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Battlement Mesa PUD Phase 11— BMC A Injection Well
Ursa Operating Company and Battlement Mesa Land Investments 016-3531
Table of Contents
Section 4-203.B.5 Project Description 1
Facility Operations 1
Hours of Operation 7
Parking Lot and Access Road 7
Alternatives Analysis 7
List of Tables
Table 1. Development Timeline 6
Table 2. Summary of Required Permits 8
List of Figures
Figure 1 — Inside Watson Ranch B pump house 5
Figure 2 — Inside Watson Ranch B pump house 5
Figure 3 — Front of Watson Ranch B pump house 5
Figure 4 — End of Watson Ranch B pump house 5
Figure 5 — DOH certificate — Watson Ranch B pump house 6
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Battlement Mesa PUD Phase II — BMC A Injection Well
Ursa Operating Company and Battlement Mesa Land Investments 016-3531
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May 19, 2017
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Battlement Mesa PUD Phase II — BMC A Injection Well
Ursa Operating Company and Battlement Mesa Land Investments 016-3531
Article 4.203.6.5 — PROJECT DESCRIPTION
SECTION 4-203.B.5 PROJECT DESCRIPTION
Ursa Operating Company, LLC (Ursa) and Battlement Mesa Land Investments LLC (BMLI)
request a Garfield County (GarCo) Special Use Permit (SUP) and approval for construction and
operation of the proposed BMC A Injection Well Facility within the Battlement Mesa PUD (PUD).
Ursa is asking for this SUP as directed in GarCo Resolution 82-121 recorded October 20, 1982
creating the PUD which specifies that extraction and processing natural resources is an allowed
special use. Ursa is requesting this permit under the "Injection Well, Small" land use that is an
allowed use in the PUD Public, Semi -Public, Recreation, and Injection Well (PSRI) zone district.
The water to be handled at this facility is produced from completion and production operations
associated with natural gas wells. Water that is produced from these operations is classified as
an exploration and production (E&P) waste by the Colorado Oil and Gas Conservation
Commission (COGCC). The proposed facility will store and dispose of water only from Ursa's
holdings. Fluids will be delivered to the facility via pipeline from well pads in Ursa's Battlement
Mesa Field.
This application is written using the Garfield County 2013 Land Use and Development Code with
references to the 1979 Zoning Code. The submittals, standards, and public noticing for a Major
Impact Review are being followed for this Special Use Permit. To provide for a thorough disclosure
of the project's potential impacts and mitigations, Ursa has taken into consideration the Garfield
County Colorado Health Impact Assessment (HIA) for Battlement Mesa. A matrix addressing
Ursa's response to the HIA is included with this submittal.
The proposed facility will be located on a well pad approved by the COGCC. In addition to being
permitted pursuant to COGCC Rule 325, the proposed facility will be permitted according to
COGCC Forms 31 and 33 for injection wells as well as COGCC Form 26 for source of produced
water. All of Ursa's surface disturbances (final reclamation requirements) are covered under a
statewide blanket surface bond held by the COGCC. A copy of Ursa's bond is included in the
Reclamation Plan section.
The site for the proposed Ursa BMC A Injection Well is located adjacent to the Battlement Mesa
PUD Water and Sewer Treatment Plant. The proposed well pad is off River Bluff Road (CR 307)
in the NE % 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 6t" P.M. on Garfield County parcel
number 2407-081-00-152. The parcel is approximately 1248.873 acres. Battlement Mesa Land
Investments own the surface. Ursa and Battlement Mesa Land Investments, have a Surface Use
Agreement allowing Ursa to develop the natural gas resources within the PUD. The proposed
injection well will be operated exclusively by Ursa. The surface area of the proposed project is
approximately 2.74 acres.
Facility Operations
The facility will consist of the following equipment: one (1) injection well, one battery of storage
tanks to be dedicated to the disposal facility (6 tanks total) with a total volume of 1,800 Bbls with
a 3 -foot high containment wall area around each tank battery, a valve set, and a maximum 20
May 19, 2017 1
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Battlement Mesa PUD Phase 11— BMC A Injection Well
Ursa Operating Company and Battlement Mesa Land Investments 016-3531
foot by 40 foot building for the electric pumps. The site perimeter will have an earthen berm a
minimum of 18 inches high.
The proximity of Ursa's operations to the proposed injection well necessitates the construction of
this facility, so that water produced during the completion and production of natural gas wells in
the area may be collected and disposed of in a centralized location. Operation and monitoring of
the facility will not require any additional equipment other than what is outlined above. Monitoring
of operations will typically be performed periodically during the daylight hours of 7:00 am to 7:00
pm by an Ursa employee or contractor arriving via pickup truck.
