorado 81506 Phone: (970) 263-3637 4. Locations Oxy has active and inactive leases for gas exploration in the following areas of Mesa and Garfield Counties: • Cascade Creek (Garfield County, Colorado) • Collbran Area (Mesa County, Colorado) Oxy operates on split estate. wholly federal (both BLM and USFS), and wholly private land and lease holdings. 5. Land Use Objectives Oxy conducts natural gas exploration on lease holdings in Colorado. Land uses and types of facilities to be developed include access roads, pipelines, well pads, compressor stations, stagingr'storage areas for equipment and supplies, and other associated natural gas development activities. Some of the developments are short- term temporary disturbances. such as staging areas and pipelines, while the roads and well pads will be in place for an estimated 20-30 years. 6. Weed Management Objectives and Implementation Strategies The following are the overall objectives of Oxy's weed management plan. Specific actions to be taken to meet these objectives are detailed in Section 6. 1) Inventory and monitor existing noxious weed infestations using GPS or other mapping techniques and consistent field documentation; 2) Prevent new infestations of noxious weeds; 3) Implement Integrated VVeed Management (IWM) to control or manage noxious weed populations; 4) Maintain weed inventory. herbicide application and mapping records; 5) Restore disturbed areas to their proper ecological function to protect native plant ecosystems and watersheds from degradation by noxious weeds. 6.1 Inventory and Monitoring Before a new site is developed, Oxy will inventory the site and adjacent areas for noxious weeds, including access roads and other probable weed ingress routes. Noxious weed locations (List A and List B species) will be collected with a GPS unit. Any noxious weed infestations found will be treated before site disturbance, if timing is appropriate. If the season is not appropriate for weed treatment, activities may proceed and the weeds will be monitored and treated during the appropriate season. Weeds on adjacent properties may be treated as appropriate with permission of the landowner. Populations of Colorado or County List A and List B species (see Appendix A) will be reported immediately to the County Weed Manager. On Federal property or for federal projects. a Noxious Weed Inventory record will be completed each time a List A or B weed infestation is inventoried (with the exception of redstem filaree and quackgrass), and the populations will be reported, Monitoring will be conducted at least once a year, early in the growing season, by Oxy staff or contractors, and in coordination with BLM or FS staff on federal lands. For most of Oxy's operation areas, monitoring will occur between May and July. All previously treated noxious weed sites will be monitored for regrowth and scheduled for re -treatment as necessary. All disturbed areas under Oxy management will also be monitored to ensure there are no new weed infestations. 6.2 Prevention The purpose of prevention measures is to preclude the introduction of new or existing noxious weeds from the project area to un -infested areas or from adjacent land into the project area. 6.2.1 Construction Prevention Measures Construction equipment entering project areas (backhoes, trackhoes. dozers. blades, rollers, lowboys, equipment trailers, etc.) will be power washed or otherwise cleaned. °Equipment" is defined as any earth moving and any other machinery, trucks or vehicles, trailers and tools. On Federal property, equipment may be inspected by USFS or BLM personnel. Pickup trucks, SUVs, vans, water trucks, and pipe trucks should also be clean but do not require inspection prior to entering federal lands. Track pads, gravel beds or rumble strips will be installed at ingress/egress points to the site to limit weed propagules from entering or leaving the site. Soils from infested areas of the project site will not be moved off site, but will be stockpiled and treated for weeds as necessary. If infested soils are moved off site, they will be kept on Oxy -managed property, monitored, and treated as necessary. Stockpiled soils will be monitored and treated to control noxious weeds. All purchased products used in development and reclamation of a site will be inspected or certified as weed -free whenever possible, including soils, rock and gravel, seeds„ mulch and erosion control products. 6.2.2 Revegetation The goal of reclamation and revegetation of a site after disturbance is timely establishment of a desirable plant community and prevention of noxious weed infestation. "Timely" is defined as "by the end of the second year of project completion" (BLM 2007). Elements cif successful revegetation include the use of topsoil that was set aside during construction and kept weed -free; reseeding with appropriate species to establish plant cover, and stabilization of the soil surface with the appropriate mulches. tackifiers. and erosion control products as needed, Plans for revegetation and reclamation of disturbed areas are site-specific, and will include a plant list, method of seeding, how seeding success will be determined and how the revegetated area will be monitored. Most private landowners request re -seeding with common pasture grasses, including timothy, (Phleum pratense), brume grasses (Bromus or Bromopsis), orchardgrass pact)/lis glomerata), and oats, tricale, rye, or wheat as an annual covercrop. USFS and BLM seed mixes are compiled on a site-specific basis, according to elevation and existing vegetation community on the site. Non-native, non-persistent sterile grasses may be used to provide ground cover for soil stabilization and weed suppression during temporary reclamation on both private and federal land. See Appendix C for a sample Oxy Revegetation and Reclamation Plan. Certified weed seed free straw, hay, mulch, seed or other materials will be used for soil stabilization and/or revegetation purposes (Colorado Department of Agriculture certified inspector to State standards). Seed tags will be available for inspection upon request of the Inspector. Topsoil that is stock piled for more than one year will be seeded according to above standards at the earliest practical time to reduce the possibility of noxious weed establishment. Revegetation efforts will be monitored annually until successful establishment of desirable or intentionally planted seed or plants is confirmed. Noxious weeds found in revegetation will be documented, and managed per guidelines in this Weed Management Plan. 6.3 Control and Management A comprehensive multi -strategy approach utilizing IWM will be employed to detect, map, treat and control noxious weeds. Treatments will include herbicide, cultural, mechanical. revegetation, and biological control alone or in combination as necessary for efficient weed control. On Federal lands, control and management methods (including herbicide use) will be verified and approved with the appropriate land management agency representatives. Activities on BLM lands in Colorado requires submittal of a "Pesticide Use Proposal Form" (BLM 2007), The accompanying treatment tables describe the management methods, rates, and timing of control measures for specific targeted weeds (see Table 1 and Table 2). Treatment application records will be retained by Oxy and available for inspection by contacting personnel listed in Section 3., Table 1. Weed slanaucmcnt Nlethuds Target Weed(s) Management Method(s) Herbicide Recommendation ProductlRatet Adjuvant or Surfactant & Rate Timing of Control Chamomile, scentless (Matricania perforate) Herbicide, mechanical, cultural picloram or clopyralid, as per label Nonionic surfactant, as per label Pre -flower, early season Houndstongue (Cynoglossum officinals) Herbicide, mechanical, cultural picloram or picloram + 2,4-D, as per label Nonionic surfactant, as per label Pre -bud or rosette stage (early spring) Knapweed, Russian (Acroptilon repens) Herbicide, cultural 1)clopyralid plus2,4-D, or 2)ctopyralid plus trictopyr or 3)picloram, as per label Nonionic surfactant, as per label Fall Knapweed, spotted (Centaurea maculosa) Herbicide 1)clopyralid pxus2,4-D, or 2)clopyralid plus triclopyr or 3)gtyphosate, as per label Nonionic surfactant, as per label Rosettes in fall or early spring Moth mullein (Verbascum blattaria) Herbicide. mechanical, cultural Dicamba or chlorsulfuron, as per label Nonionic surfactant, as per label Rosettes in fall or early spring Oxeye daisy, (Chrysanthemum leucanthemum) Herbicide, mechanical, cultural Clopyralid or metsulfuron methyl, as per label Nonionic surfactant, as per label Early, young growth *Sulfur cinquefoil (Pofentilla recta) Herbicide, mechanical, cultural 1)picloram or 2)metsulfuran methyl, as per label Nonionic surfactant, as per label Spring or Fall Target Weed(s) Management Method{s) Herbicide Recommendation ProductiRatet Adjuvant or Surfactant & Rate Timing of Control *Tamarisk, Salt cedar (all Tamarix sp.) Herbicide Triclopyr, as per label Nonionic surfactant, as per label Basal spray on young plants, cut and treat stump on older plant. Thistle, bull (Cirsium vulgare) Herbicide, mechanical, cultural Clopyralid or picloram, as per label Nonionic surfactant, as per label Rosette stage, spring or fall Thistle. Canada (13reea arvense) 1 Herbicide, cultural 1)clopyralid plus2,4-D, or 2)ciopyralid plus triclopyr or 3)glyphosate. as per label Nonionic surfactant, as per label Early bud stage or fall rosettes Thistle, musk (Carduus nutans) Herbicide, biological, mechanical, cultural 1)2.4-D or 2) clopyralid plus 2,4-D or 3)glyphosate. as per label Nonionic surfactant, as per label Rosette stage, spring or fall Thistle, plumeless (Carduus acanthoiides) Herbicide, mechanical, cultural Clopyralid or tricloram, as per label Nonionic surfactant, as per label Rosette stage. spring or fall Thistle, Scotch (Onopordum tauricum) Herbicide, mechanical, cultural Picloram or dicamba, as per label , Nonionic surfactant, as per label Rosette stage, spring or fall These are small population or individuals that have been treated in the area. and will be monitored, all others are large and widespread populations tHerbicides that are preferred for control are numbered as 1, if not numbered, there is no preference Table 2. Biological, Cultural, or Mechanical Methods to be Used Practice Target Weed(s) Seeding with approved seed mix to revegetate disturbed land, including a combination of fast growing and long-term species (see revegetation plan). All weeds above, but especially important for those that list cultural as a control method in Table 1. Removal of small infestations by pulling or hand grubbing at any stage. Houndstongue, buil thistle,, musk thistle, plumeless thistle, scotch thistle Repeated mowing during bolting pre -flowering ' stage: cutting, bagging and removal of flowering heads if already in flower All thistle species Introduce biological control approved for specific weeds in very large infestations, after agency approval. Those with biological listed as a control method in Table 1 have approved bio -controls. 7. References Bureau of Land Management, 200T. Noxious and Invasive Weed Management Plan for Oil and Gas Operators, Glenwood Springs Energy Office, Colorado. Colorado Department of Agriculture. 