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HomeMy WebLinkAbout13.0 Correspondence & ConditionsO'\OLSSON ® ASSOCIATES July 2, 2014 Tamra Allen Garfield County Community Development 108 8"' Street, Suite 401 Glenwood Springs, Colorado 81601 Re: Ursa Operating Company LLC Speakman A Small Injection Well (File GAPA-7835) Dear Ms. Allen, EXHIBIT 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 governing 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.corn 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 Matrix DESIGN GROUP 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 Deme, Colorado Sp„ngs Phoenix Anniston Atlanto N,cev,lle Parsons Pueblo Sauamento Wa<_h,nywon, D.0 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 Targe 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 G - •* Shaner, PE Attached: Exhibit 1 —Historic map, Exhibit 2 —Existing map, Hydrology Sheets matnxdesigngroup CO? • 7 • , , r".1i 9 8 Y IY A i 1 .8i =�a j 8 } d 1 1 1 1 1 1 3 1 1 jib \ \ \ \ // x / r / i 1 11,4 / / rr r�; • 1, n5 s n z .s m 1 / j 1 / / � / tl$- ♦ y. / / ' • v f ///r/ % s>'' r / 1 i 1% 7 ---z-.:-.. /i '-••••,/ 11111) / e/ / / IIK \"j\ , 1\l' i \ \ 1\\ \\ \ ,l 1 if i I I 11 / i I I 1 , Jr y# /�,I: ,, /. ;"'--;' / j '\/\ \• • �a \\,\ 1/ /; < `„ f Bio, / ' \ IWI11• _f- Al / Y(,� •-, ,( a r r ,/ I ��� rrC���.y� 1� .`"`� �, \ ` `'\ ••••••::...'......% 2-'''...---__. '"•••-....... -�*` .\ ,�. ,1 f •,r / • \ \ I / ;i -j X `• „, / 21; 1 1 jR11• Fkd Sts a F.- 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)^C3 Design Storm Retum 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 preapitation—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 LEGFND 0 Beginning Fbw Direction Catchment Boundary NRCS Land Type Heavy Meadow Tillage/ Field Short Pasture/ Lawns Nearly Bare Ground Grassed Swales/ Waterways Paved Areas & Shallow Paved Swales (Sheet Flow) Conveyance 2.5 5 7 u 10 L 15 20 Calculations: I Overland Slope s Mt input 0.0600 1 0.1500 2 3 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 0.16 N/A 0.31 16.22 789 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 2.42 2.42 8.00 3.10 4.24 8.00 8.00 Computed Tc = Regional Tc = User -Entered Tc = inch/hr Peak Flowrate, Qp = inch/hr Peak Flowrate, Qp = inch/hr 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 25 28.50 10.00 0.786 1.10 0.18 0.39 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 = Area = Percent Imperviousness = NRCS Soil Type = EX1 6.40 5.00 C Acres oda A, B, C, or D II. Rainfall Information I (inch/hr) = C1 * P1 /(C2 + Td)AC3 Design Storm Return Period, Tr = C1 = C2= C3= P1= years (input return period for design storm) (input the value of C1) (input the value of C2) (input the value of C3) 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 = (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 NRCS Land Type Heavy Meadow Tillage/ Field Short Pasture/ Lawns Nearly Bare Ground Grassed Swales/ Waterways Paved Areas & Shallow Paved Swales (Sheet Flow) Conveyance f 1 2.5 5 1 7 10 I1 15 20 Calculations: Reach ID Overland Slope S ft/ft 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 IV. Peak Runoff Prediction Rainfall Intensity at Computed Tc, I = Rainfall Intensity at Regional Tc, I = Rainfall Intensity at User -Defined Tc, 1= 2.05 2.41 2.41 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 = inch/hr Peak Flowrate, Qp = inch/hr Peak Flowrate, Qp = inch/hr Peak Flowrate, Qp = 22.20 16.17 16.17 5.15 6.06 6.06 cfs cfs cfs Speakman Existing, Tc and PeakQ 6/19/2014, 1:46 PM 0.16 0.38 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 /(C2 + Td)^C3 Design Storm Retum 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 = (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 LEGEND 0 Hwa Flew Direction Catchment Beeniary NRCS Land Type Heavy Meadow Tillage/ Field Short Pasture/ Lawns Nearly Bare Ground Grassed Swales/ Waterways Paved Areas & Shallow Paved Swales (Sheet Flow) Conveyance 0 2.5 A 5 1 7 10 u 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 0.0730 273 0.16 1 2 3 0.0250 154 0.3500 142 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, I = 2.35 2.65 2.65 N/A 8.00 9.00 0.31 14.50 1.26 2.03 5.32 0.44 Computed Tc = Regional Tc = User -Entered Tc = inch/hr Peak Flowrate, Qp = inch/hr Peak Flowrate, Qp = inch/hr Peak Flowrate, Qp = 16.98 13.16 13.16 1.54 1.74 1.74 cfs cfs cfs Speakman Existing, Tc and Peak() 6/19/2014, 2:05 PM 0.18 0.39 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 = Area = Percent Imperviousness = NRCS Soil Type = EX 8.13 4.40 C Acres A, B, C, or D II. Rainfall Information I (inch/hr) = C1 * P1 /(C2 + Td)AC3 Design Storm Retum 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 = (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 NRCS Land Type Heavy Meadow Tillage/ Field - Short Pasture/ Lawns Nearly Bare Ground - Grassed Swales/ Waterways Payed A eas & Shallow Paved Swales (Sheet Flow) Conveyance H 2.5 Q 5 I 7 b 10 15 0 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 16.33 1 2 3 4 0.0850 145 0.0640 462 0.1500 204 5 Sum 1,111 IV. Peak Runoff Prediction Rainfall Intensity at Computed Tc, I = Rainfall Intensity at Regional Tc, I = Rainfall Intensity at User -Defined Tc, I = 2.04 2.41 2.41 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 = inch/hr Peak Flowrate, Qp = inch/hr Peak Flowrate, Qp = inch/hr Peak Flowrate, Qp = -7176- 16.17 16.17 6.48 7:64 7.64 cfs cfs cfs Speakman Existing, Tc and PeakQ 6/20/2014, 12:09 PM O*\OLSSON ASSOCIATES Articie r — 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. 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 lots 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 OI0t0 * elle R nriF frgde rrPrd .11111 r1 \ 1; f 17. r_ $RS�_ - "[IP I � JR ��';R � g� � � lirul F$'Ii `�a 1 Iff°i" 7 IR �i� 1 rill' � i;i4v 2 � � � ��F i F E _ 411 a R F°ggrR 'Rs F R' 0 z_ Ir rr r. EY 10 01 II II wIrmw 110 n • Fugitive Dust Control Plan Garfield County, Colorado July 2014 Ursa Operating Company Colorado, USA Scope: The scope of these guidelines is to outline some basic principles to minimize and control fugitive dust emissions during land development. Requirements: 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: • INTRODUCTION 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. 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: W'Ursa Prepared by: S'AFETY 2381 Patterson Road Grand Junction, CO 81505 June 10, 2014 RESOURCES GROUP 11 Ursa Resources Group, 11 PAGE 2 of 35 RESOua iiURCES � c�o 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 II, 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 RESOURCES c�ouP ii EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION TABLE OF CONTENTS Revision 00 10 -JUN -14 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 G?Ursa 1 GROUP II ES EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 8.2.3.2 Evacuation Routes 15 8.2.3.3 Personnel Accountability 15 8.2.4 Fire 16 8.2.5 Flood 17 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 11 POST -EMERGENCY RESPONSE INCIDENT INVESTIGATION 34 Ursa Resources Group, 11 PAG E 4 of 35 RESOURCES GROUP II 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 ii?Ursal GR RCES EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 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 11 ("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. Ursa Resources Group, 11 PAGE 6 of 35 G?Ursa:n: ^-2. EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 2.2 Site Manager/Supervisor or Lead Operator 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 b211115a RESOURCES IGROUPII EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 ▪ 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. 