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HomeMy WebLinkAbout16 Impact AnalysisIMPACT ANALYSIS O\OLSSON ASSOCIATES THIS PAGE LEFT BLANK FOR TWO-SIDED DUPLICATION. O\OLSSON ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 Table of Contents Garfield County Zoning Resolution of 1978 1 5.03.07 Industrial Operations Impact Analysis 1 Section 5.03.07(1) Impact Statement 1 Section 5.03.07(2) Traffic 3 Section 5.03.07(3) Distance Buffers 3 Section 5.03.07(5) Rehabilitation 3 Land Use and Development Code 2013 3 Section 4-203.G. Impact Analysis 3 Adjacent Land Use 3 Site Features 4 Soil Characteristics 4 Geology and Hazard 5 Groundwater and Aquifer Recharge Areas 5 Environmental Impacts 6 Nuisance 9 April 28, 2017, revised July 14, 2017 OLSSON ASSOCIATES Battlement Mesa PUD Phase II — BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 This page intentionally blank. April 28, 2017, revised July 14, 2017 ii O\OLSSON ASSOCIATES Battlement Mesa PUD Phase II — BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 Article 4 — Impact Analysis GARFIELD COUNTY ZONING RESOLUTION OF 1978 5.03.07 Industrial Operations Impact Analysis Section 5.03.07(1) Impact Statement (a) Wetland and Water of the U.S. Impacts: Construction of the BMC A Pad has limited potential to affect wetlands and Waters of the U.S. by introducing fill, either directly during construction or indirectly from runoff. Implementation of a Spill Prevention, Control, and Countermeasure Plan (SPCC), a Stormwater Management Plan (SWMP), and Best Management Practices (BMPs) associated with this type of project will provide mitigation for any potential impacts. Mapped drainages and wetlands will be protected by Ursa using buffer zones, stormwater BMPs, and SPCC BMPs. (b) Noise and dust may be generated during construction of the proposed well pad. The impacts of these nuisances will be mitigated by use of industry best management practices. Data gathered during previous sound monitoring has demonstrated Ursa's compliance with the appropriate sound regulations. A preliminary noise analysis report modeled for this location is included in this submittal. No sound wall mitigation is proposed during operations or production phases due to the natural shielding that will be provided by the topography in the area. As discussed with County Planning Staff, the use of sound walls during operations would likely reflect sound up the slope to the south of the pad, impacting nearby. Sound study indicates that unmitigated noise levels will remain below the required thresholds. A receiver site to the northwest of the pad location is unnecessary as there are no residences in proximity and the northwest corner of the pad is somewhat buffered by the existing Waste Water Treatment facility. After the well pad has been placed into the production phase, Ursa will comply with COGCC and Colorado Revised Statutes for noise levels in Residential/Agricultural/Rural zones. Ursa will comply with COGCC green completion practices and the EPA's natural gas STAR program to reduce VOC emissions to the lowest level technically possible for the wells on the BMC A pad. To this end, Ursa will apply a low emissions flow back process for well completions and will route tank venting emissions through an enclosed combustor. Enclosed combustor type flares will be employed to burn off emissions at a 95+% efficiency. These flares have little to no visible flames and will not be visible beyond the boundaries of the oil and gas location. Enclosed combustors are the best technology for eliminating fugitive VOCs. Use of VRUs will be determined on a case-by-case basis due to the dry nature of gas in the Battlement Mesa area. A temporary VRU may be used for newly completed wells during the peak flow back period. The VRU will allow for the capture of additional vapors instead of burning them. This will decrease tank pressures. A combustor has a 95+% efficiency rating to reduce VOCs. Additionally, Ursa commits to using carbon blankets over hatches on temporary tanks to reduce odors. Ursa has in place a program to immediately respond to odor complaints via their Land Department. Other best management practices to control emissions include limiting the idling of vehicles while on site and the use of green completion techniques. April 28, 2017, revised July 14, 2017 1 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase II — BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 Ursa has developed and implemented a Leak Detection and Repair (LDAR) emissions monitoring program with infrared cameras to detect and repair any fugitive emissions. In addition, they have implemented a Storage Tank Emissions Monitoring (STEM) program to monitor and repair any fugitive emissions associated with condensate and produced water tanks. These programs have been developed in compliance with CDPHE Regulation 7 requirements. Ursa's LDAR program is set-up to inspect all facilities at least