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Home My WebLink AboutHydraulic Fracturing - Adminstrative InterpretationGurfield County Community Development Department October 18,2017 Jeff Kirtland Terra Energy Partners 4828 Loop Central Drive #900 Houston, TX77081 RE: Hydraulic Fracturing, Remote Surface Facility Dear Mr. Kirtland This letter is being provided to you in response to your inquiry about a Hydraulic Fracturing, Remote Surface Facility to be operated in Garfield County by Terra Energy Partners LLC. The Garfield County Land Use and Development Code of 2013, as Amended, lists a Hydraulic Fracturing, Remote Surface Facility as either Permitted by right, or exempt from County review and standards if located in the Public Lands zone district. The Land Use Code defines such a facility as: A CocCC-approved surface location used for staging materials and equipment (including storage of water in open pits and tanks) to pump hydraulic fracturing fluid to 1 or more COGCC-approved well locations forthe purpose of advancing the wellbore and increasing the productivity of the well through hydraulic fracturing as part of the well completion activity. Your email from October 5,2017 stated: Regarding your questions, the Smith Gulch Completions Pit 31-32-796 is in Section 32, Township 7 South, Range 96W (please see attached map), which is zoned Resource Lands. The COGCC permit includes the attached Form 15, which will be replaced with a Form 28 permit upon COGCC approval. The best source for COGCC approval is on their website, reference Facility lD#:432534. This facility is an approved and active COGCC location. The stamped construction as-built drawing for the existing facility is also 108 Eighth Street, Suite 401 Glenwood Springs, Colorado 81601 (e70)94s-8212 attached, and provides the measurements, volumes, and site information, as requested. I have also included the surety bond submitted to, and on file with, the COGCC. This facility had served as a remote hydraulic fracturing facility for the western Piceance assets previously owned and operated by Williams and WPX, now TEP Rocky Mountain LLC, and was planned and constructed to support remote hydraulic fracturing operations in the western field, including Trail Ridge, where most of our drilling has occurred in 2017. The Form 15 approved by the COGCC must be extended with a Form 28 to continue supporting the western assets and Trail Ridge development. This facility is currently being used to support remote hydraulic fracturing operations on the TR 32-23-597 (Facility lD #295973, Sec. 23, T5S-R97W) pad and was used to complete wells on three Trail Ridge well pads, including the TR 32-21-597,TR 44-27- 5g7, and TR 24-21-597. Specifically, 77 ,430 bbls of fluid was pumped for hydraulic fracturing in August-September to support completions operations in Trail Ridge. The Smith Gulch Completions Pit 31-32-796 is an integral part of continued remote hydraulic fracturing operations for an additional 100+ wells planned over the next few years, pending commodity prices. The use of this facility is consistent with the Garfield County LUR definition as it is operating on an approved COGCC location and used to stage materials and equipment, including storage of water, to pump produced water for hydraulic fracturing to multiple locations. Like all the completions pits operated by TEP, this facility supports centralized operations and promotes recycling of produced water. The benefits of this approach include piping water to various locations, thereby reducing traffic impacts and associated nuisance, and the ability to reuse produced water in lieu of fresh water. To complete the Form 28 approval, a statement from Garfield County has been requested confirming TEP Rocky Mountain LLC meets the Garfield County LUR definition and permitting requirements, thereby operating this facility as use-by-right. Per your representations Garfield County Community Development has determined that the proposed pit would fall under the Hydraulic Fracturing, Remote Surface Facility use. That use is permitted by right in the Resource Lands zone district where the subject parcel is located. Please contact Garfield Community Development Department with any additional questions Bower unity Development Director 108 Eighth Street, Suite 401 Glenwood Springs, Colorado 81601 (970) 94s-8212 Si G eld County, Colorado SG¿8..SHEÊT:PROIEC?DFT:SMTET GULC}{ 31 32-796 PÌTAS - æNSTRUCîED CROSS SECî]OIUSlll¡l5FgY wPX Enersy Roctq Mounhin, LLcConstruction Plan Prepared for:PIT Q.