HomeMy WebLinkAbout4 Exhibits AAA - ZZZEXHIBIT
Ursa Operating Company IAA A
1050 1"l'h St., Suite 2400, Denver, CO 80265 --------
September 21, 2015
Mrs. Getter,
We are writing in response to your letter dated September 3, 2015. We appreciate your
comments /concerns and note that you have been a long-time resident of Battlement Mesa. We
are not sure if you are aware, but there were a number of wells drilled nearby and prior to you
moving to the area. Within one mile of the community, the first of which was drilled in 1954,
followed by 17 wells in the 1980's, 54 wells in the 1990's and 102 wells between 2000 and
2005. In 1982, the original county resolution documents were filed in the Garfield County
Clerk's office. This resolution established the Planned Unit Development (PUD) and set out that
the PUD was established for oil and gas development within all districts. From your letter, it
appears that you were aware of the 14 pads originally proposed by a predecessor operator of ours
and were aware of the I 0 pads proposed by Antero in 2009. Your letter stated that there was to
be only 1 well drilled per pad, however, we cannot find any evidence of this statement. It is
however documented that in 2009, Antero announced that it had plans to dri11over200 wells in
the Battlement Mesa area.
While it is true that Ursa has stated that it can drill for the Williams Fork Formation directionally
from 2,500 feet away, this footage distance varies with how deep the formation is beneath the
ground. The maximum drilling reach ranges from 2000' at the Speakman A Pad, to 3100' at the
Tompkins Pad. To achieve the maximum reach a 45° maximum tangent is used. A tangent
greater than 45° can cause: an unstable wellbore, make the wellbore hard to clean and keep
clean, and cause torque and drag issues. Unclean wellbore or increased torque and drag would
require a bigger rig. A larger drilling rig would not be able to drill as many wells from smaller
pads, therefore requiring more pads.
You are correct that both WPX and Encana do have pads in the area, however wells from those
pads only access their prospective leases in the area, not Ursa's leases. Ursa pads/wells can only
be accessing minerals under the tracts that it has under lease. Please also note, that WPX,
Encana and Ursa have drilled, completed and produced wells on each of their pads safely and
without incident.
In bullet paragraph 2, you stated that "most of the minerals have already been accessed; however
geological studies by industry and by our scientist indicate the contrary.
Also in bullet paragraph 2, it was suggested that waiting for technological advancements would
allow Ursa to reach bottom-hole locations from pads further away than it currently does today;
however there is no guarantee that such advances might be achievable. In addition, we have a
duty to our shareholders, our royalty interest owners, and to the broader community as well to
economically and safely develop our natural gas assets. We are engaging the community in that
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regard, and take our "license to operate,, seriously. We, as business people, cannot wait while
our assets potentially de-value.
In bullet paragraph 3, it was stated that Ursa did not submit a Comprehensive Development Plan
(CDP). We suggest that the current Surface Use Agreement of record with Garfield County, is in
fact our CDP for the Battlement Mesa PUD. As you already know, Ursa worked diligently to
reduce the number of Pads that it plans to access in the PUD from the original 14 to 5 or less.
You should also know, that any additional Phases that are proposed will be open to public
comment, not only at the Garfield County level, but at the State level as well.
Bullet paragraph 4 and 5; we appreciate your comment in bullet paragraph 4 regarding traffic.
Please be aware that traffic studies are required by Garfield County and that the two roads that
you state are designated haul routes by the county. As presented in our community meetings,
most of the traffic that accesses the pads, is only present during the short construction and
drilling phase of our operations. After these phases are completed, the longer production phase
of our operations, requires mostly smaller, very minimal traffic impacts as well as much less
other impacts.
Bullet paragraph 6; we acknowledge that the B Pad location will be in the vicinity to a water
intake and the Battlement Mesa treatment plant. The Colorado Oil and Gas Conservation
Commission has regulations regarding safety and environmental measures that must be taken,
and Ursa utilizes Best Management Practices (BMP's) that often exceed the agency
requirements. Please be aware that that there are dozens of well pads in the Colorado River
corridor that are in as close or closer proximity to public water supplies and water sheds relative
to the planned B Pad.
Bullet paragraph 7; while it is true that today natural gas prices are relatively low, there is no
guarantee that prices might increase, just as there is no guarantee that the cost to drill and
complete wells might increase or decrease. Please refer back to our points in paragraph 5 above.
We appreciate the recommendations in your letter and assure you that we have worked diligently
and will continue to work with the developer to reduce impacts inside the PUD as well as to
access natural gas inside the PUD from pads outside of the PUD. To date , we have already
developed 28% of the minerals inside the PUD from pads outside the PUD and our current plan
is to develop 52% of the minerals from pads outside the PUD.
We support the monitoring of air quality in the area, both financially and through cooperation
with the Colorado State University -Air Quality Study. ln fact, Ursa wrote a letter to Garfield
County in support of leaving an air quality monitoring station that was most recently in
Battlement Mesa. We also understand that the mobile air monitoring station may be returning to
the area at some point, most likely during our future operations.
Regarding property values in the area, I refer you to the August 18, 2015 article in the Glenwood
Springs Post Independent, which specifically mentions Battlement Mesa as an area that has seen
the biggest increase in property values in recent months, all while our operations have been
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ongoing. Also, the 2006 Housing Study conducted by Garfield County indicates that housing
prices are not affected, long tenn following the drilling of wells.
Rest assured, Ursa also has employees that live in the Battlement Mesa community. 20% of our
Rifle office employees call this community home, including our Environmental Specialist, who
lives in Battlement Mesa with his wife and 3 children.
Once again, we appreciate your concerns and hope this letter helps answer some of them. Know
that we have taken and will continue to take seriously our responsibility to work with the
Battlement Mesa community to develop a program to produce natural gas in a manner that
maximizes our recovery while minimizing impacts on the community.
Res~ctfully,
i&m~
VP of Business Development
CC; Fred Jarman, Garfield County Community Development Director
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rsa I OPERATING
'CON\PANY
Battlement Mesa Planned Unit
Development (P.U.D.)
Phase I
BMC B -BMC D -Pipeline
Eric Schmela
Robert Blell
Tilda Evans
John Doose
Don Simpson
Matt Honeycutt
Ursa Team
President of Battlement Mesa Company
Regulatory and Environmental Manager
Consuhant Permitting Specialist
Land Representative
Vice President of Business Development
Operations Superintendent
September 23, 201 S
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P.U.D. PHASE I SCOPE lli'ursa
PHASE I APPLICATION INCLUDES:
• BMC B -25 Wells
• BMC D -28 Wells
• Pipeline -2.5 miles and 8 to 16 inches in Diameter
• Water management facility -Not needed during Phase I
BATTLEMENT MESA AREA
~ 197 wells proposed in the Battlement Mesa area
~ 94 wells proposed on up to 5 well pads within the P.U.D.
• BMC A, BMC B, BMC D, BMC L, BMC M
~ 103 wells will be drilled from outside the P.U.D.
• 56 of 103 (28%) wells have already been drilled
~ All locations inside the P.U.D. are pursuant to the Community
Development Plan and Surface Use Agreement.
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REGULATORY OVERVIEW U?ursa
~ Ursa has met or exceeded the spirit and intent of the Gav's Task Force
recommendations #17 & #20.
~ Oil and Gas is one of most heavily regulated industries in the U.S.
~ Regulated by Federal, state, county and municipal regulations.
~ Colorado has some of the most stringent regulations in the U.S.
~ 40+ notifications to agencies, landowners and the community are
required.
~ A crosswalk {matrix) of key Federal, state, county and municipal
regulations {15+ Agencies/Agency Divisions) was developed and shared
with the community.
~ Alternatives analysis was initiated in July 2014.
~ Ursa developed & implemented 16+ Environmental Program Plans (ISO
14000 approach) discussed in community meetings.
~ Under COGCC permitting regulations, Garfield County LGD, CDPHE and
CPW are required to be consulted. This will meld county and community
concerns with the COGCC permit process.
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ENVIRONMENTAL CONCERNS SUMMARY la?'ursa
ALTERNATIVES ANALYSIS
» Impact analysis initiated in July 2014 based on 5 pads in P.U.D.
» Ursa discussed key tools for alternatives analysis (SO+ criteria) in previous meetings to
include:
• Geology Evaluations
• Ability to reach bottom holes outside/within P.U.D.
• Reducing number of pads/pad footprints by maximizing wells per pad.
• Land Assessments
• Lease rights, agency setbacks, lease and property setbacks and existing easements.
• Landowner preferences, community concerns to reduce disturbance and nuisances.
• Operational and Safety Assessments
• Pad size, topography, cuts/fills, access roads and facility layouts.
• Haul routes and traffic.
• Environmental Site Assessments
• Air quality, noise, water wells, public water supplies, wildlife and noxious weeds.
NOTE: WCC/BCC Presentation on 8/31 showed Ursa's Site Assessment (July 2014).
NOTE: Current COGCC setbacks of 500 to 1000 feet are based on COGCC study.
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URSA ENVIRONMENTAL I H & s PROGRAMS 6'Pursa
Air/Odors
Noise
NEPA
Chemicals
Reclamation
Transportation
Visual Resources Waste
Water Quality Water Use
Spills/Incidents/Complaints
Emergency Response Plans
Cu ltu ra I/Pa lea
Noxious Weeds
Wildlife
Water Protection
Spill Prevention
Traffic Safety
Worker Safety
ALL PROGRAMS INCLUDE TIMELY RESPONSE, CORRECTIVE
ACTIONS AND TRACKING REGARDING LANDOWNER
CONCERNS/COMPLAINTS, AGENCY INSPECTIONS, AND URSA
INTERNAL INSPECTIONS (OVER 3,000 VTD IN 2015).
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P.U.D. PERMITTING SUMMARY n?ursa
Over 3000 hours were committed to the preparation of Garfield
County permits which included:
~ Consideration of Health Impact Assessment concerns (2011)
~ Field environmental and land assessments & surveys
~ Alternatives analysis
~ Site construction and facility design
~ Operations schedules and timelines
~ Community safety/Emergency Response Plan
~ Environmental plans for 16+ programs
~ Multiple site visits
Permits planned for COGCC submittal -Late October
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PHASE I· COMMUNITY ENGAGEMENT U?ursa
Ursa held five Focused Community Meetings in addition
to numerous public meetings including EAB, Community
Counts, NW Colorado Forum, etc.
D Jun 15 -Geology of the Piceance Basin
D Jul 13 -Comprehensive Development Plan
D Aug 3 -Operations (Construction Phase)
D Aug 17 -Operations (Drilling/Completions Phase)
D Sep 2 -Operations (Production Phase) & summary of
all previous meetings
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PHASE I COMMUNITY ENGAGEMENT aPursa
~ All meetings included:
0 Overview of the BM Comprehensive Development Plan.
0 Special guests, including agencies.
0 Questions and answers from the community.
0 Battlement Mesa/P.U.D. agency permitting processes &
status.
D Technical operations systems, processes & timing.
D Current operations status & proposed schedules.
D Regulatory, Environmental, Health and Safety, and
community concerns in the 2011 Health Impact
Assessment (HIA) for each operations phase.
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PHASE I COMMUNITY PARTICIPATION aP'ursa
~ Stakeholder/community meetings over the past 2 years: 50+
~ Avg. community participation for each Focus Meeting: 65
~ Comments/questionnaires received: 6
~ Letters received directly and via county: 8
~ Telephone/email comments/inquiries received in response to
public notice mailings: 8
Ursa will hold future Battlement Mesa community meetings on a
monthly or as-needed basis.
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Summary of comments, letters, emails, calls ~U rsa
D Where is the proposed project in relation to my property?
D Will the people who own mineral rights in the described location receive
compensation?
D How will the proposed project affect my property?
D What is the route of the pipeline?
0 How much will property values go down?
0 Where do I send a letter of protest?
0 I have no objections to the proposed extraction and production of natural
gas in the area.
D Objections due to health concerns.
D Objections due to lighting, noise, air pollution, truck traffic.
D Objections due to general location, including proximity to water supply.
D Objections due to lack of Comprehensive Drilling Plan.
D Objections due to drilling technology and reach limits of directional
drilling.
D Objections due to commercial activity in a residential area.
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Summary of comments, letters, emails, calls U?ursa
D Ursa has been a responsible and responsive operator.
D Ursa genuinely appears to want to do the right thing.
D We appreciate Ursa's operational excellence displayed on current and
active pads in the Battlement Mesa area.
D Agencies: COGCC, CDPHE and Town of Parachute.
D Acknowledgment from Garfield County School District 16 ·regarding the
safety and welfare of the students.
D Thanks for implementing operational flexibility to accommodate
community requests.
D Appreciation from local business owners that live in Battlement Mesa .
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OPERATIONS-CONSTRUCTION lli'ursa
)-Pre-Construction
• Landowner, agency and community notifications.
• Baseline water samples collected.
• Pre-Construction meeting held.
> Construction
• BMC B Pad:
• Mobilization of equipment to begin construction: 1.5 days.
• Installation of pre-construction BM Ps: 3 days.
• Commence pad and access road construction: 30-40 days.
-Note: Includes; gravel installation, temporary reclamation and noise mitigation
measures installed.
• Mobilization of equipment to complete construction: 1.5 days. (Total construction
time frame: 36-46 days)
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OPERATIONS -CONSTRUCTION la?ursa
• BMC D Pad:
• Mobilization of equipment to begin construction: 1.5 days.
• Installation of pre-construction BMPs: 5 days.
• Commence pad and access road construction: 45 days .
-Note: Includes; gravel installation, temporary reclamation, landscape design and noise
mitigation measures installed .
• Mobilization of equipment to complete construction: 1.5 days. {Total construction time
frame: 53 days)
• Phase I Pipeline:
• Mobilization of equipment to begin construction: 3.0 days.
• Installation of pre-construction BMPs: 5-10 days.
• Commence pipeline construction, to include seeding, pressure testing, and reclamation: 120
days.
• Mobilization of equipment to complete construction: 3 .0 days . (Total construction time
frame: 136 days)
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OPERATIONS -DRILLING U?ursa
~ Pre-Drilling
• Landowner, agency and communit y notifications.
• Base line water samples collected.
• Pre-Drilling meeting held.
~ Drilling -10 well occupation example.
• Mobilization of equipment to pad: 1.5 days.
• Drilling of wells: SO days.
• Mobilization of equipment off pad: 1.5 days. (Total drilling
time frame: 53 days. 24/7 operations)
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OPERATIONS -COMPLETIONS U?ursa
~ Pre-Completions
• Landowner, agency and communit y notifications.
• Pre-Completions meeting held.
~ Completions -10 well occupation example.
• Mobilization of equipment to pad: 5.0 days.
• Completing of 10 wells: 140 days.
• Note: timeframe includes: stimulation of well, green
flowback and workover rig time to tube up wells.
• Mobilization of equipment off pad: 5.0 days. (Total time
frame for completions: 150 days. Daylight operations only,
5-6 days per week)
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OPERATIONS-PRODUCTION ~Ursa
» Pre-Production
• Landowner, agency and community notifications.
• Pre-Production meeting held.
» Production
• Average well life: 20 -30 years.
• Daily traffic counts: 1 pickup truck, 1-2 trucks per pad/per week.
• Automation/mobile monitoring.
• Operators on pads daily.
» Production facilities are located within the P.U.D. boundary on well
pads to eliminate additional disturbance that would be required to
meet flow line, metering, and sales reporting requirements.
» Safety procedures for utility line excavation and marking of gas
lines will be implemented.
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HEALTHIMPACTASSESSMENT U?ursa
~ November 2009 -Battlement Concerned Citizens {BCC) requested that
Garfield County conduct a Health Impact Assessment (HIA) prior to
allowing development within the P.U.D.
~ February 2011-The HIA was completed by Colorado School of Public
Health at the direction of Garfield County.
~ July 2014 -Garfield County requested that Ursa provide responses to
the HIA, however, resolution of the concerns are ultimately the
county's decision.
~ June 2015 -Mr. Sura {attorney representing BCC) sent a letter to
Garfield County reiterating concerns identified in the HIA.
~ Mr. Sura stated in his letter that, "it is truly remarkable how many of
the HIA recommendations have already been adopted by the state
COGCC, and by local governments throughout Colorado."
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HIA-P.U.D. DEVELOPMENT BASIS lli'ursa
~ Battlement Mesa initially built as an energy
community in early 80's.
~ 1982 Resolution authorized oil & gas development.
~ Ursa has an obligation to mineral interest holders
and our investors to develop Ursa's oil and gas
assets.
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HIA-LOCATION CONSIDERATIONS (BMC Band D pads)liAPUrsa
» Well pads have been reduced from 14 to 10 and currently to 5. Each
is located based on ability to reach bottom holes and other factors
described in previous alternatives analysis slide.
» Ursa has located well pads outside of the P.U.D. to the greatest
extent practical.
» BMC Band Dwell pad locations were determined based on
historical community development plans for the P.U.D., including
consideration of future development.
» Numerous focused meetings and discussions have occurred over
the past year and as far back as 2009.
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HIA -GEOLOGY I BOTTOM HOLE REACHES lli'ursa
» Maximum drilling reach in the area ranges from 2,000' at Speakman
Pad to 3,100' at the Tompkins Pad. Average drilling reach in the area
is 2,500'.
» To achieve this maximum reach, a 45 degree tangent is used.
» A tangent greater than 45 degrees can cause;
• The wellbore to become unstable.
• The wellbore to be hard to clean/keep clean. A debris filled
wellbore can cause drilling problems.
• Torque and drag issues. Any increase in torque and drag would
require a larger rig than Ursa is using.
» A larger drilling rig would not be able to drill as many wells from
smaller pads and would require a greater number of pads.
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HIA-POTENTIAL IMPACT CONSIDERATIONS l°Q'Ursi1
)> Factors influencing potential impacts include existing background conditions and
activities, time, space, distance, size of disturbance, duration, weather, season, existing
human medical conditions and behaviors, etc.
)> Defining Short-term vs. Longer-term potential impacts relative to each operations
phase is key to a rational and focused set of solutions based on real vs perceived
concerns.
)> Short-term for purposes of potential impacts are typically considered 30-90 days, and
longer-term > 90 days.
)> Community presentations talked about the factors listed above relative to the phases
of operations (construction, drilling, completions, and production).
)> Some HIA issues are outside of Ursa's control: vehicle emissions, sexually transmitted
diseases, enforcing speed limits, and therefore are not addressed in the potential
impacts.
)> All potential impacts are addressed in Ursa's Environmental plans and H&S Programs,
Procedures and regulatory functions within operational procedures and BMPs to
mitigate them in accordance with all Federal, state, county and municipal regulations.
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HIA -SOCIOECONOMIC CONCERNS U?ursa
COMMUNITY HEALTH
./ Ursa understands the concerns identified in BCC's letter dated 11/6/2009, that there are
"seniors with existing health problems and comprised immune systems" living in the
Battlement Mesa community, therefore, Ursa has proposed numerous BMPs combined
with all agency regulations to minimize the potential to further impact existing health
conditions.
HOUSING MARKET
./ The Garfield County Land Values and Solutions Study, June 2006, states:
"It is also notable that over time the impact of gas drilling activity, and the employment
and household demands it creates, probably drives home values higher, even for gas
well affected homes, than the negative impacts diminish property value. For the great
majority of Garfield County homeowner, gas drilling has had a significantly beneficial
impact on home values."
./ Recent August 18, 2015 article in the Glenwood Springs Post Independent, specifically
mentions Battlement Mesa as an area that has seen the biggest increase in property
values in recent months, all while Ursa's operations have been ongoing.
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HIA -SOCIOECONOMIC CONCERNS U?ursa
NATURAL GAS ECONOMIC VALUE
./' Gas-related employment is the major economic driver in western Garfield County.
The Northwest Colorado Socioeconomic Analysis and Forecasts Report dated April
4, 2008, indicates that growth in population, housing, employment, and revenues
will come mainly from gas-related development. Revenue produced by this
development funds schools, protection services, and community services within
the Battlement Mesa.
EMERGENCY RESPONSE PLAN
~ Safety to workers and the community is a key aspect of Ursa's operations. Site
Safety and Emergency Response Plans are developed for each location. A
comprehensive Emergency Response Plan is in place for Ursa's operations. These
are provided to Grand Valley Fire Department, Parachute Police Department, and
Garfield County Sheriff's Department. In the event of an emergency directly
affecting the welfare of the residents of Battlement Mesa, Ursa will work with the
various emergency responders to ensure information is relayed appropriately.
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HIA -AIR QUALITY BMPs I MITIGATION a?ursa
PADS/WELLS
~ Construction & Drilling (short-term) -dust mitigated by
watering/suppressants and graveling roads/pads.
~ Completions (short-term) -air impacts mitigated using green
completions. Sand is not proposed to be used during completions,
however, if used, proper BMPs for containment and management of
silica dust will be implemented or eliminated.
~ Production -air emissions managed through CDPHE permit
conditions, leak detection and emissions monitoring, infrared
emission monitoring is conducted by third party.
PIPELINE
~ Construction (short-term) -dust mitigated by
watering/suppressants.
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HIA -AIR QUALITY INFRARED MONITORING
~ Colorado Department of
Public Health and
Environment (CDPHE) new
Regulation 7 requires both
infrared and visual
monitoring.
~ Leak Detection and Repair
{LOAR). This regulation
requires operators to use
ap p roved instrument
monitoring methods
(Infrared camera).
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U?ursa
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HIA -ODOR BMPs / MITIGATION urursa
PADS/WELLS
~ Construction, Drilling, & Production -may be periodic odors on an
intermittent scale, and are typically short term.
~ Completions (short-term) -mitigation efforts include green
completions/flowback, water treatments, carbon-fiber blankets and other
operational practices, are utilized to reduce potential intermittent odors.
PIPELINE
~ Construction & Operations-typically no odors during pipeline
construction and operations.
Odor(s) mitigation -In addition to BMPs listed above, all are addressed,
tracked and followed-up within a short timeframe, typically less than two
hours.
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HIA -CHEMICAL MANAGEMENT BMPs I MITIGATION U2'ursa
PADS/WELLS
~ Construction & Drilling (short-term} -No chemicals are required during
construction and chemicals are only used as drilling fluid additives.
~ Completions (short-term} -All chemicals used during completions are stored in
Federally and state regulated containment and visually inspected daily. Chemicals
used for fracking are reported/disclosed within 90 days of tracking operations
through Frac Focus and annual reporting to the state and EPA.
• Well stimulation consists of 99.5% water, +50% is recycled.
~ Production -Chemicals such as methanol and glycol are maintained in federally
and state regulated containment and secondary containments that are visually
inspection by operators daily.
PIPELINE
~ Construction (short-term) -No chemicals are required during construction .
~ Operations -Chemicals used to clean and maintain the pipeline are not stored on
site.
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HIA -NOISE BMPs I MITIGATION lU>ursa
PADS/WELLS
)P-Construction, drilling and completions (short-term) -Various mitigation practices include
sound walls, hay bales, equipment baffling, mounding, landscaping, shielding, etc.
)P-Production -Noise is the lowest during this phase.
PIPELINE
~ Construction and operations -Equipment noise minimal.
)P-URSA HAS IMPLEMENTED A NOISE BASELINE/MONITORING PROGRAM -First and only
currently on the Western Slope of Colorado.
);;> Ursa is continually making improvements during operations to reduce noise sources.
Recent baseline monitoring studies in Battlement Mesa indicate a range of 24-69 dB(A)
(with NO URSA ACTIVITIES). Wind direction and distance a key variable.
);;> All reported noise concerns are addressed, tracked and followed-up in a timely manner.
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HIA -VISUAL BMPs I MITIGATION U?ursa
PADS/WELLS
~ Construction, drilling, & completions {short-term) -Concerns will be
mitigated through the use of mounding, native vegetation and landscaping
that will shield the production equipment on the BMC D Pad. No visual
mitigation is proposed for the BMC B pad based on its location and
proximity to adjacent development. All lighting will be downcast and
directed into the pad.
~ Production -All production tankage and separators will be low profile and
painted a neutral color. Landscaping will hide most of the equipment. No
lighting is planned.
PIPELINE
~ Construction {short-term) -No visual mitigation measures are planned.
The construction is progressive and fast-moving.
~ Operations-Pipeline will be re-contoured to previous condition and
reseeded with seed mix that is neutral or favorable to wildlife and is
subject to landowner approval. .
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HIA -WATER PROTECTION BMPs/MITIGATION li?ursa
PADS/WELLS
~ Construction (short-term) -sediment associated with dirt moving equipment is
controlled by stormwater BMPs.
» Drilling (short-term)-potential impact to water supplies mitigated by multiple layers
of casing/cementing program (conductor, surface, production casing strings).
» Completions (short-term) -potential impact to water supplies mitigated by state of art
technologies, continual monitoring during the completion processes -pressure and
pump rates, any abnormalities are reported immediately per COGCC rules/guidance.
» Production -potential impact to water supplies mitigated by production tank liners,
steel rings, remote monitoring and shut in equipment, tank alarms. Operators conduct
daily inspections.
PIPELINE
» Construction (short-term) -sediment associated with dirt moving equipment is
controlled by stormwater BM Ps.
» Operations -potential impacts to water supplies mitigated by scheduled inspections of
pipeline facilities and monitoring of flows during water transfer activities.
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HIA -WATER PROTECTION BMPs/MITIGATION U?'ursa
~ Water Protection/Quality
• Stormwater permits/plans in place include Best Management Practices.
• Water well and public water supply sampling programs are in place and
include periodic sampling of wells and water features.
• Special containment protection near public water supplies, water wells,
watersheds, floodplains, U MAs, etc.
• Flowlines are periodically tested as per the agency requirements (MIT-
Mechanical Integrity Testing).
• Inspections are completed regularly and any repairs completed as
necessary.
~ Dozens of pads are located within the Colorado River corridor. Due to the
sensitivity and proximity to water resources, enhanced and aggressive
BMPs are mandated by regulation and permit conditions.
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HIA -SPILLS & INCIDENTS BMPs I MITIGATION n?ursa
PADS/WELLS
> Construction (short-term)-spills and incidents are unlikely to occur. Pre-
construction meetings will be conducted to remind contractors about spill and
accident prevention.
> Drilling & completions (short-term) -all spills are reported to Ursa (not just
agency reportable). Spills are tracked and reviewed for lessons learned and to
implement prevention improvements.
> Production -all spills are reported to Ursa (not just agency reportable). Spills are
tracked and reviewed for lessons learned and to implement prevention
improvements.
PIPELINE
> Construction (short-term) -spills and incidents are unlikely to occur. Pre-
construction meetings will be conducted to remind contractors about spill and
accident prevention.
)> Operations -spills and incidents are unlikely to occur. Spills are tracked and
reviewed for lessons learned and to implement prevention improvements.
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--... ..--..
HIA -SPILLS & INCIDENTS BMPs I MITIGATION llrursa
> Spill Management
• All operational phases managed under state and Federal regulations and Ursa's
spill management plan to protect soil and water.
• Ursa responds to, mitigates and tracks all spills including those not agency
reportable.
> Inspection and Incident Program
• Ursa conducts agency mandated inspections for air, SPCC, stormwater, flowlines,
etc .
• Ursa conducts voluntary site inspections at higher frequency than required by
regulations.
• Ursa's incident program captures and tracks responses to complaints, nuisances,
etc.
• Ursa is in good standing with state agencies. CDPHE performed a Battlement
Mesa Field Wide inspection in April 2015.
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--. _._,
HIA -TRAFFIC SAFETY BMPs I MITIGATION ~Ursa
PADS/WELLS
~ Construction, drilling & completions (short-term) -Ursa contractors only use
designated haul routes approved and implemented by the B.0.C.C. and Garfield
County Road and Bridge Department.
• Ursa provides notifications of upcoming operations that may include the
utilization of oversize/overweight commercial vehicles and pilots to Community
Counts, GARCO Road and Bridge and GARCO Oil and Gas Liaison .
• Ursa's Health and Safety Manager stays in direct contact with Garfield County
District 16 School Bus Transportation Department to ensure all over size/over
weight operations stand down during school bus operating hours.
• During high traffic operations certified traffic management and engineered
safety measures are staged throughout the approved designated haul routes to
assist affected residents and passers-by with safe travels.
• Water pipelines will be installed to decrease the potential truck traffic volume to
haul water.
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-,-.., -,
HIA -TRAFFIC SAFETY BMPs I MITIGATION U?ursa
~ Production -Traffic during production consists of one to two
water transports per week per pad, along with an occasional
workover rig. Pickup trucks are typically used by operators to
visit locations daily, however, remote telemetry reduces
vehicle traffic through remote monitoring.
)-Overall traffic safety -Ursa has a "zero tolerance policy 11 for
employees and contractors operating a passenger and/or
commercial vehicle in an unsafe manner. Once verification of
the concern(s)/report(s) are verified, immediate actions are
taken.
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-,.._ -,
HIA -TRAFFIC SAFETY BMPs I MITIGATION li?ursa
PIPELINES
Fewer vehicle trips associated with hauling fluids/produced water are possible
through the use of pipelines that move fluids between well pads and to injection
wells. These practices reduce traffic by up to 90%, as compared to conventional water
transport methods.
~ Construction (short-term) -Ursa contractors only use designated haul routes
approved and implemented by the B.O.C.C. and Garfield County Road and Bridge
Department.
• Ursa provides notifications of upcoming operations that may include the
utilization of oversize/overweight commercial vehicles and pilots to Community
Counts, GARCO Road and Bridge and GARCO Oil and Gas Liaison.
• Ursa's Health and Safety Manager stays in direct contact with Garfield County
District 16 School Bus Transportation Department to ensure all over size/over
weight operations stand down during school bus operating hours.
• During high traffic operations certified traffic management and engineered
safety measures are staged throughout the approved designated haul routes to
assist affected residents and passers-by with safe travels.
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,,--, ,,......... ,--......
HIA -TRAFFIC SAFETY BMPs I MITIGATION la?ursa
~ Operations -minimal traffic safety concerns are associated
with pipeline operations.
~ Overall Traffic Safety -Ursa has a "zero tolerance policy" for
employees and contractors operating a passenger and/or
commercial vehicle in an unsafe manner. Once verification of
the concern(s)/r~port(s) are verified, immediate actions are
taken.
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,,........ ,,--... ,-...,
HIA -NOXIOUS WEEDS AND RECLAMATION U?ursa
PADS/WELLS
~ Construction (short-term) -weed
management/treatment is performed during
temporary reclamation.
~Production -interim reclamation/weed
management/treatment is performed for the
life of each location.
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,..--. ,.-.-....
HIA -WASTE MANAGEMENT il?Ur&
PADS/WELLS & PIPELINES
Ursa's Waste Management Plan addresses the generation,
storage, transportation and disposal of all E&P and hazardous
wastes for all phases of operations in accordance with Federal
and state regulations and include:
• Management of drilling muds and cuttings
Management/Recycling of produced water.
• Management of all completions fluids
~ No wastes are disposed of on the locations.
~ All temporarily stored wastes are managed w i th containment
BMPs.
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,,,-.... r"' ""-
HIA -WILDLIFE BMPs I MITIGATION li?ursa
PADS/WELLS
~ Construction, drilling, & completions (short-term) -Potential impacts to
sensitive/game species are managed by timing restrictions.
~ Production -Potential impacts to sensitive/game species are mitigated.
PIPELINE
~ Construction (short-term) -Potential impacts to sensitive/game species
managed by timing restrictions.
~ Operations -No impacts to sensitive/game species. Pipeline will be
reseeded with seed mix that is neutral or favorable to wildlife subject to
landowner approval.
~ Potential impacts to game species are managed in accordance with Ursa's
Wildlife Management Plan in consultation with Colorado Parks and
Wildlife.
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HIA -CONCLUSIONS / EXHIBITS U?ursa
CONCLUSIONS
~ All HIA and stakeholder concerns have been addressed in the Garco
permit, in stakeholder meetings and in the BMPs that will be included
in the COGCC permit submittals.
EXHIBITS PROVIDED AT PLANNING COMMISSION HEARING 9/23
~ HIA responses
~ Community meeting presentations
EXHIBITS AT PLANNING COMMISSION FIELD TOUR ON 9/22
~ Regulatory crosswalk of Garfield county & other agency regulations
~ Regulatory summary (Federal, state, county and municipal
regulations applicable to oil and gas)
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REQUEST :
FILE NUMBERS:
APPLICANT:
OPERATOR :
ICCG
PC 10/28/2015
(Continued from 09/23/2015}
FJ
STAFF MEMORANDUM
Special Use Permits for "Extraction of Natural Resources" to drill for
natural gas with accessory pipelines within the Battlement Mesa Planned
Unit Development (BMPUD) for the B Pad and D Pad locations including a
2.5 mile steel pipeline {12" to 16" width) that will gather natural gas from
two proposed well pads and transport it to a location just outside
Battlement Mesa PUD . In addition to the gas pipeline will be two 8" high
density polyethylene water pipelines collocated in the same trench as the
natural gas pipeline.
MIPA-06-15-8341 (B Pad)
MIPA-06-15-8342 (D Pad)
PDPA-08-15-8378 (Pipeline)
Battlement Mesa Partners (Surface Owner)
Battlement Mesa Land Investments (Surface Owner)
Ursa {Minerals Lessee & Operator)
Ursa Operating Company: Rob Bleil, repre sentative
I. GENERAL PROJECT DESCRIPTION
Ursa Operating Company {Ursa) proposes to extract natural gas that lies below the surface of the
Battlement Mesa Planned Unit Development (BMPUD) which is defined as "Extraction of Natural
Resources" and is specifically listed as a Special Use in the PUD documents. As such, Ursa is
required to seek approval for Special Use Permits (SUP) from the Garfield County Board of County
Commissioners for two pad locations (B and D) as well as a 2.5 mile pipeline that will gather
natural gas from two proposed well pads (B Pad and D Pad) and transport it to a location just
outside Battlement Mesa PUD. The gas pipeline alignment will also contain two 8" high density
polyethylene water pipelines collocated in the same trench as the natural gas pipeline .
II. BACKGROUND FROM SEPTEMBER 23, 2015 PUBLIC HEARING
As you recall, on September 23rd, the Planning Commission (after finding legal notice was
sufficient) opened the public hearings on all three separate applications (B Pad, O Pad, and
Pipeline). County Staff made a presentation on the applications followed by a presentation by
the Applicant on the same . Following this, the Planning Commission opened the public testimony
portion of the hearing and took public testimony. At the end of the testimony, the Planning
Commission moved to close the public testimony portion of the hearing and then voted to
continue the hearing to October 28, 2015 . In doing so, the Planning Commission acknowledged
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the Applicant had a variety of new information it was to provide for the next hearing (October
28) at which time the Planning Commission would review the new informati on and move to
deliberation followed by a possible motion and vote on the Application . However, because new
information is being provided by both the Applicant and interested citizens, the Chairman should
re-open the public testimony portion of the hearing so that testimony may be taken specifically
on the new information submitted.
The focus of this memorandum will include discussion on the following points which are based
on the new information requested. [Note, this memorandum is in addition to all the points raised
in the original Staff Memorandum .]
1) Specific Points of Concern in the Staff Report and from the hearing on September 23, 2015 :
a. Refined Noise Study: Intent is to determine the likelihood for noise at 350 feet from
the pad sites with the desire to meet the Light Industrial noise threshold at 350 feet
for all operations. This is particularly important for the B Pad location given the
elevation gain to the residential neighborhoods above .
b . Revised Emissions I Odor technology: Staff has requested more information
regarding vapor recovery technology, and other measures Ursa intends to use to
better mitigate against emissions and odors, etc.
c. Revised Nuisance Response Program: Staff requested a refined plan that adds in real
certainty of response and action resulting from a complaint beyond what is
occurring presently.
d. Revised SPCC Plan: Staff requested a draft plan that indicates what is to be expected
on the site even though it is not required until later as an "as built".
e. Revised Lighting BMPs : Staff requested a more refined response to managing light
pollution off the pad sites.
2) Time Frame: Staff and the Planning Commission requested the Applicant to return with a
more specific timeline as to when the development of the pads and pipeline will be totally
complete . Recall, a primary basis of the Staff recommendation of approval with conditions is
d i rectly related to short term duration for total activity which was believed to be
approximately 2 and 2 Yi years. (In other words, time is considered a significant m itigation
among other mitigations). Ursa could not comm it to a time frame at the hearing and was to
work on that in preparation for the October 28th hearing.
3) Cond itions of Approval (COAs): This section will provide a discussion of the Staff
recommended COAs as well as Ursa 's response since the September 23rd heari ng.
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I. Refined Noise Study
Staff requested a more refined noise study as a result of the original analysis of the
application particularly based on the unique topography near the B Pad as well as the request
that Ursa meet a more restrictive noise level than allowed by the COGCC rules because of its
location inside the PUD and location near residences. The Applicant retained Behrens and
Associates, Inc. to evaluate both pad locations and model site specific expected noise levels
based on both drilling and fraccing activity at 350 feet from the pad boundaries.
Recall for reference, the COGCC rules that apply. Staff has requested that all activity fall at or
below the "Light Industrial" standard at 350 feet from the well pads which is 70 dB(A) during
the day and 65 dB(A) during the night. (COG CC allows fraccing activity, regardless of location,
to fall within the higher Industrial levels. Ursa has committed to day time fraccing activity
only.)
ZONE
Resident ial 'Agric ultural Rural
Commerci al
Light indu stri al
Industrial
7:00 am t o next 7;00
pm
55 clb(A)
60db{A)
70 clb (A)
80 d b(A)
7 :00 pm to next 7 :00
am
50 db(A)
55 db(A)
65 clb(A)
75 db(A)
B Pad: As a result, the new Behrens noise study (attached as Exhibit EEE), noise levels
measured at 350 feet from the B Pad during drilling (without mitigation) range from 54.3 to
59.8 dB(A) which fall well below the suggested Light Industrial zone and are more closely
aligned with the Commercial Zone levels . For fraccing activity during the day time,
unmitigated noise levels at 350 feet range from 69.6 to 75.5 dB(A} which are slightly higher
than the suggested Light Industrial Standard. Based on this, the Applicant is proposing two
levels of noise mitigation:
1) Option 1: This mitigation option includes installation of a 40 foot tall acoustical sound
wall around the majority of the well pad that reduces fraccing activity noise levels by
approximately 16 dB(A) in the most extreme case to ranges of 58.2 to 61.6 dB{A)
which are well below the Light Industrial Standard.
2) Option 2: This mitigation includes the 40 foot sound wall and 20 foot STC-33 panels
located around all the frac trucks inside the pad. With this added mitigation, noise
levels drop lower to ranges of 56.6 to 60.2 dB(A) at the loudest at 350 feet from the
pad. This is well below the suggested light Industrial standard.
D Pad : As a result, the new Behrens noise study (attached as Exhibit FFF), noise levels
measured at 350 feet from the D Pad during drilling (without mitigation) range from 46.7 to
59.6 dB(A) which fall well below the suggested Light Industrial zone and are more closely
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aligned with the Commercial and Residential Zone levels. For fraccing activity during the day
time, unmi t igated noise levels at 350 feet range from 62.4 to 75 .7 dB(A) which are higher
than the suggested Light Industrial Standard . Based on this, the Applicant is proposing to
mitigate these noise levels by installing a 40 foot acoustical wall around the entire well pad
with the exception of the entrance off of River Bluff Road. This mitigation will reduce the
noise levels by 13.5 dB(A) in the most extreme case. The resulting noise levels during fraccing
with mi tigation at 350 feet from the pad will range from 57.6 to 64 .1 dB(A) which is not only
below COGCC's Light Industrial standard, but is almost 16 dB(A) below what state law actually
allows. Importantly, there will also be no fraccing activity at night.
Staff Comments
These mitigated noise levels from both the B and the D Pads, based on the Behrens study,
not only reduce the noise levels to meet or be below the light Industrial zone standards, they
are also only measured at 350 feet from the pads. With the exception of the Burke residence
located approximately 400 feet from the B Pad , as the noise emanates outward, those dB(A)
will continue to decrease such that noise experienced at the closest residences in the Stone
Ridge, Monument Ridge, Valley View Village, and Willow Ridge apartments will be nearer to
or within the residential I agricultural I rural zone levels.
It has been suggested that Ursa ought to comply with the Town of Erie's Best Management
Practices (BMPs) for noise as committed to by Encana Oil and Gas, shown below:
2. Nobe mitigation. Encana will comply with the following noise mitigation requirements
at all pad sites:
(a) For db(A) scale noise, Encana win insure that the noise level from operations
subject to the light industrial zone noise standard under COGCC Regulations
802.b end 604.c .(2)(A) does not exceed sixty (60) db(A) and that the noise level
from operations subject lo the industrial zone noise standard under COGCC
Regulations 802.b end 604.c .(2)(A) is reduced nl least five (S) db(A) below the
maximum level pennitted by those Regulations. For this purpose, the noise level
shall be measured as set forth in COGCC RcguJations 802 .b & c, except no
measurements shall be taken when traffic is passing the soWld level meter,
Encana shall be present during all measurements, ond building units shall be
limited to those units existing as of the Effective Date. As set forth in COG CC
Regulation 802.b, the noise levels shell be subject to increase for a period not to
exceed fifteen (1 S) minutes in any one (1) hour period and reduction for periodic,
impulsive or shrill noises.
The Erie BMPs (above) essentially state that drilling activities and other noise (except fraccing)
shall remain at or below 60 dB(A) and that activities that are allowed at the COGCC Industrial
level {fraccing) shall be reduced only 5dB(A) from its COG CC level; essentially from a range of
75 to 80 d(B)(A) to 70 to 75 d(B)(A) for fraccing. The Behrens study submitted by the Applicant
shows that noise (during drilling & fraccing) generated on the B and D pads will not only meet
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or exceed (fall below) the Erie BMPs, but will also fall below the Staff suggested Light
Industrial thresholds.
Finally, recall that the standards in Garfield County's 1978 and 2013 Land Use and
Development Codes are as follows:
(1978Code}
Section S.03 (1.) The applicant for a permit for industrial operations shall prepare and submit
to the Planning Director two {2) copies of an impact statement on the proposed use
prescribing its location, scope, design and construction schedule, including on explanation of
its operational characteristics. The Impact statement shall show that the use shall be
designed and operated in compliance with all applicable laws and regulations of the County,
State and Federal Governments, and will not have a significant adverse effect upon :
(a) Use of adjacent land through generation of vapor, dust, smoke, noise, glare or
vibration, or other emanations;
Section 5.03.0B: Industrial Performance Standards: All industrial operations in Garfield
County shall comply with applicable County, State, and Federal regulations regulating
water, air and noise pollution and shall not be conducted in a manner constituting a
public nuisance or hazard. Operations shall be conducted in such a manner as to
minimize heat, dust, smoke, vibration, glare and odor and all other undesirable
environmental effects beyond the boundaries of the property in which such uses are
located, in accord with the following standards:
(1) Volume of the sound generated: every use shall be so operated that the volume of
sound inherently and recurrently generated does not exceed ninety {90} decibles, with
a maximum increase of five (5) decibles permitted for a maximum of fifteen (15}
minutes in any one hour, at any point of any boundary line of the property on which
the use is located.
