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HEALTH IMPACT ANALYSIS ASSESSMENT
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URSA RESPONSES TO BATTLEMENT MESA HEALTH IMPACT ASSESSMENT (HIA) "Colorado School of Public Health" (Feb 2011)
Meetings Content: 6/15/15 - Geology 7/13/15 - Regulatory/Permitting/Ops Overview 8/3/15 - Construction Phase 8/17/15 - Drilling/Completions Phase
9/2/15 - Production Phase
NOTE: All references to Antero changed to Ursa.
3.1 Findings and Specific Recommendations from Air Quality Assessment
HIA
Reference
Number
Assessment & Recommendations
GARCO Application
Reference Page Number
Agency
Comments
Presentation/Community
Mtg Date
6/15/1517/13/15
8/3/1518/17/15
9/2/15
Prior to approval of Special Use Permit (SUP), Colorado School of Public Health (CSPH) recommends BOCC require Ursa to:
1
An effective demonstration would show that levels of air pollutants, such as benzene, as measured in 24-hour
ambient air samples at 350, 500, 1000, 2000 and 3000 feet and in each cardinal direction, from the well pad
perimeter, are not higher than those measured at the Battlement Mesa monitoring station.
N/A
CDPHE
Garfield County and Ursa have been participating in the CSU ambient air quality
study. Air quality has been shown as improving in Garfield County. In addition,
new CDPHE Regulation 7 now requires both Storage Tank Emission Monitoring
(STEM) and Leak Detection and Repair (LDAR) plans. Ursa implemented both of
these plans months in advance of the effective date of January 2015.
Inspections are conducted routinely at each well pad.
V
V
2
Disclose all chemicals that will be used on its well pads within the PUD. We recommend GARCO to keep a list of these
chemicals on its website and/or on a publicly accessible website approved by the Battlement Mesa Community.
•Standards Analysis (SA) Pg 5,
7, 10
•Emergency Response Plan
(ERP)
COGCC
All chemicals are disclosed within 90 days of fracking operations, which consist
of 99.5% sand/water/proppant mix. Ursa discloses chemicals used per COGCC
regulations on the FacFocus website, also via annual EPA Tilte 3 reporting. In the
event of a health issue, the COGCC regulations require immediate disclosure to
the appropriate medical professionals.
V
V
3
Establish a system for immediate response to odor complaints that includes options for ceasing operations,
notification of affected residents and temporary relocation of residents until the source of the odor is identified and
resolved. We encourage Ursa to communicate the timing of well completion activities to Battlement Mesa residents,
which could allow for voluntary shutting of windows and air intakes or temporary relocation.
•Impact Analysis (IA) Pg 6-7
.SPCC •SA Pg 13
NA
Ursa has systems in place to respond to any type of complaint including odors,
noise, lighting, etc. The community is updated on the status of activities via
several channels including community meetings, Community Counts, Energy
Advisory Board (EAB), etc.
4
Submit a quality assurance project plan (QAPP) to GCPH and GCOC for review and approval for all monitoring
specified in these recommendations to assure monitoring information will be adequate for informing public health
decisions prior to any activities in the PUD.
N/A
All
Ursa has several plans and systems in place that address monitoring of all issues
included in the HIA.
V
V
As a condition of the SUP, CSPH recommends that the BOCC require Ursa to:
5
Complete the installation of a fully functional water storage facility and water pipeline network prior to any drilling
within the PUD to realize the full air pollution prevention benefit.
•Project Description (PD) Pg 1,
3
•Pipeline SUP
COGCC/
GARCO
There are currently no plans for a centralized water storage facility. However,
Ursa has installed several water lines around the PUD, to date, that are
associated with injection wells. Additional water lines will be added to reduce
traffic, odors, noise and air emissions.
6
Use permitted tanks rather than a pond at the centralized water storage facility. See recommendations for Water and
Soil Assessment for further details of water storage facility recommendations.
N/A
COGCC,
CDPHE,
GARCO
No centralized water storage facility is planned. All on pad tanks require
permitting through the COGCC, CDPHE (air emissions), and depending on
volume, Garfield County.
V
7
Use an effective and validated low emissions flow back process for all well completions within the PUD.
•PD Pg 7
•IA Pg 7
COGCC
Ursa has this in place as a standard operating practice.
V
V
8
Route production tank venting emissions through a VOC combustor operated with auto -igniters on all well pads
within the PUD.
•IA Pg 7
•SA Pg 13
CDPHE
Ursa has this in place as a standard operating practice.
V
9
Use vapor recovery technology when available, rather than combustion, to further reduce air pollution.
•IA Pg 6-7
CDPHE
Emissions reductions are managed in accordance with the Air Permit.
V
V
10
Obtain an emissions permit from CDPHE for each well pad production tank within the PUD, per COGCC rules. The
COGCC rules require permitting for production tanks within 1/4 mile of an occupied structure with the capacity for 5
tons per year of VOC emissions, which is the case for most of Ursa's proposed well pads. Our recommendation may
be beyond the COGCC rule at one or two well pads. This recommendation is necessary, however, for the protection of
public health because odors have been noticed up to 'A mile from the Watson Ranch pad. The % mile distance in the
rule is not based on a health -based air pollution standard, and the permit provides a mechanism for the
establishment of inspection and monitoring requirements.
•PD Pg 5
•IA Pg 6-7
•SA Pg 10, 13, 17
CDPHE
Ursa has this in place as a standard operating practice.
V
V
11
Work with GCPH to implement an air monitoring program for all well completion activities within the PUD and at the
centralized water storage facility. At a minimum, this program should include collection of 24 -ambient air samples and
grab samples, real-time VOC monitoring, odor monitoring, and collection of grab samples when odors are noticed.
•IA Pg 7
•SA Pg 13
CDPHE
See response to HIA #3.1.1 above.
V
V
3.1 Findings and Specific Recommendations from Air Quality Assessment
HIA
Reference
Number
Assessment & Recommendations
GARCO Application
Reference Page Number
Agency
Comments
Presentation/Community Mtg Date
6/15/15
7/13/15
8/3/15
8/17/15
9/2/15
12
Annually disclose all chemicals and volumes used on its well pads within the PUD and include any chemicals that are
VOCs in the air monitoring program. We recommend Garfield County to keep a list of these chemicals on its website
and/or a publicly accessible website approved by the Battlement Mesa Community.
•SA Pg 5, 7, 10
•ERP
COGCC
See response to HIA #3.1.2 above.
