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HomeMy WebLinkAbout1.05 Project Description Article 4-203.B.5 Project Description Ursa Operating Company LLC Tompkins Injection Well OA Project No. 014-2878 760 Horizon Drive TEL 970.263.7800 Grand Junction, CO 81506 FAX 970.263.7456 www.olssonassociates.com Ursa Operating Company, LLC Tompkins Injection Well Facility Project Description Ursa Operating Company, LLC (Ursa) requests a Garfield County (GarCo) Administrative Review and approval for construction and operation of the proposed Tompkins Injection Well Facility that will support the natural gas development activities of Ursa in the Battlement Mesa field. Ursa is requesting this permit under the “Injection Well, Small” land use that is an allowed use in the Rural zone district. The water to be handled at this facility is produced from drilling, completion and production operations associated with natural gas wells. Water that is produced from these operations is classified as an exploration and production (E&P) waste by the Colorado Oil and Gas Conservation Commission (COGCC). The proposed facility will store and dispose of water only from Ursa’s holdings. Fluids will be delivered to the facility via the Tompkins Pipeline which was approved by GarCo November 16, 2015. The proposed facility will be located on an existing well pad approved by the COGCC. In addition to being permitted pursuant to COGCC Rule 325, the proposed facility will be permitted using COGCC Forms 31 and 33 for injection wells as well as COGCC Form 26 for sources of produced water. The facility will consist of the following equipment: one injection well, one battery of storage tanks, one combustor, a valve set, one electric pump, and a pump house. The site perimeter will have an earthen berm a minimum of two feet high. Six storage tanks, with an approximate total volume between 1,800 and 3,000 bbls, will be dedicated to storing water for disposal in the injection well. This tank battery will be contained in a three foot high lined steel ring containment area. The pump house will have a maximum area of 1,000 square feet. The site for the proposed Ursa Tompkins Injection Well is approximately 1.75 miles north of the Battlement Mesa Planned Unit Development (PUD), Colorado off of County Road (CR) 309 in the SE ¼ of the SE ¼ of Section 5 Township 7 South, Range 95 West of the 6th Principle Meridian The site encompasses approximately 2.95 acres, at an elevation of 5,532 feet. The property is owned by Thomas Lynn Tompkins and leased to Ursa. The original surface use agreement (SUA) dated February 24, 2011 was between Mr. Tompkins and Antero Resources. Antero’s Piceance Basin Assets were purchased by Ursa. A copy of the Assignment and Bill of Sale, dated October 1, 2012, is included in this submittal. The original SUA was amended by Ursa on January 5, 2015. Ursa entered into a Water Injection Well Lease and SUA with Mr. Tompkins on August 6, 2014. The proposed facility will be operated exclusively by Ursa. The proximity of Ursa’s operations to the proposed injection well necessitates the construction of this facility so that water produced during the drilling, completion and production of natural gas wells in the area may be collected Ursa Operating Company, LLC Tompkins Injection Well Project Description Page 2 and disposed of in a centralized location. Monitoring of operations will typically be performed periodically during the daylight hours of 7:00 am to 7:00 pm by an Ursa employee or contractor arriving via pickup truck. A dust control program will be implemented for the construction interval and use of the access road. The proposed facility will not impact groundwater due to the engineering design of the injection well and the depth at which fluid will be injected. Ursa has obtained a Watershed Permit from the Town of Parachute with conditions of approval for maintaining water quality in Parachute’s watershed protection area. A copy of the approved permit and conditions of approval are included in this application. As part of the Garfield County permit approval process, Ursa will secure all appropriate Colorado Department of Public Health and Environment (CDPHE) Air Quality permits for the storage tanks. The approved Air Quality permit will address the impacts and appropriate level of mitigation for the facility associated with fugitive dust and hydrocarbon venting from the facility. Ursa has 30 days after first production to evaluate the potential to emit quantities to determine if an Air Quality permit is required. A copy of the CDPHE Air Quality approvals will be provided upon receipt. The key benefits of the proposed project are:  Minimize impacts to wildlife and vegetation by constructing a facility on previously disturbed surface  Reduce road maintenance  Utilize an engineering controlled transfer system onsite to minimize human error  Reduce Ursa’s overall development and operating cost by negating the requirement for transport and fluid disposal at distant locations  Reduce trucking and improve safety by piping produced water to the proposed injection facility Details of this request along with the information required by GarCo’s Administrative Review application are provided below. The majority of the adjacent properties are currently occupied by residential uses, PUD open space, small ranches, agricultural land, and oil and gas development. The nearest municipality is the Town of Parachute. The Battlement Mesa PUD is approximately 1.75 miles to the south. There are two residences located within 1,500 feet of the site (see Adjacent Use Map). Copies of deeds demonstrating ownership of this property are contained in the Deeds section. The edge of the disturbance for the well pad and proposed injection well facility is located approximately 50 feet from the southern boundary of the property owned