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HomeMy WebLinkAbout25 BOCC Staff Report 12.16.2013Board of County Commissioners, December 16, 2013 Public Hearing Exhibits — OXY Pond 13 E/W 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 I 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. d 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: Wildlife Comments R Conditions of Approval S Sound Analysis T U Ad Name: 9698196A Customer: Olsson Associates Your account number is: 1006467 PROOF OF PUBLICATION THE RIFLE CITIZEN TELE6RAM STATE OF COLORADO,. COUNTY OF GARF'IELD 1, Jim Morgan, do solemnly swear that 1 am General Manager of The Rhe 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 ofevery 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 11/14/2013 and that the last publication of said notice was dated 11/14/2013 the issue of said newspaper. In witness whereof, I 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 11/1912013. My Commission Expires 11101!2015 Pamela !. Schultz, Notaryublic My Commission expires: November 1, 2015 PUBLIC Nt1TE TAKE NOTICE that OXY USA WTP LP, hoe sp- oked to the Board of County Commissioners. Gar - Veld County. Susie 0f Colorado, to requital approv- al lar a Land Use Change Permit an a property situated in the County of 0arliele, State ofColo- rado: to-wa. Legbl Dezavtloji: Sdetbn: 4 township: 6 Range: 97 SEC.3 LOTS 6,7,3,8,10,11,14,15,16,.. SW SEC. 4 LOTS 10,11,12.13,14.15. SE. El/2SW. Praceca1 Qelswreson- approYlntatety 15 mesa north soue g ff ot Courtly s Conn (Creek R ). 204(al- so in the NE 114 SE 114 Section f, TSS, R97W and is pan el a properly known by Assessor's Parcel No. 2169.044.00-003. r rate, oasenoh� Thee as a Limited Impact Re• view for the conversion of an errtINng facility to Water Impoundments known as the Pond 13 EM Centralized E&P Waste Management Faclhly. Flelaled Material Handling and Storage areas ere proposed for the mite adjacent to the panda.. also. Thesill is approximately 21.47 scree In size and is located on an overall property of approximately 640 acres. The Pr0peny is zoned Resource Lands - Plateau The Applicant's 001/31111110 rapreaanla- lives are Daniel Padilla. OXY USA WTP LP, Jell Holman and Mann Asaoaalee, All parson" aflecced by Me proposed plan are Invit- ed to appear ant/elate their views. protest or sup• port. If you can not appear pereonatly at such healing. then you are urged testate your views by letter, as the Boma of County Commissionors wall give considerationto the comments of surrounding property owners, and others affected, In deciding whether to grant or deny the request- The applica- tion may be reviewed at the olfice of the Planning Department located at 106 Bth Siroel, Suite 401. Garfield County Plaza Building. Glenwood Springs, Colorado between the hours of 630 a.m. and 5:00 p.m., Monday &trough Friday. A public issuing on the application has bean scheduled tor Monday, December 16, 2613 at 1.00 P.M, In the Counl,y Commies -loners Meering Roam. Garfield County Admin.strellan 'Building, 103 alit Street. Gfenwrod 0" 05. Colorado. Flertnng Department Garfield. County Published in Nle C.Izen Telegram November Id. 2013. (0696190) m .4 3.10 2.55 0.00 6.11 Chevron Texaco Property Tax 1 Chevron USA Inc PO Box 285 1 Houston, TX 77001 U.S. Postal Service CERTIFIED MAIL... RECEIPT (r7r)rlre':.rri: M1t,rrl Only: No lnsur,rncr^ i,nverdge Provided) rn ru ru r- ru D nl 0 0 ra 0 ru 4-4r- U.S. Postal Service', CERTIFIED MAIL;,^ RECEIPT (Dann stn' M.rrl 0 11y, Nu lrrsvr.7nee Coverage Provided) For d:Ilvcry IntormallVn vl.. I uur weUr:ilc .rr w•.w.uS rr1 p..r., Polo Card Fes MARA Moot Fos Modaismara Amami Plogdolad wyr A r~ 0 ru so T- ru 0 ru 0 0 0 0 0 ru rg 0 l.4 ail 0 ru so r- ru 0 na 0 0 0 0 0 rR ru r- TD Pal .b. a coo 1 .48 3.10 2.55 0.00 8.11 Donna Koehler PO Box 300 DeBeque, CO 81630 U.S. Post,rl Service .. CERTIFIED MAILRECEIPT ((urrv^.vh+: .1.r.I {]ally, Nr1 lrs^uu., ir+• CI 'I' Provided) Fr.r rh lrvary uoloon.riwo Fare. onMlyd F.. TnMl voom%Arnim .46 3.10 2.55 0.00 6.11 1 Colorado River Valley Field Office -t Bureau of Land Management 2300 River Frontage Rd I Silt, CO 81652 d U.S. Postal Service CERTIFIED MAIL RECEIPT (Uorrlesdr Med Only, No 1rll,:ur rxlcr Cur^crayr• Prover -led) I Of PlcL Vary rllrdrrl1l11mn +Orad Out w103:•il .d v. • .+ r,r ,...•r 1 G9.od.d P.. -- •Flastrkaai Dabney gym ihrol arra...,. A P.M JoJo Properties PO Box 1926 Rifle, CO 81 650 .46_ 3.10 2.55 0.00 8.11 0 rn 0 11.1 so r- ru 0 ru 0 A 0 0 U.S. Postai Service ^ CERTIFIED MAIL RECEIPT (Domestic Mail Only, No ln•,:.r;rnr'r r'nw•rayr Provided) Fox xli.l.Wrry lnforrrr.rtIUn w,11 our wr:b•,.rlc :11 vrww.0+..p..com Pard r.. Reim rocelsa Fes C:nd� uiment 46 3.10 2.55 0.00 6.11 ru r Richard, Lyle & Ned Prather a PO Box 165 P" ; DeBeque, CO 81630-0165 u'1 0 ru U.S. Postal Service CERTIFIED MAIL RECEIPT aharro-arc Marl 0n1y. Nr/ !n' I f.1nr:r_' Cir.^e^r;lrye Provldrrn f.•hv+^ry rr.Irllilydrllrll VISIT Cll+r r:arlr^..11 r' ^' ,'+'•'- +-r - rc,nr ru Poria. O WOW Fao ru (iniaromooFag r. CI PlasOlood Maori Fes rrl ru rg 0 r- nl cl^I+.nry Irdr1rl11.11rrxrr ural aur r^rr•1+^:110 UI W'W. u.rm.[bu1;. FOatiel COMM F.. Widailwriering111"1= O".a"r1mo lrrwr °wrr.ar 0 Trawl.11.01.... a c.... .46 3.10 2.55 0.00 6.11 Property Tax Department OXY USA INC a PO Box 27570 Houston, TX 77227-7570 CIL Board of County Commissioners December 16, 2013 LI PA7675 PROJECT INFORMATION TYPE OF REVIEW APPLICANT (OWNER) CONSULTANT LOCATIO N PROPERTY DATA ACCESS ZONING COMPREHENSIVE PLAN Limited Impact— Water Impoundment, Storag OXY USA WTP, LP — Daniel Padilla Jeff Holman — Olsson Associates EXHIBIT !-may 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 r 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 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 - and "Storage". Both material handling Board of County Commissioners December 16, 2013 LI PA7675 DETAIL "A" :r►41'NO' ;• /� 1 i S► • r tifAi .61 , 111.1110110 • • l lrL `;E;•1'I +. A—A -,MZ M•i' \ .RSM. + . ' , t; r + %'',471Z; 4.1=1144. 1 f- • r • • • • 444. • • •` r 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 R97W d*T VRK 111191. My 'ie +r.19* ___ *Ira ,nnae. w PIG Mesa Opera 'ss.***Mr 1A A.; :A;RAHe+w. c�a. 11 1 4. - 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. T6S-R97W *we Q`*mere .mere. we row;wa e.* A'- .*., ...l 2I Board of County Commissioners December 16, 2013 LI PA7675 'hutu 2. Luukrgit nurtlica. t truer app . airn.,ic crntcr i t (J }'end aura t 4.24 1 1 i The application states that water and sanitation are unnecessary due to the intermittent nature of employees on the site. iitr.tuh, ,.'..kin;, ni.rth frr+nn thhrrn hr•undary (if rhy P»nd 13 pr c arra +4 24.13t II. ADJACENT USES AND ZONING The site is located 23 miles north of Debeque in the NE % SE % of Section 4, T6S, 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. Board of County Commissioners December 16, 2013 LI PA7675 • tt r t \ r t\ -,r \ .. 5 � 4 \ Nok t tt t \ IsETAIL "A" +►a6L ■aa' { { t, nine CA4r-atIP ad. 14 WORM t { are mow anktrute nu*, I a• WAR 1.4ael ♦• ♦rarlta+1 f IM. �` AMP P O 411-7411.` -. /# w►Mit4 �A.+ ` et I _erg a /t I! .• .0.-...-.0 `' t • li. 0. • ti x \ % it iftei —' A • la • iC4_S ▪ r410.9 t 1 ;. SECTION A— scAtL __, o' loofstfetfma• I ma, h n 1 1 cak 40.43 1 • ca+t+w>rr 1 ANIMA t IX K*. I 1 -I 1 1 1 1 { 1 r 1 � 1 t � 1 4 Board of County Commissioners December 16, 2013 LI PA7675 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 Gil & 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 I 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. 51 Board of County Commissioners December 16, 2013 LIPA7675 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. Pond 13 ESN Complex SoLls Map Ma •s, .e:.x a :1.1 1N11; .rtf00,43313334 :1€ C1 : CS o : aM ' "-hm ` y/*- L%"1 SY.w Alp y312•11311.Jaw :Sfc•. FYTI a iea,llw 'ti... `r, s,+w•,c. •=1c 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, 6. 