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Home My WebLink About32 NTC ResponsesNTC RESPONSES O\OLSSON ASSOCIATES THIS PAGE LEFT BLANK FOR TWO-SIDED DUPLICATION. O\OLSSON ASSOCIATES OLSSON ASSOCIATES July 14, 2017 Glenn Hartmann Garfield County Community Development 108 8th Street, Suite 401 Glenwood Springs, CO 81601 ghartmann@garfield-county.com Re: MIPA-05-17-8549 BMC A Injection Well Ursa Operating Company Dear Glenn: Thank you for your completeness review of Ursa Operating Company's (Ursa) Phase II Special Use Permit Applications within the Battlement Mesa PUD. This letter serves Ursa's response to your NTC letter dated June 29, 2017. 1. If the access roadway crosses Battlement Mesa Metro District an easement will be required, consistent with Well Pad A. Response: The Road Easement Agreement for the BMC A Well Pad which includes the injection well is included in the original submittal at the end of the Deeds and Easements Section. 2. Application needs to include an explanation on how the mineral rights were researched, and should make reference to use of the Garfield County Clerk and Recorders records. Response: Ursa's Land Department researched mineral rights by using records from the Garfield County Clerk and Recorder's office. 3. Letters from water and sanitation providers need to be dated Response: Copies of dated "Will Serve" letters from the Town of Silt and Western Colorado Waste are included with this submittal. 4. Current easements to the site are temporary and terminable. The Application needs to address permanent legal access to the site. Response: Permanent legal access is granted by Battlement Mesa Land Investments in the original Surface Use Agreement paragraphs 1 and 2 on page 2 along with the Exhibits in the original SUA and the Third Amendment to the SUA which were included 760 Horizon Drive, Suite 102 TEL 970.263.7800 Grand Junction, CO 81506 FAX 970.263.7456 www.olssonassociates.com MIPA-05-17-8549 BMC A Injection Well, NTC Response Page 2 in the original submittal. The language in the Battlement Mesa Metropolitan District is their standard language and provides access to the well pad as long as it is in use. 5. Application needs to confirm that the Surface Use Agreement includes an injection well on Well Pad A or provide an amendment to the agreement that includes an injection well on Well Pad A. Response: A Letter Agreement outlining a Location Agreement for an injection well on the BMC A Well Pad is included in this submittal. The recorded Memorandum of Agreement will be submitted at a later date. 6. Please provide a copy of the COGCC Form 31 and 33 draft Applications or Application forms to assist with the County's review. Response: Copies of the submitted COGCC Forms 31 and 33 are included with this submittal. 7. The Geologic Hazards Report identifies slopes and expansive soils as an issue for the site. The report needs to include site specific engineering recommendations for the proposed injection well pad. The report needs to address cut and fill areas, slope stability, and potential for impacts due to ground water. The report also needs to update sections on proximity to the flood plain. Response: The Geologic Hazards Report has been updated to include site specific information addressing the cut and fill areas, slope stability, expansive soils, and potential for impacts due to ground water. The proximity to the flood plain information has been updated showing that this site is not within the Colorado River floodplain. Site specific engineering recommendations are detailed in the Geotechnical Report and Drainage Report which will be submitted at a later date. 8. The sound study provides noise modelling for the drill rig on Pad A. The report needs to address the long term noise anticipated from the injection well pumps and demonstrate compliance with COGCC and County noise standards. The sound study should also include a receiver site northwest of the proposed well pad or a technical explanation of how the sound contour maps were generated. Response: 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 homes nearby. References in application materials to sound wall installation have been removed. Sound study indicates that unmitigated noise levels will remain below the required thresholds. The nearest residential structure northwest of the BMC A Well Pad is greater than 2,500 feet. Based on the significant sound attenuation expected over this distance, a receiver to the northwest should not be required. See email