HomeMy WebLinkAbout2.0 Staff Report BOCC 06.15.2015Garfield County Board of County Commissioners
Public Hearing Exhibits (Additional Exhibits shown in Red)
General Administrative Land Use Change Permit
Director's Referral to the Board of County Commissioners
Ursa Watson Ranch B Small lnjection Well (File GAPA-8224)
Applicant: Ursa Operating Company LLC
June 15,2015, Continued to June 22,2015
Exhibit #Exhibit Description
1 Public Hearing Notice lnformation Form and Attachments
2 Garfield County Land Use and Develop ment Code as amended
3 Garfield Countv Comprehensive Plan of 2030
4 Application
5 Staff Report
6 Staff Presentation
7 Referral Comments from Garfield County Consulting Engineer
8 Referral Comments from the Grand Valley fire Protection District
I Referral Comments from the Division of Water Resources
10 Referral Comments from CDPHE
11 Public Comments from Don and Barb Allred
12 Public Comments from Grand Valley Citizens Alliance
13 Referral Comments from Battlement Concerned Citizens
14 Referral Comments from Garfield County Vegetation Manager
15 Referral Comments from Garfield County Environmental Health
16 Referral Comments from Gadield County Oil and Gas Liaison
17 Public Comments received from Steve and Ann Williams (2125115 &
2127115)
18 Petition Dated 2l1Ùl15
19 Referral Comments from Colorado Parks and Wildlife (CPW)
20 Applicant Addendum to the Emergency Response Plan
21 Supplemental Staff Memorandum
22 Applicant's Power Point
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24
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EXHIBIT
1-I
Gaffield CounQ
PUBLIC HEARING NOTICE INFORMATION
Please check the appropriate boxes below based upon the notice that was conducted for your public
hearing. lnaddition,pleaseinitialontheblanklinenexttothestatementsiftheyaccuratelyreflectthe
described action.
ø My application required wr¡tten/mailed notice to adjacent property owners and mineral
owners.
r' Mailed notice was completed on the 18 day of Mav , 20L5
All owners of record within a 200 foot radius of the subject parcel were identified as
shown in the Clerk and Recorder's office at least 15 calendar days prior to sending
notice.
./ AII owners of mineral interest in the subject property were identified through records in
the Clerk and Recorder or Assessor, or through other means Iist]List from Encana's
Land Office
Please attach proof of certified, return receipt requested mailed notice
My application required Published notice
Notice was published on the day of _, 20L5
Please attach proof of publication in the Rifle Citizen Telegram.
My application required Posting of Notice.
Notice was posted on the day of _,20L5
Notice was posted so that at least one sign faced each adjacent road right of way
generally used by the public.
I testify that the above information is true and accurate.
Name: Tilda Evans
'{úá", 6,la-'***Signature
Date Mav 27.201,5
¡1, Æt¡clgAddressedto:Watson Raii.:hes, [.tdPO 8ox 383Meeker, CO 81641r Comdete iteme 1, 2, and 8. AlsocompleteItern 4 if Resûicted DdtuEry b d€siÌ€d.r Print your narþ ard adûæs on tÌ¡e reverseso that we can rcù,m the card to you.¡ Attach this card to the back of tfie rnailpiece,or on the front if spacê p€rriiF.1. Article Addressed to:Barbara Lou & Donald Max Ailred042L County Road 303Parachute, CO 91635trtr Beg¡Bþ€d trReù.¡m Beceipt f or Merchand¡secl lnsuÞd tr4a¡l trc.oÐ.4. R€sùict€d Deüyãyl (Eúatu) E yesfl Ag€ntc.D. lsfrorn ign 1?'1ìcl¡úPosramå Fæ!*Watson Ranches, LtdPO Box 383Meeker, CO 81641PodageCerüTed ËêêRetwn Boco¡Dl FÉs(Erdorsernrn ne{ulreO)Êesù¡ded DôllvaÌy F6o(Endoßonônt ÍlequirÐd)El AgenrYesEruooll¡rlm14ruEgr!ruË¡ruE3tftrtc3rjltr¡rurlc¡rrtPætagqC€ífi€d FeéRgtún Rocôiot Fse(EtdorËsmsnt Bêriu¡rsd)Restrlct€d D€||reru Fm(Endo߀ment Beqú{rd}.483.302.700.003. Sepdc€fypeÚCerdfieo uaflÈoîPAfrrnl¡lrurOrrruEIru13EItr¡[3r:ltr¡-1rur{Efioflf YES, enterdel¡veryaddrcss bdow: .F l¡o3. SryvbeTypedGertified Ma¡l 0 gxpress l'¡a¡lElnegbtsed EReh¡mReceiptforMerchandiseE lnslr€dtvlâll El C.O,O.4. Ræþioted Dúv*y? (ExbaFæ)tl vesl,Blt IEUE U¿?å e55ITold ñ*_^ ' kÉeBarbara Lou & Donald Max Allred0421 County Road 303Parachute, CO 81635,¡ r", Posl¡r¡ark*.¿rr rlÞr\. "__l--,]ñ2F!tåtrt?ea'{FNàaàU.S. Postal Service,*CERTIFIED MAIL.,, RECEIPT(Ðomestic Mail Qnly; No lnsuranceCoverage Provided)þ¡*rsÆ$*$*Ëq"øÅLFor delivery inlormål¡onvlsil ouÍ webs¡te atWWW,UspS,Com{,A.lfYES, entorD. lsd¡rr€ryB. Fæehr€d by I prtn& NanatE(t n l.lhfÅi!,r7"df5åICOMPL¿|È TH,S SËC]'iar,.,¡ Ctu r)E-ir L- ?ySENDER: COMPLETE THls sECT/o,Ví.:_:l,lanþ)COÍTIPLETE THIS SECI/ON ON DELIVERYÏHlS SFCT'ONU.S. Postal Service,,CERTIFIED MAIL,., RECEIPT(Ðomestic Mail Only; Na lnsurance Coverage prov¡ded)sÇilFFåå&t$sffiFot¡ntormationv¡sit our websile at wwv{.usps.coml:'.FB Form 38'l'1; feOruary aOOq Domestb Retum R€c€ipt-f :îTe û:) ÍUOI-r-3Nnr üN\/èls¡lû259$O2-M-1540 ¡
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B.A.xCOMPLETE TH|S SECT ON ON DELIVERYSENDER: COMPLETE rHiS SE'CI',ONr Complete lterts 1 , 2, arrl 3. Also cornpleteitem 4lf R€süicted Ddivery is dq¡ifed.r Print your name ard acklrcss on the r€\r€tseso that w€ can ret¡m th€ catd to you.r Aþch this ca¡d to tf¡e back of the ma¡lpiec€,or on lhefront lf space Pørnits.c.otrLmr\ÊorrruEIruE:IT3t:Uc¡1{rur-lÊtrLfrqn itêrn 1?MarkE&DanielRGardner134 €ounty Road 303Parachute, CO 81635-9204r Complete items 1, 2, and 3. Abo compþteitem 4 lf Fætric'ted Ddivery ls deslrcd.I Pr¡nt your name md addtes on thô r€\relseso that we can r€tum the card to yot¡.I Attash this catd to thg back of the mailpiece'or on the front if space Permits.1. ArticþAddressedto:1. Art¡clê Addressêd to:Sharon l Gardner1236 County Road 302Parachute, CO 81b3Su&-ô¡UcsNumbsrctelivery address betow: :tr| tlo3. Sqv¡oeTypEdC"nrin"O¡r"¡l tr ÞtpræMailtrne$sterea [JnaurnRecetptforM€rchand¡sêE lnsr¡ßd Mail tl C.O.D.4. Restricted D€lbtæl?- Wa tu)trl YesMarkE&DanielRGardner134 County Road 303Parachute, CO 81635-9204Fostag€Csd¡ff€d F€sR€ùJm RscslptF€6(En(brs€m€nl Ël€qL{rêd)Rsslrf*sd lt€Sv€ryFse(Endor¡emsnl Bequ¡rsd)TâtãlÞdâñÊ Fâm$.483.302.700.00*.483.302.70tlÈA SignaùÍ€x5E Agentof71YesE t¡oE ln$¡d M¿dl tl c,o.D.4. ResülcìedDeliue,.y'| @*af€p,¡ '*' [fvesu1,B ItU0e Be?ð t+?r.ltlC. Dâ¡e3-if,rLJEOr!ruË:D, ls ddiv€ry addt€ss dlfbent fiom itsn 'l?It YES, enter del¡very address below:Pogtag€Coiltl¡ed F€eRãtim RêcêlotFô6(Endorsement Heduired)t3 ÊÀsùtctêdD€fiv€trFescf GrdonernentReqrlred)$rugtETrlE¡rjlP.ôsqmÍkHe¡orur{E¡rL¿F!iæ¡rìcr{Fr\ràdà3. S€nþeTyp€dc*mæ¡,r"¡r tr E¡<,r€ssMailElRegbi€r€d ERe¡rnRece¡ptforMorchañdise0.00lbtdP¡s*ÂçæcSharon I Gardner1236 County Road 302Parachute, CO 81635tJIPtSlUr¡hmÞn¡*d¡deÆÏ3811, reuruary zoo¿DorEstic R€tr¡m ReceiptU.S. Postal Service,,,,CERTIFIED MAIL,." RËCEIPT(Dameslic Mait Only; No lnsurance Coverage Provided)fÞffiffiã&t &Jinfo¡mãt¡on visil our w€bsite ãt wu¡r^,Forlnstrucl¡onsB. Raceived by I tutntect Nanø)COMPLETE THIS SECI/O¡,, ON DELIVERYSENDER: CAMPLETE THJS SECÏ,ONU.S. Postal Service,,CERTIF¡ED MAIL,,, RECEIPT(Domest¡c Mail Only; Na lnsurance Coverage Provided)#FWnffig&tu ffifi*inlormÊtion visit our website at wy,rw.usps.comoForcTo ¿Êrf1 Àl¡ñrT I â[1.^rl- 1--':lÀlltqt\lsrt025ssæ-M-1ilOot
ACAMPL'Ei'E r,-//S SÊùI/ûN O¡! ûELrVÈRySENDER: CAM\LETE THts SECT]}NI Completo ttems 1,Also cornplete2, ard 3.Deliveryitem 4 it Rætictedls desired.t Print your nameand addresson the fÞverseso that we can retum thecard toyou.r Attach this €ld to the back ofthemailpiec€,or on the fiont lf spacg pennlts.1. Art¡clg Address€d to:Ellen 6ibson3405 E t28th ptaccThornton, CO 902412. Atlcle Numbr(lrarlsferfran seúæleÉrl)? Bl,e_, PS Form 381 1, feoruary zoo+tl Rsgister€d E R*um Recelptfor MercharutiseE lnsur€d ùefl E C.O.D.ITYES,addr€ssO. ls &livery dess df€r€ntftdn iþrn 1?It YES, ent€r ddiwry arlÛess bdow:Pqstãg€$Cðrl¡l¡sd FeâruEt Retumnece¡ûrFsoE (Er¡(þß6nEilReddrÊd)trl R€irùtcted Dêfh,€rv Foo!f (EndorcementR€qi¡ûed)rìff 1@lFosltâm8 FAærl*D.ddiverytr AgêntC. Date ot1?YEsENornrLÍEt¡fLrutr¡sF?üsb3. Se¡t¡ceTypedceruneo ualrE Ergr€ssMail4 Resùlcte<t DetivæÍ? (&a Fee)E Yes101,n BIIBe [E?st{?51,OonÞstic Reùlm Fêcelpt102595{2-M-1540E egentcfDelivervz,i-l.483.302.700.00.(íî-,".,'42;;..:,", ' .Poatmark ' :'-. HEt€:::rur{ctrLCen¡fiec, FeeruEt Reù¡mRodrlFaË¡ (Endonornentneduled)Of¿Ellen Gibson3405 E 128th PlaceThornton, CO 8024fPßbgê$çÀr Comolets ltems 1,2, and 3' Also completettem ì ¡t RestÌicted Delivery is desircd.t Print vouf name ard address on the twerseso thå we can retum the card to You.r Attach this card to the back ol the mailplece,or on the front if sPac€ Pemits.cOJIfLJEOr!ruc3[3ctEIru11tr¡rLÀx-lYesE¡ No.483.302.701. Art¡cloAddrsssðdto:Steven C Leuallen0318 County Road 303Parachute, co 81635R€sbicþd D€[vew Fsa{Endors€menl RgqúirÊd}0.00?¡l¿l P¡*tam & FcæsSteven C Leuallen0318 County Road 303Parachute, CO 816353. SenticeTypedC.tüfi"¿ ttt ¡l EI exPress uaitCl R€glst€r€d El Ret¡mtf lner€d Ma¡l tr C'O'D.Receipt for Merc.handise4. R€süH€dDel¡v€rfi(þùaFæ) EYesle l,nlE Buu¡ 0,e?å 'r?h8Pætnart . :tl€rÞLÀ¡\ç6Irlcêll\ôlàúzNumber,PS Form 381 1, re¡ruary zoøDorn6tlc R€ü,ûn BeceiptU.S. Postal Service."CERTIFIED MAIL.,, RECEIPT(Domestic Mail Only; No lnsurcnce Coverage provided)Wfl*ü&L [$ffiintormal¡on vi9¡t our webs¡te atForby(mnfudî'lana)B.COMPLETE TH'S SEC?-IOIV ON ÐELIVERYSENDER: CAMPLETE TH,S SECI/ONU.S. Postal Service,"CERTIFIED MAIL,." RECEIPT(Domestic Mail 0nly; No lnsuranceProvìded)ffiFtrfif&kt$sffiFor deliveryinfor¡nalion v¡sit out websitè at w!vw.10259*@+riaFl{,ol
COMPLETE THIS SECT'OA/ ON DELIVERYSENDER: COMPLETE THIS SECflO/Vr Complete ¡terns 1, 2, and 3. Also completeItem 4lf Resùicted Dellvery ls Gired.I Print your nar¡e ald address on ttre rcverseso that we can retum the cafd toyou.r Aüach tfris cald to tho baDk of üo ma¡lpiece,or on the ftont lfspace pernlts.1, Article Addressed to:Scott & Lauralee C patton1697 W 2450 NVernal, UT 84078r Cornpþto iterns 1, 2, and 3. Also complet€Item 4 f R€sùist€d Ddtuery b d€€Srcd'' r Pdntyour narflêand'ad&æs on the reverseso thd we can retum the catd to You.a Attach this card to lfiê back of the mallplece,or on the f¡ont if sFce ærmlts.1. ArtbleAddressedto:Brian 5 Trani60 County Road 303Parachute, CO 81635D. lsdetvery adûess difuentfiorr iHn 1?lf YES, enter ctellvery ddrcss belo¡tr:r.flr!r!il'EOrlruf3Atl es"ttAdd¡esseeC. Date of DeliveryPoûbgt€s.483.302.700.00.¡'.1 ..'.- , :' :.:::p. ^-e: .'?E ttoCêilltlsd FssruEl Rótuln R€c€iptFesEl (Endorsern€ntR€qúr€d)EResù1cléd DåWsry FêsE (ÉÉorsement Re$.*ed)rqtr¡r?F9S.tîark,ilere,t' , a,;':..- -*1.'. ÿ "'\peir¡í*Hêr€'Ðli,:63" SepbsflpedGerr¡AeO Udl tl Éeræs Maùltr RegistqÊd E R€ù¡m Ræ¡pt for MêrchandlseEl kt$rd lvlail E C.O.D.L S€wlcgTlpodceninetllua¡r E F¡pl$MalltlR€$sM EIR€tumR€cè¡ptforM€rchandls€*Scott & Lauralee C Patton1697 W 24s0 NVernal, UT 84078r .483.302.700.00TOþlFdâm*Fa6*Brian S Traniot P(60 County Road 303orruFIE¡rr4. Restlcted Deliroq¡? (fua Fæ)trl ves2. Article NumberÍrâtæfüîrort srrlt'løeM)?Bl,e lElU UUEÊ ne?B q??5PS Form, February 2()4Domes{b Retum R€ceipt10ffi.M-1540t?¡ÈAD, ls deliv€ry address diM frør¡ ibm 1?lf Y-ES, enter ctelivery address below:E ngentfl ¡¿oresseeC. CHe of Delivery.zt -/TY6ENorucOrrJEOÍrrutr¡ruE¡ctEEBrurltrtruPostag6oeilflsd FoeRetrm Fecoltt Foê(Endorsement Reqdfg<f)Êe€ùlcùBd DÊl¡v€rv Foo(Erdofsemênl B8qülf€d)C¡ lnsur€d Mail E¡ C.o.D.4, R€sùict€d Deli¡tøt\Í? (WÊ Fæ)tf YesArticlo Numberr.1ri,å19+e 181,0 Bt¡Ea ne?å t{?ðef 7-rå,si# fr¿t tdn 6þ làËË.lpS form 381 1, feUr.rary 2m4 Domestic Retum Recelpú' {;T{¡ dn-t !t!f.-:.I l:'llill"[f ftßl\rfanfr10259+02-i#r540,4,2Fttæq)ctêlFñrt2U.S. Postal Service',.CERTIFIED MAIL,' RECEIPT(Domestic Mail Only; No Insurance Coverage Provided)FptÞ*For delivery lnformalion visit our websile atA R€cêlv€d bV I Pdnted Nante)COMPLETE fH'S SECT'/OA/ ON ÐELIVÉRYSENDER: COMPLETE TH¡S SECr/ONU.S. Postal Service,,CERTIFIED MAIL,., RECEIPTMail Qnly: No lnsurance Coverage Provided)PSFFffRË&¡&*þinformation v¡s¡t our webs¡te ât www,usps,comr!ForParachute, CO 81635
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EXHIBIT
I
REQ UEST
RTY OWN
APPLICANT
ASSESSOR'S PARCEL #
PROPERTY SIZE
LOCATION
ACCESS
EXISTING ZONING
Director Referral to BOCC
June 15,2015
GAPA-8224
General Administrative Land Use Change
Permit for a Small lnjection Well Facility
Watson Ranches LTD
Ursa Operating Company LLC
2407-173-00-129
The facility will be located on a 6.43 acre site
within an approximately 43 acre overall parcel.
