HomeMy WebLinkAbout1.17 Impact Analysis and Narrative
TPR 176-25
Underground Injection Control Well
Impact Analysis Narrative
Article 4 Section 203.G.
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.G. – Impact Analysis
Impact Analysis Narrative
Administrative Review 1 CPX Piceance Holdings, LLC
Garfield County, Colorado 34 S. Wynden Drive, Suite 240
2022 Houston, TX 77056
1. Introduction
The following section addresses the requirements for the Impact Analysis under Article
4 Section 203.G. of the Garfield County Land Use and Development Code (LUDC).
The Impact Analysis shall provide a description of the impacts that this proposed land
use change may cause, based upon the standards that the proposed use must satisfy.
The application includes exhibits and descriptions of how CPX Piceance Holdings, LLC
(CPX) will ensure that impacts will be mitigated, and standards will be satisfied in the
development of the TPR 176-25 Underground Injection Control (UIC) Well.
2. Section 4-203 (G) 1. Adjacent Land Use
Existing use of adjacent property and neighboring properties within 1,500-foot radius.
Existing use of adjacent property and neighboring properties are natural resources
extraction and public lands. Adjacent parcels are zoned Rural or Public Lands. No
additional impact would occur to the abutting property owners from conversion and
operation of the TPR 176-25 UIC Well. The proposed site is located on a 1664-acre
parcel. 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.
3. Section 4-203 (G) 2. Site Features
A description of site features such as streams, areas subject to flooding, lakes, high
ground water areas, topography, vegetative cover, climatology, and other features that
may aid in the evaluation of the proposed development.
The environmental setting for Well Pad 25A is aspen woodland with an understory of
native forbs and grasses. They include Kentucky bluegrass, blue wildrye, red
baneberry, Porter’s licorice-root, tall ragwort, Fendler’s meadow-rue, Columbian
monkshood, Thimbleberry, Tall fleabane, Richardson’s geranium, and Mountain brome.
The average annual precipitation for the area is approximately 16.55 inches a year. This
data was collected from the Western Regional Weather Center at the Altenbern
Colorado weather station, which is located west of the proposed site location.
Precipitation data was collected from 2000 to 2021.
Table 1: Monthly Precipitation Average*
JAN
FEB
MAR APR MAY JUN JUL AUG SEP OCT NOV DEC Annual
Average
Annual
Precipitation
Average
(Inches)
1.12 1.15 1.38 1.37 1.55 0.65 1.3 1.64 1.77 1.82 1.13 1.56 16.55
CPX TPR 176-25 UIC Well
Article 4 Section 203.G. – Impact Analysis
Impact Analysis Narrative
Administrative Review 2 CPX Piceance Holdings, LLC
Garfield County, Colorado 34 S. Wynden Drive, Suite 240
2022 Houston, TX 77056
*Monthly Preciptation for Alternbern,CO. Source: https://www.weather.gov/wrh/Climate?wfo=gjt
Evaporation rates were not collected at the Altenbern weather station. An evaporation
rate approximately 40-45 inches a year was estimated using Map 3 of the “NOAA
Technical Report NWS: Evaporation Atlas for the Contiguous 48 Unites States”.
Weather Data Resources:
• NOAA Climatological Data Annual Summary: Colorado 2018, Volume 123
Number 13, ISSN 0145-0506.
• NOAA Technical Report NWS 33: Evaporation Atlas for the Contiguous 48
United States; Washington, D.C., June 1982.
• NOAA Technical Report NWS 34: Mean Monthly, Seasonal, and Annual
Pan Evaporation for the United States; Washington, D.C., June 1982.
• ALTENBERN, COLORADO Period of Record Monthly Climate Summary;
Western Regional Weather Center (Impact Analysis tab)
The well pad was constructed in approximately 2008. Cut and fill work is complete. The
working pad surface and cut slope are stable and compacted. The well pad fill slopes
have 2-foot-high earthen berms, which are compacted to 95 percent soil/moisture
density. The outside slopes of the berms have 80 percent vegetative cover. The berms
are stable with high structural integrity. There is no uncontrolled stormwater on the well
pad. The well pad has a 6-inch-diameter drain at the center of the well pad. The drain is
piped outside of the berm to a trench. The trench drains to a catchment basin. Solids
settle in the catchment basin for removal. The stormwater evaporates.