V
V
13
Implement the system for immediate response to odor complaints that includes options for ceasing operations.
Implement a system for notification of affected residents, and temporary relocation of residents until the source of
the odor is identified and resolved. We encourage Ursa to communicate the timing of well completion activities to
Battlement Mesa residents, which could allow for voluntary shutting of windows and air intakes or temporary
relocation.
•SAP 13
g
GOARCO
See response to HIA #3.1.3 above.
V
V
V
V
14
Make all air monitoring results within the PUD publically available for posting on the Garfield County website and/or a
publicly accessible website approved by the Battlement Mesa Community, no later than 60 -days following the
collection of samples.
N/A
CDPHE/
GARCO
See response to HIA 3.1.1. All air emission monitoring and records are required
by the CDPHE. Air emissions monitoring results are available on the Garfield
County Public Heath website, also.
V
V
15
Comply with COGCC green completion practices and EPA's natural gas STAR program to reduce VOC emissions to the
lowest level technically possible at all well pads within the PUD.
•IA Pg 6-7
•SA Pg 13
COGCC/
GARCO
Ursa complies with the requirements of the regulations regarding green
completions
v
16
Specify where in the PUD Ursa will use electric grid power for drilling and/or other operations.
•SA Pg 3
NA
Electrical power will be used on the BMC B pad only for electric pumps if an
injection well is developed on the pad. No electrical power is required for the
BMC D pad. Once the pad has entered the production phase, all electric needs
will be provided by solar power.
V
V
17
Adhere to dust control measures and traffic measures specified in the Special Use Agreement.
•PD Pg 2
•Reclamation Plan (RP) Pg 4
•IA Pg 6-7
•Fugitive Dust Control Plan
(FDCP)
•Water Supply Plan (WSP) Pg 1
•SA Pg 1, 5, 13, 17
•Traffic Study (TS) 4-203.L
COGCC/C
DPHE/G
ARCO
Dust and traffic control measures are incorporated into Ursa's standard
environmental and health and safety practices, which meet or exceed the
measures in the Surface Use Agreement and PUD Resolution.
V
V
V
V
18
Establish and implement a plan that ensures all trucks used for its plan within the PUD meet emission standards
specified in the Clean Fuel Vehicles (heavy trucks) for the Clean Fuel Fleet Program (CFR Part 88.105-94) to reduce
VOC, PAH, and PM emissions. This will reduce air pollution in the PUD.
N/A
NA
All vehicles used by Ursa and its contractors comply with vehicle emissions
standards. In addition, emissions associated with truck traffic will be further
reduced through the use of water lines and injection wells.
V
V
19
Prevent the idling of trucks on well pads and along roads in the PUD for longer than 10 minutes.
N/A
NA
Ursa will encourage contractors to turn engines off when not in use, or when
appropriate, depending upon the scope of work being performed.
V
V
20
Ensure truckloads of dirt, sand, aggregate materials, drilling cuttings, and similar materials are covered to reduce dust
and PM emissions.
N/A
COGCC/
GARCO
Trucks that are not covered and create dust, etc. should be reported to Ursa.
V
CSPH recommend that the BOCC:
21
Assign a county inspector to monitor Ursa's compliance with the special use permit and that the special use permit
contain provisions for regulatory action if Ursa is found to be in non-compliance.
N/A
COGCC/C
DPHE
COGCC and CDPHE have significantly increased their inspection staff. In
addition, Ursa conducted over 2000 inspections per year, averaging an
inspection at each location at a minimum of every two weeks.
V
V
V
22
Assign an independent observer acting on their behalf, to participate in the demonstration of the low emission flow
back tank described in recommendation 1. The independent observer would be responsible for confirming sample
locations and timing as well as monitoring for odors. The independent observer would collect grab samples if odors
are noticed during the demonstration for evaluation of possible short-term peak exposures.
N/A
COGCC
There are sufficient and robust COGCC and CDPHE air regulations in place that
accomplish this objective. Ursa has odor management SOPS in place including an
immediate response and tracking of the complaint.
Finally, CSPH strongly encourage Ursa to:
23
Assign an independent observer acting on their behalf, to participate in the demonstration of the low emission flow
back tank described in recommendation 1. The independent observer would be responsible for confirming sample
locations and timing as well as monitoring for odors. The independent observer would collect grab samples if odors
are noticed during the demonstration for evaluation of possible short-term peak exposures.
N/A
COGCC
See response to HIA 3.1.22. Note that odors don't necessarily constitute
exposure or air emissions health risks.
URSA RESPONSES TO BATTLEMENT MESA HEALTH IMPACT ASSESSMENT (HIA) "Colorado School of Public Health" (Feb 2011)
Meetings Content: 6/15/15 - Geology 7/13/15 - Regulatory/Permitting/Ops Overview 8/3/15 - Construction Phase 8/17/15 - Drilling/Completions Phase
9/2/15 - Production Phase
NOTE: All references to Antero changed to Ursa.
3.2 Findings and Specific Recommendations from Water and Soil Quality Assessment
HIA
Reference
Number
Assessment & Recommendations
GARCO Application
Reference Page Number
Agency
Comments
Presentation/Community
Mtg Date
6/15/1517/13/15
8/3/1518/17/15
9/2/15
As a condition of the SUP, CSPH recommend that the BOCC require Ursa to:
1
Disclose all chemicals that will be used on its well pads within the PUD.
•SA Pg 5, 7, 10
•ERP
COGCC
See Response to HIA #3.1.2.
V
V
2
Characterize the geology and hydrogeology within the Battlement Mesa PUD and the primary and secondary
domestic water supplies, accordingto the specifications in COGCC rule 908.
pp p
•IA Pg 2, 3
•Natural and Geologic Hazards
Assessment Rpt (NGHAR)
•SA Pg 4, 10
•Figures Site Assessment Map
COGCC
COGCC Rule 908 doesn't apply to well pads, but rather centralized E&P waste
management facilities, which are currently not planned within the PUD.
However, Ursa does characterize geologyand hydrogeology as art of UIC
p
permitting in accordance with COGCC regulations.
3
Submit a quality assurance project plan (also known as a QAPP) to GCPH and GCOG for review and approval for all
sampling and monitoring specified in these recommendations to assure monitoring information will be adequate for
informing public health decisions.
N/A
COGCC
See Response to HIA #3.2.2 above.
