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Home My WebLink About11.0 BOCC Staff Report 07.14.2014Garfield County Board of County Commissioners Public Hearing Exhibits General Administrative Land Use Change Permit — CaII Up Ursa Speakman A Small Injection Well (File GAPA-7835) Applicant: Ursa Operating Company LLC July 14, 2014 Exhibit # Exhibit Description 1 Public Hearing Notice Information Form and Attachments 2 Garfield County Land Use and Development Code, as amended 3 Garfield County Comprehensive Plan of 2030 4 Application 5 Supplemental Staff Memo (dated 7/14/14) 6 Director's Decision Letter (dated 5/30/14) 7 Staff Report (dated 5/29/14) 8 Staff Presentation 9 Referral Comments from Garfield County Consulting Engineer 10 Traffic Counts from Garfield County Road and Bridge 11 Referral Comments from Garfield County Vegetation Manager 12 Referral Comments from Garfield County Environmental Health 13 Referral Comments from the Colorado Parks and Wildlife 14 Referral Comments from the Town of Parachute 15 Referral Comments from Colorado Division of Water Resources 16 Call Up Letter from Battlement Mesa Concerned Citizens 17 Email from Gary and Bettie Evenson 18 Comment Letter from Sandra Getter and Richard Getter (recd 6/6/14) 19 Letter from Monique Speakman (dated 6/11/14) 20 Letter from Ursa Operating Company (dated 6/11/14) 21 Applicant Response/Timing for Pipeline Implementation (dated 6/16/14) 22 Applicant Response to Conditions of Approval (dated 7/2/14) 23 Memorandum & Attachments from Kirby Wynn, Oil and Gas Liaison including COGCC Seismicity Analysis 24 USGS Information & Attachments including Seismic Risk Article 25 Letter from Battlement Mesa Service Association 26 Letter from Grand River Fire Protection District 27 Letter from Battlement Mesa Concerned Citizens (BCC) 28 Letter from Chuck Hall — Battlement Mesa Oil and Gas Committee 29 Applicant's Power Point Presentation PUBLIC HEARING NOTICE INFORMATION Please check the appropriate boxes below based upon the notice that was conducted for your public hearing. In addition, please initial on the blank line next to the statements if they accurately reflect the described action. 0 My application required written/mailed notice to adjacent property owners and mineral owners. Mailed notice was completed on the 19 day of 77.12(\e_ , 2014. All owners of record within a 200 foot radius of the subject parcel were identified as shown in the Clerk and Recorder's office at least 15 calendar days prior to sending notice. ‘^ All owners of mineral interest in the subject property were identified through records in the Clerk and Recorder or Assessor, or through other means [list] s Please attach proof of certified, retum receipt requested mailed notice. 0 My applicatin required Published notice. Notice was published on the day of , 2014. Please attach proof of publication in the Rifle Citizen Telegram. ® My application required Posting of Notice, Notice was posted on the day of , 2014. Notice was posted so that at least one sign faced each adjacent road right of way generally used by the public. testify that the above information is true and accurate. Name: t&O)'� V7 . (i); Axlio 1( Signature: '1) /,( Date: (o . / 9 / (/ PUBLIC NOTICE TAKE NOTICE that the Board of County Commissioners, Garfield County, State of Colorado, have called up to the Board of County Commissioners consideration of an Application by Ursa Operating Company LLC, submitted in conjunction with James and Monique Speakman requesting an Administrative Review Land Use Change Permit to allow a Small Injection Well on a property situated in the County of Garfield, State of Colorado; to -wit: Legal Description: Section: 24 Township: 7 Range: 96 SEC 24 NWSEN NESE, THAT PORTION OF THE NESW LYING S. OF THE CO. RD. EXCEPT A TR OF LAND CONT. 16.75 AC +/- AS DESC IN BNDY LINE ADJ PLAT REC # 759297 & AFFDAVIT REC # 759296 & QCD REC # 759295. Practical Description: The proposed use is located at approximately 5242 County Road 300, approximately 0.75 miles southwest of the Battlement Mesa Community. It is located in Section 24, T7S, R96W on a part of that property known by Assessor's Parcel No. 2409-244-00-124. Description of Request: The Applicant is requesting approval for a small injection well on an existing well pad. The facility will include one injection well, 6 storage tanks with a total volume of up to 3,000 bbls, containment, two combusters, a valve set and a building to contain the electric pumps. The facility is located on the 4.6 acre pad site which is within an overall 78.25 acre parcel. Access to the site is by existing private roadways including a portion of what is known as Daybreak Drive. The property is zoned Rural (R). Vicinity Map: A Vicinity Map is attached. All persons affected by the proposed Administrative Review Land Use Change Permit for a Small Injection Well and Call -Up for review by the Board of County Commissioners are invited to appear and state their views, protests or support. If you can not appear personally at such hearing, then you are urged to state your views by letter, as the Board of County Commissioners will give consideration to the comments of surrounding property owners, and others affected, in deciding whether to approve, approve with conditions or deny the application request. The Application may be reviewed at the office of the Garfield County Community Development Department located at 108 8th Street, 4th Floor, Suite 401, Garfield County Plaza Building, Glenwood Springs, Colorado between the hours of 8:30 a.m. and 5:00 p.m., Monday through Friday. A public hearing on the Application has been scheduled for July 14, 2014 at 1:00 p.m. in the County Commissioners Meeting Room, Garfield County Plaza Building 108 8th Street, Glenwood Springs, Colorado. Community Development Department Garfield County -r311• :_, \� Aro 1/ f - I .i I ,...4- . r� _Site Vi!Cinit r!�J r s r t it�p ,l • Is t• r• -� I res.. . i "i y. ' -- - I ! i gnln. Mee4 Ursa 1 _•,'ili Vicinity Map Speakman IIIc 39.42079 -108.06023 • Yom_ Li t / • 0I6CLAIMG::Z - Tt G.ey Fhl inionnadon Sym (GIS) and Ra mmFonenes aro deeexyed an a terenco fer arcxum ingdlioa for planing and i modoPg GIS is otn3rdod rat doesIt replace legal descdpion inlorrnaton-In the cl_iul of CVo and other Worm/Ion contained In official govansnont records corn an rho County Clerk and Recorders ace er Aa courts. Inaddiaen. ale representations of Ionians in He GIS cannot bo subeIlutod fori toga! sways Author M Spinelli Revision: 0 Date: 1/2912014 rn rl r4 N r` ru D i- Pry D r- rn sq N rig CERTIFIED MAIL. RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery information visit our website at www.usps.cbm PO* FE. IAL USE Pnstage Certified Fee Return Receipt Fee ndorsemant Required) =+eetrfcted Deflvery Fee "--tlorsnner! Required) MAI Postage & Fee9 $ $0.49 $3.30 10.00 0 / $ _— $6.49 \ 06/19/2014 % Battlement Mesa Se ce Association 401 Arroyo Drive Battlement Mesa, CO 81635 U.S. Postal Service CERTIFIED MAIL RECEIPT (Domestic Mali Only; No Insurance Coverage Provided) For delivery information visit our website at www.usps.com OAF E 4 'I A L U E P Certified Fee Return Receipt Fee ® loreemenl Required) - =added Delivery Foe rclorserrtent Required) $ $0.49 $3.30 $2.70 $0.00 ;tai Pavteee & Fees $ $6.49 06/ rn Battletnent Mesa P O. 'ILIA 60010 Parachute, CO 81635 r= 7010 3090 0001 0247 c. 0 'ivy Land Investments U.S. Postal Service CERTIFIED MAIL RECEIPT (Domestic Mail Only; No Insurance Coverage Prot!ided) For delivery information visit our website at www.usps.cdm Poefeae :.erifRed Fee Return Receipt Fee Endorsement Required) Restricted Delivery Fee Endorsement Reouiret) Total Postage d F94iF $ $0.49 $3.30 $2.70 High Mesa Partners, LLC 400 Panamint Rd. Reno, NV 89521 for 111,11 :ICIII)11. CERTIFIED MAIL RECEIPT (Domestic Mail Only; No Insurance Coverage ProvideJ) For delivery Information visit our website al www.usps.com 010 3090 0001 7010 3090 0001 0247 71.4 AA(T E? T Rs1 Postage i.:erltfind Fee Return Receipt Fee �lorsement Required) -,,traded Delivery Fee ..lorsement Rewired) t9I Postage & Fess 1L USE $3.30 0 $6.49 P Rt.,/ 3�za t Pgatrretet Here , 06/19/2014 Battlement Mesa Land anvesternent 73 Ga Sipprelle Dr. Parachute, CO 81636 U.S. Postal Service CERTIFIED MAIL RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery information visit our website at www.usps.com PoCAHR F. IAL USE riosteqe Certified Fee Ftetim Receipt Fee Endorsement Required) Restricted Delivery Fee iEnfnreernent Required. Total POOIRQe & F99f $0.49 $3.30 $2.70 10.00 $ $6.4) /!`/2014 / Battlement Mesa Service Association 4O1 Arroyo Drive Battlement Mesa, CO 8 635 U.S. Postal Service CERTIFIED MAIL RECEIPT (Domestic Mail Only; No insurance Coverage Provided) For delivery information visit our website at www.usps.com NF6069FICIAL USE Mark Williams Daybreak Really LLC 400 Panamint Road Reno, NV 89521 rq r - 3090 0001 00247 ?21E D t.� U.S. Y05Ic'il �Ervli:e CERTIFIED MAIL RECEIPT (Domestic Mail Only: No Insurance Coverage Provided) For delivery information visit our website at www.usps.com PONE Fi6€IAL USE C celled Return Receipt Gee (Endorsement Required) Roetrkasd Delivery Fee (Endorsement Required) Total Pcisiea, a t,fr, $ $6.4. 05/19/2014 $ $0.49 83.30 0538 49,2 Robert A Monson 102 Mineral Springs Circle .. Parachute, CO 81635 for Initu tion) U.S. Postal Service CERTIFIED MAIL RECEIPT (Domestic Mail Only: No Insurance Coverage Provided) For delivery intormation visit our webal(e at www.usps corn P Ee�6CIAL USE I Postage Conifled Fee Return Reeeipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Recurred) s 80.49 83.30 82.70 80.00 $ 86.49 0538 J ai a stere s case O' SP'iN.' F\ )O t 'rc Postmark "fere /19/2014 Lydia R Benjamin R Tigert 36 Pinnacle Place Parachute, CO 81635 tor rq ru s-9 U.S. Postal Service CERTIFIED MAIL RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery information visit our website at wwv..usps,com PaiE lea 6' r IAL U S E sewed r" Return Rer lot Foe .Endorsement Required) Restricted Delivery Fee Endorsement Required) ® Total Postage 3 i=ce rj- 80.49 83.30 053 O )I S y, ? R erR 82.70 Q,71/ Rare ff Mi 50.00 sh.49 , 06/19/20t4 11 Ronald Leroy & Linda Jean Jensen. 64 Mineral Springs Circle Parachute, CO 81635 43 rq t' - 0 ru ru rd 2090 0001 0247 t° U. . ' ossa CERTIFIED MAIL,. RECEIPT (Domestic Mall Only: No Insurance Coverage Provided) For delivery information visit our w•ebsde at www.usps-corn PaiREEE6€IAL USE Postage Certified Fee Return Receipt Fee IEndorserrant Required) Rea:tided Delivery Fee End7^wrnent Pec(utredl r.,..< 80.49 Battlement Mesa RV Park, LLC PO. Box 6000 Battlement Mesa, CO 81635 U.S. Postal Service CERTIFIED MAIL RECEIPT (Domestic Mail Only: No Insurance Coverage Provide') For delivery Information visit our webstte at www.usps.com sOcF81F2ICoAL USE. Postage CemIIed Fee 9eturn Receipt Fee lEndorsement Required) Resected Delivery FeO (Endorsement Reault+ett) Totdl Restage n Fees 80.49 83.30 82.70 80.00\ $ 86.49 to i �S POSICMark 9/20 Joyce A Keithley & Joyce E. Terry ._ P.O. Box 305 Salt, CO 81652 U.S. Postal Service CERTIFIED MAIL RECEIPT (Domestic Mail Only: No Insurance Coverage Provided) For delivery information visit our website at www uspc Corr POHFE F*SIAL USE Jan E. Bedell Pudge 36 Pinacle Place Parachute, CO 81635 CERTIFIED MAIL RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery information visit our website at www.usps.com Pryari6€IAL USE Postage Certified Fee Return Receipt Foe rodorsement Required) -"stncted Delivery Fee : oraenient Requtmdi ;tat Po tEOa & Fees s $0.49 $3.30 $2.70 $0.00 PRLV, Postmark r tr?i $6.49 © t-1 Jane Grace Joyslin 84 Mineral Spri;r.gs Circle Parachute, CO 81635 PS ForrvtiDO. Augur i O6 See Rovoriie for Insiru .ions ru go r - gra .,d ru U.S. Postal Service CERTIFIED MAIL,- RECEIPT (Domestic Mall Only; No Insurance Coverage Provided) For delivery information visit our webslte at www. conk!: 0600 0002 dm P4kACHUTE CO 810:5 Postage Cartiheri Peer— Return Recei0! Fee nrtoremen! Re sinned) .Restricted Delivery Fee =ndrrrsement Required) Tbtet Postage 5 Fens $0,49 $3.30 $2.70 30.00 Nina L l osser 47 Pinaeae Place Parachute, CO 81635 PS Form 3800. August 200v Soo Revers* for Instructions U.S. Postal Service CERTIFIED MAIL RECEIPT (Domestic Mail Only: No Insurance Coverage Provided) For delivery inforrmtion visit our website at www.uses.com PiiKE EELS IAL USE Postage Certified Fee Retum Reoeldi Fee {Endorsement Required) Restricted Delivery Fee (Er 'oraernent Reached) Forel Poria+& Foos $0.49 33.30 0538 Car M, Metcalf, 11 4827 CR 300 Parachute, CO 81635 067t9/2014 / PS For,n 3800. August 2006 0001 0247 7205 7013 0600 0002 2695 7833 rn P9! !- N ru 7010 3090 0001 U.S. Postal Service CERTIFIED MAIL, RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery information visit our website at www.usps.corn PFBIZ IAL USE Praitngo edi(Ied Fee Return Recelvt Fee (Endorsement Required) Roatrlr/err Delivery Fee Endorsement Regiuired) Total Postage & Fees $0.49 $3.30 / $ bb.49 Dale L & Leona L Arnett 74 Mineral Springs Circle Parachute, CO 81635 t'1 l U.S. Postal Service tr, CERTIFIED MAIL, RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery Information visit our website at www.usps.cam LJ S E PAACHUTE CO 81635 Battlement Service Association 401 Arroyo Dr- Battlement r 1635 Battlement Mesa, CO 8 Src Reverse for Instructions 2006 U.S. Postal Service CERTIFIED MAIL RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery information visit our website at wwwLispsrow pairE F 81 I A L USE Postage Certified Fee Return Receipt Fee :Endorsement Required) Ressietad Delivery Fee Endn.6ement meter sdt Tn I Postage A Fees $0.49 $3.30 $t.49 Lori Metcalf 5091 CR 300 Parachute, CO 81635 SP''•Irvc. rn Poetreark Here 06l19l2014 '/!// Ydl r - ru CERTIFIED MAIL RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery information visit our website at www.u6ps.com ENFaloe IAL USE Certified Fee Q Return Receipt F ee r araernert Required) .::sMcted Delivery Feel - ^.Sarsemert Required) Er C3 -.:rtai'oetaoe R Fees i1 0 t✓ K1 ru For delivery information visit our website at www.usps.corn PIGAEe16 'IAL USE $0.49 $2.70 octemari, Here 30.00 �� J $6.499/201_;; tit" James Raso, Jr. 121 W. 5th St. Hammonton, NJ 08037 evcrso tor tris) n,Cnons. U.S. Postal Service CERTIFIED MAIL RECEIPT (Domestic Mall Only; No Insurance Coverage Provided) 0 0 0 0 fn 0! 11 p0�� i - 0247 6895 'i f0 0 t,.. ! Protege Certified Fee Return Remelt _drx eat Required) (satrlcted Delivery Fee leoreeriaerit Required) --"'t `'^'ta S Poen $3.30 52.70 -,• if $0.00 56.49 i:O t Monique Teresa Speakman 5242 CR 300 Parachute, CO 81635 U.S. Postal Service CERTIFIED MAIL RECEIPT (Domestic Mail Only: No Insurance Coverage Provided) For delivery information visit nut website at www.usps.com POHEEE.6€IAL USE Postage Corned Fee Return Reoetpt Fee Endorserment Required) Restricted Deaver/ Fee (Endorserrr it Required 'btel Cr ctRae 4 v=f es $ $0.49 1€7;q, - 33.30 32.70 30.00 $6.49 P Rbv, .;gyp Pcetmerk Here 1 0611"?014/4 James & )Monique Speakman 5242 CR 300 tairAehute, CO 81635 7010 3090 0001 0247 726 U.S. Posta ervice CERTIFIED MAIL RECEIPT (Domestic Mail Only; No Insurance Coverage ProvrdeJ) For delivery Information visit our website at www.usps.cnrn PQF doe IAL USE PrvrWge Cert) ed Fee Return Receipt Fee cndoraarnent Required; iP.slrlded Delivery Fee rxlersem ent Required) Total Postage x = I It • 36.49 6! /2014 1�7 Metcalf Property Management LLC 150 Columbine Ct. Parachute. CO 81635 U.S. Postal Service CERTIFIED MAIL. RECEIPT (Domestic Mail Only: No Insurance Coverage Provided) For delivery information visit our website at www.usps.com paiE EE.6EIAL USE Rootage Certifier! Fee Rearm Reoerat Fee :=Ixfers'ement .lequlred) ;estected Delivery Foe r darremwnt Required? 10.00 33.30 C 6 E 0 1 32.70 Rea. ted+.,` v � "Owl 'oetepa36.49 /Th421ttecS James Eugene Speakman 355 Wild Rose Lane Parachute, CO .81635 PS Form 011'Auyl ; Soc. 5'v'rr. for Ioitr:Ict,011, U.S. Postal Service CERTIFIED MAIL RECEIPT (Domestic Mail Only: No Insurance Coverage Provided) For delivery information visit our website nt www.usps.com 612ICIAL USE Postage CsfrWted Fee Return Receipt Fee nderserment Required) riestr% ted Delivery Fay end reeme ' Required) $0.49 33.30 32.70 50.00 Total Postage ± SP R1N 3C- scot .fes. ..0 Pr>etmerfr be=et 36.49 o 1 b4- Colorad© River Valley Field Office Bureau of Laud Management 2300 River Frontage Rd0 Salt. CO 81652 - Iyo 3090 Min 0247 7328 U.S. Postal Service CERTIFIED MAIL : RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery intormation visit our website at www.usps.com FO fflPx170 IAL USE CertI ler1 Fee Return Receipt Fee riiortemf nt Required) tasterted Delivery Fee Iclornemert Required) ,Ilei P69I9oo&F Fad Keifer ExtionMobil Corporation 810 Houston st Worth T 76102 CAtotc0t \U� Here #6.49 \ 04/19/2014 l 1 3090 0001 0247 7311 U.S. Postal Service CERTIFIED MAIL RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery information visit our website at www.uses.corn Hatot-rxF�ia C1AL USE onstage Certified Fee realm Receipt Fes Endoreomartt Required) Restricted Lettos,y Fes ndoreerert Reoulmdt 30.49 civr 13.30 „41' 0 ooatmerU Ne SO .00 $ $6.49 C '', Ginger Funk Texas Eastern Skyline Oil (AKA Spectra Enemy-) 5400 We theinter Court Houston, T.r.,X..:724i510 Company y Ei Complete item 1, 2. end S. Also complete roam 4 if RerAricted Delivery is desired. le Print your name and address on the reverse so that we can return the card to you. el Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Battlement Mesa Land Invest 73 O. Sipprelle lira Parachute, CO 81636 D pddreaassc Of Dsliven Jnr( D. Is delivery address diftreni from item t? 0 Yes If YES, enter delivery address below: 0 No Ment. srtiice 3 Certified Mail 3 REgistsr tl 0 Insured Mail ® Express Mail 0 Return Receipt for Meinhandis( 0 C.O.D. 4. Reslicied Delivery? (6dra Fee) 0 Yes 2. Article Number (Transfer from service label) 7010 3090 0001 0247 7106 PS Form 3811, February 2004 Domestic Return Receipt 3Dir R COMPLETE 7TYhtt gEZTMicl Complele items 1, 2, and S. Also complete item 4 if Restricted Delivery is desired. el Print your name and address on the reverse so that we can return the card to you. el Attach this card to the back of the mailpiece, or on the front if space permit's. 102595-024454 OMPLEM 'T.FGri('v r)ti tier:/et =i;,, 1. Arlicde Addressed to: D Agent 0 Address( C. Date of Delive D. Is ddlvsry sd&sss afferent from item 1? 0 Yes Ii YES, enter delivery address below: 0 No 17: Battlement Mesa Service Assoctation3avicaTipe. CelfiRed Mail 0 Express Mail 401 Arroyo D lye 2 Registered 0 Return Receipt for Merchandi: :Battlement Mesa, CO 81635 3 Insured Mail 0 C.O.D. i tricted Delivery? (Extra Fee) 0 Yes 2. Article Number' (Transfer from service label) 7011] 30900 0001 0247 7120 PS Form 3811, February 2004 Domestic Return Receipt ® Complete items 1, 2, and S. Also complete item 4 ii' Restricted Delivery is desired. is Print your name and address on the reverse so that we can return the card to you. ei Attach this card to the back of the mailpiece, or on the front if space permits. 102595 -02 -M -1E 0dltft11. rt ?7(1 egg rely air of utiE v 3c:7,61&A, 1. Article AcioYesssd to: 0 Agent © Address C. Date of Deliv€ D. Is delivery = • • dil rtt from item 1? 0 Yes IT YES. enter delivery address below: 0 No Battlement Mesa Service Association 401 Arroyo Drive Battlement Mesa, 1635 ravine iyps 3 cu"r"led Mali 3 Registered 3 Insured Mail © E" prees Mali 0 Return Receipt for Merchandi 0 0.0.D. 4. Restricted Delivery? (Bad- Fsa) 0 Yes 2. Miele Number (Transfer from service IabeO 7010 3090 0001 0247 x'113 PS Form 3811, February 2004 Domestic Return Receipt 102595-024AA-1. rnimomiwaTalieL ff Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. E Print your name end address on the reverse so that we can return the card to you. ! Attach this card to the back of the maiipiece. or on the front if space perrnits. 1. Article Addressed to: Battlement Mesa Land :P.O. Box 6000 Parachute, CO 81635 A. Signature /f 7X B. Received by (Pr/n'ted Name Agent C, Date of Deiivi D. Is delivery address different from item 1? 0 Yes 11 YES, enter delivery address below: 0 No Investments spice 7.1 - 0 Certified Mail 0 Express Mail - --0 Registered 0 Rearm Receipt for Merchandi 0 insured Mail 0 C.O.D. Resuictsd Delivery? (Extra Fee) 0 Yes 2. Article Plumber (liansier from service label) 7010 3090 0001 0247 7137 PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1: "8 EOM MefitETE 7747 EGTIQN Zit5A?PLE-TE T Ts* tS -aritra �Ff D�LfG'ERY E Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ® Print your name and address on the reverse so that we can return the card to you. ® Attach this card to the back of the maiipiece, or on the front if space permits. tore i 0 Agent 7E 0 Address C. DO of /2-//5 D. Is delivery address different from item 1?? 0 les It YES, enter delivery address below: 0 No 1. Article Addressed to: High Mesa Partners, LLC 400 Panamint Rd, Reno, NV 89521 3. Service Type ® Ceriir%-d Mail © Registered 0 Insured Mail 0 Express Mail 0 Return Receipt for Merchandi: 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (Transfer from service label) 7010 3090 0001 0247 7151 PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1'. GRAND i11%14 ::1"IOt'# SENT3ER CCIIUPLETE FP/Cs SECTION M.,fPL•ETf 714J :§MTTON ON DEf rt FFY le Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. is Print your name and address on the reverse so that we can return the card to you. 15 Attach this card to the back of the maiipiece, or on the front 11 space permits. 1.Miele Midressed to: ,Battlement Mesa BV Park, LLC.- P.O. LCPOo Box 6000 Battlement Mesa, CO 81635 A. S r0 Agent 0 Address 0.., Date of Delive D. Is delivery address different from ism 1? 0 Yes tf YES, enter delivery address below: 0 No B. Received by (Prinied dame) 3. Service Type 0 Csrtiiied Mail © Registered 0 insure.d Mail © Express Mail ® Reum Receipt for ivierchandi 0 C.O.D. 4. Restricted Delivery? (bra Fee) 0Yes 2. Article Number (Transfer from service label) 7010 3090 0001 0247 7168 PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1! M Cor ()tete items 1, 2, and 3. Ako complete item 4 ie Restricted Delivery is dciredd. IM Point your naile and address on the re.verse so that we can return the card to you. el Attach this card to the back of the mailpiece, or on the front, if space permits. 1. Article Addressed to: Obert A Monson 102 Mineral Springs Circle Parachute, CO M635 E. Received (Priv • Name) D. Is delivery address different from item 1? a Service Tips © Oalified Mail 0 Express Mau © Registered 0 Rettum Receipt for Merchandi: 0 Insured Mail 0 C.O.D. 4. Resiriaied Delivery? (Bora Fez) 0Yes 2. Article Number (Transfer from service leb?l) 7010 3090 0001 0247 7175 PS Form 3811. February 2004 Domestic Return Receipt ' ENE E at-anETE 71,1 set ffai ® Complete items 1, 2, and 3. Also complete item 4 If Restricted Delivery is desired. m Print your name and address on the reverse so that we can return the card to you. © Attach this card to the back of the nailpi ce, or on the front if space permits. 1. Article Addressed to: Lydia R & Benjamin R Tigert 36 Pinnacle Place Parachute, CO 81635 102595.0244-15 0 Agent .gAddress B. Received by ( ftted Name) C. Date of DetivE �yD/,1 !cf 7' j ,• - ;7 1 D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: .akNo 3. Service Type 0 Certified Mail 0 Express Mail 0 Registered 0 Return Receipt for Nierchandi 0 Insured Mail 0 O.O.D. 4. Restricted Delivery? (&'s Fee) 0 Yas 2. Article Number iTransier ;corn service labels 7010 3090 0001 0247 7212 PS Form 3811, February 2004 Domestic Return Receipt 102595.0264.1: tiRAND .11./Nr:" rtl, ' (:C, els C.O.RIPLETE Mrs 3E.,rct. divCELIVErT' SEICIEYE RE GOII Lt TE?1=1%Sgl?GT1sa PM Complete items 1, 2, and 3. Also complete item 4 If Restricted Delivery is desired. u Print your name and address on the reverse so that we can return the card to you. m Attach this card to the back of the maiipiece, or on the front if space permits. 1. Article Addressed to: Ronald Leroy & Linda Jean Jer, . 64 Mineral Springs Circle Parachute, CO 81635 2. Article Number (transfer frau service labep aura AAddress = of D1IIVE et, -01 D. is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No Service Type 0 Csrtitied Mail 0 Registered 0 Insured Mail 0 Express Mail 0 Return Receipt for Nierchandi ® C.O.D. 1 Restricted Delivery? (En Fee) 0 Yes 7010 3090 0001 024? 719 9 PS Form 3811, February 2004 Domestic Return Receipt 102595-02-04.11 1111111111.111.1 • CoMplete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. e Print your nary s and ark rss on the reverse so that - can return the card to you. e Attach aid to the back of the mailpiece, or on if space permits. 1. Article to: Dale L •: Leona L Arnett 74 Mineral Springs Circle Parachute, CO 81635 A. SigriatMe 0 Agent FT Address. C. Date of Derive D. Is delivery address different from item 1? 0 `(es If YES. enter delivery address below: No 3. Service Types 0 Certified Mail 0 Registered 0 Insured Mail 0 Empress Mail ® Return Receipt for Merchandi: ® C.O.D. 4. Restricted Delivery? (Elim F a) 0 Yes 2. Article Number (Transfer from service label) 7010 3090 0001 0247 7205 PS Form 3811, February 2004 Domestic Return Receipt 102595-024,1-15 ZEN5E4k twit LETS 77,0 =MN o Corr piate items 1, 2, and 3. Also complete item 4 it Restricted Delivery is desired. i9 Print your narno and address on the reverse so that we can return the card to you. ® Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Jane & Grace Joyslln 84 Mineral Springs Circle Parachute, CO 81635 fame re- B. I;eceived by ( ted -) 7 ® Agent Eg Aukfress C. Date of Derive D. Is delivery address different from item 1? 0 Yes It YES. enter delivery address below: 0 No 3. Service Type 0 Cert. ed Mail 0 Registered 0 Insured Mail 0 Express Mail 0 Return Receipt for Merchandi: 0 C.O.D. 4. Restricted Delivery? (aim Fee) 0 Yes 2. Article Number (Transfer from service label) PS Form 3811, February 2004 7010 3090 0001 0247 7236 tENCIE I> car=viPL-FE T -NG g2rldi t Domestic Return Receipt 102595.02-M-1: ER Complete items 1, 2, and 3. Also complete item 4 it Restrkked Delivery is desired. o Print your name and address on the reverse so that we can return the card to you. ® Attach this card to the back of the maiipiece, or on the front it space permits. -WY 1. Article Addressed io: Battlement Service Association 401 Arroyo Dr, Battlement Mesa, CO 816 0 Agent 0 Address( 7ffne) i from item i? 0 Yes address below: 0 No C. Date of Delive D. Is defive y address If YES. enter 3. Service Type 0 Csrtiiied Mail 0 Registered 0 hind Mail © Expsc-es Mail © Return Receipi for Merchandi: 0 C.O.D. 4. Restricted Delivery? (E• fry Fes) 0 Yes 2. Arfde Hunter (Tiarrsfer (ram service label) 7013 060© 0002 2695 7833 PS Form 3811, February 2004 Domestic Reiurn Receipi 102595-02.1v1-1: NMft-€ MTsEc iAI oFf Da Zii uS 0 Agent C-o-lddr>ss Elj Complete (terns 1, 2, end 3. A10 complete item 4 if Restricted Delivery i desired. e Print your name and address on the reverse 3o that we can return the card to you. 5 Attach this card to the back of the maiipiece, or on the front if space perrnis. 1. Article Addressed to: Nina L Bosser 47 Pinacle Place Parachute, CO 81635 0 Agent 0 Add es C. Date of DelVi7-511 D. Is delivery address different from item 1? 0 Yes li YES. enter deliver, address below: 0 No 3. S-4. "Awe 0 Csriifiie9 Mad 0 Regiserd 0 Insured Mail 0 Express Mad 0 Return Receipt for Merchandi 0 C.O.D. 4. Restricted Deilvery? (Beta Fee) 0 Yes 2. Article Number. - (Transfer from service label _7913 0 6 9 8 13002 22 i.S 7826 • PS Form 381f, February 2004 Domestic Return Receipt 102595.02-M-1: SEMI Ot L =TE Th al: s€e'TPon) 5 Complete items 1, 2, and 3. Aro complete item 4 ii Restricted Delivery is desired. ® Print your name and address on the reverse so that we can return the card to you. • Attach this card to the back of the maiipiece, or on the front if space permits. 1. Article Addressed in: Carl M. Metcalf, II 4827 CR 300 Parachute, CO 81635 Received by, (Printed Name) C. Date of Derive D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No 3. Service Type t' Cetitiied Mail 0 Express Niail 0 Registered 0 Return Receipt for Marchand' 0 Insured Mad 0 C.O.D. 4. Restricted Delivery/? a Fee) 0 Yes 2. Artticle Number (transfer from service label) 7010 3090 0001 0247 7250 PS Form 3811, February 2004 Domestic Return Receipt 102595 -02 -M -1c el Complete items 1, 2, and .3. Also complete item 4 if Restricted Delivery is desired. El Print your name and address an the reverse so that we can return the card to you. e Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: ,0 Agent i1 Address C. Dai- of Dem .04 'spa D. Is delivery address different from 1 ? 0 Yes _If YES. enter delivery address below: 0 No Metcalf Property Maoagemeut,t,C 150 Columbine Cts Parachute, CO 81635 2. Article Number (Transfer from service label) Service Type 0 reified Mail 0 Pte erect 0 Insured Mail 14. Restricted Delivery? (Extra Fee) 0 Yes 0 Era's Mail 0 Return Receipt for Merchandi 0 C.O.D. 7010 3090 0001 0247 72€7 PS Form 3511, February 2044 Domestic Return Receipt 102595-02-M-1! • Coniplete items 1. 2. and 3. Also complete item 4 it Pes',si,iad Delivery is desired. • Print your name and address o1 the reverse so that we can return the card to you. in Attach this card to the back of the mailpieoe, or on the front If space permits. 1. Article Addressed to: James Rano, Jr� 121 W. 5th Ste Hammonton, NJ 08037 D. Is nisd RNaf7 - Ute. 0 agent D Address C. Date of Deliver s different from iiern 1? - res If YES. enter delivery address below: 0 No 3. Service Tips 0 Certified Mail 0 Express Mail 0 Registered 0 Return Receipt for Merchandi 0 Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Amide Number (Transfer from service labs,) 7010 3090 0001 0247 7274 PS Form 3811, February 2004 Domestic Return Receipt . i=FlD ill aM° c -Err Tiasrerl»M Pa Complete items 1, 2, and 3. Also complete item 4 ii Restricted Delivety is desired. EE Print your name and address on the reverse so that we can return the card to you. Attach this card to the back of the mailpiece. or on the front if space permits. 102595.02 -M -1t Agent 1Address 1. Article Addressed to: James Eugene Speakman 355 Wild Rose Lane Parachute, CO 81635 D. Is delivery address different from item 1? 0 Yes If YES. enter delivery address below 0 No 3. Service Type 0 Catilied Mail 0 Registered 0 Insteed Mail o E''cpress Mail 0 Return Receipt for Merchandi 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 less 2. MICIe Number (Transfer from service label) 7010 3090 0001 02147 7281 PS Form 3811, February 2004 Domestic Return Receipt 9E►TDE1; i beMPL•EFE T NPir s -c d7V Complete items 1, 2, and 3. Also complete item 4 it ire fritted Delivery is desired. En Print your name and address on the reverse so that we can return the card to you. ln Attach this card to the back of the mailpiece. or on the front it space permits. 1. Article Addreesed to: Colorado River Valley Field Ot ei Bureau of Land Management 2300 River Frontage Rd, Silt, CO 81652 102595-0244-1E ?:,;(3 POr T-Nrs3E T%'`Oki 0A?at-If(l-R' D Agent 0 Address, D. le dere/sly addre=~` different from item 1? 0 Yes It YES, errier delivery address below: 0 No Service Type o Ger ified Mail D Registered 0 Insured Mail o Explass Mail 0 Return Receipt for Merchandi: 0 C.O.O. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (Transfer from service label) 7010 3C9C1 0001 0247 730 4 PS Form 38111, February 2004 Domestic Retum Receipt 102595-02-M•1E S>_(= Td&ROLE` € MT& Mllohi (i9 P - r0 • Complete items 1, 2, and 3. Also complete item 4 if Restricted Deliver/ is desired. e Print your name end address ori the reverse so that we can return the card to you. e Attach this card to the back of the meilpiece, or on the front if space permits. 1. Article Addressed to: Monique Teresa Speakman 5242 CR 300 Parachute9 CO 81635 A. SIwtaJJrc o Agent 0 Address C. Date of Delivr 0-24-14 D. Is delivery addrass clitenni from item 1? 0 Yes If YES, enter delivery address below: 0 No 3. Service Type 0 Certified Mail 0 Registered 0 Insured Mail o Express Mail 0 Return Receipt for Merchandi 0 C.O.D. 4. Restricted Derivay? (&ire Fee) 2. Article Number (Trawler from service label) 7010 3090 0001 0247 7298 0 Yes PS Form 381 1, February 2004 Domestic Return Receipt ENDE-R COMPLETE- Ti -fig gECT O%V o Complete items 1, 2, end 3. Also complete item 4 if Resbictsd Delivery is desired. IN Print your name and address on the reverse so that we can return the card to you. o Attach this card to the back of the rnailpiece. or on the front if space permits. 1. Article Addressed to: James Monique Speakthan 5242 CR 300 Parachute9 CO 81635 ,r 102595-024A-1: e cJkW ETE TPi>$ sErg aiv OIJ Eitoregy ®Address :''ed by (Printed Nerve) C. Date of Delius tp— D. Is delivery adchees c liferent from Ibsen 1? 0 Yes If YES, enter delivery address below: 0 No 3. SeMce Type 0 Oertiled Mall 0 Registered 0 Insured Mail 0 Express Mail 0 Return Receipt for Merchandi: 0 C.O.D. 4. Restricted Delivery? (Bdra Fee) 0 Yes 2. Article Number (fiaawer from service label) 7010 3090 0001 0247 6&95 PS Form 3811, February 2004 Domestic Relum Receipt 102595-024A-15 gErtiDM CO AL-ETE rpir Tio`Ri El Complete items 1, 2, and 3. Also complete iters 4 if l restricted DeIi?ery is desired. o Print your name and address on the reverse so that we can return the card to you. Ti Attach this card to the back of the mailplece, or on the front if space permits. 1. Article Addressed io: Ginger Funk Texas Eastern Skyline ._OiLC ins (AKA Spectra Energy) 5400 Wertheimer Court Houston, TX 77056 0 Agent 0 Address, roe D. IS delivery address dil erent from item 1 If YES. enter delivery address below: 0 No 3. Service Type ® Car lied Mail 0 Ezooreas Mail 0 Registered 0 Return Receipt for Merchandi: 0 Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) ® Yes 2. Article Number (Transfer From service label) 70101 3090 0001 0247 7311 PS Form 3.g11, February 2004 ti Domesiic Return Receipt 102596.0244.1E SDIDER arAIPL,EviE TOM ar7©Ti ▪ G4411plete sterns 1, 2, and 2. Also complete iters 4 it Restricted Delivery s dssirod. ▪ Print your name and addre s on the reverse so that we can return the card o you. e Attach this card to the back of the mailpiece, or on the front If space permits. 1. AR` cie Addressed to: Y i Paul Keifer Exxon/Mobil Corporation 810 Houston St Fort Worth, TX 76102 B. Received by ((tined Name) C. Date ol.(7l ink ZV ' D. is delivery address cligarent from item 1? 0 Yes If YES, enter delivery address below: 0 No S. Service Type. ® Csiii"ted Mail 0 Registered 0 Ind Mail 0 Express Mail 0 Return Receipt for Merchendi: 0 C.O.D. 4. Restricted DaIivcry? (airs Fee) 0 `fes 2. '.