(çr\Pit I'leltìng Sl¡udurcSoil StækqleI zz'rietaneExisling GrcundIN.\_IL2' F@ Bætd\ Erev.:5138.5\þ"YAìEIev.:5123.60J.;\Complet¡ons P¡l\cYElev.:5123.61Total Pit Volume = !124730 bbl2'ftee Board Vol.=t10580 bA. Exisbng\{ crcúd''t(-. Itrl17Firem NeÍihgt;Lilêgtuture15'F¡re Lane,\fIICØpletiØs P¡tBEIev.:urrr.orJ-Elev.:5122.78SCALE: Hotiz.: 1'= 80'Veñ.:t'=20'ñs&Gttch lt-:Ì2-?lr6 Pftftcl}¡tidJ.tu,PE *æA,m1û16REWSED:6,/14,/16KWI2WLI|AMS VALLEYEG ømpletons P|NG Èm Ste Plan.tug ETATE OF colon^Þo Document 2526538 E nvi roS can - DNR, OGCC < dnr_ogcc. envi roscan@state, co. us> Fwd: TEP Rocky Mountain LLG - Operator # 96850 1 message Fischer - DNR, Alex <alex.fischer@state.co.us> To: OGCC E nvi roScan - DNR <dnr-ogcc. envi roscan@state. co. us> Scanning Work Request: Please upload this email as follows Thanks! Alex Fischer, P.G. Environmental Supervisor, Western Colorado Mon, Jul 11, 2016 at 9:42 AM COLORADO O¡l I Gãs Congervatlon Commiasion l\'r,.1! tfr.-Ìr'iq Jfi l.¡i¡lï.¿1ì 1l(!jjrr1¡cdì Document Name(s)L Financial Assurance Document Number (leave blank if not already asslgned) Date Received 7t11t16 ls data entry needed?NO lndexing lnformation Unique lD Type Unique lD Number First Pit Facility 432534 Second Third* Additional lnstructions ^ffi1I P 303.8%.2100 x5138 | F 303.894.2109 1 1 20 Lincotn Street, Suite 801, Denver, CO 80203 I alex.fischer@state.co.us www.colorado.gov/cogcc Forwarded message From: Fischer - DNR, Alex <alex.fischer@state.co.us> Date: Mon, Jul 11, 2016 at 9:40 AM Subject: Re: TEP Rocky Mountain LLC - Operator # 96850 To: "Lutz - DNR, Deborah" <debbie.lutz@state.co.us> Cc: Martha Ramos - DNR <martha.ramos@state.co.us> Debbie- We have not received the Form 28 for review. TEP has voluntarily provided the financial assurance for the referenced pit that will be converted to a CE&P Facility. Upon receipt of the Form 28 we will review to see if the $$ amount is adequate. Thanks Alex On Fri, Jul 8, 2016 at 8:57 AM, Lutz - DNR, Deborah <debbie.lutz@state.co.us> wrote:I Good morning Alex, r We received the following bond for TEP Rod<y Mountain LLC - Operator #96850. Please advise if the amount of the I bond presented are correct and agreed upon as submitted. Also, will we be receiving any cost estimates for closure and , revised Form 28's for this facility? , Smith Gulch 31-32-796 water recycling pit for $913,445.94. Please advise. Thank you, Debbie Deborah LUE Financial Assu rance Analyst ^¿s I s*"i:"r"iîå Resou,ces P 303.8SN.2100 ext 51851 F 303.8S4.2109 1 120 Lincotn Street, Suite 801, Denve4 CO 80203 debbie.tutr@state.co.us I www.colorado.gov/cogcc LOCATION 430110 smü Gükh 11.32-7 fEP RæW MOUNTAIN I"L( 9ôS30 GARFIELD 015 m P¡I 412631 imiltr Gllcà 3t-a2.79(TEP R6KY MOUNfAIN IL( 98Sm oañFrËr_D s5 NWNE 32 75 W 6 m ::ìr ii,l I Alex Fischer, P.G. Environmental Supervisor, Western Colorado cotoRAÞo 0ll$ Gas Corurnr*üoü dom¡ntaeion ãepff$ïañ! {t N¡lurôl &ñtû{!ffi P 303.894.2100 x51 38 I F 303.894.2109 1 1 20 Lincotn Street, Suite 801 , Denver, CO 80203 I alex.fischer@state.co.us www.colorado.gov/cogcc ^ffi ^ågI Alex Fische[ P.G. Environmental Supervisor, Western Colorado c(lröaADo Õtl8 Gaa Conæn¡rüon tommissl,on t*Êûn?l.tcn( eñ Nåtur*l R*$Ê¿¡rÊrr P 303.894.2100 x51 38 I F 303.894.2109 'l'f 20 Lincol.n Street, Suite 80!, Denver, CO 80203 I alex.fischer@stãte.co.us www.colorado.gov/cogcc OGCC RECEPTION Document Number: 400386922 ATTACHMENTS Detailed Site Plan Design/Cross Sec Topo Map Calculations Sensitive Area lnfo Mud Program Form 2A Form 26 Water Analysis OGCC Operator Number:96850 Contact Name: Karolina Blaney Name of Operator: WPX ENERGY ROCKY MOUNTAIN LLC 1OO1 17TH STREET. SUITE #1200 Phone: (970) 6832295 City: DENVER State: CO Zip: 80202 Email: Karolina.Blaney@WPxEnergy.co m FORM l5 Rev 10t11 EARTHEN PIT REPORT / PERMIT This form is to be used for both reporting and permitting pits. Rule 903 describes when a Permit with prior approval, or a Report within 30 days is required for pits. Submit required attachments and forms. Form Type: IX.PERMIT T'.REPORT OGCC PIT NUMBER: 432534 NOTE: Operator to provide OGCC Pit Number only if available on an existing pit for pit report Pit Location lnformation Site Conditions Distance (in feet) to the nearest surface water: ls this location in a Sensitive Area? Yes 163 Ground Water (depth): Existing Location? 