2008. Noxious Weed Lists. Available: http:/fwww.coiorado.govlcs/Satellite?c=Page&cid=1174084048733&pagename=Agricult u re -Ma in%2 FC DAG Layo ut Mesa County, Colorado Noxious Weed Management Plan, Adopted November 30, 2009. Garfield County Weed Management Plan, Resolution No. 2002. 8. Local, State and Federal Contacts and Resources Olenwerrrd Spiingi BL.M Energy Office E401o8rw Beth Breeurerrun 2425 Smith Osumi Aceuue. Suite 101 Oleanrood Springs.. CO 816014i 90 Phone: (970) 217.5232 Fax. l270r9.I7.4267 8eth_Bre nseusanabbu.goc Cn id Jr tine Sl M Weed Management Slxcralr+t Spoly Taber 2$1! H roar.] Ortwd Jnuctiou. CO 81%6 Phone: (470) 244.3004 Fax: 1270 244-3003 mask _taber4binagor Oartield County Vegetation Alu na:it Stele Anthony P.0 Box 426. 0248 CR .133.1 Ride. CO 41650 Moue: t9'0)6:mai I Fax .970 6254627 sandiony ft garfseld•aounry.eCen Meta County Pest and Weed Inspector habit Simra P O. Box 5007 ()rand Jonetirm. PO SI 502.5028 Pluue ;9701:!!•'126 Far: 1970)21:•3519 ludlri si rotaarnaaacounty us Colorado Suite Uw crsity Cooperative Extension dcrvi c Craiticld Cowry 1001 Railroad Avenue. P 0 Bite 1112 Rile. CO 0I640.1112 Moor (070) 625.5960 Entail: gerfield;Er�ext colostate edu Colosedo Sr ler L rlivasir' L Q41.'tiatlse Lxteusiou Mesa County :774 'Hwy. Sh Clnnrd Jmtctian. CO 51503 Phone (970) 244.1*34 C910:643 Dsportatent of inaulrnra ihvisiort of Mitt Wduscry 13iologital L outrni Smion Y.U. Box 4101 PilIt+ndc. CO RI a:ri PI1.+ae r97•O1, 4-11.1.1'131r civic Colorado Weed Magapauenr .lsacoiatiou Moe: 1303Y 779-7939 www.owma.org Colorado Deuaruienr of Acri wlnre Slate 1111aact Coordinator Noxious Weird Pr'ogioni Dis sion of L'ouservosion Sara loci 7(Q Kspling Shear. Sura 400 Lakewood CO 80215.5894 Phone: 1303)219-1182 Well ...ire'. www as Mate.t:rr.ro i lei n cc tl. a ca l l trml tppendix Colorado Noxious Weed List List A- Statewide Eradication African rue (Peganum harmata)`'M'' Myrtle spurge (Euphorbia myrsinites)`'"' Camelthorn (Alhagi pseudalhagrj`'". Orange hawkweed (Hieracium aurantiiacum) Common crupina (Crupina vulgaris)""'. Purple loosestrife (Lythrum salicaria)``"'' Cypress spurge (Euphorbia cyparissias)``"• Rush skeletonweed (Chondrilla juncea)`'"". Dyer's woad (lsatis tinctoria)" r Sericea lespedeza (Lespedeza cuneate)''" Giant salvinia (Salvinia molesta)"" Squarrose knapweed (Centaurea virgata)''" Hydrilla (Hydrilla verticillataf " Tansy ragwort (Senecio jacobaea)`'M Meadow knapweed (Centaurea Yellow starthistle (Centaurea sotstitialis)`'". pratensis)''"' Mediterranean sage (Salvia aethiopis)'''. Medusahead (Taeniatherum caput - medusae)'" List B -Prevent Further Spread Absinth wormwood (Artemisia Musk thistle (Carduus nutans) absinthium)''". Oxeye daisy (Chrysanthemum leucanthemum)''' Perennial pepperweed or tall whitetop (Lepidium Bouncing bet (Saponaria ofcinalis). latifoliurr+)''"" Bull thistle (Cirsium vulgare). Plumeless thistle (Carduus acanthoides)`'"' Canada thistle (Cirsium arvense)' Quackgrass (Elytrigia repens) Chinese clematis (Clematis orienfalis)'"' Redstem filaree (Erodium cicutarium) Common tansy (Tanacetum vulgare). Russian knapweed (Acroptilon repens)''°" Black henbane (Hyoscyamus niger)''" Common teasel (Dipsacus fullonum). Corn chamomile (Anthemis arvensis)' Cutleaf teasel (Dipsacus laciniatus). Dalmatian toadflax, broad-leaved (Linaria dalmatica)' Dalmatian toadflax, narrow -leaved (Linaria genistifolia) m. Dame's rocket (Hesperis matronalis). Diffuse knapweed (Centaurea diffusa)"'m. Eurasian watermilfoil (Myriophyllum spicatum). Hoary cress or whitetop (Cardaria draba)` Houndstongue (Cynoglossum officinale). Leafy spurge (Euphorbia esula)"`"' Mayweed chamomile (Anthemis cotula). Moth mullein (Verbascum blattaria). Russian -olive (Elaeagnus angustifolia). Salt cedar (Tamarix chinensis, T.parviflora, and T. ramosissima). Scentless chamomile (Matricaria perforate). Scotch thistle (Onopordum acanthium). Scotch thistle (Onopordum tauricum). Spotted knapweed (Centaurea maculosa)''"• Spurred anode (Anode cristate)` Sulfur cinquefoil (Potentilla recta)". Venice mallow (Hibiscus trionum). Wild caraway (Carum carvi). Yellow nutsedge (Cyperus esculentusr Yellow toadflax (Linaria vulgaris)"m. List C -Localized Concern Chicory (Cichorium intybus)c Common burdock (Arctium minus)" Common mullein (Verbascum thapsus) St. Johnswort (Hypericum perforatum) Downy brome or cheatgrass (Bromus tectorum) Field bindweed (Convolvulus arvensis) Halogeton (Halogeton giorneratus) Johnsongrass (Sorghum halepense) .Jointed goatgrass (Aegilops cylindrica) Perennial sowthistle (Sonchus arvensis) Poison hemlock (Conium maculatum) Puncturevine (Tribulus terrestris) Velvetleaf (Abutilon theophrasti) Wild proso millet (Panicurn miliaceum) - Immediately report this noxious weed species to the Garfield County Weed Manager when found in Garfield County. " - Immediately report this noxious weed species to the Mesa County Weed Manager when found in Mesa County. • - These noxious weed species will be mapped and inventoried to meet BLM and FS requirements. THIS PAGE LEFT BLANK FOR TWO-SIDED DUPLICATION. Appendix H Excel Spreadsheet Components and Example Tables for Pesticide Reporting The Excel spreadsheet table will contain the data fields listed below. This information should have been recorded on Noxious Weed Inventory and Pesticide Application records completed during the field season. The Excel spreadsheet will contain a new entry for each weed inventory and/or pesticide application. Infestation Number (IN #): Needed when List A or List B species (with the exception of redstem filaree and quackgrass) are inventoried and treated. This is the unique number or code associated with each weed infestation. Date: Date of the weed inventory and/or treatment Observer/Applicator (Obs/AppI): Person conducting the inventory and/or applying the herbicide. Weed Name or Bare Ground: Common name of the weed. If it was a bare ground treatment state as such. UTM Easting (UTM E), Northing (UTM N) and Zone (Z) (should always be in NAD 83) or use Lat and Long if preferred. Be consistent with which one is used. Infested Acres (Inf Acres): List how many acres are covered with the weed. Density (Dens) i.e. Cover: L= Low (less than 5% total canopy cover) M = Moderate (5% - 25% canopy cover) H = High (more than 25% canopy cover) Surface ownership (Own): BLM, FS or private Herbicide Trade Name (Tr Name) or Treatment Method — if a manual or biological treatment state as such. Chemical Names (Chem Name) — Only needed when using an herbicide with multiple active ingredients or when using a mixture of chemicals. For example, if using Sahara DG which has two active ingredients, imazapyr and diuron, enter the first two letters of each active ingredient. e.g. im + di. See Excel spreadsheet example. Application Rate (Pounds Active Ingredient (A.l.)/Acre or Pounds Acid Equivalent (A.E.)IAcre): For those herbicides with multiple active ingredients, multiple columns for the application rates are provided. Application rates should be entered in the same order chemical names are entered. For example, for Sahara DG, the A.I./acre of imazapyr would be entered in the first Application Rate (AR #1) column. The Al,/acre of diuron would be entered in the second Application Rate (AR #2) column. If an additional chemical was used in the mix it would be entered in the third Application Rate (AR #3) column. Total Pounds Active Ingredient (AA.) or Acid Equivalent (A.E.) Applied: For those herbicides with multiple chemicals, multiple columns for the pounds of A.I./A.E. are provided. Pounds of A.I./A.E. should be entered in the same order chemical names are entered. For example. for Sahara DG, the pounds of A.l. of imazapyr would be entered in the first Total Pounds A.I./A.E. (Al AE #1) column.. The pounds of A.I. of diuron would be entered in the second Total Pounds A.IJA.E. (Al AE #2) column. If an additional chemical was used in the mix it would be entered in the third Total Pounds A.I./A.E. (Al AE #3) column, Acres Treated: This should equal the Total Pounds A.I./A.E. divided by the Application Rate in Pounds A.I./A.E. Example of a Table for Reporting Total Pounds Active Ingredient Applied and Total Acres Treated by Chemical Type Chemical(s) Application Rate (lbs. A.I./acre or lbs. A.Efacre) Acres Treated 20.7 Total Pounds A.I, or A.E. metsulfuron methyl .056 1.16 metsulfuron methyl .075 1.7 .13 Total acres and # a,l. 22.4 1.29 Metsulfuron methyl + 2,4_D .125 + 1.87 .07 .009 + .0135 Total acres and # a.i. .07 .009 + .0135 clopyralid + .285 + 1..5 5.0 1.43 +7.60 2,4-D Total Pounds A.I. or A.E. metsulfuron methyl 1.29 Clopyralid + 2,4-D .185 4- 1.0 1.6 .3 + 1.6 Total acres and # a.e. 2.37 6.6 1.73 + 9.2 Example of a Table for Reporting Total Pounds of Active Ingredient Applied by Chemical Type Chemical(s) Total Pounds A.I. or A.E. metsulfuron methyl 1.29 2,4-D 9.21 clopyralid 2.78 glyphosate 2.37 THIS PAGE LEFT BLANK FOR TWO-SIDED DUPLICATION. 1ppcndix C Sample Revegetation and Reclamation Plan The proposed facility will be in operation for an anticipated period of approximately during development and production of OXY's natural gas production operations. Upon termination of the development and production activities, the facility will be reclaimed, as outlined below: • All equipment and structures will be removed. • OXY will remove all safety and storm water BMPs, and other surface objects from the premises. • OXY will restore the site to pre -facility conditions by re -contouring and re - vegetating the site. Top soil will be redistributed across the site and will be reseeded with an approved seed mix (see attached seed mix recommendation). • OXY will monitor the site to ensure that 70 percent of the pre-existing vegetation is achieved, per the requirements of the area wide CDPHE Stormwater Permit for Cascade Creek and Collbran developments. Seedbed Preparation and Slope Reconstruction: Cut and fill slopes will be backfilled and re-contoured to a slope of 3:1 — 2.5:1 or less in instances where necessary to match the existing natural contours. Following final contouring, all backfilled or ripped surfaces will be covered evenly with topsoil. Re - contouring should form a complex slope with heavy pocking. In areas with slope greater than 3 percent, imprinting of the seed bed is recommended. Final seedbed prep will consist of scarifying/imprinting the topsoil prior to seeding. Imprinting can be in the form of dozer tracks or furrows perpendicular to the direction of slope. When hydro -seeding or mulching, imprinting should be done prior to seeding, unless the mulch is to be crimped into the soil surface. If broadcast seeding and harrowing, imprinting will be done as part of the harrowing. Furrowing can be done by several methods, the most simple of which is to drill seed perpendicular to the direction of slope in a prepared bed. Other simple imprinting methods include deep hand raking and harrowing, always perpendicular to the direction of slope. All compacted areas will be ripped to depth of 18" with max furrow spacing of 2'. Where practicable, ripping will be conducted in two passes at perpendicular direction. Topsoil: Following final contouring, all backfilled or ripped surfaces will be covered evenly with topsoil. The topsoil in the cut slope on the back of the pad will be heavily pocked using the excavator bucket to form an uneven soil surface complex which will aid in revegetation and help with