HomeMy WebLinkAbout1.24 NTC Response
NTC Response
Ursa Operating Company LLC
Tompkins Injection Well
OA Project No. 014-2878
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
February 24, 2016
Kathy Eastley, AICP
Garfield County Community Development
108 8th Street, Suite 401
Glenwood Springs, CO 81601
Re: Tompkins Injection Well – File Number GAPA-02-16-8418
Dear Kathy,
This letter serves to respond to your questions in the Not Technically Complete letter dated
February 16, 2016.
1. Please submit only that valid Pre-application Conference Summary Form documenting the
pre-application conference that occurred within 6-months of submittal of the application.
Response: The Agency Review application packages will include only the Pre-
Application Conference Summary updated December 8, 2015.
2. The owner of the property is Thomas Lynn Tompkins and this fact is not included on the
application form. It does not appear that Ursa Operating is an owner but instead should be
listed as a representative. The application then contains sufficient documentation regarding
the fact that Ursa is represented by Olsson Associates.
Response: The application has been amended to reflect that Ursa Operating Company
(Ursa) is the applicant on behalf of the owner, Thomas Lynn Tompkins.
3. Should the applicant/representative seek to change the authorized contact on this
application please revise the application form as necessary and remove any documentation
related to the currently authorized representative. We are required to comply with the
existing documentation regarding authorization for this application and will continue to do so
until such time as the information is revised.
Response: Ursa is the applicant as the lease holder on behalf of Thomas Tompkins the
property owner. Ursa’s representatives are Cari Mascioli and Rob Bleil. Olsson
Associates is Ursa’s technical consultant and one of the authorized representatives. All
necessary authorization documents are included in the original application package.
4. The application states that six (6) tanks will be dedicated for storage of water for disposal in
the injection well, however the site plan shows a total of 12 tanks, including those labeled for
Ursa Operating Company February 24, 2016
Tompkins Injection Well – GAPA-02-16-8418 Page 2
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produced water and condensate. Are these tanks part of the injection process, or used in
this process? If so the project description should include description of these tanks.
Response: The site will include a total of 12 tanks as shown on the site plan. Six 300
barrel (bbl) produced water and condensate tanks will be used during production for the
natural gas wells on the site. These tanks are not part of the injection process. Six 300
bbl injection water tanks shown on the site plan are dedicated for storage of water for
disposal in the injection well. The project description accurately describes this tank
battery.
5. The SPCC identifies six (6) tanks, W1 through W5 and 01 (a 20 bbl condensate tank).
Please clarify the number and volume of tanks onsite, given that the site plan indicates 12
total tanks on the site as opposed to the six tanks in the description and in the SPCC. Will
the secondary containment be sufficient to contain the six (6) additional tank volumes?
Response: The SPCC Plan only reflects as-built conditions on the site. There will be
twelve 300 bbl tanks on the site at full build-out – six for natural gas production and six
for injection well water storage. These will be in two separate containment areas. The
Site Specific SPCC/Containment Plan included in the application addresses the as-built
situation on the site consisting of the six tank production water and condensate battery
associated with the production of natural gas. Ursa will update the Site Specific
SPCC/Containment Plan as required by the Environmental Protection Agency (EPA),
which regulates SPCC Plans, once the injection well tank battery has been installed. The
containment calculations will be similar to the current tank battery. Ursa will provide the
updated Site Specific SPCC/Containment Plan to Garfield County within six months of
installation of the injection well tank battery.
6. It appears that the injection well may be operational prior to the completion of the pipeline as
the Water Supply and Distribution Plan section of the submittal states that “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.” The issue of hauling water, even for
these temporary purposes, was not discussed in the project description therefore some
confusion has resulted in what the application is actually requesting. Is the application
requesting that hauled water be permitted at this site? Please clarify and, if necessary,
revise either the project description or the Water Supply Plan to fully describe the request in
a consistent manner.
Response: The injection well may be operational prior to the completion of the pipeline.
The timing of placing the injection well into operation is based on the needs of Ursa’s
drilling program and may be dependent on the completion of the Tompkins pipeline.
Ursa anticipates that the pipeline will be complete prior to putting the Tompkins injection
well into operation, but needs to maintain operational flexibility if it is not. Ursa must
maintain the ability to truck water at our discretion, due to operational complexities. The
Project Description has been revised to say the same thing as the Water Supply Plan.
The revised document is included in this response.
Ursa Operating Company February 24, 2016
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7. The Project Description in the application states that the fluids will be transported to the
facility via pipeline except that trucks will be used to haul produced water when
maintenance, emergency conditions, or limited production that does not permit use of the
pipeline. Please clarify the italicized portion of this statement as the County is unaware of
the intent or meaning of ‘limited production’ and are unaware of then this may result in truck
hauling to the site.
Response: Limited production means that the volume of water is too low to flow
through the pipeline. We will be pumping water to this location. If there is not enough
water volume, the water pressure would not be sufficient to move through the pipeline to
the Tompkins Pad. Under these conditions, water would need to be trucked to the
injection well. Ursa cannot anticipate how often this may occur.
8. The traffic study states that two haul routes will be utilized, what is the criteria of use for
each? It does not appear that the traffic study clearly stated the traffic distribution among the
two haul routes, please clarify.
Response: The proposed haul routes shown in the Traffic Report correspond with the
Garfield County approved haul routes to the area. Ursa operators will use the Upper
Haul Route as the preferred route to get into the Battlement Mesa Field. Once the trucks
are in the field, they will make stops at the various pads in the area before proceeding to
the Tompkins injection well via the nearest haul route.
9. It appears that parcel number 2407-043-00-064 has multiple owners which were not listed in
the documentation for owners within 200’ of the subject site. All owners of record are
required to be notified of this land use request.
Response: The Adjacent Landowner List has been updated to reflect the multiple
owners of parcel 2407-043-00-064. The revised list is included in this response.
Please let us know if you have any further questions regarding this application.
Sincerely,
Tilda Evans
Cc: Cari Mascioli, Ursa
Rob Bleil, Ursa
Attachments: Amended Application Form
Revised Project Description
Revised Adjacent Landowner List