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 surficial 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, 61 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. Determination 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 an 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. • :.r14 ys4 Ar.J Rru r4.lry ,,; .42 +114 P' 101rty r+r11r1 f,.waw C+M14fJl HJl]Ri► 210240. 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. ERG Resources Corporation concluded that the site is poor habitat for the species which corresponded with the Garfield County Sage - Grouse Conservation Plan. 71 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 June 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 1. 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 C©GCC-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 81 Board of County Commissioners December 16, 2013 LI PA7675 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. Staff Comment: 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 LUDC. Several sections of the road are said to contain a 91 Board of County Commissioners December 16, 2013 L1PA7675 t11111111k rr.)XY IJS V1TP LP OXY -:, _. .... Pond 13 EMI Complex Traffic Volumes Map v * 4C Rw 1E .41: ,,r..6 A..'(} C , , ` } 1 _M-ra .reigooe f$,4! • AI r 1^ t . r, • bom s t� . ' • s...`_*, . rte. 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 least 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 existing roadway. 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 1, 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 10 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 I, and CPW identifies the site as being located within Greater Sage -Grouse production area and black bear year-round range. No Board of County Commissioners December 16, 2013 LIPA7675 significant impacts to wildlife are 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 all 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. 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. 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. 121 Board of County Commissioners December 16, 2013 LIPA7675 SECTION 7-204 DRAINAGE AND EROSION. A. Erosion and Sedimentation. B. Drainage C. Stormwater Run -Off. D. Culverts, drainage pipes, and bridges shall be designed and constructed in compliance with AASHTO 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 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 leaks 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. 14I 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 all 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 an 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 IS I 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.R.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 ground vibration inherently and recurrently generated is not perceptible without instruments at any point 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. 1.61 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. 17 Board of County Commissioners December 16, 2013 LIPA7675 e-0'�.�* 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 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. 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. is 1 Board of County Commissioners December 16, 2013 LIPA7675 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 19 1 Board of County Commissioners December 16, 2013 LIPA7675 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 Change 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 timed 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. 20 1 Board of County Commissioners December 16, 2013 LCPA7675 Other 16. CPW shall be notified immediately if any birds andror 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. From: Kirov Wynn To: Kaffir A Eastle% Subjtct: Relerali: L PA7675 Oxy central water Gatti Friday, November 15, 2013 8:46:27 AM EXHIBIT Hi Kathy, Gave it a look. I have no comments on this application. --Kirby Kirby Wynn 011 and Gas Liaison Community Development o (970) 625-5905 c (970) 987-2557 kwvnnt' garfield-county.com Garfield County From: tiILk Mar'.: To: Kj4r,,A. Easlit2 Subject Oxy pond 13 ENV Date: Friday, November 15, 2013 8:21:38 AM EXHIBIT I see no problem with having this pond converted. It should be benificial in reducing transportation of hazzardous material. Nick Marx DeBeque Fire Chief COLORADO PARKS & WILDLIFE EXHIBIT T 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 8`h Street, Suite 401 Glenwood Springs, CO 81601 RE: Oxy Pond 13 E/W Centralized E&P Waste Management Facility Dear Ms, Eastley: 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' 4 of the SE s-4 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 area 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 humanibear 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 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. STATE OF COLORADO John W. liickenlooper, Governor • Mike Kong, Executive Director, Department of Natural Resources Steven M Yamashita, Acting Director, Colorado Parks and Wildlife Parks and Wildlife Commission: Robert W Bray • Chris Castilian • Jeanne Horne Bill Kane, Vice -Chair • Gaspar Perricone • James Pr byt • John Singletary, Chair Mark Smith, Secretary • James Vigil • Dean Wingfretd • Michelle Timmerman Ex Officio Members. Mike King and John Salazar • 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 andlor 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 Komatinsky, Land Use Specialist Fife From: To: Subject: Oxy Pond 13 E/W LIR Referral Date: Wednesday, November 27, 2013 4:05:56 PM Hi Kathy, EXHIBIT 7 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 Air Pollution Control Division as mentioned in the fetter 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. The applicant should pay close attention to the leak detection units mentioned in the application that will be utilized on the centralizedproduced water impoundments. Leak detection should also be a priority 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. 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 Thanksgiving! Mo gaN Niii Environmental Health Specialist II Garfield County Public Health 195 W. 14th Street Rifle, CO 81650 Phone; 19701665-6383 Email: mhill@garfield-county.com www.garfield-county.com/environmental-health From: Wyatt Keesbenr To: Kathy A Easdey Subject: Oxy Pond 13 E(W Date: Monday, December 02, 2013 10:25:04 AM Kathy, EXHIBIT Road and Bridge has no exceptions to Oxy USA request to convert 2 existing ponds to a centralized impoundment area. wyatt Wyatt Ke rely, Gn licld County Ro;Lcl & 1i k1.4t- District 'Foreman 0298 C.R. 333A Rifle, Co. ) 81650 Office: 970.623-8601 Cell: 970-,3U94;073 December 3, 2013 Ms. Kathy Eastley Garfield County Planning 108 8t1i Street, Suite 401 Glenwood Springs, CO 81601 MOUNTAIN CROSS ENGINEERING, INC. Civil and Environmental Co RE: Review of OXY USA WTP LP Pond 13 EJW: LIPA-7675 Dear Kathy: 1 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 sound as if it will also be a contractorlstorage 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 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 are adequate to convey the anticipated storm flows around and through the site. Calculations would be 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 BMPs. Some minor 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. 