slope stabilization. The fill slope, and remaining disturbed, and reclaimed areas will be track walked to aid in revegetation and slope stabilization. In areas that may not have been disturbed during the reclamation process or areas of suspected compaction that will be reseeded, measures will be taken to loosen and spread the topsoil. These measures may include scarifying the soil by racking or harrowing the soil. Seed Mix: Seed mix used for reclamation will be taken from the attached seed mixtures. Seeding Procedures: For best results and success, the recommended grass mixture reseeding should be done in late autumn in order to take advantage of natural precipitation for the region. The reseeding rate should be doubled for broadcast application. Preferred seeding method is multiple seed bin rangeland drill with no soil preparation other than simple grading to slope and imprinting and waterbars, where applicable. Alternative seeding methods include, but are not limited to: • No -till -drill (no soil preparation required); • harrow with just enough soil moisture to create a rough surface, broadcast seed and reharrow, preferably at a 90 degree angle to the first harrow; • hydro -seeding (most economical in terms of seed cost}; and • hand raking and broadcast followed by re -raking at a 90 degree angle to the first raking. • These are not the only means of replanting the site. However, these methods have been observed to be effective in similar landscapes. The prepared soils will be seeded (weather permitting) no more than 24 hours following completion of final seedbed preparation. The seeding will be conducted by means of drilling the prescribed seed at prescribed seeding rate. The seed will be drilled with a common range drill at a depth of 0.25 — 0.5" beneath the soil surface. The seed will be drilled horizontally across the pad faces and perpendicular to the track walking when possible. When slope gradient less than 2.5:1 exists and drilling is not possible from a mechanical and safety standpoint the soils will be broadcast seeded at twice the prescribed amount. The reseeding will be monitored and reseeded as appropriate until the reclamation standards detailed above are met. Attachment E Cascade Creek Stormwater Permit C0R0038414 THIS PAGE LEFT BLANK FOR TWO-SIDED DUPLICATION. STATE OF COLORADO John W. llickenlooper, Governor Christopher E. Urbino, MD, MPH Executive Director and Chief Medical Officer Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. 3. Laboratory Services Divisaon Denver. Colorado 80246-1530 8100 Lowry Blvd. Phone (303) 892-2000 Denver. Colorado 80230.6928 Located in Glendale. Colorado (303) 692.3090 http.11www.cdphe.5te te.co, us June 21, 2012 Doug Weaver, Ops Mgr & Attorney -in -Fact Oxy USA WTP LP 760 Horizon Dr Ste 101 Grand Junction, CO 81506 Colorado Department of Public Health and Frivironmenr RE: Renewal of Permit/Certification Administrative Continuation For: Cascade Creek Common Plan of Development Located at: 13 Mi N of Debeque (See map in file), Debeque, Garfield County Permit No.: COR038414 Dear Mr. Weaver; The Division has received an application to renew the above permit/certification. It has been determined that there is sufficient information to make this permit/certification eligible for renewal. More information may be requested by the Division as progress is made in developing a new permit/certification for the above listed facility. This information must be made available to the Division when requested to complete the permit process. The Division is currently in the process of developing a new permit or master general permit and associated certification for the above permitted facility. The development and review procedures required by law have not yet been completed. When the discharge permit issued to you for your facility expired on June 30, 2012 your permit is administratively continued and remains in effect under Section 104(7) of the Administrative Procedures Act, C.R.S. 1973, 24-4-101, et aeg (1982 rept. vol. 10) until the new permit/certification is issued and effective. All effluent permit terms and conditions in your current permit will remain in effect until your new permiticertification is issued and effective. PLEASE KEEP THIS LETTER WITH YOUR PERMIT AND SWMP TO SHOW CONTINUATION OF PERMIT COVERAGE. Sincerely, Debbie Jessop Permits Section WATER QUALITY CONTROL DIVISION xc: Permit File STATE OF COLOFDO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT WATER QUALITY CONTROL DIVISION TELEPHONE: (303) 692-3500 CERTIFICATION TO DISCHARGE UNDER CDPS GENERAL PERMIT COR -030000 STORM -WATER DISCHARGES ASSOCIATED WITH CONSTRUCTION Certification Number COR038414 This Certification to Discharge specifically authorizes: Oxy USA WTP LP LEGAL CONTACT: Heidi Rem Sr..1HS Advisor Oxy USA WTP LP 2754 Compass Drive Ste. 170 Grand Junction, CO 81506 Phone # 970/263-3609 jfrey®cordcomp.com LOCAL CONTACT: Joanna Fry, , Phone # 970/ 263-7800 heidi_reedoxy corn During the Construction Activity: Gas/011 Field Exploration and/or Development to discharge stormwater from the facility identified as Cascade Creek Development " which is located at: 13 miles north of Debeque, map in file Debeque, Co 81630 Latitude 39/30145, Longitude 108/14/10 In Garfield County to: Cascade Creek -- Colorado River Anticipated Activity begins 07/01/2005 continuing through 05/17/2007 On 5 acres (5 acres disturbed) Certification is effective: 07/01/2007 Certification Expires: 06/30/2012 Annual Fee: $245.00 (DO NOT PAY NOW — A prorated MI will be sent shortly.) Page I of 22 From: )eff Hofrnan To: Kathy A Eastev Subject: Pond 13 amended traffic analysis Date: Monday, January 06, 2014 5:04:08 PM Attachments: Traffic Aniertid",ent. Kathy, Here is the Traffic Analysis for the storage portion of Pond 13 Thanks Jeff Hofrnan, AICP p Olsson Associates 760 Horizon Drive. Suite 1021 Grand Junction. CO 81506 j jhoffmanaolssonassociates.com TEL 970.263.78001 DIRECT 970.263.5016 1 FAX 970.263.7456 OLSSON OLSSON ASSOCIATES BASIC TRAFFIC ANALYSIS AMENDMENT OXY USA WTP LP POND 13 EIW FACILITY GARFEILD COUNTY, COLORADO Background This Basic Traffic Analysis Amendment summarizes changes to a Basic Traffic Analysis performed for the OXY USA WTP PL (OXY) Pond 13 EIW Centralized E & P Waste Management Facility, herein referred to as the Pond 13 Analysis, and analyzes additional impacts generated by the proposed accessory storage use. The facility's primary use will be to store produced water that would be recycled for well completions or eventually disposed of at a permitted facility. The site will also be used as a storage area for gas field equipment. The combined facility is currently constructed as production ponds and natural gas production pads. No construction will be required for the ancillary storage use. It is expected that the lifespan of the site will be approximately 30 years_ The storage use adjacent to the Pond 13 facility was not specifically included in the Pond 13 Analysis. This facility will be used for the storage of pipe, valves, and other gas field equipment. The trips associated with this storage facility will originate from the surrounding natural gas operations in the general area and in most cases will not use county roads to reach Pond 13, The equipment and materials that will be brought to the site are from near -by well pads and will be reused in the general area. Trip Generation Vehicle activities during daily operations of the produced water pond use will be identical to the described in the Pond 13 Analysis. However Table 2 from the document has been updated to accurately reflect entering and exiting trips of each vehicle, whereas the Pond 13 Analysis showed one trip per vehicle. These are shown in Table A below. Table A: Trip Generation - Pond 13 Facility Phase Average Trips/Day Maximum Trips/Days Percent Trucks Average Total Trips/Phase Phase Duration Operation 4 8 33 % 43,800 30 years Grilling & Completions 10 14 39% N/A NIA Storage 0 0 0 0 30 years Combined 14 22 33% NIA N/A 760 Horizon Or , Suite 102 Grand Junction. CO 81506 TEL 970.263 7800 FAX 970.263 7456 www.olssonassociates corn Similarly, the increase in traffic expected on CR 204 and CR 213 was updated to reflect two- way trips. The following Table B summarizes the expected traffic volume increases this facility will generate on the county road system. Table B: Traffic Volume Increase - Pond 13 Facility Road Year Estimated VPD Generated Average Operation Trips/Day Generated Percent of Trips/Day Average Generated Maximum Trips/Day Generated Percent of Trips/Day Maximum CR204 2013 446 4 <1% 22 5% CR213 2013 12 4 33% 22 183% Note that increase on CR 213 are still very high due to very low baseline of traffic volume. Also note that there are not additional trips included for the ancillary use as a storage facility. The most significant generator of traffic on the local road system will be drilling and completion activities associated with the surrounding gas field and not the Pond 13 Facility. These activities will occur at random intervals during the life of the facility depending on the market conditions for natural gas. The duration of these drilling and completion activities is also dependent on market conditions plus the availability of drill rigs and other equipment. The storage use is not expected to generate additional traffic on public roads and has the potential to reduce traffic by providing a place for extra materials and equipment that would otherwise be hauled in or out of the larger field. The site will be monitored and inspected by personnel doing similar activities at other facilities in the field, so this activity would currently be accounted for within the background traffic volume. Recommendation Like the Pond 13 Analysis, this amendment shows minor increases in traffic on CR 204 and relatively large increases on CR 213 only because of a very low baseline of existing traffic volume. However, the total traffic volumes will still remain very low.. The additional use as a storage facility is not expected to produce additional trips on the public roadway network and actually has the potential to reduce natural gas traffic by consolidating trips with the larger field. The addition of traffic generated by the proposed facility alone, including the use as a storage area, does not increase existing volumes to levels required for auxiliary lanes or other roadway modifications. Based on this analysis, no additional mitigation or roadway modifications are recommended for this facility. Basic Traffic Analysis Amendment Oxy Pond 13 Facility Page 2 MetroCount Traffic Executive Vehicle Counts Site: CR 213 Conn Creek ' Tuesday...tune 21, 2011 - Totat-154 (incomplete) , 15 minute drops _ Y.(49 . I 1 1.00 :f.3U 1+41 92 44 24 20 % 12 -15 20 22 15 27 102 z PM Po.k 1700. 1000 (1011, PM PHF430.5.3 ' Wednesday, June 22, 2011 - Totat=508, 15 minute drops a 1 1 12 21 01 52 25 14 20 31 10 19 26 71 AM Peak 0600 -0200 (611, AM PHF.0.01 PM Peak 1100 • 1600 (95) PM P11F.0.61 23 17 1.6 EXHIBIT x 91U 3000 2100 3-.0es :13344 13 1 2 2 1 10 4 !4 1 U 4! k 1 0 u i 0 11 .r rt, n 0 0 913 27 13 4 2 0 17 • n n 72 ' 0 e a 19 0 1 4 0 12 9 - 0 I 0 0 2 • Thursday, June 23, 2011 -Total=532, 15 minute drops zoo O 4 a 29 21 1222 42 22 22 10 11 14 21 34 15 15 75 44 1!_ 1 a o - 17 16 .. 