\rticie Nrnert- transfer from .service label) &ti 3090 0001 024328 PS Form ni 1, Februai 20 Do s.tic Return Receipt 102595-0241-1° A. Garfield County MEMORANDUM Community Development 108 8th Street, Suite 401, Glenwood Springs. CO 81601 Office: 970-945-8212 Fax: 970-384-3470 TO: Board of County Commissioners FROM: Glenn Hartmann, Senior Planner DATE: July 14, 2014 SUBJECT: Call -Up Request Regarding the Director's Decision Ursa Speakman A Injection Well (GAPA-7835) EXHIBIT 1 I. BACKGROUND- PROCESS On May 30, 2014, A Director's Decision Letter was issued by the Director of the Community Development Department for conditional approval of a General Administrative Land Use Change Permit for the Ursa Speakman A Injection Well Application. On June 5, 2014, the Community Development Department received a request from the Battlement Mesa Concerned Citizens to Call -Up the decision for review by the Board of County Commissioners (a copy of the request is attached as an exhibit). While the request was within the 10 day call-up it did not technically meet the adjacent property owner requirement. The Board of County Commissioner's considered the question of whether to call up the request at their June 9th meeting. In accordance with Section 4-112 of the Land Use and Development Code. the Board exercised its option to call up the request for review as the Board of County Commissioners. The Board set the date for the public hearing on July 14th Public notice for the hearing is required consistent with the original notice required by the Code for the Director's Decision. In this case the notice required is a mailing notice 15 days prior to the hearing. Public notice pursuant to the Code has been completed by the Community Development Department and has been reviewed by the County Attorney's Office. II. DIRECTOR'S DECISION — STAFF REPORT Copies of the Director's Decision letter and Staff Report are attached and included as exhibits for the public hearing. The Staff Report includes referral comments from a number of review agencies, comprehensive plan topics, impact issues and studies (including traffic), access issues, and information on site characteristics. Subsequent to the Staff Report referral comments from the Division of Water Resources (indicated no comment) and updated traffic counts from Road and Bridge were received and are included as exhibits. The site is an active drill pad with ongoing drilling activities occurring since the staff site visit. The Director's Decision letter was for a conditional approval. The conditions cover topics such as drainage, site plan and vehicle circulation, storm water management, spill prevention, operations, emergency response, air quality, wildlife mitigation, traffic and compliance with required Colorado Oil and Gas Conservation Commission permitting and review requirements. III. PUBLIC COMMENTS A. As documented in the call up request, the Battlement Mesa Concerned Citizens raised questions regarding (dated 6/5/14): • Potential seismic activity as a result of the injection well and the possible need for future monitoring and public notification. • Traffic and trucking impacts along with timing for operation of a proposed pipeline system. B. The County Received correspondence from Monique Speakman (dated 6/11/14) regarding the call-up request addressing scheduling concerns and indicating that the injection well will help address impacts. IV. APPLICANT RESPONSES A. The Applicant through their consultants Olsson & Associates has provided responses to the conditions of approval contained in the Director's Decision. The response letter and attachments have been included as an exhibit with this packet. In general the responses indicate an agreement to comply with the conditions of approval or the provision of additional documentation to comply with the conditions. The response letter includes the following: • Additional drainage engineering information. • Updated site plan with internal circulation delineated. • Dust Control Plan. • Copy of the Emergency Response Plan including Wildfire Mitigation Measures. B. Ursa Operating Company has provided a letter of response (dated 6/11/14) to the call up request dealing with scheduling concerns and outlining Ursa's efforts to address public concerns. V. ADDITIONAL STAFF ANALYSIS & TECHNICAL INFORMATION A. Seismic Issues Included with the Board's Packet is a summary memo and attachments from the County Oil and Gas Liaison, Kirby Wynn addressing public comments regarding seismic potential from injection wells. The memo includes an analysis of the issue by COGCC and mapping of injection wells in the vicinity of Battlement Mesa and the Town of Parachute. The COGCC analysis indicates the permitting, rules, policies. and safeguards they require in regard to injection wells. Compliance with all COGCC permits and forms along with conditions/requirements is included as Condition #7 in the Director's Decision Letter. Additional information from the United States Department of the Interior, Geological Survey has been provided and includes a technical article on seismic risk posed by wastewater disposal. B. Traffic & Trucking Issues Based on the Application submittals the proposed injection well will reduce the current traffic by 1/3 by the elimination of trucking from one of the three well pads in the Battlement Mesa area. The Speakman A Well Pad will no longer require trucking as the water generated on the site will be disposed of through the proposed injection well on the site. The haul route will change for the existing well pads and will no longer be directed north toward Battlement Mesa and the main 1-70 Parachute Interchange. In response to questions related to the timing for implementation of the pipeline system serving the two adjacent well pads the Applicant's consultants provided a response reconfirming that "Ursa hopes to complete a pipeline delivery system for fluids within the next three years." (see attached) C. Code Compliance Additional staff review and coordination with Zoning Enforcement staff has noted a code compliance issue that the property owner has been dealing with regarding grading and weed management. The Land Use and Development Code does not allow issuance of a Land Use Change Permit where this is an outstanding code compliance issue on a property. The property owner has verbally provided information on corrective efforts that have occurred (grading & plowing/harrowing) and are planned in the future (re -seeding of the site for agricultural production). Staff is comfortable that the issue has been resolved pending approval of the Applicant's plan by the County's Vegetation Manager. VI. BOARD OF COUNTY COMMISSION ACTION Option A: Uphold the Director Decision for Conditional Approval The Board can direct staff to prepare a resolution upholding the Director's Decision for approval with conditions, including the findings outlined below and the conditions of approval from the Director's Decision, #1 - #14. Staff supports the Board consideration of an additional condition of approval under Option B to address the code compliance issue. Suggested Findings 1. That proper public notice was provided as required for the hearing before the Board of County Commissioners. 2. The hearing before the Board of County Commissioners was extensive and complete, that all pertinent facts, matters and issues were submitted and that all interested parties were heard at a the meeting. 3. That for the above stated and other reasons the proposed Land Use Change Permit for the Ursa Speakman A Small Injection Well Facility is in the best interest of the health, safety, convenience, order, prosperity and welfare of the citizens of Garfield County. 4. That with the adoption of conditions, the application is in general conformance with the 2030 Comprehensive Plan, as amended. 5. That with the adoptions of conditions the application has adequately met the requirements of the Garfield County Land Use and Development Code, as amended. Option B: Modify the Director's Decision The Board can direct staff to prepare a resolution for approval based on the findings outlined above with the conditions of approval from the Director's Decision subject to any modifications based on the Board's deliberation. Outlined below is a suggested additional condition based on drainage and weed management issues on the balance of the Speakman property. Draft Condition #15 15. The Applicant and property owner shall provide the County with a plan for minor re -grading and re -seeding of disturbed portions of the Speakman property outside of the Injection Well facility. Said plan including timing for completion shall be subject to approval by the County Vegetation Manager. Option C: Overturn the Director's Decision Should the Board wish to overturn the Director's Decision the Board may formalize a motion for denial of the Land Use Change Permit with direction to staff to draft an appropriate resolution and findings. , Garfield County May 30, 2014 Community Development 108 8th Street, Suite 401, Glenwood Springs, CO 81601 Office: 970-945-8212 Fax: 970-384-3470 Lorne Prescott, Olsson Associates 760 Horizon Drive, Suite 102 Grand Junction, CO 81506 € EXHIBIT RE: Director's Decision Administrative Review Ursa Operating Company LLC, Speakman A Small Injection Well (File GAPA-7835) Dear Lorne: This letter is being provided to you as the authorized representative for Ursa Operating Company LLC, James Speakman and Monique Speakman in regard to the General Administrative Review Application for a Small Injection Well, known as the Speakman A Injection Well. The proposed use is located at approximately 5242 County Road 300 on property also known by Assessor's Parcel No. 2409-244-00-124. The Director's Decision on the Application is based on the following findings and subject to the Applicant's representations and conditions of approval. 1. That proper public notice was provided as required for the Director's Decision. 2. Consideration of the Application was extensive and complete, that all pertinent facts, matters and issues were submitted and that all interested parties were given the opportunity to provide input prior to the Director's Decision. 3. That for the above stated and other reasons the proposed Land Use Change Permit for the Ursa Speakman A Small Injection Well Facility is in the best interest of the health, safety, convenience, order, prosperity and welfare of the citizens of Garfield County. 4. That with the adoption of conditions, the application is in general conformance with the 2030 Comprehensive Plan, as amended. 5. That with the adoptions of conditions the application has adequately met the requirements of the Garfield County Land Use and Development Code, as amended. A Director's Decision is hereby issued approving the Application subject to the following conditions: 1. That all representations made by the Applicant in the application shall be conditions of approval unless specifically altered by the conditions of approval. 2. That the Ursa Speakman A, Small Injection Well Facility shall be operated in accordance with all applicable Federal, State, and local regulations governing the operation of this type of facility. 3. Prior to issuance of the Land Use Change Permit, the Applicant shall provide updated drainage information and/or designs adequate to address the referral comments from the County's Consulting Engineer, Chris Hale. 4. Prior to issuance of the Land Use Change Permit, the Applicant shall provide an updated site plan including designation of truck circulation areas within the well pad to be used for truck delivery traffic. The site plan shall also address circulation patterns to be implemented when active drilling and placement of a drill rig on the well pad occurs. Prior to issuance of the Land Use Change Permit, the Applicant shall provide an updated dust control plan for the site and access roads with more specifics on the timing of watering and application of dust suppressing chemicals. The plan shall include the well pad area surrounding the injection well facilities. 6. The facility shall maintain compliance with CDPHE Storm Water Management Permits, Drainage and Grading Plans, Reclamation and Erosion Control Plans for the site. 7. The Applicant shall maintain all required COGCC permits and forms for the facility and shall comply with all conditions or requirements of said permits and forms. 8. The facility shall maintain compliance with COGCC Noise Standards/Regulations and the facility shall be required to utilize an electric pump as represented. If future compliance issues are identified the Applicant shall provide noise mitigation in order to achieve compliance along with a technical evaluation by a qualified professional to confirm compliance. 9. The Applicant shall comply with all SPCC Plan provisions and shall keep the plan current and updated for any changes to the facility. 10. As represented in the Application the facility shall have only termporary lighting for unscheduled night time maintenance. All lighting shall comply with Section 7-306 Lighting, with all lighting to be directed inward and doward toward the interior of the site. Facilities and storage tanks shall be painted a non -glare neutral color to lessen any visual impacts. 11. The Emergency Response Plan shall be updated to include a section on response to and prevention of field or wild land fires. Separation between the injection well pad facilities and native vegetation at the perimeter of the site shall be maintained. 12. The Applicant shall maintain all required CDPHE permits for the facility including any applicable air quality, APEN permits. 13. The Applicant shall comply with the referral comments from Colorado Parks and Wildlife (CPW) including compliance with the Battlement Mesa Wildlife Mitigation Plan. Said plan and agreement between Ursa Operating Company and CPW includes a limitation on Trucking to between the hours of 10:00 a.m. and 3:00 p.m., when and where possible, compliance with COGCC Noise Regulations and use of bear proof trash containers for all food related trash. 14. The Applicant shall comply with the access representations and Traffic Report including limiting trucking to the designated haul route and the limitation to a maximum of 20 daily water truck deliveries to the facility. The daily trucking limitation may be calculated based on a weekly average to account for minor operational variations. Trucking of water to the site shall utilize watertight tanks and shall comply with all COGCC or CDOT requirements for hauling of production water. This Director's Decision will be forwarded to the Board of County Commissioners for a period of 10 days so that they may determine whether or not to call up the application for further review. Once this time period has passed with no request for review or public hearing, and provided all relevant conditions of approval have been resolved the Land Use Change Permit will be issued. Please contact this department if you have any questions. Sincerely, Tamra Allen, AICP Planning Manager, Community Development Department an .ecd lc�oe_ CC: Board of County Commissioners Kelly Cave, Assistant County Attorney A -11-x( EXHIBIT 1 7 Director Decision 5/29/14 File No. GAPA-7835 GH PROJECT INFORMATION AND STAFF COMMENTS REQUEST General Administrative Land Use Change Permit for a Small Injection Well Facility PROPERTY OWNER James Speakman and Monique Speakman APPLICANT Ursa Operating Company LLC ASSESSOR'S PARCEL # 2409-244-00-124 PROPERTY SIZE The facility will be located on a 4.6 acre site which is within an overall 78.25 acre parcel. LOCATION ACCESS The property is located at approximately 5242 County Road 300, approximately 0.75 miles southwest of the Battlement Mesa Community, in Section 24, T7S, R96W. The facility is accessed by private roadways off of County Road 300 including a portion of what is known as Daybreak Drive. EXISTING ZONING The property is zoned (R) Rural I. GENERAL PROJECT DESCRIPTION The Applicant is requesting an Administrative Land Use Change Permit for a Small Injection Well, with less than 5,000 bbls of production water storage. The facility will be located on an existing COGCC approved well pad. It will be subject to COGCC Rule 325, and Forms 31 and 33 for injection wells. COGCC Form 26 is also required to address the source of the produced water to be handled by the injection well. The Facility will include the following equipment: • One injection well and electric pump • Six storage tanks totally between 1,800 and 3,000 bbls • 3 ft. high containment wall for the tank battery • Two combusters • A valve set 1 • A 20 ft. by 50 ft. (maximum size) electric pump building • Two foot high earthen berm on the site perimeter Produced water from local Ursa facilities will be transported to the site initially by truck and in the future by pipeline. Two Ursa well pads just south of Battlement Mesa will be served by the injection well facility. Traffic generation projections and a Traffic Analysis have been provided which include the proposed hauling routes. The Facility will be monitored typically during daylight hours by an Ursa Employee. A dust mitigation program will be implemented and CDPHE Air Quality permits will be obtained if required (may be required for the storage tanks). A Storm Water Management Plan has been prepared with storm water management improvements and Best Management Practices already implemented and/or planned for the site. 2 Monitoring, alarm, and remote shut down controls are planned for the facility. The Application also includes an area wide Spill Prevention Control and Countermeasures Plan and which includes specific details for the Ursa - Speakman site. Containment as required by COGCC will be implemented for the production water storage tanks associated with the injection well. The projected storage amount is consistent with the standard for a small injection well facility (less than 5,000 bbls). The site is currently covered by a statewide bond for reclamation and reclamation plans are included in the Application submittals. A noxious weed management plan has been prepared for the site. Lighting will only occur during unscheduled nighttime activities and minimal noise impacts are anticipated based on the use of electric pumps. Site Plan Speakman A Pad 1W1/4 Of The SEIM4. The NE I/4 Of The SE 1/4 & A Portion Of the NE1/4 Of the SW 1/4, _ • ' +ection 24, Township 7 South, Range 96 Weal, / ' 1 ` _ _ y `• i, �w Of the 6th Principal Meriden, / Count Of Garfield, State Of Colorado j `/ ° — r j / 44 —6 - 1 - ' ,p .' �r. ..r.. j j \i /' // - s. Mµ c. / •w.. Mr X '/'\ / / \ /' i . 1.1 i \ / Production Water Storage for Injection Well Injection Well Pump Building SITE PLAN \ / \ A \ \N. t \ \ \ Injection Well 4w \ \ N, • \ \ \\ \ \ MOONY N.rs t. 111.4"1". ••M••V n,.r 0041. W .1, 1. n.n.M1 ww.Y \ a p\` \ \ \ 1 \ \ \\\ \\ \ \ \ N .,,,,,.......„_ \\ \\ "!,!4 \"..." --.Ln.,,,_"----,--.—...4 \\ hjk ti NO 4 _\ 44 rob Graphic Baas 1UIaRl N a 3 Benefits outlined in the submittals include minimizing new impacts on wildlife, reduced road maintenance, engineered controls for transfer system reducing potential for human error, reduction in transportation costs. II. LOCATION - SITE DESCRIPTION The site is currently a developed COGCC well pad with approximately 12 existing wells and plans for up to a total of 25 wells for the site. Land uses within 1,500 ft. include agricultural uses, natural gas extraction, public lands and a portion of open space within the adjoining Battlement Mesa PUD. Developed portions of the PUD including RV uses and residential homes are slightly farther from the site, estimated at another 150 ft. northeast of the site (total distance of 1,650 ft. +/-). Rural residential homes and properties are also located immediately west and north of the site and some distance south of the site. The site slopes up moderately from the County Road with the well pad graded and leveled out of the slope. The site is graded to slope down from the well pad on the north, west and east perimeters. The site slopes up to the south along the access road alignment. Ursa Speakman Site Aerial Photo 4 Native vegetation surrounding the site is generally sagebrush, with some pinion and juniper woodlands. No additional native vegetation will be removed for the proposed facility and the placement of the project on an existing well pad will minimize additional impacts. The site is located on a terrace above the Colorado River which is approximately 2,000 ft. to the northeast. Dry Creek is located approximately 1,645 ft. to the west. III. PUBLIC COMMENTS AND REFFERAL AGENCY COMMENTS Public Notice was provided for the Director's Decision in accordance with the Garfield County Land Use and Development Code as amended and included mailing notice to all property owners within 200 ft. and any mineral rights owners on the property. The Applicant has provided evidence of compliance with the notice requirements. Comments from referral agencies, County Departments, and the public are summarized below and attached as Exhibits. 1. Garfield County Consulting Engineer, Chris Hale, Mountain Cross Engineering: • Provided technical questions regarding the drainage engineering and calculations. 2. Garfield County Road and Bridge Department, Dan Goin District 3 Foreman: • No written comments were received, however, Dan Goin provided verbal comments that they did not have any concerns and had reviewed the haul routes. 3. Garfield County Vegetation Manager, Steve Anthony: • Provided comments indicating that the weed management plan is acceptable and that with the location on an existing well pad reclamation falls under the jurisdiction of the COGCC. 4. Garfield County Environmental Health: Morgan Hill, Environmental Health Specialist noted the following topics. • Support for Air Quality Permitting. • Recognized the importance of adherence to the SWMP and SPCC plans. • Noted safety concerns related to traffic. 5. Colorado Parks and Wildlife: • Noted the location is within a mapped area for Mule Deer severe winter range and Elk winter concentration range. • Indicated that the site is within a 1/4 mile of the Colorado River in an area of critical habitat for four federally listed fish species. • Noted the agreement with Ursa Operation Company regarding the Battlement Mesa Wildlife Mitigation Plan (BMWMP) which covers the site and the need to comply with provision of that plan including limited hours for trucking activity, 5 compliance with COGCC noise limits, and use of bear proof dumpsters/trash receptacles for food related trash. 6. Town of Parachute: • Submitted a letter indicating that the Town had no issues regarding granting the application. 7. Colorado Division of Water Resources: • Submitted a letter indicating that they had no comments at this time. 8. Battlement Mesa Concerned Citizens: • Verbally contacted the Community Development Department and noted general concerns with traffic (haul routes & traffic counts), noise, air quality, and use of current technology for installations. 9. Other referral agencies that did not submit comments include: (a) the Colorado Department of Public Health and Environment Water Quality Division and Air Quality Division; (b) Bureau of Land Management; (c) Grand Valley Fire Protection District; (d) Battlement Mesa Service Association; and (d) Battlement Mesa Metro District.. IV. STAFF COMMENTS AND ANALYSIS In accordance with the Land Use and Development Code, the Applicant has provided detailed responses to the Submittal Requirements and applicable sections of Article 7, Divisions 1, 2, and 3, including Section 7-1001 Industrial Use Standards. The Application materials include an Impact Analysis and related consultant reports, technical studies, and plans. 7-101 — 103: Zone District Regulations, Comprehensive Plan & Compatibility The proposed use demonstrates general conformance with applicable Zone District provisions contained in the Land Use and Development Code and in particular Article 3 standards for the Rural Zone District. The Comprehensive Plan 2030 designates the site as RMH (Residential Medium High Density). Excerpts from the Land Use Description Section Chapter 2 and Section 8, Natural Resources and Section 9, Mineral Extraction are provided below. Chapter 2 — Land Use Designations Residential Medium High (RMH): Small farms, estates, and clustered residential subdivision; density determined by degree of clustering and land preserved in open condition. 6 Section 8 — Natural Resources Issues *The county maintains high air quality standards, however there may be a propensity for air pollutants to exist in the western part of the county Goals 1. Ensure that natural, scenic, ecological, and critical wildlife habitat resources are protected and /or impacts mitigated. 4. Ensure the appropriate reclamation of land after extraction processes. Policies 1. The County will encourage and cooperate with the protection of critical habitat including state and federally protected, threatened, or endangered species. Section 9 — Mineral Extraction Goals 1. Ensure that mineral extraction is regulated appropriately to promote responsible development and provide benefit to the general public. 2. Ensure that mineral extraction activities mitigate their effects on the natural environment, including air quality, water quality, wildlife habitat or important visual resources. 3. In working with mineral extraction projects, the county will protect the public health, safety and welfare of its citizens. Policies 2. Mineral resource extraction activities will protect critical wildlife habitat as identified by state and federal agencies. Development within these designations that cannot be designed, constructed and conducted so as to have a minimum adverse impact upon such habitat or these wildlife species shall be discouraged. 4. Facilities that are appurtenances to oil/ gas development activities (compressors, etc.) are considered appropriate in all land uses so long as they meet the respective mitigation requirements of the LUDC to maintain compatibility with surrounding land uses. The location and design of the proposed facility is in general conformance with the Comprehensive Plan Policies subject to proper mitigation of impacts. Comprehensive Plan Future Land Use Map - Excerpt Ursa Speakman Ste The Application has also provided information on neighboring land uses indicating the general character of the area. The request demonstrates general compatibility with adjoining uses provided proper mitigation is implemented and compliance with conditions and COGCC regulations maintained. 7-104 & 105: Source of Water & Waste Water Systems The Application represents that the facilities will operated with only occasional staff activities. The proposal demonstrates that the uses will be adequately served by provision of water in individual staff vehicles and provision of portable toilets on site per OSHA standards. 3. The Application also includes extensive documentation that the water for injection is from non -tributary sources addressing any Division of Water Resources issues. 7-106: Public Utilities The site will be served with electricity to be provided by Holy Cross Energy for the operation of the electric pump for the injection well. Holy Cross facilities are currently found on portions of the site with easement locations for service line extensions to be determined. Service will be to the pump building located along the westerly perimeter of the site. 8 OIL AND GAS ACTIVITY AND PIPELINE MAPPING Ursa Speakman Site 7-107: Access & Roadways • PIPELINES = Purple, Green and Tan Lines OTHER ACTIVITES (INCL. WELLS) = Red Triangles The Applicants access their property from County Road 300 via private roads including Daybreak Lane. The applicant has provided a detailed analysis of the roadway including engineering representations. The submittal reflects compliance with the County's Roadway Standards as contained in Table 7-107. Dust control and ongoing maintenance are considerations that should be included as conditions of approval. The Applicant's Traffic Study identifies that truck traffic associated with the three Ursa Well Pads to be served by the injection well will be reduced by approximately 1/3 when the injection well becomes operational (reduction from 30 total trips to 20 total trips). The truck haul route will also be significantly shortened and will no longer connect to the main Parachute 1-70 Interchange but will run along the east edge of the Battlement Mesa PUD on County Road 303, County Road 300, and Stone Quarry Road. 9 The Traffic Study further documents that the traffic generation will be a minor increase based on existing volumes and noted that all intersections where site traffic will be turning are expected to be adequate. No requirements for County or State permitting were noted and no deficiencies identified. 7-108: Natural Hazards The Application provides significant information on natural hazards including information on soils, geology, and slopes. The information supports a determination that the proposed use is not subject to significant natural hazard risks. 7-109: Fire Protection The Application includes an Emergency Response Plan for the site that includes notification procedures for the Grand Valley Fire Protection District. The District received a referral packet but did not submit comments. The only structure proposed for the facility is the electric pump building. The Fire Protection District maintains facilities and equipment within the Battlement Mesa PUD. 7-201: Agricultural Lands With no new disturbed areas no additional impacts on nearby agricultural lands are anticipated. The well pad is not currently fenced and the proposed facility does not propose any changes. 7-202: Wildlife Habitat Areas The Applicant has provided an Environmental Impact Report, completed by WestWater Engineering, dated February 2014. The report indicates that no special status plant species are expected to occur in the project area. The report also addressed threatened, endangered or candidate species and noted a number of species that may be found in Garfield County including some species of fish with habitat in the Colorado River near the site. The report concludes that other than the fish no other species are expected in the area of the site as habitat conditions are not appropriate. The Study also addressed potential for raptor nesting and concluded that the sparse vegetation on the site provides poor to marginal nesting habitat. No raptor nests were found within 0.25 miles of the site. The study notes that the project is placed within the boundaries of an existing development and therefore avoids cumulative impacts on habitats. The Report concludes that "The development of the project is not expected to significantly affect any critical environmental resources." 10 7-203: Protection of Water Bodies Potential impacts on water bodies has been addressed by the Storm Water Management Plan (permit), drainage plans, and Spill Prevention Containment and Countermeasures Plans for the site. The site location is on a terrace above the Colorado River which is approximately 2,000 ft. to the northeast. Dry Creek is located approximately 1,645 ft. to the west and a drainage swale is located east of the site. Distance from these features along with the engineered drainage plans for the site mitigate the potential for impacts. 7-204: Drainage and Erosion (Stormwater) The Applicant has provided a copy of the State Storm water Management Permit and Plans applicable to the site. The Applicant has also provided Best Management Practices including areas already stabilized and re -vegetated. The drainage report concludes that due to the low runoff of the historic and existing conditions, no detention is required for the site, however a temporary detention feature is designed to be in place during construction of the injection well. Referral comments from the County's Consulting Engineer should be addressed as conditions prior to the issuance of the Land Use Change Permit. 7-205 Environmental Quality Air quality permits from CDPHE associated with the injection well are not anticipated base on the use of an electric pump and the request by the Applicant that the production water tanks be considered exempt. The condensate tanks currently on site are used in conjunction with well production and are regulated by COGCC and CDPHE. A recommended condition of approval shall call for the Applicant to obtain and keep current all permits as required by the CDPHE and maintain compliance with all conditions contained therein. Storm Water Management Permits, Installation of Best Management Practices, SPCC Plans, and Reclamation and Erosion Control Plans address protection of water quality. Compliance with all COGCC Permitting requirements and conditions is also an essential component of ensuring environmental issues including type of water injected, the formation injected into and the capacity of the well are addressed. 7-206: Wildfire Hazards The site is located in an area mapped with low to moderate wildfire hazard. Only a single pump house structure is proposed and no comments were received from the Fire Protection District. The site plan shall maintain a separation between the facilities and natural vegetation. The Emergency Response Plan shall be updated to include provisions regarding Field or Wildland Fire Prevention and response. 11 7-207 Natural and Geologic Hazards The Geologic Hazard Report addresses a broad range of potential hazards including landside, rock fall, soils, alluvial fans and slopes. No significant hazards to the proposed facility were noted in the report and the site is not located within a flood plain. 7-208: Reclamation The Applicant has included a reclamation plan that addresses re -vegetation and reclamation issues. A reclamation bond with the State is currently in place and shall be maintained to include well pad reclamation associated with the injection well facility. 7-301 & 302: Compatible Design, Parking, and Loading The proposed use is consistent with and compatible with typical oil and gas exploration and production activities. Large areas of the site plan are available for parking, circulation, and loading activities. 7-303: Landscaping As an industrial use landscaping submittals and standards are not applicable to the proposal. 7-304: Lighting No permanent lighting is proposed and the Application makes reference to only using lighting during unscheduled night time maintenance activities. Any lighting shall be required to meet the County standards for being down directed, shielded, and oriented toward the interior of the site. 7-305 Snow Storage Adequate portions of the site plan are available for snow storage and can be accommodated by the drainage and storm water management plans. 7-306 Trails Trails standards are generally not applicable based on the industrial nature of the proposal and surrounding uses. 7-1001 INDUSTRIAL USE STANDARDS The Application represents that the facility will comply with all the Industrial Use Standards contained in Section 1001. The Application contains a variety of documents to support compliance and the following summary addresses key issues. 12 • The facility is currently visually screened along the north and eastern portions of the well pad by a sound buffering installation. Once drilling activities are completed the existing buffer will be removed. • Hours of operation for the injection well pump are effectively 24 hours a day. However other support or maintenance activities should be conducted between the hours of 7 a.m. and 6 p.m. as represented in the application. In addition the Applicant's Wildlife Mitigation Plan (BMWMP) and agreement with Colorado Parks and Wildlife call for a limitation on trucking to between 10:00 a.m. and 3:00 p.m., when and where possible. • All industrial products and wastes will be stored in accordance with all applicable state and federal regulations. • The Applicant represents that COGCC noise limits will be adhered to and has provided a noise estimate to support that representation which does not assume any mitigation from the existing barrier. Consistent with the noise estimate the Applicant shall be limited to use of an electric pump for the injection well. Ongoing compliance with the noise standard shall be required including once the noise mitigation barrier is removed after the completion of drilling activities. • No other nuisance or ground vibration hazards are anticipated based on type of use. V. ADDITIONAL STAFF ANALYSIS Future pipelines to serve the injection well are encouraged as a means to further reduce traffic impacts. Any future pipelines will need to comply with the County's permitting requirements or be determined to be exempt. Pipelines that are over 2 miles in length and greater than 12 inches in diameter or pipelines 5 miles or greater are required to be permitted by the County. VI. SUGGESTED FINDINGS 1. That proper public notice was provided as required for the Director's Decision. 2. Consideration of the Application was extensive and complete, that all pertinent facts, matters and issues were submitted and that all interested parties were given the opportunity to provide input prior to the Director's Decision. 3. That for the above stated and other reasons the proposed Land Use Change Permit for the Ursa Speakman A Small Injection Well Facility is in the best interest of the health, safety, convenience, order, prosperity and welfare of the citizens of Garfield County. 4. That with the adoption of conditions, the application is in general conformance with the 2030 Comprehensive Plan, as amended. 5. That with the adoptions of conditions the application has adequately met the requirements of the Garfield County Land Use and Development Code, as amended. 13 VII. RECOMMENDATION The following recommended conditions of approval are provided for consideration as part of the Director's Decision for approval of the Application. 1. That all representations made by the Applicant in the application shall be conditions of approval unless specifically altered by the conditions of approval. 2. That the Ursa Speakman A, Small Injection Well Facility shall be operated in accordance with all applicable Federal, State, and local regulations governing the operation of this type of facility. Conditions Prior to Issuance Prior to issuance of the Land Use Change Permit, the Applicant shall provide updated drainage information and/or designs adequate to address the referral comments from the County's Consulting Engineer, Chris Hale. 4. Prior to issuance of the Land Use Change Permit, the Applicant shall provide an updated site plan including designation of truck circulation areas within the well pad to be used for truck delivery traffic. The site plan shall also address circulation patterns to be implemented when active drilling and placement of a drill rig on the well pad occurs. Prior to issuance of the Land Use Change Permit, the Applicant shall provide an updated dust control plan for the site and access roads with more specifics on the timing of watering and application of dust suppressing chemicals. The plan shall include the well pad area surrounding the injection well facilities. Other Conditions 6. The facility shall maintain compliance with CDPHE Storm Water Management Permits, Drainage and Grading Plans, Reclamation and Erosion Control Plans for the site. 7. The Applicant shall maintain all required COGCC permits and forms for the facility and shall comply with all conditions or requirements of said permits and forms. 8. The facility shall maintain compliance with COGCC Noise Standards/Regulations and the facility shall be required to utilize an electric pump as represented. If future compliance issues are identified the Applicant shall provide noise mitigation in order to achieve compliance along with a technical evaluation by a qualified professional to confirm compliance. 9. The Applicant shall comply with all SPCC Plan provisions and shall keep the plan current and updated for any changes to the facility. 14 10. As represented in the Application the facility shall have only termporary lighting for unscheduled night time maintenance. All lighting shall comply with Section 7-306 Lighting, with all lighting to be directed inward and doward toward the interior of the site. Facilities and storage tanks shall be painted a non -glare neutral color to lessen any visual impacts. 11. The Emergency Response Plan shall be updated to include a section on response to and prevention of field or wildland fires. Separation between the injection well pad facilities and native vegetation at the perimeter of the site shall be maintained. 12. The Applicant shall maintain all required CDPHE permits for the facility including any applicable air quality, APEN permits. 13. The Applicant shall comply with the referral comments from Colorado Parks and Wildlife (CPW) including compliance with the Battlement Mesa Wildlife Mitigation Plan. Said plan and agreement between Ursa Operating Company and CPW includes a limitation on Trucking to between the hours of 10:00 a.m. and 3:00 p.m., compliance with COGCC Noise Regulations and use of bear proof trash containers for all food related trash. 14. The Applicant shall comply with the access representations and Traffic Report including limiting trucking to the designated haul route and the limitation to a maximum of 20 daily water truck deliveries to the facility. The daily trucking limitation may be calculated based on a weekly average to account for minor operational variations. 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TU.�-�r " 3 •� CU - i> bOu O u cu . �•-' E Q) CL4 V V O7.1'O H cu u O a, ct a) p 0 O • fifi CCS v U� o cn c75 U o Ow -2 1-4 al 0-1 F1 Fes.., u t!I rim 0 rr_ rm= 0 bJD • r-, +4 (ICS �, O \p Cl) • 5 � tpOOi 1-0 Modify the Director's Decision 0 0 o v 77:11 Tlj 0 •1-4 bPi.,0-4 °cj F) 8 0 cL) ci, -4- 0 4 Oma'^c.) � OC� cn�.