monthly during drilling and completion and quarterly during production. If a leak is discovered, the first attempt to repair the leak shall be made as soon as reasonably possible and in accordance with COGCC and CDPHE rules. Pumpers are on location daily and will inspect equipment every day. Pumpers also complete Audio, Visual, Olfactory (AVO) inspections weekly. Potential dust impacts will be mitigated as directed in Ursa's Fugitive Dust Plan using water or other dust suppressants as appropriate. During construction, truckloads of dirt, sand, aggregate materials, drilling cuttings, and similar materials will be covered to reduce dust and particulate matter emissions during transport. Remote monitoring during the production phase will be used to reduce truck traffic and fugitive dust to the extent practical. Lighting impacts during drilling and completion operations will be mitigated per the SUA. All lighting, except as demonstrated for safety reasons, will be directed inward and downward and be shaded to prevent direct reflection on adjacent property and residences in the area. LED lights will be used when possible and practical. Workers will be advised when moving light plants to ensure that the light is focused directly on the work being done. Drilling mast lighting will be downcast and shielded to reduce fugitive light outside the well pad. Safety considerations will take precedence. During the production phase, all lights will be directed inward and downward, towards the interior of the site and away from residences. Above ground facilities will be painted to blend with the environment to minimize visual impacts. (c) Creation of hazardous conditions: Some passerine bird species and small mammals may choose to inhabit or nest on equipment or objects on these locations. The inherent risks associated with these structures are low. By closing or covering all ports, hatches, cavities, and openings (such as the ends of pipes) this potential is decreased. Most non -game bird species and their nests are protected under the Migratory Bird Treaty Act (16 U.S.C. 703-712; Ch. 128; July 13, 1918; 40 Stat. 755) and damaging occupied nests could be considered a "take" resulting in a violation. Indirect Construction Effects: Additional human presence and activity related to construction, operation, and maintenance of the facilities may influence spatial and temporal use of habitat surrounding the project by wildlife. The greatest influence on wildlife use would be during the drilling and completion phases. During the operation and maintenance period, the impacts would be minimal. Since the site exists within and adjacent to significant and long-term human presence, the additional disturbance from this project is expected to be low. Road -kill: Speed limits are set low and most wildlife in the area have become habituated to vehicle traffic. The potential for increased vehicle related mortalities related to this project should be low. April 28, 2017, revised July 14, 2017 2 OLSSON ASSOCIATES Battlement Mesa PUD Phase II — BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 Endangered Fish Species: Designated critical habitat for two endangered fish species (Colorado pikeminnow and razorback sucker) occurs in the Colorado River downstream of the project and upstream as far as Rifle. Potential impacts to aquatic species could include water depletions and runoff from storms or snowmelt that carry increased sediment loads or pollutants to the river. Implementation of a SPCC, SWMP, and BMPs associated with this type of project will provide mitigation for any potential impacts. Section 5.03.07(2) Traffic All movements at the access are expected to operate at acceptable levels of service throughout construction. The addition of site traffic, even in the height of construction, does not increase the existing volumes to amounts required for auxiliary lanes where they are not already provided. Once construction is complete, the daily volumes will reduce to approximately ten vehicles per day for the well pad site. Based on the results of the analysis, no mitigation is recommended for the site. Water pipelines will be installed to move produced water for reuse on other well pads in the area. The pipelines will eliminate the need to truck water, except for upset conditions, thus keeping the traffic volume increases to a minimum after drilling and completions operations are concluded on the well pad. Section 5.03.07(3) Distance Buffers The proposed well pad is in the PSRI zone district. The nearest residence is 500 feet south of the nearest well and 340 feet south of the nearest production facility. It is south and adjacent to the Battlement Mesa Metropolitan District Water Treatment Plant. Section 5.03.07(5) Rehabilitation (a) Ursa will follow COGCC Rules for Interim and Final Reclamation of the proposed well pad. A copy of Ursa's Reclamation Plan is included in Reclamation Section. The SUA with Battlement Mesa