The property is located approximately 1.5
miles south of Battlement Mesa off of County
Road 303 (also known as Gardner Lane). The
site is located in the SEy4 SWy4, Section 17,
T7S, R95W.
The facility is accessed by private roadways
off of County Road 303.
The property is zoned (R) Rural
PROJECT INFORMATION AND STAFF COMMENTS
I. GENERAL PROJECT DESCRIPTION
The Applicant is requesting an Administrative Land Use Change Permit for a Small
lnjection Well, with less than 5,000 bbls of production water storage. The facility will be
located on an existing COGCC approved well pad. lt will be subject to approval by the
Colorado Oil and Gas Conservation Commission (COGCC) including Forms 31 and 33
for injection wells. These forms typically deal with the suitability of a well for injection
and address characteristics of the formation it is being injected into, maximum pressure
gradients, limits on volume, and related requirements for construction of the injection
well. COGCC Form 26 is also required to address the source of the produced water to
be handled by the injection well.
The proposed facility is known as the Ursa Watson Ranch B lnjection Well and will be
utilized for disposal of water classified as exploration and production (E&P) Waste from
L
Ursa Operating Company gas production facilities in the vicinity of the site. Equipment
associated with the facility will include:
. One injection well.
o Storage Tank Battery (6 tanks) with a total of 18OO bbls of water storage directly
associated with the injection well.
o Two Combusters and a Valve Set.
. Electric pump building a maximum of 20 ft. x 50 ft. in size.
. Associated piping and equipment for off loading water at the site.
o Containment for Tank Battery and a containment berm for the overall site.
Produced'water from local Ursa facilities will be transported to the site by truck and by
pipeline. Several Ursa wells in the area that will be serued by the facility are already
connected by pipeline. Traffic generation projections and a Traffic Analysis have been
provided which include the proposed hauling routes.
A dust mitigation plan will be implemented for the site and Colorado Department of
Public Health and Environment (CDPHE) Air Quality permits will be obtained if required
(may be required for the storage tanks). A Storm Water Management Plan has been
prepared with storm water management improvements and Best Management
2
Practices already implemented and/or planned for the site. The Application also
includes a Spill Prevention Control and Countermeasures Plan (SPCC), Grading and
Drainage Plans, Noxious Weed Management Plan, and Reclamation Plans.
Monitoring, alarm, and remote shut down controls are planned for the facility and
include the following:
o Bradenhead Pressure Alarms. Wireless Casing Pressure MonitorÆransmitter. Wireless Tubing Pressure Monitor/Transmitter. Remote Shutdown Controls. Programmable Logic Controls on Pumps that monitor pump package and
pressures. Low Oil Level alarms on pumps.. High and low tank alarms.. Flow rate monitors for maximum daily pressure/volume.
The injection water storage and the overall tank storage on the site is less than the
maximum 5,000 bbls for a small injection well site. The site is covered by a bond for
reclamation and a copy of the bond was included with the Application. A Geologic and
Natural Hazards Repoft was included in the Application, The Report was expanded to
include a section specifically on Seismic Hazards and lnjection Wells.
3
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II. LOCATION - SITE DESCRIPTION
The site is currently a developed COGCC well pad with 13 existing wells and the
proposed injection well. Land uses within 1,500 ft. include agricultural uses, residential
and ranching uses, natural gas extraction and pipelines, and areas within the
Battlement Mesa PUD zoned Low Density Residential. The nearest residential home
is approximately 1,000 ft. from the noise generating pump building.
The site slopes up moderately to the south and has previously been graded and
leveled for the well pad. The Watson Ranch A Well Pad is located immediately noñh
of and adjacent to the Watson Ranch B Pad. Much of the native vegetation has been
removed for agricultural purposes and the current oil and gas operations. Native
vegetation that does exist on the site is generally sagebrush, with some pinion and
juniper woodlands. No additional native vegetation will be removed for the proposed
facility and the placement of the project on an existing well pad will minimize additional
impacts. While drainage swales and irrigation ditches are located near the site no live
streams are in close proximity to the site.
4
Watson Ranch A Site
III. PUBLIC COMMENTS AND REFFERAL AGENCY COMMENTS
Public Notice was provided for the Director's Decision in accordance with the Garfield
County Land Use and Development Code as amended. Notice included mailing notice
to all property owners within 200 ft. and any mineral rights owners on the property.
The Applicant has provided evidence of compliance with the notice requirements.
Comments from referral agencies, County Departments, and the public are
summarized below and attached as Exhibits.
1. Garfield County Consulting Engineer, Chris Hale, Mountain Cross Engineering:o That site specific information on the facility be included in the SPCC Plano All COGCC Permits should be a condition of approval,o Routing and easements for electrical power should be addressed.o Additional information on the pump house design should be provided.
2. Grand Valley Fire Protection District, Rob Ferguson Deputy Fire Chief:o Noted seveâl corrections needed to the Emergency Response Plan
5
3. Colorado Division of Water Resources, lvan Franco, Water Resources Engineer:
. Responded by email indicating that they had no comments.
4. CDPHE, James Dileo, Air Pollution Control Division:
o Provided general information on the CDPHE permitting requirements
5. Don and Barb Allred, adjacent property owners:
. Expressed concerns including property value loss, injection fluid flowing under a
part of their property without their consent, and loss of 1/3 of their propefty to
drill for water due to the location of the gas wells.
6. Grand Valley Citizens Alliance, Leslie Robinson Chair:
. ldentified issues including air quality, potential for spills and seeps, earthquake
hazards, affects on real estate values, and creating a precedent for future multi-
well development close to residential areas.
7. Battlement Concerned Citizens, Dave Devanney, Chair and Doug Saxton, Director:
. Noted concerns regarding the number of injections wells near Battlement Mesa.
. Noted concerns associated with earthquakes and fire/lightning strike potential.
. Recommended seismic testing and installation of a seismic monitoring station.
. Expressed concerns regarding future impacts.
8. Garfield County Vegetation Manager, Steve Anthony:. Commented that the Weed Inventory and Management Plan is acceptable and
requested treatment for weeds be completed prior to June 30, 2015.
g. Garfield County Environmental Health: Morgan Hill, Environmental Health
o Noted the potential need for redundant storage.
o Proximity to occupied structures and potential for nuisance issues.
o Potential for seismic activity and the need for monitoring.
o Air Quality Permitting requirements.. SWMP and SPCC Plans and protection of nearby drainages.
10. Gadield County Oil and Gas Liaison, Kirby Wynn:
. Provided information on topics including public outreach, status of citizen
appeals to COGCC, the COGCC lnjection Well Permit process, induced
seismicity, and mapping of injection wells in the vicinity of Battlement Mesa.
11. Additional Public Comments received prior to scheduling of the Board Hearing:
. Email correspondence from Steve and Ann Williams expressed a variety of
concerns including impacts on homes and domestic water wells.
6
. A petition was generated and signed by Neighboring Affected Families
indicating concerns for water, air, immediate safety and property values,
IV. STAFF COMMENTS AND ANALYSIS
The Applicant has provided detailed responses to the Submittal Requirements and
applicable sections of Article 7, Divisions 1, 2, and 3, including Section 7-1001
lndustrial Use Standards.
1-1 Zo ulations P n&atibil
The proposed use demonstrates general conformance with applicable Zone District
provisions contained in the Land Use and Development Code and in particular Afticle 3
standards for the Rural Zone District.
The Comprehensive Plan 2030 designates the site as RMH (Residential Medium High
Density), Excerpts from the Land Use Description Section Chapter 2 and Section 8,
Natural Resources and Section 9, Mineral Extraction are provided below.
Chapter 2 - Land Use Designations
Residentiat Medium High (RMH): Small farms, estates, and clustered
residentiat subdivision; density determined by degree of clustering and
Iand preserued in open condition.
Sectíon 8 - Natural Resources
lssues
*The county maintains high air quality standards, however there may be a
propensity for air pollutants to exist in the western part of the county
Goalsl. Ensure that natural, scenic, ecological, and critical wildlife habitat
resources are protected and /or impacts mitigated.
4. Ensure the appropriate reclamation of land after extraction
processes.
Policies1. The County will encourage and cooperate with the protection of
criticat habitat including state and federally protected, threatened, or
endangered species.
7
Section 9 - Mineral Extraction
Goalsl. Ensure that mineral extraction is regulated appropriately to promote
responsibte development and provide benefit to the general public.
2. Ensure that mineral extraction actívities mitigate their effects on the
natural environment, including air quality, water quality, wildlife habitat or
important visual resou rces.
S. In working with mineral extraction projects, the county will protect the
pubtic health, safety and welfare of its citizens.
Policies2. Mineral resource extraction activitíes will protect critical wildlife
habitat as identified by state and federal agencies. Development within
these designations that cannot be designed, constructed and conducted
sa as to have a minimum adverse impact upon such habítat or these
wildlife species shall be discouraged.
4. Facilities that are appurtenances to oil/ gas development activities
(compressors, etc.) are considered appropriate in all land uses so long as
they meet the respective mitigation requirements of the LUDC to maintain
compatibility with surrounding land uses.
3f,7 Watson Ranch B Site
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Comprehensive Plan Future
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The proposed facility is in general conformance with the Comprehensive Plan Policies
subject to proper mitigation of impacts. The Application has provided information on
neighboring land uses representing the position that the use is compatible with the
general character of the area. Public input and comment letters also address
compatibility.
7-104 & 105: Source of W er & Waste Water Svstems
The Application represents that the facilities will operate with only occasional staff
activities. The proposal demonstrates that the uses will be adequately served by
provision of water in individual staff vehicles and provision of poftable toilets on site per
OSHA standards. The Application also includes extensive documentation that the
water for injection is from nontributary sources.
7-106: Public Utilities
The site will be served with electricity to be provided by Holy Cross Energy for the
operation of the electric pump for the injection well. Holy Cross Energy has provided a
will serve letter and the Applicant's Surface Use Agreement allows for the extension of
electric lines to the site.
7-107 & Roadwavs
The applicant has provided a detailed analysis of the haul routes (including County
Roads) and the access roadway to the site. The Access Roadway reflects compliance
with the County's Roadway Standards as contained in Table 7-107 with the exception
of cross section details for shoulders and ditches and right-of-way provisions.
The Traffic Study identifies the truck traffic associated with the hauling of water to the
site from several Ursa well pads. The Traffic Study estimates the traffic generation will
result in only minor increases in traffic volume. The study also indicates that
intersections on the haul route are adequate and noted no deficiencies.
7-108: Natural Hazards
The Application provides significant information on natural hazards includíng
information on soils, geology, and seismicity. The information supports a determination
that the proposed use is not subject to significant natural hazard risks.
7-1O9: Fire Protectio n
The Application includes an Emergency Response Plan for the site that includes
notification procedures for the Grand Valley Fire Protection Distríct. The District
receíved a referral packet and provided comments. The plan includes details regarding
9
mitigation for wildland fire potential. The only structure proposed for the facility is the
electric pump building which is represented to include fire resistive roofing materials.
7-201: Aqri ural Lands
With no new disturbed areas no additional impacts on nearby agricultural lands are
anticipated. The well pad will be fenced if warranted to allow grazing on the site.
7-202: Wildlife Habitat Areas
The Applicant has provided an Environmental lmpact Report, completed by WestWater
Engineering, dated December 2014 addressing potential impacts on wildlife and
vegetation. The report indicates that the site is unlikely to provide suitable habitat for
any special status plant species in this region. The report also addressed endangered
fish species, raptors and other native wildlife. The report states, "Development of this
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L0
project will result in additional contribution to the cumulative effects of habitat alteration
and fragmentation in the region, although development of the project is not expected to
significantly affect any critical environmental resources." The Application includes a
variety of mitigation strategies íncluding the use of bird cones to prevent perching. The
Applicant has confirmed that the site is covered by the Battlement Mesa Wildlife
Mitigation Plan - Agreement between Ursa Operating Company and CPW which
addresses mitigation for wildlife impacts.
7-203: Protection of Water Bodies
Potential impacts on water bodies has been addressed by the Storm Water
Management Plan (permit), drainage plans, and Spill Prevention Containment and
Countermeasures Plans for the site. Only intermittent streams or drainages are
located near the site along with irrigation ditches.
7-204: Drainage and Erosion (Stormwater)
The Applicant has provided a copy of the State Storm Water Management Permit and
Plans and Best Management Practices for the site. The drainage report concludes that
no detention is required for the site, however temporary features such as sediment
traps, straw bale barriers, sediment control logs, and inlet protection are included in the
plans.
7-2O5 Environmental C)ualitv
Air quality permits from CDPHE associated with the injection well are not anticipated
basedon the use of an electric pump. Water storage tank batteries may however
require permits. Recommended conditions of approval should require compliance with
CDPHE permitting requirements. Compliance with Storm Water Management Permits,
installation of Best Management Practices, SPCC Plans, and Reclamation and Erosion
Control Plans addresses protection of water quality. Compliance with all COGCC
Permitting requirements and conditions is also an essential component of ensuring
environmental issues are addressed.
