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Battlement Mesa PUC Phase 11— BMC F Temporary Water Storage Facility
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
Land Use and Development Code 2013 3
Section 4-203.G. Impact Analysis 3
Adjacent Land Use 3
Site Features 3
Soil Characteristics 4
Geology and Hazard 4
Groundwater and Aquifer Recharge Areas 5
Environmental Impacts 6
Nuisance 8
April 28, 2017
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Battlement Mesa PUC Phase 11— BMC F Temporary Water Storage Facility
Ursa Operating Company and Battlement Mesa Land Investments 016-3531
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Battlement Mesa PUC Phase 11— BMC F Temporary Water Storage Facility
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 F 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.
The temporary water storage facility is located a quarter of a mile or more from nearby
residences. The location is approximately 150 feet higher than the nearest residence to the
southwest and about 50 feet lower than the nearest residence to the northeast. Visual
screening will be accomplished by creating temporary berms around the perimeter of the site.
One diesel powered pump will be part of the site. Sound mitigation will be utilized to ensure
pumping activities do not exceed COGCC standards. Ursa will comply with COGCC 800
Series Rules and Colorado Revised Statutes for noise levels in Residential/Agricultural/Rural
zones.
Potential impacts from air emissions, vapor and odor are regulated by Colorado Department
of Health and Environment (CDPHE) Air Quality Regulation 7 criteria. 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 well pads in the area. To this end,
Ursa will apply a low emissions flow back process for well completions and will route tank
venting emissions through a Volatile Organic Compound (VOC) combustor. Ursa may place
a combustor on site if deemed necessary to reduce odors.
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 completions techniques. This location
will be inspected daily and have full time personnel on location during pumping operations.
Potential dust impacts will be mitigated as directed in Ursa's Fugitive Dust Plan found in that
section using water or other dust suppressants, as appropriate. During construction,
truckloads of dirt, sand, aggregate materials, and similar materials will be covered to reduce
dust and particulate matter emissions during transport.
Lighting impacts during operations of the facility 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
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Battlement Mesa PUC Phase 11— BMC F Temporary Water Storage Facility
Ursa Operating Company and Battlement Mesa Land Investments 016-3531
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. Safety considerations will take
precedence.
The tanks will not be painted to blend in with the surrounding landscape, because the tanks
are temporary and will be removed within three years.
(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. During the operation and maintenance period, the impacts
would be minimal. Since the site exists within and next 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.
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. The site is located approximately
two miles from the Colorado River.
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 have been or will be installed to move produced water for reuse on other well
pads in the area. The pipelines eliminate the need to truck water, except for upset conditions,
thus keeping the traffic volume increases to a minimum after completions operations are
concluded on the well pad.
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Battlement Mesa PUC Phase 11— BMC F Temporary Water Storage Facility
Ursa Operating Company and Battlement Mesa Land Investments
016-3531
Section 5.03.07(3) Distance Buffers
The proposed facility is in the LDR zone district. The nearest residence is approximately a quarter
of a mile northeast and southwest of the facility.
Section 5.03.07(5) Rehabilitation
(a) Ursa will follow COGCC Rules for Interim and Final Reclamation of the proposed site. 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 facility 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 the
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 agricultural uses, natural gas
production; and vacant PUD property. The proposed use is consistent with the predominant
existing uses in the surrounding area. Visual, vegetative, and topographical buffering will be
implemented to separate the proposed facility from the less compatible nearby uses, including
the residences. These uses will not be impacted by construction and operation of the BMC F
facility beyond normal industrial uses of the parcel.
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. This site does not fall under the LUMA
rules, but is being included as part of the larger Phase II development. COGCC has a series of
notifications that go out to owners and local governments including pre -application notifications.
Certifications of the 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.
Site Features
The site is on private land located within the Battlement Mesa PUD. The proposed facility is off
Gardner Lane (CR 303) in the SW 1/4 of Section 16, 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 Gardner Lane
east of intersection of Four Corners Road (CR 308) and Gardner Lane. The project site
encompasses approximately 2.5 acres at an elevation of about 5,800 feet. Geologic hazards
potentially affecting the BMC F well pad include slope area and corrosive 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 pasture grass intermixed with sage brush and juniper trees.
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Battlement Mesa PUC Phase 11— BMC F Temporary Water Storage Facility
Ursa Operating Company and Battlement Mesa Land Investments 016-3531
The proposed facility is on vacant land in an unplatted part of Battlement Mesa PUD located in
the southeastern portion of PUD. BMC F is below the bluff that both subdivisions sit on. The site
is sloping from east to west. The project site, in its pre -developed condition, is located in a
semiarid plateau region between 5,000 ft and 6,000 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 F well pad:
• Ildefonso stony loam, 6% to 25% slopes, Map Symbol 33: 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.