(Land Use and Development Code of201.3}
7-lOOl{F) Noise shall not exceed State noise standards pursuant to C.R.S., Article 1.2, Title
25, unless the use is regulated by the COGCC. In this case, the use shall be subject to
COGCC rules in regard to noise abatement.
Noise will emanate from both the B and D Pads while they are being drilled and completed .
This noise will continue over adjacent properties. The 1978 Code requires that noise not have
a significant adverse effect on the use of adjacent land and that the noise should not
constitute a public nuisance or hazard. Further, noise from industrial activities shall not
exceed 90 dB(A) at the property lines of the subject property. The 2013 Code (Industrial
Standards) defers to the COGCC noise regulations which has been discussed above. Because
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of this, the COGCC standards are the required thresholds. This proposed operation, with the
proposed mitigation, meets or exceeds these standards as well as the more stringent staff-
recommended noise limits.
II. Revised Emissions I Odor Technology
Based on the review of the Application and discussion at the hearing, Staff requested more
information on what could be done to reduce emissions and control odors from the B and D
pads as unique mitigation beyond the typical approaches. This included having the Applicant
demonstrate what are the best proven technologies that could be implemented such as vapor
recovery units (as suggested in the Health Impact Assessment (HIA)) to carbon blankets
covering frac tank thief hatches, etc.
Whi le not synonymous, odors are commonly related to emissions including VOCs which is
related to air quality and concerns over what is in the air and its potential health impact.
Along these lines, Staff has suggested the implementation of a site specific real time air
quality monitoring program that includes a calibrated sampler and series of air samples to be
taken over the course of drilling and completing occupations as well as during production for
a period of time. This would cost approximately $50,000, including monitoring equipment the
first year and perhaps half that amount in subsequent years during active drilling and
completion operations. Monitoring costs are to be borne by the Applicant but implemented
by Garfield County and consultant staff and is currently proposed as a COA.) The goal of which
is to better isolate and identify odor I emissions issues as experienced by nearby residents
rather than not be able to respond adequately to odor nuisance complaints that are likely to
occur. This would help to identify what contaminants are in the air that are the cause for the
complaint.
As of the writing of this memorandum, the Applicant remains reluctant to thi s suggested
program . Rather, they believe that the programs that they have proposed such use of the IR
Camera, AVO Surveys, the new CDPHE I EPA emission rules, and their continued participation
in the CSU Air Quality study is sufficient regarding air quality. They suggest a site specific air
dispersion modeling program in lieu of an air quality monitoring program. Staff is concerned
that a modeling program will not reveal accurate enough information to inform a complaint
concern . Further, Ursa is a significant contri butor to the CSU Air Quality Monitoring Study
which is using site specific monitoring rather than modeling.
Regardless, these operations are required to meet or exceed regulations required by the
Colorado Department of Public Health and Environment (CDPHE) Air Quality Regulation
Sect i on 7 criteria based on the new EPA regulations around emissions . These include "low
emissions flow back process" (AKA Green Completions) for well completions and routes tank
venting through a voe combustor. Also, URSA developed a Leak Detection and Repair system
with infrared cameras to detect any emissions as well as implemented a Storage Tank
Emissions Monitoring program to monitor and repair any emissions leaks from produced
water and condensate tanks which complies with the newly adopted CDPHE Regulation 7
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requirements known as "Control of Ozone via Ozone Precursors and Control of Hydrocarbons
( via Oil and Gas Emissions .
(
Again, the County regulations that apply here are the following:
/1978Code}
Section 5.03.0B: Industrial Performance Standards: All industrial operations in Garfield
County shall comply with applicable County, State, and Federal regulations regulating
water, air and noise pollution and shall not be conducted in a manner constituting a
public nuisance or hazard. Operations shall be conducted in such a manner as to
minimize heat, dust, smoke, vibration, glare and odor and all other undesirable
environmental effects beyond the boundaries of the property in which such uses are
located, in accord with the following standards:
(4) Emission of heat, glare, radiation and fumes: every use shall be so operated that it
does not emit heat, glare, radiation or fumes which substantially interfere with the
existing use of adjoining property or which constitutes a public nuisance or hazard.
Flaring of gases, aircraft warning signals, reflective painting of storage tanks, or other
such operations which may be required by law as safety or air pollution control measures
shall be exempted from this provision;
{2013 Code}
7-205. ENVIRONMENTAL QUALITY: Any Land Use Change shall not cause air quality to be
reduced below acceptable levels established by the Colorado Air Pollution Control Division.
There is no minimum County, State or Federal requirement to require the operator to install
site specific air quality monitoring at these two pad locations. It has been suggested in the
HIA; however, state and federal rules have changed since the HIA draft was completed
including requirements for tank vent combustion, green completions, IR camera evaluations,
etc . Despite, these technological advances, the County continued to receive significant odor
complaints which is the leading complaint for nuisance related to exaction of natural gas and
is anticipated from these two proposed pads.
Ill. Revised Nuisance Response Program
.
Staff requested a refined plan that adds in additional certainty of real time response and
action resulting from a complaint beyond what is occurring presently. The Applicant has
prepared a refined plan (attached as Exhibit GGG) that also includes a newly established
phone number and physical phone that is on 24/7 and can be physically transferred from
person to person in charge of operations on that particular day. This is a way that helps to
eliminate the issue of confusion of who is reachable . Of course, the certainty will depend
largely on an immediate response to the call as well as the immediate action taken depending
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on the subject of the call. This is a better approach than was originally proposed . Success will
be measured by its 100% implementation.
IV. Revised Spill Prevention Counter Measure and Control (SPCC) Plan
Staff requested a draft plan that indicates what is to be expected on the site even though it
is not required under COGCC rules. The Application does contain a field·wide SPCC Plan that
contains good information; however, it does not lay out the specific measures for the B or D
Pad because they have not been constructed yet. Normally, those plans are required to be
submitted as "as builts" after construction.
The Applicant responded with satisfactory clarifications regarding leak detection information
which is found in the SPCC Plan on pages 76·78, 83, 85, and Appendix E. Information about
how precipitation events would be safely drained from secondary containment is found in
the SPCC document on page 84. Additionally, the Applicant clarified that the production tanks
are filled from the top by design so that they cannot equalize in the unlikely event of a tank
failure. Tank volumes are controlled and lowered individually. Thus secondary containment
is sized to the largest individual tank in the battery.
Based on this, Staff has revised the related suggested Condition of Approval to the following:
The Operator shall provide a draft site specific SPCC plan for Pad B within 30 days of
( installation of tank containment structures. The Operator shall provide a final site
specific SPCC plan for the BMC 8 and D pads within six months of installation of the tank
containment structures per EPA regulations. The site specific plan shall include
information on storage tank sizes and the volume of secondary containment is
calculated.
V. Revised Lighting Best Management Practices (BMPs)
As a result of the Application review and discussion in the hearing, Staff requested a more
refined response to managing light pollution off the pad sites. The Applicant responded with
the following:
"While a site specific lighting plan is optimal, lighting needs change depending on the active
operations at any given time. Ursa will use a lighting system that makes sure that lights are
downcast and/or shielded so as to minimize a "stadium effect."
The Applicant suggested modifications to the current Condition of Approval which Staff
agrees as the following: (Underlined language is new.)
All lighting, except as demonstrated for safety reasons, shall be directed inward and
downward and be shaded in order to prevent direct reflection on adjacent property and
residences in the area. LED lights will be used when possible and practical. Workers will
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be advised when moving light plants to ensure that the light is focused directly on the
work being done. Most lighting will be below the sound wall. Drilling mast lighting that
is above is the sound wall will be downcast and/or shielded to reduce fugitive light
outside sound wall and well pad. Safety considerations will take precedence.
VI. Time Frame
A full review of the time frames for pad construction, well drilling and completions and
placing both the B and D pads into full service (full production of 53 wells) suggests a
timeframe of 2 to 2.5 years from start to finish which also includes the construction of the
pipeline . While not exclusive, the overall timeframe to complete this project is considered
one of the most important considerations that help mitigate its associated nuisances because
they are short lived. Recall, the overall life of these wells is expected to be approximately 25
years with the bulk of those years where the pads sit in a production phase long after any
drilling I completion activity is over. [2 .5 years of nuisance activity generated from pad
construction, and drilling and completing wells is 10% of the 25 year lifetime of the projects.
Once that 10% is over, the remaining 17.5 years does not produce these short lived impacts.]
As you recall, Ursa could not commit to a time frame "from start to finish" at the hearing on
September 23rd despite what Staff believed to be approximately 2 to 2Yz years; they were to
be prepared to provide that information for the October 28th hearing. Since that hearing Ursa
indicated to Staff that they would commit to a total of 3 years (or 12% of the fill project) to
fully complete the project with the clock beginning if I when they receive the County's Special
Use Permits and completing when all wells are lying in a production state within the 3 year
timeframe. Staff would suggest this as a condition of approval. If this cannot be met, the
Applicant would be required to return for an amendment to their SUP through the County
process again .
4) Conditions of Approval {COAs): This section will provide a discussion of the Staff
Recommended Conditions of Approval as well as Ursa's response since the September 23rd
hearing. Note, for ease of the reader, these COAs have been placed into 3 separate
spreadsheets for the B Pad, D Pad and Pipeline. It contains the originally proposed COAs,
responses by the Applicant and suggested modifications if any to the COAs.
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EXHIBIT
I ee' i..
COA For B Paci Conllnllllta I Dlscnsalon COA Altem.tive PC Adopted COA on 1CL128115 with Sbff
reflMtMnta In Dl'fff'I
1 That all representations of the Applicant, either in That all representations of the Applicant, etther in
testimony or lhe submitted application materials, shall testimony or the submitted application materials, shall
be considered conditions of approval unless be considered conditions of approval unless specifically
specifically atlered by the Board of County altered by lhe Board of County Commissioners.
Commissioners.
2 If future extraction and processing activity (additional tr future extraction and processing activity (additional to
to what is being permitted herein) oould be proposed, what is being permitted herein) oould be proposed, an
an amended Special Use Permit shall be required amended Special Use Permit shall be required prior to
prior to thal activity occurring on the site. lhat activity ocalrring on lhe site.
3 The Operator (URSA) acknovdedges that the County The Operator (URSA) acknov.tedges that the County
has performance standards in place that could lead to has performance standards in place that could lead to
revocation of the Special Use Permit if violations of revocation of the Special Use Permit if violations of the
the permit ocalr. oermit occur.
4 Operalion of lhe facility must be in accordance with aQ Applicant suggests adding the fangauge in red (on the Operation ol lhe facility must be in accordance with all Operation of the facility must be in accordance with all
Federal, State and local regulations and permits right). Staff disagrees and suggests it remain as it is Federal, State and local regulations and permits Federal, State and local regulations and permits
goveming the operation of this facility. lanugae directly from the Land Use and Development goveming the operation of this facility. Any conn1cts governing the operation of this facility.
Code of 2013. Any change to COAs adopted by the between Garfield !:;ounrt and federal state j!nd local
Board of County Commissioners thel are lo be Q!l!!IJit conditions of a ~£!!2val will reg.utre resolution
modified currenUy requires a public hearing before the between the a ge!Jc1es and the 0 11erator,
BOCC so a formal process 1s available to manage lhal
connict.
5 The County commits to notifying the operator of any Staff suggests rewording this COA such that the The County commits to notifying the operator of any The County commits to notifying the operator of 11ny
compliance concern and allows an inspection with site County wiQ be allowed lo contact other permit compliance concern. This may include direct notice by compliance concem. This may include direct notice by
personnel and the designated County inspector prior agencies if the need arises before any site visit with Garfield County to other affected permitting agencies if Garfield County to other ~ pm:mittf"'I! ag.cmcics if
lo contacting any other permitting agency. the operator. necessary depending on the comptience concern. necessary depending on the compliance concern.
6 The County can request a site inspection with one The County can request a site inspection with one
calendar day's notice to the Operator. Full access to calendar day's notice to the Operator. Fut! access to
any part of the site will be granted. On request, all any part of the site will be granted. On request, at!
paperoork musl be shown. The County cannot paperoork must be shown. The County cannot request
request a large number of inspections that oould a large number of inspections that oould interfere with
interfere with normal ooeration without cause. normal ooeration without cause.
7 All extraction and processing activities shall be All extraction and processing activities shall be
required lo comply with the fottowing performance required to comply with the following performance
standards: standards:
Page 1of8
~ --...........
COAForBPed Comments/ Dlscuulon COA~ PC Adopted COA on 10121/1& with staff ---
l'eft-.ta In grHn
-
(1) Volume of \he sound generated: eveiy use shall be so Staff suggests \his COA be replaced in run wilh \he Volume of \he sound generated: Every use shall be so Volume of \he sound generated: Every use shal bit so
operated that the volume or sound inherently and suggested COA to the righl Essentially, the COGCC operated \hat the volume or sound inherently and operated that the volume of sound inherenUy and
recurrently generated does not exceed ninety (90) rule is more stringent; moreover, the Applicant has recurrenlly generated does not exceed 70 dB(A) from recurrently generated does not exceed 70 dB(A) from
decibels (or COGCC rule, whichever is more demonstrated that they can meet or exceed the Light 7:00 AM to 7:00 PM and 65 dB(A) from 7:00 PM to 7:00 7:00 AM to 7:00 PM and 65 dB(A) from 7:00 PM to
stringent), with a maximum increase of frve (5) Industrial threshold of 70 DB(A) during the day and 65 AM, measured 350 feet from the edge of the pad. As 7:00 AM, measured 350 feet from \he edge or the pad.
decibels pennitted for a maximum of fifteen (15) dB(A) during the night at 350 feet from the pad with set fonh in COGCC Regulation 802(b), the noise levels As set forth in COGCC Regulation 802(b), the noise
minutes in any one hour. at any point or any boundary mitigation. Exception langauge allowed by the shall be subject to an increase by 10 dB(A) for a period levels shall be subject to an increase by 10 dB(A) for a
line of the property on which the use is located. COGCC (and the ToM! of Erie) is included as well. not to exceed 15 minutes in any one (1) hour period and period not to exceed 15 minutes in any one (1) hour
cannot exceed 65 dB(A) for shrill or periodic impulsive period and cannot exceed 65 dB(A) for shrill or periodic
noise. Complaint protocols shall be govememed by impulsive noise. Complaint protocols shall be
COGCC Rule 802(c}. 111ovememed bv COGCC Rule B02(c}.
(2) Vibration generated: every use shall be so operated Vibration generated: every use shall be so operated
that the ground vibration inherenUy and recurrently that the ground vibration inherently and recurrenUy
generated is not perceptible, without instruments, at generated is not pen:eptible, without instruments, at
any point of any boundary line of the property on any point of any boundary line of the property on which
which the use Is located; the use is located;
(3) Emissions of smoke and particulate matter: every use Emissions of smoke and particulate matter. every use
shall be so operated so as to comply with all Federal. shall be so operated so as to comply with all Federal,
Slate and County air quality laws, regulations end Slate and County air quality laws, regulations and
standards: standards;
(4) Emission of heat, glare, radiation and fumes: every Emission of heat, glare, radiation and fumes: every use
use shall be so operated that ii does not emit heal, shall be so operated that ~ does not emit heat, glare,
glare, radiation or fumes which substantially interfere radiation or fumes which substantially interfere with the
wilh the existing use or the adjo :ning property or existing use of the adjoining property or which
which constitutes a public nuisance or hazard. Flaring constitutes a public nuisance or hazard. Flaring of
or gases, aircraft waming signals. renective painting gases, aircraft waming signals. reflective painting of
or storage tanks. or other such operations which may storage tanks. or other such operations which may be
be required by law as safety or air pollution control required by law as safety or air pollution control
measures shall be exempted from this provision; measures shall be exempted from this provision;
(5) Storage area, salvage yard, sanitary land-fill , and Storage area, salvage yard, sanitary land-fill, and
mineral waste disDOsal areas : mineral waste dispesal areas:
(a) Storage of nammable, or explosive solids, or gases, Storage of nammable, or explosive solids, or gases,
shall be in aceo«lance with accepted standards and shall be in accordance with accepted standards and
laws and shall comply with the National Fire Code; laws and shall comply with the National Fire Code;
(b) At the discretion of the County Commissioners all At the discretion of the County Commissioners all
outdoor storage facilities for fuel, raw materials and outdoor storage facilities for fuel, raw materials and
products shall be enclosed by a fence or wall products shall be enclosed by a fence or wall adequate
adeauate to conceal such facilmes from adiacent to conceal such facilities from adiacent nro,,,.nv;
(c) No materials or wastes shall be deposited upon a No materials or wastes shall be deposited upon a
property In such form or manner that \hey may be property in such fonn or manner \hat they may be
transferred off the property by any reasonable transferred off the property by any reasonable
foreseeable natural causes or forces ; foreseeable natural causes or forces;
Page 2of 8
,,--.-....
COAForBPad
(d) IAll materials or wastes v.t»ch might constitute a lire
hazard or v.tlich may be edible by or otherwise be
attractive to rodents or insects shall be stored
outdoors in accordance with applicable State Board of
Hea\th Re!lulation:
(6) !Waler pollution; in a case in v.tlich potential hazards
exist, ii shall be n~sary to install safeguards
designed to comply with the Regulations of the
Environmenlal Protection Agency belore operation of
the facdilies may b!:!Cl'n
B)lhe 6perator shall provide noise mitigation (wall,
1
btankets, engine orientation, etc.) that can effectively
reduce the noise generated from the B Pad such that
[it does not exceed the Light Industrial Zone threshold
1Wlich is 70 db(A) from 7 :00AM-7:00PM and 65 db(A)
11rom 7;00 PM lo 7 ;00AM measured at 350 feel from
the noise source.
9IAll lighling, except as demonstrated for sarety
reasons, shaU be directed inward and downward and
be shaded In order to prevent direct reflection on
adjacent property and residences in the area.
Commenta I Dlscuutan
Staff suggests deleteing this OOA as it is a duplicate
of COA number 7(1) above.
Staff agrees with the suggested additional language
suggested by the Applicant in red to the righl
t OIThe construction of the B Pad shall be limited to the The Applicant has suggested I hat it needs the
hours of 7:00 AM to 7:00 PM. Drilling may occur flexability to be able lo address emergencies al any
continuously 24 hours a day. Well completion activity hour for the safety of the community and workers.
shall be lim"ed lo occurring between 7:00 AM and Additionally, ii also needs to be able to safely
7:00 PM. Once the wells are in production, vehicle complete and stop activities when unforeseen events
trips to the pad shall be limited to the hours of 7:00AM oca.ir. Ursa will communicate with Garfield County
to 7 :00PM. and Community Counts as soon as possible v.tlen
l
lhe$8 unloreseen events occur. Slaff agrees with
these suggestions on the right in red.
COA Alt9rMtiw
Volume of the sound generated: Every use shall be so
l
operated that the volume of sound inherently and
rea.irrently generated does not exceed 70 dB(A) from
7:00 AM lo 7:00 PM and 65 dB(A) from 7:00 PM lo 7·00
AM. As set forth in COGCC Regulation B02(b), the
Incise levels shall be subject lo an increase by 1 O dB(A)
'tor a period not to exceed 15 minutes in any one (1)
hour period and cannot exceed 65 dB(A) for shrill or
periodic impulsive noise. Complaint protocols shall be
h1ovememed by COGCC Rule 802(c).
AU lighting, except as demonstrated for safety reasons,
shall be directed inward and downward and be shaded
PC Adoptmd COA on 10/28/15 with staff
refhMmenta In 11'""
!All materials or wastes v.tlich might constitute a lire
hazard or v.tlich may be edible by or otherwise be
attractive to rodents or insects shall be stored outdoors
in accordance with applicable Slate Board or Health
Regulation-
i'fVater pollutionT in a case in which potential hazards
exist, ii shall be necessary to install safeguards
designed lo comply with the Regulations of the
Environmental Protection Agency before operation or
the facilities mall' bffin,
1\lel11me ef the seund geneFBled: i;:·,.eiy use shall lie se
epeialed lhat Ille velume ef seund inheFBAlly aAd
re61lfft!All-; geAeFaled dees ABI eMGBed 79 dB(t6o1) fRlm
7:00 P,M le 7:00 PM and 86 dB(A) lfem 7:00 PM te
7:00 P.M. Pis set feAh iA GOGGG RegulalieA 802(b),
the nei&e le~·el& shall lie &ubjeet le aA iAGrea&e bv 1 O
dB(A) fer a pefied nel le eMGBed 16 miAulee iA anv ene
I .. , .. _.Jl-~llll En. ..,briJI! ~ ,., .~ ... ...,, t"'-~...,_ ..-.:11n.o ...... ~ .......... ""' ... ~-I.IV -l" .., .........
pefiedie impulsi..,e neiee. G emplaiAI prete&ele shall lie
'io.~.,..,,..,_.,,..,,.. ~'li1A . .-. ... .-.
All lighting, except as demonstrated far ~fety r~!)Qn!!-,
shall be directed inward and downward and be shaded
in order lo prevent direct reflection on adjacent property in order to prevent direct renection on adjacent
and residences in the area. LED liohls will be used when property and residences in the area. LED lights will be
1pess1ble and_pcact1ca l.Wor!\ers wil l be advised wtien used when possible and pra ctical. Workers Wi ii be
moving hg ht.s!lants lo ensure that the l!nht 1s roe:!!~ ad111sed when mov ng light plants to ensure that the
direcn., on l he work being done . Most fiq ht inq will be lg ht 1s focused drreclly on the work be~o.!!.!!...M.o~
below Jhe..soµnd wall. Oril qg masJ li gt\tnll! tbaUs aboye fqhti!!IQ Wlllbe below the sound wall, Dnlling mast
!!.!!J!! sou~will be dO\Wlc:ast anc!/or sh 'elded to !:n!;lt M! that 1s above is the so11od wall 'Mii be downca$J.
reduce I U9:t1ve l iq hl outside sound wall and well pad. and/or shielded to reduce fugit ive lig ht outside sound
Safe !\!' cansiderat1oos wiJUake mecedence.-lw;ill and_"""ll n.•d. Safetv_considerat ons will take
crecedence .
The construction or the B Pad shall be limited lo the The construction of the B Pad shall be limited to the
hours of 7:00AM lo 7 -00PM. Wllh.Jbe exception.al hours of 7 -00AM to 7 :00PM, w th •he exception of
em ttu encies and epj!od1c events btyond Ursa·s controJ. eme!j!)ncies and episodic events bevo111q Vrsa ·s
Drilling may occur continuously 24 hours a day. Well conlro Drilling may oca.ir continuously 24 hours a day.
completion activity shall be lim"ed to occurring between en completion activity shall be 1:miled to occurring
1-ooAM and 7;00PM. Once the wells are in production, between 7 .00AM end 7 :00PM. Once the wells are in
vehicle trips to the pad shall be limited lo the hours or production, vehide trips lo the pad shall be limited to
7 .00AM to 7 ;00PM. with the exception of emergencies lhe hours or 7 ;00AM to 7 :00PM. with the exception of
and ef?!sod1c events beKond Ursa's con.!r2!. emeraencies and episodic eventsJ:>m:ond Ursa·s
control,
Page·3 of B
--..,
COAForBPad CommenCa I Diacuulon COA Alternative PC Adopted COA on 111121111& with Staff
...tlnem...ts In 11'""
11 The Applicant shall provide an accurate IOcation of Applicant indicated that Westwater will provide a Pnor to BOCC Hea.!!.!!3, the Applicant shall provide an ·---
the boundary of lhe adjacent wetland as identified in narrative describing the weUand boundary and accurate location of the boundary of the adjacent ,a66wrate lesatieA el Ille llewAllaFY el Ille alljaGeAI
the Westwater report. Once identified, the location of showing the pad location In relation to the wetland. wetland as identified in the Westwater report. Once 1wellaRd as ideRlifled iA Ille Weslwaler Fepelt. QRee
the B Pad (and any associated activity related lo the Staff believes this issue will easily be met and that we identified, the location of the B Pad (and any associated 1 idenli~ed, Ille leeatien el lhe B Pad (and any
development of the B Pad) shall be located al least 35 are simply awaiting the clarif1Cation report rrom the activity related to the development of the B Pad) shall be
1
asseeiated asli•;il}• related le the de.,.elepment el the B
feet back from the idenlir.ed weUand. consultanl Slaff is in agrement with the suggested located at least 35 feet back from the identified wetland. Pad) shall be 1esated at least as feet lloael1 lrel'I the
chanm &. ideAli~ed ~'l'BllaAd.
12 Corrosive soils in the vicinity of the B pad may be a Staff and the Applicant have agreed to the suggested O "'!rator will co~~•~ with COGCC Senes 1100 rules and Operator will comply with COGCC Series 1100 rules
limitation to construction; however, this lim~alion COA on the light that adequately accommodates the associated !iuidan~ which ~i ires aUeast one annual and associated guidance which requires at least one
should be able to be oven:ome with proper issue raised here by corrosive soils. messure test be nertormed. Qljeralor shall util11e onb: ,annual pressure lest be performed. Operator shall
engineering, design, and construction. Cathodic welded and fla !llled connections for all buried flowlines utilize only welded and flanged connections for all
protection for buried piping may reduce corrosion Jke A "'"''can.• skallbed and ·-~•art~ backfill flrn.Aines on buried flowlines. The Applicant shall bed and partially
resulting from salts in these soils !he Mt! With OQMlatlve backfill Jo ehmiate the corrosive backfill flo~ines on the pad with no~native backfill to
SOii concern. elimiate the corrosive soil concern. Qpe!ator will line a'I
flowline trenches with a bentomle I ner at least 6 inches
in deo1h .
13 The Operator shall use an effective and validated low Staff and the Applicant agree this may be deleted as it :J:he Qpereler Shall W&e an effe&liYe Bild °"alidaled lew lhe Qperelef shall wse aA e#eBli...e and ...alidaled leo;J
emissions. closed system. floW back process for all is a duplicate of COA 15. emissieAs, slesed system, lie'// bask preeeee leF aR well emissiens, elesed system. lie'// ba611 llRl&ess fer all
well comaletions on the B Pad.
.. ,-. -.. ........ ~~ ., --.
·~
14 Rather than routing production tank venting emissions After further research, both Staff and the Applicant Oe!i!!!1or sh ll1l !O!:!!!lliU with 1he ~DPH 5 msiulations and Operator shan comply with the CDPHE regulations and
through a voe combustor operated with auto-agree that VRUs are not the best technology lo air g uali ~ ~rmit cond1 l ions for em1ss1on controls air quality permit conditions for emission controls
igniters, the Operator shall use vapor recovery reduce air pollution and odors in the PUD. Emissions cons denn 11 techmca!!i': and economical!:t reas ble BMPs . considering technically and economically feasible
technology to further reduce air pollution and odors. do not necessarily mean odor.;. The dry nature of the BMPs.
natural gas in the Batuement Mesa Field is not
conducive to the use of VRUs. A VRU muld require a
well pad compressor which is an additional noise
source and a Vapor Recovery tower with a height of
30 feet or more, in addition to a combustor. The
combustor is fully enclosed, so ii does not have an
open flame like a flare. Per manufacturer's
specification, the combustor has a 98% efficiency
rating to reduce VOCs. The HIA draff was completed
in 2011. New technologies exceed the efficiencies of
VRUs.
15 The Operator shall comply with COGCC green The Applicant indicated it will continue to invesligate The Operator shall comply with COGCC green The Operator shall comply with COGCC green
completion practices and EPA's natural gas STAR
1
new technologies such es carbon filler packs, sealed completion practices and EPA's natural gas STAR completion practices and EPA's natural gas STAR
program to reduce voe emissions to the lowest level flowback tanks, additional pressure tanks in an effort program lo reduce voe emissions to the lowest level program to reduce voe emissions lo the lowest level
technically possible for the wells on the B Pad. to continually reduce odors. Add~ionally, Ursa will technically possible for the wells on lhe B Pad. technically possible for the wells on the 8 Pad.
uHlize carbon blankets over lh1Bf hatches on Additiona '!'i, the.t:E!l!JicanLco!ll.!Jl1ls Jo us1~ camon Additionally, the Applicant commits to using carbon
temporary tanks to minimize potential temporary b!agkels g~er tlli!lf Oi!lchi:s on 1J'lllm(lra!l( tanks to blankets over thief hatches on temporary tanks to
odors. Staff suggests modifying the COA to the righl reduce odors. The A llll!licant shall erovide an ~te 10 reduce odors. The Applicant shaU provide an update lo
the BOCC on ~gua~e ocbasis as 10 itS_jJSe of the latest the BOCC on a quarterly basis as to its use of the
12roven 1echnolggies to reduce em1ss1ons and odors on latest proven technologies to reduce emissions and
the well -""'. odors on the well ......i.
Page4 of 8
--.....
COAForBPad Commenta I DlscuuJon COA Altemdve PC Adoptitd COA on 10121/15 with SWf
............... In """
16 The Operator shall treat all inventories noxious weeds Ursa cannot be held responsible for -eds off of its Once construction begi ns, the Opera1or shall treat a tt Once construction begins, the Operator shall treat all
within the 30 meter survey area and pad site before disturbance. Battlement Mesa Partners and list A . B C noxious weeds with in pad site penme1er and Li st A , B C noxious weeds within pad site perimeter
October 31, 2015. Battlement Mesa Metropolitan District are responsible along access road according to Ursa 's noxious weed and along access road acconl1ng to Ursa's noxious
for weeds on their property until Ursa begins management plan Th·s sha ll include three treatments weed management plan. This shall include three
construction. Weeds should be sprayed by the annually by a licensed and certified herbicide a pplicator. trealments annually by a licensed and certified
property owners prior to October 31, 2015. Staff herbicide applicator.
agrees with this suooested chanoe.
17 The Operator shall commit to ensuring truckloads of Staff agrees with the suggested additional language The Operator shall commit to ensuring truckloads ol dirt, The Operator shall commit to ensuring truckloads al
dirt. sand, aggregate materials, drilling cuttings, and suggested by the App~canl In red to the righl sand, aggregate materials , dnlling cuttings, and similar d irt, sand, aggregate materials, drilling cuttings, and
similar materials are covered to reduce dust and PM materials are covered lo reduce dust and PM emcss10ns similar materials are covered to reduce dust and PM
emissions. duri no transoorL emi ssions durino lransDOrt.
18 The Operator shall install al least one UPilradienl and Staff and the Applianl have discussed this COA at The Operator shall install at least one UPilradient and The Operator shall install at least one UPilllild1ent and
two do'Ml.gradienl groundwater monitoring -us at length. Ursa indicated they are committed to install up two do'Ml.gradienl groundwater p1ezometer monitoring two dO'Ml.gradient groundwater piezometer monitoring
the B Pad location. The Operator shall conduct to two piezomeler monitoring -lls down-gradient of -ns al the B Pad location. The Operator shall conduct wells at the B Pad location. The Operator shall conduct
baseline sampling for, at a minimum, the following: all the BMC B pad. baseline sampling for, at a minimum. Iha following: all baseline sampling for. at a min·mum, the following. an
major cations and anions, total dissolved solids, iron, This is in addition to the 609 and 317B waler quality major cations and anions, total dissolved solids, iron, major cations and anions, total dissolved solids, iron,
manganese, nitrates, nitriles, selenium, benzene, monitoring required by COGCC and CDPHE. Staff is manganese, nitrates, nitrites, selenium, benzene, manganese, nitrates, nitrites. selenium. benzene,
toluene, ethylbenzene, xylenes, methane, pH, specific in agreement that piezometes may be used in lieu of toluene. ethylbenzene. xylenes, methane, pH, specific toluene, ethylbenzene, xylenes, methane, pH . specific
condudance, and any chemical Identified in the full -11s, however, Staff recommends the COA remain as condudance, and any chemical identified I n the fuU conductance, and any chemical identified In the full
disdosure of chemicals of potential concern. written with further explaination of the piezomeler disclosure of chemicals of polenbal concem. di sclosure of chemicals of potential concem to Gai:field
nmoram as described in Exhibit HHH . Countv.
19 The Operator shall conduct monthly monitoring of the The Applicant is i n agreement with this COA as well The Operator shall conduct monthly monilonng of the
-11 site groundwater wells for the parameters as committing to an emergency water supply required -11 site groundwater wells for the parameters
specified in condition of approval No. 18 during -11 as a new COA below. The frequency of samples will specified in condition of approval No. 18 during -11
drilling and completion activities, followed by annual be relined (Monthly or quarterly sampling), etc. prior to drilling and completion activities, followed by annual
monitoring for the duration of the project All results of the BOCC. monitoring for the duration or the project All results of
this monitoring shall be provided to the Garfield thi s monitoring shall be provided to the G111fleld County
County Community Development Department and Oil Community Development Department and Oil and Gas
and Gas liaison within 60 days of sample collection Liaison within 60 days of sample collectlon and posted
and posted on Garfield County's -bsile. It (1) on Garfield County's -bsite. If (1) benzene, ethyl
benzene, ethyl benzene, toluene, or xylenes are benzene, toluene, or xylenes are detected al levels
detected at levels greater than Iha concentration grealer than the concentration levels specified in Table
levels specified in Table 910-1 of the COGCC rules; 910-1 or the COGCC rules; (2) any cations, anions,
(2) any cations, anions, metals, or total dissolved so melals. or total dissolved so lids exceed 1.25 limes
lids exceed 1.25 limes background concentrations; (3) background concentrations; (3) methane or any
methane or any chemical Identified as a eoncem from chemical identified as a concern from the full
the full disclosure of chemicals exceeds 1.25 disdosure of chemicals exceeds 1.25 background
background concentrations; or (4) if pH or specific concentrations; or (4) ii pH or specific conductance
conductance exceeds the limits specified In COGCC exceeds Iha limits specified in COGCC table 910-1 , the
table 910-1 , the Operator shalt invnediatety remediate Operator shaU immediately remediate the concem as a
the concern as a condition of the Special Use Permil condition of the Special Use Pennil
Page5of 8
COAForBPad <:--a I Dl9CU981on COA Alt8matiw PC Adopted COA on 1111281111 with staff
refinements In .....
20 Prior to a recommendation by the Garfield County •Ursa is in the process ol implementing an ol)-Cllfl PlieF le a m;emmeRdalieR ~Ille Gaffield Ge11Rly
Planning Commission, the Operator shall develop a complaint notification system acceptable lo the PlaRRiRg Gemmi&&ieR , Ille QparateF &llall d&\lelep a
more lonnalized 24n fast-action complaint receipt Garfield County Oil and Gas Liaison. mere fermaliad :!4.11 lasl aelien eemplalRI FeoeipHRG-
and response program that will ensute tesidenls have •A copy of Ursa's inlemal Incident Notification respanse pFegraFA tllal iMll en&11re 1e&ident& ha~e
immediate access to report and begin resolution of Protocol and Complain! Form are included with this imFRed iate a66e&s la 1epef4 aRd llegiR FO&ehltien el
nuisance or safety issues that may arise. submittal. nuisaflse e1 salely iss11es that may arise.
21 Prior to a recommendation by the Garfield County •Ursa has performed a site specific sound analysis for PlieF le a 1eeemmenllatieR II)' Ille Gaffield GeuR~•
Planning Commission, the Operator shall the BMC B pad to determine how to keep sound with in PlaRRiRg Gemmi &&ieR. Illa QperaleF &llall demeR&tiate
demonstrate a thorough researching or current acceptable limlts. Ursa and their sound consultant are a lllen111gh 1e&eaR;hing el &11Ffenl le&hRelegie&
technologies available to control emissions and odors investigating modifications of the sound wall, sound a11ailallle le eenlrel emis&iens and edef!l lof..all-
for all operational phases contemplated lor the blankets, and other sound mitigation technologies to eperalieRal pllasea &eRlemplaled leF Ille pFepeeed
proposed locations and dearly describe mitigeilions achieve the Light Industrial sound levels at 350 feet leealien& and sleaity de1161ille mi~galieR9 aRd BMFle
and BMPs considered most optimal and feasible to rrom sound sources during all phases of construction, sen&iderell me&I ef!lifflill end leasibla te preYefll-
prevent Impacts to nearby residents. drilling, and completions. impa61s te Aaaitiv FesideRt9 .
•Ursa wiU continue to investigate new technologies
such as carbon filter packs, sealed flowback tanks,
addltional pressure tanks in an effort to continually
reduce odors.
•Ursa will uliliZe carbon blankets over thief hatches on
temporary tanks to minimize potential temporary
odors.
•Ursa wiQ use LED lights that are shielded and/or can
be rocused directly on the work at hand.
•These are just a few of the technologies that Ursa is
utilizing to mitigate possible nuisances from its
operations. Ursa will continue to respond to
complaints wilh the best technology practically
feasible.
22 The Operator shall provide a formal update to the •Updates will begin at the beginning or construction The Operator shall provide a formal update to the
Board of County Commissioners on a quarterly basis and continue throughout drilling and completion Board of County Commissioners on a quarterly basi s
as to the progress of the project. This update shall be operations and cease once the pad is In lull as lo the progress of the project , includ na but not
coordinated through the Community Development production operations. l imited to advancement and utihza11on of odor and
Department specifically induding the Oil and Gas em1ss1ons tecbool?!ll. This update shall be
liaison's off ice. coordinated through the Community Development
Department specirically including the Oil and Gas
liaison's Office. U(!Qates shall ~in at the beginni!!!I of
construction and continue throyghoul dnl11ng and
comnletion noeratsons and cease once the na d ,. m fun
lot oduct1on ooe rations.
Page 6of 8
,.-...., -....
COAFotBPad c-m. I oi.c:u.slon COA Allernetlw PC Adoptad COA on 10121115 with st.ff
rwftnementa Ing-
23 No Special Use Permit shall be issued to the The Applicant suggests that Ursa will obtain the No Special Use Permit shall be issued to the I No Special Use Permit shall be i ssued to the
/\pplicant/Operator (and no activity shall occur on the I required Air Quality al the appropriate time i n Applicant/Operator (and no activity shall occur on the A pplicant/Operator (and no activity shall occur on the
s~e) until all required local , state and federal permits accordance with CDPHE regulations. Due to the site) until all required local, state and lederal petmils ,site) until all required local, stale and federal permits,
have been obtained and tendered to the County nature of that stale penntlting process. Staff is in exce11t !!:\QS!l M !!Il'!s \'8llcll are ob!a O!!SI !!!lb: afte[ eKcept those permits which are obtained only aner
Community Development Department. A violation of agreemnt with the sugested changes. construction is co.!!!.l!lele, have been obta ined and construction is complete, have been oblained end
any of the terms and/or conditions of these local, tendered lo the County Community Development tendered to the County Community Development
stale and federal permits shall also be considered a Department. A violalion ol any of the terms and/or Department. A violation ol any ol the terms and/or
violation ol the Special Use Permit. ' conditions of these local, stale and federal permits shall conditions of lhese local, stale and lederal petmils
1
also be considered a violation of the Special Use Permit. shall also be consi dered a violation of the Special Use
llTh1> A•r nuat 1v --11 ~hiifl hA ~11bm1ttP<i es ~nnn A~ 11 is Permit The Air Quality permit shall be submitted as
1rece1ved 'soon as it is received.
24 Prior to a recommendatJon by the Galfield County •A copy of the revised Drainage Report with Prior lo a recommendation by the Galfield County Plior to the the issuance ol 1he §fl!lc1al !.,!se Permit a-
Planning Commilllion, the Applicant should provide a calculations is induded in this submittal. Planning Commission, the Applicant should provide a reGGmmend~~~anntflg-
discussion. calculations. and details for the proposed •Delenlion ponds and stormwater are not subject to discussion, calculations, and details for the proposed Gomm+SSIOO, the Applicant should provide a
release strudures from the detenbon pond. Release SPCC rules. , ~lease structures from the detention pond.~eleH&-discussion, calculations, and details for the proposed
from the detention pond may need to comply with the release structures from the detention pond.
r""uiremenl5 ot the SPCC. '--~~ 25 Prior to a recommendation by the Garfield County Slaff has reviewed this COA with the Applicant and The O""rator will .,rovide a dralt s.te s ...... 1ric SPCC nLtn The Operator IMll provide a dralt site specific SPCC
PlaMing Commission, the Applicant should will agreed to a slighUy revised COA based on lor Pad B within 30 da:il! of 1nstiinahon of tank plan for B Pad within 30 days ot instadalion ot tank
provide the site specific SPCC plan for Pad B. The dariticalions provided in the existing SPCC Plan and containment structute~eD1to_r._shall_t!rOv1118 a_ containment structures. The Operator shaU provide a
!Applicant should provide add~ional infonnallon on Ille the nature of the State permitting process. final site s :>eciric SPCC ~an for the BMQ 8 wells ead final site specific SPCC plan for Ille 8 Pad wells pad
storage tank sizes, how those tanks are to be within srx months of 1nstanat1on of the tank s;2ntarnment within six months of installation ol the lank containment
inlerconnected, the vol ume of secondary containment structures err E~lattons.]'he.srte_s,pe<";lic.plaQ structures per EPA regulations. The site specir1e plan I to be provided indudrng precip1lallon, the anticipated shall include 1nformati!;!n on ~tor!!!)e tank ~l~e2 iind the shall indude information on storage tank siZes and the 1
leak detection, and how the precipitation events \Wuld ~lume gl ~eco!ldi!!:i! conta1nmeot i~ ~IS:!!li!!!!S! volume of secondary containment is calculated. !
be safely drained from the secondary containment.