6 WaterWell: 4994 P¡I and Construction State of Golorado Oil and Gas Conservat¡on Commission 'f120 Lincoln Street, Suite 801, Denver, Colorado 80203 Phone: (303) 894-2100 Fax: (303) 894-2109 Operator's PiUFacility Name: Smith Gulch 31-32-796 Operator's PiVFacility Number: API Number (associated well): 05-00 OGCC Location lD (associated location): 4301 10 Or Form 2A # Pit Location (OtrQtr, Sec, Twp, Rng, Meridian): NWNE-32-7S-96W-6 Latitude: 39.398863 Longitude: -108.129210 County: GARFIELD Pit Use/Type (Check all that apply): Pit Type: |_X. Lined T- Unlined ì --Drilling: (Ancillary, Completion, Flowback, Reserve Pits) f - O¡l-based Mud; I - Saft Sections or High Chloride Mud f"-Production: f' Skimming/Settling; l-'- ProducedWaterStorage; f"'Percolation; T- Evaporation l'- Special Purpose: I-.' Flare; l*' Emergency; T"- Blowdown; I - workover; ì-"' Plugging; i- gsawnank Bottoms ffiMulti-Well Pit Construction Date: 0410112013 Actual or Planned: Planned Method of treatment prior to discharge into pit: four phase separation Offsite disposal of lX lnjection; FX. Commercial; l-X. Reuse/Recycle; i - NpOeS; Permit Number: pit contents: Other lnformation Size of Pit (in feet): Length: 350 Width: 160 Depth: 16 Calculated Working Volume (in barrels): 97700 Flow Rates (in bbl/day): lnflow: 2000 Outflow: Evaporation: Percolation: 0 Primary Liner. Type: HDPE Thickness (mil): 60 ls Pit Fenced? Yes ls Pit Netted? Yes Leak Detection? Yes Other lnformation Seconday Liner (if present): Type: HDPE + clay liner Thickness (mil): 40 Certification I hereby certify all statements made in this form are, to the best of my knowledge, true, correct, and complete. Signed: Print Name: Karolina Blaney y.com Tifle:Environmental Specialist Email Operator Comments: Karolina.Blaney@WPXEnerg Date: 0310112013 Date Run: 411812013 Doc Ff4003869221 Page 1 of 4 Signed: Approval Title: Director of Cogcc Date: 0411812013 CONDITIONS OF APPROVAL: TEMPORARY SURFACE PIPELINES COAs: Operator must implement best management practices to contain any unintentional release of fluids along all portions of the surface pipeline route where temporary pumps and other necessary equipment are located. Operator must routinely inspect the entire length of the surface pipeline to ensure integrity. Operator must ensure I 10 percent secondary containment for any potential volume of fluids that may be released from the surface pipeline at all stream, intermittent stream, ditch, and drainage crossings. Operator will utilize, to the extent practical, all existing access and other public roads, and/or existing pipeline right-of- ways, when placing/routing the surface pipelines. This will reduce surface disturbance and fragmentation of wildlife habitat in the area. FORM l5 EARTHEN PIT PERMIT COAs The multi-well pit must be doublelined. The pit will also require a leak detection system (Rule 904.e). Delivery ancl vacuum truck hoses will not be allowed to be placed directly onto the pit liner. Operator will construct a loading/unloading station located next to the pit, to deliver fluids to or remove fluids from the pit by truck. The loading/unloading station shall be designed and utilized to prevent hoses from being dropped into the pits and dragged over the liner, which could lead to liner damage. The loading/unloading station will be the only permitted BMP CommentType G ROUN DWATER/SURFACE WATER BASELINE SAMPLING COA: Baseline Water ïesting: Prior to pit operations, operator shall sample at a minimum two (2) domestic water wells or springs within a one (1) mile radius of the proposed oil and gas location. Testing preference shall be given to domestic water wells and springs over surface water. lf possible, the water wells or springs selected should be on opposite sides of the oil and gas location not exceeding a one (1) mile radius. lf water wells or springs on opposite sides of the oil and gas location cannot be identified, then the two (2) closest wells or springs within a one (1) mile radius of the oil and gas location shall be sampled. The sample location shall be surveyed in accordance with Rule 215. Sampling and analysis shall be conducted in conformance with an accepted industry standard as described in Rule 910.b.