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Home My WebLink About1.00 General Application MaterialsTPR 176-25 Underground Injection Control Well Application Form CPX Piceance Holdings, LLC 34 S. Wynden Drive, Suite 240 Houston, TX 77056 TPR 176-25 Underground Injection Control Well Payment Agreement Form CPX Piceance Holdings, LLC 34 S. Wynden Drive, Suite 240 Houston, TX 77056 TPR 176-25 Underground Injection Control Well Statement of Authority Form CPX Piceance Holdings, LLC 34 S. Wynden Drive, Suite 240 Houston, TX 77056 TPR 176-25 Underground Injection Control Well Pre-Application Summary CPX Piceance Holdings, LLC 34 S. Wynden Drive, Suite 240 Houston, TX 77056 TPR 176-25 UIC Well Pre-Application Summary Administrative Review 1 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 CPX Piceance Holdings, LLC held a pre-application meeting about the proposed TPR 176-25 Underground Injection Control (UIC) Well on March 18, 2022. Glenn Hartmann and Phillip Berry from the Garfield County Community Development Department participated. Garfield County did not provide CPX with a pre- application meeting summary. TPR 176-25 Underground Injection Control Well Administrative Review Application Narrative Article 4 Section 203.B.5. - Project Description CPX Piceance Holdings, LLC 34 S. Wynden Drive, Suite 240 Houston, TX 77056 September 2022 CPX TPR 176-25 UIC Well Article 4 Section 203.B.5. - Project Description Administrative Review Application Narrative Administrative Review 1 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 TABLE OF CONTENTS 1. Introduction .......................................................................................................................................................................... 2 2. Project Description ............................................................................................................................................................. 2 2.1. Project Background .................................................................................................................................................. 2 2.2. Location Description ................................................................................................................................................ 3 2.3. Colorado Oil and Gas Conservation Commission Permitting .................................................................. 4 2.4. Facility Specifications and Equipment .............................................................................................................. 6 2.5. Operational Phase Timeframes ........................................................................................................................... 6 3. Purpose and Need ............................................................................................................................................................... 7 4. Location ................................................................................................................................................................................... 7 5. Adjacent Parcels and Property Landowners ........................................................................................................... 8 6. Section 4-202 Waiver of Submission Requirements ............................................................................................ 9 6.1. Section 4-203 J. Development Agreement ...................................................................................................... 9 6.2. Section 4-203 K. Improvement Agreement .................................................................................................... 9 6.3. Section 4-203 L. Traffic Study .............................................................................................................................. 9 7. Section 4-118 Waiver of Standards .......................................................................................................................... 10 7.1. Section 7-107 Roadway and Design Standards ......................................................................................... 10 7.2. Section 7-104. SOURCE OF WATER ................................................................................................................ 10 7.3. Section 7-105. CENTRAL WATER DISTRIBUTION AND WASTEWATER SYSTEMS .................... 11 7.4. Section 7-106. PUBLIC UTILITIES ................................................................................................................... 11 7.5. Section 7-109.B. Subdivisions. .......................................................................................................................... 