7-206: Wildfire Hazards
The Emergency Response Plan includes a detailed section on Wildland Fire
P revention and lÉesponse.
7-207 Natural and Geolooic Hazards
The Geologic Hazard Report addresses a broad range of potential hazards including
landside, rock fall, soils, alluvial fans and slopes. No significant hazards to the
proposed facility were noted in the report and the site is not located within a flood plain.
LL
7-208: Reclamation
The Applicant has included a reclamation plan that addresses re-vegetation and
reclamation issues. A reclamation bond with the State is currently in place and shall be
maintained to include well pad reclamation associated with the injection well facility.
7-301 & 302: Compatible Desiqn. Parkinq, and Loading
The proposed use is consistent with and compatible with typical oil and gas exploration
and production activities. Large areas of the site plan are available for parking,
circulation, and loading activities.
7-303: Landscapinq
As an industrial use landscaping submittals and standards are not applicable to the
proposal.
7-304 Liqhtinq
Any lighting shall be required to meet the County standards for being down directed,
shielded, and oriented toward the interior of the site. Lighting should be available for
occasional nighttime activities and the Application further indicates that uses that do
generate impacts within the established standards will occur between the hours of 7:00
a.m. and 6:00 p.m., Monday through Saturday.
7-305 Snow Storaqe
Adequate portions of the site plan are available for snow storage and can be
accommodated by the drainage and storm water'management plans.
7-306 Trails
Trails standards are generally not applicable based on the industrial nature of the
proposal and surrounding uses.
7-1001 INDUSTRIAL USE STANDARDS
The Application represents that the facility will comply with all the lndustrial Use
Standards contained in Section 7-1001 .
. The Application reflects that all setback requirements are being met.o The facility is currently visually screened along the north, east and west pottions of
the well pad by a sound buffering installation. Once drilling activities are completed
the existing buffer will be removed.
12
a Hours of operation for the injection well pump are effectively 24 hours a day.
However,other support activities are represented to occur between 7:00 a.m. and
6:00 p,m. Monday through Saturday,
All industrial products and wastes will be stored in accordance with all applicable
state and federal regulations.
The Applicant's noise analysis estimates that the facility will comply with noise
standards. Should additional pumping facilities be utilized on the site in association
with the injection well they should also maintain compliance. Ongoing compliance
with the noise standard shall be required including once the noise mitigation barrier
is removed after the completion of drilling activities.
No other nuisance or ground vibration hazards are anticipated based on type of
use.
V. ADDITIONAL STAFF ANALYSIS
1. Future pipelines to serve the injection well are encouraged as a means to further
reduce traffic impacts, Any future pipelines will need to comply with the County's
permitting requirements or be determined to be exempt. The Application includes
Permits for several exempt pipelines already installed to serve the facility.
2. Referral comments and attachments from the County's Oil and Gas Liaison
address concerns regarding the potential for induced seismicity and the COGCC
procedures for dealing with the safety of injection wells. Compliance with COGCC
permits and form requirements should be included as a condition of approval.
VI. SUGGESTED FINDINGS
a
a
o
1.
Board.
That proper public notice was provided as required for the hearing before the
2. The hearing before the Board was extensive and complete, that all pertinent
facts, matters and issues were submitted and that all interested parties were heard at a
the meeting.
3. For the above stated and other reasons, the proposed Land Use Change Permit
for the Ursa Watson Ranch B Injection Well is in the best interest of the health, safety,
convenience, order, prosperity and welfare of the citizens of Garfield County.
4. That with the adoption of conditions, the application is in general conformance
with the 2030 Comprehensive Plan, as amended.
5. That with the adoptions of conditions and the granting of a waiver from the
Roadway Standards contain in Section 7-107 regarding road cross section including
right-of-way, shoulders and ditches, the application has adequately met the
requirements of the Code,
13
VII. RECOMMENDATION
The following recommended conditions of approval are provided for consideration by
the Board of County Commissioners for approval of the Land Use Change Permit
request for the Watson Ranch B, lnjection Well.
1. That all representations made by the Applicant in the application shall be
conditions of approval unless specifically altered by the conditions of approval of the
Board.
2. That the Ursa Watson Ranch B lnjection Well shall be operated in accordance
with all applicable Federal, State and local regulations governing the operation of this
type of facility.
3. Prior to issuance of the Land Use Change Permit, the Applicant shall provide
updated information on the pump house structure to address referral comments from
the County's Consulting Engineer, Chris Hale dated 614115. The Applicant shall apply
for building permits for the structure as required by the County Building Department.
4. Prior to the issuance of the Land Use Change Permit the Applicant shall provide
site specific details in an update or addendum to the SPCC Plan addressing site
specific details for the Watson Ranch B síte. The Applicant shall comply with all SPCC
Plan provisions and shall keep the plan current and updated for any changes to the
facility.
5. Prior to the issuance of the Land Use Change Permit, the Applicant shall update
the Emergency Response Plan in conformance with the referral comments from the
Grand Valley Fire Protection District, dated 512012015. A copy of the updated plan
shall be provided to the County.
6. The facility shall maintain compliance with CDPHE Storm Water Management
Permits, Drainage and Grading Plans, and Reclamation and Erosion Control Plans for
the site.
7. The Applicant shall maintain all required COGCC permits and forms for the
facility and shall comply with all conditions or requirements of said permits and forms.
Copies of COGCC documentation shall be provided to the County once issued.
8. The facility including all pumps shall maintain compliance with COGCC Noise
Standards/Regulations and the facility shall be required to utilize an electric injection
pump as represented.
9. The facility shall have only temporary lighting for unscheduled night time
maintenance. All lighting shall comply with Section 7-304, Lighting Standards, with all
14
lighting to be directed inward and doward toward the interior of the site. Facilities and
storage tanks shall be painted a non-glare neutral color to lessen any visual impacts.
10. The Applicant shall maintain all required CDPHE permits for the facility including
any applicable air quality APEN permits.
11. The Applicant shall comply with the Battlement Mesa Wildlife Mitigation Plan -
Agreement between Ursa Operating Company and CPW including any wildlife
protection or mitigation requirements.
12. The Applicant shall comply with the Section 7-107 Road Assessment and the
Traffic Report including use of designated haul routes and compliance with the traffic
generation estimates. The daily trucking estimates may be applied based on a weekly
average to account for minor operational variations. Trucking of water to the site shall
utilize watertight tanks and shall comply with all COGCC or CDOT requirements for
hauling of production water.
1g. A copy of the existing driveway access permit #GRBO9-D-40 from the County
shall be provided and included in the Applicant's File. Compliance with all conditions of
the permit shall be required.
14. The Applicant shall provide evidence that the relocation of irrigations ditches
necessary for construction of the injection well site have been approved and/or
accepted by the affected ditch company.
1S. The Applicant shall comply with the Noxious Weed Management Plan and shall
complete treatment of weeds identified in the weed inventory prior to June 30, 2015.
15
VIEWS OF THE SITE
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Current Re-vegetation and
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View of the Speakman A
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as the Watson Ranch B Site
19
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5qrya*Ekr)5eisnrÍc IEsuesHIncluded with the Board's Packet is a summary memo and attachmentsfrom the Counly Oil and Gas Liaison, Kirby \A/ynn addressing seismicpotential from ihjection wells.The memo includes an analvsis of the issue bv COGCC and mappins ofinjection wells in the vicinity of Battlement Mesa and the Towtr'o'f <)Parachute.EEall
lrF¡tËnenÊTRÛËl$ITFX EHERßV RON¡{YmILLc05_04sü?ã0þx auemv Esexy $öuHï{tH Lt"cßå.0,15-{srüs3wfll( EiG.FGY Rçü(V l¡|ü{Í.lTËtFl tLçC¡+lSldt$SrÊ¡ãçrfrrÊx ËllËRÕYÛ$fFH E!IER'3Yl¡1|ãtsrn F UICUrsaAr{oËtE EIGRSï WClF.$¡lã-f g68S*EiüFGY tltËt$mt15147*Itl0Ðl€, EilERSY IHCS'5'Û4s.1fl7ßûLtcsss.i+.184ês
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5 u gges tecl FÍrr dir1g51.ffirgiflåîf#hiic notice was provided as required for the hearing2The hearine before the Board was extensive and complete, that allpertinent fícts, matters and issues were submitted and that all interestedþarties were heard at a the meeting.3For the above stated and other reasons, the proposed Land Use ChangePermit for the lJrsa Watson Ranch B Injecti<jn Well is in the best interestof the health, safety, convenience, order, prosperity and welfare of thecitizens of Garfield County.4That with the adoption of conditions, the application is in generalconformance with the 2030 Comprehensive Plan, as amended.5of a waiver lromroad crossapplication
Ca ¡:dí tia r"'t sCo ntÍrr uedThe facility shall maintain complianceManagemênt Permits, Drainagè and GErosioîn Control Plans for the site.with CDPHE Storm Waterrading Plans, and Reclamation and9The Anr:licant shall maintain all required COGCC permits and forms forthe taiifitv and shall complv with afi cotrditions or requrrements of saidpermits aird forms. Copiès"of COGCC documentation shall be provided toihe Countv once issued."/The facilitv including all pumps shall maintain compliance rn'ith COGCClrloise Standards/Regulationiancl the facility shall be required to utilize anelectric injection pump as represented.The facility shall hav_e only temporary lighti^g for unschedule{ +Sht timemaintenarice. AII liehtine shall'complv ilritn Section 7-304, LightingStandards, with all Iightiñg to be dirècled inward and downwãrd tówardthe interior of the site. F'acìlities and storage tanks shall be painted a non-glare neutral color to lessen any visual imþacts.The Applicant shall maintain all required CDPHE permits for the facilityincludåg at'ty applicable air qualitri APEI\.10.
Cm rr c[ Ít:io n s Co n I"irr uec[11.The Arrplicant shall complv with the Battlement Mesa Wildlife MitisationPlan -l{greement betweön'Ursu Operating Companv and CPW inclirdingany wildlife protection or mitigatiðn requremerits.The Applicant shall complv with the Section 7-107 Road Assessment andthe Tråt'fic Report includinþ use of designated haul routes and compliancewith the trafff g*t',eration éstimates. The daily trucking estimales may beapplied based on a weekly average to account-for minor operationalväiiations. Trucking of water to [he site shall utilize watertight tanks andshall comply with all COGCC or CDOT requirements for hauling ofproduction water.A copv of the existine drivewav access permit #GRB09-D-40 from theCouñíy shall be provïded and lncluded'in the Applicant's File. Compliancewith all condifiohs of the permit shall be requiredThe Applicant shall provide evidence that the relocation of irrisationsditcheb hecessary foi construction of the injection well site havã beenapproved and / or accepted by the affected ditch company.The Applicant shall comply with the lr{oxious Weed Management Plan andshall c?rinplete treatmenf of weeds identified in the weed irTventory prior toJune 30, 2b15.12.13.1,1.15.
EXHIBIT
7I
MOUNT
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Givil and Envlronmental ConEultlng and Ðoslgn
June 4,2015
Mr. Glenn Hartman
Garfield County Planning
108 8th Sheet, Suite 401
Glenwood Springs, CO 81601
RE: Review of Ursa \ilatson Ranch B Injection Well: GAP^'8224
Dear Glenn:
This office has performed a review of the documents provided for the Administrative Review
Application of the Ursa Ranch B Injection Well. The submittal was found to be thorough and
well organized. The review generated the following comments:
1. The Applicant should provide a site specific for inclusion in the SPCC plan.
2. The obtaining of a COGCC permit should be a condition of approval. The Applicant should
provide copies of the COGCC permit once obtained.
3. The Applicant should address the routing necessary for Holy Cross to provide power to the
pumps and what easements may be necessary. The Applicant should evaluate if this routing
would have impacts that are not addressed in the application materials.
4. The application materials do not provide any information for the pump house plans, size,
drainage, aesthetics, etc. The Applicant should provide this information for review.
Feel free to call if you have any questions or comments.
Sincerely,
Mountain Cross Engineering, Inc.
Chris Hale, PE
826l"Grand Avenue, Glenwood Springs, CO 81601
P: 970.945.5544 F: 970.945.5558 www.mountaincross-eng.com
Glenn Hartmann
From:
Sent:
lo:
Subject
Glenn Hartmann
Monday, June 08, 2015 11:38 AM
Glenn Hartmann
FW: Ursa Watson Ranch B lnjection Well
From: Rob Firehouse Imailto:opschief@gvfpd.org]
Sent: Wednesday, May 20, 20L5 4:05 PM
To: Glenn Hartmann
Cc: Brooke Winschell
Subject: RE: Ursa Watson Ranch B lnjection Well
Glenn & Brooke,
I have found a few errors in the ERP for Ursa
Section 3.2 - Where they list our three fire stations.The 5797 County Road .... should be 5797 County Road 309 -
Something to note is this station never has any staffing at it. The first two stations are the only staffed fire stations. So
The following line after the stations list needs to be reworded to show that Garfield County Dispatch will dispatch out
Grand Valley Fire Protection District. (They don't dispatch via stations, only Fire Districts) and when dispatched the
closest station that is staffed will respond from the 124 Stone Quarry Rd or 200 Grand Valley Way fire stations. The
phone number 970-285-9L19 should only be used for non-emergency related activities, All emergencies should be
through GarCo 91"1.
Section 3.3 - Probably should list St. Mary's hospitalalso. lf the injury is severe trauma related and there is no CareFlight
helicopter available or the weather doesn't allow for them to fly we will ground transport them to SMH.
Section 3.5 - This is worded very oddly. First off there is no area that we cannot get to in our Fire District that Ursa is
working in. The Fire Dístrict EMT's and Paramedic's will be the determining factor if CareFlight needs to be called. We
usually make this determination from info we receive from GarCo dispatch.
Section 8.2.4.2 Non-Extinguishable Fire. - the second bullet point should state " Call 9LL" -- NOT THE FIRE DEPT. Then
the third sentence says "Second, call Rifle Fire Protection District immediately." Two things with this, first it should be
Garfield County 91"1 Dispatch not the fire department. Second there is no Rifle Fire Protection District, they are Colorado
River Fire Rescue and Battlement Mesa ¡s not their response district without a request for mutual aid by Grand Valley
Fire protection. the following sentence should say the sooner " gl-L is called" the quicker the response. Calling the fire
station is a very bad idea. There may not be anyone at the station because they are out training or on another fire/EMS
call. Someone is always at 911 dispatch and can get in touch with us over our county radio system. All fires whether
they are on private, public or federal lands should be called into 91-L period. GVFPD works closely with all local fire
agencies including the BLM and USFS. We will still remain the fire responders to the incident within our 320 square
miles.
Section 10.2 - which is between 10.L and 10.L.1?? Notification from a spill or leak should be called into 911 not the fire
station for the same reasons as listed above.
This all needs to be fixed in the ERP. For this showing a June 2014 date this is the first time I have seen the ERP for Ursa
Let me know if you have any questions
1
6I
Rob Ferguson
Deputy Fire Chief
Grand Valley Fire Protection District
01-24 Stone Quarry Road
Parachute, CO 81635
Office 970-285-9119
Fax 970-285-9748
opschief@gvfpd.ors
z
EXHIBIT
1Glenn Hartmann
From:
Sent:
To:
Subject:
Glenn Hartmann
Monday, June 08, 2015 1 1:44 AM
Glenn Hartmann
FW: Ursa Watson Ranch B lnjection Well
From: Franco - DNR, Ivan fmailto:ivan,franco@state.co,us]
Sent: Friday, June 05, 2015 9:23 AM
To: Glenn Hartmann
Subject: Re: Ursa Watson Ranch B Injection Well
Glenn,
We have reviewed the Ursa Watson injection well referral in Garfield County. Thank you for the opportunity to review the application
however we have no comments at this time.