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 ii21.1rsa GRGRCOUP CFS 'JP !I EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 3.1 Garfield County Emergency 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 c 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 CareFliciht 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, 11 PAGE 9 of 35 ii? Ursa I REROU?SOURilCES G EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 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, 11 PAGE 10 of 35 EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION .'Ursa k �c. 5 RGU?uR� Revision 00 10 -JUN -14 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 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 Emergencies 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 1?Ursaup;=s EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 • Warn 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 Warning Signals and Actions ACTION WARNING SIGNAL ATTENTION (Emergency Event) 1. Continuously blast horn for 5 seconds. Repeat three times with a 5 -second pause in between. 2. Supervisor must then radio employees to communicate further instructions to all personnel. EVACUATION 1. Make five 10 -second blasts with horn, with 5 -second pauses in between each blast. Repeat two times. 2. Immediately evacuate to the designated assembly area for personnel accountability. SHELTER IN PLACE 1. Continuously blast horn for thirty seconds. Repeat one time if necessary with a 5 -second pause in between. 2. 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, II PAGE 12 of 35 OP Ursa RESOUR0UP IICES .�(2 EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION • 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 Emergencies 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 ▪ TransportationNehicle Incidents • Special Actions at the Pond Site • Shelter in Place Revision 00 10 -JUN -14 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, 11 PAGE 13 of 35 LIrsa I REGROUP II OUP 1?" iii EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 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 Ursa Resources Group, II PAGE 14 of 35 itIfilai RESOURCES =JP I! EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -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, II PAGE 15 of 35 bursa EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 8.2.4 F_jjg 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. safety► pin indicator handle/ trigger hose and/ or nozzle tank label nspecti on tug 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, 11 PAGE 16 of 35 ' GRCU RII ES EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 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 Earthauake 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 Revision 00 10 -JUN -14 UrsRESOURCES GROUP II EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION 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 less 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. Ursa Resources Group, 11 PAGE 18 of 35 bursa RESOURCES 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 Soilis 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 ge' Ursa;-,7-.)-,RE-1'c EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 8.2.10.2 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 result. 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 aerursa;EoLRIEs EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 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 Transportation 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 ta›Ursa _: 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 Response 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 rad los, first aid supplies, etc. Ursa Resources Group, 11 PAGE 22 of 35 UrsaGROU 1 GROUP I1I 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. ▪ Call 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 RCES rsa i cRoRESOUuP ii EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 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, 11 PAGE 24 of 35 &?Ursa I RGROUP ICES EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION Revision 00 10 -JUN -14 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 Potential 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 0°Ursa RESOURCESa R� 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 Management 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 .a RESOURCES I GROUP II 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 Eauioment 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 EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION tUrsa I f SOIPRCES Revision 00 10 -JUN -14 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 Emeraencv 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 'UrsaRESOUP IIRCES GROU 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, II PAGE 29 of 35 142`Ursal RESOURCES 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 fa? LJrsa Prsc.,R : s • 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 Tips 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 310135 LI?Ursa RESOURCES c� • • • • • • 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 gvent 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 Reporting Reauirements 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: Ursa Resources Group, 11 PAGE 32 of 35 1712° 1Ursa lcRouRESOUpRICES EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION • National Response Center • EPA Region 8 — Mountain States Revision 00 10 -JUN -14 (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 'LJrsaI REScROUP .I7URCES G EMERGENCY ACTION PLAN AND WIDLFIRE MITIGATION 11 POST -EMERGENCY RESPONSE INCIDENT INVESTIGATION Revision 00 10 -JUN -14 Post-Emeruencv 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 bursa CROJP Attachment A AGENCY EMERGENCY CONTACT LIST Revision 00 10 -JUN -14 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, II PAGE 35 of 35 Glenn Hartmann From: Steve Anthony Sent: Monday, August 04, 2014 2:52 PM To: Glenn Hartmann Subject: FW: Website inquiry -Vegetation Management Original Message From: Speakman, Eugene [mailto:espeakmanOtristateRt.org] Sent: Friday, June 20, 2014 1:08 PM To: Steve Anthony Cc: 'Monique' Subject: RE: Website inquiry -Vegetation Management Steve, I was also going to put LadaK Alfalfa in with the