V
V
4
Complete the installation of a fully functional water management facility and water pipeline network prior to any
drilling within the PUD to decrease potential of contamination of soil and surface water on individual well pads and
decrease potential for truck accidents to contaminate surface waters and soils in case of an accident.
•PD Pg 1,3
•Pipeline SUP
Installation of a water management system including buried water lines co -
located with gas lines was implemented in 2013. Several have already been
installed to support locations outside the PUD.
V
V
Before approval of the SUP, CSPH recommend that the BOCC require Ursa to:
5
Comply with COGCC rule 908, which pertains to non-commercial centralized E&P waste management facilities, for the
centralized water storage facility, which will be handling E&P waste (i.e., recycling water used in well completions).
One of the best management practices Ursa has proposed for its Battlement Mesa project is a centralized water
storage pond, which will allow for pit -less drilling on the pads, the recycling of water used in well completions, and
reduced potential for water and soil contamination at the well sites. We have recommended that this facility be
installed prior to any drilling. COGCC rule 908 requires permitting, a hydrogeological characterization, groundwater,
soil, and surface water testing for centralized E&P waste management facilities.
N/A
No central E&P facility is proposed
V
V
6
Use permitted tanks, rather than a storage pond for water storage at the centralized water storage facility. While
tanks are not required by COGCC, the use of tanks reduces the potential for water and pollution that could occur if a
pond/pit liner was compromised or if a pond/pit overflowed. Tanks also have the added advantage of reducing air
pollution and reducing inadvertent wildlife and pet exposures.
N/A
No central E&P facility is proposed, and production tanks located at the well
pads will be used, in combination with water lines to move water; hence
significantly minimize truck traffic during the production phase (following drilling
and completions).
7
Locate the centralized water storage facility be located at least a mile from any residential structure or school as a
condition of approval of the special use permit. This is because the water storage facility will be handling E&P waste
(i.e. recycled water from well completions).
N/A
No central E&P facility is proposed
V
V
8
Annually disclose all chemicals and volumes used on its well pads within the PUD and include any chemicals that are
VOCs in the water monitoring program as a condition of the special use permit. We recommend Garfield County to
keep a list of these chemicals on its website.
•SA Pg 5, 7, 10
•ERP
See Response to HIA #3.1.2 above
V
V
9
Install at least one up -gradient and two down -gradient groundwater monitoring wells at each well pad as well as at
the centralized water storage facility, in addition to the voluntary water well testing program specified in Ursa's best
management practices. Ursa should also conduct baseline sampling for, at a minimum, the following: all major cations
and anions, total dissolved solids, iron, manganese, nitrates, nitrites, selenium, benzene, toluene, ethylbenzene,
xylenes, methane, pH, specific conductance, and any chemical identified in the full disclosure of chemicals of potential
concern. This monitoring will ensure that drilling, hydraulic fracturing and other operations do not compromise
ground water.
•SA Pg 5, 7, 10
•ERP
•Monitoring wells N/A
COGCC/C
DPHE
COGCC allows the use of existing water wells to sample within 1/2 mile of the
locations. URSA has a monitoring well program plan that includes water well
sampling in place, which includes COGCC and CDPHE regulations and COAs.
V
V
3,2 Findings and Specific Recommendations from Water and Soil Quality Assessment
HIA
Reference
Number
Assessment & Recommendations
GARCO Application
Reference Page Number
Agency
Comments
Presentation/Community Mtg Date
6/15/15
7/13/15
8/3/15
8/17/15
9/2/15
10
Conduct monthly monitoring of the well site groundwater wells for the parameters specified in the proceeding
recommendation during well drilling and completion activities, followed by annual monitoring for the duration of
Ursa's project. All results of this monitoring should be made available to the public within 60 days of sample collection
and posted on Garfield County's website. If (1) benzene, ethylbenzene, toluene, or xylenes are detected at levels
greater than the concentration levels specified in Table 910-1 of the COGCC rules; (2) any cations, anions, metals, or
total dissolved solids exceed 1.25 times background concentrations; (3) methane or any chemical identified as a
concern from the full disclosure of chemicals exceeds 1.25 background concentrations; or (4) if pH or specific
conductance exceeds the limits specified in COGCC table 910-1, the BOCC should require Ursa to remediate as a
condition of the special use permit. This type of monitoring is the best way to ensure pollution control measures are
effective in protecting the groundwater resource.
•PD Pg 1, 4, 5
COGCC
COGCC allows public information, including water well sampling results to be
posted and distributed to the public via their website. This information is also
provided to the affected landowners in accordance with COGCC regulations.
Ursa has a water quality program, which includes tracking analytical results
received from certified laboratories.
V
V
V
11
Conduct baseline soil and surface water testing at all well pad locations and at the location of the centralized water
facility for the parameters specified in COGCC Table 910-1, in addition to the wetland/drainage survey and mapping
specified in Ursa's best management practices.
•PD Pg 1, 4, 5
COGCC
Baseline water sampling is conducted at all well pads prior to drilling events. See
response the HIA #3.2.10 above. No centralized facility is planned.
V
V
V
12
Perform monthly monitoring of any surface water bodies that are located within 'A mile of a well pad or the
centralized water storage facility using the same parameters specified for the groundwater monitoring during well
drilling and completion activities, followed by annual monitoring for the duration of the project. This type of
monitoring is the best way to ensure pollution control measures are preventing exposures through contamination of
surface water.
•PD Pg 1, 4, 5
COGCC
See response to HIA #3.9 - 11 above. In addition COGCC regulations combined
with Ursa's BMPs, require cement and bond logs, mechanical integrity testing,
etc.
V
V
V
13
Conduct soil testing at all well pad locations and at the centralized water facility during reclamation activities. All
results of this monitoring should be made available to the public within 60 days of sample collection and posted on a
publicly accessible website approved by the Battlement Mesa Community website. If (1) benzene, ethylbenzene,
toluene, or xylenes are detected at levels greater than the concentration levels specified in Table 910-1 of the COGCC
rules; (2) any cations, anions, metals, or total dissolved solids exceed 1.25 times background concentrations; (3)
methane or any chemical identified as a concern from the full disclosure of chemicals exceeds 1.25 background
concentrations; or (4) if pH or specific conductance exceeds the limits specified in COGCC table 910-1, the BOCC
should require Ursa to remediate as a condition of the special use permit. This type of monitoring is the best way to
ensure pollution control measures are preventing exposures through contamination of soil.