� v 77) raCI) O 0 cCS O rci;. '573Ocz5 a)u o (ID ci)s -4 0 0 cn E o aA E -q El Draft Condition #15 ,--4 v Uoa) cu '-4— _ C v bt CJD eX4 .:411 n v o E •- O b° p %4-_< a� 0 bA • �-+ brU o ars ¢' o-4 v •,E4 cf)� 0 u (2)Cu o� 4 ct H1.4, o u Overturn the Director's hould the Board wish to overturn the 0 N •=' 4u ctl O 4-4 cri U bt • c� EoP7i (75 cC1 .C4 O F--1 Cf) CU 0 all 4-4 CU •p O - 4-4 - •� •v,c� •�ci) ,..� ; cu • 2.4 .O E May 28, 2014 Mr. Glenn Hartman Garfield County Planning 108 8th Street, Suite 401 Glenwood Springs, CO 81601 MOUNTAIN CROSS �'� ENGINEERING, INC. Civil and Environmental Consulting and Design RE: Review of Speakman A Injection Well: GAPA-7835 Dear Glenn: EXHIBIT This office has performed a review of the documents provided for the Administrative Review Application of the Speakman A Injection Well. The submittal was found to be thorough and well organized. The following comments were generated: 1. There appears to be fill that will be generated with the re -grading of the well pad. The Applicant should address how the fill will be managed. 2. There is a large discrepancy in the areas between the Historic and the Existing basin delineations of the drainage analysis. It appears that the existing condition may split the Historic delineation into two basins, however only one basin appears to be included in the analysis. The Engineer for the Applicant should provide an explanation of how the basin delineations were determined or revise the analysis to include the remaining area of the Historic basin. 3. The Engineer for the Applicant should provide more detail on how the 1 -hour precipitation depths are determined from the 24-hour precipitation events. 4. The narrative for Section 7-204. Drainage and Erosion, in the Standards Analysis portion of the application materials describes detention that is different than proposed in the drainage analysis. This should be reviewed and the discrepancies reconciled. Feel free to call if you have any questions or comments. Sincerely, Mountan Cross En in eri , Inc. C 's Hale, PE 8261/2 Grand Avenue, Glenwood Springs, CO 81601 P: 970.945.5544 F: 970.945.5558 www.mountaincross-eng.com Glenn Hartmann From: Dan Goin Sent: Thursday, May 29, 2014 12:50 PM To: Glenn Hartmann Subject: Traffic Counts Attachments: CR 300 Stone Quary Rd 2014 Traffic Count Study.rtf; CR 3000 Old Stone Quary Rd. 2014 Traffic Count Study.rtf; CR 303 Gardner Lane 2014 Traffic Count Study.rtf EXHIBIT I ro Here's the traffic counts you asked for. Let me know if there's anything else you need.\ Thank you. Dan 1 AADT-157 - English (ENU) Datasets: Site: Input A: Input B: Survey Duration: Zone: File: Identifier: Algorithm: Data type: Profile: Filter time: Name: Scheme: Units: In profile: MetroCount Traffic Executive Adjusted Flow [CR 300] BOR CR 300 Stone Quarry 2014 Traffic Study 8 - East bound A>B, West bound B>A. - Lane= 0, Added to totals. (/2.000) 0 - Unused or unknown. - Lane= 0, Excluded from totals. 8:00 Wednesday, April 30, 2014 => 16:23 Wednesday, May 07, 2014 CR 30007May2014.ECO (Plus) R556ZXFF MC56-L5 [MC55] (c)Microcom 190ct04 Event Count (v3.21 - 15275) Axle sensors - Paired (Class/Speed/Count) 8:00 Wednesday, April 30, 2014 => 16:23 Wednesday, May 07, 2014 Default Profile Count events divided by setup divisor Non metric (ft, mi, ft/s, mph, Ib, ton) Events = 7000 / 7000 (100.00%) Day Hits RawVol DayFac MonFac AdjVol 0 1 1 562.000 1.000 1.000 2 1 530.500 1.000 1.000 3 1 494.500 1.000 1.000 4 1 363.500 1.000 1.000 5 1 469.000 1.000 1.000 6 1 566.000 1.000 1.000 7 Total days = 6, Coverage = 1.64% ADT = 497.583, SD = 75.787 AADT = 497.583, SD = 75.787 Weekdays = 4, Coverage = 1.10% AWDT = 531.875, SD = 44.823 AAWDT = 531.875, SD = 44.823 Weekend days = 2, Coverage = 0.55% AWET = 429.000, SD = 92.631 AAWET = 429.000, SD = 92.631 562.000 - 530.500 - 494.500 - 363.500 - 469.000 - 566.000 - ADT and adjustment factor by month Jan Feb Mar Apr May - Vol = 2985.500, Days = 6, ADT = 1.00000 Jun Jul Aug Sep Oct Nov Date Wednesday, April 30, 2014 Thursday, May 01, 2014 Friday, May 02, 2014 Saturday, May 03, 2014 Sunday, May 04, 2014 Monday, May 05, 2014 Tuesday, May 06, 2014 Wednesday, May 07, 2014 497.583, Adjust = 1.00000, 1/Adjust = Dec ADT and adjustment factor by day of week Mon - Vol = 469.000, Days = 1, ADT = 469.000, Adjust = 1.06095, 1/Adjust = 0. 94256 Tue - Vol = 566.000, Days = 1, ADT = 566.000, Adjust = 0.87912, 1/Adjust = 1.13750 Wed Thu - Vol 562.000, Days = 1, ADT = 562.000, Adjust = 0.88538, 1/Adjust = 1.12946 Fri - Vol = 530.500, Days 1, ADT = 530.500, Adjust = 0.93795, 1/Adjust = 1.06615 Sat - Vol = 494.500, Days 1, ADT = 494.500, Adjust = 1.00624, 1/Adjust = 0.99380 Sun - Vol = 363.500, Days = 1, ADT = 363.500, Adjust = 1.36887, 1/Adjust = 0.73053 AADT-154 -- English (ENU) Datasets: Site: Input A: Input B: Survey Duration: Zone: File: Identifier: Algorithm: Data type: Profile: Filter time: Name: Scheme: Units: In profile: MetroCount Traffic Executive Adjusted Flow [CR 303] CR 303 Gardner Lane 2014 Traffic Study 8 - East bound A>B, West bound B>A. - Lane= 2, Added to totals. (/2.000) 0 - Unused or unknown. - Lane= 0, Excluded from totals. 8:00 Wednesday, April 30, 2014 => 15:36 Wednesday, May 07, 2014 CR 30307May2014.EC2 (Plus) U764DSC4 MC56-L5 [MC55] (c)Microcom 190ct04 Event Count (v3.21 - 15275) Axle sensors - Paired (Class/Speed/Count) 8:00 Wednesday, April 30, 2014 => 15:36 Wednesday, May 07, 2014 Default Profile Count events divided by setup divisor Non metric (ft, mi, ft/s, mph, Ib, ton) Events = 6584 / 6584 (100.00%) Day Hits RawVol DayFac MonFac AdjVol .0 1 1 747.500 1.000 1.000 747.500 2 1 485.000 1.000 1.000 485.000 3 1 383.000 1.000 1.000 383.000 4 1 295.500 1.000 1.000 295.500 5 1 401.000 1.000 1.000 401.000 6 1 487.000 1.000 1.000 487.000 7 Total days = 6, Coverage = 1.64% ADT = 466.500, SD = 155.066 AADT = 466.500, SD = 155.066 Weekdays = 4, Coverage = 1.10% AWDT = 530.125, SD = 150.356 AAWDT = 530.125, SD = 150.356 Weekend days = 2, Coverage = 0.55% AWET = 339.250, SD = 61.872 AAWET = 339.250, SD = 61.872 ADT and adjustment factor by month Jan Feb Mar Apr May - Vol = 2799.000, Days = 6, ADT = 1.00000 Jun Jul Aug Sep Oct Nov Date Wednesday, April 30, 2014 Thursday, May 01, 2014 Friday, May 02, 2014 Saturday, May 03, 2014 Sunday, May 04, 2014 Monday, May 05, 2014 Tuesday, May 06, 2014 Wednesday, May 07, 2014 466.500, Adjust = 1.00000, 1/Adjust = Dec ADT and adjustment factor by day of week Mon - Vol = 401.000, Days = 1, ADT = 401.000, Adjust = 1.16334, 1/Adjust = 0.85959 Tue - Vol = 487.000, Days = 1, ADT = 487.000, Adjust = 0.95791, 1/Adjust = 1.04394 Wed Thu - Vol = 747.500, Days = 1, ADT = 747.500, Adjust = 0.62408, 1/Adjust 1.60236 Fri - Vol = 485.000, Days = 1, ADT = 485.000, Adjust = 0.96186, 1/Adjust = 1.03966 Sat - Vol = 383.000, Days = 1, ADT = 383.000, Adjust = 1.21802, 1/Adjust = 0.82101 Sun - Vol = 295.500, Days = 1, ADT = 295.500, Adjust = 1.57868, 1/Adjust = 0.63344 AADT-153 -- English (ENU) Datasets: Site: Input A: Input B: Survey Duration: Zone: File: Identifier: Algorithm: Data type: Profile: Filter time: Name: Scheme: Units: In profile: MetroCount Traffic Executive Adjusted Flow [CR 3000] CR 3000 Old Stone Quary Rd 2014 Traffic Count Study 8 - East bound A>B, West bound B>A. - Lane= 0, Added to totals. (/2.000) 0 - Unused or unknown. - Lane= 0, Excluded from totals. 8:00 Wednesday, April 30, 2014 => 15:25 Wednesday, May 07, 2014 CR 300007May2014.ECO (Plus) GPO8FJPN MC56-L5 [MC55] (c)Microcom 190ct04 Event Count (v3.21 - 15275) Axle sensors - Paired (Class/Speed/Count) 8:00 Wednesday, April 30, 2014 => 15:25 Wednesday, May 07, 2014 Default Profile Count events divided by setup divisor Non metric (ft, mi, ft/s, mph, Ib, ton) Events = 3319 / 3319 (100.00%) Day Hits RawVol DayFac MonFac AdjVol 0 1 1 273.000 1.000 1.000 273.000 2 1 281.000 1.000 1.000 281.000 3 1 211.500 1.000 1.000 211.500 4 1 161.500 1.000 1.000 161.500 5 1 241.000 1.000 1.000 241.000 6 1 260.000 1.000 1.000 260.000 7 Total days = 6, Coverage = 1.64% ADT = 238.000, SD = 44.992 AADT = 238.000, SD = 44.992 Weekdays = 4, Coverage = 1.10% AWDT = 263.750, SD = 17.462 AAWDT = 263.750, SD = 17.462 Weekend days = 2, Coverage = 0.55% AWET = 186.500, SD = 35.355 AAWET = 186.500, SD = 35.355 ADT and adjustment factor by month Jan Feb Mar Apr May - Vol 1428.000, Days = 6, ADT = 1.00000 Jun Jul Aug Sep Oct Nov Date Wednesday, April 30, 2014 Thursday, May 01, 2014 Friday, May 02, 2014 Saturday, May 03, 2014 Sunday, May 04, 2014 Monday, May 05, 2014 Tuesday, May 06, 2014 Wednesday, May 07, 2014 238.000, Adjust = 1.00000, 1/Adjust = Dec ADT and adjustment factor by day of week Mon - Vol = 241.000, Days = 1, ADT 241.000, Adjust = 0.98755, 1/Adjust = 1.01261 Tue - Vol = 260.000, Days = 1, ADT = 260.000, Adjust = 0.91538, 1/Adjust = 1.09244 Wed Thu - Vol = 273.000, Days = 1, ADT = 273.000, Adjust = 0.87179, 1/Adjust = 1.14706 Fri - Vol = 281.000, Days = 1, ADT = 281.000, Adjust = 0.84698, 1/Adjust = 1.18067 Sat - Vol = 211.500, Days = 1, ADT = 211.500, Adjust = 1.12530, 1/Adjust = 0.88866 Sun - Vol = 161.500, Days = 1, ADT = 161.500, Adjust = 1.47368, 1/Adjust = 0.67857 May 29, 2014 Garfield Coun Glenn Hartmann Garfield County Community Development Department RE: Speakman - GAPA 7835 Dear Glenn, Vej'etation Manajiement EXHIBIT 1 11 The Noxious Weed Management Plan and Reclamation Plan are acceptable. This facility is on an existing pad, therefore all reclamation issues fall under the jurisdiction of the Colorado Oil and Gas Conservation Commission. Please let me know if you have any questions. Sincerely, G/ Steve Anthony Anthony Garfield County Vegetation Manager 0375 County Road 352, Bldg 2060 Rifle, CO 81650 Phone: 970-945-1377 x 4305 Fax: 970-625-5939 Glenn Hartmann From: Morgan Hill Sent: Thursday, May 29, 2014 11:04 AM To: Glenn Hartmann Subject: Speakman A Ursa Injection Well Referral Comments Hi Glenn, EXHIBIT /Z My comments on the Speakman A Ursa Injection Well are as follows: - Air quality: o Permitting requirements seem to be fully covered, which only include the tank battery. o Thank you for acknowledging that Ursa will apply appropriate controls to minimize potential impacts to air quality and nuisance conditions. Please continue to maintain strict controls to minimize impacts to adjacent lands due to the close proximity to occupied structures. o Also due to the close proximity to occupied structures, Ursa should be careful to minimize dust and other air emissions in the construction of pipelines connecting to the injection well when those are constructed. Water Quality: o There are multiple draws in the proximity to the existing and proposed well pad which have the potential to transport pollutants to the Colorado River as it is located fairly close. From my observations, the applicant does have an adequate SWMP and SPCC plan; however, I once again encourage strict adherence to the controls mentioned in both of these plans to minimize potential impacts. Safety and Welfare: o We appreciate the attempts to minimize truck traffic in both the construction and operation phases of this project. Since trucks will be traveling along roads used by residents of Battlement Mesa, Ursa employees and their sub -contractors should be sure to use caution and reduce speeds for the safety of pedestrians and other road users. From: Glenn Hartmann Sent: Thursday, May 29, 2014 8:57 AM To: Morgan Hill Subject: RE: Referral Comments Hi Morgan: Thanks for your follow-up. I'm working on that file this morning and plan on presenting a staff report/recommendation to Tamra this afternoon, so today certainly works for your comments. If you can get them to me by lunch or early afternoon that would be great, otherwise as soon as possible. Thanks in advance for your input. Glenn. Glenn Hartmann Community Development Department From: Morgan Hill Sent: Wednesday, May 28, 2014 2:28 PM To: Glenn Hartmann Subject: Referral Comments Hi Glenn, Today has been a bit on the busy side and hasn't left time for me to get my comments in for the Ursa Injection well - would tomorrow be OK? 1 COLORADO PARKS & WILDLIFE 6060 Broadway • Denver, Colorado 80216 Phone (303) 297-1192 cpw.state.co.us 05-25-14 To: Glenn Hartmann Garfield County Community Development Department 108 8th Street, Suite 401, Glenwood Springs, CO 81601 RE: GAPA - 7835 EXHIBIT Thank you for the opportunity to comment on the proposed injection well facility to be located 0.75 miles southwest of the Battlement Mesa Community (Section 24, T7S, R96W). Colorado Parks and Wildlife (CPW) has a statutory responsibility to manage all wildlife species in Colorado; this responsibility is embraced and fulfilled through the CPW's mission to protect, preserve, enhance, and manage the wildlife of Colorado for the use, benefit, and enjoyment of the people of Colorado and its visitors. We encourage Garfield County to afford the highest protection for Colorado's wildlife species and habitats through the development and implementation of management actions combined with the use of best management practices (BMPs) to protect wildlife and their habitats. The project location is utilized year-round by many species of game and non -game wildlife. The site lies within an area mapped by the CPW as mule deer severe winter range and elk winter concentration range. Additionally, the proposed site lies less than a ' mile from the Colorado River in an area of critical habitat for four federally listed fish species. In June 2011, Ursa Operating Company (formerly Antero Resources) entered into an agreement with the Colorado Parks and Wildlife (CPW) known as the Battlement Mesa Wildlife Mitigation Plan (BMWMP). This document was intended to provide guidance in the development of the Antero's natural gas resources in the Battlement Mesa area so that impacts to local wildlife would be minimized or mitigated. Since the proposed site is within the boundaries of the established BMWMP, the CPW recommends that the 2011 WMP is utilized during the planning and development of this project. The CPW's chief wildlife concem is the increase in disturbance to wildlife (particularly during the winter months) caused by water trucks delivering produced water to the facility. By adhering to the agreed upon Best Management Practice (BMP) of limiting truck traffic to the hours of 10 am — 3 pm when and where possible, negative impacts to big -game can be greatly reduced. Also, by following the recommended BMP of utilizing buried waterlines to transport fluids to the facility, traffic disturbance concems can be virtually eliminated. STATE OF COLORADO John W. Hickeniooper, Govamor • Nike King, Executive Director, Department of Natural Resources Bob D. Broscheld, Director, Colorado Parks and Wildlife Parka and Wildlife Commission: Robert W. Bray • Chris Castilian, Secretary • Jeanne Home Bill Kane, Chair • Gaspar Penicone • James Pribyl • John Singletary Mark Smith, Vice -Chair • James Vigil • Dean Wingfield • Michelle Zimmerman Ex Officio Members: Mike King and John Salazar CPW recommends that sound mitigation be used for any compressors or injection pumps associated with the facility and its operations. CPW expects that sound mitigation measures would be consistent with the 800 series COGCC Rules for aesthetic and noise control. Finally, in accordance with COGCC Rule 1204 a-1, the CPW recommends that bear - proof dumpsters and trash receptacles be utilized for all food -related trash on location to minimize nuisance bear issues in the area. If you have any questions, please feel free to contact Scott Hoyer, District Wildlife Manager for Parachute at 970-250-0873. JT Romatzke Area Wildlife Manager Colorado Division of Wildlife rn Wn- 1 EXHIBIT 7rcku tI /it - 222 Grand Valley Way Parachute, Colorado 81 635 (970) 285-7630 Stuart S. McArthur, Town Administrator May 9, 2014 Garfield County Building and Planning Department ATTN: Glenn Hartmann 108 8th Street, Suite 401 Glenwood Springs, CO 81601 SUBJECT: SPEAKMAN URSA "A" INJECTION WELL - GAPA-7835 The purpose of this letter is to respond to your Referral Form dated April 30, 2014, for File Number GAPA - 7835. The Town of Parachute has no issues regarding granting this application. If you have any additional questions or concerns, please contact me at 970-285-7630. Sincerely you ti Stu rt S. McArthur Town Administrator SSMc Glenn Hartmann From: Franco - DNR, Ivan [ivan.franco@state.co.us] Sent: Friday, May 23, 2014 8:45 AM To: Glenn Hartmann Subject: Speakman Ursa A Injection Well Mr. Hartmann, EXHIBI Thank you for the opportunity to review the above referenced referral, however the Colorado Division of Water Resources does not have any comments to offer at this time. Sincerely, Ivan Franco, E.I.T. Water Resources Engineer Water Supply Team P 303.866.3581 x8243 1 F 303.866.3589 1313 Sherman Street, Room 818, Denver, CO 80203 Ivan.Franco@state.co.us 1 www.water.state.co.us 1 Glenn Hartmann1 I (0 From: Dave Devanney [dgdevanney@comcast.net] Sent: Thursday, June 05, 2014 2:59 PM To: Glenn Hartmann; Fred Jarman Cc: Powers Jeff; Simpson Don Subject: BCC: GAPA-7835 hearing request Fred and Glenn — RE: File no. GAPA-7835 EXHIBIT On behalf of the members of Battlement Concerned Citizens (BCC), we are requesting a hearing with regard to the referenced injection well permit application. We have identified two areas that we feel should have further consideration. 1. The Community Development staff report does not address the issue of possible seismic activity as a result of this injection well. We request that the county require that Ursa cease and desist from all current and future injection well operations at the Speakman A site, in the event of any detected seismic activity within a one mile radius of the site. The source of such detection shall be any state or federal agency responsible for earthquake monitoring. A level of two (2) or more (minor) on the Richter scale could be set. If necessary, seismic monitoring equipment should be provided. Recent news stories from around the state and nation are raising questions about the potential link between seismic activity and proximity to injection wells. See news report from Greeley by clicking here. Residents of Battlement Mesa are concerned with the growing number of injection wells near their community and the significant negative impact that could result in the event of seismic activity. We also ask that a Battlement Concerned Citizens (BCC) representative be notified in the event of such activity. 2. The Community Development staff report indicates that Ursa plans to put a pipeline in place in the future and that truck traffic will be reduced by one-third. We request that the county require that Ursa, within 60 days of receiving approval, have pipeline capability in place, to move the produced water to the injection well site from the other local well -pads. Once in place, there should be no need for truck traffic on or near Stone Quarry Road in the vicinity of these well -pads, except in emergency situations, for the transport of produced water for injection. Residents of Battlement Mesa are already concerned and have complained about the high volume of truck traffic near their homes and would like assurance that the volume 1 will be decreased, and thereby, the noise, vibration and wear & tear on their roadways. Further, we ask that Garfield County monitor the volume of truck traffic in that area of Stone Quarry Road, on a periodic basis, and compare current values with historic values, in order to detect truck traffic trends. We also ask that a Battlement Concerned Citizens (BCC) representative be notified of such results. We are planning to attend the BOCC meeting in Parachute next Monday to verbally present this request to the county commissioners. Please advise us if you have any comments or suggestions. Sincerely, Dave Devanney, BCC co-chair Doug Saxton, BCC member COPIED: Jeff Powers, Ursa Don Simpson, Ursa 2 Glenn Hartmann From: Jiggs [gwevens@q.com] Sent: Saturday, June 07, 2014 12:09 PM To: Glenn Hartmann Cc: Devanney, Dave Subject: hearing for file no. GAPA-7835 EXHIBIT 117 We request a hearing for further information about the proposed injection well application from Ursa. Since BMSA is an adjacent landholder and we are owners in the Battlement Mesa PUD we are members and have an ownership interest in all properties held by the BMSA. Garry and Bettie Evenson 122 Mineral Springs Circle Battlement Mesa CO 68 Meadow Creek Drive Parachute, CO 81635 June 1, 2014 Dear Commissioners: Since we will be out of the state when you hold your meeting in Parachute June 9, I'm sending this letter to each of you. Once again the Battlement Mesa community is facing the possibility of natural gas drilling WITHIN the PUD. URSA bought out Antero and first said they would extract the gas from outside, but now they have a plan for 4 well pads right in the core of the community. You will have the right to exercise a veto to this plan since URSA must obtain a special use permit (SUP). I hope you will do so. Two of the well pads would be by the golf course. One would be by #6, and as stated previously with Antero, is close to a declared wetlands area, a runoff that eventually goes to the Colorado River. Witt Homes years ago had been told that they couldn't build the Villas in that area, so why take a chance with a drilling operation? Because of the sensitive nature of these wells, the original plan calls for underground pipelines. Eventually this would eliminate a lot of truck traffic, but during the construction we would be subjected to dirt, noise, air pollution, excessive traffic, etc.—and at great expense to URSA. Wouldn't it be better for them to spend their money drilling farther underneath our community from outside the PUD on existing or new pads? At this time, technology allows for drilling as far away as 3 miles from a well pad. If URSA can't do that, perhaps they're not the company to be drilling here, and they, too, should sell to one that can do the job without disrupting the community. Remember, Battlement Mesa is a PUD, and there are strict rules about commercial and residential development. Does it make sense to destroy the community with heavy industry? Extraction of natural gas should not supersede the quality of life. Please do your duty and reject this plan by URSA. Sincerely, V� tir��L�,Zc Sandra Getter Richard Getter June 11, 2014 Garfield County Commissioners Re: June 16th BOCC Agenda request Dear Andrew Gorgey: EXHIBIT I `1 I am Monique Speakman, joint owner, with James Eugene Speakman, of the property located at 5242 County Road 300 in Parachute. James and I are requesting to be added to your BOCC agenda, on June 16, 2014 in reference to the Injection Well approval being delayed. We are requesting reconsideration , of the call up hearing, in reference to Injection Well approval, be rescheduled from July 14, 2014 to July 7, 2014. I was unable to attend the June 9, 2014 meeting due to an extreme family emergency. Had I been able to attend, I would've expressed our support for the board to issue final approval of the Injection Well process. I would like to address the BOCC, regarding this matter, in the afternoon session, on the June 16, 2014. The permitting process began in February and the state has stated that the approval will be granted by the end of June. That process appeared to have gone smoothly. However, when it entered the next stage of county approval, it has stalled, and mostly because of a small group of people. The call out was granted to them, even though it was supposed to only apply if you were within 200 feet of the adjacent property owner, which they are not. This, has now created a delay in development and payments in royalties to ourselves, as property owners, It has also delayed the ability to reduce truck traffic on roads, dust, and noise in Battlement Mesa, which is the most common complaint. The approval of this injection well would reduce all of this. Please email or call me or James with any questions . My cell phone is 970-355-4067. James's cell phone is 970-208-4338. Sincerely, Monique Speakman Cc: John Martin Vola Mercer, admin assistant to County manager and BOCC Fred Jarman, Director of Community Development Tamra Allen, Planning Manager Kirby Wynn, Oil and Gas Liaison Ursa Operating Company LLC 1050 17t`' St., Suite 2400, Denver, CO 80265 June 11, 20114 Garfield County Commissioners John Martin, Mike Samson and Tom Jankovsky 108 8th Street Glenwood Springs, CO 81601 Subject: Garfield County Commissioners Meeting set for July 14 Proposed Speakman UIC well Parachute Area Garfield County, CO Dear Honorable Commissioners, EXHIBIT lzo On June 9th, Ursa Operating Company attended the Garfield County Commissions meeting in Parachute where there was public comment was given concerning the county permit for a UIC well at Ursa's Speakman A Pad location. We appreciate the County's acknowledgement of Ursa's public outreach during this meeting. Ursa prides itself on communicating with the public regarding its planned operations and the Speakman UIC well is no different in this respect. In this Commissioners Meeting, the Battlement Mesa Concerned Citizens (BMCC) were provided an additional comment and protest period, 28 days past the June 9th Commissioners meeting. BMCC acknowledged at this meeting that they did not meet the requisite requirement of an adjacent landowner to have legal standing for a call-up. Ursa believes that BMCC's request to schedule a hearing at this stage in the process, given they had ample opportunity to engage Ursa, is concerning and only serves in further delaying development of the mineral interests supported by many Battlement Mesa residents and potentially delays the reduction of water truck traffic in the community in the case a disposal well would be in place. Ursa Operating Company hereby states for the record, its stance regarding the recent Battlement Mesa Concerned Citizens (BMCC) protest and their request for a delayed hearing regarding the permitting of above disposal well. While Ursa agrees that public comment is valuable, to schedule a public comment / hearing at this late stage in the process, we believe falls outside of the County review and permit approval process. In addition, further pushing back of the originally proposed date of July 7th until the 14th seems unnecessary. Ursa provides the following points regarding BMCC's request; 1. It is misleading for the representatives of the BMCC to state in a public meeting that they represent the Battlement Mesa Community. There is a Battlement Mesa Oil and Gas Committee set up specifically to address issues. Regardless, the Speakman UIC well is located outside of the Battlement Mesa Community proper. 2. Notification were provided under the COGCC pad permitting process (aka Form 2A). In addition, notifications were given under COGCC UIC Rules 31 ad 35. Since the end of last year, Ursa has held regularly scheduled meetings with the BMCC, as well as other local groups regarding this disposal well as well as any other issues of Ursa's planned development. 4. Discussion of any concerns was available to the community at the monthly Garfield County Energy Advisory Board meetings, which are attended by key members of the BMCC. Although Ursa announced the proposed disposal well, no comment or concern was given by the BMCC or any of its members. 5. The UIC well was discussed in Ursa's March semi-annual presentation meeting held in Parachute, which was well attended and where the community asked questions and Ursa answered those questions. 6. At the request of BMCC, Ursa made a special presentation on May 9th, which was attended by some BMCC members, as well as others in the community and by Garfield County Officials. In said presentation, Ursa answered questions not only regarding the Speakman disposal well, but also disposal wells in general. Given the facts above, Ursa believes that there was adequate opportunity to public comment, therefore Ursa respectfully requests that either the public/hearing date be moved back to the original July 7th date or in the alternative no last minute protest or request for additional comment period be provided in the future, especially in an instance such as this one, when many opportunities for comment have been available all along the process. If you should have any questions regarding stakeholder and community relations, do not hesitate to me by email at dsimpson@ursaresources.com or by phone at 720-508-8367. In my absence Jeff Powers may be contacted at 920-329-4376. Permitting issues should be directed to Rob Bleil, Regulatory Manager at 720 425-0303. Sincerely, Don Simpson Vice President of Business Development CC: Fred Jarman, Garfield County, Community Development Director Drew Gorgy, Garfield County Manager Kirby Wynn, Garfield County Oil & Gas Liaison Rob Bleil, Ursa Regulatory and Environmental Manager Jeff Powers, Ursa Field Landman Glenn Hartmann From: Lorne Prescott [Iprescott@olssonassociates.com] Sent: Monday, June 16, 2014 2:24 PM To: Glenn Hartmann Cc: Cari Mascioli; Rob Bleil; Tilda Evans; Jeff Hofman Subject: Hartman, GARCO request for info related to lnj well, pipe EXHIBIT 1 zf Glenn, I got your voice message and discussed your request with my client. In terms of the information we can provide towards our disclosure(s) for the permit: We will adhere strictly to the details which were provided with our application submittal. Please see below. From the Project Narrative: Ultimately, Ursa intends to construct a series of pipelines to deliver fluids from the well source(s) to the injection well. Ursa will begin working on a temporary surface line that will deliver fluids to the facility with the next 12 months. Pending approval of permanent line/layout routes, Ursa hopes to complete a pipeline delivery system for fluids within the next three years. From the Standards Narrative: In time, a pipeline will be constructed to pipe produced water to the injection well in order to cut down on the number of trucks needed to haul water and to decrease opportunities for environmental impacts due to water hauling by truck. Lorne C. Prescott 1 Senior Scientist Olsson Associates 760 Horizon Drive, Suite 102 1 Grand Junction, CO 81506 1 Iprescott c� olssonassociates.com TEL 970.263.7800 I DIRECT: 970.263.6014 1 FAX 970.263.7456 OLSSON® ASSOCIATES tfll Please consider the environment before printing this e-mail 1 OLSSON o ASSOCIATES July 2, 2014 Tamra Allen Garfield County Community Development 108 8th Street, Suite 401 Glenwood Springs, Colorado 81601 Re: Ursa Operating Company LLC Speakman A Small Injection Well (File GAPA-7835) Dear Ms. Allen, EXHIBIT i ZZ This letter serves to respond to the Conditions of Approval (COA) for the Director's Decision approving Ursa Operating Company's (Ursa) Speakman A Small Injection Well (UIC), dated May 30, 2014. 1. That all representations made by the Applicant in the application shall be conditions of approval unless specifically altered by the conditions of approval. Response: Ursa acknowledges that the representations made in the application will be adhered to. 2. That the Ursa Speakman A, Small Injection Well Facility shall be operated in accordance with all applicable Federal, State, and local regulations governing the operation of this type of facility. Response: Ursa will operate the UIC in accordance with all applicable Federal, State, and local regulations goveming the operation of the injection well. 3. Prior to issuance of the Land Use Change Permit, the Applicant shall provide updated drainage information and/or designs adequate to address the referral comments from the County's Consulting Engineer, Chris Hale. Response: Additional drainage information is included with this letter that address the referral comments of Chris Hale. Item 1 of Matrix Design Group's letter indicates that Olsson Associate provides erosion control and construction activity permit monitoring. Actually, HCSI provides these services for Ursa. Also included in this submittal is an updated Standards Analysis revising Section 7-204 per Matrix's letter. 4. Prior to issuance of the Land Use Change Permit, the Applicant shall provide an updated site plan including designation of truck circulation areas within the well pad to be used for truck delivery traffic. The site plan shall also address circulation patterns to be implemented when active drilling and placement of a drill rig on the well pad occurs. Response: An updated site plan showing truck circulation during and after active drilling operations is included with this letter. 760 Horizon Drive, Suite 102 TEL 970.263.7800 Grand Junction, CO 81506 FAX 970.263.7456 www.olssonassociates.com Ursa Operating Company LLC Speakman A Small Injection Well (GAPA-7835) 5. Prior to issuance of the Land Use Change Permit, the Applicant shall provide an updated dust control plan for the site and access roads with more specifics on the timing of watering and application of dust suppressing chemicals. The plan shall include the well pad area surrounding the injection well facilities. Response: An updated Dust Control Plan is included with this letter. 6. The facility shall maintain compliance with CDPHE Storm Water Management Permits, Drainage and Grading Plans, Reclamation and Erosion Control Plans for the site. Response: Ursa will maintain compliance with the CDPHE Stormwater Management Permits, Drainage and Grading Plans, Reclamation and Erosion Control Plans for the site. 7. The Applicant shall maintain all required COGCC permits and forms for the facility and shall comply with all conditions or requirements of said permits and forms. Response: Ursa will maintain all required COGCC permits and will comply with all conditions or requirements for these permits. 8. The facility shall maintain compliance with COGCC Noise Standards/Regulations and the facility shall be required to utilize an electric pump as represented. If future compliance issues are identified the Applicant shall provide noise mitigation in order to achieve compliance along with a technical evaluation by a qualified professional to confirm compliance. Response: Ursa will maintain compliance with COGCC Noise Standards and Regulations. An electric pump will be used as represented in the application. Ursa will provide noise mitigation as required to maintain compliance. 9. The Applicant shall comply with all SPCC Plan provisions and shall keep the plan current and updated for any changes to the facility. Response: Ursa will comply with the SPCC Plan provisions and will keep the plan updated and current for the facility. 10. As represented in the Application the facility shall have only temporary lighting for unscheduled night time maintenance. All lighting shall comply with Section 7-306 Lighting, with all lighting to be directed inward and doward toward the interior of the site. Facilities and storage tanks shall be painted a non -glare neutral color to lessen any visual impacts. Response: Only temporary lighting during unscheduled night time maintenance will be utilized at the facility. Any lighting will comply with Section 7-306 Lighting and be directed inward and downward toward the interior of the site. Facilities and storage tanks will be painted a non- glare neutral color to blend in with the surrounding area. 11. The Emergency Response Plan shall be updated to include a section on response to and prevention of field or wild land fires. Separation between the injection well pad facilities and native vegetation at the perimeter of the site shall be maintained. Response: An updated Emergency Response Plan that address response and prevention of field and wild land fires is included with this letter. Separation between the injection well pad facilities and native vegetation will be maintained. 12. The Applicant shall maintain all required CDPHE permits for the facility including any applicable air quality, APEN permits. Response to Conditions of Approval Page 2 Ursa Operating Company LLC Speakman A Small Injection Well (GAPA-7835) Response: Ursa will maintain all required CDPHE permits including applicable air quality, APEN permits. 13. The Applicant shall comply with the referral comments from Colorado Parks and Wildlife (CPW) including compliance with the Battlement Mesa Wildlife Mitigation Plan. Said plan and agreement between Ursa Operating Company and CPW includes a limitation on Trucking to between the hours of 10:00 a.m. and 3:00 p.m., when and where possible, compliance with COGCC Noise Regulations and use of bear proof trash containers for all food related trash. Response: Ursa will comply with referral comments from Colorado Parks and Wildlife including compliance with the Battlement Mesa Wildlife Mitigation Plan. Trucking will be limited to between 10:00 am and 3:00 pm, when and where possible. As noted above, Ursa will comply with COGCC Noise Regulations. Bear proof trash containers will be utilized for all food related trash. 14. The Applicant shall comply with the access representations and Traffic Report including limiting trucking to the designated haul route and the limitation to a maximum of 20 daily water truck deliveries to the facility. The daily trucking limitation may be calculated based on a weekly average to account for minor operational variations. Trucking of water to the site shall utilize watertight tanks and shall comply with all COGCC or CDOT requirements for hauling of production water. Response: Ursa will comply with access representations and will limit trucking to the designated haul route with a maximum of 20 daily water truck deliveries to the facility. Truck tanks will be watertight. Ursa will comply with COGCC and CDOT requirements for hauling of production water. I believe this should satisfy all of the Conditions of Approval. Please let us know if you have any questions or need further information. Sincerely, Lorne Prescott Senior Project Scientist Enclosures: Matrix Design Group Response Letter Revised Standards Analysis Revised Site Plan Dust Control Plan Revised Emergency Response Plan Cc: Rob Bleil, Ursa Operating Company Response to Conditions of Approval Page 3 • a rixkl1114fk DESIGN GROUP Ihe River Valley Survey c/o Mr. Scott Aibner PLS 110 E. 3rd Street Rifle, Colorado 81650 2435 Research Parkway, Suite 300 Colorado Springs, Colorado 80920 Phone: 719.575.0100 Fax: 719.575.0208 matrixdesigngroup.com RE: Speakman A Pad Garfield County Engineer Response Dear Scott, The following is a point response to the comments by Mountain Cross Engineering in their letter dated May 28, 2014 regarding the Speakman A Injection Well: GAPA-7835. 