826 1/4 Grand Avenue, Glenwood Springs, 00 81601 P: 970.945.5544 F: 970.945.5558 www.mountaincr-oss-eng.com Pond 13 EIW Page 2 of 2 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 are not include, an amended analysis should be prepared to include them. Feel free to call if you have any questions or comments. Sincerely, Mountain Cross Engine rii Chris Hale, PE g. Inc. Mountain Cross Engineering. Inc. Civil and Environmental Consulting and Design 826'/, Grand Avenue, Glenwood Springs, CO 81601 P: 970.945.5544 F: 970.945.5558 www.mountaincross-eng.00m December 6, 2013 1 Garfield County Kathy Eastley Garfield County Community Development Department RE Oxy Pond 13 ENV, File # LIPA 7675 Dear Kathy, Thanks for the opportunity to comment Noxious Weeds Vegetations ManaL'etnent 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 this 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, 7 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 O\oLssoN ASSOCIATES December 6, 2013 Kathy Eastley, AICP Senior Planner Garfield County Community Development 108 8th Street, #401 Glenwood Springs, CO 81601 keastiey@garfield-county.com EXHIBFT Re: OXY USA WTP LP Pond 13 EIW, LIPA 7675 Dear Ms. Eastley: This letter is in response to Morgan Hill'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 for a 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 an 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: a 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 970.263.7800 Grand Junction, Co 81506 FAX 970.263.7456 www.olssonassociates.com OXY USA WTP LP Pond 13 E/W, L1PA 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 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.- Additionally, torm.- 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. a 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. a 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 CDPHE 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 'E/W, 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 minirnal 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 Marge 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 Comments Page 3 1y 4 Y n 3 1 1 n 1 A ti 1 1 n i a 1 9 1 1 1 4111.– 'moi , rr•ur rrr.,.. ,,A 0 .sAPI L "...."..••41.A.10 VIAL EMO 1 Mil!ig _�.."01...4.......".. MOW— AS NOTED 11 r:. • r (1 1.0 — iiigigvaii m P +s-cursreuceroo a uc. Mcw, I ,i1 , r! 5 m, ft0 1 I!1y 1y 4 Y n 3 1 1 n 1 A ti 1 1 n i a 1 9 1 1 1 4111.– 'moi , rr•ur rrr.,.. ,,A 0 .sAPI L "...."..••41.A.10 VIAL EMO 1 Mil!ig _�.."01...4.......".. MOW— AS NOTED 11 r:. • r (1 roRVAM w — m P +s-cursreuceroo a uc. Mcw, ^��r3 a r! 5 m, ft0 1 I!1y AsniiiiIt: 1 1y 4 Y n 3 1 1 n 1 A ti 1 1 n i a 1 9 1 1 1 4111.– 'moi , OXT IAA WV. I.TP w WATER STORAGE PFT intrw.rw.esm n4rw 1311-AlONT coH AMMO.. • ne ul TA NTS, INC, ULT "...."..••41.A.10 VIAL EMO WATER STORAGE PPT - LOCATION B AS -CONSTRUCTED VOLUMES _�.."01...4.......".. MOW— AS NOTED sr r:. • r xs-caaaMurim ez roRVAM w — m P +s-cursreuceroo a uc. Mcw, ^��r3 FQRM 15 Rev MO IlliI1'iIT�111'�1111iI State of Colorado Oil and Ras Conservation Commission 1120 uncotn Sansei. Suits 501, Denver, Corrado 802031303}894.2100 Fax 13031894.2lC9 RECEIVED NOV o 3 Me COGCC EARTHEN PIT REPORT/PERMIT This form Is to be used for both reporting and permitting pits. Rule 903 describes when a Permit with prior approval, or a Report within 30 days, is required for pits Submit required attachments and forms. FORM SUBMITTED FOR: OPit Report pPlt Permit OGCC Operator Number: seen Name of Operator: OXY USA WTP LP Address P O. 904 277V City Houston Stay TX Zi: 77227.7557 Contact Nam? and Telephone. Daniel Pedal No. 0701 283.3837 Fp. (97012432525 API Number lot associated well". 06446'10M OGCC Feplity ID (of other essoci Isla fecrlity) FOF OGCC USE ONLY Complete the Attachment Checklist Oona OGc_C Oaladod Sita Pun Taco Map x7 PX Laawta+ Woo, +1nayW. IPSrm Pel Souza W•118 (Fpm 391 ibeirlryn Calculations Ser=at.. Ansa Dawnm. Mia (amara, J Form 2 Pe Location (OUOtr, Set Twp, Rng• Meridian) SE&E. Sec 1, TOB. ROM. eth PM Latitude: 39.548427 Longitude -toe-2182e County Garfield Pi( Use 0 Product:an ❑ DOWN {Attach mud program} ❑Spepal Purpose (Oeacnbe Use" Pit Type 0 LineC 0 Unlined Surface Damn. Permit: 0 Yes 0 No Offarle d+iposal of on Contents D taction ['Commercial PitrFaciMy Nam. OXY Masa WS Pc^e Attach Form 2b to identify Source Wella and Form 25 Io provide Produced Water Analysis Mulls. 4/Facility No 131 Existing Site Conditions Is Mt location in a'S.nsd,ve Ar.a1' 0 Yes 0 No Attach dale used for determination. O'itence Ir feet} is nearest surface liver +26C yround wale( 1C00 nAir N'e'Is + o mass LAND USE (or attach copy of Form 2A If previously submitted for associated weII) Select ant which beat d acrlb.a lend use: Crop Lam: D Imgeled ❑ Dry Land ❑ improved Paslur o OHO Meadow OCR 2 Non•Crdp Lantl:O Rangeane 0 Timtrer❑Recreetarnal 0Otner {describe) Subdivided ❑ Imlusei. 0 Commercial ❑ Relation Pa' SOILS (or attach copy of Form 2A If previously submitted for associated wall) Sod map units form USNRCS survey. Sheet 4o: 18 Sod ComolsiuSenes No. 63 Soils Series Name. Parachute-frlgul Corneas _ Horzon dticknesa tin Inc( eel A; 0.10 f 0.26 ; C: WA Soils Series Name Horizon Ihickness lin inches) A; ; I!: ; C Attach detailed site plan sod topo map with p11 location, Pit Design and Construction Sze el pit (fest) Length. 290Wldlh: 13Q Depth 13 Calculated pit volume (bbls) 52.555 _ Dilly inflow rate (bltisldsy) ? Daily dlepoul rates {stuch calcWetronel, Evaporation: ea bbluday Perootatlon, none Type of uner material High Dersny Polyethylwn. Thickness 60 mW nbisiday Altsch description of proposed design and conalruetlon (include sketches and calculations). —tltethad'o treelmenl of P'oducee wale( prior to discharge-rnfo ppt-teepareior reeler trails, 3inyrl separator h Pa Word? ©Yos ❑Nc Is cit nehec' ❑ Yes [y]No I hereby certify that Me statements made if this form areto the best of my knowledge. Irug, cora no complete. Pmt Name Oen*N i'a4116 Tine R+utory Coordinator OGCC Approved: CONDFTIONS OF APPROVAL, p° ANY. Clete. Signed a 5/ Title ` / IW1Q ^r. ❑ate.40,4f_ FACILITY NUMBER: 1 L,NO3 CO Access landing 81 " to 604-44 Pad SESE, Sec 4, TBS, R97W, 8'h PM Approx. Scale: 1" = 100' OXY USA WTP LP As -Built of OXY's Mesa WS Pond 13E Garfield County, Colorado Oct 15, 2008 Figure 1 RECEIVED NOV 0 3 2100 CGGG`C SESE, Sec 4, T6S, R97W, 6th PM Approx. Scale: 1"200' OXY USA WTP LP As -Built of OXY's Mesa WS Pond 13E Garfield County, Colorado Oct 20, 2008 Figure 2 rri 7_rzi e \\:\ crt.E; �J 7 1 6\ 66 t 6002 C 0 AO411._ a3A133 I s v71-'+T/f or/ Side View 7 aO-mil- - irg Density polyethylene `x' a > c co W cc 0 W CC Geo omposite 0 PRODUCTION PIT Power cable to solar powered equipment Pack outside pit Top View 290' to Water level with 2' freeboar 11 ft Fluid level indicator measures pressure and converts hydrostatic head to feet of liquid above it. Volume of Pit = 52,555 bbls (with 2` freeboard) Volume Calculation: = 11 "((280*120)+(200.150)+(225'75)] 3 295,075 cu ft = 52,555 bbls Volume of 1" = 499 bbls @ free board line OXY USA WTP LP Production Pit OXY Mesa WS Pond 13E. SESE. Sec 4, T6S, fl97W, 6th PM (Garfield County) Oct 20, 2008 Not to scale Page 1 of 1 RECEIVED NOV 0 3 20D8 Calculations for Earthen Pit Permit Applications CCG Calculation of Pit Capacities: Pit capacities were estimated from length and width measured al 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 from the total pit depth to allow fora minimum of the required two feet of freeboard. 