•PD Pg 1, 4, 5
•RP Pg 5
•SA Pg 8, 12-13
COGCC
No central E&P facility is proposed
Soil testing is required by COGCC as part of the fianl reclamation procedures.
Test results are requuired to be sent to the COGCC within 60 days of receiving
test results and are publically available on the COGCC website.
Soil testing is required by COGCC as part of remediation procedures for any
reportable spills with the results sent to the COGCC which are publically
available.
V
14
Adhere to COGCC rules 317B, 603, 904, and 908, including provisions in these rules that are at the discretion of the
director, and identify any variances or exceptions to these rules and make any variances or exceptions publically
available (as posted on Garfield County website and/or a publicly accessible website approved by the Battlement
Mesa Community) 2 months prior to submission of the special use permit.
•PD Pg 1, 2, 4,5
•IA Pg 1
•Stormwater Mgmt Plan
(SWMP) Pg 3
•RP Pg 1-2, 4-5, 7
•SPCC Pg 6, 7, 8, 76, 77, 78,
Appendix B, C
•SA Pg 6, 8, 9, 12, 13, 14, 16,
17
COGCC
Ursa has plans, sampling, tracking and monitoring programs in place that meet
and go beyond what is being addressed as a concern for 317B, 609 and 904
regulations. 908 regulations don't apply as a central E&P facility isn't proposed.
V
V
V
V
15
Develop and implement plans to ensure removal of mud from vehicles leaving the well pads and access roads to
prevent tracking of mud onto Battlement Mesa and Garfield County roads.
•SWMP Pg D21
•SA Pg 9
•Noxious Weed Mgmt Plan
(NWMP) Appendix G
CDPHE
Prevention of mud and sediment from leaving the well pad sites is part of Ursa's
stomwater BMPs as required by CDPHE.
v
v
v
16
Adhere to all its best management practices in Appendix E for spill prevention, control, and storm water control, and
groundwater and surface water resources.
•SWMP Pg 4
•SPCC
•IA Pg 5
•SA Pg 6, 7, 8, 10
COGCC/C
DPHE/
EPA
Ursa has implemented numerous Environmental Program Plans to include SPCC,
spill, and stormwater management. Plans are made available to the COGCC,
CDPHE and other agencies upon request or as a result of agency inspections.
17
Create a berm for all down gradient well pad perimeters and surface water diversion ditches to prevent pollution of
water and soil.
•Site Plan Sheet B5
•Drainage Report
•SWMP
•SPCC
•FDCP
•SA Pg 7, 8,9
COGCC/C
DPHE/
GARCO
Berming is a standard BMP included in site and stormwater management plans
required by the COGCC, CDPHE and GARCO.
v
3.2 Findings and Specific Recommendations from Water and Soil Quality Assessment
HIA
Reference
Number
Assessment & Recommendations
GARCO Application
Reference Page Number
Agency
Comments
Presentation/Community Mtg Date
6/15/15
7/13/15
8/3/15
8/17/15
9/2/15
18
Conduct monthly inspection of water and gas pipeline for leaks to prevent water and soil pollution and that the
results of the inspections be posted on the Garfield County Website.
•SWMP
•SPCC
Inspections are conducted by Ursa contract inspectors and agencies on a routine
basis; at least bi-monthly, in addition to the Operations Site and Water Manager
supervisors conducting daily and weekly inspections.
V
V
19
Immediately Report to GCOG (in addition to COGCC) any spill of one or more barrels. Notification should take place
within 24 hours and keep records of spill quantities, clean-up activities and preventive measures taken to avoid future
spills. Notification should be immediate if water sources are impacted.
•SWMP
•SPCC
•ERP Pg 6, 13, 22, 34
COGCC
COGCC spill regulations were revised to include the reporting of 1 bbl or more
outside containment. Ursa's spill management plan addresses notification,
response and remedial actions in detail.
V
V
20
Cover all drill cuttings when stored on well pads to prevent wind transport and soil pollution.
•PD Pg 1, 2, 4, 5
•IA Pg 1, 6
•SA Pg 7, 8, 9 12, 13, 14,17
COGCC/C
DPHE
Drill cuttings are managed in accordance with Ursa's Waste Management Plan,
and are sampled, stored, transported and disposed of in accordance with
COGCC, CDPHE, and county landfill requirements. Surface cuttings typically do
not exceed COGCC thresholds for standards for land disposal. Downhole
(production hole) cuttings have occasionally slightly exceeded land application
standards, requiring disposal at State approved facility/landfill.
V
V
V
V
CSPH recommend that the BOCC:
21
Assign a Garfield County inspector to monitor Ursa's compliance with the special use permit and that the special use
permit contain provisions for regulatory action if Ursa is found to be in non-compliance of the special use permit.
N/A
See response to HIA #3.1.21-23 above.
URSA RESPONSES TO BATTLEMENT MESA HEALTH IMPACT ASSESSMENT (HIA) "Colorado School of Public Health" (Feb 2011)
Meetings Content: 6/15/15 - Geology 7/13/15 - Regulatory/Permitting/Ops Overview 8/3/15 - Construction Phase 8/17/15 - Drilling/Completions Phase
9/2/15 - Production Phase
NOTE: All references to Antero changed to Ursa.
3.3 Findings and Recommendations from Traffic and Transportation Assessment
HIA
Reference
Number
Assessment & Recommendations
GARCO Application
Reference Page Number
Agency
Comments
Presentation/Community
Mtg Date
6/15/1517/13/15
8/3/1518/17/15
9/2/15
As a condition of the SUP, CSPH recommend that the BOCC require Ursa to:
1
Install a fully functional water storage facility and pipeline network before any development of well pads in the
Battlement Mesa.
•PD Pg 1, 3
•Pipeline SUP
See response to HIA #3.2.4 above.
V
V
V
2
Develop industrial haul routes outside the PUD to remove natural gas development and production -associated traffic
from residential roads prior to any well pad construction within the PUD. Industrial traffic should be diverted from
Stone Quarry Road to industrial haul routes at locations were homes are backed along the road.
•Traffic Study
•SA Pg 4, 15
Haul routes are determined by Ursa's Health and Safety Manager in consultation
with the county to minimize traffic and ensure safety to the community. A Site
Safety and Emergency Response Plan (SSERP) is developed for each location. In
addition, Ursa receives community input to work around special occasions,
school hours and community events. Community Counts, the EAB and other
organizations are also consulted and updated regarding heavy hauls, rig moves,
etc. Safety to workers and the community is a key aspect of Ursa's Operations.