(2). lnitial baseline testing shall include: pH, specific conductance, total dissolved solids (TDS), dissolved gases (methane, ethane, propane), alkalinity (total bicarbonate and carbonate as CaCO3), major anions (bromide, chloride, fluoride, sulfate, nitrate and nitrite as N, phosphorus), major cations (calcium, iron, magnesium, manganese, potassium, sodium), other elements (barium, boron, selenium and strontium), presence of bacteria (iron related, sulfate reducing, slime and coliform), total petroleum hydrocarbons (TPH) and BTEX compounds (benzene, toluene, ethylbenzene and xylenes). Hydrogen sulfide shallalso be measured using a field test method. Field observations such as pH, temperature, specific conductance, odor, water color, sediment, bubbles, and effervescence shall also be included. COGCC recommends that the latest version of EPA SW 846 analytical methods be used where possible and that analyses of samples be performed by laboratories that maintain state or national accreditation programs. lf free gas or a dissolved methane concentration greater than 1.0 milligram per liter (mg/l) is detected in a water well, gas compositional analysis and stable isotope analysis of the methane (carbon and hydrogen: 12C, 13C, 1H and 2H) shall be performed to determine gas type. lf test results indicated thermogenic or a mixture of thermogenic and biogenic gas, then the operator shall submit to the Director an action plan to determine the source of the gas. lf the methane concentration increases by more than 5.0 mg/l between sampling periods, or increases to more than 10. mg/|, the operator shall notify the Director and the owner of the water well immediately. After 90 days, but less than 180 days of use of the pit for completion operations, a "second" test shall be performed for the same analytical parameters listed above and repeated once every l2 months. Additional test(s) may be required if changes in water quality are identified during follow-up testing. The Director may require further water well sampling at any time in response to complaints from water well owners. Copies of all test results described above shall be provided to the Director and the landowner where the water quality testing well is located within three (3) months of collecting the samples used for the test. The analytical data and surveyed well locations shall also be submitted to the Director in an electronic data deliverable format. Documented refusal to grant access by well owner or surface owner (for water well or spring sampling), or if no water wells or springs are located/identified within one mile, shall not constitute a violation of this COA. Date Run: 411812013 Doc [#400386922]Page 2 of 4 access for manual fluids transfers to or from the pit. Vehicles will not be allowed to approach the pit any closer than the loading/unloading station. Each station will have a catch basin in case a leak occurs while operations personnel are connecting or disconnecting hoses. Signs clearly marking the truck loading/unloading station shall be provided and maintained by the operator. Operator must submit a professional engineer (PE) approved/stamped as-built drawing (plan view and cross-sections) of the multi-well pit within 30 calendar days of construction. After installation of the uppermost liner and prior to operating the pit, the synthetic liner(s) shall be tested by filling the pit with at least 70 percent of operating capacity of water, measured from the base of the pit (not to exceed the 2-foot freeboard requirement). The operator shall monitor the pit for leaks for a period of 72 hours prior to either draining the pit or commencing operations. Operator shall notify the COGCC Oil and Gas Location Assessment (OGLA) Specialist for Western Colorado (Dave Kubeczko; email dave.kubeczko@state.co.us) 48 hours prior to start of the hydrotest. Hydrotest monitoring results must be maintained by the operator for the life of the pit and provided to COGCC prior to using the pit (via Form 4 Sundry to Dave Kubeczko; email dave.kubeczko@state.co.us) . ln lieu of conducting an initial hydrostatic test of the pit, the operator can monitor fluid levels in the pit continuously using a minimum of two pressure transducers located at the upgradient