also outlines the Owner's request for landscaping and reclamation where appropriate. (b) The proposed well pad will be a COGCC approved location. Ursa will abide by all reclamation requirements set out by the SUA and the COGCC. Ursa's surface disturbances are covered under a statewide bond held by the COGCC. A copy of Ursa's bond is included in Reclamation Section. LAND USE AND DEVELOPMENT CODE 2013 Section 4-203.G. Impact Analysis Adjacent Land Use The adjacent uses within a 1500 -foot radius of the site consist of a water treatment plant, vehicle, boat, and RV storage; residences, a skate park; and vacant PUD commercial property. The proposed use is consistent with the predominant existing uses in the surrounding area, including the storage facility and water treatment plant. Visual, vegetative, and topographical buffering will be implemented to separate the proposed facility from the less compatible nearby uses, including the residences and the park. These uses will not be impacted by construction and operation of April 28, 2017, revised July 14, 2017 3 OLSSON ASSOCIATES Battlement Mesa PUD Phase II — BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 the well Pad A beyond normal industrial uses of the parcel once the well pad enters the production phase. Additionally, the Colorado Oil and Gas Conservation Commission (COGCC) requires that operators to notify all surface and building owners within 1000 feet of the proposed project site. Local governments with land use authority are required to be consulted and notified as part of COGCC's Large Urban Mitigation Area (LUMA) rules. COGCC has a series of notifications that go out to owners and local governments including pre -application notifications. Certifications of the LUMA notifications sent to date are included with this submittal. Ursa has planned stakeholder meetings to update the status of development plans in the PUD. Ursa participated in Garfield County's LUMA consultation visit on February 28, 2017. Per Garfield County submittal requirements, a list of landowners and mineral rights owners within 200 feet of the proposed project parcel is included with this submittal. Ursa's Land Department researched mineral rights by using records from the Garfield County Clerk and Recorder's office. Adjacent landowner addresses were obtained from the Garfield County Assessor's web based database. Exception Zone Waivers have been executed with the six mobile home owners that are within 500 feet of the proposed production facilities on the BMC A Well Pad. Approval of the COGCC Form 2A will constitute approval of the exception location. Site Features The site is located on private land located within the Battlement Mesa PUD adjacent to the Battlement Mesa PUD Water Treatment Plant. The proposed well pad is off River Bluff Road (CR 307) in the NE 1/4 of the SE 1/4 of Section 13, Township 7 South, Range 96 West and the NW % of the SW 1/4 of Section 18, Township 7 South, Range 95 West of the 6th P.M. on Garfield County parcel number 2407-081-00-152. Access to the site is via River Bluff Road from the intersection of West and South Battlement Parkway. The project site encompasses approximately 2.75 acres at an elevation of about 5100 feet. Geologic hazards potentially affecting the BMC A well pad include slope area, corrosive soils, and expansive soils. The affected area covers a variety of habitat types consisting of native and disturbed rangelands as well as agricultural areas and a small amount of riparian or wetland communities. The vegetative cover consists of mostly sage brush and juniper mix. Areas of riparian and wetland vegetation are dominated by broadleaf cattail, narrowleaf cottonwood, reed canarygrass, and three -leaf sumac. The proposed well pad is on a vacant lot in the unplatted portion of Battlement Mesa PUD located between the Tamarisk and Monument Creek Village Subdivisions and the Battlement Mesa Metropolitan District's (BMMD) Wastewater Treatment Facility. BMC A is below the bluff that both subdivisions sit on. The site is relatively flat riverfront land sloping toward the Colorado River. The project site, in its pre -developed condition, is locate in a semiarid plateau region between 5000 ft and 6000 ft in elevation. Soil Characteristics The Natural Resources Conservation Service (NRCS) Soils Map shows the area soil types. The following soil units, are within the study area around BMC A well pad: April 28, 2017, revised July 14, 2017 4 OLSSON ASSOCIATES Battlement Mesa PUD Phase II — BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 • Ildefonso stony loam, 6% to 25% slopes, Map Symbol 33, and 25% to 45%, Map Symbol 34: These soil units are deep, well drained, moderately sloping, hilly, to steep soils found on mesa breaks, valley sides, and alluvial fans at elevations ranging from 5,000 to 6,500 feet amsl. These soils formed in mixed alluvium derived primarily from basalt. The surface layer is a brown stony loam