Sincerel¡r,
Ivan Franco, P.E.
Water Resources Engineer
COLORADO
Division of Water Resources
Department of Natural Resources
P 303.866.3581 / F 303.866.2273
1313 Sherman Street, Room B18, Denver, CO 80203
ivan.franco te.co.us /www.water. state. co. us
1
^ffi1
COLORÅDO
Ðepartment of Pubiic
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
May 19,2015
Brooke Winschell
Garfield County
Commr.rnity Development Department
I 08 8th Srreer- SLrite 401
Glenwood Spiings, CO 81601
RE: Ursa Watson Ranch B Injection Well
Dear Ms. 'Winschell:
On May 15,2Ol5,the Colorado Air Pollution Control Division (APCD) received a request for an air
qualþ determination conceming Ursa Watson Ranch B Injection Well. APCD staff has reviewed the
request and has determined that the following provisions of the Colorado Air Quality Regulations apply
to the project.
All sources of potential construction and oil and gas projects that will produce air emissions in Colorado
are required to obtain a construction or oil and gas permit. The first step to obtain a permit is to determine
whether your project will need an Air Pollution Emissions Notice (APEÐ. Information on APENs and
air permits is found at www.colorado.gov/pacific/APEN . This site explains the process to obtain an
APEN and an air quality construction or oil and gas permit, as required under the Air Quality Control
Commission Regulation No. 3, Part A. Also, the site explains the process to determine whether or not
your project is exempt from the regulation's requirements.
If your project is located within the Denver Metropolitan Area Ozone Marginal Non-attainment Area, you
must obtain a permit. Visit www.epa.gov/air quality/greenbook/hnmapa.html (select Colorado) to view a
map of the Denver non-attainment area.
Once it has been determined that an APEN is required, the next phase involves submission of an
Application for Construction Permit (permit) for each facilþ and one APEN for each emission point
at each source. A source can be an individual emission point or group of similar emission points (see
Regulation No. 3, Part A, II.B.4). Both APEN reporting and permit requirements are triggered by
uncontrolled actual emission rates. Uncontrolled actual emissions are calculated based upon the requested
production/operating rate assuming no control equipment is used, In general, an APEN is required for an
èmission point with uncontrolled actual emissions of any critical pollutant equal to or greater than the
quantities listed below:
4300 Cherry Creek Drive S., Denver, C0 8024ó-1530 P 303-692-2000 www.cotorado.gov/cdphe
John W. Hickenlooper, Governor I Larry Wotk, MD, MSPH, Executive Director and Chief Medical Officer
EXHIBIT
toI
AREA UNCONTROLLED ACTUAL EMISSIONS
Attainment Area 2 tons per year
Non-attainment Area Pollutants 1 ton ner vear
All Areas Lead emissions: 100 pounds per year
All sources of non-criteria reportable pollutants have a 250 pounds or more per year reporting threshold
on an uncontrolled basis. You may wish to review Regulation No. 3, Part A, Appendices A and B on
the reporting thresholds.
However, none of the exemptions from an APEN filing requirement shall apply if a source would
otherwise be subject to any specific federal or state applicable requirement. Information concerning
submittal of revised APEN is also given in Regulation No.3, Part A. An APEN is valid for five years.
The fîve year period recommences when a revised APEN is received by the Division.
If you have any questions regarding your reporting or permitting obligations, please contact the Small
Business Assistance Program at303-692-3148 or 3I75.
Land development construction activities (ear1h moving) that are greater than 25 acres or more than six
rnonths in duration will require an APEN from the Air Division and may be required to obtain an air
permit. In addition, a start-up notice must be submitted thirty days prior to beginning a land development
project.
Please refer to the website www.colorado.gov/pacific/APENforms for information on speciaþ forms
Click on Land Development.
If you have any questions or need additional information, please call the phone numbers listed above, or
call or e-mail me directly.
Thank you for contacting the Air Division about requirements for your project'
Sincerely,
A. Dileo
A/EIS Coordinator
Planning and Policy Program
Air Pollution Control Division
Colorado Department of Public Health and Environment
3 03 -692-3 127 I jim.dileo@state.co.us
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor I Larry Wotk, MD, MSPH, Executíve Director and Chjef Medical Officer
Glenn Hartmann
From:
Sent:
To:
Subject:
File Number: GAPA-8224
Mr Glenn Hartmann,
We are land owners located alA42l County Road 303. Our home is 750 ft. from lnjection Well site.
Our concerns are:
1. Property Value loss
2. lnjection fluid flowing under part of our property, without our consent.
3. Loss of 1i3 of our property to drill for water, due to location of gas wells.
Sincerely,
Don & Barb Allred
Donallred [donallred @ aol.com]
Tuesday, May 19, 2015 9:05 AM
Glenn Hartmann
Ursa Watson Ranch B lnjection Well
1
GIenn Hartmann
From:
Sent:
To:
Subject:
a
Leslie Robinson Irifleshots@ gmail.com]
Thursday, June 04,2015 9:17 PM
Glenn Hartmann
File Number: GAPA-8224, Ursa Watson Ranch B lnjection Well comments
To Glen Hartman, Garfield County staff planner
From: Grand Valley Citizens Alliance
c/o rifleshots @ gmail.corut
PO Box 656, Silt CO 81652
970-618-0890
Subject: Public comment to File # GAPA-8224,UrsaWatson Ranch B Injection Well application
Members of the Grand Valley Citizens Alliance strongly recommend that Application File #
GAPA-8224 be declined by Garfield County for these reasons:
o Injection well development and production will further disturb local neighborhoods, reducing the quality
of life by increased truck traffic, potential source of odor and light pollution, and escalating air pollution.
There is no air quality test equipment located in Battlement Mesa to measure air impacts
. Injection wells can experience human and mechanical failures - site is too close to neighborhoods and
mishaps could affect citizen health and welfare.
o Because open pits are "use by right," there would be no controls in place to prevent pit development at
injection well site.
o Injection wells are filled with chemical concentrated material; spills above ground and seeps through
cracked casings or indirectly through other wells, could affect human health and water quality in local streams,
irrigation ditches, aquifers, and community water sources.
o Many geologists agree,there is evidence earthquakes can be generated by injection wells. Underground
geology in Battlement Mesa area is not entirely mapped out, there are no guarantees that injection wells might
not set off a chain reaction in local fault lines. In addition, for citizen s, the feør of earthquakes can be as real as
the probability of injection well-produced earthquakes.
o Because of the national and statewide negative publicity concerning injection wells and production waste,
real estate values could be affected for nearby private property owners, many of them retired senior citizens,
thus depriving them of full property investment value.
1
I Lå
. If injection wells are approved for the Battlement Mesa area, a precedent will be in place for future multi-
well industrial development close to residential areas in Garfield County, thus putting more citizens at risk from
oil and gas development.
Again, GVCA members urge Garfield County to protect citizens from concentrated energy development such as
injection wells by declining IJrsa's Watson B injection site.
Sincerely,
Leslie Robinson
Chair, Grand Valley Citizens Alliance
2
EXHIBIT
t7I
BATTLEMENT CONCERNED CITIZENS
Battlement Mesa, CO 81635
June 5, 2015
Ga rfield Cou nty Commu nity Development Depa rtment
108 8th Street, Suite 401
Glenwood Springs, CO 81601
Re: Ursa Watson Ranch B lnjection Well (File number GAPA-8224)
Dear Sir or Madam
We are increasingly concerned with the number of injection wells that are becoming a part of
the landscape near our Battlement Mesa community. There are now approximately ten (L0) of
these O&G wastewater disposal facilities that are either in place or planned in the immediate
vicinity of Parachute/Battlement Mesa.
Colorado has already been shaken by earthquakes as a result of induced seismicity caused by
injection wells. Greeley, Colorado experienced a 5.3 magnitude earthquake in August, 2011 and
it was attributed to injection wells. See ATTACHMENT'A'.
More recently, we have seen the results of a lightning strike at an injection well site near
Greeley two months ago, that caused a horrific fire and explosion. The images and video of that
incident are quite frightening. See ATTACHMENT'B'.
Therefore, we recommend that Ursa be required to perform seismic testing prior to activating
the injection well and that they be required to monitor for seismic activity continuously
thereafter.
We further recommend that Ursa be required to install and operate the most state-of-the-art
líghtning protection equipment available, to protect Battlement Mesa residents from the kind
of catastrophe that occurred near Greeley recently.
Also, we recommend that Garfield County consider locating a seismic monitoring stat¡on in an
appropriate area of the county as part of an area-wide seismic network that is maintained by
CMU. This would enable the accurate detection and location of seismic activity in the county.
We also fear the impact on future generations of our current practice of disposing of our waste
products deep within the planet that we hope will sustain us for a very long time.
Page I of 6
Let us know if you have any questions or need additional information
Sincerely,
Dave DevanneV /s/
BCC Chair
d gd êva n nev(a comcast. net
Doug Saxton /s/
BCC Director
douslassaxton @ema il.com
Page 2 of 6
ATTACHMENT'4,
http ://www.ee news. net/enersvwi rel2014l09/l-6lstories/1060005853
USGS links Colo. quakes to gas drilling
Mike Soraghan, E&E reporter
Published: Tuesday, Septem ber 16, 2OI4
There is "clear evidence" that gas drilling activities triggered the magnitude-5.3 earthquake that
shook Colorado in August 2011, a U.S. Geological Survey study has found.
That rupture was the largest quake in a l3-year pattern of shaking along the New Mexico border,
which the studv links to disposal of waste water from coalbed methane production.
"The earthquakes are clustered around wells that have been quite active since about ayear before
the earthquakes started," said Art McGarr, one of four USGS scientists who worked on the study.
The peer-reviewed study, published today in the online version of the Bulletin of the
Seismological Society of America, says that there's been a big increase in earthquakes in the
Raton Basin around Trinidad, Colo., and the only other thing that has changed has been the
arrival of new disposal wells.
But one of two companies producing gas in the arca sharply disagrees.
re70 rQ80 rsoo 2000 æ'l0
ItlA time progression of earthquakes in the Raton Basin. The dashed line indicates the
earthquake detection threshold for the Raton Basin over the entire study period. Graphic courtesy
of the Bulletin of the Seismological Society of America.
"We would categorically disagree," said Jennifer Webster, spokeswoman for lrving, Texas-based
Pioneer Natural Resources Co. "'We're not seeing any connection with disposal activity in the
area.t'
How Colorado quakes line up
Page 3 of 6
The area has a history of natural earthquakes, she noted. And for the past 18 months, Pioneer has
been monitoring a sensitive anay of 25 instruments in the area. Webster said the seismicity they
detected is far from the injection wells and 2 miles deeper than the injection zone.
The other operator in the area, Atlas Resource Partners of Philadelphia, did not return a phone
message seeking comment.
The two companies are not engaged in high-volume hydraulic fracturing of shale formations.
Instead, they are tapping into the natural gas found in coal formations of the Raton Basin. Coal
beds are found much shallower than shale, but producing from them also creates significant
amounts of wastewater. The Raton field, though, is in decline.
As with other studies from Arkansas, Oklahoma and Texas, the USGS study links the
quakes to disposal of waste fluid.
From 1972 through July 2001, there was one quake in the area larger than magnitude 4. Then 12
occurred between August 2001 and 2013, mostly within 3 miles of active disposal wells. The
study says the statistical likelihood that such a rate change would occur if earthquakes behaved
randomly in time is 3 percent. In addition, earthquake activity remains low outside the drilling
zone.
As soon as the shaking started in 2001, seismologists were suspicious that the convulsions in the
Raton Basin were linked to drilling. But for years, USGS scientists were equivocal. McGarr said
by the time of the magnitude-S.3 earthquake, the relationship between injection and earthquakes
was a lot more conclusive.
Another look at Colo. Quakes
Prompted by the magnitude-5.3 quake, which occurred the same day as a better-known
magnitude-5.8 quake that shook Virginia and the East Coast, USGS re-examined the Colorado
earthquakes going back to the "swarm" of 2001. Seismologists at the agency put out new
instruments, went back into the data they had gathered in the past 10 years and began to point the
finger at drilling activity with increasing certainty.
The series of foreshocks and aftershocks in20l1 was centered within 6 miles of five injection
wells in the Raton Basin, the study says, two owned by Atlas Resource Partners on the same site
and three owned by Pioneer. All but one, the study says, are "high-injection-rate, high-volume
wells." The ARP wells are within 1.7 miles of where the20ll sequence began.
"The proximity of the [ARP] wells to the 2011 earthquake sequence also suggests that they are
the wells most likely to have induced the earthquake sequence," the study says.
Colorado officials, though, have long rejected the USGS conclusions as premature.In 2012,
then-Colorado State Geologist Vince Matthews said, "These cowboys from USGS are sure
these are induced. They're jumping to conclusions" (En-9l8yWire., Dec. 3,2012).
Page 4 of 6
State officials, under fire from suburbanites and environmentalists charging lax regulation of
drilling, have been taking a less dismissive tone on the issue in recent months. After a smaller,
magnitude-3.2 quake near Greeley in May, the Colorado Oil and Gas Conservation Commission
asked the operator of a nearby deep-injection well to temporarily shut down for 20 days. In July,
the state allowed the well to reopen at a lower pressure and less injection than before. The state
said the well was "potentially" related to earthquakes in the area.
Colorado has a long history with man-made quakes. In the 1960s, disposal wells drilled at the
Rocky Mountain Arsenal near Denver, where the Army manufacfured chemical weapons, were
the first to be linked to earthquakes. The largest Rocky Mountain Arsenal earthquake was
magnitude 4.85.
After that, the Bureau of Reclamation began tracking man-made quakes in a river desalination
project in the Paradox Valley of western Colorado.
There was drilling and disposal in the Trinidad area from 1994 through July 2001, with no uptick
in earthquakes. But in early 200I, the study says, injection rates in the Colorado portion of the
field dramatically increased, rising from a median rate of 500,000 barrels a month to I.2 million
barrels a month. The earliest earthquakes were located in the eastern portion of the gas field,
shortly after six wastewater injection wells were put into operation.
"Total injection volumes and the number of earthquakes roughly track each other," the
study says.
Page 5 of 6
ATTACHMENT,B'
Explosions Seen At Fracking \Mastewater
Tank Site
April L7,2075 3:33 PM
GREELEY, Colo. (CBS4) - Numerous explosions have been seen during a fire at a wastewater
injection well tank site in Weld County.
The site is located near the intersection of Weld County Road 47 and Weld County Road 64, just
northeast of the Greeley Airport. Fracking wastewater, which does contain some petroleum, is
stored at the site.
Three homes were evacuated near the f,tre, which started at approximately I p,m. No injuries
have been reported.
Emergency crews said they are expecting to remain on the scene for an extended period
"'We're holding fîrefighters away due to venting and possible exploding tanks," said Greeley Fire
Department spokesman Dale Lyman. *We're waiting until that slows down and we 're not in
harm's way."