Natural gas well pads typically have a productive life span of approximately 20 to 30 years. When
the amount of gas produced by a well declines to the point that it is no longer economical to
continue operations, the well is plugged and abandoned. The plugging process involves the
installation of permanent, impermeable concrete in the well bore, sufficient to prevent any
movement of water, oil, or gas in accordance with applicable COGCC and CDPHE Rules. The
abandonment process involves the removal of all surface equipment and the backfilling of all
excavation, per applicable COGCC and CDPHE Rules. When all the wells at BMC A have
reached uneconomic levels of production and have been plugged and abandoned, the site will
enter Final Reclamation, following applicable COGCC and CDPHE Rules. All equipment will be
removed, and the pad and associated infrastructure (roads and pipeline rights-of-way) will be
closed, graded, recontoured, and seeded with appropriate seed mix. The Final Reclamation
process is considered complete when vegetative cover over the entire site reaches 80% of pre -
disturbance levels. This determination is made by the COGCC and includes only desirable
vegetation, not weed species.
A dust control program will be implemented for the construction interval and use of the access
road. The proposed facility will not impact groundwater due to engineering design of the injection
well and the depth at which fluid will be injected.
As part of the Garfield County permit approval process, Ursa will secure all appropriate Colorado
Department of Public Health and Environment (CDPHE) air quality (AQ) permits for the storage
tanks. The approved Air Quality permit also will address the impacts and appropriate level of
mitigation for the facility associated with fugitive dust and hydrocarbon venting from the facility.
The key benefits of the proposed project are:
• Minimize impacts to wildlife and vegetation by constructing a facility on previously
disturbed surface
• Reduce road maintenance
• Utilize an engineering controlled transfer system onsite
• Reduce Ursa's overall development and operating cost by negating the requirement for
transport and fluid disposal at distant locations
• Reduce trucking and improve safety by use of the pipeline network
Adjacent property uses include residential, PUD open space, wastewater treatment, RV and
equipment storage, and natural gas exploration. There are residences within 500 feet of the site.
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Battlement Mesa PUD Phase II — BMC A Injection Well
Ursa Operating Company and Battlement Mesa Land Investments 016-3531
The north edge of the well pad and proposed injection well facility is located approximately 56
feet from the southern property boundary of the BMMD wastewater treatment parcel. The rest of
the pad is more than 200 feet from the nearest property boundary.
As part of the GARCO Special Use Permit approval process, proper notification will be provided
to all appropriate landowners and mineral owners. The list of landowners and mineral owners that
will be sent certified letters informing them of the proposed project and decision date are included
as part of the submittal package.
The design for the proposed facility is provided in the facility site diagram and construction
documents. Stormwater management protections, specific best management practices (BMPs)
and other drainage controls have been designed into the facility. The facility will be constructed
according to the criteria identified in the COGCC Rule 325.
The injection well facility will be accessible to Ursa personnel and their contractors 24 hours -a -
day, 365 -days -a -year. Daily inspections will be conducted by local operations personnel.
Operations and maintenance of the proposed facility will be coordinated with the existing
operations in the area. An analysis of the traffic impacts generated by this project is provided in
the Traffic Study section.
The project will be developed in one (1) phase and will include:
• Six storage tanks totaling 1,800 Bbls
• Injection pump and pump house
• Associated piping
It is anticipated that one pump will supply fluids to the proposed injection well. Therefore, Ursa is
requesting approval for one pump and the necessary associated equipment. The injection pump
will be powered by electricity. A copy of the "Will Serve" letter from Holy Cross is included in the
Standards section of the application.
Delivery of fluids to the proposed facility could come from several of Ursa's well pads, including
Yater, Watson Ranch, Monument Ridge, Speakman A, B&V, Monument Ridge B, BMC A, BMC
B, BMC D, BMC L, and Tompkins. Potential future well pads in the Battlement Mesa Field could
send water to the proposed injection facility. Produced water from the aforementioned sites may
be delivered to the existing Speakman A, Tompkins, Watson Ranch B, and the proposed BMC A
injection wells. Water will be delivered to the injection well facilities via pipeline. A full traffic
impacts analysis has been provided as part of this submittal.