about 8 inches thick, the underlying material is a white, strongly calcareous stony loam to a depth of 60 inches. Permeability is moderately rapid, available water capacity is low, the surface runoff is medium and the erosion hazard is severe for these soils. • Arvada Loam, 6% to 20% slopes, Map Symbol 4: The Arvada loam is a deep, well drained, sloping soil formed on fans and high terraces at elevations between 5,100 feet and 6,200 feet above mean sea level. Typically the surface layer is a moderately alkaline, pale brown loam about three inches thick and the substratum is light brown to brown silty clay loam to a depth of 60 inches. Permeability is very slow, and available water capacity is high. Surface runoff is moderately rapid, and the erosion hazard is severe. The Ildefonso soils and the Arvada loam soil are corrosive to uncoated steel and low to moderately corrosive to concrete. Community development over these soil types is limited by low strength, shrink -swell potential, large stones, and slopes. Buried piping and structures onsite will need to have adequate cathodic protection to prevent corrosion due to the salinity of these soils. Slopes should be protected to prevent erosion. Geology and Hazard For a full report of the Geology and Soils Hazards, see the Geologic Hazards Section. The BMC A well pad site is located in the southeastern part of the Piceance Basin. The Piceance Basin is an irregularly-shaped elongated basin formed by tectonic forces associated with the Laramide orogeny. These forces down warped the earth's crust and formed the Piceance Basin as a result of the uplift of the surrounding Colorado Rocky Mountains and the Colorado Plateau. The Piceance Basin is the major structural geologic feature in the region. It is bound to the east by the Grand Hogback monocline, the White River Uplift to the northeast, the Gunnison Uplift to the south, the Uncompahgre Uplift to the south and southwest, the Douglas Creek Arch to the west-northwest, and the axial basin uplift to the north. Sedimentary rocks in the southwestern Piceance Basin gently dip to the north - northeast except where this regional dip is interrupted by low -amplitude folds. Numerous small sub -parallel northwest trending folds have been identified in the Green River Formation within the basin. There are no mapped faults shown in the area of the site on the Geologic and Structure Map of the Grand Junction Quadrangle, Garfield County, Colorado or on the Preliminary Geologic Map of the Grand Valley Quadrangle, Garfield County, Colorado. Groundwater and Aquifer Recharge Areas The site is located on a terrace above the Colorado River flood plain. The Colorado River is located approximately 400 feet to the north. The Monument Gulch creek drainage is located approximately 1,000 feet to the southwest. There is an unnamed intermittent drainage 300 feet to the east northeast of the site. April 28, 2017, revised July 14, 2017 5 OLSSON ASSOCIATES Battlement Mesa PUD Phase II — BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 The Wasatch Formation locally yields water to wells in some areas, but is generally considered a confining unit. The Tertiary sedimentary rocks in the Piceance Basin are generally fine-grained and well cemented resulting in very low hydraulic conductivity in the rock matrix. Sandstone and siltstone generally occur in lenticular bodies and locally have moderate hydraulic conductivities which range from 0.001 to 0.01 foot per day. These lenses of sandstone and siltstone are often widely spaced and not interconnected which further limits the volumes of groundwater the formation can yield to wells. In some areas, fracturing during the structural deformation that occurred when the Piceance Basin was uplifted and through dissolution of cementing minerals has enhanced the permeability and hydraulic conductivity in parts of the Piceance Basin aquifer system. Water well depths in the area typically range from 250 feet to 300 feet below ground surface along the terraces above the Colorado River. Static water levels reportedly range between 20 feet and 60 feet bgs based on a review of permitted water wells in the vicinity of the site. Surficial aquifers are present in the alluvium along the Colorado River and its major tributaries. The depth to groundwater is expected to be less than 20 feet in close proximity to the Colorado River. This alluvium is typically too thin, narrow, and discontinuous to be considered a major aquifer, although in some areas the alluvium is locally important as surficial aquifers. Groundwater within the unconsolidated sediments in the area of the proposed site is controlled by the thickness of the sediments and the depth to the top of the Wasatch bedrock. The estimated groundwater flow direction in the vicinity of the site is likely to be sub -parallel with the Colorado River, flowing north-northwest toward the Colorado River through the center and northern part of the