Other news stor¡es -
htto://www.thedenve rcha n nel.com /news/loca l-news/crews-battle-fi re-after-oi l-tank-
exolosion-in-greelev-homes-near-weld-countv-road-64-47-evacuated04172015
http://kdvr.com/2015/04/17lreport-lishtnine-strike-sparks-oil-ta nk-fire-near-greelev-airport/
http://www.postindependent.com/news/15948232-113/ereelev-firefishters-battlins-blaze-
nea r-greelev-weld-cou ntv-a i rport
,-Ð
Page 6 of 6
IIg+
Guffiehd Co un
Vegetation Managemenl
June 8, 2015
Glenn Hartmann
Garfield County Community Development Department
RË: GAPA-8224lJrsa Watson Ranch B lnjection Well
Ðear Glenn,
The Noxious Weed Inventory and Management plan is acceptable. Staff requests that the applicant treat the mapped
noxious weeds, to ínclude the 100 foot survey area as indicated on the map, prior to June 30, 2015 and forward the
treatment records to this office.
Please let me know if you have any questions.
Síncerely,
Steve Anthony
Garfield County Vegetation Manager
0375 GountY Road 352, Bldg 2060
Rifle, CO 81650 Phone: 970-945-1377 x4305 Fax: 970.625-5939
Frgure IUrsa Operating Gornpanylllatson Ranch B Pad UtGlntegraÞd \lbgetafion and lloxious WeedslÍanagement Planâ\Nesddfter Engineerirq€CeÌtuhûEE*rË &t*ßdrt2014December2û14¡0eFæTù0LegendI canaêtm€fleO ctfæryO Cønrnon burdock@ Common nn¡lþin@ llArsk ü¡sile+ Redstêmfhrêe* Russian krnpweed=-fìih¡sk&büeEl tæ Foot ìltbetts Suruey AreaÍffilpao- Access Road- tVf&ffid.'Fff;lleLMLocation
Gørfield County
tی
Public Heølth19s w. 14th Street
Rifle, CO 81650
(970) 625-5200
2014 Blake Avenue
Glenwood Springs, CO 81601
(970) 945-6614
Garf ield County Community Development
108 8th Street
Glenwood Springs, CO 81601
Attn: Glenn Hartmann
June 5,2015
Hello Glenn,
My comments for the Ursa Watson Ranch B lnjection Well Administrative Permit Application are
as follows:
1. System operations: ln the event that the injection well does have issues, redundancies
should be in place to ensure that there is adequate storage or other disposal locations
within the system for water that may otherwise have been sent to the well.
2. Proximity to occupied structures: because this facility is in such close proximity to
occupied structures, extra precautions should be taken to ensure that nuisance
conditions are minimized. The operator should take care to check that tank batteries and
other components of the operation are not leaking to reduce odors and other emissions.
Roads and other disturbed surfaces should have proper dust mitigation, and light coming
from drilling and other operations should be downcast and limited to normal working
hours as much as possible.
3. Seismic activity.lncreased seismic activity should be monitored during the use of the
injection well. While we recognize that produced water will be injected at depths well
below those of domestic drinking water wells, vibrations can still affect local residents.
Monitoring should be done, if possible, to ensure that well casings are properly
maintained to eliminate the potential for contamination of drinking water wells.
4. Air quality: A copy of the Air Pollution Emission Notification (APEN) or an air permit,
issued by the Air Pollution Control Division of the CDPHE, should be submitted to
Garfield County Community Development before beginning operations. Emission levels
should be monitored in the event that the operator may need to obtain an air permit
rather than an APEN. Employees and contractors working at the site should also refrain
from idling their vehicles to reduce emissions.
5. SWMP and SPCC lt appears these plans have been submitted and approved to the
appropriate agencies. The applicant should ensure that no spills are allowed to enter
nearby drainages ôr groundwater. Ursa and its contractors should also have contact
info for drinking water operators so that they can be reached in the event of a spill. lt
appears that any spills at the Watson Ranch B pad will not impact the Parachute or
Battlement Mesa drinking water supply.
\"
û{'nú'{-'{
nuh
Garfield County Public Health Department - working to promote health and prevent disease
Thank you,
',(lr,grøn ifi- H,')e:
Morgan Hill
Environmental Health Specialist lll
Garfield County Public Health
195 W. 141h Street
Rifle, CO 81650
(970) 665-6383
Garfield County Public Health Department - working to promote health and prevent disease
ftb
Oil e Gas Liaison
Krby Wynn
Memorandum
June 5, 2015
RE: GAPA-8224 Ursa Watson Ranch B lnjection Well, Liaison referral comments and COGCC
injection well permitting process, regional seismic monitoring and induced seismicity potential in
Garfield County.
Dear Glenn,
Thank you for the opportunity to review and provide comments on this application.
My office is likely the most common receiver of citizen questions, concerns and complaints
related to possible oil and gas activity impacts to Garfield County citizens. lt is with this in mind
that I have reviewed the application. The proposed land use change will occur near and just
south of the Battlement Mesa PUD and north of Gardner Lane (CR 303)'
My office received numerous calls from Gardner Lane area residents with concerns about the
proposed injection well. Concems were largely related to potential for ground water
contamínation, traffic and potential for induced seismicity. Most of the concerns were for topics
directly regulated by COGCC and a desire for the well permit application to be reviewed at a
public hearing of the COGCC, where residents would be allowed to testify.
To facilitate communication among concerned residents, Ursa, COGCC and county staff, we
facilitated preparations and notifications for a March 4, 2015 meeting that included primary
COGCC UIC permit review staff, Ursa staff, Glenn Hartmann and Kirby Wynn with Garfield
County and about 20 concerned residents. During the meeting Ursa presented detailed
information about the proposed operation of the injection well and COGCC staff presented
detailed information about their permit review process and the regulatory oversight procedures
they follow to minimize risks associated with waste disposal to injection wells. The 2-hour
meeting covered a broad range of topics and all questions were addressed at the meeting or
during follow-up emails and other communications. Liaison's office conducted numerous follow-
up cómmunications to concerned residents regarding County and State permit application
review process and opportunities for the public to review and comment on the application.
COGCC provided detailed instructions to residents regarding procedure to formally protest the
injection well permit. Via a June 1 ,2015 Order, the COGCC Hearings Officer dismissed resident
piotests on the grounds that the concerned parties failed to submit needed documentation. As
such, COGCC is on track to follow their standard administrative permit review procedures, as
summarized in this memorandum.
Specific review comments: I have visited the proposed location on several occasions and have
aÈo visited the Speakman A location injection well facility. The proposed equipment and
housing structure are expected to be same/similar to that used on the Speakman A pad and as
such aie not expected to cause noise issues for nearby residents. Proposed operational plans
include piping of allwaste water to the location which will provide a beneficial reduction of waste
managemenf truck traffic. Overall, the operation of the injection well is unlikely to cause
signlfióant long-term nuisance issues for area residents. There will likely be short-term traffic
and noise during the construction of the injection facility.
ln response to this referral request, I gathered relevant information regarding:
. Currently permitted injection wells in Garfield County
. COGCC injection well permit review process
. Current seismic monitoring and observed seismic activity in western Colorado
r Research related to induced seismicity from injection wells
Gurrently permitted injection wells in Garfield County
Accordíng to COGCC records, there are currently 61 wells in Garfield County that could
potentially be utilized for waste disposal. Of those, 27 have been used for some injection
activity since 2013. See attached map of iniection wells in the vicinity of Battlement Mesa and
the Town of Parachute.
COGCC injection well permit review process
Discussed with COGCC staff (Koehler and Ellsworth) their injection well permit review process.
COGCC reviews geologic structure in vicinity of proposed waste injection wells and evaluates
potential seismicity, including a review of all regional seismic events from 1973 to present. They
also require tests of the well and surrounding formation characteristics. Review process is
geared ioward determining suitability of the well for waste disposal as well as operational
þressure and injection volume limits along with various Conditions of Approval meant to reduce
ihe possibility oi adverse impact (i.e. induced seismicity) and to state mitigation requirements if
adverse impact is suspected in the future.
When COGCC determines a proposed well could present a risk for induced seismicity, they can
and do place permit requirements such as shut down procedures in case of a nearby seismic
event.
2
Current seismic monitoring and observed seismic activity in western Golorado
Western Garfield County is not prone to seismic activity based on discussions with and data
provided by Anne Sheehan, Professor of Geophysics at CU Boulder. Dr. Sheehan is the lead
researcher conducting investigation of the 2014 seismic events near Greeley Golorado.
Received similar information from COGCC and Paul Earle, Geologic Hazards Team at the
USGS National Earthquake lnformation Center.
Apparen¡y most waste injection induced seismicity is associated with injection into crystalline
bedrock that contains existing faults. ln Garfield County waste disposal wells inject into
sedimentary rather than crystalline bedrock which in part accounts for expert opinions that
induced seismicity from our waste injection wells is unlikely and that we have historically had no
recorded induced seismicity events. (Aster, pers. commun. 2015)
Drs. Sheehan and Earle indicate our area is currently monitored for earthquake activity at a
resolution to note earthquakes of minimum 2.5 magnitude event with a location determination of
+/- 6 miles.
Research related to induced seismicity from injection wells
Reviewed several recent academic and other publications regarding factors that have caused
induced seismic activity from by waste water injection. The phenomenon is relatively rare as
compared to the prevalence of waste injection wells but can occur under certain conditions'
COGCC evaluates permit applications with the primary objective to prevent approval of injection
wells that could cause induced seismicity such as: large or active faults and perturbation of rock
pore pressures in the proposed injection intervals. lt can be especially important to evaluate less
permeabfe and more brittle formations proposed for injection as those can be the most
susceptible to induced seismicity if not managed carefully and using information about the
permeability and capacity of target injection intervals.
The attached white paper prepared by COGCC descnôes their research and regulatory
response to the latest understanding of induced seismicity. Summary quote from the white
paper: .COGCC believes safeguards are in place, in accordance with federal law and COGCC's
rules and policies, but we will continue to review induced seismicity findings in other parts of the
country w1h interest. The current safeguards defined by COGCC permit process are injection
volume; pressure below the fracture gradient; and, input from the CDWR and CGS to reduce
the potential for induced seismicity related to UIC Class ll wells. COGCC strives to continually
improve our evaluation methods, and the effectiveness of regulations, rules policies and
procedures."
aJ
Bibliography
Aster, R,, 2015 Personal communication from visiting Seismologist who presented induced
seismicity concepts at June 4,2015 Energy Advisory Board meeting.
COGCC,2O11, COGCC Underground lnjection Control and Seismicity in Colorado, COGCC
Staff White Paper, 5 pages.
Earle, paul,2O14, July 7, 2014 USGS National Earthquake lnformation Center letter response
to query about regional seismic monitoring capabilities, 2 pages.
Eisinger, C.,2014, Personalcommunications from COGCC Senior Research Scientist
supervisor regarding COGCC UIC application review procedures and current UIC wells in
Garfield County.
Koehler, 8,2014. Personalcommunications from COGCC Underground lnjection Control(UlC)
Supervisor regarding COGCC UIC application review procedures.
National Research Council. tnduced Seismicity Potential in Energy Technologies. Washington,
DC: The National Academies Press, 2013,263 pages.
Ellsworth, W.L., 2Ol3lnjection-lnduced Earthquakes, article in SCIENCE:VOL 341 12 JULY
2013,7 pages.
Zoback,M.D.,2012, Managing the Seismic Risk Posed by
Wastewater Disposal, Article in Earth Magazine, Aprll2Q12,6 pages.
Kirby Wynn
Attachments:
Underground lnjection Control and Seismicity in Colorado, COGCC Staff White Paper
Map oi injection wells in the vicinity of Battlement Mesa and the Town of Parachute
Memo from COGCC dismissing resident protests of the proposed injection well
4
BEFORE THE OIL AND GAS CONSERVATION COMMISSION
OF THE STATE OF COLORADO
IN THE MATTER OF THE APPLICATION OF
URSA OPERATING COMPANY LLC FOR A
PERMIT TO OPERATE AN INJECT¡ON WELL IN
THE SE%SW% OF SECTION 17, TOWNSHIP 7
SOUTH, RANGE 95 WEST, 6TH P.M., GARFIELD
COUNTY, COLORADO
CAUSE NO. 1
DCICKET NO. 150500343
TYPE: GËNERAL
ADMINISTRATIVE
ORDER plSMlS-S-lNG OBJECTIONS OF
BARBARA ALLRED. DCINALD ALLRED. DANIEL GARDNER. MARK GABDI-IER
THIS MATTER is before the undersigned Hearing Officer on the Hearing Officer's Order
to Provide Evidence Supporting Objection dated May 5, 2015 ("Orde/'). The Hearing
Officer makes the following findings and order.
FINDINGS
1. The Order required Barbara Allred, Donald Allred, Daniel Gardner, and
Mark Gardner to on or before May 29, 2A15 provide to the Hearing Officer at
iames.rouse@stale.co.us and to the Commission at coqcc.hearinqs unit@state.co.us,
and mail to the Commission the original and two paper copies of, and serve on Ursa,
the following documentation specifically showing: 1) possible conflicts between the
proposed injection zone's proposed disposal use and present or future use as a source
of drinking waler or present use as a soulce of hydrocarbons, or 2) that operations at
the well site may affect potential and current sources of drinking water:
a) Resumes/curricula vitae for expert witnesses who witl testify in support of the
relief being requesled by Barbara Allred, Donald Allred, Daníel Gardner, and Mark
Gardner;
b) A detailed written summary of the testimony to support the relief being
requested by Barbara Allred, Donald Allred, Daniel Gardner, and Mark Gardner;
c) Exhibits to support the relief being requested by Barbara Allred, Donald Allred,
Daniel Gardner, and Mark Gardner; and
d) A draft proposed order providing land, geology, engineering, hydrologic, and
other appropriate findings to support the relief being requested by Barbara Allred,
Donald Allred, Daniel Gardner, and Mark Gardner:
2. By e-mail dated May 9, 2015, Barbara Allred and Donald Allred advised
the Hearing Officer that they would no longer be pursuing their objections.
3. Daniel Gardner and Mark Gardner failed to timely comply with the Order
ORDER
Based upon the foregoing findings, it is herby
ORDERED that the objections of Barbara Allred, Donald Allred, Daniel Gardner,
and Mark Gardner are hereby dismissed.
AND lT lS FURTHER ORDERED that the written objections of Barbara Allred,
Donald Allred, Daniel Gardner, and Mark Gardner will be converted to statements under
Commission Rule 510 and provided to the Gommission if a hearing is held on Ursa's
proposed injection well.
Dated: June 1,2015
OIL AND GAS CONSERVATION COMMISSION
OF THE STATE OF COLORADO
L
P. Ro use,Hearing Officer
Colorado Oiland Gas Gonservation Commission
1120 Lincoln Street, Suite 801
Denver, Colorado 80203
Website : http ://cogcc. state. co. us
Phone: (303) 894-2100
Fax: (303) 894-2'109
Order Dismissing Object¡ons (Allred, Gardner)
Page 2 of 3
DocketNo. 150500343
CERTIFICATE OF SERVICE
On June 1, 2015, a true and correct copy of the Order to Provide Evidence
Supporting Objection was sent by electronic mail, or US Mail, First Class postage prepaid
(if no e-mail address) to the following:
Barbara L. Allred
0421 County Road 303
Parachute, CO 81635
donallred@a.ql.com
Daniel Gardner
134 County Road 303
Parachute, CO 81635
oardnerex@gmail.com
d a n i e I @ q a r{n e rexc.-qo-m
Jennifer Lind
Ursa Operating Company LLC
1050 17th Street #2400
Denver, CO 80265
ilind(@ursaresou rces.com
Donald Allred
0421 County Road 303
Parachute, CO 81635
donallred(Oaol.com
Mark Gardner
250 County Road 303
Parachute, CO 81635
Robert Bleil
Ursa Operating Company LLC
rblei l(@ u rsa resources.co m
James P. Rouse
Order Dismissing Objections (Allred, Gardner)
Page 3 of 3
DocketNo. 150500343
STATE OF
cOLORADO
otL&GAS
CONSERVATION COMM ISSION
DEPARTMENT OF NATURAL RESOURCES
John W. Hickenlooper, Governor
1120 Lincoln St. Suite 801
Denver, CO 80203
Phone: (303) 894-2100
FAX: (303) 894-2109
www.colorado.gov/cogcc
January 19,2011
COGCG Underqround lniection Controland Seismicitv in Golorado
Colorado's earliest documented earthquake occurred on December 7 , 1870. fhe Colorado
Transcript stated, "A careful observer at Fort Reynolds, 20 miles east of Pueblo, noted that
bottles standing 1 inch apart were knocked together violently." Many earthquakes have
occurred throughout Colorado since that time and continue to occur today. Earthquakes are
vibrations created when large blocks of the Earth's crust move with respect to one another
along a fault plane. The Colorado Earthquake Hazard Mitigation Council published a map in
2008-of earthquakes and faults in Colorado. The map can be obtained at the Colorado
Geoloqical Survey (CGS). The United States Geological Survey (USGS) maintains a database
of CılóraOo earthquakes at the National Earthquake lnformation Center (NEIC) in Golden.