0 25 .4 4. '4 1 11 77 14 0 1 0 0 a •- ' - 35 ' - - _ Q 14 .1 15 7 7 0 0 0 0 3 7 f+3 26 5 22 1 1 0 0 44 0 0 AM P..1 0615-8718(1031,. Aa9141F.0..71 PM Peal. 1700 - 1602 1751. PM PHF-0.BS • Friday, June 24, 2011 - Totel.461, 15 minute drops ;'len 04,7 I 1)0 '9') 1.20 .109 1202 1900 =11 =300_2400 4300 L 0 0 2 19 11 t 30 19 Se 30 31 21 6 `21 25 27 00 10 12 0 • u1 3 11 11 L111 5 3 J U 3 as -. 33 1 0 0 0 6 U U 0 0 5 S 32 n r 1 1 - .1 20 1 3 4 0 0 0 0 O r P n 4 20 - - - - 14 7 n 1 n 1 r 1 AM Peak 0400.07001931, AM PHF.0.73 PM Peak 170a - 10001501, PM PH1•0.61 • Saturday, June 25, 2011 - Tota] -246, 15 minute drops -D0", 1100_-_ O 1 1 4 1. 19 49 22 10 13 7 14 15 12 10 14 9 __26 13 6 9 0 0 2 r _ 12 5 1 71 U 9 1 1 7 0 0 1 17- 7 0 0 1 14 4 • r 10 14 .1 J 4 1 AM Peak 0615 - 0715154 AM PHr.0.71 P11 Peak 1715 - 1015 (291. PM. PHF.0.72 ' Sunday, June 26, 2011 - Total=136, 15 minute drops 2200 1130 20110 .21011 '200 .2)20 O 0 0 3 1 11 20 10 0 2 1 12 5 5 0 e 13 1 - di 3 0 0 1 1 1 _ 2 4. U 0 0 U 0 a G Y 1 V J 9 14 1 1 u .4 u 0 0 0 6 4 - - ' 1 7 4 0 0 0 9 1 4 1 :1 2 7 0 1 0 0 6 I AM P334 0600 • 0700 (20), AM PHF.0.52 PM Nail 1711 - 1015 )149. PM PHr.0. 50 • Monday..lune 27, 2011 Totala74, 15 minute drops ,a a 0 0 1 11 16 462 0 a o a 0 11 n 29 0 O 0 0 0 4 6 0 rn . 6 0 A14 P..1 05#5 •0445 (3711, AM 170(2.17.15 PM Peak 1200 - 1300 101, PM PHF.1.00 11 41 Da11yCIass-69 Site: CR 213 Conn Creek.1.0NS Daily Classes Monday, June 20. 2011 1 2 3 4 5 6 7 8 9 10 11 12 Tot 1 Hon. f( 0 0 0 0 0 0 0 0 0 0 0 0 1%1 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Teas 6 103 0 297 20 4 1 12 9 2 0 0 454 (41 1.3 22.7 0.0 65.4 4.4 0.9 0.2 2.6 2.0 0.4 0.0 0.0 WW1 1 136 0 325 20 2 1 6 15 0 0 0 508 (41 0.2 27.2 0.0 64.0 3.9 0.4 0.2 1.2 3.0 D.0 0.0 0.0 Thu 9 134 0 322 25 2 1 22 17 0 0 0 532 (1,1 1.7 25.2 0.0 60.5 4.7 0.4 0.2 4.1 3.2 0.0 0.0 0.0 art 4 112 1 294 30 1 1 13 10 `, 0 0 461 (11 0.9 24.3 0.2 61.6 6.5 0.2 0.2 2.8 2.2 1.1 0.0 0.0 Sat 6 74 0 133 20 0 0 4 9 0 0 0 246 141 2.4 30.1 0.0 54.1 8.1 0.0 (1.0 1.6 J.7 0.0 0.0 0.0 Sun 1 41 0 73 9 0 0 0 12 0 0 0 136 141 0.7 30.1 0.0 53.7 6.6 0.0 0.0 0.0 9.8 0.0 0.0 0.0 Average daily volume Satire wak 3 99 0 227 20 0 0 0 12 0 0 0 376 {1) 0.8 26.3 0.0 60.4 5.3 0.0 n.0 2.1 3.2 0.0 0.0 0.0 Weekdays 4 127 0 309 25 1 013 13 1 0 0, 499 0..8 25.5 0.0 61.9 5.0 0.2 0.0 2.6 2.6 0.2 0.0 0,0 Mahood 3 51 0 107 14 0 6 2 `s0 0 0 0 190 (<; 1.6 30.0 0.0 53.7 7.4 0.0 0.n 1.1 S.3 0.0 0.0 0.h * - Incomplete abedey, June 27, 2011 1 2 3 4 3 6 7 0 9 10 11 12 Total Man 0 21 0 t -,i 1 n 0 0 i7 0 0 (1 74 0.0 2ki.4 0.0 (0., 1.4 0.0 0.0 0.0 0.0 0.0 0.0 0.0 COLORADO PARKS & WILDLIFE Northwest Regional Service Center 711 Independent Ave., Grand Junction, CO 81505 Phone (970)255-5100 • FAX (970)255-6111 wildlife.state.co.us • parks.state.co.us January 10, 2014 Kathy Eastley Garfield County Building and Planning Department 108 8`h Street, Suite 401 Glenwood Springs, CO 81601 RE: Oxy Pond 13 E/W Centralized E&P Waste Management Facility, Revised/Ammended Comments Dear Ms. Eastley: EXHIBIT 1 Colorado Parks and Wildlife (CPW) would like to thank you for the opportunity to work with Garfield County in the review of the Oxy Pond 13 E/W Centralized E&P Waste Management. Facility. This project is to be located in the NE 1 of the SE 14 and the SE' 4 of the SE 1/4 of Section 4, Township 6 South. Range 97 West, of the 6th Principal Meridian in unincorporated Garfield County on an existing location. This request would convert an existing production pond to a centralized E&P waste management facility. It is our understanding that the purpose of the facility is to conserve water by recycling flow -back and produced water for re -use in well stimulations or drilling and that no proposed facility structures, access roads, or surface water diversion structures will be required. This site and associated access road is located within a greater sage -grouse production habitat and black bear year-round range. No significant impacts to wildlife are anticipated if the following recommendations are incorporated into the development of this project: • Night lighting should be of the full -cutoff type and/or timed or otherwise minimized to reduce disruption to wildlife. • The proposed location lies within year-round black bear habitat where human/bear conflicts have previously occurred. There is potential for human/bear conflicts with gas exploration employees who are working and/or camping in these areas during development operations. The potential for human/bear conflicts within these project areas would be greatly reduced by placing and utilizing "bear proof" trash containers at work-site/camping locations. Furthermore, workers affiliated with these projects should be advised not to feed bears, whether intentional or not, since this activity is a violation of Colorado STATE OF COLORADO Jon W. l 4rdcentooper. Governor • Mike King, ExecAtve Direly Department of Natural %scumos (kb D. Sroecherd, Director, Colorado Parks and Mate Parks and W4rlite Commission: Robert W Bray • Chis Castilian. Secretary • Jearne Home 94 Kane, their • Gaspar Perri:one • James Pixel • John Singretary Mark South. Vice -Chair • James Vigil • Dean Wingfield • !Achille &rsmerman Ex CWticlo Members: Mks King end Jon Sabazarr Parks and Wildlife Commission Regulations and is detrimental to wild bears. CPW has information on the design and purchase of "bear proof" trash containers. and will provide this information to anyone who is interested in preventing conflicts with bears. • Following the completion of construction activities, newly exposed soils should be revegetated as soon as possible to prevent erosion and to reduce the likelihood of non-native plants becoming established in the area. Seed mix used for revegetation should be certified as weed -free and consist of native seeds from plants that are common to the area. • To reduce the likelihood of truck - wildlife collisions, proper speed limits (< 25 mph) should be posted and enforced on all service roads. • Fencing around the pit should consist of a minimum of a 7 -foot chain-link fence capable of preventing elk and deer from entering the pit; concurrently it should have a small mesh type of fencing along the bottom of the fence (buried one -foot below grade level and extending a minimum of two -feet above grade) capable of preventing small animals from entering between the gaps (gaps should be no larger than three -inches). • The pit should be constructed with a 4:1 slope escape ramp and/or with chain-link fencing in one corner of the pit to allow entrapped wildlife to escape. • The wastewater pit(s) should be adequately protected to ensure that waterfowl and other birds are prevented — excluded- from entering or coming in contact with water in the pit(s). Adequate protection may include netting (preferred by CPW and USFWS), RADAR triggering noise deterrents, floating cover, or other device that is a demonstrably proven method of avian deterrent. Unacceptable methods include flagging, floating 4 inch hollow plastic balls, decoy predators, or other sight deterrents, reflectors, strobe lights, or zon guns (sonic blast). See the USFW web page for additional guidance at http://www.fws.gov/mountain- prairiefcontarninants/contaminants 1 c.html • CPW requests to be notified immediately if any birds and/or wildlife are found dead or trapped within or around the pit, netting, or fences. • Construction activities (on a daily basis, continuous, intermittent loud noise) such as heavy equipment operations (backhoes, bulldozers, generators and heavy trucks) and or intensive human activities should occur outside of the time period from March 1 through June 30 to minimize impacts to greater sage -grouse production areas. Construction activities include earth moving and or pit liner removal or installation. Colorado Parks and Wildlife appreciates the opportunity to work with Garfield County on this and other projects for the benefit of wildlife. If you have any questions please contact Albert Romero, District Wildlife Manager. at 970-216-3847. JT Romatzke Area Wildlife Manager cc: Ron Velarde, NW Regional Manager Dean Riggs, Assistant NW Regional Manager Michael Warren, Energy Liaison Albert Romero, District Wildlife Manager Jim Komatinsky, Land Use Specialist File From 1 in I, To: t .. Subject: RE: OXY Ponds Date: Friday, January 10, 2014 10:46:01 AM Kathy: I have reviewed the additional materials provided. The following questions, concerns, or comments were generated: EXHIBIT 1. The drainage report has intensities that were used for calculation of runoff. The Applicant should provide documentation on the source of the intensities. 2. The drainage plan doesn't show that grading will convey water into the ponds. 3. It reads from the report as if the ponds will be pumped to release water. This operation needs to be described in greater detail. 4. Similarly, to the above, the Applicant should describe how the levels in these ponds will be monitored and managed concerning Items such as active water level, precipitation, freeboard, overflow level, etc. 5, The erosion control and drainage plans that were included are still lacking sufficient detail to determine how site runoff is directed into the existing ponds 6. The erosion control plan needs additional BMPs in areas of concentrated flow. 7. The traffic study should be revised to reflect the 2011 traffic counts from Garfield County Road and Bridge. Call or email any questions. These can also be discussed in greater detail on Monday. See you then. Sincerely, !Mountain Cross Engineering. Inc. Chris Hale. P E. 826 112 Grand Avenue Glenwood Springs, 00 81601 Ph: 970.945.5544 Fx: 970 945 5558 January 13, 2014 EXHIBIT Garfield County Kathy Eastley Garfield County Community Development Department RE Oxy Pond 13 EAN, File # LIPA 7675 Amended Comments F'e, lefaifiorr Marrame►rrent Dear Kathy. Below are amended comments based on information that you sent me on January 7, 2014. The amount of surface area disturbance to be reseeded due to future modifications made to the existing ponds is not clear from the Reclamation Plan submitted Prior to issuance of the Land Use Change permit the Applicant shall provide information regarding total amount of site disturbance related to proposed improvements and provide a revegetation security based upon $2 500 00 per acre of revegetated area if the amount of disturbance is greater than '/= acre Also it is requested that the applicant provide a soil plan that provides for soil cover if any topsoil stockpiles will sit exposed for a period of ninety days or longer Sincerely, Steve Anthony Garfield County Vegetation Manager 0375 County Road 352, Bldg 2060 Rifle, CO 81650 Phone: 970-945-1377 x 4305 Fax: 970.625.5939 Board of County Co January 20, 2014, continued from Decem EXHIBIT LIPA7675 PROJECT INFORMATION TYPE OF REVIEW APPLICANT (OWNER) CONSULTANT LOCATION PROPERTY DATA ACCESS ZONING COMPREHENSIVE PLAN Limited Impact — Water Impoundment, Storage OXY USA WTP, LP — Daniel Padilla, Chris Clark Jeff Hofman — Olsson Associates Northeast of Debeque in Section 4, Township 6 South, Range 97 West of the 6th P.M. Parcel - 640 -acres and Project area - 21.47 -acres CR 213 (Conn Creek) to private road Resource Lands - Plateau Agricultural Production / Natural I. SUPPLEMENTAL INFORMATION A public hearing was opened on December 16, 2013 regarding the request to permit existing water impoundments and to allow for general storage of equipment, machinery