proposed site. Environmental Impacts See the Impact Analysis: Section 4-203-G (8) Environmental Impacts Report prepared by WestWater Engineering and the Geologic Hazards Report prepared by Olsson Associates for a full analysis of the Environmental Impacts. The project area was evaluated for threatened, endangered, or sensitive wildlife and vegetative species, including but not limited to Greater Sage Grouse, DeBeque phacelia, Parachute beardtongue, Ute ladies' tresses orchid, and Colorado hookless cactus, listed in Garfield County. Determination of long-term and short-term effects on flora and fauna Flora The vegetation communities affected by the project are largely disturbed by previous developments and management practices. The project's impact to important native vegetation would be small within the scope of existing developments and other disturbances. No special status plant occurrences are known to exist nearby. Noxious weeds occurring in the area are discussed in an accompanying Integrated Vegetation and Noxious Weed Management Plan (IVNWMP) prepared by WestWater for this project. WestWater biologists determined that the project would affect three potentially jurisdictional wetlands or Waters of the US. Proper marking, temporary fencing, stormwater, and SPCC BMPs will reduce the likelihood of inadvertent impacts to the wetlands. April 28, 2017, revised July 14, 2017 6 OLSSON ASSOCIATES Battlement Mesa PUD Phase II — BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 Fauna Designated critical habitat for two endangered fish species (Colorado pikeminnow and razorback sucker) occurs in the Colorado River downstream of the project and critical habitat for two additional species (bonytail and humpback chub) occurs downstream of the project near Grand Junction. Colorado pikeminnow and razorback sucker have been documented in the river upstream as far as Rifle. Potential impacts to aquatic species would be limited to water depletions and runoff from storms or snowmelt that carry increased sediment loads or pollutants from the project to the river. Implementation of a Spill Prevention, Control, and Countermeasure Plan (SPCC), a Stormwater Management Plan (SWMP), and Best Management Practices (BMPs) associated with this type of project will provide a good degree of mitigation for any potential impacts. No high-quality raptor nesting habitat would be affected by the project. Short-term effects could include temporary displacement of raptors in an avoidance area surrounding the pad due to increased human presence and equipment associated with construction, operation, and maintenance of the facility. Loss of foraging habitat will occur within the footprint of the proposed well pad. No CPW mapped migration corridors would be affected. Human presence and activity may affect animal distribution by creating avoidance areas and increasing stress on wintering big game. Due to significant human presence, deer and elk that winter in this area have become habituated to human activity and the indirect effects of avoidance and displacement will be diminished. An increase in vehicle traffic may result in additional vehicle related wildlife mortality, although additional traffic resulting from this project would contribute minimally, given current traffic volumes on the existing roads. Fences can pose an increased risk to big game and fencing around the facility should be constructed per published standards that reduce impacts to big game. Potential encounters with black bears could occur if garbage or food is available on the site. Ursa will mitigate the potential impacts to black bears by keeping trash in bear -proof containers and removing on a regular schedule. Once the well pad enters the production phase, all trash will be removed by employees during their periodic maintenance visits. Nesting habitat for migratory birds will be lost in the footprint of the pad and road and construction during nesting season could result in destruction of active bird nests. The vegetation removal required for development of this project will reduce foraging habitat available for small mammals and birds. Human presence and activity may affect animal distribution. An increase in traffic could result in vehicle related mortalities. The proposed well pad is not located in Greater Sage Grouse habitat. Determination of the effect on designated environmental resources, including critical Wildlife Habitat Development of the project would not directly affect any designated critical wildlife or occupied plant habitat for threatened or endangered species. Downstream habitats for aquatic species could be affected by water depletions, pollutants, and sedimentation. This project would contribute to cumulative effects of habitat alteration in the area. April 28, 2017, revised July 14, 2017 7 OLSSON o ASSOCIATES Battlement Mesa PUD Phase 11— BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 Impacts on wildlife and domestic