1 1 Surface Lerath Le Bottom Length Figure 1. Top View of an earthen pit. Figure 2 shows the dimensions and calculated terms in a cross-sectional view of a pit. The angle p is calculated from the length and width at the surface and the freeboard depth. Pits are designed to have a 2 (horizontal) to 1 (vertical) slope on the sides. With a 2 to 1 slope the angle 3 is 63.435° from vertical as shown by the yellow shaded area. Le = Surface Length Lt Freeboard Length a, D, = Total Depth Df= Freeboard Depth Figure 2. Cross-section of an earthen pit. RECEIVED NOV 0 3 2008 A sample calculation is shown based on the construction design for a 2500 barrel pi wi 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' D, = total depth = 101 Di = depth with 2' freeboard (D, — 2') The distance al can be calculated from the measured surface lengths: al = (L,. Lb)/2 = (80'- 40')/2 = 20' The angle 3 can be calculated using the two sides of the yellow -shaded triangle. Tan0 = opposite side/adjacent side = 20'110' = 2.0 and taking the arctangent, (i = 63.435°. Side az on the smaller yellow triangle can then be calculated using the angle 0 with the freeboard depth as: a2 = Dr* Tangent 1= 8'*2.0 = 16' Lr= Ls - 2 * (8)-52) = 80' 2*(20'-16') = 72' The widths were calculated in the same manner using the same angle R: al = (W,. Wb)/2 = (50'- 10')12 = 20' a2 = Df* Tangent p = 81*2.0 = 16 Wr = Ws - 2 * (al -a2) = 50' — 2*(20'-16') 42' Capacities were calculated using the standard formula for a truncated rectangular pyramid as follows where V is the pit capacity in cubic feet: L?r*[Lr*Wr+(Li +w )(Lb+ wy)+La* WhJ v= 3 Substituting example values (all dimensions arc in feet) into the volume equation: RECEIVED Nov 03 2008 V= *L72*42+(72+42�' )(44+10/2m.40*l(}� X3 The resulting volume is 12,930.7 fig. Converting to barrels the capacity is: Capacity = l 2930,7 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 the freeboard length and width and converting to barrels as: SurfaceVolume = For the example calculation: Lf (ft) * Wr (ft) * (l "depth) 5.61458 cu ft/bbl Surface volume of 1" @ freeboard line = (72')*(42')*(1/12')15,.61458 ft'lbbl = 45 bbls Evaporation Rate The evaporation rate is calculated from the surface area at the freeboard based on the average evaporation rate for Garfield County of 45 in/yr/sq ft surface arca. The evaporation rate in barrels per day is calculated by the equation: Evaporation Rate — Lr (ft) * WI. (ft) * (evap rate (in) /12) (365 days/yr)* (5.61458 cu ft/bbl) Using the sample calculation numbers the evaporation in bb]/day is: Evaporation rate = (72')*(42')*(45 "112)1(365 days/yr)*(5.61458 ft3/bbl) = 5.5 bbl/day (FORM 15 Rev tee J, EMI HUH State of Colorado 00 and Gas Conservation Commission 1120 UnCOln Street, Suite 80', Denver. Colorado 60203 (303)894.2100 Fax .(30304-2109 ldazzfC3 EARTHEN PIT REPORT/PERMIT �Tfik form le t0 be used for both reporting and permitting p Is. Rule 903 describes when a Permit with prior approval, or a Report within 30 days, is required for pis Submit requ+red Onschrnente and forme. FORM SUBMITTED FOR: ® Pit Re • ort El Pit Permit OGCC Operator Number: 06571 Name of OfI1eser;: OXY USA W TP LP Aaron. P.O. Bax 27757 Gay Houston Roy TX ZiP• 77227.7557 s0 REQ` OOT 2 2008 COGCC Conhict Name and Telephone: Dan let Padua No: (270) 253.363? Fax: (270) 243-0625 Campl.lr the All/altmen( Checkllet Dar (MCC Datarlad 8+U Plan J Mn0 wI Pry Lacing, WII N yw iIarm 941 ao tc. WYE )Form Deslfn Cakwlauone Mine.)," Mos Num.. Ahad P•0 '1 n Form ZA API Number (af sssooialed well): DGCC Fscillty ID (of other 'modeled facility): P11 Wilke (OM]tr, Sec. Twp. Rng, Meridien): SESS, Sea 4, T6S, Re7W, 8th PM Latitude: 39.649427 Longituda: -109,24926 County: Garfield Pit Use, ( Producllon ❑ Drilling (Attach mud program) ❑Special Purpose (Describe Use): PIS Type: ❑ tined ® Untneo Surface D scheme Perrelt: 0 Yes gl NO Ofblte disponi of pit contents: 0Injection ® Commercial pttiPecilily Name' OXY Mea* WS Pard P1'Fecdify Attach Form 24 to Identify Source Wails and Form 2810 provide Produced %fete Analysis result,. a 13W Existing Site Conditions is fie location In a'Sensiive Area?' ❑ Yes ❑ No Attach dote usad orsperm notion. Diatence (In feet) to nearest surface wetor 1260' gmund wafer X00' water wells, ' 5 miles LAND USE (or attach copy of Farm 2A If previously submitted car escalated well) Select gni which beet describes lend use: Crop Land. 0 irrigated 0 Dry Land ❑Improved Pasture 0 Hay Meadow 0 CRP Non -Crop Lanc:O Rangeland (]Timber❑Recreal,anal ❑ Other (describe) Subdirded: ❑'Mustrdai ©Commercial ❑Raadentlal SOILS (or attach copy of Form 2A if previously submitted for aesox1 tsd well) Sail map unite form USNRCS euney Sheet Ye '6 Soil Complex/Senn No be Sods Series Name: Paraahute•lrigui complex Horizon thickness (in inches). A: 0-10 8: 10.25 C; NAA Soils 5e0.. Name: Horizon thickness (In Inches), A: , 8: C: Attach deteFied site plan end tope map with pit iodation. Pit Design and Construction Size of pit (teat): Length: 270' Width: 120' Dopa: 13' Calculated pit volume (bb4e 49.061 Deity triaaw rale (bbwdgr): 250 — Daily disposal rata (attach cskuls6ons): Evaporeban: 54 bb lday Pereoletlon nage obierday Type of liner material: High Renally Poyetnytene Thickness: 00 rtes Attach desortptlon of proposed dse(gn end oonstrllallon (Include 1kel014 and cafcWetlona), Method of treatment of produced water prior to discharge Into pit (separator. heater treater, other): separator Is pit fenced? Vee ❑No Is pit netted? DYee Mho I hereby certify that the statements made In this form ars, to the hest of my knowledge, true,corretnd complete. Print Name. 16101PedRk Signed: Title: Ptegula1ary C00t nator — Date. 706z;1 OGCC Approved: CONDITIONS OF APPROVAL, IF A Titin: e* _ /0/9Date:44 FACILITY NUMBER: 4,41 LI int--. \JA L_ Access landing 81" to 604-44 Pad Approx. Scale: 1" = 100' SESE, Sec 4, TBS, R97W, 6th PM OXY USA WTP LP As -Built of OXY Mesa WS Pond 13W Garfield County, Colorado Oct 15, 2008 LFigure 1 RECS1VED OCT 2 3 2008 COGCC SESE, Sec 4, TBS, R97W, 8th PM Approx. Scale: 1" = 200' OXY USA WTP LP As -Built of OXY Mesa WS Pond 13W Garfield County, Colorado Oct 20, 2008 Figure 1 FORV 15 Rey OM State of Colorado Oil and Gas Conservation Commission Ire, vtf'S3 1120 Lncdln Street, Suite 601, Denver. Colorado 88283 (30)894-2100 Fax .(303)894-21a9 EARTHEN PIT REPORT/PERMIT COGCC Thle form is to be used for both reporting and permitting p t3-. Rule 903 describes when a OO OCT 2 3 2000 Permit with prior approval. ora Report within 30 days, 16 required for pits. Submit required �$tUchmertts and forms. - FORM SUBMITTED FOR: ❑Pit Report 1Z Pit Permit OGCC Operator Number 7t Name o' Operator OXY USA WTP LP Address. F.O. Sea 27767 Flo:aton 5fe • TX Zip: 77227 75ST Contact Name and Telephone: Daniel Pada' No (470) 2633637 Fax: (970) 243-2625 API Number (of modeled welly 013CC Fscelty ID (of other associated facility): Pit Location (QtrOtr, Sac, Twp, Rng, Moncton): SESE. Sed 4, T6S. Fro7W, net PM Latitude: 34.546427 Longitude: -106.21926 County, GarReld Pit Use: m Production 0 Drilling (Attach mud program) ❑Special Purpoaa (Describe Liao). Complela the Attechmsnt Checklist ,goer OGCC I]eteeed ode Pen Taro Map re/ P11 L4cil a, r Wally Mnny W Warm 21) educes wile Norm 2e} r 01141941! r t Con aid Design Catcuiedana garwtnre ,ty . DitsrnT. Mud Program Form 3A P1i Type: 0 Lkted Q Unlined Sur'6ce Diechsrge Permit: 0 Yee 0 No Offsite diepaal of pit contents: ❑Injection 0Ccmmercfal Pit/Facility Name: aNY M.sa W5 Pond Pit/Facility NO 13W Attach Farm 26 to Identify Source Wells and Forme 2310 provide Produced Water Analysis results. ExlsJing Site Conditions Is the location In a'SensldAros7 'Sensitive ' 0 Yea No Attach data used or • 'lean nation. Dislence (in feet) to nearest ludic, water. 1290' _ ground water 200" water w.IL$. - . 5 ml+ee LANG USE (or attach copy of Fomr 2A If prryvlously eubmllted for associated well) Select pili which beat deeoribee land use;. Crop Land: 0 Intgetsd Q Dry Lend Q Improxsd Pasture Q Hey Meadow Q CRP Non -Crop Land:0 Rangeland 0 Timber Q Remotion el Q Other (describe)' Subdfv.dad: 0 Industries Q Commerraal ❑ Res:deniW SOILS for attach copy of Form 2A if previously submIttsd Ayr sssooIMad well) Soil map units torn USNRCS survey. Sheet No: 16 5fllr Complex1Senes No: IS Sols Series Name: Parachutrlrtgut Cornplex .lonzcn thickness (in nches): A: 001 ; 9: 10.25 c: N/A Soils Series Name: riorixon thlcsnese (In Inches): A: B: C: Attach detailed ells plan end topo map with pit !octillion. Pit Design and Construction S1zs of pit (fast): Length 270' iJ dd1. 120 Dept': 13 CakiWated pet volume (bbka) 49,06 t Degy inflow 'its ttlbtalderyf. 