by Thomas Tompkins and leased by Ursa. The other property boundaries are more than 200 feet from the edge of the pad disturbance. As part of the GarCo Administrative Review approval process, proper notification will be provided to all appropriate landowners and mineral owners. The list of landowners and mineral owners that will be sent certified letters informing them of the proposed project and decision date are included Ursa Operating Company, LLC Tompkins Injection Well Project Description Page 3 as part of the overall GarCo Administrative Review submittal package. Names and addresses of landowners within 200 feet of the property boundary were obtained from the Garfield County Assessor’s website database. Names and addresses of mineral owners on the subject property were obtained through a search of the Garfield County Clerk and Recorder’s office property records by Ursa’s Land Department. The design for the proposed facility is provided in the facility site diagram and construction documents. Stormwater management protections, specific best management practices (BMPs), and other drainage controls have been designed into the facility. The facility will be constructed according to the criteria identified in the COGCC Rule 325. The injection well facility will be accessible to Ursa personnel and their contractors 24 hours-a- day, 365-days-a-year. Daily inspections will be conducted by local operations personnel. Operations and maintenance of the proposed facility will be coordinated with the existing operations in the area. An analysis of the traffic impacts generated by this project is provided in the Traffic Study section. The project will be developed in one phase and will include:  Six storage tanks totaling between 1,800 and 3,000 bbls.  Injection pump  Pump house  Associated piping It is anticipated that one pump will supply fluids to the proposed injection well. Therefore, Ursa is requesting approval for one pump and the necessary associated equipment. The injection pump will be powered by electricity. A copy of the “Will Serve” letter from Holy Cross is included in the Standards section. Delivery of fluids to the proposed facility may come from several of Ursa’s well pads, including Yater, Watson Ranch, Monument Ridge, Watson Ranch B, Speakman A, B&V, Monument Ridge B, BMC B, BMC D, and Tompkins. The Tompkins injection well will work in conjunction with the previously permitted Speakman A and the Watson Ranch B injection wells. Ultimately, Ursa hopes to connect all of their production facilities to injection well(s) via pipeline. A full traffic impacts analysis has been provided as part of this submittal. Ursa’s inspector has been contracted to inspect all sites on a scheduled basis for adherence to state and federal requirements. The inspector will maintain logs to accommodate maintenance, safety, and regulatory requirements. The facility will not require potable water or human waste disposal. No lighting will be required at the facility. Fluids will be transported to the facility for underground disposal via pipeline. Trucks may be used to haul water to the injection well for no longer than three months, if the pipeline is not completed prior to the injection well coming online. After the completion of the pipeline, trucks will be used to haul produced water to or from the injection well site only when maintenance, emergency conditions, or limited production needs do not permit use of the pipeline. Water Ursa Operating Company, LLC Tompkins Injection Well Project Description Page 4 generally will be pumped to the injection well. If there is not enough water volume, the water pressure will not be sufficient to move through the pipeline. Under these conditions, water would need to be trucked to the injection well. Ursa cannot anticipate how often this may occur. Maps showing Ursa’s the origination of produced water from the Williams Fork formation and the location of Ursa well pads associated with the proposed injection well are included in the application package. Additionally, a spreadsheet list of Ursa’s existing COGCC approved well pads and well locations are included in the application package. These existing locations may provide produced water to the proposed Tompkins injection well, as well as proposed well pads listed above. The potential contributing wells are located within the non-tributary designation of the Williams Fork formation per data available from the Colorado Division of Water Resources (CDWR). The facility will be operated in accordance with the conditions dictated by the COGCC Underground Injection Control (UIC) permitting/approval process. This process reviews the formation into which water is to be injected and all underground sources of drinking water which may be affected by the proposed operation. The COGCC requires a water analysis and a fracture pressure or fracture gradient analysis of the injection formation. If remediation is required for drinking wells within a quarter of a mile of the injection well, a remediation plan must be filed with the COGCC. The construction of the well casing is highly regulated by the COGCC who requires a resistivity log and full description of the casing of the well. The minimum and maximum amounts of water to be injected daily with anticipated injection pressures are required to be reported to the COGCC at the time of permitting. Prior to application approval, the proposed disposal well must satisfactorily pass a mechanical integrity test. The proposed injection well must continue to pass mechanical integrity testing throughout the life of the well. Environmentally sound and safe operation of the proposed injection well is assured with the implementation of the following emergency controls:  Bradenhead Pressure Alarm: monitors surface casing pressure  Wireless Casing Pressure Monitor/Transmitter: monitors