In addition, designated haul routes can only be changed by the BOCC and/or on
a case by case basis per GARCO Road & Bridge. We only utilize the Garfield
County approved haul routes during of our operations.
V
V
V
If industrial haul routes outside the PUD are not constructed then CSPH recommend the following conditions be met:
3
Communicate and coordinate with the local school district to develop a plan for transportation and safety needs of all
children going to and from school by car, bus, bicycle and walking during and outside of school zone hours to prevent
injury to school children.
•ERP
See Response to HIA #3.3.2. Comply with and rely on implemented GARCO
engineered safety measures and designated haul routes. In addition, notification
is initially sent to Community Counts, GARCO R&B, GARCO Liaison and
distributed by Community Counts to inform residents and the community
affected by upcoming operations. Ursa Safety Manager and District 16 School
System work together to ensure OS/OW vehicles are off of designated haul
routes during school bus operations.
V
V
V
o
Enforce truck speed limits to 20 mph within the PUD for all areas for all truck traffic associated with the project to
reduce the severity of injury should an accident occur.
N/A
While Ursa can't enforce speed limits, it encourages all employees, consultants
and contractors to drive and observe traffic safety laws in daily briefings, bi-
monthly contractor meetings, and in pre -operations meetings. Any suspected
violations or concerns should be directed to Ursa immediately. Many of Ursa's
team and consultants live in the Battlement Mesa community. We are concern
for everyone's safety.
v
v
5
Mark pedestrian/bike high use routes and establish safe crossing zones where they intersect Battlement Mesa
Parkway or other haul routes to alert drivers of potential pedestrians and bicyclers.
N/A
Ursa will lean on the use of the approved and implemented pedestrian walks,
bike paths, etc. that were engineered, approved and installed by BOCC and
GARCO R&B.
V
V
V
6
Install safety measures (i.e., signaled cross walks, elevated sidewalks, green space buffers) for pedestrians/bikes
where established walking/biking routes overlap/run along haul routes to prevent accidents.
N/A
Ursa will lean on the use of the approved and implemented pedestrian walks,
bike paths, etc. that were engineered, approved and installed by BOCC and
GARCO R&B.
7
Require safe driver training for workers and subcontractors and Ursa implement penalty system for unsafe workers,
to encourage safe driving.
N/A
All Ursa employees and contractors operating a passenger and/or commercial
vehicle have in their possession their primary state of residence State issued
driving credentials. In the event of a verified unsafe driving practice, a
review/disciplinary process is conducted.
v
v
8
Implement a system to identify and remove unsafe drivers to prevent accidents and injuries.
N/A
Ursa has a zero tolerance for verified unsafe drivers/driving practices. Processes
include reporting, investigation and potential disciplinary actions. May include
removal of service provider and/or employee.
V
V
V
CSPH recommend that Garfield County:
9
Provide Sheriff's Auxiliary Unit with authority to log speeding and unsafe driving incidents and complaints within the
PUD. Information about incidents involving the Ursa workers or subcontractors can be provided to Ursa,
subcontractors and the Sheriff's department so that problems and unsafe conditions can be resolved.
N/A
We will utilize GARCO Sheriffs Department and/or other certified law
enforcement agencies to mitigate and manage unsafe driving practices. We
value and support their ability to legally utilize their discretion, and we support
their decision(s) for violators of all engineered/implemented traffic management
processes working for and/or providing a service to Ursa.
V
V
V
3.3 Findings and Recommendations from Traffic and Transportation Assessment
HIA
Reference
Number
Assessment & Recommendations
GARCO Application
Reference Page Number
Agency
Comments
Presentation/Community Mtg Date
6/15/15
7/13/15
8/3/15
8/17/15
9/2/15
10
Request that the Garfield County Sheriff's Department or other qualified entity review Ursa's Traffic Impact Analysis
and request feedback on possible safety mitigations and traffic hot spots to ensure the plan is protective of public
health.
N/A
•Traffic Study
GARCO
GARCO sent the entire application to County agencies including GARCO Road
and Bridge and Sheriffs Department as part of the agency review process.
V
V
V
CSPH recommend that Ursa:
11
Consider speed control measures on worker ingress and egress routes within the PUD (i.e. decreased speed limits,
signage, real time speed measurement signs, photo speed ticket vans, speed bumps or other measures) to prevent
speeding.
N/A
•Traffic Study
We will utilize GARCO Sheriff's Department and/or other certified law
enforcement agencies to mitigate and manage unsafe driving practices. We
value and support their ability to legally utilize their discretion, and we support
their decision(s) for violators of all engineered/implemented traffic management
processes working for and/or providing a service to Ursa. On all Ursa access
roads, we have various posted speed limits ranging from 5-20 mph. All verified
violators are subjected to disciplinary processes. In addition, speed bumps are
not allowed on GARCO roads.
V
V
V
URSA RESPONSES TO BATTLEMENT MESA HEALTH IMPACT ASSESSMENT (HIA) "Colorado School of Public Health" (Feb 2011)
Meetings Content: 6/15/15 - Geology 7/13/15 - Regulatory/Permitting/Ops Overview 8/3/15 - Construction Phase 8/17/15 - Drilling/Completions Phase
9/2/15 - Production Phase
NOTE: All references to Antero changed to Ursa.
3.4 Findings and Specific Recommendations from Noise, Vibration and Light Assessment
HIA
Reference
Number
Assessment & Recommendations
GARCO Application
Reference Page Number
Agency
Comments
Presentation/Community
Mtg Date
6/15/1517/13/15
8/3/1518/17/15
9/2/15
As a condition of the SUP, CSPH recommend that the BOCC require Ursa to:
1
Improve sound mitigation to achieve noise levels below 55 dbA in the day and 50 dbA at night during all well
development and production activities at the distance of 350 feet from the noise source on the well pad. Require Ursa
to monitor noise and to use best mitigation technology available to maintain these levels throughout the
development period.
•PD Pg 2
•IA Pg 6
•Sound Study
•SA Pg 14, 16-17
COGCC/
GARCO
Follow COGCC rules and GARCO rules regarding noise levels. Ursa does
background and operations noise monitoring and utilizes BMPs to mitigate noise
impacts to the community. Ursa is developing a noise program plan.
V
V
V
V
2
Require best available noise reduction technology for heavy equipment, including trucks and truck brakes, to reduce
noise levels.