11 CPX TPR 176-25 UIC Well Article 4 Section 203.B.5. - Project Description Administrative Review Application Narrative Administrative Review 2 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 1. Introduction CPX Piceance Holdings, LLC (CPX), the Applicant, is pursuing an Administrative Review in Garfield County, Colorado for the development of an underground injection control (UIC) well, the TPR 176-25 UIC Well. The proposed UIC well will be located on an existing oil and gas location on private property, owned by CPX, approximately 12 miles south of Rifle, Colorado. The proposed TPR 176-25 UIC Well is classified as a Small Injection Well under Article 15 of the Garfield County Land Use and Development Code (LUDC) because it will have less 5,000 barrels of appurtenant and accessory on-pad tanks. The TPR 176-25 UIC Well’s main function will be to accommodate the disposal of produced water from natural gas wells operated by CPX. 2. Project Description The following narrative addresses the requirements for the Project Description under Article 4 Section 203.B.5 of the Garfield County LUDC. 2.1. Project Background CPX proposes to convert an existing drilled but uncompleted (non-producing) natural gas well, TPR 176-25, to a Class II UIC well. The TPR 176-25 is located on TPR Well Pad 25A, an existing oil and gas location with two producing natural gas wells, on Tepee Park Ranch (TPR) in Garfield County. CPX owns 100 percent of the surface acreage underlying the TPR Pad Well Pad 25A location. CPX proposes to convert the existing TPR 176-25 into a Class II UIC well to provide disposal for water from well completions and produced water from natural gas wells developed and operated on TPR. CPX is not proposing any additional surface disturbance beyond the existing footprint of the TPR Well Pad 25A location. The conversion of the TPR 176-25 into a Class II UIC well will not result in additional surface disturbance and will allow CPX to significantly reduce truck traffic on public county roads. The TPR 176-25 was drilled in 2013. The well was drilled through the Williams Fork, Iles, and Mancos Shale and reached total depth in the Niobrara Formation. Soon after, it was plugged back to the Iles, but perforations and a completion were never attempted by the previous operator. CPX is proposing to convert the TPR 176-25 for use as a Class II UIC well to support CPX’s development plans on TPR and allow it to reduce truck traffic associated with completions and production activities. The proposed injection zone is the Rollins, Cozzette, and Corcoran Members which, collectively, make up the Cretaceous Iles Formation. The Iles Formation is directly below the Cameo Coal Zone in the lowest portion of the Williams Fork Formation. CPX TPR 176-25 UIC Well Article 4 Section 203.B.5. - Project Description Administrative Review Application Narrative Administrative Review 3 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 The proposed UIC well will result in efficiency and reduced impacts for the disposal of produced water and water from well completions generated during operations on TPR. Because CPX is the owner of the surface and the minerals in addition to being the operator, the long-term, responsible management of TPR is important to CPX. The proposed UIC well is a critical component in CPX’s comprehensive plans to drill and operate natural gas wells efficiently and safely at TPR. The proposed UIC well will allow CPX to inject the water generated during completions and the produced water from the proposed natural gas wells on TPR Well Pad 25A and from future natural gas development on additional surface locations on TPR. Due to TPR’s remote location, transporting water to commercial disposal facilities involves hauling water long distances and results in increased truck traffic. The proposed UIC well will allow CPX to significantly reduce the truck traffic necessary for water management and disposal. Transporting the completions water and produced water through the TPR flowline system to an on-site UIC well will also reduce the chance for spills and vehicle accidents associated with water disposal. CPX intends to utilize a 5-inch Flexpipe (non-corrosive) flowline to service the proposed injection well. TPR Well Pad 25A will have approximately 4,750 barrels of on-pad storage for produced water, part of which will be used to store produced water for injection in the proposed UIC well.1 There will be no third-party commercial use of the well. 2.2. Location Description TPR Well Pad 25A (COGCC Location ID 334457) is an existing well pad with two producing natural gas wells. TPR Well Pad 25A is located on TPR on the below lands in Garfield County: SW¼SE¼, Sec. 25, T7S R94W 39.404522, -107.832789 The existing location is 5.5 acres with a working pad surface of 2.6 acres. After interim reclamation, the working pad surface will be reduced to approximately 1.8 acres. CPX is not proposing any additional surface disturbance for Well Pad 25A beyond the existing footprint of the TPR Well Pad 25A location. 