26 Because the B Pad area is not nat and located some Th Applicant provided a relined nolse analysis BeGause IAe 8 Pad aFea is net llal ;me looated some Besause Ille B Pad area is nel llal and lesaled same
200 feel below a residential neighborhood unlike the performed by Behrens and Associates that ·---. ·-•Lo.-~gg feel belew a resieential neigllbaltleed unlike Iha ,;a-n11-~:_n1 Ridg-e Pad leGalieA , Staff is r~ monument Ridge Pad location, Slaff is reque$tlng a 1dernonstrates the noise expected to be generated at meA11meAI Ridge Pad lesalien, Slaff Is Feq11es1ing a
more relined noise analysis that is more ta~ored to lthe 8 Pad with mitigatioo during both drilling and his-maR! refiAed neise analysis lhal ia meFe lailerell le lhis
this localion prior to a recommendation by the -. ... -lesatieA 11liaf te a FE1semmeAdalien by Iha PlanniAg 1
1
completions can not only meet the suggested Light ,1_ . .• . ·-~-tlanning Commission that addresses this unique tnduslrial standard at 350 feet, but also appearas to
ieASUFe naise mt1galian Gan be s11ooe&&l11I.
GemmissieR lhal addFaHes lllia wniqwe GiA;Um&lansa
,circumstance to ensure noise mitigation can be meet or exceed the TOWl'I or Erie's BMPs with Encana. le eA&llFe Reise miligatien san be sueseaskll.
succes$ful. This COA can be deleted. i
Page7 of 8
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COA FOi' B Pad eomm.nts I 1>19c...tan COA AlterNtlve PC Adopted COA on 10128115 with Staff
' reflnementll In gran
27
1
Regarding air quality, the Operator shall design and The Applicant is reluctant to commit to an air quality Regarding air quality, Ille Qperaler Garfield County
implement an air quality monitoring program at the montoring program as suggested in this COA. During shall design and implement an air quality monitoring
well pad (locused on voe collection) prior, during and discussions. Garfield County provided a proposal to program al the well pad (locused on voe colledion)
after the drilling and completions are complete to Ursa which will be presented at the October 28th prior, during and alter the drilling and completions are
better understand air emissions at the source. hearing. The Applicant indicates there is not a need complete to better understand air emissions at the
lor site specific air monitoring based on prevention source. This erQSram will include 1he eurchase of
practices including tR camera surveys, AVO surveys, imon •1J)rin n nt:ui ~""en\ samnt1nn even's anr1 consultant
and newly implemented CDPHE regulations regarding assistance with eg,u~nt.J;!acement~..l!.st.!!L
aut<>-igniters. monthly emissions monitoring, etc. samol n a and samnle ana ~s1s and total momtonna
Ursa requests that Garfield County consider site duration Wlth a total cosl not to exceed ~50 ooo to be
speciric air dispersion modeling in lieu or site specific funded b't the Applicant.
air quality monitoring. Staff recommends this COA
remain and suggested.
28 Prior to approval by the Board or County Prior to construction, appRl\'al by Ille BeaRI el Ge11Rly
Commissioners, the Applicant shall design a Cemmi&&ieReF& , the Applicant shall design a proposed
proposed aHemative physical water intake system for alternative physical water intake system for pulling
pulling water from the Colorado River up river from water lrom the Colorado River up river rrom the B pad
the B pad location to add as an alternative water location to add as an aHemative water supply in the
supply in the event of a sp~I reaching the Colorado event of a spill caused by the Applicant reaching the
River at of near the existing intake. Colorado River at ol near the existing intake.
29 Applicant agrees and commits to a three year time !Applicant agrees and commits to a three year lime
lrama ror Phase I activities. This time frame will frame for Phase I activities which includes placing up to
commence al the start of cobslruction of either Phase 53 wells into run prodiction. This lime frame will
I well pads or pipeline, and ends with the placement commence at the start of construction of either Phase I
of the last well (of 53 weUs) being placed into full ~II pads or pipeline.
.._ production. -
Page 8of 8
. ..-.....
EXHIBIT
1eet i.
COA For D Paci Comnl9nts I Dtscuulon COA Aitem.tive PC Adot*d COA on 1012111& with staff rwlhMnlenU
In..._,
3 Thal all represenlalions ol the Applicant, either in testimony Thal all represenlalions ol lhe Applicant, either in
or the submitted application materials, shaU be considered lestimony or the submitted application materials, shall be
conditions ol approval unless specifically allered by the considered condffions ol approval unless specifically
Boan! ol County Commissioners. altered by the Board of County Commissioners.
4 If fulure extraction and processing activity (additional to II ruture extraction and processing activity (additional to
whal is being permilled herein) would be proposed, an whal is being permitted herein) would be proposed, an
amended Special Use Permit shall be required prior to lhat amended Special Use Permit shall be required prior to
activilv occurrin11 on the site. thal actillitv occurrin11 on the sile.
5 The Operalor (URSA) acknowledges thal the County has The Operator (URSA) acknowledges lhal the County has
performance slandards in place that could read to performance standards in place that could lead to
revocation of the Special Use Permit ii violations ol the revocation of the Special Use Permit if violations of the
ll>Brmit occur. oermil occur.
6 Operation or the lacility must be in accordance with all Applicant suggests adding the langauge in red (on Operation of the lacility must be in accordance Operation of the lacility must be in accordance with an
Federal, State and local regulations and permits governing the right). Staff disagrees and suggests it remain as with an Federal, State and local regulations and Federal, State and local regulations and permits
the operation or this facility. it is lanugae directly from the land Use and permits governing the operation of this facility.~ governing the operation of this facility.
Development Code of 2013. Any change to COAs CO!Jflicis belwee!]_Q arfjeld !;ioun ~ a!Jd federal ,
adopted by the Board of County Commissioners that state, and JocaJ lltrm1t conditions of a Gf!rov~Wil l
are to be modified currently requires a public r Q51u1re resolution between the ,l!Jenc1es and lhe
hearing before the BOCC so a formal process is Operator
available to manage that conmct.
7 The County commits to notifying the operator of any Staff suggests rewording this COA such that the The County commits to notifying the operator ol The County commits to notifying the operator of any
compliance concern and allows an inspee1lon with site County will be allowed lo contact other permit any compliance concern. This may include direct compliance concern. This mav include direct notice by
personnel and the designated County inspector prior to agencies ii the need anses before any site visit with notice by Garfield County to other effected Garfield Counly to other affected permitting agencies ii
conlacting any other permitting agency. the operator. permitting agencies if necessary depending on the necessary depending on the compliance concern.
comoliance concern.
8 The County can request a site inspection with one calendar The County can request a site inspection with one
day's notice to the Operator. Full access lo anv part of the calendar day's notice to the Operator. Full access to any
site will be granted. On request, all papelWOrk must be part of the site will be granted. On request. all paperwork
shov.n. The County cannot request a large number or must be shO'Nll. The County cannot request a large
inspections that would interfere with normal operation number of inspections that would interfere with normal
without cause. operation without cause.
9 All extraction and processing activities shall be required to All extraction and processing activities shall be required
comply with the lollowing performance standards: to comply with the following performance standards:
Page 1 ore
,,-...
COA For D Paci Comments I DIKllAlon COA Altematlw PC Adopt9d COA on 10121115 with staff refinements
lnarHn
(1) Volume of the sound generated: every use shall be so Start suggests this COA be replaced in lull with the Volume of the sound generated: Every use sha ~ Volume of the sound generated: Every use shall be so
operated that the volume of sound inherently and suggested COA to the right Essentially, the be so operated that the volume or sound inherently operated that the volume of sound inherently and
recurrently generated does not exceed ninety (90) decibels COGCC rule is more stringent; moreover, the and recurrently generated does not exceed 70 recurrently generated does not exceed 70 dB(A) from
(or COGCC rule, whichever is more stringent), with a Applicant has demonstrated that they can meet or dB(A) rrom 7:00 AM to 7:00 PM and 65 dB(A) from 7:00 AM to 7·00 PM and 65 dB(A) from 7:00 PM to 7:00
maximum increase or five (5) decibels permitted for a exceed the Light Industrial threshold of 70 DB(A) 7:00 PM to 1·00 AM . measured 350 feet lrom the AM, measured 350 feet from the edge of the pad. As set
maximum of fifteen (15) minutes in any one hour, at any during the day and 65 dB(A) during the night at 350 edge of the pad. As set forth m COGCC forth In COGCC Regulation 802(b), the noise levels shall
point of any boundary line or the property on which the use feet from the pad with mitigation. Exception Regulation B02(b), the noise levels shall be subject be subject lo an increase by 10 dB(A) for a period not lo
is localed. langauge allowed by the COGCC (and the Town of to en increase by 10 dB(A) for a period not to exceed 15 minutes in any one (1) hour period and cannot
Erie) is included as well. exceed 15 minutes in any one (1) hourpenod and exceed 65 dB(A) for shrill or periodic impulsive noise.
cannot exceed 65 dB(A) for shrill or periodic Complaint protocols shall be govememed by COGCC
impulsive noise. Complaint protocols shall be Rule 802(c);
aovememed bv COGCC Rule 8021cl .
(2) Vibration generated: every use shall be so operated that Vibral!On generated : every use shall be so operated that
the ground vibration inherently and recurrently generated is the ground vibration inherently and recurrenUy generated
not perceptible, without instruments, at any point of any is not perceptible. without instruments, at any point of
boundary line of the property on which the use is located; any boundary line of the property on which the use is
located;
(3) Emissions of smoke and particulate matter: every use shall Emissions or smoke and palllculate matter: every use
be so operated so as to comply with all Federal, State and shall be so operated so as to comply with all Federal,
County air quality laws, regulations and standards; State and County air quality laws. regulations and
standards:
(4) Emission of heat, glare, radiation and fumes: every use Emission of heat. glare, radiation and fumes : every use
shall be so operated that it does not emit heat, glare, shall be so operated that it does not emit heat. glare,
radiation or fumes which substantially interfere with the radiation or fumes which substantially interfere with the
existing use of the adjoining property or which constitutes a existing use of the adjoining property or v.tltch constitutes
public nuisance or hazard. Flaring of gases, aircraft a public nuisance or hazard. Flaring of gases, aircraft
warning signals, reflective painting of storage tanks, or warning signals, reflective painting of storage tanks, or
other such operations which may be required by law as other such operations v.tlich may be required by law as
safety or air pollution control measures shall be exempted safety or air pollution control measures shan be
from this ""'Vision: exempted from this orovision;
(5) Storage area. salvage yard, sanitary land-fill, and mineral Storage area, salvage yard, sanitary land-fill, and mineral
waste disposal areas: waste disposal areas:
(a) Storage or flammable, or explosive solids, or gases, shall Storage of flammable, or explosive solids, or gases, shall
be in accordance with accepted standards and laws and be in accordance with accepted standards and laws and
shall comolv with the National Fire Code; shall comolv with the National Fire Code;
(b) At the discretion of the County Commissioners all outdoor At the discretion of the County Commissioners all
storage facilities for fuel, raw materials and products shall outdoor storage facilities for fuel, raw materials and
be enclosed by a fence or wall adequate lo conceal such products shall be enclosed by a fence or wall adequate
facilities from adiacenl orooertv; to conceal such laciliUes rrom adiacent orooertv:
(c) No materials or wastes shall be deposited upon a property No materials or wastes shall be deposited upon a
in such form or manner that they may be transferred off the property in such lorm or manner that they may be
property by any reasonable foreseeable natural causes or transferred off the property by any reasonable
forces · foreseeable natural causes or forces : and
Page2 of B
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COA For D Pad I Dlacuaalon COA Alternative ~PC Adopted COA on 10l28/15 with Staff refinements
ln •rHR
(d)' All materials or wastes which might consti!Ule a fire hazard All materials or wastes which might constitute a fire
or which may be edible by or otherwise be attractive to hazard or which may be edible by or otherwise be
rodents or insects shall be stored outdoors in accordance attractive to rodents or insects shall be stored outdoors in
~h applicable State Board of Health Regulation; accordance with applicable State Board of Health
RH ulation.
(6) Water pollution: in a case in which potential hazards exist, Water pollution: in a case in which potential hazards
it shell be necessary to install safeguards designed lo exist. ii shall be necessary to install saleguards designed
comply with the Regulations of the Environmental to comply Yllilh the Regulations of the Environmental
Protection Agency before operation of the facilities may Protection Agency before operation of the facilities may
beoin. beoin.
10 All lighting, except as demonstrated lor safety reasons, Staff agrees Yllilh the suggested additional language All lighting, except as demonstrated for safety Alt lighting, except as demonstrated for safel)t rusons,
shall be directed inward and downward and be shaded in suggested by Iha Applicant in red to the right. reasons, shall be directed inward and downward shall be directed inward and downward and be shaded in
order lo prevent direct rellection on adjacent property and and be shaded in order lo prevent direct reflection order lo prevent direct reflection on adjacent property
residences in the area. on adjacent property and residences in the area. and residences in the area. LED lights will be used when
LED li.J hls will be used Mien ll!Ssi hle and possible and practical. Workers Yllill be advised when
11 ractical .Wo11<ers will be advised wtieo.movi ag moving light plants to ensure that the light is focused
!i!J h! 13l anis !O ensure !ha! lh!! li!Jtl! i~ r~u~ed directly on the work being done. Most lighting will be
directll( on the \',{)rk be!!!:!! done. Most t!g htin3 will below the sound wall. Drilling mast lighting that is above
be below the sound wall. Drilling: mast ~g ht i !l!l 1hat is the sound wall will be downcast and/or shielded lo
1s above 1s the sound wall will be downcast andlor reduce fugitive light outside sound wall and well pad.
sh1elde ~uce fu ;i1t1ve ~hi outside~sou ud_wa l!. Safety considerations Yllill take precedence.
fl!ld wel!..Efill . Safe=t considerations Wi!Uat~
Drecedence .
11 The construction of lhe D Pad shall be flmited to the hours The Applicant has suggested that it needs the The construction of Iha B Pad shall be limited to The conslruction or the B Pad shall be limited lo the
of 7:00 AM to 7:00 PM. Drilling may occur continuously 24 Rexability lo be able lo address emergencies at any the hours of 7:00AM lo 7:00PM with the exr-11on hours of 7:00AM to 7:00PM, with the exception of
hours a day. Well completion activity shall be limited to hour for the safely of the community and workers. of ememencies and e11isodic events be:i:ond emergencies and episodic events beyond Ursa's control.
occurring between 7:00 AM and 7:00 PM. Once the wells Additionally. it also needs to be able lo safely Ursa s con trol. Drilling may occur continuously 24 Drilling may occur continuously 24 hours a day. Well
are in production, vehicle trips to the pad shall be limited lo complete and slop activities when unforeseen hours a day. Well completion activity shall be completion activity shall be limited lo occurring between
lhe hours of 7 -00AM to 7 :00PM. events occur. Ursa Yllill communicate with Garfield limited lo occurring between 7:00AM and 7:00PM. 7:00AM and 7:00PM. Once the wells are in production,
County and Community Counts as soon as possible Once the wells are in production, vehicle trips to vehicle trips lo the pad shall be limited to the hours of
when these unforeseen events occur. Staff agrees the pad shall be limited to the hours of 7 :00AM lo 7:00AM to 7 .OOPM, with the exceplion of emergencies
Yllith these suggestions on the right in red. 7:00PM , with the exce ehon of ememencies and and episodic events beyond Ursa's control.
e~i sod1c events bevcnd Ursa s control,
12 Corrosive soils in Iha vicinity of the D Pad may be a Staff and lhe Appficant have agreed lo the ~will ~th COGCC_Senes_1.1QQ. Operator Yllill comply Yllith COGCC Series 1100 rules and
limitation to construction; however. this limitation should be suggested COA on the right that adequately rules and associated 11 uidance Ml1ch reg uires at associated guidance which requires al least one annual
able lo be overcome Yllith proper engineering, design, and accommodates Iha issue raised here by corrosive least one annual 2ressu~ tesLbe.:Mdo!!:!:!e!!.. pressure test be performed. Operator shall utilize only
construction. Cathodic protection for buried piping may soils. Q ~[!!!Ot ~bl!I! !.Jlili~~ O!J·~l~d and l!il:l!l!ld 1welded and flanged connections for all buried flov.fines.
reduce corrosion resuhing from sans in these soils i
connections for all buried newlines The AlJEl1cant The Applicant shall bed and partially backfill fk>Y.1ines on
I
shall bed and eart1al!Y: backfill Hov.1 nes on the ead the pad with non-nalive backrdl lo elimiale the corrosive
)!!!lb oon-na\ive_backfill to elimiate the corrosive soil concern. Q.£P.rator_will llne_all_Hov.11n~c:Qe~
!OL_com:£.!!l_ benlonite liner at least 6 inches 1n del!lh
Page 3 of B
COA For D PH Comments I Dl.cllHlon COA Altemlltive PC Adopted COA on 10128115 with stllff 1'9finements
1n-
13 The Operator shall use an· elfeciive and validated low Stalf and the Applicant agree this may be deleted as The Operator sllall .. se an etteGti~e and ¥alidatea ~ ...
emissions, closed system, llow back process ror all well it is a duplicate of COA 1 S. ~em-llew eack preooss ~~
l;l)mDletions on lhe o Pad. _q y -~~ ~.........&M-"""~~
14 Rather than routing production tank venting emissions 11.fter further research, both Slalf and the Applicant O ....... ator shall comn;v \'.\th the C Df>l-IE t~"la\1ons Operator shall comply with lhe COPHE regulations and
through B VOC combuslor Operated with aut~ignilers, the agree thal VRUs are not the best technology lo and a.!!,a!!ali~ !jlermil cond1t1ons for emiss..!2!!.. air quality pemiit ccnditions for emission controls
Operator shall use vapor reccvery technology to further reduce air pollution and odors in Iha PUD. controls CO!}Sideri1U1 te£!:!n1ca !!'J: and econolTl!ca!Ji: ccnsidering technically and economically feasib• BM~.
reduce air pollution and odors. Emissions do not necessarily mean odors. The dry feasible {!MPs.
nalure of the nalural gas in the Battlement Mesa
Field is not conducive to the use of VRUs. A VRU I
1Wuld require a well pad compressor which is an
additional noise source and a Vapor Recovery tower
with a height or 30 feet or more, in addition to a :
combustor. The combustor is fully enclosed, so it
does not have an open flame like a flare. Per
manufacturer's specification, the combustor has a
98% efficiency rating to reduce voes. The HIA draft
was completed In 2011. New lechnologies exceed
the efficiencies of VRUs.
1 s The Operator shall comply with COG CC green ccmpletion The Applicant indicated it will continue to investigate The Operator shall comply with eoGeC green The Operator shall ccmply wilh COGCC green
practices and EPA's natural gas ST AR program to reduce new technologies such as carbon filter packs, completion practices and EPA's natural gas STAR completion practices and EPA's natural gas STAR
voe emissions to the lowest level technically possible for sealed nowback lanks, addilional pressure lanks in program lo reduce voe emissions lo the lowest program lo reduce voe emissions to the lowest level
the wells on the 0 Pad. an effort to continually reduce odors. Additionally, level technically possible for the wells on the D technically possible for the wells on the B Pad.
Ursa will utilize carbon blankets over thief hatches Pad. Additiona~ ,l\ruiticanl . comm1 1s l o usin lJ Additionally, the Applicant commits to using carbon
on temporary tanks to minimize potential temporary , carbon blankel s over l h1e[ ha lches on tem [12ra~ ·blankets over thief hatches on temporary tanks lo reduce
odors. Start suggests modifying the COA to the tanks 10 reduce odors !he 111111r1cant shall 11rov1de odors. The Applicant shall provide an update to the
'righl an u11Qale lo l he BQCC on 3 guartert:t basis as to BOCC on a quartelly basis as to its use of the latest
I its use o t the latest ll!!1;Ven 1echn2!2g 1es to r~d uce proven technologies lo reduce emissions and odors on
~ns and . .£dors on !he well.J:!!'d c the well pad.
16 The Operator shall IR!at all inventories noxious weeds Ursa cannot be held responsible for weeds olf ol its Once construction begins, the Operator shall treat Once construction begins, the Operator shall treal all List
wilhin the 30 meter survey area and pad site before disturbance. Battlement Mesa Partners and all list A, B C noxious weeds within pad site A, B C noxious weeds within pad site perimeter and
October 31, 2015. The Applicant is enccuraged to manage Battlement Mesa Metropolitan District are perimeler and along access road according lo along access road according to Ursa's noxious weed
the cheatgrass this fall, within the 31kneter survey area responsible for weeds on their properly until Ursa Ursa's noxious weed management plan. This shall management plan. This shall lndude three treatments
and pad site, as mid-Seplember through October is a very begins construction. Weeds should be sprayed by include three treatments annually by a licensed annually by a licensed and certified herbicide applicator.
effective time of year lo !real this weed. the properly owners ptiorto October 31, 2015. Staff and certified herbicide applicator.
1 .... rees with this su1ttt"llled chana e.
17 The Operator shall convnit to ensuring truckloads or dirt, St.all agrees with the suggested additional language The Operator shall commit to ensuring truckloads The Operator shall commit to ensuring truckloads of dirt,
sand, aggregate materials, drilling cuttings, and similar suggested by the Applicant in red lo the right. of dirt, sand, aggregate materials. drilling cuttings, sand. aggregate materials, drilling cuttings, and similar
materials are covered lo reduce dust and PM emissions. and similar materials are ccvered to reduce dust materials are covered to reduce dust and PM emissions
and PM emissions dunn-3 transl!!lrl. during transport.
Page 4 or 8
,..-.,, ...... ._
COAForDPad Comments/~ COA Altematiw PC Adopted COA on 1012111 & with SUff niflllltllltlflts
lna19M1
18 The Operator shall install at least one up-gradient and two Staff and the Appliant have diset.1ssed this COA at The Operator shall install at least one up-gradient The Operator shall install al least one up-gradient and
down-gradient groundwater mon~oring wells at the D Pad length. Ursa indicated they are commiHed to install and two down-gradient groundwater R'.!'mn>ntf:r two down-gradient groundwater piezometer monilo1iflg
location. The Operator shall conduct baseline sampling for, up to two piezometer monitoring wells down-gradient monitcring wells et the B Pad location. The wells at the B Pad location. The Operator shall conduct
at a minimum, the lollowing: all major cations and anions, ol the BMC B pad. Operator shall conduct baseline sampling for, at a baseline sampling for, at a minimum, the following: an
total dissolved solids, iron, manganese, nitrates, nitrites, This is in addition to the 609 and 3178 waler quality minimum, the following: all major cations and major cations and anions, total dissolved solids. iron,
selenium, benzene, toluene, ethylbenzene, xylenes, monitoring required by COGCC and CDPHE. Staff is anions, total dissolved solids, iron, manganese, manganese, nitrates. n~rites, selenium. benzene,
methane, pH. specific conductance, and any chemical in agreement that piezometes may be used in lieu of nitrates, n~rites, selenium, benzene, toluene, toluene, ethylbenzene, xylenes, methane, pH, specific
identified in the full disclosure of chemicals of potential wells, however, Staff recommends the COA remain ethylbenzene, xylenes, methane, pH, specific conductance, and any chemical identified in the full
concern. as written with rurlher explaination of the piezometer conductance, and any chemical identified in the full disclosure of chemicals of potential concern to Garfield
program as described in Exhibit_. disclosure of chemicals or potential concern. ~y
19 The Operator shall conduct monthly monitoring or the well The Applicant is in agreement with this COA as well The Operator shall conduct monthly monitoring of the
site groundwater wells for the parameters specified in as commiHing to an emeigency water supply well site groundwater wells ror the parameters specified
condttion ol approval No. 18 during well drilling and required as a new COA below. The rrequency of in condition of approval No. 18 during well drilling and
completion activities, followed by annual monitoring for the samples will be refined (Monthly or quarterly completion activities, followed by annual monitoring for
duration of the project All results or this monttoring shall be sampling), etc. prior to the BOCC. the duralion of the project AH results of !his monitoring
provided to the Garfield County Community Development shall be provided to the Garfield County Community
Department and Oil and Gas liaison within 60 days ol Development Department and Oil and Gas Liaison within
sample collection and posted on Garfield County's website. 60 days of sample collection and posted on Garfield
If (1) benzene, ethyl benzene, toluene, or xylenes are County's website. If (1) benzene, ethyl benzene, toluene,
detected at levels greater than the concentration levels or xylenes are detecied at levels greater than the
specified in Table 910-1 of the COGCC rules; (2) any concentration levels specified in Table 910-1 of the
cations. anlDl'ls, metals, or total dissolved so lids exceed COGCC rules; (2) any cations, anions, metals, or total
1.25 times background concentrations; (3) methane or any dissolved so lids exceed 1.25 times background
chemical identified as a concern from the full disclosure or concentrations; (3) methane or any chemical identified as
chemicals ellceeds 1.25 background concentrations: or (4) a concern from the full disclosure of chemicals exceeds
if pH or specir.c conductance exceeds the lim"s specified in 1.25 background concentrations; or (4) if pH or specific
COGCC table 910-1, the Operator shall immediately conductance exceeds the limits specified in COGCC
remediate the concem as a condition or the Special Use table 910-1, the Operator shall immediately remediata
Permil the concern as a condition of the Special Use Perm~.
20 Prior to a recommendation by the Garfield County Planning •Ursa is in the precess of implementing an on-call ~~eF ~e a ~esem~~AlfatieA ~~ Ille Gaffie~lf GewAty
Commission, the Operator shall develop a more formalized complaint nolirication system acceptable to the -
g
24'7 fast-action complaint receipt and response program Garfield County Oil and Gas Liaison. lefff!alii!elf 2417 fasl a6tieA semplaiAI FeGeipl eAll
that will ensure residents have immediate access to report •A copy of Ursa's internal Incident Notification fe&J19A&e JIF9!fRIRI lllal will 8R6WflJ FesilfeAt& llaYe
and begin resolution of nuisance or safety issues that may Protocol and Complaint Form are included with this immediate aooeee le Fepeft aRll begin reselu~eA ef
arise. submittal. . ....
Page 5 ol B
COAFCll"DP.cf Comments I Dl9c:11Wlon
21 IPrior to a recommendation by the Garfield County Planning •Ursa has performed a site specific sound analysis
Commission, The Operator shall demonstrate a thorough lor the BMC B pad to determine how lo keep sound
researching of current technologies available to control within acceptable limits. Ursa and their sound
emissions and odors ror all operational phases consultant are investigating modifications of the
contemplated for the pmposed locations and dearly sound wall, sound blankets, and other sound
describe mitigations and BMPs considered most optimal mitigation technologies to achieve the Light
and feasible to prevent impacts to nearby residents. Industrial sound levels at 350 feel Imm sound
sources during all phases of construction. drilling,
and completions.
221The Operator shell provide a formal update lo the Boatd or
County Commissioners on a quarterly basis as to the
progress of the project. This update shall be coordinated
through the Community Development Department
specincally including the Oil and Gas liaison's office.
231 No Special Use Permil shall be issued to the Applicant I
Operator (and no activity shall occur on the site) until all
required local, state and federal permits have been
obtained and tendered to the County Community
Development Department. A violation of any of the terms
and I or conditions of these local, state and federal permits
shall also be considered a violation of the Special Use
Perm1L
•Ursa will continue lo i nvestigate new technologies
such as carbon fitter packs, sealed flowback tanks,
additional pressure tanks in an effort to continually
reduce odors.
•Ursa will utilize carbon blankets over thief hatches
on temporary tanks to minimize potential temporary
odors.
•Ursa will use LED lights that are shielded and/or
can be focused directly on the work at hand.
•These are just a few or the technologies that Ursa
is uli!izing to mitigate possible nuisances Imm its
operations. Ursa wlll continue to respond to
complaints with the best technology practically
feasible.
•Updates will begin at the beginn~ng of construction
and continue throughout drilling and completion
operations and cease once the pad is in full
production operations.
The Applicant suggests that Ursa will obtain the
required Air Quality at the appropriate time in
accordance with CDPHE regulations. Due to the
nature of that state permitting process, Staff is in
agreemnt with lhe sugested changes.
COA AltemMive PC Adot*d COA on 1D128111i with St.ff~
ln a..-i
Prier le a Feeemmendalien ll'I the Geftleld Sewn!)' lr-11 ___ : __ ,... ___ : __ : __ TL.-----•---L.-11
-· •g•• ·----·-·····::;ii-·-··-· .... ---···---=ii·---·-··----·-
GGAIFGI emissions and edel'5 fer all eperalienal pl!ases
senlemplated fer Ille prepesell lesalieR& aAll eleaflo;
llessrille mitigalieAs aAd BMPs seAsideFell mast ep~mal
and leasible te pre\lenl impasta le Realty r.aidents.
The Operator shall provide a formal update to the Board
ol County Commissioners on a quarterly basis as lo the
progress of the project, tncludin11 buLMLlimi!edJo .
advancement and utlllza11on ol odor and em1ss1ons
technology. This update shall be coordinated through
the Community Development Department specifically
including the Oil and Gas liaison's office. Updates shall
begin at the b1t111nmn9 of construction and continue
lhroughout drilling and completion operations and cease
once 1he pad is m full p roduction o pera11ons.
No Special Use Permit shall be issued to the No Special Use Permit shall be issued to 1he
ApplicanVOperator (and no activity shall occur on ApplicanVOperalor (and no activity shall occur on the
the site) unur all required local, state and federal site) un~I all required local, state and federal permits,
permi1s . exceplthose permits.w!Ju:h _are_o_b1ained except those permits which are obtained only after
only aJ1er constcucti~n is ~. have been constNction is complete. have been obtained and
obtained and tendered to the County Community tendered lo the County Community Development
Development Department. A violation of any of the Department. A violation of any of the terms and/or
terms and/or conditions of these local, state and conditions of these local, stale end federal permits shall
federal permits shall also be considered a violation also be considered a violation or the Special Use Permil
of the Special Use Permil.,The.A1r O uall ~_PErm1l The Air Quality permit shall be submitted as soon as ii is
shall be submitted as soon as it 1s received. received.
Pages ol 8
............_
COAfofDPad . /Dllc:UM!on COA~ PC AdoplJld COA on 1C1121115 wMh Staff rwflnementa
1n-
24 Prior to a recommendation by the Garfield County Planning •Leak detection information can be found in the The Operator will provide a draft site specific The Operator will provide a draft site specific SPCC plan
Commission, The Applicant should will provide the site SPCC document included In the original application SPCC plan for Pad B with n 30 days ol 1nstallat1on for O Pad within 30 days of instaUation of tank
specific SPCC plan for Pad B. The Applicant should on pages 76-78, 83, es. and Appendix E. of tank containment structures. The Operator shall containment structures. The Operator shall provide a
provide additional information on the storage tank sizes, Information about how precipitation events would be provide a f;nal site specific SPCC plan for the BMC final site speciric SPCC plan for the 0 Pad wells pad
how those tanks are to be interconnected, the volume of safely drained from stc0ndary containment can be B wells pad within six month s of insta llation of the within six months of installation of the tank conta :nmanl
secondary containment to be provided including found in the SPCC document included in the onglnal tank containment structures per EPA reg ulations structures per EPA regulations. The site specific plan
precip~alion, the anticipated leak detection, and how the application on page 84. The site specif c plan shall include information on shall Include information on storage tank sizes and Iha
precipitation events would be safely drained from the •The tanks are filled from the top by design, storage tank sizes and the volume of secondary volume of secondary conta:nment is calculated.
secondary containment. therefore cannot equalize in the unlikely event of a containment IS calculated ,
tank failure. Tank volumes are controlled and
lowered individually. Thus secondary containment is
sized lo the lamest individual tank in the battery.
25 Prior to a recommendation by the Garfield County Planning •A co~ of the revised Drainage Report with Prior to a recommendation by the Ganield County Prior to the the issuance al the S~aal Use Perrmt a-
Commission, the Applicant should provide a discussion, calculations is included in this submit1al. Planning Commission, the Applicant should ~he-Gaffield-Goull~
calculations, and details fat the proposed release •Detention ponds and stonnwater are not subject to provide a discussion, calculations, and details for Gommlss+on. the Apphcanl should provide a dlscuss10n.
structures from the detention pond. Release from the SPCC rules. the proposed release structures from the detention calculations. and details for the proposed release
detention pond may need to comply with the requirements pond.~elea5&-from-llle-deleAI~~ structures from the detention pond.
of the SPCC. le oomjll)> with Ille Fe111memen~
26 Prior ID the hearing before the Board of County If Ursa's engineer determines that a culvert is Prior to the hearing before the Board of County
Commissioners , the Applicant should evaluate if a culvert is warranted, the dta\Mngs will be revised and ConvnisslOMfS, the Appllcanl should evaluate if a culvert
necessary at the driveway intersection with River Bluff resubmitted. is neces5111Y at the dnveway mtersectJon with River Bluff
Road. II appears from the topography that grading of the Road. It appears from the topography that grading of the
area lo drain may also be necessary to gel runoff lo drain area to drain may also be necessary to get runoff to drain
to the existino culverts. to the existing culverts.
27 Prior to a recommendation by the Garfield County Planning Same as COA 24 Oelel e this COA. PAeF le a FeoommeAdalieA II~ Illa Galfield Ge1111~
Commission, The Applicant should provide the site speciric PlanAi11g Semmi&&ie11, :flle oA1111li&aAI &llewld llF&'tlide Ille
SPCC plan for Pad D. The Appticant should provide &ile s11es1fis SPGG pla11 laF Pall g :file A1111lii;a11t •llawld
additional information on the storage tank sizes, how those pFe tide addilieAal IAklFFAalieR eR 1111 5111ra11• le11k •iaH,
tanks are lo be interconnected. the volume of secondary llew llle&e laRk& a1e le lie i11leF001111e61ad. Ille 'tlalwme al
containment lo be provided Including precip~allon. the seseRdafl/ se11lainme11I le lie pre~ded i11el11dl1111
anticipated teak detection, and how the precipitation events llFBsi1Jilat1eA. Ille a11ti 6ipaled leak del161i1111. e11d 1111...,. Ille
would be safely drained from Iha secondary containment f1F&Gipilal100 e"'eAI& •1ue11ld lie &ale~ d1al11ed !Fem Ille
Page 7 of B
-,.-., .--....
COAForDhd -----Comments I Dltc:uulon -~r --· COA Altermltiw PC Adopted COA on 10128115 with Staff ntftnements
ln ·lll'fff1
2:8 Regarding air quality, the Operator shall design and The Applicant is retue1ant to commit to an air quality Regarding air quality, tile 011efaler Garfield County shall
implement an air quality mon~oring program al the well pad monloring program as suggested in this COA. design and implement an air quality moniloring program
(focused on voe collection) prior, during and alter the During discussions, Garfield County provided a al lhe well pad (focused on voe collection) prior, during
drilling and completions are complete lo better understand proposal to Ursa v.flich will be presented at the and after the drilling and completions are complete lo
air emissions al the source. October 28th hearing. The Applicant indicates there better understand air emissions at the source. Th"
is not a need for site specific air monitoring based crog ram will include the J!.!!!.Chj!s_e of monito®t
on prevention practices inciuding IR camera ~ui l!!!!!l nt SB!!lllii !l!I events . and consultant as ~istan~
surveys, AVO surveys, and newly implemented with eg u1 1!~Qt placement, fr~u!!!!51': of samel ing and
CDPHE regulations regarding aut~gniters, monthly ~l!,l~ana f'iliis ancUo!alroonitoon11 dumt1oo_with a
emissions monitoring, etc. total cost not to exceed §:50 000 to be funded ~the
Ursa requests that Garfield County consider sile Applicant.
specific air dispersion modeling in lieu of sffe
speciOc air quality monitoring. Staff recommends
this COA remain and suggested.
29 The Application proposes a significant landscaping Ursa plans lo use native vegetation in the The Application proposes a significant landscaping
program; as a resuH, the Applicant should provide more landscaping scheme. Ursa will water the program; as a result, the Applicant should provide more
information regarding the ongoing irrigation for this plan. landscaping appropriately via water trucks or a information regarding the ongoing irrigation for this plan.
temporary lank and irrigation system until the
vegetation is well established. During daily
inspections, the vegetation will be checked to make
sure that it is not dying. Dead vegetation will be
replaced with like kind vegetation. landscaping will
be maintained through the end of the productive life
of the well pad, at which lime the maintenance will
revert to the land owner. Ursa is willing lo negotiate
a vegetation bond to be held by the County.
30 Applicant agrees and commits to a three year time frame Applicant agrees and commits to a three year lime frame
for Phase I activffies. This lime frame will commence at the for Phase I activities v.flich inciudes placing up to 53
start of cobslruction of e~her Phase I well pads or pipeline, wells into full prodiction. This lime frame will commence
and ends with the placement of the last well (of 53 wells) at the start of construction of either Phase I well pads or
being placed into full production. oipeline.
Page 8 of 8
-.....
EXHIBIT
It: c.c. ~
, COA For Pipeline Comments and luUft COA Altemllllve PC Adoptlld COA on 111128115
' 1 That all representations of the Applicant, either in That all representations of the Applicant, either in
testimony or the submitted application materials, shall be testimony or the submitted application materials, shall be
considered conditions or approval unless specifically considered conditions of approval unless specifically
altered by the Board ol County Commissioners. altered by the Board ol County Commissioners.
2 That the Pipeline shall be operated in aecordance v.ith all Applicant suggests adding the langauge in red (on Operation of the facility must be in accordance with That the Pipeline shall be operated in accordance with all
applicable Federal, Slate and local regulations governing ,the right). Staff disagrees and suggests it remain as it all Federal, Stale and local regulations and permits applicable Federal, State and local regulations governing
the operation of this type of facility. is lanugae directly rrom the Land Use and governing the operation or this facility. Any conflicts the operation of this type of facility.
Development Code ol 2013. Any change to COAs between Qarfield Cm ....., andJ ederal state and local
adopted by the Board or County Commissioners that 1:iermit conditions or a.RJl!.OVal will r jlQ,U[e_J esol!!Jl2!!.
are to be modified currently requires a public hearing between tbe a oenaes and the O oerator
before the BOCC so a formal process is available to
manaoe that conllict.
3 Prior to issuance ol the Special Use Permit, the Applicant •The SPCC Plan applies only to storage tanks , There Prior to issuance of the Special Use Permit, the Applicant
shall provide additional operational procedures for are no storage tanks associated IMlh the pipeline. shall provide additional operational procedures lor
monitoring protocol for the pipeline for leak or spill Spilt response and clean-up will follow Ursa's monitoring protocol for the pipeline for leak or spill
detection , Said procedures will be Included in the Emergency Response and Spill Response Plans , detection. Said procedures v.ill be included in the
Emergency Response Plan or as an addendum to said •Pipeline monitoring plan is included in this submittal. Emergency Response Plan or as an addendum to said
plan . The Applicant shall comply v.ilh all provisions ol the plan. The Applicant shall comply with all provisions ol the
SPCC Plan including sp' II response and clean-up. SPCC Plan including spill respoose and clean-up.
4 Prior to issuance ol the Special Use Permit, the Applicant Staff prefers to discuss with PC. PfiaF la oonstruGlien , Ille AppliGaAI shall pFa.1Ele Prior to construction, the App~cant shall provide copies of
shall provide an assessment by a qualified professional sepias el aRy permits req111red oy tile Army Ca'f)6 ef any permits required by the Army Corps ol Engineers.
that no Army Corp of Engineer's Permits are required for ~ ...
the proposed pipeline or referral comments from the
Army Corp ol Engineers conftrming that no permitting is
requi red. If permits are requ :red they shall be obtained
and submitted to the County prior to Issuance of the
5 ""'"h l use Pem l
S Prior to issuance ol the Special Use Perm~. the Applicant Prior to issuance or the Special Use Permit, the Applicant
shall provide secunty in a form acceptable to the County shall provide security in a form acceptable to the County
~omey's Office in the amount ol $32,500 tor re-Attomey's Office in the amount of $32,500 for re-
vegetation. The Applicant shall comply with the vegetation. The Applicant shall comply with the
representations in !heir Weed Management Plan and representations in their Weed Management Plan and
shall comply with the Reclamation Standards contained shall comply with the Reclamation Standards contained
in the Garfield County Weed Management Plan es noted in the Garfield County Weed Management Plan as noted
in the referral comments from the County Vegetation in the referral comments from the County Vegetation
Manager dated September 11, 2015. Manager dated September t t, 2015.
6 Prior to initiating construction, the Applicant shall consuH Slaff is in egrement with deleting !his. Does not apply. PAaF le iRlliabng GGAStF\fG~BA , lhe AppliGaAI sl!all PfieF le iR~ialiRg 69RslRIBlieA, Iha ApplieaAI &llall BBRIWll
with the County Road and Bridge Supervisor regarding ~~~ ~1'illl lhe GewRly Read and 8fidge SwpeFYi&eF 1egaRliRg
sight distance improvements at the County Road 308 r~~O¥emefll!;...aHl!e-Goooty-eiglll disleAGe iRIJIFB ~emeAIS el Ille GBYRI\' Read 398
and East Battlement Parkway intersection. Any ReaEI 308 BREI !;ast 8altlemeAI Pafl(way iAl8FS8Gli9R . and ~asl 8alllemeAI Pafllil11BY inter.eGlieA. Arv(
recommended changes or improvements shall be "-· FesemmeAded 61\aAges eF imp1e\'ements shall be .. , -..
required prior to initiating construction. ~~~k<U(oti8fl ~~.
Page 1ol5
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COA For Pipeline C--.•ndlMUM COA .u.m.ttv. PC Adopted COA on 10121115
7 Prior to initiating eonstrudion the Applicanl shall obtain Staff i s in agrement with lh1s. Prior to 1n11•ar ~ conslrucllori the A 11.nlicaotshatl Prior lo i nilialing conslrudion, the Applicant shall obtain
an required permits from the Road and Bridge oblatn all reornred e:rm11s from lhe Road and Bndg e all required permits from the Road and Bridge
Department including but not limiled to permits for De12ar1ment. Com1211ance wilh all condilions or the Department Compliance 'Nith all conditions ol the Road
boring, road cuts, oveiweight or oversize vehicles. Rgad and Bnd_lJ e~rm ls sh<1ll be rfl!ll!ired, Tbe and Bridge permits shall be required. The Applicant shall
lemporaty access, and grading 'Nithi n lhe righl-of-way. A11Jl!1cant shall be res !!2ns ble lor re ea r ol a ~ be responsible for repair of any damage to roadways or
Compliance 'Nith all condilions of the Road and Bridge QB!l:!il.ae lo roadwayj. or cutbs curbs .
permits shall be required. The Applicant shall be
responsible for repair of any damage to roadways or
curbs.
8 Prior to initialing construdion the Applicant shall submil Prior to initia ti ng construction the Applicant shall submit
lor approval by the Road and Bridge Supervisor traffic for approval by the Road and Bridge SupeNisor lraffic
control plans including areas adiacenl lo the County control plans including areas adjacenl to lhe County
Road Righi of Way, conslrudion access points, Road Righi of Way. construdicn access points,
proposed bore locations and potential road cuts or the proposed bore localtons and polenlial road cuts or the
Applicanl can demonslrale thal lraffic control plans are Applicant can demonstrate that traffic control plans are
addressed in the applicable Road and Bridoe Permils. addressed in the aoolicable Road and Bndoe Permits.
