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Home My WebLink About1.21 NTC Response NTC Response Ursa Operating Company Speakman A Booster Compressor OA Project No. 015-3104 760 Horizon Drive, Suite 102 TEL 970.263.7800 Grand Junction, CO 81506 FAX 970.263.7456 www.olssonassociates.com NTC Responses All documents referenced in the following NTC Responses have been incorporated into the appropriate sections of the application. THIS PAGE LEFT BLANK FOR TWO-SIDED DUPLICATION. 760 Horizon Drive, Suite 102 TEL 970.263.7800 Grand Junction, CO 81506 FAX 970.263.7456 www.olssonassociates.com March 1, 2016 Glenn Hartmann Garfield County Community Development 108 8th Street, Suite 401 Glenwood Springs, CO 81601 Re: Ursa Speakman A Booster Compressor (GAPA-12-15-8410) Dear Glenn, Thank you for your comments concerning Ursa’s Speakman A Booster Compressor Administrative Review Application. This letter serves as Ursa Operating Company’s (Ursa) response to your comments. 1. The Application needs to clarify how the mineral rights research was completed. The Application needs to indicate if research with the County Clerk and Recorder or Assessor was completed. Ursa Response: Ursa’s Land Department researched the Garfield County Clerk and Recorder’s records to determine the mineral rights owners for the Speakman property. 2. The list of adjacent property owners within 200 ft. needs to be reviewed/checked for accuracy in particular the addresses for Pudge, Battlement Mesa RV Park, Terry, and Battlement Mesa Service Association. Ursa Response: The adjacent landowners list has been updated. A copy is included with this response. The list will be reviewed prior to sending out the public notices. 3. An updated statement of authority for Rob Bleil needs to be provided and recorded. Ursa Response: An updated recorded copy of Ursa’s Statement of Authority is included with this response. 4. The Application submittal includes a bill of sale for assets from Antero to URSA Piceance LLC. An explanation needs to be provided clarifying the relationship between URSA Piceance LLC and URSA Operating Company LLC. Ursa Speakman A Booster Compressor Page 2 GAPA-12-15-8410 March 1, 2016 F:\Projects\015-3104\40-Design\Reports\LDVP\NTC\_LDVP_NTC Response.Docx Ursa Response: A letter explaining Ursa’s corporate structure and relationship between Ursa Piceance and Ursa Operating Company is included in this response. 5. The use of previous studies is outlined in the Project Description Section of the Submittals. The pre-application meeting summary and discussion noted that the use of previous studies may be accepted provided that they are still current and address the issues as applicable to the current Application. More detailed information on the use of the previous studies is needed as outlined below:  The Grading and Drainage plan section of the submittal needs to include a clarification explaining the documentation provided including responses to previous referral comments for the Speakman A Injection Well and how they are relevant to or support the current Application. Ursa Response: See letter dated February 5, 2016 from Matrix Design Group included in this response.  The Traffic Report section of the submittal needs to include a clarification explaining the traffic generation anticipated from the current Application and confirming that the findings of the report are relevant to the current application. While the project summary states that no additional traffic will be generated, it does not address construction traffic and the traffic associated with monitoring or maintenance of the new facility. Ursa Response: A clarification from Olsson’s Traffic Engineer, Chris Rolling, is included in this response.  In regard to the Roadway Waiver, the project summary states that the current road continues to be maintained as described in the Roadway Assessment Report. The current Application needs to confirm that the findings included in the report are still current and the condition of the road has not changed. Ursa Response: See letter dated February 9, 2016 from Matrix Design Group included in this response. Photos of the road are included, also. 6. The site plan needs to be updated to shown tank sizes for existing tanks on the well pad and adjacent to the proposed compressor. Ursa Response: A revised site plan showing the tank sizes for existing tanks on the well pad is included in this response. 7. The Application provides copies of Air Quality Permits for tank storage on the site. The Application needs to address if Air Quality Permits will be needed for the booster compressor. Ursa Speakman A Booster Compressor Page 3 GAPA-12-15-8410 March 1, 2016 F:\Projects\015-3104\40-Design\Reports\LDVP\NTC\_LDVP_NTC Response.Docx Ursa Response: A revised Air Quality Permit will be required for the Speakman A Booster Compressor. Ursa has 30 days from the date the compressor goes online to evaluate the potential to emit and update their permit. A copy of the approved permit will be forwarded to Garfield County as soon as it is approved. 8. The Sound Study provided does not include documented conclusions that the sound generated by the booster compressor will be compliant with COGCC noise standards. Mitigation by the proposed acoustical barrier and from topography south of the site should quantified to more clearly establish an estimate of code compliance. Ursa Response: Ursa has further analyzed potential noise levels at the location to ensure COGCC noise standards are complied with at the compliance point of 350 feet. The Booster Compressor is considered production equipment as its sole intent is to replace six (6) existing individual well boosters, and should not be considered midstream compression. The information attached (Exhibit A to the NTC response) will also demonstrate that the new compressor will result in less noise than the existing six (6) individual booster compressors. To determine potential noise levels of the proposed single booster compressor vs. six (6) individual boosters, Ursa took representative noise readings on February 24, 2016. These noise readings included background (not just oil and gas) and existing well pad noise (including the six (6) existing boosters). Ursa took readings to replicate the distances in the Exhibit A study and compared them to Attachment A in the application. As shown on Exhibit A, noise levels provided in Attachment A for the proposed single compressor are lower than the six (6) existing booster compressors by an average of 5% for distances of 20 – 240 feet. However, the COGCC compliance standard is based on 350 feet as mentioned above, which was not provided in Attachment A of the application. Ursa collected data at two separate points at a distance of 350 feet showed readings of 46.4 and 47.5 dBA, without Ursa’s proposed sound mitigation. Project noise levels for the proposed booster at 350 feet would be 45.2 dBA; which is within COGCC’s most restrictive standard of 50 dBA for rural/residential. Please note that the standard for light industrial, which Ursa believes is the applicable standard, is consistent with the noise standard approved by Garfield County, within the PUD at 70 dBA. Also note that the closest resident is over 800 feet from the location. Without quantifying the reduction in noise with mitigation at 800 feet, Ursa would be within all compliance standards. Ursa believes that the proposed compression engine to replace the six (6) existing boosters will meet all standards. However, Ursa is proposing sound wall mitigation Ursa Speakman A Booster Compressor Page 4 GAPA-12-15-8410 March 1, 2016 F:\Projects\015-3104\40-Design\Reports\LDVP\NTC\_LDVP_NTC Response.Docx using an STC 40 sound barrier to further reduce the potential for sound impacts to the community. Ursa is prepared to provide additional mitigation as necessary to remain within noise standards. Please let us know if you have any further questions regarding this application. Sincerely, Tilda Evans Assistant Planner Attachments: Revised Adjacent Landowners and Mineral Owners List Updated Statement of Authority Ursa Piceance to Ursa Operating Document Grading and Drainage Traffic Road Assessment Revised Site Plan Sound Exhibit A Cc: Cari Mascioli, Ursa Rob Bleil, Ursa