1 Not all of the produced water storage on TPR Well Pad 25A will be devoted to supporting the proposed injection well. At the maximum anticipated injection rate, CPX anticipates that approximately 3,000 barrels of storage will be needed to support the injection well operations. In addition to the produced water storage, Pad 25A will also contain one 750 bbl condensate tank and a 300 bbl blowdown tank that will be used to control wellbore emissions from the natural gas wells on Pad 25A in the event a well on Pad 25A needs to be unloaded. The condensate tank and blowdown tank will not support the proposed UIC well. CPX TPR 176-25 UIC Well Article 4 Section 203.B.5. - Project Description Administrative Review Application Narrative Administrative Review 4 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 The subject parcel is not adjacent to any residential zoned parcels. The nearest residence is approximately 1.7 miles to the northwest. The proposed UIC well is located approximately one-half mile from the nearest public road. The following cultural features are located greater than one mile from the proposed UIC well: • Residential Building Unit • High Occupancy Building Unit • School Facility • Designated Outside Activity Area Only one water well exists within one mile of the proposed UIC well. The water well is owned by the Applicant, CPX. Water well details and map are provided in Maps and Plans tab. The TPR location is described in more detail in Section 4 below. 2.3. Colorado Oil and Gas Conservation Commission Permitting The TPR 176-25 UIC Well will be permitted as a “CLASS II UIC WELL”, as defined by the Colorado Oil and Gas Conservation Commission (COGCC) below: CLASS II UIC WELL means Wells which inject Fluids: Which are brought to the surface in connection with natural gas storage operations, or conventional oil or natural gas production and may be commingled with waste waters from gas plants which are an integral part of production operations, unless those waters are classified as a hazardous waste at the time of injection. CPX designed the proposed TPR 176-25 UIC Well to comply with and meet the standards set forth in COGCC’s 800 series rules, which govern the permitting and operation of Class II UIC wells. The proposed TPR 176-25 UIC Well is included in CPX’s Oil and Gas Development Plan (OGDP) application for the TPR Pad 25A OGDP. The TPR Pad 25A OGDP application requests approval from COGCC for the continued use of the existing TPR Well Pad 25A to drill and develop an additional 34 natural gas wells and to convert the existing TPR 176-25 into a Class II UIC well. Following full development, the TPR Well Pad 25A location will contain 36 natural gas wells and one Class II UIC well for a total of 37 wells. Because the continued use of the TPR Well Pad 25A location does not require an Alternative Location Analysis under COGCC Rule 304.b(2).B and CPX is not requesting a variance from the COGCC noise or lighting requirements, the TPR Well Pad 25A location does not require a Land Use Change Permit from Garfield County. CPX TPR 176-25 UIC Well Article 4 Section 203.B.5. - Project Description Administrative Review Application Narrative Administrative Review 5 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 CPX submitted a Form 31 Underground Injection Formation Permit Application – Intent, a Form 33 Injection Well Permit Application – Intent, and a Form 2 Application for Permit to Recomplete and Operate for the TPR 176-25 UIC Well to COGCC concurrent with the TPR Pad 25A OGDP application. The pending COGCC permit applications listed below include the proposed TPR 176-25 UIC Well: • Oil and Gas Development Plan (OGDP) – Well Pad 25A (Docket # 220300066) • Form 2A – Location Assessment for TPR Well Pad 25A (Document # 402860020) • Form 31 – Underground Injection Formation Permit Application – Intent (Document # 402948794) • Form 33 – Injection Well Permit Application – Intent (Document # 402985833) • Form 2 – Application for Permit to Recomplete and Operate (Document # 403056476) In addition to the proposed natural gas well development on TPR Well Pad 25A, CPX anticipates that the TPR 176-25 UIC Well will support additional natural gas well development on TPR. CPX has plans to develop an additional 68 natural gas wells from two additional locations on TPR. CPX also submitted an OGDP application for a Temporary Water Support Pad, Pad 25B to the COGCC. Pad 25B will provide temporary water storage to support CPX’s completion operations on TPR. CPX submitted a 30-day notice letter to Garfield County on June 6, 2022, regarding its intent to submit an OGDP application for Pad 25B. CPX submitted the TPR Pad 25B OGDP application on July 28, 2022 and submitted a Notice of Director’s Completeness Determination to Garfield County on August 25, 2022. CPX is the surface owner and mineral owner for all four of the existing and proposed oil and gas locations listed in Table 1 below. All four locations are subject