1. There appears to be fill that will be generated with the re -grading of the well pad. The Applicant should address how the fill will be managed. Soil stockpiling, management and final vegetative acceptance is to be addressed by the Olson and Associates consultant in the development of the erosion control and construction activity permit monitoring. 2. There is a Targe discrepancy in the areas between the Historic and the Existing basin delineations of the drainage analysis. It appears that the existing condition may split the Historic delineation in two basin, however only one basin appears to be included in the analysis. The Engineer for the Applicant should provide an explanation of how the basin delineations were determined or revise the analysis to include the remaining area of the Historic Basin. The mapping has been revised per our discussion. In Exhibit 1— the Historic basin size has been reduced to fit more naturally on the western ridgeline of the topography. Exhibit 2 identifies the Existing Basin 1 and Existing Basin 2 which combined marginally exceeds the acreage (0.41 acres) of Historic Basin 1. Basin flow summaries are in the table below. Basin Area % Imp. Tc Q (2 yr) Q (25 yr) H1 7.72 ac 2% 20.46 0.46 cfs 6.27 cfs El 6.40 ac 5% 22.20 0.51 cfs 5.15 cfs E2 1.73 ac 2% 16.98 0.11 cfs 1.54 cfs El & E2 8.13 ac 4.4% 22.20 0.61 cfs 6.48 cfs Basin El & E2 have been basin routed together for a combined discharge using the more conservative 8.13 acres, but does not credit the offsite reduction of 0.41acres. If the analysis is performed with a tributary area discharge of 7.72 acres the total flow is Denver Colorado Springs Phoenix Anniston Atlanta Wei/tile Parsons Pueblo Sacramento Washington, D.C. June 19, 2014 Page 2 below the historic amount due to the extended travel time through the pad. Referencing the larger acerage, the calculated 25 -year detention for the combined basin would be 429 cf per the Detention Volume by Rational Volume Method which is equivalent to 2' deep 14 -ft by 14 -ft. The proposed settlement/containment pond should be sized large enough to provide this minor amount of attenuation and an extended detention basin is not necessary. 3. The Engineer for the Applicant should provide more detail on how the 1 -hour precipitation depths are determined from the 24-hour precipitation events. The NOAA Atlas 2, Volume III — Colorado Precipitation -Frequency Atlas of the Western United States Pages 13-17 covers the Interpretation of Results. From the 6 -hour and 24- hour results of the Atlas, the 1 -hour precipitation -frequency values for the return periods 2 yr and 100 yr can be estimated using the equations in Table 11. Plotting the results on a nomogram is performed to obtain values for return periods greater than 2 year and less than 100 -year. As discussed on the phone, the new Atlas 14 has been uploaded online and 1 -hour precipitation -frequency values can be sourced from direct data from participating weather stations with NOAA. 4. The narrative for Section 7-204. Drainage and Erosion, in the Standards Analysis portion of the application materials describes detention that is different than proposed in the drainage analysis. Olson and Associates should modify the narrative to reflect the drainage report memorandum. Detention through the settlement basin is being proposed, and the narrative should be should be updated. Please let me know if you have any questions. Best Regards GreShaner, PE Attached: Exhibit 1 —Historic map, Exhibit 2 —Existing map, Hydrology Sheets matr,xdesigngroup. com of. -��*. — --' • • • • - \ \\\ \\\\ / • 0' I I i 1 3 ^4i —-- e 1 A 2 f \ \ / / ' / /' / i I l / 1 ,' /1 rI � \////r/r VV /7/ c,s' /,, r _1 r -tea r u i r . -_ r r' t i , r r r r r r t t� CALCULATION OF A PEAK RUNOFF USING RATIONAL METHOD Project Title: Catchment ID: Speak A Pad Drainage Historic -25 Year I. Catchment Hydrologic Data Catchment ID = H1 Area = 7.72 Acres Percent Imperviousness = 2.00 % NRCS Sal Type = C A, B. C, or D II. Rainfall Information I (inch/hr) = C1 * P1 /(C2 + Td)AC3 Design Storm Return Period, Tr = 25 years C1 = 28.50 C2= 10.00 C3= 0.786 P1= 1.10 inches (input return period for design storm) (input the value of C1) (input the value of C2) (input the value of C3) (input one -hr precipitation --see Sheet "Design Info") III. Analysis of Flow Time (Time of Concentration) for a Catchment Runoff Coefficient, C = Overide Runoff Coefficient, C = 5 -yr. Runoff Coefficient, C-5 = Overide 5 -yr. Runoff Coefficient, C = 0.38 0.16 (enter an overide C value if desired, or leave blank to accept calculated C.) (enter an overide C-5 value if desired, or leave blank to accept calculated C-5.) Illustration • overland Reach 1 flow LEGEND 0 Begaafng Flaw Direction Catchment Boundary NRCS Land Type Heavy Meadow Tillage/ Field Short Pasture/ Lawns Nearly Bare Ground Grassed Swales/ Waterways Paved A eas & Shallow Paved Swales (Sheet Flow) Conveyance 2.5 5 7 10 15 II 20 Calculations: Reach ID Overland Slope S Mt input Length L ft input 5 -yr Runoff Coeff C-5 output NRCS Convey- ance input Flow Velocity V fps output Flow Time Tf minutes output 0.0600 300 0.16 N/A 0.31 16.22 1 0.1500 789 2 3 4 5 Sum 1,089 IV. Peak Runoff Prediction Rainfall Intensity at Computed Tc, I = Rainfall Intensity at Regional Tc, I = Rainfall Intensity at User -Defined Tc, I = 2.14 inch/hr 2.42 inch/hr 2.42 inch/hr 8.00 3.10 4.24 8.00 8.00 Computed Tc = Regional Tc = User -Entered Tc = Peak Flowrate. Qp = Peak Flowrate, Qp = Peak Flowrate, Qp = 20.46 16.05 16.05 6.27 7.08 7.08 cfs cfs cfs Speakman Historic, Tc and PeakQ 6/19/2014, 1:59 PM CALCULATION OF A PEAK RUNOFF USING RATIONAL METHOD Project Title: Catchment ID: Speakman A Pad Drainage Existing -1 25 year I. Catchment Hydrologic Data Catchment ID = EX1 Area = 6.40 Acres Percent Imperviousness = 5.00 % NRCS Soil Type = C A, B, C, or D II. Rainfall Information I (inch/hr) = C1 * P1 /(C2 + Td)AC3 Design Storm Return Period, Tr = 25 years (input return period for design storm) C1 = 28.50 (input the value of C1) C2= 10.00 (input the value of C2) C3= 0.786 (input the value of C3) P1= 1.10 inches (input one -hr precipitation --see Sheet "Design Info") III. Analysis of Flow Time (Time of Concentration) for a Catchment Runoff Coefficient, C = Overide Runoff Coefficient, C = 5 -yr. Runoff Coefficient, C-5 = Overide 5 -yr. Runoff Coefficient, C = 0.39 (enter an overide C value if desired, or Leave blank to accept calculated C.) 0.18 (enter an overide C-5 value if desired, or leave blank to accept calculated C-5.) Illustration LEGEND 0 Beginning Flow Direction Catchment Boundary NRCS Land Type Heavy Meadow Tillage/ Field Short Pasture/ Lawns Nearly Bare Ground Grassed Swales/ Waterways Paved A eas & Shallow Paved Swales _ (Sheet Flow) Conveyance 2.5 5 7 10 15 A 20 Calculations: Reach ID Overland Slope S Mt input Length L ft input 5 -yr Runoff Coeff C-5 output NRCS Convey- ance input Flow Velocity V fps output Flow Time Tf minutes output 0.0560 300 0.18 N/A 0.31 16.26 1 2 3 4 0.0850 0.0640 0.1500 145 462 204 5 Sum 1,111 W. Peak Runoff Prediction Rainfall Intensity at Computed Tc, I = Rainfall Intensity at Regional Tc, I = Rainfall Intensity at User -Defined Tc, I = 2.05 inch/hr 2.41 inch/hr 2.41 inch/hr 8.00 2.33 1.04 8.00 2.02 3.80 8.00 3.10 1.10 Computed Tc = Regional Tc = User -Entered Tc = Peak Flowrate, Qp = Peak Flowrate, Qp = Peak Flowrate, Qp = -22.20 16.17 16.17 5.15 cfs 6.06 cfs 6.06 cfs Speakman Existing, Tc and PeakQ 6/19/2014, 1:46 PM CALCULATION OF A PEAK RUNOFF USING RATIONAL METHOD Project Title: Catchment ID: Speakman A Pad Drainage Existing 2 25 year I. Catchment Hydrologic Data Catchment ID = EX Area = Percent Imperviousness = NRCS Soil Type = 1.73 Acres 2.00 % C A. B, C, or D II. Rainfall Information I (inch/hr) = C1* P1 I(C2 + Td)AC3 Design Storm Return Period, Tr = 25 years (input return period for design storm) C1 = 28.50 (input the value of C1) C2= 10.00 (input the value of C2) C3= 0.786 (input the value of C3) P1= 1.10 inches (input one -hr precipitation --see Sheet "Design Info") III. Analysis of Flow Time (Time of Concentration) for a Catchment Runoff Coefficient, C = Overide Runoff Coefficient, C = 5 -yr. Runoff Coefficient, C-5 = Overide 5 -yr. Runoff Coefficient, C = 0.38 (enter an overide C value if desired, or leave blank to accept calculated C.) 0.16 (enter an overide C-5 value if desired, or leave blank to accept calculated C-5.) Illustration overland Reach 1 flow LEGEND 0 Beaming Flew Direction E -- Catchment Boundary NRCS Land Type Heavy Meadow Tillage/ Field Short Pasture/ Lawns Nearly Bare Ground Grassed Swales/ Waterways Paved A eas & Shallow Paved Swales (Sheet Flow) Conveyance 2.5 5 7 10 15 Q 20 Calculations: ID Overland Slope S ft/ft input 0.0730 1 1 0.0250 Length L ft input 5 -yr Runoff Coeff C-5 output NRCS Convey- ance input Flow Velocity V fps output Flow Time Tf minutes output 273 0.16 N/A 0.31 14.50 154 2 1 0.3500 142 3 4 5 Sum 569 IV. Peak Runoff Prediction Rainfall Intensity at Computed Tc, I = Rainfall Intensity at Regional Tc, I = Rainfall Intensity at User -Defined Tc, 1 = 2.35 inch/hr 2.65 inch/hr 2.65 inch/hr 8.00 1.26 2.03 9.00 5.32 0.44 Computed Tc = Regional Tc = User -Entered Tc = Peak Flowrate. Qp = Peak Flowrate, Qp = Peak Flowrate. Qp = —16.98 13.16 13.16 1.54 cfs 1.74 cfs 1.74 cfs Speakman Existing, Tc and PeakQ 6/19/2014, 2:05 PM CALCULATION OF A PEAK RUNOFF USING RATIONAL METHOD Project Title: Catchment ID: Speakman A Pad Drainage Existing Overall 25 year I. Catchment Hydrologic Data Catchment ID = EX Area = 8.13 Acres Percent Imperviousness = 4.40 % NRCS Sal Type = C A, B, C, or D II. Rainfall Information I (inch/hr) = C1 * P1 /(C2 + Td)"C3 Design Storm Return Period, Tr = 25 years (input return period for design storm) C1 = 28.50 (input the value of C1) C2= 10.00 (input the value of C2) C3= 0.786 (input the value of C3) P1= 1.10 inches (input one -hr precipitation --see Sheet "Design Info") III. Analysis of Flow Time (Time of Concentration) for a Catchment Runoff Coefficient, C = Overide Runoff Coefficient, C = 5 -yr. Runoff Coefficient, C-5 = Overide 5 -yr. Runoff Coefficient, C = 0.39 (enter an overide C value if desired, or leave blank to accept calculated C.) 0.18 (enter an overide C-5 value if desired, or leave blank to accept calculated C-5.) Illustration LEG[IID 0 Beginning Flaw Direction Catchment Boundary NRCS Land Type Heavy Meadow Tillage/ Field Short Pasture/ Lawns Nearly Bare Ground Grassed Swales/ Waterways Paved A eas & Shallow Paved Swales (Sheet Flow) Conveyance 2.5 5 7 10 15 20 Calculations: I Overland Slope S ft/ft input 0.0560 1 0.0850 2 0.0640 Length L ft input 5 -yr Runoff Coeff C-5 output NRCS Convey- ance input Flow Velocity V fps output Flow Time Tf minutes output 300 0.18 N/A 0.31 16.33 3 1 0.1500 145 462 204 4 5 Sum IV. Peak Runoff Prediction Rainfall Intensity at Computed Tc, I = 2.04 inch/hr Rainfall Intensity at Regional Tc, I = 2.41 inch/hr Rainfall Intensity at User -Defined Tc. I = 2.41 inch/hr 8.00 2.33 1.04 8.00 2.02 3.80 8.00 3.10 1.10 Computed Tc = Regional Tc = User -Entered Tc = Peak Flowrate, Qp = Peak Flowrate, Qp = Peak Flowrate, Qp = 22.26 16.17 16.17 6.48 cfs 7.64 cfs 7.64 cfs Speakman Elosting, Tc and PeakQ 6/20/2014, 12:09 PM C3i%s OLSSON ASSOCIATES Article 7 — Standards Analysis Ursa Operating Company LLC Speakman A Injection Well DIVISION 1. GENERAL APPROVAL STANDARDS SECTION 7-101. ZONE DISTRICT USE REGULATIONS Small Injection Wells are allowed upon review and approval of an Administrative Review application within the Rural zone district. SECTION 7-102. COMPREHENSIVE PLAN AND INTERGOVERNMENTAL AGREEMENTS The overall project facility generally conforms to the Garfield County Comprehensive Plan. The proposed use is not within an area governed by an intergovernmental agreement. SECTION 7-103. COMPATIBILITY The proposed facility is consistent with current uses on the subject parcel and adjacent properties. The proposed injection well will be located on a current natural gas well pad which has been screened visually from the adjacent Battlement Mesa PUD. The proposed injection well is compatible with the current use of the project site. SECTION 7-104. SOURCE OF WATER A source of potable water will not be required for workers utilizing the site. This facility is not manned on a regular basis and does not require a fresh water distribution and wastewater system to properly function. Workers will provide their own potable water in their trucks. Ursa will provide personnel bottled or potable water at their field office. A source of water is not required for the operation of the facility. Water will not be required for the operation of sanitary facilities. Portable toilets will be used and all wastes will be hauled to a licensed treatment facility. Water will not be required for landscaping. No landscaping is proposed at this site. Water to be injected into the proposed injection well is generated by Ursa's natural gas production assets in the Piceance region. Water delivered to the facility will not infringe on any existing water rights. The produced water generated from Ursa's natural gas production operations is a result of Ursa's drilling operations within the Williams Fork Formation. This formation is classified as a nontributary formation. Details specific to the nontributary nature of the water that will be delivered to the proposed injection well are provided in this submittal. The proposed injection well will not place a demand on local groundwater resources. The proposed injection well will be used to dispose of produced water from Ursa's operations only. 760 Horizon Drive, Suite 102 TEL 970.263.7800 Grand Junction. CO 81506 FAX 970.263.7456 www.olssonassociates.com Ursa Operating Company. LLC Speakman A Injection Well The injection permit applications (COGCC Forms 31 and 33) have been submitted to the Colorado Oil and Gas Conservation Commission (COGCC) and are currently under review. Copies of these applications accompany this submittal. The COGCC review process is intended to address any issues related to potential impacts to groundwater. This well will be operated in strict accordance with COGCC regulations and the approved permit criteria and conditions of approval. Other required COGCC forms will be submitted when appropriate. B. Determination of Adequate Water The proposed injection well will not place a demand on local groundwater resources. The water disposed of is a result of Ursa's drilling operations within the Williams Fork Formation. This formation is classified as a nontributary formation. Details specific to the nontributary nature of the water that will be delivered to the proposed facility are provided in the Water Supply Plan section of this submittal. SECTION 7-105. CENTRAL WATER DISTRIBUTION AND WASTEWATER SYSTEMS A. Water Distribution System The proposed injection well facility will be unmanned. This facility will not require potable or fresh water distribution within the facility. Produced water will be hauled to the proposed facility via water truck from the various Ursa Piceance Basin locations. In time, a pipeline will be constructed to pipe produced water to the injection well in order to cut down on the number of trucks needed to haul water and to decrease opportunities for environmental impacts due to water hauling by truck. B. Wastewater System No water is required for sanitary services at the site. The site will be served by porta- johns provided and serviced by Redi Services. A "Will Serve" letter is included in this submittal in the Wastewater Management Section. SECTION 7-106. PUBLIC UTILITIES A. Adequate Public Utilities Adequate Public Utilities shall be available to serve the land use. Ursa is working with Holy Cross Energy to provide electrical service to the pad. Other public utilities are not required. B. Approval of Utility Easement by Utility Company Ursa has not finalized their agreement with Holy Cross Energy to provide electrical service to the pad. All appropriate easements will be secured as part of this process. C. Utility Location High voltage overhead power lines currently exist just north of the project site on the Speakman property. Fifteen foot utility and drainage easements exist on the north and Standards Analysis Page 2 Ursa Operating Company, LLC Speakman A Injection Well south sides of the proposed injection well facility, as well as an 8 -foot gas line easement to the south of the site. D. Dedication of Easements Ursa has not finalized their agreement with Holy Cross Energy to provide electrical service to the pad. All appropriate easements will be dedicated to the public as part of this process. E. Construction and Installation of Utilities Ursa has contracted with Holy Cross Energy to provide electrical power to the site. A copy of the Job Estimate is provided in this submittal. Utilities will be installed in a manner that avoids unnecessary removal of trees or excessive excavations and will be reasonably free of physical obstructions. F. Conflicting Encumbrances Ursa has not finalized their agreement with Holy Cross Energy to provide electrical service to the pad. All appropriate easements will be free from encumbrances. SECTION 7-107. ACCESS AND ROADWAYS The proposed injection well facility will not require construction of new roads. The use will utilize the existing access from Daybreak Drive off of CR 300 (Stone Quarry Road). No traffic will be routed through the Battlement Mesa area during operation of this facility. Ultimately this facility will result in a net decrease in traffic impacts to the Battlement Mesa Planned Use Development (PUD). A. Access to Public Right of Way No new roads are proposed to accommodate the proposed injection well facility. Access to the subject property is from County Road 300, Daybreak Drive and via a private driveway. The existing roadway and access are adequate for the anticipated low traffic volumes. Dust from the private driveway will be mitigated as appropriate. Access is granted via the Surface Use Agreement between Ursa and the owners of the parcel. Daybreak Drive has been permitted via Driveway Permit number GRB07-D-122 obtained by Encana Oil and Gas in 2007. B. Safe Access The access leading to the project site meets the Semi -Primitive and Primitive Roadway/Driveway standards of Table 7-107 of the Land Use and Development Code. The county road system and private driveway provide safe access to the facility. C. Adequate Capacity The proposed facility will generate little traffic, and the current road system has adequate capacity to support the proposal. See Traffic Analysis included with this application for additional details. Standards Analysis Page 3 Ursa Operating Company, LLC Speakman A Injection Well D. Road Dedication No new public roads are being built or dedicated as part of this project. E. Impacts Mitigated Ultimately, this facility will result in a net decrease in traffic impacts to the Battlement Mesa Planned Use Development (PUD) due to truck traffic not going through Battlement Mesa to the East Parachute 1-70 Interchange to take produced water to an injection well in the Silt area. County roads between the Monument Ridge, Watson Ranch and Speakman A well pads will experience impacts from this project that are characteristic of existing natural gas development in the region due to the trucks originally going to Silt being diverted along CR 300. No formal mitigation will be required for this project. See the Traffic Analysis for further information. F. Design Standards As stated above, no new roads are being built as part of this project. Existing access route(s) conform to the standards of Table 7-107 for Semi -Primitive and Primitive/Driveways. SECTION 7-108. USE OF LAND SUBJECT TO NATURAL HAZARDS According to the Geologic Hazard Report, the project area is not subject to rock fall, snow slides, mud flows, radiation, flooding, or high water tables. The site is located on pre -historic earthflow and soil creep deposits having the potential to be a geologic hazard affecting the Site. There are existing wells on the location, and there is other development in the area. No flood prone areas are mapped in the vicinity of the site. Flash flooding is an issue for lower elevations along Dry Creek, and areas along the Colorado River located to the north and west are prone to flood risks. There are no mining activities shown in the vicinity of the site. Natural gas well drilling has been conducted in the area since the 1960s. There are no significant radioactive mineral deposits known in the immediate area of the site. The presence of NORM may be an issue with exploration and production and could be an issue with used pipe scale or used equipment. Radioactive materials are not expected to pose a significant hazard at the Site. SECTION 7-109. FIRE PROTECTION A. Adequate Fire Protection The proposed injection well is located within the Grand Valley Fire Protection District. The District is aware of the well pad location and can provide adequate fire protection/response. Ursa is willing to provide training to the District regarding the site operations if requested. Standards Analysis Page 4 Ursa Operating Company, LLC Speakman A Injection Well B. Subdivisions This standard does not apply as the proposed land use is not a subdivision nor located within a subdivision. DIVISION 2. GENERAL RESOURCE PROTECTION STANDARDS SECTION 7-201. AGRICULTURAL LANDS A. No Adverse Affect to Agricultural Operations The operation of the proposed injection well will not adversely affect agricultural operations on the subject property or adjacent lands. B. Domestic Animal Controls The operation of the proposed facility will comply with this standard. No domestic animals are allowed on the site. C. Fences The facility will not generate a potential hazard to domestic livestock or wildlife. No open storage of hazardous materials or attractions will be conducted on the site. The site is currently enclosed with a visual and sound buffer that also serves to protect the facility from possible livestock damage through the completion activities of the natural gas drilling currently taking place on the site. The parcel is considered open rangeland by the surface owner, who does not want additional fencing to be erected. D. Roads The proposed facility will not impact adjoining roadways beyond current impacts due to the anticipated low operational traffic volumes. The Project Description and Traffic Study describes the proposed access. Additional details are shown on the site plan. The proposed injection well facility will not require construction of new roads. The use will utilize the existing access from CR 300 to Daybreak Drive. E. Irrigation Ditches No irrigation ditches are adjacent to the proposed injection well site. Implementation of the engineered grading and drainage plan and conformance with stormwater best management practices will assure that any irrigation ditches on the subject parcel will not be impacted by the facility. SECTION 7-202. WILDLIFE HABITAT AREAS A. Buffers The proposed injection well is located on an existing well pad and no new surface disturbance would be required. The area immediately surrounding the Speakman A pad Standards Analysis Page 5 Ursa Operating Company, LLC Speakman A Injection Well consists of former pinyon -juniper woodland and sagebrush rangeland that has historically been developed for agricultural purposes (open rangeland) The proposed site is currently surrounded by an enclosure which provides visual and sound buffers to the surrounding properties and thus from habitat areas. B. Locational Controls of Land Disturbance The proposed injection well is located on an existing well pad and no new surface disturbance will be required. No migration corridors are affected. Human presence and activity may affect animal distribution by creating avoidance areas and increasing stress on wintering big game. Over time, deer and elk that winter in this area have become habituated to human activity and the indirect effects of avoidance and displacement have decreased. An increase in vehicle traffic could result in additional vehicle related wildlife mortality, although additional traffic resulting from this project would contribute minimally, given current traffic volumes on the existing county road. Traffic volumes and speed on the private road accessing the site are unlikely to result in significant animal mortality from vehicles. Fences can pose an increased risk to big game. The site is currently surrounded by a visual and sound mitigation enclosure. Equipment is outfitted with bird cones to prevent perching. C. Preservation of Native Vegetation 1. No additional vegetation removal will be necessary for development of the injection well since it will be placed on an existing natural gas well pad. 2. Application of the Integrated Vegetation and Noxious Weed Management Plan (IVNWMP) and Ursa's Noxious Weed Management Plan will provide a degree of mitigation for the native vegetation that has already been removed. Ursa will also comply with COGCC Rule 1002 regarding revegetation and control of noxious weeds. 3. Vehicles and equipment traveling from weed -infested areas into weed -free areas could disperse noxious or invasive weed seeds and propagates, resulting in the establishment of these weeds in previously weed -free areas. Several simple practices should be employed to prevent most weed infestations. The following practices should be adopted for any activity to reduce the costs of noxious weed control through prevention. The practices include: • Prior to delivery to the site, equipment should be thoroughly cleaned of soils remaining from previous construction sites which may be contaminated with noxious weeds. Standards Analysis Page 6 Ursa Operating Company, LLC Speakman A Injection Well • If working in sites with weed -seed contaminated soil, equipment should be cleaned of potentially seed -bearing soils and vegetative debris at the infested area prior to moving to uncontaminated terrain. • All maintenance vehicles should be regularly cleaned of soil. • Avoid driving vehicles through areas where weed infestations exist. D. Habitat Compensation Placement of this project within the boundaries of an existing development has resulted in avoidance of additional contributions to cumulative effects of habitat alteration and fragmentation in the region. The development of the project is not expected to significantly affect any critical environmental resources. E. Domestic Animal Controls Livestock and big game will likely avoid the project site. Dogs and other domestic animals are not allowed on site. SECTION 7-203. PROTECTION OF WATERBODIES A. Minimum Setback 1. The eastern edge of the project site disturbance is more than 35 feet from the Ordinary High Water Mark (TOHWM) of the natural drainage that runs south to north to the east of the proposed injection well. 2. There are no entrenched or incised streams on or adjacent to the proposed project site. 3. No hazardous material will be stored on the project site. Please see SPCC Plan included in this submittal for measures to protect surface and ground water from spills. B. Structures Permitted in Setback No structures will be located within the 35 foot setback. C. Structures and Activity Prohibited in Setback No structures will be located within the 35 foot setback. No work of any kind will occur within the 35 foot setback. D. Compliance with State and Federal Laws The proposed injection well will not impact any Waterbody of the US. Standards Analysis Page 7 Ursa Operating Company, LLC Speakman A Injection Well SECTION 7-204. DRAINAGE AND EROSION A. Erosion and Sedimentation The proposed injection well will not require clearing or vegetation removal beyond the existing well pad and previously disturbed area. BMPs such as sediment basins, top soil berms and wattles will be utilized to ensure the continued protection of water bodies from stormwater runoff during construction and operation of the facility. B. Drainage 1. This standard requires that Tots be laid out to provide positive drainage. Lots are not proposed as part of this land use application. The proposed project will not create any impacts to existing drainage patterns. 2. This standard also addresses individual lot drainage within a residential development and is not applicable to this use. The proposed facility will not impact natural drainage patterns. C. Stormwater Run -Off The site has been designed to COGCC standards for stormwater management to control stormwater runoff in a manner that minimizes erosion, transport of sediment offsite, and site degradation. BMPs will be maintained until the facility is abandoned and final reclamation is achieved pursuant to COGCC Rule 1004. The proposed injection well sites is at times within 100 feet of a Waterbody, but it will not create 10,000 square feet or more of impervious surface area. 1. Avoid Direct Discharge to Streams or Other Waterbodies. Stormwater Runoff from the project areas will be controlled by use of BMPs such as sediment basins, top soil berms and wattles. 2. Minimize Directly -Connected Impervious Areas. The site design will not create more than 10,000 square feet of impervious surface area. 3. Detain and Treat Runoff. Ursa has incorporated a number of stormwater detention facilities into the design for this site. Stormwater runoff will be controlled via a combination of sediment basins, top soil berms and wattles. a. Due to the low imperviousness of the historic and existing basins, and the reduced tributary basin size of the gas pad development, no 25 -year event detention is required for the site. Additionally, the calculated 25 -year detention for the combined basin would be 429 cf per the Detention Volume by Rational Volume Method which is equivalent to 2' deep 14 -ft by 14 -ft. The proposed settlement/containment pond should be sized large enough to provide this minor amount of attenuation and an extended detention basin is not necessary. b. The project site is above the 100- and 500 -year floodplain of the Colorado River, therefore a 100 -year storm event should not cause property damage. Standards Analysis Page 8 Ursa Operating Company, LLC Speakman A Injection Well c. Channels downstream from the stormwater detention pond discharge have been designed to prevent increased channel scour, bank instability, and erosion and sedimentation from the 25 -year return frequency, 24-hour design storm. d. See item 3.a above for details related to the need for detention. e. All culverts, and drainage pipes, utilized at this facility are designed and constructed according to the AASHTO recommendations for a water live load. SECTION 7-205. ENVIRONMENTAL QUALITY A. Air Quality The injection well itself will not require an air permit or Air Pollutant Emissions Notification (APEN). Any associated equipment that emits greater than two tons per year of criteria pollutants, i.e. production tanks, will need an APEN. The injection well is fed by an electric pump. This pump is exempt from an air permit/APEN. The only APEN associated with the Speakman A pad is the condensate tank battery. The produced water tank battery is exempt. A request that the condensate tank battery be covered under Air Permit GP01 (Form APCD-205) was submitted to the CDPHE on January 2, 2014. This application is included with this submittal under the Air Quality Permit tab. B. Water Quality No hazardous materials will be stored on site. An SPCC plan will be in effect for the tank batteries associated with the injection well. A copy of the plan is included with this submittal. SECTION 7-206. WILDFIRE HAZARDS A. Location Restrictions The proposed injection well facility is not located in an area designated as a severe wildfire hazard area according to the Garfield County on-line GIS map resources, nor is it located within a fire chimney as identified by the Colorado State Forest Service. B. Development Does Not Increase Potential Hazard The proposed injection well will not increase the potential intensity or duration of a wildfire, or adversely affect wildfire behavior or fuel composition. C. Roof Materials and Design Roof materials for the pump house will be made of noncombustible materials. Any proposed construction will comply with requirements of the 2003 International Fire Code. Standards Analysis Page 9 Ursa Operating Company, LLC Speakman A Injection Well SECTION 7-207. NATURAL AND GEOLOGIC HAZARDS A. Utilities Geological hazards are not expected to be associated with the installation of buried utilities. Slopes may be a limitation to this construction, but this limitation should be able to be overcome with proper engineering. design, and construction. B. Development in Avalanche Hazard Areas Avalanche conditions are not expected to be present in area of the Site. C. Development in Landslide Hazards Areas The site is located on pre -historic earthflow and soil creep deposits having the potential to be a geologic hazard affecting the Site. There are existing wells on the location and there is other development in the area, showing that mitigation is not required. D. Development in Rockfall Hazard Areas Rockfall areas are not present in the area of the Site. Rockfall areas are present in parts of the steep canyons and narrow drainages incised by area streams, but are not expected to be a hazard in the vicinity of the Site. E. Development in Alluvial Fan Hazard Area The Site is not in an alluvial fan hazard area. Alluvial fans are present to the northwest between the site and the Colorado River drainage. F. Slope Development Slope is a limitation associated with the Potts and the Potts Ildefonso complex soils and certain types of development. The Speakman Pad A UIC well construction is not expected to be adversely affected by the slopes in the area. G. Development on Corrosive or Expansive Soils and Rock Corrosive or expansive soils and rock are not expected to be present in the vicinity of the proposed water impoundment Site. Rocky soils may exist in the vicinity of the site which may impact the proposed development. H. Development in Mudflow Areas Collapsible soils are not present in the vicinity of the proposed UIC Well Site. I. Development Over Faults No significant faulting is known in the UIC Well Site. Standards Analysis Page 10 Ursa Operating Company, LLC Speakman A Injection Well SECTION 7-208. RECLAMATION A. Applicability No ISDS will be installed. No new access is being proposed. The injection well will be drilled on a previously approved COGCC well pad. Ursa will abide by all reclamation requirements set out by COGCC Rules 1003 and 1004 for interim and final reclamation. All of Ursa's surface disturbances are covered under a statewide bond, held by the COGCC. B. Reclamation of Disturbed Areas A copy of Ursa's Reclamation Plan is included in this submittal. Areas disturbed during development will be restored as natural -appearing landforms that blend in with adjacent undisturbed topography at the end of the life of the injection well. 1. Contouring and Revegetation. Areas disturbed by grading will be contoured so they can be revegetated as appropriate for interim and final reclamation. At the end of the life for the well pad, it will be planted and have vegetation established and growing based on 70% coverage as compared with the original on-site vegetation within 2 growing seasons of reclamation, using species as noted in the accompanying Reclamation Plan. 2. Application of Top Soil. Top soil will be stockpiled as berms around the perimeter of the well pad. Unused top soil will be stockpiled and vegetated temporarily to reduce erosion until it can be reused during reclamation. 3. Retaining Walls. No retaining walls are planned for this project. 4. Slash Around Homes. No residences will be part of the proposed project. 5. Removal of Debris. The proposed injection well is located on an existing natural gas well pad. 6. Time Line Plan. The site will be reclaimed in 20-30 years, at the end of the life for the natural gas wells serving the injection well. DIVISION 3. SITE PLANNING AND DEVELOPMENT STANDARDS SECTION 7-301. COMPATIBLE DESIGN Operation of the proposed facility will be consistent with nearby uses. The facility will be unmanned, except during times of water deliveries and maintenance. There will be minimal impacts to the existing roadway system during the operational phase. A. Site Organization The site has one access point to Daybreak Drive at the southern end of the project site. The site will be organized to provide safe access to and from the site and parking off the Standards Analysis Page 11 Ursa Operating Company, LLC Speakman A Injection Well public right-of-way. It will not disrupt solar access to adjacent properties, pedestrian access, nor access to common areas along Daybreak Drive. B. Operational Characteristics 1. Adjacent lands will not be impacted by the generation of vapor, odor, smoke, glare, noise or vibration beyond the impacts already associated with the operation of the existing natural gas well pad. Generation of dust will be mitigated by use of water or other additives to the road ways to decrease/prevent the generation of dust caused by vehicles accessing the well pad. 2. The pump for the injection well is powered by electricity located within a pump house. Noise will not exceed State noise standards pursuant to COGCC Rule 802 regarding noise and abatement. 