and supplies. The Board of County Commissioners continued the Public Hearing to this date in order for Staff and the Applicant to resolve or minimize the outstanding issues necessary to allow for demonstration of compliance with regulations and standards contained in the 2013 Land use and Development Code (LUDC). Since the prior hearing Staff provided the Applicant the opportunity to meet and discuss the outstanding issues, particularly the proposed amendments to the recommended conditions of approval, Exhibit T. The Applicant declined at that time and Staff provided a timeframe for submittal of additional information. Supplemental Information from the Applicant At the Public Hearing on December 16, 2013 the Applicant submitted the following information: 1. A Noise Analysis — Exhibit S; 2. Proposed revisions to the Staff recommended conditions of approval — Exhibit R. On January 6, 2014 the Applicant submitted the following information — Exhibit V: 1. Final Drainage Report; 2. Grading permit numbers; 3. Traffic analysis. Board of County Commissioners January 20, 2014, continued from December 16, 2013 LIPA767S Supplemental Information from Referral Agencies 1. Road &Bridge Traffic Count for CR 213 — Exhibit X; 2. Colorado Parks and Wildlife — Exhibit Y; 3. Mountain Cross Engineering— Exhibit Z; 4. Vegetation Management — Exhibit AA. The information has been reviewed by Staff and applicable referral agencies in order to determine if regulations and standards required by the LDDC have been satisfied, as well as to determine if additional conditions of approval are necessary to meet code requirements. Staff met with the Applicant and representatives on Monday, January 13, 2014 to discuss the submitted information and outstanding issues necessary to move forward to hearing. Staff and the referring engineer identified deficiencies in the supplemental submittal information and discussed proposed conditions of approval. Other discussion included OXY's timing in submittal of additional supplemental materials for the continued public hearing. Submittal documentation and discussion items from the meeting are incorporated into this report which focuses on the conditions of approval that were considered at the December 16th hearing. Each of these conditions is discussed, including any additional information submitted, including whether or not the condition has been satisfactorily resolved, remaining issues, as well as recommended revisions to the conditions. Section V. of this report contains a comprehensive list of the conditions currently being recommended to the Board of County Commissioners in order to bring the project into conformance with regulatory requirements. II. DISCUSSION OF DECEMBER 16 CONDITIONS LIST OF ORIGINAL CONDITIONS FROM DECEMBER 16 REARING General Conditions 1. That all representations made by the Applicant in the application and public hearing shall be conditions of approval, unless specifically altered by the Board of County Commissioners. Staff Comment: OXY agrees to condition. 2. That the facility shall operate in compliance with all applicable Federal, State, and local regulations governing the operation of this type of facility. Staff Comment: OXY agrees to condition. 3. The land use change permit is for two water impoundments, 13E and 13W, not to exceed 3.3 - acres in size and storage capacity not to exceed 121,480 Barrels of produced water. In addition, the 21.47 -acre project area is approved for two storage facilities as indicated on the approved Board of County Commissioners January 20, 2014, continued from December 16, 2013 LI PA7675 site plan for a total area of 3.03 -acres. No hazardous material or fuel storage is permitted within the facility. Staff Comment: OXY agrees to condition. Conditions Prior to Issuance of Permit 4. Prior to issuance of the Land Use Change Permit, the Applicant shall provide a supplement to the Traffic Analysis confirming that Storage traffic was included in the analysis or updating the report as appropriate. The supplement shall include a finding consistent with the current study that no additional traffic improvements are recommended or provide specific recommendations that the Applicant shall be required to comply with subject to review by the County's Consulting Engineer. Staff Comment: OXY has provided a supplement to the original traffic study, Exhibit W1, which indicates that existing traffic levels on CR 213 (Conn Creek Road) is twelve (12) Vehicles Per Day (VPD) and that an analysis of both average trips and maximum trips per day to serve the storage component of the project was analyzed. The addition of an average of four (4) VPD would increase the traffic on the county road by 33% while the maximum of 22 VPD to serve the storage facility would increase the traffic on CR 213 by 183%. The conclusion and recommendation of the Applicant's engineer was that no improvements were necessary due to the low volumes of traffic that would result. Staff obtained the Road and Bridge Vehicle Counts for CR 213, Exhibit X. These numbers are from 2011 and page 2 indicates an average daily volume of 376 vehicles on the road. Chris Hale, Garfield County consulting engineer, responded that the traffic study should be revised to reflect the 2011 traffic counts from Garfield County Road & Bridge. This condition should remain in place and a revised supplement to the original traffic study be required with the updated numbers used for calculation. One other discussion item was that the proposed storage areas would generate 0 vehicle/truck trips and the consulting engineer did not have sufficient documentation to support this assertion. 5. Prior to issuance of the Land Use Change Permit, the Applicant shall provide written confirmation that all pipelines serving the facility have been properly permitted or are exempt from permitting requirements. Staff Comment: Information was submitted, Exhibit V2, in the form of three grading permit numbers that, upon significant staff research, appear to be located in the area of the proposed facility. The intent of this condition is to assure that all required permits have been obtained through Garfield County for the infrastructure required for this facility. This could be accomplished via one of the following manners: A. The Applicant could submit information relative to the pipelines including origination, length and diameter, including any permits issued, to assure that all required approvals are in place; B. The Applicant could provide an affidavit that all required Garfield County permits have been obtained for the pipelines serving this facility. 3. Board of County Commissioners January 20, 2014, continued from December 16, 2013 1I PA7675 Staff recommends that one of the above methods be incorporated as a condition of approval. 6. Prior to issuance of the Land Use Change Permit, the Applicant shall provide copies of the well permits related to the three monitoring wells for the site. Staff Comment: Well permits issued by the Division of Water Resources are required for monitoring wells. OXY seeks to amend this condition to allow for provision of these permits at a later date, after issuance of the LLJCP. The recommendation to submit this information prior to issuance of the LUCP is to assure that all requirements are satisfied prior to the County's final. approval for commencement of the use and construction of the facility. Once the LUCP is issued the County has no 'trigger' to require submittal of the information other than a violation process or a process to revoke the permit. The intent of the monitoring wells is to assure water quality standards are met, without which Staff is unable to determine compliance with the standards of the LUDC. 7. Prior to issuance of the Land Use Change Permit, the Applicant shall provide a statement by a qualified professional or representative of the Applicant confirming the adequacy of the access road to serve the site. A waiver from Article 7, Roadway Standards is approved pursuant to the approval criteria contained in Section 4-118 of the Land Use and Development Code, subject to compliance with the above requirement. Staff Comment: This issue is directly related to the County requirement that the Applicant demonstrate that safe and adequate access exists to serve the site. Section 7-107 of the LDDC states that "All roads shall be designed to provide for adequate and safe access...", that "Access to and from the use shall be safe and in conformance with applicable County, State, and Federal access regulations." And that "Access serving the proposed use shall have the capacity to efficiently and safely service the additional traffic generated by the use." In order to determine compliance with these requirements sufficient documentation is necessary to be submitted and reviewed, particularly the existing physical features of the road. This information has not been provided and instead the Applicant has requested waiver. The existing physical roadway must be reviewed for a determination of compliance with the minimum standards in 7-107, and the Applicant has the ability to request a waiver for particular issues or components that are not compliant with the minimum standard. These could include issues such as road grade or road width. Insufficient information has been submitted as required by Section 4-118 with regard to granting a waiver as it appears that the Applicant has simply requested waiver of ail the road standards rather than provide sufficient information to determine which waivers may in fact be necessary. A waiver of the road standards is not a waiver of the requirement to provide adequate access but simply that the physical road may not meet certain components of the standards and a determination of adequate access may be based upon an engineer's statement of adequacy. This has not been provided, therefore Staff cannot make a determination of adequate access based as required by the code. 41 Board of County Commissioners January 20, 2014, continued from December 16, 2013 LI PA7675 Staff recommends amendment of this condition: "Prior to issuance of the Land Use Change Permit, the Applicant shall provide a statement by a qualified professional or representative of the Applicant confirming that safe and adequate access with sufficient road capacity exists to serve the proposed project. A waiver from Article 7, Roadway Standards is approved pursuant to the approval criteria contained in Section 4-118 of the Land Use and Development Code, subject to compliance with the above requirement." Prior to issuance of the Land Use Change Permit, the Applicant shall obtain the proper building permits for structures on the site, including any fencing that exceed 6' in height, and pay double the building permit fees for obtaining the permits post -construction. Staff Comment: Staff continues to recommends that this condition be incorporated into the approval of this facility but amends the condition to include the wildlife recommendation regarding fencing specifications. "Prior to issuance of the Land Use Change Permit, the Applicant shall obtain the proper building permits for structures on the site, including existing/proposed fencing that shall consist of a minimum of a 7 -foot chain-link fence capable of preventing elk and deer from entering the pit; concurrently it should have a small mesh type of fencing along the bottom of the fence {buried on - foot below grade level and extending a minimum of two -feet above grade capable of preventing small animals from entering between the gaps (gaps should be no larger than three -inches)." This Condition will alleviate or g nal condition 14 C. 9. Prior to issuance of the Land Use Change Permit, the Applicant shall provide specifications and details for the proposed liners and leak detection systems of the ponds for review and determination of sufficiency by Mountain Cross Engineering. Staff Comment: No additional information has been provided on this issue therefore Staff continues to recommend that this condition be incorporated into the approval of this facility. 