animals through creation of hazardous attractions, alteration of existing native vegetation, blockade of migration routes, use patterns, or other disruptions Creation of hazardous conditions: Some passerine bird species and small mammals may choose to inhabit or nest on equipment or objects at the site. The inherent risks associated with these structures are low. By closing or covering all ports, hatches, cavities, and openings (such as the ends of pipes) this potential is decreased. Most non -game bird species and their nests are protected under the Migratory Bird Treaty Act (16 U.S.C. 703-712; Ch. 128; July 13, 1918; 40 Stat. 755) and damaging occupied nests could be considered a "take" resulting in a violation. Livestock and big game will likely avoid the project sites. Direct Construction Effects: Construction will remove or significantly alter nesting and foraging habitat for a variety of migratory and non -migratory birds, mammals, and reptiles. Indirect Construction Effects: Additional human presence and activity related to construction, operation, and maintenance of project features may influence spatial and temporal use of habitat surrounding the project by wildlife. For sites that would be developed adjacent to significant and long-term human presence, the additional indirect effects in those areas would be smaller. Road -kill: Speed limits are relatively low and most wildlife in the area has become habituated to vehicle traffic on public transportation rights-of-way. The potential for vehicle related mortalities related to this project would be moderate. Evaluation of any potential radiation hazard that may have been identified by the State or County Health Departments Naturally occurring radioactive materials are not expected to be an issue at the Site. Colorado oil and gas operations are not known to have a significant problem with naturally occurring radioactive materials (NORM) or technologically enhanced naturally occurring radioactive materials (TENORM); however, there have been some instances where pipe scale has contained radium and associated radon gas. Olsson reviewed the Colorado Bulletin 40, Radioactive Mineral Occurrences of Colorado which states that nearly all of Garfield County's uranium production came before1954, and most of that came from the Rifle and Garfield mines, located along the same ore body near the town of Rifle. These occurrences were all hosted in the Jurassic Morrison and Entrada Formations, and the Triassic -Jurassic Navajo Sandstone, or the Triassic Chinle Formation which are known to contain uranium and vanadium deposits in the county and in the Colorado Plateau in general. These formations lie at great depth in the vicinity of the Site and are stratigraphically below the depth of the Wasatch Formation. The Colorado Department of Public Health and Environment (CDPHE) has posted a statewide radon potential map on their website based on data collected by the EPA and the U.S. Geological Survey. Garfield County and most of Colorado has been mapped as being within Zone 1 — High Radon Potential, or having a high probability that indoor radon concentrations will exceed the EPA action level of 4 picocuries per liter (pCi/L). Radon is not expected to be a significant problem at the proposed site since the development will not include any permanent structures, personnel will not be onsite for extended periods, and the April 28, 2017, revised July 14, 2017 8 O\OLSSON ASSOCIATES Battlement Mesa PUD Phase II — BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 site will not be developed with structures containing basements or substructures in which radon can accumulate. Nuisance Noise and dust may be generated during the different operational phases of the proposed well pad. The impacts of these nuisances will be mitigated by use of industry best management practices. Data gathered during previous sound monitoring has demonstrated Ursa's compliance with the appropriate sound regulations. A preliminary noise analysis report modeled for this location is included in this submittal. No sound wall mitigation is proposed during operations or production phases due to the natural shielding that will be provided by the topography in the area. As discussed with County Planning Staff, the use of sound walls during operations would likely reflect sound up the slope to the south of the pad, impacting nearby. Sound study indicates that unmitigated noise levels will remain below the required thresholds. A receiver site to the northwest of the pad location is unnecessary as there are no residences in proximity and the northwest corner of the pad is somewhat buffered by the existing Waste Water Treatment facility. After the well pad has been placed into the production phase, Ursa will comply with COGCC and Colorado Revised Statutes for noise levels in Residential/Agricultural/Rural zones. Ursa will comply with COGCC green completion practices and the EPA's natural