9 The Applicant shall coonl nate 'Nilh the County Road and The Applicant shall coordinale with the County Road and
Bridge Department during construction including field Bridge Department during construdion including field
Inspections as needed to ensure that minimum pipeline inspections as needed to ensure that minimum pipeline
depths are maintained and to ensure construction i s depths are maintained and lo ensure conslrudion Is
done in a manner that maintains et.1rrent drainage along done in a manner that maintains et.1rrent drainage along
County Roads and avoids conRicts with Mure drainage. County Roads and avoids conRicts 'With future drainage.
The Applicanl shall install posls/markers along key The Applicanl shall install posts/markers along key
sections of the pipeline indicating depth to the pi peline. sections of the pipeline indicating depth lo the pipeline.
Maintaining drainage shall be lhe responsibility of the Mainlaining drainage shall be the responsibility of the
pipeline operator subjed lo approval by the Road and pipeline operator subjed to approval by the Road and
Bridae Suoervlsor. Bridoe Supervisor.
1 O The p ipeline shall ma1nla1n compliance with CDPHE The pipeline shall mainlain compliance 'Nith CDPHE
Storm Water Management Permits, Drainage and Sail Storm Water Management Permits, Dra'nage and Soil
Erosion Protection, BMP's, Reclamation and R~ Erosion Protedion, BMP's, Reclamation and R~
vegelation Plans and Weed Manaaement Plans. veaelation Plans. and Weed Mana11emenl Plans.
11 The Applicant shall comply wilh all COGCC rules and The Applicant shall comply with all COGCC rules and
regulations regarding the pipeline facility including but not regulalions regarding the pipeline lacility including bul not
limited to reclamation and deconunissionina. limited to reclamation and decommissionin11.
12 The Applicant shall maintain compliance with COGCC The Applicant shall maintain compliance with COGCC
Rules and Regulalions in regards lo noise abalemenl Rules and Regulations in regards to noise abalement
and C.R.S. Article 12 ol Title 25, noise standards as and C.R.S. Article 12 of Tiiie 25, noise standards as
appropriate. Any pumping stations required for operation appropriate. Any pumping stations required lor operation
of the pipeline shall utilize electric pumps or mulfled of the pipeline shall utilize electric pumps or muffled
internal combustion motors. internal combustion motors.
13 The Applicant shall maintain all required CDPHE permits The Applicant shall maintain all required CDPHE permits
for the facility including any applicable air quality APEN lor the facility including any applicable air quality APEN
""rmits. ""rmits.
Page 2 ol 5
-'""
COA For Pipeline Comments and ...... COA Alternative PC Adopted COA on 1G12111&
14 The Applicant shaH comply with the Battlement Mesa The Applicant shall comply With the Battlement Mesa
Wildlife Mmgalion Plan -Agreement between Ursa Wildlife Mitigation Plan -Agreement between Ursa
Operating Company and CPW including any wildlife Operating Company and CPW including any wildlife
protec1ion or mitigation requirements. The Applicant shall protection or miligalion requ'.rements. The Applicant shall
comply with recommendations of the Sensitive Areas comply with recommendations of the Sensitive Areas
Survey completed by Westwater Engineering Inc. dated Survey completed by Westwarer Engineering Inc. dated
June 2015, including but not limited to weed June 2015. including but not limiled to weed
management, re-vegetation, avoiding construction during management, re-vegetalion , avoiding construction dunng
nesting seasons, and lemporary salety fencing for open nesting seasons, and temporary safety fencing for open
trenches as needed. trenches as needed.
15 In accordance with Seciion 9-103 (J), upon completion of Staff is in agrement with this. Upon completion of the pipeline. the Applicant shall Upon completion of the pipeline. the Applicant shall
the pipeline the Applicant shall submit an enginee(s submit an engineel's statement certifying compliance submit an engineel's statement certifying compliance
statement certifying compliance with the conditions of the with the conditions of the Land Use Change Penni! with the conditions of the Land Use Change Permit and a
Land Use Change Permit and a digital copy of the and a digital copy of the surveyed pipeline that is digital copy of the surveyed p ipeline that Is compatible
surveyed pipeline as buill kQt!lll<>tible_wil!lJb~GarueJQ...Coun!:J! GlS database, with the Garfield County GIS database.
16 Potable water and sanitation shall be addressed during Potable water and samtat1on shall be addressed dunng
construction by provision of portable facilities in constn.iclion by provision of portable facilities in
blimoliance with OSHA reotlitements. comt.1iance with OSHA reciuirements.
17 The Operator shall commit to ensunng trucldoads of dirt. Staff 1s I n agrement with thi s, The Operator shall commit to ensuring truckloads of The Operator shall commit lo ensuring truckloads of d rt .
sand, aggregate materials, drilling cuttings, and similar dirt, sand, aggregate materials, drilling cuttings, and sand, aggregate materials. drilling cuttings. and similar
materials are covered to reduce dust and PM emissions. similar materials are covered to reduce dust and PM materials are covered to reduce dust and PM emissions
emissions d uFIDll l rl!ll!>""", durin11 lransPOft.
18 The construction of the Pipeline shall be lim.ted to the This allows Ursa to stay on schedule ii unforeseen The construction of the Pipeline shall be limited to the The consln.iction of the Pipeline shall be limited to the
hours of 7:DDAM to 7:00PM, Monday through Saturday. events occur. Staff will propose with PC and hours of 7 :00AM to 7:00PM, Monday through hours of 7:00AM to 7:DOPM, Monday through Saturday. II
determine if work on Sundays is approanate. Saturday.~ mciem11nI weather conditions or field condmons require
fequif~· -, schedule changes, constn.iction may occur on Sundays ... ll4~ lo meet construction schedule. Ursa will notify Garfield
fl&I::&. ,... --.. .. County and affee1ed residents if Sunday work is ... , .. , -·
~ .. '~ necessanr.
19 AU extraction and processing activities shall be required All extraction and processing activities shall be required
to comply with the following pelfonnance standards: 1to comply with the following pelformance standards:
(1) Volume of the &iund generated: The noise shall be Volume of the sound generated: The noise shall be
required to meet lhe standards in COGCC Rule 600 required to meet the standards in COGCC Rule 800
Series. Series·
(2) Vibration generated: every use shall be so operated that Vibration generated: every use shall be so operated that
the ground vibration Inherently and recurrently generated the ground vibration inherently and recurrently generated
is not perceptible, without instn.iments, at any point of is not perceptible, without instruments, at any point of
any boundary line of lhe property on which the use is any boundary line of the property on which the use is
located· located:
(3) Emissions of smoke and particulate matter: every use Emissions of smoke and particulale matter: every use
shall be so operated so as to comply with all Federal, shall be so operated so as to comply with all Federal,
State and County air quality laws, regulations and State and County air quality laws. regulations and
standards -standards·
Page 3 of 5
,.,......... ,.-.
'"""'
COA For Plpellne Comments and ...... COA Altem.ttve PC AdopDd COA on 1111281115
(4) Emission ol heal, glare, radiation and fumes· every use Emission of heat. glare, radiation and fumes: every use
shall be so operated that it does not emit heat, glare. shall be so operated that it does not emit heat, glare,
radiation or fumes which substantially interfere with the radiation or fumes \loflich substantially interfere with the
existing use of the adjoining property or \lofllch consmutes existing use of the adjoining property or which constitutes
a public nuisance or hazard. Flaring of gases, aircraft a public nuisance or hazard. Flaring of gases, aircraft
warning signals, renective painting ol storage tanks, or warning signals, renective painting of storage tanks, or
other such operations which may be required by law as other such operations which may be required by law as
safety or air pollution control measures shall be safety or air pollution control measures shall be
exemoted from this nmvision· exemoted from this orovision· and
(5) Storage area, salvage yard, sanilary land-fill, and mineral Storage area, salvage yard, sanitary land-fill, and mineral
waste disPOsal areas: waste disoosal areas:
(a) Storage or nammable. or explosive solids, or gases, shall Storage of flammable, or explosive solids, Of' gases, shall
be in accordance with accepted standards and laws and be in accordance with accepted standards and laws and
shall comolv with the National Fire Code· shall comolv with the National Fire Code:
(b) At the d iscretion ol the County Commissioners all At the discretion ol the County Commissioners all
outdoor storage facilities lor luel, raw materials and outdoor storage facilities for fuel. raw materials and
products shall be enclosed by a fence or wall adequate products shall be enclosed by a fence or wall adequate
to conceal such facilities from adiacent oro.,..11v; to conceal such facdit1es from ad1acen1 orooertv.
(C) No materials or wastes shall be deposited upon a No materials or wastes shall be deposited upon a
property in such fonn or manner \hat they may be property in such ronn or manner that \hey may be
lranslerred off the property by any reasonable transferred olf the property by any reasonable
foreseeable natural causes or lorces: loreseeable natural causes or forces: and
(d) All materials or wastes which might constitute a fire All materials or wastes which might constitute a fire
hazard or \lofllch may be edible by or otherwise be hazard or which may be edible by or otherwise be
attractive to rodents or insects shall be stored outdoors in attractive to rodents or insects shall be stored outdoors in
accordance with applicable State Board of Heatth accordance with applicable State Board of Health
Reaulalion : Reaulation.
(6) Waler pollution: in a case in which potential hazards Waler pollution: in a case in which potential hazards
exist. it shall be necessary to install safeguards designed exist, it shall be necessary to install safeguards designed
to comply with Iha Regulallons of the Environmental to comply with the Regulations of Iha Environmental
Protection Agency before operation or the facilities may Protection Agency belore operation of the facil~ies may
IM<iin. beain_
20 The Operator shall provide infonnation lo the residents of •Ursa will work with Battlement Mesa Partners, The Operator shall provide inlonnation to the residents of
Valley View Village prior and during construction to Community Counts, lhe residents of Valley View Valley View Village prior and during construction lo
infonn them of their plans, liming, and what to expect Village, and Garfield County to make sure that the inlonn them of their plans, liming, and what to expect
during the construction portion adjacent to their homes. alfected residents have as much inlonnation as during the construction ponion adjacent lo \heir homes.
possible about the construction progresses past their Mo~ s~ci!ica1 ~, the Ol>erato[ !Jlee!..'ln!!l !::!QA
property. E![esideots or a~~J!E[late ne!a hborhood re l!!esent~
•Meet w/ HOA President or appropriate
neighborhood representatives.
•Opportunity to address emergency inlonnation and
comolainl svstem with these residents.
21 Prior to the issuance of a Special Use Permit, the Ursa agrees to address comments. Prior to the issuance ol a Special Use Permit, the
Applicant shall address Iha comments prepared by Applicant shall address lhe comments prepared by
Garfield County Consulting Engineer. Chris Hale, Garfield County Consuhing Engineer, Chris Hale,
Mountain Cross Engineering ; Mountain Cross Enaineerino:
Page4of 5
,,..---""
COA For Pipeline Comments and --
·-~ -COA MtHn.Uve PC Adopt9d COA on 1012811&
a) The Applicant should include fittings or transition Ursa needs to have the flexibility to build the pipeline The Applicant should include fittings or transition
necessary to transition from a 12· pipe to a 16" pipe at in the best manner possible as determined by field necessary to transition from a 12" pipe to a 16" pipe at
station 47+00. conditions. Staff will meet with Ursa to discuss this station 47+00.
enoineerino issue orior to the BOCC hearinos.
b) There are two horizontal bends proposed in an area ol Ursa is revising the drawing. The bore will be straighl There are two horizontal bends proposed in an area of
pipeline that is proposed to be bored beneath Stone The stan and stop locations of the bore will be pipeline that is proposed to be bored beneath Stone
Quany Road, station 59+37 to station 81 +87. The relocated on the drawing. A revised drawing will be Quany Road, station 59+37 lo station 61 +87. The
Applicant should discuss the feasibility of constructing sent when it is complete. Applicant should discuss the feasibility of constructing
45• and 87° bends in borinos. 45• and 87° bends in borinos.
c) The Applicant should provide a detail for the proposed Valve details are found in the attached drawings The Applicant should provide a detail lor the proposed
valve sets. valve sets.
d) The typical trench sedlon should be revised to match the These details can be found on Sheets 1 and 8 or the The typical trench section should be revised to match the
Garfield County cond~ions for p:peline installalfons. The Site Plan that was submitted with the Technically Garfield County conditions for pipeline Installations. The
note on the cover should be revised lo reference these Complete packages. note on the cover should be revised to relerence these
conditions also. conditions also.
22 The "Integrated Vegetation and Noxious Weed •All potential riparian areas or weUands are covered The "Integrated Vegetation and Noxious Weed
Management Plan· prepared by West Water Engineering by the Army Corps of Engineers' Nationwide Permit. Management Plan• prepared by West Water Engineering
idenHfied localions along the pipeline that had riparian •Ursa will mitigate by planting like seed mixes and idenHlied locations along the pipeline that had riparian
areas and weUands . The Applicant should Identify 1f any following Army Corps Permit conditions. areas and weUands. The Applicant should identify if any
permitting was obtained and/or necessary and the permitting was obtained and/or necessary and the
mitigation that was Implemented. Specirie construction mitigation that was Implemented. Specific conslruction
mitigation necessary should be Included on the plan mitigation necessary should be included on the plan
sheets. sheets.
23 Applicant agrees and comm~s lo a three year time rrame
Applicant agrees and commits to a three year time frame for Phase I activilies which includes placing up to 53
lor Phase I activities. This time frame will commence at wells Into full prodiction. This time frame wiH commence
the start of cobstruetion of either Phase I well pads or at the start of construction of either Phase I well pads or
pipeline. and ends with the placement of the last well Cof pipeline.
53 wellsl be1na placed into full Dmductlon.
Page 5 of 5
r--. ..-...
"'"'"'
EXHIBIT
_Fr_e_d_Ja_r_m_a_n _________________________________________ lb\)})
.. -..,m:
1t:
To:
Cc:
Subject:
Rob Bleil <rbleil@ursaresources.com>
Wednesday, October 21, 2015 4:16 PM
Fred Jarman
Eric Schmela (eschmela@battlementmesa.com); Tilda Evans
FW: BM PUD : Response Regarding COA Requiring Emissions Monitoring
For your consideration, as an alternative to the air monitoring COA. I'm not sure how exactly you'd prefer to
put this into a COA format if deemed acceptable.
To protect public health and minimize potential odor concerns, Ursa is proposing that the following measures
be considered to address concerns that may be raised by the public (in lieu of air monitoring). I have run this
be our senior management.
Protection of Health: Ursa will install and operate equipment which will reduce air pollutants by greater than
98%; hence no venting the emissions to the atmosphere. Additionally, Ursa will commit to air dispersion
modeling based on normal operations and the potential to emit (PTE) from the facility. (PTE is the maximum
level of pollution the site is capable of achieving with an additional 20% buffer added.) The air dispersion
modeling will consider actual input data (based on the CDPHE Air Permit) and I or engine specifications, BMPs,
and COGCC, CDPHE and industry accepted operating practices. Drilling and completions data and emission
:tors from EPA and other sources (perhaps the CSU study if available shortly) can be used to accommodate
tne modeling, as these temporary/short-term sources don't require air permitting.
The air dispersion modeling utilizes actual air pollutant emission rates, predominant winds, and many other
factors; the computer model will calculate the distance at which the air has been returned to ambient levels of
the pollutants introduced as a result ofthe presence of Ursa operations. This should provide reassurance to
local residents that there are no health effects due to the presence of the operation because the air quality
has been returned to background levels by the time it reaches their property.
Mitigation of Nuisance Odors: Ursa employs a number of strategies and BMPs to prevent air pollution and
nuisance odors off of Ursa property. Ursa utilizes combustion devices which have a manufacturer's
guaranteed destruction efficiency of greater than 98% where required for stationary sources. Emissions
reduced by these combustors are the odor causing pollutants. Routine inspections are conducted utilizing an
Infrared (IR) camera and other technology to locate and identify potential leaks for maintenance. Additionally,
facility walkthrough inspections are conducted to detect Audible, Visual, or Olfactory (AVO) anomalies. These
inspections are conducted at varying frequencies, but are documented no less frequently than once per
calendar month and in some cases as frequently as once per calendar week. The IR camera is capable of
detecting the gasses which contribute to the greatest potential for nuisance odors. The gasses detected
include strait chain hydrocarbons Cl-CS+, BTEX, methanol, ethanol, and others. (For a full list of gasses
detected visit FLIR's website at: http://www.flir.co.uk/ogi/displavl?id=S5671) Under normal operations these
gasses will be the greatest contributors to nuisance odors, and the camera visually locates the leaks for repair.
·r Colorado Regulations, Ursa is required to make an attempt to repair the leak within 5 working days and to
actually repair the leak within 15 days unless circumstances warrant a delay (e.g. parts are on order). While
1
(
preventing all nuisance odors is unachievable, Ursa has employed, and will continue to employ, the proper
technologies and operational practices to minimize odors to the maximum extent practicable.
· '"lte that we have ordered new and improved thief hatches for production tanks for existing pads within
-dttlement Mesa. However, also note that there is still the possibility of episodic events to short-term releases
from tank pressure relief valves designed to manage tank pressures and minimize potential safety issues.
Please advise if this is an acceptable alternative or what additional concerns we should address. Other than
this issue it appears we've reached agreement on other COAs (at least conceptually) pending your final
determination.
Rob
2
(
Behrens and Associates Inc.
~nvironmental Noise Control
URSA Operating Company, LLC
October 16 , 2015
Page 5 BMC B pad
EXHIBIT
IE£•
Table 2 . Summary of Results in dBA For Drilling Operations
Unmitigated Drilling
Receiver Location Description Oncrations dBA
A 350 ft east of noise emitting equipment 54.S
D 3 50 ft southeast of noise emitting equipment 59.8
c 350 ft southeast of noise emitting equipment 59.6
D 3 50 ft north of noise emitting equipment 54.3
Allowable 350 ft from the noise source towards an
noise level existing, occupied structure or ut the 70.0 Day I 65.0 Night
oropcrtv Jine. whichever is e:rcatcr
Behrens and Associates-Inc.
Environmental Noise Control
Attachment 2
Unmitigated BMC B Pad Drilling Noise Contour Map (dBA)
Average Noise
Level. Leq dBA
= 30.0
= 35.0
= 40.0 = 45.0
= 50.0
= 55.0
= 60.0 = 65.0
= 70.0
= 75.0 = 80.0
= 85.0
= 90.0
*
\.!'O 441!.00 eyp••l
Behrens and Associates Inc.
( Environmental Noise Control
URSA Operating Company, LLC
October 16, 2015
Page 6 BMC B pad
Table 4. Summary of Results in dBA For Fracing Operations
Option 1:
Unmitigated Mitigated
Fraciog Fracing
Operations Operations
Receiver Location Description dBA dBA
A Site property line west of Pad 73 .9 59.0
B Site property line east of Pad 72.4 58.2
c Site property line southeast of 75.S 61.6 Pad
D Site property line southeast of 69.6 6 1.2 Pad
350 ft from the noise source
Allowable towards an existing,
noise level occupied structure or at the 70.0 Day I 65.0 Night
property line, whichever is
2rcater
(
Option 2:
Mitigated
Fracing
Operations
dBA
57.6
56.6
60.2
60.l
Behrens and Associates .. Inc.
Environmental No ise Control
Attachment 10
Option 2: BMC B Pad Modeled F,.,,.cing Noise Mitigation Layout
.._,.
Behrens and Associates .. Inc.
Environmental Noise Control
'-'
~I
I
1260 ft I
20 ft high STC-33 panels
installed around frac trucks
1\ i ~
350.0
Pump House
(20'x40')
~
1
I Hioo .o·-q l:_4~0~ / -VVVVVV VVVV ~J-'•~1 j ~ ~n ·n · '~ ~ ~ ~{ ~,, : ~f -' ~~:~~:1~.
/1.l" '' · l M : DJ {Optional) t-A< ' I < 1 8~' B ms I ~ fl d
75.0'
Qt;;A . 32 .... 3 V) ~v 1,680 foot long, 40 ft high STC-I :!. N ee . Acoustica! WaU -~
-~§:-~,~3 2s.0'1Jo rJ [lOD_....___~1 4o ftl.----~ -Co i hu:'J ' 350 .0 Produced Water 240 ft Proposed Separatoi
and condensate Tanks (8} Placement I 4
00
ft J II
Attachment 9
I 4ooft I
l ,
Option 1: BMC B Pad Modeled Fracing Noise Mitigation Layout
~ .._./
Behrens and Associates Inc.
Environmental Noise Control
URSA Operating Company, LLC
October 14, 2015
Puge 4 BMC D pad
Table 2. Summary of Results in dBA For Drilling Operations
Unmitigated Drilling
Receiver Location Description Operations dBA
A 350 ft nonh of noise emitting equipment 50.0
B 350 ft northeast of noise emitting equipment 49.3
c 3 SO ft east of noise emitting equipment 59.9
D 350 ft cast of noise emitting equipment 59.4
E 350 ft south of noise emitting equipment 59.7
F 350 ft south of noise emitting equipment 55.8
G 350 ft west of noise emitting equipment 46.7
Allowable 350 ft from the noise source towards an
noise level existing, occupied structure or at the 70.0 Dny I 65.0 Night
property line, whichever is l!reater
EXHIBIT
l£F F
Behrens and Associates , Inc.
Eovironmental Noise Control
Average Noise
Level, Leq dBA
= 30.0
= 35.0
= 40.0
= 45.0
= 50.0 = 55.0
= 60 .0
= 65.0
= 70.0
= 75.0 = 80.0
= 85.0
= 90.0
t
0 200 400 600 800 mt! fHt
Attachment 2
Unmitigated BMC D Pad Drilling Noise Contour Map (dBA)
Behrens agd Associates, Inc.
( Environmental Noise Control
URSA Operating Company, LLC
October 14, 2015
Page 5 BMC D pad
Table 4. Summary of Results in dBA For Fracing Operations
Unmitigated Mitigated
Fracing Fracing
Operations Operntions
Receiver Location Descriotion dBA dBA
A 350 ft north of noise emitting equipment 71.0 60.8
B 350 ft northeast of noise emitting equipment 70.8 60.5
c 350 ft east of noise emitting equipment 75.3 61.8
D 350 ft east of noise emitting equipment 75.7 64.l
E 350 ft south of noise emitting equipment 73.8 62.3
F 350 ft south of noise emitting equipment 69.3 57.6
G 350 ft west of noise emitting equipment 62.4 59.2
Allownble 350 ft from the noise source towards an existing,
noise lenl occupied structure or at the property line, whichenr 70.0 Day/ 65.0 Night
is ereater
(
.Q~hr~_!ls and _4s~oci!tes, In~.
Environmental Noise Control
Attachment 7
Mitigated BMC D Fracing Noise Contour Map (dBA)
...._,,
Average Noise
Level, Leq dBA
= 30.0
= 35.0
= 40.0
45.0
= 50.0
= 55.0 = 60.0
= 65.0 = 70.0
= 75.0
= 80.0
= 85.0
= 90.0
*
Oillll2iiOOE:::40iiOilii60CO:::::J80r991
Behrens and Associates. Inc.
Environmental Noise Control
les
BMCDPad
1.97 Ac.%
/
/
,,,"'.,,.
/
r W-4 --'fl--
Attachment 6
...l-..A-1----------
960 foot long, 32 ft high STC-32
Acoustical Wall
Surface Owner:
Battlement Mesa
Land Investments
BMC 0 Pad Modeled Fracing Noise Mitigation Layout
"'-
EXHIBIT
i&?Ursa Colorado Operations .· IS15
MAJOR INCIDENT
•Reportable Spill
•NOV w/ Potential Fines
•Release Off·S•te
•spill to Live Water
•Property Damage
REPORT IMMEDIATELY
TO URSA • DENVER
Venty Volumes • Inform
SPILL NOTIFICATION & MANAGEMENT PROTOCOL
(SPILLS, ENVIRONMENTAL INCIDENTSfTHREATS)
SPILL DISCOVERY • VERBAL NOTIFICATION
Contain I Control Re lease
(if safe to do so)
l If no supervisor is present.
contact your company
supervisor
No t ify On -S i te Supervisor ~
IMMEDIATELY '--~~~~~~~--1.--~~~~~~~--' L___J,_M_o_b~d.-ze-1-ni~o~~C-le-an-.u-p---. l P1ocedures
Con tact Ursa Opera tions L ead
Matt Honeycun. Operations/Construction· 970-812·2198
Hans Wychgram • Drilling • 303-884-9079
Shane Vaughn • Production • 970-623-9539
Pake Younger • Completions • 970·260·2423
Dave Hayes ·Wasatch & Water Lines· 970-250·2590
l
J
Environmental
Dwayne Knudson
970-456-3335
I
1
Unless Delegated by Ursa
lead lo anolher Ursa
representative
(pumper. conuaclor. etc)
Envlronm ental Back·Up's
Rob Bleil 720·425-0303
Kris Rowe 970-261-2015
j
I
Health and S afety
Tara Mall 970·618·2155
Land & Propeny
John Doose 970·379-0008
•
WRITTEN NOTIFICATION
1
On-Site Supervi sor to Complete Ursa Incident
Investigation Form
(Shaded area within 12 hours of discovery)
l
Ursa Leads of any volume ----1
changes
En vironmental
Dwayne Knudson
9 70-456-3335
Provide Copy to Kri s Rowe
t----41 with HCSt
I
I
l
Include Spill on Ursa Daily Report
1
URSA SPILL MANAGEMENT PROTOCOL
(Appendix B)
1
Complete Remaining
Sections of Incident
Investigation Form
(
(
«?Ursa l · "i I:•
•• , • 1 IP•d/lo"•oo
_Report Date: --------------------11
INCIDENT/COMPLAINT FORM
Dincident Ostakeholder Complaint
Nature of Complaint
Odors Noise Traffic Other Light -------
Submit Completed Form to dknudson@ursaresources.com within 12 hours
Initial Reporting (personnel that received complaint}
Occurred : Time: called In By: Ph:
Description of Complaint:
FOLLOW UP REQUIRED ( )NO ( ) YES ·Complete bottom section
SIGNIFICANT THREAT TO HUMANS OR ENVIRONMENT ( ) NO ( ) YES • Implement Emergency Response Plan
Follow Up (for Ursa Offical Use)
INCIDENT LOCATION Wind Direction/Speed LANDS AFFECTED MEDIA AFFECTED
( I Pad/Well ( I Private l I Land/Soil l )
( I Facility Ops Phase I I Federal l I Wat ers(U SJ I l
( I Midstream ( ) Split Estate I ) Wetland/Riperian I l
( I Other: I ) On Lease l I Ground Water I l
I I Off · Lease l ) Air ( )
Verification of Issue (Drive by to determine if odors exist , noise testing completed, proximity to Ursa location, etc.):
ROOT CAUSE :
Mltl&atlon Factors :
PLANS TO IMPLEMENT ADDITIONAL TRAINING (DESCRIBE):
CLOSE OUT COMMUNICATION BACK TO STAKEHOLDER:
Internal Notifications:
• Land & Property
• Health and Safety
·Operations (Const/Orill/Comp/Oper.)
• Regulatory/Environmental
Agency Notifications:
• Federal (SLM, USFS)
• State (COGCC, COPHE)
• County (Kirby)
·City
SENSITIVE AREA
3178 Area
Wetland/Rlperian
Outside buffer (>1000')
Buffer or e•clusion
(<1000')
N/A
\ r:::=JRecorded on tracking system?
(
Draft Groundwater monitoring program for proposed BMC-B and BMC-D pads
Install four-inch Schedule 40 monitoring wells with 15-20 screen inteival intersecting the shallow ground
water. Monitoring wells shall be installed in accordance to the Colorado State Engineer Division of
Water Resources guidelines.
Three monitoring wells to be installed for each pad. 1 well up gradient and 2 wells down gradient from
each pad.
Measure groundwater levels monthly for 1 year to characterize seasonal fluctuations, then measure
water levels coincident with each water quality sampling event.
Collect a baseline sample(s) prior to installing facilities and prior to installing surface casing. Quarterly
ground water quality sampling should be performed for 2 years as drilling, completion and production
activities proceed. After 2 years of sampling or after drilling and completion activities are completed,
the sampling frequency may be adjusted based on the data review.
Baseline and quarterly samples will be analyzed for COGCC Rule 609 constituents plus dissolved oxygen,
water temperature, chloride and non-overlapping EPA methods 8260 (volatile organic compounds) and
8270 (semivolatile organic compounds) constituents. Groundwater levels will be measured prior to
sampling during each monitoring well sampling event.
Sample results to be submitted to COGCC for inclusion in their publicly-accessible water quality
database using the electronic data deliverable (EDD) process and to Garfield County within time frames
required by COGCC Rule 609 (within 90-days). Data submitted to Garfield County to be submitted in
electronic spreadsheet format that facilitates data review and summary. Each new data submittal to the
county will be provided as an updated spreadsheet with new data appended to previous data. Annual
data summary reports will be provided that describe notable water quality changes or other notable
issues as well as a comparison of the sample results to COGCC rule 609 thresholds and standards.
(
EXHIBIT
Ursa Operating: l;r ~ :c
How Do We Control Pipeline Corrosion
Common methods used to control corrosion on pipelines are protective coatings and linings,
cathodic protection, materials selection, inhibitors, and coupon monitoring systems.
1. Ursa Operating uses 2 styles of Pipeline coatings to protect the Natural Gas Pipelines
against corrosion depending on the pipeline configuration. (Line Pipe or Bore Pipe)
A. Line Pipe is FBE coated (Fusion bonded epoxy coating) It is an epoxy-based
powder coating that is widely used to protect steel pipe used in pipeline
construction.
B. Bore Pipe is ARO coated (Abrasion Resistant Overlay) Used to protect FBE
mainline coatings for directional drilling, bores, river crossings and other rough
terrain applications.
2. Ursa Operating uses Cathodic Protection to protect their Pipelines.
A. Cathodic protection (CP) is a technique used to control the corrosion of a
metal surface by making it the cathode of an electrochemical cell. A simple
method of protection connects the metal to be protected to a more easily
corroded "sacrificial metal" to act as the anode.
B. In some situations an Impressed Current Cathodic Protection (ICCP) system is
used along with sacrificial metal anodes. These consist of anodes connected
to a DC power source, often a transformer-rectifier connected to AC power.
C. All cathodic protection is checked by a third party inspection company
quarterly.
3. Ursa Operating also uses third party inspection to run chemical tests on produced
liquids for bacteria and pig the pipeline quarterly with biocides to protect the
pipelines from bacterial corrosi on.
4 . Ursa Operating uses Coupon Monitoring as well to detect loss in metals to help
detect pipeline deterioration.
A. A weighed sample (coupon) of the metal or alloy is introduced into the process,
and later removed after a reasonable time interval. The coupon is then cleaned
of all corrosion product and is reweighed. The weight loss is converted to a
corrosion rate (CR) or metal loss (ML) Coupons are sampled and analyzed
quarterly. If metal loss is detected higher frequency of pipeline treating will
occur.
5 . Ursa Operating uses an assortment of products to combat corrosion in the produced
water pipelines.
A. HOPE Poly (4710 Gas} line pi pe is used for most of the Produced Water
Pipelines.
B. Flexsteel Corrosion-resistant SS 316L spooled pipe (1,500 psi 600 ANSI) is
used for elevation issues.
(
(
Ursa Operating:
How Do We Control Pipeline Corrosion
C. Stainless Steel (316L) is used for most fittings and connections.
Pipeline ROW will be inspected annually. Inspection includes checking for low spots, leakage,
staining, subsidence, pipeline makers, vegetation, erosion, and any other potential items of
concern.
Valve sets are inspected during every pigging operation.
-
I I EXHIBIT I
l:S:T~_
I ,
(
CD
3 c
~ CD
::l (
DJ ;a no 0-o CD sSB
~~ Dl Zz
-<0 0
~
Vert\ca\ we\\
bore == O degree
\nc\\nat\on . 1
we\\ per we\\
pad.
.... .j
'
D\rect\ona\ dr\\\\ng
a\\ows mu\t\p\e we\\s per
we\\ pad, and great\v
reduces d\sturbance
needed.
\opographV
cts <:IJ
e9,.ee I. True Vertica\ Depth ::
0 degree \nc\\nat\on
l'Jc/ilJ~,..
""'''OIJ
TopographV -Top of Gas
Depth. This contributes to
reach capabi\it'/
Stable wellbore from 0 deg, to 45 degree
I
•schematic eross-Se ct\on, Not to scale rr:;,Ursa ___ .. -· -U£ '~:~':-;·_ .~
Top of Gas
We\\bore vertica\ at top of gas to
intercept vertica\\V stacked
W\\\\ams Fork sands
orop section
\.!.!
l2
0 ..,
1900
3500
3700
3900
4100
~ 4300
4SOO
'1700
l\C}OO
«rursa
True Vertical Depth to TOG vs Reach
Reach actuals for BMC Band BMC D pads. Based on Topography and Top of Gas
Maximum Reach @ 45~ Inclination
2100 noo 2500 2700 2900 3100 3300
·~CBPad,2243
""~~ RMC D Pad, 2403
::-:~ .. -· .. -... , -.
-.....
• • • • •
• • • • 0 • 0
•• > •
, I ··'
I ._; ~
!>1.J.
t I
~ ~ I I
E • o o o o o • • • o o • o o o o
~ ~ ro a..
llO c
u 0 0 0 • 0 0 0 • 0 • 0 0 0 • 0 • ro
~
ti)
.......
~
~
0 0 • • 0 0 • 0 0 • 0 0 0 0 • • •
u ro
I 0
~
ro
~ ::::l 0 • • • • 0 0 • • 0 0 0 0 • • •
~~
~·-' . . . '
Possible effects of higher deviation.
• Cement Bond risks.
• Safety of wellbore.
• Channelin_g of cement/Isolation of gas migration.
(COGCC Rules)
• Proven engineering vs. wildcat approach.
• Hole collapse/wellbore integrity -Open hole.
• ~tuck pip.e issues -key seating, loss of well,
s1det r ack1ng.
• Increased of time per well during drilling .
• Formation collapsing during drilling.
• Hydraulics/hole cleaning problems -contri butes to
cement issues, washouts ect.
• Anything greater than 45 degree inclination becomes a
hazard on multiple levels.
fi?Ursa ·::'~;.·:: _....._ ............
(
(
EXHIBIT
ai'Ursa I KI( K
·: -Ef--, : :·
' "J -. I'
Introduction
HRL Compliance Solutions Inc. (HRL) is providing this monitoring well summary to Ursa Operating
Company LLC (Ursa) for the installation of a monitoring well up ·gradient and/or down-gradient of the
BMC B well pad location in the Battlement Mesa area. Specifically the site is located in Section 18,
Township 7 south, range 95 west. No monitoring wells are recommended for the BMC D pad.
The purpose of this summary is to provide recommendations for the installation of the monitoring wells
as it pertains to the location of the wells in relation to the proposed well pad, suspected depths,
equipment, and permitting for future use. Recommendations outlined below are based on 10+ years of
experience and the successful installation and completion of at least 100 monitoring wells along the
Colorado River corridor in the Piceance Basin.
Monitoring Well Location
HRL recommends initially installing one (1) monitoring well directly downgradient of the well pad on the
northwest corner to evaluate the subsurface conditions and estimate the groundwater flow direction
based on the lithology present in the sub surface. Nearby well completion records indicate that water is
present in the fluvial deposits (river gravels) at a depth of approximately 20 feet. Bedrock is noted to be
approximately 42 feet. Refer to the attached map for estimated surface water flow, sub-surface river
water flow and groundwater flow based on surrounding geology, adjacent water well logs, and site
topography.
Additional monitoring well installation will be based on observations from the initial well installation and
by Ursa regulatory and environmental staff and local or state officials.
Monitoring Well Installation
The groundwater monitoring well(s) will be installed utilizing a track mounted CME 55LC drilling rig . Due
to gravels being present in the subsurface, the wells will be drilled with an ODEX (air) system.
Monitoring Well Equipment
Based on the analyte list provided by Colorado Oil and Gas Conservation Commission (COGCC), Garfield
County officials, and previous experience of monitoring well installation along the Co. River corridor; a 2
inch diameter well will be sufficient to provide the data required . The well will be screened across the
water table and will be of sufficient length to accommodate seasonal fluctuations in the groundwater
table.
Sampling & Analysis
As outlined in the recommendations document, baseline and subsequent sampling analysis of th~
groundwater will be consistent with the analysis outlined in COGCC Rule 609.e.(2), as well as field
parameters such as temperature, pH, salinity, conductivity, and dissolved oxygen (DO).
www.ursaresources.com (970) 625-9922 Telephone (970) 625 -9929 Fax
•
.,. . . . "" • .I!"
~
-tr r ...... ~ '• ........
tr .. ,.
.,.~~
,,.. .. ----,.. ... r-~ ' .. ..,...... ......... I>
,~P-1 "~ ,.. ,,
..
~Ursa (.1.~~··..f.· ~ ~·:vrA"r-
Surf ace and Groundwater
Flow Map
BMCB
39 4311689 • 108 046134
Section 18, Township 7 South. Range 95 ~sr
D
-+
-+
Proposed Pad
100 Year
Floodplain
Surface
Water Flow
Groundwater
Flow
NOTES I COMMENTS :
' . _,
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EXHIBIT
JMMM.
DRAINAGE REPORT
URSA OPERATING COMPANY, BMC B
r.r-._.-:::""""'""',.........,..·=-
October, 2014
Revised September, 2015
PREPARED BY
6 SGM
I I 8 WEST SIXTH STREET , SUITE 200
GL.ENWOOO SPRINGS, CO 8 I 60 I
970 .945 1004
970 945 .5948 f"AX
SGM Project# 2006-479.062
PadB _ DrainReport.docx
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URSA Operating Company. BMC B
TABLE OF CONTENTS
1 Introduction
1.1 Purpose
1.2 Current Site
1.3 Methods Used
2 Hydraulic and Hydrologic Analysis
2.1 Off-Site Drainage
2.2 On-Site Drainage
2.3 Stormwater Detention
3 Hydraulic Analysis
4 Stormwater Quality Plan
APPENDIX
APPENDIX A-NOAA Atlas 14 Information
APPENDIX B -Rational Method Calculations
October 2014
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URSA Operating Company, BMC B October 2014
1 Introduction
1.1 Purpose
The purpose of this drainage report is to provide calculations for storm water runoff volumes
to be detained on-site. This report contains a discussion of both off-site and on-site
drainage and the methodology used to design various drainage elements. The designed
drainage elements ensure that storm water runoff produced from the 24 hour storm will be
detained and treated on site to reduce possible contamination off-site.
1.2 Current Site
The project site is currently a vacant lot in the Battlement Mesa area. BMC B is located on
River Bluff Road, south of Interstate 70 and the Colorado River. The site is relatively flat
riverfront land sloping toward the Colorado River. There is minimal to no grading or
improvements on the property.
The project site, in its pre-developed condition, is located in a semiarid plateau region
between 5000 ft. and 6000 ft. in elevation. The vegetative cover consists of mostly sage
brush and juniper mix. A majority of the drainage basin for the project is composed of
hydraulic soil group C and D.
1.3 Methods Used
The Rational Method was used to produce a conservative set of hydrologic flood peak
calculations for sizing particular drainage elements (i.e., the Rational Method would predict
higher flood peaks than alternative methods). The Rational Method uses the equation
below:
Q=CiA Equation 1
where:
Q = flow rate ( cfs)
C = runoff coefficient based on soil type and cover
i = rainfall intensity corresponding to the time of concentration
A= basin area (acres).
2 Hydraulic and Hydrologic Analysis
The project site in its developed condition will consist of a main gravel entrance road and
large gravel pad. Because only a small portion of the site is being developed, only these
areas will be analyzed in the detention calculations due to the rest of the site maintaining
historic flow patterns and characteristics .
2.1 Off-Site Drainage
In its developed condition, BMC B has no introduction of off-site surface drainage from other
properties. Off-site drainage for this site shall be redirected around the pad and road areas.
Therefore, no offsite drainage analysis needed to be performed.
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2.2 On-Si te Drainage
The project site in its developed conditions will consist of 2 .25 acres of a large gravel pad
area. Compared to historic conditions, construction of the proposed developed conditions
would produce a reduction in pervious ground cover, resulting in a minor change to the
runoff coefficient. This will result in an increase in peak discharge of the 24 hour storm and
detention will be needed for the stormwater flowing across the developed site. The
developed flows for the site are summarized below.
Table 1 Historic Vs. Developed Flow Rates
Storm Return Period 2 year (cfs) 25 year (cfs) 100 year (cfs)
Historic Flow 0.058 0.094 0.117
Developed Flow 0.079 0.126 0 .157
The flows shown above are determined from a rainfall intensity corresponding to the 24 hour
storm and appropriate storm return period. These intensities and the flow calculations can
be seen in the appendix.
2.3 Stormwater Detention
Area
(SF)
98,000
For the purpose of this report and this project, it will be required to detain the additional
stormwater runoff volume generated from the developed site from historic conditions. In order
to determine required detention, the developed and historic stormwater runoff volumes were
analyzed . Storm runoff volume was calculated from the 2 and 25 year, 24 hour storm
precipitation depth determined from the NOAA Atlas 14 information. These depths for each
storm return period can be seen in the appendix. The runoff volume of the site was calculated
from area of the developed site multiplied by the 2 and 25 year, 24 hour prec ipitation depth
and the weighted runoff coefficient for the appropriate site condition.
Table 2 Stormwater Flow Summary
•Rainfall •Rainfall Rainfall Rainfall Detention
General Info Intensity (I· Depth Volume Volume Volume
Historic (c u bic Proposed (cubic Needed (cubic
Inches/houri (Inches} ,..,, ,..,, ,..,,
Runoff Runoff
Coefficient Coefficient 2 25 2 25 2 25 2 25 2 25
Histori c lC)
Proposed Year Ye ar Year Year Year Year Year Year Year Ye ar
(C)
0 .52 0 .70 0 .050 0 .080 1.14 1.92 4,841 8 ,154 6 ,517 10,976 1,676 2,822
*These numbers were derived from the NOAA 14 Atlas and are for the 24 hour storm.
The maximum calculated detention necessary to capture the stormwater runoff volume
generated from this storm is approximately 2,822 cubic feet. A detention pond with this
capacity and drainage features to convey water to the pond will be provided on site. Pond
specific size calculations are attached in the appendix of this report.