The well pad is not in a 100-year floodplain. An unnamed drainage is approximately
316’ uphill to the south. An unnamed drainage is approximately 485’ cross gradient to
the north. The drainage contains woody debris and no stream features. The well pad
berm, cross-gradient topography, and distance prevent flow from the well pad from
reaching the drainage. There are no field verified wetlands downgradient of Well Pad
25A. The Surface Hydrology Map and a narrative exhibit describing the surrounding
hydrology is located in the Grading and Drainage Plan tab.
4. Section 4-203 (G) 3. Soil Characteristics
A description of soil characteristics of the site that have a significant influence on the
proposed use of the land.
A soils report from the Natural Resource Conservation Service (NRCS) indicates that
that one soil map unit exists in the area surrounding the proposed TPR 176-25 UIC
Well. NRCS Soils Report and Soils Map is provided in the Impact Analysis tab.
CPX TPR 176-25 UIC Well
Article 4 Section 203.G. – Impact Analysis
Impact Analysis Narrative
Administrative Review 3 CPX Piceance Holdings, LLC
Garfield County, Colorado 34 S. Wynden Drive, Suite 240
2022 Houston, TX 77056
Table 2: Map Units Present within Well Pad 25A
Map
Unit
Soil Type Percent Slope Description
338B Wetopa-Doughspon-
Echemoor families
complex
5 to 40 percent
slopes
Occurs on mountain slopes from 8,000 to
10,000 feet. Parent material is colluvium derived
from sandstone and shale. Not Prime Farmland
Table 3: Profile of Map Unit Composition and Profile
Family Composition Typical Profile
Wetopa 55%
A - 0 to 13 inches: silty
clay loam
Bt1 - 13 to 17 inches:
silty clay loam
Bt2 - 17 to 20 inches: silty
clay loam
Bt3 - 20 to 45 inches: silty
clay
BCt - 45 to 60
inches: cobbly
silty clay loam
Doughspon 30%
A1 – 0 to 4 inches: loam
A2 - 4 to 14 inches:
cobbly silt loam
Bt1 - 14 to 19 inches: very
cobbly silty clay loam
Bt2 - 19 to 30 inches: very
cobbly clay loam
BCt - 30 to 60
inches: very
cobbly clay
Echemoor 20%
A1 - 0 to 6 inches: silt
loam
A2 - 6 to 17 inches: silt
loam
ABt - 17 to 22 inches: clay
loam
Bt - 22 to 34 inches:
sandy clay loam
Cr - 34 to 60
inches:
bedrock
5. Section 4-203 (G) 4. Geology and Hazard
A description of the geologic characteristics of the area including any potential natural or
manmade hazards, and a determination of what effect such factors would have on the
proposed use of the land.
The Geologic Hazard Assessment, prepared by a Ken Walter, P.G. at Walter
Environmental and Engineering Group, Inc. of Grand Junction, determined landslides,
rockfall, collapsible soils, and avalanches are not a hazard at the location. The Geologic
Hazards Assessment and site photos are located in the Impact Analysis tab.
Additionally, a Seismicity Evaluation was conducted by Tom Feldkamp, P.G. and
Principal at High Ground Interests LLC. The Seismicity Evaluation concluded there is an
extremely low potential for induced seismicity during the proposed injection operations. The
Seismicity Evaluation, prepared in accordance with COGCC Rule 803.g.6, is provided in the
Impact Analysis tab.
6. Section 4-203 (G) 6. Environmental Impacts
Determination of the existing environmental conditions on the parcel to be developed
and the effects of development on those conditions.
Existing conditions on the parcel are previous disturbance from an approximately 5.5-
acre well pad containing two producing and one drilled but uncompleted natural gas
well.
CPX TPR 176-25 UIC Well
Article 4 Section 203.G. – Impact Analysis
Impact Analysis Narrative
Administrative Review 4 CPX Piceance Holdings, LLC
Garfield County, Colorado 34 S. Wynden Drive, Suite 240
2022 Houston, TX 77056
There are no anticipated incremental environmental impacts from UIC well development
because the location has already been developed for natural gas wells and the UIC well
will serve only CPX fluid delivered by flowline. There will be no additional soil
disturbance. Dust controls and stormwater controls are addressed in mitigation for the
natural gas wells and consist of observing posted speed limits, watering the access
road, and diverting stormwater from the well pad to a trench and catchment basin. The
UIC well represents limited truck transport to deliver tanks designated for the UIC well
disposal system.