casing pressure  Wireless Tubing Pressure Monitor/Transmitter: monitors tubing pressure  Remote Shut Down Controls: the injection well is equipped with a stand-alone remote telemetry (shutdown) unit that would allow the injection well to continue to operate (but shut down if any alarms or operational issues occur) in the event that the operator loses contact with the injection well; it is solar powered and has a backup battery power supply. Each control is designed to notify the operator regarding any issues with the injection well. The controls have the capability to remotely shut down the well without operator assistance. In addition to the injection well controls listed above, Ursa will have additional controls, which consist of: Ursa Operating Company, LLC Tompkins Injection Well Project Description Page 5  Pump supporting the injection well is equipped with Programmable Logic Controls, which monitors the pump package and pressures.  The pump is equipped with Low Oil Level Alarms and high and low tank alarms. The equipment also monitors flow rates, including the maximum daily pressure/volume (as set by the COGCC). Estimated trip generation information is provided in the Basic Traffic Analysis report. All vehicles hauling equipment and material for project construction on Garfield County roads will abide by Garfield County Road and Bridge’s oversize/overweight regulations. All construction and operations personnel will park on the proposed site and will not block or hinder normal traffic on County Road 309. All activities on this site will be conducted out of the right-of-way of County Road 309 on the subject parcel, and all loading and unloading of vehicles will be conducted out of the public right-of-way. The construction of this facility will result in minor, temporary increases in traff ic on approved haul routes around Battlement Mesa. Regardless of the traffic volume, Ursa will implement the following measures, as necessary, to minimize impacts to transportation and roads:  Control dust along unsurfaced access roads and minimize tracking of soil onto paved roads, as required by the CDPHE Construction Stormwater Permit and per the details contained in the Dust Control Plan.  Comply with county and state weight restrictions and limitations.  Limit construction and operation traffic speeds to a low and reasonable level.  Keep dusty, exposed areas damp with water or a magnesium-chloride solution or other dust suppressant.  Stabilize traffic areas with gravel.  Revegetate or stabilize non-traffic areas as soon as practicable. The proposed injection well facility will comply with all of Ursa’s safety practices including emergency response procedures. The proposed site will comply with requirements of the 2009 International Fire Code, as applicable. A copy of Ursa’s Emergency Response Plan, which includes emergency contact numbers, is provided as part of the submittal. The overall strategic objectives in any emergency response will be to maximize personnel and public safety. Electrical power will be supplied on-site via an agreement with Holy Cross Energy. Operation of the facility will comply with the appropriate Colorado air emissions permitting regulations. Storage tanks in excess of 1,320 gallons that contain hydrocarbon liquids will be included in the area wide Spill Prevention Control and Countermeasures (SPCC) plan. A Stormwater Management Plan (SWMP) detailing the use of site-specific BMPs has been prepared for this area. Further, the SWMP is updated to reflect changes to Ursa’s stormwater plan. All updates to the SWMP are completed prior to initiating any construction activity. Implementation of the SWMP and the appropriate BMPs will ensure that activities conducted at the site comply with stormwater management regulations as required by Garfield County, the Ursa Operating Company, LLC Tompkins Injection Well Project Description Page 6 State of Colorado, and the United States Environmental Protection Agency (EPA). Implementation of this plan also ensures that installation and operation of this facility will not impact surface runoff, stream flow, or groundwater. Site specific BMPs implemented to accommodate erosion control will include (but not be limited to) the following: sediment basins, straw bales, wattles, check dams and berms. Copies of the current SWMP and permit are included in this submittal. The CDPHE Water Quality Control Division is currently developing a new permit and associated certification. The development and review procedures required by law have not yet been completed. The Construction Stormwater General Permit, which expired June 30, 2012, will be administratively continued and will remain in effect until a new permit/certification is issued and effective. All permits issued prior to 6/30/2012 were set to expire on 6/30/2012 and were administratively continued indefinitely via a letter from CDPHE. Permits issued after 6/30/2012 show an expiration date of 6/30/12 and the comment ADMINISTRATIVELY CONTINUED on the permit certificate with no further expiration date. No additional documentation is required at this time. No flammable or explosive solids or gases will be stored on site. As required by COGCC rules, all spills and releases from this facility will be reported to the COGCC in accordance with Rule 906. In the event that a reportable spill or release does occur, Ursa will notify all agencies as required by the COGCC. A Noxious Weed Management Plan including weed treatment records for the past year is part of this submittal. In addition to the measures that are outlined in this plan, Ursa will implement other measures to prevent infestation of noxious weeds. These measures typically include seeding cut and fill slopes around the facility to reestablish native vegetation and treating weeds at least three times per year. The potential impacts to