260 Deily dipole rates (attach ca cuiations): Evaporation 64 bWields), Percolation: none Type of Liner rnaterIaI H19n Dona;1y Poystrylene Thickness60 Tee Attach description of proposed design and construction (Include skelches end cafculst!ons). Method of treatment of produced water prior le discharge into pit (separator, heater teeter, other): 'Vargo( Is pit fenced? DYes Q'No Is pit netted? QYes © No 1 hereby certify that the statements meds In this form ire, to the beet of my knowiedge. true, corr¢ptnd complete.. Print Nems Dan eI Paddle Signed. Title: Regulatory Coordinator f gate: f6/ a r?/ OGCC Approved: CONDITIONS OF APPROVAL, IF A Title: 015' ` 411409 Date: 049 J FACILITY NUMBER: 'qL.10.-•1, � 111111111111111 ofamai State of Colorado 011 and Gas Conservation Commission 1120 Lincoln Street, Suite 801, Denver, Colorado 80203 (303)894.2100 Fax:(303)894.2109 Iv 22 r5-3 OO -firerffetr" EARTHEN PIT REPORT/PERMIT This form is to be uaad for both reporting and permitting pits. Rule 803 describes when a Permit with prior approval, or a Report within 30 days, is required for pits Submit required attachments and forme. FORM SUBMITTED FOR: ❑Pit Report Pit Permit OGCC Operator Number: aaaTI Name of Opera la: OXY USA WTP LP Address; P.o. Box 27767 City: 140-1lon _ State TX 21p: 77227.7557 OCT 23 MB COGCC Contact Name and Telephone: Daniel Nadia No: (07O) 283.3e37 Fax: (270) 24&2525 Complete the Attachment Checklist ger, Ogf G 134411144 SI* Plan Togo Map w1 Pts Looaluon WNW Mit1MI ttarnl i{7 sours weita (form 21) PI Ds.yP ane GpI e.I� Deet n CaloWadone 94 D tie Dsi.rm. PAtA Pitelfn Fans lA J_ API Number (of associated well): 0000 Facility ID (of oft usoddad tserllty): Pa Luellen (QtrOtr• Sec. Twp, Rno, Meridian) SESE. Soo 4, 168, Re7W, EIh Pita Latitude: 38.649427 Leagitude: • 1O821020 COW* Garfield Pit Use D Production 0 Drilling (Attach mud program) ❑Spadel Purpose (Describe Use): Pit Type: 0 Lined 0 UMW(' Surface DIschrge Permit 0 Yea ( No Offsite deposal of prt contents: i0Injection pCornmerdal PiflFecility Name: OXY Masa WS Pond Attach Form 20 to Identity Source Wells and Form 25 to provide Produced Water Analysla rtaults. PIVFac sly No 13W Existing Site Condi ions Is the louden In a 'Sentra Area?' © Yes m No Attach data used • r nation. Distance (In feet) to nearest surface water 1290" ground water 20v water welts: 1.5 mIU. LANG USE (or attach copy of Form 2A If previously submitted for aaaaolated will) Select cam which beet describe; land use: Crop Land. ❑ Irrigated t❑ Dry Land CI Improved Pasture ❑Hay Meadow ©CRP Nan -Crop Land:❑ Rangeland ❑Trmber ❑RecreabonHi 0 Obi, (describe): St,bdiv d.d: 0 industrial 0 Cornmerua ❑ Res -dentin' SOILS (or attach copy of Form 2A If previously submitted for associated well) Soli map unite bras USNRCS whey. Sheet Yo: 15 Soils Series Nome. Parach•rts•r"put Compi.a Soils Sense Name: Attach deielled site plan and tops map with pia location. Sod Corrptes/Series No: be r4o,nzon thickness (In .riches) A: 0-10 Horizon thicxnese (in Inches). A: 3: 10.25 : C. NfA Pit Design and Construction Sue of pit {feet} Length 270 Width: 120' Depth: t3° Cs/Waled pit volume (bbl;) 49.0;1 Daily IrrAow reel (bblsiday): 2b0 Deity deposal rates {attach caitulsbons): Evaporation 64 )bwlday Perooietion: flan pttlstday Type of liner metarial: High Denalty Pory.Nytene Thickness' e0 moa Attach description of props/ed dalon end construction (include sketcher and oatoulatlons). Method of treatment of produced water prior to discharge into pit (separator, heater treater, other): eeparattr is pit fenced? DYas Ohio la pit netted? ❑ Yes ©No thereby certify that the statements made in this form are, to the best of my knowtedge, true, con kind co print Name Daniel Pad.tia Signed' Ta�aolesllj Title: tory Coordinator Date: /d%,?/, P' plate. OGCC Approved:f CONDITIONS Of APPROVAL, IF A Title: E/ /irlW eleCr Date:_ C FACILITY NUMBER: o'1 Lr[ L-� FORM 15 Rev erre 11 111111 l Illi Illi State of Colorado Oil and Gas Conservation Commission 1120 Lincoln Street. Suite 801, Denver Colorado 80203 (303)694.2100 Fax:(303)894-2109 veil?rS3 EARTHEN PIT REPORT/PERMIT s0 ikralVtrY OCT2 3 x'2008 COG!�C This form is to be used for both reporting and permitting pita. Rule 1303 describes when a Permit with prior approval, Or a Report within 30 days, is required for pits. Submit required attachments and forms, FORM SUBMITTED FOR: ❑Pit Report [?Pit Permit OGCC Operator Number: 66971 Name 0! Operator: OX' USA WTP LP Addreie, P.D. Box 27757 ,.dy: Houston state: TX hp 77227.7557 Contact Name and Telephone: Daniel Pedllia No (970) 263.3637 Fix: Ia7D) 2432626 Complete the Attachment Checklist crow 0 3CD, Deud.d 91Is Pun rape May w'! Fri Lcoalien wua Analyr4r iForm 263 Sowyd Walls (forth 26) 1 tagrrFlrn s 07ar Gaal De • n C loufMlpr Ares Debra. haus Program rknm 2A API Number (Of assodeled well): OGCC Facility ID torr other gstocaated facility): PP Location (OtrOtr, Seo. Twp, Prig, Meridian) SESS. Seo 4, Tea, POW. tidy PM Latitude: 39,540427 Longtlude: •106.21626 County: Garfield Pit Usa ❑ Production 0 Drilling lAttech mud program) ❑special Purpose (Describe Use), Pit Type: El Lined 0 Unlined Sura Diechsrge Pemmrt: ❑ Yes m No Ofhlte disposal of pt contents 0InJectian QCcmmercial PitlFadiity Name: 'CXY Masa WS Port Attach Font 25 to Identify Source Wella god Forel 2540 provide Produced Water Analyst, results. PitiFsciltty No: 13W Existing_ -Site Conditions Ia dip Iocitcn In a'Se^alilve Areal ❑ Yes ©Ho Attach data u for determination. Disterce iIr teat? to nearest surface water 1280 ground water app' water weft ' 6 miles LAND USE( or 'Reck copy of Form 2A if previously submitted far associated well) Select DOl which best describes land use: Crop Land. 0 Irrigaied 0 Dry Land ['Improved Peeture ❑Hey Meadow ❑ CRP Non -Crop Lanc:i7� Rsrgesand ❑T:rnb r ❑Recreational ❑ Other ldeSerlbe) Subdiv 'dad: 0 Industrial 0 Con -mem. as ❑ Res dontiel DOLS (or attach copy of Form 2A If previously wbmltted for essocleted weli) Soli map unite form USNRCS survey Sheet 'Io to Soli Comple,JSenes No, da _ Sana Series Neme: Perachuis•Ingul Ca•npiex Horizon thickness tin inches) A. 0.10 ; 8: 10.25 ; C; NIA Solis Sones Name: Horizon thicxneee (In Inches). A: ; B. ; C: Attach detailed alta plan and topo map with p11 location. Pit De ign and Construction 81x2 of pit (het): Length' 270' Width: 120' Depth: 13 Calculated pit volume tbbty' 4tO 1 Deily inflow rote (bbls+dey), 250 Daiydisposal rates (attach ca{utelonl): Evaporation: 54 ,bC1s/day Percoistion: none Type 0f Hoar rneterlal: High Density Poiyelryiene Thickness' 60 moa bbleiday Attach description of proposed dselgn and oonatruallan (include aketchae and caioulatlone). Method Of treatment of produced water prior t0 discharge Into pit (Separator, heater treater, other): ..Pans la pit kneed? mYee ❑No Is pit netted? ❑Yea © No Thereby certify haat the statements made In thie?orm are, to the beat of my knowi7edge. true, tar t nd complete. Print Name: Denier Paella Signed. Tills: Regulator/ Coordinator m; Date: /v/a. 2/ OGCC Approved: CONDITION. OF APPROVAL, IF A Title: 4-0105 - j^,_ Oata:j03/76! FACILITY NUMBER: (1i 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' Ws = surface width = 50' Lb = length along bottom = 40' Wb = width along bottom = 10' D, = total depth = 10' Dr= depth with 2' freeboard (D,— 2') The distance al can be calculated front the measured surface lengths: as = (L, .14)/2 = (80'- 40')/2 = 20' The angle R can be calculated using the two sides of the yellow -shaded triangle. Tanja = opposite side/adjacent side = 20'/10' = 2.0 and taking the arctangent, j3 = 63.435°. Side a2 on the smaller yellow triangle can then be calculated using the angle 0 with the freeboard depth as: a2 Dr Tangent 0=8'*2.0= 16' Lf= Ls - 2 * (al -a2)= 80'-2*(20'-161=72' The widths were calculated in the same manner using the same angle 0: al = (Ws.W0/2 = (50'- 10')/2 = 20' a2 = Dr* Tangent 0 8"2.0 = 16 W'=Ws-2 *(al-a2)=50'-2*(20'-16')=42' Capacities were calculated using the standard formula for a truncated rectangular pyramid as follows where V is the pit capacity in cubic feet: Df*{Lf*Wf+(Lf+W4)(Lb+'W V= 3 ) + Lh * Wbj