oats. The oats will be used for a cover crop. With the weeds there now there is a fire hazard also. I guess this time of year it's all around us. At least I can manage this one by getting rid of the weeds. You never know when someone may flick out a cigarette butt. Thanks, James Original Message From: Steve Anthony [mailto: santhonyOgarfield-county.com] Sent: Friday, June 20, 2014 12:35 PM To: Speakman, Eugene Subject: RE: Website inquiry -Vegetation Management Hi James, Here is my email Thanks Steve Original Message From: James E Speakman [mailto:espeakmanPtristategt.org] Sent: Thursday, June 19, 2014 1:52 PM To: Steve Anthony Subject: Website inquiry -Vegetation Management James E Speakman has sent you a message: seed area in Battlement Mesa 970-208-4338 Hi Steve, My name is James Speakman and i have property in Battlement Mesa. I talked to Gale last year about seeding a area just West of the URSA Speakman pad A. My plans were to seed in the spring and irrigate that area this summer. My ditch from Dry Creek is called the #1 ditch and the hill slid last year and took about 200' of the ditch out. The hill dropped about 15' in some areas. I had Tamerrel Excavation push the dirt back up and fix the ditch. They finished around the middle of May and i called Ben Crouse the water manager in this area, and told him 1 that i put about lcfs of water in the ditch and wanted to see if it would hold. The ditch wouldn't hold no more water because of a high spot in the ditch. For this reason i wasn't able to put no more than the lcfs of water in the ditch and I couldn't water my lower field or the place i talked to Gale about. As for an action plan i could remove the weeds Fire Hazard) that are there now and re-disk and plant the seed that i have since the spring. We may get enough water in July to bring the oats and grass up. Please let me know if this would work for you. Thanks, James E Speakman 2 Glenn Hartmann From: Steve Anthony Sent: Friday, August 01, 2014 10:28 AM To: Glenn Hartmann Subject: FW: Morning Glenn Here is my earlier email to you. I'm trying to remember our conversation yesterday, was a condition that Mr. Speakman contact me for a fall site visit? Is there anything further I need to do at the moment? thanks Original Message From: Steve Anthony Sent: Monday, July 7, 2014 12:09 PM To: Glenn Hartmann Subject: Hi Glenn, Got your message, I'm gone till next week. On Speakman, I was ok with his revised seed mix to include alfalfa with the oats, and that's about the extent of my involvement, he had some weeds, but they were not noxious weeds. Gale brought some in one day -they were tumble mustards. You mentioned a drainage issue, I don't no anything about the drainage out there. Let me know if you need anything else. Steve Sent from my iPhone 1 Glenn Hartmann From: Chris Hale [chris@mountaincross-eng.com] Sent: Tuesday, July 29, 2014 11:47 AM To: Glenn Hartmann Subject: RE: Ursa Speakman A Injection Well (GAPA-7835) COA Response Glenn: I read the additional information and they have addressed my comments from my letter dated May 28, 2014. Thank you. Sincerely, Mountain Cross Engineering, Inc. Chris Hale, P.E. 826 1/2 Grand Avenue Glenwood Springs, CO 81601 Ph: 970.945.5544 Fx: 970.945.5558 From: Glenn Hartmann [mailto:ghartmann@garfield-county.com] Sent: Monday, July 28, 2014 12:57 PM To: Chris Hale Subject: FW: Ursa Speakman A Injection Well (GAPA-7835) COA Response Hi Chris: Attached are responses from the Applicant to our referral comments including your review of drainage issues on the Ursa project. The technical response is the first attachment from the Matrix Design Group. I can get you a hard copy if that is helpful. Addressing your comments was a condition of approval. Thanks for your review and comments. Hopefully they have adequately addressed the issues. Sincerely, Glenn Hartmann Community Development Department 1 Glenn Hartmann From: Kirby Wynn Sent: Wednesday, July 02, 2014 3:55 PM To: Douglas Saxton; Chuck Hall Cc: Kirby Wynn; Glenn Hartmann Subject: RE: injection wells neighboring Battlement Mesa Attachments: InjectionWell-Battlement-GIS-Attribute-Data.xls; InjectionWell-Battlement-GIS-Attribute- Data2.pdf; InjectionWells, Near Battlement.pdf Hi Doug and Chuck, I have attached what I have regarding injection wells near Battlement Mesa. Beyond this information, Bob Koehler with COGCC is 'the' guy for COGCC underground injection control (UIC) wells and he would be the one to request the additional details from that I do not have in hand, such as operating conditions and allowable injection volumes for the existing wells, including whether they are currently active or not. Doug, I believe you have visited with him previously. His phone number is: (303) 894-2100 ext. 5147. Have attached a map that lists the operator name and the unique API Well Identification number for nearby existing injection wells. Map also shows the proposed Speakman A injection well. Have also attached a table (in PDF and Excel formats ) that contains all of the data elements that COGCC had available in the GIS well file from which I mapped these IUC wells. COGCC provides definition of some of the codes used in their GIS data table http://cogcc.state.co.us/COGIS Help/GIS HELP/GISOnline Layers Internet.pdf For example a review of that document will indicate that Well Status of 'IJ' means 'Injecting'. How that relates to actual current activity associated with such a well is a question for COGCC given they monitor and regulate the down hole activity for such things. Regards, --Kirby Kirby Wynn Oil and Gas Liaison Community Development o (970) 625-5905 c (970) 987-2557 kwynn@garfield-county.com Original Message From: Douglas Saxton[mailto:douglassaxton@gmail.com] Sent: Saturday, June 28, 2014 8:42 PM To: Kirby Wynn Subject: RE: injection wells neighboring Battlement Mesa Kirby, I have the map that was given to Dave at the Commissioners meeting, but it has only dots on the map locating nearby sites, the Speakman pad, and a scale of miles. Doug u) N u, 2 CO N 1 1 1 1 Requests re Ursa's Upcoming Comprehensive Drilling Plan Garfield County Commissioners Meeting Parachute, Co June 9, 2014 My name is Doug Saxton and I am representing the Battlement Concerned Citizens (BCC). Thank you for having your meeting here today. Given that Ursa has told us that they intend to soon submit a Comprehensive Drilling Plan (CDP) for Battlement Mesa to the county which anticipates special use permit applications, I have four requests to make of you this morning. I would like to state the requests, elaborating on some, summarize them and then answer questions you may have. 1. Because Ursa has told the BCC that they may submit the CDP in phases, will you please ask the Community Development staff to insist that Ursa submit a single Comprehensive Plan that includes all the development that they anticipate. One purpose of a Comprehensive Plan, besides streamlining of permitting, is to eliminate surprises down the road which could put community members at a disadvantage. The effects of development inside Battlement Mesa will be cumulative as well as immediate in a populated area and should be judged as such. For example, drilling at multiple well pads successively without interruption and/or simultaneous use of multiple rigs could result in a greater rate of emissions in a concentrated period than current regulations would allow over the course of a year, as well as more unabated traffic and noise over a prolonged period of time than might otherwise be anticipated. Ursa traffic on North Battlement Parkway, for instance will be added to the substantial truck traffic occurring now on a daily basis. The intersection of North and West Battlement is already the busiest intersection in the community. Impacts of drilling are more intensely felt when concentrated in a short time span and in combination with other drilling nearby. 