Most earthquakes or seismicity occur as a result of naturally-occurring geologic phenomena.
However, there have been some cases where seismicity was suspected to have been triggered
by injection of fluids into the subsurface. The term "lnduced Seismicity" has been used to
Oêsci¡Oe man-made earthquakes of this type. The most notable case in Colorado was at the
Rocky Mountain Arsenal (the "Arsenal") near Denver. Earthquakes began after a 12,000-foot
injection well was drilled at the Arsenal for the disposal of waste fluids. lnjection commenced in
Märch 1962. Shortly thereafter, an unusually frequent series of earthquakes occurred during the
period from January 1963 to August 1967. ln 1968 injection stopped, and the Army began
removing fluid from the Arsenal well at a very slow rate in an effort to reduce earthquake
activitv. in Nicholson, 1990, Earthquake Hazard Associated with Deep Well lniection- A Report
to the tJ.S. E.P.A.s injection volumes were related to earthquake events, demonstrating that
these earthquakes were induced by fluid injection at the Arsenal.
COGCC, in accordance with federal law and COGCC's rules and policies, believes safeguards
are in place to reduce the likelihood of induced seismicity. The current safeguards defined by
COGCC permit process are injection volume; pressure below the fracture gradient; and, input
from the Colorado Division of Water Resources (CDWR) and CGS to reduce the potential for
induced seismicity related to UIC Class ll wells.
The federal Underground lnjection Control (UlC) program began on December 1974 with the
creation of the Safe Drinking Water Act (SDWA). The SDWA established the UIC Program,
administered by the United States Environmental Protection Agency (EPA), to protect
Underground Sources of Drinking Water (USDW's) from impacts related to underground fluid
injection practices. The EPA delegated primacy for regulation of Class l¡ UIC wells to the State
of Cotorado for underground injection of oil and gas exploration and production waste on April 2,
1g84. Colorado has administered the UIC proqram in accordance with federal regulations (40
CFR, Parts 144, 145,146, and 147) since that time, providing the EPA with semi-annual
reports, http://water.epa.qov/tvpelo roundwater/uic/index'cfm.
DEPARTMENT OF NATURAL RESOURCES: M¡ke King' Executivê Director
COGCC CoMMISSION: R¡chard Alward -John Benton -Thomas L. Compton-ÐeAnn craig-Tommy Holton -W. P€rryPearæ- AndrewSpi€lman - Mike King-chris Urbina
COGCC STAFF: Dav¡d N€st¡n, Director - Margaret Ash, F¡€ld lnsp€ction Manager - D€bbie Baldwin, Envircnmental Manager - Sluart Ellsworlh, Eng¡nær¡ng Manag€r
COGGC Underqround lniection Gontroland Seismicitv in Colorado lcont.l
The Colorado Oil and Gas Conservation Commission (COGCC) is the State regulatory agency
that permits Class ll UIC wells for inlection of oil and gas exploration and production waste and
enhanced recovery wells. The COGCC Class ll UIC permit review process is defined by
COGCC Rule 303 Permit to Drill, Rule 3248 Exempt Aquifers, Rule 325 Underground Disposal
of Water, Rule 326 Mechanical lntegrity Testing, and Rules 706,707, and712, which identify
FinancialAssurance requirements. The permit process involves the review and approval of
Form 21, Mechanical lntegrity Test, Form 26, Source of Produced Water for Disposal, Form 31
Underground Injection Formation Permit Application, and Form 33 lnjection Well Permit
Application. lnformation included with these forms and required supplementary documentation
describe well construction, ground water and injection zone isolation, fracture gradient,
maximum injection rate, maximum injection volume, maximum injection pressure, injection zone
water quality, and potential seismicity associated with fluid injection.
lnjection wells must utilize a well construction method of cemented surface casing and
production casing, which isolate and prevent fluid flow between injection zones and USDWS. To
verify isolation, the COGCC UIC engineer reviews all relevant information, including:
hydrogeologic studies, Colorado Division of Water Resources (CDWR) water well information,
and COGCC's geophysicalwell log database. This information is used in conjunction with
specific formation and well construction data submitted by the injection well operator, including
resistivity and cement bond geophysical logs to verify that: 1) the surface casing is set below all
fresh water zones used as a water supply, and 2) production casing cement placement and
quality allows for adequate isolation of the injection zone and USDWS, including fresh water
zones that are not currently being used as a water supply. Further, the geophysical logs are
used to determine the injection zone thickness and porosity, and the logs are used to verify that
the bounding shale zones are thick enough to provide zonal isolation. The COGCC UIC
engineer calculates a maximum injection volume, based on thickness and porosity from the log
data. By COGCC policy, the injection volume is restricted to a one-quarter mile radialvolume.
The restriction is intended to constrain the total volume of injected fluids during the life of the
injection well.
After a well has been drilled and completed into the injection zone, an injection zone water
sample test must be submitted. The sample is required to meet EPA-defined levels for total
dissolved solids (TDS). COGCC Rule 3248 Aquifer Exemption is required, if the sample has a
TDS below 10,000 milligrams per liter and above 3,000 milligrams per liter. Water zones
containing TDS of less than 3,000 milligrams per liter cannot be exempted and used for
injection, because they are considered to be USDW's suitable for possible future use as
treatable water supplies. COGCC solicits written opinion from the CDWR regarding the
occurrence of surface and subsurface fresh water sources in the vicinity of the injection well and
the suitability of the injection well's proposed casing and cement configuration to protect those
resources.
Maximum surface injection pressure is calculated based on a default fracture pressure gradient
of 0.6 psi per foot of depth. The operator may elect to conduct a Step Rate lnjection Test to
define whether a higher injection zone fracture gradient exists. From the resulting fracture
gradient, the COGCC UIC engineer designates a maximum surface injection pressure at the
operator's requested injection rate as a condition of permit approval. COGCC's policy is to keep
injection pressures below the fracture gradient, which is defined uniquely for each injection well,
minimizing the potentialfor seismic events related to fluid injection. Some injection wells do not
need to inject under pressure because the formation will take water on a vacuum. Beginning in
September of 2011, the COGCC UIC permit revíew process was expanded to include a review
Page2
GOGGC Underqround lniection Gontroland Selsmlcitv ln Golorado (cont.)
for seismicity by the CGS. CGS uses their geologic maps, the USGS earthquake database, and
area-specific knowledge to provide an opinion of seismic potential. lf historical seismicity has
been identified ln the vicinity of a proposed Class ll UIC well, COGCC requires an operator to
define the seismicity potential and the proximity to faults through geologic and geophysícal data
prior to any permit approval.
COGCC has had recent discussions with operators, EPA and the USGS regarding induced
seismicity. The USGS earthquake specialists visited the COGCC and CGS in January 2012.
Discussions related to providing technical expertise regarding seismicity and possible
relationships to Class ll UIC wells.
COGCC believes safeguards are in place, in accordance with federal law and COGCC's rules
and policies, but we will continue to review induced seismicity findings in other parts of the
country with interest. The current safeguards defined by COGCC permit process are injection
volume; pressure below the fracture gradient; and, input from the CDWR and CGS to reduce
the potential for induced seismicity related to UIC Class ll wells. COGCC strives to continually
improve our evaluation methods, and the effectiveness of regulations, rules policies and
procedures.
References:
1. USGS Earthquake Hazards Proqram, Earthquake History of Colorado.
http://earthq uake.usqs.oov/earthquakes/states/colorado/h istorv. php
2. Division of Minerals and Geology Golorado Geological Survey, RockTalk, Volume 5 Number
2 April 2002.
3. Colorado Earthquake Mitigation Council, Colorado's Earthquake and Fault Map, 2008
4. Davis, S.D., and Frohlich, C., 1993, Did (or will) fluid injection cause earthquakes? - Criteria
for a rational assessment, Seismological Research, Letters, v. 64, p. 207'224.
5. Nicholson, Wesson, 1990, Earthquake Hazard Associated with Deep Well lnjection- A
Report to the U.S. E.P.A., USGS Bulletin 1951,74p. (Note: Also available as USGS Open
File Report 87-331). default.htm
6. Osborne, Paul, editor,2OO2, EPA Technical Program Review: Underground lnjection
Control Regulations, EPA 81 6-R-02-025.
7 . Shirley, Kathy, 2001, Colorado Quakes Cause Concern, AAPG Explorer,
http://www.aapq.orq/exolorer/20O1/12declcolo quakes.cfm, last accessed 1111712005.
Page 3
COGGC Underqround lniection Gontroland Seismlcitv in Colorado
What is a Class ll Underground lnjection Gontrol (UlG) well?
Class ll UIC wells inject fluids associated with oil and natural gas production. Most of the
injected fluid is salt water (brine), which is brought to the surface in the process of producing
(extracting) oil and gas. ln some oil fields, brine and other fluids are injected to enhance
(improve) oil and gas production by using an enhanced recovery method known as "water
flooding." There are approximately 885 active Class ll UIC wells in Colorado, with 297 operating
as exploration and production (E&P) waste disposal wells and 588 enhanced recovery wells.
The waste disposalwells inject approximately 355,000 barrels of brine per day.
What are the types of Glass ll UIC wells?
There are three types of Class ll injection wells associated with oil and natural gas production.
1. Enhanced Oil Recovery Wells (EOR) inject brine, water, steam, polymers, natural gas
and/or carbon dioxide into oil-bearing formations to recover residual oil. This is also
known as secondary or tertiary recovery. The injected fluid thins (decreases the
viscosity) or displaces the residual oil and gas after primary production, which is then
available for recovery. ln a simple configuration, a síngle injection well is surrounded by
multiple production wells. Production wells bring oil and gas to the surface; the UIC
Program does not regulate production wells. Enhanced recovery wells are the most
numerous type of Class ll wells, representing as much as 60 percent of the Class ll
UIC wells in Colorado. There are currently 588 permitted EOR wells in Colorado.
2. Disposal Wells inject brines and other E&P waste fluids associated with the production
of oil and natural gas operations. When oil and gas are produced, brine is also brought
to the surface. The brine is segregated from the oil and gas by surface production
facilities. lt is then injected into the same deep underground formation or a similar
formation specifically permitted for disposal. Class ll disposal wells can only be used to
dispose of fluids associated with oil and gas production. Disposal wells represent about
30 percent of Colorado's Class ll UIC wells. There are 885 total UIC Class ll wells with
297 operating as E&P waste disposal wells in Colorado.
3. Hydrocarbon Storage Wells inject liquid hydrocarbons in underground formations
(such as salt caverns or abandoned hydrocarbon fields) where they are stored,
generally, as part of the U.S. Strategic Petroleum Reserve.
ls UIG Class ll Exploration and Production Disposalthe same as hydraulic fracturing?
No. lnjection well operations are not hydraulic fracturing. Hydraulic fracturing and underground
injection are not related activities. Class ll waste disposal is conducted below rock fracture
gradient so as not to create new fractures. Class ll waste disposal occurs over a long period of
time, typically many years during the life of a UIC well. On the other hand, hydraulic fracturing is
performed over a short period of time, typically hours, with "flowback" occurring over the course
of several days or weeks. By definition, pressures used for hydraulic fracturing are above the
fracture gradient, with the intent of inducing new fractures within a hydrocarbon extraction zone
and does not include the permanent emplacement of fluids.
What are the requirements for Glass llwells?
A state has the option of requesting primacv for Class ll wells under section 1422 of the Safe
Drinking Water Act:
Section 1422 requires states to meet EPA's minimum requirements for UIC programs.
Programs authorized under section 1422 must include construction, operating, monitoring and
testing, reporting, and closure requirements for well owners or operators. Enhanced oil and gas
recovery wells may either be issued permits or be authorized by rule. Disposal wells are issued
Page I
GOGGG Underqround lnlection Control- Frequentlv Asked Questions (cont.ì
permits. The owners or operators of the wells must meet all applicable requirements, including
strict construction and conversion standards and regular testing and inspection.
Are there other types of underground injection wells?
Yes, there are six injection welltypes, which are designated based on the different types of
waste injected into the wells. COGCC has primacy to administer EPA's requirements for Class ll
UIC wells.. lndustrial & Municipal Waste Disposal Wells LClass l) - There are 13 Class I wells in
Colorado.. Oil and Gas Related Wells (Class ll) - There are 885 Class ll wells in Colorado.¡ Solution Mininq Wells (Class lll) - There are 37 Class lll wells in Colorado.. Shallow Hazardous and Radioactive lniection Wells (Class lV) - There are no permitted
Class lV wells in Colorado.. Shallow Non-Hazardous lniection Wells (Class V) - There are 1759 Class V wells in
Colorado.. Geoloqic Sequestration Wells (Class Vl) - There are no Class Vl wells in Colorado.
Page2
1WPX ENERGY ROCKYWPX ENERGY ROCKY MOUNTAIN18425WPX ENERGYowpx eneReYWPXLLcos-o4s-0750þt*ENERGY ROCKY MOUNTAIN LLCO5-045-I4693ENERGY ROCKY MOUNTAIN LLCO5.O45-1 3979LLC05-045-1 8426Watson B UICaNOBLE ENERGY INCO5.O45-1 5689aLE ENERGY tNC05-045-l 51 47NOBLE ENERGY INCO5.O45-1 3786s00.5 12345Miles
Glenn Hartmann
From:
Sent:
To:
Subject:
Glenn Hartmann
Monday, June 08, 2015 9:1 1 PM
Glenn Hartmann
FW: lnjection well...Fwd: Website inquiry -BOCC
From: STEVE AN N Wl LLIAMS [mailto:sandawilliams@msn.com]
Sent: Friday, February 27,2OL5 L:36 PM
To: Kirby Wynn
Cc: Fred Jarman
Subject: RE: lnjection well...Fwd: Website inquiry -BOCC
Kirby-
'We live in Pueblo and will not be able to make the Ursa meeting due to the snow storms on the eastern slope
and previous commitments.
We are pro-drilling and have been good neighbors to Ursa in the past, going as far as granting three pipeline
right of ways through the Payton ranch. Still we feel compelled to protest the injection of toxic waste in the
'Watson Pad within half a mile of about 40 homes and 30 domestic water wells. 'We request that locally
generated waste water be disposed of at the Speakman property, an injection well that is already in use, or by
another method.
We understand that waste disposal is necessary, and injection wells may be the current best option, but they are
far from safe. There are many examples of domestic water wells being contaminated when the cementing
process is compromised and percolation of contaminates ends up in the wells. A study of inspection records,
quoted in the Alaska Dispatch News, showed that 1 in 6 injection wells had structural violations. Three such
wells have actually bubbled wastes to the surface.