3. Typical hours of operation will be 7:00 am to 6:00 pm, although the site is available to personnel 24 hours a day, in case of emergency. C. Buffering The well pad where the proposed injection well will be located is buffered to mitigate visual and noise similar impacts to adjacent property during natural gas drilling and completion activities. D. Materials Tanks, buildings, and equipment will be painted to blend in with the surrounding landscape. SECTION 7-302. OFF-STREET PARKING AND LOADING STANDARDS Adequate parking will be made available to accommodate Ursa personnel during regular operation, inspection, and maintenance of the facility. All activities on this site will be conducted out of any public right-of-way. All off-loading and loading will take place on the well pad out of the public right-of-way. See Site Plan for truck circulation related to water delivery. Loading and unloading of vehicles will take place in a manner that will not interfere with the flow of traffic on Daybreak Drive or County Road 300. Parking and loading surfaces have been designed by an engineer to ensure proper drainage of surface and stormwater. See Grading and Drainage Plan section of this submittal. Traffic circulation patterns on site will be such that no vehicle will be required to back on to the public right-of-way. The access driveway for the proposed injection well runs to the south off of the well pad to Daybreak Drive. The apron to the Daybreak Drive is constructed to accommodate the tanker trucks typical for hauling produced water. The driveway has a clear vision area of 300 feet to the east and west. See the Traffic Study for more information. Standards Analysis Page 12 Ursa Operating Company. LLC Speakman A Injection Well A. Parking and Loading Area Landscaping and Illumination No landscaping is planned for the proposed project site. Any illumination will be downcast and shielded per Garfield County standards. SECTION 7-303. LANDSCAPING STANDARDS This type of industrial use is exempt from the landscape standards of the Development Code. SECTION 7-304. LIGHTING STANDARDS A. Downcast Lighting Any lighting will be directed inward, towards the interior of the site. B. Shielded Lighting Any exterior lighting will be shielded so as not to shine directly onto other properties. C. Hazardous Lighting Light from the site will not create a traffic hazard or be confused as traffic control devices. D. Flashing Lights The facility will not contain flashing lights. E. Height Limitations There will be no light sources exceeding 40 feet in height on the site. SECTION 7-305. SNOW STORAGE STANDARDS Snow will be stored in a vacant section of the existing disturbed area. The site will be graded to accommodate snowmelt to insure sufficient drainage. SECTION 7-306. TRAIL AND WALKWAY STANDARDS A. Recreational and Community Facility Access The proposed site is located in a rural area of Garfield County. A connection to public facilities is not appropriate or feasible. DIVISION 10. ADDITIONAL STANDARDS FOR INDUSTRIAL USES SECTION 7-1001. INDUSTRIAL USE A. Residential Subdivisions This site is not located in a platted residential subdivision. Standards Analysis Page 13 Ursa Operating Company, LLC Speakman A Injection Well B. Setbacks The proposed injection well is located more than 100 feet from all adjacent property lines. C. Concealing and Screening This site is located in a rural area. It is currently screened to mitigate visual impacts to the surrounding area. Aboveground facilities will be managed to minimize visual effects (e.g. painted to blend with environment). D. Storing All products will be stored in compliance with all national, state and local codes and will be a minimum of 100 feet from adjacent property lines. E. Industrial Wastes All industrial wastes will be disposed of in a manner consistent federal and state statutes and requirements of CDPHE and COGCC. F. Noise No significant sound impacts will be generated from the facility. A sound barrier has been erected and will remain in place through completions of the natural gas wells to minimize noise. Water truck loading and unloading operations will be conducted to minimize noise impacts as much as possible. The occasional pickup truck for maintenance and monitoring purposes will not impact surrounding operations and properties beyond the impacts of the current natural gas operations on the well pad. Pumps for the injection well are electric and will be housed in a building to reduce any potential noise impacts. Operation of the facility will not exceed the Residential/Agricultural/Rural Zone Standards and Colorado Noise Statute 25-12-103 requirements. G. Ground Vibration Ground vibration will not be measurable at any point outside the property boundary. H. Hours of Operation The facility will not generate noise, odors, or glare beyond the property boundaries greater than what is allowed under the Land Use Development Code. Activities that do generate these impacts within the established standards will occur between the hours of 7:00 am and 6:00 pm Monday through Saturday. I. Interference, Nuisance, or Hazard Adjacent lands will not be impacted by the generation of vapor, dust, smoke, noise, glare, or vibration beyond those impacts of the current natural gas activities taking place on the well pad. Ursa will apply the appropriate level of controls to accommodate Standards Analysis Page 14 Ursa Operating Company, LLC Speakman A Injection Well potential impacts via adherence to CDPHE Air Quality regulations and the implementation of industry BMPs included in the SWMP and Ursa's dust control plan. The pad and access road will be graveled to reduce fugitive dust, which will be controlled using water or other dust suppressants. This proposed use will comply with Colorado Revised State Statutes and COGCC Rules regarding noise impacts at all times. Standards Analysis Page 15 • f#F M•WIPE %lir \ • \ \\ j6 \� / \ \\ /X \ tl 3 7;5; 4 ¢r 1 Y. 6 I 1 q£ 9 x4 131 91 iii 1 r --I it i 1 E^ ��e ; #t t: , if �/ -+- �r Il I I -4- Pail; fliil iirf P. rfri if if iiir n z / / / / / / _I 0 nZ o ab g- A tD 'c °A 0'17 0o,op 0 O— w - d ro N A (D -Z.".. g- W m p Ai o 3^ z 007 rte G A d 9 A o o 0a rri' A • Scope: Requirements: Fugitive Dust Control Plan Garfield County, Colorado July 2014 Ursa Operating Company Colorado, USA The scope of these guidelines is to outline some basic principles to minimize and control fugitive dust emissions during land development. Ursa Operating Company places the highest priority on the health and safety of our workforce and protection of our assets and the environment. Applicable Documents: Department of Public Health and Environment Air Quality Control Commission Regulation 1 5CCR 1001-3. Safety: Safety Plan Quality: These guidelines will be reviewed periodically and will be shared with employees and contractors to ensure that they have adequate knowledge to minimize fugitive dust emissions. • INTRODUCTION Land development activities, including clearing, excavating, and grading, release fugitive dust, a pollutant regulated by the Air Pollution Control Division (Division) at the Colorado Department of Public Health and Environment. However, small land development activities that are less than 25 contiguous acres and less than 6 months in duration do not need to report air emissions to the Division, but must use appropriate control measures to minimize the release of fugitive dust from the site. This Fugitive Dust Control Plan addresses how dust will be kept to a minimum on roads, pad sites, and operational facilities. This plan focuses action on: • Identifying specific individual sources of fugitive dust. • Control options for unpaved roadways. • Control options for disturbed areas. • Control options for transport, storage and handling of bulk materials. • Contingency Plan for alternative action in the event that control strategies are not adequate, effective, or practical. Fugitive Dust Control Plan Ursa Operating Company Page 1 July 2014 • SPECIFIC SOURCES Specific types of fugitive dust sources may appear to have negligible dust emissions, but when combined with other specific sources underway at the same time can create dust plumes that are visible beyond that which is appropriate for designated speeds and designs and may exceed nuisance emission limitation guidelines. It is important to consider all activities on the site together in determining compliance with federal, state, and local air quality regulations. Task: Provide field personnel and contractors with the information required to limit fugitive particulate matter (fugitive dust) from all specific sources to include: • Unpaved roadways and traffic areas. • Construction activities including earth moving and excavation. • Bulk material (i.e. gravel and soils). • Storage and handling of materials • CONTROL OPTIONS FOR UNPAVED ROADWAYS Any owner or operator responsible for construction or maintenance of any (existing or new) unpaved roadway is required to use all available, practical methods to minimize dust emissions. Task: Provide guidelines for minimizing fugitive dust emissions from all specific sources on unpaved roadways and traffic areas: • Require that all passenger vehicles, construction equipment, and truck traffic obey the posted speed limits on all unpaved County and private roads to and from the project site. • Ensure that vehicle speeds on new and existing access roads on the project site do not exceed 15 miles per hour by posting speed limits along these roads. • Restrict vehicle traffic to existing roads by posting signs and/or providing the locations of allowable access routes to all field personnel and visitors. • Encourage carpooling to and from the project site to limit traffic on existing County and private roads. • Roads and well locations will be surfaced with compacted gravel to protect against wind erosion, to reduce the amount of fugitive dust generated by traffic and other activities, and to reduce carryout/trackout. • Use dust inhibitors (surfacing materials, water, or non -saline dust suppressants) on all unpaved collector, local, and resource roads to prevent fugitive dust problems (ensure that any dust suppressants used are appropriate for road conditions and will not compromise the safety of workers on the project site). Fugitive Dust Control Plan Ursa Operating Company Page 2 July 2014 • Restrict vehicular access during periods of inactivity using gates, fencing, and/or onsite security personnel. • CONTROL OPTIONS FOR DISTURBED AREAS Disturbed areas include new roads, well pads, parking and staging areas, and material storage areas that have been cleared of vegetation, leveled, or excavated. These areas are susceptible to wind erosion and are a major source of fugitive dust emissions that require the appropriate controls and dust mitigation methods. Note that specific sources are subject to change as project conditions change, and will require an evaluation of current control options to ensure effectiveness and practicality. Task: Limit the adverse impacts of fugitive dust emissions through control measures and operational procedures designed so that no off -property transport emissions occur at the project site. • Surface all bare ground with gravel as soon as practicable after clearing, leveling, and grading. • Use dust inhibitors (surfacing materials, water, or non -saline dust suppressants) on all disturbed areas as necessary to prevent fugitive dust problems. • Reduce the amount of time between initially disturbing the soil and revegetating or other surface stabilization. • Apply vegetative or synthetic cover to topsoil and spoil piles as soon as practicable following stockpiling to prevent wind erosion and fugitive dust emissions. • Compact the soil on disturbed areas that will not be surfaced with gravel or revegetated immediately following construction. • Minimize surface disturbance to only that necessary for safe and efficient construction and operations. • Use vegetative mulch, reseeding, or other methods of surface stabilization on all areas adjoining development to include shoulders, borrow ditches, and berms, if practical. • Restrict vehicular access during periods of inactivity using gates, fencing. Identify any new sources of fugitive dust emissions and evaluate and implement the appropriate control methods for that source. • Incorporate fugitive dust controls in all lands projects. • CONTROL OPTIONS FOR TRANSPORT, STORAGE AND HANDLING OF BULK MATERIALS Transporting bulk materials, such as gravel and fill material, can result in off -property dust emissions and other impacts (i.e. broken windshields) over some distance if the appropriate control measures are not implemented. Storage and handling of bulk materials once they arrive Fugitive Dust Control Plan Ursa Operating Company Page 3 July 2014 at the project site also requires that controls are in place to ensure that these materials do not exceed regulated nuisance dust emissions. Task: Use control measures and operational procedures designed so that no off -property transport emissions occur along public roadways to and from the project site: • Enclose, cover, water, or otherwise treat loaded haul trucks to minimize the loss of material to wind and spillage. • Require that all contract haul vehicles obey the posted speed limits on all public roadways to and from the project site. • Ensure that haul truck speed on new and existing access roads on the project site do not exceed 15 miles per hour by posting speed limits along these roads. Restrict haul trucks to existing roads and pad locations. Promptly remove dust -forming material from haul trucks to minimize entrainment of fugitive particulate matter. • Avoid storage and handling of bulk material any more than necessary to complete construction. • Use covers, enclosures, wind breaks, or watering to prevent fugitive dust emissions from material storage piles. • Restrict access to construction areas and storage piles during periods of inactivity using gates, fencing. CONTINGENCY PLANNING Alternative control measures may become necessary in the event that the current dust control strategy is not adequate or effective for conditions. An alternative plan may require additional planning, permitting, or other regulatory compliance requirements to implement. In this case, the current activities at the project site would necessarily be suspended until such time as the alternate dust control methods could be put into place. Task: Implement alternative action to fugitive dust control plan and to each specific source if deemed necessary to comply with federal, state, and local air quality regulations: • Provide field personnel and contractors with contact information for responsible individuals in cases where control measures need to be escalated in response to weather conditions (i.e. increased windiness). Use an appropriate alternative dust inhibitor if water does not prove to be effective under normal circumstances, and obtain all regulatory permissions for the use of chemical suppressants on the project site. Fugitive Dust Control Plan Ursa Operating Company Page 4 July 2014 Use vegetative blankets or other methods for cover of topsoil, spoil, and bulk material storage piles if immediate cover becomes necessary. Attempt to locate alternative sources of bulk material closer to the project site if fugitive dust emissions or other impacts from contract haul trucks on state or federal highways become an issue with public safety or regulatory compliance. Fugitive Dust Control Plan Ursa Operating Company Page 5 July 2014 BATTLEMENT MESA SITE Emergency Evacuation, Assembly, Accountability and Response Plan Prepared for U rsa RESOURCES � GROUP 11 Prepared by. 2381 Patterson Road Grand Junction, CO 81505 June 10, 2014 g?UrSa RESOURCES GROUP II EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 This plan is intended to provide general information about the Battlement Mesa Site owned and operated by Ursa Resources Group 11, and to offer guidance for conducting emergency response operations not handled in a routine manner. This information will increase understanding of Ursa's operations and assist Ursa and the general public should unexpected conditions arise and cause concern for employee and public safety. This procedure is designed to direct emergency response operations and to meet compliance obligations of OSHA in 29 CFR Part 1910.38-39 "Employee Emergency Plans and Fire Preventions Plans", and more specifically address wildfire mitigation measures by using Best Management Practices in relation to assessing the wildfire potential at the site. EMERGENCY: A sudden and urgent occasion for action; pressing necessity. -New American Webster Dictionary Ursa Resources Group, 11 PAGE 2 of 35 tliUrsa RGERO ROES 11 EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Rev ision 00 1 •-JUN-14 TABLE OF CONTENTS 1.0 PURPOSE AND SCOPE 6 2.0 ROLES AND RESPONSIBILITIES 6 2.1 Project Coordinator 6 2.2 Site Manager/Supervisor or Lead Operator 7 2.3 Site Safety Officer 7 2.4 Incident Commander 8 3.0 OFF-SITE AND/OR LOCAL EMERGENCY RESPONSE ORGANIZATIONS 8 3.1 Garfield County Emergency Communications Center 9 3.2 Grand Valley Fire Protection District 9 3.3 Grand River Hospital District 9 3.4 Parachute Police Department 9 3.5 St. Mary's CareFlight Helicopter 9 4.0 COORDINATION WITH OFF-SITE RESPONSE ORGANIZATIONS 10 5.0 CONTINGENCY PLANNING 10 6.0 TRAINING 10 7.0 DRILLS 11 8.0 EMERGENCY ACTIONS 11 8.1 Actions Common to All Emergencies 11 8.1.1 Site Safety Kit 12 8.2 Additional Information for Specific Emergencies 13 8.2.1 Bomb or Terrorist Threats 13 8.2.2 Explosions 13 8.2.3 Evacuations 14 8.2.3.1 Assembly Areas/Muster Point 14 Ursa Resources Group, 11 PAGE 3 of 35 WUrsa RESOURCES GROUP 11 EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION 8.2.3.2 Evacuation Routes 15 8.2.3.3 Personnel Accountability 15 16 8.2.4 Fire 8.2.5 Flood 8.2.6 Earthquake 17 8.2.7 Severe Storms 17 8.2.8 Power Failure 18 8.2.9 Material or Chemical Release and/or Spills 19 8.2.10 Medical Emergencies 19 8.2.11 Public Disturbance Actions 21 8.2.12 Transportation or Vehicle Incidents 21 8.2.13 Media Response 22 9.0 WILDFIRE MITIGATION MEASURES 23 9.2 Structures and Ignition Potential 25 9.3 Vegetation Management 26 9.4 Powerlines 26 9.5 Debris Piles 27 9.6 ATVs and/or Equipment 27 9.6.1 Welding Operations 28 9.8 General Wildfire Safety Tips 31 10.0 EVENT NOTIFICATIONS AND REPORTING 32 10.1 Event Notifications 32 10.2 Reporting Requirements 32 10.1.1 Emergency Notification 33 10.1.2 Follow-up Notice Requirements 33 POST -EMERGENCY RESPONSE INCIDENT INVESTIGATION 34 17 11 Ursa Resources Group, 11 PAGE 4 of 35 GiUrsa rSa RESOURCES GROUP 11 EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 11.1 Post -Emergency Assessment 34 11.2 Lessons Learned 34 LIST OF TABLES Table 8-1 Waming Signals and Actions 12 ATTACHMENTS Attachment A Agency Emergency Contact List Ursa Resources Group, 11 PAGE 5 of 35 aflUrSa GROJP IIR=SOJRCES EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Re In compliance with: 29 CFR 1910.38-39 Means of Egress — Emergency Action/Fire Prevention Plans NFPA 1 — Fire Prevention Code NFPA 101©, Life Safety Code© Best Management Practices for Wildfire Mitigation 1.0 PURPOSE AND SCOPE This Emergency Evacuation and Response Plan ("EERP") has been prepared to address activities, including potential wildfires, at the Battlement Mesa Site. The EERP is applicable to emergencies that may occur at the Site and is intended for use by all Ursa Resources Group II ("Company") personnel, contractors, consultants, and sub -contractors. This plan is intended to minimize the potential for injury, loss of life and/or property, and to define the responsibilities of Ursa Resources' personnel during emergency situations. In the event of an emergency, it is necessary to establish immediate coordination with local responders, with Ursa corporate officials, and with Ursa representatives in Rifle, Colorado. A contingency plan shall be implemented, as needed, to meet local responders' requirements and response capabilities. Emergency procedures will be updated as needed for all potential incidents, including wildfire, structural fire, explosion, toxic gas leaks, acid or caustic spills into primary water sources, weather disturbances and civil unrest. Procedures will include details on communications, firefighting, medical, security, evacuation resumption of operations or others as required by the situation and as directed by site supervision. In accordance with 29 CFR 1910.38, this Emergency Action Plan will be kept in at the workplace and readily available to all employees. All personnel will be trained on this policy at the time of hire and any time changes are made thereafter. 2.0 ROLES AND RESPONSIBILITIES This section identifies the roles and responsibilities of project personnel and off-site response organizations crucial to handling an emergency. Contact information for key personnel and organizations are included as an attachment to this program. Key project personnel for planning, responding to, and reporting an emergency include Ursa Resources management representative, Battlement Mesa facility personnel, and Emergency Response Organizations involved in the response of a hazmat, fire, or medical emergency. 2.1 proiect Coordinator Roles of the Project Coordinator include: - Serve as the primary spokesperson for Ursa Resources (the "Company") during a response to an emergency involving hazardous materials or events that could potentially affect the public. • Provide interface between the Company and the media. • Delegate or transfer roles or responsibilities to appropriate personnel as necessary. • Notify corporate management, the United States Environmental Protection Agency (EPA) when necessary, and the Supervising Contractor and/or other outside agency contacts of emergency conditions and status, as required. W'Ursa RESOURCES GROJPII EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION 2.2 Site Manaaer/Suaervisor or Lead Ooerator The Site Manager/Supervisor or Lead Operator shall: • Provide program management, technical oversight, and expertise in Battlement Mesa field activities and assign employees roles and responsibilities. • Review response plans, incident reports, post emergency critiques, and lessons learned. • Ensure all employees possess the proper and adequate training to perform emergency response actions during a hazmat, fire, medical, or other type of emergency. • Perform duties associated with the normal operations of the Battlement Mesa site. • Isolate the response area as directed by the guidance of this document, the Emergency Response Guide (United States Department of Transportation, 2012) (ERG), or per the Project Coordinator, Site Manager, or Site Safety Officer. • Make notifications to appropriate managers/supervisors as well as the applicable emergency response organizations. • Recognize the nature of the hazard. • Call for evacuation or shelter -in-place, as required and if the Incident Commander has not arrived on site. • If prevailing winds preclude the use of a decontamination facility in the assembly area, designate an alternative meeting place for all on-site workers, contractors and consultants in the event of an emergency. • Perform spill response through the use of equipment and/or spill response kits as designated and trained to do so. If Incident Commander has been designated, by either Ursa Resources or a local emergency response agency, the spill response activities shall be dictated by that person's orders in accordance with industry practices. • If trained to do so, extinguish insipient stage fires using appropriate portable fire extinguishers and initiate emergency fire assistance with local fire services and incident command. • Coordinate and ensure that facilities have been properly and thoroughly evacuated in the event of a fire or emergency. • Ensure all personnel are properly trained on the policies contained herein. • Ensure adequate resources are made available to Battlement Mesa personnel during an emergency or, more importantly, to prevent incidents from occurring. • Act as the Incident Commander until a Company Corporate, Public Agency, or Private Sector Incident Commander with greater incident command experience arrives at the scene to relieve him/her of this responsibility. • Designate primary and alternate supervisors responsible for coordination of the accounting process at all muster points once evacuation has been achieved. 2.3 Site Safety Officer The Site Safety Officer shall: • Provide oversight for emergency planning. • Serve as on -scene coordinator during the emergency and advise the Incident Commander on the emergency condition or event. • Assist the Incident Commander with emergency response actions. • Assist emergency response/medical personnel in making notifications as requested. Ursa Resources Group, 11 PAGE 7 of 35 GiUrsa RESOURCES GROUP II EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revi • Keep emergency response/medical personnel apprised of emergency status. • Provide a current inventory of chemicals and hazardous substances, materials, or wastes present on site and identify storage locations to off-site response organizations. • Ensure emergency response communications systems are available and operational and conduct annual tests of those systems. • Assist in preparing records of emergency response events, including incident investigation reports, for noteworthy practices and emergency response improvements. • Ensure responders meet the requirements for medical surveys prior to and after exclusion zone entries. • Establish a worker, contractor, and consultant sign -in or tag -in system to account for all on-site workers, contractors, or consultants in the event of an emergency. 2.4 Incident Commander The Incident Commander is an Ursa Resources' employee or local emergency response official who is trained to the level of First Responder Operations, including Incident Management (IC) training, and is primarily responsible for responding to an emergency at the Battlement Mesa Site. Incident Commander shall: • Direct emergency response actions using appropriate personnel and resources to control or minimize the emergency. • Authorize site -wide evacuations of personnel or call for shelter -in-place. • Declare an emergency. • Delegate personnel for positions of emergency response, including operations, emergency response coordination, and public relations. - Verify personnel accountability list. • Maintain succession of authority during the emergency. • Protect the health and safety of the public and site personnel. • Conduct a post -emergency assessment as soon as practicable following stabilization of the emergency condition. 10- 3.0 OFF-SITE AND/OR LOCAL EMERGENCY RESPONSE ORGANIZATIONS Off-site agencies or local emergency response services will be used for emergencies requiring specialized training and resources of those organizations. Company employees shall act to provide aid and resources, including information and technical assistance, to off-site response organizations as necessary but shall not be responsible for emergency response activities at a technical level. Company and employees will allow access to the property for all personnel and equipment required for emergency response, such as fire equipment, law enforcement vehicles, ambulances, and flight -for -life helicopters. Depending on the scope and severity of the emergency, any of these organizations, other than the hospital, could provide an Incident Commander who is responsible for managing the emergency. Ursa Resources Group, 11 PAGE 8 of 35 R: bursa EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION 3.1 Garfield County Emeraency Communications Center The Garfield County Emergency Communications Center is responsible for all 911 calls received by dispatch and for mobilizing appropriate response agencies during an emergency, including sites located in and around Parachute, Colorado. Local lines calling 911 are directed to this authorized organization. 3.2 Grand Valley Fire Protection District Roles of the Grand Valley Fire Protection District include: • Emergency Medical Services, Ambulatory Services, Fire Suppression, Hazardous Materials Mitigation Fire Prevention, Rescue, Training and Public Education, and other emergency services including ambulance and wild fire responses. • Provides first response medical services for all injured or ill Company, contractor, subcontractor, or vendor employees and for site visitors. • Transports injured or ill personnel by ambulance to medical facilities from Site or related property. • Dispatched by the Garfield County Emergency Communications Authority and a member of a multi -county mutual aid agreement, aiding other departments both locally and within the seven member counties. There are three locations for the Grand Valley Fire Protection District in Parachute, and they are: o 124 Stone Quarry Road o 200 Grand Valley Way o 5797 County Road Emergency response shall dispatch emergency responders from one of these locations depending on availability and response times and shall be determined by dispatch at the time the emergency call is made. • The phone number is 970-285-9119 and should be used only to coordinate emergency response planning and related activities. 911 should be dialed in the event of an emergency. 3.3 Grand River Hospital District Roles of the Grand River Hospital District include: • Providing medical treatment of personnel who are ill or have life-threatening injuries associated with a project emergency. • Located at 501 Airport Road, Rifle, CO 81650. 3.4 Parachute Police Department Roles of the Parachute Police Department include: • Providing law enforcement protection, traffic control and coordination, and other law enforcement services. • Coordinating emergency law enforcement services. ▪ Providing a suitable area or accommodations for use as an emergency operations center. ▪ Located at 222 Grand Valley Way, Parachute, CO 81635. 3.5 St. Marv's CareFlight Helicopter In case of a life threatening situation requiring immediate medical attention that cannot be accommodated or treated by emergency responders located closer to the pond site, St. Ursa Resources Group, II PAGE 9 of 35 vision 00 10 -JUN -14 giOUrSa RESOURCES GROUP II EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Mary's Hospital in Grand Junction can provide medical evacuations via helicopter when necessary. 4.0 COORDINATION WITH OFF-SITE RESPONSE ORGANIZATIONS Effective coordination with off-site organizations will result in effective response to any emergency situation. Training and drills as described in Sections 7.0 and 8.0, respectively, should be periodically made available to off-site emergency response organizations. Under the direction of the Site Manager or Site Safety Officer, a project representative will participate in local emergency planning committee meetings when possible. Ursa Resources recognizes that close coordination with response organizations continuously improves emergency responses by enhancing communication, site familiarity, and lessons learned for all involved. 5.0 CONTINGENCY PLANNING The objective of contingency planning is to prepare for emergency responses. It includes coordinating with emergency response organizations, describing actions during emergencies, conducting training, and performing drills. The Project Coordinator, Site Manager, or Site Safety Officer will coordinate drills and plan for emergencies while synchronizing Ursa's efforts with off- site emergency response organizations. In order to properly prepare for an emergency response, project personnel shall: • Communicate to the Incident Commander that an emergency is in progress. • Recognize the hazards in the area potentially affected by the emergency. • Know what to do and what not to do. • Understand warning sounds and alarms. • Know where to assemble. The Company will provide first aid, cardiopulmonary resuscitation (CPR), and automated external defibrillator (AED) training to the level of First Responder consistent with the requirements of 29 CFR 1910.151(b). One individual on each shift at the Battlement Mesa location shall be trained to this level. 6.0 TRAINING The Company maintains training programs to ensure personnel are adequately trained and prepared for the work they perform and for potential emergencies. Company personnel, contractors, and consultants who regularly work at the Battlement Mesa Site must receive training on the current EERP. Specific training is provided to workers who have special duties during emergencies, such as the Battlement Mesa Site Supervisor and Site Operator who may need to respond directly to an incident. Site visitors and vendors will be accompanied by trained site personnel and shall log in upon arrival and sign out when leaving. Site -designated First Responders will train and practice procedures for any site EMS responses and off-site emergency responses. Ursa Resources Group, 1I PAGE 10 of 35 WUrsa RESOURCES GROUP II EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 Off-site response organizations should be offered training on site hazards; potential injuries and/or illnesses that could result from contamination by contact, ingestion, or inhalation of toxic substances present on site; and contamination risks associated with fires, explosions, or other releases of materials located on site. This training, along with a site tour, shall be offered annually by the Company. 7.0 DRILLS Annual on-site drills shall be conducted to practice emergency response protocol and evaluate those responses. Such drills shall simulate a variety of emergencies and may involve a single field crew, the entire site personnel, and/or off-site emergency response organizations. Drills may also involve detailed coordination and physical role-playing to establish familiarity with these procedures. Drills help improve the Emergency Response process by addressing opportunities for improvement within the Emergency Response System used at this Site. 8.0 EMERGENCY ACTIONS 10 -JUN -14 For the purpose of this plan, an emergency is considered to be any condition which requires assistance over and above that which can be supplied by the normal personnel present at the time or which cannot be handled in a routine manner. All emergency situations are unique and present various conditions. Always evaluate the situation before deciding on a course of action. Ursa Resources representatives must ensure that all site personnel do not "rush in" until the following has been considered: • Is there an immediate threat to life from fire, explosion, structure collapse, chemical spill or release? If so, sound the alarm and evacuate. • Is there an immediate potential for release of toxic (poisonous) chemicals or fumes in the air? If so, evacuate uphill and upwind of the release. • Is there an immediate potential for uncontrollable energy release (pressure), electrical shock, chemical spill, fuel to "feed" a fire? If so, de -energize equipment, disconnect power, engage emergency shut off valves to pumps and fuel sources; but only do so if the action will not cause a more serious problem or endanger someone. • Eliminate sources of ignition by shutting down all other powered equipment, including vehicles, pumps, construction equipment, welding equipment, combustors, separator burners, auxiliary generators, power tools, etc. that may be on site at the time. • When in doubt, sound the alarm, evacuate, and call for help. With regard to any emergency observed at the work site, the immediate supervisor must be contacted and the nature of the emergency reported. 8.1 Actions Common to All Emeraencies Emergency Response actions should account for life safety first, the environment second, and lastly, property (Ursa or non -Ursa). The steps below should be considered during any emergency: • Survey the scene for personal safety. If the area is deemed unsafe, re -locate. Ursa Resources Group, II PAGE 11 of 35 &?Ursa RESOURCES GROUP II EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION evision 00 10 -JUN -14 • Wam others in the area using whatever means are available (e.g., voice, telephone, radio, portable sirens, car horn). • Implement chain of command notification for an organized response. • Survey the scene and determine resources needed by emergency personnel. • Stop or secure the operation causing the emergency, but only if safe to do so. • Minimize exposure to potential hazardous conditions as part of the emergency. • Identify other hazards present (e.g., the potential for fire or explosion.) • Isolate the area and establish control boundaries, if possible. • Contact and direct emergency response organizations to the scene as necessary. • At no time should an emergency response be performed if the Incident Commander determines the area is unsafe for personnel to enter. Good communication is essential for effective emergency responses. The simple warning system described in Table 8-1 will be used to notify personnel of an emergency. This warning system shall be tested at least annually by the Site Safety Officer. Upon notification of an emergency, the Site Safety Officer will notify the Project Coordinator. Notifications to agencies and organizations will be determined by the Project Coordinator. Supplemental actions will be determined by the on-site Incident Commander and carried out as quickly possible after immediate actions are addressed. All Battlement Mesa employees must be able to identify hazards in the immediate area and be aware of alarm notification procedures. Table 8-1 below describes the alarm method using a handheld air horn. DO NOT use vehicle horns if potential for ignition exists. Battlement Mesa personnel should be trained to recognize these alarms. 8.1.1 Table 8-1 Warnina Sianals and Actions ACTION ATTENTION (Emergency Event) EVACUATION SHELTER IN PLACE WARNING SIGNAL . Continuously blast horn for 5 seconds. Repeat three times with a 5 -second pause in between. Supervisor must then radio employees to communicate further instructions to all personnel. . Make five 10 -second blasts with horn, with 5 -second pauses in between each blast. Repeat two times. . Immediately evacuate to the designated assembly area for personnel accountability. • Continuously blast horn for thirty seconds. Repeat one time if necessary with a 5 -second pause in between. • Immediately proceed to shelter -in-place and proceed with emergency preparations as indicated herein. 