2. Will you please direct the staff to be mindful of the recommendations of the HIA study which you commissioned when you consider that Comprehensive Drilling Plan. The study, for example recommends that a water pipeline and a water storage facility be constructed prior to any drilling in the PUD. It recommends that all chemicals stored on the well pads be listed for the benefit of local emergency personnel and posted on the County website. The study recommends that odor complaints should be investigated until the source is found or the situation resolved. In addition, it recommends use of the electrical power grid be used if at all possible, and that contractors' trucks and heavy trucks meet emissions standards. Further, strict enforcement with penalties to contractors for speeding and improper braking are called for. These recommendations all speak to protections the residents need and expect. 3. Another recommendation of the study was that county inspections be conducted in order to insure compliance with Conditions of Approval for the Plan and Special Use Permits including air S quality monitoring at timely intervals and investigation of noise and odor complaints. Because violations will have immediate impacts given the population density in Battlement Mesa, will you ask the staff to consider all options available to provide for local inspectors who could more frequently monitor compliance with the Conditions of Approval? 4. Lastly, we ask if the county will give special consideration to proximity of operations to recreational areas and schools in Battlement Mesa.. In summary, we are requesting a truly comprehensive Comprehensive Plan, thoughtful consideration of HIA recommendations, provision for county inspections, and special consideration for the proximity of recreational areas and schools. Thank you for the opportunity to speak with you today. 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 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 1 Garfield County, CO 1 Map Print Page 1 of 1 �Y. Owner Information '• 4EVENSON, GARRY W. & BETTIE.I. f 122 MINERAL SPRINGS CIRCLE PARACHUTE, CO 81635 •Parcel Number: 240924101003 ite Information Acres: 0 `Account Number: R800259 1 f,tK'�.Al';►�et jtil�,er�7f'�•S . t F i ,r:.!2��►i1!llf ,�1i� , ,2407_102_08_0c0 rr tict'PF110 t1oo!''>11e7p i -t� fr . tt 7v X41 �t111 ii 11141141110,01$c7i ;it..a�'.t.f 9999999.9999 . '4) ." I ,, •_rel Garfield County, CO Date Pnnted: 06/09/2014 10,5 map *for alustrdhve purposes only 300 does not represent a Survey. 1t is ptowded'as Is' vnthou1 warranty or any representat.on or accuracy, tmtelmess or Comp ensu. The user acknowledges and accepts all Inherent Imitations of the maps and data, indudmg the rad Mat the maps and data are dynamic and In a constant state or maintenance. cotrealon and re34on. No Ilapll0y .s assumed by Garfield County as to the accuracy W the data d04 0001ld hereon. http://gis.garfield-county.com/sidwell/print/?extent=236425.489131994,4367412.57349356,... 6/9/2014 41::- Garfield County Vegetation Management August 4, 2014 Glenn Hartmann Garfield County Community Development Department RE: Speakman - GAPA 7835 -Follow-up Dear Glenn, Mr. Speakman has informed me that he plans to reseed this summer with Ladak Alfalfa and also with oats. This may have occurred already, and it is acceptable. I would like to do a follow-up site visit this fall, in late September or early October. Please let me know if you have any questions. Steve Anthony Garfield County Vegetation Manager 0375 County Road 352, Bldg 2060 Rifle, CO 81650 Phone: 970-945-1377 x 4305 Fax: 970-625-5939 June 5, 2014 James and Monique Speakman 5242 County Road 300 Parachute, CO. 81635 Case # 9-13-1153 Garfield County Community Development 108 8th Street, Suite 401, Glenwood Springs, CO 81601 Office: 970-945-8212 Fax: 970-384-3470 Sent Certified Return Receipt and U.S. First Class Mail NOTICE OF VIOLATION -BUILDING CODE Dear Mr. and Mrs. Speakman The Garfield County Community Development Department Code Enforcement Officer has reason to believe a violation may exist on your property located at 5242 CR 300 (parcel #2409- 244-00-124). On September 20, 2013, the Code Enforcement Officer observed grading activities on the property that would require a Grading Permit. A Notice of Violation was sent to you on October 1, 2013 informing you of a possible violation. A week later you meet with me on site to describe your plans install irrigation and to recover the area to plant agricultural crops the following spring. Grading for agricultural purposes (crops, grazing pastures, etc.) are exempt from grading permit regulations. Based on that information no code enforcement action took place. On May 21, 2014, I drove by the site to confirm that the site was being replanted for agricultural purposes. The site shows no sign of improvements and appears to be covered in noxious weeds. There has been no attempt to install irrigation or control erosion and runoff from the site since my site inspection last October. The Garfield County Land Use and Development Code (LUDC) adopted in 2013 does not allow this activity without a grading permit. Any grading or fill activity that exceeds 6,000 square feet or 50 cubic yards requires a grading permit. Development activity over one acre in size also requires a state stormwater permit. Based on my observations the activity on your property appears to be in violation of the county's Land Use Development Code. To remedy this situation you must obtain a grading permit to restore and revegetate the site. A revegetation plan must be approved by the County Vegetation Manager. You are hereby given notice, pursuant to Article XII of the Garfield County LUDC, that you must completely correct the violations or cease and desist from continuing the violations within ten (10) days of the date you receive this notice. Under Article XII of the Garfield County LUDC, your failure to correct or cease the violations on your property may result in one or more of the following enforcement actions being taken against you: 1. Revocation of any building permits issued for improvements