•PD Pg 2
•IA Pg 6
•Sound Study
•SA Pg 14, 16-17
See HIA 3.4.1. Ursa uses BMPs to mitigate noise impacts to the community.
V
V
V
V
3
Develop and implement Community Advisory Board which can address the Battlement Mesa resident's concerns
about noise. This can help prevent long-term nuisance noise levels, in cooperation with Battlement Mesa residents
and Garfield County. For further details regarding the recommendation for a Community Advisory Board, see
recommendation for Community Wellness Assessment.
N/A
Ursa participates in the EAB and Community Counts where residents can express
their concerns regarding all types of nuisance impacts. Ursa encourages
residents to contact their Land Department with complaints so they can be dealt
with immediately. Ursa has held five community meetings focusing on the Phase
1 development.
V
V
V
V
4
Alert residents of anticipated noise, including time, duration, decibel levels, and machinery to be used to protect
public health.
•IA Pg 1
Gave an overview of time frames and durations of all noise, odor and other
concerns related to all phases of development during community meetings,
including land notifications for Move-In/Rig-Up operations during drilling.
V
V
V
V
5
Develop industrial haul routes to remove truck traffic from the PUD and away from the homes on Stone Quarry road.
'Traffic Study
•SA Pg 4, 15
GARCO
Ursa only utilizes approved and implemented haul routes designated by the
BOCC and GARCO R&B.
V
V
V
V
If industrial haul routes are not developed then:
6
Reduce speed limits for trucks within the PUD to 20 miles per hour to reduce noise and vibration levels.
N/A
GARCO
Ursa will follow all posted speed limits implemented by GARCO and/or local
governments in our operational areas. On Ursa access roads, the speed limits
vary from 5-20 mph depending on location.
V
V
V
V
7
Consider installation of traffic noise barriers near the St. John Elementary School and/or Grand Valley Middle School
to reduce noise levels at schools if school staff indicates that there are noise impacts at the school.
N/A
GARCO
We manage what we can. We utilize noise mitigation on our operations/pads.
Placing noise mitigations outside of our operations imposes multiple safety
concerns/obstruction of line of view as these structures are located directly off
of thoroughfares. This could pose a potential issues for bus transportation,
residents, emergency responders, etc.
8
Install permanent/semi-permanent noise mitigation structures (sound walls) along haul routes CR300 and other
routes where trucks are anticipated to be passing throughout the development period to reduce noise levels.
N/A
•PD Pg 2
•IA Pg 6
•Sound Study
•SA Pg 14, 16, 17
GARCO
We manage what we can. We utilize noise mitigation on our operations/pads.
Placing noise mitigations outside of our operations imposes multiple safety
concerns/obstruction of line of view as these structures are located directly of
thoroughfares. In addition, this poses various issues along CR 300.
v
v
v
v
URSA RESPONSES TO BATTLEMENT MESA HEALTH IMPACT ASSESSMENT (HIA) "Colorado School of Public Health" (Feb 2011)
Meetings Content: 6/15/15 - Geology 7/13/15 - Regulatory/Permitting/Ops Overview 8/3/15 - Construction Phase 8/17/15 - Drilling/Completions Phase
9/2/15 - Production Phase
NOTE: All references to Antero changed to Ursa.
3.5 Findings and Specific Recommendations Related to Community Wellness
HIA
Reference
Number
Assessment & Recommendations
GARCO Application
Reference Page Number
Agency
Comments
Presentation/Community
Mtg Date
6/15/1517/13/15
8/3/1518/17/15
9/2/15
CSPH recommends that Ursa, Battlement Mesa Citizens and Garfield County:
1
Establish a Community Advisory Board to facilitate on-going community engagement between Ursa, Garfield County
officials, Battlement Mesa Company and residents of Battlement Mesa for early identification of impacts to
community wellness. A Community Advisory Board can provide direct and frequent interactive communication
between these groups. It can provide an ongoing mechanism for citizens to report problems and concerns to Ursa and
can allow Ursa to address concerns in a timely manner. It can also provide feedback to the county regarding success
of residential natural gas development. A Community Advisory Board can also provide an opportunity for Ursa to
apprise the residents of current activities and changes to plans, which can help reduce uncertainty for residents and
may decrease anxiety. The Community Advisory Board can also provide input regarding the use of the one million
dollar donation to ensure that the use of this money supports community and physical health.
•IA Pg 1
Ursa participates in the EA and Community Counts where residents can express
their concerns regarding all types of nuisance impacts. Ursa encourages
residents to contact their Land Department with complaints so they can be dealt
with immediately. Ursa will continue to hold at least quarterly stakeholder
meetings to keep residents apprised of ongoing activities.
V
V
V
V
CSPH recommend that Garfield County:
2
Review sexually transmitted infection clinic access, outreach and education, with particular attention to in -migrant
workforce to reduce spread of sexually transmitted infections within the community.
N/A
GARCO
This process needs to be addressed via one's personal medical care provider, the
Center for Disease Control or one's religious representative, etc. This is a very
personal situation and should be treated with the utmost discretion and
compassion while allowing each individual to resource their option on guidance
on such medical education.
V
3
Identify operators and subcontractors that have implemented drug and alcohol free work -place programs and
encourage Ursa to do so and subcontract to companies that also do so. Provide Ursa with contacts to those that
educate employers regarding benefits of such programs.
N/A
Per our Master Service Agreement (MSA), contractors are subjected to random,
onsite, and reasonable cause drug testing, etc. All Ursa new hires must submit to
drug testing: hair, urine and breath. Ursa and contractors have in place a
comprehensive Substance Abuse Program. We have a very stringent testing
program in place. The expectations for a substance free environment is not
taken lightly at Ursa.
V
v
CSPH recommend that Garfield County and Ursa:
4
Support baseline and ongoing studies to determine the impact of residential natural gas development on community
health and the effects on individual health. This information will provide direct feedback to the Ursa -Battlement Mesa
project, allowing for improvements in community aspects as the project continues. It will also provide valuable
information for other communities experiencing or anticipating residential natural gas development. These studies
should include measurements related to lifestyle and social cohesion, education, crime, sexually transmitted
infection, mental health and suicide, and substance abuse.
•SA Pg 10
Ursa has participated in CSU's air quality monitoring program since its inception.
Ursa also has an ongoing noise monitoring program. If requested, Ursa is willing
to participate in other studies if other oil and gas producers in Garfield County
participate as well.
+/
V
+/
V
5
Ensure recommendations to mitigate other concerns (air quality, traffic, and noise) are implemented.