to permitting and approval from COGCC. CPX’s proposed development on the existing Pad 36A will also require a Land Use Change Permit from Garfield County. CPX had a pre-application meeting with Garfield County about Pad 36A on September 15, 2021. Table 1: Well Pads to be Supported by Proposed UIC Well Well Pad # Of Producing Wells COGCC Location ID Form 2A Location Assessment Estimated Timeframe for Form 2A Submittal Well Pad 25A 34 Proposed 2 Existing 334457 Amend Existing Location Submitted. Hearing Scheduled for August 8, CPX TPR 176-25 UIC Well Article 4 Section 203.B.5. - Project Description Administrative Review Application Narrative Administrative Review 6 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 2022 Well Pad 36A Up to 34 Proposed 334460 Amend Existing Location 4th Quarter 2022 Well Pad 31 Up to 34 Proposed N/A New Location 2023 Temporary Water Support Pad 25B N/A N/A New Location 3rd Quarter 2022 2.4. Facility Specifications and Equipment The TPR 176-25 UIC Well will include the following equipment and components. A Process Flowline Diagram, which details proposed flowlines to be installed at the facility, is included in the Maps and Plans tab. Table 2: TPR 176-25 UIC Well Equipment List Qty Description COGCC Category 1 1000-bbl Gunbarrel Tank (16 oz / in2, steel) w/ 0.5 MMBTU / hr burner Produced Water Tanks 5 750-bbl Produced water Tanks (16 oz / in2, steel, API 12F) w/ 0.5 MMBTU / hr burner Produced Water Tanks 3 Power Generation Units (200 kW each) Electric Generators 2 Salt-Water Disposal Charge Pumps Other Permanent Equipment 2 Salt-Water Disposal Filters Other Permanent Equipment 2 Salt-Water Disposal Injection Pumps Other Permanent Equipment 2.5. Operational Phase Timeframes Subject to permit approval and equipment availability, conversion of the existing TPR 176-25 into a Class II UIC well is planned to occur in Q1 2023. There will be a total of 2 stages during the operational lifetime of the UIC well. The stages and estimated timeframe for each stage is listed below: • Conversion of the Existing Uncompleted Well into a Class II UIC Well – 14 days • Operation of the Class II UIC Well – 30 years CPX TPR 176-25 UIC Well Article 4 Section 203.B.5. - Project Description Administrative Review Application Narrative Administrative Review 7 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 Conversion of the existing well to a UIC well will take approximately 14 days. Activities include perforation and fracturing the injection zone followed by installation of tubing and pumps. At this time of application submittal, CPX does not have a timeline for plugging and abandonment. On average in the TPR operations area, a well may be produced for 30 years. Plugging and abandonment of the UIC well will depend on the schedule of the producing wells within TPR. Closure procedures at the time of closure will influence time interval associated with reclamation activities. Inspection activities will occur throughout operations and will coincide with other stages. Inspection activities will vary and may include (but not limited to): noxious weed and stormwater inspections, government agency compliance inspections, housekeeping, maintenance, and sampling. CPX will obtain all necessary permits from the Garfield County Community Development Department and COGCC as required before the start of any future construction activities associated with the proposed UIC well. 3. Purpose and Need The long-term, responsible management of TPR is important to CPX. The purpose of the proposed UIC well is to allow CPX to efficiently and safely manage water from well completions and produced water from the planned natural gas well development on TPR by significantly reducing truck traffic associated with the development and operation of natural gas wells on TPR. The proposed TPR 176-25 UIC Well will allow CPX to transport water from well completions and produced water from the proposed natural gas wells on TPR Well Pad 25A, as well as from any future natural gas wells on additional surface locations on TPR, through the TPR flowline system and dispose of that water into an on-site injection well. The proposed TPR176-25 UIC Well is needed because transporting water to commercial disposal facilities from TPR’s location requires many miles of truck traffic. The proposed UIC well will allow CPX to significantly reduce the truck traffic necessary for water management and disposal. This will reduce impacts from truck traffic and will also reduce the chance for spills and vehicle accidents associated with water disposal. 