and downgradient ends of the pit (based on the original topographic profile). These pressure transducers should be linked to the operator's SCADA system such that they can be remotely monitored. ln addition, the pit liner will be marked at the two foot freeboard depth line so that operations personnel (as well as COGCC inspectors) can easily verify that the required fluid free board is being maintained. The electronically collected water level measurement data shall be used to confirm changes in pit inflow and outflow during operations based on estimates from truck and/or pipeline delivery o¡ removal activities. Any abnormalities that are noticed during operations will be reported to the operator's field supervisor immediately so that any necessary follow-up can be scheduled. No portion of any pit that will be used to hold liquids shall be constructed on fill material, unless the pit and fill slope are designed and certified by a professional engineer, subject to review and approval by the director prior to construction of the pit. The construction and lining of the pit shall be supervised by a professional engineer or their agent. The entire base of the pit must be in cut. The nearby downgradient hillside below the pit location must be periodically monitored for any day-lighting of fluids throughout pit operations. The multi-well pit must be fenced and netted. The operator must maintain the fencing and netting untilthe pit is closed. Operator shall pressure test pipelines in accordance with Rule I 101.e.(1) prior to putting into initial service any temporary surface pipelines or configuration of the permanent pipeline network. This multi-well pit willcomply with Rule 902. PITS - GENERAL AND SPECIAL RULES. e. Pits used for a period of no more than three (3) years for storage, recycling, reuse, treatment, or disposal of E&P waste or fresh water, as applicable, may be permitted in accordance with Rule 903 to service multiple wells. Operator has indicated that this facility may be in operation from 3 to 5 years. Should the operation of this facility continue more than three years, a Form 28 shall be submitted and approved prior to the expiration of the Form 2A and Form 15. Surface water samples (one upgradient and one downgradient from the frac pad/multi-well pit location) from the unnamed intermittent stream located east-northeast of the location (if water is present) shall be collected prior to pit use and every 12 months (until pit closure) to evaluate potential impacts from pit operations. lf water is not present in the unnamed intermittent stream, then surface water samples from Smith Gulch, located approximately 1100' to the west (if water is present), shall be collected. At a minimum, the surface water samples will be analyze for the following parameters: major cations/anions (chloride, fluoride, sulfate, sodium); total dissolved solids (TDS); and BTEXDRO. The operator shall submit, and receive approval of, a reuse and recycling plan per Rule 907.a.(3), prior to any offsite reuse/recycling of pit fluids. The multi-well pit shall be closed in accordance with Rule 905. Closure of Pits, and Buried or Partially Buried Produced Water Vessels; with an approved Site lnvestigation and Remediation Workplan, Form 27. Submit additional disposal facilities (wells, pits, etc.), if necessary (i.e., if original disposal option changes), for pit liquid contents to COGCC via a Form 4 Sundry prior to disposal. At the time of pit closure, operator must submit disposal information for solids, if necessary, via a Form 4 Sundry Notice to the COGCC Location Specialist for Western Colorado (Dave Kubeczko; email dave.kubeczko@state.co.us). Date Run: 411812013 Doc [#400386922]Page 3 of 4 SITE SPECIFIC COAs Notify the COGCC 48 hours prior to start of frac pad construction, pit liner installation, start of hydrostatic test, and start of hydraulic stimulation operations using Form 42 (the appropriate COGCC individuals will automatically be email notified, including the LGD for hydraulic stimulation operations). Operator must implement best management practices to contain any unintentional release of fluids at the pit location, as well as any fluids conveyed via temporary surface or buried permanent pipelines. Operator must ensure secondary containment for any volume of fluids contained at