wildlife from this facilit y are anticipated to be negligible as discussed in the Impact Analysis: Section 4-203-G (8) Environmental Impacts and the Section 7-202 Protection of Wildlife Habitat Areas reports provided as part of this application. These reports also discuss several mitigation measures that could be employed to further minimize wildlife impacts. The facility design will ensure that the environment is protected at all times through engineered controls and equipment. Ursa has a Wildlife Mitigation Plan approved by Colorado Parks and Wildlife (CPW) that addresses financial and field best management practices within the area of the proposed project. Additional details are provided in the Impact Analysis. Because of the minimal activity and equipment associated with the operation of this facility, no smoke, vibration, heat, radiation or fumes will be produced as a result of the operation of this facility, beyond that caused by COGCC approved drilling, completion, and production activities. Any appropriate air quality notices and/or permits will be secured from the CDPHE as required. The injection well will not require an air quality permit or Air Pollution Emissions Notice (APEN). Any associated equipment that emits greater than two tons per year criteria pollutants, i.e. production tanks, will need an APEN. The injection well will be fed by an electric pump. This pump is exempt from an air permit/APEN. Ursa Operating Company, LLC Tompkins Injection Well Project Description Page 7 The only APEN associated with the Tompkins pad is the condensate tank battery. The produced water tank battery is exempt. Ursa has 30 days after first production to evaluate the potential to emit quantities prior to submitting an Air Quality permits application. If the potential to emit values dictate that an Air Quality permit is required, Ursa will obtain the appropriate permit within the allowed timeframe from the CDPHE Air Quality Division. Lighting will only be required during unscheduled nighttime maintenance activities. When required, lighting will be shielded, downcast, and focused on the work being done. The facility will be operated in compliance with the noise standards set forth in the Colorado Revised Statutes for Residential/Agricultural/Rural zones. During operation of the facility, contributions to the background noise levels will be negligible. Adjacent property will not be affected, and a public nuisance or hazard will not be created. It is not anticipated that operation of the electric pump at the facility will create a nuisance, since it will be located inside a building. The pump house building will be a skid mounted prefabricated metal building certified by the Colorado Department of Housing. It will be built specifically for the purpose of housing the electric pump for the injection well. The building will be delivered as part of the pump package. The photos below show the typical pump house used by Ursa. This one is located at the Watson Ranch B injection well facility. A building permit will be obtained prior to putting the building into use. Figure 1 - Inside of pump house Figure 2 - Inside of pump house Ursa Operating Company, LLC Tompkins Injection Well Project Description Page 8 Solid waste refuse generated during the construction and operational activities will be stored in wildlife proof containers provided by a licensed refuse hauler. Ursa will use a refuse hauling service to empty the refuse receptacle. Receptacles will be emptied as needed and disposed of at the Garfield County Landfill or other permitted facility. Ursa’s refuse hauler will maintain all records including, but not limited to, trip logs/reports and landfill receipts, and all records will be available to the County upon request. The facility will be operated for the life of the gas wells in the area. This is currently estimated to be 20 years or more. At the end of the economic life of wells in the area, the site will be reclaimed by removing all surface facilities, plugging the natural gas wells and injection well, grading to restore original contours, replacing topsoil, and revegetating the reclaimed area as outlined in the reclamation plan included in this submittal. If deemed necessary by the County Commissioners, Ursa will provide financial assurance for the purpose of ensuring the proper reclamation and closure of the facility. All of Ursa's surface disturbances (final reclamation requirements) are covered under a statewide bond held by the Figure 3 - Front of pump house Figure 4 - End of pump house Figure 5 - DOH certificate – Watson Ranch B pump house Ursa Operating Company, LLC Tompkins Injection Well Project Description Page 9 COGCC. A copy of Ursa’s Blanket Surface Bond #2012-0126 is included in the Reclamation Section. The entire proposed area of disturbance will be reviewed and approved by the COGCC prior to construction and operation. COGCC and Colorado Parks and Wildlife inputs have been factored into engineering design and wildlife protections for the facility. Table 1 - Required Permits Required Permit Agency Permit Status Administrative Review Garfield County Submitted February 2016 Stormwater CDPHE Permit #COR03K566, dated 05/21/2013 Air Quality CDPHE Will be obtained as soon as possible after commencement of operations Watershed Town of Parachute Permit approved 09/26/2014 Special Use Permit and Pipeline Permit Garfield County Tompkins Pipeline Permit approved 11/16/2015 Access/Driveway Permit Garfield County Approved Access/Driveway Permit included in this permit application. Building Permit Garfield County Will obtain prior to making building operational Form 2A Location Assessment COGCC Permit Application approved 12/4/14. Forms 31 and 33 Injection Well COGCC Pending Ursa Operating Company, LLC Tompkins Injection Well Project Description Page 10 This page intentionally blank.