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URSA Operating Company, BMC B October 2014
3 Hydraulic Analysis
The site design will require various drainage features including ditches and culverts. These
will be required to divert the storm water runoff away from the site appropriately.
4 Stormwater Quality Plan
The main goal of the site design is to provide detention for the project, and ensure the post-
development peak discharge rates do not exceed the pre-development peak flow rates.
The only area where a significant increase in runoff coefficients occur is the gravel pad and
road. A detention pond will be sized appropriately and provide a location for sedimentation
of the storm water runoff generated from the developed site. The remaining site will remain
native vegetation and provide historic flow patterns and characteristics .
There is a minor increase of runoff generated with the construction the gravel pad and
associated access road . This increase in runoff is near negligible, however; detention
ponds will be constructed on the respective pads, with a controllable outfall pipe and valve
structure. The controlling valves in the detention pond discharge pipes will each be left in
the normally open position at approximately 60% open. Alternatively, these valves can be
closed in the event of a non-compliant release, and further ensure no detrimental impact to
the surrounding area.
In order to minimize any threat of property damage, the respective pond structures will have
an 18" culvert pipe installed at a higher elevation, along with the normal use 8" discharge
pipe, in order to facilitate conveying the 100 year storm event safely to the respective outfall
drainage features. Both proposed detention ponds will discharge into existing "natural
channel" drainage features . It is not anticipated for any additional erosion and
sedimentation protection beyond that proposed at the pipe outfalls . The operator will
monitor outfall locations to ensure there is no channel scour or additional erosion cause by
the detention pond outfall pipe. Supporting calculations have been included in the appendix
of this report.
Temporary erosion control measures will be required for the duration of construction. A
CDPHE Stormwater Permit for Construction activities will likely be required . Best
Management Practices will be utilized during construction to control the stormwater runoff
during construction. Key temporary erosion control measures include installation and
maintenance of silt fence, straw waddles, inlet protection, a stabilized construction entrance
and all necessary acceptable best management practices that would relate to this project.
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Appendix
APPENDIX A -NOAA Atlas 14 Information
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Precipitation Frequency Data Server
NOAA Atlas 14, Volume 8, Version 2
locaUon name; Par achute, Colorado, us·
LaUtude; 39.4472•, Longitude: ·108.0330•
ElevaUon; 5202 ft•
• ....,., CooQlt Mapo
POINT PRECIPITATION FREQUENCY ESTIMATES
S•nJ• P•nc. Dtbof1h M•r'lln S..nd11 P1vlovtc: tt.haN Aoy Mfch .. I St lauJtnt Cad 'f~ Da ..
Untuh Mtch1tl Yak~ G1o••'Y Bonnm
NOAA . Nebooll W18thtr StMCt St~ef Spong MuyLancf
PF tabular I PF graphigil I Map1 & !e!'ia!S
PF tabular
Page I of 3
PDS-based point precipitation frequency estimates wlth 90% confidence intervals (In incheslhourl 1
Ouratlonj
1
Averaae recurrence interval rvearsl
1 II 2 11 -··5 -f 1·0 ·-JI ·· ··25 · II ··-so .. ·1 ··100··--11 ·200 l 500 I 1000-1
s.mln II p 3~~ 081 II 11 :s~ <16) Ii !2 o!~: 28)
3.23 4.32 I 5.32 I u3 I 7.72 uo I 11 1!~·:1 01 I (2 58·4 131 f341·600) : !4 03·7 •21 ~ !4 69·9 231 : f5 35·11 •1 re 37-148>
1D·mln 1.20 1.42 I 1.11 2.36 3 .16 3.89 4.71 5.65 7.03 8.20
(0 966·1 52) ' (1 15·1 80) (151·2•0) (I 88·3 021 f2 50 .4 39) f2 95·5 •3> (3•3·6.76) (3a2-833) (4 66·10 7) (5 23·12 4)
15·mln 0.976 1.16 1.53 1.92 2.57 3.18 3.83 4.59 5.72 6.66
(0788-124) (0 932·1 <16) (1 23·195) (153·2461 (2 03-357) 12 40·4421 f279·5•9) (3 19·6 77) fl 79-8 681 ('25-101)
~ 0.618 I o.7711 1.07 1.33 1.74 2.0'J 2.46 2.117 3.45 3.93
10 499 .0 1eo1~o626-o 994> 10 856·1 Je> • (106·1 71) fl 35·2 37) (1 57-211111 (1 78-3 •91 fl 98·• 191 (2 28·5 201 f2 50 -596)
1.0l • -·· 1.21 .-., B1 0.389 0 .484 0.652 ' 0.802 1.41 1.62 1.91 2.15
<0313·04921 C0390·01113J <0523·08281
0
10839·1031 10 792 ·1 381 f0 909·1 66) (101•199) (1 .11·2 35) (126·2 87) 11 37·3 26)
~I 0 ,234 ~ 0.290 11 O.lll5 0.464 0 .589 ,t, 0.6117 ll(I 0.719 0.8911 1.05 1.17
!O 1111·0 293!::(0 238·0 3621:'10 312·0 •&3 co 377·0 590 10 458-o 1ao1 o 520-0 92•1 o 575-1 091 (0624·1211) 1011911·1551 10 753·1 74 )
~I 0.1711 0.213 0.274 o .3211 I D.407 0 .471 0 .539 0.611 0.712 0 .792
(0 1411·0 221) (0 t75·0 265) (0 224-0 342 (0 268-0 "1)
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10 319 ·0 535) (0 360·0 629) f0 396·0 740 (0 4211·0 867) 10478·1 041 10 5111·118)
.. G:h; .. J~::i~~~~5) [" ·0~12' .. 'ci.161 · ·o~i89 'J 0 .228 I · 0 .261 I' a.2;4 1 o.3:is ____ 1 · ci.377 " 0~416 .
10 107·0 1581 '(0133·0198 (0 154·0 233 (0 181 -0 2951 (0 201 ·0 3421 (0 218 ·O 3971 (0 233·0 •581 .co 257-0 5431 '10 27 4 ·O 6071
12·hr 1110 o~7~8oe21 0.079 0.096 0.112 0.134 o.1s2 I 0.110 I 0.190 0 .216 0.237
·10 066·0 0951 ·10 OllO·O 117) (0 093·0.1361 (0 107·0 1701 10 118 ·0 196) '(0 128·0 2261 (0 136·0 2601 (0 149·0 3061 (0 159·0 341)
~I o.041 'i o.048 0.058 0.067 0 .080 0.091 0.101 I 0.113 I 0.1211 110 o~s~~o199 l'to 035-o 049ll'<o 040.0 o57l 10 049·0069 10056·0 081 10 065·0 1001 10 071·0 1151 10 077 ·O 133) "o 082-0.1521. 10 089-o 11111
2-day I 0.024 II 0.028 I 0.034 0.039 0.053 0.059 I O.O&G 0.075 I 0.082
(0 021·O029); (0 024·0 0331 (0 029-0040 (0 033·0 ().t7 IOO 042·00661 (0 046 ·O 076) (0 048·0 087) (0 053·0 1021 (00511·0114
3-day I 0.018 II 0.021 r 0.025 , 0.029 0 ,035 0.039 0.044 JI 0,048 I 0.05$ 0.060
'(0 015·0 0211; (0018·0 02•1 (0 022-0029 (0 025·0 034) (0 028 ·0 !142) 10 031 ·0 !1481 (0 034·0 056_ (0 036-0 064» (0 039·0 0741 10041·0083
4-day I 0.014 I 0.017 0 .020 0 .023 0.028 0.031 0.035 ~ 0.039 I o .044 I o.048
jO 012·0 017) .10 014·0 019/ (0 017·0024 (0 020·0 027) co 023·0 034) (0 025-0039) (0027·0044 0 029 -0051) (0 031·0 059) 1(0 033 ·O 068
7-day I 0.010 0 .011 0 .013 0 .015 0 .0111 0.020 0.023 0 .025 0 .021 0.031
10 0011·0 011) fO 010·0 013 l0012·0015 (0013·0 0181 ~o 015·0 0221 (0 017·0025) fO 018·0028 (0 019-00321 10 020·0 038 ltO 022 • 0 042
~I o .ooe ' 0 .009 ' 0 .010 J 0.012 0 .014 0.016 0,017 0 .019 0.021 0.023
jO 007·0 009i
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j0008·0 0101:~0 009·0012~10 010·0 014 (0012·0017 (0013·0019 0 014·0021 10 014·0 024! <0 016·0 021 '!0016 0 031
20-da [:"'o.oos 0.00& 0.007 o .ooa o.oos 0.010 0.011 0 .011 o .on o .01c I~ (0005·00061.10005·0006) (0006-0008 (0007-00091 i0007·00t0> 0008·0011) (0008-0013 ,(0009·0014 !10009·0016) 10010-0018
3 04ay 0 .004 ,~, 0.005 0 .005 0 .006 0 .007 O.OOll 0.0011 0 . ..010 0.010 -==== (000•·0005),(0004-0005) (0005·0006 (0005·0007) k0006•0008) 10006-00091 (0007-0010 (0007·0011) 10007-00'2) (0008 0013
~1~ ~ ~ ~ ~ ~ ~ ~ ~ ~ I~ 10003·0004) (0003·0004) (0004 -0005 (0004·0005JK0005·0006) (0005·0007) (0005•0008 "(0006·00011) (0006·0010) 10006-0011
~~ 0,003 ~ 0 .003 f 0.004 I 0 .004 L 0.005 ~ 0.005 , 0.006 I' 0.006 ~ 0.007 I' 0 .007 J ~o 003-o 0031::10 003.0 004!:~0 003.0 0041: !0004·0 0051=0 004·0 006!~10 oos-o 006>~!0 oo5·0 oon:·!O 005·0 ooe.::10005-00081:10 005 0009:
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chtdatd 1ga1nst prcbable maximum prec1p;t1b0n {PMP} tst1m1t111nd may be higher than a.irren1~ v•lfd PMP values
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Precipitation Frequen cy Data Server
NOAA AUas 14, Volume 8, Version 2
Location name: Parac:hute, Colorado, US•
l.atituda: 39_4472•, Longitude: -108.0330°
Elevation: 5202 ft" • """<• Googl• Mapo
POINT PRECIPITATION FREQUENCY ESTIMATES
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Pag e I of 3
PDS-based point precipitation frequency estimates with 90o/o confidence Intervals (in lnches)1
I Averaae recurrence Interval lvearsl
.Duration i-1 11 2 --v · 5 .. r-··1·0 ---11 -is .. r so .. --u 100 Ii 200 -·11 ... soo ··1 1000 __J
I S·mln I 0 .137 0.162 il~{I 0 .215 0 .269 0 .360 0 .'43 0 .536 I o .643 o.aoo 0 .933
0 110·0 173 I 10 130·0 ZllS 0 172·0 273 <0215 ·0 ~1 '(Q 2!14·0 500 .(0 336-0 6181 (0 391·0 7691 (0U6 011481 0 531-1 .221 0 595 -1 421
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0 .200 I 0.237 .I 0.314 0 .394 l 0 .527 0 .641 0.785 0.94t 1.17 1.37 10-mln <0 161 -0 253 10 191-0 3001 r.<o 252-0 400> 10 314-o so. ~o 416·0 7321 •(0492-090S> <0 512-1 131 (0 853·1 391 0 777-178) ,(0 871 ·2 07
0.2'4 I D.289 ~ 0 .383 D.481 I 0.643 0.791 D.95a t .15 1.43 1.67 15-mln .(0 197°0 309 (0 233·0 3661:.(0 300·0 4871 (0 383-06141'(0507·0 8931 (0800•1 IOI 10698-1 37) (0 797•1 091 0 948-2 17) (I 06 ·2 531
30-mln 0.309 I D.319 J! 0.534 0.667 0.872 t.05 1.23 1.'4 1.73 1.96
(0249·0 3901 ~o 313.0 492,'110 428 ·0 878> (0 532·0 8531 (0877·1.19) (0 786-1441 (0 891-1 7'1 (0990 •2 .10) (I 14·2 60) (1.25·2 981
60-mln 0 .389 -~~ 0.152 0.802 ! 1.03 . 1.21 1.41 1.62 1.91 2.15 1
(0 313·0 4921 (0 390·0 613) ·10 523-0 8281 (0839·1031 (0792·138) (0 908·1 86) 1101·1 981 (1 11 ·2 351 (126·2 87) II 37•3 28 1
G ~ 0 .469 JI o .sao I 0.110 o.936 I 1 .ta 1.37 1.58 1.80 2.10 2.33 ~0362 ·0S86~J0 472·07251.'(0624 ·0!1661(0 754-1181 1(0917-1.56) (104·185) 11.15·2.18> I 11 25-2 57> II 40·3 091 II 51·3 491
B~ 0 .536 I 0 .641 0 .124 0 .985 1.22 1.42 1.62 1.14 2.14 2.38
439·0 665 co 525 ·0 796) (0 672·1 031 (0.798 ·1 23) (0 959·181) (I 08 °189) (I 19·2221 (129·2 80) (144-3 13) (155·3 53)
·-· ·-· ,---0.661 .• I -D.77J -1a,.,, 1.13 r -1.37 -· .. ...
1.56
·-... ---2.26 -2.49 ....
6-hr 1.76 1.97
~o 548-o 809 C0 639·0 9471 !0794·118) (0 924-1 391 (I 00 ·1 77) {I 20·2 05) (I 31·2 381 11 40 ·2 75) 1(1 54-3 251 (164·364)
12-hr 0.8t9 I o.946 1.16 I 1.35 1 .6t 1.13 2.05 2.28 2.6t 2.86
'(0 885· 0 989) 10 791·1.1 4) 7 -1 41> (1 .12 ·1641 (I 29·2 05 1 (143·2 36) I (I 54·2.731 (184·313) '1 .79·3 69) (1 91·4 ti)
! 24-hr 1 0.993 1.14 1.39 1.61 I uz 2.17 2.43 2.70 3.07 3.37
10 840•1 .18) 10 964-1.36) (1 .17-1 671 (I 35-194) (156-2411 (1.71 -2 .761 II 85-3 I Bl It 97 ·3 651 12 .15-4 29) I 12.28·4 77)
2-day 1 .17 1.35 1.84 1 .90 I 2 .26 2.55 2.84 3.t& 3 .58 I 3 .92
(100·1381 (115·1581 (I 40·1 94 ) (160·2 25) (1 85·2 78) (2 03-3.19) (2 19·3 67) (2 33 -4 20 1 12 53-4 91) (2 69-5 48)
3-day 1.29 1.48 1.81 9 I z.49 2.11 3 .13 3 .41 3 .94 4 .31
(1 .tl-1 50) (127·1 731 (I 55·2. I 2461 (2 05·3 04) (2 28-3 49) (2 43-4 00) (2 58 ·4 58 1 (2 81-5 361 12 99·5 95)
4-day 1.39 1.59 1.94 2.24 2.67 3.01 3.36 3.72 4 .22 4 .60
(I 20 ·1 811 (138·1851 (1 67-2 281 (I 92·2621 (2 21 ·3 24) 12 43·3 71) !l 62 ·4 281 12 78 -4 81) (302·5 89) (3 21-a 31 1
7-day 1.63 I 1.81 2.26 2.60 3.07 3.44 3.12 4 .22 4 .75 5.16
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URSA Operating Company, BMC B October 2014
( APPENDIX B -Rational Method Calculations
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STAGE.STORAGE SIZING FOR DETENTION BASINS
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length of Basin Bottom , L • 100.00 h
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800 10200 8160
1000 10400 1~00 -1927
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UO.Oerenbon_ "1. JS· Pad B lllsx. Basin 912912015 10 16 AM
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EXHIBIT
lr11111
DRAINAGE REPORT
OCTOBER, 2014
Revised September, 2015
PREPARED BY
6 SGM
I I 8 WEST SIXTH STREET , SUITE 200
Gl.ENWOOD SPRINGS, CO 8 I 60 I
970.945 . I 004
970 .945 .5948 FAX
SGM Project# 2006-479.062
PadO _OrainReport .docx
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URSA Operating Company, BMC D
TABLE OF CONTENTS
1 Introduction
1.1 Purpose
1.2 Current Site
1.3 Methods Used
2 Hydraulic and Hydrologic Analysis
2.1 Off-Site Drainage
2.2 On-Site Drainage
2.3 Stormwater Detention
3 Hydraulic Analysis
4 Stormwater Quality Plan
APPENDIX
APPENDIX A -NOAA Atlas 14 Information
APPENDIX B -Rational Method Calculations
October 2014
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URSA Operating Company, BMC D October 2014
1 Introduction
1.1 Purpose
The purpose of this drainage report is to provide calculations for storm water runoff volumes
to be detained on-site. This report contains a discussion of both off-site and on-site
drainage and the methodology used to design various drainage elements. The designed
drainage elements ensure that storm water runoff produced from the 24 hour storm will be
detained and treated on site to reduce possible contamination off-site.
1.2 Current Site
The project site Is currently a vacant lot in the Battlement Mesa area . BMC Dis located on
River Bluff Road, south of Interstate 70 and the Colorado River. The site is relatively flat
riverfront land sloping toward the Colorado River. There is minimal to no grading or
improvements on the property.
The project site, in its pre-developed condition, is located in a semiarid plateau region
between 5000 ft. and 6000 ft. in elevation . The vegetative cover consists of mostly sage
brush and juniper mix. A majority of the drainage basin for the project is composed of
hydraulic soil group C and D .
1.3 Methods Used
( The Rational Method was used to produce a conservative set of hydrologic flood peak
calculations for sizing particular drainage elements (i.e., the Rational Method would predict
higher flood peaks than alternative methods). The Rational Method uses the equation
below:
Q=CiA Equation 1
where:
Q = flow rate ( cfs)
C = runoff coefficient based on soil type and cover
i = rainfall intensity corresponding to the time of concentration
A= basin area (acres).
2 Hydraulic and Hydrologic Analysis
The project site in its developed condition will consist of a main gravel entrance road and
large gravel pad. Because only a small portion of the site is being developed, only these
areas will be analyzed in the detention calculations due to the rest of the site maintaining
historic flow patterns and characteristics .
2.1 Off-Site Drainage
In its developed condition, BMC D has no introduction of off-site surface drainage from other
properties. Off-site drainage for this site shall be redirected around the pad and road areas.
Therefore, no offslte drai nage analysis needed to be performed.
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URSA Operating Company, BMC D October 2014
2.2 On-Site Drainage
The project site in its developed conditions will consist of 2.49 acres of a large gravel pad
area. Compared to historic conditions, construction of the proposed developed conditions
would produce a reduction in pervious ground cover, resulting in a minor change to the
runoff coefficient. This will result in an increase in peak discharge of the 24 hour storm and
detention will be needed for the stormwater flowing across the developed site. The
developed flows for the site are summarized below.
Table 1 Historic Vs. Developed Flow Rates
Storm Return Period 2 year (cfs) 25 year (cfs) 100 year (cfs)
Historic Flow 0 .065 0.103 0 .129
Developed Flow 0 .087 0 .139 0 .174
The flows shown above are determined from a rainfall intensity corresponding to the 24 hour
storm and appropriate storm return period . These intensities and the flow calculations can
be seen in the appendix.
2.3 Stormwater Detention
Area
(SF)
108 ,363
For the purpose of this report and this project, it will be required to detain the additional
stormwater runoff volume generated from the developed site from historic conditions. In order
to determine required detention, the developed and historic stormwater runoff volumes were
analyzed. Storm runoff volume was calculated from the 2 and 25 year, 24 hour stonn
precipitation depth determined from the NOAA Atlas 14 information. These depths for each
storm return period can be seen in the appendix. The runoff volume of the site was calculated
from area of the developed site multiplied by the 2 and 25 year, 24 hour precipitation depth
and the weighted runoff coefficient for the appropriate site condition.
Table 2 Stormwater Flow Summary
*Rainfall *Rainfall Rainfall Rainfall Detention
General Info Intensity ,, • Depth Volume Volume Volume
Historic (cubic Proposed (cubic Needed (cubic
lttchesthour} (Inch••!
'"'' ffftJ , .. ,,
Runoff Runoff
Coefficient Coeffi ci ent 2 25 2 25 2 25 2 25 2 25
Historic cc> Proposed Year Year Year Year Year Year Year Year Year Year
(C)
0 .52 0 .70 0 .050 0 .080 1.14 1 .92 5 ,353 9 ,016 7 ,206 12 .137 1,853 3 ,121
*These numbers were derived from the NOAA 14 Atlas and are for the 24 hour storm.
The maximum calculated detention necessary to capture the stormwater runoff volume
generated from t~is storm is approximately 3 ,121 cubic feet. A detention pond with this
capacity and drainage features to convey water to the pond will be provided on site . Pond
specific size calculations are attached in the appendix of this report.
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URSA Operating Company, BMC 0 October 2014
3 Hydraulic Analysis
The site design will require various drainage features including ditches and culverts. These
will be required to divert the storm water runoff away from the site appropriately.
4 Stormwater Quality Plan
The main goal of the site design is to provide detention for the project, and ensure the post-
development peak discharge rates do not exceed the pre-development peak flow rates.
The only area where a significant increase in runoff coefficients occur is the gravel pad and
road. A detention pond will be sized appropriately and provide a location for sedimentation
of the storm water runoff generated from the developed site. The remaining site will remain
native vegetation and provide historic flow patterns and characteristics.
There is a minor increase of runoff generated with the construction the gravel pad and
associated access road. This increase in runoff is near negligible, however; detention
ponds will be constructed on the respective pads, with a controllable outfall pipe and valve
structure. The controlling valves in the detention pond discharge pipes will each be left in
the normally open position at approximately 60% open. Alternatively, these valves can be
closed in the event of a non-compliant release, and further ensure no detrimental impact to
the surrounding area.
In order to minimize any threat of property damage, the respective pond structures will have
an 18" culvert pipe installed at a higher elevation, along with the normal use 8" discharge
pipe, in order to facilitate conveying the 100 year storm event safely to the respective outfall
drainage features. Both proposed detention ponds will discharge into existing "natural
channel" drainage features. It is not anticipated for any additional erosion and
sedimentation protection beyond that proposed at the pipe outfalls. The operator will
monitor outfall locations to ensure there is no channel scour or additional erosion cause by
the detention pond outfall pipe. Supporting calculations have been included in the appendix
of this report.
Temporary erosion control measures will be required for the duration of construction . A
CDPHE Stormwater Permit for Construction activities will likely be required. Best
Management Practices will be utilized during construction to control the stormwater runoff
during construction . Key temporary erosion control measures include installation and
maintenance of sill fence, straw waddles, inlet protection, a stabilized construction entrance
and all necessary acceptable best management practices that would relate to this project.
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URSA Operating Company, BMC D October 2014
( Appendix
APPENDIX A -NOAA Atlas 14 Information
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Precipitation Frequency Data Server
NOAA AUas 14, Volume 8, Version 2
Loeatlon name: Parachute, Colorado, US"
Latitude; 39.4472•, Longitude; ·108.0330•
Elevation: 5202 ft"
~ IOUfCI Googtt MIOI
POINT PRECIPITATION FREQUENCY ESTIMATES
Page I of 3
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\Jntuh. M1ctr.1el Ye~ Geo1fery Bannin
NOAA. N1llon1I Weat"8r SerY1CI SdYtf Spring M1rylal'd
PF tabular I PF graphical I Maos & aerials
PF tabular
PDS-based polnt preclpftation frequency estimates with-90°/o confidence Intervals (in inches/hour)1
Ouratlonl
Average recurrence Interval (years)
1 ]I 2 ir 5 --1 10 · 1 ·2s II so-r ·100 H 200 · 11 ·· 500-·r 1000 -1
s-mln 1 1.64 ! 1.94 11 2-58 3.23 I 4.32 II 5.32 ~ 6.43 II 1.12 I' 9.eo I 111!~~7 0) I (132-208) : (1 56 -2 46J :, 12 06·3 281 I !2 58-4 13) ~ (3 41-6 OOJ :: j4 03 -742) ~ !4 69·9 23J :: (5 35 ·11 4l :1 (6 37-U 6)
i 10-mln 1.20 1.42 I 1.88 2.36 3.16 l.89 4.71 s.65 Ii 1.03 8.20
(0 966·1 52J (I 15·1 80) t(l51-240) (188-3021 (2 50-4 39) 12 95-5 43) i (343-6 76) (3 92 ·8 33) I (4 ee-10 7J (5 23·12 4)
15-mln 0.976 1.16 i 1.53 1.92 2.!7 3.16 I 3.83 4.59 5.72 6.66
(0 788·124) (0 932·146) : (123•1 95) (153·246) (2 03 -3 57) 12 40-4 42) (2 79 -5 491 (3 19·6 77l .,~ ~ 0.618 1(0 s~6'?o89841 I 1.07 1.33 1.74 2-09 2.46 2.87 3.
0 498·0 7801 !(0856 ·136) (T 06·1 71) fl 35· 7 (1 57 ·2 88) (1 78·3 491 ( 11 0.3119 . I o.484 i 0.652 0.802 1. 1.21 i "1.41 1.62 1.91 2.15
(0 313·0 492) (0 390·0 6131 '(0 523 ·0 828) (0639-1 03) (0792 8·1661 I c101-1 9s1 (1 11 •2 35) (126-2871 137-3261
~~01~i~293) 0.290 i 0.385 0.468 0. 0.687 ! 10 s~:~: 091
0.198 1.05 ! 1.17
0 236·0 3821 '10 312 -0 483 I ro 3n-o 5901 0 458 ·O 780 ro 520·0 9241 IC0624 •1 281 : (0 698-1 55) I 10 753 1 741
~ 0.178 0.213 I 0.274 0.328 0.407 0.471 I o.539 0.611 0.712 ' 0.792
(0 148·0 221) (0 175-02651'(0224-0342) (0 ~-0 411) (0 319·0 5351 10 360·0 629) ~o 396-0 7401 (0429·0 867) (0478-1 04) (0 516 ·118)
~·-·0.110 I 0.12,-r ·a :1s1 -· -o:m J o.228 • -0 .-261 r ·o.294 1 o.329 -0::;11 · -i o.416 6 -hr io 092-0 135) 10 101-0 1sa1·(o133.0 198) (0 154-0 233J (0 181·02951 10 201·0 342) (0 218-0 3971 (0 233 ·0 456) (0 257-0 543) '(0 274 ·0 607
~I 0.0&8 ~in 0.019 f o.096 -0.112 0,134 0.152 I 0.110 0.190 0.216 I o.237
io 051-0 08' 066-o 0951 '(o oao-o 117) ·(o 093.0 1381 (0 107-0 1701 10 116 -0 1961 (0 128 ·0 2261 (O 135 -0 26" ~49·0 3061·ro159-o 341
~ o.041 I o.o..., o.os8 0.0&1 0.080 0.091 i 0.101 0.113 0.128 0.140
0 035-0 049)1 1<0 040·0 0571:·10049 -0 069)110 056·0 081) co 065-0.1001 10 071 ·0115) ~o 011 -o 1331 I (O 082·0 152 89·0 11~1 lro 095 ·0 199
~I 0.024 0.021 I 0.034 o.o3s 0.047 0.053 0.059 I 0.066 0,075 O.D82
(0 021 ·0 0291 (0 024-0 033) (0 029-0 040) (0 033-0 047) (0 038 -0 058) (0 042-0 066) '(0 046·0 076) (0048-0087) 10053-0102) (0056·0114:
~I 0.010 1 0.021 0.025 0.029 I o.035 0.039 I o.044 I~~ JD 015·0 0211 CO 018·0 0241 (0 022·0 029l lO 025·0 0341 . (0 028-0 0421 (0031 ·0 048) .(D 034·0 056)
I 0.014 0.011 i 0.020 0.023 I 0.028 0.031 0.035
(0 012·0 017) (0 014•0 019) {0 017·0 024 (0 020·0 OHJ . (0 023-0 034) (0 025-0 039) 'co 021 -o 044)
jl 0.010 I 0.011 0.013 0.015 0.018 0.020 0.023 1 7 -d~y (0 008·0 011) ,(0 010·0 013)1>0 012·0 015110 013·0 018) (0 015·0 022) COOH·O 0251 (0 018·0 0281 1'(0019 003 020 00 022 0042'
~~ 0.008 11 0.009 11 0.010 0.012 0.014 0.016 0.017 I 0.019 I 0.021 0.023 ~O 007-0 009):·!0 008·0 010!;'~0 009·0 012 !O 010·0 014) 0.012·0 017 0013·0 019 1'10014-0021) '!O 014·0 024 ,·. 0 016·0 0281 0016-0031
8~ 0.005 0.006 I 0.007 J 0.008 0.009 0.010 I 0.011 0.011 0.013 0.014
' • ay o 005-o 0061 ,(O oos-o 006> .10 ooe-o oos (O 001-0 0091 <O 001-0 0101 (O 008-0 0111 (O ooe-o 013> JO 009-o 01• 10 009.0 0161 10 010-0 01s
~~ ··-.II ·-I ··-.... -... , , .... , ..... m ..... [ ..... o 004·0 005),,(0 004-0 005) 10 005·0 006) (0 oos-o 0011 10 006·0 008)(0 006 ·0 0091~001-0 0101 .(0 001-0 01 ro 001 -0 012) .co oos-o 013
~~ 0.003 11. 0.004 ! 0.004 I 0.005 0.006 D.006 i 0.007 0.007 0.008 D.008
0 003·0 004) (0 003-0 004) jO 004 ·O 005) (0 004·0 005) 10 005-0 006) CO 005·0 0071 '(O 005·0 0081 (0 006·0 006·0 0101 (0 006·0 011
~~ D.003 II 0.003 I D.004 I 0.004 ~ 0.005 II 0.005 I' 0.006 0.007 0.007 ~o 003-o 003);!10 003-o 004 ~o 003-o 004~ 10 004-o 0051~10 004-o 0061::(0 005-o ooe1~'10 005-o 001 o oos-o ooe1 (O 005-o 00~1
, Pnta;>ilat1on frequency {PF) est1ma•e1 m lh~s tabfe are based on fn1quency •nalysi1 of p•rlial duratt0n series (POS)
Numbers in parenlhes;s are PF est1matet 1t l~r and upper bounds of the 90% conftdence lnttr"Yal The prob1b1hly that preapdat1on frequency estimates (tor a
g11111n durabon and 8'1erage reaJrTence enlervaS) ¥Ad be greater than the upper bound (or less th.In the lo\\oer bound) ts 5% Estimates at upper bcundt are no1
,checked 1g1ins1 probable ma:i1mum precip111tion ~PMP} est1mate1 and may be tugher Ulan currently val.id PMP values
Please refer to NOAA AUas ,, dOOJment fot more infonnallon.
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Precipitation Frequency Data Server
@ NOAA Atlas 14, Volume 8, Version 2
Location name: Parachute, Colorado, us·
Latitude: 39.4472', Longitude: ·108.0330'
Elevation: 5202 ft'
•IOUlte GooQloMtllO
POINT PRECIPITATION FREQUENCY ESTIMATES
StnJI P~ Oet.•h M.,_n S&ndtl Pavlovte, W'llN RoY Msthael St t..1urent. Cati T1y~ 0•19
Unruh Mte:hl-4 Y tlt•. Geofl1ry Bonmn
NOAA . Naa.01,., W••1h•r StMC•. Sit.let Spnng . M•rvtend
Pf tabular I PF graphical I Maps & aerials
PF tabular
Page I of 3
I PDS·based point preclpltatlon frequency estimates with 90°k confidence Intervals (In lnches)1
Du ratio
II Average recumnce Interval fyearsl
j 1---1 : 2 --,, -5 --·-~ ---;o---11 --25 T -· so 1: 100 I 200 [ 500 I 1000
8 1 0.137 I 0.1&2 f 0 .215 0 .269 0.360 0 .443 \~(I 0.536 !,o .~~39'81 0 .800 0 .933
. • '10110-0 173 !O 130-0 205!
0
jO 1n·0273) (0 215·0 34• (0 284 ·0 500) o 336·0 e1e1 o 39H> 7691 0 531·1 22) 10595·142
10·mln 0 .200 I 0 .237 0 .314 0 .394 0 .527 I o .648 0.785 0941 1.17 1.37
~o 1e1·0 253 10 19 1·0 3001 (0 252-0 400) ,10 31•·0 504 ) ·10. 16·0 7321 .10 492·0 9051 (0 572 ·1 13) 10653·1 39) o n1.1 78) (0 87 1·2 07)
15-mln 0 .244 0 .289 .I 0 .383 0 .481 I o .643 0 .791 0 .958 1.15 U3 U7
(0 197·0 J09 10 233 ·0 3661.-0 30&-0 •&7J (0 383·0 614 1 0 507·0 893! (0l!00·110) (069&·1 37) co 79l·169) 0 908·2 171 (1 0&·2 53)
30-mln 0 .309 I o .319 o.534 0.667 I o .m 1.05 1.23 1.44 1.73 1.96
~o 2•9·0 390 (0 313·0 4921 10 428 ·0878) 10 532 0 8511 10&77·1191 (0 768 -144) /0891 ·1 74) (0990·2 101 (1 14 ·2 601 (125·29&)
[ 0 .389 co . .a.c 0.652 --0.802
..
1.0l 1.21 u1 y:u2 1.91 2.15 60·mln ~ (0 313·0 492 ,10390-08131 ·o 523 ·0 eze1 10 839-1 031 10 792-1 .38 ) (0908 -1681 (101 -1 9&1 _ 1.11 -2 35) (1 28-2 87) (1 37 ·l 26) g1 G.46' I o.sao 0.771> 0.936 1.18 1.37 1.58 1.110 2.10 2.33 I
(0 382·0 5e6 ·10 472-0 725 '10 824·0 968) ! co 75'1 ·1 181 10917·1.56) (1 D-t ·1 &51 11 15-2 181 l1 U ·2571 11 •o 3091 1151 ·3•91.
~ 0.536 0.641 0 .124 0 .985 1.22 1.42 1.62
;1 ~~:601 I 2.14 2.ll
i l-hr ~o 439·0 605 :co 525·0 7961 10 &72 ·1 03 ) (0 798·1 231 (0 959·181) (1 08 •1 &9) (119·2 221 (1 44.3 tlt (1 55 .3 53)
~I""' ~ r>.773 0.963 · · r .. ,.13 "1:31-·. 1.56 -I 1.76 --·-·1.tf --i'ii -2.49
' 6 -hr ·co 548-0 809) 0 639·0 9471 (0 711-1·118 1 (0924•139) (1 04·1 771 (120 ·2051 (I 11 •2 38) n •~·2751 (15-1·3251 (\ 64·1641
' < 0119 0.946 1.16 , 1 .JS 1.61 1.83 I 2.05 2.28 2 .11 2.86 i 12-hr 10885-o9e91 10 791-1141 (0967•1 41 111 (1 12·1 .641 (1 .29·2051 (1 43·2 36) (15•·273) [1 64-3.131 11 79·3 &9) 11 91 ·411)
, 24-hr 11 0.993 I 1.14 1.39 i 1.61 I 1.92 I z.11 2.43 2.70 3 .07 3 .37
i 10 840· 1 18) (0 96'-1 36) (117•1 671 (1 .35·1 90) ' [1 .56•241) : 11 71 .,2 76l ll 85 · 3 181 <197·3 651 12 15·• 291 12 2e .4 m ,_
1.17 I 1.35 1.64 I ur> 2.26 2.55 2.84 3.16 3 .51 3 .92 I 2-c1av (1 00·1 38 1 (115·1 581 (I 40-1 941 (1 60 2 25) (185·2781 (2 03·3 191 (2 19·3 67 ) C2 Jl•4 201 12 53·491) (2 69·5 461 I~
1.29 1.48 1.81 2 .09 2.49 r 2 .•t 3.13 3.48 3 .9" 4.31 I 3-day (1 11-1 501 (127·1 73) {I 55·2.121 (1 7& 2 •81 (2 05·3 041 (2 28·3 491 (2 43 -• 00 1 !2 58·4 581 1281·536) !2 99 .5 95) -3 .72 4-day 1 .39 1.59 1 94 2 .24 2.67 3 01 3.36 4 .22 4.60
(120-161) (1 38 -1 &5 1 (1 87-226) (192·2821 !2 2 1·324) (2 43 ·3 71 J (282 ·• 26 ! 12 7& • l7l 1302 -5 ~ (3 21 ·6 3 1!
~
j 7-day 1.13 1.87 2.26 2.60 3 .07 3 .44 3.82 4 .22 •.75 5 .16
(1 42 -1 67) (182•2141 11 98 ·2601 (2 2•·3 00) 12 58·3 881 C2 80 ·4 191 !3 0 1-• 78 1 1318·5 441 113 4•~ 321 13 64 ·8 991 = I 1.15 I 210 2.52 2.87 3 .37 -l .76 4'.16 4'.56 [1 1 37~~:1.1 5.54 10-day . jl 62 ·2 101 : 11 84 -2 39 1 12 20·2 8 71 12 49 -l 29 ) ' 12 83-• OCl 13 Cle -• 5'1 1 t 3 29·5 151 13 45-5 841 lt3 93 •7 431
20-day 2.47 I 2.76 fi4 3_64 4 .19 4'.61 5.04 ~ 6.06 I .SO
(219·2771 r2 •S ·310l f2 11&·3 641, ll 19·• 111 (l 55-4 89) _c 3 aJ-5 471 (4 04-6 14 (4 21 -6 88 1 (4 48·7 841 (4 68·8 57)
30-day 2.99 I 3.33 3.89 73r"' 4 .96 5.43 5.90 I,.~~;,., 6.98 7.4"
!2 87 ·3 321 I 12 97.3711 (3 45-• 3:11 1384·4811 (4 24 ·5 73l 14 54·1$ 38\ 14 76 7111 11521-811-t 1 15 41 ·9 72 1
45-day 3.64 4.07 4'.17 533 1 .08 6.64 7.17 7,70 -8 .38 8 .86
(3 27·4 01 1 I 13 68-4491 14 27·5 271 •• 74 .5 92 1 1522·6 931 15 57-7 101 1583-855) (6 01 ·9 •&l :6 29-10&1 1650 ·1151
60-day I 4.18 I' 4.12 I u1 ;r s.2s l 7.13 7.71 8.40 8.99 9 .73 10.2
: (3 n .4 581 : {4 28·5 m ~ (5 Ot ·612~_c s 59-6 90t. (II 14 ·8071 11 ((I 58-8 ff• f(l 85 ·9 921 11 05 10 "1 ,j7 34·1Zll i (7 57·13 21
~1 Preap1labon frequency •PF, est1mate1 in lh11 lab'9 ate blhd on treque~ 1n•ty1i1 at P•rt11t dur1hon senes (PD$!
("umbers 1n par1nthe1.is are PF et.bm1te1 •t tower 1nd upper t>ovnds ol U'lie 90,._ confid1nc1 rnlerva• The prob•thllty thlt prec;,p.t1Mn frequency flllt1males 4fot 1
:Q:rver\ durl,.on Ind average recum1nce 1nl8'Vll) Wl'll be grelltr 11\an ltwt upp1r bound Car less than lfle Cower bound) n $t.li. E1bm1teJ. 11 upper bounds Ire not tecked 1g11n11 prob1bl1 m111:1tnu:m pttCt"p•t1t1on (PMP> tthm1111 1nd may bt ~;her than a.rrently v.ahd PMP va!uet
eaw refer to NOAA Allis 1• dOCument 1or more inlormlban
Bac!s to Too
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http://hdsc.nws .noaa.gov/hdsc/pfds/pfds_printpage .html?lat ""39.4472&1on=-I 08.0330&dat... 9/30/2014
URSA Operating Company, BMC 0 October 2014
( APPENDIX B -Rational Method Calculations
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STAGE·STORAGE SIZING FOR DETENTION BASINS
Pr~ect:~P~•~d~D'--~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
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SIO<age Requirement ftl)<n Sheet 'ful .Spectrum"·
Bas'" Bason SUifate Sutface
Wodlllat lengUI at Atta al Ateaat
Stage Stage Stage Stage
It h ft' ft' u ...
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UO.Oecenbon.112 35 ·Pad O.llsx. Basin 9129/2015, 11.04 AM
(
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Analysis of Geologic Hazard Report
With Consideration to Supporting Pipelines
Prepared by Robert L. Arrington, BSME , PE
October 3, 2015
Battlement Mesa Drill Pad B Location
EXHIBIT
looo
CONTENTS
Preface .................................................................................................................. ii
Summary ............................................................................................................. 1
Analysis ............................................................................................................... 3
Figures ................................................................................................................ 10
Extracted Pages of Report 4-203.G.4 .....................•.••••••••••••••.........................• 15
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Preface
A review of the Geologic Hazard Report (hereafter "Report") was made with respect to
the site application and comments have been made to data, conclusions and findings.
Additional data, considerations and suggested recommendations have been assembled
in Analysis.
The entire 4-203.G.4 original submittal to the Planning Commission is not included,
only copies of the pages addressed. Pipeline information is added because of
location and connection to the Pad B from Pad D with reference to utilities
The Garfield County Land Use and Development Code (LUDC) has 3 points of
applicability to the analysis that are identified as B. Landslide Area, C. Mudf/ow Debris
Area and E. Potentially Unstable Soils wh ich this area poses problems and creates
hazards unrecognized in the Report .
The Geologist Kevin J . Taylor affixed his Stamp o the Report, prepared by
Geologist James Hix, but Taylor states, "However, I have not visited the proposed
site, ... ". The geologists then rely heavily on the use of geological maps to reach
conclusions. I would assume Hix was author under the supervision of Taylor. The lack
of site visitation by the one supervising can pose problems i.e. if, there are other
materials, maps or information that does not get site related or if there is missing 3
dimensional visual observation that does not get considered. Observation of local recent
happenstance can be missed that could be included in evaluation. It is not known if Hix
visited the site.
The Report defines " ... the types of natural and geologic hazards pertain to the
following:" Then it lists A. through I. of Developments i n natural and geologic hazards.
The Analysis examines and comments on those topics : C . Landslide , E. Alluvial, F.
Slope , G . Corrosive or Expansive Soils and Rock, H. Mudf/ow Areas, and I. Development
Over Faults in the Sections labeled 2 .0 General Site Location and Background and 3.0
Natural and Geologic Hazard Assessment of the Report.
In the attached, Report 4-203.G.4 16 pages extracted, particular lines are highlighted
where analysis was made or commented about.