gas STAR program to reduce VOC emissions to the lowest level technically possible for the wells on the BMC A pad. To this end, Ursa will apply a low emissions flow back process for well completions and will route tank venting emissions through an enclosed combustor. Enclosed combustor type flares will be employed to burn off emissions at a 95+% efficiency. These flares have little to no visible flames and will not be visible beyond the boundaries of the oil and gas location. Additionally, Ursa commits to using carbon blankets over hatches on temporary tanks to reduce odors. Ursa has in place a program to immediately respond to odor complaints via their Land Department. Other best management practices to control emissions include limiting the idling of vehicles while on site and the use of green completion techniques. Ursa has developed and implemented a Leak Detection and Repair (LDAR) emissions monitoring program with infrared cameras to detect and repair any fugitive emissions. In addition, they have implemented a Storage Tank Emissions Monitoring (STEM) program to monitor and repair any fugitive emissions associated with condensate and produced water tanks. These programs have been developed in compliance with CDPHE Regulation 7 requirements. Ursa's LDAR program is set-up to inspect all facilities at least monthly during drilling and completion and quarterly during production. If a leak is discovered, the first attempt to repair the leak shall be made as soon as reasonably possible and in accordance with COGCC and CDPHE rules. Pumpers are on location daily and will inspect equipment every day. Pumpers also complete Audio, Visual, Olfactory (AVO) inspections weekly. Potential dust impacts will be mitigated as directed in Ursa's Fugitive Dust Plan using water or other dust suppressants as appropriate. During construction, truckloads of dirt, sand, aggregate materials, drilling cuttings, and similar materials will be covered to reduce dust and particulate April 28, 2017, revised July 14, 2017 9 OLSSON ASSOCIATES Battlement Mesa PUD Phase II — BMC A Ursa Operating Company and Battlement Mesa Land Investments 016-3531 matter emissions during transport. Remote monitoring during the production phase will be used to reduce truck traffic and fugitive dust to the extent practical. Lighting impacts during drilling and completion operations will be mitigated per the SUA. All lighting, except as demonstrated for safety reasons, will be directed inward and downward, and be shielded to prevent direct reflection on adjacent property and residences in the area. LED lights will be used when possible and practical. Workers will be advised when moving light plants to ensure that the light is focused directly on the work being done. Drilling mast lighting will be downcast and shielded to reduce fugitive light outside the well pad. Safety considerations will take precedence. During the production phase, all lights will be directed inward and downward, towards the interior of the site and away from residences. Above ground facilities will be painted to blend with the environment to minimize visual impacts. If a nuisance complaint is received on a location for noise, odor, dust, or other nuisances, Ursa's standard operating practice is to respond to each complaint as soon as possible. The person receiving the complaint, usually the Landman, gathers as much information (such as wind direction, time, duration, strength, nature of odor or noise, etc.) about the issue as possible. This information is relayed to the operations lead who begin to determine the source of the issue and what may be causing it. Once the root cause of the issue is identified, the team determines mitigation efforts that will help remedy the concern(s). The land team follows up with the stakeholders on the effectiveness of the mitigation efforts and adjustments are made as necessary. All complaints are logged and tracked to improve Ursa's overall best management practices (BMP) performance on existing and future assets. Ursa has implemented a Stakeholder Hotline for concerns and complaints that will be answered 24 hours a day, seven days a week by a designated Ursa staff member. The number is 970-620-2787. Ursa also has a 24/7 emergency hotline, 855-625-9922. The construction of the BMC A well pad will be limited to the hours of 7:00 am and 7:00 pm, except for emergencies and episodic events beyond Ursa's control. Per the SUA, there are no time of day restrictions regarding drilling, completing, re -completing, workover, or reservoir fracture stimulation operations. Drilling will occur continuously 24 hours a day. Well completion activity will be limited to between 7:00 am and 7:00 pm as an added BMP. Once the wells are in production, vehicle trips to the pad will be limited to the hours of 7:00 am to 7:00 pm, except for emergencies and episodic events beyond Ursa's control. April 28, 2017, revised July 14, 2017 10 OLSSON ASSOCIATES