The concern is compounded by recent findings that injection wells have caused earthquakes. Hundreds
of tremors have been attributed to injection wells around the country. Oklahoma ordered an injection well shut
down after a4.1 earthquake earlier this year. Greeley, Colorado experienced 60 earthquakes in20I4 until an
injection well was shut down and the process was changed.
Cleary the process needs work. The article sited above quotes Stefan Finsterle, a leading hydrogeologist for
Lawrence Berkeley National Laboratory as saying: "There is no certainty in any of this" (being safe) "and
whoever tells you the opposite is not telling you the truth. You have changed the system with pressure and
temperature and fracturing, so you don't know how it will behave." The link to this article is included below.
Should URSA decide to'overlook these dangers, will the company be willing to post a bond to compensate
residents and property owners for damages?
We request that this information be presented at the meeting on March 4th, either read or through written means
to the attendees in our absence.
'We also request a copy of the written minutes from this meeting.
Alaska Dispatch News article: http://www.adn.com/article/poison-beneath-us-injection-wells-spew-toxins-
deep-ground
Steve and Ann Williams
Payton Ranch
1
Itt 7
> From: Ann Williams <sandawilliams@ms >
> Date: February 25,2015 at 12:59:49 PM MST
> To: Mike Samson <msamson@garfield-o >>
> Subject: Website inquiry -BOCC
> Ann Williams has sent you a message:
> URSA injection well
> 7 19-547-0323
> Hello Mr. Samson
>'We are asking for your assistance concerning a situation with potential to affect the daily lives of dozens of
people on Battlement Mesa. We recently learned that Ursa, a gas and oil development company, plans to build
an injection well within less than 750 feet of the nearest home. This project could contaminate approximately 30
drinking wells and will impact livability with increased air pollution, noise, unsightly buildings, and traffic.
Earthquakes have also been linked to injection wells, threatening 40 homes along with a 100 year-old stone
school house, all within half a mile of the proposed well. Ursa plans to begin construction on the well within the
year. A group of residents has requested that the well be relocated to a less populated area or a safer means of
disposal be found. We fear, however, that we have little chance of effecting the approval process.
I will be happy to provide further information.
Ann Williams
7t9-547-0323
2
tlEXHIBIT
I
The Concerned and Affected Resldents Surroun$ins
Ursa Oneratins Co.I,,LC Proposed \ryatso+ B - Disnosal \ryell and Pad
February 10th, 2015
RE: Watson B-24AW|-17-07-95 Waste Disposal Site
Neighboring Affected Families
Ladies and Gentlemen,
Having recently been informed by URSA of the proposed use of an existing gas well to begin
disposing of produced water, we, the undersigned, would like this letter to serve as a formal request
to stop the proposed actions. We have been notified either directly through Ursa's oblígation under
COGCC Rule 250 i. and or j., or by our neighbors who have brought awareness of the proposed waste
disposal site neighboring our homes.
We are accustomed to the oil and gas industry and have learned to exist with and benefit from it.
We feel, however, that an actual disposal facilíty containing and inJecting produced water is not
something that should be built in any community of people's homes.
We formally request that the project be stopped. We lnitially would like to site these concerns.
WATER: We drink from and use water from water wells neighborlng the proposed site. We are
concerned with even the smallest chance of water contamination on the surface, near the surface, or
anywhere along the annulus of the well, well casing(s), and cement jobs. Mechanical failure is a
possibility and agaln is not something you put lnto a subdivision of homes. Faulting in these tsle
formations is prevalent adding to the chance of the surface aquifer being contaminated. Future wells
completed in the area can conceivably add to the chance of downhole fluids entering the surface
aquifer. Monitoring the water is always wise; we feel, however, that any detection of produced
water in our drinking water will be at a po¡nt too late to be acceptable
AIR: Produced water, especially known to those of us in the subdivision who have worked around i!
is foul smelling at best. Hydrogen Sulfide Gas, a known contaminant of produced water, at low levels
smells like rotten eggs, at higher levels is deadly. We do not want to add to the air pollution in our
neighborhood even íf it lsn't considered toxic. We site Rangeln CO as an example. We already live
with and accept the diesel and dust associated with the drilling and maintenance of producing wells,
we do not want to see this magnified by adding this large dlsposal complex in the middle of our
neighborhood or anyone else's. Although it may be shown "sâfe" when accident free, we certainly
don't want accidental contam¡nant from the added H2S and waste water airborne particles like our
Colorado neighbors have experienced. We also don't wânt this to make precedent for future
injectlon wells this close to the community.
IMMEDIATE SAFEW: Our nelghborhood is already busy with truck traffic, we do not want to add to
that traffìc by building ân ¡ndustrial facility in the middle of our neighborhood. Our children, friends,
and neighbors, allenjoy the use of the county roads for walklng cycl¡ng, and getting home. Adding a
new potent¡al for environmental spills and involuntary blow off of particulates into the air nearby so
many homes? We don't need more industry than necessary when it comes to accidents and safety.
PROPERW VALUE: We are all concerned with the decrease ¡n property value here where we have
chosen to build or buy our homes. The site area itself is a far rnore massive scar than any drilling pad
in the area. No person can tell us that batterles ofstorage tanks, the transport ofproduced, often
tox¡c, waste water, and the added potential health threats will not reduce the value of our land. We
can all agree this project reduces our land's value.
lN SUMMARY: We do not oppose inJecting waste water 7000 feet into the ground 24 hours a day.
Wþ do feel that Ursa should have the decency, like their peers in the area have demonstrated, to
locate a facility like this away from our land, water, children and schools. We would like this project
relocated immediately. We hope the COGCC can help on this matter and urge everyone to come
look at the project that is underway and visit facilities already in place where waste water is
delivered stored and continually pumped into the ground below. Then decide, it is not something to
put inside a community.
Names and Signatures Below Object to the Proposed Watson B Production Waste Facílity:
P ri nted Name: Er n J 7ti.a.v /X -¡a -¿s
Na 2-/Z */f
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Printed Name Signature/Date ,2 - / ?-'.2o¡5'
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I
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Printed ¡,t" ",ß^,,u/y' {l/rw/ Signature/Date
Printedn^M
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IMMEDIATE SAFETV: Ournelghborhood is already busy wllh truck trafric, we do not w¡ntto add to
thåt trafficby bulldfng an lndustrlal facllity in the mlddle of our neþhborhood. Our chlldren, frlends,
and neþhbors, all enJoythe use of the counryroadsforwalkin& cydlnS, and S,etllng hom€. Addhg e.
new potenl¡ðl for envlronmental spitls rnd lnrrotuntary blow ofr of panlculates into the alrnearby so
many homes? We don't need more ¡ndustry than necessary when it qome¡ 10 sccldents and safety-
pßO?ERTy VALUE: We are ail concerned wlth the ddcrease ¡n property úabe here where lve have
chosen to build or buy our homes. The site a¡ea itçelf ls a far rnors masslve scar than any dritling Ébd
i¡t the afea. No petson G¡n tell us that batterles oi storage tanks, the trârisport of produce4 often
toxic, waste water, and the added potentlal heahh threats will not reduæ the value of our land. We
can all agree this prolect reduces our land's velue.
lN suMtvlARy: we do not oppose fn¡estÎng wastg ïrater 7000 fee: lnto the gmund 24 houn a day.
We do feel tha! Ursa should have the decency, llke the¡r peeË in the area have dernonslrate4 to
locat€ å f"cllíty like thls away from our land, watar, children and schools. We would llke thtsþroJest
relocated lmmedlately. We hope the @GCC c¿n help on this matter and utge everyon€ to come
look at the prôJect üat ¡s underway and v¡slt fadlitles already in place where wÐste unter ls
delivered stqred and contìnually pumped lnto the ground below. Ttren declde, lt ls not somethìnt to
putinside a community.
Names and Si8nätutês Below Obiect tO the Pfopo¡ed Watson I Produft¡on Waste Fadtltg'
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printed Nðme: ,- SÍgneture/Datet- I
printed Name¡ . Signanrre/Datet- I
Pdnted Name: -, - Slgnatuæ/Oate:- /
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Glenn Hartmann
From:
Sent:
To:
Hoyer - DNR, Scott [scott.hoyer@state.co.us]
Friday, June 12,2015 9:16 PM
Glenn Hartmann
Ursa lnjection WellSubject:
Hi Glenn,
Sorry I missed your calls today - I was on the Roan and out of cell service. To answer your question, yes the
Watson site is covered by the Ursa - CPW wildlife mitigation plan. In fact, we just met with Ursa
repressntatives recently to discuss their activities in the area and to review past and current mitigation projects
intended to offset development. At this time, CPW does not have any wildlife related concerns relative to this
development.
Please let me know if you have any additional questions
Scott Hoyer
Scott Hoyer
District Wildlife Manager, Parachute
EXHIBM
I q
I
BIT
å 70
Watson B U.l.C WellJune 2015
Garfield County Permit
Addendum To ERP Plan June ZOL
3.2 Grand Vallev Fire Protection District
Roles of the Grand Valley Fire Protection District include:. Emergency Medical Services, Ambulatory Services, Fire Suppression,
Hazardous Materials Mitigation Fire Prevention, Rescue, Training and Public
Education, and other emergency seruices including ambulance and wild fire
responses.. Provides first response medical services for all injured or ill Company,
contractor, subcontractor, or vendor employees and for site visitors.. Transports injured or ill personnel by ambulance to medical facilities
from Site or related property.. Dispatched by the Garfield County Emergency Communications
Authority and a member of a multi-county mutualaid agreement, aiding
other departments both locally and within the seven member counties.. There are three locations for the Grand Valley Fire Protection District in
Parachute, and they are:o 124 Stone Quarry Roadc 200 Grand Valley Wayo 5797 County Road 309 (unstaffed)
Garfield County Dispatch shall dispatch out to Grand Valley Fire
Protection District and when dispatched, the closest station that is
staffed shall respond f rom either the Quarry Road or Grand Valley
Way f ire stations.
. The phone number is 970-285-91 19 and should only be used for non-
emergency related activities. All emergencies should go through Garfield
County 911.
3.3 Grand River Hospital District
Roles of the Grand River Hospital District include:
o Providing medical treatment of personnel who are ill or have life-
threatening;l jHfJ,i"::fi
lîT:î#jitå:i?3i';'ä:'å"il".J;,Rirre,co
81 650.o ln the event of severe trauma and/or absence of CareFlight
helicopter services (due to availability or adverse weather
conditions), personnel would be ground transported to St. Mary's
totf''"'r,.
Mary's Hospitar is located at 2605 N. 7th street, Grand Junction, co
81 501 .
3.5 St. Marv's CareFlioht Helicopter
ln case of a life threatening situation requiring immediate
medicalattention, the responding EMT or Paramedic will
determine if CareFlight Helicopter Services are necessary.
8.2.4.2 Non-Extinguishable Fire. Report the fire by activating the nearest fire alarm and contacting the
superuisor on duty.. Call 911 and give all needed information, referencing the emergency
numbers listed herein.. Conduct an emergency shut down and evacuate the area.
lf a potential wildfire breaks out, the most important thing is accountability. First
notify someone of the fire. Second, callthe Garfield County 911 Dispatch
immediately. The sooner 911 is dispatched, the quicker the response time.
All fires on federal lands require immediate notification to applicable Ursa
personnel. lf the fire cannot be put out by the fire extinguisher in the incipient
stage, it is time to evacuate the area immediately.
10.2 Reportinq Reouirements
Spills or leaks that can be contained wholly on-site or does not represent a
reportable quantity (RQ) value as per 40 CFR 117 should be reported to
the appropriate Ursa representative.
Spills or leaks that meet or exceed RQ values as per 40 CFR 117 will result
in the contact of the following agencies:
o National Response Center
(8oo-424-8802). EPA Region I - Mountain States
(800-227-8e17)
Spills or leaks which pose a potentialthreaten public health and safety
should be called in to:. Gadield County 911
LI
EXHIBIT
I
Garfield Coúlnty
Community Development Department
SUPPLEMENTAL STAFF MEMORANDUM
TO
FROM:
DATE
Board of County Commissioners
Glenn Haftmann, Senior Planner
June 22,2015
SUBJECT: Continued Public Hearing - Ursa Watson Ranch B Small Injection
Well Administrative Land Use Change Permit
(GAPA-8224)
SU PPLEMENTAL STAFF COMMENTS
1. With the assistance of Kirby Wynn, Oil and Gas Liaison, follow-up
research on the question of impacts to mineral rights from injection well
operations has been initiated. Additional information is anticipated from Stuaft
Ellsworth, with the COGCC. lnitial feedback from Stuaft is that injection wells are
reviewed regarding their relationship to producing formations and that mineral
owners with a Vq mile are notified of the proposed use. More information is
anticipated to be presented at the continued public hearing.
2. The Applicant responded verbally to a number of public comments at the
public hearing. While some of the topics are addressed in the Application
submittals we will request that the Applicant provide a summary of responses to
topics including:
. The make-up of the injection water.. Calculation of injection well capacity and how long the well will operate.
. Geologic barriers above and below the formation proposed for injection.
o Faults in the Battlement Mesa area and their characteristics/potential for
seismic concerns.. Confirmation on the type of combuster to be utilized.. Lightning protection for the injection well.o Any previous or future fracking of wells and the potential for impacts on
the injection well.. Use of the well being limited to Ursa operations only.
1
3. Staff has met with the GarJield County Building Department and confirmed
that the Electric Pump House building will be required to obtain a building permit.
The size of the structure (proposed at 1,000 sq,ft.) is a consideration along with
the fact the structure will be connected to power, house electrical equipment, and
industrial type operations. Staff recommends that the draft condition #3 remains
appropriate for the Board's consideration.
4. The Applicant's submittal contains a very detailed "Field-wide" SPCC Plan
applicable to the Watson Ranch B Site. In accordance with the referral
comments from the County's Consulting Engineer more site specific details for
the Watson Ranch B site are appropriate including more information on
containment areas. However, the requested edits to the condition submitted by
the Applicant at the public hearing (see page 15 of their power point) are
acceptable to Staff and would required the information "within six months of
completion of the construction at the site".
S. The Applicant has provided a response to Condition #5 regarding
updates/edits to the Emergency Response Plan. Staff will review the document
and follow-up with the Grand Valley Fire Protection District. lf the condition has
been satisfied it will be recommended for deletion.
6. At the public hearing the Applicant responded to a number of questions
regarding traffic generation including truck hauling and represented their work
toward implementing pipelines for conveying water to the facility. Condition #12
provides limits on the amount of traffic generation and the use of the designated
haul routes. The Applicant's Traffic Study contains estimates of traffic (Table 3,
pg. 4 see excerpt below) on each of the road segments used for the haul routes
with a range between 12 and 22 one-way trips. This is understood to include
monitoring trips and water hauling trips.