8.1.1 Site Safety Kit The Battlement Mesa Site Safety Officer shall maintain a safety kit specifically designed for that site. It shall be available for transport to an emergency location. The kit should include, at a minimum: Ursa Resources Group, 11 PAGE 12 of 35 bursa EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION 1 9 -JUN -14 sion 00 • First response bags/first aid kits. • AED (available for trained personnel only). • Eye wash kit. • Spill response materials such as absorbent pillows, vermiculite. etc. • Minimum 20 Ib. ABC fire extinguisher. • Spotlight/flashlights. 8.2 Additional Information for Specific Emerggncies Additional information for specific emergencies includes: • Bomb or Terrorist Threats • Explosions • Evacuations Fires • Floods • Earthquakes • Severe Storms • Power Failure • Material or Chemical Spills • Medical Emergencies • Public Disturbances • Transportation/Vehicle Incidents • Special Actions at the Pond Site • Shelter in Place 8.2.1 Bomb or Terrorist Threats If a bomb threat is received, stay calm. It is important to keep the caller on the line to obtain as much information as possible. Someone other than the call recipient should notify the Project Coordinator or Site Manager of the threat while the caller is still on the line. A bomb threat may be followed by a site evacuation depending on information obtained from the caller. 8.2.2 Explosions If flammable natural gases or liquids are released, the following action should be taken immediately: • Evacuate all personnel from area. • Shut down all running equipment. • Close all valves upstream and downstream of leak. • Call 911. • Contact appropriate Ursa personnel and implement notification chain of command. • Follow instructions in "Fire" section in case of a fire. • If personnel are injured, apply first aid as trained to do so and transport them to nearest medical facility, if possible. Otherwise, wait for emergency responders to arrive. Ursa Resources Group, II PAGE 13 of 35 igePursa GROUP CES c�RouP i� EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revi 10 - 8.2.3 Evacuations Depending on the emergency, personnel shall evacuate to a location upwind and uphill, if possible. Personnel shall meet at the designated safe area and a head count will be taken by the supervisor or designee to ensure that everyone is accounted for. A call for an evacuation may be restricted to a specific work area or executed for the entire site. Area evacuations can be ordered by any Company employee, contractor, subcontractor, or others during an emergency. A site -wide evacuation may be authorized by the Project Coordinator, Site Manager, Site Safety Officer, and/or Incident Commander. All buildings, truck bays, and tank farms must be evacuated if the fire alarm sounds or if authorized personnel orders an evacuation. Never ignore an emergency alarm. Evacuation beyond muster points may be required. The Incident Commander will direct evacuation beyond muster areas to an area of safe refuge. When instructed to evacuate, proceed with the following: • Implement emergency shut -down procedures by activating the emergency shut-off valves on all equipment. • Identify the direction of the wind by observing the direction of the wind sock and evacuate immediately cross or upwind of the affected area to the designated assembly area or muster point. • Follow the primary exit route. If the designated route or assembly point is not accessible or safe due to wind direction, proceed to a secondary or alternate assembly area as designated herein or by the Incident Commander. • If primary exit is blocked or unable to be reached, choose secondary evacuation route. • All radio traffic should cease except for those authorized to broadcast emergency information on the main radio channel. A radio channel may be designated for supervisors to communicate with an emergency coordinator or a Company representative. • Assist injured persons evacuating the site as needed and if able and trained to do so. DO NOT CAUSE MORE HARM AND DO NOT BECOME ANOTHER VICTIM BY RUSHING INTO A HAZARDOUS ENVIRONMENT. ▪ All engine -driven equipment should be shut down and engines turned off. Keys should be left in the ignition. • Vehicles should be parked and clear of traffic lanes and access routes. Emergency vehicles and personnel must have clear access to the location. • Move to the predetermined muster point away from the incident. • If individuals are ignoring the alarm, warn them to evacuate immediately. Do not get involved in an altercation, but notify the supervisor immediately of the location of these employees. • Do not reenter the work area until directed to do so by authorized personnel or after the "All Clear" signal has been given by the Site Supervisor. 8.2.3.1 Assembly Areas/Muster Point Assembly areas are designated safe refuge zones during a site emergency. If prevailing winds put either the primary or secondary muster point downwind ion 00 UN -14 Ursa Resources Group, II PAGE 14 of 35 bursa EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION evision 00 90 -JUN -14 of the accident site. workers will be directed via radio or cell phone to an alternative area. All personnel must be aware of the primary and secondary muster points, even if they are NOT marked. PRIMARY MUSTER POINT SECONDARY MUSTER POINT South Entrance Gate at Access Road to the East of Staging Area. South and West of Entrance Gate on the access road across from the Staging Area. HELICOPTER LANDING ZONE South of the Site, across the access road, on relatively flat ground with no overhead obstructions or trees. Power lines lie to the north of the site and do not cross this area. 8.2.3.2 Evacuation Routes Evacuation routes will be clearly communicated to all personnel by postings or radio directives as mandated by changing conditions. As stated above, the primary evacuation route shall follow the access road that leads away from the site and towards Stone Quarry Road to the north of the location. If conditions warrant, this evacuation route shall be revised to account for upwind possibilities that are safer than traveling downslope along the access road during certain emergency situations. The Incident Commander and Site Safety Supervisor will determine if a change in the primary evacuation route is mandated. • Evacuation routes shall be upwind of any hot zone or exclusion zone and windsocks shall be visible to all site personnel to determine which exit route to take during evacuation. • Travel south or west away from the staging area and the on or offloading area of the site. • If the primary evacuation route is unusable, workers shall be directed via radio to an alternate route. The Project Coordinator or Site Manager will ensure evacuation routes are rehearsed as a part of regularly conducted site emergency drills. 8.2.3.3 Personnel Accountability The Incident Commander or Safety Officer shall use an accountability list to account for all personnel. The accountability list shall be based off the Site's daily sign-in/sign-out log or sheet. A count of all personnel shall be done at the muster point. The names of missing and/or unaccounted for personnel must be delivered to the Project Coordinator as soon as possible. CAUTION: Searches for missing personnel shall be conducted only if possible to do so safely. No personnel shall conduct a search in dangerous conditions. Ursa Resources Group, 11 PAGE 15 of 35 Geo SOURCES rsa GROJP II EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 8.2.4 fjjg The objective is to take actions that might reduce the consequences of a fire in the event one occurs at the Pond Site. When a fire alarm sounds, leave immediately. Instruct all employees to leave the area immediately as you evacuate and notify the supervisor. Be aware of individuals who may need assistance. Do not reenter the site until directed to do so by authorized personnel. 8.2.4.1 Extinguishable Fire (Incipient Stage) • Report the fire by activating the nearest fire alarm. • Use a fire extinguisher in your area to extinguish the fire, if trained to do so. • Use the PASS system: a. Pull the safety pin. b. Aim — Remove the hose and aim the nozzle toward the fire. c. Squeeze — Holding the handle, squeeze the trigger. d. Sweep — Extinguish the fire in a sweeping motion, from left to right. • Immediately report the incident to the supervisor. • Rule of thumb: If you have already discharged one 20-30 pound fire extinguisher at the base of a fire and have made no impact on the fire, then it is beyond the incipient stage and steps in Section 8.2.3.2 below must then be followed. 8.2.4.2 Non -Extinguishable Fire • Report the fire by activating the nearest fire alarm and contacting the supervisor on duty. • Call the fire department and give all needed information, referencing the emergency numbers listed herein. • Conduct an emergency shut down and evacuate the area. If a potential wildfire breaks out, the most important thing is accountability. First notify someone of the fire. Second, call the Rifle Fire Protection District immediately. The sooner the fire department is dispatched, the quicker the response time. All fires on federal lands require immediate Ursa Resources Group, II PAGE 16 of 35 evision 00 10 -JUN -14 t.?LJrsa RESOOURCUES GRP II EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION notification to applicable Ursa personnel. If the fire cannot be put out by the fire extinguisher in the incipient stage, it is time to evacuate the area immediately. 8.2.5 Flood Floods are unlikely to affect operations at the Battlement Mesa Site. Flood conditions will most likely occur from runoff associated with thunderstorms, heavy rain, snow melting, or broken pipelines. It could also occur if any pipelines or on-site tanks break. The actions taken in the event of a flood will depend upon the amount of warning received before a flood actually occurs. Flooding associated with thunderstorms can result in rapid increase in flow in drainages and flow into the pond. Stay away and out of that area. In the event of such conditions, notify the Site Safety Officer. Flooded roadways may be encountered while traveling to or from the jobsite. Drive with care and never attempt to drive through flooded road sections. 8.2.6 Jrarthauake The likelihood of an earthquake at or near Western Colorado is highly unlikely. This information is provided for awareness only. Be prepared for additional aftershocks. They are usually smaller, but can cause additional damage or bring weakened structures down. Do not attempt to move seriously injured persons unless they are in immediate danger of further injury. Report the location of the injured person to emergency personnel. 8.2.6.1 Indoors • Stay inside. Falling debris can cause serious injury outside. • Take cover under a sturdy desk, table, or other furniture, in a supported doorway, or along an inside wall. • Stay as far away from glass and windows as possible. • Extinguish open flames and do not use lighters, matches, or candles, due to possible gas leaks. • After tremors have ceased, leave the building until structural safety can be assessed. Do not enter any building until structural integrity can be verified. 8.2.6.2 Outdoors Move away from buildings and utility wires. Once in the open, stay there until the tremors have stopped. 8.2.6.1 Moving Vehicle • Stop as quickly as safety permits. Remain in the vehicle. • When tremors stop, drive carefully and watch for falling objects, downed electrical lines, and broken or undermined roadways. 8.2.7 Severe Storms Colorado weather at all times of the year can be unpredictable. To prepare for contradictory conditions, personnel shall monitor news and weather reports for forecasts. Supervisors should be warned of threatening conditions. Ursa Resources Group, 11 PAGE 17 of 35 G?Ursa RESOURCES GROUP II EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 Ursa will keep supervisors informed of the changing conditions and the effects of weather on operations. Supervisors will subsequently inform all employees. Supervisors will look at the difference in the drive time to and from the work site due to severe weather and adjust accordingly, if necessary. Supervisors will also review the appropriate PPE for the particular weather condition and inform all employees of any necessary changes. 8.2.7.1 Tornado or Severe Lightning • If a tornado or severe lightning is seen, sound the alarm and evacuate. • Seek shelter away from the pond, trailers, and vehicles. • Get low to the ground, away from trees, preferably in a ditch or depression if no likelihood of flash flooding exists in the area. • If time allows, notify others of your location and situation. • Do not attempt to outrun severe weather or flash floods. • Do not park beneath tress and avoid exposed areas such as ridgelines and natural washes. • Seek shelter if available, otherwise stay in vehicle. • If caught out of your vehicle, proceed downhill to a Tess exposed side slope location. Avoid trees, fences, large rocks. Squat in the open on the balls of our feet with y our head down. Cover ears with hands, elbows in, and wait the situation out. • Never attempt to walk or drive across flooded roads or ditches. 8.2.7.2 Blizzard • Tune into and monitor local weather radio or news broadcasts. • When blizzard has been issued, immediately notify office and field personnel that may be affected. • Inform others to tune into weather broadcasts and stay abreast of possible conditions and/or weather changes in their area. • Inform personnel if blizzard is underway. • If stranded in blizzard conditions, notify others of deteriorating conditions along with your location and situation before communications are lost. • DO NOT leave your vehicle unless absolutely necessary. Assure exhaust pipe is clear of obstructions (such as snow buildup) and run engine only when needed, so fuel is conserved. • If stranded away from vehicle or if necessary to abandon it, seek shelter in a stable structure and wait for help to arrive. If shelter is not available, build a snow cave and wait for help. If caught outside of shelter, build a fire if possible. • Tray and stay dry. Change to dry and weather resistant gear. • If caught with more than one person in a blizzard, DO NOT SEPARATE. Provide assistance to others if you are capable. • Do not attempt to walk off the mountain during blizzard conditions. 8.2.8 Power Failure If there is a power failure at the Battlement Mesa Site, proceed with the following steps: • Switch off all equipment being used to prevent injury when power returns. RESOJRCES GROUP II EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 • Ensure all other equipment or switches are turned off to prevent possible damage to equipment from power surges when power is restored. • Notify the supervisor in charge of your actions due to the power failure. After the power has been restored, check your area and report any equipment or other damage to your supervisor. Verify that all electronics are up and running, and report any discrepancies. 8.2.9 Material or Chemical Release and/or Spills Actions in the event of a spill of petroleum products or toxic materials, including condensate and process water, will be provided in Ursa Resource's Spill Prevention, Control and Countermeasure Plan for the Battlement Mesa Site. Notify all employees and other appropriate personnel of the spill and any chemicals involved. All employees will comply with the Company's personal protective equipment policy for any chemicals they are using or to which they may be exposed at the Site in the event of a spill. 8.2.10 Medical Emergencies While all employees are responsible for immediate action in response to a medical emergency, no employee is required to provide first aid for which he or she has not been trained or if uneasy about doing so. Occasionally accidents will happen where individuals, including the victim, will assume that no injury has occurred and that no medical attention is required. If symptoms become evident later, an Incident Report needs to be filled out and turned into the supervisor on duty. The injury incident will then be investigated and analyzed for root causes to mitigate or eliminate hazards that led to the incident. Different procedures for varying degrees of medical emergencies shall be utilized by site personnel when responding to a medical emergency. 8.2.10.1 Life Threatening EXAMPLES: Unconsciousness, inability to move, potential spinal injuries, seriously broken bones, uncontrollable bleeding, heart attack, stroke, inability to breath, etc. • Do not move the victim unless he or she is in a life-threatening situation or environment. Render first aid applicable to your training and abilities. • Call for emergency help and reference the emergency phone numbers listed herein. If necessary, send someone to meet emergency personnel and bring them to the victim's location. • Notify supervisor immediately and report the following: - Name of victim. - Date and time of injury. - Description and/or circumstances of the injury. - Brief summary of what happened and include actions taken as a result. - Names of witnesses. - Conditions of the site or location of injury. - Need for Incident Report Form. Ursa Resources Group, 11 PAGE 19 of 35 EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION sion 00 i -JUN -14 bursa 8.2.10.2 R Non -Life Threatening EXAMPLES: cuts, abrasions. sprains, fainting, simple fractures, etc.) • Immediately contact medical services by referencing emergency phone numbers. Render first aid applicable to your training and abilities. • Notify the supervisor of the injury and report the following: Name of victim Date and time of injury. Description and/or circumstances of the injury. Brief summary of what happened and include actions taken as a resu It. Names of witnesses Conditions of the site or location of injury. Need for Incident Report Form. 8.2.10.3 General Basic guidelines for medical emergencies: • Make sure it is safe to be in the victim's area; • Call 911 and request an ambulance. Provide the following information: Number and location of victim(s); Nature of injury or illness; Hazards involved; and, Nearest entrance (emergency access point.) • Alert trained employees to respond to the victim's location and bring a first aid kit and/or AED. • Notify the Site Supervisor or Site Manager. • Only trained responders/personnel shall provide first aid and assistance. • Never move a victim in need of medical assistance unless: Directed by a competent medical authority. The injury will not be aggravated or complicated by a move. Greater physical harm to the victim likely if not moved from current location. Wound severity is life-threatening. • Take "universal precautions" to prevent contact with bodily fluids and exposure to bloodborne pathogens. • Meet the ambulance at the nearest entrance or emergency access point and direct them to the victim(s). Never delay EMS access to the scene while applying administrative controls or prescribing personal protective equipment. Decontamination of victims, emergency medical services (EMS) personnel, and any associated equipment and materials will be performed in proportion to the nature and severity of the medical emergency. Ursa Resources Group, 11 PAGE 20 of 35 Ursa EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION R -vision 00 10 -JUN -14 8.2.11 Public Disturbance Actions A public disturbance is defined as a demonstration by activists or a threat to operations on the Battlement Mesa Site. Public disturbances can take the form of events that may serve to: • Disrupt Company. contractor, or subcontractor operations. • Adversely affect Company or contractor properties. • Jeopardize the safety and health of Company, contractor, or subcontractor employees. • Adversely affect the reputation or public image of the Company. • Threaten or cause bodily injury or hazardous material exposure to the general public. If there is no immediate threat to personal safety, the Project Coordinator or Site Manager will work with the corporate and off-site emergency response organization(s) to determine the appropriate response actions needed to safeguard personnel and property during a public disturbance, as they often occur with little or no warning. 8.2.12 Transaortation or Vehicle Incidents A vehicle collision is defined as any vehicle contact or damage requiring repairs to a Company vehicle, another vehicle. and injury to a pedestrian, animal, or third -party, or damage to Company property. 8.2.12.1 Vehicle Accident • STOP. NEVER LEAVE THE SCENE OF AN ACCIDENT. • Obtain help for injured persons. • Notify policy and a Company supervisor. • Obtain necessary information at the scene Exchange only driver's license number and insurance information with other driver. DO NOT make commitments. State the collision will be reported to your company. Any liability will be determined by the Company and its insurance carrier. DO NOT express opinions or become involved in arguments. • Have witnesses provide address and telephone numbers. • If injury results from a vehicle accident, an injury report must be completed. 8.2.12.2 Transportation Incident A transportation incident is an emergency event involving vehicle/truck transport of operation materials (such as sludge, acids. bases, or polymers) being delivered to, or shipped from, the Battlement Mesa Site. • If an injury requiring immediate medical attention occurs, or if there is a potential for impact to the environment that cannot be contained with a small spill kit or hand tools, the incident will be handled by off-site response organizations. • The carrier used for transportation incidents shall be included in all accident investigations involving their transport vehicles. • Conveyance or transportation employee/staff shall be trained to minimize the contamination of property by inspecting shipping Ursa Resources Group, 11 PAGE 21 of 35 W'Ursa RESOURCES GROUP II EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 equipment for any leaking material, signs of damage or excess wear prior to its use. • Conveyance or transportation employee/staff shall be trained to respond to an emergency without endangering personal safety. • Shipping personnel will immediately notify the Site Manager or Site Safety Officer and/or the off-site emergency response organizations of the potentially hazardous emergency and the possible threat to the public's health and safety, the potential impact to the environment, and any possible or impending damage to property. • The Project Coordinator, Site Manager, Site Safety Officer, or the conveyance company will coordinate contractor emergency response cleanup support as needed. NOTE: If the amount of material spilled exceeds the reportable quantity (RQ) as defined in the Hazardous Substance/RQ Table by the Department of Transportation and the Environmental Protection Agency, the National Response Center will be contacted by the Project Coordinator within twenty- four (24) hours of the incident at 800-424-8802. 8.2.13 Media Resaonse No personnel will talk to any media representative without prior approval. All comments will be referred to the Ursa Resources Operating Company representative or the Corporate Office in Denver. Employees shall state "no comment" to any media questions posed to them. 8.2.14 Shelter in Place If chemical, biological, or radiological contaminants are released into the environment in such quantity and/or proximity to the rig site, it may be safer to remain indoors, or shelter - in -place, rather than to evacuate. Such releases may be either accidental or intentional. "Shelter -in-place" means selecting a building with few windows, or none at all, in which to take refuge. In many cases, local authorities will issue advice to shelter -in-place via TV or radio. Use common sense and available information to determine if this type of refuge is necessary. In any emergency, local authorities may or may not immediately be able to provide information on what is happening and what you should do. If large amounts of debris are in the air, or if local authorities say the air is badly contaminated, a shelter -in- place order should be issued by the Incident Commander. To shelter -in-place, follow these instructions: • Lock exterior doors and close windows, air vents and other openings. • Turn off all fans, heating and air conditioning systems where present. • If there is danger of explosion, cover windows to protect against flying glass and debris. • Use duct tape and plastic sheeting to seal all windows, doors and vents. • Gather essential disaster supplies such as food, bottled water, battery -powered radios, first aid supplies, etc. Ursa Resources Group, 11 PAGE 22 of 35 tliUrsa RESOURCES GROUP II EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 • Write down names of everyone in the room and contact Ursa's designated emergency contact to report who is in the room with you and their affiliation with the business. • Avoid overcrowding and do not select a room with mechanical equipment like ventilation blowers or pipes because that equipment may not be able to be sealed properly. • CaII emergency contacts and have phone available to report a life threatening condition, if necessary. • Listen to radio, etc., for further information and additional emergency notifications. 9.0 WILDFIRE MITIGATION MEASURES The predominant causes of wildfire are lightning, recreational activities, residents, industry activities (industry category is ranked the third highest human -caused ignition source), railroads or other agents. A contributing factor that poses additional risk to oil and gas installations are traveling embers from existing fires that are carried on the wind and can ignite upon contacting structures and uncontrolled vegetation. Radiant heat from wildfires also poses a risk to structures and personnel at oil sites. Smoke from wildfires can affect evacuation routes and staging areas. Thus, any emergency response plan specifically addressing wildfires must take into account the following: • Increased safety for personnel; • Reduced risk to industry infrastructure from wildfires; • More secure production schedules less likely to be disrupted in the event of a wildfire; • Reduced liability from wildfires caused by the oil and gas industry; • Increased environmental stewardship and overall corporate responsibility. In addition, several factors affect a site's susceptibility to wildfire hazards and the potential for wildfires to be fueled by site installations. By assessing structures, vegetation, powerlines, equipment used on site, and work tasks conducted on site, Ursa Resources has evaluated the Battlement Mesa Site and created the measures herein for dealing with wildfire risk and potential occurrence. 9.1 Definitions CONIFEROUS VEGETATION FUEL TYPE — Any of various needle -leaved (mostly) or scale -leaved, chiefly evergreen, cone -bearing trees or shrubs such as pines, spruces, and firs. DEBRIS — The woody or herbaceous material which results from vegetation clearing operations. DECIDUOUS VEGETATION FUEL TYPE — Typically used in reference to trees or shrubs that lose their leaves seasonally, and other plant structures that shed (such as petals or seed structures) after flowering or fruit when ripe. EMBER TRANSPORT — Embers or fire brands are produced as trees and other combustible objects burn. These embers carry in the atmosphere and by winds over long distances. Hot embers ultimately come to rest and may ignite surfaces far removed from a fire, thus resulting in fire spread. This process is commonly referred to as spotting. Ursa Resources Group, 11 PAGE 23 of 35 1 ision 00 0 -JUN -14 C2u RESOURCES GROUP II EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Re FIRE BEHAVIOR — The manner in which fuel ignites, flame develops and fire spreads as determined by the interaction of fuels, weather, and topography. FIRE HAZARD — A hazard based on physical fuel characteristics, such as fuel arrangement, fuel load, condition of herbaceous vegetation and presence of elevated fuels. A general term to describe the potential fire behavior without regards to the state of weather influenced fuel moisture content and/or resistance to fireguard construction for a given fuel type. FIRE OCCURRENCE — The number of fires started in a given area over a given period of time. FUEL BREAK — An existing barrier or change in fuel type (to one that is less flammable) or a wide strip of land in which the native vegetation and topography has been modified or cleared to act as a buffer to fire spread so that fires can be more readily controlled. A strategically planned barrier, either manually or mechanically constructed that is intended to stop or slow down the rate of fire spread and from which suppression action can be carried out to control a fire. LADDER FUELS — Vegetation that will help carry a surface fire up to the tree crown/tops that result in a crown fire (typically in coniferous fuel types.) HAZARD REDUCTION — Treatment of living or dead forest fuels to diminish the likelihood of a fire starting and to lessen the potential rate of spread. MINERAL SOIL — Non-organic soil. MITIGATION — Action that decreases the severity of a fire hazard or risk. MIXED WOOD VEGETATION FUEL TYPE — A 'mixed' forest in which two or more tree species are predominant in the canopy. RADIANT HEAT TRANSFER — Heat transfer to the surrounding environment through radiation. RISK FROM WILDFIRE — The potential of loss from wildfire that can be calculated by multiplying damage or loss by uncertainty of occurrence and contributing factors. SUPPRESSION CAPABILITY — The factors and limitations that are related to the ability to contain a wildfire upon detection in order to protect values at risk. STAGING AREA — A location at an incident where resources can be placed while awaiting tactical assignment. Also used to describe an area where tasks are conducted that may be dangerous or hazardous if performed on-site or near installations. Ursa Resources Group, 1I PAGE 24 of 35 tliUrsa RESOURCES GROUP 11 EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION R VALUES AT RISK — The specific or collective set of natural resources and man-made improvements/developments that have measurable or intrinsic worth that could be destroyed or otherwise altered by fire in any given area. WICKING — Vegetation connectivity or pattern that contributes to an increase in fire spread. WILDFIRE — Any unwanted or unplanned wildland fire that burns in forested or grassland areas. 9.2 Structures and lanition Potentia( The distance between structures and flammable vegetation can affect structural ignition potential through ember transport or radiant heat exposure to structures or vegetation. It's important to note that a wildfire will burn more rapidly and intensely on slopes compared to flat or level ground. As a result, structures on or adjacent to a slope with vegetation below are more susceptible to wildfires and face a significantly higher probability of ignition due to heat exposure. The radius around structures must be assessed according to the structure's materials, flammable storage units (e.g., hydrocarbon storage tanks), and on-site vegetation. The roof of a structure is the most vulnerable component for fire ignition and the main cause of structural losses during a fire. Embers and flaming debris from wind -driven fires can travel great distances, and embers landing on a combustible roof surface can start a new fire. Flammable material storage on site, such as hydrocarbons or propane tanks, also creates additional threats to structures based on: 1. Presence or absence of hydrocarbons on site; 2. Flammable material rating; 3. Potential for accumulation of airborne embers on tanks; and, 4. Distance from storage sites to forest vegetation. Structures with metal, tile, asphalt, or non-combustible materials, such as concrete or metal siding, and that have no eaves or contain screened vents with openings turned down, possess the lowest flammability risk. Those with wood or vinyl siding and/or open eaves and no soil or metal covers at the base of the structure where embers can be trapped, pose the highest flammability risk. The location of petroleum products and combustibles (such as storage tanks) from fuel sources also increases or decreases flammability risk. Storage that is not located near structures, or that is more than ten (10) yards from those structures, pose the lowest risk. Storage sites that are 3-10 yards from a structure pose a mid-level risk, and those that are Tess than 3 yards from any structure pose the greatest flammability risk. To prevent the entry of airborne embers, all eaves and vents will be inspected to ensure they face downward to decrease the chances of embers accumulating in them and Ursa Resources Group, 11 PAGE 25 of 35 gfoursa RRSOUdJPRCES GRII EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 increasing the potential for fire on the site's structures. Any tanks located on site, such as the saltwater storage tanks, will be handled in this manner. 9.3 Vegetation Manaaement The main point to managing vegetation around the site is to minimize the risk of high- intensity crown fires. This can be done through several steps, beginning with thinning any surrounding forest stands to less than 40% of the surrounding area with at least 3 meters between crowns (of the trees) and decreasing crown cover (the percentage of ground area covered by tree crowns if viewed from above) to that level. At the Battlement Mesa site, there are very few tree stands and even fewer shrubs around the site that could affect the flammability of the landscape. As a result, all measures to mitigate the risk posed by the existing vegetation will focus on vegetation reduction and, in some rare cases, vegetation removal. By partially reducing flammable coniferous forest vegetation around the site, Ursa Resources has already reduced crown fire potential and lowered the wildfire intensity, spread, and spotting risks. Vegetation removal is recommended as the best management strategy for wildfire mitigation, Ursa Resources has maintained native vegetation for landscaping purposes as requested by local officials, and to mitigate other risks to the site such as soil erosion. Vegetation differs in its flammability as some species are MORE resistant to burning, while others are LESS resistant to burning. The flammability rating of different tree species can be determined, but Battlement Mesa Site has mostly native grasses and noxious weeds on its site. The surrounding areas contain some smaller coniferous trees, but Ursa Resources has eliminated any of that vegetation at the pad site. Because grass vegetation increases soil stability and decreases soil erosion, the existing vegetation will be managed accordingly by keeping it a good distance from any structures (as indicated above) and ensuring any grass near installations is kept relatively short. The Company has reduced all trees from the site location, built a berm to act as a buffer between the pad site and the staging area, which is located uphill from the storage tanks and pipeline facilities. Any vegetation management treatment outside the site's boundaries may require coordination and communication, as well as approval, from any of those agencies listed above, including the Colorado National Forest Service. 9.4 powerlines Falling trees can come into contact with powerline conductors and thus ignite wildfires and interrupt power to the site. Burned wooden power poles can also interrupt the current in distribution lines. Trees that come in contact with powerlines may also cause a ground arc, which can result in power outages and/or cause a wildfire ignition. None of these risks are present at the Battlement Mesa site because there are no trees large enough or near enough to the powerlines that pose a falling risk, and the power lines are constructed of metal towers and do not have wood power poles. In addition, the local utility company is responsible for the right-of-way easement where the powerlines are constructed to the south of the site and thus fall within the utility company's responsibility for vegetation and Ursa Resources Group, 11 PAGE 26 of 35 WUrsa RESOURCES GROUP 11 EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 structural management. As a result, Ursa Resources shall contact the local utility company to establish maintenance schedules and responsibilities of those agencies in maintaining the areas surrounding the power lines. Should any potential hazard develop that needs attention, Ursa Resources will contact the utility company and report it immediately. Disruption of a continuous electrical source of power during a wildfire incident may have a significant impact on industrial activities. Ursa Resources has installed back-up measures and power shut-off procedures for the site in the event of a wildfire emergency. 9.5 Debris Piles In order to decrease the risk of holdover fires from debris piles, best management practices require mulching rather than burning. If burning is used, ensure all legislative requirements are met and the proper permits are obtained prior to commencing a burn. After the burn is completed, ensure the remaining debris piles are properly extinguished by using one of the following three approaches: • Use a bare hand to check for hot embers (referred to as cold trailing); Use a temperature probe or metal rod to detect heat within the piles; or, Use infrared technology to scan the debris piles for residual hot embers. Where feasible, utilize a portable burning sled to reduce holdover potential and accelerate burning combustion, and reduce the amount of soil contained in the woody piles to allow for more efficient burning and help reduce the chance for holdover fires. 9.6 ATVs and/or Eauiament Personnel will be briefed on proper maintenance of ATVs and inspecting the vehicle's exhaust system at regular intervals when operating and to park on sites with bare mineral soil, gravel or cement. Best Management Practices also recommend carrying a small container of water that can extinguish small fires if one should ignite from the exhaust system. Use of ATVs and other light vehicles with catalytic converters should not be parked in areas where tall dry grass is prevalent. Consider restricting the use of these vehicles, ATVs, during prolonged periods of extreme fire danger levels and forest closures due to fire risk. In addition, travel on ATVs should occur during the early morning and later evening when relative humidity is usually higher. Heavy equipment exhaust systems can cause wildfire ignition by one of the two following means: 1. Clearing forest vegetation with heavy equipment can cause an accumulation of very fine organic material on the exhaust systems. This organic material dries and if heated on exhaust systems to high temperatures that can cause it to ignite. Through vibrations, the ignited materials can fall to the forest floor and ignite vegetation, thus causing a wildfire. 