The Analysis follows the Reports outline format to further locate, more specifically, the
topic examined.
ii
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Summary
The Geologic And Soil Hazards Report, Article 4-203.G.4, summarizes itself as:
1.0 EXECUTIVE SUMMARY
Olsson .t..ssociates (Ol:ison} w:ia =ntracted by Ursa Operating Company to OIS$e!SS natura and
s;;eolog'c hazards polentla ly present In !tie area or the i:iropo~d 6MC 6 producl 01i well p.id
loc:sted In the s-.N ~~NW~ Sectlcn 1 e . Towni:;h :p 7 S0\11:°1, Range 95 -.,vest. of the 6.-Frincl;ial
Mer.dian. Garfield County, Colorado The site Is at n n e1e,,.at on of about 5,09C f!tt!I nbove mean
sea evel famsl}, The she :iettlng s shown on the iittached BMC B Pad Adjacent L.-.nd Use
Map .
Ttie ;iurpos.e of this re:ior. IG to Identify geologic: ccnd:tions th1;1t may pose hao:ards to 1:1 land
de'.leloprr.ent projec:t in order !!'lat ap1=1oprlote m-tlgat::m or avoidance tec."ln;Que:i m<J'l' be
impten·ented mi descr tbed .n the Garfield County LUDC According to the G::irfteld County
LUOC, Section 7-207. the types of natura :md geolog c hazards ident1ied :>ertain to the
folla.'I ng
A. UUlfties
B. Devel opn·ent In Avcilanche Hazard Area:!I,
C. Ceve l opn~ent In Lan:lsl de Har.1rd Are:ss ,
D. Ce·~e 1 oi:n·ent In Rock-ra.I Hazard .i>.reas
E. Oeve l opn~ent In Anu ... 1a Fan Hazard .t..reas
F. Slope Oeo/elopment,
G. Cevelopn·enl on Corro!liv"' or exp;insive So.l!I an:t Rock,
H. Developn-ent In Mudflow Areas t1nd
I. Cevelopn'8nt Over Fau.ts
Th.!!l report pre!lents C l!lson findlng9 follo'Ning nn e·Jaluation of Chese and other geolog c
h:izards potentl al y affecting lhe site and proposed de11e·opn•.enl Tl'.!e Urs3 Operating Company
!lite was found to be suitab le for the pro;:i~ed developn,ent with cons derat on or the fo lowing
Identified geoogic hazards,
The so ;ls in tne voc ·nlty of the s. te ore corrosive to l;oth stee and concrete due to hic;ih
~I! conten1 and lhe subsal. laj!ers h ave an vh snrtnk-sweu potenun·
Acccrdlng to t li e Prit lmlnary Geo'ogic: ML!p or the Grand Valley Quadrangle, Gar1ie d
County, the proposed site is located on Quatemar1 age (~olocene t alluvium. terrace
de;:ioslts, and underlain by ·pre-histor.c" mudnow and fan gravel de;ioslta
The s ·te Is not mapped oo being in on Al uvial Fan Ha;:ard area, but is ·ocated on nlluvlol
fan de~sits ns:i.odated with Monument Gulch and unnnmed f nterm ttenl drainages
The 'Ue Is !'lot mopped with.n the FEMA 100.yew flood ptnin, but is ocalecl within 400
feet ot t he Co Or<ldO River ti is about t .000 feet northeast o1 Monument Gulch en::I :?·:O
feet southwe!lt of an unnan•ed lntermirrent d r ainage, T?le5>e droinagea are ::rone to r 03h
roodo
The BMC B Pad can be con:e.lructed to c::rnpensnte for these lm;tQtion:1 nn~ potcnua. hazards,
Th.s report should be read •n its e1itlret-1. including bur nol im1ed to the concluslono end
recommendations In sect Ofl 4 O
G•c:og1:: H.a;:.>.-:1 R•pe>rt Cl:;~o., A.:.::oc.t•:e.:
l..rs.> Oper.>trng Company BMC B P"d
Q.affi• ~ co ... n~y c 0
Oc•d•n. Cclo~do
OC:c.b.-:o i.:
And, the Report is reviewing the following involved criteria:
The l.UDC defines o t-'.o::ard Area aa ~An area t!lOl con:oir..!I or 1s dlrecUy affecte·:t by a aeolOQJC
hazard. lm:lz.dma out not 11ml:ed to tr.e follo•vmg types of ore.:is ••
A .
c
c
Allaanche Area, "A rr.llss of snow or 10: on:t orr..er material that moy t:e:orne
1ncorpart:Jtod lllerein as :iucn moss mov~s rapdly :1011.1n o :Jo~ "
Lands.Ide Area •An area wi:h cternonsrr-:Jb/)' DC~ mass movem<:>nt of roe/< and
soil wher. there i s a cti=:nc: surf::.ce rupture or =ne of ,_akne$.$ that se~rores
the! lar.dsl1dt: moten'ol from more star:le undertpnQ moten'o/ •
Mu<l11ow Debris A.rea . "An area subJect to roptd mud and debns movement or
cJeposJt oc::urrlr.g alter mc::b/lizotlon ty heovy r.iinfofl or sno•vme:r rvnc::rf Such
areas a~ formed by twCt:"eS$/ve episodes of d!J~fflon of mud and d!>brf:t •
R:idtooct1\'e Aren ~An tirea subject to va:ious types of rad;o:ion e/tllssion from
rad1ooctive mmerois mot o::r:u1 In nat.:ral or ~nmn* d~poslt:; of rock, son, or
v.;ater_MI
PoientJ<Jlllf Un!Ot:ible Soi:s ~An nreo cf land 1dentil1ed a .!:' h•ivir.g sc::.1s tr.at m.oy
ca1.1s~ domoge to suuctures. such as lJuildlr.gs and rooclwa.r.; as o re=lt of o~~r
stltu!'aOon or ::om-:t otht:r cuts1:1e 1nnr.,;er..ce."
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( The Analysis read in its entirety, finds problems with above B ., C., and E. when
measured against the Conclusions and Recommendations and the narratives
supporting that content in the Report.
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• The BattlemenUMorrisana mesas are basically one in materials composition and
landslide/slump origin. The Pad B site, a terrace below the main Battlement mesa,
is an alluvium fan from drainage of the mesa . There are no indications stability
tests and sampling was done or recorded i n the Report. The stamping geologist
admits not visiting the site.
• The soils are corrosive to concrete and steel and utilities, including pipelines, will
be in a bore coming down a steep slope . The pipelines will require concrete and/or
steel anchoring systems. However, WPX's failure of such a pipeline that occurred
in this same area and expected environment, is not part of the Report's
consideration. The steep slope, and its' potential failure in landslide/slump
•
effects , was not addressed. This pipeline system may have additional corrosive
problems from induced A .C . electrical current from proximity to power grid lines .
Maps used to evaluate structure cited two maps, referred herein as 1973 and
1986. The 1973 map was a compilation of quadrangle maps, but there is no
history that the Grand Valley quadrangle had any prior mapping until the 1986
Preliminary surfacial. The 1986 map did not show any structural data. This means
that the finding of "no mapped faults" CAN NOT imply there are no faults in the
area of the site. Seismic testing for faults is needed. There is a U .S.G.S . map that
does show Precambrian basement faults projected ; and, they tie into a block fault
to the Southwest that could all have implications to the development.
• Three Garfield county geologic hazard maps were used as a basis to discount
hazards on the basis they did not show site problems. This is misleading as the
areas evaluated do NOT lie within the confines of the studies' boundaries. The
statements of maps not showing hazards South of the Colorado River, while true,
misleads because it is outside the study area .
• During the time the Report was made, there was active planning of an injection
well for produced water, holding tanks, and pump house. These features would
add even an extra burden on the Pad site and the possibility of subsidence or
sink holes. The Report should have invoked further ground tests. Such conditions
found on site have created sink holes in Carbondale. For injection operations,
the basement fault should be considered particularly with earthquake potential
having been upgraded for 2015 by the U .S .G .S .
• For the LUDC types of natural and geological hazards listed in the Executive
Summary of the Report, items C., E., F., G., H ., and I. have shortcomings that
need further examination or requirements of remediation.
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Analysis
(Using Report Outline Format)
2.0 General Site Location and Background
2.1 Project and Site Description
2.2 Structural Geology
Of the two maps, dated 1973 and 1986, only the 1973 map contains structural
information. These maps should've been provided, as all assumptions of "no
mapped faults" in the area are predicated on the 1973 map of data of 42 years
age or more and a quadrangle area on the map boundary. Further, the 1986 map
is a surfacial "Preliminary Map" with no structural mapping of underlying
formations done . Later, the statement is made "There are no known faults ...
mapped in the area of the site." after discussing blind faults . This area is covered
with hundreds of feet of mud flows and slumps with large boulders, rocks and
gravels underlying. Visual observation shows escarpments on each side of the
valley and the Colorado River's path gives linear construct clues to the
presence of faults . Then there is a U .S.G .S. map of two parallel projected
Precambrian basement faults, in unmapped formations of the basement, running
Northeast with one along the Battlements and the other along the river. These
two faults connect to cross faults on their Southwest ends resulting in a block
formation, and by surface topology, appears raised on the Southwestern edge.
This could contribute to the Northeastern gas formation beds between the parallel
faults dipping from 3900 feet depth to 5000 feet deep in their progression under
Battlement Mesa to the Northeast. This drop might involve faults perpendicular to
the parallel faults and in formations above the bedrock. See Figure 1 & 5
The Report statements of "no mapped faults" can not be construed to mean there
are "no faults", it can mean there has been "no mapping" as well . In addition, WPX
did an extensive seismic study in the last two years that was possibly predicated
on both insufficient information available and their encountering unmapped faults,
low amplitude folds, and variable top of gas formations. It would be prudent to
seek a WPX sharing of information if possible.
2.4 Soil
The Report warns of corrosive to "steel and concrete" and large amounts of clay
and salts, high shrink-swell and steep slopes and "water capacity" high.
Loam combined with fine pore clay (silty clay loam) indicates it can hold water
content trapped in small pores . Erosion hazard is severe. This means downpour
rain can cause quick washout in absence of plant roots holding and taking water
which results in unstable washing soil. Engineering beyond the Pads is important
and vital , but is not suggested. The run-offs to the Northeast gully must be
abated . Since this gully feeds upstream of the Battlement water inlets , abatement
might include storm drainage piping to the Southwest and drainage downstream of
the inlets.
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2.5 Aquifers
The Report talks of the wells and water depths.
Battlement Mesa has three emergency water wells upstream of Pad B. These
wells are independent of the river water table according to the BM Metro District.
They must be sampled before and after any drilling.
3.0 Natural and Geologic Hazard Assessment
3.1 Utilities
The Report states, " ... however, it is expected that these limitations can be
overcome with proper design and installation." The design shows no automatic
pipe failure shutdown, consideration of A,C. induced current corrosion or
consideration of induced failure by moisture penetration of bore hole.
The use of pipelines must take account for the corrosiveness. The pipelines bored
down the side of the gully from Pad D must be anchored and these anchors
must be protected. Moreover these pipelines are in proximity of high voltage power
lines, and can have induced voltage.
See: Induced AC Interference, Corrosion & Mitigation
http:llwww.allanlapioeliners.com/wJM:onlenVuploads/2012/09/2013 04 08-AC-nterference-Cooosion-Miliqalion ,pelf
This link gives methods of testing and considerations of this effect.
This pipeline system must be protected from moisture in the bore. Moisture can
get in the bore from external and internal paths. Moisture in the soil can cause
mudslide or slump and tear out the pipes and electrical or any other lines such
as telephone. Warning of produced water into the gully and into the river above
the water supply inlets would not be possible in time to prevent intake. The bore
is a destabilizing feature and the possible result is could be like the WPX failure.
3.3 Landslide Areas or Potential Landslide Areas
The Report says, " ... , except for very recent slumps and mudf\ows." and puts them
on the "East side in 7.5 minute quadrangle" on a 1986 mapping. It then goes to
cite a study map that did not study the South side of the river.
The East side of Morrisana Mesa is such an area with several slides on the CR
302/309 road and upper area. It is the area of the WPX pipeline failure. This
entire "Mesa" is an old mudslide terrace that continues right around to the Pad B
site. This is the importance of physically visiting and inspecting sites. See Figure 2
for mapping. Slumps/mudflows must be considered in this area.
3.5 Alluvial Fan Hazard Areas
The Report again references Garfield County Surfacia l Geology map -Figure 3.
This map did not study the South side of the river. It is not correct to say it is not
mapped as being a hazard area leading to an assumption there are "no hazards".
It wasn't studied; however, Figure 2 shows its' landslide and mudslide origins and
the actual Pad B is an alluvial fan extension from the erosion on the mudslide
terrace by Monument Creek and intermittent drainage.
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3.6 Unstable or Potentially Unstable Slopes
The Report invokes a map that did not include the areas of Pad B, Pad D, or the
Pipelines. However, the next paragraph cites recommendations for "specific
investigations" for slopes that would be identified as unstable or potentially
unstable . It is followed by a paragraph assuming all mitigations would be
performed. And, it concludes slopes " ... not as steep as surrounding areas." See
Figure 4
To clarify, Pad Bis on an alluvial fan and framed to the East by a steep slope as
shown in the profile of the pipel ines . This slope is a continuation of the mesa
mudslide features . The slope is Qgmf and Ola identification on the 1986 geologic
map, the same as the area of demonstrated unstable slope where WPX had
landslide/mudflow pipeline destruction . While the fan Pad 8 is on is relatively flat , it
is overhung by steep slope that will be disturbed by pipeline construction .
3. 7 Corrosive or Expansive Soils and Rock
The Report identifies the soil both corrosive and shrink-swell, but states they are
not expected to adversely impact the well construction.
Problems such as sink hole (collapsible soil), seismic liquefaction and severe
erosion can be part of this type of soil. The pipelines are exposed to this
corrosion in both the pipelines and their anchor systems. The geologists do not
seem to be aware of the USGS projected Precambrian basement faults and the
planned injection well use of this pad . The latter was withdrawn from this
particular application on a basis of premature or separate submiss ion .
3.8 Mudflow and Debris Fan Areas
The Report recognizes the mudflow of the area and talks of the Collbran mudslide.
The Report does not specifically note the mud and rock slides and the WPX
pipeline slide on the CR30/309 side of the whole Mesa structure . There have been
heavy rainfalls during the last two years that have hit several localized areas and
been above "normal". These have caused mudslides and severe erosion on the
South flank of Mt. Callahan and flow across 1-70. They preceded the failure of the
WPX pipeline to the Northeast. Th is may become part of continuing weather
pattern for years to come . It doesn't really take that much rain increase to cause
earth movement. There are housing developments NE, South and SW (to correct
the Report).
3.9 Development Over Faults and Risk of Seismic Activity
The Report reiterates the lack of mapped faults and then explains the Grand
Hogback and monoclines . The second paragraph explains earthquakes as a
generally minor occurrence.
However, since the Report was drafted, the USGS has rated the earthquake risk
higher than 2014 and 2008.
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Earthquakes 2008
htto://earthguake.usgs.aov/hazards/products/conterminous/2008/maps/graphic2pct50.jpg
Earthquakes 2014
http://earthguake.usqs.gov/hazards/products/conterminous/2014/HazardMap2014 lg.jpg
Earthquakes 2015
htto:/lgallery.usqs.govlimages/wordpress/20150810/PopulationGroundShaking.jpg
The other danger is the addition of more injection wells and the number of current
ones. Oklahoma has experienced the growth of earthquake numbers and intensity
and has admitted the relationship to hydraulic stimulation and injection of
wastewaters. Their regulatory control system is the much the same as Colorado's
Green-Yellow-Red system.
Revisiting the saying the 1973 and 1986 maps "do not map any faults". Not
mapping them does not mean they are not there. The maps cited are both
outdated and, one does not address structural, to determine the fault systems that
are very likely present. See Figure 1 & Figure 5. Figure 5 shows faulting found
upon additional field work on Divide Creek problems .
3.10 Ff ood Prone Areas
The geologist's used the 100 year flood plain standards.
The Eastern slope of Colorado, after a year with record flood levels, is now using
500 year considerations. But even the 100 year flood level, while falling short of
Pad flooding, may cause pipeline damages if pipes are not properly anchored
crossing the gully.
3.11 Collapsible Soils
The Report says "are not expected" as they haven't been mapped.
Most sink holes are not "mapped" before they happen. The soil conditions, nearby
river water table are all in place to react to increased burden of Pad and
equipment. Some ground testing by drilling could answer this question.
3.12 Mining Activity and 3.13 Radioactivity
The Report states no mapped mining nearby or Radon problems.
However, they should be aware there is a migrating Tritium source from the
Rulison test that was located several miles away, but at deeper depth . There has
also been a "crossing" of drill bores affecting two other operators in the area; and
this points out the need to review the nearby drill patterns. This is important
particularly on the Northern part of Battlement PUD where WPX has pooled
interests.
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4.0 Conclusions and Recommendations
From the Report:
• Geolog cal ~azards are not ex:iected to be a55o ciated with the •nsta at on of bur 1ed
ut UJ:es at the BMC B Pad. Corrosive soi l may tfi a ljn·itatio n to this construction . hut th .s
limitation sho uld be ab e to be 0•1ercome wth pro;:ie r eng neerng ; desig n and
eonstructon. Cathodi c protection for buried piping may red uce corrosio n result ing fro o1
salts in these sols.
• Avalanche cond1ions are not expecte<I to be a hazard in the area of the site .
• The s te is lo cated on al mium and terrace grave ls 0 1,·erly ng pre -h istoric mud flow and
fan grave depos1s . The site i5 within the lo'l.11 l~'l1lts fof 6attement Mesa and there are
existng wells and other structures in the area includ 11 g the Battement Mesa waste
•11o•ater treatne nt Jae lity and housing deve ~opments to the northeast and ~uth east oS f'l e
site The mud flow, terrace. and fan grave s are not e~ected to co r.stitute a geolog c
hazard forthe BMC B Pad de\•e opment
• Rocl<fa l areas are not present In the area of the site and are not expected to lie a
geo ogic hazard affecting the site
• The ste is not in an area ma?;ied as an al U'lia l fan hazard area. however. the site s
underla ·n by a luvium and fan grm1e1s, and the floors of creel!: on the r.orthwest si de of
Battlement Me!m are mantled with a luvial gr.we l A lu·.ral fa r.shave bee n deposited at
the mcuths of Monument Guith and other nearby st reams .
• S ope is a not ex:iected to be a geo 09 1c hazard affecting deve' op ment of the BMC B
Pad site .
• The Arvada cam so Is are corrosr1e to bo~h steel and concrete , and the subso r has a
h.;h shrink-swe ll pote ntial. Corros ive and exp:msive so Is are pote ntial 'I present in the
vie nity of the proposed BMC B Pads te which is o limitation fer son~e s1e de·1elopn ·enl
• Col aps"b!e soils are not present in the ~;cint>; or the :>reposed BMC 6 Pad site .
• ~.o significant faults have been mapped or are known in the BMC B Pa d site.
• The ste is not mapped as being with n lhe 100 year food plain Flash ftooding is a
hazard for lower ele..,·ations along Monument Gu .ch and oreas along !he Colorado River.
Areas immediately adjacent to these streams are located wthin the 11:: }'ear flood ;>"ain
and are prone lo flood risks.
• There are no mining activities shown n the vci11it1 of the ste. N3tura gas wel dri!ing
has been conducted in the area since the t960s.
• There a.re no sign.ficant rad oactive minera deposits kno\11n m the immed iate area of the
site . The presence of NORM n~ay be an issue with exploration and production and coul d
be an issue with us~ pipe scale or used e:iuipment. Rad ~oacb e materia.s are not
expected lo ;Jose as gnilicant hazard at the site.
REMARKS
Remarks
1
2
3
4
5&6
7
8
1. Since a bore is involved coming down an overhang steep terminus of a "mudslide" in
a soil reactive to concrete and steel anchor systems, and coupled with the failure of a like
WPX pipeline, engineering had better be designing for this. It turned out at the first
hearing, the operator or design team had not put automatic closure valves in the design.
They were not apparently aware of of this technology.
2. Not "town limit", the term is PUD boundary. Besides structures listed, there should
include the water treatment plant, aeration ponds, settling reservoir, water inlets and
pump house.
7
( Pipeline failure in the bore coming down to Pad B could have earth flow over the Pad
along w ith pipeline(s) destruction. This failure could put flowing wastewater (produced
water) into the gully, into the river, and the water inlets before any warnings could occur.
It is a "geologic hazard".
3. It is an alluvial fan or even later slump from the drainages above and should be treated
as such . See Figure 2.
4. The Pad is relative "flat" area and has drainage to the Northeast gully which drains to
the river upstream of the water inlets . This should be changed or a storm sewer to take
drainage to the Monument Creek side. There is "slope" hazard from theslope with the
pipeline bore. WPX has had a failure of such a line.
5. The composition of soils is comparable to that where sink holes that have occurred in
the Carbondale area. This should be tested accordingly considering the built-up pad
burden and equipment, including tanks.
6 . Seismic testing needs to be done. Reliance on an old map is insufficient and there
are future plans for an injection well -regardless of application protocol not including its
use. See Figure 1.
7. For a 100 year flood level, the pad would appear safe; but recent weather in Colorado
has shown a 500 year flood plan is more applicable and should be used .
( 8. Do not overlook the drill mapping of other operators . There was recent controversy of
"too close" drill bore crossing by different operators . The North side and end of the PUD
has had "pooling" by WPX.
5.0 References
The first reference involves a 1973 map of over 42 year old data and the second is a
1986 preliminary map without structural mapping, showing surfacial layering of recent
geologic deposits of Quaternary and Tertiary Periods. The Online references include
three Garfield County maps of particular zones studied. The study areas did NOT include
Pad Areas applied for by the operator. Statements concerning these maps were
constantly stating the maps did not show items of concern; but, of course, the area of
concerns was outside the study boundaries .
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Figures
Figure 1 U.S.G.S Fault Map .................................................................................. 10
Figure 2 ArcGIS Map Landslides ...................................................................... 11
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Figure 3 Garfield County Surficial Map ............................................................ 12
Figure 4 Garfield County Slope Hazard Map .................................................. 13
Figure 5 URS Fault Map Rifle -Silt .................................................................. 14
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Report 4-203.G.4
16 pages extracted
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Article 4-203.G.4
Geologic and Soils Hazard
Report
Ursa Operating Company
and Battlement Mesa Partners
Major Impact Review Application
Battlement Mesa PUO Phase I
BMCB
OAProject No. 014 -1829
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Natural and Geologic Hazard Report Preface
Garfield Count>,i. Colorado, final-zed the Land Use and Oeve opment Code (LUDC) .. ,~th an
effective date of Ju ly 15. 2013. last an·ended September~. 2:14. According to Section 7-106
Use of Ltmd Sub:ect to F\atural Hazards of the Garfield County LUDC ,...i..ar.d suoject to id:ntlfied
Na!umf ar.d Geo!ogic h'.'.lzards, such ~s f .Ji'ling rock, lar.dstldes, snow sbr!es, mud fiows,
rad.'ation, r.oodir.g,. or hrgh w.:Jter tcJb,'s-s, sh&ll! not re de~-ei"oped unless it h.:Js b-e-en designed to
et','m!nate or mlf1g£Jte the poterrtfoi' effects oi haza rdous aite condi!ions as designed by cl quD•'ifie<i
professlomJ! engmeer and \JS a/X)roved by the Counf:I. -
Tne LuDC requires a t-.atural and C-eo 'ogic Hazard Study be ;Jrepared by a qualified
profe~iona l geo og i st and sulxnltea \11ith a development plan or pat. The Ll.OC defines a
geologic h31'.ard as 'A g-=o.1o;fc p.~enomenon that 1s so ad~-erse to p<Jsf, current. or foresee.lb.'-:
ccnsfruct!on or lar.-d use as to const.'tute a sign.'fictJnt hazr:Jrd to pabiic hetJ!t.h or,d s;,fef'J or to
properft;. •·
Tic: L ... CC def nes a HJ=:ird .-i:ea as ·-:..n ~re .:; ma: c:.'i!a :r.-~ or !S d,·recr!y ~ffec:e.CJ' by Q ge c.·=~!c
hJ=~r:t .. •nc!~·11.~g bi..'t no! .•i.ry1,·~e':t r: t.•1e fc.•.to\',.'•~Q f:,:oes =f \J.re~-s ··
A.
6 .
C.
0 .
E .
A•1atanche Area. "A mass of snow or k:e and other material th;,t may become
1'nco.rparate...1 t.r.erern Da s£,1ch mDss moves rapld1'y down a siope. 1
Lar :! :31 :! e .t-.rea. ~An ars<J wir.r. demonafrably active mass mo·.:ement of rocA Drid
so.11 where there is a dfstinc! surfDce r:.1pture or zcne ofwea;.:ness that separ::ites
the landslide maten·a.i from more stab1'e 1.mderiJ1i ng m:i!erlaJ. y
r-!u~z ow Debris .~rea '"An are<J sc1b}ect to rapid mcid onrl debris nrotlement or
depos!t o~currlr.g after mobilization by heavy rainfall or sr.owme,'t runoff. Such
Dreas :lre formed b;· successive episor.'es of deposjtlor. oi mud ;;md debris."
Racf oactive Area. "An orea subject to vrirlous f';pes cf rac!i:Jtior. emfsslon from
ro~.1oacfi1/e minem.'s th:Jt occur tr. r.::Jtl.irol or mar.made deposits of rxk, sofi, or
1t\·ater_"
Poter.tiat 'I .... r5:able .S ~il~. "An area of land ident.1fled as h;ning soi.'s that m~y
cDuse damage to structures, s~·ch as bui!dmgs ::ind r.:x1d,\'CJYs .. as a resuit of over
saturoh'on or some oft.er outs.'de influence ."
According to the Garfie d County LUDC Section 4-203 Oescrlpti.on of Submittal Requ rements,
the prore$sional qua ifications for preparation and certiicaton of certfn documents requ red by
this Code are as follows:
~Geotcgist. Geology reports shat'! be prepared by either a member of rne American
lnst!tu!e of Profes~ionat Geo.rogists, a member of the Associotion of Er.gln..,--erir.g
Geo.'~ists_. or o c;uaiifi.ed geotechnic:;jJ engjneer licenser} jn the SttJte of Co.'orDdo "
Ge-olQ.dic r azar ::I Repor.
U •sa Cpe r atng Company SMC B Paa
G.a•feld Courty, CO
Of=n Associate~
Golaen . Cclo~ado
Octobe• ~o ~..!
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Current ly. the State of Coorado does not require icensure or reg straton cf geo'ogists .
ho·\\lever. Colorado Revised Statutes do require that geo ogic repomi be ;:repared or
authori::ed by a professtona1 geo~ogist, and L1e tern· 'Profess ona r Geo og s( is def ne:l in
Co orado Sta1'Jtes .
The references for these Statutss ::ire sho\•,n here:
~-1.:~o I. Def nitions. As used i n th s part:. un ess ttle context otherwise requires .
(1) "Geolcg st" n-eam; a per.:cn engaged 1n the practice of geo ogy.
(2i "Geology' means the science \•,hi ch treats of the earth in genera l the earth's
;irocesses and its history: investigator of ttle earth's crust and the rocks an::! other
materials ·M1 ch ccn1;iose rt o:md the ap;> ied science cf utiliz:ng knowled9e of the
earth's history. processes, constluent rocks , milerals, iqu:ds, gases, and other
materials for the u~.e of mank nd.
(3) "PrcfsssiCfla ~~l ogist' is ai person who is 3 graduate of an inst1ution of hi9"'1er
education v.ti ch is accredited by a regional cc national accrediting agency, \•,ith a
m nimum of thirty semester houro tfof'1';.fi••e quarter> hour..; of undergradui'.rte or
gn~du3te work in a f e 'd of geolog~· and whose post baccalaureate train ng has been in
ttle f~td of geo rogy with a specific record of an additional fr•e years of geo~ogica1
eX?erience to inc ude no more than t\•,o years of graduate work .
(4) 34-1-202 . Reports containing geo ogle .nfoonation . Any report required by law or by
rule and regu ation . and pre;>ared as a result of or based on a geclcg c si'Jdy or on
geo cg c data. or which contains infom1at on relatng to geo ogy, as defined in Seeton
34-1-201 (2). and which .s to be presented for ani' state agency, politcal sulxfr1 sion
of the state, or reccgnized state or loca board or commission, sha I be pre;>ared or
a;proved by a profess cna geologist 35 defined in Section 34-1-201(3).
G...olcdic r az.1rd Repor:
L.<sa C:>erat ng Co'TIJ:.lni' SMC 8 Pac
G.a"f eld Courty CO
ii OJ~c:ln ..O.ssoc•3te:
Golco:n . Cclo•ado
Octot:~r ~o·.:.
(
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Professional Geologist Certification
By moa ·1:. cf th s CCJ "ti fi cation. I a1tesl thaT:
I a 11 qJa!ified ro pre;iare 2 Nati..ral and Gee l ogic hazard S1udy in acc:m:ance with
the proiJisio n s of Section 7·207 cf the Garueld CoJ'l~Y LUDC. and that I am a
m e 'Tibcr cf the A'l'lc'ican Institute of ?rofcsslonal Geologists per LUDC 4-203.
, -A itho ugt-I t-..ave not visited ~he propcse-d sit.a. I em ram ii ar witt· tf"e g-eo ogy an<l have
pe-formed f eld work io the area of the prc~osed Ursa Ope-.:ting Col'T'pany LLC BMC
B Pad Well Jv:;ated in the S'A' ~ ~/ti}~ Section 18, Tmwishi::> 7 South , Range 95
Wesl, 6 t-Prhcipel \1eridia11 in Garfield Count}'. Cclorado.
Althc·cgh Colorado does no~ currently have a :1ccns i rg board c· regis!ration r:mgra'Tl
for pro'csslonal gco!cglsts practic r.9 In tho s!ato of Colorado , the•e are requiremen ts
within local and State statutes tha' rcqu re ti<lt geologic reports be prepared by a
professi onal geologist. I attest that I meet the rocu1rcmcnts of the Cclorado
Georoglcal Survey's definit:on of a professional geologist hav rg complo~oc anc met
the educa"J~ial requ reMen-.s of the Colo raco Geological Su~cy dofid:Jon.
I ar; a li~ensed Professional Geolo5ist amf Professinr;~I Geoscientis~ in other Stales,
i1dudi1g i exas, Ula1, and Wyomir9 wn r.h do ha ... e hcensing i;rograms fer
professional 1;eologists
I ha•Jf:! re· .. i~wec pubhsh0d gaulcg c rlap:; e:nd r~i:.:o·!s appl.ceble to thfs area and
ha·.·c con sidarc:.! the lrl'phca,ions or ll"cs~ COrldiltons In th e c:o:i~exl or the proposed
develcp··ncnt
Tl" is report hm: been prepared in accordance wi:h good sc or title pr nclples and
engineering practices including cor.side..:.tion of applicable Industry stardarcs. and
wi~ C0'1Sideration of tf".e reqJ ·rements of the "ation31 Assoetc:iUon of Slalo Beards of
Geology The cor.clJsions and recom-nendations cootaired In this report are basad
on infonration available and knoW'l to me at the time of this report. Good scicntir c
prinr.iples a'1d standa ~c engineeriig prac:tioes WP.re tF.ken into consideration to in
erriving a~ the oonclus ~on!'i and rr.comrrenr!ations made in this report.
Prepared bt
-? .. W ,,n.,~ 1 /!.I ?;;;. v / «;,.. .......
James W Hix, PG
Somor Geologist
Dato ~ 10·'03''2014
,•.::.ff! n:c PG:: i:c:mrc:io:r. :;cc:i nt\' ."t''.-e.'f:' r.':r: cwr-:1 t~ . ..:i•;r ~( :l11t !~clt1 or t~ ~..i!y ID ~~':'Q,.. !'Ill; mpcrr or fa\"./ 1fl"t:~'lllJ "'\'J!i
r.'1:1 nico.'llr.er.o:iri::r~ ,,, ~.:incit ·.-i!t: lll' 1JP,t.'1::~ rr:oer.JJ St.7!.;i • .1'1C .\:1.:.:11 ~1.,·r:i1T'C11l:::n r~ tn ;.ch..,.,,,,, Ir.~ ~l~d 90 :;\~
o: o!:,t!l~·w~
Georo~ ,c Hai.3rd Report
Ursa Oporat n{; Company BMC 8 ?ad
Garfield Coun1y. CO
ill O!SSon Associa!cs
Gciden. Cclorado
October ?C1G
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TABLE OF CONTENTS
Marural and Geo ogic Hazard Report Preface ............................................................................ .i
Professiona Geolog .st Certifc<ltion ............. .... . ...................................................................... ii
TABLE OF CCNTEt·ITS ........................ ....... ... . ........................................................................ iv
FIGURES ................................................................................................................................... i·.,.·
1.C EXECl.iTl"/E SUfv1MARY ................................................................................................... 1
::?.C GENERAL SITE LOCATION .A.MD BACKGROUND .......................................................... 2
2.1 Project and Site Cescription .......................................................................................... 2
2 .2 Structural Geo ~Y ....................................................................................................... 2
2.3 Ste Geology.................................. . ............................................................................ 3
2 .4 So 1 .......................................................................................................................................... 3
2 .5 t-;;,drologic Setting ......................................................................................................... 4
2.6 Aqu1ero ..................................................................................................................... 4
3.C· t\.A.TURAL Af'~D GEOLOGIC HAZARD ASSESSMENT .................................................... 5
3 .1 1J'ti ities ...................................................................................................................... 5
3 .2 Avalanche razard .A.rea ............................................................................................... 5
3 .3 Lande,ide Areas or Potent al Landslide Hazard A.reas .................................................. 5
3 .4 Rockfall Areas ............................................................................................................... 6
3 .5 A luv1al Fan Hazard Areas ............................................................................................ 6
3 .6 Unstable or Potentia I;' Uns1ab e Slopes ........................................................................ 6
3.7 Corros :ve or Expansive Soils and Rock ......................................................................... 7
3 .8 ~.1udflo•,\• and Del:fis Fan Areas ..................................................................................... 7
3.9 Develo;:>ment Over Faults and R sk of Sesmic .A.ct ivity ................................................. 7
3 1 o Flood Prone .A.reas .. . . . . .. . . . . . . . . . . . . . . . .. . . .. .. . . . . . . . . . . . . . . .. . . . . . . .. . . . . . . . . . . . . . .. .. . . . . . . . . . . . ................... 6
3 .11 Collapsible Soils .......................................................................................................... 8
3 12 ~.~in . ng Actvity...... . . . .. . . . . .. .. .. . . . . . .. . . . . ... . . . . . . . .. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . ................. 6
3 .13Radioact '.1ity ................................................................................................................ 9
4 .C-CONCLUSIONS .A.ND RECOMMENDATIONS .............................................................. 10 : .. c REFERE~JCES ................................................................................................................ 11
FIGURES
List of Figures
Adjacent Land Use Map
Geology Ma?
NRCS Soi s Map
Topographic Map Sho•Ning Surface 1..Vater Map
Food p. ain Map
Geologic 1-a::?.lrd Report
U •sa C perat ng Comi:~n;· SMC 8 Pac
G~'f eld Courty. CO
iv Of:::zon ,4,ssoci:it.:.;;
Golden. Cclor ado
Octobe-r ~O i ..!
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1 .0 EXECUTIVE SUMMARY
Ol~son A~ociates (0is5en) W3S contracted by Ursa Oparating Company to assess natural and
geologic hazards potenta11y prer.ent in the area of the pro;:ios~ BMC B production we l pad
located n the S'iN !>~ N'l,' /.Section 18, Tm'msh p 7 South, Range 95 'Nest, of 1he 61h Princ i pa
Me rid 1an, Garfield County. Colorado. The s te is at an eJevation of about :.,cg~ feet above mea n
sea leve l (amsl). The site setting rs shown on the att:Jched 6MC B Pad Adjacent Land Use
Map.
The pur pose of this report ·s to identfy geologi c condit ons that may pose hazards 1o a and
development prefect in CY.der mat a::ipropriate m'tigation or avoidance techniques may be
imp lemented as described in the Garfield Count'/ LliC::C . According to the Garfield County
LUOC , Secfon 7-207, the types of natural and geologic hazards identife-d pertain to the
fo llow i:'lg :
A. Uti i:ie5;
8 . Develo?ment n Avalanche Hazard Areas :
C. De· .. e!c:m1ent r. La n:i:.li:le Haza·d Are:ts :
D. Development -n Rock.fail Hazard Areas;
E. De· .. elo:mie m n .~.l l Jvia l Fan H:i=ard Areas;
F. S ·::.i:e-Deve ·op mer:t;
G. De·•elc::·mmt C'l Co rros,;e or E:i:pt:r.:.rv·e Soi l:. ar.d R:>ck ;
H. De· .. e1o::ment n MJd f :ow Areas; a'ld
I. De· .. e!c::ment O· .. er Fau lis.
Th s rei:ort presents O sson find ngs fo l m•,in g an evaluation of these and other geo ogic
hazards potentially affecting the site and pro;lose-d development. The Ursa Operating Com ;i any
site was found to be su'table for 1he proposed development with consideration of the foJI O',\~ng
identif ed geo ogic hazards.
• Tne s::.ils in the 'o'i cinity of tre site .re corros i· .. e to both steel ar d cor crete d•Je to h ;h
saii cor.te r t ar.d t'le sul::.oil 1.1yers ~.a·.:e a high slirinlH•we:I ,?c:emi a .
• According to the Prel n~inary Geolog ic Map of the Grand Va.ley Quadrangle. Gartie d
Count1, the proposed site is located on Quaternary age {Ho locene } all uvium, terrace
deposits, and underla in by ";:>re-h .storic:t mudflow and fan gra .. 4el de;losits.
• Tne site is not ma::::ed as be n; in an All uvial Fan Ha:ard area. but is o ca:e d on all Jvial
far, de~·:::·siw a~soc i ate d ·,•,t i' r._•o n'J mem Gu!ch and unnaM ed in:ern· tte nt dra i nages.
• The site is not map;ied within the FEMA 1 OD-year food ? ain, but is located with in 400
feet of the Col or ado River. It is about 1.000 feet northeast of Monument Gu ch and 300
feet southwest of an unnamed ntermittent dra inage. These drainages are prone to f ash
floods.
Tne B\·1C 5 °ad ca n ::e c:r:.tructe d t :) co m ~n s::lte for t.l'l~se imiiat :on:. ~r d p~te n ttal ha:a·os.
Th:. re~c rt shcu!d ~e rea::i in ii$ ent irery·, inc L:::ing but rot lim te:: t:) tne c ~rclus ion; and
rec:-n·n·e,,da:i:>n s in sect ion 4.0.
G>!<llogic ~az.lrd Repon
L rsa Ccer:at:ng Comp.:;n;• BMC 8 Pac
G.:.~eld Courty, CO
OJ~~n .A.s.sociate.o
Golden . Colorado
Octobe~ 20 14
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2.0 GENERAL SITE LOCATION AND BACKGROUND
Ursa Operating Compan~· LLC (Ursa } co ntracted Olsson Associates (Clsoo n) to conduct a
natural and geolag :c hazards a~sessment as part of the pro;iosed development of the BMC 8
we I pad . The ;imposed fac fity w:n be used to driU for and produce natural gas . The follo•Ning
sectons pr01.ide information 3bout the proposed deve oprnent and the site geologic setting .
The site surface and bedrock geo tog:,' is sho •,M1 on the Geology Map.
2.1 Project and Site Description
The proposed BMC B we l pad is tocated to the south of the to,,;n of Parachute . Colorado off of
Co •Jnty Road 300 . The site is located :n the s~v Yc N\i'.1 Y.Section 18, TIS, R951N , 6111 P .M. ~nd
is ocated in parcel# 240913406004 . The surface land :s owned b~· Battlement Mesa Partners .
The site is rocated •,vest of the intersection of Stooe Oual'T'J' Road (County Road 3: uj and River
Bluff Road (County RoLld 3:7). n the con·n ·un ·t'l of Battlement Mesa .
2.2 Structural Geology
The BMC B '11.'ell ;:>ad site is located in the southeastern ;iart of the Piceance Basin. The
Piceance 6as n is an i:reguk:ir y-shaped elongated basin formed b;• tectonic forces associated
\•/th the Laramide oro;;eny. These faces d-:1~'.ln war;>ed the earth's crJst and formed the
Piceance Bas n as a re~rn t of the up!ift of the s·Jrrouncilng Co'orado Rocky fl,1o{Jnta ·ns and the
Co orado P ateau.
The P:ceance Basin is the n-.a. or strucftJral geolag .c feature :n the region. Ii is bound to the east
by the Grand Hogback monocl ·ne, the '~·Vhite Ri•.rer U;:> ift to the northeast, me G unn son l.plift to
the south, the Uncon·pahgre Up tif\ to the ~-0uth and so •Jmwest, the Do~fas Creek Arch to the
west-north•uest, and t he axial basin uplift to the north (Grout and Verbeek, 199~ j .
Sedimental"'; rocks n the southwestern P'.ceance Basin gently d :p to the north -northeast
exce;:it '.\lhere th s reg fonal d i ::>~ interrupted by lol/.'-3mpt1 lr.le fo rds. Numerm.1s small sub-
paraUel northwesttrending fo ds ha'i.•e been identifed In the Green Rver Forn·ation v.1hin the
basin.
T~re are no mtlpped fa ults &t-:>·,•1., n th e area of tre site c 1 the Gee ~;ic and Structure rv~J:J c"'
the Grand Junction Quad rangle . Garfie d County, Colo rado (Cash:on, 1973) or on the
Pre·iminary Geotogic Map of the Grand Va l ey Q•Jadnmg le, Garfield Count','. Colorado (Donne ll ,
Yeerid, Smith . 1966i . A fau ·t is a fracture in rock along which n•oven·ent has occ~rred.
Mount.ans are bound by fa ults and are a vis .ble ind~cation of a structural weakness in the eartt,-s
crust The Colorado Rocky Mountains are bound by fau ·ts ; however, these fau 'ts are not a ·ways
visible at the ground surface either because ti-.e fa ult tra ce is ·b :ind n·eanirg that the fa'.! t d:·es
r:.t h ~l'.·e surface e•:pre:.s :.n si n ce i: does no: <:J i across O'.'er l ~~r;;; sedimemmy bedrcck unit5, C""
t t:it it has been bured ar=i corceo led r.:y ur cor.sol :jated :.e di men:s de::csited o·~ert t-e a ~ea
wri ere tt.e fa ults are prer.e'lt There .re no know n n·a.or fa.1t:. t1·.at hJ•/e been r1a~i:;ed n t r e
3reJ o;the ste.