Table 3; lnlectlon Well Brclcoround Trafllc Prolectlons
iϡaflic durlng phrre
2
Tot l
Trafflc lncr.Comtructlon
& Drltllna*
To¡l
Trrfffc lncr.OperetlonrRordwayBackground
Tnfflc
540 7Vo 22 522 4o/ocR 300 500 40
280 14o/"22 262 8o/ocR 3000 240 40
trln405108o/o 22 492cR 303 470
6840 12 6852 <1VocR 300N 6840
382 5s/ø36022cR 308 360
12 287 4a/ocR 309 255 z5ı
Watson Ranch BlnBatection Welllement MesaGarfield CountyBoard of Gounty CommissionersJune 15, 2015IIt!¡bþr'ù.¡tmx.L-g{
Ursa Permit and Land TeamRob Bleil - Regulatory & Environmental ManagerJohn Doose - Landman & Stakeholder RelationsDuke Cooley - Senior GeologistLorne Prescott - Lead Garfield County Permitting ConsultantTilda Evans - Garfield County Permitting Consultantaoooo2OPERAT]NGCOMPANYO\oLssoNuæursaÀssoctArEs
oooProject DescriptionConstruction and operation of a small injection well, akaUnderground lnjection Control, Class ll (UlC), to support the naturalgas development activities of U rsaAll ¡njection well permits are subject to rigorous oversight by theColorado Oil and Gas Conservation Commission (COGCC) andother Federal I state agenciesWater that is no longer recycled associated wrth completion andproduction operations to be injected at this facilityO\oLssoN*OPËRAT]NGCOMMNY3UrsaA$5OCI,ATE5
Permit Scope & BenefitsoPERMIT SCOPE - Application for a centralized disposal well (akaUIC well) for water produced during completion and production ofnatural gas wells in the Battlement Mesa area, outside the BM PUD.BENEFITSBattlement Mesa / the PUD, Parachute, S¡lt and l-70water estimated at 80 - 90% less with UIC wells and water linesin place vs. hauling produced water.Plah in cooperation with Colorado Parks and W¡ldlifeO4
Location1.5 milessoutheast ofParachuteOutside ofBattlement MesaPUDOn Private landAccessed off ofCounty Road 303(Gardner Lane).ooaa
Site Photo wl Sound Walls DuringDr¡lling/Gompletionsr)Nb{þ\,p155ffih,ü ep,-{gûctr\-ii:5ffiUrsaPåffi,il,'
IrtræR¡¡¡üBPrú ¿+ratÉ¡c¡rbt17rOIJOrÇhüctJItcËdlfrbItúb16lPr!ùc.d [rEraco¡drnt¡ffi0ñnpl{tr(¿d¡ltlS.früÊCrlñmtárüFac¡l¡ty LayoutUIC Facilities in upper right (NE) corner of well pad (see below)o One injection wello One battery of low profile 300 bbl storage tanks M total volume of1,800 barrels (bbls) surrounded by 3-ft high containment wallo Pump Houseo One combustoro Electric pumps+50' o' ro(Il-Jt-{CrqlESs¡.hbfthfol-*?íD.tttür7
lnjection Well Uses rNot Just Gas Wellso Food Productiono Municipal Wastewater Treatmento Pharmaceutical Production. Disposal of Fluids from Car Washeso Commercial Disposalo Oil and Gas Production including Petroleum Refiningo Metal Productiono Chemical ProductionIOPERATINGCOMPANYO\oLSSoN*ASSOCIATES
State Perm¡tting Process r Many AgenciesCOGCC KEY PERMITS & REQUIREMENTS. Form 2l 2A- Preapplication Notification/PublicComment Period - no comments received. Baseline Water Sampling (609 Rules). Setbacks from Building Units, ParcelBoundaries... (300 and 600 Rules). Noise and Lighting Requirements (600 and 800Rules). Reclamation (1000 Rules). Waste Management/Spill Plans. 30 Day Statutory Notifications. Form 31 - lnjection permit application. Form 33 - lnjection well permit application. Form 21 - Mechanical integrity test. Form 42 - Notice of notification. Weekly/Monthly Compliance lnspectionsEPA/CDPHE KEY PERMITS & REQUIREMENTS. Air Quality Permit. Stormwater Best Management Practices(BMPs) and Permit - includes inspectionsthrough the lifetime of the well pad. Spill Prevention Control and Counterrneasures(SPCC) - Plan is updated every 5 years. Clean Water Act9ffiUrsaPåffi¡O\oLssoN*AssocrA,TÊs
UIC Permitting ProcessaaDelegated Authority Received from EPAUIC Documents - Forms 31 & 33Proposed injection programSurface owner agreement - specifies SWDNotice to surface and mineral owners - letter sent certified mail to all surface and mineralowners in lq mile area of reviewRemedial corrective action plan for wells - all wells in /+ mile review area must havecement coverage to prevent water migrating vertically to another zoneMaps and list. Map of all wells (oil and gas and water) within Vq mile of injection well. Map of all producing wells in lz mile of injection well. Maps and list of all surface and mineral owners within lq mile of injection wellSurface facility plan viewResistivity or induction logCement bond logWater analysis for injection zoneKeyoaoO\oLSSoN*toaaao10OPERATINGCOMPANYffiFursaASSOCIATES
lnjection lntervalTop of injection interval = 6,272',I.27 Miles, or5.3 Empire State Buildingsnd Levelr* Wasatch f_1nK [tc]Williams ForkProducing lntervalGRILD PorosityThe Watson Ranch BU lC ¡njection intervalis the Cozzette andCorcora n mem bersof the lles FormationROLLTNS [DClcozzErrE [Dc]coRcoRAN lÐcl5IiDclIDç]lDc¡11OPERAT1NGCOMPANYO\oLSSoN*IASSOCI,ATES
Wellbore Schematico Conductoro Surface Casingo Production Casing. lnjectiontubing/packer12O\oLssoN*OPERAT1NGCOMMNYÐepthIIKB:fiDepthftKE:-1Descrìption:Prcductionin: lO:4.892 in:numberlOD:16lD:15.12-tr in.OD:9 5/8ini Depth.2 ftKB; Length:Aai€'.2i281241{(b,lDi:15.L298.0Descrìption:Surface1.750.0 frKE:Cement:Date:2Jz\i?i1+iiJDj:298.Ð-2,a09.0Descdptìon:Conduclor Cement:Bepth {lrlÐJ: 1 5.!75.ü ftKB;Date:1¡1t2014Description:Froduction Casin gTail Cement: Deplh(l,f Dì:2.409. tl3.424. û ftKB;Oate:2128i2014Item numbei3:Description:Production. 0D:5{¡,'lD}:15 5-6..424.4Lengrth:6.4riB-86 ft(l',lDl:15.5-90-5Lenglh:75-00 ftItem numberz:i[,lDj:15.51.714,66Desciplion:Production CasingLead Cement: Depthì/ertrcal schematic (actualJrdD{ftKEjIncl ('ìtllU{fiKBlffiUrrsaASSOCIATEg
Legende lnjection Well Earthquakeil-*"1 tu¡r.u Verde outcropCOGCCpro!idedloÉtions proyided bïthe USGS-::1""".-rìl: Y,^Å4A¡lÛFF,alfCÛIINTYtl.ilÂÂi::. "".Å(Ê¡-¡trIT {,_r,r.lt.tit )ÅoÅaLAll recorded seismic activity from1975-PresentSeismic events are localized atedge of basinRecorded seismic events are notrelated to Oil & Gas DevelopmentooIRtù ÊL4r'rtI{.I!ÜILINT Ya¡.j:{3.o¡O¡a*--cElIIIIo^l,'Wì'C.prrpr noI ciliÌì,*^El\tjt.Er: ül_rNT îoAce^ooto*Aoa-. -oooo.} i'/toPITr^1il_(!äbf-nÞÞH,of¡Lf ¡.qI{]U NTÏ^^oo^^a'i^^ '-)etstr,.li.ITYl_;li¡,r- rìl I'î¿¡Â13O\oLSSoNoOPMAÏNGCOMPANY''...."'.*.ASSOCIATES
Garti eld Countylnfection Well Perm¡tCond¡tions of Approval
Cond¡t¡on 4Ursa requests Condition 4 be modified as followsPrier te issuenee ef the t and Use ehange Permit, The Applicantshall provide site specific details in an update or addendum to theSPCC Plan addressing site specific details for the Watson Ranch Bsite within six months of comletion of construction at the site'. TheApplicant shall comply with all SPCC Plan provisions and shall keepthe pan current and updated for any changes to the facility.According to SPCC Rules, final site specific information is required withinsix months of completion of construction at the site.15ffiUrsagff**,'O\oLSSoN*ASSOCIATES
Ursa w¡ll comply with allOther Cond¡tions of Approval.O\oLssoNuOPERATINGEOMPANYASSOCIATES
Gommunity OutreachUrsa has held a number of meetings including one-on-one rneetings withLandowners to address concerns in the Battlement Mesa Communityand will continue to do so. Community meetings have included:o Air Quality Presentation - January 22,2014o Green Completions Presentation - March 1 2,2014o Injection Well Presentation - May 23,201417
aCommunity OutreachActions to Address Stakeholder Concerns (post meetings)regulations.Ursa has demonstrated sensitivity to traffic concerns and intwo cases rescheduled operations to accommodate School &Community EventsGeology of the Piceance Basin presentation - June 15, 2015oo18O\oLSSoN*OPERATINGCOMPAI-lYASSOCIATES
lniection Well Outreach and BenefitsoWatson Ranch B lnjection Well replaces the G Pad well inside thePUD planned since 2009.Community Concerned Citizens UIG Meeting - March 5 ,2015Battlement Mesa UIC Gommunity Meeting - March 10, 2015were availableKey Community Concern - Trafficwell / water lines installed.Key Community Concern - Noise during UIC operationbuilding; increase voluntary noise monitoringOoooaSakman lnection Well - Orated without incident
Questions?Thank you20O\oLSSoN*OPERATINGCOMPAf{YASSOCIATES
Watson Ranch Blnfection WellBattlement MesaGarfield GountyBoard of County CommissionersJune 22,2015(June 1 5, 2015 Hearing Continuance)
This Update complements the June 15,201 5 presentation to the BOCC> Addresses key issues requested to be addressedby the community or Garfield County Board ofCounty Commissioners2OPFfiATINGCOMMNYO\oLSSoN*...'.,UrsaASSOCIATES
Location1.5 milessoutheast ofParachute townboundaryOutside ofBattlement MesaPUDOn Private landAccessed off ofCounty Road 303(Gardner Lane).ooao3
Y.ûmû R¡¡¡ù BPrú c*r¡Cdr&rÊ¡nrHill¡lrrcl1750JJilL5úa¡rlolrt¡ollftlrllrt16¡Pr!fro¡d hErraGaadï.ltÉ0ft?r¡ütcñ.ittllTanuottttc¡rndrüdtïlllLAËrFacility LayoutUIC Facilities in upper right corner of well pad (see below)o One injection wello One battery of low profile 300 bbl storage tanks M total volume of1,800 barrels (bbls) surrounded by 3-ft high containment wallo Pump Houseo One combustoro Electric pumps+q lüt'l-.r+læ¡shLhthtæ-*ãlDüfff.t4
Permit Clar¡f¡cations r GeologyUnderground lnjection Control, Class ll (UlC), to support the naturalgas development activities of Ursa.formation that will not communicate (isolated) with plannedproduction wells, hence will not affect mineral production I royalties.water (>10,000 ppm TDS per EPA and COGCC).determined by the COGCC based on the Form 31 I 33 process.
Perm it Cl arifications r lnfrastructurewells in the Battlement Mesa area and,will be for Ursa's sole use...no otherOperators permitted.in the Battlement Mesa area...one well cãn't handle all produced water...basedon COGCC prescribed injection limits.with the gas pipeline) servicing the well pad.Watson Ranch A and Speakman A well pads (UlC well at the Speakman A hasbeen operating for several months). Speakman A line is temporary and is notburied at this time.6
Permit Clar¡fications r SeismicBasin based on geological faults prone to earthquakes. His information, andthat of CSU show limited, if any potential for earthquakes.is approximately 6,200', reactivation of a basement fault highly unlikelybecause there are no active faultsbefore injection permit is issuedproposed UIC well, one is located as close as 13 miles7OPERATINGCOMHANYO\oLssoN*ASSOCIATES
Seismometersr-slls-l:.Taiii\i:11,lr¡ a :;:ì,'\ì*ii.i:RCCOCECOLECOCNCO25.934.733.7*-l-3 * **LECO not on state map,Listed on CMU's website**Station CNCO is theclosest Seismometer toBattlement Mesa, Stationlocation was not availableon CMU website, distanceis approximate8Seis moûrête r l¡êtrvorks0 n¡opql É¡n¡q¡¡Írr¡lm¡ËgnCçrtËr ÈrÊrclQ us eunu olnrl¡ffiqpu{usBuRlt ço¡o¡¡oc ti?p U¡ìwrlty {çÌtulÜ ¡¡¡tout errffiulp ror o{cuÞ¡fioÊ¡t 9¡tÈ?y ¡ñú &¡ïh lrtesHlhttp://coloradogeologicalsu rvev.orglgeologic-haza rds/ea rthq ua kes-2/seismom eter-networks/htto://www.coloradomesa.edu/eeosciences/CM UGeosciencesSeismicl\letwork. htmlO\oLSSoNuOPERATINGCOMHANYÈL *49*aif,EMæfU¡¡€Ô{{oËmaffi*{bBÉÞ{¡{ôl(HVÆII]s¡rümmñr#J?S.rzseÊr9 cr¡iof,": 'Sco0*ec @eoeffiffiffiUrsaASS0CrAfES
You have to check the data. On the map provided during theprevious hearing, you can clearly see"ROCKS NOT MAPPED - Datalnadequate", this is for areas not colorfilled which includes Battlement Mesahttp://nemd b.usss.eov/Prodesc/proddesc 4802. htmThe2 faults are greater than 5 milesfrom UIC wellThe faults on the map are NOT activebasement faults, not related to anyrecorded seismic activityDepth from lles Formation toBasement *6,2O0" highly unlikelyinjection water would reactivatebasement faultsI{GMDBHaldingrFi¡te l-: Ë;r-:lngii þ1aÊ oiih* Pr-ec,:mbri,rn Ela:*r*nt lr [o]c¡rarlrûov'nloads. Sçr¡en ili;¡;;ii 1r;€':1 iJ|'lþi'' Fliiì: C:ììinì;:*C i1-ii'd!:1-?lì:,1¡:::!::l | -i ll0i1lC,iE:':i,,ie i3r-e¡:i i,: iE4öK:GaagiÈ [ÉliiASSOCIATES:È è: !r .:'É=-: ,. t:i i ^ t::: ¡ c :1.. 1i c -:: cf,:;: Taaa:":i+:'.r'- c;c c' - : -.:..:::: :. - +. :r' '."'' .,. !".::IOPERÆINGCOMPANYO\oLSSoN*+IUrsa
Permit Clarifications r General Concernsstorm and an Emergency Response Plan is in place.returned to the ground) over the life of the injection well.being injected...which isn't the case...see 99.95% above. KEY NOTE: Thewater is being injected into a geological formation that doesn't meetwater use standards...lìow or in the future.spill prevention and response plan is already in place.10
Permit Clarifications r General Goncernslighting storm and an Emergency Response Plan is in place.returned to the ground) over the life of the injection well.being injected...which isn't the case...see 99.95% above. KEY NOTE: Thewater is being injected into a geological formation that doesn't meetwater use standards...llow or in the future.spill prevention and response plan is already in place.11
Cond¡t¡ons of Approval Updatebuilding the pumphouse. Request that submittal of buildinq desiqndrawinqs prior to issuance of the permit not be a Condition ofApproval. The building has not yet been designed.The Applicant shall provide updated information on the pump housestructure to address referral comments from the County's ConsultingEngineer, Chris Hale dated 614115 when apply¡ng for building permitsfor the structure as required by the County Building Department12
Cond¡tions of Approval UpdatecoA.Response Plan to address Grand Valley Fire Protection District'scomments.O\oLSSoNuOPERATINGCOMMNYUrsaASs0crATES
Questions?Thank you14