4. Location The proposed Class II UIC well will be located on TPR, a 1,664-acre parcel in an unpopulated, remote rural area of Garfield County. CPX TPR 176-25 UIC Well Article 4 Section 203.B.5. - Project Description Administrative Review Application Narrative Administrative Review 8 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 The proposed UIC well will be located on an existing oil and gas pad, TPR Well Pad 25A. The site is located approximately 12 mapped miles southwest of Rifle, Colorado, and located approximately 3.5 access miles from County Road 317. The facility will be easterly located on parcel 1917-274-00-012. The legal description of the site is SW¼SE¼, Section 25, Township 7 South, Range 94 West of the 6th Principal Meridian, Garfield County. An access road to the site location is maintained and owned by CPX, the Applicant. Well and Location Information Well Name: TPR 176-25 Well API Number: 05-045-22153 Location Name: TPR Well Pad 25A Legal Description: SW¼SE¼, Section 25, Township 7 South, Range 94 West Location Coordinates: Latitude: 39.404522; Longitude: -107.832789 Elevation: 9,129 feet CPX, the Applicant, owns 100 percent of the surface acreage on TPR, including the lands underlying the TPR Well Pad 25A oil and gas location. CPX also owns 100 percent of the fee interest in the minerals in the injection lands for the proposed TPR 176-25 UIC Well. The Special Warranty Deed for TPR (Reception # 861903) is provided in the Parcel Details tab. Table 3. Parcel Ownership Information Surface Owner Surface and Mineral Owner Address Parcel Number Zone District Parcel Size CPX Piceance Holdings, LLC Operator # 10639 CPX Corporate Office 34 S. Wynden Drive, Suite 240 Houston, TX 77056 245306100005 Rural 1664 Acres 5. Adjacent Parcels and Property Landowners All adjacent parcels are located within Garfield County and are zoned Rural or Public Lands. The Adjacent Parcel Map is located in the Parcel Details tab. The nearest adjacent parcel is owned by CPX, the Applicant. Throughout the subject land use application, the parcel boundary distances will be based on the nearest boundary with a different surface owner. The nearest parcel boundary, owned by the White River National Forest, is located to the north. The proposed UIC well will be located approximately 2,200 feet from the nearest parcel boundary (owned by a different surface owner) to the north. Adjacent parcels are owned by the Applicant and National Forest Service. All adjacent parcels are larger than 1,000 acres. All adjacent parcels are located within Garfield County and are zoned Rural or Public Lands. CPX TPR 176-25 UIC Well Article 4 Section 203.B.5. - Project Description Administrative Review Application Narrative Administrative Review 9 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 An address list of real property adjacent to parcel 2453-061-00-005, the mailing address for each of the property owners and the appropriate portion of a Garfield County Assessor’s Map showing the project site location and all public and private landowners adjacent to the subject parcel are provided in the Parcel Details tab. 6. Section 4-202 Waiver of Submission Requirements 6.1. Section 4-203 J. Development Agreement CPX requests a waiver for the Development Plan, Section 4-203(J) of the Garfield County LUDC. The proposed project is an industrial use and will solely be owned by the Applicant. The Development Agreement is not applicable to the proposed UIC well because the applicant does not seek to enter into a development agreement. 6.2. Section 4-203 K. Improvement Agreement CPX requests a waiver for the Improvement Agreement, Section 4-203(K) of the Garfield County LUDC. The proposed UIC well will not require the installation of public utilities nor will increase demands on public facilities. The UIC well location is remote and is currently used for oil and gas activities. The Improvement Agreement is not applicable to the proposed UIC well because the remote location will not require the installation or improvements of public facilities. 6.3. Section 4-203 L. Traffic Study CPX requests a waiver from the Section 4-203(L).1.c requirement to submit a traffic study prepared by a professional engineer. The development of TPR176-25 UIC well will not increase vehicular traffic during operations since vehicles will access the proposed site from other oil and has locations within CPX’s private property. Average daily traffic will increase on CR 320 and CR 317 for 6 non-consecutive days during a 14-day period during the UIC well conversion. The increase in traffic is not anticipated to be significant. Vehicles will consist of large equipment transport vehicles and pickup trucks. Vehicle activities during well conversion will consist of approximately 56 large equipment transport vehicles trips and 34 pickup truck trips. Long-term traffic impacts are not anticipated from the development of the UIC well. After UIC well conversion, no vehicles are expected to access the site solely from public roads. CPX TPR 176-25 UIC Well Article 4 Section 203.B.5. - Project Description Administrative Review Application Narrative Administrative Review 10 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 An average of one pick-up truck will access