G~logic t-= a:zatd Repor.
Lrsa Coerat ng Comi:-;.n-,-BMC 8 Paa
Garfeld Courty. CO
2 Of~on .4.ssooi:ite.>
Golden , CcltYado
Octobe• 20 1 ~
( 2.3 Site Geology
(
According me Prel n·inary Geolog c Map of t he Grand ··/a ley Quadrangle {Donnell. Yeend.
Smith . 1986}, bedrock n·ap::>ed to the east of the pro,ect area cons ists of the Eocsne and
Paleocene-age Shire Men·b& of the Wasatch Fom1aton \11h.ch con sists of pu rple . avender,
gray, and brown claystone, vith n·inor beds of f ine-to medi~m-graned sandstone . The
n·aximum exposed thickness of the W asat ch is approximately 1,2:::: feet
The bedrock ·n t he area of t he site ·s covered with unconsolidated sed ;n·ents of Quaternary age
cons sting of mud now and fan gravel depos its . •/v'e~k c ~ystc ne n tre J::::er 'vV::isa:ch
Fcrr-iat iori are respons ble for tre slope foi ure wr.i :1 res J te:! ir1 slides and debr s flews d u"ing a
time when t he cl ii1a1e was mu-:n we::er. These mudfiow and fan gravel deposits consist of
pebble, cobbl e, and boulder gravel in a grai' matrix of coarse sand . The unit is poorly sorted and
conta ins ang ular to subar1g u ar clasts of :>rimarily unweathere=I basalt, but conta ns some
sands to ne , mar lsto ne. s]tstone. and c laystone . The un it 1/1.'as large~.>' deriv=d from solifluction
depos its located to the east of the qu~drangle .
Mode m al uvium. allu•.•ia , and floodpla n d~;:iosits consisting of mud, sit, sand, and grave are
also present along the Colorado R ver drainage covering the far1 gravel de:>osits .n the vie nity of
the site . The all'J vfal and f ood;i ain sed n ~e n1s are locally derved from coa lescing fan deposits
and sheet.wash deposits form teraces along the active Colorado R·'.'er drainage, and also
conta in well-rounded, wel .sorted, non-loca ly derived cr1sta l ine rocks trnns;iorted from areas to
t he ea st. The gn.wel con~n·on 'l ranges in th i ckne ss from 10 feet to 60 feet th ck; however , it ;s
loca ly u;:> to 100 feet thick, es;:iecially near the Colorado Rver (Yeend . 1969~.
Alluvial terrace and fan grave deposits are present to the sout hwest of me site and in the
northea Gt comer of Sectio n 18. These deposlts cons 'st of grayish bro'lm sand;•..gra vel cons ist11 g
pr n·aril;• of ba~.a t and oca l y derived s1abby s ltstone, marlstone, and sa ndstone elasts that are
n·oderate ly to poorly sorted, poorly stratfied. The maximum thickness ofthi$ unit reaches 200
feet.
2.4 Soil
The fl\atura Resou rces Conservation Service {NRCS) Soils Map shows the area soi types .
Soils, cons ist ng of the fo l ol/ing units, are with in the study area around BMC 8 wel pad :
• Arvatla Loan ~. 6% to 20% slopes. Map Symbo l ~: The Arvada loam is a dee;>, wel
dra ned 1 slo;:>ing soil formed on fans and high terraces ate evatio ns bet,•;een 5, 100 feet
and e,2 r:m feet abo·1e mean sea 'evel. T~rp i ca ll y the surface layer is a n·ooe rately
alka line. pale bro.,.ri .oan' about three inches thick and the substra rJm is light lx'olf1n to
brown silt'/ c lay oan to a de::ith of 60 inches. Pem1eabi li ty :s very slow, and availa ll e
water ca;:iaciti; i s high . Surface runoff .s moderately ra:i .d, and the er osi·::>n hazard is
seve r e.
T ne A~ .. ·ada !c.Jm ~-:i i s cc'Tcsi · .. e i•'.: stee a.r d corcrete due to t he c:.rge amourits of ca·:' and
:.alt:. CcmmJn:t~· de·,·elc:me n~ is lln·ited b~· 1"1ig'l s-i rinr.-s·1,·e I po:ent ia, :.a l r.it'/ and s1ee:
:.~c ::es. Bur ed ~ iping and srruct.ire-s ors te ;.•,i I need to ha ·~e adequate ca:hodic i: ro:ec1 or t~
i:rev:nt co 11os :n cue to \he h:g'l s.a int:,· of trese so s.
Ge-ale.die t-a:za rd Report
l. rsa C perat ng Co'llp.:iny BMC 8 Pac
Garf eld Courity CO
OJ~on Associate.'.:
Go!cen , Colorado
Octo b~r :o "l ~
{
2.5 Hydrologi c Setting
The site is located on a terrace above me Colorado Rver f lood pfain. The Co orado River i s
!oca1ed a?pro:1jmate y 40::: feet to me north. The Monun•e nt Gulch creek drai nage s located
appro KmGte l;1 1,000 feet to the southwest. There is an unnamed intermittent drainage 3:::~ feet
to the east northeast of the site . These surface ·,•later feat ures. are shown on the Surface Water
Map.
2.6 Aquifers
The Wasatch Fonnation locally yie ds water to weTi s in some areas , but is genell'ally cons dered
a confin ng unit. The Tertiarf sedimentary-rocks i n t he Piceance Basin are general y fine-
gra ned and wel cemented resul ti ng i n \'er}I smal hydra •J ic conductivit:f 'n the rock n·atrix.
Sandstone and siltstone genera ly occur in lenticular bod ies and loca!ly have moderate hydraul·c
conduct1-ites 1Nhich range from 0.001to0.01 foot ?e r da;•. These lenses of sandstone and
si tstone are often 'l.\~dely soaced and not interconnected which further linrts the vo lumes of
groundwater 1he forn·ation can yeld to wells . In some areas, fractJring during the structura
deformation that occurred w~en the P:ceance Basin was uplifted and through dissolution of
cementing minerals has enhanced the perrneabi it)' and hydraul c cood ucti'e.'ity in !J~.Uts of the
Piceance Bas n a.qu fer system (Topper et al, 2003;
't/v'ater well depths in the area typica ly range from 50 feet to 1 s: feet be o·w ground surface
along the Colorado River and 151 feet to 3LC feet be low ground surface (bg~-) in are.as further
south of the Co orado River . Static water leve ls reported y range between 4!: feet and 60 feet
bgs based on a review of pem1itted water ·,•,-el s in the vie nity of the site .
Surfcia a:iuifers are present in the al U\1ium a ong the Co orado River and its ma, or tributaries .
The depth to groundwater s ex::iected 1o be ess t.'lan 20 feet in c lose proximifl; to the Co orado
R •.•er . Th s a l uvium i s t'Jpica~ly too thin, narrow , and d scont nuous to be considered a major
a:iuifer, a.though ,n some areas the a lu'" un · is ocal y im::iortant as surficial aquifers (Banta and
Robs.on , 1995). Ground,•iater v/thin the uncons::> idated sed n·e nts in the area of the ;:iroposed
site ;s control ed by the tn :ckness or the sed n-.ents and the de;>th to the top of the 'yVasatch
bedrock. The estimated ~roondwate r flow directon in the vicinity' of the site ..s I kely to l>e sub-
para llel with' the Colorado River, f ow ng north -northwest to•Nard 1he Colorado R"'·er through the
center and northern ;>art of the ;>reposed s1e . These de;>osits are shown on the Geology Map.
Geologic ~ azard Rep:>n
L•sa Cperat ng Co ~p.any BMC 8 Paa
G~1 eld Courty. CO
4 OJ~:>n .l'..ssoc•::i t e.>
Golcen . Colorado
Octobe ~ 20 1..!.
( 3.0 NATURAL AND GEOLOGIC HAZARD ASSESSMENT
(
The fo l lo\I,' ng sections present the assessment of geo ogic hazards in the 1-ic init;r of the
pro;:iosed V.'ater lmpoundment. The Adjacent Land Use Map shows the locaton of the BMC B
'Nel Pad site i n relaton to the affected ::iarce and ocal roads .
3.1 Utilities
Abo'o'e-ground uti ity f acil:ties ocated in razard Areas are to be protected by barriers or
dive rsio n techniques a;i;:iroved by a qual fied profess ional engineer. The detenninati on to locate
util1y facilities above ground \I,' I ~e base~ up.:n tie reccmmer.cation and req J rernents o" the
i.til t 1• ~c ··.-i ce-pr:Yv·ider ar: a~:l'o· .. ed b;.-t"le 2.ourt-,. Except for potenti al flood ing, above.ground
util:ties, such as transformers, are not expected to be affected b]' geolog c or other natural
hazards .
Trenches fo r •Nater pi:le ines, natural gas;:> pelines, and e ectr'cal ines are e:(pected to be
associated with the pro=iosed development The s opes and corrosive s:>il may pose techn ical
cha l enges to the insta lation of these utilit'es: however. tis expected tl"{:t tl"ese Un·i:3~iC "l$ c;:m
l: e :)Ver come \•,ith i: ro per : e5ign and hs.ta la:i :.ri .
There are ex_ sting natural gas wells in 1he area, the Battlement Mesa waste water treatme nt
fac i ity to the west of the s1e and Rver Bluff R:oad {Counr/ Road 307) to the south . A boat
storage facil ity is located to me SO'Jt'l and houses are located to the east and southeast of the
site .
3.2 Avalanche Hazard Area
l/v'L"lters are cold i n the mountainous arel:ls of Gamed County, and valleys are colder th~m the
lower parts of adjacent mounta in s due to cold air drainage. A•.•erage seasonal snm•1fa I in
Garfield Count'/ is 50 inches. The greatest snow dep1h at any one tn·e during the period of
record fron' 1951 to 1974 was 29 inches recorded at Rifle, Colorado approx.n•ately 25 m !es to
the east-ncrtheast of the pro?osed site .
Avalanches are not expected to affect the pro?osed nat'Jral well site since it is ocated at an
ele\•ation of ap::i ro:o:in·atey 5.160 feet an·sr. Areas in eastern Gamed County are at higher
elevati on$, receive mo re sno 1A1 pack, and are, therefore, more prone to ava anches in certa n
years.
Avalanches are t he mast dangerous geolog -c hazard In Co lorado resu.ting in in.uresT loss of
life, and about $ t 00, ODO in direct property damage, and indirect econom .c lo55es in the n~i l ions
of dollars annual y. t-:owever. the ava anche prone areas include the Park Range and Flat TO?S
in northeastern Garfie <I County, Colorado , to the north of G enwood Springs . Glenv.xxxi
Spr~ngs . near the east edge of the area, averages about one degree cooler than Rifl e and
receh.'e$ aoout f..,e inches more ;>reci?'tation per year (Harman and Murray, 1985}.
3.3 Landslide Areas or Potential Landslide Hazard Areas
The site is located on mudflow and fan gra ... et de~osits overta in by younger terrace depos·ts,
alltivial, and f oodp ain depos1s . There are earthflow and soi creep de;losits mapped to the
Geologic I-azar-d Repor: 5 OJ.::s:Jn .4..ssoi:-i:ite:o
l..!!>a Cperat.ng Co'Tl~ny BMC 8 Paa Golden . Colorado
G~rf eld Courty. CO October .20 i~
( south of the site n southern ha f of Section 19 . but these deposits a.re not mapped in Se ctlon
·1 s, Townshi p 7 So-Jt.'1, Range 95 West Movement of the e xtemi"ve e:srthf ow and so'.I creep
sloj)es has ceased, except for ocal occurrences of veroJ rece nt slumps and mudflows.
Soliflucton deposits. are e:dens 've in the Rul ison 7.5-m nute Qu adr angle located to the east , but
are on ly found in a sma l arer1 on the east side of the Parachute (Grand V alley) 7 .5-minute
quoorangle {Yeend, Conne ~ Smi1h , 19·96) .
. ~.c..:ord i ~g iC Milp 24 -Stri:ic~ Geo!cgy n·ap, 2-e:.'ogic Ha=ards lde:itflca:ion St ucy ,L nco ln
Devore i 975-1 :-7€.i there a·e r.o !ards ides 5 1'~,wn to i he scu:h of lnter5totc-7: n t~.e
P::.rach1te -EJtt;er-1ert r~4 e5a area Lands ide areJ5 ~re 5t-:J·,•,n to the nor1..'1west c f :ne town of
P~rac~ute (Ga 11e d CcJn:y , St.ra ~e 3eo'og: 2007:.
3.4 Rockfall Areas
The site is not ocated withi n an area that has been mapped as htw·ng rockf al or potentia for
rockfa l . Pote ntial rockfa!l areas are present afong the stee:> dr ainages n cise<l by Monun ~en t
Creek to the south and so•Jtneast or at higher ele-.•ations to the south on Battlement Mesa
3.5 Alluvia l Fan Hazard Areas
The site is located in an area t hat is '1C: mapped ::.s being n an a luv al fan h•m1rd ::area
according to the Garfield County Surficial Geology. 2007. The site is located on a lwium,
floodpla ·n, a llu v~al terrace , and fa n gravel depo~rts and is underla in b;• olde r mudflow and fa n
graves accord r,g to the Pre l n•inary Geologic Map of the Gram! Va lley Quad rangle (Donnell,
'r'eend, Smith . 1 966 ~. The site is on the nortnea~tem part of an a ruvia fa n created by
Monument G ulch and other unn amed intermittent dra ·nages . These deposits fi e abo'Jt 100 feet
above the Colorado River f o:xi ;:> ain.
3.6 Unstable or Potentially Unstable Slopes
.According to the Garfie d County Slope Hazard SrJdy Areas 1, 2, & 3 n·a ;:>, ;>arts or the area
nor'1n o.: the Co !orado River and the to'l:n of Pa rachJte. Co1c~ado ha·.·e bee r n·ai:p~ a 5 t-e ir.g In
an area of major slc:::e hazard . The mao does net sho·,•1 trie area sout h of t,t1e Col:)tado Ri·.·er
an:l in t he ·.·icinir1• cf t~.e site as l:e ir.g idem ifed in as oi:e hazard area .
The $lope hazard ma;> recommends that s'te specific nvestgations shou d be cond ucted to
asress acti.·e landslide areas . Geolog c srJd.es ma1· include intensive drilling and ~.O?h sticate d
strength testing, stability ana yses, and n·onitor:ng of soil, rock, and grounct,•1ater condit ions .
Mitigaton n~y be poss .b!e, but likely \•,ill be e:Qensive, may requ tre specia l s'ting . and vll
invo ve some risk. Avoidance n·ay be recom'11ended for projects of lower economi c value
(Garfie td County, Slope Hazard Study 2c:-1).
The Ar .. •ada Loam so ·1s are found on 6% to 2G% s. opes . Engineering . des gn, and constructio n
practices of the ;>reposed de't•elo;:iment are expected to mitgate the imitaton of slo;ies at th e
site since 1he site i$ located within an area dei.·eloped for other land uses, including
development of natura gas well pads. The s te n·.:sy reqJ :re mit ;;pt ior. for s ope , ar.d .,,· 11 c.e
graded and cc '1etruct.::d for t tiis ~Jrpose The site is in an area near the Co orado River v.~th
slo;:ies that are not as steep as surr ourding are:J5
Ge:>logic I-a:?.Jrd Repor.
Losa Cperat:ng Co'lli:~n;• SMC 8 Paa
G.arf eld County. CO
Ofa .. ~n ,.:'lssoc.1a~~
Golde n . Colorado
October :o·~
( 3.7 Corrosive or Expansive Soils and Rock
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According 10 me So I Surve;' of the Rffle Area . the Arvada loam $C ~ .re corr cs i·•e !O both $1.ae l
rt r:: corc·ete. Se::iMe-rt~ry· r·:::ct. ccnia r 1r; l·igh sat co1-,tert , suc'l a5 ctloride c•r 5ul:ate. •md
soi $ deri·•ed ton· trese r•:::t~ ty~es, n-:ly ::.I~~ te c::irros ive to cor.crete er metal, cau~ing
::an· age 1°;, $trJ-:ti.·es bJ t upcir, tr en·. The Arvada loam is atka ine with pH greater than 7 .. 9 to
n•ore than 6.4 standard un'ts . T he $Gli n t;• in tfie Arvada loam ·s typi cally less than 4 mil imhos
per cent meter. ho 1A'ever sal in tyma;< ncrease vith depth. These conditions are a potentia
hazard :Jresent i n 1he vi<: ni ty of 1he t:.ite .
Some Tertiary an d Creta ceous age se<fimentary' rocks •,\1th h.gh clay content are ca;>ab e of
acce:>tn ·iJ water into their chemica l structure and expand ng many ti mes the r volume when d r','.
These sedimentari; rocks , and soils formed from the!!e rock ~;pes . may expand or contract i3s
they become 'A'et and then dr;r out resul ti ng n dan·age to str Jctu:-es bu ilt upon thern .
The nubstrate of A:• .. ada loam soils have a high shrink-swel potential which i:;-ose a lim1ation for
some community' and recreational development, but are not e:•:pected to adversely impact fae
pro;iosed wel construct Cfl .
3 .8 Mudflow and Debris Fan Areas
The site is located rn an area of n·ud flow and fan gravel deposits overla _n by all uvium and flood
plain deposits . and al uvia terrace deposits . The site is located on a terrace near the Co orado
R \•er drainage. These deposits are Holocene in age and fut ure mud slides are a pote~t c:I
ta::t:rd f t~.e area 1A'ere to receive he::ivy ra ins . These f ows are exi)ectsd to originate fro m
higher ete•.•atio ns to the s.outh and would fo low the dra inages to ewer elevations closer to the
Co orado River flood? ain _
·wetter conditions at the end of the last ce age were most ike 'I responsro e for the deve opn ·ent
of the extensive n ~udflo•/.'s and fan deposits peri;ihera l to Battlement Mesa . G acia condi t ons
that eldsted on the Grand Mesa during the Pleistocene did not eX:st on Batdement Mesa at th.s
time _ Abundant annual mnoff is s•Jspected in cr eating hig h ?Ore -water Pfessures with n the
·wasatch Forma t:on shale and c aystone to cause slope fai ure, especial!;• on north -fac ing
slo;Jes \•,tiere evaporation was at a n~lnimum (Yeend, 196-9 1. M::.re recent s i.n·i;s ar.d n·Ld f ows
that ~ave occ J rre~ south oz P ateau Creek near Cc .bra'l deve oped in grac ial t II.
The proposed BMC B Pad is ocated on a parcei develo;:>ed (o r outdoor storage, and there is
other deve opn·ent in the area including a ;>ubl c works yard to the west and River Bl uff Road
(County Road 307) to the south and eus t. The Battlement Mesa waste water treatment fac 11t1
is 'ocmed further to the west of the site " There are housing deve lo;::iments located to the
northeast and southeast of the site .
3.9 Development Over Faults and Risk of Seismic Acti vity
Tnere are no majc· fa u'ts s h:>·,·,~ n t re Gra nd \'al.e;· area on t he Geologi c ar:i Str..icrn·e r·lJ~ cf
tl"e Grn mi Junctic'l C i.adrar·;le Colorn d:> and Utah 1::::as h on, , 273 .• -i-.ere are r:> n1ao::ed
fau ·:~ ~h:\•1n on the 0 re im nar,.-Geolog ic M::i;: cz tne Sra~d ·-.:a e: C ua=:rarg le. G:11ic d Ccu1:1·,
Cc :.rado (C~r.'le \een d, ~r d 5r1i:h 19d6; iri the immedia:e ·•· ci'l t ;; of the s te .
Geolcglc ~azard Repor.
L rsa C perat ng Com~n;· SMC B Pac
Garfeld Courty CO
7 O.lc~!Jn A~~oc-.1 a~s
Golaen . Cclomio
October ~O i ..:.
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The P cea nce Basin and other Tertiar1 age basins of the Colorado Plateau are defined by
n·onocl nes, at least a ong one ma,gin . The Grand rogback.1 to me east nea r the town of Rife,
is such a monocl ne .,,ti ch i s thought to have formed by reactivation of pre-e:a:isting . stee::i 'I
dipping fa u t zones in tile Precambrian basement rock . Recent se i smic data suggests that
some of the n·o noclines, espec ·atly in the Rocky r-.i1o untai n foretand near the bo'Jndary with the
Co orado P ateau , overtie a west., south·,•;est., or south-d .rected thr ust fault system . These
blind thrust fau11s transect otder Mesozoic and Pa reozo i c sedimentar y rocks that r esu ted from
two ma. or deformatona l events associated \•/th t he u;i ift of the an cestral Rocky Mountains.
The Grand Ho~back monocline fom1ed above the ti ::> of a blind, Precan•brian basen·ent rock
thrJst taut wedge whic h n·oved southwest and ·we$t -south\'iest into the Pi ceance basin (Grout
and V erbeek, 1992j.
Co orado is co nsidered a reg ior1 of n-inor e::ir.hqu.:ke a\:t '.·i:y; ho\•;ever. there is uncertainty due
to the relahely short historic r ecord. According to the L.SGS Color ado Earthquake H story
on line. newspaper accounts \•1\?re the r:<imar ~· sou rce of earthquake data in Co orado prior to
1 &E2 . Few earthquakes have been reported in this ;:iart of Co orado _ A verf m n·~r earthquake
occurr~ n the northwestern part of Co orado on November 22, 1982 at 3:09 a.m. MST . The
n·a·;nitude 2.9 earthquake was located about 18 mi es northeast of the town of Rlf e and was
felt at a fi$h hatcher/ 1n the area .
The largest quake :n the area occurred on Apri ~. 1984 and had a magnitude of 3.1 o n the
R chter sea e. The quake was felt n Carbonda te and in G tenwood S!'.lrings . Of the hundreds of
quakes that occurred in the Car1Jondale area duri ng that t n·e oeriod, 12 were reported as fet
3.10 Flood Prone Areas
The fociriti; is not shown with n the FEMA El•J yea· flccd hazard zone based on the Flood Pian
Ma;:i n the Vicinity of the Town of Parach:Jte. Garfte d County, Co orado, or a Firmette Ma;:i
generated from the FEMA data_ The Colorado R'\·er f food plain :s located ap::irox.n~te l;' 400
feet to the north of the site The unnamed drainage and the Monument Gu lch drainage are
shown as having Zone A - 1 OD-year food ;J a ins ocated along their banks These areas are
a l$O ;:irone to fl3sh foods. The flood o ain along the Co lorado River s shown in relation to the
BMC B Pad on the attached Flood Plain Map.
3.11 Collapsible Soils
Cc laps l:'e so is a·e another ty-:e c~ s ubsidence t1ai cccur~ in parts of we:.te m Co :c rado 11."le ~&
un conso idated sediments are present This ground sett:ement can dan ~age man-made
structuree. such as foundatons, pavements, concrete slabs, utilities, and irrigation works .
Co.laps ble so.ls have not been ma;i;:>ed in the area and are rot expec~ed to be e ncounter~:i r
th:: vic.ir1ity· cf t t-e :.i:e
3.12 Mining Activity
A review of the Grand Va ley 7 .5-minute quadrang e did not show any sign ifi cant m ning
actMtie$ inc ose proximiti; to the proposed BMC B Pad site. 0 ·1 ~-ha ·e n•ining was conducted
north of the tot1.n of Parachute. and there are sand and gravel operat:ons along the Colorado
R..ver. There are no mining acti·ities sho11.n n the immediate area of the ~ite. Natural gas wel s
are sho·\•1n in the surrounding areas of the proposed BMC B Pad s"te.
Ge<>IO>dic r azard Report o
Vsa Cper.at'ng Co'llp.:;n;• SMC B Pac
G.:.rf·eld Courity. CO
OJ~on .4.s.socia t.e-s
Golden , Coto~ado
October 20 • ~
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3.13 Racli0'1Ctivity
Mat'Jlal y occurring rad o&tive n·ateria s are not expected to be a.n issue at the site Colorado
oil and gas operations are 11ot known to ha 1.·e a signficant _problem with natura lyoccurring
rad ·::>active materials (NORM) or techno og ica ~I enhanced nat'Jrally occ·Jrring rad oacti ve
n·ateria s (fENORM); however, there have L'ee n son·e instances v.tiere pipe scale has
contained radium and associated radon ga$. A NORM sur,<ey including sie specific testng
could be :>erforrned to further assess the radon potentia ;::.t the sits to mmte as a baseline
assessment if used;> pe or pipe scale s to be disposed offsite i n the tJtJre.
Olsson reviewed the Co orado Su letin 40. Radioact ve Mineral Ccc1Jrrences of Co orado which
states 1hat nearly all of Garfield Counr/s uran ·um producton came before 1954, and most of
that came from the Rifle and G:i.-;le d n•ines . Both of these m nes were located along the s::ime
ore body nea r the to'\'i''l oi Rifle. These occurrences were au host~ ·n the Jurassic Morrison
and Entrada Formations., and tie Tr ass c-Jurass ·c Navajo Sandstone, or the Triassic Ch nte
Formation which are known to contain uranium and vanadium deposits in the co ·Jnty and n ths
Co orado P ateau in general (t,elsan-Moore , Co l ins. and Hornbaler. 1978). These iormations
lie at great depth n the \icinity' of the site and are stratgraphitally below the depth of the
ifilasatch Fom1aton.
The Colorado Departn·ent of Put> ic Health and Environment (CDPHE> has posted a statewide
radon potentia n·a:> on 1heir 1Aiebsite based o n dma collected by the EPA and the U.S .
Gealog ca l Survey. Garf eld Count>; and most of Co orado has been ma;::iped as be ng \•,ith n
Zone 1 -1-'igh Radon Potential. or having a hfgh probabiliti; that indoor radon concentrations \•,i I
el(ceed the EPA action level of 4 picocur"es per iter (pCill).
Radon .snot e:·:pected to be as ;rifi r.art i;·oble'l1 at the pro:>osed site since the deve opn·ent
\•/II not inctu de any permanent structures, pers.onne w ll not be onsite for extended periods, and
the site wi I not be de\•e loped with structJres co nta nlng basements or s'Jbstruct>Jres in whi ch
radon can accumulate .
G~lo.tJiC I-azard Repor.
L. ~sa C per.rt ng Co-npan;• BMC 8 Paa
G.:.'f·eld County. CO
OJxon .".ssoci:1tE.::
Golaen , Colorado
October 20 ~ .t.
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4.0 Conclusrons and Recommendations
The iol!ovrng cone usions and recommendations were made follo·11.~ng a re)-iew of the a ... ai abl e
site data for natural and geolog c hazards n the vie nity of BMC S Fad site lo cat~ in Garfie ld
County, Co orado .
• Geolog ·cal hazards are not e:.;pected to be associated 'Aith the installat on of buried
utilties. at 1he BMC S Pad Corrostve soi ma1• be a I n·itation to this constructi on , t 1:>: ti":>
lrmt;::tion sho :i :! l:e ab e to i:e cverc.on·e with ~roper eng r ree ~r1g .t des ig n ~ a rd
cons ~uct :r_ Cathodi c i;ro~e c t i o ri f:r buried pip:1g may reduce c::rros1.:in resJ t ing frc1 i
saltr. in these s:iJ,:;.
• Avalanche conditons are not expected to be a hazard in the area of t he site .
• The site is located on al uvium and terrace gravels o'.'erlying pre-his.to ne niud f ow and
fan grave deposits. The s'te is \•,i'lh n the b\•,n limi:s f:r Ba::lei1e1! Mesa and there are
e)(isting wells and other structures in the area inc uding the Battlement Mesa waste
water tre-atrnent facilify• and housing developments to the northeast and SO'J1heast of t he
si1e . The mud flow, terrace-, ar.d fa n grave:. are not e xpected to cons:itute a geolcg c
ta::ard b· the SMC 8 Pad development
• Rockfall areas are not present in the area of the s te and are not e:-:pe cted to be a
geologic hazard affecting the site .
• T ne site is n ~t r, an area mapped as ari al uvial fan ha::ard are:i ; hO\'ieve r, the s'te is
underlain b:,• al uvi·Jm and fan gravels, and the foom of creeks on the northwe.st s de of
Battlement Mesa are n ~ante-:i ·,•;th anu...-ial gravel. Aluyjal fans have been deposited at
the n~ouths of Monument Gulch and other nearby streams .
• Slope is a not e l pected to be a geo'og i c t:i.:ard affectir:g de·.·elc~men: of the SMC B
P~d site.
• The An•ada loam soils are corrosive to both steel and con cr ete, and t he subsol has a
t igh shrink-s-\•,el potertial. Corros·'.'e and e:-:pans \•e so Is are potential y presen t in the
vicinity of the proposed BMC S Pad site wh ich is a rn ~itation for some site development.
• Cc laps b'e sc ·:s are not pre5e nt ir1 tte ·•i cin:t1• of t he proposed B\.1C 5 Pad site.
• t-lc significam faul ts have b~n n·aped er are l.ncwn i n the BMC 5 Pad site .
• The site is not mapped as be ng with in the t C1: ye ar f oo:! ~ 'ain Flas h f oo :iir.g is :i
hazard f~ lcwer e e· .. atic n5 i.f ong Mor 1.1n-ert Gulch and areas along ine Colorn:!o R ~·er .
Areas immediately adjacent to these streams are lac.ate-:! \•1i1h ;n the t CO year food pain
and are prone to food risks.
• There are no min ng activ'ties shol/m in the \•i cinity of the site. Natura gas well drillin g
has been conducted 'n the area since the 1 es::::s.
• There are nos gr 1ii ca17it radioactive m neral de:iosits knm•m in t he n•n•e<f ate are a of the
site . The presence of NORM may l>e an i ss ue with explorat on and producton and could
be an issue \"ith used pipe scale or used eq ui pme nt. Rad 'oactive m ateri als are not
expected to pose a significant hazard at the site .
Geob:Jic t-a:z.lrd Repori
Lrsa Cperatng Com~.:n:,• SMC B Pac
G.:.ofeld Courty CO
10 OJ~on Asso~ia~~
Golden , Colorado
Octob~r ~D I .!
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5.0 References
• Cat.t'i ion '\",'.8 ., 1£172 .. G~c o;ic ~r,d .3:~c:ure M;:p o: t"le Grnr:: .. 1Jn·:t1or Ou~drang le .
Cc oradc and .... t~t·, U~:?-S. ~/a p 1-73 '3 ~c;:le i 250.GQD
• CC "l'l<e I. J .R .• Vee-r e ·."; = Sn·ith Mc .. 1866. =>rel i n· r,~r,· Gecl :-g ic r~·a~ or t"le Gra rd
":'r:lle:; OJadrar;'e. Gartield County Colom::~. sca l e 1:24:JoJtJ
• Grout, M.A. and \lerbeek, E.R., 1992. U.S.G.S. Bullet in 1767-Z. Fracture History of the
DNlc.<e: Crsek ar.d Wolf Creek Anticiines and Its Retati'or. to Lar<Jm l c!e Basm-M:irg,=n
Te .ctonism, Soi..them Pjcear.ce B{Js,•n,. Ncrlhwes!em Coiomdo , 32 p.
• Fsciler, R .P., 1960, Vanadium-Urnnium Deposits of the Rifle Creek Area, Garfeld
County, Co orado . IJ.S.G S. Bu letin 1101 . 52 p.
• Ha I. "i/v .J .• Jr-. 1992, U.S .G.S. Bu lletn 1737-R. Geoiog1 of the Centro•' Roon P.'~!5tHJ
Area . Northwestern, Coiorado , 26 p.,
• Harman, J.B. and Murray, 0 . J ., 198!:-. Soi.' Sl..'rttey of Rif:e AreD, Co•'orfjdo, Parts of
G;:ufiei'd •md .'iAesa Counties. Co.1cr&Jcfo : U.S. De::mrtn·e nt of Ag riculture. So I
Conserv'ation Serice. in cooperation with the Co' orado Agri cu t uml Ex::ierime nt Station .
1~9 p. t\e,o plates. and 20 ma::> sheets.
• Ne son-Moore, J.L.1 Bishop Col ins, D., Hornbaker, A.L., 2005 . Coiorad·~ Geo!ogic
Survey, BuUetin 40, ,q,3c!fooc!ive ,•.·fi'nern•' Occurrences of Cc.'or<Jdo . pp 154-15-9 {CD)
• Robson, S.G. and Banta, E.R ., 19•35 , U.S.G.S. HyrJro ,•ogi c lnvesf.'gatfons AtltJ s 730-C,
Grour:c!water At.i:1s of rt.e Vrnted Sta!es, Segment 2, Arizona , Co,•orOJdo, Me w Mexico,.
Vtah, 32 ;>.
• To;:iper, R., Sp<ay, K. L, Be lis, \/y' H ., Ham lton, J .L., Barkman , P.E .. Gro~inri l'IOJter Af.i<Js
of Coiorodo. Colorado Geologic Su~·e~·. 2003, Specia Publication 53. 210 p.
• Yeend, v:.E., 1969, Quatemart Geo ·ogy of the Grand and Battlement Mesas Area
Co orado. USGS Professional Fa?er 6 17, 5!: p, 1 :::>ate.
Online Refe rences
• Co orado Oil and Gas Conservaton Comm ss on
• Mat'Jral Resources ConseNation Ser.r.:ce -So i Survey
• G'71rfield County
t-.ttp://cogcc.state.co .us/
bttp: //v.ww .nrcs. usda. go•.:/
• Slcpe !--azard:; r ttp:/l:=rfie ld-co'-nw.com/g.:oz·aoh c-irforma:ion-
s·.·s:ems l docu'l"lere/6.;;923I;C•j.:.:?2.o cpeia:: pdf
• Soil Hazards: h':t:>: //garf eld-ccurtv corr l;eogr:c"lk-i nfcrm:tio'l·
s·.·s:ems /d,:>cU'l"lere/64?..3S:2S l 20C423so lna2 pd"
• Surficill l Gecl:9y =·f Garf e:d County· t-t:p :l:'::rfield-coi_nty.ccm/geog·aoh c-
in'¥mat1 g i-s·.-~te 'Tls:'cc.:u me n:s/ geoloi:l ;·"If; I rd s I 24s JrfEeo pdf
• Cc oradc Ge:.:o;ica Sur./ey wel:s:i e: ::>:t2·!lf'"?Sj.Ci.::.,, eta:=-C(;I ush;ruds
• Cc oradc Gec.'o;ica ~•urv·ey wel:::;·:e: "l:t:i //geosLr.-ey.~ta:e u;/lard :'Pu.:;/P •ofe.:;ic·n::i l
Geologist
• Co orado Departme nt o ( Publ c t-ealth and En v.ronment: htto:l/co-
radon.info/CO radon mao.html
Geologic l-:a2.lrd Repon
l.•sa Coerat ng Co'l'lpany BMC 8 Paa
G.;.rf eld Courty. CO
11 O!cs::m .4..sooc•:ite~
Golcen . Colo~ad:)
Octobe-~ ~O l~
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EXHIBIT \
O\oLSSON
'
' I J?PP
ASSOC I A T ES
October 20, 2015
Mr. Fred Jarman
Garfield County Community Development Director
108 B'h Street, Suite 401
Glenwood Springs, Colorado 81601
RE: Response to Analysis of Geologic Hazard Report with Consideration to Supporting
Pipelines by Robert L. Arrington, BSME, PE -Ursa Operating Company BMC B Pad,
Garfield County, Colorado
Dear Mr. Jarman:
Ursa Operating Company (Ursa) retained Olsson Associates (Olsson) to prepare a Natural and
Geologic Hazards Assessment Report for its BMC B Pad located in the SW X, NW X, Section
18, Township 7 South, Range 95 West, of the 61h Principal Meridian, Battlement Mesa, Garfield
County, Colorado. The report was prepared on October 3, 2014 in accordance with Section 7-
207 of the Garfield County land use development code (LUDC) effective July 2013, as revised
in December 2013.
Mr. Robert L. Arrington , BSME, PE prepared an analysis paper titled, Analysis of Geologic
Hazard Report with Consideration to Supporting Pipelines dated October 3, 2015 ("Analysis").
This is a response Mr. Arrington's Analysis concerning the Natural and Geologic Hazard Report
("Report") prepared by Olsson for Ursa's BMC B Pad location and applicable references to the
BMC D Pad also located in East Y2 NW X Section 18, Township 7 South, Range 95 West.
Olsson's Natural and Geologic Hazard Report was not written for the pipeline right-of-way and
was not required for the pipeline application . Mr. Arrington's Analysis was presented in four
sections as follows:
• A preface
• A bullet summary analysis
• An analysis following Olsson's report format
• Remarks
Olsson's responses follow Mr. Arrington's Analysis format.
Preface
Mr. Arrington begins his analysis with a preface that states that he is attaching excerpts of the 4-
203 .G.4 submittal with copies of the pages addressed. Mr. Arrington states that the LUDC has 3
points of applicability to the analysis that are identified as B . Landslide Area, C. Mudflow Debris
Area and E . Mr. Arrington asserts potentially unstable soils pose a problem and creates hazards
that were allegedly unrecognized in the Report.
4690 Table Mountain Drive, Suite 200
Golden, CO 80403
TEL 303.237.2072
FAX 303.237.2659 www .olssonassociates.com
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The Analysis states "The Geologist Kevin J. Taylor affixed his Stamp o (sic) the Report,
prepared by Geologist James Hix, but Taylor states, 'However, I have not visited the proposed
site, ... ' The geologists then rely heavily on the use of geological maps to reach conclusions.''
This is incorrect. Mr. Kevin J. Taylor, reviewed the report and affixed his stamp to the report
prepared by Mr. James W. Hix, a qualified geologist under the definition in Section 4-203 of the
LUDC. Mr. Taylor did not state that he had not visited the proposed site, as this is a statement
by Mr. Hix.
I concur with Mr. Arrington on the value of site visits, and while I did not visit the proposed site, I
have performed field work in the area and am familiar with the geology of the area. A site visit
was beyond the scope of work requested by Ursa.
Conclusions presented in the Report were based on geologic reports and map review and past
field work I have conducted in the vicinity of the site as stated in the geologist certification of the
Report. Mr. Taylor has also performed field work in the area and is familiar with the area
geology.
Mr. Arrington's Analysis suggests that by not visiting the site that there may be other materials,
maps, or information that was not considered, and that Olsson may have missed three
dimensional visual observation. At the time of the Report, the BMC B Pad site development was
reportedly a production well pad site and available materials, maps, and relevant information
were provided by Ursa. Olsson has viewed the area during previous field work conducted for
other clients in the project area which provides the necessary perspective.
The Report defines the types of natural and geologic hazards as ldentified in the LUDC. As
stated in the Report, the LUDC defines a geologic hazard as "A geologic phenomenon that is so
adverse to past, current, or foreseeable construction or land use as to constitute a significant
hazard to public health and safety or to property." The Analysis purports to examine and
provides commentary on the topics in the Report including landslides, alluvial, slope, corrosive
or expansive soil and rock, mudflow areas, and development over faults.
Analysis
The following presents Mr. Arrington's Analysis assertions and Olsson's responses to each.
1.) The Battlement/Morrisana (sic) Mesas are basically one in materials composition and
landslide/slump origin. The Pad B site, a terrace below the main Battlement mesa, is an
alluvium (sic) fan from drainage of the mesa. There are no indications of stability tests
and sampling was done or recorded in the Report. The stamping geologist admits not
visiting the site.
The unconsolidated materials present on Battlement Mesa and Morrisania Mesa are not
one in materials composition or origin. The Report identified the site as being located on
alluvial fan deposits and terrace deposits underlain by upre-historic" mudflow and fan
gravel deposits. The alluvial and floodplain deposits beneath the BMC B Pad site consist
of mud, silt, sand, and gravel, locally derived coalescing fan deposits and sheet-wash
deposits along the Colorado River including the Grand Mesa Formation of Pinedale age
glaciation and Recent deposits. These sediments also include well-rounded, well-sorted
(poorly graded), non-locally derived crystalline rocks transported from areas to the east
and reworked alluvium of Pleistocene age.
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The sediments on Morrisania Mesa consist of alluvial terrace, and alluvial fan gravels, of
the Lands End Formation (Yeend, 1966) shed from Battlement Mesa and associated
with Bull Lake glaciation during the Pleistocene Epoch. These gravels were deposited as
older, poorly-sorted (well graded), alluvial fan gravels, consisting of sub-rounded to sub-
angular basalt and locally derived slabby siltstone, sandstone, and marlstone with some
probable mudflow debris, north-northwest of Battlement Mesa.
The fan gravels of the Lands End Formation that were deposited onto the Colorado
River valley and its flood plain were erased by subsequent river erosion and mass
wasting. Although it appears that there has been significant downcutting (600 feet) by
the Colorado River since the deposition of the Lands End Formation gravels on Holms,
Morrisania, and Taughenbaugh Mesas, it should be realized that the surfaces of these
mesas were perched above the Colorado River base level during fan gravel deposition
(Yeend, 1966). The wetter conditions associated with glaciation observed on Grand
Mesa provided sufficient runoff for the development of mudflows and fan debris
peripheral to Battlement Mesa, but insufficient to cause appreciable downcutting (Yeend,
1966). The younger fan and mudflow deposits of the Grand Mesa Formation, also of
Pleistocene age, are observed in numerous localities on the Grand Valley and Rulison
7.5-minute quadrangle maps transecting the Lands End Formation, overlying it on the
mesa surfaces, cutting through it on the mesa margins, and lying below it in the
Colorado River valley (Yeend, 1966).
According to the LUDC, development is permitted to occur on an alluvial fan if it can be
demonstrated that the development cannot avoid such areas, and the development
complies with the minimum requirements and standards. Pad development would be
adjacent to an existing parking lot and building. Stability tests and sampling were beyond
the scope of work requested.
2.) The soils are corrosive to concrete and steel and utilities, including pipelines, will be in a
bore coming down a steep slope. The pipelines will require concrete and/or steel
anchoring systems. However, WPX's failure of such a pipeline that occurred in this same
area and expected environment, is not part of the Report's consideration. The steep
slope, and its' (sic) potential failure in landslide/slump effects, was not addressed. This
pipeline system may have additional corrosive problems from induced A.G. electrical
current from proximity to power grid lines.
The WPX Energy pipeline leak/ pipeline failure incident is not relevant to the proposed
development since it was publicly reported that the pipeline failure was the result of a
faulty valve. Proximity to overhead power lines is neither a natural or geologic hazard,
but may be a consideration for engineering and design prior to pipeline installation and
pad construction. Similarly, automatic closure valves may also be considered as proper
installation and design, but are not relevant to a natural and geologic hazard report. It is
beyond the scope of the Report to suggest prescriptive remedies for pipeline installation
and design.