If approved by Garfield County, the injection well will be appropriately permitted through the
COGCC Form 31 and Form 33 process. This process reviews the formation into which water is
to be injected and all underground sources of drinking water which may be affected by the
proposed operation. The COGCC requires a water analysis and a fracture pressure or fracture
gradient analysis of the injection formation. If remediation is required for drinking wells within a
quarter of a mile of the injection well, a remediation plan must be filed with the COGCC. The
facility will be operated in accordance with the conditions dictated by the COGCC
permitting/approval process.
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Battlement Mesa PUD Phase II — BMC A Injection Well
Ursa Operating Company and Battlement Mesa Land Investments 016-3531
The construction of the well casing is highly regulated by the COGCC. The regulations require a
resistivity log and full description of the casing of the well.
The minimum and maximum amounts of water to be injected daily are assigned by the COGCC.
Anticipated injection pressures are required to be reported to and approved by the COGCC.
Prior to application approval, the proposed disposal well must satisfactorily pass a mechanical
integrity test. The proposed injection well must continue to pass mechanical integrity testing
throughout the life of the well.
Environmentally sound and safe operation of the proposed injection well is assured with the
implementation of the following emergency controls:
• Bradenhead Pressure Alarm: monitors surface casing pressure
• Wireless Casing Pressure Monitor/Transmitter: monitors casing pressure
• Wireless Tubing Pressure Monitor/Transmitter: monitors tubing pressure
• Remote Shut Down Controls: the injection well is equipped with a stand-alone remote
telemetry (shutdown) unit that would allow the injection well to continue to operate (but
shut down if any alarms or operational issues occur) in the event that the operator loses
contact with the injection well; it is solar powered and has a backup battery power supply.
Each control is designed to notify the operator regarding any issues with the injection well and,
the controls have the capability to remotely shut down the well, without operator assistance. In
addition to the injection well controls listed above, Ursa will have additional controls, which consist
of:
• Pump(s) supporting the injection well are equipped with Programmable Logic Controls,
which monitors the pump package and pressures.
• The pump(s) are equipped with Low Oil Level Alarms and high and low tank alarms. The
equipment also monitors flow rates, including the maximum daily pressure/volume (as set
by the COGCC).
The pump house building will be a skid mounted prefabricated metal building certified by the
Colorado Department of Housing. It will be built specifically for the purpose of housing the electric
pump for the injection well. The building will be delivered as part of the pump package. The photos
below show the typical pump house used by Ursa. This one is located at the Watson Ranch B
injection well facility. A building permit will be obtained prior to putting the building into use.
May 19, 2017 4
OLSSON
ASSOCIATES
Battlement Mesa PUD Phase 11— BMC A Injection Well
Ursa Operating Company and Battlement Mesa Land Investments
016-3531
Figure 1 — Inside Watson Ranch B pump house Figure 2 — Inside Watson Ranch B pump house
Figure 3 — Front of Watson Ranch B pump
house
Figure 4 — End of Watson Ranch B pump
house
May 19, 2017
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Battlement Mesa PUD Phase 11— BMC A Injection Well
Ursa Operating Company and Battlement Mesa Land Investments 016-3531
•
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THIS INSIGNIA IS THE PROPERTY OF THE
STATE OF COLORADO
DIVISION OF HOUSING
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Figure 5 — DOH certificate — Watson Ranch B pump house
DevpinDment Timeline and Emplover N11mhers
The typical timeline for the development and production of the well pad is:
Table 1. Development Timeline
Phase
Duration
No. of Employees
Facility Installation
7 days
6 contractors per day
Drilling
5 days
20 contractors per day
Completions
10 days
35 contractors per day
The well will be drilled as part of the BMC A drilling occupation. Final reclamation will be done as
part of the BMC A reclamation. The facility will be operated for the life of the gas wells in the area.
This is currently estimated to be 20 years or more. At the end of the economic life of wells in the
area, the site will be reclaimed by removing all surface facilities, plugging the natural gas wells
and injection well, grading to restore original contours, replacing topsoil, and revegetating the
reclaimed area as outlined in the reclamation plan included in this submittal.
The anticipated construction schedule will be approximately one month beginning in the fourth
quarter of 2017, with drilling starting the first quarter of 2018. Construction start is dependent upon
weather conditions. Grading and/or construction sequence, including the installation and removal
of erosion and sediment control measures, and the estimated duration of exposure of each area
prior to the completion of temporary erosion and sediment control measures will follow Ursa's
CDPHE approved Stormwater Management Plan and Permit and COGCC Rules for interim and
May 19, 2017
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Battlement Mesa PUD Phase II - BMC A Injection Well
Ursa Operating Company and Battlement Mesa Land Investments 016-3531
final reclamation and the SUA. The cost of the soil erosion control measures is $5,000 to $15,000
for the pad.