Substituting example values (all dimensions are in feet) into the volume equation: 8*172*42+(72+42,/x40+1%)+40*10 The resulting volume is 12,930.7 ft3. Converting to ban -els the capacity is: Capacity = 129303 ft3/5.61458 ft3/bbl = 2303 bbls RECEIVED OCT 2 3 2008 Li V VlCC Freeboard Surface Calculations Surface Volume at Freeboard Line The volume at the freeboard line is calculated for a depth of 1 inch using the freeboard length and width and converting to barrels as: SurfaceVolume = Lr (ft) * Wr (ft) * (1"depth) 5.61458 cu ft/bbl For the example calculation: Surface volume of 1" @ freeboard line = (721)*(42')*(1112')1561458 ft'/bbl 45 bbls Evaporation Rate The evaporation rate is calculated from the surface area at the freeboard based on the average evaporation rate for Garfield County of 45 in/yr/sq ft surface arca. The evaporation rate in barrels per day is calculated by the equation: Evaporation Rate = Lr (ft) * Wr (ft) * (evap rate (in) /12) (365 days/yr) * (5.61458 cu ft/bbl) Using the sample calculation numbers the evaporation in bbliday is: Evaporation rate - (72')*(42')*(45 "112) / (365 days/yr)*(5,61458 fta/bbl) - 5,5 bbliday OLSSON ASSOCIATES December 6, 2013 Kathy Eastley, AICP Senior Planner Garfield County Community Development 108 8th Street, #401 Glenwood Springs, CO 81601 keastley@garfield-county.com Re: OXY USA WTP LP Pond 13 E/W, LIPA 7675 Dear Ms. Eastley: This letter is in response to Mountain Cross Engineering's comments dated December 3, 2013. 1. The narrative makes it sound as if it will also be a contractorlstorage 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 are 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 970.263.7800 Grand Junction. CO 81506 FAX 970.263.7456 www.olssonassociates.com OXY USA WTP LP Pond 13 E/W, LIPA 7675 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 protect site will be evaluated with the previousty 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 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. 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 minimis. 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 riot 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 wrsen 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 HSPS 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, efr/62.4, Tilde Evans Olsson Associates Cc: Daniel Padilla, Oxy File Attachments: Approved COGCC Form 2 APD Pad 604-44 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 FOrea 2 State of Colorado Oil and Gas Conservation Commission f 70lSieak+ Siswi, Suite 901. rlfdyer.. Cabled° 811203 (307) 8942100 Fir: (3031894.7109 APPLICATION FOR PERM{ i1[If l�l�lf���� en ❑ Re-enter ❑ 05 '. UPI et wail L Drill, ❑ Deepen, , ReC4m 012663 2 TYPE OF WELL OIL ❑ GAS Q COAL ay 0 OTHER: SINGLE TONE 1p MULTIPLE 2oi1E ❑ COMMINGLE ZONES 3 OGCC Operator Number. 6 6 571 4. Nara* of OpeiatOr: on USA 1rTP 1.1' 5 Address_ 5 GR!.W1WAY PLAZA, SUITE 110 £,alar HOUSTON Safe: TX 7 wen Mame• CASCADE CREEK 8 Una Neese (if appy)• N/A 9 Proposed Total Poplar 9.3 50' ✓ 0.0 fRefiling Sidetrack 0 et Nam. & Pharm 1-01,7LCc Lu pat, '?bol ooUJ ,RECEIVEf JUN I F is 4 Piot tyGt5c-ety IDM MR. T. RENT WOOLLEY Ram. 1111i_3S0-4856 ZIp:77046 Feet WYe1*Ynbrr; 604-44 UsI Na! N/A ." J Complete the Attachment Checklist (713) 350-4873 woC 17 coda r�mya_Le s_amMa,a}aee Noma r.a NVe „Castaa pea 17 rant✓ WCC WELL LOCATION INFORMATION 10 Otratr. NESE See4 TO. 6S rootage Rpm Exterior Section Ones: At 5urreas 927 ' FEL 1.844 ' FSL F veld Nestle OR,llilrD VALLEY ✓ 12 Grouted Elevation 0601' Farwr^: 9 7 W Mer4dan Field Number. 312 9 0 0"--- 13 County: GARFIELD ✓ 14 Irwetlm: ❑DreetianaI ❑Hdrizontal(HiptiyDeviated), strantMdrvHMsde0016e170e00. Footage from Exterior Sarno Lase end Sec Twp Rr1g. N I A Vertical well Al Tap of Plodudron Zona At Batmen 1104 ., 15 is Aocaton in a flus dense/ area (Rule 803b)7 0 Yet [] N0!-� 16 Distance to naresl buiidirg, public roar,Impel keit)/ or rearmed: more than a mile 17 Oestence to Nearest Property Ulla: Mfg f 4 G 1 ✓ - 18 DEM/MA to Ma reef well COMPil 4d r same formation 3 , 5 2 5 l r---- CzELLIf tram V Moog L.., Wand lama tuft_ Selo* Vaaawannafall, r'a teem Folio 19 tampion utcem,e we.rn J rare Fae.eanatarese lr see tent completer permit Racuapa to county 19. LEASE, SPACING. AND POOLING INFORMATION Objective Formation(*) FarmnGon Code Spacing Order Member Una Amur Atalanta at Wee flea Cone cream pea eEi4 awl waBA '....MME MVUD NIA as *Mks w!IS Production 7 7/9 4 1 /2 11.6 5350 1000 9350 4200 i _. 20 Mintel Ownetahlp, Q Fee 0 Stat* 0 Federal 0 Indian 21 Surl4olt L7wr1e110110: ll Fee OS"' ©Fedarel 0indlan III tits 5u Ownerno Ino Mineral O owl Cholla (r Ne &doom If Na- udace Owners Agnomen Asad -red Or 0 825,000 Barium SOrf*Ce pond 23 Describe lease area aasdciatod only oda the a by QbOtr Sec. Twp. Rog tatted' Lease e: �]�!�/l1 �yy�f Sway fD I- .nlDt I i dere LJLfr7 cj 82,000 surfs= Two [55.000 Surface Bane. separate sl eetheep it trended$ 24. DOUnde t0 Neeresl Lease Line- 1 , 4 21 ' l 25 Total Acres in Lease -14" —7-1,2Q, a<<t --- DRILLING PLANS AND PROCEDURES 26 Apprpx Spud Date: July 5, 700. NOTE: If degas dring, nobly local fire a 27 DriLIiigConlradoaNumber 10050 None: r3ARY IIILX.£ic 28 Is H2S Antecepaled 0 Yee 0 leo if yes, met contingency plan 20 war ter secv0nx be sndduntotld Managers/her? Q Yee 0 No 30 Yvan sari r>15.000 pprn TDS CO or of bated mediae Weed during dram 7 11 11 questions 29 rot 20 No yes. -a� tris booboo n a nneeve area Mule 903{7 32 Mud despaskI. it.! Oft* ID Oeste method Ei Land Farming r]. Lend Spreading '[l Disposal Facility 0 0810* NOTE. The use or an earthen pit for rorampletlon fluids requires a pit permit (Rule 905b). ❑ Yes QFk D Yes O No O ami E �sl o 0 2 2 .1,n C U E•a 8 c Q8 4343 COa, a U ql c©3�'' O N t2 -o spa N C 4 •0 O "Is a . E Q lidded.. m 0 0� Pa (5037 565-5305 Yr' 2+1 HOUR SPUD NOTICE REQUIRED. CONTACT COC"GCC NW AREA ENGINEER JAIME ADKINS —P (970)-285-9000. SEE NOTICE. 33 Sinn¢ Sate of Ffo% CASING AND CEMENTING PROGRAM Sue of Cane Mate Put Foot Snag Depth Sithe Cancra Cement Bodeen Ceeunt. Top SurLa,e 14 3/4 9 5 /8 23 2400 1200 2400 0 Production 7 7/9 4 1 /2 11.6 5350 1000 9350 4200 i _. _ 1 ! Stag! TCOI 34 BOP Equipment Type. lj Annular Prrysrrtar 0 Double Ram Q Rowena teed © Mone 35 Comrnants. if any SEE ATTACHED COVER LETTER DATED JUNE 15, 2004 FOR ADDITIONAL INFORMATZON,. t Z lir- 306, 1 hereby certify that the statements made in this tonal are, to the best of my knowledge. true, correct, and complete. Porn Nattier K Wr� LEY / L4ialSerej, �3,,J Signed' /' a�•:,:� rimy .A L ttiw Dade: ate:6f 1 • f � � ,fl OGCC Approved _ �Direc(ar 01 CCOG=D1 !► .� 04414314 -7 API . NUMBER Permit Number: lratiorf Date � 0 �i s' [ g5 + coteu tncaxfacE AEE it .rF NK — eQb co> bad r�ss�1 or, co flit -16<w\ w , ,,� n °t o dais ovc Cctwt1-e--'0 STATE OE COLORADO OIL& S CONSERVATION COMMISSION DE1?Af TNIE " F NATO -RAC. RSC]UiRCES' Br!! Owens, Gc:•error 1120 Lincoln St., Suite 601 Denver, CO 60203 Phone: (303) 894-2100 FAX: (303) 894-2109 •.www.oii-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 parameters for Williams Fork Formation wells in Garfield County, the surface casing setting depth requirements specified in the September 22, 1998 policystatement will remain in effect with the exception of new requirements for wells 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 is set as specified in this policy. 'With the exception of wells drilled in the Grand Valley Field, the following conditions are to be attached to ai! 