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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.