The Report identified the soil conditions onsite as being potentially corrosive to concrete
and steel. The Report also identified steep slopes as a potential site condition due to the
Arvada Loam soils being found on 6% to 20% slopes. The intent of the Report was to
OLSSON ·~· 4
ASSOCIATES October 2015
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identify conditions that could result in potential natural and geologic hazards, and states
that "Engineering, design, and construction practices of the proposed development are
expected to mitigate the limitation of slopes at the site since the site is located within an
area developed for other land uses", including natural gas well pads. The LUDC requires
special engineering studies for development on slopes 20% or greater. The slope of the
proposed BMC B Pad and adjacent areas is less than 20%.
Article 9: Pipelines section of the LUDC, applies to pipelines greater than 12 inches in
diameter and over two miles in length or two cumulative miles if separated by municipal
or public lands, or any pipeline that is more than five miles in length or five cumulative
miles if separated by municipal or public lands. The proposed development does not
require a permit since it does not meet this criteria. It is expected that the pipelines will
be constructed to comply with applicable engineering and design standards.
The Report also states that the slopes and corrosive soils may pose technical
challenges for utilities, but that it is expected that these limitations can be overcome with
proper design and installation. With respect to corrosive or expansive soils and rock, the
LUDC requires that surface drainage be directed away from foundations, and that runoff
from impervious surfaces be directed into natural drainages which are located to the
east and southwest of the site, as well as the Colorado River to the north. With respect
to stormwater drainage, the Colorado Department of Public Health and Environment
(CDPHE) requires construction stormwater permits for land disturbance of one acre or
more, or disturbance of five acres or more that are part of a common plan of
development. The Colorado Oil and Gas Conservation Commission (COGCC) has
additional post-construction stormwater requirements for well pads in its 1000 series
rules.
3.) Maps used to evaluate structure cited two maps, referred herein as 1973 and 1986. The
1973 map was a compilation of quadrangle maps, but there is no history that the Grand
Valley quadrangle had any prior mapping until the 1986 Preliminary Surfacial (sic). The
1986 map did not show any structural data. This means that the finding of "no mapped
faults" CAN NOT imply there are no faults in the area of the site. Seismic testing for
faults is needed. There is a U.S. G. S. map that does show Precambrian basement faults
projected; and, they tie into a block fault to the Southwest that could all have implications
on the development.
The Analysis is incorrect that the 1986 map does not show structural data. A review of
the 1986 map depicts structural contours drawn on top of the Wasatch Formation
bedrock as indicated in the legend on the upper right-hand side of the Map MF-1883
(Donnell, Yeend, Smith, 1986). There are no mapped faults shown on the Preliminary
Geologic Map of the Grand Valley Quadrangle, Garfield County, Colorado (MF-1883).
Much of the map area is covered with tens of feet to hundreds of feet of unconsolidated
sediments, which obscures fault traces. The lack of identifiable fault traces at the surface
suggests that there has not been any significant fault movement in the area since
prehistoric times. Fault traces that are observed in the surrounding areas show minimal
displacement and are not laterally extensive.
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ASSOCIATES October 2015
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4.) Three Garfield County geologic hazard maps were used as a basis to discount hazards
on the basis they did not show site problems. This is misleading as the areas evaluated
do NOT lie within the confines of the studies' boundaries. The statements of maps not
showing hazards South of the Colorado River, while true, misleads because it is outside
the study area.
The Analysis is critical that the Report provides a review of available Garlield County
geologic hazard maps, and that the site lies outside the mapped boundaries. The
Analysis then goes on to cite examples from Carbondale, Divide Creek, Eastern slope of
Colorado, and Oklahoma -areas that are far removed and geologically dissimilar than
the proposed site -to support its conclusions. Criticism for using existing geologic maps
of the surrounding area contradicts the Analysis statement that the mesas are basically
one in materials composition and origin. Just because a geologic map is old does not
necessarily mean that it is outdated or wrong. A current map of the area printed from the
USGS mapped faults website does not show any faults in the area of the site (attached).
A similar statewide map from the 2012 Interactive Colorado Earthquake and Late
Cenozoic Fault Map Server from the Colorado Geological Survey also does not show
any mapped faults or earthquakes plotted in the area of the BMC B Pad.
5.) During the time the Report was made, there was active planning of an injection well for
produced water, holding tanks, and a pump house. These features would add even an
extra burden on the Pad site and the possibility of subsidence or sink holes. The Report
should have invoked further ground tests. Such conditions found on site have created
sink holes in Carbondale. For injection operations the basement fault should be
considered particularly with earthquake potential having been upgraded for 2015 by the
U.S.G.S.
Information provided to Olsson at the time of the Report preparation indicated that the
proposed development was for the BMC B production well pad as stated in the Report.
Information was not provided to Olsson indicating the BMC B Pad well pad was an
injection well site. Construction of such facilities would require additional analysis.
Not all natural subsidence is the result of sink holes. Sink holes result from several
causes such as the presence of karst or dissolution of evaporite minerals that produce
subsurface voids or caverns below ground surface. These natural subsidence conditions
are not present at the site, but are present elsewhere in Colorado along the Roaring
Fork River or Eagle River where carbonate or evaporite sediments are present. Sink
holes can also result by other means including anthropomorphic causes.
Further ground tests were beyond the scope of work requested of the Report.
Discussion of the area structural geology and earthquake potential is discussed below.
6.) For the LUDC type of natural and geological hazards listed in the Executive Summary of
the Report, items C., E., F., G., H., and I. have shortcomings that need further
examination or requirements of remediation.
• ... ~ OLSSON ~ 6
ASSOC:IATiS October 2015
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Nothing in the Report prevents or precludes further examination; however, further
evaluation or remedies were beyond the scope of work at the time the Report was
written for the proposed BMC B Pad development as presented to Olsson.
Analysis Using Report Outline Format
Structural Geology
The Analysis is critical of the Report statements of Uno mapped faults." The Report also includes
information that mountainous areas are fault prone, as mountains are a visible indication of a
structural weakness in the earth's crust and that faults are not always visible at the ground
surface.
Development Over Faults and Risk of Seismic Activity
The LUDC states that development shall be permitted over faults only if the Applicant
demonstrates that such areas cannot be avoided and the development complies with mitigation
measures based on geotechnical analysis and recommendations, as certified by a qualified
professional engineer, or qualified professional geologist, and approved by the County.
Faults have not been mapped in the area of the site since bedrock is covered by thick layers of
unconsolidated sediments from mudflows, debris flows, alluvial fans, and alluvial terrace
deposits. No faults have been observed in the area since the surficial sediments obscures the
underlying bedrock, and there are no visible fault traces expressed at the surface of the
unconsolidated sediments. Those faults that are exposed in the region closest to the site show
minimal displacement and are not laterally extensive. Although the Report states that faults
have not been mapped in the area, page 8 of the Report describes the regional structural
setting and structure of the Piceance basin. It discusses the possibility of blind thrust faults -
faults that do not show surface expression. The Report also provided a review of reported
earthquakes in the vicinity of the site with few earthquake reports identified as low magnitude
(2.9 to 3.1 on the Richter scale) reported to the east near Carbondale and Glenwood Springs.
The Analysis states that since the Report was drafted, the USGS has rated the earthquake risk
higher than in 2008 and 2014. The updated earthquake potential shows the area with a peak
acceleration, expressed as a fraction of standard gravity (g) between 0.1 and 0.14 on the two
percent probability of exceeding in 50 years map of peak ground acceleration. The 2015 map
shows the study area with moderate risk of damage based on the Modified Mercalli Intensity
scale (VI to VII) showing the locations of major populations and the intensity of potential
earthquake ground shaking that has a 2% chance of occurring in 50 years.
At the time of the Report the proposed development was for construction of a production well
pad. If the well(s) are converted to Class II underground injection control (UIC) injection well(s),
then the COGCC will have additional requirements for this change in status including step-rate
tests, mechanical integrity tests (MIT) -conducted initially and every five years thereafter, and
well construction details. A water sample from the intended injection formation will need to be
collected and the water quality evaluated, or an aquifer exemption rationale will need to be
performed. The latter triggers review by the CDPHE, Division of Water Resources, and the
Region 8 EPA for the Class II UIC well, in addition to the COGCC requirements. The rate and
volume of produced water and exploration and production (E&P) waste (fracturing and flow-
OLSSON ") 7
ASSOCIATES October 2015
( back water) are regulated as limits placed within the permit. The COGCC may require seismic
monitoring before and during the initial injection of fluids into a permitted Class ll UIC disposal
well.
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Soil
The Report describes the characteristics of the Aivada Loam, including limitations for
community development which include high shrink-swell potential, salinity, and steep slopes.
The erosion hazard is severe, permeability is very slow and available water capacity is high.
As stated in the Report, and acknowledged in the Analysis, soils at the site were identified as
being corrosive to steel and concrete. Buried piping and structures onsite will need to have
adequate cathodic protection to prevent corrosion. This may include pipe coatings, anode beds
or sacrificial anodes, or rectifiers that induce a current on the buried pipe.
The Analysis states that engineering beyond the pads is important and vital. The Report was not
an engineering report. A construction stormwater management plan and permit will be required
as part of disturbance of one acre or more, or common plans of development that disturb five or
more acres. The Report could have acknowledged that there is a requirement in place for
construction stormwater permit coverage and preparation of a stormwater management plan
(SWMP).
Aquifers
Page 4 of the Report describes the alluvial and bedrock aquifers in the area. The discussion is
not limited to water wells and water well depths, although that information is included where
applicable. The Analysis states that there are "three emergency water wells" upstream of BMC
B Pad site. The Analysis alleges that these wells are independent of the river water table
according to the BM Metro District, and that these wells must be sampled before and after any
drilling.
The COGCC requires baseline groundwater monitoring of area wells prior to drilling and states
these as a condition of approval (COA) for permit to drill. The Analysis does not explain why
upstream (upgradient) water wells must be sampled.
Utilities
On Page 5, the Report states that trenches for water pipelines, natural gas pipelines, and
electrical lines are expected to be associated with the proposed development. The Report
states that slopes and corrosive soil may pose technical challenges to the installation of these
utilities; however, it is expected that these limitations can be overcome with proper design and
installation. Other commercial and municipal development has occurred in the area.
Proximity of power lines is not a natural or geologic hazard, but is an engineering and design
consideration for the installation of a pipeline.
Landslide Areas or Potential Landslide Areas
On Page 5 the Report clearly states that the site is located on mudflow and fan gravel deposits
overlain by younger terrace deposits, alluvial, and floodplain deposits. There are earthflow and
soil creep deposits mapped in the south half of Section 19, but these deposits are not mapped
in Section 18, where the site is located. This was shown on the Preliminary Grand Valley
Geologic Map. Movement of the extensive earthflow and soil creep ~lopes has ceased, except
f ·~ ~~ \OLSSON ~1 8
ASSOCIATES October 2015
( for local occurrence of very recent slumps and mudflows. The Report describes extensive
solifluction deposits on the Rulison 7.5-minute quadrangle map to the east.
(
The conditions on Morrisania Mesa and the WPX pipeline are outside the scope of work for this
natural and geologic hazard report as it pertained to the proposed development at the time the
Report was written. Equipment failure, such as a faulty valve, is not a natural or geologic
hazard. The LUDC states that development shall comply with recommended construction
practices to artificially stabilize, support, buttress, or retain the potential slide area and to control
surface and subsurface drainage that affects the slide area. The proposed location of the BMC
Pad Bis in an area of the planned unit development (PUD) that has been developed for other
commercial, residential, and community infrastructure as acknowledged in the Analysis. The
developed areas lie between Battlement Mesa and the proposed BMC B Pad.
Alluvial Fan Hazard Areas
On Page 6 of the Report, it does discuss the Garfield County Surficial Geology, 2007, and then
it describes the site geologic conditions from the Preliminary Geologic Map of the Grand Valley
(Donnell, Yeend, Smith, 1986). The site is on the northeastern part of an alluvial fan created by
Monument Gulch and other unnamed intermittent drainages.
According to the LUDC development shall only be permitted to occur in an alluvial fan if the
Applicant demonstrates that the development cannot avoid such areas, and the development
complies with the following minimum requirements and standards, as certified by a qualified
professional engineer, or qualified professional geologist, and as approved by the County. The
development is to 1) be protected using structures or other measures on the uphill side that
channel, dam, or divert the potential mud or debris flow, and 2) disturbance in the drainage
basin above the alluvial fan is to be prohibited, unless an evaluation of the effect on runoff and
stability of the fan and on the groundwater recharge area shows that disturbance is not
substantial or can be successfully mitigated.
Mudflow and Debris Fan Areas
The Analysis points out a correction in the Report that there are housing developments
northeast, South (emphasis added), and southwest of the proposed BMC B Pad site. These
housing developments to the south were constructed on the uphill side of the proposed BMC B
Pad site, in the drainage basin from Battlement Mesa, and lie directly in the path of potential
mudflows, debris fan areas, and landslides that would occur potentially affecting the pad. The
proposed development of the BMC B Pad will include adequate stormwater controls as required
by the CDPHE-Water Quality Control Division and COGCC.
Flood Prone Areas
The Analysis is critical that the Report used 100 year flood plain standards. This is the standard
that is specified in the LUDC. The Map FP-1 included in the Report showed that the proposed
BMC B Pad was located outside the 1001500 year combined floodplain.
Collapsible Soils
This refers to hydrocompactive soil which is the most common type of collapsible soil.
Hydrocompactive soils form in semi-arid to arid climates in the western United States and large
parts of Colorado in specific depositional environments characterized by low density and low
moisture content. The soil grains in this dry soil are not packed tightly together, but instead the
·OLSSON., 9
ASSOCIATES October 2015
( grains are loosely stacked, forming a skeletal fabric, that can collapse when wet. The Analysis
acknowledges that loam combined with fine pore clay or silty clay loam can hold water trapped
in the pores, and that the water capacity of the Arvada loam is high. This is not characteristic of
hydrocompactive soil.
As described above, sink holes can result from a variety of geologic settings and mechanisms,
the most common resulting from dissolution of carbonate sediments or evaporite minerals
producing voids in the subsurface. These conditions are not present at the proposed BMC B
Pad site.
Mining Activity and Radioactivity
The Analysis combines these two sections of the Report. No mining activities are indicated on
the maps reviewed or on aerial photographs of the area. lt is not clear in the Analysis how
"crossing" of drill bores affecting two other operators in the area, a need to review nearby drill
patterns, or how WPX having pooled interests in the northern part of the Battlement PUD is
related to or relevant to natural or geologic hazards, mining, or radioactivity.
The Analysis states that there is a migrating Tritium source from Project Rulison located several
miles away, but at deeper depth. Project Rulison is located approximately six miles to the
southeast of the BMC B Pad site, 'as the crow flies', and was conducted at a depth of 8,426 feet
below ground surface. Area testing of water wells, surface water, and natural gas and produced
water has been conducted and has not detected any tritium from Project Rulison.
( Remarks
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1. In the Analysis "Remarks" section, it is pointed out that the water treatment plant,
aeration ponds, settling reservoir, water inlets and pump house are located within the
PUD boundary in addition to structures listed in the Report. This suggests that the
Battlement PUD is not an area with natural or geologic hazards that are so severe that
they cannot be eliminated or mitigated for the purposes of development.
2. The Analysis states that pipeline failure in a bore coming down to BMC B Pad site
could be impacted by a landslide or mudflow, resulting in damage to the pipeline and
result in produced water or E&P waste discharged to the "gully" or (Colorado) River,
and impact to water inlets before any warnings occur. The Analysis does not seem to
be concerned about the neighboring wastewater treatment plant, or natural gas and
sewer lines associated with the housing developments to the south, which would also
be affected by such an event. .
3. The Report identified the BMC B Pad as being constructed on an alluvial fan overlying
older mudflow and debris fan materials and alluvial terraces. Since there is an existing
building and a parking lot located on the same alluvial fan adjacent to the proposed
pad, it is unclear what the Analysis statement "and should be treated as such" means.
4. The BMC B Pad is relatively "flat" and has drainage to the northeast "gully" which
drains to the Colorado River. The CDPHE and COGCC require a construction
stormwater permit and a stormwater management plan which includes disturbance of
soils for the welt pad and pipelines.
~ •• w) .. \ OLSSON ··· 10
ASSOCIATES October 2015
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5 . The Analysis is incorrect in comparing the geology of the BMC B Pad to sink holes in
the Carbondale area . A geotechnical survey of the site prior to construction of tanks
or other structures may be prudent in light of the conditions identified in the Report.
6 . Seismic testing may be required by the COGCC if the well status is converted to a
Class II UIC well.
7 . The LUDC does not specify criteria beyond a 100-year flood level.
8 . Drill mapping by other operators Is not relevant to a natural and geologic hazard report.
Please contact me if there are any additional comments or concerns regarding the Olsson's
Natural and Geologic Hazards Assessment Report for the Ursa BMC B Pad site .
Sincerely,
Olsson Associates, Inc.
James W . Hix, PG
Senior Geologist
O\oLSSON .~
AS5 0(:1 A f E$
Kevin J. Taylor, PG
Senior Geologist
11
October 2015
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EXHIBIT
14DQ
GAS DRfLLING: Are YOU next? By Sandy Getter
f n 1998 my husband and r bought land in Battlement Mesa from the Battlement
Mesa Company and built a house. NOW we're finding out that the company didn't
register with Garfield County the potential drilling pads within the community until
1999. They continued selling property and homes without disclosing this.
There were NO drilling rigs to be seen in 1998. That's probably because up to 1995
Colorado had 160-acre well spacing! Then the Energy Dept. allowed one to be
drilled per 80 acres. Next, in 1997 our very own COGCC (Colorado Oil and Gas
Conservation Commission) approved 1 per 40 acres; in 1998 1 per 20 acres; and in
2003 1 per 10 acres. [n 2007 multiple wells (now up to 25) from one well pad were
approved.
With 40-acre spacing, well pads were kept in rural and back country areas. Since
the drilling boom in the 2000's, our community has been surrounded by drilling
pads. Since we are a PUD (Planned Unit Development) and have strict covenants,
the gas companies placed their pads just outside our perimeter and have been
drilling multiple natural gas wells from each pad, accessing the minerals beneath us
using directional drilling (at least up to 2500 feet) and fracking.
At this time they can access almost all of these minerals underneath us from
OUTSIDE our PUD. The proposed Phase I of Ursa and B. Mesa Co. would put well
pads INSIDE the PUD--one by the Colo. River and near our water intake and another
within 1,000 ft. of homes. There also would be a high-pressure gas line right along
the back yard of 22 homes. The next two phases would include 2 well pads along
our award-winning golf course and one below a village of homes, plus an injection
well.
The Battlement Concerned Citizens (BCC) formed to work with gas companies to
mitigate the effects of drilling so close to our community. They're not a renegade
group opposed to all drilling, but they do care about the air & water quality, noise,
traffic, home values, etc.
With an oversupply of gas and low natural gas prices, why is this proposal on the
table now? Are we the test case for all of Colorado? If they can come into a PUD,
then they can drill anywhere. Will the COGCC and our county commissioners
protect us and deny this special use permit?
(
EXHIBIT
'~~---
October 7 comments from Sandy Getter, 68 Meadow Creek Drive, Battlement:~M~••••J
for Fred Jarman, Ursa, Battlement Mesa Company, the O&G Commiss ioners, Garfield
County Commissioners, and the COGCC
Reasons why Ursa and Battlement Mesa's proposals for pads B & D should be denied
at this time:
1. A Comprehensive Drilline Plan (CDP) was not presented at this t ime, Only
pads B and D are detailed. There are 3 more pads, all highly contentious, and
should be addressed all at one time.
2. When asked if there would be an injection well at the Sept. meeting, Ursa
stalled because they have told us at a previous meeting in B. Mesa that there
will be one with either phase 2 or 3. (Injection wells do not belong w ithin a
community.)
3. Phase 2 is again by the river, downriver from the treatment plant, but below
many homes.
4. Phase 3 is for one well pad next to #6/7 along the golf course, while the other
is by the driving range. (These a r e VERY intrusive.)
5. In Ursa's proposals, just in phase 1, there are still many additional problems
that need to be addressed: feasibility of bores; closeness of facilities to over
22 residences; need for water pipeline to be included alongside the gas line;
emergency closure valves for pipelines; irrigation system around pad D; all
items mentioned by Fred Jarman; better means of communication with the
community; disaster plans for the community, etc.
Reasons why this proposal should be rejected NOW AND FOR ALL TIME .
1. Most of the natural gas beneath Battlement Mesa is being extracted from well
pads on the perimeter of our Planned Unit Development (PUD).
2. With directional drilling, off-set drilling, and using existing pads, it is possible
to access all the gas under the PUD . Exxon is getting far more gas royalties
from beneath our community than they would have ever gotten from their 14
original well pads of the 1980's that had one well per pad.
3. Just because Ursa doesn't have the drilling rig or equipment to drill
directionally in the Wms. Fork Formation for up to a mile is not a good
reason to invade the heart of our community. They should lease, buy or sell
to some other company, such as Encana or WPX, who is willing to drill
farther out from the pad outside the PUD, if Exxon and Colorado insist on
accessing every "last drop" beneath us.
4. The proposals do not show good faith and concern by Battlement Mesa
Company or Ursa for residents in this community.
5. Even the existing pads surround ing us are as close to homes as perm itted,
that is, 500 ft. The industry hasn't graciously said they would stay 1,000 ft . or
more away.
6. The money spent on 5 pads, a pipeline, more plans and meetings within the
community would be far better spent on increased directional drilling from
OUTSIDE the PUD, on established pads.
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7. At this time Ursa already has 3 approved pads that have yet to have drilling,
so they have the ability to keep workers employed.
8. At this time both oil and natural gas are at an extremely low price. There is
no national emergency; we are already energy independent; workers are
being laid off by many other companies. If Ursa is planning to sell overseas,
and thus refute the claim that drilling in the U.S. is for our own energy
independence, that would REALLY put a black mark on the ind us try.
9. 0 & Gare a boom and bust industry. We're in the down cycle now. Home
values HAVE NOT increased. Our evaluation went up somewhat this year
after a radical downturn two years ago. However, most people trying to sell
are having to radically reduce their price.
10. Well pads will not go away. Ursa has said that the next big drilling would be
in the deeper Niobrara Formation, which can be drilled horizontally.
Therefore, all minerals beneath Battlement Mesa could be accessed from the
well pads outside our PUD, they said. So why put pads within, just so they
can change their minds and use them because it's easier, perhaps? Ursa also
is not really committing to how long they'll be drilling from the pads
proposed. Drilling might last forever, as one company sells to the next or
another formation is found to have quantities of gas.
11. We, the residents of the community should not be subjected to these
proposals over and over. Not only is it stressful, but it keeps our community
in limbo. Re-marketing this ideal location will not take place until a firm
decision is made. If wells are being drilled, the place will languish.
Just who is REALLY behind this proposal???
1. Ursa mentioned that they had to use a lease with Exxon or lose it. Why
not go into another agreement instead?
2. Battlement Mesa appears only to want immediate money, that is, from the
surface rights. They've done a poor job of marketing our area and now
have empty apartments and land that no one wants to buy, mostly not
knowing whether drilling might end up in the community. (They "gave"
the golf course to the Parks and Rec Dept. because they've been losing
money on it.) Again, if drilling occurs along this golf course that is one of
the best on the western slope, the course might fold.
3. Is Exxon insisting that ALL possible gas be extracted, at all costs??? Do
they care at all about the community that they planned originally?
4. Are we being "set up" and sacrificed by the industry just to show their
might, that is, that they can drill anywhere they please?
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EXHIBIT
_F_re_d_Ja_r_m_a_n __________________________________________ JS!SS
From:
nt:
To:
Subject:
Lillian.wyant@q.com
Sunday, October 4, 2015 7:20 AM
Fred Jarman
Request for Special Use Permit in the community of Battlement Mesa
Regretfully l was unable to attend the recent Planning Commission meeting as my husband is disabled and I
could not leave him alone to travel to Glenwood. It is my understanding that a second meeting will be held
regarding this permit request, and I would sincerely appreciate serious consideration be given to holding this
meeting in Battlement Mesa where all residents affected by this decision can be represented and heard.
When we purchased our home in Battlement Mesa, it was the culmination of a 40 year dream ... our dream
retirement home and our final place of rest. We were so happy with our purchase that my husband even wrote
a poem about our property entitled "Where Eagles Soar!' It seems that now our home has become our "final
place of STRESS". Not only are we concerned about the loss in the value of our home, the loss of our peaceful,
scenic community, but also the increased risk to our health and safety by having an industrial site in our
"planned" residential community. Should a serious environmental accident occur such as a toxic spi11 or fire,
evacuating my husband with his disabilities in a safe and timely manner, would be almost impossible. Mesa
Vista, an assisted care facility, is also located in our community .... .is any thought given to the increased risk
these residents will face?
Isn't it morally and ethically wrong to ruin the lives of some 4000 residents for the sake of gas that can be
accessed from outside of the community through horizontal drilling? If, in fact, as Ursa states, there are some
·es that cannot be accessed from outside of the planned unit development.. .. well, then, maybe it need not be
"'~cessed at all. What is the national emergency? Last week's Daily Sentinel reported there was a GLUT of gas
in the United States .... then what is the urgency? What is the justification for ruining a community in order to
drill every last bit of gas when it is not even needed? Why is Ursa's profit and loss statement more important
than our health, our safety, our homes, our community, our investment? Why don't we matter? Why is a
corporation more important than the people who live here?
It is my hope and prayer that the Planning Commission will do the "right thing" and deny this special use
permit. Put yourselves in our shoes ... .in our homes ..... DO YOU WANT A GAS WELL NEXT TO YOUR
HOME? IS THAT WHAT YOU WOULD HA VE EXPECTED IN A PLANNED COMMUNITY WITH
COVENANTS THAT WAS MARKETED AS THE COLORADO DREAM? Would that be your
dream? ..... OR YOUR WORST NIGHTMARE? Would you have invested 40 years of hard work and savings
into a home that promised a noisy, dirty, unhealthy neighbor? THAT IS NOT WHAT WAS PROMISED TO
US! Drilling in a planned residential community is just wrong! If it feels wrong, it usually is ..... please ask
yourself, DOESNT THIS FEEL WRONG?
Please share my thoughts with the Commission members. Our future and the quality of our lives rest with your
recommendations .
Lillian Wyant
133 Willow Creek Trail
Parachute, CO
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ftrlhu~ ~ Carmen litschl:!W3kl
0 1 -2 'J m be:-:i1 :1e Ci;· ... :a
Parachu te, CO 81 ti3S
PUBLIC NOTICE
TAKE NOTICE: that Battlement Mesa Partners. LLC & URSA Operating Company has applied to the
Planning Commission, Garfield County, State of Colorado, to request a recommendation of approval
for a Special Use Permit on a property situated in the County of Garfield, State of Colorado; to-wit:
Legal Description:
Practical Description:
East Y2 of the NW~ of Section 18, Township 7 South, Range 98 West within
the Battlement Mesa Planned Unit Development, a parcel having 1248.87
acres.
PIO: 2407-081-00-152
Section: 8 Township: 7 Range : 95 ALL THAT PROPERTY LOCATED IN SEC
5, 6, 7, 8, 9, 10, 16, 17, 18, 19 IN 7-95. ALSO THAT PROPERTY LOCATED
IN SEC 13 & 24 7-96 ALL WITHIN THE BATILEMENT MESA PUD.
EXCEPT A TR CONT 6.20 AC DESC IN REC #502259. EXCEPT TOWN
CENTER FL #5 AS DESC IN REC #513419 CONT 22.370 AC. ALSO A TR
OF LAND CONT 18.574 AC +/-AS DESC IN BNDY LINE ADJ BK 1703/327,
330 EXCEPT A TR OF L ANI) CX1NT . 37 .65 AC +/-AS DESC ON THE FINAL
PLAT, STONE QUARRY COMMONS, A RE-SUB OF LOTS 5-1 & 5-2 OF
BATTLEMENT MESA PUD REC #691907. EXCEPT A TR OF LAND CONT
35.461 AC +/-AS DESC IN WO BK 1877/16 EXCEPT A TR OF LAND CONT
35.33 AC +/-AS DESC IN SWD BK 1947/706. EXCEPT A TR OF LAND
CONT. 11 .81 AC+/-AS DESC IN THE TOWN CENTER, FLG #6,
BATILEMENT MESA PUD, REC# 743233 & GWD #743971 . EXCEPT FOR
6 TRACTS OF LAND -PARCEL 1, 57.68 AC+/-: PARCEL 2, 76.26 AC+/-:
PARCEL 3, 52.80 AC+/-: PARCEL 6, 35.67 AC+/-: PARCEL 7 , 56 .17 AC+/-
AND OLD HIGH SCHOOL PARCEL, 41 .35 AC +/-AND DESC IN SWD REC
#740298, & TOTALING 319.93 AC+/-
The proposed D Pad location is on a 7 acre portion of the 1248.87 acres
adjacent to and south east of River Blucc Road (CR 307) in the Battlement
Mesa PUD. The proposed site is west of the Valley View Village residential
area and south of the willow Creek Village residential area .
Description of Request: This is a Special Use Permit application for Extraction and Production of
Natural Resources to develop a natural gas well pad (called the "D Pad")
to contain a total of 28 gas wells. The overall pad location will comprise
approximately 5 acres. The property is zones "Low Density Residential"
within the Battlement Mesa PUD.
All persons affected by the proposed plan are invited to appear and state their views, protest or
support. If you cannot appear personally at such hearing, then you are urged to state your views by
letter, as the Planning Commission will give consideration to the comments of surrounding property
owners , and others affected, in deciding whether to recommend that the Board of County
Commissioners grand to deny the request. The application may be reviewed at the office of the
Community Development Department located at 108 8 1h Street, Suite 401, Garfield County Plaza
Building, Glenwood Springs, Colorado between the hours of 8:30 a .m. and 5 :00 p .m., Monday through
Friday.
A public hearing on the application has been scheduled for Wednesday, September 23, 2015
at 6:00 P.M. in the County Commissioners Meeting Room, Garfield County Administration Building,
108 s•h Street, Glenwood Springs, Colorado. ,., ,;_
_-,-// • 'A~~.. ~· ~~904-~·~~ / A.R.. UJAfl '¥ ./ /""'-~ 'T(f ~ ~ f Community Development Department
l .aJ -~ ~ 11. • J .... ;1 () ~ ./ ~ r Garfield County -z:::::.~_,._.,<rQ~ _.,~ z;v~...<h.. LL'dfa."l-c..£ zk.
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EXHIBIT
_Fr_e_d_Ja_r_m_a_n ____________________________________ ...... I Llld Lt
.nt:
To:
Subject:
John Keller <jpkinnj@hotmail.com>
Friday, September 25, 201 S 9:15 AM
Fred Jarman
RE : Battlement Mesa comments about Ursa drilling
I had t:o .leave the meeting before my turn t:o speak came up. I had an
operat:ion recent.ly and it start:ed t:o .leak. I had t:o t:reat: it: yesterday,
but I am okay now. I hope you wi.l.l consider my submission be.low.
My name is John Keller and I reside at 2 Meadow Creek Drive Battlement Mesa
Tonight I have heard for the first time that Battlement Mesa Company knew in 2006 that gas wells would be
drilled in the PUD. They did not tell the residents and in fact hid it from them until 2009 when Antero
announced their drilling plans. They knew residents would make an exodus to avoid the stress and health
issues and more importantly loss of property values and inability to sell their homes and move elsewhere. I
ask the commissioners, how can you know you are getting all the details surrounding the ultimate plan BMC
has? It's hard to rely on what they say since they hid information that is devastating to people they should be
protecting vis-a-vis their fiduciary duty to residents of Battlement Mesa. I ask the Commissioners to fact
check and ask if they have received all relevant information to cover the thirty years this drilling will take
place.
I heard property values have gone up due to drilling operations in Garfield County and Battlement Mesa
having the highest increase. This is very misleading and totally unt rue. Assessed values have gone u p, not
resale values. Battlement Mesa had the highest increase because they had the lowest values in the County.
There are ten single family homes for sale in Battlement Creek Village . Some have been on the market for
over two years. Realtors tell them even after lowering sales prices bel ow their original cost they lose potential
buyers when they disclose gas drilling operations in the PUD .
My point is if you are hearing this false story how much of what else you have heard is false? There i s no
ethics in business. I ask you to fact check everything you have been told by the gas company and BMA now
that I am telling you they are making statements that are entirely false about property values going up with
drilling operations. BMA withholds vital information and URSA is spinning falsehoods. You can put their feet
to fire before committing to more than thirty years of active well activities in the PUD . These companies will
not go out of bus i ness by not drilling in the PUD, but it wreak h avoc on 3,500 people in the PUD .
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DATTlgM~NT M~!a, eo 916?;
l)'TO-i9~-'1515
Director Fred Jarman
Community Development
Garfield County
108 8th Street Suite 401
Glenwood Springs, CO 81601
Dear Fred,
October 5, 2015
The URSA application to drill many wells within the boundaries of the Battlement
Mesa i>UD is before you for your recommendation to our Planning Commission.
There are many technical problems with this application as you know. Bob
Arrington has detailed these technical problems to you in his report "Analysis of
Geological Hazard Report" dated October 3, 2015 These technical issues, except
for injection problems, go away if URSA drills outside the Battlement Mesa PUD.
The added costs that URSA would incur cannot be a consideration in your
recommendation Fred, as you know.
~~erely, r
Vi&~~j ~~
F. Peter Simmons, D. Sc.
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Mr. Fred Jarman, Director
Garfield County Department of Community Development
And Garfield County Planning & Zoning Commissioners
Dear Mr.Jarman and Commissioners;
EXHIBIT
IX X K
I am writing to call to your attention to the need for an alternate site analysis that has
been glaringly absent from Ursa's representations to you and the Commission. Before I
do so, I would like to thank you all for the volume and the quality of the work you have
done for the public thus far. This includes the site visit, some staff recommendations we
thought were very helpful, working late into the evening to allow to make our comments
on Sept 23, and your attentiveness as well . The following comments speak to work
that still needs to be done, however.
Unless a significant number of mineral rights owners with Battlement Mesa addresses
were missed in Ursa's applications, almost no one in living in my community owns
mineral rights. Almost no one but Ursa believes that they must drill inside the PUD to
access the gas. See the 465 resident signatures on the petition you received . The
petition does not ask Ursa to give up the resources or not to drill. Increasing the
distance from our homes could alleviate all of our concerns and possibly mitigation
costs. Proximity to homes is the issue that unites all opponents of Ursa plans .
You, the Community Development Director and commission are able to ask for any
information you want from an SUP applicant like Ursa . You have already asked for four
additional plans as to how impacts can be mitigated. What you have not requested is
an alternate site analysis-the one report that could prevent the impacts altogether.
The Director may request additional information such as an alternate site analysis in his
staff report as allowed under 4-101.D.3 of the Garfield County Land Use and
Development Code.
We believe an alternate site analysis is also required. The 1982 Garfield County Zoning
Code requires an "impact statement" that "shall show that the use shall be designed and
operated in compliance with all applicable laws and regulations of the County, State,
and Federal Governments." As Director Jarman stated, the alternative site analysis is
goi ng to be requ i red at the state level anyway, and they are already in the process of
applying for state permits.
Ursa said on Sept 23 that their alternate site analysis was "95% complete". Moreover,
they have told the public repeatedly that the company has looked at all the options.
What did they look at? Why were other locations discounted? Without seeing their
( analysis, how could we otherwise verify that they even explored other possibilities?
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Was the process so informal that it can't even be reconstructed?
The ruling out of all other possible options has zero credibility with the community for
several reasons. Directional wells throughout our valley are routinely reaching out over
3,000 feet. Everyone believes that money drives every decision in the industry today.
People in the industry, who are not with Ursa, tell us this is only an issue because of
cost.
People are aware that bigger rigs are more expensive, and Ursa has said that the small
rig they want to use has fewer capabilities. If Ursa can't afford a bigger rig, we shouldn't
have to leave our homes because of it! Ursa should leave and sell their rights to
another operator, or come back when they can afford one. Why should their business
expenses be essentially paid from our life savings as represented by investment in our
homes? Taking Ursa at their word that they can't access minerals from farther away is
extremely unfair and is not the way for the department or the Commission to promote
quality of life in Garfield County.
Sincerely,
Doug Saxton
81 Ridge View Place
Battlement Mesa
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Fred Jarman , AICP
Director
Garfield County Community Development
108 81h Street, Suite 401
Glenwood Springs, CO 81601
Betsy A. Leonard
71 River View Place
Parachute, CO 81635
September 30 , 2015
Dear Mr. Jarman,
EXHIBIT
1 Y'ft
I was in attendance of the Community Development meeting on Wednesday,
September 23, 2015 commencing at 6:00 pm. I was surprised that conditions were so
taxing, especially after asking that the meeting be moved to Battlement Mesa. There
were no extra chairs available for an overflow crowd . The sound system did not seem to
be working, or if it was it was not amplifying beyond the front. The room temperature
was most oppressive. Was the system not running?
I am curious to learn why Don Simpson, Vice President of URSA Resources, was
allowed to speak during the public comment period . He had ample time during URSA's
presentation , and he is not considered a public citizen (at least in this context). This was
a long meeting and the public adhered to the rules: waiting to speak and utilizing 3
minutes. Thank you for allowing us this opportunity and for listening to all who spoke.
This meeting was not adjourned until very late in the evening, a hardship for those of us
who had to drive 47 miles back to Battlement Mesa at such a late hour. Many of our
citizens are elderly people and this hardly seemed fair. They are only trying to protect
their most precious investment, their homes. As you know, we are of the opinion that
drilling does not belong in residential neighborhoods. We are most concerned about the
possible health impacts of having drilling so close to our homes.
Sincerely,
Betsy A. Leonard
Battlement Mesa Resident
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EXHIBIT
I i!.2 2
INTRODUCTION
Ursa Operating Company, LLC.
BMCBPAD
Wetland Boundary Determination
Garfield County, Colorado
Prepared for:
Ursa Operating Company, LLC.
Prepared by :
WestWater Engineering
25 l 6 Foresight Circle # 1
Grand Junction, CO 81505
October 2015
At the request of Ursa Operating Company, LLC (Ursa) West Water Engineering (WestWater)
performed a wetland boundary determination near Ursa·s BMC B well pad. The project is
located on private lands in Section 18, Township 7 South, Range 95 West, Sixth Principal
Meridian in Garfield County, Colorado (Figure 1 ).
The purpose of identifying the wetland/upland boundary is to ensure activities related to the well
pad development are a minimum of 35 feet from the wetland edge.
WATERS OF THE U.S. (WOUS)
Deli11eatio11 Methods
WestWater biologists performed the wetland boundary determination on October 16, 2015 . The
wetland boundaries were identified on the basis of the vegetation, soils, and hydrologic
characteristics present at the site in accordance with U.S. Army Corps of Engineers (ACOE)
standards included in the '·Corps of Engineers Wetland Delineation Manual, January 1987"'
(ACOE 1987) and Regional Supplement to the ACOE Wetland Delineation Manual : Arid West
Region (Version 2.0, September 2008) (ACOE 2008).
The wetland boundary delineation included identification of plant species, species composition,
and soil structure. Soil borings (18 ±in. deep) were taken with an auger for observation of
wetland soil characteristics and hydrology indicators to aid in the delineation of wetland
boundaries.
Wetland boundary points were marked in the field and located using an Ashtech ProMark 100
sub-meter accuracy GPS unit. Boundary flags of the wetland/upland boundary were left in the
field . Data collected at the wetland/upland boundaries were recorded on ACOE Arid West
Region Wetland Determination Data Forms, which are available upon request.
WestWater Engineering Page 1of6 October 2015
A delineation report for the ACOE was not requested at this time. All pertinent data was
collected during the site visit and a delineation report and jurisdictional determination can be
prepared for submittal to the ACOE if requested.
Deli11eatio11 Fi11di11gs
On the basis of wetland vegetation, soils, and hydrology, WestWater identified approximately
353 linear feet of wetland boundary adjacent the unnamed tributary of the Colorado River
(Figure 2). Wetland consisted of a combination of riverine emergent wetland, palustrine
emergent wetland, and palustrine scrub-shrub wetland.
Approximately 65 feet separates the wetland from the closest point of the well pad (Figure 2).
The distance from the well pad to the wetland ranges from 65 feet to 155 feet. The
wetland/upland boundary is depicted in Photos 1 and 2. The northern comer flag of the well pad
in relation to the wetland boundary is shown in Photos 2 through 4.
Photo 1. View of the wetland boundary flags south of the wetland/upland boundary data points.
WestWater Engineering Page 2of6 October 2015
Well Pad
Comer
Photo 2. View of the wetland boundary flags north of the wetland/upland boundary data points
and the well pad ·s northern corner stake.
Well Pad
Photo 3. View of the well pad's northern comer stake to the west from the wetland.
WestWater Engineering Page3of6 October 2015
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( REFERENCES
ACOE. 1987. Environmental Laboratory. 1987. ''The Corps of Engineers Wetlands Delineation
Manual," Technical Report Y-87-1, U.S . Anny Engineers Waterways Experiment
Station, Vicksburg, Mississippi.
ACOE. 2008. U.S. Anny Corps of Engineers Regional Supplement to the Corps of Engineers
Wetland Delineation Manual: Arid West Region (Version 2.0). U.S . Army Corps of
Engineers Research and Development Center, 3909 Halls Ferry Road, Vicksburg, MS
39180-6199.
WestWater Engineering Page 4of6 October 2015
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( -WeUand Edge ..__..,..,,.;,...
-Edge of Pad
Figure 1
Ursa Operating Company
BMC B Pad
Wetlands Boundary Determination
Vicinity Map
~'Nestwater Eng ineeri ng
":;!/1 Consulting Engl nHrs r. Sdentlsts
OS
Miles
1 in = O 4 miles
USA Topo Parachute 1.24000 Quad
October 2015
,-..
"(::( Welland Date Point
Boundary Flag Point
-WeUand Edge
Pad Corner Stake
=Edge of Pad
l -=1 BLM
,-..... r"'\
Figure 2
Ursa Operating Company
BMC B Pad
Wetland Boundary Detennination
Distance to Edge of Wetlands
n 'Nestwater Engineering
-:a' Consulllng Engineers & Sclentlsh
0 ~o 80 120
f""t
October 2015
e:fa',;::;.1~G1!. H~<11• :niaJ l.;t 2t i ,trt. •11