Hours of Operation
Preliminary construction of the well pad generally takes place during daylight hours. These hours
are restricted by the SUA to between 7:00 am and 8:00 pm. Drilling will take place 24 hours a day
as allowed in the SUA. Ursa will limit completion activities to between 7:00 am and 7:00 pm as an
added BMP. Once the pad enters the Production phase, it will be an unmanned facility with
periodic visits by Ursa personnel and contractors for routine inspections and maintenance
between the hours of 7:00 am and 7:00 pm.
Parking Lot and Access Road
No formalized parking lot will be developed as part of the BMC A Injection Well. Only authorized
personnel will be on the site during any part of the operation of the well pad. No public access will
be allowed. Employees and contractors will be directed to park in specific areas based on safety
needs during each phase of the pad's operation.
The access road is approximately 785 feet from River Bluff Road to the proposed well pad site.
The road will be graveled to control mud tracking off the site onto public roads. The access is
designed to channel stormwater off the road and around the well pad site, while controlling erosion
and sedimentation.
Alternatives Analysis
Ursa performed an alternatives analysis for this location to make sure that it is the most
appropriate place for this injection well. Existing/future planned pad locations proximate to but
outside of the BM PUD were all considered as possible locations for injection wells. Due to
topography, the Colorado River and planned and existing infrastructure including the additional
injection wells discussed above, the preferred location for the fourth injection well is along the
western side of the BM PUD.
Per the 2009 SUA, an injection well has been planned within the BM PUD boundary from the
BMC G pad. In response to community concern, Ursa eliminated the BMC G pad from the BM
PUD development plan and was successful in constructing adjacent well pads (Yater and Watson
Ranch B) outside of the BM PUD boundary. The injection well within the BM PUD was replanned
at the BMC B pad location. Due to community and CDPHE concerns regarding the proximate
location to the Colorado River, PUD drinking water intake and 317B public water supply internal
buffer, Ursa has worked with the surface owner and Garfield County staff and commissioners to
move the surface location for the planned injection well to the BMC A pad location. The proposed
BMC A location is outside of the 317B public water supply area, outside of the floodplain and is
located nearly 2000 feet from the Colorado River.
Due to adjacent land uses surrounding the proposed BMC A pad, Ursa feels this site is best suited
for their injection needs for their development. The Battlement Mesa Metro District sewer
treatment plant is immediately adjoining to the N/NE along with the Battlement Mesa Company
maintenance shop and an RV storage lot. All other pads that Ursa operates are surrounded by
residential areas other than the Proposed BMC M pad which is located along the Golf Course
May 19, 2017 7
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Battlement Mesa PUD Phase II — BMC A Injection Well
Ursa Operating Company and Battlement Mesa Land Investments 016-3531
area in the middle of Battlement Mesa. To locate this injection well on the BMC M pad would
create a large amount of additional disturbance to build the pad, access road and pipeline
connections through the Battlement Mesa community. Ursa feels it is best to try and utilize an
already planned producing pad to continue their efforts in overall reduction of disturbance in the
area. If Ursa is allowed to place this injection facility at the proposed BMC A pad, they are one
more step closer to eliminating yet another pad from the overall development, which started as
14 well pads, and this plan would help Ursa reduce their planned well pads down to 4.
A full alternatives analysis is included in this submittal.
Table 2. Summary of Required Permits
Permit Required
Responsible
Regulatory Agency
Status
Land Use Change Permit —Special
Use Permit and Major Impact Review
Garfield County
Application submitted May 2017
Stormwater Permit
CDPHE
Permit COR03K66 issued 5/21/2013, and
administratively continued 5/21/2013,
included in this permit.
Air Quality
CDPHE
Air Permit Application will be submitted prior
to commencement of operations of the
injection well.
Form 2 — Application for Permit to Drill
COGCC
Permit Applications submitted May 2017
Form 2A — Location Assessment
COGCC
Permit Application submitted May 2017
Forms 31 and 33 — Injection Well
Permit
COGCC
Permit Application will be submitted prior to
completion of the injection well.
Access/Driveway Permit
Garfield County
Ursa will obtain any required access permits
within 30 days prior to construction
Pipeline Special Use Permit and
Pipeline Development Plan
Garfield County
Applications submitted May 2017
Building Permits
Garfield County
Ursa will obtain when necessary for the
pump house.
May 19, 2017
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