of the subject property; 2. Denial of additional land use approvals or building or other development applications pertaining to the subject property; 3. Suspension of any land use approvals for the subject property; 4. Withdrawal of any development permits that are being violated; 5. Forfeiture of any vested property rights; 6. Criminal enforcement; 7. County court civil penalties; and 8. Civil lawsuit. You have the right to appeal this Notice of Violation, pursuant to the provisions of the Garfield County LUDC. Pursuant to Garfield County's LUDC, Article XII, the county may pursue any of the available enforcement procedures and penalties in connection with this violation. Garfield County Building and Zoning regulations, Enforcement Protocol and permit application forms are available at www.garfield-county.conl in the "Community Development "directory. If you have any questions regarding what actions are required to achieve compliance, or you wish to report compliance action taken, please contact this office in writing at the address below or by E-mail gcarmoncv(a)garlicld-county_com Respectfully, Gale D. armon Code Enforce ' Officer Community De lopment Garfield County Administration Building 108 Eighth Street, Suite 401 Glenwood Springs, CO 81601 cc: Andy Schwaller, Chief Building Official (via email) Steve Anthony, Vegetation Manager (via email) file T:\Code Enforcement\NOV Letters-Cases\2014\Speakman 5242 CR 300\NOV 6-5-14.Docx June 5, 2014 James and Monique Speakman 5242 County Road 300 Parachute, CO. 81635 Case # 9-13-1153 Garfield u1 c0 N U.S. Postal Service v., CERTIFIED MAILT�.� RECEIPT (Domestic Mall Only; No Insurance Coverage Provided) For delivery Information visit our webaite at www.uspa.com® PARACHUTE CO B1635 ..A postage ru Certified Fee Com ru 108 8th Street, Suite 401, I 0 Return Receipt Fee (Endorsement Required) Office: 970-9 Restricted DeliveryFee 0 (Endorsement Required) 0 j3 Total Postage & Fees 0 Sent Certified Return Receipt and U.S. First Class Mail m a 0 r`- 06/ • b -Sp o 8160 Foslmark "'� Here" PS 50C11, -To �1.cw..n5.�. !:. ma... oorP, Apt. N. 5(22 Ll r POOBox No. C1 stte, Zl ?c G0 PS Form 3800; August 2006 NOTICE OF VIOLATION -BUILDING CODE Dear Mr. and Mrs. Speakman The Garfield County Community Development Department Code Enforcement Officer has reason to believe a violation may exist on your property located at 5242 CR 300 (parcel #2409- 244-00-124). On September 20, 2013, the Code Enforcement Officer observed grading activities on the property that would require a Grading Permit. A Notice of Violation was sent to you on October 1, 2013 informing you of a possible violation. A week later you meet with me on site to describe your plans install irrigation and to recover the area to plant agricultural crops the following spring. Grading for agricultural purposes (crops, grazing pastures, etc.) are exempt from grading permit regulations. Based on that information no code enforcement action took place. On May 21, 2014, I drove by the site to confirm that the site was being replanted for agricultural purposes. The site shows no sign of improvements and appears to be covered in noxious weeds. There has been no attempt to install irrigation or control erosion and runoff from the site since my site inspection last October. The Garfield County Land Use, ----' this activity without a grading or 50 cubic yards requires a requires a state stormwater pe appears to be in violation of the SENDER: COMPLETE THIS SECTION To remedy this situation you n revegetation plan must be appro You are hereby given notice, r must completely correct the via ten (10) days of the date you rec • 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 retum the card to you. • Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: 09lrtt,. i- 0101 5aq.2 CR 300 CO. 0/('35 inityk See Reverse for Instructions COMPLETE THIS SECTION ON DELIVERY A. SI X • �j-1(41(. ❑ Agent ❑ Addressee Received by (Printed Name) C. Date of Delivery D. Is delivery address different from Item 1? 0 Yes If YES, enter delivery address below: 0 No 3. Service type ❑ Certified Mall ❑ Registered ❑ Insured Mail ❑ Express Mall ❑ Return Receipt for Merchandise ❑ C.O.D. 4. Restricted Delivery? (Extra Fee) ❑ Yes 2. Article 7013 0600 0002 2695 7895 (Transfer PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 WATER INJECTION WELL LEASE AND SURFACE USE AGREEMENT THIS WATER INJECTION WELL LEASE AND SURFACE USE AGREEMENT ("Agreement") is made and entered into this 23rd day of April, 2014 by and between James Eugene Speakman, whose address is 355 Wild Rose Lane, Parachute, CO 81635 and Monique Teresa Speakman, whose address is 5242 County Road 300, Parachute, CO 81635, hereinafter called "Owner", and Ursa Operating Company LLC, whose address is 1050 17th Street, Suite 2400, Denver, Colorado 80265, hereinafter called "Operator". WHEREAS, the Owner owns the surface of a tract of land located in Section 24 of Township 7 South, Range 96 West, in Garfield County, Colorado and further depicted in Exhibit A attached hereto for all purposes hereafter termed the "Lands" or "Speakman Pad A"; and WHEREAS, Operator desires to utilize the Lands for the operations hereafter described, and Owner in accordance with and pursuant to this Agreement desires to allow such utilization; and WHEREAS, Owner and Operator desire to enter into this Agreement to stipulate the terms and conditions under which Owner will permit such use of the Lands by Operator; and WHEREAS, Owner and Operator acknowledge and understand that the "Water Injection Well Lease and Surface Use Agreement" entered into on November 27, 2013 between James Eugene Speakman and Monique Teresa Speakman, as Owner, and Ursa Piceance LLC , as Operator, is null and void. NOW, THEREFORE, in consideration of ten dollars ($10.00) and other good and valuable consideration in hand paid, the receipt and sufficiency of which hereby are acknowledged, Owner and Operator agree as follows: 1. Surface Use. Owner hereby consents to Operator's use of the surface of the Lands to conduct natural gas recovery operations. 2. Grant of Easement. Owner, in consideration of the consideration provided for and of the covenants and agreements herein contained, and strictly subject to the provisions hereinafter set forth, does, by this Agreement demise, lease, and let unto Operator, for the exclusive purpose of drilling, utilizing, equipping and maintaining one water injection well on Speakman Pad A and use of the well located thereon (the "Well"), in connection with the injection and disposal of water associated with the production of oil and gas and other hydrocarbons (whether the origin of same is from the Lands or other operations of Operator from lands in which Owner does not have an interest) and their injection into the substrata of land; for the digging of pits, laying pipelines, for the placement of tanks and receptacles necessary in receiving, treating and disposing of water associated with the production of oil and gas and other hydrocarbons, and for the placement of structures, telephone and power lines, appliances, engines and machinery required or reasonably deemed necessary by Operator in connection with the operation of the Well as a water disposal input and injection well, including the construction of roads necessary for the purpose of accessing the Lands. Operator may drill, deepen or plug back the Well to make suitable for use as stated herein. Owner agrees that Operator may file in the real property records of Garfield County, Colorado on behalf of Owner appropriate documentation evidencing the rights granted under this Agreement. 