N/A
See previous comments.
V
V
V
V
Recommendations to Support Benefits to Community Wellness
CSPH recommend that Garfield County:
6
Encourage use of local business, especially those that enhance community cohesion, such as local restaurants and
coffee shops.
N/A
Ursa and its employees live and work in the area. Support of local businesses is
part of being a member of the community.
7
Utilize Ursa's one million dollar donation to enhance community cohesion.
N/A
Acknowledged
URSA RESPONSES TO BATTLEMENT MESA HEALTH IMPACT ASSESSMENT (HIA) "Colorado School of Public Health" (Feb 2011)
Meetings Content: 6/15/15 - Geology 7/13/15 - Regulatory/Permitting/Ops Overview 8/3/15 - Construction Phase 8/17/15 - Drilling/Completions Phase
9/2/15 - Production Phase
NOTE: All references to Antero changed to Ursa.
3.6 Findings and Specific Recommendations from Economic and Employment Assessment
HIA
Reference
Number
Assessment & Recommendations
GARCO Application
Reference Page Number
Agency
Comments
Presentation/Community
Mtg Date
Recommendations to Reduce Impacts from Economic Effects
6/15/1517/13/15
8/3/15
18/17/15
9/2/15
CSPH recommend that before the project starts, the BOCC require Ursa to:
1
Require that Ursa develop a reasonable and specific timeline for all activities associated with development and
maintenance of the wells. Require that Ursa communicate changes to the plans at the earliest possible time before
any changes in the plans occur. This would address some concerns in the real estate market. If sellers and buyers can
confidently anticipate the steps and timing of the well development process, the real estate market may react less
unfavorably to the project.
•PD Pg 4
•IA Pg 1
Development timeline was communicated during the five community meetings.
Ursa will continue to communicate through community organizations and
meetings and updates.
V
V
V
V
CSPH recommend that Ursa, Battlement Mesa Citizens and Garfield County do the following before the Project starts:
2
Establish a Community Advisory Board that meets regularly and frequently with Ursa (at least every month). Garfield
County, citizens, Ursa and the Battlement Mesa Company should be a part of this board. The Community Advisory
Board can actively interact with Ursa to facilitate communication to and from the residents and the county. Establish
clear and timely communications methods to facilitate information regarding changes to the timeline and activities.
Provide the Community Advisory Board with sufficient powers to allow for resident input, which can demonstrate
that residents can voice their concerns.
•IA Pg 1
See HIA 3.5.1
3
Consider multiple methods of communication to residents regarding development and maintenance activities.
•IA Pg 1
See HIA 3.6.1. Ursa uses multiple avenues to communicate with residents
including required notifications and courtesy notification through Community
Counts.
V
V
V
V
CSPH recommend that Garfield County:
4
Continue to consider public health as a high level priority when judging uses of local government revenues derived
from the natural gas development and production to maximize protection of public health.
N/A
GARCO
Garfield County BOCC will respond.
5
Ensure recommendations to mitigate other concerns (air quality, traffic, noise and community wellness) are
implemented.
•PD Pg 2,5
•IA Pg 6, 7
•FDCP
•SA Pg 1, 14, 16, 17
GARCO
Garfield County BOCC will respond.
V
V
V
V
Recommendations to Support Benefits from Employment Effects
CSPH recommend that Garfield County:
6
Support local educational institutions that provide training for industry related jobs during the development period
and retraining for when industry jobs end after the development period.
N/A
GARCO
Garfield County BOCC will respond.
URSA RESPONSES TO BATTLEMENT MESA HEALTH IMPACT ASSESSMENT (HIA) "Colorado School of Public Health" (Feb 2011)
Meetings Content: 6/15/15 - Geology 7/13/15 - Regulatory/Permitting/Ops Overview 8/3/15 - Construction Phase 8/17/15 - Drilling/Completions Phase
9/2/15 - Production Phase
NOTE: All references to Antero changed to Ursa.
3.7 Findings and Specific Recommendations Related to Health Care Infrastructure
HIA
Reference
Number
Assessment & Recommendations
GARCO Application
Reference Page Number
Agency
Comments
Presentation/Community
Mtg Date
6/15/1517/13/15
8/3/1518/17/15
9/2/15
CSPH recommends that Garfield County:
1
Monitor which companies, including Ursa and subcontracting companies, provide health insurance to employees to
determine how the natural gas industry contributes to health care infrastructure.
N A
/
GARCO
Ursa provides medical insurance to their employees. The Patient Protection and
Affordable Care Act was signed into law by President Obama on March 23, 2010.
The federal law mandates coverage for all Americans and penalties for those
who elect to waive coverage.
2
Monitor health care utilization in Garfield County to determine if rates of uncompensated care are associated natural
gas industry cycles.
N/A
GARCO
This assessment is unobtainable as it could potentially violate one's billing
privacy and access to any information revolving around medical care could
potentially violate HIPPA.
3
Ensure that county revenues continue to meet changes in county services, including public health services.
N/A
GARCO
Garfield County BOCC will respond.
URSA RESPONSES TO BATTLEMENT MESA HEALTH IMPACT ASSESSMENT (HIA) "Colorado School of Public Health" (Feb 2011)
Meetings Content: 6/15/15 - Geology 7/13/15 - Regulatory/Permitting/Ops Overview 8/3/15 - Construction Phase 8/17/15 - Drilling/Completions Phase
9/2/15 - Production Phase
NOTE: All references to Antero changed to Ursa.
3.8 Findings and Specific Recommendations from Assessment of Accidents and Malfunctions
HIA
Reference
Number
Assessment & Recommendations
GARCO Application
Reference Page Number
Agency
Comments
Presentation/Community
Mtg Date
6/15/1517/13/15
8/3/1518/17/15
9/2/15
CSPH recommends that as a condition of the SUP the BOCC requires Ursa to:
1
Work with emergency responders in Battlement Mesa (e.g., the sheriff and fire departments) and Battlement Mesa
residents to establish a comprehensive emergency response plan that includes notification and communication
systems, evacuation routes, plans for evacuating schools, the assisted living facility, and capacity of local emergency
responders hospitals, and sheltering in place, accurate maps of pipelines, shut-off valves, and well pads, as well as
identifying air intakes at the schools, assisted living facility, and recreation center prior to any activity in the PUD. We
recommend that the copies of the emergency response plan be kept at the sheriff department, fire department, all
responding hospitals, and on a Garfield County website and/or a publicly accessible website approved by the
Battlement Mesa Community.