2. Diesel engines that idle for long period build up carbon in the exhaust system. When the engine is throttled up and placed under load, small, hot carbon pieces can be expelled, causing wildfire ignition. During windy days, particles can be Ursa Resources Group, 11 PAGE 27 of 35 ?Ursa EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION R carried longer distances from the equipment and pose an even greater wildfire hazard. Ursa Resources will ensure that contractors inspect and clean their heavy equipment exhaust systems on a regular basis. While cleaning the equipment, park it on bare mineral soil if possible or spray the area with water before driving the equipment over the wet area to clean. Place heavy equipment with diesel engines over mineral soil or other non- flammable material. Then throttle up and place the diesel engine under load to expel any loose carbon particles after considering wind speed first. 9.6.1 Welding Operations Employees and contractors operating in wildland areas on the site shall conduct their operations on mineral soil if possible. As an alternative, during high fire hazard periods, the work area where welding is to take place can be wet down with water or foam additives if allowed by the Forest Service. Water is not very effective in fibrous soils during high and extreme build up indices (BUI), however. Ursa Resources will also ensure that all employees and contractors performing welding operations will have the appropriate equipment on hand for fire and emergency situations. Another option is to use a non-flammable shield around the area where welding will take place to confine and prevent the sparks from spreading in all directions. If it is essential to conduct welding operations during high and extreme fire danger periods with very high probability of wildfire ignitions, then a water tanker and crew may accompany the welding operation to patrol, detect, and extinguish any fires that may be ignited. Wildfire foam additives can be considered for use when welding on pipelines during high and extreme ignition potential periods to reduce the amount of water required to be on hand and to ensure the water penetrates into the organic layers. Properly mixed foam will increase the effectiveness of water by 3-5 times, depending on the foam and equipment used. Foam solutions act as a fire suppressant rather than a fire retardant. A suppressant extinguishes the flaming and glowing phases of combustion when applied directly to forest vegetation. 9.7 Emergency Response Measures to Wildfires Personnel should always know what to do during a wildfire, and thus URSA Resources will ensure that all personnel are trained on the provisions in this procedure for clarification and knowledge about wildfire hazards that may exist at URSA's locations. During a wildfire emergency, personnel should (1) determine the minimum number of personnel required to operate during a wildfire threat; and, (2) issue evacuation alerts. 9.7.1 Wildfire Evacuation Routes Evacuation routes are critical for evacuating personnel from a location during a wildfire emergency. It should be noted that visibility during a wildfire may be drastically reduced due to smoke drifting across access roads, and thus knowledge Ursa Resources Group, 11 PAGE 28 of 35 U rsa RESOURCES GROUP II EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 of evacuation routes and training thereon assist personnel in properly evacuating if needed. When identifying evacuation routes: • Identify safe helicopter landing areas for air lift evacuation. If road access has been cut off, helicopters may provide the only means of evacuation. • Identify adjacent waterways that can be accessed by boat if applicable. • Identify current roads into the site. Assess the threat of wildfire on the potential evacuation routes. 9.7.2 Access Roads All-weather gravel roads should be used as evacuation routes for emergency vehicles or workers. Narrow or dead-end roads without proper turnarounds are particularly problematic for wildfire suppression vehicles since they may not be able to turn around when necessary. Road rings are optimal for this purpose. Whenever possible, access or evacuation routes should double as barriers to fire spread by helping to slow or impede the spread of wildfire. During a wildfire, all-weather gravel routes can be used as both access routes for emergency vehicles and evacuation routes for workers. They may need to be used as both, depending on the location. Narrow or dead-end roads without proper turnarounds can be problematic for emergency vehicles. When detailing emergency access, it's best to identify ring roads and other places where emergency vehicles have the ability to get back out. Access and/or evacuation routes should double as barriers to fire spread as a means for slowing or impeding the spread of wildfire. 9.7.3 Water Sources Wildfire suppression needs substantial volumes of water from a dependable source. There are local water resources near the Battlement Mesa site, but the local emergency responders will determine how and where water sources will be utilized during a wildfire. By having water sources integrated into the plan, both the wildfire and structural fire suppression capability of the site will be greatly enhanced. 9.7.4 Personnel Safety Employees should know what to do during a wildfire emergency. During a wildfire emergency, determine the minimum number of personnel required to operate during a wildfire threat and know when to issue evacuation alerts. If evacuation alerts have been issued for a site, Ursa personnel should follow these protocols and ensure that all other emergency shut-off measures as identified by the Emergency Action Plan as well as additional site measures determined by the Company, shall also be followed. A proper assessment for access roads and water sources near and around the site should be analyzed to determine the flammability risk of the site and whether or not these resources can be used for proper fire suppression and fire barriers in Ursa Resources Group, 1I PAGE 29 of 35 0)101 PESOURCES GROUP II EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 order to protect personnel. If these resources are deemed adequate to reduce high flammability risk, then they should be included as part of a site drawing and given to local emergency responders who would be responsible for fighting the wildfire. Obviously, the lowest flammability risk occurs with facilities that have gravel or paved access roads to the facility that can also be used as evacuation routes and which have fire suppression measures located on site (such as natural water resources), and that ensure emergency vehicles have a proper turnaround for entering and leaving the site during an emergency. Employees must be adequately trained on the evacuation plan and routes, the facility management to reduce wildfire risk, flammability of surrounding vegetation, contact numbers for local agencies (including utility company for powerline management), and emergency alarms and local emergency warnings in order to successfully maintain a safe work environment. In case of a nearby wildfire that poses no risk to the site and which has not prompted evacuation orders, employees shall monitor the site for ignitions from embers and extinguish them ONLY to ensure personnel safety if evacuation orders have not been issued and ONLY if employees have been properly trained on how to use the fire extinguishers. Once evacuation orders have been issued, employees shall follow emergency protocol and NOT fight the wildfire. The local emergency responders are responsible for wildfire firefighting and Ursa personnel need to stay out of their way by evacuating and allowing emergency responders to do their job. Ursa will obtain and maintain emergency contact lists. including the numbers of local emergency responders and reporting agencies in case of a wildfire warning or evacuation measure issued due to wildfire risk. The number of on-site personnel should be decreased, or evacuated in its entirety, after emergency shut- down procedures and other measures in the Emergency Action Plan are completed, if possible. In addition, evacuation staging areas to be used during a wildfire event shall be identified, and then personnel shall be made aware of evacuation alerts, routes, and staging areas away from the wildfire and the method to be used for those alerts so that personnel know what to do in case of a wildfire. The methods of transportation for evacuation shall also be determined and personnel shall be notified of that method during a wildfire event. Short-term food and safe lodging arrangement may also be determined by Ursa as part of its site- specific wildfire emergency measures. In addition, personnel will be trained and tested, such as conducting mock wildfire exercises, to test the evacuation plans and train personnel in the Emergency Action Plan measures in the event of a wildfire. If the potential exists for Ursa personnel to become trapped by an approaching wildfire, those individuals will be trained to recognize and utilize adequate evacuation staging areas that have been identified prior to commencing operations. Staging areas should have the following characteristics: • Clean burn site, natural cleared area, or constructed site free of vegetation; • Quickly and safety accessed from the worksite; Ursa Resources Group, 11 PAGE 30 of 35 GiUrsa i RESOURCES GROUP 11 EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 Free of hazardous materials; and, • Radiant heat and preheated air associated with wildfire flame fronts must also be considered in evacuation staging area selection and size. For successful employee participation, Ursa shall review wildfire safety issues each spring with its employees. They will inform personnel of the implications of wildfire in the forest environment and be trained upon emergency procedures in preparation for a wildfire event and/or entrapment. In addition, the protocols for reporting a wildfire, or if they see smoke or fire, shall be reviewed. Any wildfire trends, and obtaining and/or monitoring weather information in the surrounding area on days when fire danger is high or extreme, shall also be done by Ursa when necessary. Whenever fire danger ratings are high and extreme and restrictions may be in effect, Ursa will ensure its employees are notified of such conditions and have received proper training for managing those situations (such as obtaining permits, heeding road closures or forest closures, open fire bans, etc.) When possible, Ursa shall coordinate its wildfire prevention measures with state, federal, and local agencies responsible for handling wildfires and other forest management issues. In these instances, Ursa shall attempt to ensure that all items relating to wildfire administration, prevention, pre -suppression, wildfire operations, and training are addressed and understood by its employees and are in coordination with the other agencies' requirements and wildfire measures. Training prepares personnel for a more coordinated and educated approach to both wildfire prevention and wildfire emergency response. Training is essential for firefighter safety, equipment compatibility, integrating communications, understanding procedures and wildfire incident command structures, understanding wildfire management and fire behavior, and developing and implementing consolidated emergency response plans with other agencies as stated above. 9.8 General Wildfire Safety Tias Many incidents that result in tragic and costly losses from wildfire can be attributed to substandard communication and lack of proactive measures in emergency response planning. When planning a wildfire emergency response plan, the following recommendations shall be analyzed: • Incorporating open spaces such as borrow pits, lay down yards, spoil piles, parking lots, for staging equipment and personnel in wildfire emergencies; • Place open spaces downslope and/or upwind of the site (using the existing wind conditions as a guideline): • Use open spaces as a barrier to fire spread if they are at least thirty (30) yards wide on level ground and up to fifty (50) yards wide when located near slopes; • Open spaces should have trimmed short grass, gravel, or mineral soil. • Main access road surfaces should provide two-way access with a travel surface of not less than 6.1 yards; • Fire service access routes should be identified and connect to principal roadways; • Road gradients should not exceed ten (10%) percent; Ursa Resources Group, 11 PAGE 31 of 35 EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 • Dead-end roadways that are more than ninety (90) yards in length should be constructed with a turnaround at the end and have no less than eighteen (18) yards turning radius or a hammerhead "T" alternate turnaround. A site loop or ring road is the best option for short-term planning; • All gates should be located at least nine (9) yards off the main road and does not open downward. Gate openings should provide a clear opening of not less than 0.6 yards wider than the access or traveled roadway; • Fire service personnel should be provided with ready access to any locking mechanisms at the site; Bridges should be designed and built with an all-weather surface capable of supporting heavy pieces of equipment traveling across the bridge. Weight limits should be clearly posted at the approaches to each bridge; • If the main access road is cut off by a wildfire, alternative emergency evacuation routes will be identified; • Natural water sources, such as streams, small lakes, and rivers, should be identified and, if not available, a water storage facility can be developed on high value sites such as tank farms and plant sites for emergency use. Non -draining borrow pits or large tanks may be used for storing large volumes of water in extreme cases, but will only be done at the recommendation of local emergency responders when that agency deems it necessary; and, • Ensure access to natural water sources for tanker trucks and portable pump set- up is identified where possible and if located near the site and in coordination with local emergency responders and their requirements for wildfire firefighting. 10.0 EVENT NOTIFICATIONS AND REPORTING All incidents (serious or non -serious) must be reported to the Safety Officer. Note: All near miss incidents and equipment damage accidents must be reported to the Battlement Mesa Site Supervisor and/or Safety Officer so corrective actions can be taken to avoid the same or similar situations in the future. 10.1 Event Notifications The notifying first responder or acting Incident Commander will report the emergency to Alternate Project Coordinator or Site Manager. Battlement Mesa Site employees/first responders will endeavor to keep all affected agencies informed of any emergency or incident that may occur. Small incidents that do not pose a human health or environmental hazard shall be remedied immediately by trained personnel. Incidents that pose a serious threat to employees, the public, the environment, or property will immediately be reported to the Alternate Project Coordinator or Site Manager. Notifications to outside regulatory agencies shall be made as required. 10.2 Reoortina Requirements Spills or leaks that can be contained wholly on-site or does not represent a reportable quantity (RQ) value as per 40 CFR 117 should be reported to the appropriate Ursa representative. Spills or leaks that meet or exceed RQ values as per 40 CFR 117 will result in the contact of the following agencies: bursa EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 • National Response Center • EPA Region 8 — Mountain States (800-424-8802) (800-227-8917) Spills or leaks which pose a potential threaten public health and safety requires the contact of all the following in addition to those above: • Parachute Police Department (970-285-7630) • Colorado State Patrol (970-328-0249) • Grand Valley Fire Protection District and Emergency Services (970-285-9119) • Grand River Hospital District (970-625-1510) 10.1.1 Emergency Notification Depending on where the incident occurs (on or off the pond site), notification may be required pursuant to the Emergency Planning and Community Right -to -Know Act (EPCRA). The Project Coordinator or Site Manager shall make the determination if reporting is required. Reporting shall contain the following information to the extent known at the time of notice, as long as a delay does not occur in reporting results: Where is the spill? What spilled? How much spilled? • How concentrated is the spilled material? • Who spilled the material? • Is anyone cleaning up the spill? • Are there resource damages (e.g. dead fish or oiled birds)? • Who is reporting the spill? How can the person reporting the spill be reached? 10.1.2 Follow-up Notice Requirements A nationwide notification system has been established for hazardous material spills during transport. The Chemical Manufacturer's Association's Chemical Transportation Emergency Center (CHEMTREC) is located in Washington, D.C. (800-424-9300). The information specialist on duty will ask for the following information: • Name of the caller ▪ Location of the caller • Name of the shipper/Transporter • Product or hazmat involved • Destination of the hazmat • Location of incident • What happened • Weather conditions • Proximity to populated areas. CHEMTREC will give the caller recommendations for controlling the emergency situation until the shipper of the materials and a specialist can contact the caller promptly. Ursa Resources Group, 11 PAGE 33 of 35 EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION 11 POST -EMERGENCY RESPONSE INCIDENT INVESTIGATION Revision 00 10 -JUN -14 Post-Emeraencv Assessment A post -emergency assessment will be conducted by the Incident Commander as soon as practicable following stabilization of the emergency condition. If classification of the emergency or results of the assessment indicate that more extensive investigation is required, the Alternate Project Coordinator, Site Manager, or Site Safety Officer will initiate the investigation. 11.2 Lessons Learned Lessons learned from the emergency will be documented and distributed to appropriate project personnel, incorporated into project personnel training, and used to amend this plan and to institute corrective measures and procedures in an effort to prevent a similar emergency condition in the future. In addition, the lessons learned will be incorporated in the project Operating Experience/Lessons Learned program. Ursa Resources Group, 11 PAGE 34 of 35 EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Attachment A AGENCY EMERGENCY CONTACT LIST Revision 00 10 -JUN -14 NAME PHONE FEDERAL AND STATE GOVERNMENT Bureau of Land Management (970) 257-4800 National Response Center (800) 424-9300 Colorado Oil & Gas Conservation Commission (COGCC) (888) 235-1101 CHEMTREC (800) 424-9300 SEPC (State Emergency Planning Committee) (970) 846-3912 Colorado Division of Wildlife (DOW) (970) 255-6100 US Forest Service (USFS) District Ranger in Rifle (970) 625-2371 Colorado Department of Public Health & Environment (CDPHE) (877) 518-5608 Poison Control Hotline (800) 222-1222 LOCAL GOVERNMENT and OTHER AGENCIES Grand Valley Fire Protection District (970) 285-9119 Garfield County Emergency Communications Center 911 Garfield County Dispatch - Direct (970) 625-8095 Grand River Hospital District (970) 625-1510 Parachute Police Department (970) 285-7630 St. Mary's CareFlight Helicopter (970) 332-4923 Local Emergency Planning Committee — Garfield County (970) 945-0453 URSA OPERATIONS Ursa Operating LLC Emergency Number (855) 625-9922 Ursa Resources Group II, Inc. Main Office (713) 456-3000 NOTE: DO NOT USE "911" from a satellite phone. You will likely not be able to reach a local dispatcher. In many oil and gas work areas, cell phones will not connect with a local dispatch either. The above phone numbers can be used from any phone and will reach immediate response teams. It is very crucial that each individual follows this procedure to ensure an appropriate response time of emergency personnel. Ursa Resources Group, 11 PAGE 35 of 35 Memorandum July 3, 2014 EXHIBIT 1l? Garfield County Oil & Gas Liaison Kirby Wynn RE: Review of COGCC injection well permitting, regional seismic monitoring and induced seismicity In response to BOCC decision to call up a Director's decision regarding an injection well permit application, I gathered relevant information regarding: • Currently permitted injection wells in Garfield County • COGCC injection well permit review process • Current seismic monitoring and observed seismic activity in western Colorado • Research related to induced seismicity from injection wells Currently permitted injection wells in Garfield County According to COGCC records, there are currently 60 injection wells that could potentially be utilized for waste disposal. Of those, 26 have been used for some injection activity since 2013. The attached map displays permitted injection wells near Battlement Mesa. COGCC injection well permit review process Discussed with COGCC staff (Koehler and Eisinger) their injection well permit process. COGCC reviews geologic structure in vicinity of proposed waste injection wells and evaluates potential seismicity, including a review of all regional seismic events from 1973 to present. They also require tests of the well and surrounding formation characteristics. Review process is geared toward determining suitability of the well for waste disposal as well as operational pressure and injection volume limits along with various Conditions of Approval meant to reduce the possibility of adverse impact (i.e. induced seismicity) and to state mitigation requirements if adverse impact is suspected in the future. When COGCC determines a proposed well could present a risk for induced seismicity, they can and do place permit requirements such as shut down procedures in case of a nearby seismic event. 1 Current seismic monitoring and observed seismic activity in western Colorado Western Garfield County is not prone to seismic activity based on discussions with and data provided by Anne Sheehan, Professor of Geophysics at CU Boulder. Dr. Sheehan is the lead researcher conducting investigation of the 2014 seismic events near Greeley Colorado. Received similar information from COGCC and Paul Earle, Geologic Hazards Team at the USGS National Earthquake Information Center. Drs. Sheehan and Earle indicate our area is currently monitored for earthquake activity at a resolution to note earthquakes of minimum 2.5 magnitude event with a location determination of +1- 6 miles. Research related to induced seismicity from injection wells Reviewed several recent academic and other publications regarding factors that have caused induced seismic activity from by waste water injection. The phenomenon is relatively rare as compared to the prevalence of waste injection wells but can occur under certain conditions. COGCC evaluates permit applications with the primary objective to prevent approval of injection wells that could cause induced seismicity such as: Targe or active faults and perturbation of rock pore pressures in the proposed injection intervals. It can be especially important to evaluate less permeable and more brittle formations proposed for injection as those can be the most susceptible to induced seismicity if not managed carefully and using information about the permeability and capacity of target injection intervals. The attached white paper prepared by COGCC describes their research and regulatory response to the latest understanding of induced seismicity. Summary quote from the white paper: "COGCC believes safeguards are in place, in accordance with federal law and COGCC's rules and policies, but we will continue to review induced seismicity findings in other parts of the country with interest. The current safeguards defined by COGCC permit process are injection volume; pressure below the fracture gradient: and, input from the CDWR and CGS to reduce the potential for induced seismicity related to UIC Class II wells. COGCC strives to continually improve our evaluation methods, and the effectiveness of regulations, rules policies and procedures." Sincerely, Kirby Wynn Enclosures 2 Bibliography COGCC, 2011, COGCC Underground Injection Control and Seismicity in Colorado, COGCC Staff White Paper, 5 pages. Earle, Paul, 2014, July 7, 2014 USGS National Earthquake Information Center letter response to query about regional seismic monitoring capabilities, 2 pages. Eisinger, C., 2014, Personal communications from COGCC Senior Research Scientist supervisor regarding COGCC UIC application review procedures and current UIC wells in Garfield County. Koehler, B, 2014. Personal communications from COGCC Underground Injection Control (UIC) Supervisor regarding COGCC UIC application review procedures. National Research Council. Induced Seismicity Potential in Energy Technologies. Washington, DC: The National Academies Press, 2013, 263 pages. Ellsworth, W.L., 2013 Injection -Induced Earthquakes, article in SCIENCE: VOL 341 12 JULY 2013, 7 pages. Zoback, M.D., 2012, Managing the Seismic Risk Posed by Wastewater Disposal, Article in Earth Magazine, April 2012, 6 pages. 3 Injection wells in the Battlement Mesa area Injection Wells, COGCC GIS data Injection Well Status Active Injection Well TD 0 t75 a) a) TD O c ro o o U Q a) L - 0 Q 0 L C/)1- Waiting on Completion, Injection Well Proposed Ursa Injection Well • co CD ttl N 0 0 STATE OF COLORADO CONSERVATION COMMISSION EXHIBIT 12eJ DEPARTMENT OF NATURAL RESOURCES John W. Hickenlooper, Governor 1120 Lincoln St. Suite 801 Denver, CO 80203 Phone: (303) 894-2100 FAX: (303) 894-2109 www. Colorado. govlcogcc January 19, 2011 COGCC Underground Injection Control and Seismicity in Colorado Colorado's earliest documented earthquake occurred on December 7, 1870. The Colorado Transcript stated, "A careful observer at Fort Reynolds, 20 miles east of Pueblo, noted that bottles standing 1 inch apart were knocked together violently." Many earthquakes have occurred throughout Colorado since that time and continue to occur today. Earthquakes are vibrations created when large blocks of the Earth's crust move with respect to one another along a fault plane. The Colorado Earthquake Hazard Mitigation Council published a map in 2008 of earthquakes and faults in Colorado. The map can be obtained at the Colorado Geological Survey (CGS). The United States Geological Survey (USGS) maintains a database of Colorado earthquakes at the National Earthquake Information Center (NEIC) in Golden. Most earthquakes or seismicity occur as a result of naturally -occurring geologic phenomena. However, there have been some cases where seismicity was suspected to have been triggered by injection of fluids into the subsurface. The term "Induced Seismicity" has been used to describe man-made earthquakes of this type. The most notable case in Colorado was at the Rocky Mountain Arsenal (the "Arsenal") near Denver. Earthquakes began after a 12,000 -foot injection well was drilled at the Arsenal for the disposal of waste fluids. Injection commenced in March 1962. Shortly thereafter, an unusually frequent series of earthquakes occurred during the period from January 1963 to August 1967. In 1968 injection stopped, and the Army began removing fluid from the Arsenal well at a very slow rate in an effort to reduce earthquake activity. In Nicholson, 1990, Earthquake Hazard Associated with Deep Well Injection- A Report to the U.S. E.P.A.5 injection volumes were related to earthquake events, demonstrating that these earthquakes were induced by fluid injection at the Arsenal. COGCC, in accordance with federal law and COGCC's rules and policies, believes safeguards are in place to reduce the likelihood of induced seismicity. The current safeguards defined by COGCC permit process are injection volume; pressure below the fracture gradient; and, input from the Colorado Division of Water Resources (CDWR) and CGS to reduce the potential for induced seismicity related to UIC Class II wells. The federal Underground Injection Control (UIC) program began on December 1974 with the creation of the Safe Drinking Water Act (SDWA). The SDWA established the UIC Program, administered by the United States Environmental Protection Agency (EPA), to protect Underground Sources of Drinking Water (USDW's) from impacts related to underground fluid injection practices. The EPA delegated primacy for regulation of Class II UIC wells to the State of Colorado for underground injection of oil and gas exploration and production waste on April 2, 1984. Colorado has administered the UIC program in accordance with federal regulations (40 CFR, Parts 144, 145, 146, and 147) since that time, providing the EPA with semi-annual reports, http://water.epa.gov/type/groundwater/uic/index.cfm. DEPARTMENT OF NATURAL RESOURCES: Mike King, Executive Director COGCC COMMISSION: Richard Alward - John Benton - Thomas L. Compton - DeAnn Craig - Tommy Holton - W. Perry Pearce — Andrew Spielman - Mike King - Chris Urbina COGCC STAFFS David Nestin, Director - Margaret Ash. Field Inspection Manager - Debbie Baldwin, Environmental Manager - Stuart Ellsworth, Engineering Manager COGCC Underground Injection Control and Seismicity in Colorado (cont.) The Colorado Oil and Gas Conservation Commission (COGCC) is the State regulatory agency that permits Class II UIC wells for injection of oil and gas exploration and production waste and enhanced recovery wells. The COGCC Class II UIC permit review process is defined by COGCC Rule 303 Permit to Drill, Rule 324B Exempt Aquifers, Rule 325 Underground Disposal of Water, Rule 326 Mechanical Integrity Testing, and Rules 706, 707, and 712, which identify Financial Assurance requirements. The permit process involves the review and approval of Form 21, Mechanical Integrity Test, Form 26, Source of Produced Water for Disposal, Form 31 Underground Injection Formation Permit Application, and Form 33 Injection Well Permit Application. Information included with these forms and required supplementary documentation describe well construction, ground water and injection zone isolation, fracture gradient, maximum injection rate, maximum injection volume, maximum injection pressure, injection zone water quality, and potential seismicity associated with fluid injection. Injection wells must utilize a well construction method of cemented surface casing and production casing, which isolate and prevent fluid flow between injection zones and USDWs. To verify isolation, the COGCC UIC engineer reviews all relevant information, including: hydrogeologic studies, Colorado Division of Water Resources (CDWR) water well information, and COGCC's geophysical well log database. This information is used in conjunction with specific formation and well construction data submitted by the injection well operator, including resistivity and cement bond geophysical logs to verify that: 1) the surface casing is set below all fresh water zones used as a water supply, and 2) production casing cement placement and quality allows for adequate isolation of the injection zone and USDWs, including fresh water zones that are not currently being used as a water supply. Further, the geophysical logs are used to determine the injection zone thickness and porosity, and the logs are used to verify that the bounding shale zones are thick enough to provide zonal isolation. The COGCC UIC engineer calculates a maximum injection volume, based on thickness and porosity from the log data. By COGCC policy, the injection volume is restricted to a one-quarter mile radial volume. The restriction is intended to constrain the total volume of injected fluids during the life of the injection well. After a well has been drilled and completed into the injection zone, an injection zone water sample test must be submitted. The sample is required to meet EPA -defined levels for total dissolved solids (TDS). COGCC Rule 324B Aquifer Exemption is required, if the sample has a TDS below 10,000 milligrams per liter and above 3,000 milligrams per liter. Water zones containing TDS of less than 3,000 milligrams per liter cannot be exempted and used for injection, because they are considered to be USDW's suitable for possible future use as treatable water supplies. COGCC solicits written opinion from the CDWR regarding the occurrence of surface and subsurface fresh water sources in the vicinity of the injection well and the suitability of the injection well's proposed casing and cement configuration to protect those resources. Maximum surface injection pressure is calculated based on a default fracture pressure gradient of 0.6 psi per foot of depth. The operator may elect to conduct a Step Rate Injection Test to define whether a higher injection zone fracture gradient exists. From the resulting fracture gradient, the COGCC UIC engineer designates a maximum surface injection pressure at the operator's requested injection rate as a condition of permit approval. COGCC's policy is to keep injection pressures below the fracture gradient, which is defined uniquely for each injection well, minimizing the potential for seismic events related to fluid injection. Some injection wells do not need to inject under pressure because the formation will take water on a vacuum. Beginning in September of 2011, the COGCC UIC permit review process was expanded to include a review Page 2 COGCC Underground Infection Control and Seismicity in Colorado (cont.) for seismicity by the CGS. CGS uses their geologic maps, the USGS earthquake database, and area -specific knowledge to provide an opinion of seismic potential. If historical seismicity has been identified in the vicinity of a proposed Class II UIC well, COGCC requires an operator to define the seismicity potential and the proximity to faults through geologic and geophysical data prior to any permit approval. COGCC has had recent discussions with operators, EPA and the USGS regarding induced seismicity. The USGS earthquake specialists visited the COGCC and CGS in January 2012. Discussions related to providing technical expertise regarding seismicity and possible relationships to Class II UIC wells. COGCC believes safeguards are in place, in accordance with federal law and COGCC's rules and policies, but we will continue to review induced seismicity findings in other parts of the country with interest. The current safeguards defined by COGCC permit process are injection volume; pressure below the fracture gradient; and, input from the CDWR and CGS to reduce the potential for induced seismicity related to UIC Class 11 wells. COGCC strives to continually improve our evaluation methods, and the effectiveness of regulations, rules policies and procedures. References: 1. USGS Earthquake Hazards Program, Earthquake History of Colorado. http://earthquake.usgs.qov/earthquakes/states/colorado/historv.php 2. Division of Minerals and Geology Colorado Geological Survey, RockTalk, Volume 5 Number 2 April 2002. 3. Colorado Earthquake Mitigation Council, Colorado's Earthquake and Fault Map, 2008 4. Davis, S.D., and Frohlich, C., 1993, Did (or will) fluid injection cause earthquakes? - Criteria for a rational assessment, Seismological Research, Letters, v. 64, p. 207-224. 5. Nicholson, Wesson, 1990, Earthquake Hazard Associated with Deep Well Injection- A Report to the U.S. E.P.A., USGS Bulletin 1951, 74p. (Note: Also available as USGS Open File Report 87-331). default.htm 6. Osborne, Paul, editor, 2002, EPA Technical Program Review: Underground Injection Control Regulations, EPA 816-R-02-025. 7. Shirley, Kathy, 2001, Colorado Quakes Cause Concern, AAPG Explorer, http://www.aapq.orq/explorer/2001/12dec/colo quakes.cfm, last accessed 11/17/2005. Page 3 COGCC Underground Injection Control and Seismicity in Colorado What is a Class II Underground Injection Control (UIC) well? Class II UIC wells inject fluids associated with oil and natural gas production. Most of the injected fluid is salt water (brine), which is brought to the surface in the process of producing (extracting) oil and gas. In some oil fields, brine and other fluids are injected to enhance (improve) oil and gas production by using an enhanced recovery method known as "water flooding." There are approximately 885 active Class II UIC wells in Colorado, with 297 operating as exploration and production (E&P) waste disposal wells and 588 enhanced recovery wells. The waste disposal wells inject approximately 355,000 barrels of brine per day. What are the types of Class II UIC wells? There are three types of Class II injection wells associated with oil and natural gas production. 1. Enhanced Oil Recovery Wells (EOR) inject brine, water, steam, polymers, natural gas and/or carbon dioxide into oil-bearing formations to recover residual oil. This is also known as secondary or tertiary recovery. The injected fluid thins (decreases the viscosity) or displaces the residual oil and gas after primary production, which is then available for recovery. In a simple configuration, a single injection well is surrounded by multiple production wells. Production wells bring oil and gas to the surface; the UIC Program does not regulate production wells. Enhanced recovery wells are the most numerous type of Class II wells, representing as much as 60 percent of the Class II UIC wells in Colorado. There are currently 588 permitted EOR wells in Colorado. 