from Justin Puggioni of Behrens and Associates with this submittal. Additional modeling to include the pump for the injection well is not required as the unit will not impact Ursa's ability to comply with the COGCC noise regulations. The pump will be housed in a pump house as described in the Project Description. MIPA-05-17-8549 BMC A Injection Well, NTC Response Page 3 9. The Traffic Study needs to address any special permits, safety provisions or traffic control needed for hauling equipment to the site. The study needs to more clearly identify the proposed haul route for accessing the site. Response: The Traffic Study has been revised to address special permits, safety provision and traffic control that may be required for hauling equipment and the drilling rig to the site. The proposed haul route is described and shown with a blue line on the maps included in the Study. A copy of the revised Traffic Study is included in this submittal. 10. Relationship of the site to the Parachute Watershed Protection District needs to be provided. Response: Per conversation with the Town of Parachute, the BMC A Well Pad where the injection well is located is outside Parachute's Watershed Protection District boundary. 11. The LUMA comments and responses need to be included in the Application. Response: The LUMA comments and Ursa's responses are included with this submittal. A recorded Statement of Authority for Ursa is included in this submittal. Also included is a Letter of Authorization for Battlement Mesa Land Investments and Battlement Mesa Partners. Sincerely, Tilda Evans Assistant Planner Attachments: 3a — Dated Silt Will Serve Letter 3b — Dated Western Colorado Waste Will Serve Letter 5 — BMC A Pad UIC Location Agreement 6 — COGCC Forms 31 and 33 7 — Revised Geologic Hazards Report 8a — Revised Impact Analysis 8b — Email from Justin Puggioni, Behrens and Associates 9 — Revised Detailed Traffic Study 11 — LUMA Comments Ursa recorded Statement of Authority Eric Schmela Letter of Authority cc: Ursa Operating Company Eric Schmela, Battlement Mesa Company OLSSON ASSOCIATES July 26, 2017 Glenn Hartmann Garfield County Community Development 108 8th Street, Suite 401 Glenwood Springs, CO 81601 ghartmann@garfield-county.com Re: MIPA-05-17-8549 BMC A Injection Well Ursa Operating Company Dear Glenn: Thank you for your completeness review of Ursa Operating Company's (Ursa) Phase II Special Use Permit Applications within the Battlement Mesa PUD. This letter provides the remainder of the requested submittals in response to your NTC letter dated June 29, 2017. 5. Application needs to confirm that the Surface Use Agreement includes an injection well on Well Pad A or provide an amendment to the agreement that includes an injection well on Well Pad A. Response: The recorded Memorandum of Letter Agreement for the injection well is included with this submittal. 7. The Geologic Hazards Report identifies slopes and expansive soils as an issue for the site. The report needs to include site specific engineering recommendations for the proposed injection well pad. The report needs to address cut and fill areas, slope stability, and potential for impacts due to ground water. The report also needs to update sections on proximity to the flood plain. Response: The site specific engineering recommendations requested are included in the Geotechnical Report and letter included in this submittal. 8. The sound study provides noise modelling for the drill rig on Pad A. The report needs to address the long term noise anticipated from the injection well pumps and demonstrate compliance with COGCC and County noise standards. The sound study should also include a receiver site northwest of the proposed well pad or a technical explanation of how the sound contour maps were generated. Response: A letter from Dwayne Knudson, Noise Program Manager for Ursa, regarding the sound levels for the electric injection well pumps and the how the pump house will further mitigate the sound from the pumps is included in this submittal. 760 Horizon Drive, Suite 102 TEL 970.263.7800 Grand Junction, CO 81506 FAX 970.263.7456 www.olssonassociates.com MIPA-05-17-8549 BMC A Injection Well, NTC Response Page 2 Please contact us if you have any further questions or document needs. Sincerely, Tilda Evans Assistant Planner Attachments: 5 — Recorded Memorandum of Agreement 7 — Geotechnical Letter and Report from SGM 8 — BMC A UIC Noise Modeling letter from Ursa cc: Ursa Operating Company Eric Schmela, Battlement Mesa Company