the subject location from within TPR operations area during established operation phases which includes inspection and maintenance activities. Operation of the UIC well is also anticipated to have a net positive impact on traffic volumes. CPX estimated that transporting water from TPR to a commercial disposal facility using water-hauling trucks would result in approximately 30,000 large vehicles accessing county roads during pre-production activities for the three proposed well pads on TPR. Utilizing the UIC well for disposal of produced water during the production phase of the proposed natural gas wells is also anticipated to significantly reduce truck traffic needed for water hauling over the life of the well. The TPR 176-25 UIC Well Traffic Summary is provided in the Impact Analysis tab 7. Section 4-118 Waiver of Standards 7.1. Section 7-107 Roadway and Design Standards In accordance with Policy 01-14 Waiver for Roads and Demonstration of Compliance, CPX requests a waiver for the Roadway and Design Standards, Section 7-107 of the Garfield County Land Use and Development Code for CPX’s existing private access road. CPX’s private access road on Tepee Park Ranch was constructed, and is maintained, to provide safe access to the existing well pads and natural gas wells on Tepee Park Ranch. The proposed use of the Tepee Park Ranch road to develop the TPR 176-25 UIC Well is consistent with the existing use of the road, and the road is adequate for the proposed use. The road does not provide for any public access. A Professional Engineer (P.E.) from Mountain Civil Consulting assessed the private roadways the Tepee Park Ranch access road and determined that the access road is safe and adequate for the proposed, and current, industrial traffic. The P.E. Assessment Letter (Policy 01-14), which includes photos and cross sections, compares the existing roadways to Table 7-107 Roadway Standards is provided in the Access Road Waiver in the Standards tab. 7.2. Section 7-104. SOURCE OF WATER CPX requests a waiver to the standard Sufficient Adequate, Legal, and Physical Source of Water, Section 7-104 of the Garfield County LUDC. The standard is not applicable to the proposed use, a Small Injection Well. The proposed facility will not require a long- term water source for personnel or for the proposed use. CPX TPR 176-25 UIC Well Article 4 Section 203.B.5. - Project Description Administrative Review Application Narrative Administrative Review 11 CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 A temporary and limited amount of water will be needed for initial well conversion. CPX plans to use recycled produced water sourced from a third-party operator for this. A long-term is not required for continued operation of the well. In regard to personnel, during conversion and initial operational activities, personnel will access the site daily until the injection well is in full operation. Once operations are established, Well Pad 25A will be accessed approximately daily for inspections and other regular operational work. But Well Pad 25A and TPR 176-25 well will not have personnel staffed at the site on a regular continuous basis. Due to the minimal and intermittent presence of employees onsite, drinking water use will not be required onsite during operations. Drinking water will be provided to personnel in the form of bottled water. 7.3. Section 7-105. CENTRAL WATER DISTRIBUTION AND WASTEWATER SYSTEMS CPX requests a waiver to the standard “Adequate Central Water Distribution and Wastewater Systems,” Section 7-105 of the Garfield County LUDC. The standard is not applicable to the proposed use. The subject use, Small Injection Well, is not served by an existing public collection system or treatment facility nor is an on-site wastewater treatment system proposed. During operations, personnel will not be required to be manned at the site full-time. Due to the minimal presence of personnel onsite, a wastewater use will not be required onsite. 7.4. Section 7-106. PUBLIC UTILITIES CPX requests a waiver for the standard “Public Utilities,” Section 7-106 of the Garfield County LUDC. The standard is not applicable to the proposed use. The proposed use, Small Injection Well, does not require the use or installation of any public utilities. 7.5. Section 7-109.B. Subdivisions. CPX requests a waiver for the standard “Fire Protection: Subdivisions”, Section 7-109 B. of the Garfield County LUDC. The standard is not applicable to the proposed use. The site will be an industrial use and no division of land will occur. Administrative Review CPX Piceance Holdings, LLC Garfield County, Colorado 34 S. Wynden Drive, Suite 240 2022 Houston, TX 77056 TPR 176-25 Underground Injection Control Well Application Materials Tab Table of Contents 1. Application Form 2. Payment Agreement Form 3. Statement of Authority Form 4. Pre-Application Summary 5. Application Narrative and Project Description