2. Disposal Wells inject brines and other E&P waste fluids associated with the production of oil and natural gas operations. When oil and gas are produced, brine is also brought to the surface. The brine is segregated from the oil and gas by surface production facilities. It is then injected into the same deep underground formation or a similar formation specifically permitted for disposal. Class II disposal wells can only be used to dispose of fluids associated with oil and gas production. Disposal wells represent about 30 percent of Colorado's Class II UIC wells. There are 885 total UIC Class II wells with 297 operating as E&P waste disposal wells in Colorado. 3. Hydrocarbon Storage Wells inject liquid hydrocarbons in underground formations (such as salt caverns or abandoned hydrocarbon fields) where they are stored, generally, as part of the U.S. Strategic Petroleum Reserve. Is UIC Class II Exploration and Production Disposal the same as hydraulic fracturing? No. Injection well operations are not hydraulic fracturing. Hydraulic fracturing and underground injection are not related activities. Class II waste disposal is conducted below rock fracture gradient so as not to create new fractures. Class II waste disposal occurs over a long period of time, typically many years during the life of a UIC well. On the other hand, hydraulic fracturing is performed over a short period of time, typically hours, with "flowback" occurring over the course of several days or weeks. By definition, pressures used for hydraulic fracturing are above the fracture gradient, with the intent of inducing new fractures within a hydrocarbon extraction zone and does not include the permanent emplacement of fluids. What are the requirements for Class II wells? A state has the option of requesting primacy for Class II wells under section 1422 of the Safe Drinking Water Act: Section 1422 requires states to meet EPA's minimum requirements for UIC programs. Programs authorized under section 1422 must include construction, operating, monitoring and testing, reporting, and closure requirements for well owners or operators. Enhanced oil and gas recovery wells may either be issued permits or be authorized by rule. Disposal wells are issued Page 1 COGCC Underground Iniection Control — Frequently Asked Questions (cont.) permits. The owners or operators of the wells must meet all applicable requirements, including strict construction and conversion standards and regular testing and inspection. Are there other types of underground injection wells? Yes, there are six injection well types, which are designated based on the different types of waste injected into the wells. COGCC has primacy to administer EPA's requirements for Class II UIC wells. • Industrial & Municipal Waste Disposal Wells (Class I) — There are 13 Class I wells in Colorado. • Oil and Gas Related Wells (Class II) — There are 885 Class II wells in Colorado. • Solution Mining Wells (Class III) — There are 37 Class III wells in Colorado. • Shallow Hazardous and Radioactive Injection Wells (Class IV) — There are no permitted Class IV wells in Colorado. • Shallow Non -Hazardous Injection Wells (Class V) — There are 1759 Class V wells in Colorado. • Geologic Sequestration Wells (Class VI) — There are no Class VI wells in Colorado. Page 2 United States Department of the Interior GEOLOGICAL SURVEY Geologic Hazards Team MS 966, Box 25046 Denver, Colorado 80225-0046 30 June, 2014 Dear Kirby Wynn and Douglas Saxton, S 7.4 41 •Sc* %K' o*/X\* Q CAL/ This letter is in response to questions I received from both of you concerning USGS monitoring capabilities in Garfield County. There were several questions raised in our discussions. What are the current USGS earthquake monitoring procedures and capabilities in Garfield County? The USGS National Earthquake Information Center (NEIC) publishes earthquake locations and magnitudes for all detected earthquakes magnitude 2.5 or larger or reported felt within the U.S. In your region, NEIC's procedure is to rapidly release earthquakes that are reported felt and/or those with magnitude 4.0 or larger. It may take several weeks before the smaller earthquakes are processed and released on the website. What resources are required to improve the monitoring capabilities in this and other regions? Currently, the USGS NEIC receives data from 22 stations within 200 km of Rifle, CO. The vast majority of these are to the southwest in Paradox Valley. These stations are run by the Bureau of Reclamation to monitor their brine injection wells. With this station coverage, we estimate we can automatically detect earthquakes with magnitudes 2.5 and above. Accurate estimates of location uncertainty would require further study, but horizontal uncertainty is likely in the 10 to 15 km range with similar or greater uncertainty in our estimates of earthquake depth. To achieve location uncertainties in the 1 km range and to robustly detect quakes smaller than about 2.5, requires the installation of a local seismic array similar to that currently being run by Dr. Anne Sheehan near Greeley, CO. Additional resources would be required to build realtime capabilities and process earthquakes falling below the current USGS magnitude 2.5 threshold. What type of seismic activity should trigger an injection well be shut down? The USGS is not a regulatory body and has not authored a specific "stop light" system for shutting down waste water injection wells. To provide some background on the issue, I have emailed you a short article by Mark Zoback that represents his views not those of the USGS. Additional information can be found in a USGS authored here: http:l/www.sciencemag.orglcontent1341/6142/1225942.abstract . Other possible sources for advice include the Bureau of Reclamation since they have been seismically monitoring disposal wells in Paradox. Valley, Colorado for many years. Sincerely, Paul Earle USGS National Earthquake Information Center Telephone (303) 273-8417 pearle@usgs.gov Liquid carbon dioxide has been injected into the Sleipner gas- and oilfield in the North Sea for 15 years without triggering any seismicity. It serves as a good example of how fluid injec- tion can be done safely. Managing the Seismic Risk Posed by Wastewater Disposal Mark D. Zoback Froman earthquake perspective, 2011 was a remarkable year, While the devastation accompanying the magnitude -9.0 Tohoku earthquake that occurred off the coast of Japan on March 11 still captures attention worldwide, the relatively stable interior of the U.S. was struck by a somewhat surprising num- ber of small-to-moderate earthquakes that were widely felt. Most of these were natural events, the types of earthquakes that occur from time to time in all intraplate regions. For example, the magnitude 5.8 that occurred in central Virginia on Aug. 23 was felt throughout the northeast, damaged the Washington Monument, and caused the temporary shutdown of a nuclear power plant. This earthquake occurred in the Central Virginia Seismic Zone, an area known to produce relatively frequent small earthquakes. However, a number of the small-to-moderate earthquakes that occurred in the U.S. interior in 2011 appear to be associated with the disposal of wastewater, at least in part related to natural gas production. Several small earthquakes were apparently caused by injection of wastewater associated with shale gas production near Guy, Ark.; the largest earthquake was a magnitude -4.7 event on Feb. 27. In the Trinidad/Raton area near the border of Colorado and New Mexico, injection. of wastewater associated with coalbed methane production seems to be associated with a magni- tude -5.3 event that occurred on Aug, 22, and small earthquakes that appear to have been triggered by 38 • EARTH April 2012 www.earthrnagaaine.org Both: Statoil 49' 110' 105' 100' 95" 90' 80' 70' 65' • uy, ArIcansa Feb. 27, 2011 - M 4. �. • a as t. Worth, Texas May 16, 2009 - M 3.3 110` 105' 100' 95' 90' 85' __r 80' 75' ° r 70' Earthquakes above magnitude -3.0 have been recorded by the U.S. Geological Survey in the Central and Eastern United States and southeastern Canada since 1960. The dates and largest magnitudes associated with recent earthquakes apparently triggered by fluid injection are noted. wastewater injection occurred on Christmas Eve and New Year's Eve near Youngstown, Ohio, the largest of which was a magnitude 4.0. Although there has been speculation that the magnitude -5.6 earthquake that occurred in Oklahoma on Nov. 5 may have been triggered by similar fluid injection, no Linkage between this earthquake and fluid injection has been established. The occurrence of injection -related earthquakes is understandably of concern to the public, govern- ment regulators, policymakers and industry alike. Yet it is important to recognize that with proper planning, monitoring and response, the occurrence of small-to-moderate earthquakes associated with fluid injection can be reduced and the risks associ- ated with such events effectively managed. First, the Facts No earthquake triggered by fluid injection has ever caused serious injury or significant damage. Moreover, approximately 140,000 wastewater disposal wells have been operating safely and without incident in the U.S. for many decades. That said, we have known for more than 40 years that earthquakes can be triggered by www.earthmagazine.org 26' 65` No earthquake triggered by fluid injection has ever caused serious injury or significant damage. fluid injection. The first well -studied cases were earthquakes triggered by waste disposal at the Rocky Mountain arsenal near Denver, Colo., in the early 1960s, and by water injection at the Rangely oilfield in western Colorado in the late '60s and early '70s. Such quakes occur when increasing pore pres- sure at depth caused by fluid injection reduces the effective normal stress acting perpendicular to pre-existing faults. The effective normal stress on a fault can be thought of as a force that resists shear movement — much as how putting a weight on a box makes it more difficult to slide along the floor. Increasing pore pressure reduces the effec- tive normal stress, allowing elastic energy already stored in brittle rock formations to be released in earthquakes. These earthquakes would some- day have occurred anyway as a result of slowly accumulating forces in the earth resulting from natural geologic processes — injection just speeds up the process. EARTH April 2012 • 39 As there has been an appreciable increase in hydraulic fracturing associated with shale gas development in recent years, it should be pointed out that the water injection associated with hydraulic fracturing is not responsible for the triggered seismicity in question. As there has been an appreciable increase in hydraulic fracturing associated with shale gas development in recent years, it should be pointed out that the water injection associated with hydrau- lic fracturing is not responsible for the triggered seismicity in question. The reason for this is that pressurization during hydraulic fracturing affects only limited volumes of rock (typically several hundred meters in extent) and pressurization typically lasts only a few hours. Thus, while very small earthquakes have occurred during hydraulic fracturing (such as a magnitude -2.3 earthquake near Blackpool, England, in April 2011), these are extremely rare events. The concern about triggered seismicity associated with shale gas development arises after hydraulic fracturing, when wastewater that flows back out of the wells is disposed of at dedicated injection wells. Five straightforward steps can be taken to reduce the probability of triggering seismicity whenever we inject any fluid into the subsur- face. First, it is important to avoid injection into active faults and faults in brittle rock. Second, formations should be selected for injection (and injection rates should be limited) to minimize pore pressure changes. Third, local seismic monitor- ing arrays should be installed when there is a potentia] for injection to trigger seismicity. Fourth, protocols should be established in advance to define how operations will be modified if seis- micity is triggered. And fifth, operators need to be prepared to reduce injection rates or abandon wells if triggered seismicity poses any hazard. These five steps provide regulators and operating companies with a framework for reducing the risk associated with triggered earthquakes. Step 1: Avoid Injection into Active Faults Aside from plate boundaries where large earth- quakes occur with regularity, earthquakes also occur in brittle rocks nearly everywhere within continental interiors around the world as a result of natural geologic processes. ]t is thus no sur- prise that fluid injection occasionally triggers earthquakes. In fact, building dams for surface reservoirs occasionally triggers small- to moder- ate-sized earthquakes even though resultant pore pressure increases at depth are extremely small. 40 . EARTH April 2012 Shale gas and tight oil are produced in the Bak- ken Formation in North Dakota. Modern 3-D seismic imaging methods are suf- ficiently advanced that we can identify faults capable of producing potentially damaging earth- quakes at depth. Faults large enough to produce damaging earthquakes - say, those above mag- nitude 6.0 — should be easily detectable as part of geologic characterization studies of potential injection sites because they are associated with slip on faults that are many tens of kilometers in size. Smaller faults may be harder to detect, but will only produce small earthquakes that might be felt locally but will not cause damage. Modern 3-D seismic imaging methods are sufficiently advanced that we can identify faults capable of producing potentially damaging earthquakes at depth. We also know a lot about the relationship between the orientation of potentially active faults and the ambient stress field in a given region. This also enables us to identify (and avoid) potentially problematic faults prior to injection. Potentially active faults can be identified because the rela- tionship bet -ween the orientation of active faults and the regional stress field is well known from basic principles of structural geology and rock mechanics. In other words, only faults of cer- tain orientations are potentially activated during injection in a given area. The earthquakes appar- ently triggered by fluid injection at Guy, Ark., occurred on northeast trending, near -vertical faults, consistent with what would be expected from knowledge of the regional stress field and quite similar to the trend of active faults in the New Madrid Seismic Zone immediately to the east. Had these faults been identified during site characterization studies carried out as part of the permitting process, this site would not have been used for injection. www.earthrnagaz[ne.org 0 Wastewater from hydraulic fracturing is trucked away from drilling operations in Pennsylvania in the Marcellus Shale and moved elsewhere in the region where it will most likely be rein- jected and reused. Step 2: Minimize Pore Pressure Changes at Depth Rocks in the upper part of Earth's crust contain pre-existing pore space, fractures and flaws. These void spaces are normally filled with freshwater near Earth's surface (in the upper 1 kilometer or so) and filled with saline brines at greater depths. Injecting fluids into the subsurface will increase the pressure in these voids, depending on the rate it is injected and the volume of pore space available to accommodate the injected fluids. It should be pointed out that injection always occurs at depths where the injected fluids are isolated from near -surface water supplies. To minimize the potential for injection to trigger seismicity, it is obviously a good idea to minimize the pore pressure perturbations associated with injection. This can be accomplished in a variety of ways. The best way, of course, is to minimize the injected volume of fluid. Consider the case of the disposal of flowback waters following hydraulic fracturing associated with shale gas development in the Marcellus Formation of the northeastern U.S. Typically, 25 to 50 percent of the water used during hydraulic fracturing flows back and needs to be disposed of. However, because it has been difficult to find suitable injection sites in this Nearly all of the water used in hydraulic fractur- ing in the Marcellus Shale is reinjected during subsequent hydraulic fracturing operations. Meanwhile, itis stored in wastewaterimpound- ment ponds like this one in Pennsylvania. region (and quite expensive to haul water great distances to already operating injection wells), it is common practice to recycle flowback water by using it in subsequent hydraulic fracture operations rather than disposing of it in injection wells. in the Marcellus, nearly all of the water is recycled. That certainly minimizes the pore pres- sure perturbations. Another way to reduce the pressure buildup associated with injection is to utilize highly permeable regional saline aquifers to dispose of wastewater. These aquifers can accommo- date large volumes of injected fluids without experiencing significant pressure changes. The Ellenburger Formation in Texas is regionally extensive and highly permeable — one reason why many of the approximately 50,000 per- mitted wastewater disposal wells in the state have operated for so long, essentially without the occurrence of triggered seismicity. in cases where saline water is used for hydraulic frac- turing, it is possible to reinject the water that flows back after fracturing into the same forma- tions. When flowback water is injected into the www.earthmagazine.org EARTH April 2012 • 41 Operators and regulators should establish operational protocols — like perhaps a "traffic light" system — for wastewater injection sites located in areas where there is concern about the potential for triggered seismicity: Green means go, all systems working correctly; yel- low means proceed with caution, seismicity detected; red means stop, seismicity poten- tially presents a hazard. same saline aquifers from which the water used for hydraulic fracturing was produced, pressure in the aquifers decreases over time as more water is pro- duced for hydraulic fracturing than injected following flowback. Alternatively, weak, poorly cemented and highly permeable sandstone formations would also be ideal for injection. Such formations deform plastically and do not store elastic strain energy that can be released in potentially damaging earthquakes. No earthquakes have been triggered in the 15 years during which a million metric tons per year of carbon dioxide from the Sleipner gas - and oilfield in the North Sea has been injected into the Utsira sand, a highly porous, regionally extensive saline aquifer. In the same way that it's important to plan for the possibility of triggered seismicity in advance, we have to be prepared to reduce injection rates, or even abandon wells if triggered seismicity cannot be stopped by limiting injection rates. Obviously, cases will arise where well -cemented, Less permeable and more brittle formations must be used for injection. In those cases, care must be taken to avoid large pore pressure changes. This can be done through modeling prior to injection once the permeability and capacity of the injection intervals have been determined. Well-established procedures have been developed over many decades by petroleum engineers to do this. Step 3: Install Local Seismic Monitoring Arrays Potentially active faults that might cause large and damaging earthquakes should be identifiable during the site characterization phase of permit- ting potential injection wells. Because smaller faults cart escape detection, seismic monitoring 42 • EARTH April 2012 stop: seismicity potentially presents a hazard proceed with caution: seismicity detected go: all Systems working correctly arrays should be deployed in the vicinity of injec- tion wells when there is a cause for concern that injection might trigger seismicity. I he locations and magnitudes of naturally occurring earthquakes are routinely determined on a real-time basis in numerous seismically active regions around the world. The instrumenta- tion, data telemetry and analysis techniques used to accomplish this monitoring are well developed and easily implemented at relatively low cost. By supplementing regional networks with local seismic arrays near injection wells, accurate loca- tions of earthquakes that might be triggered by injection can be used to determine the locations and orientations of the causative faults. Although small faults cannot cause large earthquakes, even small earthquakes felt by the public will be a cause for concern and should be monitored. Step 4: Establish Modification Protocols in Advance Following precedents established to deal with earthquakes triggered during the development of enhanced geothermal systems, operators and regulators should jointly establish operational protocols for injection sites located in areas where there is concern about the potential for triggered seismicity. These protocols are sometimes referred to as "traffic light" systems. Green means go: Once operational protocols and local seismic networks are in place and injection begins at agreed-upon rates, operators would have a green light to continue unless earthquakes begin to occur that appear to be www.earthmagazine.org Brenna 5. Tobler/ A saline wastewater injection well owned by Northstar Disposal Services LLC in Youngstown, Ohio, Following several small earthquakes in the area in December 2011, the company halted injection of wastewater into the well, which stopped the earthquakes. The wastewater is from the production of oil and gas. related to injection. The occurrence of seismic- ity would be a cautionary yellow light. Once seismicity occurs, operators would slow injec- tion rates and study the relationship between the seismicity and injection. Should seismicity cease, operations could potentially continue at reduced injection rates. In fact, it was demon- strated 40 years ago at Rangely that earthquakes could be turned on and off by modulating the injection rate and resultant increase in pore pres- sure at depth. With such protocols in place, the potential occurrence and associated response to triggered seismicity are pre -defined and known to all parties. Step 5: Be Prepared to Alter Plans or Abandon Wells In the same way that it's important to plan for the possibility of triggered seismicity in advance, we have to be prepared to reduce injection rates,. or even abandon wells if triggered seismicity cannot be stopped by limiting injection rates. www,ea rth magazin e,org That would be the red traffic light: Seismicity has been detected that appears to be associated with a fault potentially capable of producing a moderate-sized earthquake. In the case of the Arkansas triggered earthquakes, as well as a series of quakes thought to have been caused by wastewater injection in the Barnett Shale in Texas near the Dallas -Fort Worth metro area in 2008, the seismicity abated once inject -ion in the problematic wells was terminated. Overall, it is important for the public to recog- nize that the risks posed by injection of wastewa- ter are extremely low. In addition, the risks can be minimized further through proper study and planning prior to injection, careful monitoring in areas where there is a possibility that seismicity might be triggered, and operators and regulators taking a proactive response if triggered seismicity were to occur. Zoback is a professor of geophysics at Stanford University. The views expressed are his own. EARTH April 2012 • 43 BATTLEMENT MESA Service Association June 25, 2014 Garfield County Board of County Commissioners 108 8th Street, Suite 213 Glenwood Springs, CO 81601 EXHIBIT Dear Commissioners, The Battlement Mesa Service Association, Board of Directors, wish to express their support for the addition of two conditions of approval for the Ursa injection well proposed for the Speakman Pad adjacent to the Battlement Mesa PUD. These conditions are: Require the operator to cease pumping at the injection well in the event of seismic activity, 2.0 or greater on the Richter Scale, within a ane mile radius of the injection well Require the operator to utilize a pipeline to transport the produced water to the injection well, within 60 days of county approval, so that additional truck traffic on and near Stone Quarry Road will not be necessary. Thank you for your consideration of these two conditions of approval. eith La /my, President Battlement Mes Service Association The Colorado Dream 401 Arroyo Drive • Battlement Mesa, Colorado 81635 PHONCC 970.285.9432 rnx: 970.285.963] rMA,L: BMSAQBBattlementMesaColorado.com WEB' www.BattlementMesaColorado.com GRAND VALLEY FIRE PROTECTION DISTRICT t�►� 0124 STONE QUARRY RD C� PARACHUTE, CO 81635 July 9,2014 PHONE: 285-9119, FAX (970) 285-9748 Glenn Hartmann Garfield County Building and Planning Dept. 108 8th Street, Suite 401 Glenwood Springs, CO 81601 970-945-8212 Re: Speakman Ursa A Injection Well. Mr. Hartmann; EXHIBIT j I have reviewed the Speakman Ursa Injection A Well application. The 12 percent grade is over the allowed IFC code requirement, however the Fire District is in the process of purchasing a remote area response Engine. This apparatus is designed to handle the steeper inclines of our remote areas. With the grade being over the 10 percent incline Speakman Ursa should now that this could delay our response time if there is an emergency on site. The other issue that hasn't been resolved in the past is the contact Name and number for the Fire District. The Fire District is very familiar with this site with it being close to GVFPD fire station #1 and easily accessed for personnel to review the site. It is noted that no flammable or explosive solids or gases will be stored on site as well. The Fire District doesn't have any objections to Ursa Operating Company, LLC to move forward with the project. Even with the Fire Districts review of the plans it is the responsibility of the owner to make sure the building complies with the International Fire Code 2009 Edition. If you should have any further questions please feel free to contact me. Sincerely, Rob Ferguson Deputy Fire Chief— Operations GVFPD Cc: Lorne Prescott Memorandum To: Board of County Commissioners From: Dave Devanney, BCC Co -Chair Doug Saxton, BCC Director Date: July 14, 2014 EXHIBIT 1 27 Subject: Call-up Request Regarding the Director's Decision — URSA Speakman A Injection Well (GAPA- 7835) I would like to offer the following comments regarding our concerns about induced seismicity. Recently, earthquakes have been linked to injection wells in five states. In Oklahoma a manyfold increase in earthquakes in the last five years has paralleled gas and oil development and the use of injection wells for waste disposal and could not have been predicted. No single factor can predict earthquakes. An earthquake in Greeley on June 7th was a wakeup call. It was the first seismic event there in 30 years. The COOGC was alarmed and responded to public concern by calling in an investigator from CU to look at the possibility the quake was caused by an injection well. The investigation is still ongoing. A 20 day shutdown was implemented and an earthquake of 3.4 magnitude was verified. A study was initiated by CU and data was said to be limited due to distant monitoring facilities. There was a second quake of 2.2 magnitude. Repairs have been undertaken and the well has still not resumed operations, and that resumption is still being negotiated. The investigation is still in its preliminary stages and portable monitors will remain in place in Greeley for ane year. Kirby's documentation from COGCC appears to show that their permitting process and regulation gives us a lot of protection, but the documents are dated 2011- well before recent events. Shut down procedures have existed at COGCC, but specific red light- green protocols for operation of wells after an incident are actively being considered by COGCC after the Greeley event. Reliance on the USGS monitoring system, as Ursa seems to intend, has the drawback that USGS's sole purpose is monitoring and recording. With the world wide monitoring responsibilities of the USGS, nothing under a 4.0 really gets their attention. The incomplete Greeley investigation has pointed out weaknesses in the monitoring network itself, operated by the USGS. The closest monitoring site was 75 miles distant from Greeley and researchers felt important data was not available. The nearest monitoring site to Battlement Mesa is in Paradox Valley. Certainly Ursa and everyone else will want to know if It's operations are responsible for an earthquake as soon as possible and nearer monitoring stations would do that. A study sponsored by the USGS and the National Science Foundation made public this month said, " Earthquake and subsurface pressure monitoring should be routinely conducted in regions of wastewater disposal.,." This should also include detailed monitoring of pumping volumes and pressures." If Ursa becomes the operator of a 7th active injection well within 10 miles of Battlement Mesa {with two more contemplated) the network needs to be supplemented by a local seismic array here. This type of monitoring is recommended in the article submitted by Kirby Wynn. The COGCC says they would lave that and we ask that the County support the acquisition of the equipment and it's monitoring in every way possible. If the ground shakes in Battlement Mesa, it is not clear from the permit who will do what and when. We hope that if an earthquake is either felt or detected here, Ursa will contact the COGCC and the county immediately and cease injection, pending an investigation. There are many response plans in the permit application, but earthquake response is not one of them. Thank you for your consideration in this matter. MEMORANDUM TO: Board of County Commissioner FROM: Dave Devanney, BCC co-chair Doug Saxton, BCC director DATE: July 14, 2014 SUBJECT: Ursa/Speakman A Injection Well (GAPA-2835) — Trucking & pipeline issues The Ursa application and subsequent materials indicate that a temporary surface pipeline for the transport of produced water to the injection well will be completed within a 12 month timeframe and a subsurface pipeline within three years. The staff report dated July 14, 2014 reconfirms the plan that "Ursa hopes to complete a pipeline delivery system within the next three years." Previously Ursa representatives had informed BCC members that the temporary pipeline work had already begun and that completion would occur shortly after permit approval. We are concerned that the legal requirements being considered are at great odds with the verb& assurances that were made. Our primary concern is the reduction of truck traffic as soon as possible. The benefits of this project are reduced truck traffic impacts as well as reduced transportation costs for Ursa and reduced opportunity for spills in the transport process. We therefore request that the county require Ursa to complete the temporary pipeline within 60 days of the permit approval date. This request is supported by the board of the Battlement Mesa Service Association — the governing body for Battlement Mesa residents. If the county cannot or will not impose such requirement, we request that Ursa voluntarily commit to such steps. Garfield County Board of County Commissioners July 14, 2014 Small Injection Well at approximately 5242 County Road 300. • Chuck Hall o I am from the Battlement Mesa community, an unincorporated 3,200 acre planned unit development, (PUD). o The Battlement Mesa Service Association, (BMSA), is Battlement Mesa's "city government." The BMSA, a Colorado non-profit corporation, is a self-governing homeowners association. The BMSA is the community's governing body. o BMSA is supported by several committees. I have included information about one of these committees: ■ I am Chairman of the Oil and Gas Committee. • The Committee's purpose is to monitor and report on energy issues affecting the Battlement Mesa Planned Unit Development (PUD) and / or energy issues outside the PUD if those issues could affect the health and welfare of Battlement Mesa residents. Additionally, provide a communication outlet between the energy industry, Energy Advisory Board, Local Government Designee and the BMSA, ▪ Primary Responsibilities; • Review and monitor oil, gas and other mineral extraction activities in the Battlement Mesa area and report to the BMSA Board of Directors. • When necessary, meet with energy companies to gather information about their activities and / or communicate concerns. ■ Make every attempt to achieve the desired outcome by negotiation rather than confrontation on issues involving energy companies. • From time to time, hold informational gatherings with the mineral extraction industry, BMSA Board of Directors and community members. o In regard to the URSA proposed injection well: • At the request of the Battlement Concerned Citizens (BCC) the BMSA Board of Directors has submitted a letter to the Garfield County Board of County Commissioners in support of the two conditions: • The first condition is to require the operator of the injection well to cease pumping if there is a 2.0 or higher seismic activity within 1 mile radius of the well. • The seconded condition is to require a pipeline be installed, within 60 days of the permit date, to carry the processing fluids instead of using trucks. ■ Since the Oil & Gas Committee reports to the BMSA Board of Directors we understand this position. Additional discussion may have been beneficial to understand information about the COGCC Injection well permit review process, geologic formations in the injection well area, and the ability of organizations to monitor earthquakes. This additional discussion may have modified the letter. URSA to date has been a responsive energy company since they became responsible for energy activities around, under from outside and in the future within the PUGS. They have kept the community informed through semi-annual meetings; meetings with committees; answering question and concerns; and preparing briefings and tours for community members to keep them informed about URSA activities and methods. ■ The Oil & Gas Committee of the BMSA feels that we can achieve our desired outcome with URSA by negotiation on all issues for Battlement Mesa Residents. ca <0G) 0 CD C13�E v as as 0..0) C� co July 14, 2014 jiimmiumt EXHIBIT 1 1 11:111 (21 c o t co 2 ▪ 2 All Iwo 0 ii -,�. 0, Q E o L a U) LL co Q3 _ E 2 co 0 o CU To co a) a) � E u) c Do CO 2c r 73M 06 07)c v au E .5 u co .� 0 c z w 10 o 1 � ©u c IX� o � sin12 co eL le0 0▪ o o • • • • C[3 ) CO -0 0W a) L 0 (13 (A U3 0 -'+ r ( • N J a a CO a o cv c —moo a. DVI (7)E p o ©� o ta) 5 -- C Q 03 . 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CO To 0 tC:$ CO c 0 0 toto 03 CR CO • • • 0 0 injection zone • • • CY y Z W F 1110 0 LI VD S) a 0 z eL ro Wasatch Fm LLIAMS_FORK [DC] ro 5- 0 W 2 2 r_i —© 00 r• cu 1 -ti 11 bO c > s. 16 c co 0 CO .� ._ '.1 Q W C Q tD F- .q- U .V}0 0 < ca Ts m a) o c� E u` w QQ NJ V) U D U v v v iv au u 4--+ U 0 G w 1- a 0 Uri o 0 z o° ro m 7 1 a c L Q1 U 40 a t10 ra U 0 ra 4) o c o (13 N c CCS i►= U C 1+ � > [[3 2 E o 0 7 ti,v a) CD- c o 0 2 v o COCO -CI CIO C I- V) 0 Ursa agrees to this Condition. CCS U {I] J fij 4- =16o N - CU CD a fel 1:73 —Q- c Q. o CCS CCS E 0, (6) ao- �' o > o Ct 0 CN Ou Condition 3 C6 U▪ f ] -3 cu * Q .o co cla v < 7, IF, =z co CL o = E co a cu E -0 C) U "` 0 s co � � ,s Q) C c .0 CD .0 ' C7 - cr) C cts 0 C7tt v cv TIS 4- — • .- c , a) '` "� X37 U 0 U a 4— u) Q co -z 0 co 03 L— r 0 Qs z ilCa (1) j .' -00) co zz Ou Condition 4 — c (1) C{3 .c U `(„)• 0 U a a Q Q a -.1=cts _c3a) E La N . (13c3) a L U LE 1 CD -45 co Go n ,C7 o cmoL CU J 73 0 E a) o � a� 00 00 C7) c Cn Cam— = a () -C —CS CL 0_CO 0_CU Ursa agrees to this Condition. Q} Z Q) •� E z 0 p t116 '4"4 .- U •� U Q) 0) o .a CO ct) z co c (13 N -0 _c tU rtco a) Imo O._ 0 (3} - 0) L CD .0 ..C. c §' 7-13— 2. 0 co 4- = —CO� 0 00 = .3 (0_ O) o . C 0 —I -1-, _C v S vi0 -0 0 U cll l- a. + 0 > -C Q " Ursa agrees t© this Condition. co N V)c tin r, 0 z ro c 1 �.�. ird C13 EC3 L_ o c W c Nei I 00 D� 06 0 c CO fin (1) CD C(7) 0 CU w E .� op1.4 o ° .0 o c� EL" 0 ›N CD `U adz O 4- CCS !1J C6 (43 Ursa agrees to this Condition. co te -+ a d a) E Co E Q3 Q) L 0_ 0 O 2 0 0 o .4=1 o La 0 a co a E .(13 rts C COnziCL CD< a in Z w 4 0 tan tn0 Ursa agrees to this Condition. PPP Z i° 6j' 1a V cco a) !E N 0 = a) - �v�,�a C fu) .` Z O CO U v 0 co = Qa3 C13 CCS OS o _ 0- E a) co•§ CD (..)WI— U c U= a) U c�o-.0 42..,) Si 0 •— t.i 4— 5 co C a'%sr _ .Q 03 15 0 Ci3 .> E .c 2 c _c ar) o V1 C U 4E1 To 0C C 2 co0 E co 2 ,. .0_ c p = cl co 0 CU CD CO i a) a '� 0 o a D C6 Q-0 0 0 U co Q) a) `7) i.fri_ —0 -c. !.1.= (t. ccii3 a3 2 C3 C � �C3 H 00 CU 72 co Q Ursa agrees to this Condition. Co c13 0 j G) 0_ a) C U c 0 CD L- u) Lt CU CD E 073a) To U] 0 C CDU Q Cll Q CZ C37 Ursa agrees to this Condition. U) N 0 0 747,0 v 0 0 0 ,�yy•0 < L .0 0 C U — � C o 0 -11-r 0 co co -,•-,• 1)-0 0i 0 � I . � 0 cia _l� a) C o 0 > D_ . 0� Q) 0 Q} 0 72 0 0 0 CO co .Q o - O) 0 U Q) It. 2 Q] ._ 0 >, co 0)— 0 07 t� I- = -IE. 0) _ 3 J, ' 0 0 Q) 02 U? U u) 0 ,� Q] Q) aa) 0 63) -' #= c c L 0`}' ._ 01 E • . Q) - Q) 2 w Ursa agrees cn N Z d 0 Viinw 0 t } F - 0u ro _ 4--▪ 1 cu c o c0 ccs oc4=} -0 a) coc c c CO {ll ■_ C V C i c 0 CD 'Fs f .o U) 0—, C 7 N -0 cp v • C 0 •E N {U {U 14= C7 cu W m Q3 N o.0 a Ursa agrees to this Condition. o E co E coco O co 013 "i -.r CO CD (la viz • Q) C co 03 o 0 U a)0) cD LILI p .+...; � la) Q Q) st CO C.1 h N UJ d V)0 4 0 f Ou ra 0 C 2 c c �' _ a) 0 a) C C3 S C7 Q ori E E 45 L c1 Q § (13 .E = ' V) CL 0_ O U cm s1 �) 0< ° C73 Ntp t13}3 co = 03 >:; aC3 a) t3 ,— 2 c E .c4 (DOMCco-ci tO CT _� C)-0 10 W 76 2 '7280 0 MATO C CU :5 •c CL 0 E — g c.. g k "a •§ -% 0 >, 4 ° () = E (1) a) ' 0 ..0 co X33S „, C *la CI):5 2 g W a-5) CQ Tai cb co 2 a=.,- E .a s X) a tZ a) Q3 0 co cu S [+ S co w L S © CD C)-� � I � ui 0 CO ° co 2 _c (,) C` - cD S tUC7 Ursa agrees to this Condition. CX) C 0 z Ou 191 a) 2 E CO • >0 C „O Cl. -ow g co co 03 a, c s.7 WI 0 (13 �� 3 {,U c (/) O C13a--' 7, wO CL3 0 00 CU .� © O p - O ■� CN T - CD Ld1 CU E -� CO 0 - cr E cr) E 8 o- O� � � O �' ca O 3."- O W co 0 c cn O cu 0 O Co 0 .L-) __E >lw bi L rn 1 .C.7 CU i ( O -O cD O _CL C CU _ F COO Cid Ursa agrees to this Condition. -z Ou ra