3. Payments. Consideration for use and damages for the rights granted hereunder shall be made as follows: Six Cents ($0.06) per barrel of water injected into the Wells payable on the amount of disposed water as reported by Operator to the Colorado Oil and Gas Conservation Commission and paid quarterly. Operator shall also purchase and install one (1) one phase and two (2) two phase metered service boxes with transformers and meters at each box to be located as depicted on the attached Exhibit B. All tap, initiation, acquisition and line extension fees shall be paid by Operator. 4. Termination of Rights. The rights granted by Owner to Operator relating to the operation of the Well as provided for in this Agreement shall terminate twenty (20) years from the Effective Date of this Agreement. The easements and rights-of-way granted herein relating to lands in which Owner does not have an interest, shall terminate if and when Operator shall cease to use such easements and rights-of-way for a period of 36 consecutive months without suspension of use for regulatory reasons or events of force majeure. 5. Nonexclusive Rights. With the exception of the exclusive right to use the Well for the purposes set forth herein, the rights granted by Owner to Operator are nonexclusive, and Owner reserves all other rights including those to use all roads and surface and subsurface uses of the Lands. Owners shall be entitled to construct streets or roadways, water, sewer, or other utility lines which do not damage, destroy or alter the operation of Operator's facilities. Owner specifically reserves the right to use their property for all purposes, including commercial purposes. Operator understands that Owner intends to develop a commercial recreational vehicle park (RV Park). Operator agrees to reasonably cooperate with Owner's activities concerning development and operation of a RV Park. Operator shall reasonably facilitate (without any financial obligation) Owner's future development of the lands of Owner. 6. Use Operator and its employees, authorized agents and invitees shall not disturb, use or travel upon any property owned or controlled by Owner not subject to this Agreement or required for activities identified in this Agreement. None of the Operator's employees, authorized agents invitees or any other person under the direction or control of Operator shall be permitted to carry firearms or any weapon while crossing Owner's properties and such persons shall not hunt or fish on same; and shall not trespass on the same for the purposes of hunting, fishing or any other recreational use. Operator will notify all of its contractors, agents, employees and invitees that no firearms, weapons, hunting, fishing or recreational activities will be allowed on Owner's property. Operator shall not use any water from existing wells, reservoirs and springs on Owner's property, without Owner's prior written consent. Operator shall not permanently disturb, interfere with, fill or block any creek, reservoir, spring or other source of water on Owner's property without paying compensation. 7. Hazardous Wastes Except for privileges specifically enumerated in Paragraph 2 above, the Operator shall not discharge, dump, bury or store pollutants or hazardous materials of any kind on the lands of Owner including, but not limited to, pollutants such as oil, chemicals, toxic substances or materials, hazardous wastes or hazardous substances, including pollutants as the same may be defined, now or in the future, in any federal, state, or municipal laws, rules, regulations or ordinances. Operator specifically agrees to fully indemnify and hold Owner harmless from and against all claims, demands, losses, costs of removal of pollutants, judgments, causes of actions, fines, penalties, costs, including reasonable attorney's fees and costs of court, arising out of or connected with Operator's noncompliance with the terms of this Agreement or Operator's use of the Owner's property, except for any claims arising out of or due to acts or omissions of Owner. 8. Environmental damages Operator shall remain liable for all environmental damages caused or allowed by Operator, or Operator's employees, trustees, agents, invitees or guests. This obligation shall survive the expiration of this Agreement. 9. Roads and Fences Ingress and egress shall be confined to the purposes described in the Agreement. Hunting, fishing and all other recreational uses are specifically forbidden. The use of toxic substances for animal or plant control is prohibited without Owner's written consent. Operator shall reasonably contribute to maintenance and repair of commonly used roads. Upon completion of any construction by Operator, any improvements, roads, culverts and permanent fencing damaged by construction activities shall be repaired by Operator, at its sole expense, along the same alignment and approximate location of the Owner's existing improvements. Operator shall have the right to install, maintain and use gates in all fences and to install its own locks so long as appropriate keys or other adequate opening devices are provided to Owner at all times. In this regard, Operator shall cooperate with Owner with the planning, development, installation and operation of fences and gates to achieve minimal placement and optimal use thereof. Operator and its designated contractors, employees and invitees shall keep all gates in fences closed at all times. Upon final termination of Operator's rights under this Agreement, Operator shall return all roads and other rights-of-way or sites as near as practical to the condition which they were in prior to the execution of this Agreement, unless a different standard is otherwise agreed by Owner. All disturbed areas caused by Operator's activities shall be reseeded. No fences, cattle guards or other improvements on Owner's property shall be cut or damaged by Operator without the prior written consent of Owner, which shall not be unreasonably withheld, and the payment to Owner of additional damages and/or the institution of other safeguards to protect the rights and property. 