10. Prior to issuance of the Land Use Change Permit, the Applicant shall provide a Drainage and Erosion Control Plan that includes all area within the 21,47 -acre site and the plan reviewed for sufficiency by Mountain Cross Engineering. Staff Comment: A Reclamation and Erosion Control Plan was submitted, EXHIBIT V3. The report has not been signed nor stamped by the preparing engineer. Mountain Cross Engineering has reviewed the Plan and provided comments, Exhibit Z: 1. The erosion control and drainage plans that were included are still lacking sufficient detail to determine how site runoff is directed into the existing ponds 2. The erosion control plan needs additional BMPs in areas of concentrated flow. Staff recommends amending the condition to the following: 5J Board of County Commissioners January 20, 2014,.continued from December 16, 2013 LIPA7675 "Prior to issuance of the Land Use Change Permit, the Applicant shall provide a Drainage and Erosion Control Plan that includes analysis of the 21.47 -acre project area including sufficient detail to determine how site runoff is directed on the site and includes additional BMPs in areas of concentrated flow. This plan shall be reviewed for sufficiency by Mountain Cross Engineering." Steve Anthony, Garfield County Vegetation Manager, has reviewed this supplemental documentation, Exhibit AA, as well and commented that revegetation security will be required once sufficient information is provided regarding the amount of disturbance required based for site improvements. Security associated with proposed revegetation of improvements shall be calculated at $2,500.00 per acre. This is now Condition 12. Mr. Anthony also recommends that a Soil Plan be submitted regarding topsoil stockpiles that may be exposed for longer than ninety days. This plan would include management/prevention of weeds as well as to determine that necessary erosion control measures are in place for the stockpiles. This is now Condition 13. 11. Prior to issuance of the Land Use Change Permit, the Applicant shall provide a revision to site grading and drainage plan that clearly shows how the water will drain around the water impoundments and storage areas. This should include Best Management Practices to ensure positive drainage of the site. Staff Comment: A Final Drainage Report was submitted which appears to indicate that stormwater from the site currently flows into the production ponds. Typically stormwater is detained, treated and released, however in this instance the stormwater is captured by the ponds and becomes part of the reuse of the fluids in the impoundments. Staff has reviewed Section 7- 204 (C) which presumes that that detention, treatment and discharge is required to manage runoff from a site — in this instance there would be no discharge of storm water if it is diverted into the produced water impoundments. It does appear that from the Report that a Retention Pond is planned to detain, treat and release stormwater at the site however this results in two issues: first, that no retention pond specifications were provided for engineering review nor was the retention pond located on the site plan; and second, that overflow from the retention pond is proposed to overflow to the existing impoundments. The original condition required provision of a plan that clearly shows how the water will drain around the impoundments and storage areas and this has not been resolved by the information submitted. Chris Hale, Mountain Cross Engineering, reviewed the additional information and provides the following comments, Exhibit Z: 1. The drainage report has intensities that were used for calculation of runoff. The Applicant should provide documentation on the source of the intensities. 2. The drainage plan doesn't show that grading will convey water into the ponds. 3. It reads from the report as if the ponds will be pumped to release water. This operation needs to be described in greater detail. Board of County Commissioners January 20, 2014, continued from December 16, 2013 LI PA7675 4. Similarly, to the above, the Applicant should describe how the levels in these ponds will be monitored and managed concerning items such as active water level, precipitation, freeboard, overflow level, etc. At our meeting on January 13, 2014 OXY stated that it is not their intent to allow stormwater to be detained in the produced water impoundments nor was a retention pond proposed to be located on the site. It appears that additional study of this issue needs to occur in order for Staff to be assured that sufficient stormwater controls will be constructed for this project. Staff recommends amending the condition: "Prior to issuance of the Land Use Change Permit, the Applicant shall provide a signed and stamped Drainage Report prepared by an engineer that satisfies the requirements of Section 7- 204 of the 2013 Land Use and Development Code and includes documentation on the source of the runoff calculation intensities as well plans indicating how water will drain around the impoundments and storage areas (including grading plans). The Applicant shall provide information related to how the levels in the ponds will be monitored and management concerning items such as active water level, precipitation, freeboard, overflow level, etc. This information, once submitted shall be reviewed by Mountain Cross Engineering for compliance with code standards and BMP's." 12. Prior to issuance of the Land Use Change Permit, the Applicant shall provide a noise analysis that demonstrates the site is compliant with the COGCC Noise Standards/Regulations. Staff Comment: OXY has satisfied this condition with provision of a noise analysis, EXHIBIT 5, that identifies the noise level from the generator at 64.7 Db(A) at 35 feet from the source. This meets the nighttime light industrial noise level (the most restrictive requirement). This condition has been removed. 13. Prior to issuance of the Land Use Change Permit, the Applicant shall provide copies of all current air quality permits from CDPHE. Any future or amended permits shall be provided to the County upon issuance by the CDPHE. Staff Comment: OXY requests that this condition be amended due to the fact that the ponds, generators and production tanks are exempt from CDPHE permit requirements for air quality. Staff has amended the condition as follows: "Any future air quality permits for this facility shall be provided to the County upon issuance by CDPHE." This is now Condition 15. 14. Prior to issuance of the Land Use Change Permit, the Applicant shall comply with the following recommendations from the Colorado Department of Parks and Wildlife (CPW): Staff Comment: OXY seeks removal of the requirement to satisfy these requirements prior to issuance of the LUCP and Staff has instead included language in specific items below when this requirement is necessary and therefore recommended. Amendment to the language above: Board of County Commissioners January 20, 2014, continued from December 16, 2013 LIPA7675 "The Applicant shall comply with the following recommendations regarding protection of wildlife:" A. Night Lighting should be of the full -cutoff type and/or timed or otherwise minimized to reduce disruption to wildlife. Staff Comment: OXY agrees to this condition. B. Bear -proof trash containers should be utilized at work -site locations and workers should be advised not to feed bears. Staff Comment: CPW has amended this recommendation: "The proposed location lies within year-round black bear habitat where human/bear conflicts have previously occurred. There is potential for human/bear conflicts with gas exploration employees who are working and/or camping in these areas during development operations. The potential for human/bear conflicts within these project areas would be greatly reduced by placing and utilizing "bear proof" trash containers at work-site/camping locations. Furthermore, workers affiliated with these projects should be advised not to feed the bears, whether intentional or not, since this activity is a violation of Colorado Parks and Wildlife Commission Regulations and is detrimental to wild bears. CPW has information on the design and purchase of "bear proof' trash containers and will provide this information to anyone who is interested in preventing conflicts with bears." The intent of the staff recommended condition appears to satisfy the CPW recommendation with the following amendment: "The Applicant shall install bear -proof trash containers at this facility and workers shall be advised that feeding bears is a prohibited activity." C. Fencing should consist of a minimum 7 -foot high chain-link fence with a mesh type of fencing along the bottom (buried one -foot below grade level and extending a minimum of two -feet above grade) capable of preventing small animals from entering between the gaps (gaps should be no larger than three -inches), Staff Comment: OXY requests that this condition be amended to allow for construction of the mesh fencing at some future time after issuance of the LUCP from the County. Staffs issue is with assurance of construction of this improvement. Staff recommends modifying the condition and combining it with the requirement to obtain a building permit. This will assure that the necessary improvements are completed pursuant to the CPW recommendation. This is now condition 8. D. The pits shall be constructed with a 4:1 slope escape ramp with chain-link fencing in one corner of the pit to allow entrapped wildlife to escape. Staff Comment: OXY agrees to this condition which is now 14 C. Board of County Commissioners January 20, 2014, continued from December 16, 2013 LI PA767 5 E. The pit shall be adequately netted to ensure that waterfowl and other birds are prevented from entering. Staff Comment: CPW recommends that this condition be amended as follows: "The wastewater pit(s) should be adequately protected to ensure that waterfowl and other birds are prevented — excluded -- frorn entering or coming in contact with water in the pit(s). Adequate protection may include netting (preferred by CPW and USFWS), RADAR triggering noise deterrents, floating cover, or other device that is a demonstrably proven method of avian deterrent. Unacceptable methods including flagging, floating 4 inch hollow plastic balls, decoy predators, or other sight deterrents, reflectors, strobe lights, or zon guns (sonic blast). See the USFW web page for additional guidance at http:J/www.fws.gove/rnountain- praIrie/fontamIndnts/contaminantslc.html" This is now Condition 14 D. Staff recommends that the language above be incorporated as the revision