6.1. Section 4-203 (G) 6. a. Determination of the long-term and short-term effect on
flora and fauna;
The TPR 176-25 UIC Well will be located on an existing location using an existing
wellbore, so no impacts to flora and fauna will occur due to any construction or drilling
activities. Operation of the TPR 176-25 UIC Well will reduce water truck traffic to and
from the site, reducing any indirect impacts from truck traffic on flora and fauna.
6.2. Section 4-203 (G) 6. b. Determination of the effect on designated environmental
resources, including critical wildlife habitat
There is not mapped critical habitat for federally Threatened, Endangered, or Candidate
wildlife species at the site. CPX received a waiver from Colorado Parks and Wildlife
(CPW) for a location between 300 and 500 feet of cutthroat trout high priority habitat
(HPH) and will comply with all applicable BMPs. The nearest mapped terrestrial HPH is
Elk Production HPH 4,350 feet to the east. The well pad represents a continued land
use that is separated from mapped elk habitat by a ridgeline, approximately 0.75 miles
of spruce/fir forest and aspen woodlands, and a drop of approximately 400 feet from the
ridge into the next drainage, the Mamm Creek drainage. The combination of
topography, forest cover, and distance avoids impacts to mapped HPH The conversion
of the existing well into an injection well not result in additional surface disturbance nor
fragment wildlife habitat. CPX will not impact natural drainage patterns by utilizing an
existing location.
6.3. Section 4-203 (G) 6. c. Impacts on wildlife and domestic animals through
creation of hazardous attractions, alteration of existing native vegetation,
blockade of migration routes, use patterns, or other disruptions
Operation of the TPR 176-25 UIC Well will not create a hazardous attraction to wildlife
or domestic animals, nor will it alter existing native vegetation as the well and pad are
both existing. No big game migration corridors are mapped at the site, and the location
of the injection well within a row of production wells on an existing production pad will be
contextually inconspicuous.
CPX TPR 176-25 UIC Well
Article 4 Section 203.G. – Impact Analysis
Impact Analysis Narrative
Administrative Review 5 CPX Piceance Holdings, LLC
Garfield County, Colorado 34 S. Wynden Drive, Suite 240
2022 Houston, TX 77056
6.4. Section 4-203 (G) 6. d. Evaluation of any potential radiation hazard that may
have been identified by the State or County Health Departments.
The Geologic Hazard Assessment, prepared by a Ken Walter, P.G. at Walter
Environmental and Engineering Group, Inc. of Grand Junction, concluded that no
radiation hazard has been identified by the State or County Health Departments. The
Geologic Hazards Assessment (Impact Analysis tab) states no radioactive minerals
are plotted within several miles of the Site.
7. Section 4-203 (G) 7. Nuisance
Impacts on adjacent land from generation of vapor, dust, smoke, noise, glare or
vibration, or other emanations.
Nuisance from noise, lighting, and dust is not anticipated. Smoke, vibration, and vapor
is not expected to occur as a result of operations at the proposed facility. The TPR 176-
25 UIC Well is not located within one mile of any residential buildings units or
designated outdoor areas. The proposed UIC well is located approximately 2,200 feet
from nearest parcel boundary with a different surface owner.
7.1. Lighting
TPR 176-25 UIC Well will not require lighting for operations. No lighting or utilities will
be installed for operations of the proposed UIC well. All lighting will adhere to the
Lighting Standards stated in Article 7 of the Garfield County LUDC.
7.2. Noise
Nuisance from noise is not anticipated from operations of the proposed UIC well. The
TPR 176-25 well is not located within one mile of any residential buildings units or
designated outdoor areas. 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.
Noise generated associated with injection well will be similar to other oil and gas
activities on Well Pad 25A.
7.3. Dust
CPX implements fugitive dust controls at Well Pad 25A and throughout the TPR. BMPs
for dust mitigation are described in Table 4.