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 fields: 1. The Rulison Field Overpressured Area is the following (see attached map): Township 6 South, Range 94 West, Sections 9,15-23,26-35 Township 7 South, Range 94 West, Sections 2-6,8-10,11,15,16 2. Surface casing must be set at a 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 test results with the Completion Report Form 5 when it is submitted. The following shall be required In all fields outside the Rulison Field Overpressured Area: 1. Surface casing must be set ata minimum depth of ten percent (10%) of the total depth of the well. 2. A surface casing shoe leak off test will be performed at the discretion of the operator. Notify the COGCC Northwest Area Engineer during the running of the surface casingsothat he may have the opportunity to witness the test. 3. Provide all leak off test results with the Completion Report Form 5 when it is submitted. The following shall also be required for ALL -Williams Fork Formation welts drilled in Garfield County 1. All losttlrculationzones Bndgas kicks-must.be reported to the COGCC Northwest Colorado Area Engineer as soon:as teaslbleavit in twenty four hours, and strait be provided with the Completion Report Form 5 when. itis submitted: 7hetollowing data Is required -depths, -mud volumes lost,Trtud weights before and after kicks; nd-procedures.used.tor-ontro{ kicks. Submittal of mud logs which include this information is also acceptable. 2. When the well reaches total depth, the operator must notify the COGCC Northwest Colorado Area Engineer as $oon as feasible within six hours to provide an opportunity for the prodtrt;tion casing cementing operations to be witnessed. Thank you for cooperating with these requirements. Rich Griebling, Director by 41 The Northwest Colorado Area Engineer Is: Jaime Adkins, Loma, Colorado Battlement Mesa Office (970) 285-9000 Battlement Mesa FAX (970) 265-5659 Cellular Phone (970) 250-2440 GE-'• • ENT OF NATURAL RESOURCES. Greg E. Waklwr• Eeacutl a Director COGCC COMMISSION: Tran Ann Casey - (man Cnaa - an.rca John UM • MirJtatel K>3ah • Abe PhT}lpa - NNW Staab= - Stephan Sonnenberg COGCC STAFF: Richard T. Gdchling. DneC.or - Brian J. Macke. Oaputy Director - Morris Batt. Operations Manager Paercta C. BeeMr. Hear+rgs Manager -Thomas 1 Ken, Irriormetion Manager —18 #1•.R TIM • Vi • 18 17' -4 T1sic. •,e 19 30' w. 1 110 R1101r. 1ics.crrb r �r1fa� 4.�.►11.. KR1111e11 .-+ 111.01111 110100.00•00171 . • . 16 16 1+. 16..11,. 10 ....R., IR. C/0004 odtkos Ip. 16.Y, elc CIF . socaT1p 0". s.rRe us*" i ' ' I 1•141 1010011I " 01711100 41111001 ..s saw "1rii"t= •'y11.1.s p1A111 ▪ n h! z. • r44 • 14 do C I16.µ1 e0411:1Tr._. s1nL . /40.01, r 1. 17.10/ 0110 *CC 26 31 '16 111 ava 1•f'•' crar.32 ' 411.1 •L WU 41.1.1e00. .0110^ 0 s o-� Im *w.••_•...1 ---'"--1T 33 10 1 moticr • • s a.� Mere a1• worn' "W1 ...••• - Arrw +Ir+•e..11e W ri..• 1•k4 _A__ Cr. 1•e• 16 • • . 040 00/010. _ r•r'3 11.L* y.1 SAS .., ..,1...1 .10 r - 'FIs . W-cwNwe scow me fir..,. -16+.0x_ f7� (104 [S� _ �/ (I I� it S .fir . .mow 11e 0 011000 1f J_10 ■O 15 VE 4 ARS (,r co 4.f 0 •t•.0x1 coma law NIL 10N' F/EL P PgESsvit E., .rt'riFACE #G EQ 111 icc4 06/30/2004 16:23 FAX 3037219298 GREYSTON'E 411002 Envimnmentat Consultants, Inc. SentbyFacsimile 303894,21i)9: June 30, 2004 Ms: Linda Pavelka . Permitting Se,.. -tion Colorado•Oil :end Gas Conservation Commission • 1120 Lincoln Street, Suite 801 Denver, Colorado 86203 Re. Application for Permit to Drill (APD) Colorado Oil and Gas Conservation Commission (COGCC) Well Name: Cascade Creek 604-44 Legal Location: 927' FEL, 1844' FSL, Section 4 (T6S, R97W, 6th P.M.) Operator: OXY USA WTP LP County: Garfield County, Colorado Dear Ms. Paw tlka: OXY USA WTP LP (OXY) is currently drilling the OXY Federal 23=15 well in the SWf4SW14 or Section 15 (!'6S, R97W, 6th P.M.) in Garfield County, Colorado. As of this morning, OXY's • drilling contractor was drilling below 7,000' in this well with a planned TD of 9,200'. As soon as the drilling contractor reaches TD in the OXY Federal 23-15.we11, OXY wishes to move the drilling rig to the Cascade Creek 604-44 well. I submitted the APO material to you for the Cascade Creek 604-44 well on Jane 16, 2004. That sabre day, Mr. Do}tg Dennison, acting on behalf of Garfield County, submitted a later: addressed to Mr. Richard Griebling with the COGCC, stating that the county waived thelocal governmental designee and notification requirements contained in. COGCC Rules -303(d) and 305(b). In addition, at OXY's request, the surface owners ofthe drillstte location for the Cascade Creek 604-44 well . waived the notice requirements imposed under COGCC Rule 305 by signing OXY's memo covering COGCC: Rule 305 ."Notice Requirements." A copy of the signed memo was included with the APD material that 1 submitted to you on June 16: If possible, OXY requests that the COGCC approve thc'driiling permit for the Cascade Creek 604-44 well by next Tuesday (July 6) so that Oxy's drilling contractor can move the.drilling rid, to the location for the Cascade Creek 604-44 welt. 5231 South Quebec Street * Greenwood Village, Colorado 8017 1 Phone (303) 850-0930 Fax (303) 721-9298 06/30/2004 16:24 FAL 3037219298 GRF.YSTOME 1 003 Ms. Linda Pa►.relka Permitting Seztian Colorado Oil Ind Gas Conservation Commission Juice 30, 2004 Page 2 Please contact me at 303/850-0930 if you have any questions or need any additional information regarding the APD for the Cascade Creek 604-44 well. .Thank you for your assistan GRP/jg Enclosures Cc: . Mr. T. Kent Woolley Senior Landman Advisor Occidental Oil and Gas Corporation Mr. James W. Konst Operaiions Manager Occidental Oil and Gas Corporation 0630-030 (Ms. Limit PaveIka — COGCC) 08/30/2004 16:23 FAX 3037219298 GREYST0\1 FAX TRANSMISSION GREYSTONE ENVIRONMENTAL CONSULTANTS, INC. 523i South Quebec Street Englewood, CO 80111 Phone: (303) 850-0930 Fax(303) 721-9298 Date: June 30, 2004 Pages: i plus this Facsimile Cover Page To: !As, Linda Bovelka Fax: 303/894-2109 Permitting Section Colorado Oil and Gas Conservation Commission From: Gordon R. Palmer Greystone Subject: Application of Permit to Drill: Cascade Creek 604-44 Well Legal Location: 927' FEL, 1844' FSL, Section 4 (T6S, R97W, 6`s 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 w,sek. If possible, OXY is seeking COGCC approval of the drilling permit for the Cascade Creek 604-44 well by July 6. Thank you, 0630.03 (Ms. Linda Pavelka - COGCC) FACILITY OVERVIEW I. Facility Name 604-44 2. Operational Area Cascade Creek 3. Physical Location (coordinates) NESE Sec.4 T6S R97W, 6th PM 4. Facility Contact Phone # (970) 263-3600 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 Sales Line and the liquid phase is piped to one of two (2) storage tanks. A container of corrosioniscale inhibitor is maintained near the wellhead for in-line application as needed. A container of methanol is also maintained on-site for addition to lines as needed to help inhibit freezing. 7. Drainage Pathway and Distance to Navigable Waters: Spill direction is to the West. The nearest surface water body is greater than V4 mile from the pad. 8. Oil Storage Containers/Other Bulk Chemical Storage: SPCC Tank ID Contents Capacity UnitsA Ibblrgal) Containment Type Discharge Prevention" CIT1 Produced Water 400 bbl Steel wi Liner 111.I C1T2 Condensate 400 bbl Steel wl Liner HLI C2T1 Methanol 300 gal Steel ACC C3T1 Corrosion Inhibitor/MCC-6252 150 gal Poly ACC C4T1 Diesel ? ? Double Walled Tank ACC A Containment Types: Steel wl or w/o Liner, Earthen, Poly, Hesco, Concrete, Steel Stock Tank, Steel Trough, etc, or a combination, as applicable a Discharge Prevention Measures: High Level Indicator (HLI), Adequate Container Capacity (ACC), Top Equalization Lines (TEL), Bottom Equalization Lines (BEL), etc. or a combination, as applicable 9. Flow -Through Process Vessels (Separators, Knock -out Pots, Filter Pods, etc): SPCC Unit ID Unit. Type Material Processed Capacity Units (bbl/gal) Containment Type SEP 1 2 Pack Separator Produced Water & Condensate 42-84 gal General Secondary (refer to Section 5.1) 10. Notes (out -of -service, empty tank storage, portable containers on-site, deviation from SPCC rules, etc.): Oxy SPCC Facility 604-44 Rev Date: 10115/2012 Page 3 U ra LL 11 CL u Ln c E cc Containment duction Tanks a an Non -production tanks I LN LAI Portable