to this condition which is now 14 D. F. No construction activity shall occur during the time period from March 1 through June 30 to minimize impacts to sage -grouse production areas. Staff Comment: CPW discussions with the Applicant have resulted m an amended recommendation from CPW regarding activity that occurs during the sage -grouse production timeframe. CPW's revision to this condition: "Construction activities (on a daily basis, continuous, intermittent loud noise) such as heavy equipment operations (backhoes, bulldozers, generator, and heavy trucks) and or intensive human activities should occur outside of the time period from March 1 to June 30 to minimize impacts to greater sage -grouse production areas. Construction activities include earth moving and or pit liner removal or installation." Staff recommends that this language be incorporated as a condition of approval which is now Condition 14 E. 15. Prior to issuance of the Land Use Change Permit, the Applicant shall install anti -perching devices on all structures within the facility, including fences, to prevent predators from preying on small animals and Greater -Sage Grouse. Staff Comment: Staff had a discussion with Michael Warren, CPW NW District Energy Liaison, regarding the intent of this issue. It appears that CPW does not recommend this requirement in particular areas of the state due to the vegetation characteristics which, on the Piceance, renders this requirement unnecessary. Mr. Warren also stated that most of the sage grouse predators, raptors in particular, do not perch. This condition has been removed. Other 16. CPW shall be notified immediately if any birds and/or wildlife are found dead or trapped within or around the pit, netting, or fences. Staff Comment: OXY agrees to this condition which is now 14 F. Board of County Commissioners January 20, 2014, continued from December 16, 2013 LIPA7675 17. The applicant shall conduct on-site weed inventory in the spring or early summer of 2014 and provide the information to the County Vegetation Manager by June 30, 2014. Staff Comment: OXY agrees to this condition which is now condition 16. Additional conditions based upon supplemental review: 18. Additional recommendations were made by CPW and include: A. Following the completion of construction activities, newly exposed soils should be revegetated as soon as possible to prevent erosion and to reduce the likelihood of non-native plants becoming established in the area. Seed mix used for revegetation should be certified as weed -free and consist of native seeds from plants that are common to the area. This is now Condition 14 G. B. To reduce the likelihood of truck — wildlife collisions, proper speed limits (25 mph) should be posted and enforced on all service roads. Staff Comment: Staff recommends incorporation of these comments as conditions of approval. This is now Condition 14 H. III. STAFF DISCUSSION The Applicant has submitted documentation which has been reviewed. Despite the additional information provided there is insufficient information to complete a comprehensive review of the project. There continues to be outstanding issues on erosion, drainage, stormwater, grading and traffic analysis that need to be resolved. Should the Board seek to move forward at this time Staff has incorporated conditions that may allow for adequate findings to approve the project. IV. FINDINGS 1. That proper public notice was provided as required for the hearing before the Board of County Commissioners. That the hearing before the Board of County Commissioners was extensive and complete, that all pertinent facts, matters and issues were submitted or could be submitted and that all interested parties were heard at that meeting. 3. That for the above stated and other reasons and upon compliance with the conditions of approval, the Land Use Change Permit for the Water Impoundments and Storage is in the best interest of the health, safety, convenience, order, prosperity and welfare of the citizens of Garfield County. 4. That, upon compliance with the conditions of approval and the waivers granted, the application has 101 Board of County Commissioners January 20, 2014, continued from December 16, 2013 LI PA7675 adequately demonstrated that the proposed Facility is compliant with the minimum standards and regulations required by the Garfield County 2013 Land Use and Development Code. 5. That, upon compliance with the conditions of approval and the waivers granted, the application is generally consistent with the Garfield County Comprehensive Plan 2030, as amended. V. BOARD OF COUNTY COMMISSIONERS DELIBERATION AND DECISION Should the Board seek to approve the application for OXY's Pond 13 E/W Water impoundment and Storage, Staff provides the following conditions as amended based upon this report: 1. That all representations made by the Applicant in the application and public hearing shall be conditions of approval, unless specifically altered by the Board of County Commissioners. 2. That the facility shall operate in compliance with all applicable Federal, State, and local regulations governing the operation of this type of facility. 3. The land use change permit is for two water impoundments, 13E and 13W, not to exceed 3.3 -acres in size and storage capacity not to exceed 121,480 Barrels of produced water. In addition, the 21.47 -acre project area is approved for two storage facilities as indicated on the approved site plan for a total area of 3.03 -acres. No hazardous material or fuel storage is permitted within the facility. Prior to Issuance of the LUCP 4. Prior to issuance of the Land Use Change Permit, the Applicant shall provide a supplement to the Traffic Analysis utilizing the 2011 Road & Bridge Traffic Counts and updating the report as appropriate to include traffic generated by the storage areas. The supplement shall include a finding consistent with the current study that no additional traffic improvements are recommended or provide specific recommendations that the Applicant shall be required to comply with subject to review by the County's Consulting Engineer. 5. Prior to issuance of the Land Use Change Permit, the Applicant shall provide written confirmation that all pipelines serving the facility have been properly permitted or are exempt from permitting requirements. 6. Prior to issuance of the Land Use Change Permit, the Applicant shall provide copies of the well permits related to the three monitoring wells for the site. 7. Prior to issuance of the Land Use Change Permit, the Applicant shall provide a statement by a qualified professional or representative of the Applicant confirming the adequacy of the access road to serve the site. A waiver from Article 7, Roadway Standards is approved pursuant to the approval criteria contained in Section 4-118 of the Land Use and Development Code, subject to compliance with the above requirement. 8. Prior to issuance of the Land Use Change Permit, the Applicant shall obtain the proper building permits for structures on the site, including existing/proposed fencing that shall consist of a Board of County Commissioners January 20, 2014, continued from December 16, 2013 LI PA7675 minimum of a 7 -foot chain-link fence capable of preventing elk and deer from entering the pit; concurrently it should have a small mesh type of fencing along the bottom of the fence (buried on - foot below grade level and extending a minimum of two -feet above grade capable of preventing small animals from entering between the gaps (gaps should be no larger than three -inches). 9. Prior to issuance of the Land Use Change Permit, the Applicant shall provide specifications and details for the proposed liners and leak detection systems of the ponds for review and determination of sufficiency by Mountain Cross Engineering. 10. Prior to issuance of the Land Use Change Permit, the Applicant shall provide a Drainage and Erosion Control Plan that includes analyzes the 21.47 -acre project area including sufficient detail to determine how site runoff is directed on the site and includes additional BMPs in areas of concentrated flow. This plan shall be reviewed for sufficiency by Mountain Cross Engineering. 11. Prior to issuance of the land Use Change Permit, the Applicant shall provide a signed and stamped Drainage Report prepared by an engineer that satisfies the requirements of Section 7-204 of the 2013 Land Use and Development Code and includes documentation on the source of the runoff calculation intensities as well plans indicating how water will drain around the impoundments and storage areas (including grading plans). The Applicant shall provide information related to how the levels in the ponds will be monitored and management concerning items such as active water level, precipitation, freeboard, overflow level, etc. This information, once submitted shall be reviewed by Mountain Cross Engineering for compliance with code standards and BMP's. 12. Prior to issuance of the Land Use Change Permit the Applicant shall provide information regarding total amount of site disturbance related to proposed improvements and provide a revegetation security based upon $2,500.00 per acre of revegetated area if the amount of disturbance is greater than one-half (1/2) acre. 13. Prior to issuance of the Land Use Change Permit the Applicant shall provide a Soil Plan that provides for soil cover if any topsoil stockpiles will site exposed for a period of ninety days or longer. Wildlife Conditions 14. The Applicant shall comply with the following recommendations regarding protection of wildlife: A. Night Lighting should be of the full -cutoff type and/or timed or otherwise minimized to reduce disruption to wildlife. B. The Applicant shall install bear -proof trash containers at this facility and workers shall be advised that feeding bears is a prohibited activity. C. The wastewater pit(s) should be adequately protected to ensure that waterfowl and other birds are prevented — excluded — from entering or coming in contact with water in the pit(s). Adequate protection may include netting (preferred by CPW and USFWS), RADAR triggering noise deterrents, floating cover, or other device that is a demonstrably proven method of avian deterrent. Unacceptable methods including flagging, floating 4 inch hollow plastic balls, decoy predators, or other sight deterrents, reflectors, strobe lights, or zon guns (sonic blast). See the USFW web page for additional guidance at http://www,fws.gove/mountain- pra i rielfon tam i na nts/con to m i na nts l e. html 12 Board of County Commissioners January 20, 2014, continued from December 16, 2013 LIPA7675 D. Construction activities (on a daily basis, continuous, intermittent loud noise) such as heavy equipment operations (backhoes, bulldozers, generator, and heavy trucks) and or intensive human activities should occur outside of the time period from March 1 to June 30 to minimize impacts to greater sage -grouse production areas. Construction activities include earth moving and or pit liner removal or installation. E. CPW shall be notified immediately if any birds and/or wildlife are found dead or trapped within or around the pit, netting, or fences. F. Following the completion of construction activities, newly exposed soils should be revegetated as soon as possible to prevent erosion and to reduce the likelihood of non-native plants becoming established in the area. Seed mix used for revegetation should be certified as weed - free and consist of native seeds from plants that are common to the area. G. To reduce the likelihood of truck — wildlife collisions, proper speed limits (<25 mph) should be posted and enforced on all service roads. Other 15. Any future air quality permits for this facility shall be provided to the County upon issuance by CDPHE. 