• Potts Loam, 6% to 12 % slopes, Map Symbol 56: The Potts loam is a deep, well drained,
moderately sloping to rolling soil formed on mesas, benches, and the sides of valleys at
elevations between 5,000 feet and 7,000 feet above mean sea level. The Potts loam soil
formed in alluvium derived from sandstone, shale, or basalt. Typically, the surface layer is a
brown loam about four inches thick, the subsoil is a reddish -brown clay about 24 inches thick,
and the substratum is a pinkish white loam to a depth of 60 inches. Permeability is moderate,
and available water capacity is high. Surface runoff is medium, and the erosion hazard is
severe.
• Potts Ildefonso complex, 12% to 25% slopes, Map Symbol 58: Strongly sloping to hilly soils
on mesas, alluvial fans, and the sides of valleys at elevations ranging from 5,000 feet to 6,500
feet amsl. As stated above, the Potts loam was formed in alluvium derived from sandstone,
shale, or basalt; while the Ildefonso soil formed in very strongly calcareous, basaltic alluvium
with small amounts of eolian material. Permeability of the Potts loam is moderate, and the
available water capacity is high. Surface runoff is medium, and the erosion hazard is
moderate. Permeability of the Ildefonso soil is moderately rapid and the available water
capacity is low. Surface runoff is medium for the Ildefonso soils, and the erosion hazard is
moderate.
The Ildefonso soils and the Potts loam soils 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
F 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
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Battlement Mesa PUC Phase 11— BMC F Temporary Water Storage Facility
Ursa Operating Company and Battlement Mesa Land Investments 016-3531
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 on a terrace above the Colorado River flood plain. The Colorado River is located
approximately two miles to the west. The site is on a ridge between two significant drainages
which flow to the west toward Battlement Mesa and the Colorado River.
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.
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Battlement Mesa PUC Phase 11— BMC F Temporary Water Storage Facility
Ursa Operating Company and Battlement Mesa Land Investments 016-3531
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.
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.
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Battlement Mesa PUC Phase 11— BMC F Temporary Water Storage Facility
Ursa Operating Company and Battlement Mesa Land Investments 016-3531
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.
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
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Battlement Mesa PUC Phase 11— BMC F Temporary Water Storage Facility
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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
site will not be developed with structures containing basements or substructures in which radon
can accumulate.
Nuisance
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.
To mitigate potential noise and visual impacts to residents, Ursa will install a berm around the
perimeter of the site. A preliminary noise analysis report is included in Sound Study section of this
application. The preliminary noise analysis anticipates Ursa's BMC F temporary water storage
facility will be in compliance with the relevant sound regulations. After the facility has been placed
into the operation, Ursa will follow COGCC and Colorado Revised Statutes for noise levels in
Residential/Agricultural/Rural zones.
Potential impacts from air emissions, vapor and odor are regulated by Colorado Department of
Health and Environment (CDPHE) Air Quality Regulation 7 criteria. Ursa will comply with COGCC
green completions practices and the EPA's natural gas STAR program to reduce VOC emissions
to the lowest level technically possible for the well pads in the area. To this end, Ursa will apply a
low emissions flow back process for well completions and will route tank venting emissions
through a Volatile Organic Compound (VOC) combustor. Ursa may place a combustor on site if
deemed necessary to reduce odors.
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 completions techniques. This location will be inspected daily and
have full time personnel on location during pumping operations.
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Battlement Mesa PUC Phase 11— BMC F Temporary Water Storage Facility
Ursa Operating Company and Battlement Mesa Land Investments 016-3531
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, and similar materials will be covered to reduce dust and particulate matter emissions
during transport.
Lighting impacts during operations of the facility 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. Safety considerations will take precedence.
The tanks will not be painted to blend in with the surrounding landscape, because the tanks are
temporary and will be removed within three years.
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.
Preliminary construction of the facility generally takes place during daylight hours. These hours
are restricted by the SUA to between 7:00 am and 8:00 pm. Personnel will be present at this
facility and operations will be conducted 24 hours per day, 7 days per week in order to allow Ursa
to move produced/recycled water as needed to reduce truck traffic and maximize water recycling.
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Battlement Mesa PUC Phase 11— BMC F Temporary Water Storage Facility
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