containment 8 c 41. x Pits or Ponds Vapor Combustion Unit Knockout Pot Loadout Pot Underground Piping Equaliration Une (TEL, BEI) Wellheads Production Tank Feed Line say—es l A, • •-dX 0 I Underground Water line {JOle,aua9 osard algel+odl I1V7 Vapor Unes Above ground piping Temporary Tank Storage area Direction of Flow ODQoi: aoOe 91 ux IA o'' 2 L E a a d g 8 0 FACILITY OVERVIEW I. Facility Name Pond 13 West 2. Operational Area Cascade Creek 3. Physical Location (coordinates) SESE Sec.4 T6S R97W, 6`h PM 4. Facility Contact Phone er (970) 263-3600 5. Photo: -..."1111111111111.11111111111111111r 111111111110 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 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 nearest water body is approximately 1/4 mile to the southwest. r $. Oil Storage Containers Other Bulk Chemical Storage: SPCC Tank ID Contents _ Capacity Units (bbUgal) Containment Type" Discharge Prevention C1Pl Produced or Fresh Water 49,084 bbl Pond w/ 60 mil HDPE liner Level monitor and freeboard A Containmen Types: Steel w/ or w/o Liner, Earthen, Poly, Hesco, Concrete, Steel Stock Tank, Steel Trough, etc. or a combination, as applicable 8 Discharge Prevention Measures: High Level Indicator (HLI), Adequate Container Capacity (ACC), Top Equalization Lines (TEL), Bottom Equalization Lines (BEL), etc. or a combination, as applicable 9. Flow -Through Process Vessels (Separators. Knock -out Pots, Filter Pods, etc): SPCC Unit ID Unit Type Material Processed Capacity Units (bbUgal) Containment Type PMP l Pump Produced or Fresh Water General Secondary (refer to Section 5.1) PMP2 Pump Produced or Fresh Water General Secondary (refer to Section 5.1) 10. Notes (out -of -service, empty tank storage, portable containers on-site, deviation from SPCC rules, etc.): Oxy SPCC Facility Pond 13 West Rev Date: 10/15/2012 Page 3 Pits or Ponds 1:10000 :o❑ Vapor Combustion Unlit Knockout Pot Loadout Po Underground Piping Equalization line (TEL, BEL) Wellheads Production Tank Feed Line Underground Water fine d P a O a 8 r9 c� Oxy SPCC Facility FACILITY OVERVIEW 1. Facility Name Pond 13 East. 2. Operational Area Cascade Creek 3. Physical Location (coordinates) NESE Sec.4 T6S R97W, 6th PM 4. Facility Contact Phone # (970) 263-3600 5. Photo: 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 ICONICS electronic equipment which transmits the fluid level to the field office in a daily report. Pond 13 East is equipped with. a 60 -mil HDPE liner. 7. Drainage Pathway and Distance to Navigable Waters: Spill direction is to the south and the nearest water bodv is annroximatelv'/ mile to the southwest. H. Oil Storage Containers/Other Bulk Chemical Storage: SPCC Tank ID Contents Capacity Units (bbl/gal) ,, Containment Type Discharge Prevention K C 1 l' 1 Produced and Fresh Water 52,555 bbl Pond w/ 60 mil HDPE liner Level monitor & freeboard " Containmen Types: Steel w/ or w/o Liner, Earthen, Poly, Hesco, Concrete, Steel Stock Tank, Steel Trough, etc. or a combination, as applicable a Discharge Prevention Measures: High Level Indicator (HLI), Adequate Container Capacity (ACC), Top Equalization Lines (TEL), Bottom Equalization Lines (BEL), etc. or a combination, as applicable 9. Flow -Through Process Vessels (Separators, Knock -out Pots, Filter Pods, etc): SPCC Unit ID Unit Type Material Processed Capacity Units (bbligal) Containment Type PMP 1 Pump Produced and Fresh Water General Secondary (refer to Section 5.1) 10. Notes (out -of -service, empty tank storage, portable containers on-site, deviation from SPCC rules, etc.): • PMP1 Is sitting in a catch basin that is 13'x15'x5" Oxy SPCC Facility Pond 13 East Rev Date: 10115/2012 Page 3 CD y 11116, LEGEND IaML'l _. - - i. © Pump ❑ Separator 0 Non -Production Tanks I Portable Containment 17 fence 0 Pits or Ponds j Vapor Combustion Unit Knockout Pot -O Loadout Pot — -> Underground Piping ii—lo Equalization Line (TEL, BEL) X Wellheads 0-6 Production Tank Feed Line — — ► Underground Water line •----4 Vapor Lines •, 44 �S3 ,Sova Above Ground Piping Loading and Unloading Area Direction or Flow 1 Facility II); Pond 13 East SPCC Facility Diagram Oxy Pond 13 East Created:09/20/11 Cascade Creek Operating Area Revised:07/20/12 Garfield County, Colorado Locations of underground pang are approximate. Not to Scale NESE Sec.4, T6S R97W, 6`" PM Oxy SPCC Facility Pond 13 East Rev Date: 10/15/2012 Page 4 STATE OF COLORADO John W Feckeniooper, Governor Christopher E Urbino, MIJ MPH Executive Director and Choi Medical Officer Dedicated to protecting and improving the health and environment of IM peopV* of Colorado 4300 Cherry Creek Dr, S. Laboratory Services oivre+on Denver Colorado 80246.1530 8100 Lowry Blvd, Phone (303) 692.2000 Denver, Colorado 80230-6928 Located in Glendale, Colorado (303) 692.3090 hltp://www.cdphe.atale co us December 6, 2011 Mike Brygger OXY USA WTP Limited Partnership 760 Horizon Derive, Suite 101 Grand Junction, CO 81506 RE Permit Application No. 11 GA1950 Dear Mike Brygger Colorado Department of Public Health and Environment ACTION: APEN REQUIRED PERMIT EXEMPTED 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- charged, 4SLB reciprocating internal combustion engine, site rated at 555 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 6S, Range 97W, in Garfield county, Colorado. It has been determined that this engine is exempt from permit requirements. The filing of an Air Pollutant Emissions Notice(s) (APEN) is required. The above emission unit is a listed source that is specifically exempt from construction permit requirements, per Regulation No, 3, Part B, Section II.D.1.c.ili. Specifically, this exemption has been granted because emissions of nitrogen oxides and carbon monoxide are less than 10 tons per year each and the source is located in an attainment area If this engine is replaced with another engine, with uncontrolled actual emissions less than 10 spy or manufacturer's site -rated horsepower less than 100, this exemption shall remain valid as long as a revised APEN is 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 application Consumption of natural gas as fuel shall not exceed 33.84 MMscf per year. This exemption from permit requirements is issued in reliance upon the accuracy and completeness of information supplied by the applicant and is conditioned upon construction, installation and operation in accordance with this Information and with representations made by the applicant or applicant's agents. AIRS: 045/2157/001 Page 1 of 2 NGErrpine XP Version 2009.1 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 AIRS Point Tons per Year NOx CO VOC G-1 001 8.81 9.95 2.82 It 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 II.C.) 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 erni year or more, above the level reported on the fast APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, c. Whenever new control equipment is installed, or whenever a different type 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 exemption shall expire on 6120/2016. ions of five tons per ess, above the level or activity; or of control equipment. associated with this 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 wilt have to obtain a permit before implementing the change. Sincerely, „ 40, Adam Reed, EIT 1 Permit Engineer Stationary Sources Program Air Pollution Control Division AIRS: 045121571001 PERMIT EXEMPT Page 2 of 2 VGEngrate )(P Version 2009-1 From: Daniel Padilla@'oxv.com To: sieve Anthony Cc: Kathy A, Eastle'; ihofman;d'olssonat.souate5 corn Subject: 2013 Noxious Weeds Treatment at Pond 13E!W and 604-44 Pad Date: 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 mullen), 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 1. Padilla Regulatory Advisor OXY USA WTP LP and OXY USA Inc. Occidental DI and Gas Corporation 760 Horizon Drive, Suite 101 Grand Junction, CO 81506 970,263.3637 - office 970.263.3694 - fax daniel_padilla@oxy.com