10. Reclamation and Landscaping Owner shall have the right to plant customary crops, irrigate, carry irrigation water over, harvest and graze the surface areas. Operator shall take all reasonable steps to punctually reclaim the surface of the lands of Owner to a condition that is reasonably satisfactory to Owner. Operator will, insofar as practicable, construct and maintain soil conservation devices as may be reasonably appropriate to prevent damage to the Owner's property resulting from operations of Operator hereunder. Operator shall provide reasonable landscaping and other visual mitigation features and shall be responsible for interim and final reclamation for its activities. 11. Damages Operator agrees to pay for any damage caused to livestock and growing crops and also pay other damages should same constitute other than ordinary and customary use damages. The consideration provided above does not include damage to property not required to accomplish Operator's normal activities, as well as damage to livestock, buildings or improvements, or injuries to persons or to any damage or destruction caused to Owner's property. Operator shall be liable for damages if, as a result of its operations hereunder, any water on or under the Lands which had been potable is affected to the extent that it is rendered non -potable for humans, cattle or other ranch animals on the Lands, or any such water supply, well or reservoir be destroyed or its output diminished. This Agreement does not relieve Operator from liability due to Operator's negligence or due to spills or discharges of any hydrocarbon or toxic or hazardous chemicals or wastes, or from leaks or breaks in Operator's pipelines. 12. Maintenance. Operator shall at all times keep the well site and the road right-of-way safe and in good order, and free of noxious weeds, litter and debris. Operator shall not permit the release or discharge of any toxic or hazardous chemicals or wastes on Owner's property in excess of what is permitted under applicable state and federal regulations. Operator shall, at all times, keep Owner's property in good order, and free of noxious weeds, litter and debris. Operator shall not permit the release or discharge of any toxic or hazardous chemicals or wastes. Operator shall conduct operations and activities in accordance with existing local, state and federal laws, rules and regulations and shall take reasonable steps to (1) limit surface disturbances and damage, noise, trash, weeds, debris, waste, dust, erosion, hazardous materials; (2) protect the Owner's real property, livestock, wildlife habitat and water quality and quantity, and use and enjoyment of Owner's property; (3) establish and implement policies concerning the activities of the Operator's employees, agents and invitees on the Lands, consistent with applicable regulations and laws. The rules of the Colorado Oil and Gas Conservation Commission applicable to wells shall apply to Owner's activities herein. Operator shall keep its interests and activities adequately insured and shall provide Owner with emergency contact information. In any event and notwithstanding any transfer or assignment, the Operator shall remain liable for all environmental damages caused by the Operator and its affiliates and successors and shall indemnify and hold the Owner harmless, including reasonable attorney fees, concerning any and all environmental damages, except for any environmental damages cause by the Operator. 13. Enforcement Costs. If Operator defaults under this Agreement, Operator shall pay all costs and expenses, including a reasonable attorney fee, incurred by Owner in enforcing this Agreement. 14. Indemnification. To the maximum extent permitted by law, Operator will indemnify, defend and hold Owner harmless from any and all claims, liabilities, demands, suits, losses, damages and costs (including, without limitation, any attorney fees) which may arise out of, or be related to Operator's activities on Owner's property (including, without limitation, any claims that Operator's operations hereunder are either illegal, unauthorized, or constitute an improper interference with any party's rights, or have damaged the lands or operations of adjacent landowners). Operator also agrees to and shall indemnify and hold Owner harmless from and against any claim or liability or loss from personal injury or property damage resulting from or arising out of the activities of Operator, its servants, agents or invitees, excepting, however, such claims, liabilities or damages as may be due to or caused by the acts of Owner. 15. Compliance with Law. Operator shall conduct operations and activities in accordance with all applicable local, state and federal laws, rules and regulations, as such may be enacted, revised or amended from time to time which are incident to or arising out of or in any way connected with Operator's activities. 16. Release. To the maximum extent permitted by law, Operator releases and waives and discharges Owner, and, if applicable, Owner's officers, directors, employees, agents, successors and assigns from any and all liabilities for personal injury, death, property damage or otherwise arising out of Operator's operation under this Agreement or use of Owner's property. 17. Notice. Notice may be given to either party to this Agreement by depositing the same in the United States mail, postage prepaid, duly addressed to the other party at the address as set out in the preamble to Agreement. Such notice shall be deemed delivered when deposited in the United States mail. Operator shall punctually provide Owner with Operator's contact information. Operator shall reasonably notify Owner's prior to operations upon the Lands and shall timely consult with Owner regarding the re -location of roads, gates and other facilities incident to Operator's operations. Any plan changes materially different from those shown on Exhibit A shall be evidenced by a new or an amended Exhibit A, which shall be approved by Owner's in writing prior to any construction activities. To the maximum extent commercially feasible, Operator will use existing roads. 18. Construction of Agreement. This Agreement shall be construed under the laws of the State of Colorado, without regard to any conflicts of law's principle that would require the application of the laws of any other jurisdiction. 19. Assignabililty and Binding Effect. This will be binding upon such successors and assigns of the parties. Any sale or assignment by the Grantee of any right or privilege to any third party is void without the consent of Grantors which shall not be unreasonably withheld. In witness whereof, Owner and Operator have executed this Agreement effective as of the Effective Date regardless of the date of execution. OW ,7 R: ames Eugenkman Mon • ue Teresa ' : eakman OPERATOR: Ursa Operating Company LLC Don Simpson, Vice resident of Ursa Operating Company LLC ANNE KELLERBY Notary Public State of Colorado Commission # 20084024843 My Commission Expires Jul 17, 2016 ACKNOWLEDGMENTS STATE OF COLORADO § § COUNTY OF GARFIELD § The foregoing instrument is acknowledged before me, a notary public, this 23rd day of April, 2014, by James Eugene Speakman and Monique Teresa Speakman. Witness my hand and official seal. My commission expires:Ju ) 0 Public STATE OF COLORADO § COUNTY OF GARFIELD § The foregoing instrument is acknowledged before me, a notary public, this 24th day of April, 2014 by Don Simpson, Vice President of Ursa Operating Company LLC on behalf of said corporation. Witness my hand and official seal. My commission expires: DEBORAH BAYLEY NOTARY PUBLIC STATE OF COLORADO NOTARY ID 19924003756 MY COMMISSION EXPIRES 12/31/2017 0 Notary Pubfi EXHIBIT "A" . "43 / / — \ / ,- —.