16. The applicant shall conduct on-site weed inventory in the spring or early summer of 2014 and provide the information to the County Vegetation Manager by June 30, 2014.. 131 M Lu M w F.- Q N D Z 0 O I— ca. v) >- o ><z O EXHIBIT A& N 0 N 0 N 0 C 0 --, V 0 0 CO continued from December 16, 2013 PROJECT SUMMARY Land Use Change Permit requested for two existing water impoundments and proposed storage areas Public hearing on December 1 6th was continued to review additional information submitted by the Applicant at the hearing, and to resolve outstanding issues regarding compliance with the LUDC E Additional information was submitted and Staff met with the Applicant to discuss proposed conditions of approval Proposed Conditions General Conditions That all representations made by the Applicant in the application and public hearing shall be conditions of approval, unless specifically altered by the Board of County Commissioners. That the facility shall operate in compliance with all applicable Federal, State, and local regulations governing the operation of this type of facility. The land use change permit is for two water impoundments, 1 3E and 1 3W, not to exceed 3.3 -acres in size and storage capacity not to exceed 121,480 Barrels of produced water. In addition, the 21 .47 -acre project area is approved for two storage facilities as indicated on the approved site plan for a total area of 3.03 -acres. No hazardous material or fuel storage is permitted within the facility. The Applicant agrees to these conditions Proposed Conditions ?. Prior to issuance of the Land Use Change Permit, the Applicant shall provide a supplement to the Traffic Analysis utilizing the 2011 Road & Bridge Traffic Counts and updating the report as appropriate to include traffic generated by the storage areas. The supplement shall include a finding consistent with the current study that no additional traffic improvements are recommended or provide specific recommendations that the Applicant shall be required to comply with subject to review by the County's Consulting Engineer. The Application provided a revision to the Traffic Analysis however updated numbers are required as well as justification for a zero traffic generation from the proposed storage. Prior to issuance of the Land Use Change Permit, the Applicant shall provide written confirmation that all pipelines serving the facility have been properly permitted or are exempt from permitting requirements. The Applicant provided three (3) grading permit numbers however this did not satisfy the requirement to demonstrate that all necessary permits had been obtained. This would require an affidavit or information regarding the length and diameter of the pipelines serving the project. c . Prior to issuance of the Land Use Change Permit, the Applicant shall provide copies of the well permits related to the three monitoring wells for the site. The Applicant requested that this condition require submittal of permits at a later date, however Staff continues to recommend that these permits be submitted prior to issuance of the Land Use Change Permit due to the fact that the permits demonstrate compliance with Section 7-102, adequate legal and physical water, and Sections 7-203 and 7-205 regarding protection of water quality. Proposed Conditions 7. Prior to issuance of the Land Use Change Permit, the Applicant shall provide a statement by a qualified professional or representative of the Applicant confirming the adequacy of the access road to serve the site. A waiver from Article 7, Roadway Standards is approved pursuant to the approval criteria contained in Section 4-1 1 8 of the Land Use and Development Code, subject to compliance with the above requirement. The Applicant seeks an overall waiver of the road standards in Section 7-107 rather than provide the documentation necessary to demonstrate that adequate access exists to the site. Specific sections of the road that do not meet the standards may be acceptable, however an overall granting of waiver does not demonstrate that the roads are safe or that adequate capacity exists to serve the site. 8. Prior to issuance of the Land Use Change Permit, the Applicant shall obtain the proper building permits for structures on the site, including existing/proposed fencing that shall consist of a minimum of a 7 -foot chain-link fence capable of preventing elk and deer from entering the pit; concurrently it should have a small mesh type of fencing along the bottom of the fence (buried on -foot below grade level and extending a minimum of two -feet above grade capable of preventing small animals from entering between the gaps (gaps should be no larger than three -inches). This condition has been amended to include the CPW specifications for fencing. 9. Prior to issuance of the Land Use Change Permit, the Applicant shall provide specifications and details for the proposed liners and leak detection systems of the ponds for review and determination of sufficiency by Mountain Cross Engineering. No information has been provided on these issues. Demonstration of compliance with Sections 7.- 204 and 7-205 cannot occur without this information. Proposed Conditions 1 0. Prior to issuance of the Land Use Change Permit, the Applicant shall provide a Drainage and Erosion Control Plan that includes analyzes the 21.47 -acre project area including sufficient detail to determine how site runoff is directed on the site and includes additional BMPs in areas of concentrated flow. This plan shall be reviewed for sufficiency by Mountain Cross Engineering. Additional information has been provided however it remains insufficient to demonstrate compliance with minimum County standards. Additional detail was added to this condition based upon comments from Mountain Cross Engineering. 11. Prior to issuance of the Land Use Change Permit, the Applicant shall provide a signed and stamped Drainage Report prepared by an engineer that satisfies the requirements of Section 7-204 of the 2013 Land Use and Development Code and includes documentation on the source of the runoff calculation intensities as well plans indicating how water will drain around the impoundments and storage areas (including grading plans). The Applicant shall provide information related to how the levels in the ponds will be monitored and management concerning items such as active water level, precipitation, freeboard, overflow level, etc. This information, once submitted shall be reviewed by Mountain Cross Engineering for compliance with code standards and BMP's. Additional information has been submitted, however that information appears to state that stormwater is diverted to, and detained in, the production ponds. This is not permitted by State Statute therefore revisions to the plan are required. OXY has stated that stormwater is not proposed to be detained in the production ponds. Proposed Conditions 1 2. Prior to issuance of the Land Use Change Permit the Applicant shall provide information regarding total amount of site disturbance related to proposed improvements and provide a revegetation security based upon $2,500.00 per acre of revegetated area if the amount of disturbance is greater than one-half (1/2) acre. 1 3 Prior to issuance of the Land Use Change Permit the Applicant shall provide a Soil Plan that provides for soil cover if any topsoil stockpiles will site exposed for a period of ninety days or longer. Steve Anthony reviewed and commented on the supplemental materials and determined that proposed improvements will result in site disturbance and topsoil stockpiles. Revegetation of the site is required, along with provision of security to assure completion. Site disturbance requires provision of a Soil Plan. These items are related to construction disturbance which is required to be revegetated, but not to overall site reclamation. Wildlife Conditions i The Applicant shall comply with the following recommendations regarding protection of wildlife: . Night Lighting should be of the full -cutoff type and/or timed or otherwise minimized to reduce disruption to wildlife. Proposed Conditions B. The Applicant shall install bear -proof trash containers at this facility and workers shall be advised that feeding bears is a prohibited activity. Items A & B appear to be acceptable to the Applicant. C. The wastewater pit(s) should be adequately protected to ensure that waterfowl and other birds are prevented — excluded — from entering or coming in contact with water in the pit(s). Adequate protection may include netting (preferred by CPW and USFWS), RADAR triggering noise deterrents, floating cover, or other device that is a demonstrably proven method of avian deterrent. Unacceptable methods including flagging, floating 4 inch hollow plastic balls, decoy predators, or other sight deterrents, reflectors, strobe lights, or zon guns (sonic blast). See the USFW web page for additional guidance at http:, ;: wv,.v .i ,r .gove/n ouni :, prairie, 'orucnlir1an1Si COltaill1r1on1i5I C.il'Iill . The Applicant stated that they were unaware that CPW had these requirements for impoundments, but that this condition provides sufficient options for OXY to achieve the goal of protecting avian species. D. Construction activities (on a daily basis, continuous, intermittent loud noise) such as heavy equipment operations (backhoes, bulldozers, generator, and heavy trucks) and or intensive human activities should occur outside of the time period from March 1 to June 30 to minimize impacts to greater sage -grouse production areas. Construction activities include earth moving and or pit liner removal or installation. Proposed Conditions CPW shall be notified immediately if any birds and/or wildlife are found dead or trapped within or around the pit, netting, or fences. The Applicant appears to be in agreement with both D. and F. F. Following the completion of construction activities, newly exposed soils should be revegetated as soon as possible to prevent erosion and to reduce the likelihood of non-native plants becoming established in the area. Seed mix used for revegetation should be certified as weed -free and consist of native seeds from plants that are common to the area. G. To reduce the likelihood of truck — wildlife collisions, proper speed limits (<25 mph) should be posted and enforced on all service roads. These are new recommendations from CPW and it appears that the Applicant agrees to these conditions. 1 5. Any future air quality permits for this facility shall be provided to the County upon issuance by CDPHE. This condition was amended to require submittal of any permits or amendments upon issuance by CDPHE. The Applicant agrees to this condition. 16. The applicant shall conduct on-site weed inventory in the spring or early summer of 2014 and provide the information to the County Vegetation Manager by June 30, 2014. The Applicant agrees to this condition. 0 • 2 • rte' 0 Consideration 0 m