•SA Pg 5
•ERP
A comprehensive and thorough Emergency Response Plan is in place for Ursa's
Operations. It includes hospitals, air flight, fire stations, mustering processes
complete with coordinates. This has been provided to Grand Valley Fire
Department and Grand Valley Police Department. It is revised as additional
operational pads are constructed. In the event of an emergency directly
affecting the welfare of the residents of Battlement Mesa, we will work with
various EMS agencies/Battlement Mesa to ensure information is relayed
accordingly. There are limits to various communications as not all citizens utilize
a computer, have cell phones and/or residential phones.
V
V
V
2
Test the emergency response plan in cooperation with emergency responders by performing a drill prior to any
natural gas operations commence in the PUD and annual drills thereafter, as well as annual reviews and updates of
the emergency response plan.
•SA Pg 5
•ERP
Ursa has in place procedures included in the Site Specific Emergency Response
Plan (SSERP) that addresses how Ursa representatives and our contractors are to
respond in the event of a fire, well control, medical emergency, chemical
spill/exposure, and severe weather response for our immediate operations. Ursa
is willing to participate in emergency response drills if local emergency
responders request. The GVFD Chief addressed this at the 9/2/15 community
meeting.
V
V
V
3
Annually disclose all chemicals used on its well pads within the PUD and include a list of these chemicals in the
emergency response plan.
•SA Pg 5, 7,
•ERP
10
COGCC
See HIA 3.1.2.
4
Notify the sheriff and fire department one week prior to well drilling, hydraulic fracturing, flow back, and pipeline
pigging activities.
N/A
We notify Community Counts for rig moving operations and our Land
representative works with residents on other various ops.
v
v
v
5
Implement the emergency response provisions provided in Ursa's best management practices submitted as
comments to the September 2010 Draft HIA.
•SA Pg 5
•ERP
Emergency response provisions have been included in Ursa's policies, plans, and
procedures.
v
v
v
6
Implement the well site and facility security provisions provided in Ursa's best management practices submitted as
comments to the September 2010 Draft HIA.
•SA Pg 4
A comprehensive and thorough Emergency Response Plan is in place for Ursa's
Operations. It includes hospitals, air flight, fire stations, mustering processes
complete with coordinates. This has been provided to Grand Valley Fire
Department and Grand Valley Police Department. It is revised as additional
operational pads are constructed. In the event of an emergency directly
affecting the welfare of the residents of Battlement Mesa, we will work with
various EMS agencies/Battlement Mesa to ensure information is relayed
accordingly. There are limits to various communications as not all citizens utilize
a computer, have cell phones and/or residential phones.
V
V
V
7
Adhere to its best management practices for pipelines and all COGCC rules throughout the life of the project as a
condition of the special use permit.
•PD Pg 1, 2,
•IA Pg 1, 6
•SA Pg 7, 8,
4, 5
9 12,
13, 14,17
Ursa will utilize all industry standard practices and BMPs as represented in the
application and its institutional documents. Ursa will comply with all applicable
agency rules and regulations throughout the life of the project.
V
V
8
Institute mechanism for reporting safety concerns, near -misses, and minor incidents to the appropriate designated
county agency or department to reduce accidents and malfunctions. Reports of these concerns and incidents should
also be made to the Community Advisory Board, along with plans for preventive and corrective actions.
•PD 4
•IA Pg 7
•SA Pg 5
•ERP
Ursa complies with regulations implemented through COGCC, CDPHE, and
OSHA/HIPPA for all reporting processes. A comprehensive and thorough incident
investigation/reporting process is conducted in house/with contractors to
always properly mitigate and train on the prevention of reoccurrence or the
prevention of further Health & Safety risks.
V
V
V
9
Develop an ongoing fire prevention program in coordination with the local fire department's community fire
prevention program. This program should include routine inspection and implementation of wildfire mitigation plans
(for example, all areas surrounding well pads are kept clear of vegetation that could contribute to spreading).
•SA Pg 5, 10
•ERP
Ursa will utilize all industry standard practices and BMPs as represented in the
application and its institutional documents. Ursa will comply with all applicable
agency rules and regulations throughout the life of the project.
V
V
3.8 Findings and Specific Recommendations from Assessment of Accidents and Malfunctions
HIA
Reference
Number
Assessment & Recommendations
GARCO Application
Reference Page Number
Agency
Comments
Presentation/Community
Mtg Date
6/15/1517/13/151
8/3/1518/17/15
9/2/15
CSPH recommend that Garfield County:
10
Clearly mark primary and secondary evacuation routes from Battlement Mesa.
•ERP
GARCO
All routes are clearly addressed in the SSERP provided to Ursa representatives
and contractors on/off site. These routes are intended for Ursa and our
contractors. For citizens/residents, they shall receive guidance from designated
GVFD/GVPD/GARCO officials for their evacuation routes. Ursa will also follow
any direct guidance on evacuation given on behalf of the mentioned responding
officials/brigades.
V
V
V
11
Perform quarterly tests of emergency notification systems within Battlement Mesa (e.g., sirens and reverse 911).
N/A
GVFD/
GVPD/
GARCO
All routes are clearly addressed in the SSERP provided to Ursa representatives
and contractors on/off site. These routes are intended for Ursa and our
contractors. For citizens/residents, they shall receive guidance from designated
GVFD/GVPD/GARCO officials for their evacuation routes. Ursa will also follow
any direct guidance on evacuation given on behalf of the mentioned responding
officials/brigades. This was addressed by the GVFD Fire Chief at the 9/2/15
community meeting.
V
V
12
Request the Battlement Mesa fire department to inspect all proposed well pad locations and make recommendations
for the prevention of well pad fires spreading from the pads up to relocation of pads and that these
recommendations are incorporated into the special use permit.
•SA Pg 5
GVFD
Will reach out to GVFD Chief for guidance and assistance. GARCO and state
agencies determine the appropriate local agencies to inspect locations. Ursa
wecomes safety inspections at any time.
V
V
13
Require all gas pipelines to follow established truck haul routes and allow no gas pipelines through the center of the
PUD.
SUA
GVFD
Gas pipelines were located per the SUA with Battlement Mesa Partners.
14
Assign a county inspector to oversee and inspect all pipeline construction and maintenance in the PUD.
•Pipeline SUP
GARCO
Ursa will cooperate with all county departments as appropriate during pipeline
construction.
V
V