frac pad site during completion operations (as described on the BMP tab); including, but not limited to, construction of a berm or diversion dike, diversion/collection trenches within and/or outside of berms/dikes, site grading, or other comparable measures (i.e., best management practices (BMPs) associated with stormwater management) sufficiently protective of nearby surface water. Any berm constructed at the frac pad location will be stabilized, inspected at regular intervals (at least every 14 days), and maintained in good condition. Flowback and stimulation fluids must be sent to tanks, separators, or other containmenVfiltering equipment before the fluids can be placed into the multi-well pit or storage vessel on the frac pad; or into tanker trucks for offsite disposal. flowback and stimulation fluid tanks, separators, or other containment/filtering equipment must be placed on the pad or nearby well pads in an area with additional downgradient perimeter berming. The area where flowback will be stored/reused must be constructed to be sufficiently impervious to contain any spilled or released material itional containment shall be required where temporary or permanent pumps and other necessary equipment or chemicals are located. Berms or other containment devices shall be constructed to be sufficiently impervious (preferably corrugated steel with poly liner) to contain any spilled or released material around crude oil, condensate, and produced water storage tanks. The disposal method will need to be approved prior to operator starting pit closure. Date Run: 411812013 Doc [#É400386922]Page 4 of 4 Patrick Waller From: Sent: lo: Cc: Subiect: Attachments: Jeff Kirtland < J Kirtland@terraep.com > Thursday, October 05,2017 10:26 AM Patrick Waller Heather Foor; Travis Roby RE: Hydraulic Fracturing, Follow-up ÑÅ* t^f'^*á*Å A¿Ø aba,tl supporting the western assets I ilolvt*< SG 31-32-796 Topo Map.pdf; SG 31-32-796 Certified As-Constructed Drawing.pdf; S mith G u lch 3 1 -32-7 96 -ti na ncia I Assu ra nce-432534 -T EP Rocky M ou ntai n LLC - Operator_96850.pdf; Smith Gulch 31-32-796_APPROVED_Form 15_Pit Permit_20130418 _400386922.pdf Patrick, Thank you again for your email and patience with my response. Regarding your questions, the Smith Gulch Completions PiI3t-32-796 is in Section 32, Township 7 South, Range 96W (please see attached map), which is zoned Resource Lands. The COGCC permit includes the attached Form 15, which will be replaced with a Form 28 permit upon COGCC approval. The best source for COGCC approval is on their website, reference Facility lD#:432534. This facility is an approved and active COGCC location. The stamped construction as-built drawing for the existing facility is also attached, and provides the measurements, volumes, and site information, as requested. I have also included the surety bond submitted to, and on file with, the COGCC. This facility had served as a remote hydraulic fracturing facility for the western Piceance assets previously owned and operated by Williams and WPX, now TEP Rocky Mountain LLC, and was planned and constructed to support remote hydraulic fracturing operat¡ons in the western field, including Trail Ridge, where most of our drilling has occurred in 2OL7.The Form 15 approved by the COGCC must be extended with a Form 28 to continue and Trail Ridge development. This facility is currently being used to support remote hydrau cturing operations on the TR 32-23-597 (Facility lD #295973, Sec. 23, T5S-R97W) pad and was used to wells on three Trail Ridge well pads, including the TR32-27- 597, TR 44-27-597, and TR 24-2L-597. Specifica s of fluid was pumped for hydraulic fracturing in August- September to support completions operations in . The Smith Gulch Completions Pit3L-32-796 is an integral part of continued remote hydraulic fracturing operat¡ons for an additional 100+ wells planned over the next few years, pending commodity prices. The use of this facility is consistent with the Garfield County LUR definition as it is operating on an approved COGCC location and used to stage materials and equipment, including storage of water, to pump produced water for hydraulic fracturing to multiple locations. Like all the completions pits operated by TEP, this facility supports centralized operations and promotes recycling of produced water. The benefits of this approach include piping water to various locations, thereby reducing traffic impacts and associated nuisance, and the ability to reuse produced water in lieu of fresh water. To complete the Form 28 approval, a statement from Garfield County has been requested confirming TEP Rocky Mountain LLC meets the Garfield County LUR definition and permitting requirements, thereby operating this facility as use-by-right. Thank you for your review of this information and please contact me with any additional questions. 