- ...,.'. ......_ ....___. \ _ . IP \—---- /4j.Ct:_ • • \-7--;4 _% - \- ° . ^-., 1•0:4 / • F+6.5 10593' r' r__ Existing F*9.5 .A ' . k_,...\ , - -,/ / : / Pad Limits ---- - \ ! ' \ \ \ / ii 0\ v. , t .../ ..• 105.0 127. 5 - 0 \ / .c‘ .... . • \ 1 • . . • \ 12.5 z ..t, 0 I.S• .. \ s, \ \ • \ .._ ' .,... \ \ Tanks 107.9 3214A °O__..2,A •,.\\ 32C sat 03:6 130 Q.\ 013a \ Spealunan A Pad 34A Prop. UIC •\ -.. Prop Pad \ Pump House 5.5.0 Existing — -- 2:2.5 Pad Limits .-Ltnittasppacdr i .JCSt. Separators FuA ' \ \ 28.8 Eicpunmon I Z 5 32A \ Prop.Separator \ Placement Area 01,1A9/- MC Well \ \ N , \ \ ‘. \ , .6.,\ " • 6 \ 40* 0' :4}3 4, 7 • ., Exist. se \.3\,......N °I1114-scwi \ a. G" Gas .:• ,-, 3•ID W 6' Gas .°7. . Pipeline i• I 4D IN 22.5 PIPelinc o iss„, is 0 I 50.0 O \ \T)..a., \ Exist. \ \ ' • \ s• Combustor / 1 0, 149.5 11.3.0 c, Future N Production \ \\\ ..‘ • ° 1 160.0 \ Pr Water \ . \ \ \ \ ProiAc" s Valve Set ct.' ....• \ ‘ Comb.ustor , o Existing \ • \ \ \ \ -... s .: ..... 0 \ • \ \ - "IP- -- \ 7c\)\ • \ \ \ ••,, Existmg \ \ • • 44 \ o'• - N Pit Limits ............ •• -----A„.., •- vz.,\ • -,_, • .•%. N \ \ \ \ ---"---.,___:. -.... \ • •.',,p• .', \ \ ,• ' / .." : \ \ • \ \ \ ( Pile \ \ \ 80' ‘... ......Soit Stock / \ / / I,' \ /- N ..--- /---- \ \ \ , sow Graphic Scale in Feet . 1".• 80' 'EXHIBA INJECTION WELL SUA " ---- , ,IT ' `• 2.t-.$ Ursa CO:\ ',JAN', Project: Speakman A Pad Rvs 0600144A Speakman A Pad River Valley Survey, Inc. - s 7 110 East 3rd. Street, Suite 213 Rifle, C olorado 81650 Field Date: 10-15-13 Seale: 1"=-- 80' Speakman UIC Sundry Facilities Layout Drawing , Ph; 970-379-7846 Date: 10-24-13 Sheet: 1 of 1 Section 24, Township 7 South, Range 96 West OLSSON ASSOCIATES April 14, 2014 Glenn Hartmann Garfield County Community Development 108 8th Street, Suite 401 Glenwood Springs, CO 81601 RE: Completeness Review Speakman- Ursa Injection Well General Administrative Review - Land Use Change Permit (GAPA-7835) Dear Glenn: Thank you for your Completeness Review Letter dated March 24, 2014. Olsson is responding to this letter on behalf of Ursa Operating Company. 1. Per Comments from the Assistant County Attorney, please provide documentation establishing the name change between URSA Piceance LLC .to Ursa Operating Company adequate to clarify any ownership/lease/permitting questions. Ursa Response: Please see Contract Operating Agreement between Ursa Resources Group II LLC and Ursa Operating Company LLC documenting the relationship between these two companies. 2. Please provide clarification as to the status of the State Storm Water Management Permit. Ursa Response: The CDPHE anticipates updating its rules regarding Stormwater permits. All permits issued prior to 6/30/2013 were set to expire on 6/30/2013 and were administratively continued indefinitely via a letter from CDPHE. Permits issued after 6/30/2013 show an expiration date of 6/30/13 and the comment ADMINISTRATIVELY CONTINUED on the permit certificate with no further expiration date. No additional documentation is required now. 3. Supplemental Information on the SPCC Plan is needed to clarify who prepared the plan and/or clarify any additional information that may be provided as a condition of approval. Ursa Response: Please see SPCC Plan signed and sealed by the professional engineer who prepared the document. 4. Additional documentation regarding potential noise impacts including equipment, plans for mitigation, and an estimate of noise generation reflecting consistency with COGCC noise limitations is needed. The analysis needs to utilize the residential use category for the adjacent properties and needs to be prepared by a professional with noise assessment credentials. Ursa Response: Noise output from the facility will be negligible. The only possible source of noise will be from an electric motor, housed in a structure. The sound impact will be well below the Residential/Agricultural/Rural permitted sound output in COGCC Rule 802. The sound wall that is in place now is intended to accommodate the current activities at the location and will not 760 Horizon Drive, Suite 102 TEL 970.263.7800 Grand Junction, CO 81506 FAX 970.263.7456 www.olssonassociates.com Ursa Operating Company Speakman A Injection Well General Administrative Review — GAPA-7835 April 14, 2014 be a permanent fixture once the injection well is operational. See Sound Analysis included with this response. 5. While not a completeness items, it is requested that the Applicant address the fact that the lease included in the Application refers to the owner's future plan to operate an RV Park on the property and any potential conflicts between the lease and the current Application. Ursa Response: The owner had plans to build an RV Park on a separate area of his property, over a quarter mile away from the Speakman A Pad. However, access to this RV Park area is on Daybreak Road, we also access the Speakman A Pad from Daybreak Road. The intent of this language was simply to ensure that, if the owner begins construction on this RV Park, we would cooperate with them as to limit interference with construction traffic along Daybreak Road. Sincerely, i:1?— 52. 4 47 Lorne Prescott Senior Project Scientist Cc: Rob Bleil, Regulatory lead, Ursa Dave Hayes, Water Manager, Ursa Completeness Review Response Page 2 Glenn Hartmann From: Glenn Hartmann Sent: Friday, May 30, 2014 3:07 PM To: Glenn Hartmann Subject: Small Injection Well LUP From: Hoyer - DNR, Scott[mailto:scott.hoyer@state.co.us] Sent: Friday, May 30, 2014 2:22 PM To: Glenn Hartmann Subject: Re: Small Injection Well LUP Hi Glenn, Our phone discussion yesterday about restricting vehicle traffic to between the hours of 10 am to 3 pm got me thinking about our WMP with Antero (now Ursa). I re -read the WMP and it states that well pad visits during the production phase will be limited, when and where possible, to the hours of 10 am to 3 pm to minimize impacts to wildlife unless operational concerns warrant visits outside of this time -frame. Looking at the comment letter that we submitted, I think that it gives the impression that our WMP agreement completely restricts traffic to this 5 -hour time -frame. I just wanted to clarify that the language of limiting traffic time- frames "when and where possible" was part of the agreement. Please let me know if we need to submit a revised letter clarifying this point or if you have need more information. I can be reached via email or at 970-250-0873 Thanks much Scott Hoyer District Wildlife Manager. Parachute (970) 250-0873