1 Jeff Kirtland Regulatory Lead W: 970.263-2736 | C: 970.812.7874 TE ËN*'ì';Y ÞAÈTNåIì5 From: Patrick Waller Imailto:pwaller@garfield-county.com] Sent: Wednesday, September L3,2Ot7 11:40 AM To: Jeff Kirtland <JKirtla nd@terraep.com> Subject: Hydraulic Fracturing, Follow-up HiJeff, Glen forwarded me your request for a verification that the Smith Gulch pit meets applicable County requirements. Please provide additional information on the pit (including but not limited to location, COGCC permits, size of the impoundment, revegetation requirements or bonds, etc.) as well as a statement as to how the pit meets the definition of Hydraulic Fracturing, Remote Surface Location. That definition can be found in the Land Use and Development Code. I have included it for your reference below: Hydraulic Fracturing, Remote Surface Location. A COGCC-approved surface location used for staging materials and equipment (including storage of water in open pits and tanks)to pump hydraulic fracturing fluid to 1or more COGCC- approved well locations for the purpose of advancing the wellbore and increasing the productivity of the well through hydraulic fracturing as part of the well completion activity. Please let me know if you have any questions, Patrick Waller Senior Planner Garfíeld County Community Development Depa rtment 108 8th Street, Suite 401 Glenwood Springs, CO 8L60L (970) 945-1377 ext. 1580 pwa I le r@sa rfield-co untv.com http://www.sa rfield-co u ntv.com/com m u nitv-development/ 2 ACCESS DESCRIPTION: FROM INTERSTATE 70 EXIT 72 ROUND-ABOUT INTERSECTION 9UTHWES'T OF THE TOWN OF PARACHUTE, PROCEED IN ASOUTHWESTERLY ùRECNONALONG SATE HIGHWAY 6 & 24, T3.O MILESTO AN INTERSECTION WITH A DIRT/GRAVEL ROAD, PROCEEDRIGHTIN A NORTHERLY DIRECTIONTOTHE STI/ilTH GULCH 31-32.796 PIT LOCATION, ASSHOWN HEREON. Legend - Pad - Existing Access Road - Existing Road TEP Rocky Mountain LLC Plat 5C Smith Gulch Pit 31-32-796 Topo & Access Map Smith Gulch Pit 31-32-796 T7S R96W Section 32 T\Projects\PlC\Grandvallsy\16\0531_SGCompletionsPiLForm2S_P¡tconversion\TopoMap.mxd lvanloaî 912712017 1:54:16PM Gurfield County Community l)evelopment Department September L,2OL7 Julie Webb Progressive Consulting P.O. Box 863 Lafayette, CO 80026 RE: Hydraulic Fracturing, Remote Surface Facility Dear Mrs. Webb: This letter is being provided to you in response to your inquiry about a Hydraulic Fracturing Remote Surface Facility to be operated in Garfield County by Vanguard Operating LLC. The Garfield County Land Use and Development Code of 2O!3, as Amended lists a Hydraulic Fracturing Remote Surface Facility as either Permitted by right, or exempt from County review and standards if located in the Public Lands zone district. The Land Use Code defines such a facility a5: A COGCC-approved surface location used for staging materials and equipment (including storage of water in open pits and tanks) to pump hydraulic fracturing fluid to L or more COGCC-approved well locations for the purpose of advancing the wellbore and increasing the productivity of the well through hydraulic fracturing as part of the well completion activity. Your email from Augusl.28,2077 stated: The temporary hydraulic fracturing pit(s) will be located on approved COGCC oil and gas location(s) Miller l1D (location lD 335427), GGU MILLER FED (MDP PAD #6) (Location lD 4L69791. We will be utilizing these pits in accordance with article 15-102 definition 108 Eighth Street, Suite 401 Glenwood Springs, Colorado 8ló01 (970)e4s-8212 Hydraullc Fracturlng, Remote Sudace Locatlon. ln agreement wlth artlcle 15 we find that the operations of this location fall under the category of right by use. The location will be used for staglng materials and equipment (including storage of water in open pits and tanks) to pump hydraulic fracturing fluid to 1 or more C0GCC-approved well locations for the purpose of advancing the wellbore and increasing the productivity of the well through hydraulic fracturing as part of the well completion activity. Once the hydraulic fracturing and flow-back operations have been completed for all the wells within the current development area, the water handled by these systems will be transported either to another location for reuse or to a disposalfacility. The operations for these pits fall under rite by use. ln addition to the approved Form 2A Oil and Gas Location Assessment, Vanguard also received an approved Form 15 Pit Permit for both locations. These pits will be temporary and will be in use no more than three years per conditions of approval from the COGCC. The locations will be covered under Vanguard's COGCC Surface blanket bond, Surety lD 2014-0093. Per your representations Garfield County Community Development has determined that the proposed pits would fall under the Hydraulic Fracturing Remote Surface Facility use. That use is permitted by right in the rural zone district and is exempt from County review in the Public Lands zoning district. Please contact Garfield Community Development Department w¡th any additional questions. Sincerely, erylBower ity Development D¡rector ld Count¿ Colorado 108 Eighth Street, Suite 401 Glcnwood Springs, Colorndo 81601 (970)945-82t2 Construction Plan Prepared for:q¡¡i|I9Y wPX Enersy Rocky Mountain, LLcSMITT! G¿ILCH 3132-796 PTIAS - CO)VSIRUC?ED SITEPLAII|183'tùñ{ìø6l'P¡t CenEtN:1580910.8E:2257111.7P¡t Botton eleu= 5123.0Pit l,tetting Anêlþt Pæt(rw.)0480EE-GltMTCSCÆtNEt1&FEfEx¡st. L¡nitof Disiu,bânæSpor Eleølion @Edge of LinelB\ ,,'/.I4_**'-'ñ9-ì- _- ._ -_.>\\ r*" --f'- aÈil¡ryM IWfuMTEÞ J,l-)\ll'llllIlilIo¿tSX---4,^MæsuÊ Point &Læk DeÞction Pipes/""XSoil Stæk,teø.41sN Az. 152.94'176'238',Topln ætd PumpÉk TEdmd --X=-- IlC+:*¿'¡ I rF--¡X-¡ t-ful!!r-.Jads.o/\\þX. Jdge oÍExisting PitPìt ì'lelitu Studure5170 ' -:\ -, t' ' \\ft"-! ¡- whådlÉo \\XFie Laæ-_ s1tu -- 511?srs --\¿¿--....----¿"2\L tY6¿ ¿rDtof Dìslutùrcsr&-.--Tobl Pit Volune = t124730 bbl2'Free Board Vol.=t105230 bbl,ùq3ltt@Mt@affiffitE !ffiàfüffiú M I æt,pt l.n ltñll'r ffi ú ræ@t úñø nidè ¡æú ú yVX Epgyl tuilh Gttú t 4¿dü mi.t,ttú ø It'¡ úúrtg; ad lhtìtt.þüitvffi h@túIñúþffibtidJtu,PEg&Ðtæt,2016REWSED: 6,/ 14,/f 6Kiqqz WLLIAMS VALLEYFG ømpþtons PltEc Èm SAê Pþn.ùg Const¡uction Plan Prepared f'rr:ry w?x É'ergy Rocty riountain, LLcsMIltf cllL(xt 3131796 PIîTECAL DE,StrIëTOù'sTEÉI:PRo"JECT:DFÍ:PN)PEWY BOT]TIDARY33 PnoPEETy AOTTNDABY'(**"r'!l"ritt'\\\PN'PENTT BOTJNDARYÈËoe\Ê.EË326ù':c-.J\\ffiIW GTûLCE/LEGEND{'SG¿O B¡êss CapBLM Alþm. CapPI^SAtun. 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Itñq q til$dñæ of 61t.æ lba;theæ @úituiîg aloig &là. tþht ojt'ag li^e afog the erc of a øw þ tiE tiglú haviag a tødius of 3, 9.70 Ícâ, a diúaæ qf932.601eü (ùe drod of thie arc beæ NorTh SO'25'Of Eaú c distuß ol93O.4O fú) þ the #ixliæ 6m'@ E øior 32dad sdiú 33 of úíd tuurehìF; thzÆ Noñh 00'25 Ø" W* along stld. søion nne d ¿lituæ 4 l2æ.8OJd b thè SØionMr @mûon to Súi,Dß 2A, 29, 32 and.33 oî *id Twßlq, ø btuæ Øp ¡iMúment; tleræ tuth 88'C8'0O' tteû along lhenodheñV Iire of súíe 32, a dístunæ oÍ 2,712,70 ¡æt to the saí¿ Nú¡. 1/ 4 Mù: thqe tuuthoo"s.30' tus aiong thcnofrh..øth ñldsê(,Jo^ IIre, a dis æ of 3,a72.2O fcâ" M t lN to tu ñINî OF ffimtING-AÍDA ttud ù paæl of Iaú No. 810-RB oÍthc S.ate Dqabeú o! Hlglwars, DivlríØ oÍ HíghùagE s.øte af @btdo, ÈoJú ço, I7Õ-1(45) SeúioL 8 inthc NW1/4NW1/4 otd.thc NEL/4NW1/4, Sectuft 33, TouñEhip 7 Se44 RoÅge 96. Wbt ofahe 6Nh P.I., kGarfeld. Cøtn¡v, crlotodo, síd tmd û pdrel of land. beîry m pffiíeløly dæíbed ds fclb@^.¡0\e'irrra.s¡.I æ¡¡S SI,RI/TY I/A'9 PREPARED WTITTOUT THE BENEFIT OF A CT]RRÊN'I'TITLE æMlATluß,NTåMDOE*S /VO¡RDPRESE¡VI A TITLE SEARc.II BYPROPERTY SITOVÍN TO DETERMINE OWNERSHIP, æMPANE IUTY WM.TAD,TOINTNG PARCE¿S, OR &{S'I¡¿]E/fl OR ENfiJMBRANCES OF RÈCORDSAFFECNNGNNS PAPCEL.2J THIS COMPLETIONS PIT TS NOT I.ACATED WTTTTM A 30% *OPE AREA.3.¡ ?ft¡S Sr¡E P¿¿]VDOÀS flOf REPR&SEI\TA SOWDARY, IMPROVEMENI'ORIMPROVEME¡¡¡ LOCATION CEPNFICA?E SIJRI/aY BY BOOXCUFF SURVEYsaRØcEs, Itvc oRÁìL oFi¡sÁ.gsoc¿qrEs.AND], ÌúICHAELJ.LAND SURVEYOR, UCENSEDUNDER 7I1E I.ADO TTEREBY CERNFYWATTÍTEONTHIS DATEOCTOBER2T,I]PERWSTON ANI}THEREOF,REWSED:6/14/16FORÁIVD OJVNO.36572